In re Candida S.
CA.40629; 7 Cal. App. 4th 1240; 9 Cal. Rptr. 2d 521 (1992)
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[7 CalApp4th Page 1243] After a contested six-month review hearing held pursuant to Welfare and Institutions Code section 366.21, subdivision (e)1
in a dependency proceeding regarding the four minor children of Rebecca and Shelby S., the juvenile court found that reasonable
reunification efforts had been offered to Rebecca and Shelby and that they had not successfully satisfied the reunification
plans. The court scheduled a 12-month review hearing pursuant to section 366.21, subdivision (f) for January 16, 1991. Each
parent separately appeals from the decision. (No. H007959.) Shelby argues (1) section 366.25, rather than 366.26, applied
to these proceedings because the children were adJudged dependent on December 5, 1988; (2) the court's determination that
reasonable efforts had been made to assist him with reunification was erroneous because (a) it was not supported by the evidence,
(b) the reunification plans were unreasonable, (c) the court held the parents to a reunification plan different from the one
they signed, and (d) the court failed to advise Shelby that he would be protected by use immunity if he admitted to sexual
abuse. Rebecca joins in Shelby's arguments and adds two additional arguments: the court erred in failing to order visitation
and in failing to appoint separate counsel for each minor.