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In re Summer B.
In April 2005, Summer B. was taken into protective custody by the Orange County Social Services Agency (SSA) shortly after her birth, 10 weeks premature. SSA provided reunification services to Summers mother and biological father for 18 months; at the end of that period, the juvenile court concluded the fathers progress on his case plan had been unsatisfactory, terminated reunification services, and set the matter for a permanency hearing.
Court conclude the juvenile court did not abuse its discretion in denying the section 388 petition without a hearing. The petition did not make a prima facie showing of changed circumstances or that it was in Summers best interests to modify the previous order. Additionally, there was substantial evidence supporting the juvenile courts finding that the parent‑child relationship exception to adoption ( 366.26, subd. (c)(1)(A)) did not apply. Visitation between Summer and her father had not been regular, and there was no evidence Summer would benefit from maintaining a relationship with her biological father. Courttherefore affirm.

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