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Adoption of Sophia D.
Adoptive father Randy C. challenges a trial court order approving a postadoption contact agreement entered over his objection after the trial court excused the biological fathers failure to comply with an earlier oral agreement. He contends the order failed to comply with the requirements of Family Code section 8616.5. Court agree, and reverse on that basis. Court need not and do not reach Randys other arguments that the order violated his substantive due process rights as a parent, that the court lacked jurisdiction to enter the order, and that the evidence was insufficient to support the order.

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