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Christi F. v. Super. Ct.
Christi F. seeks review of a juvenile court order setting a hearing under section 366.26. She contends the court improperly applied the disentitlement doctrine, which deprives a party of the right to present a defense as a result of the litigant's violation of the processes of the court. Christi contends the denial of her right to present evidence and cross-examine witnesses at the 12-month review hearing requires reversal of the order terminating reunification services and setting a section 366.26 hearing.
Although the application of the disentitlement doctrine at review hearings in juvenile dependency proceedings will be rare, on this record we cannot conclude that the court erred in applying the doctrine. Accordingly, we deny the petition.

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