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In re J.L. CA6
Four-year-old J.L. was freed for adoption under Welfare and Institutions Code section 366.26 after the court terminated reunification services provided to his mother, M.S. (mother), and then terminated her parental rights. Mother appeals, contending that the court abused its discretion by denying her section 388 petition to restart services because she had recently made significant progress in addressing the issues that had led to J.L.’s dependency. We find no abuse of discretion in the court’s denial of that petition. Because mother is unable to show error in the ensuing termination of her parental rights, we must affirm the order.

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