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In re A.A. CA4/1
V.S. (Mother) challenges the juvenile court's denial of reunification services
related to A.A. (Minor 1) based on the prior termination of reunification services for a
half sibling of Minor 1 and Mother's failure to make a reasonable effort to treat the
problems that led to removal of the half sibling. (Welf. & Inst. Code, § 361.5, subd.
(b)(10).)1 We conclude there was substantial evidence to support the court's finding
Mother did not make a reasonable effort to treat the problems that led to the removal of
Minor 1's half sibling. We further conclude the court did not abuse its discretion or
violate Mother's substantive due process rights by denying her reunification services but
granting services to Minor 1's biological father. We affirm the judgment.2

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