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In re S.G. CA4/3
The minor, S.G., and Orange County Social Services Agency (SSA) appeal from a July 2017 juvenile court order extending reunification services to mother, J.G., at a hearing held pursuant to Welfare and Institutions Code section 387. The 24-month review hearing was scheduled for November 2017 but was continued into January 2018, and SSA was advocating before the juvenile court that the hearing be continued yet another 60 days to coincide with a period of trial custody for mother.
Appellants argue the juvenile court was statutorily barred from offering mother further reunification services at the section 387 hearing because mother had already been provided with 18 months of services, and she did not meet the criteria for more services under section 366.22, subdivision (b), therefore, the court should have scheduled a permanency plan hearing under section 366.26. They further argue the court lacked discretion to continue the hearing under section 352.

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