Is it legal for an Agency to proceed to adopt a dependent toddler (A.K.) out of her biological family when the record contains no "written notification" of child's detention to any of her paternal relatives (or any other form of notification) in violation of US Public Government Law 110-351; California Welfare and Institutions code §309 (e)(1); California Rule of Court 5.695 (e)(1)(2) and (f); and California Rule of Court 5.722 (5)(A-D), and despite the Agency having identifying information with which to contact such relatives (i.e. social security numbers, names, dates of birth, an employment location where uncle was manager), and despite such relatives being on programs the Agency uses for family-finding (i.e. Medi-Cal, HUD, having valid drivers licenses, California IDs, grandmother being on disability, grandfather and uncle both veterans, uncle running a foster care facility and being a pediatric nurse)? (grandparents, aunt, uncles, sibling, parent of siblings, great-aunts, great-grandparents all denied notification) (2 CT 514, 515, 555-562, 525-527; 546-547; SCT 740-742, 755-756, 620-621, 632-633, 642-651, 654-659, 719-721, 731-732, 727-728, 737739, 729-730, 746-748, 733- 734, 749-751, 735-736, 752- 754, 743-745, 757-758; 579-582)

Is it legal for a toddler with worsening medical conditions that the Agency directly attributes "to her heavy use of steroids to control her asthma/wheezing," such as: starting to grow "pubic hair" at less than 2 years old, and recurrent episodes of "oral and pharyngeal thrush" (yeast infection of the mouth) along with continued "visits to immunology," to be denied her state and federally-guaranteed right to permanence with her biological family when they live in an area medically documented to improve toddler's asthma in as little as 1 week, and even reduce or eliminate her need for steroid medications altogether, thus eliminating her current worsening medical conditions, i.e. being in her best medical interests? (4CT 885, 886; 4CT 1083, 959; S253971 Supreme Court Petition for Review Exhibit 3; 4RT 145, 160, 161, 164; 4CT 954.977)

Does A.K.'s immediate medical need, coupled with the fact that none of her paternal family were ever notified, constitute 'fa changed circumstance" that would warrant new placement with relatives? "Section 388 provides a procedural vehicle to change a child's placement based on changed circumstances," and "is appropriate for a child who has been freed for adoption... 388 encompasses any change in circumstances affecting the dependent child." (In re A. C. (2010) 186 Cal.App.4th 976, 978.)

Is it legal for Agency to deny an entire paternal side notification because, as defacto counsel argues: "The Agency was under no legal obligation to notify the paternal grandmother because A.K. was in a stable placement offering permanency"? (4CT 891) And if so, how does this match up with Rule of Court 5.722 (5) (A-D) which requires relatives

Is it legal for an Agency to proceed to adopt a toddler out of her biological family when the record contains no written notification to any of her paternal relatives?