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IN RE PAUL E.

Docket No. G017932.

39 Cal.App.4th 996 (1995)

46 Cal. Rptr.2d 289

In re PAUL E., a Person Coming Under the Juvenile Court Law. ORANGE COUNTY SOCIAL SERVICES AGENCY, Plaintiff and Respondent, v. SUSAN E. et al., Defendants and Appellants.

Court of Appeals of California, Fourth District, Division Three.

October 25, 1995.

Attorney(s) appearing for the Case

COUNSEL

John L. Dodd, Ann H. Qushair and Jane Winer, under appointments by the Court of Appeal, for Defendants and Appellants.

Laurence M. Watson, Chief Assistant County Counsel, and Gene Axelrod, Deputy County Counsel, for Plaintiff and Respondent.

Harold F. LaFlamme and Linda M. O'Neil for Minor.

OPINION

SILLS, P.J. —

INTRODUCTION

In this case we hold the safeguards afforded parents by section 361 of the Welfare and Institutions Code apply just as much to supplemental petitions filed under section 387 of the same code as they do to initial petitions. We further hold that mere chronic messiness in housekeeping, absent unsanitary conditions or resulting illness or accident, is not the clear and convincing evidence...

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