ANNUNZIATA, Judge.
The issues in these consolidated appeals arise from a decision of the Circuit Court of the City of Fredericksburg denying a petition filed by the Fredericksburg Department of Social Services District ("DSS") to terminate the parental rights of Clyde Brown ("father") and Joyce Williams ("mother"), parents of four minor children. DSS's petition was denied on the ground that Code § 16.1-266(C) required the appointment of counsel for the parents...
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