OPINION
SILLS, P.J.
I. The Case
When Eileen, then a little more than a year old, was made a dependent of the juvenile court in the fall of 1999, the trial court denied any reunification services to her mother, Olga, because of the severity of physical abuse perpetrated by the father, Jose. (See Welf. & InstCode, § 361.5. subd. (b)(5).
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