Prior to the finalization of an adoption, where there is a substantial failure of a material condition of a surrender executed pursuant to Social Services Law § 383-c, Family Court may rehear the matter sua sponte, or upon petition by the agency, parent or attorney for the child (see Family Ct Act § 1055-a [a]). Here, however, it appears that the adoption of the child was finalized during the pendency of this appeal. Thus, the parties' rights will not be...
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