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IN RE WELFARE OF S.I.

Nos. 31727-7-III, 31728-5-III.

337 P.3d 1114 (2014)

In re the WELFARE OF S.I., D.D.

Court of Appeals of Washington, Division 3.

November 18, 2014.

Attorney(s) appearing for the Case

Eric J. Nielsen , Jennifer J. Sweigert , Nielsen Broman & Koch PLLC, Seattle, WA, for Appellant.

Rebecca L. Prahl , Office of the Attorney General, Spokane, WA, for Respondent.

LAWRENCE-BERREY, J.

¶ 1 A party who fails to appear in an action is not entitled to notice prior to entry of a default order. We are asked to decide whether a mother who appeared and participated in a dependency action yet failed to appear in a subsequent termination proceeding is required to receive notice prior to entry of a default order in the termination proceeding. We hold that a dependency proceeding is separate...

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