In re D.R.
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Father appealed the denial of his motion to modify judgment because DCFS failed to give him adequate notice of dependency proceedings involving his children. The Court of Appeal held that the juvenile court erred by finding that notice through publication was adequate, because DCFS's efforts did not constitute reasonable due diligence.
The court also held that the Hague Service Convention applied in this case because father is a resident of Mexico, and there was no compliance with the Convention as to notice for the jurisdictional and dispositional hearings. Accordingly, the court reversed all orders as to father and remanded with instructions to commence de novo with arraignment and adjudication after providing father with proper notice.
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