In Re Jennifer J.

Gerald J. (Father) and Cynthia T. (Mother) appeal from a judgment following a selection and implementation hearing under Welfare and Institutions Code 2 section 366.26, which terminated their parental rights and placed their two children, Jennifer and Richard, for adoption. Both Mother's and Father's appeals included efforts to achieve review of certain orders made at prior review hearings. 3 Upon respondent's motion to limit the scope of appeal, this court determined that the review efforts which were the subject of the motion could not be challenged following the selection and implementation hearing. Following In re Taya C. (1991) 2 Cal.App.4th 1 [ 2 Cal.Rptr.2d 810 ] and In re Amanda B. (1992) 3 Cal.App.4th 935 [ 4 Cal.Rptr.2d 922 ], we ruled that review of interim orders made at review or reference hearings must be undertaken by timely writ petition and cannot be achieved as part of an appeal from a selection and implementation hearing judgment. We therefore issued an order limiting the scope of appeal.

The contentions which remain for determination are as follows:

I. Error in the court's denial of Mother's request for testimony from the oldest child, Jennifer (Mother's…