San Diego County Department of Social Services v. Tina G.

Tina G. appeals a judgment of the juvenile court terminating her parental rights under Welfare and Institutions Code 1 section 366.26 as to her minor daughter Tabatha G. Tina contends the court erred in (1) failing to apply a “best interests” exception to terminating her parental rights based on Tabatha’s relationship with her grandmother and (2) ordering the discovery of a bonding study between Tabatha and Tina in violation of the attorney work product doctrine and the psychotherapist-patient privilege. We affirm.

Factual and Procedural Background

The circumstances of Tabatha’s history as a dependent child of the juvenile court and Tina’s involvement with San Diego County Department of Social Services (Department) are set forth in detail in two unpublished opinions from this court in prior appeals, Tina G. v. Superior Court (Jan. 7, 1993) D017092 (nonpub. opn.) and In re Tabatha G. (Sept. 18, 1995) D021804 (nonpub. opn.). For purposes of this appeal, we have taken judicial notice of the records in those cases. Accordingly, we limit our recitation of the facts and procedure to matters relevant to the court’s findings and order at the selection and implementation hearing…