Whether the petitioner's right to due process and 7th amendment right and Massachusetts rule 38 Jury Trial of Right was violated

QUESTION(S) PRESENTED | 1. Whether the petitioners right to due process and 7th amendment right and Massachusetts ruje 38 Jury Trial of Right was violated when petitioner filed timely written demand on February 20, 2022 and was denied on October 19, 2020 and April 22, 2021. 2. Whether the judge violated mother's rights to due process when she Sua sponte without clear and convincing evidence terminated her parental rights to all her children despite the fact the department did not have custody of any of the children and did not present an adoption plan and was not seeking the termination of mother's parental rights at the time of trial | 3. Whether the evidence was clear and convincing that mother's parental rights should have been terminated because three of the children were living with her at the time of trial and DCF was not seeking to terminate her parental rights or remove them from her care and custody, 4. Whether the termination of mother's parental rights was in any of the children's best interest where they had lived all of their lives with mother and we're bonded with her. 5. Whether the mother should be granted further review because the judge's decision to terminate mother's parental rights to all her children Sua sponte mother had custody of all three children at the time of trial two of the children turned 18 on October 21; 2023 all of the children were bonded with their mother and DCF was not seeking termination at the trial and never submitted an adoption plan. 6. Whether the course of decision to terminate mother's parental rights leaving the children as legal orphans with no adoptive home and no adoption plan determination served no purpose except to punish mother for her conduct during the trial. 7. Whether the appeals court erred in ruling that the mother's conduct at trial was consistent with her parenting deficiencies warranting determination of her parental rights even though she was appropriately parenting her children and that DCF did not seek to remove the children even though mother was hot engaged in the department services. 8. Whether the judge violated mother's due process rights and committed ; reversible error by terminating mother's parental rights to all her children because she could not Sua sponte decide in the issue that was not raised by the parties or properly before the court where the parties have not had notice an opportunity to address the issue. In this case the department never sought to terminate mother's parental rights and the department did not submit an adoption plan as required by statute. 9: The three boys remained in their mother's care and custody from April 7; 2020 and throughout the trial after the mother filed a motion to stay the judgment with the single justice she retained custody of the boys because Justice Englander granted her motion to stay in the judgment because DCF agreed after trial at the single justice hearing that it was still not seeking to terminate mother's parental rights, the twin girls were not in departments } custody but was placed with a third party 10. Whether the fundamental right and the due process is to receive notice as to what rights are being deprived mother was entitled: to know what was at stake at the trial in order for her to appropriately prepare for her defense though the summons mentioned the possibility that her parental rights might be terminated the understanding of the time of the trial was that DCF was only seeking custody states relief sought including whether or not there will . be a request for a decree dispensing with the need for parental consent of adoption custody guardianship or other dispositions other child named in the petition custody and termination of parental rights intertwine in the standard for each and the resulting consequences are significantly different serious problems may be created whether a judge bases a decision on the issue that is not before the court. 11-In this case there was no adoption plan for