Whether the denial of appointed counsel for indigent parents harmed them and their children, violated due process, and deprived them of their parental rights

QUESTIONS PRESENTED L Whether the denial of appointed counsel for parents found to be indigent in the trial court despite multiple requests for an attorney to protect their interests, coupled with the subsequent ineffective assistance of two separate belatedly appointed counsels after the first of two termination trials, harmed the parents and children due to the unfair advantage it gave the state in the adversarial proceedings in the trial court, failed to protect the parents from multiple violations to their rights to due process, and subjected them to the unlawful erroneous deprivation of their : fundamental liberty interest to protect and preserve their parental rights. : Did the failure of the appointed attorney to object to the Sua Sponte transfer of the case by the trial court judge which changed the venue of the case without offering any opportunity for hearing or objection, along with other acts and failures to act, deprive parents of due process by failing to uphold their right to competent counsel? ; IL. Whether the trial court violated the Due Process Clause by holding termination of parental rights proceedings beyond the automatic : dismissal date set. by Texas Family Code §263.401 without making the necessary finding of extraordinary circumstances and entering orders which schedule the new dismissal date, failing to make further temporary orders for the safety and wellbeing of the children, and not setting the trial for the merits as specified, thereby exceeding its jurisdiction and : depriving parents of their right to Due Process. In addition, did the trial court again fail to abide by the statutory provisions set forth in Texas Family Code 263.4011 when it did not issue a final order within 90 days of . the timely commencement of the trial on February 15, 2022, and subsequently only signed the final order June 23, 2022 under cause No ‘ CCL20-16990. Did the trial then neglect to dismiss the case when the new trial was granted upon which the case status was set back to the status it was in prior to the commencement of the February trial (Texas Rules of Civil Procedure Rule 29.1(b)), thus putting the case well past the previously date set by extension of the case of February 14, 2022, due to the Deparment’s inability to file additional case extensions from those previously ordered under Texas Family Code 263.402? . Til. Whether the procedures of the trial court and the Texas Department of Family and Protective Service risked cutting off critical Federal foster care funding to Texas due to noncompliance with ASFA and Title IV-E. Also whether the trial court’s failure to follow fundamentally fair — procedures also violates the provisions of ASFA, due to the trial court’s obvious bias against the Petitioners due to the trial court allowing the ; Page 2 of 30 , . ls Department to violate the rules of production and discovery when offering its evidence after the periods of discovery had passed and before submission to the Petitioners, in effect “blindsiding” the Petitioners with certain evidence in open court which deprived them of an opportunity to examine their evidence or object. 7 Page 3 of 30