California, United States of America
The following excerpt is from Adoption Los v. W.R., 2d Juv. No. B264073 (Cal. App. 2015):
the other issues. [Citation.] Where there has been no showing one way or the other, however, the court's failure to appoint counsel is deemed erroneous.' (Neumann v. Melgar, supra, 121 Cal.App.4th at pp. 170-171.)4
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