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| | Reasonable Efforts Volume 1, Number 6, 2004 |
 | | N.X.,5 the Delaware Family Court held that the state did not meet its burden of demonstrating, by clear and convincing evidence, that reasonable efforts had been extended. |
 | | The Court noted that DFS had only provided a chemically dependent mother with referrals for out-patient treatment programs even after the department’s drug treatment professionals had recommended in-patient programming to address the mother’s addiction. |
 | | Beyond chemical dependency treatment, in other cases the services provided range from a bare minimum of counseling and transportation assistance, to a comprehensive package of services including counseling, housing assistance, parenting aides, and homemaker services. |
| www.ndaa-apri.org /publications/newsletters/reasonable_efforts_volume_1_number_6_2004.html (1393 words) |
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