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Name: In re Z.W.
Case #: C065746
Court: CA Court of Appeal
District 3 DCA
Opinion Date: 04/07/2011

There was no ICWA notice error where notices were sent to correct agent list which was later amended. Mother contended that the Department sent ICWA notice to the wrong agents, relying on a list of agents published in May, 2010. The appellate court rejected the argument, noting that the last revised ICWA notices were sent two and a half months prior to the publication of the new list of agents. The notices were correct at the time they were sent and received. Further, even if the agents had changed, the addresses had not. Mother forfeited her claims of error regarding the content of the notice because the matters were not raised in the trial court. Any inadequacies could easily have been corrected had they been brought to the juvenile court’s attention.