the sister in law of that i live for that i'm sorry the foster mother and to present other testimony relevant to the bias and pervasive interference that had ben  misstep in this case on behalf on the part of catholic charities that evidence that the biological mother's times the fourth year was excluded on objection the state on the grounds of relevance however this is an abuse of discretion because this type of evidence is clearly relevant under illinois case and was a part of the mounting evidence that had been presented that demonstrated that catholic charities and specifically the d c i think caseworker assigned to the biological mother's case had treated her case as an adoption from the outset not as a foster situation where the minor child would be honor that is that is the point that we were trying to make when this evidence was offered that there were some situations where catholic charities interfered with the mother's attempts to complete the  well she needed to complete her service plan and she needed satisfactory evaluations of her service and there were instances where she was given unsatisfactory evaluations for situations over which she had no control or for instance when she was on the section question that you stated is supposed to be asked under their own a supreme court decision and say this question is for us to be asked and answered in the context of so have circumstances it's not simply that biological mothers kind act in a vacuum th biological mother's contact should be considered in the context of whether the child's residence the actions and statements of others that hinder or discourage visitation along with whether the parent's failure to visit a child was motivated by need to cope with personal circumstances rather than the true indifference or lack of conservative child so here on earth by denying this type of evidence the trial court failed to consider this step the biological mother's conduct in the circumstances because it foreclosed her avondale of entering evidence that tended to demonstrate that her progress was current consistently and purposely interfered with by catholic charities and her case worker so the answer to transportation and kind of the context that's been required to be considered by the supreme court she said she did testify to some of the problems that she had communicating with catholic charities to understand this time traveler who was charged with administering this plan and charged with getting this mother back on track and reunited with her child and plainly did not do south did not have this boy in mind did that counseling she made an agreement with catholic church she would go to counseling through memorial the caseworker did not ever speak to her counselor through more she testified with regard to drug testing and drug counseling with  trying caseworker testified specifically that she would sometimes all referrals for two or three weeks or even a month and admitted that with someone who has had drug problems and they ask for the referral to the drug counseling it's imperative that you get that biological mother come to the visitations an hour then they would call the foster parents and try to bring the child there sometimes she would come sometimes she would there were three periods of visitation right around the holidays with the mother  advance i want to use one of these periods of visitation to get a holiday picture mysteriously the child was gone and thanksgiving and the two visitations between thanksgiving first so i mean there are there is a problem here and all all the biological mother here is the evidence i agree catholic church it's not a problem but you do get put on evidence about a hindrance some kind of hindrance and she is it seems to me you know the  if you can imagine she was not a very friendly witness for me she could say a catholic charities pull my sister and brother in law that would you be an offer proof i took i told the judge i explained to the judge what the the service provider told the foster family from day one when they said hey we're a doctor only family if they said no problem this is going to be an adoption you're set and that's what it sounds like from the letter that's what it sounds like it sounds like the foster family said wait don't give us this child if you're going to take it back and catholic charities sure sure this family that that's what would so a j i mean if hearing this evidence of that doesn't seem to be a stay of the fit here where i asked you what you'd say if you say you're not sure what we know we know from the letter at least at least the summary of what she's going to say and the judge said anything any any obstruction essentially by catholic charities is not to be fair yes they did but this does they think what both ways they work to confirm that the mother was going to be there but then they would also know that the mother or for instance at some point the the hour or hour long wait for the child  there that conflicted with triangle points which for an hour later so the child wouldn't necessarily be there and those would swing the other way and then that the biological mother would get one satisfactory evaluation for being late to a hear hear what happened between catholic charities foster family at at when when the child's place i think the judge should hear that if after hearing all of this he says you know you know this is still  it's the ferry is purpose behind certain things like the trial judge i can't infer the purpose of the things they did whether there was this conversation or not whether  at the letter if i had no evidence and it was just we we did five service plan i would agree with you but we did have evidence from directly from the caseworker about not contacting the counselor speaking of counsel but never making a home  relevant in the my my final argument is that even if the court did air there was no respondent cannot show that she was prejudiced in any way from this evidence not being admitted first i think we need to look at the remote mists of what it seems like michelle wants testimony was the letter specifically said that miss barnes was basing what she knew on conversations that a caseworker had with her sister so i mean we're already dealing with hearsay upon hearsay and i think there were moments of the sister of the foster mother's the sister the foster mother testifying about a conversation that the foster mother had with the caseworker it's all right i just think the remoteness of the testimony itself demonstrates that it's not relevant if this is saying he's for the test we don't know the letters the letter vaguely said it was a caseworker so we do not even know what you have that shows the services i do not remember if it even said specifically that it was catholic charities i actually do not believe that it said specifically who even that the wording is a sion was but i do know that it did not refer to a name of the case for me just remotely said that her sister had conversations and the caseworker had told them something that to the effect of this case was basically set  testifying to but we do know that they called her to testify based on the contents of this letter and the contents of this letter to show that michelle barnes was basing her testimony or what she was whether complaints were about the way that this the way th case was progressing over this three year period on conversations that her sister had had with the caseworker also i do not think in the letter shows sitting examples over response counsel argues that it shows that this the catholic charities view this case as an adoptee only case from the get go nothing in the letter showed pacific examples of impediments or blocks that catholic charities had placed to prevent responding from from doing the things that are required in or service place and from there our focus on the things that specifically from the record completely separate of anything the caseworker had to do with of the actions  respondent made they could not of been impeded by catholic charities warning that individual counseling at the fitness hearing specifically responded actually testified that and this is page eight of brief she says that she attended individual counseling but she did not complete it and this is her quote due to financial issues and having to pay for counseling on my own and no medical card no great transportation and that's basically all so we're going individual counseling responded to not testify in any way that catholic charities or a caseworker had impeded her ability to complete the individual counseling and you can look at that she does say that she had no transportation the caseworker in this case brown did testified that when responding would approach him and say that she did not have transportation that he would give her tokens for transportation we're going to mastic violence counseling it sojourner responded testify that i did participate with soldier  got to where i just the transportation issues was a problem and then that's basically all i can say about soldier i didn't do so german i participated the soldier probably three or four sessions so again from response on testimony she does not blame the reason why she didn't complete so overtures she and this is what i have on page forty six and forty seven the record that wound which was a caseworker in catholic charities were unfair to her throughout this case and she specifically said that she would attempt to call them but they would not return her calls she also testified she attempted to retain referrals from triangle she said that she attempted to obtain referral seventy eight times but triangle would not accept or because brown did not sign the referrals trial that was her testimony regarding what brown did regarding the counseling a triangle also i think that a lot of what responses are you want to appeal is that catholic charities specifically impeded her billy to to visit her daughter katie during the course and i think it's important look at the numbers and if you look at the records some of the numbers were the total visitations were the numbers were were different a few times but i think that the disparity in in may visits and missed visits never changed and during the course of this case respondent missed eighty three out of a possible one hundred seventeen visits she missed eighty three out of a possible one hundred  were i believe there are catholic charities there is a look i'm unsure your honor but like i said i think you could look at the totality of this record and say you know what i'm not sure that and if you've done more than a couple of these cases you realize that never they've done perfectly and i think you can look at this right and you say there are things that could have been done differently there are things that probably should have been done differently but there are things that respondent simply failed to marijuana on april twentieth two thousand i actually tested positive for marijuana and cocaine she was also arrested twice during the life of this case so all this goes to show that while this case could have been probably should have been handled better like most these cases could respond make conscious decisions on a consistent basis not to do the things that she needed to do in order fraidy to return to her care and if your honour's you don't have any other questions yes i the show yet she has had a previous child her parental rights were terminated previously kooser twice well i i have i believe twice but i'm under the impression that this  caseworker i'm specifically another child with the initials h d this caseworker brown also handled that case that's my impression typically the reason i asked as i want to review it to be sure that whatever else we have with how you handled this case or your the idea that you might have in your head this isn't docked on the case and and we know exactly what's going to happen here and any task i know he didn't deny the mindset this is undocked on the case but it's a possible also to to argue that he would have  had been given a place yet she found one satisfactory because of housing but she was living with her mother found her own satisfactory on the on the issue of staying out of criminal problems on an