<p> TABLE OF CONTENTS</p><p>Page</p><p>TABLE OF AUTHORITIES ii</p><p>ISSUES PRESENTED 1</p><p>STATEMENT OF THE CASE 1</p><p>STATEMENT OF FACTS 3</p><p>SUMMARY OF THE ARGUMENT 12</p><p>ARGUMENT 16</p><p>I. In a “lack-of-supervision” case, the Juvenile Court erred in terminating Mother’s parental rights to Travis and Daniel when it ignored evidence favorable to Mother during the two years prior to trial, including evidence of Mother’s appropriate supervision of the boys’ sister who had similar needs, and Mother’s participating in services that showed her commitment to correcting her parenting shortcomings. 16</p><p>A. The Juvenile Court erred in disregarding Mother’s appropriate care of the boys’ sister, Juno, whose needs were similar to those of the boys. 20</p><p>B. The Juvenile Court erred in disregarding evidence relevant to Mother’s parenting and commitment to the boys during the two years prior to trial. 26</p><p>C. The Findings with respect to Mother’s conduct in the two years from the date of the care and protection stipulation to the termination trial do not constitute clear and convincing evidence of parental unfitness. 29</p><p> i II. The Juvenile Court erred in failing to consider the boys’ strong bonds to their Mother and their unequivocal and often-repeated wish to return to her care. 32</p><p>III. The Juvenile Court abused its discretion in refusing to order post-termination and post-adoption visitation between Mother and the boys because the evidence of a significant bond between them is overwhelming and undisputed, and the boys have no bonds with substitute caretakers. 41</p><p>CONCLUSION 46</p><p>TABLE OF AUTHORITIES</p><p>Cases Page</p><p>Adoption of Helen, 32, 41, 42 429 Mass. 856 (1999)</p><p>Adoption of Inez, 39 428 Mass. 717 (1999)</p><p>Adoption of Iris, 20 43 Mass. App. Ct. 95 (1997), S.C.,</p><p>427 Mass. App. Ct. 582 (1998)</p><p>Adoption of John, 44 53 Mass. App. Ct. 431 (2001)</p><p>Adoption of Katharine, 18, 20, 32 42 Mass. App. Ct. 25 (1997)</p><p>Adoption of Lenore, 41, 42 55 Mass. App. Ct. 275 (2002)</p><p>Adoption of Lorna, 37 46 Mass. App. Ct. 134 (1999)</p><p>Adoption of Paula, 18 420 Mass. 716 (1995)</p><p> ii Adoption of Rhona, 17, 18, 19, 22, 23, 26, 29, 31 57 Mass. App. Ct. 479 (2003)</p><p>Adoption of Stuart, 28 39 Mass. App. Ct. 380 (1995)</p><p>Adoption of Terrence, 42, 43 2003 Mass. App. LEXIS 494 (2003)</p><p>Adoption of Vito, 41, 42, 43, 45 431 Mass. 550 (2000)</p><p>Bak v. Bak, 37 24 Mass. App. Ct. 608 (1987)</p><p>Custody of a Minor, 37, 38 383 Mass. 595 (1981)</p><p>Custody of Eleanor, 19 414 Mass. 795 (1993)</p><p>Custody of Vaughn, 36 422 Mass. 590 (1996)</p><p>Lonergan-Gillen v. Gillen, 44, 45 57 Mass. App. Ct. 746 (2003)</p><p>Petition of Catholic Charitable Bureau of the 22 Archdiocese of Boston, Inc., to Dispense with Consent to Adoption, 395 Mass. 180 (1985)</p><p>Petition of the Dep’t of Social Servs. to 19 Dispense with Consent to Adoption, 18 Mass. App. Ct. 120 (1984)</p><p>Petition of the Dep’t of Social Servs. to Dispense with Consent to Adoption, 32, 33 392 Mass. 738 (1984)</p><p>Massachusetts Statutes/Regulations/Rules G.L. c. 119, § 24 1 G.L. c. 119, § 26 2, 25</p><p> iii G.L. c. 119, § 51A 4, 5, 6, 21, 30 G.L. c. 210, § 2 38 G.L. c. 210, § 3 32, 36 G.L. c. 210, § 5A 40 110 C.M.R. § 4.32 31 Mass. R. Prof. C. 1.14 37</p><p> iv</p>