In Elijah R. v. Superior Court (1998) 66 Cal.App.4th 965, visitation and phone calls were denied because the child was young and the father was incarcerated in Nevada. The record "painted a picture of a father who, as the result of his criminal activities which had been ongoing for 20 years, fathered a child and then promptly reoffended, with the result that he was confined for the greater part of the reunification period in a distant, out-of-state prison." ( Id., at p. 971.)