In In re E.M. (2012) 204 Cal.App.4th 467, the court applied the doctrine in a dependency proceeding where the mother had absconded with the children to Mexico and kept them concealed for years, following a finding that her husband had sexually abused her daughter. By the time of the jurisdictional hearing, the mother had been located and was cooperating with DCFS under the supervision of Mexican authorities, contacting the caseworker monthly, and attending parenting and sexual abuse classes. Although the mother was no longer a fugitive or in contempt of court orders, the Court of Appeal found that the mother's "continuing absence with the children from the jurisdiction . . . prevented the juvenile court from ensuring that she was in compliance with its legal orders and processes" and from "ensuring compliance with court-ordered therapy, parenting, and sexual abuse programs," thereby "undermining and frustrating the purpose of the dependency law." (Id. at pp. 477-478.) Accordingly, the mother's conduct "was sufficiently egregious to warrant the application of the doctrine of disentitlement" and dismissal of her appeals of the court's jurisdictional and dispositional orders. (Id. at p. 478.)