In In re Elaine E. (1990) 221 Cal. App. 3d 809, the Court considered the scope of a section 364 hearing to terminate juvenile court dependency jurisdiction. The trial court had dismissed dependency petitions that had been filed on behalf of a father's three natural children after he had sexually molested his adopted daughter. Prior to terminating the proceedings, the trial court had refused to allow the father to present evidence in support of his request for increased or unsupervised visitation. The court declined appellant's request because he had failed to show changed circumstances under section 388 and the proposed family court order was substantially similar to the existing juvenile court orders. On appeal, this court upheld the trial court's action saying "Where, as here, the noncustodial parent seeks modification of an existing order, he must comply with the specific requirements of section 388. These requirements may not be avoided by making the motion in a section 364 hearing. While we can envision consideration of a section 388 petition concurrent with a section 364 hearing, the moving party is still held to its burden of showing changed circumstances. The trial court here invited appellant to file a section 388 petition but he declined to do so. Without the requisite proof of changed circumstances the trial court properly rejected appellant's request to modify the existing visitation order." (Id. at p. 815.)