In In re Jeanette V. (1998) 68 Cal.App.4th 811, Division Four of this District considered whether a parent has a statutory or due process right at the section 366.26 hearing to cross-examine the authors of the social worker reports. The court stressed that a parent has a right to due process at the hearing, which may result in termination of parental rights, but noted that due process is a flexible concept which depends upon the circumstances and the balancing of various factors. (48 Cal.App.4th at pp. 817-818.) The court emphasized that the due process right to present evidence is limited to relevant evidence of significant probative value to the issues before the court. ( In re Jeanette V., supra, 68 Cal.App.4th at p. 817.) Noting that the issue before the trial court was whether "'the parents or guardians have maintained regular visitation and contact with the minor and the minor would benefit from continuing the relationship' ( 366.26, subd. (c)(1)(A))," and that appellant's trial counsel could not deny appellant's failure to satisfy the "maintain regular visitation and contact" element and could only suggest that cross-examination might reveal something about appellant's visitation during an unspecified earlier period, the court concluded that the trial court did not err in failing to permit the parent to cross-examine the authors of the various social study reports.