In In re Richard C. (1998) 68 Cal.App.4th 1191, the court upheld the denial of a bonding study requested before the 366.26 hearing was held. The court rejected the mother's claim that she had a due process right to a bonding study. The court opined that "at such a late stage in the proceedings mother's right to develop further evidence regarding her bond with the children was approaching the vanishing point." (Id. at p. 1195.) Although acknowledging that a bonding study may have enabled the mother to make a stronger case, the court observed that "under the dependency scheme described by the Supreme Court . . ., mother was required to muster her evidence before the termination of reunification services. The kind of parent-child bond the court may rely on to avoid termination of parental rights under the exception provided in section 366.26, subdivision (c)(1)(A) does not arise in the short period between the termination of services and the section 366.26 hearing." (Id. at p. 1196.) Moreover, "bonding studies after the termination of reunification services would frequently require delays in permanency planning. Similar requests to acquire additional evidence in support of a parent's claim under section 366.26, subdivision (c)(1)(A) could be asserted in nearly every dependency proceeding where the parent has maintained some contact with the child. The Legislature did not contemplate such last-minute efforts to put off permanent placement. " (Id. at p. 1197.)