In In re T.V. (2013) 217 Cal.App.4th 126, the father had successfully reunified with the child after an initial dependency proceeding brought due, in part, to his commission of domestic violence against the mother. However, his violence continued after reunification, and new dependency proceedings were instituted. (Id. at p. 130.) One incident occurred in the child's presence; another occurred when she was not present. (Ibid.) This evidence supported a finding that the domestic violence between the parents was "ongoing and likely to continue, thus placing the child at substantial risk of physical harm." (Id. at p. 134.)