In Katheryn S. v. Superior Court (2000) 82 Cal.App.4th 958, the mother absconded with her six-year-old daughter shortly after the juvenile court had declared the child a dependent and released her to the mother under a conditional release to intensive supervision program (CRISP). The two remained in hiding for more than three years. During that time, the juvenile court relieved the mother's appointed counsel based on the mother's failure to participate in the proceedings, terminated reunification services, set a permanency hearing, and terminated parental rights. At that point, the mother appeared in custody (having been incarcerated in Washington state on child abduction charges for the previous six months), and counsel was reappointed for her. She immediately filed a notice of intent under rule 39.1B to attack the referral findings made 10 months before. (82 Cal.App.4th at pp. 961-963.) This court found the mother had been deprived of her right to counsel and construed the claims in the petition "as sounding in habeas corpus," thus avoiding the need to "determine whether good cause existed to excuse its tardiness . . . ." ( Katheryn S. v. Superior Court, supra, 82 Cal.App.4th at p. 969.) Finding the termination of reunification services while mother and daughter were "together, absent from the state" a mere "fiction used to move the case toward final resolution" (ibid.), the court stated: "We can discern neither benefit from nor authority for such a procedure. When the progress of ongoing dependency proceedings is thwarted because a parent absconds with his or her child and stays beyond the court's jurisdictional grasp, the court has no reason to do anything but issue warrants for their arrest and return and await their return. The statutory scheme has empowered the district attorney to take steps on behalf of the court to locate and obtain the return of the parent and child to the court. (See, e.g., Fam. Code, 3131 - 3135.) But the court is not empowered to order or terminate reunification services until the prosecutor has succeeded in locating them - or they have otherwise been returned to the court's jurisdiction." ( Id. at p. 969, fn. 11)