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it depends.....
In our case the 15/22 doesn't apply. The kids have been in care for just a little over 6 months and TPR trial starts in a week. This is the first time they have been in care and no previous TPRs on either parent. It just depends on the case, situation, and current issues that determine when CPS files TPR.
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Foster Care License approved! 12/19/08 
Emergency placements arrived 12/27/09
License extended 2/09 for "The Ring Leader"
"The Ring Leader moved in! 3/09"
License extended 5/09 for "Sissy"
"Sissy" stayed with her aunt.
Aunt changed her mind and "Sissy" moves in! 8/09
License extended 8/09 for "Gracie" (20 months).
Transition started 9/09. Move in 10/09
Placements:
Sibling Group
 2-"Little Man" Placed: 12/08@22 months
3- "M" Placed: 12/08@32 months
5- "The Ring Leader" Placed: 3/09@4 years
 9- "Sissy" Placed: 08/09@8 years
1- "Gracie" Placed: 10/09@21 months
Goal: TPR (contested) and adoption by us
  
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