of parental rights must be afforded a procedure whereby he or she may challenge his or her appointed counsel’s adequacy. Because of the importance of expeditious resolution of termination cases, the cour in which petitioner is the party seeking relief. The Geist rationale is not controlling here merely because petitioner, like the parent in Geist, also has a statutory right to suitable counsel. Second, petitioner cites no authority, and we are aware of none, suggesting that due process requires a hearing, as opposed to consideration on the written record, when a post-conviction petitioner wants a new appointed attorney because of dissatisfaction with existing counsel. Such a requirement is not compelled by Geist, and we decline to so extend its rationale. See Geist, 310 Or at 190 (<HOLDING>); cf. Bartz v. State of Oregon, 314 Or 353,
holding that no single factor controls and that all factors must be weighed in light of fundamental fairness and the circumstances of the case holding that fundamental fairness demands at least an opportunity to present rebuttal to surprise evidence holding that an essential component of procedural fairness is an opportunity to be heard holding right to be fundamental holding that fundamental fairness is flexible and calls for such procedural protections as the particular situation demands