13 47 Cal. Rptr. 2d 587 (Ct. App. 1995). 14 Id. at 588-89. 15 Id. at 589. 16 Id. at 593. 17 Id. at 594-95. 18 See In re J.S.C., 356 S.E.2d 754, 756 (Ga. Ct. App. 1987) (noting, in a termination case, that the appointment of a party interested in the litigation’s outcome as a guardian ad litem would defeat the purpose of the guardian ad litem statute — to provide the ward “with representation separate from any other interests in the litigation”); see generally Baker v. Baker, 59 Nev. 163, 172, 87 P.2d 800, 803 (noting that guardian statutes “are intended as a shield for the protection of [wards], and should not be used as a sword for their injury”), modified on rehearing in part on other grounds, 59 Nev. 177, 96 P.2d 200 (1939); In re Custody of Krause, 19 P.3d 811, 814 (Mont. 2001)
holding that the recommendations of the childrens caseworker and guardian ad litem coupled with evidence of the mothers extensive drug history her incompletion of courtordered services and testimony that the children were happy and doing well in their foster homes were sufficient for the trial court to determine that termination of parental rights was in the childrens best interest recognizing that upon request a district court may remove the guardian ad litem andor  appoint another guardian ad litem to protect the childrens interests holding that tolling statute applicable to incompetent plaintiffs continues in effect in spite of appointment of guardian ad litem recognizing that the person appointed as a guardian ad litem may not have interest adverse to those of the ward holding that the statute of limitations accrued when the minors father was appointed his guardian and not when the minor became comatose