by counsel at all stages of the proceedings." CINA Rule 12(a). 24 . See 25 U.S.C. § 1912(2) (2012). 25 . See D.M. v. State, Div. of Family & Youth Servs., 995 P.2d 205, 212-14 (Alaska 2000) (noting that in many cases, late or inadequate notice may deny the parent due process, but concluding that there had been no showing that lack of proper notice risked erroneous termination of parental rights). 26 . Paula E. v. State, Dep't of Health & Soc. Servs., Office of Children's Servs., 276 P.3d 422, 433 (Alaska 2012). 27 . Id. (quoting D.M., 995 P.2d at 212) (citations omitted). 28 . Payton briefs this issue on appeal; Effie adopts Payton's argument by reference. 29 . See Alyssa B. v. State, Dep't of Health & Soc. Servs., Div. of Family & Youth Servs., 165 P.3d 605, 610 (Alaska 2007) (<HOLDING>). 30 . Paula E., 276 P.3d at 432-33 (quoting
holding that the standard of proof for dischargeability actions is the preponderance of the evidence standard holding that a defendant must prove an affirmative defense at sentencing stage by a preponderance of evidence holding that the proper standard of proof is preponderance of the evidence holding that the district court determines the amount of loss under the preponderance of the evidence standard holding that challenges to a trial courts finding of probable causeincluding an allegation that the father did not receive notice of the hearingwere mooted when the trial court later decided cina status at the adjudication stage by a preponderance of the evidence a higher standard