Termination of parental rights; Whether the trial court violated MCL 712A.17b(5) by reading quotations from a child’s forensic interview to the jury & referencing the interview during adjudication; Pretrial discovery; MCR 3.922(A); Grubor Enters, Inc v Kortidis; Substantially justified delay; Harmless delay

Holding that the trial court did not violate MCL 712A.17b(5) or err by allowing a piece of delayed discovery to be used during adjudication, the court affirmed termination of respondent-father’s parental rights. His rights to the children were terminated on the basis of his sexual abuse of his daughter. On appeal, the court rejected his argument that the trial court violated MCL 712A.17b(5) because quotations from her forensic interview were read to the jury and the forensic interview was referenced during adjudication. “[N]o violation of MCL 712A.17b(5) occurred because a video recording of [the child’s] forensic interview was not admitted into evidence during adjudication. [She] provided live testimony, recounting her allegations against” her father. The court also rejected his claim that the trial court erred by allowing a police report to be used during adjudication, which he “received only 4 days prior to adjudication, i.e., less than 21 days before adjudication.” The delay “in discovery was substantially justified because DHHS made a continuous effort to obtain the report. DHHS did not receive the report until after the 21-day discovery deadline had passed. Further, the discovery delay was harmless.”