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Ours is semi voluntary. CO has some pretty strict rules regarding relinquishment, including several counseling sessions. Our BM wanted to relinquish but couldn't meet the requirements for one reason or another (I haven't specifically asked her why she couldn't). So she has advised her lawyer not to fight TPR and not to appeal it. She is not showing up at any hearings at this point either.
In our case no one approached her. She approached the department about it.
I'm told doing it this way will take less time in the grand scheme...and I don't really care as long as we get to adopt in the end!