In re C.H., L.H., and W.H., Minors 

During permanency review hearing as to mother's fitness to parent her three children, trial court asked that recordings of telephone conversations between parents be played. State alleged unfitness was evidenced by mother's use of abusive, vulgar language which was in presence of her child, as a child's voice could be heard in background. Court erred in admitting recordings, as they lacked proper foundation, as no testimony as to whose voices were on recordings, and whether they were unaltered and accurate recordings.