Legal Question in Family Law in California

You are not likely to succeed. Termination of parental rights is a drastic step and one that the courts are VERY reluctant to take. If she is in contempt of court orders, the remedy is a contempt citation and possibly modification of the orders, not termination of parental rights. The courts always favor keeping the door open to problem parents mending their ways and reunification with the child. Pretty much only cases of abuse, serious neglect and the like, along with multiple failed efforts at treatment and reunification result in actual permanent termination of parental rights. You should look into having her brought into court on a contempt charge rather than trying to terminate parental rights.