Sounds like your example is not far from my situation other than a motion to reconsider was not part of it. Is there any down side to filing for a motion to dismiss and possibly having it rejected other than obviously the time and money involved to do so?
I don't think that you're thinking of things realistically.
1. It does not take 30 days for an order to become effective or permanent. It is effective the moment the judge issues it - even if it's a bench order and there's nothing in writing yet.
2. Mom CANNOT file an appeal for an order that ISN'T a final judgment. So if, as you believe, this is not yet a final judgment, and appeal is not the correct course of action.
3. Before an appeal can be filed, Mom MUST ask the court to reconsider the judgment, AND THEN let the court know that she intends to appeal if she loses that reconsideration.
4. It is far better to file a Motion for Dismissal, COMBINED WITH an answer.