Laying down. I had ear infections until the 4th grade and lying down creates a lot of pressure and the fluid doesn't drain down the throat naturally-mine actually drained out my ears in my sleep-well, in my attempts to sleep.
Because I was about 9 when they stopped, I always have those memories of lying in bed, writhing and crying; my ear drums are permanently scarred.
You could try this: under her crib mattress, use something to prop up one end so she sleeps with her head slightly elevated. My daughter didn't get ear infections, but she did get colds and such and propping the mattress allowed for better 'drainage'-I have even had her in her crib in her carryseat so she'd sleep more or less in a sitting position-just be sure she's strapped in properly.
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