(1) The Fourth DCA stands by its rule that sufficiency of the evidence arguments must be preserved at the trial level. E.G. v. DCF, — So.3d —-, 2012 WL 3965121 (Fla. 4th DCA 2012).
(2) The telephone appearance rule is as strong as ever. N.L. v. DCF, — So.3d —-, 2012 WL 3965124 (Fla. 4th DCA). The father in this case requested (presumably through his attorney) to appear by phone at his adjudicatory hearing when he didn’t appear in person. DCF objected. The result: Default. The court drops some breadcrumbs for the next parent in this situation, however: the father didn’t raise any constitutional arguments below, he didn’t appear at his best interests hearing either, and he never made any request to appear by phone as required under Florida Rule of Judicial Administration 2.530(d).