In In re Clifton V. (2001) 93 Cal.App.4th 1400, the reviewing court considered the applicability of rule 1432(f). In that case, the mother brought a section 388 petition seeking return of her son to her care after the juvenile court terminated reunification services. The mother alleged that she had completed all court-ordered programs and had maintained regular contact with her son. The Department of Children and Family Services filed opposition to the petition, which included a declaration from the child's paternal grandmother that the mother had not visited her son on a regular basis. The juvenile court refused the mother's request to permit live testimony and to cross-examine witnesses at the hearing on the petition for modification. The reviewing court held that where there is a contested hearing with an issue of credibility, a parent has a due process right to confront and cross-examine witnesses.