In In re Dolly D. (1995) 41 Cal.App.4th 440, the father failed to appear for a pretrial mediation conference prior to the jurisdictional hearing. The court deemed him in "default" and denied his counsel's request for a "default prove-up" hearing so that he could cross-examine the social worker regarding the allegations in the petition. Instead, the court determined the jurisdictional issue based on the social worker's reports and declared the child to be a dependent child within the meaning of section 300, subdivision (b). (Id. at p. 443.) The appellate court found that by denying counsel's request for a hearing, the court deprived the father of his right to confront and cross-examine the social worker who prepared the jurisdictional report, "a clear violation of his rights." (Id. at p. 445.) The case was set for a pretrial resolution conference prior to the jurisdictional hearing; the father failed to appear. The juvenile court found him in default. The matter was continued for mediation; the father appeared for the mediation, but it did not take place due to a scheduling conflict. The father failed to appear at the date set for the next continued mediation hearing; the father's counsel requested a "default prove-up" so that he would be able to cross-examine the social worker regarding the allegations in the petition. The juvenile court denied the father's request. The juvenile court proceeded by way of default on the basis of the report prepared by the department, sustained an allegation in the petition, and removed the minor from the father's custody. (Id. at pp. 442-443.) The appellate court held that the juvenile court erred in depriving the father of his right to confront and cross-examine the social worker who prepared the report. (Id. at pp. 444-445.)