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No proffer, no review

Florida requires the substance of excluded evidence in the record. What a proffer must contain, when an oral one works, and why exhibits must be marked.

The rehearing trap in dependency appeals

A motion for rehearing does not toll the appeal clock in Florida dependency and termination cases. What that costs, and the one motion that does toll.

When appellate deference runs out

The Fifth DCA reverses a Florida termination of parental rights judgment, marking where appellate deference to a trial court's findings actually stops.

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