The minor mother of two-year-old N. H. appeals an order of the juvenile court in which the court after a review hearing continued custody of the child with the Fulton County Department of Family and Children Services “DFACS”. She contends that the juvenile court erred when it held the hearing without the mother being present, and in admitting into evidence documents that were not authenticated. Upon our review, we discern no error and affirm the juvenile court. The evidence shows that the 14-year-old mother was in DFACS care on June 20, 2008, when she gave birth to N. H. The newborn was subsequently placed in DFACS custody on July 10, 2008, and later found to be deprived. An order extending custody of N. H. with DFACS was entered on August 18, 2009. On June 11, 2010, DFACS filed another deprivation petition because the 2009 order was going to expire on July 6, 2010, and the “conditions of deprivation as found by the court had not been alleviated.” A hearing was held on June 28, 2010, at which the mother was present via telephone and represented in court by her attorney. N. H. was again determined to be deprived, and custody was continued with DFACS.
The review hearing at issue in this appeal was held on September 15, 2010, and the mother was not present for the hearing. The mother’s attorney requested that the hearing be continued until the mother was present. The trial court tendered as evidence a letter from Laurel Heights Hospital where the mother was a patient explaining that it was “clinically contraindicated for the mother to be transported to attend a hearing at this time.” The mother’s attorney objected to the admission of the letter on the basis that it could not be properly authenticated because the person who prepared it was not present at the hearing. The trial court noted that at an earlier hearing “we tried to involve the mother by telephone and mother had a hard time communicating,” and proceeded without the mother. The DFACS caseworker and the mother’s paternal grandmother, who N. H. was placed with, testified at the hearing.
