OPINION
MILLER, J.
FACTUAL AND PROCEDURAL HISTORY
D.A. (father) and B.M. (mother) had a relationship and mother became pregnant in 2007. In August 2007, father severely beat mother with a two-by-four. The next month, father pled guilty to kidnapping mother, inflicting corporal injury on a cohabitant, and other charges. He was sentenced to three years in state prison, and has remained incarcerated throughout these proceedings.
Mother is not a party to this appeal.
Mother also had a relationship with another man, P.S., who could have been the biological father of the child. P.S. was also incarcerated. In October 2007, mother began living in the home of P.S.’s mother. The child was born in early 2008. Neither father nor P.S. was present at the birth, and neither was listed on the child’s birth certificate as the father.
The San Bernardino County Department of Children’s Services (DCS) became involved in July 2008 when mother, who suffered from unmedicated bipolar disease, tried to sell the baby at the local courthouse.
The child was taken into protective custody. DCS filed a dependency petition alleging that the child came within Welfare and Institutions Code section 300, subdivisions (b) (failure to protect) and (g) (no provision for support). The petition alleged that mother suffered from a mental disease that interfered with her ability to parent. It further alleged that father had been imprisoned for inflicting great bodily harm on mother while she was pregnant with the child, thus placing the child at risk of injury or death, and that because of his incarceration, father provided no care or emotional support for the child.
At a detention hearing on July 28 and 29, 2008, the juvenile court appointed counsel for father.
The court scheduled a jurisdictional and dispositional hearing and, in August 2008, ordered the prison authorities to transport father to the hearing. Father was served personal notice of the hearing. Father personally declined to attend the hearing and authorized his attorney to represent him.
At the jurisdictional and dispositional hearing, the social worker’s report proposed that the court order and offer reunification services to mother, but that both alleged fathers were incarcerated and clear and convincing evidence showed that contact from either of them would be detrimental to the child.
The court initiated the jurisdictional and dispositional hearing on August 19, 2008. At that time, father did not appear but his counsel was present. DCS proposed that no services be offered to either father or P.S., as they were only alleged fathers. In addition, father would not be entitled to services under Welfare and Institutions Code section 361.5, subdivision (b)(12), because of his conviction for a violent felony, kidnapping. The court continued the matter for a contested hearing.
At the continued contested hearing, father’s counsel stated that he had no affirmative evidence to offer, but objected to denying him services: “As far as I have had communication with my client—and he is requesting to be paternity tested—he would like to have services. He is willing to do anything, he says, to have service[s] and be reunified with his child, but he is requesting paternity testing.” Father wanted testing to establish biological paternity and change his status from being merely an alleged father. At the same time, counsel “request[ed] to be able to reserve the right at a future hearing to be declared a nonparty and have the allegations vacated against him if in fact he is not the biological father....”
DCS argued that the oral request for paternity testing was untimely. Father had been represented by counsel since the detention hearing, and at the earlier jurisdictional hearing he had made no such request. In addition, neither father met the conditions to be declared a presumed father: they had not been married to mother, they had not been present at the birth, they had not been listed on the birth certificate, they had not lived in the child’s home, and they had provided no care or support for the child. They were each incarcerated, and father in particular was incarcerated for a serious offense against mother (and the unborn child).
The court found that father and P.S. were each alleged fathers, not entitled to reunification services. The court also denied father’s request for paternity testing. The court further found by clear and convincing evidence that father had been convicted of a violent felony and that he was incarcerated, and that it would be detrimental to the child to provide reunification services to him.
Twenty-nine days later, on October 23, 2008, father filed a notice of appeal, specifying that he appealed from, “In particular, [d]enial of father’s request for paternity testing. (9-24-08)”
DISCUSSION
A. Issues on Appeal
Father complains of two issues on appeal.
First, he complains that no one sent him a Judicial Council form JV-505 (form JV-505), as required under Welfare and Institutions Code section 316.2, and California Rules of Court, rule 5.635. He argues that the failure to ensure that he received this notice rendered the court’s ruling, denying his counsel’s oral request for paternity testing, erroneous and violative of his rights.
All further rule references are to the California Rules of Court unless otherwise indicated.
Second, father contends that the trial court failed to ensure that he was properly asked about possible Indian heritage, pursuant to the Indian Child Welfare Act (ICWA). (25 U.S.C. § 1901 et seq.)
We discern no basis for reversal, as to the first issue, even if protocol was not followed and the form JV-505 was not given to father in the prescribed manner. As to the second issue, DCS argues that it is not encompassed within the scope of father’s notice of appeal. We decline to decide the issue on this narrow basis, but we conclude that, in any event, father’s contention is not meritorious.
Counsel for minor filed a brief on January 16, 2009, joining the position of DCS and requesting that the juvenile court’s orders be affirmed.
B. The Failure to Provide the Paternity Notice and Waiver Form Was Harmless, and the Court Did Not Abuse Its Discretion in Denying the Oral Request for Paternity Testing
Father recognizes that case law establishes that the standard of review on a trial court’s denial of a request for paternity testing is abuse of discretion. (County of Orange v. Superior Court (2007) 155 Cal.App.4th 1253, 1257.) He argues, nonetheless, that he has been deprived of a fundamental right to parent a child, and thus, that an error must be shown to be harmless beyond a reasonable doubt. (See In re Angelia P. (1981) 28 Cal.3d 908, 915; In re Justice P. (2004) 123 Cal.App.4th 181, 193.)
The failure to provide notice to father in this instance was harmless under any standard of review.
Welfare and Institutions Code section 316.2 requires that when any man has been identified as an alleged father, “each alleged father shall be provided notice at his last and usual place of abode by certified mail return receipt requested alleging that he is or could be the father of the child. The notice shall state that the child is the subject of proceedings under Section 300 and that the proceedings could result in the termination of parental rights and adoption of the child. Judicial Council form Paternity—Waiver of Rights (JV-505) shall be included with the notice.” The notice sent to father apparently failed to include the form JV-505.
The form JV-505 provides an alleged father the opportunity to deny parentage of the child, to request an attorney, to request or consent to a paternity test, to consent to a judgment of paternity, to provide evidence of a declaration of paternity, to provide proof of marriage to the mother, to show indicia of presumed paternity (lived with child and held out as his own), and other similar matters.
Father complains that the failure to mail this form to him deprived him of the right to require the court to order a paternity test or to make a voluntary declaration of paternity.
Even though the failure to mail father the form was error, reversal is not required. We are mindful of the constitutional standard that judgments and orders are not to be reversed absent a miscarriage of justice. (Cal. Const., art. VI, § 13.) Father has not shown, and cannot show, any miscarriage of justice here.
Although the notice to father apparently did not include a form JV-505, father was represented by counsel at the outset of the proceedings. Father’s attorney appeared at the initial jurisdictional hearing in August 2008 and said nothing about paternity. Father himself was provided with a court order for transportation to the jurisdictional and dispositional hearing, but he personally declined to come to court. If father had come to court, a form JV-505 would have been available to him in the courtroom; pursuant to rule 5.635(e)(1), such forms must be made available in the courtroom.
Father’s reliance on In re Paul H. (2003) 111 Cal.App.4th 753 is misplaced. There the alleged father did appear in court and the court abused its discretion in refusing to give him a form JV-505. (Id. at p. 761-762.) Here, of course, father voluntarily did not appear in court. Similarly, the father in In re Baby Boy V. (2006) 140 Cal.App.4th 1108 (Baby Boy V.) also came to court. That father was undisputedly “a nonoffending, stable, employed, and financially responsible adult [who] came forward at the earliest possible moment.” (Id. at p. 1117.) In Baby Boy V. there was nothing there to suggest that the alleged father was unfit as a parent. (Id. at p. 1118.) By contrast, not only did father here fail to come to court, there also existed many factors which militated against father’s fitness.
Even if father had received and filled out a form JV-505, and even if he was able to establish biological paternity, that test or determination would not have materially altered the case. The request for a paternity test is not an end in itself: the purpose for which father requested the test ultimately would be to receive reunification services as a presumed father. The order here denying reunification services would not have been changed, even if paternity testing had been ordered.
Father had no affirmative evidence to offer on the issues of the petition. The evidence indicated that, even if he was a biological father, he had not been present at the child’s birth, was not listed on the child’s birth certificate, had never married mother, had never lived in the home with the child, had provided no care or support for the child, and, in short, had nothing to do with the child. Indeed, he was unavailable to care for the child precisely because he had committed violent crimes against mother, who was pregnant at the time, and thus he had endangered the child’s life as well. He was incarcerated for his crimes and had no prospect of release in time to establish any relationship with the child.
Even if father had been sent the form JV-505, even if he had declared paternity, even if he had requested and received paternity testing that showed him to be the biological father, there would have been no change in the ultimate result: by clear and convincing evidence it would be detrimental to the child to provide reunification services to father. Because father has failed to show that the error, in failing to mail him a form JV-505, resulted in a miscarriage of justice, reversal is not required.
C. ICWA Issues Do Not Require Reversal
Father complains that, although the trial court inquired of mother as to her Indian ancestry (mother stated that she had Crow and Blackfoot affiliations—notices to tribes were sent and letters were returned stating that the child was not an Indian child), it failed to ensure that he was asked about his Indian heritage.
DCS argues that the issue is not properly before us on appeal, as father’s notice of appeal was specifically directed solely to the court’s denial of his attorney’s oral request for paternity testing. A notice of appeal is sufficient if it identifies the particular judgment or order being appealed (rule 8.100(a)(2)), but here father specified only the order denying his attorney’s request for paternity testing.
Nonetheless, public policy and the court rules require that notices of appeal be liberally construed. (Rule 8.100(a)(2) [the notice of appeal must be liberally construed].) In dependency cases, the dispositional order is the appealable judgment. Although, for example, father’s notice of appeal specified that he appealed from the court’s ruling denying him a paternity test, that order was a preliminary matter to the dispositional order. It was by virtue of the dispositional order that father was denied reunification services. As we noted above, father’s claim that the court erred in denying him a paternity test was not made in a vacuum; what father really sought was reunification services and a chance to establish that the court erred in denying him those services. If DCS’s position were taken to its logical conclusion, then the notice of appeal, specifying an appeal from the trial court’s order denying a request for paternity testing, was from a non appealable order, and no appeal would lie on either of father’s claimed issues.
Given the directive to construe notices of appeal liberally, we decline to place such strict limits on the issues encompassed in the notice of appeal here. Thus, we turn to a consideration of father’s ICWA claim, but we find his argument to be without merit.
As with the paternity testing issue, father has made no showing of any miscarriage of justice so as to justify reversal. (Cal. Const., art. VI, § 13.) Father made no representation below whether he actually has any Indian ancestry, and both his opening brief and his reply brief on appeal are equally silent on the matter. We meant what we said in In re Rebecca R. (2006) 143 Cal.App.4th 1426: “Father complains that he was not asked below whether the child had any Indian heritage. Fair enough. But, there can be no prejudice unless, if he had been asked, father would have indicated that the child did (or may) have such ancestry.
“Father is here, now, before this court. There is nothing whatever which prevented him, in his briefing or otherwise, from removing any doubt or speculation. He should have made an offer of proof or other affirmative representation that, had he been asked, he would have been able to proffer some Indian connection sufficient to invoke the ICWA. He did not.
“In the absence of such a representation, the matter amounts to nothing more than trifling with the courts. [Citation.] The knowledge of any Indian connection is a matter wholly within the appealing parent’s knowledge and disclosure is a matter entirely within the parent’s present control.... [¶]
“The burden on an appealing parent to make an affirmative representation of Indian heritage is de minimis. In the absence of such a representation, there can be no prejudice and no miscarriage of justice requiring reversal.” (In re Rebecca R., supra, 143 Cal.App.4th at p, 1431.)
DISPOSITION
For the reasons stated, the judgment is affirmed.
We concur: HOLLENHORST Acting P. J., KING, J.