(denying due process); (3) the evidence did not establish proof evident, presumption great; and (4) the trial court refused to set bond based on facts not in the record. The State was ordered to respond, and Bleiweiss filed a reply. We grant the petition based on Blei-weiss’s argument (2) — that, after the evidence was presented, the court made its finding that the proof was evident and the presumption great and denied counsel’s request to make argument on the same. We believe that the failure to allow argument of counsel, in this case, amounted to a basic denial of petitioner’s right to be heard at an adversarial judicial proceeding that could deprive him of his liberty — the most fundamental of all due process rights. See Chalk v. State, 443 So.2d 421, 422-23 (Fla. 2d DCA 1984) (<HOLDING>); J.M.S. v. State, 921 So.2d 813, 815-16 (Fla.
holding a party failed to preserve error on its constitutional due process argument concerning notice when they did not cite any state or federal constitutional provision to the trial court or otherwise explain how lack of notice violated their constitutional rights holding that because defense counsel failed to alert the trial court that he was requesting relief based on a violation of defendants constitutional rights due process argument was not preserved for appellate review holding that patients constitutional due process rights were violated when his trial counsel was not allowed to present a closing argument prior to involuntary commitment holding statute permitting judge to deny counsel opportunity for closing argument violated criminal defendants constitutional rightto counsel holding that statute which permitted judge to deny defense closing in bench trial violated right to counsel and emphasizing the importance of argument by counsel in the factfinding process