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Posted By John D. Hodson,
Thursday, April 04, 2013
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Looking for a CFLS who is also licensed in Arizona, to consult on a project. Any takers?
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Posted By Dawn Gray,
Tuesday, August 07, 2012
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L.M.
v. M.G. (2012) 2012 WL 3125123, published by the Fourth District on August
2, 2012
Holding: The trial court properly held that a
single-parent adoption by one former same-sex partner did not, as a matter of
law, either preclude the trial court from adjudging the other partner to be the
child's second parent or automatically rebut the maternity presumption arising
under Family Code section 7611(a).
Summary
of the facts: M.G. and L.M. lived together as same-sex partners from
1998 through 2003. Each had a child that lived with them. M.G. wanted another
child; after failing to conceive using the same sperm donor that had fathered
her son, she and L.M. discussed adoption. M.G. learned about an opportunity to
adopt a child in Mexico; with L.M.’s agreement and participation, she met with
the birth mother, moved her to the United States and paid her living and birth
expenses. C was born in November of 2000, and came to live with L.M. and M.G.
Both parties took maternity leave to care for him.
M.G. formally adopted C in October
of 2001 by a single-parent adoption decree. L.M. testified that the plan was
for her to adopt C as well and for the parties to register as domestic
partners. At the time, second-parent adoptions were not available for lesbian
couples, but "(t)he parties did not develop the record on the issue of whether
it would have been possible for [them], as a same-sex couple, to jointly and simultaneously adopt the Child in October 2001 had they desired to
do so rather than planning on a subsequent stepparent adoption after becoming
registered domestic partners.”
The parties’ relationship ended when
C was three years old. L.M. testified that part of the reason was that M.G.
would not enter into a domestic partnership so that L.M. could adopt C; she
said that she consistently asked M.G. to cooperate in her obtaining legal
parentage of C, but M.G. refused. After the parties separated, C spent time
with both of them and L.M. regularly cared for him when M.G. was out of town.
L.M. testified that she did not file a parentage petition in 2003 because she
was advised that there was no precedent for her doing so, and M.G. was allowing
contact and she did not want to risk this being cut off if she angered her.
However, in 2010, when M.G. decided to relocate to Europe, L.M. filed a
petition to establish a parental relationship under the UPA. She sought custody
and visitation orders and a decision as to whether to allow the move, which she
believed was not in C’s best interest.
M.G. filed a motion to quash and to
dismiss the proceedings, or to lift the restraining orders and allow her to
move. The trial court denied the motion. After several hearings, the court
adjudged L.M. to be C’s second parent, finding that she had satisfied the
requirements of Family Code §7611(d) "because she received the Child into her
home and held him out to the world as her natural child.” It cited authority
holding that a child can have two mothers and rejected M.G.’s argument that the
trial court was required to weigh the parties’ "competing” parentage claims and
choose only one. It held that the
case was not a proper one in which
to rebut the maternity presumption, granted joint legal custody, "designated
M.G.’s residence as the Child’s primary residence,” permitted M.G. to travel to
Europe with C for one school year with visitation to L.M., and set follow-up
hearings to monitor the situation and determine whether a longer stay was
appropriate. It entered judgment on its order.
Result
on Appeal:
M.G. appealed, but a Fourth District majority affirmed with the third justice
concurring in the result. M.G. did not challenge the trial court’s
determination that a presumption of maternity arose based on its finding that
L.M. had received C into her home and openly held him out as her natural child.
Rather, she contended that the presumption in favor of a second parent is
rebutted as a matter of law "whenever the child who is the subject of the
parentage petition was adopted by his legal parent through a single parent
adoption decree.” The justices disagreed.
Citing Elisa B. v. Superior Court (2005) 37 Cal.4th 108, 33 Cal.Rptr.3d
46, they held that when a woman fulfills the requirements of section 7611(b), a
presumption of maternity arises. Noting that "(b)uilding on the decision in Elisa B., other cases have addressed
parentage determinations with respect to children raised by lesbian couples,”
the majority disagreed with M.G.’s argument that as a matter of law, her
single-parent adoption decree rebutted the presumption that arose in favor of
L.M.’s maternity, an issue not reached in Elisa
B.
The justices said that M.G.’s first
argument, that "a single parent adoption decree is a judgment establishing
paternity by another man” under Family Code §7612(c), was a question of law and
statutory interpretation, and thus reviewed de
novo. The majority held that the adoption decree did not, as M.G. argued,
"constitute[] a judicial determination that ‘this is not a two slot parent
family. It is a one slot parent family. There is no extra (or second) parent
slot for L.M. to occupy.’” Rather, it said, the decree operated to extinguish
C’s natural parent’s parental rights and determined that C’s interests would be
promoted by the adoption. However, it said that "(t)he record contains no
evidence that the issue of whether the Child could have only one parent was
raised or decided in the adoption proceedings,” and thus did not adjudicate
whether C’s interests might be served in the future by having more than one
parent.
Next, M.G. argued that L.M.’s
petition raised a parentage claim under section 7612(b) required a weighing of
the competing claims and necessarily a determination that her claim prevailed.
However, the panel agreed with the trial court that there was no "conflict” to
resolve, because under Elisa B., "a
child raised in a same-sex relationship may have two mothers.” It said that
"L.M. seeks recognition as the Child’s second mother,” not to take away M.G.’s
status as C’s adoptive parent. Thus, there was no conflict between their
claims.
M.G. also argued that the trial
court should have determined that this was an appropriate case in which to
allow her to rebut the presumption of maternity that arose under section
7612(a). The panel, however, was not convinced. After summarizing recent cases
on the subject, it said that under those cases,
"(t)he
stated policy in favor of providing a child with two parents has led courts to
conclude that it would not be an ‘appropriate action’ to rebut a parentage
presumption when that presumption arises in favor of a second parent of a child
raised by a same-sex couple and there is no other person competing for the
second parent position. The situation presented in this case fits squarely into
that fact pattern, because L.M. and M.G. were a same-sex couple who decided together
to bring the Child into their family to jointly raise him, and no other person
is competing for the position of the child's second parent. Based on Elisa B. and subsequent cases applying
its holding, the trial court correctly determined that this case is not an
appropriate action in which to rebut the presumption.”
M.G. argued that the court should
have allowed her to rebut the maternity presumption because a parentage
determination in L.M.’s favor would have constituted a collateral attack on the
single-parent adoption decree, which "vested single parenthood status from time
of rendition.” However, the justices said that
"there is
no basis to treat the adoption decree as comprising the issue of whether,
regardless of future developments, the Child should be precluded from having a
second mother. The adoption decree served only to vest parent status in M.G.
and cut off the legal rights of the Child's birth parents. As the adoption
decree did not adjudicate the issue of whether the Child may only have one
parent, L.M.'s parentage petition does not constitute an impermissible
collateral attack on the adoption decree.”
M.G. then argued that she should
have been allowed to rebut the maternity presumption because "L.M. should be
estopped from challenging M.G.’s adoption decree after the limitations period”
in section 9102(a), which provides that with certain exceptions, "an action or
proceeding of any kind to vacate, set aside, or otherwise nullify an order of
adoption on any ground, except fraud, shall be commenced within one year after
entry of the order.” The majority explained that this limitations period did
not apply because "the adoption decree is not properly characterized as a
judgment that the Child may have only one parent.”
Finally, M.G. argued that she should
have been permitted to rebut the maternity presumption because "through this
action, L.M. seeks the equivalent of a stepparent adoption ‘without any of the
required processes and without M.G.'s consent.’” Unconvinced, the justices said
that
"(a)doption
and an order determining parentage under the UPA are alternative methods for someone to establish parental status. Case
law recognizes parental status under the UPA even when a stepparent adoption
procedure was not followed during the time that the parents were together and
cannot now be followed because the parents' relationship has ended. Therefore,
the fact that L.M. did not obtain a stepparent adoption, and instead seeks to
establish parental rights through the UPA, does not necessarily make this an
appropriate action in which to rebut the parentage presumption in favor of L.M.”
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Posted By Dawn Gray,
Friday, July 06, 2012
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2012 WL 2582353,
published by the Fourth District on July 5, 2012 Holding: Upon the parent’s marriage, an existing child custody and future
support provisions of a paternity judgment regarding their child are nullified
and replaced by the law governing the rights and obligations of married parents
to their children. If those parents subsequently seek a divorce, the
divorce laws are then applicable to the determination of child custody and
support.
Summary
of the facts: Husband and Wife were unmarried when their son, J.W.,
was born in 2001. In 2002, Wife filed a paternity action based on a voluntarily
declaration of paternity "The court construed the declaration of paternity as a
judgment of paternity and recognized it as the basis for making child custody,
visitation, and support orders. The court awarded Mother sole legal and physical
custody of J.W. and granted Father reasonable visitation. Father was ordered to
pay $1,600 monthly child support.”
The parties had a daughter in June
of 2003, and married on December 31, 2005. The marriage lasted only two years;
they separated on January 30, 2008, Wife filed a dissolution on
March 17, 2008, and Father filed a response in April 2008. On June 17, 2010, Husband
filed an ex parte OSC in the paternity case seeking to modify the child support
order and determine arrears. In his declaration, he stated DCSS had told him that
he owed over $150,000 in arrears, which included the time he was living with
and married to Wife. He stated that they had equal timeshare with both children
and he asked the court to determine child support based on the current custody
arrangement.
In Wife’s response, she stated that
Husband owed between $85,000 and $90,000 in child support arrears for the
period of March 1, 2002, through July 23, 2010. She stated that Husband did not
pay the full amount of the child support order in 2002 or 2003 when they lived
apart and that she had credited him with having paid support while they lived
together and then subsequently married from October 2005 to January 2008. At
the hearing, the court found that Husband owed $1,600 per month for the period from
March 1, 2002, to June 30, 2003, when their daughter was born. It reserved for
later hearing the issue of arrearages from the parties’ date of separation to
the date of the hearing.
Meanwhile, in the divorce case, the
parties stipulated to joint legal and physical custody of the two children and
equal timeshare, and the court entered a partial final judgment resolving the
issues of custody, visitation, and property division based on the parties’
stipulation. It reserved a decision on the child support issue, and at the October
28, 2010, hearing in the paternity case, the court noted that the paternity
case and the divorce case were being "related for hearing purposes.”
At the hearing, the Wife’s counsel "acknowledged
the support order was ‘abated’ from July 2003 to January 2008 because the
parties were living together and Father was providing support by having
thechild in his home. Mother clarified the issue was whether support was owed
after the date of
separation in February 2008 to the
present. She also requested the court determine support arrears for the period
of July 2002 (when she obtained the support order) to September 2003 (the month
before they moved in together).” For his part, Husband argued that the 2002
child support order was extinguished by the marriage.
Both parties cited and discussed Davis v. Davis (1968) 68 Cal.2d 290, in
which the Supreme Court held that parties’ remarriage extinguished the child
support order entered in their first divorce action. Husband held that this
case was on point but Wife argued that it was distinguishable because "paternity
orders should be treated differently than divorce decrees.” Ultimately, the
trial court entered a temporary child support order that Father pay Mother $42
per month, ordered Husband to pay $250 per month toward arrears accrued in the
paternity case. At the next hearing, it determined that Davis was not controlling. It found that "the child support order
made as a result of the paternity action remains even after the marriage,” held
that it retained jurisdiction over the paternity child support order and ruled that
Wife could seek arrears from the date of separation until June 2010, when Husband
filed the OSC seeking modification of the 2002 support order.
In its statement of decision, the
court explained that Davis was
inapplicable because it involved a married couple and that "this case was
different because it involved ‘unmarried parents who lived together on and off,
then married and separated thereafter.’” It held that "(a) valid order was made
in 2002 and the duty to comply with that order was not extinguished by the 2005
marriage.” The appellate court "found nothing in the record, and Father fails
to cite to any document, showing the court ruled the total amount of arrears
owed from (1) July 2002 to September 2003 (before the couple’s marriage) or (2)
from January 2008 to July 2010 (after the marriage)."
Result
on Appeal:
Husband appealed, challenging the arrears relating to period after he and Wife
separated. Wife did not appear in the appeal. The Fourth District panel said
that "(t)he sole issue presented in this appeal is what effect, if any, does
the act of marriage have on a prior child custody support order entered in a paternity
action when the child’s parents were unmarried.” It reversed the trial court’s order
that Husband owed arrearages for the period from January 2008 to July 2010
based on the prior paternity order. It essentially held that this was an issue
of first impression in California and followed the "well reasoned decision by
the Supreme Court of North Dakota” in Schaff
v. Schaff (N.D. 1989) 446 N.W.2d 28.
In Schaff, the North Dakota court analogized to cases of remarriage
between parents and held that
"there is
a reasonable distinction to be drawn between the effect on a paternity judgment
of the child’s parents’ subsequent marriage to each other and the effect on a
divorce decree of the divorced parents’ subsequent remarriage to each other.
The paternity action, as well as the divorce action, each involves a
determination of the separate rights and liabilities of parents for their
children. While a paternity action and a divorce action establish the separate
rights and liabilities of parents, those parents’ subsequent marriage or
remarriage establishes anew the parents’ joint rights and liabilities for
custody and support of their children replacing their former separate rights
and liabilities. We believe that the rationale of the divorce cases regarding
the resumption of joint rights to custody and joint obligations for future
support upon remarriage should govern this case. Accordingly, we hold that when parents of a child born out-of-wedlock
marry each other, the child custody and future support provisions of the
paternity judgment are nullified and replaced by the law governing the rights
and obligations of married parents to their children. If those parents
subsequently seek a divorce, the divorce laws are then applicable to the
determination of child custody and support.’ (Schaff, supra, 446 N.W.2d at p. 32, italics added.)”
The Fourth District followed this
reasoning and concluded that
"(a)s in
North Dakota, the Act (§7600 et seq.) provides the statutory framework by which
California courts make paternity determinations. (§7570 et seq.) In California,
paternity actions, like divorce actions, involve a determination of the
separate rights and liabilities of parents for their children. The marriage or
remarriage by those parents automatically creates joint rights and liabilities
for custody and support of the child and extinguishes any preexisting order of
child support entered for the child’s benefit. Upon the termination of the
marriage or a second marriage between parents, custody and support issues will
be visited anew. (§§ 3600, 4001; In re Marriage
of Wittgrove (2004) 120 Cal.App.4th 1317, 1326 (Wittgrove) [‘Pending a marriage dissolution or legal separation
action where there is an issue of support of a minor child, the court may order
either or both parents to pay ‘any amount necessary for the support of the
child”’].) The dissolution legal proceedings have built-in protections for the
best interest of the child. (Wittgrove,
supra, 120 Cal.App.4th at p. 1326 [in implementing statewide uniform
guidelines for child support under section 4053, the court’s ‘main concern is
the child’s best interests’].) Thus, the child will not be harmed by the fact
that an earlier child support order was terminated upon the marriage or
remarriage of the parents.”
The panel reversed the order that Husband pay arrearages
for the period from January 2008 to July 2010 based on the prior paternity
order but held that he "still had an obligation to support his children during
this time period.” It directed the trial court on remand to determine whether
or not he had "satisfied his parental obligation” during that period.
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Posted By Frieda Gordon,
Friday, June 22, 2012
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I thought this was a really good summary of the law re spousal support modification and an interesting comparison between the Wife's position and the important cases in this area of law. To me, the Wife got what she deserved.
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Posted By Dawn Gray,
Thursday, June 21, 2012
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In re the Marriage of
Sameer Khera and Madhu Sameer (2012) 2012
WL 2308121, published by the Sixth District on June 19, 2012
Holding: The trial court did not abuse its
discretion in denying Wife’s post-judgment motion to modify spousal support for
lack of a showing of changed circumstances. Wife failed to demonstrate that her
failure to become self-supporting by the date set in the parties’ Judgment on
Reserved Issues constituted an "unrealized expectation” sufficient to
constitute changed circumstances. Wife’s voluntary decision to pursue a
doctorate instead of finding employment after completion of her MSW as
contemplated by the judgment did not justify extending spousal support.
Summary of the facts: Husband filed a petition for
dissolution on October 10, 2003. In May of 2007, the parties reached a
settlement and placed it orally on the record before the court. Judgment was
entered in February of 2008 incorporating their settlement. It provided for
spousal support commencing on June 1, 2007, which was annually stepped down
through June 1, 2010. It provided that "[o]n June 1, 2010, spousal support will
be reduced to zero, unless, before that date, [appellant Madhu] files a motion
to have spousal support continued and shows good cause as to why the Court
should order spousal support to be continued.”
In
February of 2009, Wife moved to set aside the judgment. In March of 2010, she
brought another motion to modify the judgment’s spousal support provisions,
including a request that the court order Husband to "continue paying support
beyond June 1, 2010 until that time that Wife can become self-supporting.” In
her pleadings,
"counsel for Madhu argued that ‘no
showing of changed circumstances is required due to the fact that the language
contained in the Judgment specifically allows for Wife to seek modification of
the stated order on or before June 1, 2010.’ Counsel alternatively contended
that, even if a change of circumstances is required, "’odification may be
grounded on a showing of "unrealized expectations."’ Citing In re Marriage
of Beust (1994) 23 Cal.App.4th 29, counsel asserted that ‘[s]o long as the
supported spouse has made reasonable efforts to become self-supporting, a change
of circumstances may be in the form of "unrealized expectations” in the ability
of the supported spouse to become self-supporting within a certain period of
time.’ Counsel contended that despite Madhu's fulltime enrollment in the doctoral
program in clinical psychology, ‘she has not yet met all of the necessary
requirements in order to graduate and has, therefore, not yet been able to
support herself and the children’ and ‘she is currently only able to earn $9.00
per hour.’ On behalf of Madhu, counsel requested the court to determine the
marital standard of living, set the appropriate level of support, order an
upward modification of spousal support that included an Ostler & Smith
provision, and modify the existing order to require Sameer to ontinue paying spousal support
beyond June 1, 2010 until Madhu "can become self-supporting.”
In
response, Husband stated that Wife had
"undergone a vocational assessment
before their May 2007 agreement. The vocational assessment examination report,
dated April 4, 2007, indicated that, at that time, Madhu was attending a
Master's program in social work at California State University, Fresno. She had
completed the required practicum hours and would complete her coursework at the
end of May 2007. Madhu indicated that she still needed to complete her Master
thesis and have it signed by her advisor. At one point she indicated that she
would be able to earn her MSW degree by August 1, 2007 but then indicated that
her Master's thesis might not be done until as late as November 2007. The
report indicated that Madhu would be employable as soon as she completed her
thesis at a salary of between $38,000 and $42,000 per year. Her earning
capacity would increase significantly after she had completed the requisite
supervised work experience and obtained licensure as a licensed clinical social
worker (‘LCSW’). As a LCSW, she could earn from $72,000 to $93,000 per year.”
The
trial court denied Wife’s modification motion. It noted that the set-aside
motion was still pending, but held that Wife did not present sufficient facts
demonstrating a change of circumstances.
Result on appeal: Wife appealed, but the Sixth
District affirmed on substantial evidence. Citing Marriage of Lautsbaugh (1999) 72 Cal.App.4th 1131, 85 Cal.Rptr.2d
688, it said that although Beust does
hold that unrealized expectations can constitute a change in circumstances,
reconsideration of circumstances that have not changed since entry of the
existing order cannot constitute a "change.” It held that "(t)he clear
implication of the judgment was that, absent unforeseen circumstances, Madhu
was expected to complete her MSW degree and be able to be fully self-supporting
by June 1, 2010.”
Wife
argued that her failure to become self-supporting constituted an "unrealized
expectation” and thus a change in circumstances. She argued "that the record
shows that the parties' expectation that she would be employed as a social
worker at a salary of at least $42,000 was not realized and, when she filed her
modification motion, her monthly income was only approximately $700.” However,
said the court, "her supporting declaration did not show that she diligently
acted to achieve financial self-sufficiency and, despite her reasonable
efforts, she had been unable to complete her MSW degree, she had been unable to
obtain fulltime work as a social worker, or she had been unable to find
fulltime employment at a salary that made her self-supporting. An unrealized
expectation of self- support requires ‘a showing that despite [the supported
spouse's] reasonable efforts she was unable to support herself.’ (In re Marriage of Aninger (1990) 220
Cal.App.3d 230, 241.)”
Wife
then argued that "the record contains ‘no evidence of available jobs because
[respondent Sameer] failed to submit any evidence that gainful employment
exists.’ She states that ‘[t]he record contains no current or relevant evidence
that any job exists that suits [her] qualifications.’” However, said the panel,
she "did not make any showing that the state's general economic situation
impeded her ability to obtain fulltime employment in her chosen field at a
salary sufficient to be self-supporting.
The burden was on Madhu to show reasonable efforts to achieve this objective.
(See Evid.Code, §§ 500, 550.)”
The
court also held that in the trial court, she failed to raise other facts that
might have constituted a change in circumstances, such as the fact that she had
suffered a stroke since entry of judgment. It held that her failure to raise
these facts below precluded relief for them on appeal. It said that she had
"presented no evidence that any change in her health had affected her ability
to complete her MSW degree or obtain or maintain fulltime employment.” Rather,
said the panel, she "stated in the supporting memorandum that Madhu had
enrolled herself in a doctoral program in clinical psychology and she had
‘decided on this course of action’ ‘so that she may one day support herself and
the parties' children as near to the ‘Marital Standard of Living’ as possible.’”
It concluded that "(i)n our view, a voluntary decision to pursue a doctoral
degree rather than entering the working world fulltime does not constitute a
material change of circumstances in the context of this case.” It said that
"(n)othing in the parties'
stipulation, or the judgment entered pursuant to the stipulation, suggested
that the parties expected spousal support to facilitate a voluntary decision by
Madhu to pursue higher education beyond a MSW degree, if she was able to be
self-supporting based on her education and skills in the existing job market.
Madhu did not show that despite her reasonable efforts she was unable to
support herself. It was not an abuse of discretion to conclude that the
evidence was insufficient to show a material change of circumstances.”
Wife
also argued that under the judgment, no change of circumstances was required to
justify a modification of the step-down provision, but the panel found no such
provision. She argued that under Richmond, the effect of the judgment was to
"merely postpone[] the analysis under section 4320 until she brought a motion
to modify.” The panel disagreed with her on this point too, holding that "the Richmond
court did not say that the lower court, in making its spousal support order in
the first place, had put off proper consideration of the relevant statutory
criteria. … The Richmond court recognized that the lower court had
properly exercised its discretion and squarely placed the procedural and
evidentiary burden on the supported spouse to avoid termination of spousal
support. Here, the superior court could not consider modification absent a
change in circumstances.”
As
to Wife’s contention that the trial court’s failure to make findings on, or
establish, a marital living standard constituted an abuse of discretion, the
panel said that although that would generally be true, "in this case, the
amount and duration of spousal support was established by the parties'
agreement,” and Wife’s argument amounted to nothing more than a collateral attack
on the judgment. It also held that "(t)he burden of producing evidence was on
appellant Madhu as the moving party. She did not present evidence of the
marital standard of living or her needs based on that standard.”
Wife
argued that her living standard was dramatically lower than Husband’s. However,
the court said that a continuing disparity in the parties’ standard of living
after judgment was not, in and of itself, a basis upon which to modify support.
It reasoned that
"(e)ven assuming the mere fact that
appellant Madhu was a Ph.D. student and not employed full-time constituted a
material change of circumstances, the appellate record does not establish that
the superior court failed to consider all relevant evidence of the section 4320
circumstances that was presented or abused its
discretion in denying appellant's motion. … Madhu did not show that she had
made reasonable efforts to become fully self-supporting before June 1, 2010 but
was unable to do so under the prevailing economic conditions. Based on the
evidence before it, the court did not abuse its discretion in refusing to
modify the judgment to extend spousal support.”
In
a footnote, the court noted Wife’s argument that the parties’ judgment did not
contain a Gavron warning. However, it
held that unlike in Gavron, in this
case
"the order from which Madhu is appealing is not
an order for termination. We have no reason to suppose that Madhu was unaware
of the expectation that she become self-supporting by June 1, 2010 since Madhu
submitted to a vocational assessment which resulted in a report regarding her
job readiness and her potential salary range shortly before the agreeing to the
stipulation. The stipulation provided child support for child care expenses to
permit her to finish her MSW through only the end of October 2007 and annual
step-downs in spousal support over a three-year period, ending with zero
spousal support unless she showed ‘good cause’ to continue support.” What do you think of this case?
Tags:
Hot Off the Press
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Posted By Bonnie Riley,
Monday, March 26, 2012
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I am starting this thread to open a discussion about iOS devices and how we can use them in our practices.
Tags:
law office technology
mobile computing
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Posted By Bonnie Riley,
Sunday, March 25, 2012
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While working in the Exhibitors' Hall at the Spring Seminar here in Rancho Mirage, I had a chance to talk to Bryan Altman, COO of Our Family Wizard, who has an exhibitor's table here. Since there had been a relatively vigorous discussion on the listserv of what the newly announced Tonemeter feature could and could not be used for, I was happy to get info directly from Bryan, who graciously allowed me to take a couple of screen shots of the email application contained in the program. Bryan also wanted to stress that Tonemeter is not a psychologist who sits on your shoulder, nor is it particularly sophisticated with regard to subtle digs based on sarcasm, etc. The attached screenshot of the "meter" in action will give an idea of the level of sophistication it contains. Bryan also told me there is also a warning that what you have typed is "humiliating." If you need further information from Bryan you can email him at firstinitial_lastname AT ourfamilywizard.com (paraphrasing to fool spambots) or phone at (952) 548-8122. Disclaimer: I am not a customer of OFW, nor am I ever likely to be. I am passing on this info to assist our members, many of whom appear to utilize this service/program.
Attached Thumbnails:
Tags:
child custody
mobile parenting
parenting
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Posted By Bonnie Riley,
Sunday, March 25, 2012
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On the agenda:
Imputed income (Cooperman and Swan)
What law applies (Black and Lewis)
Ask the judges (Alksne, Lewis, Naughton, Unger)
Lots of folks pre-ordering the DVD!
Tags:
child support
continuing education
financial issues
spousal support
Spring Seminar
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Posted By Bonnie Riley,
Sunday, March 25, 2012
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On the agenda:
Imputed income (Cooperman and Swan)
What law applies (Black and Lewis)
Ask the judges (Alksne, Lewis, Naughton, Unger)
Lots of folks pre-ordering the DVD!
Tags:
child support
continuing education
financial issues
spousal support
Spring Seminar
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