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Spousal Support for the 21st Century

Posted By David M. Lederman, Saturday, December 5, 2015

Everything you want to know about Spousal Support!  Come attend the 24th Annual ACFLS Spring Seminar at the Omni Rancho Las Palmas April 1, 2016 through April 3, 2016.

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Spousal Support for the 21st Century

Posted By David M. Lederman, Saturday, December 5, 2015

Everything you want to know about Spousal Support!  Come attend the 24th Annual ACFLS Spring Seminar at the Omni Rancho Las Palmas April 1, 2016 through April 3, 2016.

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Anyone Here Licensed in Arizona?

Posted By John D. Hodson, Thursday, April 4, 2013
Looking for a CFLS who is also licensed in Arizona, to consult on a project.  Any takers?

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Hot Off the Press: L.M. v. M.G.

Posted By Dawn Gray, Tuesday, August 7, 2012

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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Hot Off the Press: In re the Marriage of Mark O. Wilson and Tamara S. Bodine

Posted By Dawn Gray, Friday, July 6, 2012

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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Hot Off the Press: Marriage of Sameer Khera and Madhu Sameer

Posted By Frieda Gordon, Friday, June 22, 2012
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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Hot Off the Press: Marriage of Sameer Khera and Madhu Sameer

Posted By Dawn Gray, Thursday, June 21, 2012

 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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iPad discussions

Posted By Bonnie Riley, Monday, March 26, 2012
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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Our Family Wizard Tonemeter Information

Posted By Bonnie Riley, Sunday, March 25, 2012

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 (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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Last Day of ACFLS Spring Seminar

Posted By Bonnie Riley, Sunday, March 25, 2012
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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2019 ACFLS 27th Annual Spring Seminar in Rancho Mirage, CA