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Contract analysis / letter-client-temporary-custody-order.docx
letter-client-temporary-custody-order.docx
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I. Summary of the Temporary Custody Order
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⚑ Liability cap to check against exposure
I. Summary of the Temporary Custody Order The temporary custody order entered on May 30, 2023, addresses both legal custody and physical custody of the minor children. We summarize each component below. A. Legal Custody The court granted temporary joint legal custody to both you and Mr. Rafael J. Medrano. Joint legal custody means that both parents share the right and the responsibility to participate in making major
II. Child Support Status
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⚑ Commercial term
II. Child Support Status The court did not make a temporary child support order at the May 30, 2023 hearing. The issue of child support remains pending and will be addressed at a future hearing once we have assembled the financial information necessary to support our request. As you know, we filed your Income and Expense Declaration (Judicial Council Form FL-150) concurrently with the Request for Order on May 2, 2023
III. Respondent's Counsel
III. Respondent's Counsel Mr. Medrano is represented in this matter by Gwendolyn R. Kwan (California State Bar No. 218453) and Benjamin T. Okafor (California State Bar No. 312776) of Kwan, Delacroix & Samuels LLP, located at 4400 Riverside Drive, Suite 700, Burbank, California 91505. Ms. Kwan is lead counsel and Mr. Okafor serves as the associate on the matter. Pursuant to the California Rules of Professional Conduct
IV. Next Steps
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⚑ Confidentiality undertaking
IV. Next Steps There are several important steps that we will be undertaking in the coming weeks and months. We outline each below. A. Appointment of Minor's Counsel We anticipate that the court will appoint an attorney to represent the interests of Isabela and Mateo in these proceedings, commonly referred to as "minor's counsel," pursuant to California Family Code section 3150. At the May 30 hearing, the court indic
V. Costs and Billing Update
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V. Costs and Billing Update We wish to remind you that the $50,000 retainer deposit received from you on April 20, 2023, is being held in our client trust account and applied against legal fees and costs as they are incurred, in accordance with the terms of our engagement letter dated April 18, 2023. The upcoming anticipated costs in this matter include: • Your share of the custody evaluation fee: approximately $9,25
VI. Confidentiality Reminder
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⚑ Confidentiality undertaking
VI. Confidentiality Reminder We remind you that all communications between Calderwood & Harkness LLP and you are protected by the attorney-client privilege. This means that the substance of our conversations, correspondence, and legal advice is confidential and cannot be disclosed to third parties without your consent, nor can it be compelled by opposing counsel or the court. Given both your and Mr. Medrano's public-
VII. Action Items for Client
VII. Action Items for Client To ensure that we can continue to advance your interests effectively, we respectfully ask that you attend to the following action items at your earliest convenience:
1. Review the enclosed temporary custody order. Please review the attached copy of the te
1. Review the enclosed temporary custody order. Please review the attached copy of the temporary custody order entered May 30, 2023, carefully and confirm that you understand the custodial schedule and all provisions contained therein. If you have any questions or concerns about any aspect of the order, please contact us immediately.
2. Begin assembling documentation for the custody evaluation. We recommend that you begin
Medium
⚑ Liability cap to check against exposure
2. Begin assembling documentation for the custody evaluation. We recommend that you begin gathering any documentation that may be useful in the custody evaluation process. This includes, but is not limited to: • The children's school records from Ridgeview Academy, including report cards, progress reports, attendance records, and any communications with teachers or administrators; • Medical and dental records for bot
3. Advise us of any changes to your work schedule. Please notify us promptly of any chang
3. Advise us of any changes to your work schedule. Please notify us promptly of any changes to your work schedule at Luminos Entertainment Group, Inc. that may affect custody logistics, including any upcoming travel, extended work hours, or changes to your employment status. It is important that we are aware of any potential scheduling conflicts so that we can plan accordingly and, if necessary, make appropriate arra
4. Contact us with any questions. If you have any questions, concerns, or new information
4. Contact us with any questions. If you have any questions, concerns, or new information that you believe may be relevant to the case, please do not hesitate to contact Devon Archer at (213) 555-7124 or darcher@calderwoodharkness.com, or Nadia Petrov at (213) 555-7138 or npetrov@calderwoodharkness.com.
VIII. Closing Assessment
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⚑ Commercial term
VIII. Closing Assessment We want to close by sharing our assessment that the temporary custody order entered on May 30, 2023, represents a favorable outcome at this stage of the proceedings. The court's decision to award you the majority timeshare — a 60/40 split — reflects its recognition of your established role as the children's primary caretaker and the stability and continuity that your home provides for Isabela