Contract analysis

I. Executive Summary The purpose of this memorandum is to analyze the California child support guideline calculation under Family Code section 4055 et seq. as applied to the facts of Fonseca v. Medrano. The analysis concerns support obligations for the parties' two minor children: Isabela Luz Fonseca-Medrano (date of birth: February 11, 2017; age 6) and Mateo Elías Fonseca-Medrano (date of birth: August 29, 2019; age

II. Applicable Legal Framework A. California Family Code § 4055 — The Guideline Formula California employs a statewide uniform guideline for the determination of child support, codified at Family Code section 4050 et seq. The Legislature enacted the uniform guideline to promote consistency and predictability in child support calculations across all California counties, and to ensure that children benefit from both pa

Section 4057(b) enumerates specific factors that may rebut the presumption and justify a deviation from the guideline amount. These factors include, among others: • That the parent being ordered to pay support has an extraordinarily high income and the guideline amount exceeds the children's reasonable needs; • That a parent is not contributing to the needs of the children commensurate with their custodial time; • Th

III. Income Inputs The accuracy of the guideline calculation depends critically on the income inputs used. This section sets forth the income figures for each party, the bases for those figures, and the relevant legal and factual considerations that may affect income determination at trial or in settlement negotiations. A. Marguerite D. Fonseca — Petitioner / Client Ms. Fonseca is employed by Luminos Entertainment Gr

1. Annual Base Salary: $485,000 per year, as reflected in Ms. Fonseca's current offer letter and Luminos compensation records on file with the firm.

2. Average Annual Discretionary Bonus: $210,000, calculated as a three-year average of the discretionary bonuses paid to Ms. Fonseca in calendar years 2020, 2021, and 2022. The individual annual bonus amounts varied over this period, reflecting the discretionary nature of the bonus and fluctuations in Luminos's financial performance, but the three-year average of $210,000 represents a reasonable and commonly accepted

3. Annual RSU Vesting: Approximately $175,000 per year, based on the vesting schedule under the Luminos Entertainment Group, Inc. Equity Incentive Plan. Ms. Fonseca was granted RSUs in connection with her promotion to SVP and has subsequent annual grants. The $175,000 figure reflects the approximate value of shares vesting annually at current market prices. Total annual compensation: $485,000 + $210,000 + $175,000 =

IV. Timeshare Inputs and Scenarios The timeshare percentage — i.e., the proportion of custodial time allocated to each parent — is a critical variable in the guideline formula. As discussed in Section II.A above, the formula credits the higher-earning parent for time spent with the children, and even modest changes in the timeshare can produce meaningful shifts in the guideline support amount. This section sets forth

1. Direction of payment is constant across all scenarios. In every scenario modeled, Ms. Fonseca is the obligor (payor) and Mr. Medrano is the obligee (payee). This is because Ms. Fonseca's income is sufficiently higher than Mr. Medrano's that, even at a 75/25 timeshare, the formula still requires a transfer from Fonseca to Medrano.

2. As Ms. Fonseca's timeshare increases, the guideline support payable by her decreases significantly. This inverse relationship between custodial time and support obligation is a built-in feature of the section 4055 formula. At a 50/50 split, guideline support is approximately $2,350 per month. At the proposed 63.6% split, it is $1,274 per month — a reduction of approximately $1,076 per month, or nearly 46%. At a 75

3. Even a modest shift of a few percentage points in either direction has a meaningful impact on the guideline amount. At the income levels involved in this case, a shift of approximately 3 to 5 percentage points in the timeshare translates to a change of approximately $100 to $200 per month in the guideline support amount. For example, the difference between the proposed 63.6% and a 65% timeshare is approximately $9

4. At the proposed 63.6%/36.4% split, guideline support is $1,274 per month payable by Fonseca to Medrano. This is the figure we recommend using as the baseline for settlement discussions.

V. Analysis of the Guideline Amount at Proposed Timeshare A. DissoMaster Output at 63.6% / 36.4% The following is a detailed breakdown of the DissoMaster calculation at the proposed timeshare of 63.6% for Ms. Fonseca and 36.4% for Mr. Medrano: Gross Monthly Incomes: • Ms. Fonseca's gross monthly income: $72,500 • Mr. Medrano's imputed gross monthly income: $28,333 • Combined gross monthly income: $100,833 Tax Adjustm

1. Childcare costs related to employment or reasonably necessary education or training for employment. If either parent incurs childcare costs — such as after-school care, babysitting during work hours, or similar expenses — those costs are added to the base guideline support and apportioned between the parents.

2. Unreimbursed healthcare costs for the children. Medical, dental, vision, orthodontic, psychological, and other healthcare costs that are not covered by insurance are mandatory add-ons. Discretionary add-on expenses under section 4062(b) include:

1. Costs of education at private schools. Both children are enrolled at or expected to enroll at Ridgeview Academy, a private school in the greater Los Angeles area. Current annual tuition is $32,400 for Isabela (first grade) and $26,800 for Mateo (preschool program), for a combined annual tuition of $59,200 (or approximately $4,933 per month). Private school tuition is a discretionary add-on, meaning the court has d

2. Extracurricular activities. These may include sports, music lessons, tutoring, summer camps, and similar activities. Isabela currently participates in ballet and swimming lessons; Mateo is not yet enrolled in formal extracurricular activities but may be in the near future.

3. Travel expenses for visitation. If the custodial schedule requires significant travel — for example, if Mr. Medrano accepts out-of-state or international work engagements — the travel costs associated with transporting the children may be treated as a discretionary add-on. Add-on expenses are typically apportioned in proportion to each parent's respective income or by separate agreement of the parties. Given the p

VI. Preliminary Considerations for Deviation A detailed analysis of potential deviation arguments will be prepared in a separate memorandum if the team determines that pursuing a deviation from guideline is strategically appropriate. However, a brief overview of the relevant considerations is warranted here. Family Code section 4057(b) permits deviation from the presumptively correct guideline amount where the circum

VII. Open Issues and Next Steps Several issues remain open and will require follow-up action before the guideline analysis can be finalized. This section identifies each issue, the responsible party, and the anticipated timeline. A. Forensic Income Analysis Harold K. Yamamoto, CPA/ABV/CFF, of the accounting firm Yamamoto Brace & Liu, LLP ("YBL"), has been retained to perform a forensic income analysis of Mr. Medrano'

VIII. Conclusion Based on the analysis set forth in this memorandum, the following conclusions and recommendations are offered:

1. Guideline Amount. At the proposed timeshare of 63.6% (Fonseca) / 36.4% (Medrano), using gross monthly incomes of $72,500 for Ms. Fonseca and $28,333 for Mr. Medrano, for a combined gross monthly income of $100,833, the California guideline child support for two minor children is $1,274 per month payable by Ms. Fonseca to Mr. Medrano. This figure is calculated using the Family Code section 4055 formula as implement

2. Presumptive Correctness. The guideline amount of $1,274 per month is presumptively correct under Family Code section 4057(a) and will serve as the starting point for any negotiation or court determination. Deviation from this amount is permissible only upon a showing of circumstances enumerated in section 4057(b), supported by a written declaration of reasons and approved by the court.

3. Timeshare Sensitivity. The scenario analysis presented in Section IV demonstrates that the timeshare percentage is a critical variable in the guideline calculation. Even modest changes in the timeshare allocation shift the support amount by several hundred dollars per month. This underscores the strategic importance of the custody evaluation and the negotiations surrounding the permanent custodial schedule. Specif

4. Settlement Baseline. We recommend using the $1,274 per month figure as the baseline for settlement discussions with Mr. Medrano's counsel, while exploring the possibility of a downward deviation if favorable extracurricular cost-sharing terms can be negotiated. A potential structure — in which Mr. Medrano accepts a larger share of private school tuition and extracurricular costs in exchange for a slightly higher b

5. Pending Updates. This analysis will be updated upon receipt of the following: • The YBL forensic income report (expected within approximately six to eight weeks); • The Dr. Sorensen custody evaluation report (expected within approximately 90 to 120 days); • Confirmation of Mr. Medrano's tax filing status and dependent coverage insurance costs. I am available to discuss this memorandum and the scenarios at Devon's