Contract analysis

I. Purpose and Executive Summary This memorandum provides a comprehensive summary of all final settlement terms agreed upon during Mediation Session 3, held on January 19, 2024, before the Honorable Constance M. Yee (Ret.) at Pacific Coast Dispute Resolution Services, 801 South Figueroa Street, Suite 1250, Los Angeles, California 90017. The purpose of this memorandum is to memorialize the substantive terms of the par

II. Procedural Background The following procedural history provides context for the settlement terms summarized in this memorandum:

1. Domestic Partnership Registration. Marguerite D. Fonseca and Rafael J. Medrano registered a domestic partnership with the California Secretary of State on September 12, 2015 (California Secretary of State File No. DP-2015-038741). The parties did not subsequently marry.

2. Dissolution Petition. Ms. Fonseca filed a Petition for Dissolution of Domestic Partnership on July 8, 2022 (Case No. 22STFL09847, Superior Court of California, County of Los Angeles). Mr. Medrano filed his Response on August 19, 2022. At the time of the filing, the parties had been living separately since approximately May 2022.

3. Dissolution Judgment. A judgment of dissolution was entered by the court on November 3, 2022. The judgment dissolved the domestic partnership and resolved all property division issues by stipulation of the parties. However, the court expressly reserved jurisdiction over all issues relating to custody, visitation, and child support, as the parties had been unable to reach agreement on those issues at that time.

4. Engagement of Calderwood & Harkness LLP. Ms. Fonseca retained Calderwood & Harkness LLP on April 18, 2023, for the purpose of representing her in the remaining custody and child support matters. Prior counsel (Maria C. Orosco of Orosco Family Law, APLC) had represented Ms. Fonseca through the dissolution proceedings and withdrew upon entry of the dissolution judgment.

5. Request for Order (RFO). On May 2, 2023, we filed a Request for Order re Custody & Child Support on behalf of Ms. Fonseca, seeking primary physical custody, joint legal custody with educational tie-breaking authority, and an order of child support.

6. Temporary Custody Order. Following a hearing on May 30, 2023, the court entered a temporary custody order establishing a 60/40 timeshare in favor of Ms. Fonseca (approximately 219 overnights per year to Ms. Fonseca and 146 overnights per year to Mr. Medrano). The temporary order also established joint legal custody on an interim basis without designating tie-breaking authority on any category of decisions.

7. Appointment of Minor's Counsel. On June 22, 2023, the court appointed Tessa L. Brannigan, Esq. (California State Bar No. 267894), as Minor's Counsel pursuant to California Family Code section 3150 to represent the interests of both Isabela and Mateo in the custody proceedings.

8. Custody Evaluation. By stipulation of the parties, filed July 14, 2023, the court ordered a comprehensive custody evaluation pursuant to California Family Code section 3111. The court appointed Dr. Elena V. Sorensen, Psy.D. (California License No. PSY 24891), of Sorensen Family Behavioral Health, P.C., 2121 Avenue of the Stars, Suite 800, Los Angeles, California 90067, to conduct the evaluation. Dr. Sorensen compl

9. Stipulation and Order to Seal Court File. On July 14, 2023, the parties filed a joint Stipulation and Order to Seal Court File pursuant to California Rules of Court, Rule 2.550 et seq. The court granted the sealing order on the same date. All filings in this matter have been made under seal since that date.

10. Mediation. The three mediation sessions were held as follows: • Session 1: November 17, 2023 (full day, approximately 8 hours) • Session 2: December 15, 2023 (full day, approximately 9 hours) • Session 3: January 19, 2024 (full day, approximately 10 hours) All sessions were conducted before the Honorable Constance M. Yee (Ret.) at Pacific Coast Dispute Resolution Services. Full agreement was reached at the conclu

III. Legal Custody The parties have agreed to the following terms regarding legal custody of Isabela and Mateo: Joint Legal Custody. Both parents shall share joint legal custody of Isabela Luz Fonseca-Medrano and Mateo Elías Fonseca-Medrano. This means that both Ms. Fonseca and Mr. Medrano shall have equal rights and responsibilities to make decisions relating to the health, education, and welfare of the children, su

IV. Physical Custody and Timeshare A. General Structure The parties have agreed to joint physical custody of Isabela and Mateo, with primary residence designated with Ms. Fonseca. The children's primary residential address shall be Ms. Fonseca's current residence at 1742 Laurel Canyon Boulevard, Unit 3A, Studio City, California 91604. This address shall be used for school enrollment and all official purposes unless o

V. Child Support A. Income Figures Used for Calculation The child support calculation is based on the following income figures, which were agreed upon by the parties during the mediation process after review of the financial disclosures, tax returns, and the forensic income analysis: Ms. Fonseca's Gross Monthly Income: $72,500 ($870,000 annual total compensation ÷ 12). Ms. Fonseca is employed as Senior Vice President

VI. Education and Extracurricular Costs A. Tuition — Ridgeview Academy Both children are currently enrolled at Ridgeview Academy, located at 4515 Sepulveda Boulevard, Sherman Oaks, California 91403. The parties have agreed that both children shall continue to attend Ridgeview Academy for the foreseeable future, subject to the joint legal custody provisions regarding educational decisions (including Ms. Fonseca's tie-

VII. Healthcare and Medical Expenses A. Health Insurance The children shall remain enrolled on Ms. Fonseca's employer-sponsored health insurance plan through Luminos Entertainment Group, Inc. The current plan is administered by Veridian Health Insurance Co. and provides comprehensive medical, dental, and vision coverage for dependents. Ms. Fonseca shall be responsible for maintaining health insurance coverage for bot

VIII. Travel Provisions A. International Travel Neither parent shall take either child outside the continental United States without providing 30 days' prior written notice to the other parent and obtaining the other parent's written consent. Written notice shall include the destination, dates of travel, mode of transportation, accommodations, and contact information for the traveling parent during the trip. If the n

IX. Confidentiality and Non-Disparagement The parties have agreed to include a mutual non-disparagement and confidentiality clause in the Stipulated Custody & Parenting Plan Agreement. The key terms of this provision are as follows: Non-Disparagement. Neither party shall make disparaging, derogatory, or defamatory statements about the other party in the presence of the children, to the children's teachers, coaches, o

X. Court Sealing Order The court file in this matter has been sealed pursuant to California Rules of Court, Rule 2.550 et seq. The Stipulation and Order to Seal Court File was filed by the parties on July 14, 2023, and was granted by the court on the same date. The sealing order covers all documents filed in the case, including but not limited to the dissolution petition, the RFO, the custody evaluation report, finan

XI. Parenting Plan Coordinator Appointment. The parties have agreed to appoint Dr. Marcus W. Ingalls, LMFT (California License No. LMFT 89412), of Ingalls & Cuevas Family Counseling, located at 10880 Wilshire Boulevard, Suite 630, Los Angeles, California 90024, as the Parenting Plan Coordinator for the parties and the children. Role and Scope. Dr. Ingalls's role shall be to assist the parties in resolving day-to-day

XII. Summary of Financial Obligations The following table summarizes the principal financial obligations of each party under the agreed settlement terms: The extracurricular cost-sharing arrangement (60% Medrano / 40% Fonseca), which shifts a greater relative burden to Mr. Medrano, serves as the primary justification for the agreed $174/month below-guideline child support deviation. Taken as a whole, the financial pa

XIII. Next Steps and Recommendations A. Document Drafting I recommend that we proceed immediately to drafting the following execution documents, with a target completion date for internal review of January 26, 2024, and a target execution date of January 31, 2024:

1. Stipulated Custody & Parenting Plan Agreement (execution version) — incorporating all terms summarized in Sections III through XI of this memorandum, together with standard boilerplate provisions regarding modification, enforcement, governing law, and integration.

2. Child Support Agreement — to be attached as an exhibit or addendum to the Stipulated Custody & Parenting Plan Agreement, setting forth the agreed child support amount, payment terms, and the annual adjustment provision.

3. Exhibit A — Holiday & Vacation Schedule — a detailed calendar-based schedule specifying the holiday and vacation rotation for odd and even years, including exchange times, locations, and protocols.

4. Exhibit B — Right of First Refusal & Travel Notice Protocol — setting forth the right of first refusal procedures (8-hour trigger, 2-hour response window) and the travel notice requirements for international, domestic, and on-location work travel.

5. Stipulation for Judgment re Custody, Parenting Plan & Child Support — the formal stipulation to be filed with the Superior Court of California, County of Los Angeles, requesting the court's approval and entry of the stipulated agreement as a court order. Upon completion of internal review, I recommend that we transmit execution copies of all documents to Kwan, Delacroix & Samuels LLP (attention: Gwendolyn R. Kwan,

1. Client Letter. We should provide Ms. Fonseca with a detailed letter summarizing the final terms of the court order and her obligations thereunder, including payment deadlines for child support, tuition cost-sharing, and other financial obligations.

2. Introduction of Parenting Plan Coordinator. We should facilitate an introduction between the Parenting Plan Coordinator (Dr. Marcus W. Ingalls) and both parties, ideally through a joint initial session to be scheduled within 30 days of entry of the order.

3. Financial Implementation. We should initiate the adjustment of child support payments, tuition cost-sharing, and other financial obligations to become effective upon entry of the court order. This may include coordination with Ms. Fonseca's payroll department and with Ridgeview Academy's billing office to establish the appropriate payment arrangements.

4. Confirmation of Filed Order. Upon receipt of the filed and endorsed court order, we should distribute conformed copies to Ms. Fonseca, to Mr. Medrano's counsel, and to Minor's Counsel.

5. Matter Closing. Upon receipt and distribution of the filed order, we should confirm matter closing procedures with the partners, including the preparation of a closing letter to Ms. Fonseca, the archiving of the matter file, and the processing of any final billing.

XIV. Fee Status Total fees billed to date and the estimated remaining work through execution, filing, and court entry will be addressed in a separate billing memorandum. However, I note the following for the partners' reference: Retainer and Billing. A retainer deposit of $50,000 was received from Ms. Fonseca on April 20, 2023. All billing in this matter has been on an hourly basis pursuant to the engagement letter d