Contract analysis

I. INTRODUCTION AND PURPOSE OF THIS BRIEF This confidential mediation brief is submitted on behalf of Petitioner Marguerite D. Fonseca ("Ms. Fonseca") in advance of the first mediation session scheduled for November 17, 2023, before the Honorable Constance M. Yee (Ret.), at the offices of Pacific Coast Dispute Resolution Services. This brief is intended solely for the use of the mediator and is submitted pursuant to,

II. PROCEDURAL HISTORY A. The Domestic Partnership and Dissolution Marguerite D. Fonseca and Rafael J. Medrano registered their domestic partnership on September 12, 2015, with the California Secretary of State, under File Number DP-2015-038741. At the time, both parties resided in the greater Los Angeles area and were building their respective careers in the entertainment industry. The parties maintained a joint hou

1. Isabela Luz Fonseca-Medrano, born February 11, 2017, who is currently six (6) years of age; and

2. Mateo Elías Fonseca-Medrano, born August 29, 2019, who is currently four (4) years of age. The parties' relationship began to deteriorate in late 2021 and early 2022, as the demands of their respective careers and the pressures of parenthood created increasing tension. Ms. Fonseca filed a Petition for Dissolution of Domestic Partnership on July 8, 2022, in the Superior Court of California, County of Los Angeles, S

III. THE PARTIES A. Marguerite D. Fonseca (Petitioner) Marguerite Delphine Fonseca is thirty-nine (39) years of age, born June 14, 1984. She currently resides at 1742 Laurel Canyon Boulevard, Unit 3A, Studio City, CA 91604. Ms. Fonseca has resided at this address since 2019 and maintains a stable, well-established home for the children in a family-friendly neighborhood conveniently located near the children's school,

IV. SUMMARY OF THE CUSTODY EVALUATION REPORT A. Overview of Dr. Sorensen's Evaluation Process As noted above, Dr. Elena V. Sorensen, Psy.D. (California License Number PSY 24891), of Sorensen Family Behavioral Health, P.C., was appointed by stipulation and order of the Court as the custody evaluator in this matter. Dr. Sorensen is a licensed psychologist with over seventeen years of experience in family law evaluation

V. MS. FONSECA'S CUSTODY AND PARENTING PLAN PROPOSALS Ms. Fonseca submits the following proposals for the mediator's consideration. These proposals are designed to be consistent with Dr. Sorensen's recommendations, reflective of the best interests of the children under California Family Code section 3011 and related provisions, and responsive to the practical realities of both parents' lives and careers. A. Legal Cus

VI. MS. FONSECA'S CHILD SUPPORT PROPOSALS A. Income Summary For purposes of calculating child support, Ms. Fonseca presents the following income summary: Ms. Fonseca's Gross Monthly Income: $72,500. This figure is derived from Ms. Fonseca's total annual compensation of $870,000, which includes her base salary of $485,000, discretionary bonuses averaging $210,000 per year (based on a three-year average), and restricte

VII. ISSUES FOR MEDIATION AND MS. FONSECA'S SETTLEMENT OBJECTIVES A. Primary Issues to Be Resolved Ms. Fonseca identifies the following as the primary issues to be addressed during the mediation process:

1. Timeshare Percentage. The specific allocation of parenting time between the parties during the school year and summer, including the detailed weekly schedule. Ms. Fonseca anticipates that Mr. Medrano will seek a higher timeshare than the 65/35 school-year and 50/50 summer arrangement she has proposed. Ms. Fonseca's position is that the proposed timeshare is well-supported by the custody evaluation, consistent with

2. On-Location Work Provisions. The specific terms of the provision governing the transfer of custodial time when either parent accepts work requiring extended travel, including the threshold for triggering the provision (Ms. Fonseca proposes 14 consecutive calendar days), the parameters for scheduling make-up time, and the role of the parenting plan coordinator in resolving disputes under this provision.

3. Child Support Amount. The base monthly child support obligation, including whether the parties will agree to a deviation from the guideline amount and, if so, the terms and conditions of that deviation.

4. Education and Extracurricular Cost-Sharing. The specific allocation of tuition costs, extracurricular activity costs, and related educational expenses between the parties.

5. Travel Notice and Consent Requirements. The specific terms governing domestic and international travel with the children, including notice periods, consent requirements, and any geographic limitations.

6. Selection and Appointment of a Parenting Plan Coordinator. The identification and appointment of a qualified professional to serve as parenting plan coordinator, including the scope of the coordinator's authority, the process for engaging the coordinator, and the allocation of the coordinator's fees between the parties. B. Ms. Fonseca's Settlement Priorities Ms. Fonseca approaches this mediation with the following

VIII. CONCLUSION Ms. Fonseca respectfully requests that the mediator, the Honorable Constance M. Yee (Ret.), facilitate a resolution of the outstanding custody, parenting plan, and child support issues in this matter that prioritizes the best interests of Isabela Luz Fonseca-Medrano and Mateo Elías Fonseca-Medrano above all other considerations. Ms. Fonseca approaches this mediation in good faith, with proposals that