Contract analysis

I. INTRODUCTION AND IDENTITY OF DECLARANT

1. My name is Marguerite Delphine Fonseca. I was born on June 14, 1984, and I am currently thirty-nine (39) years of age. I am the Petitioner in the above-captioned matter.

2. I currently reside at 1742 Laurel Canyon Boulevard, Unit 3A, Studio City, California 91604. I have resided at this address continuously since before the filing of the Petition for Dissolution of Domestic Partnership and it is the primary residence of the two minor children who are the subject of this Request for Order.

3. I make this Declaration in support of Petitioner's Request for Order re Custody and Child Support, which is filed concurrently herewith. This Declaration is intended to provide the Court with the factual background necessary to evaluate the requested relief, including the establishment of a formal custody and visitation schedule and the calculation of child support under the California guidelines.

4. I have personal knowledge of all facts stated in this Declaration and, if called as a witness, I could and would testify competently thereto. Except where otherwise indicated, the matters set forth herein are based upon my own direct observation and experience.

II. EMPLOYMENT AND PROFESSIONAL BACKGROUND

5. I am currently employed as Senior Vice President, Original Content Development at Luminos Entertainment Group, Inc. ("Luminos"), a streaming media and production company headquartered at 3200 West Olive Avenue, Burbank, California 91505. In this role, I oversee the development, production, and delivery of a slate of approximately eighteen (18) original scripted and unscripted series for the Luminos streaming platf

6. I have been employed by Luminos since 2017. Prior to my current position, I held progressively senior roles within the company's content development division. My work at Luminos is office-based at the Burbank headquarters, and my schedule is generally predictable, consisting of regular weekday business hours with occasional evening events or weekend obligations that are planned well in advance.

7. My current annual compensation consists of the following components: (a) Base salary: Four Hundred Eighty-Five Thousand Dollars ($485,000) per year. (b) Discretionary annual bonus: Based on a three-year average, my discretionary bonus has averaged approximately Two Hundred Ten Thousand Dollars ($210,000) per year. This bonus is not guaranteed but has been paid consistently for each of the past three fiscal years.

8. In total, my approximate annual compensation is Eight Hundred Seventy Thousand Dollars ($870,000). My gross monthly income, computed by dividing total annual compensation by twelve, is approximately Seventy-Two Thousand Five Hundred Dollars ($72,500) per month.

9. A complete Income and Expense Declaration on Judicial Council Form FL-150, setting forth full details of my income, deductions, expenses, and assets, has been prepared and is filed concurrently with this Declaration and the accompanying Request for Order. I incorporate the information set forth in the FL-150 herein by reference.

III. DOMESTIC PARTNERSHIP AND FAMILY HISTORY

10. Respondent Rafael Joaquín Medrano was born on March 22, 1982. He is currently forty-one (41) years of age.

11. Mr. Medrano and I registered as domestic partners in the State of California on September 12, 2015. Our domestic partnership was registered with the California Secretary of State under File Number DP-2015-038741. The parties were never married.

12. Two minor children were born of our domestic partnership: (a) Isabela Luz Fonseca-Medrano, born February 11, 2017. Isabela was six (6) years of age at the time this Request for Order was filed. (b) Mateo Elías Fonseca-Medrano, born August 29, 2019. Mateo was three (3) years of age at the time this Request for Order was filed.

13. Both Isabela and Mateo have lived in the greater Los Angeles area for their entire lives. They were born in Los Angeles, and neither child has ever resided outside of the Los Angeles metropolitan area. Their social networks, educational institutions, pediatric healthcare providers, and extended family connections are all based in the Los Angeles area.

14. Both children are healthy and well-adjusted. They have a close and loving bond with one another, and I believe it is essential to their well-being that they continue to reside together under any custody arrangement ordered by this Court.

IV. DISSOLUTION OF DOMESTIC PARTNERSHIP

15. On July 8, 2022, I filed a Petition for Dissolution of Domestic Partnership in this Court, initiating the above-captioned proceeding, Case No. 22STFL09847, in the Superior Court of California, County of Los Angeles.

16. A Judgment of Dissolution of Domestic Partnership was entered on November 3, 2022. The dissolution judgment resolved all issues pertaining to the division of community property and the allocation of debts and obligations between the parties. The judgment also addressed and resolved issues of partner support (analogous to spousal support). Those matters are not at issue in this Request for Order and are not addres

17. Critically, the dissolution judgment expressly reserved jurisdiction over the issues of child custody, visitation, and child support. These issues were not adjudicated in connection with the dissolution proceedings and remain pending before this Court. It is this reservation of jurisdiction that gives rise to the instant Request for Order.

18. At the time of the dissolution, the parties were operating under a mutual, informal understanding regarding custody and visitation of the minor children. Because the parties believed they could cooperate on these matters without court intervention, no formal orders were sought at that time. As detailed below, subsequent events have demonstrated that a formal, court-ordered custody and visitation schedule is neces

V. RESPONDENT'S BACKGROUND AND EMPLOYMENT

19. Mr. Medrano is a freelance cinematographer and director of photography. He is a skilled professional who works on feature films and episodic television productions. His work in the entertainment industry is, by its nature, project-based and involves periods of intensive on-set work interspersed with periods between engagements.

20. Mr. Medrano operates primarily through his loan-out entity, Medrano Visuals, LLC, a California limited liability company. To my knowledge, Mr. Medrano is the sole member and manager of Medrano Visuals, LLC, and substantially all of his professional income flows through this entity.

21. Mr. Medrano's annual income is variable due to the freelance and project-based nature of his work. Based on information available to me, including financial disclosures made during the dissolution proceedings and subsequent communications, Mr. Medrano's gross annual income, calculated as a three-year average, is approximately Three Hundred Forty Thousand Dollars ($340,000) per year. This yields an imputed gross m

22. I recognize that Mr. Medrano's actual income in any given year may be higher or lower than this average, depending on the number and scale of projects he secures. I respectfully request that the Court evaluate Mr. Medrano's income based on the three-year average, as it provides the most accurate and fair representation of his earning capacity given the variable nature of his profession.

23. Mr. Medrano currently resides at 609 Moorpark Street, Apartment 12, North Hollywood, California 91602. His residence is located approximately six (6) miles from my home in Studio City, which facilitates reasonable custodial exchanges and allows both parents to remain in close geographic proximity to the children's school and activities.

VI. THE CHILDREN'S CURRENT LIVING SITUATION AND EDUCATIONAL ENROLLMENT

24. Isabela Luz Fonseca-Medrano is currently enrolled in the first grade at Ridgeview Academy, a private school located at 4515 Sepulveda Boulevard, Sherman Oaks, California 91403. The annual tuition for Isabela's first-grade program is Thirty-Two Thousand Four Hundred Dollars ($32,400).

25. Mateo Elías Fonseca-Medrano is currently enrolled in the pre-kindergarten program at Ridgeview Academy, the same institution attended by his older sister. The annual tuition for Mateo's pre-kindergarten program is Twenty-Six Thousand Eight Hundred Dollars ($26,800).

26. The total combined annual tuition for both children at Ridgeview Academy is Fifty-Nine Thousand Two Hundred Dollars ($59,200).

27. Both children have attended Ridgeview Academy since their respective enrollment ages. Isabela began attending the school's early childhood program when she was approximately three years old, and Mateo was enrolled in the toddler program at approximately age two. The school provides a structured, nurturing, and academically rigorous environment. Both children have formed strong bonds with their teachers and classm

28. Ridgeview Academy is conveniently located approximately three (3) miles from my home in Studio City and approximately five (5) miles from Mr. Medrano's residence in North Hollywood. Both parents are able to transport the children to and from school without difficulty.

29. Since the entry of the dissolution judgment, the children's primary residence has been with me at the Studio City address. The children have their own bedrooms at my home, and their clothing, toys, school supplies, and personal belongings are principally housed at my residence. The children also maintain personal items and a bedroom at Mr. Medrano's apartment for use during their custodial time with him.

VII. THE INFORMAL CUSTODY ARRANGEMENT FOLLOWING DISSOLUTION

30. Following the entry of the dissolution judgment on November 3, 2022, the parties did not establish a formal custody or visitation order. As noted above, the dissolution judgment expressly reserved jurisdiction over these issues, and at that time, Mr. Medrano and I believed we could manage co-parenting cooperatively without the need for court intervention.

31. Instead, the parties operated under an informal arrangement whereby the children spent the majority of their time with me—approximately four to five days per week—and spent weekends and occasional weeknights with Mr. Medrano. The precise schedule varied from week to week depending on Mr. Medrano's work commitments and the children's school and activity schedules, but the general pattern was consistent: the childr

32. This informal arrangement, while imperfect and lacking the predictability of a formal court order, functioned reasonably well from approximately November 2022 through early February 2023. During this approximately three-month period, the parties were generally able to communicate about scheduling, transitions were handled without significant conflict, and the children appeared to adjust to the new living arrangem

33. Throughout this period, I served as the primary day-to-day caretaker of the children. My responsibilities included, but were not limited to: (a) Transporting the children to and from Ridgeview Academy each school day, including morning drop-off and afternoon pick-up; (b) Scheduling, attending, and following up on all medical and dental appointments for both children, including well-child visits, vaccinations, and

34. Mr. Medrano participated in the children's lives during his custodial time and was an engaged and caring parent when present. I do not dispute that Mr. Medrano loves the children and that they love him. However, the reality of the informal arrangement was that the substantial majority of the day-to-day caregiving burden fell on me, consistent with the pattern that had existed throughout the children's lives, incl

VIII. BREAKDOWN OF THE INFORMAL ARRANGEMENT — MR. MEDRANO'S EXTENDED ABSENCE

35. In or around late January 2023, Mr. Medrano informed me that he had accepted a position as director of photography on a feature film requiring an extended on-location shoot in Vancouver, British Columbia, Canada. Mr. Medrano explained that the production schedule would require him to be on location in Vancouver for approximately seven (7) weeks.

36. Mr. Medrano provided minimal advance notice of the duration and timing of his absence. To the best of my recollection, Mr. Medrano first mentioned the possibility of the Vancouver project in passing approximately two weeks before his departure, but he did not confirm the commitment or communicate the full extent of the time away until shortly before he left. He did not engage in any meaningful discussion with me

37. Mr. Medrano departed for Vancouver in approximately early to mid-February 2023. He did not return to Los Angeles until approximately late March or early April 2023—a period of approximately seven consecutive weeks.

38. During the entire seven-week period of Mr. Medrano's absence, he was unable to exercise any custodial time with the children whatsoever. The children remained exclusively in my care for the duration. I was solely responsible for all aspects of their daily lives, including school transportation, meals, bedtime routines, weekend activities, medical care, and emotional support.

39. Mr. Medrano did not discuss or negotiate any alternative arrangements for maintaining his relationship with the children during his time away. For example, he did not propose a regular schedule of video calls at set times, did not arrange for the children to spend time with his parents or other family members in his absence, and did not suggest any other measures to maintain continuity in the children's relations

40. Although Mr. Medrano made intermittent video calls with the children during his seven-week absence, these calls were irregular in frequency and often occurred at inconvenient times due to the demands of his production schedule. Some calls came late in the evening, after the children's bedtime, or were cut short because Mr. Medrano was called back to set. On several occasions, days passed between calls. The lack o

41. The impact of Mr. Medrano's prolonged absence on the children was significant and observable. Isabela, who was six years old at the time, expressed confusion and sadness about her father's extended time away. On multiple occasions, Isabela asked me when her father would come home, how many more days until he returned, and why he had to go away for so long. These questions were often accompanied by visible distres

42. Mateo, who was three years old at the time, displayed behavioral regression consistent with the stress of the disrupted routine. Specifically, Mateo exhibited increased clinginess, reluctance to separate from me at school drop-off (which had not been an issue prior to Mr. Medrano's departure), difficulty falling asleep at night, and occasional nighttime waking and crying. While I cannot state with medical certain

IX. CONTINUED INSTABILITY AND NEED FOR A FORMAL ORDER

43. Upon Mr. Medrano's return from Vancouver in approximately late March or early April 2023, the parties attempted to resume the informal custody arrangement. However, the arrangement proved unworkable.

44. Mr. Medrano, understandably wanting to reconnect with the children after his extended absence, sought to "make up" for lost time by requesting extended blocks of custodial time that went significantly beyond the pre-departure pattern. Specifically, Mr. Medrano requested that the children spend four or five consecutive days with him, including school nights, on multiple occasions. While I sympathized with Mr. Medr

45. Disagreements arose between the parties regarding scheduling, pick-up and drop-off logistics, and the children's participation in after-school activities. Mr. Medrano expressed frustration that the children's scheduled activities limited his available custodial time, and I expressed concern that deviating from the established routine was unsettling for the children. These disagreements, while not rising to the le

46. Of particular concern, Mr. Medrano indicated in conversations with me in approximately April 2023 that he anticipated additional on-location work opportunities outside of California—and potentially outside of the United States—in the coming months. While Mr. Medrano did not identify specific projects, he conveyed that his professional aspirations involved pursuing high-profile cinematography work that would likel

47. As these difficulties mounted, I became increasingly convinced that the lack of a formal, court-ordered custody and visitation schedule was detrimental to the children's need for stability, predictability, and routine. The informal arrangement, which had functioned adequately during a limited period of relative calm, proved incapable of withstanding the disruptions caused by Mr. Medrano's professional travel obli

48. The children's enrollment at Ridgeview Academy requires consistent attendance during the school year. The school's academic calendar runs from early September through mid-June, and the school's policies emphasize the importance of regular attendance and punctuality. The informal arrangement, as disrupted by Mr. Medrano's travel and the ensuing scheduling conflicts, made it difficult to ensure that the children's

X. DECLARANT'S PROPOSED CUSTODY AND TIMESHARE ARRANGEMENT

49. For all of the foregoing reasons, I respectfully request that the Court establish a formal custody and visitation order governing the parties' respective rights and responsibilities with respect to the minor children, Isabela Luz Fonseca-Medrano and Mateo Elías Fonseca-Medrano.

50. Legal Custody. I request that the Court award joint legal custody of both minor children to both parties. Joint legal custody will ensure that both Mr. Medrano and I participate in major decisions affecting the children's health, education, and welfare, consistent with our shared commitment to co-parenting. However, I respectfully request that the Court grant me tie-breaking authority on educational decisions—inc