Contract analysis

I. Purpose and Background I write on behalf of our client, Marguerite D. Fonseca ("Ms. Fonseca" or "Petitioner"), in connection with the above-referenced custody and parenting-plan dispute with Rafael J. Medrano ("Mr. Medrano" or "Respondent"). As you are aware, Calderwood & Harkness LLP represents Ms. Fonseca in all aspects of the pending proceedings before the Superior Court of California, County of Los Angeles. Yo

II. Procedural History Summary To ensure a complete record for your files, we provide the following summary of the procedural history of this matter: Ms. Fonseca and Mr. Medrano registered their domestic partnership on September 12, 2015, with the California Secretary of State (File No. DP-2015-038741). Following the breakdown of the parties' relationship, Ms. Fonseca filed a Petition for Dissolution of Domestic Part

III. The Minor Children We provide the following background regarding the two minor children for the sake of completeness and to contextualize certain provisions of the proposed parenting plan: Isabela Luz Fonseca-Medrano. Isabela is six years old, born on February 11, 2017. She is currently enrolled in first grade at Ridgeview Academy, a private school located at 4515 Sepulveda Boulevard, Sherman Oaks, California 91

IV. Summary of Proposed Parenting Plan Terms The enclosed draft Proposed Stipulated Custody & Parenting Plan Agreement sets forth the following principal terms. We summarize them here for ease of reference and to invite your focused input on each component. A. Legal Custody Ms. Fonseca proposes that the parties share joint legal custody of both Isabela and Mateo. Both parents would be required to consult in good fait

I. Parenting Plan Coordinator Ms. Fonseca proposes that the parties jointly appoint a Parenting Plan Coordinator to assist in resolving day-to-day scheduling disputes and implementation issues without the need to return to court. We propose 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 900

V. Reference to the Custody Evaluation As noted above, Dr. Sorensen's custody evaluation report was delivered to all counsel of record on October 6, 2023. We have reviewed the report in detail. Without disclosing the specific contents of the evaluation in this correspondence—consistent with the confidentiality protections surrounding the report—we note that the principal terms of the proposed parenting plan are consi

VI. Request for Your Input We respectfully request that you review the enclosed proposed parenting plan and the accompanying Exhibits A and B at your earliest convenience. We would be grateful for your written position on the proposals, including any specific modifications, alternative recommendations, or additional provisions that you believe would better serve the best interests of Isabela and Mateo, in advance of

VII. Availability and Contact I am available to meet in person or to confer by telephone at your earliest convenience to discuss any aspect of the proposed parenting plan or the upcoming mediation. Please do not hesitate to contact me directly at the following: Devon Archer Calderwood & Harkness LLP 777 South Flower Street, Suite 3400 Los Angeles, California 90017 Telephone: (213) 555-7200 Direct Dial: (213) 555-7218

1. Draft Proposed Stipulated Custody & Parenting Plan Agreement

2. Draft Exhibit A — Holiday & Vacation Schedule

3. Draft Exhibit B — Right of First Refusal & Travel Notice Protocol cc: Marguerite D. Fonseca (client) (via email) cc: Priya Anand, Esq., Calderwood & Harkness LLP (via email) Note: This letter and its enclosures are directed solely to Minor's Counsel in her capacity under California Family Code Section 3150 and have not been transmitted to opposing counsel. Child | Annual Tuition | Ms. Fonseca (70%) | Mr. Medrano (