1035-00002 · Calderwood & Harkness LLP · Client Correspondence

letter-client-final-agreement-court-approval.docx DOCUMENT M&A / Corporate

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CALDERWOOD & HARKNESS LLP Attorneys at Law

777 South Flower Street, Suite 3400 Los Angeles, California 90017 Telephone: (213) 555-7800 Facsimile: (213) 555-7801 www.calderwoodharkness.com

February 9, 2024

VIA EMAIL AND FIRST-CLASS MAIL PRIVILEGED & CONFIDENTIAL — ATTORNEY-CLIENT COMMUNICATION

Marguerite D. Fonseca 1742 Laurel Canyon Boulevard, Unit 3A Studio City, CA 91604

Re: Fonseca Custody & Parenting Plan — Court Approval of Stipulated Agreement Matter No.: 1035-00002 Case No.: 22STFL09847, Superior Court of California, County of Los Angeles

Dear Ms. Fonseca:

1. Purpose of This Letter and Confirmation of Court Approval

We are very pleased to write to you to confirm that, as of today, February 9, 2024, the Superior Court of California, County of Los Angeles, sitting at the Stanley Mosk Courthouse, has approved and entered both the Stipulated Custody & Parenting Plan Agreement and the Child Support Agreement in In re the Marriage of Fonseca and Medrano, Case No. 22STFL09847. This letter summarizes the key terms of the approved agreements and addresses certain important next steps.

As you will recall, the stipulation was executed by both parties on January 31, 2024, and was thereafter filed with the court for judicial review and approval. We are pleased to report that the Honorable Judge Patricia M. Wexler has reviewed the stipulation, found the terms to be in the best interests of the minor children, and signed the proposed order. The court's entry of the order makes all terms of the Stipulated Custody & Parenting Plan Agreement and the Child Support Agreement fully enforceable as a court order, effective immediately.

Enclosed with this letter, you will find conformed copies of the filed Stipulation for Judgment and the court's signed order, as well as execution copies of the underlying agreements and their exhibits. We encourage you to review each of these documents carefully and to retain them in a secure location, as discussed further below.

This marks the successful resolution of the custody and parenting-plan matter without the need for a contested hearing or trial. We recognize how important it was to you to reach a resolution that protected your children's well-being and stability, and we believe this agreement accomplishes that goal admirably.

Finally, please be advised that the court file in this matter remains sealed pursuant to California Rules of Court, Rule 2.550 et seq. This sealing order was entered to protect the privacy of the children and of both parties, and it remains in full force and effect. Third parties may not access the sealed court records absent a further order of the court.

2. Summary of Key Terms — Custody and Timeshare

The following is a summary of the principal custody and timeshare provisions of the Stipulated Custody & Parenting Plan Agreement, as approved by the court. This summary is provided for your convenience and reference; in the event of any discrepancy between this summary and the language of the filed agreements and court order, the filed agreements and court order shall control.

2.1 Legal Custody

The court has ordered joint legal custody of both minor children: Isabela Luz Fonseca-Medrano (date of birth: February 11, 2017, age seven) and Mateo Elías Fonseca-Medrano (date of birth: August 29, 2019, age four). Joint legal custody means that both you and Mr. Medrano share the right and responsibility to make decisions relating to the health, education, and welfare of the children.

As agreed in the stipulation, you hold tie-breaking decision-making authority with respect to educational decisions affecting the children, including but not limited to school enrollment, school transfers, tutoring, and educational assessments. This tie-breaking authority is intended to provide a clear mechanism for resolving educational disagreements that the parties are unable to resolve through discussion or with the assistance of the Parenting Plan Coordinator.

All other major decisions — including those related to the children's healthcare, extracurricular activities, religious upbringing, and general welfare — remain subject to joint decision-making by both parents. Neither parent may make a unilateral decision on any major matter (other than educational decisions, as noted above) without first making a good-faith effort to consult with and obtain the agreement of the other parent. In the event of a disagreement on any such major decision, either party may seek the assistance of the Parenting Plan Coordinator, Dr. Marcus W. Ingalls, or, if necessary, petition the court for resolution.

2.2 Physical Custody and Primary Residence

The court has ordered joint physical custody of both minor children. The children's primary residence is designated as your home located at 1742 Laurel Canyon Boulevard, Unit 3A, Studio City, CA 91604. This designation reflects the existing arrangement and is intended to provide the children with continuity and stability.

The children will continue their enrollment at Ridgeview Academy, located at 4515 Sepulveda Boulevard, Sherman Oaks, CA 91403. As noted above, any decision to change the children's school enrollment is subject to your tie-breaking authority on educational matters, though you remain obligated to consult with Mr. Medrano in good faith before making any such decision.

2.3 Timeshare Allocation

The timeshare schedule set forth in the Parenting Plan establishes the following allocation of custodial time between the parties:

School Year Schedule. During the regular school year, the timeshare is allocated on an approximately 65%/35% basis in your favor. Calculated on an annualized basis, you will receive approximately 232 overnights per year, and Mr. Medrano will receive approximately 133 overnights per year. This yields an effective annual timeshare of approximately 63.6% to you and 36.4% to Mr. Medrano. The specific weekly schedule, including weekday and weekend allocations, transitions, and pickup/drop-off arrangements, is detailed in the Parenting Plan Agreement itself.

Summer Schedule. During the ten-week summer break (approximately 70 days), custodial time is split equally between the parties, with each parent receiving 35 overnights. The specific summer schedule, including the mechanism for selecting summer weeks, is detailed in the Parenting Plan Agreement and is subject to the travel notice requirements discussed below.

Holiday Rotation. The parties have agreed to an alternating even-year/odd-year holiday rotation schedule for Thanksgiving, winter break (including Christmas Eve, Christmas Day, and New Year's Eve/Day), spring break, and each parent's individually designated holidays (including each parent's birthday, Mother's Day, Father's Day, and the children's birthdays). The complete holiday and vacation schedule is set forth in Exhibit A to the Parenting Plan, a copy of which is enclosed with this letter. We encourage you to review Exhibit A carefully and to note the dates for the current 2024 calendar year, as you are in an even-numbered year.

2.4 Travel and On-Location Work Provisions

Given the nature of both parties' professional lives, the Parenting Plan includes specific provisions governing travel with the children and accommodations for on-location work:

International Travel. Any travel with the children outside of the continental United States requires a minimum of thirty (30) days' advance written notice to the non-traveling parent. In addition, such international travel requires the written consent of the other parent, or, in the absence of such consent, a court order authorizing the travel. The notice must include the travel dates, destination, itinerary, accommodations, and emergency contact information.

Domestic Travel Outside California. Any travel with the children outside the State of California but within the continental United States requires a minimum of fourteen (14) days' advance written notice to the non-traveling parent. While written consent is not required for domestic out-of-state travel, the traveling parent must provide the same travel details described above (dates, destination, itinerary, accommodations, and emergency contact information).

On-Location Work Provision. If either parent accepts professional work requiring travel of more than fourteen (14) consecutive calendar days, the custodial time that would otherwise be allocated to the traveling parent during those days shall transfer to the other parent. The traveling parent is entitled to make-up time equivalent to the transferred custodial days, to be scheduled by mutual agreement of the parties within sixty (60) days of the traveling parent's return. If the parties are unable to agree on a make-up schedule, either party may seek the assistance of the Parenting Plan Coordinator.

Right of First Refusal. The Parenting Plan includes a right of first refusal for childcare. When a parent who has custodial time is unavailable to personally care for the children for more than eight (8) consecutive hours (excluding normal school hours and the children's regular sleeping hours), that parent must first offer the other parent the opportunity to care for the children during the period of unavailability before engaging a third-party caretaker. The specific procedures for exercising this right are detailed in Exhibit B to the Parenting Plan, a copy of which is enclosed with this letter.

3. Summary of Key Terms — Child Support

The following is a summary of the child support provisions contained in the Child Support Agreement, as approved and entered by the court.

3.1 Monthly Child Support

Pursuant to the Child Support Agreement, you will pay Mr. Medrano the sum of $1,100.00 per month in child support, payable on the first day of each month, commencing March 1, 2024. This amount represents an agreed deviation of $174.00 per month below the California statutory guideline amount.

For your records, the California guideline child support amount was calculated at $1,274.00 per month using the DissoMaster software, based on the following inputs:

• Your gross monthly income: $72,500.00

• Mr. Medrano's imputed gross monthly income: $28,333.00

• Combined gross monthly income: $100,833.00

• Timeshare allocation: 63.6% (Ms. Fonseca) / 36.4% (Mr. Medrano)

The agreed deviation of $174.00 per month below guideline was approved by the court based on the parties' stipulation that Mr. Medrano will contribute a higher proportional share of the children's extracurricular and enrichment activity costs, as described in Section 3.3 below. The court found that this arrangement, taken as a whole, serves the best interests of the children and that the deviation is consistent with the requirements of California Family Code Section 4065.

3.2 Education Costs — Ridgeview Academy Tuition

The parties have agreed to share the cost of the children's tuition at Ridgeview Academy on a 70% Ms. Fonseca / 30% Mr. Medrano basis. Based on current tuition rates, the cost-sharing is as follows:

Tuition payments are to be made directly to Ridgeview Academy in accordance with the school's billing schedule. Each party is responsible for ensuring that his or her share of tuition is paid on time. In the event that tuition rates increase, the 70/30 cost-sharing ratio remains in effect unless and until modified by agreement of the parties or order of the court.

3.3 Extracurricular and Enrichment Activities

As noted above, the parties have agreed to an allocation of extracurricular and enrichment activity costs that differs from the general 70/30 cost-sharing ratio applied to tuition and healthcare. Specifically, costs for the children's extracurricular and enrichment activities shall be split 60% Mr. Medrano / 40% Ms. Fonseca, up to a maximum of $1,500.00 per child per quarter.

This means that for each child, up to $1,500.00 per calendar quarter may be spent on extracurricular and enrichment activities (such as sports leagues, music lessons, art classes, tutoring, camps, and similar programs) without the need for prior approval from the other parent, so long as the costs are shared on the 60/40 basis described above. Any proposed expenditure that would cause the total quarterly cost for a child to exceed the $1,500.00 cap requires the mutual written consent of both parents before the expense is incurred.

This arrangement reflects the parties' agreement that Mr. Medrano will bear a greater share of extracurricular costs in exchange for the below-guideline child support amount.

3.4 Healthcare. The children shall remain enrolled on your employer-sponsored health insurance plan through Luminos Entertainment Group, Inc. (underwritten by Veridian Health Insurance Co.). You are responsible for maintaining the children's enrollment and for paying any employee-share premiums associated with the children's coverage.

Unreimbursed medical, dental, orthodontic, and mental health expenses — meaning those costs not covered by insurance — shall be shared between the parties on a 70% Ms. Fonseca / 30% Mr. Medrano basis. Each party must provide the other with documentation of any unreimbursed expense within thirty (30) days of incurring the expense, and the non-incurring party's share shall be due within thirty (30) days of receipt of such documentation.

3.5 Annual Review

The child support order is subject to review on each anniversary of the date of the order, or at any time upon a material change in circumstances. For purposes of this agreement, a "material change in circumstances" is defined as:

(a) a change in either party's gross monthly income exceeding fifteen percent (15%), whether an increase or decrease; or

(b) a change in the actual custodial timeshare exceeding ten percent (10%) from the timeshare set forth in the Parenting Plan.

Either party may request a review by providing written notice to the other party. If the parties are unable to agree on a modification, either party may petition the court for a modification of the child support order in accordance with applicable law.

4. Parenting Plan Coordinator

By agreement of the parties, and as reflected in the court's order, Dr. Marcus W. Ingalls, LMFT (License No. LMFT 89412), of Ingalls & Cuevas Family Counseling, located at 10880 Wilshire Boulevard, Suite 630, Los Angeles, CA 90024, has been appointed as the Parenting Plan Coordinator for this matter.

Dr. Ingalls's role is to assist you and Mr. Medrano in resolving day-to-day scheduling disputes and implementation questions that may arise under the Parenting Plan. His role is facilitative in nature: Dr. Ingalls may offer non-binding recommendations to the parties on logistical issues, such as scheduling adjustments, transition logistics, and communication protocols. However, it is important to understand the limitations of this role. The Parenting Plan Coordinator is not a mediator, arbitrator, or judge. Dr. Ingalls's recommendations are non-binding, and his appointment is not a substitute for court intervention with respect to major disputes or requests for modification of the custody or support orders. If a significant dispute arises that cannot be resolved with Dr. Ingalls's assistance, either party retains the right to seek relief from the court.

The costs of the Parenting Plan Coordinator's services shall be shared equally between the parties unless otherwise agreed or ordered. We encourage you to contact Dr. Ingalls's office at (310) 555-2290 to schedule an introductory session at your earliest convenience.

5. Confidentiality and Non-Disparagement

We wish to take this opportunity to remind you of the mutual non-disparagement and confidentiality clause contained in the Stipulated Agreement, which is now an enforceable provision of the court's order.

Pursuant to this clause, neither party shall make disparaging remarks about the other party in the presence of or within the hearing of the children, or to any third parties, including but not limited to family members, friends, colleagues, and members of the media. This obligation extends to statements made in person, in writing, and on social media or other electronic platforms.

In addition, neither party shall disclose the financial terms of the agreement — including the child support amount, the income figures used in the support calculation, or the tuition and cost-sharing arrangements — to any third party, except to the party's legal counsel, tax advisors, or financial professionals engaged for the purpose of complying with the agreement, or as required by court order or applicable law. Similarly, neither party shall disclose the contents of the custody evaluation conducted during the pendency of this matter.

As noted above, the court file in this matter is sealed pursuant to California Rules of Court, Rule 2.550 et seq., and this protection remains in full force and effect. Violation of the confidentiality or non-disparagement provisions may be addressed by the court through its contempt power or other appropriate remedies.

6. Enclosures

Enclosed with this letter, please find the following documents:

1. Conformed copy of the Stipulation for Judgment re Custody, Parenting Plan & Child Support (filed and entered February 9, 2024)

2. Conformed copy of the Court's signed Order (entered February 9, 2024)

3. Execution copy of the Stipulated Custody & Parenting Plan Agreement (dated January 31, 2024)

4. Execution copy of the Child Support Agreement (dated January 31, 2024)

5. Exhibit A — Holiday & Vacation Schedule

6. Exhibit B — Right of First Refusal & Travel Notice Protocol

Please review each of these documents carefully and confirm that the copies you have received are complete. If any document appears to be missing pages or is otherwise incomplete, please contact our office immediately so that we may provide a replacement copy.

7. Next Steps and Administrative Matters

With the court's entry of the order today, the principal legal work in this matter has been concluded. However, there are several administrative matters to which we wish to draw your attention.

Final Accounting of Fees and Costs. Our firm will be sending you a separate matter closing letter, under separate cover, which will include a final accounting of all legal fees billed and costs advanced in connection with this matter. The total fees billed and costs advanced through the conclusion of the matter will be detailed in that letter, along with a final trust account statement reflecting any remaining balance in your client trust account. We anticipate that the closing letter will be sent to you within approximately two to three weeks.

Document Retention. We strongly advise you to retain all of the enclosed documents in a secure location for your permanent records. These documents may be needed for reference in the future — for example, in connection with any request for modification, any tax-related inquiry, or any question regarding the terms of the Parenting Plan. We recommend maintaining both physical and electronic copies in a secure location.

Ongoing Availability. While the matter is now concluded, please do not hesitate to contact our office if any questions arise regarding the implementation of the Parenting Plan or the Child Support Agreement, or if a future modification becomes necessary due to changed circumstances. Our firm remains available to assist you with any family law needs that may arise in the future.

Minor's Counsel. As you are aware, Attorney Tessa L. Brannigan was appointed by the court as Minor's Counsel to represent the interests of Isabela and Mateo during the pendency of this matter. With the court's entry of the order today, Ms. Brannigan's appointment as Minor's Counsel will terminate. Going forward, if disputes arise under the Parenting Plan, those disputes should be directed in the first instance to Dr. Marcus W. Ingalls in his capacity as Parenting Plan Coordinator. If the matter cannot be resolved with Dr. Ingalls's assistance, you may contact our office to discuss further options, including the possibility of seeking court intervention.

8. Closing Remarks

It has been a genuine privilege to represent you throughout this matter. We are gratified that this case was resolved by agreement of the parties, in a manner that we believe serves the best interests of Isabela and Mateo. Reaching a stipulated resolution — rather than proceeding to a contested hearing or trial — has spared the children the stress and uncertainty of protracted litigation and has provided both families with a clear, workable framework for co-parenting going forward.

We wish to thank you sincerely for your cooperation, patience, and trust throughout this process. Your willingness to engage constructively in negotiations, and your consistent focus on the well-being of your children, were instrumental in achieving this outcome.

We wish you and your family all the best, and we look forward to the opportunity to be of service to you again should the need ever arise.

Very truly yours,

CALDERWOOD & HARKNESS LLP

By: ________

Devon Archer Associate

Direct Dial: (213) 555-7824

Email: darcher@calderwoodharkness.com

cc: Priya Anand, Partner, Calderwood & Harkness LLP cc: Oliver Mackenzie, Partner, Calderwood & Harkness LLP

Enclosures (6)

Annual Tuition	Ms. Fonseca (70%)	Mr. Medrano (30%)
Isabela Luz Fonseca-Medrano	$32,400.00	$22,680.00	$9,720.00
Mateo Elías Fonseca-Medrano	$26,800.00	$18,760.00	$8,040.00
Total	$59,200.00	$41,440.00	$17,760.00

CALDERWOOD & HARKNESS LLP Attorneys at Law
777 South Flower Street, Suite 3400 Los Angeles, California 90017 Telephone: (213) 555-7800 Facsimile: (213) 555-7801 www.calderwoodharkness.com
February 9, 2024
VIA EMAIL AND FIRST-CLASS MAIL PRIVILEGED & CONFIDENTIAL — ATTORNEY-CLIENT COMMUNICATION
Marguerite D. Fonseca 1742 Laurel Canyon Boulevard, Unit 3A Studio City, CA 91604
Re: Fonseca Custody & Parenting Plan — Court Approval of Stipulated Agreement Matter No.: 1035-00002 Case No.: 22STFL09847, Superior Court of California, County of Los Angeles
Dear Ms. Fonseca:
1. Purpose of This Letter and Confirmation of Court Approval
We are very pleased to write to you to confirm that, as of today, February 9, 2024, the Superior Court of California, County of Los Angeles, sitting at the Stanley Mosk Courthouse, has approved and entered both the Stipulated Custody & Parenting Plan Agreement and the Child Support Agreement in In re the Marriage of Fonseca and Medrano, Case No. 22STFL09847. This letter summarizes the key terms of the approved agreements and addresses certain important next steps.
As you will recall, the stipulation was executed by both parties on January 31, 2024, and was thereafter filed with the court for judicial review and approval. We are pleased to report that the Honorable Judge Patricia M. Wexler has reviewed the stipulation, found the terms to be in the best interests of the minor children, and signed the proposed order. The court's entry of the order makes all terms of the Stipulated Custody & Parenting Plan Agreement and the Child Support Agreement fully enforceable as a court order, effective immediately.
Enclosed with this letter, you will find conformed copies of the filed Stipulation for Judgment and the court's signed order, as well as execution copies of the underlying agreements and their exhibits. We encourage you to review each of these documents carefully and to retain them in a secure location, as discussed further below.
This marks the successful resolution of the custody and parenting-plan matter without the need for a contested hearing or trial. We recognize how important it was to you to reach a resolution that protected your children's well-being and stability, and we believe this agreement accomplishes that goal admirably.
Finally, please be advised that the court file in this matter remains sealed pursuant to California Rules of Court, Rule 2.550 et seq. This sealing order was entered to protect the privacy of the children and of both parties, and it remains in full force and effect. Third parties may not access the sealed court records absent a further order of the court.
2. Summary of Key Terms — Custody and Timeshare
The following is a summary of the principal custody and timeshare provisions of the Stipulated Custody & Parenting Plan Agreement, as approved by the court. This summary is provided for your convenience and reference; in the event of any discrepancy between this summary and the language of the filed agreements and court order, the filed agreements and court order shall control.
2.1 Legal Custody
The court has ordered joint legal custody of both minor children: Isabela Luz Fonseca-Medrano (date of birth: February 11, 2017, age seven) and Mateo Elías Fonseca-Medrano (date of birth: August 29, 2019, age four). Joint legal custody means that both you and Mr. Medrano share the right and responsibility to make decisions relating to the health, education, and welfare of the children.
As agreed in the stipulation, you hold tie-breaking decision-making authority with respect to educational decisions affecting the children, including but not limited to school enrollment, school transfers, tutoring, and educational assessments. This tie-breaking authority is intended to provide a clear mechanism for resolving educational disagreements that the parties are unable to resolve through discussion or with the assistance of the Parenting Plan Coordinator.
All other major decisions — including those related to the children's healthcare, extracurricular activities, religious upbringing, and general welfare — remain subject to joint decision-making by both parents. Neither parent may make a unilateral decision on any major matter (other than educational decisions, as noted above) without first making a good-faith effort to consult with and obtain the agreement of the other parent. In the event of a disagreement on any such major decision, either party may seek the assistance of the Parenting Plan Coordinator, Dr. Marcus W. Ingalls, or, if necessary, petition the court for resolution.
2.2 Physical Custody and Primary Residence
The court has ordered joint physical custody of both minor children. The children's primary residence is designated as your home located at 1742 Laurel Canyon Boulevard, Unit 3A, Studio City, CA 91604. This designation reflects the existing arrangement and is intended to provide the children with continuity and stability.
The children will continue their enrollment at Ridgeview Academy, located at 4515 Sepulveda Boulevard, Sherman Oaks, CA 91403. As noted above, any decision to change the children's school enrollment is subject to your tie-breaking authority on educational matters, though you remain obligated to consult with Mr. Medrano in good faith before making any such decision.
2.3 Timeshare Allocation
The timeshare schedule set forth in the Parenting Plan establishes the following allocation of custodial time between the parties:
School Year Schedule. During the regular school year, the timeshare is allocated on an approximately 65%/35% basis in your favor. Calculated on an annualized basis, you will receive approximately 232 overnights per year, and Mr. Medrano will receive approximately 133 overnights per year. This yields an effective annual timeshare of approximately 63.6% to you and 36.4% to Mr. Medrano. The specific weekly schedule, including weekday and weekend allocations, transitions, and pickup/drop-off arrangements, is detailed in the Parenting Plan Agreement itself.
Summer Schedule. During the ten-week summer break (approximately 70 days), custodial time is split equally between the parties, with each parent receiving 35 overnights. The specific summer schedule, including the mechanism for selecting summer weeks, is detailed in the Parenting Plan Agreement and is subject to the travel notice requirements discussed below.
Holiday Rotation. The parties have agreed to an alternating even-year/odd-year holiday rotation schedule for Thanksgiving, winter break (including Christmas Eve, Christmas Day, and New Year's Eve/Day), spring break, and each parent's individually designated holidays (including each parent's birthday, Mother's Day, Father's Day, and the children's birthdays). The complete holiday and vacation schedule is set forth in Exhibit A to the Parenting Plan, a copy of which is enclosed with this letter. We encourage you to review Exhibit A carefully and to note the dates for the current 2024 calendar year, as you are in an even-numbered year.
2.4 Travel and On-Location Work Provisions
Given the nature of both parties' professional lives, the Parenting Plan includes specific provisions governing travel with the children and accommodations for on-location work:
International Travel. Any travel with the children outside of the continental United States requires a minimum of thirty (30) days' advance written notice to the non-traveling parent. In addition, such international travel requires the written consent of the other parent, or, in the absence of such consent, a court order authorizing the travel. The notice must include the travel dates, destination, itinerary, accommodations, and emergency contact information.
Domestic Travel Outside California. Any travel with the children outside the State of California but within the continental United States requires a minimum of fourteen (14) days' advance written notice to the non-traveling parent. While written consent is not required for domestic out-of-state travel, the traveling parent must provide the same travel details described above (dates, destination, itinerary, accommodations, and emergency contact information).
On-Location Work Provision. If either parent accepts professional work requiring travel of more than fourteen (14) consecutive calendar days, the custodial time that would otherwise be allocated to the traveling parent during those days shall transfer to the other parent. The traveling parent is entitled to make-up time equivalent to the transferred custodial days, to be scheduled by mutual agreement of the parties within sixty (60) days of the traveling parent's return. If the parties are unable to agree on a make-up schedule, either party may seek the assistance of the Parenting Plan Coordinator.
Right of First Refusal. The Parenting Plan includes a right of first refusal for childcare. When a parent who has custodial time is unavailable to personally care for the children for more than eight (8) consecutive hours (excluding normal school hours and the children's regular sleeping hours), that parent must first offer the other parent the opportunity to care for the children during the period of unavailability before engaging a third-party caretaker. The specific procedures for exercising this right are detailed in Exhibit B to the Parenting Plan, a copy of which is enclosed with this letter.
3. Summary of Key Terms — Child Support
The following is a summary of the child support provisions contained in the Child Support Agreement, as approved and entered by the court.
3.1 Monthly Child Support
Pursuant to the Child Support Agreement, you will pay Mr. Medrano the sum of $1,100.00 per month in child support, payable on the first day of each month, commencing March 1, 2024. This amount represents an agreed deviation of $174.00 per month below the California statutory guideline amount.
For your records, the California guideline child support amount was calculated at $1,274.00 per month using the DissoMaster software, based on the following inputs:
• Your gross monthly income: $72,500.00
• Mr. Medrano's imputed gross monthly income: $28,333.00
• Combined gross monthly income: $100,833.00
• Timeshare allocation: 63.6% (Ms. Fonseca) / 36.4% (Mr. Medrano)
The agreed deviation of $174.00 per month below guideline was approved by the court based on the parties' stipulation that Mr. Medrano will contribute a higher proportional share of the children's extracurricular and enrichment activity costs, as described in Section 3.3 below. The court found that this arrangement, taken as a whole, serves the best interests of the children and that the deviation is consistent with the requirements of California Family Code Section 4065.
3.2 Education Costs — Ridgeview Academy Tuition
The parties have agreed to share the cost of the children's tuition at Ridgeview Academy on a 70% Ms. Fonseca / 30% Mr. Medrano basis. Based on current tuition rates, the cost-sharing is as follows:
Tuition payments are to be made directly to Ridgeview Academy in accordance with the school's billing schedule. Each party is responsible for ensuring that his or her share of tuition is paid on time. In the event that tuition rates increase, the 70/30 cost-sharing ratio remains in effect unless and until modified by agreement of the parties or order of the court.
3.3 Extracurricular and Enrichment Activities
As noted above, the parties have agreed to an allocation of extracurricular and enrichment activity costs that differs from the general 70/30 cost-sharing ratio applied to tuition and healthcare. Specifically, costs for the children's extracurricular and enrichment activities shall be split 60% Mr. Medrano / 40% Ms. Fonseca, up to a maximum of $1,500.00 per child per quarter.
This means that for each child, up to $1,500.00 per calendar quarter may be spent on extracurricular and enrichment activities (such as sports leagues, music lessons, art classes, tutoring, camps, and similar programs) without the need for prior approval from the other parent, so long as the costs are shared on the 60/40 basis described above. Any proposed expenditure that would cause the total quarterly cost for a child to exceed the $1,500.00 cap requires the mutual written consent of both parents before the expense is incurred.
This arrangement reflects the parties' agreement that Mr. Medrano will bear a greater share of extracurricular costs in exchange for the below-guideline child support amount.
3.4 Healthcare. The children shall remain enrolled on your employer-sponsored health insurance plan through Luminos Entertainment Group, Inc. (underwritten by Veridian Health Insurance Co.). You are responsible for maintaining the children's enrollment and for paying any employee-share premiums associated with the children's coverage.
Unreimbursed medical, dental, orthodontic, and mental health expenses — meaning those costs not covered by insurance — shall be shared between the parties on a 70% Ms. Fonseca / 30% Mr. Medrano basis. Each party must provide the other with documentation of any unreimbursed expense within thirty (30) days of incurring the expense, and the non-incurring party's share shall be due within thirty (30) days of receipt of such documentation.
3.5 Annual Review
The child support order is subject to review on each anniversary of the date of the order, or at any time upon a material change in circumstances. For purposes of this agreement, a "material change in circumstances" is defined as:
(a) a change in either party's gross monthly income exceeding fifteen percent (15%), whether an increase or decrease; or
(b) a change in the actual custodial timeshare exceeding ten percent (10%) from the timeshare set forth in the Parenting Plan.
Either party may request a review by providing written notice to the other party. If the parties are unable to agree on a modification, either party may petition the court for a modification of the child support order in accordance with applicable law.
4. Parenting Plan Coordinator
By agreement of the parties, and as reflected in the court's order, Dr. Marcus W. Ingalls, LMFT (License No. LMFT 89412), of Ingalls & Cuevas Family Counseling, located at 10880 Wilshire Boulevard, Suite 630, Los Angeles, CA 90024, has been appointed as the Parenting Plan Coordinator for this matter.
Dr. Ingalls's role is to assist you and Mr. Medrano in resolving day-to-day scheduling disputes and implementation questions that may arise under the Parenting Plan. His role is facilitative in nature: Dr. Ingalls may offer non-binding recommendations to the parties on logistical issues, such as scheduling adjustments, transition logistics, and communication protocols. However, it is important to understand the limitations of this role. The Parenting Plan Coordinator is not a mediator, arbitrator, or judge. Dr. Ingalls's recommendations are non-binding, and his appointment is not a substitute for court intervention with respect to major disputes or requests for modification of the custody or support orders. If a significant dispute arises that cannot be resolved with Dr. Ingalls's assistance, either party retains the right to seek relief from the court.
The costs of the Parenting Plan Coordinator's services shall be shared equally between the parties unless otherwise agreed or ordered. We encourage you to contact Dr. Ingalls's office at (310) 555-2290 to schedule an introductory session at your earliest convenience.
5. Confidentiality and Non-Disparagement
We wish to take this opportunity to remind you of the mutual non-disparagement and confidentiality clause contained in the Stipulated Agreement, which is now an enforceable provision of the court's order.
Pursuant to this clause, neither party shall make disparaging remarks about the other party in the presence of or within the hearing of the children, or to any third parties, including but not limited to family members, friends, colleagues, and members of the media. This obligation extends to statements made in person, in writing, and on social media or other electronic platforms.
In addition, neither party shall disclose the financial terms of the agreement — including the child support amount, the income figures used in the support calculation, or the tuition and cost-sharing arrangements — to any third party, except to the party's legal counsel, tax advisors, or financial professionals engaged for the purpose of complying with the agreement, or as required by court order or applicable law. Similarly, neither party shall disclose the contents of the custody evaluation conducted during the pendency of this matter.
As noted above, the court file in this matter is sealed pursuant to California Rules of Court, Rule 2.550 et seq., and this protection remains in full force and effect. Violation of the confidentiality or non-disparagement provisions may be addressed by the court through its contempt power or other appropriate remedies.
6. Enclosures
Enclosed with this letter, please find the following documents:
1. Conformed copy of the Stipulation for Judgment re Custody, Parenting Plan & Child Support (filed and entered February 9, 2024)
2. Conformed copy of the Court's signed Order (entered February 9, 2024)
3. Execution copy of the Stipulated Custody & Parenting Plan Agreement (dated January 31, 2024)
4. Execution copy of the Child Support Agreement (dated January 31, 2024)
5. Exhibit A — Holiday & Vacation Schedule
6. Exhibit B — Right of First Refusal & Travel Notice Protocol
Please review each of these documents carefully and confirm that the copies you have received are complete. If any document appears to be missing pages or is otherwise incomplete, please contact our office immediately so that we may provide a replacement copy.
7. Next Steps and Administrative Matters
With the court's entry of the order today, the principal legal work in this matter has been concluded. However, there are several administrative matters to which we wish to draw your attention.
Final Accounting of Fees and Costs. Our firm will be sending you a separate matter closing letter, under separate cover, which will include a final accounting of all legal fees billed and costs advanced in connection with this matter. The total fees billed and costs advanced through the conclusion of the matter will be detailed in that letter, along with a final trust account statement reflecting any remaining balance in your client trust account. We anticipate that the closing letter will be sent to you within approximately two to three weeks.
Document Retention. We strongly advise you to retain all of the enclosed documents in a secure location for your permanent records. These documents may be needed for reference in the future — for example, in connection with any request for modification, any tax-related inquiry, or any question regarding the terms of the Parenting Plan. We recommend maintaining both physical and electronic copies in a secure location.
Ongoing Availability. While the matter is now concluded, please do not hesitate to contact our office if any questions arise regarding the implementation of the Parenting Plan or the Child Support Agreement, or if a future modification becomes necessary due to changed circumstances. Our firm remains available to assist you with any family law needs that may arise in the future.
Minor's Counsel. As you are aware, Attorney Tessa L. Brannigan was appointed by the court as Minor's Counsel to represent the interests of Isabela and Mateo during the pendency of this matter. With the court's entry of the order today, Ms. Brannigan's appointment as Minor's Counsel will terminate. Going forward, if disputes arise under the Parenting Plan, those disputes should be directed in the first instance to Dr. Marcus W. Ingalls in his capacity as Parenting Plan Coordinator. If the matter cannot be resolved with Dr. Ingalls's assistance, you may contact our office to discuss further options, including the possibility of seeking court intervention.
8. Closing Remarks
It has been a genuine privilege to represent you throughout this matter. We are gratified that this case was resolved by agreement of the parties, in a manner that we believe serves the best interests of Isabela and Mateo. Reaching a stipulated resolution — rather than proceeding to a contested hearing or trial — has spared the children the stress and uncertainty of protracted litigation and has provided both families with a clear, workable framework for co-parenting going forward.
We wish to thank you sincerely for your cooperation, patience, and trust throughout this process. Your willingness to engage constructively in negotiations, and your consistent focus on the well-being of your children, were instrumental in achieving this outcome.
We wish you and your family all the best, and we look forward to the opportunity to be of service to you again should the need ever arise.
Very truly yours,
CALDERWOOD & HARKNESS LLP
By: ________
Devon Archer Associate
Direct Dial: (213) 555-7824
Email: darcher@calderwoodharkness.com
cc: Priya Anand, Partner, Calderwood & Harkness LLP cc: Oliver Mackenzie, Partner, Calderwood & Harkness LLP
Enclosures (6)
Annual Tuition | Ms. Fonseca (70%) | Mr. Medrano (30%)
Isabela Luz Fonseca-Medrano | $32,400.00 | $22,680.00 | $9,720.00
Mateo Elías Fonseca-Medrano | $26,800.00 | $18,760.00 | $8,040.00
Total | $59,200.00 | $41,440.00 | $17,760.00

CALDERWOOD & HARKNESS LLP Attorneys at Law

CALDERWOOD & HARKNESS LLP

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