1035-00002 · Calderwood & Harkness LLP · Engagement & Administrative

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MEMORANDUM

PRIVILEGED & CONFIDENTIAL — ATTORNEY WORK PRODUCT

FROM: Devon Archer, Lead Associate, Calderwood & Harkness LLP

TO: Priya Anand, Partner, Calderwood & Harkness LLP

CC: Oliver Mackenzie, Partner, Calderwood & Harkness LLP

DATE: April 14, 2023

RE: Conflict Check Results — Prospective Engagement: Marguerite D. Fonseca, Custody & Parenting Plan Matter

MATTER NO.: 1035-00002 (Proposed)

1. Purpose of Memorandum

This memorandum documents the results of the conflicts clearance process conducted in connection with the prospective engagement of Marguerite Delphine Fonseca as a client of Calderwood & Harkness LLP ("C&H" or the "Firm") in a custody and parenting-plan dispute pending in the Superior Court of California, County of Los Angeles. The purpose of this memorandum is to confirm that the conflict check has been completed in full, to set forth each party and entity run through the Firm's conflicts management system, and to report the results of each search so that the Billing Partner and Responsible Partner may make an informed determination regarding clearance of the proposed engagement.

The prospective matter involves the representation of Ms. Fonseca as petitioner in post-dissolution proceedings concerning custody, visitation, and child support for her two minor children — Isabela Luz Fonseca-Medrano and Mateo Elías Fonseca-Medrano — with her former domestic partner, Rafael Joaquín Medrano. The underlying proceeding is captioned In re Domestic Partnership of Fonseca and Medrano, Case No. 22STFL09847, pending in the Superior Court of California, County of Los Angeles, assigned to the Stanley Mosk Courthouse. The judgment dissolving the domestic partnership of the parties was entered on November 3, 2022. The dissolution judgment expressly reserved jurisdiction over all matters relating to custody, visitation, and child support, and the prospective engagement would address those reserved issues.

This memorandum confirms that the conflict check has been completed in accordance with the Firm's internal policies and the requirements of the California Rules of Professional Conduct, Rules 1.7 and 1.9, and sets forth all parties and entities checked, together with the results. Based on the search results detailed below, no conflicts of interest have been identified, and the proposed engagement is recommended for clearance.

2. Matter Description

The following information describes the prospective matter, the parties involved, and the underlying case. This information was obtained through the intake interview conducted by the undersigned with Ms. Fonseca on April 11, 2023, supplemented by a review of publicly available court records in Case No. 22STFL09847 accessed via the Los Angeles Superior Court's online case information portal.

Prospective Client:

Marguerite Delphine Fonseca Date of Birth: June 14, 1984 Residence: 1742 Laurel Canyon Boulevard, Unit 3A, Studio City, CA 91604 Occupation: Senior Vice President, Original Content Development, Luminos Entertainment Group, Inc.

Ms. Fonseca is a senior entertainment executive who has been employed by Luminos Entertainment Group, Inc. for approximately six years. In her capacity as SVP of Original Content Development, she oversees the development and production of original series programming for the Luminos streaming platform. Her compensation and benefits are expected to be relevant to the income determination component of any custody and support analysis.

Adverse Party / Respondent:

Rafael Joaquín Medrano Date of Birth: March 22, 1982 Residence: 609 Moorpark Street, Apt. 12, North Hollywood, CA 91602 Occupation: Freelance Cinematographer / Director of Photography Business Entity: Medrano Visuals, LLC (California Limited Liability Company)

Mr. Medrano is a freelance cinematographer and director of photography who operates his business through a loan-out entity, Medrano Visuals, LLC, a California limited liability company. He is the respondent in the underlying dissolution proceedings and is anticipated to be the respondent in the post-dissolution custody and parenting-plan matter that forms the basis of the prospective engagement.

Minor Children:

Isabela Luz Fonseca-Medrano, Date of Birth: February 11, 2017 (age 6) Mateo Elías Fonseca-Medrano, Date of Birth: August 29, 2019 (age 3)

Both minor children currently reside primarily with Ms. Fonseca at her Studio City residence and attend Ridgeview Academy, a private school located in Sherman Oaks, California. The children are covered under employer-sponsored health insurance through Ms. Fonseca's employment at Luminos Entertainment Group, with coverage provided by Veridian Health Insurance Co.

Nature of Matter:

Post-dissolution custody, visitation, and child support dispute; Family Law; State of California. The matter is expected to involve the establishment of a formal custody arrangement (legal and physical), a detailed parenting plan addressing timeshare schedules and decision-making authority, and the determination of guideline and above-guideline child support, including allocation of private school tuition, extracurricular activity costs, and health insurance premiums.

Underlying Case:

Case No. 22STFL09847 Superior Court of California, County of Los Angeles (Stanley Mosk Courthouse) In re Domestic Partnership of Fonseca and Medrano Domestic Partnership Registration: September 12, 2015, California Secretary of State File No. DP-2015-038741 Dissolution Petition Filed: July 8, 2022 Judgment of Dissolution Entered: November 3, 2022 Jurisdiction Reserved: Custody, visitation, and child support

Opposing Counsel (Anticipated):

Gwendolyn R. Kwan (CA State Bar No. 218453), Partner Benjamin T. Okafor (CA State Bar No. 312776), Associate Kwan, Delacroix & Samuels LLP 4400 Riverside Drive, Suite 700 Burbank, CA 91505

Based on information provided by Ms. Fonseca during the intake interview, Mr. Medrano was represented by Kwan, Delacroix & Samuels LLP ("KD&S") during the dissolution proceedings and is anticipated to continue that representation in the post-dissolution custody matter. Ms. Fonseca indicated that she received informal correspondence from Ms. Kwan's office in March 2023 relating to proposed modifications to the interim visitation schedule, which confirms that KD&S remains counsel of record for Mr. Medrano in the underlying case.

3. Proposed Engagement Team

The following attorneys have been identified as the proposed engagement team for the Fonseca matter. Each member of the proposed team was separately cleared during the conflicts check process, including individual queries regarding personal or professional relationships with any parties or entities identified in connection with this matter.

Each member of the engagement team confirmed, through individual inquiry conducted on April 13, 2023, that he or she has no personal, familial, financial, or prior professional relationship with any of the parties, entities, or counsel identified in Section 4 below. No member of the team has any prior involvement with the underlying dissolution proceeding or any related matter.

4. Parties and Entities Searched

The following section identifies each party and entity run through the Firm's internal conflicts management database (IntaCheck v.7.2), together with the full legal name, any known aliases or alternate name forms, short names, entity type (where applicable), and the role of each party or entity in the prospective matter. The result of each search is reported individually.

All searches were conducted on April 13–14, 2023, in accordance with the methodology described in Section 5 below.

4.1 Marguerite Delphine Fonseca (Prospective Client)

Full Legal Name: Marguerite Delphine Fonseca

Names/Variants Searched: Marguerite Delphine Fonseca; Marguerite D. Fonseca; M. Fonseca; Marguerite Fonseca

Role: Petitioner / Prospective Client

Residence: 1742 Laurel Canyon Boulevard, Unit 3A, Studio City, CA 91604

Employer: Luminos Entertainment Group, Inc.

Search Result: No current or prior representation of Ms. Fonseca by Calderwood & Harkness LLP was identified in the Firm's conflicts database. No matters in which Ms. Fonseca appears as an adverse party, related party, or witness were identified. No existing client relationship of any kind exists between the Firm and Ms. Fonseca.

Determination: CLEAR — No conflict identified.

4.2 Rafael Joaquín Medrano (Adverse Party)

Full Legal Name: Rafael Joaquín Medrano

Names/Variants Searched: Rafael Joaquín Medrano; Rafael J. Medrano; R. Medrano; Rafael Medrano

Role: Respondent / Adverse Party

Residence: 609 Moorpark Street, Apt. 12, North Hollywood, CA 91602

Search Result: No current or prior representation of Mr. Medrano by Calderwood & Harkness LLP was identified. No existing client relationship, whether active or historical, exists between the Firm and Mr. Medrano. No matters were identified in which Mr. Medrano appears as a client, adverse party, related party, or witness in any engagement of the Firm.

Determination: CLEAR — No conflict identified.

4.3 Medrano Visuals, LLC (Adverse Party Affiliate)

Full Legal Name: Medrano Visuals, LLC

Entity Type: California Limited Liability Company

Role: Mr. Medrano's loan-out entity through which he conducts his freelance cinematography and director-of-photography business. This entity is relevant to the income determination analysis, as Mr. Medrano's professional income flows through this entity.

Names/Variants Searched: Medrano Visuals, LLC; Medrano Visuals LLC; Medrano Visuals

Search Result: No current or prior representation of Medrano Visuals, LLC by Calderwood & Harkness LLP was identified. No existing client or business relationship of any kind exists between the Firm and this entity. The entity does not appear in the Firm's conflicts database as a client, adverse party, or related entity in any matter.

Determination: CLEAR — No conflict identified.

4.4 Luminos Entertainment Group, Inc. (Prospective Client's Employer)

Full Legal Name: Luminos Entertainment Group, Inc.

Entity Type: Delaware corporation; principal offices at 3200 West Olive Avenue, Burbank, CA 91505

Role: Employer of the prospective client, Ms. Fonseca. Luminos Entertainment Group is a mid-major streaming and production company. Ms. Fonseca's compensation, benefits, and stock-based incentive arrangements through Luminos are relevant to the income determination component of the child support analysis. Luminos itself is not a party to the underlying custody or dissolution proceedings.

Names/Variants Searched: Luminos Entertainment Group, Inc.; Luminos Entertainment Group; Luminos Entertainment; Luminos

Search Result: No current representation of Luminos Entertainment Group, Inc. in any matter was identified. No prior representation of Luminos was identified. No matters in which Luminos appears as an adverse party were identified. The Firm has no existing client, business, or advisory relationship with Luminos Entertainment Group or any of its known subsidiaries or affiliates. Although Ms. Fonseca's employment at Luminos is relevant to the income analysis in the custody matter, Luminos itself is not a party to the proceedings, and no conflict arises from this relationship.

Determination: CLEAR — No conflict identified.

4.5 Kwan, Delacroix & Samuels LLP (Opposing Counsel — Firm)

Full Legal Name: Kwan, Delacroix & Samuels LLP

Entity Type: California Limited Liability Partnership

Address: 4400 Riverside Drive, Suite 700, Burbank, CA 91505

Role: Law firm representing the respondent, Rafael J. Medrano, in the underlying dissolution proceeding and anticipated to continue representing Mr. Medrano in the post-dissolution custody and parenting-plan matter.

Names/Variants Searched: Kwan, Delacroix & Samuels LLP; Kwan Delacroix & Samuels LLP; Kwan Delacroix Samuels; KD&S; Kwan Delacroix

Search Result: No current matters were identified in which Calderwood & Harkness LLP and Kwan, Delacroix & Samuels LLP serve as co-counsel. No matters were identified in which the two firms are adverse to one another. No institutional conflict, referral arrangement, fee-sharing agreement, or other professional relationship between the two firms was identified. The Firm has no pending or historical matter involving KD&S as a party, client, or adverse entity.

Determination: CLEAR — No institutional conflict identified.

4.6 Gwendolyn R. Kwan (Opposing Lead Counsel — Individual)

Full Legal Name: Gwendolyn R. Kwan

California State Bar No.: 218453

Role: Partner at Kwan, Delacroix & Samuels LLP; lead counsel for respondent Rafael J. Medrano

Names/Variants Searched: Gwendolyn R. Kwan; Gwendolyn Kwan; G. Kwan

Search Result: No prior professional relationship between any attorney at Calderwood & Harkness LLP and Ms. Kwan was identified. Ms. Kwan does not appear in the Firm's conflicts database as a client, adverse party, co-counsel, or related individual in any matter. No engagement team member reported any personal or professional relationship with Ms. Kwan.

Determination: CLEAR — No conflict identified.

4.7 Benjamin T. Okafor (Opposing Associate Counsel — Individual)

Full Legal Name: Benjamin T. Okafor

California State Bar No.: 312776

Role: Associate at Kwan, Delacroix & Samuels LLP; counsel for respondent Rafael J. Medrano

Names/Variants Searched: Benjamin T. Okafor; Benjamin Okafor; B. Okafor

Search Result: No prior professional relationship between any attorney at Calderwood & Harkness LLP and Mr. Okafor was identified. Mr. Okafor does not appear in the Firm's conflicts database as a client, adverse party, co-counsel, or related individual in any matter. No engagement team member reported any personal or professional relationship with Mr. Okafor.

Determination: CLEAR — No conflict identified.

4.8 Isabela Luz Fonseca-Medrano (Minor Child)

Full Legal Name: Isabela Luz Fonseca-Medrano

Date of Birth: February 11, 2017

Role: Minor child; subject of the custody proceedings

Names/Variants Searched: Isabela Luz Fonseca-Medrano; Isabela Fonseca-Medrano; I. Fonseca-Medrano

Search Result: No results returned. As a minor child of six years of age, no appearance in the Firm's conflicts database was expected. No conflict identified.

Determination: CLEAR.

4.9 Mateo Elías Fonseca-Medrano (Minor Child)

Full Legal Name: Mateo Elías Fonseca-Medrano

Date of Birth: August 29, 2019

Role: Minor child; subject of the custody proceedings

Names/Variants Searched: Mateo Elías Fonseca-Medrano; Mateo Fonseca-Medrano; M. Fonseca-Medrano

Search Result: No results returned. As a minor child of three years of age, no appearance in the Firm's conflicts database was expected. No conflict identified.

Determination: CLEAR.

4.10 Ridgeview Academy (Children's School)

Full Legal Name: Ridgeview Academy

Entity Type: Private school (nonprofit educational institution)

Address: 4515 Sepulveda Boulevard, Sherman Oaks, CA 91403

Role: School attended by both minor children. Tuition and education-related costs at Ridgeview Academy are expected to be a component of any child support arrangement and may be at issue in the proceedings, particularly with respect to the allocation of private school tuition as an above-guideline expense.

Names/Variants Searched: Ridgeview Academy; Ridgeview Academy Sherman Oaks

Search Result: No current or prior representation of Ridgeview Academy by Calderwood & Harkness LLP was identified. No matters in which Ridgeview Academy appears as a party, adverse party, or related entity were identified. No conflict exists.

Determination: CLEAR — No conflict identified.

4.11 Veridian Health Insurance Co. (Health Insurer)

Full Legal Name: Veridian Health Insurance Co.

Entity Type: Insurance company (California-domiciled)

Role: Provides employer-sponsored health insurance coverage for the minor children through Ms. Fonseca's employment at Luminos Entertainment Group, Inc. The allocation of health insurance premiums and coverage responsibility may be a component of the child support determination.

Names/Variants Searched: Veridian Health Insurance Co.; Veridian Health Insurance; Veridian Health; Veridian Insurance

Search Result: No current or prior representation of Veridian Health Insurance Co. by Calderwood & Harkness LLP was identified. No matters in which Veridian appears as a client, adverse party, or related entity were identified. No adverse matters against Veridian were found.

Determination: CLEAR — No conflict identified.

5. Search Methodology

The conflict check searches described in this memorandum were conducted on April 13–14, 2023, using the Firm's internal conflicts management database system (IntaCheck v.7.2). The following methodology was employed:

1. Full Legal Name Searches. Each individual and entity identified in Section 4 was searched by full legal name, including middle names and suffixes where known.

2. Alias and Variant Searches. In addition to full legal name searches, each individual and entity was searched using common abbreviations, short names, known aliases, and reasonable variant spellings. Specific name variants searched for each party are documented in Section 4 above.

3. Cross-Reference Against All Active and Closed Matters. All searches were cross-referenced against the Firm's complete database of active matters, closed matters, and archived matters, including client lists, adverse-party lists, related-party lists, and witness lists maintained in IntaCheck.

4. Entity Affiliation Searches. For individuals identified as associated with corporate or organizational entities (e.g., Ms. Fonseca's employment at Luminos Entertainment Group; Mr. Medrano's ownership of Medrano Visuals, LLC), the affiliated entities were separately searched as described in Sections 4.3 and 4.4 above.

5. Opposing Counsel Searches. The opposing law firm and its identified attorneys were searched individually to identify any prior co-counsel relationships, adverse relationships, or other institutional conflicts.

6. Engagement Team Queries. All four members of the proposed engagement team — Oliver Mackenzie (Partner), Priya Anand (Partner), Devon Archer (Lead Associate), and Nadia Petrov (Working Associate) — were individually queried via email on April 13, 2023, regarding any personal, familial, financial, or prior professional relationships with any of the parties, entities, or counsel identified in Section 4. All four team members responded in the negative. No issues were reported by any member of the proposed engagement team.

7. Supplemental Public Records Review. The undersigned conducted a supplemental review of the California Secretary of State's business entity records to confirm the current status and formation details of Medrano Visuals, LLC and to verify the registration information for the domestic partnership (File No. DP-2015-038741). The Los Angeles Superior Court online case portal was reviewed to confirm the case number, filing dates, and status of Case No. 22STFL09847.

The searches were conducted by Devon Archer, Lead Associate, and reviewed by Priya Anand, Partner, in accordance with the Firm's Conflicts Clearance Policy (C&H Policy No. GM-2019-007, as amended January 2022).

6. Conclusion and Clearance

Based on the comprehensive conflicts clearance process described in this memorandum, the following conclusions are reached:

1. No conflicts of interest have been identified in connection with the prospective representation of Marguerite D. Fonseca in the custody and parenting-plan matter against Rafael J. Medrano, Case No. 22STFL09847, Superior Court of California, County of Los Angeles.

2. No current or former client of Calderwood & Harkness LLP is adverse to the prospective client, and no current or former client would be materially affected by the Firm's acceptance of the proposed engagement. The representation does not present a conflict under California Rules of Professional Conduct, Rule 1.7 (Conflict of Interest: Current Clients) or Rule 1.9 (Duties to Former Clients).

3. No member of the proposed engagement team has any personal, familial, financial, or prior professional relationship with any party, entity, or counsel identified in connection with the proposed matter.

4. The matter is cleared for engagement. It is recommended that the Firm proceed with the preparation and execution of the engagement letter, which is anticipated to be executed on or about April 18, 2023. The initial retainer deposit is expected to be $50,000.00, to be deposited into the Firm's Client Trust Account upon execution of the engagement letter, in accordance with the Firm's standard billing and retainer policies for family law matters.

5. Ongoing monitoring. As with all active matters, the parties and entities identified in this memorandum will remain in the Firm's IntaCheck database for ongoing conflict monitoring. Should any new parties, entities, or counsel become involved in the matter, supplemental conflict checks will be conducted promptly and documented in an addendum to this memorandum.

7. Approval

The undersigned requests approval from the Billing Partner and Responsible Partner to proceed with the engagement of Marguerite D. Fonseca in the matter described herein. Upon execution of both approvals below, the matter will be opened under Matter No. 1035-00002, and the engagement letter will be transmitted to the prospective client for execution.

BILLING PARTNER APPROVAL

Conflicts clearance approved — proceed with engagement.

Signature: ________

Name: Priya Anand

Title: Partner, Calderwood & Harkness LLP

Date: ________

RESPONSIBLE PARTNER APPROVAL

Conflicts clearance approved — proceed with engagement.

Signature: ________

Name: Oliver Mackenzie

Title: Partner, Calderwood & Harkness LLP

Date: ________

PREPARED BY

Signature: ________

Name: Devon Archer

Title: Lead Associate, Calderwood & Harkness LLP

Date: April 14, 2023

8. Distribution

This memorandum is designated PRIVILEGED & CONFIDENTIAL — ATTORNEY WORK PRODUCT and is prepared in connection with the Firm's internal conflicts clearance process. Distribution is limited to the following:

1. Matter File. The original of this memorandum shall be retained in the matter file for Matter No. 1035-00002 (Proposed), to be maintained in the Firm's document management system in accordance with the Firm's records retention policies.

2. Conflicts Department. A copy of this memorandum shall be filed with the Firm's General Counsel and Conflicts Department for retention in the central conflicts clearance archive.

3. Addressees. Copies have been transmitted to Priya Anand (Billing Partner) and Oliver Mackenzie (Responsible Partner) via the Firm's secure internal document delivery system.

This memorandum shall not be disclosed to any person or entity outside Calderwood & Harkness LLP without the prior written authorization of the Billing Partner or the Firm's General Counsel. The contents of this memorandum are protected by the attorney work product doctrine and the attorney-client privilege, and no waiver of any applicable privilege or protection is intended by the internal distribution described above.

CALDERWOOD & HARKNESS LLP — PRIVILEGED & CONFIDENTIAL — ATTORNEY WORK PRODUCT Conflict Check Memorandum — Matter No. 1035-00002 (Proposed) — Marguerite D. Fonseca Prepared by Devon Archer, Lead Associate — April 14, 2023

Role	Attorney	Clearance Status
Responsible Partner	Oliver Mackenzie	Cleared — No conflicts identified
Billing Partner	Priya Anand	Cleared — No conflicts identified
Lead Associate	Devon Archer	Cleared — No conflicts identified
Working Associate	Nadia Petrov	Cleared — No conflicts identified

MEMORANDUM
PRIVILEGED & CONFIDENTIAL — ATTORNEY WORK PRODUCT
FROM: Devon Archer, Lead Associate, Calderwood & Harkness LLP
TO: Priya Anand, Partner, Calderwood & Harkness LLP
CC: Oliver Mackenzie, Partner, Calderwood & Harkness LLP
DATE: April 14, 2023
RE: Conflict Check Results — Prospective Engagement: Marguerite D. Fonseca, Custody & Parenting Plan Matter
MATTER NO.: 1035-00002 (Proposed)
1. Purpose of Memorandum
This memorandum documents the results of the conflicts clearance process conducted in connection with the prospective engagement of Marguerite Delphine Fonseca as a client of Calderwood & Harkness LLP ("C&H" or the "Firm") in a custody and parenting-plan dispute pending in the Superior Court of California, County of Los Angeles. The purpose of this memorandum is to confirm that the conflict check has been completed in full, to set forth each party and entity run through the Firm's conflicts management system, and to report the results of each search so that the Billing Partner and Responsible Partner may make an informed determination regarding clearance of the proposed engagement.
The prospective matter involves the representation of Ms. Fonseca as petitioner in post-dissolution proceedings concerning custody, visitation, and child support for her two minor children — Isabela Luz Fonseca-Medrano and Mateo Elías Fonseca-Medrano — with her former domestic partner, Rafael Joaquín Medrano. The underlying proceeding is captioned In re Domestic Partnership of Fonseca and Medrano, Case No. 22STFL09847, pending in the Superior Court of California, County of Los Angeles, assigned to the Stanley Mosk Courthouse. The judgment dissolving the domestic partnership of the parties was entered on November 3, 2022. The dissolution judgment expressly reserved jurisdiction over all matters relating to custody, visitation, and child support, and the prospective engagement would address those reserved issues.
This memorandum confirms that the conflict check has been completed in accordance with the Firm's internal policies and the requirements of the California Rules of Professional Conduct, Rules 1.7 and 1.9, and sets forth all parties and entities checked, together with the results. Based on the search results detailed below, no conflicts of interest have been identified, and the proposed engagement is recommended for clearance.
2. Matter Description
The following information describes the prospective matter, the parties involved, and the underlying case. This information was obtained through the intake interview conducted by the undersigned with Ms. Fonseca on April 11, 2023, supplemented by a review of publicly available court records in Case No. 22STFL09847 accessed via the Los Angeles Superior Court's online case information portal.
Prospective Client:
Marguerite Delphine Fonseca Date of Birth: June 14, 1984 Residence: 1742 Laurel Canyon Boulevard, Unit 3A, Studio City, CA 91604 Occupation: Senior Vice President, Original Content Development, Luminos Entertainment Group, Inc.
Ms. Fonseca is a senior entertainment executive who has been employed by Luminos Entertainment Group, Inc. for approximately six years. In her capacity as SVP of Original Content Development, she oversees the development and production of original series programming for the Luminos streaming platform. Her compensation and benefits are expected to be relevant to the income determination component of any custody and support analysis.
Adverse Party / Respondent:
Rafael Joaquín Medrano Date of Birth: March 22, 1982 Residence: 609 Moorpark Street, Apt. 12, North Hollywood, CA 91602 Occupation: Freelance Cinematographer / Director of Photography Business Entity: Medrano Visuals, LLC (California Limited Liability Company)
Mr. Medrano is a freelance cinematographer and director of photography who operates his business through a loan-out entity, Medrano Visuals, LLC, a California limited liability company. He is the respondent in the underlying dissolution proceedings and is anticipated to be the respondent in the post-dissolution custody and parenting-plan matter that forms the basis of the prospective engagement.
Minor Children:
Isabela Luz Fonseca-Medrano, Date of Birth: February 11, 2017 (age 6) Mateo Elías Fonseca-Medrano, Date of Birth: August 29, 2019 (age 3)
Both minor children currently reside primarily with Ms. Fonseca at her Studio City residence and attend Ridgeview Academy, a private school located in Sherman Oaks, California. The children are covered under employer-sponsored health insurance through Ms. Fonseca's employment at Luminos Entertainment Group, with coverage provided by Veridian Health Insurance Co.
Nature of Matter:
Post-dissolution custody, visitation, and child support dispute; Family Law; State of California. The matter is expected to involve the establishment of a formal custody arrangement (legal and physical), a detailed parenting plan addressing timeshare schedules and decision-making authority, and the determination of guideline and above-guideline child support, including allocation of private school tuition, extracurricular activity costs, and health insurance premiums.
Underlying Case:
Case No. 22STFL09847 Superior Court of California, County of Los Angeles (Stanley Mosk Courthouse) In re Domestic Partnership of Fonseca and Medrano Domestic Partnership Registration: September 12, 2015, California Secretary of State File No. DP-2015-038741 Dissolution Petition Filed: July 8, 2022 Judgment of Dissolution Entered: November 3, 2022 Jurisdiction Reserved: Custody, visitation, and child support
Opposing Counsel (Anticipated):
Gwendolyn R. Kwan (CA State Bar No. 218453), Partner Benjamin T. Okafor (CA State Bar No. 312776), Associate Kwan, Delacroix & Samuels LLP 4400 Riverside Drive, Suite 700 Burbank, CA 91505
Based on information provided by Ms. Fonseca during the intake interview, Mr. Medrano was represented by Kwan, Delacroix & Samuels LLP ("KD&S") during the dissolution proceedings and is anticipated to continue that representation in the post-dissolution custody matter. Ms. Fonseca indicated that she received informal correspondence from Ms. Kwan's office in March 2023 relating to proposed modifications to the interim visitation schedule, which confirms that KD&S remains counsel of record for Mr. Medrano in the underlying case.
3. Proposed Engagement Team
The following attorneys have been identified as the proposed engagement team for the Fonseca matter. Each member of the proposed team was separately cleared during the conflicts check process, including individual queries regarding personal or professional relationships with any parties or entities identified in connection with this matter.
Each member of the engagement team confirmed, through individual inquiry conducted on April 13, 2023, that he or she has no personal, familial, financial, or prior professional relationship with any of the parties, entities, or counsel identified in Section 4 below. No member of the team has any prior involvement with the underlying dissolution proceeding or any related matter.
4. Parties and Entities Searched
The following section identifies each party and entity run through the Firm's internal conflicts management database (IntaCheck v.7.2), together with the full legal name, any known aliases or alternate name forms, short names, entity type (where applicable), and the role of each party or entity in the prospective matter. The result of each search is reported individually.
All searches were conducted on April 13–14, 2023, in accordance with the methodology described in Section 5 below.
4.1 Marguerite Delphine Fonseca (Prospective Client)
Full Legal Name: Marguerite Delphine Fonseca
Names/Variants Searched: Marguerite Delphine Fonseca; Marguerite D. Fonseca; M. Fonseca; Marguerite Fonseca
Role: Petitioner / Prospective Client
Residence: 1742 Laurel Canyon Boulevard, Unit 3A, Studio City, CA 91604
Employer: Luminos Entertainment Group, Inc.
Search Result: No current or prior representation of Ms. Fonseca by Calderwood & Harkness LLP was identified in the Firm's conflicts database. No matters in which Ms. Fonseca appears as an adverse party, related party, or witness were identified. No existing client relationship of any kind exists between the Firm and Ms. Fonseca.
Determination: CLEAR — No conflict identified.
4.2 Rafael Joaquín Medrano (Adverse Party)
Full Legal Name: Rafael Joaquín Medrano
Names/Variants Searched: Rafael Joaquín Medrano; Rafael J. Medrano; R. Medrano; Rafael Medrano
Role: Respondent / Adverse Party
Residence: 609 Moorpark Street, Apt. 12, North Hollywood, CA 91602
Search Result: No current or prior representation of Mr. Medrano by Calderwood & Harkness LLP was identified. No existing client relationship, whether active or historical, exists between the Firm and Mr. Medrano. No matters were identified in which Mr. Medrano appears as a client, adverse party, related party, or witness in any engagement of the Firm.
Determination: CLEAR — No conflict identified.
4.3 Medrano Visuals, LLC (Adverse Party Affiliate)
Full Legal Name: Medrano Visuals, LLC
Entity Type: California Limited Liability Company
Role: Mr. Medrano's loan-out entity through which he conducts his freelance cinematography and director-of-photography business. This entity is relevant to the income determination analysis, as Mr. Medrano's professional income flows through this entity.
Names/Variants Searched: Medrano Visuals, LLC; Medrano Visuals LLC; Medrano Visuals
Search Result: No current or prior representation of Medrano Visuals, LLC by Calderwood & Harkness LLP was identified. No existing client or business relationship of any kind exists between the Firm and this entity. The entity does not appear in the Firm's conflicts database as a client, adverse party, or related entity in any matter.
Determination: CLEAR — No conflict identified.
4.4 Luminos Entertainment Group, Inc. (Prospective Client's Employer)
Full Legal Name: Luminos Entertainment Group, Inc.
Entity Type: Delaware corporation; principal offices at 3200 West Olive Avenue, Burbank, CA 91505
Role: Employer of the prospective client, Ms. Fonseca. Luminos Entertainment Group is a mid-major streaming and production company. Ms. Fonseca's compensation, benefits, and stock-based incentive arrangements through Luminos are relevant to the income determination component of the child support analysis. Luminos itself is not a party to the underlying custody or dissolution proceedings.
Names/Variants Searched: Luminos Entertainment Group, Inc.; Luminos Entertainment Group; Luminos Entertainment; Luminos
Search Result: No current representation of Luminos Entertainment Group, Inc. in any matter was identified. No prior representation of Luminos was identified. No matters in which Luminos appears as an adverse party were identified. The Firm has no existing client, business, or advisory relationship with Luminos Entertainment Group or any of its known subsidiaries or affiliates. Although Ms. Fonseca's employment at Luminos is relevant to the income analysis in the custody matter, Luminos itself is not a party to the proceedings, and no conflict arises from this relationship.
Determination: CLEAR — No conflict identified.
4.5 Kwan, Delacroix & Samuels LLP (Opposing Counsel — Firm)
Full Legal Name: Kwan, Delacroix & Samuels LLP
Entity Type: California Limited Liability Partnership
Address: 4400 Riverside Drive, Suite 700, Burbank, CA 91505
Role: Law firm representing the respondent, Rafael J. Medrano, in the underlying dissolution proceeding and anticipated to continue representing Mr. Medrano in the post-dissolution custody and parenting-plan matter.
Names/Variants Searched: Kwan, Delacroix & Samuels LLP; Kwan Delacroix & Samuels LLP; Kwan Delacroix Samuels; KD&S; Kwan Delacroix
Search Result: No current matters were identified in which Calderwood & Harkness LLP and Kwan, Delacroix & Samuels LLP serve as co-counsel. No matters were identified in which the two firms are adverse to one another. No institutional conflict, referral arrangement, fee-sharing agreement, or other professional relationship between the two firms was identified. The Firm has no pending or historical matter involving KD&S as a party, client, or adverse entity.
Determination: CLEAR — No institutional conflict identified.
4.6 Gwendolyn R. Kwan (Opposing Lead Counsel — Individual)
Full Legal Name: Gwendolyn R. Kwan
California State Bar No.: 218453
Role: Partner at Kwan, Delacroix & Samuels LLP; lead counsel for respondent Rafael J. Medrano
Names/Variants Searched: Gwendolyn R. Kwan; Gwendolyn Kwan; G. Kwan
Search Result: No prior professional relationship between any attorney at Calderwood & Harkness LLP and Ms. Kwan was identified. Ms. Kwan does not appear in the Firm's conflicts database as a client, adverse party, co-counsel, or related individual in any matter. No engagement team member reported any personal or professional relationship with Ms. Kwan.
Determination: CLEAR — No conflict identified.
4.7 Benjamin T. Okafor (Opposing Associate Counsel — Individual)
Full Legal Name: Benjamin T. Okafor
California State Bar No.: 312776
Role: Associate at Kwan, Delacroix & Samuels LLP; counsel for respondent Rafael J. Medrano
Names/Variants Searched: Benjamin T. Okafor; Benjamin Okafor; B. Okafor
Search Result: No prior professional relationship between any attorney at Calderwood & Harkness LLP and Mr. Okafor was identified. Mr. Okafor does not appear in the Firm's conflicts database as a client, adverse party, co-counsel, or related individual in any matter. No engagement team member reported any personal or professional relationship with Mr. Okafor.
Determination: CLEAR — No conflict identified.
4.8 Isabela Luz Fonseca-Medrano (Minor Child)
Full Legal Name: Isabela Luz Fonseca-Medrano
Date of Birth: February 11, 2017
Role: Minor child; subject of the custody proceedings
Names/Variants Searched: Isabela Luz Fonseca-Medrano; Isabela Fonseca-Medrano; I. Fonseca-Medrano
Search Result: No results returned. As a minor child of six years of age, no appearance in the Firm's conflicts database was expected. No conflict identified.
Determination: CLEAR.
4.9 Mateo Elías Fonseca-Medrano (Minor Child)
Full Legal Name: Mateo Elías Fonseca-Medrano
Date of Birth: August 29, 2019
Role: Minor child; subject of the custody proceedings
Names/Variants Searched: Mateo Elías Fonseca-Medrano; Mateo Fonseca-Medrano; M. Fonseca-Medrano
Search Result: No results returned. As a minor child of three years of age, no appearance in the Firm's conflicts database was expected. No conflict identified.
Determination: CLEAR.
4.10 Ridgeview Academy (Children's School)
Full Legal Name: Ridgeview Academy
Entity Type: Private school (nonprofit educational institution)
Address: 4515 Sepulveda Boulevard, Sherman Oaks, CA 91403
Role: School attended by both minor children. Tuition and education-related costs at Ridgeview Academy are expected to be a component of any child support arrangement and may be at issue in the proceedings, particularly with respect to the allocation of private school tuition as an above-guideline expense.
Names/Variants Searched: Ridgeview Academy; Ridgeview Academy Sherman Oaks
Search Result: No current or prior representation of Ridgeview Academy by Calderwood & Harkness LLP was identified. No matters in which Ridgeview Academy appears as a party, adverse party, or related entity were identified. No conflict exists.
Determination: CLEAR — No conflict identified.
4.11 Veridian Health Insurance Co. (Health Insurer)
Full Legal Name: Veridian Health Insurance Co.
Entity Type: Insurance company (California-domiciled)
Role: Provides employer-sponsored health insurance coverage for the minor children through Ms. Fonseca's employment at Luminos Entertainment Group, Inc. The allocation of health insurance premiums and coverage responsibility may be a component of the child support determination.
Names/Variants Searched: Veridian Health Insurance Co.; Veridian Health Insurance; Veridian Health; Veridian Insurance
Search Result: No current or prior representation of Veridian Health Insurance Co. by Calderwood & Harkness LLP was identified. No matters in which Veridian appears as a client, adverse party, or related entity were identified. No adverse matters against Veridian were found.
Determination: CLEAR — No conflict identified.
5. Search Methodology
The conflict check searches described in this memorandum were conducted on April 13–14, 2023, using the Firm's internal conflicts management database system (IntaCheck v.7.2). The following methodology was employed:
1.  Full Legal Name Searches. Each individual and entity identified in Section 4 was searched by full legal name, including middle names and suffixes where known.
2.  Alias and Variant Searches. In addition to full legal name searches, each individual and entity was searched using common abbreviations, short names, known aliases, and reasonable variant spellings. Specific name variants searched for each party are documented in Section 4 above.
3.  Cross-Reference Against All Active and Closed Matters. All searches were cross-referenced against the Firm's complete database of active matters, closed matters, and archived matters, including client lists, adverse-party lists, related-party lists, and witness lists maintained in IntaCheck.
4.  Entity Affiliation Searches. For individuals identified as associated with corporate or organizational entities (e.g., Ms. Fonseca's employment at Luminos Entertainment Group; Mr. Medrano's ownership of Medrano Visuals, LLC), the affiliated entities were separately searched as described in Sections 4.3 and 4.4 above.
5.  Opposing Counsel Searches. The opposing law firm and its identified attorneys were searched individually to identify any prior co-counsel relationships, adverse relationships, or other institutional conflicts.
6.  Engagement Team Queries. All four members of the proposed engagement team — Oliver Mackenzie (Partner), Priya Anand (Partner), Devon Archer (Lead Associate), and Nadia Petrov (Working Associate) — were individually queried via email on April 13, 2023, regarding any personal, familial, financial, or prior professional relationships with any of the parties, entities, or counsel identified in Section 4. All four team members responded in the negative. No issues were reported by any member of the proposed engagement team.
7.  Supplemental Public Records Review. The undersigned conducted a supplemental review of the California Secretary of State's business entity records to confirm the current status and formation details of Medrano Visuals, LLC and to verify the registration information for the domestic partnership (File No. DP-2015-038741). The Los Angeles Superior Court online case portal was reviewed to confirm the case number, filing dates, and status of Case No. 22STFL09847.
The searches were conducted by Devon Archer, Lead Associate, and reviewed by Priya Anand, Partner, in accordance with the Firm's Conflicts Clearance Policy (C&H Policy No. GM-2019-007, as amended January 2022).
6. Conclusion and Clearance
Based on the comprehensive conflicts clearance process described in this memorandum, the following conclusions are reached:
1.  No conflicts of interest have been identified in connection with the prospective representation of Marguerite D. Fonseca in the custody and parenting-plan matter against Rafael J. Medrano, Case No. 22STFL09847, Superior Court of California, County of Los Angeles.
2.  No current or former client of Calderwood & Harkness LLP is adverse to the prospective client, and no current or former client would be materially affected by the Firm's acceptance of the proposed engagement. The representation does not present a conflict under California Rules of Professional Conduct, Rule 1.7 (Conflict of Interest: Current Clients) or Rule 1.9 (Duties to Former Clients).
3.  No member of the proposed engagement team has any personal, familial, financial, or prior professional relationship with any party, entity, or counsel identified in connection with the proposed matter.
4.  The matter is cleared for engagement. It is recommended that the Firm proceed with the preparation and execution of the engagement letter, which is anticipated to be executed on or about April 18, 2023. The initial retainer deposit is expected to be $50,000.00, to be deposited into the Firm's Client Trust Account upon execution of the engagement letter, in accordance with the Firm's standard billing and retainer policies for family law matters.
5.  Ongoing monitoring. As with all active matters, the parties and entities identified in this memorandum will remain in the Firm's IntaCheck database for ongoing conflict monitoring. Should any new parties, entities, or counsel become involved in the matter, supplemental conflict checks will be conducted promptly and documented in an addendum to this memorandum.
7. Approval
The undersigned requests approval from the Billing Partner and Responsible Partner to proceed with the engagement of Marguerite D. Fonseca in the matter described herein. Upon execution of both approvals below, the matter will be opened under Matter No. 1035-00002, and the engagement letter will be transmitted to the prospective client for execution.
BILLING PARTNER APPROVAL
Conflicts clearance approved — proceed with engagement.
Signature: ________
Name: Priya Anand
Title: Partner, Calderwood & Harkness LLP
Date: ________
RESPONSIBLE PARTNER APPROVAL
Conflicts clearance approved — proceed with engagement.
Signature: ________
Name: Oliver Mackenzie
Title: Partner, Calderwood & Harkness LLP
Date: ________
PREPARED BY
Signature: ________
Name: Devon Archer
Title: Lead Associate, Calderwood & Harkness LLP
Date: April 14, 2023
8. Distribution
This memorandum is designated PRIVILEGED & CONFIDENTIAL — ATTORNEY WORK PRODUCT and is prepared in connection with the Firm's internal conflicts clearance process. Distribution is limited to the following:
1.  Matter File. The original of this memorandum shall be retained in the matter file for Matter No. 1035-00002 (Proposed), to be maintained in the Firm's document management system in accordance with the Firm's records retention policies.
2.  Conflicts Department. A copy of this memorandum shall be filed with the Firm's General Counsel and Conflicts Department for retention in the central conflicts clearance archive.
3.  Addressees. Copies have been transmitted to Priya Anand (Billing Partner) and Oliver Mackenzie (Responsible Partner) via the Firm's secure internal document delivery system.
This memorandum shall not be disclosed to any person or entity outside Calderwood & Harkness LLP without the prior written authorization of the Billing Partner or the Firm's General Counsel. The contents of this memorandum are protected by the attorney work product doctrine and the attorney-client privilege, and no waiver of any applicable privilege or protection is intended by the internal distribution described above.
CALDERWOOD & HARKNESS LLP — PRIVILEGED & CONFIDENTIAL — ATTORNEY WORK PRODUCT Conflict Check Memorandum — Matter No. 1035-00002 (Proposed) — Marguerite D. Fonseca Prepared by Devon Archer, Lead Associate — April 14, 2023
Role | Attorney | Clearance Status
Responsible Partner | Oliver Mackenzie | Cleared — No conflicts identified
Billing Partner | Priya Anand | Cleared — No conflicts identified
Lead Associate | Devon Archer | Cleared — No conflicts identified
Working Associate | Nadia Petrov | Cleared — No conflicts identified

MEMORANDUM

BILLING PARTNER APPROVAL

RESPONSIBLE PARTNER APPROVAL

PREPARED BY

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