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

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CALDERWOOD & HARKNESS LLP Attorneys at Law

777 South Flower Street, Suite 3400 Los Angeles, California 90017

Telephone: (213) 554-7800 Facsimile: (213) 554-7801 www.calderwoodharkness.com

February 12, 2024

VIA ELECTRONIC MAIL AND U.S. MAIL

CONFIDENTIAL — ATTORNEY-CLIENT PRIVILEGED

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

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

Dear Ms. Fonseca:

1. Purpose of This Letter and Confirmation of Matter Conclusion

We write to confirm that the above-referenced matter has been concluded to a successful resolution and that Calderwood & Harkness LLP is formally closing the engagement file associated with your custody and parenting-plan dispute.

As you are aware, on February 9, 2024, the Honorable Judge of the Superior Court of California, County of Los Angeles, approved and entered the Stipulated Custody & Parenting Plan Agreement and the Child Support Agreement (collectively, the "Stipulated Agreement") as a final order in Case No. 22STFL09847. The court's entry of the final order represents the culmination of the objectives set forth at the outset of our engagement and concludes the substantive legal proceedings in which our firm was retained to represent you.

With the court's entry of the order and the completion of all outstanding administrative and billing matters, the firm is formally closing Matter No. 1035-00002 effective as of the date of this letter. This letter serves as our official notification to you of the closure of the matter and provides a comprehensive summary of the engagement, its outcome, financial matters, and important information regarding your continuing obligations and document retention.

2. Summary of the Engagement

Calderwood & Harkness LLP was engaged by you on April 18, 2023, to represent you in a confidential custody and parenting-plan dispute concerning your two minor children, Isabela Luz Fonseca-Medrano (date of birth: February 11, 2017) and Mateo Elías Fonseca-Medrano (date of birth: August 29, 2019), with their father, Rafael J. Medrano. The dispute arose following the entry of a dissolution judgment on November 3, 2022, which resolved the marital dissolution but expressly reserved jurisdiction over custody, visitation, and child support for further adjudication. Our firm was engaged to pursue a custody and parenting-plan arrangement that protected your interests as a parent and served the best interests of Isabela and Mateo.

The scope of the engagement encompassed the preparation and filing of all necessary pleadings, participation in court proceedings, retention and coordination with experts, negotiation with opposing counsel, participation in court-ordered and voluntary mediation, and the drafting and finalization of the Stipulated Agreement ultimately approved by the court. Throughout the engagement, the firm's team worked closely with you, with the court-appointed minor's counsel, and with multiple expert consultants to achieve a resolution that reflected both the children's welfare and your priorities as a custodial parent.

The firm's engagement team comprised the following attorneys:

• Oliver Mackenzie, Responsible Partner

• Priya Anand, Billing Partner

• Devon Archer, Lead Associate

• Nadia Petrov, Working Associate

Each member of the team contributed to the successful resolution of this matter, and we appreciate the collaborative and trusting relationship we maintained with you throughout the engagement.

3. Summary of Key Milestones and Outcome

The following is a summary of the principal milestones and events during the course of the representation, provided for your records:

May 2, 2023 — Request for Order Filed. The firm filed a Request for Order re Custody and Child Support with the Superior Court of California, County of Los Angeles, initiating the formal post-judgment custody proceedings and placing before the court the issues of legal and physical custody, timeshare, and child support.

May 30, 2023 — Temporary Custody Order Obtained. Following a hearing on the Request for Order, the court entered a Temporary Custody Order establishing a 60/40 timeshare in your favor during the pendency of the proceedings. This order provided important interim stability for Isabela and Mateo and positioned you as the primary residential parent while the case was being resolved.

June 22, 2023 — Appointment of Minor's Counsel. The court, acting on its own motion and pursuant to California Family Code Section 3150, appointed Tessa L. Brannigan, Esq., to serve as counsel for the minor children. Ms. Brannigan participated actively throughout the remainder of the proceedings and was instrumental in facilitating communication among all parties regarding the children's needs and preferences.

July 14, 2023 — Stipulation to Custody Evaluation. The parties entered into a stipulation for a comprehensive custody evaluation to be conducted by Dr. Elena V. Sorensen, Psy.D., of Sorensen Family Behavioral Health, P.C. The evaluation included individual interviews with both parents, observations of parent-child interactions, psychological testing, collateral interviews, and a review of relevant documentation.

October 6, 2023 — Custody Evaluation Report Delivered. Dr. Sorensen delivered her completed custody evaluation report to the court, the parties, and minor's counsel. The findings and recommendations contained in the report were favorable to your position and provided substantial support for the custody arrangement ultimately reflected in the Stipulated Agreement.

October – November 2023 — Forensic Income Analysis. In connection with the child support determination, the firm retained Harold K. Yamamoto, CPA/ABV/CFF, of Yamamoto Brace & Liu, LLP, to conduct a forensic income analysis of Mr. Medrano's freelance earnings. Mr. Yamamoto's analysis provided the court and the parties with a reliable basis for calculating guideline child support and supported our negotiating position regarding the appropriate support obligation.

November 17, 2023; December 15, 2023; January 19, 2024 — Mediation Sessions. Three mediation sessions were held before the Honorable Constance M. Yee (Ret.) of Pacific Coast Dispute Resolution Services. Judge Yee facilitated productive settlement discussions over the course of these sessions, and her experienced guidance was critical to bridging the remaining gaps between the parties' positions. Through the mediation process, the parties were able to reach a comprehensive settlement addressing all outstanding custody, parenting-plan, and child support issues.

January 31, 2024 — Execution of the Stipulated Agreement. Following the successful conclusion of mediation, the parties executed the Stipulated Custody & Parenting Plan Agreement and the Child Support Agreement on January 31, 2024. The agreements were then submitted to the court for approval.

February 9, 2024 — Court Approval and Entry of Final Order. The court reviewed and approved the Stipulated Agreement and entered it as a final order in Case No. 22STFL09847, bringing the custody and support proceedings to a conclusion.

We are pleased to note that this favorable resolution was achieved through negotiated settlement, without the need for a contested evidentiary hearing or trial. This outcome reflects both the strength of your position and the diligent, collaborative approach taken by all members of the engagement team.

4. Summary of Final Agreement Terms

For your reference and records, the following is a summary of the material terms of the Stipulated Agreement as approved and entered by the court. This summary is provided for convenience only and does not supersede or modify the terms of the actual agreements, which are enclosed with this letter. In the event of any discrepancy between this summary and the executed agreements, the terms of the executed agreements shall control.

Legal Custody. The parties share joint legal custody of both Isabela and Mateo. In the event the parties are unable to reach agreement on educational decisions affecting either child—including but not limited to school enrollment, educational programming, and special education services—tie-breaking authority on such decisions is vested in you.

Physical Custody. The parties share joint physical custody, with the children's primary residence designated as your home in Studio City, California.

Timeshare — School Year. During the school year, you are allocated approximately 232 overnights and Mr. Medrano is allocated approximately 133 overnights, reflecting an approximate timeshare of 63.6% to you and 36.4% to Mr. Medrano.

Timeshare — Summer Break. During the 10-week summer break (70 days), custodial time is split equally between the parents, with each parent receiving 35 overnights. The specific scheduling of summer custodial blocks is to be agreed upon by the parties no later than April 15 of each year, and in the absence of agreement, the default schedule set forth in the Stipulated Agreement shall apply.

Holiday Schedule. The Stipulated Agreement provides for an alternating even/odd year rotation for Thanksgiving, winter break, spring break, and other designated holidays. The full holiday and vacation schedule is set forth in Exhibit A to the Stipulated Custody & Parenting Plan Agreement, a copy of which is enclosed.

Travel Notice Provisions. The Stipulated Agreement requires thirty (30) days' written notice and written consent from the non-traveling parent for any international travel with the children outside the continental United States. For domestic travel outside the State of California, fourteen (14) days' written notice to the non-traveling parent is required. The full Right of First Refusal & Travel Notice Protocol is set forth in Exhibit B to the Stipulated Custody & Parenting Plan Agreement, a copy of which is enclosed.

On-Location Work Provision. If either parent's work requires travel exceeding fourteen (14) consecutive calendar days, custodial time during the travel period transfers to the other parent. The traveling parent is entitled to make-up time, which must be exercised within sixty (60) days of the traveling parent's return.

Child Support. You are obligated to pay child support to Mr. Medrano in the amount of $1,100.00 per month. This represents a downward deviation of $174.00 per month below the guideline amount of $1,274.00 per month, as calculated pursuant to applicable DissoMaster guidelines. The deviation reflects Mr. Medrano's agreement to contribute a higher share of the children's extracurricular activity costs, as described below. The court approved the deviation as being in the best interests of the children.

Education Costs. The children's tuition at Ridgeview Academy is allocated between the parties as follows: 70% to you and 30% to Mr. Medrano. Current annual tuition is $32,400.00 for Isabela and $26,800.00 for Mateo, for a combined total of $59,200.00 per year. Based on this allocation, your annual share is $41,440.00 and Mr. Medrano's annual share is $17,760.00.

Extracurricular Activities. Costs for the children's extracurricular activities are split 60% to Mr. Medrano and 40% to you, for qualifying expenses up to $1,500.00 per child per quarter. Any extracurricular expenditure exceeding the $1,500.00 per-child-per-quarter cap requires mutual written consent from both parents before the expense is incurred.

Healthcare. The children will remain enrolled in your employer-sponsored health insurance plan through Veridian Health Insurance Co. (the Luminos Entertainment Group plan). Unreimbursed medical, dental, orthodontic, and mental health expenses for the children are allocated 70% to you and 30% to Mr. Medrano.

Parenting Plan Coordinator. Dr. Marcus W. Ingalls, LMFT (License No. LMFT 89412), of Ingalls & Cuevas Family Counseling, has been appointed by the court to serve as the Parenting Plan Coordinator. Dr. Ingalls is available to assist both parties with the implementation of the parenting plan, resolution of day-to-day scheduling conflicts, and facilitation of communication regarding co-parenting matters.

Confidentiality and Non-Disparagement. The Stipulated Agreement includes a mutual non-disparagement and confidentiality clause binding both parties. In addition, the court has ordered the court file sealed pursuant to California Rules of Court, Rule 2.550 et seq. Both parties are prohibited from disclosing the terms of the Stipulated Agreement to third parties except as required by law, as necessary for enforcement, or to each party's respective legal, tax, and financial advisors.

Annual Review. Child support is subject to review on the anniversary of the order or upon a material change in circumstances. For purposes of the Stipulated Agreement, a "material change in circumstances" includes, without limitation, a change in either parent's gross income exceeding 15% or a change in the actual custodial timeshare exceeding 10%.

5. Final Billing Summary

Set forth below is a summary of the total fees and costs incurred during the engagement, as well as the current status of your account with the firm.

5.1 Professional Fees

The total professional fees billed for the engagement amount to $147,325.00. The following hourly rates were applied to the work performed by each member of the engagement team:

Detailed monthly invoices reflecting the hours billed by each attorney and the specific tasks performed were provided to you throughout the engagement. Should you require copies of any prior invoices, please do not hesitate to contact the firm.

5.2 Costs Advanced

In addition to professional fees, the firm advanced the following costs on your behalf during the course of the engagement:

5.3 Total Client Obligation and Payment Status

The following summarizes the total financial obligation for the engagement and its current status:

A retainer deposit of $50,000.00 was received from you on April 20, 2023, at the inception of the engagement. Subsequent payments were applied against invoices as they were issued through the pendency of the matter. The final payment was received on February 22, 2024.

Account Status: Paid in full. No balance remains outstanding. We thank you for your prompt attention to billing matters throughout the engagement.

6. Enclosed Documents

For your records and safekeeping, enclosed with this letter are the following documents:

1. Copy of the filed Stipulation for Judgment re Custody, Parenting Plan & Child Support, as entered by the court on February 9, 2024;

2. Copy of the court's signed order approving and entering the Stipulated Agreement;

3. Copy of the executed Stipulated Custody & Parenting Plan Agreement, dated January 31, 2024, together with all exhibits thereto, including:

(a) Exhibit A — Holiday & Vacation Schedule; and

(b) Exhibit B — Right of First Refusal & Travel Notice Protocol; and

4. Copy of the executed Child Support Agreement, dated January 31, 2024.

Please review the enclosed documents carefully to ensure they are complete and consistent with your understanding of the agreements reached. If you have any questions regarding any of the enclosed documents, please contact the firm promptly.

7. Document Retention Advisory

We strongly advise you to retain the enclosed originals and copies of all court orders and executed agreements in a safe and secure location. These documents may be needed for future reference in connection with the implementation and enforcement of the Stipulated Agreement, as well as for any future modification proceedings that may arise.

In accordance with Calderwood & Harkness LLP's document retention policy, the firm will maintain the complete matter file for this engagement, including all electronic records, correspondence, pleadings, work product, and related materials, for a period of seven (7) years from the date of matter closing—that is, through approximately February 2031. At the expiration of that seven-year retention period, the firm may destroy the file in its entirety, including all electronic and physical records, without further notice to you, absent contrary instruction received from you prior to that date.

If you wish for the firm to return to you any original documents currently maintained in the matter file, or if you wish to request an extension of the retention period beyond the standard seven-year term, please contact the firm in writing at your earliest convenience. We will be happy to accommodate any such request.

8. Continuing Obligations and Future Matters

Although the engagement has concluded and this letter constitutes the formal closure of the attorney-client relationship for purposes of Matter No. 1035-00002, we wish to bring to your attention certain continuing obligations arising from the Stipulated Agreement, compliance with which is your responsibility going forward.

The Stipulated Agreement contains several provisions that impose ongoing obligations on both you and Mr. Medrano. These include, but are not limited to, the annual review provision for child support, the travel notice requirements (including the 30-day notice and consent requirement for international travel and the 14-day notice requirement for domestic travel outside California), the on-location work provision, the extracurricular activity cost-sharing and consent requirements, and the confidentiality and non-disparagement provisions. We encourage you to review the enclosed agreements periodically to ensure your continued compliance with all applicable terms.

As noted in Section 4 above, Dr. Marcus W. Ingalls, LMFT, has been appointed as the Parenting Plan Coordinator. Should any implementation issues, scheduling disputes, or co-parenting communication difficulties arise, Dr. Ingalls may be contacted at:

Ingalls & Cuevas Family Counseling 10880 Wilshire Boulevard, Suite 630 Los Angeles, CA 90024

We encourage you to establish contact with Dr. Ingalls's office proactively, so that a working relationship is in place should the need for his assistance arise.

Please note that this letter constitutes the formal closure of our engagement, and Calderwood & Harkness LLP does not have an ongoing obligation to monitor compliance with the Stipulated Agreement or to advise you on post-order matters unless and until a new engagement is established. The firm's duty of representation has concluded as of the date of this letter. No attorney-client relationship will exist between you and the firm with respect to any future matters unless a new written engagement letter is executed.

Should you require legal assistance in the future—including but not limited to any modification of the custody, parenting plan, or child support orders; enforcement of the Stipulated Agreement; or any other family law matter—you are, of course, welcome to contact the firm to discuss a new engagement. We would be pleased to assist you and would make every effort to ensure continuity of counsel, to the extent possible, with the attorneys who handled this matter.

9. Expression of Appreciation

In closing, we wish to express our sincere appreciation for the confidence you placed in Calderwood & Harkness LLP and in the members of the engagement team throughout this matter. Representing you in the resolution of your custody and parenting-plan dispute was a privilege, and we are gratified by the favorable outcome that was achieved. The negotiated settlement secured meaningful protections for you and, most importantly, a stable and well-structured arrangement for Isabela and Mateo—accomplished without the uncertainty, expense, and emotional toll of a contested hearing or trial.

We wish you and your family every happiness going forward.

Sincerely,

CALDERWOOD & HARKNESS LLP

By: ________

Devon Archer Lead Associate Calderwood & Harkness LLP 777 South Flower Street, Suite 3400 Los Angeles, CA 90017 Telephone: (213) 554-7800

Email: darcher@calderwoodharkness.com

cc: Priya Anand, Esq. (Calderwood & Harkness LLP) cc: Oliver Mackenzie, Esq. (Calderwood & Harkness LLP)

Enclosures (as noted above)

Attorney	Role	Hourly Rate
Oliver Mackenzie	Responsible Partner	$925.00/hr
Priya Anand	Billing Partner	$875.00/hr
Devon Archer	Lead Associate	$625.00/hr
Nadia Petrov	Working Associate	$485.00/hr
Item	Amount
Custody evaluator — client's share (of $18,500.00 total, split equally with Mr. Medrano)	$9,250.00
Forensic accountant — Yamamoto Brace & Liu, LLP (flat fee)	$14,750.00
Mediator fees — client's share (of $13,650.00 total, split equally with Mr. Medrano)	$6,825.00
Filing fees, process server, and miscellaneous costs	$7,650.00
Total Costs Advanced	$38,475.00
Item	Amount
Total professional fees	$147,325.00
Total costs advanced	$38,475.00
Total client obligation	$185,800.00

CALDERWOOD & HARKNESS LLP Attorneys at Law
777 South Flower Street, Suite 3400 Los Angeles, California 90017
Telephone: (213) 554-7800 Facsimile: (213) 554-7801 www.calderwoodharkness.com
February 12, 2024
VIA ELECTRONIC MAIL AND U.S. MAIL
CONFIDENTIAL — ATTORNEY-CLIENT PRIVILEGED
Marguerite D. Fonseca 1742 Laurel Canyon Boulevard, Unit 3A Studio City, CA 91604
Re: Fonseca Custody & Parenting Plan — Matter Closing Matter No.: 1035-00002 Court Case: Case No. 22STFL09847, Superior Court of California, County of Los Angeles
Dear Ms. Fonseca:
1. Purpose of This Letter and Confirmation of Matter Conclusion
We write to confirm that the above-referenced matter has been concluded to a successful resolution and that Calderwood & Harkness LLP is formally closing the engagement file associated with your custody and parenting-plan dispute.
As you are aware, on February 9, 2024, the Honorable Judge of the Superior Court of California, County of Los Angeles, approved and entered the Stipulated Custody & Parenting Plan Agreement and the Child Support Agreement (collectively, the "Stipulated Agreement") as a final order in Case No. 22STFL09847. The court's entry of the final order represents the culmination of the objectives set forth at the outset of our engagement and concludes the substantive legal proceedings in which our firm was retained to represent you.
With the court's entry of the order and the completion of all outstanding administrative and billing matters, the firm is formally closing Matter No. 1035-00002 effective as of the date of this letter. This letter serves as our official notification to you of the closure of the matter and provides a comprehensive summary of the engagement, its outcome, financial matters, and important information regarding your continuing obligations and document retention.
2. Summary of the Engagement
Calderwood & Harkness LLP was engaged by you on April 18, 2023, to represent you in a confidential custody and parenting-plan dispute concerning your two minor children, Isabela Luz Fonseca-Medrano (date of birth: February 11, 2017) and Mateo Elías Fonseca-Medrano (date of birth: August 29, 2019), with their father, Rafael J. Medrano. The dispute arose following the entry of a dissolution judgment on November 3, 2022, which resolved the marital dissolution but expressly reserved jurisdiction over custody, visitation, and child support for further adjudication. Our firm was engaged to pursue a custody and parenting-plan arrangement that protected your interests as a parent and served the best interests of Isabela and Mateo.
The scope of the engagement encompassed the preparation and filing of all necessary pleadings, participation in court proceedings, retention and coordination with experts, negotiation with opposing counsel, participation in court-ordered and voluntary mediation, and the drafting and finalization of the Stipulated Agreement ultimately approved by the court. Throughout the engagement, the firm's team worked closely with you, with the court-appointed minor's counsel, and with multiple expert consultants to achieve a resolution that reflected both the children's welfare and your priorities as a custodial parent.
The firm's engagement team comprised the following attorneys:
• Oliver Mackenzie, Responsible Partner
• Priya Anand, Billing Partner
• Devon Archer, Lead Associate
• Nadia Petrov, Working Associate
Each member of the team contributed to the successful resolution of this matter, and we appreciate the collaborative and trusting relationship we maintained with you throughout the engagement.
3. Summary of Key Milestones and Outcome
The following is a summary of the principal milestones and events during the course of the representation, provided for your records:
May 2, 2023 — Request for Order Filed. The firm filed a Request for Order re Custody and Child Support with the Superior Court of California, County of Los Angeles, initiating the formal post-judgment custody proceedings and placing before the court the issues of legal and physical custody, timeshare, and child support.
May 30, 2023 — Temporary Custody Order Obtained. Following a hearing on the Request for Order, the court entered a Temporary Custody Order establishing a 60/40 timeshare in your favor during the pendency of the proceedings. This order provided important interim stability for Isabela and Mateo and positioned you as the primary residential parent while the case was being resolved.
June 22, 2023 — Appointment of Minor's Counsel. The court, acting on its own motion and pursuant to California Family Code Section 3150, appointed Tessa L. Brannigan, Esq., to serve as counsel for the minor children. Ms. Brannigan participated actively throughout the remainder of the proceedings and was instrumental in facilitating communication among all parties regarding the children's needs and preferences.
July 14, 2023 — Stipulation to Custody Evaluation. The parties entered into a stipulation for a comprehensive custody evaluation to be conducted by Dr. Elena V. Sorensen, Psy.D., of Sorensen Family Behavioral Health, P.C. The evaluation included individual interviews with both parents, observations of parent-child interactions, psychological testing, collateral interviews, and a review of relevant documentation.
October 6, 2023 — Custody Evaluation Report Delivered. Dr. Sorensen delivered her completed custody evaluation report to the court, the parties, and minor's counsel. The findings and recommendations contained in the report were favorable to your position and provided substantial support for the custody arrangement ultimately reflected in the Stipulated Agreement.
October – November 2023 — Forensic Income Analysis. In connection with the child support determination, the firm retained Harold K. Yamamoto, CPA/ABV/CFF, of Yamamoto Brace & Liu, LLP, to conduct a forensic income analysis of Mr. Medrano's freelance earnings. Mr. Yamamoto's analysis provided the court and the parties with a reliable basis for calculating guideline child support and supported our negotiating position regarding the appropriate support obligation.
November 17, 2023; December 15, 2023; January 19, 2024 — Mediation Sessions. Three mediation sessions were held before the Honorable Constance M. Yee (Ret.) of Pacific Coast Dispute Resolution Services. Judge Yee facilitated productive settlement discussions over the course of these sessions, and her experienced guidance was critical to bridging the remaining gaps between the parties' positions. Through the mediation process, the parties were able to reach a comprehensive settlement addressing all outstanding custody, parenting-plan, and child support issues.
January 31, 2024 — Execution of the Stipulated Agreement. Following the successful conclusion of mediation, the parties executed the Stipulated Custody & Parenting Plan Agreement and the Child Support Agreement on January 31, 2024. The agreements were then submitted to the court for approval.
February 9, 2024 — Court Approval and Entry of Final Order. The court reviewed and approved the Stipulated Agreement and entered it as a final order in Case No. 22STFL09847, bringing the custody and support proceedings to a conclusion.
We are pleased to note that this favorable resolution was achieved through negotiated settlement, without the need for a contested evidentiary hearing or trial. This outcome reflects both the strength of your position and the diligent, collaborative approach taken by all members of the engagement team.
4. Summary of Final Agreement Terms
For your reference and records, the following is a summary of the material terms of the Stipulated Agreement as approved and entered by the court. This summary is provided for convenience only and does not supersede or modify the terms of the actual agreements, which are enclosed with this letter. In the event of any discrepancy between this summary and the executed agreements, the terms of the executed agreements shall control.
Legal Custody. The parties share joint legal custody of both Isabela and Mateo. In the event the parties are unable to reach agreement on educational decisions affecting either child—including but not limited to school enrollment, educational programming, and special education services—tie-breaking authority on such decisions is vested in you.
Physical Custody. The parties share joint physical custody, with the children's primary residence designated as your home in Studio City, California.
Timeshare — School Year. During the school year, you are allocated approximately 232 overnights and Mr. Medrano is allocated approximately 133 overnights, reflecting an approximate timeshare of 63.6% to you and 36.4% to Mr. Medrano.
Timeshare — Summer Break. During the 10-week summer break (70 days), custodial time is split equally between the parents, with each parent receiving 35 overnights. The specific scheduling of summer custodial blocks is to be agreed upon by the parties no later than April 15 of each year, and in the absence of agreement, the default schedule set forth in the Stipulated Agreement shall apply.
Holiday Schedule. The Stipulated Agreement provides for an alternating even/odd year rotation for Thanksgiving, winter break, spring break, and other designated holidays. The full holiday and vacation schedule is set forth in Exhibit A to the Stipulated Custody & Parenting Plan Agreement, a copy of which is enclosed.
Travel Notice Provisions. The Stipulated Agreement requires thirty (30) days' written notice and written consent from the non-traveling parent for any international travel with the children outside the continental United States. For domestic travel outside the State of California, fourteen (14) days' written notice to the non-traveling parent is required. The full Right of First Refusal & Travel Notice Protocol is set forth in Exhibit B to the Stipulated Custody & Parenting Plan Agreement, a copy of which is enclosed.
On-Location Work Provision. If either parent's work requires travel exceeding fourteen (14) consecutive calendar days, custodial time during the travel period transfers to the other parent. The traveling parent is entitled to make-up time, which must be exercised within sixty (60) days of the traveling parent's return.
Child Support. You are obligated to pay child support to Mr. Medrano in the amount of $1,100.00 per month. This represents a downward deviation of $174.00 per month below the guideline amount of $1,274.00 per month, as calculated pursuant to applicable DissoMaster guidelines. The deviation reflects Mr. Medrano's agreement to contribute a higher share of the children's extracurricular activity costs, as described below. The court approved the deviation as being in the best interests of the children.
Education Costs. The children's tuition at Ridgeview Academy is allocated between the parties as follows: 70% to you and 30% to Mr. Medrano. Current annual tuition is $32,400.00 for Isabela and $26,800.00 for Mateo, for a combined total of $59,200.00 per year. Based on this allocation, your annual share is $41,440.00 and Mr. Medrano's annual share is $17,760.00.
Extracurricular Activities. Costs for the children's extracurricular activities are split 60% to Mr. Medrano and 40% to you, for qualifying expenses up to $1,500.00 per child per quarter. Any extracurricular expenditure exceeding the $1,500.00 per-child-per-quarter cap requires mutual written consent from both parents before the expense is incurred.
Healthcare. The children will remain enrolled in your employer-sponsored health insurance plan through Veridian Health Insurance Co. (the Luminos Entertainment Group plan). Unreimbursed medical, dental, orthodontic, and mental health expenses for the children are allocated 70% to you and 30% to Mr. Medrano.
Parenting Plan Coordinator. Dr. Marcus W. Ingalls, LMFT (License No. LMFT 89412), of Ingalls & Cuevas Family Counseling, has been appointed by the court to serve as the Parenting Plan Coordinator. Dr. Ingalls is available to assist both parties with the implementation of the parenting plan, resolution of day-to-day scheduling conflicts, and facilitation of communication regarding co-parenting matters.
Confidentiality and Non-Disparagement. The Stipulated Agreement includes a mutual non-disparagement and confidentiality clause binding both parties. In addition, the court has ordered the court file sealed pursuant to California Rules of Court, Rule 2.550 et seq. Both parties are prohibited from disclosing the terms of the Stipulated Agreement to third parties except as required by law, as necessary for enforcement, or to each party's respective legal, tax, and financial advisors.
Annual Review. Child support is subject to review on the anniversary of the order or upon a material change in circumstances. For purposes of the Stipulated Agreement, a "material change in circumstances" includes, without limitation, a change in either parent's gross income exceeding 15% or a change in the actual custodial timeshare exceeding 10%.
5. Final Billing Summary
Set forth below is a summary of the total fees and costs incurred during the engagement, as well as the current status of your account with the firm.
5.1 Professional Fees
The total professional fees billed for the engagement amount to $147,325.00. The following hourly rates were applied to the work performed by each member of the engagement team:
Detailed monthly invoices reflecting the hours billed by each attorney and the specific tasks performed were provided to you throughout the engagement. Should you require copies of any prior invoices, please do not hesitate to contact the firm.
5.2 Costs Advanced
In addition to professional fees, the firm advanced the following costs on your behalf during the course of the engagement:
5.3 Total Client Obligation and Payment Status
The following summarizes the total financial obligation for the engagement and its current status:
A retainer deposit of $50,000.00 was received from you on April 20, 2023, at the inception of the engagement. Subsequent payments were applied against invoices as they were issued through the pendency of the matter. The final payment was received on February 22, 2024.
Account Status: Paid in full. No balance remains outstanding. We thank you for your prompt attention to billing matters throughout the engagement.
6. Enclosed Documents
For your records and safekeeping, enclosed with this letter are the following documents:
1. Copy of the filed Stipulation for Judgment re Custody, Parenting Plan & Child Support, as entered by the court on February 9, 2024;
2. Copy of the court's signed order approving and entering the Stipulated Agreement;
3. Copy of the executed Stipulated Custody & Parenting Plan Agreement, dated January 31, 2024, together with all exhibits thereto, including:
(a) Exhibit A — Holiday & Vacation Schedule; and
(b) Exhibit B — Right of First Refusal & Travel Notice Protocol; and
4. Copy of the executed Child Support Agreement, dated January 31, 2024.
Please review the enclosed documents carefully to ensure they are complete and consistent with your understanding of the agreements reached. If you have any questions regarding any of the enclosed documents, please contact the firm promptly.
7. Document Retention Advisory
We strongly advise you to retain the enclosed originals and copies of all court orders and executed agreements in a safe and secure location. These documents may be needed for future reference in connection with the implementation and enforcement of the Stipulated Agreement, as well as for any future modification proceedings that may arise.
In accordance with Calderwood & Harkness LLP's document retention policy, the firm will maintain the complete matter file for this engagement, including all electronic records, correspondence, pleadings, work product, and related materials, for a period of seven (7) years from the date of matter closing—that is, through approximately February 2031. At the expiration of that seven-year retention period, the firm may destroy the file in its entirety, including all electronic and physical records, without further notice to you, absent contrary instruction received from you prior to that date.
If you wish for the firm to return to you any original documents currently maintained in the matter file, or if you wish to request an extension of the retention period beyond the standard seven-year term, please contact the firm in writing at your earliest convenience. We will be happy to accommodate any such request.
8. Continuing Obligations and Future Matters
Although the engagement has concluded and this letter constitutes the formal closure of the attorney-client relationship for purposes of Matter No. 1035-00002, we wish to bring to your attention certain continuing obligations arising from the Stipulated Agreement, compliance with which is your responsibility going forward.
The Stipulated Agreement contains several provisions that impose ongoing obligations on both you and Mr. Medrano. These include, but are not limited to, the annual review provision for child support, the travel notice requirements (including the 30-day notice and consent requirement for international travel and the 14-day notice requirement for domestic travel outside California), the on-location work provision, the extracurricular activity cost-sharing and consent requirements, and the confidentiality and non-disparagement provisions. We encourage you to review the enclosed agreements periodically to ensure your continued compliance with all applicable terms.
As noted in Section 4 above, Dr. Marcus W. Ingalls, LMFT, has been appointed as the Parenting Plan Coordinator. Should any implementation issues, scheduling disputes, or co-parenting communication difficulties arise, Dr. Ingalls may be contacted at:
Ingalls & Cuevas Family Counseling 10880 Wilshire Boulevard, Suite 630 Los Angeles, CA 90024
We encourage you to establish contact with Dr. Ingalls's office proactively, so that a working relationship is in place should the need for his assistance arise.
Please note that this letter constitutes the formal closure of our engagement, and Calderwood & Harkness LLP does not have an ongoing obligation to monitor compliance with the Stipulated Agreement or to advise you on post-order matters unless and until a new engagement is established. The firm's duty of representation has concluded as of the date of this letter. No attorney-client relationship will exist between you and the firm with respect to any future matters unless a new written engagement letter is executed.
Should you require legal assistance in the future—including but not limited to any modification of the custody, parenting plan, or child support orders; enforcement of the Stipulated Agreement; or any other family law matter—you are, of course, welcome to contact the firm to discuss a new engagement. We would be pleased to assist you and would make every effort to ensure continuity of counsel, to the extent possible, with the attorneys who handled this matter.
9. Expression of Appreciation
In closing, we wish to express our sincere appreciation for the confidence you placed in Calderwood & Harkness LLP and in the members of the engagement team throughout this matter. Representing you in the resolution of your custody and parenting-plan dispute was a privilege, and we are gratified by the favorable outcome that was achieved. The negotiated settlement secured meaningful protections for you and, most importantly, a stable and well-structured arrangement for Isabela and Mateo—accomplished without the uncertainty, expense, and emotional toll of a contested hearing or trial.
We wish you and your family every happiness going forward.
Sincerely,
CALDERWOOD & HARKNESS LLP
By: ________
Devon Archer Lead Associate Calderwood & Harkness LLP 777 South Flower Street, Suite 3400 Los Angeles, CA 90017 Telephone: (213) 554-7800
Email: darcher@calderwoodharkness.com
cc: Priya Anand, Esq. (Calderwood & Harkness LLP) cc: Oliver Mackenzie, Esq. (Calderwood & Harkness LLP)
Enclosures (as noted above)
Attorney | Role | Hourly Rate
Oliver Mackenzie | Responsible Partner | $925.00/hr
Priya Anand | Billing Partner | $875.00/hr
Devon Archer | Lead Associate | $625.00/hr
Nadia Petrov | Working Associate | $485.00/hr
Item | Amount
Custody evaluator — client's share (of $18,500.00 total, split equally with Mr. Medrano) | $9,250.00
Forensic accountant — Yamamoto Brace & Liu, LLP (flat fee) | $14,750.00
Mediator fees — client's share (of $13,650.00 total, split equally with Mr. Medrano) | $6,825.00
Filing fees, process server, and miscellaneous costs | $7,650.00
Total Costs Advanced | $38,475.00
Item | Amount
Total professional fees | $147,325.00
Total costs advanced | $38,475.00
Total client obligation | $185,800.00

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