CALDERWOOD & HARKNESS LLP

CALDERWOOD & HARKNESS LLP
NEW MATTER INTAKE FORM
Internal / Confidential — Not for External Distribution
Calderwood & Harkness LLP 777 South Flower Street, Suite 3400 Los Angeles, California 90017 Telephone: (213) 555-8200 | Facsimile: (213) 555-8201
Date Completed: April 18, 2023
Completed By: Devon Archer, Lead Associate
SECTION 1: MATTER IDENTIFICATION
Matter Number: 1035-00002
Matter Name: Fonseca Custody & Parenting Plan
Date Opened: April 18, 2023
Practice Area: Family Law
Matter Type: Custody / Parenting Plan / Child Support
Related Case Number: Case No. 22STFL09847
Court: Superior Court of California, County of Los Angeles, Stanley Mosk Courthouse, 111 North Hill Street, Los Angeles, CA 90012
Related Prior Proceeding: Dissolution of Domestic Partnership — Judgment of Dissolution entered November 3, 2022 (Case No. 22STFL09847). Pursuant to the terms of the dissolution judgment, the court expressly reserved jurisdiction over all issues related to child custody, visitation, and child support. The dissolution judgment resolved property division and related financial claims between the parties, but the parties were unable to reach agreement on custodial arrangements at the time of judgment, and the court accordingly bifurcated and reserved those issues for future determination.
CA Secretary of State Domestic Partnership File No.: DP-2015-038741 (registered September 12, 2015, with the California Secretary of State)
SECTION 2: CLIENT INFORMATION
Client Name: Marguerite Delphine Fonseca
Date of Birth: June 14, 1984
Role in Matter: Petitioner
Home Address: 1742 Laurel Canyon Boulevard, Unit 3A, Studio City, CA 91604
Telephone (Mobile): On file
Email: On file
Employer: Luminos Entertainment Group, Inc.
Employer Address: 3200 West Olive Avenue, Burbank, CA 91505
Employer Entity Type / Jurisdiction of Incorporation: Corporation, incorporated in the State of Delaware, with principal place of business and corporate headquarters located in Burbank, California.
Title / Position: Senior Vice President, Original Content Development
Annual Compensation (as reported by client):
Ms. Fonseca's compensation includes base salary paid on a semi-monthly basis, a discretionary annual bonus typically paid in Q1 of the following fiscal year, and restricted stock units that vest on a four-year schedule with annual cliff vesting. The RSU vesting figure of $175,000 represents the approximate annualized fair market value of units vesting in the current grant cycle. Ms. Fonseca has confirmed that she receives no additional perquisites, deferred compensation, or supplemental income beyond the foregoing.
Referral Source: To be completed. Note: not specified in current matter records; intake coordinator to follow up with client to confirm referral source for firm marketing and tracking purposes.
Existing Client of Calderwood & Harkness LLP: No. Ms. Fonseca is a new client of the firm. No prior engagements or representations have been identified. A new client file has been established and new client onboarding procedures have been initiated.
SECTION 3: ADVERSE / OPPOSING PARTY INFORMATION
Adverse Party Name: Rafael Joaquín Medrano
Date of Birth: March 22, 1982
Role in Matter: Respondent
Home Address: 609 Moorpark Street, Apt. 12, North Hollywood, CA 91602
Occupation: Freelance Cinematographer / Director of Photography. Mr. Medrano works on a project-by-project basis in the motion picture and television industries, serving as Director of Photography and/or cinematographer on feature films, television series, streaming content, and commercial productions. His work schedule is irregular, project-dependent, and frequently requires extended periods of on-location work outside of the Los Angeles metropolitan area.
Loan-Out Entity: Medrano Visuals, LLC, a California limited liability company. Mr. Medrano operates his professional services through this entity and is believed to be the sole member and manager. All or substantially all of Mr. Medrano's professional income is understood to flow through Medrano Visuals, LLC, which contracts directly with production companies and studios on Mr. Medrano's behalf. The use of this loan-out entity will necessitate forensic accounting analysis to determine Mr. Medrano's true available income for child support calculation purposes, as loan-out entities in the entertainment industry may be used to shelter income through business expense deductions, retained earnings, and other means.
Estimated Annual Income: Approximately $340,000 (three-year average, based on preliminary information provided by client). This figure is subject to verification through discovery and forensic accounting analysis. Mr. Medrano's income is expected to be highly variable from year to year depending on project availability, the scale and budget tier of productions on which he works, and the duration of individual engagements. Accurate income determination will be a central issue in the child support calculation.
SECTION 4: OPPOSING COUNSEL
Firm Name: Kwan, Delacroix & Samuels LLP
Entity Type / Jurisdiction: Limited Liability Partnership, organized under the laws of the State of California.
Address: 4400 Riverside Drive, Suite 700, Burbank, CA 91505
Lead Attorney: Gwendolyn R. Kwan, Partner California State Bar No. 218453
Associate Attorney: Benjamin T. Okafor California State Bar No. 312776
Ms. Kwan is a well-known family law practitioner in the Los Angeles area with particular experience representing entertainment industry professionals. She is known for aggressive advocacy during negotiation phases but has demonstrated a willingness to reach reasonable settlements in appropriate cases. Her firm regularly handles high-net-worth custody and support matters in Los Angeles County. Mr. Okafor is understood to be a mid-level associate in the firm's family law practice group.
Communication with opposing counsel should be directed to Ms. Kwan in the first instance, with copies to Mr. Okafor, unless otherwise instructed. Contact information for opposing counsel is on file.
SECTION 5: MINOR CHILDREN
Child 1.  Full Legal Name: Isabela Luz Fonseca-Medrano
Date of Birth: February 11, 2017
Age at Matter Opening: 6 years old
School: Ridgeview Academy, 4515 Sepulveda Boulevard, Sherman Oaks, CA 91403. Ridgeview Academy is a private, nonprofit educational institution offering pre-kindergarten through eighth grade programming. The school is located in the San Fernando Valley, approximately equidistant from both parents' residences.
Current Grade: First Grade
Annual Tuition: $32,400
Additional Information: Isabela has been enrolled at Ridgeview Academy since kindergarten. Ms. Fonseca reports that Isabela has adjusted well to the school environment and that continuity of enrollment is important for her educational and social development. Both parents have historically participated in parent-teacher conferences, school events, and extracurricular activities at Ridgeview Academy. The allocation of tuition costs and educational expenses will be addressed as part of the child support and parenting plan negotiations.
Child 2.  Full Legal Name: Mateo Elías Fonseca-Medrano
Date of Birth: August 29, 2019
Age at Matter Opening: 3 years old
School: Ridgeview Academy, 4515 Sepulveda Boulevard, Sherman Oaks, CA 91403 (same institution as Child 1).
Current Program: Pre-Kindergarten
Annual Tuition: $26,800
Additional Information: Mateo commenced enrollment at Ridgeview Academy's pre-kindergarten program at the beginning of the 2022–2023 school year. Ms. Fonseca reports that Mateo has been thriving in the pre-kindergarten program and that maintaining both children at the same school simplifies logistics and promotes sibling connection. The combined annual tuition for both children is $59,200. This expense will be a factor in the child support analysis and will be addressed in the stipulated agreement or court order.
SECTION 6: STAFFING & BILLING INFORMATION
Engagement Team.  
Staffing Notes: Oliver Mackenzie serves as the Responsible Partner on this matter in a supervisory capacity, consistent with the firm's policies requiring partner oversight on all client engagements. Mr. Mackenzie's involvement will be limited to supervisory review, strategic guidance, and client relationship management. Priya Anand will serve as the Billing Partner and will have primary responsibility for billing oversight, client invoicing, and trust account management. Day-to-day substantive work on the matter will be handled by Devon Archer, Lead Associate, who will coordinate all filings, correspondence with opposing counsel, discovery, and hearing preparation. Nadia Petrov will provide supporting research, document drafting, and case management assistance under Mr. Archer's direction. Additional staffing (including paralegals and temporary support staff) may be assigned as the matter progresses and workload requirements are assessed.
Fee Arrangement.  Billing Basis: Hourly. All attorney and professional time spent on the matter will be billed at the hourly rates set forth above, in increments of one-tenth (0.1) of an hour. Costs and expenses (including filing fees, service of process, copying, expert fees, and travel) will be billed separately at actual cost.
Retainer Deposit: $50,000.00
Retainer Received Date: Expected April 20, 2023. As of the date of this intake form, the retainer deposit has not yet been received. The client has been advised that substantive work on the matter will not commence until the retainer has been received and deposited into the firm's client trust account.
Estimated Total Fees: $120,000–$175,000. This range is dependent on whether the matter resolves by negotiated agreement (including through mediation or other alternative dispute resolution) or proceeds to a contested hearing or trial on custody and/or child support issues. The lower end of the range assumes that the parties are able to reach a stipulated agreement following one to two rounds of mediation and limited discovery. The upper end of the range assumes contested proceedings, including a custody evaluation, expert testimony, and one or more evidentiary hearings. The estimate does not include third-party professional fees (forensic accountant, custody evaluator, mediator, etc.), which will be billed to the client separately or allocated between the parties as determined by agreement or court order.
Billing Frequency: Monthly. Invoices will be prepared and transmitted to the client on or about the fifteenth (15th) of each month for services rendered and costs incurred during the prior calendar month.
Client Trust Account: The $50,000 retainer deposit will be deposited into the firm's Interest on Lawyers' Trust Account (IOLTA) client trust account upon receipt, in compliance with California Business & Professions Code § 6211 and California Rules of Professional Conduct, Rule 1.15. Funds will be drawn from the trust account against billed fees and costs as invoices are issued and approved by the client. The client will be notified when the trust account balance falls below a threshold to be set forth in the engagement letter, and the client will be expected to replenish the retainer as necessary.
SECTION 7: SCOPE OF REPRESENTATION
The scope of the firm's representation of Marguerite Delphine Fonseca in this matter encompasses the following:
1.  Custody Agreement and Parenting Plan. Negotiation and, if necessary, litigation of a comprehensive custody agreement and parenting plan for the two minor children, Isabela Luz Fonseca-Medrano and Mateo Elías Fonseca-Medrano, addressing legal custody (joint or sole), physical custody, primary residential parent designation, and all related custodial issues.
2.  Child Support Order. Establishment of a child support order pursuant to the California guideline child support calculation under California Family Code § 4055 et seq., taking into account both parties' income, custodial timeshare, tax filing status, mandatory payroll deductions, health insurance costs, and add-on expenses including but not limited to childcare, educational costs (tuition at Ridgeview Academy), and extracurricular activities.
3.  Request for Order (RFO). Preparation and filing of a Request for Order re Custody and Child Support in Case No. 22STFL09847, Superior Court of California, County of Los Angeles, including all supporting declarations, income and expense declarations, and exhibits.
4.  Temporary Custody and Visitation Orders. Pursuit of temporary (pendente lite) custody and visitation orders to establish a stable and predictable custodial arrangement for the children while the matter proceeds toward final resolution.
5.  Coordination with Third-Party Professionals. Coordination and collaboration with a custody evaluator (to be appointed by the court or stipulated by the parties), forensic accountant (Harold K. Yamamoto, CPA/ABV/CFF, of Yamamoto Brace & Liu, LLP), minor's counsel (to be appointed by the court pursuant to Family Code § 3150), mediator (to be proposed), and parenting plan coordinator (to be determined post-agreement), as necessary to advance the client's interests and facilitate resolution of the matter.
6.  Mediation and Alternative Dispute Resolution. Representation of the client in mediation proceedings and other alternative dispute resolution processes, including preparation of mediation briefs, attendance at mediation sessions, and negotiation of settlement terms arising from such proceedings.
7.  Stipulated Agreements and Related Documents. Drafting, review, negotiation, and execution of a stipulated custody agreement, parenting plan, child support agreement, and all related exhibits, schedules, and ancillary documents, including holiday and vacation schedules, right of first refusal provisions, relocation provisions, communication protocols, and dispute resolution mechanisms.
8.  Stipulation for Judgment and Court Approval. Preparation and filing of a stipulation for judgment incorporating the agreed-upon custody, parenting plan, and child support terms, and obtaining court approval and entry of the stipulated judgment.
9.  Petition to Seal Court File. Preparation and filing of a petition or motion to seal the court file, in whole or in part, pursuant to California Rules of Court, Rule 2.550 et seq., to protect the privacy interests of both parties as public-facing entertainment industry professionals and to safeguard the privacy and well-being of the minor children.
10.  General Goal and Strategy. The overarching objective of the representation is to achieve a resolution by settlement and stipulated agreement without the necessity of a contested trial. All efforts will be directed toward reaching a fair, workable, and comprehensive agreement that serves the best interests of the children while protecting Ms. Fonseca's parental rights and financial interests. However, the firm is prepared to proceed to contested hearing or trial if settlement efforts are unsuccessful.
The scope of representation is limited to the foregoing matters. Representation does not include any post-judgment modification proceedings, enforcement actions, appellate proceedings, or matters unrelated to custody, parenting plan, and child support issues in Case No. 22STFL09847, unless separately agreed upon in writing.
SECTION 8: CONFLICTS CHECK
Conflicts Check Completed: Yes
Conflicts Check Memorandum Date: April 14, 2023
Conflicts Check Conducted By: Firm Conflicts Department, Calderwood & Harkness LLP
Parties and Entities Checked Against the Firm's Conflicts Database:
(a) Marguerite Delphine Fonseca (individual — prospective client)
(b) Rafael Joaquín Medrano (individual — adverse party)
(c) Medrano Visuals, LLC, a California limited liability company (loan-out entity of adverse party)
(d) Kwan, Delacroix & Samuels LLP (opposing counsel)
(e) Gwendolyn R. Kwan (lead attorney, opposing counsel)
(f) Benjamin T. Okafor (associate attorney, opposing counsel)
(g) Luminos Entertainment Group, Inc. (client's employer)
(h) Related parties, affiliates, officers, directors, and known associates of each of the foregoing, as identified through the firm's standard conflicts search protocols
Conflicts Identified: None. The conflicts search did not identify any current or former client relationships, adverse representations, business relationships, financial interests, or other circumstances that would give rise to a conflict of interest under the California Rules of Professional Conduct, Rules 1.7 or 1.9, or that would otherwise preclude or restrict the firm's representation of Ms. Fonseca in this matter.
Cleared By: Firm Conflicts Counsel / General Counsel (to be designated upon final clearance signature below). Final conflicts clearance is pending execution of the approval signature in Section 13 of this form.
SECTION 9: MATTER DESCRIPTION / BACKGROUND SUMMARY
Ms. Marguerite Delphine Fonseca and Mr. Rafael Joaquín Medrano were registered as domestic partners under California law on September 12, 2015, with the California Secretary of State (Domestic Partnership File No. DP-2015-038741). During the course of their domestic partnership, two children were born: Isabela Luz Fonseca-Medrano (date of birth: February 11, 2017) and Mateo Elías Fonseca-Medrano (date of birth: August 29, 2019). Both children were born in Los Angeles, California, and have resided in the Los Angeles area for their entire lives.
Ms. Fonseca filed a Petition for Dissolution of Domestic Partnership on July 8, 2022, initiating Case No. 22STFL09847 in the Superior Court of California, County of Los Angeles. The matter was assigned to the Stanley Mosk Courthouse. The dissolution proceedings progressed on an expedited basis with respect to the termination of the domestic partnership and the division of community property. A Judgment of Dissolution was entered on November 3, 2022. However, at the time of judgment, the parties had not reached agreement on issues relating to child custody, visitation, or child support. Accordingly, the court expressly reserved jurisdiction over those issues for future determination.
Following the entry of the dissolution judgment, the children split their time between both parents under an informal, unwritten custodial arrangement. This arrangement was generally workable in the immediate aftermath of the dissolution, with the children spending roughly alternating weeks with each parent and both parents coordinating school drop-offs and pickups at Ridgeview Academy in Sherman Oaks.
The informal arrangement broke down in early 2023 when Mr. Medrano accepted a seven-week on-location production shoot in Vancouver, British Columbia, Canada. Mr. Medrano's departure for Vancouver left the children primarily in the care of Ms. Fonseca for the duration of the shoot, disrupting the established custodial routine and causing significant logistical and emotional difficulties for the children and for Ms. Fonseca, who was required to adjust her own professional schedule to accommodate the unplanned change. Ms. Fonseca reports that Mr. Medrano provided limited advance notice of the Vancouver engagement, did not consult her regarding childcare arrangements during his absence, and was inconsistent in maintaining contact with the children during the on-location period.
As a result of this breakdown, Ms. Fonseca has determined that a formal, court-ordered custody and parenting plan is necessary to provide stability, predictability, and structure for the children going forward. Ms. Fonseca seeks to establish a comprehensive parenting plan that addresses, among other things, legal and physical custody, a detailed custodial timeshare schedule, holiday and vacation schedules, provisions for travel and on-location work by either parent, right of first refusal, communication protocols, and dispute resolution mechanisms. Ms. Fonseca also seeks the establishment of a child support order consistent with the California guideline calculation.
Both parties are public-facing professionals in the entertainment industry. Ms. Fonseca serves as Senior Vice President, Original Content Development at Luminos Entertainment Group, Inc., a major entertainment conglomerate. Mr. Medrano is a freelance cinematographer and Director of Photography who has worked on numerous high-profile film and television productions. Given their professional profiles and the potential for media attention, confidentiality and the protection of the children's privacy are of paramount importance. The firm will pursue sealing of the court file pursuant to California Rules of Court, Rule 2.550 et seq.
Both children are currently enrolled at Ridgeview Academy, a private, nonprofit school in Sherman Oaks, California. Isabela is in first grade and Mateo is in the pre-kindergarten program. Combined annual tuition for both children is $59,200. Continuity of the children's enrollment at Ridgeview Academy is a priority for Ms. Fonseca and is expected to be a point of agreement between the parties.
The children are currently covered under Ms. Fonseca's employer-sponsored health insurance plan through Veridian Health Insurance Co. (the Luminos Entertainment Group plan). The allocation of health insurance costs and uninsured medical expenses will be addressed as part of the child support and parenting plan negotiations.
SECTION 10: ANTICIPATED THIRD-PARTY PROFESSIONALS / VENDORS
The following third-party professionals and vendors are anticipated to be engaged or appointed in connection with this matter:
SECTION 11: KEY DATES / INITIAL TIMELINE
The following target dates and action items have been identified for the initial phase of the matter:
The foregoing timeline is preliminary and subject to adjustment based on court scheduling, opposing counsel's availability, the pace of discovery and expert engagement, and the parties' progress toward settlement.
SECTION 12: SPECIAL CONSIDERATIONS / NOTES
Confidentiality and Court File Sealing. Ms. Fonseca is a high-profile executive in the entertainment industry, and Mr. Medrano is a well-known cinematographer whose credits include several major studio and streaming productions. Both parties have a significant public profile within the entertainment community and, to a lesser extent, in the general media. The firm will pursue sealing of the court file, in whole or in part, pursuant to California Rules of Court, Rule 2.550 et seq. The motion to seal will be predicated on the grounds that both parties are public-facing professionals, that the court filings will contain sensitive financial and personal information, and that the privacy interests of the minor children are paramount and outweigh the public's right of access. The engagement team should be mindful of confidentiality considerations in all filings and communications and should avoid including unnecessary identifying details in publicly filed documents pending resolution of the sealing motion.
Income Complexity — Loan-Out Entity. Mr. Medrano's income is variable and flows through a loan-out entity, Medrano Visuals, LLC, a California limited liability company. Loan-out entities are common in the entertainment industry and present particular challenges in the child support context. The entity may be used to pay for personal expenses, retain earnings, or claim business deductions that effectively reduce the income available for child support calculation. Forensic accounting will be required to accurately determine Mr. Medrano's gross and net disposable income for purposes of the California guideline child support calculation under Family Code § 4055 et seq. Harold K. Yamamoto, CPA/ABV/CFF, of Yamamoto Brace & Liu, LLP, has been identified as the forensic accountant for this purpose. Discovery directed at Medrano Visuals, LLC, including subpoenas for business bank statements, tax returns (including Form 1065 and Schedule K-1), profit and loss statements, and contract records, will be necessary.
Health Insurance. The minor children are currently covered under Ms. Fonseca's employer-sponsored health insurance plan through Veridian Health Insurance Co., provided as part of the Luminos Entertainment Group employee benefits program. The cost of the children's health insurance coverage and the allocation of uninsured and unreimbursed medical, dental, vision, and mental health expenses will be addressed in the child support order and/or stipulated agreement. The parenting plan should include provisions governing decision-making authority for non-emergency medical treatment and the selection of healthcare providers.
Travel and On-Location Work. Both parties' professions may require domestic and international travel, including extended periods of on-location work. This is particularly relevant for Mr. Medrano, whose work as a freelance cinematographer frequently requires multi-week on-location shoots in various locations. The parenting plan must include detailed provisions addressing on-location work contingencies, including advance notice requirements (minimum notice period to be negotiated), right of first refusal for additional custodial time during the traveling parent's absence, communication and video contact schedules during periods of parental travel, designation of approved caregivers or family members to care for the children in the traveling parent's absence, and travel consent and passport/documentation provisions for any international travel involving the children.
Additional Notes. The engagement team should be prepared for the possibility that Mr. Medrano's counsel may raise Ms. Fonseca's own professional travel and demanding work schedule as a factor in the custody analysis. The team should proactively develop a record of Ms. Fonseca's availability, flexibility, and the childcare arrangements she has maintained throughout the informal custodial period. Additionally, the team should be attentive to the children's developmental needs, given their young ages (6 and 3 at matter opening), and should ensure that all proposed custodial arrangements are consistent with age-appropriate parenting research and the best-interest-of-the-child standard under California Family Code § 3011.
SECTION 13: APPROVALS
The undersigned have reviewed this New Matter Intake Form and hereby approve the opening of Matter No. 1035-00002 (Fonseca Custody & Parenting Plan) and the commencement of the firm's representation of Marguerite Delphine Fonseca in connection with the matters described herein, subject to receipt of the executed engagement letter and retainer deposit.
Responsible Partner Approval
OLIVER MACKENZIE Responsible Partner
By: ________
Name: Oliver Mackenzie
Title: Partner, Mergers & Acquisitions
Date: ________
Billing Partner Approval
PRIYA ANAND Billing Partner
By: ________
Name: Priya Anand
Title: Partner, Litigation – General
Date: ________
Conflicts Counsel / General Counsel Clearance
CONFLICTS COUNSEL / GENERAL COUNSEL
By: ________
Name: ________
Title: ________
Date: ________
CALDERWOOD & HARKNESS LLP — Confidential — Internal Use Only Matter No. 1035-00002
Component | Amount
Base Salary | $485,000
Average Annual Discretionary Bonus (three-year average) | $210,000
Annual RSU Vesting (restricted stock units, Luminos Entertainment Group, Inc.) | $175,000
Total Estimated Annual Compensation | $870,000
Name | Role | Practice Group | Hourly Rate
Oliver Mackenzie | Responsible Partner (supervisory) | Mergers & Acquisitions | $925/hr
Priya Anand | Billing Partner | Litigation – General | $875/hr
Devon Archer | Lead Associate | Labor & Employment | $625/hr
Nadia Petrov | Working Associate | Labor & Employment | $485/hr
Role | Anticipated Provider | Notes
Custody Evaluator | To be determined by stipulation of the parties or court appointment | A custody evaluation pursuant to California Family Code § 3111 or Evidence Code § 730 is expected. The evaluator may be stipulated by the parties or appointed by the court. The engagement team will confer with opposing counsel regarding mutually acceptable candidates.
Forensic Accountant | Harold K. Yamamoto, CPA/ABV/CFF, of Yamamoto Brace & Liu, LLP, 333 South Grand Avenue, Suite 2800, Los Angeles, CA 90071 | Mr. Yamamoto will be engaged to perform an income analysis of Mr. Medrano's freelance earnings and his loan-out entity, Medrano Visuals, LLC, for purposes of the guideline child support calculation. The analysis will include review of personal and business tax returns, bank statements, 1099 forms, loan-out entity financial statements, and related records. Estimated flat fee: $14,750, subject to scope confirmation and engagement letter.
Mediator | To be proposed; private mediation is recommended | The engagement team recommends private mediation before a qualified family law mediator as the preferred method of dispute resolution. Candidates will be proposed to opposing counsel following initial case assessment and the completion of preliminary discovery.
Minor's Counsel | To be appointed by the court pursuant to California Family Code § 3150 | Appointment of counsel for the minor children is expected given the children's ages, the complexity of the custodial issues, and the parties' respective professional demands. The firm will support a motion for appointment or stipulate to appointment as appropriate.
Parenting Plan Coordinator | To be determined | Post-agreement appointment of a parenting plan coordinator is anticipated to assist the parties in implementing the terms of the parenting plan, resolving day-to-day scheduling disputes, and facilitating co-parenting communication. The coordinator will be identified and agreed upon as part of the stipulated agreement.
Target Date | Action Item
April 18, 2023 | Engagement letter executed by client; matter opened in firm's case management system; new matter intake form completed and submitted for partner and conflicts counsel approval.
April 20, 2023 (expected) | Receipt of $50,000 retainer deposit from client; deposit into firm IOLTA client trust account; confirmation of deposit to client and engagement team.
Late April 2023 | Initial case assessment and strategy memorandum prepared by Lead Associate; introductory letter to opposing counsel (Gwendolyn R. Kwan, Kwan, Delacroix & Samuels LLP); initial meet and confer regarding informal exchange of financial information and potential stipulations.
Early May 2023 | Preparation and filing of Request for Order (RFO) re Custody and Child Support in Case No. 22STFL09847, including supporting declarations, Income and Expense Declarations (Form FL-150), and proposed temporary custody schedule.
Late May 2023 | Hearing on RFO; pursuit of temporary (pendente lite) custody and visitation orders; potential referral to Family Court Services for mandatory mediation (if applicable).
June – July 2023 | Engagement of forensic accountant (Harold K. Yamamoto, CPA/ABV/CFF); commencement of income analysis; exchange of financial documents and discovery.
Mid-2023 | Custody evaluation (if ordered by the court or stipulated by the parties); evaluation expected to take approximately 60–90 days from commencement.
Late 2023 – Early 2024 | Mediation and settlement negotiations; drafting and negotiation of stipulated custody agreement, parenting plan, and child support agreement.
TBD | Execution of stipulated agreement; filing of stipulation for judgment; court approval and entry of judgment. If settlement is not achieved, preparation for contested hearing or trial.