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MEMORANDUM

PRIVILEGED AND CONFIDENTIAL — ATTORNEY WORK PRODUCT

TO: Priya Anand, Partner Oliver Mackenzie, Partner

FROM: Devon Archer, Lead Associate

DATE: January 22, 2024

RE: Fonseca Custody & Parenting Plan — Final Settlement Terms Summary Matter No. 1035-00002

CASE: In re Fonseca / Medrano, Case No. 22STFL09847 Superior Court of California, County of Los Angeles

CLIENT: Marguerite D. Fonseca

This memorandum is a privileged and confidential communication prepared by counsel in anticipation of litigation and in the course of providing legal advice to Marguerite D. Fonseca. It is protected by the attorney-client privilege, the work-product doctrine, and all other applicable privileges. It should not be disclosed to any person other than those identified on the distribution list without the prior written consent of the undersigned or a partner of Calderwood & Harkness LLP.

I. Purpose and Executive Summary

This memorandum provides a comprehensive summary of all final settlement terms agreed upon during Mediation Session 3, held on January 19, 2024, before the Honorable Constance M. Yee (Ret.) at Pacific Coast Dispute Resolution Services, 801 South Figueroa Street, Suite 1250, Los Angeles, California 90017. The purpose of this memorandum is to memorialize the substantive terms of the parties' agreement, to identify the documents that must now be drafted for execution and court filing, and to set forth the recommended next steps and timeline for bringing this matter to a conclusion.

The parties to this action are Marguerite D. Fonseca (Petitioner and our client) and Rafael J. Medrano (Respondent, represented by Gwendolyn R. Kwan, Esq., of Kwan, Delacroix & Samuels LLP, located at 1901 Avenue of the Stars, Suite 1100, Los Angeles, California 90067). At Mediation Session 3, the parties reached full agreement on all remaining open issues pertaining to the custody of their two minor children, the allocation of parenting time, child support, education and extracurricular cost-sharing, healthcare cost allocation, travel restrictions, and all ancillary matters. This full agreement followed substantial progress made at the prior two mediation sessions: Session 1 (November 17, 2023), during which the parties reached agreement in principle on the general framework for joint legal and physical custody and on the school-year timeshare; and Session 2 (December 15, 2023), during which the parties resolved the contested issue of tie-breaking authority on educational decisions and began negotiations on child support and cost-sharing provisions.

Minor's Counsel Tessa L. Brannigan, Esq. (California State Bar No. 267894), who was appointed on June 22, 2023, pursuant to California Family Code section 3150 to represent the interests of the children in this proceeding, was consulted throughout the mediation process. Ms. Brannigan was present at all three mediation sessions either in person or by telephone. She has indicated her preliminary approval of the final terms as consistent with the best interests of the children, Isabela Luz Fonseca-Medrano and Mateo Elías Fonseca-Medrano, and has stated that she anticipates filing a statement of non-opposition with the court upon review of the final execution documents.

The two minor children at issue in this matter are:

• Isabela Luz Fonseca-Medrano, born February 11, 2017 (age 6), currently enrolled in the first grade at Ridgeview Academy, 4515 Sepulveda Boulevard, Sherman Oaks, California 91403; and

• Mateo Elías Fonseca-Medrano, born August 29, 2019 (age 4), currently enrolled in the pre-kindergarten program at Ridgeview Academy.

Recommendation: It is my recommendation that we proceed immediately to drafting the execution version of the Stipulated Custody & Parenting Plan Agreement, the Child Support Agreement, and all exhibits and attachments referenced therein. The target execution date should be January 31, 2024. Upon execution by both parties and approval by Minor's Counsel, we should file the Stipulation for Judgment re Custody, Parenting Plan & Child Support with the Superior Court of California, County of Los Angeles, under seal consistent with the existing sealing order, and seek the court's approval and entry of the order as soon as practicable thereafter.

The balance of this memorandum sets forth the detailed terms of the settlement, organized by subject matter.

II. Procedural Background

The following procedural history provides context for the settlement terms summarized in this memorandum:

1. Domestic Partnership Registration. Marguerite D. Fonseca and Rafael J. Medrano registered a domestic partnership with the California Secretary of State on September 12, 2015 (California Secretary of State File No. DP-2015-038741). The parties did not subsequently marry.

2. Dissolution Petition. Ms. Fonseca filed a Petition for Dissolution of Domestic Partnership on July 8, 2022 (Case No. 22STFL09847, Superior Court of California, County of Los Angeles). Mr. Medrano filed his Response on August 19, 2022. At the time of the filing, the parties had been living separately since approximately May 2022.

3. Dissolution Judgment. A judgment of dissolution was entered by the court on November 3, 2022. The judgment dissolved the domestic partnership and resolved all property division issues by stipulation of the parties. However, the court expressly reserved jurisdiction over all issues relating to custody, visitation, and child support, as the parties had been unable to reach agreement on those issues at that time.

4. Engagement of Calderwood & Harkness LLP. Ms. Fonseca retained Calderwood & Harkness LLP on April 18, 2023, for the purpose of representing her in the remaining custody and child support matters. Prior counsel (Maria C. Orosco of Orosco Family Law, APLC) had represented Ms. Fonseca through the dissolution proceedings and withdrew upon entry of the dissolution judgment.

5. Request for Order (RFO). On May 2, 2023, we filed a Request for Order re Custody & Child Support on behalf of Ms. Fonseca, seeking primary physical custody, joint legal custody with educational tie-breaking authority, and an order of child support.

6. Temporary Custody Order. Following a hearing on May 30, 2023, the court entered a temporary custody order establishing a 60/40 timeshare in favor of Ms. Fonseca (approximately 219 overnights per year to Ms. Fonseca and 146 overnights per year to Mr. Medrano). The temporary order also established joint legal custody on an interim basis without designating tie-breaking authority on any category of decisions.

7. Appointment of Minor's Counsel. On June 22, 2023, the court appointed Tessa L. Brannigan, Esq. (California State Bar No. 267894), as Minor's Counsel pursuant to California Family Code section 3150 to represent the interests of both Isabela and Mateo in the custody proceedings.

8. Custody Evaluation. By stipulation of the parties, filed July 14, 2023, the court ordered a comprehensive custody evaluation pursuant to California Family Code section 3111. The court appointed Dr. Elena V. Sorensen, Psy.D. (California License No. PSY 24891), of Sorensen Family Behavioral Health, P.C., 2121 Avenue of the Stars, Suite 800, Los Angeles, California 90067, to conduct the evaluation. Dr. Sorensen completed her evaluation over a period of approximately eleven weeks, including individual interviews with both parents, observations of each parent with the children, collateral interviews, psychological testing, and a home study. Her evaluation report was delivered to the parties and the court on October 6, 2023. The report's conclusions and recommendations, which are detailed in our separate privileged analysis memorandum dated October 12, 2023, were generally favorable to Ms. Fonseca's position and provided substantial support for the terms ultimately agreed upon in mediation.

9. Stipulation and Order to Seal Court File. On July 14, 2023, the parties filed a joint Stipulation and Order to Seal Court File pursuant to California Rules of Court, Rule 2.550 et seq. The court granted the sealing order on the same date. All filings in this matter have been made under seal since that date.

10. Mediation. The three mediation sessions were held as follows:

• Session 1: November 17, 2023 (full day, approximately 8 hours)

• Session 2: December 15, 2023 (full day, approximately 9 hours)

• Session 3: January 19, 2024 (full day, approximately 10 hours)

All sessions were conducted before the Honorable Constance M. Yee (Ret.) at Pacific Coast Dispute Resolution Services. Full agreement was reached at the conclusion of Session 3, as summarized in the sections that follow.

III. Legal Custody

The parties have agreed to the following terms regarding legal custody of Isabela and Mateo:

Joint Legal Custody. Both parents shall share joint legal custody of Isabela Luz Fonseca-Medrano and Mateo Elías Fonseca-Medrano. This means that both Ms. Fonseca and Mr. Medrano shall have equal rights and responsibilities to make decisions relating to the health, education, and welfare of the children, subject to the specific provisions set forth below.

Tie-Breaking Authority on Educational Decisions. Ms. Fonseca shall have tie-breaking authority on all educational decisions affecting either or both children. This authority extends to, but is not limited to, decisions regarding school enrollment, school transfers, selection of schools (public or private), tutoring arrangements, special education services, educational testing, grade-level placement, and participation in school-sponsored programs. In the event that the parents are unable to agree on an educational decision after good-faith consultation and, if applicable, after consultation with the Parenting Plan Coordinator (discussed in Section XI below), Ms. Fonseca shall have the authority to make the final decision.

This provision was a key negotiating point throughout the mediation process and was one of the final issues resolved at Session 2. Mr. Medrano initially sought either equal tie-breaking authority (with disputes to be resolved by a neutral third party) or a rotating tie-breaking mechanism by which each parent would hold tie-breaking authority on educational decisions in alternating school years. After extensive discussion, Mr. Medrano ultimately agreed to vest tie-breaking authority exclusively in Ms. Fonseca. This concession was made on the basis of several factors: (i) Ms. Fonseca's role as the primary caretaker during school-year periods, during which she holds approximately 65% of custodial time; (ii) the recommendation in Dr. Sorensen's custody evaluation report, which noted that Ms. Fonseca had historically been the parent more involved in the children's educational planning and school-related activities; and (iii) the practical consideration that educational decisions frequently require timely action, making a single decision-maker more efficient than a rotating or shared mechanism.

All Other Major Decisions. All other major decisions affecting the children — including but not limited to decisions regarding medical treatment (non-emergency), dental care, mental health treatment, religious upbringing, and extracurricular activities — shall be made jointly by the parents. In the event of a disagreement regarding any such decision, the parties shall first consult with the Parenting Plan Coordinator (Dr. Marcus W. Ingalls, as discussed in Section XI below) before seeking relief from the court. Neither parent shall have unilateral decision-making authority on any category of major decisions other than education, as specifically provided above.

Emergency Decisions. Notwithstanding the foregoing, either parent may make emergency decisions regarding the children's health and safety without the prior consent of the other parent, provided that the parent making the emergency decision notifies the other parent as soon as reasonably practicable following the emergency.

IV. Physical Custody and Timeshare

A. General Structure

The parties have agreed to joint physical custody of Isabela and Mateo, with primary residence designated with Ms. Fonseca. The children's primary residential address shall be Ms. Fonseca's current residence at 1742 Laurel Canyon Boulevard, Unit 3A, Studio City, California 91604. This address shall be used for school enrollment and all official purposes unless otherwise agreed in writing by both parties.

Mr. Medrano's current residential address is 609 Moorpark Street, Apartment 12, North Hollywood, California 91602. Both residences are located within the attendance area for Ridgeview Academy and within reasonable proximity to one another (approximately 3.8 miles by car), which facilitates the exchange schedule described below.

B. School-Year Schedule

During the regular school year (defined as the period from the first day of the Ridgeview Academy academic calendar through the last day of the academic calendar, excluding the summer break period), the timeshare shall be approximately 65% Ms. Fonseca / 35% Mr. Medrano. The specific weekly schedule to be set forth in the Parenting Plan Agreement will include the following general framework:

• Ms. Fonseca shall have custody on Monday, Tuesday, and Wednesday overnights each week.

• Mr. Medrano shall have custody on Thursday overnight each week (the midweek overnight).

• Weekends shall alternate, with each parent receiving custody from Friday after school (or 3:00 p.m. on non-school days) through Monday morning school drop-off (or 8:30 a.m. on non-school days).

• On Mr. Medrano's non-weekend weeks, his custodial time shall consist of the Thursday overnight only.

This schedule yields approximately 192 overnights to Ms. Fonseca and approximately 103 overnights to Mr. Medrano during the approximately 295 school-year days (42 school-year weeks), which corresponds to the agreed 65/35 timeshare during the school year. The specific details, including exchange times, locations, and protocols, will be set forth in the execution version of the Parenting Plan Agreement.

C. Summer Schedule

During the 10-week summer break (approximately 70 days), custodial time shall be split 50/50, with each parent receiving 35 overnights. The summer schedule shall be implemented as follows:

• Each parent shall select blocks of time in increments of no fewer than 5 consecutive days and no more than 14 consecutive days.

• Selection of summer weeks shall occur by alternating priority: Ms. Fonseca shall select first in odd-numbered years (2025, 2027, etc.), and Mr. Medrano shall select first in even-numbered years (2024, 2026, etc.).

• Each parent shall submit their summer schedule selections to the other parent by April 1 of each year. If a parent fails to submit selections by April 1, the other parent shall have the right to make selections for both parties, subject to the 50/50 requirement.

• The summer schedule shall be finalized by mutual agreement no later than May 1 of each year.

D. Effective Annual Totals

Taking into account both the school-year schedule and the summer schedule, the effective annual timeshare is as follows:

These annual totals incorporate the approximately 65/35 school-year split (192 Fonseca / 103 Medrano during 295 school-year days) and the 50/50 summer split (35 / 35 during 70 summer days), yielding combined figures of 227 + approximately 5 additional overnights attributable to holiday adjustments for Ms. Fonseca, and 133 for Mr. Medrano. The precise figures will be confirmed in the final Parenting Plan Agreement once the holiday and vacation rotation (discussed immediately below) is fully calendared, but the parties have agreed that the annual totals shall be approximately as stated above.

E. Holiday and Vacation Rotation

The parties have agreed to an alternating annual holiday and vacation schedule, to be set forth in detail as Exhibit A to the Parenting Plan Agreement. The general framework is as follows:

• Thanksgiving: The Thanksgiving holiday period shall run from the Wednesday before Thanksgiving (after school or 3:00 p.m.) through the following Sunday at 6:00 p.m. The parties shall alternate Thanksgiving in even and odd years, with Ms. Fonseca having Thanksgiving in odd years and Mr. Medrano having Thanksgiving in even years.

• Winter Break: The winter break shall be divided into two approximately equal portions: the first portion (beginning on the last day of school before winter break through December 25 at 12:00 p.m.) and the second portion (December 25 at 12:00 p.m. through the day before school resumes). The parents shall alternate the first and second portions annually.

• Spring Break: The spring break period shall alternate annually, with Ms. Fonseca having spring break in even years and Mr. Medrano having spring break in odd years.

• Designated Holidays: Each parent shall have the children on that parent's designated holidays each year (e.g., Mother's Day with Ms. Fonseca; Father's Day with Mr. Medrano; each parent's birthday with that parent; and the children's birthdays to be alternated or shared as specified in Exhibit A).

All pick-up and drop-off times and locations for holidays and vacations shall be specified in Exhibit A. The holiday schedule shall take precedence over the regular weekly schedule when the two conflict.

V. Child Support

A. Income Figures Used for Calculation

The child support calculation is based on the following income figures, which were agreed upon by the parties during the mediation process after review of the financial disclosures, tax returns, and the forensic income analysis:

Ms. Fonseca's Gross Monthly Income: $72,500 ($870,000 annual total compensation ÷ 12). Ms. Fonseca is employed as Senior Vice President, Original Content Development, at Luminos Entertainment Group, Inc., located in Burbank, California. Her total annual compensation is comprised of the following components:

• Base salary: $485,000 per year

• Average annual discretionary bonus: $210,000 per year (based on the three-year average of actual bonuses received for fiscal years 2021, 2022, and 2023)

• Annual restricted stock unit (RSU) vesting: approximately $175,000 per year (based on the current vesting schedule and stock price as of the date of the mediation)

Mr. Medrano's Imputed Gross Monthly Income: $28,333 ($340,000 three-year average annual income ÷ 12). Mr. Medrano derives his income from freelance cinematography and director of photography work in the motion picture and television industry, conducted through his loan-out entity, Medrano Visuals, LLC (a California limited liability company). Due to the variable and project-based nature of Mr. Medrano's income, the parties agreed to use a three-year average annual income figure derived from the forensic income analysis completed by Harold K. Yamamoto, CPA/ABV/CFF, of Yamamoto Brace & Liu, LLP. Mr. Yamamoto's analysis, delivered on September 22, 2023, examined Mr. Medrano's tax returns, bank statements, and 1099 income for calendar years 2020, 2021, and 2022, and concluded that Mr. Medrano's average annual gross income for the three-year period was approximately $340,000. This figure was not contested by Mr. Medrano's counsel at mediation.

Combined Gross Monthly Income: $100,833 ($72,500 + $28,333).

B. Guideline Calculation

The guideline child support amount was calculated using the DissoMaster software program, which is the standard computer program used in California courts for determining guideline child support under California Family Code sections 4055 through 4060. The inputs for the calculation were as follows:

• Number of children: 2

• Ms. Fonseca's gross monthly income: $72,500

• Mr. Medrano's gross monthly income: $28,333

• Timeshare: 63.6% Ms. Fonseca / 36.4% Mr. Medrano (based on 232 overnights to Ms. Fonseca and 133 overnights to Mr. Medrano)

• Tax filing status: both parties filing as Head of Household (one child claimed as dependent by each parent, per the existing tax allocation agreement in the dissolution judgment)

Based on these inputs, the DissoMaster calculation yields a guideline child support amount of $1,274 per month, payable by Ms. Fonseca to Mr. Medrano. It should be noted that despite Ms. Fonseca's significantly higher income ($72,500/month versus $28,333/month), the guideline support amount is moderated substantially by her majority timeshare. Under the California guideline formula, the higher-earning parent's support obligation is reduced in proportion to the amount of time the children spend in that parent's custody, because the higher-earning parent is already directly bearing a greater share of the children's living expenses during the majority of the year.

C. Agreed Deviation from Guideline

The parties agreed to a child support amount of $1,100 per month, payable by Ms. Fonseca to Mr. Medrano. This amount represents a deviation of $174 per month below the guideline amount ($1,274 − $1,100 = $174), or approximately 13.7% below guideline.

The legal basis for this deviation is California Family Code section 4057(b), which permits the court to approve a child support amount that deviates from the guideline where the deviation is justified by the circumstances of the case and is in the best interests of the children. Here, the deviation is justified by Mr. Medrano's agreement to bear a disproportionately higher share of extracurricular and enrichment costs for the children (60% Medrano / 40% Fonseca, as detailed in Section VI.B below). This cost-sharing allocation effectively offsets the below-guideline base support amount, such that the overall package of financial support — including base child support, tuition cost-sharing, extracurricular cost-sharing, and healthcare cost-sharing — meets or exceeds the children's reasonable needs as contemplated by the guideline.

As noted in our memorandum to file dated November 1, 2023, a deviation of $174 per month (approximately 13.7% below guideline) is well within the range that California courts routinely approve, particularly where, as here, the deviation is offset by other financial contributions and the overall support package is adequate to meet the children's needs. We do not anticipate any objection from the court or from Minor's Counsel on this point.

Child support shall be payable on the first day of each month, commencing on the first day of the month following entry of the court order. Payments shall be made by electronic funds transfer directly to an account designated by Mr. Medrano, unless the parties agree to an alternative payment method.

D. Annual Adjustment Provision

The child support amount shall be subject to review on the anniversary of the court order or upon a material change in circumstances. For purposes of this provision, a "material change in circumstances" is defined as:

(a) A change in either parent's gross annual income exceeding 15% (increase or decrease) from the income figure used in the most recent support calculation; or

(b) A change in the custodial timeshare exceeding 10% (i.e., a shift of more than approximately 36.5 overnights per year) from the timeshare used in the most recent support calculation.

Either parent may request a review of child support upon the occurrence of a material change in circumstances by providing written notice to the other parent. If the parties are unable to agree on a modified support amount, either party may seek relief from the court.

VI. Education and Extracurricular Costs

A. Tuition — Ridgeview Academy

Both children are currently enrolled at Ridgeview Academy, located at 4515 Sepulveda Boulevard, Sherman Oaks, California 91403. The parties have agreed that both children shall continue to attend Ridgeview Academy for the foreseeable future, subject to the joint legal custody provisions regarding educational decisions (including Ms. Fonseca's tie-breaking authority) set forth in Section III above. The current annual tuition for each child is as follows:

The parties have agreed to share tuition costs on a 70% Ms. Fonseca / 30% Mr. Medrano basis. The resulting annual obligations are as follows:

Tuition payments shall be made directly to Ridgeview Academy in accordance with the school's billing schedule. Each parent shall be responsible for ensuring that their respective share of tuition is paid on time. In the event that either parent fails to make a timely tuition payment, the other parent may advance the payment and seek reimbursement from the non-paying parent within 30 days.

Any future change of school for either child shall require the mutual written agreement of both parents, subject to Ms. Fonseca's educational tie-breaking authority under the joint legal custody provisions set forth in Section III above. In the event that a school change results in a change in tuition costs, the 70/30 cost-sharing ratio shall continue to apply to the new tuition amount unless the parties agree otherwise in writing.

B. Extracurricular and Enrichment Activities

Costs for extracurricular and enrichment activities — including but not limited to sports leagues, music lessons, art classes, language instruction, tutoring, and summer camps — shall be split 60% Mr. Medrano / 40% Ms. Fonseca for activities costing up to $1,500 per child per quarter (i.e., per calendar quarter). This cost-sharing ratio applies to the aggregate cost of all extracurricular activities for each child, not to each individual activity.

Any extracurricular or enrichment activity whose cost, when combined with other extracurricular costs for the same child in the same quarter, would cause the total to exceed the $1,500 per child per quarter cap shall require the mutual written consent of both parents before either parent is obligated to contribute to the cost. A parent who enrolls a child in an extracurricular activity without the other parent's consent, where the cost exceeds the quarterly cap, shall bear the full cost of that activity.

This cost-sharing allocation, which shifts a disproportionately greater share of extracurricular costs to Mr. Medrano (60%) relative to his share of income (approximately 28% of the combined income), was the agreed basis for the $174 per month deviation below guideline child support. The parties and their respective counsel acknowledged during mediation that this allocation effectively compensates for the below-guideline support amount and ensures that the children's extracurricular and enrichment needs are adequately funded.

VII. Healthcare and Medical Expenses

A. Health Insurance

The children shall remain enrolled on Ms. Fonseca's employer-sponsored health insurance plan through Luminos Entertainment Group, Inc. The current plan is administered by Veridian Health Insurance Co. and provides comprehensive medical, dental, and vision coverage for dependents. Ms. Fonseca shall be responsible for maintaining health insurance coverage for both children at all times and shall provide proof of current coverage to Mr. Medrano on an annual basis, or upon request, within 10 business days.

In the event that Ms. Fonseca's employer-sponsored health insurance plan becomes unavailable or materially changes in scope or cost, the parties shall confer in good faith regarding alternative coverage options. Any change in the children's health insurance coverage shall require the mutual agreement of both parents, consistent with the joint legal custody provisions regarding medical decisions.

B. Unreimbursed Medical, Dental, Orthodontic, and Mental Health Expenses

All unreimbursed and out-of-pocket medical, dental, orthodontic, and mental health expenses for the children — including but not limited to co-pays, deductibles, prescription costs, therapy sessions, and any other healthcare costs not covered by the children's health insurance plan — shall be shared 70% Ms. Fonseca / 30% Mr. Medrano. This cost-sharing ratio is consistent with the parties' approximate relative income shares ($72,500 / $100,833 ≈ 71.9% for Ms. Fonseca; $28,333 / $100,833 ≈ 28.1% for Mr. Medrano) and is also consistent with the tuition cost-sharing ratio.

Each parent shall submit receipts, Explanation of Benefits (EOB) statements, and other supporting documentation for unreimbursed medical costs to the other parent within 30 calendar days of incurring the expense. The parent receiving such documentation shall reimburse the other parent for their share of the expense within 30 calendar days of receipt of the documentation. Failure to submit documentation within the 30-day period shall not constitute a waiver of the right to reimbursement, but the submitting parent shall make reasonable efforts to comply with the deadline.

VIII. Travel Provisions

A. International Travel

Neither parent shall take either child outside the continental United States without providing 30 days' prior written notice to the other parent and obtaining the other parent's written consent. Written notice shall include the destination, dates of travel, mode of transportation, accommodations, and contact information for the traveling parent during the trip. If the non-traveling parent does not consent to the proposed international travel, either parent may seek a court order authorizing or prohibiting the travel. The children's passports shall be held jointly, with the physical passport documents maintained at Ms. Fonseca's residence and made available to Mr. Medrano upon request for approved international travel.

B. Domestic Travel Outside California

Either parent may take the children on domestic travel outside the State of California during that parent's custodial time, provided that the traveling parent provides 14 days' prior written notice to the other parent. Written notice shall include the destination, dates of travel, mode of transportation, and contact information for the traveling parent during the trip. Domestic travel within the State of California during a parent's custodial time does not require advance notice, although each parent shall ensure that the other parent is able to reach the children by telephone or video call at all times.

C. On-Location Work Provision

This provision addresses a central issue in this matter, given the nature of Mr. Medrano's career as a freelance cinematographer and director of photography. Mr. Medrano's work frequently requires travel to film sets at distant locations for extended periods. The parties' separation was precipitated in significant part by Mr. Medrano's acceptance of a seven-week on-location shoot in Vancouver, British Columbia, in February 2023, during which Ms. Fonseca assumed sole care of both children without advance planning or agreement. The filing of the initial RFO in this matter was substantially motivated by the disruption to the children's routine caused by that absence.

To address this issue on a going-forward basis, the parties have agreed to the following reciprocal provisions:

(a) Mr. Medrano. If Mr. Medrano accepts work requiring travel of more than 14 consecutive calendar days, his custodial time during those days shall transfer to Ms. Fonseca. Mr. Medrano shall provide Ms. Fonseca with written notice of such travel as soon as practicable, and in no event fewer than 14 days before departure. Upon Mr. Medrano's return, make-up custodial time shall be scheduled within 60 calendar days of his return, in consultation with the other parent and, if necessary, with the assistance of the Parenting Plan Coordinator.

(b) Ms. Fonseca. Reciprocally, if Ms. Fonseca's work requires travel exceeding 14 consecutive calendar days, her custodial time during those days shall transfer to Mr. Medrano, with the same 60-day make-up window and the same notice requirements.

The 14-day threshold was selected as a reasonable balance between the parents' professional obligations and the children's need for stability and routine. Shorter work-related absences (14 days or fewer) do not trigger the automatic transfer provision but are subject to the right of first refusal provisions described in Section VIII.D below.

D. Detail in Exhibit B

The full travel notice protocol, including specific notice formats, permissible methods of communication, and timelines, shall be set forth in Exhibit B to the Parenting Plan Agreement. Exhibit B shall also include the right of first refusal provisions agreed upon by the parties. The right of first refusal shall be triggered when a parent is unavailable to care for the children for more than 8 consecutive hours during that parent's custodial time (excluding time the children are in school or otherwise in an organized childcare or educational setting). Before arranging for a third-party caregiver (other than a regularly employed nanny or babysitter), the custodial parent shall offer the non-custodial parent the opportunity to care for the children during the period of unavailability. The non-custodial parent shall have 2 hours to accept or decline the offer.

IX. Confidentiality and Non-Disparagement

The parties have agreed to include a mutual non-disparagement and confidentiality clause in the Stipulated Custody & Parenting Plan Agreement. The key terms of this provision are as follows:

Non-Disparagement. Neither party shall make disparaging, derogatory, or defamatory statements about the other party in the presence of the children, to the children's teachers, coaches, or healthcare providers, or in any public forum, including social media platforms. Each parent shall use best efforts to foster a positive and respectful relationship between the children and the other parent.

Confidentiality. Neither party shall disclose the financial terms of the agreement, the contents of the custody evaluation report prepared by Dr. Sorensen, or the substance of the mediation discussions to any third party, except as follows:

(a) Disclosure to each party's legal counsel, tax advisors, financial advisors, or mental health professionals, provided that such professionals agree to maintain the confidentiality of the disclosed information;

(b) Disclosure as required by valid court order or subpoena;

(d) Disclosure with the prior written consent of the other party.

This confidentiality provision reflects the particular circumstances of both parties as public-facing professionals in the entertainment industry. Ms. Fonseca, as Senior Vice President of Original Content Development at Luminos Entertainment Group, Inc., maintains a significant professional profile within the entertainment industry. Mr. Medrano, as a freelance cinematographer and director of photography who works on feature films and episodic television, similarly has a public-facing career. Both parties have expressed strong concerns about the potential for public disclosure of the terms of their custody and financial arrangements, and both have identified the children's privacy interests as paramount. The confidentiality provision is designed to protect those interests while permitting reasonable disclosures necessary for the administration of the parties' legal, tax, and financial affairs.

X. Court Sealing Order

The court file in this matter has been sealed pursuant to California Rules of Court, Rule 2.550 et seq. The Stipulation and Order to Seal Court File was filed by the parties on July 14, 2023, and was granted by the court on the same date. The sealing order covers all documents filed in the case, including but not limited to the dissolution petition, the RFO, the custody evaluation report, financial declarations, and all other pleadings and filings.

The final Stipulated Custody & Parenting Plan Agreement, the Child Support Agreement, and all exhibits and attachments thereto shall be filed under seal consistent with the existing sealing order. No additional sealing motion should be required, as the existing order broadly covers all filings in the case. However, we will confirm with the court clerk's office that the existing order is sufficient to cover the new filings and, if necessary, will file a supplemental stipulation to extend the sealing order to specifically encompass the final stipulated agreement.

XI. Parenting Plan Coordinator

Appointment. The parties have agreed to appoint Dr. Marcus W. Ingalls, LMFT (California License No. LMFT 89412), of Ingalls & Cuevas Family Counseling, located at 10880 Wilshire Boulevard, Suite 630, Los Angeles, California 90024, as the Parenting Plan Coordinator for the parties and the children.

Role and Scope. Dr. Ingalls's role shall be to assist the parties in resolving day-to-day parenting disputes and implementation questions arising under the Parenting Plan without resort to the court. His scope of authority includes, but is not limited to, the following:

(a) Providing non-binding recommendations to the parties regarding scheduling conflicts, including adjustments to the regular custody schedule necessitated by work travel, illness, school events, or other circumstances;

(b) Facilitating communication between the parties regarding parenting issues, including the development of effective co-parenting communication strategies;

(c) Assisting the parties in resolving disputes regarding the interpretation or implementation of specific provisions of the Parenting Plan;

(d) Making non-binding recommendations regarding minor modifications to the custodial schedule that do not alter the overall timeshare by more than 5%; and

(e) Providing referrals to family therapists, child psychologists, or other professionals as appropriate.

Limitations. The Parenting Plan Coordinator shall not have the authority to modify the court order, to alter the legal or physical custody designations, to change the overall timeshare allocation, or to make any binding decisions on behalf of the parties. The Parenting Plan Coordinator's recommendations are advisory only. If the parties are unable to resolve a dispute through the Parenting Plan Coordinator, either party may seek relief from the court.

Costs. The costs of the Parenting Plan Coordinator, including Dr. Ingalls's professional fees and any associated administrative costs, shall be split equally (50/50) between the parties, unless the parties agree otherwise in writing. Dr. Ingalls's current hourly rate is $350 per hour, and each party shall be responsible for paying their 50% share directly to Dr. Ingalls in accordance with his billing practices.

Term. The Parenting Plan Coordinator's appointment shall continue for an initial term of two years from the date of entry of the court order, subject to renewal by mutual agreement of the parties. Either party may request the replacement of the Parenting Plan Coordinator upon a showing of good cause, subject to the agreement of the other party or an order of the court.

XII. Summary of Financial Obligations

The following table summarizes the principal financial obligations of each party under the agreed settlement terms:

The extracurricular cost-sharing arrangement (60% Medrano / 40% Fonseca), which shifts a greater relative burden to Mr. Medrano, serves as the primary justification for the agreed $174/month below-guideline child support deviation. Taken as a whole, the financial package provides adequate support for the children's needs across all categories — basic living expenses, education, healthcare, and enrichment activities — and is consistent with the standard of living the children have enjoyed during both parents' domestic partnership and since the separation.

XIII. Next Steps and Recommendations

A. Document Drafting

I recommend that we proceed immediately to drafting the following execution documents, with a target completion date for internal review of January 26, 2024, and a target execution date of January 31, 2024:

1. Stipulated Custody & Parenting Plan Agreement (execution version) — incorporating all terms summarized in Sections III through XI of this memorandum, together with standard boilerplate provisions regarding modification, enforcement, governing law, and integration.

2. Child Support Agreement — to be attached as an exhibit or addendum to the Stipulated Custody & Parenting Plan Agreement, setting forth the agreed child support amount, payment terms, and the annual adjustment provision.

3. Exhibit A — Holiday & Vacation Schedule — a detailed calendar-based schedule specifying the holiday and vacation rotation for odd and even years, including exchange times, locations, and protocols.

4. Exhibit B — Right of First Refusal & Travel Notice Protocol — setting forth the right of first refusal procedures (8-hour trigger, 2-hour response window) and the travel notice requirements for international, domestic, and on-location work travel.

5. Stipulation for Judgment re Custody, Parenting Plan & Child Support — the formal stipulation to be filed with the Superior Court of California, County of Los Angeles, requesting the court's approval and entry of the stipulated agreement as a court order.

Upon completion of internal review, I recommend that we transmit execution copies of all documents to Kwan, Delacroix & Samuels LLP (attention: Gwendolyn R. Kwan, Esq.) for Mr. Medrano's review and signature. We should request that Mr. Medrano's counsel return executed copies within five business days of transmittal.

B. Minor's Counsel Approval

We should coordinate with Minor's Counsel Tessa L. Brannigan to provide her with drafts of the execution documents for review and to obtain her written statement of non-opposition or approval of the final terms. This statement should be obtained prior to or concurrent with court filing. Based on Ms. Brannigan's preliminary indication of approval at the conclusion of Mediation Session 3, I do not anticipate any substantive objections. However, we should provide her with sufficient time to review the documents carefully and to consult with Isabela and Mateo (to the extent age-appropriate) before issuing her formal statement.

C. Court Filing and Entry of Order

Upon execution of all documents by both parties and receipt of Minor's Counsel's statement of non-opposition or approval, we should promptly file the Stipulation for Judgment re Custody, Parenting Plan & Child Support with the Superior Court of California, County of Los Angeles (Stanley Mosk Courthouse, 111 North Hill Street, Los Angeles, California 90012). All documents shall be filed under seal, consistent with the existing sealing order entered July 14, 2023.

We should request that the court enter the order as soon as practicable following filing. In my experience, stipulated custody orders in the Los Angeles Superior Court are typically processed and entered within 10 to 15 business days of filing, absent any issues identified by the court upon review. We may wish to file a cover letter or declaration requesting expedited processing given the parties' mutual desire for prompt resolution.

D. Post-Order Implementation

Upon entry of the court order, the following implementation steps should be taken:

1. Client Letter. We should provide Ms. Fonseca with a detailed letter summarizing the final terms of the court order and her obligations thereunder, including payment deadlines for child support, tuition cost-sharing, and other financial obligations.

2. Introduction of Parenting Plan Coordinator. We should facilitate an introduction between the Parenting Plan Coordinator (Dr. Marcus W. Ingalls) and both parties, ideally through a joint initial session to be scheduled within 30 days of entry of the order.

3. Financial Implementation. We should initiate the adjustment of child support payments, tuition cost-sharing, and other financial obligations to become effective upon entry of the court order. This may include coordination with Ms. Fonseca's payroll department and with Ridgeview Academy's billing office to establish the appropriate payment arrangements.

4. Confirmation of Filed Order. Upon receipt of the filed and endorsed court order, we should distribute conformed copies to Ms. Fonseca, to Mr. Medrano's counsel, and to Minor's Counsel.

5. Matter Closing. Upon receipt and distribution of the filed order, we should confirm matter closing procedures with the partners, including the preparation of a closing letter to Ms. Fonseca, the archiving of the matter file, and the processing of any final billing.

XIV. Fee Status

Total fees billed to date and the estimated remaining work through execution, filing, and court entry will be addressed in a separate billing memorandum. However, I note the following for the partners' reference:

Retainer and Billing. A retainer deposit of $50,000 was received from Ms. Fonseca on April 20, 2023. All billing in this matter has been on an hourly basis pursuant to the engagement letter dated April 18, 2023. The applicable hourly rates for this matter are as follows:

Estimated Total Fees. At the time of engagement, the estimated total fees for this matter were $120,000 to $175,000. The matter is currently tracking within the estimated range. I anticipate that the remaining work — including drafting of execution documents, review and revision cycles with opposing counsel, coordination with Minor's Counsel, court filing, and post-order implementation — will require approximately 30 to 45 additional hours of attorney time, which should keep the matter within the upper end of the estimated range.

Costs Advanced. The following costs have been advanced to date on behalf of Ms. Fonseca:

All costs have been billed to Ms. Fonseca in accordance with the terms of the engagement letter.

Please let me know if you have any questions or comments regarding any of the foregoing, or if you would like me to proceed with drafting the execution documents on the timeline set forth above.

Respectfully submitted,

DEVON ARCHER Lead Associate Calderwood & Harkness LLP 1800 Century Park East, Suite 2400 Los Angeles, California 90067 Telephone: (310) 556-8200

Email: darcher@calderwoodharkness.com

California State Bar No. 318472

Date: January 22, 2024

Distribution:

Priya Anand, Partner — Calderwood & Harkness LLP Oliver Mackenzie, Partner — Calderwood & Harkness LLP

cc:

Nadia Petrov, Working Associate — Calderwood & Harkness LLP

Matter File: 1035-00002

PRIVILEGED AND CONFIDENTIAL — ATTORNEY WORK PRODUCT This document and the information contained herein are privileged and confidential, intended solely for the use of the addressees listed above. If you have received this document in error, please notify the sender immediately and destroy all copies. Unauthorized disclosure, copying, distribution, or use of this document or the information contained herein is strictly prohibited.

Parent	Annual Overnights	Percentage of Year
Ms. Fonseca	232 overnights	63.6% (232 ÷ 365)
Mr. Medrano	133 overnights	36.4% (133 ÷ 365)
Total	365 overnights	100%
Child	Program	Annual Tuition
Isabela Luz Fonseca-Medrano	First Grade	$32,400
Mateo Elías Fonseca-Medrano	Pre-Kindergarten	$26,800
Total	$59,200
Child	Annual Tuition	Ms. Fonseca (70%)	Mr. Medrano (30%)
Isabela	$32,400	$22,680	$9,720
Mateo	$26,800	$18,760	$8,040
Total	$59,200	$41,440	$17,760
Category	Ms. Fonseca	Mr. Medrano	Notes
Child Support	$1,100/month ($13,200/year) payable to Mr. Medrano	Receives $1,100/month ($13,200/year)	$174/month below guideline; deviation per FC § 4057(b)
Tuition — Ridgeview Academy	$41,440/year (70%)	$17,760/year (30%)	Total annual tuition: $59,200
Extracurricular Activities	40% of costs up to $1,500/child/quarter	60% of costs up to $1,500/child/quarter	Costs above cap require mutual consent
Unreimbursed Medical Expenses	70%	30%	Receipts within 30 days; reimbursement within 30 days
Health Insurance Premiums	100% (employer-sponsored plan)	0%	Veridian Health Insurance Co. through Luminos Entertainment Group
Parenting Coordinator Fees	50%	50%	Dr. Ingalls at $350/hour
Timekeeper	Rate
Oliver Mackenzie, Partner	$925/hour
Priya Anand, Partner	$875/hour
Devon Archer, Lead Associate	$625/hour
Nadia Petrov, Working Associate	$485/hour
Cost Category	Amount

Client's share of custody evaluation (Dr. Sorensen)	$9,250
Forensic accountant fee (Yamamoto Brace & Liu, LLP)	$14,750
Mediator fees (Pacific Coast Dispute Resolution Services — 3 sessions)	$6,825
Filing fees, service of process, copying, and miscellaneous costs	$7,650
Total Costs Advanced	$38,475

MEMORANDUM
PRIVILEGED AND CONFIDENTIAL — ATTORNEY WORK PRODUCT
TO: Priya Anand, Partner Oliver Mackenzie, Partner
FROM: Devon Archer, Lead Associate
DATE: January 22, 2024
RE: Fonseca Custody & Parenting Plan — Final Settlement Terms Summary Matter No. 1035-00002
CASE: In re Fonseca / Medrano, Case No. 22STFL09847 Superior Court of California, County of Los Angeles
CLIENT: Marguerite D. Fonseca
This memorandum is a privileged and confidential communication prepared by counsel in anticipation of litigation and in the course of providing legal advice to Marguerite D. Fonseca. It is protected by the attorney-client privilege, the work-product doctrine, and all other applicable privileges. It should not be disclosed to any person other than those identified on the distribution list without the prior written consent of the undersigned or a partner of Calderwood & Harkness LLP.
I. Purpose and Executive Summary
This memorandum provides a comprehensive summary of all final settlement terms agreed upon during Mediation Session 3, held on January 19, 2024, before the Honorable Constance M. Yee (Ret.) at Pacific Coast Dispute Resolution Services, 801 South Figueroa Street, Suite 1250, Los Angeles, California 90017. The purpose of this memorandum is to memorialize the substantive terms of the parties' agreement, to identify the documents that must now be drafted for execution and court filing, and to set forth the recommended next steps and timeline for bringing this matter to a conclusion.
The parties to this action are Marguerite D. Fonseca (Petitioner and our client) and Rafael J. Medrano (Respondent, represented by Gwendolyn R. Kwan, Esq., of Kwan, Delacroix & Samuels LLP, located at 1901 Avenue of the Stars, Suite 1100, Los Angeles, California 90067). At Mediation Session 3, the parties reached full agreement on all remaining open issues pertaining to the custody of their two minor children, the allocation of parenting time, child support, education and extracurricular cost-sharing, healthcare cost allocation, travel restrictions, and all ancillary matters. This full agreement followed substantial progress made at the prior two mediation sessions: Session 1 (November 17, 2023), during which the parties reached agreement in principle on the general framework for joint legal and physical custody and on the school-year timeshare; and Session 2 (December 15, 2023), during which the parties resolved the contested issue of tie-breaking authority on educational decisions and began negotiations on child support and cost-sharing provisions.
Minor's Counsel Tessa L. Brannigan, Esq. (California State Bar No. 267894), who was appointed on June 22, 2023, pursuant to California Family Code section 3150 to represent the interests of the children in this proceeding, was consulted throughout the mediation process. Ms. Brannigan was present at all three mediation sessions either in person or by telephone. She has indicated her preliminary approval of the final terms as consistent with the best interests of the children, Isabela Luz Fonseca-Medrano and Mateo Elías Fonseca-Medrano, and has stated that she anticipates filing a statement of non-opposition with the court upon review of the final execution documents.
The two minor children at issue in this matter are:
•  Isabela Luz Fonseca-Medrano, born February 11, 2017 (age 6), currently enrolled in the first grade at Ridgeview Academy, 4515 Sepulveda Boulevard, Sherman Oaks, California 91403; and
•  Mateo Elías Fonseca-Medrano, born August 29, 2019 (age 4), currently enrolled in the pre-kindergarten program at Ridgeview Academy.
Recommendation: It is my recommendation that we proceed immediately to drafting the execution version of the Stipulated Custody & Parenting Plan Agreement, the Child Support Agreement, and all exhibits and attachments referenced therein. The target execution date should be January 31, 2024. Upon execution by both parties and approval by Minor's Counsel, we should file the Stipulation for Judgment re Custody, Parenting Plan & Child Support with the Superior Court of California, County of Los Angeles, under seal consistent with the existing sealing order, and seek the court's approval and entry of the order as soon as practicable thereafter.
The balance of this memorandum sets forth the detailed terms of the settlement, organized by subject matter.
II. Procedural Background
The following procedural history provides context for the settlement terms summarized in this memorandum:
1.  Domestic Partnership Registration. Marguerite D. Fonseca and Rafael J. Medrano registered a domestic partnership with the California Secretary of State on September 12, 2015 (California Secretary of State File No. DP-2015-038741). The parties did not subsequently marry.
2.  Dissolution Petition. Ms. Fonseca filed a Petition for Dissolution of Domestic Partnership on July 8, 2022 (Case No. 22STFL09847, Superior Court of California, County of Los Angeles). Mr. Medrano filed his Response on August 19, 2022. At the time of the filing, the parties had been living separately since approximately May 2022.
3.  Dissolution Judgment. A judgment of dissolution was entered by the court on November 3, 2022. The judgment dissolved the domestic partnership and resolved all property division issues by stipulation of the parties. However, the court expressly reserved jurisdiction over all issues relating to custody, visitation, and child support, as the parties had been unable to reach agreement on those issues at that time.
4.  Engagement of Calderwood & Harkness LLP. Ms. Fonseca retained Calderwood & Harkness LLP on April 18, 2023, for the purpose of representing her in the remaining custody and child support matters. Prior counsel (Maria C. Orosco of Orosco Family Law, APLC) had represented Ms. Fonseca through the dissolution proceedings and withdrew upon entry of the dissolution judgment.
5.  Request for Order (RFO). On May 2, 2023, we filed a Request for Order re Custody & Child Support on behalf of Ms. Fonseca, seeking primary physical custody, joint legal custody with educational tie-breaking authority, and an order of child support.
6.  Temporary Custody Order. Following a hearing on May 30, 2023, the court entered a temporary custody order establishing a 60/40 timeshare in favor of Ms. Fonseca (approximately 219 overnights per year to Ms. Fonseca and 146 overnights per year to Mr. Medrano). The temporary order also established joint legal custody on an interim basis without designating tie-breaking authority on any category of decisions.
7.  Appointment of Minor's Counsel. On June 22, 2023, the court appointed Tessa L. Brannigan, Esq. (California State Bar No. 267894), as Minor's Counsel pursuant to California Family Code section 3150 to represent the interests of both Isabela and Mateo in the custody proceedings.
8.  Custody Evaluation. By stipulation of the parties, filed July 14, 2023, the court ordered a comprehensive custody evaluation pursuant to California Family Code section 3111. The court appointed Dr. Elena V. Sorensen, Psy.D. (California License No. PSY 24891), of Sorensen Family Behavioral Health, P.C., 2121 Avenue of the Stars, Suite 800, Los Angeles, California 90067, to conduct the evaluation. Dr. Sorensen completed her evaluation over a period of approximately eleven weeks, including individual interviews with both parents, observations of each parent with the children, collateral interviews, psychological testing, and a home study. Her evaluation report was delivered to the parties and the court on October 6, 2023. The report's conclusions and recommendations, which are detailed in our separate privileged analysis memorandum dated October 12, 2023, were generally favorable to Ms. Fonseca's position and provided substantial support for the terms ultimately agreed upon in mediation.
9.  Stipulation and Order to Seal Court File. On July 14, 2023, the parties filed a joint Stipulation and Order to Seal Court File pursuant to California Rules of Court, Rule 2.550 et seq. The court granted the sealing order on the same date. All filings in this matter have been made under seal since that date.
10.  Mediation. The three mediation sessions were held as follows:
•  Session 1: November 17, 2023 (full day, approximately 8 hours)
•  Session 2: December 15, 2023 (full day, approximately 9 hours)
•  Session 3: January 19, 2024 (full day, approximately 10 hours)
All sessions were conducted before the Honorable Constance M. Yee (Ret.) at Pacific Coast Dispute Resolution Services. Full agreement was reached at the conclusion of Session 3, as summarized in the sections that follow.
III. Legal Custody
The parties have agreed to the following terms regarding legal custody of Isabela and Mateo:
Joint Legal Custody. Both parents shall share joint legal custody of Isabela Luz Fonseca-Medrano and Mateo Elías Fonseca-Medrano. This means that both Ms. Fonseca and Mr. Medrano shall have equal rights and responsibilities to make decisions relating to the health, education, and welfare of the children, subject to the specific provisions set forth below.
Tie-Breaking Authority on Educational Decisions. Ms. Fonseca shall have tie-breaking authority on all educational decisions affecting either or both children. This authority extends to, but is not limited to, decisions regarding school enrollment, school transfers, selection of schools (public or private), tutoring arrangements, special education services, educational testing, grade-level placement, and participation in school-sponsored programs. In the event that the parents are unable to agree on an educational decision after good-faith consultation and, if applicable, after consultation with the Parenting Plan Coordinator (discussed in Section XI below), Ms. Fonseca shall have the authority to make the final decision.
This provision was a key negotiating point throughout the mediation process and was one of the final issues resolved at Session 2. Mr. Medrano initially sought either equal tie-breaking authority (with disputes to be resolved by a neutral third party) or a rotating tie-breaking mechanism by which each parent would hold tie-breaking authority on educational decisions in alternating school years. After extensive discussion, Mr. Medrano ultimately agreed to vest tie-breaking authority exclusively in Ms. Fonseca. This concession was made on the basis of several factors: (i) Ms. Fonseca's role as the primary caretaker during school-year periods, during which she holds approximately 65% of custodial time; (ii) the recommendation in Dr. Sorensen's custody evaluation report, which noted that Ms. Fonseca had historically been the parent more involved in the children's educational planning and school-related activities; and (iii) the practical consideration that educational decisions frequently require timely action, making a single decision-maker more efficient than a rotating or shared mechanism.
All Other Major Decisions. All other major decisions affecting the children — including but not limited to decisions regarding medical treatment (non-emergency), dental care, mental health treatment, religious upbringing, and extracurricular activities — shall be made jointly by the parents. In the event of a disagreement regarding any such decision, the parties shall first consult with the Parenting Plan Coordinator (Dr. Marcus W. Ingalls, as discussed in Section XI below) before seeking relief from the court. Neither parent shall have unilateral decision-making authority on any category of major decisions other than education, as specifically provided above.
Emergency Decisions. Notwithstanding the foregoing, either parent may make emergency decisions regarding the children's health and safety without the prior consent of the other parent, provided that the parent making the emergency decision notifies the other parent as soon as reasonably practicable following the emergency.
IV. Physical Custody and Timeshare
A. General Structure
The parties have agreed to joint physical custody of Isabela and Mateo, with primary residence designated with Ms. Fonseca. The children's primary residential address shall be Ms. Fonseca's current residence at 1742 Laurel Canyon Boulevard, Unit 3A, Studio City, California 91604. This address shall be used for school enrollment and all official purposes unless otherwise agreed in writing by both parties.
Mr. Medrano's current residential address is 609 Moorpark Street, Apartment 12, North Hollywood, California 91602. Both residences are located within the attendance area for Ridgeview Academy and within reasonable proximity to one another (approximately 3.8 miles by car), which facilitates the exchange schedule described below.
B. School-Year Schedule
During the regular school year (defined as the period from the first day of the Ridgeview Academy academic calendar through the last day of the academic calendar, excluding the summer break period), the timeshare shall be approximately 65% Ms. Fonseca / 35% Mr. Medrano. The specific weekly schedule to be set forth in the Parenting Plan Agreement will include the following general framework:
•  Ms. Fonseca shall have custody on Monday, Tuesday, and Wednesday overnights each week.
•  Mr. Medrano shall have custody on Thursday overnight each week (the midweek overnight).
•  Weekends shall alternate, with each parent receiving custody from Friday after school (or 3:00 p.m. on non-school days) through Monday morning school drop-off (or 8:30 a.m. on non-school days).
•  On Mr. Medrano's non-weekend weeks, his custodial time shall consist of the Thursday overnight only.
This schedule yields approximately 192 overnights to Ms. Fonseca and approximately 103 overnights to Mr. Medrano during the approximately 295 school-year days (42 school-year weeks), which corresponds to the agreed 65/35 timeshare during the school year. The specific details, including exchange times, locations, and protocols, will be set forth in the execution version of the Parenting Plan Agreement.
C. Summer Schedule
During the 10-week summer break (approximately 70 days), custodial time shall be split 50/50, with each parent receiving 35 overnights. The summer schedule shall be implemented as follows:
•  Each parent shall select blocks of time in increments of no fewer than 5 consecutive days and no more than 14 consecutive days.
•  Selection of summer weeks shall occur by alternating priority: Ms. Fonseca shall select first in odd-numbered years (2025, 2027, etc.), and Mr. Medrano shall select first in even-numbered years (2024, 2026, etc.).
•  Each parent shall submit their summer schedule selections to the other parent by April 1 of each year. If a parent fails to submit selections by April 1, the other parent shall have the right to make selections for both parties, subject to the 50/50 requirement.
•  The summer schedule shall be finalized by mutual agreement no later than May 1 of each year.
D. Effective Annual Totals
Taking into account both the school-year schedule and the summer schedule, the effective annual timeshare is as follows:
These annual totals incorporate the approximately 65/35 school-year split (192 Fonseca / 103 Medrano during 295 school-year days) and the 50/50 summer split (35 / 35 during 70 summer days), yielding combined figures of 227 + approximately 5 additional overnights attributable to holiday adjustments for Ms. Fonseca, and 133 for Mr. Medrano. The precise figures will be confirmed in the final Parenting Plan Agreement once the holiday and vacation rotation (discussed immediately below) is fully calendared, but the parties have agreed that the annual totals shall be approximately as stated above.
E. Holiday and Vacation Rotation
The parties have agreed to an alternating annual holiday and vacation schedule, to be set forth in detail as Exhibit A to the Parenting Plan Agreement. The general framework is as follows:
•  Thanksgiving: The Thanksgiving holiday period shall run from the Wednesday before Thanksgiving (after school or 3:00 p.m.) through the following Sunday at 6:00 p.m. The parties shall alternate Thanksgiving in even and odd years, with Ms. Fonseca having Thanksgiving in odd years and Mr. Medrano having Thanksgiving in even years.
•  Winter Break: The winter break shall be divided into two approximately equal portions: the first portion (beginning on the last day of school before winter break through December 25 at 12:00 p.m.) and the second portion (December 25 at 12:00 p.m. through the day before school resumes). The parents shall alternate the first and second portions annually.
•  Spring Break: The spring break period shall alternate annually, with Ms. Fonseca having spring break in even years and Mr. Medrano having spring break in odd years.
•  Designated Holidays: Each parent shall have the children on that parent's designated holidays each year (e.g., Mother's Day with Ms. Fonseca; Father's Day with Mr. Medrano; each parent's birthday with that parent; and the children's birthdays to be alternated or shared as specified in Exhibit A).
All pick-up and drop-off times and locations for holidays and vacations shall be specified in Exhibit A. The holiday schedule shall take precedence over the regular weekly schedule when the two conflict.
V. Child Support
A. Income Figures Used for Calculation
The child support calculation is based on the following income figures, which were agreed upon by the parties during the mediation process after review of the financial disclosures, tax returns, and the forensic income analysis:
Ms. Fonseca's Gross Monthly Income: $72,500 ($870,000 annual total compensation ÷ 12). Ms. Fonseca is employed as Senior Vice President, Original Content Development, at Luminos Entertainment Group, Inc., located in Burbank, California. Her total annual compensation is comprised of the following components:
•  Base salary: $485,000 per year
•  Average annual discretionary bonus: $210,000 per year (based on the three-year average of actual bonuses received for fiscal years 2021, 2022, and 2023)
•  Annual restricted stock unit (RSU) vesting: approximately $175,000 per year (based on the current vesting schedule and stock price as of the date of the mediation)
Mr. Medrano's Imputed Gross Monthly Income: $28,333 ($340,000 three-year average annual income ÷ 12). Mr. Medrano derives his income from freelance cinematography and director of photography work in the motion picture and television industry, conducted through his loan-out entity, Medrano Visuals, LLC (a California limited liability company). Due to the variable and project-based nature of Mr. Medrano's income, the parties agreed to use a three-year average annual income figure derived from the forensic income analysis completed by Harold K. Yamamoto, CPA/ABV/CFF, of Yamamoto Brace & Liu, LLP. Mr. Yamamoto's analysis, delivered on September 22, 2023, examined Mr. Medrano's tax returns, bank statements, and 1099 income for calendar years 2020, 2021, and 2022, and concluded that Mr. Medrano's average annual gross income for the three-year period was approximately $340,000. This figure was not contested by Mr. Medrano's counsel at mediation.
Combined Gross Monthly Income: $100,833 ($72,500 + $28,333).
B. Guideline Calculation
The guideline child support amount was calculated using the DissoMaster software program, which is the standard computer program used in California courts for determining guideline child support under California Family Code sections 4055 through 4060. The inputs for the calculation were as follows:
•  Number of children: 2
•  Ms. Fonseca's gross monthly income: $72,500
•  Mr. Medrano's gross monthly income: $28,333
•  Timeshare: 63.6% Ms. Fonseca / 36.4% Mr. Medrano (based on 232 overnights to Ms. Fonseca and 133 overnights to Mr. Medrano)
•  Tax filing status: both parties filing as Head of Household (one child claimed as dependent by each parent, per the existing tax allocation agreement in the dissolution judgment)
Based on these inputs, the DissoMaster calculation yields a guideline child support amount of $1,274 per month, payable by Ms. Fonseca to Mr. Medrano. It should be noted that despite Ms. Fonseca's significantly higher income ($72,500/month versus $28,333/month), the guideline support amount is moderated substantially by her majority timeshare. Under the California guideline formula, the higher-earning parent's support obligation is reduced in proportion to the amount of time the children spend in that parent's custody, because the higher-earning parent is already directly bearing a greater share of the children's living expenses during the majority of the year.
C. Agreed Deviation from Guideline
The parties agreed to a child support amount of $1,100 per month, payable by Ms. Fonseca to Mr. Medrano. This amount represents a deviation of $174 per month below the guideline amount ($1,274 − $1,100 = $174), or approximately 13.7% below guideline.
The legal basis for this deviation is California Family Code section 4057(b), which permits the court to approve a child support amount that deviates from the guideline where the deviation is justified by the circumstances of the case and is in the best interests of the children. Here, the deviation is justified by Mr. Medrano's agreement to bear a disproportionately higher share of extracurricular and enrichment costs for the children (60% Medrano / 40% Fonseca, as detailed in Section VI.B below). This cost-sharing allocation effectively offsets the below-guideline base support amount, such that the overall package of financial support — including base child support, tuition cost-sharing, extracurricular cost-sharing, and healthcare cost-sharing — meets or exceeds the children's reasonable needs as contemplated by the guideline.
As noted in our memorandum to file dated November 1, 2023, a deviation of $174 per month (approximately 13.7% below guideline) is well within the range that California courts routinely approve, particularly where, as here, the deviation is offset by other financial contributions and the overall support package is adequate to meet the children's needs. We do not anticipate any objection from the court or from Minor's Counsel on this point.
Child support shall be payable on the first day of each month, commencing on the first day of the month following entry of the court order. Payments shall be made by electronic funds transfer directly to an account designated by Mr. Medrano, unless the parties agree to an alternative payment method.
D. Annual Adjustment Provision
The child support amount shall be subject to review on the anniversary of the court order or upon a material change in circumstances. For purposes of this provision, a "material change in circumstances" is defined as:
(a) A change in either parent's gross annual income exceeding 15% (increase or decrease) from the income figure used in the most recent support calculation; or
(b) A change in the custodial timeshare exceeding 10% (i.e., a shift of more than approximately 36.5 overnights per year) from the timeshare used in the most recent support calculation.
Either parent may request a review of child support upon the occurrence of a material change in circumstances by providing written notice to the other parent. If the parties are unable to agree on a modified support amount, either party may seek relief from the court.
VI. Education and Extracurricular Costs
A. Tuition — Ridgeview Academy
Both children are currently enrolled at Ridgeview Academy, located at 4515 Sepulveda Boulevard, Sherman Oaks, California 91403. The parties have agreed that both children shall continue to attend Ridgeview Academy for the foreseeable future, subject to the joint legal custody provisions regarding educational decisions (including Ms. Fonseca's tie-breaking authority) set forth in Section III above. The current annual tuition for each child is as follows:
The parties have agreed to share tuition costs on a 70% Ms. Fonseca / 30% Mr. Medrano basis. The resulting annual obligations are as follows:
Tuition payments shall be made directly to Ridgeview Academy in accordance with the school's billing schedule. Each parent shall be responsible for ensuring that their respective share of tuition is paid on time. In the event that either parent fails to make a timely tuition payment, the other parent may advance the payment and seek reimbursement from the non-paying parent within 30 days.
Any future change of school for either child shall require the mutual written agreement of both parents, subject to Ms. Fonseca's educational tie-breaking authority under the joint legal custody provisions set forth in Section III above. In the event that a school change results in a change in tuition costs, the 70/30 cost-sharing ratio shall continue to apply to the new tuition amount unless the parties agree otherwise in writing.
B. Extracurricular and Enrichment Activities
Costs for extracurricular and enrichment activities — including but not limited to sports leagues, music lessons, art classes, language instruction, tutoring, and summer camps — shall be split 60% Mr. Medrano / 40% Ms. Fonseca for activities costing up to $1,500 per child per quarter (i.e., per calendar quarter). This cost-sharing ratio applies to the aggregate cost of all extracurricular activities for each child, not to each individual activity.
Any extracurricular or enrichment activity whose cost, when combined with other extracurricular costs for the same child in the same quarter, would cause the total to exceed the $1,500 per child per quarter cap shall require the mutual written consent of both parents before either parent is obligated to contribute to the cost. A parent who enrolls a child in an extracurricular activity without the other parent's consent, where the cost exceeds the quarterly cap, shall bear the full cost of that activity.
This cost-sharing allocation, which shifts a disproportionately greater share of extracurricular costs to Mr. Medrano (60%) relative to his share of income (approximately 28% of the combined income), was the agreed basis for the $174 per month deviation below guideline child support. The parties and their respective counsel acknowledged during mediation that this allocation effectively compensates for the below-guideline support amount and ensures that the children's extracurricular and enrichment needs are adequately funded.
VII. Healthcare and Medical Expenses
A. Health Insurance
The children shall remain enrolled on Ms. Fonseca's employer-sponsored health insurance plan through Luminos Entertainment Group, Inc. The current plan is administered by Veridian Health Insurance Co. and provides comprehensive medical, dental, and vision coverage for dependents. Ms. Fonseca shall be responsible for maintaining health insurance coverage for both children at all times and shall provide proof of current coverage to Mr. Medrano on an annual basis, or upon request, within 10 business days.
In the event that Ms. Fonseca's employer-sponsored health insurance plan becomes unavailable or materially changes in scope or cost, the parties shall confer in good faith regarding alternative coverage options. Any change in the children's health insurance coverage shall require the mutual agreement of both parents, consistent with the joint legal custody provisions regarding medical decisions.
B. Unreimbursed Medical, Dental, Orthodontic, and Mental Health Expenses
All unreimbursed and out-of-pocket medical, dental, orthodontic, and mental health expenses for the children — including but not limited to co-pays, deductibles, prescription costs, therapy sessions, and any other healthcare costs not covered by the children's health insurance plan — shall be shared 70% Ms. Fonseca / 30% Mr. Medrano. This cost-sharing ratio is consistent with the parties' approximate relative income shares ($72,500 / $100,833 ≈ 71.9% for Ms. Fonseca; $28,333 / $100,833 ≈ 28.1% for Mr. Medrano) and is also consistent with the tuition cost-sharing ratio.
Each parent shall submit receipts, Explanation of Benefits (EOB) statements, and other supporting documentation for unreimbursed medical costs to the other parent within 30 calendar days of incurring the expense. The parent receiving such documentation shall reimburse the other parent for their share of the expense within 30 calendar days of receipt of the documentation. Failure to submit documentation within the 30-day period shall not constitute a waiver of the right to reimbursement, but the submitting parent shall make reasonable efforts to comply with the deadline.
VIII. Travel Provisions
A. International Travel
Neither parent shall take either child outside the continental United States without providing 30 days' prior written notice to the other parent and obtaining the other parent's written consent. Written notice shall include the destination, dates of travel, mode of transportation, accommodations, and contact information for the traveling parent during the trip. If the non-traveling parent does not consent to the proposed international travel, either parent may seek a court order authorizing or prohibiting the travel. The children's passports shall be held jointly, with the physical passport documents maintained at Ms. Fonseca's residence and made available to Mr. Medrano upon request for approved international travel.
B. Domestic Travel Outside California
Either parent may take the children on domestic travel outside the State of California during that parent's custodial time, provided that the traveling parent provides 14 days' prior written notice to the other parent. Written notice shall include the destination, dates of travel, mode of transportation, and contact information for the traveling parent during the trip. Domestic travel within the State of California during a parent's custodial time does not require advance notice, although each parent shall ensure that the other parent is able to reach the children by telephone or video call at all times.
C. On-Location Work Provision
This provision addresses a central issue in this matter, given the nature of Mr. Medrano's career as a freelance cinematographer and director of photography. Mr. Medrano's work frequently requires travel to film sets at distant locations for extended periods. The parties' separation was precipitated in significant part by Mr. Medrano's acceptance of a seven-week on-location shoot in Vancouver, British Columbia, in February 2023, during which Ms. Fonseca assumed sole care of both children without advance planning or agreement. The filing of the initial RFO in this matter was substantially motivated by the disruption to the children's routine caused by that absence.
To address this issue on a going-forward basis, the parties have agreed to the following reciprocal provisions:
(a) Mr. Medrano. If Mr. Medrano accepts work requiring travel of more than 14 consecutive calendar days, his custodial time during those days shall transfer to Ms. Fonseca. Mr. Medrano shall provide Ms. Fonseca with written notice of such travel as soon as practicable, and in no event fewer than 14 days before departure. Upon Mr. Medrano's return, make-up custodial time shall be scheduled within 60 calendar days of his return, in consultation with the other parent and, if necessary, with the assistance of the Parenting Plan Coordinator.
(b) Ms. Fonseca. Reciprocally, if Ms. Fonseca's work requires travel exceeding 14 consecutive calendar days, her custodial time during those days shall transfer to Mr. Medrano, with the same 60-day make-up window and the same notice requirements.
The 14-day threshold was selected as a reasonable balance between the parents' professional obligations and the children's need for stability and routine. Shorter work-related absences (14 days or fewer) do not trigger the automatic transfer provision but are subject to the right of first refusal provisions described in Section VIII.D below.
D. Detail in Exhibit B
The full travel notice protocol, including specific notice formats, permissible methods of communication, and timelines, shall be set forth in Exhibit B to the Parenting Plan Agreement. Exhibit B shall also include the right of first refusal provisions agreed upon by the parties. The right of first refusal shall be triggered when a parent is unavailable to care for the children for more than 8 consecutive hours during that parent's custodial time (excluding time the children are in school or otherwise in an organized childcare or educational setting). Before arranging for a third-party caregiver (other than a regularly employed nanny or babysitter), the custodial parent shall offer the non-custodial parent the opportunity to care for the children during the period of unavailability. The non-custodial parent shall have 2 hours to accept or decline the offer.
IX. Confidentiality and Non-Disparagement
The parties have agreed to include a mutual non-disparagement and confidentiality clause in the Stipulated Custody & Parenting Plan Agreement. The key terms of this provision are as follows:
Non-Disparagement. Neither party shall make disparaging, derogatory, or defamatory statements about the other party in the presence of the children, to the children's teachers, coaches, or healthcare providers, or in any public forum, including social media platforms. Each parent shall use best efforts to foster a positive and respectful relationship between the children and the other parent.
Confidentiality. Neither party shall disclose the financial terms of the agreement, the contents of the custody evaluation report prepared by Dr. Sorensen, or the substance of the mediation discussions to any third party, except as follows:
(a) Disclosure to each party's legal counsel, tax advisors, financial advisors, or mental health professionals, provided that such professionals agree to maintain the confidentiality of the disclosed information;
(b) Disclosure as required by valid court order or subpoena;
(c) Disclosure as required by law or regulation; or
(d) Disclosure with the prior written consent of the other party.
This confidentiality provision reflects the particular circumstances of both parties as public-facing professionals in the entertainment industry. Ms. Fonseca, as Senior Vice President of Original Content Development at Luminos Entertainment Group, Inc., maintains a significant professional profile within the entertainment industry. Mr. Medrano, as a freelance cinematographer and director of photography who works on feature films and episodic television, similarly has a public-facing career. Both parties have expressed strong concerns about the potential for public disclosure of the terms of their custody and financial arrangements, and both have identified the children's privacy interests as paramount. The confidentiality provision is designed to protect those interests while permitting reasonable disclosures necessary for the administration of the parties' legal, tax, and financial affairs.
X. Court Sealing Order
The court file in this matter has been sealed pursuant to California Rules of Court, Rule 2.550 et seq. The Stipulation and Order to Seal Court File was filed by the parties on July 14, 2023, and was granted by the court on the same date. The sealing order covers all documents filed in the case, including but not limited to the dissolution petition, the RFO, the custody evaluation report, financial declarations, and all other pleadings and filings.
The final Stipulated Custody & Parenting Plan Agreement, the Child Support Agreement, and all exhibits and attachments thereto shall be filed under seal consistent with the existing sealing order. No additional sealing motion should be required, as the existing order broadly covers all filings in the case. However, we will confirm with the court clerk's office that the existing order is sufficient to cover the new filings and, if necessary, will file a supplemental stipulation to extend the sealing order to specifically encompass the final stipulated agreement.
XI. Parenting Plan Coordinator
Appointment. The parties have agreed to appoint Dr. Marcus W. Ingalls, LMFT (California License No. LMFT 89412), of Ingalls & Cuevas Family Counseling, located at 10880 Wilshire Boulevard, Suite 630, Los Angeles, California 90024, as the Parenting Plan Coordinator for the parties and the children.
Role and Scope. Dr. Ingalls's role shall be to assist the parties in resolving day-to-day parenting disputes and implementation questions arising under the Parenting Plan without resort to the court. His scope of authority includes, but is not limited to, the following:
(a) Providing non-binding recommendations to the parties regarding scheduling conflicts, including adjustments to the regular custody schedule necessitated by work travel, illness, school events, or other circumstances;
(b) Facilitating communication between the parties regarding parenting issues, including the development of effective co-parenting communication strategies;
(c) Assisting the parties in resolving disputes regarding the interpretation or implementation of specific provisions of the Parenting Plan;
(d) Making non-binding recommendations regarding minor modifications to the custodial schedule that do not alter the overall timeshare by more than 5%; and
(e) Providing referrals to family therapists, child psychologists, or other professionals as appropriate.
Limitations. The Parenting Plan Coordinator shall not have the authority to modify the court order, to alter the legal or physical custody designations, to change the overall timeshare allocation, or to make any binding decisions on behalf of the parties. The Parenting Plan Coordinator's recommendations are advisory only. If the parties are unable to resolve a dispute through the Parenting Plan Coordinator, either party may seek relief from the court.
Costs. The costs of the Parenting Plan Coordinator, including Dr. Ingalls's professional fees and any associated administrative costs, shall be split equally (50/50) between the parties, unless the parties agree otherwise in writing. Dr. Ingalls's current hourly rate is $350 per hour, and each party shall be responsible for paying their 50% share directly to Dr. Ingalls in accordance with his billing practices.
Term. The Parenting Plan Coordinator's appointment shall continue for an initial term of two years from the date of entry of the court order, subject to renewal by mutual agreement of the parties. Either party may request the replacement of the Parenting Plan Coordinator upon a showing of good cause, subject to the agreement of the other party or an order of the court.
XII. Summary of Financial Obligations
The following table summarizes the principal financial obligations of each party under the agreed settlement terms:
The extracurricular cost-sharing arrangement (60% Medrano / 40% Fonseca), which shifts a greater relative burden to Mr. Medrano, serves as the primary justification for the agreed $174/month below-guideline child support deviation. Taken as a whole, the financial package provides adequate support for the children's needs across all categories — basic living expenses, education, healthcare, and enrichment activities — and is consistent with the standard of living the children have enjoyed during both parents' domestic partnership and since the separation.
XIII. Next Steps and Recommendations
A. Document Drafting
I recommend that we proceed immediately to drafting the following execution documents, with a target completion date for internal review of January 26, 2024, and a target execution date of January 31, 2024:
1.  Stipulated Custody & Parenting Plan Agreement (execution version) — incorporating all terms summarized in Sections III through XI of this memorandum, together with standard boilerplate provisions regarding modification, enforcement, governing law, and integration.
2.  Child Support Agreement — to be attached as an exhibit or addendum to the Stipulated Custody & Parenting Plan Agreement, setting forth the agreed child support amount, payment terms, and the annual adjustment provision.
3.  Exhibit A — Holiday & Vacation Schedule — a detailed calendar-based schedule specifying the holiday and vacation rotation for odd and even years, including exchange times, locations, and protocols.
4.  Exhibit B — Right of First Refusal & Travel Notice Protocol — setting forth the right of first refusal procedures (8-hour trigger, 2-hour response window) and the travel notice requirements for international, domestic, and on-location work travel.
5.  Stipulation for Judgment re Custody, Parenting Plan & Child Support — the formal stipulation to be filed with the Superior Court of California, County of Los Angeles, requesting the court's approval and entry of the stipulated agreement as a court order.
Upon completion of internal review, I recommend that we transmit execution copies of all documents to Kwan, Delacroix & Samuels LLP (attention: Gwendolyn R. Kwan, Esq.) for Mr. Medrano's review and signature. We should request that Mr. Medrano's counsel return executed copies within five business days of transmittal.
B. Minor's Counsel Approval
We should coordinate with Minor's Counsel Tessa L. Brannigan to provide her with drafts of the execution documents for review and to obtain her written statement of non-opposition or approval of the final terms. This statement should be obtained prior to or concurrent with court filing. Based on Ms. Brannigan's preliminary indication of approval at the conclusion of Mediation Session 3, I do not anticipate any substantive objections. However, we should provide her with sufficient time to review the documents carefully and to consult with Isabela and Mateo (to the extent age-appropriate) before issuing her formal statement.
C. Court Filing and Entry of Order
Upon execution of all documents by both parties and receipt of Minor's Counsel's statement of non-opposition or approval, we should promptly file the Stipulation for Judgment re Custody, Parenting Plan & Child Support with the Superior Court of California, County of Los Angeles (Stanley Mosk Courthouse, 111 North Hill Street, Los Angeles, California 90012). All documents shall be filed under seal, consistent with the existing sealing order entered July 14, 2023.
We should request that the court enter the order as soon as practicable following filing. In my experience, stipulated custody orders in the Los Angeles Superior Court are typically processed and entered within 10 to 15 business days of filing, absent any issues identified by the court upon review. We may wish to file a cover letter or declaration requesting expedited processing given the parties' mutual desire for prompt resolution.
D. Post-Order Implementation
Upon entry of the court order, the following implementation steps should be taken:
1.  Client Letter. We should provide Ms. Fonseca with a detailed letter summarizing the final terms of the court order and her obligations thereunder, including payment deadlines for child support, tuition cost-sharing, and other financial obligations.
2.  Introduction of Parenting Plan Coordinator. We should facilitate an introduction between the Parenting Plan Coordinator (Dr. Marcus W. Ingalls) and both parties, ideally through a joint initial session to be scheduled within 30 days of entry of the order.
3.  Financial Implementation. We should initiate the adjustment of child support payments, tuition cost-sharing, and other financial obligations to become effective upon entry of the court order. This may include coordination with Ms. Fonseca's payroll department and with Ridgeview Academy's billing office to establish the appropriate payment arrangements.
4.  Confirmation of Filed Order. Upon receipt of the filed and endorsed court order, we should distribute conformed copies to Ms. Fonseca, to Mr. Medrano's counsel, and to Minor's Counsel.
5.  Matter Closing. Upon receipt and distribution of the filed order, we should confirm matter closing procedures with the partners, including the preparation of a closing letter to Ms. Fonseca, the archiving of the matter file, and the processing of any final billing.
XIV. Fee Status
Total fees billed to date and the estimated remaining work through execution, filing, and court entry will be addressed in a separate billing memorandum. However, I note the following for the partners' reference:
Retainer and Billing. A retainer deposit of $50,000 was received from Ms. Fonseca on April 20, 2023. All billing in this matter has been on an hourly basis pursuant to the engagement letter dated April 18, 2023. The applicable hourly rates for this matter are as follows:
Estimated Total Fees. At the time of engagement, the estimated total fees for this matter were $120,000 to $175,000. The matter is currently tracking within the estimated range. I anticipate that the remaining work — including drafting of execution documents, review and revision cycles with opposing counsel, coordination with Minor's Counsel, court filing, and post-order implementation — will require approximately 30 to 45 additional hours of attorney time, which should keep the matter within the upper end of the estimated range.
Costs Advanced. The following costs have been advanced to date on behalf of Ms. Fonseca:
All costs have been billed to Ms. Fonseca in accordance with the terms of the engagement letter.
Please let me know if you have any questions or comments regarding any of the foregoing, or if you would like me to proceed with drafting the execution documents on the timeline set forth above.
Respectfully submitted,
DEVON ARCHER Lead Associate Calderwood & Harkness LLP 1800 Century Park East, Suite 2400 Los Angeles, California 90067 Telephone: (310) 556-8200
Email: darcher@calderwoodharkness.com
California State Bar No. 318472
Date: January 22, 2024
Distribution:
Priya Anand, Partner — Calderwood & Harkness LLP Oliver Mackenzie, Partner — Calderwood & Harkness LLP
cc:
Nadia Petrov, Working Associate — Calderwood & Harkness LLP
Matter File: 1035-00002
PRIVILEGED AND CONFIDENTIAL — ATTORNEY WORK PRODUCT This document and the information contained herein are privileged and confidential, intended solely for the use of the addressees listed above. If you have received this document in error, please notify the sender immediately and destroy all copies. Unauthorized disclosure, copying, distribution, or use of this document or the information contained herein is strictly prohibited.
Parent | Annual Overnights | Percentage of Year
Ms. Fonseca | 232 overnights | 63.6% (232 ÷ 365)
Mr. Medrano | 133 overnights | 36.4% (133 ÷ 365)
Total | 365 overnights | 100%
Child | Program | Annual Tuition
Isabela Luz Fonseca-Medrano | First Grade | $32,400
Mateo Elías Fonseca-Medrano | Pre-Kindergarten | $26,800
Total | $59,200
Child | Annual Tuition | Ms. Fonseca (70%) | Mr. Medrano (30%)
Isabela | $32,400 | $22,680 | $9,720
Mateo | $26,800 | $18,760 | $8,040
Total | $59,200 | $41,440 | $17,760
Category | Ms. Fonseca | Mr. Medrano | Notes
Child Support | $1,100/month ($13,200/year) payable to Mr. Medrano | Receives $1,100/month ($13,200/year) | $174/month below guideline; deviation per FC § 4057(b)
Tuition — Ridgeview Academy | $41,440/year (70%) | $17,760/year (30%) | Total annual tuition: $59,200
Extracurricular Activities | 40% of costs up to $1,500/child/quarter | 60% of costs up to $1,500/child/quarter | Costs above cap require mutual consent
Unreimbursed Medical Expenses | 70% | 30% | Receipts within 30 days; reimbursement within 30 days
Health Insurance Premiums | 100% (employer-sponsored plan) | 0% | Veridian Health Insurance Co. through Luminos Entertainment Group
Parenting Coordinator Fees | 50% | 50% | Dr. Ingalls at $350/hour
Timekeeper | Rate
Oliver Mackenzie, Partner | $925/hour
Priya Anand, Partner | $875/hour
Devon Archer, Lead Associate | $625/hour
Nadia Petrov, Working Associate | $485/hour
Cost Category | Amount
Client's share of custody evaluation (Dr. Sorensen) | $9,250
Forensic accountant fee (Yamamoto Brace & Liu, LLP) | $14,750
Mediator fees (Pacific Coast Dispute Resolution Services — 3 sessions) | $6,825
Filing fees, service of process, copying, and miscellaneous costs | $7,650
Total Costs Advanced | $38,475

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