California Court of Appeal

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Marriage of Woolsey, C067800

Judgment enforcing the parties' marital settlement agreement is affirmed, where: 1) parties who agree to settle their disputes by private mediation may also agree to make financial disclosures that do not meet the technical procedural requirements of Family Code sections 2104 and 2105; 2) Local Rule 30.7 is invalid insofar as it imposes additional requirements on a mediated settlement agreement beyond those specified by statute; 3) the record reveals husband received a full and fair trial; 4) husband forfeited the right to further mediation or arbitration of the issues; 5) the mediation confidentiality imposed by Evidence Code section 1119 undermines husband's arguments regarding undue influence and there is no presumption of undue influence in a marital settlement agreement reached as the result of mediation; 6) husband's failure to provide any legal authority that supports his deceit argument forfeits the issue on appeal; 7) husband's challenges to the custody and visitation terms in the judgment do not establish an abuse of discretion by the trial court; and 8) the trial court's statement of decision is adequate in addressing the issues presented for trial.

Appellate Information

  • Decided 10/22/2013
  • Published 10/22/2013


  • HOCH


  • California Court of Appeal