<!-- citation-library:start --> ## Citation reference Brooks & Robinson, In re Marriage of (2008) 169 Cal.App.4th 176, 86 Cal.Rptr.3d 624, overruled in part by In re Marriage of Valli (2014) 58 Cal.4th at 1405 > [!info] Working notes > This is a personal working note. Citation details are for reference; opinion and current-status verification may still be pending. <!-- citation-library:end -->