<!-- citation-library:start --> ## Citation reference Garcia, In re Marriage of (2003) 111 Cal.App.4th 140, 3 Cal.Rptr.3d 370, disapproved In re Marriage of Fellows (2006) 39 Cal.4th 179 > [!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 -->