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## Citation reference
Gram, In re Marriage of (1994) 25 Cal.App.4th 859, 30 Cal.Rptr.2d 792, disapproved in part In re Marriage of Lehman (1998) 18 Cal.4th 169, 188, 74 Cal.Rptr.2d 825
> [!info] Working notes
> This is a personal working note. Citation details are for reference; opinion and current-status verification may still be pending.
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