<!-- citation-library:start --> ## 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. <!-- citation-library:end -->