<!-- citation-library:start --> ## Citation reference Martinez, In re Marriage of (1984) 156 Cal.App.3d 20, disapproved on other grounds, In re Marriage of Buol (1985) 39 Cal.3d 751, 763, fn. 10, In re Marriage of Fabian (1986) 41 Cal.3d 440, 451, fn. 13, 22 > [!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 -->