<!-- citation-library:start --> ## Citation reference Wood, In re Marriage of (1995) 37 Cal.App.4th 1059, 44 Cal.Rptr.2d 236, disapproved on other grounds in 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 -->