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TROPE and TROPE

ATTORNEYS AT LAW 12121 WILSHIRE BLVD. LOS ANGELES, CA 90025-1171 310-207-8228

323-879-2726

1TROPE AND TROPE MARK S. PATT (State Bar 62364) LORI A. HOWE (State Bar 152060) MEGHANN BONVIE (State Bar 236858) Attorneys at Law 12121 Wilshire Boulevard Suite 801 Los Angeles, California 90025-1164 Telephone: 310-207-8228; 323-879-2726 Facsimile: 310-826-1122 Attorneys for Respondent CORINNE LOUISE NEHRENBERG SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF LOS ANGELES In Re Marriage of Petitioner: and Respondent: CORINNE LOUISE NEHRENBERG ___________________________________ Pursuant Petitioner, DELMAR to the DELMAR LAWRENCE NEHRENBERG ) ) ) ) ) ) ) ) ) ) CASE NO. SD 029 077 COMMR. DAVID J. COWAN DEPT. E STIPULATION RE CHILD CUSTODY AND VISITATION; AND ORDER THEREON

stipulation NEHRENBERG,

of

the

parties,

LAWRENCE

and

Respondent,

CORINNE LOUISE NEHRENBERG, and their respective attorneys of record, Trabolsi & Levyi, APC, by IlLene Evans Trabolsi, and Trope and Trope, by Meghann Bonvie, in resolution of all

custody/visitation issues and exclusive use issues presently pending in Respondents Order to Show Cause filed with the Court on January 7, 2011, and for the purpose of entry of a pendente lite, order, THE COURT HEREBY ORDERS, ADJUDGES, AND DECREES as follows: 1. All other issues in this matter not

otherwise adjudged are reserved for further Order of the Court Page 1
STIPULATION RE CHILD CUSTODY AND VISITATION; AND ORDER THEREON
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ATTORNEYS AT LAW 12121 WILSHIRE BLVD. LOS ANGELES, CA 90025-1171 310-207-8228

323-879-2726

or further stipulation by and between the parties at a later time. 1. The parties were married on April 17, 1995

and separated on June 20, 2010, a period of 15 years and 2 months. 2. children: a. August 10, 2003 (age 7); b. 2005 (age 5); and c. Asher Vaughn Nehrenberg, born Evan James Nehrenberg, born July 26, Austin Thompson Nehrenberg, born The parties have the following minor

November 12, 2008 (age 2). I.


A.

Custody Legal Custody. The parties shall have joint, legal custody and all

rights and privileges included with such of each of the minor children. Both parties shall share the right and

responsibility to make decisions and shall keep each other informed of all matters related to the health, education and general welfare of the children. In exercising joint legal custody, the parties shall cooperate and reach agreement in making decisions on the following matters: 1. Selection/enrollment in or termination of

attendance at any private, parochial or public school. 2. Participation in or termination of mental

health counseling or therapy, including the selection of the therapist. Page 2


STIPULATION RE CHILD CUSTODY AND VISITATION; AND ORDER THEREON
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ATTORNEYS AT LAW 12121 WILSHIRE BLVD. LOS ANGELES, CA 90025-1171 310-207-8228

323-879-2726

3. treatment, situations, other each

Non-emergency than party routine may

medical check ups.

and In

dental emergency and shall

authorize

treatment,

notify the other as soon as reasonably possible. / / / In the event of any dispute regarding the foregoing matters the court shall resolve same upon application of

either party. However as provided herein, except in the case of an emergency or imminent harm, the parties shall attempt to resolve mediator any dispute with an a mutually agreed with upon the custody for

before

filing

application

court

resolution of same.
B.

Physical Custody. Respondent shall be granted primary physical custody

of the minor children. Respondent shall have physical custody of the children at all times not designated as Petitioners time.
1.

Regular Schedule. Petitioner shall have physical custody of the

children as follows:
a.

Every Tuesday from 56:00 p.m. until

Wednesday at 7:00 30 a.m.;


b.

Every Thursday from5 6:00 p.m. until

Friday at 7:00 30 a.m.; and c. Sunday at 1:00 p.m. Respondent shall have physical custody of the children at all times not designated as Petitioners time. Page 3
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Every Saturday from 1:00 p.m. until

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ATTORNEYS AT LAW 12121 WILSHIRE BLVD. LOS ANGELES, CA 90025-1171 310-207-8228

323-879-2726

Notwithstanding

the

foregoing,

while

the

parties

are

sharing the same residence they acknowledge that there will be times when respondent is present during petitioners custodial time with the children and vice versa. For example,

petitioner gets up with the children between 6:00 and 6:30 on all days of the week (unless not home) and spends time with the children before school or relaxing on Saturday morning. wWhen petitioner sleeps in the house he and is present the next morning after 7 am and will have the right to spend that early morning time with the boys and help get the children ready for school while respondent makes breakfast, packs the lunches, and gets backpacks ready. on the weekend when petitioner is Similarly, there are times home, for example on a

Sunday afternoon, during respondents custodial time with the children. Neither party shall deny the other party access to .

the home while the parties continue to live together.

Petitioner shall have the right to take the children to school and/or pick up the children from school as mutually and reasonably agreed between the parties when his work schedule permits. Upon further written agreement between the parties, the regular custodial schedule set forth above may be modified so that Petitioners weekend custodial time occurs only during alternating weekends but will be for a period of 48 hours instead of only 24 hours.The parties agree to

cooperate in sharing custody of the children during holidays and vacation. Notwithstanding the above, Page 4
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Petitioner

and

Respondent

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ATTORNEYS AT LAW 12121 WILSHIRE BLVD. LOS ANGELES, CA 90025-1171 310-207-8228

323-879-2726

shall

work

together

to

accommodate

changes

to

the

above-

schedule as needed for Petitioner's work. / / / / / /


C. 1.

General Orders. Notification. Petitioner and Respondent shall notify each

other of any requests for changes to the regular custody and visitation schedule via email with not less than 24 hours

notice unless the parties agree otherwise.


2. a.

Communication Between Parties. Petitioner and Respondent shall make

all communications with each other via email except in the event of an emergency or subsequent agreement reached between the parties.
b.

Petitioner

and

Respondent

shall

not

send any harassing text messages or emails to each other and shall speak respectfully to each other in front of the

children. c.
3.

Communications With the Minor Children. a. Petitioner and Respondent shall not

expose the minor children to any of this litigation or make any derogatory the or negative comments to the minor children either

regarding

other parent or any person with whom

parent associates. b. Petitioner and Respondent shall

ensure that no third parties expose the minor children to this Page 5
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ATTORNEYS AT LAW 12121 WILSHIRE BLVD. LOS ANGELES, CA 90025-1171 310-207-8228

323-879-2726

litigation or speak negatively or derogatorily about either parent or people with whom either parent associates while the third parties are in the presence or in hearing distance of the minor children. / / / / / / / / / / / / / / /
4. a.

Mutual Conduct Orders. For a period of at least 6 months, Respondent shall not introduce the minor

Petitioner

and

children to new friends of the opposite sex of that parent or introduce the minor children to new relationships with people of the opposite sex of that parent that were friends or

relationships established after the parties separation.


b.

While the parties are living in the

same house, Petitioner shall not bring women into the parties home during his custodial time with the children unless the woman is related to the children or a woman who is a mutual friend of the parties that the children knew prior to the parties separation. While the parties are living in the same house, Respondent shall not bring men into the parties home during her custodial time with the children unless the man is related to the children or a man who is a mutual friend of the parties that the children knew prior to the parties

separation. c. Petitioner and Respondent shall clean Page 6


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ATTORNEYS AT LAW 12121 WILSHIRE BLVD. LOS ANGELES, CA 90025-1171 310-207-8228

323-879-2726

up

after

themselves

during

their

custodial

time

with

the

children to ensure the safety and well-fare of the children while they are under that parents care. d. Petitioner and Respondent shall meet

and confer regarding the time by which the children are to be put to bed for the night. Presently, the childrens bedtimes are 7:15 p.m. for Evan, 7:30 p.m. for Asher, and 8:00 p.m. for Austin. Petitioner and Respondent shall put the children to

bed by each childs respective bedtime during each of their custodial times with the children. e. Petitioner and Respondent shall

ensure that all of the childrens homework is done during each of their custodial times with the children. For example, if homework is due on Tuesday, Respondent shall ensure that the child completes the homework by no later than the Monday

evening prior to being due Tuesday. Likewise, if homework is due on Wednesday, Petitioner shall ensure that the child

completes the homework by no later than the Tuesday evening prior to being due Wednesday.

f.

Petitioner and Respondent shall keep

each other informed as to the activities of the children while the other is enjoying keep custodial Petitioner time with the children. school Both

Resondent

shall

informed

about

activities and homework assignments for the children.

Petitioner and Resondent shall make the children reasonably available by phone (i.e., for one conversation after school or before bedtime) to the non custodial parent when they are with Page 7
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ATTORNEYS AT LAW 12121 WILSHIRE BLVD. LOS ANGELES, CA 90025-1171 310-207-8228

323-879-2726

the children.
g.

Petitioner and Respondent shall not leave

the children in the custody of others during their custodial time without advance notice to the other party, except

relatives, in the event of an emergency. h. If either Petitioner and Respondent desire

to leave children in the custody of others they shall give each other the opportunity to spend that time with the

children whenever reasonably possible.


D.

Family Code 3048 Findings. Pursuant to Family Code 3048, the parties declare

and agree herein that the family law department of the Los Angeles County Superior Court has jurisdiction over the

parties and the issues pertaining to custody of their minor children based upon the residence of the parties and their children in the County of Los Angeles, State of California, United States of America; both parties were personally present at the execution of this custody/visitation agreement and both have had an opportunity to be heard in connection with this action; both have knowledge of their rights to a hearing in this matter and both waive their right to the hearing based upon this custody that and a visitation agreement. of the Both parties and

acknowledged

clear

description

custody

visitation rights of each party is set out in this Stipulated and they acknowledge being advised that any violation of this Order may result in civil or criminal penalties, or both. Both parties agree that the United States of America has been the Page 8
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ATTORNEYS AT LAW 12121 WILSHIRE BLVD. LOS ANGELES, CA 90025-1171 310-207-8228

323-879-2726

country of habitual residence of the minor children. / / / / / / / / /


E. 1.

Exclusive Use Orders. Respondent shall be granted exclusive use

and control of the bed in the parties master bedroom at all times.Respondent shall have exclusive use and control of the bed when she is sleeping in the house. Respondent shall

inform Petitioner in advance if she will not be sleeping in the house. the bed, Petitioner shall have exclusive use and control of if desired, on nights where Respondent is not

sleeping in the house.

When either Respondent or Petitioner

are ill, they shall have the right to rest in the bed and shall cooperate with each other in such regard. 2. Respondent shall be granted exclusive use

and control of the family residence located at 16571 Las Casas Place, Pacific Palisades, California 90272 at all times during her court-ordered custodial time with the minor children.

Petitioner shall be granted exclusive use and control of the family residence (except the bed in the Master bedroom) at all times during his court-ordered custodial time with the minor children.
F.

Withdrawal of Respondents Order to Show Cause

filed January 7, 2011. Upon all parties and counsel executing this

stipulation, all pending issues raised in Respondents Order to Show Cause for Custody/Visitation, Restraining Orders and Page 9
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ATTORNEYS AT LAW 12121 WILSHIRE BLVD. LOS ANGELES, CA 90025-1171 310-207-8228

323-879-2726

Exclusive Use Orders, filed with the Court on January 7, 2011 will be resolved. / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / Accordingly, Respondents Order to Show Cause set to be heard on February 22, 2011 at 8:30 a.m. in Department E of the entitled Court, located at 1725 Main Street, Santa Monica

California 90401 shall be taken off calendar. Furthermore, the mediation appointment set for February 9, 2011, set in

connection with the Order to Show Cause, shall be taken off calendar. THE FOREGOING IS AGREED TO BY AND BETWEEN: Dated: ____________, 2011 _____________________________

DELMAR LAWRENCE NEHRENBERG, Petitioner

Dated: ____________, 2011 _____________________________

CORINNE LOUISE NEHRENBERG, Respondent

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ATTORNEYS AT LAW 12121 WILSHIRE BLVD. LOS ANGELES, CA 90025-1171 310-207-8228

323-879-2726

APPROVED AS TO FORM: Dated: ____________, 2011 TRABOLSI & LEVY, APC

_________________________

By: IlLENE EVANS TRABOLSI Attorneys for Petitioner DELMAR LAWRENCE NEHRENBERG TROPE AND TROPE

Dated: ____________, 2011

_________________________

By: MEGHANN BONVIE Attorneys for Respondent CORINNE LOUISE NEHRENBERG

IT IS SO ORDERED.

Dated: ____________________ _____________________________

JUDGE OF THE SUPERIOR COURT

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