Filed 9/3/26 Marriage of C.S.D. and A.D. CA4/1 NOT TO BE PUBLISHED IN OFFICIAL REPORTS California Rules of Court, rule 8.1115(a), prohibits courts and parties from citing or relying on opinions not certified for publication or ordered published, except as specified by rule 8.1115(b). This opinion has not been certified for publication or ordered published for purposes of rule 8.1115.
COURT OF APPEAL, FOURTH APPELLATE DISTRICT
DIVISION ONE
STATE OF CALIFORNIA
In re the Marriage of C.S.D. and A.D.
C.S.D., D086809
Respondent,
v. (Super. Ct. No. 24FL008778C)
A.D.,
Appellant.
APPEAL from a judgment of the Superior Court of San Diego County, Rebecca F. Zipp, Judge. Affirmed.
A. D., in pro. per., for Appellant. Law Office of Beatrice L. Snider and John L. Romaker for Respondent.
I. INTRODUCTION
This is the second direct appeal by A.D. (Father) in this contentious
family law case.1 (See A.D. v. C.S.D. (Feb. 25, 2026, D085466) [nonpub. opn.]
(A.D. I).)2 In A.D. I, Father appealed the trial court’s issuance of a domestic violence restraining order (DVRO) protecting C.S.D. (Mother) after Father pushed Mother during an after-school pickup of their daughter (Daughter). Father argued on appeal that Mother and a disinterested eyewitness committed perjury, that Mother’s attorney engaged in misconduct, and that the trial court was biased against Father. This court rejected Father’s challenges and affirmed the DVRO.
Representing himself on appeal, Father now challenges the trial court’s dissolution judgment determining custody, visitation, support, and property issues. Father contends the trial court lacked jurisdiction to address these issues because, in doing so, the trial court relied on the DVRO — which was then still under appellate review — to invoke the statutory presumption against awarding custody to a perpetrator of domestic violence. (See Fam. Code, § 3044.) Father also argues the trial court was biased against him and that a third party engaged in discovery misconduct. For reasons we will explain, Father has not met his burden as the appellant to show prejudicial error on any of his claims.
Accordingly, we affirm the judgment.
1 Father previously filed six writ petitions in the case. This court summarily denied them all. 2 We grant Father’s unopposed request to take judicial notice of the docket in A.D. I.
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II. FACTUAL AND PROCEDURAL BACKGROUND
Mother and Father married in 2015, had Daughter together in 2016, and separated in July 2024. Mother filed for dissolution in August 2024. As with many dissolutions, this one included vigorously contested custody and support issues.
A. A.D. I
To provide context for Father’s current appeal, we briefly describe his unsuccessful prior appeal.
1. DVRO Proceedings
In 2024, Mother filed a petition seeking a DVRO against Father. She supported her petition with declarations from herself and eyewitness Dora S. The declarations stated that Father pushed Mother during an after-school pickup of Daughter. The trial court (Judge Ialeggio) issued a temporary DVRO and set an evidentiary hearing.
The court held an evidentiary hearing on October 28, 2024. The parties agreed the matter could be heard within the 20 to 30 minutes provided for matters on the “regular domestic violence calendar.” Mother’s counsel informed the court that she had a 30-minute audio recording of the incident, but only about five or ten seconds of it were relevant. Father’s counsel agreed that the most relevant portion lasted only about 15 seconds but requested that the court also listen to the 15-minute lead-up to the incident. The court ultimately listened to the entire 30-minute recording.
The court received Mother’s and Dora’s declarations in evidence. Dora also testified in person. On direct examination, Dora testified that she wrote and signed her declaration, which contained her direct observations of an angry man (later identified as Father) pushing Mother at Daughter’s school.
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On cross-examination, Dora clarified that Mother helped Dora prepare her declaration:
Q. And did you discuss with [Mother’s counsel] what to include in your declaration? And I would ask that you just answer my questions yes or no.
A. No.
Q. Did you discuss with [Mother] what to include in your declaration?
A. Okay. We did come to an agreement as far as where to meet so I could hand it or deliver it. Because . . . I am not good with multimedia, and so I had to give it to her in person. Okay. We agreed to meet outside of my church, and she arrived. Yes, she gave me the document, so I could sign it, but I did read it beforehand. I read it beforehand, and it was my statement and my signature.
Q. Okay. So [Mother] typed this statement for you?
A. I asked her to because . . . I don’t do typing. And I could indicate what to include and what not to include. She only helped me to express my statement. (A.D. I, supra, D085466.)
Father did not move to strike (or otherwise challenge) Dora’s declaration. He testified he did not push Mother.
Based on the evidence before it, the trial court found that portions of Mother’s declaration were “self-serving and not accurate” and that Father’s testimony was “not consistent with the evidence.” (A.D. I, supra, D085466.) Relying in part on Dora’s “neutral and unbiased” testimony, the trial court found that Mother met her burden to establish abuse entitling her to a DVRO. (Ibid.)
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Accordingly, the trial court issued a DVRO through January 1, 2026, identifying Mother and Daughter as the protected parties. The DVRO also addressed custody and visitation issues.
2. Appeal
Father appealed the DVRO, “rais[ing] a variety of challenges that fall into the broad categories of evidentiary error, attorney misconduct, and judicial bias. The factual bases of each challenge [were] largely the same: (1) Dora committed perjury by testifying that she ‘wrote’ her declaration, when she also testified that Mother actually typed it and presented it to Dora for signature; and (2) Mother committed perjury . . . in her declaration . . . , which the trial court found to be ‘self-serving and not accurate’ based on the audio recording of the incident.” (A.D. I, supra, D085466.) Father also accused Mother’s counsel of attempting to “ ‘suppress[] exculpatory material’ ” by “propos[ing] to play only a few seconds of the 30-minute audio recording of the incident.” (Ibid.) “Finally, Father accuse[d] the trial court of judicial bias ‘by failing to ensure fair proceedings and exhibiting bias favoring one party.’ ” (Ibid.)
On February 25, 2026, this court affirmed the DVRO, concluding Father had not established the factual predicates for his claims, which he forfeited in any event by failing to raise them in the trial court. (A.D. I, supra, D085466.)
B. Trial Court Proceedings at Issue in This Appeal
In the meantime, on March 3, 2025, Father filed a motion regarding child custody, child and spousal support, attorney fees, and to set aside the DVRO to increase his share of custody over Daughter. The following month,
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on April 30, 2025, Father filed a motion seeking sanctions. Neither motion is in the appellate record.
On June 6, 2025, the trial court (Judge Zipp) heard Father’s motions and held a trial on dissolution. Mother appeared with counsel; Father represented himself. The parties were sworn in as witnesses.
The parties agreed the trial court could begin by announcing its tentative rulings on the contested issues: spousal support, child support, property division, attorney fees as a sanction against Father for filing a
frivolous restraining order request against Mother, and child custody.3 As relevant here, when addressing spousal support and child custody, the trial court considered Father’s history of domestic violence, as evidenced by the DVRO. (See Fam. Code, §§ 4320 [“In ordering spousal support . . . , the court shall consider . . . [¶] . . . [¶] All documented evidence of any history of domestic violence”], 3044 [“Upon a finding by the court that a party seeking custody of a child has perpetrated domestic violence . . . , there is a rebuttable presumption that an award of sole or joint physical or legal custody” to that person “is detrimental to the best interest of the child”].)
The trial court then heard testimony from Mother and Father. The court repeatedly — at least a dozen times — invited Father to address concerns raised in the court’s tentative and any other issues Father wished to address.
3 The trial court stated: “[T]he court does have tentatives on all of [the] issues with a couple of exceptions. [¶] If [Mother’s counsel] and [Father] agree, I would like to read those tentatives, and then the parties can choose how to devote their time today, hopefully with emphasis on the issues on which the court would like to hear more.” After Mother’s counsel agreed, the court asked Father, “[D]o you agree to hear the court’s tentatives and then — they’re not final rulings, but it’s what I’m inclined to do, and then I’ll highlight the issues that I do want to hear more from, from both you and [Mother].” Father responded, “Okay.”
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Regarding his motion to set aside the DVRO, Father argued the DVRO “was obtained fraudulently” because Mother “submitted false evidence” and “false testimony.” Father cited Dora’s testimony about how she prepared her declaration with Mother’s assistance, and Mother’s counsel’s proposal that the court listen to only a portion of the audio recording of the incident. Father did not advise the court that he had appealed the DVRO or that the appeal was still pending.
The trial court denied Father’s request to set aside the DVRO. The court explained its ruling to Father: “When Judge Ialeggio made her decision, she had all the information that you are presenting to the court now. So it is not as though new information emerged after the hearing that showed someone had stated something incorrect on which Judge Ialeggio relied. So Judge Ialeggio knew when she made her ruling that [Dora] said she wrote the declaration, but admitted, ‘no, I didn’t actually write the declaration, I read it, and signed it.’ And even with that disparity, Judge Ialeggio found that the evidence showed by a preponderance of the evidence that a restraining order was necessary.”
At this point, Father stated, “I don’t believe I can get a fair trial, and so I would like to continue this matter until I can get represented, because I don’t feel like I’m getting a fair trial, and I feel like I’m getting taken advantage of because I don’t have a lawyer at this time.” When the court asked Father to elaborate on why he felt he was not receiving a fair trial, Father said, “I don’t believe any of these proceedings have been impartial. . . . I presented . . . substantial evidence [of] perjury and fraud, and it was just dismissed based on the fact that the previous judge decided not to rule on it. That’s why it is in appeal, because the judge did not rule according to the law and according to the evidence. [¶] And I don’t feel like you’re ruling
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according to the law or the evidence as well. [¶] And so I feel . . . like I’m being railroaded and pushed into — trying to push the divorce through, and I don’t feel like — I am just not getting a fair trial. I’m not. [¶] And so . . . I need to get . . . someone to represent me as well and . . . see what my other options are because I am not getting a fair trial.” The court took a recess.
After the recess, the trial court explained it would treat Father’s fairness concerns as a request to disqualify the court for cause under Code of
Civil Procedure section 170.1.4 Treated as such, the court denied the request because it was neither in writing nor filed before trial began.
Trial resumed and the issue of the DVRO arose again. Father asserted that, based on his view that the DVRO “was based on falsified evidence,” he had overcome the statutory presumption that awarding him custody would be detrimental to Daughter’s interests. The court asked Father if he had enrolled in a “batterer’s treatment program,” which “is an important factor for the court to consider.” (See Fam. Code, § 3044, subd. (b)(2)(A) [in determining whether the presumption has been rebutted, the court must consider whether “[t]he perpetrator has successfully completed a batterer’s treatment program”].) Father said he had not, but added that he had completed an anger management class.
The court took a lunch recess and directed the parties to return at 2:30 p.m. Father did not return. After making several attempts to contact Father, the court resumed the trial without him.
After the close of evidence, the court orally announced its ruling and directed Mother’s counsel to prepare a judgment containing all the court’s orders and findings. As relevant here, the court denied Father’s motion to set
4 Further statutory references are to the Code of Civil Procedure unless otherwise indicated.
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aside the DVRO, finding that Judge Ialeggio had before her all the information on which Father based his current motion. After finding that Father failed to rebut the Family Code section 3044 presumption, the court (with minor exceptions not relevant here) declined to modify its previous order granting Mother legal and physical custody of Daughter, with visitation rights for Father. The court ordered Mother to pay Father spousal and child support. The court also divided the parties’ marital property.
The court entered judgment on October 13, 2025.5
III. DISCUSSION
A. The Trial Court Had Jurisdiction
Father argues the trial court lacked jurisdiction to conduct further dissolution proceedings because the DVRO — which factored into the court’s decisions regarding support, custody, and setting aside the DVRO — was still on appeal. We disagree.
Father is correct that, “[a]s a general rule, ‘ “[t]he filing of a valid notice of appeal vests jurisdiction of the cause in the appellate court until determination of the appeal and issuance of the remittitur” [citation], thereby divesting the trial court of jurisdiction over anything affecting the judgment.’ ” (Stubblefield v. Superior Court (2025) 108 Cal.App.5th 675, 679– 680, italics added.) Similarly, “[s]ubject to certain exceptions . . . ‘the perfecting of an appeal stays proceedings in the trial court upon the judgment or order appealed from . . . .’ ” (Varian Medical Systems, Inc. v. Delfino (2005)
5 Father filed a notice of appeal on July 22, 2025, purportedly from the trial court’s June 6, 2025 minute order. Because the minute order directed the preparation of a judgment, we deem Father’s notice of appeal as being prematurely taken from the October 13, 2025 judgment.
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35 Cal.4th 180, 189, italics added, quoting § 916, subd. (a).)6 These rules preserve the status quo to ensure the appellate court can render effective relief. (See Stubblefield, at p. 680; Varian, at p. 189.) As noted, however, these general rules are subject to exceptions, several of which apply here.
The first applicable exception is found in section 917.7, which provides that the filing of an appeal does “not stay proceedings as to those provisions of a judgment or order which award, change, or otherwise affect the custody . . . of a minor child in any civil action.” Instead, an order affecting child custody or visitation is stayed on appeal only if the trial court orders a stay. (§ 917.7.) Unless the trial court grants a stay, the court retains jurisdiction to modify any order affecting child custody or visitation during the pendency of an appeal. (Ibid.)
The DVRO contained custody orders. Indeed, Father in part sought to set aside the DVRO to eliminate the Family Code section 3044 presumption against custody so that the trial court could award him greater custody than he was entitled to under the DVRO. Yet, Father failed to request or obtain from the trial court a stay pending his appeal of the DVRO. Absent such a stay, the trial court was free to address the custody aspects of the DVRO — which include the court’s earlier finding of abuse that implicated the Family Code section 3044 presumption against custody — even if the trial court’s ruling would moot the issues under appellate review. (See Mancini v. Superior Court (1964) 230 Cal.App.2d 547, 555 [“more than one modification
6 Section 916, subdivision (a) states: “Except as provided in Sections 917.1 to 917.10, inclusive, and in Section 116.810, the perfecting of an appeal stays proceedings in the trial court upon the judgment or order appealed from or upon the matters embraced therein or affected thereby, including enforcement of the judgment or order, but the trial court may proceed upon any other matter embraced in the action and not affected by the judgment or order.”
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[of a child custody order] might be made pending appeal” and “may render one or more appeals taken from custody orders moot before they are heard”]; Smith v. Superior Court (1974) 41 Cal.App.3d 109, 111, fn. 1 [“the trial court retains jurisdiction pending the appeal to modify or amend its custody orders”].)
The second relevant exception applies, more generally, to appeals from orders granting injunctive relief. Under this exception, “the appeal of an injunctive order does not result in a stay of trial court proceedings on the merits of the dispute.” (In re Marriage of Tim & Wong (2019) 32 Cal.App.5th 1049, 1053; see Hayworth v. City of Oakland (1982) 129 Cal.App.3d 723, 727 [“the rule of automatic stay does not apply to an injunction which is ‘prohibitory’ in nature”].) “ ‘A domestic violence restraining order is a type of injunction, as it is “an order requiring a person to refrain from a particular act.” ’ ” (In re Marriage of A.M. & R.Y. (2025) 110 Cal.App.5th 1115, 1124.) Accordingly, because the DVRO is a prohibitory injunction, Father’s first appeal challenging that injunction did not stay the trial court proceedings on the merits of the parties’ ongoing disputes.
Finally, orders subject to modification upon changed circumstances generally are not stayed pending appeal. (In re Marriage of Horowitz (1984) 159 Cal.App.3d 377, 381–382; see id. at p. 384 [“Modification of the trial judge’s order for child or spousal support while the issue of the validity of that amount is on appeal, when based upon a change of circumstances justifying a change in amount, does not interfere with the jurisdiction of the appellate court, since its review is based upon the record at trial.”].) A DVRO may be modified or terminated when the facts or the law change or when the ends of justice would be served. (Fam. Code, § 6345, subd. (a) [“personal conduct, stay-away, and residence exclusion orders . . . [are] subject to
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termination or modification by further order of the court”].) Therefore, trial court proceedings on matters encompassed by the DVRO were not stayed while the DVRO was on appeal. (In re Marriage of Horowitz, at pp. 381–383.) Indeed, it was Father who sought to set aside the DVRO even though he knew it was on appeal.
For these reasons, Father has not met his burden to show that the trial court lacked jurisdiction while the DVRO was on appeal.
B. Father Has Not Shown Judicial Misconduct
Father argues the trial court exhibited bias against him through “judicial prejudgment” and by “unlawfully” ruling on Father’s motion to disqualify the court. He also argues the court denied him due process. These
arguments are unpersuasive.7
1. Tentative Rulings
Father argues that the trial court’s oral announcement of tentative rulings at the beginning of the trial amounted to improper judicial prejudgment of the issues that “constitute[d] structural error and denie[d] due process.” We disagree.
Preliminarily, Father forfeited this challenge by expressly consenting to the trial court announcing tentative rulings. (In re Marriage of Broderick (1989) 209 Cal.App.3d 489, 501 [“an appellant waives his right to attack error by expressly or implicitly agreeing or acquiescing at trial to the ruling or
7 Although an order denying a motion to disqualify a judge is not an appealable order — it must be brought by way of a writ petition filed within 10 days of the challenged ruling (§ 170.3, subd. (d)) — we will exercise our discretion to treat Father’s direct appeal of the trial court’s disqualification ruling as a writ petition because Father promptly (indeed, prematurely) filed a notice of appeal encompassing the challenge.
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procedure objected to on appeal”].) And, in any event, “[t]he practice of formulating tentative rulings in advance of argument . . . is commonplace and unobjectionable.” (People v. Rodriguez (2014) 58 Cal.4th 587, 651–652; see People v. Gamache (2010) 48 Cal.4th 347, 404 [“a trial court may ‘study[] the merits of a motion in advance of the hearing and reach[] a tentative conclusion as to how the motion should be resolved’ ”].)
2. Ruling on the Motion to Disqualify
Father contends the trial court was “absolutely prohibit[ed]” by statute “from ruling on her own disqualification.” He relies on section 170.3, subdivision (c)(5), which states in part, “A judge who refuses to recuse himself or herself shall not pass upon his or her own disqualification or upon the sufficiency in law, fact, or otherwise, of the statement of disqualification filed by a party.” This limitation, however, applies only to the ultimate decision on the merits of a properly filed disqualification motion. A challenged judge may rule on the timeliness and procedural sufficiency of a party’s statement of disqualification. (§ 170.4, subd. (b) [“if a statement of disqualification is untimely filed or if on its face it discloses no legal grounds for disqualification, the trial judge against whom it was filed may order it stricken”]; see North American Title Co. v. Superior Court (2024) 17 Cal.5th 155, 171.) Moreover, if the objecting party seeks disqualification after trial has commenced, the challenged judge can continue to hear the trial. (§ 170.4,
subd. (c)(1); see Eckert v. Superior Court (1999) 69 Cal.App.4th 262, 265.)8 Here, the challenged judge found that Father’s disqualification motion was untimely and procedurally deficient because it was not in writing, as
8 “[I]f it is [ultimately] determined that the judge is disqualified, all orders and rulings of the judge found to be disqualified made after the filing of the statement [of disqualification] shall be vacated.” (§ 170.4, subd. (c)(1).)
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required. (§ 170.3, subd. (c)(1) [“If a judge who should disqualify himself or herself refuses or fails to do so, any party may file with the clerk a written verified statement objecting to the hearing or trial before the judge and setting forth the facts constituting the grounds for disqualification of the judge.” (Italics added.)]; see People v. Bryant (1987) 190 Cal.App.3d 1569, 1573 [oral disqualification request is insufficient].) These were matters the challenged judge was statutorily authorized to address. (§ 170.4, subd. (b).) In addition, because trial had already commenced — it began when the court swore-in Mother and Father as witnesses (§ 170.4, subd. (c)(1)) — the challenged judge could continue to preside over the trial (ibid.).
Accordingly, Father’s statutory challenges to the trial court’s disqualification ruling fail.
3. Due Process
“ ‘[N]otwithstanding the exclusive-remedy provision of [the judicial disqualification statutes], “a [party] may assert on appeal a claim of denial of the due process right to an impartial judge.” ’ ” (Brown v. American Bicycle Group, LLC (2014) 224 Cal.App.4th 665, 673.) Father argues the trial court “denie[d] due process when it announce[d] its ruling in advance, refuse[d] a continuance necessary to ensure fairness, relie[d] on an appealed order rather than current evidence, and recharacterize[d] [Father]’s fairness objection to avoid addressing it.” We are not convinced.
Regarding Father’s complaint about tentative rulings, we reject that due process claim for the same reasons we rejected his statutory claim.
As to Father’s claim that the trial court denied him due process by refusing to continue the trial date, he has not met his burden to show error. Trial courts have “ ‘wide discretion in granting or denying continuances, and
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its decision is not disturbed on review unless a clear abuse of discretion is shown.’ ” (Agnew v. Parks (1963) 219 Cal.App.2d 696, 700.) Father makes no attempt in his appellate briefing to explain how the trial court not only abused its discretion in denying his request for a continuance but abused its discretion to such a degree that it denied Father due process. This failure is fatal to Father’s appellate challenge. (See In re Marriage of Carlisle (2021) 60 Cal.App.5th 244, 255 [“ ‘The absence of cogent legal argument or citation to authority allows this court to treat the contentions as’ forfeited.”]; United Grand Corp. v. Malibu Hillbillies, LLC (2019) 36 Cal.App.5th 142, 165, fn. 6 [“ ‘[A]n appellant is required to not only cite to valid legal authority, but also explain how it applies in [the] case.’ ”].)
Father next asserts that the court denied him due process by “rel[ying]
on an appealed order rather than current evidence.” We presume this relates to the trial court’s reliance on the DVRO (as opposed to receiving new evidence on Father’s history of domestic violence) to find that the Family Code section 3044 presumption applied. However, Father does not explain how the trial court’s application of a statutory presumption denied him due process. Indeed, the trial court was statutorily authorized to rely on the DVRO in determining whether the presumption applied or had been rebutted. (Fam. Code, § 3044, subd. (d)(2); see Noble v. Superior Court (2021) 71 Cal.App.5th 567, 577 [“A court finding that the party seeking custody has perpetrated domestic violence may be made by any court, not just the court hearing the custody matter.”].) And once the court found that the presumption applied, the court was required to apply it. (In re Marriage of Fajota (2014) 230 Cal.App.4th 1487, 1498 [“The presumption is rebuttable,
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but the court must apply the presumption in any situation in which a finding
of domestic violence has been made.”].)9 Finally, we reject Father’s claim that the trial court denied him due process by “recharacteriz[ing] [his] fairness objection to avoid addressing it.” As noted, the trial court was not required to address Father’s claim of judicial bias because he did not comply with the statutory procedure for raising the challenge. And although Father faults the trial court for “recharacteriz[ing]” his objection, he does not explain how the objection should properly have been characterized or what procedure should have governed it.
We are satisfied that Father received a fair hearing. He received notice of the proceeding; indeed, it partially addressed his own request for relief. The court received and reviewed trial briefs and exhibits from both parties. And Father had the opportunity to testify and to cross-examine Mother. Indeed, the trial court told Father at least a dozen times that the court was willing to hear from him on the pending issues. The fact that the trial court ultimately found Mother’s evidence more persuasive than Father’s does not constitute bias or reflect a denial of due process. (See W.S. v. S.T. (2018) 20 Cal.App.5th 132, 154 [“As the trier of fact, the trial court must evaluate the credibility of witnesses and make determinations when conflicting evidence is presented. The trial court’s ‘reliance on certain witnesses and rejection of others cannot be evidence of bias no matter how consistently the [trial court] rejects or doubts the testimony produced by one of the adversaries. . . . “[T]otal rejection of an opposed view cannot by itself impugn the integrity or competence of a trier of fact.” ’ ”]; Schmidt v. Superior Court
9 To the extent Father complains about the due process afforded him in the underlying DVRO proceedings, this court rejected substantially similar challenges and affirmed the order in A.D. I.
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(2020) 44 Cal.App.5th 570, 589 [“Numerous and continuous rulings against a party are not grounds for a finding of bias.”].)
C. Father Has Not Properly Presented His Claim of Third Party Discovery Misconduct
Father contends that the “destruction of subpoenaed exculpatory evidence denied [him] due process.” Specifically, he asserts in his appellate briefing that, in connection with the original DVRO hearing, he subpoenaed Daughter’s school for surveillance footage of the incident, but the school acknowledged that it failed to preserve the footage. Father forfeited this challenge in two ways.
First, Father failed to support it with citations to any supporting evidence in the appellate record. (See Cal. Rules of Court, rule 8.204(a)(1)(C) [appellate briefs must “[s]upport any reference to a matter in the record by a citation to the volume and page number of the record where the matter appears”]; American Indian Model Schools v. Oakland Unified School Dist. (2014) 227 Cal.App.4th 258, 284 [the appellant’s “burden on appeal . . . includes supporting factual assertions by providing appropriate references to the record”]; Anton’s Services Inc. v. Hagen (2025) 116 Cal.App.5th 90, 110 [“[Appellant] fails to provide any record citations for its factual assertions or any authority for its arguments, which are thus forfeited.”].)
Second, our review of the limited record on appeal shows that Father failed to raise this issue in the current trial court proceedings. “It is well settled that the failure to raise an issue in the trial court typically forfeits on appeal any claim of error based on that issue.” (Howitson v. Evans Hotels, LLC (2022) 81 Cal.App.5th 475, 489.)
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IV. DISPOSITION
The judgment is affirmed. Mother is entitled to her costs on appeal.
RUBIN, J.
WE CONCUR:
MCCONNELL, P. J.
DO, J.