Marriage of Giller CA2/4

CourtCalifornia Court of Appeal
DecidedSeptember 4, 2025
DocketB339223
StatusUnpublished

This text of Marriage of Giller CA2/4 (Marriage of Giller CA2/4) is published on Counsel Stack Legal Research, covering California Court of Appeal primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Marriage of Giller CA2/4, (Cal. Ct. App. 2025).

Opinion

Filed 9/4/25 Marriage of Giller CA2/4

NOT TO BE PUBLISHED IN THE OFFICIAL REPORTS California Rules of Court, rule 8.1115(a), prohibits courts and parties from citing or relying on opinions not certified for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 This opinion has not been certified for publication or ordered published for purposes of rule 8.1115.

IN THE COURT OF APPEAL OF THE STATE OF CALIFORNIA

SECOND APPELLATE DISTRICT

DIVISION FOUR

In re the Marriage of PATRICIA B339223 GILLER and RICHARD C. GILLER. (Los Angeles County Super. Ct. No. 19TRFL00474) PATRICIA GILLER,

Petitioner and Respondent.

v.

RICHARD C. GILLER,

Appellant.

APPEAL from a judgment of the Superior Court of Los Angeles County, Gia G. Bosley, Judge. Affirmed. Richard C. Giller, in pro. per.; Law Offices of Romi Ben-Elyaho and Romi Ben-Elyaho for Appellant. [Retained.] Law Office of Roberta L. Murawski and Roberta L. Murawski for Respondent. In March of 2023, Richard and Patricia Giller1 entered into a stipulated judgment resolving their divorce proceedings. Six months later, Richard filed a request for order (RFO) seeking to set aside the stipulated judgment and an earlier default entered against him. He argued that he signed the stipulated judgment under duress and due to mental incapacity, as evidenced by its unconscionable terms. He also asserted that Patricia made false statements in her financial disclosures and failed to provide the required documentation. The trial court denied the RFO, finding that Richard, an attorney, did not meet his burden to demonstrate sufficient grounds to set aside the judgment. On appeal, Richard challenges the trial court’s order on multiple grounds. He contends the trial court prejudicially failed to consider his reply brief and supporting materials before ruling on the RFO. He does not challenge the court’s findings regarding his claims of duress or mental incapacity. Instead, he focuses on his contention that Patricia violated her fiduciary duties by failing to provide certain financial disclosures and that she committed perjury and fraud. He contends that this conduct materially affected the judgment and requires it to be set aside. We find no error and affirm. BACKGROUND I. Dissolution and Judgment Richard and Patricia were married in 2009. Patricia filed a petition for dissolution of marriage in propria persona on April 19, 2019. Regarding division of property, child custody, spousal and child support,2 and attorney fees, the petition stated that the “parties have voluntarily agreed upon and entered into a Postnuptial Agreement detailing and resolving these issues.” Richard did not file a response to the petition, so Patricia filed a request to enter default in February 2020. She checked the boxes indicating that she had not attached an income and expenses declaration or financial

1 We refer to the parties by first name for clarity. 2 Both parties have children from other relationships, but no children together. Patricia’s youngest child was a minor in 2019 and lived with her and Richard. 2 statement because the “issues subject to disposition by the court in this proceeding are the subject of a written agreement,” and “there are no issues of child, spousal, or partner support or attorney fees and costs subject to determination by the court.” The court entered default on February 28, 2020.3 Patricia retained counsel in early 2023. On March 15, 2023, through counsel, Patricia filed a form declaration regarding service of disclosures (FL- 141). On the form, she checked the boxes indicating that she served Richard by mail on March 2, 2023 with her preliminary declaration of disclosure (FL- 140), current income and expense declaration (FL-150), completed schedule of assets and debts (FL-142), all tax returns for the past two years, and all other required information under Family Code, section 2104.4 She also checked the boxes indicating that it was a default proceeding and waiving the parties’ final disclosure requirements under section 2110. On the same day, Patricia also filed a declaration for default or uncontested dissolution. She checked the boxes indicating that the parties agreed that the matter could proceed as a default and that they had entered into a written agreement regarding their property and marriage rights, to be submitted to the court for approval. Patricia filed a proposed judgment of dissolution on April 25, 2023, stating that the provisions of the judgment were reflected in the parties’ stipulated judgment. In the attached stipulated judgment, signed by Patricia and Richard on March 10, 2023, the parties agreed that its terms would replace the 2019 postnuptial agreement. In the judgment, Richard agreed to pay Patricia half of his “net take home pay” as spousal support, with

3 The postnuptial agreement is not in the record. Patricia filed an RFO in August 2022 (she later claimed that Richard filed it under her name), seeking to lodge a copy of the postnuptial agreement under seal or to file a redacted version. The court rejected this request at a hearing in October 13, 2022, at which both parties appeared in propria persona, and ordered the parties to file preliminary declarations of disclosure. 4 All undesignated statutory references are to the Family Code. 3 delineated exceptions, until either party’s death, Patricia’s remarriage, or February 2030. Richard waived the right to all spousal support from Patricia, and she waived the right to any support after February 2030. Both parties initialed this section indicating that they “have carefully bargained for this buy-out and waiver of spousal support” and “understand the legal consequences of this waiver, and they have voluntarily entered into this waiver with full knowledge and understanding.” The judgment also stated that Patricia’s “earnings are $0 for the purpose of spousal support.” Richard also agreed in the judgment to maintain several life insurance policies for the remainder of his life, with Patricia as sole or partial beneficiary. The parties agreed that Richard would make certain payments toward expenses for three of Patricia’s adult children, including health insurance, car payments, and college education. The judgment detailed the parties’ agreement to division of property and assumption of debts and obligations. The parties also agreed that they had been “filing separate tax returns since 2019. Due to [Richard’s] tax issues, the authorities have been withholding [Patricia’s] tax refunds to pay down [Richard’s] tax debt.” Richard agreed to reimburse Patricia for any withheld tax refunds, and also to assume full responsibility for any tax liability for the joint tax returns filed during the marriage. The court entered the judgment on April 25, 2023. II. Richard’s RFO A. RFO Six months later, in October 2023, Richard, now represented by counsel, filed an RFO seeking to set aside the judgment and default. He also requested $8,000 in attorney fees and costs as well as sanctions against Patricia.

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