Reyna R. v. Joel R. CA4/1

Filed 10/22/26 Reyna R. v. Joel R. CA4/1 NOT TO BE PUBLISHED IN OFFICIAL REPORTS California Rules of Court, rule 8.1115(a), prohibits courts and parties from citing or relying on opinions not certified for publication or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 This opinion has not been certified for publication or or dered published for purposes of rule 8.1115. COURT OF APPEAL, FOURTH APPELLATE DISTRICT DIVISION ONE STATE OF CALIFORNIA REYNA R., D085947 Appellant, (Super. Ct. No. DN179677) v. JOEL R., Respondent. APPEAL from a postjudgment order of the Superior Court of San Diego County, Renee Stackhouse, Judge. Affirmed. Reyna R., in pro. per., for Appellant. Joel R., in pro. per., for Respondent. I INTRODUCTION Reyna R. (Mother) appeals a family court order granting her request to move out of state with two of the three minor children she shares with her ex- husband, Joel R. (Father), but denying her request to move away with the couple’s third and youngest child. On appeal, she argues that the family court: (1) abused its discretion by denying her move-away request as to the youngest child; (2) improperly delegated its judicial authority to the court’s Family Court Services (FCS) department; (3) committed evidentiary errors; and (4) violated her due process rights; and (5) the cumulative effect of these asserted errors requires reversal of the order. We reject these arguments and affirm the order. II BACKGROUND A. The 2014 Custody Arrangement Mother and Father were married in 2007. They had three children together during the marriage—twin sons J.L.R. and J.R. (together, Sons), and I.R. (Daughter). A petition for dissolution of marriage was filed in 2014. After marital dissolution proceedings were initiated, the parties agreed to share joint legal and physical custody of the children. Under the parties’ parenting plan, Father had parenting time with the children on Mondays, Tuesdays, and alternating weekends, and Mother had parenting time with the children on Wednesdays, Thursdays, and alternating weekends. B. The 2022 Custody Proceedings In 2022, Father filed a request for order (RFO) in the family court seeking sole physical custody of J.L.R. Father alleged that Mother had disparaged him and his extended family to J.L.R., Mother had inflicted corporal punishment on J.L.R., and J.L.R. desired to live with Father. In connection with the RFO, the parties participated in a conference with an FCS counselor, who prepared a report and recommendation for the court’s consideration. During the conference, the parties agreed to retain joint custody of J.L.R. under the existing parenting plan. However, in her 2 report and recommendation, the FCS counselor expressed concern about “the high level of conflict between the parents and the impact this is having on the children.” She explained, “Both parents have engaged in negative talk with the children and have allowed others to do the same.” The FCS counselor specifically articulated concerns with Father’s behavior, including his practice of “manipulat[ing] the children, especially [J.L.R.], and discourag[ing] a positive relationship with the [M]other.” The FCS counselor also believed it was “incredibly concerning” that Father sent his then- girlfriend to parent-child exchanges because her presence caused conflict with Mother. Despite these reservations, the FCS counselor supported the parties’ decision to maintain the existing custody arrangement. C. The 2024 Custody and Move-Away Proceedings On August 23, 2024, Mother filed an RFO seeking sole legal and physical custody of all three children and a move-away order allowing her to move with the children to Colorado Springs, Colorado. In an accompanying declaration, Mother alleged that Sons had lived exclusively with her for over a year and Father had drifted apart from them, in large part due to his relationship with his new fiancée. Mother also averred that Father had not fully satisfied his child support obligations. She claimed she wanted to move with the children because she was struggling financially and would be able to save money if she and the children lived with her brother in Colorado. Father consented to the move-away request as to Sons, but not Daughter. On August 29, 2024, Mother filed a second RFO asking the family court: (1) to allow J.R. to speak with the court in chambers concerning Mother’s move-away request; and (2) to order the FCS department to interview both Sons. In connection with the request that J.R. be allowed to address the court, the RFO stated, “[J.R.] really wants to be heard.” 3  On September 18, 2024, Mother and Father jointly participated in a conference with an FCS counselor, who prepared a report and recommendation in connection with Mother’s first RFO seeking sole custody and a move-away order. The FCS counselor interviewed both parties and all three children as part of the conference. During the interviews, the 16-year- old Sons indicated that they wanted to move to Colorado with Mother. Meanwhile, 10-year-old Daughter told the FCS counselor she wanted to remain in San Diego with Father. The FCS counselor wrote in her report and recommendation that she was “extremely alarm[ed]” Sons’ relationship with Father had “deteriorated so severely,” and she was “surprised to learn” Father had made few “attempts to repair his relationship” with Sons. The FCS counselor expressed apprehension that Father can sometimes get “clouded by his need to be right in his arguments with the mother and he [loses] sight of the most important issue – to mend his relationship with the children, to teach them to forgive and help them be able to move forward.” However, the FCS counselor expressed even more concern that Mother had “negatively influenced the boys against the father.” She wrote, “it [was] evident the mother ha[d] a strong negative reaction to the father and his fiancé[e],” and she was “very concerned about how the boys quickly stopped seeing the father in 2023, which occurred around the same time that the mother was expressing concerns to the father about his fiancé[e], his living arrangements and his parenting choices.” She added that Sons could not “identify any significant reasons why they do not want to be around the father,” and Mother “presented with a lot of anger and frustration toward the father and she likely acts this way in front of the children.” The FCS counselor also wrote that Mother may have “coached or influenced” Sons for 4 their FCS interview, and Mother was “creating [a] narrative with the children” that Father had not supported them financially. The FCS counselor recommended that the parties “continue to share legal custody” of the children. She also recommended that Sons be permitted to move to Colorado with Mother. However, she recommended that the court deny Mother’s request to move with Daughter. The FCS counselor explained that Daughter had “been practicing a 50/50 schedule between her parents for the majority of her life,” and it “would be a sudden and drastic change for her to not be able to see the father regularly during the week.” She wrote that Father “ha[d] been a significant attachment figure for [Daughter] and it appear[ed] she [was] very happy in his home and attached to his fiancé[e].” The counselor also noted that Daughter had “extended family in San Diego County and she [was] connected to her community through school and friends.” The FCS counselor stated that she would not “typically recommend splitting a sibling group,” but in this case, the “parents ha[d] already allowed the children to practice different custody schedules for the past 1 ½ years, [Daughter] [was] at a different developmental stage in her life than the boys, they ha[d] a large age gap[,] and the boys [would] only have one more year left of high school before they possibly move[d] elsewhere for college.” On October 1, 2024, Mother filed a third RFO alleging that Father had “refused to pay child support for about a year,” and asking the family court to hold Father in contempt, order garnishment of his retirement accounts, order him to pay interest on the unsatisfied child support payments, and order him to pay half of “the medical, dental, [and] vision bills that he … owe[d] for [the] children.” According to a court order dated November 6, 2024, Mother withdrew this RFO, except for her request for reimbursement of medical, 5 dental, and vision expenses, which were calculated to be $141.36 for the period August 1, 2023, through September 30, 2024. On January 2, 2025, the family court held a hearing and denied Mother’s second RFO requesting that the FCS counselor interview the children and that J.R. be allowed to address the court in chambers. The record does not include a reporter’s transcript for the hearing. However, in its minute order denying the second RFO, the court noted that the RFO was “moot” with respect to the FCS interview because Sons had already “had the opportunity to provide … their preference[s]” to the FCS counselor. The court also stated that it had “read everything provided and there [was] no need for the [c]ourt to speak with the minor [J.R.].” On January 8, 2025, Father filed a responsive declaration to Mother’s first RFO seeking sole custody and a move-away order. In his detailed responsive declaration, Father opposed the requested relief and asked the court to adopt the FCS counselor’s recommendation. On January 16, 2025, the family court held a 40-minute hearing on Mother’s request for sole custody and a move-away order. At the hearing, Mother’s legal counsel asked the court to reject the FCS counselor’s recommendation because it would disrupt the sibling relationship and Father was unlikely to facilitate contact between Mother and Daughter if Daughter stayed in San Diego. In reply, Father claimed he had already shown he would facilitate contact by accommodating Mother’s requests for extended vacation time with Daughter. He also noted that Daughter had told the FCS counselor she did not oppose separation from Sons, and the children’s age gap minimized any potential disruption to the sibling bond. At the end of the hearing, the court provided a tentative ruling adopting the FCS counselor’s recommendation and granting the move-away request as to Sons, but not 6 Daughter. From the bench, the court opined that “Mother ha[d] alienated the kids against Dad, and … if Father does not have constant communication with [Daughter], … it will completely deteriorate and probably terminate because of [Mother’s] lack of facilitating contact.” The court then set the matter for a continued RFO hearing on February 11, 2025. The continued RFO hearing lasted about two hours. At the hearing, the court read its full tentative ruling from the bench and invited the parties to correct any inaccuracies in the ruling. Mother interjected at various points during the recitation of the tentative ruling, which will be discussed below to the extent the objections are relevant to the present appeal. Thereafter, the court adopted its tentative ruling with minor modifications. In its 11-page written order, the court applied the factors enumerated in In re Marriage of LaMusga (2004) 32 Cal.4th 1072 (LaMusga), and concluded that they favored a denial of Mother’s RFO as to Daughter. Relevant here, the court found: (1) Mother sought to relocate to obtain more affordable living and a better financial situation; (2) Mother’s “move [was] not wholly to frustrate Father’s custody, but may be part of it, or at least … she would not be concerned with any negative impact” on Father’s relationship with Daughter; (3) Daughter “would have more stability [by] remain[ing] with Father, in a familiar home, with a familiar set of friends and activities[;]” (4) Mother would not facilitate contact between Father and Daughter if she moved with Mother to Colorado; (5) the parties had a “high conflict” relationship; (6) the parties “struggle[d] to different degrees with putting the children’s needs above their own[;]” (7) Mother’s “interference with Father’s parenting time” and her “comments about [F]ather, his fiancé[e], [and] their home” was not in the children’s best interests; (8) both parties had a “close bond” with Daughter; (9) Daughter had loving extended 7 family members in both San Diego and Colorado; (10) Daughter desired to remain with Father; and (11) there was a connection between the siblings, but that bond did not outweigh all other factors, which collectively showed that it was in Daughter’s best interests to “foster[] [her] relationship [with] Father … in a place where she [was] familiar, stable, well acclimated in the community, surrounded by family, and … thriving.”1 III DISCUSSION2 A. The Family Court Properly Exercised its Discretion When it Found that Daughter’s Best Interests Would be Served by Remaining in San Diego 1. Legal Standards “[W]here one of two parents sharing joint physical custody seeks to relocate with the minor children, ‘the [family] court “must determine de novo what arrangement for primary custody is in the best interest of the minor children.” ’ ” (Andrew V. v. Superior Court (2015) 234 Cal.App.4th 103, 107, quoting LaMusga, supra, 32 Cal.4th at p. 1089, fn. 3; see also Brody v. Kroll (1996) 45 Cal.App.4th 1732, 1736 [“As a practical matter, a hearing on a 1 The family court also adopted the FCS counselor recommendation that Daughter share equal time with the parents on alternating holidays and school breaks. 2 While appellate briefing was ongoing, we granted Father an extension of time to file a respondent’s brief, which he did within the allotted timeframe. After we granted this extension, Mother filed a motion requesting that we vacate our order granting the extension. We deny Mother’s motion to vacate. (See Cal. Rules of Court, rule 8.220(a) [an appellate court, in its discretion, “may” decide an appeal based on the record, opening brief, and oral arguments if the respondent does not file a respondent’s brief within 15 days after the sending of a notice concerning the respondent’s failure to timely file a respondent’s brief].) 8 request for a so-called move-away order necessarily involves issues of custody and visitation. … The issue before the court is: Assuming the custodial parent moves, does the best interest of the child require changes be made in the existing custody or visitation arrangements?”].) In LaMusga, the Supreme Court identified a non-exhaustive list of factors “that the [family] court ordinarily should consider when deciding whether to modify a custody order in light of … [a] parent’s proposal to change the residence of the child … : [1] the children’s interest in stability and continuity in the custodial arrangement; [2] the distance of the move; [3] the age of the children; [4] the children’s relationship with both parents; [5] the relationship between the parents including, but not limited to, their ability to communicate and cooperate effectively and their willingness to put the interests of the children above their individual interests; [6] the wishes of the children if they are mature enough for such an inquiry to be appropriate; [7] the reasons for the proposed move; and [8] the extent to which the parents currently are sharing custody.” (LaMusga, supra, 32 Cal.4th at p. 1101.) As the court further explained, “ ‘bright line rules in this area are inappropriate: each case must be evaluated on its own unique facts.’ ” (Id. at p. 1089.) “We review orders granting or denying move-away requests for abuse of discretion. [Citation.] Generally, a [family] court abuses its discretion if there is no reasonable basis on which the court could conclude its decision advanced the best interests of the child.” (Jacob A. v. C.H. (2011) 196 Cal.App.4th 1591, 1598–1599.) A court also abuses its discretion if it applies the wrong legal standard or issues factual findings that are not supported by substantial evidence. (Department of Water Resources Environmental Impact Cases (2022) 79 Cal.App.5th 556, 573.) On appeal, the test is “not whether this court would have made the same order or whether the [family] court 9 could have reasonably made some other order, but ‘whether the [family] court could reasonably have concluded that the order in question advanced the “best interest” of the child.’ ” (Lester v. Lennane (2000) 84 Cal.App.4th 536, 595; see In re Marriage of Burgess (1996) 13 Cal.4th 25, 32 [“The precise measure is whether the trial court could have reasonably concluded that the order in question advanced the ‘best interest’ of the child.”].) 2. The Family Court Reasonably Found That Daughter’s Best Interests Would be Served by Granting Primary Custody to Father Mother contends the family court abused its discretion when it denied her request for Daughter to move with her to Colorado. Mother argues the court gave insufficient weight to the disruption to the sibling bond that would be caused by a denial of her move-away request as to Daughter. Mother also claims the court gave too much weight to its finding that she would not facilitate contact between Father and Daughter if the court were to grant her move-away request as to Daughter. We discern no abuse of discretion in the family court’s application of the LaMusga factors or its conclusion that Daughter’s interests would be best served by a denial of Mother’s custody and move-away request as to Daughter. The record before us demonstrates that the court thoroughly considered each of the LaMusga factors pertinent to its custody and move- away determination in a lengthy and well-reasoned 11-page decision, and over the course of two court hearings that together lasted for more than two and a half hours. Based on its consideration of all relevant factors, the court made a reasonable determination that Daughter’s interests would best be served by remaining in San Diego in the primary physical custody of Father. With respect to the specific factors identified by Mother, the family court acknowledged that the preservation of the sibling bond was an important factor in its decisionmaking. Nevertheless, the court identified 10 several considerations that minimized the potential disruption to the sibling bond arising from a denial of Mother’s move-away request as to Daughter. Specifically, the court noted that Sons were already entering their senior years in high school and making plans to attend college, they were close to the age of emancipation and nearly six years older than Daughter, Daughter already had spent a considerable amount of time with Father even though Sons lived primarily with Mother, and Father reported that the children had different interests due, in part, to their age gap. Further, the family court found that numerous countervailing concerns supported the denial of Mother’s move-away request as to Daughter despite the disruption it might have on the sibling bond. In its thorough analysis of the LaMusga factors, the court found that Daughter’s best interests would be promoted if she were allowed to remain with Father because: (1) Mother’s move may have been based, in part, on her desire to frustrate Father’s custody of Daughter; (2) Daughter would enjoy a “familiar home, with a familiar set of friends and activities” with Father in San Diego; (3) Father has a close bond with Daughter; (4) Mother would not facilitate contact between Father and Daughter if she moved with Mother to Colorado; (5) Daughter has loving extended family members in San Diego; (6) Daughter has frequent contact with Father; and (7) Daughter desired to stay with Father in San Diego. Considering all these factors, we conclude the court reasonably exercised its discretion when it determined that Daughter’s best interests would be furthered if she stayed primarily with Father in San Diego. (See In re Marriage of Steiner & Hosseini (2004) 117 Cal.App.4th 519, 529 (Steiner) [court properly exercised its discretion by granting custody of different siblings to separate parents] [“Keeping siblings together is no doubt a weighty factor in the calculus of custody, but not a dispositive one.”].) 11  We likewise reject Mother’s claim that the family court erred by giving too much weight to the fact that Mother would not facilitate contact between Father and Daughter. When making a custody determination, a court must “take into consideration which parent, as primary custodian, will best facilitate a good relationship with the other parent.” (Steiner, supra, 117 Cal.App.4th at p. 529; see also Fam. Code,3 § 3020, subd. (b) [“it is the public policy of this state to ensure that children have frequent and continuing contact with both parents”].) Here, the family court described facilitation as a “huge issue,” but the record does not support Mother’s claim that facilitation became a “decisive” and “outcome-determinative” factor. As discussed, the court weighed numerous factors when making its custody and move-away decision. “The weight to be accorded to such factors must be left to the [family] court’s sound discretion,” and an appellate court “err[s] in substituting its judgment for that of the [family] court. (LaMusga, supra, 32 Cal.4th at p. 1093.) Here, the court reasonably exercised its wide-ranging discretion when it considered and weighed the various factors that were relevant to its overall determination of the custody arrangement that promoted Daughter’s best interests. 3. Substantial Evidence Supported the Court’s Facilitation Finding Mother also claims the family court abused its discretion because its finding that Mother would not facilitate contact between Father and Daughter is unsupported by substantial evidence. We reject Mother’s claim. In the proceedings below, the family court relied on several documents to support its facilitation finding. It relied in part on the FCS counselor’s 2024 report and recommendation, which stated that Mother displayed a 3 Further undesignated statutory references are to the Family Code. 12 “strong negative reaction to the father and his fiancé[e],” had “negatively influenced” the children against Father, and “presented with a lot of anger and frustration toward the father and she likely acts this way in front of the children.” The court also relied on documents showing that Mother refused to relinquish Daughter to Father’s care on July 4, 2023, despite a court order granting custody to Father on that date. Further, the court relied on documents showing that Mother did not allow Daughter to visit Father over winter break in 2024 during his designated visitation period, which resulted in Father seeking and obtaining an ex parte court order to enforce the parties’ stipulated visitation schedule. Based on this collective evidence, the court reasonably found that Mother would not facilitate contact between Father and Daughter if Daughter moved with Mother to Colorado.4 On appeal, Mother claims that substantial evidence does not support the court’s facilitation finding because the record “contains a materially significant prior FCS evaluation” from 2022. According to Mother, this 2022 report and recommendation, and its emphasis on certain troubling behaviors exhibited by Father, “undermines the reliability of the [court’s] 4 Mother complains that the family court considered the July 4th and winter break incidents because they were discussed for the first time in Father’s responsive declaration dated January 8, 2025. Without any analysis, Mother claims that Father filed his responsive declaration “late,” which deprived her of a meaningful chance to rebut the allegations contained therein. Even if we assume Father’s responsive declaration was untimely, “ ‘[a] trial court has broad discretion to accept or reject late-filed papers,’ ” and Mother has made no showing that the family court abused its discretion in this case by accepting the responsive declaration. (Jack v. Ring LLC (2023) 91 Cal.App.5th 1186, 1210.) Further, there is no indication in the record that Mother sought a continuance of the RFO hearing to file a reply to the responsive declaration. For these reasons, we reject Mother’s arguments about the alleged untimeliness of Father’s filing. 13 facilitation finding,” and proves that the finding is unsupported by substantial evidence. Mother misunderstands the nature of our role when we review the record for substantial evidence. The 2022 report and recommendation may well have provided the family court with enough evidence to issue a facilitation finding more favorable to Mother. However, “ ‘ “ ‘[w]hen a finding of fact is attacked on the ground that there is not any substantial evidence to sustain it, the power of an appellate court begins and ends with the determination as to whether there is any substantial evidence contradicted or uncontradicted which will support the finding of fact.’ ” ’ ” (Ashby v. Ashby (2021) 68 Cal.App.5th 491, 511–512.) In other words, “the pertinent inquiry is whether substantial evidence supports the court’s finding—not whether a contrary finding might have been made.” (In re Marriage of Fregoso & Hernandez (2016) 5 Cal.App.5th 698, 702.) Here, as discussed above, ample documentary evidence supported the family court’s facilitation finding, even though other evidence contained in the record might have supported a different or contrary facilitation finding. Because substantial evidence supported the facilitation finding, we reject Mother’s challenge to the sufficiency of the evidence.5 5 Mother also claims that the family court erroneously found that there was no evidence Father had fallen behind on his child support payments. To support this argument, Mother cites to a family court order dated January 16, 2025, which states that Mother had “dropped all complaints against [Father] except for one relating to the child’s medical bills.” This court order is silent concerning the existence of evidence related to Father’s compliance with his child support obligations. Because the record does not show that the family court ever made the finding that Mother purports to challenge on appeal, we reject Mother’s claim of error. 14  B. The Family Court Did Not Improperly Delegate its Judicial Authority Next, Mother asks that we reverse the custody and move-away order because the family court “improperly delegated” its judicial authority to the FCS counselor who wrote the 2024 report and recommendation. Mother claims the court erroneously adopted the 2024 report and recommendation “without articulat[ing] independent findings concerning sibling separation, [the] emotional impact [of sibling separation], or [a] compelling justification” for separating the siblings. We reject this argument. As an initial matter, Mother does not support her claim of error with citations to relevant legal authorities. “ ‘In order to demonstrate error, an appellant must supply the reviewing court with some cogent argument supported by legal analysis and citation to the record. … [W]e may disregard conclusory arguments that are not supported by pertinent legal authority.’ ” (Champir, LLC v. Fairbanks Ranch Assn. (2021) 66 Cal.App.5th 583, 597 (Champir); United Grand Corp. v. Malibu Hillbillies, LLC (2019) 36 Cal.App.5th 142, 146 (United Grand) [“ ‘an appellant must supply the reviewing court with some cogent argument supported by legal analysis and citation to the record’ ”].) These rules of appellate practice apply to Mother, even though she is a self-represented party. (Nwosu v. Uba (2004) 122 15 Cal.App.4th 1229, 1247.) Because Mother has not supported her argument with pertinent legal authorities, she has forfeited her claim of error.6 Mother’s delegation argument also fails on the merits. As just discussed, the record shows that the family court thoroughly analyzed the issues presented in Mother’s RFO, reviewed copious documents submitted by the parties in connection with the RFO, and issued a detailed 11-page order analyzing the LaMusga factors and applying them to the facts of the case. Thus, the record shows that the court did not delegate its judicial authority. Instead, it independently exercised its discretion to conclude that Daughter’s best interests would be served by remaining in San Diego with Father. C. The Family Court Did Not Commit Prejudicial Evidentiary Errors 1. The Family Court Did Not Err by Relying on Father’s Responsive Declaration Mother also argues that the family court erred by relying on Father’s responsive declaration as evidence at the RFO hearing. She claims the court erred because the “untested written assertions” contained within Father’s responsive declaration were “not evidence,” and yet the court relied on the declaration to support its purported findings that: (1) there was an existing “strain” in the sibling relationship; and (2) Mother told Daughter she did not 6 To support her delegation argument, Mother cites In re Marriage of Brown & Yana (2006) 37 Cal.4th 947. There, the Supreme Court held that a noncustodial parent who opposes a proposed relocation of the parent’s child may obtain a modification to the existing custody arrangement by proving a significant change of circumstances, but the noncustodial parent does not have an absolute right to an evidentiary hearing to show that the proposed relocation would cause detriment to the child or that the relocation is not in the child’s best interests. This decision does not address the delegation of judicial authority, and it is not relevant to Mother’s claim of error. 16 have to worry about “La Llorona” when she stayed with Mother, but Daughter needed to worry about “La Llorona” when she stayed with Father.7 We conclude the court did not err insofar as it relied on the responsive declaration at the RFO hearing. When a court conducts a postjudgment RFO proceeding, a party’s “declaration may be considered as evidence,” and “any objection [to the declaration] will be considered waived,” unless another party objects to the declaration at least two court days prior to the RFO hearing. (Cal. Rules of Court, rule 5.111(c)(1); see Code Civ. Proc., § 2009 [allowing a court to consider affidavits in lieu of live testimony as an exception to the hearsay rule]; In re Marriage of Falcone & Fyke (2012) 203 Cal.App.4th 964, 982 [“A family law court is empowered to hear motions based upon declarations and to exclude oral testimony.”]; In re Marriage of George & Deamon (2019) 35 Cal.App.5th 476, 483 [“When the parties fail to present any live testimony in support or opposition to a motion in family court, Code of Civil Procedure section 2009 controls, which—despite the hearsay rule— allows a motion hearing to be decided based on declarations.”].) Mother does not direct us to any portion of the record in which she asked the court to resolve her RFO based on live witness testimony procured at a contested evidentiary hearing in lieu of the declarations and related exhibits submitted by both parties. She also does not point us to any portion of the record showing that she filed timely objections to Father’s responsive declaration. For both reasons, we reject Mother’s claim that the family court erred by relying on Father’s responsive declaration as evidence. 7 At the hearing on Mother’s RFO, the family court described La Llorona as a “mythical ghost” who “steal[s] kids and kill[s] them.” 17  2. The Family Court Did Not Err by Rejecting Mother’s “Offer of Proof” After the family court provided its tentative ruling at the continued RFO hearing, Mother and her legal counsel identified additional issues that, in their view, should have been incorporated into the final custody and move- away order. Relevant here, they urged the court to review the FCS counselor’s 2022 report and recommendation. Shortly after, the court stated that it had reviewed the 2022 report and recommendation while other proceedings were taking place off the record. The court then recited excerpts from the 2022 report and recommendation, including the FCS counselor’s concerns about certain of Father’s behaviors. The court also stated that it would “add all of that to [its] analysis.” Thereafter, Mother’s legal counsel asked the court for permission to make an “offer of proof” about the report and recommendation. The court replied, “No, no. I’m going to move forward. … I’m done with the argument on the LaMusga factors. I’m going to go back in chambers for the next 15 minutes and make sure this additional information does not change my analysis.” Mother’s counsel followed up by asking the court to at “least consider all of the statements” concerning Father’s behaviors that the FCS counselor wrote in the report and recommendation. The court replied, “Counsel, I read the paragraph. I put in what I thought was important. I’m not taking argument anymore.” Thereafter, the court went into recess. When the hearing resumed, the court stated that it had spent the recess “reviewing the analysis” and going “through the whole thing again,” and the court’s “tentative ruling ha[d] not changed.” On appeal, Mother claims that the family court erroneously “limited further development of the record” and improperly excluded “material evidence” by rejecting her trial counsel’s “offer of proof.” However, Mother 18 has not supported her claim of error with relevant legal authorities or cogent argument articulating what “evidence” she believes was improperly excluded. Thus, Mother’s argument is forfeited. (Champir, supra, 66 Cal.App.5th at p. 597; United Grand, supra, 36 Cal.App.5th at p. 146.) Further, our reading of the record indicates that the “offer of proof” proposed by Mother’s counsel pertained to the contents of the 2022 report and recommendation, as that was the document that was under discussion during the RFO hearing at the time that Mother’s counsel made her “offer of proof.” However, the court indicated that it had already reviewed the 2022 report and recommendation, and the court even recited the most pertinent excerpts from the 2022 report and recommendation at the RFO hearing. Further, there is no indication in the record what counsel hoped to achieve through her “offer of proof,” apart from highlighting certain components of the report and recommendation that the court had already reviewed and considered. For all these reasons, Mother has not established a reasonable probability that the family court’s rejection of her counsel’s “offer of proof” would have changed the outcome of the RFO proceeding. 3. Mother Has Not Proven That The Court Prejudicially Erred by Precluding J.R. from Conveying his Wishes to the Court Mother asks that we reverse the custody and move-away order because the family court erroneously denied her second RFO asking that the court permit 16-year-old J.R. to speak directly with the court in chambers. Mother claims the court erred because the denial of her second RFO violated section 3042, a statutory provision that outlines the circumstances under which minors may relate their views on custody proceedings to courts. Section 3042, subdivision (a), states, “If a child is of sufficient age and capacity to reason so as to form an intelligent preference as to custody or visitation, the court shall consider, and give due weight to, the wishes of the 19 child in making an order granting or modifying custody or visitation.” Section 3042, subdivision (c), continues, “If the child is 14 years of age or older and wishes to address the court regarding custody or visitation, the child shall be permitted to do so, unless the court determines that doing so is not in the child’s best interest, in which case, the court shall state its reasons for that finding on the record.” Section 3042, subdivision (f)(1), adds that, as a general matter, “the court shall not permit a child addressing the court regarding custody or visitation to do so in the presence of the parties. The court shall provide an alternative to having the child address the court in the presence of the parties in order to obtain input directly from the child.” Mother claims the family court violated section 3042 because it denied her second RFO without making any findings that J.R.’s best interests would not be served by addressing the court in chambers. However, no court reporter attended the hearing on the second RFO, and Mother has not supplied us with a suitable alternative to a reporter’s transcript. “[I]t is a fundamental principle of appellate procedure that a trial court [order] is ordinarily presumed to be correct and the burden is on an appellant to demonstrate, on the basis of the record presented to the appellate court, that the trial court committed an error that justifies reversal of the [order].” (Jameson v. Desta (2018) 5 Cal.5th 594, 608–609.) “ “A necessary corollary to this rule is that if the record is inadequate for meaningful review, the appellant defaults and the decision of the trial court should be affirmed.’ ” (Gee v. American Realty & Construction, Inc. (2002) 99 Cal.App.4th 1412, 1416.) Here, it is possible that the family court made findings that it would not be in J.R.’s best interests to address the court in chambers, and that the court explicitly stated its findings on the record during the unreported RFO hearing. Because the court could have denied the second RFO on this basis, 20 we must apply the presumption of correctness and presume that the events of the unreported hearing supported the order. Even if we assume the court violated section 3042, the error was harmless. In its minute order denying Mother’s second RFO, the court indicated it had read the FCS counselor’s 2024 report and recommendation, which incorporated J.R.’s views on his family dynamics and the custody proceedings. In the 2024 report and recommendation, the FCS counselor wrote that Sons had told her they “want[ed] to move to Colorado with the mother because they like it there, [and] San Diego is too expensive ….” The 2024 report and recommendation also noted (without distinguishing between the Sons) that one of the Sons “had a hard time explaining why he was upset with the father,” and the other Son believed Father had lied to the children, engaged in improper discussions with them about child support, and priorit