To the best of our knowledge, Cal Safety, the American Heart Association, and others have only about 2% of adults certified in CPR in California. More than 13% of people in California smoke cigarettes. What is wrong with this picture? Something as serious as saving a life should be taken more seriously, don’t you think?

More than a billion people smoke cigarettes and perhaps only 1/5,000 percent of people are certified in CPR worldwide. We teach our students about things that happened thousands of years ago, but we don’t require anything when graduating on life-saving skills that 99.9% of them would use at some point in their lives. Let’s start this right here in California and CPR Certify all children before the age of 14 and set an example for the rest of America and maybe even the world!

Help teach CPR and first aid to our children in California by supporting these types of programs. When it’s time to take a CPR and first aid class, be sure to select a program that updates its material to keep up with all the changes in basic emergency care. CPR and First Aid classes are best taught by experienced Emergency Medical Professionals who have been trained and have responded to emergency situations.

Make sure the CPR and First Aid programs you select are compliant and compliant with all of these respected agencies: OSHA Compliant, California State Emergency Services, Authoritative Journal of the American Medical Association. Maybe the life you save is that of someone you love!

Newspapers, the TV station, the Internet, the parent forum, and office hallway conversations are all about Mattel’s recent toy recall. As the mom of my 5-year-old angel, I am very concerned about this message. My mother told me this news in the first memory about 2 weeks ago. I dismissed it thinking this only happened in China. But in the back of my mind, my mind is racing and pulling out my collections of the newest toys that my husband, my colleagues in China bought for my daughter. Yes, there are Barbie toys, lots of them.

Just yesterday, the news of Mattel Toy’s recall was featured prominently in Singapore’s leading newspaper and TV channel. Quickly, I did a metal check and realized that 30% of my daughter’s toys (gifts from family, friends, my parents) are from Mattel. From Barbie, Polly Pockets, Dora and some other Disney characters. My heart is beating fast, I’m getting seriously worried.

Turning on my internet, I began browsing Mattel’s website for more information on the recall. The link pointing to the Singapore withdrawal was active, but was listed as under construction (Yuks, this is not good!). I check with the Mattel Care hotline (available only during business hours). The phone has been busy all day.

I’m frustrated. I am extremely concerned as the news of Dora’s toy recall was mentioned in our newspaper, but not on Mattel’s website. this is conflicting

As I subscribed to the Fisher Price (Mattel subsidiary brand) newsletter to receive toys and updates, I was surprised that Mattel CEO Bob Eckert sent emails to his Fisher Price member mailing list informing about their withdrawal. .

Regardless, I’m prepared to return these toys to Mattel. However, how am I going to tell my “princess” that she won’t have her toys to play with? 30% of her toy (2 full boxes) and 1 big Dora house! My nurturing instinct tells me to calmly tell her and get her emotionally prepared to willingly part with her toys from her.

So I pulled her aside, showed her the newspaper (which luckily has pictures of Barbie and other toys). I told him that some “bad” people use bad paint and bad magnets in these toys. The bad things in these toys will hurt her and make her sick. So mom is worried about her health. Specifically I use these words “Mom loves you and she doesn’t want to see you sick. If these paints on the toys make you sick, I’ll take them off.” She began to understand what she meant. She said, “Yeah, I don’t want to be sick. I can’t go to Sunday school and skate when I’m sick.” So I said, “So no Barbie dolls and Dora toys, since Mommy wants to put them away.” She replied and nodded “Yes”.

So it was good for me. My “princess” was very understanding and has taken it very well.

As for me, nothing is more important than my daughter’s health. I’m sure other parents share this too.

However share some tips with parents when choosing toys.

1. Choose brands that are well established.
Most of these companies are more responsible and will take action if something happens or tighten their quality control process.

2. Choose toys that are relevant to the age of the children.

3. Check the ingredients used to make the toys and the countries where it was made.
Yes, almost 80% of toys are made in China.

Example: wooden brick toys. The ones made with non-toxic paint from Israel can cost S$80 per bucket compared to S$8 from a store in Singapore (made in China) or RMB 8 in China. only 36 months.

4. For special occasions such as birthdays, Christmas or Children’s Day, you can provide a list of toys or gifts that you want to buy for your children. This can prevent duplication of the same toys or too much of one type of toy versus another.

5. Identify if the toy can help the child in

– Pure creative play (Example: finger puppets)

– Innovation (Example: beach or garden tool kit for exploration)

– Problem solving (Puzzle; start with 2,3,4,6 pieces and go to 12-24-64 pieces as they grow)

– Role play (doll house, dress up)
Act out different characters (Daddy or Mommy, Rabbit, Kitten or Tiger, etc.)

Whatever it is, a toy given to a child should not be seen as just a pacifier or a convenience tool for busy parents. Every item given to a child, especially when they are infants or toddlers, should be selected with care and consideration. Toys are a very important part of children’s activities, especially when they are young. So choose with consideration and lots of thought.

More than 25 percent of the fish caught in Wisconsin are caught when the lakes have frozen over, indicating just how popular ice fishing is in dairy country.

Most ice fishing begins in early December. This is when the local fisherman braves 3-4 inches of ice and starts looking for walleye. This year is an exception. There is a lot of ice in the north. This author was in the Eagle River Chain of Lakes this past Thanksgiving. Although it was too early to put flags where he was fishing, my neighbor was able to catch a monster in a nearby lake. He Caught a 30″, 12lb Walleye! That would go on just about anyone’s wall.

Walleye and Panfish are the most popular fish to ice fish, but if you can find a good spot for northern pike during the day, you’re in for a fun day of fishing. All of these fish are good through the ice. During the winter the meat of these fish is firm and delicious. Sometimes during the summer Northerns and some panfish get mushy and dirty. This is not the case in the winter. You would be hard pressed to tell the difference between a northern winter and a winter walleye in a blind taste test.

Panfish are usually caught by jigging. Some anglers have good success on the Tip Downs. Tip downs typically have a wooden support next to the hole and a rod, wire, or even umbrella extending from the top. When the fish bites, the wire bends down. These are good setups for soft biting fish.

Walleye and Northern usually get caught in Tip Ups. These tip ups usually have a flag on a spring that is released when the fish bites. In my opinion the number one Tip Up is Beaver Dam Tip Up. I don’t own any stock in the company nor do I sell any of their products, they just make a very good tip. When using a tip up it is important that your reel moves smoothly without catching. Winter walleye can be skittish and if they feel a pull from the reel they will drop the bait.

Early in the season I like to use medium and large shiners through the ice for walleye. It is important that you hook the black eye just below the dorsal fin for walleye. Put that treble hook as close to the back as possible. If you hook them too deep into the body, it’s what we call a “kill hook”: your minnow will likely die quickly and will lack the movement that a well-hooked minnow has. Northerners will smack a dead minnow, but walleye like to get it moving.

Where you put your minnow in the water when you are fishing for walleye is also important. The best position is to have that minnow about 10-15 inches off the bottom of the lake. Use a depth finder first to mark the bottom. First I sink my depth finder, grab the line at the waterline, pull up about 20 inches of the line, and place a wooden match through the line. Then I put the minnow in and let the line out making sure the match is next to my spool when I put the tip in the hole.

This should help you start ice fishing. Remember, be safe and check the ice with a potato bar before you head out.

In 2003, the American Animal Hospital Association (AAHA) revised vaccination guidelines and recommended that veterinarians vaccinate adult dogs every three years instead of annually, and many veterinarians changed their protocols in light of the new guidelines. The change was implemented after experts agreed with overwhelming evidence showing that annual vaccinations for canine diseases were unnecessary and harmful. It is up to the pet owner to avoid veterinary service providers who recommend, and even require, annual vaccinations. There are many veterinarians who choose to ignore the guidelines because they don’t want to lose the revenue that these booster shots generate each year. Another veterinary service that pet owners should avoid are those provided in a parking lot or pet supply store where you and your pet meet without the benefit of a relationship with the veterinarian who provides the affordable service. Your pet may pay the price for inappropriate or unnecessary veterinary care. Vaccinations are a major stress on your pet’s immune system and can cause side effects and allergic reactions, as well as long-term chronic illnesses such as skin allergies, arthritis, leukemia, upper respiratory infections, bowel syndrome irritable, and neurological conditions such as aggressive behavior, epilepsy, autoimmune disease, and cancer. Today, it is common for veterinarians to see sicker dogs and cats at a much younger age. Pets as young as 5 years old are being diagnosed with cancer, and autoimmune diseases are also on the rise. Combine over-vaccination with poor nutrition, poor breeding practices and environmental stress and you are left with generations of pets that are susceptible to chronic diseases and congenital disorders. Annual veterinary checkups are a must for your pet, as this gives them a solid foundation of health, helps pet owners recognize subtle changes in their pets over time, and builds a relationship between your veterinarian, you, and your pet.

It’s best to prepare for your dog’s annual veterinary visit. Be prepared to discuss the best vaccination strategy for your pet by bringing along veterinary records of your pet’s vaccination history. Do not assume that the clinic will have the latest information at hand and this is more imperative if you have changed veterinary clinics. Include all test results, such as heartworm, antibody titer, blood, and/or urinalysis. Have a clear idea of ​​whether you want or need your pet to receive vaccinations for which diseases, and ask your veterinarian if any particular vaccinations are necessary due to conditions in the area where he lives. Consider the risk. If your pet is only indoors and is never exposed to unvaccinated animals, then the risk of infection is low. Educate yourself so you can have an intelligent conversation with your vet about the pros and cons of vaccinating your pet. Know the health of your pet; if you have any health or behavioral issues that your vet should be aware of and bring a list of any medications or supplements your pet is taking along with dosage, strength and frequency. The decision whether or not to vaccinate your pet is highly individual and should be based on extensive research before going to your veterinarian. If you’re seeing a vet for the first time, it’s a good idea to make an appointment to see him without your pet to discuss his philosophy regarding vaccinations and other tests, such as antibody titer testing. A “titer” is a measure of the amount of antibodies to a certain antigen circulating in the blood at that time. A dog that shows a positive antibody titer test result is considered protected against the disease for which the vaccine is intended and does not need vaccinations at that time. Never vaccinate a pet whose immune system is compromised with an infection, as the vaccine could distract the immune system from handling the infection and create the likelihood that the vaccine will not produce protective immunity.

If you decide to vaccinate your pet, consider asking your veterinarian to perform a health exam and other tests first, and then wait for the results. If your pet is in good health, schedule a follow-up vaccination visit. Avoid multiple vaccinations in one or combined vaccinations; if this is the only option available, look elsewhere. Do not vaccinate your pet more than every three years. Some vaccines, such as Lepto, Bordetella or Lyme, do not last more than a year; however, consider whether these diseases are on the rise in your area before vaccinating your pet. Schedule these vaccinations separately from the rabies vaccine if your pet needs them and administer them elsewhere on the body. Vaccination programs must be designed for the specific needs of each animal, not for the masses. You need to factor the dog’s age, environment, activities, lifestyle, and pre-vaccine adverse reactions, if any, into the equation. Do not vaccinate puppies and kittens under 12 weeks of age as their immune systems are highly vulnerable to the stress of the vaccine. Keep puppies and kittens safe from exposure by avoiding public areas like parks and pet stores. Vaccinate puppies between 12 and 15 weeks of age against parvovirus and distemper and wait until they are 6 months old before vaccinating against rabies. For kittens, a combination of panleukopenia (FRCP) and, if available, administer the vaccine separately at an interval of three to four weeks. Consider your cat’s lifestyle and environment; if he goes out and you have rabies in your area, vaccinate him at 6 months of age. Vaccines against feline leukemia and FIP may not be necessary for your cat. Please note that legal requirements vary from state to state. Studies show that a single vaccine against parvovirus, distemper and panleukopenia provides long-term protection and a simple blood test will reveal if antibody levels remain high enough to resist infection, so it is not needed a “booster”. Vaccines do not need a “booster.” Unless the diseases are locally endemic or a specific kennel has Bordetella, Corona Virus, Leptospirosis or Lyme, veterinarians do not recommend vaccinations. The leptospirosis vaccine is generally not useful because the currently licensed leptospiral bacterins do not have the serovars that currently cause leptospirosis. An alternative homeopathic method used by pet owners who choose not to vaccinate is Nosodes, which can be used on animals less than three months of age if the animal is at risk. These homeopathic medicines help protect pets against parvovirus, distemper, kennel cough, panleukopenia, and FIP. Although some nosodes work more effectively than others, they are not vaccines and do not produce titers against these diseases, but they do appear to offer some protection in disease severity if the pet has been exposed, even if they do not prevent disease.

When it comes to vaccinating your pet, educate yourself. You are your pet’s guardian and the decision is yours, not your veterinarians, nor should it be. You are responsible for the care of your companion; give them the best by carefully researching and weighing decisions about their health care.

Burbank houses provide an interesting topic of discussion. Burbank, CA, or the Media Capital of the World as it is called, is located just outside of famous Hollywood, CA. More people work in the entertainment-oriented city of more than 100,000 residents than actually live in it. The primarily upper-middle-class area offers something for everyone. While it’s true that stars like Orlando Bloom, Sean Penn, and Patton Oswalt own real estate in Burbank, what is little talked about outside of Burbank’s entertainment focus are the many vibrant communities that make up this famous city.

For starters, there are executive homes in Burbank located on the Verdugo hillside that captures the beautiful views of the Valley. Business owners, executives, and entrepreneurs call this area home. Includes the pristine developments of Burbank Hills, Burbank North, Halston and Highridge Estates.

Homes for young professionals in Burbank who want the ideal urban zen tend to be located in the downtown Burbank area. Downtown Burbank contains many lofts with cafes, entertainment venues, and shops right outside of them. In fact, this is the perfect community for people who choose to live and work in a vibrant area that never allows for a dull moment.

In addition to the executive and downtown Burbank homes discussed, Burbank also boasts a thriving Equestrian Rancho district. This beautiful area is an idyllic ranch community that is ideal for horse lovers. In fact, many of the houses in this district have their own stables.

Last but not least, probably the most overlooked Burbank home communities are its family-oriented districts. One such area is Magnolia Park, which contains many California ranch and Spanish-style bungalows. The houses are conveniently located near schools, cafes, shops and parks. Another such area is the Media District, which is in close proximity to Disney, NBC, and Warner Bros.

Burbank homes and real estate make for quite an interesting topic. While focused on the entertainment industry, Burbank, CA has communities for executives, young professionals, horse lovers, and families. There is something for everyone in Burbank.

“Cursed is the ground because of you” (Genesis, 3:17 – NKJV)

Today, the coronavirus is one more proof, among a thousand other proofs, of the inability of modern man to face himself and his environment. The truth is that we cannot live peacefully in a world that, most of the time, looks like a nest of snakes. While there are many pieces to the COVID-19 puzzle, and I certainly can’t address all of them, I’d like to share with you a few thoughts about the current pandemic and relate them to a more philosophical argument.

In early December 2019, the virus outbreak began. But it was only on March 11, 2020, that the World Health Organization (WHO) declared COVID-19 a pandemic, after the disease caused thousands of cases. Back then, according to the WHO, the risk to people who did not live in China was very low. Could not be farther from the truth. Apparently, organizations have their own ways, and it seems to take thousands of deaths to get a dinosaur-like bureaucratic structure on the right track. This is a large family of viruses that are collectively known as the coronavirus. How come the so-called experts couldn’t have seen it coming? This glitch claimed the lives of so many! In fact, they are experts at excusing themselves, their organizations, their industry, or their political agenda for not having foreseen the problem.

Now, let’s remember that disease transmissions from animals, insects to humans are not that uncommon. A pneumonia of unknown causes was detected in people around an animal market. Have you ever heard of that? That is not completely foreign to us. If you are a great scientist, your mind automatically makes predictions about the future of your field, even when you are not aware of it. Of course, beyond that, what you learn in one area can often be applied to others. Not long ago, researchers in the field of artificial intelligence were optimistic that highly capable machines would exist within a few decades. What I want to know is this: where are those damn machines now? Where’s a good HAL 9000 to help those guys anticipate catastrophe and calculate viral genetic variation before it turns into something else?

The gradual replacement of men and women by machines to carry out the functions of life is a characteristic of our time. But there is one area where no machine, no matter how complex, can act for its creator. This is the area of ​​empathic understanding. Now and always, only the human being will favor compassion.

I think anyone will agree with me that it is not easy to make sense of life due to the chaos and arbitrariness in which we live. We are increasingly dissatisfied with the narrow-mindedness of the politicians and bureaucrats around us. Despite everything, we must draw attention to the storehouse of human resources that we carry within. The search for meaning raises questions, for example: where do I fit into the whole of life? Shadow effect or not, we must fight this thing with all our might. The weight of history is once again on our heads. Indeed, there are many lessons to be learned in the midst of the storm. Let’s not waste time with vulgar vanities and selfishness.

Breed Description
The Welsh Springer Spaniel is a compact, medium-sized dog with a robust, stocky appearance. They appear to be set much lower off the ground than they are, as their straight to shaggy hair is longer on the chest, neck, and lower sides. These sporting dogs generally stand around 17 inches tall at the shoulder and weigh between 30 and 40 pounds.

Coat
The Welsh Springer Spaniel has a coat that is naturally smooth and soft to the touch. It is never wavy or stringy with waterproof features that protect these dogs from all kinds of bushes and thorns. They only come in red and white colors, and any pattern is allowed based on the breed standards.

Exercise
The Welsh Springer Spaniel is a very energetic breed that is naturally lively. They would require plenty of off-leash exercise, preferably with a large open space. They do quite well in an apartment if they are given enough exercise. They can be relatively active indoors and would enjoy play sessions with the family. These spaniels excel at retrieving, tracking, swimming, and hunting. If they don’t exercise properly, they will become lazy, obese and bored.

Temper
The Welsh Springer Spaniel is an affectionate, loyal and active breed. Some are known to be reserved with strangers, but never shy, hostile, or shy. They are known to be very affectionate with family, especially children. They also get along with other household pets, play games and make friends. They tend to be clingy with their masters and love the company of children.

Overview
The Welsh Springer Spaniel is among the dog breed that has been popular in Europe and North America due to its cheerful personality and trainability. These traditional hunting dogs are among the oldest hunting dogs, originally used to move to the net and search for game.

Watch out
The thick coat of Welsh Springer Spaniels can become a problem if not cared for. They should be checked regularly for parasites and beetles, including ticks, if they live in rural locations. It is also convenient to brush them from time to time, especially if they are going to spend their time indoors. Trimming during the summer should be considered to prevent them from overheating.

Training
The Welsh Springer Spaniel is a versatile dog that is willing to learn but tends to be headstrong. They would require basic obedience and early socialization to avoid a timid, dominant dog. They especially love hunting, so it is advisable to train them in this sport to prevent these dogs from wandering. As with the other entire dog breeds, training must be done with consistency, firmness, and fairness.

character
The Welsh Springer Spaniel is a very devoted breed that has a soft-eyed loyalty just like the other spaniels. These lively dogs are good-natured companions. They are generally people-oriented dogs, but they tend to be a bit reserved around strangers. They are never aggressive and would be suitable for families with children and household pets.

Wisconsin law takes arson very seriously. It is a malicious and highly dangerous crime. In the year 2006, there were approximately 31,000 intentionally set fires in the US, resulting in the deaths of 305 civilians. To qualify as a felony arson, a fire must be started intentionally, but Wisconsin law includes ways to prosecute people who unintentionally set fires through reckless behavior. Here’s a quick overview of our state’s fire safety laws, in order of increasing severity.

Negligent Handling of Burning Materials – If you start a fire by mishandling or failing to supervise a smaller fire, you are guilty of a Class A misdemeanor. This is punishable by up to nine months in prison and/or a fine of up to $10,000. For repeat offenders, the award can be up to two years.

Arson of Property Other Than Buildings: The intentional use of fire to damage any property, other than buildings, with a value of more than $100 is a class E felony. This is punishable by up to 15 years in prison.

Unsafe Burning of Buildings: Sometimes people decide to get rid of old sheds or dangerously dilapidated buildings by simply burning them down. This is legal, as long as you do it with the knowledge and cooperation of the fire department. If you burn down an old building in a reckless or dangerous manner, you are guilty of a Class D felony. This is punishable by up to 25 years in prison.

Setting fire to buildings: When a person deliberately sets fire to a building without the consent of the owner, sets fire to his own property to commit insurance fraud, or does any of these with the use of explosives, he has committed a Class B felony The penalty can be up to 60 years in prison.

Arson Injuries – Anyone who is injured or suffers property damage due to arson, including municipal employees, can sue the arsonist for treble damages. This means that the arsonist will have to pay the injured party three times the cost of the damages suffered.

First degree murder – If an act of arson results in the death of a person, the arsonist can be charged with first degree felony murder, even if the death was accidental. In Wisconsin, being convicted of a Class A felony carries a mandatory life sentence.

Arson is clearly not a charge to be taken lightly. Because fires are so difficult to control once they start, arson is an extremely dangerous crime. For more information about Wisconsin arson laws, contact the arson defense attorneys at Appleton, Kohler, Hart & Priebe.

The following tips are applicable to almost any pet. I have compiled this information from my own experiences as an animal communicator, with my own pets (including dogs, fish, birds, turtles, and rabbits), as well as from veterinarians and animal rescue organizations. No part of this information is intended to be used as a substitute for professional veterinary care.

1. If you leave the house for any reason, tell your pet(s) where you’re going, when you’ll be back, and what work you’d like them to do (nap, house-sit, etc.) while you’re gone. I always tell my dogs I’m going to run an errand and when I’ll be back (ie 2 hours, around their dinner, etc.). I also tell them to take a nap while I’m gone and be a good boy. This tends to ease his anxiety about me being gone. If it’s a longer trip, I always tell them how many days I’ll be gone.
2. Animals like their routines. If your routine is going to change for a day or more, tell them why and how the change will affect your routine. For example, if you’re going to have to work late for a couple of weeks, let your pet know. This will help avoid any unwanted behavior they may exhibit as their way of protesting the upset of the change in their routine.
3. If your animal is having seizures, ask your vet to do a food allergy test. One of our dogs started having seizures shortly after we brought him home from the shelter. Our vet did a thorough allergy test and found that he had many allergies (cigarette smoke, Bermuda grass, chicken, rice, etc.). The food that he ate consisted mainly of chicken and rice. So we changed his food to one on the ‘approved food and treats’ list provided by the testing company. Since he changed his food, he has not had another seizure. So while food allergies may not always be the cause of seizures, it’s worth investigating with your vet.
4. Before you bring a plant or flower into your home, find out if the plant or flower is poisonous to animals. Reactions to the toxic substance in some plants and flowers can range from mild nausea to death. I had a family member’s cat die because he ate part of an Easter lily leaf. Other common houseplants that are poisonous include, but are not limited to, philodendrons and poinsettias. For a more complete list, check the Internet, ask your veterinarian, or ask someone at the store that sells the plant or flower.
5. If you suspect your pet has ingested a poisonous substance, seek veterinary help immediately. If the incident occurs after hours, contact the nearest after-hours animal emergency center. Try to bring a sample of what the animal has eaten or bitten if it is safe for you to do so. For example, one of my dogs put a spider in his mouth and promptly spit it out. I assumed that the spider had bit him in the mouth. So, I put the spider in a plastic container and took my dog ​​to the emergency vet after hours for treatment. Fortunately, since he had the spider with me, the vet was able to tell me that it was a type of spider that was not poisonous.
6. Keep the contact information on your pet’s identification tags and/or microchip up to date. If your pet is lost and someone from animal control or your neighborhood finds the animal, this will help expedite the return of your pet.
7. Post a pet-related notice for rescue personnel in the windows of each exterior door of your home. In each notice, include the number and type of animals residing in your home, as well as the name and phone number of your veterinarian. This will alert rescue personnel that there are animals in the home and who has medical records on file for each pet in the event of a fire or other major catastrophe involving your home. Some animal rescue organizations (ie Humane Society of the United States, ASPCA, etc.) have these types of decals for your window and can provide them free or for a nominal fee upon request.
8. Plan for your pet’s future in case something happens to you. Many states allow you to set up trusts for your pet so that they can be cared for the way you want them to be if you die before them. For more information, visit the Humane Society of the United States website or consult with your family attorney.
9. If you have to give up your family pet for any reason (ie divorce, loss of residence, etc.), fully explain to the pet why you have to do so. It is very important that an animal is told why it will not be part of the family that raised it. I’ve seen in clients’ pets and animals in rescue shelters the impact that not knowing this kind of information has on animals. Some become aggressive and think that nobody loves them. Others become very withdrawn and harbor a lot of guilt that it was their fault that they are no longer with their family.
10. Teach children the proper way to approach an unfamiliar animal. This includes asking the animal’s human companion for permission to pet the animal. Some animals are not used to children and may react adversely if approached too quickly.

Prior to the January 1, 2003 amendment to California Family Code section 4502, laches (unreasonable delay with undue prejudice) was a defense to the collection of spousal support and child support. But on January 1, 2003, Family Code section 4502(c) eliminated the laches’ defense to back spousal support and child support. And while the aforementioned section 4502(c) was later struck down by the California Legislature, Family Code section 291(d) was enacted as a replacement.

In an action for enforcement of judgment for child or spousal support, the defendant may oppose, and the court may consider, the defense of laches only with respect to any part of the judgment that is due towards conditionunder Family Code Section 291(d).

Therefore, the alternative defense of waiver under California Civil Code section 3515 may be available to prohibit the collection of spousal and child support arrears, but no longer laches.

Delay inconsistent with intent to enforce right to support:

With the laches defense of common law for the collection of spousal support eliminated by the California Legislature, the laches defense set forth in Plescia’s marriage (1997) 59 CA 4th 252, 257-258, 69 CR 2d 120, 123-124, and in In re Marriage of Lamb (2007), 95cal. app. 4th 653, 115 cal. Rptr. 2d 787, is no longer good law.

This leaves the defendant-debtor spouse with the waiver defense. Waiver has been defined as “the intentional waiver of a known right or such ride that merits an inference of the waiver of such right, and may result from an express agreement Prayed be inferred from the circumstances indicating the intention to resign,” according to Panno v. Russian 82 cal. app. 2d 408, 412, 186 P. 2d 452.

In In re Marriage by Paboojian (1987) 189cal. app. 3d 1434, 235 Cal Rpt. 65, the Court of Appeals ruled that: “although the evidence of an express waiver is equivocal… (the) delay (the lack of demand for court-ordered child support for almost 16 years) in itself is not a defense of the right to enforce increased payments under the divorce decree, (citing DiMarco v. dimarco (1963) 60cal. 2d 387, 294, 33 cal. Rptr. 610), (b) but the delay is so inconsistent with the intent to assert the right to support that it substantiates the trial court’s decision for a waiver.”

Acceptance of a lesser amount of support and delay of 4 years without exemption:

However, it has been ruled hammer v. Hammer (2000) ___cal. app. 4th ___, that “mere acquiescence in paying an amount of child and spousal support less than that provided by a final dissolution judgment (is not) sufficient to constitute a waiver or prohibit collection of unpaid amounts” .

In hammer v. Hammer, upthe Court of Appeals found that… “it simply cannot be said that the four-year delay in the present case – especially in the absence of an express agreement to waive collection of the unpaid amount – was” ‘conduct so inconsistent with intent to assert the right in question to induce a reasonable belief that it has been waived,'” citing paboojian, up.

The passage of time is not enough in laches and waiver defenses:

As indicated in paboojian Y Hammer, up, the mere delay or passage of time is not enough to waive or prohibit spousal support. There must be a lack of intention to assert the right to aid, either by express agreement or an influence of circumstances indicating an intention to renounce, for Graham v. graham, (1959) 174cal. app. 2d 678, quote Panno v. Russian, up.

The same is true in the defense of eliminated laches. In fact, laches implies an unreasonable delay that causes undue prejudice to the party presenting the laches defense, according to Plescia’s marriage, up.

(The author, Roman P. Mosqueda, has practiced family law for over 20 years in California, New York, and the Philippines. He published a book: Manual of marriage and its dissolution.)