In re Marriage of Ousterman (1996) 46 Cal.App.4th 1090
Holding
In long-duration marriages, the trial court retains jurisdiction to entertain a motion to modify spousal support brought after the last date the original order required support to be paid, where FC §4336 jurisdiction has not been expressly terminated. Court found jurisdiction proper under §4336 to consider a wife’s modification motion filed after the original support obligation’s stated end date.
Relevance to this matter
Cited by name in Stipulated Judgment ¶62 and ¶63. The parties’ express waivers under those paragraphs preempt the Ousterman / §4336 default that would otherwise apply. Together with In re Marriage of Vomacka and In re Marriage of Brown, it completes the trio of “extension absent express termination” authorities the parties contracted around.