In In re Marriage of Adams & Jack A. (2012) 209 Cal.App.4th 1543, the family court concluded that an evaluator was biased against the father, but denied the father's motion to remove the evaluator. (Id. at p. 1564.) The reviewing court noted that the facts set forth in father's removal motion were essentially undisputed; thus, the question of bias was one of law to be reviewed de novo. (Id. at pp. 1563-1564.) It declined to do so, however, because the family court's factual finding regarding bias was "clearly supported by substantial evidence." (Id. at p. 1564.) Based on this finding, the Adams court concluded the family court abused its discretion when it denied father's motion to remove the evaluator. (Ibid.)