In re Marriage of Egedi

In In re Marriage of Egedi (2001) 88 Cal. App. 4th 17, the husband and wife hired an attorney to prepare a marital settlement agreement (MSA) and signed a conflict of interest waiver. After the wife fully performed her MSA obligations, the husband moved to set aside the MSA on the ground that the attorney's disclosures were insufficient to enable the parties to give informed consent to dual representation. Absent evidence of unconscionability or unfairness, we held that the husband could not disregard the waiver and "seize upon the subsequent conduct of the attorney to invalidate the MSA." ( Id., at p. 25.)