In In re Marriage of O'Connell (1992) 8 Cal.App.4th 565, husband filed a motion seeking reduction in his child and spousal support due to disability. Ex-wife's attorney offered by letter and phone call (but without a formal pleading in response to the motion) to agree, so long as she and her children were named beneficiaries to a life insurance policy. Husband was not present at the hearing, but was represented by counsel. When the request to modify the insurance was brought up at the hearing, husband's counsel objected on several grounds, including that it had not been made through formal pleadings since wife neither filed a responsive pleading nor filed an affirmative motion to have it heard, and husband's counsel "didn't know that until, I guess just a day or two ago when the attorneys discussed it on the telephone." (Id. at pp. 570-571, fn. 3.) The court ordered reductions in monthly spousal support to nothing, and greatly reduced the child support, but ordered that husband name his ex-wife and minor son as beneficiaries on the life insurance policy along with his current wife. When husband died shortly thereafter, ex-wife filed a motion seeking enforcement of the life insurance modification order alleging that husband had not changed beneficiaries before he died. Second wife filed a motion to vacate the order modifying the life insurance. In denying the motion to vacate, the court held that ex-wife was not required to "formally request" modifying husband's life insurance by written motion or opposition to husband's reduction motion "in order to put the life insurance in issue" because husband's "motion itself put the issue before the court." (Id. at pp. 574-575.) The court went on to describe that in "establishing and modifying spousal support, courts are required to consider a broad range of factors" by statute, citing Family Code section 4801, and the same is true for establishing and modifying child support. (Id. at p. 575.) The court continued, "Thus, courts have not been precluded from considering the big picture by the particular phrasing of a motion to establish or modify support. A motion to increase support has been held to put modification in general in issue and authorizes the court 'to either increase or decrease the payments to meet the equities of the situation,' though the opponent has not formally requested a decrease. " (Id. at p. 575.)