In In re Marriage of Woolsey (2013) 220 Cal.App.4th 881, a husband challenged a mediated marital settlement agreement, claiming "undue influence on him during the mediation rendered the agreement unenforceable ... ." (Id. at p. 888.) The husband did not attempt to introduce direct evidence showing the wife actually engaged in undue influence during the mediation; rather, he resorted to the rule that "when an interspousal transaction advantages one spouse, 'the law, from considerations of public policy, presumes such transactions to have been induced by undue influence.'" (In re Marriage of Haines (1995) 33 Cal.App.4th 277, 293 39 Cal. Rptr. 2d 673; see Woolsey, at p. 901.) The Woolsey court rejected the proffered presumption, concluding "the mediation confidentiality provisions of Evidence Code section 1119 protect the mediation process and preclude any claim of undue influence." (Woolsey, at p. 903.) Addressing the presumption directly, the court explained: "'To apply the presumption of undue influence to mediated marital settlements would severely undermine the practice of mediating such agreements. Application of the presumption would turn the shield of mediation confidentiality into a sword by which any unequal agreement could be invalidated. We do not believe that the Legislature could have intended that result when it provided for spousal fiduciary duties on the one hand and for mediation confidentiality on the other.'" (Id. at p. 902.)