In In re Marriage of Gavron (1988) 203 Cal.App.3d 705, the parties were married for approximately 25 years. Approximately 10 years after the parties' separation, the trial court abruptly terminated spousal support based on Wife's failure to become self-supporting. The Court of Appeal reversed. The Court of Appeal recognized that the lack of a spouse's good faith effort to become self-supporting can be a basis for modifying spousal support, but ruled the supported spouse must be made aware of the need to become self-supporting. (In re Marriage of Gavron, supra, 203 Cal.App.3d at p. 712.) In that case, the trial court terminated spousal support to a 57-year-old woman who had been married for 25 years to a dentist and had very little employment experience. (Id. at p. 708.) Six years after entry of the judgment of dissolution, and after 11 years of spousal support, the former husband moved for termination of support. Due to the wife's lack of diligence in becoming employed, the trial court ordered four additional months of support and then termination of all support, with the trial court retaining jurisdiction. (Id. at pp. 708-709.) On appeal, the Gavron court reversed on the ground that the supported spouse must be made aware of the obligation to become self-supporting and the consequences of failing to do so before the supporting spouse's support is modified due to failing to make good-faith efforts to become self-sufficient: "Inherent in the concept that the supported spouse's failure to at least make good-faith efforts to become self-sufficient can constitute a change in circumstances which would warrant a modification in spousal support is the premise that the supported spouse be made aware of the obligation to become self-supporting." (Gavron, supra, 203 Cal.App.3d at p. 712.) The Gavron court thus concluded: "It is particularly appropriate here that there should have been some reasonable advance warning that after an appropriate period of time the supported spouse was expected to become self-sufficient or face onerous legal and financial consequences." (Ibid.) Such notice is commonly referred to as "Gavron notice." The court in Gavron held that, "in the absence of a 'reasonable advance warning that after an appropriate period of time the supported spouse was expected to become self-sufficient or face onerous legal and financial consequences,' failure of the supported spouse to become self-supporting cannot be a 'changed circumstance' supporting a modification. Thus, what has become known as a 'Gavron warning' is a fair warning to the supported spouse he or she is expected to become self-supporting" (id. at p. 55), and such "warning" must include notice of the potential consequences of failing to become self-supporting. The Court of Appeal concluded that the trial court erred in reducing a party's spousal support from $ 1,100 per month to nothing after a 25-year marriage and approximately eight years of support, where "the record did not indicate that the unemployed 57-year-old wife had any prior awareness that the court would require her to become self-sufficient." The Gavron court held that a supported spouse must be made aware of the court's expectation that the spouse will attempt to become self-supporting: "Inherent in the concept that the supported spouse's failure to at least make good-faith efforts to become self-sufficient can constitute a change in circumstances which could warrant a modification in spousal support is the premise that the supported spouse be made aware of the obligation to become self-supporting. It is particularly appropriate here that there should have been some reasonable advance warning that after an appropriate period of time the supported spouse was expected to become self-sufficient or face onerous legal and financial consequences. . . .. . . For example, there may be an explicit statement by the court at the time of its original support order regarding employment expectations of the supported spouse. . . ." (Ibid.) In In re Marriage of Gavron, the original spousal support order was that the husband pay support in a given amount until further order of the court. Several years later, on the husband's motion, the trial court entered an order terminating support in four months' time. The Court of Appeal reversed, holding that "Inherent in the concept that the supported spouse's failure to at least make good-faith efforts to become self-sufficient can constitute a change in circumstances which could warrant a modification in spousal support is the premise that the supported spouse be made aware of the obligation to become self-supporting." ( In re Marriage of Gavron, supra, 203 Cal. App. 3d at p. 711.)