In re the Marriage of Brewer v. Federici

In In re the Marriage of Brewer v. Federici (2001) 93 Cal.App.4th 1334, a marital dissolution case, the court rejected the wife's contention that once she had provided the information known to her, her former spouse had an obligation to search for additional information. The court observed that the Family Code imposes fiduciary obligations on both spouses that include the obligation to make full, accurate and complete disclosures to one another and a continuing duty to update and augment information. The court held "that a spouse who is in a superior position to obtain records or information from which an asset can be valued and can reasonably do so must acquire and disclose such information to the other spouse." (Id. at p. 1348.)