The following excerpt is from Sec. & Exch. Comm'n v. Vassallo, NO. CIV. S-09-0665 LKK/DAD (E.D. Cal. 2012):
18. For example, although the court makes no ruling on the subject, it may be that "[I]n California, property acquired prior to marriage is separate, while property acquired during the marriage is presumed community property." Patrick v. Alacer Corp. 201 Cal. App.4th 1326, 1339 (4th Dist. 2011).
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