We often deal with cases where one side wishes to modify a previous spousal support spousal support order.  One of the leading cases involving this area is Irmo Gavron (1988) 203 Cal.App.3d 705, which advises that at the time of any spousal support judgment, a supported spouse should be given a Gavron warning, which dictates that self support is expected, and that spousal support will likely terminate if the supported party fails diligently to take steps to enhance his or her earning ability.  The court further noted that any such warning should indicate that the supported spouse should make every effort to diligently “enhance her (or his) earning ability through retraining and education, and if she (he) fails to do so, support could be reduced or terminated.”

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