Can a plaintiff waive his right to cross-examine his wife during a family law hearing?

during the October 23 hearing. However, as Wife acknowledges and this court has previously concluded in Mendoza v. Ramos (2010) 182 Cal.App.4th 680, the right to present live testimony can be waived.

Mendoza involved a child support action, in which the father argued that the trial court improperly denied him the right to cross-examine the mother at a hearing on his petition. We noted that while the father was "correct that Elkins[] confirms the rights of litigants in family law matters to the protections afforded in other civil proceedings ([Elkins], supra, 41 Cal.4th at p. 1345) [the father's] argument [was] misplaced in [that] case." (Mendoza v. Ramos, supra, 182 Cal.App.4th at p. 687.) We reasoned that "[n]either [party] requested live testimony at the hearing, nor did [the father] indicate to the court that he wished to have the opportunity to examine [the mother]. Instead, the parties relied on their filings, and on the arguments of counsel." (Ibid.) Thus, because the father failed to request testimony, this court concluded he forfeited his right to obtain relief. (Ibid.) This is because "issues not raised in the trial court may not be raised for the first time on appeal." (Ibid.)