What is the burden of providing an adequate record to assess error?

California, United States of America


The following excerpt is from Villalobos v. Villalobos (In re Marriage of Villalobos), F078477 (Cal. App. 2019):

without the reporter's transcript of the November 1, 2018 hearing. "It is the burden of the [appellant] to provide an adequate record to assess error." (Nielsen v. Gibson (2009) 178 Cal.App.4th 318, 324.) Because Paul chose not to provide the reporter's transcript, "we must treat this as an appeal 'on the judgment roll.' [Citations.]" (Ibid.) "[W]e ' "must conclusively presume that the evidence is ample to sustain the [trial court's] findings." ' [Citation.] Our review is limited to determining whether any error 'appears on the face of the record.' [Citations.]" (Id. at pp. 324-325.)

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