Over the last decade, beginning with two seminal cases being decided by the California Supreme Court in 2000, there have been significant developments in the law pertaining to premarital agreements. One common theme found in the flurry of recent reported appellate cases involving premarital agreements is the need for both parties entering into such agreements to utilize the services of experienced family law counsel. In fact, the California state legislature in response to the California Supreme Court's holding in Pendleton and Firemanfrom 2000, amended the California Uniform Premarital Agreement Act to specifically and expressly require that both parties have "independent legal counsel" if a waiver or limitation of spousal support is incorporated in a premarital agreement. By way of example, and there are many, in the recent holding of In re Marriage of Facter (2013) 212 Cal.App.4th 967, the court held that a premarital agreement that contained a waiver of spousal support prepared by a lawyer who had graduated from Harvard Law School was in part unenforceable. In Facter the court found that although the attorney who drafted the premarital agreements was a seasoned commercial transactional lawyer who practiced corporate law, he failed to follow some of the basic conventions which experienced family law attorneys follow in negotiating a premarital agreement. The fallout for the party in Facter who sought to enforce his premarital agreement after a failed 14 year marriage was devastating.