In re the Marriage of Camille Beaumont and Andre Lassiter

CASE-FILE DOCUMENT · PETITION DISSOLUTION

Exhibit m19.exh.001 — Petition for Dissolution of Marriage

SUPERIOR COURT OF CALIFORNIA, COUNTY OF ALAMEDA Family Law Division

In re the Marriage of Petitioner: Camille Beaumont Respondent: Andre Lassiter

Case No.: [assigned on filing] PETITION — MARRIAGE (Dissolution)

Petitioner requests that the Court dissolve the parties' marriage and enter the orders set out below.

1. Residence. Petitioner and Respondent have each been residents of the State of California for more than six months and of the County of Alameda for more than three months immediately preceding the filing of this Petition.

1. Marriage. The parties were married on April 21, 2018, and separated on or about January 15, 2026. The period from marriage to separation is approximately seven years and nine months.

1. Minor child. There is one minor child of the marriage:

• Noémie Lassiter, born August 14, 2019.

1. Grounds. This Petition is brought on the basis of irreconcilable differences that have caused the irremediable breakdown of the marriage.

1. Legal and physical custody. Petitioner requests that the parties share joint legal custody of the minor child, that Petitioner be awarded primary physical custody, and that the Court order a parenting-time schedule that provides the child a predictable routine while affording Respondent regular and meaningful time consistent with the parties' work schedules.

1. Child and spousal support. Petitioner requests that the Court order child support in accordance with law and reserve jurisdiction over spousal support for both parties.

1. Property. Petitioner requests that the Court:

• determine the parties' rights in the community and separate property, including the parties' interests in Petite Marigny LLC and the family residence on Chabot Terrace, Oakland;
• confirm to each party his or her separate property, if any, subject to proof of characterization and tracing;
• divide the community estate; and
• order each party to complete and exchange the required declarations of disclosure.

1. Attorney's fees and costs. Petitioner requests an award of attorney's fees and costs as the Court finds just.

1. Other. Petitioner requests such other and further relief as the Court deems proper.

I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct.

Dated: February 27, 2026

/s/ Camille Beaumont Camille Beaumont, Petitioner

/s/ Amara Ellingboe Amara Ellingboe, Ellingboe & Ravndal LLP Attorneys for Petitioner

CASE-FILE DOCUMENT · SCHEDULE ASSETS DEBTS

Exhibit m19.exh.002 — Schedule of Assets and Debts (Community & Separate Property)

Petitioner's working schedule, prepared with counsel, for the required declarations of disclosure. Figures are estimates pending appraisal and discovery; characterization (community vs. separate) is disputed where noted.

In re the Marriage of Camille Beaumont and Andre Lassiter — as of June 2026

Real property

Business

Financial accounts

Separate-property claim asserted by Respondent

Vehicles and personal property

Debts

Note for the file. This schedule is a working draft. Two items are unresolved and material: (1) the characterization and tracing of Respondent's asserted $80,000 separate contribution, and (2) the valuation and division of the LLC, including the allocation between enterprise and personal goodwill. Both parties owe a duty of full and accurate disclosure of all assets, including recent account activity.

CASE-FILE DOCUMENT · RESTAURANT FINANCIALS

Exhibit m19.exh.003 — Petite Marigny LLC Financial Summary

Summary prepared from the LLC's tax returns and the general manager's supplementary books. For case reference; not an appraisal.

Petite Marigny LLC — Temescal, Oakland Entity: Two-member LLC (Camille Beaumont 50%, Andre Lassiter 50%), formed 2019 Opened for service: October 2019

Operating snapshot

• Seats: 38 dining seats plus a full bar
• License: Full on-sale liquor license (transferable, subject to approval)
• Lease: Storefront lease in Temescal; below-market base rent with several years remaining
• Staff: ~12 employees (kitchen, front of house, bar)
• Press: Favorable local write-ups in 2023 and 2024

Net income (per LLC returns)

Net income is stated after the owners' draws and swings materially year to year; 2024 was the strongest year on record, 2025 leaner.

Owner compensation

• Camille Beaumont: owner's draw ~$62,000/yr; runs front of house, staff, vendors, reservations, and day-to-day books.
• Andre Lassiter: owner's draw comparable to Petitioner's; executive chef, menu, kitchen, public face of the restaurant.

2019 buildout

• Total buildout cost (kitchen, bar, leasehold improvements): ~$155,000.
• Respondent asserts that approximately $80,000 of the buildout was funded from his pre-marital inheritance, transferred from a separate credit-union account. Supporting invoices and the account trail have not been produced in a complete form.
• The balance of the buildout was funded from a small-business loan (since repaid) and the couple's joint funds.

Flag for the file

The general manager and the jointly retained analyst have both noted irregularity in the recent months' cash deposits relative to point-of-sale totals. The cause is not established in this summary and requires follow-up against the bank statements and POS detail.

CASE-FILE DOCUMENT · SEPARATE PROPERTY TRACING

Exhibit m19.exh.004 — Separate-Property Tracing Documents (Described)

Description of the documents Respondent has produced, and identified gaps, on his asserted $80,000 separate-property contribution. Prepared for the file; the underlying documents are held in the matter file.

What Respondent asserts

Respondent Andre Lassiter claims that approximately $80,000 used in the 2019 restaurant buildout was his separate property, on the theory that it came from an inheritance he received in 2016 — before the April 2018 marriage — from his grandmother, Odette Lassiter, and that he kept it in a separate credit-union account in his name alone until it was applied to the buildout.

Documents produced to date

1. A single credit-union statement (dated 2016) showing a deposit of roughly $81,400 described as an estate distribution, into an account in Andre Lassiter's name only. (One month only; no continuous statements after this.)
2. A 2019 wire-transfer confirmation of $52,000 from an account ending in the same last four digits to the general contractor for the buildout.
3. Two contractor invoices from 2019 totaling ~$47,000 for kitchen equipment and bar millwork, marked "paid."
4. A handwritten note from Andre summarizing, from memory, how he believes the inheritance was spent.

Gaps identified

• No continuous account statements between the 2016 deposit and the 2019 wire — so the file cannot yet show that the separate funds remained separate and were not commingled with community earnings in the interim.
• The 2019 wire is $52,000, not $80,000; the remaining ~$28,000 of the asserted contribution is not documented by any transfer the file can tie to the separate account.
• No records establish whether other (community) funds also flowed through the same account before the buildout.
• The contractor invoices show that money was spent on the buildout, but not the source of that money.

Note for the file

Whether Respondent can establish that the $80,000 is traceable separate property — and, if so, whether he is entitled to a reimbursement before the community estate is divided — is a legal characterization question for counsel and the Court. It turns on the completeness of the tracing above, which is presently incomplete. Petitioner's position is that the funds were contributed to a jointly owned, jointly built community business and commingled with community labor and funds over seven years.

CASE-FILE DOCUMENT · VALUATION REPORT

Exhibit m19.exh.005 — Preliminary Business Valuation Report (Ferrante)

Prepared by: Daniel Ferrante, CPA/ABV Engagement: Jointly retained by both parties to value Petite Marigny LLC Report type: PRELIMINARY — subject to receipt of additional records Date: June 17, 2026

Scope and standard

I was jointly retained to estimate the fair value of Petite Marigny LLC as of a current date for purposes of the parties' property division. This preliminary report is based on the LLC tax returns (2022–2025), the general manager's supplementary books, the lease, an equipment list, and interviews with both owners. I have not yet received a complete set of bank statements, the point-of-sale transaction detail, or the 2019 buildout source records. My conclusions are preliminary and may change materially.

Components of value

1. Tangible assets. The kitchen and bar equipment and leasehold improvements have an estimated depreciated/replacement value in the range of $95,000–$130,000. The full on-sale liquor license is a transferable asset with independent market value, estimated at $45,000–$70,000, subject to regulatory transfer approval.

2. Lease. The below-market lease with several years remaining carries assignment value if the landlord consents; I have not assigned a separate figure pending confirmation of transferability.

3. Goodwill. Applying an income approach to normalized earnings, the enterprise supports goodwill above tangible value. The central issue is the allocation between enterprise goodwill (location, name, systems, recurring clientele, transferable with the business) and personal goodwill (attributable to Mr. Lassiter as chef and public identity, which may not transfer). My preliminary allocation places a majority but not the entirety of goodwill in the enterprise, but this range is wide and sensitive to assumptions about a chef transition.

Preliminary range of value

Subject to the caveats above, my preliminary estimate of the fair value of the enterprise (tangible + intangible, before any separate-property reimbursement adjustment) falls in a range of approximately $240,000–$320,000. I emphasize the width of this range and its preliminary nature.

Open items materially affecting the opinion

1. Separate-property tracing. Any reimbursement for Mr. Lassiter's asserted $80,000 buildout contribution is a legal characterization question on which I express no opinion, but it would adjust the parties' respective interests.
2. Cash-deposit irregularity. The recent months' cash deposits do not reconcile cleanly against POS totals. Until reconciled, normalized earnings — and therefore the goodwill figure — carry additional uncertainty.
3. Records still needed: complete bank statements, POS detail, and buildout invoices.

This is a preliminary report and should not be relied upon as a final opinion of value.

CASE-FILE DOCUMENT · TEXT MESSAGES

Exhibit m19.exh.006 — Co-Parenting Text-Message Thread (Excerpts)

Excerpts from text messages between Camille Beaumont and Andre Lassiter after the January 2026 separation, provided by Petitioner. Reproduced as sent; typos preserved.

Mon, Feb 2, 2026

Camille: You said you'd take Noémie Thurs but you have the wine dinner. I can't cover the floor AND get her. Which is it Andre: I'll move the wine dinner to Marguerite. I want my Thursdays. Camille: Then be ON TIME. Last time was 40 min and she was the last kid there.

Sat, Feb 21, 2026

Andre: Can I get her Sunday instead of Sat? Slammed sat. Camille: She has dance Sat morning. If you take Sunday you do the whole day not just dinner Andre: Fine. The whole day. I'm not trying to fight about this. Camille: Neither am I. I just need to be able to plan.

Wed, Mar 11, 2026

Andre: My lawyer says we shouldn't be hashing money over text. But you moved something out of the joint didn't you. It's short. Camille: I'm not doing this over text. Andre: So that's a yes. Camille: I said I'm not doing this over text, Andre.

Fri, Apr 3, 2026

Camille: Reminder Noémie has the dentist Tues 9am. I'll take her. You have her Tues night? Andre: Yes. I'll pick her up from aftercare at 5. On time. I heard you the first hundred times. Camille: Thank you. Genuinely.

Sun, May 24, 2026

Andre: She told me she wants "one house." Broke my heart. We have to do better than this for her. Camille: I know. I want that too. Can we just settle the schedule and stop making her the go-between? Andre: Yes. Let's let the lawyers do the money and you and I fix the schedule. For her. Camille: Deal.

CASE-FILE DOCUMENT · PARENTING JOURNAL

Exhibit m19.exh.007 — Petitioner's Parenting-Time Journal (Excerpts)

Excerpts from a journal kept by Camille Beaumont after the separation to track parenting time, hand-offs, and issues affecting Noémie. Provided by Petitioner.

Sat, June 14, 2025 — The birthday party. Andre was supposed to get Noémie from the Delaney girl's party at 4. I was on the floor for the dinner rush. Got a call from the host mom close to 5 — Andre finally showed, almost an hour late, and she said he smelled like drinking and seemed "not right." I called Yvette and she went and got Noémie so she wasn't in his car. Talked to Andre that night. He says it was "a couple drinks at a colleague's thing." I don't know how to feel. Noémie was fine but I keep thinking about the drive that didn't happen.

Thurs, Jan 22, 2026 — First full week since he moved out. We're improvising. He took her Tues and Thurs nights, I have the rest. She asked me why Daddy has "a small apartment." Told her both her homes are her home.

Tues, Feb 10, 2026 — Aftercare called; Andre was 35 min late again. Noémie was the last one there. She doesn't say anything but she notices. Have to build a schedule that doesn't depend on him leaving the kitchen mid-service.

Sat, Mar 7, 2026 — Good day, actually. Andre took her all day Sunday, brought her home happy and on time, made her the beignets. When he's on, he's a wonderful dad. That's what makes all of this so hard.

Wed, Apr 15, 2026 — Noémie had a rough drop-off, cried at the classroom door. Teacher says she's been a little clingy. Trying to keep her routine as steady as I can — same bedtime, same breakfast, same everything.

Sun, May 24, 2026 — Noémie told Andre she wishes she had "one house." He texted me about it, pretty shaken. We agreed to stop putting her in the middle and just fix the schedule ourselves. I want to believe we can.

Fri, June 20, 2026 — Sat down with my own calendar and mapped what a real schedule could look like around service hours — my nights on the floor, his nights in the kitchen, who covers mornings. It's a puzzle but it's solvable if we both stop keeping score.

CASE FILE · WITNESS STATEMENT TESSIER

Witness Statement — Marguerite Tessier

Witness ID: m19.wit.tessier Relationship: General manager and bookkeeper, Petite Marigny Taken: May 15, 2026, at the offices of Ellingboe & Ravndal LLP, Oakland

My name is Marguerite Tessier. I'm forty-five and I've been the general manager at Petite Marigny since 2021. I run the floor schedule, the vendor accounts, payroll, and the daily deposits, and I keep the supplementary books that our accountant works from at tax time. I know that restaurant about as well as anyone who isn't married to it.

People keep asking me who "really" makes the place work, and the honest answer is both of them, in different lanes. Andre is the kitchen and the name — the menu, the food, the face the regulars come to see. Camille is the business: reservations, staff, the vendors, the money. She built the systems I run every day. When people say the restaurant is "just Andre," that's not the whole picture. His cooking is the draw, no argument, but there's a real operation underneath it that Camille runs.

On the value question — I'm not an appraiser, so take this as an operator's view. We've got thirty-eight seats, a full liquor license, a good lease in a neighborhood people want to be in, a fully outfitted kitchen and bar, and a name that got us written up in 2023 and 2024. When we're on, we're turning tables twice on a Friday. The numbers swing a lot, though — 2024 was our best year by a wide margin, and other years are a lot leaner. A strong chef could keep the place running; it wouldn't be the same restaurant, but it wouldn't be worthless either.

I get asked about the original buildout money from 2019 — whose it was, what was separate. I honestly can't help there. I wasn't hired until 2021, and I've never seen the records from when they built the place out. That's a question for their accountant, not me.

I'll add one thing because I was asked directly and I'll be straight about it: this past year Andre was drinking more after service than he used to. In this business a lot of us have a drink after a hard night, so I don't want to make it sound like more than it was — I never saw him blow a service over it. But it was noticeable to me, and since he moved out he's seemed steadier. That's just what I observed.

I care about both of them and I care about the twelve people whose jobs depend on that restaurant staying open. I signed this because it's accurate.

— Marguerite Tessier

CASE FILE · WITNESS STATEMENT LARUE

Witness Statement — Yvette Larue

Witness ID: m19.wit.larue Relationship: Close friend of Camille Beaumont; godmother of Noémie Lassiter Taken: May 8, 2026, at the offices of Ellingboe & Ravndal LLP, Oakland

My name is Yvette Larue. I'm forty-one and I teach middle-school science here in Oakland. Camille and I have been friends since before she and Andre got married — I was at the wedding in 2018, and I'm Noémie's godmother. I'm at that house a lot. I help with pickups when the restaurant runs long, I've done bedtime a hundred times, and I love that little girl like she's my own.

Here's the honest truth about the parenting. Camille does the mornings and the school stuff — always has, because Andre's in that kitchen until eleven most nights. She's the one at drop-off, at the pediatrician, packing the lunch. Andre's not absent — when he's off, he's a wonderful, goofy dad, and Noémie is crazy about him. But the day-to-day, the routine, that's Camille. That's just how a restaurant marriage works, I guess.

I want to be careful about the next part because I don't want to hurt Andre, but you asked and I'm going to tell you what I saw. This past year or so, his drinking got worse. I'd notice it after service, at the house, the couple of times we all overlapped. And there was the Saturday last June with the birthday party.

Camille was working the dinner rush and Andre was supposed to get Noémie from a classmate's party. He was almost an hour late. The mom hosting it called Camille, kind of alarmed, and said Andre showed up and he smelled like alcohol and seemed off — unsteady, was the word. Camille called me in a panic and I drove over and got Noémie myself so she wasn't getting in a car with him. Noémie was fine, a little confused about why Auntie Yvette was there instead of Daddy. Camille had it out with Andre that night. I know it scared her, and I know she's been chewing on it ever since, because she doesn't want to be the person who uses it against him.

I don't know anything about the money side — the restaurant's worth, the inheritance, none of that. That's over my head and I stay out of it. What I can tell you is that Noémie needs a calm, steady schedule, and Camille is the steady one. I'd say the same thing to Andre's lawyer if they asked me.

I signed this because it's true.

— Yvette Larue

CASE FILE · WITNESS STATEMENT FERRANTE

Witness Statement — Daniel Ferrante, CPA/ABV

Witness ID: m19.wit.ferrante Relationship: Jointly retained business-valuation analyst Taken: June 18, 2026, at the offices of Ellingboe & Ravndal LLP, Oakland (interview accompanying the analyst's preliminary report)

My name is Daniel Ferrante. I am a certified public accountant with a business-valuation credential, and I was jointly retained by both parties to prepare a preliminary valuation of Petite Marigny LLC. This statement summarizes my observations; my numbers and methods are set out more fully in my preliminary report.

Valuing a small owner-operated restaurant is genuinely difficult, and I want to be candid about why. The tangible pieces are the easy part: the kitchen and bar equipment, the leasehold improvements, and the transferable liquor license have identifiable resale or replacement value, and the lease has value if it can be assigned. I have preliminary figures for each of those. The hard part is goodwill — how much of the restaurant's earning power is tied to the enterprise (the location, the name, the systems, the recurring clientele) versus tied personally to the chef. Those are treated very differently, and reasonable analysts can disagree about the split.

Here the question is sharp because Mr. Lassiter is both the chef and the public identity of the business, while Ms. Beaumont runs the operations and controls the systems and records. My preliminary view is that a meaningful portion of the value is enterprise goodwill that would survive a chef transition, but that a portion is personal to Mr. Lassiter and would be at risk if he left. I have not finalized that allocation.

Two items materially affect my work and are not yet resolved. First, I have been given the LLC tax returns and Ms. Tessier's supplementary books, but I have not received clean documentation tracing the roughly eighty-thousand-dollar buildout contribution from 2019 to a separate source — that tracing question is a legal characterization issue on which I express no opinion, but it affects any reimbursement adjustment to the parties' respective interests. Second, the parties' cash-deposit records for the recent months show some irregularity that I have flagged for follow-up and that I cannot yet reconcile against the point-of-sale totals.

My report is preliminary. I would want additional records — a full set of bank statements, the point-of-sale detail, and the buildout invoices — before I would offer a final opinion of value.

I signed this because it accurately reflects my preliminary work.

— Daniel Ferrante, CPA/ABV

BUSINESS EXHIBIT · ENGAGEMENT LETTER

Engagement Letter

ELLINGBOE & RAVNDAL LLP Attorneys at Law · Norsholm, Meridian

February 13, 2026

Camille Beaumont 48 Chabot Terrace Oakland, California

Re: Legal Representation — Dissolution of Marriage (Beaumont / Lassiter)

Dear Ms. Beaumont:

Thank you for retaining Ellingboe & Ravndal LLP. This letter sets out the terms of our engagement.

Scope of Representation. We will represent you as Petitioner in the dissolution of your marriage to Andre Lassiter, including matters of legal and physical custody and parenting time for your daughter, child support and spousal support, characterization and division of community and separate property (including the family residence and the parties' interests in Petite Marigny LLC), and any claim for reimbursement of a separate-property contribution. This engagement does not include any appeal, enforcement, or post-judgment modification, which would require a separate agreement.

Your Attorneys. Amara Ellingboe (senior attorney, $250/hour) will be primarily responsible for your matter, assisted by Marcus Ravndal (associate attorney, $225/hour). Paralegal time, when used, is billed at $120/hour. We staff each task at the most efficient appropriate level.

Retainer. You have deposited an advance fee retainer of $7,000, which we will hold in our client trust account. We will bill against the retainer as fees and costs are incurred and will provide you with itemized statements. This is an evergreen retainer: when the trust balance is drawn down by a billing, you agree to replenish it so that the balance is restored to $7,000 while the matter is active. Any unearned balance remaining at the conclusion of the representation will be refunded to you.

Billing. We bill in one-tenth-of-an-hour increments. Statements are issued periodically and are payable from the trust account; we will apply trust funds to a statement only after it is issued to you. Costs such as court filing fees, service fees, and any appraiser, evaluator, or business-valuation charges are billed as incurred; the parties have agreed to share the cost of a jointly retained valuation analyst.

Confidentiality and Disclosure. Everything you tell us in the course of this representation is protected by the attorney-client privilege and our duty of confidentiality. Please be candid with us, including about facts you find difficult; we can only protect your interests if we know the full picture. Please also understand that California law imposes on each spouse a duty to fully and accurately disclose all community assets and debts in this proceeding, and we will advise you on how to meet that obligation.

Cooperation and Communication. You agree to provide requested documents promptly, to keep us informed, and to make the final decisions on the objectives of the representation after our advice. We agree to keep you reasonably informed and to explain matters so you can make informed decisions.

If these terms are acceptable, please sign below and return one copy.

Sincerely,

/s/ Amara Ellingboe Amara Ellingboe, for Ellingboe & Ravndal LLP

Agreed and accepted:

______________________________ Date: ____________ Camille Beaumont

BUSINESS EXHIBIT · INTAKE & CONFLICTS

Intake (2026-02-09). Petitioner in a California marriage dissolution with one minor child; disputes over custody and a parenting schedule, the family residence, characterization and tracing of the respondent's asserted separate-property contribution to the parties' restaurant, and the valuation and division of that community-owned restaurant business.

Conflicts check (2026-02-11) — CLEAR. No prior or current representation of Andre Lassiter, Petite Marigny LLC, or any adverse party. Firm has not represented the restaurant. The jointly retained valuation analyst, Daniel Ferrante, has no prior relationship with the firm. No personal relationships identified between the firm's attorneys and the parties or witnesses.

BUSINESS EXHIBIT · BILLING STATEMENT (15 TIME ENTRIES)

BUSINESS EXHIBIT · INVOICES

BUSINESS EXHIBIT · CLIENT TRUST LEDGER

Client money is not firm money: every deposit and disbursement must reconcile to the penny.