9
Rawat’s failure to state the facts fairly forfeits her evidentiary points. (Foreman &
Clark Corp. v. Fallon (1971) 3 Cal.3d 875, 881 (Foreman).) “[I]n addressing [a party’s]
issues we will not be drawn onto inaccurate factual ground.” (Western Aggregates,
Inc. v. County of Yuba (2002) 101 Cal.App.4th 278, 291.)6
B. Punitive Damages
Rawat claims that no substantial evidence supports her liability for ratifying her
husband’s reprehensible conduct. But because there is no reporter’s transcript of the trial,
Rawat cannot attack the factual finding that she and Singh were co-actors in matters
regarding Trust property. (See, e.g., Foust v. San Jose Construction Co., Inc. (2011) 198
Cal.App.4th 181, 186-187.)
We also reject Rawat’s claim that her conduct was insufficiently reprehensible to
merit an award of punitive damages. First, she does not state any facts about
reprehensibility, far less state them in favor of the judgment, and therefore forfeits the
claim. (Foreman, supra, 3 Cal.3d at p. 881.) Second, the trial court detailed a vicious
and premeditated course of conduct that meets the standard for punitive damages. “Of
the three guideposts that the [United States Supreme Court] court outlined [to establish
the propriety of an award of punitive damages], the most important is the degree of
reprehensibility of the defendant’s conduct. On this question, the high court instructed
courts to consider whether ‘[1] the harm caused was physical as opposed to economic; [2]
the tortious conduct evinced an indifference to or a reckless disregard of the health or
safety of others; [3] the target of the conduct had financial vulnerability; [4] the conduct