The judge already ruled the pair divorced, but separated the child custody issues.
A lower court judge ruled that Jolie’s request for disqualification came too late.
In May, Jolie and her attorneys criticized Ouderkirk for not allowing the couple’s children to testify in the proceedingsThe actress also said the judge “has failed to adequately consider” a section of the California courts code, which says it is detrimental to the best interest of the child if custody is awarded to a person with a history of domestic violence