Family Law: $45,000 Needs Based Fee Order Reversed Because It Was An Improper Judgment Modification

. . . Not Just A Clerical Change From Earlier Judgment.

Clerical error?

     In Marriage of Goldberg, Case No. C077384 (3d Dist. Jan. 25, 2016) (unpublished), husband contended that a $45,000 fee award was an improper modification of an earlier judgment which had only awarded $15,000 in needs-based fees to wife. The Third District reviewed the record and agreed, because the $30,000 augmentation from the earlier judgment was not just a clerical error subject to correction.