Innovative Futuristic Award Sustained Upon Review.
Marriage of Chan, Case No. B242788 (2d Dist., Div. 8 Aug. 4, 2014) (unpublished) is interesting for the “needs-based” futuristic attorney’s fees component awarded to ex-wife under Family Code section 2030/2032.
In this one, the family law judge indicated that, for on-going fees incurred by ex-wife, ex-husband—who had some access to his parents’ largesse—had to pay dollar-for-dollar for future work in the case that he incurred with respect to his ex-wife for future representation. This was affirmed on appeal based on the disparity in income, especially given the $150,000 delinquency ex-wife owed to her attorney.