Judgment Roll Limitations Drove the Result in this One.
Marriage of Notaro, Case No. C074200 (3d Dist. May 20, 2014) (unpublished) is a situation where an ex-wife appealed only obtaining an award of $3,000 out of a requested $15,335 in needs-based fees. The fee order was affirmed, for one major reason. Ex-wife elected to proceed on a clerk’s transcript—known as a “judgment roll” appeal—which limited review greatly, with the appellate court conclusively presuming evidence was presented to uphold the result below unless error was facially apparent, something which was not present in this particular case.