Marriage of Conrad, Case No. D058756 (4th Dist., Div. 1 Dec. 20, 2011) (Unpublished).
In this one, husband was ordered to pay wife $2,200 in attorney’s fees. She claimed this was not enough, even though the opinion talked about an admission that wife was a compulsive buyer (apropos in this Yuletime season, we surmise). Wife’s main challenge was that husband did not file a “current” income and expense declaration before trial. Not so, said the appellate court. The local San Diego Superior Court rule did define “current” as within three months of trial, something husband was compliant with. Fee award affirmed.
Marriage of Gross, Case Nos. E051037 et al. (4th Dist., Div. 2 Dec. 20, 2011) (Unpublished).
Wife appealed the denial of pendente lite fees based on the “needs” statutes of Family Code section 2030 and 2032. She argued that husband had a history of unreported income, even though the lower court determined that neither side had any real income. No abuse of discretion under the circumstances, simply because the evidence from wife did not conclusively demonstrate that husband had any current income or assets.