Failure to Reserve Jurisdiction May Be Costly.
The Second District, Division 6 provides all family law practitioners with an important reminder to make sure attorney’s fees is a reserved issue for future consideration by a family law judge in a judgment. A $10,000 fee award to husband under Family Code section 1101 (breach of fiduciary duties) in Dionisio v. Reyes, Case No. B215146 (2d Dist., Div. 6 Nov. 30, 2011) (unpublished) was reversed when wife correctly pointed out on appeal that absent a reservation of jurisdiction in a marital dissolution judgment, future attorney fee orders cannot be entered to account for legal services rendered prior to judgment. (Hogoboom & King, Cal. Practice Guide: Family Law (The Rutter Group 2011) ¶ 14:9, p. 13-4.)
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