No Exception Applied To Family Matters, With The Family Law Court Not Expressly Reserving The Matter For Later Junctures.
In In re Marriage of A.O. and Vologodskaya, Case No. A176388 (1st Dist., Div. 3 Oct. 28, 2026) (published), the issue on appeal was whether CRC 3.1702 deadlines applied to a prevailing party as far as a deadline to timely file an attorney’s fees request under Family Code section 6344 [domestic violence restraining order fee-shifting provision]. The appellate court determined that the 3.1702 Rules of Court deadlines applied, which required a reversal of a $39,000 fee recovery because the motion was untimely (filed 14 months after issuance of the restraining order)—there was no exception under the CRC for family law matters. The party obtaining the order below tried to argue that the motion was reserved for later determination so it was more open extended, but the record showed that the very orders indicated inapplicable for fee recovery and that there was no explicit preservation of those fee issues (versus other issues) in orders entered below.