Discovery, Family Law: $165,188.75 Needs-Based Award To Ex-Wife Reversed Because Lower Court Failed To Consider Whether Her Discovery Efforts Were Unreasonable Or Over Litigated

Record Below Showed The Lower Court Pulled The Trigger Too Fast.

               Tragni v. Tragni, Case No. A169130 (1st Dist., Div. 5 Aug. 12, 2025) (unpublished) is one of those rare cases where a needs-based family law award to an ex-wife was reversed for an abuse of discretion.  We now explore why.

               Ex-wife received all requested Family Code 2020/2032 needs-based fees for discovery efforts, to the tune of $165,188.75.  Although ex-husband likely could bear it from a financial standpoint, the appellate panel did not believe the lower court reasonably evaluated whether her discovery efforts were reasonable or over-litigated in nature, especially deciding the fee award before a discovery referee came out with rulings.  Reversed for a remand on reasonableness of requested fees.

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