Inadequate Record and Evidence Supporting Decision Guided Affirmance.
The Sixth District in Marriage of Naim and Price, Case No. H035497 (6th Dist. Dec. 16, 2010) (unpublished) affirmed a needs-based attorney’s fees order of $7,149 to ex-wife. Husband’s challenges were rejected on these grounds: (1) the family law judge did not have to make express findings on the Family Code section 4320 needs factors; (2) husband failed to make an adequate record by providing all the moving papers and evidence presented before the family law judge; and (3) the proof did show a disparity in income–husband had much more monthly income and assets than wife. No abuse of discretion was committed by the lower court in awarding “needs” fees to wife.