Lack Of Fee Hearing Reporters’ Transcripts Sealed The Correctness Of The Orders.
The Third District, in Marriage of Samorano, Case Nos. C084143/C086540 (3d Dist. February 5, 2019) (unpublished), affirmed $7,500 in fees and sanctions awards in favor of ex-husband and against ex-wife under Family Code sections 2032 (needs-based provision) and 271 (sanctions provision). The main reason was that she did not provide any reporter transcripts of the fee hearings, so the orders were presumed correct. An inadequate appellate record sealed the deal.