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- Marriage of Hearn, Case No. A162932 (1st Dist., Div. 2 Aug. 10, 2023) (published)–$20,000 needs-based fee award to ex-wife under section 2030 was affirmed for two principal reasons: (1) although unemployed now, ex-husband—an attorney—had superior future earning capacity than ex-wife had; and (2) ex-husband had vigorously represented himself in the dissolution case, while wife had to hire outside counsel to protect her interests. [NOTE: Husband’s name is Rocky, coincidentally.]
- Marriage of Cole, Case No. A163975 (1st Dist., Div. 3 Aug. 11, 2023) (fee discussion unpublished)–$123,909 fee award to wife under section 271 was warranted where there was significant written discovery, a long deposition of ex-wife, and substantial law-and-motion work brought by ex-husband. [NOTE: In a companion unpublished case issued the same day, the appellate court affirmed a $6,000 section 271 sanction award granted against ex-wife and in favor of ex-husband.]
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