However, Error Was Not Prejudicial In Nature.
In Marriage of Bareket & Marcus, Case No. A136067 (1st Dist., Div. 4 Mar. 12, 2014) (unpublished), ex-wife was miffed when a lower court denied her request for Family Code section 2030 needs-based fees on the eve of a trial. On appeal, the reviewing court agreed that the lower court committed error in denying such fees simply because the matter was set for trial; needs based fees are appropriately awarded and the reasoning for granting/denying an award must be specified even in the wake of an evidentiary hearing or trial. However, the error was harmless: ex-wife did not incur a lot of fees and got much of the relief she wanted at the subsequent proceedings, where she represented herself. Affirmed based on a lack of prejudice.