Mother Was Not a Party, So Her Finances Were Irrelevant.
In Marriage of Bailey & Nation, Case No. B236851 (2d Dist., Div. 8 Jan. 14, 2013) (unpublished), the appellate court reversed a needs-based fee award to husband because no evidence was adduced showing that ex-wife could afford to compensate him for his family litigation. The fact that the lower court relied on the fact wife’s mother, a nonparty, had money did not mean the court could order the mother to finance ex son-in-law’s litigation. (In re Marriage of Schulze, 60 Cal.App.4th 519, 532 (1997).)