Fees Governed Instead By CRC 3.1185, Not Rule 8.278(c)(1).
In Marriage of Hogan, Case No. B265141 (2d Dist., Div. 1 Oct. 24, 2016) (unpublished), a couple in a marital dissolution action appealed a trial court’s award of appellate attorney’s fees to an appointed receiver for successfully defending a prior appeal involving the receivership. They argued that the receiver was precluded from obtaining the award because he failed to submit a costs memorandum as required under California Rules of Court, rule 8.278(c)(1). The appellate court disagreed, determining that the award of fees for the work of the receiver’s attorney on appeal was governed instead by rule 3.1184—a Rule of Court not requiring a costs memo as a condition of confirming a receiver’s request for an award of appellate fees.