Ex-Husband Could Not Show An Abuse Of Discretion, Especially With No Reporter’s Transcript.
In Marriage of Longinotti and Karpala, Case No. H051393 (6th Dist. Apr. 25, 2024) (unpublished), ex-husband requested the family law judge to modify a Family Code section 2030 need-based fees/costs award to ex-wife after he paid a substantial part of it (requesting forgiveness of the $17,000 remaining amount). Under section 2030(c), a lower court shall augment or modify an original fees award “as may be reasonably necessary for the prosecution or defense of the proceeding, or any proceeding related thereto, including after any appeal has been concluded.” The lower court refused the request, and the appellate court affirmed. Ex-husband could not show any abuse of discretion, especially given the lack of a reporter’s transcript to show the lower court’s reasoning at the hearing below.
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