Court of Appeal affirms order denying motion to recover attorney’s fees from GMSR’s client under Family Code section 2030

In re Marriage of Armour/Ritter (2010) 2010 Cal.App. Unpub. LEXIS 6108 (California Court of Appeal, Second District, Division Eight) [unpublished]. A wife in a marital dissolution proceeding incurred almost $700,000 in attorney’s fees litigating whether the confidential documents of her husband’s employer, which the spouses had used in litigating property division, should be sealed or publicly disclosed. After winning an appeal reversing an initial sealing order, the wife moved under Family Code section 2030 for an order compelling her husband, GMSR’s client, and his employer to pay her sealing-related attorney’s fees. The trial court denied the motion on multiple grounds, including that the fees did not sufficiently relate to the merits of the dissolution proceeding to justify fee shifting and that, notwithstanding the husband’s greater net worth, fee shifting was not needed to ensure parity of representation. The Court of Appeal upheld both findings as within the trial court’s discretion.