4th Begins to Set a Limit on Fees

In what may be an attempt to back away from substantial fee awards between parties who each have significant assets, the Fourth District released the Von Baillou decision on July 5^th, reversing a fee award to a party who had substantial assets from the divorce on the grounds of lack of need. The ruling specifically points out that a financial review remains the first step for a fee award even under Rosen, and clearly requires at least some evidence of need…