Remand to Consider in Light of Wife’s Changed Income Picture.
Updated, fresh income and expense statements are key in support and Family Code section 2030/2032 needs-based fee proceedings. Using outdated statements can result in a reversal under the circumstances, as it did in Marriage of Ching, Case No. G049628 (4th Dist., Div. 3 May 29, 2014) (unpublished).
The lower court utilized “stale” income and expense statements showing ex-wife had higher income and less expenses, contrasted with updated statements showing she made $8,000 less per year, and her monthly expenses increased $1,000 per month. Because the denial of needs-based fees was based on the stale information, the matter was reversed and remanded for a fee “redo.”