Bittenson v. Bittenson
Annotate this Case
Family Code section 2034, subdivision (c) permits a family law court to reduce or limit a Family Law Attorney's Real Property Lien (FLARPL) after the lien is recorded. The Court of Appeal affirmed a pretrial discretionary order limiting husband's $250,000 pendente lite lien for attorney fees in a marital dissolution action.
The court held that the plain language of section 2034, subdivision (c) does not impose any timing requirement or otherwise limit the trial court's ability to revisit the propriety of a FLARPL. The court rejected the argument that section 2033, which addresses the ex parte objection procedure before a FLARPL is recorded, restricts the trial court's discretion to limit the amount of a FLARPL after it is recorded.
Some case metadata and case summaries were written with the help of AI, which can produce inaccuracies. You should read the full case before relying on it for legal research purposes.
This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply.