Does a statement of decision need to be included in an order for attorney fees?

California, United States of America


The following excerpt is from Morcos-Jewgieniew v. Jewgieniew (In re Morcos-Jewgieniew), G050727 (Cal. App. 2016):

At oral argument mother complained the court failed to set out specific facts as to why the court ordered attorney fees in a substantially smaller amount than requested. But the court found the amount requested was unreasonable. And as father points out, even if a statement of decision was required, the court merely need set out ultimate findings of fact, not the specific evidence on which the court relied to make such findings. (Muzquiz v. City of Emeryville (2000) 79 Cal.App.4th 1106, 1125.)

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