In what circumstances will a former partner be ordered to pay the fees of a plaintiff in a civil action seeking to regain custody of their children?

other actions in the civil suit.⁸ Similarly, in United States v. Cummings, 281 F.3d 1046 (9th Cir. 2002), the court affirmed a restitution award of attorneys' fees incurred by a mother who in separate civil proceedings sought to regain custody of her children. Her fees were "a direct and foreseeable result" of the former husband's criminal conduct of kidnapping their children, as "[t]here would have been no need to engage in civil proceedings to recover the children if [the husband] had not unlawfully taken them to Germany." Id. at 1052-53.