California, United States of America
The following excerpt is from Taghavi v. Afkham, C068768 (Cal. App. 2013):
If there is some other basis for an award of legal fees on appeal under the Family Code, then the better practice is to apply to the trial court in the first instance for a determination of his entitlement to them and the amount. (Cf. Milman v. Shukhat (1994) 22 Cal.App.4th 538, 546.) We therefore deny the request without prejudice.
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