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Marriage of Sparks CA4/3
The trial court ordered David N. Sparks to pay a portion of the attorney fees incurred by his ex-wife, Julie A. Sparks, in litigating postjudgment matters. The court’s attorney fees award was based both on Julie’s financial need, and on David’s vexing conduct, pursuant to Family Code sections 2032 and 271, respectively. (All further statutory citations are to the Family Code.) David challenges the attorney fees award on appeal. We conclude the trial court did not err in making the award on either ground set forth in the court’s order; therefore, we affirm.

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