Marriage of Dolkhani and Izadpanahi CA2/7, B336871

Nahid H. Dolkhani and Kourosh Izadpanahi married in 2005 and had a child in 2010; Dolkhani filed for divorce in 2014, and a stipulated judgment was reached in 2017, though the parties later attempted reconciliation.
In 2018, Dolkhani refiled for dissolution, and the family court eventually entered a judgment (incorporating earlier terms) on September 30, 2021, over Izadpanahi’s objection; this judgment required each party to bear their own fees.
Izadpanahi filed three successive requests for attorney’s fees (RFOs), seeking funds to cover past and prospective legal fees; each was denied by the family court.
The court consistently found that Izadpanahi's requests were either unreasonable, duplicative, or for fees already denied, and noted his pattern of over-litigating the case, which resulted in previous sanctions against him.
Izadpanahi appealed the denial of his third RFO, arguing the family court failed to make mandatory findings as required by Family Code section 2030 regarding disparity of access to funds and ability to pay.

Issue	Izadpanahi's Argument	Dolkhani's Argument	Held
Whether denial of previous attorney’s fees requests (RFOs) was improper due to lack of findings under Family Code section 2030	Prior denials lacked required findings, so those motions remain open and the fees are still owed	Requests were duplicative, and Izadpanahi continued overlitigating issues already resolved	Izadpanahi's failure to appeal prior orders means they are final; relitigation of denied fees is not permitted
Whether court erred in denying request for $15,000 for limited scope representation in third RFO	Court failed to consider or make findings on this specific new request	Not specifically addressed in opposition	Izadpanahi forfeited the issue by not arguing or substantiating it in trial or on appeal; no prejudice shown
Whether the $60,000 in previously incurred fees were properly denied as duplicative	The court failed to make requisite findings under section 2030 for the third RFO	Requests were duplicative of prior denied requests, already covered	The court properly found requests duplicative; no evidence provided to show otherwise
Whether Izadpanahi’s alleged unreasonable litigation justified denial of attorney's fees	No unreasonable conduct since prior sanctions; fees sought were reasonable	Pattern of unreasonable litigation persisted, causing unnecessary costs	Court found continued excessive litigation supported denial of fees

In re Marriage of Bendetti, 214 Cal.App.4th 863 (Cal. Ct. App. 2013) (explains the purpose and process for attorney fee awards in marital dissolution)
In re Marriage of Falcone & Fyke, 203 Cal.App.4th 964 (Cal. Ct. App. 2012) (discusses the statutory criteria under sections 2030 and 2032 for fee orders)
In re Marriage of Keech, 75 Cal.App.4th 860 (Cal. Ct. App. 1999) (addresses the standard for awarding fees based on parties' total circumstances)
In re Marriage of Smith, 242 Cal.App.4th 529 (Cal. Ct. App. 2015) (sets forth abuse of discretion standard for reviewing fee awards)