Request for Order (RFO) to terminate support; request for attorney fees
LAW & MOTION TENTATIVE RULINGS DEPARTMENT 5 May 7, 2026 8:30 a.m./1:30 p.m.
4. MARY CROWDER V. JEFFREY CROWDER PFL20120584
Respondent filed a Request for Order (RFO) on February 26, 2026, seeking a termination of permanent spousal support as well as termination of insurance payments for the parties’ adult daughter. Petitioner was personally served in accordance with Family Code § 215 on March 5, 2026. Respondent filed and served an Income and Expense Declaration on February 17, 2026.
Petitioner filed and served her Responsive Declaration on April 22, 2026, along with her Income and Expense Declaration. Petitioner objects to the termination of permanent spousal support and requests an increase in spousal support. Petitioner also seeks Family Code section 2030 attorney’s fees. Petitioner does not address the issue of health insurance.
The court finds this is a post-judgment request to modify spousal support and as such, the court must take testimony on the Family Code section 4320 factors. Parties are ordered to appear for the hearing to select mandatory settlement conference and trial dates.
The court finds that the issue of payment of the parties’ adult daughter’s medical insurance requires testimony. Parties are ordered to appear to appear for the hearing to select mandatory settlement conference and trial dates.
Regarding the request for attorney’s fees, the public policy of Family Code section 2030 is to provide “at the outset of litigation, consistent with the financial circumstances of the parties, parity between spouses in their ability to obtain effective legal representation.” In re Marriage of Keech,75 Cal. App. 4th 860, 866 (1999). This ensures each party has access to legal representation to preserve each party’s rights. In the face of a request for attorney’s fees and costs, the court is to make findings on “whether there is a disparity in access to funds to retain counsel, and whether one party is able to pay for legal representation of both parties.” Fam. Code § 2030(a)(2).
The court finds there is a disparity in income between the parties. The court finds Respondent does have the ability to pay some of Petitioner’s attorney’s fees. The court therefore grants the request for Family Code section 2030 attorney’s fees in the amount of $1,500. Payment may be made in one lump sum, or in monthly payments of $150 with the first payment due on May 15, 2026, directly to Petitioner’s counsel. Further payments are due on the 15th of each month until paid in full. If any payment is missed or late, the entire amount shall become immediately due and payable with legal interest.
Looking for case law or statutes not cited here? Search published authorities
Examples: “Why did the court rule this way?” · “What were the procedural grounds?” · “Is appearance required?”
LAW & MOTION TENTATIVE RULINGS DEPARTMENT 5 May 7, 2026 8:30 a.m./1:30 p.m.
All prior orders not in conflict with these orders remain in full force and effect. Respondent is directed to prepare the Findings and Orders After Hearing (FOAH); however, this order is effective immediately upon the court’s adoption of the tentative ruling and is not conditioned on the preparation of the FOAH.
TENTATIVE RULING #4: THE COURT FINDS THIS IS A POST-JUDGMENT REQUEST TO MODIFY SPOUSAL SUPPORT AND AS SUCH, THE COURT MUST TAKE TESTIMONY ON THE FAMILY CODE SECTION 4320 FACTORS. PARTIES ARE ORDERED TO APPEAR FOR THE HEARING TO SELECT MANDATORY SETTLEMENT CONFERENCE AND TRIAL DATES.
THE COURT FINDS THAT THE ISSUE OF PAYMENT OF THE PARTIES’ ADULT DAUGHTER’S MEDICAL INSURANCE REQUIRES TESTIMONY. PARTIES ARE ORDERED TO APPEAR TO APPEAR FOR THE HEARING TO SELECT MANDATORY SETTLEMENT CONFERENCE AND TRIAL DATES.
THE COURT FINDS THERE IS A DISPARITY IN INCOME BETWEEN THE PARTIES. THE COURT FINDS RESPONDENT DOES HAVE THE ABILITY TO PAY SOME OF PETITIONER’S ATTORNEY’S FEES. THE COURT THEREFORE GRANTS THE REQUEST FOR FAMILY CODE SECTION 2030 ATTORNEY’S FEES IN THE AMOUNT OF $1,500. PAYMENT MAY BE MADE IN ONE LUMP SUM, OR IN MONTHLY PAYMENTS OF $150 WITH THE FIRST PAYMENT DUE ON MAY 15, 2026, DIRECTLY TO PETITIONER’S COUNSEL. FURTHER PAYMENTS ARE DUE ON THE 15TH OF EACH MONTH UNTIL PAID IN FULL. IF ANY PAYMENT IS MISSED OR LATE, THE ENTIRE AMOUNT SHALL BECOME IMMEDIATELY DUE AND PAYABLE WITH LEGAL INTEREST.
ALL PRIOR ORDERS NOT IN CONFLICT WITH THESE ORDERS REMAIN IN FULL FORCE AND EFFECT. RESPONDENT IS DIRECTED TO PREPARE THE FINDINGS AND ORDERS AFTER HEARING (FOAH); HOWEVER, THIS ORDER IS EFFECTIVE IMMEDIATELY UPON THE COURT’S ADOPTION OF THE TENTATIVE RULING AND IS NOT CONDITIONED ON THE PREPARATION OF THE FOAH.
NO HEARING ON THIS MATTER WILL BE HELD UNLESS A REQUEST FOR ORAL ARGUMENT IS TRANSMITTED ELECTRONICALLY THROUGH THE COURT’S WEBSITE OR BY PHONE CALL TO THE COURT AT (530) 621-6725 BY 4:00 P.M. ON THE DAY THE TENTATIVE RULING IS ISSUED. CAL. RULE CT. 3.1308; LOCAL RULE 8.05.07; SEE ALSO LEWIS V. SUPERIOR COURT, 19 CAL.4TH 1232, 1247 (1999). NOTICE TO ALL PARTIES OF A REQUEST FOR ORAL ARGUMENT AND THE GROUNDS UPON WHICH ARGUMENT IS BEING REQUESTED MUST BE MADE BY PHONE CALL OR IN PERSON BY 4:00 P.M. ON
LAW & MOTION TENTATIVE RULINGS DEPARTMENT 5 May 7, 2026 8:30 a.m./1:30 p.m.
THE DAY THE TENTATIVE RULING IS ISSUED. CAL. RULE CT. 3.1308; LOCAL RULE 8.05.07.