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Family

Jan. 13, 2025

Laches, limitations & equity - Oh my!

In the recent cases of Shayan and Saraye, California courts addressed the application of laches and statute of limitations in family law, clarifying that while money judgments for attorney fees are enforceable without renewal, laches may apply to child support reimbursements if pursued too late.

Ira M. Friedman

Certified Family Law Specialist and a Fellow of the American Academy of Matrimonial Lawyers Friedman & Friedman

Email: imf@f-flaw.com

David Friedman

Partner and Certified Family Law Specialist Friedman & Friedman

Email: david@f-f-law.com

Shutterstock

In the recent case of In Re The Marriage of Zohreh McIntyre Shayan and Shahriyar S. Shayan (Los Angeles Superior Court Case No. SD 025162 and Court of Appeal Second Appellate District Case No. B323455) in which Los Angeles Superior Court Judge Elizabeth Scully was affirmed on appeal the Appellate Court discussed when, if ever, it is too late to enforce a Family Law Judgment for attorney's fees.

In another recent case, <...

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