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Marriage of Faragalli
The trial court awarded Darleen Faragalli[1] $10,000 in attorney fees as a sanction under Family Code section 271 (all statutory citations are to the Family Code unless specified). Her former husband George argues the trial court made the order without notice to him, failed to hold a hearing on the matter, and improperly included fees that had already been paid or litigated. For the reasons expressed below, Court affirm.

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