Fee disgorgement

On Nov. 30, the Illinois Supreme Court issued its opinion in In re the Marriage of Christine Goesel and Andrew Goesel, 2017 IL 122046. The court held that attorney fees earned by a party’s lawyer in the normal course of representation for past services rendered are not “available funds” to be disgorged and paid to the opposing parties’ attorney within the meaning of Section 501(c-1 …

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