All in the Family

On Oct. 3, a unanimous Illinois Supreme Court in In re Marriage of Earlywine, 2013 IL 114779 (Ill. 2013) held, pursuant to 750 ILCS 5/501(c-1), that a court can order disgorgement of one party’s attorney fees in order to level the playing field in a dissolution of marriage action. A court may also order disgorgement of an advance payment retainer paid to an attorney if both parties lack …

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