The Court of Appeals in Khawam v. Wolfe decided on August 22, 2019, delineated all legal theories available to recover attorney’s fees in a child custody and by extension in relating family matters. Here, Wolfe moved to recover attorney’s fees ($700K) against Khawam for a rather protracted and vexatious litigation and under three theories: Common law theory of “necessaries” which permits an award of attorney’s fees in a child-custody case if the court finds that engaging an attorney was necessary to protect the interests of the child; The “bad faith” exception which permits recovering fees against a party who has
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