On Nov. 30, the Illinois Supreme Court, in In re Marriage of Christine Goesel and Andrew Goesel, 2017 IL 122046 (2017), held that earned attorney fees — as in fees received for actual services rendered — are not “available” for turnover, or disgorgement, pursuant to a petition for interim attorney fees brought under Section 5/501(c-1) of the Illinois Marriage and Dissolution of Marriage Act and, thus, …
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