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Long and winding road to Goesel and family law disgorgement

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, resolving a contentious split in the circuits.

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