In Askew v. Askew (1994) 22 Cal.App.4th 942, husband responded to wife's dissolution action by filing a separate lawsuit against her for fraud, alleging that he married her and put property jointly in her name based on false representations that she loved him. The Askew court concluded that wife could be awarded section 2030(a) attorney fees for defending the fraud action. The Askew court reasoned that an improper motive for bringing the nondissolution action was not a prerequisite for finding such action to be related under section 2030(a). But in the case before it, the fraud action "involved matters which were the province of the family law court in the first place," and thus "the expense associated with the civil action was completely avoidable." ( Askew v. Askew, supra, 22 Cal.App.4th at p. 965.)