In re Marriage of Guilardi

In In re Marriage of Guilardi (2011) 200 Cal.App.4th 770, the parties had entered into an MSA containing a broad attorney's fees clause. This clause read: "'If either party brings an action or other proceeding to enforce this Agreement, or to enforce or modify any judgment or order made by a court in connection with this Agreement or to obtain any judgment or order relating to or arising from the subject matter of this Agreement, the prevailing party shall be entitled to reasonable attorney's fees and other costs from the other party as established by the court of competent jurisdiction.'" (Guilardi, at p. 775.) The Court held that the wife, who had not prevailed in her action, was barred by this clause from asserting a right to statutory attorney's fees under section 2030. (Guilardi, at pp. 775-776.)