In Alan S. v. Superior Court (2009) 172 Cal.App.4th 238, the court reversed an order requiring the husband to pay $ 9,000 of wife's attorney fees where the husband had a negative cash flow of about $ 800 a month, having incurred large credit card balances to pay his attorney, and the court failed to consider a host of relevant factors such as the respective equity of the two parties in their homes, the income of each party's new spouse or cohabitant, husband's child support payments and his exhaustion of his liquid assets. (Alan S., supra, 172 Cal.App.4th at pp. 241-243, 251-254.) In Alan S. v. Superior Court (2009) 172 Cal.App.4th 238, the appellate court reversed a trial court's need-based fee award on a writ petition presenting an important "access to justice" issue for the pro per ex-husband (Alan S., at p. 241) where the record reflected that there were "several significant relevant factors that the trial court did not consider," in ordering Alan to pay $ 9,000 in attorney fees in favor of Mary. (Id. at p. 242.) These factors included "Alan's negative cash flow of about $ 800 a month (he ran up a large credit card debt in order to pay a $ 25,000 attorney fee bill from the time when he was represented), the respective amounts of property owned by the parties (including some horses that Mary owns and apparently rents out and whether either of the parties has any equity in their respective homes), the $ 1,800 a month in child support that Alan pays to Mary . . . , new mate or new partner contributions to the respective households, . . . and, finally, the incurrence by Mary of at least a quantum of fees clearly not 'reasonably necessary' for the litigation to date." (Alan S., at pp. 242-233.) The Court of Appeal reversed the trial court's award of $ 30,000 in pendente lite attorney fees, concluding the court took a "truncated approach" to the matter and failed to consider the factors relevant to the divorcing couple's circumstances and the reasonableness of their conduct during the litigation. (Id. at pp. 255-256.) In the view of the Court of Appeal, the trial court had accepted at face value the contention Alan S. earned more money and could more readily bear the burden of attorney fees, even though his financial obligations had sapped his resources to the point he could not afford to retain counsel for himself. As the court observed, "There was, in short, much the trial court should have explored, but did not." (Id. at p. 256.)