FAMILY LAW: ATTORNEY’S FEES: INADEQUATE FINDINGS; APPEALS: PRESERVATION: HUSBAND WAIVED OBJECTION TO INADEQUATE FINDINGS BY FAILING TO MOVE FOR REHEARING

Spreng v. Spreng, ___ So. 3d ___, 40 Fla. L. Weekly D309 (Fla. 5th DCA January 30, 2015)

The court affirmed an award of temporary attorney’s fees and costs to the wife, despite her concession of error. “Although [the trial court’s order] was deficient in its factual findings with regard to the factors set forth in Florida Patient’s Compensation Fund v. Rowe, 472 So. 2d 1145 (Fla. 1985), [the appellate court found] this error was not preserved for appeal because Husband never filed a motion for rehearing.”

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