Katherine sought full indemnity costs after a successful spousal support trial.
Christopher argued for no costs or a fraction.
The court found Katherine "far more successful" on key issues and her offers more reasonable, while Christopher's behavior was "far less reasonable," including unilaterally withdrawing from a joint retainer, tardy disclosure, and deliberately disobeying a temporary support order.
The court clarified that the recent amendment to Rule 24(11) of the Family Law Rules, allowing a trial judge to award costs for prior steps even if not reserved, is procedural and applies retroactively.
However, the judge deferred the final determination of costs for prior conferences, requesting further submissions from both parties.