Erickson

Dennis Simpson appeals from an order requiring him to pay attorney fees directly to the law firm of Phillips, Lemer, Lauzon, & Jamra (Phillips), which previously represented his former wife, Debra Erickson, in their dissolution proceedings. The award to Phillips was premised on its motion for fees under In re Marriage of Borson (1974) 37 Cal.App.3d 632 [ 112 Cal.Rptr. 432 ] (Borson) (commonly known as a “Borson motion”). Borson allows a discharged attorney to pursue a request for direct fee payment from the former client’s spouse if the request is expressly or impliedly authorized by the former client. Simpson argues the trial court had no jurisdiction to make the award because an attorney substitution form, replacing Phillips with new counsel, had been filed before the trial court ruled on Phillips’s fee request. We reject his argument and affirm the order.

FACTUAL AND PROCEDURAL BACKGROUND

In July 2004, Erickson, represented by Phillips, filed a petition to dissolve her marriage to Simpson. Sometime after, Erickson and Phillips apparently agreed that Phillips would no longer be Erickson’s counsel. On December 17, 2004, Phillips filed a Borson motion on behalf of…