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The party moving for conduct-based attorney fees has the burden of showing that the other party’s conduct “unreasonably contributed to the length or expense of the 18 proceeding.” (quotation omitted), rev. denied (Minn. Aug.

Geske v. 22 Marcolina, n.2 (Minn. App. 2001) (explaining that “disparity in income” is no longer “an adequate basis for a fee award”).

Geske v. Marcolina , -19 (Minn. App. 2001).

-1 7 n.1 (Minn. App. 2001) (noting caselaw tension over whether Minn. Stat. § 518.14, subd.

Marcolina, for his proposition that the district court “should have denied the request to withdraw.” The arguments are unconvincing.

The party moving for conduct-based attorney fees has the burden of showing that the other party’s conduct “unreasonably contributed to the length or expense of the proceeding.”

1 ; 817 n.2 (Minn. App. 2001) (noting that the attorney-fee statute— Minn. Stat. § 518.14, subd.

The party moving for conduct-based attorney fees has the burden of showing that the other party’s conduct “unreasonably contributed to the length or expense of the proceedings.” (quotations omitted).

d 813, 816 (Minn. App. 2001) (addressing the then-existing version of the attorney-fee statute).

“Conclusory findings on the statutory factors do not adequately support a fee award.” d 813, 817 (Minn. App. 2001).

The party moving for conduct-based attorney fees has the burden of showing that the other party’s conduct “unreasonably contributed to the length 12 or expense of the proceeding.”

-17 n.1 (Minn. App. 2001) (discussing lack of uniformity in caselaw).

1 (2022); -96 (Minn. App. 2007); d 813, 818-19 (Minn. App. 2001).

The party moving for conduct-based attorney fees has the burden of showing that the other party’s conduct “unreasonably contributed to the length or expense of the proceeding.”

The party moving for conduct-based attorney fees has the burden of showing that the other party’s conduct “unreasonably contributed to the length or expense of the proceeding.” (citations omitted).

“Generally, attorney fees in dissolution cases are governed by [section] 518.14, [subdivision] 1, which allows both need-based and conduct-based fee awards.”

t court did not make “true findings of fact on the evidence” and instead “merely recited the evidence with no proper analysis.” (stating that a district court’s recitation of the parties’ factual assertions “is not making true findings” because findings “must be affirmatively stated as findings of the trial court”); n.3 (Minn. App. 2001) (citing this aspect of Dean).

A district court’s failure to make specific findings on these statutory factors is “not fatal to an award where review of the order ‘reasonably implies’ that the district court considered the relevant factors and where the district court ‘was familiar with the history of the case’ and ‘had access to the parties’ financial records.’” (-26 (Minn. 1999)).

The requesting party bears the burden of establishing that the other party’s conduct unreasonably contributed to the length or expense of the proceeding, and the attorney fee award must also be supported by specific findings , Richards v. Richards

“Conclusory findings on the statutory 15 factors do not adequately support a fee award.”

1 (2022); -96 (Minn. App. 2007); -19 (Minn. App. 2001).

App. P. 139.05 (identifying procedure for seeking attorney fees on appeal); (stating that former Minn. R. Civ.

1 (2022); -19 (Minn. App. 2001).

“Conclusory findings on the statutory factors do not adequately support a fee award.”

“Conclusory findings on the statutory factors do not adequately support a fee award.” d 813, 817 (Minn. App. 2001).

In contrast, a district court may award conduct-based attorney fees “based on behavior occurring during the litigation process.”

1 (2020); -96 (Minn. App. 2007); - 19 (Minn. App. 2001).

See, -96 (Minn. App. 2007); - 19 (Minn. App. 2001).

-17 (Minn. App. 2001) (noting that district court did not identify authority 8 for its award of attorney fees but apparently inferring from that award that it was made under Minn. Stat. § 518.14, subd.

1, -19 (Minn. App. 2001), this court has identified circumst ances under which a district court can award attorney fees generated in litigation ancillary to a dissolution under Minn. Stat. § 518.14, subd.

See Madden, d at 702; Geske v. Marcolina , n.5 (Minn. App. 2001) (discussing conduct-based attorney fees).

8 “Conclusory findings on the statutory factors do not adequately support a fee award.”

26 considered the relevant factors and if “the di strict court was familiar with the history of the case and had access to the parties’ financial records.” Geske v. Marcolina , (quotations omitted).

may be made regardless of the recipient’s need for fees and regardless of the payor’s ability to contribute to a fee award.” Geske v. Marcolina , -19 (Minn. App. 2001); (noting that conduct-based attorney fees may be “based on the impact a party’s behavior has had on the costs of the litigation regardless of the re lative financial resources of the parties”).

But the district court may award conduct-based attorney fees “regardless of the recipient’s need for fee s and regardless of the payor’s ability to contribute to a fee award.”