The award of $25,000 on account was well within the bounds of reasonable judicial discretion.232 Cal. App. 2d 191, 42 Cal. Rptr. 616, 623 (Ct. App. 1965). In Cruz, this court upheld attorney's fees where the trial court considered the requested amount of attorney's fees, the payments already paid to the attorney, and invoices presented by the attorney.

(Leavitt v. County of Madera (2004) 123 Cal.App.4th 1502, 1519.) Avnet v. Bank of America (1965) 232 Cal.App.2d 191 (Avnet), is instructive. In that case husband's principal defense to wife's application for temporary support was the invalidity of wife's divorce from her first husband, rendering the second marriage void.

(1) Respecting the first of these claims, it is accepted by Dorothy that "the authorities are practically unanimous in favor of the proposition that a remarriage estops the party entering into it from denying the validity of previous divorce." ( Chilcott v. Chilcott (1967) 257 Cal.App.2d 868, 870 [ 65 Cal.Rptr. 263]; see also Spellens v. Spellens (1957) 49 Cal.2d 210 [ 317 P.2d 613]; Rediker v. Rediker (1950) 35 Cal.2d 796 [ 221 P.2d 1, 20 A.L.R.2d 1152]; Avnet v. Bank of America (1965) 232 Cal.App.2d 191 [ 42 Cal.Rptr. 616]; 6 Witkin, Summary of Cal. Law (8th ed. 1974) Husband and Wife, pp. 4955-4958.) She nevertheless maintains the rule is of no moment here, since her marriage to Ralph Gentry was annulled, such that it never existed for purposes of the rule's application.

As the Family Law Act provision for attorney's fees is substantially a reenactment of the previous provision, it is useful to begin by considering the decisions rendered under the former section and to then consider whether they have been invalidated by the requirement of the Family Law Act that the community property be equally divided. (20) The purpose of an allowance to a wife for counsel fees on account is to enable her to have sufficient resources to adequately present her case. ( Bernheimer v. Bernheimer, 103 Cal.App.2d 643, 648 [ 230 P.2d 17]; Avnet v. Bank of America, 232 Cal.App.2d 191, 200 [ 42 Cal.Rptr. 616].) In order to be entitled to an award the wife must demonstrate that her resources are not sufficient to meet the expenses of litigation.

(1) Where a large amount of property is involved in the action the legal services necessarily required will usually justify a substantial pendente lite award of attorneys' fees. ( Dietrich v. Dietrich, 41 Cal.2d 497, 506 [ 261 P.2d 269]; Warner v. Warner, 34 Cal.2d 838, 842 [ 215 P.2d 20]; Avnet v. Bank of America, 232 Cal.App.2d 191, 202 [ 42 Cal.Rptr. 616].) (2) However, four factors make the present case unusual.