← LexyCorpus index

LexyCorpus case page

CourtListener opinion 4180140

Date unknown · US

Extracted case name
In re Marriage of Kane
Extracted reporter citation
806 F.3d 414
Docket / number
Second Division Docket No. 2-15-0774
QDRO relevance 5/5Retirement relevance 5/5Family-law relevance 5/5gold label pending
Research-use warning: This page contains machine-draft public annotations generated from public opinion text. The headnote is not Willie-approved gold-label work product and is not legal advice. Verify the full opinion and current law before relying on it.

Machine-draft headnote

Machine-draft public headnote: CourtListener opinion 4180140 is included in the LexyCorpus QDRO sample set as a public CourtListener opinion with relevance to QDRO procedure / domestic relations order issues. The current annotation is conservative: it identifies source provenance, relevance signals, and evidence quotes for attorney/agent retrieval. It is not a Willie-approved legal headnote yet.

Retrieval annotation

Draft retrieval summary: this opinion has QDRO relevance score 5/5, retirement-division score 5/5, and family-law score 5/5. Use the quoted text and full opinion below before relying on the case.

Category: QDRO procedure / domestic relations order issues

Evidence quotes

QDRO

g the statement; otherwise, the objection would be considered waived. Canulli filed his appearance on behalf of Gregory on July 23, 2014. On September 23, 2014, the trial court entered an order awarding Canulli $37,500 in interim attorney fees, by way of a qualified domestic relations order that partially liquidated Heather's retirement account. Canulli's billing records indicated that from July 1, 2014, through September 23, 2014, he billed Gregory approximately $35,000 in attorney fees. On January 15, 2015, Canulli filed a second petition for interim fees, seeking an additional $72,000. According to the petition, said sum would satisfy h

retirement benefits

anulli filed his appearance on behalf of Gregory on July 23, 2014. On September 23, 2014, the trial court entered an order awarding Canulli $37,500 in interim attorney fees, by way of a qualified domestic relations order that partially liquidated Heather's retirement account. Canulli's billing records indicated that from July 1, 2014, through September 23, 2014, he billed Gregory approximately $35,000 in attorney fees. On January 15, 2015, Canulli filed a second petition for interim fees, seeking an additional $72,000. According to the petition, said sum would satisfy his then-unpaid fees of $37,000 and provide an additiona

domestic relations order

ement; otherwise, the objection would be considered waived. Canulli filed his appearance on behalf of Gregory on July 23, 2014. On September 23, 2014, the trial court entered an order awarding Canulli $37,500 in interim attorney fees, by way of a qualified domestic relations order that partially liquidated Heather's retirement account. Canulli's billing records indicated that from July 1, 2014, through September 23, 2014, he billed Gregory approximately $35,000 in attorney fees. On January 15, 2015, Canulli filed a second petition for interim fees, seeking an additional $72,000. According to the petition, said sum would satisfy h

Source and provenance

Source type
courtlistener_qdro_opinion_full_text
Permissions posture
public
Generated status
machine draft public v0
Review status
gold label pending
Jurisdiction metadata
US
Deterministic extraction
reporter: 806 F.3d 414 · docket: Second Division Docket No. 2-15-0774
Generated at
May 14, 2026

Related public corpus pages

Deterministic links based on shared title/citation terms and QDRO / retirement / family-law retrieval scores.

Clean opinion text

Digitally signed by
 Reporter of Decisions
 Illinois Official Reports Reason: I attest to the
 accuracy and integrity
 of this document
 Appellate Court Date: 2017.05.25
 16:02:06 -05'00'

 In re Marriage of Kane, 2016 IL App (2d) 150774

Appellate Court In re MARRIAGE OF GREGORY PHILLIP KANE, Petitioner-
Caption Appellee, and HEATHER ANN KANE, Respondent-Appellee
 (Michael D. Canulli, Appellant).

District & No. Second Division
 Docket No. 2-15-0774

Filed December 29, 2016
Rehearing denied March 28, 2017

Decision Under Appeal from the Circuit Court of Du Page County, No. 14-D-1199;
Review the Hon. Linda E. Davenport, Judge, presiding.

Judgment Affirmed.

Counsel on Michael D. Canulli, of Naperville, appellant pro se.
Appeal
 Natalie M. Stec, of Wolfe & Stec, Ltd., of Woodridge, for appellee
 Gregory Kane.

 Amy L. Jonaitis and James M. Quigley, of Beerman Pritikin Mirabelli
 Swerdlove LLP, of Chicago, for other appellee.

Panel JUSTICE SPENCE delivered the judgment of the court, with opinion.
 Justices McLaren and Schostok concurred in the judgment and
 opinion.
 OPINION

¶1 This dispute concerns fees sought by attorney Michael D. Canulli, who represented
 petitioner, Gregory Phillip Kane, during a portion of his dissolution-of-marriage proceeding.
 Upon withdrawing as counsel, Canulli filed against Gregory a petition for setting final fees and
 costs pursuant to section 508(c) of the Illinois Marriage and Dissolution of Marriage Act (Act)
 (750 ILCS 5/508(c) (West 2014)), and against respondent, Heather Ann Kane, a petition for
 contribution pursuant to section 503(j) of the Act (750 ILCS 5/503(j) (West 2014)). In both
 petitions, Canulli sought an award of approximately $48,000, which was in addition to the
 $37,500 that he had already been paid. Following a full evidentiary hearing, the trial court
 denied Canulli's request for contribution from Heather, but awarded Canulli $12,500 on his
 petition against Gregory. Because the trial court's rulings on the petitions were not an abuse of
 discretion, we affirm.

¶2 I. BACKGROUND
¶3 Gregory and Heather were married in 1995 and have two minor children. In June 2014,
 Gregory filed a pro se petition for dissolution of marriage. He thereafter retained Canulli on
 July 1, 2014. Canulli and Gregory's written engagement agreement provided that, if Gregory
 had an objection regarding any of Canulli's billing statements, he would notify Canulli in
 writing within seven days of receiving the statement; otherwise, the objection would be
 considered waived. Canulli filed his appearance on behalf of Gregory on July 23, 2014. On
 September 23, 2014, the trial court entered an order awarding Canulli $37,500 in interim
 attorney fees, by way of a qualified domestic relations order that partially liquidated Heather's
 retirement account. Canulli's billing records indicated that from July 1, 2014, through
 September 23, 2014, he billed Gregory approximately $35,000 in attorney fees. On January 15,
 2015, Canulli filed a second petition for interim fees, seeking an additional $72,000.
 According to the petition, said sum would satisfy his then-unpaid fees of $37,000 and provide
 an additional retainer of $35,000.
¶4 On February 4, 2015, Canulli sent Gregory an email, stating that his balance due was
 nearly $43,000, that he would be willing to stay on the case if Gregory and Heather entered an
 agreed order to each receive $200,000 from Heather's retirement account, and that Gregory
 would have to further agree to use $90,000 to pay Canulli's fees, with the surplus funds
 constituting an additional retainer.
¶5 Gregory did not agree, and on February 10, 2015, Canulli filed an emergency motion to
 withdraw as counsel, alleging an inability to communicate with Gregory and unpaid attorney
 fees. On February 13, 2015, the trial court granted Canulli's request to withdraw his
 appearance and also granted him leave to file fee petitions. Gregory represented himself for
 several weeks and then retained new counsel, who entered an appearance on April 23, 2015.
 Said counsel continues to represent Gregory in this appeal.
¶6 Within the dissolution action, on April 15, 2015, Canulli filed against Gregory a petition
 for setting final fees and costs pursuant to section 508(c) of the Act. Canulli also filed against
 Heather a petition for contribution pursuant to section 503(j) of the Act. The engagement
 agreement and 28 pages of itemized billing statements were among the exhibits attached to the
 fee petitions. In both petitions, Canulli acknowledged that he had already been paid $37,500 in
 fees, but he alleged that he was owed an additional $48,000.

 -2-
 ¶7 On May 1, 2015, the trial court entered a judgment for dissolution of marriage, which
 incorporated a marital settlement agreement and a joint parenting agreement. Said judgment
 awarded Gregory and Heather joint legal custody of the children, awarded Heather primary
 residential custody of the children, established a visitation schedule, and awarded Gregory
 $27,000 in maintenance in gross.
¶8 The trial court held a day-long evidentiary hearing on Canulli's fee petitions on July 2,
 2015. The court took judicial notice of the court file and admitted into evidence Canulli's 28
 pages of itemized billing statements, which reflected that he had billed Gregory for 268.7
 hours from July 2014 until he withdrew in February 2015. At the hearing, Canulli testified, in
 relevant part, as follows. He had practiced family law for 38 years. Gregory filed a number of
 pleadings pro se, which Canulli agreed was not normal or customary. The total fees incurred in
 Canulli's representation of Gregory were $85,529.86, of which he had been paid $37,500.
 Canulli thus sought the remaining balance of more than $48,000. Gregory and Heather had no
 ability to communicate or resolve any matters in the case, and "the case was litigious on both
 ends." Gregory was "unusually extraordinarily emotional" about the divorce. Gregory and
 Canulli exchanged emails almost every day, and sometimes more than once a day. Canulli also
 testified as to his billing practices that he recorded services contemporaneously when rendered
 and that he reviewed each bill for accuracy before mailing it to Gregory.
¶9 On cross-examination, Canulli was questioned regarding billing entries that opposing
 counsel asserted were unreasonable and unnecessary. Much of the hearing was spent going
 line-by-line through these entries. Canulli was questioned regarding time that he billed to
 review pleadings that, according to his billing statements, were filed by Heather when in fact
 no such pleadings had been filed. Canulli also billed for drafting motions that were not noticed
 or presented to the court and in some cases never filed. Canulli acknowledged that he did not
 prepare for trial, nor did he prepare a trial notebook, parenting agreement, or marital settlement
 agreement. On several days he billed more than 10 hours on Gregory's case.
¶ 10 Gregory testified as follows. He was employed by the Illinois River Winery, a corporation
 of which he was the sole shareholder and director and from which he drew an annual salary of
 $18,000. Gregory was awarded the business by way of the parties' marital settlement
 agreement. The corporation had recently emerged from chapter 11 bankruptcy, and Gregory
 operated it judgment-free. The gross receipts for the winery in 2014 were approximately
 $500,000, and its checking account contained approximately $3000. The winery owned the
 real property it was situated on, but the property was encumbered by several loans, totaling
 approximately $200,000. By way of the marital settlement agreement, Gregory was receiving
 maintenance from Heather, and he also received approximately $225,000 from Heather's
 retirement account. In April 2015, Gregory received $20,000 from the settlement of a
 personal-injury claim.
¶ 11 Heather then testified as follows. She earned approximately $134,000 per year working at
 the Nielsen Company, and she had received a bonus in excess of $40,000 in each of the prior
 three years. By way of the marital settlement agreement, Heather received the marital
 residence, which was valued at $355,000 but encumbered by a mortgage of $208,000 and a
 home-equity line of credit that exceeded $200,000, both of which were solely Heather's
 responsibility. The marital residence was "under water." After the payment of her legal fees
 and a distribution to Gregory pursuant to the marital settlement agreement, her retirement
 account was worth approximately $200,000. Also pursuant to the marital settlement

 -3-
 agreement, Heather was responsible for $43,000 of credit card debt incurred by the parties
 during the marriage. Heather paid tuition for the younger child to go to private school. She was
 paying maintenance to Gregory, and she was not receiving child support from him.
¶ 12 At the conclusion of the hearing, the court first observed that the parties stipulated to the
 reasonableness of Canulli's $304 hourly rate, which included a $9 administrative fee. In ruling
 on the reasonableness of Canulli's fees, the court found that "the majority of the work that was
 done was not necessary nor [sic] reasonable." The court agreed that Gregory was a "difficult"
 client who "contacted [Canulli] a lot," but it stated that Canulli encouraged Gregory's "rogue
 behavior" by fostering, tolerating, and aiding him in filing pro se petitions, "which did nothing
 to control the litigation" and allowed Gregory to take "unreasonable positions." The court
 noted that only two hearings were held while Canulli was on the case and that no depositions
 were taken. The court stated that Canulli's billing statements, though very detailed, were
 "absolutely form over content at some point because [there were] no substantive things being
 done in the case." The court denied Canulli's request for contribution from Heather, but it
 found that he was entitled to a total of $50,000 from Gregory for his work on the case. As
 Canulli had already been paid $37,500, the court awarded Canulli $12,500, to be paid by
 Gregory.

¶ 13 II. ANALYSIS
¶ 14 Before addressing the merits of the appeal, we must first address our own jurisdiction. We
 previously dismissed this appeal pursuant to In re Marriage of Knoerr, 377 Ill. App. 3d 1042
 (2007). Though no party had raised the issue, we discovered that a contempt petition filed by
 Gregory remained pending in the trial court when Canulli filed his notice of appeal on July 31,
 2015. As the appealed order lacked a finding, pursuant to Illinois Supreme Court Rule 304(a)
 (eff. Jan. 1, 2015), that there was no just reason for delaying either enforcement or appeal or
 both, we dismissed the appeal as premature. In the dismissal order, we commented that Illinois
 Supreme Court Rule 303(a)(2) (eff. Jan. 1, 2015) could potentially allow Canulli to establish
 the effectiveness of his July 31, 2015, notice of appeal. Reiterating the procedure set forth in
 Knoerr, we stated that, "if the trial court has already disposed of the [contempt] petition ***
 and all other subsequently filed claims, if any, Canulli may file a petition for rehearing and to
 supplement the record with the appropriate orders to establish our jurisdiction over this
 appeal."
¶ 15 Canulli timely filed a petition for rehearing and supplemented the record with several
 filings and trial court orders. Included in the supplemental record is an order entered on
 September 14, 2015, that disposed of the contempt petition. Said order also disposed of a
 motion for sanctions that Heather had apparently filed, and the order indicated that the case
 would be taken "off call." Though an additional motion appears in the supplemental record, it
 was filed more than 30 days after the entry of the September 14, 2015, order, and it was
 disposed of on April 12, 2016. Thus, based on our review of the supplemental record, all
 matters in the trial court appear resolved.
¶ 16 Pursuant to Illinois Supreme Court Rule 367(d) (eff. Mar. 8, 2016), we ordered Gregory
 and Heather to respond to the petition for rehearing, and they make similar arguments in
 opposition to it. Though they acknowledge that the contempt petition was resolved on
 September 14, 2015, they assert that we still lack jurisdiction because Canulli did not file a new
 or amended notice of appeal within 30 days of that date. They also argue that Rule 303(a)(2)

 -4-
 cannot be used to establish the effectiveness of the July 31, 2015, notice of appeal because, as
 a "condition precedent" for the rule to apply, a timely postjudgment motion must have been
 filed in the trial court. Rule 303(a)(2) provides, in pertinent part, as follows:
 "When a timely postjudgment motion has been filed by any party, *** a notice of
 appeal filed before the entry of the order disposing of the last pending postjudgment
 motion, or before the final disposition of any separate claim, becomes effective when
 the order disposing of said motion or claim is entered." Ill. S. Ct. R. 303(a)(2) (eff. Jan.
 1, 2015).
 Gregory and Heather stress that Gregory's contempt petition was not a postjudgment motion
 because it did not request at least one of the forms of relief contained in section 2-1203 of the
 Code of Civil Procedure (735 ILCS 5/2-1203 (West 2014)), namely, rehearing, retrial,
 modification of the judgment, vacation of the judgment, or other relief directed against the
 judgment.
¶ 17 Though we agree that a postjudgment motion was not filed in this case, the absence of such
 a motion does not preclude Rule 303(a)(2) from "saving" a premature notice of appeal where
 the notice was filed before the final disposition of any separate claim that is later resolved.
 Indeed, this court has long interpreted Rule 303(a)(2) to allow the effectuation of a notice of
 appeal upon the resolution of a pending claim—even in the absence of a postjudgment motion.
 See, e.g., McMackin v. Weberpal Roofing, Inc., 2011 IL App (2d) 100461; People ex rel.
 Madigan v. Illinois Commerce Comm'n, 407 Ill. App. 3d 207 (2010); Suburban Auto
 Rebuilders, Inc. v. Associated Tile Dealers Warehouse, Inc., 388 Ill. App. 3d 81 (2009);
 Knoerr, 377 Ill. App. 3d 1042; In re Marriage of Valkiunas, 389 Ill. App. 3d 965 (2008).
¶ 18 In Valkiunas, we rejected an argument similar to the one that Gregory and Heather now
 advance. There, the petitioner appealed orders that were entered on February 8, 2008, and
 March 3, 2008—neither of which contained a Rule 304(a) finding. We initially dismissed the
 appeal pursuant to Knoerr because, when the petitioner filed her notice of appeal, two civil
 contempt petitions remained pending in the trial court. Valkiunas, 389 Ill. App. 3d at 966.
 Following the procedure set out in Knoerr, the petitioner thereafter filed a petition for
 rehearing and supplemented the record with an order entered on June 24, 2008, that disposed of
 both contempt petitions. However, the supplemented materials also reflected that, on May 14,
 2008 (after the notice of appeal was filed), the respondent filed a motion to disqualify the
 petitioner's attorney, and the motion remained pending as of the June 24, 2008, order. The
 petitioner contended that her notice of appeal became effective when the contempt petitions
 were resolved, despite the pendency of the motion. She further argued that the motion to
 disqualify her attorney was not a postjudgment motion. Id. at 968.
¶ 19 In interpreting Rule 303(a)(2), we noted that there is "nothing magical about the date the
 notice of appeal was actually filed, and the plain meaning of the rule is that the notice of appeal
 ‘becomes' effective on the date the impediment to our jurisdiction is removed." Id. We held
 that, although one jurisdictional impediment was removed on June 24, 2008, the pendency of
 the motion to disqualify impeded our jurisdiction such that the notice of appeal was still
 premature. Id. In so ruling, we rejected the petitioner's argument—that Rule 303(a)(2) did not
 apply because the motion to disqualify is not a postjudgment motion—because it ignored the
 possibility that the motion was a separate claim under Rule 303(a)(2). We also noted that a
 "pending claim" under Rule 303(a)(2) is the same as a "claim" under Rule 304(a), meaning

 -5-
 any "right, liability or matter raised" in an action, and that the motion to disqualify was a
 pending "matter" raised in the action. Id.
¶ 20 Based on our practice of interpreting Rule 303(a)(2) to allow the effectuation of a notice of
 appeal upon the resolution of a pending claim, and especially in light of Valkiunas, we reject
 Gregory's and Heather's argument that Rule 303(a)(2) is inapplicable, and we find that the
 notice of appeal became effective on September 14, 2015—when the contempt petition was
 resolved. As a result, we have jurisdiction over this appeal, and we accordingly grant the
 petition for rehearing.
¶ 21 We now turn to the merits of the appeal. Section 508(c) of the Act sets forth the rules for a
 final hearing for a trial court's determination of attorney fees and costs against the attorney's
 own client after the attorney has withdrawn. The statute provides, in relevant part, as follows:
 "(3) The determination of reasonable attorney's fees and costs *** is within the
 sound discretion of the trial court. The court shall first consider the written engagement
 agreement and, if the court finds that the former client and the filing counsel, pursuant
 to their written engagement agreement, entered into a contract which meets applicable
 requirements of court rules and addresses all material terms, then the contract shall be
 enforceable in accordance with its terms, subject to the further requirements of this
 subdivision (c)(3). Before ordering enforcement, however, the court shall consider the
 performance pursuant to the contract. Any amount awarded by the court must be found
 to be fair compensation for the services, pursuant to the contract, that the court finds
 were reasonable and necessary." 750 ILCS 5/508(c)(3) (West 2014).
¶ 22 Section 503(j) of the Act addresses contribution from an opposing party toward attorney
 fees and costs before a final dissolution-of-marriage judgment is entered. 750 ILCS 5/503(j)
 (West 2014). Ordinarily, the primary obligation for the payment of attorney fees rests on the
 party on whose behalf the services were rendered. In re Marriage of Hassiepen, 269 Ill. App.
 3d 559, 569 (1995); In re Marriage of Mantei, 222 Ill. App. 3d 933, 941 (1991). However,
 section 503(j) allows the trial court to order one party to contribute to the other party's attorney
 fees. 750 ILCS 5/503(j) (West 2014). Unlike section 508(c) of the Act, section 503(j) does not
 expressly require that the amount awarded be "reasonable." Nevertheless, the statute has been
 interpreted to incorporate a reasonability requirement. In re Marriage of Hasabnis, 322 Ill.
 App. 3d 582, 596 (2001).
¶ 23 It is worth noting that, pursuant to section 503(j), Canulli's request for contribution should
 have been heard and decided prior to entry of the judgment for dissolution of marriage.
 Nevertheless, it appears that no party raised the issue in the trial court, and any objection is thus
 forfeited. The timing provisions of section 503(j), although mandatory, are not jurisdictional
 prerequisites, and they therefore may be forfeited. In re Marriage of Cozzi-DiGiovanni, 2014
 IL App (1st) 130109, ¶ 40; In re Marriage of Lindsey-Robinson, 331 Ill. App. 3d 261, 269
 (2002).
¶ 24 In his brief, Canulli argues various theories as to which standard of review we should apply
 to this case, and he seemingly advocates for a number of standards that span the spectrum from
 de novo to abuse of discretion. However, when an appeal concerns an award of attorney fees,
 we review it for an abuse of discretion. In re Marriage of Harrison, 388 Ill. App. 3d 115, 120
 (2009); Wildman, Harrold, Allen & Dixon v. Gaylord, 317 Ill. App. 3d 590, 595 (2000). All
 reasonable presumptions are in favor of the action of the trial court, and, absent an affirmative

 -6-
 showing to the contrary, the reviewing court will assume that the trial court understood and
 applied the law correctly. In re Marriage of Walters, 238 Ill. App. 3d 1086, 1102-03 (1992).
¶ 25 It is well established that the burden of proof is on the attorney to establish the value of his
 services, and that appropriate fees consist of reasonable charges for reasonable services. In re
 Marriage of Shinn, 313 Ill. App. 3d 317, 323 (2000). In order to justify the fees sought, the
 attorney must present more than a mere compilation of hours multiplied by a fixed hourly rate.
 In re Marriage of Angiuli, 134 Ill. App. 3d 417, 423 (1985). Rather, the attorney must provide
 sufficiently detailed time records that were maintained throughout the proceeding, and those
 records must specify the services performed, by whom they were performed, the time
 expended thereon, and the hourly rate charged. Shinn, 313 Ill. App. 3d at 323. The trial court
 should consider a variety of additional factors when assessing the reasonableness of fees, such
 as the skill and standing of the attorney, the nature of the case, the novelty and/or difficulty of
 the issues involved, the importance of the matter, the degree of responsibility required, the
 usual and customary charges for similar work, the benefit to the client, and whether there is a
 reasonable connection between the fees requested and the amount involved in the litigation.
 Kaiser v. MEPC American Properties, Inc., 164 Ill. App. 3d 978, 984 (1987). The trial court
 should scrutinize the records for their reasonableness in the context of the case. McHugh v.
 Olsen, 189 Ill. App. 3d 508, 514 (1989). In ruling on the reasonableness of fees, the trial judge
 may also rely on his or her own experience. Richardson v. Haddon, 375 Ill. App. 3d 312, 315
 (2007); Heller Financial, Inc. v. Johns-Byrne Co., 264 Ill. App. 3d 681, 691 (1994). When a
 trial court awards less than the amount requested in a fee petition, the court's ruling should
 include the reasons justifying a particular reduction. Richardson, 375 Ill. App. 3d at 315.
¶ 26 Canulli asserts that the trial court's award of attorney fees was erroneous for a number of
 reasons. Though they appear in multiple sections of his brief, many of his arguments are but
 one argument phrased in varying ways. We also observe that a number of paragraphs are
 repeated verbatim in two sections of his brief. Canulli's main contention on appeal is that,
 when the trial court ruled on his fee petitions, it was required to (1) review each billing entry
 line-by-line; (2) state with specificity which line items it found unreasonable; and (3) provide a
 specific explanation to support each individual reduction. For these propositions, he relies
 heavily on Fitzgerald v. Lake Shore Animal Hospital, Inc., 183 Ill. App. 3d 655 (1989).
¶ 27 Fitzgerald involved an action to recover possession of commercial property that was
 leased to the defendant, and the sole dispute concerned when the defendant would vacate the
 premises. The trial court granted summary judgment in favor of the plaintiff, who then sought
 attorney fees pursuant to a fee-shifting provision contained in the lease. Id. at 658-59. The
 plaintiff sought fees of approximately $50,000, but the trial judge awarded $25,000, and the
 judge commented that the amount was "as probably a wild a guess [as he could] take." Id. at
 661. On review, the appellate court found that the award was unreasonably high and remanded
 the matter for a hearing on the fees. Id. at 662. In so holding, the court commented that the trial
 judge "did not make clear what billings he was striking as duplicitous or unnecessary," but
 rather took a "Solomonic" approach when he "clove the baby in two." Id. The court stated that
 "[w]ithout a full, complete and detailed hearing on this matter, and without a ruling on each
 billing entry, *** there can be no way of determining what a reasonable fee might be in this
 case." Id. The court indicated that the case was not complicated, and it stated that "the usual
 and customary charge for a simple eviction case surely must be far less than the fee that was
 awarded here, to say nothing of the one demanded." Id.

 -7-
 ¶ 28 We find Fitzgerald distinguishable. In Fitzgerald, when the trial court simply halved the
 fees requested in the fee petition, it did so without the benefit of a full evidentiary hearing and
 it candidly characterized the award as a "wild guess." Id. at 661; see also Heller Financial, Inc.
 v. Johns-Byrne Co., 264 Ill. App. 3d 681, 693 (1994). In the instant matter, the report of
 proceedings makes clear that the parties engaged in an exhaustive hearing wherein Canulli's
 itemized billing statements were scrutinized by Gregory and Heather, as well as the trial court.
 The sole subject of the hearing was Canulli's request for fees, and indeed the trial court
 devoted an entire day to the consideration thereof. Here, nothing suggests that the trial court
 took a "wild guess" or acted arbitrarily when it awarded Canulli an additional $12,500 in fees
 from Gregory. Further, the court did not take a "Solomonic" approach and simply halve the
 requested fees. The report of proceedings demonstrates that the court was engaged, asked
 numerous pointed questions, and gave due consideration to the fee petitions, as well as the
 billing statements attached thereto.
¶ 29 It should also be noted that, despite Canulli's assertion, Fitzgerald does not require the trial
 court to review the attorney's billing entries line-by-line and affirmatively strike those
 individual entries that it deems unreasonable, nor does Fitzgerald require the court to provide a
 "specific explanation supporting each reduction." No court has cited Fitzgerald for such
 propositions, and we decline to do so now. Though the Fitzgerald court remanded the matter
 for a "ruling on each billing entry," it is clear that the court directed the trial court to make such
 evaluations and rulings in light of the particular facts of that case.
¶ 30 In addition to Fitzgerald, Canulli cites a number of cases to support his "itemization"
 argument. He prefaces this list of cases with the introductory signal "see," which should be
 used only when an authority clearly and directly supports the proposition for which it is cited.
 People v. Gonzalez, 292 Ill. App. 3d 280, 287 (1997). Simply put, none of the additional cases
 requires the trial court to review each individual billing entry line-by-line before striking any
 as unreasonable. Patton v. Lee, 406 Ill. App. 3d 195 (2010), concerned a request for sanctions
 under section 226 of the Illinois Domestic Violence Act of 1986 (750 ILCS 60/226 (West
 2008)), based on allegedly false statements made in an emergency petition for an order of
 protection. There, we affirmed the trial court's denial of sanctions, because, among several
 other reasons, the party seeking the sanctions did not itemize the costs that he believed were
 caused by the false statements. Id. at 201. In re Marriage of Heindl, 2014 IL App (2d) 130198,
 concerned the trial court's denial of interim attorney fees. We held that the trial court did not
 abuse its discretion in denying interim fees where the petitions were not verified and did not
 include any affidavits or other support for the request. Id. ¶¶ 32-33. Canulli also cites Cholipski
 v. Bovis Lend Lease, Inc., 2014 IL App (1st) 132842, but notably absent from that case is any
 discussion of attorney fees. Finally, he cites McHenry Savings Bank v. Autoworks of
 Wauconda, 399 Ill. App. 3d 104 (2010), which involved the amount of fees a bank was entitled
 to collect from a guarantor of a promissory note that was in default. At the conclusion of the
 trial, the bank filed a verified petition for attorney fees, detailing the services performed and
 the time spent by each of the seven attorneys who represented the bank. Id. at 108. We held that
 the trial court did not abuse its discretion in reducing from 58 to 30 the compensable hours the
 bank spent preparing and trying the case. Though the bank offered an argument similar to that
 now advanced by Canulli regarding itemization, we did not reach the issue because the trial
 court offered a reasonable explanation for reducing the fees. Id. at 119. Thus, these cases do
 not support Canulli's itemization argument.

 -8-
 ¶ 31 Canulli insists that, because attorneys must provide sufficiently detailed time records when
 seeking fees, "in fairness" the trial court should have a corresponding duty to detail the specific
 entries that it finds unreasonable. Although it is well established that the absence of specificity
 with regard to task and time precludes a finding of reasonableness by the trial court (In re
 Marriage of Broday, 256 Ill. App. 3d 699, 707 (1993)), we reject Canulli's implicit assertion
 that the presence of specificity in an attorney's billing records therefore mandates a
 line-by-line finding of reasonableness (or unreasonableness) by the trial court. The purpose of
 requiring such specificity by the attorney is to aid the trial court in its efforts to determine a
 reasonable fee award (In re Estate of Bitoy, 395 Ill. App. 3d 262, 275 (2009)), and those efforts
 would not be aided by requiring of the trial court the same degree of specificity, Canulli's
 fairness argument aside. While reviewing courts have commented favorably where trial courts
 did undertake a line-by-line review (see Kaiser, 164 Ill. App. 3d at 988), there is simply no
 requirement for trial courts to do so. Further, reviewing courts have upheld trial courts'
 valuations of work performed by attorneys in terms of rounded numbers. See, e.g., In re
 Marriage of Auriemma, 271 Ill. App. 3d 68 (1994) (finding that law firm was entitled to
 receive a total of $90,000 in fees, rather than the $155,987.76 it sought, due to the firm's failure
 in its obligation to control the litigiousness of its client); 400 Condominium Ass'n v. Wright,
 240 Ill. App. 3d 546 (1992) (upholding award of $8000 in fees when petition sought
 $24,164.21); Angiuli, 134 Ill. App. 3d 417 (upholding trial court's decision to reduce fees
 sought by attorney against former client from $62,202.25 to $36,000).
¶ 32 Canulli next asserts that Gregory waived his right to object to the fees because he did not
 object to any bill within seven days of receiving it, as required by the engagement agreement.
 Based on this provision, and prior to the hearing on his fee petitions, Canulli filed a motion
 in limine to bar Gregory from opposing his fee petitions. The trial court denied the motion and
 proceeded to a full hearing on the petitions. Canulli cites no authority in support of his waiver
 argument, and so the argument is forfeited. "The appellate court is not a depository into which
 a party may dump the burden of research." (Internal quotation marks omitted.) Hall v. Naper
 Gold Hospitality, LLC, 2012 IL App (2d) 111151, ¶ 13.
¶ 33 Next, Canulli contends that the court abused its discretion by not applying the "required
 criteria and factors" when it reduced his fees. This argument consists almost entirely of
 material quoted from Goesel v. Boley International (H.K.) Ltd., 806 F.3d 414 (7th Cir. 2015).
 In Goesel, a law firm represented a minor and his parents in a personal-injury suit. Id. at 417.
 The parties entered into a retainer agreement whereby the firm would receive one-third of any
 gross amount recovered and the Goesels would be responsible for any litigation expenses. If
 there was no recovery, they would owe no attorney fees. Id. The case settled prior to trial, and,
 after paying the litigation expenses, the Goesels would be left with 42% of the total recovery.
 Because the injured party was a minor, the trial court was required to approve the settlement
 before it could be finalized. The court, sua sponte, objected to the contingent fee agreement,
 invoked " ‘fairness and right reason,' " and "modified the fee structure so that the litigation
 expenses were deducted off the top, prior to the one-third allocation to the law firm." Id. at 418.
¶ 34 On appeal, the Seventh Circuit undertook a review of the objective reasonableness of the
 retainer agreement's provision for attorney fees. Looking to the factors that courts use to
 determine the reasonableness of fees (see supra ¶ 25), the court found that the firm's fees
 "easily passe[d] muster" and were not excessive. Goesel, 806 F.3d at 421. In so holding, the
 court stated that the trial court impermissibly relied on " ‘fairness and right reason,' " which

 -9-
 the reviewing court described both as a "rhetorical flourish" and a factor outside the
 appropriate scope of its inquiry. Id. at 422-23. The court stated that, of the criteria that govern
 attorney fees in settlements involving minors, none supported rewriting the terms of the
 agreement. Id. at 422.
¶ 35 At the outset, we note that federal appellate decisions are not binding on this court. See
 People v. Kidd, 129 Ill. 2d 432, 457 (1989). While such decisions may be considered
 persuasive authority (People ex rel. Ryan v. World Church of the Creator, 198 Ill. 2d 115, 127
 (2001)), we agree with Gregory and Heather that Goesel has little relevance to this matter.
 Indeed, much of the Goesel court's discussion concerns the "vital role" that contingent-fee
 contracts play in our legal system. Goesel, 806 F.3d at 423. Also, while the Goesel court took
 issue with the trial court's reliance on "additional factors outside the appropriate scope of its
 inquiry" (id.), Canulli does not indicate what factor or factors he believes the trial court here
 improperly relied on in reducing the fees. Moreover, Goesel does not state that a court should
 review "line item" billing statements when reducing fees, nor does it require a court to
 articulate with particularity how it evaluated each of the factors when assessing the
 reasonableness of the fees. Thus, Goesel does not bolster Canulli's arguments.
¶ 36 Our review of the record, as well as the report of proceedings concerning the hearing on
 Canulli's fee petitions, shows that the trial court provided numerous reasons for reducing the
 fees, and we believe that the trial court's award of fees was not an abuse of discretion. The
 court commented on the absence of progress in the case, despite the more than $85,000 in fees
 that Canulli billed to Gregory. The court stressed that only two hearings were held, that no
 depositions were taken, and that there were "no substantive things being done" in the case.
 Indeed, these statements were supported by Canulli's own acknowledgment that he did not
 prepare for trial, that no experts were consulted or retained, and that he did not prepare a joint
 parenting agreement or a marital settlement agreement. The record confirms that Canulli
 participated in only two contested hearings: the hearing on Heather's motion to vacate
 Gregory's pro se order of protection (which was granted) and the hearing on Heather's petition
 for exclusive possession of the marital residence (which also was granted). These observations
 were clearly within the court's province, as a judge is permitted to rely on his or her own
 knowledge and experience when determining the reasonableness of fees. Richardson v.
 Haddon, 375 Ill. App. 3d 312, 315 (2007); In re Marriage of McHenry, 292 Ill. App. 3d 634,
 642 (1997); In re Marriage of Sanda, 245 Ill. App. 3d 314, 319 (1993).
¶ 37 Further, Heather correctly points out that Canulli billed for drafting documents that were
 either not presented or not filed with the court, including a motion to dismiss her petition for
 exclusive possession of the marital residence and a notice of dissipation. Canulli's billing
 statements also contain several entries that indicate that he charged for reviewing an
 emergency petition for an order of protection filed by Heather, though no such petition was
 ever filed. Canulli's statements also indicate that he billed Gregory for more than two hours
 after he was granted leave to withdraw.
¶ 38 It is well established that unnecessarily increasing the cost of litigation is a relevant factor
 for a trial court to consider when allocating attorney fees. In re Marriage of Patel, 2013 IL App
 (1st) 112571, ¶ 117. Moreover, an attorney's fees may be reduced if the attorney fails to
 control the litigiousness of his or her client. Auriemma, 271 Ill. App. 3d at 74. In her findings,
 the trial judge here clearly found these factors important, as she spoke directly to Canulli:
 "Yes, your client was difficult. I understand that. But you fostered, you tolerated, and you

 - 10 -
 actually aided him in filing pro se petitions, by your own testimony which, in fact, encouraged
 rogue behavior and did nothing to control the litigation, which, I believe, is also part of an
 attorney's obligation when your client is taking unreasonable positions."
¶ 39 The record indicates that Gregory filed four separate pro se submissions with the court
 while represented by Canulli, including two emergency petitions for orders of protection, a
 petition for temporary support, and a filing consisting of 40 pages of exhibits regarding
 Heather's private matters.
¶ 40 Gregory filed his first pro se emergency petition for an order of protection on September
 15, 2014. Canulli's billing statements indicate that, the day prior, he billed Gregory for
 discussing "9/11 incident and Order of Protection and going forward on the same." He also
 emailed Gregory regarding the possibility of seeking an order of protection, stating: "FYI—I
 received this from opposing counsel and it does not appear from this e-mail that they intend to
 file a Petition for Order of Protection. *** If they do not file anything, don't you think it is
 necessary or in your best interests to do so? Possibly better to let things calm down and also
 lessen the legal fees." The trial court granted the emergency petition. Heather thereafter filed
 an emergency motion to rehear the petition, and a hearing was held on September 23, 2014,
 wherein Canulli represented Gregory. At the conclusion of the hearing, the court vacated the
 order of protection. Canulli's billing statements show that he charged Gregory for more than
 16 hours of work related to this petition, including time spent representing Gregory at the
 hearing, preparing for the hearing, and exchanging phone calls and emails with Gregory and
 with opposing counsel. Some two weeks after the hearing, Canulli sent Gregory an email,
 stating "[t]ruth be told, there wasn't enough for an order of protection and I wouldn't have filed
 a petition based on what happened."
¶ 41 Gregory filed a second pro se emergency petition for an order of protection approximately
 three months later, and the court denied it after chastising Gregory for filing it. Though Canulli
 testified that he did not help Gregory prepare the petition, he acknowledged that he billed
 Gregory for reviewing the petition before Gregory filed it. In sum, Canulli billed for nearly
 four hours related to this petition.
¶ 42 Gregory also filed pro se approximately 40 pages of exhibits that contained personal
 information regarding Heather. Heather thereafter filed an emergency motion to impound the
 exhibits, and Canulli billed Gregory for assisting him in preparing to appear pro se at the
 hearing. Canulli testified at the hearing on his fee petitions that the emergency motion to
 impound was noticed for a date on which he was not available. Canulli's billing statements
 show that he billed Gregory for nearly six hours for addressing the matter with opposing
 counsel, conducting legal research, and preparing Gregory for his pro se court appearance.
 One billing entry states, "review, select, copy and highlight cases to oppose Wife's request to
 impound file *** and very detailed email to client about what to do and say to Judge tomorrow
 w/multiple attachments of highlighted cases."
¶ 43 Gregory's final pro se filing while Canulli represented him was a petition for temporary
 maintenance. The court struck the petition on January 12, 2015, ordered Gregory not to file
 pleadings in any other courtrooms, and granted Heather's counsel leave to file a petition for
 attorney fees for her time spent that day appearing in court. Canulli testified that he assisted
 Gregory in preparing the pro se petition and the notice of it.
¶ 44 "The question for the reviewing court is not whether it agrees with the trial court's
 decision; rather, the reviewing court must analyze whether the trial court, in the exercise of its

 - 11 -
 discretion, acted arbitrarily without conscientious judgment or, in view of all the
 circumstances, exceeded the bounds of reason and ignored recognized principles of law so that
 substantial injustice resulted." In re Marriage of Baniak, 2011 IL App (1st) 092017, ¶ 9. Based
 on all of the foregoing, we cannot conclude that the trial court's decision to deny contribution
 from Heather and award Canulli a total of $50,000 from Gregory was an abuse of discretion.
¶ 45 Finally, we consider the issue of sanctions. Canulli filed a motion for sanctions under
 Illinois Supreme Court Rule 375(b) (eff. Feb. 1, 1994) against Gregory, wherein he asserts that
 Gregory's reply brief quotes portions of Canulli's emails out of context, thereby placing
 Canulli "in a bad light." Similarly, Heather has filed a motion for Rule 375(b) sanctions against
 Canulli, asserting that Canulli's briefs falsely state that she filed pro se pleadings in the trial
 court. We ordered both of these motions taken with the case.
¶ 46 Rule 375 permits us to impose appropriate sanctions on a party if we determine that the
 appeal or other action itself is frivolous or that the appeal or other action was not taken in good
 faith or was taken for an improper purpose, such as to harass or cause unnecessary delay. The
 purpose of Rule 375 is to condemn and punish the abusive conduct of litigants and their
 attorneys who appear before us. Sterling Homes, Ltd. v. Rasberry, 325 Ill. App. 3d 703, 709
 (2001).
¶ 47 We conclude that sanctions would not be appropriate in this case. Gregory's
 mischaracterization of Canulli's emails by not quoting them in their entirety was de minimis, at
 most. As for Heather's motion, she is correct that Canulli's briefs state that both parties filed
 pro se pleadings, where the record is clear that she did not act pro se. Specifically, Canulli
 refers to Heather's emergency motion to impound as having been filed pro se, and he states
 that "the record is replete with instances where Mrs. Kane filed pro se motions [and] sought
 pro se relief." We decline to impose sanctions here, as Canulli's misstatements likely reflect
 carelessness in drafting his briefs, rather than a deliberate effort to mislead this court.

¶ 48 III. CONCLUSION
¶ 49 For the reasons stated, we affirm the judgment of the circuit court of Du Page County.

¶ 50 Affirmed.

 - 12 -