Divorce; Attorney fees for repeated delay in satisfying judgment terms; MCR 3.206(D); Waived reasonableness issue

Concluding that the trial court did not abuse its discretion by awarding attorney fees under the circumstances, the court affirmed the order holding defendant-ex-husband in contempt and requiring him to pay plaintiff-ex-wife “$5,000 in attorney fees for the repeated delay in satisfying the terms of the divorce judgment.” The court noted that he “was required to make three payments to [her] within a specified period in order to execute the divorce judgment terms. [He] claimed that he made the first two payments to his attorney. When the veracity of that statement was called into question, [he] failed to present documentary evidence in support. Instead, [he] claimed that plaintiff was obligated to provide a quitclaim deed. After [he] was ordered to make the payments or sell the property, he sought relief from the judgment, claiming that he was damaged by plaintiff’s dissolution of an LLC. Yet, defendant could not identify specific damages and once again failed to provide proof of his payment of his obligations under the divorce judgment. Finally, although plaintiff requested over $15,000 in attorney fees, the trial court awarded only $5,000.”