A husband who eventually mostly prevailed, after appeal and remand, in litigation over the wording of an order dividing his military retired pay, did not qualify for a fee award under a PSA provision awarding fees for successful enforcement of the PSA, or successful defense against enforcement. Jones v. Gates, Va. Ct. App. unpublished 2017. The PSA required the wife to have an order drafted, dividing his retired pay. Presenting such an order to a court is not an enforcement action, the court ruled, even if it involves disputed language that was found inconsistent with the Agreement.