California, United States of America
The following excerpt is from Garcia v. Kellogg, B266039 (Cal. App. 2016):
Generally, in the case of surcharge litigation, beneficiaries must "pay their own attorney fees in challenging the trustee's conduct, even when they are successful. [Citation.]" (Leader v. Cords (2010) 182 Cal.App.4th 1588, 1595 (Leader).)
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