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It appears that, after the Trustee’s first account,
petitioner filed objections to that account, and those objections
resulted in substantial reductions in the Trustee’s fees. At
that time, the Trustee tried to have sanctions imposed on
petitioner but was unsuccessful in that attempt. With this
experience in mind, DiLeonardo, Burroughs, Field, and petitioner
discussed whether the Trustee would move for sanctions or an
award of litigation costs against petitioner if she filed the
Objections. DiLeonardo, Field, and Burroughs represented to
petitioner that this would not happen because the Objections were
good on their face and would not subject petitioner to any kind
of sanction, penalty, or litigation costs award. After
consultation with DiLeonardo, Field, and Burroughs, and after
assurances that the Objections were reviewed by Professor Halbach
and investigated by another law firm, petitioner signed the
Objections.
On August 7, 1991, petitioner filed the Objections with the
California Court. Petitioner made several Objections to the
Third Account, including the following:
Guardian ad litem. Petitioner agreed that a guardian ad
litem should be appointed, but objected to the Third Account by
asking the California Court to delay authorizing the distribution
until the guardian was appointed and had sufficient time to
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