Nothing In General Costs Statutes Or Probate Code Section 17211 So Allows.
In Ramirez v. Rue, Case Nos. B283677/B286574 (2d Dist., Div. 4 April 18, 2019) (unpublished), a trustee prevailed in a battle by co-beneficiaries challenging certain accountings. Trustee won because the probate court determined the contested accounting dispute was brought/prosecuted in bad faith and without reasonable cause under Probate Code section 17211. The lower court awarded the expenses of a privately-retained expert to the trustee. That order was reversed on appeal, given that nothing in the general costs statute or section 17211 allows for recovery of such expenses.