Trustees who successfully defend themselves against a surcharge action are entitled to recover the legal fees and costs from the trust, and the litigation costs relating to three trusts should be born proportionately by all three trusts because the surcharge related to actions that occurred before the division of the one trust into three trusts, because the non-surcharge actions were intended to divide the trusts in a way that benefited all of the beneficiaries, and because all three beneficiaries participated in the litigation.  McFadden Trusts, 3 Fid. Rep. 3d 209 (O.C. Phila. 2013):