Bye

I. FACTS AND PROCEDURAL BACKGROUND

The Ogier Trust was established by Helene’s mother, Sarah Mula Ogier (Sarah Ogier) in 2000. The Ogier Trust expressly authorized the trustee to employ attorneys and to compensate them from the Ogier Trust’s assets. The primary beneficiaries of the Ogier Trust were Helene, Paul’s uncle, Alan Mula (Alan), and Paul’s now-deceased father, Paul Mula, Sr. (Paul Sr.). Helene was originally the trustee of the Ogier Trust. Her share of the Ogier Trust was to be put in a trust for her benefit, and Paul was the beneficiary of that trust if any property remained in it at Helene’s death. Sarah Ogier died in 2005. The Ogier Trust’s primary assets were real properties, but Sarah Ogier deeded these properties to Helene, Alan, and Paul Sr. before her death. Paul apparently questioned the validity of those deeds. In 2006, Paul accepted $100,000 from Sarah Ogier’s estate in return for a handwritten release stating: “I do hereby waive/release any future interest in any of the real property now held in the names of [Alan, Paul Sr., and Helene] and/or the estate of Sarah Mula Ogier.” The release expressly stated that this $100,000 was accepted “as final payment for…