In Conservatorship of Lefkowitz (1996) 50 Cal.App.4th 1310, the Court of Appeal reversed an award of attorney fees to attorneys representing a conservator. They noted that the moving party for an award of fees has the initial burden of establishing the propriety of the fees requested. ( Id. at p. 1316, fn. 4.) Analogizing the fiduciary relationship between a conservator and a conservatee to that of a trustee and a beneficiary (Prob. Code, 2101), the court discussed some of the issues to be addressed in determining the propriety of the requested fees: "Just as a trustee must 'administer the trust solely in the interest of the beneficiaries' , a conservator must exercise his or her powers solely in the interest of the conservatee. . . . In short, as a fiduciary, a conservator is bound to act with reasonable prudence and pursuant to a good-faith belief that its actions will tend to accomplish the purpose of its trust by benefiting the conservatee. "The right of a fiduciary to be reimbursed for his or her expenses is governed by the same considerations. A trustee's power to incur expenses is limited to those expenses which are reasonably necessary or appropriate to carry out the purposes of the trust. 'If the trustee exceeds his or her powers in incurring an expense and no benefit is conferred thereby upon the trust estate, the trustee is not entitled to indemnity.' Thus, 'the underlying principle which guides the court in allowing costs and attorneys' fees incidental to litigation arising out of a trust estate is that such litigation is a benefit and service to the trust.' If it was not reasonably necessary for the trustee to engage in litigation, he or she will not be reimbursed for the attorney's fees which he or she incurred. Moreover, in addition to being reasonable, the decision must be properly motivated: 'It is a general rule that trustees are entitled to reimbursement for expense incurred in good faith in the execution of the trust.' "In short, a trustee may not be indemnified for an expense unless the trustee subjectively believed that the expense was necessary or appropriate to carry out the purpose of the trust and that belief was objectively reasonable." ( Id. at pp. 1313-1314.)