In Ziegler v. Nickel (1998) 64 Cal.App.4th 545, the court concluded that a trustee who is not an attorney could not act in propria persona to represent the trust's interests in litigation. The court reasoned that it would be inappropriate for the trustee to do so, because " 'in this capacity such trustee would be representing interests of others and would therefore be engaged in the unauthorized practice of law.' " (Id. at p. 548.) As the Ziegler court explicitly stated, the "others" whose interests the trustee would be representing in the litigation are the trust beneficiaries: "a nonattorney trustee who represents the trust in court is representing and affecting the interests of the beneficiary and is thus engaged in the unauthorized practice of law." (Id. at p. 549.) In sum, the Court of Appeal held that "a nonattorney trustee who represents a trust in court is representing and affecting the interests of the beneficiary and is thus engaged in the unauthorized practice of law." Observing that the statutory prohibition on the unlicensed practice of law (Bus. & Prof. Code, 6125) has been construed to forbid one who is not a licensed attorney from appearing in court for another person, the court in Ziegler reasoned: "'It is true that, as a general rule, a trust is not a legal personality, and the trustee is the proper person to sue or be sued on behalf of such trust. However, . . . a trustee's duties in connection with his or her office do not include the right to present argument in propria persona in courts of the state, because in this capacity such trustee would be representing interests of others and would therefore be engaged in the unauthorized practice of law.' " (64 Cal.App.4th at p. 548.)