Riggs National Bank of Wash., D.C. v. Zimmer
In Riggs National Bank of Wash., D.C. v. Zimmer, 355 A.2d 709, 713-14 (Del. Ch. 1976), the court focused on three factors to identify the beneficiaries as the "real" clients:
(1) the trustees had sought legal advice that would only benefit the trust, not the trustees personally;
(2) the trustees had paid for that advice with trust funds, not the trustees' personal funds;
(3) there was no adversarial proceeding pending against the trustees, which presumably meant that there was no need for the trustees to seek advice in a personal capacity. 355 A.2d at 711-12.