E.g., Millennium Square Residential Ass'n v. 2200 M St. LLC, 952 F. Supp. 2d 234, 243 (D.C. Cir. 2013) (trust is not an entity distinct from its trustee and is not capable of legal action on its own behalf); Presta v. Tepper, 102 Cal. Rptr. 3d 12, 16 (App. 2009) (“[A] trust itself can neither sue nor be sued in its own name .... [T]he real party in interest in litigation involving a trust is always the trustee.”); Ray Malooly Trust v. Juhl, 186 S.W.3d 568, 570 (Tex. 2006) (“The general rule in Texas (and elsewhere) has long been that suits against a trust must be brought against its legal representative, the trustee.”); see also 76 Am. Jur. 2d Trusts § 601 (2017) (“In most jurisdictions, a trust is not an entity separate from its trustees, and cannot sue or be sued in its own name, and therefore, the trustee, rather than the trust, is the real party in interest in litigation involving trust property.”).