The following excerpt is from Fitzsimmons, In re, 920 F.2d 1468 (9th Cir. 1989):
We also note that as a general rule the district court must consider the relative fault of the client and the attorney. See, e.g., Greco v. Stubenberg, 859 F.2d 1401, 1404 (9th Cir.1988). 3
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