In an article in Plaintiff Magazine, Mary Katherine Bedard of Lopez, Hodes, Restaino, Milman & Skikos in San Francisco explores the issues and principles of attorney fee awards in common fund cases. Her article, "Attorney Fee Awards and the Common Fund Doctrine: Hands in the Plaintiffs' Pocket?" concludes, "With the expansion of the common fund doctrine has come the diminishment of ethical and statutory requirements governing recovery of attorney's costs and fees. While the law of restitution allows for counsel to recover the cost of securing a successful resolution, it does not permit counsel to be unjustly enriched at the expense of the client."