The allegations read: That the living trust, prepared by attorney on behalf of cla, was too expensive and complicated, that customer thought: i) surrender penalties were not "covered" or disclosed to customer; ii) customer trusted mr. Johnson; iii)disclosure forms were not accurate; iv) there were unanticipated expenses for customer's spouse due to her declining health that forced customer to withdraw funds; v) that forethought would not waive the surrender fee under the nursing home waiver and there were issues with medicaid, and; vi) that the customer should be reimbursed attorney fees relative to the issues with the living will, drafted by attorney on behalf of cla.