Cadle Co. v. Woods & Erickson, LLP
Annotate this CaseRobert Krause retained Woods & Erickson, LLP for estate planning services. Woods & Erickson created for Krause an asset protection trust, into which Krause transferred his assets. The Cadle Company, which was attempting to collect on a judgment against Krause, filed a second amended complaint against Woods & Erickson, asserting claims for conspiracy, aiding and abetting, and concert of action. Specifically, the Cadle Company alleged that that Krause had fraudulently transferred the assets and that Woods & Erickson had unlawfully facilitated the fraudulent transfers. The district court entered judgment in favor of Woods & Erickson on all claims and awarded Woods & Erickson attorney fees. The Supreme Court (1) affirmed the district court’s judgment on the merits, holding that Nevada law does not recognize accessory liability for fraudulent transfers; and (2) reversed the portion of the court’s order awarding photocopy costs, runner service costs, and certain deposition transcription costs, holding that the court erred by awarding these costs because no evidence was presented showing that those costs were reasonable, necessary, and actually incurred.
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