Frei Ex Rel. Frei v. Goodsell, 305 P.3d 70

Goodsell prepared estate documents for Frei at Brock's instruction, transferring over $1 million to Frei's wife's trust.
Frei challenged the trust documents, seeking disqualification of Goodsell in the trust action due to a claimed attorney-client relationship.
The district court disqualified Goodsell in the trust action on conflict grounds; the trust action settled with court approval.
After settlement, Frei sued Goodsell for legal malpractice, asserting an attorney-client relationship existed and that Goodsell breached standards of care.
Frei moved in limine to preclude Goodsell from denying an attorney-client relationship; trial included parol evidence concerns regarding Frei's intent in executing the documents.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether issue preclusion applies	Frei argues the prior disqualification bound Goodsell to admit an attorney-client relationship.	Goodsell contends the prior action did not render the relationship necessarily litigated.	Issue preclusion does not apply; not necessarily litigated in the prior action.
Whether parol evidence barred Frei's intent	Frei asserts extrinsic intent evidence is admissible to show mismatch with unambiguous documents.	Goodsell argues evidence of intent is precluded by the parol evidence rule for unambiguous documents.	Parol evidence properly excludes evidence of intent for unambiguous instruments.

Five Star Capital Corp. v. Ruby, 124 Nev. 1048, 194 P.3d 709 (2008) (elements of issue preclusion)
Univ. & Cmty. Coll. Sys. v. Sutton, 120 Nev. 972, 103 P.3d 8 (2004) (conditions for claim of res judicata/issue preclusion)
Jarosz v. Palmer, 766 N.E.2d 482 (Mass. 2002) (attorney-client relationship not necessarily litigated)
Kaldi v. Farmers Ins. Exch., 117 Nev. 273, 21 P.3d 16 (2001) (parol evidence rule and extrinsic evidence limits)
Tarkanian, 110 Nev. 581, 879 P.2d 1180 (1994) (necessity of issue for prior judgment under res judicata analysis)