Julie Reznick & Carol Lorenzen v. Livengood, Alskog, Pllc, 74607-3

Judd, estate planning attorney, assisted Ellen Lorenzen with a 2005 will that favored two nonfamily individuals and gave $10,000 gifts to Ellen's sisters, Carol Lorenzen and Julie Reznick.
In 2012, Ellen's condition worsened; discussions occurred about revising the will to benefit the sisters, and Ellen signaled assent by squeezing Judd's hand during a short confrontation.
Ellen died the same day without Judd destroying the 2005 will, leaving the prior will in effect.
Carol and Julie, as Ellen's sisters, sued Judd for legal malpractice, but the trial court granted summary judgment, ruling Judd owed no duty to nonclients.
The issue on appeal is whether an estate planning attorney owes a duty of care to intended beneficiaries when the attorney is not their client, and how Trask v. Butler's six-factor framework applies.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Duty to intended beneficiaries of legal services	Parks controls; nonclients may recover	No duty to nonclients under fifth/sixth Trask factors	No duty owed to sisters

Parks v. Fink, 173 Wn. App. 366 (2013) (six-factor Trask framework applied to nonclient beneficiaries)
Trask v. Butler, 123 Wn.2d 835 (1994) (establishes six-factor test for duty to nonclients; factors five and six decisive here)
Stanqland v. Brock, 109 Wn.2d 675 (1987) (nonclient beneficiaries not entitled to claim; distinguishable from Trask)