908 P.2d 705, 706 (1995). Thus, Bingham & Snow properly brings a writ 

petition to challenge the district court's denial of its motion to adjudicate. 

We consider two issues raised in the writ petition and answer: 

(1) whether the district court had jurisdiction to consider Bingham & 

Snow's motion to adjudicate and (2) whether Bingham & Snow's attorney's 

lien was enforceable. We review these issues de novo. Leventhal v. Black 

& LoBello, 129 Nev., Adv. Op. 50, 305 P.3d 907, 910 (2013) (stating that 

we review de novo the construction of the statute authorizing an attorney's 

charging lien); Argentena Consol. Mining Co. v. Jolley Urga Wirth 

Woodbury & Standish, 125 Nev. 527, 531, 216 P.3d 779, 782 (2009) 

(stating that we review de novo the district court's jurisdiction to resolve 

an attorney's lien dispute). 

The district court had jurisdiction to consider Bingham & Snow's motion 

Premier argues that the district court lacked jurisdiction to 

consider Bingham & Snow's motion to adjudicate the attorney's lien. 

After a final judgment is entered, "the district court retains 

jurisdiction to consider collateral matters." Emerson v. Eighth Judicial 

Dist. Court, 127 Nev., Adv. Op. 61, 263 P.3d 224, 229 (2011). The 

adjudication of an attorney's lien is a collateral matter over which the 

district court has incidental jurisdiction because its enforceability arises 

from the underlying litigation but does not directly concern the merits of 

the case. See Argentena, 125 Nev. at 532-33, 216 P.3d at 783. Therefore, 

the district court had jurisdiction to consider Bingham & Snow's motion to 

adjudicate the attorney's lien. 

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The attorney's lien was unenforceable because it was not perfected 

Bingham & Snow argues that it perfected its attorney's lien by 

serving a notice of the lien on an attorney who represented Premier and 

another party in the underlying litigation. 

NRS 18.015 establishes the requirements for an attorney's 

charging lien. In relevant part, this statute provides that lain attorney 

perfects a lien. . . by serving notice in writing. . . upon the party against 

whom the client has a cause of action." NRS 18.015(3). 

Notice provided to an attorney with regard to one client cannot 

be imputed to a different client and does not create a duty for the attorney 

to determine whether the notice is relevant to another client's interests. 

See In re Perle, 725 F.3d 1023, 1028 (9th Cir. 2013); Maldonado v. 

Ramirez, 757 F.2d 48, 51 (3d Cir. 1985); Bayne v. Jenkins, 593 S.W.2d 519, 

533 (Mo. 1980); Ross v. Mayflower Drug Stores, 12 A.2d 569, 571 (Pa. 

1940); Secord v. Chrysler Corp., 292 N.W.2d 365, 368 (Wis. Ct. App. 1980). 

Premier was a party against whom Bingham & Snow's client 

had a cause of action in the underlying litigation. Therefore, Bingham & 

Snow had a duty to serve Premier with notice of the attorney's lien. 

When serving the notice of its attorney's lien on the attorney 

who represented Premier and the other party, Bingham & Snow produced 

a certificate of service that identified that the notice was for the other 

party and did not indicate that it was for Premier. The record does not 

suggest that Bingham & Snow otherwise attempted to serve notice of the 

attorney's lien on Premier. Thus, by not serving Premier, Bingham & 

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Snow failed to perfect the attorney's lien. As a result, the district court 

properly denied Bingham & Snow's motion to adjudicate.' Therefore, we 

ORDER the petition DENIED. 

,44.A , C.J. 

Hardesty 

Parraguirre 

Douglas 

Saitta 

J. 

'In light of Bingham & Snow's failure to perfect the attorney's lien, 

we decline to address the remaining issues raised by the petition and 

answer, including whether service of a party's attorney would fulfill NRS 

18.015(3)'s notice requirement and whether various parties in the 

underlying litigation had standing to contest the attorney's lien. 

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cc: Hon. Rob Bare, District Judge 

Bingham Snow & Caldwell 

Lewis Roca Rothgerber LLP/Las Vegas 

Eighth District Court Clerk 

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