In Cooke v. Gove , the Nevada Supreme Court upheld an attorney fees award based on "the reasonable value" of the attorney’s services, even though the case was taken on a contingency fee basis with no formal agreement. 61 Nev. 55, 61, 114 P.2d 87, 89 (1941). The "evidence" to support the fee was the case file from the successful matter, some of the letters between the client and attorney, and two depositions from other attorneys about the value of the appellant’s services.

"In making its determination, the trial court should assess all of the relevant factors, including the time and labor required, the attorney's skill and standing, the nature of the cause, the novelty and difficulty of the subject matter, the attorney's degree of responsibility in managing the case, the usual and customary charge for that type of work in the community, and the benefits resulting to the client." Id.; see alsoCooke v. Gove, 61 Nev. 55, 114 P.2d 87, 89 (1941) (listing similar factors). These are precisely the factors identified and considered by the district court.

When the attorney is discharged and the contract is terminated, "the attorney may be compensated for the reasonable value of his services under quantum meruit principles." Golightly, 2009 WL 1470342 at *2; see also Gordon, 324 P.2d 234; Cooke, 114 P.2d 87; Nevada Rule of Professional Conduct 1.5(a) (imposing upon attorneys an ethical obligation to "not make an agreement for, charge, or collect an unreasonable fee or an unreasonable amount for expenses"). In determining the reasonable value for legal services rendered, the Court may consider either the "applicability of established customs" or the amount the parties orally agreed upon.

Although not directly addressing the issues in this case, the Nevada Supreme Court has indicated that where there is no agreement regarding attorneys' fees, the attorney is entitled to the reasonable value of services performed in quantum meruit, rather than a contingency fee. See Cooke v. Gove, 114 P.2d 87, 88 (Nev. 1941). Additionally, the Nevada State Bar has issued a non-binding advisory opinion stating that a discharged attorney hired on contingency is entitled to recover in quantum meruit when the discharge occurs after an initial offer of settlement has been made.

We have previously upheld awards of attorney fees based on similar evidence. See, e.g., Herbst v. Humana Health Ins. of Nev., Inc., 105 Nev. 586, 591, 781 P.2d 762, 765 (1989) (holding that an affidavit documenting the hours of work performed, the length of litigation, and the number of volumes of appendices on appeal was sufficient evidence to enable the court to make a reasonable determination of attorney fees, even in the absence of a detailed billing statement); Cooke v. Gove, 61 Nev. 55, 57, 114 P.2d 87, 88 (1941) (upholding an award of attorney fees based on, among other evidence, two depositions from attorneys testifying about the value of the services rendered). We therefore conclude that the district court did not abuse its discretion when it awarded IVGID attorney fees for Brooke’s services, even though IVGID did not provide a detailed breakdown of Brooke’s fees.

Furthermore, in the matter of determining a reasonable fee there is a distinction between, as here, defending a client's property and enriching one client under the "salvage" theory. See, Cooke v. Gove, 61 Nev. 55, 114 P.2d 87, 135 A.L.R. 855. Two attorneys, called by defendants, who had heard plaintiff's testimony and carefully examined the complete file, testified that in their opinion a reasonable fee on this count would be $6,000.

Therefore, a quantum meruit analysis is appropriate in conjunction with the application of the Brunzell factors. See, e.g., Cooke v. Gove, 61 Nev. 55, 61, 114 P.2d 87, 89 (1941) (awarding compensation for legal services based on quantum meruit principles). Finally, we consider whether the district court abused its discretion when it deducted $23,593.15 in costs from the $66,000 in attorney fees to be awarded, resulting in a reduced fee amount of $42,406.85 to be divided among Blank, G&H, and Huggins.

7 Am.Jur.2d, Attorney at Law, Sec. 254. Fleming v. Phinizy, (1926) 35 Ga. App. 792, 134 S.E. 814; Citizens and Southern National Bank v. Hodnett, (1976) 139 Ga. App. 839, 229 S.E.2d 792; Sullivan v. Fawver, (1965) 58 Ill. App.2d 37, 206 N.E.2d 492; Thurston v. Travelers' Insurance Company, (1934) 128 Neb. 141, 258 N.W. 66; Cooke v. Gove, (1941) 61 Nev. 55, 114 P.2d 87; Crumlish's Administrator v. Shenandoah Valley R. Co., (1985) 40 W. Va. 627, 22 S.E. 90; Podell v. Gronik, (1938) 229 Wis. 238, 282 N.W. 53. Podell held that such agreement must be entered prior to the service performed.