Audrey Tolson and the Tolson Firm disputed a fee award to the Cochran Firm after both firms had worked on a medical-malpractice case arising from the death of Quincy Bryant’s wife after gastric-bypass surgery. The Cochran Firm investigated the claim, obtained records, consulted experts, developed a theory, and drafted a complaint before Tolson left and Bryant retained Tolson and successor counsel. After the case settled for $2 million and produced $800,000 in attorney fees, the trial court enforced the Cochran Firm’s lien and awarded it 30 percent of the fees: 25 percent for originating the case and 5 percent for pre-suit legal work. The Court of Appeals of Georgia affirmed in part, reversed in part, and remanded with direction. The court held that OCGA § 15-19-14 (b) permits former counsel who performed legal work in anticipation of a lawsuit to assert a charging lien on the later-filed action for money, even when successor counsel filed the suit. The court rejected reliance on subsection (d), explaining that its reference to “property recovered” concerns liens on real or personal property under subsection (c), not monetary liens under subsection (b). But the trial court could not award quantum meruit for originating or procuring the case because rainmaking is not a service rendered to or for the client and confers no client benefit. The court affirmed the 5-percent award for pre-suit legal work because the record showed concrete investigative and litigation value that contributed to the successful result. The 25-percent origination award was reversed and those fees were directed to be distributed to Tolson; the 5-percent pre-suit-work award and the lien’s validity were affirmed.