Discovery Digest
General
The Rules of the Game: Comprehensive Amendments to the Nevada Rules of Civil Procedure
The Changes Coming to the Nevada Rules of Civil Procedure: An Overview
Deadlines and Due Dates Under the 2019 Nevada Rules of Civil Procedure
What Can Nevada State Court Attorneys Learn About Proportionality From Federal Court Decisions?
NRCP 26 – GENERAL PROVISIONS GOVERNING DISCOVERY
NRCP 29 – STIPULATIONS ABOUT DISCOVERY PROCEDURE
NRCP 35 – PHYSICAL AND MENTAL EXAMINATIONS
NRCP 37 – FAILURE TO MAKE DISCLOSURE OR TO COOPERATE IN DISCOVERY; SANCTIONS
Written Discovery
Model Objections to Written Discovery (Interrogatories, Requests to Produce, and Requests for Admission
How Do I Respond to A Subpoena in Nevada?
Compelling Identification of Previously Bates Stamped Documents in Response to Discovery Requests
Rule 45 Requires That a Party Imposing an Undue Financial Burden on a Third Party Must Reimburse its Costs
Sample Objections to Written Discovery
Responding to Discovery “Subject to” Objections
Piggyback Discovery Requests: “Produce All Documents Produced in Prior Litigation”
NRCP 33 – INTERROGATORIES TO PARTIES
NRCP 34 – PRODUCING DOCUMENTS, ELECTRONICALLY STORED INFORMATION, AND TANGIBLE THINGS, OR ENTERING ONTO LAND, FOR INSPECTION AND OTHER PURPOSES
NRCP 36 – REQUESTS FOR ADMISSION
NRCP 45 – SUBPOENA
Non-Party Discovery
Rule 45 Requires that a Party Imposing an Undue Financial Burden on a Third Party Must Reimburse its Costs
Can the Confidential Documents of a Non-Party be Subpoenaed?
Can a Party to Litigation Object to a Subpoena Issued to a Non-Party Witness for Documents?
A Subpoena Seeking Documents from a Third Party That Could be Obtained from a Party is Unduly Burdensome
Depositions
The Rule 30(b)(6) Deposition in Nevada
Expert Witness Depositions, by Rebecca Sitterly
Ask for a Break in a Deposition in Nevada and You Waive the Attorney-Client Privilege
Practice Pointer: How to Conclude a Deposition While Avoiding Later Attempts to Change Testimony
Practice Pointer: How to use an Adverse Witness to Help Your Case
Impeaching a Witness With Prior Testimony: A How-To Guide
Practice Pointer: How to Conclude a Deposition While Avoiding Later Attempts to Change Testimony
NRCP 27 – DEPOSITIONS TO PERPETUATE TESTIMONY
NRCP 28 – PERSONS BEFORE WHOM DEPOSITIONS MAY BE TAKEN
NRCP 30 – DEPOSITIONS UPON ORAL EXAMINATION
NRCP 31 – DEPOSITIONS UPON WRITTEN QUESTIONS
NRCP 32 – USING DEPOSITIONS IN COURT PROCEEDINGS
Court Intervention
Getting a Motion Filed with the Discovery Commissioner
Objecting to Discovery Commissioner’s Report
Complying with the Meet and Confer Requirement in Nevada Discovery Disputes
What is a Motion in Limine?
Nevada Statutes of Limitation and the Discovery Rule
Discovery Commissioner Opinions
Discovery Commissioner’s Opinion #11 (April 2003) – Olivarez v Rebel Oil Co.
Discovery Commissioner’s Opinion #10 (November 2001) – Alboum v. Koe, M.D., et al.
Discovery Commissioner’s Opinion #9 (June 1992) – Legardy v. Las Vegas Metro. Police Dept.
Discovery Commissioner’s Opinion #8 (September 1990) – Houk v. Wet ‘N Wild
Discovery Commissioner’s Opinion #7 (July 1990) – Amer. Cas. v. Hotel and Rest. Emp. and Bartenders Int’l Union Welfare Fund, et al.
Discovery Commissioner’s Opinion #6 (July 1989) – Wilburn v. Caterpillar
Discovery Commissioner’s Opinion #5 (March 1989) – Mitchell v. Simkins
Discovery Commissioner’s Opinion #4 (March 1989) – Assoc., Capital Serv. v. Ponderosa Lawn Servi.
Discovery Commissioner’s Opinion #3 (August 1988) – Dillon v. Brown
Discovery Commissioner’s Opinion #2 (August 1988) – Grassinger v. Trudel
Discovery Commissioner’s Opinion #1 (June 1988) – Moyns v. Creviston
See the excellent Compelling Discovery Blog by Michael Lowry here
