Judge Crystal Eller
Individual Rules, Standing Orders & Policies
- Rules last changed:
Limits & Logistics
Courtesy Copies
Motion In Limine, Motion To Dismiss, Motion For Summary Judgment
- Chambers Drop Off • At Least One Week Prior To Scheduled Hearing
Exhibits
Court-wide- 3 copies
Communication
Clerk8 contacts
- clinea@clarkcountycourts.us
- howardm@clarkcountycourts.us
- dept19lc@clarkcountycourts.us
- courthelpdesk@clarkcountycourts.us
- sivongsas@clarkcountycourts.us
- milhousk@clarkcountycourts.us
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- dcevidencevault@clarkcountycourts.us
- 702.671.4442
Chambers3 contacts
- dc19inbox@clarkcountycourts.us
- (702) 671-4450
- (702) 671-4449
Document Format Requirements22 rules
Two drives are required per exhibit set (Joint, Plaintiff, Defendant): a 'Golden Drive' with PDF exhibits plus the exhibit list and a 'Working Drive' with PDF exhibits only.
TWO drives per set of exhibits (2 drives of the Joint Exhibits, 2 drives of Plaintiffs, 2 drives of the Defendants) Drive 1 - “Golden Drive”: exhibits in pdf format + the exhibit list Drive 2 - “Working Drive”: exhibits in pdf format, no exhibit list
Photographs must be identified separately with one photograph per page.
Photographs should be identified separately. ONE PHOTOGRAPH PER PAGE is required.
Three sets of exhibits must be submitted in tabbed binders no larger than three inches.
Submit THREE (3) SETS of exhibits in BINDERS no larger than three (3) inches, separated by tabs.
Electronic exhibits cannot be admitted in portions; selected pages of a large exhibit must be designated as a separate exhibit.
Electronic exhibits cannot be admitted in portions. If an exhibit is hundreds or thousands of pages long, and you wish to move into evidence only a select few, please designate that group as a separate exhibit.
Each proposed electronic exhibit file must be named numerically (e.g., 1047.pdf) per section 4 of the Electronic Exhibit Protocol.
Please note, section 4 of the Protocol Regarding Electronic Exhibits instructs as follows, “The file name for each proposed electronic exhibit shall be numerical, i.e. 1047.pdf”.
Each exhibit must bear a 'proposed' label placed on the back of the first page, lower left corner, not covering material, before trial begins.
Counsel is required to mark each exhibit with a “proposed” label prior to the start of trial. The proposed sticker should be placed on the back of the first page on the lower left corner. (should not be covering any material)
Exhibit PDF file names and exhibit list entries must use only the number and file extension with no leading zeroes (e.g., 12345.pdf).
No leading zeroes in the file names of the pdf nor on the exhibit list. Exhibits are to be named with only the <number>.<file extension>. For example, (12345.pdf)
Courtesy copies must be compiled into a single 3-ring binder in Motion/Opposition/Reply format with tabbed exhibits and a Table of Contents.
Copies must be compiled into a single 3-Ring binder, in Motion/Opposition/Reply format, with tabbed exhibits, and a Table of Contents.
Litigants must bring their own adaptor to convert computer video to VGA because the courtroom does not provide adaptors for newer computers.
The courtrooms are NOT equipped with adaptors for newer computers. Please bring the appropriate adaptor to convert your computer video to VGA.
When playing a DVD or CD in court, the party must bring the laptop that previously played the disc to ensure compatible software is available.
If you find it necessary to play a DVD or CD please bring with you the laptop that has previously played your disc to ensure you have the correct software in which to play it in the courtroom.
Depositions are not marked or admitted as exhibits, but original unopened depositions may be provided and published when used in court.
Depositions are neither marked nor admitted as exhibits; however, original, unopened depositions may be provided and “published” when used in Court.
Joint exhibits must be numbered J01, J02, J03, etc., and stipulated exhibits are admitted for all purposes.
Stipulated exhibits will be admitted for all purposes and marked and recorded as such. Joint exhibits should be numbered as follows: J01, J02, J03, etc.
Two printed sets of the exhibit list must be provided, printed in an easily readable font.
Two sets of a printed copy of the exhibit list– please print in easily readable font.
Paper exhibits should be printed single sided.
All paper exhibits should be single sided.
Electronic exhibit drives must not contain subfolders.
The drives should NOT have any subfolders.
Plaintiffs number their exhibits and Defendants use letters; parties with large exhibit sets must coordinate block numbers with the Court Clerk.
Plaintiffs to use numbers and Defendants to use letters. If ample amount of exhibits, please coordinate with the Court Clerk for set of block numbers (i.e Plaintiff 1-500, Defense 501-1000).
Excel documents must be converted to PDF or submitted separately, and videos must be submitted separately.
Excel document should be converted to PDF or submitted separately. Videos should also be submitted separately.
The three exhibit sets are distributed to the witness stand, the Judge, and the Courtroom Clerk, with the Clerk's set designated as the originals.
Each set will be distributed in the courtroom as follows: one set for the witness stand, one set for the Judge, and one set for the Courtroom Clerk. The set of exhibits maintained by the Courtroom Clerk will be designated as the originals.
Larger versions of exhibits may be used as demonstratives, which generally are not marked, do not go to the jury, and are returned to counsel.
Larger versions of exhibits may be used as demonstrative exhibits. These are generally not marked as exhibits, do not go to the Jury, and will be returned to submitting counsel.
Department XIX accepts electronic signatures on any document in accordance with Administrative Orders 20-17 and 20-24.
District Court Department XIX accepts electronic signatures on any document, pursuant to the requirements of Administrative Orders (AO) 20-17 and 20-24.
Document Filing Requirements18 rules
Before trial, each witness appearing by video conference requires either a stipulation of both parties or approval from the judge, and arrangements can take one to two weeks.
Prior to the start of trial, both parties must stipulate to each witness that wishes to appear by video conferencing. Once stipulated, proceed to 2. OR: Prior to the start of trial, parties must receive approval from the judge to have each witness appear by video conferencing.
Document Type
Video Conferencing Witness Request
The Agreement to Pay Recording Fee form must be completed, signed, and returned to the Court Recorder before the hearing or trial begins (it may be handed in on the day of the hearing or the first day of trial).
Please complete the form, sign it and return it to the Court Recorder prior to the beginning of your hearing or trial (the form can be handed to the Court Recorder the day your matter is heard or on the first day when trial begins).
Document Type
Agreement To Pay Recording Fee
Daily transcripts by a privately secured Court Reporter require prior approval from the Judge, are at the party's expense, and are not the official Court record.
Option #1: You must have preapproval by the Judge to have a Court Reporter present in court. You will secure your own Court Reporter to type daily transcripts during trial. You will be responsible for all fees associated with the Court Reporter. Daily transcripts produced by the Court Reporter are for your use only during trial. These transcripts will not be considered the official Court record.
Document Type
Daily Transcripts Private Court Reporter
An ATEAR form, available on the County website or from the Court Recorder, must be submitted to the JEA in Department 19 to arrange video conferencing.
One week prior to start of trial you must submit an ATEAR form to the JEA in Department 19. The form is available on the County website here (select: Audio/Visual Appearance Request Instructions) or contact the Court Recorder for a copy.
Document Type
ATEAR Form
Before using any recording clips during a hearing or trial, the party must state on the record that clips will be shown.
However, the information obtained from the CDs may be utilized for your use during your hearing/trial (including recording clips), but you must put on the record that you will be showing any clips prior to using them.
Document Type
Recording Clips Presentation
In jury trials, parties must provide an additional blank thumb drive and the party offering electronic exhibits must provide a blank laptop for the jury to view exhibits.
JURY TRIAL ONLY: Parties will need to provide an additional BLANK THUMB DRIVE. Also, the side offering electronic exhibits is to provide a blank laptop for the jury to view the exhibits. (Section 9 & 12 of the attached Protocol Regarding Electronic Exhibits)
Document Type
Electronic Exhibits
The exhibit list must exactly match the exhibit file names as labeled on the thumb drives (e.g., 537.pdf, 538.pdf, 539.pdf).
The exhibits list should reflect the exhibits exactly as they are labeled in the thumb drives (ex. 537.pdf, 538.pdf, 539.pdf).
Document Type
Exhibit List
Each binder must include an exhibit list with a short description of each exhibit and columns labeled 'Offered,' 'Objection,' and 'Admitted.'
Include one (1) exhibit list in each binder containing the following information: a short description of each exhibit with a minimum of three (3) columns on the right-hand side labeled “Offered,” “Objection,” and “Admitted.”
Document Type
Exhibit List
Every OST request must attach a courtesy copy of the Motion/Application and must contain proposed dates and a detailed explanation for the request.
Any and all requests for OSTs must have a courtesy copy of the Motion/Application attached. Requests for OST must contain proposed dates and a detailed explanation for the request.
Document Type
Request For Order Shortening Time
Stipulations and orders for dismissal must comply with EDCR 2.75 or they will be returned.
All stipulations and orders for dismissal must comply with EDCR 2.75 or they will be returned.
Document Type
Stipulation And Order For Dismissal
Proposed orders will not be signed unless the "IT IS SO ORDERED" language and the Judge's signature line appear on a page containing the substance of the order (or at least two lines of stipulation text, or a page with some signatures plus the case number/name when multiple signatures make that impossible).
The proposed Order will not be signed if the "IT IS SO ORDERED" language and signature line are on a separate page from the content of the Order. The signature line must be on a page describing what the Judge is ordering. Alternatively, the Judge's signature line may be on the same page as the other signatures provided that there are at least two lines of text from the stipulation. The only exception is if there are multiple signatures, and it is not possible for the party to put the Judge's signature with two lines of text, in which case the parties need to ensure the Judge's signature is at least on a page with some of the signatures, and the case number/name of the document is included on the page to be signed.
Document Type
Proposed Order
A Stipulation and Order to Extend Discovery and Trial must contain the required deadlines/dates (trial date, pretrial conference, calendar call, discovery cutoffs, and status check) or can be left blank or confirmed by calling the department.
When submitting a Stipulation and Order to Extend Discovery and Trial, the Order must contain the following Deadlines/Dates (leave blank or call the department for correct dates):
Document Type
Stipulation And Order To Extend Discovery And Trial
Ex parte TRO applications are resolved in chambers and must include an affidavit showing adequate advance notice or an NRCP 65(b) exception, and the applicant must be prepared to deposit any required bond with the Clerk.
Ex parte applications for a TRO shall be presented to the Court to be resolved in chambers. The applicant must, by affidavit, show adequate advance notice to the other side or an appropriate exception in accordance with NRCP 65(b). Further, applicants should be aware of, and prepared to deposit with the Clerk of the Court, any required bond, as determined by the Court.
Document Type
Ex Parte Tro Application
Motions in limine are limited to ten (10) per side, with additional motions allowed only upon a properly filed and served motion showing good cause after failed EDCR 2.47(b) negotiations.
Further, Dept. XIX limits motions in limine to ten (10) per side. If a party cannot negotiate matters (pursuant to EDCR 2.47(b)), and feels further motions are necessary, the Court will entertain a properly filed and served motion showing good cause for the additional filings.
Document Type
Motion In Limine
Orders inconsistent with the Court's oral ruling or Court Minutes will be returned unsigned or corrected via interlineation, and perceived errors in the Court Minutes must be raised by motion under NRCP 60(a).
Any order that is inconsistent with the oral ruling of the Court or the Court Minutes will be returned unsigned for correction, or will be corrected via interlineation. Counsel should notify the Court of any perceived error in the Court Minutes by Motion pursuant to NRCP 60(a).
Document Type
Proposed Order
Unopposed motions may be granted in advance by submitting an order to the department inbox, and absent other instruction the order granting an unopposed motion must not include findings of fact or conclusions of law.
Pursuant to EDCR 2.20, Department XIX may grant certain unopposed motions in advance by submitting an order to the department inbox (DC19Inbox@clarkcountycourts.us). Unless otherwise ordered, an order granting an unopposed motion must not include findings of fact or conclusions of law.
Document Type
Order Granting Unopposed Motion
Parties must discuss and designate on the Agreement to Pay Recording Fee form which billing option (equal 50/50 split, plaintiff pays, defendant pays, or neither side pays) will cover the $40 per hour recording fee.
Please discuss with opposing counsel and check which billing process you will use to pay the recording fee of $40 (NRS 3.370) per hour for the trial/hearing:
Document Type
Agreement To Pay Recording Fee
On the ATEAR form, the witness appearance should be scheduled within a four to five hour timeframe, or longer if extended testimony, multiple days, or possible rebuttal recall is anticipated.
When completing the form please keep in mind that you should schedule your witness to appear within a four to five hour timeframe or longer if you know it will take longer for the witness to be on the stand, possible multiple days of questioning, or of the possibility that a witness will be recalled as a rebuttal witness.
Document Type
ATEAR Form
Filing & Service rules
Filing Timing and Cure Windows
Opposition to a video conferencing request must be made in writing within two (2) judicial days of service of the request.
Opposing counsel will have an opportunity to oppose this request. Opposition to the request must be made in writing within two (2) judicial days of service of this request.
Page 1 | BLUE JEANS – VIDEO CONFERENCING
The ATEAR form for video conferencing must be submitted to the JEA in Department 19 one week before the start of trial.
One week prior to start of trial you must submit an ATEAR form to the JEA in Department 19.
Page 1 | BLUE JEANS – VIDEO CONFERENCING
Parties must allow a minimum of two weeks before the Calendar Check hearing for validation of electronic exhibit drives.
Additionally, please allow for ample time (a minimum of two weeks) to validate the drives prior to the Calendar Check hearing with the Court.
Page 1 | ELECTRONIC EXHIBITS
The prevailing party must prepare the proposed order and submit it to the department inbox within ten (10) days of notification of the ruling, pursuant to EDCR 7.21.
UNLESS OTHERWISE STATED BY THE COURT, THE PREVAILING PARTY IS TO PREPARE THE ORDER. Department XIX requires proposed orders to be submitted to the department inbox (DC19Inbox@clarkcountycourts.us) within ten (10) days of notification of the ruling, pursuant to EDCR 7.21.
Page 1 | Submission of Orders
A stipulated jury questionnaire is allowed with Court approval, and the stipulation and proposed questionnaire must be submitted to the Department not less than 8 weeks before the Pretrial Conference.
Department XIX will allow a Stipulated Jury Questionnaire. The parties' must seek approval from the Court. The Stipulation and Proposed Jury Questionnaire must be submitted to the Department not less than 8 weeks before the Pretrial Conference.
Page 1 | Jury Questionnaires
If the parties cannot stipulate to a jury questionnaire, a motion seeking one must be filed 12 weeks before the Pretrial Conference.
If the parties cannot reach a Stipulation, then a motion is required and should be filed 12 weeks before the Pretrial Conference.
Page 1 | Jury Questionnaires
Filing Fees and Waivers
All civil matters in Department 19 are recorded and a $40 per hour recording fee (NRS 3.370) applies.
Department 19 is a court recording department, therefore all civil matters heard in Department 19 are recorded at the request of the Judge. District Court Administration charges $40 an hour for recording fees (NRS 3.370).
Page 1 | Recording Fees
Even when a party retains their own Court Reporter, the Agreement to Pay Recording Fee form and the recording fees remain required, in addition to transcription and CD fees, before any official transcripts can be produced.
You will still be required to complete the Agreement to Pay Recording Fee form prior to your hearing/trial. The recording fees must still be paid in addition to daily transcription fees, daily CDs, and before any future official transcripts can be produced.
Page 1 | Daily Trial Transcripts
Thumb drives of proceedings cost $5 each, and any self-provided thumb drive must be unopened and in its original packaging.
CDs and thumb drives of proceedings are available for $2 per disc and $5 per thumb drive. Please note: If you provide your own thumb drive, it must be unopened and in the original packaging.
Page 1 | CDs/Thumb Drives
CDs of proceedings are available for $2 per disc and must be ordered through the Court Recorder.
CDs and thumb drives of proceedings are available for $2 per disc and $5 per thumb drive.
Page 1 | CDs/Thumb Drives
Courtesy Copy Requirements
Paper courtesy copies are required for Motions in Limine, Motions to Dismiss, and Motions for Summary Judgment and must be delivered to the department inbox at least one week before the hearing; email and fax courtesy copies are not accepted.
Hearings – Hard paper courtesy copies are required for Motions in Limine, Motions to Dismiss, and Motions for Summary Judgment. If a courtesy copy is required for any other hearings, the Law Clerk will reach out to the moving party requesting them. Department XIX requires that paper courtesy copies be delivered to its inbox at least one week prior to the scheduled hearing pursuant to EDCR 2.20 (g). E-mail and faxed courtesy copies are not accepted.
Page 1 | Courtesy Copies – Hearings
Sealing & Redaction Procedures
All social security numbers and insurance information must be redacted from exhibits.
Counsel must redact any and all social security numbers and any insurance information from the exhibits.
Page 1 | PAPER EXHIBITS
Filing Bundling Requirements
Motions in limine must be filed as independently-noticed motions and may not be bundled into omnibus motions.
Department XIX requires that motions in limine be submitted as independently-noticed motions rather than omnibus motions.
Page 1 | Omnibus Motions
Pre-Motion Conference Requirements
Remote appearances are not allowed for arraignments, calendar calls, and sentencing without the Judge's prior approval.
Department 19 does not allow remote appearances for arraignments, calendar calls, and sentencing without prior approval from the Judge.
Page 1 | Department 19 Criminal - Judge Crystal Eller (8 am - 9 pm)
Counsel must appear in person for Motions to Dismiss and Motions for Summary Judgment; remote appearances are not permitted.
Please note that Dept. 19 does not allow remote appearances for Motions to Dismiss or Motions for Summary Judgment. Counsel must appear in person for those hearings.
Page 1 | Department 19 Civil - Judge Crystal Eller (8 am - 8 pm)
Undisputed motions in limine must be resolved via EDCR 2.47 conference or stipulation before the hearing, and the Court will not hear undisputed motions in limine that should have been resolved.
Parties have a responsibility to resolve undisputed motions in limine prior to hearing pursuant to EDCR 2.47. The Court will not hear on its calendar undisputed motions in limine that ought to have been resolved via EDCR 2.47 conference or stipulation.
Page 1 | Omnibus Motions
Adjournment & Extension Requirements
In medical malpractice cases, stipulations to continue trial are not accepted; parties must instead file a motion or stipulated motion to continue trial.
Medical Malpractice cases: Stipulations to Continue Trial for medical malpractice cases are not accepted as they require a firm trial setting. Please file a motion or stipulated motion to continue trial.
Page 1 | Stipulation and Order to Extend Discovery and Continue Trial
Chambers Communication Rules
A Microsoft Word copy of the exhibit list must be emailed to the clerk, judicial assistant, and law clerk prior to trial.
In addition, please e-mail a copy of the exhibit list (in Microsoft Word), prior to trial, to clinea@clarkcountycourts.us, HowardM@clarkcountycourts.us and dept19lc@clarkcountycourts.us.
Page 1 | PAPER EXHIBITS
Parties must email the Evidence Custodian (cc: DCEvidencevault@clarkcountycourts.us) to schedule an appointment for verification of their exhibit drives.
Once your drives have been formatted and are ready to be submitted, an appointment will be scheduled for the verification of your drives. Please contact the Evidence Custodian – Kari Milhous by email at milhousk@clarkcountycourts.us as well as cc’ing the DCEvidencevault@clarkcountycourts.us to schedule an appointment for validation of the drives.
Page 1 | ELECTRONIC EXHIBITS
Counsel must email the Court Clerk to set an exhibit appointment and deadline, and must meet and confer under EDCR 2.67 to stipulate to joint exhibits before submitting exhibits.
Counsel for each party shall contact the Court Clerk, April Cline (clinea@clarkcountycourts.us), to set an appointment and deadline for exhibits. Counsel must meet and confer pursuant to EDCR 2.67 to discuss exhibits and stipulate to Joint Exhibits, prior to submitting them to the Court Clerk.
Page 1 | PAPER EXHIBITS
Requests for Orders Shortening Time must be emailed to the department inbox with "Order Shortening Time" in the subject line, with advance notice to the JEA or law clerk welcome.
Order Shortening Time – A Request for an Order Shortening Time ("OST") must be delivered to the department inbox (DC19Inbox@clarkcountycourts.us). "Order Shortening Time" must be in the subject line. Advance notice to the JEA or law clerk is welcome.
Page 1 | Submission of Orders
To obtain official daily transcripts from court recordings, the party must contact the Court Recorder a few weeks before trial to see if an outside transcription company is available.
Option #2: A few weeks prior to your trial contact the Court Recorder for Department 19 to inquire if she can secure an outside company to type dailies using the court recordings. If one is available the company will set up the payment plan and delivery of the dailies directly through you. Transcripts produced from the court recordings will be considered official Court records. This option is only available if an outside service can be located and available to provide this service.
Page 1 | Daily Trial Transcripts
Parties planning to use courtroom equipment must contact the Court Recorder before trial begins to arrange an equipment test.
If you are planning to use any equipment please contact the Court Recorder so that she can meet with you prior to trial starting so that you can test the equipment.
Page 1 | EQUIPMENT
Daily CDs of a hearing or trial must be arranged with the Court Recorder before the hearing or trial starts.
If you would like daily CDs of your hearing/trial please make the arrangements with the Court Recorder prior to the start of your hearing/trial.
Page 1 | CDs/Thumb Drives
Parties must contact the court as soon as possible with the number of electronic exhibits planned so number ranges can be assigned.
Please contact me as soon as possible to provide the number of exhibits you plan to use so I may assign each party with a range of numbers for your exhibits.
Page 1 | ELECTRONIC EXHIBITS
Courtroom equipment must be reserved in advance by emailing CourtHelpDesk@clarkcountycourts.us with a courtesy copy to the Court Recorder.
To reserve courtroom equipment, i.e., ELMO, screens, televisions, projectors, DVD/VHS players, etc., submit an advanced request to CourtHelpDesk@clarkcountycourts.us with a courtesy copy to the Court Recorder, Serenity Sivongsa, at sivongsas@clarkcountycourts.us.
Page 1 | PAPER EXHIBITS
When counsel cannot agree on order language, they must email competing versions to the Department Inbox in a word document stating only that there is a disagreement as to the wording, with no additional argument or explanation.
In District Court Department XIX, when counsel are unable to agree on the language of an order, counsel should present their competing positions in a word document emailed to the Department Inbox with no additional argument or explanation; stating only that there is a "disagreement as to the wording of the Order."
Page 1 | Contested Orders
Letters to the Court containing substantive merits argument on contested issues are disfavored, treated as improper ex parte communications even if copied to opposing counsel, and will generally be disregarded.
Letters to the Court containing substantive argument on the merits of a contested issue are disfavored, viewed as improper ex parte communications (even if copied to opposing counsel), and will generally be disregarded.
Page 1 | Contested Orders
Correspondence directed to the Department or intended as a courtesy copy must be electronically served on all parties and emailed to the Department.
Correspondence – Department XIX requests that all "correspondence" directed to the Department or intended to be a courtesy copy be electronically served on all parties and emailed to the Department.
Page 1 | Courtesy Copies – Hearings
A party whose matter is set on the Chambers Calendar may email the Court (cc'ing all parties) to request oral argument, and the Court will notify the party if the request is granted.
If your matter has been set on the Chambers Calendar, but you prefer an oral hearing, you may submit an email, cc'ing all parties, to the Court requesting oral argument, and the Court will notify you if your request is granted.
Page 1 | Regular Chambers Calendar
Transcript requests and Zoom appearance logistics questions must be directed to Court Recorder contact Serenity Sivongsa at 702.671.4442 or SivongsaS@clarkcountycourts.us.
Department XIX uses a Court Recorder. To request a transcript, or for any questions regarding the logistics of Zoom appearances, please contact Serenity Sivongsa at 702.671.4442 or SivongsaS@clarkcountycourts.us.
Page 1 | Court Reporter or a Court Recorder for its official record
Department XIX chambers can be reached at (702) 671-4450 (office), (702) 671-4449 (fax), (702) 671-4443 (law clerk), and dept19lc@clarkcountycourts.us (email).
Office – (702) 671-4450, Fax – (702) 671-4449, Law Clerk – (702) 671-4443, Email – dept19lc@clarkcountycourts.us
Page 1 | Department XIX