Eighth Judicial District Court, Clark County Document Filing Requirements

CRITICAL

Applies to

Proposed findings conclusions

In non-jury cases, proposed findings of fact and conclusions of law must be submitted at least two working days before trial, emailed to the law clerk with a copy to opposing counsel, in Word format.

Judge Hardy requires the submission of proposed findings of fact and conclusions of law in non-jury cases at least two working days prior to the commencement of trial. Those should be emailed to the law clerk, with a carbon copy to opposing counsel, in Word format.

CRITICAL

Applies to

Final pretrial conference submissions

Lead trial counsel must bring marked exhibits, typed exhibit lists, jury instructions in two groups, proposed voir dire questions, original depositions, and an equipment-needs list to the final pre-trial conference.

Lead trial counsel must comply with EDCR 2.67 and 2.68 and bring to the final pre-trial conference the following: All exhibits already marked by counsel for identification purposes; Typed exhibit lists with all stipulated exhibits marked as admitted; Jury instructions in 2 groups: the agreed upon uncontested set, and the contested sets; Proposed voir dire questions; and Original depositions. A list of equipment needed for trial not usually found in the courtroom. The court or its designee will inform counsel if such equipment is available in house or if counsel must procure the same and bring to the courtroom;

CRITICALCivil cases

Applies to

Exhibits

Parties must notify the court at the trial readiness pre-trial conference whether they will use paper or electronic exhibits.

Parties can chose to use either paper or electronic exhibits. Parties must notify the court of their format choice at the trial readiness pre-trial conference.

CRITICAL

Applies to

Confidentiality order

Confidentiality orders will be approved only if they include a detailed good cause statement and the Court's required reservation-of-rights language.

Judge Hardy will approve a confidentiality order for discovery purposes if the order includes a detailed statement demonstrating that good cause exists. All such orders must contain the following language or language substantially similar: "The Court retains the right to allow disclosure of any subject covered by this stipulation or to modify this stipulation at any time in the interest of justice."

CRITICALCivil cases

Applies to

Jury instructions

Counsel must meet and confer on jury instructions before the Calendar Call, and each side must provide the court at the Calendar Call an agreed set of instructions, a proposed verdict form, and any additional instructions with a Word-format electronic copy.

In accordance with EDCR 2.67,prior to the Calendar Call, counsel shall meet and discuss preinstructions to the jury, jury instructions and verdict forms. Each side shall provide the Court, at the Calendar Call, an agreed set ofjury instructions and proposed form of verdict along with any additional proposed jury instructions with an electronic copy in Word format.

CRITICAL

Applies to

Jury instructions

Counsel are to submit proposed jury instructions and forms of verdict in word format prior to the commencement of trial. Counsel should meet and agree upon jury instructions and object to jury instructions proposed by the adverse parties.

Counsel are to submit proposed jury instructions and forms of verdict in word format prior to the commencement of trial. Counsel should meet and agree upon jury instructions and object to jury instructions proposed by the adverse parties.

CRITICAL

Applies to

Motion to withdraw as counsel

A motion to withdraw as counsel must comply with EDCR 7.40 and include the client's last known email address.

Withdrawing counsel must comply with EDCR 7.40 and also provide the last known email address of the client in the motion.

CRITICALCivil cases

Applies to

Electronic exhibit list

An exhibit list must be provided in both paper and Excel format; the Excel version must be named 'Exhibit List' and located only on the master electronic storage device.

An exhibit list in substantially the same form as the attachment hereto shall be provided in paper form as well as electronic in Excel format. The electronic (Excel) version of the exhibit list is to be named "Exhibit List" and is to be located on the master electronic storage device only.

CRITICALCivil cases

Applies to

Exhibit list

A Word-version exhibit list prepared on the court's template must be emailed to the Courtroom Clerks when exhibits are submitted (obtain the template from the Courtroom Clerk if needed).

EXHIBITLIST-Usetheexhibitlisttemplatesentandemail aWordversionoftheexhibitlisttotheCourtroomClerks when you submit your exhibits at revesf(oclarkcountvcourts.us and RabonD@clarkcountvcourts.us. lf you do not have it, please obtain it from the Courtroom Clerk.

CRITICALCivil cases

Applies to

Demonstrative exhibits

All anticipated demonstrative exhibits, including exemplars, must be disclosed before the final pre-trial conference.

Any demonstrative exhibits including exemplars anticipated to be used must be disclosed prior to the final pre-trial conference.

CRITICALCivil cases

Applies to

Electronic exhibit

The proposed electronic exhibit must exactly match the admitted exhibit; any change requires resubmission by counsel as a supplemental proposed exhibit with a new exhibit number.

The proposed electronic exhibit shall exactly match the admitted electronic exhibit. Any change between the proposed electronic exhibit and the admitted electronic exhibit will require the submission of the exhibit as a supplemental proposed electronic exhibit by offering counsel with a new proposed exhibit number in conformance with paragraph 4.

CRITICALCivil cases

Applies to

Electronic exhibit

Proposed electronic exhibits must exactly match the admitted exhibits; any change requires resubmission as a supplemental proposed exhibit with a new exhibit number.

The proposed electronic exhibit shall exactly match the admitted electronic exhibit. Any change between the proposed electronic exhibit and the admitted electronic exhibit will require the submission of the exhibit as a supplemental proposed electronic exhibit by offering counselwith a new proposed exhibit number in conformance with paragraph 4.

CRITICALCivil cases

Applies to

Exhibit list

The electronic exhibit list must include tabular entries for each proposed exhibit showing exhibit number, storage device identification, description, discovery designation, and clerk notation spaces for date offered, objections, and admission; physical evidence must be listed on a separate exhibit list.

The list must include the following information in tabular format for each proposed electronic exhibit (please note that traditional "physical"evidence is not to be listed on the electronic exhibit list and should be submitted on a separate exhibit list): a. The exhibit number for the proposed electronic exhibit consistent with paragraph 4 above b. The identification of the electronic storage device on which the proposed exhibit is stored or a space for the clerk to make notation in the event the Exhibit was submitted in traditional form c. A description of the proposed electronic exhibit d. Any numeric or alphanumeric designation used on the proposed electronic exhibit during discovery or other pretrial proceedings f. A space for the clerk to make notation on the date the proposed electronic exhibits is offered g. A space fbr the clerk to make notation on objections made to the proposed electronic exhibits at the time it is offered for admission h. A space forthe clerkto make notation on the admission of the proposed electronic exhibits

CRITICALCivil cases

Applies to

Exhibit list

The exhibit list must be provided in both paper and Excel format, with the Excel version named 'Exhibit List' and located only on the master electronic storage device.

An exhibit list in substantially the same form as the attachment hereto shall be provided in paper form as well as electronic in Excel format. The electronic (Excel) version of the exhibit list is to be named "Exhibit List" and is to be located on the master electronic storage device only.

CRITICALCivil cases

Applies to

Jury deliberation equipment

In jury trials, the proffering party must provide a laptop and monitor for deliberations containing only an operating system, associated programs, and an Adobe viewer for admitted exhibits with no internet or research capability, subject to inspection by Court I.T. staff and counsel.

Prior to the commencement of deliberations by a jury, if the trial is a jury trial, the party proffering the electronic exhibits will provide a laptop computer and additional monitor with only an operating system and associated programs, an adobe program to permit viewing of the admitted exhibits, and no internet or other research capability. The laptop will be subject to inspection by Court I.T. staff and counsel for compliance prior to it being provided to the deliberating jury.

CRITICALCivil cases

Applies to

Electronic exhibits

The offering party must provide the clerk two identical sets of proposed electronic exhibits on separate storage devices, plus an additional blank device in jury trials for copying admitted exhibits for jury use.

The party offering the proposed electronic exhibits shall provide the clerk with two identical sets of the proposed electronic exhibits on separate electronic storage devices. In the event of a jury trial, an additional blank electronic storage device will be required to copy all of the admitted electronic exhibits onto for use by the jury (see paragraph l2)' The clerk will maintain one of the electronic storage devices as a master without modification.

CRITICAL

Applies to

Discovery motion

Must include

local rule certificate

All discovery motions must contain the certification required under EDCR 2.34.

As a reminder, all discovery motions must contain the certification required under EDCR 2.34.

CRITICAL

Applies to

Pretrial documents

Each counsel must deliver the pre-trial memorandum, proposed voir dire, and jury instructions to chambers before the scheduled trial date.

EACH COUNSEL IS REQUIRED TO DELIVER PRE-TRIAL MEMORANDUM, PROPOSED VOIR DIRE & JURY INSTRUCTIONS TO CHAMBERS BEFORE THE SCHEDULED TRIAL DATE.

CRITICAL

Applies to

Default judgment

An application requesting a default judgment award of at least $50,000 must state “Hearing Requested.”

Please indicate “Hearing Requested” in the Application for Default Judgment if the total award requested is $50,000 or more.

CRITICAL

Applies to

Order

Orders must bear original signatures from all parties or include, as the final page(s), an email confirming their approval to use electronic signatures.

All orders must have original signatures from all parties or an email – appended as the last page(s) of the proposed order – confirming that the parties approved use of their electronic signature.

CRITICALCivil cases

Applies to

Agreement to pay recording fee

The Agreement to Pay Recording Fee must be signed by both parties before trial begins and returned to the Recorder.

An Agreement to Pay Recording Fee will be provided to counsel prior to the start of trial and must be signed by both parties prior to the beginning of trial and returned to the Recorder.

CRITICAL

Applies to

Proposed order

Counsel preparing an order must provide the draft to opposing counsel with a reasonable opportunity to review and comment.

Counsel designated to prepare the order is required to provide a draft to opposing counsel(s), allowing for a reasonable opportunity for review and comment.

CRITICAL

Applies to

Minor compromise order

An order approving a minor’s compromise must state that the parent or guardian will use the proceeds at their discretion for the minor’s benefit, subject to court-ordered terms or conditions.

The Order must have language stating that the parent or guardian to whom the proceeds of the compromise are ordered to be paid will use the proceeds at his or her discretion for the benefit of the minor, in compliance with any terms or conditions ordered by the Court.

CRITICAL

Applies to

Exhibits

If separate sets of exhibits are submitted, duplicate exhibits must be eliminated.

If separate sets of exhibits are submitted, duplicate exhibits MUST be eliminated.

CRITICAL

Applies to

Guilty plea agreement

Defendants must sign guilty plea agreements.

For guilty plea agreements, defendants must sign the agreement.

CRITICAL

Applies to

Guilty plea agreement

An attorney may not sign a guilty plea agreement on the client’s behalf.

Attorneys cannot sign the GPA on the client’s behalf.

CRITICALCivil cases

Applies to

Proposed findings conclusions

Proposed Findings of Fact and Conclusions of Law must include all elements of each cause of action alleged by Plaintiff and the basis for Defendant's affirmative defense.

The detailed, proposed Findings of Fact and Conclusions of Law shall include all elements of each Cause of Action alleged by Plaintiff and the basis for Defendant's Affirmative Defense.

CRITICAL

Applies to

Jury instructions

All counsel must submit a single set of jury instructions as two separate documents: one for agreed-upon instructions and one for disputed instructions.

ONLY ONE SET OF JURY INSTRUCTIONS TO BE SUBMITTED BY ALL COUNSEL AS TWO SEPARATE DOCUMENTS: 1) THOSE AGREED UPON AND 2) THOSE IN DISPUTE.

CRITICAL

Applies to

Exhibit list

An exhibit list must be submitted, numbered for plaintiff(s) and lettered for defendant(s), containing a title or short description of each exhibit; joint exhibit lists use numbers only per the attached Exhibit Sheet.

Submit an Exhibit List, numbered for the Plaintiff(s), and lettered for Defendant(s), containing title and/or short description of each exhibit. If it is a Joint Exhibit List, just use numbers. (See attached Exhibit Sheet).

CRITICAL

Applies to

Exhibits

Counsel must provide a hard copy of every exhibit to be admitted at an evidentiary hearing.

Department 25 requires counsel to provide a hard-copy of all exhibits to be admitted into the record for any type of evidentiary hearing.

CRITICAL

Applies to

Proposed order

Prevailing counsel must submit a draft order to opposing counsel for review; the department imposes no fixed deadline but considers 7-10 days a reasonable review period.

Does your department require prevailing counsel to submit a draft order to opposing counsel to review? Yes Does your department impose a period of time for opposing counsel to review and return an Order? No Reasonable time for opposing counsel to review and return an order 7-10 days

CRITICAL

Applies to

Proposed order

Proposed orders must be submitted in PDF format to the Department V email inbox.

Proposed orders must be submitted in PDF format to DeptVInbox@ClarkCountyCourts.us

CRITICAL

Applies to

Proposed order

Only one proposed order per email, with counsel's electronic signature approval included, and a subject line containing the case number, filing event code, and document name.

Only one order can be attached per e-mail and must also include e-mail correspondence from counsel approving the use of their electronic signature. The e-mail subject line must contain the case number, filing event code and the name of the document (i.e., “J-20-123456, Out-of-Home Order”).

CRITICALCivil cases

Applies to

Powerpoint presentation

PowerPoint Presentation: If counsel intends to use a PowerPoint presentation, please provide a paper copy to the court as this will be marked as a court's exhibit, which does not go back to the Jury. If there are overlying projections or video files embedded into the PowerPoint presentations, please provide an electronic copy (CD, DVD, or Flash drive) instead of a paper copy.

PowerPoint Presentation: If counsel intends to use a PowerPoint presentation, please provide a paper copy to the court as this will be marked as a court's exhibit, which does not go back to the Jury. If there are overlying projections or video files embedded into the PowerPoint presentations, please provide an electronic copy (CD, DVD, or Flash drive) instead of a paper copy.

CRITICALCivil cases

Applies to

Exhibit list

Exhibits must be accompanied by a table-format exhibit list with exhibit numbers, descriptions, bates stamps, and Stipulated/Date Offered/Objection/Date Admitted columns, and the court encourages pretrial stipulation to exhibit admission.

Exhibits must be accompanied by an exhibit list (EDCR 2.69(a)(2)). The list must be in a table format with the exhibit number or letter; a description of the exhibit, and bates stamp numbers should accompany each set of exhibits; and columns labeled "Stipulated," "Date Offered," "Objection," and "Date Admitted." The parties must indicate on the list exhibits stipulated as admitted. The court encourages the parties to agree on admission of exhibits prior to trial when possible, as this streamlines the process for the court clerk and the jury.

CRITICALCivil cases

Applies to

Electronic exhibits

Counsel must provide the equipment needed to view electronic exhibits during trial and jury deliberation, and laptops must be clear of all extraneous files.

If counsel admits any exhibits that require electronic equipment for viewing (CDs, DVDs, etc.), counsel must provide the necessary equipment for viewing during the trial and during jury deliberation. Laptops must be clear of all extraneous files.

CRITICALCivil cases

Applies to

Jury notebooks

Please provide eleven juror notebooks one judicial day prior to trial.

Please provide eleven juror notebooks one judicial day prior to trial.

CRITICALCivil cases

Applies to

Motion in limine

Must include

certificate of conference

The court will not hear untimely motions in limine or motions in limine lacking a complete EDCR 2.47(b) affidavit.

The court will not hear untimely motions or motions without a complete EDCR 2.47(b) affidavit.

CRITICALCivil cases

Applies to

Amended exhibit

Counsel must provide three complete copies of any amended exhibit.

If an exhibit is changed, counsel must provide three complete copies of the amended exhibit.

CRITICALCivil cases

Applies to

Original deposition

Original depositions intended for use at trial must be submitted to the court clerk at calendar call per EDCR 2.69(5) unless the court directs other arrangements.

If counsel intends to use depositions during trial, the original depositions must be submitted to the court clerk at calendar call per EDCR 2.69(5), unless the court has instructed other arrangements for the submission date.

CRITICALCivil cases

Applies to

Exhibits

The court will not admit only part of an exhibit; a single page of a larger document must be submitted as a separately numbered exhibit.

The court will not admit only part of an exhibit. If counsel intends to admit a single page of a larger document, it should be submitted as a separately numbered exhibit.

CRITICALCivil cases

Applies to

Motion in limine

Must include

certificate of conference

The EDCR 2.47(b) affidavit must detail the conference (or why it was impossible), attempts to resolve, and what was resolved or unresolved with specific reasons.

EDCR 2.47(b) requires an affidavit detailing: (1) A personal or telephone conference occurred or an explanation why a conference impossible. Impossible means something more than being unable to reach opposing counsel the day the motions were due. Department 9 requires the 2.47 conference at least one week prior to the filing of motions in limine. (2) Attempts made to resolve the matter. (3) What was resolved, what was not resolved and the reasons counsel could not reach a resolution. The reasons why a matter was unable to resolve the issue should be stated with specificity. Indicating “counsel could not agree” fails to comply with the rule.

CRITICALCivil cases

Applies to

Jury laptop

Please have a clean laptop to go back with the jury if you intend for jurors to view videos.

Please have a clean laptop to go back with the jury if you intend for jurors to view videos.

CRITICALCivil cases

Applies to

Exhibits

For voluminous exhibits, counsel must provide the original exhibits to the court clerk plus a copy for the judge and a copy for the witness; the clerk's copy is the official record.

The court clerk will contact counsel to schedule a time to meet with counsel to mark the exhibits (only if they are voluminous). Counsel are to provide the original exhibits to the court clerk, along and a copy for the judge and a copy for the witness (but the court clerk's copy is the official record).

CRITICALCivil cases

Applies to

Deposition

The party offering a deposition must submit to the court a copy of the deposition with the offered portions highlighted per NRCP 32(c).

Pursuant to NRCP 32(c), the party offering the deposition must submit to the court a copy of the deposition with the portions being offered highlighted.

CRITICALCivil cases

Applies to

Exhibits

Exhibits that do not comply with the court's exhibit requirements will not be accepted by the court.

Exhibits that do not comply with these requirements will not be accepted by the court.

CRITICALCivil cases

Applies to

Deposition designations

Deposition designations must be provided and all objections to designations resolved before trial begins.

Deposition designations must be provided and all objections to designations resolved prior to the start of trial.

CRITICALCivil cases

Applies to

Injunction case

Parties must submit proposed findings of fact and conclusions of law in injunction cases in accordance with NRCP 52.

The court requires the submission of proposed findings of fact and conclusions of law in injunction cases, in accordance with NRCP 52.

CRITICALCivil cases

Applies to

Motion in limine

Must include

certificate of conference

The EDCR 2.47(b) affidavit must detail the conference (or why it was impossible), attempts to resolve, and what was or was not resolved with specificity; vague statements like 'counsel could not agree' fail to comply.

EDCR 2.47(b) requires an affidavit detailing: (1) A personal or telephone conference occurred or an explanation why a conference impossible. Impossible means something more than being unable to reach opposing counsel the day the motions were due. Department 9 requires the 2.47 conference at least one week prior to the filing of motions in limine. (2) Attempts made to resolve the matter. (3) What was resolved, what was not resolved and the reasons counsel could not reach a resolution. The reasons why a matter was unable to resolve the issue should be stated with specificity. Indicating "counsel could not agree" fails to comply with the rule.

CRITICALCivil cases

Applies to

Exhibit list

Exhibits must be accompanied by a table-format exhibit list with exhibit number/letter, description, bates stamp numbers, and columns for Stipulated, Date Offered, Objection, and Date Admitted, with stipulated exhibits indicated.

Exhibits must be accompanied by an exhibit list (EDCR 2.69(a)(2)). The list must be in a table format with the exhibit number or letter; a description of the exhibit, and bates stamp numbers should accompany each set of exhibits; and columns labeled "Stipulated," "Date Offered," "Objection," and "Date Admitted." The parties must indicate on the list exhibits stipulated as admitted.