Eighth Judicial District Court, Clark County Document Filing Requirements

WARNINGCivil cases

Applies to

Jury notebook

Counsel must meet and discuss Jury Notebook items (EDCR 2.67) and at the final pre-trial conference be prepared to stipulate or make specific objections to included items (EDCR 2.68).

In accordance with EDCR 2.67, counsel shall meet, review, and discuss items to be included in the Jury Notebook. Pursuant to EDCR 2.68, at the final Pre-Trial Conference, counsel shall be prepared to stipulate or make specific objections to items to be included in the Jury Notebook.

WARNING

Applies to

Pretrial memorandum

The Pre-trial Memorandum should identify prior rulings on motions in limine and partial summary judgment, anticipated legal issues, and summarize opinion testimony to be offered along with objections to it.

Counsel should include in the Memorandum an identification of orders on all motions in limine or motions for partial summary judgement previously made, a summary of any anticipated legal issues remaining, a brief summary of the opinions to be offered by any witness to be called to offer opinion testimony as well as any objections to the opinion testimony.

WARNINGCivil cases

Applies to

Exhibit list

An exhibit list (numbered for plaintiff, lettered for defense) must be submitted with a short description of each exhibit and three columns: Date Offered, Objection, and Date Admitted.

Submit an Exhibit List, numbered for Plaintiffs and letterd for Defendants, containing a short description of each exhibit with three columns to the right entitled: Date Offered/ Objection/Date Admitted.

WARNING

Applies to

Motion to withdraw as counsel

Motions to Withdrawal as Counsel of Record should be in writing and comply with NRCrP 3.

Motions to Withdrawal as Counsel of Record should be in writing and comply with NRCrP 3.

WARNING

Applies to

Attorney fees request

Attorney fee requests in default judgment matters must be made by motion.

All requests for attorney fees must be by motion.

WARNING

Applies to

Order

Electronically signed documents require email verification of the signer's agreement, included after the last page of the order rather than as a separate filing.

All documents requiring the signature of another person may be electronically signed without original signatures; however, the party submitting the document must obtain email verification of the other person’s agreement to sign electronically and submit the email with the filed documents. Please include the email after the last page of the order. The email should not be filed as a separate document.

WARNING

Applies to

Motion in limine

When filing motions in limine, please include the following format in the caption “Plaintiff’s Motion in Limine #1…..” “Defendant Clark’s Motion in Limine A…..”

When filing motions in limine, please include the following format in the caption “Plaintiff’s Motion in Limine #1…..” “Defendant Clark’s Motion in Limine A…..”

WARNING

Applies to

Minors compromise order

All orders should include language that upon reaching the age of 18 years that a copy of this order and driver's license in the name of the minor may be presented to the bank for release to the minor.

All orders should include language that upon reaching the age of 18 years that a copy of this order and driver's license in the name of the minor may be presented to the bank for release to the minor.

WARNING

Applies to

Minors compromise accounting

For minor's compromises, no yearly accounting is required—only a bank statement showing the account still exists and the amount in it.

The Court will not require a yearly accounting, just a bank statement showing the account is still in existence and the amount in the account.

WARNINGCivil cases

Applies to

Plaintiffs proposed jury instructions

Plaintiff's objected-to proposed jury instructions must bear the specified captions and be numbered P-1, P-2, etc. in the lower right-hand corner.

Any jury instructions proposed by Plaintiff, which are not stipulated to by the other party(ies), should be captioned "Plaintiff's Proposed Special Jury Instructions - Objected to by Defendant (Cited)" and "Plaintiff's Proposed Special Jury Instructions - Objected to by Defendant (Uncited)" and shall be numbered in the lower right-hand corner, in numerical order, as P-1, P-2 etc. (An example is attached.)

WARNINGCivil cases

Applies to

Jury deliberation laptop

In a jury trial, the proffering party must provide a laptop and monitor with only an operating system, associated programs, and Adobe for viewing admitted exhibits (no internet) for jury deliberations.

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.

WARNINGCivil cases

Applies to

Electronic exhibit

The admitted electronic exhibit must exactly match the proposed version; any change requires resubmission as a supplemental 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.

WARNINGCivil cases

Applies to

Electronic exhibits

Electronic exhibits cannot be admitted in portions; a selected group of pages 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 only a select few into evidence, please designate that group as a separate exhibit.

WARNINGCivil cases

Applies to

Exhibit label

The Clerk's exhibit binders must be pre-marked with labels showing Joint/Plaintiff/Defendant status, exhibit number/letter, and case number, placed in prescribed locations.

The clerk's exhibit binder(s) must be pre-marked with a proposed exhibit label indicating if the exhibit is Joint/Plaintiff/Defendant, the exhibit number/letter and case number #. The label must be adhered to either on the first page of a single page exhibit, or on the lower right back-side of the last page of a multiple page document, or on the back side of any exhibit to avoid covering up any pertinent information or part of a photograph.

WARNINGCivil cases

Applies to

Electronic storage devices

Prior to the clerk admitting the electronic storage devices, the clerk will perform a virus check on each device in the presence of counsel or their designee.

Prior to the clerk admitting the electronic storage devices, the clerk will perform a virus check on each device in the presence of counsel or their designee.

WARNINGCivil cases

Applies to

Defendants proposed jury instructions

Defendant's objected-to proposed jury instructions must bear the specified captions and be numbered D-1, D-2, etc. in the lower right-hand corner.

Any jury instructions proposed by Defendant, which are not stipulated to, shall be captioned, "Defendant's Proposed Special Jury Instructions Objected to by Plaintiff (Cited)" and "Defendant's Proposed Special Jury Instructions Objected to by Plaintiff (Uncited)" and shall be numbered in the lower right-hand corner, in numerical order, as D-1, D-2 etc. (An example is attached.)

WARNINGCivil cases

Applies to

Audiovisual objection notice

If an audiovisual appearance is objected to, the parties must notify the Court and schedule time to have the objection heard.

If the Audiovisual appearance is objected to, the parties must notify the Court and schedule time to have the objection heard.

WARNINGCivil cases

Applies to

Electronic exhibits

The offering party must give the clerk two identical sets of proposed electronic exhibits on separate devices, plus an additional blank device in a jury trial.

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 12).

WARNINGCivil cases

Applies to

Electronic exhibit

Electronic exhibits cannot be admitted in portions; desired portions of lengthy exhibits 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 only a select few into evidence, please designate that group as a separate exhibit.

WARNINGCivil cases

Applies to

Electronic exhibit list

The Exhibit List must reflect electronic exhibit file names exactly as labeled on the storage drives.

**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". The Exhibit List should reflect the exhibits exactly as they are labeled in the storage drives (ex. 537.pdf, 538.pdf, 539.pdf)**

WARNINGCivil cases

Applies to

Enlarged exhibit

Large blow-ups are demonstratives not marked as exhibits; a larger version may go to the jury only if approved by the Court, marked separately, and admitted.

Large blow-ups of exhibits may be used as demonstrative exhibits. These are not marked as exhibits and usually do not go to the jury. However, if Counsel wants a larger version of an exhibit to go to the jury, it must be approved by the Court, marked separately and admitted.

WARNINGCivil cases

Applies to

Electronic exhibit list

The electronic exhibit list must include specified tabular information for each proposed electronic exhibit, with traditional physical evidence listed separately.

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):

WARNINGCivil cases

Applies to

Deposition objection excerpts

Objections to deposition designations/counter-designations must be provided to the Court at or before the Calendar Call with excerpts showing on each page what is objected to, by whom, and on what basis.

If there are any objections to the designations or counter-designations, then the parties need to provide the Court (at or before the Calendar Call) with copies of the deposition excerpts which show on each page which excerpts are objected to, who is objecting, and the basis.

WARNING

Applies to

Competing proposed orders submission

When counsel are unable to agree on the language of an order, counsel should submit their proposed order to Department 15, with a written statement outlining the differences in the competing orders. If a redline copy is available, counsel may also submit that document. No additional argument should be provided. Rather, the statement should be limited to identifying the language believed to be incorrect, and directing the Court to the alternate language believed to be incorrect, and directing the Court to the alternate language proposed.

When counsel are unable to agree on the language of an order, counsel should submit their proposed order to Department 15, with a written statement outlining the differences in the competing orders. If a redline copy is available, counsel may also submit that document. No additional argument should be provided. Rather, the statement should be limited to identifying the language believed to be incorrect, and directing the Court to the alternate language believed to be incorrect, and directing the Court to the alternate language proposed.

WARNINGCivil cases

Applies to

Demonstrative exhibits

Large demonstrative versions are not marked as exhibits; to admit one, a standard-sized copy must be submitted to be marked, offered, and admitted.

DEMONSTRATIVES - Largerversions of Exhibits may be used as demonstrative exhibits. These are not marked as exhibits. lf parties wish for the larger exhibits to be admitted, they must submit a standard sized copy to be marked, offered, and admitted.

WARNINGCivil cases

Applies to

Original certified depositions

Depositions do not go to the jury, are not marked, nor admitted as Exhibits; however, original depositions which counsel intend to use for impeachment purposes are "published and filed" during trial proceedings and they should be original certified and sealed depositions, unless otherwise agreed to. Submit these to the Court Clerk along with your exhibits.

Depositions do not go to the jury, are not marked, nor admitted as Exhibits; however, original depositions which counsel intend to use for impeachment purposes are "published and filed" during trial proceedings and they should be original certified and sealed depositions, unless otherwise agreed to. Submit these to the Court Clerk along with your exhibits.

WARNINGCivil cases

Applies to

Depositions

Original certified and sealed depositions intended for impeachment must be submitted to the Court Clerk along with the exhibits, unless otherwise agreed.

Depositions do not go to the jury, are not marked, nor admitted as Exhibits; however, original depositions which counsel intend to use for impeachment purposes are "published and filed" during trial proceedings and they should be original certified and sealed depositions, unless otherwise agreed to. Submit these to the Court Clerk along with your exh ibits.

WARNING

Applies to

Pretrial memorandum

Counsel should include in the memorandum an identification of orders on all motions in limine or motions for summary judgment previously made, a summary of any anticipated legal issues remaining, a brief summary of the opinions to be offered by any witnesses to be called to offer opinion testimony, as well as any objections to the opinion testimony.

Counsel should include in the memorandum an identification of orders on all motions in limine or motions for summary judgment previously made, a summary of any anticipated legal issues remaining, a brief summary of the opinions to be offered by any witnesses to be called to offer opinion testimony, as well as any objections to the opinion testimony.

WARNING

Applies to

Submission to court

Submissions to the Court containing substantive argument on the merits of a contested issue are improper ex parte communications and will generally be disregarded, even if copied to opposing counsel.

Submissions to the Court containing substantive argument on the merits of a contested issue are disfavored, viewed as improper ex parte communication, even if copied to opposing counsel, and will, generally, be disregarded.

WARNINGCivil 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 defenses.

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.

WARNING

Applies to

Default judgment

Must include

proposed order

Counsel should provide all supporting exhibits with the proposed order at least one judicial day before a default judgment prove-up hearing.

The Court requests that counsel provide to the Court, at least one (1) judicial day prior to the default judgment prove-up hearing, all supporting exhibits with the proposed order.

WARNING

Applies to

Contested order submission

A contested order may be addressed by submitting an explanatory letter to chambers, copying all parties, with a draft competing order.

Contested orders may also be resolved by submission to chambers of an explanatory letter, copied on all parties, with a draft of a competing order.

WARNING

Applies to

Deposition

Depositions do not go to the jury, are not marked, nor admitted as exhibits; however, original depositions which counsel intend to use for impeachment purposes are "published" during trial proceedings and should be lodged with the Court Clerk prior to trial.

Depositions do not go to the jury, are not marked, nor admitted as exhibits; however, original depositions which counsel intend to use for impeachment purposes are "published" during trial proceedings and should be lodged with the Court Clerk prior to trial.

WARNING

Applies to

Proposed order

Prevailing counsel must generally submit a drafted proposed order to opposing counsel for review before submission to the court.

Department N generally requires prevailing counsel to submit a drafted Order to opposing counsel for review.

WARNINGCivil cases

Applies to

Jury notebooks

The court highly encourages jury notebooks in document-intensive cases, with counsel stipulating to all contents and including witness photos and frequently referenced documents.

Even with the use of audio-visual equipment, the court highly encourages the use of jury notebooks in document-intensive cases. Counsel should stipulate to all the contents of the notebooks. Jury notebooks generally should include photos of witnesses and copies of documents that will be referred to frequently in trial.

WARNINGCivil cases

Applies to

Trial memorandum

Trial memoranda must discuss the issues in the case and the party's position, and must not ask the Court to rule on issues or serve as a vehicle for late motions in limine.

The document should discuss issues you see in the case and your position. This should not be a document asking the Court to rule on issues or a second chance at filing late motions in limine.

WARNINGCivil cases

Applies to

Deposition

If a deposition will be read in lieu of live testimony, counsel must provide a reader who is not participating in the trial.

If depositions will be read in lieu of live testimony, counsel must provide a reader who is not participating in the trial.

WARNINGCivil cases

Parties should submit written briefs that thoroughly address all issues and arguments related to each motion and include all exhibits, affidavits, and evidence that they deem relevant to the disposition of the matter.

Parties should submit written briefs that thoroughly address all issues and arguments related to each motion and include all exhibits, affidavits, and evidence that they deem relevant to the disposition of the matter.

WARNINGCivil cases

Applies to

Trial memorandum

Trial memoranda should discuss the issues in the case and the party's position, and must not request rulings or serve as a second chance at filing late motions in limine.

The document should discuss issues you see in the case and your position. This should not be a document asking the court to rule on issues or a second chance at filing late motions in limine.

WARNINGCivil cases

Applies to

Exhibits

For voluminous exhibits the clerk schedules a marking session, and counsel must provide the original exhibits to the clerk plus a copy for the judge and a copy for the witness.

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 with a copy for the judge and a copy for the witness (but the court clerk's copy is the official record).

WARNINGCivil 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. 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. 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.

WARNINGCivil 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.

WARNINGCivil cases

Applies to

Proposed order

There should be no commentary accompanying the submissions, whether within the documents, in the form of a cover letter, or otherwise.

There should be no commentary accompanying the submissions, whether within the documents, in the form of a cover letter, or otherwise.

WARNINGCivil cases

Applies to

Electronic exhibits

Counsel must provide the equipment needed to view electronic exhibits at trial, 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. Laptops must be clear of all extraneous files.

WARNINGCivil cases

Applies to

Depositions

Counsel must provide a reader who is not participating in the trial when depositions will be read in lieu of live testimony.

If depositions will be read in lieu of live testimony, counsel must provide a reader who is not participating in the trial.

WARNINGCivil cases

Applies to

Exhibits

Partial exhibits will not be admitted; 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.

WARNINGCivil cases

Applies to

Exhibits

Each exhibit presented to the Clerk will be marked as a "Proposed" Exhibit and counsel are to refer to it as such until such time as it is allowed to be admitted.

Each exhibit presented to the Clerk will be marked as a "Proposed" Exhibit and counsel are to refer to it as such until such time as it is allowed to be admitted.

WARNING

Applies to

Proposed order

When counsel cannot agree on the language of an order from a hearing, both attorneys may submit proposed orders for Court Clerk review; the order complying with the minutes is processed, or the Judge will set a status check hearing to resolve the dispute.

District Court Department P, if counsel cannot agree on the language for an order from a hearing, Dept. P will permit both attorneys to submit proposed orders for the Court Clerk to review. If one of the orders complies with the minutes (unless there is a dispute with the minutes), that order is then processed. Alternatively, the Judge will place the matter on calendar for a status check and notice counsel to appear in order to resolve the dispute.

WARNINGCivil cases

Applies to

Exhibit list

An Exhibit List noting the exhibit number/letter, description, and bates stamp numbers should accompany each set of exhibits; however, do not identify the exhibits as offered or admitted as that will be performed at trial.

An Exhibit List noting the exhibit number/letter, description, and bates stamp numbers should accompany each set of exhibits; however, do not identify the exhibits as offered or admitted as that will be performed at trial.

WARNINGCivil cases

Applies to

Depositions

Depositions are not marked or admitted as exhibits; counsel intending to use one must request that it be 'published' during trial proceedings.

Depositions do not go to the jury, and are not marked or admitted as exhibits; however, if counsel intends on using a deposition, he/she must request to have the deposition "published" during the trial proceedings.