Civil Discovery

Discovery Commissioner:
Erin Lee Truman
Adam Ganz

The Discovery Commissioner is charged to resolve any problems that arise from District Court pre-trial disputes involving discovery in civil cases.  The Commissioner is appointed by and responsible to the full complement of District Court Judges.

At the direction of the Commissioner, the discovery staff processes between 2,500 and 3,000 cases per year and is responsible for regulating the orderly exchange of information between the parties.   The office sets guidelines for pre-trial case preparation and readiness based upon the needs of the party, as determined by the Commissioner.  The Discovery Office notifies each Judge when cases should be ready for trial setting, thereby allowing the Court to keep track of the progress of each case through the system.

Commissioner Truman and Commissioner Ganz split civil ADR and Discovery duties by department as follows:

Commissioner Truman
Departments 1, 2, 3, 4, 5, 6, 7, 8, 9, 12, 14, 19, 21, 23, 24, 26, 27, and 32.

Commissioner Ganz
Departments 10, 11, 13, 15, 16, 17, 18, 20, 22, 25, 28, 29, 30, and 31.

These assignments went into effect on Monday, March 15, 2021.

Department Information

Location:

Phoenix Building 10th Floor
330 S. Third St., 10th Floor
Las Vegas, NV 89101

Discovery Hearing Room:
Regional Justice Center
200 Lewis Ave, Las Vegas NV. 89155
Hearing Room: 5308 on the 5th Floor

Location Hours:
Mon – Fri: 8:00AM – 5:00PM
Lunch: Noon – 1:00PM

Contact:
Phone Number: 671-4486
Department Email: DiscoveryInbox@clarkcountycourts.us

Discovery Forms & Information Packets

The following forms are intended to be used as samples only.  You can print them or save them as a template for your own individual documents.  To download form samples, click on the appropriate document title.

  • You are alerted to multi-paged forms in the index.
  • Please use care to download and print all pages.
  • Missing pages may render your document unacceptable to the courts.
  • To access our on-line forms click the appropriate title.
Title
Download
Download
Administrative Order 22-08 Regarding Deposition Behavior
Model declaration in support of request for fees and costs
Model meet and confer declaration
Want to Stay Out of Trouble in Discovery? Read This  
Discovery Zoom Hearing Information
Discovery Conference Procedure  
Discovery Commissioner's Report and Recommendations Form
Report and Recommendations Regarding Attorney's Fees and Costs
Report and Recommendations Regarding Proportionality
Notice of Early Case Conference Form  
Order Shortening Time Form
Eighth Judicial District Court Rule (EDCR) 2.34  
Civil Subpoena (Duces Tecum)  
Civil Subpoena  
Deposition Subpoena (Duces Tecum)  
Deposition Subpoena  
Subpoena Duces Tecum for Business Records  
Transcript CD Form  
List of Discovery Motions  

Frequently Asked Questions (FAQs)

The Discovery Office:

  • All Discovery documents need to be submitted to the Discovery e-mail: DiscoveryInbox@ClarkCountyCourts.us.
    • Documents submitted to Discovery:
      • Motions on Order Shortening Time
      • Discovery Commissioner’s Report and Recommendations
      • Stipulation and Orders (Discovery Extensions must be submitted to the District Court Judge)
      • Courtesy Copies of Withdrawals
      • Pleadings filed the day before a hearing is scheduled
      • In Camera Documents
      • Letters and Correspondence
  • The Discovery Commissioner’s Calendar/minutes are posted in Odyssey;
  • The Discovery office is unable to give any legal advice pursuant to N.R.S. 7.285. Discovery can only answer procedural questions.

Telephone Conferences or Depo calls with the Discovery Commissioner:

  • The Commissioner holds conference calls for Report and Recommendations disputes and if issues arise during a deposition and counsel cannot move forward without assistance.
  • The case must be exempt from Arbitration and cannot be in the Short trial Program.
  • All active parties to the case must be represented and must agree to speak to the Commissioner.

Discovery Commissioner’s Report and Recommendations:

  • A proper report must be timely submitted within 14 days of the hearing.
  • All active counsel and/or parties must approve as to form and content unless otherwise stated by the Discovery Commissioner.
  • If counsel will not sign or does not approve the form and content, submitting counsel must attach a cover letter addressed to the Discovery Commissioner with details about the situation. The letter must be copied on all active parties. Counsel that does not approve as form and content will need to prepare a red line version of the report and recommendations and submit as soon as possible. The red line version must identify anything added, deleted or changed.
  • Once the Discovery Commissioner has signed the Report and Recommendations the document will be filed – page 1 through the notice page. All parties on e-service will receive a copy of the e-filed report. The notice page will indicate when the objection time has started and when it will expire. Discovery will forward the Report and Recommendations Order to the Department for review and consideration. Once the objection time has expired the Judge will execute the order and e-file. If counsel has filed an objection and have requested a hearing – that hearing will be scheduled by the Judge and set with the report and recommendations order when e-filed. Remember, the Report and Recommendations is not an Order until the Judge has signed and filed the Order page.
  • If counsel needs additional time to submit the Report and Recommendations please submit a letter explaining the situation and why counsel is requesting additional time. Make sure to copy all active counsel.

Motions:

  • A hearing must be held in order to get a ruling / recommendations from the Discovery Commissioner.
  • Motions submitted on an Order Shortening Time are typically reviewed / set within a day.
  • The Order Shortening Time must contain an Affidavit or Declaration of moving counsel pursuant to EDCR 2.34(d). This rule specifically requires your affidavit to contain reference to either a personal or telephone conference between counsel (or with a proper person) with an attempt to resolve the matter. Letters/Faxes/E-mails to the other side are not sufficient. (Who did counsel speak to? When? What was discussed amongst counsel? Why was counsel unable to resolve?)
  • Affidavit must support the need for the Order Shortening Time (When do you need the motion heard by and why).
  • The Order Shortening Time must comply with Rule EDCR 7.23. Counsel must sign the Order Shortening Time.
  • If Discovery sets the Order Shortening Time, counsel will receive the motion back signed, e-filed and e-served.
  • Motions being set in the regular course (30 day or more) must be e-filed.
    • In order to get a motion set before the Discovery Commissioner the front page of the motion must contain:

HEARING REQUESTED

DISCOVERY COMMISSIONER

  • Please Note: If counsel fails to state Discovery Commissioner the hearing will automatically get set before the Judge.
  • E-filed Motions are auto accepted and will receive a Notice of Hearing set by Master Calendar.
  • As of March 1, 2019, Discovery no longer handles Case Management and will not set or hear motions to extend discovery deadline dates.

Hearings – Required Telephonic/Video Appearances

  • Discovery is conducting all hearing utilizing Zoom. This is a free conferencing system set up by the Discovery Office. The Zoom e-mail will be sent to everyone set up for e-service a couple of days before each hearing. Zoom has both Video and Audio only options. https://zoom.us/

In Camera Submission:

  • Start with the unredacted documents:
    • bate stamp the documents
    • make a copy
    • redact the copy
  • Please submit the privilege log, redacted and unredacted documents to the DiscoveryInbox. File sharing programs can be used if necessary.

Transcripts/Audio CD:

    • The Discovery Court Recorder is Francesca Haak
    • To request a Transcript or order a CD please fill out the Transcript Request form and E-mail it to HaakF@clarkcountycourts.us or call 671-4642
    • Receipts, Checks and CDs are to be picked up in the RJC 5th Floor – Room 5305. Please knock on the door.

For subpoenas:

  • Please visit the Clerk of the Court Civil Forms Library – Foreign Deposition Packet.