In December, 2011 my firm hosted a CLE presented by DC Bulla entitled Discovery Matters. As usual, I post the written materials here for everyone to see in hopes it helps us all avoid common problems. Topics covered include 1) appropriate NRCP 16.1 affirmative disclosures; 2) the importance of timely case conference reports; 3) appropriate stipulations and motions to extend discovery; 4) timely NRCP 16.1(a)(3) pretrial disclosures and objections; 5) proper NRCP 34 inspections; and a perpetual favorite on this blog, 6) the proper location for a deposition.
This particular hand-out is quite detailed and addresses many of the most common discovery questions. Please use it for all its worth to avoid Friday morning hearings. Many of the tips are similar to those repeated in DC Bulla’s March, 2009 NV Lawyer article. DC Ayres wrote a similar article in the same issue.