To say the Eighth Judicial District Court has a lot of cases is an understatement. Judges in the Eighth have a heavy docket. So, at a recent Civil Bench–Bar meeting some judges put forth some secrets to help attorneys generate stellar filings to give judges the tools they need to rule expeditiously on cases.
- Communicate: If counsel is going to miss a scheduled hearing, notify the department.
Conduct meaningful meet and confers with opposing counsel to make things go quicker and smoother in court. Draft what you want the court to order as part of meet and confer.
- Number or Bates stamp case exhibits. It sounds like a no-brainer when a case has thousands of exhibits, but many filings come in that are not numbered making it time-consuming and difficult for the judges who have to fish through to match up exhibits. For cases with more than——exhibits have an index of the numbered and tabbed exhibits.
- Draft your own order when you file a Motion. A draft Order is a wonderful outline of the points you want to make and it will help to focus issues.
- Brush up on the Supreme Court of Nevada rules on Zoom hearings and know that appearances do have to be audio/visual unless special permission has been granted for audio only.
- Review judicial webpages at clarkcountycourts.us for department preferences before calling departments with questions. Each department has a judicial webpage with preferences listed.
- Don’t file Motions in Limine to “follow the law.” Such motions are frustrating.
- When Motions in Limine are broad, speak with opposing counsel to determine what is agreed on that can be eliminated. Also, see point #3 above to help focus your motion.
- Do not use the argument with one judge that another judge does it a “different way.” It does not work.
- Per NRS chapter 18, costs must be substantiated with a proper verified memorandum of costs in the action or proceeding. Receipts for costs sought must be provided.
- Motions for Summary Judgment: During discovery focus on locking down all the evidence regarding potential questions of fact that could be the basis for denying motion. A failure to preclude questions of fact during discovery will weaken your motion for summary judgment.
Civil Bench-Bar meetings are held on the second Tuesday of every month with some exceptions (including this November). The next meeting is December 10 at noon.