Civil Practice Cheat Sheet, Cheat Sheet of Civil Law

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Action Time Limit Statute/Rule Serve Reply to Counterclaims Lawsuit Initiation 20 days after being served an Answer with Counterclaims unless a Rule 12 motion is served, then see NRCP 12(a)(4) NRCP 12(a)(2) Serve Answer to Cross-claims 20 days after being served an Answer with Cross-claims unless a Rule 12 motion is served, then see NRCP 12(a)(4) NRCP 12(a)(2) Bring in Third Party Defendant or Counter-Defendant No later than 10 days after serving original answer without leave of court; at any time after commencement of the action with leave of court NRCP 14(a-b) Supplement Pleading Put on Dismissal Calendar If Complaint not served or answered within 180 or no action for 6 months in EDCR 1.90(b)(2) proceeding open for 1 year Amend/Supplement/Substitute Pleadings or Party Amend pleading as matter of course At any time before a responsive pleading, or, if no responsive pleading is permit- | NRCP 15(a) ted, within 20 days after it was served Amend Pleading with leave of court or writ- | Nat later than 90 days before discovery cut-off date; granted if justice so NRCP 15(a); NRCP ten consent of parties Tequires” 16.1(0(6) Respond to Amended Pleading Within the time remaining for response to the original pleading or within 10 NRCP 15(a) days after service of the amended pleading, whichever period may be the longer Amend to Conform to Evidence At any time, even after judgment, under certain circumstances NRCP 15(b) Upon motion and reasonable notice upon such terms as are just for the purpose | NRCP 15(d) of setting forth additional facts that occurred after the date of original pleading Substitute Party due to death, incompetency, or transfer of interest Not later than 90 days after the event NRCP 25(a-c) Substitute DOE/ROE defendants When true name is discovered NRCP 10/a) Discovery May Serve Written Discovery (depositions, At any time after (1) the filing of a joint case conference report, or not sooner NRCP 26(a) ROGs, RFPs, RFAs, permission to enter land, than 10 days after a party has filed a separate case conference report, and (2) etc.) making NRCP 16.1(a)(1) initial disclosures Depositions-oral examination 15 days’ notice in writing before time set for deposition; 5 days’ notice to desig- | NRCP 30(b)(1&3) &(e) nate another method to record the deponent’s testimony; 30 days for deponent to review transcript once noticed it is available if requested review at deposition ROGs/RFPs/RFAs Respond within 30 days after service of ROGs/RFPs/RFAS NRCP 33(b)(3)/ NRCP 34(b)(2)(A)/ NRCP 36(a) ie Compulsory in every case, * Updated 3/21/17 36 Clark Gounty Bar Association - COMMUNIQUE — May 2017 Reem nrc nsne File motions to amend pleadings or add Not later than 90 days before the close of discovery unless by court order NRCP 16.1(c)(6) parties Initial Expert Disclosures No later than 90 days before discovery cut-off date in the absence ofextraordi- | NRCP 16.1(a)(2\(C)(i); nary circumstances NRCP 16.1(c)( Rebuttal Expert Disclosures No later than 30 days after opposing party's expert disclosure NRCP 16.1(a)(2)(C)(ii); NRCP 16.1(c)(7) Close of Discovery Asset in scheduling Order EDCR 1.90(b) File dispositive Motions No later than 30 days after discovery cut-off date NRCP 16.1(c)(8) File Motions In Limine 45 days prior to the date set for trial and must be heard not less than 14 days rior to trial EDCR 2.47 trial Object to Evidence in Pre-Trial Disclosure Within 14 days after pre-trial disclosures made NRCP 16.1(a)(3) File Motion/SAO to Extend Discovery Deadline _} Within 20 days before the discovery deadline EDCR 2.35 set forth in discovery order Pre-Trial Request Jury Trial Any time after the commencement of the action and not later than the time of || NRCP 38(b) the entry af the order first setting the case for trial File Motion for Summary Judgment Anytime after the expiration of 20 days from the commencement of the action; | NRCP 56(a&c) shall be served at least 10 days before the time fixed for the hearing Pretrial Motions Should be heard and decided no later than 15 days before the date scheduled for | EDCR 1.90(a)(3) allowed by the court. Make/Accept Offer of Judgment Any time more than 10 days before trial; acceptance of an offer of mustbe made | NRCP 68(a) within 10 days after service or the offer shall be deemed rejected Post-Trial File Renewed Motion for Judgements as No later than 10 days after service of written notice of entry of judgment NRCP 50(b)/ Matter of Law/ Motion for New Trial / Motion NRCP 59(b)/ to Amend Findings and Judgment Accordingly NRCP 52(b)/ / Motion to Alter or Amend Judgment NRCP 59(2) File Motion for Attorney's Fees No later than 20 days after notice of entry of judgment is served NRCP 54(d)(2)(B) File Notice of Appeal No later than 30 days after service of written notice of the order/judgment NRAP 4 Relief from Judgment (Mistake, Inadvertence, | Within a reasonable time, and for reasons (1), (2), and (3) not more than 6 NRCP 60(b) Excusable Neglect, Newly discovery Evidence, | months after the proceeding was taken or the date that written notice of entry Fraud, etc.) of the judgment or order was served Motions File Joinder to Motion Within 5 days after service af motion EDCR 2.20(d) File Opposition or Notice of Non-Opposition “| Within 10 days after service of motion EDCR 2.20(e) File Reply to Opposition No later than 5 days before hearing on Motion unless court approval first EDCR 2.20(h) obtained File Motion for Reconsideration Within 10 days after service of written notice of the order/judgment EDCR 2.24(b) Preparation of Order Within 10 days after counsel is notified of the ruling, unless additional time is EDCR7.21 = Compulsory in every case, * Updated 3/21/17 *Please consult NRCP 6 and EDCR 1.14 & 8.06 for the correct computation of the above time limits, May 2017 - COMMUNIQUE = Clark County Bar Association