The Nevada discovery plan
Nevada's signature is NRCP 16.1: a mandatory early case conference, initial disclosures WITHOUT a request, and a case conference report that goes on file — the machine starts on its own. The stations and the statewide caps, from the loaded rules:
The early case conference — held within 30 days of the first answer
All parties who have filed a pleading must participate; the conference must be held within 30 days after service of an answer by the first answering defendant. Nothing is requested yet — the machine starts on its own.
NRCP 16.1(b)(2)(A)
Initial disclosures arrive WITHOUT a request
Witnesses, documents, damages computations, and insurance agreements are disclosed at or within 14 days after the conference — no interrogatory required. A party appearing later discloses within 30 days after its answer or Rule 12 motion.
NRCP 16.1(a)(1), (a)(1)(D)
The case conference report goes ON FILE
Within 30 days after each case conference the parties file a joint (or individual) report — the discovery plan becomes a court record, and the scheduling order issues from it within 60 days.
NRCP 16.1(c)(1)(A); NRCP 16(b)(2)
Supplementation is a continuing duty
A party must supplement or correct disclosures and discovery responses in a timely manner when it learns the prior response is materially incomplete or incorrect.
NRCP 26(e)
The statewide limits
No more than 40 written interrogatories, including all discrete subparts; leave for more must be consistent with Rule 26(b)(1)-(2).
Leave required when a deposition would push a side (plaintiffs, defendants, or third-party defendants) past 10 under Rules 30/31 — custodian-of-records depositions excepted.
A matter is ADMITTED unless answered or objected to within 30 days after service — silence admits.
Answers and objections within 30 days after service (Rule 29 stipulations or court order may vary).
Scope · work product · the statutory privilege
Parties may obtain discovery regarding any nonprivileged matter that is relevant to any party's claims or defenses and proportional to the needs of the case — the restyled proportionality standard, with the rule's own factor list.
Documents and tangible things prepared in anticipation of litigation or for trial are ordinarily not discoverable absent substantial need and undue hardship; mental impressions, conclusions, opinions, and legal theories get the higher protection.
Nevada's privileges are STATUTORY: the lawyer-client privilege is NRS 49.095 (confidential communications between client and lawyer and their representatives), inside chapter 49's full privilege code — cite the statute, not a common-law formula.
NRCP 26(b)(1) · NRCP 26(b)(3) · NRS 49.095
How the sibling states differ — honestly
vs Florida
Florida's initial disclosures run 60 days from service of the complaint; Nevada's ride the 16.1 early case conference — held within 30 days of the first answer, disclosures within 14 days after. Different trigger, same no-request principle.
vs Texas
No Levels here. Texas scales discovery by Level 1/2/3 plans; Nevada runs one proportionality standard (26(b)(1)) plus flat statewide caps — 40 interrogatories, 10 depositions per side.
vs North Carolina
North Carolina kept the classic scope and waits for requests; Nevada's restyled rules carry the federal-style proportionality scope AND disclosures that arrive without a request.
vs Arizona
No tiers. Arizona assigns cases to three tiers with per-tier caps; Nevada's caps are flat, and the mandatory-arbitration ladder (not a discovery tier) is what scales small cases down.
vs Washington
Washington has NO statewide caps and NO statewide initial disclosures (its counties carry that discipline); Nevada has both — the 40/10 caps and the 16.1 disclosure regime are statewide law.
Read the rules verbatim: NRCP 16.1 · NRCP 26 · NRCP 33 · NRCP 36 · NRCP 37
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