Respond & protect
The lawful response states and protection levers Nevada discovery provides — shown with their rules; choosing among them for YOUR requests is legal judgment. And the disclosure duty runs regardless: initial disclosures arrive without a request under the 16.1 regime.
The response clocks, honestly
Interrogatory answers and objections within 30 days after service; production responses on the same 30-day window; and NEVER sit on requests for admission — the matter is ADMITTED unless answered or objected to within 30 days. Silence admits.
NRCP 33(b)(2) · NRCP 34 · NRCP 36(a)(3)
Objections with specificity
Grounds are stated with specificity, and an objection to part of a request answers the rest. Boilerplate is a discipline problem the rules themselves reject.
NRCP 33 · NRCP 34
The signing certification
Signing of Disclosures, Discovery Requests, Responses, and Objections — every discovery paper is certified to the best of the signer's knowledge after reasonable inquiry. The certification is the floor under every response and every objection.
NRCP 26(g)
The protective order
The court's good-cause lever against annoyance, embarrassment, oppression, or undue burden or expense — scope fights, sequencing, confidentiality terms, and who may attend all route through it.
NRCP 26(c)
Work product + the statutory privilege
Trial-preparation materials carry the substantial-need/undue-hardship shield with mental impressions protected — and Nevada's PRIVILEGES ARE STATUTORY: the lawyer-client privilege is NRS 49.095, inside chapter 49's privilege code. Cite the statute, not a common-law formula.
NRCP 26(b)(3) · NRS 49.095
THE CONFERRAL COMES FIRST
A motion to compel must certify that the movant in good faith conferred or attempted to confer — and in the Eighth Judicial District, EDCR 2.34 adds its own discovery-dispute conference machinery. Under DCR 5, the local book wins on procedure.
NRCP 37(a)(1) · EDCR 2.34
The subpoena lane + the interstate door
Rule 45 subpoenas command attendance, production, or inspection — and the issuing court MUST quash or modify on the rule's protective grounds. Out-of-state discovery INTO Nevada rides the UIDDA (NRS 53.100-53.200): submit the foreign subpoena to the clerk, who promptly issues the Nevada subpoena.
NRCP 45 · NRS 53.170 · NRS 49.095
The whole device board lives on the discovery plan →
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