The Discovery War Room
The Mirror runs BOTH directions — their requests through Nevada's levers, and your own drafts through the same detectors before they leave. Keyed authority: NRCP 26(b)(1) scope · the 40/10 caps · the 16.1 disclosure regime · the conferral gate.
Does the request clear the scope?
NRCP 26(b)(1)Nonprivileged, relevant to a claim or defense, and PROPORTIONAL to the needs of the case — Nevada carries the restyled standard with the rule's own factor list. Run their requests and yours through it.
Does it blow a statewide cap?
NRCP 33(a)(1) · NRCP 30(a)(2)40 interrogatories including all discrete subparts; 10 depositions per side before leave. The caps are statewide law — count before you serve, and count what they serve.
Is the response evasive?
NRCP 37(a)(4)An evasive or incomplete disclosure, answer, or response is treated as a FAILURE to disclose, answer, or respond — the compel lane opens.
Has the conferral happened?
NRCP 37(a)(1) · EDCR 2.34The compel motion certifies a good-faith conferral or attempt. The Mirror flags motion-ready disputes as CONFERRAL-FIRST — always — and in Clark County the EDCR 2.34 machinery is the local door.
Does the signature hold?
NRCP 26(g)Every disclosure, request, response, and objection is signed — and certified after reasonable inquiry. The certification is real; check theirs and yours.
Did the disclosure duty already answer it?
NRCP 16.1(a)Witnesses, documents, damages computations, and insurance arrive WITHOUT a request in Nevada — a fight over what 16.1 already required is a fight the Mirror flags first.
The full device board: the discovery plan → · The governors: The Escalation Zone →
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