Judge Joe Hardy
Individual Rules, Standing Orders & Policies
- Rules last changed:
Limits & Logistics
Courtesy Copies
Affidavit, Exhibits
- Hand Delivery • At Least Five Judicial Days Before Hearing
All Motions
- Hand Delivery • At Least Five Judicial Days Before Hearing
Brief
Default Judgment Application
- Upon Filing
Communication
Chambers
Phone
Chambers
Phone
Fax
Chambers
Clerk
Document Format Requirements47 rules
Parties can chose to use either paper or electronic exhibits. Parties must notify the court of their format choice at the trial readiness pre-trial conference. If the exhibits will take up more than three 3-inch binders, the court strongly encourages using electronic exhibits. All exhibits must comply with EDCR 2.27.
When submitting exhibits that will take up more than three (3) 3-inch binders, please submit electronic exhibits. Counsel must seek permission to use electronic exhibits as the Courtroom Clerk must assign each party a designated set number of exhibits to use.
- Exhibits
Formatting
- •Electronic exhibits must be submitted when exhibits exceed three 3-inch binders
The proposed electronic exhibits shall be submitted in portable document format (.PDF)
- File type
- Proposed electronic exhibits
No letters will be used as exhibit numbers for identifying proposed electronic exhibits.
- Proposed electronic exhibits
Formatting
- •No letters may be used as exhibit numbers for proposed electronic exhibits
The electronic storage device must have space available for additional storage of electronic data in at least an amount equal to the storage required for the proposed electronic exhibit(s). External hard drives must have a minimum read speed of 33 MBps and minimum write speed of 25 MBps.
Photographs must have at least a I inch border at the top of the page for the clerk to be able to affix the indicator documenting the admission of the photo. If the court deems the quality of the photograph is not of sufficient quality for demonstrative purposes, the photo shall be re-submitted in traditional format.
Each page within the proposed exhibit will be internally and sequentially numbered beginning with the trial exhibit number and the page number will be placed on each page of the proposed electronic exhibit in the lower right hand corner in the following format "l047-001".
Prior to trial each party will be assigned a range of exhibit numbers for use in naming exhibits. The file name for each proposed electronic exhibit shall be numerical, i.e. l047.pdf.
- Proposed electronic exhibits
Formatting
- •File names for proposed electronic exhibits must be numerical (e.g., 1047.pdf)
The font size shall be 12 and the font style to be used is Times New Roman.
- Font
- Times New Roman
- Font size
- 12 points
CD'S,DVD'S,USBTHUMBDRIVES,ETC.-lfyouareproposingaCD,theClerkneedstheactual CD,donotsubmita photocopy of the disk. DO NOT PLACE MORE THAN ONE exhibit on the CD, DVD, or Thumbdrive. lf you are planning to admit a portion of this, please separate the portion into another exhibit. Court cannot admit part of a CD.
- Media exhibits
Formatting
- •Submit the actual CD; do not submit a photocopy of the disk
Photographs must be identified separately with no more than one photo per sheet (letter-suffixed, e.g., 7-A, 7-B, 7-C), unless counsel stipulate to admitting all photos on a page.
- Photograph exhibits
Formatting
- •Each photograph must be identified separately
Court's wording
PHOTOS - Photographs MUST be identified separately. DO NoT PLACE MoRE THAN ONE PHoToGRAPH on one sheet of paper, as this causes problems if a single photo is admitted. For example, if Exhibit 7 consists of three photographs, label them 7-A,7-B and 7-C. You may place more than one photo on a page, if counsel are stipulating to admitting all of them.
Photographs must have at least a I inch border at the top of the page for the clerk to be able to affix the indicator documenting the admission of the photo. lf the court deems the quality of the photograph is not of sufficient quality for demonstrative purposes, the photo shall be re-submitted in traditional format.
The font size shall be 12 and the font style to be used is Times New Roman.
- Font
- Times New Roman
- Font size
- 12 points
The proposed electronic exhibits shall be submitted in portable document format (.PDF).
- File type
- Exhibits
Proposed electronic exhibits must be submitted on a single storage device (subject to integrity/volume exceptions) with free space at least equal to the exhibits' storage needs, and external hard drives must have at least 33 MBps read and 25 MBps write speeds.
Court's wording
The proposed electronic exhibits shall be submitted on a single electronic storage device, except when the integrity of the proposed electronic exhibit would be corrupted by being on a single electronic storage device or the volume of the proposed electronic exhibit(s) cannot practically be stored on a single electronic storage device. The electronic storage device must have space available for additional storage of electronic data in at least an amount equal to the storage required for the proposed electronic exhibit(s). External hard drives must have a minimum read speed of 33 MBps and minimum write speed of 25 MBps.
Electronic exhibits must use numerical file names from court-assigned exhibit number ranges, with each page sequentially numbered in the lower right corner in '1047-001' format and no letters used as exhibit numbers.
Court's wording
Prior to trial each party will be assigned a range of exhibit numbers for use in naming exhibits. The file name for each proposed electronic exhibit shall be numerical, i.e. 1047.pdf. Each page within the proposed exhibit will be internally and sequentially numbered beginning with the trial exhibit number and the page number will be placed on each page of the proposed electronic exhibit in the lower right hand corner in the following format "l047-001", No letters will be used as exhibit numbers for identifying proposed electronic exhibits.
Those should be emailed to the law clerk, with a carbon copy to opposing counsel, in Word format.
- File type
- Word
Counsel are to submit proposed jury instructions and forms of verdict in word format prior to the commencement of trial.
- File type
- Word
- Jury instructions
In any case, subjects of each motion in limine must be numbered and there can be no redundantly numbered motions in limine for any individual party.
On stipulations, signatures may be facsimile, electronic, or typographical, provided the submitting party has written permission from the signing party or attorney for such.
Jury instructions and proposed verdict forms must be accompanied by an electronic copy in Word format.
- File type
- Word
- Jury instructions
- Verdict forms
Court's wording
Each side shall provide the Court, at the Calendar Call, an agreed set ofjury instructions and proposed form of verdict along with any additional proposed jury instructions with an electronic copy in Word format.
If the parties chose to use paper exhibits, three (3) sets must be three-hole punched, placed in three ring binders along with the exhibit list.
- Binding
- Three-ring binder
- Exhibits
Formatting
- •Three (3) sets of paper exhibits required
Submit the actual CD (not a photocopy), place only one exhibit per CD/DVD/thumb drive with portions separated into separate exhibits, and provide a stipulated clean DVD player or laptop for jury viewing of digital media.
- Exhibits
Formatting
- •Submit the actual CD; photocopies of disks are not accepted
- •No more than one exhibit per CD, DVD, or thumb drive
Court's wording
CD'S, DVD'S, USB THUMBDRIVES, ETC. - lf you are proposing a CD, the Clerk needs the actual CD, do not submit a photocopy of the disk. DO NOT PLACE MORE THAN ONE exhibit on the CD, DVD, or Thumbdrive. lf you are planning to admit a portion of this, please separate the portion into another exhibit. Court cannot admit part of a CD. Also, if in a jury trial and digital media is given, Counsel must provide and stipulate to use a dvd player, or laptop that is "clean" to go back to the jury in order for them to view it.
ln order to keep each Exhibit intact, be certain they are bound in some fashion, either by staples, brads, etc. Additionally, exhibits must be single-sided.
- Binding
- Securely bound
- Exhibits
Formatting
- •Bind each exhibit intact using staples, brads, or similar
When submitting exhibits, please submit exhibits in a binder, separated by tabs. Label the tabs with numbers for Plaintiffs Exhibits and lettersfor Defendant's Exhibits. lf Joint Exhibits are submitted, label tabswith numbers. Bates Stamp the pages for ease in locating a specific page of an Exhibit and to ensure a clean record.
- Binding
- Tabbed binder
- Exhibits
Formatting
- •Label tabs with numbers for Plaintiff's exhibits and letters for Defendant's exhibits
- •Bates stamp the exhibit pages
Mark the first page of each exhibit as proposed using the required box format at the bottom right (uncolored, not covering content), unless there are fewer than twenty exhibits.
- Exhibits
Formatting
- •Any other exhibit labels on documents must not be colored
- •The proposed label must not cover information on the exhibit
- •Exemption: if exhibits are fewer than twenty, this step may be skipped
Court's wording
MARKING EXHIBITS - Mark the first page of each exhibit as proposed, format is shown below. lf there are other exhibit labels on your documents, please make sure they are not colored. Follow the format here, placing the box at the bottom right of the first page of each exhibit (like you would bate stamp). Please ensure the proposed label does not cover information on the exhibit. lf exhibits are less than twenty, you may skip this step.
The exhibit list must be emailed to the Courtroom Clerks in Word format using the court's exhibit list template.
Court's wording
EXHIBITLIST-Usetheexhibitlisttemplatesentandemail aWordversionoftheexhibitlisttotheCourtroomClerks when you submit your exhibits at revesf(oclarkcountvcourts.us and RabonD@clarkcountvcourts.us. lf you do not have it, please obtain it from the Courtroom Clerk.
Photographs must be identified separately with no more than one photo per sheet (e.g., 7-A, 7-B, 7-C), unless counsel stipulate to admitting all photos on a page.
- Exhibits
Formatting
- •No more than one photograph per sheet of paper
- •Label each photograph with sub-letters (e.g., 7-A, 7-B, 7-C)
Court's wording
PHOTOS - Photographs MUST be identified separately. DO NOT PLACE MORE THAN ONE PHOTOGRAPH on one sheet of paper, as this causes problems if a single photo is admitted. For example, if Exhibit 7 consists of three photographs, label them 7-A,7-B and 7-C. You may place more than one photo on a page, if counsel are stipulating to admitting all of them.
NUMBERING YOUR EXHIBITS - Label the tabs with numbers for Plaintiffs exhibits use numbers 1-1000 and Defendants exhibits use A-2, AA-ZZ, elc. Should Defendants exhibits exceed ZZZ, please reach out to the Courtroom Clerk for a range of exhibit numbers to use. For joint exhibits, use J1{1000 (Please notify the Courtroom Clerk/Dept. should there need to be any adjqslrnqql Label the first page of the exhibit with its exhibit number (i.e. Plaintiffs Proposed Exhibit 13).
- Exhibits
Formatting
- •Plaintiff's exhibit tabs use numbers 1-1000
Each side shall provide the Court, two (2) working days prior to the start of trial, a detailed, proposed Findings of Fact and Conclusions of Law with an electronic copy in Word format.
- File type
- Word
- Proposed findings conclusions
All exhibits must comply with EDCR 2.27.
If the parties chose to use electronic exhibits, they must comply with the court's protocol regarding electronic exhibits, which can be obtained upon request from the court's clerks.
If the parties chose to use paper exhibits, three (3) sets must be three-hole punched, placed in three ring binders along with the exhibit list.
- Binding
- Three-ring binder
- Paper exhibits
Formatting
- •Three sets required
- •Pages must be three-hole punched
Bates Stamp the pages for ease in locating a specific page of an Exhibit and to ensure a clean record.
- Exhibits
Formatting
- •Bates stamp the exhibit pages
ln order to keep each Exhibit intact, be certain they are bound in some fashion, either by staples, brads, etc. Additionally, exhibits must be single-sided
- Binding
- Securely bound
- Exhibits
NUMBERING YOUR EXHIBITS - Label the tabs with numbers for Plaintiffs exhibits use numbers 1-1000 and Defendants exhibits use A-2, AA-ZZ, etc. Should Defendants exhibits exceed ZZZ, please reach out to the Courtroom Clerk for a range of exhibit numbers to use. For joint exhibits, use i1-J1000 (Please notify the Courtroom Clerk/Dept. should there need to be any adjustments.) Label the first page of the exhibit with its exhibit number (i.e. Plaintiffs Proposed Exhibit 13).
- Exhibits
Formatting
- •Plaintiff's exhibits use numbers 1-1000
MARKING EXHIBITS - Mark the first page of each exhibit as proposed, format is shown below. lf there are other exhibit labels on your documents, please make sure they are not colored. Follow the format here, placing the box at the bottom right of the first page of each exhibit (like you would bate stamp). Please ensure the proposed label does not cover information on the exhibit. lf exhibits are less than twenty, you may skip this step.
- Exhibits
Formatting
- •Other exhibit labels on documents must not be colored
- •The proposed label must not cover information on the exhibit
- •Exemption: if exhibits are fewer than twenty, this step may be skipped
Also, if in a jury trial and digital media is given, Counsel must provide and stipulate to use a dvd player, or laptop that is "clean" to go back to the jury in order for them to view it.
When submitting exhibits, please submit exhibits in a binder, separated by tabs. Label the tabs with numbers for Plaintiff's Exhibits and letters for Defendant's Exhibits. lf Joint Exhibits are submitted, label tabs with numbers.
- Binding
- Tabbed binder
- Exhibits
Formatting
- •Joint exhibits tabs labeled with numbers
EXHIBITLIST-Usetheexhibitlisttemplatesentandemail aWordversionoftheexhibitlisttotheCourtroomClerks when you submityourexhibits at revesf@clarkcountvcourts.us and RabonD@clarkcountvcourts.us. lf you do not have it, please obtain it from the Courtroom Clerk.
- Exhibit list
Formatting
- •Use the exhibit list template provided by the Courtroom Clerk
Document Filing Requirements30 rules
Judge Hardy requires the submission of proposed findings of fact and conclusions of law in injunction cases, in accordance with NRCP 52.
Judge Hardy requires the submission of proposed findings of fact and conclusions of law in non-jury cases at least two working days prior to the commencement of trial. Those should be emailed to the law clerk, with a carbon copy to opposing counsel, in Word format.
Lead trial counsel must bring marked exhibits, typed exhibit lists, jury instructions in two groups, proposed voir dire questions, original depositions, and an equipment-needs list to the final pre-trial conference.
- Document
- Final pretrial conference submissions
Must include
- •Exhibit list
Court's wording
Lead trial counsel must comply with EDCR 2.67 and 2.68 and bring to the final pre-trial conference the following: All exhibits already marked by counsel for identification purposes; Typed exhibit lists with all stipulated exhibits marked as admitted; Jury instructions in 2 groups: the agreed upon uncontested set, and the contested sets; Proposed voir dire questions; and Original depositions. A list of equipment needed for trial not usually found in the courtroom. The court or its designee will inform counsel if such equipment is available in house or if counsel must procure the same and bring to the courtroom;
Confidentiality orders will be approved only if they include a detailed good cause statement and the Court's required reservation-of-rights language.
Court's wording
Judge Hardy will approve a confidentiality order for discovery purposes if the order includes a detailed statement demonstrating that good cause exists. All such orders must contain the following language or language substantially similar: "The Court retains the right to allow disclosure of any subject covered by this stipulation or to modify this stipulation at any time in the interest of justice."
Counsel are to submit proposed jury instructions and forms of verdict in word format prior to the commencement of trial. Counsel should meet and agree upon jury instructions and object to jury instructions proposed by the adverse parties.
As a reminder, all discovery motions must contain the certification required under EDCR 2.34.
Any motion in limine filed MUST be supported by an affidavit of counsel which contains ALL appropriate elements required by EDCR 2.47. The Court will not consider motions in limine which are not in compliance with EDCR 2.47.
Withdrawing counsel must comply with EDCR 7.40 and also provide the last known email address of the client in the motion.
Parties can chose to use either paper or electronic exhibits. Parties must notify the court of their format choice at the trial readiness pre-trial conference.
In accordance with EDCR 2.67,prior to the Calendar Call, counsel shall meet and discuss preinstructions to the jury, jury instructions and verdict forms. Each side shall provide the Court, at the Calendar Call, an agreed set ofjury instructions and proposed form of verdict along with any additional proposed jury instructions with an electronic copy in Word format.
Any demonstrative exhibits including exemplars anticipated to be used must be disclosed prior to the final pre-trial conference.
EXHIBITLIST-Usetheexhibitlisttemplatesentandemail aWordversionoftheexhibitlisttotheCourtroomClerks when you submit your exhibits at revesf(oclarkcountvcourts.us and RabonD@clarkcountvcourts.us. lf you do not have it, please obtain it from the Courtroom Clerk.
(please note that traditional "physical"evidence is not to be listed on the electronic exhibit list and should be submitted on a separate exhibit list)
The electronic exhibit list must be in tabular format and include, for each proposed electronic exhibit, the exhibit number, storage device identification, description, any discovery/pretrial designation, and spaces for clerk notations of the offer date, objections, and admission.
- Document
- Electronic exhibit list
Must include
- •Exhibit list
Court's wording
The list must include the following information in tabular format for each proposed electronic exhibit (please note that traditional "physical"evidence is not to be listed on the electronic exhibit list and should be submitted on a separate exhibit list): a. The exhibit number for the proposed electronic exhibit consistent with paragraph 4 above b. The identification of the electronic storage device on which the proposed exhibit is stored or a space for the clerk to make notation in the event the Exhibit was submitted in traditional form c. A description of the proposed electronic exhibit d, Any numeric or alphanumeric designation used on the proposed electronic exhibit during discovery or other pretrial proceedings f. A space for the clerk to make notation on the date the proposed electronic exhibits is offered g. A space for the clerk to make notation on objections made to the proposed electronic exhibits at the time it is offered for admission h. A space for the clerk to make notation on the admission of the proposed electronic exhibits
An exhibit list must be provided in both paper and Excel format; the Excel version must be named 'Exhibit List' and located only on the master electronic storage device.
- Document
- Electronic exhibit list
Must include
- •Exhibit list
Court's wording
An exhibit list in substantially the same form as the attachment hereto shall be provided in paper form as well as electronic in Excel format. The electronic (Excel) version of the exhibit list is to be named "Exhibit List" and is to be located on the master electronic storage device only.
In the event of a jury trial, an additional blank electronic storage device will be required to copy all of the admitted electronic exhibits onto for use by the jury (see paragraph 12).
The proposed electronic exhibit must exactly match the admitted exhibit; any change requires resubmission by counsel as a supplemental proposed exhibit with a new exhibit number.
Court's wording
The proposed electronic exhibit shall exactly match the admitted electronic exhibit. Any change between the proposed electronic exhibit and the admitted electronic exhibit will require the submission of the exhibit as a supplemental proposed electronic exhibit by offering counsel with a new proposed exhibit number in conformance with paragraph 4.
In jury trials, the proffering party must provide a laptop and monitor for deliberations containing only an operating system, associated programs, and an Adobe viewer for admitted exhibits with no internet or research capability, subject to inspection by Court I.T. staff and counsel.
Court's wording
Prior to the commencement of deliberations by a jury, if the trial is a jury trial, the party proffering the electronic exhibits will provide a laptop computer and additional monitor with only an operating system and associated programs, an adobe program to permit viewing of the admitted exhibits, and no internet or other research capability. The laptop will be subject to inspection by Court I.T. staff and counsel for compliance prior to it being provided to the deliberating jury.
The electronic exhibit list must include tabular entries for each proposed exhibit showing exhibit number, storage device identification, description, discovery designation, and clerk notation spaces for date offered, objections, and admission; physical evidence must be listed on a separate exhibit list.
Court's wording
The list must include the following information in tabular format for each proposed electronic exhibit (please note that traditional "physical"evidence is not to be listed on the electronic exhibit list and should be submitted on a separate exhibit list): a. The exhibit number for the proposed electronic exhibit consistent with paragraph 4 above b. The identification of the electronic storage device on which the proposed exhibit is stored or a space for the clerk to make notation in the event the Exhibit was submitted in traditional form c. A description of the proposed electronic exhibit d. Any numeric or alphanumeric designation used on the proposed electronic exhibit during discovery or other pretrial proceedings f. A space for the clerk to make notation on the date the proposed electronic exhibits is offered g. A space fbr the clerk to make notation on objections made to the proposed electronic exhibits at the time it is offered for admission h. A space forthe clerkto make notation on the admission of the proposed electronic exhibits
The exhibit list must be provided in both paper and Excel format, with the Excel version named 'Exhibit List' and located only on the master electronic storage device.
Court's wording
An exhibit list in substantially the same form as the attachment hereto shall be provided in paper form as well as electronic in Excel format. The electronic (Excel) version of the exhibit list is to be named "Exhibit List" and is to be located on the master electronic storage device only.
In jury trials, the proffering party must provide a laptop and monitor with only an operating system, an Adobe viewer for admitted exhibits, and no internet capability, subject to inspection before deliberations.
Court's wording
Prior to the commencement of deliberations by a jury, if the trial is a jury trial, the party proffering the electronic exhibits will provide a laptop computer and additional monitor with only an operating system and associated programs, an adobe program to permit viewing of tn. admitted exhibits, and no internet or other research capability. The laptop willbe subjectto inspection byCourt l.T. staff and counsel forcompliance priorto itbeing provided to the deliberating jury.
Proposed electronic exhibits must exactly match the admitted exhibits; any change requires resubmission as a supplemental proposed exhibit with a new exhibit number.
Court's wording
The proposed electronic exhibit shall exactly match the admitted electronic exhibit. Any change between the proposed electronic exhibit and the admitted electronic exhibit will require the submission of the exhibit as a supplemental proposed electronic exhibit by offering counselwith a new proposed exhibit number in conformance with paragraph 4.
The offering party must provide the clerk two identical sets of proposed electronic exhibits on separate storage devices, plus an additional blank device in jury trials for copying admitted exhibits for jury use.
Court's wording
The party offering the proposed electronic exhibits shall provide the clerk with two identical sets of the proposed electronic exhibits on separate electronic storage devices. In the event of a jury trial, an additional blank electronic storage device will be required to copy all of the admitted electronic exhibits onto for use by the jury (see paragraph l2)' The clerk will maintain one of the electronic storage devices as a master without modification.
Counsel should include in the memorandum an identification of orders on all motions in limine or motions for summary judgment previously made, a summary of any anticipated legal issues remaining, a brief summary of the opinions to be offered by any witnesses to be called to offer opinion testimony, as well as any objections to the opinion testimony.
When counsel are unable to agree on the language of an order, counsel should submit their proposed order to Department 15, with a written statement outlining the differences in the competing orders. If a redline copy is available, counsel may also submit that document. No additional argument should be provided. Rather, the statement should be limited to identifying the language believed to be incorrect, and directing the Court to the alternate language believed to be incorrect, and directing the Court to the alternate language proposed.
Submissions to the Court containing substantive argument on the merits of a contested issue are disfavored, viewed as improper ex parte communication, even if copied to opposing counsel, and will, generally, be disregarded.
Large demonstrative versions are not marked as exhibits; to admit one, a standard-sized copy must be submitted to be marked, offered, and admitted.
Court's wording
DEMONSTRATIVES - Largerversions of Exhibits may be used as demonstrative exhibits. These are not marked as exhibits. lf parties wish for the larger exhibits to be admitted, they must submit a standard sized copy to be marked, offered, and admitted.
Depositions do not go to the jury, are not marked, nor admitted as Exhibits; however, original depositions which counsel intend to use for impeachment purposes are "published and filed" during trial proceedings and they should be original certified and sealed depositions, unless otherwise agreed to. Submit these to the Court Clerk along with your exhibits.
The detailed, proposed Findings of Fact and Conclusions of Law shall include all elements of each Cause of Action alleged by Plaintiff and the basis for Defendant's Affirmative Defense.
Original certified and sealed depositions intended for impeachment must be submitted to the Court Clerk along with the exhibits, unless otherwise agreed.
Court's wording
Depositions do not go to the jury, are not marked, nor admitted as Exhibits; however, original depositions which counsel intend to use for impeachment purposes are "published and filed" during trial proceedings and they should be original certified and sealed depositions, unless otherwise agreed to. Submit these to the Court Clerk along with your exh ibits.
Filing & Service rules
Electronic Filing Rules
Exhibits not included on the proffered electronic storage device will not be accepted electronically absent a showing of good cause.
Absent good cause shown, no exhibits not included in the proffered electronic storage device witl be accepted electronically.
Civil cases
Page 4 | Exhibits
Exhibits not included on the proffered electronic storage device will not be accepted electronically absent a showing of good cause.
Absent good cause shown, no exhibits not included in the proffered electronic storage device will be accepted electronically.
Civil cases
Page 4 | Electronic Exhibits Submission Order
When the Court orders electronic submission of documentary and/or photographic evidence in a case, proposed exhibits must be submitted pursuant to this order.
Whenever a party determines and the Court orders that the submission of documentary and/or photographic evidence will be made in electronic format in a particular case, the submission of the proposed exhibits will be made pursuant to this order
Civil cases
Page 3 | Exhibits
When the Court orders electronic submission of documentary or photographic evidence in a case, proposed exhibits must be submitted pursuant to this order.
Whenever a party determines and the Court orders that the submission of documentary and/or photographic evidence will be made in electronic format in a particular case, the submission of the proposed exhibits will be made pursuant to this order.
Civil cases
Page 3 | Electronic Exhibits Submission Order
Filing Timing and Cure Windows
The EDCR 2.67 pre-trial memorandum must be filed no later than 14 days before trial.
The EDCR 2.67 pre-trial memorandum must be filed no later than 14 days before trial.
Page 1 | CIVIL CASES - F. Pre-Trial Memorandum Deadline
Electronic exhibits must comply with the court's electronic exhibits protocol and be submitted to the court's clerk 21 days before trial.
If the parties chose to use electronic exhibits, they must comply with the court's protocol regarding electronic exhibits, which can be obtained upon request from the court's clerks. Electronic exhibits must be submitted to the court's clerk 21 days prior to trial.
Page 1 | CIVIL CASES - I. Exhibits
Proposed orders must be submitted to Chambers within 10 days of notification, after the drafting counsel gives the draft to non-drafting counsel for review.
Proposed orders must be submitted to Chambers within ten (10) days of notification to the parties pursuant to EDCR 7.21. Counsel designated to prepare the order must provide the draft order to non-drafting counsel for review prior to submission.
Page 1 | CIVIL CASES - A. Pre-trial Procedure - 3. Motion Practice
Proposed orders must be submitted to Chambers within ten (10) days of notification to the parties pursuant to EDCR 7.21.
Proposed orders to be submitted to Chambers within ten (10) days of notification to the parties pursuant to EDCR 7.21.
Page 1 | Orders
Electronic exhibits must comply with the court's protocol and be submitted to the clerk 21 days before trial.
If the parties chose to use electronic exhibits, they must comply with the court's protocol regarding electronic exhibits, which can be obtained upon request from the court's clerks. Electronic exhibits must be submitted to the court's clerk 21 days prior to trial.
Civil cases
Page 1 | Exhibits
Original depositions anticipated to be used at trial must be delivered to the clerk before the Calendar Call.
All original depositions anticipated to be used in any manner during the trial must be delivered to the clerk prior to the Calendar Call.
Civil cases
Page 1 | Depositions
Electronic exhibits must be validated with the Vault at least two weeks (14 days) before trial begins.
Electronic Exhibits must be validated with the Vault and must be validated at least two weeks prior to the start of trial
Civil cases
Page 2 | Exhibits (continued)
Counsel should contact the Courtroom Clerks ot leost 5 days prior to trial to make arrangements to deliver the exhibits directly to the Courtroom Clerk. Exhibits must be hand delivered to the Courtroom Clerk only. They cannot be dropped off in the bin nor handed to other Department staff.
Counsel should contact the Courtroom Clerks ot leost 5 days prior to trial to make arrangements to deliver the exhibits directly to the Courtroom Clerk. Exhibits must be hand delivered to the Courtroom Clerk only. They cannot be dropped off in the bin nor handed to other Department staff.
Civil cases
Page 2 | Exhibits (continued)
Demonstrative exhibits and exemplars anticipated to be used must be disclosed before the final pre-trial conference.
Any demonstrative exhibits including exemplars anticipated to be used must be disclosed prior to the final pre-trial conference.
Civil cases
Page 1 | Exhibits
Original depositions to be used in any manner at trial must be delivered to the clerk three judicial days before trial begins.
All original depositions anticipated to be used in any manner during the trial must be delivered to the clerk three (3) judicial days prior to the commencement of trial.
Civil cases
Page 1 | Depositions
Each side must provide the Court detailed proposed Findings of Fact and Conclusions of Law two working days before trial begins.
Each side shall provide the Court, two (2) working days prior to the start of trial, a detailed, proposed Findings of Fact and Conclusions of Law with an electronic copy in Word format.
Civil cases
Page 1 | Proposed Findings of Fact and Conclusions of Law
Electronic exhibits must be submitted to the court's clerk 21 days before trial.
Electronic exhibits must be submitted to the court's clerk 21 days prior to trial.
Civil cases
Page 1 | Exhibits
Electronic exhibits must be validated with the Vault at least two weeks before trial begins.
Electronic Exhibits must be validated with the Vault and must be validated at least two weeks prior to the start of trial.
Civil cases
Page 2 | Exhibit Numbering, Marking, and Submission Instructions
Service and Proof of Service Rules
Legal briefs on trial issues must have originals filed and a copy served on opposing counsel at or before the close of trial.
Originals must be filed and a copy served on opposing counsel at or before the close of trial.
Page 1 | CIVIL CASES - D. Pre-trial Submissions
A copy of the default judgment application with a notice of hearing must be mailed to the defendant's last known address, if any.
A copy of the application with a notice of hearing must be mailed to defendant’s last known address, if any.
Page 1 | Default Judgments
Motions to withdraw as counsel are placed on the Chambers calendar, and notice must be provided to the client and all parties.
Motions to withdraw as counsel are placed on Chambers Calendar. Notice must be provided to the client and all parties.
Page 1 | Motions
Deposition designations (by page/line citation) must be filed and served by facsimile or hand two judicial days before the Calendar Call.
If deposition testimony is anticipated to be used in lieu of live testimony, a designation (by page/line citation) of the portions of the testimony to be offered must be filed and served by facsimile or hand, two (2) judicial days prior to the Calendar Call.
Civil cases
Page 1 | Depositions
Proposed voir dire questions must be filed and e-served two judicial days before the Calendar Call.
In accordance with EDCR 7.70, counsel shall file and e-serve proposed voir dire questions, two (2) judicial days prior to the Calendar Call conducted pursuant to EDCR 2.67.
Civil cases
Page 1 | Proposed Voir Dire
Objections or counterdesignations to deposition testimony must be filed and served by facsimile or hand one judicial day before the Calendar Call.
Any objections or counterdesignations (by page/line citation) of testimony must be filed and served by facsimile or hand, one (1) judicial day prior to the Calendar Call commencement.
Civil cases
Page 1 | Depositions
Deposition designations (by page/line) for testimony offered in lieu of live testimony must be filed and served by facsimile or hand three judicial days before trial.
If deposition testimony is anticipated to be used in lieu of live testimony, a designation (by page/line citation) of the portions of the testimony to be offered must be filed and served by facsimile or hand, three (3) judicial days prior to the commencement of trial.
Civil cases
Page 1 | Depositions
Objections and counter-designations to deposition testimony must be filed and served by facsimile or hand one judicial day before trial.
Any objections or counter-designations (by page/line citation) of testimony must be filed and served by facsimile or hand, one (1) judicial day prior to the commencement of trial.
Civil cases
Page 1 | Depositions
Trial memoranda submitted under EDCR 7.27 are optional but must be served on opposing counsel.
Pursuant to EDCR 7.27, counsel may submit trial memoranda of points and authorities when they are likely to be helpful to the Court and must serve such on opposing counsel.
Page 1 | CIVIL CASES - G. Trial Memoranda
The counsel designated to prepare an order must provide the draft order to non-drafting counsel for review before it is submitted to Chambers.
Counsel designated to prepare the order must provide the draft order to non-drafting counsel for review prior to submission.
Page 1 | Orders
Opposing counsel must be copied on the email transmitting the proposed Findings of Fact and Conclusions of Law.
Opposing counsel must be cc'd on the email.
Civil cases
Page 1 | Proposed Findings of Fact and Conclusions of Law
Courtesy Copy Requirements
Courtesy copies of legal briefs on trial issues. Originals must be filed and a copy served on opposing counsel at or before the close of trial.
Courtesy copies of legal briefs on trial issues. Originals must be filed and a copy served on opposing counsel at or before the close of trial.
Page 1 | CIVIL CASES - D. Pre-trial Submissions
Moving counsel must hand deliver single-sided, tabbed paper courtesy copies of all briefing, affidavits, and exhibits (including other parties' filings) to the Department 15 chambers box at least five judicial days before the hearing, or risk denial or continuance of the motion.
The department requires the parties to provide courtesy copies in advance of the hearing. Counsel for the moving party is required to submit physical, paper courtesy copies of all related briefing, affidavits, and exhibits, including those filed by other parties at least five judicial days prior to the scheduled hearing pursuant EDCR 2.20(g) and 7.26(d). All courtesy copies must be hand delivered to Department 15's chambers box (RJC, 11th floor), be single sided with all exhibits tabbed, and comply with EDCR 2.27. Failure to provide the Court with courtesy copies may result in your motion being denied or continued to a later date to allow counsel to provide courtesy copies to the Court.
Page 1 | CIVIL CASES - A. Pre-trial Procedure - 3. Motion Practice
Paper exhibits require three sets, three-hole punched and placed in three-ring binders with the exhibit list, delivered to the clerk at the final pre-trial conference.
If the parties chose to use paper exhibits, three (3) sets must be three-hole punched, placed in three ring binders along with the exhibit list. The sets must be delivered to the clerk at the final pre-trial conference in accordance with EDCR 2.69(a)(1).
Page 1 | CIVIL CASES - I. Exhibits
A courtesy copy of any default judgment application, together with the proposed default judgment, must be delivered to Department 15 upon filing.
A courtesy copy of any application for default judgment must be delivered to Department 15 (along with the proposed Default Judgment) upon filing of the application with the Court.
Page 1 | Default Judgments
When requested, the moving party must hand-deliver single-sided paper courtesy copies of all briefing, affidavits, and exhibits (with exhibits tabbed) to Department 15's chambers box at least five judicial days before the hearing, or the motion may be denied or continued.
The department will request the parties to provide courtesy copies in advance of the hearing. If the request is made, Counsel for the moving party is required to submit physical, paper courtesy copies of all related briefing, affidavits, and exhibits, including those filed by other parties at least five judicial days prior to the scheduled hearing pursuant EDCR 2.20(g) and 7.26(d). All courtesy copies must be hand delivered to Department 15’s chambers box (RJC, 11th floor), be single sided with all exhibits tabbed, and comply with EDCR 2.27. Failure to provide the Court with courtesy copies may result in your motion being denied or continued to a later date to allow counsel to provide courtesy copies to the Court.
Page 1 | Motions
The three sets of paper exhibits must be delivered to the clerk at the final pre-trial conference per EDCR 2.69(a)(1).
The sets must be delivered to the clerk at the final pre-trial conference in accordance with EDCR 2.69(a)(1).
Civil cases
Page 1 | Exhibits
Exhibits must be submitted in three sets: one for the Judge, one for the Courtroom Clerk, and one for the Witness.
SETS/COPIES - Submit three sets of exhibits (Judge, Courtroom Clerk, and Witness).
Civil cases
Page 2 | Exhibits (continued)
The offering party must provide the clerk with two identical sets of proposed electronic exhibits on separate electronic storage devices.
The party offering the proposed electronic exhibits shall provide the clerk with two identical sets of the proposed electronic exhibits on separate electronic storage devices.
Civil cases
Page 4 | Exhibits
The three sets of paper exhibits must be delivered to the clerk at the final pre-trial conference in accordance with EDCR 2.69(a)(1).
The sets must be delivered to the clerk at the final pre-trial conference in accordance with EDCR 2.69(a)(1).
Civil cases
Page 1 | Exhibits
Exhibits must be hand delivered to the Courtroom Clerk only and cannot be dropped in the bin or given to other Department staff.
Exhibits must be hond delivered to the Courtroom Clerk only. They cannot be dropped off in the bin nor handed to other Department staff.
Civil cases
Page 2 | Exhibit Numbering, Marking, and Submission Instructions
Motions for an extension of time to serve a party may be submitted to Chambers without being placed on the calendar, and a courtesy copy of the filed motion with the proposed order should be delivered to Department 15 upon filing.
All motions seeking an extension of time to serve a party may be submitted to Chambers for processing without placing the matter on the Court´s calendar. A courtesy copy of the filed Motion (along with the proposed Order) should be delivered to Department 15 upon filing of the Motion with the Court.
Page 1 | Motions
Three sets of exhibits must be submitted: one for the Judge, one for the Courtroom Clerk, and one for the Witness.
SETS/COPIES - Submit lhree sets of exhibits (Judge, Courtroom Clerk, and Witness)
Civil cases
Page 2 | Exhibit Numbering, Marking, and Submission Instructions
Filing Bundling Requirements
All proposed electronic exhibits must be submitted on a single electronic storage device unless integrity would be corrupted or volume makes single-device storage impractical.
The proposed electronic exhibits shall be submitted on a single electronic storage device, except when the integrity of the proposed electronic exhibit would be corrupted by being on a single electronic storage device or the volume of the proposed electronic exhibit(s) cannot practically be stored on a single electronic storage device.
Civil cases
Page 3 | Exhibits
Pre-Motion Conference Requirements
Upon a TRO request, Judge Hardy schedules a conference as soon as counsel have appeared, requires all counsel to attend unless urgency precludes notice, and rarely grants ex parte TROs.
When a temporary restraining order is requested, Judge Hardy will schedule a conference as soon as counsel have appeared and it is possible to properly consider the request. Judge Hardy requires all counsel to be present unless the urgency of circumstances precludes notice to opposing counsel. Judge Hardy rarely grants ex parte temporary restraining orders.
Page 1 | CIVIL CASES - M. Injunctions - 1. Scheduling and Expedited Discovery
Ex parte TRO applications are not permitted absent unusual circumstances, and any application must include an affidavit or declaration of counsel regarding attempts to contact the party to be enjoined or its counsel.
Unless unusual circumstances exist, Judge Hardy does not permit ex parte applications for temporary restraining orders. An affidavit or declaration of counsel regarding attempts to contact the party seeking to be enjoined or its respective counsel must be provided with the application.
Page 1 | CIVIL CASES - M. Injunctions
Counsel must discuss discovery disputes and make a good faith effort to resolve them before filing a discovery motion.
When a discovery dispute arises, counsel are required to discuss it amongst themselves. If, after making a good faith effort, counsel are unable to resolve a disputed issue, counsel for the aggrieved party shall promptly file with the Court a motion.
Page 1 | CIVIL CASES - B. Discovery Matters - 1. Discovery Disputes
Counsel (but not parties) must appear at the Rule 16 conference, which is held after the Joint Case Conference Report is filed, after which a scheduling/trial order issues.
Judge Hardy will issue a scheduling/trial order after the Joint Case Conference Report has been filed. Judge Hardy requires counsel, but not the parties, to appear at the conference.
Page 1 | CIVIL CASES - A. Pre-trial Procedure - 1. Rule 16 Conference in Civil and Business Court Cases
Before the final pre-trial conference, designated trial attorneys must meet in Clark County (plaintiff sets time/place unless agreed otherwise) to exchange all exhibits and witness lists and arrive at stipulations.
In accordance with EDCR 2.67, before the final pre-trial conference, the designated trial attorneys for all the parties must meet together to exchange their exhibits and list of witnesses, and arrive at stipulations and agreements, all for the purpose of simplifying the issues to be tried. The plaintiff must designate the time and place of the meeting which must be within Clark County, unless the parties agree otherwise. At this conference, all exhibits must be exchanged and examined and counsel must also exchange a list of the names and addresses of all witnesses, including experts, to be called at the trial.
Page 1 | CIVIL CASES - E. EDCR 2.67 Conference between Trial Counsel
A hearing on a proposed order dispute will only be set if counsel files a Motion for Reconsideration or Clarification and remains unsatisfied with the proposed order the Court elected to sign.
Disputes may be resolved by submission to Chambers of a proposed order copied on all parties, with or without a draft of a competing order. A hearing shall only be set if counsel files a Motion for Reconsideration or Clarification, and counsel is unsatisfied with the proposed order the Court elected to sign.
Page 1 | CIVIL CASES - A. Pre-trial Procedure - 3. Motion Practice
Adjournment & Extension Requirements
Stipulations to continue the trial are not allowed; the parties must file a motion with a hearing requested to obtain a trial continuance.
The department does not allow stipulations to continue the trial. If the parties wish to continue the trial, the parties must file a motion with a hearing requested.
Page 1 | Stipulations
Continuances of trial dates are disfavored, but the Court will consider extensions of discovery deadlines upon a showing of good cause.
Trials are scheduled on a 5 week stacked calendar. Since trial dates are set well in advance, Judge Hardy is reluctant to grant continuances - especially if the attorneys have not been diligent in moving the case forward. However, the Court will consider requests for extension of discovery deadlines upon showing of good cause.
Page 1 | CIVIL CASES - A. Pre-trial Procedure - 2. Continuances and Extensions
Department 15 approves stipulations extending response deadlines or discovery only upon a showing of good cause; otherwise a show cause hearing may be set.
With good cause shown, Department 15 will approve stipulations to extend response deadlines and stipulations to extend discovery. If good cause is not shown, a show cause hearing may be set.
Page 1 | Stipulations
Chambers Communication Rules
Judge Hardy does not accept emails from counsel.
Judge Hardy does not accept emails from counsel.
Page 1 | GENERAL CHAMBERS AND COURTROOM MATTERS - A. Correspondence with the Court
Ex parte communication with the Court, written or otherwise, is prohibited.
Judge Hardy does not permit ex parte communication with the Court, written or otherwise.
Page 1 | GENERAL CHAMBERS AND COURTROOM MATTERS - A. Correspondence with the Court
Judge Hardy does not accept letters from counsel.
Judge Hardy does not accept of letters from counsel.
Page 1 | GENERAL CHAMBERS AND COURTROOM MATTERS - A. Correspondence with the Court
Correspondence may not be used to request unopposed extensions of time or unopposed scheduling requests.
Judge Hardy does not allow correspondence to request an unopposed extension of time and for unopposed requests pertaining to scheduling.
Page 1 | GENERAL CHAMBERS AND COURTROOM MATTERS - A. Correspondence with the Court
Jury instructions in Word format may be submitted on disc or emailed to the Department JEA (RiveraA@ClarkCountyCourts.us) and the Department Law Clerk (Dept15LC@ClarkCountyCourts.us).
These can be submitted on disc or should be e-mailed to the Department JEA, RiveraA@ClarkCountyCourts.us and the Department Law Clerk, Dept 1 5 LC@ClarkCountyCourts.us .
Civil cases
Page 1 | Proposed Jury Instructions and Verdict Forms
If counsel anticipate the need for audio visual equipment during the trial, a request must be submitted to the District Courts AV department following the calendar call. You can reach the AV Dept at 671-3300 or via E-Mail at CourtHelpDesk@C larkCountyCourts.us
If counsel anticipate the need for audio visual equipment during the trial, a request must be submitted to the District Courts AV department following the calendar call. You can reach the AV Dept at 671-3300 or via E-Mail at CourtHelpDesk@C larkCountyCourts.us
Civil cases
Page 1 | Audio Visual Equipment
These can be e-mailed to the Department JEA, RiveraA(@ClarkCsqtryeeurtlug and the Department Law Clerk, DeptlSlC@ClarkCountyCourts.us .
These can be e-mailed to the Department JEA, RiveraA(@ClarkCsqtryeeurtlug and the Department Law Clerk, DeptlSlC@ClarkCountyCourts.us .
Civil cases
Page 1 | Proposed Findings of Fact and Conclusions of Law
Counsel needing audio visual equipment at trial must submit a request to the District Court's AV department following the calendar call (phone 671-3300 or CourtHelpDesk@ClarkCountyCourts.us).
If counsel anticipate the need for audio visual equipment during the trial, a request must be submitted to the District Courts AV department following the calendar call. You can reach the AV Dept at 671-3300 or via E-Mail at CourtHelpDesk@ClarkCountyCourts. us
Civil cases
Page 1 | Audio Visual Equipment
Counsel should contact the Courtroom Clerks at least 5 days before trial to arrange direct delivery of the exhibits.
Counsel should contact the Courtroom Clerks at leost 5 days prior to trial to make arrangements to deliver the exhibits directly to the Courtroom Clerk.
Civil cases
Page 2 | Exhibit Numbering, Marking, and Submission Instructions
Counsel should contact the JEA or law clerk to schedule a telephone conference.
Judge Hardy usually requests that counsel initiate any such call. Counsel should contact either the JEA or law clerk to schedule a telephone conference.
Page 1 | GENERAL CHAMBERS AND COURTROOM MATTERS - C. Telephone Conferences
Department 15 chambers may be reached by phone at (702) 671-4412, by fax at (702) 671-4411, and the law clerk at (702) 671-4409.
Office – (702) 671-4412 Fax – (702) 671-4411 Law Clerk – (702) 671-4409
Page 1 | Department XV Contact Information
Department 15 chambers may be contacted by email at dept15lc@clarkcountycourts.us.
Email – dept15lc@clarkcountycourts.us
Page 1 | Department XV Contact Information
Please reach out to the Courtroom Clerks, Francisco Reyes at revesf@clarkcountvcourts.us and Dafne Rabon Lopez at RabonD@clarkcountvcourts.us for instructions on submitting electronic exhibits.
Please reach out to the Courtroom Clerks, Francisco Reyes at revesf@clarkcountvcourts.us and Dafne Rabon Lopez at RabonD@clarkcountvcourts.us for instructions on submitting electronic exhibits.
Civil cases
Page 2 | Exhibits (continued)
Counsel must contact the Courtroom Clerks (Francisco Reyes and Dafne Rabon Lopez) for instructions on submitting electronic exhibits.
Please reach out to the Courtroom Clerks, Francisco Reyes at revesf@clarkcountvcourts.us and Dafne Rabon Lopez at RabonD@clarkcountycourts.us for instructions on submitting electronic exhibits.
Civil cases
Page 2 | Exhibit Numbering, Marking, and Submission Instructions