Judge Michelle Leavitt
Individual Rules, Standing Orders & Policies
- Rules last changed:
Limits & Logistics
Courtesy Copies
Exhibits
- 2 copies
- 3 copies • Prior to Trial
Jury Notebooks
- 11 copies
Pretrial Memorandum
- 1 copy • Upon Filing
Communication
Chambers5 contacts
Clerk4 contacts
Other Contacts1 contacts
Document Format Requirements9 rules
NOTE: It is the responsibility of counsel to ensure that all sets of exhibits provided to the Court match exactly.
- Exhibits
Formatting
- •All sets of exhibits provided to the Court must match exactly
Photographs and CD/DVD/flash drives must be submitted and identified separately, with only one photograph per page and one file per medium, unless counsel stipulate to admitting all items.
Court's wording
Photographs & CD/DVD/Flash Drives: MUST be submitted and identified separately. DO NOT place more than one photograph on one sheet of paper, or multiple files on the CD/DVD/Flash Drive, as this presents an issue if only one photograph/file is moved for admission. You may ONLY place more than one photo on a page or multiple files on a CD/DVD/Flash Drive if counsel are stipulating to admitting all of Photographs on the page or all of the Files within the CD/DVD/Flash Drive.
Clerk's exhibit binders must be pre-marked with proposed exhibit labels showing Joint/Plaintiff/Defendant, the exhibit number/letter, and case number, adhered in specified locations without covering pertinent information.
Court's wording
The clerk's exhibit binder(s) must be pre-marked with a proposed exhibit label on the lower left back side of the last page of the exhibit; indicating either Joint, Plaintiff, Defendant, and the exhibit number/letter and case number #. The label must be adhered to either on the first page of a single page exhibit, or on the lower left back-side of the last page of multiple page documents, or on the back side of any exhibit to avoid covering up any pertinent information or part of a photograph. See samples of proposed exhibit labels on pages 7-10 which can be used for Avery Template 5160 Easy Peel Labels.
Exhibits binders: Submit binders no wider than 3 to 4 inches and separate each exhibit by a tab that is accordingly labeled with the exhibit number/letter.
Joint and Plaintiff's exhibits must be labeled with numbers, while Defendant's exhibits must be labeled with letters.
Court's wording
Joint Exhibits: Label the tabs/proposed labels with numbers. (i.e. 1, 2, 3, 4…) Plaintiff's Exhibits: Label the tabs/proposed labels with numbers. (i.e. 1, 2, 3, 4…) Defendant's Exhibits: Label the tabs/ proposed labels with Letters (i.e. A, B, C, D… X, Y, Z, A1, A2, A3…).
If an individual exhibit has more than one (1) page and is not Bates stamped or identified by number on each page, it must be bound in some fashion, either by staples, brads, Acco fastener, etc.
- Binding
- Securely bound
- Exhibits
Please email a set in WORD format, to the JEA, Pamela Osterman at OstermanP@clarkcountycourts.us
- File type
- Word
Each page must be bates stamped in numeric order for ease in locating a specific page of an exhibit.
These are generally permitted. They are not marked as exhibits and would not go to the Jury or Judge as trier of fact. However, if counsel wish these larger versions submitted as part of the record, they must be numbered and marked separately as standalone exhibits.
Document Filing Requirements8 rules
Additionally, a clean laptop must be provided for jury deliberations for the jury to view any admitted exhibits on a CD/DVD/Flash Drive player.
Depositions must be sealed, certified copies or they will not be accepted without the Court's approval.
- Document
- Depositions
Must include
- •Sealed, certified copies
Parties must prepare trial briefs addressing significant issues not adequately addressed in dispositive or pretrial motions.
Court's wording
If the trial of the case will involve significant issues not adequately addressed by the parties in connection with dispositive Motions or other Pre-trial Motions, the parties must prepare trial briefs addressing such issues.
An Exhibit List noting the exhibit number/letter, description, and bates stamp numbers should accompany each set of exhibits; however, do not identify the exhibits as offered or admitted as that will be performed at trial.
Depositions do not go to the jury, and are not marked or admitted as exhibits; however, if counsel intends on using a deposition, he/she must request to have the deposition "published" during the trial proceedings.
If counsel intends to use a PowerPoint presentation, please provide a paper copy to the Court as this will be marked as a Court's Exhibit, which does not go back to the Jury. If there are overlying projections or video files embedded into the PowerPoint presentations, please provide an electronic copy (CD, DVD, or Flash drive) instead of a paper copy.
If agreement cannot be reached, a memorandum must be prepared separately by each attorney and so submitted.
Jury notebooks are highly encouraged, their contents should be stipulated to, they should include frequently referenced documents, and counsel may bring copies of non-stipulated exhibits for each notebook.
Court's wording
Even with the use of audio-visual equipment, the court highly encourages the use of jury notebooks. Counsel should stipulate to all the contents of the notebooks. Jury notebooks generally should include copies of documents that will be referred to frequently at trial. For exhibits that are not stipulated to, counsel proposing the admission of the exhibit may bring enough copies for each notebook to give copies to the jurors at the time the exhibit is admitted.
Filing & Service rules
Electronic Filing Rules
Motions must be e-filed; Department 12 does not accept motions by email or hardcopy.
Department 12 does not accept motions via email or hardcopy. All motions must be e-filed in order to be set on calendar.
Page 1 | Submission of Motions
Filing Timing and Cure Windows
Proposed orders must be submitted to the Department 12 chambers inbox (dc12inbox@clarkcountycourts.us) within ten days of notification of the ruling.
Department 12 requires proposed orders to be submitted to chambers to dc12inbox@clarkcountycourts.us within ten (10) days of notification of the ruling, pursuant to EDCR 7.21.
Page 1 | Submissions of Orders
Proposed voir dire questions must be presented to the trial judge in writing 10 business days before trial begins.
Proposed voir dire questions shall be presented to the trial judge in writing ten (10) business days before the start of trial.
Civil cases
Page 1 | Voir Dire Questions
Objections to proposed voir dire questions must be submitted 5 business days before trial begins.
Any objections to the proposed questions shall be submitted five (5) business days before the start of trial.
Civil cases
Page 1 | Voir Dire Questions
If there are more than 100 exhibits, please submit exhibits and email the exhibit list to the Court Clerk one week prior to trial.
If there are more than 100 exhibits, please submit exhibits and email the exhibit list to the Court Clerk one week prior to trial.
Civil cases
Page 1 | For ALL Trials (Exhibit Sets Submission)
Proposed jury instructions and verdict forms are due at Calendar Call.
Both are due at Calendar Call.
Civil cases
Page 1 | Proposed Jury Instructions and Verdict Forms
A joint pretrial memorandum must be served and filed at least 15 days before the trial date.
Per EDCR 2.67, the attorneys must prepare a joint pretrial memorandum that must be served and filed not less than 15 days before the date set for trial.
Civil cases
Page 1 | Pre-Trial Memorandum
An unfiled copy of the trial brief must be delivered to the Court at or before the Pre-trial Conference, prior to commencement of trial.
At or before the Pre-trial Conference, the parties deliver an unfiled copy to the Court prior to the commencement of Trial.
Civil cases
Page 1 | Trial Briefs (EDCR 7.27)
All deposition should be lodged with the court clerk prior to trial along with the exhibits.
All deposition should be lodged with the court clerk prior to trial along with the exhibits.
Civil cases
Page 1 | Depositions
Courtesy Copy Requirements
Three sets of exhibits (Judge, Court Clerk/official record, witness stand) must be submitted for all trials, and each party's counsel must also have their own set.
For ALL Trials, submit Three (3) sets of exhibits (one for the Judge, one for the Court Clerk/official record, and one for the witness stand). Plaintiff and Defendant's counsel must also have a set for themselves.
Civil cases
Page 1 | For ALL Trials (Exhibit Sets Submission)
A courtesy copy of each pretrial memorandum must be delivered to the court at the time of filing.
A courtesy copy of each memorandum must be delivered to the court at the time of filing.
Civil cases
Page 1 | Pre-Trial Memorandum
Please provide eleven juror notebooks one judicial day prior to trial.
Please provide eleven juror notebooks one judicial day prior to trial.
Civil cases
Page 1 | Jury Notebooks
For voluminous exhibits the Clerk will schedule a marking meeting; counsel must provide original exhibits to the Clerk and a copy for the Judge (and possibly the witness), with the Clerk's copy serving as the official record.
The Court Clerk will contact counsel to schedule a time to meet with counsel to mark the exhibits (only if a voluminous). Counsel are to provide the original exhibits to the Clerk and a copy for the Judge a copy maybe used for the witness (but the clerk's copy is the official record).
Civil cases
Page 1 | Additional info
Sealing & Redaction Procedures
Counsel must ensure exhibits are redacted if needed; late redaction requests must be addressed on the record and a new redacted exhibit provided and marked.
It is the responsibility of counsel to ensure the exhibits are redacted if needed. If a redaction is requested after the exhibits have been submitted to the Court, or have been testified to, or have been admitted as an exhibit, Counsel will need to address this matter on the record with the Court, and an additional redacted exhibit would need to be provided to the Court and marked as a new exhibit.
Civil cases
Page 1 | Redactions
Filing Bundling Requirements
Joint exhibits are encouraged and stipulations may be noticed to the Court Clerk before trial (but must still be placed on the record); if separate exhibit sets are submitted, duplicates must be eliminated.
Counsel are encouraged to submit Joint Exhibits, which may or may not be stipulated to for admittance. You may notify the Court Clerk of stipulation(s) prior to start of trial; however, these stipulations will still need to be placed on the record. If separate sets of exhibits are submitted, duplicate exhibits MUST be eliminated.
Civil cases
Page 1 | Joint Exhibits and Stipulations
Pre-Motion Conference Requirements
Counsel must meet and discuss pre-instructions to the jury, jury instructions, and verdict forms per EDCR 2.67.
In accordance with EDCR 2.67, Counsel shall meet and discuss pre-instructions to the Jury, Jury instructions and verdict forms.
Civil cases
Page 1 | Proposed Jury Instructions and Verdict Forms
Counsel must complete the EDCR 2.67 conference before meeting with the Court Clerk to mark exhibits.
Counsel are to conduct their E.D.C.R. 2.67 conference prior to meeting with the Court Clerk to mark exhibits.
Civil cases
Page 1 | Joint Exhibits and Stipulations
Chambers Communication Rules
All proposed orders must be submitted to the Department 12 email inbox (dc12inbox@clarkcountycourts.us).
All orders must be submitted to the Department 12 Inbox.
Page 1 | Submissions of Orders
Audio visual equipment arrangements must be made in advance with Court Recorder Sara Richardson by email.
If counsel anticipates the need for audio visual equipment for trial, arrangements must be made in advance with the Court Recorder Sara Richardson, RicharsonS@clarkcountycourts.us
Civil cases
Page 1 | Audio Visuals
A set of the proposed jury instructions and verdict forms must be emailed in WORD format to JEA Pamela Osterman.
Please email a set in WORD format, to the JEA, Pamela Osterman at OstermanP@clarkcountycourts.us
Civil cases
Page 1 | Proposed Jury Instructions and Verdict Forms
In-person appearance is required for substantive matters in courtroom 14D, while Zoom appearances are allowed for all other matters upon contacting the Department for connection information.
Department 12 requires in-person appearances for substantive matters in courtroom 14D. Zoom appearances are allowed for all other matters. Please contact the Department for the information.
Page 1 | Requests for Appearances via Zoom
Please email a copy of the exhibit list to both the Courtroom Clerks: Reina Esparza, Esparzar@clarkcountycourts.us and Maxine Fuentes, Fuentesma@clarkcountycourts.us
Please email a copy of the exhibit list to both the Courtroom Clerks: Reina Esparza, Esparzar@clarkcountycourts.us and Maxine Fuentes, Fuentesma@clarkcountycourts.us
Civil cases
Page 1 | Exhibit List
Counsel must email the Court Recorder at least two weeks in advance to request daily trial transcripts, or transcript production may be delayed.
Counsel is to notify the Court recorder at least two (2) weeks in advance if they are going to require daily copies of the transcripts of this Trial. Failure to do so may result in a delay in the production of the Transcripts. You should email the request to the Court Recorder, Sara Richardson at richardsonS@clarkcountycourts.us
Civil cases
Page 1 | Requesting Daily Copies of Transcripts
Department 12 chambers can be contacted by email at dept12lc@clarkcountycourts.us.
Email – dept12lc@clarkcountycourts.us
Page 1 | Department XII Contact Information
The Department 12 law clerk can be reached at (702) 671-4369.
Law Clerk – (702) 671-4369
Page 1 | Department XII Contact Information
Department 12 chambers can be reached by phone at (702) 671-4372.
Office – (702) 671-4372
Page 1 | Department XII Contact Information
Telephonic appearances through the Court Call service are not used in Department 12.
Department 12 does not use Court Call
Page 1 | Requests for Telephonic Appearances
Department 12 chambers fax number is (702) 671-4371.
Fax – (702) 671-4371
Page 1 | Department XII Contact Information