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D. Nev. · Judge Couvillier · Practice Guide

Hon. Maximiliano D. Couvillier III

All local rules for D. Nev., integrated with this judge's published requirements.

Before You File
Ex parte applications
👤 Judge Couvillier — standing order

Counsel and parties should not contact Judge Couvillier’s chambers ex parte - except as provided for in LR IA 7-1(a) or in connection with Early Neutral Evaluation or Settlement Conference proceedings.

Lead counsel requirements
👤 Judge Couvillier — standing order

Lead counsel for each party shall meet and confer in person, videoconference, or telephone. A mere exchange of letters or e-mails does not satisfy the meet and confer requirement.

Contacting chambers
👤 Judge Couvillier — standing order

Parties should contact the Clerk’s Office at (702) 464-5400 or Judge Couvillier’s Courtroom Deputy, Tawnee Renfro, at (702) 464-5427, with any scheduling or other non-substantive issues. See LR IA 7-2(c). Substantive matters should be addressed through filings that are served upon all parties.

Drafting the Motion
AI use & disclosure requirements
👤 Judge Couvillier — standing order

Any counsel or party may use AI to draft documents or process discovery consistent with Rule 11 of the Federal Rules of Civil Procedure (Fed. R. Civ. P.), this Standing Order, and any other applicable legal or ethical obligations. 1. Certification of AI Use In Drafting Filings. Any party that files (manually or e-filing) a brief, motion, request, pleading, or other similar document with the Court which includes content generated or drafted by artificial intelligence (i.e., ChatGPT, Harvey, CoCounsel, Google Gemini, or any other such application) must include the following certification above the signature line: “I certify that artificial intelligence was used to generate a portion of this filing. I have reviewed the source material and verified that the artificially generated content in the filing is accurate and complies with the filer’s Rule 11 obligations.” Failure to include such certification may result in sanctions. Standing Order — III. Artificial Intelligence (AI) (p.3) ↗

The Hearing
Oral argument
👤 Judge Couvillier — standing order
Default practice

Per LR 78-1, all motions may be considered and decided with or without a hearing. Any party making or opposing a motion who believes oral argument may assist the court may request a hearing by inserting the words ORAL ARGUMENT REQUESTED below the title of the document on the first page of the motion or response.

Decided on the papers?

Yes — motions decided on the papers without oral argument.

Discovery
Discovery dispute procedure
👤 Judge Couvillier — standing order

Pursuant to LR 1-1(b)(2), Judge Couvillier requires the parties to follow the procedures outlined below regarding any discovery dispute. No discovery motion may be filed until the following procedure has been followed and such motion is ordered by Judge Couvillier: 1. If a discovery dispute arises the parties must first meet and confer to try to resolve their dispute in compliance with LR IA 1-3(f). Lead counsel for each party shall meet and confer

If the parties are unable to resolve their dispute informally after a good-faith effort, the parties must file a single document captioned “Stipulation Regarding Discovery Dispute” that addresses each one of the following items: i. A brief, joint summary of the discovery dispute not to exceed one (1) page;

More from Judge Couvillier’s procedures
👤 Judge Couvillier — standing order
Argument counsel requirement

Judge Couvillier encourages litigants to permit more junior members of the litigation team to present oral argument and gain courtroom experience. Thus, if a party requests oral argument, the party should further note in the caption of the motion that a junior, less experienced attorney will be responsible for presenting argument. Allowing junior, less experienced attorneys to argue will weigh in favor of holding a hearing. Source ↗

Dispositive motion stay

The filing of a motion to dismiss does not stay discovery. Rather, the parties are required to comply with the rules of discovery as required by the Local Rules and the Federal Rules of Civil Procedure. See LR 26-1 et. seq.; Fed. R. Civ. Pro. 26 et. seq. Source ↗

content assembled from published local rules & standing orders · click any section in the rail for the full treatment
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