Clark County's deposition behavior order: what Administrative Order 22-08 requires in a Las Vegas deposition, from scheduling to objections

What the order is and who it covers

Administrative Order 22-08 is a 23-page order of the Eighth Judicial District Court dated May 9, 2022, signed by Chief Judge Linda Marie Bell and both of the court's Discovery Commissioners. By its own terms it "applies to all civil and family division actions filed in the Eighth Judicial District Court ... for which discovery disputes are heard by a discovery commissioner or discovery hearing master." In practice that is the ordinary civil and family docket in Las Vegas.

As of October 2026 the order is still listed on the court's administrative-order index with no later order amending or rescinding it. That status rests on the index alone; a call to the discovery commissioners' office is the way to settle any doubt before a contested deposition. The order does not replace NRCP 30. It restates parts of the rule, borrows from the federal committee notes, and adds Clark County expectations on conduct. Where the order and the rule speak to the same point, this guide quotes both.

No other Nevada district has anything like it. Washoe County's local rules do not mention depositions at all, a difference covered near the end of this guide. In federal court in Nevada, FRCP 30 applies instead.

Scheduling: reasonable efforts, and a waiver for silence

The order starts with the calendar. Counsel "must make reasonable efforts to ascertain and accommodate the availability of the witnesses and all counsel both before and after noticing the deposition." That is a two-way obligation: the noticing attorney asks first, and the other side answers.

The teeth are in what happens when someone objects to a date and offers nothing else. A person with a conflict "must promptly propose several reasonable alternative dates," and failure to do so "acts as a waiver of their right to object to the date set by deposing counsel." An email that says only "unavailable" does not preserve the objection.

The rule behind the order is NRCP 30(b)(1), which requires "not less than 14 days' written notice to every other party" stating the time and place of the deposition and, if known, the deponent's name and address. The order's courtesy expectation is layered on top of that minimum, not a substitute for it.

Reporting firms are the last to know when a date moves. If a deposition is renoticed after the alternative-date exchange, send the amended notice to the reporting firm the same day so the reporter, the room and any videographer or interpreter move with it.

Weekdays, business hours, and 7 hours on the record

"Absent an agreement or order, depositions must take place on weekdays during normal business hours." Evening and weekend depositions in Clark County therefore need a stipulation or a court order.

On length, the order adopts the reading in the Nevada Supreme Court's 2019 committee note. NRCP 30(d)(1) limits a deposition to "1 day of 7 hours of testimony" unless otherwise stipulated or ordered. The order says that limit "means 7 hours [of time] on the record. The time taken for convenience breaks, recess for a meal, or an adjournment under Rule 30(d)(3) does not count as deposition time." The reporter keeps the running time on the record, and most firms announce it at each break so no one is surprised at the end of the day.

NRCP 30(d)(1) also requires the court to allow additional time if needed to fairly examine the deponent or if anyone "impedes or delays the examination," and NRCP 30(d)(2) lets the court sanction "a person who impedes, delays, or frustrates the fair examination of the deponent," including reasonable expenses and attorney fees.

A related point from the same 2019 committee note, though not from the order itself: discussion between the deponent and counsel during a convenience break is not privileged unless counsel called the break to preserve a privilege, to enforce a court-ordered limitation, or to present a motion under Rule 30(d)(3). After a privilege-assessment break, counsel for the deponent must place on the record that a conference took place, its subject, and its result, citing Coyote Springs Inv., LLC v. Eighth Judicial Dist. Court, 131 Nev. 140, 149, 347 P.3d 267, 273 (2015).

In person by default, remote on stipulation or good cause, and where each witness is deposed

"Normally, a deposition will take place in person. The parties may stipulate, and the Court may order for good cause shown, that a deposition 'be taken by telephone or other [including video] remote means.'" The quoted phrase inside that sentence is NRCP 30(b)(4), which provides that the parties may stipulate, or the court may on motion order, a deposition by telephone or other remote means, and that for purposes of Rule 30 and Rules 28(a), 37(a)(2) and 37(b) "the deposition takes place where the deponent answers the questions." The order points to the good-cause factors in Okada v. Eighth Jud. Dist. Ct., 131 Nev. 834, 359 P.3d 1106 (2015) for contested motions.

The order also states the default on location. "Generally, a plaintiff's deposition may be taken in this District; a defendant's deposition may be taken where the defendant resides or, in the case of a corporate defendant's Rule 30(b)(6) designee, where the corporation has its principal place of business." For a Las Vegas plaintiff that usually means a conference room in the valley; for an out-of-state corporate defendant it can mean travel or a remote stipulation.

The order does not say where the court reporter must sit during a remote deposition; the Clark County COVID-era orders that once allowed the officer to be in a separate location lapsed in April 2022. Our remote-depositions guide covers that history and the stipulation language parties use.

Exhibits: disclose before the deposition, share on the screen during it

The order treats surprise documents as a conduct problem. Any document to be used as an exhibit "must be disclosed prior to the deposition," and disclosing a document for the first time at the deposition "constitutes gamesmanship and may warrant sanctions." That is a Clark County expectation; NRCP 30 itself has no pre-disclosure requirement.

For remote and video depositions the order adds two mechanical rules. "During a deposition taken remotely or by audio/visual means, the examiner must contemporaneously provide all participants with electronic copies of any document used at the deposition. Further, the examiner must display a document on the video feed during a remote video deposition while questioning the witness about the document." Both rules exist so the witness, the other lawyers and the record are looking at the same page at the same moment.

Marking and attaching exhibits remains governed by NRCP 30(f)(2): documents produced for inspection during a deposition must, on a party's request, be marked for identification and attached to the deposition. The reporter marks what counsel hands over or shares, logs it in the exhibit index, and attaches it to the certified transcript.

The objection regime: what is preserved, and the two-part form objection

This is the heart of the order and the part that most changes how a Las Vegas deposition sounds. Start with the rule. NRCP 30(c)(2) provides that an objection "must be noted on the record, but the examination still proceeds; the testimony is taken subject to any objection," and that "An objection must be stated concisely in a nonargumentative and nonsuggestive manner."

The order then tells counsel which objections need to be made at all. All objections are preserved for trial except six categories: privilege, a court-ordered limitation, a motion under Rule 30(d)(3), a party's conduct, lack of foundation, and form. Everything else, relevance included, can wait for the courtroom.

Form objections are confined to two parts. They "are limited to stating: 1) that the form of the question is objectionable; and 2) identifying the specific way the form is objectionable." The order lists nine appropriate form objections: ambiguous; vague or unintelligible; argumentative; calls for a narrative; calls for speculation; compound; leading; mischaracterizes prior testimony; and mischaracterizes the evidence. So the compliant objection is "Objection, form, compound," and nothing more.

Two habits are prohibited outright: string objections, where counsel recites several grounds in a row, and speaking objections, where counsel explains or argues the objection in front of the witness.

• Preserved without objection at the deposition: everything except privilege, court-ordered limitations, Rule 30(d)(3) motions, party conduct, lack of foundation and form.
• Form objection: state that the form is objectionable, then the specific defect, and stop.
• The nine recognized form objections: ambiguous; vague or unintelligible; argumentative; calls for a narrative; calls for speculation; compound; leading; mischaracterizes prior testimony; mischaracterizes the evidence.
• Not allowed: string objections and speaking objections.

Instructions not to answer, and finishing the other topics first

The order restates NRCP 30(c)(2) on this point: "A person may instruct a deponent not to answer only when necessary to preserve a privilege, to enforce a limitation ordered by the court, or to present a motion under Rule 30(d)(3)." Those are the only three grounds. An instruction not to answer because a question is irrelevant, repetitive or beyond the notice is not one of them.

When an instruction is given and the parties cannot resolve it, the order's stated best practice is to preserve the issue on the record and "finish the examination as to all other topics before suspending or terminating the deposition for the purpose of seeking protection from the Court." The disputed question is set aside, the rest of the examination proceeds, and the suspended portion is taken up only if the court or discovery commissioner orders it.

The mechanism for suspension is NRCP 30(d)(3). The deponent or a party may move to terminate or limit a deposition "on the ground that it is being conducted in bad faith or in a manner that unreasonably annoys, embarrasses, or oppresses the deponent or party," and on demand "the deposition must be suspended for the time necessary to obtain an order." A terminated deposition "may be resumed only by order of the court where the action is pending."

Rule 30(b)(6) under the order: confer, no PMK, and how designees are counted

The order devotes several pages to organizational depositions. It begins with the rule's own standard: the notice "must describe with reasonable particularity the matters for examination," quoting NRCP 30(b)(6). It then adds a Clark County expectation that the rule text does not contain: "Parties who object to the number or description of topics for examination must confer in good faith promptly upon the service of the subpoena or notice." The order draws that from the 2020 federal committee note. NRCP 30(b)(6) itself has no confer clause, so in Clark County the duty comes from the order, and elsewhere in Nevada it does not exist in the text.

The order rejects the "person most knowledgeable" shortcut. "There is no such type of deposition recognized under the NRCP" as a PMK deposition "for the purpose of binding the entity." The entity's job is narrower and clearer: it "must only prepare the designee and be willing to be bound by the designee's testimony."

Counting is where the order matters most for planning. "If an entity designates more than one spokesperson under Rule 30(b)(6), the designees collectively count as one deposition toward the presumptive maximum of ten depositions per side." But for the time limit, "the deposition of each person designated under Rule 30(b)(6) should be considered a separate deposition. In other words, the deposing party may depose each designee for up to 7 hours in 1 day." Three designees means one deposition against the 10-per-side limit in NRCP 30(a)(2)(A)(i) and up to three days of 7 hours on the record.

Two more rules round it out. An entity that objects to topics "must also seek and obtain a protective order from the Court before going forward with the deposition." And questions beyond the noticed scope may not be the basis of an instruction not to answer, though counsel "may note on the record that ... the answers will not bind the entity." Our dedicated Rule 30(b)(6) guide goes deeper.

Calling the discovery commissioner, and the meet-and-confer before any motion

Clark County routes discovery disputes to a discovery commissioner before a district judge sees them. EDCR 2.34 provides that "all discovery disputes (except disputes regarding any extension of deadlines set by the discovery scheduling order, or presented at a pretrial conference or at trial) must be heard first by the discovery commissioner." The order extends that into the deposition room: if all counsel agree, the discovery commissioner "will take a call during a deposition (or accept an invitation to participate in a streamed video deposition)." That is often faster than suspending and briefing.

A motion based on deposition behavior requires a record of an EDCR 2.34 meet-and-confer. The rule says discovery motions "may not be filed unless an affidavit of moving counsel is attached thereto setting forth that after a discovery dispute conference or a good faith effort to confer, counsel have been unable to resolve the matter satisfactorily," and that "A conference requires either a personal or telephone conference between or among counsel." After a hearing the commissioner files a report and recommendations for the district judge.

The discovery clock frames all of this. EDCR 1.90(a)(2) directs judges to ensure that pretrial discovery is completed within 18 months from the filing of the joint case conference report, or 24 months in complex litigation. A deposition suspended over an objection fight consumes that time.

Washoe County: no counterpart order

The Second Judicial District Court in Reno has no deposition-behavior order and no local rule that mentions depositions. What Washoe does have is WDCR 24, under which the court "has approved the automatic referral to the discovery commissioner all discovery proceedings," and WDCR 12(6), which requires every discovery motion to "include the certificate of moving counsel certifying that after consultation with opposing counsel, they have been unable to resolve the matter."

In a Washoe case, then, the conduct rules are NRCP 30(c)(2) and 30(d) as written: concise, nonargumentative, nonsuggestive objections; three grounds to instruct not to answer; 7 hours of testimony. The Clark County glosses on form objections, exhibit pre-disclosure, confer duties for 30(b)(6) topics and designee counting do not travel north unless a Washoe judge or commissioner adopts them in a particular case. Our Reno and Washoe County guide covers the practical differences.

From the reporter's chair: what the order does for the record

A court reporter has no role in enforcing Administrative Order 22-08, but we see its effect in every transcript. One-voice, two-part form objections produce a clean record: question, "Objection, form, leading," answer. String objections and speaking objections produce overlapping speech, interrupted answers and pages a judge has to wade through. The order's objection regime is, in effect, a readability standard for the transcript that will later be read in motions and at trial.

The 7-hours-on-the-record rule depends on an accurate time log, and that is the reporter's. We note the time the record opens, every off-the-record break, and the time it closes, and give counsel the elapsed total on request. Under NAC 656.350 a Nevada reporter treats all words spoken during the proceeding as on the record and stops reporting only when a party or attorney instructs us to go off the record and no one immediately objects.

Western Reporting Services has reported depositions in Las Vegas since 1990 with stenographic and voice-writing reporters certified by the Nevada Certified Court Reporters' Board. We cover the Las Vegas valley, host depositions in our conference rooms, provide remote depositions and legal videography, and arrange interpreters by referral. If your deposition may involve a call to the discovery commissioner or a streamed video feed, tell us at scheduling.

Currency of the sources quoted

Administrative Order 22-08 is quoted from the order dated May 9, 2022, listed on the Eighth Judicial District Court's administrative-order index with no amending order as of October 2026. Rule text is the Nevada Rules of Civil Procedure as amended through October 31, 2025; Rule 30 was last amended effective March 1, 2019, under ADKT 0522, and the committee note quoted is the 2019 Advisory Committee Note to Rule 30. The Eighth Judicial District Court Rules and the Washoe District Court Rules are as amended through October 31, 2025; NAC 656 is the page revised 2026-04-13. Orders and rules change; confirm the current text with counsel.

Common questions

Does Administrative Order 22-08 apply to my case?

It applies to all civil and family division actions filed in the Eighth Judicial District Court for which discovery disputes are heard by a discovery commissioner or discovery hearing master. It does not apply in Washoe County or any other Nevada district, and it does not apply in federal court. Your attorney can confirm how your case is assigned.

Is the order still in effect?

As of October 2026 it is listed on the court's administrative-order index with no later order amending or rescinding it. That is an index check, not a ruling; the discovery commissioners' office can confirm current status.

What objections do I have to make at the deposition to preserve them?

Under the order, all objections are preserved for trial except six categories: privilege, a court-ordered limitation, a Rule 30(d)(3) motion, a party's conduct, lack of foundation, and form. Those six must be raised at the deposition. NRCP 30(c)(2) requires every objection to be stated concisely in a nonargumentative and nonsuggestive manner.

What does a proper form objection sound like?

Two parts: that the form of the question is objectionable, and the specific way it is objectionable. The order recognizes nine form objections: ambiguous; vague or unintelligible; argumentative; calls for a narrative; calls for speculation; compound; leading; mischaracterizes prior testimony; and mischaracterizes the evidence. "Objection, form, compound" is complete. Reciting several grounds in a string, or explaining the objection, is prohibited.

Do breaks count against the 7 hours?

No. The order, following the 2019 committee note to NRCP 30(d)(1), says the limit means 7 hours on the record, and that time taken for convenience breaks, a meal recess, or an adjournment under Rule 30(d)(3) does not count as deposition time. The court reporter keeps the running time.

If a company designates three witnesses under Rule 30(b)(6), is that one deposition or three?

Both, depending on the limit. For the 10-per-side limit in NRCP 30(a)(2)(A)(i), the designees collectively count as one deposition. For the 7-hour limit in NRCP 30(d)(1), each designee is treated as a separate deposition, so the deposing party may depose each designee for up to 7 hours in 1 day.

Can we get the discovery commissioner on the phone during the deposition?

The order says that if all counsel agree, the discovery commissioner will take a call during a deposition or accept an invitation to participate in a streamed video deposition. Any later motion about deposition behavior still needs the EDCR 2.34 meet-and-confer affidavit.

Does any of this apply to a deposition in Reno?

No. Washoe County has no counterpart order and no local rule that mentions depositions. Discovery proceedings there are automatically referred to the discovery commissioner under WDCR 24, and discovery motions need the certificate of consultation under WDCR 12(6). The conduct rules in a Washoe deposition are NRCP 30(c) and 30(d) as written.