Interrogatories
(NV)
Summary
These interrogatories are for discovery between parties in civil actions in Nevada district court. This template includes the components of a complete set of interrogatories, including a caption, definitions, instructions, and a certificate of service. This template includes practical guidance, drafting notes, and optional clauses. Interrogatories may be served by any party on any other party at any time after the commencement of suit. Nev. R. Civ. P. 33(a). Rule 33 addresses basic procedures for preparing, serving and answering interrogatories, as well as using them in Nevada civil court matters. A party may serve no more than 40 interrogatories on any other party without leave of court. Nev. R. Civ. P. 33(a)(1). Strive to avoid wasting interrogatories by drafting precise interrogatories that are not repetitive. Subparts of interrogatories count toward the total of 40 but, in practice, subparts directly related to the interrogatory will be counted as one, especially when the subpart simply modifies or defines the interrogatory. You need not serve all 40 permitted interrogatories at the same time. You may want to serve preliminary "background" interrogatories first and, dependent upon the answers received, serve a second set of interrogatories to obtain more specific information from the other party. Answers to interrogatories must be served within 30 days of service of the interrogatories unless the court orders otherwise. Nev. R. Civ. P. 33(b)(2). When drafting interrogatories, keep the following in mind: • Rules 26 governs all aspects of discovery in civil litigation, including interrogatories. Read it before drafting interrogatories to understand both the letter and the spirit of the discovery process, including its scope and limitations. • Progress from general to specific questions, beginning with an interrogatory requesting the identity of the person answering. • Be sure interrogatories are comprehensible to avoid an objection from the answering party. • To avoid an objection from the answering party, be sure interrogatories do not request privileged or irrelevant information. They may seek inadmissible information as long as it is reasonably calculated to lead to the discovery of admissible evidence. See Nev. R. Civ. P. 26(b)(1). • Proofread comprehensively to be sure dates, times, places, identities, and other facts set out in your interrogatories are correct. • Serve interrogatories early and keep an eye on your deadlines. This template assumes the plaintiff is propounding interrogatories. If you represent the defendant, you should customize them accordingly. For more information on interrogatories, see Interrogatories: Drafting and Serving Interrogatories (NV). For a related template, see Objections and Responses to Interrogatories (NV).