Objections and Responses to Requests for Production of Documents
(NV)

Summary

This template of objections and responses to a request for production of documents (RFPs) may be used when responding to RFPs served on you or your client in a civil lawsuit in Nevada District Court. This template includes practical guidance, drafting notes, and alternate clauses. Pursuant to Nev. R. Civ. P. 34(a) any party may serve upon any other party requests to produce or permit the requesting party to inspect, copy, test, or sample: • Documents • Electronically stored information (ESI) –or– • Tangible things This material is referred to collectively herein as "documents." The responding party then has 30 days to serve responses. Nev. R. Civ. P. 34(b)(2)(A). For each item or category, you must either: • State that inspection and related activities will be permitted as requested –or– • State that the request is objected to, including the reasons for the objection Nev. R. Civ. P. 34(b)(2)(B). You are obligated to produce only documents that are in your possession, custody, or control. Nev. R. Civ. P. 34(a)(1). And, you have a duty to supplement your client's responses to requests for production (RFPs), if you learn that the response is incomplete or incorrect. Nev. R. Civ. P. 26(e)(1). This template assumes the defendant is responding to a request for production of documents served by the plaintiff. If you represent the plaintiff or co-defendant, you should modify the template accordingly. For more information on responding to requests for production of documents, see Document Requests: Responding to RFPs (NV).