In re Parental Rights as to T.M.R.
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The Supreme Court affirmed the judgment of the district court terminating Appellant's parental rights, holding that the district court's failure to apply Nev. R. Civ. P. 16.2(e)(4)'s mandate regarding disclosure of witnesses was harmless error.
The State sought to terminate Appellant's parental rights, but the State did not disclose a nonexpert witness until after the trial had commenced. The district court, however, allowed the witness to testify at trial on the grounds that the nonexpert witness disclosure requirements in Rule 16.2(e)(4) do not apply to termination of parental rights proceedings. The district court ultimately terminated Appellant's parental rights. The Supreme Court affirmed, holding (1) the nonexpert witness notice requirements in Nev. R. Civ. P. 16.2 apply to termination of parental rights proceedings; and (2) the district court erred by denying Appellant's motion in liming to exclude an unnoticed nonexpert witness during trial, but the error was harmless.
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