• 

IN THE SUPREME COURT OF THE STATE OF NEVADA 

No. 84330 

FILE 

VALLEY HEALTH SYSTEM, LLC, D/B/A 

CENTENNIAL HILLS HOSPITAL 

MEDICAL CENTER; GREENBERG 

TRAURIG, LLP; UHS OF DELAWARE; 

AND TAK-YING SHEFFIELD, R.N., 

Petitioners, 

vs. 

THE EIGHTH JUDICIAL DISTRICT 

COURT OF THE STATE OF NEVADA, IN 

AND FOR THE COUNTY OF CLARK; 

AND THE HONORABLE NADIA KRALL, 

DISTRICT JUDGE, 

Respondents, 

and 

RAYMOND BELLAVANCE; AND ROBIN 

BELLAVANCE, INDIVIDUALLY AND AS 

CO-GUARDIANS OF JOSEPH 

BELLAVANCE, A PROTECTED PERSON, 

Real Parties in Interest. 

ORDER GRANTING PETITION 

This original petition seeks a writ of mandamus or prohibition 

directing the district court to vacate discovery orders and assigning the case 

to a different district court department. 

FACTUAL AND PROCEDURAL HISTORY 

Real parties in interest Joseph Bellavance and his parents 

(collectively, Bellavance) sued petitioners Valley Health System, LLC 

(VHS) d/b/a Centennial Hills Hospital Medical Center (CHH) and Tak-Ying 

Sheffield, R.N., after Joseph suffered severe brain damage following a brain 

surgery. The medical records that Bellavance obtained from CHH before 

suing, and those that CHH thereafter produced under NRCP 16.1, omitted 

Joseph's post-surgical assessment and treatment records. The omission did 
not come to light until deposition discovery was underway. When it did, 

counsel for CHH contacted the electronic record provider and supplemented 

its prior productions with what CHH maintains are the omitted records. 

CHH also offered to reimburse Bellavance for the expense associated with 

redoing the discovery that had taken place without the complete records. 

CHH also did not disclose all relevant insurance policies and, after several 

conferences, CHH supplemented these disclosures as well. 

Asserting that CHH's untimely and incomplete productions 

prejudiced their case, Bellavance filed a motion requesting an "Order of 

sanctions against CHH and striking its Answer and defenses in accordance 

with NRCP 37." Up to that point, CHH was represented by a local medical 

malpractice firm as trial counsel. Thereafter, additional CHH counsel, 

petitioner Greenberg Traurig, LLP, sent a letter authored by attorney Jacob 

Bundick to Bellavance explaining that the medical record production was 

inadvertently incomplete due to a variety of issues related to the methods 

and processes CHH used to identify and gather the relevant documents 

from the electronic record provider. That letter included yet additional 

documents CHH found via new search methods and processes and 

attempted to explain the earlier incomplete productions and the variations 

in some of the documents. 

CHH filed an opposition to Bellavance's sanction motion. In 

addition to generally arguing against sanctions for failing to disclose the 

medical records given that it asserted that it had now provided Bellavance 

a complete set, CHH also posited that sanctions were not warranted to deter 

future conduct regarding the failure to disclose relevant insurance policies 

because "CHH and its subsidiaries have had over 346 cases filed against 

them" in the previous two years with no discovery sanctions. This prompted 

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Bellavance to ask the court to direct CHH to produce the initial disclosures 

from those 346 cases, arguing that the information was needed to determine 

the sanctions necessary to deter similar future conduct. The district court 

orally granted Bellavance's request and set the matter for an evidentiary 

hearing "on the issue[s] of the medical records and their alteration, 

and . . . the insurance polic[ies]," and "to determine what, if any, sanctions" 

to impose. 

Bellevance issued and served subpoenas on Bundick and his 

assistant, requiring them to testify at the hearing. Greenberg Traurig 

moved to quash the subpoenas, and CHH moved to reconsider the hearing's 

scope as it pertained to insurance disclosures in other CHH cases. CHH 

included an affidavit from Bundick wherein he claimed that he made an 

error as to the 346 cases, stating that number represented the cases that 

petitioner UHS of Delaware and all of its subsidiaries had been involved in, 

not CHH specifically. By its motion, CHH sought to limit the hearing and 

its production obligation to only cases involving CHH. 

The district court orally addressed CHH's motion at the start of 

the evidentiary hearing. The district court limited the disclosures from 

CHH's other cases to only those in Nevada involving CHH and VHS. But 

the district court refused to quash Bundick's and his assistant's subpoenas, 

citing its concern that Bundick had misrepresented to the court when he 

and his firm became involved in the case and his client's insurancedisclosure and sanction record in other cases. In making its rulings, the 

district court found that (1) by writing the letter explaining the updated 

medical records disclosures, Bundick put privileged communications at 

issue, waiving the work product and attorney-client privileges and making 

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himself a witness in the case, and (2) that the crime-fraud exception to the 

attorney-client privilege applied. 

The evidentiary hearing proceeded and Bellavance called 

Bundick as a witness. CHH and Greenberg Traurig (who had its own 

counsel appear) objected numerous times during Bundick's questioning 

based on attorney-client and work-product privileges. Despite the court 

overruling these objections, the parties agreed to pause Bundick's testimony 

and instead call the witness who assisted CHH in obtaining and producing 

what it represented to be Bellavance's entire medical file from the electronic 

medical records provider. The second day of the hearing ended in the 

middle of that witness's testimony, and petitioners filed a writ petition with 

this court regarding the privilege issues. After we directed the district court 

to enter written orders regarding its decisions, the district court entered an 

order granting in part and denying in part CHH's motion for 

reconsideration of the scope of the evidentiary hearing, and an order 

denying Greenberg Traurig's motion to quash the subpoenas for Bundick 

and his assistant. Both orders stated that CHH's counsel had violated 

Nevada's Rules of Professional Conduct. Now before us is petitioners' 

supplemental petition which asks us to vacate these orders. As directed, 

Bellavance has filed an answer and petitioners have filed a reply. Further 

proceedings on the sanctions hearing have been stayed pending decision on 

the writ petition. 

DISCUSSION 

Petitioners main contention is that the district court abused its 

discretion in concluding that attorney-client and work-product privileges 

were waived. A writ petition is the proper mechanism for petitioners to seek 

relief as to this issue. While we rarely consider petitions challenging 

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discovery orders, consideration here is appropriate because the district 

court deemed certain privileges waived and, "once information is produced, 

any privilege applicable to that information cannot be restored." Valley 

Health Sys., LLC v. Eighth Judicial Dist. Court, 127 Nev. 167, 169, 252 P.3d 

676, 677 (2011); see also Canarelli v. Eighth Judicial Dist. Court, 136 Nev. 

247, 250, 464 P.3d 114, 119 (2020) (recognizing that this court will intervene 

via a writ when a district court wrongfully orders the disclosure of 

privileged information). And we disagree with Bellavance that the issue is 

moot due to Bundick and his assistant having completed their testimony 

because, in light of the district court's orders, nothing prevents Bellavance 

from recalling them or otherwise delving into privileged inforniation. See 

Personhood Nev. v. Bristol, 126 Nev. 599, 602, 245 P.3d 572, 574 (2010) 

(discussing the mootness doctrine). 

Petitioners challenge to the district court's findings that 

counsel violated the Nevada Rules of Professional Conduct is also 

appropriately raised by writ petition. See Valley Health Sys., LLC v. Estate 

of Doe, 134 Nev. 634, 638, 427 P.3d 1021, 1026 (2018) (concluding that the 

finding of an RPC violation constitutes a "reputational sanction" that is 

"reviewable by writ"). We will consider petitioners' remaining argument, 

whether the district court abused its discretion in entering orders against 

Sheffield and UHS, in the interest of judicial economy. See City of Mesquite 

v. Eighth Judicial Dist. Court, 135 Nev. 240, 243, 445 P.3d 1244, 1248 

1Bellavance argues that we should not entertain the petition or grant 

relief because no privileged information has been divulged or is in danger 

of being divulged. We disagree. The danger of privileged information being 

divulged arose once the district court deemed attorney-client and workproduct privileges waived. 

5 

. • ' 

, 
(2019) (considering issues via a writ petition when judicial economy 

warranted it). 

Waiver of privileges 

In its order denying Greenberg Traurig's motion to quash 

Bellavance's subpoenas of Bundick and his assistant, the district court 

concluded that petitioners had waived both attorney-client and workproduct privileges on two grounds: the crime fraud-exception and the atissue exception. We address each in turn. 

Crime-fraud exception 

NRS 49.115(1) sets forth the crime-fraud exception to attorneyclient privilege: "There is no privilege under NRS 49.095 or NRS 

41.105 . . . [i]f the services of the lawyer were sought or obtained to enable 

or aid anyone to commit or plan to commit what the client knew or 

reasonably should have known to be a crime or fraud."2For the statutory 

exception to apply, the party asserting the crime-fraud exception "has the 

burden of making a prima facie showing that the comniunications were in 

furtherance of an intended or present illegality . . . and that there is some 

relationship between the communications and the illegality." In re Grand 

Jury Proceedings, 87 F.3d 377, 380 (9th Cir. 1996) (alteration in original) 

(quoting United States v. Laurins, 857 F.2d 529, 540 (9th Cir. 1988)). The 

moving party cannot "merely . . allege that it has a sneaking suspicion the 

client was engaging in or intending to engage in a crime or fraud when it 

consulted the attorney." Id. at 381. The district court must instead "find 

2NRS 49.095 provides that the client has the privilege to refuse to 

disclose and prevent others from disclosing confidential communications 

between the client and/or their representative and the attorney and/or their 

representative. NRS 49.105 states who may claim the privilege. 

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reasonable cause to believe that the attorney's services were utilized in 

furtherance of the ongoing unlawful scheme." Id. (internal quotation marks 

and alteration omitted); see also Rock Bay, LLC v. Eighth Judicial Dist. 

Court, 129 Nev. 205, 211 n.3, 298 P.3d 441, 445 n.3 (2013) (recognizing that 

federal cases interpreting federal laws that have Nevada counterparts are 

"strongly persuasive"). 

In its written order, the district court concludes Bellavance 

presented prima facie evidence "that somebody altered Joseph's medical 

records," and cites NRS 199.210, which makes it a felony to knowingly offer 

"forged or fraudulently altered" evidence at a judicial hearing. This statute 

does not appear in the district court's oral rulings, and appears to be based 

on the district court's finding that the records Bundick produced with his 

letter to Bellavance contained "material differences" from the previously 

disclosed medical records. But the fact that the newly produced records 

contained material differences, even if accurate, does not equate to prima 

facie evidence that they were forged or fraudulently altered, or that 

petitioners submitted the records with knowledge of their forged or 

fraudulent nature or sought counsel's services to enable them to commit a 

crime or fraud. Indeed, the evidentiary hearing was convened to determine 

what caused the differences in the productions and whether they occurred 

by accident or design, or technological failure. And, since the record 

contains no prima facie evidence that petitioners violated NRS 199.210, we 

agree that the district court erred in concluding the crime-fraud exception 

applied to waive attorney-client and work-product privileges. See Las Vegas 

Sands Corp. v. Eighth Judicial Dist. Court, 130 Nev. 643, 650, 331 P.3d 905, 

909-10 (2014) (reviewing privilege issues, which are "governed primarily by 

statute," de novo). 

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At-issue exception 

The "at-issue" doctrine provides "that a party waives his 

privilege if he affirmatively pleads a claim or defense that places at-issue 

the subject matter of privileged material over which he has control." 

Wardleigh v. Second Judicial Dist. Court, 111 Nev. 345, 354, 891 P.2d 1180, 

1186 (1995) (quoting Developments in the Law-Privileged Communications, 

98 Harv. L. Rev. 1450, 1637 (1985)). The "waiver occurs when the holder of 

the privilege pleads a claim or defense in such a way that eventually he or 

she will be forced to draw upon the privileged communication at trial in 

order to prevail." Id. at 355, 891 P.2d at 1186. But here, CHH pleaded no 

claim or defense to trial issues that would require the disclosure of 

privileged information. Rather, the crux of the at-issue waiver found by the 

district court was based on CHH's defense to Bellavance's discovery 

sanctions motion, not on its defense to a substantive trial issue. As such, 

Wardleigh's at-issue doctrine does not apply to waive the privileges in this 

case.3 See id.; see also Laser Indus., Ltd. v. Reliant Tech., Inc., 167 F.R.D. 

417, 446 (N.D. Cal. 1996) (recognizing that courts are unlikely to find atissue waiver when the statements purported to constitute waiver address 

matters outside of trial issues); Am. Optical Corp. v. Medtronic, Inc., 56 

3Furthermore, while the district court noted the differences between 

attorney-client and work-product privileges, when concluding that the 

crime-fraud and at-issue exceptions applied to waive the privileges it did 

not distinguish between them. See Cotter v. Eighth Judicial Dist. Court, 

134 Nev. 247, 250, 416 P.3d 228, 232 (2018) (discussing the differences 

between attorney-client privilege, which "protect[s] the confidential 

relationship between attorney and client," and work-product privilege, 

which "protects an attorn.ey's mental impressions, conclusions, or legal 

theories concerning the litigation, as reflected in memoranda, 

correspondence, interviews, briefs, or in other tangible and intangible ways" 

(quoting Wardleigh, 111 Nev. at 357, 891 P.2d at 1188)). 

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F.R.D. 426, 432 (refusing to find at-issue waiver in part because the 

challenged statements did not pertain to trial evidence, but to pre-trial 

matters); 98 C.J.S. Witnesses § 300 (2022) (stating the exception applies 

when a party "assert[s] a claim or defense by reference to otherwise 

privileged information"). Based on the foregoing, writ relief is warranted to 

vacate the district court's order refusing to quash the subpoenas for Bundick 

and his assistant based on waiver of the attorney-client and work-product 

privileges.4 

Rules of Professional Conduct violations 

Both of the challenged orders include findings that the district 

court admonished Bundick and CHH's other counsel for violating RPC 3.3 

(candor to the court) and RPC 3.4 (fairness to the opposing party and 

opposing counsel) on the first day of the evidentiary hearing. This was 

based on the court's finding that Bundick made misrepresentations 

regarding when Bundick became involved in the case and the disclosure of 

CHH insurance policies in other cases. Such findings amount to 

reputational sanctions. See Valley Health, 134 Nev. at 643-44, 427 P.3d at 

1030. Bellavance contends the district court properly admonished the 

attorneys while petitioners argue that the evidence does not support the 

court's findings. The record before us supports petitioners. The district 

court made these findings before taking all the evidence relevant to its 

decision such that we cannot conclude that substantial evidence supports 

the sanctions at this point in the proceedings. See id. at 639, 427 P.3d at 

4This is not to say that the crime-fraud or at-issue exceptions could 

not be found to apply after the district court concludes its evidentiary 

hearing on the sanctions motion below. Indeed, the writ petition before us 

and the stay that followed interrupted the district court's taking of evidence 

on those issues. 

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1027 ("Non-case-concluding sanctions will be upheld if the district court's 

sanction order is supported by substantial evidence."). Moreover, we are 

not convinced that Bundick's misstatements were material, especially 

considering his later correction of them both orally and by affidavit to the 

court, in compliance with the obligation stated in RPC 3.3(a)(1). 

Accordingly, we also grant writ relief as to this issue. 

Sheffield and UHS of Delaware 

Petitioners next argue that the district court erred in including 

Sheffield and UHS in its orders as parties to be sanctioned. We agree. Both 

orders purport to consider sanctions against VHS, which is defined to 

include Sheffield and UHS, in addition to CHH. But Bellavance's motion 

did not seek sanctions against Sheffield or UHS; instead, Bellavance sought 

sanctions only against VHS doing business as CHH. Although Bellavance 

is correct that the district court later granted a motion for leave to file an 

amended complaint adding UHS as a party, that does not change the fact 

that UHS and Sheffield neither received notice that sanctions could be 

entered against them nor had an opportunity to oppose such sanctions, 

violating their due process rights. See Callie v. Bowling, 123 Nev. 181, 183, 

160 P.3d 878, 879 (2007) (This court has recognized that procedural due 

process requires notice and an opportunity to be heard." (internal quotation 

marks omitted)). We therefore grant writ relief as to this issue as well. 

Reassignment 

In their final request, petitioners ask this court to direct the 

chief judge to reassign this case to a different district judge pursuant to NRS 

3.025(2)(a). Wickliffe v. Sunrise Hosp., Inc., 104 Nev. 777, 783, 766 P.2d 

1322, 1326-27 (1988) (directing reassignment of case to different judge on 

remand, citing Nev. Const. art. 6, § 19(1)); California v. Montrose Chem. 

Corp., 104 F.3d 1507, 1521 (9th Cir. 1997) (holding that, in evaluating a 

10 

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request for reassignment on remand, an appellate court considers "(1) 

whether the original judge would reasonably be expected upon remand to 

have substantial difficulty in putting out of his or her mind previouslyexpressed views or findings determined to be erroneous or based on 

evidence that must be rejected, (2) whether reassignment is advisable to 

preserve the appearance of justice, and (3) whether reassignment would 

entail waste and duplication out of proportion to any gain in preserving the 

appearance of fairnese (quoting Smith v. Mulvaney, 827 F.2d 558, 562-63 

(9th Cir. 1987) (citation omitted))). 

Petitioners did not seek recusal or disqualification below, and 

Bellavance has not responded to the reassignment request. An order 

directing reassignment by an appellate court without a disqualification 

motion in district court is rare "but occasionally warranted, even in the 

absence of bias, to avoid an appearance of partiality." United States v. New 

York City, 717 F.3d 72, 99 (2d Cir. 2013); compare Canarelli v. Eighth 

Judicial Dist. Court, 138 Nev., Adv. Op. 12, 506 P.3d 334, 339 (2022) 

(reversing an order granting a motion to disqualify for actual bias where the 

record did not establish that the district court had "form[ed] an opinion that 

'display [ed] "a deep-seated favoritism or antagonism that would make fair 

judgment impossible"' (quoting Kirksey v. State, 112 Nev. 980, 1007, 923 

P.2d 1102, 1119 (1996) and Liteky v. United States, 510 U.S. 540, 555 

(1994))), with Aparicio v. State, 137 Nev., Adv. Op. 62, 496 P.3d 592, 597 

(2021) (reassigning a case to a different district court judge on remand for 

resentencing where the judge erred in considering the impact of statements 

from friends and non-immediate family members of the victim); FCH1, LLC 

v. Rodriguez, 130 Nev. 425, 435, 335 P.3d 183, 190 (2014) (granting 

appellant's request that, on remand, the case be reassigned to a different 

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district judge); Leven v. Wheatherstone Condo. Corp., 106 Nev. 307, 310, 791 

P.2d 450, 451 (1990) (similar).5 

We conclude that reassignment is warranted. The district court 

set an evidentiary hearing to resolve factual issues related to Bellavance's 

sanctions motion based on CHH's alleged discovery abuses. These factual 

issues regarding the level of culpability of CHH included the electronic 

storage issues with respect to its medical record production, its delayed 

insurance disclosures, and the issues of when Bundick became involved in 

the case and whether CHH failed to disclose relevant insurance policies in 

other cases. But the record shows that, before taking evidence on these 

issues, the district court concluded that Bundick had misrepresented to the 

court both when he became involved in the case and that CHH's insurance 

disclosures in other cases would show that CHH generally complied with 

discovery rules. The court called these statements "false" and stated 

defense counsel was not "fully honese with the court or opposing counsel 

And, as to the privilege issues that arose during the evidentiary 

hearing, the district court again concluded, before the parties presented all 

their evidence regarding the circumstances surrounding the incomplete and 

inconsistent document productions, that the crime-fraud exception applied. 

It thus implicated CHH and its counsel in felonious activity without proper 

evidentiary support. Going further, when petitioners asked the court to 

5We reject as inconsistent with Aparicio, Wickliffe, FCH1, and Leven 

the suggestion in the unpublished order in Sands China Ltd. v. Eighth 

Judicial District Court, Nos. 68265, 68275, 68309, 2015 WL 6829520, *3 

(Nev. Nov. 4, 2015) (Order Granting in Part and Denying in Part Petition 

for Writ Relief (Docket No. 68265), Granting Petition for Writ Relief (Docket 

No. 68275), and Denying Petition for Writ Relief (Docket No. 68309)), that 

this court's power to direct reassignment requires an affidavit or motion 

under NRS 1.235 or NCJC Canon 2, Rule 2.11. 

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clarify the basis for its conclusion that the crime-fraud exception applied at 

the hearing, the court declined to explain what crime or fraud it based its 

decision on or otherwise explain its ruling and instead instructed 

Bellavance to prepare a written order. Ultimately, the district court signed 

the order Bellavance prepared without changes, finding a violation of NRS 

199.210 although that criminal statute had never been mentioned in any of 

the parties arguments or the court's oral ruling. 

These conclusory findings and prernature legal conclusions 

strongly suggest that the court would have "substantial difficulty" putting 

aside her "previously-expressed views or findings" if she were to continue 

presiding over this case. Montrose Chem., 104 F.3d at 1521. They also 

support that reassignment is needed to preserve the appearance of justice. 

Id.; see Ybarra v. State, 127 Nev. 47, 51, 247 P.3d 269, 272 (2011) (citing 

Suh v. Pierce, 630 F.3d 685, 691-92 (7th Cir. 2011), for the proposition that 

"due process requires [a] fair trial in [a] fair tribunar). Last, we recognize 

that reassignment will require the duplication of proceedings as to 

sanctions, however, substantive motion practice and final pretrial 

proceedings have yet to occur. Thus, we conclude that reassignment will 

not "entail waste and duplication out of proportion to any gain in preserving 

the appearance of fairness." Montrose Chem., 104 F.3d at 1521; Aparicio, 

137 Nev., Adv. Op. 62, 496 P.3d at 597 (reassigning for resentencing); 

FCH1, 130 Nev. at 435, 335 P.3d at 190 (reassigning a civil case on remand); 

Echeverria v. State, 119 Nev. 41, 44, 62 P.3d 743, 745-46 (2003) (reassigning 

a matter after vacating a sentence); Wickliffe, 104 Nev. at 783, 766 P.2d at 

1326-27 (reassigning on remand to avoid an appearance of partiality). 

CONCLUSION 

In summary, we conclude that the district court erred in 

applying the crime-fraud and at-issue exceptions to find petitioners waived 

13 
attorney-client and work-product privileges, that its finding of RPC 

violations by CHifs counsel are not supported by substantial evidence in 

the record before us, and that it erred in including Sheffield and UHS in the 

orders that are the subject of this writ petition.6Accordingly, we grant the 

petition. The clerk of this court shall issue a writ of mandamus instructing 

the district court to vacate its "Order Granting in Part and Denying in Part 

Defendant[s] Motion for Clarification and Reconsideration of the Scope of 

the February 8th Evidentiary Hearing and its "Order Denying Non-Party 

Greenberg Traurig, LLP's Motion to Quash Subpoenas."7We further direct 

the district court to request that the chief judge reassign this matter to a 

different department.8Finally, consistent with this decision, we lift the 

temporary stay entered by this court on March 7, 2022 

It is so ORDERED. 

, 

J. 

Hardesty 

(

iA P , J. 

Cadish Pickering 

8These conclusions are not a comment on the merits of Bellavance's 

motion for sanctions. That motion will still need to be resolved following 

reassignment. 

7As petitioners do not challenge that part of the district court's order 

requiring CHH to produce insurance disclosures frorn its other Nevada 

cases, we do not vacate that portion of the "Order Granting in Part and 

Denying in Part Defendant[s] Motion for Clarification and Reconsideration 

of the Scope of the February 8th Evidentiary Hearing," 

8We decline Bellavance's request that we withdraw our previous writ 

regarding attorney Joseph Farchione's pro hac vice admission. 

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• •••1,--7< 

• . . 

:••._ ..:17 4:44: ';'z • 
cc: Hon. Nadia Kra11, District Judge 

John H. Cotton & Associates, Ltd. 

Weinberg, Wheeler, Hudgins, Gunn & Dial, LLC/Las Vegas 

Lipson Neilson P.C. 

Greenberg Traurig, LLP/Las Vegas 

Peterson Baker, PLLC 

The Gage Law Firm, PLLC 

Claggett & Sykes Law Firm 

Eighth District Court Clerk 

15 

.„ "