Thomas Labs, LLC v. Dukes

Summary

The Nevada Supreme Court reversed the district court’s dismissal and remanded, holding that a decedent’s attorney must serve a notice of death on non‑party successors or representatives to trigger the 180‑day substitution deadline under NRCP 25(a) and must file a substitution motion within 90 days under NRS 7.075. Because counsel failed to satisfy those duties, the deadline never began and the dismissal was improper.