RulesofCivilProcedure.com Civil Procedure · Every State

Rule 80.Transcript or recording of testimony as evidence

Group X: District Courts and Clerks · Last amended March 1, 2019 · Last verified July 14, 2026

In one sentenceRule 80 explains how a party can prove up recorded or reported testimony from an earlier hearing or trial so it can be used again at a later trial, through a certified transcript or a certified audio or video recording.

Full Text of Rule 80

Text sizeJump to: (a) (b)

If recorded or stenographically reported testimony at a hearing or trial is admissible in evidence at a later trial, the testimony may be proved by:
(a) a transcript certified by the person who stenographically reported it; or
(b) an audio or audiovisual recording certified by the court in which the recording was made.

Notes

Advisory Committee Note — 2019 Amendment: The amendments to Rule 80(a) retain former NRCP 80(c)’s provision for stenographic transcripts and add Rule 80(b) to govern audio or audiovisual recordings made by the court. The judge or any court employee who operates the recording equipment (e.g., the court clerk, judicial assistant, law clerk, recorder, bailiff, or any other employee) may make the certification required by “the court” in Rule 80(b). Nevada’s law of evidence governs the admissibility of a transcript of a certified recording.

Amendment History

Amended eff. 3-1-19.

Plain-English Summary

Testimony given once doesn't have to be given again to be used a second time. If a hearing or trial produced a stenographic transcript or a court recording, and that testimony is otherwise admissible in a later trial, Rule 80 sets out the mechanics for putting it before the new fact-finder: a transcript certified by the stenographer who reported it, or an audio or video recording certified by the court where it was made.

The rule only handles the how, not the whether. It doesn't decide on its own that old testimony can come in at a new trial — Nevada's evidence law still governs admissibility, covering questions like hearsay exceptions or a witness's unavailability. Once those hurdles are cleared, Rule 80 tells you what form of proof — a certified transcript or a certified recording — will satisfy the court that the testimony is what it's claimed to be.

Frequently Asked Questions

Can I use a witness's testimony from an earlier hearing at the trial itself?

Only if the testimony is admissible under Nevada's rules of evidence. Rule 80 then tells you how to prove it up — through a certified transcript or a certified recording — once admissibility is established.

Who can certify a transcript of earlier testimony?

The person who stenographically reported the original hearing or trial certifies the transcript.

What if the earlier proceeding was recorded rather than reported by a stenographer?

Rule 80(b) covers that situation: the court where the recording was made certifies the audio or audiovisual recording, and any court employee who operated the equipment — a clerk, judicial assistant, law clerk, recorder, or bailiff — can provide that certification.

Does a certified recording carry the same weight as a certified transcript?

Rule 80 treats both as acceptable ways of proving the earlier testimony; which one applies depends on how the original proceeding was preserved.

Does Rule 80 decide whether hearsay objections apply to the old testimony?

No. Rule 80 addresses proof of the testimony's content and authenticity, not whether it survives a hearsay or other evidentiary objection at the later trial.

Source & verification. Rule text, official Advisory Committee Notes, and amendment history are reproduced verbatim from the Nevada Rules of Civil Procedure, adopted by the Supreme Court of Nevada. Last verified July 14, 2026. · Official source
Also known as: using prior testimony at trial nevadacertified transcript prior hearingcertified recording nevada courtproving old testimony at new trialNRCP 80