PATRICIO BELLIZZI v. HILL (2020)

ORDER OF AFFIRMANCE

Respondents filed a demand for a change of venue, but the demand contained two typographical errors. Less than a month later, and before the demand and motion for a change of venue were heard, respondents filed an amended demand for a change of venue, which corrected the typographical errors. The district court granted the change of venue and appellants now appeal.

Respondents' demand for a change of venue was timely filed, see NRS 13.050(1)(a) (requiring a defendant seeking a change in venue to file a demand before the time to answer has expired), and preceded respondents’ motion for a change of venue, see Nevada Transit Co. v. Harris Brothers Lumber Co., 80 Nev. 465, 468-69, 396 P.2d 133, 134 (1964) (explaining that a motion for a change of venue does not meet the requirement that a written demand for a change of venue be filed). While the demand contained two typographical errors, those errors were quickly corrected. See Tunnicliff v. Holmes, 232 P. 148, 149 (Cal. Dist. Ct. App. 1924) (concluding that a typographical error in a demand for a change of venue did not defeat the demand). Thus, we conclude the district court did not err in granting the motion to change venue. Accordingly, we

ORDER the judgment of the district court AFFIRMED.