The Court determined that Nevada caselaw and NRCP 4(c) give conflicting opinions on whether an attorney or their employee can serve someone for their client. Moreover, the Court clarified that the purpose of the 2004 amendment to NRCP 4(c) was to mirror FRCP 4(c)(2) to interpret the exclusion of counsel as a “party.”
Bower, Darcy, "McGowen v. Second Jud. Dist. Ct., 134 Nev. Adv. Op. 89 (Nov. 21, 2018) (en banc)" (2018). Nevada Supreme Court Summaries. 1208.