1 WRIGHT, FINLAY & ZAK, LLP Darren T. Brenner, Esq. 2 Nevada Bar No. 8386 Stephanie A. Garabedian, Esq. 3 Nevada Bar No. 9612 4 7785 W. Sahara Ave., Suite 200 Las Vegas, NV 89117 5 (949)477-5050; Fax: (702) 946-1345 6 dbrenner@wrightlegal.net sgarabedian@wrightlegal.net 7 Attorneys for Defendant, Hartford Insurance Company of the Midwest 8 9 DAVID R. SIDRAN, ESQ. Nevada Bar No. 7517 10 SIDRAN LAW CORP 7251 West Lake Mead Boulevard, Suite 300 11 Las Vegas, Nevada 89128 12 Phone/Facsimile: (702) 551-2015 dsidran@sidranlaw.com 13 eservice@sidranlaw.com Attorneys for Plaintiff, 14 Leslie R. Bakke 15 16 UNITED STATES DISTRICT COURT 17 DISTRICT OF NEVADA 18 19 LESLIE R. BAKKE, an individual, ROBERT Case No.: 2:23-cv-01098-GMN-EJY 20 HANBLEN, an individual STIPULATION AND ORDER TO 21 Plaintiff, EXTEND THE CLOSE OF v. DISCOVERY, DISPOSITIVE 22 MOTIONS DEADLINE, AND JOINT HARTFORD INSURANCE COMPANY OF PRETRIAL ORDER DEADLINE 23 THE MIDWEST, Does 1 through 10, inclusive, 24 Defendant. SIXTH REQUEST 25 26 27 IT IS HEREBY STIPULATED AND AGREED, by and between Plaintiff Leslie R. 28 Bakke, through her counsel of record, the law firm of Sidran Law Corp and Defendant 1 Hartford Insurance Company of the Midwest, through its counsel of record, the law firm of 2 WRIGHT, FINLAY & ZAK, LLP, that the discovery deadlines in this matter shall be 3 extended ninety (90) days pursuant to LR 26-3. This is the Parties’ sixth request for an 4 extension of the discovery deadlines. The Parties set forth the following information in 5 support of their stipulation. 6 I. 7 DISCOVERY COMPLETED TO DATE 8 A.FRCP 26(a) Disclosures and Supplements 9 Title Date Served Plaintiff’s Initial Disclosure of Documents and Witnesses Pursuant to September 28, 2023 10 FRCP 26(a)(1) 11 Hartford Insurance Company of the Midwest’s Initial Disclosure of September 14, 2023 Witnesses and Documents Pursuant to FED. R. CIV. P. RULE 26.1(a)(1) 12 Hartford Insurance Company of the Midwest’s First Supplemental January 30, 2024 13 Disclosure of Witnesses and Documents Pursuant to FED. R. CIV. P. RULE 26.1(a)(1) 14 Hartford Insurance Company of the Midwest’s Second Supplemental May 23, 2024 Disclosure of Witnesses and Documents Pursuant to FED. R. CIV. P. 15 RULE 26.1(a)(1) 16 Hartford Insurance Company of the Midwest’s Third Supplemental September 11, 2024 Disclosure of Witnesses and Documents Pursuant to FED. R. CIV. P. 17 RULE 26.1(a)(1) Hartford Insurance Company of the Midwest’s Fourth Supplemental November 15, 2024 18 Disclosure of Witnesses and Documents Pursuant to FED. R. CIV. P. 19 RULE 26.1(a)(1) Hartford Insurance Company of the Midwest’s Fifth Supplemental November 7, 2024 20 Disclosure of Witnesses and Documents Pursuant to FED. R. CIV. P. 21 RULE 26.1(a)(1) Hartford Insurance Company of the Midwest’s Initial Disclosure of November 8, 2024 22 Expert Witnesses Plaintiff Leslie Bakke’s Initial Disclosure of Expert Witnesses November 8, 2024 23 Hartford Insurance Company of the Midwest’s Rebuttal Expert December 18, 2024 24 Witnesses and Reports Plaintiff Leslie Bakke’s Rebuttal Disclosure of Expert Witnesses December 20, 2024 25 Hartford Insurance Company of the Midwest’s Sixth Supplemental January 29, 2025 26 Disclosure of Witnesses and Documents Pursuant to FED. R. CIV. P. RULE 26.1(a)(1) 27 Plaintiff’s First Supplemental Disclosure of Documents and Witnesses February 21, 2025 Pursuant to FRCP 26(a)(1) 28 Plaintiff’s Second Supplemental Disclosure of Documents and March 3, 2025 Witnesses Pursuant to FRCP 26(a)(1) 1 2 B. Written Discovery 3 Title Date Served 4 Hartford Insurance Company of the Midwest’s First Set of October 6, 2023 Interrogatories to Plaintiff 5 Hartford Insurance Company of the Midwest’s First Set of Requests October 6, 2023 6 for Admissions to Plaintiff Hartford Insurance Company of the Midwest’s First Set of Requests October 6, 2023 7 for Production of Documents to Plaintiff Plaintiff’s Responses to Hartford Insurance Company of the Midwest’s December 22, 2023 8 First Set of Requests for Production of Documents to Plaintiff 9 Plaintiff’s Responses to Hartford Insurance Company of the Midwest’s December 22, 2023 First Set of Requests for Admissions to Plaintiff 10 Plaintiff’s Responses to Hartford Insurance Company of the Midwest’s December 22, 2023 First Set of Interrogatories to Plaintiff 11 Plaintiff’s First Set of Requests for Production of Documents to August 26, 2024 12 Defendant Plaintiff’s First Set of Requests for Admissions to Defendant August 26, 2024 13 Plaintiff’s First Set of Interrogatories to Defendant August 26, 2024 14 Defendant’s Response to Plaintiff’s First Set of Requests for October 15, 2024 Production of Documents to Defendant 15 Defendant’s Response to Plaintiff’s First Set of Requests for October 15, 2024 Admissions to Defendant 16 Defendant’s Response to Plaintiff’s First Set of Interrogatories to October 15, 2024 17 Defendant Defendant’s Second Set of Requests for Admissions to Plaintiff November 20, 2024 18 Defendant’s Second Set of Interrogatories to Plaintiff November 20, 2024 19 Defendant’s Third Set of Requests for Admissions to Plaintiff December 5, 2024 Defendant’s Third Set of Interrogatories to Plaintiff December 5, 2024 20 Bakke’s Responses to Defendant’s Second Set of Requests for January 10, 2025 Admissions 21 Bakke’s Responses to Defendant’s Third Set of Interrogatories January 10, 2025 22 Bakke’s Responses to Defendant’s Third Set of Requests for January 10, 2025 Production of Documents 23 24 C.Depositions 25 Deponent Date Plaintiff Leslie Bakke January 31, 2024 26 Robert Hamblen January 27, 2025 27 Hartford employee Michelle Burruel January 30, 2025 Hartford employee Will Shade January 31, 2025 28 1 2 D.Subpoenas Issued Subpoena Date 3 Stanford Healthcare January 4, 2024 4 5 E. Expert Disclosure 6 Initial Expert Disclosure Date Both Sides Served Initial Expert Disclosures November 8, 2024 7 Hartford Insurance Company of the Midwest’s Rebuttal Expert December 18, 2024 Witnesses and Reports 8 Plaintiff Leslie Bakke’s Rebuttal Disclosure of Expert Witnesses December 20, 2024 9 Plaintiff’s First Supplemental Disclosure of Documents and Witnesses February 21, 2025 Pursuant to FRCP 26(a)(1) 10 11 II. 12 DISCOVERY TO BE COMPLETED 13 1. Plaintiff will take the deposition of the FRCP 30(b)(6) witness for Defendant. 14 15 2. Plaintiff will take the deposition of Defendant’s medical expert, Dr. Fish. 16 3. Plaintiff will take the deposition of Defendant’s liability expert, Mr. Titus 17 4. Defendant will take the deposition of Plaintiff’s medical expert, Dr. Oliveri. 18 5. Defendant will take the deposition of Plaintiff’s liability expert, Mr. Zalma. 19 6. Defendant will take the deposition of Plaintiff’s treating physicians. 20 7. The parties will engage in additional written discovery and notice any 21 additional depositions. 22 The parties anticipate that they may need to conduct other forms of discovery not 23 specifically delineated herein on an as-needed basis. Therefore, the list outlined above is in no 24 way intended to be a comprehensive list of the outstanding discovery that remains to be 25 completed. 26 27 28 1 III. REASONS DISCOVERY WAS NOT COMPLETED WITHIN THE TIME LIMITS 2 AND NEEDS TO BE EXTENDED 3 “[D]istrict courts . . . retain broad discretion to control their dockets . . . .” Shahrokhi v. 4 Harter, No. 2:21-cv-01126-RFB-NJK, 2021 U.S. Dist.
Free access — add to your briefcase to read the full text and ask questions with AI
1 WRIGHT, FINLAY & ZAK, LLP Darren T. Brenner, Esq. 2 Nevada Bar No. 8386 Stephanie A. Garabedian, Esq. 3 Nevada Bar No. 9612 4 7785 W. Sahara Ave., Suite 200 Las Vegas, NV 89117 5 (949)477-5050; Fax: (702) 946-1345 6 dbrenner@wrightlegal.net sgarabedian@wrightlegal.net 7 Attorneys for Defendant, Hartford Insurance Company of the Midwest 8 9 DAVID R. SIDRAN, ESQ. Nevada Bar No. 7517 10 SIDRAN LAW CORP 7251 West Lake Mead Boulevard, Suite 300 11 Las Vegas, Nevada 89128 12 Phone/Facsimile: (702) 551-2015 dsidran@sidranlaw.com 13 eservice@sidranlaw.com Attorneys for Plaintiff, 14 Leslie R. Bakke 15 16 UNITED STATES DISTRICT COURT 17 DISTRICT OF NEVADA 18 19 LESLIE R. BAKKE, an individual, ROBERT Case No.: 2:23-cv-01098-GMN-EJY 20 HANBLEN, an individual STIPULATION AND ORDER TO 21 Plaintiff, EXTEND THE CLOSE OF v. DISCOVERY, DISPOSITIVE 22 MOTIONS DEADLINE, AND JOINT HARTFORD INSURANCE COMPANY OF PRETRIAL ORDER DEADLINE 23 THE MIDWEST, Does 1 through 10, inclusive, 24 Defendant. SIXTH REQUEST 25 26 27 IT IS HEREBY STIPULATED AND AGREED, by and between Plaintiff Leslie R. 28 Bakke, through her counsel of record, the law firm of Sidran Law Corp and Defendant 1 Hartford Insurance Company of the Midwest, through its counsel of record, the law firm of 2 WRIGHT, FINLAY & ZAK, LLP, that the discovery deadlines in this matter shall be 3 extended ninety (90) days pursuant to LR 26-3. This is the Parties’ sixth request for an 4 extension of the discovery deadlines. The Parties set forth the following information in 5 support of their stipulation. 6 I. 7 DISCOVERY COMPLETED TO DATE 8 A.FRCP 26(a) Disclosures and Supplements 9 Title Date Served Plaintiff’s Initial Disclosure of Documents and Witnesses Pursuant to September 28, 2023 10 FRCP 26(a)(1) 11 Hartford Insurance Company of the Midwest’s Initial Disclosure of September 14, 2023 Witnesses and Documents Pursuant to FED. R. CIV. P. RULE 26.1(a)(1) 12 Hartford Insurance Company of the Midwest’s First Supplemental January 30, 2024 13 Disclosure of Witnesses and Documents Pursuant to FED. R. CIV. P. RULE 26.1(a)(1) 14 Hartford Insurance Company of the Midwest’s Second Supplemental May 23, 2024 Disclosure of Witnesses and Documents Pursuant to FED. R. CIV. P. 15 RULE 26.1(a)(1) 16 Hartford Insurance Company of the Midwest’s Third Supplemental September 11, 2024 Disclosure of Witnesses and Documents Pursuant to FED. R. CIV. P. 17 RULE 26.1(a)(1) Hartford Insurance Company of the Midwest’s Fourth Supplemental November 15, 2024 18 Disclosure of Witnesses and Documents Pursuant to FED. R. CIV. P. 19 RULE 26.1(a)(1) Hartford Insurance Company of the Midwest’s Fifth Supplemental November 7, 2024 20 Disclosure of Witnesses and Documents Pursuant to FED. R. CIV. P. 21 RULE 26.1(a)(1) Hartford Insurance Company of the Midwest’s Initial Disclosure of November 8, 2024 22 Expert Witnesses Plaintiff Leslie Bakke’s Initial Disclosure of Expert Witnesses November 8, 2024 23 Hartford Insurance Company of the Midwest’s Rebuttal Expert December 18, 2024 24 Witnesses and Reports Plaintiff Leslie Bakke’s Rebuttal Disclosure of Expert Witnesses December 20, 2024 25 Hartford Insurance Company of the Midwest’s Sixth Supplemental January 29, 2025 26 Disclosure of Witnesses and Documents Pursuant to FED. R. CIV. P. RULE 26.1(a)(1) 27 Plaintiff’s First Supplemental Disclosure of Documents and Witnesses February 21, 2025 Pursuant to FRCP 26(a)(1) 28 Plaintiff’s Second Supplemental Disclosure of Documents and March 3, 2025 Witnesses Pursuant to FRCP 26(a)(1) 1 2 B. Written Discovery 3 Title Date Served 4 Hartford Insurance Company of the Midwest’s First Set of October 6, 2023 Interrogatories to Plaintiff 5 Hartford Insurance Company of the Midwest’s First Set of Requests October 6, 2023 6 for Admissions to Plaintiff Hartford Insurance Company of the Midwest’s First Set of Requests October 6, 2023 7 for Production of Documents to Plaintiff Plaintiff’s Responses to Hartford Insurance Company of the Midwest’s December 22, 2023 8 First Set of Requests for Production of Documents to Plaintiff 9 Plaintiff’s Responses to Hartford Insurance Company of the Midwest’s December 22, 2023 First Set of Requests for Admissions to Plaintiff 10 Plaintiff’s Responses to Hartford Insurance Company of the Midwest’s December 22, 2023 First Set of Interrogatories to Plaintiff 11 Plaintiff’s First Set of Requests for Production of Documents to August 26, 2024 12 Defendant Plaintiff’s First Set of Requests for Admissions to Defendant August 26, 2024 13 Plaintiff’s First Set of Interrogatories to Defendant August 26, 2024 14 Defendant’s Response to Plaintiff’s First Set of Requests for October 15, 2024 Production of Documents to Defendant 15 Defendant’s Response to Plaintiff’s First Set of Requests for October 15, 2024 Admissions to Defendant 16 Defendant’s Response to Plaintiff’s First Set of Interrogatories to October 15, 2024 17 Defendant Defendant’s Second Set of Requests for Admissions to Plaintiff November 20, 2024 18 Defendant’s Second Set of Interrogatories to Plaintiff November 20, 2024 19 Defendant’s Third Set of Requests for Admissions to Plaintiff December 5, 2024 Defendant’s Third Set of Interrogatories to Plaintiff December 5, 2024 20 Bakke’s Responses to Defendant’s Second Set of Requests for January 10, 2025 Admissions 21 Bakke’s Responses to Defendant’s Third Set of Interrogatories January 10, 2025 22 Bakke’s Responses to Defendant’s Third Set of Requests for January 10, 2025 Production of Documents 23 24 C.Depositions 25 Deponent Date Plaintiff Leslie Bakke January 31, 2024 26 Robert Hamblen January 27, 2025 27 Hartford employee Michelle Burruel January 30, 2025 Hartford employee Will Shade January 31, 2025 28 1 2 D.Subpoenas Issued Subpoena Date 3 Stanford Healthcare January 4, 2024 4 5 E. Expert Disclosure 6 Initial Expert Disclosure Date Both Sides Served Initial Expert Disclosures November 8, 2024 7 Hartford Insurance Company of the Midwest’s Rebuttal Expert December 18, 2024 Witnesses and Reports 8 Plaintiff Leslie Bakke’s Rebuttal Disclosure of Expert Witnesses December 20, 2024 9 Plaintiff’s First Supplemental Disclosure of Documents and Witnesses February 21, 2025 Pursuant to FRCP 26(a)(1) 10 11 II. 12 DISCOVERY TO BE COMPLETED 13 1. Plaintiff will take the deposition of the FRCP 30(b)(6) witness for Defendant. 14 15 2. Plaintiff will take the deposition of Defendant’s medical expert, Dr. Fish. 16 3. Plaintiff will take the deposition of Defendant’s liability expert, Mr. Titus 17 4. Defendant will take the deposition of Plaintiff’s medical expert, Dr. Oliveri. 18 5. Defendant will take the deposition of Plaintiff’s liability expert, Mr. Zalma. 19 6. Defendant will take the deposition of Plaintiff’s treating physicians. 20 7. The parties will engage in additional written discovery and notice any 21 additional depositions. 22 The parties anticipate that they may need to conduct other forms of discovery not 23 specifically delineated herein on an as-needed basis. Therefore, the list outlined above is in no 24 way intended to be a comprehensive list of the outstanding discovery that remains to be 25 completed. 26 27 28 1 III. REASONS DISCOVERY WAS NOT COMPLETED WITHIN THE TIME LIMITS 2 AND NEEDS TO BE EXTENDED 3 “[D]istrict courts . . . retain broad discretion to control their dockets . . . .” Shahrokhi v. 4 Harter, No. 2:21-cv-01126-RFB-NJK, 2021 U.S. Dist. LEXIS 247936, at *4 (D. Nev. Dec. 5 6 30, 2021). To prevail on a request to extend discovery deadlines, the parties must establish 7 good cause. Johnson v. Mammoth Recreations, Inc., 975 F.2d 604, 608-09 (9th Cir. 1992). 8 “Good cause to extend a discovery deadline exists if it cannot reasonably be met despite the 9 diligence of the party seeking the extension.” Las Vegas Skydiving Adventures LLC v. 10 Groupon, Inc., No. 2:18-cv-02342-APG-VCF, 2020 U.S. Dist. LEXIS 166073, at *6 (D. Nev. 11 Sep. 10, 2020) (internal quotations omitted). For the reasons set forth below, the parties 12 respectfully submit that good cause supports their request for an extension of the close of 13 discovery, dispositive motions deadline and joint pretrial order deadline. 14 The Court may note that no additional discovery has been completed since the Parties’ 15 fifth request for an extension of the discovery deadlines. However, the Parties have arranged 16 mediation with the Honorable Trevor Atkin (Ret.) for June 30, 2025. The dates available for 17 mediation were much later than the Parties anticipated, and the scheduled mediation will take 18 place only one week before discovery closes. The Parties want to conserve time and expenses 19 and devote resources to settling rather than the considerable costs of completing fact and 20 expert discovery. 21 An extension of the discovery deadlines will preserve the status quo, and will 22 minimize the expense of the Parties’ resources and those of the Court until the mediation 23 concludes. Mediterranean Enterprises, Inc. v. Ssangyong Corp., 708 F.2d 1458, 1465 (9th 24 Cir. 1983). Additionally, it will prevent the risk of the court needlessly expending its energies 25 26 to further manage the case when the case may well settle as a result of the parties' own accord 27 at the upcoming mediation. Sommers v. Cuddy, 2013 U.S. Dist. LEXIS 12430 (D.Nev. 2013). 28 1 Discovery should be extended as stipulated between the Parties to allow for a full and 2 complete effort to mediate this dispute. 3 In the event the Parties do not settle at mediation, the requested extension will allow 4 the Parties 90 days from the mediation date to schedule and conduct the depositions of expert 5 witnesses and treating physicians and complete any other discovery deemed necessary. 6 IV. 7 PROPOSED SCHEDULE FOR COMPLETING DISCOVERY 8 Current Date Proposed Date 9 Amend Pleadings and Add Parties: Closed Closed 10 Initial Expert Disclosures: Completed Completed 11 Rebuttal Expert Disclosures: Completed Completed 12 Close of Discovery: July 7, 2025 September 29, 2025 13 Dispositive Motions August 28, 2025 October 29, 2025 14 Joint Pretrial Order August 28, 2025 December 1, 2025 15 16 /// 17 /// 18 /// 19 /// 20 /// 21 /// 22 /// 23 /// 24 /// 25 /// 26 /// 27 /// 28 1 Based on the foregoing, the parties respectfully request this Court grant their 2 Stipulation and Order to Extend the Close of Discovery, Dispositive Motions Deadline, and 3 Joint Pretrial Order Deadline (Sixth Request). 4 DATED this 31st day of March, 2025. DATED this 31st day of March, 2025. 5 6 /s/ David R. Sidran /s/ Stephanie Garabedian DAVID R. SIDRAN, ESQ. STEPHANIE GARABEDIAN, ESQ. 7 Nevada Bar No. 7517 Nevada Bar No. 9612 8 SIDRAN LAW CORP WRIGHT, FINLAY & ZAK, LLP 7251 West Lake Mead Boulevard, #300 8337 West Sunset Rd., #220 9 Las Vegas, Nevada 89128 Las Vegas, NV 89113 Attorney for Plaintiff, LESLIE R. BAKKE Attorney for Defendant HARTFORD 10 INSURANCE COMPANY OF THE 11 MIDWEST 12 ORDER 13 IT IS SO ORDERED. 14 Dated this 31st day of March, 2025. 15 ___________________________________ UNITED STATES MAGISTRATE JUDGE 16 17 18 19 20 21 22 23 24 25 26 27 28