1 WRIGHT, FINLAY & ZAK, LLP Darren T. Brenner, Esq. 2 Nevada Bar No. 8386 Stephanie A. Garabedian, Esq. 3 Nevada Bar No. 9612 4 8337 W. Sunset Rd., Suite 220 Las Vegas, NV 89113 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. SEVENTH 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-one (91) days pursuant to LR 26-3. This is the Parties’ seventh 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) Hartford Insurance Company of the Midwest’s Initial Disclosure of September 14, 2023 11 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 Disclosure of Witnesses and Documents Pursuant to FED. R. CIV. P. 13 RULE 26.1(a)(1) Hartford Insurance Company of the Midwest’s Second Supplemental May 23, 2024 14 Disclosure of Witnesses and Documents Pursuant to FED. R. CIV. P. RULE 26.1(a)(1) 15 Hartford Insurance Company of the Midwest’s Third Supplemental September 11, 2024 16 Disclosure of Witnesses and Documents Pursuant to FED. R. CIV. P. RULE 26.1(a)(1) 17 Hartford Insurance Company of the Midwest’s Fourth Supplemental November 15, 2024 Disclosure of Witnesses and Documents Pursuant to FED. R. CIV. P. 18 RULE 26.1(a)(1) Hartford Insurance Company of the Midwest’s Fifth Supplemental November 7, 2024 19 Disclosure of Witnesses and Documents Pursuant to FED. R. CIV. P. RULE 26.1(a)(1) 20 Hartford Insurance Company of the Midwest’s Initial Disclosure of November 8, 2024 Expert Witnesses 21 Plaintiff Leslie Bakke’s Initial Disclosure of Expert Witnesses November 8, 2024 22 Hartford Insurance Company of the Midwest’s Rebuttal Expert December 18, 2024 Witnesses and Reports 23 Plaintiff Leslie Bakke’s Rebuttal Disclosure of Expert Witnesses December 20, 2024 Hartford Insurance Company of the Midwest’s Sixth Supplemental January 29, 2025 24 Disclosure of Witnesses and Documents Pursuant to FED. R. CIV. P. RULE 26.1(a)(1) 25 Plaintiff’s First Supplemental Disclosure of Documents and Witnesses February 21, 2025 Pursuant to FRCP 26(a)(1) 26 Plaintiff’s Second Supplemental Disclosure of Documents and March 3, 2025 27 Witnesses Pursuant to FRCP 26(a)(1) 28 1 B. Written Discovery Title Date Served 2 Hartford Insurance Company of the Midwest’s First Set of October 6, 2023 3 Interrogatories to Plaintiff Hartford Insurance Company of the Midwest’s First Set of Requests October 6, 2023 4 for Admissions to Plaintiff 5 Hartford Insurance Company of the Midwest’s First Set of Requests October 6, 2023 for Production of Documents to Plaintiff 6 Plaintiff’s Responses to Hartford Insurance Company of the Midwest’s December 22, 2023 First Set of Requests for Production of Documents to Plaintiff 7 Plaintiff’s Responses to Hartford Insurance Company of the Midwest’s December 22, 2023 8 First Set of Requests for Admissions to Plaintiff Plaintiff’s Responses to Hartford Insurance Company of the Midwest’s December 22, 2023 9 First Set of Interrogatories to Plaintiff Plaintiff’s First Set of Requests for Production of Documents to August 26, 2024 10 Defendant 11 Plaintiff’s First Set of Requests for Admissions to Defendant August 26, 2024 Plaintiff’s First Set of Interrogatories to Defendant August 26, 2024 12 Defendant’s Response to Plaintiff’s First Set of Requests for October 15, 2024 13 Production of Documents to Defendant Defendant’s Response to Plaintiff’s First Set of Requests for October 15, 2024 14 Admissions to Defendant Defendant’s Response to Plaintiff’s First Set of Interrogatories to October 15, 2024 15 Defendant 16 Defendant’s Second Set of Requests for Admissions to Plaintiff November 20, 2024 Defendant’s Second Set of Interrogatories to Plaintiff November 20, 2024 17 Defendant’s Third Set of Requests for Admissions to Plaintiff December 5, 2024 18 Defendant’s Third Set of Interrogatories to Plaintiff December 5, 2024 Bakke’s Responses to Defendant’s Second Set of Requests for January 10, 2025 19 Admissions Bakke’s Responses to Defendant’s Third Set of Interrogatories January 10, 2025 20 Bakke’s Responses to Defendant’s Third Set of Requests for January 10, 2025 21 Production of Documents 22 23 C.Depositions Deponent Date 24 Plaintiff Leslie Bakke January 31, 2024 Robert Hamblen January 27, 2025 25 Hartford employee Michelle Burruel January 30, 2025 26 Hartford employee Will Shade January 31, 2025 27 28 1 D.Subpoenas Issued Subpoena Date 2 Stanford Healthcare January 4, 2024 3 Chiropractic Physicians Board of Nevada May 1, 2025 Nevada Highway Patrol May 29, 2025 4 Elite Customs & Collision LLC May 31, 2025 5 Sudden Impact Auto Body Collision Repair, Inc. May 31, 2025 6 E. Expert Disclosure 7 Initial Expert Disclosure Date 8 Both Sides Served Initial Expert Disclosures November 8, 2024 Hartford Insurance Company of the Midwest’s Rebuttal Expert December 18, 2024 9 Witnesses and Reports 10 Plaintiff Leslie Bakke’s Rebuttal Disclosure of Expert Witnesses December 20, 2024 Plaintiff’s First Supplemental Disclosure of Documents and Witnesses February 21, 2025 11 Pursuant to FRCP 26(a)(1) 12 II. 13 DISCOVERY TO BE COMPLETED 14 1. Plaintiff will take the deposition of the FRCP 30(b)(6) witness for Defendant. 15 2. Plaintiff expects to take the depositions of at least four employees for 16 Defendant that worked on the subject claim. 17 3. Defendant will take the deposition of Plaintiff’s medical expert, Dr. Oliveri. 18 4. Defendant will take the deposition of Plaintiff’s liability expert, Mr. Zalma. 19 5. Defendant will take the deposition of Plaintiff’s treating physicians. 20 6. 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 25 way intended to be a comprehensive list of the outstanding discovery that remains to be 26 completed. 27 . . . 28 . . . 1 III.
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1 WRIGHT, FINLAY & ZAK, LLP Darren T. Brenner, Esq. 2 Nevada Bar No. 8386 Stephanie A. Garabedian, Esq. 3 Nevada Bar No. 9612 4 8337 W. Sunset Rd., Suite 220 Las Vegas, NV 89113 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. SEVENTH 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-one (91) days pursuant to LR 26-3. This is the Parties’ seventh 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) Hartford Insurance Company of the Midwest’s Initial Disclosure of September 14, 2023 11 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 Disclosure of Witnesses and Documents Pursuant to FED. R. CIV. P. 13 RULE 26.1(a)(1) Hartford Insurance Company of the Midwest’s Second Supplemental May 23, 2024 14 Disclosure of Witnesses and Documents Pursuant to FED. R. CIV. P. RULE 26.1(a)(1) 15 Hartford Insurance Company of the Midwest’s Third Supplemental September 11, 2024 16 Disclosure of Witnesses and Documents Pursuant to FED. R. CIV. P. RULE 26.1(a)(1) 17 Hartford Insurance Company of the Midwest’s Fourth Supplemental November 15, 2024 Disclosure of Witnesses and Documents Pursuant to FED. R. CIV. P. 18 RULE 26.1(a)(1) Hartford Insurance Company of the Midwest’s Fifth Supplemental November 7, 2024 19 Disclosure of Witnesses and Documents Pursuant to FED. R. CIV. P. RULE 26.1(a)(1) 20 Hartford Insurance Company of the Midwest’s Initial Disclosure of November 8, 2024 Expert Witnesses 21 Plaintiff Leslie Bakke’s Initial Disclosure of Expert Witnesses November 8, 2024 22 Hartford Insurance Company of the Midwest’s Rebuttal Expert December 18, 2024 Witnesses and Reports 23 Plaintiff Leslie Bakke’s Rebuttal Disclosure of Expert Witnesses December 20, 2024 Hartford Insurance Company of the Midwest’s Sixth Supplemental January 29, 2025 24 Disclosure of Witnesses and Documents Pursuant to FED. R. CIV. P. RULE 26.1(a)(1) 25 Plaintiff’s First Supplemental Disclosure of Documents and Witnesses February 21, 2025 Pursuant to FRCP 26(a)(1) 26 Plaintiff’s Second Supplemental Disclosure of Documents and March 3, 2025 27 Witnesses Pursuant to FRCP 26(a)(1) 28 1 B. Written Discovery Title Date Served 2 Hartford Insurance Company of the Midwest’s First Set of October 6, 2023 3 Interrogatories to Plaintiff Hartford Insurance Company of the Midwest’s First Set of Requests October 6, 2023 4 for Admissions to Plaintiff 5 Hartford Insurance Company of the Midwest’s First Set of Requests October 6, 2023 for Production of Documents to Plaintiff 6 Plaintiff’s Responses to Hartford Insurance Company of the Midwest’s December 22, 2023 First Set of Requests for Production of Documents to Plaintiff 7 Plaintiff’s Responses to Hartford Insurance Company of the Midwest’s December 22, 2023 8 First Set of Requests for Admissions to Plaintiff Plaintiff’s Responses to Hartford Insurance Company of the Midwest’s December 22, 2023 9 First Set of Interrogatories to Plaintiff Plaintiff’s First Set of Requests for Production of Documents to August 26, 2024 10 Defendant 11 Plaintiff’s First Set of Requests for Admissions to Defendant August 26, 2024 Plaintiff’s First Set of Interrogatories to Defendant August 26, 2024 12 Defendant’s Response to Plaintiff’s First Set of Requests for October 15, 2024 13 Production of Documents to Defendant Defendant’s Response to Plaintiff’s First Set of Requests for October 15, 2024 14 Admissions to Defendant Defendant’s Response to Plaintiff’s First Set of Interrogatories to October 15, 2024 15 Defendant 16 Defendant’s Second Set of Requests for Admissions to Plaintiff November 20, 2024 Defendant’s Second Set of Interrogatories to Plaintiff November 20, 2024 17 Defendant’s Third Set of Requests for Admissions to Plaintiff December 5, 2024 18 Defendant’s Third Set of Interrogatories to Plaintiff December 5, 2024 Bakke’s Responses to Defendant’s Second Set of Requests for January 10, 2025 19 Admissions Bakke’s Responses to Defendant’s Third Set of Interrogatories January 10, 2025 20 Bakke’s Responses to Defendant’s Third Set of Requests for January 10, 2025 21 Production of Documents 22 23 C.Depositions Deponent Date 24 Plaintiff Leslie Bakke January 31, 2024 Robert Hamblen January 27, 2025 25 Hartford employee Michelle Burruel January 30, 2025 26 Hartford employee Will Shade January 31, 2025 27 28 1 D.Subpoenas Issued Subpoena Date 2 Stanford Healthcare January 4, 2024 3 Chiropractic Physicians Board of Nevada May 1, 2025 Nevada Highway Patrol May 29, 2025 4 Elite Customs & Collision LLC May 31, 2025 5 Sudden Impact Auto Body Collision Repair, Inc. May 31, 2025 6 E. Expert Disclosure 7 Initial Expert Disclosure Date 8 Both Sides Served Initial Expert Disclosures November 8, 2024 Hartford Insurance Company of the Midwest’s Rebuttal Expert December 18, 2024 9 Witnesses and Reports 10 Plaintiff Leslie Bakke’s Rebuttal Disclosure of Expert Witnesses December 20, 2024 Plaintiff’s First Supplemental Disclosure of Documents and Witnesses February 21, 2025 11 Pursuant to FRCP 26(a)(1) 12 II. 13 DISCOVERY TO BE COMPLETED 14 1. Plaintiff will take the deposition of the FRCP 30(b)(6) witness for Defendant. 15 2. Plaintiff expects to take the depositions of at least four employees for 16 Defendant that worked on the subject claim. 17 3. Defendant will take the deposition of Plaintiff’s medical expert, Dr. Oliveri. 18 4. Defendant will take the deposition of Plaintiff’s liability expert, Mr. Zalma. 19 5. Defendant will take the deposition of Plaintiff’s treating physicians. 20 6. 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 25 way intended to be a comprehensive list of the outstanding discovery that remains to be 26 completed. 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 parties scheduled a June 30th 2025 mediation in March of 2025. During the time 15 period between March 2025 through June 2025, the parties postponed conducting expensive 16 discovery (ie, expert depositions, etc.) until after the mediation with hopes of resolving the 17 matter at the mediation without incurring additional significant discovery expenses this case 18 entails. The Parties attended mediation on June 30, 2025. While the parties remain hopeful 19 informal resolution is eventually achievable, the parties, having now gone through the 20 mediation and informal resolution process, recognize that settlement may not be attainable at 21 this time. 22 The extension requested herein allows the parties additional time to schedule and 23 conduct the proposed depositions of fact witnesses, expert witnesses and treating physicians, 24 of which there are at least eleven depositions to be held, as well as complete any other 25 26 discovery deemed necessary. Moreover, Hartford’s lead counsel, Darren Brenner, is moving 27 to another firm effective the week August 18, 2025. It is expected that Mr. Brenner’s new 28 firm will be substituting as counsel. While Mr. Brenner is familiar with the case, the parties 1 have generally agreed to push deposition discovery into September in order to allow for the 2 substitution a smooth transition while accommodating sensible scheduling. The parties 3 acknowledged and mindful of this Court’s instructions and intentions to keep discovery on a 4 steady pace going forward. The parties respectfully submit that their cooperation and mutual 5 desire to avoid expense of significant discovery until settlement could be explored, and the 6 fact that Mr. Brenner is moving firms, are an appropriate reasons to grant the requested 7 extension, 8 IV. 9 PROPOSED SCHEDULE FOR COMPLETING DISCOVERY 10 Current Date Proposed Date 11 Amend Pleadings and Add Parties: Closed Closed 12 Initial Expert Disclosures: Completed Completed 13 Rebuttal Expert Disclosures: Completed Completed 14 Close of Discovery: September 29, 2025 December 29, 2025 15 16 Dispositive Motions October 29, 2025 January 28, 2026 17 Joint Pretrial Order December 1, 2025 February 27, 2026 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 (Seventh Request). 4 DATED this 13th day of August, 2025. DATED this 13th day of August, 2025. 5 6 /s/ David R. Sidran /s/ Darren T. Brenner DAVID R. SIDRAN, ESQ. DARREN T. BRENNER, ESQ. 7 Nevada Bar No. 7517 Nevada Bar No. 8387 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; provided, however, no further extension of discovery will be 14 granted. 15 Dated this 13th day of August, 2025. 16 17 18 _______________________________________ UNITED STATES MAGISTRATE JUDGE 19 20 21 22 23 24 25 26 27 28