United States District Court, D. Nevada
DIANE F. KROLL, Plaintiff,
STATE FARM MUTUAL AUTOMOBILE INSURANCE COMPANY; DOES I through X; and ROE CORPORATIONS I through X, inclusive, Defendants.
L. DENNETT, ESQ. Nevada Bar No. 005617
DENNETT WINSPEAR, LLP Attorneys for State Farm Mutual
Automobile Insurance Company
L. AMICK, ESQ. Nevada Bar No. 5204 Attorney for Plaintiff,
DIANE F. KROLL
MATTHEW J. WAGNER, ESQ. Nevada Bar No. 11311 Attorneys for
Defendant, STATE FARM MUTUAL AUTOMOBILE INSURANCE COMPANY
STIPULATION AND ORDER TO EXTEND DISCOVERY FOR
PURPOSES OF COMPLETING THE DEPOSITION OF PLAINTIFF'S
TREATING PHYSICIAN (SECOND REQUEST - LIMITED EXTENSION
DIANE F. KROLL, by and through her attorney, ROBERT L. AMICK,
ESQ. of the AMICK LAW OFFICE and STATE FARM MUTUAL AUTOMOBILE
INSURANCE COMPANY, by and through its attorneys, RYAN L.
DENNETT, ESQ. and MATTHEW J. WAGNER, ESQ., of the law firm of
DENNETT WINSEAR, LLP, submit this STIPULATION AND ORDER TO
EXTEND DISCOVERY FOR PURPOSES OF COMPLETING THE DEPOSITION OF
PLAINTIFF'S TREATING PHYSICIAN (Second Request - Limited
extension only) pursuant to Rules 6(b) and 26(f) of the
Federal Rules of Civil Procedure and Local Rule 6-1 and 26-4
for the Court's consideration:
COMPLETED TO DATE
26(f) Conference was held and a Discovery Plan and Scheduling
Order was filed. The Court denied the parties' mutual
request for 260 days to conduct discovery based on
“good cause” for requesting a special scheduling
review and ordered a standard 180-day plan consistent with LR
Plaintiff served her Witness and Document list on May 15,
2019, outlining ten (10) medical providers with medical
specials totaling $364, 661.72. Additionally, Plaintiff
disclosed economic damages per a Report by Terrance M.
Dinneen for past and future vocational losses alleged to be
caused by the subject accident in the total sum of $271,
Defendant served its Witness and Document list on May 22,
2019, containing documentary evidence regarding the claim of
the Plaintiff, along with various authorizations to be
executed by the Plaintiff in order to obtain medical records
and bills, as well as insurance documentation, worker comp
records and employment information.
Defendant served written discovery on Plaintiff on June 6,
2019, consisting of interrogatories, requests for production
of documents, and requests for admission related to the
breach of contract, common law bad faith, and statutory bad
faith claims. Those discovery requests have been responded
Plaintiff served written discovery on Defendant on August 15,
2019 and granted Defendant an extension on September 9, 2019
to respond to the same by September 30, 2019.
Plaintiff's deposition was completed on August 19, 2019.
Plaintiff served her expert ...