1 ADAM J. BREEDEN, ESQ. Nevada Bar No. 008768 2 BREEDEN & ASSOCIATES, PLLC 7432 W. Sahara Ave., Suite 101 3 Las Vegas, Nevada 89117 Phone: (702) 819-7770 4 Fax: (702) 819-7771 [email protected] 5 Attorneys for Plaintiff 6 UNITED STATES DISTRICT COURT 7 DISTRICT OF NEVADA 8 GARY DEAN DILLMAN, an individual, CASE NO. 2:25-CV-00443-GMN-DJA 9 Plaintiff, STIPULATION AND ORDER TO 10 v. EXTEND DISCOVERY DEADLINES 11 STATE OF NEVADA on relation of the (FIRST REQUEST) NEVADA HIGHWAY PATROL; AARON 12 CRISP, in his individual capacity; DOES I-V, 13 inclusive, 14 Defendants. 15 The parties recently held a conference to discuss Defendant Aaron Crisp’s active military 16 leave on June 26, 2025. As a result of this leave, Defendant Crisp will be unavailable for deposition 17 until October 2025. The parties now submit a Stipulation to Extend Discovery Deadlines (First 18 Request) and request that the current deadlines be extended for 120 days from the deadlines 19 established in the Discovery Plan and Scheduling Order [ECF No. 10] filed April 10, 2025. The 20 extension is sought due to Defendant being on active military duty until the beginning of October. 21 I. DISCOVERY COMPLETED TO DATE 22 1. Plaintiff has served initial disclosures and one supplement, which includes nearly 300 pages 23 of documents and 11 witnesses; 24 2. Defendants State of Nevada on relation of the Nevada Highway Patrol and Aaron Crisp have 25 served their initial disclosure, which includes 65 pages of documents, 17 videos, and 4 26 witnesses; 27 1 3. Plaintiff propounded interrogatories and requests for documents on Defendant Aaron Crisp 2 and interrogatories, requests for documents, and requests for admission on State of Nevada 3 on relation of the Nevada Highway Patrol on April 18, 2025, to which Defendant responded 4 to the requests for admission on May 5, 2025 and the remaining responses were provided on 5 May 21, 2025. 6 4. Plaintiff has noticed the FRCP 30(b)(6) designee of Nevada Highway Patrol for July 16, 7 2025 and July 18, 2025. 8 II. DISCOVERY YET TO BE COMPLETED 9 1. Depositions of all parties and witnesses, including experts 10 2. Expert practice 11 3. Completion of any written discovery 12 III. REASONS WHY REMAINING DISCOVERY HAS NOT BEEN COMPLETED 13 As stated above, Defendant Aaron Crisp is currently on active military duty and is 14 unavailable for deposition until October 1, 2025. There is good cause for the requested extension. 15 IV. PROPOSED EXTENDED DEADLINES 16 The parties respectfully request this Court enter an order as follows: 17 1. Discovery Cut-Off Date. The new discovery cut-off date is January 13, 2026. 18 2. Amending the Pleadings and Adding Parties. The current deadline is June 17, 2025. The 19 parties do not request an extension of this deadline. 20 3. Expert and Rebuttal-Expert Disclosures. The new deadline to disclose experts is November 21 14, 2025. The deadline to disclose rebuttal experts is December 16, 2025. 22 4. Dispositive Motions. The new deadline to file dispositive motions is February 12, 2026. 23 5. Pretrial Order. The new deadline to file a pretrial order is March 16, 2026. If dispositive 24 motions are filed, the deadline for filing the joint pretrial order will be suspended until 30 25 days after the decision on the dispositive motions or further court order. 26 6. Extensions or Modifications of the Discovery Plan and Scheduling Order. In accordance 27 with LR 26-3, applications to extend any date set by the discovery plan, scheduling order, 1 showing of good cause for the extension. All motions or stipulations to extend a deadline set 2 forth in a discovery plan shall be received by the Court not later than 21 days before the 3 expiration of the subject deadline. A request made after the expiration of the subject deadline 4 shall not be granted unless the movant demonstrates that the failure to set was the result of 5 excusable neglect. Any motion or stipulation to extend a deadline or to reopen discovery 6 shall include: 7 a. A statement specifying the discovery completed; 8 b. A specific description of the discovery that remains to be completed; 9 c. The reasons why the deadline was not satisfied or the remaining discovery was not 10 completed within the time limits set by the discovery plan; and 11 d. A proposed schedule for completing all discovery. 12 The parties submit that good cause exists for an extension of the current deadlines. The 13 parties seek additional time due to the fact Defendant Aaron Crisp is on active military leave until 14 the beginning of October. Additional time is needed so that the parties will have sufficient time to 15 conduct his deposition and complete any necessary additional discovery prior to expert disclosures 16 in light of Crisp’s military leave until October 1, 2025. This request is timely. This brief delay will 17 not substantially impede this matter. This is the first discovery extension request. No trial date has 18 been set and dispositive motions have not yet been filed. 19 20 21 22 [remainder of page intentionally blank] 23 24 25 26 27 1 Further, Plaintiff served a second set of Request for Production of Documents and 2 || Interrogatories on Defendant Aaron Crisp on June 2, 2025. This discovery pertains to punitive 3 || damages and discovery of financial information. Counsel has conferred regarding these written 4 || discovery requests and the deadline for Defendant to respond to these requests are stayed until 14 5 || days after the dispositive motion deadline. If dispositive motions are filed to dismiss punitive 6 || damages, this deadline is stayed until 14 days after the ruling of the dispositive motions at which 7 || time the Defendant will respond if the punitive damages claims remain. However, objections to 8 || these requests or motions for protective order must be made within 30 days of the entering of this 9 || Order. If no objections are made by this deadline, all objections are waived. 10 IT IS SO STIPULATED AND AGREED. 11 || Dated this 16" day of July, 2025. Dated this 16" day of July, 2025. 12|| BREEDEN & ASSOCIATES, PLLC OFFICE OF THE ATTORNEY GENERAL 13 /s/ Adam D. Honey /s/ Adam J. Breeden 14 □ ADAM J. BREEDEN, ESQ. AARON D. FORD, ESQ. 15 || Nevada Bar No. 008768 Attorney General 7432 W. Sahara Ave., Suite 101 ADAM D. HONEY, ESQ. || Las Vegas, Nevada 89117 Nevada Bar No. 9588 Phone: (702) 819-7770 1 State of Nevada Way, Suite 100 || Fax: (702) 819-7771 Las Vegas, Nevada 89119 [email protected] 18 || Attorneys for Plaintiff Phone: (702) 486-3573 Fax: (702) 486-3773 19 Attorneys for Defendants 20 The Court notes that the parties essentially seek a limited stay of discovery regarding Plaintiff's second set of requests for production of documents and interrogatories served on Defendant Aaron Crisp. Although the parties did not cite the applicable standard for a stay, the Court nonetheless finds that they have shown good cause for the stay they seek. See Schrader v. 23 || Wynn, 2:19-cv-02159-JCM-BNW,

, at *2-4 (D. Nev. Oct. 14, 2021). || IT IS THEREFORE ORDERED that the stipulation to extend discovery (ECF No. 13) is GRANTED. 25 o> . 26 s<“\ 2} L) DANIEL J. ALBREGTS \ 27 UNITED STATES MAGISTRATE JUDGE 28 DATED: July 17, 2025