Nevada, a plaintiff must take reasonable steps mitigate damages, which means to
minimize the effects and loss related to his or her injuries/damages.Dillard's Dep’t Stores, Inc. v. Beckwith,
989 P.2d 882, (Nev. 1999); NRS 118.175; James Hardie Gypsum (Nevada), Inc. v. Inquipco,
112 Nev. 1397, 929 P.2d 903 (1996) (“As a general rule, a party cannot recover
damages for loss that he could have avoided by reasonable efforts.” Conner v. S. Nevada Paving, Inc., 103 Nev. 353, 355, 741
P.2d 800, 801 (1987) (citation omitted). “[T]he rule den[ies] recovery for losses which could have been prevented by
the . . . expenditures of plaintiff. . . .” Valencia v.
Shell Oil Co., 147 P.2d 558, 561 (Cal. 1944). In order to recover
loss of use damages, the plaintiff must “show diligence in getting the car
repaired as early as reasonably possible.” Rownstein
v. Bernhard & Turner Auto. Co., 180 N.W. 282, 284 (Iowa 1920).
“[T]he trial court’s role, as trier of fact, is to
determine the reasonable period of repair.” Airborn, Inc. v. Denver
Air Ctr., Inc., 832 P.2d 1086, 1091 (Colo. Ct. App. 1992)).