United States District Court, D. Nevada
ROBERT WINLAND, Special Administrator for the Estate of Joyce Windland, Plaintiff,
HARBOR FREIGHT TOOLS USA, INC.; and DOES 1 through 100; and ROE CORPORATIONS 101 through 200, Defendants.
BERNSTEIN & POISSON LLP Jennifer Gastelum, Esq. Attorneys
BRISBOIS BISGAARD & SMITH, LLP Blake A. Doerr, Esq.
Attorneys for Defendant Harbor Freight
WEINBERGWHEELER HUDGINS GUNN & DIAL Jeremy R. Alberts D.
Lee Roberts, Jr., Esq. Jeremy R. Alberts, Esq. Josephine E.
Groh, Esq. Weinberg, Wheeler, Hudgins, Gunn & Dial, LLC
Attorneys for Third-Party Defendant Unifirst Corporation
STIPULATION AND ORDER TO EXTEND EXPERT WITNESS
DISCOVERY (FIFTH REQUEST)
Plaintiff ROBERT WINLAND, SPECIAL ADMINSITRATOR FOR THE
ESTATE OF JOYCE WINLAND (“Plaintiff”),
Defendant/Third Party Plaintiff HARBOR FREIGHT TOOLS, USA.
INC. (“Harbor Freight” or
“Defendant”), and Third Party Defendant UNIFIRST
CORPORATION (“Third Party Defendant” or
“UniFirst”) by and through their respective
counsel, hereby respectfully submits their Stipulation and
Order to Extend Expert Witness Discovery (Fifth Request)
pursuant to Rules 6(b) and 26(f) of the Federal Rules of
Civil Procedure and Local Rules 6-1 and 26-4. The proposed
Stipulation contemplates a one week extension on the current
expert disclosure deadline, given Third Party Defendant
UniFirst's recent entry into the case.
Plaintiff and Harbor Freight exchanged their Initial
Disclosures pursuant to FRCP 26(a)(1);
Plaintiff propounded written discovery on Harbor Freight;
Harbor Freight responded to Plaintiff's written
Plaintiff provided authorizations for Harbor Freight to
procure Plaintiff's medical records;
Harbor Freight requested medical records from Plaintiff's
Harbor Freight propounded written discovery on Plaintiff;
Plaintiff and Harbor Freight disclosed their initial experts;
Harbor Freight disclosed its rebuttal expert;
Harbor Freight deposed Plaintiff and Plaintiff's medical