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Winland v. Harbor Freight Tools USA, Inc.

United States District Court, D. Nevada

December 5, 2017

ROBERT WINLAND, Special Administrator for the Estate of Joyce Windland, Plaintiff,
v.
HARBOR FREIGHT TOOLS USA, INC.; and DOES 1 through 100; and ROE CORPORATIONS 101 through 200, Defendants.

          BERNSTEIN & POISSON LLP Jennifer Gastelum, Esq. Attorneys for Plaintiff

          LEWIS 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.

         I. DISCOVERY COMPLETED

         1. Plaintiff and Harbor Freight exchanged their Initial Disclosures pursuant to FRCP 26(a)(1);

          2. Plaintiff propounded written discovery on Harbor Freight;

         3. Harbor Freight responded to Plaintiff's written discovery;

         4. Plaintiff provided authorizations for Harbor Freight to procure Plaintiff's medical records;

         5. Harbor Freight requested medical records from Plaintiff's treating physicians;

         6. Harbor Freight propounded written discovery on Plaintiff;

         7. Both Plaintiff and Harbor Freight disclosed their initial experts;

         8. Harbor Freight disclosed its rebuttal expert;

         9. Harbor Freight deposed Plaintiff and Plaintiff's medical ...


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