Barrette et al v. Jubilee Fisheries, Inc.

Filing 18

STIPULATION AND ORDER to extend deadline for expert witness disclosures; signed by Judge Marsha J. Pechman. (SC)

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HONORABLE MARSHA J. PECHMAN

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UNITED STATES DISTRICT COURT
WESTERN DISTRICT OF WASHINGTON
AT SEATTLE

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CHRISTIAN BARRETTE, and KATRENA
BARRETTE, Washington citizens,

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Plaintiffs,
v.

No. C10-01206
STIPULATION AND ORDER TO
EXTEND DEADLINE FOR EXPERT
WITNESS DISCLOSURES

JUBILEE FISHERIES, INC., a Washington
corporation,

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Defendant.
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STIPULATION
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Parties and their counsel of record in this matter agree, jointly request and stipulate

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that the deadline to disclose expert witnesses and their reports, presently due May 9, 2011, be

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extended to May 31, 2011.

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STIPULATION AND [PROPOSED] ORDER TO EXTEND
DEADLINE FOR EXPERT DISCLOSURES
No. C10-01206 – Page 1

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Depositions of plaintiffs were just held on April 30, 2011, and previously unknown

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medical allegations were discovered, for which the defendant will need an expert’s opinion to

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defend its case. In addition, depositions of defense witnesses are yet to be held due to

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difficulties in contacting the witnesses and coordinating all parties’ schedules.

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Deadline for discovery completion is currently set on July 8, 2011, and trial is
scheduled to begin on December 5, 2011.
Finally, this extension of expert witnesses and their reports should not affect the other
case schedule.

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DATED this 3rd day of May, 2011.

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s/Richard Nielsen
RICHARD A. NIELSEN, WSBA # 11916
NIELSEN SHIELDS, PLLC
600 Stewart Street, Suite 1703
Seattle, Washington 98101
Telephone: [phone]
Facsimile:
206-728-1302
Email:
[e-mail]
Attorneys for Defendant

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s/Albert Bannon (per email authorization)
ALBERT BANNON, OSBA # 69009
BANNON MEDIATION LLC
200 S.W. Market St., Ste. 1777
Portland, OR 97201-5727
Telephone:
503.295.7977
Facsimile:
503.225.1257
Email:
[e-mail]
Attorneys for Plaintiff
STIPULATION AND [PROPOSED] ORDER TO EXTEND
DEADLINE FOR EXPERT DISCLOSURES
No. C10-01206 – Page 2

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[PROPOSED] ORDER
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Based upon the foregoing Stipulation, the deadline to disclose the expert witnesses and
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their reports is extended from May 9, 2011 to May 31, 2011.
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DATED this _9th_ day of __May__, 2011.
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A

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Marsha J. Pechman
United States District Judge

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Presented By:

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NIELSEN SHIELDS, PLLC

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By Richard A. Nielsen________________
RICHARD A. NIELSEN, WSBA #11916
Nielsen Shields, PLLC
600 Stewart St. Suite 1703
Seattle, WA 98101
Phone: [phone]
Fax: [phone]
Email: [e-mail]
Attorneys for Defendant

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STIPULATION AND [PROPOSED] ORDER TO EXTEND
DEADLINE FOR EXPERT DISCLOSURES
No. C10-01206 – Page 3

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CERTIFICATE OF SERVICE

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I hereby certify that on May 9, 2011, I electronically filed the
foregoing with the Clerk of the Court using the CM/ECF system,
which will send notification of such filing to the following:

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Matt Adamson, Esq.
Jameson Babbitt Stites & Lombard, PLLC

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999 Third Ave. #1900
Seattle, WA 98104

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Albert J. Bannon

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Bannon Mediation LLC
200 S.W. Market St., Ste. 1777

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Portland, OR 97201-5727

I certify under penalty of perjury under the laws of the State of
Washington that the foregoing is true and correct.

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Signed at Seattle, Washington.

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s/Sheila Baskins

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Legal Assistant
600 Stewart Street, Suite 1703
Seattle, Washington 98101
Telephone: [phone]
Facsimile: 206-728-1302
[e-mail]

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STIPULATION AND [PROPOSED] ORDER TO EXTEND
DEADLINE FOR EXPERT DISCLOSURES
No. C10-01206 – Page 4