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JPMorgan Chase Bank, N.A. v. SFR Investments Pool 1, LLC

United States District Court, D. Nevada

November 14, 2017

JPMORGAN CHASE BANK, N.A., Plaintiff,
v.
SFR INVESTMENTS POOL 1, LLC, a Nevada limited liability company; TRAIL RIDGE COMMUNITY ASSOCIATION, a Nevada non-profit corporation; LIZZY HOLBROOK, an individual. Defendants. SFR INVESTMENTS POOL 1, LLC, a Nevada limited liability company, Counterclaimant/Cross-Claimant,
v.
JPMORGAN CHASE BANK, N.A.; LIZZY HOLBROOK, an individual, Counter-Defendant/Cross-Defendant.

          Abran E. Vigil, Esq. Nevada Bar. No. 7548 Maria A. Gall, Esq. Nevada Bar No. 14200 Lindsay C. Demaree, Esq. Nevada Bar No. 11949 Kyle A. Ewing, Esq. Nevada Bar. No. 14051 Ballard Spahr LLP Attorneys for JPMorgan Chase Bank, N.A.

          STIPULATION AND ORDER TO EXTEND SCHEDULING ORDER DEADLINES BY 30 DAYS (First Request)

         Pursuant to LR IA 6-1 and LR 26-4, Plaintiff/Counter-Defendant JPMorgan Chase Bank, N.A. (“Chase”), Defendant/Counterclaimant/Cross-Claimant SFR Investments Pool 1, LLC (“SFR”), and Defendant Trail Ridge Community Association (“Trail Ridge”), [1] by and through their respective counsel of record, stipulate and request that this Court extend discovery and dispositive motion deadlines in the above-captioned case for 30 days, to permit the parties to efficiently complete party depositions and outstanding written discovery. The parties have conferred and agree that this brief extension is the most reasonable, most economical, and least burdensome way to complete discovery in this case.

         This is the parties' first request for an extension to the scheduling order deadlines, which were submitted in compliance with LR 26-1. The parties make this request in good faith and not for purposes of delay.

         A. Discovery Completed to Date

          To date, Chase has served the following discovery: initial disclosures; initial expert disclosure; requests for production to SFR; interrogatories to SFR; notice of Rule 30(b)(6) deposition of SFR; requests for production to Trail Ridge; interrogatories to Trail Ridge; notice of Rule 30(b)(6) deposition of Trail Ridge; subpoena to produce documents on non-party Alessi & Koenig, LLC; and subpoena to testify at a deposition on non-party Alessi & Koenig, LLC.

         To date, SFR has served the following discovery: initial disclosures.

         To date Trail Ridge has served the following discovery: initial disclosures.

         B. Specific Description of Discovery that Remains to be Completed

          Chase is awaiting responses to the discovery requests it served, and SFR anticipates that it will soon be serving discovery requests upon Chase. In addition, they are working to schedule party and non-party depositions. Chase has scheduled the deposition of non-party Alessi & Koenig, LLC for November 27, 2017 and of Defendant Trail Ridge for November 28, 2017 and of Defendant SFR for November 29, 2017. SFR has also noticed a Rule 30(b)(6) deposition of Chase. As discussed below, however, the parties seek to schedule Chase's deposition and to reschedule to occur after the current discovery cutoff of November 29, 2017.[2]

         C. Good Cause Exists for the Requested Extension

         Good cause exists for the requested extension, as it will provide time for the parties to complete written discovery and schedule depositions in a way that minimizes burden and increases efficiency. SFR has noticed Chase's deposition for November 29, 2017, but Chase's Rule 30(b)(6) designee is unavailable on this date because the designee will be testifying in five other depositions in similar lawsuits involving Chase and SFR, on not only November 29 but also on November 28 and 30. The parties have met and conferred about rescheduling Chase's deposition in this lawsuit to take place during the week of December 11-15, 2017, when the Chase designee will be available and again in Las Vegas. This approach will significantly minimize the cost and burden to the witness. This is the parties' first request to extend the standard, 180-day discovery period in this case, and they seek only a brief 30-day extension. The parties have diligently engaged in discovery to date and seek this extension in good faith.

         D. Proposed Discovery Deadlines

         The parties request an order extending the close of discovery, the deadline to file dispositive motions, and the deadline to file a pre-trial order by 30 days.

Event

Current Deadline3

New Deadline

Close of Discovery

November 29, 2017

December 29, 2017

Dispositive Motions

December 29, 2017

January 29, 2018

Pre-Trial Order

January 29, 2018

March 1, 2018


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