United States District Court, D. Nevada
Ballard Spahr LLP, Abran E. Vigil, Stacy H. Rubin, Ballard
Spahr LLP, Attorneys for JPMorgan Chase Bank, N.A.
Ball Law Group, Zachary T. Ball, Attorneys for Terrafirma
JOHNSON SONG & GRUCHOW, Sean L. Anderson, T. Chase
Pittsenbarger, Attorneys for Azure Estates Owners'
STIPULATION AND ORDER TO EXTEND SCHEDULING ORDER
DEADLINES BY 30 DAYS
to LR IA 6-1 and LR 26-4, Plaintiff JPMorgan Chase Bank, N.A.
(“Chase”), Defendant Terrafirma Venture LLC
(“Terrafirma”) and Defendant Azure Estates Owners
Association (“Azure”), by and through their
counsel of record, hereby 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 complete written discovery and party depositions. The
parties have conferred and agree that this brief extension is
the most reasonable given the Chapter 7 bankruptcy filing of
nominal Defendant Adrienne Love. See Notice of
Bankruptcy Filing, at ECF No. 25. A Motion for Relief from
Automatic Stay is pending before the United States Bankruptcy
Court for the Central District of California.
the parties' first request for an extension to the
discovery deadlines, which were submitted in compliance with
LR 26-1. The parties make this request in good faith and not
for purposes of delay.
Discovery Completed to Date
date, Chase has served initial disclosures. No other
discovery has been served.
Discovery that Remains to be Completed
Ms. Love's Chapter 7 Bankruptcy filing, extensive
discovery remains to be completed.
Good Cause Exists for the Requested
cause exists for the requested extension, as it will provide
time for the parties to exchange expert witness information,
and complete written discovery and schedule depositions. To
date, Chase has served initial disclosures. On November 7,
2017, a Notice of Bankruptcy filing was filed at ECF No. 25
regarding nominal defendant Adrienne Love's Chapter 7
bankruptcy pending in the United States Bankruptcy Court for
the Central District of California. A Motion for Relief from
Automatic Stay is currently pending, and scheduled to be
heard on December 14, 2017. Accordingly, the parties desire
to extend the Scheduling Order deadlines by 30 days pending
the determination of the Motion for Relief from Automatic
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 seek this
extension in good faith.
parties request an order extending the exchange of expert
information, the interim status report, the close of
discovery, the deadline to file dispositive motions, ...