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JPMorgan Chase Bank N.A. v. Terrafirma Venture LLC

United States District Court, D. Nevada

November 17, 2017

JPMORGAN CHASE BANK, N.A., Plaintiff,
v.
TERRAFIRMA VENTURE LLC, a Nevada limited liability company; AZURE ESTATES OWNERS ASSOCIATION, a Nevada non-profit corporation; ADRIENNE LOVE, an individual, Defendants.

          Ballard Spahr LLP, Abran E. Vigil, Stacy H. Rubin, Ballard Spahr LLP, Attorneys for JPMorgan Chase Bank, N.A.

          The Ball Law Group, Zachary T. Ball, Attorneys for Terrafirma Venture LLC

          LEACH JOHNSON SONG & GRUCHOW, Sean L. Anderson, T. Chase Pittsenbarger, Attorneys for Azure Estates Owners' Association

          STIPULATION AND ORDER TO EXTEND SCHEDULING ORDER DEADLINES BY 30 DAYS

         Pursuant 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.

         This is 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.

         I. Discovery Completed to Date

         To date, Chase has served initial disclosures. No other discovery has been served.

         II. Discovery that Remains to be Completed

         Due to Ms. Love's Chapter 7 Bankruptcy filing, extensive discovery remains to be completed.

         III. Good Cause Exists for the Requested Extension

         Good 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 Stay.

         Finally, 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.

         IV. Proposed Deadlines

         The parties request an order extending the exchange of expert information, the interim status report, the close of discovery, the deadline to file dispositive motions, ...


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