United States District Court, D. Nevada
JPMORGAN CHASE BANK, N.A., a national banking association, Plaintiff,
SFR INVESTMENTS POOL 1, LLC, a Nevada limited liability company; THE WILLOWS HOMEOWNERS' ASSOCIATION, a Nevada non-profit corporation; DANIEL A. RICHARD, an individual, Defendants. SFR INVESTMENTS POOL 1, LLC, a Nevada limited liability company, Counterclaimant/Cross-Claimant,
JPMORGAN CHASE BANK, N.A.; DANIEL A. RICHARD, an individual, Counter-Defendant/Cross-Defendants.
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. Attorneys for
Plaintiff/Counter-Defendant JPMorgan Chase Bank, N.A.
S. Ebron, Esq. Nevada Bar No. 10580 Jacqueline A. Gilbert,
Esq. Nevada Bar No. 10593 Karen L. Hanks, Esq. Attorneys for
Defendant/Counter-Claimant/Cross-Claimant SFR Investments
Pool 1, LLC
L. Anderson, Esq. Nevada Bar No. 7259 T. Chase Pittsenbarger,
Esq. Nevada Bar. No. 13740 8945 W. Russell Road, Attorneys
for Defendant The Willows' Homeowners Association
STIPULATION AND ORDER TO EXTEND SCHEDULING ORDER
DEADLINES BY 30 DAYS (First Request)
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 The Willows Homeowners
Association (“Willows”), 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.
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.
Discovery Completed to Date
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
Willows; interrogatories to Willows; notice of Rule 30(b)(6)
deposition of Willows; subpoena to produce documents on
non-party Absolute Collection Services, LLC; and subpoena to
testify at a deposition on non-party Absolute Collection
date, SFR has served the following discovery: initial
disclosures; requests for production to Chase;
interrogatories to Chase; requests for admission to Chase;
and notice of Rule 30(b)(6) deposition of Chase.
Willows has served the following discovery: requests for
production to Chase; interrogatories to Chase; and requests
for admission to Chase.
Specific Description of Discovery that Remains to be
parties are awaiting responses to the served discovery
requests. In addition, they are working to schedule party and
non-party depositions. Chase has scheduled the deposition of
SFR for December 4, 2017, of Willows for December 4, 2017,
and of Absolute Collection Services, LLC for November 22,
2017. SFR has also noticed a Rule 30(b)(6) of Chase. As
discussed below, however, the parties seek to schedule
Chase's deposition to occur after the current discovery
cutoff of December 4, 2017.
Good Cause Exists for the Requested
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 served voluminous written
discovery requests on Chase. While Chase requires additional
time to respond to SFR's discovery, Chase's current
response deadline December 4, 2017-i.e., the last
day of the discovery period. SFR is willing to provide Chase
with a two-week extension for its responses, but it cannot do
so unless discovery is extended.
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 the
deposition in this ...