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

United States District Court, D. Nevada

November 28, 2017

JPMORGAN CHASE BANK, N.A., a national banking association, Plaintiff,
v.
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,
v.
JPMORGAN CHASE BANK, N.A.; DANIEL A. RICHARD, an individual, Counter-Defendant/Cross-Defendants.

          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. Attorneys for Plaintiff/Counter-Defendant JPMorgan Chase Bank, N.A.

          Diana 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

          Sean 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)

         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 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.

         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.

         I. 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 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 Services, LLC.

         To 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.

         To date Willows has served the following discovery: requests for production to Chase; interrogatories to Chase; and requests for admission to Chase.

         B. Specific Description of Discovery that Remains to be Completed

          The 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.[1]

         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 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.

         Additionally, 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 ...


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