United States District Court, D. Nevada
JPMORGAN CHASE BANK, N.A. Plaintiff,
SFR INVESTMENTS POOL 1, LLC, a Nevada limited liability company; MOUNTAIN'S EDGE MASTER ASSOCIATION, a Nevada non-profit corporation; and DIAMOND CREEK HOMEOWNERS' ASSOCIATION, a Nevada non-profit corporation. Defendants. SFR INVESTMENTS POOL 1, LLC., a Nevada limited liability company, Counter-Claimant,
JPMORGAN CHASE BANK, N.A. Counter-Defendant. SFR INVESTMENTS POOL 1, LLC., a Nevada limited liability company, Cross-Claimant,
SIU MING PANG, an individual, Cross-Defendant.
Ballard Spahr LLP Russell J. Burke Joel E. Tasca, Esq.
Attorneys for JPMorgan Chase Bank, N.A.
Jaffe & Clayton, LLP Ashlie L. Surur, Esq. NV Bar No.
11290 Attorneys for Diamond Creek Homeowners' Association
Gilbert Ebron Diana S. Ebron Diana S. Ebron, Esq. Attorneys
for SFR Investments Pool 1, LLC
E. Tasca Russell J. Burke Nevada Bar No. 12710 BALLARD SPAHR
LLP Attorneys for Plaintiff
STIPULATION AND ORDER TO EXTEND SCHEDULING
to LR IA 6-1 and LR 26-4, plaintiff/counter-defendant
JPMorgan Chase Bank, N.A. (“Chase”),
defendant/counterclaimant SFR Investments Pool 1, LLC
(“SFR”), defendant Diamond Creek Homeowners'
Association (the “HOA) (all parties together, the
“Parties”),  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 by approximately 90 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
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 or production to the
HOA; interrogatories to the HOA; and deposition of the HOA.
date, SFR has served the following discovery: initial
disclosures; requests for production to Chase;
interrogatories to Chase; requests for admission to Chase;
notice of deposition of Chase.
Specific Description of Discovery that Remains to be
parties are awaiting responses to the served discovery
requests prior to taking the respective Rule 30(b)(6)
depositions. In addition, they are working to schedule
third-party and party depositions. The parties have also
noticed Rule 30(b)(6) party depositions for SFR and Chase. As
discussed below, however, they seek to schedule Chase's
deposition to occur after the current discovery
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 served voluminous written
(approximately 170 discovery requests) on Chase on the last
day to serve discovery. While Chase requires additional time
to respond to SFR's discovery, Chase's current
response deadline is December 4, 2017-i.e., the last
day of the discovery period. SFR is willing to provide Chase
with an extension for its responses, but it cannot do so
unless discovery is extended.
SFR has noticed Chase's deposition for November 28, 2017,
but Chase's Rule 30(b)(6) designee is unavailable on this
date due other depositions. The parties have met and
conferred about rescheduling the deposition to take place
during February 2018, when the Chase designee will be
available and in Las Vegas. This approach will significantly
minimize the cost and burden to the witness. Moreover,
scheduling the Chase deposition during this time period will
also allow SFR to obtain Chase's written discovery
responses before deposing Chase, a logical process that will
enable SFR to conduct an efficient, ...