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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. Plaintiff,
v.
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,
v.
JPMORGAN CHASE BANK, N.A. Counter-Defendant. SFR INVESTMENTS POOL 1, LLC., a Nevada limited liability company, Cross-Claimant,
v.
SIU MING PANG, an individual, Cross-Defendant.

          Ballard Spahr LLP Russell J. Burke Joel E. Tasca, Esq. Attorneys for JPMorgan Chase Bank, N.A.

          Hall, Jaffe & Clayton, LLP Ashlie L. Surur, Esq. NV Bar No. 11290 Attorneys for Diamond Creek Homeowners' Association

          Kim Gilbert Ebron Diana S. Ebron Diana S. Ebron, Esq. Attorneys for SFR Investments Pool 1, LLC

          Joel E. Tasca Russell J. Burke Nevada Bar No. 12710 BALLARD SPAHR LLP Attorneys for Plaintiff

          STIPULATION AND ORDER TO EXTEND SCHEDULING ORDER

         Pursuant 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”), [1] 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 this case.[2]

         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 or production to the HOA; interrogatories to the HOA; and deposition of the HOA.

         To 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.

         B. Specific Description of Discovery that Remains to be Completed

         The 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 cutoff.[3]

         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 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.

         Additionally, 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.[4] 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, ...


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