United States District Court, D. Nevada
Ballard Spahr LLP Abran E. Vigil Russell J. Burke, Esq.
Attorneys for JPMorgan Chase Bank, N.A.
Jaffe & Clayton, LLP Ashlie L. Surur, Esq. Attorneys for
Sutter Creek Homeowners' Association
Gilbert Ebron Diana S. Ebron, Esq. Attorneys for SFR
Investments Pool 1, LLC
STIPULATION AND TO EXTEND SCHEDULING ORDER (FIRST
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 Sutter 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.
date, the HOA has served its initial disclosures.
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 ...