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

United States District Court, D. Nevada

November 29, 2017

JPMORGAN CHASE BANK, N.A, Plaintiff,
v.
SFR INVESTMENTS POOL 1, LLC, a Nevada limited liability company; and SUTTER CREEK HOMEOWNERS ASSOCIATION, a Nevada non-profit corporation, Defendants. SFR INVESTMENTS POOL 1, LLC, a Defendants. Counterclaimant,
v.
JPMORGAN CHASE BANK, N.A.; Counter-Defendant. SFR INVESTMENTS POOL 1, LLC, a Nevada limited liability company, Cross-Claimant,
v.
WAI CHUNG NG, an individual, Cross-Defendant.

         Nevada Bar 7548

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

          Hall, Jaffe & Clayton, LLP Ashlie L. Surur, Esq. Attorneys for Sutter Creek Homeowners' Association

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

          STIPULATION AND TO EXTEND SCHEDULING ORDER (FIRST REQUEST)

         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 Sutter 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.

         To date, the HOA has served its initial disclosures.

         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 ...


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