United States District Court, D. Nevada
JPMORGAN CHASE BANK, N.A., a national banking association, Plaintiff,
SFR INVESTMENTS POOL 1, LLC, a Nevada limited liability company; SEVEN HILLS MASTER COMMUNITY ASSOCIATION; and MOUSHIR MANIOUS, an individual. Defendants. SFR INVESTMENTS POOL 1, LLC, a Nevada limited liability company Counter/Cross-Claimant,
JPMORGAN CHASE BANK, N.A., a national banking association; UNITED GUARANTY RESIDENTIAL INSURANCE COMPANY OF NORTH CAROLINA; MOUSHIR, an individual Counter/Cross-Defendants.
STIPULATION AND ORDER TO EXTEND SCHEDULING ORDER
DEADLINES BY 60 DAYS
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. Nevada Bar. No. 14051 Ballard Spahr
LLP 100 North City Parkway, Suite 1750 Las Vegas, Nevada
89106 Telephone: (702) 471-7000 Facsimile: (702) 471-7070
firstname.lastname@example.org Attorneys for Plaintiff
JPMorgan Chase Bank, N.A.
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 Defendant Seven Hills Master
Community Association (the “HOA”) stipulate and
request that this Court extend discovery and dispositive
motion deadlines in the above-captioned case for 60 days, to
permit the parties to efficiently complete 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. 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 for production to the
HOA; interrogatories to the HOA; notice of Rule 30(b)(6)
deposition of the HOA; subpoena duces tecum to
Alessi & Koenig (“Alessi”); and a subpoena
for deposition testimony to Alessi.
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 and Alessi's responses to the subpoenas
duces tecum. The Rule 30(b)(6) deposition for SFR
currently is set for December 8, 2017. In addition, the
parties are working to schedule Rule 30(b)(6) depositions for
Alessi, the HOA, and Chase, but, as discussed below, they
seek to schedule the depositions of Chase and the HOA after
the current discovery cutoff.
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 and Chase are conferring about
potential dates for the deposition of Chase's Rule
30(b)(6) designee, who lives out of state. In addition, 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 is December
17, 2017-i.e., only a few days before discovery ends
on December 20, 2017. SFR is willing to provide Chase with an
extension for its responses, but it cannot do so unless
discovery is extended. Accordingly, the requested extension
to the scheduling order deadlines will minimize the cost and
burden to the witness and provide sufficient time for Chase
to respond to SFR's discovery. It will also permit SFR to
depose Chase after receiving Chase's discovery responses,
a logical process that will enable SFR to conduct an
efficient, productive, and targeted deposition. SFR
anticipates that it will be able to significantly limit the
scope of the deposition based on the responses to its written
addition, the HOA's Rule 30(b)(6) designee lives in
Alabama and travels to Las Vegas monthly for depositions.
While Chase's counsel anticipated deposing the HOA's
designee on December 14 or 15, 2017, this date is no longer
practicable as counsel's office is moving to a new
location on December 15, 2017. Accordingly, the next
available date for the HOA's deposition is not until
this is the parties' first request to extend discovery in
this case, and they seek only a 60-day extension. The parties
have diligently engaged in discovery to date and seek this
extension in good faith.
Proposed Discovery Deadlines
parties request an order extending the close of discovery,
the deadline to file dispositive motions, and the deadline to
file a pre-trial order by 60 days. This extension is