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

United States District Court, D. Nevada

December 1, 2017

JPMORGAN CHASE BANK, N.A., a national banking association, Plaintiff,
v.
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,
v.
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

         Abran 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 vigila@ballardspahr.com gallm@ballardspahr.com demareel@ballardspahr.com ewingk@ballardspahr.com Attorneys for Plaintiff JPMorgan Chase Bank, N.A.

         Pursuant 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 this case.

         This is 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.

         A. 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 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.

         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 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.[1]

         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 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 discovery.

         In 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 January, 2018.

         Finally, 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.

         D. Proposed Discovery Deadlines

         The 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 ...


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