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

United States District Court, D. Nevada

December 20, 2017

JPMORGAN CHASE BANK, N.A., a national banking association, Plaintiff,
v.
SFR INVESTMENTS POOL 1, LLC, a Nevada limited liability company; THE WILLOWS HOMEOWNERS' ASSOCIATION, a Nevada non-profit corporation; DANIEL A. RICHARD, an individual, Defendants. SFR INVESTMENTS POOL 1, LLC, a Nevada limited liability company, Counterclaimant/Cross-Claimant, vs. JPMORGAN CHASE BANK, N.A.; DANIEL A. RICHARD, an individual, Counter-Defendant/Cross-Defendants.

          Maria A. Gall, Abran E. Vigil, Esq. Maria A. Gall, Esq. Lindsay C. Demaree, Esq. Kyle A. Ewing, Esq. Las Vegas, Nevada 89106 Attorneys for Plaintiff/Counter-Defendant

          Kim Gilbert Ebron By: Diana S. Ebron Diana S. Ebron, Esq. Nevada Bar No. 10580 Jacqueline A. Gilbert, Esq. Nevada Bar No. 10593 Karen L. Hanks, Esq. Nevada Bar No. 9578 7625 Dean Martin Dr., Suite 110 Las Vegas, Nevada 89139 Attorneys for Defendant/Counter-Claimant/Cross-Claimant SFR Investments Pool 1, LLC

          T. Chase Pittsenbarger, Sean L. Anderson, Esq., T. Chase Pittsenbarger, Esq, Attorneys for Defendant The Wi lows' Homeowners Association

          STIPULATION AND ORDER TO EXTEND SCHEDULING ORDER DEADLINES BY 60 DAYS

         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 The Willows Homeowners Association (“Willows”), 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 for 60 days, to permit the parties to complete party depositions, and specifically the deposition of Chase, whose designated witness must undergo significant surgery in December, from which she will not have recuperated until at least the end of January or beginning of February 2018. The parties have conferred and agree that this brief extension is the most reasonable way to complete discovery in this case, including so that Chase's designated witness has sufficient time to attend to necessary medical treatment.

         This is the parties' second 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 for production to Willows; interrogatories to Willows; notice of Rule 30(b)(6) deposition of Willows; subpoena to produce documents on non-party Absolute Collection Services, LLC; and subpoena to testify at a deposition on non-party Absolute Collection Services, LLC.

         To date, SFR has served the following discovery: initial disclosures; requests for production to Chase; interrogatories to Chase; requests for admission to Chase; and notice of Rule 30(b)(6) deposition of Chase. SFR has also responded to Chase's requests for production and interrogatories to SFR.

         To date Willows has served the following discovery: requests for production to Chase; interrogatories to Chase; and requests for admission to Chase.

         B. Specific Description of Discovery that Remains to be Completed

         SFR has noticed a Rule 30(b)(6) deposition of Chase. As discussed below, however, the parties seek to reschedule Chase's deposition to occur after the current discovery cutoff of January 4, 2018.[1] Chase has also noticed depositions of SFR, Willows, and non-party Absolute Collection Services, LLC. Chase is currently preparing its responses/objections to SFR's requests for admission to Chase, requests for production to Chase, and interrogatories to Chase. Chase is also currently preparing its responses/objections to Willows's requests for admission to Chase, requests for production to Chase, and interrogatories to Chase. Willows is currently preparing its responses/objections to Chase's requests for production to Willows and interrogatories to Willows.

         C. Good Cause Exists for the Requested Extension

         SFR has noticed Chase's deposition for December 12, 2017, but Chase's Rule 30(b)(6) designee is unavailable on this date because the designee will be undergoing significant surgery in December, from which she will need to recuperate until at least the end of January or beginning of February 2018. The parties have met and conferred about rescheduling Chase's deposition in this lawsuit to take place during the week of February 12-16, 2018, when the Chase designee should be recuperated from surgery and able to travel to Las Vegas. This is the parties' second request to extend the standard, 180-day discovery period in this case, and they seek the extension so that Chase's designated witness may have an opportunity to receive necessary medical treatment and recover from the same. The parties have diligently engaged in discovery to date and seek this extension in good faith.

         D. Proposed ...


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