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

United States District Court, D. Nevada

January 5, 2018

JPMORGAN CHASE BANK, N.A. Plaintiff,
v.
SFR INVESTMENTS POOL 1, LLC, a Nevada limited liability company; CASA PALERMO 20N HOMEOWNERS' ASSOCIATION, a Nevada non-profit corporation; and FARANAK PANAHBARHAGH, an individual. Defendants.

          Abran E. Vigil, Esq. Nevada Bar No. 7548 Maria A. Gall, Esq. Nevada Bar No. 14200 Lindsay Demaree, Esq. Nevada Bar No. 11949 Kyle A. Ewing, Esq. Nevada Bar No. 14051 BALLARD SPAHR LLP Attorneys for JPMorgan Chase Bank, N.A.

          KIM GILBERT EBRON Diana S. Ebron Diana S. Ebron, Esq. Nevada Bar No. 10580 Karen L. Hanks, Esq. Nevada Bar No. 9578 Jacqueline A. Gilbert, Esq. Nevada Bar No. 10593 Attorneys for SFR Investments Pool 1, LLC

          HALL JAFFEE & CLAYTON, LLP Ashlie L. Surur Ashlie L. Surur, Esq. Nevada Bar No. 11290 Attorneys for Casa Palermo 20N Homeowners' Association

          BLUT LAW GROUP, APC Elliot S. Blut Elliot S. Blut, Esq. Nevada Bar No. 6570 300 S. 4th Street Las Vegas, Nevada 89101 Attorneys for Faranak Panahbarhagh

          STIPULATION AND ORDER TO EXTEND SCHEDULING ORDER DEADLINES BY 60 DAYS (FIRST REQUEST)

         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”), Defendant Casa Palermo 20N Homeowners' Association (“Casa Palermo”), and Defendant Faranak Panabarhagh, 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 underwent 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 and recuperate before traveling to Las Vegas for her depositions in not only this action but numerous other lawsuits between Chase and SFR involving homeowners' association foreclosure sales.

         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.

         A. Discovery Completed to Date

         To date, Chase has served the following discovery: its initial disclosure of documents and witnesses and its initial expert disclosure.

         To date, SFR has served the following discovery: its initial disclosure of documents and witnesses and notice of Rule 30(b)(6) deposition of Chase and notice of deposition of Faranak Panabarhagh.

         To date, Casa Palermo has served its initial disclosure of documents and witnesses.

         To date, Faranak Panabarhagh has served her initial disclosure of documents and witnesses.

         Moreover, on December 18, 2017, the Parties filed their interim status report. See ECF No. 41.

         B. Specific Description of Discovery that Remains to be Completed

         SFR has noticed a Rule 30(b)(6) deposition of Chase for January 10, 2017. As discussed below, however, the parties seek to reschedule Chase's deposition to occur after the current discovery cutoff of February 16, 2018.[1] Chase plans to notice depositions of SFR, Casa Palermo, and non-party Alessi & Koenig, LLC. Chase and SFR are currently preparing written ...


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