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

United States District Court, D. Nevada

January 8, 2018

JPMORGAN CHASE BANK, N.A., Plaintiff,
v.
SFR INVESTMENTS POOL 1, LLC, a Nevada limited liability company; SEVEN HILLS MASTER COMMUNITY ASSOCIATION, a Nevada non-profit corporation; and VENANCIO H. REYES, JR., an individual, Defendants. SFR INVESTMENTS POOL 1, LLC, a Nevada limited liability company Counterclaimant/Cross-Claimant,
v.
JPMORGAN CHASE BANK, N.A.; MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. AS NOMINEE BENEFICIARY FOR COUNTRYWIDE HOME LOANS, INC., a New York corporation; REAL TIME RESOLUTIONS, INC., Counter/Third-Party/Cross- Defendants.

          Kim Gilbert Ebron Diana S. Ebron, Esq. Karen L. Hanks, Esq. Jacqueline A. Gilbert, Esq. Attorneys for SFR Investments Pool 1, LLC

          Ballard Spahr LLP Abran E. Vigil, Esq. Maria A. Gall, Esq. Lindsay Demaree, Esq. Kyle A. Ewing, Esq. Attorneys for JPMorgan Chase Bank, N.A.

          Boyack Orme & Anthony Edward D. Boyack, Esq. Patrick Orme, Esq. Attorneys for Seven Hills Master Community 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 Defendant Seven Hills Master Community Association (“Seven Hills”), 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 Mortgage Electronic Registration Systems, Inc.

         Moreover, on December 20, 2017, the Parties filed their interim status report. See ECF No. 35.

         B. Specific Description of Discovery that Remains to be Completed

         SFR has noticed a Rule 30(b)(6) deposition of Chase for January 11, 2017. As discussed below, however, the parties seek to reschedule Chase's deposition to occur after the current discovery cutoff of February 22, 2018.[1] Chase plans to notice depositions of SFR, Seven Hills, and non-party Alessi & Koenig, LLC. Chase and SFR are currently preparing written discovery to be served on each other. Chase is also preparing written discovery to be served on Seven Hills.

         C. Good Cause Exists for the Requested Extension

         SFR has noticed Chase's deposition for January 11, 2018, but Chase's Rule 30(b)(6) designee is unavailable on this date because the designee will be recovering from a significant surgery she underwent in December. It is not known at this point when her doctor will clear her to fly again, and she may be unable to fly until the end of January or beginning of February 2018. The parties have met and conferred about rescheduling Chase's deposition in this and other similar lawsuits to the week of March 19, 2017. Although it is anticipated that Chase's designated witness should be able to fly by February 2018, the parties are unable to schedule her deposition in February as the witness will be testifying in numerous other lawsuits that month (the rescheduling of which was also necessitated by her surgery.)

         This is the parties' first request to extend the 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, which treatment and recovery were not anticipated at the time the parties filed their first proposed scheduling order. The parties have diligently engaged in discovery to date, met and conferred ...


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