United States District Court, D. Nevada
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.
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
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.
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.
Discovery Completed to Date
date, Chase has served the following discovery: its initial
disclosure of documents and witnesses and its initial expert
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.
on December 20, 2017, the Parties filed their interim status
report. See ECF No. 35.
Specific Description of Discovery that Remains to be
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. 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.
Good Cause Exists for the Requested
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
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