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

United States District Court, D. Nevada

January 11, 2018

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.

          BALLARD SPAHR LLP 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. Attorneys for Plaintiff/Counter-Defendant JPMorgan Chase Bank, N.A.

          KIM GILBERT 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 Attorneys for Defendant/Counter-Claimant/Cross-Claimant SFR Investments Pool 1, LLC

          BOYACK ORME & ANTHONY Edward D. Boyack, Esq. Nevada Bar No. 5229 Patrick Orme, Esq. Nevada Bar No. 7853 Attorneys for Defendant Seven Hills Master Community Association

          STIPULATION AND ORDER TO EXTEND SCHEDULING ORDER DEADLINES BY 30 DAYS (Second 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”), 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 30 days. The parties request this extension to complete party depositions, specifically the deposition of Chase, whose designated witness underwent significant surgery in December and requires until at least the end of January or beginning of February 2018 to recuperate, and responses to written discovery. The parties have conferred and agree that this brief extension is the most reasonable way to complete discovery in this case, 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 Seven Hills; interrogatories to Seven Hills; notice of Rule 30(b)(6) deposition of Seven Hills; subpoena to produce documents on non-party Alessi & Koenig, LLC; and subpoena to testify at a deposition on non-party Alessi & Koenig, 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.

         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 only days before the current discovery cutoff of February 19, 2018, which would leave the parties very little time to obtain the deposition transcript prior to the dispositive motion deadline and would not provide Chase sufficient time to review and correct the deposition transcript prior to the dispositive motion deadline.[1] Chase has also noticed depositions of SFR, Seven Hills, and non-party Alessi & Koenig, LLC. Chase is currently preparing its responses and objections to SFR's requests for admission to Chase, requests for production to Chase, and interrogatories to Chase. Additionally, Seven Hills is in the process of providing its written responses to Chase's written discovery requests.

         C. Good Cause Exists for the Requested Extension

         SFR had noticed Chase's deposition for December 1, 2017, but Chase's Rule 30(b)(6) designee was unavailable on this date because the designee was preparing to undergo significant surgery in December, which she underwent and 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 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 requested extension will also provide additional time for Seven Hills to provide its responses to Chase's written discovery. 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 ...


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