United States District Court, D. Nevada
GIDEN LOCHER TURNER SENET & WITTBRODT LLP MATTHEW L.
GRODE TIMOTHY P. ELSON ATTORNEYS FOR DEFENDANT ARBUCKLE DRIVE
HOMEOWNERS ASSOCIATION, INC.
BALLARD SPAHR LLP ABRAN E. VIGIL STACY H. RUBIN ATTORNEYS FOR
PLAINTIFF JPMORGAN CHASE BANK, N.A.
WRIGHT LAW GROUP, P.C. JOHN HENRY WRIGHT ATTORNEY FOR
DEFENDANT G2 VENTURES LLC
STIPULATION AND ORDER TO EXTEND
SCHEDULING ORDER DEADLINES BY 30 DAYS
to LR IA 6-1 and LR 26-4, Plaintiff JPMORGAN CHASE BANK N.A.
(“Chase”), Defendant ARBUCKLE DRIVE HOMEOWNERS
ASSOCIATION, INC. (“Arbuckle”), and Defendant G2
VENTURES LLC (“G2”), (collectively, the
“Parties”), 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, to permit the Parties to
efficiently complete party depositions and outstanding
written discovery-specifically the deposition of Chase, whose
designated witness underwent significant surgery in late
December, from which she will not have recuperated until
February 2018. The Parties 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 for her deposition.
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.
Discovery Completed to Date
date, Chase has served the following discovery: initial
disclosures; initial expert disclosure; requests for
production to G2; interrogatories to G2; notice of Rule
30(b)(6) deposition of G2 (scheduled for January 16, 2018);
subpoena duces tecum to Alessi & Koenig, LLC.
(“Alessi”); subpoena for deposition testimony to
Alessi (scheduled for January 22, 2018); requests for
production to Arbuckle; interrogatories to Arbuckle; and
notice of Rule 30(b)(6) deposition of Arbuckle (scheduled for
January 17, 2018).
date, G2 has served the following discovery: requests for
production to Chase and interrogatories to Chase.
date, Arbuckle has served the following discovery: initial
disclosures; requests for production to Chase;
interrogatories to Chase; and requests for admission to
Specific Description of Discovery that Remains to be
Parties are awaiting responses to the served discovery
requests. Arbuckle and Chase have been working to schedule
the Rule 30(b)(6) deposition of Chase. As discussed below,
however, the Parties seek to reschedule Chase's Rule
30(b)(6) deposition to occur after the current discovery
cutoff of January 28, 2018 to accommodate the Chase
designee's recovery from surgery.
Good Cause Exists for the Requested
the Court entered the Order on the stipulation to extend the
discovery cutoff and subsequent deadlines (ECF No. 54),
counsel learned that the designee would be undergoing
significant surgery in late December, from which she is
currently recovering. Chase and Arbuckle have been attempting
to schedule the deposition of Chase. While it is not certain
at this point when her doctor will clear her, the Parties
have met and conferred about rescheduling Chase's
deposition in this lawsuit near the end of February 2018,
when the Chase designee is fully recuperated from surgery and
able to be deposed. Accordingly, the Parties seek an
additional 30 days for discovery to conduct this party
deposition and provide adequate time for the witness to
receive and review the deposition transcript and for the
Parties to finalize their disclosures. 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, which
treatment and recovery were not anticipated at the time the
Parties filed their stipulation to extend the discovery
period and/or at the time the Court entered an Order thereon
(ECF No. 54). The Parties have diligently engaged in
discovery to date, met and conferred regarding the requested
extension and scheduling of outstanding discovery items, and
seek this extension in good faith.