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JP Morgan Chase Bank, N.A. v. G2 Ventures LLC

United States District Court, D. Nevada

January 12, 2018

JPMORGAN CHASE BANK, N.A., Plaintiff,
v.
G2 VENTURES LLC, a Nevada limited liability company; ARBUCKLE DRIVE HOMEOWNERS ASSOCIATION, INC., a Nevada non-profit corporation; PATRICIA K. PURCELL; and LEONARD D. PURCELL, Defendants.

          GIBBS 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.

          THE 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

         Pursuant 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.

         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.

         A. Discovery Completed to Date

         To 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).

         To date, G2 has served the following discovery: requests for production to Chase and interrogatories to Chase.

         To date, Arbuckle has served the following discovery: initial disclosures; requests for production to Chase; interrogatories to Chase; and requests for admission to Chase.

         B. Specific Description of Discovery that Remains to be Completed

         The 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.[1]

         C. Good Cause Exists for the Requested Extension

         After 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.

         D. Proposed ...


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