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

United States District Court, D. Nevada

January 29, 2018

JPMORGAN CHASE BANK, N.A., Plaintiff,
v.
SFR INVESTMENTS POOL 1, LLC, a Nevada limited liability company; TRAIL RIDGE COMMUNITY ASSOCIATION, a Nevada non-profit corporation; LIZZY HOLBROOK, an individual. Defendants. SFR INVESTMENTS POOL 1, LLC, a Nevada limited liability company, Counterclaimant/Cross-Claimant,
v.
JPMORGAN CHASE BANK, N.A.; LIZZY HOLBROOK, an individual, Counter-Defendant/Cross-Defendant.

          BALLARD SPAHR LLP Maria A. Gall 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. Nevada Bar. No. 14051 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 Adam J. Breeden, Esq. Nevada Bar No. 8768 Christopher B. Anthony Nevada Bar No. 9748 Attorneys for Trail Ridge Community Association

          STIPULATION AND ORDER TO EXTEND SCHEDULING ORDER DEADLINES BY 60 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 Trail Ridge Community Association (“Trail Ridge”), [1] 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 must undergo significant surgery in December and 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.

         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; first set of requests for production to SFR; second set of requests for production to SFR, interrogatories to SFR; notice of Rule 30(b)(6) deposition of SFR; first set of requests for production to Trail Ridge; second set of requests for production to Trail Ridge; interrogatories to Trail Ridge; notice of Rule 30(b)(6) deposition of Trail Ridge; subpoena to produce documents on non-party Alessi & Koenig, LLC; and subpoena to testify at a deposition on non-party Alessi & Koenig, LLC. In addition, Chase has taken the deposition of SFR, Trail Ridge, and 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.

         To date Trail Ridge has served the following discovery: initial disclosures.

         B. Specific Description of Discovery that Remains to be Completed SFR has also noticed a Rule 30(b)(6) deposition of Chase. As discussed below, however, the parties seek to reschedule Chase's to occur after the current discovery cutoff of December 29, 2017.[2] Chase is currently preparing its responses/objections to SFR's requests for admission to Chase, requests for production to Chase, and interrogatories to Chase. Trail Ridge is currently preparing its responses/objections to Chase's requests for production to Trail Ridge and interrogatories to Trail Ridge.

         C. Good Cause Exists for the Requested Extension

         SFR has noticed Chase's deposition for December 12, 2017, but Chase's Rule 30(b)(6) designee is unavailable on this date because the designee will be undergoing significant surgery in December, 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 standard, 180-day 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 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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