United States District Court, D. Nevada
E. Vigil Nevada Bar No. 7548 Russell J. Burke Nevada Bar No.
12710 BALLARD SPAHR LLP Attorneys for
Ballard Spahr LLP By: Russell J. Burke Abran Vigil, Esq. NV
Bar No. 7548 Attorneys for JPMorgan Chase Bank, N.A.
Jaffe & Clayton, LLP By: Ashlie L. Surur NV Bar No. 11290
Attorneys for Sutter Creek Homeowners' Association
Gilbert Ebron B Dia Diana S. Ebron NV Bar N Ebron 580 Esq.
Attorneys for SFR Investments Pool 1, LLC
STIPULATION AND ORDER TO EXTEND SCHEDULING ORDER
DEADLINES BY 30 DAYS (SECOND REQUEST)
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 Sutter Creek
Homeowners' Association (“Sutter Creek”),
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 an
additional 30 days, to permit the parties to complete party
depositions, and specifically the deposition of Chase, whose
designated witness who underwent significant surgery in
December and from which she will not have recuperated until
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
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; first set of requests
for production and interrogatories to SFR; notice of Rule
30(b)(6) deposition of SFR; first set of requests for
production and interrogatories to Sutter Creek; and notice of
Rule 30(b)(6) deposition of Sutter Creek.
date, SFR has served the following discovery: initial
disclosures; first set of requests for production,
interrogatories, and requests for admissions 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.
Sutter Creek has served the following discovery: initial
Specific Description of Discovery that Remains to be
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
February 28, 2018. 
has also noticed the Rule 30(b)(6) deposition of SFR and
Good Cause Exists for the ...