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

United States District Court, D. Nevada

February 2, 2018

JPMORGAN CHASE BANK, N.A., Plaintiff,
v.
SFR INVESTMENTS POOL 1, LLC, a Nevada limited liability company; and SUTTER CREEK HOMEOWNERS ASSOCIATION, a Nevada non-profit corporation, Defendants. SFR INVESTMENTS POOL 1, LLC, a Nevada limited liability company, Counterclaimant,
v.
JPMORGAN CHASE BANK, N.A.; Counter-Defendant. SFR INVESTMENTS POOL 1, LLC, a Nevada limited liability company, Cross-Claimant,
v.
WAI CHUNG NG, an individual, Cross- Defendant.

          Abran E. Vigil Nevada Bar No. 7548 Russell J. Burke Nevada Bar No. 12710 BALLARD SPAHR LLP Attorneys for Plaintiff/Counter-Defendant

          Ballard Spahr LLP By: Russell J. Burke Abran Vigil, Esq. NV Bar No. 7548 Attorneys for JPMorgan Chase Bank, N.A.

          Hall, Jaffe & Clayton, LLP By: Ashlie L. Surur NV Bar No. 11290 Attorneys for Sutter Creek Homeowners' Association

          Kim 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)

         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 Sutter Creek Homeowners' Association (“Sutter Creek”), [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 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 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 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.

         To 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.

         To date Sutter Creek 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 February 28, 2018. [2]

         Chase has also noticed the Rule 30(b)(6) deposition of SFR and Sutter Creek.

         C. Good Cause Exists for the ...


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