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Deutsche Bank National Trust Company v. Ventana Canyon Homeowners Association, Inc.

United States District Court, D. Nevada

February 9, 2018

DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE UNDER THE POOLING AND SERVICING AGREEMENT RELATING TO IMPAC SECURED ASSETS CORP., MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2006-4, Plaintiff,
v.
VENTANA CANYON HOMEOWNERS ASSOCIATION, INC.; NEVADA ASSOCIATION SERVICES, INC.; PREMIER ONE HOLDINGS, INC.; LIQUN HOLDINGS LIMITED; SHA LI, an individual TAI HUANG CHEN, an individual, Defendants.

          SARAH A. MORRIS, ESQ. Nevada Bar No. 8461 TIMOTHY A. WISEMAN, ESQ. Nevada Bar No. 13786 MORRIS LAW CENTER Attorneys for Sha Li, Tai Huan Chen and Premier One Holdings

          DARREN T. BRENNER, ESQ. Nevada Bar No.8386 JAMIE K. COMBS, ESQ. Nevada Bar No. 13088 AKERMAN LLP Attorneys for Deutsche Bank National Trust Company

          DAVID T. GLUTH, ESQ. Nevada Bar No 10596 PHIL WEN-SHENG SU, ESQ. Nevada Bar No. 10450 GORDON REES SCULLY MANSUKHANI LLP Attorneys for Ventana Homeowners Association, Inc.

          BANDON WOOD, ESQ. Nevada Bar No. 12900 Attorneys for Nevada Association Services, Inc.

          STIPULATION AND ORDER TO EXTEND DISCOVERY

         IT IS HEREBY STIPULATED by and between Defendant Premier One Holdings, Inc. (“Premier One”), Defendant Sha Li (“Sha Li”), Defendant Tai Huan Chen (“Tai Huan Chen”), Plaintiff Deutsche Bank National Trust Company, as Trustee Under the Pooling and Servicing Agreement Relating to IMPAC Secured Assets Corp., Mortgage Pass-Through Certificates, Series 2006-4, (“Deutsche Bank”)[1] and Defendant Ventana Canyon Homeowners Association (“Ventana HOA”) (referred to collectively as the parties) by and through their respective counsel to extend deadlines by 90 days from now, up to and including, May 8, 2018, to allow the parties to complete necessary discovery.

         A. REASON FOR REQUEST FOR EXTENSION OF DISCOVERY DEADLINES

         A scheduling order may be modified upon a showing of good cause and with the court's consent. Fed.R.Civ.P. 16(b)(4); LR 26-4. Good cause may be found if the parties can show they could not comply with the schedule due to the matter that could not been reasonably foreseen at the time of the issuance of the scheduling order. See Kuschner v. Nationstar Credit, Inc., 256 F.R.D. 684, 687 (E.D. Cal. 2009). Inadequate time remains in the scheduling order to complete all discovery for this litigation.

         The timelines previously proposed by the parties due to the administrative stay have proven inadequate to conduct full discovery. See ECF 45. Specifically, counsel has encountered scheduling difficulties with respect to the depositions of the Rule 30(b)(6) witnesses for Premier One Holdings and NAS.

         Additionally, Ventana HOA has recently noticed depositions for the Rule 30(b)(6) witness for Deutsche Bank, Mr. Rock Jung, and Mr. Matt Lubawy which are scheduled to occur shortly before the currently scheduled end of discovery. Parties will need additional time to conduct discovery based on the information learned from those depositions. An extension shall also provide additional time to attempt settlement negotiations in this matter. Accordingly, there is good cause to permit additional time for discovery here.

         B. PROPOSED SCHEDULE FOR COMLETING DISCOVERY

         1. Discovery Cut Off Date. The parties request the discovery be extended until Monday, May 8, 2018 (current deadline February 28, 2018).

         2. Expert Deadlines. The prior deadline to make initial expert disclosures expired August 22, 2016. As previously agreed, this deadline shall not be extended. See ECF 45.

         3. Rebuttal Expert Deadlines. the prior deadline to make initial expert disclosures expired September 21, 2016. As previously agreed, this deadline shall not be extended. See ECF 45.

         4. Dispositive Motion Deadline. The parties propose June 7, 2018 as the new dispositive motions deadline, thirty ...


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