United States District Court, D. Nevada
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,
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.
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
T. BRENNER, ESQ. Nevada Bar No.8386 JAMIE K. COMBS, ESQ.
Nevada Bar No. 13088 AKERMAN LLP Attorneys for Deutsche Bank
National Trust Company
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.
WOOD, ESQ. Nevada Bar No. 12900 Attorneys for Nevada
Association Services, Inc.
STIPULATION AND ORDER TO EXTEND DISCOVERY
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”) 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.
REASON FOR REQUEST FOR EXTENSION OF DISCOVERY DEADLINES
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.
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.
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.
PROPOSED SCHEDULE FOR COMLETING DISCOVERY
Discovery Cut Off Date. The parties request the discovery be
extended until Monday, May 8, 2018 (current deadline February
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.
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.
Dispositive Motion Deadline. The parties propose June 7, 2018
as the new dispositive motions deadline, thirty ...