United States District Court, D. Nevada
JPMORGAN CHASE BANK, N.A. Plaintiff,
SFR INVESTMENTS POOL 1, LLC, a Nevada limited liability company; MOUNTAIN'S EDGE MASTER ASSOCIATION, a Nevada non-profit corporation; and DIAMOND CREEK HOMEOWNERS' ASSOCIATION, a Nevada non-profit corporation. Defendants. SFR INVESTMENTS POOL 1, LLC., a Nevada limited liability company, Counter-Claimant,
JPMORGAN CHASE BANK, N.A. Counter-Defendant. SFR INVESTMENTS POOL 1, LLC., a Nevada limited liability company, Cross-Claimant,
SIU MING PANG, an individual, Cross-Defendant.
E. Tasca, Russell J. Burke, Attorneys for Plaintiff.
Ballard Spahr LLP By: Russell J. Burke Abran Vigil, Esq.,
Russell J. Burke, Esq. Attorneys for JPMorgan Chase Bank,
Jaffe & Clayton, LLP By: Ashlie L. Surur Ashlie L. Surur,
Esq., Attorneys for Diamond Creek Homeowners'
Gilbert Ebron By: Diana S. Ebron Diana S. Ebron, Esq.
Attorneys for SFR Investments Pool 1, LLC.
STIPULATION AND ORDER TO EXTEND SCHEDULING ORDER
DEADLINES BY 30 DAYS
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 Diamond Creek Homeowners'
Association (“Diamond Creek”),  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.
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 Diamond Creek; and notice
of Rule 30(b)(6) deposition of Diamond 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.
Diamond 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 ...