United States District Court, D. Nevada
WELLS FARGO BANK, N.A., a national banking association, Plaintiff,
SFR INVESTMENTS POOL 1, LLC, a Nevada limited-liability company; HOMEOWNER ASSOCIATION SERVICES, INC., a Nevada corporation; THE FOOTHILLS AT MACDONALD RANCH MASTER ASSOCIATION, a Nevada nonprofit corporation;, Defendants. SFR INVESTMENTS POOL 1, LLC, a Nevada limited liability company, Counter-Claimant,
WELLS FARGO BANK, N.A., a national banking association; TRANSUNION SETTLEMENT SOLUTIONS, Counter-Defendant/Cross-Defendant.
GILBERT EBRON JACQUELINE A. GILBERT, ESQ., DIANA CLINE EBRON,
ESQ. KAREN L. HANKS, ESQ. ATTORNEYS FOR DEFENDANT SFR
INVESTMENTS POOL L, LLC
& WILMER L.L.P. JOHN S. DELIKANAKIS, ESQ. KIAH D.
BEVERLY-GRAHAM, ESQ. ATTORNEYS FOR PLAINTIFF WELLS FARGO
STIPULATION AND ORDER TO EXTEND DISCOVERY
to Fed.R.Civ.P. 26(f), and Local Rules 6-1, 26-1 and 26-4,
Wells Fargo Bank, N.A. ("Wells Fargo") and SFR
Investments Pool 1, LLC ("SFR" and together with
Wells Fargo, the "Parties"), by and through their
respective undersigned counsel of record, submit this
Stipulation and Proposed Order to extend the discovery
deadlines in this action by sixty days. This is the
Parties' first request for extension of the operative
Parties have served document demands and written discovery;
served answers and objections thereto;
Wells Fargo served its expert disclosures; and
person most knowledgeable for SFR appeared for deposition.
Discovery that Remains to be Completed
Wells Fargo's responses and objections to SFR's
requests for production and written discovery (the deadline
for these responses is upcoming);
Deposition of the person most knowledgeable for Wells Fargo;
Production of documents by non-party the Foothills at
MacDonald Ranch Master Association (the "HOA"); and
Deposition of the person most knowledgeable for the HOA.
Reasons Why Discovery ...