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Gryglak v. Hsbc Bank USA, N.A.

United States District Court, D. Nevada

April 12, 2018

EDYTA GRYGLAK, formerly known as EDYTA A. FROMKIN, Plaintiff,
v.
HSBC BANK USA, N.A., as trustee for WELLS FARGO HOME EQUITY ASSET-BACKED CERTIFICATES, Series 2006-3, by its Attorney-in-fact WELLS FARGO BANK, N.A.; WELLS FARGO BANK, N.A.; and WELLS FARGO ASSET SECURITIES CORPORATION, Defendants.

          Amy F. Sorenson, Esq., Blakeley E. Griffith, Esq. SNELL & WILMER L.L.P. Attorneys for HSBC Bank USA, N.A., as Trustee for Wells Fargo Home Equity Asset-Backed Certificates, Series 2006-3, by its Attorney-in-fact Wells Fargo Bank, N.A., Wells Fargo Bank, N.A., and Wells Fargo Asset Securities Corporation

          Boris Avramski VEGAS WEST ATTORNEYS Attorney for Plaintiff

          STIPULATION AND ORDER TO EXTEND DISCOVERY DEADLINES (THIRD REQUEST)

         Defendants HSBC BANK USA, N.A., as trustee for WELLS FARGO HOME EQUITY ASSET-BACKED CERTIFICATES, Series 2006-3, by its Attorney-in-fact WELLS FARGO BANK, N.A.; WELLS FARGO BANK, N.A. (“Wells Fargo”); AND WELLS FARGO ASSET SECURITIES CORPORATION (collectively “Defendants”) and Plaintiff Edyta Gryglak (“Plaintiff” and together with Defendants, the “Parties”) by and through their counsel, hereby stipulate and request that this Court extend the remaining discovery deadlines in the above-captioned case by sixty (60) days. The current close of discovery is May 14, 2018, and the Parties seek an extension to July 13, 2018.

         This is the Parties' Third Request to extend the discovery deadlines. In support of this Stipulation, the Parties state as follows.

         A. REASONS WHY REMAINING DISCOVERY WAS NOT COMPLETED

         As previously noted to the Court, Defendants' counsel Blakeley E. Griffith, Esq., had taken the lead in litigating this case on behalf of Defendants, but was on leave pursuant to the Family Medical Leave Act (“FMLA”) through March 25, 2018. Unfortunately, counsel that took her place as lead, Jennifer L. McBee, Esq., had a health diagnosis in February that required her to have multiple out-of-town doctor appointments and required surgery. This unexpected medical issue caused the parties to request the second extension for discovery. Now, Ms. Griffith has returned from FMLA leave and is getting back up to speed on this case while Ms. McBee is now out on FMLA leave. Previously, the parties intended to respond to all written discovery by April 6, 2018 and have depositions take place in April. However, due to the Parties' schedules they were unable to schedule the depositions in April and these have been scheduled for early May instead. A significant reason for the delay in scheduling these depositions is Wells Fargo's extensive witness schedule. In Nevada alone, Wells Fargo is currently providing witnesses for hundreds of depositions. The Parties have worked together to schedule the depositions of Wells Fargo for May 11, 2018 and Mrs. Gryglak for May 15, 2018.[1] However, in an abundance of caution, the Parties wish to extend discovery for an additional sixty (60) days in case any third party deposition is necessary after the depositions of Plaintiff and Wells Fargo. The Parties acknowledge that it is not typical to have three extensions of discovery and do not seek such an extension lightly. Unfortunately, due to the circumstances noted above it has been necessary in this case.

         The Parties have been working diligently to litigate this action, with a dispositive motion having recently been ruled on and written discovery propounded by all Parties. Further, Plaintiff recently filed a Motion for Reconsideration and Defendants' opposition is due on April 16, 2018. Extending the close of discovery and dispositive motion deadlines will allow additional time for counsel to take the depositions and schedule any further depositions if necessary.

         The Parties do not seek an extension for any improper purpose, or for the purpose of delay. Additionally, an extension of time will not prejudice the Parties, as all counsel explicitly consents to the requested extension. Finally, the Parties are only requesting an extension of the close of discovery, dispositive motions, and the joint pretrial order, and request that these deadlines be extended, as detailed below.

         B. DISCOVERY COMPLETED TO DATE

         The following discovery has been completed:

1. Defendants responded to Plaintiff's written discovery on March 23, 2018.
2. Plaintiff will respond to Defendant's written discovery on April 20, 2018.
3. The Parties have scheduled depositions of the Plaintiff for May 15, 2018 and of Wells Fargo for May 11, 2018.

         C. DISCOVERY THAT ...


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