United States District Court, D. Nevada
WRIGHT, FINLAY & ZAK, LLP R. Samuel Ehlers, Esq. Nevada
Bar No. 9313 Attorneys for Plaintiff, Bank of America, N.A.
FINLAY & ZAK Aaron D Lancaster, Esq. Nevada Bar No. 10115
Plaintiff, Bank of America, N.A.
JOHNSON SONG & GRUCHOW Sean L. Anderson, Esq. Nevada Bar
No. 7259 T. Chase Pittsenbarger, Esq. Nevada Bar No. 13740
Attorneys for Defendant Indigo Homeowners' Association
SCHWARTZ FLANSBURG Andrew P. Dunning, Esq. Attorneys for
Defendant George Peter Lee
STIPULATION AND ORDER TO EXTEND DISCOVERY DEADLINES
to Local Rules 6-1 and 26-4, Plaintiff, BANK OF AMERICA, N.A.
(“BANA”), through its counsel of record, Aaron D.
Lancaster, Esq., GEORGE PETER LEE (“Mr. Lee”),
through its counsel of record, Andrew P. Dunning, Esq. and
INDIGO HOMEOWNERS ASSOCIATION (“HOA”), through
its counsel of record T. Chase Pittsenbarger, Esq., submit
this Stipulation and Order to extend discovery by one hundred
and eighty (180) days. This is the parties' first request
for an extension.
dispute arises out of Plaintiff's complaint, which asks
the Court for a determination and declaration: (1) quiet
title/declaratory relief of the subject property, (2)
injunctive relief, (3) Unjust enrichment, (4) wrongful
foreclosure, (5) negligence, (6) negligence per se, (7)
breach of contract, (8) misrepresentation, and (9) tortious
interference of contract.
matter an Order Granting Motion for Default Judgment [ECF No.
45] was entered on February 7, 2018, against Defendants
George Peter Lee and Bridger Investment LLC. After the entry
of the Order Granting Motion for Default Judgment counsel
made an appearance on behalf of the Defendant George Peter
Lee [ECF No. 46]. On March 28, 2018, the Court entered a
Stipulation and Order Limited Stay as to Claims Asserted
Against Indigo Homeowners' Association [ECF No. 53].
parties have filed a Stipulation and Order to: (1) Set Aside
Clerk's Default; and (2) Vacate Default Judgment Against
Defendant George Peter Lee [ECF No. 58]. Further, the parties
have requested the Stipulation and Order Limited Stay as to
Claims Asserted Against Indigo Homeowners' Association
[ECF No. 53] be lifted and set aside. Now, the parties
stipulate to an extension of discovery by one hundred and
eighty (180) days.
STATEMENT SPECIFYING THE DISCOVERY
November 21, 2017, the Court entered a Scheduling Order which
set the following deadlines:
(a) Discovery Cut Off: 3/28/2018
(b) Last day to file motions to amend pleadings or add