Bank of America, N.A. v. Premier One Holdings, Inc. et al

Filing 49

ORDER Granting 48 Stipulation to Take Rule 30(B)(6) Deposition Outside the Close of Discovery. Signed by Magistrate Judge Nancy J. Koppe on 3/8/16. (Copies have been distributed pursuant to the NEF - TR)

Case 2:15-cv-00860-JCM-NJK Document 48 Filed 03/07/16 Page 1 of 3

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LIPSON, NEILSON, COLE, SELTZER & GARIN, P.C.
JOSEPH P. GARIN, ESQ.
Nevada Bar No. 6653
SIRIA L. GUTIERREZ, ESQ.
Nevada Bar No. 11981
9900 Covington Cross Drive, Suite 120
Las Vegas, Nevada 89144
[phone] - Telephone
[phone] - Facsimile
[e-mail]
[e-mail]

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Attorneys for Augusta Belford and Ellingwood HOA

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UNITED STATES DISTRICT COURT
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DISTRICT OF NEVADA
BANK OF AMERICA, N.A.,

CASE NO.: 2:15-CV-00860-JCM-NJK

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Plaintiff.
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9900 Covington Cross Drive, Suite 120
Las Vegas, Nevada 89144
[phone] FAX: [phone]

Lipson, Neilson, Cole, Seltzer & Garin, P.C.

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vs.
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PREMIER ONE HOLDINGS, INC.;
AUGUSTA BELFORD AND
ELLINGWOOD HOMEOWNERS
ASSOCIATION; DOE INDIVIDUALS I-X,
inclusive, and ROE CORPORATIONS I-X,
inclusive,

STIPULATION AND ORDER TO TAKE
RULE 30(B)(6) DEPOSITION OF
AUGUSTA BELFORD AND
ELLINGWOOD HOMEOWNERS
ASSOCIATION HOA OUTSIDE THE
CLOSE OF DISCOVERY
(FIRST REQUEST)

Defendants.

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IT IS HEREBY STIPULATED by and between the parties through their respective

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counsel to take the deposition of 30(b)(6) Witness for AUGUSTA BELFORD AND

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ELLINGWOOD HOMEOWNERS ASSOCIATION (“Augusta Belford”) on or before March

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29, 2016, outside the close of discovery. Discovery closes on March 9, 2016. The parties
further stipulate and understand that the taking of this deposition outside the close of

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discovery will not affect or alter the any pending deadlines, the dispositive motions

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deadline or the joint pre-trial deadline. The parties are not seeking an extension of any

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deadlines.

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Case 2:15-cv-00860-JCM-NJK Document 48 Filed 03/07/16 Page 2 of 3

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REASONS FOR NECESSITY OF STIPULATION

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Bank of America noticed Augusta Belford’s FRCP 30(b)(6) deposition to take

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place on March 8, 2016. August Belford timely notified Bank of America’s counsel that

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the Association’s designated witness was unavailable on the noticed date due to a prior

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commitment and is available later this month. In an effort to cooperate and

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accommodate the deponent’s schedule, the parties have agreed to conduct Augusta

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Belford’s FRCP 30(b)(6) deposition, on or before March 29, 2016. All other discovery

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has been completed or will be completed in this matter during the discovery period. This

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stipulation is made by the parties in good faith, not for the purpose of delay, and is also
a professional courtesy to accommodate the deponent.
DISCOVERY COMPLETED

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9900 Covington Cross Drive, Suite 120
Las Vegas, Nevada 89144
[phone] FAX: [phone]

Lipson, Neilson, Cole, Seltzer & Garin, P.C.

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1)

November 4, 2015

2)

BANA served responses to Augusta Belford’s
Written discovery

January 15, 2016

3)

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Augusta Belford served written discovery

BANA served written discovery on Augusta Belford
And Premier One Holdings, Inc.

February 5, 2016

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DISCOVERY PENDING
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1)

March 8, 2016

BANA Deposition of
Nevada Association Services, Inc.

March 8, 2016

3)

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BANA deposition of Premier One Holdings,
Inc. 30(b)(6) Witness

2)

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Premier One Holdings, Inc. deposed 30(b)(6)
Witness for BANA

March 8, 2016

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Page 2 of 3

Case 2:15-cv-00860-JCM-NJK Document 48 Filed 03/07/16 Page 3 of 3

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This stipulation is made in good faith and not for purposes of delay.

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DATED this 7th day of March, 2016.

DATED this 7th day of March, 2016.

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LIPSON, NEILSON, COLE, SELTZER &
GARIN, P.C.

AKERMAN, LLP

By: /s/ Siria L. Gutierrez
Joseph P. Garin, Esq.
Siria L. Gutierrez, Esq.
9900 Covington Cross Dr., Suite 120
Las Vegas, NV 89144

By: /s/ Donna M. Wittig
Ariel E. Stern, Esq.
Donna M. Wittig, Esq.
1160 Town Center Dr., Ste. 330
Las Vegas, NV 89144

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9900 Covington Cross Drive, Suite 120
Las Vegas, Nevada 89144
[phone] FAX: [phone]

Lipson, Neilson, Cole, Seltzer & Garin, P.C.

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Attorneys for Plaintiffs

Attorneys for Augusta Belford and
Ellingwood HOA

DATED this 7th day of March, 2016.

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MORRIS & MORRIS

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By: /s/ Sarah A. Morris
Sarah A. Morris, Esq.
Brian A. Morris, Esq.
6085 W. Twain Avenue, Suite 201
Las Vegas, NV 89103
Attorneys for Premier One Holdings, Inc.

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ORDER

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IT IS SO ORDERED.
DATED this 8th

day of March

, 2016.

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UNITED STATES MAGISTRATE JUDGE

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