HSBC Bank USA, N.A. v. Wu et al

Filing 35

ORDER re: 34 STIPULATION re Discovery Deadlines. Discovery due by 8/3/2018. Motions due by 9/4/2018. Proposed Joint Pretrial Order due by 10/4/2018. Signed by Magistrate Judge Carl W. Hoffman on 5/31/2018. (Copies have been distributed pursuant to the NEF - MMM)

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Joel E. Tasca
Nevada Bar No. 14124
Holly Ann Priest
Nevada Bar No. 13226
BALLARD SPAHR LLP
1980 Festival Plaza Drive, Suite 900
Las Vegas, NV 89135
Telephone: [phone]
Facsimile: [phone]
[e-mail]
[e-mail]

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Attorneys for HSBC Bank USA, N.A.

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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

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HSBC BANK USA, N.A.,

[phone] FAX [phone]

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LAS VEGAS, NEVADA 89135

BALLARD SPAHR LLP

1980 FESTIVAL PLAZA DRIVE, SUITE 900

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Plaintiff,

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vs.

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IRIS WU, an individual; NEWPORT
COVE CONDOMINIUM UNIT-OWNERS
ASSOCIATION, INC., a Nevada nonprofit corporation; MATTHEW AYRES,
an individual,

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Case No. 2:16-CV-02786-APG-CWH
STIPULATED AND PROPOSED
ORDER TO AMEND SCHEDULING
ORDER (ECF NO. 28)
(Second Request)

Defendants.
______________________________________
IRIS WU,

Counter-Claimant,

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vs.

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HSBC BANK USA, N.A.;
DOES 1 through X and ROE BUSINESS
ENTITIES 1 through X,

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Counter-Defendants.
Pursuant to Fed. R. Civ. P. 16(b)(4), LR IA 6-1 and LR 26-4, Plaintiff HSBC
Bank USA, N.A. (“HSBC”), Defendant Newport Cove Condominium Unit-Owners
Association, Inc. (the “HOA”), and Defendants Iris Wu (“Wu”) (collectively, the
“Parties”) by and through their undersigned counsel of record, hereby stipulate to

DMWEST #17770591 v1

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amend the Scheduling Order approved on November 13, 2017 (ECF No. 28). This is

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the Parties first request for an extension of the subject deadlines.

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A.

Discovery completed: HSBC served initial disclosures on December 06,

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2017. HSBC served its initial expert disclosure on March 3, 2018. HSBC served

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written discovery on the defendants and the deposition of a third party, Alessi &

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Koenig, was taken by HSBC.

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B.

Discovery to Be Completed:

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1.

Continued production of documents as they are located;

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2.

Written discovery responses;

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3.

Deposition of Parties and third parties.

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Current Discovery Deadlines:

[phone] FAX [phone]

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LAS VEGAS, NEVADA 89135

BALLARD SPAHR LLP

1980 FESTIVAL PLAZA DRIVE, SUITE 900

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1.

Discovery cut-off: June 4, 2018

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2.

Dispositive motions: July 5, 2018

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3.

Joint pretrial order: August 6, 2018

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D.

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The Parties seek to extend discovery and scheduling dates 30 days. On April 2,

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2018, HSBC noticed the deposition of Wu and the deposition was scheduled for April

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30, 2018. Wu had a scheduling conflict and did not appear for the deposition. To

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accommodate Wu’s schedule, the parties extended the deadlines 30 days to allow

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HSBC to reset her deposition. However, counsel for Wu informed counsel for HSBC

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that Wu is now out of the state for work until end of July. As such, the parties agreed

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to extend the discovery schedule to allow the deposition of Wu to move forward. The

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brief extension will give HSBC time to re-notice the deposition. Further, no parties

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will be prejudiced by the brief extension to discovery.

Reason for Extending Discovery Plan Deadlines

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E.

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Accordingly, all Parties hereby stipulate and jointly request that the Court

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Proposed Schedule for Completed Discovery:

enter an Amended Scheduling Order to establish the following deadlines:
1.

Discovery cut-off: August 3, 2018
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2.

Dispositive motions: September 4, 2018

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3.

Joint pretrial order: October 4, 2018

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The Parties make this request in good faith and not for the purposes of delay.

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IT IS SO STIPULATED this 25th day of May, 2018.

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BALLARD SPAHR LLP

HONG & HONG

By:

By: /s/ Joseph Y. Hong
Joseph Y. Hong, Esq.
Nevada Bar No.: 5995
10781 W. Twain Ave
Las Vegas, Nevada 89135

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[phone] FAX [phone]

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LAS VEGAS, NEVADA 89135

BALLARD SPAHR LLP

1980 FESTIVAL PLAZA DRIVE, SUITE 900

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/s/ Holly Ann Priest
Joel E. Tasca
Nevada Bar No. 14124
Holly Ann Priest
Nevada Bar No. 13226
Kyle A. Ewing
Nevada Bar No. 14051
Nevada Bar No.
1980 Festival Plaza Drive, Suite 900
Las Vegas, Nevada 89135

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Attorneys for Plaintiff/Counterdefendant HSBC Bank USA, N.A.

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HOA LAWYERS GROUP, LLC

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By: /s/ Steven T. Loizzi
Steven T. Loizzi, Esq.
Nevada Bar No. 10920
9500 W. Flamingo, Suite 204
Las Vegas, Nevada 89147
ORDER
IT IS SO ORDERED.

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_____________________________________
United States District/Magistrate Judge
May 31, 2018
DATED: ________________________

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