Wells Fargo Financial Nevada 2, Inc. v. Haddad et al

Filing 39

ORDER granting 38 Stipulation to Extend Discovery Deadlines. Discovery due by 7/19/2018. Motions due by 8/17/2018. Signed by Magistrate Judge Carl W. Hoffman on 6/13/2018. (Copies have been distributed pursuant to the NEF - MMM)

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Kelly H. Dove, Esq.
Nevada Bar No. 10569
Michael Paretti, Esq.
Nevada Bar No. 13926
SNELL & WILMER L.L.P.
3883 Howard Hughes Parkway, Suite 1100
Las Vegas, Nevada 89169
Telephone: [phone]
Facsimile: 702-784-5252
Email: [e-mail]
[e-mail]
Attorneys for Plaintiff Wells Fargo Financial Nevada 2, Inc.

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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

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Snell & Wilmer

L.L.P.
LAW OFFICES
3883 Howard Hughes Parkway, Suite 1100
Las Vegas, Nevada 89169
702.784.5200

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WELLS FARGO FINANCIAL NEVADA 2,
INC., a Nevada corporation,
Plaintiff,

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vs.

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EDDIE HADDAD, an individual; DESERT
INN MOBILE FAMILY ESTATES OWNERS
ASSOCIATION; a Nevada non-profit
corporation; VIAL FOTHERINGHAM LLP,
an Oregon limited-liability partnership;

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Case No. 2:17-cv-01511-RFB-CWH

STIPULATION AND ORDER TO
EXTEND DISCOVERY DEADLINES

(FIRST REQUEST)

Defendants.

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Plaintiff Wells Fargo Financial Nevada 2, Inc. (“Wells Fargo”) and Eddie Haddad

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(“Haddad”), by and through their respective counsel (collectively the “Parties”), for good cause

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shown, hereby stipulate and agree to extend the discovery cut-off deadline in this action by 30

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days to allow the Parties to reschedule and conduct depositions due to the Parties’ scheduling

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constraints. This request complies with Local Rule (“LR”) 6-1, 6-3, 7-1, and 26-4, and is based on

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good cause because the litigation of this matter will be best served by the proposed extension.

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This is the Parties’ first extension request.

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I.

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GOOD CAUSE FOR EXTENSION TO COMPLETE DISCOVERY
Pursuant to Federal Rule of Civil Procedure 6(b)(1) and Local Rule 6-1, there exists good

cause to grant this extension to respond for the following reasons:

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1.

On May 21, 2018, Wells Fargo served deposition notices on Haddad and non-party

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the Desert Inn Mobile Family Estates Owners Association (the “HOA”) for depositions to occur

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on June 6 and June 15, 2018, respectively.

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2.

June 6, 2018, but has not yet provided alternative availability.

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3.

L.L.P.
LAW OFFICES
3883 Howard Hughes Parkway, Suite 1100
Las Vegas, Nevada 89169
702.784.5200

Snell & Wilmer

Additionally, on June 8, 2018, the HOA’s counsel advised Wells Fargo’s counsel

that the HOA’s Rule 30(b)(6) witness was unavailable for a deposition on June 15.

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Haddad’s counsel advised Wells Fargo’s counsel that Haddad was unavailable on

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Wells Fargo’s counsel and the HOA’s counsel are working to rescheduled the

HOA’s Rule 30(b)(6) deposition to a mutually agreeable time.

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5.

Due to the parties’ and their counsels’ availability, the parties are unable to

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conduct Haddad’s deposition or the HOA’s deposition before the current discovery deadline of

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June 19, 2018.

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6.

Therefore, good cause exists to extend the discovery cut-off deadline by 30 days,

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to July 19, 2018, for Wells Fargo to conduct Haddad’s and the HOA’s respective depositions.

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II.

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DISCOVERY COMPLETED TO DATE
To date the Parties have completed the following discovery:

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

Wells Fargo made its initial FRCP 26(a)(1) disclosure on May 7, 2017.

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

Haddad made his initial FRCP 26(a)(1) disclosure on January 22, 2018.

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

Wells Fargo made its initial expert disclosure on March 19, 2018.

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

Haddad served his first set of Interrogatories, Requests for Production of

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Documents, and Requests for Admission on Wells Fargo on March 19, 2018.

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o Wells Fargo responded to Haddad’s requests on May 7, 2018.
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Wells Fargo served its first set of Interrogatories, Requests for Production of
Documents, and Requests for Admission on Haddad on May 17, 2018.
o Haddad’s responses are currently due June 19, 2018.
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

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Wells Fargo on May 21, 2018.

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Haddad served his second set of Interrogatories, and Requests for Admission on

o Wells Fargo’s responses are currently due June 25, 2018.
III.

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DISCOVERY TO BE COMPLETED
The parties anticipate that the following discovery still needs to be completed:

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

Deposition of the HOA’s corporate representative.

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

Deposition of Haddad.

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IV.

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PROPOSED NEW DEADLINES
Discovery cut-off deadline:

Snell & Wilmer

Currently: June 19, 2018

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L.L.P.
LAW OFFICES
3883 Howard Hughes Parkway, Suite 1100
Las Vegas, Nevada 89169
702.784.5200

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Proposed: July 19, 2018.

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Dispositive motions:

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Currently: July 19, 2018

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Proposed: August 17, 2018.

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V.

CONCLUSION
For the foregoing reasons, the Parties respectfully request that the Court grant their

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request to continue the discovery deadlines detailed herein by thirty (30) days.

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Dated: June 12, 2018

Dated: June 12, 2018

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SNELL & WILMER L.L.P.

LAW OFFICES OF MICHAEL S. BOHN,
ESQ., LTD.

By: /s/ Michael Paretti
Kelly H. Dove, Esq.
Nevada Bar No. 10569
Michael Paretti, Esq.
Nevada Bar No. 13926
3883 Howard Hughes Parkway, Suite 1100
Las Vegas, NV 89169

By: /s/ Michael F. Bohn
Michael F. Bohn, Esq.
Nevada Bar No. 1641
Adam R. Trippiedi, Esq.
Nevada Bar No. 12294
2260 Corporate Circle, Ste. 480
Henderson, Nevada 89074
Attorneys for Defendant Eddie Haddad

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Snell & Wilmer

L.L.P.
LAW OFFICES
3883 Howard Hughes Parkway, Suite 1100
Las Vegas, Nevada 89169
702.784.5200

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Attorneys for Plaintiff Wells Fargo
Financial Nevada 2, Inc.

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ORDER
IT IS ORDERED.
June
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DATED this ____ day of _______________ 2018.

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_______________________________________
UNITED STATES MAGISTRATE JUDGE

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Case 2:17-cv-01511-RFB-CWH Document 38 Filed 06/12/18 Page 5 of 5

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CERTIFICATE OF SERVICE

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I, the undersigned, declare under penalty of perjury, that I am over the age of eighteen

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(18) years, and I am not a party to, nor interested in, this action. On this date, I caused to be

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served a true and correct copy of the foregoing STIPULATION AND ORDER TO EXTEND

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DISCOVERY DEADLINES (FIRST REQUEST) by the method indicated:

U.S. Certified Mail

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Facsimile Transmission

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Overnight Mail

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Federal Express

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Snell & Wilmer

U.S. Mail

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L.L.P.
LAW OFFICES
3883 Howard Hughes Parkway, Suite 1100
Las Vegas, Nevada 89169
702.784.5200

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Hand Delivery

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X

Electronic Filing

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and addressed to the following:
Michael F. Bohn, Esq.
Adam R. Trippiedi, Esq.
Law Offices of Michael F. Bohn, Esq., Ltd.
2260 Corporate Circle, Suite 480
Henderson, NV 89074
Attorneys for Defendant Eddie Haddad 

DATED June 12, 2018

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/s/ Maricris Williams
An Employee of Snell & Wilmer L.L.P.

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4829-1084-6313

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