JPMorgan Chase Bank, N.A. v. G2 Ventures LLC et al

Filing 57

ORDER Granting 56 Stipulation re Discovery Deadlines. Discovery due by 2/27/2018. Motions due by 3/28/2018. Proposed Joint Pretrial Order due by 4/26/2018. Signed by Magistrate Judge Nancy J. Koppe on 1/12/2018. (Copies have been distributed pursuant to the NEF - MMM)

Case 2:17-cv-01576-RFB-NJK Document 56 Filed 01/11/18 Page 1 of 4

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Abran E. Vigil
Nevada Bar No. 7548
Stacy H. Rubin
Nevada Bar No. 9298
BALLARD SPAHR LLP
1980 Festival Plaza Drive, Suite 900
Las Vegas, Nevada 89135
Telephone: [phone]
Facsimile: [phone]
[e-mail]
[e-mail]

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Attorneys for Plaintiff JPMorgan

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Chase Bank, N.A.

DISTRICT OF NEVADA

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JPMORGAN CHASE BANK, N.A.,

[phone] FAX [phone]

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LAS VEGAS, NEVADA 89135-2958

BALLARD SPAHR LLP

UNITED STATES DISTRICT COURT

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ONE SUMMERLIN, 1980 FESTIVAL PLAZA DRIVE, SUITE 900

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Plaintiff,

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vs.

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G2 VENTURES LLC, a Nevada limited
liability company; ARBUCKLE DRIVE
HOMEOWNERS ASSOCIATION, INC., a
Nevada non-profit corporation; PATRICIA
K. PURCELL; and LEONARD D.
PURCELL,

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Case No. 2:17-cv-01576-RFB-NJK

STIPULATION AND ORDER TO
EXTEND SCHEDULING ORDER
DEADLINES BY 30 DAYS
(Second Request)

Defendants.

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Pursuant to LR IA 6-1 and LR 26-4, Plaintiff JPMORGAN CHASE BANK N.A.

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(“Chase”), Defendant ARBUCKLE DRIVE HOMEOWNERS ASSOCIATION, INC.

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(“Arbuckle”), and Defendant G2 VENTURES LLC (“G2”), (collectively, the “Parties”),

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by and through their respective counsel of record, stipulate and request that this

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Court extend discovery and dispositive motion deadlines in the above-captioned case

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for 30 days, to permit the Parties to efficiently complete party depositions and

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outstanding

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designated witness underwent significant surgery in late December, from which she

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will not have recuperated until February 2018. The Parties agree that this brief

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extension is the most reasonable way to complete discovery in this case, including so

written

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discovery—specifically

the

deposition

of

Chase,

whose

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that Chase’s designated witness has sufficient time to attend to necessary medical

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treatment and recuperate for her deposition.

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This is the Parties’ second request for an extension to the scheduling order

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deadlines, which were submitted in compliance with LR 26-1. The Parties make this

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request in good faith and not for purposes of delay.

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A.

Discovery Completed to Date

Alessi & Koenig, LLC. (“Alessi”); subpoena for deposition testimony to Alessi

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(scheduled for January 22, 2018); requests for production to Arbuckle; interrogatories

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[phone] FAX [phone]

30(b)(6) deposition of G2 (scheduled for January 16, 2018); subpoena duces tecum to

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LAS VEGAS, NEVADA 89135-2958

expert disclosure; requests for production to G2; interrogatories to G2; notice of Rule

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BALLARD SPAHR LLP

To date, Chase has served the following discovery: initial disclosures; initial

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ONE SUMMERLIN, 1980 FESTIVAL PLAZA DRIVE, SUITE 900

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to Arbuckle; and notice of Rule 30(b)(6) deposition of Arbuckle (scheduled for January

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17, 2018).
To date, G2 has served the following discovery: requests for production to

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Chase and interrogatories to Chase.
To date, Arbuckle has served the following discovery:

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initial disclosures;

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requests for production to Chase; interrogatories to Chase; and requests for

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admission to Chase.

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B.

Specific Description of Discovery that Remains to be Completed

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The Parties are awaiting responses to the served discovery requests. Arbuckle

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and Chase have been working to schedule the Rule 30(b)(6) deposition of Chase. As

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discussed below, however, the Parties seek to reschedule Chase’s Rule 30(b)(6)

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deposition to occur after the current discovery cutoff of January 28, 2018 to

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accommodate the Chase designee’s recovery from surgery. 1

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///

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///

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The Parties further reserve their rights to meet and confer and, if necessary, engage
in motion practice regarding any discovery issues that may arise.
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C.

Good Cause Exists for the Requested Extension

currently recovering.

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deposition of Chase. While it is not certain at this point when her doctor will clear

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her, the Parties have met and conferred about rescheduling Chase’s deposition in this

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lawsuit near the end of February 2018, when the Chase designee is fully recuperated

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from surgery and able to be deposed. Accordingly, the Parties seek an additional 30

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days for discovery to conduct this party deposition and provide adequate time for the

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witness to receive and review the deposition transcript and for the Parties to finalize

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[phone] FAX [phone]

would be undergoing significant surgery in late December, from which she is

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LAS VEGAS, NEVADA 89135-2958

cutoff and subsequent deadlines (ECF No. 54), counsel learned that the designee

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BALLARD SPAHR LLP

After the Court entered the Order on the stipulation to extend the discovery

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ONE SUMMERLIN, 1980 FESTIVAL PLAZA DRIVE, SUITE 900

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their disclosures. This is the Parties’ second request to extend the discovery period in

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this case, and they seek the extension so that Chase’s designated witness may have

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an opportunity to receive necessary medical treatment and recover from the same,

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which treatment and recovery were not anticipated at the time the Parties filed their

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stipulation to extend the discovery period and/or at the time the Court entered an

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Order thereon (ECF No. 54). The Parties have diligently engaged in discovery to

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date, met and conferred regarding the requested extension and scheduling of

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outstanding discovery items, and seek this extension in good faith.

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D.

Chase and Arbuckle have been attempting to schedule the

Proposed Discovery Deadlines

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As a result of the foregoing, the Parties request an order extending the close of

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discovery, the deadline to file dispositive motions, and the deadline to file a pre-trial

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order by 30 days:

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Event

January 28, 2018

February 27, 2018

Dispositive Motions

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New Deadline

Close of Discovery

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Current Deadline 2

February 26, 2018

March 28, 2018

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See Order, ECF No. 54.
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Pre-Trial Order

March 27, 2018

April 26, 2018

This requested extension is reasonable and necessary given the good cause set
forth above.

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IT IS SO STIPULATED.

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Respectfully submitted this 11th day of January, 2018.

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[phone] FAX [phone]

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LAS VEGAS, NEVADA 89135-2958

BALLARD SPAHR LLP

ONE SUMMERLIN, 1980 FESTIVAL PLAZA DRIVE, SUITE 900

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GIBBS GIDEN LOCHER TURNER
SENET & WITTBRODT LLP

BALLARD SPAHR LLP

By: /s/ Timothy P. Elson
Matthew L. Grode
Nevada Bar No. 6326
Timothy P. Elson
Nevada Bar No. 11559
1140 N. Town Center Drive
Suite 300
Las Vegas, Nevada 89144-0596

By: /s/ Stacy H. Rubin
Abran E. Vigil
Nevada Bar No. 7548
Stacy H. Rubin
Nevada Bar No. 9298
1980 Festival Plaza Drive, Suite 900
Las Vegas, Nevada 89135

Attorneys for Plaintiff JPMorgan

Attorneys for Defendant

Arbuckle Drive Homeowners
Association, Inc.

Chase Bank, N.A.

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THE WRIGHT LAW GROUP, P.C.

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By: /s/ John Henry Wright
John Henry Wright
Nevada Bar No. 6182
2340 Paseo Del Prado, Suite D-305
Las Vegas, Nevada 89102

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Attorney for Defendant
G2 Ventures LLC

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ORDER

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IT IS SO ORDERED.

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___________________________________
UNITED STATES MAGISTRATE JUDGE

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January 12, 2018
DATED: __________________________

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