JPMorgan Chase Bank N.A. v. TerraFirma Venture LLC et al

Filing 27

ORDER Granting 26 Stipulation for Extension of Time (First Request) re Deadlines. Discovery due by 3/7/2018. Motions due by 4/6/2018. Proposed Joint Pretrial Order due by 5/7/2018. Signed by Magistrate Judge Nancy J. Koppe on 11/17/2017. (Copies have been distributed pursuant to the NEF - SLD)

Case 2:17-cv-01928-RFB-NJK Document 26 Filed 11/16/17 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
100 North City Parkway, Suite 1750
Las Vegas, Nevada 89106
Telephone: [phone]
Facsimile: [phone]
[e-mail]
[e-mail]

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Attorneys for JPMorgan Chase Bank, N.A.

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UNITED STATES DISTRICT COURT

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[phone] FAX [phone]

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LAS VEGAS, NEVADA 89106

BALLARD SPAHR LLP

100 NORTH CITY PARKWAY, SUITE 1750

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DISTRICT OF NEVADA
JPMORGAN CHASE BANK, N.A.,
Plaintiff,

Case No. 2:17-cv-01928-RFB-NJK

vs.

S TIPULATION AND ORDER TO
E XTEND SCHEDULING ORDER
TERRAFIRMA VENTURE LLC, a Nevada DEADLINES BY 30 DAYS
limited liability company; AZURE
ESTATES OWNERS ASSOCIATION, a
( First Request)
Nevada non-profit corporation;
ADRIENNE LOVE, an individual,
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 Terrafirma Venture LLC (“Terrafirma”) and Defendant Azure

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Estates Owners Association (“Azure”), by and through their counsel of record, hereby

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stipulate and request that this Court extend discovery and dispositive motion

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deadlines in the above-captioned case for 30 days, to permit the parties to complete

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written discovery and party depositions. The parties have conferred and agree that

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this brief extension is the most reasonable given the Chapter 7 bankruptcy filing of

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nominal Defendant Adrienne Love. See Notice of Bankruptcy Filing, at ECF No. 25.

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A Motion for Relief from Automatic Stay is pending before the United States

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Bankruptcy Court for the Central District of California.

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Case 2:17-cv-01928-RFB-NJK Document 26 Filed 11/16/17 Page 2 of 4

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This is the parties’ first request for an extension to the discovery deadlines,

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which were submitted in compliance with LR 26-1. The parties make this request in

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good faith and not for purposes of delay.

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I.

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Discovery Completed to Date
To date, Chase has served initial disclosures. No other discovery has been

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served.

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II.

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Discovery that Remains to be Completed
Due to Ms. Love’s Chapter 7 Bankruptcy filing, extensive discovery remains to

be completed.
III.

Good Cause Exists for the Requested Extension

[phone] FAX [phone]

Good cause exists for the requested extension, as it will provide time for the

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LAS VEGAS, NEVADA 89106

BALLARD SPAHR LLP

100 NORTH CITY PARKWAY, SUITE 1750

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parties to exchange expert witness information, and complete written discovery and

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schedule depositions. To date, Chase has served initial disclosures. On November 7,

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2017, a Notice of Bankruptcy filing was filed at ECF No. 25 regarding nominal

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defendant Adrienne Love’s Chapter 7 bankruptcy pending in the United States

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Bankruptcy Court for the Central District of California. A Motion for Relief from

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Automatic Stay is currently pending, and scheduled to be heard on December 14,

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2017. Accordingly, the parties desire to extend the Scheduling Order deadlines by 30

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days pending the determination of the Motion for Relief from Automatic Stay.

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Finally, this is the parties’ first request to extend the standard, 180-day

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discovery period in this case, and they seek only a brief 30-day extension.

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parties seek this extension in good faith.

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IV.

The

Proposed Deadlines

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The parties request an order extending the exchange of expert information, the

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interim status report, the close of discovery, the deadline to file dispositive motions,

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and the deadline to file a pre-trial order by 30 days.

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Case 2:17-cv-01928-RFB-NJK Document 26 Filed 11/16/17 Page 3 of 4

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Event
Exchange of experts and expert

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Current Deadline 1
December 7, 2017

New Deadline
January 8, 2018

December 7, 2017

January 8, 2018

January 8, 2018

February 7, 2018

February 5, 2018

March 7, 2018

March 7, 2018

April 6, 2018

April 6, 2018

May 7, 2018

reports

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Interim Status Report

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Exchange of rebuttal experts and

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reports

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Close of Discovery

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Dispositive Motions

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Pre-Trial Order 2

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[phone] FAX [phone]

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LAS VEGAS, NEVADA 89106

BALLARD SPAHR LLP

100 NORTH CITY PARKWAY, SUITE 1750

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[Remainder of Page Intentionally Left Blank]

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See Scheduling Order, ECF No. 19.

2 Pursuant to the Scheduling Order, at ECF No. 19, if dispositive motions are filed,
the deadline for filing the joint pretrial order will be suspended until 30 days after
the decision on the last such dispositive motion or further order of the Court.

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Case 2:17-cv-01928-RFB-NJK Document 26 Filed 11/16/17 Page 4 of 4

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This extension is reasonable and necessary given the good cause set forth
above.
IT IS SO STIPULATED.

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Dated: November 16, 2017

Dated: November 16, 2017

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BALLARD SPAHR LLP

THE BALL LAW GROUP

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By:/s/ Stacy H. Rubin
Abran E. Vigil
Nevada Bar No. 7548
Stacy H. Rubin
Nevada Bar No. 9298
BALLARD SPAHR LLP
100 North City Parkway, Suite 1750
Las Vegas, Nevada 89106

By:/s/ Zachary T. Ball
Zachary T. Ball
Nevada Bar No. 8364
3455 Cliff Shadows Parkway
Suite 150
Las Vegas, Nevada 89129

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Attorneys for JPMorgan Chase Bank,
N.A.

[phone] FAX [phone]

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LAS VEGAS, NEVADA 89106

BALLARD SPAHR LLP

100 NORTH CITY PARKWAY, SUITE 1750

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Attorneys for Terrafirma Venture
LLC

Dated: November 16, 2017

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LEACH JOHNSON SONG & GRUCHOW

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By:/s/ T. Chase Pittsenbarger
Sean L. Anderson
Nevada Bar No. 7259
T. Chase Pittsenbarger
Nevada Bar No. 13740
8945 West Russell Road, Ste. 300
Las Vegas, NV 89148

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Attorneys for Azure Estates Owners’
Association
ORDER

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IT IS SO ORDERED.

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U.S. DISTRICT/MAGISTRATE JUDGE

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November 17, 2017
DATED: __________________________

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