Opinion
2:22-cv-00629-JAD-BNW
10-28-2022
SFR INVESTMENTS POOL 1, LLC, Plaintiff, v. BANK OF AMERICA, N.A.; DOES I through X, inclusive; and ROE BUSINESS ENTITIES I through X, inclusive, Defendants.
HANKS LAW GROUP KAREN L. HANKS, ESQ. Nevada Bar No. 9578 CHANTEL M. SCHIMMING, ESQ. Nevada Bar No. 8886 ANA P. MURGUIA, ESQ. Nevada Bar No. 16284 Attorneys for SFR Investments Pool 1, LLC AKERMAN LLP SCOTT R. LACHMAN, ESQ. Nevada Bar No. 12016 Attorneys for Nationstar Mortgage, LLC and Federal National Mortgage Association
HANKS LAW GROUP KAREN L. HANKS, ESQ. Nevada Bar No. 9578 CHANTEL M. SCHIMMING, ESQ. Nevada Bar No. 8886 ANA P. MURGUIA, ESQ. Nevada Bar No. 16284 Attorneys for SFR Investments Pool 1, LLC
AKERMAN LLP SCOTT R. LACHMAN, ESQ. Nevada Bar No. 12016 Attorneys for Nationstar Mortgage, LLC and Federal National Mortgage Association
STIPULATION AND ORDER TO EXTEND DISCOVERY AND DISPOSITIVE MOTION DEADLINES
BRENDA WEKSLER UNITED STATES MAGISTRATE JUDGE
SFR Investments Pool 1, LLC (“SFR”) and Bank of America, N.A., (“BANA”) hereby respectfully submit this Stipulation and Order to Extend Discovery and Dispositive Motion Deadlines pursuant to LR 26-4 and LR IA 6-1.
On October 25, 2022, the parties, Karen L. Hanks, Esq. for SFR and Scott R. Lachman, Esq. for the Bank conducted a meet and confer to secure dates to schedule the depositions of the 30(b)(6) witnesses for BANA and SFR. At this time, the parties have agreed to schedule the depositions for BANA on December 13, 2022, and SFR for December 14, 2022. The parties hereby request to extend the discovery deadlines to January 7, 2023, the dispositive motions deadline to February 6, 2023, and the Pre-trial Order deadline to March 8, 2023.
I. DISCOVERY COMPLETED:
A. Initial and Supplement Disclosures:
1. On July 15, 2022, SFR served its Initial Disclosures.
2. On July 5, 2022, Bank of America served its Initial Disclosures.
B. Initial and Rebuttal Expert Disclosures:
N/A
C. Written Discovery:
1. On October 4, 2022, SFR served its First Sets of Requests for Admission, Interrogatories, and Requests for Production of Documents to Bank of America.
D. Depositions:
1. TBD
II. SPECIFIC DESCRIPTION OF DISCOVERY THAT REMAINS TO BE COMPLETED:
A. Written Discovery:
1. First set of interrogatories, requests for production of documents and requests for admission from Bank of America to SFR Investments Pool 1, LLC.
B. Depositions:
1. SFR's deposition of the Fed.R.Civ.P. 30(b)(6) witness for Bank of America.
2. Bank of America's deposition of the Fed.R.Civ.P. 30(b)(6) witness for SFR.
3. Any additional depositions by the parties as necessary pursuant to the discovery process.
III. REASONS WHY DISCOVERY WAS NOT COMPLETED WITHIN TIME LIMITS SET BY DISCOVERY PLAN:
As required by LR 26-4, because this stipulation is being submitted within twenty-one (21) days of the discovery deadline, the parties must demonstrate good cause. Good cause is present to allow the parties an additional sixty (60) days to complete the remaining discovery. Specifically, the scheduling of the depositions of the 30(b)(6) witnesses for SFR and Bank of America, which the parties had difficulty scheduling within the discovery deadlines due to witness availability as well as counsel for both parties having numerous additional caseload scheduling conflicts.
Accordingly, for the reasons stated above, good cause exists for the parties' requested extension of the discovery and dispositive motion deadlines.
IV. PROPOSED SCHEDULE FOR COMPLETING ALL REMAINING DISCOVERY:
Event
Previous Deadline
New Deadline
Discovery Cut- Off
Monday, November 7, 2022
Friday, January 6, 2023
Dispositive Motions
Wednesday, December 7, 2022
Monday, February 6, 2023
Pre-Trial Order
Friday, January 6, 2023
Wednesday, March 8, 2023
The parties submit this Stipulation and Order in good faith and not for purposes of delay or to prejudice any party.
ORDER
IT IS SO ORDERED