Filed: Jun. 13, 2018
Latest Update: Jun. 13, 2018
Summary: STIPULATION AND ORDER TO EXTEND DISCOVERY DEADLINES (FIRST REQUEST) CARL W. HOFFMAN , Magistrate Judge . Plaintiff Wells Fargo Financial Nevada 2, Inc. ("Wells Fargo") and Eddie Haddad ("Haddad"), by and through their respective counsel (collectively the "Parties"), for good cause shown, hereby stipulate and agree to extend the discovery cut-off deadline in this action by 30 days to allow the Parties to reschedule and conduct depositions due to the Parties' scheduling constraints. This requ
Summary: STIPULATION AND ORDER TO EXTEND DISCOVERY DEADLINES (FIRST REQUEST) CARL W. HOFFMAN , Magistrate Judge . Plaintiff Wells Fargo Financial Nevada 2, Inc. ("Wells Fargo") and Eddie Haddad ("Haddad"), by and through their respective counsel (collectively the "Parties"), for good cause shown, hereby stipulate and agree to extend the discovery cut-off deadline in this action by 30 days to allow the Parties to reschedule and conduct depositions due to the Parties' scheduling constraints. This reque..
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STIPULATION AND ORDER TO EXTEND DISCOVERY DEADLINES (FIRST REQUEST)
CARL W. HOFFMAN, Magistrate Judge.
Plaintiff Wells Fargo Financial Nevada 2, Inc. ("Wells Fargo") and Eddie Haddad ("Haddad"), by and through their respective counsel (collectively the "Parties"), for good cause shown, hereby stipulate and agree to extend the discovery cut-off deadline in this action by 30 days to allow the Parties to reschedule and conduct depositions due to the Parties' scheduling constraints. This request complies with Local Rule ("LR") 6-1, 6-3, 7-1, and 26-4, and is based on good cause because the litigation of this matter will be best served by the proposed extension. This is the Parties' first extension request.
I. 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:
1. On May 21, 2018, Wells Fargo served deposition notices on Haddad and non-party the Desert Inn Mobile Family Estates Owners Association (the "HOA") for depositions to occur on June 6 and June 15, 2018, respectively.
2. Haddad's counsel advised Wells Fargo's counsel that Haddad was unavailable on June 6, 2018, but has not yet provided alternative availability.
3. 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.
4. 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.
5. Due to the parties' and their counsels' availability, the parties are unable to conduct Haddad's deposition or the HOA's deposition before the current discovery deadline of June 19, 2018.
6. Therefore, good cause exists to extend the discovery cut-off deadline by 30 days, to July 19, 2018, for Wells Fargo to conduct Haddad's and the HOA's respective depositions.
II. DISCOVERY COMPLETED TO DATE
To date the Parties have completed the following discovery:
• Wells Fargo made its initial FRCP 26(a)(1) disclosure on May 7, 2017.
• Haddad made his initial FRCP 26(a)(1) disclosure on January 22, 2018.
• Wells Fargo made its initial expert disclosure on March 19, 2018.
• Haddad served his first set of Interrogatories, Requests for Production of Documents, and Requests for Admission on Wells Fargo on March 19, 2018.
• Wells Fargo responded to Haddad's requests on May 7, 2018.
• Wells Fargo served its first set of Interrogatories, Requests for Production of Documents, and Requests for Admission on Haddad on May 17, 2018.
• Haddad's responses are currently due June 19, 2018.
• Haddad served his second set of Interrogatories, and Requests for Admission on Wells Fargo on May 21, 2018.
• Wells Fargo's responses are currently due June 25, 2018.
III. DISCOVERY TO BE COMPLETED
The parties anticipate that the following discovery still needs to be completed:
• Deposition of the HOA's corporate representative.
• Deposition of Haddad.
IV. PROPOSED NEW DEADLINES
Discovery cut-off deadline:
Currently: June 19, 2018
Proposed: July 19, 2018.
Dispositive motions:
Currently: July 19, 2018
Proposed: August 17, 2018.
V. CONCLUSION
For the foregoing reasons, the Parties respectfully request that the Court grant their request to continue the discovery deadlines detailed herein by thirty (30) days.
ORDER
IT IS ORDERED.
