STIPULATION TO TAKE DEPOSITION OF BO JONES OUTSIDE OF THE DISCOVERY DEADLINES

(First Request)

CARL W. HOFFMAN, District Judge.

Bank of America, N.A., Cottonwood at Sunrise Mountain Homeowners Association, Edward Kielty Trust, and Nevada Association Services, Inc. respectfully submit the following stipulation requesting to take Bo Jones' deposition outside of the discovery deadline. This is the parties' first request to take a deposition outside of the discovery deadline.

Discovery in this case closes on September 6, 2016. ECF No. 21, ¶ 1. The parties have participated in discovery in good faith. After BANA timely took each of defendants' depositions, BANA learned Bo Jones purchased the property on Kielty Trust's behalf. On August 15, 2016, BANA served a subpoena to Bo Jones, c/o Luis A. Ayon, noticing Bo Jones' deposition for September 1, 2016 at 1:00 p.m. On the day of the noticed deposition, BANA learned Bo Jones was on vacation and would not be appearing for her September 1 deposition. The parties have agreed to take Bo Jones' deposition outside the discovery period. BANA intends to re-notice Bo Jones' deposition for September 9, 2016 at 1:00 p.m. The parties' agreement to reschedule Bo Jones' deposition will not affect any other deadlines in this case.

The parties request the court allow BANA to take Bo Jones' deposition on September 9, 2016. In the event a subsequent conflict arises with the September 9, 2016 deposition, the parties request the court allow BANA to take Bo Jones' deposition up to and including September 15, 2016. Dated this 1st day of September, 2016. Dated this 1st day of September, 2016.

IT IS SO ORDERED: