STIPULATION AND ORDER TO EXTEND DISCOVERY DEADLINES

[SECOND REQUEST]

CARL W. HOFFMAN, Magistrate Judge.

The Bank of New York Mellon f/k/a The Bank of New York as Trustee for the Benefit of the Certificate Holders of the CWALT, Inc., Alternative Loan Trust 2004-8CB Mortgage Pass Through Certificates, Series 2004-8CB (BoNYM), Absolute Collections Services, LLC (Absolute), and SFR Investments Pool 1, LLC1 (SFR) by and through their respective counsel of record, and hereby jointly submit this Stipulation and Order to Extend Discovery Deadlines (Second Request) pursuant to LR IA 6-1 and LR 26-4. This is the second stipulation to extend the discovery deadlines set by the first request to extend discovery deadlines (ECF No. 17) entered by the Court on September 29, 2017.

A. STATEMENT SPECIFYING THE DISCOVERY COMPLETED

1. Rule 26 Disclosures

Plaintiff BoNYM served its Initial Disclosures on September 28, 2017.

Plaintiff BoNYM served its First Supplement to Initial Disclosures on December 1, 2017.

Plaintiff BoNYM served its Initial Expert Disclosures on December 29, 2017.

Defendant Absolute served its Initial Disclosures on January 23, 2018.

Plaintiff BoNYM served its Second Supplement to Initial Disclosures on February 7, 2018.

Plaintiff BoNYM served its Third Supplement to Initial Disclosures on March 12, 2018.

2. Written Discovery

Plaintiff BoNYM served its first set of interrogatories, requests for admissions and requests for production of documents to Absolute on November 6, 2017.

Plaintiff BoNYM served its first set of interrogatories, requests for admissions and requests for production of documents to SFR on November 6, 2017.

Defendant SFR served its responses to requests for production of documents, response to requests for admission and answers to interrogatories on December 11, 2017.

Defendant Absolute served its responses to requests for admission on December 11, 2017, responses to requests for production of documents on January 23, 2018, and answers to interrogatories on January 24, 2018.

Defendant SFR served its first set of requests for admission, requests for production, and interrogatories to BoNYM on January 24, 2018.

Plaintiff BoNYM served a Subpoena Duces Tecum upon the HOA, with the response due by February, 12, 2018.

Plaintiff BoNYM served its responses to SFR's first set of requests for admission, requests for production, and interrogatories to SFR on March 12, 2018.

3. Depositions

BoNYM deposed Absolute Collections on January 26, 2018.

BoNYM subpoenaed the HOA for deposition to take place on March 29, 2018, but this deposition needs to be rescheduled due to illness of the witness.

B. STATEMENT OF DISCOVERY REMAINING TO BE COMPLETED

SFR's deposition of BoNYM and BoNYM's deposition of the HOA. The parties reserve the right to conduct any additional discovery.

C. REASONS WHY AN EXTENSION IS REQUIRED

BoNYM's deposition was stayed pending this court's decision on BANA's motion for protective order in Bank of Am., N.A. v. Falcon Pointe Ass'n et al, D. Nev. Case. No. 2:16-cv-00814-GMN-CWH. See ECF No. 34. A decision on the Falcon Pointe motion was issued on April 5, 2018. See ECF No. 107 in the Falon Pointe case. The parties request an extension of discovery to accommodate the scheduling of SFR's deposition of BoNYM. Given counsel and witness availability, the parties anticipate scheduling BoNYM's deposition in late April or early May 2018.

D. PROPOSED SCHEDULE FOR ALL REMAINING DISCOVERY

E. CURRENT TRIAL DATE

The court has not yet set a trial date.

Based on the foregoing, the parties respectfully request the court extend the remaining discovery deadlines as requested above.

The parties make this request in good faith and believe good cause exists for extending these deadlines.

ORDER

IT IS SO ORDERED.