United States District Court, D. Nevada
BANK OF AMERICA, N.A. Plaintiff,
SAMUEL R. BAILEY, an individual; PETE G. AGUILAR, an individual; and DOES 1 through 10, inclusive, Defendants. SAMUEL R. BAILEY, Defendant/Counterclaimant,
BANK OF AMERICA, N.A, WESTCOR LAND TITLE INSURANCE COMPANY, a Florida corporation; and NEVADA TITLE COMPANY, a Nevada Corporation; Counterdefendants.
DRIGGS WALCH FINE WRAY PUZEY & THOMPSON BY GLENN F.
MEIER, ESQ. RACHEL E. DONN, ESQ. ATTORNEYS FOR
PLAINTIFF-COUNTER DEFENDANT BANK OF AMERICA, N.A.
SCHWARTS FLANSBURG PLLC BY FRANK M. FLANSBURG, ESQ. ATTORNEYS
FOR DEFENDANT/COUNTER CLAIMANT SAMUEL R. BAILEY
STIPULATION AND (PROPOSED)
ORDER TO EXTEND DEADLINE TO FILE PRETRIAL ORDER
Bank of America, N.A. (hereinafter “BANA” or
“Plaintiff”), by and through its counsel of
record, Rachel E. Donn, Esq. of HOLLEY DRIGGS WALCH FINE WRAY
PUZEY & THOMPSON and Defendant/Counterclaimant SAMUEL R.
BAILEY (hereinafter “Bailey” or
“Defendant”), by and through his counsel of
record, Frank M. Flansburg, III, Esq. of SCHWARTZ FLANSBURG
PLLC hereby agree and stipulate to extend the deadline to
file the Pretrial Order which is currently due on July 21,
2017 as follows:
on the following, the parties hereto respectfully request an
extension to file the Pretrial Order 30 days after ruling on
Plaintiff BANA's Motion to Bifurcate Trial (ECF No. 77)
filed on July 19, 2017, as follows:
Parties stipulated to new deadlines on August 5, 2016 (ECF
Thereafter, the Parties attended a Mediation at which some of
the claims were resolved.
Between Plaintiff/Counterdefendant BANA and
Defendant/Counterclaimant Bailey, the case was not resolved.
Following the Mediation, Defendant/Counterclaimant Bailey
took the deposition of the 30(b)(6) designee for
Plaintiff/Counterdefendant BANA. The date for the 30(b)(6)
deposition had been set prior to Mediation and was set forth
and contemplated in the August 5, 2016 discovery stipulation
(EFC No. 64).
Parties are working together to determine whether any
additional discovery may be produced following the deposition
and may lead to a potential discovery motion.
Because the deposition transcript was received on October 6,
2016, the Parties have agreed to extend the time for which to
file discovery motions. This extension will change the
deadline for discovery motions from October 7, 2016 to
October 14, 2016.
Plaintiff/Counterdefendant BANA filed a Motion for Summary
Judgment on October 14, 2016 (ECF No. 68).
Defendant/Counterclaimant Bailey filed a Motion for Summary
Judgment on October 31, 2016 (ECF No. 70).
June 22, 2017, the Court granted in part and denied in part
Plaintiff/Counterdefendant BANA's Motion for Summary
Judgment (ECF No. 76).
June 22, 2017, the Court denied Defendant/Counterclaimant
Bailey's Motion ...