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.
F. MEIER, ESQ. Nevada Bar No. 006059 RACHEL E. DONN, ESQ.
Nevada Bar No. 10568 HOLLEY DRIGGS WALCH FINE WRAY PUZEY &
THOMPSON Attorneys for Plaintiff/Counterdefendant BANK OF
SCHWARTS FLANSBURG PLLC Frank M. Flansburg, Esq. Nevada Bar
No. 6974 Attorneys for Defendant/Counterclaimant Samuel R.
STIPULATION AND (PROPOSED)
ORDER TO EXTEND DEADLINE TO FILE PRETRIAL ORDER (ELEVENTH
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 November
20, 2017, as follows:
on the following, the parties hereto respectfully request a
90-day extension to file the Pretrial Order 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).
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 for Summary Judgment (ECF No. 76).
July 19, 2017, BANA filed a Motion to Bifurcate Trial (EFC
August 2, 2017, Defendant/Counterclaimant Bailey filed a
Response to ...