United States District Court, D. Nevada
WRIGHT, FINLAY & ZAK, LLP LINDSAY D. ROBBINS, ESQ.
ATTORNEY FOR PLAINTIFF, DEUTSCHE BANK NATIONAL TRUST COMPANY,
AS INDENTURE TRUSTEE, ON BEHALF OF THE HOLDERS OF THE
ACCREDITED MORTGAGE LOAN TRUST 2004-3 ASSET-BACKED NOTES
SULLIVAN WRIGHT GIZER & MCRAE LLP SOPHIA S. LAU, ESQ.,
ATTORNEYS FOR SPECIALLY APPEARING DEFENDANTS FIDELITY
NATIONAL TITLE INSURANCE COMPANY AND CHICAGO TITLE INSURANCE
STIPULATION AND ORDER TO EXTEND DISCOVERY DEADLINES
Deutsche Bank National Trust Company, as Indenture Trustee,
on Behalf of the Holders of the Accredited Mortgage Loan
Trust 2004-3 Asset-Backed Notes (âDeutsche Bankâ) and
specially appearing Defendants Fidelity National Title
Insurance Company (âFidelityâ) and Chicago Title Insurance
Company (âChicago Title, â and with Fidelity and Deutsche
Bank, the âPartiesâ), by and through their counsel of record,
hereby submit their Stipulation to Extend Discovery Deadlines
by sixty (60) days in accordance with Local Rule 26-4 and
Local Rule IA 6-1.
accordance with Local Rule 26-4, this Stipulation has been
brought in good faith, with good cause, is the first request
for an extension of time to the discovery deadlines and is
not intended to cause delay.
A statement specifying the discovery completed:
20, 2019, Fidelity and Deutsche Bank conducted the
Fed.R.Civ.P. 26(f) conference. Thereafter, Fidelity and
Deutsche Bank promptly submitted their proposed Joint
Discovery Plan and Scheduling Order on June 21, 2019 [ECF No.
12]. On June 24, 2019, the Court entered the Discovery Plan
and Scheduling Order [ECF No. 13] with the following
• Initial disclosures: July 16, 2019;
• Amend pleadings/add parties: October 18, 2019;
• Initial experts: November 18, 2019;
• Interim status report: November 18, 2019;
• Rebuttal experts: December 18, 2019;
• Discovery cutoff: January 17, 2020;
• Dispositive motions: February 18, 2020; and
• Joint proposed pretrial order: March 19, 2020, or 30
days after resolution of ...