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Deutsche Bank National Trust Co. v. Fidelity National Title Insurance Co.

United States District Court, D. Nevada

November 15, 2019

DEUTSCHE BANK NATIONAL TRUST COMPANY, Plaintiff,
v.
FIDELITY NATIONAL TITLE INSURANCE COMPANY, et al., Defendant.

          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

          EARLY SULLIVAN WRIGHT GIZER & MCRAE LLP SOPHIA S. LAU, ESQ., ATTORNEYS FOR SPECIALLY APPEARING DEFENDANTS FIDELITY NATIONAL TITLE INSURANCE COMPANY AND CHICAGO TITLE INSURANCE COMPANY

          STIPULATION AND ORDER TO EXTEND DISCOVERY DEADLINES (FIRST REQUEST)

         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 (“Deutsche Bank”) and specially appearing Defendants Fidelity National Title Insurance Company (“Fidelity”) and Chicago Title Insurance Company (“Chicago Title, ” and with Fidelity and Deutsche Bank, the “Parties”), 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.

         In 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) A statement specifying the discovery completed:

         On June 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 deadlines:

• 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 ...

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