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U.S. Bank, National Association v. Fidelity National Title Insurance Co.

United States District Court, D. Nevada

November 19, 2019

U.S. BANK, NATIONAL ASSOCATION, Plaintiff,
v.
FIDELITY NATIONAL TITLE INSURANCE COMPANY, et al., Defendants.

          Kevin S. Sinclair, Esq., Sophia S. Lau, Esq., EARLY SULLIVAN WRIGHT GIZER & McRAE LLP, Attorneys for Specially Appearing Defendant FIDELITY NATIONAL TITLE INSURANCE COMPANY.

          WRIGHT, FINLAY & ZAK, LLP, Lindsay D. Robbins, Esq., Attorneys for Plaintiff, U.S. Bank National Trust Company, as Indenture Trustee, on Behalf of the Holders of the Accredited Mortgage Loan Trust 2004-3 Asset-Backed Notes.

          STIPULATION AND ORDER TO EXTEND DISCOVERY DEADLINES (FIRST REQUEST)

         Plaintiff U.S. Bank National Association, as Successor Trustee to Wachovia Bank, N.A., as Trustee for the Certificateholders of the MLMI Trust, Mortgage Loan Asset-Backed Certificates, Series 2005-A8 (“U.S. Bank”) and specially appearing Defendant Fidelity National Title Insurance Company (“Fidelity, ” and with U.S. Bank, the “Parties”), by and through their counsel of record, hereby submit their Stipulation to Extend Discovery Deadlines by twenty-eight (28) 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 September 18, 2019, Fidelity and U.S. Bank conducted the Fed.R.Civ.P. 26(f) conference. Thereafter, Fidelity and U.S. Bank promptly submitted their proposed Joint Discovery Plan and Scheduling Order on September 23, 2019 [ECF No. 13]. On September 24, 2019, the Court entered the Discovery Plan and Scheduling Order [ECF No. 14] with the following deadlines:

• Initial disclosures: October 11, 2019;
• Amend pleadings/add parties: October 23, 2019;
• Initial experts: November 22, 2019;
• Interim status report: November 22, 2019;
• Rebuttal experts: December 20, 2019;
• Discovery cutoff: January 21, 2020;
• Dispositive motions: February 20, 2020; and
• Joint proposed pretrial order: March 23, 2020, or 30 days after resolution of ...

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