United States District Court, D. Nevada
U.S. BANK, NATIONAL ASSOCATION, Plaintiff,
FIDELITY NATIONAL TITLE INSURANCE COMPANY, et al., Defendants.
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
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 (âU.S. Bankâ) and specially appearing
Defendant Fidelity National Title Insurance Company
(âFidelity, â and with U.S. Bank, the âPartiesâ), 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
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:
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 ...