Opinion
2:21-cv-00537-JCM-BNW
01-10-2022
U.S. BANK NATIONAL ASSOCIATION, SUCCESSOR IN INTEREST TO BANK OF AMERICA, NATIONAL ASSOCIATION, SUCCESSOR BY MERGER TO LASSALLE BANK NATIONAL ASSOCIATION AS TRUSTEE FOR GSAMP TRUST 2007-NC1 MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2007-NC1 Plaintiff, v. FIDELITY NATIONAL TITLE GROUP, INC., et al., Defendants.
Scott E. Gizer, Esq., Nevada Bar No. 12216 Sophia S. Lau, Esq., Nevada Bar No. 13365 EARLY SULLIVAN WRIGHT GIZER & McRAE LLP Kevin S. Sinclair, Nevada Bar Number 12277 SINCLAIR BRAUN LLP Attorneys for Defendant CHICAGO TITLE INSURANCE COMPANY DESIGNATED LOCAL COUNSEL FOR SERVICE OF PROCESS ON SINCLAIR BRAUN LLP PER L.R. IA 11-1(b) Gary L. Compton, State Bar No. 1652 WRIGHT FINLAY & ZAK, LLP LINDSAY D. DRAGON Attorneys for Plaintiff U.S. BANK NATIONAL ASSOCIATION D'METRIA BOLDEN An Employee of EARLY SULLIVAN WRIGHT GIZER & McRAE LLP
Scott E. Gizer, Esq., Nevada Bar No. 12216
Sophia S. Lau, Esq., Nevada Bar No. 13365
EARLY SULLIVAN WRIGHT GIZER & McRAE LLP
Kevin S. Sinclair, Nevada Bar Number 12277
SINCLAIR BRAUN LLP
Attorneys for Defendant CHICAGO TITLE INSURANCE COMPANY
DESIGNATED LOCAL COUNSEL FOR SERVICE OF PROCESS ON SINCLAIR BRAUN LLP PER L.R. IA 11-1(b)
Gary L. Compton, State Bar No. 1652
WRIGHT FINLAY & ZAK, LLP
LINDSAY D. DRAGON Attorneys for Plaintiff U.S. BANK NATIONAL ASSOCIATION
D'METRIA BOLDEN An Employee of EARLY SULLIVAN WRIGHT GIZER & McRAE LLP
STIPULATION AND PROPOSED ORDER EXTENDING DEFENDANT CHICAGO TITLE INSURANCE COMPANY'S TIME TO RESPOND TO RENEWED MOTION FOR REMAND [ECF NO. 22] (FIRST REQUEST)
JAMES C. MAHAN UNITED STATES DISTRICT COURT JUDGE
Defendant Chicago Title Insurance Company (“Chicago Title”) and Plaintiff U.S. Bank N.A. (“U.S. Bank”) (collectively, the “Parties”), by and through their counsel of record, hereby stipulate and agree as follows:
1. On April 1, 2021, U.S. Bank filed its Complaint in the Eighth Judicial District Court, Case No. A-21-832212-C [ECF No. 1-1];
2. On April 2, 2021, Chicago Title filed a Petition for Removal to this Court [ECF No. 1];
3. On May 3, 2021, U.S. Bank filed a Motion for Remand [ECF No. 6] and Motion for Costs and Fees [ECF No. 7];
4. On June 9, 2021, the Court entered an order, pursuant to the Parties' stipulation, staying the case pending resolution of Wells Fargo Bank, N.A. v. Fidelity National Title Ins. Co. Ninth Cir. Case No. 19-17332 (the “Wells Fargo II Appeal”). Upon entry of the stay the Court denied as moot, all pending motions, including the Motion for Remand. The Court further ordered that the Parties file any motions that were denied as moot within 30 days of the issuance of the mandate in the Wells Fargo II Appeal [ECF No. 19];
5. On December 28, 2021, U.S. Bank filed a Renewed Motion for Remand;
6. Chicago Title's deadline to respond to U.S. Bank's Renewed Motion for Remand is currently January 11, 2022;
7. Chicago Title's counsel is requesting an extension until January 25, 2022, to file its response to the pending Renewed Motion for Remand;
8. Chicago Title requests a brief extension of time to respond to the Motion for Remand to afford Chicago Title additional time to respond to the legal arguments set forth in U.S. Bank's motions;
9. U.S. Bank does not oppose the requested extension;
10. This is the first request for an extension which is made in good faith and not for purposes of delay;
IT IS SO STIPULATED that Chicago Title's deadline to respond to U.S. Bank's Motion for Remand [ECF No. 22] is hereby extended through and including January 25, 2022.
IT IS SO ORDERED:
CERTIFICATE OF SERVICE
I hereby certify that on January 10, 2022, I electronically filed the foregoing with the Clerk of the Court using the CM/ECF system which will send notification of such filling to the Electronic Service List for this Case.
I declare under penalty of perjury under the laws of the United State of America that the foregoing is true and correct.