Wells Fargo Bank, N.A. v. Commonwealth Land Title Insurance Company

Filing 50

ORDER granting 48 Stipulation to extend time to respond to 46 Motion to Dismiss. Responses due by 4/9/2024. Signed by Judge Gloria M. Navarro on 3/26/2024. (Copies have been distributed pursuant to the NEF - MAM)

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WRIGHT, FINLAY & ZAK, LLP
Darren T. Brenner, Esq. (NBN 8386)
Christina V. Miller, Esq. (NBN 12448)
Lindsay D. Dragon, Esq. (NBN 13474)
Yanxiong Li, Esq. (NBN 12807)
7785 W. Sahara Ave., Suite 200
Las Vegas, NV 89117
[phone]; Fax: [phone]
[e-mail]
[e-mail]
[e-mail]
[e-mail]
Attorney for Plaintiff, Wells Fargo Bank, N.A., As Trustee For The Certificate Holders Of Park
Place Securities, Inc., Asset-Backed Pass-Through Certificates, Series 2005-WCW1
UNITED STATES DISTRICT COURT
DISTRICT OF NEVADA

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WELLS FARGO BANK, N.A., AS
Case No.: 2:19-cv-00803-GMN-EJY
TRUSTEE FOR THE CERTIFICATE
HOLDERS OF PARK PLACE SECURITIES,
STIPULATION TO EXTEND TIME TO
INC., ASSET-BACKED PASS-THROUGH
RESPOND TO MOTION TO DISMISS
CERTIFICATES, SERIES 2005-WCW1,
[ECF NO. 46]
Plaintiff,
vs.
(First Request)
COMMONWEALTH LAND TITLE
INSURANCE COMPANY,

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Defendant.

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COMES NOW, Plaintiff, Wells Fargo Bank, N.A., as Trustee for the Certificate Holders

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of Park Place Securities, Inc., Asset-Backed Pass-Through Certificates, Series 2005-WCW1

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(“Wells

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(“Commonwealth”, collectively, the “Parties”), by and through their respective undersigned

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counsels, stipulate and agree as follows:

Fargo”)

and

Defendant,

Commonwealth

Land

Title

Insurance

Company

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1. On March 12, 2024, Commonwealth filed a Motion to Dismiss [ECF No. 46];

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2. Wells Fargo’s deadline to respond to Commonwealth’s Motion to Dismiss is currently

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March 26, 2024;

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3. This is one of five cases pending before this Court in which similar Motions to Dismiss

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have been filed and with the same deadline for a response1. Good cause exists for a

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brief extension as counsel for Wells Fargo reasonably requires additional time to

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diligently prepare responses given the numerous Motions to Dismiss due at the same

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time. Wells Fargo requests a two-week extension up to and including April 9, 2024 to

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file its response to Commonwealth’s Motion to Dismiss;

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4. Counsel for Commonwealth does not oppose the requested extension;

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5. This is the first request for an extension and is made in good faith and not for purposes

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of undue delay or prejudice.

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IT IS SO STIPULATED.

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DATED this 25th day of March, 2024.

DATED this 25th day of March, 2024.

WRIGHT, FINLAY & ZAK, LLP

SINCLAIR BRAUN KARGHER LLP

/s/ Yanxiong Li, Esq.
Yanxiong Li, Esq.
Nevada Bar No. 12807
7785 W. Sahara Ave., Suite 200
Las Vegas, NV 89117
Attorneys for Plaintiff, Wells Fargo Bank,
N.A., As Trustee For The Certificate Holders
Of Park Place Securities, Inc., Asset-Backed
Pass-Through Certificates, Series 2005WCW1

/s/ Kevin S. Sinclair, Esq.
Kevin S. Sinclair, Esq.
Nevada Bar No. 12277
15260 Ventura Blvd., Ste 715
Sherman Oaks, California 91403
Attorneys for Defendant, Commonwealth
Land Title Insurance Company

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IT IS SO ORDERED.

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DATED:___________
March 26, 2024

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_________________________________
DISTRICT COURT JUDGE

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The other four cases being U.S. Bank National Association v. Fidelity National Title Group,
Inc., et al, Case No. 2:21-cv-01454-GMN-NJK; U.S. Bank, National Association v. Fidelity
National Title Insurance Company, Case No. 2:19-cv-00809-GMN-BNW; Deutsche Bank
National Trust Company v. Fidelity National Title Group, Inc., et al, Case No. 2:20-cv-01886GMN-BNW; Wilmington Trust, National Association v. Commonwealth Land Title Insurance
Company, Case No. 2:18-cv-02023-GMN-BNW.

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