HSBC Bank USA, National Association v. Old Republic Title Insurance Group, Inc. et al

Filing 16

ORDER granting 13 Stipulation to Extend Deadline to Answer 1 Complaint. Old Republic National Title Insurance Company answer due 12/24/2020; Old Republic Title Insurance Group, Inc. answer due 12/24/2020. Signed by Magistrate Judge Daniel J. Albregts on 11/20/2020. (Copies have been distributed pursuant to the NEF - DRS)

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Case 2:20-cv-01975-RFB-DJA Document 13 Filed 11/19/20 Page 1 of 4 16 11/20/20 1 2 3 4 5 Scott E. Gizer, Esq., Nevada Bar No. 12216 sgizer@earlysullivan.com Sophia S. Lau, Esq., Nevada Bar No. 13365 slau@earlysullivan.com EARLY SULLIVAN WRIGHT GIZER & McRAE LLP 8716 Spanish Ridge Avenue, Suite 105 Las Vegas, Nevada 89148 Telephone: (702) 331-7593 Facsimile: (702) 331-1652 6 7 8 Attorneys for Specially-Appearing Defendant OLD REPUBLIC TITLE INSURANCE GROUP, INC. and Defendants OLD REPUBLIC NATIONAL TITLE INSURANCE COMPANY and OLD REPUBLIC TITLE COMPANY OF NEVADA 9 UNITED STATES DISTRICT COURT 10 DISTRICT OF NEVADA 11 12 13 14 15 16 HSBC BANK USA, NATIONAL ASSOCIATION, AS TRUSTEE, IN TRUST FOR THE REGISTERED HOLDERS OF ACE SECURITIES CORP., HOME EQUITY LOAN TRUST, SERIES 2006-FM2, ASSET BACKED PASS-THROUGH CERTIFICATES, vs. 18 20 21 22 STIPULATION AND PROPOSED ORDER EXTENDING OLD REPUBLIC NATIONAL TITLE INSURANCE COMPANY’S AND OLD REPUBLIC TITLE INSURANCE GROUP, INC.’S TIME TO RESPOND TO COMPLAINT Plaintiff, 17 19 Case No.: 2:20-cv-01975-RFB-DJA (First Request) OLD REPUBLIC TITLE INSURANCE GROUP, INC., OLD REPUBLIC NATIONAL TITLE INSURANCE COMPANY; OLD REPUBLIC TITLE COMPANY OF NEVADA; DOE INDIVIDUALS I through X; and ROE CORPORATIONS XI through XX, inclusive, Defendants. 23 24 25 26 27 28 STIPULATION AND PROPOSED ORDER TO EXTEND TIME TO RESPOND TO COMPLAINT 586517.1 Case 2:20-cv-01975-RFB-DJA Document 13 Filed 11/19/20 Page 2 of 4 16 11/20/20 Defendants Old Republic National Title Insurance Company (“Old Republic”) and Old 1 2 Republic Title Company of Nevada (“Old Republic Agency”) and Specially-Appearing 3 Defendant Old Republic Title Insurance Group, Inc. (“ORTIG”) and plaintiff HSBC Bank USA, 4 National Association, as Trustee, in Trust for the Registered Holders of ACE Securities Corp., 5 Home Equity Loan Trust, Series 2006-FM2, Asset Backed Pass-Through Certificates (“HSBC”) 6 (collectively, the “Parties”), by and through their counsel of record, hereby stipulate as follows: 7 WHEREAS, HSBC commenced the action by filing a Complaint on October 23, 2020, in 8 the Eighth Judicial District Court for the State of Nevada, Clark County (Case No. A-20-823631- 9 C); 10 11 WHEREAS, on October 25, 2020, Old Republic filed a Petition of Removal with this Court, based upon diversity jurisdiction (ECF No. 1); 12 13 WHEREAS, on November 3, 2020, HSBC served Old Republic and ORTIG with the complaint pursuant to the executed summons filed on November 6, 2020 (ECF Nos. 6-7); 14 15 WHEREAS, HSBC has not yet served the summons and complaint on Old Republic Agency; WHEREAS, Old Republic’s and ORTIG’s responses to the Complaint are due on 16 17 November 24, 2020; 18 WHEREAS, Old Republic and ORTIG are requesting an extension of time to respond to 19 the Complaint to afford their counsel additional time to review, analyze and respond to HSBC’s 20 Complaint; WHEREAS, HSBC has agreed to extend Old Republic’s and ORTIG’s time to respond to 21 22 the Complaint by thirty (30) days to December 24, 2020; and WHEREAS, this is the first stipulation for an extension of Old Republic’s and ORTIG’s 23 24 time to respond to the complaint. 25 /// 26 /// 27 /// 28 1 STIPULATION AND PROPOSED ORDER TO EXTEND TIME TO RESPOND TO COMPLAINT 586517.1 Case 2:20-cv-01975-RFB-DJA Document 13 Filed 11/19/20 Page 3 of 4 16 11/20/20 1 2 Now, therefore, the Parties hereto, by and through their counsel of record, hereby stipulate and agree as follows: 3 1. 4 24, 2020. 5 2. 6 Old Republic and ORTIG shall respond to the complaint on or before December Old Republic and ORTIG intend to preserve their rights and do not expressly waive any and all defenses listed in Fed. R. Civ. P. 12(b). 7 8 DATED this 19th day of November, 2020 DATED this 19th day of November, 2020 9 WRIGHT FINLAY & ZAK, LLP EARLY SULLIVAN WRIGHT GIZER & McRAE LLP /s/-Lindsay D. Robbins By: _______________________________ Darren T. Brenner Nevada State Bar No. 8386 Lindsay D. Robbins Nevada State Bar No. 13474 7785 W. Sahara Ave, Suite 200 Las Vegas, NV 89117 /s/-Sophia S. Lau By: _____________________________________ Scott E. Gizer Nevada State Bar No. 12216 Sophia S. Lau Nevada State Bar No. 13365 8716 Spanish Ridge Ave., Ste. 105 Las Vegas, NV 89148 10 11 12 13 14 15 16 17 18 19 20 Attorneys for Plaintiff HSBC BANK USA, NATIONAL ASSOCIATION, AS TRUSTEE, IN TRUST FOR THE REGISTERED HOLDERS OF ACE SECURITIES CORP., HOME EQUITY LOAN TRUST, SERIES 2006-FM2, ASSET BACKED PASS-THROUGH CERTIFICATES Attorneys for Specially-Appearing Defendant OLD REPUBLIC TITLE INSURANCE GROUP, INC. and Defendants OLD REPUBLIC NATIONAL TITLE INSURANCE COMPANY and OLD REPUBLIC TITLE COMPANY OF NEVADA 21 ORDER 22 IT IS SO ORDERED: 23 24 25 Dated: November 20, 2020 By: 26 UNITED STATES MAGISTRATE JUDGE 27 28 2 STIPULATION AND PROPOSED ORDER TO EXTEND TIME TO RESPOND TO COMPLAINT 586517.1 Case 2:20-cv-01975-RFB-DJA Document 13 Filed 11/19/20 Page 4 of 4 16 11/20/20 1 CERTIFICATE OF SERVICE 2 3 I hereby certify that on November 19, 2020, I electronically filed the foregoing with the 4 Clerk of the Court using the CM/ECF system which will send notification of such filling to the 5 Electronic Service List for this Case. 6 7 I declare under penalty of perjury under the laws of the United State of America that the foregoing is true and correct. 8 9 /s/ D’Metria Bolden D’METRIA BOLDEN An Employee of EARLY SULLIVAN WRIGHT GIZER & McRAE LLP 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 3 STIPULATION AND PROPOSED ORDER TO EXTEND TIME TO RESPOND TO COMPLAINT 586517.1

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