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)

Case 2:20-cv-01975-RFB-DJA Document 13 Filed 11/19/20 Page 1 of 4
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11/20/20

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Scott E. Gizer, Esq., Nevada Bar No. 12216
[e-mail]
Sophia S. Lau, Esq., Nevada Bar No. 13365
[e-mail]
EARLY SULLIVAN WRIGHT
GIZER & McRAE LLP
8716 Spanish Ridge Avenue, Suite 105
Las Vegas, Nevada 89148
Telephone: [phone]
Facsimile: [phone]

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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

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UNITED STATES DISTRICT COURT
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DISTRICT OF NEVADA
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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.

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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,

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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.

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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
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Defendants Old Republic National Title Insurance Company (“Old Republic”) and Old

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Republic Title Company of Nevada (“Old Republic Agency”) and Specially-Appearing

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Defendant Old Republic Title Insurance Group, Inc. (“ORTIG”) and plaintiff HSBC Bank USA,

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National Association, as Trustee, in Trust for the Registered Holders of ACE Securities Corp.,

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Home Equity Loan Trust, Series 2006-FM2, Asset Backed Pass-Through Certificates (“HSBC”)

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(collectively, the “Parties”), by and through their counsel of record, hereby stipulate as follows:

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WHEREAS, HSBC commenced the action by filing a Complaint on October 23, 2020, in

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the Eighth Judicial District Court for the State of Nevada, Clark County (Case No. A-20-823631-

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C);

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WHEREAS, on October 25, 2020, Old Republic filed a Petition of Removal with this
Court, based upon diversity jurisdiction (ECF No. 1);

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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);

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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

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November 24, 2020;

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WHEREAS, Old Republic and ORTIG are requesting an extension of time to respond to

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the Complaint to afford their counsel additional time to review, analyze and respond to HSBC’s

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Complaint;
WHEREAS, HSBC has agreed to extend Old Republic’s and ORTIG’s time to respond to

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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

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time to respond to the complaint.

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///

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///

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///

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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
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Now, therefore, the Parties hereto, by and through their counsel of record, hereby stipulate
and agree as follows:

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1.

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24, 2020.

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2.

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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).

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DATED this 19th day of November, 2020

DATED this 19th day of November, 2020

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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

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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

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ORDER

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IT IS SO ORDERED:

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Dated: November 20, 2020

By:

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UNITED STATES MAGISTRATE JUDGE

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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
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CERTIFICATE OF SERVICE

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I hereby certify that on November 19, 2020, I electronically filed the foregoing with the

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Clerk of the Court using the CM/ECF system which will send notification of such filling to the

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Electronic Service List for this Case.

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I declare under penalty of perjury under the laws of the United State of America that the
foregoing is true and correct.

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/s/ D’Metria Bolden
D’METRIA BOLDEN
An Employee of EARLY SULLIVAN
WRIGHT GIZER & McRAE LLP

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STIPULATION AND PROPOSED ORDER TO EXTEND TIME TO RESPOND TO COMPLAINT

586517.1