US Bank National Association v. Fidelity National Title Group, Inc. et al
Filing
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ORDER Granting 25 Stipulation for Extension of Time to File Response to 22 Motion to Remand to State Court. Responses due by 1/25/2022. Signed by Judge James C. Mahan on 1/11/2022. (Copies have been distributed pursuant to the NEF - ABG)
Case 2:21-cv-00537-JCM-BNW Document 28 Filed 01/11/22 Page 1 of 4
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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
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Kevin S. Sinclair, Nevada Bar Number 12277
ksinclair@sinclairbraun.com
SINCLAIR BRAUN LLP
16501 Ventura Boulevard, Suite 400
Encino, California 91436
Telephone: (213) 429-6100
Facsimile: (213) 429-6101
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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)
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Gary L. Compton, State Bar No. 1652
2950 E. Flamingo Road, Suite L
Las Vegas, Nevada 89121
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UNITED STATES DISTRICT COURT
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DISTRICT OF NEVADA
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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
STIPULATION AND PROPOSED
ORDER EXTENDING DEFENDANT
CHICAGO TITLE INSURANCE
COMPANY’S TIME TO RESPOND
TO RENEWED MOTION FOR
REMAND [ECF No. 22]
(First Request)
Plaintiff,
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vs.
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Case No.: 2:21-cv-00537-JCM-BNW
FIDELITY NATIONAL TITLE GROUP,
INC., et al.,
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Defendants.
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656924.1
STIPULATION AND ORDER TO EXTEND TIME TO RESPOND
TO RENEWED MOTION FOR REMAND
Case 2:21-cv-00537-JCM-BNW Document 28 Filed 01/11/22 Page 2 of 4
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Defendant Chicago Title Insurance Company (“Chicago Title”) and Plaintiff U.S. Bank
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N.A. (“U.S. Bank”) (collectively, the “Parties”), by and through their counsel of record, hereby
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stipulate and agree as follows:
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1. On April 1, 2021, U.S. Bank filed its Complaint in the Eighth Judicial District Court,
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Case No. A-21-832212-C [ECF No. 1-1];
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2. On April 2, 2021, Chicago Title filed a Petition for Removal to this Court [ECF No.
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1];
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3. On May 3, 2021, U.S. Bank filed a Motion for Remand [ECF No. 6] and Motion for
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Costs and Fees [ECF No. 7];
4. On June 9, 2021, the Court entered an order, pursuant to the Parties’ stipulation,
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staying the case pending resolution of Wells Fargo Bank, N.A. v. Fidelity National
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Title Ins. Co. Ninth Cir. Case No. 19-17332 (the “Wells Fargo II Appeal”). Upon
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entry of the stay the Court denied as moot, all pending motions, including the Motion
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for Remand. The Court further ordered that the Parties file any motions that were
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denied as moot within 30 days of the issuance of the mandate in the Wells Fargo II
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Appeal [ECF No. 19];
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5. On December 28, 2021, U.S. Bank filed a Renewed Motion for Remand;
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6. Chicago Title’s deadline to respond to U.S. Bank’s Renewed Motion for Remand is
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currently January 11, 2022;
7. Chicago Title’s counsel is requesting an extension until January 25, 2022, to file its
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response to the pending Renewed Motion for Remand;
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8. Chicago Title requests a brief extension of time to respond to the Motion for Remand
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to afford Chicago Title additional time to respond to the legal arguments set forth in
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U.S. Bank’s motions;
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9. U.S. Bank does not oppose the requested extension;
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10. This is the first request for an extension which is made in good faith and not for
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purposes of delay;
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656924.1
STIPULATION AND ORDER TO EXTEND TIME TO RESPOND TO
RENEWED MOTION FOR REMAND
Case 2:21-cv-00537-JCM-BNW Document 28 Filed 01/11/22 Page 3 of 4
IT IS SO STIPULATED that Chicago Title’s deadline to respond to U.S. Bank’s Motion
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for Remand [ECF No. 22] is hereby extended through and including January 25, 2022.
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Dated: January 10, 2022
EARLY SULLIVAN WRIGHT
GIZER & McRAE LLP
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By:
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Dated: January 10, 2022
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SINCLAIR BRAUN LLP
By:
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Dated: January 10, 2022
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/s/-- Sophia S. Lau
SCOTT E. GIZER
SOPHIA S. LAU
Attorneys for Defendant CHICAGO TITLE
INSURANCE COMPANY
/s/-Kevin S. Sinclair
KEVIN S. SINCLAIR
Attorneys for Defendant CHICAGO TITLE
INSURANCE COMPANY
WRIGHT FINLAY & ZAK, LLP
By:
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/s/-Lindsay D. Dragon
LINDSAY D. DRAGON
Attorneys for Plaintiff U.S. BANK
NATIONAL ASSOCIATION
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IT IS SO ORDERED:
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Dated:
January 11, 2022
By:
UNITED STATES DISTRICT COURT JUDGE
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656924.1
STIPULATION AND ORDER TO EXTEND TIME TO RESPOND TO
RENEWED MOTION FOR REMAND
Case 2:21-cv-00537-JCM-BNW Document 28 Filed 01/11/22 Page 4 of 4
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CERTIFICATE OF SERVICE
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I hereby certify that on January 10, 2022, 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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656924.1
STIPULATION AND ORDER TO EXTEND TIME TO RESPOND TO
RENEWED MOTION FOR REMAND
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