Deutsche Bank National Trust Company v. Old Republic National Title Insurance Company et al

Filing 13

ORDER Granting 12 Stipulation for Extension of Time. Old Republic National Title Insurance Company, Old Republic Title Company of Nevada, Old Republic Title Insurance Group, Inc. answer due 10/8/2021. Signed by Magistrate Judge Daniel J. Albregts on 9/8/2021. (Copies have been distributed pursuant to the NEF - JQC)

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Case 2:21-cv-01466-GMN-DJA Document 12 Filed 09/07/21 Page 1 of 4 13 09/08/21 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 DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE FOR MORGAN STANLEY DEAN WITTER CAPITAL I INC. TRUST 2003-NC2, MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2003-NC2, 16 Plaintiff, 17 18 19 20 21 Case No.: 2:21-cv-01466-GMN-DJA STIPULATION AND PROPOSED ORDER TO EXTEND DEFENDANTS’ TIME TO RESPOND TO COMPLAINT (First Request) vs. 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, 22 Defendants. 23 24 25 26 27 28 STIPULATION AND PROPOSED ORDER TO EXTEND TIME TO RESPOND TO COMPLAINT 636560.2 Case 2:21-cv-01466-GMN-DJA Document 12 Filed 09/07/21 Page 2 of 4 13 09/08/21 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”) (collectively, “Defendants”) and 4 plaintiff Deutsche Bank National Trust Company, as Trustee for Morgan Stanley Dean Witter 5 Capital I Inc. Trust 2003-NC2, Mortgage Pass-Through Certificates, Series 2003-NC2 (“Deutsche 6 Bank”) (collectively, the “Parties”), by and through their counsel of record, hereby stipulate as 7 follows: 8 9 10 WHEREAS, Deutsche Bank commenced the action by filing a Complaint on August 5, 2021, in the Eighth Judicial District Court for the State of Nevada, Clark County (Case No. A-21839034-C); 11 12 WHEREAS, on August 6, 2021, Old Republic filed a Petition of Removal with this Court, based upon diversity jurisdiction (ECF No. 1); 13 14 WHEREAS, on August 18, 2021, Deutsche Bank served Old Republic Agency with the complaint pursuant to the executed Affidavit of Service filed on August 24, 2021 (ECF No. 7); 15 16 WHEREAS, on August 25, 2021, Deutsche Bank served Old Republic with the complaint pursuant to the executed Affidavit of Service filed on August 31, 2021 (ECF No. 9); 17 18 WHEREAS, on August 27, 2021, Deutsche Bank served ORTIG with the complaint pursuant to the executed Affidavit of Service filed on September 1, 2021 (ECF No. 10); WHEREAS, Old Republic Agency’s response to the Complaint is due on September 8, 19 20 2021; 21 WHEREAS, Old Republic’s response to the Complaint is due on September 15, 2021; 22 WHEREAS, ORTIG’s response to the Complaint is due on September 17, 2021; 23 WHEREAS, Defendants are requesting an extension of time to respond to the Complaint 24 to afford their counsel additional time to review, analyze and respond to Deutsche Bank’s 25 Complaint; WHEREAS, Deutsche Bank has agreed to extend Defendants’ time to respond to the 26 27 Complaint so that all of Defendants’ responses to the Complaint are due on or before October 8, 28 2021; and 1 STIPULATION AND PROPOSED ORDER TO EXTEND TIME TO RESPOND TO COMPLAINT 636560.2 Case 2:21-cv-01466-GMN-DJA Document 12 Filed 09/07/21 Page 3 of 4 13 09/08/21 WHEREAS, this is the first stipulation for an extension of Defendants’ time to respond to 1 2 the complaint. 3 4 Now, therefore, the Parties hereto, by and through their counsel of record, hereby stipulate and agree as follows: 5 1. Defendants shall respond to the complaint on or before October 8, 2021. 6 2. Defendants intend to preserve their rights and do not expressly waive any and all 7 defenses listed in Fed. R. Civ. P. 12(b). 8 9 10 DATED this 7th day of September, 2021 DATED this 7th day of September, 2021 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 11 12 13 14 15 16 17 18 19 20 21 Attorneys for Plaintiff DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE FOR MORGAN STANLEY DEAN WITTER CAPITAL I INC. TRUST 2003-NC2, MORTGAGE PASSTHROUGH CERTIFICATES, SERIES 2003-NC2 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 22 ORDER 23 IT IS SO ORDERED: 24 25 26 Dated: September 8, 2021 By: 27 UNITED STATES MAGISTRATE JUDGE 28 2 STIPULATION AND PROPOSED ORDER TO EXTEND TIME TO RESPOND TO COMPLAINT 636560.2 Case 2:21-cv-01466-GMN-DJA Document 12 Filed 09/07/21 Page 4 of 4 13 09/08/21 1 CERTIFICATE OF SERVICE 2 3 I hereby certify that on September 7, 2021, 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 636560.2

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