Filed: Jun. 12, 2019
Latest Update: Jun. 12, 2019
Summary: STIPULATION AND ORDER TO EXTEND TIME TO RESPOND TO FIDELITY'S MOTION TO DISMISS [ECF NO. 6] AND CHICAGO'S MOTION TO DISMISS [ECF NO. 7] [First Request] RICHARD F. BOULWARE, II , District Judge . Plaintiff, Deutsche Bank National Trust Company, As Trustee For Ameriquest Mortgage Securities Inc., Asset-Backed Pass-Through Certificates, Series 2005-R3 ("Deutsche Bank"), Defendant Fidelity National Title Group, Inc. ("Fidelity"), and Defendant Chicago Title Insurance Company ("Chicago"), by an
Summary: STIPULATION AND ORDER TO EXTEND TIME TO RESPOND TO FIDELITY'S MOTION TO DISMISS [ECF NO. 6] AND CHICAGO'S MOTION TO DISMISS [ECF NO. 7] [First Request] RICHARD F. BOULWARE, II , District Judge . Plaintiff, Deutsche Bank National Trust Company, As Trustee For Ameriquest Mortgage Securities Inc., Asset-Backed Pass-Through Certificates, Series 2005-R3 ("Deutsche Bank"), Defendant Fidelity National Title Group, Inc. ("Fidelity"), and Defendant Chicago Title Insurance Company ("Chicago"), by and..
More
STIPULATION AND ORDER TO EXTEND TIME TO RESPOND TO FIDELITY'S MOTION TO DISMISS [ECF NO. 6] AND CHICAGO'S MOTION TO DISMISS [ECF NO. 7]
[First Request]
RICHARD F. BOULWARE, II, District Judge.
Plaintiff, Deutsche Bank National Trust Company, As Trustee For Ameriquest Mortgage Securities Inc., Asset-Backed Pass-Through Certificates, Series 2005-R3 ("Deutsche Bank"), Defendant Fidelity National Title Group, Inc. ("Fidelity"), and Defendant Chicago Title Insurance Company ("Chicago"), by and through their respective attorneys of records, hereby agree and stipulate as follows.
1. On May 28, 2019, Fidelity filed a Motion to Dismiss for Lack of Personal Jurisdiction; or in the Alternative, to Dismiss for Failure to State a Claim; Memorandum of Points and Authorities [ECF No. 6];
2. On May 28, 2019, Chicago filed a Motion to Dismiss for Lack of Subject Matter Jurisdiction; Memorandum of Points and Authorities [ECF No. 7];
3. Deutsche Bank's response to the Motions to Dismiss are currently due June 11, 2019;
4. Deutsche Bank's counsel is requesting an additional thirty (30) days to file its responses to the Motions to Dismiss, and thus requests up to July 11, 2019, to file its Oppositions;
5. This extension is requested to allow Counsel for Deutsche Bank additional time to review and respond to the points and authorities cited to in the Motions;
6. Counsel for Fidelity and Chicago does not oppose this extension;
7. This is the first request for an extension which is made in good faith and not for purposes of delay; and
8. In addition, the Parties stipulate to stay discovery pending conclusion of briefing on the Motions to Dismiss [ECF Nos. 6 and 7]; in other words, through the date that Fidelity and Chicago each file a Reply in support of their respective Motion to Dismiss. Thereafter, discovery shall automatically resume.
IT IS SO STIPULATED.
Dated this 11th day of June, 2019. Dated this 11th day of June, 2019.
WRIGHT, FINLAY & ZAK, LLP EARLY SULLIVAN WRIGHT GIZER &
McRAE LLP
/s/Christina V. Miller
Christina V. Miller, Esq. /s/Sophia S. Lau
Nevada Bar No. 12448 Kevin S. Sinclair, Esq.,
Lindsay D. Robbins, Esq. Nevada Bar No. 12277
Nevada Bar No. 13474 Sophia S. Lau, Esq.,
7785 W. Sahara Ave., Suite 200 Nevada Bar No. 13365
Las Vegas, NV 89117 8716 Spanish Ridge Avenue, Suite 105
Attorneys for Plaintiff Deutsche Bank Las Vegas, Nevada 89148
National Trust Company, As Trustee For Attorneys for Defendants, Fidelity National
Ameriquest Mortgage Securities Inc., Asset-Backed Title Group, Inc. and Chicago Title
Pass-Through Certificates, Series Insurance Company
2005-R3
IT IS SO ORDERED.
