Wells Fargo Bank, N.A. v. Fidelity National Title Insurance Company

WRIGHT, FINLAY & ZAK, LLP Lindsay D. Dragon, Esq.

2 Nevada Bar No. 13474 7785 W. Sahara Ave., Suite 200 Las Vegas, NV 89117 (702) 475-7964; Fax: (702) 946-1345 [email protected] Attorney for Plaintiff, Wells Fargo Bank, N.A., As Trustee For The Pooling And Servicing Agreement Dated As Of August 1, 2005 Park Place Securities, Inc. Asset-Backed Pass-Through Certificates Series 2005-WHQ4 UNITED STATES DISTRICT COURT 8 DISTRICT OF NEVADA WELLS FARGO BANK, N.A., AS TRUSTEE Case No.: 2:19-cv-01874-RFB-BNW FOR THE POOLING AND SERVICING AGREEMENT DATED AS OF AUGUST 1, JOINT STATUS REPORT and 2005 PARK PLACE SECURITIES, INC. STIPULATION REGARDING COURT ASSET-BACKED PASS-THROUGH ORDER ON JOINT MOTION TO LIFT CERTIFICATES SERIES 2005-WHQ4, STAY [ECF No. 14].

Plaintiff, vs. FIDELITY NATIONAL TITLE INSURANCE COMPANY and LAWYERS TITLE INSURANCE CORPORATION, 18 Defendants.

Plaintiff, Wells Fargo Bank, N.A., As Trustee For The Pooling And Servicing Agreement Dated As Of August 1, 2005 Park Place Securities, Inc. Asset-Backed Pass-Through Certificates Series 2005-WHQ4 (“Wells Fargo”) and Defendant Fidelity National Title Insurance Company (“Fidelity”, collectively the “Parties”), by and through their undersigned counsel of record, hereby submit the following joint status report in response to this Court’s Minute Order, dated October 14, 2020, directing the parties to file a Joint Motion to Lift Stay within 14 days from the disposition of the appeal in Wells Fargo, N.A. v. Fid. Nat’l Title Ins. Co., Case No. 3:19-cv- 00241-MMD-WGC (Ninth Circuit Case No. 19-17332) (“Wells Fargo II”) [ECF No. 14]. . . .

1 On November 5, 2021, the Ninth Circuit issued its Memorandum Disposition in Wells || Fargo I, vacating the order granting Fidelity’s Motion to Dismiss and remanding the case for || the court to determine whether leave to amend the complaint is appropriate. See Wells Fargo || Bank, N.A.. v. Fid. Nat'l Title Ins. Co., 2021 U.S. App. LEXIS 32975 (9th Cir. Nov. 5, 2021).

5 || Mandate has not yet issued. It is not clear to Wells Fargo whether ECF No. 14 requires a joint || motion from the date the Wells Fargo IT decision was entered or the date of mandate. In order ||to ensure compliance with the Court’s minute order, the parties have stipulated and agree that || any joint motion shall be due 14 days from the date mandate is issued in Wells Fargo II. ? || DATED this 19" day of November, 2021. DATED this 19" day of November, 2021.

WRIGHT, FINLAY & ZAK, LLP SINCLAIR BRAUN LLP || □□ Lindsay D. Dragon /s/ Kevin S. Sinclair || Lindsay D. Dragon, Esq. Kevin S. Sinclair, Esq.

Nevada Bar No. 13474 Nevada Bar No. 12277 || 7785 W. Sahara Ave., Suite 200 16501 Ventura Blvd, Suite 400 Las Vegas, NV 89117 Encino, CA 91436 Attorney for Plaintiff Wells Fargo Bank, Attorneys for Defendant, Fidelity National 16 N.A., As Trustee For The Pooling And Title Insurance Company Servicing Agreement Dated As Of August I, || 2005 Park Place Securities, Inc. Asset- 1 Backed Pass-Through Certificates Series || 2005-WHO4 21 IT IS SO ORDERED.

22 DATED _ November 22 2021 RICHA LWARE, II 26 : □ os United States District Court