WRIGHT, FINLAY & ZAK, LLP 1 Darren T. Brenner, Esq. 2 Nevada Bar No. 8386 Lindsay D. Dragon, Esq. 3 Nevada Bar No. 13474 7785 W. Sahara Ave., Suite 200 4 Las Vegas, NV 89117 5 (702) 637-2345; Fax: (702) 946-1345 [email protected] 6 [email protected] Attorneys for Plaintiff, Bank of America, N.A. 7

8 UNITED STATES DISTRICT COURT DISTRICT OF NEVADA 9 10 BANK OF AMERICA, N.A., Case No.: 2:21-cv-00584-KJD-NJK

11 Plaintiff, STIPULATION AND ORDER TO vs. EXTEND DEADLINES TO RESPOND 12 TO NATIC’S PENDING MOTIONS 13 NORTH AMERICAN TITLE INSURANCE COMPANY, (Second Request) 14 Defendants. 15 16 Plaintiff, Bank of America, N.A. (“BANA”) and Defendant, North American Title 17 Insurance Company (“NATIC”), by and through their undersigned counsel, stipulate and agree 18 as follows: 19 1. On September 29, 2023, NATIC filed a Motion for Summary Judgment [ECF No. 36], as 20 well as a Motion to Seal and Redact an exhibit to the Motion [ECF No. 38]. 21 2. BANA’s responses to NATIC’s pending Motions are currently due November 20, 2023 22 [ECF No 41]. 23 3. On November 6, 2023, the Parties submitted a Stipulation to Stay Case in light of the 24 October 12, 2023 decision from the Nevada Supreme Court in Deutsche Bank National 25 Trust Company v. Fidelity National Title Insurance Company, Case No. 84161,

Ad. Rep. 45,

(Nev. 2023) (“Deutsche Bank Opinion”) [ECF No. 42]. The 27 Parties requested that the stay in the case be in affect until the remittitur issued in Deutsche 28 Bank. 1 4. The Court has not yet entered an Order on the Stipulation. 2 5. On October 30, 2023, the appellant filed a Petition for Rehearing in Deutsche Bank. While 3 the Petition for Rehearing was denied on November 13, 2023, the remittitur has not yet 4 issued.! 5 6. In light of the Court’s pending Order on the Parties’ stipulation to stay case, BANA 6 requests an additional thirty (30) days to file its response to the pending Motions, through 7 and including, December 20, 2023. 8 7. Counsel for NATIC does not oppose the requested extension. 9 8. This is the second request for an extension which is made in good faith and not for 10 purposes of delay. 11 IT IS SO STIPULATED. 12 |! DATED this 20" day of November 2023. DATED this 20" day of November, 2023. 1 3 WRIGHT, FINLAY & ZAK, LLP SINCLAIR BRAUN LLP 14 /s/ Lindsay D, Dragon, Esq. /s/ Kevin S. Sinclair, Esq. 15 Lindsay D. Dragon, Esq. Kevin S. Sinclair, Esq. 16 Nevada Bar No. 13474 Nevada Bar No. 12277 7785 W. Sahara Ave., Suite 200 16501 Ventura Blvd, Suite 400 17 Las Vegas, Nevada 89117 Encino, California 91436 Attorneys for Plaintiff, Bank of America, N.A. Attorneys for Defendant, North American 18 Title Insurance Company 19 20 21 92 || IT IS SO ORDERED. 23 Dated this 21St_day of November 9923. \ 24 25 UNITED STATES DISTRICT COURT JUDGE 26 27 |, tet . . . The remittitur in Deutsche Bank is set to issue on December 8, 2023. See NRAP 41(b)(1) Gifa 28 || petition for rehearing is denied, “the remittitur shall issue 25 days after entry of the order denying the petition.”).