WRIGHT, FINLAY & ZAK, LLP 1 Christina V. Miller, Esq. 2 Nevada Bar No. 12448 8337 W. Sunset Road, Suite 220 3 Las Vegas, Nevada 89113 (702)475-7964; Fax: (702) 946-1345 4 [email protected] 5 Attorneys for Defendant Freedom Mortgage Corporation 6 UNITED STATES DISTRICT COURT DISTRICT OF NEVADA 7 8 M.T. REAL ESTATE INVESTMENT INC., Case No.: 2:25-cv-01372-GMN-DJA 9 Plaintiff, STIPULATION AND ORDER TO STAY 10 vs. DISCOVERY PENDING OUTCOME OF PENDINGS MOTIONS TO DISMISS 11 SERVIS ONE, INC. DBA BSI FINANCIAL (ECF NOS. 6 AND 8) SERVICES; MTC FINANCIAL INC. DBA 12 TRUSTEE CORPS; FREEDOM MORTGAGE CORPORATION; MORTTGAGE 13 ELECTRONIC REGISTRATION SYSTEMS, 14 INC. (MERS); and DOES 1 THROUGH 10, inclusive; AND ROE CORPORATIONS 1 – 10, 15 inclusive, 16 Defendants. 17 COME NOW, Plaintiff M.T. Real Estate Investment, Inc. (“MTREI”), and Defendants 18 Freedom Mortgage Corporation (“Freedom”), Servis One, Inc. dba BSI Financial Services 19 (“BSI”) and Mortgage Electronic Registration Systems, Inc. (“MERS”) (MTREI, Freedom, BSI 20 and MERS are collectively, the “Parties”), by and through their counsel of record, and hereby 21 stipulate and agree as follows: 22 On June 9, 2025, MTREI filed its Complaint in the Eighth Judicial District Court, State 23 of Nevada. ECF No. 1-1. The action was subsequently removed to this Court on July 29, 2025. 24 ECF No. 1. On July 30, 2025, Defendants BSI and MERS filed a Motion to Dismiss for Failure 25 to State a Claim, or Alternatively Motion for Summary Judgment. ECF No. 6. On August 7, 2025, 26 Freedom filed its separate Motion to Dismiss Plaintiff’s Complaint With Prejudice. ECF No. 8. 27 Both Motions to Dismiss are not yet fully briefed. 28 1 The Parties submit that the Tradebay, LLC v. eBay, Inc.,

(D. Nev. 2 □□ 2011) factors weigh in favor of a stay of discovery because a ruling in favor of Defendants on 3 || their pending Motions to Dismiss (ECF Nos. 6 and 8) will be case-dispositive and can be decided 4 || without the need for additional discovery. Accordingly, in the interests of judicial economy and 5 || as permitted by Fed. R. Civ. P. 1, the parties stipulate and agree that discovery should be stayed 6 || pending decision on the pending Motions to Dismiss. 7 The Parties further stipulate and agree that, in the event the pending Motions to Dismiss 8 || are denied in whole or in part, the stay shall be automatically lifted and the Parties shall submit 9 || their proposed Discovery Plan and Scheduling Order within 21 days after entry of the Court’s 10 |] order(s) on the Motions to Dismiss. 11 IT IS SO STIPULATED. 12 DATED this 4 day of September, 2025. 13 WRIGHT, FINLAY & ZAK, LLP D. BRYCE FINLEY, ESQ. 14 /s/ Christina V. Miller /s/ D. Bryce Finley 15 || Christina V. Miller, Esq. D. Bryce Finley, Esq. 16 Nevada Bar No. 12448 Nevada Bar No. 9310 7785 W. Sahara Ave, Suite 200 8668 Spring Mountain Road, Suite 110 17 || Las Vegas, NV 89117 Las Vegas, NV 89117 Attorney for Defendant, Freedom Attorneys for Plaintiff M.T. Real Estate 18 Mortgage Corporation Investment, Inc. 19 ATLAS | SOLOMON LLP 20 /s/ Natalie L. Winslow 21 || Natalie L. Winslow, Esq. 97 || Nevada Bar No. 12125 7674 W. Lake Mead Blvd., Suite 220 23 || Las Vegas, NV 89128 Attorneys for Defendants Servis One, Inc. dba 24 |) BST financial Services and Mortgage Electronic 25 || Registration Systems, Inc. 26 ) _- IT IS SO ORDERED. CO? PN) 27 | YO 28 UNITED STATES MA\GISTRATE JUDGE DATED: 9/5/2025