District Court, D. Nevada, 2025

Michael G. Naessens v. Bank of America, N.A.

Michael G. Naessens v. Bank of America, N.A.
District Court, D. Nevada · Decided October 1, 2025
Michael G. Naessens v. Bank of America, N.A.

Trial Court Opinion

3 UNITED STATES DISTRICT COURT 4 DISTRICT OF NEVADA Michael G. Naessens, Case No. 2:25-cv-01079-RFB-NJK 7 Plaintiff(s), Order v. [Docket Nos. 62-65] Bank of America, N.A., 10 Defendant(s).

11 Pending before the Court are Plaintiff’s motions to compel Defendant to amend its certificate of interested parties and for sanctions. Docket No. 62-65.1 Defendant filed a response in opposition. Docket No. 71. Plaintiff filed a reply. Docket No. 73. The Court does not require a hearing. See Local Rule 79-1.

15 A party must file a certificate of interested parties to identify persons, associations, firms, partnerships, or corporations that have a “direct, pecuniary interest in the outcome of the case.”

17 Local Rule 7.1-1. A central function of this filing is to alert the assigned judges to potential recusal issues. See id. 19 The instant motion practice centers on Plaintiff’s contention that Defendant should have identified Early Warning Services, LLC as an interested party in its certificate. See, e.g., Docket No. 62 at 1. To the extent Plaintiff believes Early Warning Services, LLC is an interested party, then Plaintiff could identify it on his own certificate of interested parties. See Local Rule 7.1-1 (requiring certificates of interested parties to be filed by pro se plaintiffs). Indeed, Plaintiff appears to have now effectively done that. See Docket No. 19. Hence, it would appear the central function The Court liberally construes the filings of pro se litigants. Erickson v. Pardus, 551 U.S. 28 89, 94 (2007).

1] of these filings (alerting the judges to potential recusal issues) has been fulfilled.2 Moreover, the 2|| Court is not persuaded that sanctions should be imposed based on the circumstances.

3 Accordingly, Plaintiff’s motions to compel and for sanctions are DENIED.’

4 IT IS SO ORDERED.

5 Dated: October 1, 2025 .

Nancy J. Koppé 7 United States Magistrate Judge ——___________ ? Plaintiff seems to misunderstand the function of certificates of interested parties. For example, Plaintiff argues that his “ability to conduct discovery against a necessary party” has been thwarted. Docket No. 62 at 2. The scope of relevance for discovery purposes 1s tied to the claims and defenses in the case, see Fed. R. Civ. P. 26(b)(1), and Plaintiff does not explain why discovery is impacted by the contents of a certificate of interested parties. > The motion to compel seeks an order that Defendant file a corrected certificate of 27) interested parties. Docket No. 62 at 1. The reply brief seeks different relief. See Docket No. 73.

The Court declines to address requests for relief raised for the first time in reply. Zamani v. Carnes, 28] 491 F.3d 990, 997 (9th Cir. 2007).

Case-law data current through December 31, 2025. Source: CourtListener bulk data.