WRIGHT, FINLAY & ZAK, LLP 1 Christina V. Miller, Esq. 2 Nevada Bar No. 12448 Stephanie Garabedian, Esq. 3 Nevada Bar No. 9612 8337 W. Sunset Rd., Suite 220 4 Las Vegas, NV 89113 5 (949) 477-5050; Fax: (702) 946-1345 [email protected] 6 [email protected] Attorneys for Defendants, Statebridge Company LLC and Wilmington Savings Fund Society, 7 FSB, d/b/a Christiana Trust as Trustee for PNPMS Trust I 8 UNITED STATES DISTRICT COURT 9 DISTRICT OF NEVADA 10 ELENA ESPINO, Trustee of the Rommel and Case No.: 2:24-cv-02347-CDDJAS- DJA 11 Elena Espino Trust,

12 Plaintiffs, STIPULATION AND ORDER TO STAY 13 DISCOVERY PENDING RULING ON vs. FORTHCOMING MOTION TO 14 DISMISS STATEBRIDGE COMPANY LLC, a 15 Colorado Limited Liability Company; 16 WILMINGTON SAVINGS FUND SOCIETY, FSB, d/b/a Christiana Trust as Trustee for 17 PNPMS Trust I; SABLES LLC, a Nevada Limited Liability Company, MORTGAGE 18 ELECTRONIC REGISTRATION SYSTEMS, 19 INC., a Foreign Corporation; UNIVERSAL AMERICAN MORTGAGE COMPANY, LLC, 20 a Florida Limited Liability Company; US BANK NATIONAL ASSOCIATION, a National 21 Banking Association, AND DEFENDANT 22 DOES 1-100 AND ROES 3-10,

23 Defendants.

24 25 Defendants, Statebridge Company LLC and Wilmington Savings Fund Society, FSB, 26 d/b/a Christiana Trust as Trustee for PNPMS Trust I (collectively “Defendants”), Defendant 27 Sables LLC (“Sables”), and Plaintiff, Elena Espino (“Plaintiff” and with Sables and Defendants, 28 the “Parties”), by and through their counsel of record, hereby stipulate and agree as follows: 1 WHEREAS, on December 16, 2024, Removing Defendants removed Plaintiff’s First 2 Amended Complaint to this Court [ECF No. 1]; 3 WHEREAS, on December 23, 2024, Removing Defendants filed a Motion to Dismiss 4 Plaintiff’s First Amended Complaint [ECF No. 6]; 5 WHEREAS, on March 4, 2025, the Parties stipulated to stay discovery pending a ruling 6 on Removing Defendants’ Motion to Dismiss [ECF No. 17]; 7 WHEREAS, on September 17, 2025, the Court entered an Order Granting Removing 8 Defendants’ Motion to Dismiss [ECF No. 19]; 9 WHEREAS, on October 3, 2025, Plaintiff filed her Second Amended Complaint [ECF 10 No. 20]; 11 WHEREAS, on October 15, 2025, Plaintiff and Defendants stipulated to extend the time 12 for Removing Defendants to respond to the Second Amended Complaint to November 7, 2025 13 [ECF No. 21]; 14 WHEREAS, on October 21, 2025, the Court entered a Minute Order requiring the Parties 15 to file a Stipulated Discovery Plan by November 4, 2025 [ECF No. 23]; and 16 WHEREAS, although it has not been filed yet, Defendants plan to file a Motion to 17 Dismiss Plaintiff’s Second Amended Complaint on or before November 7, 2025. 18 NOW THEREFORE, the Parties, by and through their undersigned counsel, hereby 19 stipulate and agree as follows: 20 1. In the interests of judicial economy, the Parties stipulate and agree that discovery in 21 this case shall be STAYED pending the Court’s decision on Defendants’ forthcoming 22 Motion to Dismiss Plaintiff’s Second Amended Complaint; 23 2. Nothing contained in this stipulation will affect any pending dispositive motions or 24 prevent the Parties from filing any dispositive motions; 25 3. Each of the Parties may request a further Fed R. Civ. P. 26(f) conference at any time 26 180 days after the order granting this Stipulation; 27 4. By entering into this Stipulation, none of the parties are waiving their right to 28 subsequently move the Court for an order lifting the stay in this action; and 1 5. In the event the forthcoming Motion to Dismiss is denied, the Parties will submit a 2 proposed discovery plan within thirty (30) days of the Court’s Order. 3 IT IS SO STIPULATED. 4 || DATED this 4th day of November, 2025. WRIGHT, FINLAY & ZAK, LLP HOMEOWNER RELIEF LAWYERS 7 /s/ Stephanie A. Garabedian, Esq. /s/ Dale K. Kleven, Esq. Stephanie Garabedian, Esq. Dale K. Kleven, Esq. 8 Nevada Bar No. 9612 Nevada Bar No. 7778 8337 W. Sunset Rd., Suite 220 7455 W. Azure Drive, Suite 130 9 Las Vegas, NV 89113 Las Vegas, NV 89130 10 Attorneys for Defendants, Statebridge Attorneys for Plaintiff, Elena Espino Company LLC and Wilmington Savings 11 Fund Society, FSB, d/b/a Christiana Trust as Trustee for PNPMS Trust I 12 || ZBs LAW, LLP 13 /s/ J. Stephen Dolembo, Esq. 14 J. Stephen Dolembo, Esq. 15 Nevada Bar No. 9795 9435 W. Russell Road, Suite 120 16 Las Vegas, Nevada 89148 Attorney for Defendant, Sables, LLC 17 Having reviewed the parties’ stipulation, the Court finds that they have demonstrated good 18 cause to stay discovery pending the outcome of the forthcoming motion to dismiss. See 19 Schrader v. Wynn, No. 2:19-cv-02159-JCM-BNW,

(D. Nev. Oct. 14, 2021). IT IS THEREFORE ORDERED that the stipulation (ECF No. 25) is GRANTED.

71 Dated this 5th day of November , 20

DANIEL J. ALBREGTS 24 UNITED STATES MAGISTRATE JUDGE 25 26 27 28