United States District Court, W.D. Washington, Seattle
HSBC BANK USA, NATIONAL ASSOCIATION AS TRUSTEE FOR THE J.P. MORGAN ALTERNATIVE LOAN TRUST 2006-A7, Plaintiff,
DONALD E. MACCORD et al., Defendants. DONALD E. MACCORD, Counterclaim Plaintiff,
NATIONSTAR MORTGAGE, LLC, HSBC BANK USA, NATIONAL ASSOCIATION AS TRUSTEE FOR THE J.P. MORGAN ALTERNATIVE LOAN TRUST 2006-A7, Counterclaim Defendants.
CRONIN MICHELSON BAUMGARDNER FOGG &MOORE LLP Todd T.
Williams, CORR CRONIN MICHELSON BAUMGARDNER FOGG & MOORE
LLP Attorneys for Defendant/ Counterclaim Plaintiff Donald E.
MCCARTHY & HOLTHUS LLP Wendy L. Walter, MCCARTHY &
HOLTHUS LLP Attorneys for Plaintiff HSBC Bank USA, National
WITHERSPOON ∙ KELLEY Daniel J. Gibbons, Attorneys for
Counterclaim Defendants HSBC Bank USA, National Association,
and Nationstar Mortgage LLC.
STIPULATION AND ORDER TO EXTEND DISCOVERY AND
DISPOSITIVE MOTION DEADLINES BY 30 DAYS
RICARDO S. MARTINEZ CHIEF UNITED STATES DISTRICT JUDGE.
Defendant HSBC Bank USA, National Association, Counterclaim
Defendant Nationstar Mortgage LLC, and Defendant/Counterclaim
Plaintiff Donald E. MacCord (“Defendant/Counterclaim
Plaintiff”) (collectively, the “Parties”),
by and through their undersigned counsel, hereby stipulate to
a 30 day extension of the discovery and dispositive motion
deadlines enumerated in the Court's August 30, 2017 Order
Setting Trial Date and Related Dates, and respectfully
request that the Court enter an Order to extend said
deadlines. In requesting this extension of time, the Parties
hereby represent as follows.
Defendant/Counterclaim Plaintiff removed this matter
(“Litigation”) from King County Washington
Superior Court, Case No. 16-2-26478-6 SEA, on June 6, 2017.
June 15, 2017, the Court entered its August 30, 2017 Order
Setting Trial Date and Related Dates (“Order Setting
Trial Date and Related Dates”) setting forth the trial
date and deadlines regarding discovery, dispositive motions,
and related pre-trial matters. ECF 25.
Parties engaged in mediating this matter on or about December
20, 2017, which mediation did not immediately resolve the
Litigation, however defined their respective positions and
led to the continued and ongoing attempt to settle this
After the mediation ended, it was determined that continued
negotiations would require that the Parties ascertain the
condition of the real property (“Property”)
related to the Litigation.
Parties have continued to cooperate, and the Property was
recently evaluated to facilitate the ongoing effort to
resolve the Litigation.
the result of the evaluation of the Property only just
becoming available, the Parties will require additional time
to assess the impact of the condition of the Property on
parties anticipate making additional progress with
negotiations, and wish to focus their time and resources on
settlement rather than discovery.
light of the ongoing settlement efforts, the Parties agree
and hereby stipulate that a 30 day extension of the discovery
and dispositive deadlines is ...