Markowitz v. Saxon Special Servicing

OPINION

Under Nevada’s Foreclosure Mediation Program Rules, the deed-trust beneficiary must submit an appraisal and/or a broker’s price opinion prepared “no more than 60 days before the commencement date of the mediation” that provides a valuation for the home that is the subject of the mediation. Saxon Special Servicing attended the underlying mediation and provided a broker’s price opinion that was 83 days old at the time of mediation. We are asked to decide whether the mediation rule requiring an appraisal or broker’s price opinion that is no more than 60 days old at the time of the…