Patrick R. Leverty, Esq., NV Bar No. 8840 1 || William R. Ginn, Esq., NV Bar No. 6989 LEVERTY & ASSOCIATES LAW CHTD. 2 ||3100 W. Charleston Blvd., Suite 200 Las Vegas, NV 89102 3 ||Ph. (702) 507-0201 4 ||MAILING ADDRESS 832 Willow Street 5 |/Reno, NV 89502 Telephone: (775) 322-6636 6 || Attorneys for RMC Motorsports, LLC g UNITED STATES DISTRICT COURT

9 DISTRICT OF NEVADA

10 RMC MOTORSPORTS, LLC Case No.: 2:25-CV-00547-CDS-DJA

11 Plaintiff, STIPULATION AND [PROPOSED] ORDER TO STAY THE CASE WHILE THE 12 PARTIES DISCUSS RESOLUTION 13 || vs. (Second Request) 14 |} BERKSHIRE HATHAWAY DIRECT INSURANCE COMPANY, et al. As amended on page 2 15 Defendants 16 17 TO THE COURT: 18 Plaintiff RMC Motorsports, LLC (““RMC”) and Berkshire Hathaway Direct Ins. Co. and 19 ||Biberk Insurance Services, Inc. (collectively “Berkshire”), by and through counsel, stipulate and 20 ||agree as follows: 21 WHEREAS, this matter is an insurance coverage dispute regarding benefits owing in 22 ||connection with stolen property; 23 WHEREAS, on March 31, 2025, Berkshire filed a Motion to Compel Appraisal and Stay 24 ||the Case (ECF NO. 6); 25 WHEREAS, RMC and Berkshire (collectively “Parties”) desire to explore settlement in 26 lieu of incurring litigation costs and expenses; 27 WHEREAS, RMC has provided documentation to Berkshire to support their claims; \ 28

] WHEREAS, Berkshire is processing the documentation provided and also addressing 2 ||third-party theft claims related to RMC’s loss; 3 WHEREAS, the Parties believe it is in their best interest to continue discussions to try to 4 ||resolve this case as opposed to expending time and resources to litigating this matter; 5 WHEREFORE, the Parties, subject to this Court’s approval, agree to Stay the Case 6 ||(ECF NO. 6) to July 31, 2025. 7 IT IS SO AGREED. 8 ||DATED: June 4, 2025 DATED: June 4, 2025 9 ||LEVERTY & ASSOCIATES LAW CHTD. MORALES FIERRO & REEVES 10 /S/ Patrick Leverty /S/ William Reeves _ 11 ||Patrick R. Leverty, Esq. William C. Reeves, Esq. 832 Willow Street 600 S. Tonopah Drive, Suite 300 12 ||Reno, NV 89502 Las Vegas, NV 89106 Attorneys for RMC Motorsports, LLC Attorneys for Defendants 13 Berkshire Hathaway Direct Ins. Co. and 4 Biberk Insurance Services, Inc.

15 16 The Court, having considered the stipulation of the Parties and good cause appearing, 17 Stays the Case until July 31, 2025, to allow the Parties time to try to resolve this dispute. 18 || See Landis v. North American Co.,

(1936) (explaining that "the power to stay proceedings is incidental to the power inherent in every court to control the 19 || disposition of the causes on its docket...") 20!) The parties shall either file a stipulation of dismissal, a stipulation to continue the stay, or a 21 || stipulation to lift the stay and set a discovery plan on or before August 7, 2025. 22 || The Court will further DENY Defendants’ motion to compel appraisal (ECF No. 6) without 53 prejudice and with leave to refile if settlement is unsuccessful.

94 || IT ISSO ORDERED. 25 ID A/) 26 DANIEL J. ALBREGTS 7 UNITED STATES MAGISTRATE JUDGE \ 28 DATED: June 13, 2025

1 CERTIFICATE OF SERVICE 2 Pursuant to FRCP 5(b), I hereby certify under penalty of perjury that am an employee o 3 ||Leverty & Associates Law, Chtd., and that service of the foregoing STIPULATION AND 4 ||[PROPOSED] ORDER TO STAY THE CASE WHILE THE PARTIES DISCUSS 5 |; RESOLUTION was made CM/ECF to all parties on the Service List including: William C. Reeves 7 State Bar No.: 8235 MORALES FIERRO & REEVES 8 ||| 600 S. Tonopah Drive, Suite 300 Las Vegas, NV 89106 9 ||| Telephone: 702/699-7822 Facsimile: 702/699-9455 10 ||| Email: [email protected] Attorneys for Defendants 11 ||| Berkshire Hathaway Direct Ins. Co. and Biberk Insurance Services, Inc. DATED: June 4, 2025 13

15 An Employee of Leverty & Associates Law Chtd. 16 17 18 19 20 21 22 23 24 25 26 27 \ 28