The Standard Fire Insurance Company v. Xiyue Yang

District Court, D. Nevada

The Standard Fire Insurance Company v. Xiyue Yang

Trial Court Opinion

1 Sheri M. Thome, Esq. Nevada Bar No. 008657 2 Jeffrey A. Bollers, Esq. Nevada Bar No. 016501 3 WILSON, ELSER, MOSKOWITZ, EDELMAN & DICKER LLP 4 6689 Las Vegas Blvd. South, Suite 200 Las Vegas, Nevada 89119 5 Telephone: 702.727.1400 Facsimile: 702.727.1401 6 Email: [email protected] Email: [email protected] 7 Attorneys for Plaintiff The Standard Fire Insurance Company 8 UNITED STATES DISTRICT COURT 9 DISTRICT OF NEVADA 10 THE STANDARD FIRE INSURANCE Case No. 2:25-cv-01757-JAD-NJK 11 COMPANY

12 Plaintiff, STIPULATION TO EXTEND TIME FOR PLAINTIFF TO FILE RESPONSE TO 13 v. DEFENDANT'S MOTION TO DISMISS

14 (FIRST REQUEST) XIYUE YANG, an individual,

15 Defendant. 16 17 Plaintiff The Standard Fire Insurance Company ("SFIC") by and through its counsel of 18 record, Sheri Thome, Esq. and Jeffrey A. Bollers, Esq., of the law offices of Wilson, Elser, 19 Moskowitz, Edelman & Dicker LLP, and Defendant Xiyue Yang by and through his attorney of 20 record, Thomas N. Beckom, Esq. of Thomas Beckom Law, PLLC hereby stipulate pursuant to 21 Local Rule IA 6-1 to extend the time for Plaintiff SFIC to submit its Response to Defendant's Motion 22 to Dismiss as follows:

23 STIPULATION FOR EXTENSION OF TIME FOR PLAINTIFF TO FILE RESPONSE TO DEFENDANT'S MOTION TO DISMISS 24 25 1. Plaintiff filed its Complaint for Declaratory Relief and Breach of Contract on 26 September 17, 2025. [ECF 1] 27 2. Defendant filed a Motion to Dismiss Pursuant to F.R.C.P. 12(b)(6) on November 10, 1 3. Pursuant to LR 7-2(b), Plaintiff's Response in the Motion to Dismiss is due November 2 24, 2025. The parties have conferred and hereby stipulate to extend the time for the Plaintiff to file 3 its Response to Defendant's Motion to Dismiss by ten (10) days, until December 4, 2025. 4 4. The stipulated extension will afford counsel for Plaintiff SFIC sufficient time to 5 confer with the client representatives about Defendant's Motion, the arguments to be raised in the 6 Response, and the bases therefor. The opportunity to do so earlier has been restricted by counsel's 7 limited availability due to other obligations. No party will be prejudiced by the stipulated ten-day 8 extension, nor will the stipulated extension unduly delay resolution of any issues in this case. 9 5. This stipulation is entered into in good faith, and not for purposes of delay or any other 10 improper reason. 11 IT IS SO STIPULATED. 12 || Dated this 20th day of November 2025 Dated this 20th day of November 2025 13 || THOMAS BECKOM LAW PLLC WILSON, ELSER, MOSKOWITZ, EDELMAN 4 & DICKER LLP By: /s/Thomas N. Beckom By: /s/Jeffrey A. Bollers 15 Thomas N. Beckom, Esq. Sheri M. Thome, Esq. Nevada Bar No. 12554 Nevada Bar No. 008657 16

610 South 9

" Street Jeffrey A. Bollers, Esq. Las Vegas, Nevada 89101 Nevada Bar No. 016501 17 Attorney for Defendant Xiyue Yang 6689 Las Vegas Blvd. South, Suite 200 Las Vegas, Nevada 89119 18 Attorneys for Plaintiff The Standard Fire Insurance Company 19 20 ORDER 21 IT IS HEREBY ORDERED that pursuant to the above Stipulation, Plaintiff SFIC shall file 22 || its Response to Defendant's Motion to Dismiss Pursuant to F.R.C.P. 12(b)(6) no later than December 23 || 4, 2025. 24 IT IS SO ORDERED. 25 26 sf eas UNITER STATES DI CT JUDGE 27 DATED: 12/1/2025 28 ry

Reference

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