throbber
District Court Case No: A-21-832316-C
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`Electronically Filed
`Apr 22 2025 02:21 PM
`Elizabeth A. Brown
`Clerk of Supreme Court
`IN THE EIGHTH JUDICIAL DISTRICT COURT OF THE
`STATE OF NEVADA IN AND FOR
`THE COUNTY OF CLARK
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`Plaintiff(s),
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`vs.
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`Defendant(s).
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`2 of 2
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`YANLING ZHANG,
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`YANHUI ZHANG,
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`NOTICE OF APPEAL PACKET
`COVER SHEET
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`Docket 90509 Document 2025-18011
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`

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`NOAS
`MICHAEL M LIN, ESQ.
`Nevada Bar No. 010392
`LIN LAW GROUP
`5288 Spring Mtn. Rd, Ste 103
`Las Vegas, Nevada 89146
`(702) 871 9888
`Attorney for Plaintiff
`
`IN THE EIGHT JUDICIAL DISTRICT COURT
`OF THE STATE OF NEVADA IN AND FOR THE COUNTY OF CLARK
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`CASE NO. A-21-832316-C
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`DEPT NO. 11
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`YANLING ZHANG, an individual,
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` Plaintiff,
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`vs.
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`YANHUI ZHANG, an individual; DOES I
`through X and ROE CORPORATIONS I
`through X, inclusive,
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` Defendant.
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`NOTICE OF APPEAL
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` Notice is hereby given that YANLING ZHANG, Plaintiff above named, hereby appeals to
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`the Supreme Court of Nevada from the final order of the Civil Order to Statistically Close Case
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`entered in this action on the 15th day of April 2025. A true and correct copy of the Order is
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`attached hereto as Exhibit 1.
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`Dated this 18th day of April, 2025.
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`
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`LIN LAW GROUP
`
`/s/ Michael Lin___
`MICHAEL M. LIN, ESQ.
`Nevada Bar No. 10392
`Page 1 of 2
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`(702) 871-9888 FAX: (702) 648-0888
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`5288 SpringMtnRd., Ste 103
`LIN LAW GROUP
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`Las Vegas, NV 89146
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`Case Number: A-21-832316-C
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`Electronically Filed
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`4/18/2025 3:12 PM
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`Steven D. Grierson
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`CLERK OF THE COURT
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`

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`5288 Spring Mtn. Rd, Ste 103
`Las Vegas, Nevada 89146
`Attorneys for Plaintiff
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`CERTIFICATE OF SERVICE
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`Pursuant to NRCP 5(b) and EDCR 7.26, I certify that on this date, I served the above
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`and foregoing on all parties to this action via Electronic service made in accordance with the E-
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`Service List as follows or by placing in the US mail, enclosed in a sealed envelope and postage
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`prepaid:1
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`Timothy Wiseman, Esq.
`Nevada Bar No. 13786
`5450 W. Sahara Ave Ste 330
`Las Vegas, NV 89146
`Attorney for Defendant
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`Dated this 18th day of April, 2025.
`
`_____/s/ Ngoc Phan______
`An employee of the law firm of
`LIN LAW GROUP
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`1 Pursuant to EDCR 8.05(a), each party who submits an E-Filed document through the E-Filing System
`consents to electronic service in accordance with NRCP 5(b)(2)(D).
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`(702) 871-9888 FAX: (702) 648-0888
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`5288 SpringMtnRd., Ste 103
`LIN LAW GROUP
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`Las Vegas, NV 89146
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`

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`OSCC
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`DISTRICT COURT
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`CLARK COUNTY, NEVADA
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`
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`YANLING ZHANG, Plaintiff(s),
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`vs.
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`YANHUI ZHANG, Defendant(s).
`
`
`CASE NO: A-21-832316-C
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`DEPT. 11
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`CIVIL ORDER TO STATISTICALLY CLOSE CASE
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`Upon review of this matter and good cause appearing,
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`IT IS HEREBY ORDERED that the Clerk of the Court is hereby directed to
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`statistically close this case for the following reason:
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`
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`DISPOSITIONS:
`Default Judgment
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`Judgment on Arbitration
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`Stipulated Judgment
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`Summary Judgment
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`Involuntary Dismissal
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` Motion to Dismiss by Defendant(s)
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`Stipulated Dismissal
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`Voluntary Dismissal
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`Transferred (before trial)
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`Non-Jury – Disposed After Trial Starts
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`Non-Jury – Judgment Reached
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`Jury – Disposed After Trial Starts
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`Jury – Verdict Reached
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`Other Manner of Disposition
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`There are no issues or causes of action left for trial. A detailed order will be entered
`shortly. Trial is VACATED at this time.
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`Electronically Filed
`04/15/2025 2:52 PM
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`Case Number: A-21-832316-C
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`ELECTRONICALLY SERVED
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`4/15/2025 2:54 PM
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`

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`CSERV
`
`DISTRICT COURT
`CLARK COUNTY, NEVADA
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`Yanling Zhang, Plaintiff(s)
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`CASE NO: A-21-832316-C
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`vs.
`
`DEPT. NO. Department 11
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`Yanhui Zhang, Defendant(s)
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`AUTOMATED CERTIFICATE OF SERVICE
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`This automated certificate of service was generated by the Eighth Judicial District
`Court. The foregoing Order to Statistically Close Case was served via the court’s electronic
`eFile system to all recipients registered for e-Service on the above entitled case as listed
`below:
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`Service Date: 4/15/2025
`
`Sarah Morris
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`sarah@morrislawcenter.com
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`Timothy Wiseman
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`tim@morrislawcenter.com
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`MLC Calendar
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`MLC Efile
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`MLC Docket
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`MICHAEL LIN
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`Yanhui Zhang
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`Dave Zhang
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`MICHAEL LIN
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`Ngoc Phan
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`OWL Clerk
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`calendar@morrislawcenter.com
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`efile@morrislawcenter.com
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`docket@morrislawcenter.com
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`ML@LINLAWGROUP.COM
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`zyh3000@yahoo.com
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`daveyz@hotmail.com
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`LINLAWGROUP@GMAIL.COM
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`ngocphan@linlawgroup.com
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`clerk@ocampowisemanlaw.com
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`Craig Bourke
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`craigb@linlawgroup.com
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`EIGHTH JUDICIAL DISTRICT COURT
`CASE SUMMARY
`CASE NO. A-21-832316-C
`
`Location: Department 11
`Judicial Officer: Albertson, Anna
`Filed on: 04/05/2021
`Case Number History:
`Cross-Reference Case
`Number:
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`A832316
`
`§§§§§
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`CASE INFORMATION
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`Case Type: Other Real Property
`Case
`Status: 04/15/2025 Closed
`
`Yanling Zhang, Plaintiff(s)
`vs.
`Yanhui Zhang, Defendant(s)
`
`Statistical Closures
`04/15/2025 Other Manner of Disposition
`
`DATE
`
`CASE ASSIGNMENT
`
`Current Case Assignment
`Case Number
`Court
`Date Assigned
`Judicial Officer
`
`A-21-832316-C
`Department 11
`01/03/2023
`Albertson, Anna
`
`PARTY INFORMATION
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`Plaintiff
`
`Zhang, Yanling
`
`Defendant
`
`Zhang, Yanhui
`
`Lead Attorneys
`Lin, Michael M, ESQ
`Retained
`702-871-9888(W)
`Edwards, Michael M.
`Retained
`725-258-7360(W)
`
`DATE
`
`04/05/2021
`
`04/05/2021
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`04/05/2021
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`04/05/2021
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`04/05/2021
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`EVENTS & ORDERS OF THE COURT
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`INDEX
`
`EVENTS
`Complaint
`Filed By: Plaintiff Zhang, Yanling
`[1] Complaint
`
`Lis Pendens
`Filed By: Plaintiff Zhang, Yanling
`[2] Lis Pendens Aztec
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`Lis Pendens
`[3] Lis Pendens 6137 Meadowsgrass Lane, LV NV 89103
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`Lis Pendens
`Filed By: Plaintiff Zhang, Yanling
`[4] Lis Pendens Valley
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`Lis Pendens
`Filed By: Plaintiff Zhang, Yanling
`[5] Lis Pendens Yankee
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`04/05/2021
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`Summons Electronically Issued - Service Pending
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`PAGE 1 OF 18
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`Printed on 04/21/2025 at 10:05 AM
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`

`

`EIGHTH JUDICIAL DISTRICT COURT
`CASE SUMMARY
`CASE NO. A-21-832316-C
`Party: Plaintiff Zhang, Yanling
`[6] Summons
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`Release of Lis Pendens
`Filed By: Plaintiff Zhang, Yanling
`[7] Release of Lis Pendens
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`Affidavit of Attempted Service
`Filed By: Plaintiff Zhang, Yanling
`[8] Affidavit of Attempts - Yanhui Zhang
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`Affidavit of Due Diligence
`Filed By: Plaintiff Zhang, Yanling
`[9] Declaration of Due Diligence
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`Application
`Filed By: Plaintiff Zhang, Yanling
`[10] Application for Publication
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`Ex Parte Application
`Party: Plaintiff Zhang, Yanling
`[11] Ex Parte Application for an Order Extending of Time for Service of Summons and
`Complaint (First Request)
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`Order
`Filed By: Plaintiff Zhang, Yanling
`[12] Order Enlarging Time for Service of Summons and Complaint
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`Order
`Filed By: Plaintiff Zhang, Yanling
`[13] Order for Service by Publication
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`05/13/2021
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`06/11/2021
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`06/11/2021
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`06/14/2021
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`07/16/2021
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`08/06/2021
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`08/11/2021
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`09/07/2021
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`Case Reassigned to Department 17
`From Judge Jacqueline Bluth to Judge Michael Villani
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`09/15/2021
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`09/23/2021
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`10/26/2021
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`12/22/2021
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`03/03/2022
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`Affidavit of Publication
`Filed By: Plaintiff Zhang, Yanling
`[14] Affidavit of Publication
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`Affidavit of Publication
`Filed By: Plaintiff Zhang, Yanling
`[15] Affidavit of Publication for Yanhui Zhang
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`Default
`Filed By: Plaintiff Zhang, Yanling
`[16] (5/6/22 Set Aside) Default
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`Notice of Entry of Default
`Party: Plaintiff Zhang, Yanling
`[17] Notice of Entry of Default
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`Application for Default Judgment
`Party: Plaintiff Zhang, Yanling
`[18] Application for Default Judgment
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`PAGE 2 OF 18
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`Printed on 04/21/2025 at 10:05 AM
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`

`

`EIGHTH JUDICIAL DISTRICT COURT
`CASE SUMMARY
`CASE NO. A-21-832316-C
`
`Application
`Filed By: Plaintiff Zhang, Yanling
`[19] Application for Attorney's Fees and Costs
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`Request
`Filed by: Plaintiff Zhang, Yanling
`[20] Request for Summary Disposition of Judgment
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`Motion to Set Aside Default Judgment
`Filed By: Defendant Zhang, Yanhui
`[21] Defendant's Motion to Set Aside Default Judgment
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`Initial Appearance Fee Disclosure
`Filed By: Defendant Zhang, Yanhui
`[22] Defendant's Initial Appearance Fee Disclosure
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`Clerk's Notice of Hearing
`[23] Notice of Hearing
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`Opposition to Motion
`Filed By: Plaintiff Zhang, Yanling
`[24] Plaintiff's Opposition to Motion to Set Aside Default
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`Ex Parte Application
`Party: Defendant Zhang, Yanhui
`[25] Ex Parte Application and Emergency Motion for Temporary Restraining Order and
`Preliminary Injunction
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`Clerk's Notice of Hearing
`[26] Notice of Hearing
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`Answer
`Filed By: Defendant Zhang, Yanhui
`[27] Answer to Plaintiff's Complaint
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`Ex Parte Application
`Party: Defendant Zhang, Yanhui
`[28] Amended Ex Parte Application and Emergency Motion for Temporary Restraining Order
`and Preliminary Injunction
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`Motion to Set Aside Default Judgment
`Filed By: Defendant Zhang, Yanhui
`[30] Defendant's Motion to Set Aside Default
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`Clerk's Notice of Hearing
`[31] Notice of Hearing
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`Order
`[32] ORDER STRIKING DOCUMENT IMPROPERLY FILED INTO CASE
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`Notice of Entry of Order
`Filed By: Defendant Zhang, Yanhui
`[33] Notice of Entry of Order Striking Improperly Filed Document
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`03/03/2022
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`03/03/2022
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`03/11/2022
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`03/11/2022
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`03/11/2022
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`03/24/2022
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`03/24/2022
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`03/24/2022
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`04/08/2022
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`04/12/2022
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`04/14/2022
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`04/15/2022
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`04/20/2022
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`04/20/2022
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`PAGE 3 OF 18
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`Printed on 04/21/2025 at 10:05 AM
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`

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`EIGHTH JUDICIAL DISTRICT COURT
`CASE SUMMARY
`CASE NO. A-21-832316-C
`
`04/22/2022
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`04/25/2022
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`05/06/2022
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`05/06/2022
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`06/28/2022
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`07/01/2022
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`Opposition to Motion
`Filed By: Plaintiff Zhang, Yanling
`[34] Plaintiff's Opposition to Motion to Set Aside Default
`
`Reply in Support
`Filed By: Defendant Zhang, Yanhui
`[35] Reply in Support of Defendants Motion to Set Aside Default Judgment
`
`Order
`Filed By: Defendant Zhang, Yanhui
`[36] Order Granting In Part/Denying In Part Defendant's Motion to Set Aside Default
`
`Notice of Entry
`Filed By: Defendant Zhang, Yanhui
`[37] NOTICE OF ENTRY OF ORDER GRANTING IN PART/DENYING IN PART
`DEFENDANTS MOTION TO SET ASIDE DEFAULT
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`Joint Case Conference Report
`Filed By: Plaintiff Zhang, Yanling
`[38] Joint Case Conference Report
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`Mandatory Rule 16 Conference Order
`[39] ORDER SCHEDULING MANDATORY CASE MANAGEMENT CONFERENCE
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`07/18/2022
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`Administrative Reassignment - Judicial Officer Change
`Cases Reassigned from Judge Michael Villani to Vacant, DC 17
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`07/27/2022
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`10/31/2022
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`11/01/2022
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`Scheduling and Trial Order
`[40] Scheduling Order and Order Setting Civil Bench Trial, Calendar Call and Pre-Trial
`Conference Scheduling Order
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`Receipt
`Party: Defendant Zhang, Yanhui
`[41] Receipt of Check
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`Satisfaction of Judgment
`Filed by: Plaintiff Zhang, Yanling
`[42] Satisfaction of Judgment
`
`01/03/2023
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`Case Reassigned to Department 11
`Pursuant to Administrative Order 22-14 - Reassigned to Judge Anna Albertson
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`01/04/2023
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`01/11/2023
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`01/27/2023
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`Motion
`Filed By: Plaintiff Zhang, Yanling
`[43] Plaintiff's Motion to Hold Rent in Trust Account
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`Clerk's Notice of Hearing
`[44] Notice of Hearing
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`Notice of Change of Hearing
`[45] Notice of Change of Hearings
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`01/27/2023
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`Opposition to Motion
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`PAGE 4 OF 18
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`Printed on 04/21/2025 at 10:05 AM
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`

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`EIGHTH JUDICIAL DISTRICT COURT
`CASE SUMMARY
`CASE NO. A-21-832316-C
`Filed By: Defendant Zhang, Yanhui
`[46] Defendant's Opposition to Plaintiff's Motion to Hold Rent in Trust Account
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`Reply
`Filed by: Plaintiff Zhang, Yanling
`[47] Plaintiff's Reply to Defendant's Opposition
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`Audiovisual Transmission Equipment Appearance Request
`Party: Defendant Zhang, Yanhui
`[48] Defendant's Audiovisual Transmission Equipment Appearance Request
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`Amended Scheduling Order
`[49] Amended Scheduling Order and Order Setting Civil Jury Trial
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`Notice of Change of Hearing
`Filed by: Plaintiff Zhang, Yanling
`[50] Notice of Change of Hearing
`
`Order
`[51] Order Denying Pltf's Motion to Hold Rents in Trust (07352823xA9B4D)
`
`Notice of Entry of Order
`Filed By: Defendant Zhang, Yanhui
`[52] Notice of Entry of Order Denying Plaintiff's Motion to Hold Rent in Trust Account
`
`Motion
`Filed By: Plaintiff Zhang, Yanling
`[53] Plaintiff's Motion for Order Shortening Time for Plaintiff's Motion to Extend Discovery
`Deadline
`
`Clerk's Notice of Hearing
`Party: Plaintiff Zhang, Yanling
`[54] Notice of Hearing
`
`Opposition and Countermotion
`Filed By: Defendant Zhang, Yanhui
`[55] Defendant's Opposition to Plaintiff's Motion to Extend Discovery Deadline on an Order
`Shortening Time and Defendant's Countermotion for Sanctions Pursuant to 16.1(E)(3)(b)
`
`Reply
`[56] Plaintiff's Reply to Defendant's Opposition to Motion to Exend Discovery Deadline on
`Order Shortening Time (Ost) and Plaintiff's Oppostion to Defendants' Countermotion for
`Sanctions
`
`Supplemental Brief
`[57] Plaintiff's Supplemental Reply to Defendant's Opposition to Plaintiff's Motion to Extend
`
`Audiovisual Transmission Equipment Appearance Request
`[58] Defendant's Notice of Intent to Appear by Simultaneous Audiovisual Equipment
`
`Reply in Support
`[59] DEFENDANT'S REPLY IN SUPPORT OF THE COUNTERMOTION FOR SANCTIONS
`PURSUANT TO 16.1(E)(3)(b)
`
`03/02/2023
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`03/06/2023
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`03/07/2023
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`05/18/2023
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`06/08/2023
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`06/09/2023
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`06/12/2023
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`06/14/2023
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`06/26/2023
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`07/03/2023
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`08/08/2023
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`08/14/2023
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`08/14/2023
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`PAGE 5 OF 18
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`Printed on 04/21/2025 at 10:05 AM
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`

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`08/15/2023
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`09/26/2023
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`10/02/2023
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`11/15/2023
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`11/16/2023
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`11/17/2023
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`12/12/2023
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`12/12/2023
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`12/14/2023
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`12/15/2023
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`12/23/2023
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`01/18/2024
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`01/18/2024
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`01/31/2024
`
`EIGHTH JUDICIAL DISTRICT COURT
`CASE SUMMARY
`CASE NO. A-21-832316-C
`
`Order
`[60] Order Granting Plaintiff's Motion To Extend Discovery Deadline And Denying
`Defendant's Countermotion For Sanctions
`
`Stipulation and Order
`[61] Stipulation and Order to Continue Status Hearing on September 28, 2023 at 11:00 A.M.
`
`Notice of Change of Hearing
`Filed by: Plaintiff Zhang, Yanling; Defendant Zhang, Yanhui
`[62] Notice of Change of Hearing
`
`Audiovisual Transmission Equipment Appearance Request
`Party: Defendant Zhang, Yanhui
`[63] Defendant's Audiovisual Transmission Equipment Appearance Request
`
`Audiovisual Transmission Equipment Appearance Request
`Party: Plaintiff Zhang, Yanling
`[64] Audiovisual Transmission Equipment Appearance Request
`
`Notice of Change of Hearing
`Filed By: Plaintiff Zhang, Yanling; Defendant Zhang, Yanhui
`[65] Notice of Change of Hearing
`
`Stipulation and Order to Extend Discovery Deadlines
`[66] Stipulation and Order to Extend Discovery Deadlines and Continue Trial
`
`Notice of Entry of Stipulation and Order
`Filed By: Defendant Zhang, Yanhui
`[67] Notice of Entry of Stipulation and Order to Extend Discovery Deadlines and Continue
`Trial
`
`Audiovisual Transmission Equipment Appearance Request
`Party: Plaintiff Zhang, Yanling
`[68] Audiovisual Transmission Equipment Appearance Request 2
`
`Audiovisual Transmission Equipment Appearance Request
`Party: Defendant Zhang, Yanhui
`[69] Defendant's Audiovisual Transmission Equipment Appearance Request
`
`Scheduling and Trial Order
`[70] Amended Scheduling Order and Trial Setting
`
`Motion to Withdraw As Counsel
`[71] Motion to Withdraw on OST
`
`Notice of Entry of Order
`Filed By: Defendant Zhang, Yanhui
`[72] Notice of Entry of Order Shortening Time re: Messner Reeves LLP's Motion to Withdraw
`as Counsel for Defendant Yanhui Zhang
`
`Order Granting Motion
`Filed By: Defendant Zhang, Yanhui
`[73] Order Granting Messner Reeves LLP's Motion to Withdraw as Counsel for Defendant
`Yanhui Zhang on Order Shortening Time
`
`PAGE 6 OF 18
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`Printed on 04/21/2025 at 10:05 AM
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`

`

`EIGHTH JUDICIAL DISTRICT COURT
`CASE SUMMARY
`CASE NO. A-21-832316-C
`
`Notice of Entry of Order
`Filed By: Defendant Zhang, Yanhui
`[74] Notice of Entry of Order Granting Messner Reeves LLP's Motion to Withdraw as Counsel
`for Defendant Yanhui Zhang on Order Shortening Time
`
`Subpoena Duces Tecum
`Filed by: Plaintiff Zhang, Yanling
`[75] Notice of Intent to Subpoena_Ticor
`
`Subpoena Duces Tecum
`Filed by: Plaintiff Zhang, Yanling
`[76] Notice of Intent to Subpoena_Lawyers
`
`Notice of Appearance
`Party: Defendant Zhang, Yanhui
`[77] Notice of Appearance
`
`Demand for Prior Discovery
`Filed By: Defendant Zhang, Yanhui
`[78] Defendant's Demand for Prior Discovery
`
`Subpoena Duces Tecum
`Filed by: Plaintiff Zhang, Yanling
`[79] Notice of Intent to Subpoena_Fidelity
`
`Subpoena Duces Tecum
`Filed by: Plaintiff Zhang, Yanling
`[80] Notice of Intent to Subpoena_Lawyers
`
`Notice of Intent
`Filed By: Plaintiff Zhang, Yanling
`[81] Notice of Intent to Subpoena
`
`Amended
`Filed By: Plaintiff Zhang, Yanling
`[82] Amended Notice of Intent to Subpoena
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`Stipulation and Order
`[83] Stipulation and Order to Extend Discovery and Contiue Trial Pursuant to E.D.C.R. 2.35
`(Third Request)
`
`Audiovisual Transmission Equipment Appearance Request
`Party: Plaintiff Zhang, Yanling
`[84] Audiovisual Transmission Equipment Appearance Request 3
`
`Audiovisual Transmission Equipment Appearance Request
`Party: Defendant Zhang, Yanhui
`[85] Notice of Intent to Appear by Simultaneous Audiovisual Transmission Equipment
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`Scheduling and Trial Order
`[86] Amended Scheduling Order and Trial Setting
`
`02/01/2024
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`02/16/2024
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`02/16/2024
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`03/01/2024
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`03/06/2024
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`03/22/2024
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`03/22/2024
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`05/21/2024
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`05/22/2024
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`05/27/2024
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`05/31/2024
`
`06/03/2024
`
`06/05/2024
`
`07/15/2024
`
`Stipulation and Order
`
`PAGE 7 OF 18
`
`Printed on 04/21/2025 at 10:05 AM
`
`

`

`EIGHTH JUDICIAL DISTRICT COURT
`CASE SUMMARY
`CASE NO. A-21-832316-C
`[87] Stipulation and Order to Extend Discovery Until July 30, 2024 (Fourth Request)
`
`Scheduling and Trial Order
`[88] Amended Scheduling Order and Trial Setting
`
`Notice of Taking Deposition
`Filed By: Plaintiff Zhang, Yanling
`[89] Notice of Taking Deposition of Ban Fei
`
`Stipulation and Order
`[90] Stipulation and Order to Extend Discovery Until August 29, 2024 (Fifth Request)
`
`Motion to Extend Discovery
`Filed By: Plaintiff Zhang, Yanling
`[91] Plaintiff's Motion to Reopen Discovery for a Limited Period for Expert to Submit a
`Supplemental Report Re the Deposition Testimony of Ban Fei on Order Shortening Time
`(OST)
`
`Audiovisual Transmission Equipment Appearance Request
`Party: Defendant Zhang, Yanhui
`[92] Notice of Intent to Appear by Simultaneous Audiovisual Transmission Equipment
`
`Audiovisual Transmission Equipment Appearance Request
`Party: Plaintiff Zhang, Yanling
`[93] Audiovisual Transmission Equipment Appearance Request 4
`
`Opposition to Motion
`Filed By: Defendant Zhang, Yanhui
`[94] Oppositon to Plaintiff's Moiton to Reopen Discovery
`
`Reply to Opposition
`Filed by: Plaintiff Zhang, Yanling
`[95] Plaintiff's Reply to Defendant's Opposition to Motion to Reopen Discovery
`
`Supplemental Brief
`[96] Plaintiff's Supplemental Reply Brief to Defendant's Opposition to Plaintiff's Motion to
`Reopen Discovery for a Limited Period
`
`Audiovisual Transmission Equipment Appearance Request
`Party: Plaintiff Zhang, Yanling
`[97] Audiovisual Transmission Equipment Appearance Request 5
`
`Motion for Summary Judgment
`Filed By: Defendant Zhang, Yanhui
`[98] Defendant's Motion for Summary Judgment
`
`Clerk's Notice of Hearing
`[99] Clerk's Notice of Hearing
`
`Declaration
`Filed By: Defendant Zhang, Yanhui
`[100] Verification and Declaration in Support of Defendant's Motion for Summary Judgment
`
`07/24/2024
`
`08/08/2024
`
`08/13/2024
`
`09/09/2024
`
`09/10/2024
`
`09/10/2024
`
`09/10/2024
`
`09/12/2024
`
`09/18/2024
`
`10/07/2024
`
`10/23/2024
`
`10/23/2024
`
`10/25/2024
`
`11/06/2024
`
`Opposition to Motion For Summary Judgment
`
`PAGE 8 OF 18
`
`Printed on 04/21/2025 at 10:05 AM
`
`

`

`EIGHTH JUDICIAL DISTRICT COURT
`CASE SUMMARY
`CASE NO. A-21-832316-C
`Filed By: Plaintiff Zhang, Yanling
`[101] Plaintiff's Opposition to Defendant's Motion For Summary Judgment
`
`Reply in Support
`Filed By: Defendant Zhang, Yanhui
`[102] Defendant's Reply in Support to Motion for Summary Judgment
`
`Audiovisual Transmission Equipment Appearance Request
`Party: Plaintiff Zhang, Yanling
`[103] Audiovisual Transmission Equipment Appearance Request 6
`
`Notice of Change of Hearing
`[104] Notice of Change of Hearing
`
`Stipulation and Order
`[105] Stipulation and Order to Continue Non-Jury Trial Date
`
`Scheduling and Trial Order
`[106] Amended Scheduling Order and Trial Setting
`
`Order
`[107] Proposed Order Granting In Part and Denying In Part Defendant's Motion for
`Summary Judgment
`
`Notice of Entry of Order
`Filed By: Defendant Zhang, Yanhui
`[108] Notice of Entry of Order
`
`Order
`[109] Order
`
`Mandatory Pretrial Disclosure
`Party: Defendant Zhang, Yanhui
`[110] Pretrial Disclosures
`
`Motion in Limine
`Filed By: Defendant Zhang, Yanhui
`[111] Defendant's Motion in Limine I- Motion to Preclude Introduction of Evidence or
`Argument for Special Damages
`
`Motion in Limine to Exclude Expert Witness
`Filed by: Defendant Zhang, Yanhui
`[112] Defendant's Motion in Limine II- Motion to Preclude Introduction of Michelle Chen as
`Expert Witness
`
`Motion in Limine
`Filed By: Defendant Zhang, Yanhui
`[113] Defendant's Motion in Limine III- Motion to Preclude introduction of Unpled Causes of
`Action
`
`11/26/2024
`
`12/02/2024
`
`12/02/2024
`
`12/16/2024
`
`12/16/2024
`
`12/17/2024
`
`12/20/2024
`
`01/02/2025
`
`01/13/2025
`
`01/24/2025
`
`01/24/2025
`
`01/24/2025
`
`01/24/2025
`
`Clerk's Notice of Hearing
`[114] Notice of Hearing
`
`02/10/2025
`
`Opposition
`
`PAGE 9 OF 18
`
`Printed on 04/21/2025 at 10:05 AM
`
`

`

`EIGHTH JUDICIAL DISTRICT COURT
`CASE SUMMARY
`CASE NO. A-21-832316-C
`Filed By: Plaintiff Zhang, Yanling
`[115] Plaintiff's Opposition to DEFENDANTS MOTION IN LIMINE I MOTION TO
`PRECLUDE INTROUDCTION OF EVIDENCE OR ARGUMENT FOR SPECIAL DAMAGES.
`
`Opposition
`Filed By: Plaintiff Zhang, Yanling
`[116] PLAINTIFFS OPPOSITION TO DEFENDANTS MOTION IN LIMINE II MOTION TO
`PRECLUDE INTROUDCTION OF MICHELLE CHEN AS AN EXPERT WITNESS
`
`Opposition
`Filed By: Plaintiff Zhang, Yanling
`[117] Plaintiff's Opposition to Defendant's MOTION TO PRECLUDE INTROUDCTION OF
`UNPLED CAUSES OF ACTION
`
`Reply in Support
`Filed By: Defendant Zhang, Yanhui
`[118] Defendant's Reply in Support to Motion in Limine I - Motion to Preclude Introduction of
`Evidence or Argument for Special Damages
`
`Reply in Support
`Filed By: Defendant Zhang, Yanhui
`[119] Defendant's Reply in Support to Motion in Limine II - Motion to Preclude Introduction
`of Michelle Chen as an Expert Witness
`
`Reply in Support
`Filed By: Defendant Zhang, Yanhui
`[120] Defendant's Reply in Support to Motion in Limine III - Motion to Preclude Introduction
`of Unpled Caused of Action
`
`Scheduling and Trial Order
`[121] Amended Scheduling Order and Order Setting Civil Bench Trial
`
`Notice of Change of Address
`Filed By: Defendant Zhang, Yanhui
`[122] Notice of Change of Address
`
`Audiovisual Transmission Equipment Appearance Request
`Party: Plaintiff Zhang, Yanling
`[123] Audiovisual Transmission Equipment Appearance Request 7
`
`Mandatory Pretrial Disclosure
`Party: Plaintiff Zhang, Yanling
`[124] Plaintiff's Pretrial Memorandum
`
`Status Report
`Filed By: Defendant Zhang, Yanhui
`[125] Defendant's Status Report
`
`Objection
`Filed By: Defendant Zhang, Yanhui
`[126] Defendant's Objections to Pretrial Disclosures
`
`Supplement
`Filed by: Plaintiff Zhang, Yanling
`[127] PLAINTIFFS SUPPLEMENT TO OPPOSITION TO DEFENDANTS MOTION IN
`
`PAGE 10 OF 18
`
`Printed on 04/21/2025 at 10:05 AM
`
`02/10/2025
`
`02/11/2025
`
`02/20/2025
`
`02/20/2025
`
`02/20/2025
`
`02/21/2025
`
`02/24/2025
`
`02/24/2025
`
`02/28/2025
`
`03/10/2025
`
`03/11/2025
`
`03/11/2025
`
`

`

`EIGHTH JUDICIAL DISTRICT COURT
`CASE SUMMARY
`CASE NO. A-21-832316-C
`LIMINE I MOTION TO PRECLUDE INTRODUCTION OF EVIDENCE OR ARGUMENT
`FOR SPECIAL DAMAGES
`
`Clerk's Notice of Hearing
`[128] Notice of Hearing
`
`Supplement
`Filed by: Plaintiff Zhang, Yanling
`[129] Supplement to 16.1 Computation of Damages by Plaintiff's Expert
`
`Response
`Filed by: Defendant Zhang, Yanhui
`[130] Response to Plaintiffs Supplement to NRCP 16.1 Disclosures and Plaintiffs Computation
`of Damages by Expert Witness Michelle Chen, CPA
`
`Order
`[131] Order Regaridng Motions In Limine
`
`Notice of Entry of Order
`Filed By: Plaintiff Zhang, Yanling; Defendant Zhang, Yanhui
`[132] Notice of Entry of Order
`
`Joint Pre-Trial Memorandum
`Filed By: Defendant Zhang, Yanhui
`[133] Defendant's Pretrial Memorandum and Statement of Remaining Issues for Trial
`
`Order to Statistically Close Case
`[134] Order Statistically Closing Case
`
`Notice of Attorney Lien
`Filed By: Defendant Zhang, Yanhui
`[135] Notice of Attorney Lien
`
`Certificate of Mailing
`Filed By: Defendant Zhang, Yanhui
`[136] Certificate of mailing
`
`Notice of Appeal
`Filed By: Plaintiff Zhang, Yanling
`[137] Notice of Appeal_Motion in Limine
`
`Notice of Appeal
`Filed By: Plaintiff Zhang, Yanling
`[138] Notice of Appeal_Dismissal
`DISPOSITIONS
`Order (Judicial Officer: Villani, Michael)
`Debtors: Yanling Zhang (Plaintiff)
`Creditors: Yanhui Zhang (Defendant)
`Judgment: 05/06/2022, Docketed: 05/09/2022
`Total Judgment: 3,930.50
`
`03/11/2025
`
`03/14/2025
`
`03/14/2025
`
`03/24/2025
`
`03/25/2025
`
`03/26/2025
`
`04/15/2025
`
`04/17/2025
`
`04/17/2025
`
`04/18/2025
`
`04/18/2025
`
`05/06/2022
`
`04/14/2022
`
`HEARINGS
`Motion to Set Aside Default Judgment (3:00 AM) (Judicial Officer: Villani, Michael)
`
`PAGE 11 OF 18
`
`Printed on 04/21/2025 at 10:05 AM
`
`

`

`EIGHTH JUDICIAL DISTRICT COURT
`CASE SUMMARY
`CASE NO. A-21-832316-C
`Defendant's Motion to Set Aside Default Judgment
`Vacate;
`Journal Entry Details:
`Motion to Set Aside Default Judgment is set to come before this Court on the April 14, 2022
`(Chambers) Calendar. COURT NOTES, a Default Judgment has not been entered in this case.
`COURT FURTHER NOTES, Motion to Set Aside Default was filed April 14, 2022 and is set to
`be heard on April 26, 2022 at 9:00 A.M. COURT ORDERED, matter VACATED. CLERK'S
`NOTE: This Minute Order was electronically served to all registered parties for Odyssey File
`& Serve/ SA 4/20/2022;
`
`Motion (9:00 AM) (Judicial Officer: Villani, Michael)
`Defendant's Ex Parte Application and Emergency Motion for Temporary Restraining Order
`and Preliminary Injunction
`MINUTES
`Granted;
`SCHEDULED HEARINGS
`All Pending Motions (04/26/2022 at 9:00 AM) (Judicial Officer: Villani, Michael)
`
`Motion to Set Aside (9:00 AM) (Judicial Officer: Villani, Michael)
`Defendant's Motion to Set Aside Default
`Granted in Part;
`
`All Pending Motions (9:00 AM) (Judicial Officer: Villani, Michael)
`Matter Heard;
`Journal Entry Details:
`DEFT'S. MOTION TO SET ASIDE DEFAULT....DEFT'S. EX-PARTE APPLICATION AND
`EMERGENCY MOTION FOR TEMPORARY RESTRAINING ORDER AND PRELIMINARY
`INJUNCTION Ms. Jilliane Jackson, Esq. present on behalf of Deft. DEFT'S. MOTION TO SET
`ASIDE DEFAULT Extensive arguments regarding Deft's. current residency in China and their
`inability to return, service on Deft., the families knowledge of Deft's. whereabouts, and the
`family members not speaking to each other due to a family feud. Additional arguments
`regarding Pltf's. request for attorney's fees and costs associated with the attempts at service
`and the timing of the retention of Deft's. counsel. COURT ORDERED, Motion to Set Aside
`Default, GRANTED, and STATED FINDINGS. Pltf's. counsel is to prepare a request for Fees
`and Costs from 01.26.21 through 08.14.21. The Answer STANDS. Ms. Jackson is to prepare
`the Order Setting Aside the Default and Imposition of Sanctions. DEFT'S. EX-PARTE
`APPLICATION AND EMERGENCY MOTION FOR TEMPORARY RESTRAINING ORDER
`AND PRELIMINARY INJUNCTION At the request of counsel, COURT RESET the Ex-Parte
`Application and Emergency Motion for Temporary Restraining Order and Preliminary
`Injunction, SET on the Chambers calendar on 04.28.22; to be heard today. COURT
`FURTHER ORDERED, Motion GRANTED, based upon the Setting Aside of the Default. Both
`sides are PRECLUDED from encumbering the property or taking any action to affect the other
`parties interest in the property. Ms. Jackson is to include that in the Order, provide a copy to
`Mr. Akin to review as to form and content, and return it back to the Court within 10 days. ;
`
`Minute Order (3:00 AM) (Judicial Officer: Villani, Michael)
`Vacate;
`Journal Entry Details:
`Defendant s Ex Parte Application and Emergency Motion for Temporary Restraining Order
`and Preliminary Injunction set to come before the Court on the April 28, 2022 (Chambers)
`Calendar. COURT NOTES, an Order was entered on April 26, 2022 preventing any further
`encumbrances on the properties at issue. As a result, the instant matter is now moot and
`therefore, COURT ORDERED, matter VACATED. CLERK'S NOTE: This Minute Order was
`electronically served to all registered parties for Odyssey File & Serve/ OG (04/29/22);
`
`Mandatory Rule 16 Conference (8:30 AM) (Judicial Officer: Ellsworth, Carolyn)
`MINUTES
`Scheduling Order Will Issue;
`Journal Entry Details:
`Upon Court's inquiry, counsel indicated there were no outstanding issues. Upon Court's
`
`04/26/2022
`
`04/26/2022
`
`04/26/2022
`
`04/28/2022
`
`07/26/2022
`
`PAGE 12 OF 18
`
`Printed on 04/21/2025 at 10:05 AM
`
`

`

`EIGHTH JUDICIAL DISTRICT COURT
`CASE SUMMARY
`CASE NO. A-21-832316-C
`inquiry, Mr. Remitio advised they would file their 16.1 disclosures before the end of the week
`and Ms. Jackson confirmed they had already filed theirs. Court noted this was a bench trial
`and counsel estimated 5 full days for trial. Upon Court's inquiry, Ms. Jackson confirmed their
`clients were in China and these dates would allow them more time to prepare for trial. Court
`ADOPTED the discovery deadlines in the Joint Case Conference Report and ORDERED, trial
`SET; scheduling order to issue. 11/7/2023 9:00 AM STATUS CHECK: TRIAL READINESS
`12/12/2023 9:00 AM CALENDAR CALL 1/2/2024 10:30 AM BENCH TRIAL;
`SCHEDULED HEARINGS
`Status Check: Trial Readiness (12/21/2023 at 1:00 PM) (Judicial Officer: Albertson,
`Anna)
`CANCELED Calendar Call (01/18/2024 at 9:30 AM) (Judicial Officer: Vacant, DC 17)
`Vacated
`CANCELED Bench Trial (02/05/2024 at 9:30 AM) (Judicial Officer: Albertson, Anna)
`Vacated - per Stipulation and Order
`
`Motion (9:30 AM) (Judicial Officer: Albertson, Anna)
`Plaintiff's Motion to Hold Rent in Trust Account
`Denied;
`Journal Entry Details:
`Arguments by Mr. Remitio regarding the merits of and by Mr. Martinez in opposition to the
`motion. Court stated that it's ruling today is not in any way a statement on the ownership of the
`properties, that issue is not before the Court today. COURT ORDERED, Plaintiff's Motion to
`Hold Rent in Trust Account DENIED. Court stated that holding money in Trust may impact the
`expenses and maintenance of the subject properties and no agreement for what the status quo
`was before filing of the Complaint. Mr. Martinez to prepare the order, circulate to counsel,
`and submit to the Department 11 inbox.;
`
`Motion for Order (9:30 AM) (Judicial Officer: Albertson, Anna)
`Events: 06/12/2023 Motion
`Plaintiff's Motion for Order Shortening Time for Plaintiff's Motion to Extend Discovery
`Deadline
`Granted;
`
`Opposition and Countermotion (9:30 AM) (Judicial Officer: Albertson, Anna)
`Defendant's Opposition to Plaintiff's Motion to Extend Discovery Deadline on an Order
`Shortening Time and Defendant's Countermotion for Sanctions Pursuant to 16.1(E)(3)(b)
`Denied;
`
`All Pending Motions (9:30 AM) (Judicial Officer: Albertson, Anna)
`Matter Heard;
`Journal Entry Details:
`PLAINTIFF'S MOTION FOR ORDER SHORTENING TIME FOR PLAINTIFF'S MOTION TO
`EXTEND DISCOVERY DEADLINE DEFENDANT'S OPPOSITION TO PLAINTIFF'S
`MOTION TO EXTEND DISCOVERY DEADLINE ON AN ORDER SHORTENING TIME AND
`DEFENDANT'S COUNTERMOTION FOR SANCTIONS PURSUANT TO 16.1(E)(3)(B) Mr.
`Remitio stated the documents he is requesting to review in the extended discovery are crucial
`to make a fair and full representation of his case; further stating the non disclosure of these
`documents were not intended to be made in bad faith by the Plaintiff. Upon Court's inquiry
`regarding the language the notes are in, Mr. Remitio advised the notes are in Mandarin and
`they have not been translated by a certified court translator yet; further stating the translation
`was done by an employee in his office due to time restraint prior to close of discovery. Mr.
`Martinez stated the documents were known prior to the deposition that were not disclosed,
`further stating NRCP 16.1 requires Plaintiff to reasonably comply with production in
`discovery. COURT stated Its FINDINGS and ORDERED, Plaintiff's Motion for Order
`Shortening Time for Plaintiff's Motion to Extend Discovery Deadline, GRANTED. COURT
`FURTHER ORDERED, Defendant's Opposition to Plaintiff's Motion to Extend Discovery
`Deadline on an Order Shortening Time and

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