Sanchez v. Windhaven National Insurance Company

1 ROBERT E. SCHUMACHER, ESQ.

Nevada Bar No. 7504 WING YAN WONG, ESQ.

Nevada Bar No. 13622 GORDON REES SCULLY MANSUKHANI, LLP 300 South 4th Street, Suite 1550 Las Vegas, Nevada 89101 Telephone: (702) 577-9300 Direct Line: (702) 577-9319 Facsimile: (702) 255-2858 E-Mail: [email protected] [email protected] Attorneys for Defendant/Cross-Defendant DMA CLAIMS MANAGEMENT, INC., erroneously sued as DMA CLAIMS INC. UNITED STATES DISTRICT COURT DISTRICT OF NEVADA DIANE SANCHEZ, ) CASE NO.: 2:19-cv-02196-RFB-VCF 13 ) Plaintiff, ) 14 vs. ) STIPULATION AND ORDER TO ) EXTEND TIME FOR DMA WINDHAVEN NATIONAL INSURANCE ) CLAIMS MANAGEMENT, INC. COMPANY, a domestic corporation; ) TO FILE REPLY BRIEFS (ECF WINDHAVEN NATIONAL INSURANCE ) NOS. 33, 34) COMPANY fka ATX PREMIER INSURANCE, a ) domestic corporation; DMA CLAIMS INC., a ) FIRST REQUEST foreign corporation; BLAS BON, an individual; ) DOES I-X and ROE CORPORATIONS I-X, ) inclusive, ) 20 ) Defendants. ) 21 ) WINDHAVEN NATIONAL INSURANCE ) COMPANY, a foreign corporation, ) ) Cross-Claimant, ) 24 vs. ) ) DMA CLAIMS SERVICES, INC., a foreign ) corporation; DOES I-X, inclusive, and ROE ) CORPORATIONS I-X, inclusive, ) ) Cross-Defendant. ) 1 Pursuant to Local Rule IA 6-1 and LR 7-1, Plaintiff Diane Sanchez (“Sanchez”) and Defendant DMA Claims Management, Inc. (“DMA”), by and through their respective counsel of record, hereby stipulate that the deadlines for DMA to files its Reply briefs to Sanchez’s Response to DMA’s Motion to Dismiss, ECF No. 33, and Sanchez’s Response to DMA’s Motion to Stay, ECF No. 34, are hereby extended for two (2) weeks to Friday, May 29, 2020.

6 This is the first stipulation for extension of time to allow DMA to file its Reply briefs.

7 On April 2, 2020, DMA filed its Motion to Dismiss First Amended Complaint. ECF No. 27. On April 22, 2020, DMA filed its Motion to Stay Pursuant to Injunction or Alternatively, Motion to Stay Discovery. ECF No. 30. On May 8, 2020, Sanchez filed her Response briefs to both Motions. ECF No. 33, 34. DMA’s Reply briefs are currently due on May 15, 2020.

11 This extension of time is to allow DMA additional time to review and evaluate Sanchez’s position in her Response briefs. This request is not made for any improper purposes or to cause any unnecessary delay.

14 /// /// /// /// /// /// /// /// /// /// /// /// /// /// 1 While Sanchez and DMA may dispute whether the stay triggered by defendant || Windhaven National Insurance Company’s (““Windhaven”) liquidation proceeding applies as to || DMA, Sanchez and DMA do not dispute that this action is currently stayed as to Windhaven and || defendant Blas Bon. See ECF No. 25, Notice of Automatic Stay Proceeding. Thus, these || defendants are not parties to this Stipulation.

6 || DATED this 14 day of May, 2020 DATED this 14" day of May, 2020 || GORDON REES SCULLY PRINCE LAW GROUP MANSUKHANI, LLP || Robert E. Schumacher /s/ Kevin T. Strong ROBERT E. SCHUMACHER, ESQ. DENNIS M. PRINCE, Esq.

10 || Nevada Bar No. 7504 Nevada Bar No. 5092 WING YAN WONG, ESQ. KEVIN T. STRONG, Esq.

11 |} Nevada Bar No. 13622 Nevada Bar No. 12107 300 South 4" Street, Suite 1550 10801 W. Charleston Boulevard, Suite560 12 Las Vegas, Nevada 89101 Las Vegas, Nevada 89135 = Attorneys for Defendant, Attorneys for Plaintiff, £5 13 || DMA CLAIMS MANAGEMENT, INC., DIANE SANCHEZ > erroneously sued as DMA CLAIMS INC. (14 gt ORDER IT IS SO ORDERED: 19 aAS- 0 RICHARD F. WARE, II UNITED STATES DISTRICT JUDGE DATED this 15th day of May, 2020. -3-