Kido v. Independent American Insurance Compoany

ROBERT S. LARSEN, ESQ.

Nevada Bar No. 7785 DIONE C. WRENN, ESQ.

Nevada Bar No. 13285 GORDON REES SCULLY MANSUKHANI, LLP So. 4th Street, Suite 1550 Las Vegas, Nevada 89101 Telephone: (702) 577-9300 Direct: (702) 577-9301 Facsimile: (702) 255-2858 E-Mail: [email protected] [email protected] Attorneys for Defendants Independence American Insurance Company; Independence Holding Company; IHC Specialty Benefits, Inc.; and The Loomis Company

UNITED STATES DISTRICT COURT DISTRICT OF NEVADA

Joel David Kido, Case No.: 2:21-cv-00678-APG-BNW Plaintiff, STIPULATION AND ORDER TO vs. EXTEND TIME TO FILE REPLY IN SUPPORT OF MOTION TO DISMISS Independence American Insurance Company, a Delaware corporation; Independence (First Request) Holding Company, a Delaware corporation; IHC Specialty Benefits, Inc., a Delaware corporation; The Loomis Company, a Delaware corporation; Elixir Savings, LLC, fka Envision Medical Solutions, LLC, dba, EnvisionSavings; and United Services Automobile Association; and Does 2 through 20, inclusive, Defendants.

Pursuant to Local Rule 7-1, Defendants Independence American Insurance Company (“IAIC”), Independence Holding Company (“IHC”), IHC Specialty Benefits (“IHC SB”), and The Loomis Company (“Loomis”) (collectively, “Insurance Defendants”), by and through their attorneys, Robert S. Larsen, Esq. and Dione C. Wrenn, Esq. of Gordon Rees Scully Mansukhani, Whitehead, Esq. of Whitehead & Whitehead, Ltd., hereby stipulate and agree as follows: 1. Plaintiff filed his Amended Complaint in the District Court for Clark County, Nevada on March 17, 2021.

2. Defendants IAIC and Loomis removed the case to this Court on April 23, 2021.

3. Insurance Defendants filed a Motion to Dismiss the Amended Complaint on April 30, 2021.

4. Plaintiff filed a Response to the Insurance Defendants’ Motion to Dismiss on May 14, 2021.

5. The current deadline for the Insurance Defendants to reply to Plaintiff’s Response is May 21, 2021.

6. Insurance Defendants requested additional time to file their Reply up to and including May 25, 2021.

7. Plaintiff does not oppose Insurance Defendants’ requested extension.

8. Accordingly Insurance Defendants will file their Reply in support of their Motion to Dismiss on May 25, 2021.

9. This stipulation is not made for the purposes of delay.

IT IS SO STIPULATED.

DATED this 21st day of May 2021. DATED this 21st day of May 2021.

GORDON REES SCULLY WHITEHEAD & WHITEHEAD, LTD. MANSUKHANI Dione C. Wrenn /s/ Jonathan Whitehead ROBERT S. LARSEN, ESQ. JONATHAN WHITEHEAD, ESQ. © || Nevada Bar No. 7785 Nevada Bar No. 4415 Nevada Bar No. 13285 Reno, Nevada 89521 evaca a 0. . Attorney for Plaintiff, 300 South 4" Street, Suite 1550 Joel David Kido Las Vegas, Nevada 89101 Attorneys for Defendants Independence American Insurance Company; Independence Holding Company; IHC Specialty Benefits, Inc.; and The Loomis Company

IT IS SO ORDERED.

4% 16 so 17 |, UNITED STATES DISTRICT JUDGE DATED: May 21, 2021