Kinsale Insurance Company v. United States District

1 MATTHEW J. HAFEY (admitted Pro Hac Vice) [email protected] TIMOTHY P. KITT (SBN: 11828) [email protected] KHRYS WU (admitted Pro Hac Vice) [email protected] NICOLAIDES FINK THORPE MICHAELIDES SULLIVAN LLP 777 South Figueroa Street, Suite 750 Los Angeles, CA 90017 Telephone: (213) 402-1245 Facsimile: (213) 402-1246 Jeffrey W. Saab (Nevada SBN: 11261) [email protected] BREMER, WHYTE, BROWN & O’MEARA, LLP 1160 N. Town Center Drive, Suite 250 Las Vegas, Nevada 89144 Telephone: (702) 258-6665 Facsimile: (702) 258-6662 Designated solely for personal service pursuant to Nev. SCR 42.1 Attorneys for Plaintiff KINSALE INSURANCE COMPANY 16 UNITED STATES DISTRICT COURT 17 DISTRICT OF NEVADA KINSALE INSURANCE COMPANY, an Case No. 2:24-cv-00997-RFB-DJA Arkansas corporation, 19 STIPULATION AND ORDER Plaintiff, DISMISSING ENTIRE ACTION WITH 20 PREJUDICE, RESERVING v. JURISDICTION TO ENFORCE SETTLEMENT SVS SECURITY LLC, a Nevada limited liability company; HENRY WILLIS WEBB, Complaint filed: May 28, 2024 JR., an individual; MEISHA LARITA Trial Date: Not set WEBB, an individual and Special Administrator of the Estate of Breeana Larita Webb (Deceased), 26 Defendants.

1 WHEREAS plaintiff Kinsale Insurance Company (“Kinsale”) and Defendants SVS Security LLC (“SVS”); Henry Willis Webb, Jr. (“H. Webb”) and Meisha Larita Webb (“M. Webb”) (collectively the “Parties”) have resolved their differences to the satisfaction of the Parties as memorialized in a Confidential Settlement Agreement dated December 10, 2025 (the “Settlement Agreement”); and 6 WHEREAS the settlement fully resolves the within action, including the operative First Amended Complaint, with the parties each to bear its / their own attorney’s fees and costs, save and except to enforce the Settlement Agreement; and 9 WHEREAS due to the confidential nature of the settlement the Parties shall maintain copies of the fully executed Settlement Agreement outside the Court file, but request that the terms of the Settlement Agreement be deemed incorporated by this reference into this Stipulation and Proposed Order as fully set forth therein verbatim, so as to eliminate the need to file a copy of the Settlement Agreement under seal; and 14 WHEREAS the Parties have agreed the Court may reserve jurisdiction to enforce the Settlement Agreement pursuant to its inherent power as recognized in Kokkonen v. Guardian Life Ins. Co. of Am., 511 U.S. 375, 378-81 (1994); see also In re City Equities Anaheim, Ltd., 22 F.3d 954, 957 (9th Cir. 1994) (district court has the inherent power “to summarily enforce on motion a settlement agreement entered into by the litigants while the litigation is pending before it”); Monroy v. Wal-Mart Inc., No. 2:22-CV-01638-RFB-NJK, 2024 WL 4441831, at *1 (D. Nev. Sept. 29, 2024) (citing In re City Equities); 22 IT IS HEREBY STIPULATED AND AGREED by the Parties through their attorneys of record that this entire action, including the Complaint (Dkt. 1) and the First Amended Complaint (Dkt. 17) be dismissed with prejudice pursuant to Fed.R.Civ.P. 41(a)(2).

26 IT IS ALSO STIPULATED AND AGREED that the Court shall reserve jurisdiction to enforce the Settlement Agreement pursuant to its inherent power as ||and In re City Equities Anaheim, Ltd., 22 F.3d 954, 957 (9th Cir. 1994); Monroy v. Wal- || Mart Inc., No. 2:22-CV-01638-RFB-NJK, 2024 WL 4441831, at *1 (D. Nev. Sept. 29, ||2024). Each of the parties is to bear its own attorney's fees and costs save and except ||to enforce the Settlement Agreement.

6 ||Dated: January 6, 2026 NICOLAIDES FINK THORPE 7 MICHAELIDES SULLIVAN LLP By: fle.

9 Matthew J. Aafey Khrys Wu 10 Attorneys for Plaintiff KINSALE INSURANCE COMPANY 12 Dated: December 15, 2025 REISMAN SOROKAC /s/ Jody W. Hagins By 15 Joshua Reisman 16 Jody W. Hagins Attorneys for Defendant SVS Security LLC Dated: December 18, 2025 CHRISTIANSEN TRIAL ATTORNEYS /s/ R. Todd Terry By 20 R. Todd Terry 21 Attorneys for Defendants Henry Willis Webb, Jr. and Meisha Larita Webb 1 Attestation re Electronic Signatures 2 |, Matthew J. Hafey, declare under penalty of perjury that | have received ||permission to attach electronic signatures of Jody W. Hagins, Esq. and R. Todd Terry, 4 in the form of /s/ [Name] pursuant to LR IC 5-1(d).

Neh, Dated: January 6, 2026 Matthew J. Hafey 10 UNITED STATES DISTRICT COURT 11 DISTRICT OF NEVADA KINSALE INSURANCE COMPANY, an Case No. 2:24-cv-00997-RFB-DJA Arkansas corporation, 13 ORDER DISMISSING ENTIRE Plaintiff, ACTION WITH PREJUDICE, 14 RESERVING JURISDICTION TO v. ENFORCE SETTLEMENT SVS SECURITY LLC, a Nevada limited Complaint filed: May 28, 2024 liability company; HENRY WILLIS WEBB, Trial Date: Not set JR., an individual; MEISHA LARITA WEBB, an individual and Special Administrator of the Estate of Breeana Larita Webb (Deceased), 20 Defendants.

1 Having considered the stipulation of counsel and GOOD CAUSE APPEARING || THEREFOR, IT IS HEREBY ORDERED as follows: 1. This entire action, including the Complaint (Dkt. 1) and the First Amended Complaint (Dkt. 17) is hereby dismissed with prejudice pursuant to Fed.R.Civ.P. ° 41(a)(2), save and except that ° 2. The Court shall reserve jurisdiction to enforce the December 10, 2025 ’ Settlement Agreement, which is deemed incorporated herein by this reference, ° pursuant to its inherent power as recognized in Kokkonen v. Guardian Life Ins. Co. of ° Am., 511 U.S. 375, 378-81 (1994) and In re City Equities Anaheim, Ltd., 22 F.3d 954, (9th Cir. 1994); Monroy v. Wal-Mart Inc., No. 2:22-CV-01638-RFB-NJK, 2024 WL 4441831, at *1 (D. Nev. Sept. 29, 2024).

3. Each of the parties is to bear its own attorney's fees and costs save and ° except to enforce the Settlement Agreement.

16 DATED: January 8, 2026 sie RICHARD F. BOULWARE, II 17 UNITED STATES DISTRICT JUDGE