1 Ethan D. Thomas, Nevada Bar No. 12874 LITTLER MENDELSON, P.C. 2 8474 Rozita Lee Avenue, Suite 200 Las Vegas, NV 89113-4770 3 Telephone: (702) 862-8800 GRANT in part and deny in part with language Facsimile: (702) 862-8811 on page 4. 4 edthomas@littler.com The parties seek leave for Pl to file her AC by 5 Joshua B. Simon* 3/24. CDS already granted that relief, and Warren Haskel* 6 Richard W. Nicholson, Jr.* Plaintiff already filed the AC, so I think we Richard D. Diggs* should DENY it as moot. 7 MCDERMOTT WILL & SCHULTE LLP One Vanderbilt Avenue The parties also seek leave for Pl to include two 8 New York, NY 10017-3852 additional Pls in the AC. I'm not sure they need Telephone: (212) 547-5400 9 Facsimile: (212) 547-5444 additional leave to do that because CDS already jsimon@mcdermottlaw.com gave Pl leave to amend, but I see no issue with 10 whaskel@mcdermottlaw.com GRANTING that request. rnicholson@mcdermottlaw.com 11 rdiggs@mcdermottlaw.com The parties also seek leave for Pl to name an
12 Brett Boskiewicz* adult Pl by their initials. Pl provides no basis MCDERMOTT WILL & SCHULTE LLP for this request and the AC doesn't include one 13 200 Clarendon Street either. I think we should DENY this request. Boston, MA 02116 14 Telephone: (617) 535-4000 Facsimile: (617) 535-3800 15 bboskiewicz@mcdermottlaw.com
16 *Admitted Pro Hac Vice
17 Attorneys for Defendant Cigna Health and Life Insurance Company 18 UNITED STATES DISTRICT COURT 19 DISTRICT OF NEVADA 20 IRENA STANIC RASIN, on her own behalf, and Case No. 2:25-cv-00407-CDS-DJA 21 on behalf of all similarly situated individuals, STIPULATION AND [PROPOSED] 22 Plaintiff, ORDER TO EXTEND TIME FOR DEFENDANT TO RESPOND TO 23 v. PLAINTIFF’S COMPLAINT
24 CIGNA HEALTH AND LIFE INSURANCE COMPANY, 25 Defendant. 26
27 1 Defendant Cigna Health and Life Insurance Company (“Cigna”) and Plaintiff Irena Stanic 2 Rasin (“Plaintiff”) (and together with Cigna, the “Parties”), by and through their respective 3 undersigned counsel of record, hereby agree and stipulate as follows: 4 1. WHEREAS, on March 10, 2026, this Court entered an order granting in part and 5 denying in part Cigna’s Motion to Dismiss the Complaint and dismissed certain allegations without 6 prejudice and with leave to amend (the “Order”) (ECF No. 53); 7 2. WHEREAS, the Order gave Plaintiff leave to file a First Amended Complaint by 8 March 24, 2026; 9 3. WHEREAS, Plaintiff intends to file a First Amended Complaint that will include 10 allegations to address the insufficiencies identified in the Order and to add a second named plaintiff 11 who is a minor child; 12 4. WHEREAS, the Parties stipulate and agree that Plaintiff may file the First Amended 13 Complaint, including allegations to add the second named plaintiff, on or before March 24, 2026, 14 and that consolidating these amendments into one pleading serves the interests of efficiency and 15 judicial economy; 16 5. WHEREAS, the Parties stipulate and agree that both the minor child and his parent 17 may be identified in the First Amended Complaint and other filings through their initials in order to 18 protect the minor child’s identity so long as Plaintiff’s counsel separately provides Cigna notice of 19 the minor child’s and his parent’s identity at the time of the filing of the First Amended Complaint; 20 6. WHEREAS, under Federal Rule of Civil Procedure 12, Cigna’s response to the 21 remaining allegations in the current Complaint would also be due on March 24, 2026; 22 7. WHEREAS, under Federal Rule of Civil Procedure 15, Cigna’s response to the First 23 Amended Complaint would be due on April 7, 2026; 24 8. WHEREAS, the Parties stipulate and agree that Cigna shall have an extension up to 25 and including April 14, 2026, to respond to the Complaint or the First Amended Complaint, 26 whichever is the operative pleading at that time, including filing a Rule 12 motion for any new 27 allegations in the First Amended Complaint; 1 9. WHEREAS, this is Cigna’s first request for an extension of these deadlines, and good 2 cause exists because the extension is in the interests of efficiency and judicial economy in that Cigna 3 will not be required to Answer the original Complaint after Plaintiff files the First Amended 4 Complaint; 5 10. Accordingly, the Parties stipulate and hereby request that the Court: 6 i. permit Plaintiff to file a First Amended Complaint that includes allegations to 7 add a minor child as the second named plaintiff on or before March 24, 2026; 8 ii. permit Plaintiff to identify the minor named plaintiff and his parent using their 9 initials in the First Amended Complaint and all other filings; and 10 iii. grant Cigna an extension up to and including April 14, 2026 to file a response 11 to the operative complaint on that date. 12 Dated: March 23, 2026 Respectfully submitted, 13 /s/ Elizabeth M. Binczik /s/ Richard W. Nicholson, Jr. 14 Anna P. Prakash* Joshua B. Simon* Brock J. Specht * Warren Haskel* 15 Elizabeth M. Binczik* Richard W. Nicholson, Jr.* NICHOLS KASTER, PLLP Richard Diggs* 16 80 S. Eighth Street, Suite 4700 MCDERMOTT WILL & SCHULTE LLP Minneapolis, MN 55402 One Vanderbilt Avenue 17 Telephone: (877) 344-4628 New York, NY 10017-3852 aprakash@nka.com Telephone: (212) 547-5400 18 bspecht@nka.com Facsimile: (212) 547-5444 ebinczik@nka.com jsimon@mcdermottlaw.com 19 whaskel@mcdermottlaw.com Kathleen Bliss (NV Bar No. 7606) rnicholson@mcdermottlaw.com 20 Kathleen Bliss Law PLLC rdiggs@mcdermottlaw.com 170 South Green Valley Parkway, Suite 300 21 Henderson, NV 89012 Ethan D. Thomas, Neveda Bar No. 12874 Telephone: (702) 318-7375 LITTLER MENDELSON, P.C. 22 kb@kathleenblisslaw.com 8474 Rozita Lee Avenue, Suite 200 Las Vegas, NV 89113-4770 23 Eleanor Hamburger* Telephone: (702) 862-8800 Ari Robbins Greene* Facsimile: (702) 862-8811 24 SIRIANNI YOUTZ SPOONEMORE edthomas@littler.com HAMBURGER PLLC 25 3101 Western Avenue, Suite 350 Brett Boskiewicz* Seattle, WA 98121 MCDERMOTT WILL & SCHULTE LLP 26 Telephone: (206) 223-0303 200 Clarendon Street ehamburger@sylaw.com Boston, MA 02116 27 arobbinsgreene@sylaw.com Telephone: (617) 535-4000 Facsimile: (617) 535-3800 1}| Kevin Costello* bboskiewicz@mcdermottlaw.com Zeinab Bakhiet* 2|| CENTER FOR HEALTH LAW & POLICY *Admitted Pro Hac Vice INNOVATION 3|| HARVARD LAW SCHOOL Attorneys for Defendant Cigna Health and 1585 Massachusetts Avenue Life Insurance Company Cambridge, MA 02138 Telephone: (617) 496-0901 5|| kcostello@law.harvard.edu zbakhiet@law.harvard.edu 6 *Admitted Pro Hac Vice 7 Attorneys for Plaintiff 8 IT IS THEREFORE ORDERED that the stipulation (ECF No. 54) is GRANTED in part and 9|| DENIED in part as outlined below: 10 The stipulation is DENIED in part as moot regarding the parties' request that Plaintiff have until March 24, 2026, to file an amended complaint because the Honorable District Judge Cristina D. Silva has already granted Plaintiff that relief. (ECF No. 53). 12 B The stipulation is DENIED in part regarding the parties’ request that Plaintiff be permitted to refer to an adult party using only their initials. While Federal Rule of Civil Procedure 5.2(a)(3) and Local 14|} Rule IC 6-1(a)(2) permit parties to refer to minor children using only their initials, those rules do not afford the same to adults. To the contrary, the Ninth Circuit has concluded that "a party may preserve his or her anonymity in judicial proceedings in special circumstances when the party's need 16 for anonymity outweighs prejudice to the opposing party and the public's interest in knowing the party's identity." Does I through XXII v. Advanced Textile Corp., 214 F.3d 1058, 1068 (9th Cir. 17|| 2000).
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1 Ethan D. Thomas, Nevada Bar No. 12874 LITTLER MENDELSON, P.C. 2 8474 Rozita Lee Avenue, Suite 200 Las Vegas, NV 89113-4770 3 Telephone: (702) 862-8800 GRANT in part and deny in part with language Facsimile: (702) 862-8811 on page 4. 4 edthomas@littler.com The parties seek leave for Pl to file her AC by 5 Joshua B. Simon* 3/24. CDS already granted that relief, and Warren Haskel* 6 Richard W. Nicholson, Jr.* Plaintiff already filed the AC, so I think we Richard D. Diggs* should DENY it as moot. 7 MCDERMOTT WILL & SCHULTE LLP One Vanderbilt Avenue The parties also seek leave for Pl to include two 8 New York, NY 10017-3852 additional Pls in the AC. I'm not sure they need Telephone: (212) 547-5400 9 Facsimile: (212) 547-5444 additional leave to do that because CDS already jsimon@mcdermottlaw.com gave Pl leave to amend, but I see no issue with 10 whaskel@mcdermottlaw.com GRANTING that request. rnicholson@mcdermottlaw.com 11 rdiggs@mcdermottlaw.com The parties also seek leave for Pl to name an
12 Brett Boskiewicz* adult Pl by their initials. Pl provides no basis MCDERMOTT WILL & SCHULTE LLP for this request and the AC doesn't include one 13 200 Clarendon Street either. I think we should DENY this request. Boston, MA 02116 14 Telephone: (617) 535-4000 Facsimile: (617) 535-3800 15 bboskiewicz@mcdermottlaw.com
16 *Admitted Pro Hac Vice
17 Attorneys for Defendant Cigna Health and Life Insurance Company 18 UNITED STATES DISTRICT COURT 19 DISTRICT OF NEVADA 20 IRENA STANIC RASIN, on her own behalf, and Case No. 2:25-cv-00407-CDS-DJA 21 on behalf of all similarly situated individuals, STIPULATION AND [PROPOSED] 22 Plaintiff, ORDER TO EXTEND TIME FOR DEFENDANT TO RESPOND TO 23 v. PLAINTIFF’S COMPLAINT
24 CIGNA HEALTH AND LIFE INSURANCE COMPANY, 25 Defendant. 26
27 1 Defendant Cigna Health and Life Insurance Company (“Cigna”) and Plaintiff Irena Stanic 2 Rasin (“Plaintiff”) (and together with Cigna, the “Parties”), by and through their respective 3 undersigned counsel of record, hereby agree and stipulate as follows: 4 1. WHEREAS, on March 10, 2026, this Court entered an order granting in part and 5 denying in part Cigna’s Motion to Dismiss the Complaint and dismissed certain allegations without 6 prejudice and with leave to amend (the “Order”) (ECF No. 53); 7 2. WHEREAS, the Order gave Plaintiff leave to file a First Amended Complaint by 8 March 24, 2026; 9 3. WHEREAS, Plaintiff intends to file a First Amended Complaint that will include 10 allegations to address the insufficiencies identified in the Order and to add a second named plaintiff 11 who is a minor child; 12 4. WHEREAS, the Parties stipulate and agree that Plaintiff may file the First Amended 13 Complaint, including allegations to add the second named plaintiff, on or before March 24, 2026, 14 and that consolidating these amendments into one pleading serves the interests of efficiency and 15 judicial economy; 16 5. WHEREAS, the Parties stipulate and agree that both the minor child and his parent 17 may be identified in the First Amended Complaint and other filings through their initials in order to 18 protect the minor child’s identity so long as Plaintiff’s counsel separately provides Cigna notice of 19 the minor child’s and his parent’s identity at the time of the filing of the First Amended Complaint; 20 6. WHEREAS, under Federal Rule of Civil Procedure 12, Cigna’s response to the 21 remaining allegations in the current Complaint would also be due on March 24, 2026; 22 7. WHEREAS, under Federal Rule of Civil Procedure 15, Cigna’s response to the First 23 Amended Complaint would be due on April 7, 2026; 24 8. WHEREAS, the Parties stipulate and agree that Cigna shall have an extension up to 25 and including April 14, 2026, to respond to the Complaint or the First Amended Complaint, 26 whichever is the operative pleading at that time, including filing a Rule 12 motion for any new 27 allegations in the First Amended Complaint; 1 9. WHEREAS, this is Cigna’s first request for an extension of these deadlines, and good 2 cause exists because the extension is in the interests of efficiency and judicial economy in that Cigna 3 will not be required to Answer the original Complaint after Plaintiff files the First Amended 4 Complaint; 5 10. Accordingly, the Parties stipulate and hereby request that the Court: 6 i. permit Plaintiff to file a First Amended Complaint that includes allegations to 7 add a minor child as the second named plaintiff on or before March 24, 2026; 8 ii. permit Plaintiff to identify the minor named plaintiff and his parent using their 9 initials in the First Amended Complaint and all other filings; and 10 iii. grant Cigna an extension up to and including April 14, 2026 to file a response 11 to the operative complaint on that date. 12 Dated: March 23, 2026 Respectfully submitted, 13 /s/ Elizabeth M. Binczik /s/ Richard W. Nicholson, Jr. 14 Anna P. Prakash* Joshua B. Simon* Brock J. Specht * Warren Haskel* 15 Elizabeth M. Binczik* Richard W. Nicholson, Jr.* NICHOLS KASTER, PLLP Richard Diggs* 16 80 S. Eighth Street, Suite 4700 MCDERMOTT WILL & SCHULTE LLP Minneapolis, MN 55402 One Vanderbilt Avenue 17 Telephone: (877) 344-4628 New York, NY 10017-3852 aprakash@nka.com Telephone: (212) 547-5400 18 bspecht@nka.com Facsimile: (212) 547-5444 ebinczik@nka.com jsimon@mcdermottlaw.com 19 whaskel@mcdermottlaw.com Kathleen Bliss (NV Bar No. 7606) rnicholson@mcdermottlaw.com 20 Kathleen Bliss Law PLLC rdiggs@mcdermottlaw.com 170 South Green Valley Parkway, Suite 300 21 Henderson, NV 89012 Ethan D. Thomas, Neveda Bar No. 12874 Telephone: (702) 318-7375 LITTLER MENDELSON, P.C. 22 kb@kathleenblisslaw.com 8474 Rozita Lee Avenue, Suite 200 Las Vegas, NV 89113-4770 23 Eleanor Hamburger* Telephone: (702) 862-8800 Ari Robbins Greene* Facsimile: (702) 862-8811 24 SIRIANNI YOUTZ SPOONEMORE edthomas@littler.com HAMBURGER PLLC 25 3101 Western Avenue, Suite 350 Brett Boskiewicz* Seattle, WA 98121 MCDERMOTT WILL & SCHULTE LLP 26 Telephone: (206) 223-0303 200 Clarendon Street ehamburger@sylaw.com Boston, MA 02116 27 arobbinsgreene@sylaw.com Telephone: (617) 535-4000 Facsimile: (617) 535-3800 1}| Kevin Costello* bboskiewicz@mcdermottlaw.com Zeinab Bakhiet* 2|| CENTER FOR HEALTH LAW & POLICY *Admitted Pro Hac Vice INNOVATION 3|| HARVARD LAW SCHOOL Attorneys for Defendant Cigna Health and 1585 Massachusetts Avenue Life Insurance Company Cambridge, MA 02138 Telephone: (617) 496-0901 5|| kcostello@law.harvard.edu zbakhiet@law.harvard.edu 6 *Admitted Pro Hac Vice 7 Attorneys for Plaintiff 8 IT IS THEREFORE ORDERED that the stipulation (ECF No. 54) is GRANTED in part and 9|| DENIED in part as outlined below: 10 The stipulation is DENIED in part as moot regarding the parties' request that Plaintiff have until March 24, 2026, to file an amended complaint because the Honorable District Judge Cristina D. Silva has already granted Plaintiff that relief. (ECF No. 53). 12 B The stipulation is DENIED in part regarding the parties’ request that Plaintiff be permitted to refer to an adult party using only their initials. While Federal Rule of Civil Procedure 5.2(a)(3) and Local 14|} Rule IC 6-1(a)(2) permit parties to refer to minor children using only their initials, those rules do not afford the same to adults. To the contrary, the Ninth Circuit has concluded that "a party may preserve his or her anonymity in judicial proceedings in special circumstances when the party's need 16 for anonymity outweighs prejudice to the opposing party and the public's interest in knowing the party's identity." Does I through XXII v. Advanced Textile Corp., 214 F.3d 1058, 1068 (9th Cir. 17|| 2000). Accordingly, the party seeking to be referred to using only their initials must move for that relief and properly brief the basis for it. 18 19 The stipulation is GRANTED in part regarding the parties’ request that Plaintiff be permitted to name an additional Plaintiff given the liberal standards that Courts apply to motions to amend under 20 || Federal Rule of Civil Procedure 15(a)(2). The stipulation is GRANTED in part regarding the parties' request that Plaintiff be permitted to refer to the minor Plaintiff using only their initials. See Fed. R. Civ. P. 5.2(a)(3); see LR IC 6-1(a) (2). 23 Finally, the stipulation is GRANTED in part regarding the parties' request that Defendant have until 24|| April 14, 2026, to respond to the operative complaint. 25 \ :
27 DANIELT. ACBREGT i UNITED STATES MAGISTRATE JUDGE 28 DATED: March 24, 2026