“should be held jointly and severally liable for any award of damages under 29 U.S.C. § 1132”); see also Doc. 27 at 6 (“Caudle’s contention is that Cigna vicariously does business in Alabama using subsidiaries like LINA as proxies.”) (emphasis in original)). Further, while Ms. Caudle has referred to some ERISA-based authorities that have permitted limited jurisdictional discovery from a parent corporation such as Cigna, she has not pointed to any cases that have ultimately allowed a parental holding company to be held jointly and severally liable for the actions of its subsidiary in denying a plaintiffs benefits claim under an ERISA co-conspirator, vicarious liability, and/or alter ego theory. Cf. Flanigan’s Enters., Inc. v. Fulton County, Ga., 242 F.3d 976, 987 n, 16 (11th Cir.2001) (<HOLDING>); Ordower v. Feldman, 826 F.2d 1569, 1576 (7th
holding that a party waives an argument if the party fails to elaborate or provide any citation of authority in support of the argument holding that an issue is waived when a party fails to provide adequate citation to authority recognizing that where a party fails to provide any authority for an argument we will presume that none exists holding party must support argument with legal authority holding that a party waives an argument that it raises in the background section of its brief but not in the argument section