Free Order on Motion to Amend/Correct - District Court of Connecticut - Connecticut

1 _ Case 3:00-cv-O1096(St:{U Document 124 Filed 10/253€OO3 Page 1 of 1
1 I
I · l
11110 1
1 UNITED STATES DISTRICT COURT
1 DISTRICT OF CONNECTICUT 1
I ··**······“·····*·············*··········· · ····-—--——-----—--—— >< 1
, John Doe, ; =
1 Plaintiff ; 1
1 VS. 1 Civil Action No.: 3:00 CV-01096(SRU)
UNUMProvident Corporation f/k/a E
Provident Companies, Inc., : 1
The Paul Revere Life Insurance Company, : 1
Provident Life and Accident Insurance : 1
Company of America : 1
and John Hancock Mutual Life Insurance : _
<3¤mr>¤t13i, I , :
Defendants ; 1
1-r-v —————- Q; 1 ———-—--------——---—————--------——-—-—--—---—- — —---—— x September 25, 2003 1
(‘ F ,.~
'_ git; _ MOTION TO AMEND WITNESS LIST
1 , Pursuant to the court's Pretrial Order plaintiff moves for permission to amend his
$7 witnessiilist toliadd two additional fact witnesses (non-experts) whom he may call in this 1
§ matter, as follows: 1
I
§ 1. Linda Nee, 60 Hicks Road, West Newfield Maine 04095
¢“ 1
Linda Nee is a former claims representative ("Customer Care Specialist") employed by 1
1 UNUM Life, and subsequently by the UNUMProvident companies from approximately 1994
{ to 2002. She rose through the ranks of defendants' claims representatives positions to the 1
1 level of Lead Customer Care Specialist and worked with psychiatric claims and the so- 1
I _caIled "psych unit." She has personal knowledge of defendants} claims handling practices 1
1 _ I Qincluding their implementation and use of a pattern and practice of strategies to deny
Eclaims. She has personal knowledge of Ralph Mohney's involvement in implementing
__,.,_E . gthese strategies. These strategies included the use of round~table procedures inqtltiding so
¤ I ecalled "multi disci Iina round tab|es" to implement denials of claims. It is._.anticlpated that
p ry • . i · · 1
ishe will testify concerning her experiences and observations as a claims representtivei { 2 _
; mployed by defendants.
· 2. Thomas Basden Heys c/o UNUMProvident Corportation, Chattanooga,.TlfN 1
~ - . l
g sz
1
1

. . U . `4`` 2
Yi --. __ _i
l —_ ri ri __