Free Motion for Extension of Time - District Court of Connecticut - Connecticut

Case 3:01-cv-02361-MRK

Document 97

Filed 02/25/2005

Page 1 of 3

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF CONNECTICUT

JANICE C. AMARA, individually and on behalf of others similarly situated, Plaintiff, v. CIGNA CORP. AND CIGNA PENSION PLAN, Defendants.

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CIVIL ACTION NO. 3:01-CV-2361 (DJS)

FEBRUARY 24, 2005

JOINT MOTION TO EXTEND DEADLINE TO FILE STATUS REPORT The parties in the above-captioned matter, hereby respectfully move for a seven (7) day extension of time in which to file their joint status report, through and including March 4, 2005. In support hereof, the parties respectfully represent as follows: 1. 2. The Status Report is currently due on February 25, 2005; The parties are negotiating in good faith to resolve disagreements on

the items required in the joint report, but additional time is needed to complete the parties' work. 3. 4. This is the first request to extend this deadline. All parties authorize plaintiffs' counsel to sign for them.

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Case 3:01-cv-02361-MRK

Document 97

Filed 02/25/2005

Page 2 of 3

WHEREFORE, the parties respectfully move for a seven (7) day extension of time in which to file their Joint Status Report, through and including March 4, 2005.

FOR THE PLAINTIFF (On behalf of all parties):

By: /s/ Thomas G. Moukawsher Thomas G. Moukawsher ct08940 Ian O. Smith ct24135 Moukawsher & Walsh, LLC 21 Oak Street Hartford, CT 06106 (860) 278-7000 [email protected] Stephen R. Bruce (Proc Hac Vice) Suite 210 805 15th St., NW Washington, DC 20005 (202) 371-8013

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Case 3:01-cv-02361-MRK

Document 97

Filed 02/25/2005

Page 3 of 3

CERTIFICATION I hereby certify that a copy of the foregoing has been mailed on this date to the defendant at: Christopher A. Parlo Morgan, Lewis & Bockius 101 Park Avenue New York, NY 10178 Joseph J. Costello Jeremy P. Blumenfeld Morgan, Lewis & Bockius 1701 Market Street Philadelphia, PA 19103-2921 Dated this 24th day of February, 2005.

/s/ Thomas G. Moukawsher Thomas G. Moukawsher

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