Free Motion for Extension of Time to File Response/Reply to Motion - District Court of Connecticut - Connecticut

Case 3:01-cv-02361-MRK

Document 84

Filed 06/28/2004

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, vs. CIGNA CORP. AND CIGNA PENSION PLAN, Defendants. : : : : : : : : : : : CIVIL ACTION NO. 3:01-CV-2361 (DJS)

JUNE 25, 2004

PLAINTIFF'S MOTION FOR EXTENSION OF TIME TO RESPOND TO MOTION TO DECERTIFY CLASS Plaintiff, Janice Amara ("Amara") hereby respectfully requests a two week extension of time through and including July 12, 2004 in which to respond to defendants' motion to decertify the class in the above-captioned matter. In support hereof, Amara respectfully represents as follows: 1. Plaintiff's response is currently due on June 28, 2004; 2. Both of Amara's counsel have been occupied with briefs and discovery matters to meet preexisting deadlines in other courts; 3. Because of their other commitments, counsel have been unable to complete the research and briefing necessary to respond to defendants' motion; 4. This is Amara's first request to extend this deadline; 5. Defense counsel consents to the granting of this motion. WHEREFORE, Amara respectfully moves for a two week extension of time through and including July 12, 2004 in which to respond to defendants' motion to decertify the class.

THE PLAINTIFF

Case 3:01-cv-02361-MRK

Document 84

Filed 06/28/2004

Page 2 of 3

By____/s/ Thomas G. Moukawsher_____ Thomas G. Moukawsher Fed. Bar. No.: ct08940 Moukawsher & Walsh, LLC 21 Oak Street, Suite 209 Hartford, CT 06106 (860) 278-7003 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 84

Filed 06/28/2004

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 25th day of June, 2004.

___/s/ Thomas G. Moukawsher___ Thomas G. Moukawsher

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