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

Case 3:01-cv-02361-MRK

Document 245

Filed 04/25/2007

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UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT JANICE C. AMARA, GISELA R. BRODERICK, ANNETTE S. GLANZ, individually and on behalf of all others similarly situated, : : : : : Plaintiffs, : : : : : : : Defendants. : :

vs. CIGNA Corp. and CIGNA Pension Plan,

Civil. No. 3:01-CV-2361 (MRK) April 25, 2007

JOINT MOTION TO AMEND THE POST-TRIAL SCHEDULING ORDER Plaintiffs and Defendants hereby jointly move to amend the Post-Trial Scheduling Order issued on March 21, 2007 (dkt. #244). The parties respectfully request that this Court extend each of the deadlines in the post-trial briefing schedule by ten (10) days. In support of this request, the parties state that good cause exists as follows: 1. The previous Scheduling Order contemplated completion of the transcripts

by April 15, 2007. The parties received the transcript for Day 6 (1/24/2007) of the bench trial on April 22, 2007. The parties received the transcript for Day 7 (1/25/2007) of the trial on April 25, 2007. 2. Plaintiffs' post-trial brief with updated Proposed Findings of Fact is due on

May 15, 2007. Defendants' post-trial brief with updated Proposed Findings of Fact is due on June 15, 2007, and Plaintiffs' Reply Brief is due on July 6, 2007.

Case 3:01-cv-02361-MRK

Document 245

Filed 04/25/2007

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3.

Counsel for the parties conferred by e-mail on April 25, 2007 and agreed to

jointly move to extend the post-trial briefing schedule by 10 days for each deadline. Specifically, the Scheduling Order entered on March 21, 2007 would be revised as follows: · Plaintiffs will file their post-trial brief along with updated Proposed Findings of Fact including supporting citations to the trial transcript, no later than May 25, 2007. Defendants will file their post-trial brief along with updated Proposed Findings of Fact including supporting citations to the trial transcript no later than June 25, 2007. Plaintiffs will reply to Defendants' submissions no later than July 19, 2007. Presumably the revised briefing schedule will not interfere with the date for

·

· 4.

Closing Arguments, which is currently set for August 9, 2007. WHEREFORE, the parties request that Court grant this Joint Motion and issue an Order amending the March 21, 2007 Scheduling Order. Dated: April 25, 2007 Respectfully submitted,

By: /s/ Stephen R. Bruce Stephen R. Bruce (CT #23534) Allison C. Caalim 805 15th Street, NW Washington, DC 20005 (202) 371-8013 (202) 371-0121 (fax)

By: /s/ Jeremy P. Blumenfeld Jeremy P. Blumenfeld Joseph J. Costello Jamie M. Kohen MORGAN, LEWIS & BOCKIUS LLP 1701 Market Street Philadelphia, PA 19103-2921 (215) 963-5295/5258

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Case 3:01-cv-02361-MRK

Document 245

Filed 04/25/2007

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Thomas G. Moukawsher (CT #08940) MOUKASHER & WALSH, LLC 328 Mitchell Street Groton, CT 06340 (860) 445-1809 (860) 446-8161 (fax)

Christopher A. Parlo (CT #04700) MORGAN, LEWIS & BOCKIUS LLP 101 Park Avenue New York, NY 10178 (212) 309-6062 (212) 309-6273 (fax) James A.Wade (CT #00086) 280 Trumbull Street ROBINSON & COLE Hartford, CT 06103 (860) 275-8270 (860) 275-8299 (fax)

Attorneys for Plaintiffs

Attorneys for Defendants

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