Free Motion for Sanctions - District Court of Connecticut - Connecticut

Case 3:01-cv-02361-MRK

Document 161-9

Filed 02/02/2006

Page 1 of 1

Exhibits to Plaintiffs' Motion to Compel Responses to Discovery and for Sanctions (dkt #158; 01cv2361) Exhibit A: Exhibit B: Exhibit C: Exhibit D: Exhibit E: Exhibit F: Defs. Suppl. Responses to Second Requests for Documents. Defs. Responses to Third Requests for Documents. Defs. Responses to First Set of Interrogatories. Letter dated 11/23/2005 with Defs. Suppl. Responses to Interrog. Nos. 4 and 14. Excerpts from 4/20/2005 Hearing Transcript. Email produced in discovery on inquiries with January 3, 2003 Hartford Courant article and statement that "Representatives provide no more info than the dotpoints." Wall Street Journal and Hartford Courant articles on Depenbrock decision. February 4, 2005 letter to 178 participants affected by Depenbrock decision. 12/5/2005 email on "exemplars" that CIGNA contends are responsive to Request Nos. 13 and 18, with printouts of those exemplars. William Mercer's benefit comparisons, with defined contribution ("SIP") benefit included in comparison. 11/30/2005 email from John Arko to Jack Lamb about "questions" from Prudential about benefit calculations for rehires affected by the Depenbrock decision. 1/29/2006 email from Jack Lamb to John Arko about "delay after delay" in his benefits being increased. Defs' 7/21/03 Opp. to Motion to Enforce Order Compelling Production. 10/12/05 email from CIGNA's counsel indicating that making "available a copy of the software" does not actually mean a copy of the software. 1/23/2006 email with follow-up requests after systems inspection in Hartford. 9/15/05 letter from CIGNA's counsel stating that "complete class list" will be produced. 1/11/2006 email about questions on the class list. 9/29/2005 email that Defendants' production "does not have a privilege log." 12/9/2005 privilege log with one item. "HR Talking Points" (aka dot-points) document from G.T. Meyn dated 1/03/2003.

Exhibit G: Exhibit H: Exhibit I: Exhibit J: Exhibit K:

Exhibit L: Exhibit M: Exhibit N: Exhibit O: Exhibit P: Exhibit Q: Exhibit R: Exhibit S: Exhibit T: