Free Report of Rule 26(f) Planning Meeting - District Court of Connecticut - Connecticut

Case 3:01-cv-02361-MRK

Document 133

Filed 07/13/2005

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UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT : : : : Plaintiff, : v. : : CIGNA CORP. and CIGNA : PENSION PLAN, : Defendants. : JANICE C. AMARA, individually and on behalf of others similarly situated,

3:01 CV 2361 (MRK)

PLAINTIFF'S SCHEDULING PROPOSAL Plaintiff Janice C. Amara ("Plaintiff") submits the following revised case management schedule pursuant to this Court's June 21, 2005 Order. Plaintiff's counsel conferred with counsel for the Defendants and were unable to reach an agreement on a Joint Scheduling Proposal: 1. Joinder of Parties: Any motion by the Plaintiff Class to add additional named representatives besides Janice Amara and Gisela Broderick shall be filed by August 12, 2005. 2. Plaintiffs' Discovery. Defendants shall produce all documents identified in their responses to Plaintiffs' Second and Third Set of Document Requests and any privilege log on or before July 22, 2005. Plaintiffs shall take the depositions of Arthur Assantes, Stewart Beltz and Denise Hill by August 11, 2005. By September 9, 2005, Plaintiffs shall take two Rule 30(b)(6)

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depositions on the William M. Mercer company's consulting advice to CIGNA and CIGNA's compliance with ERISA §204(g). 3. Defendants' Discovery. Defendants shall take the deposition of Gisela Broderick, the proposed new named plaintiff, by August 11, 2005. Defendants shall take the deposition of any other proposed named plaintiff by September 9, 2005. Defendants shall take discovery on the new claims in the Second Amended Complaint from up to seven additional class members by questionnaires or by deposition (lasting no more than one hour per person) by September 30, 2005.1 4. Motions: Plaintiffs shall file any motion to compel complete responses to their Second and Third Set of Document Requests and their First Set of Interrogatories by July 29, 2005. Defendants shall file any motion to designate additional expert witnesses by July 29, 2005. 5. Discovery Completion Date: All discovery shall be completed (not just propounded) by September 30, 2005. 6. Proposed Findings of Fact and Conclusions of Law: The Plaintiff class shall serve their proposed findings of fact and conclusions of law on the Defendants on or before October 17, 2005. Defendants shall serve their

1

See e.g., McCarthy v. Paine Webber, 164 FRD 309, 313 (D. Conn. 1995).
2

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proposed findings of fact and conclusions of law on or before November, 7, 2005. 7. Trial Memorandum: The Parties' Joint Trial Memorandum, prepared according to the Court's Instructions for Joint Trial Memorandum (rev'd 11/03) is due December 5, 2005. 8. Trial Ready Date: The case will be considered trial ready on December 30, 2005. 9. Proposed Dates for Trial: January 30-February 3, 2006; February 6-10, 13-17, or 20-24, 2006. Dated: July 13, 2005 FOR THE PLAINTIFF:

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 ct 23534 (pro hac vice) Suite 210 805 15th St., NW Washington, DC 20005 (202) 371-8013 [email protected]

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Case 3:01-cv-02361-MRK

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CERTIFICATE OF SERVICE This certifies that copies of the foregoing Plaintiff's Scheduling Proposal were sent on this 13th day of July, 2005 by e-mail as a PDF and WordPerfect attachment addressed to: Joseph J. Costello Jeremy P. Blumenfeld Morgan Lewis & Bockius 1701 Market St. Philadelphia, PA 19103-2921 [email protected] [email protected] Christopher A. Parlo Morgan Lewis & Bockius 100 Park Ave. New York, NY 10178 [email protected] Elizabeth A. Fowler Robinson & Cole 280 Trumbell St. Hartford, CT 06103-3597 [email protected]

/s/ Thomas G. Moukawsher Thomas G. Moukawsher