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

Case 3:01-cv-02361-MRK

Document 118

Filed 05/31/2005

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

3:01 CV 2361 (MRK) May 31, 2005

UNOPPOSED MOTION FOR EXTENSION OF TIME Defendants CIGNA Corporation and CIGNA Pension Plan ("Defendants"), by and through counsel, hereby move for two week extension of time, until June 14, 2005, to respond to Plaintiff Janice Amara's Motion in Limine on Direct Testimony Relevant To The "Likely Prejudice" Standard in Burke v. Kodak ("Plaintiff's Motion"). As grounds for this Motion, Defendants state that: 1. This extension is being sought to accommodate other professional obligations of

counsel for Defendants, including but not limited to Defendants' Opposition to Plaintiff's Motion for Leave To Amend The Complaint in this case, which is being filed concurrently with this Motion, and an appellate brief due to the United States Court of Appeals for the Third Circuit. 2. This extension will not delay the pretrial or trial proceedings in this case.

Case 3:01-cv-02361-MRK

Document 118

Filed 05/31/2005

Page 2 of 3

3.

No prior extensions of time have been sought or received by counsel for

Defendants for responding to Plaintiff's Motion. 4. Counsel for Plaintiffs concur in the instant Motion.

WHEREFORE, Defendants respectfully request for an extension of time be granted and that their response to Plaintiff's Motion be due on June 14, 2005.

Dated: May 31, 2005

Respectfully submitted, MORGAN, LEWIS & BOCKIUS LLP By:_______________________________ Christopher A. Parlo (CT-04700) 101 Park Avenue New York, New York 10178 (212) 309-6062 (212) 309-6273 (fax) Joseph J. Costello Jeremy P. Blumenfeld 1701 Market Street Philadelphia, Pennsylvania 19103-2921 (215) 963-5295/5258 ROBINSON & COLE James A.Wade (CT # 00086) Elizabeth A. Fowler (CT #23584) 280 Trumbull Street Hartford, Connecticut 06103 (860) 275-8270 (860) 275-8299 (fax) Attorneys for Defendants CIGNA Corporation and CIGNA Pension Plan

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Case 3:01-cv-02361-MRK

Document 118

Filed 05/31/2005

Page 3 of 3

CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing was served this 31st day of May, 2005, via telecopy and first-class mail upon the following: Thomas G. Moukawsher, Esq. Moukawsher & Walsh, LLC 328 Mitchell Street Groton, CT 06340 and upon: Stephen R. Bruce, Esq. 805 15th Street, NW Suite 210 Washington, DC 20005

________________________ Elizabeth A. Fowler