Free Motion to Stay - District Court of Connecticut - Connecticut

Case 3:03-cv—O0141-PCD Document 42 Filed O3/31/2006 Page 1 of 3
UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF CONNECTICUT
MARIO PASOUINI 2
Plaintiff, :
2 3:03CV ‘I4'I (PCD)
V. 1
DESCO CORPORATION; DESCO
CORPORATION LONG TERM DISABILITY 1
INCOME PLAN; UNUM LIFE INSURANCE I
COMPANY OF AMERICA 2
Defendant : MARCH 30, 2006
PLAlNTIFF’S STATUS REPORT
AND
FOURTH MOTION TO STAY CASE
Plaintiff submits this status report in response to this Courts prior granting of its
motion to stay the case pending completion of the defendant's reconsideration of its
decision to deny plaintiff benefits. Plaintiff also moves for a further thirty-day stay of this
case.
This case involves a claim for disability benefits pursuant to the Employee
Retirement Income Security Act. As set forth inthe prior motions to stay, the defendant
had entered into a multi—state settlement providing a procedure for further
administrative review of previously—denied disability claims. Plaintiff consented to
'I

Case 3:03-cv-00141-PCD Document 42 Filed 03/31/2006 Page 2 of 3
submit his claim to this process, but the defendant required that any pending litigation
be stayed pending resolution of the administrative review. Both parties have tiled and
fully briefed motions forjudgment on the pleadings, which the Court denied without
prejudice pending expiration of the stay.
The administrative review of plaintiffs claim is still pending. Defendant's counsel
represented to the undersigned that the defendant needs an additional thirty days to
issue a decision.
Plaintiff hereby moves for a further stay of this case to May 5, 2006 pending
resolution of the administrative review. lf the Court denies the motion, plaintiff hereby
renews its Motion for Judgment on the Pleadings.
PLAINTIFF,
By: Q
David S. Rintoul, Esq.
BROWN, PAINDIRIS & SCOTT, LLP
2252 Main Street
Glastonbury, CT 06033
(860) 659-0700
Fed. Bar No. ct#08456
2

Case 3:03-cv-00141-PCD Document 42 Filed O3/31/2006 Page 3 of 3
CERTIFICATION
The undersigned hereby certities that the above motion was served by tirst class
maii, postage pre-paid on March 30, 2006 to:
Alexander Schwartz
3695 Post Road
` F’.O. Box 70*1
Southport CT 06890
;@;—»;_
David S. Rintoul
3