Free Motion to Stay - District Court of Connecticut - Connecticut

Case 3:03-cv—00141-PCD Document 40 Filed 03/08/2006 Page 1 of 3
UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF CONNECTICUT
MARIO PASQUINI 2
Plaintiff, 2
Z 3:03CV ’l4‘I (PCD)
DESCO CORPORATION; DESCO .
CORPORATION LONG TERM DISABILITY 2
INCOME PLAN; UNUM LIFE INSURANCE 2
COMPANY OF AMERICA 1
Defendant : MARCH 8, 2006
PLAINTIFF’S STATUS REPORT
AND
THIRD 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 defendants reconsideration of its
. decision to deny plaintiff benetits. Plaintiff also moves for a further two—month stay of
this case.
This case involves a claim for disability benefits pursuant to the Employee
Retirement Income Security Act. As set forth in the 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 40 Filed 03/08/2006 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
has informed the undersigned that a decision on the reconsideration is expected in the
next two to three weeks.
Plaintiff hereby moves for a further two month stay of this case to May 15, 2006
pending resolution of the administrative review. If the Court denies the motion, plaintiff
hereby renews its Motion for Judgment on the Pleadings.
PLAINTIFF,
B,.\/goscqpsx dZ»\&~Q
David S. Rintoul, Esq.
BROWN, PAINDIRIS 8. SCOTF, LLP
2252 Main Street
Glastonbury, CT 05033
(860) 659-0700
Fed. Bar No. ct#08456
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Case 3:03-cv-00141-PCD Document 40 Filed 03/08/2006 Page 3 of 3
CERTIFICATION
The undersigned hereby certities that the above motion was served by hrst class
mail, postage pre-paid on March 8, 2006 to:
3695 Post Road
P.O. Box 701
Southport CT 06890
David S. Rintoul 5
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