STIPULATION BETWEEN PLAINTIFF AND CIGNA DEFENDANTS AND ORDER TO STAY CASE PENDING SETTLEMENT DISCUSSIONS AND TO EXTEND TI TO COMPLETE CLASS DISCOVERY IF SETTLEMENT IS NOT ACHIEVED

MICHAEL W. FITZGERALD, District Judge.

Plaintiff and defendants Cigna Health and Life Insurance Co., Cigna Health Management, Inc., and Cigna Behavioral Health, Inc. (together, "Cigna") hereby respectfully request that the Court, as to Plaintiff's claims against Cigna, (i) stay the Stipulated Case Schedule [Docket No. 45] for a period of 90 days to permit Plaintiff and Cigna to continue their settlement discussions; and (ii) extend all deadlines in the Stipulated Case Schedule by 90 days to allow Plaintiff and Cigna to complete class certification discovery and motions in the event that they are unable to resolve this case. In support of the request, Plaintiff and Cigna jointly stipulate that:

1. Plaintiff Annette Weil filed this class action on her own behalf and on behalf of others similarly situated on September 8, 2015.

2. The defendants answered the complaint on November 2, 2015.

3. On January 14, 2016, the Court entered the Stipulated Case Schedule.

4. Plaintiff and Cigna have been engaged in productive settlement discussions and are confident they will be able to reach agreement on a proposed resolution to submit to the Court for preliminary approval. These parties believe a stay in the discovery and briefing deadlines as to Plaintiff's claims against Cigna will allow them to focus on the ongoing settlement discussions and avoid the needless expenditure of their, and the Court's, resources.

5. Accordingly, Plaintiff and Cigna request that the Court, as to Plaintiff's claims against Cigna: (i) stay this case for a period of 90 days to enable them either to reach a resolution or notify the Court that they are unable to do so; (ii) extend all dates in the Stipulated Case Schedule by 90 days, such that, most immediately, the deadline for class certification discovery for Plaintiff and Cigna would be July 28, 2016, and the deadline for Plaintiff's motion for class certification against Cigna would be August 25, 2016; and (iii) direct that Plaintiff and Cigna, on or before June 15, 2016, update the Court on the status of settlement negotiations.

ATTESTATION

Pursuant to Civil Local Rule 5-1(i)(3) regarding signatures, I attest that concurrence in the filing of this document has been obtained from the other signatories.

IT IS SO ORDERED AND APPROVED.