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    CignaLab Settlement

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    Jakob Emerson
    This motion requests leave to file a summary judgment brief that is 5 pages longer than the standard 40 page limit. Cigna is seeking summary judgment on all claims in a lawsuit involving over $60 million in disputed insurance reimbursement claims for drug testing services. Given the extensive discovery conducted over nearly two years, including over 1.5 million document pages and 18 depositions, Cigna argues the complex legal and factual issues warrant the additional pages. The opposing parties do not object to the request.

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    CignaLab Settlement

    Uploaded by

    Jakob Emerson
    154 views4 pages
    This motion requests leave to file a summary judgment brief that is 5 pages longer than the standard 40 page limit. Cigna is seeking summary judgment on all claims in a lawsuit involving over $60 million in disputed insurance reimbursement claims for drug testing services. Given the extensive discovery conducted over nearly two years, including over 1.5 million document pages and 18 depositions, Cigna argues the complex legal and factual issues warrant the additional pages. The opposing parties do not object to the request.

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    CignaLab Settlement

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    This motion requests leave to file a summary judgment brief that is 5 pages longer than the standard 40 page limit. Cigna is seeking summary judgment on all claims in a lawsuit involving over $60 million in disputed insurance reimbursement claims for drug testing services. Given the extensive discovery conducted over nearly two years, including over 1.5 million document pages and 18 depositions, Cigna argues the complex legal and factual issues warrant the additional pages. The opposing parties do not object to the request.

    Copyright:

    © All Rights Reserved
    Download as PDF, TXT or read online from Scribd
    Download as pdf or txt
    154 views4 pages

    CignaLab Settlement

    Uploaded by

    Jakob Emerson
    This motion requests leave to file a summary judgment brief that is 5 pages longer than the standard 40 page limit. Cigna is seeking summary judgment on all claims in a lawsuit involving over $60 million in disputed insurance reimbursement claims for drug testing services. Given the extensive discovery conducted over nearly two years, including over 1.5 million document pages and 18 depositions, Cigna argues the complex legal and factual issues warrant the additional pages. The opposing parties do not object to the request.

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    © All Rights Reserved
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    Download as pdf or txt
    of 4

    Case 3:19-cv-01324-JCH Document 205 Filed 07/07/23 Page 1 of 4

    UNITED STATES DISTRICT COURT


    DISTRICT OF CONNECTICUT

    CONNECTICUT GENERAL LIFE


    INSURANCE COMPANY and
    CIGNA HEALTH AND LIFE
    INSURANCE COMPANY,
    Case No. 3:19-cv-01324-JCH
    Plaintiffs,
    Hon. Janet C. Hall
    v.

    BIOHEALTH LABORATORIES, INC.,


    PB LABORATORIES, LLC, and July 7, 2023
    EPIC REFERENCE LABS, INC.,

    Defendants.

    CIGNA’S UNOPPOSED MOTION FOR LEAVE TO FILE EXCESS PAGES

    Pursuant to Local Rules of Civil Procedure 7(a), Cigna Health and Life Insurance Company

    and Connecticut General Life Insurance Company (together, “Cigna”) respectfully moves this

    Court for leave to file five additional pages in Cigna’s brief in support of summary judgment. In

    support of this motion, Cigna states as follows.

    1. Local Rule 7(a) limits supporting briefs to forty pages except by order of the Court.

    2. Cigna intends to file a motion for summary judgment on or before July 14, 2023 on

    all counts in the First Amended Complaint filed by BioHealth Laboratories, Inc., PB Laboratories,

    LLC, and Epic Reference Labs, Inc. (together, the “Labs”).

    3. Good cause exists to permit Cigna to file the additional pages in light of the

    complicated nature of this protracted litigation and the issues to be litigated on summary judgment.

    4. The Labs demand more than $60 million from Cigna based on tens of thousands of

    individual claims for reimbursement for drug testing services. The Labs assert claims under

    multiple statutes, as well as claims under Florida common law. Cigna intends to raise, among other
    Case 3:19-cv-01324-JCH Document 205 Filed 07/07/23 Page 2 of 4

    things, arguments based on preemption under the Employee Retirement Income Security Act of

    1974 (ERISA), statutory interpretation, and the undisputed nature of material facts that compel

    summary judgment. The parties have conducted nearly two years of discovery, exchanging more

    than 1.5 million pages of documents and deposing 18 witnesses.

    5. Given the breadth of evidence and the complexity of legal issues involved, Cigna

    respectfully requests leave to include up to forty-five pages for its supporting brief, exclusive of

    the cover page, signature block, and Certificate of Service.

    6. Cigna’s counsel has conferred with the Labs’ counsel, who agreed to the requested

    enlargement of the page limits for Cigna’s brief in support of its motion for summary judgment.

    CONCLUSION

    For the foregoing reasons, Cigna respectfully requests that the Court enter an order granting

    the relief requested herein.

    DATED this 7th day of July 2023. Respectfully submitted,

    ALSTON & BIRD LLP

    /s/ Edward T. Kang


    EDWARD T. KANG (CT26653)
    EMILY COSTIN (PHV No. 10291)
    950 F Street, NW
    Washington, DC 20004
    Telephone: 202-239-3300
    Facsimile: 202-239-3333
    E-mail: edward.kang@alston.com
    E-mail: emily.costin@alston.com

    KELSEY L. KINGSBERY
    (PHV No. 10282)
    555 Fayetteville Street, Suite 600
    Raleigh, North Carolina 27615
    Telephone: 919-862-2200
    Facsimile: 919-862-2260
    E-mail: kelsey.kingsbery@alston.com

    1
    Case 3:19-cv-01324-JCH Document 205 Filed 07/07/23 Page 3 of 4

    Counsel for Connecticut General Life


    Insurance Company and Cigna Health and
    Life Insurance Company

    2
    Case 3:19-cv-01324-JCH Document 205 Filed 07/07/23 Page 4 of 4

    CERTIFICATE OF SERVICE

    This is to certify that this day, July 7, 2023, I electronically filed the foregoing CIGNA’S

    UNOPPOSED MOTION FOR LEAVE TO FILE EXCESS PAGES using the CM/ECF system,

    and via email, upon the following:

    Parajudicial Officer James R. Hawkins


    Email: jrhawkinsii@yahoo.com

    SCOTT M. HARE
    ANTHONY THOMAS GESTRICH
    WHITEFORD, TAYLOR & PRESTON, LLP
    11 Stanwix Street, Suite 1400
    Pittsburgh, PA 15222
    E-mail: share@whitefordlaw.com
    E-mail: agestrich@whitefordlaw.com

    Fred Alan Cunningham


    Matthew Christ
    Domnick Cunningham & Yaffa
    2401 PGA Boulevard, #140
    Palm Beach Gardens, FL 33410
    Email: fred@pbglaw.com
    Email: mtc@pbglaw.com

    John J. Radshaw, III


    65 Trumbull Street, 2d Fl.
    New Haven, CT 06510
    Email: jjr@jjr-esq.com

    Counsel for the Labs

    ALSTON & BIRD LLP

    /s/ Edward T. Kang


    EDWARD T. KANG (No. CT26653)
    950 F Street, NW
    Washington, DC 20004
    Telephone: 202-239-3300
    E-mail: edward.kang@alston.com

    Counsel for Connecticut General Life


    Insurance Company and Cigna Health and
    Life Insurance Company

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