RJ
RJ v. Cigna Behavioral Health, Inc.
Opinion
Trial Court Opinion
I. BACKGROUND
20 In this putative class action, plaintiffs challenge defendants’ alleged failure to reimburse 21 covered mental health provider claims at the usual, customary, and reasonable rates. They assert 22 several claims for relief, including for violations of 18 U.S.C. §§ 1962(c) and 1962(d), for 23 underpayment of benefits and breach of plan provisions in violation of ERISA, 29 U.S.C. 24 § 1132(a)(1) and 29 U.S.C. § 1132(a)(3)502(a)(1)(B), and for breach of fiduciary duties. See Dkt. 25 Nos. 63, 116. 26 Although it is not entirely clear from the joint submission which depositions have been 27 completed, plaintiffs originally noticed ten fact depositions—eight individual depositions and two Rule 30(b)(6) depositions (one for each corporate defendant). Each of the Rule 30(b)(6) depositions has necessitated the designation of more than one corporate representative. See Dkt. No. 125 at 1, 4. In addition to these noticed depositions, plaintiffs wish to take the individual depositions of Keith Jones, a current Cigna employee, and Annette Parotti, a former employee, as well as the depositions of four as-yet-unidentified witnesses from four non-party…