UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT



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UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT JANICE C. AMARA, individually and on behalf of all others similarly situated, Plaintiffs, v. CIGNA CORPORATION and CIGNA PENSION PLAN, Defendants. Civil No. 3:01cv2361 (JBA) Important Notice About Increased Retirement Benefits from the CIGNA Pension Plan and Proposed Attorneys Fee Award Your Increased CIGNA Pension Benefits You are receiving this Notice as part of the Amara v. CIGNA class action litigation in the United States District Court for the District of Connecticut. This litigation sought to remedy misleading disclosures by CIGNA about retirement benefits from the CIGNA Pension Plan by providing increased benefits to current and former CIGNA employees who participated in the CIGNA Pension Plan. You have been identified as a current or former CIGNA employee who may be entitled to an increased retirement benefit as a result of this class action lawsuit. Before this litigation, you were entitled to receive the total amount of your Part B cash balance account at any time after you ended your employment with CIGNA. You could choose to receive this benefit as a lump sum or as an annuity. This cash balance account included an opening account balance calculated based on the benefits you earned under CIGNA s Part A pension plan as of December 31, 1997. It also included certain benefit and interest credits that you earned after January 1, 1998 until the plan was frozen and/or until you commenced benefits. As a result of this litigation, you will receive what is called an A+ B benefit. That is, you will receive: an A benefit equal to your frozen monthly benefit under CIGNA s Part A pension plan as of December 31, 1997, PLUS a B benefit equal to the cash balance benefit and interest credits (not including the opening balance and any interest that you accrued on your opening account balance) that you have earned after January 1, 1998 under CIGNA s Part B cash balance plan.

The resulting A+ B benefit will be reduced by the value of retirement benefits you have already received from CIGNA. The form, manner, and timing of payment of the increased retirement benefit will be communicated to you separately. The United States District Court for the District of Connecticut has ordered CIGNA to pay these increased retirement benefits to you, net of any attorneys fee award and taxes. The Amara Class Action Lawsuit In December 2001, Janice Amara, an account manager who worked for 29 years for CIGNA before retiring in 2003, filed a lawsuit against the CIGNA Pension Plan on behalf of herself and over 27,000 Plan participants and beneficiaries. She was later joined as lead plaintiff by two other individuals, Gisela Broderick and Annette Glanz. The lawsuit alleged, among other claims, that CIGNA deliberately failed to disclose significant reductions in retirement benefits when it changed from a traditional defined benefit pension plan (the Part A Plan) to a cash balance pension formula (the Part B Plan) at the start of 1998. In 2008, after a seven-day trial, Judge Mark Kravitz of the United States District Court for the District of Connecticut ruled that CIGNA failed to disclose the reductions in future benefits and made downright misleading statements in the Summary Plan Description and other communications that employees cash balance benefits would be comparable or larger than under the prior Part A formula with no cost savings for CIGNA. After several appeals, the case was transferred to Judge Janet Bond Arterton, who ordered relief in the form of the A+B benefit formula described above. The Requests for Attorneys Fees and Incentive Awards The total value of the benefit increases expected to result from this class action litigation has been estimated by Class counsel to be over $197 million and by CIGNA to be significantly less than half that amount. The attorneys for the Plaintiff class, which includes three law firms, are requesting that the Court make an award of attorneys fees based on 17.5% of the increased benefits. An award of attorneys fees from this common fund will compensate the Plaintiffs attorneys for their time and services over the past 14 years on behalf of the Plaintiffs and 27,000 members of the class. Included within this request are $240,000 in incentive awards for the named Plaintiffs and other witnesses who shouldered the burden of this litigation on behalf of other employees. The Plaintiffs attorneys are requesting incentive awards of $50,000 for Ms. Amara, Ms. Broderick and Ms. Glanz, who were the lead Plaintiffs. They also request incentive awards of $15,000 for five witnesses who testified at trial (Bruce

Charette, Patricia Flannery, Barbara Hogan, Lillian Jones and Robert Upton), and $5,000 for three witnesses who were deposed and responded to CIGNA s document requests and interrogatories but did not testify at trial. If the Court grants these requests, the amount of any increased retirement benefits payable to you as a result of the Amara litigation (the A+ B relief, minus any retirement distribution you already received) will be reduced by a total of 17.5%. For example, a $50 monthly benefit increase will be reduced by $8.75 to $41.25 to account for the attorneys fees and incentive awards. The reduction for fees will only apply to any benefit increase to which you are entitled as a result of this lawsuit, not to any benefits you already had. The attorneys for the Plaintiff class are also seeking reimbursement in the amount of $990,689 directly from CIGNA for the out-of-pocket costs of prosecuting this lawsuit over 14 years, including expert witness fees, and the future expenses of notifying the class, verifying addresses, locating survivors of deceased participants, and monitoring CIGNA s implementation of the A+B relief. Your Right to Object or Comment If you wish to object or comment on the requests by the attorneys for the Plaintiff class for attorneys fees and incentive awards from the common fund recovery, please send your objections or comments to: Clerk of the Court, P.O. Box 506, New Haven, CT 06502. The letter must be post-marked no later than September 24, 2015. The Court will consider any objections or comments before making its final decision. Complete Address Verification Form to Ensure Receipt of Benefit Increase Whether or not you object or comment, if you are eligible to receive a retirement benefit increase as a result of this litigation, you will receive a future notice about how to obtain your increased benefit. Attached to this Notice is an Address Verification Form to confirm or update your current address to ensure that you receive the future notice about how to obtain your increased retirement benefit. Please complete the Address Verification Form as soon as possible and return it in the enclosed prepaid envelope. If you are the surviving spouse or beneficiary of a deceased former CIGNA employee, please fill your name, address, and relationship to the deceased former CIGNA employee. Additional Information If you have questions or concerns, please call 1-888-886-6487 or contact the lead counsel for the Plaintiff class, Stephen R. Bruce, by email to MyCignaPension@verizon.net or mail to Stephen R. Bruce Law Offices, 1667 K Street,

NW, Suite 410, Washington DC 20006. A website at www.mycignapension.com includes this Notice and answers to frequently-asked questions. This Notice is authorized by the United States District Court for the District of Connecticut, Hon. Janet Bond Arterton, United States District Judge.

ADDRESS VERIFICATION FORM *P-CIA$F-POC/1* Dear Participant: You are a current or former employee of CIGNA Corp. who is entitled to an increased retirement benefit from the CIGNA Pension Plan as a result of the Amara v. CIGNA class action lawsuit. It is very important that you confirm or update your address to ensure that you receive future notices about the payment of these retirement benefits. Please confirm or update your address in the space below and mail this form in the enclosed pre-paid envelope to: Garden City Group, LLC, P.O. Box 10234, Dublin, OH 43017-9977. The information you provide will be strictly confidential, but will confirm that you have been located. - - - - - - - (Please complete portion below) - - - - - - - Check One or More The name and address information at AD the right is correct. DR ESS The name or address as printed at the VE AD right is incorrect. I have made changes to RIF DR correct the information in the box. ICA ESS TIO VE If addressee is deceased, please supply NRIF spouse or beneficiary information below: FO ICA RM TIO Date of death of former CIGNA employee: N FO RM Beneficiary s name: Relationship: Control Number: Name or address corrections: