Case: 2:14-cv-01458-ALM-EPD Doc #: 6 Filed: 11/10/14 Page: 1 of 5 PAGEID #: 17
IN THE UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF OHIO EASTERN DIVISION BLYS GRAD,
) ) Plaintiff, ) ) vs. ) ) ABBOTT LABORATORIES and MATRIX ) ABSENCE MANAGEMENT, ) ) Defendants. )
Case No. 2:14-cv-01458-ALM-EPD Judge Algenon L. Marbley Magistrate Judge Elizabeth Preston Deavers
ANSWER TO COMPLAINT Defendants ABBOTT LABORATORIES and MATRIX ABSENCE MANAGEMENT hereby answer Plaintiff’s complaint as follows: 1.
Defendants admit that Matrix is the claims administrator for the Abbott
Laboratories Extended Disability Plan (“EDP”) and that Plaintiff made a claim under the EDP. Defendants deny the remaining allegations of Paragraph 1. 2.
Defendants admit that Plaintiff was employed by Abbott at the time she made a
claim under the EDP, but deny that Abbott was the plan administrator of the EDP and deny the remaining allegations of Paragraph 2. 3.
Defendants admit that Plaintiff was employed by Abbott and resided in Delaware
County at the time she made a claim under the EDP. Defendants lack knowledge or information sufficient to form a belief as to the truth of the remaining allegations of Paragraph 3 and, therefore, deny same. 4.
Defendants admit that Plaintiff was eligible to apply for benefits under the EDP
and that the EDP was first amended as of January 1, 2004 and its second amendment was
Ex. M, p. 1