

9 After negotiations between Wolff and Rawlings, Wolff agreed to reimburse Aetna and Rawlings $30,000. 8 Aetna and another entity with which it worked, the Rawlings Company ("Rawlings"), sought reimbursement of the benefits that Aetna had paid to Wolff under the terms of the Plan, despite the Plan allegedly not permitting such reimbursement. 7 Wolff and the defendant eventually settled the matter, with Wolff receiving monetary compensation from the defendant in that matter. Wolff separately filed a civil action against the other party involved in the accident.

5 Wolff submitted a claim to Aetna under the Plan and received long-term disability benefits exceeding $50,000. 4 In September 2015, Wolff was temporarily disabled as a result of a motor vehicle accident that caused Wolff injuries. Wolff avers that she was previously insured for long-term disability benefits under the terms of a group plan (the "Plan") issued by Aetna through Bank of America Corporation-Wolff's employer. In 2020, Joanne Wolff, on behalf of herself on all similarly situated individuals, filed a second amended complaint 1 against Aetna Life Insurance Company ("Aetna") raising claims for: a violation of the Employee Retirement Income Security Act of 1974 ("ERISA"), 2 breaches of fiduciary duties, conversion, money had and received, intentional misrepresentation, negligent misrepresentation, unjust enrichment, theft by deception, attempted theft, a violation of Pennsylvania's Unfair Trade Practices and Consumer Protection Law, and a violation of the Pennsylvania Fair Credit Extension Uniformity Act.
