MEMORANDUM
BARTLE, District Judge.
These are actions alleging violations of the Employee Retirement Income Security Act ("ERISA"), 29 U.S.C. § 1001 et seq. Before the court are motions to amend each complaint to add a claim for punitive damages under Pennsylvania's bad faith statute, 42 Pa.Cons.Stat.Ann. § 8371.
Plaintiffs are employees of defendant Lincoln Technical Institute, Inc. They are participants in an employee welfare benefit...
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