STATE OF MAINE
DEPARTMENT OF PROFESSIONAL AND FINANCIAL REGULATION
BUREAU OF INSURANCE
| IN RE: APPLICATION OF ASSOCIATED HOSPITAL
SERVICE OF MAINE, d/b/a BLUE CROSS AND BLUE SHIELD OF MAINE, TO CONVERT TO A STOCK INSURER
AND VOLUNTARILY LIQUIDATE AND DISSOLVE |
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IN RE: APPLICATION OF ANTHEM
HEALTH PLAN OF MAINE, INC.,
TO ACQUIRE THE ASSETS OF ASSOCIATED HOSPITAL SERVICE OF MAINE, d/b/a BLUE CROSS AND BLUE
SHIELD OF MAINE, AND RELATED TRANSACTIONS Docket NO. INS 99-14 (CONSOLIDATED) |
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ANTHEM INSURANCE COMPANIES,
INC.’S OBJECTIONS TO FIRST DISCOVERY REQUEST OF THE CONSUMER INTERVENORS
February 9, 2000 |
On Monday January 31, 2000, the Consumer Intervenors served on Applicants their First
Discovery Request (the "Request"), consisting of 45 requests for information and
documents. Counsel for Anthem, BCBSME and the CAHC had one conference on Monday, February
7th to discuss the Request, but were unable to get through all of the questions
due to scheduling conflicts. A follow up conference is being scheduled and Anthem will
advise the Superintendent of any additional agreements reached for response to the Request.
Per agreement of counsel, Anthem and BCBSME agreed to file their respective objections to
the Request on or before February 9th with a supporting memorandum to be filed
on or before February 14th. Thus, although the parties’ discussions are
ongoing and some of the objections ultimately may be resolved, Anthem hereby makes the
following objections to the First Discovery Request of the Consumer Intervenors:
I. Definitions and Instructions
- Paragraph A of the Definitions and Instructions provides:
"Anthem" means Anthem Insurance Companies, Inc., including each
predecessor-in-interest, and its present or former officers, directors, consultants,
employees, agents, representatives, counsel, and all persons and entities acting or
purporting to act on its behalf or under its control, and each and every subsidiary,
affiliate or parent of Anthem Insurance Companies, Inc. wherever located including but not
limited to those located in Colorado/Nevada, Connecticut, Kentucky, New Hampshire, and
Ohio, unless otherwise noted in the specific request. This definition of
"Anthem" shall include Anthem East, Inc. and Anthem Health Plans of Maine.
Objections: The instructions are overly broad, unduly burdensome, and seek irrelevant
information.
- Paragraph C of the Definitions and Instructions provides:
"BCBSME " means Associated Hospital Service of Maine including each
predecessor-in-interest, and its present or former officers, directors, consultants,
employees, agents, representatives, counsel, and all persons and entities acting or
purporting to act on its behalf or under its control, and each and every subsidiary,
affiliate or parent of Associated Hospital Service of Maine unless otherwise noted in the
specific request.
Objections: The instructions are overly broad, unduly burdensome, and seek irrelevant
information.
- Paragraph L of the Definitions and Instructions provides:
If a request is made for production or identification of documents which are no longer
in the possession or subject to the control of the Applicants, state when such documents
were most recently in the possession of or subject to the control of the Applicants and
what disposition was made of them, including an identification of the person presently in
possession or control of such documents. If the documents have been destroyed, identify
the person who destroyed the documents, the person who directed that the documents be
destroyed, state the reason(s) the documents were destroyed, and the date and manner of
their destruction.
Objections: The instructions are unduly burdensome.
- Paragraph M of the Definitions and Instructions provides:
When a request seeks documents or things from a corporate entity, such corporate entity
includes its present and former directors, officers, employees, representatives, agents,
consultants, contractors, legal counsel and all persons or entities acting or purporting
to act on its behalf or under its control.
Objections: The instructions are overly broad and unduly burdensome.
- Paragraph N requires specific information if/when Anthem claims a privilege in any
response. If Anthem objects to any request on the basis of privilege, it will provide a
privilege log identifying the privileged documents and objects to the instruction
requiring "the name and employment at the time of viewing of each person who has seen
the document."
II. Attorney Client / Work Product Privilege
Counsel have not yet had an opportunity to review all of the documents that will be
responsive to the Request. To prevent inadvertent disclosure of privileged materials,
Anthem objects to every request to the extent it calls for production of information or
documents subject to attorney-client or work product privileges. Anthem will identify the
privileged documents and, at the time of the responsive filing, provide a more specific
objection.
III. Relevance / Scope / Burdensome
- Please provide all documents prepared by or for the Blue Cross and Blue Shield
Association and its predecessors relating to its rules, practices, policies, procedures,
Articles of Incorporation, and bylaws of the said Association.
Objections:
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The request seeks information that is
irrelevant to this proceeding; it is overly broad; and it would be overly burdensome to
produce and/or obtain the requested information. After consultation with counsel for
CAHC, the Consumer Intervenors have agreed to reconsider the wording of the question and
type of information they are seeking. |
- Please provide all documents prepared by or for the Blue Cross and Blue Shield
Association and its predecessors related to a licensee and/or member:
- operating on a for-profit basis;
- operating as a mutual insurer; and/or c) acquiring, merging or
affiliating with other licensees and/or members.
Objections:
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The request seeks information that is
irrelevant to this proceeding; it is overly broad; and it would be overly burdensome to
produce and/or obtain the requested information. After consultation with counsel for
CAHC, the Consumer Intervenors have agreed to reconsider the wording of the question and
type of information they are seeking. |
- Please provide all documents prepared by or for the Blue Cross and Blue Shield
Association and its predecessors related to the decision by the Association to allow its
members to operate on a for-profit basis and/or to purchase another member.
Objections:
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The request seeks information that is
irrelevant to this proceeding; it is overly broad; and it would be overly burdensome to
produce and/or obtain the requested information. After consultation with counsel for
CAHC, the Consumer Intervenors have agreed to reconsider the wording of the question and
type of information they are seeking. |
- Please provide all documents prepared by or for the Blue Cross and Blue Shield
Association and its predecessors related to competition among or between members and/or
licensees in or for the same service area or market.
Objections:
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The request seeks information that is
irrelevant to this proceeding; it is overly broad; and it would be overly burdensome to
produce and/or obtain the requested information. After consultation with counsel for
CAHC, the Consumer Intervenors have agreed to reconsider the wording of the question and
type of information they are seeking. |
- Please provide all documents prepared by or for Anthem related to competition between
Anthem and members and/or licensees of the Blue Cross and Blue Shield Association in or
for the same service area or market.
Objections:
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The request seeks information that is
irrelevant to this proceeding; it is overly broad; and it would be overly burdensome to
produce and/or obtain the requested information. After consultation with counsel for
CAHC, the Consumer Intervenors have agreed to reconsider the wording of the question and
type of information they are seeking. |
- Please provide all documents prepared by or for the applicants related to purchasing any
interest in Harvard Pilgrim Community Health Plans. Please describe in detail any and all
discussions and/or communications by Anthem with Harvard Pilgrim Community Health Plans or
its representatives and/or with any governmental agency having jurisdiction over Harvard
Pilgrim Community Health Plans.
Objections:
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The request seeks information that is
irrelevant to this proceeding; it is overly broad; and it would be overly burdensome to
produce and/or obtain the requested information. |
- Please provide all documents between the applicants relating to the status of or
requirements on BCBSME to maintain its good standing, membership, trademarks and licenses
in and with the Blue Cross and Blue Shield Association from January 1998 to date.
Objections:
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The request seeks information that is
irrelevant to this proceeding; it is overly broad; and it would be overly burdensome to
produce and/or obtain the requested information. After consultation with counsel for
CAHC, subject to and without waiving these objections, Anthem will refer to the relevant
sections of the Asset Purchase Agreement and produce whatever "watch list"
information it received prior to entering into the APA. |
- Is there any correlation between the sale price and premiums to be charged by Anthem?
Please state all assumptions underlying the correlation. Please quantify in dollars the
effect that increasing the sale price may have on premiums for each million dollars that
the price is increased over and above the total consideration stated in the Asset Purchase
Agreement dated July 13, 1999.
Objections:
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The request seeks information that is
irrelevant to this proceeding; it is overly broad; and it would be overly burdensome to
produce and/or obtain the requested information. After consultation with counsel for
CAHC, Anthem will answer the first 2 parts of the question and the Consumer Intervenors
have agreed to strike the final part of the question. |
- Please provide all documents prepared by or for Anthem related to the preparation of the
attached Anthem policyholder notice in Kentucky (see Attachment "A").
Objections:
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The request seeks information that is
irrelevant to this proceeding; it is overly broad; and it would be overly burdensome to
produce and/or obtain the requested information. |
- Please provide a chart that describes in detail all Anthem purchases of BCBS plans
anywhere in the United States from 1993 to date and provide a schedule of premiums for
each and every product offered by the seller during the 24 month period prior to the sale
and by Anthem in the 24 month period subsequent to the sale. In states where Anthem has
less than one year of premium experience, such as New Hampshire and Colorado/Nevada,
please state the premiums currently in place and the premiums that Anthem has sought or
will seek in the next six months for each and every product offered.
Objections:
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The request seeks information that is
irrelevant to this proceeding; it is overly broad; it would be overly burdensome to
produce and/or obtain the requested information and Anthem is under no obligation to
prepare additional analyses in response to information requests from intervenors. |
- For each purchase identified in response to question number 13, please provide a chart
that describes in detail each and every: a) product added and/or dropped; b) increase or
decrease in coinsurance rates and/or copayment amounts by item or service and by product;
c) increase or decrease in lifetime and/or annual benefit amounts or payments by product;
and d) increase or decrease in benefits and/or coverage levels by item or service and by
product, for the first 24 months after the purchase. In states where Anthem has less than
one year of experience, such as New Hampshire and Colorado/Nevada, please provide the
above information as it is currently in effect and any proposed modifications Anthem has
sought or will seek in the next six months for each and every product offered.
Objections:
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The request seeks information that is
irrelevant to this proceeding; it is overly broad; it would be overly burdensome to
produce and/or obtain the requested information and Anthem is under no obligation to
prepare additional analyses in response to information requests from intervenors. |
- Please provide all documents related to Anthem’s plans to gain marketshare in New
England from January 1997 to the present. Please provide all documents prepared by or for
Anthem related to the desirability to be in the New England market.
Objections:
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To the extent the request seeks information
beyond the integration plans already produced in response to the Attorney General’s
discovery requests, the request seeks information that is irrelevant to this proceeding;
it is overly broad; and it would be overly burdensome to produce and/or obtain the
requested information. |
- Please provide all documents prepared by or for Anthem and/or BCBSME from January 1998
to the present related to the financial condition of competitors of Blue Cross and Blue
Shield plans in Connecticut, Maine, New Hampshire, Rhode Island and Massachusetts.
Objections:
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The request seeks information that is
irrelevant to this proceeding; it is overly broad; and it would be overly burdensome to
produce and/or obtain the requested information After consultation with counsel for
CAHC, the Consumer Intervenors have agreed to limit the scope of the question to Maine and
Massachusetts. Anthem maintains its objections to producing the requested documents. |
- Please provide all documents prepared by or for Anthem related to demutualization from
1995 to date.
Objections: |
The request seeks information that is
irrelevant to this proceeding and it is overly broad. |
- Please provide all documents prepared by or for Anthem Insurance Companies, Inc. of
Indiana related to the positive or negative effects a demutualization of Anthem Insurance
Companies, Inc. of Indiana would have on insureds in Maine and any other state in which
Anthem operates. Please describe in detail what persons would receive stock, dividends,
assets, or anything of value and in what proportions if Anthem Insurance Companies, Inc.
of Indiana were to demutualize under current Indiana law. Please provide all documents
prepared by or for Anthem Insurance Companies, Inc. of Indiana related to lobbying efforts
by Anthem Insurance Companies, Inc. of Indiana in connection with the passage of Senate
Bill 33, affecting Indiana Code sections 27-9-1, et seq.
Objections: |
The request seeks information that is
irrelevant to this proceeding and it is overly broad. |
- Please provide all documents related to Anthem’s description of itself as a
"for profit mutual" or its operations as "for profit" from 1990 to
date.
Objections:
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The request seeks information that is
irrelevant to this proceeding; it is overly broad; and it would be overly burdensome to
produce and/or obtain the requested information. After consultation with counsel for
CAHC, subject to and without waiving these objections, Anthem will provide a limited
narrative response. |
- Please describe the applicants’ efforts or plans to gain marketshare in each state
or jurisdiction with regard to products such as life, health, disability or administrative
services from January 1997 to the present.
Objections: |
The request seeks information that is
irrelevant to this proceeding; it is overly broad; and it would be overly burdensome to
respond. |
- Please provide a chart that describes in detail the medical underwriting practices
and/or criteria used by the applicants by product and by item or service. Please include
in the chart all waiting periods, exclusions of services and items, exclusionary periods,
rate and rating variations which are dependent on age, sex, health status and medical
condition, used or in effect for each of the calendar years 1997, 1998, 1999 and 2000.
Objections:
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The request seeks information that is
irrelevant to this proceeding; it is overly broad; it would be overly burdensome to
produce and/or obtain the requested information and Anthem is under no obligation to
prepare additional analyses in response to information requests from intervenors. After
consultation with counsel for CAHC, the Consumer Intervenors have agreed to limit the
scope of the question to Indiana and Connecticut for 1998 & 1999 only. Anthem
maintains its objections to producing the requested documents. |
- Please provide the number and rate of prior authorization requests made from January
1998 to the present to the applicants. Please also include in the response, the number and
rate of prior authorization requests reversed on appeal for the same period. Please also
estimate the dollar value of those services authorized as a result of appeals during that
same time period.
Objections:
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The request seeks information that is
irrelevant to this proceeding; it is overly broad; and it would be overly burdensome to
produce and/or obtain the requested information. |
- Please provide a schedule of the five procedures and/or services most frequently denied
by the applicants from January 1998 to date. Please provide an estimated dollar value per
procedure or service.
Objections:
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The request seeks information that is
irrelevant to this proceeding; it is overly broad; and it would be overly burdensome to
produce and/or obtain the requested information. |
- Please provide all documents related to the rapid disenrollment rates (i.e.,
disenrollment within six months of enrollment) for Anthem’s Medicare HMO products.
Objections:
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The request seeks information that is
irrelevant to this proceeding; it is overly broad; and it would be overly burdensome to
produce and/or obtain the requested information. After consultation with counsel for
CAHC, subject to and without waiving these objections, Anthem will consider providing a
limited narrative response. |
- In which states did Anthem offer Medicare HMO and/or Medicaid HMO products from January
1997 to date? Has Anthem terminated or proposed to terminate any such product offering in
any state during that period? Please state which product(s) and in which state(s) such
termination or proposed termination has occurred or may occur. If Anthem intends to offer
a Medicare HMO product and/or a Medicaid HMO product in any state, please identify which
state, which product(s), and when the product(s) will be offered.
Objections:
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The request seeks information that is
irrelevant to this proceeding; it is overly broad; and it would be overly burdensome to
produce and/or obtain the requested information. |
- Please provide all documents related to prescription drug formulary or formularies used
by the applicants for each product offered. Please describe in detail the formulary
development, evaluation and/or review process(es) used by the applicants?
Objections:
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The request seeks information that is
irrelevant to this proceeding; it is overly broad; and it would be overly burdensome to
produce and/or obtain the requested information. After consultation with counsel for
CAHC, subject to and without waiving these objections, Anthem will provide the formulary
and describe the makeup of the committee charged with developing the formulary. |
- During calendar years 1998 and 1999, please state how many of the applicants’
insureds were insured or covered on a secondary basis by another health insurance plan
– private or public?
Objections:
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The request seeks information that is
irrelevant to this proceeding; it is overly broad; and it would be overly burdensome to
produce and/or obtain the requested information. After consultation with counsel for
CAHC, the Consumer Intervenors have limited the scope of this question to Connecticut
only. Anthem maintains its objections, but is reviewing this question. |
- Has Anthem terminated or proposed to terminate non-group product offerings in any state
during calendar year 1998, 1999 or 2000? If yes, please specify in which state and when
such termination was or will be effective. For each non-group product termination, state
how much time in days insureds were given as notice of termination. Please provide a
sample of the notice for each non-group product termination.
Objections:
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The request seeks information that is
irrelevant to this proceeding; it is overly broad; and it would be overly burdensome to
produce and/or obtain the requested information. After consultation with counsel for
CAHC, subject to and without waiving these objections, Anthem will provide a limited
narrative response. |
- In which state(s) does Anthem impose or anticipate imposing waiting or exclusionary
periods for prescription drugs, durable medical equipment or supplies, and mental health
services? Please provide all documents related to the waiting or exclusionary period(s)
for each of these items and services.
Objections:
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The request seeks information that is
irrelevant to this proceeding; it is overly broad; and it would be overly burdensome to
produce and/or obtain the requested information. After consultation with counsel for
CAHC, subject to and without waiving these objections, Anthem will provide a limited
narrative response. |
COUNSEL FOR THE PARTIES WERE UNABLE TO DISCUSS THE FOLLOWING OBJECTIONS DUE TO
SCHEDULING CONFLICTS. COUNSEL ARE RESCHEDULING A TIME TO CONTINUE DISCUSSING THESE
QUESTIONS.
- Please provide a list with the names, addresses and phone numbers of the pharmaceutical
benefits manager(s), the durable medical equipment or supply manager(s), and the mental
health benefits manager(s) which administer the applicants’ prescription drug,
durable medical equipment and supplies, and/or mental health benefit programs. Please
state the termination dates for contracts with all such managers. Please state which
manager(s) Anthem intends to employ in Maine during calendar years 2000, 2001 and 2002.
Objections:
|
The request seeks information that is
irrelevant to this proceeding; it is overly broad; and it would be overly burdensome to
produce and/or obtain the requested information. Subject to and without waiving these
objections, Anthem will consider providing a limited narrative response. |
- Please provide a list with the names, addresses and phone numbers of the independent
review organizations (IROs) with which Anthem and BCBSME have contracted and/or intend to
contract during the calendar years 1998, 1999, and 2000. Please provide the total number
of appeals made to each of these IROs during the calendar years 1998 and 1999. How many
appeals were denied in each of those years? Provide a redacted copy of a decision by each
of the identified IROs for each of the calendar years 1998 and 1999.
Objections:
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The request seeks information that is
irrelevant to this proceeding; it is overly broad; and it would be overly burdensome to
produce and/or obtain the requested information. |
- Provide all documents prepared by or for Anthem and BCBSME which define or provide
definitions of the terms "medical necessity", "medically necessary",
"short term therapy", "case management", "experimental
treatment", "clinical trial" and "emergency" in effect during the
calendar year 1999 for each state in which Anthem operates.
Objections:
|
The request seeks information that is
irrelevant to this proceeding; it is overly broad; and it would be overly burdensome to
produce and/or obtain the requested information. Subject to and without waiving these
objections, Anthem will consider providing a limited narrative response. |
- How many of the applicants’ insureds have requested case management services for
each of the calendar years 1998 and 1999? How many of the applicants’ insureds have
received case management services for 30 or fewer days, 31 – 60 days, 61 - 90 days,
and more than 90 days during each of those two years?
Objections: |
The request seeks information that is
irrelevant to this proceeding; it is overly broad; and it would be overly burdensome to
produce and/or obtain the requested information. |
- Please provide all documents prepared by or for the applicants related to criteria used
or in effect for the purpose of determining whether someone qualifies and/or continues to
qualify for case management services for each of the calendar years 1998 and 1999. Please
provide the aggregate number of case management services requested and the aggregate
number of case management services denied by the applicants during those two years. How
many of those denials were appealed to the applicants? How many were reversed on appeal by
the applicants? Please provide one redacted copy of an Anthem decision and one redacted
copy of a BCBSME decision denying case management services for each of the calendars years
1998 and 1999.
Objections:
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The request seeks information that is
irrelevant to this proceeding; it is overly broad; and it would be overly burdensome to
produce and/or obtain the requested information. |
- Please provide all documents used by the applicants for the purpose(s) of identifying
and/or subrogating costs to other insurers or coverage sources – public or private.
Objections:
|
The request seeks information that is
irrelevant to this proceeding; it is overly broad; and it would be overly burdensome to
produce and/or obtain the requested information. Subject to and without waiving these
objections, Anthem will consider providing a limited narrative response. |
- Please state in detail the applicants’ practices and/or policies as primary and/or
secondary payer where the insured is also covered by Medicare and/or Medicaid.
Objections:
|
The request seeks information that is
irrelevant to this proceeding; it is overly broad; and it would be overly burdensome to
produce and/or obtain the requested information. Subject to and without waiving these
objections, Anthem will consider providing a limited narrative response. |
- Please provide the applicants’ complaint ratios for the calendar years 1998 and
1999 and the methodologies for calculating such ratios. Please provide a detailed
explanation where the ratio for complaints exceeds marketshare during that time period.
Objections:
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In response to question no. 7 of the Attorney
General’s Second Discovery Request, Anthem provided the complaint ratios for
Kentucky, Indiana, Connecticut and Ohio. See also Document Numbers AN-02568
to AN-02575. To the extent the request seeks information beyond that
already provided in response to the Attorney General’s discovery requests, the
request seeks information that is irrelevant to this proceeding; it is overly broad; and
it would be overly burdensome to produce and/or obtain the requested information. |
- Please provide all documents used by the applicants which state the criteria for
covering experimental treatment or transplants services?
Objections:
|
The request seeks information that is
irrelevant to this proceeding; it is overly broad; and it would be overly burdensome to
produce and/or obtain the requested information. Subject to and without waiving these
objections, Anthem will provide a limited narrative response. |
- Please provide a chart that describes in detail the total amount of consideration paid
by Anthem for Blue Cross and Blue Shield plans in New Hampshire, Connecticut, Ohio,
Kentucky, and Colorado/Nevada. Please include in your response the date of closing for
each sale and the total number of insureds for each plan on the closing date. For each of
these purchases, please describe in detail any and all increases in the total amount of
consideration paid over and above the total amount of consideration stated in the Asset
Purchase Agreement or Purchase and Sale Agreement for that particular purchase. Please
describe in detail each and every reduction and/or downward adjustment ordered or agreed
to by Anthem to the total amount of consideration stated in the Asset Purchase Agreement
or Purchase and Sale Agreement for that particular purchase.
Objections:
|
The request seeks information that is
irrelevant to this proceeding; it is overly broad; it would be overly burdensome to
produce and/or obtain the requested information and Anthem is under no obligation to
prepare additional analyses in response to information requests from intervenors. Subject
to and without waiving these objections, Anthem will provide a limited narrative response. |
- Please provide a list of all lawsuits or litigation initiated against Anthem by name,
court, jurisdiction and state where filed from January 1997 to the present where the total
amount of damages and/or benefits sought and attorneys fees exceeds or may exceed
$1,000,000. Please provide a detailed description of the nature of the litigation and the
amount entered in judgment against and/or agreed to in settlement of such litigation.
Objections:
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In response to question no. 57 of the
Superintendent’s Second Discovery Request, Anthem provided information on all cases
with a reserve greater than $250,000. See Confidential Version of Anthem’s First
Supplement to Response to Superintendent’s Second Discovery Request, confidential
document numbers AN- 01969 to AN-01985. To the extent the request
seeks information beyond that already provided in response to the Superintendent’s
discovery requests, the request seeks information that is irrelevant to this proceeding;
it is overly broad; and it would be overly burdensome to produce and/or obtain the
requested information. |
DATED: February 9, 2000
_____________________________
James B. Zimpritch, Esq.
Jeffrey M. White, Esq.
Catherine R. Connors, Esq.
PIERCE ATWOOD
One Monument Square
Portland, Maine 04101
(207) 791-1100
Attorneys for Anthem Insurance Companies, Inc
CERTIFICATE OF SERVICE
The undersigned hereby certifies that on February 9, 2000 a copy of Anthem Insurance
Companies, Inc.’s Objections to the First Discovery Request of the Consumer
Intervenors was served by United States mail, first class postage prepaid, or, where
indicated, by hand delivery, on each of the persons listed below.
Robert S. Frank, Esq.
Harvey & Frank
Two City Center
P.O. Box 126
Portland, Maine 04112
e-mail: frank@harveyfrank.com
(Blue Cross/Blue Shield of Maine)
Judith Chamberlain, Esq.
State of Maine
Department of the Attorney General
6 State House Station
Augusta, Maine 04333-0006
e-mail: judy.chamberlain@state.me.us
(Bureau of Insurance)
William H. Laubenstein, Esq.
State of Maine
Department of the Attorney General
6 State House Station
Augusta, Maine 04333-0006
e-mail: bill.laubenstein@state.me.us
(Office of the Attorney General)
Gregory A. Brodek, Esq.
Duane, Morris & Heckscher, LLP
15 Columbia Street, 4th Floor
Bangor, Maine 04401-6355
e-mail: gabrodek@duanemorris.com
(Maine Health Alliance)
Joseph P. Ditre, Esq.
Consumer Health Law Program
One Weston Court, Level One
P.O. Box 2490
Augusta, Maine 04338-2490
e-mail: jditre@mainecahc.org
(Consumers for Affordable Health Care Foundation/Coalition)
Michele M. Garvin, Esq.
Ropes & Gray
One International Place
Boston, Massachusetts 02110-2624
e-mail: Mgarvin@Ropesgray.com
(Central Maine Healthcare Corporation; Central Maine Partners Health Plan)
Robert I. Goldman
Maine Council of Senior Citizens
27 Bowery Beach Road
Cape Elizabeth, Maine 04107
e-mail: Rgoldma1@maine.rr.com
(Maine Council of Senior Citizens)
Bonnie Post
Executive Director of the Maine Ambulatory Care Coalition
P.O. Box 390
Manchester, Maine 04351
e-mail: bdpmacc@mint.net
(Sacopee Valley Health Center, Regional Medical Center at Lubec, Eastport Health Care,
Inc., and the Maine Ambulatory Care Coalition)
John Dieffenbacher-Krall
Executive Director
Maine People’s Alliance
192 State Street
Portland, Maine 04101
e-mail: MPA@gwi.net
(Maine People’s Alliance)
Gordon H. Smith, Esq.
Maine Medical Association
30 Association Drive
P.O. Box 190
Manchester, Maine 04351
e-mail: gsmith@ctel.net
(Thomas D. Hayward, M.D.,
Maroulla S. Gleaton, M.D.,
And the Maine Medical Association)
Donald E. Quigley, Esq.
General Counsel
465 Congress Street, Suite 600
Portland, Maine 04101-3537
e-mail: quigld@mail.mmc.org
(Maine Medical Center)
Sandra L. Parker, Esq.
Attorney for MHA, Inc.
150 Capitol Street
Augusta, Maine 04330
e-mail: sparker@themha.org
(MHA, Inc.)
Kellie P. Miller, M.S.
Executive Director
Maine Osteopathic Association
693 Western Avenue
Manchester, Maine 04351
e-mail: meosteo@mint.net
(Maine Osteopathic Association)
Edward Miller
Executive Director
American Lung Association of Maine
122 State Street
Augusta, Maine 04330
e-mail: emiller@mainelung.org
(American Lung Association of Maine)
DATED: February 9, 2000
_____________________________
James B. Zimpritch, Esq.
Jeffrey M. White, Esq.
Catherine R. Connors, Esq.
PIERCE ATWOOD
One Monument Square
Portland, Maine 04101
(207) 791-1100
Attorneys for Anthem Insurance Companies, Inc.
Last Updated:
November 18, 2009
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