Free Order on Motion for Protective Order - District Court of Connecticut - Connecticut

"`F A _ "`'``` I Case 3:00-cv-O10@-AVC Document 126 Filed Ogg?/2004 Page 1 of 1
UNITED STATES DISTRICT COURT F 9 n
DISTRICT OF CONNECTICUT ‘f‘·" l--*‘~
MARY CARR, et af. : CIVIL ACTION NGUUU E i '] [D 3; I 8
Plaint@s : 3:00 CV 1050 (AWT) M
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PATRICIA WILSON-COKER, in her
official capacity as Commissioner ofthe : FEBRUARY 6, 2004 4
State of Connecticut Department of Social : l
Services, : I
· Defendant : __
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Q JOINT MOTION FOR A STIPULATED PROTECTIVE ORDER [BENECAREI
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2 WHEREAS, the plaintiffs have brought the above—titled action against the defendant l l
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ff, Patricia Wilson—Coker to challenge alleged violations of their rights to access to dental health
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H gi care under the federal Medicaid Act; and
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§ ii WHEREAS, the plaintiffs are certified under Rule 23 of the Federal Rules of Civil F
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g M Procedure as a class consisting of all individuals in Connecticut who are or will be eligible for
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gi E, Medicaid managed care HUSKY A beneiits, and are or will be seeking dental health services;
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"' lg WHEREAS, a subclass has also been certified consisting of all children in Connecticut
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Fg m who are now or will be under the age of 21, are or will be seeking dental health services, and are
g or will be eligible for Medicaid managed care HU SKY A benefits; and
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Jig WHEREAS, the plaintiffs have sought production of documents related to the
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E I defendant’s proposed "carve—out’” of dental services from Medicaid managed care, including `
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ig I °1 proposals of bidders in response to a Request for Proposals that was issued by the Department of
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.9; U I ,5 Sgcial Services and the Office of the State Comptroller (hereinafter "RFP"); and
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