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

· ,./f Case 3:00-cv-O1050—AVC Document 124 Filed O3/27/2004 Page 1 of 1
l UNITED STATES DISTRICT COURT g i
DISTRICT OF CONNECTICUT I A H ` i
MARY CARR, et al. I CIVIL i nil;) BT I q i
g Plaint%v : 3:00 CV 1050 *, g/' p
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PATRICIA WILSON-COKER, in her
official capacity as Commissioner ofthe : FEBRUARY 6, 2004
State of Connecticut Department of Social : i
Services, : _ l
. Defendant : '
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rg JOINT MOTION FOR A STIPULATED PROTECTIVE ORDER DORAL
3 WHEREAS, the plaintiffs have brought the above-titled action against the defendant
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Patricia Wilson-Coker to challenge alleged violations of their rights to access to dental health
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_ § care under the federal Medicaid Act; and
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§ Q WHEREAS, the plaintiffs are certified under Rule 23 of the Federal Rules of Civil
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Q U Medicaid managed care HUSKY A benefits, and are or will be seeking dental health services;
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5 Q WHEREAS, a subclass has also been certified consisting of all children in Connecticut
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8 who are now or will be under the age of 21,, are or will be seeking dental health services, and are i
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or will be eligible for Medicaid managed care HUSKY A benefits; and
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*5) WHEREAS, the plaintiffs have sought production of documents related to the
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rg g ri defendant’s proposed "carve-out" of dental services from Medicaid managed care, including
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g V C5 goposals of bidders in response to a Request for Proposals that was issued by the Department of [
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