Free Motion for Leave to File - District Court of Federal Claims - federal

Case 1:01-cv-00517-MBH

Document 44

Filed 12/06/2005

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS

GHS HEALTH MAINTENANCE ORGANIZATION, INC. d/b/a BlueLincs HMO, Plaintiff, TEXAS HEALTH CHOICE, L.C., Plaintiff, SCOTT & WHITE HEALTH PLAN Plaintiff, v. THE UNITED STATES, Defendant.

) ) ) ) ) No. 01-517C, 05-371C, 05-963C ) (Judge Horn) ) ) ) ) ) ) ) ) ) ) ) )

UNOPPOSED MOTION TO FILE SUPPLEMENTAL APPENDIX MATERIALS Defendant respectfully requests that this Court permit defendant to file supplemental materials in the appendix relating to GHS Health Maintenance Organization, Inc., d/b/a BlueLincs HMO (Bluelincs), and also supplemental materials in the appendix relating to Scott and White Health Plan. Counsel for plaintiffs Bluelincs and Scott and White consent to this motion.

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Case 1:01-cv-00517-MBH

Document 44

Filed 12/06/2005

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GHS Health Maintenance Organization PDF File Number 5 - "GHS Supp. 5" In the original appendix, filed on October 24, 2005, one document in PDF file number 5

contained the odd-numbered, but not the even-numbered pages, of the document. We provide a complete copy of the document, with all the pages, in this revised appendix. Because this case is subject to electronic filing, and because the appendix is voluminous (with 16 PDF files for the appendix), and given the Court's limit on the size of PDF filings, we simply inserted the new pages of the document, between pages 89 to 96a, in one of the PDF files, number 5. Therefore, this revised, supplemental PDF file number 5 replaces in full the previously-filed PDF 5. PDF File Number 20 In addition, we submit two additional documents, in PDF file number GHS 20: Letter, April 26, 2000, from BlueLincs to OPM, App. 528-29; Letter, May 2, 2000, from BlueLincs to OPM, App. 530-31. 2. Scott and White Health Plan The appendix in Scott and White should include a declaration from Ms. Nancy Kichak, Director, Office of Actuaries. This declaration was filed in the briefing in the case that Scott and White filed in the United States District Court for the District of Columbia, that was transferred to this Court. The declaration will be PDF number 13, and begins at page 319 of the appendix.

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Case 1:01-cv-00517-MBH

Document 44

Filed 12/06/2005

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Conclusion Accordingly, defendant respectfully requests that this Court permit defendant to file supplemental materials in the appendix relating to GHS Health Maintenance Organization, Inc., d/b/a BlueLincs HMO (Bluelincs), and also supplemental material in the appendix relating to Scott and White Health Plan. Respectfully submitted, PETER D. KEISLER Assistant Attorney General

/s/David M. Cohen DAVID M. COHEN Director /s/Jane W. Vanneman JANE W. VANNEMAN Senior Trial Counsel Commercial Litigation Branch Civil Division Department of Justice Phone: (202) 307-1011 Fa x: (202) 514-8624 December 6, 2005

Case 1:01-cv-00517-MBH

Document 44

Filed 12/06/2005

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CERTIFICATE OF SERVICE I hereby certify that on this 6th day of December, 2005, a copy of the foregoing "UNOPPOSED MOTION TO FILE SUPPLEMENTAL APPENDIX MATERIALS" was filed electronically. I understand that notice of this filing will be sent to all parties by operation of the Court's electronic filing system. Parties may access this filing through the Court's system.

/s/Jane W. Vanneman

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