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State Government Home Page
National Association of
Insurance Commissioners
Home Page
> Special
> Premera
Legal Filings by Commissioner
2/27/04
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Twenty-Ninth Order — Procedures for Filing and Disclosing Documents
2/11/04
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Twenty-Eighth Order — Ruling on Disclosure of Post-Conversion Compensation Plan
1/23/04
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Twenty-Seventh Orde r— Ruling on Request to Extend Deadline to Designate ADI Reports
1/14/04
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Twenty-Sixth Order — Ruling on Redactions in Experts Reports
1/9/2004
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Twenty-Fifth Order — Order Extending Case Schedule
12/31/03
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Twenty-Fourth Order — Ruling on Use of Alaska Division of Insurance Expert Reports
12/11/03
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Twenty-Third Order — Order Extending Case Schedule
12/8/03
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Twenty-Second Order — Notice of Changed Briefing Schedule and Hearing Date
12/4/03
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Twenty-First Order — Notice of Briefing Schedule and Hearing
11/24/03
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Twentieth Order — Notice regarding Appeals of Special Master's Second Order on Objections to Redactions, and Denial of Premera's Motion for Emergency Hearing Regarding Publication of Reports
11/24/03
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Carol Sureau Reply to Thomas Kelly
11/18/03
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Ninteenth Order — Notice regarding Appeals of Special Master's Order on the Objections or Production of Reports
11/13/03
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Eighteenth Order — Denial of Premera's Motion to Clarify Seventeenth Order and Declare Form A Complete
10/30/03
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Notice of Appearance
10/23/03
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Seventeenth Order — Ruling on Status of Form A, Publication of Expert Reports, and Production of Documents
10/3/03
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Sixteenth Order — Notice Regarding Public Hearing Procedures and Setting of Conference
10/3/03
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Fifteenth Order — Ruling on Disclosure of OIC's Draft Consultant Reports to the Interveners
9/30/03
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Fourteenth Order — Ruling on Intervener's Request to Revise the Case Schedule
9/18/03
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Thirteenth Order — Setting Revised Case Schedule
9/12/03
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Stipulation of Parties and Final Order
9/12/03
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Commissioner's Memo Regarding Deficiencies in Premera's Form A Statement
9/12/03
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Exhibit 1 — Schedule of Deficiencies
9/12/03
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Exhibit 2 — Declaration of James Tompkins
9/12/03
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Exhibit 3 — Declaration of Patrick Cantilo
9/11/03
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Insurance Commissioner's Notice of Appeal
8/28/03
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Twelfth Order: Setting Trigger Date for Case Schedule
8/19/03
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Eleventh Order: Commissioner Adopts Case Schedule
7/25/03
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Tenth Order: Order to Produce Documents for In Camera Review
7/16/03
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Ninth Order: Extending the Time for Premera to Request review
6/25/03
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Insurance Commissioner's Response Brief to Premera's Petition for Judicial Review
6/16/03
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Commissioner's Eighth Order: Protective Order
6/16/03
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Appendix A: Declaration and Agreement to Comply With Protective Agreement and Confidentiality Agreement
6/16/03
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Appendix B: Confidentiality Agreement Between Premera and Designated Interveners
4/28/03
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Commissioner's Denial of Consortium's Request to Intervene
4/10/03
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Seventh Order: Insurance Commissioner Appoints Special Master
4/1/03
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3/14/03
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Fifth Order: Setting Status Conference; Addressing Certain Discovery Matters; and Revising Filing Requirements
2/10/03
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OIC's Fourth Order: Ruling on Motions to Intervene
12/23/02
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Third Order: Ruling on Premera's Objections to the Case Management Order
11/13/02
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Second Order: Order on Status Conference
10/24/02
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First Order: Case Management Order
Legal Filings by Special Master
6/17/04
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Order on Premera's Motion to Strike Untimely Material
4/1/04
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Order on Premera's Motion to Exclude Supplemental Report and Testimony of Aaron Katz
4/1/04
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Order on OIC Staff's Motion for Protective Order
4/1/04
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Privilege Log
3/23/04
Order on Intervener's and OIC Staff's Objections to Premera's "AEO" and "Confidential" Designations of OIC Staff's Consultants' Supplemental Reports
3/23/04
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Order on OIC Staff's Objections to Premera's Proposed Redactions to Blackstone Group's Report Regarding Allocation
2/10/04
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Order on WSMA's Objections to Premera's Proposed Redactions to Deposition Transcript of Premera Expert
1/12/04
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Revised Procedural Order
12/19/03
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Procedural Order
12/19/03
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Order on Premera's Motion for Order Directing OIC Staff to Withold Disclosure of Portions of the Mercer Report
12/3/03
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Order on Intervener's Motion for Authorization to Disclose AEO Information to Interveners' Consultant Aaron Katz
11/26/03
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Order on Alaska Intervener's Motion Re Alaska Division of Insurance Consultants' Reports
11/24/03
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Second Order on Objections to Premera's "AEO" and "Confidential" Designations
11/24/03
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Order on OIC Staff's Motion for Protective Order
11/17/03
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Order on Objections to Premera's "AEO" and "Confidential" Designations
11/5/03
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Order on WSMA's Request for Disclosure of Attorney's Eyes Only Materials
8/22/03
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Special Master's Decision Following In Camera review of Documents
7/14/03
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Special Master's Case Schedule Recommendation
7/7/03
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Special Master's Scheduling Recommendation to the Commissioner
5/9/03
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Protective Order Submitted by Special Master - Not Yet Adopted/Signed by the Commissioner
Legal Filings by OIC Review Team
1/8/04
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Melanie Deleon Response Letter to Jeff Coopersmith Concerning Interveners Concerns About Changes to Conversion Application
12/10/03
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Corrections to OIC Staff's Response to Intervener's Motion for Emergency Hearing
12/8/03
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Response to Intervener's Motion for Emergency Hearing
12/4/03
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OIC Staff's Response to Premera's Motion to Extend Case Schedule, Including Upcoming Deadlines
12/4/03
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Response to Premera's Motion for Order Directing OIC Staff to Withhold Disclosure of Portions of the Mercer Report
11/26/03
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Amended Disclosure of Witnesses in Addition to Consultants
11/19/03
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OIC Staff's Appeal of the Special Master's Order on Objections or Production of Reports
11/19/03
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Declaration of James E. Tompkins in Support of OIC Staff's Appeal of the Special Master's Order on Objections or Productions of Reports
11/19/03
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OIC Staff's Motion for Protective Order
11/17/03
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Staff's Disclosure of Witnesses in Addition to Consultants
11/17/03
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Staff's Objections to Premera's Proposed Redactions to Experts' Reports
11/14/03
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Notice of Association of Counsel
11/12/03
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Motion for Pre-Hearing Conference
11/4/03
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Response to Premera's Motion to Clarify Seventeenth Order and Declare Form A Complete
11/4/03
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Declaration of James E. Tompkins in Support of OIC Staff's Response to Premera's Motion to Clarify Seventeenth Order and Declare Form A Complete
11/3/03
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Objections to Premera's Proposed Redactions to the Consultant's Reports
11/3/03
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Motion to Strike Timelines in Premera's First Set of Requests for Production of Documents to the OIC Staff
10/27/03
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Notice of Submission of Consultants' Reports
10/21/03
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Declaration of James T. Odiorne
Exhibit A: 10-10-03 E-Mail Message from Jim Odiorne to Yori Milo
Exhibit B: 10-13-03 Faxed Letter from Yori Milo to Jim Odiorne
Exhibit C: 10-14-03 E-Mail Response from Jim Odiorne to Yori Milo
Exhibit D: 10-14-03 Faxed response from Yori Milo to Jim Odiorne
Exhibit E: 10-17-03 Letter from John Domeika to Jim Odiorne
Exhibit G: 10-17-03 Letter from John Domeika to Jim Odiorne
10/21/03
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Motion to Disregard Premera's Late-Filed Amendment to Form "A"
10/9/03
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Response to Premera's Comments on the Commissioner's Sixteenth Order
10/3/03
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Notice of Submission of Consultants Draft Reports
9/24/03
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Response to Intervener's Motion for Reconsideration
8/4/03
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OIC Staff's Brief on Privilege Issues
7/28/03
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OIC Staff's Response to Premera's Review of the Special Master's July 14th, 2003 Case Schedule Recommendation
7/22/03
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OIC Staff's Response to Premera's Proposed Order Regarding the In Camera Privilege Review
4/15/03
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OIC Staff Response to Consortium Substitution Request
3/27/03
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OIC Staff's Response to Motion for Leave to Intervene of Consortium of Northwest Law Schools
3/25/03
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2nd Joint Status Report of OIC and Premera Blue Cross and its Affiliates
3/25/03
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Attachment I
3/25/03
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Data Request Response Matrix
3/25/03
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Exhibit A: Data Responses and Requests Status of Completion as/of 1-13-2003
3/25/03
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Exhibit B: Data Responses and Requests Status of Completion as/of 3-21-2003
3/25/03
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Cantilo and Bennett, LPP status report on outstanding data request with Premera
3/25/03
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PriceWaterhouseCoopers status report on outstanding data request with Premera
3/25/03
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Blackstones status report on outstanding data request with Premera
3/25/03
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Attorney General's Office status report on outstanding data request with Premera
3/25/03
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Signal Hill Capital Group LLC status report on outstanding data request with Premera
3/25/03
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Redent Anders LTD status report on outstanding data request with Premera
3/25/03
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Peterson Consulting status report on outstanding data request with Premera
3/25/03
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LeBoeuf, Lamb, Greene and MacRae status report on outstanding data request with Premera
2/26/03
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Joint Proposal Regarding Discovery and Hearing Schedule
2/26/03
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First Joint Status Report of OIC Staff and Premera Blue Cross and its Affiliates
2/26/03
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Exhibit A — Data Responses and Requests: Status of Completion
2/26/03
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Exhibit A — Data Responses and Requests: Status of Completion — Part 2
2/26/03
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Exhibit B — Questions and Answers: Status of Completion
2/26/03
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Exhibit C — Overview of Interviews and Discussion Topics
2/27/03
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Modification of First Order: Filing of Instruments
1/14/03
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Exhibit C — Overview of Consultants' Interviews
and Discussion Topics
1/14/03
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Second Status Report of OIC Staff
1/14/03
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Exhibit B — Consultants' Questions
1/13/03
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Exhibit A — Consultants' Data Responses and Requests
12/11/02
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OIC Staff's Response to Requests for Intervention
11/22/02
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First Status Report of OIC Staff
11/22/02
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OIC Staff's Response to Premera's Motion for Partial Reconsideration and Clarification
11/21/02
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Declaration of James T. Odiorne
Legal Filings by Premera
8/13/04
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Petition for Review
4/29/04
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Response to OIC Staff's Pre-hearing Memorandum
4/23/04
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Premera's Pre-Hearing Brief
2/24/04
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Proposed Order — Procedures for Filing and Disclosing Documents
2/24/04
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Joint Motion for Order Regarding Filing and Disclosure of Procedures
2/18/04
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Unredacted Mercer Report
2/12/04
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Order on WSMA's Objections to Premera's Proposed Redactions to Deposition Transcript of Premera Expert
1/9/04
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Response to OIC Staff's Objections to Proposed Redactions to OIC Consultant Supplemental Reports
1/8/04
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Joint Motion to Extend Case Schedule in Twenty-Third Order
12/23/03
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Mercer Report
12/8/03
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Declaration of John P. Domeika
12/8/03
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Response to Interveners' Motion for Emergency Hearing
12/5/03
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Reply in Support of Motion to Direct Witholding of Portions of Mercer Report
12/4/03
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Motion to Extend Case Schedule, Including Upcoming Deadlines and Hearing Date
12/1/03
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Response to Motion for Authorization to Disclose AEO Material to Aaron Katz
11/21/03
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Emergency Motion Regarding Publication of Premera Expert Reports and OIC Staff Consultants' Reports on the OIC Web Site
11/21/03
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Notice of Deposition
11/20/03
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Amended First Set of Requests for Production of Documents to the Premera Watch Coalition and Premera Watch Coalition Objections and responses Thereto
11/19/03
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Letter From Thomas Kelly to Carol Sureau Concerning Commissioner's Ninteenth Order
11/17/03
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Premera's Disclosure of Fact Witnesses
11/17/03
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Notice of Deposition
11/17/03
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First Set of Requests for Production of Documents to the OIC Staff, and Objections and responses Thereto
11/14/03
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Notices of Deposition
11/11/03
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Reply in Support of Motion to Clarify Seventeenth Order and Declare Form A Complete
11/10/03
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Declaration of Thomas E. Kelley
11/10/03
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Expedited Motion for Conference for Scheduling Depositions and Discount for Depositions
11/5/03
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Amended First Set of requests for Production of Documents to the Hospital Associations, and Objections and Responses Thereto
11/4/03
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Response to WSMA's Reply Concerning Disclosure of AEO Materials to WSMA's Experts
11/3/03
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Request for Three of the Intervener Groups to Produce Requested Documents by 10-10-03
10/31/03
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Declaration od Kent Marquardt
10/31/03
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Substantive Response to the WSMA's Request for an Emergency Hearing Concerning Disclosure of Attorney's Eyes Only Materials
10/31/03
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Motion to Clarify Seventeenth Order and Declare Form A Complete
10/31/03
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Declaration of John P. Domeika
10/28/03
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Declaration of Thomas E. Kelly, Jr.,
Exhibits A Through D
10/23/03
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Response to Intervener's Second and Third Set of Documents Request
10/22/03
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Response to Intervener's Motion for Emergency Hearing
Exhibit A: Intervener's Third Request for Production of Documents
Exhibit B: Proposed Order: Intervener's October 21, 2003 Motion for an Emergency Hearing
Exhibit C: Premera's Response to OIC Staff's Motion to Disregard late-Filed Amendments
Exhibit D: Declaration of John P. Domeika
Exhibit E: Proposed Order: OIC Staff's October 21, 2003 Motion
Exhibit F: Certificate of Service
10/21/03
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Amended First Set of Requests for Production of Documents to the Hospital Associations
10/20/03
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Third Joint Status Report of OIC Staff and Premera Blue Cross and Affiliates
10/20/03
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Response to Intervener's Concerns and Objections
10/10/03
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Intervener's Second Request for Production of Documents and Premera's Responses Thereto
10/10/03
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Request for Production of Consultants' Draft Reports and Premera's Responses Thereto
10/7/03
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Comments on the Commissioner's Sixteenth Order
10/1/03
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Premera's Proposed Wording for a Fifteenth Order Covering Premera's Motion to Modify the Fourteenth Order
10/1/03
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Premera's Emergency Motion for Modification of Fourteenth Order
9/25/03
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Response to Intervener's Motion for Reconsideration of Thirteenth Order
9/11/03
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Memorandum Regarding Schedule of Alleged Deficiencies
8/11/03
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Premera's Reply to Privilege Briefing by the OIC Staff and the Interveners
7/28/03
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In Camera Submissions and Premera's Briefing on Privilege Matters for the Special Master
7/24/03
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Premera's Reply to OIC Staff's Response Regarding the In Camera Privilege Review
7/22/03
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Premera's Seven Recommended Points for Proposed Order
7/14/03
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Premera's Motion for Review of Case Schedule Recommendation
7/10/03
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Petitioner's Reply Brief to Insurance Commissioner's Response Brief to Premera's Petition for Judicial Review
6/17/03
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Petitioner's Opening Brief Related to the Thurston County Appeal of the Third Order
5/19/03
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Premera's Response to Intervener Group's Motion for Commissioner's Review
5/12/03
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Cover Letter From Preston/Gates/Ellis to Carol Sureau Concerning Motion for Review of a Provision of the Proposed Protective Order
5/12/03
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Premera's Motion for the Review of a Provision of the Protective Order Recommended by the Special Master
3/31/03
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Premera Support Response to OIC Staff's Conclusion that the Motion for Leave to Intervene of Consortium of Northwest Law Schools Be Denied
3/7/2003
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Premera's Response Letter Concerning Their Position on Special Master Compensation
1/21/03
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Premera's Petition for Judicial Review
1/14/03
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Premera's Status Report in Response to Third Order
12/11/02
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Premera's Opposition to Motions to Intervene
11/25/02
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Premera's Supplemental Status Report
11/25/02
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Premera's Reply in Support of its Motion for Partial Reconsideration and Clarification
11/22/02
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Premera's Status Report
11/1/02
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Premera's Motion for Partial Reconsideration and Clarification
Legal Filings by Interveners
1/13/04
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Motion for Extension of Deadline in Twenty-Fourth Order
12/23/03
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Letter to Melanie Deleon From Jeff Coopersmith Concerning Changes to Conversion Application
12/9/03
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Interveners' Response to Premera's Motion to Extend Case Schedule
12/9/03
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(Proposed) Order Regarding Interveners' Motion for Emergency Hearing and Premera's Motion to Extend Case Schedule
12/8/03
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Hamburger to Replace Spoonmore at 12 - 8 Hearing
12/3/03
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Motion for Emergency Hearing
12/3/03
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Declaration of Eleanor Hamburger
11/26/03
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Motion for Authorization to Disclose Attorneys Eyes Only Information to Interveners' Consultant Aaron Katz
11/26/03
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Declaration of Rick Spoonmore
11/17/03
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Premera Watch Coalition Disclosure of Non-Expert Witnesses
11/17/03
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Intervener — Hospital Associations' Disclosure of Fact Witnesses
11/17/03
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Premera Watch Coalition's Supplemental Disclosure of Non-Expert Witnesses
11/17/03
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Washington State Medical Association's Disclosure of Fact Witnesses
11/17/03
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Alaska Intervener's fact Witness List
11/17/03
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Intervener — Hospital Associations' Disclosure of Fact Witnesses
11/14/03
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Fourth Request for Production of Documents and Premera's Objections and responses Thereto
11/10/03
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Notice of Submission of Expert Reports
11/7/03
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Notice of Temporary Substitution of Lead Counsel
11/5/03
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WSMA's Objection to Premera's Amended First Set of Document Requests
11/3/03
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WSMA's Reply to Premera's Substantive Response to WSMA's Request for the Disclosure of Attorney's Eyes Only Material to Its Experts
10/28/03
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WSMA's Reply to Premera's Procedural Response to WSMA's Request for an Emergency Hearing
10/26/03
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Request for Emergency Hearing with Special Master Regarding Disclosure of Material Designated Attorney's Eyes Only
10/22/03
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Response to OIC Staff's Motion to Disregard Premera's Late-Filed Amendments to Form "A"
10/21/03
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Motion for an Emergency Hearing Before the Commissioner
10/17/03
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Change of Address
10/14/03
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Concerns and Objections Concerning Prehearing Procedure
10/9/03
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Comments On and Response To Premera's Comments on Sixteenth Order
10/6/03
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Request for Production of Consultants' Draft Reports
10/3/03
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Response to Premera's Proposed Fifteenth Order and Intervener's Second Request for Production of Documents
10/1/03
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Intervener's Second Request for Production of Documents
9/30/03
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Notice of Substitution of Local Counsel
9/23/03
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Motion for Reconsideration of Two 13th Order Deadlines
9/19/03
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Notice of Withdrawal and Substitution of Counsel
8/28/03
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Interveners' First Request for Production of Documents
8/25/03
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Notice of Change of Address
8/5/03
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Interveners Response to Premera's Briefing on Privilege Issues for the Special Master
7/28/03
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Interviewer's Response to Premera's Motion for Review of the Special Master's Case Schedule Recommendation of July 14, 2003
7/23/03
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Intervener's Response to Premera's Proposal Regarding July 7th, 2003 Special Master's Scheduling Recommendation
7/22/03
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Notice of Withdrawal and Substitution for Attorney's
7/16/03
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Notice of Temporary Substitution of Counsel
5/20/03
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Hospital Association's Joinder in Alaska Intervener's Errata
5/20/03
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Notice of Errata - University of Alaska Inadvertently Omitted
5/19/03
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Notice of Temporary Substitution for Lead Intervener Lead Counsel
5/16/03
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Intervener's Response to Premera's Motion for Review of a Provision of the Protective Order Recommended by the Special Master
5/15/03
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Intervener Group's Motion for Commissioner's Review of Special Master's Recommended Protective Order
4/18/03
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UW School of Medicine Response to Consortium Request to Replace Them as Intervener
4/7/03
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Washington School of Medicine Withdraws as Intervener Group
3/13/03
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Intervener Groups Written Response Concerning Proposed Use of a Special Master
3/11/03
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Alaska Interveners Addition of Maritza Rivera as Associate Local Counsel
1/23/03
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Hospital Associations' Supplemental Filing re: Motion to Intervene
1/22/03
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Hospital Association and Public Hospital District's
Complaint for Declaratory and Injunctive Relief
2/20/03
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Intervener Lead Attorneys Chosen
12/29/02
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Washington State Medical Association's Reply to OIC Staff Response and Premera Opposition to Motions to Intervene
12/20/02
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Joint Reply to OIC Staff Response and Premera Opposition to Motions to Intervene
12/19/02
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Alaska Petitioners' Supplemental Joint Reply to OIC Staff's Response to Requests for Intervention and to Premera's Opposition to Motions to Intervene
12/20/02
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Premera Watch Coalition's Supplement to Joint Reply on Motion to Intervene
12/19/02
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University of Washington's Reply to OIC Staff Response and Premera Opposition to Motions to Intervene
12/20/02
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Declaration of Elanor Hamburger
12/18/02
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Hospital Association's Supplement to Joint Reply Brief in Support of Motion to Intervene
11/26/02
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Memorandum in Support of Applicant-Intervenors' Motion to Intervene
11/26/02
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Declaration of Mark Stroh
11/26/02
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Declaration of Ellie Menzies
11/25/02
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Declaration of Barbara Flye
11/25/02
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Declaration of Liz Arjun
11/25/02
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Declaration of Eleanor Hamburger
11/22/02
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Declaration of Linda Tosti-Lane
11/22/02
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Declaration of Janet Varon
11/21/02
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Declaration of Vicki Black, M.D.
11/21/02
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Declaration of Jean Colman
11/20/02
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Declaration of Julie Watts
11/20/02
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Declaration of Leeann Hall
11/26/02
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University of Alaska's Motion for Leave to Intervene
11/26/02
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United Way of Anchorage, et. al Motion to Intervene
11/26/02
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University of Washington's Petition for Leave to Intervene
11/26/02
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Motion of Washington Association of Community & Migrant Health Centers for Leave to Intervene
11/25/02
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Notice of Appearance by UW
11/25/02
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Hospital Associations' Supplemental Memorandum in Support of Motion to Intervene
11/25/02
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Declaration of Claudia Sanders
11/25/02
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Declaration of Jeff Mero
11/25/02
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Supplemental Filing to Washington State Medical Association's Motion to Intervene
11/22/02
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Declaration of Eleanor Hamburger
11/22/02
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Applicant-Intervenors' Joint Response to Premera's Motion for Partial Reconsideration and Clarification
10/14/02
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Premera's Motion for Partial Reconsideration and Clarification
Legal Filings by Others
9/5/03
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Superior Court Judge Orders Premera Decision to Be Rendered Within 60 Days
4/10/03
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Consortium Request to Substitute for Intervener Medical School
3/17/03
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Motion for Leave to Intervene by Consortium of Northwest Law Schools
1/21/03
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Notice of Assignment/Notice of Status Conference
re; Petition for Judicial Review
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