Document 406 : Docket No. 99-14 : Hearing Decision : Bureau of Insurance

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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ASSOCIATED HOSPITAL SERVICES OF MAINE D/B/A/ BLUE CROSS BLUE SHIELD OF MAINE’S RESPONSE TO DISCOVERY REQUEST OF THE MAINE MEDICAL ASSOCIATION AND ON BEHALF OF THE PROVIDER GROUP FOR INTEVENORS

February 18, 2000

Applicants, Associated Hospital Services of Maine d/b/a/ Blue Cross Blue Shield of Maine ("BCBSME"), hereby responds to the Discovery Request of Maine Medical Association and on behalf of the Provider Group for Intervenors, dated February 4, 2000, as follows:

All of the Requests (#’s 1 – 34) seek information in one or more of the following categories:

The activities of Anthem in other states
Anthem’s policies and operating procedures and experience
Anthem’s intentions for operating Anthem BlueCross BlueShield of Maine following the closing of the Asset Purchase Agreement.

Such requests are properly directed to Anthem, and accordingly BCBSME defers to Anthem’s responses.

Because BCBSME’s response to each paragraph of the request is the same, and to save on the costs of photocopying and clerical resources for all parties, BCBSME’s response has not reproduced each of the paragraphs of the request.

DATED: February 18, 2000

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Robert S. Frank

HARVEY & FRANK

Two City Center

Suite 402

Portland, Maine 04112-0126

(207) 775-1300

Attorneys for Associated Hospital Services of Maine d/b/a/ Blue Cross Blue Shield of Maine