Document 493 : Docket No. 99-14 : Hearing Decision : Bureau of Insurance

STATE OF MAINE
DEPARTMENT OF PROFESSIONAL AND FINANCIAL REGULATION
BUREAU OF INSURANCE
34 STATE HOUSE STATION
AUGUSTA, MAINE 04333-0034

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	)
	)
	)	CONSUMERS FOR
	)	AFFORDABLE HEALTH
And	)	CARE’S MOTION TO
	)	ENLARGE TIME FOR
	)	FILING REPORTS OF
	)	EXPERTS
	)
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	)
	)
Consolidated Docket No. INS 99-14	)

Now comes Consumers for Affordable Health Care ("CAHC"), through its attorneys, and requests an enlargement of time up to and including Friday, March 17, 2000 to file CAHC’s Reports of Experts. In support, of its Motion CAHC states that:

1. As of March 2, 2000, no experts have been retained by CAHC.

2. CAHC intends to retain experts to deal with issues of valuation and other issues, including those issues relevant to the issuance of a Certificate of Authority under 24-A M.R.S.A. §§ 4203-4204.

3. CAHC is a non-profit organization that does not have the financial resources to pay experts their normal fees.

4. CAHC has been actively searching for experts who will work either on a pro-bono basis or at drastically reduced rates.

5. CAHC believes that relevant responses by both Anthem and BCBSME to the first and second discovery requests by Consumer Intervenors will be an integral part of any reports by experts retained by CAHC.

6. CAHC is still receiving responses to the First and Second Discovery Requests of Consumer Intervenors.

7. CAHC will also be filing a Motion to Compel Anthem to Respond to Consumer Intervenors’ Second Discovery Request.

Wherefore, CAHC respectfully requests that the Superintendent grant an enlargement of time up to and including Friday, March 17, 2000, for CAHC to file its Reports of Experts.

DATED: March 2, 2000

_________________

Joseph P. Ditre, Esq.

Dale Lavi, Esq.

Consumer Health Law Program

A Program of CAHC Foundation

One Weston Court, Level One

P.O. Box 2490

Augusta, ME 04338-2490

Ph: (207) 622-7083/ Fx:622-7077

Email: jditre@mainecahc.org

Patrick Ende, Esq.

Maine Equal Justice Partners

65 State Street, 2^nd floor

P.O. Box 5347

Augusta, ME

Ph: (207) 626-7058/Fx:621-8148

Email: pende@mejp.org

Counsel for CAHC

CERTIFICATE OF SERVICE

The undersigned hereby certifies that on March 2, 2000, a copy of CAHC’s Motion To Enlarge Time for Filing Reports of Experts was served by United States mail, first class postage prepaid, on each of the persons listed below.

Robert S. Frank, Esq.	James B. Zimpritch, Esq.
Harvey & Frank	Catherine R. Connors, Esq.
Two City Center	Pierce Atwood
P.O. Box 126	One Monument Square
Portland, Maine 04112	Portland, Maine 04101
(Blue Cross/Blue Shield of Maine)	(Anthem Insurance Companies, Inc.)
Judith Chamberlain, Esq.	Michele M. Garvin, Esq.
State of Maine	Ropes & Gray
Department of the Attorney General	One International Place
6 State House Station	Boston, Massachusetts 02110-2624
Augusta, Maine 04333-0006	(Central Maine Healthcare Corp.)
(Office of the Attorney General)
William H. Laubenstein, Esq.	Robert I. Goldman
State of Maine	Maine Council of Senior Citizens
Department of the Attorney General	27 Bowery Beach Road
6 State House Station	Cape Elizabeth, Maine 04107
Augusta, Maine 04333-0006	(Maine Council of Senior Citizens)
(Office of the Attorney General)
	John Dieffenbacher-Krall
Gregory A. Brodek, Esq.	Executive Director
Duane, Morris & Heckscher, LLP	Maine People's Alliance
15 Columbia Street, 4^th Floor	192 State Street
Bangor, Maine 04401-6355	Portland, Maine 04101
(Maine Health Alliance)	(Maine People's Alliance)
Andrew B. MacLean, Esq.	Bonnie Post
Maine Medical Association	Executive Director or the Maine
Frank O. Stred Building	Ambulatory Care Coalition
P.O. Box 190	P.O. Box 390
Manchester, Maine 04351	Manchester, Maine 04351
(Thomas D. Hayward, M.D.,	(Sacopee Valley Health Center,
Maroulla S. Gleaton, M.D.,	Regional Medical Center at Lubec,
And the Maine Medical Association)	Eastport Health Care, Inc., and the
	Maine Ambulatory Care Coalition)
Kellie Miller	Sandra Parker
Maine Osteopathic Association	Maine Hospital Association
RR 2, Box 1920	150 Capitol Street
Manchester, Maine 04351	Augusta, ME 04330
(Maine Osteopathic Assn.)	(Maine Hospital Association)

Donald E. Quigley, Esq.

Maine Health

465 Congress Street, Ste. 600

Portland, ME 04101-3537

(MaineHealth)

Dated: March 2, 2000