EMERGENCY CARE SERVICES OF PENNSYLVANIA, P.C. et al v. UNITEDHEALTH GROUP, INC. et al
| EMERGENCY CARE SERVICES OF PENNSYLVANIA, P.C. and EMERGENCY PHYSICIAN ASSOCIATES OF PENNSYLVANIA, P.C. |
| UNITEDHEALTH NETWORKS, INC., UNITEDHEALTHCARE OF PENNSYLVANIA, INC., UNITEDHEALTHCARE OF NEW ENGLAND, INC., UNITEDHEALTHCARE, INC., UNITEDHEALTHCARE INSURANCE COMPANY, MULTIPLAN, INC., UNITEDHEALTHCARE SERVICES, INC. and UNITEDHEALTH GROUP, INC. |
| 5:2020cv05094 |
| October 14, 2020 |
| US District Court for the Eastern District of Pennsylvania |
| JOSEPH F LEESON |
| Labor: E.R.I.S.A. |
| 28 U.S.C. § 1331 |
| Defendant |
Docket Report
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| Filing 51 Letter FROM COURT OF COMMON PLEAS RE: RECEIPT OF RECORD; ETC. (JL ) |
| Original state court record, along with certified copies of Opinion and Order dated 1/25/2021, mailed to the Court of Common Pleas of Philadelphia County by Certified Mail on 2/23/2021. (md, ) |
| Certified Copies of Opinion and Order, dated 1/25/2021, mailed to the Court of Common Pleas of Philadelphia County on 2/16/2021. (md, ) |
Filing 50
ORDER THAT PLAINTIFFS MOTION TO REMAND, ECF NO. #20 , IS GRANTED; THIS MATTER IS HEREBY REMANDED TO THE PENNSYLVANIA COURT OF COMMON PLEAS, PHILADELPHIA COUNTY. DEFENDANTS MOTIONS FOR JUDGMENT ON THE PLEADINGS, ECF NOS. #33 , #36 , AS WELL AS THE UNITED DEFENDANTS MOTION FOR FEES AND COSTS, ECF NO. #35 , ARE DISMISSED AS MOOT IN LIGHT OF THE ABSENCE OF SUBJECT MATTER JURISDICTION. THIS CASE IS CLOSED. SIGNED BY HONORABLE JOSEPH F. LEESON, JR ON 1/25/21. 1/25/21 ENTERED AND COPIES E-MAILED.(mas, )
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| Filing 49 OPINION. SIGNED BY HONORABLE JOSEPH F. LEESON, JR ON 1/25/21. 1/25/21 ENTERED AND COPIES E-MAILED.(mas, ) |
| Filing 48 RESPONSE in Support re #20 MOTION to Remand filed by EMERGENCY CARE SERVICES OF PENNSYLVANIA, P.C.. (Attachments: #1 Exhibit 1, #2 Exhibit 2, #3 Exhibit 3)(BOCHETTO, GEORGE) |
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Filing 47
ORDER THAT PLAINTIFFS' UNOPPOSED MOTION TO FILE A SINGLE REPLY BRIEF IN FURTHER SUPPORT OF THEIR MOTION TO REMAND IN EXCESS OF THE COURT'S 10-PAGE LIMIT FOR REPLY BRIEFS, AND IN PARTICULAR, A BRIEF OF 15 PAGES IN LENGTH, SEE ECF NO. 46, IT IS GRANTED. SIGNED BY HONORABLE JOSEPH F. LEESON, JR ON 12/17/20.12/17/20 ENTERED AND COPIES E-MAILED.(er, )
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| Filing 46 MOTION Uncontested Motion for Leave to File Omnibus Reply Brief in Excess of 10 Pages filed by EMERGENCY CARE SERVICES OF PENNSYLVANIA, P.C., EMERGENCY PHYSICIAN ASSOCIATES OF PENNSYLVANIA, P.C..Certificate of Service.(BOCHETTO, GEORGE) |
| Filing 45 RESPONSE in Opposition re #20 MOTION to Remand / United Defendants' Opposition to Plaintiffs' Motion to Remand filed by UNITEDHEALTH GROUP, INC., UNITEDHEALTH NETWORKS, INC., UNITEDHEALTHCARE INSURANCE COMPANY, UNITEDHEALTHCARE OF NEW ENGLAND, INC., UNITEDHEALTHCARE OF PENNSYLVANIA, INC., UNITEDHEALTHCARE SERVICES, INC., UNITEDHEALTHCARE, INC.. (Attachments: #1 Text of Proposed Order)(BLALACK, K.) |
| Filing 44 RESPONSE in Opposition re #20 MOTION to Remand Memorandum in Opposition to Plaintiffs' Motion to Remand filed by MULTIPLAN, INC.. (Attachments: #1 Text of Proposed Order Order)(KING, ERROL) |
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Filing 43
ORDER THAT THE COURTS DECEMBER 3, 2020 ORDER, SEE ECF NO. #41 , CONTEMPLATES THE STAYING OF ALL DEADLINES EXCEPT FOR THE DEADLINES RELATED TO THE BRIEFING OF THE PLAINTIFFS MOTION TO REMAND. THEREFORE, THE DEADLINE FOR PLAINTIFFS TO RESPOND TO DEFENDANTS COUNTERCLAIMS, AND THE DEADLINE FOR DEFENDANTS TO IN TURN AMEND THEIR ANSWER/COUNTERCLAIMS, ARE HEREBY HELD IN ABEYANCE PENDING A RESOLUTION OF THE MOTION TO REMAND. ALL OTHER DIRECTIVES AND DEADLINES, SEE ECF NOS. #30 , #41 , REMAIN IN EFFECT. SIGNED BY HONORABLE JOSEPH F. LEESON, JR ON 12/9/20. 12/9/20 ENTERED AND COPIES E-MAILED.(mas, )
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| Filing 42 NOTICE by EMERGENCY CARE SERVICES OF PENNSYLVANIA, P.C., EMERGENCY PHYSICIAN ASSOCIATES OF PENNSYLVANIA, P.C. Letter Re: No. 41 (HEIM, DAVID) |
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Filing 41
ORDER THAT THE DEADLINES FOR BRIEFING ALL MOTIONS EXCEPT PLAINTIFFS MOTION TO REMAND, SEE ECF NO. #20 , ARE HEREBY HELD IN ABEYANCE PENDING A RESOLUTION OF THAT MOTION. THE EXISTING DEADLINES FOR THE COMPLETION OF BRIEFING OF PLAINTIFFS MOTION TO REMAND, SEE ECF NO. #30 , REMAIN IN EFFECT. THE PENDING MOTIONS AT ECF NOS. #21 AND #40 ARE HEREBY DISMISSED, AS MOOT IN LIGHT OF THE DIRECTIVES CONTAINED IN THIS ORDER. SIGNED BY HONORABLE JOSEPH F. LEESON, JR ON 12/3/20.12/3/20 ENTERED AND COPIES E-MAILED.(mas, )
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| Filing 40 MOTION for Extension of Time to File filed by EMERGENCY CARE SERVICES OF PENNSYLVANIA, P.C., EMERGENCY PHYSICIAN ASSOCIATES OF PENNSYLVANIA, P.C...(HEIM, DAVID) |
| Filing 39 LETTER re Reply to Response to Motion re #21 MOTION to Stay Proceedings Pending A Decision on Plaintiffs' Motion for Remand filed by EMERGENCY CARE SERVICES OF PENNSYLVANIA, P.C.. (HEIM, DAVID) Modified on 11/27/2020 (md, ). |
| Filing 38 RESPONSE in Opposition re #21 MOTION to Stay Proceedings Pending A Decision on Plaintiffs' Motion for Remand / United Defendants' Opposition to Plaintiffs' Motion to Stay filed by UNITEDHEALTH GROUP, INC., UNITEDHEALTHCARE INSURANCE COMPANY, UNITEDHEALTHCARE OF NEW ENGLAND, INC., UNITEDHEALTHCARE OF PENNSYLVANIA, INC., UNITEDHEALTHCARE SERVICES, INC., UNITEDHEALTHCARE, INC.. (Attachments: #1 Text of Proposed Order, #2 Certificate of Service)(BLALACK, K.) |
| Filing 37 United Defendants' ANSWER to Complaint and, COUNTERCLAIM against EMERGENCY CARE SERVICES OF PENNSYLVANIA, P.C., EMERGENCY PHYSICIAN ASSOCIATES OF PENNSYLVANIA, P.C. by UNITEDHEALTH GROUP, INC., UNITEDHEALTHCARE INSURANCE COMPANY, UNITEDHEALTHCARE OF PENNSYLVANIA, INC., UNITEDHEALTHCARE OF NEW ENGLAND, INC., UNITEDHEALTHCARE SERVICES, INC., UNITEDHEALTHCARE, INC..(BLALACK, K.) |
| Filing 36 MOTION for Judgment on the Pleadings / United Defendants' Motion for Judgment on the Pleadings filed by UNITEDHEALTH GROUP, INC., UNITEDHEALTHCARE INSURANCE COMPANY, UNITEDHEALTHCARE OF NEW ENGLAND, INC., UNITEDHEALTHCARE OF PENNSYLVANIA, INC., UNITEDHEALTHCARE SERVICES, INC., UNITEDHEALTHCARE, INC..Memorandum, Proposed Order, Certificate of Service. (Attachments: #1 Memorandum in Support of Motion, #2 Text of Proposed Order, #3 Certificate of Service)(BLALACK, K.) |
| Filing 35 MOTION for Costs / Defendants' Motion for Imposition of Costs and a Stay Pursuant to Federal Rule of Civil Procedure 41(d) filed by UNITEDHEALTH GROUP, INC., UNITEDHEALTHCARE INSURANCE COMPANY, UNITEDHEALTHCARE OF NEW ENGLAND, INC., UNITEDHEALTHCARE OF PENNSYLVANIA, INC., UNITEDHEALTHCARE SERVICES, INC., UNITEDHEALTHCARE, INC..Memorandum, Proposed Order, Certificate of Service. (Attachments: #1 Memorandum in Support of Motion, #2 Text of Proposed Order, #3 Certificate of Service)(BLALACK, K.) |
| Filing 34 RESPONSE in Opposition re #21 MOTION to Stay Proceedings Pending A Decision on Plaintiffs' Motion for Remand filed by MULTIPLAN, INC.. (Attachments: #1 Text of Proposed Order)(KING, ERROL) |
| Filing 33 MOTION for Judgment on the Pleadings filed by MULTIPLAN, INC..Memorandum, Certificate of Non-Concurrence. (Attachments: #1 Text of Proposed Order, #2 Exhibit Certificate of Non-Concurrence, #3 Memorandum)(KING, ERROL) |
| Filing 32 ANSWER to Complaint by MULTIPLAN, INC..(KING, ERROL) |
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Filing 31
(DOCKETED IN ERROR, CORRECTLY DOCKETED IN 20-2233) STIPULATION AND ORDER THAT THE STIPULATION IS APPROVED AND ENTERED AS AN ORDER OF THE COURT. THE CROSSCLAIM AGAINST DEFENDANT, JEFFREY SELVIDIO, IS DISMISSED WITH PREJUDICE. SIGNED BY MAGISTRATE JUDGE HENRY S. PERKIN ON 11/13/20. 11/3/20 ENTERED AND COPIES E-MAILED.(mas, ) Modified on 11/13/2020 (mas, ). (Main Document 31 replaced on 11/13/2020) (mas, ).
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Filing 30
STIPULATION AND ORDER THAT THE BRIEFING DEADLINES SET FORTH IN THE STIPULATION ARE HEREBY ADOPTED. IN PARTICULAR, THE FOLLOWING DEADLINES ARE HEREBY SET: A. NOVEMBER 20, 2020 DEADLINE FOR DEFENDANTS TO FILE MOTIONS FOR JUDGMENT ON THE PLEADINGS; B. DECEMBER 11, 2020 DEADLINE TO FILE OPPOSITION BRIEFS IN RESPONSE TO MOTION TO REMAND AND MOTIONS FOR JUDGMENT ON THE PLEADINGS; C. DECEMBER 30, 2020 DEADLINE TO FILE REPLY BRIEFS IN SUPPORT OF MOTION TO REMAND AND MOTIONS FOR JUDGMENT ON THE PLEADINGS. SIGNED BY HONORABLE JOSEPH F. LEESON, JR ON 11/13/20. 11/13/20 ENTERED AND COPIES E-MAILED.(mas, ) Modified on 11/13/2020 (mas, ).
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| Filing 29 AFFIDAVIT of Service re: served Complaint; Praecipe to Reinstate Complaint upon L. Durenberger; CT Corporation by USPS Certified Mail on 10/19/2020 (Attachments: #1 Exhibit A)(HEIM, DAVID) |
| Filing 28 AFFIDAVIT of Service re: served Complaint; Praecipe to Reinstate Complaint upon Front Desk/Reception/Mail Room by USPS Certified Mail on 10/09/2020 (Attachments: #1 Exhibit A) |
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Filing 27
ORDER THAT THE APPLICATION OF ATTORNEY JASON A. ORR TO PRACTICE IN THIS COURT IS GRANTED. SIGNED BY HONORABLE JOSEPH F. LEESON, JR ON 11/10/20. 11/10/20 ENTERED AND COPIES E-MAILED.(mas, )
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Filing 26
ORDER THAT THE APPLICATION OF ATTORNEY DIMITRI D. PORTNOI TO PRACTICE IN THIS COURT IS GRANTED. SIGNED BY HONORABLE JOSEPH F. LEESON, JR ON 11/10/20. 11/10/20 ENTERED AND COPIES E-MAILED.(mas, )
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Filing 25
ORDER THAT THE APPLICATION FOR ATTORNEY K. LEE BLALACK, II TO PRACTICE IN THIS COURT IS GRANTED. SIGNED BY HONORABLE JOSEPH F. LEESON, JR ON 11/10/20. 11/10/20 ENTERED AND COPIES E-MAILED.(mas, )
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| Filing 24 MOTION for Pro Hac Vice Admission of Jason A. Orr ( Filing fee $ 40 receipt number 0313-14701112.) filed by UNITEDHEALTH GROUP, INC., UNITEDHEALTH NETWORKS, INC., UNITEDHEALTHCARE INSURANCE COMPANY, UNITEDHEALTHCARE OF NEW ENGLAND, INC., UNITEDHEALTHCARE OF PENNSYLVANIA, INC., UNITEDHEALTHCARE SERVICES, INC., UNITEDHEALTHCARE, INC..Certificate of Service.(MYERS, KARL) |
| Filing 23 MOTION for Pro Hac Vice Admission of Dimitri D. Portnoi ( Filing fee $ 40 receipt number 0313-14701104.) filed by UNITEDHEALTH GROUP, INC., UNITEDHEALTH NETWORKS, INC., UNITEDHEALTHCARE INSURANCE COMPANY, UNITEDHEALTHCARE OF NEW ENGLAND, INC., UNITEDHEALTHCARE OF PENNSYLVANIA, INC., UNITEDHEALTHCARE SERVICES, INC., UNITEDHEALTHCARE, INC..Certificate of Service.(MYERS, KARL) |
| Filing 22 MOTION for Pro Hac Vice Admission of K. Lee Blalack II ( Filing fee $ 40 receipt number 0313-14701075.) filed by UNITEDHEALTH GROUP, INC., UNITEDHEALTH NETWORKS, INC., UNITEDHEALTHCARE INSURANCE COMPANY, UNITEDHEALTHCARE OF NEW ENGLAND, INC., UNITEDHEALTHCARE OF PENNSYLVANIA, INC., UNITEDHEALTHCARE SERVICES, INC., UNITEDHEALTHCARE, INC..Certificate of Service.(MYERS, KARL) |
| Filing 21 MOTION to Stay Proceedings Pending A Decision on Plaintiffs' Motion for Remand filed by EMERGENCY CARE SERVICES OF PENNSYLVANIA, P.C., EMERGENCY PHYSICIAN ASSOCIATES OF PENNSYLVANIA, P.C..Memorandum. (Attachments: #1 Certificate of Service)(HEIM, DAVID) |
| Filing 20 MOTION to Remand filed by EMERGENCY CARE SERVICES OF PENNSYLVANIA, P.C., EMERGENCY PHYSICIAN ASSOCIATES OF PENNSYLVANIA, P.C..Memorandum of Law, Certificate of Service. (Attachments: #1 Exhibit 1)(HEIM, DAVID) |
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Filing 19
ORDER THAT THE APPLICATION OF ATTORNEY JONATHAN E. SIEGELAUB TO PRACTICE IN THIS COURT IS GRANTED. SIGNED BY HONORABLE JOSEPH F. LEESON, JR ON 11/3/20. 11/3/20 ENTERED AND COPIES E-MAILED.(mas, )
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Filing 18
ORDER THAT THE APPLICATION OF ATTORNEY JUSTIN C. FINEBERG TO PRACTICE IN THIS COURT IS GRANTED. SIGNED BY HONORABLE JOSEPH F. LEESON, JR ON 11/3/20. 11/3/20 ENTERED AND COPIES E-MAILED.(mas, )
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| Filing 17 APPLICATION for Admission Pro Hac Vice of Jonathan E. Siegelaub by EMERGENCY CARE SERVICES OF PENNSYLVANIA, P.C., EMERGENCY PHYSICIAN ASSOCIATES OF PENNSYLVANIA, P.C.. ( Filing fee $ 40 receipt number 0313-14685707.). (HEIM, DAVID) |
| Filing 16 APPLICATION for Admission Pro Hac Vice of Justin C. Fineberg by EMERGENCY CARE SERVICES OF PENNSYLVANIA, P.C., EMERGENCY PHYSICIAN ASSOCIATES OF PENNSYLVANIA, P.C.. ( Filing fee $ 40 receipt number 0313-14685690.). (HEIM, DAVID) |
| Filing 15 Original Record together with certified copy of docket entries received from Court of Common Pleas of Philadelphia County. (fdc, ) |
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Filing 14
ORDER THAT THE STIPULATION IS APPROVED AND GRANTED IN PART AND DISAPPROVED AND DENIED IN PART; AND DEFENDANTS DEADLINE TO FILE AN ANSWER TO PLAINTIFFS COMPLAINT, ONLY, AND FOR NO OTHER PURPOSE, IS EXTENDED THROUGH AND INCLUDING NOVEMBER 20, 2020. SIGNED BY HONORABLE JOSEPH F. LEESON, JR ON 10/22/20. 10/22/20 ENTERED AND COPIES E-MAILED.(mas, ) Modified on 10/23/2020 (lisad, ).
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Order #8 NEF receipt regenerated as to Unrep. (mas, )
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Filing 13
ORDER THAT THE APPLICATION OF ERROL J. KING TO PRACTICE IN THIS COURT PURSUANT TO LOCAL RULE OF CIVIL PROCEDURE 83.5.2(b) IS GRANTED. SIGNED BY HONORABLE JOSEPH F. LEESON, JR ON 10/16/20. 10/16/20 ENTERED AND COPIES E-MAILED.(mas, )
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Filing 12
ORDER THAT THE APPLICATION OF KATHERINE C. MANNINO TO PRACTICE IN THIS COURT PURSUANT TO LOCAL RULE OF CIVIL PROCEDURE 83.5.2(b) IS GRANTED. SIGNED BY HONORABLE JOSEPH F. LEESON, JR ON 10/16/20. 10/16/20 ENTERED AND COPIES E-MAILED.(mas, )
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| Filing 11 APPLICATION for Admission Pro Hac Vice of Errol J. King by MULTIPLAN, INC.. ( Filing fee $ 40 receipt number 0313-14643426.). (O'CONNELL, BARBARA) |
| Filing 10 APPLICATION for Admission Pro Hac Vice of Katherine C. Mannino by MULTIPLAN, INC.. ( Filing fee $ 40 receipt number 0313-14643386.). (O'CONNELL, BARBARA) |
| Filing 9 NOTICE of Appearance by BARBARA A. O'CONNELL on behalf of MULTIPLAN, INC. with Certificate of Service (Attachments: #1 Certificate of Service)(O'CONNELL, BARBARA) |
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Filing 8
ORDER THAT COUNSEL FOR PLAINTIFF[S] MUST SERVE THIS ORDER ON EVERY PARTY TO THIS CASE IMMEDIATELY AFTER THE PARTYS FIRST APPEARANCE, UNLESS THIS CASE WAS REMOVED FROM STATE COURT, IN WHICH CASE THIS RESPONSIBILITY FALLS ON COUNSEL FOR THE PARTY WHO REMOVED THE CASE; ETC. AS HEREIN. SIGNED BY HONORABLE JOSEPH F. LEESON, JR ON 10/15/20. 10/15/20 ENTERED AND COPIES NOT MAILED TO UNREP AND E-MAILED.(mas, )
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| Filing 7 NOTICE of Appearance by JOHN A. O'CONNELL on behalf of EMERGENCY CARE SERVICES OF PENNSYLVANIA, P.C., EMERGENCY PHYSICIAN ASSOCIATES OF PENNSYLVANIA, P.C. with Certificate of Service(O'CONNELL, JOHN) Modified on 10/15/2020 (lisad, ). |
| Filing 6 NOTICE of Appearance by DAVID P. HEIM on behalf of EMERGENCY CARE SERVICES OF PENNSYLVANIA, P.C., EMERGENCY PHYSICIAN ASSOCIATES OF PENNSYLVANIA, P.C. with Certificate of Service(HEIM, DAVID) Modified on 10/15/2020 (lisad, ). |
| Filing 5 NOTICE of Appearance by GEORGE BOCHETTO on behalf of EMERGENCY CARE SERVICES OF PENNSYLVANIA, P.C., EMERGENCY PHYSICIAN ASSOCIATES OF PENNSYLVANIA, P.C. with Certificate of Service(BOCHETTO, GEORGE) Modified on 10/15/2020 (lisad, ). |
| Filing 4 NOTICE by UNITEDHEALTH GROUP, INC., UNITEDHEALTH NETWORKS, INC., UNITEDHEALTHCARE INSURANCE COMPANY, UNITEDHEALTHCARE OF NEW ENGLAND, INC., UNITEDHEALTHCARE OF PENNSYLVANIA, INC., UNITEDHEALTHCARE SERVICES, INC., UNITEDHEALTHCARE, INC. re #1 Notice of Removal (Attorney),,,, Notice of Filing of Case Opening Forms; Civil Cover Sheet (Attachments: #1 Case Management Track Form, #2 Designation Form)(MYERS, KARL) (Attachment 2 replaced on 10/15/2020) (lisad, ). |
| Filing 3 Disclosure Statement Form pursuant to FRCP 7.1 including UHIC Holdings, Inc.; Three Rivers Holdings, Inc.; AmeriChoice Corporation with Certificate of Service by UNITEDHEALTH GROUP, INC., UNITEDHEALTH NETWORKS, INC., UNITEDHEALTHCARE INSURANCE COMPANY, UNITEDHEALTHCARE OF NEW ENGLAND, INC., UNITEDHEALTHCARE OF PENNSYLVANIA, INC., UNITEDHEALTHCARE SERVICES, INC., UNITEDHEALTHCARE, INC..(MYERS, KARL) |
| Filing 2 NOTICE of Appearance by KARL S. MYERS on behalf of UNITEDHEALTH GROUP, INC., UNITEDHEALTH NETWORKS, INC., UNITEDHEALTHCARE INSURANCE COMPANY, UNITEDHEALTHCARE OF NEW ENGLAND, INC., UNITEDHEALTHCARE OF PENNSYLVANIA, INC., UNITEDHEALTHCARE SERVICES, INC., UNITEDHEALTHCARE, INC. with Certificate of Service (Attachments: #1 Certificate of Service)(MYERS, KARL) |
| Filing 1 NOTICE OF REMOVAL by UNITEDHEALTH NETWORKS, INC., UNITEDHEALTH GROUP, INC., UNITEDHEALTHCARE INSURANCE COMPANY, UNITEDHEALTHCARE OF PENNSYLVANIA, INC., UNITEDHEALTHCARE OF NEW ENGLAND, INC., UNITEDHEALTHCARE SERVICES, INC., UNITEDHEALTHCARE, INC. (Filing fee $ 400 receipt number 0313-14638208), filed by UNITEDHEALTH NETWORKS, INC., UNITEDHEALTH GROUP, INC., UNITEDHEALTHCARE INSURANCE COMPANY, UNITEDHEALTHCARE OF PENNSYLVANIA, INC., UNITEDHEALTHCARE OF NEW ENGLAND, INC., UNITEDHEALTHCARE SERVICES, INC., UNITEDHEALTHCARE, INC.. (Attachments: #1 Exhibit A (Copies of State Court Papers), #2 Exhibit B (MultiPlan Consent), #3 Exhibit C (Plaintiffs' Complaint filed in M.D. Pa.), #4 Exhibit D (State Court Notice of Filing of Notice of Removal), #5 Declaration Stalinski Declaration in Support of Notice of Removal, #6 Exhibit Exhibit 1 to Declaration, #7 Exhibit Exhibit 2 to Declaration, #8 Exhibit Exhibit 3 to Declaration, #9 Exhibit Exhibit 4 to Declaration, #10 Exhibit Exhibit 5 to Declaration, #11 Exhibit Exhibit 6 to Declaration)(MYERS, KARL) |
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