UNITED STATES OF AMERICA, EX REL. ROBERT A. CUTLER v. THE CIGNA GROUP. et al
| Party A, UNITED STATES OF AMERICA, EX REL. ROBERT A. CUTLER and United States of America |
| Party C, Party D, Party E, Party F, Party G, Party H, Party I, Party J, CONNECTICUT GENERAL CORP., HOME PHYSICIANS MANAGEMENT LLC, HealthSpring, Inc., NEW QUEST LLC, CIGNA Holdings, Inc., GULF QUEST LP, CIGNA Corp., HEALTHSPRING LIFE & HEALTH INSURANCE COMPANY, INC., CIGNA Corporation, PHYSICIANS MANAGEMENT LLC, ALEGIS CARE SERVICES, LLC and The Cigna Group |
| Cigna Healthcare of Georgia, Inc., Cigna Healthcare of Colorado, Inc., Bravo Health Mid-Atlantic, Inc., Cigna Healthcare of Connecticut, Inc., Bravo Health Pennsylvania, Inc., Cigna Healthcare of South Carolina, Inc., Cigna Health & Life Ins. Co., Cigna Healthcare of St. Louis, Inc., Cigna Healthcare of California, Inc., Cigna Healthcare of North Carolina, Inc. and HealthSpring of Florida, Inc. |
| 3:2021cv00748 |
| September 29, 2021 |
| US District Court for the Middle District of Tennessee |
| Jeffery S Frensley |
| Eli J Richardson |
| Other Statutes: False Claims Act |
| 31 U.S.C. § 3729 False Claims Act |
| Plaintiff |
Docket Report
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Filing 254
STATUS REPORT (Joint) Regarding ESI Discovery by ALEGIS CARE SERVICES, LLC, CIGNA Corp., CIGNA Holdings, Inc., CONNECTICUT GENERAL CORP., GULF QUEST LP, HEALTHSPRING LIFE & HEALTH INSURANCE COMPANY, INC., HOME PHYSICIANS MANAGEMENT LLC, HealthSpring, Inc., NEW QUEST LLC, PHYSICIANS MANAGEMENT LLC, The Cigna Group. (Ogden, David)
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Filing 253
Joint MOTION for Leave to File Supplemental Briefs re #242 Notice (Other) by ALEGIS CARE SERVICES, LLC, CIGNA Corp., CIGNA Holdings, Inc., CONNECTICUT GENERAL CORP., GULF QUEST LP, HEALTHSPRING LIFE & HEALTH INSURANCE COMPANY, INC., HOME PHYSICIANS MANAGEMENT LLC, HealthSpring, Inc., NEW QUEST LLC, PHYSICIANS MANAGEMENT LLC, The Cigna Group. (Attachments: #1 Exhibit A - Defendants' Response to the Government's Notice Regarding Supervalu)(Ogden, David)
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Filing 252
ORDER granting #243 Motion to Substitute Attorney. Ellen Bowden McIntyre substituted as counsel of record for the United States, and Kara F. Sweet is terminated as counsel of record in this matter. Signed by Magistrate Judge Jeffery S. Frensley on 6/20/2023. (mg)
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Filing 251
Sealed Document Sealed Exhibits A-C to Proposed Second Amended Complaint filed by UNITED STATES OF AMERICA, EX REL. ROBERT A. CUTLER. (Attachments: #1 Exhibit A to Proposed Second Amended Complaint - 360 Comprehensive Assessment Forms, #2 Exhibit B to Proposed Second Amended Complaint - List of Diagnostic Codes, #3 Exhibit C to Proposed Second Amended Complaint - Compilation from Exhs A and B (example of alleged fraud))(Hart, Elizabeth)
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Filing 250
NOTICE of Filing by UNITED STATES OF AMERICA, EX REL. ROBERT A. CUTLER Proposed Second Amended Complaint (Attachments: #1 Attachment Proposed Second Amended Complaint)(Hart, Elizabeth)
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Filing 249
NOTICE of Filing by UNITED STATES OF AMERICA, EX REL. ROBERT A. CUTLER Notice of Compliance with Local Rule 7.01 (Hart, Elizabeth)
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Filing 248
ORDER: This matter is before the Court upon Relator Robert A. Cutler's ("Relator") Motion for Leave to Amend the First Amended Complaint under Fed. R. Civ. P. 15. Docket No. #236 . Relator has not filed the proposed amended pleading along with his Motion as required by the Local Rules. Local Rule 15.01(b) requires that "amended pleadings must restate the entirety of the pleading with the amendments incorporated, rather than merely reciting the amended sections." Although Relator previously filed the Proposed Second Amended Complaint as an exhibit to another pleading, Relator must, no later than June 23, 2023, file the Proposed Second Amended Complaint as a separate document in compliance with Local Rule 15.01. Signed by Magistrate Judge Jeffery S. Frensley on 6/13/2023. (DOCKET TEXT SUMMARY ONLY-ATTORNEYS MUST OPEN THE PDF AND READ THE ORDER.)(mg)
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Filing 247
Joint MOTION for Oral Argument re #198 MOTION to Dismiss Relator's Amended Complaint, #195 MOTION to Dismiss the United States' Complaint-in-Intervention by ALEGIS CARE SERVICES, LLC, CIGNA Corp., CIGNA Holdings, Inc., CONNECTICUT GENERAL CORP., GULF QUEST LP, HEALTHSPRING LIFE & HEALTH INSURANCE COMPANY, INC., HOME PHYSICIANS MANAGEMENT LLC, HealthSpring, Inc., NEW QUEST LLC, PHYSICIANS MANAGEMENT LLC. (Ogden, David)
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Filing 246
ORDER granting #244 Motion. Signed by Magistrate Judge Jeffery S. Frensley on 6/7/2023. (af)
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Filing 245
AMENDED DOCUMENT by CIGNA Corp.. Amendment to #135 Business Entity Disclosure Statement . (Ogden, David)
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Filing 244
MOTION to Amend/Correct Caption and Notice of Name Change by ALEGIS CARE SERVICES, LLC, CIGNA Corp., CIGNA Corporation, CIGNA Holdings, Inc., CONNECTICUT GENERAL CORP., GULF QUEST LP, HEALTHSPRING LIFE & HEALTH INSURANCE COMPANY, INC., HOME PHYSICIANS MANAGEMENT LLC, HealthSpring, Inc., NEW QUEST LLC, PHYSICIANS MANAGEMENT LLC. (Ogden, David)
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Filing 243
MOTION to Substitute Attorney by United States of America. (McIntyre, Ellen)
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Filing 242
NOTICE by United States of America of Supplemental Authority (Attachments: #1 Attachment Opinion in United States ex rel. Schutte v. SuperValu Inc.)(Dolinger, Samuel)
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Filing 241
ORDER: MOTION #239 FOR EXTENSION OF TIME TO FILE ESI STATUS REPORT GRANTED. Signed by Magistrate Judge Jeffery S. Frensley on 05/30/23. (ad)
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Filing 240
REPLY to Response to re #236 MOTION to Amend/Correct First Amended Complaint filed by UNITED STATES OF AMERICA, EX REL. ROBERT A. CUTLER. (Swafford, Tara)
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Filing 239
Joint MOTION for Extension of Time to File Joint Report on the Status of ESI Discovery by United States of America. (Dolinger, Samuel)
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Filing 238
RESPONSE in Opposition re #236 MOTION to Amend/Correct First Amended Complaint filed by ALEGIS CARE SERVICES, LLC, CIGNA Corp., CIGNA Corporation, CIGNA Holdings, Inc., CONNECTICUT GENERAL CORP., GULF QUEST LP, HEALTHSPRING LIFE & HEALTH INSURANCE COMPANY, INC., HOME PHYSICIANS MANAGEMENT LLC, HealthSpring, Inc., NEW QUEST LLC, PHYSICIANS MANAGEMENT LLC. (Attachments: #1 Exhibit 1 - February 15, 2023 Emails Between Cutler, the Government, and Cigna, #2 Exhibit 2 - February 17, 2023 Emails Between Cutler, the Government, and Cigna, #3 Exhibit 3 - April 3-4, 2023 Emails Between Cutler, the Government, and Cigna)(Ogden, David)
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Filing 237
MEMORANDUM in Support of #236 MOTION to Amend/Correct First Amended Complaint filed by UNITED STATES OF AMERICA, EX REL. ROBERT A. CUTLER . (Swafford, Tara)
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Filing 236
MOTION to Amend/Correct First Amended Complaint by UNITED STATES OF AMERICA, EX REL. ROBERT A. CUTLER. (Swafford, Tara)
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Filing 235
ORDER granting #231 Motion to Seal Exhibits A-C to Second Amended Complaint by UNITED STATES OF AMERICA, EX REL. ROBERT A. CUTLER. Signed by Magistrate Judge Jeffery S. Frensley on 05/01/23. (DOCKET TEXT SUMMARY ONLY-ATTORNEYS MUST OPEN THE PDF AND READ THE ORDER.)(ad)
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Filing 234
ORDER: Pending before the Court are two motions to dismiss (Doc. Nos. #195 , #198 ). The motion to dismiss at Doc. No. #198 seeks to dismiss the Relator's amended complaint at Doc. No. #12 . In his response to the motion to dismiss the amended complaint at Doc. No. #12 , the Relator requested leave to file a second-amended complaint. (Doc. No. #214 ). Local Rule 15.01 requires a party seeking to amend their pleading to file a motion requesting permission to do so. As stated in the Court's revised initial case management order (Doc. No. #229 ), motions to amend or to add parties must be filed on or before September 14, 2023 and must comply with Local Rules 15.01 and 7.01. Signed by District Judge Eli J. Richardson on 04/10/23. (DOCKET TEXT SUMMARY ONLY-ATTORNEYS MUST OPEN THE PDF AND READ THE ORDER.)(ad)
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Filing 233
Sealed Document filed by UNITED STATES OF AMERICA, EX REL. ROBERT A. CUTLER. (Attachments: #1 Exhibit A to Proposed Second Amended Complaint - 360 Comprehensive Assessment Forms, #2 Exhibit B to Proposed Second Amended Complaint - List of Diagnostic Codes, #3 Exhibit C to Proposed Second Amended Complaint - Compilation from Exhs A and B (example of alleged fraud))(Hart, Elizabeth)
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Filing 232
MEMORANDUM in Support of #231 MOTION to Seal Exhibits A-C to Second Amended Complaint filed by UNITED STATES OF AMERICA, EX REL. ROBERT A. CUTLER . (Hart, Elizabeth)
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Filing 231
MOTION to Seal Exhibits A-C to Second Amended Complaint by UNITED STATES OF AMERICA, EX REL. ROBERT A. CUTLER. (Hart, Elizabeth)
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Filing 230
ORDER SETTING CASE FOR TRIAL: Jury Trial set for 10/14/2025 at 09:00 AM in Courtroom 5C before District Judge Eli J. Richardson. Pretrial Conference set for 10/6/2025 at 08:30 AM in Courtroom 5C before District Judge Eli J. Richardson. Exhibit List due by 9/29/2025. Witness List due by 9/29/2025. Joint Proposed Pretrial Order due by 9/29/2025. Signed by District Judge Eli J. Richardson on 03/31/23. (DOCKET TEXT SUMMARY ONLY-ATTORNEYS MUST OPEN THE PDF AND READ THE ORDER.)(ad)
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Filing 229
REVISED INITIAL CASE MANAGEMENT ORDER: Amended Pleadings due by 9/14/2023. Discovery due by 9/22/2024. Dispositive Motions due by 4/10/2025. Joint Status Report due by 9/1/2023. Telephone Conference set for 1/17/2024 08:30 AM before Magistrate Judge Jeffery S. Frensley. Signed by Magistrate Judge Jeffery S. Frensley on 03/30/23. (DOCKET TEXT SUMMARY ONLY-ATTORNEYS MUST OPEN THE PDF AND READ THE ORDER.)(ad)
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Minute Entry for proceedings held before Magistrate Judge Jeffery S. Frensley: Case Management Conference by Telephone held on 3/30/2023. (Hearing lasted :24)(sm)
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Filing 228
STIPULATED PROTECTIVE ORDER. Signed by Magistrate Judge Jeffery S. Frensley on 03/29/23. (DOCKET TEXT SUMMARY ONLY-ATTORNEYS MUST OPEN THE PDF AND READ THE ORDER.)(ad)
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Filing 227
ORDER #226 MOTION GRANTED. Signed by Magistrate Judge Jeffery S. Frensley on 03/29/23. (ad)
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Filing 226
Joint MOTION for Protective Order by United States of America. (Attachments: #1 Attachment Proposed Stipulated Protective Order)(Dolinger, Samuel)
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Filing 225
REPLY to Response to re #198 MOTION to Dismiss Relator's Amended Complaint filed by ALEGIS CARE SERVICES, LLC, CIGNA Corp., CIGNA Corporation, CIGNA Holdings, Inc., CONNECTICUT GENERAL CORP., GULF QUEST LP, HEALTHSPRING LIFE & HEALTH INSURANCE COMPANY, INC., HOME PHYSICIANS MANAGEMENT LLC, HealthSpring, Inc., NEW QUEST LLC, PHYSICIANS MANAGEMENT LLC. (Ogden, David)
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Filing 224
REPLY to Response to re #195 MOTION to Dismiss the United States' Complaint-in-Intervention filed by ALEGIS CARE SERVICES, LLC, CIGNA Corp., CIGNA Corporation, CIGNA Holdings, Inc., CONNECTICUT GENERAL CORP., GULF QUEST LP, HEALTHSPRING LIFE & HEALTH INSURANCE COMPANY, INC., HOME PHYSICIANS MANAGEMENT LLC, HealthSpring, Inc., NEW QUEST LLC, PHYSICIANS MANAGEMENT LLC. (Ogden, David)
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Filing 223
PROPOSED CASE MANAGEMENT ORDER (Revised) filed by ALEGIS CARE SERVICES, LLC, CIGNA Corp., CIGNA Corporation, CIGNA Holdings, Inc., CONNECTICUT GENERAL CORP., GULF QUEST LP, HEALTHSPRING LIFE & HEALTH INSURANCE COMPANY, INC., HOME PHYSICIANS MANAGEMENT LLC, HealthSpring, Inc., NEW QUEST LLC, PHYSICIANS MANAGEMENT LLC. (Ogden, David)
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Filing 222
ORDER: As the Court has recently ruled on the motion to stay and no proposed case management order has been filed, the Initial Case Management Conference set for March 9, 2023 at 10:00 a.m. is hereby reset for March 30, 2023, at 9:30 a.m. via telephone. The parties shall call 1-877-336-1831 at the appointed time, and when prompted for the access code, enter 7039387# to participate in the Conference. If a party has difficulty connecting to the call or has been on hold for more than five (5) minutes, please contact chambers at 615-736-7344. Signed by Magistrate Judge Jeffery S. Frensley on 3/8/2023. (kc)
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Filing 221
ORDER denying #205 Motion to Stay. Signed by Magistrate Judge Jeffery S. Frensley on 03/03/23. (DOCKET TEXT SUMMARY ONLY-ATTORNEYS MUST OPEN THE PDF AND READ THE ORDER.)(ad)
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Filing 220
ORDER granting #215 Motion for Leave to File Excess Pages. Signed by Magistrate Judge Jeffery S. Frensley on 02/28/23. (DOCKET TEXT SUMMARY ONLY-ATTORNEYS MUST OPEN THE PDF AND READ THE ORDER.)(ad)
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Filing 219
ORDER: Due to a conflict in the Court's calendar, the Case Management Conference set for March 6, 2023 at 10:00 a.m. is hereby RESET for March 9, 2023 at 10:00 a.m. via telephone. The parties shall call 1-877-336-1831 at the appointed time, and when prompted for the access code, enter 7039387# to participate in the Conference. If a party has difficulty connecting to the call or has been on hold for more than five (5) minutes, please contact the chambers at 615-736-7344. Signed by Magistrate Judge Jeffery S. Frensley on 02/27/23. (DOCKET TEXT SUMMARY ONLY-ATTORNEYS MUST OPEN THE PDF AND READ THE ORDER.)(ad)
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Filing 218
REPLY to Response to re #205 MOTION to Stay Discovery filed by ALEGIS CARE SERVICES, LLC, CIGNA Corp., CIGNA Corporation, CIGNA Holdings, Inc., CONNECTICUT GENERAL CORP., GULF QUEST LP, HEALTHSPRING LIFE & HEALTH INSURANCE COMPANY, INC., HOME PHYSICIANS MANAGEMENT LLC, HealthSpring, Inc., NEW QUEST LLC, PHYSICIANS MANAGEMENT LLC. (Ogden, David)
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Filing 217
ORDER granting #216 Motion for Leave to file redacted Exhibit A to Relator's Response to Defendants' Motion to Dismiss. Signed by District Judge Eli J. Richardson on 02/23/23. (DOCKET TEXT SUMMARY ONLY-ATTORNEYS MUST OPEN THE PDF AND READ THE ORDER.)(ad)
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Filing 216
Unopposed MOTION for Leave to File Redacted Exhibit re #214 Response in Opposition to Motion, by UNITED STATES OF AMERICA, EX REL. ROBERT A. CUTLER. (Attachments: #1 Attachment Memorandum in Support of Motion to Redact Exhibit)(Swafford, Tara)
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Filing 215
Unopposed MOTION for Leave to File Excess Pages by ALEGIS CARE SERVICES, LLC, CIGNA Corp., CIGNA Corporation, CIGNA Holdings, Inc., CONNECTICUT GENERAL CORP., GULF QUEST LP, HEALTHSPRING LIFE & HEALTH INSURANCE COMPANY, INC., HOME PHYSICIANS MANAGEMENT LLC, HealthSpring, Inc., NEW QUEST LLC, PHYSICIANS MANAGEMENT LLC. (Ogden, David)
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Filing 214
RESPONSE in Opposition re #198 MOTION to Dismiss Relator's Amended Complaint filed by UNITED STATES OF AMERICA, EX REL. ROBERT A. CUTLER. (Attachments: #1 Exhibit A - 360 Form, #2 Exhibit B - Business Service Agreement, #3 Exhibit C - Nov. 25, 2020 S.D. Ind. Order, #4 Exhibit D - Proposed Second Amended Complaint)(Hart, Elizabeth)
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Filing 213
RESPONSE in Opposition re #195 MOTION to Dismiss the United States' Complaint-in-Intervention filed by United States of America. (Barnea, Jean-David)
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Filing 212
ORDER granting #209 : Having satisfied the requirements of Local Rule 83.01(b), the Motion for Samuel Dolinger to Appear Pro Hac Vice is granted. Signed by Lynda M. Hill, Clerk of Court, on 02/03/2023. (lh)
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Filing 211
RESPONSE in Opposition re #205 MOTION to Stay Discovery filed by UNITED STATES OF AMERICA, EX REL. ROBERT A. CUTLER. (Swafford, Tara)
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Filing 210
RESPONSE in Opposition re #205 MOTION to Stay Discovery filed by United States of America. (Aronoff, Peter)
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Filing 209
MOTION for attorney Samuel Dolinger to Appear Pro Hac Vice (Fee not paid-due within 21 days) by United States of America. (Attachments: #1 Exhibit certificate of good standing)(Aronoff, Peter)
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Filing 208
ORDER granting #207 Motion for Extension of Time to File Response/Reply. Response/Reply due February 23. The Initial Case Management Conference is hereby reset to March 6, 2023 at 10:00 a.m. via telephone to allow the Court to consider the motion to stay. All parties shall call 1-877-336-1831, and when prompted for the access code, enter 7039387# to participate. If a party has difficulty connecting to the call or has been on hold for more than five (5) minutes, please call 615-736-7344. Signed by Magistrate Judge Jeffery S. Frensley on 01/10/23. (DOCKET TEXT SUMMARY ONLY-ATTORNEYS MUST OPEN THE PDF AND READ THE ORDER.)(ad)
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Reset Hearing: Initial Case Management Conference by Telephone set for 3/6/2023 at 10:00 AM before Magistrate Judge Jeffery S. Frensley. (ad)
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Filing 207
Joint MOTION for Extension of Time to File Response/Reply as to #205 MOTION to Stay Discovery by ALEGIS CARE SERVICES, LLC, CIGNA Corp., CIGNA Corporation, CIGNA Holdings, Inc., CONNECTICUT GENERAL CORP., GULF QUEST LP, HEALTHSPRING LIFE & HEALTH INSURANCE COMPANY, INC., HealthSpring, Inc., NEW QUEST LLC, PHYSICIANS MANAGEMENT LLC. (Ogden, David)
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Filing 206
MEMORANDUM in Support of #205 MOTION to Stay Discovery filed by ALEGIS CARE SERVICES, LLC, CIGNA Corp., CIGNA Corporation, CIGNA Holdings, Inc., CONNECTICUT GENERAL CORP., GULF QUEST LP, HEALTHSPRING LIFE & HEALTH INSURANCE COMPANY, INC., HOME PHYSICIANS MANAGEMENT LLC, HealthSpring, Inc., NEW QUEST LLC, PHYSICIANS MANAGEMENT LLC . (Ogden, David)
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Filing 205
MOTION to Stay Discovery by ALEGIS CARE SERVICES, LLC, CIGNA Corp., CIGNA Corporation, CIGNA Holdings, Inc., CONNECTICUT GENERAL CORP., GULF QUEST LP, HEALTHSPRING LIFE & HEALTH INSURANCE COMPANY, INC., HOME PHYSICIANS MANAGEMENT LLC, HealthSpring, Inc., NEW QUEST LLC, PHYSICIANS MANAGEMENT LLC. (Ogden, David)
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Filing 204
ORDER: The #203 JOINT MOTION FOR EXTENSION OF TIME AND TO EXCEED PAGE LIMITS is granted. Responses due February 15, 2023 and replies due March 17, 2023. Signed by District Judge Eli J. Richardson on 12/28/22. (DOCKET TEXT SUMMARY ONLY-ATTORNEYS MUST OPEN THE PDF AND READ THE ORDER.)(ad)
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Filing 203
MOTION for Extension of Time to File Response/Reply as to #198 MOTION to Dismiss Relator's Amended Complaint, #195 MOTION to Dismiss the United States' Complaint-in-Intervention , MOTION for Leave to File Excess Pages by United States of America. (Sweet, Kara)
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Filing 202
ORDER granting #193 : Having satisfied the requirements of Local Rule 83.01(b), the Motion for Jean-David Barnea to Appear Pro Hac Vice is granted. Signed by Lynda M. Hill, Clerk of Court, on 12/20/2022. (lh)
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Filing 201
ORDER: Due to a conflict in the Court's calendar, the Status Conference set for December 21, 2022 at 8:30 a.m. is hereby RESET for January 19, 2023 at 9:30 a.m. via telephone. The parties shall call 1-877-336-1831 at the appointed time, and when prompted for the access code, enter 7039387# to participate in the Conference. If a party has difficulty connecting to the call or has been on hold for more than five (5) minutes, please contact the chambers at 615-736-7344. Signed by Magistrate Judge Jeffery S. Frensley on 12/20/22. (ad)
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Filing 200
DECLARATION of Charles C. Speth filed by ALEGIS CARE SERVICES, LLC, CIGNA Corp., CIGNA Corporation, CIGNA Holdings, Inc., CONNECTICUT GENERAL CORP., GULF QUEST LP, HEALTHSPRING LIFE & HEALTH INSURANCE COMPANY, INC., HOME PHYSICIANS MANAGEMENT LLC, HealthSpring, Inc., NEW QUEST LLC, PHYSICIANS MANAGEMENT LLC re: #198 MOTION to Dismiss Relator's Amended Complaint. (Attachments: #1 Exhibit A - Alegis Contract, #2 Exhibit B - THM Contract, #3 Exhibit C - EMSI Contract, #4 Exhibit D - 360 Comprehensive Assessment)(Ogden, David)
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Filing 199
MEMORANDUM in Support of #198 MOTION to Dismiss Relator's Amended Complaint filed by ALEGIS CARE SERVICES, LLC, CIGNA Corp., CIGNA Corporation, CIGNA Holdings, Inc., CONNECTICUT GENERAL CORP., GULF QUEST LP, HEALTHSPRING LIFE & HEALTH INSURANCE COMPANY, INC., HOME PHYSICIANS MANAGEMENT LLC, HealthSpring, Inc., NEW QUEST LLC, PHYSICIANS MANAGEMENT LLC . (Ogden, David)
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Filing 198
MOTION to Dismiss Relator's Amended Complaint by ALEGIS CARE SERVICES, LLC, CIGNA Corp., CIGNA Corporation, CIGNA Holdings, Inc., CONNECTICUT GENERAL CORP., GULF QUEST LP, HEALTHSPRING LIFE & HEALTH INSURANCE COMPANY, INC., HOME PHYSICIANS MANAGEMENT LLC, HealthSpring, Inc., NEW QUEST LLC, PHYSICIANS MANAGEMENT LLC. (Ogden, David)
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Filing 197
DECLARATION of Charles C. Speth filed by ALEGIS CARE SERVICES, LLC, CIGNA Corp., CIGNA Corporation, CIGNA Holdings, Inc., CONNECTICUT GENERAL CORP., GULF QUEST LP, HEALTHSPRING LIFE & HEALTH INSURANCE COMPANY, INC., HOME PHYSICIANS MANAGEMENT LLC, HealthSpring, Inc., NEW QUEST LLC, PHYSICIANS MANAGEMENT LLC re: #195 MOTION to Dismiss the United States' Complaint-in-Intervention. (Attachments: #1 Exhibit A - Alegis Contract, #2 Exhibit B - THM Contract, #3 Exhibit C - EMSI Contract, #4 Exhibit D - 360 Comprehensive Assessment)(Ogden, David)
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Filing 196
MEMORANDUM in Support of #195 MOTION to Dismiss the United States' Complaint-in-Intervention filed by ALEGIS CARE SERVICES, LLC, CIGNA Corp., CIGNA Corporation, CIGNA Holdings, Inc., CONNECTICUT GENERAL CORP., GULF QUEST LP, HEALTHSPRING LIFE & HEALTH INSURANCE COMPANY, INC., HOME PHYSICIANS MANAGEMENT LLC, HealthSpring, Inc., NEW QUEST LLC, PHYSICIANS MANAGEMENT LLC . (Ogden, David)
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Filing 195
MOTION to Dismiss the United States' Complaint-in-Intervention by ALEGIS CARE SERVICES, LLC, CIGNA Corp., CIGNA Corporation, CIGNA Holdings, Inc., CONNECTICUT GENERAL CORP., GULF QUEST LP, HEALTHSPRING LIFE & HEALTH INSURANCE COMPANY, INC., HOME PHYSICIANS MANAGEMENT LLC, HealthSpring, Inc., NEW QUEST LLC, PHYSICIANS MANAGEMENT LLC. (Ogden, David)
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Filing 194
PROPOSED CASE MANAGEMENT ORDER filed by United States of America. (Sweet, Kara)
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Filing 193
MOTION for attorney Jean-David Barnea to Appear Pro Hac Vice (Fee not paid-due within 21 days) by United States of America. (Attachments: #1 Attachment Certificate of Good Standing)(Sweet, Kara)
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Filing 192
ORDER granting #191 UNOPPOSED MOTION TO MODIFY PAGE LIMITATIONS. Defendants anticipate filing two motions to dismiss, one seeking dismissal of the Government's complaint-in-intervention and one seeking dismissal of Relator's amended complaint to the extent his claims are not superseded by the Government's complaint-in-intervention. To streamline the presentation of arguments for dismissal of each complaint, Defendants respectfully request leave to file an identical 45-page memorandum of law in support of each of the two motions. Signed by District Judge Eli J. Richardson on 12/08/22. (DOCKET TEXT SUMMARY ONLY-ATTORNEYS MUST OPEN THE PDF AND READ THE ORDER.)(ad)
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Filing 191
Unopposed MOTION to Modify Page Limitations by ALEGIS CARE SERVICES, LLC, CIGNA Corp., CIGNA Corporation, CIGNA Holdings, Inc., CONNECTICUT GENERAL CORP., GULF QUEST LP, HEALTHSPRING LIFE & HEALTH INSURANCE COMPANY, INC., HOME PHYSICIANS MANAGEMENT LLC, HealthSpring, Inc., NEW QUEST LLC, PHYSICIANS MANAGEMENT LLC. (Ogden, David)
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Filing 190
WAIVER OF SERVICE Returned Executed by United States of America. HealthSpring of Florida, Inc. waiver sent on 10/28/2022. (Sweet, Kara)
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Filing 189
WAIVER OF SERVICE Returned Executed by United States of America. HEALTHSPRING LIFE & HEALTH INSURANCE COMPANY, INC. waiver sent on 10/28/2022. (Sweet, Kara)
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Filing 188
WAIVER OF SERVICE Returned Executed by United States of America. Cigna Healthcare of St. Louis, Inc. waiver sent on 10/28/2022. (Sweet, Kara)
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Filing 187
WAIVER OF SERVICE Returned Executed by United States of America. Cigna Healthcare of South Carolina, Inc. waiver sent on 10/28/2022. (Sweet, Kara)
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Filing 186
WAIVER OF SERVICE Returned Executed by United States of America. Cigna Healthcare of North Carolina, Inc. waiver sent on 10/28/2022. (Sweet, Kara)
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Filing 185
WAIVER OF SERVICE Returned Executed by United States of America. Cigna Healthcare of Connecticut, Inc. waiver sent on 10/28/2022. (Sweet, Kara)
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Filing 184
WAIVER OF SERVICE Returned Executed by United States of America. Cigna Healthcare of Colorado, Inc. waiver sent on 10/28/2022. (Sweet, Kara)
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Filing 183
WAIVER OF SERVICE Returned Executed by United States of America. Cigna Healthcare of California, Inc. waiver sent on 10/28/2022. (Sweet, Kara)
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Filing 182
WAIVER OF SERVICE Returned Executed by United States of America. Cigna Health & Life Ins. Co. waiver sent on 10/28/2022. (Sweet, Kara)
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Filing 181
WAIVER OF SERVICE Returned Executed by United States of America. CIGNA Corporation waiver sent on 10/28/2022. (Sweet, Kara)
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Filing 180
WAIVER OF SERVICE Returned Executed by United States of America. Bravo Health Pennsylvania, Inc. waiver sent on 10/28/2022. (Sweet, Kara)
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Filing 179
WAIVER OF SERVICE Returned Executed by United States of America. Bravo Health Mid-Atlantic, Inc. waiver sent on 10/28/2022. (Sweet, Kara)
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Filing 178
Intervenor COMPLAINT , filed by United States of America.(Aronoff, Peter)
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Filing 177
ORDER: The Joint Motion for Extension of Time to file Complaint in Intervention and for Defendants to File a Response Thereto, and to Reschedule Case Management Conference ( #176 ) is GRANTED. The deadline for the United States to file a complaint in intervention is extended to October 14, 2022. The Defendant's time to answer is extended to December 16, 2022. The Case Management Conference set for November 28, 2022, is RESCHEDULED to December 21, 2022, at 8:30 a.m. by telephone. Signed by Magistrate Judge Jeffery S. Frensley on 9/23/2022. (DOCKET TEXT SUMMARY ONLY-ATTORNEYS MUST OPEN THE PDF AND READ THE ORDER.)(gb)
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Set/Reset Hearings: Case Management Conference by Telephone RESET for 12/21/2022 at 08:30 AM before Magistrate Judge Jeffery S. Frensley. (gb)
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Filing 176
Joint MOTION for Extension of Time to File COMPLAINT-IN-INTERVENTION AND FOR DEFENDANTS TO FILE A RESPONSE THERETO, AND TO RESCHEDULE CASE MANAGEMENT CONFERENCE by United States of America. (Sweet, Kara)
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Filing 175
ORDER: The Joint Motion for Extension of Time to file Complaint in Intervention and for Defendants to File a Response Thereto, and to Reschedule Case Management Conference #174 is GRANTED. The deadline for the United States to file a complaint in intervention is extended to September 30, 2022. The Defendant's time to answer is extended to November 18, 2022. The Initial Case Management Conference set for September 27, 2022, is RESCHEDULED to November 28, 2022, at 9:30 a.m. by telephone. The Parties shall call 1-877-336-1831 at the appointed time, and when prompted for the access code, enter 7039387# to participate in the Conference. Signed by Magistrate Judge Jeffery S. Frensley on 8/24/2022. (DOCKET TEXT SUMMARY ONLY-ATTORNEYS MUST OPEN THE PDF AND READ THE ORDER.)(kc)
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Reset Hearing per Order #175 : Case Management Conference by Telephone is set for 11/28/2022 at 9:30 AM before Magistrate Judge Jeffery S. Frensley. (kc)
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Filing 174
Joint MOTION for Extension of Time to File Complaint In Intervention and for Defendants to File a Response Thereto, and to Reschedule Case Management Conference by United States of America. (Sweet, Kara)
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Filing 173
ORDER: The Notice perhaps could have been stronger in its expression of mea culpas. But in any event, counsel for Defendants at least acknowledged the issue and pledged to take[ ] to heart the Courts stated concern. From the undersigned's perspective, nothing further needs be said except to direct counsel on both sides who very likely need no reminder in any event to conduct themselves accordingly. Signed by District Judge Eli J. Richardson on 8/8/2022. (DOCKET TEXT SUMMARY ONLY-ATTORNEYS MUST OPEN THE PDF AND READ THE ORDER.)(jm) (Main Document 173 replaced on 8/8/2022) (jm). Modified text on 8/25/2022 (hb).
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Filing 172
NOTICE by ALEGIS CARE SERVICES, LLC, CIGNA Corp., CIGNA Corporation, CIGNA Holdings, Inc., CONNECTICUT GENERAL CORP., GULF QUEST LP, HEALTHSPRING LIFE & HEALTH INSURANCE COMPANY, INC., HOME PHYSICIANS MANAGEMENT LLC, HealthSpring, Inc., NEW QUEST LLC, PHYSICIANS MANAGEMENT LLC re #169 Memorandum Opinion of the Court (Notice Regarding Citation) (Ogden, David)
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Filing 171
ORDER: A Case Management Conference in this matter is set for September 27, 2022 at 8:30 a.m. The Parties shall call 1-877-336-1831 at the appointed time, and when prompted for the access code, enter 7039387# to participate in the Conference. If a party has difficulty connecting to the call or has been on hold for more than five (5) minutes, please contact chambers at 615-736-7344. Signed by Magistrate Judge Jeffery S. Frensley on 8/3/2022. (DOCKET TEXT SUMMARY ONLY-ATTORNEYS MUST OPEN THE PDF AND READ THE ORDER.)(jm)
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Filing 170
ORDER granting #157 Motion to Intervene. The Government may file its complaint in intervention within thirty (30) days from the date of this Order. IT IS SO ORDERED. Signed by District Judge Eli J. Richardson on 8/2/2022. (DOCKET TEXT SUMMARY ONLY-ATTORNEYS MUST OPEN THE PDF AND READ THE ORDER.)(hb)
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Filing 169
MEMORANDUM OPINION OF THE COURT. Signed by District Judge Eli J. Richardson on 8/2/2022. (DOCKET TEXT SUMMARY ONLY-ATTORNEYS MUST OPEN THE PDF AND READ THE ORDER.)(hb)
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Filing 168
ORDER granting #160 Motion to Substitute Attorney. Attorney Ellen Bowden McIntyre terminated. Signed by Magistrate Judge Jeffery S. Frensley on 3/14/2022. (DOCKET TEXT SUMMARY ONLY-ATTORNEYS MUST OPEN THE PDF AND READ THE ORDER.)(kc)
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Filing 167
ORDER granting #163 : Having satisfied the requirements of Local Rule 83.01(b), the Motion for Peter M. Aronoff to Appear Pro Hac Vice is granted. Signed by Lynda Hill, Clerk of Court, on 02/02/2022. (lh)
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Filing 166
REPLY filed by United States of America re #157 Motion to Intervene filed by United States of America. (Sweet, Kara)
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Filing 165
ORDER granting #164 Motion for Leave to File Excess Pages. Signed by District Judge Eli J. Richardson on 1/28/2022. (jm)
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NY State Bar status verified as active for Kara F. Sweet admitted to this court. (jm)
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Filing 164
MOTION for Leave to File Excess Pages by United States of America. (Sweet, Kara)
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Filing 163
MOTION for attorney PETER M. ARONOFF to Appear Pro Hac Vice (Fee not required) by United States of America. (Attachments: #1 Attachment Certificate of Good Standing)(Sweet, Kara) Modified on 2/2/2022 (jm).
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Filing 162
NOTICE of Appearance by Kara F. Sweet on behalf of United States of America (Sweet, Kara)
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Filing 161
RESPONSE in Opposition re #157 Partial MOTION to Intervene filed by ALEGIS CARE SERVICES, LLC, CIGNA Corp., CIGNA Corporation, CIGNA Holdings, Inc., CONNECTICUT GENERAL CORP., GULF QUEST LP, HEALTHSPRING LIFE & HEALTH INSURANCE COMPANY, INC., HOME PHYSICIANS MANAGEMENT LLC, HealthSpring, Inc., NEW QUEST LLC, PHYSICIANS MANAGEMENT LLC. (Ogden, David)
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Filing 160
MOTION to Substitute Attorney by United States of America. (Sweet, Kara)
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Filing 159
ORDER: In light of the Government's motion to intervene (Docket No. #157 ), the Initial Case Management Conference set for January 12, 2022 at 10:00 a.m. is hereby CANCELLED. It will be reset by separate order following resolution of the motion to intervene. Signed by Magistrate Judge Jeffery S. Frensley on 1/12/2022. (ln)
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Filing 158
MEMORANDUM in Support of #157 Partial MOTION to Intervene filed by United States of America . (McIntyre, Ellen)
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Filing 157
Partial MOTION to Intervene by United States of America. (McIntyre, Ellen)
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Filing 156
PROPOSED CASE MANAGEMENT ORDER (Joint) filed by UNITED STATES OF AMERICA, EX REL. ROBERT A. CUTLER. (Hart, Elizabeth)
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Filing 155
ORDER: Due to a conflict in the Court's calendar, the Initial Case Management Conference previously set for January 6, 2022 at 10:00 a.m., is hereby RESET for January 12, 2022 at 10:00 a.m. via telephone. All parties shall call 1-877-336-1831, and when prompted for the access code, enter 7039387# to participate in the Case Management Conference. If a party has difficulty connecting to the call or has been on hold for more than five (5) minutes, please call 615-736-7344. Signed by Magistrate Judge Jeffery S. Frensley on 12/29/2021. (DOCKET TEXT SUMMARY ONLY-ATTORNEYS MUST OPEN THE PDF AND READ THE ORDER.)(bs)
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Filing 154
ORDER granting #152 Motion. The Initial Case Management Conference is hereby reset to January 6, 2022 at 10:00 a.m. via telephone. All parties shall call 1-877-336-1831, and when prompted for the access code, enter 7039387# to participate. If a party has difficulty connecting to the call or has been on hold for more than five (5) minutes, please call 615-736-7344. Signed by Magistrate Judge Jeffery S. Frensley on 11/24/2021. (jm)
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Reset Hearing: Initial Case Management Conference by Telephone set for 1/6/2022 at 10:00 AM before Magistrate Judge Jeffery S. Frensley. (jm)
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Filing 153
RESPONSE in Opposition re #152 MOTION TO RESCHEDULE INITIAL CASE MANAGEMENT CONFERENCE re #133 Notice of Case Management Conference filed by ALEGIS CARE SERVICES, LLC, CIGNA Corp., CIGNA Corporation, CIGNA Holdings, Inc., CONNECTICUT GENERAL CORP., GULF QUEST LP, HEALTHSPRING LIFE & HEALTH INSURANCE COMPANY, INC., HOME PHYSICIANS MANAGEMENT LLC, HealthSpring, Inc., NEW QUEST LLC, PHYSICIANS MANAGEMENT LLC. (Ogden, David)
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Filing 152
MOTION TO RESCHEDULE INITIAL CASE MANAGEMENT CONFERENCE re #133 Notice of Case Management Conference by United States of America. (McIntyre, Ellen)
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TN State Bar status verified as active for Elizabeth G. Hart, Tara L. Swafford, and William Lee Maddux admitted to this court. (jm)
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Filing 151
NOTICE of Appearance by Elizabeth G. Hart on behalf of UNITED STATES OF AMERICA, EX REL. ROBERT A. CUTLER (Hart, Elizabeth)
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Filing 150
ORDER granting #144 , #145 , #146 , and #147 : Having satisfied the requirements of Local Rule 83.01(b), the Motions for Kevin M. Lamb, David W. Ogden, Howard M. Shapiro, and Charles C. Speth to Appear Pro Hac Vice are granted. Signed by Lynda M. Hill, Clerk of Court, on 11/01/2021. (lh)
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Filing 149
NOTICE of Filing by ALEGIS CARE SERVICES, LLC, CIGNA Corp., CIGNA Corporation, CIGNA Holdings, Inc., CONNECTICUT GENERAL CORP., GULF QUEST LP, HEALTHSPRING LIFE & HEALTH INSURANCE COMPANY, INC., HOME PHYSICIANS MANAGEMENT LLC, HealthSpring, Inc., NEW QUEST LLC, PHYSICIANS MANAGEMENT LLC re #146 MOTION for attorney Howard M. Shapiro to Appear Pro Hac Vice (paid $150 PHV fee; receipt number 0650-3473940), #144 MOTION for attorney Kevin M. Lamb to Appear Pro Hac Vice (paid $150 PHV fee; receipt number 0650-3473855), #145 MOTION for attorney David W. Ogden to Appear Pro Hac Vice (paid $150 PHV fee; receipt number 0650-3473933), #147 MOTION for attorney Charles C. Speth to Appear Pro Hac Vice (paid $150 PHV fee; receipt number 0650-3473945) Supplemental Declarations in Support of the Motions for Admission Pro Hac Vice (Attachments: #1 Attachment Supplemental Declaration of David W. Ogden, #2 Attachment Supplemental Declaration of Howard M. Shapiro, #3 Attachment Supplemental Declaration of Charles C. Speth, #4 Attachment Supplemental Declaration of Kevin M. Lamb)(Potter, Thomas)
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NOTICE TO FILER re DE# [144, 145, 146, and 147]: The pending pro hac vice motion does not comply with the Court's local rules, because the motion fails to state whether disciplinary proceedings by any disciplinary authority, a finding of contempt or a sanction under 28 U.S.C. 1927 by any court, or criminal charges have been instituted against the attorney seeking pro hac vice admission. Local Rule 83.01(b)(2). By no later than five (5) business days from the date of this docket annotation, the pro hac vice motion must be supplemented by the filing of a statement under oath of the attorney seeking pro hac vice admission disclosing such matters. Failure to do so will result in denial of the pro hac vice motion. (jm)
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DC Bar status verified as active for Howard M. Shapiro, Kevin Matthew Lamb, David William Ogden, and Charles Speth not admitted to this court - Local counsel secured. (jm)
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TN State Bar status verified as active for Thomas K. Potter, III and J. Alex Little admitted to this court. (jm)
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Filing 148
ORDER: On October 27, 2021, the undersigned's chambers received a phone call from the relator requesting an extension of the October 27, 2021 deadline to have current counsel associate local counsel qualified to practice in the U.S. District Court for the Middle District of Tennessee as prescribed by the third Docket Entry dated October 6, 2021. The relator requests an additional week to acquire local counsel. The request is GRANTED. As such, the deadline is extended to November 3, 2021. Signed by District Judge Eli J. Richardson on 10/27/2021. (jm)
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Filing 147
MOTION for attorney Charles C. Speth to Appear Pro Hac Vice (paid $150 PHV fee; receipt number 0650-3473945) by ALEGIS CARE SERVICES, LLC, CIGNA Corp., CIGNA Corporation, CIGNA Holdings, Inc., CONNECTICUT GENERAL CORP., GULF QUEST LP, HEALTHSPRING LIFE & HEALTH INSURANCE COMPANY, INC., HOME PHYSICIANS MANAGEMENT LLC, HealthSpring, Inc., NEW QUEST LLC, PHYSICIANS MANAGEMENT LLC. (Attachments: #1 Attachment Certificate of Good Standing)(Potter, Thomas)
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Filing 146
MOTION for attorney Howard M. Shapiro to Appear Pro Hac Vice (paid $150 PHV fee; receipt number 0650-3473940) by ALEGIS CARE SERVICES, LLC, CIGNA Corp., CIGNA Corporation, CIGNA Holdings, Inc., CONNECTICUT GENERAL CORP., GULF QUEST LP, HEALTHSPRING LIFE & HEALTH INSURANCE COMPANY, INC., HOME PHYSICIANS MANAGEMENT LLC, HealthSpring, Inc., NEW QUEST LLC, PHYSICIANS MANAGEMENT LLC. (Attachments: #1 Attachment Certificate of Good Standing)(Potter, Thomas)
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Filing 145
MOTION for attorney David W. Ogden to Appear Pro Hac Vice (paid $150 PHV fee; receipt number 0650-3473933) by ALEGIS CARE SERVICES, LLC, CIGNA Corp., CIGNA Corporation, CIGNA Holdings, Inc., CONNECTICUT GENERAL CORP., GULF QUEST LP, HEALTHSPRING LIFE & HEALTH INSURANCE COMPANY, INC., HOME PHYSICIANS MANAGEMENT LLC, HealthSpring, Inc., NEW QUEST LLC, PHYSICIANS MANAGEMENT LLC. (Attachments: #1 Attachment Certificate of Good Standing)(Potter, Thomas)
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Filing 144
MOTION for attorney Kevin M. Lamb to Appear Pro Hac Vice (paid $150 PHV fee; receipt number 0650-3473855) by ALEGIS CARE SERVICES, LLC, CIGNA Corp., CIGNA Corporation, CIGNA Holdings, Inc., CONNECTICUT GENERAL CORP., GULF QUEST LP, HEALTHSPRING LIFE & HEALTH INSURANCE COMPANY, INC., HOME PHYSICIANS MANAGEMENT LLC, HealthSpring, Inc., NEW QUEST LLC, PHYSICIANS MANAGEMENT LLC. (Attachments: #1 Attachment Certificate of Good Standing)(Potter, Thomas)
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Filing 143
BUSINESS ENTITY DISCLOSURE STATEMENT filed by ALEGIS CARE SERVICES, LLC. (Potter, Thomas)
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Filing 142
BUSINESS ENTITY DISCLOSURE STATEMENT filed by HOME PHYSICIANS MANAGEMENT LLC. (Potter, Thomas)
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Filing 141
BUSINESS ENTITY DISCLOSURE STATEMENT filed by GULF QUEST LP. (Potter, Thomas)
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Filing 140
BUSINESS ENTITY DISCLOSURE STATEMENT filed by HEALTHSPRING LIFE & HEALTH INSURANCE COMPANY, INC.. (Potter, Thomas)
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Filing 139
BUSINESS ENTITY DISCLOSURE STATEMENT filed by NEW QUEST LLC. (Potter, Thomas)
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Filing 138
BUSINESS ENTITY DISCLOSURE STATEMENT filed by HealthSpring, Inc.. (Potter, Thomas)
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Filing 137
BUSINESS ENTITY DISCLOSURE STATEMENT filed by CONNECTICUT GENERAL CORP.. (Potter, Thomas)
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Filing 136
BUSINESS ENTITY DISCLOSURE STATEMENT filed by CIGNA Holdings, Inc.. (Potter, Thomas)
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Filing 135
BUSINESS ENTITY DISCLOSURE STATEMENT filed by CIGNA Corp.. (Potter, Thomas)
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Filing 134
NOTICE of Appearance by Thomas K. Potter, III on behalf of ALEGIS CARE SERVICES, LLC, CIGNA Corp., CIGNA Corporation, CIGNA Holdings, Inc., CONNECTICUT GENERAL CORP., GULF QUEST LP, HEALTHSPRING LIFE & HEALTH INSURANCE COMPANY, INC., HOME PHYSICIANS MANAGEMENT LLC, HealthSpring, Inc., NEW QUEST LLC, PHYSICIANS MANAGEMENT LLC (Potter, Thomas)
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Filing 133
NOTICE of Initial Case Management Conference by Telephone set for 12/7/2021 at 10:00 AM before Magistrate Judge Jeffery S. Frensley. (jm)
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TN State Bar status verified as active for Ellen Bowden McIntyre admitted to this court. (jm)
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Filing 132
NOTICE of Appearance by Ellen Bowden McIntyre on behalf of United States of America (McIntyre, Ellen)
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DC Bar status verified as active for Howard M. Shapiro, Kevin Matthew Lamb, David William Ogden, and Charles Speth; NY State Bar status verified as active for Robert A. Cutler, Li Yu, and Peter Max Aronoff not admitted to this court - Local counsel required. (jm)
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NOTICE TO COUNSEL Howard M. Shapiro, Kevin Matthew Lamb, David William Ogden, Charles Speth, Robert A. Cutler, Li Yu, and Peter Max Aronoff: WITHIN 21 DAYS, counsel shall file a Motion to Appear Pro Hac Vice, a Certificate of Good Standing signed by the Clerk of a United States District Court or a U. S. appellate court where admitted, and pay a fee of $150.00 (LR 83.01(b)). PHV due by 10/27/2021. (jm)
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NOTICE TO COUNSEL Howard M. Shapiro, Kevin Matthew Lamb, David William Ogden, Charles Speth, and Robert A. Cutler: WITHIN 21 DAYS, counsel shall associate local counsel qualified to practice in the United States District Court for the Middle District of Tennessee. Local counsel shall electronically file a Notice of Appearance (LR 83.01(d)). Appearance by local counsel due by 10/27/2021. (jm)
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Filing 131
NOTICE/INFORMATION regarding Consent of the Parties to the Magistrate Judge. (jm)
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Filing 130
NOTICE of Business Entity Disclosure Statement filing requirement. (jm)
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Filing 129
NOTICE OF ADMINISTRATIVE ORDER NO. 217 to parties re obligation of counsel to keep Court apprised of current contact information. (jm)
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Filing 128
Case transferred in from the District of New York Southern; Case Number 7:17-cv-07515. Original file certified copy of transfer order and docket sheet received.
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Filing 127
ORDER: granting #71 Motion to Transfer Case. For the reasons stated on the record at the Oral Argument on September 17, 2021, the Court grants Defendants Motion To Transfer. The Clerk of the Court is respectfully directed to terminate the pending Motion. (Dkt. No. 71). SO ORDERED. (Signed by Judge Kenneth M. Karas on 9/29/2021) (ama) [Transferred from New York Southern on 9/30/2021.]
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Filing 126
ORDER GRANTING DEFENDANTS' MOTION TO SEAL CONFIDENTIAL DOCUMENTS: granting #120 Motion to Seal. Before the Court is Defendants' Motion To Seal Confidential Documents. The Court, having considered the parties' submissions, orders that the motion be GRANTED. IT IS HEREBY ORDERED that the following docket entries shall be sealed and remain sealed unless and until the seal is lifted by order of the Court: Dkt. 91, 91-3, 91-4, 91-5, 91-6, 91-7, 91-8; Dkt. 92; Dkt. 95, 95-4, 95-5, 95-6, 95-7, 95-8, 95-9, 95-10, 95-11, 95-12, 95-13; and Dkt. 97. (Signed by Judge Kenneth M. Karas on 9/29/2021) (ama) [Transferred from New York Southern on 9/30/2021.]
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Filing 125
DECLARATION of Robert Cutler in Opposition re: #120 MOTION to Seal Confidential Documents.. Document filed by UNITED STATES OF AMERICA, EX REL. ROBERT A. CUTLER. (Attachments: #1 Exhibit A, #2 Exhibit B, #3 Exhibit C, #4 Exhibit D, #5 Exhibit E, #6 Exhibit F, #7 Exhibit G, #8 Exhibit H, #9 Exhibit I, #10 Exhibit J, #11 Exhibit K, #12 Exhibit L, #13 Exhibit M, #14 Exhibit N, #15 Exhibit O, #16 Exhibit P, #17 Exhibit Q).(Cutler, Robert) [Transferred from New York Southern on 9/30/2021.]
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Filing 124
RESPONSE in Opposition to Motion re: #120 MOTION to Seal Confidential Documents. . Document filed by UNITED STATES OF AMERICA, EX REL. ROBERT A. CUTLER..(Cutler, Robert) [Transferred from New York Southern on 9/30/2021.]
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CASE TRANSFERRED OUT ELECTRONICALLY from the U.S.D.C. Southern District of New York to the United States District Court - Middle District of Tennessee.(ama) [Transferred from New York Southern on 9/30/2021.]
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***NOTICE TO COURT REGARDING PROPOSED ORDER. Document No. #122 Proposed Order, was reviewed and approved as to form. (dt) [Transferred from New York Southern on 9/30/2021.]
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Filing 123
DECLARATION of Charles C. Speth in Support re: #120 MOTION to Seal Confidential Documents.. Document filed by ALEGIS CARE SERVICES, LLC, CIGNA Corporation, CONNECTICUT GENERAL CORP., Cigna Holdings, Inc., GULF QUEST LP, HEALTHSPRING LIFE & HEALTH INSURANCE COMPANY, INC., HEALTHSPRING, INC., HOME PHYSICIANS MANAGEMENT LLC, NEW QUEST LLC, PHYSICIANS MANAGEMENT LLC. (Attachments: #1 Exhibit A - Protective Order, #2 Exhibit B - Apr. 12 2018 E.D. Tex. Order, #3 Exhibit C - June 7 2018 S.D.N.Y. Order, #4 Exhibit D - Sept. 7 2018 Tex. D. Ct. Order, #5 Exhibit E - Jan. 19 2018 THM Response and Exhibit 1, #6 Exhibit F - Redacted Dkt. 91, #7 Exhibit G - Redacted Dkt. 95).(Speth, Charles) [Transferred from New York Southern on 9/30/2021.]
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Filing 122
PROPOSED ORDER. Document filed by ALEGIS CARE SERVICES, LLC, CIGNA Corporation, CONNECTICUT GENERAL CORP., Cigna Holdings, Inc., GULF QUEST LP, HEALTHSPRING LIFE & HEALTH INSURANCE COMPANY, INC., HEALTHSPRING, INC., HOME PHYSICIANS MANAGEMENT LLC, NEW QUEST LLC, PHYSICIANS MANAGEMENT LLC. Related Document Number: #120 ..(Ogden, David) Proposed Order to be reviewed by Clerk's Office staff. [Transferred from New York Southern on 9/30/2021.]
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Filing 121
MEMORANDUM OF LAW in Support re: #120 MOTION to Seal Confidential Documents. . Document filed by ALEGIS CARE SERVICES, LLC, CIGNA Corporation, CONNECTICUT GENERAL CORP., Cigna Holdings, Inc., GULF QUEST LP, HEALTHSPRING LIFE & HEALTH INSURANCE COMPANY, INC., HEALTHSPRING, INC., HOME PHYSICIANS MANAGEMENT LLC, NEW QUEST LLC, PHYSICIANS MANAGEMENT LLC..(Ogden, David) [Transferred from New York Southern on 9/30/2021.]
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Filing 120
MOTION to Seal Confidential Documents. Document filed by ALEGIS CARE SERVICES, LLC, CIGNA Corporation, CONNECTICUT GENERAL CORP., Cigna Holdings, Inc., GULF QUEST LP, HEALTHSPRING LIFE & HEALTH INSURANCE COMPANY, INC., HEALTHSPRING, INC., HOME PHYSICIANS MANAGEMENT LLC, NEW QUEST LLC, PHYSICIANS MANAGEMENT LLC..(Ogden, David) [Transferred from New York Southern on 9/30/2021.]
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Minute Entry for proceedings held before Judge Kenneth M. Karas: Oral Argument held on 9/17/2021 re: #71 MOTION to Transfer Case to the Middle District of Tennessee. filed by GULF QUEST LP, HEALTHSPRING LIFE & HEALTH INSURANCE COMPANY, INC., Cigna Holdings, Inc., NEW QUEST LLC, CIGNA Corporation, CONNECTICUT GENERAL CORP., Connecticut General Corp., ALEGIS CARE SERVICES, LLC, HOME PHYSICIANS MANAGEMENT LLC, PHYSICIANS MANAGEMENT LLC, HEALTHSPRING, INC. Robert A. Cutler appeared on behalf of himself as Relator. Charles Speth, David W. Ogden, and Kevin M. Lamb appeared on behalf of Defendants. AUSA Peter M. Aronoff appeared on behalf of the Government. Angela ODonnell served as court reporter. Oral arguments were made on Defendants' Motion To Transfer. (Dkt. No. 71.) For the reasons stated on the record, Defendants' Motion will be granted and the Court shall issue an order by no later than September 30, 2021. The Parties may request a transcript of the record. Defendants are to file their Motion To Seal by September 22, 2021. Relator Robert A. Cutler is to file his response by September 29, 2021. (ANR) [Transferred from New York Southern on 9/30/2021.]
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Filing 119
LETTER addressed to Judge Kenneth M. Karas from Robert Cutler dated 9-16-2021 Document filed by UNITED STATES OF AMERICA, EX REL. ROBERT A. CUTLER..(Cutler, Robert) [Transferred from New York Southern on 9/30/2021.]
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Filing 118
LETTER addressed to Judge Kenneth M. Karas from Charles C. Speth dated September 13, 2021 re: Supplemental Authority. Document filed by ALEGIS CARE SERVICES, LLC, CIGNA Corporation, CONNECTICUT GENERAL CORP., Cigna Holdings, Inc., GULF QUEST LP, HEALTHSPRING LIFE & HEALTH INSURANCE COMPANY, INC., HEALTHSPRING, INC., HOME PHYSICIANS MANAGEMENT LLC, NEW QUEST LLC, PHYSICIANS MANAGEMENT LLC..(Speth, Charles) [Transferred from New York Southern on 9/30/2021.]
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Filing 117
MEMO ENDORSEMENT on re: #115 Letter filed by UNITED STATES OF AMERICA. ENDORSEMENT: Application granted. Rachel Doud is terminated as an attorney of record in this matter. SO ORDERED. Attorney Rachael Lightfoot Doud terminated. (Signed by Magistrate Judge Judith C. McCarthy on 9/10/2021) (vfr) [Transferred from New York Southern on 9/30/2021.]
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Filing 116
NOTICE OF TELECONFERENCE INFORMATION. For the week of September 13, 2021, the Court will hold all civil conferences, hearings, and/or oral arguments by telephone. Counsel shall call the following number at the designated time: Meeting Dial-In Number (USA toll-free): (888) 363-4749 Access Code: 7702195 Please enter the conference as a guest by pressing the pound sign (#). SO ORDERED. (Signed by Judge Kenneth M. Karas on 9/10/21) (yv) [Transferred from New York Southern on 9/30/2021.]
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Filing 115
LETTER addressed to Magistrate Judge Judith C. McCarthy from Rachael L. Doud dated September 9, 2021 re: Request for Termination of Appearance. Document filed by UNITED STATES OF AMERICA..(Doud, Rachael) [Transferred from New York Southern on 9/30/2021.]
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Filing 114
ORDER granting #110 Letter Motion to Adjourn Conference. The Court grants Cigna's request for an adjournment. The Court will instead hold Oral Argument on the Motion to Transfer on September 17, 2021 at 10:30am. The Court will not grant any further adjournments on this Motion. Telephone Conference set for 9/17/2021 at 10:30 AM before Judge Kenneth M. Karas. (Signed by Judge Kenneth M. Karas on 7/22/2021) (ate) [Transferred from New York Southern on 9/30/2021.]
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Filing 113
ORDER granting #109 Motion to Withdraw as Attorney. IT IS HEREBY ORDERED THAT: 1. Sidley Austin LLP's request to withdraw Eamon P. Joyce, Robert D. Keeling, Sean Christopher Griffin, and Amy L. DeLine as counsel in the above-captioned action is granted. 2. Eamon P. Joyce (ejoyce@sidley.com), Robert D. Keeling (rkeeling@sidley.com), Sean Christopher Griffin (sgriffin@sidley.com), and Amy L. DeLine's (adeline@sidley.com) names and email addresses shall be removed from the ECF service lists. So Ordered. (Attorney Eamon Paul Joyce; Robert D. Keeling, III; Amy L. DeLine and Sean Christopher Griffin terminated.) (Signed by Judge Kenneth M. Karas on 7/21/21) (yv) [Transferred from New York Southern on 9/30/2021.]
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Filing 112
SEALED DOCUMENT placed in vault.(sk) [Transferred from New York Southern on 9/30/2021.]
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Filing 111
SEALED DOCUMENT placed in vault.(sk) [Transferred from New York Southern on 9/30/2021.]
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Filing 110
LETTER MOTION to Adjourn Conference addressed to Judge Kenneth M. Karas from David W. Ogden dated July 20, 2021. Document filed by ALEGIS CARE SERVICES, LLC, CIGNA Corporation, CONNECTICUT GENERAL CORP., Cigna Holdings, Inc., GULF QUEST LP, HEALTHSPRING LIFE & HEALTH INSURANCE COMPANY, INC., HEALTHSPRING, INC., HOME PHYSICIANS MANAGEMENT LLC, NEW QUEST LLC, PHYSICIANS MANAGEMENT LLC..(Ogden, David) [Transferred from New York Southern on 9/30/2021.]
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Filing 109
MOTION for Eamon P. Joyce, Robert D. Keeling, Sean Christopher Griffin, and Amy L. DeLine to Withdraw as Attorney . Document filed by ALEGIS CARE SERVICES, LLC, CIGNA Corporation, CONNECTICUT GENERAL CORP., Cigna Holdings, Inc., GULF QUEST LP, HEALTHSPRING LIFE & HEALTH INSURANCE COMPANY, INC., HEALTHSPRING, INC., HOME PHYSICIANS MANAGEMENT LLC, NEW QUEST LLC, PHYSICIANS MANAGEMENT LLC. (Attachments: #1 Declaration of Eamon P. Joyce, #2 Text of Proposed Order).(Joyce, Eamon) [Transferred from New York Southern on 9/30/2021.]
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Filing 108
ORDER FOR ADMISSION PRO HAC VICE granting #105 Motion for David W. Ogden to Appear Pro Hac Vice. The motion of David W. Ogden for admission pro hac vice is granted. IT IS HEREBY ORDERED that Applicant is admitted to practice pro hac vice in the above-captioned case in the United States District Court for the Southern District of New York. All attorneys appearing before this Court are subject to the Local Rules of this Court, including the Rules governing discipline of attorneys. (Signed by Judge Kenneth M. Karas on 7/14/21) (yv) [Transferred from New York Southern on 9/30/2021.]
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Filing 107
ORDER FOR ADMISSION PRO HAC VICE granting #106 Motion for Charles C. Speth to Appear Pro Hac Vice. The motion of Charles C. Speth for admission pro hac vice is granted. IT IS HEREBY ORDERED that Applicant is admitted to practice pro hac vice in the above-captioned case in the United States District Court for the Southern District of New York. All attorneys appearing before this Court are subject to the Local Rules of this Court, including the Rules governing discipline of attorneys. (Signed by Judge Kenneth M. Karas on 7/14/21) (yv) [Transferred from New York Southern on 9/30/2021.]
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>>>NOTICE REGARDING PRO HAC VICE MOTION. Regarding Document No. #106 MOTION for Charles C. Speth to Appear Pro Hac Vice . Filing fee $ 200.00, receipt number ANYSDC-24787412. Motion and supporting papers to be reviewed by Clerk's Office staff., #105 MOTION for David W. Ogden to Appear Pro Hac Vice . Filing fee $ 200.00, receipt number ANYSDC-24787329. Motion and supporting papers to be reviewed by Clerk's Office staff.. The document has been reviewed and there are no deficiencies. (bcu) [Transferred from New York Southern on 9/30/2021.]
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Filing 106
MOTION for Charles C. Speth to Appear Pro Hac Vice . Filing fee $ 200.00, receipt number ANYSDC-24787412. Motion and supporting papers to be reviewed by Clerk's Office staff. Document filed by ALEGIS CARE SERVICES, LLC, CIGNA Corporation, CONNECTICUT GENERAL CORP., Cigna Holdings, Inc., GULF QUEST LP, HEALTHSPRING LIFE & HEALTH INSURANCE COMPANY, INC., HEALTHSPRING, INC., HOME PHYSICIANS MANAGEMENT LLC, NEW QUEST LLC, PHYSICIANS MANAGEMENT LLC. (Attachments: #1 Declaration of Charles C. Speth, #2 Certificate of Good Standing - DC, #3 Text of Proposed Order).(Speth, Charles) [Transferred from New York Southern on 9/30/2021.]
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Filing 105
MOTION for David W. Ogden to Appear Pro Hac Vice . Filing fee $ 200.00, receipt number ANYSDC-24787329. Motion and supporting papers to be reviewed by Clerk's Office staff. Document filed by ALEGIS CARE SERVICES, LLC, CIGNA Corporation, CONNECTICUT GENERAL CORP., Cigna Holdings, Inc., GULF QUEST LP, HEALTHSPRING LIFE & HEALTH INSURANCE COMPANY, INC., HEALTHSPRING, INC., HOME PHYSICIANS MANAGEMENT LLC, NEW QUEST LLC, PHYSICIANS MANAGEMENT LLC. (Attachments: #1 Declaration of David W. Ogden, #2 Certificate of Good Standing - DC, #3 Text of Proposed Order).(Ogden, David) [Transferred from New York Southern on 9/30/2021.]
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Filing 104
NOTICE OF APPEARANCE by Kevin Matthew Lamb on behalf of ALEGIS CARE SERVICES, LLC, CIGNA Corporation, CONNECTICUT GENERAL CORP., Cigna Holdings, Inc., GULF QUEST LP, HEALTHSPRING LIFE & HEALTH INSURANCE COMPANY, INC., HEALTHSPRING, INC., HOME PHYSICIANS MANAGEMENT LLC, NEW QUEST LLC, PHYSICIANS MANAGEMENT LLC..(Lamb, Kevin) [Transferred from New York Southern on 9/30/2021.]
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Filing 103
NOTICE OF APPEARANCE by Howard M. Shapiro on behalf of ALEGIS CARE SERVICES, LLC, CIGNA Corporation, CONNECTICUT GENERAL CORP., Cigna Holdings, Inc., GULF QUEST LP, HEALTHSPRING LIFE & HEALTH INSURANCE COMPANY, INC., HEALTHSPRING, INC., HOME PHYSICIANS MANAGEMENT LLC, NEW QUEST LLC, PHYSICIANS MANAGEMENT LLC..(Shapiro, Howard) [Transferred from New York Southern on 9/30/2021.]
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Filing 102
CALENDAR NOTICE, Please take notice that the above captioned action has been scheduled for oral argument on the Defendant's Motion to Transfer the Case before the Honorable Kenneth M. Karas, United States District Judge, on Thursday, July 29, 2021 at 1:00 p.m. NOTICE OF TELECONFERENCE INFORMATION: Counsel shall call the following number at the designated time: Meeting Dial-In Number (USA toll-free): (888) 363-4749 Access Code: 7702195 Please enter the conference as a guest by pressing the pound sign(#). So Ordered. ( Telephone Conference set for 7/29/2021 at 01:00 PM before Judge Kenneth M. Karas.) (Signed by Judge Kenneth M. Karas on 7/7/21) (yv) [Transferred from New York Southern on 9/30/2021.]
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NOTICE OF REASSIGNMENT OF A REFERRAL TO ANOTHER MAGISTRATE JUDGE. The referral in the above entitled action has been reassigned to Magistrate Judge Judith C. McCarthy, for General Pretrial (includes scheduling, discovery, non-dispositive pretrial motions, and settlement). Magistrate Judge Andrew E. Krause no longer referred to the case. (laq) [Transferred from New York Southern on 9/30/2021.]
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NOTICE OF REDESIGNATION TO ANOTHER MAGISTRATE JUDGE. The above entitled action has been redesignated to Magistrate Judge Judith C. McCarthy. Please note that this is a reassignment of the designation only. (laq) [Transferred from New York Southern on 9/30/2021.]
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Magistrate Judge Judith C. McCarthy is so redesignated. (ad) [Transferred from New York Southern on 9/30/2021.]
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Filing 101
LETTER addressed to Magistrate Judge Andrew E. Krause from Li Yu/Peter Aronoff/Rachael Doud dated 3/8/2021 re: Referral to Your Honor. Document filed by UNITED STATES OF AMERICA..(Yu, Li) [Transferred from New York Southern on 9/30/2021.]
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Filing 100
ORDER REFERRING CASE TO MAGISTRATE JUDGE: Order that case be referred to the Clerk of Court for assignment to a Magistrate Judge for General Pretrial (includes scheduling, discovery, non-dispositive pretrial motions, and settlement). Referred to Magistrate Judge Andrew E. Krause. SO ORDERED. Motions referred to Andrew E. Krause. (Signed by Judge Kenneth M. Karas on 3/4/2021) (jca) [Transferred from New York Southern on 9/30/2021.]
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Magistrate Judge Andrew E. Krause is so redesignated. (laq) [Transferred from New York Southern on 9/30/2021.]
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Filing 99
LETTER addressed to Judge Kenneth M. Karas from Robert A. Cutler dated 2/26/21 Document filed by UNITED STATES OF AMERICA, EX REL. ROBERT A. CUTLER. (Attachments: #1 Exhibit A - HealthSpring Petition 1-9-18, #2 Exhibit B - HealthSpring Motion 1-17-18, #3 Exhibit C - HealthSpring Motion 7-31-18, #4 Exhibit D - HealthSpring Motion 11-29-18, #5 Exhibit E - HelthSpring Response 12-4-18, #6 Exhibit F - Letter to HealthSpring re CID).(Cutler, Robert) [Transferred from New York Southern on 9/30/2021.]
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Filing 98
LETTER addressed to Judge Kenneth M. Karas from Eamon P. Joyce dated February 23, 2021 re: Request for Pre-Motion Conference Regarding Motion to Seal Materials Filed In Violation Of Protective Order. Document filed by CIGNA Corp.. (Attachments: #1 Exhibit A, #2 Exhibit B, #3 Exhibit C, #4 Exhibit D).(Joyce, Eamon) [Transferred from New York Southern on 9/30/2021.]
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Filing 97
DECLARATION of Robert A. Cutler in Opposition re: #71 MOTION to Transfer Case to the Middle District of Tennessee.. Document filed by UNITED STATES OF AMERICA, EX REL. ROBERT A. CUTLER..(Cutler, Robert) [Transferred from New York Southern on 9/30/2021.]
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Filing 96
DECLARATION of Joseph L. Stroffolino in Opposition re: #71 MOTION to Transfer Case to the Middle District of Tennessee.. Document filed by UNITED STATES OF AMERICA, EX REL. ROBERT A. CUTLER..(Cutler, Robert) [Transferred from New York Southern on 9/30/2021.]
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Filing 95
REPLY to Response to Motion re: #71 MOTION to Transfer Case to the Middle District of Tennessee. THIS DOCUMENT IS RELATOR'S SUR-REPLY. Document filed by UNITED STATES OF AMERICA, EX REL. ROBERT A. CUTLER. (Attachments: # 1 Exhibit 1 - Nashville Area, # 2 Exhibit 2 - Muney Appointment, # 3 Exhibit 3 - Muney Presentation, # 4 Exhibit 4 - Stevens Emails, # 5 Exhibit 5 - Emails re 360 Contracts, # 6 Exhibit 6 - Whitney Horak, # 7 Exhibit 7 - Texas Strategy, # 8 Exhibit 8 - Contracting Emails, # 9 Exhibit 9 - Call Scripts Emails, # 10 Exhibit 10 - Gardner Emails, # 11 Exhibit 11 - Careallies Emails, # 12 Exhibit 12 - Emails re AZ rollout, # 13 Exhibit 13 - 360 Contracts, # 14 Exhibit 14 - Livingwell Centers).(Cutler, Robert) [Transferred from New York Southern on 9/30/2021.]
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Filing 93
MEMO ENDORSEMENT on re: 91 Letter, filed by UNITED STATES OF AMERICA, EX REL. ROBERT A. CUTLER. ENDORSEMENT: The Sur-Reply is due 2/10/21. SO ORDERED. (Surreplies due by 2/10/2021.) (Signed by Judge Kenneth M. Karas on 2/2/2021) (jca) [Transferred from New York Southern on 9/30/2021.]
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Filing 92
DECLARATION of Robert A. Cutler in Opposition re: #71 MOTION to Transfer Case to the Middle District of Tennessee.. Document filed by UNITED STATES OF AMERICA, EX REL. ROBERT A. CUTLER..(Cutler, Robert) [Transferred from New York Southern on 9/30/2021.]
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Filing 91
LETTER addressed to Judge Kenneth M. Karas from Robert A. Cutler dated 2/2/21 re: Request to disregard declarations or allow surrepy. Document filed by UNITED STATES OF AMERICA, EX REL. ROBERT A. CUTLER. (Attachments: # 1 Exhibit 1, # 2 Exhibit 2, # 3 Exhibit 3, # 4 Exhibit 4, # 5 Exhibit 5, # 6 Exhibit 6, # 7 Exhibit 7, # 8 Exhibit 8).(Cutler, Robert) [Transferred from New York Southern on 9/30/2021.]
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Filing 90
MEMO ENDORSEMENT on re: #83 Letter,, filed by GULF QUEST LP, HEALTHSPRING LIFE & HEALTH INSURANCE COMPANY, INC., Cigna Holdings, Inc., NEW QUEST LLC, CIGNA Corporation, CONNECTICUT GENERAL CORP., Connecticut General Corp., ALEGIS CARE SERVICES, LLC, HOME PHYSICIANS MANAGEMENT LLC, PHYSICIANS MANAGEMENT LLC, HEALTHSPRING, INC. ENDORSEMENT: The Court orders that the seal be lifted for the original Complaint as to the Defendants only and otherwise leaves the exhibits under seal for the public. Any future briefing filed related to this Motion should redact any contents that remain unseal. Unredacted copies of such briefing must be emailed directly to Chambers. SO ORDERED. (Signed by Judge Kenneth M. Karas on 1/28/2021) (jca) [Transferred from New York Southern on 9/30/2021.]
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Transmission to Sealed Records Clerk. Transmitted re: #90 Memo Endorsement to the Sealed Records Clerk for the sealing or unsealing of document or case. (jca) [Transferred from New York Southern on 9/30/2021.]
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Filing 89
DECLARATION of Dr. Alan Muney in Support re: #71 MOTION to Transfer Case to the Middle District of Tennessee.. Document filed by ALEGIS CARE SERVICES, LLC, CIGNA Corp., CIGNA Corporation, CONNECTICUT GENERAL CORP., Cigna Holdings, Inc., GULF QUEST LP, HEALTHSPRING LIFE & HEALTH INSURANCE COMPANY, INC., HEALTHSPRING, INC., HOME PHYSICIANS MANAGEMENT LLC, NEW QUEST LLC, PHYSICIANS MANAGEMENT LLC..(Joyce, Eamon) [Transferred from New York Southern on 9/30/2021.]
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Filing 88
DECLARATION of Dr. Dirk Wales in Support re: #71 MOTION to Transfer Case to the Middle District of Tennessee.. Document filed by ALEGIS CARE SERVICES, LLC, CIGNA Corp., CIGNA Corporation, CONNECTICUT GENERAL CORP., Cigna Holdings, Inc., GULF QUEST LP, HEALTHSPRING LIFE & HEALTH INSURANCE COMPANY, INC., HEALTHSPRING, INC., HOME PHYSICIANS MANAGEMENT LLC, NEW QUEST LLC, PHYSICIANS MANAGEMENT LLC..(Joyce, Eamon) [Transferred from New York Southern on 9/30/2021.]
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Filing 87
DECLARATION of Dr. Jason Jean in Support re: #71 MOTION to Transfer Case to the Middle District of Tennessee.. Document filed by ALEGIS CARE SERVICES, LLC, CIGNA Corp., CIGNA Corporation, CONNECTICUT GENERAL CORP., Cigna Holdings, Inc., GULF QUEST LP, HEALTHSPRING LIFE & HEALTH INSURANCE COMPANY, INC., HEALTHSPRING, INC., HOME PHYSICIANS MANAGEMENT LLC, NEW QUEST LLC, PHYSICIANS MANAGEMENT LLC..(Joyce, Eamon) [Transferred from New York Southern on 9/30/2021.]
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Filing 86
DECLARATION of Dr. Julian Harris in Support re: #71 MOTION to Transfer Case to the Middle District of Tennessee.. Document filed by ALEGIS CARE SERVICES, LLC, CIGNA Corp., CIGNA Corporation, CONNECTICUT GENERAL CORP., Cigna Holdings, Inc., GULF QUEST LP, HEALTHSPRING LIFE & HEALTH INSURANCE COMPANY, INC., HEALTHSPRING, INC., HOME PHYSICIANS MANAGEMENT LLC, NEW QUEST LLC, PHYSICIANS MANAGEMENT LLC..(Joyce, Eamon) [Transferred from New York Southern on 9/30/2021.]
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Filing 85
DECLARATION of Dr. Michael Fessenden in Support re: #71 MOTION to Transfer Case to the Middle District of Tennessee.. Document filed by ALEGIS CARE SERVICES, LLC, CIGNA Corp., CIGNA Corporation, CONNECTICUT GENERAL CORP., Cigna Holdings, Inc., GULF QUEST LP, HEALTHSPRING LIFE & HEALTH INSURANCE COMPANY, INC., HEALTHSPRING, INC., HOME PHYSICIANS MANAGEMENT LLC, NEW QUEST LLC, PHYSICIANS MANAGEMENT LLC..(Joyce, Eamon) [Transferred from New York Southern on 9/30/2021.]
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Filing 84
REPLY MEMORANDUM OF LAW in Support re: #71 MOTION to Transfer Case to the Middle District of Tennessee. . Document filed by ALEGIS CARE SERVICES, LLC, CIGNA Corp., CIGNA Corporation, CONNECTICUT GENERAL CORP., Cigna Holdings, Inc., GULF QUEST LP, HEALTHSPRING LIFE & HEALTH INSURANCE COMPANY, INC., HEALTHSPRING, INC., HOME PHYSICIANS MANAGEMENT LLC, NEW QUEST LLC, PHYSICIANS MANAGEMENT LLC..(Joyce, Eamon) [Transferred from New York Southern on 9/30/2021.]
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Filing 83
LETTER addressed to Judge Kenneth M. Karas from Eamon P. Joyce dated January 27, 2021 re: response to the correspondence from Relator Robert A. Cutler dated January 20, 2021, Dkt. 81.. Document filed by ALEGIS CARE SERVICES, LLC, CIGNA Corporation, CONNECTICUT GENERAL CORP., Cigna Holdings, Inc., GULF QUEST LP, HEALTHSPRING LIFE & HEALTH INSURANCE COMPANY, INC., HEALTHSPRING, INC., HOME PHYSICIANS MANAGEMENT LLC, NEW QUEST LLC, PHYSICIANS MANAGEMENT LLC. (Attachments: #1 Exhibit A).(Joyce, Eamon) [Transferred from New York Southern on 9/30/2021.]
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Filing 82
MEMO ENDORSEMENT on re: #81 Response to Motion, filed by UNITED STATES OF AMERICA, EX REL. ROBERT A. CUTLER. ENDORSEMENT: Defendants are to respond to this letter by 1/27/21. SO ORDERED. (Replies due by 1/27/2021.) (Signed by Judge Kenneth M. Karas on 1/20/2021) (jca) [Transferred from New York Southern on 9/30/2021.]
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Filing 81
LETTER RESPONSE to Motion addressed to Judge Kenneth M. Karas from Robert A. Cutler dated 1/20/21 re: #75 LETTER MOTION for Conference / Pre-Motion Conference regarding a motion to unseal the original Complaint, or, alternatively, that the Court so-order the unsealing of the original Complaint addressed to Judge Kenneth M. Karas from Eamon P. Jo . Document filed by UNITED STATES OF AMERICA, EX REL. ROBERT A. CUTLER..(Cutler, Robert) [Transferred from New York Southern on 9/30/2021.]
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Filing 80
DECLARATION of Joseph Stroffolino in Opposition re: #71 MOTION to Transfer Case to the Middle District of Tennessee.. Document filed by UNITED STATES OF AMERICA, EX REL. ROBERT A. CUTLER..(Cutler, Robert) [Transferred from New York Southern on 9/30/2021.]
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Filing 79
DECLARATION of Robert A. Cutler in Opposition re: #71 MOTION to Transfer Case to the Middle District of Tennessee.. Document filed by UNITED STATES OF AMERICA, EX REL. ROBERT A. CUTLER..(Cutler, Robert) [Transferred from New York Southern on 9/30/2021.]
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Filing 78
DECLARATION of Robert A. Cutler in Opposition re: #71 MOTION to Transfer Case to the Middle District of Tennessee.. Document filed by UNITED STATES OF AMERICA, EX REL. ROBERT A. CUTLER..(Cutler, Robert) [Transferred from New York Southern on 9/30/2021.]
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Filing 77
MEMORANDUM OF LAW in Opposition re: #71 MOTION to Transfer Case to the Middle District of Tennessee. . Document filed by UNITED STATES OF AMERICA, EX REL. ROBERT A. CUTLER. (Attachments: #1 Exhibit A - Trademark Filings, #2 Exhibit B - Closed HS Offices, #3 Exhibit C - Cigna 2019 Annual Report, #4 Exhibit D - Cigna Contract Westchester, #5 Exhibit E - Dr. Harris Location, #6 Exhibit F - Dr. Muney Location, #7 Exhibit G - Muney Appointment, #8 Exhibit H - Cornell ACO, #9 Exhibit I - Hill Briefing Dr. Muney Slides, #10 Exhibit J - CCS Location, #11 Exhibit K - Blackburn Location, #12 Exhibit L - Location of Arbitrators, #13 Exhibit M - Cigna Offiers and Directors, #14 Exhibit N - CareAllies, #15 Exhibit O - Dr. Harris Presentation, #16 Exhibit P - Workforce Comparison).(Cutler, Robert) [Transferred from New York Southern on 9/30/2021.]
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Filing 76
ORDER with respect to #75 LETTER MOTION for Conference / Pre-Motion Conference regarding a motion to unseal the original Complaint, or, alternatively, that the Court so-order the unsealing of the original Complaint. Relator is to respond to this letter by 1/20/21. So Ordered. (Signed by Judge Kenneth M. Karas on 1/13/2021) (jca) [Transferred from New York Southern on 9/30/2021.]
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Filing 75
LETTER MOTION for Conference / Pre-Motion Conference regarding a motion to unseal the original Complaint, or, alternatively, that the Court so-order the unsealing of the original Complaint addressed to Judge Kenneth M. Karas from Eamon P. Joyce dated January 13, 2021. Document filed by ALEGIS CARE SERVICES, LLC, CIGNA Corporation, CONNECTICUT GENERAL CORP., Cigna Holdings, Inc., GULF QUEST LP, HEALTHSPRING LIFE & HEALTH INSURANCE COMPANY, INC., HEALTHSPRING, INC., HOME PHYSICIANS MANAGEMENT LLC, NEW QUEST LLC, PHYSICIANS MANAGEMENT LLC..(Joyce, Eamon) [Transferred from New York Southern on 9/30/2021.]
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Set/Reset Deadlines: Responses due by 1/20/2021 (jca) [Transferred from New York Southern on 9/30/2021.]
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Filing 74
DECLARATION of Robert D. Keeling in Support re: #71 MOTION to Transfer Case to the Middle District of Tennessee.. Document filed by ALEGIS CARE SERVICES, LLC, CIGNA Corporation, CONNECTICUT GENERAL CORP., Cigna Holdings, Inc., GULF QUEST LP, HEALTHSPRING LIFE & HEALTH INSURANCE COMPANY, INC., HEALTHSPRING, INC., HOME PHYSICIANS MANAGEMENT LLC, NEW QUEST LLC, PHYSICIANS MANAGEMENT LLC. (Attachments: #1 Exhibit A - 2/14/2017 AAA Transcript, #2 Exhibit B - Letter from THM General Counsel Robert A. Cutler to AAA, #3 Exhibit C - Final Award in AAA Proceeding, #4 Exhibit D - 9/6/2018 Hearing Transcript).(Joyce, Eamon) [Transferred from New York Southern on 9/30/2021.]
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Filing 73
DECLARATION of Casey McKeon in Support re: #71 MOTION to Transfer Case to the Middle District of Tennessee.. Document filed by ALEGIS CARE SERVICES, LLC, CIGNA Corporation, CONNECTICUT GENERAL CORP., Cigna Holdings, Inc., GULF QUEST LP, HEALTHSPRING LIFE & HEALTH INSURANCE COMPANY, INC., HEALTHSPRING, INC., HOME PHYSICIANS MANAGEMENT LLC, NEW QUEST LLC, PHYSICIANS MANAGEMENT LLC..(Joyce, Eamon) [Transferred from New York Southern on 9/30/2021.]
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Filing 72
MEMORANDUM OF LAW in Support re: #71 MOTION to Transfer Case to the Middle District of Tennessee. . Document filed by ALEGIS CARE SERVICES, LLC, CIGNA Corporation, CONNECTICUT GENERAL CORP., Cigna Holdings, Inc., GULF QUEST LP, HEALTHSPRING LIFE & HEALTH INSURANCE COMPANY, INC., HEALTHSPRING, INC., HOME PHYSICIANS MANAGEMENT LLC, NEW QUEST LLC, PHYSICIANS MANAGEMENT LLC..(Joyce, Eamon) [Transferred from New York Southern on 9/30/2021.]
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Filing 71
MOTION to Transfer Case to the Middle District of Tennessee. Document filed by ALEGIS CARE SERVICES, LLC, CIGNA Corporation, CONNECTICUT GENERAL CORP., Cigna Holdings, Inc., GULF QUEST LP, HEALTHSPRING LIFE & HEALTH INSURANCE COMPANY, INC., HEALTHSPRING, INC., HOME PHYSICIANS MANAGEMENT LLC, NEW QUEST LLC, PHYSICIANS MANAGEMENT LLC..(Joyce, Eamon) [Transferred from New York Southern on 9/30/2021.]
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Filing 70
SCHEDULING ORDER: At the Conference held before the Court on November 12, 2020, the Court adopted the following briefing schedule for Defendants' upcoming Motion to Transfer: Defendants' Motion to Transfer is due December 4, 2020. Relator's response is due January 14, 2021. Defendants' reply is due January 28, 2021. The Parties are reminded that there is a strict page limit of 25 pages for opening briefs and 10 pages for replies. If oral argument is requested, it may be scheduled by the Court. Please wait to hear from the Court to schedule argument. SO ORDERED. Motions due by 12/4/2020. Responses due by 1/14/2021 Replies due by 1/28/2021. (Signed by Judge Kenneth M. Karas on 11/13/2020) (jca) [Transferred from New York Southern on 9/30/2021.]
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Minute Entry for proceedings held before Judge Kenneth M. Karas: Pre-Motion Conference held on 11/12/2020. Robert A. Cutler appeared on behalf of himself as Relator. Peter Max Aronoff and Rachael Lightfoot Doud appeared on behalf of the Government. Amy L. DeLine, Eamon Paul Joyce, Robert D. Keeling, III, and Sean Christopher Griffin appeared on behalf of Defendants. The Court adopted a briefing schedule. See Order. Defendants shall file its Motion to Transfer by no later than December 4, 2020. Relator shall file a response by no later than January 14, 2021. Defendants shall file a reply by no later than January 28, 2021. (ANR) [Transferred from New York Southern on 9/30/2021.]
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Filing 69
NOTICE OF APPEARANCE by Peter Max Aronoff on behalf of UNITED STATES OF AMERICA..(Aronoff, Peter) [Transferred from New York Southern on 9/30/2021.]
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Filing 68
LETTER addressed to Judge Kenneth M. Karas from Eamon P. Joyce dated November 11, 2020 re: Status Update in Advance of Upcoming Pre-Motion Conference and Proposed Briefing Schedule. Document filed by ALEGIS CARE SERVICES, LLC, CIGNA Corporation, CONNECTICUT GENERAL CORP., Cigna Holdings, Inc., GULF QUEST LP, HEALTHSPRING LIFE & HEALTH INSURANCE COMPANY, INC., HEALTHSPRING, INC., HOME PHYSICIANS MANAGEMENT LLC, NEW QUEST LLC, PHYSICIANS MANAGEMENT LLC..(Joyce, Eamon) [Transferred from New York Southern on 9/30/2021.]
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Filing 67
ORDER FOR ADMISSION PRO HAC VICE granting #66 Motion for Robert Keeling to Appear Pro Hac Vice. The motion of Robert Keeling, for admission to practice Pro Hae Vice in the above captioned action is granted. (Signed by Judge Kenneth M. Karas on 10/6/2020) (va) Modified on 10/19/2020 (va). [Transferred from New York Southern on 9/30/2021.]
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Filing 66
MOTION for Robert D. Keeling to Appear Pro Hac Vice . Filing fee $ 200.00, receipt number ANYSDC-21978191. Motion and supporting papers to be reviewed by Clerk's Office staff. Document filed by ALEGIS CARE SERVICES, LLC, CIGNA Corporation, CONNECTICUT GENERAL CORP., Cigna Holdings, Inc., GULF QUEST LP, HEALTHSPRING LIFE & HEALTH INSURANCE COMPANY, INC., HEALTHSPRING, INC., NEW QUEST LLC, PHYSICIANS MANAGEMENT LLC. (Attachments: #1 Declaration, #2 DC Certificate of Good Standing, #3 VA Certificate of Good Standing, #4 Text of Proposed Order for Admission Pro Hac Vice).(Keeling, Robert) [Transferred from New York Southern on 9/30/2021.]
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>>>NOTICE REGARDING PRO HAC VICE MOTION. Regarding Document No. #66 MOTION for Robert D. Keeling to Appear Pro Hac Vice . Filing fee $ 200.00, receipt number ANYSDC-21978191. Motion and supporting papers to be reviewed by Clerk's Office staff.. The document has been reviewed and there are no deficiencies. (bcu) [Transferred from New York Southern on 9/30/2021.]
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Filing 65
ORDER granting #64 Letter Motion to Adjourn Conference. The conference is adjourned until 11/12/20 at 3pm. This gives counsel plenty of time to discuss this very old case. So Ordered. Pre-Motion Conference set for 11/12/2020 at 03:00 PM before Judge Kenneth M. Karas. (Signed by Judge Kenneth M. Karas on 10/2/2020) (jca) [Transferred from New York Southern on 9/30/2021.]
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Filing 64
LETTER MOTION to Adjourn Conference Temporarily addressed to Judge Kenneth M. Karas from Eamon P. Joyce dated October 1, 2020. Document filed by ALEGIS CARE SERVICES, LLC, CIGNA Corporation, CONNECTICUT GENERAL CORP., Cigna Holdings, Inc., GULF QUEST LP, HEALTHSPRING LIFE & HEALTH INSURANCE COMPANY, INC., HEALTHSPRING, INC., NEW QUEST LLC, PHYSICIANS MANAGEMENT LLC..(Joyce, Eamon) [Transferred from New York Southern on 9/30/2021.]
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Filing 63
ORDER FOR ADMISSION PRO HAC VICE granting #62 MOTION for Sean C. Griffin to Appear Pro Hac Vice. (Signed by Judge Kenneth M. Karas on 9/29/2020) (jca) [Transferred from New York Southern on 9/30/2021.]
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>>>NOTICE REGARDING PRO HAC VICE MOTION. Regarding Document No. #62 MOTION for Sean C. Griffin to Appear Pro Hac Vice . Filing fee $ 200.00, receipt number ANYSDC-21877879. Motion and supporting papers to be reviewed by Clerk's Office staff.. The document has been reviewed and there are no deficiencies. (wb) [Transferred from New York Southern on 9/30/2021.]
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Filing 62
MOTION for Sean C. Griffin to Appear Pro Hac Vice . Filing fee $ 200.00, receipt number ANYSDC-21877879. Motion and supporting papers to be reviewed by Clerk's Office staff. Document filed by ALEGIS CARE SERVICES, LLC, CIGNA Corporation, CONNECTICUT GENERAL CORP., Cigna Holdings, Inc., GULF QUEST LP, HEALTHSPRING LIFE & HEALTH INSURANCE COMPANY, INC., HEALTHSPRING, INC., NEW QUEST LLC, PHYSICIANS MANAGEMENT LLC. (Attachments: #1 Declaration in Support, #2 Certificate of Good Standing - District of Columbia, #3 Certificate of Good Standing - Virginia, #4 Text of Proposed Order).(Griffin, Sean) [Transferred from New York Southern on 9/30/2021.]
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Filing 61
MEMO ENDORSEMENT on re: #60 Letter, filed by UNITED STATES OF AMERICA, EX REL. ROBERT A. CUTLER. ENDORSEMENT: The Court will hold a pre-motion conference on 10/8/20, at 11:30. SO ORDERED. (Pre-Motion Conference set for 10/8/2020 at 11:30 AM before Judge Kenneth M. Karas.), Motions terminated: #44 LETTER MOTION for Conference / Pre-Motion Conference for Defendants' Motion to Transfer Venue addressed to Judge Kenneth M. Karas from Eamon P. Joyce dated September 8, 2020. filed by GULF QUEST LP, HEALTHSPRING LIFE & HEALTH INSURANCE COMPANY, INC., Cigna Holdings, Inc., NEW QUEST LLC, CIGNA Corporation, CONNECTICUT GENERAL CORP., Connecticut General Corp., ALEGIS CARE SERVICES, LLC, PHYSICIANS MANAGEMENT LLC, HEALTHSPRING, INC., #45 LETTER MOTION for Conference / Pre-Motion Conference for Defendants' Motion to Stay Pending Resolution of their Motion to Transfer addressed to Judge Kenneth M. Karas from Eamon P. Joyce dated September 8, 2020. filed by GULF QUEST LP, HEALTHSPRING LIFE & HEALTH INSURANCE COMPANY, INC., Cigna Holdings, Inc., NEW QUEST LLC, Connecticut General Corp., CONNECTICUT GENERAL CORP., CIGNA Corporation, ALEGIS CARE SERVICES, LLC, PHYSICIANS MANAGEMENT LLC, HEALTHSPRING, INC.. (Signed by Judge Kenneth M. Karas on 9/22/2020) (jca) [Transferred from New York Southern on 9/30/2021.]
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Filing 60
LETTER addressed to Judge Kenneth M. Karas from Robert A. Cutler dated 9/21/20 re: Response to Defendants' letter re Motion to Dismiss. Document filed by UNITED STATES OF AMERICA, EX REL. ROBERT A. CUTLER. (Attachments: #1 Exhibit A - Protective Order, #2 Exhibit B - Cigna Identity).(Cutler, Robert) [Transferred from New York Southern on 9/30/2021.]
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Filing 59
DECLARATION of Casey McKeon in Support re: #44 LETTER MOTION for Conference / Pre-Motion Conference for Defendants' Motion to Transfer Venue addressed to Judge Kenneth M. Karas from Eamon P. Joyce dated September 8, 2020.. Document filed by ALEGIS CARE SERVICES, LLC, CIGNA Corporation, CONNECTICUT GENERAL CORP., Cigna Holdings, Inc., GULF QUEST LP, HEALTHSPRING LIFE & HEALTH INSURANCE COMPANY, INC., HEALTHSPRING, INC., NEW QUEST LLC, PHYSICIANS MANAGEMENT LLC..(Joyce, Eamon)[Transferred from New York Southern on 9/30/2021.]
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Filing 58
REPLY re: #52 Response to Motion,, . Document filed by ALEGIS CARE SERVICES, LLC, CIGNA Corporation, CONNECTICUT GENERAL CORP., Cigna Holdings, Inc., GULF QUEST LP, HEALTHSPRING LIFE & HEALTH INSURANCE COMPANY, INC., HEALTHSPRING, INC., HOME PHYSICIANS MANAGEMENT LLC, NEW QUEST LLC, PHYSICIANS MANAGEMENT LLC..(Joyce, Eamon) [Transferred from New York Southern on 9/30/2021.]
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Filing 57
FILING ERROR - DEFICIENT DOCKET ENTRY - MOTION for Sean C. Griffin to Appear Pro Hac Vice . Filing fee $ 200.00, receipt number ANYSDC-21689977. Motion and supporting papers to be reviewed by Clerk's Office staff. Document filed by ALEGIS CARE SERVICES, LLC, CIGNA Corp., CIGNA Corporation, CONNECTICUT GENERAL CORP., Cigna Holdings, Inc., GULF QUEST LP, HEALTHSPRING LIFE & HEALTH INSURANCE COMPANY, INC., HEALTHSPRING, INC., HOME PHYSICIANS MANAGEMENT LLC, NEW QUEST LLC, PHYSICIANS MANAGEMENT LLC. (Attachments: #1 Declaration, #2 DC Certificate of Good Standing, #3 VA Certificate of Good Standing, #4 Text of Proposed Order).(Griffin, Sean) Modified on 9/16/2020 (aea). [Transferred from New York Southern on 9/30/2021.]
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>>>NOTICE REGARDING DEFICIENT MOTION TO APPEAR PRO HAC VICE. Notice to RE-FILE Document No. #57 MOTION for Sean C. Griffin to Appear Pro Hac Vice . Filing fee $ 200.00, receipt number ANYSDC-21689977. Motion and supporting papers to be reviewed by Clerk's Office staff. The filing is deficient for the following reason(s): missing Certificate of Good Standing from SUPREME COURT OF VIRGINIA - 804-786-2251;. Re-file the motion as a Motion to Appear Pro Hac Vice - attach the correct signed PDF - select the correct named filer/filers - attach valid Certificates of Good Standing issued within the past 30 days - attach Proposed Order. (aea) [Transferred from New York Southern on 9/30/2021.]
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Filing 56
LETTER addressed to Judge Kenneth M. Karas from Eamon P. Joyce dated September 15, 2020 re: Pre-Motion Letter to Robert A. Cutler regarding Defendants' intent to move to dismiss. Document filed by ALEGIS CARE SERVICES, LLC, CIGNA Corporation, CONNECTICUT GENERAL CORP., Cigna Holdings, Inc., GULF QUEST LP, HEALTHSPRING LIFE & HEALTH INSURANCE COMPANY, INC., HEALTHSPRING, INC., NEW QUEST LLC, PHYSICIANS MANAGEMENT LLC..(Joyce, Eamon) [Transferred from New York Southern on 9/30/2021.]
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Filing 55
NOTICE OF APPEARANCE by Rachael Lightfoot Doud on behalf of UNITED STATES OF AMERICA..(Doud, Rachael) [Transferred from New York Southern on 9/30/2021.]
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Filing 54
MEMO ENDORSEMENT on re: #52 Response to Motion,, filed by UNITED STATES OF AMERICA, EX REL. ROBERT A. CUTLER. ENDORSEMENT: Defendants are to reply to this letter by 9/21/20. So Ordered. (Replies due by 9/21/2020.) (Signed by Judge Kenneth M. Karas on 9/14/2020) (jca) [Transferred from New York Southern on 9/30/2021.]
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Filing 53
LETTER RESPONSE to Motion addressed to Judge Kenneth M. Karas re: #45 LETTER MOTION for Conference / Pre-Motion Conference for Defendants' Motion to Stay Pending Resolution of their Motion to Transfer addressed to Judge Kenneth M. Karas from Eamon P. Joyce dated September 8, 2020. . Document filed by UNITED STATES OF AMERICA, EX REL. ROBERT A. CUTLER..(Cutler, Robert) [Transferred from New York Southern on 9/30/2021.]
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Filing 52
LETTER RESPONSE to Motion addressed to Judge Kenneth M. Karas re: #44 LETTER MOTION for Conference / Pre-Motion Conference for Defendants' Motion to Transfer Venue addressed to Judge Kenneth M. Karas from Eamon P. Joyce dated September 8, 2020. . Document filed by UNITED STATES OF AMERICA, EX REL. ROBERT A. CUTLER. (Attachments: #1 Exhibit Ex. A - TN Registrations, #2 Exhibit Ex. B - Cigna Company Names, #3 Exhibit Ex. C - Cigna Contract Press Release, #4 Exhibit Ex. D - Cigna CT and TN Registrations).(Cutler, Robert) [Transferred from New York Southern on 9/30/2021.]
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Filing 51
AFFIDAVIT OF SERVICE of Summons and Amended Complaint,. Document filed by UNITED STATES OF AMERICA, EX REL. ROBERT A. CUTLER..(Cutler, Robert) [Transferred from New York Southern on 9/30/2021.]
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Filing 50
ORDER FOR ADMISSION PRO HAC VICE granting #46 MOTION for Amy DeLine to Appear Pro Hac Vice. (Signed by Judge Kenneth M. Karas on 9/10/2020) (jca) [Transferred from New York Southern on 9/30/2021.]
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Filing 49
SEALED DOCUMENT placed in vault..(fk) [Transferred from New York Southern on 9/30/2021.]
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Filing 48
NOTICE OF APPEARANCE by Li Yu on behalf of UNITED STATES OF AMERICA..(Yu, Li) [Transferred from New York Southern on 9/30/2021.]
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Filing 47
ORDER with respect to #44 LETTER MOTION for Conference / Pre-Motion Conference for Defendants' Motion to Transfer Venue. Relater is to respond to this letter by 9/14/20. SO ORDERED. (Signed by Judge Kenneth M. Karas on 9/8/2020) (jca) [Transferred from New York Southern on 9/30/2021.]
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Filing 46
MOTION for Amy DeLine to Appear Pro Hac Vice . Filing fee $ 200.00, receipt number ANYSDC-21564576. Motion and supporting papers to be reviewed by Clerk's Office staff. Document filed by ALEGIS CARE SERVICES, LLC, CIGNA Corporation, CONNECTICUT GENERAL CORP., Cigna Holdings, Inc., GULF QUEST LP, HEALTHSPRING LIFE & HEALTH INSURANCE COMPANY, INC., HEALTHSPRING, INC., NEW QUEST LLC, PHYSICIANS MANAGEMENT LLC. (Attachments: #1 Declaration of Amy DeLine, #2 IL Certificate of Good Standing, #3 DC Certificate of Good Standing, #4 Text of Proposed Order for Admission Pro Hac Vice).(DeLine, Amy) [Transferred from New York Southern on 9/30/2021.]
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Set/Reset Deadlines: Responses due by 9/14/2020 (jca) [Transferred from New York Southern on 9/30/2021.]
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>>>NOTICE REGARDING PRO HAC VICE MOTION. Regarding Document No. #46 MOTION for Amy DeLine to Appear Pro Hac Vice . Filing fee $ 200.00, receipt number ANYSDC-21564576. Motion and supporting papers to be reviewed by Clerk's Office staff.. The document has been reviewed and there are no deficiencies. (vba) [Transferred from New York Southern on 9/30/2021.]
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Filing 45
LETTER MOTION for Conference / Pre-Motion Conference for Defendants' Motion to Stay Pending Resolution of their Motion to Transfer addressed to Judge Kenneth M. Karas from Eamon P. Joyce dated September 8, 2020. Document filed by ALEGIS CARE SERVICES, LLC, CIGNA Corporation, CONNECTICUT GENERAL CORP., Cigna Holdings, Inc., GULF QUEST LP, HEALTHSPRING LIFE & HEALTH INSURANCE COMPANY, INC., HEALTHSPRING, INC., NEW QUEST LLC, PHYSICIANS MANAGEMENT LLC..(Joyce, Eamon) [Transferred from New York Southern on 9/30/2021.]
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Filing 44
LETTER MOTION for Conference / Pre-Motion Conference for Defendants' Motion to Transfer Venue addressed to Judge Kenneth M. Karas from Eamon P. Joyce dated September 8, 2020. Document filed by ALEGIS CARE SERVICES, LLC, CIGNA Corporation, CONNECTICUT GENERAL CORP., Cigna Holdings, Inc., GULF QUEST LP, HEALTHSPRING LIFE & HEALTH INSURANCE COMPANY, INC., HEALTHSPRING, INC., NEW QUEST LLC, PHYSICIANS MANAGEMENT LLC..(Joyce, Eamon) [Transferred from New York Southern on 9/30/2021.]
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Filing 43
RULE 7.1 CORPORATE DISCLOSURE STATEMENT. Identifying Corporate Parent Home Physicians Management, LLC for ALEGIS CARE SERVICES, LLC; Corporate Parent NewQuest, LLC for GULF QUEST LP, HEALTHSPRING LIFE & HEALTH INSURANCE COMPANY, INC., HOME PHYSICIANS MANAGEMENT LLC; Corporate Parent Connecticut General Corp. for HEALTHSPRING, INC.; Corporate Parent Cigna Holding Company, Corporate Parent Cigna Corp. for Cigna Holdings, Inc.; Corporate Parent HealthSpring Inc. for NEW QUEST LLC; Corporate Parent Cigna Holdings, Inc. for CONNECTICUT GENERAL CORP.. Document filed by ALEGIS CARE SERVICES, LLC, CIGNA Corporation, CONNECTICUT GENERAL CORP., Cigna Holdings, Inc., GULF QUEST LP, HEALTHSPRING LIFE & HEALTH INSURANCE COMPANY, INC., HEALTHSPRING, INC., HOME PHYSICIANS MANAGEMENT LLC, NEW QUEST LLC, PHYSICIANS MANAGEMENT LLC..(Joyce, Eamon) [Transferred from New York Southern on 9/30/2021.]
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Filing 42
NOTICE OF APPEARANCE by Eamon Paul Joyce on behalf of ALEGIS CARE SERVICES, LLC, CIGNA Corporation, CONNECTICUT GENERAL CORP., Cigna Holdings, Inc., GULF QUEST LP, HEALTHSPRING LIFE & HEALTH INSURANCE COMPANY, INC., HEALTHSPRING, INC., NEW QUEST LLC, PHYSICIANS MANAGEMENT LLC..(Joyce, Eamon) [Transferred from New York Southern on 9/30/2021.]
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Filing 41
AFFIDAVIT OF SERVICE of Summons and Amended Complaint,. NEW QUEST LLC served on 8/25/2020, answer due 9/15/2020. Document filed by UNITED STATES OF AMERICA, EX REL. ROBERT A. CUTLER..(Cutler, Robert) [Transferred from New York Southern on 9/30/2021.]
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Filing 40
AFFIDAVIT OF SERVICE of Summons and Amended Complaint,. CONNECTICUT GENERAL CORP. served on 8/25/2020, answer due 9/15/2020. Document filed by UNITED STATES OF AMERICA, EX REL. ROBERT A. CUTLER..(Cutler, Robert) [Transferred from New York Southern on 9/30/2021.]
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Filing 39
AFFIDAVIT OF SERVICE of Summons and Amended Complaint,. Cigna Holdings, Inc. served on 8/25/2020, answer due 9/15/2020. Document filed by UNITED STATES OF AMERICA, EX REL. ROBERT A. CUTLER..(Cutler, Robert) [Transferred from New York Southern on 9/30/2021.]
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Filing 38
AFFIDAVIT OF SERVICE of Summons and Amended Complaint,. CIGNA Corp. served on 8/25/2020, answer due 9/15/2020. Document filed by UNITED STATES OF AMERICA, EX REL. ROBERT A. CUTLER..(Cutler, Robert) [Transferred from New York Southern on 9/30/2021.]
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Filing 37
AFFIDAVIT OF SERVICE of Summons and Amended Complaint,. PHYSICIANS MANAGEMENT LLC served on 8/25/2020, answer due 9/15/2020. Document filed by UNITED STATES OF AMERICA, EX REL. ROBERT A. CUTLER..(Cutler, Robert) [Transferred from New York Southern on 9/30/2021.]
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Filing 36
AFFIDAVIT OF SERVICE of Summons and Amended Complaint,. HEALTHSPRING, INC. served on 8/25/2020, answer due 9/15/2020. Document filed by UNITED STATES OF AMERICA, EX REL. ROBERT A. CUTLER..(Cutler, Robert) [Transferred from New York Southern on 9/30/2021.]
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Filing 35
AFFIDAVIT OF SERVICE of Summons and Amended Complaint,. ALEGIS CARE SERVICES, LLC served on 8/25/2020, answer due 9/15/2020. Document filed by UNITED STATES OF AMERICA, EX REL. ROBERT A. CUTLER..(Cutler, Robert) [Transferred from New York Southern on 9/30/2021.]
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Filing 34
ELECTRONIC SUMMONS ISSUED as to PHYSICIANS MANAGEMENT LLC..(pc) [Transferred from New York Southern on 9/30/2021.]
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Filing 33
ELECTRONIC SUMMONS ISSUED as to HEALTHSPRING LIFE & HEALTH INSURANCE COMPANY, INC...(pc) [Transferred from New York Southern on 9/30/2021.]
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Filing 32
REQUEST FOR ISSUANCE OF SUMMONS as to Physicians Management LLC, re: #12 Amended Complaint,. Document filed by UNITED STATES OF AMERICA, EX REL. ROBERT A. CUTLER..(Cutler, Robert) [Transferred from New York Southern on 9/30/2021.]
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Filing 31
REQUEST FOR ISSUANCE OF SUMMONS as to HealthSpring Life & Health Insurance Company, Inc., re: #12 Amended Complaint,. Document filed by UNITED STATES OF AMERICA, EX REL. ROBERT A. CUTLER..(Cutler, Robert) [Transferred from New York Southern on 9/30/2021.]
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Filing 30
ELECTRONIC SUMMONS ISSUED as to NEW QUEST LLC..(jgo) [Transferred from New York Southern on 9/30/2021.]
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Filing 29
ELECTRONIC SUMMONS ISSUED as to HEALTHSPRING, INC...(jgo) [Transferred from New York Southern on 9/30/2021.]
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Filing 28
ELECTRONIC SUMMONS ISSUED as to GULF QUEST LP..(jgo) [Transferred from New York Southern on 9/30/2021.]
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Filing 27
ELECTRONIC SUMMONS ISSUED as to CONNECTICUT GENERAL CORP...(jgo) [Transferred from New York Southern on 9/30/2021.]
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Filing 26
ELECTRONIC SUMMONS ISSUED as to Cigna Holdings, Inc...(jgo) [Transferred from New York Southern on 9/30/2021.]
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Filing 25
ELECTRONIC SUMMONS ISSUED as to CIGNA Corporation..(jgo) [Transferred from New York Southern on 9/30/2021.]
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Filing 24
ELECTRONIC SUMMONS ISSUED as to ALEGIS CARE SERVICES, LLC..(jgo) [Transferred from New York Southern on 9/30/2021.]
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***NOTICE TO ATTORNEY REGARDING DEFICIENT REQUEST FOR ISSUANCE OF SUMMONS. Notice to Attorney Robert A. Cutler to RE-FILE Document No. #20 Request for Issuance of Summons, #22 Request for Issuance of Summons,. The filing is deficient for the following reason(s): party name on the PDF 'To' section (Docs. 20 & 22) and the 'as to' docket entry text (Doc. 22) does not exactly match as it appears on the pleading caption;. Re-file the document using the event type Request for Issuance of Summons found under the event list Service of Process - select the correct filer/filers - and attach the correct summons form PDF. (jgo) [Transferred from New York Southern on 9/30/2021.]
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Filing 23
REQUEST FOR ISSUANCE OF SUMMONS as to Alegis Care Services, LLC, re: #12 Amended Complaint,. Document filed by UNITED STATES OF AMERICA, EX REL. ROBERT A. CUTLER..(Cutler, Robert) [Transferred from New York Southern on 9/30/2021.]
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Filing 22
FILING ERROR - SUMMONS REQUEST 'As To' AND PDF ERROR - REQUEST FOR ISSUANCE OF SUMMONS as to Home Physicians Management LLC, re: #12 Amended Complaint,. Document filed by UNITED STATES OF AMERICA, EX REL. ROBERT A. CUTLER..(Cutler, Robert) Modified on 8/18/2020 (jgo). [Transferred from New York Southern on 9/30/2021.]
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Filing 21
REQUEST FOR ISSUANCE OF SUMMONS as to Gulf Quest LP, re: #12 Amended Complaint,. Document filed by UNITED STATES OF AMERICA, EX REL. ROBERT A. CUTLER..(Cutler, Robert) [Transferred from New York Southern on 9/30/2021.]
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Filing 20
FILING ERROR - SUMMONS REQUEST PDF ERROR - REQUEST FOR ISSUANCE OF SUMMONS as to HealthSpring Life & Health Insurance Company, Inc., re: #12 Amended Complaint,. Document filed by UNITED STATES OF AMERICA, EX REL. ROBERT A. CUTLER..(Cutler, Robert) Modified on 8/18/2020 (jgo). [Transferred from New York Southern on 9/30/2021.]
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Filing 19
REQUEST FOR ISSUANCE OF SUMMONS as to New Quest LLC, re: #12 Amended Complaint,. Document filed by UNITED STATES OF AMERICA, EX REL. ROBERT A. CUTLER..(Cutler, Robert) [Transferred from New York Southern on 9/30/2021.]
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Filing 18
REQUEST FOR ISSUANCE OF SUMMONS as to HealthSpring, Inc., re: #12 Amended Complaint,. Document filed by UNITED STATES OF AMERICA, EX REL. ROBERT A. CUTLER..(Cutler, Robert) [Transferred from New York Southern on 9/30/2021.]
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Filing 17
REQUEST FOR ISSUANCE OF SUMMONS as to Connecticut General Corp., re: #12 Amended Complaint,. Document filed by UNITED STATES OF AMERICA, EX REL. ROBERT A. CUTLER..(Cutler, Robert) [Transferred from New York Southern on 9/30/2021.]
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Filing 16
REQUEST FOR ISSUANCE OF SUMMONS as to Cigna Holdings, Inc., re: #12 Amended Complaint,. Document filed by UNITED STATES OF AMERICA, EX REL. ROBERT A. CUTLER..(Cutler, Robert) [Transferred from New York Southern on 9/30/2021.]
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Filing 15
REQUEST FOR ISSUANCE OF SUMMONS as to Cigna Corporation, re: #12 Amended Complaint,. Document filed by UNITED STATES OF AMERICA, EX REL. ROBERT A. CUTLER..(Cutler, Robert) [Transferred from New York Southern on 9/30/2021.]
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Filing 13
NOTICE of THE UNITED STATES THAT IT IS DECLINING IN PART AND NOT INTERVENING AS TO THE REMAINING CLAIMS AT THIS TIME. (yv) [Transferred from New York Southern on 9/30/2021.]
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Filing 14
UNSEALING ORDER. IT IS HEREBY ORDERED THAT: The amended qui tam complaint shall be unsealed on April 10, 2020. In the event that the relater has not moved to dismiss the action, service upon the defendants by the relater is authorized as of that date. The Notice shall be served by the relator upon defendants only after the service of the amended qui tam complaint. Except for the relator's amended qui tam complaint, this Order, and the Government's Notice, all other contents of the Court's file in this action as of the date of this Order shall remain under seal and not be made public or served upon the defendant. Upon the unsealing of the relator's amended qui tam complaint, the seal shall be lifted as to all matters occurring in this action subsequent to the date of the unsealing. The relator and defendants shall serve all pleadings and motions filed in this action, including all supporting memoranda, upon the Government; and the Government may order any transcripts of depositions. All further orders of this Court in this action shall be sent to the Government by the relator. So Ordered. ***This document was previously filed under seal in envelope #10 and unsealed by docket entry 11*** (Signed by Judge Kenneth M. Karas on 2/26/20) (yv) [Transferred from New York Southern on 9/30/2021.]
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Filing 11
UNSEALING ORDER. IT IS HEREBY ORDERED THAT: The amended qui tam complaint shall be unsealed on April 10, 2020. In the event that the relater has not moved to dismiss the action, service upon the defendants by the relater is authorized as of that date. The Notice shall be served by the relator upon defendants only after the service of the amended qui tam complaint. Except for the relator's amended qui tam complaint, this Order, and the Government's Notice, all other contents of the Court's file in this action as of the date of this Order shall remain under seal and not be made public or served upon the defendant. Upon the unsealing of the relator's amended qui tam complaint, the seal shall be lifted as to all matters occurring in this action subsequent to the date of the unsealing. The relator and defendants shall serve all pleadings and motions filed in this action, including all supporting memoranda, upon the Government; and the Government may order any transcripts of depositions. All further orders of this Court in this action shall be sent to the Government by the relator. So Ordered. ***This document was previously filed under seal in envelope #10 and unsealed by docket entry 11*** (Signed by Judge Kenneth M. Karas on 2/25/20) (yv) Modified on 8/6/2020 (yv). [Transferred from New York Southern on 9/30/2021.]
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Filing 10
SEALED DOCUMENT placed in vault..(bal) [Transferred from New York Southern on 9/30/2021.]
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Filing 9
SEALED DOCUMENT placed in vault.(bal) [Transferred from New York Southern on 9/30/2021.]
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Filing 12
AMENDED COMPLAINT against CONNECTICUT GENERAL CORP., Cigna Holdings, Inc., GULF QUEST LP, HEALTHSPRING LIFE & HEALTH INSURANCE COMPANY, INC., HEALTHSPRING, INC., NEW QUEST LLC, CIGNA Corporation, PHYSICIANS MANAGEMENT LLC, ALEGIS CARE SERVICES, LLC with JURY DEMAND.Document filed by UNITED STATES OF AMERICA, EX REL. ROBERT A. CUTLER. ***This document was previously filed under seal in envelope #8 and unsealed by docket entry 11***. (yv) Modified on 8/6/2020 (yv). [Transferred from New York Southern on 9/30/2021.]
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Filing 8
SEALED DOCUMENT placed in vault.(bal) [Transferred from New York Southern on 9/30/2021.]
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Filing 7
SEALED DOCUMENT placed in vault.(alo) [Transferred from New York Southern on 9/30/2021.]
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Filing 6
SEALED DOCUMENT placed in vault.(alo) [Transferred from New York Southern on 9/30/2021.]
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Filing 5
SEALED DOCUMENT placed in vault.(bal) [Transferred from New York Southern on 9/30/2021.]
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Filing 4
SEALED DOCUMENT placed in vault.(wc) [Transferred from New York Southern on 9/30/2021.]
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Filing 3
SEALED DOCUMENT placed in vault.(wc) [Transferred from New York Southern on 9/30/2021.]
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Filing 2
SEALED DOCUMENT placed in vault.(wc) [Transferred from New York Southern on 9/30/2021.]
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Filing 94
COMPLAINT against CIGNA Corp., CONNECTICUT GENERAL CORP., Cigna Holdings, Inc., GULF QUEST LP, HEALTHSPRING LIFE & HEALTH INSURANCE COMPANY, INC., HEALTHSPRING, INC., HOME PHYSICIANS MANAGEMENT LLC, NEW QUEST LLC. Document filed by UNITED STATES OF AMERICA, EX REL. ROBERT A. CUTLER. This document was previously filed under seal in envelope #1 and unsealed by docket entry 90.(yv) [Transferred from New York Southern on 9/30/2021.]
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Filing 1
SEALED DOCUMENT placed in vault. (mml) [Transferred from New York Southern on 9/30/2021.]
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Case Designated ECF. (mml) [Transferred from New York Southern on 9/30/2021.]
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Magistrate Judge Lisa M. Smith is so designated. Pursuant to 28 U.S.C. Section 636(c) and Fed. R. Civ. P. 73(b)(1) parties are notified that they may consent to proceed before a United States Magistrate Judge. Parties who wish to consent may access the necessary form at the following link: #http://nysd.uscourts.gov/forms.php. (mml) [Transferred from New York Southern on 9/30/2021.]
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