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Stock v. Integrated Health Plan

October 27, 2006

ANN M. STOCK, ET AL., PLAINTIFFS,
v.
INTEGRATED HEALTH PLAN, INC., DEFENDANT.



The opinion of the court was delivered by: Donald G. Wilkerson United States Magistrate Judge

ORDER

The Court held a telephonic discovery dispute conference with the parties on October 24, 2006. Jeffrey A.J. Millar appeared on behalf of Plaintiffs; Michael Kendall and Lauren M. Papenhausen appeared on behalf of Defendant. In the hearing, Defendant sought rulings as to whether Plaintiffs would be required to answer or supplement previous answers to numerous outstanding discovery requests and interrogatories served upon them. The rulings are set for below.

Also, Defendant made an oral motion to reset the deadline for taking Plaintiffs's depositions to avoid having to re-depose any witness in the event that, pursuant to this Order, Plaintiffs later provide more responses and/or documents that are relevant to deposition testimony. The oral motion is GRANTED and the deadline for taking Plaintiffs's depositions is hereby RESET to November 24, 2006.

PLAINTIFF ANN M.STOCK,D.C.'S RESPONSES TO DEFENDANT'S FIRST SET OF INTERROGATORIES*fn1

Interrogatory No. 11

Defendant seeks a list of all civil or criminal cases in which Plaintiff was a party. Plaintiff objects that this interrogatory is not reasonably calculated to lead to the discovery of admissible evidence and has limited her response to cases involving her and relating to Silent PPO's. The Court overrules Plaintiff's objection. Therefore, Plaintiff SHALL, by November 10, 2006, supplement his previous response to include all civil and criminal cases to which Plaintiff was a party -- not just those involving Silent PPO's.

Interrogatory No. 13

Defendant seeks a one to two paragraph summary of the reasons Plaintiff believes that equitable relief is necessary in this matter. Plaintiff's response directs Defendant to the Complaint. Plaintiff SHALL, by November 10, 2006, provide Defendant a one to two paragraph summary of the reasons Plaintiff believes that equitable relief is necessary in this matter.

Interrogatory No. 14

Defendant seeks the basis of Plaintiff's allegation of irreparable harm as made in paragraph 69 of the Complaint. Plaintiff's response directs Defendant to the Complaint. Plaintiff SHALL, by November 10, 2006, provide Defendant a one to two paragraph summary of the basis for her allegation of irreparable harm as made in paragraph 69 of the Complaint.

Interrogatory No. 16

Defendant seeks the approximate number of class members in the putative class and how Plaintiff arrived that number. Plaintiff's response provides a ballpark figure and directs Defendant to deposition testimony. Plaintiff SHALL, by November 10, 2006, supplement her previous response by providing an inventory of the proposed class members, organized according to geography, type of provider, type of contract, and type of insurance.

Interrogatory No. 17

Defendant seeks identification of other legal services that Plaintiff's counsel has provided Plaintiff in addition to representation in the current lawsuit. Plaintiff objects that this ...


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