UNITED STATES DISTRICT COURT
FOR THE SOUTHERN DISTRICT OF FLORIDA
MIAMI DIVISION
MDL NO.: 1334
MASTER FILE NO.: 00-1334-MD-MORENO
IN RE:
HUMANA, INC., MANAGED CARE LITIGATION
THIS DOCUMENT RELATES ONLY
TO PROVIDER TRACK CASES
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CHARLES B. SHANE, M.D.; JEFFREY BOOK, D.O;
DENNIS BREEN, M.D.; MICHAEL BURGESS, M.D.;
EDWARD L. DAVIS, D.O.; LANCE R. GOODMAN, M.D.;
H. ROBERT HARRISON, M.D.; GLENN L. KELLY, M.D.;
LEONARD J. KLAY, M.D.; EUGENE MANGIERE, M.D.;
KEVIN MOLK, M.D.; MARTIN MORAN, M.D.;
MANUEL PORTH, M.D.; THOMAS BACKER, M.D.;
DAVID BOXSTEIN, M.D.; NAVID GHALAMBOR, M.D.;
SUSAN HANSEN, M.D.; ANDRES TALEISNIK, M.D.;
JULIO TALEISNIK, M.D.; ROGER WILSON, M.D.;
CALIFORNIA MEDICAL ASSOCIATION; DENTON
COUNTY MEDICAL SOCIETY; MEDICAL ASSOCIATION
OF GEORGIA; and TEXAS MEDICAL ASSOCIATION,
Plaintiffs,
vs.
HUMANA, INC.; AETNA, INC.; AETNA-USHC, INC.;
CIGNA; COVENTRY HEALTH CARE, INC.; HEALTH
NET, INC.; HUMANA HEALTH PLAN, INC.; PACIFICARE
HEALTH SYSTEMS, INC.; PRUDENTIAL INSURANCE
COMPANY OF AMERICA; UNITED HEALTH GROUP;
UNITED HEALTH CARE; and WELLPOINT HEALTH
NETWORKS, INC.;
Defendants.
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PROVIDER PLAINTIFFS' CONSOLIDATED,
SNIPPETS:
HUMANA, INC., MANAGED CARE LITIGATION
UNITED HEALTH CARE; and WELLPOINT HEALTH
PROVIDER PLAINTIFFS' CONSOLIDATED,
Amended Class Action Complaint, which is meant to be consistent with this
2000 Order Granting in Part and Denying in Part Various Defendants'
physicians cannot maintain
Defendants' capitation payment schedules are founded on actuarially unsound
If medical practice in the United States is to remain viable and if medical care is to
Dr. Backer provides or has provided services to patients insured
with Defendants CIGNA and Aetna.
and is a citizen of the United States of America.
patients insured with Defendants Aetna, CIGNA, United, Humana, Pacificare and Foundation.
Plaintiff, David Boxstein, M.D., a pediatrician, is a resident of the State of California,
services to patients insured with Defendants Aetna, Coventry, United, and Prudential.
and in its representative capacity, on behalf of its members in this proceeding against
courts, and in the private sector with large health plans, hospitals and other entities that
which generally direct and control the operations of said subsidiaries.
As Defendants have engaged in the unlawful overt and predicate acts against the IPAs,
contrary to stated corporate policy and to representations to the Plaintiffs.
the overt and predicate acts in furtherance of the conspiracy and aiding and abetting
Aetna-USHC Inc. Aetna, Inc.'s corporate headquarters is located at 151 Farmington Avenue,
the Aetna plan co-conspirators acted within the scope of their
In 1998, Foundation Health Systems, Inc.
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