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1
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COMPLAINT
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EXTRACTED KEY WORDS
MAGELLAN CLASS MEMBERS TREATMENT PHYSICIAN MAPS CRITERIA ERISA CLASS COVERAGE HEALTH INSURANCE HEALTH CARE PAID COST PLAINTIFFS PLAN CLAIMS REVIEWERS ADMINISTRATORS MAP DOCUMENTS SUBSTANCE ABUSE RICO CLASS TREATING PHYSICIANS MEDICAL NECESSITY POLICYHOLDERS MISREPRESENTATIONS ENTERPRISE RESTRICTING PURCHASED HEALTH INSURANCE INSURANCE COMPANIES RACKETEERING ACTIVITY RELEVANT TIMES |
UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF MISSOURI
B.S.W., T.A.W. and D.P.L. on behalf of )
themselves and all others )
similarly situated, )
)
Plaintiffs, )
)
v. )
)
MAGELLAN HEALTH SERVICES, )
INC., a Delaware Corporation, and )
MAGELLAN BEHAVIORAL )
HEALTH, INC. a Delaware )
Corporation, )
)
Serve: CSC-Lawyers Inc. Service Co. )
221 Bolivar Street )
Jefferson City, Missouri 65101 )
)
Defendants. )
CLASS ACTION
C:\Program Files\Adobe\Acrobat 4.0\Acrobat\plug_ins\OpenAll\Transform\temp\magellan_compl.wpd
I. INTRODUCTION
1. Millions of Americans confront a national crisis--as well as a personal
crisis--when they need treatment for mental illness or substance abuse. Less than one-
third of adults in this country with a diagnosable mental disorder actually receives
treatment in a given year. The most commonly cited reason is cost.
2. Although they have purchased health insurance policies that expressly
cover treatment for mental illness and substance abuse where such treatment is
"medically necessary," many policyholders discover they cannot obtain the treatment
their doctors say is necessary, because insurance companies and their claims reviewers
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