John M. Morrison ORRISON S W DEOLA PLLP...John M. Morrison MORRISON SHERWOOD WILSON DEOLA, PLLP 401...

John M. Morrison MORRISON SHERWOOD WILSON DEOLA, PLLP 401 North Last Chance Gulch P.O. Box 557 Helena, Montana 59624-0557 (406) 442-3261 (406) 443-7294 facsimile [email protected]

John L. Amsden BECK, AMSDEN & STAPLES, PLLC 1946 Stadium Drive, Suite 1 Bozeman, MT 59715 (406) 586-8700 (406) 586-8960 [email protected] Attorneys for Plaintiffs

IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF MONTANA, GREAT FALLS DIVISION

AUDREY TURNER, VICKY BYRD, JENNIFER TANNER, LINDA LARSEN, PAUL LEE, BRANDI BRETH, KATE HOULIHAN and BARB MOSER,

Plaintiffs,

v. NORTHERN MONTANA HOSPITAL, a Montana Nonprofit Corporation, ST. PETER’S HOSPITAL, a Montana Nonprofit Corporation, BOZEMAN DEACONESS HEALTH SERVICES, a Montana Nonprofit Corporation, RCHP BILLINGS–MISSOULA, LLC, d/b/a COMMUNITY MEDICAL CENTER, a Delaware Limited Liability Corporation, and BILLINGS CLINIC, a Montana Nonprofit Corporation,

Defendants.

CAUSE NO. ______________

COMPLAINT FOR

AN ERISA ACCOUNTING

Case 4:17-cv-00141-BMM Document 1 Filed 12/29/17 Page 1 of 11

Page 2 of 11

COMPLAINT FOR AN ACCOUNTING

Plaintiffs complain and allege as follows in support of this complaint,

brought pursuant to the Employee Retirement Income Security Act of 1974, 29

U.S.C. §§ 1001, et. seq., seeking an accounting:

PARTIES, JURISDICTION AND VENUE

1. Plaintiff Audrey Turner is an individual residing in Hill County,

Montana. Plaintiff Turner is and/or was, at times relevant hereto, an employee of

Defendant Northern Montana Hospital and a participant in its employee benefit

health plan.

2. Plaintiff Vicky Byrd is an individual residing in Lewis and Clark

County, Montana. Plaintiff Byrd is and/or was, at times relevant hereto, an

employee of Defendant St. Peter’s Hospital and a participant in its employee

benefit health plan.

3. Plaintiff Jennifer Tanner is an individual residing in Jefferson County,

Montana. Plaintiff Tanner is and/or was, at times relevant hereto, an employee of

Defendant St. Peter’s Hospital and a participant in its employee benefit health plan.

4. Plaintiff Linda Larsen is an individual residing in Gallatin County,

Montana. Plaintiff Larsen is and/or was, at times relevant hereto, an employee of

Defendant Bozeman Deaconess Health Services, and a participant in its employee



Page 3 of 11

5. Plaintiff Paul Lee is an individual residing in Lewis and Clark County,

Montana. Plaintiff Lee is and/or was, at times relevant hereto, an employee of

Defendant St. Peter’s Hospital and a participant in its employee benefit health plan.

6. Plaintiff Brandi Breth is an individual residing in Missoula County,

Montana. Plaintiff Breth is and/or was, at times relevant hereto, an employee of

Defendant Community Medical Center Hospital and a participant in its employee


7. Plaintiff Kate Houlihan is an individual residing in Missoula County,

Montana. Plaintiff Houlihan is and/or was, at times relevant hereto, an employee of

Defendant RCHP Billings-Missoula, LLC, d/b/a Community Medical Center, and

a participant in its employee benefit health plan.

8. Plaintiff Barb Moser is an individual residing in Yellowstone County,

Montana. Plaintiff Moser is and/or was, at times relevant hereto, an employee of

Defendant Billings Clinic and a participant in its employee benefit health plan.

9. Plaintiffs are or at relevant times were employees of Defendants and

participants in Defendants’ employee benefit programs, which are governed by the

Employee Retirement Income Security Act of 1974, 29 U.S.C. §§ 1001, et. seq.

(“ERISA”).

10. Defendant St. Peter’s Hospital is a Montana public benefit corporation

operating as St. Peter’s Hospital in Lewis and Clark County, Helena, Montana.


Page 4 of 11

11. Defendant Bozeman Deaconess Health Services is a Montana public

benefit corporation operating as a community hospital in Gallatin County,

Bozeman, Montana.

12. Defendant Northern Montana Hospital is a Montana public benefit

corporation operating as a community hospital in Hill County, Havre, Montana.

13. Defendant RCHP Billings—Missoula, LLC, d/b/a Community

Medical Center is a foreign limited liability company or series limited liability

company, which owns Community Medical Center in Missoula County, Missoula,

Montana.

14. Defendant Billings Clinic is a non-profit health care organization

operating in Yellowstone County, Billings, Montana.

15. Defendants, collectively referred to herein as Defendants or “the

Hospitals,” sponsor employee health benefit plans by which eligible employees

and their eligible dependents obtain benefits.

16. John Does 1-10 are individuals or business entities who may owe

duties to Plaintiffs or be subject to an accounting on Plaintiffs’ behalf.

17. This Court has personal jurisdiction over Defendants, including

because Defendants are organized, incorporated or located in Montana, the claims

asserted herein arise out of Defendants’ activities within the state, including their


Page 5 of 11

operation of hospitals and clinics in Montana and the employment of Montana

citizens and residents.

18. As provided for in 28 U.S.C. § 1331 and 29 U.S.C. § 1132(e)(1), this

Court has subject matter jurisdiction over this action, including because it arises

under ERISA.

19. Pursuant to 28 U.S.C. § 1367(a), this Court further has supplemental

jurisdiction over all other claims that are so related to claims in the action within

such original jurisdiction that they form part of the same case or controversy under

Article III of the United States Constitution.

20. As provided in 29 U.S.C.A. § 1132(e)(2), venue is proper in this

Court, including because one or more of the subject plans is administered in this

district; breaches may have occurred here; and one or more of the Defendants may

be “found” in this district as that term is interpreted by ERISA jurisprudence,

providing that if a court may exercise personal jurisdiction, then the defendant is

“found” in that district for purposes of ERISA venue. Varsic v. U.S., 607 F.2d 245,

247-48 (9th Cir. 1979).

GENERAL ALLEGATIONS

21. Health Care Service Corporation is an Illinois mutual legal reserve

company doing business in Montana as “Blue Cross Blue Shield of Montana”

(BCBSMT, herein). BCBSMT provides health insurance coverage and/or third


Page 6 of 11

party administrative services to employers that sponsor employee health benefit

plans.

22. In 2011, Defendants made a deal with BCBSMT, commencing

January 1, 2012, that fundamentally affected the rights and interests of thousands

of Hospital employees, including the Plaintiffs.

23. On information and belief, the Hospitals each signed an agreement

with BCBSMT entitled an “Employee Benefit Plan Commitment Agreement”

(EBPCA) by which the Hospitals agreed to give BCBSMT their employee health

plan business, including administrative services and possibly reinsurance coverage,

for six years in return for total payments by BCBSMT to the Hospitals over the six

years of more than $20 million.

24. Publicly available documents reflect that BCBSMT expected to more

than make back this initial investment over the terms of its contracts with the

Defendants.

25. Defendants recently told employees during bargaining sessions that

health insurance was not subject to negotiations because a six-year commitment

had been made to BCBSMT.

26. Six years is an unusually long term for these types of agreements.

27. On information and belief, Plaintiffs allege that Defendants may have

received the above-described lucrative payments from BCBSMT in exchange for


Page 7 of 11

committing the plans to this unusually long contract term. Defendants may further

have committed the plans to pay inflated rates for coverage and/or administrative

services to BCBSMT as the means by which BCBSMT made back its initial

investment.

28. On information and belief, Plaintiffs allege that Defendants were used

some portion of the money received from BCBSMT, directly or indirectly, for their

own benefit at the expense of the Plaintiffs and other participants and beneficiaries.

29. It is highly unusual for an employer to receive payments from the

health insurer/administrator of its health plan. But to the extent value was received

for committing the health plan to BCBSMT, these funds belonged to the plan and

should have been preserved in the plan or distributed to the plan participants

including Plaintiffs.

30. Plaintiffs allege that Defendants are ERISA fiduciaries with duties to

Plaintiffs, including: (1) the duty of loyalty, requiring all decisions with regard to

the plan be made in the interests of the participants and beneficiaries; (2) the duty

of prudence, requiring the care, skill, prudence, and diligence of a prudent person

acting under similar circumstances; and, (3) the duty of exclusivity, requiring a

fiduciary to act for the exclusive purpose of providing benefits to plan participants.

31. On information and belief, Plaintiffs further allege that their

employers may have breached the foregoing duties. In their capacities as


Page 8 of 11

fiduciaries of the employee benefit plans, Defendants entered into agreements with

BCBSMT pursuant to which the plans may have paid inflated rates for

administrative services. It appears Defendants did so in exchange for lucrative

payments from BCBSMT which, in whole or part, benefited Defendants at the

expense of Plaintiffs and other participants in the plans.

32. Plaintiffs hereby seek an accounting as a means of determining

whether breaches of duty have occurred, including: 1) accepting money from

BCBSMT for the Defendant hospitals’ own benefit; 2) diverting money away from

the plans and their participants to the Hospitals for their own benefit; 3) paying

BCBSMT more than market price for the coverage or services provided, in order to

benefit Defendant hospitals at the expense of the plans and their participants;

and/or 4) selling and giving up, for the Hospitals’ own benefit, the right (and duty)

to shop for the best available value for the plans and their participants throughout

the six-year period.

COUNT I – FOR AN ACCOUNTING

(All Plaintiffs Against All Defendants)

33. Plaintiffs hereby incorporate every other allegation in this complaint

as though fully set forth herein.

34. Defendants are ERISA fiduciaries with respect to Plaintiffs and the

aforementioned employee benefit plans and, as such, owed duties of care and


Page 9 of 11

loyalty to Plaintiffs. 29 U.S.C. § 1002(21)(A); see also § 1102(a)(1). Defendants

are fiduciaries either by operation of law or due to their exercise of discretionary

authority, control or responsibility for management of plan assets or administration

of the plan.

35. Plaintiffs have a right to an accounting. As set forth in 29 U.S.C. §

1132(a)(1)(B), plan participants and beneficiaries may bring an action to clarify

their rights under the plan. As set forth in 29 U.S.C. § 1132(a)(3)(B), plan

participants and beneficiaries may bring actions to obtain appropriate equitable

relief to redress violations or enforce provisions of ERISA or the terms of their

plan. As set forth in 29 U.S.C. § 1109(a), fiduciaries are subject to equitable and

remedial claims.

36. The Supreme Court of the United States has recognized the equitable

relief available under ERISA to include actions for an accounting. E.g., Pender v.

Bank of America Corp., 788 F.3d 354, 364-65 (4th Cir. 2015) (ERISA provision

allowing participants to bring action for “appropriate equitable relief” to redress

ERISA violations authorized action seeking an accounting for profits against their

employer), on remand 2016 WL 1057635; Edmonson v. Lincoln Nat. Life Ins. Co.,

725 F.3d 406, 419 (3rd Cir. 2013), certiorari denied 134 S. Ct. 2291; Dunnigan v.

Metro. Life Ins. Co., 214 F.R.D. 125, 134 (S.D.N.Y. 2003).


Page 10 of 11

37. On information and belief, it appears that Defendants committed the

plans to long-term contracts with BCBSMT at such excessive rates that BCBSMT

was willing to pay substantial sums to Defendants in exchange for those

contractual commitments. This resulted in Plaintiffs and others similarly situated

paying more than the fair market value for the services provided by BCBSMT.

Moreover, rather than distributing to plan participants the payments received from

BCBSMT in exchange for these long-term commitments or preserving those

payments in the plans, it appears Defendants channeled at least some portion of

those payments to themselves and/or used the payments to supplant the Hospitals’

contributions to the plans so that the Hospitals could redeploy those funds for their

own self-serving purposes.

38. Defendants and BCBSMT have been secretive about the terms of the

agreement between them according to which the payments described herein are

made and Plaintiffs have only this year become aware of some of the terms of the

EBPCAs and the apparent diversion of funds by the Hospitals to themselves for

their own benefit. Although Plaintiffs have recently obtained some information, a

full accounting of the relationship and payments between BCBSMT and

Defendants in connection with the employee benefit plans has not been provided.

39. The relationships, payments and accounts that must be evaluated are

complicated in nature and scope.


Page 11 of 11

40. Plaintiffs need discovery in this accounting action to determine the

nature and extent of any ERISA violations that have occurred.

41. Such an accounting may demonstrate that Plaintiffs are entitled either

to further relief available under ERISA.

42. Pursuing alternative legal remedies at this time would require

Plaintiffs to assert allegations on information and belief without benefit of

assessing the accounting the nature and extent of any ERISA violations.

PRAYER FOR RELIEF

WHEREFORE, Plaintiffs pray for judgment against Defendants as follows:

1. For a court-ordered accounting of the transfers, transactions and

payments between and among Defendants, BCBSMT and the

employee benefit plans.

2. Any such other relief as may be permitted in equity or deemed

appropriate by this Court, including attorney fees and costs.

DATED this 29th day of December 2017.

By: /s/ John M. Morrison John M. Morrison MORRISON SHERWOOD WILSON DEOLA PLLP

Attorney for Plaintiffs


JS44 (Rev. 06/17) C I V I L C O V E R S H E E T

The JS 44 civil cover sheet and the information contained herein neither rgtlace nor supplement the filing and service of pleadings or other papers as required by law, except asprovided by local rules of court. This form, approved by the Judicial Conference of the United States in September 1974, is required for the use of the Clerk of Court for thepurpose of initiating the civil docket sheet. (SEE INSTRUCTIONS ON NEXT PAGE OF THIS FORM.)

'AtifWnWlySByrd , Jennifer Tanner, Linda Larsen, Paul Lee,Brandi Breth, Kate Houlihan and Barb Moser

(b) Cotmty of Residence of First Listed Plaintiff JHjjj

(EXCEPTIN US. PLAINTIFF CASES)

(c) Attorneys (Firm Name, Address, and Telephone Number)Jonn M. Morrison, Morrison Sherwood Wilson & Deola, PLLP

401 N. Last Chance Gulch, P.O. Box 557, Helena Ml 59624-0557

406-442-3261 & John Amsden, Beck Amsden & Staples, PLLC,

Jorthern Moriiana Hospital, a Montana Nonprofit Corporation, St.Peter's Hospital, a Montana Nonprofit Corporation, Bozeman

Deaconess Health Services, a Montana Nonprofit Corporation, et al.

County of Residence of First Listed Defendant Hill(IN as. PLAINTIFF CASES ONLY)

NOTE: IN LAND CONDEMNATION CASES, USE THE LOCATION OFTHE TRACT OF LAND INVOLVED.

Attorneys (If Known)

II. BASIS OF JURISDICTION (Place an "X" in One Box Only)

O 1 U.S. Government H 3 Federal Question

P l a i n t i f f ( U . S . G o v e r n m e n t N o t a P a r t y )

□ 2 U . S . G o v e r n m e n t □ 4 D i v e r s i t y

D e f e n d a n t ( I n d i c a t e C i t i z e n s h i p o f P a r t i e s i n I t e m I I I )

III, CITIZENSHIP OF PRINCIPAL PARTIES (Place an "X" in One Box for Plaintiff( F o r D i v e r s i t y C a s e s O n l y ) a n d O n e B o x f o r D e f e n d a n t )

P T E D E F P T F D E F

C i t i z e n o f T h i s S t a t e 0 1 □ 1 I n c o r p o r a t e d o r P r i n c i p a l P l a c e 0 4 0 4

of Business In This State

Citizen of Another State

Citizen or Subject of a

Foreign Country

□ 2 0 2 Incorporated cwf/Principal Placeof Business In Another State

□ 3 0 3 F o r e i g n N a t i o n

□ 5 D 5

D 6 n 6

IV, NATURE OF SUIT (Place an "X" in One Box Only)

LCl ick here fo r : Nature o f Su i t Code Descr ip t ions .

_ £ Q N 3 S A Q L T p R T ? F O R F E I T U R E / P E N A L T YBANKRyPTipV O T H E R S T A T U T E S

O 1 1 0 I n s u r a n c e

G 120 Marine

□ 130 Miller Act

□ 140 Negotiable Instrument

G 150 Recovery of Overpayment

& Enforcement of Judgment

G 151 Medicare Act

G 152 Recovery of Defaulted

Student Loans

(Excludes Veterans)G 153 Recovery of Overpayment

o f V e t e r a n ' s B e n e fi t s

G 160 Stockholders' Suits

□ 1 9 0 O t h e r C o n t r a c t

G 195 Contract Product LiabilityG 196 Franchise

R E A L P R O P E R T Y

P E R S O N A L I N J U R Y

G 310 Airplane

G 315 Airplane Product

LiabilityG 320 Assault, Libel &

S l a n d e r

G 330 Federal Employers'

LiabilityG 3 4 0 M a r i n e

G 3 4 5 M a r i n e P r o d u c t

LiabilityG 3 5 0 M o t o r V e h i c l e

G 355 Motor Vehicle

Product LiabilityG 360 Other Personal

InjuryG 362 Personal Injury -

Medical Malpractice

P E R S O N A L I N J U R Y

G 365 Personal Injury -

Product Liability

O 367 Health Care/

P h a r m a c e u t i c a l

Personal InjuryProduct Liability

G 368 Asbestos Personal

Injury Product

LiabilityP E R S O N A L P R O P E R T Y

G 3 7 0 O t h e r F r a u d

O 371 Truth in Lending

G 380 Other Personal

Property DamageG 385 Property Damage

Product Liability

G 625 Drug Related Seizure

of Property 21 USC88I

G 690 Other

G 422 Appeal 28 use 158

G 4 2 3 W i t h d r a w a l

2 8 u s e 1 5 7

P R O P E R T Y R I G H T S

G 820 Copyrights

G 8 3 0 P a t e n t

G 835 Patent - Abbreviated

New Drug Application

G 8 4 0 T r a d e m a r k

l a b o r

C I V I L R I G H T S

G 210 Land Condemnation

G 220 Foreclosure

G 230 Rent Lease & Ejectment

G 240 Torts to Land

G 245 Tort Product LiabilityG 290 All Other Real Property

G 440 Other Civil Rights

O 441 Voting

G 442 EmploymentG 443 Housing/

A c c o m m o d a t i o n s

G 445 Amer. w/Disabilities •

EmploymentG 4 4 6 A m e r . w / D i s a b i l i t i e s ■

O t h e r

G 4 4 8 E d u c a t i o n

P R I S O N E R P E T I T I O N S

Habeas Corpus:

G 463 Alien Detainee

G 510 Motions to Vacate

S e n t e n c e

G 5 3 0 G e n e r a l

G 535 Death Penalty

O t h e r :

G 5 4 0 M a n d a m u s & O t h e r

G 550 Civil Rights

G 555 Prison Condition

G 560 Civil Detainee-

Conditions of

C o n fi n e m e n t

G 710 Fair Labor Standards

A c t

G 720 Labor/Management

R e l a t i o n s

G 740 Railway Labor Act

G 751 Family and Medical

L e a v e A c t

G 790 Other Labor Litigation

^ 791 Employee RetirementIncome Security Act

s v c i A b g O T R i n r Y□ 861HIA(1395ff)

G 862 Black Lung (923)O 863 DIWC/DIWW (405(g))

G 864 SSID Title XVI

G 865 RSI (405(g))

F E D E R A L TA X S U I T S

G 870 Taxes (U.S. Plaintiff

or Defendant)

G 871 IRS—Third Party2 6 u s e 7 6 0 9

I M M I G R A T I O N

G 375 False Claims Act

G 376QuiTam(3I USC

3729(a))G 400 State Reapportionment

G 410 Anti trust

G 430 Banks and Banking

G 450 Commerce

G 460 DeportationO 470 Racketeer Influenced and

Corrupt OrganizationsG 480 Consumer Credit

G 490 Cable/Sat TV

G 850 Securities/Commodities/

ExchangeG 890 Other Statutory Actions

G 891 Agricultural Acts

G 893 Environmental Matters

G 895 Freedom of Information

A c t

G 896 Arbitration

G 899 Administrative Procedure

Act/Review or Appeal of

Agency DecisionG 950 Constitutionality of

S t a t e S t a t u t e s

G 462 Naturalization ApplicationG 465 Other Immigration

A c t i o n s

v. ORIGIN (Place an "X" in One Box Only)

X1 Or ig ina l □ 2 Removed f romP r o c e e d i n g S t a t e C o u r t

□ 3 R e m a n d e d f i ' o m

Appellate Court

□ 4 Reinstated or □ 5 Transferred from O 6 Mtiltidistrict □ 8 Multidistrict

R e o p e n e d A n o t h e r D i s t r i e t L i t i g a t i o n - L i t i g a t i o n -( s p e c i f y ) T r a n s f e r D i r e c t F i l e

V I . C A U S E O F A C T I O N

Cite the U.S. Civil Statute under which you are filing (Do not cite jurisdictional statutes unless diversity):2 9 U S C 6 11 3 2

Brief description of cause:

ERISA action for Accounting

VII. REQUESTED IN □ CHECK IF THIS IS A CLASS ACTION DEMANDS fiCC QU h/T/ PJ & CHECK YES only if demanded in complaint:

C O M P L A I N T: U N D E R r u l e 2 3 , F. R . C V. P. J U R Y D E M A N D : □ Ye s O N oVIII. RELATED CASE(S)

I F A N Y i n s t r u c t i o n s ) :J U D G E D O C K E T N U M B E R

D A T E

1 2 / 2 9 / 2 0 1 7

FOR OFFICE USE ONLY

SIGNATURE OF ATTORNEY OF RECORD

/s/ John M. Morrison

R E C E I P T # A M O U N T A P P L Y I N G I F F J U D G E M A G . J U D G E

Case 4:17-cv-00141-BMM Document 1-1 Filed 12/29/17 Page 1 of 1

AO 440 (Rev. 06/12) Summons in a Civil Action

UNITED STATES DISTRICT COURTfor the

__________ District of __________

))))))))))))

Plaintiff(s)

v. Civil Action No.

Defendant(s)

SUMMONS IN A CIVIL ACTION

To: (Defendant’s name and address)

A lawsuit has been filed against you.

Within 21 days after service of this summons on you (not counting the day you received it) — or 60 days if youare the United States or a United States agency, or an officer or employee of the United States described in Fed. R. Civ.P. 12 (a)(2) or (3) — you must serve on the plaintiff an answer to the attached complaint or a motion under Rule 12 ofthe Federal Rules of Civil Procedure. The answer or motion must be served on the plaintiff or plaintiff’s attorney,whose name and address are:

If you fail to respond, judgment by default will be entered against you for the relief demanded in the complaint. You also must file your answer or motion with the court.

CLERK OF COURT

Date:Signature of Clerk or Deputy Clerk


District of Montana

Audrey Turner, Vicky Byrd, Jennifer Tanner, Linda Larsen, Paul Lee, Brandi Breth, Kate Houlihan and

Barb Moser,

CV-17-141-GF-BMM

Northern Montana Hospital, a Montana Nonprofit Corporation, St. Peter's Hospital, a Montana

Nonprofit Corporation, Bozeman Deaconess Health Services, a Montana Nonprofit Corporation, et al.

Northern Montana Hospital c/o David C. Henry, Registered Agent 30 - 13th Street P.O. Box 1231 Havre MT 59501-1231

12/29/2017

AO 440 (Rev. 06/12) Summons in a Civil Action (Page 2)

Civil Action No.

PROOF OF SERVICE(This section should not be filed with the court unless required by Fed. R. Civ. P. 4 (l))

This summons for (name of individual and title, if any)

was received by me on (date) .

’ I personally served the summons on the individual at (place)

on (date) ; or

’ I left the summons at the individual’s residence or usual place of abode with (name)

, a person of suitable age and discretion who resides there,

on (date) , and mailed a copy to the individual’s last known address; or

’ I served the summons on (name of individual) , who is

designated by law to accept service of process on behalf of (name of organization)

on (date) ; or

’ I returned the summons unexecuted because ; or

’ Other (specify):

.

My fees are $ for travel and $ for services, for a total of $ .

I declare under penalty of perjury that this information is true.

Date:Server’s signature

Printed name and title

Server’s address

Additional information regarding attempted service, etc:


CV-17-141-GF-BMM

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__________ District of __________

))))))))))))

Plaintiff(s)

v. Civil Action No.

Defendant(s)






CLERK OF COURT



District of Montana


Barb Moser,

CV-17-141-GF-BMM



Bozeman Deaconess Health Services c/o Gordon L. Davidson, Registered Agent 915 Highland Blvd. Bozeman MT 59715

12/29/2017


Civil Action No.





on (date) ; or






on (date) ; or



.





Server’s address



CV-17-141-GF-BMM

0.00




__________ District of __________

))))))))))))

Plaintiff(s)

v. Civil Action No.

Defendant(s)






CLERK OF COURT



District of Montana


Barb Moser,

CV-17-141-GF-BMM



RCHP Billings-Missoula, LLC d/b/a Community Medical Center c/o CT Corporation System, Registered Agent 3011 American Way Missoula MT 59808

12/29/2017


Civil Action No.





on (date) ; or






on (date) ; or



.





Server’s address



CV-17-141-GF-BMM

0.00




__________ District of __________

))))))))))))

Plaintiff(s)

v. Civil Action No.

Defendant(s)






CLERK OF COURT



District of Montana


Barb Moser,

CV-17-141-GF-BMM



St. Peter's Hospital c/o John Green, Registered Agent 2475 Broadway Avenue Helena MT 59601

12/29/2017


Civil Action No.





on (date) ; or






on (date) ; or



.





Server’s address



CV-17-141-GF-BMM

0.00




__________ District of __________

))))))))))))

Plaintiff(s)

v. Civil Action No.

Defendant(s)






CLERK OF COURT



District of Montana


Barb Moser,

CV-17-141-GF-BMM



Billings Clinic c/o Ellen L. Layton, Registered Agent 2800 - 10th Avenue North Billings MT 59101

12/29/2017


Civil Action No.





on (date) ; or






on (date) ; or



.





Server’s address



CV-17-141-GF-BMM

0.00


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