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THIRD AMENDED COMPLAINT CASE NO. SACV15−736 DOC (DFMx)
206541.1
STRIS & MAHER LLP PETER K. STRIS (SBN 216226) [email protected] BRENDAN S. MAHER (SBN 217043) [email protected] RACHANA PATHAK (SBN 218521) [email protected] VICTOR O’CONNELL (SBN 288094) [email protected] KRISTINA KOURASIS (SBN 291729) [email protected] HANNA CHANDOO (SBN 306973) [email protected] 725 South Figueroa Street, Suite 1830 Los Angeles, CA 90017 T: (213) 995-6800 | F: (213) 261-0299
SOVEREIGN ASSET MANAGEMENT, INC. d/b/a SOVEREIGN HEALTH GROUP SETH ZAJAC (SBN 285718) [email protected] 1211 Puerta Del Sol, Suite 280 San Clemente, CA 92673 T: (949) 276-5553 | F: (949) 272-5797
Attorneys for Plaintiffs DUAL DIAGNOSIS TREATMENT CENTER, INC., et al.
UNITED STATES DISTRICT COURT
CENTRAL DISTRICT OF CALIFORNIA
SOUTHERN DIVISION
DUAL DIAGNOSIS TREATMENTCENTER, INC., et al.,
Plaintiffs,
v.
BLUE CROSS OF CALIFORNIA, et al.,
Defendants.
Case No. SACV15−0736 DOC (DFMx)
THIRD AMENDED COMPLAINT FOR:
VIOLATIONS OF ERISA (Claims for Benefits under 29 U.S.C. § 1132(a))
UNFAIR COMPETITION (Common Law and Cal. Bus. & Prof. Code §§ 17200 et seq.)
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INTRODUCTION
1. The Blue Cross Blue Shield Association (the “Association”) and its
affiliated insurance companies (the “Blue Cross Companies”) (collectively “Blue
Cross”) provide health insurance coverage to about one in three Americans. According
to Blue Cross’s own press, ninety-one percent of health care providers have contracted
with Blue Cross entities to offer discounted services to Blue Cross members, and
ninety-seven percent of the claims that Blue Cross pays are to such “in-network”
providers.
2. This litigation arises out of Blue Cross’s efforts to coerce the few
remaining “out-of-network” providers, such as Plaintiffs Dual Diagnosis Treatment
Center, Inc., Satya Health of California, Inc., Adeona Healthcare, Inc., Sovereign
Health of Phoenix, Inc., Sovereign Asset Management, Inc., and Medical Concierge,
Inc. to join Blue Cross’s vast provider network.
3. Plaintiffs treat individuals suffering from drug addiction and/or mental
health problems. As a matter of practice, Plaintiffs obtain assignments from their
patients.
4. Plaintiffs bring this suit to enforce their valid assignments of benefits and
to vindicate their rights under the Employee Retirement Income Security Act of 1974
(“ERISA”) and state law.
5. In a nutshell, Blue Cross (in concert with compliant Welfare Plan
Defendants listed below) does everything it can to undermine Plaintiffs’ ability to
operate as independent, out-of-network (“OON”) providers. Specifically, Blue Cross
(1) misleads Plaintiffs about whether claims are assignable under the governing plan
documents, and then later, with no explanation, refuses to pay Plaintiffs and instead
pays some unknown amount to the recovering addicts themselves, (2) refuses to honor
assignments even when the underlying plan document permits them, and (3) never
plainly tells its beneficiaries that the assignments they choose to give will not be
honored. All of this is prohibited by ERISA and state law.
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6. This scheme of deception and confusion leaves OON providers like
Plaintiffs misled, confused, and often holding the bag for services rendered to suffering
patients in good faith—all of which unfairly increases the cost of running their
businesses. Defendants do not even attempt to hide this conduct; as one Blue Cross
company described it: “payments for services rendered by providers who do not
contract with [Blue Cross] are sent directly to our customers. Thus, out-of-network
providers face the inconvenience of attempting to collect payment from the customer
and the accompanying possibility of incurring bad debts.” See Blue Perspective:
BCBSOK Position on Legislation and Regulatory Issues, Blue Cross Blue Shield
Oklahoma, www.bcbsok.com/grassroots/pdf/blueperspective_aob27-103003.pdf (last
visited Dec. 23, 2016).
7. This scheme directly serves Blue Cross, who clearly hopes that its cynical
campaign to mislead, stonewall, and bully OON providers like Plaintiffs will force
them to join Blue Cross’s network. Cutting providers out of the process also saves
Defendants money by leaving to unsophisticated patients (i.e., recovering addicts) the
responsibility of ensuring that the insurance plans have fully paid the patients’ benefit
entitlements.
JURISDICTION AND VENUE
8. This Court has subject matter jurisdiction over this action pursuant to
28 U.S.C. § 1331 and ERISA § 502(e)(1), 29 U.S.C. § 1132(e)(1), and pursuant to
28 U.S.C. § 1367.
9. ERISA provides for nationwide service of process. ERISA § 502(e)(2),
29 U.S.C. § 1132(e)(2). All Defendants are either residents of the United States or
subject to service in the United States and this Court therefore has personal jurisdiction
over them.
10. Venue is proper in this District pursuant to ERISA § 502(e)(2), 29 U.S.C.
§ 1132(e)(2), because much of the conduct that is the subject of this lawsuit occurred
within this District, and at least one Defendant resides in this District and all
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Defendants conduct business within this District, either directly or through wholly
owned and controlled subsidiaries.
THE PARTIES
A. Plaintiffs
11. Plaintiffs are entities that provide in- and out-patient substance abuse
and/or mental health treatment in California and Arizona.1
12. Dual Diagnosis Treatment Center, Inc. (“Dual Diagnosis”). Plaintiff Dual
Diagnosis is a corporation duly organized and existing under the laws of California.
Dual Diagnosis does business as “Sovereign Health of California,” and on occasion
under other names in accordance with its governing certifications and licensures. Dual
Diagnosis is certified to operate and maintain behavioral health treatment facilities in
San Clemente, Culver City, and Palm Springs, California.
13. Satya Health of California, Inc. (“Satya”). Plaintiff Satya is a corporation
duly organized and existing under the laws of California. Satya does business as
“Sovereign by the Sea II,” and on occasion under other names in accordance with its
governing certifications and licensures. Satya is licensed to operate and maintain
behavioral health treatment facilities in San Clemente, Culver City, and Palm Springs,
California.
14. Adeona Healthcare, Inc. (“Adeona”). Plaintiff Adeona is a corporation
duly organized and existing under the laws of California. Adeona does business as
“Sovereign Health Rancho/San Diego.” Adeona is licensed to operate and maintain a
children’s group home in El Cajon, California.
15. Sovereign Health of Phoenix, Inc. (“Sovereign Phoenix”). Plaintiff
Sovereign Phoenix is a corporation duly organized and existing under the laws of
Delaware, doing business as “Sovereign Health of Phoenix.” Sovereign Phoenix is
1 In accordance with this Court’s Order dated September 25, 2017 (“Sept. 25 Order”), see Sept. 25 Order at 20 n.9, Plaintiffs confirm that Sovereign Health of Florida is no longer a plaintiff in this case.
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licensed to operate and maintain a behavioral health residential facility in Chandler,
Arizona.
16. Sovereign Asset Management, Inc. (“SAM”). Plaintiff SAM is a
corporation duly organized and existing under the laws of Delaware, doing business as
“Sovereign Health Group.”2
17. For purposes of this Complaint, Dual Diagnosis, Satya, Adeona,
Sovereign Phoenix, and SAM are collectively referred or individually referred to as
“Sovereign,” as context requires.
18. Medical Concierge, Inc. (“Medlink”). Medlink is a corporation duly
organized and existing under the laws of California, doing business as “Medlink.”
Medlink is licensed to operate and maintain an adult residential facility (“ARF”) for
ambulatory mentally ill adults.
19. The above-described entities are referred to collectively as “Plaintiffs.”
B. Significant Non-Party
20. MedPro Billing, Inc. (“MedPro”). MedPro is a corporation duly organized
and existing under the laws of Florida. MedPro provides benefits verification and
eligibility information, utilization review, and medical billing and collection services
to mental health and substance abuse treatment providers. At pertinent times, MedPro
agreed to provide benefits verification and eligibility information, utilization review,
and medical billing and collection services to, and in certain ways act as an agent for,
Sovereign, in exchange for fair consideration.
C. Defendants
21. This lawsuit involves behavioral health treatment services rendered by
Plaintiffs to many individuals (“Former Patients”) who Plaintiffs are informed and
2 In light of this Court’s ruling on assignability of assignments, see Sept. 25 Order
at 6-7, SAM is named for appeal purposes only.
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believe, at all relevant times, possessed health insurance covering some or all of the
services that Plaintiffs provided.
22. Plaintiffs are informed and believe that the relevant health insurance of
each Former Patient was provided by an employer-sponsored plan covered by ERISA,
except for a handful of plans and policies.
23. Plaintiffs are also informed and believe that, with regard to each and every
Former Patient, the ERISA-governed coverage (or other coverage) was insured and/or
administered by one or more Blue Cross Company.
The ERISA Welfare Plan Defendants
24. Based upon documents obtained by Plaintiffs to date, Plaintiffs are
informed and believe that the health insurance of each Former Patient was obtained
through what ERISA defines as an “employee benefit plan.” 29 U.S.C. § 1002(3).
Specifically, Plaintiffs are informed and believe that the health insurance of each
Former Patient was obtained through what ERISA defines as a “welfare plan.”
29 U.S.C. § 1002(1). Section 502(d)(1) of ERISA, 29 U.S.C. § 1132(d)(1), provides
that “[a]n employee benefit plan [such as a welfare plan] may sue or be sued under this
subchapter as an entity . . . .” Plaintiffs name the following welfare plans as defendants
in this lawsuit:
25. 3M Employees’ Welfare Benefits Association (Trust II) Plan (the “3M
Plan”). Plaintiffs are informed and believe that Defendant 3M Plan is an employer-
sponsored welfare plan capable of suing and being sued pursuant to section 502(d) of
ERISA, 29 U.S.C. § 1132(d). The principal place of business of the 3M Plan is 3M
Center, 224-2W-15, St. Paul, Minnesota 55144.
26. Alltech, Inc. Benefit Plan (the “Alltech Plan”). Plaintiffs are informed and
believe that Defendant Alltech Plan is an employer-sponsored welfare plan capable of
suing and being sued pursuant to section 502(d) of ERISA, 29 U.S.C. § 1132(d). The
principal place of business of the Alltech Plan is 3031 Catnip Hill Pike, Nicholasville,
Kentucky 40356.
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27. Baxter International Inc. and Subsidiaries Welfare Benefit Plan (the
“Baxter Plan”). Plaintiffs are informed and believe that Defendant Baxter Plan is an
employer-sponsored welfare plan capable of suing and being sued pursuant to section
502(d) of ERISA, 29 U.S.C. § 1132(d). The principal place of business of the Baxter
Plan is One Baxter Parkway, Deerfield, Illinois 60015.
28. Chico’s FAS, Inc. Health & Welfare Benefit Plan (the “FAS Plan”).
Plaintiffs are informed and believe that Defendant FAS Plan is an employer-sponsored
welfare plan capable of suing and being sued pursuant to section 502(d) of ERISA,
29 U.S.C. § 1132(d). The principal place of business of the FAS Plan is 11215 Metro
Parkway, Fort Meyers, Florida 33966.
29. Covance, Inc. Health & Welfare Plan (the “Covance Plan”). Plaintiffs are
informed and believe that Defendant Covance Plan is an employer-sponsored welfare
plan capable of suing and being sued pursuant to section 502(d) of ERISA, 29 U.S.C.
§ 1132(d). The principal place of business of the Covance Plan is 210 Carnegie Center,
Princeton, New Jersey 08540.
30. C.R. Bard, Inc. Employee Benefit Plan (the “Bard Plan”). Plaintiffs are
informed and believe that Defendant Bard Plan is an employer-sponsored welfare plan
capable of suing and being sued pursuant to section 502(d) of ERISA, 29 U.S.C.
§ 1132(d). The principal place of business of the Bard Plan is 730 Central Avenue,
Murray Hill, New Jersey 07974.
31. Eaton Corporation Medical Plan for U.S. Employees (the “Eaton Plan”).
Plaintiffs are informed and believe that Defendant Eaton Plan is an employer-
sponsored welfare plan capable of suing and being sued pursuant to section 502(d) of
ERISA, 29 U.S.C. § 1132(d). The principal place of business of the Eaton Plan is 1000
Eaton Boulevard, Cleveland, Ohio 44122.
32. Elliott Electric Supply, Inc. Group Health Plan (the “Elliott Electric
Plan”). Plaintiffs are informed and believe that Defendant Elliott Electric Plan is an
employer-sponsored welfare plan capable of suing and being sued pursuant to section
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502(d) of ERISA, 29 U.S.C. § 1132(d). The principal place of business of the Elliott
Electric Plan is 2526 North Stallings Drive, Nacogdoches, Texas 75963.
33. Ernst & Young Medical Plan (the “Ernst & Young Plan”). Plaintiffs are
informed and believe that Defendant Ernst & Young Plan is an employer-sponsored
welfare plan capable of suing and being sued pursuant to section 502(d) of ERISA,
29 U.S.C. § 1132(d). The principal place of business of the Ernst & Young Plan is 200
Plaza Drive, Secaucus, New Jersey 07094.
34. Walter Investment Management Corp. Comprehensive Welfare Benefit
Plan, formerly known as Green Tree Comprehensive Welfare Plan (the “Green Tree
Plan”). Plaintiffs are informed and believe that Defendant Green Tree Plan is an
employer-sponsored welfare plan capable of suing and being sued pursuant to section
502(d) of ERISA, 29 U.S.C. § 1132(d). The principal place of business of the Green
Tree Plan is 600 Landmark Towers, 345 St. Peter Street, St. Paul, Minnesota 55102.
35. Group Health & Welfare Benefits Plan of American Eagle Airlines, Inc.
& Its Affiliates (the “AEA Plan”). Plaintiffs are informed and believe that Defendant
AEA Plan is an employer-sponsored welfare plan capable of suing and being sued
pursuant to section 502(d) of ERISA, 29 U.S.C. § 1132(d). The principal place of
business of the AEA Plan is 4333 Amon Carter Boulevard, MD-5485, Fort Worth,
Texas 76155.
36. The Group Life and Health Benefits Plan for Employees of Participating
AMR Corporation Subsidiaries (the “American Air Plan”). Plaintiffs are informed and
believe that Defendant American Air Plan is an employer-sponsored welfare plan
capable of suing and being sued pursuant to section 502(d) of ERISA, 29 U.S.C.
§ 1132(d). The principal place of business of the American Air Plan is 4333 Amon
Carter Boulevard, Fort Worth, Texas 76155.
37. H.E. Butt Grocery Company Welfare Benefit Plan (the “H.E. Butt
Grocery Plan”). Plaintiffs are informed and believe that Defendant H.E. Butt Grocery
Plan is an employer-sponsored welfare plan capable of suing and being sued pursuant
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to section 502(d) of ERISA, 29 U.S.C. § 1132(d). The principal place of business of
the H.E. Butt Grocery Plan is 646 South Main Avenue, San Antonio, Texas 78204.
38. Huntington Bancshares Incorporated Health Care Plan (the “Huntington
Plan”). Plaintiffs are informed and believe that Defendant Huntington Plan is an
employer-sponsored welfare plan capable of suing and being sued pursuant to section
502(d) of ERISA, 29 U.S.C. § 1132(d). The principal place of business of the
Huntington Plan is 41 South High Street HC0339, Columbus, Ohio 43215.
39. J.R. Simplot Company Group Health & Welfare Plan (the “Simplot
Plan”). Plaintiffs are informed and believe that Defendant Simplot Plan is an employer-
sponsored welfare plan capable of suing and being sued pursuant to section 502(d) of
ERISA, 29 U.S.C. § 1132(d). The principal place of business of the Simplot Plan is
999 Main Street, Boise, Idaho 83702.
40. Live Nation Entertainment, Inc. Group Benefits Plan (the “Live Nation
Plan”). Plaintiffs are informed and believe that Defendant Live Nation Plan is an
employer-sponsored welfare plan capable of suing and being sued pursuant to section
502(d) of ERISA, 29 U.S.C. § 1132(d). The principal place of business of the Live
Nation Plan is 7060 Hollywood Boulevard, 2nd Floor, Hollywood, California 90028.
41. Martin Marietta Medical Plan (the “Martin Marietta Plan”). Plaintiffs are
informed and believe that Defendant Martin Marietta Plan is an employer-sponsored
welfare plan capable of suing and being sued pursuant to section 502(d) of ERISA,
29 U.S.C. § 1132(d). The principal place of business of the Martin Marietta Plan is
2710 Wycliff Road, Raleigh, North Carolina 27607.
42. Novartis Corporation Welfare Benefit Plan (the “Novartis Plan”).
Plaintiffs are informed and believe that Defendant Novartis Plan is an employer-
sponsored welfare plan capable of suing and being sued pursuant to section 502(d) of
ERISA, 29 U.S.C. § 1132(d). The principal place of business of the Novartis Plan is
One South Ridgedale Avenue, East Hanover, New Jersey 07936.
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43. OraSure Technologies Inc. Health and Welfare Plan (the “OraSure Tech
Plan”). Plaintiffs are informed and believe that Defendant OraSure Tech Plan is an
employer-sponsored welfare plan capable of suing and being sued pursuant to section
502(d) of ERISA, 29 U.S.C. § 1132(d). The principal place of business of the OraSure
Tech Plan is 220 East First Street, Bethlehem, Pennsylvania 18015.
44. Owens-Illinois Hourly Employees Welfare Benefit Plan (the “Owens-
Illinois Plan”). Plaintiffs are informed and believe that Defendant Owens-Illinois Plan
is an employer-sponsored welfare plan capable of suing and being sued pursuant to
section 502(d) of ERISA, 29 U.S.C. § 1132(d). The principal place of business of the
Owens-Illinois Plan is One Michael Owens Way, Perrysburg, Ohio 43551.
45. Consolidated Graphics, Inc. Health Plan (the “Consolidated Graphics
Plan”). Plaintiffs are informed and believe that Defendant Consolidated Graphics Plan
is an employer-sponsored welfare plan capable of suing and being sued pursuant to
section 502(d) of ERISA, 29 U.S.C. § 1132(d). The principal place of business of the
Consolidated Graphics Plan is 1614 East 40th Street, Cleveland, Ohio 44103.
46. SAS Institute Inc. Welfare Benefits Plan (the “SAS Plan”). Plaintiffs are
informed and believe that Defendant SAS Plan is an employer-sponsored welfare plan
capable of suing and being sued pursuant to section 502(d) of ERISA, 29 U.S.C.
§ 1132(d). The principal place of business of the SAS Plan is SAS Campus Drive,
Cary, North Carolina 27513.
47. SeaBright Holdings, Inc. Group Health Plan (the “SeaBright Plan”).
Plaintiffs are informed and believe that Defendant SeaBright Plan is an employer-
sponsored welfare plan capable of suing and being sued pursuant to section 502(d) of
ERISA, 29 U.S.C. § 1132(d). The principal place of business of the SeaBright Plan is
1501 Fourth Avenue, Suite 2600, Seattle, Washington 98101.
48. TUV America, Inc. Insurance Benefits Plan (the “TUV Plan”). Plaintiffs
are informed and believe that the TUV Plan is an employer-sponsored welfare plan
capable of suing and being sued pursuant to section 502(d) of ERISA, 29 U.S.C.
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§ 1132(d). The principal place of business of the TUV Plan is 10 Centennial Drive,
Peabody, Massachusetts 01960.
49. Twin Cities Bakery Drivers Health & Welfare Fund (the “Bakery Drivers
Plan”). Plaintiffs are informed and believe that Defendant Bakery Drivers Plan is an
employer-sponsored welfare plan capable of suing and being sued pursuant to section
502(d) of ERISA, 29 U.S.C. § 1132(d). The principal place of business of the Bakery
Drivers Plan is 2919 Eagandale Boulevard, Suite 120, Eagan, Minnesota 55121.
50. Verizon National PPO West (the “Verizon Plan”). Plaintiffs are informed
and believe that Defendant Verizon Plan is an employer-sponsored welfare plan
capable of suing and being sued pursuant to section 502(d) of ERISA, 29 U.S.C.
§ 1132(d). The principal place of business of the Verizon Plan is One Verizon Way,
Basking Ridge, New Jersey 07920.
51. Vertical Search Works, Inc. Medical Plan (the “Vertical Plan”). Plaintiffs
are informed and believe that Defendant Vertical Plan is an employer-sponsored
welfare plan capable of suing and being sued pursuant to section 502(d) of ERISA,
29 U.S.C. § 1132(d). The principal place of business of the Vertical Plan is 1919
Gallows Road, Suite 1050, Vienna, Virginia 22182.
52. ViaSat, Inc. Employee Benefit Plan (the “ViaSat Plan”). Plaintiffs are
informed and believe that Defendant ViaSat Plan is an employer-sponsored welfare
plan capable of suing and being sued pursuant to section 502(d) of ERISA, 29 U.S.C.
§ 1132(d). The principal place of business of the ViaSat Plan is 6155 El Camino Real,
Carlsbad, California 92009.
53. WebMD Health and Welfare Plan (the “WebMD Plan”). Plaintiffs are
informed and believe that Defendant WebMD Plan is an employer-sponsored welfare
plan capable of suing and being sued pursuant to section 502(d) of ERISA, 29 U.S.C.
§ 1132(d). The principal place of business of the WebMD Plan is 111 Eighth Avenue,
7th Floor, New York, New York 10011.
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11 THIRD AMENDED COMPLAINT
CASE NO. SACV15−736 DOC (DFMx) 222434.2
54. Wells Fargo & Company Health Plan (the “WF Plan”). Plaintiffs are
informed and believe that Defendant WF Plan is an employer-sponsored welfare plan
capable of suing and being sued pursuant to section 502(d) of ERISA, 29 U.S.C.
§ 1132(d). The principal place of business of the WF Plan is Wells Fargo & Company,
333 Market Street, MAC A0109-080, 8th Floor, San Francisco, California 94105.
55. Xerox Business Services, LLC Funded Welfare Benefit Plan (the “Xerox
Plan”). Plaintiffs are informed and believe that Defendant Xerox Plan is an employer-
sponsored welfare plan capable of suing and being sued pursuant to section 502(d) of
ERISA, 29 U.S.C. § 1132(d). The principal place of business of the Xerox Plan is 1303
Ridgeview, R382-LV301, Lewisville, Texas 75057.
56. GKN Employee Welfare Benefit Plan (the “GKN Plan”). Plaintiffs are
informed and believe that Defendant GKN Plan is an employer-sponsored welfare plan
capable of suing and being sued pursuant to section 502(d) of ERISA, 29 U.S.C.
§ 1132(d). The principal place of business of the GKN Plan is 1150 West Bradley
Avenue, El Cajon, California 92020.
57. ION Geophysical Corporation Group Health Plan (the “ION Geophysical
Plan”). Plaintiffs are informed and believe that Defendant ION Geophysical Plan is an
employer-sponsored welfare plan capable of suing and being sued pursuant to section
502(d) of ERISA, 29 U.S.C. § 1132(d). The principal place of business of the ION
Geophysical Plan is 2105 City West Boulevard, Suite 400, Houston, Texas 77042.
58. Xerox Corporation Welfare Plan (the “Xerox Corp. Plan”). Plaintiffs are
informed and believe that Defendant Xerox Corp. Plan is an employer-sponsored
welfare plan capable of suing and being sued pursuant to section 502(d) of ERISA,
29 U.S.C. § 1132(d). The principal place of business of the Xerox Corp. Plan is
45 Glover Avenue, Norwalk, Connecticut 06856.
59. The Lilly Employee Welfare Plan (the “Eli Lilly Plan”). Plaintiffs are
informed and believe that Defendant Eli Lilly Plan is an employer-sponsored welfare
plan capable of suing and being sued pursuant to section 502(d) of ERISA, 29 U.S.C.
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CASE NO. SACV15−736 DOC (DFMx) 222434.2
§ 1132(d). The principal place of business of the Eli Lilly Plan is Lilly Corporate
Center, Indianapolis, Indiana 46285.
60. HL Financial Services, LLC Employee Benefits Plan (the “Hilliard Lyons
Plan”). Plaintiffs are informed and believe that Defendant Hilliard Lyons Plan is an
employer-sponsored welfare plan capable of suing and being sued pursuant to section
502(d) of ERISA, 29 U.S.C. § 1132(d). The principal place of business of the Hilliard
Lyons Plan is 500 West Jefferson Street, Suite 700, Louisville, Kentucky 40202.
61. The Master Builders Association Health Insurance Trust (the “Master
Builders Plan”). Plaintiffs are informed and believe that Defendant Master Builders
Plan is an employer-sponsored welfare plan capable of suing and being sued pursuant
to section 502(d) of ERISA, 29 U.S.C. § 1132(d). The principal place of business of
the Master Builders Plan is 335 116th Avenue S.E., Bellevue, Washington 98004.
62. Home Depot Welfare Benefits Plan (the “Home Depot Plan”). Plaintiffs
are informed and believe that Defendant Home Depot Plan is an employer-sponsored
welfare plan capable of suing and being sued pursuant to section 502(d) of ERISA,
29 U.S.C. § 1132(d). The principal place of business of the Home Depot Plan is 2455
Ferry Road, Atlanta, Georgia 30339.
63. IESI Corporation Employee Welfare Benefits Plan (the “IESI Corp.
Plan”). Plaintiffs are informed and believe that Defendant IESI Corp. Plan is an
employer-sponsored welfare plan capable of suing and being sued pursuant to section
502(d) of ERISA, 29 U.S.C. § 1132(d). The principal place of business of the IESI
Corp. Plan is 2301 Eagle Parkway, Suite 200, Fort Worth, Texas 76177.
64. Peak 10, Inc. Employee Benefit Plan (the “Peak 10 Plan”). Plaintiffs are
informed and believe that Defendant Peak 10 Plan is an employer-sponsored welfare
plan capable of suing and being sued pursuant to section 502(d) of ERISA, 29 U.S.C.
§ 1132(d). The principal place of business of the Peak 10 Plan is 8809 Lenox Pointe
Drive, Suite A, Charlotte, North Carolina 28273.
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13 THIRD AMENDED COMPLAINT
CASE NO. SACV15−736 DOC (DFMx) 222434.2
65. Peak Finance Company Group Health Plan (the “Peak Finance Plan”).
Plaintiffs are informed and believe that Defendant Peak Finance Plan is an employer-
sponsored welfare plan capable of suing and being sued pursuant to section 502(d) of
ERISA, 29 U.S.C. § 1132(d). The principal place of business of the Peak Finance Plan
is 5900 Canoga Avenue, Suite 200, Woodland Hills, California 91367.
66. Dycom Industries Health and Welfare Plan (the “Dycom Plan”). Plaintiffs
are informed and believe that Defendant Dycom Plan is an employer-sponsored
welfare plan capable of suing and being sued pursuant to section 502(d) of ERISA, 29
U.S.C. § 1132(d). The principal place of business of the Dycom Plan is 11780 U.S.
Highway 1, Suite 101, Palm Beach Gardens, Florida 33408.
67. Medtronic, Inc. Group Insurance Plan (the “Medtronic Plan”). Plaintiffs
are informed and believe that Defendant Medtronic Plan is an employer-sponsored
welfare plan capable of suing and being sued pursuant to section 502(d) of ERISA,
29 U.S.C. § 1132(d). The principal place of business of the Medtronic Plan is 710
Medtronic Parkway N.E., LC245, Minneapolis, Minnesota 55432.
68. PepsiCo Employee Health Care Program (the “PepsiCo Plan”). Plaintiffs
are informed and believe that Defendant PepsiCo Plan is an employer-sponsored
welfare plan capable of suing and being sued pursuant to section 502(d) of ERISA,
29 U.S.C. § 1132(d). The principal place of business of the PepsiCo Plan is 700
Anderson Hill Road, Purchase, New York 10577.
69. Follett Corporation Employees Benefit Trust (the “Follett Plan”).
Plaintiffs are informed and believe that Defendant Follett Plan is an employer-
sponsored welfare plan capable of suing and being sued pursuant to section 502(d) of
ERISA, 29 U.S.C. § 1132(d). The principal place of business of the Follett Plan is 3
Westbrook Corporate Center, Westchester, Illinois 60154.
70. Ogletree, Deakins, Nash, Smoak & Stewart, P.C. Group Medical Plan (the
“Ogletree Deakins Plan”). Plaintiffs are informed and believe that Defendant Ogletree
Deakins Plan is an employer-sponsored welfare plan capable of suing and being sued
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14 THIRD AMENDED COMPLAINT
CASE NO. SACV15−736 DOC (DFMx) 222434.2
pursuant to section 502(d) of ERISA, 29 U.S.C. § 1132(d). The principal place of
business of the Ogletree Deakins Plan is 300 North Main Street, Greenville, South
Carolina 29601.
71. Alaska Air Group, Inc. Welfare Benefit Plan (the “Alaska Air Plan”).
Plaintiffs are informed and believe that Defendant Alaska Air Plan is an employer-
sponsored welfare plan capable of suing and being sued pursuant to section 502(d) of
ERISA, 29 U.S.C. § 1132(d). The principal place of business of the Alaska Air Plan is
19300 International Boulevard, Seattle, Washington 98188.
72. FNB Corporation Health and Welfare Plan (the “FNB Corp. Plan”).
Plaintiffs are informed and believe that Defendant FNB Corp. Plan is an employer-
sponsored welfare plan capable of suing and being sued pursuant to section 502(d) of
ERISA, 29 U.S.C. § 1132(d). The principal place of business of the FNB Corp. Plan is
1 South Hermitage Road, Hermitage, Pennsylvania 16148.
73. LeCroy Health and Disability Benefit Plan (the “LeCroy Plan”). Plaintiffs
are informed and believe that Defendant LeCroy Plan is an employer-sponsored
welfare plan capable of suing and being sued pursuant to section 502(d) of ERISA,
29 U.S.C. § 1132(d). The principal place of business of the LeCroy Plan is 700
Chestnut Ridge Road, Chestnut Ridge, New York 10977.
74. MediaNews Group Welfare Benefits Plan (the “MediaNews Plan”).
Plaintiffs are informed and believe that Defendant MediaNews Plan is an employer-
sponsored welfare plan capable of suing and being sued pursuant to section 502(d) of
ERISA, 29 U.S.C. § 1132(d). The principal place of business of the MediaNews Plan
is 101 West Colfax Avenue, Suite 1100, Denver, Colorado 80202.
75. Sallie Mae Employees Comprehensive Welfare Benefits Plan (the “Sallie
Mae Plan”). Plaintiffs are informed and believe that Defendant Sallie Mae Plan is an
employer-sponsored welfare plan capable of suing and being sued pursuant to section
502(d) of ERISA, 29 U.S.C. § 1132(d). The principal place of business of the Sallie
Mae Plan is 300 Continental Drive, Newark, Delaware 19713.
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15 THIRD AMENDED COMPLAINT
CASE NO. SACV15−736 DOC (DFMx) 222434.2
76. Active Power, Inc. Health and Welfare Plan (the “Active Power Plan”).
Plaintiffs are informed and believe that Defendant Active Power Plan is an employer-
sponsored welfare plan capable of suing and being sued pursuant to section 502(d) of
ERISA, 29 U.S.C. § 1132(d). The principal place of business of the Active Power Plan
is 2128 West Braker Lane, BK12, Austin, Texas 78758.
77. Machinists Health & Welfare Trust Fund (the “Machinists Plan”).
Plaintiffs are informed and believe that Defendant Machinists Plan is an employer-
sponsored welfare plan capable of suing and being sued pursuant to section 502(d) of
ERISA, 29 U.S.C. § 1132(d). The principal place of business of the Machinists Plan is
9125 15th Place S., Seattle, Washington 98108.
78. Mueller Water Products, Inc. Flexible Benefits Plan (the “Mueller Plan”).
Plaintiffs are informed and believe that Defendant Mueller Plan is an employer-
sponsored welfare plan capable of suing and being sued pursuant to section 502(d) of
ERISA, 29 U.S.C. § 1132(d). The principal place of business of the Mueller Plan is
1200 Abernathy Road N.E., Suite 1200, Atlanta, Georgia 30328.
79. CNS Health and Welfare Benefits Plan (the “CNS Plan”). Plaintiffs are
informed and believe that Defendant CNS Plan is an employer-sponsored welfare plan
capable of suing and being sued pursuant to section 502(d) of ERISA, 29 U.S.C.
§ 1132(d). The principal place of business of the CNS Plan is 5215 Ashe Road,
Bakersfield, California 93313.
80. Alliant Insurance Services Welfare Benefits Plan (the “Alliant Plan”).
Plaintiffs are informed and believe that Defendant Alliant Plan is an employer-
sponsored welfare plan capable of suing and being sued pursuant to section 502(d) of
ERISA, 29 U.S.C. § 1132(d). The principal place of business of the Alliant Plan is
1301 Dove Street, Suite 200, Newport Beach, California 92660.
81. Publix Super Markets, Inc. Group Health Benefit Plan (the “Publix Plan”).
Plaintiffs are informed and believe that Defendant Publix Plan is an employer-
sponsored welfare plan capable of suing and being sued pursuant to section 502(d) of
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16 THIRD AMENDED COMPLAINT
CASE NO. SACV15−736 DOC (DFMx) 222434.2
ERISA, 29 U.S.C. § 1132(d). The principal place of business of the Publix Plan is
3300 Publix Corporate Parkway, Lakeland, Florida 33811.
82. Community Health Systems Group Health Plan (the “CHS Group Plan”).
Plaintiffs are informed and believe that Defendant CHS Group Plan is an employer-
sponsored welfare plan capable of suing and being sued pursuant to section 502(d) of
ERISA, 29 U.S.C. § 1132(d). The principal place of business of the CHS Group Plan
is 4000 Meridian Boulevard, Franklin, Tennessee 37067.
83. USUI International Group Health & Welfare Plan (the “USUI Plan”).
Plaintiffs are informed and believe that Defendant USUI Plan is an employer-
sponsored welfare plan capable of suing and being sued pursuant to section 502(d) of
ERISA, 29 U.S.C. § 1132(d). The principal place of business of the USUI Plan is 88
Partnership Way, Sharonville, Ohio 45241.
84. Transport Corporation of America, Inc. Employee Health and Welfare
Benefit Plan (the “Transport America Plan”). Plaintiffs are informed and believe that
Defendant Transport America Plan is an employer-sponsored welfare plan capable of
suing and being sued pursuant to section 502(d) of ERISA, 29 U.S.C. § 1132(d). The
principal place of business of the Transport America Plan is 1715 Yankee Doodle
Road, Eagan, Minnesota 55121.
85. Ardent Health Services Welfare Benefit Plan (the “Ardent Plan”).
Plaintiffs are informed and believe that Defendant Ardent Plan is an employer-
sponsored welfare plan capable of suing and being sued pursuant to section 502(d) of
ERISA, 29 U.S.C. § 1132(d). The principal place of business of the Ardent Plan is
1 Burton Hills Boulevard, Suite 250, Nashville, Tennessee 37215.
86. Fresenius Medical Care North America Medical Plan (the “Fresenius
Plan”). Plaintiffs are informed and believe that Defendant Fresenius Plan is an
employer-sponsored welfare plan capable of suing and being sued pursuant to section
502(d) of ERISA, 29 U.S.C. § 1132(d). The principal place of business of the Fresenius
Plan is 920 Winter Street, Waltham, Massachusetts 02451.
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17 THIRD AMENDED COMPLAINT
CASE NO. SACV15−736 DOC (DFMx) 222434.2
87. The Steak N Shake Employee Benefit Plan (the “Steak N Shake Plan”).
Plaintiffs are informed and believe that Defendant Steak N Shake Plan is an employer-
sponsored welfare plan capable of suing and being sued pursuant to section 502(d) of
ERISA, 29 U.S.C. § 1132(d). The principal place of business of the Steak N Shake
Plan is 107 South Pennsylvania Avenue, Suite 400, Indianapolis, Indiana 46204.
88. The Southwest Shipyard, LP Cafeteria Plan (the “S.W. Shipyard Plan”).
Plaintiffs are informed and believe that Defendant S.W. Shipyard Plan is an employer-
sponsored welfare plan capable of suing and being sued pursuant to section 502(d) of
ERISA, 29 U.S.C. § 1132(d). The principal place of business of the S.W. Shipyard
Plan is 18310 Market Street, Channelview, Texas 77530.
89. F5 Networks, Inc. Employee Benefit Plan (the “F5 Plan”). Plaintiffs are
informed and believe that Defendant F5 Plan is an employer-sponsored welfare plan
capable of suing and being sued pursuant to section 502(d) of ERISA, 29 U.S.C.
§ 1132(d). The principal place of business of the F5 Plan is 401 Elliott Avenue W.,
Seattle, Washington 98119.
90. MDU Resources Group, Inc. Health and Welfare Benefits Program (the
“MDU Plan”). Plaintiffs are informed and believe that Defendant MDU Plan is an
employer-sponsored welfare plan capable of suing and being sued pursuant to section
502(d) of ERISA, 29 U.S.C. § 1132(d). The principal place of business of the MDU
Plan is 1200 West Century Avenue, Bismarck, North Dakota 58503.
91. Employees’ Benefit Plan of General Mills, Inc. (the “General Mills
Plan”). Plaintiffs are informed and believe that Defendant General Mills Plan is an
employer-sponsored welfare plan capable of suing and being sued pursuant to section
502(d) of ERISA, 29 U.S.C. § 1132(d). The principal place of business of the General
Mills Plan is 1 General Mills Boulevard, BT02-C, Minneapolis, Minnesota 55426.
92. Northrop Grumman Corporation Group Benefits Plan (the “Northrop
Grumman Plan”). Plaintiffs are informed and believe that Defendant Northrop
Grumman Plan is an employer-sponsored welfare plan capable of suing and being sued
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18 THIRD AMENDED COMPLAINT
CASE NO. SACV15−736 DOC (DFMx) 222434.2
pursuant to section 502(d) of ERISA, 29 U.S.C. § 1132(d). The principal place of
business of the Northrop Grumman Plan is 2980 Fairview Park Drive, Falls Church,
Virginia 22042.
93. Rayonier, Inc. Welfare Plans (the “Rayonier Plan”). Plaintiffs are
informed and believe that Defendant Rayonier Plan is an employer-sponsored welfare
plan capable of suing and being sued pursuant to section 502(d) of ERISA, 29 U.S.C.
§ 1132(d). The principal place of business of the Rayonier Plan is 225 Water Street,
Suite 1400, Jacksonville, Florida 32202.
94. Randall S. Fudge P.C. Employee Benefits Plan (the “Fudge Plan”).
Plaintiffs are informed and believe that Defendant Fudge Plan is an employer-
sponsored welfare plan capable of suing and being sued pursuant to section 502(d) of
ERISA, 29 U.S.C. § 1132(d). The principal place of business of the Fudge Plan is 4801
Classen Boulevard, Suite 202, Oklahoma City, Oklahoma 73118.
95. Gentiva Health Services Health & Welfare Plan (the “Gentiva Plan”).
Plaintiffs are informed and believe that Defendant Gentiva Plan is an employer-
sponsored welfare plan capable of suing and being sued pursuant to section 502(d) of
ERISA, 29 U.S.C. § 1132(d). The principal place of business of the Gentiva Plan is
3350 Riverwood Parkway, Suite 1400, Atlanta, Georgia 30339.
96. eHealthInsurance Services, Inc. Plan (the “eHealth Plan”). Plaintiffs are
informed and believe that Defendant eHealth Plan is an employer-sponsored welfare
plan capable of suing and being sued pursuant to section 502(d) of ERISA, 29 U.S.C.
§ 1132(d). The principal place of business of the eHealth Plan is 440 East Middlefield
Road, Mountain View, California 94043.
97. Fastrac Markets LLC Employee Welfare Benefit Plan (the “Fastrac
Plan”). Plaintiffs are informed and believe that Defendant Fastrac Plan is an employer-
sponsored welfare plan capable of suing and being sued pursuant to section 502(d) of
ERISA, 29 U.S.C. § 1132(d). The principal place of business of the Fastrac Plan is
6500 New Venture Gear Road, E. Syracuse, New York 13057.
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19 THIRD AMENDED COMPLAINT
CASE NO. SACV15−736 DOC (DFMx) 222434.2
98. Wolseley North America Flexible Benefits Plan, formerly known as the
Ferguson Enterprises Inc. Flexible Benefits Plan (the “Ferguson Plan”). Plaintiffs are
informed and believe that Defendant Ferguson Plan is an employer-sponsored welfare
plan capable of suing and being sued pursuant to section 502(d) of ERISA, 29 U.S.C.
§ 1132(d). The principal place of business of the Ferguson Plan is 12500 Jefferson
Avenue, Newport News, Virginia 23602.
99. Pioneer Energy Services Corp. Group Health Plan (the “Pioneer Energy
Plan”). Plaintiffs are informed and believe that Defendant Pioneer Energy Plan is an
employer-sponsored welfare plan capable of suing and being sued pursuant to section
502(d) of ERISA, 29 U.S.C. § 1132(d). The principal place of business of the Pioneer
Energy Plan is 1250 N.E. Loop 410, Suite 1000, San Antonio, Texas 78209.
100. The Kroger Co. Health & Welfare Benefit Plan (the “Kroger Plan”).
Plaintiffs are informed and believe that Defendant Kroger Plan is an employer-
sponsored welfare plan capable of suing and being sued pursuant to section 502(d) of
ERISA, 29 U.S.C. § 1132(d). The principal place of business of the Kroger Plan is
1014 Vine Street, Cincinnati, Ohio 45202.
101. The Hartford Fire Insurance Company Employee Medical and Dental
Expense Benefits Plan (the “Hartford Plan”). Plaintiffs are informed and believe that
Defendant Hartford Plan is an employer-sponsored welfare plan capable of suing and
being sued pursuant to section 502(d) of ERISA, 29 U.S.C. § 1132(d). The principal
place of business of the Hartford Plan is One Hartford Plaza, H01-142, Hartford,
Connecticut 06155.
102. Bloomberg LP Health and Welfare Plan (the “Bloomberg Plan”).
Plaintiffs are informed and believe that Defendant Bloomberg Plan is an employer-
sponsored welfare plan capable of suing and being sued pursuant to section 502(d) of
ERISA, 29 U.S.C. § 1132(d). The principal place of business of the Bloomberg Plan is
731 Lexington Avenue, New York, New York 10022.
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CASE NO. SACV15−736 DOC (DFMx) 222434.2
103. Intel Corporation Health and Welfare Benefit Plan (the “Intel Plan”).
Plaintiffs are informed and believe that Defendant Intel Plan is an employer-sponsored
welfare plan capable of suing and being sued pursuant to section 502(d) of ERISA,
29 U.S.C. § 1132(d). The principal place of business of the Intel Plan is 1600 Rio
Rancho Boulevard, Rio Rancho, New Mexico 87124.
104. St. Luke’s Lutheran Care Center Employee Health Care Plan (the “St.
Luke’s Plan”). Plaintiffs are informed and believe that Defendant St. Luke’s Plan is an
employer-sponsored welfare plan capable of suing and being sued pursuant to section
502(d) of ERISA, 29 U.S.C. § 1132(d). The principal place of business of the St.
Luke’s Plan is 1219 South Ramsey Street, Blue Earth, Minnesota 56013.
105. TAC Manufacturing, Inc. Employee Welfare Benefit Plan (the “TAC
Plan”). Plaintiffs are informed and believe that Defendant TAC Plan is an employer-
sponsored welfare plan capable of suing and being sued pursuant to section 502(d) of
ERISA, 29 U.S.C. § 1132(d). The principal place of business of the TAC Plan is 4111
County Farm Road, Jackson, Michigan 49201.
106. Inlandboatmen’s Union of the Pacific National Health Benefit Trust (the
“IBU Health Plan”). Plaintiffs are informed and believe that Defendant IBU Health
Plan is an employer-sponsored welfare plan capable of suing and being sued pursuant
to section 502(d) of ERISA, 29 U.S.C. § 1132(d). The principal place of business of
the IBU Health Plan is 1220 S.W. Morrison Street, Suite 300, Portland, Oregon 97205.
107. Sheet Metal Workers’ Local No. 40 Health Fund (the “SMW No. 40
Plan”). Plaintiffs are informed and believe that Defendant SMW No. 40 Plan is an
employer-sponsored welfare plan capable of suing and being sued pursuant to section
502(d) of ERISA, 29 U.S.C. § 1132(d). The principal place of business of the SMW
No. 40 Plan is 100 Old Forge Road, Rocky Hill, Connecticut 06067.
108. The Aerospace Corporation Group Hospital-Medical Plan (the
“Aerospace Plan”). Plaintiffs are informed and believe that Defendant Aerospace Plan
is an employer-sponsored welfare plan capable of suing and being sued pursuant to
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section 502(d) of ERISA, 29 U.S.C. § 1132(d). The principal place of business of the
Aerospace Plan is 2310 E. El Segundo Boulevard, El Segundo, California 90245.
109. Albertson’s LLC Health & Welfare Plan (the “Albertson’s Plan”).
Plaintiffs are informed and believe that Defendant Albertson’s Plan is an employer-
sponsored welfare plan capable of suing and being sued pursuant to section 502(d) of
ERISA, 29 U.S.C. § 1132(d). The principal place of business of the Albertson’s Plan
is 250 Parkcenter Boulevard, Boise, Idaho 83706.
110. Spokane Teachers Credit Union Employee Medical & Dental Plan (the
“STCU Plan”). Plaintiffs are informed and believe that Defendant STCU Plan is an
employer-sponsored welfare plan capable of suing and being sued pursuant to section
502(d) of ERISA, 29 U.S.C. § 1132(d). The principal place of business of the STCU
Plan is 1620 North Signal Drive, Liberty Lake, Washington 99019.
111. Construction Industry Laborers Welfare Fund (the “CIL Plan”). Plaintiffs
are informed and believe that Defendant CIL Plan is an employer-sponsored welfare
plan capable of suing and being sued pursuant to section 502(d) of ERISA, 29 U.S.C.
§ 1132(d). The principal place of business of the CIL Plan is 6405 Metcalf, Suite 200,
Overland Park, Kansas 66202.
112. Intevac Life and Welfare Plan (the “Intevac Plan”). Plaintiffs are informed
and believe that Defendant Intevac Plan is an employer-sponsored welfare plan capable
of suing and being sued pursuant to section 502(d) of ERISA, 29 U.S.C. § 1132(d).
The principal place of business of the Intevac Plan is 3560 Bassett Street, Santa Clara,
California 95054.
113. Tenet Employee Benefit Plan (the “Tenet Plan”). Plaintiffs are informed
and believe that Defendant Tenet Plan is an employer-sponsored welfare plan capable
of suing and being sued pursuant to section 502(d) of ERISA, 29 U.S.C. § 1132(d).
The principal place of business of the Tenet Plan is 1445 Ross Avenue, Suite 1400,
Dallas, Texas 75202.
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114. The Lincoln Electric Company Welfare Benefits Plan (the “Lincoln
Electric Plan”). Plaintiffs are informed and believe that Defendant Lincoln Electric
Plan is an employer-sponsored welfare plan capable of suing and being sued pursuant
to section 502(d) of ERISA, 29 U.S.C. § 1132(d). The principal place of business of
the Lincoln Electric Plan is 22801 St. Clair Avenue, Cleveland, Ohio 44117.
115. Interrail Signals, Inc. Welfare Benefit Plan (the “Interrail Plan”).
Plaintiffs are informed and believe that Defendant Interrail Plan is an employer-
sponsored welfare plan capable of suing and being sued pursuant to section 502(d) of
ERISA, 29 U.S.C. § 1132(d). The principal place of business of the Interrail Plan is
12443 San Jose Boulevard, Suite 1103, Jacksonville, Florida 32223.
116. United Surgical Partners, Intl Welfare Benefit Plan (the “Surgical Partners
Plan”). Plaintiffs are informed and believe that Defendant Surgical Partners Plan is an
employer-sponsored welfare plan capable of suing and being sued pursuant to section
502(d) of ERISA, 29 U.S.C. § 1132(d). The principal place of business of the Surgical
Partners Plan is 15305 Dallas Parkway, Suite 1600, LB 28, Addison, Texas 75001.
117. Kentucky Construction Industry Trust (the “Kentucky Construction
Plan”). Plaintiffs are informed and believe that Defendant Kentucky Construction Plan
is an employer-sponsored welfare plan capable of suing and being sued pursuant to
section 502(d) of ERISA, 29 U.S.C. § 1132(d). The principal place of business of the
Kentucky Construction Plan is 333 West Vine Street, Lexington, Kentucky 40507.
118. General Nutrition Group Insurance Plan (the “GNC Plan”). Plaintiffs are
informed and believe that Defendant GNC Plan is an employer-sponsored welfare plan
capable of suing and being sued pursuant to section 502(d) of ERISA, 29 U.S.C.
§ 1132(d). The principal place of business of the GNC Plan is 300 Sixth Avenue,
Pittsburgh, Pennsylvania 15222.
119. SCANA Corporation Health & Welfare Plan (the “SCANA Plan”).
Plaintiffs are informed and believe that Defendant SCANA Plan is an employer-
sponsored welfare plan capable of suing and being sued pursuant to section 502(d) of
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CASE NO. SACV15−736 DOC (DFMx) 222434.2
ERISA, 29 U.S.C. § 1132(d). The principal place of business of the SCANA Plan is
220 Operation Way, Cayce, South Carolina 29033.
120. Ensco Health Plan (the “Ensco Plan”). Plaintiffs are informed and believe
that Defendant Ensco Plan is an employer-sponsored welfare plan capable of suing and
being sued pursuant to section 502(d) of ERISA, 29 U.S.C. § 1132(d). The principal
place of business of the Ensco Plan is 5847 San Felipe, Suite 3300, Houston, Texas
77057.
121. Metal-Matic, Inc. Welfare Benefit Plan (the “Metal-Matic Plan”).
Plaintiffs are informed and believe that Defendant Metal-Matic Plan is an employer-
sponsored welfare plan capable of suing and being sued pursuant to section 502(d) of
ERISA, 29 U.S.C. § 1132(d). The principal place of business of the Metal-Matic Plan
is 629 Second Street S.E., Minneapolis, Minnesota 55414.
122. Layne Christensen Company Health and Welfare Plan (the “Layne
Plan”). Plaintiffs are informed and believe that Defendant Layne Plan is an employer-
sponsored welfare plan capable of suing and being sued pursuant to section 502(d) of
ERISA, 29 U.S.C. § 1132(d). The principal place of business of the Layne Plan is 1800
Hughes Landing Boulevard, Suite 700, The Woodlands, Texas 77380.
123. L Brands, Inc. Health and Welfare Benefits Plan (the “L Brands Plan”).
Plaintiffs are informed and believe that Defendant L Brands Plan is an employer-
sponsored welfare plan capable of suing and being sued pursuant to section 502(d) of
ERISA, 29 U.S.C. § 1132(d). The principal place of business of the L Brands Plan is
Three Limited Parkway, Columbus, Ohio 43230.
124. Asante Employee Benefits Plan (the “Asante Plan”). Plaintiffs are
informed and believe that Defendant Asante Plan is an employer-sponsored welfare
plan capable of suing and being sued pursuant to section 502(d) of ERISA, 29 U.S.C.
§ 1132(d). The principal place of business of the Asante Plan is 2650 Siskiyou
Boulevard, Medford, Oregon 97504.
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24 THIRD AMENDED COMPLAINT
CASE NO. SACV15−736 DOC (DFMx) 222434.2
125. Nature’s Path Foods, Inc. Welfare Benefit Plan (the “Nature’s Path
Plan”). Plaintiffs are informed and believe that Defendant Nature’s Path Plan is an
employer-sponsored welfare plan capable of suing and being sued pursuant to section
502(d) of ERISA, 29 U.S.C. § 1132(d). The principal place of business of the Nature’s
Path Plan is 9100 Van Horne Way, Richmond, BC V6X 1W3, Canada.
126. Southern California IBEW-NECA Health Trust Fund (the “So. Cal.
IBEW-NECA Plan”). Plaintiffs are informed and believe that Defendant So. Cal.
IBEW-NECA Plan is an employer-sponsored welfare plan capable of suing and being
sued pursuant to section 502(d) of ERISA, 29 U.S.C. § 1132(d). The principal place of
business of the So. Cal. IBEW-NECA Plan is 6023 Garfield Avenue, Commerce,
California 90040.
127. Bimbo Bakeries USA Health and Welfare Plan (the “Bimbo Plan”).
Plaintiffs are informed and believe that Defendant Bimbo Plan is an employer-
sponsored welfare plan capable of suing and being sued pursuant to section 502(d) of
ERISA, 29 U.S.C. § 1132(d). The principal place of business of the Bimbo Plan is
225 Business Center Drive, Horsham, Pennsylvania 19044.
128. Sage Software Inc. and Co-Sponsoring Affiliates Health and Welfare Plan
(the “Sage Software Plan”). Plaintiffs are informed and believe that Defendant Sage
Software Plan is an employer-sponsored welfare plan capable of suing and being sued
pursuant to section 502(d) of ERISA, 29 U.S.C. § 1132(d). The principal place of
business of the Sage Software Plan is 6561 Irvine Center Drive, Irvine, California
92618.
129. Bayhealth Medical Center Employee Health and Dental Insurance Plan
(the “Bayhealth Plan”). Plaintiffs are informed and believe that Defendant Bayhealth
Plan is an employer-sponsored welfare plan capable of suing and being sued pursuant
to section 502(d) of ERISA, 29 U.S.C. § 1132(d). The principal place of business of
the Bayhealth Plan is 640 South State Street, Dover, Delaware 19901.
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CASE NO. SACV15−736 DOC (DFMx) 222434.2
130. UFCW Local 555-Employers Health Trust (the “UFCW Plan”). Plaintiffs
are informed and believe that Defendant UFCW Plan is an employer-sponsored welfare
plan capable of suing and being sued pursuant to section 502(d) of ERISA, 29 U.S.C.
§ 1132(d). The principal place of business of the UFCW Plan is 7600 S.W. Mohawk
Street, Tualatin, Oregon 97062.
131. TriNet Employee Benefit Insurance Plan (the “TriNet Plan”). Plaintiffs
are informed and believe that Defendant TriNet Plan is an employer-sponsored welfare
plan capable of suing and being sued pursuant to section 502(d) of ERISA, 29 U.S.C.
§ 1132(d). The principal place of business of the TriNet Plan is 1100 San Leandro
Boulevard, Suite 300, San Leandro, California 94577.
132. United States Steel Plan for Active Employee Insurance Benefits (the
“U.S. Steel Plan”). Plaintiffs are informed and believe that Defendant U.S. Steel Plan
is an employer-sponsored welfare plan capable of suing and being sued pursuant to
section 502(d) of ERISA, 29 U.S.C. § 1132(d). The principal place of business of the
U.S. Steel Plan is 600 Grant Street, Room 2643, Pittsburgh, Pennsylvania 15219.
133. Puget Sound Pilots Group Health Plan (the “Puget Sound Pilots Plan”).
Plaintiffs are informed and believe that Defendant Puget Sound Pilots Plan is an
employer-sponsored welfare plan capable of suing and being sued pursuant to section
502(d) of ERISA, 29 U.S.C. § 1132(d). The principal place of business of the Puget
Sound Pilots Plan is First & Stewart Building, 101 Stewart Street, Suite 900, Seattle,
Washington 98101.
134. Ameriflight, LLC Group Life & Health Insurance Plan (the “Ameriflight
Plan”). Plaintiffs are informed and believe that Defendant Ameriflight Plan is an
employer-sponsored welfare plan capable of suing and being sued pursuant to section
502(d) of ERISA, 29 U.S.C. § 1132(d). The principal place of business of the
Ameriflight Plan is 4700 Empire Avenue, Hangar 1, Burbank, California 91505.
135. Morris Bart Employee Benefits Plan (the “Bart Plan”). Plaintiffs are
informed and believe that Defendant Bart Plan is an employer-sponsored welfare plan
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26 THIRD AMENDED COMPLAINT
CASE NO. SACV15−736 DOC (DFMx) 222434.2
capable of suing and being sued pursuant to section 502(d) of ERISA, 29 U.S.C.
§ 1132(d). The principal place of business of the Bart Plan is 909 Poydras Street, Suite
2000, New Orleans, Louisiana 70112.
136. Globecast Health and Welfare Benefits Plan (the “Globecast Plan”).
Plaintiffs are informed and believe that Defendant Globecast Plan is an employer-
sponsored welfare plan capable of suing and being sued pursuant to section 502(d) of
ERISA, 29 U.S.C. § 1132(d). The principal place of business of the Globecast Plan is
10 East 40th Street, 11th Floor, New York, New York 10016.
137. Globys, Inc. Group Health Plan (the “Globys Plan”). Plaintiffs are
informed and believe that Defendant Globys Plan is an employer-sponsored welfare
plan capable of suing and being sued pursuant to section 502(d) of ERISA, 29 U.S.C.
§ 1132(d). The principal place of business of the Globys Plan is 705 5th Avenue South,
Suite 700, Seattle, Washington 98104.
138. Cargill, Incorporated & Participating Affiliates Group Health Plan (the
“Cargill Plan”). Plaintiffs are informed and believe that Defendant Cargill Plan is an
employer-sponsored welfare plan capable of suing and being sued pursuant to section
502(d) of ERISA, 29 U.S.C. § 1132(d). The principal place of business of the Cargill
Plan is 15407 McGinty Road, Suite 15615, Wayzata, Minnesota 55391.
139. ACWA/JPIA Employee Benefits Program (the “ACWA/JPIA Plan”).
Plaintiffs are informed and believe that Defendant ACWA/JPIA Plan is an employer-
sponsored welfare plan capable of suing and being sued pursuant to section 502(d) of
ERISA, 29 U.S.C. § 1132(d). The principal place of business of the ACWA/JPIA Plan
is 2100 Professional Drive, Roseville, California 95661.
140. HDR, Inc. Group Insurance Plan (the “HDR Plan”). Plaintiffs are
informed and believe that Defendant HDR Plan is an employer-sponsored welfare plan
capable of suing and being sued pursuant to section 502(d) of ERISA, 29 U.S.C.
§ 1132(d). The principal place of business of the HDR Plan is 8404 Indian Hills Drive,
Omaha, Nebraska 68114.
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CASE NO. SACV15−736 DOC (DFMx) 222434.2
141. Bricklayers and Allied Craftworkers Local 1 PA/DE Health & Welfare
Fund (the “Bricklayers Plan”). Plaintiffs are informed and believe that Defendant
Bricklayers Plan is an employer-sponsored welfare plan capable of suing and being
sued pursuant to section 502(d) of ERISA, 29 U.S.C. § 1132(d). The principal place of
business of the Bricklayers Plan is 2706 Black Lake Place, Philadelphia, Pennsylvania
19154.
142. Profit Insight Holdings, LLC Group Health Plan (the “Profit Plan”).
Plaintiffs are informed and believe that Defendant Profit Plan is an employer-
sponsored welfare plan capable of suing and being sued pursuant to section 502(d) of
ERISA, 29 U.S.C. § 1132(d). The principal place of business of the Profit Plan is 249
Williamson Road, Suite 200, Mooresville, North Carolina 28117.
143. Delta Kappa Gamma Society International Health Benefit Plan (the
“DKG Plan”). Plaintiffs are informed and believe that Defendant DKG Plan is an
employer-sponsored welfare plan capable of suing and being sued pursuant to section
502(d) of ERISA, 29 U.S.C. § 1132(d). The principal place of business of the DKG
Plan is 416 West 12th Street, Austin, Texas 78701.
144. Dirt Free Flood Services Inc. Health Benefit Plan (the “Dirt Free Plan”).
Plaintiffs are informed and believe that Defendant Dirt Free Plan is an employer-
sponsored welfare plan capable of suing and being sued pursuant to section 502(d) of
ERISA, 29 U.S.C. § 1132(d). The principal place of business of the Dirt Free Plan is
901 E. Mulberry Street, Angleton, Texas 77515.
145. Einstein Noah Restaurant Group, Inc. Employee Benefit Plan (the
“Einstein Bagels Plan”). Plaintiffs are informed and believe that Defendant Einstein
Bagels Plan is an employer-sponsored welfare plan capable of suing and being sued
pursuant to section 502(d) of ERISA, 29 U.S.C. § 1132(d). The principal place of
business of the Einstein Bagels Plan is 555 Zang Street, Suite 300, Lakewood,
Colorado 80228.
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CASE NO. SACV15−736 DOC (DFMx) 222434.2
146. Northern California Sheet Metal Workers Health Care Plan (the “Nor.
Cal. SMW Plan”). Plaintiffs are informed and believe that Defendant Nor. Cal. SMW
Plan is an employer-sponsored welfare plan capable of suing and being sued pursuant
to section 502(d) of ERISA, 29 U.S.C. § 1132(d). The principal place of business of
the Nor. Cal. SMW Plan is 2610 Crow Canyon Road, Suite 200, San Ramon, California
94583.
147. Jennings American Legion Hospital Employee Benefit Plan (the
“Jennings Plan”). Plaintiffs are informed and believe that Defendant Jennings Plan is
an employer-sponsored welfare plan capable of suing and being sued pursuant to
section 502(d) of ERISA, 29 U.S.C. § 1132(d). The principal place of business of the
Jennings Plan is 1634 Elton Road, Jennings, Louisiana 70546.
148. The welfare plans listed above are collectively referred to hereafter as the
“Welfare Plan Defendants.”
The Blue Cross Defendants
149. Plaintiffs are informed and believe that the Blue Cross and Blue Shield
System is comprised of “36 independent, community-based and locally operated Blue
Cross and Blue Shield companies,” and the Blue Cross and Blue Shield Association,
which “owns and manages the Blue Cross and Blue Shield trademarks and names in
more than 170 countries around the world.” The Blue Cross and Blue Shield System,
Blue Cross Blue Shield Ass’n, www.bcbs.com/about-us/blue-cross-blue-shield-system
(last visited Dec. 18, 2016). According to the Association’s website, its member
companies and their subsidiaries “provid[e] nationwide healthcare coverage . . . for
more than 106 million members in all 50 states, Washington, D.C., and Puerto Rico.”
Id.; see also BCBS Companies and Licensees, Blue Cross Blue Shield Ass’n,
www.bcbs.com/bcbs-companies-and-licensees (last visited Dec. 18, 2016) (providing
links to the websites of sixty-three Association member companies or their
subsidiaries). Plaintiffs are informed and believe that each and every Welfare Plan
Defendant has a contractual relationship with one or more of those sixty-three
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29 THIRD AMENDED COMPLAINT
CASE NO. SACV15−736 DOC (DFMx) 222434.2
Association member companies or their subsidiaries that is relevant to the claims
asserted in this lawsuit. Plaintiffs name as defendants the following companies:
150. Blue Cross and Blue Shield of Alabama (“Alabama Blue”). Plaintiffs are
informed and believe that Alabama Blue is an active, domestic nonprofit corporation
registered to do business in Alabama. Its principal place of business is located at 450
Riverchase Parkway E., Birmingham, Alabama 35244.
151. Premera Blue Cross Blue Shield of Alaska (“Alaska Blue”). Plaintiffs are
informed and believe that Defendant Alaska Blue is registered as a hospital and
medical service corporation in the state of Alaska. Its principal place of business is
located at 2550 Denali Street, Suite 1404, Anchorage, Alaska 99503.
152. Blue Cross of California (“California Blue Cross”). Plaintiffs are
informed and believe that Defendant California Blue Cross is registered in the state of
California as a corporation and operates therein as a health insurer. Defendant
California Blue Cross does business under the trade name Anthem Blue Cross.
Plaintiffs are informed and believe that California Blue Cross also sometimes operates
through one or more subsidiaries, including Anthem Blue Cross Life and Health
Insurance Company. The principal place of business of California Blue Cross is located
at 21555 Oxnard Street, Woodland Hills, California 91367.
153. California Physicians’ Service (“California Blue Shield”). Plaintiffs are
informed and believe that Defendant California Blue Shield is registered to do business
as a nonprofit mutual benefit corporation in the state of California. Defendant
California Blue Shield does business under the trade name Blue Shield of California.
Plaintiffs are informed and believe that California Blue Shield also sometimes operates
through one or more subsidiaries, including Blue Shield of California Life & Health
Insurance Company, which does business under the trade name Blue Shield of
California. The principal place of business of California Blue Shield is located at
50 Beale Street, San Francisco, California 94105.
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30 THIRD AMENDED COMPLAINT
CASE NO. SACV15−736 DOC (DFMx) 222434.2
154. Rocky Mountain Hospital and Medical Service, Inc. (“Colorado Blue”).
Plaintiffs are informed and believe that Defendant Colorado Blue is a nonprofit
corporation, authorized to do business in the state of Colorado. Defendant Colorado
Blue does business under the trade names Anthem Blue Cross and Blue Shield and
Blue Cross and Blue Shield of Colorado. Its principal place of business is located at
555 Middle Creek Parkway, Colorado Springs, Colorado 80921.
155. Anthem Health Plans, Inc. (“Connecticut Blue”). Plaintiffs are informed
and believe that Defendant Connecticut Blue is a nonprofit corporation, authorized to
do business in the state of Connecticut. Defendant Connecticut Blue does business
under the trade name Anthem Blue Cross and Blue Shield. Its principal place of
business is located at 370 Bassett Road, North Haven, Connecticut 06473.
156. Highmark BCBSD, Inc. (“Delaware Blue”). Plaintiffs are informed and
believe that Defendant Delaware Blue is an active nonprofit corporation registered to
do business in in the state of Delaware. Defendant Delaware Blue is an independent
licensee of the Blue Cross and Blue Shield Association and a member of the Highmark
Health Plans enterprise, operating under the trade name Highmark Blue Cross Blue
Shield Delaware. Its principal place of business is located at 800 Delaware Avenue,
Suite 900, Wilmington, Delaware 19801.
157. Group Hospitalization and Medical Services, Inc. (“CareFirst District of
Columbia Blue”). Plaintiffs are informed and believe that Defendant CareFirst District
of Columbia Blue is a not-for-profit corporation authorized to do business in the state
of Virginia and the District of Columbia. Defendant CareFirst District of Columbia
Blue does business under the trade name CareFirst BlueCross BlueShield. Its principal
place of business is located at 840 First Street N.E., Washington D.C. 20065.
158. Blue Cross and Blue Shield of Florida, Inc. (“Florida Blue”). Plaintiffs are
informed and believe that Defendant Florida Blue is an active Florida nonprofit
corporation. Defendant Florida Blue formally does business under the trade name
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CASE NO. SACV15−736 DOC (DFMx) 222434.2
Florida Blue. Its principal place of business is located at 4800 Deerwood Campus
Parkway, Jacksonville, Florida 32246.
159. Blue Cross and Blue Shield of Georgia, Inc. (“Georgia Blue”). Plaintiffs
are informed and believe that Defendant Georgia Blue is registered to do business in
Georgia as an active, health insurance corporation. Defendant Georgia Blue does
business under the trade name Blue Cross and Blue Shield of Georgia. Its principal
place of business is located at 1201 Peachtree Street N.E., Atlanta, Georgia 30361.
160. Blue Cross of Idaho Health Service, Inc. (“Idaho Blue”). Plaintiffs are
informed and believe that Defendant Idaho Blue is a corporation formed under the laws
of Idaho. Defendant Idaho Blue operates under the trade name Blue Cross of Idaho. Its
principal place of business is located at 3000 East Pine Avenue, Meridian, Idaho
83642.
161. Health Care Service Corporation, a Mutual Legal Reserve Company
(“Illinois Blue”). Plaintiffs are informed and believe that Defendant Illinois Blue is
active and licensed to do business in the state of Illinois and does business there under
the trade names BlueCross BlueShield of Illinois. Its corporate office is located at
300 East Randolph Street, Chicago, Illinois 60601.
162. Anthem Insurance Companies, Inc. (“Indiana Blue”). Plaintiffs are
informed and believe that Defendant Indiana Blue is registered to do business in
Indiana as a domestic insurance corporation. Indiana Blue does business under the
trade name Anthem Blue Cross and Blue Shield. Its principal place of business is
located at 120 Monument Circle, Indianapolis, Indiana 46204.
163. Wellmark, Inc. (“Iowa Blue”). Plaintiffs are informed and believe that
Defendant Iowa Blue is incorporated in Iowa as an active insurance company.
Defendant Iowa Blue does business under the trade name Wellmark Blue Cross and
Blue Shield of Iowa. Its principal place of business is located at 1331 Grant Avenue,
Des Moines, Iowa 50309.
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164. Blue Cross and Blue Shield of Kansas, Inc. (“Kansas Blue”). Plaintiffs are
informed and believe that Defendant Kansas Blue is registered to do business as an
insurance company in the state of Kansas. Defendant Kansas Blue does business under
the trade name Blue Cross and Blue Shield of Kansas. Its principal place of business
is located at 1133 S.W. Topeka Boulevard, Topeka, Kansas 66629.
165. Anthem Health Plans of Kentucky, Inc. (“Kentucky Blue”). Plaintiffs are
informed and believe that Defendant Kentucky Blue is a corporation, authorized to do
business in the state of Kentucky. Defendant Kentucky Blue does business under the
trade name Anthem Blue Cross and Blue Shield. Its principal place of business is
located at 13550 Triton Park Boulevard, Louisville, Kentucky 40223.
166. Louisiana Health Service & Indemnity Company (“Louisiana Blue”).
Plaintiffs are informed and believe that Defendant Louisiana Blue is licensed to do
business in Louisiana as an insurance entity. Defendant Louisiana Blue does business
under the trade name Blue Cross and Blue Shield of Louisiana. Plaintiffs are informed
and believe that Louisiana Blue also does business through one or more subsidiaries,
including HMO Louisiana, Inc., which does business under the trade name Blue Cross
and Blue Shield of Louisiana. The principal place of business of Louisiana Blue is
located at 5525 Reitz Avenue, Baton Rouge, Louisiana 70809.
167. CareFirst of Maryland, Inc. (“CareFirst Maryland Blue”). Plaintiffs are
informed and believe that Defendant CareFirst Maryland Blue is a non-stock
corporation, organized under the laws of Maryland. Defendant CareFirst Maryland
Blue operates under the same ownership of, and shares the same employees with,
Defendant CareFirst District of Columbia Blue. Defendant CareFirst Maryland Blue
also does business under the trade name CareFirst BlueCross BlueShield. Its principal
place of business is located at Canton Tower, 1501 South Clinton Street, Baltimore,
Maryland 21224.
168. Blue Cross and Blue Shield of Massachusetts, Inc. and Blue Cross and
Blue Shield of Massachusetts HMO Blue, Inc. (“Massachusetts Blue”). Plaintiffs are
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informed and believe that Defendant Massachusetts Blue is incorporated in
Massachusetts as a nonprofit health maintenance organization. Its principal place of
business is located at Landmark Center, 401 Park Drive, Boston, Massachusetts 02215.
169. Blue Cross Blue Shield of Michigan Mutual Insurance Company
(“Michigan Blue”). Plaintiffs are informed and believe that Defendant Michigan Blue
is registered to do business as a nonprofit mutual company in the state of Michigan.
Defendant Michigan Blue does business under the trade name Blue Cross Blue Shield
of Michigan. Its principal place of business is located at 600 Lafayette E., Mail Code
1929, Detroit, Michigan 48826.
170. BCBSM, Inc. (“Minnesota Blue”). Plaintiffs are informed and believe that
Defendant Minnesota Blue is a nonprofit corporation, authorized to do business in the
state of Minnesota. Defendant Minnesota Blue does business under the trade name
Blue Cross Blue Shield of Minnesota. Its principal place of business is located at
3535 Blue Cross Road, Eagan, Minnesota 55122.
171. Blue Cross and Blue Shield of Kansas City (“Kansas City Blue”).
Plaintiffs are informed and believe that Defendant Kansas City Blue is a Missouri
insurance company. Defendant Kansas City Blue does business under its legal name
and under the trade name Blue KC. Its principal place of business is located at
2301 Main Street, Kansas City, Missouri 64108.
172. Health Care Service Corporation, a Mutual Legal Reserve Company
(“Montana Blue”). Plaintiffs are informed and believe that Defendant Montana Blue,
a Mutual Legal Reserve Company, is active and licensed to do business in the states of
Montana and does business there under the trade name BlueCross BlueShield of
Montana. Its corporate office is located at 300 East Randolph Street, Chicago, Illinois
60601; its Montana state headquarters is located at 560 North Park Avenue, Helena,
Montana 59604.
173. Blue Cross and Blue Shield of Nebraska (“Nebraska Blue”). Plaintiffs are
informed and believe that Defendant Nebraska Blue is a mutual benefit corporation,
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authorasized to do business in the state of Nebraska. Its principal place of business is
located at 1919 Aksarben Drive, Omaha, Nebraska 68106.
174. Horizon Healthcare Services, Inc. (“New Jersey Blue”). Plaintiffs are
informed and believe that Defendant New Jersey Blue is registered to do business in
New Jersey as an active, nonprofit corporation. Defendant New Jersey Blue does
business under the trade name Horizon Blue Cross Blue Shield of New Jersey. Its
principal place of business is located at 3 Penn Plaza E., Newark, New Jersey 07105.
175. Health Care Service Corporation, a Mutual Legal Reserve Company
(“New Mexico Blue”). Plaintiffs are informed and believe that Defendant New Mexico
Blue is active and licensed to do business in the state of New Mexico and does business
there under the trade name BlueCross BlueShield of New Mexico. Its corporate office
is located at 300 East Randolph Street, Chicago, Illinois 60601; its New Mexico state
headquarters is located at 5701 Balloon Fiesta Parkway N.E., Albuquerque, New
Mexico 87113.
176. Empire HealthChoice Assurance, Inc. (“New York Empire Blue”).
Plaintiffs are informed and believe that Defendant New York Empire Blue is a
nonprofit corporation in the state of New York. Defendant New York Empire Blue does
business as a health insurer under the trade name Empire BlueCross BlueShield.
Plaintiffs are informed and believe that New York Empire Blue also sometimes
operates as a claims administrator through one or more subsidiaries, including and/or
under the trade name Anthem Blue Cross Blue Shield (“New York Anthem Blue”). The
principal place business of New York Empire Blue is located at 1 Liberty Plaza, 165
Broadway, New York, New York 10006; and the principle place of business of New
York Anthem Blue is 85 Crystal Run Road, Middletown, New York 10940.
177. Excellus Health Plan, Inc. (“New York Excellus Blue”). Plaintiffs are
informed and believe that Defendant New York Excellus Blue is registered to do
business as a nonprofit indemnity health insurance company in the state of New York.
Defendant New York Excellus Blue does business under the trade name Excellus
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BlueCross BlueShield. Its principal place of business is located at 165 Court Street,
Rochester, New York 14647.
178. Blue Cross and Blue Shield of North Carolina (“North Carolina Blue”).
Plaintiffs are informed and believe that Defendant North Carolina Blue is a North
Carolina hospital and medical service corporation. Its principal place of business 5901
Chapel Hill Road, Durham, North Carolina 27707.
179. Community Insurance Company (“Ohio Blue”). Plaintiffs are informed
and believe that Defendant Ohio Blue is a health insurer, authorized to do business in
the state of Ohio. Defendant Ohio Blue does business under the trade name Anthem
Blue Cross and Blue Shield. Its principal place of business is located at 4361 Irwin
Simpson Road, Mason, Ohio 45040.
180. Health Care Service Corporation, a Mutual Legal Reserve Company
(“Oklahoma Blue”). Plaintiffs are informed and believe that Defendant Oklahoma Blue
is active and licensed to do business in the state of Oklahoma, and does business there
under the trade name BlueCross BlueShield of Oklahoma. Plaintiffs are informed and
believe that Oklahoma Blue sometimes operates through one or more subsidiaries
including BlueLincs HMO. The corporate office of Oklahoma Blue is located at 300
East Randolph Street, Chicago, Illinois 60601; its Oklahoma state headquarters is
located at 1400 S. Boston Avenue, Tulsa, Oklahoma 74119.
181. Regence BlueCross BlueShield of Oregon (“Oregon Blue”). Plaintiffs are
informed and believe that Defendant Oregon Blue is registered in the state of Oregon
as a nonprofit corporation. Its principal place of business is located at 200 S.W. Market
Street, Portland, Oregon 97201.
182. Highmark Blue Shield (“Central Pennsylvania Blue”). Plaintiffs are
informed and believe that Defendant Central Pennsylvania Blue is registered as a
nonprofit corporation in the state of Pennsylvania. Defendant Central Pennsylvania
Blue is an independent licensee of the Blue Cross and Blue Shield Association.
Defendant Central Pennsylvania Blue does business as a full-service health plan in the
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21 counties of central Pennsylvania and, as a partner in joint operating agreements with
Defendant Northeastern Pennsylvania Blue, provides health insurance services in
northeastern Pennsylvania. Its principal place of business is located at 1800 Center
Street, Camp Hill, Pennsylvania 17089.
183. Highmark, Inc. (“Highmark”). Plaintiffs are informed and believe that
Defendant Highmark is an active, nonprofit corporation organized under the laws of
Pennsylvania. Defendant Highmark is an independent licensee of the Blue Cross and
Blue Shield Association and the operator of Highmark Health Plans, a corporate group
of health insurers that includes Defendant Central Pennsylvania Blue, Defendant
Western Pennsylvania Blue, Defendant Northeastern Pennsylvania Blue, and
Defendant Delaware Blue. Plaintiffs are informed and believe that, through its
subsidiaries and businesses in Highmark Health Plans, Defendant Highmark provides
BCBS-branded health insurance plans in Pennsylvania, West Virginia, Delaware, and
Ohio. Defendant Highmark’s principal place of business is located at Fifth Avenue
Place, 120 Fifth Avenue, Pittsburgh, Pennsylvania 15222.
184. Highmark Blue Cross Blue Shield (“Western Pennsylvania Blue”).
Plaintiffs are informed and believe that Defendant Western Pennsylvania Blue is
registered as a nonprofit corporation in the state of Pennsylvania. Western
Pennsylvania Blue is an independent licensee of the Blue Cross and Blue Shield
Association and a member of the Highmark Health Plans enterprise, doing business in
the 29 counties of western Pennsylvania. Its principal place of business is located at
1800 Center Street, Camp Hill, Pennsylvania 17089.
185. Blue Cross of Northeastern Pennsylvania, formerly Hospital Service
Association of Northeastern Pennsylvania (“Northeastern Pennsylvania Blue”).
Plaintiffs are informed and believe that Defendant Northeastern Pennsylvania Blue is
registered to do business in Pennsylvania as an active, nonprofit corporation.
Defendant Northeastern Pennsylvania Blue is an independent licensee of the Blue
Cross and Blue Shield Association and a member of the Highmark Health Plans
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enterprise, operating in 12 counties in northeastern and central Pennsylvania. Its
principal place of business is located at 19 North Main Street, Wilkes-Barre,
Pennsylvania 18711.
186. Blue Cross and Blue Shield of South Carolina (“South Carolina Blue”).
Plaintiffs are informed and believe that Defendant South Carolina Blue is registered to
do business as a mutual insurance company in the state of South Carolina. Its
headquarters is located at 2501 Faraway Drive, Columbia, South Carolina 29223.
187. Blue Cross Blue Shield of Tennessee, Inc. (“Tennessee Blue”). Plaintiffs
are informed and believe that Defendant Tennessee Blue is a nonprofit corporation,
authorized to do business in the state of Tennessee. Its principal place of business is
located at 1 Cameron Hill Circle, Chattanooga, Tennessee 37402.
188. Health Care Service Corporation, a Mutual Legal Reserve Company
(“Texas Blue”). Plaintiffs are informed and believe that Defendant Texas Blue is active
and licensed to do business in the state of Texas and does business there under the trade
name BlueCross BlueShield of Texas. Its corporate office is located at 300 East
Randolph Street, Chicago, Illinois 60601; its Texas state headquarters is located at1001
East Lookout Drive, Richardson, Texas 75082.
189. Anthem Health Plans of Virginia, Inc. (“Virginia Anthem Blue”).
Plaintiffs are informed and believe that Defendant Virginia Anthem Blue is a health
insurer, authorized to do business in the state of Virginia. Defendant Virginia Anthem
Blue does business under the trade name Anthem Blue Cross and Blue Shield. Its
principal place of business is located at 2015 Staples Mill Road, Richmond, Virginia
23230.
190. Premera Blue Cross (“Washington Premera Blue”). Plaintiffs are
informed and believe that Defendant Premera Blue Cross is a nonprofit corporation
organized under the laws of Washington. Its principal place of business is located at
7001 220th Street S.W., Building 1, Mountlake Terrace, Washington 98043.
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191. Regence BlueShield (“Washington Regence Blue”). Plaintiffs are
informed and believe that Defendant Washington Regence Blue is an active nonprofit
corporation formed under the laws of and authorized to do business in the state of
Washington. Its principal place of business is located at 1800 Ninth Avenue, Seattle,
Washington 98101.
192. The Anthem Companies, Inc. (“Wisconsin Blue”). Plaintiffs are informed
and believe that Defendant Wisconsin Blue is a health insurer, authorized to do
business in the state of Wisconsin. Defendant Wisconsin Blue does business under the
trade name Blue Cross and Blue Shield of Wisconsin. Its principal place of business is
located at N17 W24340 Riverwood Drive, Waukesha, Wisconsin 53188.
193. The defendants listed above are collectively referred to hereafter as the
“Blue Cross Defendants.”
RELEVANT FACTS
A. Plaintiffs Provide Gold-Standard Treatment Services.
194. Sovereign is a leading provider of comprehensive addiction and mental
health treatment programs to individuals in California and other states.
195. It is widely accepted that the services rendered by Sovereign and similar
providers are extremely important. For example, according to the National Institute on
Drug Abuse, every $1 spent on substance abuse treatment saves $4.87 in health care
costs and $7.00 in crime costs. See Nat’l Inst. on Drug Abuse, Principles of Drug
Addiction Treatment: A Research-Based Guide (3d ed. 1999).
196. Sovereign’s approach to addiction and other mental health treatment is
consistent with best practices in the industry. Its proven track record has also earned
Sovereign accolades from trade and government groups. Dual Diagnosis, for example,
has received the Gold Seal of Approval from the Joint Commission, an independent
not-for-profit organization that is the nation’s oldest and largest standards-setting and
accrediting body in health care. And the California Board of Behavioral Health
Sciences, the California Association for Alcohol/Drug Educators, and the National
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Association for Alcoholism and Drug Abuse Counsels have approved Sovereign
entities to provide continuing education to licensed professionals.
197. Medlink, a fully furnished and licensed adult residential facility (“ARF”),
contracts for Sovereign to provide extensive non-medical and administrative services
to Medlink and its patients. By partnering with Sovereign, Medlink is able to deliver
high-quality services to individuals whose illnesses necessitate admission into an ARF.
B. Many Patients Pay Plaintiffs Through ERISA-Governed Welfare Plans.
198. Plaintiffs, who are for-profit enterprises, allow prospective patients to pay
for their services out-of-pocket or with health insurance. Unfortunately, many
individuals in need of treatment cannot afford to pay for Plaintiffs’ services up front.
Plaintiffs are only able to treat those individuals who have health insurance covering
some or all of their services.
199. This litigation involves Former Patients who paid for Plaintiffs’ services
through health insurance provided by the Welfare Plan Defendants. Such plans and
their benefits are governed by ERISA.
200. ERISA is a landmark federal law enacted to promote the interests of
employees and their beneficiaries in employee benefit plans and to protect
contractually defined benefits owed to those employees and beneficiaries.
201. To that end, ERISA imposes extensive procedural requirements on
employee benefit plans. For example, it mandates that a written instrument be
established and maintained, 29 U.S.C. § 1102; that a straightforward summary of
material plan terms be furnished to participants and beneficiaries, id. § 1022; that a
grievance and appeals process be established, id. § 1133; and that fiduciary duties be
satisfied by those who manage the plan, id. § 1104.
202. ERISA also gives plan participants and their beneficiaries the right to sue
for benefits, 29 U.S.C. § 1132(a)(1)(B), to enforce or clarify their rights under the plan,
ibid., to enjoin violations of ERISA or the terms of the plan, id. § 1132(a)(3)(A), and
“to obtain other appropriate equitable relief . . . ,” id. § 1132(a)(3)(B).
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203. Each of the plans offered by Welfare Plan Defendants covered the mental
health and/or substance abuse treatment services provided by Plaintiffs to the Former
Patients. As explained below, before agreeing to provide treatment, Plaintiffs’ general
practice is to contact a patient’s insurer to confirm that the treatment they offer is
covered, and that the assigned benefits claims brought here arise from services
provided to Former Patients for which Plaintiffs received such a coverage
confirmation.
C. The Blue Cross Defendants Insured and/or Administered the Former
Patients’ ERISA-Governed Welfare Plans.
204. ERISA distinguishes between self-insured and fully insured employee
benefit plans. In self-insured plans, the employer pays directly for the covered health
care services provided to participants and beneficiaries. In fully insured plans, the
employer buys group health insurance coverage and the insurance company pays for
covered health care services.
205. The Welfare Plan Defendants include both self-insured and fully insured
employee benefit plans. Plaintiffs are informed and believe that:
a. Each fully insured Welfare Plan Defendant bought group health
insurance coverage from a Blue Cross Defendant and retained a Blue Cross
Defendant as a third-party administrator (“TPA”); and
b. Each self-insured Welfare Plan Defendant retained a Blue Cross
Defendant as a TPA.
206. Plaintiffs are informed and believe that, either as group insurers or group
TPAs, the Blue Cross Defendants provided extensive services to the Welfare Plan
Defendants pursuant to administrative service agreements (“ASAs”) between the
parties. These services included: determining to whom and in what amounts benefits
are paid, drafting and providing plan members with ERISA plan documents,
interpreting plan documents, providing notices to employees and their beneficiaries,
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determining usual and customary rates, and/or hearing and deciding administrative
appeals.
207. Plaintiffs are informed and believe that as insurers or TPAs, the Blue
Cross Defendants “effectively controlled the decision whether to honor or deny a
claim” on behalf of the Welfare Plan Defendants. Cyr v. Reliance Life Ins. Co., 642 F.3d
1202, 1204 (9th Cir. 2011). Indeed, Plaintiffs are informed and believe that the Welfare
Plan Defendants had little if any involvement in claims administration or pricing and
deferred entirely to the Blue Cross Defendants.
208. Because the Blue Cross Defendants, as either insurers or TPAs, exercised
discretion in connection with the granting or denial of benefits and otherwise with
respect to plan administration, they are fiduciaries under ERISA.
209. Plaintiffs are informed and believe that the Blue Cross Defendants that
served as TPAs, were, because of terms of the ASAs or otherwise, motivated by
financial incentives to keep benefit costs to the self-insured Welfare Plan Defendants
low.
210. The Blue Cross Defendants who insured the Welfare Plan Defendants had
independent financial incentives to keep benefit costs low because they paid for
covered health care services themselves.
D. Plaintiffs Investigate Prospective Patients’ Health Insurance Coverage.
211. Before agreeing to treat any patient, Plaintiffs take steps to ensure that
they will be compensated for their services. When a prospective patient seeks to pay
with his or her health insurance, Plaintiffs investigate whether and to what extent the
patient’s insurance policy covers their various levels of service.
212. As explained above, this litigation involves Former Patients who paid for
Plaintiffs’ services through health insurance coverage provided by the Welfare Plan
Defendants—insured and/or administered by one or more Blue Cross Defendant. When
each Former Patient first sought treatment, as a matter of intended general practice
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described below, Plaintiffs or their agents verified that he or she was insured and
ascertained the scope of his or her coverage through the following procedures.
213. Plaintiffs or its agents first secured the Former Patient’s consent to contact
his or her health insurance company, along with the identifying information necessary
for Plaintiffs to interact with the insurer. Plaintiffs or their agents also asked for the
dedicated phone number of healthcare providers associated with the Former Patient’s
insurance policy (“Provider Hotline”). Plaintiffs are informed and believe that each
Former Patient authorized Plaintiffs to contact the Provider Hotline of a Blue Cross
Defendant. Plaintiffs or their agents generally, but not always, recorded this
information in the top box of a comprehensive document entitled “Insurance
Verification Form.”
214. Plaintiffs or their agents called the Provider Hotline listed on the
Insurance Verification Form on each Former Patient’s behalf. When it reached a Blue
Cross Defendant, Plaintiffs or their agents relayed the Former Patient’s identifying
information and requested details about his or her coverage. Plaintiffs or their agents
generally, but not always, recorded the information learned from the Blue Cross
Defendant on the bottom of the Insurance Verification Form.
215. To attempt to complete Plaintiffs’ Insurance Verification Form, Plaintiffs
or their agents generally, but not always, inquired exhaustively into the characteristics
of the Former Patient’s health insurance coverage, including with respect to:
a. The general characteristics of the health insurance policy (including
fields for effective date and renewal date, the type of plan, and whether it covers
preexisting conditions, among other things);
b. The existence and scope of any substance abuse or mental health
coverage (including fields regarding deductible for in-network and out-of-
network services and maximum out-of-pocket payments for in-network and out-
of-network services, among other things);
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c. Any precertification requirements (including fields indicating
whether precertification required for inpatient treatment, residential treatment,
partial hospitalization, intensive outpatient treatment, and/or outpatient
treatment by in-network and out-of-network providers); and
d. Copayments for each type of treatment and any limits on the length
of treatment.
216. Plaintiffs or their agents generally, but not always, also investigated the
logistics of securing authorization and payment for Plaintiffs’ services, including:
a. How to comply with precertification requirements (including fields
for pre-certification company and telephone number);
b. The name of the insurance company and the entity to which benefit
claims should be submitted (including fields for insurance company and claims
address); and
c. Whether the Former Patient’s health insurance benefits were
assignable. The answer to this question was supposed to be recorded by circling
“Yes” or “No” (or “Y” or “N”) next to the word “assignable” on the Insurance
Verification Form.
217. After the insurance verification process, Plaintiffs then contacted each
Former Patient to discuss his or her insurance policy and to make appropriate
arrangements for treatment.
E. Each Former Patient Had “Preferred Provider Organization” Coverage for
Substance Abuse and Mental Health Treatment Services.
218. Plaintiffs only wish to provide services that prospective patients can
afford. As such, as a matter of course Plaintiffs investigate whether the treatment
needed by a patient (including the Former Patients) was covered by insurance.
219. When Plaintiffs or their agents called the Blue Cross Defendants’ Provider
Hotlines, they learned that each Former Patient’s health insurance policy had at least
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the following key features: (1) coverage for substance abuse/mental health treatment
offered by Plaintiffs, and (2) preferred provider organization (“PPO”) coverage.
220. A PPO plan covers medical expenses incurred when the insured visits
either an “in-network” provider (i.e., a provider who has a contractual relationship with
the insurance company) or an “out-of-network” provider (i.e., one who does not have
a contractual relationship with the insurance company).
a. PPO coverage tends to be significantly more expensive than health
maintenance organization (“HMO”) coverage because it gives insureds the
option to visit the providers of their choice, who are typically entitled to
reimbursement at the “usual and customary rate” for their services and not a
lower negotiated rate. Many insureds are nevertheless willing to pay a premium
for PPO coverage to, inter alia, gain access to a bigger and better pool of
providers.
b. No law required the Welfare Plan Defendants to offer PPO
coverage instead of HMO coverage. Each Welfare Plan Defendant chose to offer
the more robust and expensive insurance to their employees, and each Former
Patient or subscriber enrolled in and paid for that premium level of coverage.
c. Plaintiffs are out-of-network with respect to all Blue Cross
Defendants. In other words, Plaintiffs are not contracted with any Blue Cross
Defendant to provide services to their insureds at a discounted rate.
221. In short, Plaintiffs and their agents learned from the Blue Cross
Defendants that each Former Patient had PPO coverage for substance abuse and mental
health treatments and services, and that the Blue Cross Defendants were the relevant
insurance companies, administrators, and contacts for those plans.
F. Plaintiffs Obtain Valid Benefit Assignments from Each Former Patient.
222. Plaintiffs (or their agents, on Plaintiffs’ behalf) obtained and obtain a valid
assignment of benefits (“Assignment”) from all patients before treating them.
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223. The Assignments give Plaintiffs the right to be paid directly for any
services rendered to patients, and also entitle Plaintiffs to assert patients’ legal rights to
recover benefits. These legal rights include the right to file claims and appeals, to
request and obtain information and documents relating to the plan, and to bring suit for
violations of ERISA.
224. Plaintiffs or their agents obtained an Assignment from each Former
Patient. For some Former Patients, the Assignment was in or substantially similar to
the document identified as “Form A” in the Blue Cross Defendants’ Omnibus Motion
to Dismiss (ECF No. 637-3) (“Omnibus Motion”). A copy of the “Form A”
Assignment is attached as Exhibit A. However, for at least one Former Patient
associated with each and every Blue Cross Defendant (and in most instances, for
multiple Former Patients associated with a Blue Cross Defendant) the form of the
Assignment was in or substantially similar to the document identified as “Form B” in
the Omnibus Motion. A copy of the “Form B” Assignment is attached as Exhibit B.
225. The Assignments entitle Plaintiffs to collect payment for services
provided to the Former Patients directly from the Blue Cross Defendants.
226. The Assignments also confer legal standing on Plaintiffs to assert various
legal claims against the Welfare Plan Defendants and the Blue Cross Defendants under
ERISA, including the claims in this Complaint. Assignees are “beneficiaries” under
ERISA with standing to assert the claims of their assignors. See Misic v. Bldg. Servs.
Emps. Health & Welfare Trust, 789 F.2d 1374, 1379 (9th Cir. 1986). And any
beneficiary—including an assignee—who makes a claim is a “claimant” under federal
law. 29 C.F.R. § 2560.503-1(a) (“[T]his section sets forth minimum requirements for
employee benefit plan procedures pertaining to claims for benefits by participants and
beneficiaries (hereinafter referred to as claimants).”).
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G. After Providing Covered Services, Plaintiffs Submitted Claims for Benefits
to the Blue Cross Defendants Following Blue Cross Procedures.
227. Plaintiffs provided medically necessary services to the Former Patients
that were covered by their plans.
228. Plaintiffs then sought payment by submitting the appropriate documents
to the appropriate Blue Cross Defendants in accordance with the Association’s
“BlueCard Program” described below. These claims for payment notified the Blue
Cross Defendants that Plaintiffs had obtained valid Assignments from the Former
Patients and asserted Plaintiffs’ right to receive any benefits owed to the Former
Patients under the terms of their health plans.
229. The BlueCard Program. Plaintiffs are informed and believe that the
BlueCard Program is “a single electronic network for claims processing and
reimbursement” for all Blue Cross Companies. See BlueCard Program, Blue Shield of
California, www.blueshieldca.com/provider/guidelines-resources/patient-care/blueca
rd-program/home.sp (last visited Dec. 23, 2016).
230. All Blue Cross Defendants are BlueCard Program participants.
231. The BlueCard Program requires health care providers to submit claims for
benefits to the Blue Cross entity that controls the territory in which the provider is
located (the “Host Entity”). See generally id. (“When an out-of-area Blue Plan member
seeks medical care from your office, use the information and tools in this section to
submit those claims to Blue Shield of California.”).
232. Plaintiffs are informed and believe that the insurance cards that the Blue
Cross Defendants issued to the Former Patients instructed health providers to
communicate with and submit claims directly to the Host Entity for their location.
Plaintiffs are informed and believe that the Blue Cross Defendant on the Provider
Hotline likewise instructed Plaintiffs or their agents to submit claims to the Host Entity
for the territory in which Plaintiffs are located. The Host Entity was listed on the
Insurance Verification Form.
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233. Plaintiffs complied with the BlueCard Program by submitting claims for
payment directly to the Host Entity for the territory in which Plaintiffs are located. For
many of the Former Patients, for example, the Host Entity would be California Blue
Cross.
234. Plaintiffs are informed and believe that the Host Entity processes claims
on behalf of the distant or out-of-state Blue Cross Company (the “Home Entity”). The
Host Entity sends the claim to the Home Entity, which authorizes the Host Entity to
finalize and pay the claim. Id. The Host Entity then remits payment. Id.; see also
Horizon Blue FAQs, Horizon Blue Cross Blue Shield of New Jersey,
www.horizonblue.com/providers/products-programs/bluecard-r-program/bluecard-
claims (last visited Dec. 23, 2016) (“Once we receive your claims, we will
electronically route them to the out-of-state Blue Cross Blue Shield [Entity] that will
process the claim according to each member’s contract. They will transmit the claim
information to us . . . .”). If the Host Entity and the Home Entity are one and the same,
Plaintiffs are informed and believe that such Blue Cross Company alone handles claim
processing.
235. Uniform Billing (“UB”) Forms. Plaintiffs or their agent timely submitted
claims for payment to the correct Host Entity using industry standard UB-04 forms.
236. UB forms are promulgated by the National Uniform Billing Committee
(“NUBC”), an organization formed in 1975 “to develop and maintain a single billing
form and standard data to be used nationwide by institutional, private and public
providers and payers for handling health care claims.” About Us, NUBC,
www.nubc.org/aboutus/index.dhtml (last visited Dec. 23, 2016) (“About NUBC”).
Plaintiffs are informed and believe that the Association is a member of NUBC. Member
Organizations, NUBC, www.nubc.org/aboutus/memberorganizations.dhtml (last
visited Dec. 23, 2016).
237. The NUBC approved the UB-04 in February of 2005. Department of
Health & Human Services, “CMS Manual System: Pub 100-04 Medicare Claims
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Processing, Transmittal 1104” (Nov. 3, 2006) (“Transmittal 1104”), at 3. The UB-04
form is now the “‘de facto’ institutional claim standard.” About NUBC; see also
Transmittal 1104 at 3 (“The Form UB-04 (CMS-1450) answers the needs of many
health insurers. It is the basic form prescribed by CMS for the Medicare
program . . . .”).
238. The UB-04 form includes information sufficient to allow insurance
companies to identify, process, and pay claims. For example, it contains fields for the
service provided, the appropriate code for that service, and the charge for the service
that the provider believes is usual and customary. The UB-04 form also includes a field
(“ASG BEN” in field 53) in which the provider indicates whether it has received an
assignment of health care benefits from the patient.
239. Each UB-04 form submitted in connection with services that Plaintiffs
provided to a Former Patient indicated that Plaintiffs had received an assignment of
health care benefits from the Former Patient.
H. Despite Extensive Dealings with Plaintiffs, the Blue Cross Defendants Did
Not Notify Plaintiffs of the Terms of Any Valid Anti-Assignment Provision
That They Intended to Enforce.
240. After the verification of benefits, Defendants (or their agents) repeatedly
continued to interact with Plaintiffs (or their agents) with respect to the Former Patients
and claims for whom Plaintiffs received assignments. In addition to verification of
services, such interaction, which was over a long period of time, included receiving
and processing UB-04 claim forms for payment for the services, communicating with
Plaintiffs (or their agents) about the services and claims, and requesting additional
documentation for the claims.
241. During this continued interaction neither the Defendants nor their agents
notified Plaintiffs or their agents of the specific terms of any alleged anti-assignment
provision in any plan document. Nor did they refuse to deal directly with Plaintiffs or
their agents on the grounds of any such provision. Indeed, as pled in additional detail
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below, Defendants (or their agents) regularly informed Plaintiffs’ agents through
express words in many cases, but at a minimum impliedly through their actions, that
the claims of Former Patients at issue were freely assignable.
242. With respect to the Blue Cross Defendants, the behavior alleged herein
constitutes a pattern and practice that caused Plaintiffs to suffer direct and independent
injury:
a. The Blue Cross Defendants (or their agents) should have but failed
to explain to Plaintiffs (or their agents) during the verification of benefits
process, or at a minimum early in the Blue Cross Defendants’ (or their agents’)
long and extensive course of dealing with Plaintiffs (or their agents) thereafter,
that the Blue Cross Defendants would not pay Plaintiffs directly and why.
b. Whether they were declining to make payments directly to
Plaintiffs because more documentation of a valid assignment was required,
because (as Plaintiffs believe and allege) they were engaging in a wrongful
pattern and practice of declining to honor direct payment rights even though
many of the relevant plan documents permit assignments, or because (under their
interpretation of a particular plan) the Former Patients’ benefits were not
assignable, the Blue Cross Defendants should have promptly notified Plaintiffs
in writing.
c. Instead, the Blue Cross Defendants dealt directly with Plaintiffs for
other purposes, but said nothing to contradict the information Plaintiffs
reasonably thought they had verified once during the verification of benefits
process and again upon submitting UB-04s indicating that Plaintiffs had been
assigned the Former Patient’s rights.
d. By failing to clarify in writing to Plaintiffs (or even their Former
Patients) during the verification of benefits process, or at a minimum promptly
upon submission of a UB-04, that the Blue Cross Defendants would refuse to
pay Plaintiffs directly and why, and by instead issuing payments directly to
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Former Patients in violation of their instructions and of the right to direct
payment that Plaintiffs obtained (or at least legitimately believed they obtained),
the Blue Cross Defendants engaged in an improper and unfair business practice.
e. The Blue Cross Defendants’ improper and unfair business practice
caused Plaintiffs—who reasonably believed that they would be paid directly and
relied on the Blue Cross Defendants express or implied representations to the
contrary—to suffer independent and direct harm in at least the following ways:
1. To the extent the Blue Cross Defendants now say they would
have honored these assignments had more documentation been provided,
their behavior deprived Plaintiffs of the opportunity to submit such
documentation and obtain direct payment;
2. To the extent the Blue Cross Defendants now say their
interpretation of relevant plan language is that it prohibits assignments,
Plaintiffs were deprived of the ability to make alternate payment
arrangements with their Former Patients that would have avoided the need
for costly collection efforts and to write off revenue they expected to
receive when at least some Former Patients failed to submit the payment
checks they received to Plaintiffs, or failed to do so in a timely manner;
and
3. The wrongful behavior of the Blue Cross Defendants set
forth above obfuscated Plaintiffs’ ability to ascertain whether the Blue
Cross Defendants were paying benefits at the appropriate amount versus
wrongfully denying claims in whole or in part which, on information and
belief, happened in at least some instances. This deprived Plaintiffs of a
meaningful opportunity to assist their Former Patients with the
administrative appeal process for benefits denials, and at a minimum
delayed and made unnecessarily difficult the ability to ascertain whether
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initiating that process was appropriate, and Plaintiffs lost money as a
result.
243. Unless the Blue Cross Defendants are enjoined from providing inaccurate
information about their willingness to honor assignments of benefits during the
verification of benefits process, and required promptly to state in writing if they are
unwilling to do so upon receipt of a UB-04 indicating that Plaintiffs have received such
assignments, the Blue Cross Defendants will continue to interfere with the conduct of
Plaintiffs’ business, and Plaintiffs will continue to be directly and irreparably harmed.
I. The Blue Cross Defendants Approved Plaintiffs’ Claims But Arbitrarily
Disregarded Their Assignments.
244. A valid assignment obligates the debtor to pay the assignee, not the
original creditor: “When there is a valid assignment in place, performance under a
contract runs to the assignee. Thus, when a creditor assigns its interest in an existing
debt owed to it, the debtor must generally pay the debt to the assignee, not the original
creditor.” 6A C.J.S. Assignments § 106. Indeed, “after a debtor has received notice of
a valid assignment, or obtained knowledge of it in any manner, a payment to the
assignor or any person other than the assignee is at the debtor’s peril and does not
discharge him or her from liability to the assignee.” Id.
245. Plaintiffs are informed and believe that the Blue Cross Defendants
approved and authorized payment on Plaintiffs’ claims for benefits in connection with
the services provided to the Former Patients, but did not pay Plaintiffs (apparently on
the grounds that Plaintiffs were assignees). In other words, despite Blue Cross
Defendants being informed of and on written notice that Plaintiffs were assignees—
and despite Blue Cross Defendants approving the underlying claim for covered
services—the Blue Cross Defendants mailed checks directly to the Former Patients and
not to Plaintiffs.
246. Plaintiffs are informed and believe that the Blue Cross Defendants’
disregard of Plaintiffs’ Assignments is consistent with acknowledged BlueCard policy
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to disregard the assignments of out-of-network providers like Plaintiffs. As one Blue
Cross Company put it: “payments for services rendered by providers who do not
contract with [Blue Cross] are sent directly to our customers. Thus, out-of-network
providers face the inconvenience of attempting to collect payment from the customer
and the accompanying possibility of incurring bad debts.” See Blue Perspective:
BCBSOK Position on Legislation and Regulatory Issues, Blue Cross Blue Shield
Oklahoma, www.bcbsok.com/grassroots/pdf/blueperspective_aob27-103003.pdf (last
visited Dec. 23, 2016).
247. Indeed, when Plaintiffs sought payment for covered claims the Former
Patients had assigned to it, Blue Cross uniformly refused to pay, or even to
acknowledge, Plaintiffs’ benefit claims. Neither Plaintiffs’ initial UB-04 requests for
payment nor its follow-up letters written by experienced ERISA counsel resulted in
payment or a reasoned denial.
248. The Blue Cross Defendants’ policy of not honoring assignments to out-
of-network providers like Plaintiffs furthers their objective to pressure such providers
to contract with the Blue Cross Defendants and become in-network providers.
a. In-network providers with respect to insurance plans agree to
accept discounted reimbursement rates in exchange for the benefits of network
status, which include increased business, advertisements, and lower co-
payments and deductibles for members.
b. Conversely, out-of-network providers receive less plan business,
but they are entitled to receive payment based on their charges for services
rendered without any discount.
249. Plaintiffs are informed and believe that in recent years, Blue Cross
Defendants contracts have demanded such low reimbursement rates and have become
so onerous and one-sided in favor of Blue Cross Defendants that many providers have
determined that they cannot afford to enter into, maintain, or renew such contracts. As
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a result, a growing number of providers have become out-of-network with the Blue
Cross Defendants.
250. Plaintiffs are informed and believe that the Blue Cross Defendants punish
out-of-network providers by underpaying them for the medically necessary, covered
services they provide to Blue Cross Defendants insured individuals.
251. The Blue Cross Defendants know or should know that misleading
providers about the assignability of claims, and/or failing to honor assignments, results
in underpayment to providers because patients do not always forward their benefits
checks to their providers, and are less likely to contest improper denials of benefits.
252. In this litigation, the Blue Cross Defendants’ policy of misleading
Plaintiffs on the assignability of claims and/or disregarding assignments to out-of-
network providers like Plaintiffs led them to send large sums of money to chemically
dependent individuals. That practice was patently reckless with respect to the health
and safety of the Former Patients, as well as the health and safety of the general public.
It also all but guaranteed that Plaintiffs would receive only a fraction of what it was
owed for their services.
J. In Clear Violation of ERISA, No Defendant Ever Informed Plaintiffs of Its
Basis for Refusing to Honor Plaintiffs’ Assignments.
253. Plaintiffs formally asserted claims for ERISA benefits to ERISA
fiduciaries by submitting UB-04s to the Blue Cross Defendants for services provided
to the Former Patients.
254. Plaintiffs’ UB-04s never received any response from the Blue Cross
Defendants. As Plaintiffs learned only later and at great expense, the Blue Cross
Defendants instead had approved and authorized payment on the claims for Plaintiffs’
services to the Former Patients. The Blue Cross Defendants then issued payment
checks to the Former Patients.
255. When the Blue Cross Defendants refused to pay Plaintiffs’ claims and
instead sent claims payment checks to the Former Patients, they made “adverse benefit
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determinations” against Plaintiffs under ERISA. See 29 C.F.R. § 2560.503-1(m)(4)
(defining “adverse benefit determination” as including “a failure to provide or make
payment” for a claimed benefit).
256. Federal law and regulations set forth extensive procedural requirements
for making adverse benefit determinations in the health insurance context. Generally
speaking, plans must propound denials in writing, set forth the specific reasons for such
a denial, and afford a reasonable opportunity for a full and fair review by the
appropriate named fiduciary of the decision denying the claim. See generally 29 U.S.C.
§ 1133.
257. Among other things, the plan or its representative must explain, “in a
manner calculated to be understood by the claimant (i) the specific reason or reasons
for the adverse determination; (ii) reference to the specific plan provisions on which
the determination is based; (iii) a description of any additional material or information
necessary for the claimant to perfect the claim and an explanation of why such material
or information is necessary; [and] (iv) a description of the plan’s review procedures
and the time limits applicable to such procedures, including a statement of the
claimant’s right to bring a civil action under section 502(a) of the Act following an
adverse benefit determination on review. . . .” 29 C.F.R. § 2560.503-1(g)(i)-(iv). See
also 29 C.F.R. § 2590.715-2719(b).
258. In spite of such detailed regulations, Plaintiffs received no written notice
that such adverse benefit determinations had taken place at all. As a result, Plaintiffs
did not know whether the Blue Cross Defendants had acted on their claims at all, what
decisions they had reached if they had, or why they never received payment from the
Blue Cross Defendants. Only after a costly and protracted investigation were Plaintiffs
able to ascertain what was happening.
259. Defendants obviously failed to comply, in any respect, with the relevant
federal regulations governing the manner and means by which an insurer must make
an adverse benefit determination. As a result, any administrative prerequisites to
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litigation are deemed exhausted and a claimant may commence suit in federal court.
See 29 C.F.R. § 2560.503-1(l) (“In the case of the failure of a plan to establish or follow
claims procedures consistent with the requirements of this section, a claimant shall be
deemed to have exhausted the administrative remedies available under the plan and
shall be entitled to pursue any available remedies . . . .”) and 29 C.F.R. §2590.715-
2719(b)(2)(ii)(F) (deemed exhaustion).
K. At Great Effort And Expense, Plaintiffs Attempt to Collect Plan Documents
And Learn the Scope of Defendants’ Misconduct.
260. When the Blue Cross Defendants uniformly refused to acknowledge
Plaintiffs’ benefit claims, Plaintiffs undertook an independent investigation.
261. Specifically, for the Former Patients, Plaintiffs at great effort and expense
attempted to determine the name of the welfare plan providing the Former Patients’
respective coverage.
262. Once Plaintiffs obtained that information, Plaintiffs were able to obtain
for some welfare plans the operative plan documents governing the terms of the Former
Patient’s coverage.
263. Because several of those plan documents did not bar the assignment of
benefits, it became clear that Blue Cross Defendants were refusing to pay Plaintiffs’
validly assigned claims without any investigation into whether the applicable plan
documents supported their position. See also Omnibus Motion to Dismiss, ECF
No. 246-1, at 16 (contending that anti-assignment clauses bar only approximately 40
out of 74 underlying claims alleged in the original complaint). It also became clear that
the Welfare Plan Defendants were totally derelict in their responsibility to make sure
that the operative plan documents were and are being followed.
264. Nonetheless, Plaintiffs attempted—through over two dozen letters sent to
the Blue Cross Defendants—to inquire as to why their Assigned Claims were denied.
Those letters were ignored or otherwise unsuccessful in getting the Blue Cross
Defendants to comply with the required federal claims handling regulations.
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265. Given the utter futility of its efforts at non-judicial resolution, Plaintiffs
filed this suit to seek relief.
First Claim For Relief3
Claim To Recover Benefits Under ERISA § 502(a)(1)(B)
(Against Welfare and Blue Cross Defendants Associated With
Plans Lacking Applicable Anti-Assignment Provisions)
266. Plaintiffs re-allege each paragraph of this Complaint as if fully set forth
herein. Plaintiffs also incorporate by reference the allegations set forth in the Patient
Appendix concerning all Patients.
267. Plaintiffs seek relief against any Defendant who is associated with (1) an
ERISA plan that (2) does not by its own terms contain an anti-assignment provision
enforceable against Plaintiffs. (Plaintiffs also seek relief under this claim with respect
to any Patient for whom the foregoing is true on the proofs.)
268. There are a number of reasons that could be so, including (by way of
example): (1) the plan contains no anti-assignment provision at all; (2) the plan
contains an anti-assignment provision that does not reach Plaintiffs; and/or (3) the
relied upon anti-assignment language is not, in fact, contained in a plan document.
269. Plaintiff bring this claim against the Defendants associated with Patients
4, 5, 9, 10, 14, 17, 20, 21, 24, 25, 30, 32, 33, 35, 36, 38, 40, 42, 43, 44, 45, 48, 49, 50,
3 Plaintiffs have amended and restyled their claims for clarity and to comply in good
faith with this Court’s Orders of November 22, 2016 (“Nov. 22 Order”) and September 25, 2017. Although the facts alleged in this Complaint support relief under additional theories—e.g., (1) that Plaintiffs are entitled to reformation and estoppel under ERISA § 502(a)(3), (2) that an anti-assignment provision is not enforceable unless properly disclosed in an SPD, and (3) that the holder of a facially valid assignment is entitled to ERISA’s protective procedures and Defendants’ refusal to follow same is a fiduciary breach for which Plaintiffs are entitled to a remedy such as surcharge—this Court rejected those theories as a matter of law in its Nov. 22 and Sept. 25 Orders. Plaintiffs accordingly do not replead those theories here. But they expressly preserve and intend to appeal them to the Ninth Circuit at the appropriate time.
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51, 52, 53, 54, 56, 57, 60, 70, 73, 74, 76, 78, 81, 84, 90, 91, 92, 100, 103, 106, 107,
108, 110, 114, 115, 117, 121, 122, 124, 128, 129, 133, 136, 141, 142, 143, 145, 146,
147, 148, 151, 155, 156, 158, 159, 162, 164, 165, 166, 167, 168, 169, 170, 172, 175,
176, 177, 179, 183, 184, 185, 187, 188, 189, 190, 193, 194, 195, 199, 201, 206, 208,
212, 214, 217, 218, 220, 221, 223, 225, 226, 227, 228, 229, 230, 231, 232, 233, 234,
235, 236, 237, 241, 242, 244, 245, 248, 249, 251, 252, 253, 255, 256, 259, 260, and
269.
270. The plans associated with these Patients (1) do not have anti-assignment
provisions, (2) have anti-assignment provisions that do not facially or clearly apply to
Plaintiffs, or (3) Defendants have produced documents that purport to have relevant
anti-assignment provisions, but those provisions are unenforceable because they on
their own terms do not clearly reach Plaintiffs and/or because they are not contained in
documents that are part of the plan. Thus, under these plans, Plaintiffs were entitled to
be paid directly for services rendered in connection with the treatment of these Patients.
271. Plaintiffs were not paid directly, and seek to be paid, in full, for the
services rendered in treating all Patients that fall within the scope of the First Claim for
Relief, pursuant to 29 U.S.C § 1132(a)(1)(B).
Second Claim For Relief
Claim for Unfair Competition Under
Cal. Business and Professions Code §§ 17200 et seq.
(Against the Blue Cross Defendants)
272. Plaintiffs re-allege each paragraph of this Complaint as if fully set forth
herein. Plaintiffs also incorporate by reference the allegations set forth in the Patient
Appendix concerning all Patients.
273. Plaintiffs bring this claim in their own right and not as assignees. They
seek restitutionary and injunctive relief against the Blue Cross Defendants collectively
as co-conspirators, and also against specifically identified Blue Cross Defendants
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individually, for violations of California’s Unfair Competition Law (“UCL”), Cal. Bus.
& Prof. Code § 17200 et seq.
274. To comply with this Court’s order to provide greater specificity into its
allegations of fraud (i.e., the who, what, and when of each Blue Cross Defendant’s
specific misrepresentations), Sept. 25 Order at 15-16, Plaintiffs will submit, as Exhibits
C and D, verification of benefits (“VOB”) forms that were prepared at relevant times
by Plaintiffs’ agents and that contain detailed information about the misrepresentations.
See also supra ¶¶ 211-17 (describing Plaintiffs’ VOB process). These forms, which
Plaintiffs will seek to file under seal to avoid disclosure of patient health information,
identify, among other things, (1) the provider hotline that Plaintiffs’ agents called; (2)
the name of the agent placing the call; (3) the date and time of the call; (4) whether or
not Plaintiffs were told the patient’s benefits were assignable, and (5) the name of the
Blue Cross Defendant representative answering the call.4
275. To comply with this Court’s order to individually plead their UCL claims
by patient or by defendant, Sept. 25 Order at 15 & n.4, Plaintiffs have created the table
that immediately follows this paragraph. Plaintiffs have identified Blue Cross
Defendants who made misrepresentations to Plaintiffs using check marks placed in the
table’s second and third columns. A check mark in the second column, labeled
Misrepresented benefits as assignable, indicates that a Blue Cross Defendant
misrepresented at least once that a patient’s benefits were assignable when in fact they
were not (“Column 2 Defendants”). A check mark in the third column, labeled
Misrepresented benefits as not assignable, indicates that a Blue Cross Defendant
misrepresented at least once that a patient’s benefits were not assignable when in fact
4 Because the Blue Cross Defendants’ provider hotlines are not clear about whether the host or home entity is the one answering calls placed by Plaintiffs’ agents, Plaintiffs have made allegations in the incorporated Patient Appendix in the disjunctive against the potentially answering Blues. Plaintiffs detailed VOBs provide information that will allow the Blue Cross Defendants to determine who among them in fact made the false representations. This information is currently unknown to Plaintiffs.
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they were (“Column 3 Defendants”). Because some Blue Cross Defendants made false
representations in both directions, some Blue Cross Defendants have check marks in
the table’s second and third columns. The table also identifies those Blue Cross
Defendants who Plaintiffs seek to hold liable as co-conspirators or joint actors in the
table’s fourth column, labeled Liable as co-conspirator or joint actor. To be clear:
Plaintiffs assert a UCL claim against each Blue Cross Defendant listed below. To avoid
pleading multiple identical paragraphs for each Blue Cross Defendant, after the
following table, Plaintiffs state their allegations against the Blue Cross Defendants
once, adverting to this table where doing so will clarify the allegations made against a
specific Blue Cross Defendant.
Blue Cross Defendant Misrepresented benefits as assignable
Misrepresented benefits as not assignable
Liable as co-conspirator or joint actor
Anthem Health Plans of Kentucky, Inc. ✔ ✔ ✔
Anthem Health Plans of Virginia, Inc. ✔ ✔
Anthem Health Plans, Inc. ✔
Anthem Insurance Companies, Inc. ✔ ✔ ✔
BCBSM, Inc. ✔ ✔ ✔
Blue Cross and Blue Shield of Alabama ✔
Blue Cross and Blue Shield of Florida, Inc. ✔ ✔ ✔
Blue Cross and Blue Shield of Georgia, Inc. ✔
Blue Cross and Blue Shield of Kansas City ✔
Blue Cross and Blue Shield of Kansas, Inc. ✔
Blue Cross and Blue Shield of Mass., Inc. ✔ ✔ Blue Cross and Blue Shield of Massachusetts HMO Blue, Inc. ✔ ✔
Blue Cross and Blue Shield of Nebraska ✔ ✔ ✔
Blue Cross and Blue Shield of North Carolina ✔ ✔ ✔
Blue Cross and Blue Shield of South Carolina ✔ Blue Cross Blue Shield of Michigan Mutual Insurance Co. ✔
Blue Cross Blue Shield of Tennessee, Inc. ✔ ✔
Blue Cross of California ✔ ✔ ✔
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Blue Cross of Idaho Health Service, Inc. ✔ ✔
Blue Cross of Northeastern Pennsylvania ✔
California Physicians’ Service ✔ ✔ ✔
CareFirst of Maryland, Inc. ✔ ✔
Community Insurance Company ✔ ✔ ✔
Empire HealthChoice Assurance, Inc. ✔ ✔
Excellus Health Plan, Inc. ✔ ✔
Group Hospitalization and Medical Services, Inc. ✔ ✔ ✔
Health Care Service Corporation ✔ ✔ ✔
Highmark BCBSD, Inc. ✔ ✔
Highmark Blue Cross Blue Shield ✔
Highmark, Inc. ✔
Highmark Blue Shield ✔ ✔
Horizon Healthcare Services, Inc. ✔ ✔ ✔
Louisiana Health Service & Indemnity Co. ✔ ✔
Premera Blue Cross ✔
Premera Blue Cross Blue Shield of Alaska ✔
Regence BlueCross BlueShield of Oregon ✔ ✔
Regence BlueShield ✔ ✔
Regence BlueShield and/or Premera Blue Cross ✔
Rocky Mtn. Hospital and Medical Service, Inc. ✔ ✔
The Anthem Companies, Inc. ✔ ✔
Wellmark, Inc. ✔
276. The UCL prohibits “unfair competition” and defines it to “mean and
include any unlawful, unfair or fraudulent business act or practice,” among other
things. Cal. Bus. & Prof. Code § 17200. To state a UCL claim, Plaintiffs need only
allege sufficient facts to satisfy at least one of the UCL’s three prongs (unfair, unlawful,
or fraudulent), and must also establish standing by alleging “a loss or deprivation of
money or property sufficient to qualify as injury in fact, i.e., economic injury,”
occurring as a result of, “i.e., caused by, the unfair business practice.” Kwikset Corp.
v. Super. Ct., 51 Cal. 4th 310, 322-24 (Cal. 2011). The Blue Cross Defendants’
unlawful, unfair, and fraudulent conduct is described in turn below.
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277. Unlawful. A business practice that violates a statute is “unlawful” under
the UCL. Each Blue Cross Defendant who misrepresented the assignability of benefits
to Plaintiffs during the verification of benefits (VOB) process engaged in an unlawful
business practice by violating California law prohibiting fraud. Relatedly, all Blue
Cross Defendants engaged in an unlawful business practice by conspiring with one
another to commit fraud on Plaintiffs and other OON providers.
278. Intentional misrepresentation, Cal. Civ. Code § 1710(1), and negligent
misrepresentation, Cal. Civ. Code § 1710(2), are forms of fraud recognized by
California law. “The elements of intentional misrepresentation, or actual fraud, are: (1)
misrepresentation (false representation, concealment, or nondisclosure); (2)
knowledge of falsity (scienter); (3) intent to defraud (i.e., to induce reliance); (4)
justifiable reliance; and (5) resulting damage.” Anderson v. Deloitte & Touche, 56 Cal.
App. 4th 1468, 1474 (1997). Negligent misrepresentation does not require knowledge
of falsity or intent to defraud. It is enough to show that a person asserted a fact as true
without a reasonable basis for believing it to be true. OCM Principal Opportunities
Fund v. CIBC World Market, 157 Cal. App. 4th 835, 845 (2007), as modified (Dec. 26,
2007). Individuals who “share with the immediate tortfeasors a common plan or
design” in the perpetration of a fraud are liable along with the tortfeasors themselves
under the doctrine of conspiracy. See Applied Equipment Corp. v. Litton Saudi Arabia
Ltd. 7 Cal.4th 503, 510-11 (1994) (citations omitted).
279. On numerous occasions, the Blue Cross Defendants misrepresented
whether benefits under the relevant plans could be assigned to Plaintiffs. Specifically:
a. During the verification of benefits process, Blue Cross Defendants
routinely told Plaintiffs that claims were assignable when in fact assignments
were barred. For example, with respect to the 80 patients where Plaintiffs’
ERISA claims were dismissed with prejudice on the grounds of valid AAP,
Plaintiffs were told that 45 of them (56%) were enrolled in plans that permitted
assignment. See Appendix for Patients Nos. 1, 8, 11, 18, 19, 22, 37, 41, 47, 55,
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61, 67, 68, 69, 71, 72, 83, 85, 86, 93, 96, 105, 125, 130, 134, 135, 149, 150, 154,
163, 171, 173, 178, 186, 191, 198, 204, 238, 243, 247, 261, 264, 268, 270, and
274 & Exhibit C (VOBs where assignments were misrepresented as permitted).
b. During the verification of benefits process, Blue Cross Defendants
also routinely told Plaintiffs that assignments were barred when in fact they were
permitted. For example, with respect to the 130 patients in this case where
Plaintiffs ERISA claims have not been dismissed, Plaintiffs were told that 44 of
them (34%) were enrolled in plans that barred assignment. See Appendix for
Patients Nos. 5, 32, 35, 38, 43, 44, 45, 50, 52, 81, 84, 90, 100, 103, 108, 122,
129, 136, 142, 145, 159, 165, 169, 179, 183, 184, 187, 188, 189, 190, 194, 195,
201, 206, 217, 220, 228, 232, 235, 249, 252, 255, 256, and 269 & Exhibit D
(VOBs where assignments were misrepresented as barred).
280. Each Blue Cross Defendant knew or should have known that OON
providers such as Plaintiffs reasonably rely on the representations they make when
calling their provider hotlines, including about whether or not benefits are assignable.
See, e.g., supra ¶¶ 242-43. Each Blue Cross Defendant who made misrepresentations
to Plaintiffs also knew or should have known that their representations were false
because ERISA allows assignments by default and any anti-assignment provision
would have been included in the relevant plan, which the Blue Cross Defendants could
access.
281. Blue Cross Defendants who made misrepresentations to Plaintiffs acted
intentionally or recklessly in making them. The misrepresentations were pervasive
across numerous Blue Cross entities (negating the possibility of isolated mistakes) and
are congruent with the group’s expressed intent to use the assignment process to drive
up costs for OON providers such as Plaintiffs and discourage them from treating Blue
Cross insureds. See supra ¶¶ 244-52; see also Blue Perspective: BCBSOK Position on
Legislation and Regulatory Issues, Blue Cross Blue Shield Oklahoma,
www.bcbsok.com/grassroots/pdf/blueperspective_aob27-103003.pdf (last visited Dec.
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23, 2016) (explaining Blue Cross strategy that “payments for services rendered by
providers who do not contract with [Blue Cross] are sent directly to our customers.
Thus, out-of-network providers face the inconvenience of attempting to collect
payment from the customer and the accompanying possibility of incurring bad debts.”).
At a minimum, the Blue Cross Defendants collectively devised a negligent scheme that
would provide Plaintiffs with some true and some false information about assignability
of benefits, making it impossible for Plaintiffs to know with certainty whether any
particular Blue Cross Defendant’s statements were true.
282. By virtue of their continued membership in, acquiescence to, and approval
of the Blue Cross Blue Shield Association’s anti-assignment policies, including its
policy of providing false information in response to provider inquiries about the
assignability of benefits, all Blue Cross Defendants—including those who are not
alleged to have engaged in misrepresentations themselves—are liable for the
fraudulent acts of one another as co-conspirators.5
283. Plaintiffs were entitled to and did rely on representations of each Blue
Cross Defendant about whether benefits were assignable in deciding whether and on
what terms to treat each Former Patient. Plaintiffs also relied on representations about
whether benefits were assignable throughout the claims process with respect to each
Former Patient. For example, each time a Blue Cross Defendant represented that
benefits were assignable, Plaintiffs reasonably expected to be paid directly for the
claims submitted. Because in some instances Plaintiffs were paid directly by welfare
plans that were administered by Blue Cross Defendants, Plaintiffs had an additional
reason to reasonably rely on the Blue Cross Defendants’ representations.
284. By implementing and overseeing processes that they knew or should have
known would cause OON providers such as Plaintiffs to receive inaccurate information
5 Plaintiffs do not understand the Court’s Sept. 25 Order to foreclose writ large theories upon which the Blue Cross Defendants may be liable for one another’s misconduct, and therefore Plaintiffs have clarified their allegations on that issue herein.
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about the assignability of the benefits of their insureds, each Blue Cross Defendant
benefited itself and harmed Plaintiffs.
285. Each Blue Cross Defendant benefited from its individual
misrepresentations, and collectively from its co-conspirators’ misrepresentations, in at
least the following ways:
a. Some Former Patients received treatment that they otherwise would
not have received at all. All Blue Cross Defendants received reputational
benefits when these Blue Cross insureds received treatment, and the specific
Blue Cross Defendants administering the Former Patients’ plans received an
additional benefit in the form of satisfied customers.
b. Each Blue Cross Defendants paid lower prices for the treatment
Plaintiffs rendered to their insureds.
286. “There are innumerable ways in which economic injury from unfair
competition may be shown.” Kwikset, 51 Cal. 4th at 323. Plaintiffs were harmed and
suffered economic injuries as a result of each Blue Cross Defendant’s
misrepresentations, and as a result of the group’s collective scheme, in at least the
following ways:
a. Each time a Blue Cross Defendant made a misrepresentation to
Plaintiffs, Plaintiffs had to spend money to learn the truth. (This allegation
applies to Column 2 and 3 Defendants.) This included hiring outside counsel to
send letters to the Blue Cross Defendants and associated welfare plans
requesting copies of the plan documents so that they could be reviewed to
determine whether they in fact contained anti-assignment provisions. It also
included bringing this lawsuit to seek restitution (to compensate Plaintiffs for
those losses) and an injunction (to avoid the need for Plaintiffs to continue
spending money to learn the truth).
b. Each time a Blue Cross Defendant told Plaintiffs a claim was
assignable when in fact it was not, Plaintiffs lost money because their
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assignments were worthless when they had been led to believe they would be
honored and therefore were highly valuable. See, e.g., Guido v. L’Oreal, USA,
Inc., 284 F.R.D. 468, 474 (C.D. Cal. 2012), on reconsideration, 2012 WL
2458118 (C.D. Cal. June 25, 2012) (standing found where plaintiffs “suffered a
loss in value and usefulness of [the product]” due to defendant’s
misrepresentation). (This allegation applies to Column 2 Defendants.)
c. Each time a Blue Cross Defendant told Plaintiffs a claim was
assignable when in fact it was not, Plaintiffs lost the opportunity to make
alternate payment arrangements with the Former Patients or to collect additional
money from the Former Patients up front. (This allegation applies to Column 2
and 3 Defendants.) As a result, Plaintiffs received less compensation for their
services than they reasonably expected and were entitled to receive. By
increasing these collection risks and costs, the Blue Cross Defendants caused
Plaintiffs to lose money.
d. Each time a Blue Cross Defendant told Plaintiffs a claim was not
assignable when it in fact was, Plaintiffs lost money when they conducted
unnecessary efforts to collect from patients when they were in fact entitled to
direct payment from Defendants. (This allegation applies to Column 3
Defendants.)
e. Each time a Blue Cross Defendant told Plaintiffs a claim was not
assignable when it in fact was, Plaintiffs spent significant time and resources
pursuing the claims process for claims that the Blue Cross Defendants had
already paid directly to the Former Patients. By increasing these collection costs,
the Blue Cross Defendants caused Plaintiffs to lose money. (This allegation
applies to Column 3 Defendants.)
f. Each time a Blue Cross Defendant told Plaintiffs a claim was not
assignable when it in fact was, Plaintiffs lost the opportunity to assist the Former
Patients with the administrative appeals process. (This allegation applies to
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66 THIRD AMENDED COMPLAINT
CASE NO. SACV15−736 DOC (DFMx) 222434.2
Column 3 Defendants.) As a result, Plaintiffs received less compensation for
their services than they reasonably expected and were entitled to receive even
when the Former Patients sent their payments from the Blue Cross Defendants
to Plaintiffs. By increasing the probability that Plaintiffs would collect less
money from Defendants, the Blue Cross Defendants increased collection risk
and costs, and thereby caused Plaintiffs to lose money.
287. Plaintiffs do not merely seek restitution for their past losses. The primary
relief sought by Plaintiffs is an injunction barring future misrepresentations by the Blue
Cross Defendants about the assignability of claims. Kwikset, 51 Cal. 4th at 337 (citation
omitted) (“Injunctions are ‘the primary form of relief available under the UCL . . . .’”).
Absent this relief, the Blue Cross Defendants will continue to impermissibly injure
Plaintiffs through their fraudulent statements.
288. Unfair. An “unfair” business practice is one that is unfair (including
anticompetitive conduct) but not otherwise proscribed by law. The conduct of the Blue
Cross Defendants described above, see supra ¶¶ 277-87, also constitutes
anticompetitive behavior forbidden by the UCL.
289. Specifically, each Blue Cross Defendant intended either through its direct
misrepresentations or by supporting, acquiescing to, and approving the
misrepresentations by others to reduce the number of OON providers treating Blue
Cross insureds. In doing so, each Blue Cross Defendant sought to distort the market
and force Blue Cross insureds to either select in-network providers or forgo treatment
altogether. Attempted market distortions of this nature are precisely what the UCL is
designed to prevent. See Kwikset, 51 Cal. 4th at 331 (“The UCL [is] intended to
preserve fair competition and protect consumers from market distortions.”).
290. Plaintiffs have standing to seek relief for this misconduct because they
were economically injured in the ways described above. See supra ¶¶ 286(a)-(f).
Plaintiffs seek restitutionary and injunctive relief against each Blue Cross Defendant
for their direct and indirect participation in this anticompetitive scheme.
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67 THIRD AMENDED COMPLAINT
CASE NO. SACV15−736 DOC (DFMx) 222434.2
291. Fraudulent. To satisfy the fraudulent prong, Plaintiffs need not satisfy all
elements of a claim for common law fraud. Instead, Plaintiffs need only show three
things: (1) a “fraudulent” business practice, i.e., one likely to deceive the public; (2)
that it caused Plaintiffs to suffer an economic injury; and (3) a causal connection
between those two things. The conduct of the Blue Cross Defendants described above
also constitutes a fraudulent business practice that independently violates the UCL.
292. As described above, the Blue Cross Defendants made numerous
fraudulent misrepresentations to Plaintiffs causing them to suffer specifically identified
economic injuries. See supra ¶¶ 277-87. Accordingly, in addition to claims for unlawful
and unfair practices, Plaintiffs assert a claim under the fraudulent prong against each
Blue Cross Defendant who made at least one misrepresentation to Plaintiffs. (This
allegation applies to Column 2 and 3 Defendants.) Plaintiffs seek restitution for their
past losses and an injunction barring future misrepresentations by the Blue Cross
Defendants.
PRAYER FOR RELIEF
WHEREFORE, Plaintiffs pray for judgment against Defendants as follows:
1. For equitable relief and monetary relief, in an amount to be proven at trial,
plus all applicable interest and costs;
2. For all attorneys’ fees and costs incurred in bringing this action, to the
extent recoverable by law;
3. For an order enjoining Defendants from continuing their illegal practices;
and
4. For all other relief the Court deems appropriate, proper, and just.
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68 THIRD AMENDED COMPLAINT
CASE NO. SACV15−736 DOC (DFMx) 222434.2
Dated: October 16, 2017 STRIS & MAHER LLP
/s/ Peter K. Stris Peter K. Stris Attorneys for Plaintiffs
DUAL DIAGNOSIS TREATMENT CENTER, INC., SATYA HEALTH OF CALIFORNIA, INC., ADEONA HEALTHCARE, INC., SOVEREIGN HEALTH OF PHOENIX, INC., and SOVEREIGN ASSET MANAGEMENT, INC.
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 69 of 360 Page ID #:61689
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1 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
APPENDIX OF PATIENT SPECIFIC ALLEGATIONS
PATIENT 1
1. On information and belief: Patient 1 was a participant in or beneficiary of
Defendant Profit Plan during all times relevant to this complaint.
2. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the Profit Plan either (i) is insured by North Carolina Blue
and/or California Blue Cross or (ii) is self-insured and has entered into an agreement
with North Carolina Blue and/or California Blue Cross by which the Profit Plan
receives third party administrative services.
3. Plaintiffs obtained an assignment of benefits from Patient 1, who executed
an assignment in the same or substantially similar form to the document attached hereto
as Exhibit A.
4. On or about July 18, 2013, Plaintiffs secured Patient 1’s consent to contact
North Carolina Blue and/or California Blue Cross, along with the identifying
information necessary for Plaintiffs to interact with the insurer.
5. On or about July 18, 2013, Plaintiffs or their agents contacted the Provider
Hotline of North Carolina Blue and/or California Blue Cross and requested details
about Patient 1’s coverage. Plaintiffs or their agents recorded the information learned
from North Carolina Blue and/or California Blue Cross on the bottom of Patient 1’s
Insurance Verification Form. Plaintiffs or their agents learned from North Carolina
Blue and/or California Blue Cross that Patient 1’s benefits were assignable. Plaintiffs
or their agents recorded this by circling “Yes” next to the line “Assignable” on Patient
1’s Insurance Verification Form.
6. On or about July 22, 2013, Plaintiffs began providing mental health and/or
substance abuse treatment to Patient 1.
7. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Cross or North Carolina Blue on the industry-standard
UB-04 form. Plaintiffs indicated that it was requesting that benefits be paid to it as an
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CASE NO. SACV15−0736 DOC (DFMx) 206541.1
assignee by inserting the letter Y in the appropriate field (box 53) each time it submitted
a claim.
8. On information and belief: California Blue Cross, North Carolina Blue,
and/or the Profit Plan thereafter paid some or all of the assigned benefits to Patient 1
instead of Plaintiffs.
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CASE NO. SACV15−0736 DOC (DFMx) 206541.1
PATIENT 4
9. On information and belief: Patient 4 was a participant in or beneficiary of
an unknown ERISA-governed welfare plan during all times relevant to this complaint.
10. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the unknown plan either (i) is insured by California Blue
Cross or (ii) is self-insured and has entered into an agreement with California Blue
Cross by which the unknown plan receives third party administrative services.
11. Plaintiffs obtained an assignment of benefits from Patient 4, who executed
an assignment in the same or substantially similar form to the document attached hereto
as Exhibit A.
12. On or about April 10, 2014, Plaintiffs secured Patient 4’s consent to
contact California Blue Cross, along with the identifying information necessary for
Plaintiffs to interact with the insurer.
13. On or about April 14, 2014, Plaintiffs began providing mental health
and/or substance abuse treatment to Patient 4.
14. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Cross on the industry-standard UB-04 form. Plaintiffs
indicated that it was requesting that benefits be paid to it as an assignee by inserting
the letter Y in the appropriate field (box 53) each time it submitted a claim.
15. On information and belief: California Blue Cross and/or the unknown
plan thereafter paid some or all of the assigned benefits to Patient 4 instead of Plaintiffs.
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CASE NO. SACV15−0736 DOC (DFMx) 206541.1
PATIENT 5
16. On information and belief: Patient 5 was a participant in or beneficiary of
an unknown ERISA-governed welfare plan during all times relevant to this complaint.
17. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the unknown plan either (i) is insured by North Carolina
Blue and/or California Blue Cross or (ii) is self-insured and has entered into an
agreement with North Carolina Blue and/or California Blue Cross by which the
unknown plan receives third party administrative services.
18. Plaintiffs obtained an assignment of benefits from Patient 5, who executed
an assignment in the same or substantially similar form to the document attached hereto
as Exhibit B.
19. On or about July 2, 2014, Plaintiffs secured Patient 5’s consent to contact
North Carolina Blue and/or California Blue Cross, along with the identifying
information necessary for Plaintiffs to interact with the insurer.
20. On or about July 2, 2014, Plaintiffs or their agents contacted the Provider
Hotline of North Carolina Blue and/or California Blue Cross and requested details
about Patient 5’s coverage. Plaintiffs or their agents recorded the information learned
from North Carolina Blue and/or California Blue Cross on the bottom of Patient 5’s
Insurance Verification Form. Plaintiffs or their agents learned from North Carolina
Blue and/or California Blue Cross that Patient 5’s benefits were not assignable.
Plaintiffs or their agents recorded this by circling “No” next to the line “Assignable”
on Patient 5’s Insurance Verification Form.
21. On or about July 10, 2014, Plaintiffs began providing mental health and/or
substance abuse treatment to Patient 5.
22. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Cross or North Carolina Blue on the industry-standard
UB-04 form. Plaintiffs indicated that it was requesting that benefits be paid to it as an
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CASE NO. SACV15−0736 DOC (DFMx) 206541.1
assignee by inserting the letter Y in the appropriate field (box 53) each time it submitted
a claim.
23. On information and belief: California Blue Cross, North Carolina Blue,
and/or the unknown plan thereafter paid some or all of the assigned benefits to Patient
5 instead of Plaintiffs.
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6 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
PATIENT 8
24. On information and belief: Patient 8 was a participant in or beneficiary of
Defendant Ameriflight Plan during all times relevant to this complaint.
25. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the Ameriflight Plan either (i) is insured by California Blue
Cross or (ii) is self-insured and has entered into an agreement with California Blue
Cross by which the Ameriflight Plan receives third party administrative services.
26. Plaintiffs obtained an assignment of benefits from Patient 8, who executed
an assignment in the same or substantially similar form to the document attached hereto
as Exhibit A.
27. On or about December 13, 2012, Plaintiffs secured Patient 8’s consent to
contact California Blue Cross, along with the identifying information necessary for
Plaintiffs to interact with the insurer.
28. On or about December 13, 2012, Plaintiffs or their agents contacted the
Provider Hotline of California Blue Cross and requested details about Patient 8’s
coverage. Plaintiffs or their agents recorded the information learned from California
Blue Cross on the bottom of Patient 8’s Insurance Verification Form. Plaintiffs or their
agents learned from California Blue Cross that Patient 8’s benefits were assignable.
Plaintiffs or their agents recorded this by circling “Yes” next to the line “Assignable”
on Patient 8’s Insurance Verification Form.
29. On or about December 14, 2012, Plaintiffs began providing mental health
and/or substance abuse treatment to Patient 8.
30. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Cross on the industry-standard UB-04 form. Plaintiffs
indicated that it was requesting that benefits be paid to it as an assignee by inserting
the letter Y in the appropriate field (box 53) each time it submitted a claim.
31. On information and belief: California Blue Cross and/or the Ameriflight
Plan thereafter paid some or all of the assigned benefits to Patient 8 instead of Plaintiffs.
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CASE NO. SACV15−0736 DOC (DFMx) 206541.1
PATIENT 9
32. On information and belief: Patient 9 was a participant in or beneficiary of
the ADP Total Source Plan (the “ADP Plan”) during all times relevant to this
complaint.
33. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the ADP Plan either (i) is insured by New York Empire
Blue and/or California Blue Cross or (ii) is self-insured and has entered into an
agreement with New York Empire Blue and/or California Blue Cross by which the
ADP Plan receives third party administrative services.
34. Plaintiffs obtained an assignment of benefits from Patient 9, who executed
an assignment in the same or substantially similar form to the document attached hereto
as Exhibit A.
35. On or about February 14, 2014, Plaintiffs secured Patient 9’s consent to
contact New York Empire Blue and/or California Blue Cross, along with the
identifying information necessary for Plaintiffs to interact with the insurer.
36. On or about February 18, 2014, Plaintiffs began providing mental health
and/or substance abuse treatment to Patient 9.
37. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Cross or New York Empire Blue on the industry-
standard UB-04 form. Plaintiffs indicated that it was requesting that benefits be paid
to it as an assignee by inserting the letter Y in the appropriate field (box 53) each time
it submitted a claim.
38. On information and belief: California Blue Cross, New York Empire
Blue, and/or the ADP Plan thereafter paid some or all of the assigned benefits to Patient
9 instead of Plaintiffs.
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8 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
PATIENT 10
39. On information and belief: Patient 10 was a participant in or beneficiary
of the Targeted Medical Pharma, Inc. Plan (the “TMP Plan”) during all times relevant
to this complaint.
40. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the TMP Plan either (i) is insured by Hawai’i Blue and/or
California Blue Cross or (ii) is self-insured and has entered into an agreement with
Hawai’i Blue and/or California Blue Cross by which the TMP Plan receives third party
administrative services.
41. Plaintiffs obtained an assignment of benefits from Patient 10, who
executed an assignment in the same or substantially similar form to the document
attached hereto as Exhibit A.
42. On or about February 17, 2014, Plaintiffs secured Patient 10’s consent to
contact Hawai’i Blue and/or California Blue Cross, along with the identifying
information necessary for Plaintiffs to interact with the insurer.
43. On or about March 19, 2014, Plaintiffs began providing mental health
and/or substance abuse treatment to Patient 10.
44. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to Hawai’i Blue and/or California Blue Cross on the industry-standard
UB-04 form. Plaintiffs indicated that it was requesting that benefits be paid to it as an
assignee by inserting the letter Y in the appropriate field (box 53) each time it submitted
a claim.
45. On information and belief: Hawai’i Blue, California Blue Cross and/or
the TMP Plan thereafter paid some or all of the assigned benefits to Patient 10 instead
of Plaintiffs.
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9 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
PATIENT 11
46. On information and belief: Patient 11 was a participant in or beneficiary
of The Dog Lady, LLC group health plan (the “Dog Lady Plan”) during all times
relevant to this complaint.
47. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the Dog Lady Plan either (i) is insured by California Blue
Shield or (ii) is self-insured and has entered into an agreement with California Blue
Shield by which the Dog Lady Plan receives third party administrative services.
48. Plaintiffs obtained an assignment of benefits from Patient 11, who
executed an assignment in the same or substantially similar form to the document
attached hereto as Exhibit A.
49. On or about October 16, 2012, Plaintiffs secured Patient 11’s consent to
contact California Blue Shield, along with the identifying information necessary for
Plaintiffs to interact with the insurer.
50. On or about October 16, 2012, Plaintiffs or their agents contacted the
Provider Hotline of California Blue Shield and requested details about Patient 11’s
coverage. Plaintiffs or their agents recorded the information learned from California
Blue Shield on the bottom of Patient 11’s Insurance Verification Form. Plaintiffs or
their agents learned from California Blue Shield that Patient 11’s benefits were
assignable. Plaintiffs or their agents recorded this by circling “Yes” next to the line
“Assignable” on Patient 11’s Insurance Verification Form.
51. On or about November 12, 2012, Plaintiffs began providing mental health
and/or substance abuse treatment to Patient 11.
52. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Shield on the industry-standard UB-04 form.
Plaintiffs indicated that it was requesting that benefits be paid to it as an assignee by
inserting the letter Y in the appropriate field (box 53) each time it submitted a claim.
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CASE NO. SACV15−0736 DOC (DFMx) 206541.1
53. On information and belief: California Blue Shield and/or the Dog Lady
Plan thereafter paid some or all of the assigned benefits to Patient 11 instead of
Plaintiffs.
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11 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
PATIENT 14
54. On information and belief: Patient 14 was a participant in or beneficiary
of Defendant Hartford Plan during all times relevant to this complaint.
55. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the Hartford Plan either (i) is insured by Indiana Blue and/or
California Blue Cross or (ii) is self-insured and has entered into an agreement with
Indiana Blue and/or California Blue Cross by which the Hartford Plan receives third
party administrative services.
56. Plaintiffs obtained an assignment of benefits from Patient 14, who
executed an assignment in the same or substantially similar form to the document
attached hereto as Exhibit A.
57. On or about January 11, 2013, Plaintiffs secured Patient 14’s consent to
contact Indiana Blue and/or California Blue Cross, along with the identifying
information necessary for Plaintiffs to interact with the insurer.
58. On or about January 25, 2013, Plaintiffs began providing mental health
and/or substance abuse treatment to Patient 14.
59. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Cross or Indiana Blue on the industry-standard UB-
04 form. Plaintiffs indicated that it was requesting that benefits be paid to it as an
assignee by inserting the letter Y in the appropriate field (box 53) each time it submitted
a claim.
60. On information and belief: California Blue Cross, Indiana Blue, and/or
the Hartford Plan thereafter paid some or all of the assigned benefits to Patient 14
instead of Plaintiffs.
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12 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
PATIENT 17
61. On information and belief: Patient 17 was a participant in or beneficiary
of an unknown ERISA-governed welfare plan during all times relevant to this
complaint.
62. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the unknown plan either (i) is insured by New Jersey Blue
and/or California Blue Cross or (ii) is self-insured and has entered into an agreement
with New Jersey Blue and/or California Blue Cross by which the unknown plan
receives third party administrative services.
63. Plaintiffs obtained an assignment of benefits from Patient 17, who
executed an assignment in the same or substantially similar form to the document
attached hereto as Exhibit B.
64. On or about July 29, 2014, Plaintiffs secured Patient 17’s consent to
contact New Jersey Blue and/or California Blue Cross, along with the identifying
information necessary for Plaintiffs to interact with the insurer.
65. On or about August 28, 2014, Plaintiffs began providing mental health
and/or substance abuse treatment to Patient 17.
66. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Cross or New Jersey Blue on the industry-standard
UB-04 form. Plaintiffs indicated that it was requesting that benefits be paid to it as an
assignee by inserting the letter Y in the appropriate field (box 53) each time it submitted
a claim.
67. On information and belief: California Blue Cross, New Jersey Blue,
and/or the unknown plan thereafter paid some or all of the assigned benefits to Patient
17 instead of Plaintiffs.
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13 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
PATIENT 18
68. On information and belief: Patient 18 was a participant in or beneficiary
of Defendant Bart Plan during all times relevant to this complaint.
69. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the Bart Plan either (i) is insured by Louisiana Blue and/or
California Blue Cross or (ii) is self-insured and has entered into an agreement with
Louisiana Blue and/or California Blue Cross by which the Bart Plan receives third
party administrative services.
70. Plaintiffs obtained an assignment of benefits from Patient 18, who
executed an assignment in the same or substantially similar form to the document
attached hereto as Exhibit A.
71. On or about May 13, 2013, Plaintiffs secured Patient 18’s consent to
contact Louisiana Blue and/or California Blue Cross, along with the identifying
information necessary for Plaintiffs to interact with the insurer.
72. On or about May 13, 2013, Plaintiffs or their agents contacted the Provider
Hotline of Louisiana Blue and/or California Blue Cross and requested details about
Patient 18’s coverage. Plaintiffs or their agents recorded the information learned from
Louisiana Blue and/or California Blue Cross on the bottom of Patient 18’s Insurance
Verification Form. Plaintiffs or their agents learned from Louisiana Blue and/or
California Blue Cross that Patient 18’s benefits were assignable. Plaintiffs or their
agents recorded this by circling “Yes” next to the line “Assignable” on Patient 18’s
Insurance Verification Form.
73. On or about May 15, 2013, Plaintiffs began providing mental health
and/or substance abuse treatment to Patient 18.
74. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Cross or Louisiana Blue on the industry-standard UB-
04 form. Plaintiffs indicated that it was requesting that benefits be paid to it as an
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14 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
assignee by inserting the letter Y in the appropriate field (box 53) each time it submitted
a claim.
75. On information and belief: California Blue Cross, Louisiana Blue, and/or
the Bart Plan thereafter paid some or all of the assigned benefits to Patient 18 instead
of Plaintiffs.
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 83 of 360 Page ID #:61703
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0017
15 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
PATIENT 19
76. On information and belief: Patient 19 was a participant in or beneficiary
of the Rauh Polymers, Inc. Plan (the “Polymers Plan”) during all times relevant to this
complaint.
77. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the Polymers Plan either (i) is insured by Ohio Blue and/or
California Blue Cross or (ii) is self-insured and has entered into an agreement with
Ohio Blue and/or California Blue Cross by which the Polymers Plan receives third
party administrative services.
78. Plaintiffs obtained an assignment of benefits from Patient 19, who
executed an assignment in the same or substantially similar form to the document
attached hereto as Exhibit B.
79. On or about March 21, 2014, Plaintiffs secured Patient 19’s consent to
contact Ohio Blue and/or California Blue Cross, along with the identifying information
necessary for Plaintiffs to interact with the insurer.
80. On or about March 21, 2014, Plaintiffs or their agents contacted the
Provider Hotline of Ohio Blue and/or California Blue Cross and requested details about
Patient 19’s coverage. Plaintiffs or their agents recorded the information learned from
Ohio Blue and/or California Blue Cross on the bottom of Patient 19’s Insurance
Verification Form. Plaintiffs or their agents learned from Ohio Blue and/or California
Blue Cross that Patient 19’s benefits were assignable. Plaintiffs or their agents recorded
this by circling “Yes” next to the line “Assignable” on Patient 19’s Insurance
Verification Form.
81. On or about March 24, 2014, Plaintiffs began providing mental health
and/or substance abuse treatment to Patient 19.
82. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Cross or Ohio Blue on the industry-standard UB-04
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 84 of 360 Page ID #:61704
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16 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
form. Plaintiffs indicated that it was requesting that benefits be paid to it as an assignee
by inserting the letter Y in the appropriate field (box 53) each time it submitted a claim.
83. On information and belief: California Blue Cross, Ohio Blue, and/or the
Polymers Plan thereafter paid some or all of the assigned benefits to Patient 19 instead
of Plaintiffs.
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 85 of 360 Page ID #:61705
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0017
17 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
PATIENT 20
84. On information and belief: Patient 20 was a participant in or beneficiary
of an unknown ERISA-governed welfare plan during all times relevant to this
complaint.
85. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the unknown plan either (i) is insured by New Jersey Blue
and/or California Blue Cross or (ii) is self-insured and has entered into an agreement
with New Jersey Blue and/or California Blue Cross by which the unknown plan
receives third party administrative services.
86. Plaintiffs obtained an assignment of benefits from Patient 20, who
executed an assignment in the same or substantially similar form to the document
attached hereto as Exhibit A.
87. On or about August 12, 2013, Plaintiffs secured Patient 20’s consent to
contact New Jersey Blue and/or California Blue Cross, along with the identifying
information necessary for Plaintiffs to interact with the insurer.
88. On or about August 30, 2013, Plaintiffs began providing mental health
and/or substance abuse treatment to Patient 20.
89. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Cross or New Jersey Blue on the industry-standard
UB-04 form. Plaintiffs indicated that it was requesting that benefits be paid to it as an
assignee by inserting the letter Y in the appropriate field (box 53) each time it submitted
a claim.
90. On information and belief: California Blue Cross, New Jersey Blue,
and/or the unknown plan thereafter paid some or all of the assigned benefits to Patient
20 instead of Plaintiffs.
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 86 of 360 Page ID #:61706
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0017
18 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
PATIENT 21
91. On information and belief: Patient 21 was a participant in or beneficiary
of an unknown ERISA-governed welfare plan during all times relevant to this
complaint.
92. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the unknown plan either (i) is insured by New Jersey Blue
and/or California Blue Cross or (ii) is self-insured and has entered into an agreement
with New Jersey Blue and/or California Blue Cross by which the unknown plan
receives third party administrative services.
93. Plaintiffs obtained an assignment of benefits from Patient 21, who
executed an assignment in the same or substantially similar form to the document
attached hereto as Exhibit A.
94. On or about November 20, 2012, Plaintiffs secured Patient 21’s consent
to contact New Jersey Blue and/or California Blue Cross, along with the identifying
information necessary for Plaintiffs to interact with the insurer.
95. On or about November 27, 2012, Plaintiffs began providing mental health
and/or substance abuse treatment to Patient 21.
96. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Cross or New Jersey Blue on the industry-standard
UB-04 form. Plaintiffs indicated that it was requesting that benefits be paid to it as an
assignee by inserting the letter Y in the appropriate field (box 53) each time it submitted
a claim.
97. On information and belief: California Blue Cross, New Jersey Blue,
and/or the unknown plan thereafter paid some or all of the assigned benefits to Patient
21 instead of Plaintiffs.
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 87 of 360 Page ID #:61707
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19 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
PATIENT 22
98. On information and belief: Patient 22 was a participant in or beneficiary
of Defendant HDR Plan during all times relevant to this complaint.
99. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the HDR Plan either (i) is insured by Nebraska Blue and/or
California Blue Cross or (ii) is self-insured and has entered into an agreement with
Nebraska Blue and/or California Blue Cross by which the HDR Plan receives third
party administrative services.
100. Plaintiffs obtained an assignment of benefits from Patient 22, who
executed an assignment in the same or substantially similar form to the document
attached hereto as Exhibit A.
101. On or about December 26, 2012, Plaintiffs secured Patient 22’s consent
to contact Nebraska Blue and/or California Blue Cross, along with the identifying
information necessary for Plaintiffs to interact with the insurer.
102. On or about December 26, 2012, Plaintiffs or their agents contacted the
Provider Hotline of Nebraska Blue and/or California Blue Cross and requested details
about Patient 22’s coverage. Plaintiffs or their agents recorded the information learned
from Nebraska Blue and/or California Blue Cross on the bottom of Patient 22’s
Insurance Verification Form. Plaintiffs or their agents learned from Nebraska Blue
and/or California Blue Cross that Patient 22’s benefits were assignable. Plaintiffs or
their agents recorded this by circling “Yes” next to the line “Assignable” on Patient
22’s Insurance Verification Form.
103. On or about December 27, 2012, Plaintiffs began providing mental health
and/or substance abuse treatment to Patient 22.
104. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Cross or Nebraska Blue on the industry-standard UB-
04 form. Plaintiffs indicated that it was requesting that benefits be paid to it as an
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20 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
assignee by inserting the letter Y in the appropriate field (box 53) each time it submitted
a claim.
105. On information and belief: California Blue Cross, Nebraska Blue, and/or
the HDR Plan thereafter paid some or all of the assigned benefits to Patient 22 instead
of Plaintiffs.
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 89 of 360 Page ID #:61709
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21 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
PATIENT 24
106. On information and belief: Patient 24 was a participant in or beneficiary
of Defendant DKG Plan during all times relevant to this complaint.
107. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the DKG Plan either (i) is insured by Texas Blue and/or
California Blue Cross or (ii) is self-insured and has entered into an agreement with
Texas Blue and/or California Blue Cross by which the DKG Plan receives third party
administrative services.
108. Plaintiffs obtained an assignment of benefits from Patient 24, who
executed an assignment in the same or substantially similar form to the document
attached hereto as Exhibit A.
109. On or about March 21, 2014, Plaintiffs secured Patient 24’s consent to
contact Texas Blue and/or California Blue Cross, along with the identifying
information necessary for Plaintiffs to interact with the insurer.
110. On or about March 26, 2014, Plaintiffs began providing mental health
and/or substance abuse treatment to Patient 24.
111. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Cross or Texas Blue on the industry-standard UB-04
form. Plaintiffs indicated that it was requesting that benefits be paid to it as an assignee
by inserting the letter Y in the appropriate field (box 53) each time it submitted a claim.
112. On information and belief: California Blue Cross, Texas Blue, and/or the
DKG Plan thereafter paid some or all of the assigned benefits to Patient 24 instead of
Plaintiffs.
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 90 of 360 Page ID #:61710
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22 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
PATIENT 25
113. On information and belief: Patient 25 was a participant in or beneficiary
of Defendant Dirt Free Plan during all times relevant to this complaint.
114. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the Dirt Free Plan either (i) is insured by Texas Blue and/or
California Blue Cross or (ii) is self-insured and has entered into an agreement with
Texas Blue and/or California Blue Cross by which the Dirt Free Plan receives third
party administrative services.
115. Plaintiffs obtained an assignment of benefits from Patient 25, who
executed an assignment in the same or substantially similar form to the document
attached hereto as Exhibit A.
116. On or about April 17, 2014 Plaintiffs secured Patient 25’s consent to
contact Texas Blue and/or California Blue Cross, along with the identifying
information necessary for Plaintiffs to interact with the insurer.
117. On or about May 2, 2014, Plaintiffs began providing mental health and/or
substance abuse treatment to Patient 25.
118. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Cross or Texas Blue on the industry-standard UB-04
form. Plaintiffs indicated that it was requesting that benefits be paid to it as an assignee
by inserting the letter Y in the appropriate field (box 53) each time it submitted a claim.
119. On information and belief: California Blue Cross, Texas Blue, and/or the
Dirt Free Plan thereafter paid some or all of the assigned benefits to Patient 25 instead
of Plaintiffs.
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 91 of 360 Page ID #:61711
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A 9
0017
23 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
PATIENT 26
120. On information and belief: Patient 26 was a participant in or beneficiary
of the Wyman-Gordon Investing Casting, Inc. Century Preferred Plan (the “Wyman-
Gordon Plan”) during all times relevant to this complaint.
121. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the Wyman-Gordon Plan either (i) is insured by Connecticut
Blue and/or California Blue Cross or (ii) is self-insured and has entered into an
agreement with Connecticut Blue and/or California Blue Cross by which the Wyman-
Gordon Plan receives third party administrative services.
122. Plaintiffs obtained an assignment of benefits from Patient 26, who
executed an assignment in the same or substantially similar form to the document
attached hereto as Exhibit B.
123. On or about August 25, 2014, Plaintiffs secured Patient 26’s consent to
contact Connecticut Blue and/or California Blue Cross, along with the identifying
information necessary for Plaintiffs to interact with the insurer.
124. On or about August 28 2014, Plaintiffs began providing mental health
and/or substance abuse treatment to Patient 26.
125. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Cross or Connecticut Blue on the industry-standard
UB-04 form. Plaintiffs indicated that it was requesting that benefits be paid to it as an
assignee by inserting the letter Y in the appropriate field (box 53) each time it submitted
a claim.
126. On information and belief: California Blue Cross, Connecticut Blue,
and/or the Wyman-Gordon Plan thereafter paid some or all of the assigned benefits to
Patient 26 instead of Plaintiffs.
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 92 of 360 Page ID #:61712
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0017
24 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
PATIENT 28
127. On information and belief: Patient 28 was a participant in or beneficiary
of Defendant Puget Sound Pilots Plan during all times relevant to this complaint.
128. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the Puget Sound Pilots Plan either (i) is insured by
Washington Regence Blue and/or California Blue Cross or (ii) is self-insured and has
entered into an agreement with Washington Regence Blue and/or California Blue Cross
by which the Puget Sound Pilots Plan receives third party administrative services.
129. Plaintiffs obtained an assignment of benefits from Patient 28, who
executed an assignment in the same or substantially similar form to the document
attached hereto as Exhibit A.
130. On or about July 29, 2013, Plaintiffs secured Patient 28’s consent to
contact Washington Regence Blue and/or California Blue Cross, along with the
identifying information necessary for Plaintiffs to interact with the insurer.
131. On or about July 30, 2013, Plaintiffs began providing mental health and/or
substance abuse treatment to Patient 28.
132. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Cross or Washington Regence Blue on the industry-
standard UB-04 form. Plaintiffs indicated that it was requesting that benefits be paid
to it as an assignee by inserting the letter Y in the appropriate field (box 53) each time
it submitted a claim.
133. On information and belief: California Blue Cross, Washington Regence
Blue, and/or the Puget Sound Pilots Plan thereafter paid some or all of the assigned
benefits to Patient 28 instead of Plaintiffs.
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 93 of 360 Page ID #:61713
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25 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
PATIENT 30
134. On information and belief: Patient 30 was a participant in or beneficiary
of the VCM, LLC Plan (the “VCM Plan”) during all times relevant to this complaint.
135. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the VCM Plan either (i) is insured by Tennessee Blue and/or
California Blue Cross or (ii) is self-insured and has entered into an agreement with
Tennessee Blue and/or California Blue Cross by which the VCM Plan receives third
party administrative services.
136. Plaintiffs obtained an assignment of benefits from Patient 30, who
executed an assignment in the same or substantially similar form to the document
attached hereto as Exhibit A.
137. On or about February 7, 2013, Plaintiffs secured Patient 30’s consent to
contact Tennessee Blue and/or California Blue Cross, along with the identifying
information necessary for Plaintiffs to interact with the insurer.
138. On or about February 14, 2013, Plaintiffs began providing mental health
and/or substance abuse treatment to Patient 30.
139. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Cross or Tennessee Blue on the industry-standard
UB-04 form. Plaintiffs indicated that it was requesting that benefits be paid to it as an
assignee by inserting the letter Y in the appropriate field (box 53) each time it submitted
a claim.
140. On information and belief: California Blue Cross, Tennessee Blue, and/or
the VCM Plan thereafter paid some or all of the assigned benefits to Patient 30 instead
of Plaintiffs.
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 94 of 360 Page ID #:61714
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26 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
PATIENT 31
141. On information and belief: Patient 31 was a participant in or beneficiary
of Defendant TUV Plan during all times relevant to this complaint.
142. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the TUV Plan either (i) is insured by Massachusetts Blue
and/or California Blue Cross or (ii) is self-insured and has entered into an agreement
with Massachusetts Blue and/or California Blue Cross by which the TUV Plan receives
third party administrative services.
143. Plaintiffs obtained an assignment of benefits from Patient 31, who
executed an assignment in the same or substantially similar form to the document
attached hereto as Exhibit A.
144. On or about September 5, 2012, Plaintiffs secured Patient 31’s consent to
contact Massachusetts Blue and/or California Blue Cross, along with the identifying
information necessary for Plaintiffs to interact with the insurer.
145. On or about September 10, 2012, Plaintiffs began providing mental health
and/or substance abuse treatment to Patient 31.
146. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Cross or Massachusetts Blue on the industry-standard
UB-04 form. Plaintiffs indicated that it was requesting that benefits be paid to it as an
assignee by inserting the letter Y in the appropriate field (box 53) each time it submitted
a claim.
147. On information and belief: California Blue Cross, Massachusetts Blue,
and/or the TUV Plan thereafter paid some or all of the assigned benefits to Patient 31
instead of Plaintiffs.
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 95 of 360 Page ID #:61715
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27 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
PATIENT 32
148. On information and belief: Patient 32 was a participant in or beneficiary
of Defendant AEA Plan during all times relevant to this complaint.
149. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the AEA Plan either (i) is insured by Texas Blue and/or
California Blue Cross or (ii) is self-insured and has entered into an agreement with
Texas Blue and/or California Blue Cross by which the AEA Plan receives third party
administrative services.
150. Plaintiffs obtained an assignment of benefits from Patient 32, who
executed an assignment in the same or substantially similar form to the document
attached hereto as Exhibit A.
151. On or about October 1, 2012, Plaintiffs secured Patient 32’s consent to
contact Texas Blue and/or California Blue Cross, along with the identifying
information necessary for Plaintiffs to interact with the insurer.
152. On or about October 1, 2012, Plaintiffs or their agents contacted the
Provider Hotline of Texas Blue and/or California Blue Cross and requested details
about Patient 32’s coverage. Plaintiffs or their agents recorded the information learned
from Texas Blue and/or California Blue Cross on the bottom of Patient 32’s Insurance
Verification Form. Plaintiffs or their agents learned from Texas Blue and/or California
Blue Cross that Patient 32’s benefits were not assignable. Plaintiffs or their agents
recorded this by circling “No” next to the line “Assignable” on Patient 32’s Insurance
Verification Form.
153. On or about October 4, 2012, Plaintiffs began providing mental health
and/or substance abuse treatment to Patient 32.
154. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Cross or Texas Blue on the industry-standard UB-04
form. Plaintiffs indicated that it was requesting that benefits be paid to it as an assignee
by inserting the letter Y in the appropriate field (box 53) each time it submitted a claim.
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 96 of 360 Page ID #:61716
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155. On information and belief: California Blue Cross, Texas Blue, and/or the
AEA Plan thereafter paid some or all of the assigned benefits to Patient 32 instead of
Plaintiffs.
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29 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
PATIENT 33
156. On information and belief: Patient 33 was a participant in or beneficiary
of Defendant WF Plan during all times relevant to this complaint.
157. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the WF Plan either (i) is insured by Indiana Blue and/or
California Blue Cross or (ii) is self-insured and has entered into an agreement with
Indiana Blue and/or California Blue Cross by which the WF Plan receives third party
administrative services.
158. Plaintiffs obtained an assignment of benefits from Patient 33, who
executed an assignment in the same or substantially similar form to the document
attached hereto as Exhibit A.
159. On or about February 25, 2013, Plaintiffs secured Patient 33’s consent to
contact Indiana Blue and/or California Blue Cross, along with the identifying
information necessary for Plaintiffs to interact with the insurer.
160. On or about February 26, 2013, Plaintiffs began providing mental health
and/or substance abuse treatment to Patient 33.
161. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Cross or Indiana Blue on the industry-standard UB-
04 form. Plaintiffs indicated that it was requesting that benefits be paid to it as an
assignee by inserting the letter Y in the appropriate field (box 53) each time it submitted
a claim.
162. On information and belief: California Blue Cross, Indiana Blue, and/or
the WF Plan thereafter paid some or all of the assigned benefits to Patient 33 instead
of Plaintiffs.
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 98 of 360 Page ID #:61718
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30 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
PATIENT 34
163. On information and belief: Patient 34 was a participant in or beneficiary
of Defendant SeaBright Plan during all times relevant to this complaint.
164. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the SeaBright Plan either (i) is insured by Washington
Premera Blue and/or California Blue Cross or (ii) is self-insured and has entered into
an agreement with Washington Premera Blue and/or California Blue Cross by which
the SeaBright Plan receives third party administrative services.
165. Plaintiffs obtained an assignment of benefits from Patient 34, who
executed an assignment in the same or substantially similar form to the document
attached hereto as Exhibit A.
166. On or about November 9, 2013, Plaintiffs secured Patient 34’s consent to
contact Washington Premera Blue and/or California Blue Cross, along with the
identifying information necessary for Plaintiffs to interact with the insurer.
167. On or about November 12, 2013, Plaintiffs began providing mental health
and/or substance abuse treatment to Patient 34.
168. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Cross or Washington Premera Blue on the industry-
standard UB-04 form. Plaintiffs indicated that it was requesting that benefits be paid
to it as an assignee by inserting the letter Y in the appropriate field (box 53) each time
it submitted a claim.
169. On information and belief: California Blue Cross, Washington Premera
Blue, and/or the SeaBright Plan thereafter paid some or all of the assigned benefits to
Patient 34 instead of Plaintiffs.
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 99 of 360 Page ID #:61719
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31 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
PATIENT 35
170. On information and belief: Patient 35 was a participant in or beneficiary
of Defendant Simplot Plan during all times relevant to this complaint.
171. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the Simplot Plan either (i) is insured by Idaho Blue and/or
California Blue Cross or (ii) is self-insured and has entered into an agreement with
Idaho Blue and/or California Blue Cross by which the Simplot Plan receives third party
administrative services.
172. Plaintiffs obtained an assignment of benefits from Patient 35, who
executed an assignment in the same or substantially similar form to the documents
attached hereto as Exhibit A.
173. On or about November 21, 2013, Plaintiffs secured Patient 35’s consent
to contact Idaho Blue and/or California Blue Cross, along with the identifying
information necessary for Plaintiffs to interact with the insurer.
174. On or about November 21, 2013, Plaintiffs or their agents contacted the
Provider Hotline of Idaho Blue and/or California Blue Cross and requested details
about Patient 35’s coverage. Plaintiffs or their agents recorded the information learned
from Idaho Blue and/or California Blue Cross on the bottom of Patient 35’s Insurance
Verification Form. Plaintiffs or their agents learned from Idaho Blue and/or California
Blue Cross that Patient 35’s benefits were not assignable. Plaintiffs or their agents
recorded this by circling “No” next to the line “Assignable” on Patient 35’s Insurance
Verification Form.
175. On or about November 29, 2013, Plaintiffs began providing mental health
and/or substance abuse treatment to Patient 35.
176. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Cross or Idaho Blue on the industry-standard UB-04
form. Plaintiffs indicated that it was requesting that benefits be paid to it as an assignee
by inserting the letter Y in the appropriate field (box 53) each time it submitted a claim.
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 100 of 360 Page ID #:61720
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32 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
177. On information and belief: California Blue Cross, Idaho Blue, and/or the
Simplot Plan thereafter paid some or all of the assigned benefits to Patient 35 instead
of Plaintiffs.
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 101 of 360 Page ID #:61721
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33 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
PATIENT 36
178. On information and belief: Patient 36 was a participant in or beneficiary
of Defendant H.E. Butt Grocery Plan during all times relevant to this complaint.
179. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the H.E. Butt Grocery Plan either (i) is insured by Texas
Blue and/or California Blue Cross or (ii) is self-insured and has entered into an
agreement with Texas Blue and/or California Blue Cross by which the H.E. Butt
Grocery Plan receives third party administrative services.
180. Plaintiffs obtained an assignment of benefits from Patient 36, who
executed an assignment in the same or substantially similar form to the document
attached hereto as Exhibit A.
181. On or about December 5, 2013, Plaintiffs secured Patient 36’s consent to
contact Texas Blue and/or California Blue Cross, along with the identifying
information necessary for Plaintiffs to interact with the insurer.
182. On or about December 30, 2013, Plaintiffs began providing mental health
and/or substance abuse treatment to Patient 36.
183. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Cross or Texas Blue on the industry-standard UB-04
form. Plaintiffs indicated that it was requesting that benefits be paid to it as an assignee
by inserting the letter Y in the appropriate field (box 53) each time it submitted a claim.
184. On information and belief: California Blue Cross, Texas Blue, and/or the
H.E. Butt Grocery Plan thereafter paid some or all of the assigned benefits to Patient
36 instead of Plaintiffs.
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 102 of 360 Page ID #:61722
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34 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
PATIENT 37
185. On information and belief: Patient 37 was a participant in or beneficiary
of Defendant OraSure Tech Plan during all times relevant to this complaint.
186. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the OraSure Tech Plan either (i) is insured by Pennsylvania
Blue and/or California Blue Cross or (ii) is self-insured and has entered into an
agreement with Pennsylvania Blue and/or California Blue Cross by which the OraSure
Tech Plan receives third party administrative services.
187. Plaintiffs obtained an assignment of benefits from Patient 37, who
executed an assignment in the same or substantially similar form to the document
attached hereto as Exhibit A.
188. On or about June 17, 2014, Plaintiffs secured Patient 37’s consent to
contact Pennsylvania Blue and/or California Blue Cross, along with the identifying
information necessary for Plaintiffs to interact with the insurer.
189. On or about June 17, 2014, Plaintiffs or their agents contacted the Provider
Hotline of Pennsylvania Blue and/or California Blue Cross and requested details about
Patient 37’s coverage. Plaintiffs or their agents recorded the information learned from
Pennsylvania Blue and/or California Blue Cross on the bottom of Patient 37’s
Insurance Verification Form. Plaintiffs or their agents learned from Pennsylvania Blue
and/or California Blue Cross that Patient 37’s benefits were assignable. Plaintiffs or
their agents recorded this by circling “Yes” next to the line “Assignable” on Patient
37’s Insurance Verification Form.
190. On or about June 30, 2014, Plaintiffs began providing mental health
and/or substance abuse treatment to Patient 37.
191. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Cross or Pennsylvania Blue on the industry-standard
UB-04 form. Plaintiffs indicated that it was requesting that benefits be paid to it as an
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 103 of 360 Page ID #:61723
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35 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
assignee by inserting the letter Y in the appropriate field (box 53) each time it submitted
a claim.
192. On information and belief: California Blue Cross, Pennsylvania Blue,
and/or the OraSure Tech Plan thereafter paid some or all of the assigned benefits to
Patient 37 instead of Plaintiffs.
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 104 of 360 Page ID #:61724
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36 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
PATIENT 38
193. On information and belief: Patient 38 was a participant in or beneficiary
of Defendant FAS Plan during all times relevant to this complaint.
194. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the FAS Plan either (i) is insured by Florida Blue and/or
California Blue Cross or (ii) is self-insured and has entered into an agreement with
Florida Blue and/or California Blue Cross by which the FAS Plan receives third party
administrative services.
195. Plaintiffs obtained an assignment of benefits from Patient 38, who
executed an assignment in the same or substantially similar form to the document
attached hereto as Exhibit A.
196. On or about January 9, 2014, Plaintiffs secured Patient 38’s consent to
contact Florida Blue and/or California Blue Cross, along with the identifying
information necessary for Plaintiffs to interact with the insurer.
197. On or about January 9, 2014, Plaintiffs or their agents contacted the
Provider Hotline of Florida Blue and/or California Blue Cross and requested details
about Patient 38’s coverage. Plaintiffs or their agents recorded the information learned
from Florida Blue and/or California Blue Cross on the bottom of Patient 38’s Insurance
Verification Form. Plaintiffs or their agents learned from Florida Blue and/or
California Blue Cross that Patient 38’s benefits were not assignable. Plaintiffs or their
agents recorded this by circling “No” next to the line “Assignable” on Patient 38’s
Insurance Verification Form.
198. On or about January 13, 2014, Plaintiffs began providing mental health
and/or substance abuse treatment to Patient 38.
199. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Cross or Florida Blue on the industry-standard UB-
04 form. Plaintiffs indicated that it was requesting that benefits be paid to it as an
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 105 of 360 Page ID #:61725
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37 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
assignee by inserting the letter Y in the appropriate field (box 53) each time it submitted
a claim.
200. On information and belief: California Blue Cross, Florida Blue, and/or the
FAS Plan thereafter paid some or all of the assigned benefits to Patient 38 instead of
Plaintiffs.
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 106 of 360 Page ID #:61726
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38 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
PATIENT 40
201. On information and belief: Patient 40 was a participant in or beneficiary
of Defendant Elliott Electric Plan during all times relevant to this complaint.
202. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the Elliott Electric Plan either (i) is insured by Texas Blue
and/or California Blue Cross or (ii) is self-insured and has entered into an agreement
with Texas Blue and/or California Blue Cross by which the Elliott Electric Plan
receives third party administrative services.
203. Plaintiffs obtained an assignment of benefits from Patient 40, who
executed an assignment in the same or substantially similar form to the document
attached hereto as Exhibit B.
204. On or about September 19, 2014, Plaintiffs secured Patient 40’s consent
to contact Texas Blue and/or California Blue Cross, along with the identifying
information necessary for Plaintiffs to interact with the insurer.
205. On or about October 10, 2014, Plaintiffs began providing mental health
and/or substance abuse treatment to Patient 40.
206. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Cross or Texas Blue on the industry-standard UB-04
form. Plaintiffs indicated that it was requesting that benefits be paid to it as an assignee
by inserting the letter Y in the appropriate field (box 53) each time it submitted a claim.
207. On information and belief: California Blue Cross, Texas Blue, and/or the
Elliott Electric Plan thereafter paid some or all of the assigned benefits to Patient 40
instead of Plaintiffs.
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 107 of 360 Page ID #:61727
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39 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
PATIENT 41
208. On information and belief: Patient 41 was a participant in or beneficiary
of Defendant SAS Plan during all times relevant to this complaint.
209. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the SAS Plan either (i) is insured by North Carolina Blue
and/or California Blue Cross or (ii) is self-insured and has entered into an agreement
with North Carolina Blue and/or California Blue Cross by which the SAS Plan receives
third party administrative services.
210. Plaintiffs obtained an assignment of benefits from Patient 41, who
executed an assignment in the same or substantially similar form to the document
attached hereto as Exhibit A.
211. On or about January 7, 2014, Plaintiffs secured Patient 41’s consent to
contact North Carolina Blue and/or California Blue Cross, along with the identifying
information necessary for Plaintiffs to interact with the insurer.
212. On or about January 7, 2014, Plaintiffs or their agents contacted the
Provider Hotline of North Carolina Blue and/or California Blue Cross and requested
details about Patient 41’s coverage. Plaintiffs or their agents recorded the information
learned from North Carolina Blue and/or California Blue Cross on the bottom of
Patient 41’s Insurance Verification Form. Plaintiffs or their agents learned from North
Carolina Blue and/or California Blue Cross that Patient 41’s benefits were assignable.
Plaintiffs or their agents recorded this by circling “Yes” next to the line “Assignable”
on Patient 41’s Insurance Verification Form.
213. On or about January 8, 2014, Plaintiffs began providing mental health
and/or substance abuse treatment to Patient 41.
214. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Cross or North Carolina Blue on the industry-standard
UB-04 form. Plaintiffs indicated that it was requesting that benefits be paid to it as an
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 108 of 360 Page ID #:61728
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40 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
assignee by inserting the letter Y in the appropriate field (box 53) each time it submitted
a claim.
215. On information and belief: California Blue Cross, North Carolina Blue,
and/or the SAS Plan thereafter paid some or all of the assigned benefits to Patient 41
instead of Plaintiffs.
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 109 of 360 Page ID #:61729
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41 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
PATIENT 42
216. On information and belief: Patient 42 was a participant in or beneficiary
of Defendant Bakery Drivers Plan during all times relevant to this complaint.
217. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the Bakery Drivers Plan either (i) is insured by Minnesota
Blue and/or California Blue Cross or (ii) is self-insured and has entered into an
agreement with Minnesota Blue and/or California Blue Cross by which the Bakery
Drivers Plan receives third party administrative services.
218. Plaintiffs obtained an assignment of benefits from Patient 42, who
executed an assignment in the same or substantially similar form to the document
attached hereto as Exhibit B.
219. On or about October 28, 2014, Plaintiffs secured Patient 42’s consent to
contact Minnesota Blue and/or California Blue Cross, along with the identifying
information necessary for Plaintiffs to interact with the insurer.
220. On or about November 6, 2014, Plaintiffs began providing mental health
and/or substance abuse treatment to Patient 42.
221. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Cross or Minnesota Blue on the industry-standard
UB-04 form. Plaintiffs indicated that it was requesting that benefits be paid to it as an
assignee by inserting the letter Y in the appropriate field (box 53) each time it submitted
a claim.
222. On information and belief: California Blue Cross, Minnesota Blue, and/or
the Bakery Drivers Plan thereafter paid some or all of the assigned benefits to Patient
42 instead of Plaintiffs.
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 110 of 360 Page ID #:61730
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42 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
PATIENT 43
223. On information and belief: Patient 43 was a participant in or beneficiary
of Defendant WF Plan during all times relevant to this complaint.
224. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the WF Plan either (i) is insured by Indiana Blue and/or
California Blue Cross or (ii) is self-insured and has entered into an agreement with
Indiana Blue and/or California Blue Cross by which the WF Plan receives third party
administrative services.
225. Plaintiffs obtained an assignment of benefits from Patient 43, who
executed an assignment in the same or substantially similar form to the document
attached hereto as Exhibit A.
226. On or about May 10, 2013, Plaintiffs secured Patient 43’s consent to
contact Indiana Blue and/or California Blue Cross, along with the identifying
information necessary for Plaintiffs to interact with the insurer.
227. On or about May 10, 2013, Plaintiffs or their agents contacted the Provider
Hotline of Indiana Blue and/or California Blue Cross and requested details about
Patient 43’s coverage. Plaintiffs or their agents recorded the information learned from
Indiana Blue and/or California Blue Cross on the bottom of Patient 43’s Insurance
Verification Form. Plaintiffs or their agents learned from Indiana Blue and/or
California Blue Cross that Patient 43’s benefits were not assignable. Plaintiffs or their
agents recorded this by circling “No” next to the line “Assignable” on Patient 43’s
Insurance Verification Form.
228. On or about May 17, 2013, Plaintiffs began providing mental health
and/or substance abuse treatment to Patient 43.
229. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Cross or Indiana Blue on the industry-standard UB-
04 form. Plaintiffs indicated that it was requesting that benefits be paid to it as an
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43 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
assignee by inserting the letter Y in the appropriate field (box 53) each time it submitted
a claim.
230. On information and belief: California Blue Cross, Indiana Blue, and/or
the WF Plan thereafter paid some or all of the assigned benefits to Patient 43 instead
of Plaintiffs.
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44 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
PATIENT 44
231. On information and belief: Patient 44 was a participant in or beneficiary
of Defendant Simplot Plan during all times relevant to this complaint.
232. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the Simplot Plan either (i) is insured by Idaho Blue and/or
California Blue Cross or (ii) is self-insured and has entered into an agreement with
Idaho Blue and/or California Blue Cross by which the Simplot Plan receives third party
administrative services.
233. Plaintiffs obtained an assignment of benefits from Patient 44, who
executed an assignment in the same or substantially similar form to the document
attached hereto as Exhibit B.
234. On or about August 6, 2014, Plaintiffs secured Patient 44’s consent to
contact Idaho Blue and/or California Blue Cross, along with the identifying
information necessary for Plaintiffs to interact with the insurer.
235. On or about August 6, 2014, Plaintiffs or their agents contacted the
Provider Hotline of Idaho Blue and/or California Blue Cross and requested details
about Patient 44’s coverage. Plaintiffs or their agents recorded the information learned
from Idaho Blue and/or California Blue Cross on the bottom of Patient 44’s Insurance
Verification Form. Plaintiffs or their agents learned from Idaho Blue and/or California
Blue Cross that Patient 44’s benefits were not assignable. Plaintiffs or their agents
recorded this by circling “No” next to the line “Assignable” on Patient 44’s Insurance
Verification Form.
236. On or about August 13, 2014, Plaintiffs began providing mental health
and/or substance abuse treatment to Patient 44.
237. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Cross or Idaho Blue on the industry-standard UB-04
form. Plaintiffs indicated that it was requesting that benefits be paid to it as an assignee
by inserting the letter Y in the appropriate field (box 53) each time it submitted a claim.
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 113 of 360 Page ID #:61733
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45 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
238. On information and belief: California Blue Cross, Idaho Blue, and/or the
Simplot Plan thereafter paid some or all of the assigned benefits to Patient 44 instead
of Plaintiffs.
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 114 of 360 Page ID #:61734
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46 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
PATIENT 45
239. On information and belief: Patient 45 was a participant in or beneficiary
of Defendant American Air Plan during all times relevant to this complaint.
240. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the American Air Plan either (i) is insured by Texas Blue
and/or California Blue Cross or (ii) is self-insured and has entered into an agreement
with Texas Blue and/or California Blue Cross by which the American Air Plan receives
third party administrative services.
241. Plaintiffs obtained an assignment of benefits from Patient 45, who
executed an assignment in the same or substantially similar form to the document
attached hereto as Exhibit A.
242. On or about April 30, 2014, Plaintiffs secured Patient 45’s consent to
contact Texas Blue and/or California Blue Cross, along with the identifying
information necessary for Plaintiffs to interact with the insurer.
243. On or about April 30, 2014, Plaintiffs or their agents contacted the
Provider Hotline of Texas Blue and/or California Blue Cross and requested details
about Patient 45’s coverage. Plaintiffs or their agents recorded the information learned
from Texas Blue and/or California Blue Cross on the bottom of Patient 45’s Insurance
Verification Form. Plaintiffs or their agents learned from Texas Blue and/or California
Blue Cross that Patient 45’s benefits were not assignable. Plaintiffs or their agents
recorded this by circling “No” next to the line “Assignable” on Patient 45’s Insurance
Verification Form.
244. On or about May 8, 2014, Plaintiffs began providing mental health and/or
substance abuse treatment to Patient 45.
245. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Cross or Texas Blue on the industry-standard UB-04
form. Plaintiffs indicated that it was requesting that benefits be paid to it as an assignee
by inserting the letter Y in the appropriate field (box 53) each time it submitted a claim.
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 115 of 360 Page ID #:61735
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47 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
246. On information and belief: California Blue Cross, Texas Blue, and/or the
American Air Plan thereafter paid some or all of the assigned benefits to Patient 45
instead of Plaintiffs.
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48 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
PATIENT 47
247. On information and belief: Patient 47 was a participant in or beneficiary
of Defendant Green Tree Plan during all times relevant to this complaint.
248. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the Green Tree Plan either (i) is insured by Minnesota Blue
and/or California Blue Cross or (ii) is self-insured and has entered into an agreement
with Minnesota Blue and/or California Blue Cross by which the Green Tree Plan
receives third party administrative services.
249. Plaintiffs obtained an assignment of benefits from Patient 47, who
executed an assignment in the same or substantially similar form to the document
attached hereto as Exhibit A.
250. On or about October 3, 2013 Plaintiffs secured Patient 47’s consent to
contact Minnesota Blue and/or California Blue Cross, along with the identifying
information necessary for Plaintiffs to interact with the insurer.
251. On or about October 3, 2013 Plaintiffs or their agents contacted the
Provider Hotline of Minnesota Blue and/or California Blue Cross and requested details
about Patient 47’s coverage. Plaintiffs or their agents recorded the information learned
from Minnesota Blue and/or California Blue Cross on the bottom of Patient 47’s
Insurance Verification Form. Plaintiffs or their agents learned from Minnesota Blue
and/or California Blue Cross that Patient 47’s benefits were assignable. Plaintiffs or
their agents recorded this by circling “Yes” next to the line “Assignable” on Patient
47’s Insurance Verification Form.
252. On or about October 10, 2013, Plaintiffs began providing mental health
and/or substance abuse treatment to Patient 47.
253. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Cross or Minnesota Blue on the industry-standard
UB-04 form. Plaintiffs indicated that it was requesting that benefits be paid to it as an
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49 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
assignee by inserting the letter Y in the appropriate field (box 53) each time it submitted
a claim.
254. On information and belief: California Blue Cross, Minnesota Blue, and/or
the Green Tree Plan thereafter paid some or all of the assigned benefits to Patient 47
instead of Plaintiffs.
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 118 of 360 Page ID #:61738
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50 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
PATIENT 48
255. On information and belief: Patient 48 was a participant in or beneficiary
of Defendant Martin Marietta Plan during all times relevant to this complaint.
256. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the Martin Marietta Plan either (i) is insured by North
Carolina Blue and/or California Blue Cross or (ii) is self-insured and has entered into
an agreement with North Carolina Blue and/or California Blue Cross by which the
Martin Marietta Plan receives third party administrative services.
257. Plaintiffs obtained an assignment of benefits from Patient 48, who
executed an assignment in the same or substantially similar form to the document
attached hereto as Exhibit A.
258. On or about May 6, 2013, Plaintiffs secured Patient 48’s consent to
contact North Carolina Blue and/or California Blue Cross, along with the identifying
information necessary for Plaintiffs to interact with the insurer.
259. On or about May 7, 2013, Plaintiffs began providing mental health and/or
substance abuse treatment to Patient 48.
260. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Cross or North Carolina Blue on the industry-standard
UB-04 form. Plaintiffs indicated that it was requesting that benefits be paid to it as an
assignee by inserting the letter Y in the appropriate field (box 53) each time it submitted
a claim.
261. On information and belief: California Blue Cross, North Carolina Blue,
and/or the Martin Marietta Plan thereafter paid some or all of the assigned benefits to
Patient 48 instead of Plaintiffs.
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51 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
PATIENT 49
262. On information and belief: Patient 49 was a participant in or beneficiary
of Defendant Xerox Plan during all times relevant to this complaint.
263. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the Xerox Plan either (i) is insured by Texas Blue and/or
California Blue Cross or (ii) is self-insured and has entered into an agreement with
Texas Blue and/or California Blue Cross by which the Xerox Plan receives third party
administrative services.
264. Plaintiffs obtained an assignment of benefits from Patient 49, who
executed an assignment in the same or substantially similar form to the document
attached hereto as Exhibit A.
265. On or about March 7, 2013, Plaintiffs secured Patient 49’s consent to
contact Texas Blue and/or California Blue Cross, along with the identifying
information necessary for Plaintiffs to interact with the insurer.
266. On or about March 11, 2013, Plaintiffs began providing mental health
and/or substance abuse treatment to Patient 49.
267. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Cross or Texas Blue on the industry-standard UB-04
form. Plaintiffs indicated that it was requesting that benefits be paid to it as an assignee
by inserting the letter Y in the appropriate field (box 53) each time it submitted a claim.
268. On information and belief: California Blue Cross, Texas Blue, and/or the
Xerox Plan thereafter paid some or all of the assigned benefits to Patient 49 instead of
Plaintiffs.
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52 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
PATIENT 50
269. On information and belief: Patient 50 was a participant in or beneficiary
of Defendant Ernst & Young Plan during all times relevant to this complaint.
270. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the Ernst & Young Plan either (i) is insured by New York
Empire Blue and/or California Blue Cross or (ii) is self-insured and has entered into an
agreement with New York Empire Blue and/or California Blue Cross by which the
Ernst & Young Plan receives third party administrative services.
271. Plaintiffs obtained an assignment of benefits from Patient 50, who
executed an assignment in the same or substantially similar form to the document
attached hereto as Exhibit A.
272. On or about February 22, 2014, Plaintiffs secured Patient 50’s consent to
contact New York Empire Blue and/or California Blue Cross, along with the
identifying information necessary for Plaintiffs to interact with the insurer.
273. On or about February 22, 2014, Plaintiffs or their agents contacted the
Provider Hotline of New York Empire Blue and/or California Blue Cross and requested
details about Patient 50’s coverage. Plaintiffs or their agents recorded the information
learned from New York Empire Blue and/or California Blue Cross on the bottom of
Patient 50’s Insurance Verification Form. Plaintiffs or their agents learned from New
York Empire Blue and/or California Blue Cross that Patient 50’s benefits were not
assignable. Plaintiffs or their agents recorded this by circling “No” next to the line
“Assignable” on Patient 50’s Insurance Verification Form.
274. On or about February 25, 2014, Plaintiffs began providing mental health
and/or substance abuse treatment to Patient 50.
275. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Cross or New York Empire Blue on the industry-
standard UB-04 form. Plaintiffs indicated that it was requesting that benefits be paid
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53 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
to it as an assignee by inserting the letter Y in the appropriate field (box 53) each time
it submitted a claim.
276. On information and belief: California Blue Cross, New York Empire
Blue, and/or the Ernst & Young Plan thereafter paid some or all of the assigned benefits
to Patient 50 instead of Plaintiffs.
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54 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
PATIENT 51
277. On information and belief: Patient 51 was a participant in or beneficiary
of Defendant Owens-Illinois Plan during all times relevant to this complaint.
278. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the Owens-Illinois Plan either (i) is insured by Ohio Blue
and/or California Blue Cross or (ii) is self-insured and has entered into an agreement
with Ohio Blue and/or California Blue Cross by which the Owens-Illinois Plan receives
third party administrative services.
279. Plaintiffs obtained an assignment of benefits from Patient 51, who
executed an assignment in the same or substantially similar form to the document
attached hereto as Exhibit A.
280. On or about January 9, 2014, Plaintiffs secured Patient 51’s consent to
contact Ohio Blue and/or California Blue Cross, along with the identifying information
necessary for Plaintiffs to interact with the insurer.
281. On or about January 16, 2014, Plaintiffs began providing mental health
and/or substance abuse treatment to Patient 51.
282. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Cross or Ohio Blue on the industry-standard UB-04
form. Plaintiffs indicated that it was requesting that benefits be paid to it as an assignee
by inserting the letter Y in the appropriate field (box 53) each time it submitted a claim.
283. On information and belief: California Blue Cross, Ohio Blue, and/or the
Owens-Illinois Plan thereafter paid some or all of the assigned benefits to Patient 51
instead of Plaintiffs.
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55 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
PATIENT 52
284. On information and belief: Patient 52 was a participant in or beneficiary
of Defendant Huntington Plan during all times relevant to this complaint.
285. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the Huntington Plan either (i) is insured by Ohio Blue and/or
California Blue Cross or (ii) is self-insured and has entered into an agreement with
Ohio Blue and/or California Blue Cross by which the Huntington Plan receives third
party administrative services.
286. Plaintiffs obtained an assignment of benefits from Patient 52, who
executed an assignment in the same or substantially similar form to the document
attached hereto as Exhibit A.
287. On or about October 23, 2013, Plaintiffs secured Patient 52’s consent to
contact Ohio Blue and/or California Blue Cross, along with the identifying information
necessary for Plaintiffs to interact with the insurer.
288. On or about October 28, 2013, Plaintiffs or their agents contacted the
Provider Hotline of Ohio Blue and/or California Blue Cross and requested details about
Patient 52’s coverage. Plaintiffs or their agents recorded the information learned from
Ohio Blue and/or California Blue Cross on the bottom of Patient 52’s Insurance
Verification Form. Plaintiffs or their agents learned from Ohio Blue and/or California
Blue Cross that Patient 52’s benefits were not assignable. Plaintiffs or their agents
recorded this by circling “No” next to the line “Assignable” on Patient 52’s Insurance
Verification Form.
289. On or about November 1, 2013, Plaintiffs began providing mental health
and/or substance abuse treatment to Patient 52.
290. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Cross or Ohio Blue on the industry-standard UB-04
form. Plaintiffs indicated that it was requesting that benefits be paid to it as an assignee
by inserting the letter Y in the appropriate field (box 53) each time it submitted a claim.
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 124 of 360 Page ID #:61744
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56 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
291. On information and belief: California Blue Cross, Ohio Blue, and/or the
Huntington Plan thereafter paid some or all of the assigned benefits to Patient 52
instead of Plaintiffs.
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57 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
PATIENT 53
292. On information and belief: Patient 53 was a participant in or beneficiary
of Defendant Live Nation Plan during all times relevant to this complaint.
293. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the Live Nation Plan either (i) is insured by California Blue
Cross or (ii) is self-insured and has entered into an agreement with California Blue
Cross by which the Live Nation Plan receives third party administrative services.
294. Plaintiffs obtained an assignment of benefits from Patient 53, who
executed an assignment in the same or substantially similar form to the document
attached hereto as Exhibit B.
295. On or about March 3, 2014, Plaintiffs secured Patient 53’s consent to
contact California Blue Cross, along with the identifying information necessary for
Plaintiffs to interact with the insurer.
296. On or about March 3, 2014, Plaintiffs began providing mental health
and/or substance abuse treatment to Patient 53.
297. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Cross on the industry-standard UB-04 form. Plaintiffs
indicated that it was requesting that benefits be paid to it as an assignee by inserting
the letter Y in the appropriate field (box 53) each time it submitted a claim.
298. On information and belief: California Blue Cross and/or the Live Nation
Plan thereafter paid some or all of the assigned benefits to Patient 53 instead of
Plaintiffs.
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 126 of 360 Page ID #:61746
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58 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
PATIENT 54
299. On information and belief: Patient 54 was a participant in or beneficiary
of Defendant Consolidated Graphics Plan during all times relevant to this complaint.
300. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the Consolidated Graphics Plan either (i) is insured by Texas
Blue and/or California Blue Cross or (ii) is self-insured and has entered into an
agreement with Texas Blue and/or California Blue Cross by which the Consolidated
Graphics Plan receives third party administrative services.
301. Plaintiffs obtained an assignment of benefits from Patient 54, who
executed an assignment in the same or substantially similar form to the document
attached hereto as Exhibit A.
302. On or about June 24, 2013, Plaintiffs secured Patient 54’s consent to
contact Texas Blue and/or California Blue Cross, along with the identifying
information necessary for Plaintiffs to interact with the insurer.
303. On or about June 25, 2013, Plaintiffs began providing mental health
and/or substance abuse treatment to Patient 54.
304. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Cross or Texas Blue on the industry-standard UB-04
form. Plaintiffs indicated that it was requesting that benefits be paid to it as an assignee
by inserting the letter Y in the appropriate field (box 53) each time it submitted a claim.
305. On information and belief: California Blue Cross, Texas Blue, and/or the
Consolidated Graphics Plan thereafter paid some or all of the assigned benefits to
Patient 54 instead of Plaintiffs.
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 127 of 360 Page ID #:61747
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59 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
PATIENT 55
306. On information and belief: Patient 55 was a participant in or beneficiary
of Defendant WebMD Plan during all times relevant to this complaint.
307. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the WebMD Plan either (i) is insured by New Jersey Blue
and/or California Blue Cross or (ii) is self-insured and has entered into an agreement
with New Jersey Blue and/or California Blue Cross by which the WebMD Plan
receives third party administrative services.
308. Plaintiffs obtained an assignment of benefits from Patient 55, who
executed an assignment in the same or substantially similar form to the document
attached hereto as Exhibit B.
309. On or about September 25, 2014, Plaintiffs secured Patient 55’s consent
to contact New Jersey Blue and/or California Blue Cross, along with the identifying
information necessary for Plaintiffs to interact with the insurer.
310. On or about September 25, 2014, Plaintiffs or their agents contacted the
Provider Hotline of New Jersey Blue and/or California Blue Cross and requested
details about Patient 55’s coverage. Plaintiffs or their agents recorded the information
learned from New Jersey Blue and/or California Blue Cross on the bottom of Patient
55’s Insurance Verification Form. Plaintiffs or their agents learned from New Jersey
Blue and/or California Blue Cross that Patient 55’s benefits were assignable. Plaintiffs
or their agents recorded this by circling “Yes” next to the line “Assignable” on Patient
55’s Insurance Verification Form.
311. On or about October 1, 2014, Plaintiffs began providing mental health
and/or substance abuse treatment to Patient 55.
312. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Cross or New Jersey Blue on the industry-standard
UB-04 form. Plaintiffs indicated that it was requesting that benefits be paid to it as an
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 128 of 360 Page ID #:61748
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60 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
assignee by inserting the letter Y in the appropriate field (box 53) each time it submitted
a claim.
313. On information and belief: California Blue Cross, New Jersey Blue,
and/or the WebMD Plan thereafter paid some or all of the assigned benefits to Patient
55 instead of Plaintiffs.
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 129 of 360 Page ID #:61749
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61 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
PATIENT 56
314. On information and belief: Patient 56 was a participant in or beneficiary
of Defendant ViaSat Plan during all times relevant to this complaint.
315. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the ViaSat Plan either (i) is insured by California Blue Cross
or (ii) is self-insured and has entered into an agreement with California Blue Cross by
which the ViaSat Plan receives third party administrative services.
316. Plaintiffs obtained an assignment of benefits from Patient 56, who
executed an assignment in the same or substantially similar form to the document
attached hereto as Exhibit A.
317. On or about October 3, 2012, Plaintiffs secured Patient 56’s consent to
contact California Blue Cross, along with the identifying information necessary for
Plaintiffs to interact with the insurer.
318. On or about October 8, 2012, Plaintiffs began providing mental health
and/or substance abuse treatment to Patient 56.
319. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Cross on the industry-standard UB-04 form. Plaintiffs
indicated that it was requesting that benefits be paid to it as an assignee by inserting
the letter Y in the appropriate field (box 53) each time it submitted a claim.
320. On information and belief: California Blue Cross and/or the ViaSat Plan
thereafter paid some or all of the assigned benefits to Patient 56 instead of Plaintiffs.
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 130 of 360 Page ID #:61750
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62 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
PATIENT 57
321. On information and belief: Patient 57 was a participant in or beneficiary
of the ConAgra Foods, Inc. Welfare Benefit WRAP Plan (the “ConAgra Plan”) during
all times relevant to this complaint.
322. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the ConAgra Plan either (i) is insured by Nebraska Blue
and/or California Blue Cross or (ii) is self-insured and has entered into an agreement
with Nebraska Blue and/or California Blue Cross by which the ConAgra Plan receives
third party administrative services.
323. Plaintiffs obtained an assignment of benefits from Patient 57, who
executed an assignment in the same or substantially similar form to the document
attached hereto as Exhibit A.
324. On or about December 31, 2013, Plaintiffs secured Patient 57’s consent
to contact Nebraska Blue and/or California Blue Cross, along with the identifying
information necessary for Plaintiffs to interact with the insurer.
325. On or about January 9, 2014, Plaintiffs began providing mental health
and/or substance abuse treatment to Patient 57.
326. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Cross or Nebraska Blue on the industry-standard UB-
04 form. Plaintiffs indicated that it was requesting that benefits be paid to it as an
assignee by inserting the letter Y in the appropriate field (box 53) each time it submitted
a claim.
327. On information and belief: California Blue Cross, Nebraska Blue, and/or
ConAgra Plan thereafter paid some or all of the assigned benefits to Patient 57 instead
of Plaintiffs.
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 131 of 360 Page ID #:61751
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63 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
PATIENT 60
328. On information and belief: Patient 60 was a participant in or beneficiary
of Defendant Novartis Plan during all times relevant to this complaint.
329. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the Novartis Plan either (i) is insured by New Jersey Blue
and/or California Blue Cross or (ii) is self-insured and has entered into an agreement
with New Jersey Blue and/or California Blue Cross by which the Novartis Plan
receives third party administrative services.
330. Plaintiffs obtained an assignment of benefits from Patient 60, who
executed an assignment in the same or substantially similar form to the document
attached hereto as Exhibit A.
331. On or about July 10, 2014, Plaintiffs secured Patient 60’s consent to
contact New Jersey Blue and/or California Blue Cross, along with the identifying
information necessary for Plaintiffs to interact with the insurer.
332. On or about July 14, 2014, Plaintiffs began providing mental health and/or
substance abuse treatment to Patient 60.
333. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Cross or New Jersey Blue on the industry-standard
UB-04 form. Plaintiffs indicated that it was requesting that benefits be paid to it as an
assignee by inserting the letter Y in the appropriate field (box 53) each time it submitted
a claim.
334. On information and belief: California Blue Cross, New Jersey Blue,
and/or Novartis Plan thereafter paid some or all of the assigned benefits to Patient 60
instead of Plaintiffs.
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 132 of 360 Page ID #:61752
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64 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
PATIENT 61
335. On information and belief: Patient 61 was a participant in or beneficiary
of Defendant Globecast Plan during all times relevant to this complaint.
336. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the Globecast Plan either (i) is insured by California Blue
Cross or (ii) is self-insured and has entered into an agreement with California Blue
Cross by which the Globecast Plan receives third party administrative services.
337. Plaintiffs obtained an assignment of benefits from Patient 61, who
executed an assignment in the same or substantially similar form to the document
attached hereto as Exhibit A.
338. On or about July 2, 2013, Plaintiffs secured Patient 61’s consent to contact
California Blue Cross, along with the identifying information necessary for Plaintiffs
to interact with the insurer.
339. On or about July 2, 2013, Plaintiffs or their agents contacted the Provider
Hotline of California Blue Cross and requested details about Patient 61’s coverage.
Plaintiffs or their agents recorded the information learned from California Blue Cross
on the bottom of Patient 61’s Insurance Verification Form. Plaintiffs or their agents
learned from California Blue Cross that Patient 61’s benefits were assignable. Plaintiffs
or their agents recorded this by circling “Yes” next to the line “Assignable” on Patient
61’s Insurance Verification Form.
340. On or about July 3, 2013, Plaintiffs began providing mental health and/or
substance abuse treatment to Patient 61.
341. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Cross on the industry-standard UB-04 form. Plaintiffs
indicated that it was requesting that benefits be paid to it as an assignee by inserting
the letter Y in the appropriate field (box 53) each time it submitted a claim.
342. On information and belief: California Blue Cross and/or Globecast Plan
thereafter paid some or all of the assigned benefits to Patient 61 instead of Plaintiffs.
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 133 of 360 Page ID #:61753
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65 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
PATIENT 67
343. On information and belief: Patient 67 was a participant in or beneficiary
of Defendant Verizon Plan during all times relevant to this complaint.
344. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the Verizon Plan either (i) is insured by Ohio Blue and/or
California Blue Cross or (ii) is self-insured and has entered into an agreement with
Ohio Blue and/or California Blue Cross by which the Verizon Plan receives third party
administrative services.
345. Plaintiffs obtained an assignment of benefits from Patient 67, who
executed an assignment in the same or substantially similar form to the document
attached hereto as Exhibit A.
346. On or about May 12, 2014, Plaintiffs secured Patient 67’s consent to
contact Ohio Blue and/or California Blue Cross, along with the identifying information
necessary for Plaintiffs to interact with the insurer.
347. On or about May 12, 2014, Plaintiffs or their agents contacted the Provider
Hotline of Ohio Blue and/or California Blue Cross and requested details about Patient
67’s coverage. Plaintiffs or their agents recorded the information learned from Ohio
Blue and/or California Blue Cross on the bottom of Patient 67’s Insurance Verification
Form. Plaintiffs or their agents learned from Ohio Blue and/or California Blue Cross
that Patient 67’s benefits were assignable. Plaintiffs or their agents recorded this by
circling “Yes” next to the line “Assignable” on Patient 67’s Insurance Verification
Form.
348. On or about May 22, 2014, Plaintiffs began providing mental health
and/or substance abuse treatment to Patient 67.
349. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Cross or Ohio Blue on the industry-standard UB-04
form. Plaintiffs indicated that it was requesting that benefits be paid to it as an assignee
by inserting the letter Y in the appropriate field (box 53) each time it submitted a claim.
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 134 of 360 Page ID #:61754
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66 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
350. On information and belief: California Blue Cross, Ohio Blue, and/or
Verizon Plan thereafter paid some or all of the assigned benefits to Patient 67 instead
of Plaintiffs.
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 135 of 360 Page ID #:61755
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67 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
PATIENT 68
351. On information and belief: Patient 68 was a participant in or beneficiary
of Defendant 3M Plan during all times relevant to this complaint.
352. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the 3M Plan either (i) is insured by Minnesota Blue and/or
California Blue Cross or (ii) is self-insured and has entered into an agreement with
Minnesota Blue and/or California Blue Cross by which the 3M Plan receives third party
administrative services.
353. Plaintiffs obtained an assignment of benefits from Patient 68, who
executed an assignment in the same or substantially similar form to the document
attached hereto as Exhibit A.
354. On or about January 15, 2013, Plaintiffs secured Patient 68’s consent to
contact Minnesota Blue and/or California Blue Cross, along with the identifying
information necessary for Plaintiffs to interact with the insurer.
355. On or about January 15, 2013, Plaintiffs or their agents contacted the
Provider Hotline of Minnesota Blue and/or California Blue Cross and requested details
about Patient 68’s coverage. Plaintiffs or their agents recorded the information learned
from Minnesota Blue and/or California Blue Con the bottom of Patient 68’s Insurance
Verification Form. Plaintiffs or their agents learned from Minnesota Blue and/or
California Blue Cross that Patient 68’s benefits were assignable. Plaintiffs or their
agents recorded this by circling “Yes” next to the line “Assignable” on Patient 68’s
Insurance Verification Form.
356. On or about February 20, 2013, Plaintiffs began providing mental health
and/or substance abuse treatment to Patient 68.
357. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Cross or Minnesota Blue on the industry-standard
UB-04 form. Plaintiffs indicated that it was requesting that benefits be paid to it as an
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 136 of 360 Page ID #:61756
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68 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
assignee by inserting the letter Y in the appropriate field (box 53) each time it submitted
a claim.
358. On information and belief: California Blue Cross, Minnesota Blue, and/or
3M Plan thereafter paid some or all of the assigned benefits to Patient 68 instead of
Plaintiffs.
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 137 of 360 Page ID #:61757
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69 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
PATIENT 69
359. On information and belief: Patient 69 was a participant in or beneficiary
of Defendant Covance Plan during all times relevant to this complaint.
360. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the Covance Plan either (i) is insured by New Jersey Blue
and/or California Blue Cross or (ii) is self-insured and has entered into an agreement
with New Jersey Blue and/or California Blue Cross by which the Covance Plan
receives third party administrative services.
361. Plaintiffs obtained an assignment of benefits from Patient 69, who
executed an assignment in the same or substantially similar form to the document
attached hereto as Exhibit A.
362. On or about February 26, 2014, Plaintiffs secured Patient 69’s consent to
contact New Jersey Blue and/or California Blue Cross, along with the identifying
information necessary for Plaintiffs to interact with the insurer.
363. On or about February 26, 2014, Plaintiffs or their agents contacted the
Provider Hotline of New Jersey Blue and/or California Blue Cross and requested
details about Patient 69’s coverage. Plaintiffs or their agents recorded the information
learned from New Jersey Blue and/or California Blue Cross on the bottom of Patient
69’s Insurance Verification Form. Plaintiffs or their agents learned from New Jersey
Blue and/or California Blue Cross that Patient 69’s benefits were assignable. Plaintiffs
or their agents recorded this by circling “Yes” next to the line “Assignable” on Patient
69’s Insurance Verification Form.
364. On or about March 4, 2014, Plaintiffs began providing mental health
and/or substance abuse treatment to Patient 69.
365. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Cross or New Jersey Blue on the industry-standard
UB-04 form. Plaintiffs indicated that it was requesting that benefits be paid to it as an
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 138 of 360 Page ID #:61758
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70 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
assignee by inserting the letter Y in the appropriate field (box 53) each time it submitted
a claim.
366. On information and belief: California Blue Cross, New Jersey Blue,
and/or Covance Plan thereafter paid some or all of the assigned benefits to Patient 69
instead of Plaintiffs.
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 139 of 360 Page ID #:61759
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71 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
PATIENT 70
367. On information and belief: Patient 70 was a participant in or beneficiary
of Defendant Vertical Plan during all times relevant to this complaint.
368. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the Vertical Plan either (i) is insured by CareFirst District
of Columbia Blue and/or California Blue Cross or (ii) is self-insured and has entered
into an agreement with CareFirst District of Columbia Blue and/or California Blue
Cross by which the Vertical Plan receives third party administrative services.
369. Plaintiffs obtained an assignment of benefits from Patient 70, who
executed an assignment in the same or substantially similar form to the document
attached hereto as Exhibit A.
370. On or about October 4, 2013, Plaintiffs secured Patient 70’s consent to
contact CareFirst District of Columbia Blue and/or California Blue Cross, along with
the identifying information necessary for Plaintiffs to interact with the insurer.
371. On or about October 12, 2013, Plaintiffs began providing mental health
and/or substance abuse treatment to Patient 70.
372. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Cross or CareFirst District of Columbia Blue on the
industry-standard UB-04 form. Plaintiffs indicated that it was requesting that benefits
be paid to it as an assignee by inserting the letter Y in the appropriate field (box 53)
each time it submitted a claim.
373. On information and belief: California Blue Cross, CareFirst District of
Columbia Blue, and/or Vertical Plan thereafter paid some or all of the assigned benefits
to Patient 70 instead of Plaintiffs.
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 140 of 360 Page ID #:61760
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72 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
PATIENT 71
374. On information and belief: Patient 71 was a participant in or beneficiary
of Defendant Bard Plan during all times relevant to this complaint.
375. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the Bard Plan either (i) is insured by New Jersey Blue and/or
California Blue Cross or (ii) is self-insured and has entered into an agreement with
New Jersey Blue and/or California Blue Cross by which the Bard Plan receives third
party administrative services.
376. Plaintiffs obtained an assignment of benefits from Patient 71, who
executed an assignment in the same or substantially similar form to the document
attached hereto as Exhibit A.
377. On or about June 17, 2014, Plaintiffs secured Patient 71’s consent to
contact New Jersey Blue and/or California Blue Cross, along with the identifying
information necessary for Plaintiffs to interact with the insurer.
378. On or about June 17, 2014, Plaintiffs or their agents contacted the Provider
Hotline of New Jersey Blue and/or California Blue Cross and requested details about
Patient 71’s coverage. Plaintiffs or their agents recorded the information learned from
New Jersey Blue and/or California Blue Cross on the bottom of Patient 71’s Insurance
Verification Form. Plaintiffs or their agents learned from New Jersey Blue and/or
California Blue Cross that Patient 71’s benefits were assignable. Plaintiffs or their
agents recorded this by circling “Yes” next to the line “Assignable” on Patient 71’s
Insurance Verification Form.
379. On or about June 18, 2014, Plaintiffs began providing mental health
and/or substance abuse treatment to Patient 71.
380. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Cross or New Jersey Blue on the industry-standard
UB-04 form. Plaintiffs indicated that it was requesting that benefits be paid to it as an
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 141 of 360 Page ID #:61761
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73 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
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assignee by inserting the letter Y in the appropriate field (box 53) each time it submitted
a claim.
381. On information and belief: California Blue Cross, New Jersey Blue,
and/or Bard Plan thereafter paid some or all of the assigned benefits to Patient 71
instead of Plaintiffs.
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74 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
PATIENT 72
382. On information and belief: Patient 72 was a participant in or beneficiary
of Defendant Eaton Plan during all times relevant to this complaint.
383. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the Eaton Plan either (i) is insured by New York Anthem
Blue and/or California Blue Cross or (ii) is self-insured and has entered into an
agreement with New York Anthem Blue and/or California Blue Cross by which the
Eaton Plan receives third party administrative services.
384. Plaintiffs obtained an assignment of benefits from Patient 72, who
executed an assignment in the same or substantially similar form to the document
attached hereto as Exhibit A.
385. On or about May 3, 2013, Plaintiffs secured Patient 72’s consent to
contact New York Anthem Blue and/or California Blue Cross, along with the
identifying information necessary for Plaintiffs to interact with the insurer.
386. On or about May 3, 2013, Plaintiffs or their agents contacted the Provider
Hotline of New York Anthem Blue and/or California Blue Cross and requested details
about Patient 72’s coverage. Plaintiffs or their agents recorded the information learned
from New York Anthem Blue and/or California Blue Cross on the bottom of Patient
72’s Insurance Verification Form. Plaintiffs or their agents learned from New York
Anthem Blue and/or California Blue Cross that Patient 72’s benefits were assignable.
Plaintiffs or their agents recorded this by circling “Yes” next to the line “Assignable”
on Patient 72’s Insurance Verification Form.
387. On or about May 6, 2013, Plaintiffs began providing mental health and/or
substance abuse treatment to Patient 72.
388. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Cross or New York Anthem Blue on the industry-
standard UB-04 form. Plaintiffs indicated that it was requesting that benefits be paid
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 143 of 360 Page ID #:61763
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75 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
to it as an assignee by inserting the letter Y in the appropriate field (box 53) each time
it submitted a claim.
389. On information and belief: California Blue Cross, New York Anthem
Blue, and/or Eaton Plan thereafter paid some or all of the assigned benefits to Patient
72 instead of Plaintiffs.
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 144 of 360 Page ID #:61764
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76 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
PATIENT 73
390. On information and belief: Patient 73 was a participant in or beneficiary
of Defendant Baxter Plan during all times relevant to this complaint.
391. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the Baxter Plan either (i) is insured by Illinois Blue and/or
California Blue Cross or (ii) is self-insured and has entered into an agreement with
Illinois Blue and/or California Blue Cross by which the Baxter Plan receives third party
administrative services.
392. Plaintiffs obtained an assignment of benefits from Patient 73, who
executed an assignment in the same or substantially similar form to the document
attached hereto as Exhibit A.
393. On or about May 9, 2014, Plaintiffs secured Patient 73’s consent to
contact Illinois Blue and/or California Blue Cross, along with the identifying
information necessary for Plaintiffs to interact with the insurer.
394. On or about May 14, 2014, Plaintiffs began providing mental health
and/or substance abuse treatment to Patient 73.
395. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Cross or Illinois Blue on the industry-standard UB-
04 form. Plaintiffs indicated that it was requesting that benefits be paid to it as an
assignee by inserting the letter Y in the appropriate field (box 53) each time it submitted
a claim.
396. On information and belief: California Blue Cross, Illinois Blue, and/or
Baxter Plan thereafter paid some or all of the assigned benefits to Patient 73 instead of
Plaintiffs.
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 145 of 360 Page ID #:61765
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77 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
PATIENT 74
397. On information and belief: Patient 74 was a participant in or beneficiary
of Defendant Alltech Plan during all times relevant to this complaint.
398. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the Alltech Plan either (i) is insured by Kentucky Blue
and/or California Blue Cross or (ii) is self-insured and has entered into an agreement
with Kentucky Blue and/or California Blue Cross by which the Alltech Plan receives
third party administrative services.
399. Plaintiffs obtained an assignment of benefits from Patient 74, who
executed an assignment in the same or substantially similar form to the document
attached hereto as Exhibit B.
400. On or about July 30, 2014, Plaintiffs secured Patient 74’s consent to
contact Kentucky Blue and/or California Blue Cross, along with the identifying
information necessary for Plaintiffs to interact with the insurer.
401. On or about August 7, 2014, Plaintiffs began providing mental health
and/or substance abuse treatment to Patient 74.
402. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Cross or Kentucky Blue on the industry-standard UB-
04 form. Plaintiffs indicated that it was requesting that benefits be paid to it as an
assignee by inserting the letter Y in the appropriate field (box 53) each time it submitted
a claim.
403. On information and belief: California Blue Cross, Kentucky Blue, and/or
the Alltech Plan thereafter paid some or all of the assigned benefits to Patient 74 instead
of Plaintiffs.
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 146 of 360 Page ID #:61766
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78 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
PATIENT 76
404. On information and belief: Patient 76 was a participant in or beneficiary
of an unknown ERISA-governed welfare plan during all times relevant to this
complaint.
405. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the unknown plan either (i) is insured by Tennessee Blue
and/or California Blue Cross or (ii) is self-insured and has entered into an agreement
with Tennessee Blue and/or California Blue Cross by which the unknown plan receives
third party administrative services.
406. Plaintiffs obtained an assignment of benefits from Patient 76, who
executed an assignment in the same or substantially similar form to the document
attached hereto as Exhibit A.
407. On or about August 14, 2013, Plaintiffs secured Patient 76’s consent to
contact Tennessee Blue and/or California Blue Cross, along with the identifying
information necessary for Plaintiffs to interact with the insurer.
408. On or about September 4, 2013, Plaintiffs began providing mental health
and/or substance abuse treatment to Patient 76.
409. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Cross or Tennessee Blue on the industry-standard
UB-04 form. Plaintiffs indicated that it was requesting that benefits be paid to it as an
assignee by inserting the letter Y in the appropriate field (box 53) each time it submitted
a claim.
410. On information and belief: California Blue Cross, Tennessee Blue, and/or
the unknown plan thereafter paid some or all of the assigned benefits to Patient 76
instead of Plaintiffs.
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79 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
PATIENT 78
411. On information and belief: Patient 78 was a participant in or beneficiary
of the Old Republic National Title Group Welfare Plan (the “Old Republic Plan”)
during all times relevant to this complaint.
412. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the Old Republic Plan either (i) is insured by Minnesota
Blue and/or California Blue Cross or (ii) is self-insured and has entered into an
agreement with Minnesota Blue and/or California Blue Cross by which the Old
Republic Plan receives third party administrative services.
413. Plaintiffs obtained an assignment of benefits from Patient 78, who
executed an assignment in the same or substantially similar form to the document
attached hereto as Exhibit A.
414. On or about May 28, 2013, Plaintiffs secured Patient 78’s consent to
contact Minnesota Blue and/or California Blue Cross, along with the identifying
information necessary for Plaintiffs to interact with the insurer.
415. On or about June 3, 2013, Plaintiffs began providing mental health and/or
substance abuse treatment to Patient 78.
416. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Cross or Minnesota Blue on the industry-standard
UB-04 form. Plaintiffs indicated that it was requesting that benefits be paid to it as an
assignee by inserting the letter Y in the appropriate field (box 53) each time it submitted
a claim.
417. On information and belief: California Blue Cross, Minnesota Blue, and/or
the Old Republic Plan thereafter paid some or all of the assigned benefits to Patient 78
instead of Plaintiffs.
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80 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
PATIENT 81
418. On information and belief: Patient 81 was a participant in or beneficiary
of an unknown ERISA-governed welfare plan during all times relevant to this
complaint.
419. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the unknown plan either (i) is insured by California Blue
Shield or (ii) is self-insured and has entered into an agreement with California Blue
Shield by which the unknown plan receives third party administrative services.
420. Plaintiffs obtained an assignment of benefits from Patient 81, who
executed an assignment in the same or substantially similar form to the document
attached hereto as Exhibit B.
421. On or about September 3, 2014, Plaintiffs secured Patient 81’s consent to
contact California Blue Shield, along with the identifying information necessary for
Plaintiffs to interact with the insurer.
422. On or about September 3, 2014, Plaintiffs or their agents contacted the
Provider Hotline of California Blue Shield and requested details about Patient 81’s
coverage. Plaintiffs or their agents recorded the information learned from California
Blue Shield on the bottom of Patient 81’s Insurance Verification Form. Plaintiffs or
their agents learned from California Blue Shield that Patient 81’s benefits were not
assignable. Plaintiffs or their agents recorded this by circling “No” next to the line
“Assignable” on Patient 81’s Insurance Verification Form.
423. On or about September 9, 2014, Plaintiffs began providing mental health
and/or substance abuse treatment to Patient 81.
424. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Shield on the industry-standard UB-04 form.
Plaintiffs indicated that it was requesting that benefits be paid to it as an assignee by
inserting the letter Y in the appropriate field (box 53) each time it submitted a claim.
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81 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
425. On information and belief: California Blue Shield and/or the unknown
plan thereafter paid some or all of the assigned benefits to Patient 81 instead of
Plaintiffs.
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82 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
PATIENT 83
426. On information and belief: Patient 83 was a participant in or beneficiary
of the Hilliard Corporation Group Health Plan (the “Hilliard Corp. Plan”) during all
times relevant to this complaint.
427. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the Hilliard Corp. Plan either (i) is insured by New York
Excellus Blue and/or California Blue Cross or (ii) is self-insured and has entered into
an agreement with New York Excellus Blue and/or California Blue Cross by which the
Hilliard Corp. Plan receives third party administrative services.
428. Plaintiffs obtained an assignment of benefits from Patient 83, who
executed an assignment in the same or substantially similar form to the document
attached hereto as Exhibit B.
429. On or about January 5, 2015, Plaintiffs secured Patient 83’s consent to
contact New York Excellus Blue and/or California Blue Cross, along with the
identifying information necessary for Plaintiffs to interact with the insurer.
430. On or about January 5, 2015, Plaintiffs or their agents contacted the
Provider Hotline of New York Excellus Blue and/or California Blue Cross and
requested details about Patient 83’s coverage. Plaintiffs or their agents recorded the
information learned from New York Excellus Blue and/or California Blue Cross on the
bottom of Patient 83’s Insurance Verification Form. Plaintiffs or their agents learned
from New York Excellus Blue and/or California Blue Cross that Patient 83’s benefits
were assignable. Plaintiffs or their agents recorded this by circling “Yes” next to the
line “Assignable” on Patient 83’s Insurance Verification Form.
431. On or about January 9, 2015, Plaintiffs began providing mental health
and/or substance abuse treatment to Patient 83.
432. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Cross or New York Excellus Blue on the industry-
standard UB-04 form. Plaintiffs indicated that it was requesting that benefits be paid
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 151 of 360 Page ID #:61771
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83 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
to it as an assignee by inserting the letter Y in the appropriate field (box 53) each time
it submitted a claim.
433. On information and belief: California Blue Cross, New York Excellus
Blue, and/or the Hilliard Corp. Plan thereafter paid some or all of the assigned benefits
to Patient 83 instead of Plaintiffs.
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 152 of 360 Page ID #:61772
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84 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
PATIENT 84
434. On information and belief: Patient 84 was a participant in or beneficiary
of an unknown ERISA-governed welfare plan during all times relevant to this
complaint.
435. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the unknown plan either (i) is insured by North Carolina
Blue and/or California Blue Cross or (ii) is self-insured and has entered into an
agreement with North Carolina Blue and/or California Blue Cross by which the
unknown plan receives third party administrative services.
436. Plaintiffs obtained an assignment of benefits from Patient 84, who
executed an assignment in the same or substantially similar form to the document
attached hereto as Exhibit A.
437. On or about November 12, 2012, Plaintiffs secured Patient 84’s consent
to contact North Carolina Blue and/or California Blue Cross, along with the identifying
information necessary for Plaintiffs to interact with the insurer.
438. On or about November 12, 2012, Plaintiffs or their agents contacted the
Provider Hotline of North Carolina Blue and/or California Blue Cross and requested
details about Patient 84’s coverage. Plaintiffs or their agents recorded the information
learned from North Carolina Blue and/or California Blue Cross on the bottom of
Patient 84’s Insurance Verification Form. Plaintiffs or their agents learned from North
Carolina Blue and/or California Blue Cross that Patient 84’s benefits were not
assignable. Plaintiffs or their agents recorded this by circling “No” next to the line
“Assignable” on Patient 84’s Insurance Verification Form.
439. On or about November 15, 2012, Plaintiffs began providing mental health
and/or substance abuse treatment to Patient 84.
440. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Cross or North Carolina Blue on the industry-standard
UB-04 form. Plaintiffs indicated that it was requesting that benefits be paid to it as an
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85 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
assignee by inserting the letter Y in the appropriate field (box 53) each time it submitted
a claim.
441. On information and belief: California Blue Cross, North Carolina Blue,
and/or the unknown plan thereafter paid some or all of the assigned benefits to Patient
84 instead of Plaintiffs.
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 154 of 360 Page ID #:61774
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86 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
PATIENT 85
442. On information and belief: Patient 85 was a participant in or beneficiary
of the Eureka Realty Partners, Inc. Plan (the “Eureka Plan”) during all times relevant
to this complaint.
443. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the Eureka Plan either (i) is insured by California Blue
Cross or (ii) is self-insured and has entered into an agreement with California Blue
Cross by which the Eureka Plan receives third party administrative services.
444. Plaintiffs obtained an assignment of benefits from Patient 85, who
executed an assignment in the same or substantially similar form to the document
attached hereto as Exhibit A
445. On or about May 28, 2013, Plaintiffs secured Patient 85’s consent to
contact California Blue Cross, along with the identifying information necessary for
Plaintiffs to interact with the insurer.
446. On or about May 28, 2013, Plaintiffs or their agents contacted the Provider
Hotline of California Blue Cross and requested details about Patient 85’s coverage.
Plaintiffs or their agents recorded the information learned from California Blue Cross
on the bottom of Patient 85’s Insurance Verification Form. Plaintiffs or their agents
learned from California Blue Cross that Patient 85’s benefits were assignable.
Plaintiffs or their agents recorded this by circling “Yes” next to the line “Assignable”
on Patient 85’s Insurance Verification Form.
447. On or about June 6, 2013, Plaintiffs began providing mental health and/or
substance abuse treatment to Patient 85.
448. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Cross on the industry-standard UB-04 form.
Plaintiffs indicated that it was requesting that benefits be paid to it as an assignee by
inserting the letter Y in the appropriate field (box 53) each time it submitted a claim.
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 155 of 360 Page ID #:61775
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87 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
449. On information and belief: California Blue Cross and/or the Eureka Plan
thereafter paid some or all of the assigned benefits to Patient 85 instead of Plaintiffs.
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 156 of 360 Page ID #:61776
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88 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
PATIENT 86
450. On information and belief: Patient 86 was a participant in or beneficiary
of the U.S. Battery Corp. Plan (the “Battery Plan”) during all times relevant to this
complaint.
451. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the Battery Plan either (i) is insured by California Blue
Cross or (ii) is self-insured and has entered into an agreement with California Blue
Cross by which the Battery Plan receives third party administrative services.
452. Plaintiffs obtained an assignment of benefits from Patient 86, who
executed an assignment in the same or substantially similar form to the document
attached hereto as Exhibit A.
453. On or about December 6, 2012, Plaintiffs secured Patient 86’s consent to
contact California Blue Cross, along with the identifying information necessary for
Plaintiffs to interact with the insurer.
454. On or about December 6, 2012, Plaintiffs or their agents contacted the
Provider Hotline of California Blue Cross and requested details about Patient 86’s
coverage. Plaintiffs or their agents recorded the information learned from California
Blue Cross on the bottom of Patient 86’s Insurance Verification Form. Plaintiffs or
their agents learned from California Blue Cross that Patient 86’s benefits were
assignable. Plaintiffs or their agents recorded this by circling “Yes” next to the line
“Assignable” on Patient 86’s Insurance Verification Form.
455. On or about December 13, 2012, Plaintiffs began providing mental health
and/or substance abuse treatment to Patient 86.
456. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Cross on the industry-standard UB-04 form. Plaintiffs
indicated that it was requesting that benefits be paid to it as an assignee by inserting
the letter Y in the appropriate field (box 53) each time it submitted a claim.
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 157 of 360 Page ID #:61777
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89 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
457. On information and belief: California Blue Cross and/or the Battery Plan
thereafter paid some or all of the assigned benefits to Patient 86 instead of Plaintiffs.
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 158 of 360 Page ID #:61778
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90 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
PATIENT 87
458. On information and belief: Patient 87 was a participant in or beneficiary
of an unknown ERISA-governed welfare plan during all times relevant to this
complaint.
459. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the unknown plan either (i) is insured by Louisiana HMO
Blue and/or California Blue Cross or (ii) is self-insured and has entered into an
agreement with Louisiana HMO Blue and/or California Blue Cross by which the
unknown plan receives third party administrative services.
460. Plaintiffs obtained an assignment of benefits from Patient 87, who
executed an assignment in the same or substantially similar form to the document
attached hereto as Exhibit A.
461. On or about September 11, 2012, Plaintiffs secured Patient 87’s consent
to contact Louisiana HMO Blue and/or California Blue Cross, along with the
identifying information necessary for Plaintiffs to interact with the insurer.
462. On or about September 25, 2012, Plaintiffs began providing mental health
and/or substance abuse treatment to Patient 87.
463. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Cross or Louisiana HMO Blue on the industry-
standard UB-04 form. Plaintiffs indicated that it was requesting that benefits be paid
to it as an assignee by inserting the letter Y in the appropriate field (box 53) each time
it submitted a claim.
464. On information and belief: California Blue Cross, Louisiana HMO Blue,
and/or the unknown plan thereafter paid some or all of the assigned benefits to Patient
87 instead of Plaintiffs.
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 159 of 360 Page ID #:61779
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91 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
PATIENT 90
465. On information and belief: Patient 90 was a participant in or beneficiary
of the Active Network, Inc. Plan (the “Active Network Plan”) during all times relevant
to this complaint.
466. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the Active Network Plan either (i) is insured by California
Blue Cross or (ii) is self-insured and has entered into an agreement with California
Blue Cross by which the Active Network Plan receives third party administrative
services.
467. Plaintiffs obtained an assignment of benefits from Patient 90, who
executed an assignment in the same or substantially similar form to the document
attached hereto as Exhibit A.
468. On or about November 1, 2012, Plaintiffs secured Patient 90’s consent to
contact California Blue Cross, along with the identifying information necessary for
Plaintiffs to interact with the insurer.
469. On or about November 1, 2012, Plaintiffs or their agents contacted the
Provider Hotline of California Blue Cross and requested details about Patient 90’s
coverage. Plaintiffs or their agents recorded the information learned from California
Blue Cross on the bottom of Patient 90’s Insurance Verification Form. Plaintiffs or
their agents learned from California Blue Cross that Patient 90’s benefits were not
assignable. Plaintiffs or their agents recorded this by circling “No” next to the line
“Assignable” on Patient 90’s Insurance Verification Form.
470. On or about November 2, 2012, Plaintiffs began providing mental health
and/or substance abuse treatment to Patient 90.
471. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Cross on the industry-standard UB-04 form. Plaintiffs
indicated that it was requesting that benefits be paid to it as an assignee by inserting
the letter Y in the appropriate field (box 53) each time it submitted a claim.
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 160 of 360 Page ID #:61780
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92 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
472. On information and belief: California Blue Cross and/or the Active
Network Plan thereafter paid some or all of the assigned benefits to Patient 90 instead
of Plaintiffs.
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 161 of 360 Page ID #:61781
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93 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
PATIENT 91
473. On information and belief: Patient 91 was a participant in or beneficiary
of Great Falls College – Montana State University Group Health Plan (the “Great Falls
College Plan”) during all times relevant to this complaint.
474. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the Great Falls College Plan either (i) is insured by Montana
Blue and/or California Blue Shield or (ii) is self-insured and has entered into an
agreement with Montana Blue and/or California Blue Shield by which the Great Falls
College Plan receives third party administrative services.
475. Plaintiffs obtained an assignment of benefits from Patient 91, who
executed an assignment in the same or substantially similar form to the document
attached hereto as Exhibit A.
476. On or about June 25, 2013, Plaintiffs secured Patient 91’s consent to
contact Montana Blue and/or California Blue Shield, along with the identifying
information necessary for Plaintiffs to interact with the insurer.
477. On or about June 26, 2013, Plaintiffs began providing mental health
and/or substance abuse treatment to Patient 91.
478. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Shield or Montana Blue on the industry-standard UB-
04 form. Plaintiffs indicated that it was requesting that benefits be paid to it as an
assignee by inserting the letter Y in the appropriate field (box 53) each time it submitted
a claim.
479. On information and belief: California Blue Shield, Montana Blue, and/or
the Great Falls College Plan thereafter paid some or all of the assigned benefits to
Patient 91 instead of Plaintiffs.
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 162 of 360 Page ID #:61782
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94 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
PATIENT 92
480. On information and belief: Patient 92 was a participant in or beneficiary
of an unknown ERISA-governed welfare plan during all times relevant to this
complaint.
481. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the unknown plan either (i) is insured by CareFirst Maryland
Blue and/or California Blue Shield or (ii) is self-insured and has entered into an
agreement with CareFirst Maryland Blue and/or California Blue Shield by which the
unknown plan receives third party administrative services.
482. Plaintiffs obtained an assignment of benefits from Patient 92, who
executed an assignment in the same or substantially similar form to the document
attached hereto as Exhibit B.
483. On or about October 27, 2014, Plaintiffs secured Patient 92’s consent to
contact CareFirst Maryland Blue and/or California Blue Shield, along with the
identifying information necessary for Plaintiffs to interact with the insurer.
484. On or about October 29, 2014, Plaintiffs began providing mental health
and/or substance abuse treatment to Patient 92.
485. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Shield or CareFirst Maryland Blue on the industry-
standard UB-04 form. Plaintiffs indicated that it was requesting that benefits be paid
to it as an assignee by inserting the letter Y in the appropriate field (box 53) each time
it submitted a claim.
486. On information and belief: California Blue Shield, CareFirst Maryland
Blue, and/or the unknown plan thereafter paid some or all of the assigned benefits to
Patient 92 instead of Plaintiffs.
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 163 of 360 Page ID #:61783
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95 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
PATIENT 93
487. On information and belief: Patient 93 was a participant in or beneficiary
of the Perlectric, Inc. Group Plan (the “Perlectric Plan”) during all times relevant to
this complaint.
488. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the Perlectric Plan either (i) is insured by California Blue
Cross, CareFirst Maryland Blue and/or CareFirst District of Columbia Blue or (ii) is
self-insured and has entered into an agreement with California Blue Cross, CareFirst
Maryland Blue and/or CareFirst District of Columbia Blue by which the Perlectric Plan
receives third party administrative services.
489. Plaintiffs obtained an assignment of benefits from Patient 93, who
executed an assignment in the same or substantially similar form to the document
attached hereto as Exhibit B.
490. On or about September 22, 2014, Plaintiffs secured Patient 93’s consent
to contact California Blue Cross, CareFirst Maryland Blue and/or CareFirst District of
Columbia Blue, along with the identifying information necessary for Plaintiffs to
interact with the insurer.
491. On or about September 22, 2014, Plaintiffs or their agents contacted the
Provider Hotline of California Blue Cross, CareFirst Maryland Blue and/or CareFirst
District of Columbia Blue and requested details about Patient 93’s coverage. Plaintiffs
or their agents recorded the information learned from California Blue Cross, CareFirst
Maryland Blue and/or CareFirst District of Columbia Blue on the bottom of Patient
93’s Insurance Verification Form. Plaintiffs or their agents learned from California
Blue Cross, CareFirst Maryland Blue and/or CareFirst District of Columbia Blue that
Patient 93’s benefits were assignable. Plaintiffs or their agents recorded this by circling
“Yes” next to the line “Assignable” on Patient 93’s Insurance Verification Form.
492. On or about September 22, 2014, Plaintiffs began providing mental health
and/or substance abuse treatment to Patient 93.
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 164 of 360 Page ID #:61784
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96 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
493. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Cross, CareFirst Maryland Blue and/or CareFirst
District of Columbia Blue on the industry-standard UB-04 form. Plaintiffs indicated
that it was requesting that benefits be paid to it as an assignee by inserting the letter Y
in the appropriate field (box 53) each time it submitted a claim.
494. On information and belief: California Blue Cross, CareFirst Maryland
Blue, CareFirst District of Columbia Blue, and/or the Perlectric Plan thereafter paid
some or all of the assigned benefits to Patient 93 instead of Plaintiffs.
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 165 of 360 Page ID #:61785
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97 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
PATIENT 96
495. On information and belief: Patient 96 was a participant in or beneficiary
of Defendant CHS Plan during all times relevant to this complaint.
496. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the CHS Plan either (i) is insured by Florida Blue and/or
California Blue Cross or (ii) is self-insured and has entered into an agreement with
Florida Blue and/or California Blue Cross by which the CHS Plan receives third party
administrative services.
497. Plaintiffs obtained an assignment of benefits from Patient 96, who
executed an assignment in the same or substantially similar form to the document
attached hereto as Exhibit B.
498. On or about March 18, 2015, Plaintiffs secured Patient 96’s consent to
contact Florida Blue and/or California Blue Cross, along with the identifying
information necessary for Plaintiffs to interact with the insurer.
499. On or about April 3, 2015, Plaintiffs began providing mental health and/or
substance abuse treatment to Patient 96.
500. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Cross or Florida Blue on the industry-standard UB-
04 form. Plaintiffs indicated that it was requesting that benefits be paid to it as an
assignee by inserting the letter Y in the appropriate field (box 53) each time it submitted
a claim.
501. On information and belief: California Blue Cross, Florida Blue, and/or the
CHS Plan thereafter paid some or all of the assigned benefits to Patient 96 instead of
Plaintiffs.
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 166 of 360 Page ID #:61786
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98 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
PATIENT 99
502. On information and belief: Patient 99 was a participant in or beneficiary
of Defendant Master Builders Plan during all times relevant to this complaint.
503. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the Master Builders Plan either (i) is insured by Washington
Regence Blue and/or California Blue Cross or (ii) is self-insured and has entered into
an agreement with Washington Regence Blue and/or California Blue Cross by which
the Master Builders Plan receives third party administrative services.
504. Plaintiffs obtained an assignment of benefits from Patient 99, who
executed an assignment in the same or substantially similar form to the document
attached hereto as Exhibit B.
505. On or about January 21, 2015, Plaintiffs secured Patient 99’s consent to
contact Washington Regence Blue and/or California Blue Cross, along with the
identifying information necessary for Plaintiffs to interact with the insurer.
506. On or about January 21, 2015, Plaintiffs or their agents contacted the
Provider Hotline of Washington Regence Blue and/or California Blue Cross and
requested details about Patient 99’s coverage. Plaintiffs or their agents recorded the
information learned from Washington Regence Blue and/or California Blue Cross on
the bottom of Patient 99’s Insurance Verification Form. Plaintiffs or their agents
learned from Washington Regence Blue and/or California Blue Cross that Patient 99’s
benefits were assignable. Plaintiffs or their agents recorded this by circling “Yes” next
to the line “Assignable” on Patient 99’s Insurance Verification Form.
507. On or about February 11, 2015, Plaintiffs began providing mental health
and/or substance abuse treatment to Patient 99.
508. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Cross or Washington Regence Blue on the industry-
standard UB-04 form. Plaintiffs indicated that it was requesting that benefits be paid
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 167 of 360 Page ID #:61787
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99 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
to it as an assignee by inserting the letter Y in the appropriate field (box 53) each time
it submitted a claim.
509. On information and belief: California Blue Cross, Washington Regence
Blue, and/or the Master Builders Plan thereafter paid some or all of the assigned
benefits to Patient 99 instead of Plaintiffs.
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 168 of 360 Page ID #:61788
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100 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
PATIENT 100
510. On information and belief: Patient 100 was a participant in or beneficiary
of an unknown ERISA-governed welfare plan during all times relevant to this
complaint.
511. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the unknown plan either (i) is insured by Wisconsin Blue
and/or California Blue Cross or (ii) is self-insured and has entered into an agreement
with Wisconsin Blue and/or California Blue Cross by which the unknown plan receives
third party administrative services.
512. Plaintiffs obtained an assignment of benefits from Patient 100, who
executed an assignment in the same or substantially similar form to the document
attached hereto as Exhibit B.
513. On or about February 20, 2015, Plaintiffs secured Patient 100’s consent
to contact Wisconsin Blue and/or California Blue Cross, along with the identifying
information necessary for Plaintiffs to interact with the insurer.
514. On or about February 20, 2015, Plaintiffs or their agents contacted the
Provider Hotline of Wisconsin Blue and/or California Blue Cross and requested details
about Patient 100’s coverage. Plaintiffs or their agents recorded the information
learned from Wisconsin Blue and/or California Blue Cross on the bottom of Patient
100’s Insurance Verification Form. Plaintiffs or their agents learned from Wisconsin
Blue and/or California Blue Cross that Patient 100’s benefits were not assignable.
Plaintiffs or their agents recorded this by circling “No” next to the line “Assignable”
on Patient 100’s Insurance Verification Form.
515. On or about March 2, 2015, Plaintiffs began providing mental health
and/or substance abuse treatment to Patient 100.
516. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Cross or Wisconsin Blue on the industry-standard
UB-04 form. Plaintiffs indicated that it was requesting that benefits be paid to it as an
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 169 of 360 Page ID #:61789
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101 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
assignee by inserting the letter Y in the appropriate field (box 53) each time it submitted
a claim.
517. On information and belief: California Blue Cross, Wisconsin Blue, and/or
the unknown plan thereafter paid some or all of the assigned benefits to Patient 100
instead of Plaintiffs.
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 170 of 360 Page ID #:61790
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102 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
PATIENT 102
518. On information and belief: Patient 102 was a participant in or beneficiary
of the Samson Investment Company Group Medical Plan (the “Samson Plan”) during
all times relevant to this complaint.
519. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the Samson Plan either (i) is insured by Oklahoma Blue
and/or California Blue Cross or (ii) is self-insured and has entered into an agreement
with Oklahoma Blue and/or California Blue Cross by which the Samson Plan receives
third party administrative services.
520. Plaintiffs obtained an assignment of benefits from Patient 102, who
executed an assignment in the same or substantially similar form to the document
attached hereto as Exhibit B.
521. On or about February 25, 2015, Plaintiffs secured Patient 102’s consent
to contact Oklahoma Blue and/or California Blue Cross, along with the identifying
information necessary for Plaintiffs to interact with the insurer.
522. On or about February 28, 2015, Plaintiffs began providing mental health
and/or substance abuse treatment to Patient 102.
523. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Cross or Oklahoma Blue on the industry-standard
UB-04 form. Plaintiffs indicated that it was requesting that benefits be paid to it as an
assignee by inserting the letter Y in the appropriate field (box 53) each time it submitted
a claim.
524. On information and belief: California Blue Cross, Oklahoma Blue, and/or
the Samson Plan thereafter paid some or all of the assigned benefits to Patient 102
instead of Plaintiffs.
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 171 of 360 Page ID #:61791
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103 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
PATIENT 103
525. On information and belief: Patient 103 was a participant in or beneficiary
of an unknown ERISA-governed welfare plan during all times relevant to this
complaint.
526. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the unknown plan either (i) is insured by California Blue
Cross or (ii) is self-insured and has entered into an agreement with California Blue
Cross by which the unknown plan receives third party administrative services.
527. Plaintiffs obtained an assignment of benefits from Patient 103, who
executed an assignment in the same or substantially similar form to the document
attached hereto as Exhibit A.
528. On or about November 27, 2012, Plaintiffs secured Patient 103’s consent
to contact California Blue Cross, along with the identifying information necessary for
Plaintiffs to interact with the insurer.
529. On or about November 27, 2012, Plaintiffs or their agents contacted the
Provider Hotline of California Blue Cross and requested details about Patient 103’s
coverage. Plaintiffs or their agents recorded the information learned from California
Blue Cross on the bottom of Patient 103’s Insurance Verification Form. Plaintiffs or
their agents learned from California Blue Cross that Patient 103’s benefits were not
assignable. Plaintiffs or their agents recorded this by circling “No” next to the line
“Assignable” on Patient 103’s Insurance Verification Form.
530. On or about December 3, 2012, Plaintiffs began providing mental health
and/or substance abuse treatment to Patient 103.
531. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Cross on the industry-standard UB-04 form. Plaintiffs
indicated that it was requesting that benefits be paid to it as an assignee by inserting
the letter Y in the appropriate field (box 53) each time it submitted a claim.
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 172 of 360 Page ID #:61792
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104 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
532. On information and belief: California Blue Cross and/or the unknown
plan thereafter paid some or all of the assigned benefits to Patient 103 instead of
Plaintiffs.
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 173 of 360 Page ID #:61793
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105 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
PATIENT 105
533. On information and belief: Patient 105 was a participant in or beneficiary
of the Health & Welfare Plan for the Oregon-Washington Carpenters-Employers
Health & Welfare Trust Fund (the “Oregon-Washington Carpenters Plan”) during all
times relevant to this complaint.
534. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the Oregon-Washington Carpenters Plan either (i) is insured
by Oregon Blue and/or California Blue Cross or (ii) is self-insured and has entered into
an agreement with Oregon Blue and/or California Blue Cross by which the Oregon-
Washington Carpenters Plan receives third party administrative services.
535. Plaintiffs obtained an assignment of benefits from Patient 105, who
executed an assignment in the same or substantially similar form to the document
attached hereto as Exhibit B.
536. On or about September 5, 2014, Plaintiffs secured Patient 105’s consent
to contact Oregon Blue and/or California Blue Cross, along with the identifying
information necessary for Plaintiffs to interact with the insurer.
537. On or about September 5, 2014, Plaintiffs or their agents contacted the
Provider Hotline of Oregon Blue and/or California Blue Cross and requested details
about Patient 105’s coverage. Plaintiffs or their agents recorded the information
learned from Oregon Blue and/or California Blue Cross on the bottom of Patient 105’s
Insurance Verification Form. Plaintiffs or their agents learned from Oregon Blue
and/or California Blue Cross that Patient 105’s benefits were assignable. Plaintiffs or
their agents recorded this by circling “Yes” next to the line “Assignable” on Patient
105’s Insurance Verification Form.
538. On or about September 16, 2014, Plaintiffs began providing mental health
and/or substance abuse treatment to Patient 105.
539. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Cross or Oregon Blue on the industry-standard UB-
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 174 of 360 Page ID #:61794
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106 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
04 form. Plaintiffs indicated that it was requesting that benefits be paid to it as an
assignee by inserting the letter Y in the appropriate field (box 53) each time it submitted
a claim.
540. On information and belief: California Blue Cross, Oregon Blue, and/or
the Oregon-Washington Carpenters Plan thereafter paid some or all of the assigned
benefits to Patient 105 instead of Plaintiffs.
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 175 of 360 Page ID #:61795
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107 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
PATIENT 106
541. On information and belief: Patient 106 was a participant in or beneficiary
in the City Of Bradenton Group Health Plan (the “Bradenton Plan”) during all times
relevant to this complaint.
542. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the Bradenton Plan either (i) is insured by Florida Blue
and/or California Blue Cross or (ii) is self-insured and has entered into an agreement
with Florida Blue and/or California Blue Cross by which the Bradenton Plan receives
third party administrative services.
543. Plaintiffs obtained an assignment of benefits from Patient 106, who
executed an assignment in the same or substantially similar form to the document
attached hereto as Exhibit B.
544. On or about March 11, 2015, Plaintiffs secured Patient 106’s consent to
contact Florida Blue and/or California Blue Cross, along with the identifying
information necessary for Plaintiffs to interact with the insurer.
545. On or about April 2, 2015, Plaintiffs began providing mental health and/or
substance abuse treatment to Patient 106.
546. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Cross or Florida Blue on the industry-standard UB-
04 form. Plaintiffs indicated that it was requesting that benefits be paid to it as an
assignee by inserting the letter Y in the appropriate field (box 53) each time it submitted
a claim.
547. On information and belief: California Blue Cross, Florida Blue, and/or the
Bradenton Plan thereafter paid some or all of the assigned benefits to Patient 106
instead of Plaintiffs.
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 176 of 360 Page ID #:61796
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108 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
PATIENT 107
548. On information and belief: Patient 107 was a participant in or beneficiary
of an unknown ERISA-governed welfare plan during all times relevant to this
complaint.
549. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the unknown plan either (i) is insured by New Jersey Blue
and/or California Blue Cross or (ii) is self-insured and has entered into an agreement
with New Jersey Blue and/or California Blue Cross by which the unknown plan
receives third party administrative services.
550. Plaintiffs obtained an assignment of benefits from Patient 107, who
executed an assignment in the same or substantially similar form to the document
attached hereto as Exhibit B.
551. On or about January 27, 2015, Plaintiffs secured Patient 107’s consent to
contact New Jersey Blue and/or California Blue Cross, along with the identifying
information necessary for Plaintiffs to interact with the insurer.
552. On or about February 4, 2015, Plaintiffs began providing mental health
and/or substance abuse treatment to Patient 107.
553. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Cross or New Jersey Blue on the industry-standard
UB-04 form. Plaintiffs indicated that it was requesting that benefits be paid to it as an
assignee by inserting the letter Y in the appropriate field (box 53) each time it submitted
a claim.
554. On information and belief: California Blue Cross, New Jersey Blue,
and/or the unknown plan thereafter paid some or all of the assigned benefits to Patient
107 instead of Plaintiffs.
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 177 of 360 Page ID #:61797
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109 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
PATIENT 108
555. On information and belief: Patient 108 was a participant in or beneficiary
of the Berry Plastics Corporation Employee Benefit Plan (the “Berry Plan”) during all
times relevant to this complaint.
556. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the Berry Plan either (i) is insured by Indiana Blue and/or
California Blue Cross or (ii) is self-insured and has entered into an agreement with
Indiana Blue and/or California Blue Cross by which the Berry Plan receives third party
administrative services.
557. Plaintiffs obtained an assignment of benefits from Patient 108, who
executed an assignment in the same or substantially similar form to the document
attached hereto as Exhibit B.
558. On or about February 23, 2015, Plaintiffs secured Patient 108’s consent
to contact Indiana Blue and/or California Blue Cross, along with the identifying
information necessary for Plaintiffs to interact with the insurer.
559. On or about February 23, 2015, Plaintiffs or their agents contacted the
Provider Hotline of Indiana Blue and/or California Blue Cross and requested details
about Patient 108’s coverage. Plaintiffs or their agents recorded the information
learned from Indiana Blue and/or California Blue Cross on the bottom of Patient 108’s
Insurance Verification Form. Plaintiffs or their agents learned from Indiana Blue
and/or California Blue Cross that Patient 108’s benefits were not assignable. Plaintiffs
or their agents recorded this by circling “No” next to the line “Assignable” on Patient
108’s Insurance Verification Form.
560. On or about March 12, 2015, Plaintiffs began providing mental health
and/or substance abuse treatment to Patient 108.
561. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Cross or Indiana Blue on the industry-standard UB-
04 form. Plaintiffs indicated that it was requesting that benefits be paid to it as an
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 178 of 360 Page ID #:61798
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110 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
assignee by inserting the letter Y in the appropriate field (box 53) each time it submitted
a claim.
562. On information and belief: California Blue Cross, Indiana Blue, and/or
the Berry Plan thereafter paid some or all of the assigned benefits to Patient 108 instead
of Plaintiffs.
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 179 of 360 Page ID #:61799
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111 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
PATIENT 110
563. On information and belief: Patient 110 was a participant in or beneficiary
of the TOPA Benefits Plan (the “TOPA Plan”) during all times relevant to this
complaint.
564. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the TOPA Plan either (i) is insured by California Blue Cross
or (ii) is self-insured and has entered into an agreement with California Blue Cross by
which the TOPA Plan receives third party administrative services.
565. Plaintiffs obtained an assignment of benefits from Patient 110, who
executed an assignment in the same or substantially similar form to the document
attached hereto as Exhibit B.
566. On or about April 9, 2015, Plaintiffs secured Patient 110’s consent to
contact California Blue Cross, along with the identifying information necessary for
Plaintiffs to interact with the insurer.
567. On or about April 9, 2015, Plaintiffs began providing mental health and/or
substance abuse treatment to Patient 110.
568. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Cross on the industry-standard UB-04 form. Plaintiffs
indicated that it was requesting that benefits be paid to it as an assignee by inserting
the letter Y in the appropriate field (box 53) each time it submitted a claim.
569. On information and belief: California Blue Cross and/or the TOPA Plan
thereafter paid some or all of the assigned benefits to Patient 110 instead of Plaintiffs.
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 180 of 360 Page ID #:61800
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112 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
PATIENT 114
570. On information and belief: Patient 114 was a participant in or beneficiary
of an unknown ERISA-governed welfare plan during all times relevant to this
complaint.
571. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the unknown plan either (i) is insured by Alabama Blue
and/or California Blue Cross or (ii) is self-insured and has entered into an agreement
with Alabama Blue and/or California Blue Cross by which the unknown plan receives
third party administrative services.
572. Plaintiffs obtained an assignment of benefits from Patient 114, who
executed an assignment in the same or substantially similar form to the document
attached hereto as Exhibit B.
573. On or about January 27, 2015, Plaintiffs secured Patient 114’s consent to
contact Alabama Blue and/or California Blue Cross, along with the identifying
information necessary for Plaintiffs to interact with the insurer.
574. On or about January 28, 2015, Plaintiffs began providing mental health
and/or substance abuse treatment to Patient 114.
575. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Cross or Alabama Blue on the industry-standard UB-
04 form. Plaintiffs indicated that it was requesting that benefits be paid to it as an
assignee by inserting the letter Y in the appropriate field (box 53) each time it submitted
a claim.
576. On information and belief: California Blue Cross, Alabama Blue, and/or
the unknown plan thereafter paid some or all of the assigned benefits to Patient 114
instead of Plaintiffs.
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 181 of 360 Page ID #:61801
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113 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
PATIENT 115
577. On information and belief: Patient 115 was a participant in or beneficiary
of the Aegis Living Welfare Benefits Plan (the “Aegis Plan”) and the EmpRes
Healthcare Management LLC Group Health Plan (the “EmpRes Plan”) during all times
relevant to this complaint.
578. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the Aegis Plan and EmpRes Plan either (i) were insured by
Washington Regence Blue, Washington Premera Blue, and/or California Blue Cross
or (ii) were self-insured and have entered into an agreement with Washington Regence
Blue, Washington Premera Blue, and/or California Blue Cross by which the Aegis Plan
and EmpRes Plan receive third party administrative services.
579. Plaintiffs obtained an assignment of benefits from Patient 115, who
executed an assignment in the same or substantially similar form to the document
attached hereto as Exhibit B.
580. On or about October 1, 2014, Plaintiffs secured Patient 115’s consent to
contact Washington Regence Blue, Washington Premera Blue, and/or California Blue
Cross, along with the identifying information necessary for Plaintiffs to interact with
the insurers.
581. On or about November 4, 2014, Plaintiffs began providing mental health
and/or substance abuse treatment to Patient 115.
582. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Cross, Washington Regence Blue or Washington
Premera Blue on the industry-standard UB-04 form. Plaintiffs indicated that it was
requesting that benefits be paid to it as an assignee by inserting the letter Y in the
appropriate field (box 53) each time it submitted a claim.
583. On information and belief: California Blue Cross, Washington Regence
Blue, Washington Premera Blue, the Aegis Plan, and/or the EmpRes Plan thereafter
paid some or all of the assigned benefits to Patient 115 instead of Plaintiffs.
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 182 of 360 Page ID #:61802
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114 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
PATIENT 117
584. On information and belief: Patient 117 was a participant in or beneficiary
of the TheLaundryList.com, Inc. Group Health Plan (the “Laundry List Plan”) during
all times relevant to this complaint.
585. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the Laundry List Plan either (i) is insured by California Blue
Cross or (ii) is self-insured and has entered into an agreement with California Blue
Cross by which the Laundry List Plan receives third party administrative services.
586. Plaintiffs obtained an assignment of benefits from Patient 117, who
executed an assignment in the same or substantially similar form to the document
attached hereto as Exhibit B.
587. On or about November 6, 2014, Plaintiffs secured Patient 117’s consent
to contact California Blue Cross, along with the identifying information necessary for
Plaintiffs to interact with the insurer.
588. On or about November 11, 2014, Plaintiffs began providing mental health
and/or substance abuse treatment to Patient 117.
589. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Cross on the industry-standard UB-04 form. Plaintiffs
indicated that it was requesting that benefits be paid to it as an assignee by inserting
the letter Y in the appropriate field (box 53) each time it submitted a claim.
590. On information and belief: California Blue Cross and/or the Laundry List
Plan thereafter paid some or all of the assigned benefits to Patient 117 instead of
Plaintiffs.
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 183 of 360 Page ID #:61803
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115 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
PATIENT 121
591. On information and belief: Patient 121 was a participant in or beneficiary
of the U.S. Xpress Enterprises, Inc. Employee Benefit Plan (the “U.S. Xpress Plan”)
during all times relevant to this complaint.
592. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the U.S. Xpress Plan either (i) is insured by Tennessee Blue
and/or California Blue Cross or (ii) is self-insured and has entered into an agreement
with Tennessee Blue and/or California Blue Cross by which the U.S. Xpress Plan
receives third party administrative services.
593. Plaintiffs obtained an assignment of benefits from Patient 121, who
executed an assignment in the same or substantially similar form to the document
attached hereto as Exhibit B.
594. On or about March 24, 2015, Plaintiffs secured Patient 121’s consent to
contact Tennessee Blue and/or California Blue Cross, along with the identifying
information necessary for Plaintiffs to interact with the insurer.
595. On or about April 2, 2015, Plaintiffs began providing mental health and/or
substance abuse treatment to Patient 121.
596. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Cross or Tennessee Blue on the industry-standard
UB-04 form. Plaintiffs indicated that it was requesting that benefits be paid to it as an
assignee by inserting the letter Y in the appropriate field (box 53) each time it submitted
a claim.
597. On information and belief: California Blue Cross, Tennessee Blue, and/or
the U.S. Xpress Plan thereafter paid some or all of the assigned benefits to Patient 121
instead of Plaintiffs.
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 184 of 360 Page ID #:61804
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116 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
PATIENT 122
598. On information and belief: Patient 122 was a participant in or beneficiary
of the Marvell Semiconductor, Inc. Group Health Plan (the “Marvell Plan”) during all
times relevant to this complaint.
599. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the Marvell Plan either (i) is insured by California Blue
Cross or (ii) is self-insured and has entered into an agreement with California Blue
Cross by which the Marvell Plan receives third party administrative services.
600. Plaintiffs obtained an assignment of benefits from Patient 122, who
executed an assignment in the same or substantially similar form to the document
attached hereto as Exhibit B.
601. On or about December 15, 2014, Plaintiffs secured Patient 122’s consent
to contact California Blue Cross, along with the identifying information necessary for
Plaintiffs to interact with the insurer.
602. On or about December 15, 2014, Plaintiffs or their agents contacted the
Provider Hotline of California Blue Cross and requested details about Patient 122’s
coverage. Plaintiffs or their agents recorded the information learned from California
Blue Cross on the bottom of Patient 122’s Insurance Verification Form. Plaintiffs or
their agents learned from California Blue Cross that Patient 122’s benefits were not
assignable. Plaintiffs or their agents recorded this by circling “No” next to the line
“Assignable” on Patient 122’s Insurance Verification Form.
603. On or about December 23, 2014, Plaintiffs began providing mental health
and/or substance abuse treatment to Patient 122.
604. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Cross on the industry-standard UB-04 form. Plaintiffs
indicated that it was requesting that benefits be paid to it as an assignee by inserting
the letter Y in the appropriate field (box 53) each time it submitted a claim.
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 185 of 360 Page ID #:61805
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117 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
605. On information and belief: California Blue Cross and/or the Marvell Plan
thereafter paid some or all of the assigned benefits to Patient 122 instead of Plaintiffs.
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 186 of 360 Page ID #:61806
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118 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
PATIENT 124
606. On information and belief: Patient 124 was a participant in or beneficiary
of the Winning Edge health benefit plan (the “Winning Edge Plan”) during all times
relevant to this complaint.
607. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the Winning Edge Plan either (i) is insured by Oklahoma
Blue and/or California Blue Cross or (ii) is self-insured and has entered into an
agreement with Oklahoma Blue and/or California Blue Cross by which the Winning
Edge Plan receives third party administrative services.
608. Plaintiffs obtained an assignment of benefits from Patient 124, who
executed an assignment in the same or substantially similar form to the document
attached hereto as Exhibit B.
609. On or about May 12, 2015, Plaintiffs secured Patient 124’s consent to
contact California Blue Cross, along with the identifying information necessary for
Plaintiffs to interact with the insurer.
610. On or about May 15, 2015, Plaintiffs began providing mental health
and/or substance abuse treatment to Patient 124.
611. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Cross or Oklahoma Blue on the industry-standard
UB-04 form. Plaintiffs indicated that it was requesting that benefits be paid to it as an
assignee by inserting the letter Y in the appropriate field (box 53) each time it submitted
a claim.
612. On information and belief: California Blue Cross, Oklahoma Blue, and/or
the Winning Edge Plan thereafter paid some or all of the assigned benefits to Patient
124 instead of Plaintiffs.
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PATIENT 125
613. On information and belief: Patient 125 was a participant in or beneficiary
of the California Association of Golf and Private Clubs Trust (the “Golf & Private
Clubs Plan”) during all times relevant to this complaint.
614. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the Golf & Private Clubs Plan either (i) is insured by
California Blue Cross or (ii) is self-insured and has entered into an agreement with
California Blue Cross by which the Golf & Private Clubs Plan receives third party
administrative services.
615. Plaintiffs obtained an assignment of benefits from Patient 125, who
executed an assignment in the same or substantially similar form to the document
attached hereto as Exhibit B.
616. On or about May 29, 2015, Plaintiffs secured Patient 125’s consent to
contact California Blue Cross, along with the identifying information necessary for
Plaintiffs to interact with the insurer.
617. On or about May 29, 2015, Plaintiffs or their agents contacted the Provider
Hotline of California Blue Cross and requested details about Patient 125’s coverage.
Plaintiffs or their agents recorded the information learned from California Blue Cross
on the bottom of Patient 125’s Insurance Verification Form. Plaintiffs or their agents
learned from California Blue Cross that Patient 125’s benefits were assignable.
Plaintiffs or their agents recorded this by circling “Yes” next to the line “Assignable”
on Patient 125’s Insurance Verification Form.
618. On or about May 29, 2015, Plaintiffs began providing mental health
and/or substance abuse treatment to Patient 125.
619. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Cross on the industry-standard UB-04 form. Plaintiffs
indicated that it was requesting that benefits be paid to it as an assignee by inserting
the letter Y in the appropriate field (box 53) each time it submitted a claim.
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CASE NO. SACV15−0736 DOC (DFMx) 206541.1
620. On information and belief: California Blue Cross and/or the Golf &
Private Clubs Plan thereafter paid some or all of the assigned benefits to Patient 125
instead of Plaintiffs.
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 189 of 360 Page ID #:61809
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121 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
PATIENT 126
621. On information and belief: Patient 126 was a participant in or beneficiary
of the Badlands Tank Lines, LLC Group Health Plan (the “Badlands Pan”) during all
times relevant to this complaint.
622. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the Badlands Plan either (i) is insured by Nebraska Blue
and/or California Blue Cross or (ii) is self-insured and has entered into an agreement
with Nebraska Blue and/or California Blue Cross by which the Badlands Plan receives
third party administrative services.
623. Plaintiffs obtained an assignment of benefits from Patient 126, who
executed an assignment in or substantially similar form to the document attached as
Exhibit B.
624. On or about April 29, 2015, Plaintiffs secured Patient 126’s consent to
contact Nebraska Blue and/or California Blue Cross, along with the identifying
information necessary for Plaintiffs to interact with the insurer.
625. On or about May 22, 2015, Plaintiffs began providing mental health
and/or substance abuse treatment to Patient 126.
626. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Cross or Nebraska Blue on the industry-standard UB-
04 form. Plaintiffs indicated that it was requesting that benefits be paid to it as an
assignee by inserting the letter Y in the appropriate field (box 53) each time it submitted
a claim.
627. On information and belief: California Blue Cross, Nebraska Blue, and/or
the Badlands Plan thereafter paid some or all of the assigned benefits to Patient 126
instead of Plaintiffs.
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 190 of 360 Page ID #:61810
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122 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
PATIENT 128
628. On information and belief: Patient 128 was a participant in or beneficiary
of Defendant ION Geophysical Plan during all times relevant to this complaint.
629. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the ION Geophysical Plan either (i) is insured by Texas
Blue and/or California Blue Cross or (ii) is self-insured and has entered into an
agreement with Texas Blue and/or California Blue Cross by which the ION
Geophysical Plan receives third party administrative services.
630. Plaintiffs obtained an assignment of benefits from Patient 128, who
executed an assignment in the same or substantially similar form to the document
attached hereto as Exhibit A.
631. On or about March 18, 2014, Plaintiffs secured Patient 128’s consent to
contact Texas Blue and/or California Blue Cross, along with the identifying
information necessary for Plaintiffs to interact with the insurer.
632. On or about March 19, 2014, Plaintiffs began providing mental health
and/or substance abuse treatment to Patient 128.
633. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Cross or Texas Blue on the industry-standard UB-04
form. Plaintiffs indicated that it was requesting that benefits be paid to it as an assignee
by inserting the letter Y in the appropriate field (box 53) each time it submitted a claim.
634. On information and belief: California Blue Cross, Texas Blue, and/or the
ION Geophysical Plan thereafter paid some or all of the assigned benefits to Patient
128 instead of Plaintiffs.
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 191 of 360 Page ID #:61811
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123 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
PATIENT 129
635. On information and belief: Patient 129 was a participant in or beneficiary
of Defendant Xerox Corp. Plan during all times relevant to this complaint.
636. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the Xerox Corp. Plan either (i) is insured by Indiana Blue,
New York Empire Blue, and/or California Blue Cross or (ii) is self-insured and has
entered into an agreement with Indiana Blue, New York Empire Blue, and/or
California Blue Cross by which the Xerox Corp. Plan receives third party
administrative services.
637. Plaintiffs obtained an assignment of benefits from Patient 129, who
executed an assignment in the same or substantially similar form to the document
attached hereto as Exhibit A.
638. On or about September 18, 2013, Plaintiffs secured Patient 129’s consent
to contact Indiana Blue, New York Empire Blue, and/or California Blue Cross, along
with the identifying information necessary for Plaintiffs to interact with the insurer.
639. On or about September 18, 2013, Plaintiffs or their agents contacted the
Provider Hotline of Indiana Blue, New York Empire Blue, and/or California Blue
Cross and requested details about Patient 129’s coverage. Plaintiffs or their agents
recorded the information learned from Indiana Blue, New York Empire Blue, and/or
California Blue Cross on the bottom of Patient 129’s Insurance Verification Form.
Plaintiffs or their agents learned from Indiana Blue, New York Empire Blue, and/or
California Blue Cross that Patient 129’s benefits were not assignable. Plaintiffs or their
agents recorded this by circling “No” next to the line “Assignable” on Patient 129’s
Insurance Verification Form.
640. On or about September 20, 2013, Plaintiffs began providing mental health
and/or substance abuse treatment to Patient 129.
641. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Cross, Indiana Blue, or New York Empire Blue on
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 192 of 360 Page ID #:61812
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CASE NO. SACV15−0736 DOC (DFMx) 206541.1
the industry-standard UB-04 form. Plaintiffs indicated that it was requesting that
benefits be paid to it as an assignee by inserting the letter Y in the appropriate field
(box 53) each time it submitted a claim.
642. On information and belief: California Blue Cross, Indiana Blue, New
York Empire Blue, and/or the Xerox Corp. Plan thereafter paid some or all of the
assigned benefits to Patient 129 instead of Plaintiffs.
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 193 of 360 Page ID #:61813
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125 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
PATIENT 130
643. On information and belief: Patient 130 was a participant in or beneficiary
of Defendant Eli Lilly Plan during all times relevant to this complaint.
644. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the Eli Lilly Plan either (i) is insured by Indiana Blue and/or
California Blue Cross or (ii) is self-insured and has entered into an agreement with
Indiana Blue and/or California Blue Cross by which the Eli Lilly Plan receives third
party administrative services.
645. Plaintiffs obtained an assignment of benefits from Patient 130, who
executed an assignment in the same or substantially similar form to the document
attached hereto as Exhibit A.
646. On or about February 13, 2014, Plaintiffs secured Patient 130’s consent
to contact Indiana Blue and/or California Blue Cross, along with the identifying
information necessary for Plaintiffs to interact with the insurer.
647. On or about February 13, 2014, Plaintiffs or their agents contacted the
Provider Hotline of Indiana Blue and/or California Blue Cross and requested details
about Patient 130’s coverage. Plaintiffs or their agents recorded the information
learned from Indiana Blue and/or California Blue Cross on the bottom of Patient 130’s
Insurance Verification Form. Plaintiffs or their agents learned from Indiana Blue
and/or California Blue Cross that Patient 130’s benefits were assignable. Plaintiffs or
their agents recorded this by circling “Yes” next to the line “Assignable” on Patient
130’s Insurance Verification Form.
648. On or about February 19, 2014, Plaintiffs began providing mental health
and/or substance abuse treatment to Patient 130.
649. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Cross or Indiana Blue on the industry-standard UB-
04 form. Plaintiffs indicated that it was requesting that benefits be paid to it as an
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assignee by inserting the letter Y in the appropriate field (box 53) each time it submitted
a claim.
650. On information and belief: California Blue Cross, Indiana Blue, and/or
the Eli Lilly Plan thereafter paid some or all of the assigned benefits to Patient 130
instead of Plaintiffs.
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 195 of 360 Page ID #:61815
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127 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
PATIENT 133
651. On information and belief: Patient 133 was a participant in or beneficiary
of Defendant Ernst & Young Plan during all times relevant to this complaint.
652. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the Ernst & Young Plan either (i) is insured by New York
Empire Blue and/or California Blue Cross or (ii) is self-insured and has entered into an
agreement with New York Empire Blue and/or California Blue Cross by which the
Ernst & Young Plan receives third party administrative services.
653. Plaintiffs obtained an assignment of benefits from Patient 133, who
executed an assignment in the same or substantially similar form to the document
attached hereto as Exhibit A.
654. On or about April 16, 2013, Plaintiffs secured Patient 133’s consent to
contact New York Empire Blue and/or California Blue Cross, along with the
identifying information necessary for Plaintiffs to interact with the insurer.
655. On or about May 8, 2013, Plaintiffs began providing mental health and/or
substance abuse treatment to Patient 133.
656. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Cross or New York Empire Blue on the industry-
standard UB-04 form. Plaintiffs indicated that it was requesting that benefits be paid
to it as an assignee by inserting the letter Y in the appropriate field (box 53) each time
it submitted a claim.
657. On information and belief: California Blue Cross, New York Empire
Blue, and/or the Ernst & Young Plan thereafter paid some or all of the assigned benefits
to Patient 133 instead of Plaintiffs.
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 196 of 360 Page ID #:61816
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128 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
PATIENT 134
658. On information and belief: Patient 134 was a participant in or beneficiary
of Defendant Hilliard Lyons Plan during all times relevant to this complaint.
659. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the Hilliard Lyons Plan either (i) is insured by Kentucky
Blue and/or California Blue Cross or (ii) is self-insured and has entered into an
agreement with Kentucky Blue and/or California Blue Cross by which the Hilliard
Lyons Plan receives third party administrative services.
660. Plaintiffs obtained an assignment of benefits from Patient 134, who
executed an assignment in the same or substantially similar form to the document
attached hereto as Exhibit B.
661. On or about May 5, 2014, Plaintiffs secured Patient 134’s consent to
contact Kentucky Blue and/or California Blue Cross, along with the identifying
information necessary for Plaintiffs to interact with the insurer.
662. On or about May 5, 2014, Plaintiffs or their agents contacted the Provider
Hotline of Kentucky Blue and/or California Blue Cross and requested details about
Patient 134’s coverage. Plaintiffs or their agents recorded the information learned from
Kentucky Blue and/or California Blue Cross on the bottom of Patient 134’s Insurance
Verification Form. Plaintiffs or their agents learned from Kentucky Blue and/or
California Blue Cross that Patient 134’s benefits were assignable. Plaintiffs or their
agents recorded this by circling “Yes” next to the line “Assignable” on Patient 134’s
Insurance Verification Form.
663. On or about July 30, 2014, Plaintiffs began providing mental health and/or
substance abuse treatment to Patient 134.
664. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Cross or Kentucky Blue on the industry-standard UB-
04 form. Plaintiffs indicated that it was requesting that benefits be paid to it as an
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129 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
assignee by inserting the letter Y in the appropriate field (box 53) each time it submitted
a claim.
665. On information and belief: California Blue Cross, Kentucky Blue, and/or
the Hilliard Lyons Plan thereafter paid some or all of the assigned benefits to Patient
134 instead of Plaintiffs.
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 198 of 360 Page ID #:61818
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130 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
PATIENT 135
666. On information and belief: Patient 135 was a participant in or beneficiary
of Defendant Master Builders Plan during all times relevant to this complaint.
667. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the Master Builders Plan either (i) is insured by Washington
Regence Blue and/or California Blue Cross or (ii) is self-insured and has entered into
an agreement with Washington Regence Blue and/or California Blue Cross by which
the Master Builders Plan receives third party administrative services.
668. Plaintiffs obtained an assignment of benefits from Patient 135, who
executed an assignment in the same or substantially similar form to the document
attached hereto as Exhibit B.
669. On or about October 1, 2014, Plaintiffs secured Patient 135’s consent to
contact Washington Regence Blue and/or California Blue Cross, along with the
identifying information necessary for Plaintiffs to interact with the insurer.
670. On or about October 1, 2014, Plaintiffs or their agents contacted the
Provider Hotline of Washington Regence Blue and/or California Blue Cross and
requested details about Patient 135’s coverage. Plaintiffs or their agents recorded the
information learned from Washington Regence Blue and/or California Blue Cross on
the bottom of Patient 135’s Insurance Verification Form. Plaintiffs or their agents
learned from Washington Regence Blue and/or California Blue Cross that Patient 135’s
benefits were assignable. Plaintiffs or their agents recorded this by circling “Yes” next
to the line “Assignable” on Patient 135’s Insurance Verification Form.
671. On or about October 24, 2014, Plaintiffs began providing mental health
and/or substance abuse treatment to Patient 135.
672. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Cross or Washington Regence Blue on the industry-
standard UB-04 form. Plaintiffs indicated that it was requesting that benefits be paid
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 199 of 360 Page ID #:61819
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to it as an assignee by inserting the letter Y in the appropriate field (box 53) each time
it submitted a claim.
673. On information and belief: California Blue Cross, Washington Regence
Blue, and/or the Master Builders Plan thereafter paid some or all of the assigned
benefits to Patient 135 instead of Plaintiffs.
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 200 of 360 Page ID #:61820
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132 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
PATIENT 136
674. On information and belief: Patient 136 was a participant in or beneficiary
of the DECO Products Company Plan (the “DECO Plan”) during all times relevant to
this complaint.
675. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the DECO Plan either (i) is insured by Iowa Blue and/or
California Blue Cross or (ii) is self-insured and has entered into an agreement with
Iowa Blue and/or California Blue Cross by which the DECO Plan receives third party
administrative services.
676. Plaintiffs obtained an assignment of benefits from Patient 136, who
executed an assignment in the same or substantially similar form to the document
attached hereto as Exhibit A.
677. On or about October 12, 2013, Plaintiffs secured Patient 136’s consent to
contact Iowa Blue and/or California Blue Cross, along with the identifying information
necessary for Plaintiffs to interact with the insurer.
678. On or about October 12, 2013, Plaintiffs or their agents contacted the
Provider Hotline of Iowa Blue and/or California Blue Cross and requested details about
Patient 136’s coverage. Plaintiffs or their agents recorded the information learned from
Iowa Blue and/or California Blue Cross on the bottom of Patient 136’s Insurance
Verification Form. Plaintiffs or their agents learned from Iowa Blue and/or California
Blue Cross that Patient 136’s benefits were not assignable. Plaintiffs or their agents
recorded this by circling “No” next to the line “Assignable” on Patient 136’s Insurance
Verification Form.
679. On or about October 14, 2013, Plaintiffs began providing mental health
and/or substance abuse treatment to Patient 136.
680. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Cross or Iowa Blue on the industry-standard UB-04
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 201 of 360 Page ID #:61821
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form. Plaintiffs indicated that it was requesting that benefits be paid to it as an assignee
by inserting the letter Y in the appropriate field (box 53) each time it submitted a claim.
681. On information and belief: California Blue Cross, Iowa Blue, and/or the
DECO Plan thereafter paid some or all of the assigned benefits to Patient 136 instead
of Plaintiffs.
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 202 of 360 Page ID #:61822
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134 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
PATIENT 137
682. On information and belief: Patient 137 was a participant in or beneficiary
of Defendant Home Depot Plan during all times relevant to this complaint.
683. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the Home Depot Plan either (i) is insured by Georgia Blue
and/or California Blue Cross or (ii) is self-insured and has entered into an agreement
with Georgia Blue and/or California Blue Cross by which the Home Depot Plan receives
third party administrative services.
684. Plaintiffs obtained an assignment of benefits from Patient 137, who
executed an assignment in the same or substantially similar form to the document
attached hereto as Exhibit A.
685. On or about December 17, 2013 Plaintiffs secured Patient 137’s consent
to contact Georgia Blue and/or California Blue Cross, along with the identifying
information necessary for Plaintiffs to interact with the insurer.
686. On or about December 19, 2013, Plaintiffs began providing mental health
and/or substance abuse treatment to Patient 137.
687. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Cross or Georgia Blue on the industry-standard UB-
04 form. Plaintiffs indicated that it was requesting that benefits be paid to it as an
assignee by inserting the letter Y in the appropriate field (box 53) each time it submitted
a claim.
688. On information and belief: California Blue Cross, Georgia Blue, and/or
the Home Depot Plan thereafter paid some or all of the assigned benefits to Patient 137
instead of Plaintiffs.
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 203 of 360 Page ID #:61823
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135 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
PATIENT 140
689. On information and belief: Patient 140 was a participant in or beneficiary
of the Time Warner Cable Benefits Plan (“Time Warner Plan”) during all times
relevant to this complaint.
690. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the Time Warner Plan either (i) is insured by California
Blue Cross or (ii) is self-insured and has entered into an agreement with California
Blue Cross by which the Time Warner Plan receives third party administrative services.
691. Plaintiffs obtained an assignment of benefits from Patient 140, who
executed an assignment in the same or substantially similar form to the document
attached hereto as Exhibit A.
692. On or about March 11, 2014, Plaintiffs secured Patient 140’s consent to
contact California Blue Cross, along with the identifying information necessary for
Plaintiffs to interact with the insurer.
693. On or about March 19, 2014, Plaintiffs began providing mental health
and/or substance abuse treatment to Patient 140.
694. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Cross on the industry-standard UB-04 form. Plaintiffs
indicated that it was requesting that benefits be paid to it as an assignee by inserting
the letter Y in the appropriate field (box 53) each time it submitted a claim.
695. On information and belief: California Blue Cross and/or the Time Warner
Plan thereafter paid some or all of the assigned benefits to Patient 140 instead of
Plaintiffs.
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 204 of 360 Page ID #:61824
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136 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
PATIENT 141
696. On information and belief: Patient 141 was a participant in or beneficiary
of Defendant IESI Corp. Plan during all times relevant to this complaint.
697. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the IESI Corp. Plan either (i) is insured by Texas Blue and/or
California Blue Cross or (ii) is self-insured and has entered into an agreement with
Texas Blue and/or California Blue Cross by which the IESI Corp. Plan receives third
party administrative services.
698. Plaintiffs obtained an assignment of benefits from Patient 141, who
executed an assignment in the same or substantially similar form to the document
attached hereto as Exhibit A.
699. On or about January 28, 2014, Plaintiffs secured Patient 141’s consent to
contact Texas Blue and/or California Blue Cross, along with the identifying
information necessary for Plaintiffs to interact with the insurer.
700. On or about February 14, 2014, Plaintiffs began providing mental health
and/or substance abuse treatment to Patient 141.
701. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Cross or Texas Blue on the industry-standard UB-04
form. Plaintiffs indicated that it was requesting that benefits be paid to it as an assignee
by inserting the letter Y in the appropriate field (box 53) each time it submitted a claim.
702. On information and belief: California Blue Cross, Texas Blue, and/or the
IESI Corp. Plan thereafter paid some or all of the assigned benefits to Patient 141
instead of Plaintiffs.
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 205 of 360 Page ID #:61825
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137 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
PATIENT 142
703. On information and belief: Patient 142 was a participant in or beneficiary
of Defendant IESI Corp. Plan during all times relevant to this complaint.
704. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the IESI Corp. Plan either (i) is insured by Texas Blue and/or
California Blue Cross or (ii) is self-insured and has entered into an agreement with
Texas Blue and/or California Blue Cross by which the IESI Corp. Plan receives third
party administrative services.
705. Plaintiffs obtained an assignment of benefits from Patient 142, who
executed an assignment in the same or substantially similar form to the document
attached hereto as Exhibit B.
706. On or about February 4, 2015, Plaintiffs secured Patient 142’s consent to
contact Texas Blue and/or California Blue Cross, along with the identifying
information necessary for Plaintiffs to interact with the insurer.
707. On or about February 4, 2015, Plaintiffs or their agents contacted the
Provider Hotline of Texas Blue and/or California Blue Cross and requested details
about Patient 142’s coverage. Plaintiffs or their agents recorded the information
learned from Texas Blue and/or California Blue Cross on the bottom of Patient 142’s
Insurance Verification Form. Plaintiffs or their agents learned from Texas Blue and/or
California Blue Cross that Patient 142’s benefits were not assignable. Plaintiffs or their
agents recorded this by circling “No” next to the line “Assignable” on Patient 142’s
Insurance Verification Form.
708. On or about February 28, 2015, Plaintiffs began providing mental health
and/or substance abuse treatment to Patient 142.
709. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Cross or Texas Blue on the industry-standard UB-04
form. Plaintiffs indicated that it was requesting that benefits be paid to it as an assignee
by inserting the letter Y in the appropriate field (box 53) each time it submitted a claim.
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 206 of 360 Page ID #:61826
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138 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
710. On information and belief: California Blue Cross, Texas Blue, and/or the
IESI Corp. Plan thereafter paid some or all of the assigned benefits to Patient 142
instead of Plaintiffs.
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 207 of 360 Page ID #:61827
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139 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
PATIENT 143
711. On information and belief: Patient 143 was a participant in or beneficiary
of Defendant Peak Finance Plan during all times relevant to this complaint.
712. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the Peak Finance Plan either (i) is insured by California
Blue Cross or (ii) is self-insured and has entered into an agreement with California
Blue Cross by which the Peak Finance Plan receives third party administrative services.
713. Plaintiffs obtained an assignment of benefits from Patient 143, who
executed an assignment in the same or substantially similar form to the document
attached hereto as Exhibit A.
714. On or about July 17, 2013, Plaintiffs secured Patient 143’s consent to
contact California Blue Cross, along with the identifying information necessary for
Plaintiffs to interact with the insurer.
715. On or about July 25, 2013, Plaintiffs began providing mental health and/or
substance abuse treatment to Patient 143.
716. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Cross on the industry-standard UB-04 form. Plaintiffs
indicated that it was requesting that benefits be paid to it as an assignee by inserting
the letter Y in the appropriate field (box 53) each time it submitted a claim.
717. On information and belief: California Blue Cross and/or the Peak Finance
Plan thereafter paid some or all of the assigned benefits to Patient 143 instead of
Plaintiffs.
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 208 of 360 Page ID #:61828
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140 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
PATIENT 144
718. On information and belief: Patient 144 was a participant in or beneficiary
of Defendant Globys Plan during all times relevant to this complaint.
719. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the Globys Plan either (i) is insured by Washington Regence
Blue and/or California Blue Cross or (ii) is self-insured and has entered into an
agreement with Washington Regence Blue and/or California Blue Cross by which the
Globys Plan receives third party administrative services.
720. Plaintiffs obtained an assignment of benefits from Patient 144, who
executed an assignment in the same or substantially similar form to the document
attached hereto as Exhibit B.
721. On or about September 3, 2014, Plaintiffs secured Patient 144’s consent
to contact Washington Regence Blue and/or California Blue Cross, along with the
identifying information necessary for Plaintiffs to interact with the insurer.
722. On or about September 9, 2014, Plaintiffs began providing mental health
and/or substance abuse treatment to Patient 144.
723. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Cross or Washington Regence Blue on the industry-
standard UB-04 form. Plaintiffs indicated that it was requesting that benefits be paid
to it as an assignee by inserting the letter Y in the appropriate field (box 53) each time
it submitted a claim.
724. On information and belief: California Blue Cross, Washington Regence
Blue, and/or the Globys Plan thereafter paid some or all of the assigned benefits to
Patient 144 instead of Plaintiffs.
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 209 of 360 Page ID #:61829
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141 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
PATIENT 145
725. On information and belief: Patient 145 was a participant in or beneficiary
of Defendant Peak 10 Plan during all times relevant to this complaint.
726. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the Peak 10 Plan either (i) is insured by North Carolina Blue
and/or California Blue Cross or (ii) is self-insured and has entered into an agreement
with North Carolina Blue and/or California Blue Cross by which the Peak 10 Plan
receives third party administrative services.
727. Plaintiffs obtained an assignment of benefits from Patient 145, who
executed an assignment in the same or substantially similar form to the document
attached hereto as Exhibit B.
728. On or about January 5, 2015, Plaintiffs secured Patient 145’s consent to
contact North Carolina Blue and/or California Blue Cross, along with the identifying
information necessary for Plaintiffs to interact with the insurer.
729. On or about January 5, 2015, Plaintiffs or their agents contacted the
Provider Hotline of North Carolina Blue and/or California Blue Cross and requested
details about Patient 145’s coverage. Plaintiffs or their agents recorded the information
learned from North Carolina Blue and/or California Blue Cross on the bottom of
Patient 145’s Insurance Verification Form. Plaintiffs or their agents learned from North
Carolina Blue and/or California Blue Cross that Patient 145’s benefits were not
assignable. Plaintiffs or their agents recorded this by circling “No” next to the line
“Assignable” on Patient 145’s Insurance Verification Form.
730. On or about January 9, 2015, Plaintiffs began providing mental health
and/or substance abuse treatment to Patient 145.
731. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Cross or North Carolina Blue on the industry-standard
UB-04 form. Plaintiffs indicated that it was requesting that benefits be paid to it as an
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 210 of 360 Page ID #:61830
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142 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
assignee by inserting the letter Y in the appropriate field (box 53) each time it submitted
a claim.
732. On information and belief: California Blue Cross, North Carolina Blue,
and/or the Peak 10 Plan thereafter paid some or all of the assigned benefits to Patient
145 instead of Plaintiffs.
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 211 of 360 Page ID #:61831
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143 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
PATIENT 146
733. On information and belief: Patient 146 was a participant in or beneficiary
of Defendant IBU Health Plan during all times relevant to this complaint.
734. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the IBU Health Plan either (i) is insured by Washington
Premera Blue and/or California Blue Cross or (ii) is self-insured and has entered into
an agreement with Washington Premera Blue and/or California Blue Cross by which
the IBU Health Plan receives third party administrative services.
735. Plaintiffs obtained an assignment of benefits from Patient 146, who
executed an assignment in the same or substantially similar form to the document
attached hereto as Exhibit B.
736. On or about January 13, 2015, Plaintiffs secured Patient 146’s consent to
contact Washington Premera Blue and/or California Blue Cross, along with the
identifying information necessary for Plaintiffs to interact with the insurer.
737. On or about January 20, 2015, Plaintiffs began providing mental health
and/or substance abuse treatment to Patient 146.
738. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Cross or Washington Premera Blue on the industry-
standard UB-04 form. Plaintiffs indicated that it was requesting that benefits be paid
to it as an assignee by inserting the letter Y in the appropriate field (box 53) each time
it submitted a claim.
739. On information and belief: California Blue Cross, Washington Premera
Blue and/or the IBU Health Plan thereafter paid some or all of the assigned benefits to
Patient 146 instead of Plaintiffs.
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 212 of 360 Page ID #:61832
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144 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
PATIENT 147
740. On information and belief: Patient 147 was a participant in or beneficiary
of Defendant Cargill Plan during all times relevant to this complaint.
741. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the Cargill Plan either (i) is insured by Minnesota Blue
and/or California Blue Cross or (ii) is self-insured and has entered into an agreement
with Minnesota Blue and/or California Blue Cross by which the Cargill Plan receives
third party administrative services.
742. Plaintiffs obtained an assignment of benefits from Patient 147, who
executed an assignment in the same or substantially similar form to the document
attached hereto as Exhibit B.
743. On or about May 15, 2015, Plaintiffs secured Patient 147’s consent to
contact Minnesota Blue and/or California Blue Cross, along with the identifying
information necessary for Plaintiffs to interact with the insurer.
744. On or about May 29, 2015, Plaintiffs began providing mental health
and/or substance abuse treatment to Patient 147.
745. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Cross or Minnesota Blue on the industry-standard
UB-04 form. Plaintiffs indicated that it was requesting that benefits be paid to it as an
assignee by inserting the letter Y in the appropriate field (box 53) each time it submitted
a claim.
746. On information and belief: California Blue Cross, Minnesota Blue, and/or
the Cargill Plan thereafter paid some or all of the assigned benefits to Patient 147
instead of Plaintiffs.
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 213 of 360 Page ID #:61833
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145 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
PATIENT 148
747. On information and belief: Patient 148 was a participant in or beneficiary
of Defendant ACWA/JPIA Plan during all times relevant to this complaint.
748. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the ACWA/JPIA Plan either (i) is insured by California
Blue Cross or (ii) is self-insured and has entered into an agreement with California
Blue Cross by which the ACWA/JPIA Plan receives third party administrative
services.
749. Plaintiffs obtained an assignment of benefits from Patient 148, who
executed an assignment in the same or substantially similar form to the document
attached hereto as Exhibit A.
750. On or about June 4, 2012, Plaintiffs secured Patient 148’s consent to
contact California Blue Cross, along with the identifying information necessary for
Plaintiffs to interact with the insurer.
751. On or about June 5, 2012, Plaintiffs began providing mental health and/or
substance abuse treatment to Patient 148.
752. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Cross on the industry-standard UB-04 form. Plaintiffs
indicated that it was requesting that benefits be paid to it as an assignee by inserting
the letter Y in the appropriate field (box 53) each time it submitted a claim.
753. On information and belief: California Blue Cross and/or the ACWA/JPIA
Plan thereafter paid some or all of the assigned benefits to Patient 148 instead of
Plaintiffs.
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 214 of 360 Page ID #:61834
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146 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
PATIENT 149
754. On information and belief: Patient 149 was a participant in or beneficiary
of Defendant Dycom Plan during all times relevant to this complaint.
755. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the Dycom Plan either (i) is insured by Florida Blue and/or
California Blue Cross or (ii) is self-insured and has entered into an agreement with
Florida Blue and/or California Blue Cross by which the Dycom Plan receives third
party administrative services.
756. Plaintiffs obtained an assignment of benefits from Patient 149, who
executed an assignment in the same or substantially similar form to the document
attached hereto as Exhibit B.
757. On or about September 22, 2014, Plaintiffs secured Patient 149’s consent
to contact Florida Blue and/or California Blue Cross, along with the identifying
information necessary for Plaintiffs to interact with the insurer.
758. On or about September 22, 2014, Plaintiffs or their agents contacted the
Provider Hotline of Florida Blue and/or California Blue Cross and requested details
about Patient 149’s coverage. Plaintiffs or their agents recorded the information
learned from Florida Blue and/or California Blue Cross on the bottom of Patient 149’s
Insurance Verification Form. Plaintiffs or their agents learned from Florida Blue and/or
California Blue Cross that Patient 149’s benefits were assignable. Plaintiffs or their
agents recorded this by circling “Yes” next to the line “Assignable” on Patient 149’s
Insurance Verification Form.
759. On or about October 1, 2014, Plaintiffs began providing mental health
and/or substance abuse treatment to Patient 149.
760. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Cross or Florida Blue on the industry-standard UB-
04 form. Plaintiffs indicated that it was requesting that benefits be paid to it as an
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 215 of 360 Page ID #:61835
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147 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
assignee by inserting the letter Y in the appropriate field (box 53) each time it submitted
a claim.
761. On information and belief: California Blue Cross, Florida Blue, and/or the
Dycom Plan thereafter paid some or all of the assigned benefits to Patient 149 instead
of Plaintiffs.
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 216 of 360 Page ID #:61836
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148 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
PATIENT 150
762. On information and belief: Patient 150 was a participant in or beneficiary
of Defendant Medtronic Plan during all times relevant to this complaint.
763. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the Medtronic Plan either (i) is insured by Minnesota Blue
and/or California Blue Cross or (ii) is self-insured and has entered into an agreement
with Minnesota Blue and/or California Blue Cross by which the Medtronic Plan
receives third party administrative services.
764. Plaintiffs obtained an assignment of benefits from Patient 150, who
executed an assignment in the same or substantially similar form to the document
attached hereto as Exhibit B.
765. On or about August 25, 2014, Plaintiffs secured Patient 150’s consent to
contact Minnesota Blue and/or California Blue Cross, along with the identifying
information necessary for Plaintiffs to interact with the insurer.
766. On or about August 25, 2014, Plaintiffs or their agents contacted the
Provider Hotline of Minnesota Blue and/or California Blue Cross and requested details
about Patient 150’s coverage. Plaintiffs or their agents recorded the information
learned from Minnesota Blue and/or California Blue Cross on the bottom of Patient
150’s Insurance Verification Form. Plaintiffs or their agents learned from Minnesota
Blue and/or California Blue Cross that Patient 150’s benefits were assignable.
Plaintiffs or their agents recorded this by circling “Yes” next to the line “Assignable”
on Patient 150’s Insurance Verification Form.
767. On or about August 29, 2014, Plaintiffs began providing mental health
and/or substance abuse treatment to Patient 150.
768. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Cross or Minnesota Blue on the industry-standard
UB-04 form. Plaintiffs indicated that it was requesting that benefits be paid to it as an
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 217 of 360 Page ID #:61837
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149 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
assignee by inserting the letter Y in the appropriate field (box 53) each time it submitted
a claim.
769. On information and belief: California Blue Cross, Minnesota Blue, and/or
the Medtronic Plan thereafter paid some or all of the assigned benefits to Patient 150
instead of Plaintiffs.
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 218 of 360 Page ID #:61838
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150 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
PATIENT 151
770. On information and belief: Patient 151 was a participant in or beneficiary
of Defendant PepsiCo Plan during all times relevant to this complaint.
771. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the PepsiCo Plan either (i) is insured California Blue Cross
or (ii) is self-insured and has entered into an agreement with California Blue Cross by
which the PepsiCo Plan receives third party administrative services.
772. Plaintiffs obtained an assignment of benefits from Patient 151, who
executed an assignment in the same or substantially similar form to the document
attached hereto as Exhibit B.
773. On or about July 6, 2014, Plaintiffs secured Patient 151’s consent to
contact Minnesota Blue and/or California Blue Cross, along with the identifying
information necessary for Plaintiffs to interact with the insurer.
774. On or about August 8, 2014, Plaintiffs began providing mental health
and/or substance abuse treatment to Patient 151.
775. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Cross on the industry-standard UB-04 form. Plaintiffs
indicated that it was requesting that benefits be paid to it as an assignee by inserting
the letter Y in the appropriate field (box 53) each time it submitted a claim.
776. On information and belief: California Blue Cross and/or the PepsiCo Plan
thereafter paid some or all of the assigned benefits to Patient 151 instead of Plaintiffs.
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 219 of 360 Page ID #:61839
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151 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
PATIENT 152
777. On information and belief: Patient 152 was a participant in or beneficiary
of Defendant Follett Plan during all times relevant to this complaint.
778. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the Follett Plan either (i) is insured by California Blue Cross
or (ii) is self-insured and has entered into an agreement with California Blue Cross by
which the Follett Plan receives third party administrative services.
779. Plaintiffs obtained an assignment of benefits from Patient 152, who
executed an assignment in the same or substantially similar form to the document
attached hereto as Exhibit A.
780. On or about May 30, 2013, Plaintiffs secured Patient 152’s consent to
contact California Blue Cross, along with the identifying information necessary for
Plaintiffs to interact with the insurer.
781. On or about June 6, 2013, Plaintiffs began providing mental health and/or
substance abuse treatment to Patient 152.
782. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Cross on the industry-standard UB-04 form. Plaintiffs
indicated that it was requesting that benefits be paid to it as an assignee by inserting
the letter Y in the appropriate field (box 53) each time it submitted a claim.
783. On information and belief: California Blue Cross and/or the Follett Plan
thereafter paid some or all of the assigned benefits to Patient 152 instead of Plaintiffs.
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 220 of 360 Page ID #:61840
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152 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
PATIENT 153
784. On information and belief: Patient 153 was a participant in or beneficiary
of Defendant Ogletree Deakins Plan during all times relevant to this complaint.
785. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the Ogletree Deakins Plan either (i) is insured by South
Carolina Blue and/or California Blue Cross or (ii) is self-insured and has entered into
an agreement with South Carolina Blue and/or California Blue Cross by which the
Ogletree Deakins Plan receives third party administrative services.
786. Plaintiffs obtained an assignment of benefits from Patient 153, who
executed an assignment in the same or substantially similar form to the document
attached hereto as Exhibit B.
787. On or about April 22, 2014, Plaintiffs secured Patient 153’s consent to
contact South Carolina Blue and/or California Blue Cross, along with the identifying
information necessary for Plaintiffs to interact with the insurer.
788. On or about May 9, 2014, Plaintiffs began providing mental health and/or
substance abuse treatment to Patient 153.
789. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Cross or South Carolina Blue on the industry-standard
UB-04 form. Plaintiffs indicated that it was requesting that benefits be paid to it as an
assignee by inserting the letter Y in the appropriate field (box 53) each time it submitted
a claim.
790. On information and belief: California Blue Cross, South Carolina Blue,
and/or the Ogletree Deakins Plan thereafter paid some or all of the assigned benefits to
Patient 153 instead of Plaintiffs.
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 221 of 360 Page ID #:61841
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153 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
PATIENT 154
791. On information and belief: Patient 154 was a participant in or beneficiary
of the WaferTech LLC Health & Welfare Plan (the “WaferTech Plan”) during all times
relevant to this complaint.
792. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the WaferTech Plan either (i) is insured by Oregon Blue
and/or California Blue Cross or (ii) is self-insured and has entered into an agreement
with Oregon Blue and/or California Blue Cross by which the WaferTech Plan receives
third party administrative services.
793. Plaintiffs obtained an assignment of benefits from Patient 154, who
executed an assignment in the same or substantially similar form to the document
attached hereto as Exhibit B.
794. On or about October 27, 2014, Plaintiffs secured Patient 154’s consent to
contact Oregon Blue and/or California Blue Cross, along with the identifying
information necessary for Plaintiffs to interact with the insurer.
795. On or about October 27, 2014, Plaintiffs or their agents contacted the
Provider Hotline of Oregon Blue and/or California Blue Cross and requested details
about Patient 154’s coverage. Plaintiffs or their agents recorded the information
learned from Oregon Blue and/or California Blue Cross on the bottom of Patient 154’s
Insurance Verification Form. Plaintiffs or their agents learned from Oregon Blue
and/or California Blue Cross that Patient 154’s benefits were assignable. Plaintiffs or
their agents recorded this by circling “Yes” next to the line “Assignable” on Patient
154’s Insurance Verification Form.
796. On or about November 6, 2014, Plaintiffs began providing mental health
and/or substance abuse treatment to Patient 154.
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 222 of 360 Page ID #:61842
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154 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
797. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Cross or Oregon Blue on the industry-standard UB-
04 form. Plaintiffs indicated that it was requesting that benefits be paid to it as an
assignee by inserting the letter Y in the appropriate field (box 53) each time it submitted
a claim.
798. On information and belief: California Blue Cross, Oregon Blue, and/or
the WaferTech Plan thereafter paid some or all of the assigned benefits to Patient 154
instead of Plaintiffs.
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 223 of 360 Page ID #:61843
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155 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
PATIENT 155
799. On information and belief: Patient 155 was a participant in or beneficiary
of Defendant Alaska Air Plan during all times relevant to this complaint.
800. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the Alaska Air Plan either (i) is insured by Washington
Premera Blue and/or California Blue Shield or (ii) is self-insured and has entered into
an agreement with Washington Premera Blue and/or California Blue Shield by which
the Alaska Air Plan receives third party administrative services.
801. Plaintiffs obtained an assignment of benefits from Patient 155, who
executed an assignment in the same or substantially similar form to the document
attached hereto as Exhibit A.
802. On or about February 21, 2013, Plaintiffs secured Patient 155’s consent
to contact Washington Premera Blue and/or California Blue Shield along with the
identifying information necessary for Plaintiffs to interact with the insurer.
803. On or about February 25, 2013, Plaintiffs began providing mental health
and/or substance abuse treatment to Patient 155.
804. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Shield or Washington Premera Blue on the industry-
standard UB-04 form. Plaintiffs indicated that it was requesting that benefits be paid
to it as an assignee by inserting the letter Y in the appropriate field (box 53) each time
it submitted a claim.
805. On information and belief: California Blue Shield, Washington Premera
Blue, and/or the Alaska Air Plan thereafter paid some or all of the assigned benefits to
Patient 155 instead of Plaintiffs.
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 224 of 360 Page ID #:61844
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156 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
PATIENT 156
806. On information and belief: Patient 156 was a participant in or beneficiary
of Defendant FNB Corp. Plan during all times relevant to this complaint.
807. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the FNB Corp. Plan either (i) is insured by Western
Pennsylvania Blue, Highmark, and/or California Blue Cross or (ii) is self-insured and
has entered into an agreement with Western Pennsylvania Blue, Highmark, and/or
California Blue Cross by which the FNB Corp. Plan receives third party administrative
services.
808. Plaintiffs obtained an assignment of benefits from Patient 156, who
executed an assignment in the same or substantially similar form to the document
attached hereto as Exhibit A.
809. On or about March 27, 2014, Plaintiffs secured Patient 156’s consent to
contact Western Pennsylvania Blue, Highmark, and/or California Blue Cross, along
with the identifying information necessary for Plaintiffs to interact with the insurer.
810. On or about April 2, 2014, Plaintiffs began providing mental health and/or
substance abuse treatment to Patient 156.
811. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Cross, Western Pennsylvania Blue, or Highmark on
the industry-standard UB-04 form. Plaintiffs indicated that it was requesting that
benefits be paid to it as an assignee by inserting the letter Y in the appropriate field
(box 53) each time it submitted a claim.
812. On information and belief: California Blue Cross, Western Pennsylvania
Blue, Highmark, and/or the FNB Corp. Plan thereafter paid some or all of the assigned
benefits to Patient 156 instead of Plaintiffs.
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 225 of 360 Page ID #:61845
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157 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
PATIENT 157
813. On information and belief: Patient 157 was a participant in or beneficiary
of Defendant LeCroy Plan during all times relevant to this complaint.
814. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the LeCroy Plan either (i) is insured by New York Empire
Blue and/or California Blue Cross or (ii) is self-insured and has entered into an
agreement with New York Empire Blue and/or California Blue Cross by which the
LeCroy Plan receives third party administrative services.
815. Plaintiffs obtained an assignment of benefits from Patient 157, who
executed an assignment in the same or substantially similar form to the document
attached hereto as Exhibit A.
816. On or about January 27, 2014, Plaintiffs secured Patient 157’s consent to
contact New York Empire Blue and/or California Blue Cross, along with the
identifying information necessary for Plaintiffs to interact with the insurer.
817. On or about March 27, 2014, Plaintiffs began providing mental health
and/or substance abuse treatment to Patient 157.
818. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Cross or New York Empire Blue on the industry-
standard UB-04 form. Plaintiffs indicated that it was requesting that benefits be paid
to it as an assignee by inserting the letter Y in the appropriate field (box 53) each time
it submitted a claim.
819. On information and belief: California Blue Cross, New York Empire
Blue, and/or the LeCroy Plan thereafter paid some or all of the assigned benefits to
Patient 157 instead of Plaintiffs.
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 226 of 360 Page ID #:61846
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158 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
PATIENT 158
820. On information and belief: Patient 158 was a participant in or beneficiary
of the Experian Information Solutions, Inc. Health and Welfare Plan (the “Experian
Plan”) during all times relevant to this complaint.
821. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the Experian Plan either (i) is insured by Northeastern
Pennsylvania Blue and/or California Blue Cross or (ii) is self-insured and has entered
into an agreement with Northeastern Pennsylvania Blue and/or California Blue Cross
by which the Experian Plan receives third party administrative services.
822. Plaintiffs obtained an assignment of benefits from Patient 158, who
executed an assignment in the same or substantially similar form to the document
attached hereto as Exhibit B.
823. On or about August 20, 2014, Plaintiffs secured Patient 158’s consent to
contact Northeastern Pennsylvania Blue and/or California Blue Cross, along with the
identifying information necessary for Plaintiffs to interact with the insurer.
824. On or about September 26, 2014, Plaintiffs began providing mental health
and/or substance abuse treatment to Patient 158.
825. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Cross or Northeastern Pennsylvania Blue on the
industry-standard UB-04 form. Plaintiffs indicated that it was requesting that benefits
be paid to it as an assignee by inserting the letter Y in the appropriate field (box 53)
each time it submitted a claim.
826. On information and belief: California Blue Cross, Northeastern
Pennsylvania Blue, and/or the Experian Plan thereafter paid some or all of the assigned
benefits to Patient 158 instead of Plaintiffs.
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 227 of 360 Page ID #:61847
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159 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
PATIENT 159
827. On information and belief: Patient 159 was a participant in or beneficiary
of Defendant MediaNews Plan during all times relevant to this complaint.
828. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the MediaNews Plan either (i) is insured by Colorado Blue
and/or California Blue Cross or (ii) is self-insured and has entered into an agreement
with Colorado Blue and/or California Blue Cross by which the MediaNews Plan
receives third party administrative services.
829. Plaintiffs obtained an assignment of benefits from Patient 159, who
executed an assignment in the same or substantially similar form to the document
attached hereto as Exhibit B.
830. On or about July 28, 2014, Plaintiffs secured Patient 159’s consent to
contact Colorado Blue and/or California Blue Cross, along with the identifying
information necessary for Plaintiffs to interact with the insurer.
831. On or about July 28, 2014, Plaintiffs or their agents contacted the Provider
Hotline of Colorado Blue and/or California Blue Cross and requested details about
Patient 159’s coverage. Plaintiffs or their agents recorded the information learned from
Colorado Blue and/or California Blue Cross on the bottom of Patient 159’s Insurance
Verification Form. Plaintiffs or their agents learned from Colorado Blue and/or
California Blue Cross that Patient 159’s benefits were not assignable. Plaintiffs or their
agents recorded this by circling “No” next to the line “Assignable” on Patient 159’s
Insurance Verification Form.
832. On or about October 2, 2014, Plaintiffs began providing mental health
and/or substance abuse treatment to Patient 159.
833. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Cross or Colorado Blue on the industry-standard UB-
04 form. Plaintiffs indicated that it was requesting that benefits be paid to it as an
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 228 of 360 Page ID #:61848
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160 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
assignee by inserting the letter Y in the appropriate field (box 53) each time it submitted
a claim.
834. On information and belief: California Blue Cross, Colorado Blue, and/or
the MediaNews Plan thereafter paid some or all of the assigned benefits to Patient 159
instead of Plaintiffs.
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 229 of 360 Page ID #:61849
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161 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
PATIENT 162
835. On information and belief: Patient 162 was a participant in or beneficiary
of Defendant WF Plan during all times relevant to this complaint.
836. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the WF Plan either (i) is insured by Ohio Blue and/or
California Blue Cross or (ii) is self-insured and has entered into an agreement with
Ohio Blue and/or California Blue Cross by which the WF Plan receives third party
administrative services.
837. Plaintiffs obtained an assignment of benefits from Patient 162, who
executed an assignment in the same or substantially similar form to the document
attached hereto as Exhibit A.
838. On or about June 7, 2012, Plaintiffs secured Patient 162’s consent to
contact Ohio Blue and/or California Blue Cross, along with the identifying information
necessary for Plaintiffs to interact with the insurer.
839. On or about June 8, 2012, Plaintiffs began providing mental health and/or
substance abuse treatment to Patient 162.
840. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Cross or Ohio Blue on the industry-standard UB-04
form. Plaintiffs indicated that it was requesting that benefits be paid to it as an assignee
by inserting the letter Y in the appropriate field (box 53) each time it submitted a claim.
841. On information and belief: California Blue Cross, Ohio Blue, and/or the
WF Plan thereafter paid some or all of the assigned benefits to Patient 162 instead of
Plaintiffs.
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 230 of 360 Page ID #:61850
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162 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
PATIENT 163
842. On information and belief: Patient 163 was a participant in or beneficiary
of Defendant Sallie Mae Plan during all times relevant to this complaint.
843. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the Sallie Mae Plan either (i) is insured by Virginia Blue
and/or California Blue Cross or (ii) is self-insured and has entered into an agreement
with Virginia Blue and/or California Blue Cross by which the Sallie Mae Plan receives
third party administrative services.
844. Plaintiffs obtained an assignment of benefits from Patient 163, who
executed an assignment in the same or substantially similar form to the document
attached hereto as Exhibit B.
845. On or about April 16, 2014, Plaintiffs secured Patient 163’s consent to
contact Virginia Blue and/or California Blue Cross, along with the identifying
information necessary for Plaintiffs to interact with the insurer.
846. On or about April 16, 2014, Plaintiffs or their agents contacted the
Provider Hotline of Virginia Blue and/or California Blue Cross and requested details
about Patient 163’s coverage. Plaintiffs or their agents recorded the information
learned from Virginia Blue and/or California Blue Cross on the bottom of Patient 163’s
Insurance Verification Form. Plaintiffs or their agents learned from Virginia Blue
and/or California Blue Cross that Patient 163’s benefits were assignable. Plaintiffs or
their agents recorded this by circling “Yes” next to the line “Assignable” on Patient
163’s Insurance Verification Form.
847. On or about April 25, 2014, Plaintiffs began providing mental health
and/or substance abuse treatment to Patient 163.
848. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Cross or Virginia Blue on the industry-standard UB-
04 form. Plaintiffs indicated that it was requesting that benefits be paid to it as an
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 231 of 360 Page ID #:61851
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163 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
assignee by inserting the letter Y in the appropriate field (box 53) each time it submitted
a claim.
849. On information and belief: California Blue Cross, Virginia Blue, and/or
the Sallie Mae Plan thereafter paid some or all of the assigned benefits to Patient 163
instead of Plaintiffs.
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 232 of 360 Page ID #:61852
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164 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
PATIENT 164
850. On information and belief: Patient 164 was a participant in or beneficiary
of Defendant Active Power Plan during all times relevant to this complaint.
851. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the Active Power Plan either (i) is insured by Texas Blue
and/or California Blue Cross or (ii) is self-insured and has entered into an agreement
with Texas Blue and/or California Blue Cross by which the Active Power Plan receives
third party administrative services.
852. Plaintiffs obtained an assignment of benefits from Patient 164, who
executed an assignment in the same or substantially similar form to the document
attached hereto as Exhibit B.
853. On or about August 26, 2014, Plaintiffs secured Patient 164’s consent to
contact Texas Blue and/or California Blue Cross, along with the identifying
information necessary for Plaintiffs to interact with the insurer.
854. On or about September 4, 2014, Plaintiffs began providing mental health
and/or substance abuse treatment to Patient 164.
855. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Cross or Texas Blue on the industry-standard UB-04
form. Plaintiffs indicated that it was requesting that benefits be paid to it as an assignee
by inserting the letter Y in the appropriate field (box 53) each time it submitted a claim.
856. On information and belief: California Blue Cross, Texas Blue, and/or the
Active Power Plan thereafter paid some or all of the assigned benefits to Patient 164
instead of Plaintiffs.
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 233 of 360 Page ID #:61853
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165 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
PATIENT 165
857. On information and belief: Patient 165 was a participant in or beneficiary
of Defendant Machinists Plan during all times relevant to this complaint.
858. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the Machinists Plan either (i) is insured by Washington
Regence Blue and/or California Blue Cross or (ii) is self-insured and has entered into
an agreement with Washington Regence Blue and/or California Blue Cross by which
the Machinists Plan receives third party administrative services.
859. Plaintiffs obtained an assignment of benefits from Patient 165, who
executed an assignment in the same or substantially similar form to the document
attached hereto as Exhibit A.
860. On or about June 20, 2014, Plaintiffs secured Patient 165’s consent to
contact Washington Regence Blue and/or California Blue Cross, along with the
identifying information necessary for Plaintiffs to interact with the insurer.
861. On or about June 20, 2014, Plaintiffs or their agents contacted the Provider
Hotline of Washington Regence Blue and/or California Blue Cross and requested
details about Patient 165’s coverage. Plaintiffs or their agents recorded the information
learned from Washington Regence Blue and/or California Blue Cross on the bottom of
Patient 165’s Insurance Verification Form. Plaintiffs or their agents learned from
Washington Regence Blue and/or California Blue Cross that Patient 165’s benefits
were not assignable. Plaintiffs or their agents recorded this by circling “No” next to the
line “Assignable” on Patient 165’s Insurance Verification Form.
862. On or about July 2, 2014, Plaintiffs began providing mental health and/or
substance abuse treatment to Patient 165.
863. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Cross or Washington Regence Blue on the industry-
standard UB-04 form. Plaintiffs indicated that it was requesting that benefits be paid
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 234 of 360 Page ID #:61854
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166 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
to it as an assignee by inserting the letter Y in the appropriate field (box 53) each time
it submitted a claim.
864. On information and belief: California Blue Cross, Washington Regence
Blue, and/or the Machinists Plan thereafter paid some or all of the assigned benefits to
Patient 165 instead of Plaintiffs.
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 235 of 360 Page ID #:61855
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167 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
PATIENT 166
865. On information and belief: Patient 166 was a participant in or beneficiary
of Defendant Mueller Plan during all times relevant to this complaint.
866. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the Mueller Plan either (i) is insured by Alabama Blue,
Illinois Blue, and/or California Blue Cross or (ii) is self-insured and has entered into
an agreement with Alabama Blue, Illinois Blue, and/or California Blue Cross by which
the Mueller Plan receives third party administrative services.
867. Plaintiffs obtained an assignment of benefits from Patient 166, who
executed an assignment in the same or substantially similar form to the document
attached hereto as Exhibit B.
868. On or about September 8, 2014, Plaintiffs secured Patient 166’s consent
to contact Alabama Blue, Illinois Blue, and/or California Blue Cross, along with the
identifying information necessary for Plaintiffs to interact with the insurer.
869. On or about September 17, 2014, Plaintiffs began providing mental health
and/or substance abuse treatment to Patient 166.
870. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Cross, Illinois Blue, or Alabama Blue on the industry-
standard UB-04 form. Plaintiffs indicated that it was requesting that benefits be paid
to it as an assignee by inserting the letter Y in the appropriate field (box 53) each time
it submitted a claim.
871. On information and belief: California Blue Cross, Illinois Blue, Alabama
Blue, and/or the Mueller Plan thereafter paid some or all of the assigned benefits to
Patient 166 instead of Plaintiffs.
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 236 of 360 Page ID #:61856
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168 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
PATIENT 167
872. On information and belief: Patient 167 was a participant in or beneficiary
of Defendant CNS Plan during all times relevant to this complaint.
873. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the CNS Plan either (i) is insured by California Blue Cross
or (ii) is self-insured and has entered into an agreement with California Blue Cross by
which the CNS Plan receives third party administrative services.
874. Plaintiffs obtained an assignment of benefits from Patient 167, who
executed an assignment in the same or substantially similar form to the document
attached hereto as Exhibit B.
875. On or about October 6, 2014, Plaintiffs secured Patient 167’s consent to
contact California Blue Cross, along with the identifying information necessary for
Plaintiffs to interact with the insurer.
876. On or about October 13, 2014, Plaintiffs began providing mental health
and/or substance abuse treatment to Patient 167.
877. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Cross on the industry-standard UB-04 form. Plaintiffs
indicated that it was requesting that benefits be paid to it as an assignee by inserting
the letter Y in the appropriate field (box 53) each time it submitted a claim.
878. On information and belief: California Blue Cross and/or the CNS Plan
thereafter paid some or all of the assigned benefits to Patient 167 instead of Plaintiffs.
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 237 of 360 Page ID #:61857
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169 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
PATIENT 168
879. On information and belief: Patient 168 was a participant in or beneficiary
of the Group Welfare Plan For Quest Diagnostics Incorporated (the “Quest Plan”)
during all times relevant to this complaint.
880. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the Quest Plan either (i) is insured by New Jersey Blue
and/or California Blue Cross or (ii) is self-insured and has entered into an agreement
with New Jersey Blue and/or California Blue Cross by which the Quest Plan receives
third party administrative services.
881. Plaintiffs obtained an assignment of benefits from Patient 168, who
executed an assignment in the same or substantially similar form to the document
attached hereto as Exhibit A.
882. On or about March 3, 2014, Plaintiffs secured Patient 168’s consent to
contact New Jersey Blue and/or California Blue Cross, along with the identifying
information necessary for Plaintiffs to interact with the insurer.
883. On or about March 19, 2014, Plaintiffs began providing mental health
and/or substance abuse treatment to Patient 168.
884. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Cross or New Jersey Blue on the industry-standard
UB-04 form. Plaintiffs indicated that it was requesting that benefits be paid to it as an
assignee by inserting the letter Y in the appropriate field (box 53) each time it submitted
a claim.
885. On information and belief: California Blue Cross, New Jersey Blue,
and/or the Quest Plan thereafter paid some or all of the assigned benefits to Patient 168
instead of Plaintiffs.
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 238 of 360 Page ID #:61858
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170 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
PATIENT 169
886. On information and belief: Patient 169 was a participant in or beneficiary
of the Alliant Insurance Services Welfare Benefits Plan (the “Alliant Plan”) during all
times relevant to this complaint.
887. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the Alliant Plan either (i) is insured by California Blue Cross
or (ii) is self-insured and has entered into an agreement with California Blue Cross by
which the Alliant Plan receives third party administrative services.
888. Plaintiffs obtained an assignment of benefits from Patient 169, who
executed an assignment in the same or substantially similar form to the document
attached hereto as Exhibit B.
889. On or about July 2, 2014, Plaintiffs secured Patient 169’s consent to
contact California Blue Cross, along with the identifying information necessary for
Plaintiffs to interact with the insurer.
890. On or about July 2, 2014, Plaintiffs or their agents contacted the Provider
Hotline of California Blue Cross and requested details about Patient 169’s coverage.
Plaintiffs or their agents recorded the information learned from California Blue Cross
on the bottom of Patient 169’s Insurance Verification Form. Plaintiffs or their agents
learned from California Blue Cross that Patient 169’s benefits were not assignable.
Plaintiffs or their agents recorded this by circling “No” next to the line “Assignable”
on Patient 169’s Insurance Verification Form.
891. On or about July 17, 2014, Plaintiffs began providing mental health and/or
substance abuse treatment to Patient 169.
892. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Cross on the industry-standard UB-04 form. Plaintiffs
indicated that it was requesting that benefits be paid to it as an assignee by inserting
the letter Y in the appropriate field (box 53) each time it submitted a claim.
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 239 of 360 Page ID #:61859
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171 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
893. On information and belief: California Blue Cross and/or the Alliant Plan
thereafter paid some or all of the assigned benefits to Patient 169 instead of Plaintiffs.
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 240 of 360 Page ID #:61860
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172 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
PATIENT 170
894. On information and belief: Patient 170 was a participant in or beneficiary
of Defendant H.E. Butt Grocery Plan during all times relevant to this complaint.
895. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the H.E. Butt Grocery Plan either (i) is insured by Texas
Blue and/or California Blue Cross or (ii) is self-insured and has entered into an
agreement with Texas Blue and/or California Blue Cross by which the H.E. Butt
Grocery Plan receives third party administrative services.
896. Plaintiffs obtained an assignment of benefits from Patient 170, who
executed an assignment in the same or substantially similar form to the document
attached hereto as Exhibit A.
897. On or about February 6, 2014, Plaintiffs secured Patient 170’s consent to
contact Texas Blue and/or California Blue Cross, along with the identifying
information necessary for Plaintiffs to interact with the insurer.
898. On or about February 11, 2014, Plaintiffs began providing mental health
and/or substance abuse treatment to Patient 170.
899. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Cross or Texas Blue on the industry-standard UB-04
form. Plaintiffs indicated that it was requesting that benefits be paid to it as an assignee
by inserting the letter Y in the appropriate field (box 53) each time it submitted a claim.
900. On information and belief: California Blue Cross, Texas Blue, and/or the
H.E. Butt Grocery Plan thereafter paid some or all of the assigned benefits to Patient
170 instead of Plaintiffs.
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 241 of 360 Page ID #:61861
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173 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
PATIENT 171
901. On information and belief: Patient 171 was a participant in or beneficiary
of Defendant 3M Plan during all times relevant to this complaint.
902. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the 3M Plan either (i) is insured by Minnesota Blue and/or
California Blue Cross or (ii) is self-insured and has entered into an agreement with
Minnesota Blue and/or California Blue Cross by which the 3M Plan receives third party
administrative services.
903. Plaintiffs obtained an assignment of benefits from Patient 171, who
executed an assignment in the same or substantially similar form to the document
attached hereto as Exhibit A.
904. On or about July 31, 2014, Plaintiffs secured Patient 171’s consent to
contact Minnesota Blue and/or California Blue Cross, along with the identifying
information necessary for Plaintiffs to interact with the insurer.
905. On or about July 31, 2014, Plaintiffs or their agents contacted the Provider
Hotline of Minnesota Blue and/or California Blue Cross and requested details about
Patient 171’s coverage. Plaintiffs or their agents recorded the information learned from
Minnesota Blue and/or California Blue Cross on the bottom of Patient 171’s Insurance
Verification Form. Plaintiffs or their agents learned from Minnesota Blue and/or
California Blue Cross that Patient 171’s benefits were assignable. Plaintiffs or their
agents recorded this by circling “Yes” next to the line “Assignable” on Patient 171’s
Insurance Verification Form.
906. On or about January 17, 2013, Plaintiffs began providing mental health
and/or substance abuse treatment to Patient 171.
907. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Cross or Minnesota Blue on the industry-standard
UB-04 form. Plaintiffs indicated that it was requesting that benefits be paid to it as an
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 242 of 360 Page ID #:61862
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174 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
assignee by inserting the letter Y in the appropriate field (box 53) each time it submitted
a claim.
908. On information and belief: California Blue Cross, Minnesota Blue, and/or
the 3M Plan thereafter paid some or all of the assigned benefits to Patient 171 instead
of Plaintiffs.
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 243 of 360 Page ID #:61863
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175 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
PATIENT 172
909. On information and belief: Patient 172 was a participant in or beneficiary
of an unknown ERISA-governed welfare plan during all times relevant to this
complaint.
910. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the unknown plan either (i) is insured by Indiana Blue
and/or California Blue Cross or (ii) is self-insured and has entered into an agreement
with Indiana Blue and/or California Blue Cross by which the unknown plan receives
third party administrative services.
911. Plaintiffs obtained an assignment of benefits from Patient 172, who
executed an assignment in the same or substantially similar form to the document
attached hereto as Exhibit B.
912. On or about April 28, 2014, Plaintiffs secured Patient 172’s consent to
contact Indiana Blue and/or California Blue Cross, along with the identifying
information necessary for Plaintiffs to interact with the insurer.
913. On or about May 5 2014, Plaintiffs began providing mental health and/or
substance abuse treatment to Patient 172.
914. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Cross or Indiana Blue on the industry-standard UB-
04 form. Plaintiffs indicated that it was requesting that benefits be paid to it as an
assignee by inserting the letter Y in the appropriate field (box 53) each time it submitted
a claim.
915. On information and belief: California Blue Cross, Indiana Blue, and/or
the unknown plan thereafter paid some or all of the assigned benefits to Patient 172
instead of Plaintiffs.
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 244 of 360 Page ID #:61864
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176 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
PATIENT 173
916. On information and belief: Patient 173 was a participant in or beneficiary
of Defendant Publix Plan during all times relevant to this complaint.
917. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the Publix Plan either (i) is insured by Florida Blue and/or
California Blue Cross or (ii) is self-insured and has entered into an agreement with
Florida Blue and/or California Blue Cross by which the Publix Plan receives third party
administrative services.
918. Plaintiffs obtained an assignment of benefits from Patient 173, who
executed an assignment in the same or substantially similar form to the document
attached hereto as Exhibit B.
919. On or about August 26, 2014, Plaintiffs secured Patient 173’s consent to
contact Florida Blue and/or California Blue Cross, along with the identifying
information necessary for Plaintiffs to interact with the insurer.
920. On or about August 26, 2014, Plaintiffs or their agents contacted the
Provider Hotline of Florida Blue and/or California Blue Cross and requested details
about Patient 173’s coverage. Plaintiffs or their agents recorded the information
learned from Florida Blue and/or California Blue Cross on the bottom of Patient 173’s
Insurance Verification Form. Plaintiffs or their agents learned from Florida Blue and/or
California Blue Cross that Patient 173’s benefits were assignable. Plaintiffs or their
agents recorded this by circling “Yes” next to the line “Assignable” on Patient 173’s
Insurance Verification Form.
921. On or about September 3, 2014, Plaintiffs began providing mental health
and/or substance abuse treatment to Patient 173.
922. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Cross or Florida Blue on the industry-standard UB-
04 form. Plaintiffs indicated that it was requesting that benefits be paid to it as an
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 245 of 360 Page ID #:61865
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177 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
assignee by inserting the letter Y in the appropriate field (box 53) each time it submitted
a claim.
923. On information and belief: California Blue Cross, Florida Blue, and/or the
Publix Plan thereafter paid some or all of the assigned benefits to Patient 173 instead
of Plaintiffs.
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 246 of 360 Page ID #:61866
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178 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
PATIENT 174
924. On information and belief: Patient 174 was a participant in or beneficiary
of Defendant CHS Group Plan during all times relevant to this complaint.
925. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the CHS Group Plan either (i) is insured by Tennessee Blue
and/or California Blue Cross or (ii) is self-insured and has entered into an agreement
with Tennessee Blue and/or California Blue Cross by which the CHS Group Plan
receives third party administrative services.
926. Plaintiffs obtained an assignment of benefits from Patient 174, who
executed an assignment in the same or substantially similar form to the document
attached hereto as Exhibit A.
927. On or about October 30, 2013, Plaintiffs secured Patient 174’s consent to
contact Tennessee Blue and/or California Blue Cross, along with the identifying
information necessary for Plaintiffs to interact with the insurer.
928. On or about November 1, 2013, Plaintiffs began providing mental health
and/or substance abuse treatment to Patient 174.
929. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Cross or Tennessee Blue on the industry-standard
UB-04 form. Plaintiffs indicated that it was requesting that benefits be paid to it as an
assignee by inserting the letter Y in the appropriate field (box 53) each time it submitted
a claim.
930. On information and belief: California Blue Cross, Tennessee Blue, and/or
the CHS Group Plan thereafter paid some or all of the assigned benefits to Patient 174
instead of Plaintiffs.
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 247 of 360 Page ID #:61867
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179 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
PATIENT 175
931. On information and belief: Patient 175 was a participant in or beneficiary
of Defendant USUI Plan during all times relevant to this complaint.
932. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the USUI Plan either (i) is insured by Michigan Blue and/or
California Blue Cross or (ii) is self-insured and has entered into an agreement with
Michigan Blue and/or California Blue Cross by which the USUI Plan receives third
party administrative services.
933. Plaintiffs obtained an assignment of benefits from Patient 175, who
executed an assignment in the same or substantially similar form to the document
attached hereto as Exhibit B.
934. On or about September 5, 2014, Plaintiffs secured Patient 175’s consent
to contact Michigan Blue and/or California Blue Cross, along with the identifying
information necessary for Plaintiffs to interact with the insurer.
935. On or about September 15, 2014, Plaintiffs began providing mental health
and/or substance abuse treatment to Patient 175.
936. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Cross or Michigan Blue on the industry-standard UB-
04 form. Plaintiffs indicated that it was requesting that benefits be paid to it as an
assignee by inserting the letter Y in the appropriate field (box 53) each time it submitted
a claim.
937. On information and belief: California Blue Cross, Michigan Blue, and/or
the USUI Plan thereafter paid some or all of the assigned benefits to Patient 175 instead
of Plaintiffs.
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 248 of 360 Page ID #:61868
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180 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
PATIENT 176
938. On information and belief: Patient 176 was a participant in or beneficiary
of Defendant Transport America Plan during all times relevant to this complaint.
939. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the Transport America Plan either (i) is insured by
Minnesota Blue and/or California Blue Cross or (ii) is self-insured and has entered into
an agreement with Minnesota Blue and/or California Blue Cross by which the
Transport America Plan receives third party administrative services.
940. Plaintiffs obtained an assignment of benefits from Patient 176, who
executed an assignment in the same or substantially similar form to the document
attached hereto as Exhibit B.
941. On or about April 10, 2014, Plaintiffs secured Patient 176’s consent to
contact Minnesota Blue and/or California Blue Cross, along with the identifying
information necessary for Plaintiffs to interact with the insurer.
942. On or about April 11, 2014, Plaintiffs began providing mental health
and/or substance abuse treatment to Patient 176.
943. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Cross or Minnesota Blue on the industry-standard
UB-04 form. Plaintiffs indicated that it was requesting that benefits be paid to it as an
assignee by inserting the letter Y in the appropriate field (box 53) each time it submitted
a claim.
944. On information and belief: California Blue Cross, Minnesota Blue, and/or
the Transport America Plan thereafter paid some or all of the assigned benefits to
Patient 176 instead of Plaintiffs.
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 249 of 360 Page ID #:61869
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181 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
PATIENT 177
945. On information and belief: Patient 177 was a participant in or beneficiary
of the Frank Calandra, Inc. Medical Plan (the “JENNMAR Plan”) during all times
relevant to this complaint.
946. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the JENNMAR Plan either (i) is insured by Western
Pennsylvania Blue, Highmark, and/or California Blue Cross or (ii) is self-insured and
has entered into an agreement with Western Pennsylvania Blue, Highmark, and/or
California Blue Cross by which the JENNMAR Plan receives third party administrative
services.
947. Plaintiffs obtained an assignment of benefits from Patient 177, who
executed an assignment in the same or substantially similar form to the document
attached hereto as Exhibit A.
948. On or about July 15, 2014, Plaintiffs secured Patient 177’s consent to
contact Western Pennsylvania Blue, Highmark, and/or California Blue Cross, along
with the identifying information necessary for Plaintiffs to interact with the insurer.
949. On or about July 18, 2014, Plaintiffs began providing mental health and/or
substance abuse treatment to Patient 177.
950. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Cross, Western Pennsylvania Blue, or Highmark on
the industry-standard UB-04 form. Plaintiffs indicated that it was requesting that
benefits be paid to it as an assignee by inserting the letter Y in the appropriate field
(box 53) each time it submitted a claim.
951. On information and belief: California Blue Cross, Western Pennsylvania
Blue, Highmark, and/or the JENNMAR Plan thereafter paid some or all of the assigned
benefits to Patient 177 instead of Plaintiffs.
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 250 of 360 Page ID #:61870
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182 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
PATIENT 178
952. On information and belief: Patient 178 was a participant in or beneficiary
of Defendant Fresenius Plan during all times relevant to this complaint.
953. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the Fresenius Plan either (i) is insured by Massachusetts
Blue and/or California Blue Cross or (ii) is self-insured and has entered into an
agreement with by Massachusetts Blue and/or California Blue Cross by which the
Fresenius Plan receives third party administrative services.
954. Plaintiffs obtained an assignment of benefits from Patient 178, who
executed an assignment in the same or substantially similar form to the document
attached hereto as Exhibit B.
955. On or about September 18, 2014, Plaintiffs secured Patient 178’s consent
to contact Massachusetts Blue and/or California Blue Cross, along with the identifying
information necessary for Plaintiffs to interact with the insurer.
956. On or about September 18, 2014, Plaintiffs or their agents contacted the
Provider Hotline of Massachusetts Blue and/or California Blue Cross and requested
details about Patient 178’s coverage. Plaintiffs or their agents recorded the information
learned from Massachusetts Blue and/or California Blue Cross on the bottom of Patient
178’s Insurance Verification Form. Plaintiffs or their agents learned from
Massachusetts Blue and/or California Blue Cross that Patient 178’s benefits were
assignable. Plaintiffs or their agents recorded this by circling “Yes” next to the line
“Assignable” on Patient 178’s Insurance Verification Form.
957. On or about September 24, 2014, Plaintiffs began providing mental health
and/or substance abuse treatment to Patient 178.
958. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Cross or by Massachusetts Blue on the industry-
standard UB-04 form. Plaintiffs indicated that it was requesting that benefits be paid
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 251 of 360 Page ID #:61871
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183 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
to it as an assignee by inserting the letter Y in the appropriate field (box 53) each time
it submitted a claim.
959. On information and belief: California Blue Cross, by Massachusetts Blue,
and/or the Fresenius Plan thereafter paid some or all of the assigned benefits to Patient
178 instead of Plaintiffs.
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 252 of 360 Page ID #:61872
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184 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
PATIENT 179
960. On information and belief: Patient 179 was a participant in or beneficiary
of Defendant Steak N Shake Plan during all times relevant to this complaint.
961. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the Steak N Shake Plan either (i) is insured by Indiana Blue
and/or California Blue Cross or (ii) is self-insured and has entered into an agreement
with Indiana Blue and/or California Blue Cross by which the Steak N Shake Plan
receives third party administrative services.
962. Plaintiffs obtained an assignment of benefits from Patient 179, who
executed an assignment in the same or substantially similar form to the document
attached hereto as Exhibit B.
963. On or about January 22, 2015, Plaintiffs secured Patient 179’s consent to
contact Indiana Blue and/or California Blue Cross, along with the identifying
information necessary for Plaintiffs to interact with the insurer.
964. On or about January 22, 2015, Plaintiffs or their agents contacted the
Provider Hotline of Indiana Blue and/or California Blue Cross and requested details
about Patient 179’s coverage. Plaintiffs or their agents recorded the information
learned from Indiana Blue and/or California Blue Cross on the bottom of Patient 179’s
Insurance Verification Form. Plaintiffs or their agents learned from Indiana Blue
and/or California Blue Cross that Patient 179’s benefits were not assignable. Plaintiffs
or their agents recorded this by circling “No” next to the line “Assignable” on Patient
179’s Insurance Verification Form.
965. On or about January 22, 2015, Plaintiffs began providing mental health
and/or substance abuse treatment to Patient 179.
966. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Cross or Indiana Blue on the industry-standard UB-
04 form. Plaintiffs indicated that it was requesting that benefits be paid to it as an
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 253 of 360 Page ID #:61873
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185 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
assignee by inserting the letter Y in the appropriate field (box 53) each time it submitted
a claim.
967. On information and belief: California Blue Cross, Indiana Blue, and/or
the Steak N Shake Plan thereafter paid some or all of the assigned benefits to Patient
179 instead of Plaintiffs.
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 254 of 360 Page ID #:61874
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186 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
PATIENT 180
968. On information and belief: Patient 180 was a participant in or beneficiary
of the ACE Surgical Supply Co., Inc. Employee Welfare Benefits Plan (the “ACE
Surgical Plan”) during all times relevant to this complaint.
969. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the ACE Surgical Plan either (i) is insured by Massachusetts
Blue and/or California Blue Cross or (ii) is self-insured and has entered into an
agreement with Massachusetts Blue and/or California Blue Cross by which the ACE
Surgical Plan receives third party administrative services.
970. Plaintiffs obtained an assignment of benefits from Patient 180, who
executed an assignment in the same or substantially similar form to the document
attached hereto as Exhibit B.
971. On or about February 24, 2014, Plaintiffs secured Patient 180’s consent
to contact Massachusetts Blue and/or California Blue Cross, along with the identifying
information necessary for Plaintiffs to interact with the insurer.
972. On or about March 10, 2015, Plaintiffs began providing mental health
and/or substance abuse treatment to Patient 180.
973. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Cross or Massachusetts Blue on the industry-standard
UB-04 form. Plaintiffs indicated that it was requesting that benefits be paid to it as an
assignee by inserting the letter Y in the appropriate field (box 53) each time it submitted
a claim.
974. On information and belief: California Blue Cross, Massachusetts Blue,
and/or the ACE Surgical Plan thereafter paid some or all of the assigned benefits to
Patient 180 instead of Plaintiffs.
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 255 of 360 Page ID #:61875
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187 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
PATIENT 183
975. On information and belief: Patient 183 was a participant in or beneficiary
of Defendant S.W. Shipyard Plan during all times relevant to this complaint.
976. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the S.W. Shipyard Plan either (i) is insured by Texas Blue
and/or California Blue Cross or (ii) is self-insured and has entered into an agreement
with Texas Blue and/or California Blue Cross by which the S.W. Shipyard Plan
receives third party administrative services.
977. Plaintiffs obtained an assignment of benefits from Patient 183, who
executed an assignment in the same or substantially similar form to the document
attached hereto as Exhibit B.
978. On or about May 13, 2013, Plaintiffs secured Patient 183’s consent to
contact Texas Blue and/or California Blue Cross, along with the identifying
information necessary for Plaintiffs to interact with the insurer.
979. On or about December 8, 2015, Plaintiffs or their agents contacted the
Provider Hotline of Texas Blue and/or California Blue Cross and requested details
about Patient 183’s coverage. Plaintiffs or their agents recorded the information
learned from Texas Blue and/or California Blue Cross on the bottom of Patient 183’s
Insurance Verification Form. Plaintiffs or their agents learned from Texas Blue and/or
California Blue Cross that Patient 183’s benefits were not assignable. Plaintiffs or their
agents recorded this by circling “No” next to the line “Assignable” on Patient 183’s
Insurance Verification Form.
980. On or about December 11, 2014, Plaintiffs began providing mental health
and/or substance abuse treatment to Patient 183.
981. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Cross or Texas Blue on the industry-standard UB-04
form. Plaintiffs indicated that it was requesting that benefits be paid to it as an assignee
by inserting the letter Y in the appropriate field (box 53) each time it submitted a claim.
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 256 of 360 Page ID #:61876
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188 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
982. On information and belief: California Blue Cross, Texas Blue, and/or the
S.W. Shipyard Plan thereafter paid some or all of the assigned benefits to Patient 183
instead of Plaintiffs.
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 257 of 360 Page ID #:61877
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189 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
PATIENT 184
983. On information and belief: Patient 184 was a participant in or beneficiary
of Defendant F5 Plan during all times relevant to this complaint.
984. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the F5 Plan either (i) is insured by Washington Premera
Blue and/or California Blue Cross or (ii) is self-insured and has entered into an
agreement with Washington Premera Blue and/or California Blue Cross by which the
F5 Plan receives third party administrative services.
985. Plaintiffs obtained an assignment of benefits from Patient 184, who
executed an assignment in the same or substantially similar form to the document
attached hereto as Exhibit B.
986. On or about February 25, 2015, Plaintiffs secured Patient 184’s consent
to contact Washington Premera Blue and/or California Blue Cross, along with the
identifying information necessary for Plaintiffs to interact with the insurer.
987. On or about February 25, 2015, Plaintiffs or their agents contacted the
Provider Hotline of Washington Premera Blue and/or California Blue Cross and
requested details about Patient 184’s coverage. Plaintiffs or their agents recorded the
information learned from Washington Premera Blue and/or California Blue Cross on
the bottom of Patient 184’s Insurance Verification Form. Plaintiffs or their agents
learned from Washington Premera Blue and/or California Blue Cross that Patient 184’s
benefits were not assignable. Plaintiffs or their agents recorded this by circling “No”
next to the line “Assignable” on Patient 184’s Insurance Verification Form.
988. On or about March 16, 2015, Plaintiffs began providing mental health
and/or substance abuse treatment to Patient 184.
989. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Cross or Washington Premera Blue on the industry-
standard UB-04 form. Plaintiffs indicated that it was requesting that benefits be paid
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 258 of 360 Page ID #:61878
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190 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
to it as an assignee by inserting the letter Y in the appropriate field (box 53) each time
it submitted a claim.
990. On information and belief: California Blue Cross, Washington Premera
Blue, and/or the F5 Plan thereafter paid some or all of the assigned benefits to Patient
184 instead of Plaintiffs.
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 259 of 360 Page ID #:61879
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191 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
PATIENT 185
991. On information and belief: Patient 185 was a participant in or beneficiary
of Defendant MDU Plan during all times relevant to this complaint.
992. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the MDU Plan either (i) is insured by Minnesota Blue and/or
California Blue Cross or (ii) is self-insured and has entered into an agreement with
Minnesota Blue and/or California Blue Cross by which the MDU Plan receives third
party administrative services.
993. Plaintiffs obtained an assignment of benefits from Patient 185, who
executed an assignment in the same or substantially similar form to the document
attached hereto as Exhibit B.
994. On or about October 23, 2014, Plaintiffs secured Patient 185’s consent to
contact Minnesota Blue and/or California Blue Cross, along with the identifying
information necessary for Plaintiffs to interact with the insurer.
995. On or about November 3, 2014, Plaintiffs began providing mental health
and/or substance abuse treatment to Patient 185.
996. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Cross or Minnesota Blue on the industry-standard
UB-04 form. Plaintiffs indicated that it was requesting that benefits be paid to it as an
assignee by inserting the letter Y in the appropriate field (box 53) each time it submitted
a claim.
997. On information and belief: California Blue Cross, Minnesota Blue, and/or
the MDU Plan thereafter paid some or all of the assigned benefits to Patient 185 instead
of Plaintiffs.
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 260 of 360 Page ID #:61880
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192 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
PATIENT 186
998. On information and belief: Patient 186 was a participant in or beneficiary
of the Racing Products Group Inc. Plan (the “Racing Products Plan”) during all times
relevant to this complaint.
999. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the Racing Products Plan either (i) is insured by Washington
Regence Blue and/or California Blue Cross or (ii) is self-insured and has entered into
an agreement with Washington Regence Blue and/or California Blue Cross by which
the Racing Products Plan receives third party administrative services.
1000. Plaintiffs obtained an assignment of benefits from Patient 186, who
executed an assignment in the same or substantially similar form to the document
attached hereto as Exhibit B.
1001. On or about May 6, 2015, Plaintiffs secured Patient 186’s consent to
contact Washington Regence Blue and/or California Blue Cross, along with the
identifying information necessary for Plaintiffs to interact with the insurer.
1002. On or about May 6, 2015, Plaintiffs or their agents contacted the Provider
Hotline of Washington Regence Blue and/or California Blue Cross and requested
details about Patient 186’s coverage. Plaintiffs or their agents recorded the information
learned from Washington Regence Blue and/or California Blue Cross on the bottom of
Patient 186’s Insurance Verification Form. Plaintiffs or their agents learned from
Washington Regence Blue and/or California Blue Cross that Patient 186’s benefits
were assignable. Plaintiffs or their agents recorded this by circling “Yes” next to the
line “Assignable” on Patient 186’s Insurance Verification Form.
1003. On or about May 4, 2015, Plaintiffs began providing mental health and/or
substance abuse treatment to Patient 186.
1004. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Cross or Washington Regence Blue on the industry-
standard UB-04 form. Plaintiffs indicated that it was requesting that benefits be paid
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 261 of 360 Page ID #:61881
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to it as an assignee by inserting the letter Y in the appropriate field (box 53) each time
it submitted a claim.
1005. On information and belief: California Blue Cross, Washington Regence
Blue, and/or the Racing Products Plan thereafter paid some or all of the assigned
benefits to Patient 186 instead of Plaintiffs.
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PATIENT 187
1006. On information and belief: Patient 187 was a participant in or beneficiary
of Defendant General Mills Plan during all times relevant to this complaint.
1007. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the General Mills Plan either (i) is insured by Minnesota
Blue and/or California Blue Cross or (ii) is self-insured and has entered into an
agreement with Minnesota Blue and/or California Blue Cross by which the General
Mills Plan receives third party administrative services.
1008. Plaintiffs obtained an assignment of benefits from Patient 187, who
executed an assignment in the same or substantially similar form to the document
attached hereto as Exhibit B.
1009. On or about December 2, 2014, Plaintiffs secured Patient 187’s consent
to contact Minnesota Blue and/or California Blue Cross, along with the identifying
information necessary for Plaintiffs to interact with the insurer.
1010. On or about December 2, 2014, Plaintiffs or their agents contacted the
Provider Hotline of Minnesota Blue and/or California Blue Cross and requested details
about Patient 187’s coverage. Plaintiffs or their agents recorded the information
learned from Minnesota Blue and/or California Blue Cross on the bottom of Patient
187’s Insurance Verification Form. Plaintiffs or their agents learned from Minnesota
Blue and/or California Blue Cross that Patient 187’s benefits were not assignable.
Plaintiffs or their agents recorded this by circling “No” next to the line “Assignable”
on Patient 187’s Insurance Verification Form.
1011. On or about March 16, 2015, Plaintiffs began providing mental health
and/or substance abuse treatment to Patient 187.
1012. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Cross or Minnesota Blue on the industry-standard
UB-04 form. Plaintiffs indicated that it was requesting that benefits be paid to it as an
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assignee by inserting the letter Y in the appropriate field (box 53) each time it submitted
a claim.
1013. On information and belief: California Blue Cross, Minnesota Blue, and/or
the General Mills Plan thereafter paid some or all of the assigned benefits to Patient
187 instead of Plaintiffs.
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 264 of 360 Page ID #:61884
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196 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
PATIENT 188
1014. On information and belief: Patient 188 was a participant in or beneficiary
of Defendant Northrop Grumman Plan during all times relevant to this complaint.
1015. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the Northrop Grumman Plan either (i) is insured by
California Blue Cross or (ii) is self-insured and has entered into an agreement with
California Blue Cross by which the Northrop Grumman Plan receives third party
administrative services.
1016. Plaintiffs obtained an assignment of benefits from Patient 188, who
executed an assignment in the same or substantially similar form to the document
attached hereto as Exhibit B.
1017. On or about November 13, 2014, Plaintiffs secured Patient 188’s consent
to contact California Blue Cross, along with the identifying information necessary for
Plaintiffs to interact with the insurer.
1018. On or about November 13, 2014, Plaintiffs or their agents contacted the
Provider Hotline of California Blue Cross and requested details about Patient 188’s
coverage. Plaintiffs or their agents recorded the information learned from California
Blue Cross on the bottom of Patient 188’s Insurance Verification Form. Plaintiffs or
their agents learned from California Blue Cross that Patient 188’s benefits were not
assignable. Plaintiffs or their agents recorded this by circling “No” next to the line
“Assignable” on Patient 188’s Insurance Verification Form.
1019. On or about November 18, 2014, Plaintiffs began providing mental health
and/or substance abuse treatment to Patient 188.
1020. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Cross on the industry-standard UB-04 form. Plaintiffs
indicated that it was requesting that benefits be paid to it as an assignee by inserting
the letter Y in the appropriate field (box 53) each time it submitted a claim.
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1021. On information and belief: California Blue Cross and/or the Northrop
Grumman Plan thereafter paid some or all of the assigned benefits to Patient 188
instead of Plaintiffs.
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198 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
PATIENT 189
1022. On information and belief: Patient 189 was a participant in or beneficiary
of the Sierra Nevada Brewing Co. Welfare Plan (the “Sierra Nevada Plan”) during all
times relevant to this complaint.
1023. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the Sierra Nevada Plan either (i) is insured by California
Blue Cross or (ii) is self-insured and has entered into an agreement with California
Blue Cross by which the Sierra Nevada Plan receives third party administrative
services.
1024. Plaintiffs obtained an assignment of benefits from Patient 189, who
executed an assignment in the same or substantially similar form to the document
attached hereto as Exhibit B.
1025. On or about January 12, 2015, Plaintiffs secured Patient 189’s consent to
contact California Blue Cross, along with the identifying information necessary for
Plaintiffs to interact with the insurer.
1026. On or about January 12, 2015, Plaintiffs or their agents contacted the
Provider Hotline of California Blue Cross and requested details about Patient 189’s
coverage. Plaintiffs or their agents recorded the information learned from California
Blue Cross on the bottom of Patient 189’s Insurance Verification Form. Plaintiffs or
their agents learned from California Blue Cross that Patient 189’s benefits were not
assignable. Plaintiffs or their agents recorded this by circling “No” next to the line
“Assignable” on Patient 189’s Insurance Verification Form.
1027. On or about January 22, 2015, Plaintiffs began providing mental health
and/or substance abuse treatment to Patient 189.
1028. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Cross on the industry-standard UB-04 form. Plaintiffs
indicated that it was requesting that benefits be paid to it as an assignee by inserting
the letter Y in the appropriate field (box 53) each time it submitted a claim.
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1029. On information and belief: California Blue Cross and/or the Sierra
Nevada Plan thereafter paid some or all of the assigned benefits to Patient 189 instead
of Plaintiffs.
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200 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
PATIENT 190
1030. On information and belief: Patient 190 was a participant in or beneficiary
of Defendant Rayonier Plan during all times relevant to this complaint.
1031. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the Rayonier Plan either (i) is insured by Florida Blue and/or
California Blue Cross or (ii) is self-insured and has entered into an agreement with
Florida Blue and/or California Blue Cross by which the Rayonier Plan receives third
party administrative services.
1032. Plaintiffs obtained an assignment of benefits from Patient 190, who
executed an assignment in the same or substantially similar form to the document
attached hereto as Exhibit B.
1033. On or about March 3, 2015, Plaintiffs secured Patient 190’s consent to
contact Florida Blue and/or California Blue Cross, along with the identifying
information necessary for Plaintiffs to interact with the insurer.
1034. On or about March 3, 2015, Plaintiffs or their agents contacted the
Provider Hotline of Florida Blue and/or California Blue Cross and requested details
about Patient 190’s coverage. Plaintiffs or their agents recorded the information
learned from Florida Blue and/or California Blue Cross on the bottom of Patient 190’s
Insurance Verification Form. Plaintiffs or their agents learned from Florida Blue and/or
California Blue Cross that Patient 190’s benefits were not assignable. Plaintiffs or their
agents recorded this by circling “No” next to the line “Assignable” on Patient 190’s
Insurance Verification Form.
1035. On or about March 17, 2015, Plaintiffs began providing mental health
and/or substance abuse treatment to Patient 190.
1036. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Cross or Florida Blue on the industry-standard UB-
04 form. Plaintiffs indicated that it was requesting that benefits be paid to it as an
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CASE NO. SACV15−0736 DOC (DFMx) 206541.1
assignee by inserting the letter Y in the appropriate field (box 53) each time it submitted
a claim.
1037. On information and belief: California Blue Cross, Florida Blue, and/or the
Rayonier Plan thereafter paid some or all of the assigned benefits to Patient 190 instead
of Plaintiffs.
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202 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
PATIENT 191
1038. On information and belief: Patient 191 was a participant in or beneficiary
of Defendant Ardent Plan during all times relevant to this complaint.
1039. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the Ardent Plan either (i) is insured by Oklahoma Blue
and/or California Blue Cross or (ii) is self-insured and has entered into an agreement
with Oklahoma Blue and/or California Blue Cross by which the Ardent Plan receives
third party administrative services.
1040. Plaintiffs obtained an assignment of benefits from Patient 191, who
executed an assignment in the same or substantially similar form to the document
attached hereto as Exhibit B.
1041. On or about April 27, 2015, Plaintiffs secured Patient 191’s consent to
contact Oklahoma Blue and/or California Blue Cross, along with the identifying
information necessary for Plaintiffs to interact with the insurer.
1042. On or about April 27, 2015, Plaintiffs or their agents contacted the
Provider Hotline of Oklahoma Blue and/or California Blue Cross and requested details
about Patient 191’s coverage. Plaintiffs or their agents recorded the information
learned from Oklahoma Blue and/or California Blue Cross on the bottom of Patient
191’s Insurance Verification Form. Plaintiffs or their agents learned from Oklahoma
Blue and/or California Blue Cross that Patient 191’s benefits were assignable.
Plaintiffs or their agents recorded this by circling “Yes” next to the line “Assignable”
on Patient 191’s Insurance Verification Form.
1043. On or about April 27, 2015, Plaintiffs began providing mental health
and/or substance abuse treatment to Patient 191.
1044. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Cross or Oklahoma Blue on the industry-standard
UB-04 form. Plaintiffs indicated that it was requesting that benefits be paid to it as an
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assignee by inserting the letter Y in the appropriate field (box 53) each time it submitted
a claim.
1045. On information and belief: California Blue Cross, Oklahoma Blue, and/or
the Ardent Plan thereafter paid some or all of the assigned benefits to Patient 191
instead of Plaintiffs.
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204 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
PATIENT 193
1046. On information and belief: Patient 193 was a participant in or beneficiary
of Defendant Ferguson Plan during all times relevant to this complaint.
1047. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the Ferguson Plan either (i) is insured by Virginia Blue
and/or California Blue Cross or (ii) is self-insured and has entered into an agreement
with Virginia Blue and/or California Blue Cross by which the Ferguson Plan receives
third party administrative services.
1048. Plaintiffs obtained an assignment of benefits from Patient 193, who
executed an assignment in the same or substantially similar form to the document
attached hereto as Exhibit B.
1049. On or about August 21, 2014, Plaintiffs secured Patient 193’s consent to
contact Virginia Blue and/or California Blue Cross, along with the identifying
information necessary for Plaintiffs to interact with the insurer.
1050. On or about August 22, 2014, Plaintiffs began providing mental health
and/or substance abuse treatment to Patient 193.
1051. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Cross or Virginia Blue on the industry-standard UB-
04 form. Plaintiffs indicated that it was requesting that benefits be paid to it as an
assignee by inserting the letter Y in the appropriate field (box 53) each time it submitted
a claim.
1052. On information and belief: California Blue Cross, Virginia Blue, and/or
the Ferguson Plan thereafter paid some or all of the assigned benefits to Patient 193
instead of Plaintiffs.
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 273 of 360 Page ID #:61893
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205 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
PATIENT 194
1053. On information and belief: Patient 194 was a participant in or beneficiary
of Defendant Hartford Plan during all times relevant to this complaint.
1054. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the Hartford Plan either (i) is insured by Indiana Blue and/or
California Blue Cross or (ii) is self-insured and has entered into an agreement with
Indiana Blue and/or California Blue Cross by which the Hartford Plan receives third
party administrative services.
1055. Plaintiffs obtained an assignment of benefits from Patient 194, who
executed an assignment in the same or substantially similar form to the document
attached hereto as Exhibit B.
1056. On or about May 12, 2015, Plaintiffs secured Patient 194’s consent to
contact Indiana Blue and/or California Blue Cross, along with the identifying
information necessary for Plaintiffs to interact with the insurer.
1057. On or about May 12, 2015, Plaintiffs or their agents contacted the Provider
Hotline of Indiana Blue and/or California Blue Cross and requested details about
Patient 194’s coverage. Plaintiffs or their agents recorded the information learned from
Indiana Blue and/or California Blue Cross on the bottom of Patient 194’s Insurance
Verification Form. Plaintiffs or their agents learned from Indiana Blue and/or
California Blue Cross that Patient 194’s benefits were not assignable. Plaintiffs or their
agents recorded this by circling “No” next to the line “Assignable” on Patient 194’s
Insurance Verification Form.
1058. On or about May 14, 2015, Plaintiffs began providing mental health
and/or substance abuse treatment to Patient 194.
1059. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Cross or Indiana Blue on the industry-standard UB-
04 form. Plaintiffs indicated that it was requesting that benefits be paid to it as an
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 274 of 360 Page ID #:61894
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206 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
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assignee by inserting the letter Y in the appropriate field (box 53) each time it submitted
a claim.
1060. On information and belief: California Blue Cross, Indiana Blue, and/or
the Hartford Plan thereafter paid some or all of the assigned benefits to Patient 194
instead of Plaintiffs.
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207 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
PATIENT 195
1061. On information and belief: Patient 195 was a participant in or beneficiary
of Defendant Bloomberg Plan during all times relevant to this complaint.
1062. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the Bloomberg Plan either (i) is insured by New York
Empire Blue and/or California Blue Cross or (ii) is self-insured and has entered into an
agreement with New York Empire Blue and/or California Blue Cross by which the
Bloomberg Plan receives third party administrative services.
1063. Plaintiffs obtained an assignment of benefits from Patient 195, who
executed an assignment in the same or substantially similar form to the document
attached hereto as Exhibit B.
1064. On or about November 18, 2014, Plaintiffs secured Patient 195’s consent
to contact New York Empire Blue and/or California Blue Cross, along with the
identifying information necessary for Plaintiffs to interact with the insurer.
1065. On or about November 18, 2014, Plaintiffs or their agents contacted the
Provider Hotline of New York Empire Blue and/or California Blue Cross and requested
details about Patient 195’s coverage. Plaintiffs or their agents recorded the information
learned from New York Empire Blue and/or California Blue Cross on the bottom of
Patient 195’s Insurance Verification Form. Plaintiffs or their agents learned from New
York Empire Blue and/or California Blue Cross that Patient 195’s benefits were not
assignable. Plaintiffs or their agents recorded this by circling “No” next to the line
“Assignable” on Patient 195’s Insurance Verification Form.
1066. On or about November 20, 2014, Plaintiffs began providing mental health
and/or substance abuse treatment to Patient 195.
1067. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Cross or New York Empire Blue on the industry-
standard UB-04 form. Plaintiffs indicated that it was requesting that benefits be paid
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208 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
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to it as an assignee by inserting the letter Y in the appropriate field (box 53) each time
it submitted a claim.
1068. On information and belief: California Blue Cross, New York Empire
Blue, and/or the Bloomberg Plan thereafter paid some or all of the assigned benefits to
Patient 195 instead of Plaintiffs.
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 277 of 360 Page ID #:61897
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209 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
PATIENT 197
1069. On information and belief: Patient 197 was a participant in or beneficiary
of Defendant Sallie Mae Plan during all times relevant to this complaint.
1070. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the Sallie Mae Plan either (i) is insured by Delaware Blue
and/or California Blue Cross or (ii) is self-insured and has entered into an agreement
with Delaware Blue and/or California Blue Cross by which the Sallie Mae Plan
receives third party administrative services.
1071. Plaintiffs obtained an assignment of benefits from Patient 197, who
executed an assignment in the same or substantially similar form to the document
attached hereto as Exhibit B.
1072. On or about November 10, 2014, Plaintiffs secured Patient 197’s consent
to contact Delaware Blue and/or California Blue Cross, along with the identifying
information necessary for Plaintiffs to interact with the insurer.
1073. On or about December 4, 2014, Plaintiffs began providing mental health
and/or substance abuse treatment to Patient 197.
1074. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Cross or Delaware Blue on the industry-standard UB-
04 form. Plaintiffs indicated that it was requesting that benefits be paid to it as an
assignee by inserting the letter Y in the appropriate field (box 53) each time it submitted
a claim.
1075. On information and belief: California Blue Cross, Delaware Blue, and/or
the Sallie Mae Plan thereafter paid some or all of the assigned benefits to Patient 197
instead of Plaintiffs.
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 278 of 360 Page ID #:61898
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210 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
PATIENT 198
1076. On information and belief: Patient 198 was a participant in or beneficiary
of Defendant Ensco Plan during all times relevant to this complaint.
1077. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the Ensco Plan either (i) is insured by Texas Blue and/or
California Blue Cross or (ii) is self-insured and has entered into an agreement with
Texas Blue and/or California Blue Cross by which the Ensco Plan receives third party
administrative services.
1078. Plaintiffs obtained an assignment of benefits from Patient 198, who
executed an assignment in the same or substantially similar form to the document
attached hereto as Exhibit B.
1079. On or about March 16, 2015, Plaintiffs secured Patient 198’s consent to
contact Texas Blue and/or California Blue Cross, along with the identifying
information necessary for Plaintiffs to interact with the insurer.
1080. On or about March 16, 2015, Plaintiffs or their agents contacted the
Provider Hotline of Texas Blue and/or California Blue Cross and requested details
about Patient 198’s coverage. Plaintiffs or their agents recorded the information
learned from Texas Blue and/or California Blue Cross on the bottom of Patient 198’s
Insurance Verification Form. Plaintiffs or their agents learned from Texas Blue and/or
California Blue Cross that Patient 198’s benefits were assignable. Plaintiffs or their
agents recorded this by circling “Yes” next to the line “Assignable” on Patient 198’s
Insurance Verification Form.
1081. On or about March 27, 2015, Plaintiffs began providing mental health
and/or substance abuse treatment to Patient 198.
1082. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Cross or Texas Blue on the industry-standard UB-04
form. Plaintiffs indicated that it was requesting that benefits be paid to it as an assignee
by inserting the letter Y in the appropriate field (box 53) each time it submitted a claim.
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 279 of 360 Page ID #:61899
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211 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
1083. On information and belief: California Blue Cross, Texas Blue, and/or the
Ensco Plan thereafter paid some or all of the assigned benefits to Patient 198 instead
of Plaintiffs.
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 280 of 360 Page ID #:61900
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212 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
PATIENT 199
1084. On information and belief: Patient 199 was a participant in or beneficiary
of Defendant Metal-Matic Plan during all times relevant to this complaint.
1085. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the Metal-Matic Plan either (i) is insured by Minnesota Blue
and/or California Blue Cross or (ii) is self-insured and has entered into an agreement
with Minnesota Blue and/or California Blue Cross by which the Metal-Matic Plan
receives third party administrative services.
1086. Plaintiffs obtained an assignment of benefits from Patient 199, who
executed an assignment in the same or substantially similar form to the document
attached hereto as Exhibit B.
1087. On or about February 5, 2015, Plaintiffs secured Patient 199’s consent to
contact Minnesota Blue and/or California Blue Cross, along with the identifying
information necessary for Plaintiffs to interact with the insurer.
1088. On or about February 23, 2015, Plaintiffs began providing mental health
and/or substance abuse treatment to Patient 199.
1089. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Cross or Minnesota Blue on the industry-standard
UB-04 form. Plaintiffs indicated that it was requesting that benefits be paid to it as an
assignee by inserting the letter Y in the appropriate field (box 53) each time it submitted
a claim.
1090. On information and belief: California Blue Cross, Minnesota Blue, and/or
the Metal-Matic Plan thereafter paid some or all of the assigned benefits to Patient 199
instead of Plaintiffs.
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 281 of 360 Page ID #:61901
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213 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
PATIENT 200
1091. On information and belief: Patient 200 was a participant in or beneficiary
of Defendant Publix Plan during all times relevant to this complaint.
1092. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the Publix Plan either (i) is insured by Florida Blue and/or
California Blue Cross or (ii) is self-insured and has entered into an agreement with
Florida Blue and/or California Blue Cross by which the Publix Plan receives third party
administrative services.
1093. Plaintiffs obtained an assignment of benefits from Patient 200, who
executed an assignment in the same or substantially similar form to the document
attached hereto as Exhibit B.
1094. On or about March 3, 2015, Plaintiffs secured Patient 200’s consent to
contact Florida Blue and/or California Blue Cross, along with the identifying
information necessary for Plaintiffs to interact with the insurer.
1095. On or about March 23, 2015, Plaintiffs began providing mental health
and/or substance abuse treatment to Patient 200.
1096. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Cross or Florida Blue on the industry-standard UB-
04 form. Plaintiffs indicated that it was requesting that benefits be paid to it as an
assignee by inserting the letter Y in the appropriate field (box 53) each time it submitted
a claim.
1097. On information and belief: California Blue Cross, Florida Blue, and/or the
Publix Plan thereafter paid some or all of the assigned benefits to Patient 200 instead
of Plaintiffs.
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 282 of 360 Page ID #:61902
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214 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
PATIENT 201
1098. On information and belief: Patient 201 was a participant in or beneficiary
of Defendant TriNet Plan during all times relevant to this complaint.
1099. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the TriNet Plan either (i) is insured by California Blue
Shield or (ii) is self-insured and has entered into an agreement with California Blue
Shield by which the TriNet Plan receives third party administrative services.
1100. Plaintiffs obtained an assignment of benefits from Patient 201, who
executed an assignment in the same or substantially similar form to the document
attached hereto as Exhibit B.
1101. On or about September 8, 2014, Plaintiffs secured Patient 201’s consent
to contact California Blue Shield, along with the identifying information necessary for
Plaintiffs to interact with the insurer.
1102. On or about September 8, 2014, Plaintiffs or their agents contacted the
Provider Hotline of California Blue Shield and requested details about Patient 201’s
coverage. Plaintiffs or their agents recorded the information learned from California
Blue Shield on the bottom of Patient 201’s Insurance Verification Form. Plaintiffs or
their agents learned from California Blue Shield that Patient 201’s benefits were not
assignable. Plaintiffs or their agents recorded this by circling “No” next to the line
“Assignable” on Patient 201’s Insurance Verification Form.
1103. On or about September 10, 2014, Plaintiffs began providing mental health
and/or substance abuse treatment to Patient 201.
1104. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Shield on the industry-standard UB-04 form.
Plaintiffs indicated that it was requesting that benefits be paid to it as an assignee by
inserting the letter Y in the appropriate field (box 53) each time it submitted a claim.
1105. On information and belief: California Blue Shield and/or the TriNet Plan
thereafter paid some or all of the assigned benefits to Patient 201 instead of Plaintiffs.
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 283 of 360 Page ID #:61903
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215 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
PATIENT 203
1106. On information and belief: Patient 203 was a participant in or beneficiary
of the Ascension SmartHealth Medical Plan (“Ascension Plan”) during all times
relevant to this complaint.
1107. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the Ascension Plan either (i) is insured by Michigan Blue
and/or California Blue Cross or (ii) is self-insured and has entered into an agreement
with Michigan Blue and/or California Blue Cross by which the Ascension Plan
receives third party administrative services.
1108. Plaintiffs obtained an assignment of benefits from Patient 203, who
executed an assignment in the same or substantially similar form to the document
attached hereto as Exhibit B.
1109. On or about October 13, 2014, Plaintiffs secured Patient 203’s consent to
contact Michigan Blue and/or California Blue Cross, along with the identifying
information necessary for Plaintiffs to interact with the insurer.
1110. On or about October 15, 2014, Plaintiffs began providing mental health
and/or substance abuse treatment to Patient 203.
1111. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Cross or Michigan Blue on the industry-standard UB-
04 form. Plaintiffs indicated that it was requesting that benefits be paid to it as an
assignee by inserting the letter Y in the appropriate field (box 53) each time it submitted
a claim.
1112. On information and belief: California Blue Cross, Michigan Blue, and/or
the Ascension Plan thereafter paid some or all of the assigned benefits to Patient 203
instead of Plaintiffs.
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 284 of 360 Page ID #:61904
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216 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
PATIENT 204
1113. On information and belief: Patient 204 was a participant in or beneficiary
of Defendant Medtronic Plan during all times relevant to this complaint.
1114. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the Medtronic Plan either (i) is insured by Minnesota Blue
and/or California Blue Cross or (ii) is self-insured and has entered into an agreement
with Minnesota Blue and/or California Blue Cross by which the Medtronic Plan
receives third party administrative services.
1115. Plaintiffs obtained an assignment of benefits from Patient 204, who
executed an assignment in the same or substantially similar form to the document
attached hereto as Exhibit B.
1116. On or about January 8, 2015, Plaintiffs secured Patient 204’s consent to
contact Minnesota Blue and/or California Blue Cross, along with the identifying
information necessary for Plaintiffs to interact with the insurer.
1117. On or about January 8, 2015, Plaintiffs or their agents contacted the
Provider Hotline of Minnesota Blue and/or California Blue Cross and requested details
about Patient 204’s coverage. Plaintiffs or their agents recorded the information
learned from Minnesota Blue and/or California Blue Cross on the bottom of Patient
204’s Insurance Verification Form. Plaintiffs or their agents learned from Minnesota
Blue and/or California Blue Cross that Patient 204’s benefits were assignable.
Plaintiffs or their agents recorded this by circling “Yes” next to the line “Assignable”
on Patient 204’s Insurance Verification Form.
1118. On or about January 13, 2015, Plaintiffs began providing mental health
and/or substance abuse treatment to Patient 204.
1119. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Cross or Minnesota Blue on the industry-standard
UB-04 form. Plaintiffs indicated that it was requesting that benefits be paid to it as an
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 285 of 360 Page ID #:61905
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217 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
assignee by inserting the letter Y in the appropriate field (box 53) each time it submitted
a claim.
1120. On information and belief: California Blue Cross, Minnesota Blue, and/or
the Medtronic Plan thereafter paid some or all of the assigned benefits to Patient 204
instead of Plaintiffs.
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 286 of 360 Page ID #:61906
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218 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
PATIENT 206
1121. On information and belief: Patient 206 was a participant in or beneficiary
of Defendant Fudge Plan during all times relevant to this complaint.
1122. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the Fudge Plan either (i) is insured by Oklahoma Blue
and/or California Blue Cross or (ii) is self-insured and has entered into an agreement
with Oklahoma Blue and/or California Blue Cross by which the Fudge Plan receives
third party administrative services.
1123. Plaintiffs obtained an assignment of benefits from Patient 206, who
executed an assignment in the same or substantially similar form to the document
attached hereto as Exhibit B.
1124. On or about March 30, 2015, Plaintiffs secured Patient 206’s consent to
contact Oklahoma Blue and/or California Blue Cross, along with the identifying
information necessary for Plaintiffs to interact with the insurer.
1125. On or about March 30, 2015, Plaintiffs or their agents contacted the
Provider Hotline of Oklahoma Blue and/or California Blue Cross and requested details
about Patient 206’s coverage. Plaintiffs or their agents recorded the information
learned from Oklahoma Blue and/or California Blue Cross on the bottom of Patient
206’s Insurance Verification Form. Plaintiffs or their agents learned from Oklahoma
Blue and/or California Blue Cross that Patient 206’s benefits were not assignable.
Plaintiffs or their agents recorded this by circling “No” next to the line “Assignable”
on Patient 206’s Insurance Verification Form.
1126. On or about April 3, 2015, Plaintiffs began providing mental health and/or
substance abuse treatment to Patient 206.
1127. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Cross or Oklahoma Blue on the industry-standard
UB-04 form. Plaintiffs indicated that it was requesting that benefits be paid to it as an
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 287 of 360 Page ID #:61907
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219 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
assignee by inserting the letter Y in the appropriate field (box 53) each time it submitted
a claim.
1128. On information and belief: California Blue Cross, Oklahoma Blue, and/or
the Fudge Plan thereafter paid some or all of the assigned benefits to Patient 206 instead
of Plaintiffs.
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 288 of 360 Page ID #:61908
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220 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
PATIENT 207
1129. On information and belief: Patient 207 was a participant in or beneficiary
of the Fluid Power Sales, Inc. Group Health Plan (the “Fluid Power Plan”) during all
times relevant to this complaint.
1130. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the Fluid Power Plan either (i) is insured by New York
Excellus Blue and/or California Blue Cross or (ii) is self-insured and has entered into
an agreement with New York Excellus Blue and/or California Blue Cross by which the
Fluid Power Plan receives third party administrative services.
1131. Plaintiffs obtained an assignment of benefits from Patient 207, who
executed an assignment in the same or substantially similar form to the document
attached hereto as Exhibit B.
1132. On or about February 20, 2015, Plaintiffs secured Patient 207’s consent
to contact New York Excellus Blue and/or California Blue Cross, along with the
identifying information necessary for Plaintiffs to interact with the insurer.
1133. On or about March 18, 2015, Plaintiffs began providing mental health
and/or substance abuse treatment to Patient 207.
1134. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Cross or New York Excellus Blue on the industry-
standard UB-04 form. Plaintiffs indicated that it was requesting that benefits be paid
to it as an assignee by inserting the letter Y in the appropriate field (box 53) each time
it submitted a claim.
1135. On information and belief: California Blue Cross, New York Excellus
Blue, and/or the Fluid Power Plan thereafter paid some or all of the assigned benefits
to Patient 207 instead of Plaintiffs.
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 289 of 360 Page ID #:61909
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221 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
PATIENT 208
1136. On information and belief: Patient 208 was a participant in or beneficiary
of the Dowdell Shellenberg LLC health benefit plan (the “DSLLC Plan”) during all
times relevant to this complaint.
1137. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the DSLLC Plan either (i) is insured by Montana Blue
and/or California Blue Cross or (ii) is self-insured and has entered into an agreement
with Montana Blue and/or California Blue Cross by which the DSLLC Plan receives
third party administrative services.
1138. Plaintiffs obtained an assignment of benefits from Patient 208, who
executed an assignment in the same or substantially similar form to the document
attached hereto as Exhibit B.
1139. On or about December 29, 2014, Plaintiffs secured Patient 208’s consent
to contact Montana Blue and/or California Blue Cross, along with the identifying
information necessary for Plaintiffs to interact with the insurer.
1140. On or about December 30, 2014, Plaintiffs began providing mental health
and/or substance abuse treatment to Patient 208.
1141. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Cross or Montana Blue on the industry-standard UB-
04 form. Plaintiffs indicated that it was requesting that benefits be paid to it as an
assignee by inserting the letter Y in the appropriate field (box 53) each time it submitted
a claim.
1142. On information and belief: California Blue Cross, Montana Blue, and/or
the DSLLC Plan thereafter paid some or all of the assigned benefits to Patient 208
instead of Plaintiffs.
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 290 of 360 Page ID #:61910
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222 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
PATIENT 209
1143. On information and belief: Patient 209 was a participant in or beneficiary
of Defendant Gentiva Plan during all times relevant to this complaint.
1144. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the Gentiva Plan either (i) is insured by Georgia Blue and/or
California Blue Cross or (ii) is self-insured and has entered into an agreement with
Georgia Blue and/or California Blue Cross by which the Gentiva Plan receives third
party administrative services.
1145. Plaintiffs obtained an assignment of benefits from Patient 209, who
executed an assignment in the same or substantially similar form to the document
attached hereto as Exhibit B.
1146. On or about May 10, 2015, Plaintiffs secured Patient 209’s consent to
contact Georgia Blue and/or California Blue Cross, along with the identifying
information necessary for Plaintiffs to interact with the insurer.
1147. On or about May 28, 2015, Plaintiffs began providing mental health
and/or substance abuse treatment to Patient 209.
1148. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Cross or Georgia Blue on the industry-standard UB-
04 form. Plaintiffs indicated that it was requesting that benefits be paid to it as an
assignee by inserting the letter Y in the appropriate field (box 53) each time it submitted
a claim.
1149. On information and belief: California Blue Cross, Georgia Blue, and/or
the Gentiva Plan thereafter paid some or all of the assigned benefits to Patient 209
instead of Plaintiffs.
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 291 of 360 Page ID #:61911
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223 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
PATIENT 210
1150. On information and belief: Patient 210 was a participant in or beneficiary
of Defendant eHealth Plan during all times relevant to this complaint.
1151. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the eHealth Plan either (i) is insured by California Blue
Cross or (ii) is self-insured and has entered into an agreement with California Blue
Cross by which the eHealth Plan receives third party administrative services.
1152. Plaintiffs obtained an assignment of benefits from Patient 210, who
executed an assignment in the same or substantially similar form to the document
attached hereto as Exhibit B.
1153. On or about January 12, 2015, Plaintiffs secured Patient 210’s consent to
contact California Blue Cross, along with the identifying information necessary for
Plaintiffs to interact with the insurer.
1154. On or about January 24, 2015, Plaintiffs began providing mental health
and/or substance abuse treatment to Patient 210.
1155. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Cross on the industry-standard UB-04 form. Plaintiffs
indicated that it was requesting that benefits be paid to it as an assignee by inserting
the letter Y in the appropriate field (box 53) each time it submitted a claim.
1156. On information and belief: California Blue Cross and/or the eHealth Plan
thereafter paid some or all of the assigned benefits to Patient 210 instead of Plaintiffs.
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 292 of 360 Page ID #:61912
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224 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
PATIENT 211
1157. On information and belief: Patient 211 was a participant in or beneficiary
of Defendant Fastrac Plan during all times relevant to this complaint.
1158. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the Fastrac Plan either (i) is insured by New York Excellus
Blue and/or California Blue Cross or (ii) is self-insured and has entered into an
agreement with New York Excellus Blue and/or California Blue Cross by which the
Fastrac Plan receives third party administrative services.
1159. Plaintiffs obtained an assignment of benefits from Patient 211, who
executed an assignment in the same or substantially similar form to the document
attached hereto as Exhibit B.
1160. On or about October 23, 2014, Plaintiffs secured Patient 211’s consent to
contact New York Excellus Blue and/or California Blue Cross, along with the
identifying information necessary for Plaintiffs to interact with the insurer.
1161. On or about November 7, 2014, Plaintiffs began providing mental health
and/or substance abuse treatment to Patient 211.
1162. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Cross or New York Excellus Blue on the industry-
standard UB-04 form. Plaintiffs indicated that it was requesting that benefits be paid
to it as an assignee by inserting the letter Y in the appropriate field (box 53) each time
it submitted a claim.
1163. On information and belief: California Blue Cross, New York Excellus
Blue, and/or the Fastrac Plan thereafter paid some or all of the assigned benefits to
Patient 211 instead of Plaintiffs.
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 293 of 360 Page ID #:61913
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225 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
PATIENT 212
1164. On information and belief: Patient 212 was a participant in or beneficiary
of Defendant Martin Marietta Plan during all times relevant to this complaint.
1165. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the Martin Marietta Plan either (i) is insured by North
Carolina Blue and/or California Blue Cross or (ii) is self-insured and has entered into
an agreement with North Carolina Blue and/or California Blue Cross by which the
Martin Marietta Plan receives third party administrative services.
1166. Plaintiffs obtained an assignment of benefits from Patient 212, who
executed an assignment in the same or substantially similar form to the document
attached hereto as Exhibit B.
1167. On or about January 20, 2015, Plaintiffs secured Patient 212’s consent to
contact North Carolina Blue and/or California Blue Cross, along with the identifying
information necessary for Plaintiffs to interact with the insurer.
1168. On or about February 10, 2015, Plaintiffs began providing mental health
and/or substance abuse treatment to Patient 212.
1169. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Cross or North Carolina Blue on the industry-standard
UB-04 form. Plaintiffs indicated that it was requesting that benefits be paid to it as an
assignee by inserting the letter Y in the appropriate field (box 53) each time it submitted
a claim.
1170. On information and belief: California Blue Cross, North Carolina Blue,
and/or the Martin Marietta Plan thereafter paid some or all of the assigned benefits to
Patient 212 instead of Plaintiffs.
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 294 of 360 Page ID #:61914
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226 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
PATIENT 214
1171. On information and belief: Patient 214 was a participant in or beneficiary
of Defendant Pioneer Energy Plan during all times relevant to this complaint.
1172. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the Pioneer Energy Plan either (i) is insured by Texas Blue
and/or California Blue Cross or (ii) is self-insured and has entered into an agreement
with Texas Blue and/or California Blue Cross by which the Pioneer Energy Plan
receives third party administrative services.
1173. Plaintiffs obtained an assignment of benefits from Patient 214, who
executed an assignment in the same or substantially similar form to the document
attached hereto as Exhibit B.
1174. On or about September 4, 2014, Plaintiffs secured Patient 214’s consent
to contact Texas Blue and/or California Blue Cross, along with the identifying
information necessary for Plaintiffs to interact with the insurer.
1175. On or about September 18, 2014, Plaintiffs began providing mental health
and/or substance abuse treatment to Patient 214.
1176. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Cross or Texas Blue on the industry-standard UB-04
form. Plaintiffs indicated that it was requesting that benefits be paid to it as an assignee
by inserting the letter Y in the appropriate field (box 53) each time it submitted a claim.
1177. On information and belief: California Blue Cross, Texas Blue, and/or the
Pioneer Energy Plan thereafter paid some or all of the assigned benefits to Patient 214
instead of Plaintiffs.
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 295 of 360 Page ID #:61915
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227 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
PATIENT 215
1178. On information and belief: Patient 215 was a participant in or beneficiary
of Defendant Kroger Plan during all times relevant to this complaint.
1179. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the Kroger Plan either (i) is insured by Ohio Blue and/or
California Blue Cross or (ii) is self-insured and has entered into an agreement with
Ohio Blue and/or California Blue Cross by which the Kroger Plan receives third party
administrative services.
1180. Plaintiffs obtained an assignment of benefits from Patient 215, who
executed an assignment in the same or substantially similar form to the document
attached hereto as Exhibit B.
1181. On or about May 4, 2015, Plaintiffs secured Patient 215’s consent to
contact Ohio Blue and/or California Blue Cross, along with the identifying information
necessary for Plaintiffs to interact with the insurer.
1182. On or about May 19, 2015, Plaintiffs began providing mental health
and/or substance abuse treatment to Patient 215.
1183. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Cross or Ohio Blue on the industry-standard UB-04
form. Plaintiffs indicated that it was requesting that benefits be paid to it as an assignee
by inserting the letter Y in the appropriate field (box 53) each time it submitted a claim.
1184. On information and belief: California Blue Cross, Ohio Blue, and/or the
Kroger Plan thereafter paid some or all of the assigned benefits to Patient 215 instead
of Plaintiffs.
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 296 of 360 Page ID #:61916
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228 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
PATIENT 216
1185. On information and belief: Patient 216 was a participant in or beneficiary
of the Voto Healthcare, Inc. group plan (the “Voto Healthcare Plan”) during all times
relevant to this complaint.
1186. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the Voto Healthcare Plan either (i) is insured by Washington
Regence Blue and/or California Blue Cross or (ii) is self-insured and has entered into
an agreement with Washington Regence Blue and/or California Blue Cross by which
the Voto Healthcare Plan receives third party administrative services.
1187. Plaintiffs obtained an assignment of benefits from Patient 216, who
executed an assignment in the same or substantially similar form to the document
attached hereto as Exhibit B.
1188. On or about January 22, 2015, Plaintiffs secured Patient 216’s consent to
contact Washington Regence Blue and/or California Blue Cross, along with the
identifying information necessary for Plaintiffs to interact with the insurer.
1189. On or about January 27, 2015, Plaintiffs began providing mental health
and/or substance abuse treatment to Patient 216.
1190. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Cross or Washington Regence Blue on the industry-
standard UB-04 form. Plaintiffs indicated that it was requesting that benefits be paid
to it as an assignee by inserting the letter Y in the appropriate field (box 53) each time
it submitted a claim.
1191. On information and belief: California Blue Cross, Washington Regence
Blue, and/or the Voto Healthcare Plan thereafter paid some or all of the assigned
benefits to Patient 216 instead of Plaintiffs.
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 297 of 360 Page ID #:61917
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229 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
PATIENT 217
1192. On information and belief: Patient 217 was a participant in or beneficiary
of Defendant Intel Plan during all times relevant to this complaint.
1193. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the Intel Plan either (i) is insured by California Blue Cross
or (ii) is self-insured and has entered into an agreement with California Blue Cross by
which the Intel Plan receives third party administrative services.
1194. Plaintiffs obtained an assignment of benefits from Patient 217, who
executed an assignment in the same or substantially similar form to the document
attached hereto as Exhibit B.
1195. On or about January 26, 2015, Plaintiffs secured Patient 217’s consent to
contact California Blue Cross, along with the identifying information necessary for
Plaintiffs to interact with the insurer.
1196. On or about January 26, 2015, Plaintiffs or their agents contacted the
Provider Hotline of California Blue Cross and requested details about Patient 217’s
coverage. Plaintiffs or their agents recorded the information learned from California
Blue Cross on the bottom of Patient 217’s Insurance Verification Form. Plaintiffs or
their agents learned from California Blue Cross that Patient 217’s benefits were not
assignable. Plaintiffs or their agents recorded this by circling “No” next to the line
“Assignable” on Patient 217’s Insurance Verification Form.
1197. On or about January 29, 2015, Plaintiffs began providing mental health
and/or substance abuse treatment to Patient 217.
1198. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Cross on the industry-standard UB-04 form. Plaintiffs
indicated that it was requesting that benefits be paid to it as an assignee by inserting
the letter Y in the appropriate field (box 53) each time it submitted a claim.
1199. On information and belief: California Blue Cross and/or the Intel Plan
thereafter paid some or all of the assigned benefits to Patient 217 instead of Plaintiffs.
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 298 of 360 Page ID #:61918
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230 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
PATIENT 218
1200. On information and belief: Patient 218 was a participant in or beneficiary
of an unknown ERISA-governed welfare plan during all times relevant to this
complaint.
1201. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the unknown plan either (i) is insured by Iowa Blue and/or
California Blue Cross or (ii) is self-insured and has entered into an agreement with
Iowa Blue and/or California Blue Cross by which the unknown plan receives third
party administrative services.
1202. Plaintiffs obtained an assignment of benefits from Patient 218, who
executed an assignment in the same or substantially similar form to the document
attached hereto as Exhibit B.
1203. On or about January 23, 2015, Plaintiffs secured Patient 218’s consent to
contact Iowa Blue and/or California Blue Cross, along with the identifying information
necessary for Plaintiffs to interact with the insurer.
1204. On or about January 29, 2015, Plaintiffs began providing mental health
and/or substance abuse treatment to Patient 218.
1205. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Cross or Iowa Blue on the industry-standard UB-04
form. Plaintiffs indicated that it was requesting that benefits be paid to it as an assignee
by inserting the letter Y in the appropriate field (box 53) each time it submitted a claim.
1206. On information and belief: California Blue Cross, Iowa Blue, and/or the
unknown plan thereafter paid some or all of the assigned benefits to Patient 218 instead
of Plaintiffs.
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 299 of 360 Page ID #:61919
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231 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
PATIENT 220
1207. On information and belief: Patient 220 was a participant in or beneficiary
of Defendant FAS Plan during all times relevant to this complaint.
1208. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the FAS Plan either (i) is insured by Florida Blue and/or
California Blue Cross or (ii) is self-insured and has entered into an agreement with
Florida Blue and/or California Blue Cross by which the FAS Plan receives third party
administrative services.
1209. Plaintiffs obtained an assignment of benefits from Patient 220, who
executed an assignment in the same or substantially similar form to the document
attached hereto as Exhibit B.
1210. On or about April 6, 2015, Plaintiffs secured Patient 220’s consent to
contact Florida Blue and/or California Blue Cross, along with the identifying
information necessary for Plaintiffs to interact with the insurer.
1211. On or about April 6, 2015, Plaintiffs or their agents contacted the Provider
Hotline of Florida Blue and/or California Blue Cross and requested details about
Patient 220’s coverage. Plaintiffs or their agents recorded the information learned from
Florida Blue and/or California Blue Cross on the bottom of Patient 220’s Insurance
Verification Form. Plaintiffs or their agents learned from Florida Blue and/or
California Blue Cross that Patient 220’s benefits were not assignable. Plaintiffs or their
agents recorded this by circling “No” next to the line “Assignable” on Patient 220’s
Insurance Verification Form.
1212. On or about April 22, 2015, Plaintiffs began providing mental health
and/or substance abuse treatment to Patient 220.
1213. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Cross or Florida Blue on the industry-standard UB-
04 form. Plaintiffs indicated that it was requesting that benefits be paid to it as an
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 300 of 360 Page ID #:61920
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232 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
assignee by inserting the letter Y in the appropriate field (box 53) each time it submitted
a claim.
1214. On information and belief: California Blue Cross, Florida Blue, and/or the
FAS Plan thereafter paid some or all of the assigned benefits to Patient 220 instead of
Plaintiffs.
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 301 of 360 Page ID #:61921
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233 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
PATIENT 221
1215. On information and belief: Patient 221 was a participant in or beneficiary
of Defendant St. Luke’s Plan during all times relevant to this complaint.
1216. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the St. Luke’s Plan either (i) is insured by Minnesota Blue
and/or California Blue Cross or (ii) is self-insured and has entered into an agreement
with Minnesota Blue and/or California Blue Cross by which the St. Luke’s Plan
receives third party administrative services.
1217. Plaintiffs obtained an assignment of benefits from Patient 221, who
executed an assignment in the same or substantially similar form to the document
attached hereto as Exhibit B.
1218. On or about September 23, 2014, Plaintiffs secured Patient 221’s consent
to contact Minnesota Blue and/or California Blue Cross, along with the identifying
information necessary for Plaintiffs to interact with the insurer.
1219. On or about October 1, 2014, Plaintiffs began providing mental health
and/or substance abuse treatment to Patient 221.
1220. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Cross or Minnesota Blue on the industry-standard
UB-04 form. Plaintiffs indicated that it was requesting that benefits be paid to it as an
assignee by inserting the letter Y in the appropriate field (box 53) each time it submitted
a claim.
1221. On information and belief: California Blue Cross, Minnesota Blue, and/or
the St. Luke’s Plan thereafter paid some or all of the assigned benefits to Patient 221
instead of Plaintiffs.
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 302 of 360 Page ID #:61922
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234 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
PATIENT 223
1222. On information and belief: Patient 223 was a participant in or beneficiary
of an unknown ERISA-governed welfare plan during all times relevant to this
complaint.
1223. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the unknown plan either (i) is insured by Florida Blue and/or
California Blue Cross or (ii) is self-insured and has entered into an agreement with
Florida Blue and/or California Blue Cross by which the unknown plan receives third
party administrative services.
1224. Plaintiffs obtained an assignment of benefits from Patient 223, who
executed an assignment in the same or substantially similar form to the document
attached hereto as Exhibit B.
1225. On or about April 20, 2015, Plaintiffs secured Patient 223’s consent to
contact Florida Blue and/or California Blue Cross, along with the identifying
information necessary for Plaintiffs to interact with the insurer.
1226. On or about April 28, 2015, Plaintiffs began providing mental health
and/or substance abuse treatment to Patient 223.
1227. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Cross or Florida Blue on the industry-standard UB-
04 form. Plaintiffs indicated that it was requesting that benefits be paid to it as an
assignee by inserting the letter Y in the appropriate field (box 53) each time it submitted
a claim.
1228. On information and belief: California Blue Cross, Florida Blue, and/or the
unknown plan thereafter paid some or all of the assigned benefits to Patient 223 instead
of Plaintiffs.
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 303 of 360 Page ID #:61923
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235 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
PATIENT 225
1229. On information and belief: Patient 225 was a participant in or beneficiary
of Defendant TAC Plan during all times relevant to this complaint.
1230. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the TAC Plan either (i) is insured by Michigan Blue and/or
California Blue Cross or (ii) is self-insured and has entered into an agreement with
Michigan Blue and/or California Blue Cross by which the TAC Plan receives third
party administrative services.
1231. Plaintiffs obtained an assignment of benefits from Patient 225, who
executed an assignment in the same or substantially similar form to the document
attached hereto as Exhibit B.
1232. On or about October 31, 2014, Plaintiffs secured Patient 225’s consent to
contact Michigan Blue and/or California Blue Cross, along with the identifying
information necessary for Plaintiffs to interact with the insurer.
1233. On or about November 7, 2014, Plaintiffs began providing mental health
and/or substance abuse treatment to Patient 225.
1234. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Cross or Michigan Blue on the industry-standard UB-
04 form. Plaintiffs indicated that it was requesting that benefits be paid to it as an
assignee by inserting the letter Y in the appropriate field (box 53) each time it submitted
a claim.
1235. On information and belief: California Blue Cross, Michigan Blue, and/or
the TAC Plan thereafter paid some or all of the assigned benefits to Patient 225 instead
of Plaintiffs.
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 304 of 360 Page ID #:61924
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236 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
PATIENT 226
1236. On information and belief: Patient 226 was a participant in or beneficiary
of the Kongsberg Gruppen Health Plan (the “Kongsberg Plan”) during all times
relevant to this complaint.
1237. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the Kongsberg Plan either (i) is insured by Texas Blue
and/or California Blue Cross or (ii) is self-insured and has entered into an agreement
with Texas Blue and/or California Blue Cross by which the Kongsberg Plan receives
third party administrative services.
1238. Plaintiffs obtained an assignment of benefits from Patient 226, who
executed an assignment in the same or substantially similar form to the document
attached hereto as Exhibit B.
1239. On or about December 15, 2014, Plaintiffs secured Patient 226’s consent
to contact Texas Blue and/or California Blue Cross, along with the identifying
information necessary for Plaintiffs to interact with the insurer.
1240. On or about December 29, 2014, Plaintiffs began providing mental health
and/or substance abuse treatment to Patient 226.
1241. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Cross or Texas Blue on the industry-standard UB-04
form. Plaintiffs indicated that it was requesting that benefits be paid to it as an assignee
by inserting the letter Y in the appropriate field (box 53) each time it submitted a claim.
1242. On information and belief: California Blue Cross, Texas Blue, and/or the
Kongsberg Plan thereafter paid some or all of the assigned benefits to Patient 226
instead of Plaintiffs.
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 305 of 360 Page ID #:61925
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237 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
PATIENT 227
1243. On information and belief: Patient 227 was a participant in or beneficiary
of an unknown ERISA-governed welfare plan during all times relevant to this
complaint.
1244. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the unknown plan either (i) is insured by Florida Blue and/or
California Blue Cross or (ii) is self-insured and has entered into an agreement with
Florida Blue and/or California Blue Cross by which the unknown plan receives third
party administrative services.
1245. Plaintiffs obtained an assignment of benefits from Patient 227, who
executed an assignment in the same or substantially similar form to the document
attached hereto as Exhibit B.
1246. On or about January 29, 2015, Plaintiffs secured Patient 227’s consent to
contact Florida Blue and/or California Blue Cross, along with the identifying
information necessary for Plaintiffs to interact with the insurer.
1247. On or about February 5, 2015, Plaintiffs began providing mental health
and/or substance abuse treatment to Patient 227.
1248. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Cross or Florida Blue on the industry-standard UB-
04 form. Plaintiffs indicated that it was requesting that benefits be paid to it as an
assignee by inserting the letter Y in the appropriate field (box 53) each time it submitted
a claim.
1249. On information and belief: California Blue Cross, Florida Blue, and/or the
unknown plan thereafter paid some or all of the assigned benefits to Patient 227 instead
of Plaintiffs.
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CASE NO. SACV15−0736 DOC (DFMx) 206541.1
PATIENT 228
1250. On information and belief: Patient 228 was a participant in or beneficiary
of the Wellfount Corporation Group Benefit Plan (the “Wellfount Plan”) during all
times relevant to this complaint.
1251. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the Wellfount Plan either (i) is insured by Indiana Blue
and/or California Blue Cross or (ii) is self-insured and has entered into an agreement
with Indiana Blue and/or California Blue Cross by which the Wellfount Plan receives
third party administrative services.
1252. Plaintiffs obtained an assignment of benefits from Patient 228, who
executed an assignment in the same or substantially similar form to the document
attached hereto as Exhibit B.
1253. On or about February 2, 2015, Plaintiffs secured Patient 228’s consent to
contact Indiana Blue and/or California Blue Cross, along with the identifying
information necessary for Plaintiffs to interact with the insurer.
1254. On or about February 2, 2015, Plaintiffs or their agents contacted the
Provider Hotline of Indiana Blue and/or California Blue Cross and requested details
about Patient 228’s coverage. Plaintiffs or their agents recorded the information
learned from Indiana Blue and/or California Blue Cross on the bottom of Patient 228’s
Insurance Verification Form. Plaintiffs or their agents learned from Indiana Blue
and/or California Blue Cross that Patient 228’s benefits were not assignable. Plaintiffs
or their agents recorded this by circling “No” next to the line “Assignable” on Patient
228’s Insurance Verification Form.
1255. On or about February 4, 2015, Plaintiffs began providing mental health
and/or substance abuse treatment to Patient 228.
1256. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Cross or Indiana Blue on the industry-standard UB-
04 form. Plaintiffs indicated that it was requesting that benefits be paid to it as an
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assignee by inserting the letter Y in the appropriate field (box 53) each time it submitted
a claim.
1257. On information and belief: California Blue Cross, Indiana Blue, and/or
the Wellfount Plan thereafter paid some or all of the assigned benefits to Patient 228
instead of Plaintiffs.
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 308 of 360 Page ID #:61928
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240 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
PATIENT 229
1258. On information and belief: Patient 229 was a participant in or beneficiary
of Defendant IBU Health Plan during all times relevant to this complaint.
1259. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the IBU Health Plan either (i) is insured by Washington
Premera Blue and/or California Blue Cross or (ii) is self-insured and has entered into
an agreement with Washington Premera Blue and/or California Blue Cross by which
the IBU Health Plan receives third party administrative services.
1260. Plaintiffs obtained an assignment of benefits from Patient 229, who
executed an assignment in the same or substantially similar form to the document
attached hereto as Exhibit B.
1261. On or about March 8, 2013, Plaintiffs secured Patient 229’s consent to
contact Washington Premera Blue and/or California Blue Cross, along with the
identifying information necessary for Plaintiffs to interact with the insurer.
1262. On or about March 11, 2013, Plaintiffs began providing mental health
and/or substance abuse treatment to Patient 229.
1263. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Cross or Washington Premera Blue on the industry-
standard UB-04 form. Plaintiffs indicated that it was requesting that benefits be paid
to it as an assignee by inserting the letter Y in the appropriate field (box 53) each time
it submitted a claim.
1264. On information and belief: California Blue Cross, Washington Premera
Blue, and/or the IBU Health Plan thereafter paid some or all of the assigned benefits
to Patient 229 instead of Plaintiffs.
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 309 of 360 Page ID #:61929
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241 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
PATIENT 230
1265. On information and belief: Patient 230 was a participant in or beneficiary
of the Cargotec Holding, Inc. Group Health & Welfare Plan (the “HIAB Plan”) during
all times relevant to this complaint.
1266. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the HIAB Plan either (i) is insured by Ohio Blue and/or
California Blue Cross or (ii) is self-insured and has entered into an agreement with
Ohio Blue and/or California Blue Cross by which the HIAB Plan receives third party
administrative services.
1267. Plaintiffs obtained an assignment of benefits from Patient 230, who
executed an assignment in the same or substantially similar form to the document
attached hereto as Exhibit B.
1268. On or about December 18, 2014, Plaintiffs secured Patient 230’s consent
to contact Ohio Blue and/or California Blue Cross, along with the identifying
information necessary for Plaintiffs to interact with the insurer.
1269. On or about December 30, 2014, Plaintiffs began providing mental health
and/or substance abuse treatment to Patient 230.
1270. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Cross or Ohio Blue on the industry-standard UB-04
form. Plaintiffs indicated that it was requesting that benefits be paid to it as an assignee
by inserting the letter Y in the appropriate field (box 53) each time it submitted a claim.
1271. On information and belief: California Blue Cross, Ohio Blue, and/or the
HIAB Plan thereafter paid some or all of the assigned benefits to Patient 230 instead
of Plaintiffs.
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242 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
PATIENT 231
1272. On information and belief: Patient 231 was a participant in or beneficiary
of Defendant SMW No. 40 Plan during all times relevant to this complaint.
1273. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the SMW No. 40 Plan either (i) is insured by Indiana Blue
and/or California Blue Cross or (ii) is self-insured and has entered into an agreement
with Indiana Blue and/or California Blue Cross by which the SMW No. 40 Plan
receives third party administrative services.
1274. Plaintiffs obtained an assignment of benefits from Patient 231, who
executed an assignment in the same or substantially similar form to the document
attached hereto as Exhibit B.
1275. On or about October 21, 2014, Plaintiffs secured Patient 231’s consent to
contact Indiana Blue and/or California Blue Cross, along with the identifying
information necessary for Plaintiffs to interact with the insurer.
1276. On or about November 7, 2014, Plaintiffs began providing mental health
and/or substance abuse treatment to Patient 231.
1277. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Cross or Indiana Blue on the industry-standard UB-
04 form. Plaintiffs indicated that it was requesting that benefits be paid to it as an
assignee by inserting the letter Y in the appropriate field (box 53) each time it submitted
a claim.
1278. On information and belief: California Blue Cross, Indiana Blue, and/or
the SMW No. 40 Plan thereafter paid some or all of the assigned benefits to Patient
231 instead of Plaintiffs.
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 311 of 360 Page ID #:61931
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PATIENT 232
1279. On information and belief: Patient 232 was a participant in or beneficiary
of Defendant Aerospace Plan during all times relevant to this complaint.
1280. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the Aerospace Plan either (i) is insured by California Blue
Cross or (ii) is self-insured and has entered into an agreement with California Blue
Cross by which the Aerospace Plan receives third party administrative services.
1281. Plaintiffs obtained an assignment of benefits from Patient 232, who
executed an assignment in the same or substantially similar form to the document
attached hereto as Exhibit B.
1282. On or about March 25, 2015, Plaintiffs secured Patient 232’s consent to
contact California Blue Cross, along with the identifying information necessary for
Plaintiffs to interact with the insurer.
1283. On or about March 25, 2015, Plaintiffs or their agents contacted the
Provider Hotline of California Blue Cross and requested details about Patient 232’s
coverage. Plaintiffs or their agents recorded the information learned from California
Blue Cross on the bottom of Patient 232’s Insurance Verification Form. Plaintiffs or
their agents learned from California Blue Cross that Patient 232’s benefits were not
assignable. Plaintiffs or their agents recorded this by circling “No” next to the line
“Assignable” on Patient 232’s Insurance Verification Form.
1284. On or about April 3, 2015, Plaintiffs began providing mental health and/or
substance abuse treatment to Patient 232.
1285. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Cross on the industry-standard UB-04 form. Plaintiffs
indicated that it was requesting that benefits be paid to it as an assignee by inserting
the letter Y in the appropriate field (box 53) each time it submitted a claim.
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 312 of 360 Page ID #:61932
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1286. On information and belief: California Blue Cross and/or the Aerospace
Plan thereafter paid some or all of the assigned benefits to Patient 232 instead of
Plaintiffs.
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 313 of 360 Page ID #:61933
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245 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
PATIENT 233
1287. On information and belief: Patient 233 was a participant in or beneficiary
of Defendant Albertson’s Plan during all times relevant to this complaint.
1288. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the Albertson’s Plan either (i) is insured by Idaho Blue
and/or California Blue Cross or (ii) is self-insured and has entered into an agreement
with Idaho Blue and/or California Blue Cross by which the Albertson’s Plan receives
third party administrative services.
1289. Plaintiffs obtained an assignment of benefits from Patient 233, who
executed an assignment in the same or substantially similar form to the document
attached hereto as Exhibit B.
1290. On or about January 8, 2015, Plaintiffs secured Patient 233’s consent to
contact Idaho Blue and/or California Blue Cross, along with the identifying
information necessary for Plaintiffs to interact with the insurer.
1291. On or about January 13, 2015, Plaintiffs began providing mental health
and/or substance abuse treatment to Patient 233.
1292. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Cross or Idaho Blue on the industry-standard UB-04
form. Plaintiffs indicated that it was requesting that benefits be paid to it as an assignee
by inserting the letter Y in the appropriate field (box 53) each time it submitted a claim.
1293. On information and belief: California Blue Cross, Idaho Blue, and/or the
Albertson’s Plan thereafter paid some or all of the assigned benefits to Patient 233
instead of Plaintiffs.
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 314 of 360 Page ID #:61934
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246 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
PATIENT 234
1294. On information and belief: Patient 234 was a participant in or beneficiary
of Defendant STCU Plan during all times relevant to this complaint.
1295. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the STCU Plan either (i) is insured by Washington Premera
Blue and/or California Blue Cross or (ii) is self-insured and has entered into an
agreement with Washington Premera Blue and/or California Blue Cross by which the
STCU Plan receives third party administrative services.
1296. Plaintiffs obtained an assignment of benefits from Patient 234, who
executed an assignment in the same or substantially similar form to the document
attached hereto as Exhibit B.
1297. On or about February 13, 2015, Plaintiffs secured Patient 234’s consent
to contact Washington Premera Blue and/or California Blue Cross, along with the
identifying information necessary for Plaintiffs to interact with the insurer.
1298. On or about February 23, 2015, Plaintiffs began providing mental health
and/or substance abuse treatment to Patient 234.
1299. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Cross or Washington Premera Blue on the industry-
standard UB-04 form. Plaintiffs indicated that it was requesting that benefits be paid
to it as an assignee by inserting the letter Y in the appropriate field (box 53) each time
it submitted a claim.
1300. On information and belief: California Blue Cross, Washington Premera
Blue, and/or the STCU Plan thereafter paid some or all of the assigned benefits to
Patient 234 instead of Plaintiffs.
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 315 of 360 Page ID #:61935
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247 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
PATIENT 235
1301. On information and belief: Patient 235 was a participant in or beneficiary
of Defendant CIL Plan during all times relevant to this complaint.
1302. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the CIL Plan either (i) is insured by Kansas City Blue and/or
California Blue Cross or (ii) is self-insured and has entered into an agreement with
Kansas City Blue and/or California Blue Cross by which the CIL Plan receives third
party administrative services.
1303. Plaintiffs obtained an assignment of benefits from Patient 235, who
executed an assignment in the same or substantially similar form to the document
attached hereto as Exhibit B.
1304. On or about January 20, 2015, Plaintiffs secured Patient 235’s consent to
contact Kansas City Blue and/or California Blue Cross, along with the identifying
information necessary for Plaintiffs to interact with the insurer.
1305. On or about January 20, 2015, Plaintiffs or their agents contacted the
Provider Hotline of Kansas City Blue and/or California Blue Cross and requested
details about Patient 235’s coverage. Plaintiffs or their agents recorded the information
learned from Kansas City Blue and/or California Blue Cross on the bottom of Patient
235’s Insurance Verification Form. Plaintiffs or their agents learned from Kansas City
Blue and/or California Blue Cross that Patient 235’s benefits were not assignable.
Plaintiffs or their agents recorded this by circling “No” next to the line “Assignable”
on Patient 235’s Insurance Verification Form.
1306. On or about February 10, 2015, Plaintiffs began providing mental health
and/or substance abuse treatment to Patient 235.
1307. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Cross or Kansas City Blue on the industry-standard
UB-04 form. Plaintiffs indicated that it was requesting that benefits be paid to it as an
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 316 of 360 Page ID #:61936
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assignee by inserting the letter Y in the appropriate field (box 53) each time it submitted
a claim.
1308. On information and belief: California Blue Cross, Kansas City Blue,
and/or the CIL Plan thereafter paid some or all of the assigned benefits to Patient 235
instead of Plaintiffs.
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 317 of 360 Page ID #:61937
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CASE NO. SACV15−0736 DOC (DFMx) 206541.1
PATIENT 236
1309. On information and belief: Patient 236 was a participant in or beneficiary
of an unknown ERISA-governed welfare plan during all times relevant to this
complaint.
1310. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the unknown plan either (i) is insured by California Blue
Shield or (ii) is self-insured and has entered into an agreement with California Blue
Shield by which the unknown plan receives third party administrative services.
1311. Plaintiffs obtained an assignment of benefits from Patient 236, who
executed an assignment in the same or substantially similar form to the document
attached hereto as Exhibit A.
1312. On or about July 24, 2013, Plaintiffs secured Patient 236’s consent to
contact California Blue Shield, along with the identifying information necessary for
Plaintiffs to interact with the insurer.
1313. On or about August 12, 2013, Plaintiffs began providing mental health
and/or substance abuse treatment to Patient 236.
1314. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Shield on the industry-standard UB-04 form.
Plaintiffs indicated that it was requesting that benefits be paid to it as an assignee by
inserting the letter Y in the appropriate field (box 53) each time it submitted a claim.
1315. On information and belief: California Blue Shield and/or the unknown
plan thereafter paid some or all of the assigned benefits to Patient 236 instead of
Plaintiffs.
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 318 of 360 Page ID #:61938
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CASE NO. SACV15−0736 DOC (DFMx) 206541.1
PATIENT 237
1316. On information and belief: Patient 237 was a participant in or beneficiary
of Defendant Intel Plan during all times relevant to this complaint.
1317. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the Intel Plan either (i) is insured by California Blue Cross
or (ii) is self-insured and has entered into an agreement with California Blue Cross by
which the Intel Plan receives third party administrative services.
1318. Plaintiffs obtained an assignment of benefits from Patient 237, who
executed an assignment in the same or substantially similar form to the document
attached hereto as Exhibit B.
1319. On or about September 11, 2014, Plaintiffs secured Patient 237’s consent
to contact California Blue Cross, along with the identifying information necessary for
Plaintiffs to interact with the insurer.
1320. On or about October 18, 2014, Plaintiffs began providing mental health
and/or substance abuse treatment to Patient 237, who validly assigned all claims arising
as a result of Plaintiffs’s services pursuant to the Intel Plan.
1321. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Cross on the industry-standard UB-04 form. Plaintiffs
indicated that it was requesting that benefits be paid to it as an assignee by inserting
the letter Y in the appropriate field (box 53) each time it submitted a claim.
1322. On information and belief: California Blue Cross and/or the Intel Plan
thereafter paid some or all of the assigned benefits to Patient 237 instead of Plaintiffs.
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PATIENT 238
1323. On information and belief: Patient 238 was a participant in or beneficiary
of Defendant Intevac Plan during all times relevant to this complaint.
1324. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the Intevac Plan either (i) is insured by California Blue
Cross or (ii) is self-insured and has entered into an agreement with California Blue
Cross by which the Intevac Plan receives third party administrative services.
1325. Plaintiffs obtained an assignment of benefits from Patient 238, who
executed an assignment in the same or substantially similar form to the document
attached hereto as Exhibit B.
1326. On or about October 8, 2014, Plaintiffs secured Patient 238’s consent to
contact California Blue Cross, along with the identifying information necessary for
Plaintiffs to interact with the insurer.
1327. On or about October 8, 2014, Plaintiffs or their agents contacted the
Provider Hotline of California Blue Cross and requested details about Patient 238’s
coverage. Plaintiffs or their agents recorded the information learned from California
Blue Cross on the bottom of Patient 238’s Insurance Verification Form. Plaintiffs or
their agents learned from California Blue Cross that Patient 238’s benefits were
assignable. Plaintiffs or their agents recorded this by circling “Yes” next to the line
“Assignable” on Patient 238’s Insurance Verification Form.
1328. On or about October 21, 2014, Plaintiffs began providing mental health
and/or substance abuse treatment to Patient 238.
1329. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Cross on the industry-standard UB-04 form. Plaintiffs
indicated that it was requesting that benefits be paid to it as an assignee by inserting
the letter Y in the appropriate field (box 53) each time it submitted a claim.
1330. On information and belief: California Blue Cross and/or the Intevac Plan
thereafter paid some or all of the assigned benefits to Patient 238 instead of Plaintiffs.
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 320 of 360 Page ID #:61940
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252 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
PATIENT 240
1331. On information and belief: Patient 240 was a participant in or beneficiary
of the Boucher Preferred Health Plan (the “Boucher Plan) during all times relevant to
this complaint.
1332. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the Boucher Plan either (i) is insured by Wisconsin Blue
and/or California Blue Cross or (ii) is self-insured and has entered into an agreement
with Wisconsin Blue and/or California Blue Cross by which the Boucher Plan receives
third party administrative services.
1333. Plaintiffs obtained an assignment of benefits from Patient 240, who
executed an assignment in the same or substantially similar form to the document
attached hereto as Exhibit B.
1334. On or about March 31, 2015, Plaintiffs secured Patient 240’s consent to
contact Wisconsin Blue and/or California Blue Cross, along with the identifying
information necessary for Plaintiffs to interact with the insurer.
1335. On or about April 8, 2015, Plaintiffs began providing mental health and/or
substance abuse treatment to Patient 240.
1336. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Cross or Wisconsin Blue on the industry-standard
UB-04 form. Plaintiffs indicated that it was requesting that benefits be paid to it as an
assignee by inserting the letter Y in the appropriate field (box 53) each time it submitted
a claim.
1337. On information and belief: California Blue Cross, Wisconsin Blue, and/or
the Boucher Plan thereafter paid some or all of the assigned benefits to Patient 240
instead of Plaintiffs.
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 321 of 360 Page ID #:61941
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253 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
PATIENT 241
1338. On information and belief: Patient 241 was a participant in or beneficiary
of an unknown ERISA-governed welfare plan during all times relevant to this
complaint.
1339. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the unknown plan either (i) is insured by Tennessee Blue
and/or California Blue Cross or (ii) is self-insured and has entered into an agreement
with Tennessee Blue and/or California Blue Cross by which the unknown plan receives
third party administrative services.
1340. Plaintiffs obtained an assignment of benefits from Patient 241, who
executed an assignment in the same or substantially similar form to the document
attached hereto as Exhibit B.
1341. On or about February 13, 2015, Plaintiffs secured Patient 241’s consent
to contact Tennessee Blue and/or California Blue Cross, along with the identifying
information necessary for Plaintiffs to interact with the insurer.
1342. On or about February 25, 2015, Plaintiffs began providing mental health
and/or substance abuse treatment to Patient 241.
1343. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Cross or Tennessee Blue on the industry-standard
UB-04 form. Plaintiffs indicated that it was requesting that benefits be paid to it as an
assignee by inserting the letter Y in the appropriate field (box 53) each time it submitted
a claim.
1344. On information and belief: California Blue Cross, Tennessee Blue, and/or
the unknown plan thereafter paid some or all of the assigned benefits to Patient 241
instead of Plaintiffs.
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 322 of 360 Page ID #:61942
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254 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
PATIENT 242
1345. On information and belief: Patient 242 was a participant in or beneficiary
of Defendant Tenet Plan during all times relevant to this complaint.
1346. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the Tenet Plan either (i) is insured by Texas Blue and/or
California Blue Cross or (ii) is self-insured and has entered into an agreement with
Texas Blue and/or California Blue Cross by which the Tenet Plan receives third party
administrative services.
1347. Plaintiffs obtained an assignment of benefits from Patient 242, who
executed an assignment in the same or substantially similar form to the document
attached hereto as Exhibit B.
1348. On or about March 31, 2015, Plaintiffs secured Patient 242’s consent to
contact Texas Blue and/or California Blue Cross, along with the identifying
information necessary for Plaintiffs to interact with the insurer.
1349. On or about April 10, 2015, Plaintiffs began providing mental health
and/or substance abuse treatment to Patient 242.
1350. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Cross or Texas Blue on the industry-standard UB-04
form. Plaintiffs indicated that it was requesting that benefits be paid to it as an assignee
by inserting the letter Y in the appropriate field (box 53) each time it submitted a claim.
1351. On information and belief: California Blue Cross, Texas Blue, and/or the
Tenet Plan thereafter paid some or all of the assigned benefits to Patient 242 instead of
Plaintiffs.
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 323 of 360 Page ID #:61943
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255 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
PATIENT 243
1352. On information and belief: Patient 243 was a participant in or beneficiary
of Defendant Lincoln Electric Plan during all times relevant to this complaint.
1353. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the Lincoln Electric Plan either (i) is insured by Ohio Blue
and/or California Blue Cross or (ii) is self-insured and has entered into an agreement
with Ohio Blue and/or California Blue Cross by which the Lincoln Electric Plan
receives third party administrative services.
1354. Plaintiffs obtained an assignment of benefits from Patient 243, who
executed an assignment in the same or substantially similar form to the document
attached hereto as Exhibit B.
1355. On or about February 19, 2015, Plaintiffs secured Patient 243’s consent
to contact Ohio Blue and/or California Blue Cross, along with the identifying
information necessary for Plaintiffs to interact with the insurer.
1356. On or about February 19, 2015, Plaintiffs or their agents contacted the
Provider Hotline of Ohio Blue and/or California Blue Cross and requested details about
Patient 243’s coverage. Plaintiffs or their agents recorded the information learned from
Ohio Blue and/or California Blue Cross on the bottom of Patient 243’s Insurance
Verification Form. Plaintiffs or their agents learned from Ohio Blue and/or California
Blue Cross that Patient 243’s benefits were assignable. Plaintiffs or their agents
recorded this by circling “Yes” next to the line “Assignable” on Patient 243’s Insurance
Verification Form.
1357. On or about February 22, 2015, Plaintiffs began providing mental health
and/or substance abuse treatment to Patient 243.
1358. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Cross or Ohio Blue on the industry-standard UB-04
form. Plaintiffs indicated that it was requesting that benefits be paid to it as an assignee
by inserting the letter Y in the appropriate field (box 53) each time it submitted a claim.
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 324 of 360 Page ID #:61944
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CASE NO. SACV15−0736 DOC (DFMx) 206541.1
1359. On information and belief: California Blue Cross, Ohio Blue, and/or the
Lincoln Electric Plan thereafter paid some or all of the assigned benefits to Patient 243
instead of Plaintiffs.
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257 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
PATIENT 244
1360. On information and belief: Patient 244 was a participant in or beneficiary
of Defendant Interrail Plan during all times relevant to this complaint.
1361. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the Interrail Plan either (i) is insured by Tennessee Blue
and/or California Blue Cross or (ii) is self-insured and has entered into an agreement
with Tennessee Blue and/or California Blue Cross by which the Interrail Plan receives
third party administrative services.
1362. Plaintiffs obtained an assignment of benefits from Patient 244, who
executed an assignment in the same or substantially similar form to the document
attached hereto as Exhibit B.
1363. On or about April 20, 2015, Plaintiffs secured Patient 244’s consent to
contact Tennessee Blue and/or California Blue Cross, along with the identifying
information necessary for Plaintiffs to interact with the insurer.
1364. On or about April 24, 2015, Plaintiffs began providing mental health
and/or substance abuse treatment to Patient 244.
1365. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Cross or Tennessee Blue on the industry-standard
UB-04 form. Plaintiffs indicated that it was requesting that benefits be paid to it as an
assignee by inserting the letter Y in the appropriate field (box 53) each time it submitted
a claim.
1366. On information and belief: California Blue Cross, Tennessee Blue, and/or
the Interrail Plan thereafter paid some or all of the assigned benefits to Patient 244
instead of Plaintiffs.
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 326 of 360 Page ID #:61946
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258 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
PATIENT 245
1367. On information and belief: Patient 245 was a participant in or beneficiary
of Defendant Surgical Partners Plan during all times relevant to this complaint.
1368. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the Surgical Partners Plan either (i) is insured by Texas Blue
and/or California Blue Cross or (ii) is self-insured and has entered into an agreement
with Texas Blue and/or California Blue Cross by which the Surgical Partners Plan
receives third party administrative services.
1369. Plaintiffs obtained an assignment of benefits from Patient 245, who
executed an assignment in the same or substantially similar form to the document
attached hereto as Exhibit B.
1370. On or about February 2, 2015, Plaintiffs secured Patient 245’s consent to
contact Texas Blue and/or California Blue Cross, along with the identifying
information necessary for Plaintiffs to interact with the insurer.
1371. On or about February 6, 2015, Plaintiffs began providing mental health
and/or substance abuse treatment to Patient 245.
1372. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Cross or Texas Blue on the industry-standard UB-04
form. Plaintiffs indicated that it was requesting that benefits be paid to it as an assignee
by inserting the letter Y in the appropriate field (box 53) each time it submitted a claim.
1373. On information and belief: California Blue Cross, Texas Blue, and/or the
Surgical Partners Plan thereafter paid some or all of the assigned benefits to Patient
245 instead of Plaintiffs.
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 327 of 360 Page ID #:61947
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259 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
PATIENT 246
1374. On information and belief: Patient 246 was a participant in or beneficiary
of the Ascension Plan during all times relevant to this complaint.
1375. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the Ascension Plan either (i) is insured by Michigan Blue
and/or California Blue Cross or (ii) is self-insured and has entered into an agreement
with Michigan Blue and/or California Blue Cross by which the Ascension Plan
receives third party administrative services.
1376. Plaintiffs obtained an assignment of benefits from Patient 246, who
executed an assignment in the same or substantially similar form to the document
attached hereto as Exhibit B.
1377. On or about September 29, 2014, Plaintiffs secured Patient 246’s consent
to contact Michigan Blue and/or California Blue Cross, along with the identifying
information necessary for Plaintiffs to interact with the insurer.
1378. On or about October 6, 2014, Plaintiffs began providing mental health
and/or substance abuse treatment to Patient 246.
1379. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Cross or Michigan Blue on the industry-standard UB-
04 form. Plaintiffs indicated that it was requesting that benefits be paid to it as an
assignee by inserting the letter Y in the appropriate field (box 53) each time it submitted
a claim.
1380. On information and belief: California Blue Cross, Michigan Blue, and/or
the Ascension Plan thereafter paid some or all of the assigned benefits to Patient 246
instead of Plaintiffs.
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 328 of 360 Page ID #:61948
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260 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
PATIENT 247
1381. On information and belief: Patient 247 was a participant in or beneficiary
of Defendant Kentucky Construction Plan during all times relevant to this complaint.
1382. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the Kentucky Construction Plan either (i) is insured by
Kentucky Blue and/or California Blue Cross or (ii) is self-insured and has entered into
an agreement with Kentucky Blue and/or California Blue Cross by which the Kentucky
Construction Plan receives third party administrative services.
1383. Plaintiffs obtained an assignment of benefits from Patient 247, who
executed an assignment in the same or substantially similar form to the document
attached hereto as Exhibit B.
1384. On or about April 15, 2015, Plaintiffs secured Patient 247’s consent to
contact Kentucky Blue and/or California Blue Cross, along with the identifying
information necessary for Plaintiffs to interact with the insurer.
1385. On or about April 15, 2015, Plaintiffs or their agents contacted the
Provider Hotline of Kentucky Blue and/or California Blue Cross and requested details
about Patient 247’s coverage. Plaintiffs or their agents recorded the information
learned from Kentucky Blue and/or California Blue Cross on the bottom of Patient
247’s Insurance Verification Form. Plaintiffs or their agents learned from Kentucky
Blue and/or California Blue Cross that Patient 247’s benefits were assignable.
Plaintiffs or their agents recorded this by circling “Yes” next to the line “Assignable”
on Patient 247’s Insurance Verification Form.
1386. On or about April 17, 2015, Plaintiffs began providing mental health
and/or substance abuse treatment to Patient 247.
1387. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Cross or Kentucky Blue on the industry-standard UB-
04 form. Plaintiffs indicated that it was requesting that benefits be paid to it as an
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 329 of 360 Page ID #:61949
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261 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
assignee by inserting the letter Y in the appropriate field (box 53) each time it submitted
a claim.
1388. On information and belief: California Blue Cross, Kentucky Blue, and/or
the Kentucky Construction Plan thereafter paid some or all of the assigned benefits to
Patient 247 instead of Plaintiffs.
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 330 of 360 Page ID #:61950
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262 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
PATIENT 248
1389. On information and belief: Patient 248 was a participant in or beneficiary
of Defendant GNC Plan during all times relevant to this complaint.
1390. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the GNC Plan either (i) is insured by Western Pennsylvania
Blue, Highmark, and/or California Blue Cross or (ii) is self-insured and has entered
into an agreement with Western Pennsylvania Blue, Highmark, and/or California Blue
Cross by which the GNC Plan receives third party administrative services.
1391. Plaintiffs obtained an assignment of benefits from Patient 248, who
executed an assignment in the same or substantially similar form to the document
attached hereto as Exhibit B.
1392. On or about February 9, 2015, Plaintiffs secured Patient 248’s consent to
contact Western Pennsylvania Blue, Highmark, and/or California Blue Cross, along
with the identifying information necessary for Plaintiffs to interact with the insurer.
1393. On or about February 18, 2015, Plaintiffs began providing mental health
and/or substance abuse treatment to Patient 248.
1394. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Cross, Western Pennsylvania Blue, or Highmark on
the industry-standard UB-04 form. Plaintiffs indicated that it was requesting that
benefits be paid to it as an assignee by inserting the letter Y in the appropriate field
(box 53) each time it submitted a claim.
1395. On information and belief: California Blue Cross, Western Pennsylvania
Blue, Highmark, and/or the GNC Plan thereafter paid some or all of the assigned
benefits to Patient 248 instead of Plaintiffs.
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 331 of 360 Page ID #:61951
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263 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
PATIENT 249
1396. On information and belief: Patient 249 was a participant in or beneficiary
of Defendant CIL Plan during all times relevant to this complaint.
1397. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the CIL Plan either (i) is insured by Kansas City Blue and/or
California Blue Cross or (ii) is self-insured and has entered into an agreement with
Kansas City Blue and/or California Blue Cross by which the CIL Plan receives third
party administrative services.
1398. Plaintiffs obtained an assignment of benefits from Patient 249, who
executed an assignment in the same or substantially similar form to the document
attached hereto as Exhibit B.
1399. On or about January 23, 2015, Plaintiffs secured Patient 249’s consent to
contact Kansas City Blue and/or California Blue Cross, along with the identifying
information necessary for Plaintiffs to interact with the insurer.
1400. On or about January 23, 2015, Plaintiffs or their agents contacted the
Provider Hotline of Kansas City Blue and/or California Blue Cross and requested
details about Patient 249’s coverage. Plaintiffs or their agents recorded the information
learned from Kansas City Blue and/or California Blue Cross on the bottom of Patient
249’s Insurance Verification Form. Plaintiffs or their agents learned from Kansas City
Blue and/or California Blue Cross that Patient 249’s benefits were not assignable.
Plaintiffs or their agents recorded this by circling “No” next to the line “Assignable”
on Patient 249’s Insurance Verification Form.
1401. On or about February 17, 2015, Plaintiffs began providing mental health
and/or substance abuse treatment to Patient 249.
1402. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Cross or Kansas City Blue on the industry-standard
UB-04 form. Plaintiffs indicated that it was requesting that benefits be paid to it as an
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264 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
assignee by inserting the letter Y in the appropriate field (box 53) each time it submitted
a claim.
1403. On information and belief: California Blue Cross, Kansas City Blue,
and/or the CIL Plan thereafter paid some or all of the assigned benefits to Patient 249
instead of Plaintiffs.
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 333 of 360 Page ID #:61953
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265 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
PATIENT 250
1404. On information and belief: Patient 250 was a participant in or beneficiary
of Defendant SCANA Plan during all times relevant to this complaint.
1405. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the SCANA Plan either (i) is insured by South Carolina
Blue and/or California Blue Cross or (ii) is self-insured and has entered into an
agreement with South Carolina Blue and/or California Blue Cross by which the
SCANA Plan receives third party administrative services.
1406. Plaintiffs obtained an assignment of benefits from Patient 250, who
executed an assignment in the same or substantially similar form to the document
attached hereto as Exhibit B.
1407. On or about February 18, 2015, Plaintiffs secured Patient 250’s consent
to contact South Carolina Blue and/or California Blue Cross, along with the identifying
information necessary for Plaintiffs to interact with the insurer.
1408. On or about February 24, 2015, Plaintiffs began providing mental health
and/or substance abuse treatment to Patient 250.
1409. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Cross or South Carolina Blue on the industry-standard
UB-04 form. Plaintiffs indicated that it was requesting that benefits be paid to it as an
assignee by inserting the letter Y in the appropriate field (box 53) each time it submitted
a claim.
1410. California Blue Cross, South Carolina Blue, and/or the SCANA Plan
thereafter paid some or all of the assigned benefits to Patient 250 instead of Plaintiffs.
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PATIENT 251
1411. On information and belief: Patient 251 was a participant in or beneficiary
of Defendant Northrop Grumman Plan during all times relevant to this complaint.
1412. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the Northrop Grumman Plan either (i) is insured by
California Blue Cross or (ii) is self-insured and has entered into an agreement with
California Blue Cross by which the Northrop Grumman Plan receives third party
administrative services.
1413. Plaintiffs obtained an assignment of benefits from Patient 251, who
executed an assignment in the same or substantially similar form to the document
attached hereto as Exhibit B.
1414. On or about September 16, 2014, Plaintiffs secured Patient 251’s consent
to contact California Blue Cross, along with the identifying information necessary for
Plaintiffs to interact with the insurer.
1415. On or about October 2, 2014, Plaintiffs began providing mental health
and/or substance abuse treatment to Patient 251.
1416. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Cross on the industry-standard UB-04 form. Plaintiffs
indicated that it was requesting that benefits be paid to it as an assignee by inserting
the letter Y in the appropriate field (box 53) each time it submitted a claim.
1417. On information and belief: California Blue Cross and/or the Northrop
Grumman Plan thereafter paid some or all of the assigned benefits to Patient 251
instead of Plaintiffs.
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PATIENT 252
1418. On information and belief: Patient 252 was a participant in or beneficiary
of Defendant FAS Plan during all times relevant to this complaint.
1419. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the FAS Plan either (i) is insured by Florida Blue and/or
California Blue Cross or (ii) is self-insured and has entered into an agreement with
Florida Blue and/or California Blue Cross by which the FAS Plan receives third party
administrative services.
1420. Plaintiffs obtained an assignment of benefits from Patient 252, who
executed an assignment in the same or substantially similar form to the document
attached hereto as Exhibit B.
1421. On or about March 23, 2015, Plaintiffs secured Patient 252’s consent to
contact Florida Blue and/or California Blue Cross, along with the identifying
information necessary for Plaintiffs to interact with the insurer.
1422. On or about March 23, 2015, Plaintiffs or their agents contacted the
Provider Hotline of Florida Blue and/or California Blue Cross and requested details
about Patient 252’s coverage. Plaintiffs or their agents recorded the information
learned from Florida Blue and/or California Blue Cross on the bottom of Patient 252’s
Insurance Verification Form. Plaintiffs or their agents learned from Florida Blue and/or
California Blue Cross that Patient 252’s benefits were not assignable. Plaintiffs or their
agents recorded this by circling “No” next to the line “Assignable” on Patient 252’s
Insurance Verification Form.
1423. On or about March 24, 2015, Plaintiffs began providing mental health
and/or substance abuse treatment to Patient 252.
1424. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Cross or Florida Blue on the industry-standard UB-
04 form. Plaintiffs indicated that it was requesting that benefits be paid to it as an
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assignee by inserting the letter Y in the appropriate field (box 53) each time it submitted
a claim.
1425. On information and belief: California Blue Cross, Florida Blue, and/or the
FAS Plan thereafter paid some or all of the assigned benefits to Patient 252 instead of
Plaintiffs.
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 337 of 360 Page ID #:61957
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269 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
PATIENT 253
1426. On information and belief: Patient 253 was a participant in or beneficiary
of Defendant Layne Plan during all times relevant to this complaint.
1427. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the Layne Plan either (i) is insured by Kansas City Blue
and/or California Blue Shield or (ii) is self-insured and has entered into an agreement
with Kansas City Blue and/or California Blue Shield by which the Layne Plan receives
third party administrative services.
1428. Plaintiffs obtained an assignment of benefits from Patient 253, who
executed an assignment in the same or substantially similar form to the document
attached hereto as Exhibit B.
1429. On or about April 1, 2013, Plaintiffs secured Patient 253’s consent to
contact Kansas City Blue and/or California Blue Shield, along with the identifying
information necessary for Plaintiffs to interact with the insurer.
1430. On or about April 2, 2013, Plaintiffs began providing mental health and/or
substance abuse treatment to Patient 253.
1431. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Shield or Kansas City Blue on the industry-standard
UB-04 form. Plaintiffs indicated that it was requesting that benefits be paid to it as an
assignee by inserting the letter Y in the appropriate field (box 53) each time it submitted
a claim.
1432. On information and belief: California Blue Cross, Kansas City Blue,
and/or the Layne Plan thereafter paid some or all of the assigned benefits to Patient
253 instead of Plaintiffs.
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 338 of 360 Page ID #:61958
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270 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
PATIENT 254
1433. On information and belief: Patient 254 was a participant in or beneficiary
of Defendant L Brands Plan during all times relevant to this complaint.
1434. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the L Brands Plan either (i) is insured by Ohio Blue and/or
California Blue Cross or (ii) is self-insured and has entered into an agreement with
Ohio Blue and/or California Blue Cross by which the L Brands Plan receives third
party administrative services.
1435. Plaintiffs obtained an assignment of benefits from Patient 254, who
executed an assignment in the same or substantially similar form to the document
attached hereto as Exhibit B.
1436. On or about May 7, 2015, Plaintiffs secured Patient 254’s consent to
contact Ohio Blue and/or California Blue Cross, along with the identifying information
necessary for Plaintiffs to interact with the insurer.
1437. On or about May 18, 2015, Plaintiffs began providing mental health
and/or substance abuse treatment to Patient 254.
1438. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Cross or Ohio Blue on the industry-standard UB-04
form. Plaintiffs indicated that it was requesting that benefits be paid to it as an assignee
by inserting the letter Y in the appropriate field (box 53) each time it submitted a claim.
1439. On information and belief: California Blue Cross, Ohio Blue, and/or the
L Brands Plan thereafter paid some or all of the assigned benefits to Patient 254 instead
of Plaintiffs.
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 339 of 360 Page ID #:61959
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271 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
PATIENT 255
1440. On information and belief: Patient 255 was a participant in or beneficiary
of Defendant Asante Plan during all times relevant to this complaint.
1441. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the Asante Plan either (i) is insured by Oregon Blue and/or
California Blue Cross or (ii) is self-insured and has entered into an agreement with
Oregon Blue and/or California Blue Cross by which the Asante Plan receives third
party administrative services.
1442. Plaintiffs obtained an assignment of benefits from Patient 255, who
executed an assignment in the same or substantially similar form to the document
attached hereto as Exhibit B.
1443. On or about May 19, 2015, Plaintiffs secured Patient 255’s consent to
contact Oregon Blue and/or California Blue Cross, along with the identifying
information necessary for Plaintiffs to interact with the insurer.
1444. On or about May 19, 2015, Plaintiffs or their agents contacted the Provider
Hotline of Oregon Blue and/or California Blue Cross and requested details about
Patient 255’s coverage. Plaintiffs or their agents recorded the information learned from
Oregon Blue and/or California Blue Cross on the bottom of Patient 255’s Insurance
Verification Form. Plaintiffs or their agents learned from Oregon Blue and/or
California Blue Cross that Patient 255’s benefits were not assignable. Plaintiffs or their
agents recorded this by circling “No” next to the line “Assignable” on Patient 255’s
Insurance Verification Form.
1445. On or about May 20, 2015, Plaintiffs began providing mental health
and/or substance abuse treatment to Patient 255.
1446. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Cross or Oregon Blue on the industry-standard UB-
04 form. Plaintiffs indicated that it was requesting that benefits be paid to it as an
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assignee by inserting the letter Y in the appropriate field (box 53) each time it submitted
a claim.
1447. On information and belief: California Blue Cross, Oregon Blue, and/or
the Asante Plan thereafter paid some or all of the assigned benefits to Patient 255
instead of Plaintiffs.
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 341 of 360 Page ID #:61961
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273 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
PATIENT 256
1448. On information and belief: Patient 256 was a participant in or beneficiary
of Defendant Nature’s Path Plan during all times relevant to this complaint.
1449. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the Nature’s Path Plan either (i) is insured by Washington
Premera Blue and/or California Blue Cross or (ii) is self-insured and has entered into
an agreement with Washington Premera Blue and/or California Blue Cross by which
the Nature’s Path Plan receives third party administrative services.
1450. Plaintiffs obtained an assignment of benefits from Patient 256, who
executed an assignment in the same or substantially similar form to the document
attached hereto as Exhibit B.
1451. On or about February 5, 2015, Plaintiffs secured Patient 256’s consent to
contact Washington Premera Blue and/or California Blue Cross, along with the
identifying information necessary for Plaintiffs to interact with the insurer.
1452. On or about February 5, 2015, Plaintiffs or their agents contacted the
Provider Hotline of Washington Premera Blue and/or California Blue Cross and
requested details about Patient 256’s coverage. Plaintiffs or their agents recorded the
information learned from Washington Premera Blue and/or California Blue Cross on
the bottom of Patient 256’s Insurance Verification Form. Plaintiffs or their agents
learned from Washington Premera Blue and/or California Blue Cross that Patient 256’s
benefits were not assignable. Plaintiffs or their agents recorded this by circling “No”
next to the line “Assignable” on Patient 256’s Insurance Verification Form.
1453. On or about February 18, 2015, Plaintiffs began providing mental health
and/or substance abuse treatment to Patient 256.
1454. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Cross or Washington Premera Blue on the industry-
standard UB-04 form. Plaintiffs indicated that it was requesting that benefits be paid
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 342 of 360 Page ID #:61962
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to it as an assignee by inserting the letter Y in the appropriate field (box 53) each time
it submitted a claim.
1455. On information and belief: California Blue Cross, Washington Premera
Blue, and/or the Nature’s Path Plan thereafter paid some or all of the assigned benefits
to Patient 256 instead of Plaintiffs.
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275 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
PATIENT 258
1456. On information and belief: Patient 258 was a participant in or beneficiary
of Defendant Sage Software Plan during all times relevant to this complaint.
1457. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the Sage Software Plan either (i) is insured by California
Blue Cross or (ii) is self-insured and has entered into an agreement with California
Blue Cross by which the Sage Software Plan receives third party administrative
services.
1458. Plaintiffs obtained an assignment of benefits from Patient 258, who
executed an assignment in the same or substantially similar form to the document
attached hereto as Exhibit B.
1459. On or about February 24, 2015, Plaintiffs secured Patient 258’s consent
to contact California Blue Cross, along with the identifying information necessary for
Plaintiffs to interact with the insurer.
1460. On or about March 3, 2015, Plaintiffs began providing mental health
and/or substance abuse treatment to Patient 258.
1461. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Cross on the industry-standard UB-04 form. Plaintiffs
indicated that it was requesting that benefits be paid to it as an assignee by inserting
the letter Y in the appropriate field (box 53) each time it submitted a claim.
1462. On information and belief: California Blue Cross and/or the Sage
Software Plan thereafter paid some or all of the assigned benefits to Patient 258 instead
of Plaintiffs.
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 344 of 360 Page ID #:61964
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276 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
CASE NO. SACV15−0736 DOC (DFMx) 206541.1
PATIENT 259
1463. On information and belief: Patient 259 was a participant in or beneficiary
of Yates Petroleum Corporation, et al. Flexible Benefits Cafeteria Plan (the “Yates
Petroleum Plan”) during all times relevant to this complaint.
1464. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the Yates Petroleum Plan either (i) is insured by New
Mexico Blue and/or California Blue Cross or (ii) is self-insured and has entered into
an agreement with New Mexico Blue and/or California Blue Cross by which the Yates
Petroleum Plan receives third party administrative services.
1465. Plaintiffs obtained an assignment of benefits from Patient 259, who
executed an assignment in the same or substantially similar form to the document
attached hereto as Exhibit B.
1466. On or about January 5, 2015, Plaintiffs secured Patient 259’s consent to
contact New Mexico Blue and/or California Blue Cross, along with the identifying
information necessary for Plaintiffs to interact with the insurer.
1467. On or about January 8, 2015, Plaintiffs began providing mental health
and/or substance abuse treatment to Patient 259.
1468. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Cross or New Mexico Blue on the industry-standard
UB-04 form. Plaintiffs indicated that it was requesting that benefits be paid to it as an
assignee by inserting the letter Y in the appropriate field (box 53) each time it submitted
a claim.
1469. On information and belief: California Blue Cross, New Mexico Blue,
and/or the Yates Petroleum Plan thereafter paid some or all of the assigned benefits to
Patient 259 instead of Plaintiffs.
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 345 of 360 Page ID #:61965
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277 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
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PATIENT 260
1470. On information and belief: Patient 260 was a participant in or beneficiary
of Defendant U.S. Steel Plan during all times relevant to this complaint.
1471. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the U.S. Steel Plan either (i) is insured by Western
Pennsylvania Blue, Highmark, and/or California Blue Cross or (ii) is self-insured and
has entered into an agreement with Western Pennsylvania Blue, Highmark, and/or
California Blue Cross by which the U.S. Steel Plan receives third party administrative
services.
1472. Plaintiffs obtained an assignment of benefits from Patient 260, who
executed an assignment in the same or substantially similar form to the document
attached hereto as Exhibit B.
1473. On or about December 4, 2014, Plaintiffs secured Patient 260’s consent
to contact Western Pennsylvania Blue, Highmark, and/or California Blue Cross, along
with the identifying information necessary for Plaintiffs to interact with the insurer.
1474. On or about December 13, 2014, Plaintiffs began providing mental health
and/or substance abuse treatment to Patient 260.
1475. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Cross, Western Pennsylvania Blue, or Highmark on
the industry-standard UB-04 form. Plaintiffs indicated that it was requesting that
benefits be paid to it as an assignee by inserting the letter Y in the appropriate field
(box 53) each time it submitted a claim.
1476. On information and belief: California Blue Cross, Western Pennsylvania
Blue, Highmark, and/or the U.S. Steel Plan thereafter paid some or all of the assigned
benefits to Patient 260 instead of Plaintiffs.
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 346 of 360 Page ID #:61966
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278 APPENDIX OF PATIENT-SPECIFIC ALLEGATIONS
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PATIENT 261
1477. On information and belief: Patient 261 was a participant in or beneficiary
of Defendant Bayhealth Plan during all times relevant to this complaint.
1478. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the Bayhealth Plan either (i) is insured by Delaware Blue
and/or California Blue Cross or (ii) is self-insured and has entered into an agreement
with Delaware Blue and/or California Blue Cross by which the Bayhealth Plan receives
third party administrative services.
1479. Plaintiffs obtained an assignment of benefits from Patient 261, who
executed an assignment in the same or substantially similar form to the document
attached hereto as Exhibit B.
1480. On or about February 20, 2015, Plaintiffs secured Patient 261’s consent
to contact Delaware Blue and/or California Blue Cross, along with the identifying
information necessary for Plaintiffs to interact with the insurer.
1481. On or about February 20, 2015, Plaintiffs or their agents contacted the
Provider Hotline of Delaware Blue and/or California Blue Cross and requested details
about Patient 261’s coverage. Plaintiffs or their agents recorded the information
learned from Delaware Blue and/or California Blue Cross on the bottom of Patient
261’s Insurance Verification Form. Plaintiffs or their agents learned from Delaware
Blue and/or California Blue Cross that Patient 261’s benefits were assignable.
Plaintiffs or their agents recorded this by circling “Yes” next to the line “Assignable”
on Patient 261’s Insurance Verification Form.
1482. On or about May 7, 2015, Plaintiffs began providing mental health and/or
substance abuse treatment to Patient 261.
1483. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Cross or Delaware Blue on the industry-standard UB-
04 form. Plaintiffs indicated that it was requesting that benefits be paid to it as an
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assignee by inserting the letter Y in the appropriate field (box 53) each time it submitted
a claim.
1484. On information and belief: California Blue Cross, Delaware Blue, and/or
the Bayhealth Plan thereafter paid some or all of the assigned benefits to Patient 261
instead of Plaintiffs.
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 348 of 360 Page ID #:61968
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PATIENT 264
1485. On information and belief: Patient 264 was a participant in or beneficiary
of Defendant UFCW Plan during all times relevant to this complaint.
1486. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the Portland UFCW Plan either (i) is insured by Oregon
Blue and/or California Blue Cross or (ii) is self-insured and has entered into an
agreement with Oregon Blue and/or California Blue Cross by which the UFCW Plan
receives third party administrative services.
1487. Plaintiffs obtained an assignment of benefits from Patient 264, who
executed an assignment in the same or substantially similar form to the document
attached hereto as Exhibit B.
1488. On or about October 7, 2014, Plaintiffs secured Patient 264’s consent to
contact Oregon Blue and/or California Blue Cross, along with the identifying
information necessary for Plaintiffs to interact with the insurer.
1489. On or about October 7, 2014, Plaintiffs or their agents contacted the
Provider Hotline of Oregon Blue and/or California Blue Cross and requested details
about Patient 264’s coverage. Plaintiffs or their agents recorded the information
learned from Oregon Blue and/or California Blue Cross on the bottom of Patient 264’s
Insurance Verification Form. Plaintiffs or their agents learned from Oregon Blue
and/or California Blue Cross that Patient 264’s benefits were assignable. Plaintiffs or
their agents recorded this by circling “Yes” next to the line “Assignable” on Patient
264’s Insurance Verification Form.
1490. On or about November 12, 2014, Plaintiffs began providing mental health
and/or substance abuse treatment to Patient 264.
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1491. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Cross or Oregon Blue on the industry-standard UB-
04 form. Plaintiffs indicated that it was requesting that benefits be paid to it as an
assignee by inserting the letter Y in the appropriate field (box 53) each time it submitted
a claim.
1492. On information and belief: California Blue Cross, Oregon Blue, and/or
the UFCW Plan thereafter paid some or all of the assigned benefits to Patient 264
instead of Plaintiffs.
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PATIENT 268
1493. On information and belief: Patient 268 was a participant in or beneficiary
of Defendant Einstein Bagels Plan during all times relevant to this complaint.
1494. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the Einstein Bagels Plan either (i) is insured by Colorado
Blue and/or California Blue Cross or (ii) is self-insured and has entered into an
agreement with Colorado Blue and/or California Blue Cross by which the Einstein
Bagels Plan receives third party administrative services.
1495. Plaintiffs obtained an assignment of benefits from Patient 268, who
executed an assignment in the same or substantially similar form to the document
attached hereto as Exhibit B.
1496. On or about October 24, 2014, Plaintiffs secured Patient 268’s consent to
contact Colorado Blue and/or California Blue Cross, along with the identifying
information necessary for Plaintiffs to interact with the insurer.
1497. On or about October 24, 2014, Plaintiffs or their agents contacted the
Provider Hotline of Colorado Blue and/or California Blue Cross and requested details
about Patient 268’s coverage. Plaintiffs or their agents recorded the information
learned from Colorado Blue and/or California Blue Cross on the bottom of Patient
268’s Insurance Verification Form. Plaintiffs or their agents learned from Colorado
Blue and/or California Blue Cross that Patient 268’s benefits were assignable.
Plaintiffs or their agents recorded this by circling “Yes” next to the line “Assignable”
on Patient 268’s Insurance Verification Form.
1498. On or about November 3, 2014, Plaintiffs began providing mental health
and/or substance abuse treatment to Patient 268.
1499. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Cross or Colorado Blue on the industry-standard UB-
04 form. Plaintiffs indicated that it was requesting that benefits be paid to it as an
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assignee by inserting the letter Y in the appropriate field (box 53) each time it submitted
a claim.
1500. On information and belief: California Blue Cross, Colorado Blue, and/or
the Einstein Bagels Plan thereafter paid some or all of the assigned benefits to Patient
268 instead of Plaintiffs.
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 352 of 360 Page ID #:61972
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PATIENT 269
1501. On information and belief: Patient 269 was a participant in or beneficiary
of Defendant Nor. Cal. SMW Plan during all times relevant to this complaint.
1502. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the Nor. Cal. SMW Plan either (i) is insured by California
Blue Shield or (ii) is self-insured and has entered into an agreement with California
Blue Shield by which the Nor. Cal. SMW Plan receives third party administrative
services.
1503. Plaintiffs obtained an assignment of benefits from Patient 269, who
executed an assignment in the same or substantially similar form to the document
attached hereto as Exhibit B.
1504. On or about January 5, 2015, Plaintiffs secured Patient 269’s consent to
contact California Blue Cross, along with the identifying information necessary for
Plaintiffs to interact with the insurer.
1505. On or about January 5, 2015, Plaintiffs or their agents contacted the
Provider Hotline of California Blue Shield and requested details about Patient 269’s
coverage. Plaintiffs or their agents recorded the information learned from California
Blue Shield on the bottom of Patient 269’s Insurance Verification Form. Plaintiffs or
their agents learned from California Blue Shield that Patient 269’s benefits were not
assignable. Plaintiffs or their agents recorded this by circling “No” next to the line
“Assignable” on Patient 269’s Insurance Verification Form.
1506. On or about January 7, 2015, Plaintiffs began providing mental health
and/or substance abuse treatment to Patient 269.
1507. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Shield on the industry-standard UB-04 form.
Plaintiffs indicated that it was requesting that benefits be paid to it as an assignee by
inserting the letter Y in the appropriate field (box 53) each time it submitted a claim.
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1508. On information and belief: California Blue Shield and/or the Nor. Cal.
SMW Plan thereafter paid some or all of the assigned benefits to Patient 269 instead
of Plaintiffs.
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 354 of 360 Page ID #:61974
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PATIENT 270
1509. On information and belief: Patient 270 was a participant in or beneficiary
of Defendant Jennings Plan during all times relevant to this complaint.
1510. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the Jennings Plan either (i) is insured by Louisiana Blue
and/or California Blue Cross or (ii) is self-insured and has entered into an agreement
with Louisiana Blue and/or California Blue Cross by which the Jennings Plan receives
third party administrative services.
1511. Plaintiffs obtained an assignment of benefits from Patient 270, who
executed an assignment in the same or substantially similar form to the document
attached hereto as Exhibit B.
1512. On or about February 23, 2015, Plaintiffs secured Patient 270’s consent
to contact Louisiana Blue and/or California Blue Cross, along with the identifying
information necessary for Plaintiffs to interact with the insurer.
1513. On or about February 23, 2015, Plaintiffs or their agents contacted the
Provider Hotline of Louisiana Blue and/or California Blue Cross and requested details
about Patient 270’s coverage. Plaintiffs or their agents recorded the information
learned from Louisiana Blue and/or California Blue Cross on the bottom of Patient
270’s Insurance Verification Form. Plaintiffs or their agents learned from Louisiana
Blue and/or California Blue Cross that Patient 270’s benefits were assignable.
Plaintiffs or their agents recorded this by circling “Yes” next to the line “Assignable”
on Patient 270’s Insurance Verification Form.
1514. On or about March 11, 2015, Plaintiffs began providing mental health
and/or substance abuse treatment to Patient 270.
1515. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Cross or Louisiana Blue on the industry-standard UB-
04 form. Plaintiffs indicated that it was requesting that benefits be paid to it as an
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 355 of 360 Page ID #:61975
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assignee by inserting the letter Y in the appropriate field (box 53) each time it submitted
a claim.
1516. On information and belief: California Blue Cross, Louisiana Blue, and/or
the Jennings Plan thereafter paid some or all of the assigned benefits to Patient 270
instead of Plaintiffs.
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PATIENT 271
1517. On information and belief: Patient 271 was a participant in or beneficiary
of the United Support Services, Inc. Group Health Plan (the “Support Services Plan”)
during all times relevant to this complaint.
1518. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the Support Services Plan either (i) is insured by North
Carolina Blue and/or California Blue Cross or (ii) is self-insured and has entered into
an agreement with North Carolina Blue and/or California Blue Cross by which the
Support Services Plan receives third party administrative services.
1519. Plaintiffs obtained an assignment of benefits from Patient 271, who
executed an assignment in the same or substantially similar form to the document
attached hereto as Exhibit B.
1520. On or about March 30, 2015, Plaintiffs secured Patient 271’s consent to
contact North Carolina Blue and/or California Blue Cross, along with the identifying
information necessary for Plaintiffs to interact with the insurer.
1521. On or about April 3, 2015, Plaintiffs began providing mental health and/or
substance abuse treatment to Patient 271.
1522. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Cross or North Carolina Blue on the industry-standard
UB-04 form. Plaintiffs indicated that it was requesting that benefits be paid to it as an
assignee by inserting the letter Y in the appropriate field (box 53) each time it submitted
a claim.
1523. On information and belief: California Blue Cross, North Carolina Blue,
and/or the Support Services Plan thereafter paid some or all of the assigned benefits to
Patient 271 instead of Plaintiffs.
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PATIENT 272 1524. On information and belief: Patient 272 was a participant in or beneficiary
of the Mercy Health Services, Inc. and Subsidiaries Medical Plan (the “Mercy Plan”) during all times relevant to this complaint.
1525. On information and belief: With regard to the relevant welfare benefits implicated by this lawsuit: the Mercy Plan either (i) is insured by California Blue Cross, CareFirst Maryland Blue and/or CareFirst District of Columbia Blue or (ii) is self-insured and has entered into an agreement with California Blue Cross, CareFirst Maryland Blue and/or CareFirst District of Columbia Blue by which the Mercy Plan receives third party administrative services.
1526. Plaintiffs obtained an assignment of benefits from Patient 272, who executed an assignment in the same or substantially similar form to the document attached hereto as Exhibit B.
1527. On or about February 12, 2014, Plaintiffs secured Patient 272’s consent to contact California Blue Cross, CareFirst Maryland Blue and/or CareFirst District of Columbia Blue, along with the identifying information necessary for Plaintiffs to interact with the insurer.
1528. On or about March 10, 2015, Plaintiffs began providing mental health and/or substance abuse treatment to Patient 272.
1529. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for these services to California Blue Cross, CareFirst Maryland Blue, or CareFirst District of Columbia Blue on the industry-standard UB-04 form. Plaintiffs indicated that it was requesting that benefits be paid to it as an assignee by inserting the letter Y in the appropriate field (box 53) each time it submitted a claim.
1530. On information and belief: California Blue Cross, CareFirst Maryland Blue, CareFirst District of Columbia Blue, and/or the Mercy Plan thereafter paid some or all of the assigned benefits to Patient 272 instead of Plaintiffs.
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 358 of 360 Page ID #:61978
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PATIENT 274
1531. On information and belief: Patient 274 was a participant in or beneficiary
of Defendant Bimbo Plan during all times relevant to this complaint.
1532. On information and belief: With regard to the relevant welfare benefits
implicated by this lawsuit: the Bimbo Plan either (i) is insured by Illinois Blue and/or
California Blue Cross or (ii) is self-insured and has entered into an agreement with
Illinois Blue and/or California Blue Cross by which the Bimbo Plan receives third party
administrative services.
1533. Plaintiffs obtained an assignment of benefits from Patient 274, who
executed an assignment in the same or substantially similar form to the document
attached hereto as Exhibit B.
1534. On or about November 11, 2014, Plaintiffs secured Patient 274’s consent
to contact Illinois Blue and/or California Blue Cross, along with the identifying
information necessary for Plaintiffs to interact with the insurer.
1535. On or about November 11, 2014, Plaintiffs or their agents contacted the
Provider Hotline of Illinois Blue and/or California Blue Cross and requested details
about Patient 274’s coverage. Plaintiffs or their agents recorded the information
learned from Illinois Blue and/or California Blue Cross on the bottom of Patient 274’s
Insurance Verification Form. Plaintiffs or their agents learned from Illinois Blue and/or
California Blue Cross that Patient 274’s benefits were assignable. Plaintiffs or their
agents recorded this by circling “Yes” next to the line “Assignable” on Patient 274’s
Insurance Verification Form.
1536. On or about November 17, 2014, Plaintiffs began providing mental health
and/or substance abuse treatment to Patient 274.
1537. Shortly thereafter, Plaintiffs submitted claims seeking reimbursement for
these services to California Blue Cross or Illinois Blue on the industry-standard UB-
04 form. Plaintiffs indicated that it was requesting that benefits be paid to it as an
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 359 of 360 Page ID #:61979
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assignee by inserting the letter Y in the appropriate field (box 53) each time it submitted
a claim.
1538. On information and belief: California Blue Cross, Illinois Blue, and/or the
Bimbo Plan thereafter paid some or all of the assigned benefits to Patient 274 instead
of Plaintiffs.
Case 8:15-cv-00736-DOC-DFM Document 1177 Filed 10/16/17 Page 360 of 360 Page ID #:61980