J CR Subject: FW: Pending Discovery Requests - narrowing request to 4 RFPs - further request to meet Date: Wed, 27 Jul 2016 20:37:44 +0000 Importance: Normal Embedded: RE:_Pending_Discovery_Requests_-_narrowed,_amended_discovery_request In light of the government's withdrawal of the Wellcare argument, petitioners withdrew the December 2 and December 29, 2015 requests for admissions. As to the two requests for production served on those same dates, petitioners withdrew the RFP's, and consolidated them into a single amended supplemental request for production, which seeks four (4) categories of documents. This is the email where Cassell withdrew the requests for admissions. I am attaching the previous email, which contains the amended supplemental request. From: Paul Cassell (mailto:[email protected]] Sent: Friday, January 29, 20161:11 PM Subject: RE: Pending Discovery Requests - narrowing request to 4 RFPs - further request to meet Thank you for working on these discovery issues with us. As we have always tried to indicate, we are happy to work with the Government to avoid any undue burden. We appreciate your stipulations, and understand your caveat that you are not waiving your right to argue the points you identify. In view of those stipulations, we withdraw our December 2 and December 29 Requests for Admissions. With regard to the Requests for Production, as we indicated earlier, there are four particular requests that are still quite important to us for a variety of reasons. To avoid any confusion, we have sent you by earlier email an "amended" Request for Production that contains only those four requests for production -- in identical form to what was sent to you earlier. However, this amended RFP elucidates in the "background" section of the RFP the multiple purposes for which this previously-sought information is still being sought. Accordingly, this Amended RFP significantly narrows our requests to the Government. We hope that you w