Cigna - Indiana AG (corrected)

David Sirota filed this request with the Office of the Attorney General - Indiana of Indiana.
Submitted March 31, 2016
Status
Completed

Communications

From: David Sirota

Subject: MR#24927-237308 - Indiana Access to Public Records Act Request: Cigna - Indiana AG (corrected)

Fax

To Whom It May Concern:

Pursuant to the Indiana Access to Public Records Act, I hereby request the following records:

- All correspondence to or from employees of the Office of the Attorney General to or from employees of the National Association of Insurance Commissioners referencing the proposed merger between Cigna and Anthem. This includes correspondence to or from email address from the domain name "naic.org."

- All correspondence to or from employees of the Office of the Attorney General to or from employees of the Connecticut Insurance Department, including Connecticut Insurance Commissioner Katharine Wade, referencing the proposed merger between Cigna and Anthem.

- All correspondence to or from employees of the Office of the Attorney General to or from employees of Cigna and/or Anthem referencing the proposed merger between Cigna and Anthem. This includes correspondence to or from email address from the domain name "cigna.com" and "anthem.com"

I hereby request such correspondence for the dates 1/1/15 to the present.

The requested documents will be made available to the general public, and this request is not being made for commercial purposes.

Please search for responsive records regardless of format. I request the information in a machine-processable format, such as a spreadsheet (CSV or XLS) or word processor (TXT, DOC, DOCX) format. It can be provided by email, thumb drive, or CD. If it is unavailable in any other format, an OCRed PDF (i.e. searchable) will do.

If it is your position that some of these records are available but others are not (or a part of the request is too broad), please provide me with the records that are available.

If it is your position that any portion of the requested records is exempt from disclosure, I request that you provide it with an index of those documents as required under Vaughn v. Rosen, 484 F.2d 820 (D.C. Cir. 1973), cert. denied, 415 U.S. 977 (1972). As you are aware, a Vaughn index must describe each document claimed as exempt with sufficient specificity “to permit a reasoned judgment as to whether the material is actually exempt under FOIA.” Founding Church of Scientology v. Bell, 603 F.2d 945, 949 (D.C. Cir. 1979). Moreover, the Vaughn index must “describe each document or portion thereof withheld, and for each withholding it must discuss the consequences of supplying the sought-after information.” King v. U.S. Dep’t of Justice, 830 F.2d 210, 223-24 (D.C. Cir. 1987) (emphasis added). Further, “the withholding agency must supply ‘a relatively detailed justification, specifically identifying the reasons why a particular exemption is relevant and correlating those claims with the particular part of a withheld document
to which they apply.’” Id.at 224 (citing Mead Data Central v. U.S. Dep’t of the Air Force, 566 F.2d 242, 251 (D.C. Cir. 1977)).

In the event some portions of the requested records are properly exempt from disclosure, please disclose any reasonably segregable non-exempt portions of the requested records. See 5 U.S.C. § 552(b). If it is your position that a document contains non-exempt segments, but that those non-exempt segments are so dispersed throughout the document as to make segregation impossible, please state what portion of the document is non-exempt, and how the material is dispersed throughout the document. Mead Data Central, 566 F.2d at 261. Claims of nonsegregability must be made with the same degree of detail as required for claims of exemptions in a Vaughn index. If a request is denied in whole, please state specifically that it is not reasonable to segregate portions of the record for release.

I request a waiver of fees associated with processing this request for records. International Business Times is a news media organization. Disclosure of the requested information to me is in the public interest because it is likely to contribute significantly to public understanding of the operations or activities of the government. The requested documents will be made available to the general public, and this request is not being made for commercial purposes.

In the event that fees cannot be waived, I would be grateful if you would inform me of the total charges in advance of fulfilling my request.

Thank you in advance for your anticipated cooperation in this matter. I look forward to receiving your response to this request within 7 business days, as the statute requires.

Sincerely,

David Sirota
International Business Times
(720) 854-4875

From: Kochar, Aaron

Subject: APRA David Sirota request

Email

Dear Mr. Sirota,

Attached is a fax message sent to our office regarding a public records request you made and which was received by our office on April 11, 2016. Our final response letter, including all of our responsive and disclosable records, was sent to you on June 22, 2016.

If you have any additional questions, please feel free to contact our office.

Sincerely,

Aaron Kochar, JD
Deputy Attorney General - Advisory Section
302 West Washington Street - IGCS, 5th Floor
Office: 317.234.6667
Fax: 317.232.7979

NOTICE: This communication may contain privileged or other confidential information. If you have received it in error, please advise the sender by reply email and immediately delete the message and any attachments without copying or disclosing the contents. Thank you.

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