PH2\742938.1 

IN THE UNITED STATES DISTRICT COURT FOR 

THE EASTERN DISTRICT OF PENNSYLVANIA 

THE CHESTER COUNTY HOSPITAL : CIVIL ACTION 

 : NO. 02-2746 

 v. : 

 : 

INDEPENDENCE BLUE CROSS, : 

QCC INSURANCE COMPANY, : 

KEYSTONE HEALTH PLAN EAST, and : 

KEYSTONE MERCY HEALTH PLAN :

PLAINTIFF'S MOTION FOR LEAVE TO FILE UNDER SEAL ITS 

JOINT RESPONSE TO NON-PARTY AETNA INC.’S APPEAL OF 

THE COURT’S JULY 7, 2003 AND JULY 16, 2003 ORDERS 

MODIFYING THE JANUARY 24, 2003 PROTECTIVE ORDER AND TO 

MULTIPLAN’S STATEMENT OF OBJECTIONS AND/OR NOTICE OF APPEAL 

FROM THE MAGISTRATE JUDGE’S ORDER DENYING MULTIPLAN’S 

MOTION TO INTERVENE AND/OR MOTION FOR PROTECTIVE ORDER 

(DOC. NO. 54) AND MOTION TO QUASH, MOTION TO INTERVENE 

AND/OR MOTION FOR PROTECTIVE ORDER (DOC. NO. 83) 

 Plaintiff The Chester County Hospital, by its attorneys, respectfully files this Motion for 

Leave to file under seal Its Joint Response to Non-Party Aetna Inc.'s Appeal of The Court's July 7, 

2003 and July 16, 2003 Orders Modifying the January 24, 2003 Protective Order and to Multiplan's 

Statement of Objections and/or Notice of Appeal From the Magistrate Judge's Order Denying 

Multiplan's Motion to Intervene and/or Motion for Protective Order (Doc. No. 54) and Motion to 

Quash, Motion to Intervene and/or Motion for Protective Order (Doc. No. 83). Plaintiff's Motion 

contains information designated confidential under the Court's January 24, 2003 Protective Order. 

Therefore, pursuant to the terms of the January 24, 2003 Protective Order, Plaintiff respectfully 

Moves to file under seal Its Joint Response to Non-Party Aetna Inc.'s Appeal of The Court's July 7, 

2003 and July 16, 2003 Orders Modifying the January 24, 2003 Protective Order and to Multiplan's 

Statement of Objections and/or Notice of Appeal From the Magistrate Judge's Order Denying 

Case 2:02-cv-02746-JP Document 100 Filed 07/29/2003 Page 1 of 3
PH2\742938.1 2 

Multiplan's Motion to Intervene and/or Motion for Protective Order (Doc. No. 54) and Motion to 

Quash, Motion to Intervene and/or Motion for Protective Order (Doc. No. 83) . 

Respectfully Submitted, 

_____________________ 

Lewis R. Olshin 

Wayne A. Mack 

Seth A. Goldberg 

Duane Morris LLP 

One Liberty Place 

Philadelphia, Pennsylvania 19103-7396 

 

Richard A. Feinstein 

Daniel A. Kotchen 

Boies, Schiller & Flexner LLP 

5301 Wisconsin Avenue, N.W., Suite 800 

Washington, D.C. 20015 

Attorneys for 

THE CHESTER COUNTY HOSPITAL 

Case 2:02-cv-02746-JP Document 100 Filed 07/29/2003 Page 2 of 3
PH2\742938.1 

IN THE UNITED STATES DISTRICT COURT FOR 

THE EASTERN DISTRICT OF PENNSYLVANIA 

THE CHESTER COUNTY HOSPITAL : CIVIL ACTION 

 : NO. 02-2746 

 v. : 

 : 

INDEPENDENCE BLUE CROSS, : 

QCC INSURANCE COMPANY, : 

KEYSTONE HEALTH PLAN EAST, and : 

KEYSTONE MERCY HEALTH PLAN :

ORDER

AND NOW, on this _____ day of ___________________, 2003, upon consideration of 

Plaintiff The Chester County Hospital’s Motion for Leave to File Under Seal Its Joint Response 

to Non-Party Aetna Inc.'s Appeal of The Court's July 7, 2003 and July 16, 2003 Orders Modifying 

the January 24, 2003 Protective Order and to Multiplan's Statement of Objections and/or Notice of 

Appeal From the Magistrate Judge's Order Denying Multiplan's Motion to Intervene and/or Motion 

for Protective Order (Doc. No. 54) and Motion to Quash, Motion to Intervene and/or Motion for 

Protective Order (Doc. No. 83), it is hereby ORDERED that the Motion is GRANTED. 

BY THE COURT: 

___________________________________ 

JOHN R. PADOVA 

UNITED STATES DISTRICT JUDGE 

Case 2:02-cv-02746-JP Document 100 Filed 07/29/2003 Page 3 of 3