This timing sequence allowed for the usual 14-day response period contemplated in the Bureau's Rules of Practice. Although these requests were filed with the Superintendent within the technical time requirements required by the Procedural Order, they were sent to the Applicants via regular mail and, accordingly, were not received until Monday, February 7, 2000. As has been our practice, counsel for Anthem sent an email to the parties serving the requests, as well as to the Bureau, detailing when the responses were received and calculating the deadline for response.
Applicants hereby make that request.
In the last four days of the discovery period, the Applicants were served with over 150 discovery requests, many of which contained multiple parts. The Applicants have been and continue to be diligent in their efforts to respond to the extensive discovery requests made by the parties. The Consumer and Provider intervenors could have served their requests via email on February 4 th , but apparently chose not to do so. Compressing the Applicants' already minimal response time under these circumstances would be unfair and certainly not within the spirit of the Superintendent's Procedural Order. The Applicants need this additional time to respond and request only that the Superintendent grant them the usual and ordinary time to respond to the referenced requests.