To avoid repetition, Anthem incorporates these memoranda by reference. The majority of the documents responsive to question number 22 reflect Anthem's confidential business plans and financial projections. The Superintendent has already determined that Anthem's financial projections are confidential and the projections and business plans contained in the referenced documents are confidential for the same reasons. Anthem previously submitted a memorandum of law setting forth the law and reasoning in support of highly confidential treatment for Anthem's internal valuation information. See Anthem's Memorandum in Support of Confidential Treatment for Response to AG's First Request, dated January 24, 2000.
Anthem incorporates that memorandum by reference.
Considering the minimal, if any, relevance of the documents and the harm to Anthem if the documents were disclosed, the level of protection Anthem requests is warranted. Jeffrey M. White, Esq. Catherine R. Connors, Esq. Robert S. Frank, Esq. Judith Chamberlain, Esq.