Case 1:09-cv-11156-JLT

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UNITED STATES DISTRICT COURT DISTRICT OF MASSACHUSETTS COMMONWEALTH OF MASSACHUSETTS, Plaintiff, v. UNITED STATES DEPARTMENT OF HEALTH AND HUMAN SERVICES; KATHLEEN SEBELIUS, in her official capacity as the Secretary of the United States Department of Health and Human Services; UNITED STATES DEPARTMENT OF VETERANS AFFAIRS; ERIC K. SHINSEKI, in his official capacity as the Secretary of the United States Department of Veterans Affairs; and the UNITED STATES OF AMERICA, Defendants. AFFIDAVIT OF DOLORES MITCHELL Dolores Mitchell, being duly sworn, hereby deposes and says as follows: 1. I am the Executive Director of the Group Insurance Commission (GIC). I have

Civil Action No. 1:09-cv-11156-JLT

held that position since 1987. 2. The GIC is an agency of the Commonwealth of Massachusetts that provides

health insurance (among other benefits) for employees of the Commonwealth, several state authorities (such as the Massachusetts Bay Transportation Authority), and certain municipalities as well as members of several retirement boards. See generally MASS. GEN. LAWS ch. 32A 123; MASS. GEN. LAWS ch. 32B, 1-19. For the sake of clarity, all individuals receiving coverage from the GIC by virtue of their current or past employment shall be referred to as enrollees. 3. Through the GIC, enrollees can choose from a variety of health care plans that

range substantially in benefits and premiums. Enrollees can choose to cover only themselves or

Case 1:09-cv-11156-JLT

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Case 1:09-cv-11156-JLT

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Case 1:09-cv-11156-JLT

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CERTIFICATE OF SERVICE I, Jonathan B. Miller, hereby certify that this document filed through the ECF system shall be sent electronically to the registered participants as identified on the Notice of Electronic Filing (NEF) and paper copies shall be sent by first-class mail postage prepaid to: Mark A. Thomas 482 Beacon Street Boston, MA 02115 Proposed Intervenor

/s/ Jonathan B. Miller______ Jonathan B. Miller Assistant Attorney General