Escolar Documentos
Profissional Documentos
Cultura Documentos
Box 10841
Eugene, Oregon 97440
p/f: 541.257.8878
info@t1df.org
www.t1df.org
August 1, 2019
A. Requestor:
Type 1 Diabetes Defense Foundation, ℅ Charles Fournier
3059 Hendricks Hill Drive, Eugene OR 97403
(206) 643-1479
charles.fournier@t1df.org
B. Records being sought:
This PRR concerns insulin products including but not limited to Lantus, Levemir, Novolog,
Humalog, Apidra.
The agency is the Office of Minnesota Attorney General (the “Agency”).
The relevant time frame is from January 1, 2016, to August 1, 2019
• Logs of all meetings, including but not limited to in-person meetings, conferences,
teleconferences, presentations.
• Logs of all communications, including but not limited to phone communications (call
logs), written communications, electronic communications (included email logs) with
third parties. Government telephone call, meeting and email logs are covered by the
• Logs of all documents created by the Agency filed in any court, sent to, exchanged with
or received from any third party including all records, letters, submittals, applications,
exhibits, filings, either on paper or electronically.
• All meeting minutes, including but not limited to minutes, notes and summaries of in-
person meetings, conferences, teleconferences, presentations.
• All communications, including but not limited to the notes and transcripts of phone
communications, written communications, electronic communications (included
emails).
• All documents created by the Agency, sent to, exchanged with or received from any
third party including all records, letters, submittals, applications, exhibits, filings, either
on paper or electronically.
The above mentioned private or public third parties include, but are not limited to organizations and
individuals affiliated with:
• JDRF and the American Diabetes Association, and their local affiliates;
• The Minnesota Commerce Department and its Insurance Division, including but not limited to
Grace Arnold (Deputy Insurance Commissioner), Steve Kelley (Minnesota Commerce
Commissioner), Fred Andersen (former Acting Deputy Commissioner of Insurance and Chief
Life Actuary) and their predecessor;
• The Minnesota Department of Corrections and its contractors, including Centurion of Minnesota
LLC and Centene Corporation;
• The Minnesota Department of Human Services (DHS), Minnesota Health Care Programs
(MHCP) such as Medicaid (Medical Assistance and MN Care), Insurance Affordability Programs
(IAP), 340B Drug Pricing Program — programs managed by Magellan Health Services. Change
Healthcare Minnesota, MHCP contracted vendor for the Specialty Drug List (incl. insulin) and
state maximum allowable cost (SMAC);
• Minnesota Multistate Contracting Alliance for Pharmacy (MMCAP), the Materials Management
Division of the State of Minnesota's Department of Administration for government healthcare
facilities (MMCAP administrator), the National Medicaid Pooling Initiative (supplemental rebate
• Private pharmacy benefit managers and insurers, including Humana, Blue Cross and Blue Shield
of Minnesota, Express Scripts, Eagan-based Prime Therapeutics, Minnetonka-based
UnitedHealthcare,
• Keith Ellison (in his individual capacity and a candidate for Attorney General), Keith Ellison for
Attorney General committee, as well as any affiliated or non-affiliated committee;
• U.S. District Court of New Jersey, including Judge Martinotti and Administrative Judge
Goodman.
When a privilege is asserted, the document or communication must still be included in the requested
log. The specific statutory or legal basis of the privilege must be provided in writing and the record
must be specifically described in order to allow us to appeal the assertion of privilege, if necessary.
When access to a record is denied, the specific statutory or legal basis must be provided in writing,
including when any data is redacted.
If the Agency maintains the requested data "in a computer storage medium” and in a standard format
(e.g. pdf), then the copy of the data must be provided in that medium, if the government entity "can
reasonably make the copy or have a copy made." Minn. Stat. § 13.03, subd. 3(e).
C. A statement concerning willingness to pay fees:
The purpose of this request is primarily for educational and research purpose. Litigation on
insulin pricing has been ongoing for many years with limited success. The insulin pricing class action
filed in NJ against insulin manufacturers has now been partially dismissed. In the meantime, people
with type 1 diabetes are still being overcharged for their insulin.
Considering the critical importance of the underlying issues, T1DF’s charitable purpose—but
also its extremely limited resources (less than $20,000 in 2018)—we therefore request that all fees
and costs associated with this request be waived in their entirety.
Thank you for your consideration of these matters.
Respectfully submitted,