The plaintiff requests all documents and records of Lathrop & Gage, L.C. and its attorneys along with identification and addresses of persons with knowledge related to creating entities, plans and contracting for Governor Matt Blunt’s healthcare initiative that came to be known as Insure Missouri including all communications and advisory opinions related to the scheme and to withdrawing from or cutting Medicaid and State of Missouri funds to low income or socially disadvantaged Missouri citizens provided to Missouri officials including , Ed Martin, Patricia E. Vincent, Henry T. Herschel and State Representative Jeff Grisamore; all communications with the office of the US Department of Health and Human Services; HHS Secretary Mike Leavitt; Missouri Senator Kit Bond, former Missouri Senator Jim Talent, Kansas Governor Kathleen Sebelius, former Kansas Attorneys General Phil Kline and Jim Morrison, the defendants and the
nondefendant Cerner and its CEO Neal Patterson; and Irvine O. Hockaday.

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