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New Hampshire Local Government Center

This page contains material related to the Secretary of State regulatory hearing process and Legislative activity related to RSA 5-B, concerning public risk pools.

Legislative Secretary of State

Updates

Dental - August 2013 Revised Distribution List, Posted on 2/7/13
January Medical - August 2013 Revised Distribution List, Posted on 2/7/13
July Medical - August 2013 Revised Distribution List, Posted on 2/7/13
January Medical - December 2012 Distribution List, 12/19/12
PLT - August 2013 Distribution List, 12/19/12
Letter to NH Supreme Court from LGC RE: Mediation, 11/29/12
Media Alert 11/20/12: Local Government Center Complies with Hearing Officer's Order in Bureau of Securities Regulation Process
Press Release 11/14/12: Local Government Center Statement on Acceptance of Appeal
by NH Supreme Court
Order Motion for Stay Denied, 11/13/12
Reply to the BSR's Objection to Motion for Stay, 11/1/12
Press Release 10/15/12: Local Government Center Files Petition for Appeal with NH Supreme Court in Administrative Hearing Process
LGC Appeal by Petition, 10/15/12
LGC Motion for Stay Pending Appeal, 10/15/12
Media Statement 9/25/12: LGC Statement on Denial of Motion for Reconsideration
Hearing Officer's Order Denying Reconsideration, 9/24/12
Hearing Officer's Order Denying Stay, 9/24/12
Hearing Officer's Final Order Corrected Page, 9/24/12
Press Release 9/14/12: Local Government Center Files Motion for Reconsideration
Press Release 8/23/12: LGC Board Votes Unanimously to File a Motion for Reconsideration in the Administrative Hearing Process
Press Release 8/16/12: Local Government Center Responds to Decision in Administrative Hearing Process: 3 out of 5 Counts Dismissed
Hearing Officer's Final Order, 8/16/12
Press Release 6/7/12: Local Government Center and Related Respondents Release Rebuttal Briefs
Press Release 6/4/12: Local Government Center and Related Respondents Release Post-Hearing Briefs
Press Release 5/30/12: Local Government Center Announcement of Motion for Withdrawal of Presiding Officer in BSR Hearing Process
Press Release 5/11/12: Local Government Center and Bureau of Securities Regulation
Hearing Process Ends
Press Release 4/30/12: First Day of LGC and Bureau of Securities Regulation Hearing Process Ends

Follow our @NHLGCNewsroom Twitter feed for periodic updates.

Legislative

Secretary of State

Additional documents and audio recordings pertaining to the Secretary of State Administrative Hearings are available at the Secretary of State's website.

April 2013

Motion for Stay of September 1, 2013 Deadlines, 4/11/13

March 2013

March 22, 2013 Filings Re: Remand
LGC Memo of Necessity of Remand, 3/22/13
BSR Memo of Whether Remand is Necessary, 3/22/13
Towns Memo of Whether Remand is Necessary, 3/22/13

November

Press Release 11/14/12: Local Government Center Statement on Acceptance of Appeal
by NH Supreme Court
Order Motion for Stay Denied, 11/13/12
Reply to the BSR's Objection to Motion for Stay, 11/1/12
October
Press Release 10/15/12: Local Government Center Files Petition for Appeal with NH Supreme Court in Administrative Hearing Process
LGC Appeal by Petition, 10/15/12
LGC Motion for Stay Pending Appeal, 10/15/12
September
Media Statement 9/25/12: LGC Statement on Denial of Motion for Reconsideration
Hearing Officer's Order Denying Reconsideration, 9/24/12
Hearing Officer's Order Denying Stay, 9/24/12
Hearing Officer's Final Order Corrected Page, 9/24/12
Motion for Reconsideration, 9/14/12
Motion to Stay the Order, 9/14/12
August
Hearing Officer's Final Order, 8/16/12
June
Respondents' Response to the Bureau's Trial Memorandum, 6/7/12
Comments on the BSR's Proposed Findings of Fact and Rulings of Law, 6/7/12
Bureau of Securities Regulation's Combined Response to Respondents' Post-Hearing Memoranda, 6/7/12
Local Government Center, Post-Hearing Brief, 6/4/12
Respondent Maura Carroll, Post-Hearing Brief, 6/4/12
Respondent Curro, Post-Hearing Memorandum, 6/4/12
Bureau of Securities Regulation Trial Memorandum, 6/4/12
May
Respondents' Memorandum in Support of Oral Motion for Withdrawal of Presiding Officer, 5/30/12
April
Media Statement on School Care Agreement 4/26/2012
Media Statement on Hearing Process 4/6/2012
March

LGC Motions to Dismiss Filed March 12, 2012:

LGC Motion to Dismiss Count I, 3/12/12
LGC Motion to Dismiss Count II, 3/12/12
LGC Motion to Dismiss Counts I and II, 3/12/12
LGC Motion to Dismiss Counts III, IV and V, 3/12/12

Additional Motions to Dismiss from Individuals:

Curro Motion to Dismiss Count VI - Securities, 3/12/12
Andrews Motion to Dismiss Count VI of Amended Petition - Civil Conspiracy, 3/12/12
Carroll Motion for Summary Judgement, 3/12/12
Curro Motion to Dismiss Count IV of BSR's Amended Staff Petition, 3/12/12
Andrews Motion to Dismiss from Counts I and II, Failure to State Cause of Action, 3/12/12
Andrews Second Motion to Dismiss Counts I and II of Amended Petition, 3/12/12
Andrews Motion to Dismiss Counts III, IV and V of Amended Petition - Securities Claims, 3/12/12
Carroll Motion to Dismiss All Counts of the Amended Petition, 3/12/12

February

Press Release: Local Government Center Responds to Latest False Claims from the Bureau of Securities Regulation, 2/17/12
LGC Answer to BSR Amended Petition, January 6, 2012
Bureau of Securities Regulation Amended Petition of February 17, 2012, 2/17/12
Appearance of Kimberly Myers, Esq., 2/10/2012
BSR Objection to Andrews' Motion to Dismiss Count 2, 2/8/12
Appearance - Christopher G. Aslin for the BSR, 2/8/12
Order Granting Deposition of Witness with Limitations and Issuance of Subpeona Duces Tecum, 2/7/12
Attachments: Subpoena with Appendix A
Memo in Support of BSR Motion to Clarify, 2/6/2012
LGC Objection to BSR Motion for Reconsideration of Order to Compel Production, 2/3/12
Respondent John Andrews Response to BSR's Motion Requesting Hearing Officer to Find Waiver of Attorney Client Privilege, 2/3/12
LGC Objection to BSR Requesting Hearing Officer to Waive Attorney Client Privilege, 2/2/12
Respondent John Andrews Motion to Dismiss Count 2, 2/1/12

January

LGC Joinder in Respondent Andrews Response to PPFNH's Initial Response to LGC Motion for Subpoena, 1/26/12
Atty. William Saturley Notice of Withdrawal, 1/26/12
Atty. Brian Quirk Notice of Withdrawal, 1/26/12
Respondent John Andrews Response to PPFNHs Initial Response to LGC Motion for Subpoena, 1/26/12
Order Motion to Preclude Testimony, 1/25/12
Respondent John Andrews' Response to BSR's Objection to Motion to Preclude Legal Conclusion Testimony, 1/25/12
Motion to Reconsider Order on Motions to Compel Production, 1/24/12
Motion Requesting Hearing Officer to Find Waiver of The Attorney Client Privilege, 1/24/12
ORDER Notice of Hearing, 1/20/12
ORDER Pro Hac Vice, 1/20/12
Objection to Respondent Andrews Motion to Preclude Legal Conclusion Testimony, 1/20/12
Production Order, 1/19/12
Motion for Admission Pro Hac Vice for Benjamin Siracusa Hillman, Esq., 1/17/12
BSR Vaughn Index for Document Production, 1/17/12
LGC Assented Motion to Reschedule Hearing, 1/13/12
Appearance of Steven Gordon, Esq. for Maura Carroll, 1/13/12
Press Release: Local Government Center Files Response to Secretary of State Bureau of Securities Regulation Petition, 1/12/12
PFFNH Initial Response to LGC Motion for Subpoena & Motion to Cancel 1-17-2012
Hearing, 1/12/12
Order Revised Notice of Hearing Related to Deposition Request, 1/12/12
Order BSR Nonsuit as to Moltenbrey, Berry and MacDonald, 1/12/12
Order Notice of Hearing, 1/12/12
LGC Motion for Issuance of Subpoena, 1/10/12
LGC Response to Motion to Quash Subpeona & Notice of Withdrawal, 1/10/12
BSR Motion in Support of Motion to Quash Subpoena Firefighters, 1/10/12
Respondent John Andrews Motion to Preclude Legal Conclusion Testimony, 1/10/12
LGC Response to BSR Motion for Clarification, 1/9/12
LGC Answer to Amended Petition, 1/6/12
Notice of Hearing on Motion to Quash Subpoena, 1/6/12
Respondent John Andrews Answer to BSRs Staff Petition, 1/6/12
BSR Motion for Voluntary Nonsuit as to MacDonald and Moltonbrey, 1/6/12
Answer of Respondents filed by Atty. Mark Howard, 1/6/12
BSR Motion for Voluntary NonSuit as to Robert Berry Only, 1/6/12
Appearance of Andru Volinsky, Esq. for BSR, 1/6/12
Motion to Quash Subpoena Filed by Glenn Milner, Esq., 1/3/12
Order Granting Assented to Motion for Modification of Order Granting BSR Request for
On-Site Examination, 1/3/12
Order Expanding Requirements for Protective and Confidential Treatment of Information, 1/3/12

2011

December

Revised Scheduling Order, 12/30/11
Order Cancellation of Informal Conference, 12/30/11
BSR Motion for Clarification, 12/29/11
LGC's Objection to the BSR's Motion to Extend Time to Conduct Onsite Examination, 12/27/11
Notice of Limited Availability of Counsel, 12/27/11
Counsel for Respondents Beecher, Et Al. Notice of Potential Scheduling Conflict re Final Hearing, 12/27/11
Respondents Beecher, Et Al. Joinder in Respondent Andrews' Response Motion to Extend On-Site Examination, 12/27/11
Respondent John Andrews Response to BSR's Motion to Extend Time to Conduct On-Site Examination, 12/24/11
BSR Objection to John Andrews Motion to Dismiss, 12/23/11
LGC Notice of Potential Scheduling Conflict, 12/23/11
Order Scheduling Hearing on BSR Motion to Extend Time, 12/23/11
BSR Motion to Extend Time to Conduct On-Site Examination, 12/23/11
Order Scheduling Modification, 12/23/11
Protective Order Pursuant to HIPPA, 12/23/11
Respondent John Andrews Assented-To Motion for Modification of Scheduling Order, 12/22/11
LGC Proposed Order on Motion for Protect Order, 12/21/11
LGC Limited Assent to BSR Motion, 12/21/11
BSR Proposed Order on BSR Motion for Protective Order and Confidential Treatment, 12/21/11
Respondent John Andrews Response to BSR Motion for Protective Order and Confidential Treatment, 12/20/11
Respondent John Andrews Assented-to Motion for Modification of Order on BSR Request for On-Site Exam, 12/20/11
Proposed Order on BSR Motion for Protective Order and Confidential Treatment, 12/19/11
BSR Motion for Protective Order and Confidential Treatment, 12/19/11
Scheduling Order, 12/14/11
Order on BSR Request for On-Site Examination, 12/14/11
BSR Response to LGC Motion to Compel, 12/5/11
LGC Supplemental Objection, 12/5/11
Respondent John Andrews Motion to Dismiss Him from Counts 1, 2 and 4, and Sections A, C and D of Count 3 for Failure to State a Cause of Action, 12/3/11

November

Attorney David Frydman Notice of Appearance, 11/30/11
BSR Supplemental Memorandum, 11/29/11
LGC Response to BSR Motion to Compel, Preserve and Enforce Subpoena, 11/21/11
Roy W. Tilsley, Jr. Appearance for BSR, 11/21/11
Respondent John Andrews Motion for More Definite Statement or for Clarification, 11/21/11
LGC Motion to Compel Document Production, 11/18/11
BSR Motion to Compel, Preserve and Enforce Subpoena, 11/18/11
Respondent John Andrews Motion to Compel Production of BSR Interviews, Statements and Summaries, 11/18/11
Eric Forcier Appearance for BSR, 11/14/11
Order Regarding Document Exchange and Notice of Hearing, 11/14/11
BSR Motion to Amend the Proposed Structuring Conference Order, 11/9/11
Jeffrey D. Spill Appearance for BSR, 11/9/11
Order on Motion to Determine Status of Counsel, 11/4/11
Order on Intervention, 11/3/11
BSR, Letter Regarding Documents Produced and Withheld, 11/4/11
Order on Motion to Determine Status of Counsel, 11/4/11
Order on Motion to Intervene, 11/3/11

October

LGC, Objection to Motion to Enlarge Time, 10/12/11
Order on Bureau of Securities Regulation Request Extension to File, 10/12/11
BSR, Motion to Enlarge Time for Submission of Motion Regarding Representation of Respondents, 10/11/11
BSR, Motion to Determine Status of Counsel, 10/11/11
Press Release: Local Government Center Responds to Media Report, 10/6/11
Press Release: LGC Prepares for Public Hearing Process, 10/3/11
LGC Proposed Structuring Conference Order, 10/3/11
LGC Objection to Motion to Intervene: PFFNH, 10/3/11
LGC Objection to Motion to Intervene: NE Police, 10/3/11
LGC Objection to Amended Motion to Intervene, 10/3/11

August

Press Release: LGC Takes Steps to Address Corporate Structure, 8/31/11
Letter from LGC to New Hampshire Secretary of State, 8/31/11
LGC Membership Update: A Letter to NHMA/LGC Members from Maura Carroll, 8/31/11
Press Release: Local Government Center Calls for Neutral and Experienced Officer for Secretary of State Administrative Hearing, 8/15/11
Letter from LGC General Counsel to New Hampshire Secretary of State, Bureau of Securities Regulation, 8/15/11
LGC Membership Update: A Letter to NHMA/LGC Members from Maura Carroll, 8/12/11
LGC Membership Update: Responses to Specific Issues Identified in the August 2, 2011 Report of the Bureau of Securities Regulation, 8/12/11
LGC Membership Update: A Letter to NHMA/LGC Members from Maura Carroll, 8/2/11
Report on Local Government Center, Bureau of Securities Regulation, 8/2/11
Press Release: Local Government Center Statement in Response to Secretary of State Report, 8/2/11

May

Press Release: Public Risk Pools Reserve Methods Proper: Actuary Report Shows LGC’s Reserve Levels Are Appropriate, 5/31/11
Letter from LGC General Counsel to New Hampshire Secretary of State, Bureau of Securities Regulation, 5/31/11
Milliman Report: Target Capital/Surplus for HealthTrust 5/31/11
Press Release: Local Government Center Calls on Securities Bureau to Correct Misleading Press Release, 5/19/11
Letter from LGC General Counsel to New Hampshire Secretary of State, Bureau of Securities Regulation, 5/19/11
Letter from LGC General Counsel to Bureau of Securities Regulation re: Right-to-Know Request, 5/19/11
New Hampshire Secretary of State, Bureau of Securities Regulation Response to LGC RSA 91-A Request, 5/18/11
LGC Right-to-Know Request to New Hampshire Secretary of State, Bureau of Securities Regulation, 5/16/11
Op-ed by LGC General Counsel David Frydman, 5/18/11
LGC Membership Update: A Letter to NHMA/LGC Members from Maura Carroll, 5/12/11
Press Release: Local Government Center Comments on Securities Bureau News Release, 5/11/11

April

Press Release: Local Government Center Supports Risk Pool Reform Legislation, 4/19/11
HB 424 (proposed amendment to RSA 5-B), 4/19/11
Maura Carroll, Testimony on HB 424, 4/19/11

March

LGC Letter to Secretary of State, 3/17/11

February

LGC Letter to Secretary of State, 2/24/11
Secretary of State Response to LGC, 2/14/11
LGC Letter to Secretary of State, 2/03/11
LGC Letter to Secretary of State, 2/03/11

2010

Press Release: Local Government Center Receives Department of State Securities Bureau Report on Appropriate Reserves for Pooled Risk Programs, 12/30/10
Local Government Center Responses to Secretary of State's Interim Report, 12/23/10
Press Release: Local Government Center Receives Department of State Securities Bureau Report on Appropriate Reserves for Pooled Risk Programs (links to full report), 12/30/10
Process in Place to Resolve Local Government Center Concerns, Op-Ed by Maura Carroll, 11/21/10
LGC Membership Update: A Message from Maura Carroll to LGC Members and Local Officials, 11/16/10
Press Release: Local Government Center Responds to Release of Department of State's Securities Bureau Interim Report, 10/28/10
Media Advisory: Reporter’s Roundtable with LGC Executive Director Maura Carroll, 10/27/10
Press Release: Local Government Center Awaits Department of State’s Securities Bureau Report, 10/27/10
Press Release: Local Government Center Withdraws Lawsuit; New Legislation Clarifies Jurisdiction, 6/28/10

2009

Press Release: Local Government Center Releases Requested Information to
NH Department of State, 12/16/09
LGC Membership Update: A Message from Maura Carroll to LGC Members and Local Officials, 11/17/09
Press Release: Local Government Center Responds to Secretary of State
Subpoena for Information, 10/30/09
Background Information on Secretary of State Records Request,10/30/09
Secretary of State Response to LGC Proposal, 10/30/09
LGC Letter to Secretary of State, 10/27/09
HIPAA Fact Sheet
LGC Membership Update: A Message from Maura Carroll to LGC Members and Local Officials, 10/21/09
Concord Monitor Op-Ed by Maura Carroll, published 10/18/09
LGC Letter to Secretary of State, 8/27/09
Secretary of State Letter to LGC, 8/25/09
LGC Letter to Secretary of State, 8/25/09

2010 Legislative Session:
Proposed Legislation Affecting RSA 5-B Risk Pools

Press Release: New Hampshire Local Government Center’s Chair Issues Statement on Proposed Legislation Affecting Public Risk Pools, 5/28/10
Video: LGC Interim Executive Director Maura Carroll Testifies to House Commerce Committee on Legislation to Regulate Risk Pools (HB 1393) on May 21, 2010, 5/21/10
Press Release: NH Public Risk Pools and Local Officials Address Likely Consequences of Proposed Legislative Amendments, 5/06/10
LGC Membership Update: A Message from Maura Carroll to LGC Members and Local Officials, 5/04/10

Documents pertaining to Professional Fire Fighters of New Hampshire and court-related matters are available on the Legal Matters page.