Nancy Moran

             BEFORE THE OFFICE OF ADMINISTRATIVE HEARINGS

                                   *
                                   
      Nancy Moran                  *        Case No. MIA-2004-01-012
                                   
           Consumer                *
                                   
           v.                      *
                                   
      CareFirst                    
           Blue Cross Blue Shield  *

           Carrier                 *

*    *    *    *    *    *    *    *    *    *    *    *    *    *    *    *    *

        RESPONSE TO REQUEST FOR DISCOVERY AND MOTION TO DISMISS

      Comes now Nancy Moran, proceeding pro se, who states and affirms:

      1)   She is not now the Licensee of Claimant nor hasn't been for several months.

      2)   She is not an attorney and to conduct litigation with Carrier is dilatory and
harassing.

      3)   She cannot afford an attorney and such a requirement proscribes affordability and
accessibility to Carrier's service contrary to its legislative mandate.

      4)   She has no transportation to Gilroy Road in Hunt Valley.

      5)   Communication by Federal Express is intended to be intimidating in addition to
being expensive.

      6)   The contentions and arguments are moot given the results of the 2004 Maryland
General Assembly (Table of Exhibits enclosed).


Respectfully submitted,



Nancy Moran

nm
enclosures
                           TABLE OF EXHIBITS


A.    Request for Hearing dated December 18, 2003

B.    Presentation to each and every member of Senate Finance Committee dated April 1, 2004
      (6 sheets)

C.    House Bill 341, "Regulation and Acquisition of Nonprofit Health Entities", (14 pages). 
      Scrutinize page 9.

D.    House Bill 845 (Chapter 94), "Maryland Health Care Commission and Maryland
      Insurance Administration - Affordability of Health Insurance in Maryland - Study and
      Recommendations (5 sheets). Scrutinize page 4, lines 28 and 29.

      House Bill 1361, "Hearings on Appeals and Grievances", omitted.



                        CERTIFICATE OF SERVICE

      This motion is not going through the mails and is not going Federal Express.  Instead, it
is going by fax to:

      Terri O'Shea / Mark McCoy                            410-998-5133
      (Paralegal and Attorney for the Carrier)

      Sharon E. Moore                                      410-468-2260
      Maryland Insurance Administration

      Clerk, Office of Administrative Hearings             410-229-4111

      Maryland Health Care Commission                      410-358-1236