APPENDIX EXHIBIT ADECLARATION OF SEAN J. HELLEIN IN SUPPORT OF PETITION FOR QUO WARRANTO. 1, SEAN J. HELLEIN, declare as follows: 1, My name is Sean J. Hellein, Iam over 21 years of age and suffer from no mental or physical disabilities. { make this Declaration based on my personal knowledge of the facts set forth herein. 2. Tam a citizen of the State of Florida and have lived here all my life, although | am temporarily on a sojourn out of the State for safety concems and as a result ‘of an employment opportunity. | intend to return to Florida as my place of domicile as safety, work and finances permit. I own my home in Florida, I hold 2 Florida State ID and a Florida Voter ID, and I use an area code (813) Tampa cell phone number. 3. was employed by WellCare Health Plans, Inc. (“WellCare”) in various positions from November 2002 through October 2007, including as a Senior Financial Analyst. Because of my position, I frequently spoke with, attended meetings with and had interactions with the top management at WellCare. 4, Daring all relevant times hereto, I was disgusted with Wellcare’s fraud and had reported it to the FBI and the -U.S. Atiomey’s Office. At such times, ] was cooperatinig. as an insider, confidential informant for the FBI, the Office of the Inspector General of the Department of Health and Human Services and the U.S. Attorney’s Office. In that role, and during all relevant times hereto, | wore audio and video surveillance equipment almost daily to assist in the criminal and civil investigations of WellCare by the Federal Government, all which were triggered by my filing of the original complaintin the False Claims Act case referenced in the Original Quo Warranto Petition filed with this Court. 5. In June 2006, special concems arose at WellCare regarding possible significant obligations to repay Medicaid overpayments relating to past behavioral health encounters. WellCare had traditionally relied on providing false records to conceal these overpayments. However, at a point in time, the regulators at AHCA began asking for more detailed information and WellCare’s overpayment liability was becoming greater ‘each year. 6 This concem was the result of the Florida law requiring that 80% of monies advanced for behavioral encounters had to be spent on the patient or treatment for the patient (“80/20 Law”). Around this time, Peter Clay, WellCare’s Vice President of Medical Economics, feared a one-year liability could now exceed $10M. 7. Asa result of these internal discussions, in the summer of 2006, Greg West, another Senior Financial Analyst, prepared a spreadsheet report showing actual expenses versus the fiaudulently reported expenses. The conclusion of this report was that, based on the Florida 80/20 Law requirement and considering WellCare’s actual expenses, WellCare was currently liable to the State of Floride for approximately $23M in Medicaid overpayments. 8. The extent of this potential liability created a panic among top management who feared that discovery or disclosure of the $23M in liability would trigger increased serutiny and discovery by the Government of WellCare’s improper and fraudulent financial practices, as well as a severe drop in the value of WellCare’s publicly traded stock. Management’s primary concer was always creating and maintaining the