The fear and panic that spread throughout UnitedHealthcare and the entire health insurance business after company executive Brian Thompson was gunned down outside a Manhattan hotel last December was exactly what the gunman wanted, state prosecutors said in an 82-page brief filed Wednesday.

The government made its argument in support of the terrorism charges against the suspect, Luigi Mangione.

Mangione, a University of Pennsylvania graduate, was indicted on Dec. 17 on 11 counts connected to the killing, with the top charge of murder as an act of terrorism. He pleaded not guilty.

His defense lawyer, Karen Agnifilo Friedman, requested that the top charge be dropped because, she said, it should not be applied to the death of a single person.

She further claimed that it was law enforcement, not her client, who has been spreading the fear surrounding the case by publishing parts of a notebook, referred to as a manifesto, found on Mangione when police arrested him on Dec. 7 in an Altoona, Pennsylvania, McDonald’s.

In the motion filed on Wednesday, lead prosecutor Joel Seidmann outlined the repercussions felt at UnitedHealthcare and the health insurance industry in general after the shooting.

"You are gonna hang," a caller told a UnitedHealth call center specialist in a recording played to the grand jury that indicted Mangione. "You know what that means. That means that the killing of Brian Thompson was just a start. There are a lot more that are gonna be taken out. The only question is whether you're gonna be their collateral damage when it’s done or not."

In response, a UnitedHealthcare executive dyed her hair and moved to temporary housing, according to the filing, and the insurance company hired personal security for 40 of its executives. Employees in the Penn Station office received death threats and plainclothes police were hired to protect the company’s Minnesota headquarters, the Manhattan District Attorney said. Workers were told not to wear clothing with the company’s insignia on it for fear of further attacks.

The CEO of Emblem Health, a Manhattan-based health insurer, also received threats, prosecutors said.

Days after Mangione was arrested, posters appeared at the company’s headquarters with the executive’s photo and the words "Health Care CEO’s should not feel safe. Deny, Defend, Depose."

The last three words refer to the words written on the shell casings and a live bullet found at the scene of Thompson’s murder. Prosecutors, for the first time, revealed in the filing that one bullet had only the letters "den," which they assume meant deny.

Authorities said that they believe Mangione was referencing the book "Delay, Deny, Defend" that professes to detail how health insurance companies respond to claims.

The motion includes a more complete version of Mangione’s manifesto in which he says he hopes for the headline "INSURANCE CEO KILLED AT ANNUAL INVESTORS CONFERENCE."

"All of these writings convey one clear message: that the murder of Brian Thompson was intended to bring about revolutionary change to the health care industry," Seidmann wrote in his brief. "Defendant's targeting of UHC had nothing to do with anything that the company had done to him personally. In fact, he had no business relationship with the company. Brian Thompson and UHC were simply symbols of the health care industry and what defendant considered a deadly greed-fueled cartel."

Seidmann argued in his brief that the number of people killed or injured is not what makes it terrorism, it's the population affected by the act.

"Aside from defendant's obvious intent to intimidate the employees of UHC and other health insurance companies, it is abundantly clear that Brian Thompson's execution was designed to intimidate investors and analysts from advising their clients to invest in health insurance companies," the prosecutor wrote.

The bullet that killed Thompson struck him in the left side of the back, pierced his liver before going through his heart and exiting the front left side of his chest, prosecutors said. His expensive Rolex watch was not taken, they point out, eliminating robbery as a motive.

Mangione, who could get life in prison without parole if convicted on the Manhattan state charges, also faces federal charges in Manhattan federal court. He’s been charged with murder, gun possession and two counts of stalking.

Attorney General Pamela Bondi said in a news release that her office will seek the death penalty if he’s convicted.

Mangione is currently being held in the Metropolitan Detention Center in Brooklyn.