If you do not exclude yourself from the Settlement, you will not be able to sue the Defendants about the issues in this case, and you will be bound by all decisions made by the Court in this case, the Settlement, and its included Release. This is true regardless of whether you submit a Claim Form. You can read the Settlement Agreement in Important Case Documents. However, you may exclude yourself from the Settlement (see Question 14 below). If you exclude yourself from the Settlement, you will not be bound by any of the Released Claims.
“Released Claims” mean the Claims and all manner of demands, actions, suits, causes of action, whether class, individual, or otherwise in nature, damages whenever incurred, liabilities of any nature whatsoever, including, without limitation, costs, penalties, and attorneys’ fees, known or unknown, suspected or unsuspected, asserted or unasserted, in law or equity, that any Settlement Class Members, or any one of them, whether directly, representatively, derivatively, or in any other capacity, ever had, now have, or hereafter can, shall, or may have, related to or arising from conduct alleged in the Complaint or which could have been asserted in the Litigation against the Released Defendants, or any one of them, prior to and through the Effective Date, on account of, arising out of, resulting from, or related to No-Bill Agreements including, without limitation, Claims arising under federal and state consumer protection, consumer fraud, unfair competition, unfair practices, or deceptive trade practice law, including, without limitation, Minnesota common law; the Minnesota Consumer Fraud Act, Minn. Stat. §§ 325F.68–.70; and the Minnesota Uniform Deceptive Trade Practices Act, Minn. Stat. §§ 325D.43–.48.
Expressly excluded from Released Claims are any claims for payment of insurance benefits that do not involve insurance claims for medical expenses by healthcare providers subject to No-Bill Agreements.
The Settlement Agreement describes the Release, Released Claims, Released Defendants, and Releasing Plaintiffs in necessary legal terminology, so please read these sections carefully. The Settlement Agreement is available at Important Case Documents or in the public court records on file in this lawsuit.
The Released Claims do not include any claims arising from or relating to any conduct by Defendants after the date the Agreement is executed. The Released Claims shall also not include the right of Plaintiff, any Class Member, or any Releasing Party to enforce the terms of the Settlement Agreement.