UnitedHealth Group (UNH)

18.1 Stay Of Proceedings And Bar Order

Until the Preliminary Approval Order has been entered, including the stay of proceedings as to the Released Parties in the form contained therein, Settling Plaintiffs and Settlement Class Counsel covenant and agree that neither Settling Plaintiffs nor Settlement Class Counsel shall pursue litigation proceedings against the Released Persons; Defendants shall not pursue litigation proceedings against the Releasors; and the Parties and their respective counsel shall not in any way subsequently argue that the Released Persons or Releasors have failed to comply with their litigation obligations in any respect by reason of the Released Persons’ and Releasors’ suspension of litigation efforts following the execution of this Settlement Agreement.

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Upon entry of the Preliminary Approval Order, all proceedings in the Actions, other than proceedings necessary to carry out the terms and conditions of this Settlement Agreement, shall be stayed and suspended until further order of the Court. The Preliminary Approval Order also shall bar and enjoin all Settlement Class Members who have not Opted-Out of the Settlement pursuant to Section 14.1 from commencing, prosecuting, or assigning the right to do so, of any action asserting any Released Claims against any Released Person. The Final Order and Judgment shall include a bar of any and all assertion of claims or demands by any Non-Party Carrier against any Released Person for liability, contribution, indemnity, or other similar claims concerning, relating to, or arising out of any Released Claims (the “Bar Order”).