Common Contracts

EXHIBIT A

Settlement Agreement • April 1st, 2011

• Contract Type
  Settlement Agreement
• Filed
  April 1st, 2011

This Settlement and Complete Waiver/Release Agreement (“Master Agreement”) is between Plaintiffs E. Thomas Merritt, Elizabeth Granger, Townley Sheap, Victor Cherry, and James Johnson and all other individuals who filed consents in the case of E. Thomas Merritt, et al. v. WellPoint, Inc., Case No. 3:08cv272-JRS (collectively, the “Collective Plaintiffs”) and Defendant WellPoint, Inc. (“WellPoint”). The Collective Plaintiffs and WellPoint will be referred to collectively as the “Parties.”