MEMORANDUM OF UNDERSTANDINGMemorandum of Understanding • November 7th, 2008 • Unitedhealth Group Inc • Hospital & medical service plans
This Memorandum of Understanding (“Memorandum”) is made and entered into between and among (i) California Public Employees’ Retirement System (“CalPERS”), Alaska Plumbing and Pipefitting Industry Pension Trust (“Alaska Plumbing”) (for themselves and on behalf of all persons who purchased or otherwise acquired the publicly traded securities of UnitedHealth Group Inc. (“UnitedHealth”) between January 20, 2005 and May 17, 2006 (“Class Members”)) (collectively, the “Plaintiffs”); and (ii) UnitedHealth, and Stephen J. Hemsley, Patrick J. Erlandson, Robert J. Sheehy, William A. Munsell, Tracy L. Bahl, Lois E. Quam, James A. Johnson, Thomas H. Kean, Mary O. Mundinger, William C. Ballard, Douglas W. Leatherdale, William G. Spears, Gail R. Wilensky, Richard T. Burke, Donna E. Shalala, and Robert L. Ryan (collectively the “Individual Defendants”) (together with UnitedHealth, the “Settling Defendants”). Defendants William W. McGuire and David J. Lubben (collectively, the “Non-Settling Defendants”
