THIS NOTICE IS TO INFORM YOU OF A PROPOSED SETTLEMENT THAT MAY AFFECT YOUR RIGHTS. A

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1 NOTICE OF PROPOSED SETTLEMENT OF CLASS ACTION WITH ANTHEM HEALTH PLANS, INC., OF SETTLEMENT HEARING TO CONSIDER THE PROPOSED SETTLEMENT AND OF YOUR RIGHTS CONCERNING THE PROPOSED SETTLEMENT IF YOU ARE A DENTIST OR DENTAL PRACTICE THAT PROVIDED OR ARRANGED FOR PROVISION OF SERVICES TO ANY MEMBERS OF DENTAL AND/OR DENTAL PLANS ISSUED OR ADMINISTERED BY ANTHEM HEALTH PLANS, INC. D/B/A ANTHEM BLUE CROSS AND BLUE SHIELD OF CONNECTICUT PURSUANT TO A PROVIDER CONTRACT IN FORCE AT ANY TIME DURING THE PERIOD APRIL 15, 1996 THROUGH APRIL 15, 2002, PLEASE READ THIS NOTICE CAREFULLY. The Court having reviewed and considered the Joint Motion for Final THIS NOTICE IS TO INFORM YOU OF A PROPOSED SETTLEMENT THAT MAY AFFECT YOUR RIGHTS. A FEDERAL COURT AUTHORIZED WHY THISSHOULD NOTICE. YOU THIS READ IS THISANOTICE? SOLICIATION FROM A LAWYER OR A NOTICE OF A LAWSUIT AGAINST YOU. YOU MAY BENEFIT FROM READING THIS NOTICE. IF YOU WISH TO RECEIVE BENEFITS UNDER THE PROPOSED SETTLEMENT, YOU MUST SUBMIT A CLAIM FORM. If you are or have been a dentist or dental Provider Group or Organization or other entity that provided (or arranged for the provision of) any services to any individual enrolled in or covered by a Dental Plan issued or administered by Anthem Health Plans, Inc., d/b/a Anthem Blue Cross and Blue Shield of Connecticut ( Anthem or Defendant ) pursuant to any Provider Contracts in force at any time during the period April 15, 1996 through April 14, 2002, your rights may be affected by a proposed settlement with Anthem Health Plans, Inc. in the class action lawsuit Martin J. Rutt, D.D.S. and Michael Egan, D.D.S., individually and on behalf of all others similarly situated v. Anthem Health Plans, Inc. d/b/a Anthem Blue Cross and Blue Shield of Connecticut, Case No. 1:02-CV FAM (the Class Action Litigation or Action ), which is pending in the United States District Court for the Southern District of Florida (the Court ). The Class Representatives have agreed to settle all claims against Anthem in the Class Action Litigation in exchange for Anthem s adoption of a number of commitments and initiatives regarding its business practices, and the establishment of a settlement fund of three million, eight-hundred thousand dollars ($3,800,000.00) less approved attorneys fees and costs and an approved award to Class Representatives, against which eligible members of the Settlement Class (as defined below) may make a claim for a cash payment. You may be a potential member of the Settlement Class who would be entitled to receive the benefits of the proposed settlement. As a member of the Settlement Class, however, you will also be bound by the release and other provisions of the Settlement if it is approved by the Court. You may elect to opt out of the Settlement Class and the Settlement, as explained below. You also have a right to object to the Settlement, the dismissal of the Class Action Litigation, the entry of Final Order and Judgment, or to the applications for attorneys fees and Class Representatives fees that counsel for the Class intend to make to the Court, but only if you comply with the procedures described in this notice. The Court has scheduled a hearing to consider the fairness, reasonableness and adequacy of the proposed settlement with Anthem, together with certain other matters, to be held on September 13, 2012, at 10:00 A.M., at the Wilkie D. Ferguson, Jr. United States Courthouse, 400 North Miami Avenue, Miami, Florida, (the Settlement Hearing ). BECAUSE YOUR RIGHTS TO PURSUE CERTAIN TYPES OF CLAIMS AGAINST ANTHEM HEALTH PLANS, INC. MAY BE AFFECTED BY THE SETTLEMENT, YOU SHOULD READ THIS NOTICE CAREFULLY. WHAT IS THIS LITIGATION ABOUT? The Complaint in this Class Action Litigation alleges that Anthem reimbursed dentists participating in Anthem s provider network in amounts less than required under their Provider Contracts for claims for services provided during the period April 15, 1996 through April 14, The Complaint in this Class Action Litigation asserts claims for violations of the Connecticut Unfair Trade Practices Act b et seq. ( CUTPA ) and also seeks recovery on various common law theories, including breach of contract, breach of the duty of good faith and fair dealing, and unjust enrichment. By agreeing to the Settlement described in this Notice, Anthem makes no admission as to the truth of these allegations and denies any wrongdoing. 1 of 8

2 If you would like further information about the claims asserted in the Class Action Litigation, you can review copies of the Complaint at: WHAT ARE THE TERMS OF THE PROPOSED SETTLEMENT? The proposed Settlement Agreement dated January 30, 2012 (the Settlement Agreement ) provides for the settlement and release of all claims Plaintiffs have against Anthem related in any way to claims submitted for services rendered between April 15, 1996 and April 14, 2002 in exchange for Anthem s agreement regarding certain of its business practices and for certain monetary consideration. The terms of the Settlement Agreement are summarized in this notice, but a copy of the entire Settlement Agreement can be reviewed at THE SETTLEMENT CLASS The Parties have agreed that the proposed settlement will be on behalf of the following Settlement Class, which has been preliminarily certified for settlement proposes: All Participating Providers who provided any services to any individual enrolled in or covered by a Dental and/or Dental Plans issued or administered by Anthem Health Plans, Inc. pursuant to any Provider Contracts in force at any time during the period April 15, 1996 through April 14, 2002 (the Class Period ). As used above, Participating Provider means any dentist, or Provider Group (that is, two or more dentists, and those claiming by or through them, who practice under a single taxpayer identification number), Provider Organization (that is, association, partnership, corporation, or other form of organization that arranges for dental care to be provided to individuals enrolled in or covered by a Dental Plan), or other entity that entered into or provided services pursuant to a Provider Contract. Provider Contract means every Participating Dentist Agreement between Blue Cross & Blue Shield of Connecticut, Inc. or Anthem Health Plans, Inc., and any Participating Provider that was in force at any time between April 15, 1996 and April 14, 2002, including the Blue Cross & Blue Shield of Connecticut, Inc. Agreements attached to the Complaint and any contracts similar to them. The Court will hold a Hearing to decide whether this proposed Settlement Class and the Settlement Agreement shall be finally approved. You need not do anything to become part of the Settlement Class, but you must complete the Claim Form in order to be eligible to receive any benefit from the Settlement. As a Settlement Class Member, you will be bound by all proceedings, orders, and judgments entered in connection with the proposed settlement and Settlement Agreement, including the release, covenant not to sue, and dismissal with prejudice described below. THE SETTLEMENT CONSIDERATION If the Settlement is approved by the Court, the Settlement Agreement provides for both monetary and other benefits to be provided by Anthem to members of the Settlement Class. Business Practice Initiatives As a part of the Settlement, Anthem has agreed to certain commitments regarding its policies and procedures. For example, Anthem has agreed, subject to implementation dates and other conditions described in the Settlement Agreement, to the following: Dental Advisory Group. Anthem and Class Representatives, with the input of the Connecticut State Dental Association ( CSDA ) will establish a Dental Advisory Group ( DAG ) that will be comprised of at least two Anthem Designees and no more than five Connecticut Dentists all of whom must be participating providers with Anthem that will be selected by the CSDA. Anthem and the CSDA s designees will meet four times during the first year of the three-year Term of the Settlement Agreement and at least twice a year in each subsequent year during the Term of the Settlement Agreement. The Dental Advisory Group will be able to discuss local, regional or national issues arising from or related to the relationships and interactions between and among Connecticut participating dentists, their patients, and Anthem. These issues may include, but are not limited to: (a) improvement of dental care and clinical quality; (b) improvement of communications, relations and cooperation between participating dentists and Anthem; (c) matters of a clinical or administrative nature that impact the interaction between participating dentists and Anthem; and/or (d) addressing the needs of underserved populations. 2 of 8

3 Any recommendations made by members of the DAG will be advisory in nature and will not be binding on the policies or practices of either the Dentists or Anthem. Anthem will, at no cost to members of the DAG, host DAG meetings at an Anthem facility in Connecticut. Web-Based Portal. Within 12 months of Final Approval of this Settlement, Anthem will make available to Connecticut Participating Dentists a web-based portal that provides access to an updated Anthem Participating Provider Policy and Procedure Manual. The online Manual shall be updated within a reasonable time of implementation, but no longer than sixty (60) days following implementation of any change, to reflect any and all changes to the Manual. Notice of such changes shall also be posted on the web-based portal. During the Term of the Settlement Agreement, Anthem also will continue to make web-based portals or systems that provide on-line verification of member eligibility and dental benefits coverage under Dental Plans available to Connecticut Participating Dentists. Currently, these on-line services are available for the new Prime and Complete dental products via the provider web-based portal on Anthem.com and for legacy PPO and PPO+ (Flex) dental products via For the Prime and Complete dental products, to which the large majority of Anthem s dental business is expected to migrate during the Term of the Settlement Agreement, the current portal on Anthem.com also provides on-line claims adjudication status. Both ANSLink and the portal on Anthem.com are updated with information from Anthem s membership and claims processing systems on a nightly basis. The systems will be designed so that Connecticut Participating Dentists can electronically register for such web-based portals, and Anthem will provide these services at no cost to the Connecticut Participating Dentists. Provider Credentialing. During the Term of the Settlement Agreement, Anthem will continue to maintain its recent policies aimed at simplifying provider credentialing, by: (a) For Provider Groups or Organizations with more than twenty-five (25) Connecticut Participating Dentists, Anthem will offer and implement delegated credentialing and recredentialing if a practice can meet the standardize delegated credentialing criteria; (b) For all other dentists, Anthem will i. continue to accept the standardized credentialing application; and ii. recredential, at a minimum of every four (4) years for non-medicare or Medicaid programs and at a the Centers for Medicare and Medicaid standards for Medicare or Medicaid programs using a standardized, pre-populated database recredentialing form for dentists to verify or update information currently on file. Seminars. Anthem will offer two dentist and/or office administrator seminars per year, one in-person seminar and one on-line seminar, without charge to participating dentists or their employees. The annual in-person seminar will rotate to various geographic areas of the state to ensure all participating dentists have an opportunity to participate. The seminars shall focus on how to effectively register for, use and operate the web-based portals. Most Favored Nations Provisions. During the Term of the Settlement Agreement, (a) no newly-executed Connecticut Participating Dental Agreements will include a Most Favored Nations provision; and (b) to the extent that any in-force Connecticut Participating Dental Agreements contains a Most Favored Nations provision, Anthem will not enforce these provisions. As used in subsections (a) and (b) above, Most Favored Nations Provision means any provision that requires a participating dentist to provide dental services under Anthem Dental Plans at a payment or reimbursement equal to or lower than the lowest of such rates that a participating dentist has contracted for with any other dental benefit payer. These changes are also described in the Settlement Agreement. The Settlement Fund As a part of the settlement, Anthem will make a settlement payment of three million, eight hundred thousand dollars ($3,800,000.00), less fees, costs and other expenses approved by the Court, which will be distributed to eligible, individual dentist Settlement Class Members that practiced under a Provider Contract and who rendered services at any time during the period April 15, 1996 through April 14, 2002 for which a claim was submitted and reimbursed under that Provider Contract. If the Settlement is approved by the Court, eligible individual dentists who submit valid 3 of 8

4 and timely Claim Forms will be entitled to payments from the Settlement Fund in accordance with the formula that is set forth in the Settlement Agreement at Section and described below. The Settlement Fund amount above includes payments that will be made to cover attorneys fees and costs of Class Counsel, as well as any approved award to the Class Representatives. The amount remaining in the Settlement Fund (the Residual Corpus ) after subtraction of these approved amounts will be divided and payable per capita to eligible individual dentist Settlement Class Members who have submitted valid and timely Claim Forms based a reasonable estimate of the percentage of the Class Period that those Settlement Class Members were Participating Providers with Anthem. The Settlement Administrator shall calculate the amount due to each Settlement Class Member who has validly submitted a Claim Form NO LATER THAN AUGUST 9, 2012 by assigning one point to that dentist for each calendar year during the period from April 15, 1996 through April 14, 2002 in which he or she was a Participating Provider for any portion of that year. An individual dentist may be assigned a maximum of seven points. After the Deadline for Submission of Claim Forms has passed, the Settlement Administrator shall divide the Residual Corpus by the total number of points assigned to eligible individual Settlement Class Members on the basis of timely, valid Claim Forms received in order to establish the monetary value of each point (the Point Value ). An individual Settlement Class Member s Share of the Settlement shall be calculated by multiplying the number of points assigned to that Settlement Class Member by the Point Value. Please also note that with the individual dentist s authorization, Provider Groups and Provider Organizations may submit Claim Form(s) on behalf of eligible Settlement Class Members who are, or were, members of that Physician Group during the Class Period. Provider Groups and Organizations are not entitled to any points, and any payments from the Settlement Fund will be made to individual Settlement Class Members. The seven-point maximum will apply to every individual Settlement Class Member regardless of whether he or she participated in a Provider Group or Organization and regardless of whether the Claim Form is submitted by the individual dentist or by a Provider Group or Organization on the dentist s behalf. The claims may be subject to certain limitations described below. For information on submitting a claim, see How Do I Submit A Claim?, below. The Settlement Fund is described in detail at Section 8.6 of the Settlement Agreement. THE RELEASE AND DISMISSAL WITH PREJUDICE Upon Final Approval, this Action will be dismissed with prejudice as to Anthem. In addition, Anthem, and certain others affiliated with Anthem, will receive a release and discharge from the Settlement Class (which would not include members of the Class who timely elect to opt-out of the Settlement, as discussed below) of any clam, liability, right, demand, suit, obligation, damage, including consequential damages, losses or costs, punitive damages, attorneys fees and costs, actions or causes of action, of every kind or description that Plaintiffs have had, or may have against Defendant, whether known or unknown, suspected or unsuspected, asserted or unasserted, accrued or which may hereafter accrue, regardless of legal or equitable theory and the type of relief or damages claimed, arising out of or in any way related to claims submitted for services rendered between April 15, 1996 and April 14, This means that all Settlement Class Members who have not opted-out of the Settlement and Settlement Class will be forever barred from bringing, continuing, or being part of any claim or lawsuit relating to the Settled Claims, as detailed in the Settlement Agreement, against Anthem and its personnel, representatives, insurers, and related companies. If you fall within the class definition and do not want to be prevented from bringing, continuing, or being part of such lawsuit or do not want to release Anthem from the Settled Claims, you must exclude yourself from the Settlement Class and proposed Settlement as explained below in What If I Do Not Want To Participate In The Settlement?. The Settlement Agreement also includes a covenant not to sue Anthem for claims that are subject to the release. Except as provided above, nothing in this the Settlement Agreement shall be deemed in any way to impair, limit, or preclude each Settlement Class Member s rights to bring a claim (whether in litigation, arbitration or administratively) under a Participating Provider Agreement with Defendant that was effective after April 15, The release provided for in the Settlement applies to Settled Claims whether they are known or unknown. Each member of the Settlement Class that has not timely elected to opt out of the Settlement and Settlement Class shall be deemed to have expressly waived and relinquished the Settled Claims, to the fullest extent permitted by law including any and all provisions, rights and benefits conferred either (a) by California Civil Code 1542, which reads: 4 of 8

5 Section General Release - Claims Extinguished. A general release does not extend to claims which the creditor does not know or suspect to exist in his favor at the time of executing the release, which if known by him must have materially affected his settlement with the debtor. or (b) any law of any state or territory of the United States, federal law, or principle of common law, or of international foreign law, which is similar comparable or equivalent to Section 1542 of the California Civil Code. WHAT WILL HAPPEN AT THE SETTLEMENT HEARING? As mentioned above, the Court will hold a Settlement Hearing on September 13, 2012, at 10:00 A.M., at the Wilkie D. Ferguson, Jr. United States Courthouse, 400 North Miami Avenue, Miami, Florida, However, the order scheduling that hearing also provides that it may be adjourned by the Court and that no additional notice will be provided to potential members of the Class other than an announcement in open court. Updated information will be posted on the settlement website at At the Settlement Hearing, the Court will consider several different issues. First, the Court will consider whether the proposed settlement is fair, reasonable and adequate to members of the Settlement Class. Second, the Court will consider whether it should finally certify the Settlement Class pursuant to Rules 23(a) and 23(b)(3) of the Federal Rules of Civil Procedure. Among other things, this will require the Court to determine (i) whether questions of law or fact common to the members of the Settlement Class predominate over questions affecting only individual members of the Class, and (ii) whether a class action is superior to other available methods for fair and efficient adjudication of the controversy. If the Court certifies the Settlement Class, potential Settlement Class members who have timely elected to opt-out from the Settlement Class by following the procedures described below will be excluded from it. Third, the Court will consider whether to enter orders that would prevent members of the Settlement Class and certain other persons from asserting Settled Claims against Anthem in the future. Fourth, the Court will consider the application for a payment of fees to the Class Representatives, which is discussed in more detail below. Finally, the Court will consider an application by counsel to the Settlement Class for attorneys fees and expenses, which is also discussed in more detail below. CAN I COMMENT ON THE PROPOSED SETTLEMENT? If you have comments about, or disagree with, any aspect of the proposed Settlement, you may express your views to the Court in writing. The document should include your name, address, telephone number and an explanation of your comment or reason for objections, if any, to the matters to be considered. The written response should be postmarked on or before July 10, 2012, and mailed to: Clerk of Court Wilkie D. Ferguson, Jr. United States Courthouse 400 North Miami Avenue Miami, Florida, Your document must clearly state that it relates to Civil Action Number: 1:02-CV FAM. In addition, you must also send a copy of your comment or objection by first class mail, postage prepaid, to the following counsel: For Plaintiffs: John B. Ostrow, Esq. John B. Ostrow, P.A. Courthouse Tower, Suite West Flagler Street Miami, FL of 8 Michael D. Neubert, Esq. Simon I. Allentuch, Esq. Neubert, Pepe & Monteith, P.C. 195 Church Street New Haven, CT 06510

6 For Defendant: E. Desmond Hogan, Esq. Hogan Lovells US LLP th Street, Northwest Washington, DC Michael G. Durham, Esq. Donahue, Durham & Noonan, P.C. 741 Boston Post Road, Suite 306 Guilford, CT HOW DO I PARTICIPATE IN THE SETTLEMENT HEARING? Any Settlement Class Member who has filed objections to the proposed Settlement may appear at the Settlement Hearing and present such objections, provided, however, no member of the Settlement Class that has elected to optout of the Class will be entitled to object. Your attendance at, or participation in, the Settlement Hearing is not required, even if you properly mailed a written response, pursuant to the procedure described above in Can I Comment on the Proposed Settlement?. If you or your personal attorney wish to attend the Settlement Hearing, you are welcome to do so at your own expense. However, it is not necessary that either of you attend. As long as your comment or objection was postmarked before the deadline, the Court will consider it. If you wish to participate in the Settlement Hearing, or want your own attorney to represent your interests at the Settlement Hearing (instead of Class Counsel), you must timely file a comment or objection pursuant to the procedures described above in Can I Comment on the Proposed Settlement?. In addition, you must file with the Court a Notice of Appearance, which should include the name and number of the lawsuit, Civil Action Number 1:02-CV FAM, and state that you wish to enter an appearance at the Settlement Hearing. It must also include your name, address, telephone number, and signature. Your Notice of Appearance must be postmarked on or before July 10, 2012, and mailed to: Clerk of Court Wilkie D. Ferguson, Jr. United States Courthouse 400 North Miami Avenue Miami, Florida, You must also serve a copy of the Notice of Appearance on the counsel listed above in Can I Comment on the Proposed Settlement?. HOW DO I FILE A CLAIM? As discussed above, the proposed settlement contemplates certain settlement payments to members of the Settlement Class who timely submit valid Claim Forms to the Settlement Administrator. In order to qualify for a settlement payment, you must complete the enclosed Claim Form, sign the form, and mail the completed and signed form by NO LATER THAN AUGUST 9, 2012 to: Via United States Postal Service: P.O. Box Birmingham, AL Via UPS or Federal Express: 3415 Independence Drive, Suite 102 Birmingham, AL IF YOU DO NOT SUBMIT YOUR SIGNED CLAIM FORM BY THE DEADLINE, YOU WILL BE DEEMED TO HAVE WAIVED YOUR RIGHT TO RECEIVE ANY PAYMENT FROM THE SETTLEMENT FUND. A Settlement Administrator appointed by the Court will determine whether a claim is reasonable, valid, and payable from the Settlement Fund based on information you provide on the Claim Form. The Settlement Administrator is a neutral party, not affiliated with either Plaintiffs or Defendant. The Settlement Administrator has complete and final authority to determine the amount to be paid on each claim and its decision shall be final, binding, and cannot be appealed. 6 of 8

7 WHAT IF I DO NOT WANT TO BE PART OF THE SETTLEMENT? If you do not want to be a member of the Settlement Class and participate in the proposed settlement, then BY NO LATER THAN July 10, 2012, you must send a signed statement to that effect that includes your name, business address, telephone number and all federal tax identification numbers under which you have sought or received reimbursement from Anthem to the following: Via United States Postal Service: P.O. Box Birmingham, AL Via UPS or Federal Express: 3415 Independence Drive, Suite 102 Birmingham, AL If you choose to opt out of the Settlement and the Settlement Class, you will not be entitled to receive the benefits of the proposed settlement with Anthem, including any payment from the Settlement Fund. Further, you will not be allowed to comment on or object to the proposed Settlement. If you choose to opt out, your claims against Anthem will not be released and you will be free to pursue any claims you believe you have by filing a separate action or request for arbitration if you are subject to an arbitration agreement. Any member of the Settlement Class who or which timely submits a request to opt out of the Settlement will have until seven days prior to the Settlement Hearing to deliver to the Settlement Administrator a written revocation of the request to opt out and shall thereby remain a member of the Settlement Class. TO BE CONSIDERED TIMELY AND TO EFFECTIVELY OPT OUT OF THE SETTLEMENT, YOUR COMPLETED AND SIGNED OPT-OUT NOTICE MUST BE POSTMARKED BY NO LATER THAN JULY 10, IF IT IS NOT POSTMARKED BY THAT DATE, YOUR RIGHT TO OPT-OUT WILL BE DEEMED WAIVED AND YOU WILL BE BOUND BY ALL ORDERS AND JUDGMENTS ENTERED IN CONNECTION WITH THE SETTLEMENT. WHO ARE THE ATTORNEYS APPOINTED TO REPRESENT THE SETTLEMENT CLASS? The Court has appointed the following law firms as Class Counsel to represent the Settlement Class: Local Counsel John B. Ostrow, Esq. John B. Ostrow, P.A. Courthouse Tower, Suite West Flagler Street Miami, FL Primary Counsel Michael D. Neubert, Esq. Simon I. Allentuch, Esq. Neubert, Pepe & Monteith, P.C. 195 Church Street New Haven, CT HOW WILL CLASS COUNSEL BE PAID? Since the beginning of this litigation, Primary Counsel in this Action has not received any payment for their services in prosecuting the Action, nor has it been reimbursed for any out-of-pocket expenses. If the Court approves the proposed Settlement, Primary Counsel will apply to the Court for an award of attorneys fees, including costs and expenses. As part of the Settlement Agreement, Primary Counsel will ask the Court to approve an amount of attorneys fees, costs, or expenses in aggregate amount of six hundred fifty thousand dollars ($650,000.00). If the Court awards attorneys fees and expenses in an amount no greater than that amount, the amount awarded by the Court to Primary Counsel will be paid out of the Settlement Fund described above. This payment will reduce the amount available to members of the Class if the proposed Settlement is approved. WHAT ARE THE CLASS REPRESENTATIVES FEES? In addition to the application for attorneys fees and expenses described in the preceding section, in connection with the Court s consideration of the proposed Settlement, the Class Counsel, on behalf of Class Representatives intend to seek an award from the Court of fees in the aggregate amount of $50,000, which, if awarded, would be paid out of the Settlement Fund discussed above. If the Court awards Class Representatives a fee up to that amount, the amount awarded by the Court to Class Representatives will be paid out of the Settlement Fund described above. This payment will reduce the amount available to members of the Class generally if the proposed settlement is approved. 7 of 8

8 EXAMINATION OF PAPERS This notice is a summary and does not describe all details of the proposed settlement with Anthem, the Settlement Agreement or the proceedings in this Action generally. Complete copies of the Settlement Agreement and certain pleadings and papers filed in the Action can be found for review on the following website: In addition, you may review the complete files of papers submitted in the Actions at the office of the Clerk of the Court, Wilkie D. Ferguson, Jr. United States Courthouse, 400 North Miami Avenue, Miami, Florida, during regular business hours. WHO CAN I CONTACT WITH QUESTIONS? If you have questions regarding this Notice, the proposed settlement, or the Class Action Litigation, you may: Visit the settlement website at: Call the Settlement Administrator toll free at: Write or fax to the Settlement Administrator P.O. Box Birmingham, AL (fax) PLEASE DO NOT CALL ANTHEM, YOUR ANTHEM PROVIDER RELATIONS REPRESENTATIVE, THE COURT OR THE CLERK S OFFICE. REQUEST TO FORWARD THIS NOTICE If you would be a member of the Settlement Class described in this notice but you have assigned any claim that might be covered by the proposed Settlement or the release described above, please forward this notice to the appropriate person as soon as possible. Dated: April 11, 2012 BY ORDER OF THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF FLORIDA 8 of 8