SUPERIOR COURT OF THE STATE OF WASHINGTON KING COUNTY
NOTICE OF CLASS ACTION SETTLEMENT
This notice affects your rights. Please read it carefully.
The Court authorized this notice. It is not a solicitation.
TO: Class members and their attorneys, if any, of a Class defined as:
All individuals covered by a government health care plan established or maintained within Washington State from whom MultiPlan and/or Regence collected or attempted to collect subrogation reimbursement and stated verbally or in writing that the health plan was an ERISA plan or subject to ERISA (the “Class”).
ThisNotice(1)explainsthattheCourthascertifiedthisClassActionforalldamagesclaimsunderWashington’s Consumer ProtectionAct,(2) informs youof a proposed Class Action monetary settlement,(3) identifiesyour options and deadlines to exercise them, and (4) explains how to provide information for accurate claims processing and the deadline fordoingso. Your responseis REQUIREDfor you toobtainmore thana default amount described below.
YOUR LEGAL RIGHTS AND OPTIONS IN THIS SETTLEMENT
SUBMIT A CLAIM FORM
DO NOTHING
EXCLUDE YOURSELF
ESPONSE DEADLINE: JULY 27, 2026
The only way to assure your compensation is calculated accurately.
Accept default payments based on information that may be incomplete or inaccurate.
Exclude yourself from the Class Settlement. Get no payment from the settlement. This is the only option that allows you to bring any claims against Defendants under Washington’s Consumer Protection Act.
OBJECT
APPEAR OR INTERVENE IN THE LAWSUIT
Write to theCourt with specificdetail about whyyoudon’t like the settlement
Enter an appearance in the lawsuit on your own behalf.
1. Why Did I Receive This Notice?
TheCourthasdirectedthisnoticetoadviseClassmembersofaClassActionpendingontheirbehalf. Your rights may be affected by a Class Action lawsuit known as Zou, et al. v. MultiPlan, et al., Cause No. 23-2-188471 KNT, filed in King County Superior Court and assigned to the Honorable Kent Liu (the “Lawsuit”).
You are receiving this notice because MultiPlan and Regence identified you or your client (if you are an attorney) as someone meeting the Class definition above. The basis for you being a Class member may have been communications by MultiPlan or Regence to you, your attorney, or an insurance company, rather than to you directly.
2. What Is the Settlement?
The parties have proposed to the Court a settlement for all Class members’ claims under the Washington Consumer Protection Act (“CPA”). The Court has not yet approved the settlement. The proposed settlement (1) compensates Class members who may have overpaid MultiPlan and Regence from a personal injury settlement, and (2) compensates Class members for alleged delayed access to settlement funds. The gross settlement amount is $600,000 for approximately 156 Class members.
Under the proposed settlement, Class members would be entitled to different compensation depending on the circumstances of their personal injury claims. Compensation to individual Class members ranges from $250 to many thousands of dollars.
3. How Is Compensation Calculated Under the Settlement?
Class member compensation under the proposed settlement is complex. You are encouraged to contact Class Counsel or your own attorney, if any, for assistance in fully understanding the compensation formula and your likely individual compensation The formula is summarized briefly here by categories A – D:
A. Class members who had personal injury settlements where all available bodily injury liability insurance** was paid out are entitled to full refunds of amounts paid to MultiPlan/Regence, plus interest, plus statutory damages in amounts to be determined by the Court after final approval
B. Class members who had personal injury settlements and were represented by an attorney where all available insurance** was not paid out are entitled to refunds of any amounts paid in excess of 55% of the amount MultiPlan/Regence claimed, plus interest, plus statutory damages in amounts to be determined by the Court after final approval. This is to account for MultiPlan/Regence’s share of your attorneys’ fees and costs
C. Classmemberswhohadpersonalinjurysettlements butdidnotpayMultiPlan/Regenceareentitled to interest at 1% per month on the amount claimed by MultiPlan/Regence (up to the available insurance limits), from the date of your personal injury settlement to the date that MultiPlan/Regence waived or withdrew its claim.
D. All Class members, including those with no personal injury settlement and no other compensation described above, are awarded an additional sum of at least $250, depending on the claim calculations at final approval.
** For Categories A and B, bodily injury liability insurance refers to an at-fault party’s liability insurance and, if applicable, underinsured motorist coverage (UIM). The available insurance may have been paid to you, your attorney, an insurer, or another party, or some combination.
4. What Category Am I In and How Do I Find Out My Approximate Compensation?
The parties have made reasonable efforts to designate amounts to which each Class member is entitled based on available information. However, that information may not necessarily be complete or fully accurate. You may contact Class Counsel about the information available and current calculations of your compensation. That information may also be made available at the website in Section 5.
You must follow the instructions in Section 5 to provide information necessary to accurately compensate you under the settlement formula.Failure to do so by July 27, 2026 may result in compensation substantially less than what you are entitled to under the settlement formula. For example, for some Class members the parties already have records indicating that you fall into Category A above and are entitled to a full refund under the settlement formula. In other cases, you may fall into Category A, but the parties have insufficient information to verify that Unless the parties already have information to verify that you are in Category A, Class members who were represented by an attorney and paid MultiPlan/Regence will be compensated
with partial refunds (Category B). Similarly, unless the parties already have information to verify that you are in Category A, Class members who were not represented by an attorney and paid MultiPlan/Regence will be compensated only under Category D.
After receiving claims in response to this notice and prior to issuing final approval of the settlement, the Court may in its discretion increase compensation to the Class, categories of Class members described above, or individual Class members in unique circumstances, in an amount not to exceed the gross settlement amount of $600,000. No additional Class notice will be issued prior to final approval of the settlement. You may contact Class Counsel for more information and should consider your options under Section 7.
5.
How Do
I Submit Information For My Compensation?
a. Where Do I Submit Information and What Is the Deadline?
You may submit information online or in response to this notice using the forms provided with this notice Forms must be mailed to CPT Group at the address provided and postmarked no later than July 27, 2026. To submit online, go to www.MultiPlanClassAction.com. To log in, enter CPT ID: «ID» and Passcode: «Passcode» Answers must be submitted no later than July 27, 2026.
b. Do I Need to Answer Every Question?
Answer each question as best you can to assist in the most accurate calculation of your compensation However, your response will be accepted regardless of whether you answer every question, and you will be entitled to compensation from the Class settlement regardless of whether you submit any information.
c. Will I Be Asked to Provide Documentation?
If the information you provide differs substantially from the information in the parties’ possession, you may be asked to provide documentation. You may also contact Class Counsel or your attorney, if any, for assistance in completing the questionnaire.
d. Why Do I Need to Provide Tax Information and How Do I Provide It?
If your compensation does or may exceed $2,000, you will need to fill out an IRS Form W-9 so that the Class Administrator can issue an IRS Form 1099. If your Form W-9 is not received, the Class Administrator will be required to withhold 24% of the recovery for tax purposes, which may be different than the taxes actually owed.
You may submit your tax information using the W-9 form provided with this notice, mailed to CPT Group and postmarked no later than July 27, 2026. You may also submit your tax information on the website identified above.
If you do not feel comfortable mailing the Form W-9 to CPT Group or submitting your tax information online, you may contact Class Counsel to verify secure transmission of your information
6. Who Is Representing the Class and How Will They Be Paid?
The Court appointed the Class Representatives Lydia Zou, Blair Fleming, and Kristin Bohanan to represent the interests of the Class as a whole. The Court also appointed the following attorneys as counsel for the Class (“Class Counsel”):
AndrewAckley
Lisa Benedetti
PaulStritmatter
Darcy Covert
StritmatterLaw
3600 15th Ave W, Ste. 300 Seattle, WA 98119
andrew@stritmatter.com
206-826-8217
Class Counsel will be paid from sums separate from the Class settlement. You are not responsible for paying attorneys’ fees or costs for Class Counsel.
7. What Does Class Certification and Settlement Mean, and What Are My Options?
Class certification means the judgment and any settlement of claims based on the Consumer Protection Act, whether favorable or not, will apply to all Class members who do not timely elect to be excluded from the Class. The deadline for all options regarding this settlement is July 27, 2026.
Your options are:
A. Do Nothing/Stay in the Class. You are automatically in the Class if you do not opt out. If you stay in the Class, you are entitled to compensation from the Class settlement
While you are not required to submit a claim or provide additional information to receive compensation, itisimportant toprovide information (seeSection 5) that will assistin the accurate calculation of your compensation as described above By staying in the Class, you give up the right to sue Defendants for CPA claims that this Lawsuit resolves, i.e. the conduct by which you meet the Class definition
B. Opt Out. If you do not want to remain a member of the Class for purposes of CPA claims, you must complete the Request for Exclusion form, which is included with this Notice, and return it by mail postmarked no later than July 27, 2026. You will not be entitled to any compensation from the Class settlement
IfyouareexcludedfromtheClass,youmayfileyourownlawsuitbyhiring an attorney at your expense or representing yourself. You may wish to opt out if you intend to seek damages that are greater than or different from the settlement formula described in this notice, or you plan to assert other claims against MultiPlan/Regence involving the conduct by which you meet the Class definition
C. EnterAnAppearance.If you stay in the Class, youmayenteranappearanceintheLawsuit, including throughyour ownattorney,allowing you to participate in the Lawsuit.
D. Seek to Intervene. You may seek to intervene in the Lawsuit. Intervention must be timely. The grounds and procedure for a Class member to intervene are beyond the scope of this notice.
E. Object to the Settlement. If you stay in the Class, you may object to the settlement and give reasons why you think the Court should not approve it. The Court will consider your input. Your objection must state whether it applies only to you, to a specific subset of the Class, or to the entire Class, and also state with specificity the grounds for the objection.
To object, you must send a letter saying that you object to Zou, et al. v. MultiPlan, et al., Cause No. 23-2-18847-1 KNT. Be sure to include your name, address, telephone number, your signature, and the specific reasons you object to the settlement, and indicate whether you intend to attend the final fairness hearing. Mail the objection to these three different places postmarked no later than July 27, 2026.
King County Superior Court Clerk’s Office
401 4th Ave N Kent, WA 98032
Class Counsel
Stritmatter Law 3600 15th Ave W, Ste. 300 Seattle, WA 98119
Defense Counsel
Williams Kastner
601 Union Street, Suite 4000 Seattle, WA 98101-2341
You may consult with Class Counsel or your own attorney about the Class, the Lawsuit, and your decision. You may also wish to consult with a tax professional about compensation under this settlement.
8. What Happens Next?
If the Court schedules a hearing to determine the fairness of the Class settlement, the hearing will take place shortly after the deadlines in this notice. You do not need to attend the hearing, but you may do so. You may contact Class Counsel to be apprised of developments in the Lawsuit, including the scheduling of any hearing. Payments under the proposed settlement cannot be issued until after the Court approves the settlement and an appeals period elapses. Thank you for being patient.
You are responsible for appropriate payment of any taxes, if applicable, related to your compensation. The Court has made no ruling on tax issues and has made no ruling as to which portions of compensation that you may receive relate to personal injury or other claims. The full amount stated in a Form 1099 is not necessarily taxable. You should consult with a tax professional.
9. Where Can I Get Additional Information?
You may obtain the complaint, answer, briefing on and orders certifying the Class, and other public materials from Class Counsel or on the following website: www.stritmatter.com/multiplanclassaction.
For more detailed information, you may review the pleadings, records, and other papers on file in the Lawsuit,whichmaybeinspectedduringregularbusinesshoursattheClerk’sOffice;KingCountySuperiorCourt; 516 Third Avenue, Room E609; Seattle, WA 98104 (directions and hours available at https://kingcounty.gov/en/court/superior-court/courts-jails-legal-system/court-calendars-locationsoperations/superior-court-locations/king-county-courthouse). You may also view court records, at your expense, at the Clerk’s Office Records Access Portal: https://dja-prd-ecexap1.kingcounty.gov/?q=Home. You may also visit the Kent Clerk’s Office; King County Superior Court; 401 Fourth Avenue N, Room 2C, Kent, WA 98032 (directions and hours available at https://kingcounty.gov/en/dept/dja/courts-jails-legal-system/court-calendarslocations-operations/locations-hours).
Please do not contact the Court, Defendants, or defense counsel directly about the Lawsuit, because they cannot provide legal advice.
SUPERIOR COURT OF THE STATE OF WASHINGTON KING COUNTY
Zou, et al. v. MultiPlan, et al., Cause No. 23-2-18847-1 KNT
REQUEST FOR EXCLUSION
Read the enclosed legal notice carefully before filling out this form. You must return this form if you wish to be excluded from the Class. If you want to exclude yourself from the Class, you must complete and return this postcard by mail postmarked before July 27, 2026.
I do not wish to remain a member of the Class certified as Zou, et al. v. MultiPlan, et al., Cause No. 23-218847-1 KNT, filed in King County Superior Court.
(Date) (Signature)
(Address 1) (Print Name)
(Address 2) (Email Address)
SUPERIOR COURT OF THE STATE OF WASHINGTON KING COUNTY
Zou, et al. v. MultiPlan, et al., Cause No. 23-2-18847-1 KNT
COMPENSATION QUESTIONNAIRE AND ATTESTATION
Please answer the following questions as best you can. Your response must be postmarked by July 27, 2026 and will be accepted regardless of whether you answer every question If the information youprovide differs substantially from the information in the parties’ possession, you may be asked to provide documentation. You may consult with Class Counsel or your attorney, if any, for assistance in answering these questions. Please use the CPT ID and Passcode shown at the top right of this page to access your Compensation Questionnaire and Attestation on the Settlement Website at www.MultiPlanClassAction.com.
Please provide:
• The approximate date of your personal injury settlement: ________________________________.
• The amount of your personal injury settlement: _______________________________________.
• The total of all available bodily injury liability insurance including any underinsured motorist coverage (UIM): _______________.
• Whether you were represented by an attorney in obtaining your personal injury settlement: YES ____ NO ____
If Yes, who was your attorney/law firm? ___________________.
• The approximate amount claimed by Defendants: _ ______.
• The approximate amount paid to Defendants: ____________ _______.
• The approximate date MultiPlan/Regence waived or withdrew their claim to settlement funds, if applicable: _________________.
I declare under penalty of perjury under the laws of the State of Washington that the foregoing is true and correct to the best of my knowledge. (Date) (Signature)
1)
2)