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HomeMy WebLinkAbout03/21/2023 10. Resolution authorizing the Opioid Pharmacy & Manufacturer Settlements and the accompanying allocation agreement 1 s F` ,1„11„4\ 4.. .:„Iiki.0;1 , '�,�c.I:' :yes '''":,:,`,(‘''‘;:.::::::_3.1 BUSINESS OF THE CITY COUNCIL YAKIMA, WASHINGTON AGENDA STATEMENT Item No. 10. For Meeting of: March 21, 2023 ITEM TITLE: Resolution authorizing the Opioid Pharmacy& Manufacturer Settlements and the accompanying allocation agreement SUBMITTED BY: Sara Watkins, City Attorney SUMMARY EXPLANATION: The Washington State Attorney General has reached settlement with five opioid pharmacy and manufacturers: Walgreens, CVS, Walmart, Teva and Allergan. To take advantage of the settlement, and receive settlement funds, the City must join the settlements by executing a number of documents and agreeing to the proposed Allocation Agreement. These five settlements will bring Washington $434 million over 15 years if all conditions are met. Washington cities and counties will receive half of this amount— $217 million— if each eligible city and county joins the settlement by approving, signing, and returning the necessary forms. As with the previous distributor settlement, these settlements are contingent on eligible cities and counties joining the settlements. ITEM BUDGETED: No STRATEGIC PRIORITY: Public Safety APPROVED FOR SUBMITTAL BY THE CITY MANAGER RECOMMENDATION: Adopt resolution. ATTACHMENTS: Description Upload Date Type 0 Res-Opioid Settlement_CVS et al. 2/28/2023 Resolution ❑ ExecutiNie Summary of National Opioid Settlements 2/28/2023 Backup Material O Allocation Agreement II 2/28/2023 Contract ❑ Settlement_Participation_Form Teva 2/28/2023 Contract O Settlement_Participation_Form Allergan 2/28/2023 Contract ❑ Settlement_Participation_Form_CVS 2/28/2023 Contract 2 D Settlement_Participation_Form Walgreens 2/28/2023 Contract D Settlement_Participation_Form Walmart 2/28/2023 Contract 3 RESOLUTION NO. R-2023- A RESOLUTION approving the Opioid Pharmacy and Manufacturer settlements with Teva, Allergan, CVS, Walgreens and Walmart, and approving Allocation Agreement II for the allocation and use of settlement funds. WHEREAS, the City approved the One Washington Memorandum of Understanding Between Washington Municipalities on April 19, 2022, in which the City agreed to settle any claims it might have against certain pharmaceutical supply chain entities in exchange for a percentage of the total negotiated settlement amounts; and WHEREAS, the City agreed to negotiated settlement amounts with respect to claims against McKesson, AmerisourceBergen and Cardinal Health, as part of the One Washington collective group, in September of 2022; and WHEREAS, tentative settlements have now been reached with the following pharmacies and manufacturers: Teva, Allergan, CVS, Walgreens and Walmart; and WHEREAS, the City is entitled to take advantage of these settlement amounts due to its participation in the One Washington memorandum; and WHEREAS, to take advantage of the settlement funding the City must approve said settlements and enter into the state-wide Allocation Agreement II which dictates how settlement funds can be spent, as well as provides for regional councils and oversight; and WHEREAS, the City Council finds that it is in the best interest of the City of Yakima and its residents to enter into the Allocation Agreement II; the settlement agreements with Teva, Allergan, CVS, Walgreens, and Walmart; and to secure a portion of the settlement proceeds to be used in the City of Yakima for approved uses as outlined in the One Washington Memorandum and Allocation Agreement II; now, therefore BE IT RESOLVED BY THE CITY COUNCIL OF THE CITY OF YAKIMA: The City Council of the City of Yakima hereby authorizes the City Manager to sign all necessary documents and contracts to effectuate the settlements with Teva, Allergan, CVS, Walgreens and Walmart, and to sign the Allocation Agreement II to access and secure a share of settlement proceeds from recent opioid litigation settlements as outlined therein. ADOPTED BY THE CITY COUNCIL this 21 st day of March, 2023. Janice Deccio, Mayor ATTEST: Sonya Clear Tee, City Clerk 4 Executive Summary of National Opioid Settlements [2.03.2023. Subject to ongoing corrections and updates] In 2021 , nationwide settlements were reached to resolve all opioids litigation brought by states and local political subdivisions against the three largest pharmaceutical distributors—McKesson, Cardinal Health, and AmerisourceBergen ("Distributors")—and against manufacturer Janssen Pharmaceuticals, Inc. and its parent company Johnson & Johnson (collectively, "J&J"). These "2021 National Settlements" have been finalized, and payments have already begun. In all, the Distributors will pay up to $21 billion over 18 years, and J&J will pay up to an additional $5 billion over no more than nine years. In late 2022, agreements were announced with three pharmacy chains—CVS, Walgreens, and Walmart—and two additional manufacturers—Allergan and Teva. In January 2023, each of those pharmacy chains and manufacturers confirmed that a sufficient number of states had agreed to the settlements to move forward. As with the 2021 National Settlements, states and local governments that want to participate in the 2022 National Settlements now will have the opportunity to "opt in." The greater the level of subdivision participation, the more funds will ultimately be paid out for abatement. Assuming maximum participation, the 2022 National Settlements require: • Teva to pay up to $3.34 billion over 13 years and to provide either $1 .2 billion of its generic version of the drug Narcan over 10 years or $240 million of cash in lieu of product, as each state may elect; • Allergen to pay up to $2.02 billion over 7 years; • CVS to pay up to $4.90 billion over 10 years; • Walgreens to pay up to $5.52 billion over 15 years; and • Walmart to pay up to $2.74 billion in 2023, and all payments to be made within 6 years. (These figures include amounts attributable to prior settlements between the Defendants and certain states/subdivisions and amounts for attorneys' fees and costs.) Under both the 2021 and 2022 National Settlements, at least 85% of the funds going directly to participating states and subdivisions must be used for abatement of the 5 opioid epidemic, with the overwhelming bulk of the proceeds restricted to funding future abatement efforts by state and local governments. In addition to providing billions of dollars for abatement, the settlements also impose changes in the way the settling defendants conduct their business. For example: • The Distributors will create a groundbreaking clearinghouse through which they will be required to account not only for their own shipments, but also the shipments of the other distributors, in order to detect, stop, and report suspicious opioids orders; • J&J (which ceased marketing Opioids in 2015 and ceased selling Opioids in 2020) will not market or sell any opioid products in the next ten years and has agreed to cease lobbying concerning prescription opioids for ten years; • Teva and Allergen have agreed to strict limitations on their marketing, promotion, sale, and distribution of opioids, including a ban on: (1) promotion and lobbying; (2) rewarding or disciplining employees based on volume of opioid sales; and (3) funding or grants to third parties; and • Walmart, CVS, and Walgreens are required to implement changes in how they handle opioids, including requirements addressing their compliance structures, pharmacist judgment, diversion prevention, suspicious order monitoring, and reporting on red-flag processes, as well as blocked and potentially problematic prescribers. The 2021 and 2022 National Settlements are the culmination of many years of intense negotiations among representatives of the State Attorneys General, the court-appointed Plaintiffs' Executive Committee and Negotiation Committee, which are comprised of lawyers in the National Prescription Opiate MDL who represent subdivisions, and counsel to the Settling Defendants. These negotiations were facilitated by Judge Dan 6 Polster (who oversees the federal MDL litigation), by the Special Masters appointed by the MDL Court, and by experienced, neutral mediators. The agreements do not settle or release any claims brought by Tribes or by private parties, including private individuals, private hospitals, or private third-party payers. Additional information, including answers to FAQs, can be found at nationalopioidsettlement.com/news. • HOME • NEWS • RISKS & ASSUMPTIONS • MDL ORDERS • TRIBAL SETTLEMENTS https://nationalopioidsettlement.com/executive-summary/ 7 WASHINGTON STATE ALLOCATION AGREEMENT GOVERNING THE ALLOCATION OF FUNDS PAID BY CERTAIN SETTLING OPIOID MANUFACTURERS AND PHARMACIES JANUARY 27, 2023 This Washington State Allocation Agreement Governing the Allocation of Funds Paid by Certain Settling Opioid Manufacturers and Pharmacies (the "Allocation Agreement IP') governs the distribution of funds obtained from (1)Walmart, (2)Teva, (3)Allergan, (4) CVS, and (5) Walgreens (the "Settling Entities") in connection with the resolution of any and all claims by the State of Washington and the counties, cities, and towns in Washington State ("Local Governments") against the Settling Entities via the following settlements: • Walmart Settlement Agreement dated November 12, 2022 and any subsequent amendments ("Walmart Settlement"). • Teva Public Global Settlement Agreement dated November 22, 2022 and any subsequent amendments ("Teva Settlement"). • Allergan Public Global Settlement Agreement dated November 22, 2022 and any subsequent amendments ("Allergan Settlement"). • CVS Settlement Agreement dated December 9, 2022 and any subsequent amendments ("CVS Settlement"). • Walgreens Settlement Agreement dated December 9, 2022 and any subsequent amendments ("Walgreens Settlement"). Collectively, the Walmart Settlement, the Teva Settlement, the Allergan Settlement,the CVS Settlement, and the Walgreens Settlement shall be referred to as "the Settlements". Each of the Settlements can be accessed at https://nationalopioidsettlement.com/. The terms and definitions of each of the respective Settlement are incorporated into this Allocation Agreement II, and any undefined terms in this Allocation Agreement II are as defined in the Settlements. 1. This Allocation Agreement II is intended to be a State-Subdivision Agreement as defined in the Settlements. This Allocation Agreement II shall be interpreted to be consistent with the requirements of a State-Subdivision Agreement in the Settlements. 2. This Allocation Agreement II shall become effective only if all of the following occur: A. The State of Washington joins one of the Settlements and becomes a Settling State as provided for in the respective Settlement. B. One of the Settlements becomes final and effective and a Consent Judgment is filed and approved as provided for in the respective Settlement. 1 8 C. The number of Local Governments that execute and return this Allocation Agreement II satisfies the participation requirements for a State- Subdivision Agreement as specified in one of the Settlements, Washington is a Settling State for that Settlement, and a Consent Judgment has been filed and approved for that Settlement. 3. Requirements to become a Participating Local Government. To become a Participating Local Government that can participate in this Allocation Agreement II with respect to any one of the Settlements, a Local Government must do all of the following: A. The Local Government must execute and return this Allocation Agreement II. B. The Local Government must release its claims against the Settling Entities identified in the respective Settlement and agree to be bound by the terms of the Settlement by timely executing and returning the Participation Form for that Settlement. The forms are attached hereto as Exhibits 1-5. C. Litigating Subdivisions, also referred to as Litigating Local Governments, must dismiss the Settling Entities identified in the respective Settlement with prejudice from their lawsuits. D. Each of the Local Governments that is eligible to participate in this Allocation Agreement II has previously executed and signed the One Washington Memorandum of Understanding Between Washington Municipalities ("MOU") agreed to by the Participating Local Governments in Washington State, which is attached hereto as Exhibit 6. By executing this Allocation Agreement II, the local government agrees and affirms that the MOU applies to and shall govern the Local Government Share as modified by this Allocation Agreement II for each of the Settlements in which the Local Government participates. A Local Government that meets all of the conditions in this paragraph for any of the Settlements shall be deemed a"Participating Local Government"for that Settlement. A Local Government can be a"Participating Local Government"for less than all of the Settlements. If a Local Government is a Participating Local Government for less than all of the Settlements,the Local Government can only receive a portion of the Washington Abatement Amount for the specific Settlement(s)for which it is a Participating Local Government. 4. This Allocation Agreement II applies to the following, all of which collectively shall be referred to as the "Washington Abatement Amount": A. For the Walmart Settlement,the State of Washington's allocation of the (1) Global Settlement Remediation Amount and (2) Additional Remediation Amount. 2 9 B. For the Teva Settlement, the State of Washington's allocation of the (1) Net Abatement Amount and (2) Additional Restitution Amount. C. For the Allergan Settlement, the State of Washington's allocation of the (1) Global Settlement Abatement Amount and (2) Additional Restitution Amount. D. For the CVS Settlement,the State of Washington's allocation of the (1) Maximum Remediation Payment and (2) Additional Remediation Amount. E. For the Walgreens Settlement, the State of Washington's allocation of the (1) Adjusted State Remediation Payment and (2) Additional Remediation Amount. As specified in each of the Settlements, the Washington Abatement Amount will vary dependent on the percentage of Participating Local Governments and whether there are any Later Litigating Subdivisions. 5. The Teva Settlement provides the option for Settling States to obtain Settlement Product or the discretion to convert any portion of the Settlement Product allocated to the Settling State into a cash value equaling twenty percent(20%) of the WAC value of the Settling State's allocated Settlement Product in specified years. It shall be solely the decision of the State regarding whether to convert any portion of the Settlement Product allocated to Washington into a cash value or to obtain the Settlement Product. If the State elects to obtain Settlement Product,the State in its sole discretion shall make all decisions related to the Settlement Product, including but not limited to where, how, and to whom it shall be distributed. For purposes of calculating the division of the Washington Abatement Amount in Paragraph 10 of this Allocation Agreement II,the Settlement Product allocated to Washington shall be considered "State Share" and shall have the cash value assigned to it in the Teva Public Global Settlement Agreement dated November 22, 2022. 6. This Allocation Agreement II does not apply to the State Cost Fund, State AG Fees and Costs, or any attorneys' fees,fees, costs, or expenses referred to in the Settlement or that are paid directly or indirectly via the Settlements to the State of Washington ("State's Fees and Costs"). 7. This Allocation Agreement II and the MOU are a State Back-Stop Agreement. The Settling Entities are paying a portion of the Local Governments' attorneys' fees and costs as provided for in the Settlements. The total contingent fees an attorney receives from the Contingency Fee Fund in the Settlements, the MOU, and this Allocation Agreement II combined cannot exceed 15% of the portion of the LG Share paid to the Litigating Local Government that retained that firm to litigate against the Settling Entities (i.e., if City X filed suit with outside counsel on a contingency fee contract and City X receives $1,000,000 from the Walmart 3 10 Settlement, then the maximum that the firm can receive is $150,000 for fees as to the Walmart Settlement; if City X did not retain the same firm for potential litigation against CVS and City X receives $1,000,000 from the CVS Settlement, then the firm receives no fees from the CVS Settlement.) 8. No portion of the State's Fees and Costs and/or the State Share as defined in Paragraphs 6 and 10 of this Allocation Agreement II shall be used to fund the Government Fee Fund ("OFF")referred to in Paragraph 12 of this Allocation Agreement II and Section D of the MOU, or in any other way to fund any Participating Local Government's attorneys' fees, costs, or common benefit tax. 9. The Washington Abatement Amount shall and must be used by the State and Participating Local Governments for future Opioid Remediation as defined in the Settlements, except as allowed by the Settlements. 10. The State and the Participating Local Governments agree to divide the Washington Abatement Amount as follows: A. Fifty percent(50%)to the State of Washington ("State Share"). B. Fifty percent(50%)to the Participating Local Governments ("LG Share"). 11. The LG Share shall be distributed to Participating Local Governments pursuant to the MOU attached hereto as Exhibit 6 as amended and modified in this Allocation Agreement II. 12. For purposes of this Allocation Agreement II only,the MOU is modified as follows and any contrary provisions in the MOU are struck: A. Exhibit A of the MOU is replaced by Exhibit E of each of the respective Settlements. B. The definition of"Litigating Local Governments" in Section A.4 of the MOU shall mean Litigating Subdivisions as defined in each the respective Settlements. C. The definition of"National Settlement Agreement" in Section A.6 of the MOU shall mean the Settlements. D. The definition of"Settlement" in Section A.14 of the MOU shall mean the Settlements. E. The MOU is amended to add new Section C.4.g.vii, which provides as follows: "If a Participating Local Government receiving a direct payment (a)uses Opioid Funds other than as provided for in the respective Settlements, (b) does not comply with conditions for receiving 4 I direct payments under the MOU, or(c) does not promptly submit necessary reporting and compliance information to its Regional Opioid Abatement Counsel ("Regional OAC") as defined at Section C.4.h of the MOU, then the Regional OAC may suspend direct payments to the Participating Local Government after notice, an opportunity to cure, and sufficient due process. If direct payments to Participating Local Government are suspended, the payments shall be treated as if the Participating Local Government is foregoing their allocation of Opioid Funds pursuant to Section C.4.d and C.4.j.iii of the MOU. In the event of a suspension, the Regional OAC shall give prompt notice to the suspended Participating Local Government and the Settlement Fund Administrator specifying the reasons for the suspension,the process for reinstatement,the factors that will be considered for reinstatement, and the due process that will be provided. A suspended Participating Local Government may apply to the Regional OAC to be reinstated for direct payments no earlier than five years after the date of suspension." F. The amounts payable to each law firm representing a Litigating Local Government from the GFF shall be consistent with the process set forth in the Order Appointing the Fee Panel to Allocate and Disburse Attorney's Fees Provided for in State Back-Stop Agreements, Case No. 1:17-md- 02804-DAP Doc #: 4543 (June 17, 2022). JoJo Tann (the "GFF Administrator"), who is authorized by the MDL Fee Panel (David R. Cohen, Randi S. Ellis and Hon. David R. Herndon (ret.))to calculate the amounts due to eligible counsel from each State Back-Stop fund (i.e., the GFF) (see id. at p. 4), will oversee and confirm the amounts payable to each law firm representing a Litigating Local Government from the GFF. Upon written agreement between the law firms representing the Litigating Local Governments on the one hand and the Washington Attorney General's Office on the other, in consultation with the Washington State Association of Counties and the Association of Washington Cities,the GFF Administrator may be replaced by another person,firm, or entity. G. The GFF set forth in the MOU shall be funded by the LG Share of the Washington Abatement Amount only. To the extent the common benefit tax is not already payable by the Settling Entities as contemplated by Section D.8 of the MOU, the GFF shall be used to pay Litigating Local Government contingency fee agreements and any common benefit tax referred to in Section D of the MOU, which shall be paid on a pro rata basis to eligible law firms as determined by the GFF Administrator. H. To fund the GFF, fifteen percent(15%) of the LG Share shall be deposited in the GFF from each LG Share settlement payment until the Litigating Subdivisions' contingency fee agreements and common benefit tax (if any)referred to in Section D of the MOU are satisfied. Under no 5 12 circumstances will any Primary Subdivision or Litigating Local Government be required to contribute to the GFF more than 15% of the portion of the LG Share allocated to such Primary Subdivision or Litigating Local Government. In addition, under no circumstances will any portion of the LG Share allocated to a Litigating Local Government be used to pay the contingency fees or litigation expenses of counsel for some other Litigating Local Government. The maximum amount of any Litigating Local Government contingency fee agreement(from the Contingency Fee Fund of the respective Settlements) payable to a law firm permitted for compensation shall be fifteen percent (15%) of the portion of the LG Share paid to the Litigating Local Government that retained that firm (i.e., if City X filed suit with outside counsel on a contingency fee contract and City X receives $1,000,000 from the Walmart Settlement, then the maximum that the firm can receive is $150,000 for fees.) The firms also shall be paid documented expenses due under their contingency fee agreements that have been paid by the law firm attributable to that Litigating Local Government. Consistent with Agreement on Attorneys' Fees, Costs, and Expenses, which is Exhibit R of the Settlements, amounts due to Participating Litigating Subdivisions' attorneys under this Allocation Agreement II shall not impact(i) costs paid by the subdivisions to their attorneys pursuant to a State Back-Stop agreement, (ii)fees paid to subdivision attorneys from the Common Benefit Fund for common benefit work performed by the attorneys pursuant to Exhibit R of the Settlements, or (iii) costs paid to subdivision attorneys from the MDL Expense Fund for expenses incurred by the attorneys pursuant to the Settlements. J. Under no circumstances may counsel receive more for its work on behalf of a Litigating Local Government than it would under its contingency agreement with that Litigating Local Government. To the extent a law firm was retained by a Litigating Local Government on a contingency fee agreement that provides for compensation at a rate that is less than fifteen percent(15%) of that Litigating Local Government's recovery, the maximum amount payable to that law firm referred to in Section D.3 of the MOU shall be the percentage set forth in that contingency fee agreement. K. For the avoidance of doubt, both payments from the GFF and the payment to the Participating Litigating Local Governments' attorneys from the Contingency Fee Fund in the respective Settlements shall be included when calculating whether the aforementioned fifteen percent(15%) maximum percentage (or less if the provisions of Paragraph 10.J of this Allocation Agreement II apply) of any Litigating Local Government contingency fee agreement referred to above has been met. 6 13 L. To the extent there are any excess funds in the GFF,the GFF Administrator and the Settlement Administrator shall facilitate the return of those funds to the Participating Local Governments as provided for in Section D.6 of the MOU. 13. In connection with the execution and administration of this Allocation Agreement II, the State and the Participating Local Governments agree to abide by the Public Records Act, RCW 42.56 et seq. 14. All Participating Local Governments, Regional OACs, and the State shall maintain all non-transitory records related to this Allocation Agreement II as well as the receipt and expenditure of the funds from the Settlements for no less than five (5) years. 15. If any party to this Allocation Agreement II believes that a Participating Local Government, Regional OAC,the State, an entity, or individual involved in the receipt, distribution, or administration of the funds from the Settlements has violated any applicable ethics codes or rules, a complaint shall be lodged with the appropriate forum for handling such matters, with a copy of the complaint promptly sent to the Washington Attorney General, Complex Litigation Division, Division Chief, 800 Fifth Avenue, Suite 2000, Seattle, Washington 98104. 16. To the extent(i) a region utilizes a pre-existing regional body to establish its Opioid Abatement Council pursuant to the Section 4.h of the MOU, and (ii)that pre-existing regional body is subject to the requirements of the Community Behavioral Health Services Act, RCW 71.24 et seq.,the State and the Participating Local Governments agree that the Opioid Funds paid by the Settling Entities are subject to the requirements of the MOU and this Allocation Agreement II. 17. Upon request by any of the Settling Entities, the Participating Local Governments must comply with the Tax Cooperation and Reporting provisions of the respective Settlement. 18. Venue for any legal action related to this Allocation Agreement II(separate and apart from the MOU or the Settlements) shall be in King County, Washington. 19. Each party represents that all procedures necessary to authorize such party's execution of this Allocation Agreement II have been performed and that such person signing for such party has been authorized to execute this Allocation Agreement II. 7 14 FOR THE STATE OF WASHINGTON: ROBERT W. FERGUSON Attorney General N_ JEFFREY . RUP 'RT Division Chie Date: c� / 8 15 FOR THE PARTICIPATING LOCAL GOVERNMENT: Name of Participating Local Government: Authorized signature: Name: Title: Date: 9 16 EXHIBIT 1 Subdivision Settlement Participation Form (Exhibit K of the Walmart Settlement) 10 EXHIBIT K 4h division Partirjpatinnf orm Govenunental Entity. I State Authorized Official: Address 1: Address 2: City,State, Zip: Phone: Email: The governmental entity identified above ("Governmental Eiifi ), inorderto obtain and in consideretionfor the benefits provided to the Governmental Entity pusuantto the Settlenent Agreement dated November 14, 2022 ("Walmart Settlement'),and acting thneughthe unde:siv,ed authorized official,limb yelects to participate in the Walmart Sentiment,release allReleased Claims against all Released Ennbties,and agrees as follows. 1. The Govenurental Entity is aware of and has reviewed the Walmart Settlement,understands that all team inthus Election and Release have the neadngs defiled therein,and agrees tlut bythis Election, the GovenunentalEntityelects to participate inthe Wahnunt Settlenrentand become a Participating Subdivisionas provided therein. 2. The Governmental Enttityshallpronptiy,and inanyevendwithin 14 days of tie Effective Date and prior to the filhg of the Consent Judgment,dismiss withprejudice am/ Released Claims that it has filed.Withrespect to airy Released Claims pending inlnre National PrescriptionOpiate Litigation MDL No. 2304,the Govenurendal Entity authorizes the Plaintiff? Executive Committee to execute and file onbelalf ofthe Governmental Entity Stipulation of Dismissal WithPrejudice subs taidially in the formated at httos://nationalatioidsettlement.com/. 3. The Governmental Entity agrees to the tems of the Walmait Settlenrend pedainisg to Subdivisions as defnred therein. 4. By agreeing to the teens of the Wahuart Settlement andbecomisg a Releaso5 the Governmental Entity is entitled to the berefits provided therev, ireluding, ifapplicable, monetary payments begimcng after the Effective Date. 5. The Govenurental Entity agrees touse anymonie it receives 0uough the Walnut Settlement solely for the purposes provided therein. 1 O '7O ge n Is 6 The Govenurental Enetysubnuts to the junsthceonof the courtmthe Govenmental Etty's state when file Consentlu.dgment is filed forpuroses Imuted to that comts rok a5 pondedm anIforrescbug thsput¢ to fie ertentmovIdedm the Wahnut Settlement 7. 'Ile GovenmentalEnttylns fie ddt© etforce the Wahnut Settlenentas movnled 8 'Ile GovenmentalEntty, a5 aPartpahrg SubthnsumbIlembybecomes Rekasor for all Pmloses mule Wahnut Settlene* mcludmgbut not Imuted to all ponslom of Sect:al% (Rekase),anl alongwIthalldepannents,agencles,dmsnms,boads,comnusslom,thstnts, mstmnentahtes ©fan/landau attoneysond annelson mfien.&flail capamty elected or appomted to serve ally&fie folegomg and am/agemy.per my or other enttyclamm6 by©e.tholgh aryof the folegomg and anyother enttynlentfied mule definthon of Rekasor,movnles thr nkase to the flllestertent©fits autionty.As a Rekaso5 fie GovenmentalEnttylienbyabsolutely,mmnIthonallyonl mevocablycovenads not to bamg, file, or clam or to cause, assutorpeannt tobe blovglt filed,or damn& ©do ofielwIse seek to establislthabilltyfor myRekaed Clams agamstmyReleased Enttym themnwhalsoeverThnkases movnled for mile Wahnat Settlementan mtenled by the Pates tobebloadanl shallbe mtelmeted so as to pve the Rekased Enthes fie bloadest Poss bar.gamst myhabilltyrelatmg manywayto Rekased Clams anl e<ten1 to fie full extent of fie rower&fie GoventmmtalEnttyto nkase clams 'Ile Wahnalt SettlementsInllbe a complete bar to myRekased Clam 9 IncomectonwIththerekases povnled thrm fie Wahnalt Settlement each GovenmentalEnttyexpesslywaves, nkases, anIfonvuthschuges my and all Monslons,nghts, allberefits confenedbymylaw of mystate or temtoriof fie Uniled States or otherjunsdnton ormurmk commonlaw,wInclus sunilax, comparabk, or equIvalentto § 1542 of the Caro=CmICole,wInchreals GeneraIRelease;cant A gemral nkase does rotexten1 to clums Junin crethtororleleasug party do¢ lot how orsuspectto elast m It ©1.11ufavor&MIA the Of eXPalillIg tiEleleasethat7fflmaxnbylmnor ler,would have matenallY afficted Ins ceiersettlementwIth fie debtor or nkasedputY A Rekasormay lereafter thscover facts other thmor thffeentfromthosewInclutImaxs, btheves, or asmnes tobetvewIthrespect to He Rekased Clams,but eachGovenmental Enttylerebyexpesslywaves fnly, thnversettles, leleas¢ and thschuges, vronfie Effectve Date,anyanl all Rekased Clams thatmayemsta5 of suchdatebutwInch Rekason do not how 01'511511Pa tO C<ISt Iltfilertillailghlg2114.11EP, ovesIgId.eno5 negligence or thbvglino faultwhatsceverondwIncly Ilmmnywould matenallyaffecttle Govenmental Enthes' deculontopancmate mile Wahnut Settlement 10 NotImg lerenus mtenled to molify manyway fie teams of fie Wahnat Settleme* to winch Govenmental Enhtylereby&pees To the extent tins Electonanl Rekaeis mtemnteddLffirently fiom fie Wahnalt Settlemmt maw nspect7 the WahnutS ettlenent contols 2 3 20 EXHIBIT 2 Subdivision Settlement Participation Form (Exhibit K of the Teva Settlement) 11 21 Exhibit K Subdivision and SpecidDishct Setllament Participation Form Governmental Entity: State: Authorized Signatory: Address 1: Address 2: City,State, Zip: Plicate: Email: The governmental entity identified above ("Governmental Fntio"), in order to cbtain and in comidention for the berefrts provided to the Govenunerdal Entity pursuant to the Agreement dated November 22, 2722 ("Peva Settlemsrd7, and acting tluough the undersigned authorized official, hereby elects to participate in the Teva Settlement, release all Released Claims against all Released Entities, and agrees as follows. 1. The Governmental Entity is aware of and leas reviewed the Teva S ettlemend,understands that all terns in this Election and Release have the rreandngs defined therein, and agree that by this Election,the Govenunental Entity elects to participate inthe Teva Settlement as provided therein. 2. Fohoving the execution of this S ettlenerd Participation Form, the Governmental Entity shall comply withSection 111.B of fie Ten Settlenentregarding Ce sation of Litigation Activities. 3. The Governmental Entity shall,within 14 days of the Rekrenre Date and prior to the filing of the Consent Judgment, file arequest to dismiss withprejudice asry Released Claims that it has filed. With respect to any Released Claims pending in In re Nationd Presceiption Opiate Litigation, 1vIDL No. 2304, fie Govenunentd Entity authorizes the PlaintifB' Executive Committee to execute and file onbelalf oftle GovenmentalEntitya Stipnlatien of Dismissal With Prejudice substantially in the form found athtm< llnetiorralopioidAottlonnnecoru. 4. Tle Govenurentd Entity zgrees to the tenor of fie Teva Settlement pertarvg to Subdivisions as defrred therein. 5. Byagreeing to the terns of the Teva Settlement and becoming a Releaso; the Govenmantd Endityis entitled to the benefits provided therein; irebading, if applicable, nnretanypaymen b begimdng after the Effective Date. 6. Tle Governmental Entity agrees to use any monies it receives though the Teva S ettlemend solely for the pnposes provided therein 7. Tle Governmental Entity submits to the jurisdiction of the cant in fie Governmental Entity's state where the Consent Judgment is filed for pnpcses limited to that cont's role as provided in,and for resolving d spstes to the extend provided in, the Ten Settlement. 1 O 22 8. The Goverzeumtal Elfin/has fie la to nfone fie Teva S et-dankaz monied final 9 Tie G© d Enfity, aS a Partpann Sbdii© © Partpang Sremal Dunn, libyb © a Rks© f© all pnposes m the Teva Settleme* ach,ling but rot Immted t© all pisi© of Sechon V (Release), and © vnth all departments, agemes, dii© bong, columnsnen thstacts, nufignentalnes of anr knn &ft© y and wry person m then' captly ekcted © app=101 t© serve an, ©f the thg©i ani anY ageng Peron © other erthty [thIlththg by © fivongh any ©f fie finnan& au any other enhtY Klernned m fie dthuff© ©f Rds©; ponies thr a rekase t© the idlest extant ©f its antIonty. As a Rks© fie Govenmental Enhty lereby absohtely, gmconithonally, and mengably © t nt t©bang, file, © damn © t© cause, assut © pennd t©beI:gown fileg or clamed, or to ©Jenne seek to g tablish haighty thr any Rekased Clams &gamut any Rekned Enfity m any thrnn whatsoever Tie rekases ponied f© m fie Teva Settlement an mtemied by Released Enhtles au the Govenmental Enfity th be bmad and shall be mteneted so as t© nye the Released Erdnes the noadgt rossk bar agangt any thab any lelang L11 anyway to Reththed Clams au extend t© fie flu extent of the rower of the Governmental Etty t© nkase clamus Tie Teva Settlement shall be a congkte bar t© anyRekased Clam 10 Tie G© d army lenby takes © all nghts th]ifli© s ©f a Partpahrg Sbdii© or Partpang SpecnIgunct a Set fofilum fie Teva Settlement II Inconrectonvnthtle nkases monied for m the Teva Settlement, eachGovenvnentalErhtY ennessly waves, nkag, f© thscInges any au all ponnons, nen, au benefits cornened by any law ©f any state © ttht©y©f fie glutei States © ©tier jidiff©4 © pammple ©f comugn law, winch is =lag comparable, © eqmvalent t© § 1542 ©f the Cabfonna Clvil CodewInclueads GeneralRekese; edent A gererahelease d© rot extend t©damns that fie dit© oneleasng panynes not laggl! or suspect t©nast th his or he favor at fie the of execvng the !glean that, Slmonnby Imn or ler,woild have matenally affected his or her settlemed vnth the dbt© © nk.ased party. A Rls© may Innatler dis © fads one' than © difignnt flan those winch It Inn's, believes, © asumes th be bye wIth respect t© the Rekased Clams,but each Governmental Enhty henb y expessly wanes anl gllly, anl f© settles, rekases and thschang, nrontheEffichve Dag, any au all Rekned Clams thannayenst a5 of suchdate butwInch R4s© d© ©t Inn, or suspect t© enst, whefier tholgh cm:awn% over WU, engg neagerge or Jun&no faultwhatnever, and winch Shown matenally affect the GovenvnentalErdnes' decnonto parnnate mthe Teva Settlemed 12 Nothrng hennns mtemied to modify m anyway fie terms of fie Teva S damn* to winch G© d Enfity lereby agnes T© fie 1E(thrd filth Elef filth\ au Release Is mterpeted difigrentlyfromthe TevaSettlementmanygn red, fie Teva Settlement corthols 2 3 24 EXHIBIT 3 Subdivision Settlement Participation Form (Exhibit K of the Allergan Settlement) 12 Exhibit K iilsderirionvsd 'gx:alDisfiet Sefement Participation Form Govenuental Entity. State: Authorized Signatory: Address 1: Address 2: City,State, Zip: Phone: Email: The govemunental entity identified above ("Governmental j?nti v"), in order to obtain and in comideretion for the benefits provided to the Govenmental Entity pursuant to the Agreement dated November 22, 2022 ("Atlwrgn Sanlanaou'l, and acting tluough the undersigned authorized official, herebyelects to participate inthe AllerganS ettlement, release all Released Claims against all Released Entities,and agrees as &lions. 1. The Governmental Entity is aware of and has reviewed the Allergen S ettlement, understands that all terms in this Election and Release have the meaning defined therein, and agrees that by this Election, tie Governmental Entity elects to participate in the Allergen S ettlenrent as provided therein. 2. Following the execution of this S ettlenrent Participation Farm, the Governmental Entity shall comply with Section IlI.B of to Allergen Settlement regarding Cessation of Litigation Activities. 3. The Governmental Entity shall,within fourteen (14) days of the Rekrence Date and prior to the filing of to Commit Judgment, file a request to dismiss with prejudice airy Released Claims that it has filed. With respect to any Released Claims pending in In ra Nasio,aal Prescription Opiate litignxtiwr, MDL No. 2804, the Govemmntal Entity authorizes the MDL Plaintiff? Executive Cornnittee to execute and file onbelalf of the Governmental Entity a Stipulation of Dismissal With Prejudice substantially in the form Sound at httos:lhationalopioidsettlenend.com. 4. The Governmental Entity agrees to the temps of the Allergen Settlement pertaining to Subdivisions and S pecialD shicts as defined therein. 5. By agreeing to the tenor of the Allergen Settlement and becomwg a Releasce, the Governmental Entity is entitled to tie benefits provided therein, hrluding, if applicable, monetarypay ents begimcng after the Effective Date. 6. The Govenuntal Entity agrees to use any worries it receives tlnatgh the Allergen Settlement solely for to purposes provided therein 1 O 7. The GoyeramentalEnthy submnts to tle Jim dthon of tle ©TM III tie GoyeratheltalEnthis state wlere the ConsentJudgment 35 filed thr pmposes Mulled t© that can's 5551e as povIded •and for resolvmg thsputes to tie ertentmonded m the Allelgan Settlement 8 The GoyemneltalEnthyllas tle ddt© ff© the AllerganSettlementas monded tlelerat 9 The G© t Etty, a5 a Partpalmg Sbdiisi© © Partpahrg Speclal Duffict, heleby becomes a Rks© f© all pmposes 351 the Allegan Settlement achdralg, but rot 155thed to, all pisi© ©f Section V (Rekese), and alorg wIth all departhelts, agemes, dmslons, bomds, commuslons, Subdthslom, dIStl[b, LIISfril/Ilelltahtes ©f my kmd a5U attome”, and annenon mthevoffmal capaywhetler elected © appomted t©serve my of the thg©i aml my agency, p& ©4 or other enthy clammg by or though any ©f the folegorag, and anyotherenthyldenffied mthe defrathonof Releasor, p © d thr a lelease to the fillest ertent©fits althonty As a Rek.asor, the Goyeramental afity beleby absohtelY. urtonithonally, and mevocably © t rot t© bmg„ file, © clam; © t© cause, assut 351 bamgmg„ © penult th be braght, filed © clamed, © t© otlennse seek t© establish habfiltY for my Rekased Clams &gamut Rekased Etty 351 fonth whatsoever Tle rekases monded thr mtle Allelgan Settlement a5e mtended to be bload ani shallbe therpeted so a t© glye the Rek.ased Enthes tie bmadest ross bax agamst habillty lelathg ralanYwaY t© Rekased Clams ani tM th the fun C(terd of the paxer of tle Goyeramental Enthy to rekase damns The Allegan Settlement shallbe a complete bax to anyRekaed Clam 10 The Goyeramental Etty le/515 y takes © all rIghts and cbligatom ©f a Partpathg Subdmslon or Partpahrg SpeclalThstact as set fofillm tle AllecanSettlement II In connecton wIth tle rekases monded for In the Allegan S ettlenent each G© t EntIty expessly waves, leleas¢, ani f© thschragesw ani all monslom, 55g1515, and berefits cce&rredby lax of mystate or tenatoly of the Muted States or offer itmsdthon, © purmk of common law, winch is mnlar, compaxabk, © ethlyalent t© § 1542 of the Caldmva Clvil Cole,winch leads GeneralRekese;camt. A gereral release dces rot el-tend t© clams that tle crethtor or lekasmg pa5ty does not how or suspect to exist Inks or he favor at tle 'LIR &eXPalffilg tie lekase that, 5f 15555,nbyhm or ler,wall have matenally affected It ©ñ settlemmtwIththe debtor or rekased palti A Rls© may helealler dis © fads other than © d5ffirent flan those winch It hows, believes, © assumes t© be the wIth respect t© the Rekased thralls, but each Goyemneltal Enhty heeby ermessly waves 6511y, finally, aml foleyer settles, rekases and thschrages, upon tle Effecthe Date, my and all Rekaed Clams that may 15(15t a50f5LIClidate but winch R4s© d© ©t 15555, © 51.15red th elast wlether thlcugh Ignorance, ovemght emoS neagerte © 050501510 fault whatscever, and winch, if 15555,4 would matally affect tle Govemnental Enthes' isi© t© panmpate 351 the Allelgan Settlement 12 Notlmg lerem is mtenied t© modify many way the terms of the Allergan S ettlenent t© winch the Govemnental Enthy heleby &glees T© the el-tent fins Settlement P &ip&ff© Foam 35 mtelmeted draTelently flan the Allergan Settlement In my lespect the Allegan Settlementcothols 2 3 28 EXHIBIT 4 Subdivision Settlement Participation Form (Exhibit K of the CVS Settlement) 13 EXHIBIT K Sub division Participation and Release Form Govenunental Entity: I State: Authorized Signatory: Address 1: Address 2: _ City,State, Zip: Phone: Email: The govenunental entity identified above ("Governmental Endo"), in order to obtain and in consideration for the berefits provided to the Governmental Entity pursuant to the Settlement Agreement dated Decenrber9, 2022("CNSSattlementl, and acting tluoughtheundersigned arthorized official, hereby elects to participate in the CVS Settlement, release all Released Claims against all Released Entities, and agrees as follows. 1. The Governmental Entity is aware of and has reviewed the CVS Settlenrend,undeatands that all terms inthis Participation and Release Form have the n anwgs defined therein, and agrees that by executing this Participation and Release Forn, fie Governmental Entity elects to participate inthre CVS Serilerrentandbecorre a Participating Subdivisionas provided therein. 2. The Governmental Entity shall promptly, and in airy event in later than 14 days after the Reference Date and prior to the filing of the Convent Judgment, dismiss with prejudice any Released Claims that it has filed. With respect to any Released Claims pending in la ra National Prescription C Eate litigation, MDL No. 2304, the Governmental Entity authorizes the Plaintiffs'fs'Executive Committee to execute and file onbehalfofthe Govemmrental Entitya Stipulation of Dismissal with Prejudice substantially in the fora Sound at htt llratinrralnpinidcettlenend rim 3. The Governmental Entity agrees to the terns of the CVS Settlement pertaining to Participating Subdivisions as defired therein. 4. By agreeing to the tenor of the CVS Settlement and becoming a Releaso; fie Govenunental Entity is entitled to the berefnts provided therein, iwluding, if applicable, monetary payments beginning after the Effective Date. 5. The Governmental Entity agrees to use any nnries it receives tluough the CVS Settlement solelyfor the punpeses provided therein. 1 0 6 The G© t Enthy subnuts t© the &ff© ©f the cowl tht1e G© d Enthy's state wlere the Consent Judgmenbs filed f© pnposes Ltd t©that comts mk as monded ani f© lesolvmg thsputes t© the ertent monded m the CVS Setfiemmt The G© d Etty hkevnse ag2e¢ t© abthate bethre the Natonal AlbMatonPaxel a5 movuled i all f© resolvmg thsplt¢ to tle ertent othewnse p! ddi the CVS Sefflemmt 7. Tie Govenmental Enfity has fie la to elicece fie CVS Sethenent ponded&mem 8. The G© d Enfity, .as a PancIpathg S, bdii©4 helebybecomes a Rks© for all Pthrosesth the CVS S ettlene* mcludmg wItIout Lttff© all plonsIons ©f Sff© XI (Rekase), 1© mill all deparinents, agemes, dansIons, b© commsslom, thsffids, nuthmentathes of my kmi &tt© y and anyperson Jen. capay ekded © appomted t©serve am/of the folegoag ani aary agency, per ory © other et ty clammg by© though am/ of the folegomg, ani my other etty Identhed m fie dthiff© of Rekaso5 Plondes f© a lekase t© the fullest extent ©fits authonty As a Rekasor, the G© d Enthy heleby absohtely, thconthonally, ani mevocably © t ©t t© bnng, file, © clam; or to callse, assut or penult t© be blough{ filed, or clamed, or to otlewnse seek t© establish habillty thr any Released Clams &gamut y Rekased Enhty m wthrym whatscenm The leleas¢ ponded for m tle CVS Setfiemmt thended by tle Pates tobe bmad all shall be mtemleted so as t© pve the Released Enthes the bloadest plbk bax aganut habthlylelatag m anyway to Released Clanns and eetmd to the ffill eetent of fie Paxer of the G© d Enthy t©rekase clanns The CVS Setfienent shallbe a complete bar t©myRekased Clam 9 The G© t Etty lereby tak¢ all It all oblcafions ©f a Partpang S, bdi $!© s set frail=tle CVS Setfiemmt 10 In conrectonwIth tle lekases ponded f© m the CVS Settlenent, each Govenmentil Etty erm¢sly waves, rekases, and f© thschuges all all plonsIons, ngth, ani benefits confmed by my lav of my state © ttht©w ©f the Unded States © other jSdiff©4 © PthcIple ©f conumn law, winch Is sunilax, conmanbk, © equwalent t© § 1542 ©f tle CalfonnaCmICcae,winch leads GenmalRekese; cdolt. A galena lelease d© not ellend t© that the crethtor or lekasmg pay-do¢ kmw © suspect to emst mins ©rlie!. favor at tle the of executhg tle lekase that Lf Imaxnbylumor ler wall have matmally affected It or he. setfienent wIth the dbt© or rekaed Pad') A Rekasor may hmeafter di © fads othm than © dffelent fiom Jose winch It Imaxs, btheves, or assthes t©b the mill lespect to tle Rekased Clanns,but esliGovenmental EnthY hueby ermessly walv¢ 611y, fthlly, and folevut& lekases and thschalges, upon tle Effecthe Date,my all all Rekaed Clams that marmst as of suchdate but wInchReka ors d© not how or suspect t©elast wletlerthaglugrorame,ovemet els% reagens © thloughm fltwhatscever, and winch if hown would matenally &ffict the Goventhmtal Erthes' deculonto pancmate mtleCVS Setfienent 2 SI II Nothng bele3211s 3ntencled t© modify many way the 0.m tie CVS Settlement t© winch behalf of the Govemnental Ent2tY :Gs 32 EXHIBIT 5 Subdivision Settlement Participation Form (Exhibit K of the Walgreens Settlement) 14 37 EXHIBIT K Sub division Partici.atiun and SeleaseForm Governmental Entity: I State: Authorized Signatory: Address I: Address 2: City,State, Zip: Phone: Email: The govenurental entity identified above ("Governmental Endo"), in order to obtain and in consideration for the berefits provided to the Govennnnental Entity pursuant to the Settlement Agreement dated Decennber 9, 2022 ("Wdgreetu Senlammntl, and acting through the unniersigred autlreized official, hereby elects to participate in the Walgreens Settlement, release all Released Claims against all Released Entities, and agree as follovs. 1. The Governmental Entityis aware of and has reviewed the Walgreens Settlement,understands that all terms in this Participation and Release Form have tle manwgs defined therein, and agrees thatbyexecuting this Participationannd Release Form, tle GovemnpntalEntityelects to participate in the Walgreens Settlement and become a Participating Subdivision as provided therein. 2. The Governmental Entity shall promptly, and in army event nn later than 14 days after the Reference Date and prior to the filing of the Convent Judgment, dismiss with prejudice any Released Claims that it has filed. With respect to any Released Claims pendug ill In re Maiota l Prescription Oya'ate litigation, MDL No. 2304, the Governmental Entity authorizes the Plaintiffs'fs'Executive Committee to execute and file on behalf of the Goveuurnntd Entity a Stipulation of Dismissal with Prejudice substantially in the form bind at htt: ll:n€nnolnpinid<ontamr,d nW 3. The Govenurental Entity agrees to the terns of the Walgreens Settlement perta ni g to Participating Subdivisions as defined therein. 4. By agreeing to the terns of the Walgreens Settlenrend and becoming a Releasar, the Governmental Entity is entitled to the benefits provided therein, irebuding, if applicable, monetarypaymends beginuninng after the Effective Date. 5. The Govemrrental Entity agrees to use army monies it receives through the Walgreens Settlement solelyfor the purposes provided therein. 1 0 st 6 Tie Govenurental Enfity subnuts to the junsthchon of the cowl tht1e Govemnental Enfity's state wlere the Consent Judgmentls filed for pmoses Ltd to that comts rok as movIded ani thr resolvmg thspltes to tle ertent movIded • the Walgreens Settlement Tie Govemnental Etty hkevnse &pees th attlate befole the Raton,' AlbMaton Parel as Monded ani for lesolnng thsputes th the eetent ofienvIse monded ny fie Walgreem Settlement 7. Tie Gove=tal Enfity has fie nghtto etf=e the Walgreem Setdementas ponded Jelem 8. Tie Govemnerdal Enfity, as a Pancmathg Subdmslon helebybecomes a Rekasor for all 77770ses 371 tie Walpeens Settlement mcludng vntlouthnutatonall ponslom of S ecton XI (Rekase), ani alorg mill all departments, agemes, dmslons, boaths, conumsnom, thstacts, nuMunelltalMes of any kaki ani attome”, and any rersolunthen&flail capacIty elected or appoInted to serve axy of the folegong ani aary agency, per on or other et ty clammg by or tluough am/ of tie folegomg, ani any oiler enfity Idelthfied m the dethuton of Rekaso5 Mondes for a lekase to fie thll¢t eetent of Its auflonty. As a Rekaso5 the Govemnerdal Enhty heleby absohtely, tmcondMonally, ani mevocably covmants not th bmg, nie, or clam or to callse, assut or remnt th be 1)=0* filed, or clamed, or to otlennse seek th establish habillty thr any Released Clams &gamut any Rekased army In any fonun whatscevuThrekases movIded form the Walpeem Settlenent ale mtended by the Panes tobe bmad anislellbe mtelmeted so a5 to glve the Rekased Enthes the bmadest plbk bar &gamut any habilltylelathg m anyway to Released Clams and eetmd to the eetent of fie Paxer of the Governmental Enfity th lelease damns The Walpeens Settlemmt shall be a completebaxto anyRekased Clam 9 Ile Govenmental Enhty lereby tak¢ on all la ani oblcafions of a Partpang Subdmslonas set&dim tle Walpeem Settlement 10 In comectonvnth tle rekases povIded for!nth Walpeem Settlenent each Govmmental Enhty expessly lekases, ani folever thschuges any ani fl ponslom, rclds, and benefits col&rredby any law of any state or temtory of tle Muted States or otlerjunsthcfion or pmcmle of conmon winch Is smula; conmaxabk, or eqmvalent th § 1542 of the CalifonuaCm1 Code,whchreads GeneraIRekesq camt. A genual rekae does rot ertend to clams that the crethtor or lekasmg party does not how or susrect to elast mlus or ler favor at the the of execuMg tle lelease that Lf Imaxn by Itun or ler wall have matmallyaffEcted It or ler setdementvathile dEb tor or mk.ased party. A Reka or may heleatler thscover fads oiler than or dffelent flan tlose winch It hows, btheves, or assum¢ th be the vnth respect to the Rekased Clams, but each Govemnental Enhty lereby erm¢sly waves and sub; finally, ani folever settles, rekases ani thschuges, uronthe Effecfive Date, venni all Released Clams that mayemst as of suchdate but winch Rekasors do rot Imo?! or 511Sped th elast vaetler tholgh Ignorame, over cht, error, nEgligmce or travel ro fault whatsoever, and wrack If k ldmatenally affEct the Govemnental Enthes' deculonto pancmate mtle Walpeens Settlenent 2 3 36 EXHIBIT 6 One Washington Memorandum of Understanding Between Washington Municipalities 15 37 ONE WASHINGTON MEMORANDUM OF UNDERSTANDING BETWEEN WASHINGTON MUNICIPALITIES Whereas, the people of the State of Washington and its communities have been harmed by entities within the Pharmaceutical Supply Chain who manufacture, distribute, and dispense prescription opioids; Whereas, certain Local Governments, through their elected representatives and counsel, are engaged in litigation seeking to hold these entities within the Pharmaceutical Supply Chain of prescription opioids accountable for the damage they have caused to the Local Governments; Whereas, Local Governments and elected officials share a common desire to abate and alleviate the impacts of harms caused by these entities within the Pharmaceutical Supply Chain throughout the State of Washington, and strive to ensure that principals of equity and equitable service delivery are factors considered in the allocation and use of Opioid Funds; and Whereas, certain Local Governments engaged in litigation and the other cities and counties in Washington desire to agree on a form of allocation for Opioid Funds they receive from entities within the Pharmaceutical Supply Chain. Now therefore, the Local Governments enter into this Memorandum of Understanding ("MOU") relating to the allocation and use of the proceeds of Settlements described. A. Defmitions As used in this MOU: 1. "Allocation Regions" are the same geographic areas as the existing nine (9) Washington State Accountable Community of Health(ACH) Regions and have the purpose described in Section C below. 2 "Approved Purpose(s)" shall mean the strategies specified and set forth in the Opioid Abatement Strategies attached as Exhibit A. 3. "Effective Date" shall mean the date on which a court of competent jurisdiction enters the first Settlement by order or consent decree. The Parties anticipate that more than one Settlement will be administered according to the terms of this MOU, but that the first entered Settlement will trigger allocation of Opioid Funds in accordance with Section B herein, and the formation of the Opioid Abatement Councils in Section C. 4. "Litigating Local Government(s)" shall mean Local Governments that filed suit against any Pharmaceutical Supply Chain Participant pertaining to the Opioid epidemic prior to September 1, 2020. 1 38 5. "Local Government(s)" shall mean all counties, cities, and towns within the geographic boundaries of the State of Washington. 6. "National Settlement Agreements"means the national opioid settlement agreements dated July 21, 2021 involving Johnson & Johnson, and distributors AmerisourceBergen, Cardinal Health and McKesson as well as their subsidiaries, affiliates, officers, and directors named in the National Settlement Agreements, including all amendments thereto. 7 "Opioid Funds" shall mean monetary amounts obtained through a Settlement as defined in this MOU. 8 "Opioid Abatement Council" shall have the meaning described in Section C below. 9. "Participating Local Government(s)" shall mean all counties, cities, and towns within the geographic boundaries of the State that have chosen to sign on to this MOU. The Participating Local Governments may be referred to separately in this MOU as "Participating Counties" and "Participating Cities and Towns" (or "Participating Cities or Towns,"as appropriate) or "Parties." 10. "Pharmaceutical Supply Chain" shall mean the process and channels through which controlled substances are manufactured, marketed, promoted, distributed, and/or dispensed, including prescription opioids. 11. "Pharmaceutical Supply Chain Participant" shall mean any entity that engages in or has engaged in the manufacture, marketing, promotion, distribution, and/or dispensing of a prescription opioid, including any entity that has assisted in any of the above. 12. "Qualified Settlement Fund Account," or "QSF Account," shall mean an account set up as a qualified settlement fund, 468b fund, as authorized by Treasury Regulations 1.468B-1(c) (26 CFR §1.468B-1). 13. "Regional Agreements" shall mean the understanding reached by the Participating Local Counties and Cities within an Allocation Region governing the allocation, management, distribution of Opioid Funds within that Allocation Region. 14. "Settlement" shall mean the future negotiated resolution of legal or equitable claims against a Pharmaceutical Supply Chain Participant when that resolution has been jointly entered into by the Participating Local Governments. "Settlement" expressly does not include a plan of reorganization confirmed under Title l lof the United States Code, irrespective of the extent to which Participating Local Governments vote in favor of or otherwise support such plan of reorganization. 2 39 15. "Trustee" shall mean an independent trustee who shall be responsible for the ministerial task of releasing Opioid Funds from a QSF account to Participating Local Governments as authorized herein and accounting for all payments into or out of the trust. 16. The "Washington State Accountable Communities of Health" or "ACH" shall mean the nine (9) regions described in Section C below. B. Allocation of Settlement Proceeds for Approved Purposes 1. All Opioid Funds shall be held in a QSF and distributed by the Trustee, for the benefit of the Participating Local Governments, only in a manner consistent with this MOU. Distribution of Opioid Funds will be subject to the mechanisms for auditing and reporting set forth below to provide public accountability and transparency. 2. All Opioid Funds, regardless of allocation, shall be utilized pursuant to Approved Purposes as defined herein and set forth in Exhibit A. Compliance with this requirement shall be verified through reporting, as set out in this MOU. 3. The division of Opioid Funds shall first be allocated to Participating Counties based on the methodology utilized for the Negotiation Class in In Re:National Prescription Opiate Litigation, United States District Court for the Northern District of Ohio, Case No. 1:17-md-02804-DAP. The allocation model uses three equally weighted factors: (1)the amount of opioids shipped to the county; (2)the number of opioid deaths that occurred in that county; and (3)the number of people who suffer opioid use disorder in that county. The allocation percentages that result from application of this methodology are set forth in the "County Total" line item in Exhibit B. In the event any county does not participate in this MOU, that county's percentage share shall be reallocated proportionally amongst the Participating Counties by applying this same methodology to only the Participating Counties. 4. Allocation and distribution of Opioid Funds within each Participating County will be based on regional agreements as described in Section C. C. Regional Agreements 1. For the purpose of this MOU, the regional structure for decision- making related to opioid fund allocation will be based upon the nine (9) pre- defined Washington State Accountable Community of Health Regions (Allocation Regions). Reference to these pre-defined regions is solely for the purpose of 3 40 drawing geographic boundaries to facilitate regional agreements for use of Opioid Funds. The Allocation Regions are as follows: • King County (Single County Region) • Pierce County (Single County Region) • Olympic Community of Health Region (Clallam, Jefferson, and Kitsap Counties) • Cascade Pacific Action Alliance Region (Cowlitz, Grays Harbor, Lewis, Mason, Pacific, Thurston, and Wahkiakum Counties) • North Sound Region (Island, San Juan, Skagit, Snohomish, and Whatcom Counties) • SouthWest Region (Clark, Klickitat, and Skamania Counties) • Greater Columbia Region (Asotin, Benton, Columbia, Franklin, Garfield, Kittitas, Walla Walla, Whitman, and Yakima Counties) • Spokane Region (Adams, Ferry, Lincoln, Pend Oreille, Spokane, and Stevens Counties) • North Central Region(Chelan, Douglas, Grant, and Okanogan Counties) 2. Opioid Funds will be allocated, distributed and managed within each Allocation Region, as determined by its Regional Agreement as set forth below. If an Allocation Region does not have a Regional Agreement enumerated in this MOU, and does not subsequently adopt a Regional Agreement per Section C.5, the default mechanism for allocation, distribution and management of Opioid Funds described in Section C.4.a will apply. Each Allocation Region must have an OAC whose composition and responsibilities shall be defined by Regional Agreement or as set forth in Section C.4. 3. King County's Regional Agreement is reflected in Exhibit C to this MOU. 4. All other Allocation Regions that have not specified a Regional Agreement for allocating, distributing and managing Opioid Funds, will apply the following default methodology: a. Opioid Funds shall be allocated within each Allocation Region by taking the allocation for a Participating County from Exhibit B and apportioning those funds between that Participating County and its Participating Cities and Towns. Exhibit B also sets forth the allocation to the Participating Counties and the Participating Cities or Towns within the Counties based on a default allocation formula. As set forth above in Section B.3, to determine the allocation to a county, this formula utilizes: (1)the amount of opioids shipped to the county; (2)the number of opioid deaths that occurred in that county; and (3)the number of people who suffer opioid use disorder in that county. To determine the allocation within a county, the formula utilizes historical federal data showing how the specific Counties and the Cities and Towns within the Counties have 4 41 made opioids epidemic-related expenditures in the past. This is the same methodology used in the National Settlement Agreements for county and intra-county allocations. A Participating County, and the Cities and Towns within it may enter into a separate intra-county allocation agreement to modify how the Opioid Funds are allocated amongst themselves, provided the modification is in writing and agreed to by all Participating Local Governments in the County. Such an agreement shall not modify any of the other terms or requirements of this MOU. b. 10% of the Opioid Funds received by the Region will be reserved, on an annual basis, for administrative costs related to the OAC. The OAC will provide an annual accounting for actual costs and any reserved funds that exceed actual costs will be reallocated to Participating Local Governments within the Region. c. Cities and towns with a population of less than 10,000 shall be excluded from the allocation, with the exception of cities and towns that are Litigating Participating Local Governments. The portion of the Opioid Funds that would have been allocated to a city or town with a population of less than 10,000 that is not a Litigating Participating Local Government shall be redistributed to Participating Counties in the manner directed in C.4.a above. d. Each Participating County, City, or Town may elect to have its share re-allocated to the OAC in which it is located. The OAC will then utilize this share for the benefit of Participating Local Governments within that Allocation Region, consistent with the Approved Purposes set forth in Exhibit A. A Participating Local Government's election to forego its allocation of Opioid Funds shall apply to all future allocations unless the Participating Local Government notifies its respective OAC otherwise. If a Participating Local Government elects to forego its allocation of the Opioid Funds,the Participating Local Government shall be excused from the reporting requirements set forth in this Agreement. e. Participating Local Governments that receive a direct payment maintain full discretion over the use and distribution of their allocation of Opioid Funds, provided the Opioid Funds are used solely for Approved Purposes. Reasonable administrative costs for a Participating Local Government to administer its allocation of Opioid Funds shall not exceed actual costs or 10% of the Participating Local Government's allocation of Opioid Funds, whichever is less. f. A Local Government that chooses not to become a Participating Local Government will not receive a direct allocation of Opioid Funds. The portion of the Opioid Funds that would have been allocated to a Local Government that is not a Participating Local Government shall be 5 42 redistributed to Participating Counties in the manner directed in C.4.a above. g. As a condition of receiving a direct payment, each Participating Local Government that receives a direct payment agrees to undertake the following actions: i. Developing a methodology for obtaining proposals for use of Opioid Funds. ii. Ensuring there is opportunity for community-based input on priorities for Opioid Fund programs and services. iii. Receiving and reviewing proposals for use of Opioid Funds for Approved Purposes. iv. Approving or denying proposals for use of Opioid Funds for Approved Purposes. v. Receiving funds from the Trustee for approved proposals and distributing the Opioid Funds to the recipient. vi. Reporting to the OAC and making publicly available all decisions on Opioid Fund allocation applications, distributions and expenditures. h. Prior to any distribution of Opioid Funds within the Allocation Region, The Participating Local Governments must establish an Opioid Abatement Council (OAC)to oversee Opioid Fund allocation, distribution, expenditures and dispute resolution. The OAC may be a preexisting regional body or may be a new body created for purposes of executing the obligations of this MOU. i. The OAC for each Allocation Region shall be composed of representation from both Participating Counties and Participating Towns or Cities within the Region. The method of selecting members, and the terms for which they will serve will be determined by the Allocation Region's Participating Local Governments. All persons who serve on the OAC must have work or educational experience pertaining to one or more Approved Uses. j. The Regional OAC will be responsible for the following actions: i. Overseeing distribution of Opioid Funds from Participating Local Governments to programs and services within the Allocation Region for Approved Purposes. 6 43 ii. Annual review of expenditure reports from Participating Local Jurisdictions within the Allocation Region for compliance with Approved Purposes and the terms of this MOU and any Settlement. iii. In the case where Participating Local Governments chose to forego their allocation of Opioid Funds: (i) Approving or denying proposals by Participating Local Governments or community groups to the OAC for use of Opioid Funds within the Allocation Region. (ii) Directing the Trustee to distribute Opioid Funds for use by Participating Local Governments or community groups whose proposals are approved by the OAC. (Hi) Administrating and maintaining records of all OAC decisions and distributions of Opioid Funds. iv. Reporting and making publicly available all decisions on Opioid Fund allocation applications, distributions and expenditures by the OAC or directly by Participating Local Governments. v. Developing and maintaining a centralized public dashboard or other repository for the publication of expenditure data from any Participating Local Government that receives Opioid Funds, and for expenditures by the OAC in that Allocation Region, which it shall update at least annually. vi. If necessary, requiring and collecting additional outcome- related data from Participating Local Governments to evaluate the use of Opioid Funds, and all Participating Local Governments shall comply with such requirements. vii. Hearing complaints by Participating Local Governments within the Allocation Region regarding alleged failure to (1) use Opioid Funds for Approved Purposes or (2) comply with reporting requirements. 5. Participating Local Governments may agree and elect to share, pool, or collaborate with their respective allocation of Opioid Funds in any manner they choose by adopting a Regional Agreement, so long as such sharing, pooling, or collaboration is used for Approved Purposes and complies with the terms of this MOU and any Settlement. 7 44 6. Nothing in this MOU should alter or change any Participating Local Government's rights to pursue its own claim. Rather,the intent of this MOU is to join all parties who wish to be Participating Local Governments to agree upon an allocation formula for any Opioid Funds from any future binding Settlement with one or more Pharmaceutical Supply Chain Participants for all Local Governments in the State of Washington. 7. If any Participating Local Government disputes the amount it receives from its allocation of Opioid Funds, the Participating Local Government shall alert its respective OAC within sixty (60) days of discovering the information underlying the dispute. Failure to alert its OAC within this time frame shall not constitute a waiver of the Participating Local Government's right to seek recoupment of any deficiency in its allocation of Opioid Funds. 8. If any OAC concludes that a Participating Local Government's expenditure of its allocation of Opioid Funds did not comply with the Approved Purposes listed in Exhibit A, or the terms of this MOU, or that the Participating Local Government otherwise misused its allocation of Opioid Funds,the OAC may take remedial action against the alleged offending Participating Local Government. Such remedial action is left to the discretion of the OAC and may include withholding future Opioid Funds owed to the offending Participating Local Government or requiring the offending Participating Local Government to reimburse improperly expended Opioid Funds back to the OAC to be re-allocated to the remaining Participating Local Governments within that Region. 9. All Participating Local Governments and OAC shall maintain all records related to the receipt and expenditure of Opioid Funds for no less than five (5) years and shall make such records available for review by any other Participating Local Government or OAC, or the public. Records requested by the public shall be produced in accordance with Washington's Public Records Act RCW 42.56.001 et seq. Records requested by another Participating Local Government or an OAC shall be produced within twenty-one (21) days of the date the record request was received. This requirement does not supplant any Participating Local Government or OAC's obligations under Washington's Public Records Act RCW 42.56.001 et seq. D. Payment of Counsel and Litigation Expenses 1. The Litigating Local Governments have incurred attorneys' fees and litigation expenses relating to their prosecution of claims against the Pharmaceutical Supply Chain Participants, and this prosecution has inured to the benefit of all Participating Local Governments. Accordingly, a Washington 8 45 Government Fee Fund ("OFF") shall be established that ensures that all Parties that receive Opioid Funds contribute to the payment of fees and expenses incurred to prosecute the claims against the Pharmaceutical Supply Chain Participants, regardless of whether they are litigating or non-litigating entities. 2. The amount of the GFF shall be based as follows: the funds to be deposited in the GFF shall be equal to 15% of the total cash value of the Opioid Funds. 3. The maximum percentage of any contingency fee agreement permitted for compensation shall be 15% of the portion of the Opioid Funds allocated to the Litigating Local Government that is a party to the contingency fee agreement, plus expenses attributable to that Litigating Local Government. Under no circumstances may counsel collect more for its work on behalf of a Litigating Local Government than it would under its contingency agreement with that Litigating Local Government. 4. Payments from the GFF shall be overseen by a committee (the "Opioid Fee and Expense Committee") consisting of one representative of the following law firms: (a) Keller Rohrback L.LP.; (b) Hagens Berman Sobol Shapiro LLP; (c) Goldfarb & Huck Roth Riojas, PLLC; and (d) Napoli Shkolnik PLLC. The role of the Opioid Fee and Expense Committee shall be limited to ensuring that the GFF is administered in accordance with this Section. 5. In the event that settling Pharmaceutical Supply Chain Participants do not pay the fees and expenses of the Participating Local Governments directly at the time settlement is achieved, payments to counsel for Participating Local Governments shall be made from the GFF over not more than three years, with 50% paid within 12 months of the date of Settlement and 25%paid in each subsequent year, or at the time the total Settlement amount is paid to the Trustee by the Defendants, whichever is sooner. 6. Any funds remaining in the GFF in excess of (i)the amounts needed to cover Litigating Local Governments' private counsel's representation agreements, and (ii)the amounts needed to cover the common benefit tax discussed in Section C.8 below (if not paid directly by the Defendants in connection with future settlement(s), shall revert to the Participating Local Governments pro rata according to the percentages set forth in Exhibits B, to be used for Approved Purposes as set forth herein and in Exhibit A. 7. In the event that funds in the GFF are not sufficient to pay all fees and expenses owed under this Section, payments to counsel for all Litigating Local Governments shall be reduced on a pro rata basis. The Litigating Local Governments will not be responsible for any of these reduced amounts. 9 46 8. The Parties anticipate that any Opioid Funds they receive will be subject to a common benefit"tax" imposed by the court in In Re: National Prescription Opiate Litigation, United States District Court for the Northern District of Ohio, Case No. 1:17-md-02804-DAP ("Common Benefit Tax"). If this occurs, the Participating Local Governments shall first seek to have the settling defendants pay the Common Benefit Tax. If the settling defendants do not agree to pay the Common Benefit Tax,then the Common Benefit Tax shall be paid from the Opioid Funds and by both litigating and non-litigating Local Governments. This payment shall occur prior to allocation and distribution of funds to the Participating Local Governments. In the event that GFF is not fully exhausted to pay the Litigating Local Governments' private counsel's representation agreements, excess funds in the GFF shall be applied to pay the Common Benefit Tax(if any). E. General Terms 1. If any Participating Local Government believes another Participating Local Government, not including the Regional Abatement Advisory Councils, violated the terms of this MOU, the alleging Participating Local Government may seek to enforce the terms of this MOU in the court in which any applicable Settlement(s) was entered, provided the alleging Participating Local Government first provides the alleged offending Participating Local Government notice of the alleged violation(s) and a reasonable opportunity to cure the alleged violation(s). In such an enforcement action, any alleging Participating Local Government or alleged offending Participating Local Government may be represented by their respective public entity in accordance with Washington law. 2. Nothing in this MOU shall be interpreted to waive the right of any Participating Local Government to seek judicial relief for conduct occurring outside the scope of this MOU that violates any Washington law. In such an action, the alleged offending Participating Local Government, including the Regional Abatement Advisory Councils, may be represented by their respective public entities in accordance with Washington law. In the event of a conflict, any Participating Local Government, including the Regional Abatement Advisory Councils and its Members, may seek outside representation to defend itself against such an action. 3. Venue for any legal action related to this MOU shall be in the court in which the Participating Local Government is located or in accordance with the court rules on venue in that jurisdiction. This provision is not intended to expand the court rules on venue. 4. This MOU may be executed in two or more counterparts, each of which shall be deemed an original, but all of which shall constitute one and the same instrument. The Participating Local Governments approve the use of electronic signatures for execution of this MOU. All use of electronic signatures 10 47 shall be governed by the Uniform Electronic Transactions Act. The Parties agree not to deny the legal effect or enforceability of the MOU solely because it is in electronic form or because an electronic record was used in its formation. The Participating Local Government agree not to object to the admissibility of the MOU in the form of an electronic record, or a paper copy of an electronic document, or a paper copy of a document bearing an electronic signature, on the grounds that it is an electronic record or electronic signature or that it is not in its original form or is not an original. 5. Each Participating Local Government represents that all procedures necessary to authorize such Participating Local Government's execution of this MOU have been performed and that the person signing for such Party has been authorized to execute the MOU. [Remainder of Page Intentionally Left Blank— Signature Pages Follow] 11 48 This One Washington Memorandum of Understanding Between Washington Municipalities is signed this day of , 2022 by: Name& Title On behalf of 4894-0031-1574,v. 2 12 49 EXHIBIT A 50 OPIOID ABATEMENT STRATEGIES PART ONE: TREATMENT A. TREAT OPIOID USE DISORDER(OUD) Support treatment of Opioid Use Disorder (OUD) and any co-occurring Substance Use Disorder or Mental Health (SUD/MH) conditions, co-usage, and/or co-addiction through evidence-based, evidence-informed, or promising programs or strategies that may include, but are not limited to,the following: 1. Expand availability of treatment for OUD and any co-occurring SUD/MH conditions, co-usage, and/or co-addiction, including all forms of Medication-Assisted Treatment (MAT) approved by the U.S. Food and Drug Administration. 2. Support and reimburse services that include the full American Society of Addiction Medicine (ASAM) continuum of care for OUD and any co-occurring SUD/MH conditions, co-usage, and/or co-addiction, including but not limited to: a. Medication-Assisted Treatment(MAT); b. Abstinence-based treatment; c. Treatment, recovery, or other services provided by states, subdivisions, community health centers; non-for-profit providers; or for-profit providers; d. Treatment by providers that focus on OUD treatment as well as treatment by providers that offer OUD treatment along with treatment for other SUD/MH conditions, co-usage, and/or co-addiction; or e. Evidence-informed residential services programs, as noted below. 3. Expand telehealth to increase access to treatment for OUD and any co-occurring SUD/MH conditions, co-usage, and/or co-addiction, including MAT, as well as counseling, psychiatric support, and other treatment and recovery support services. 4. Improve oversight of Opioid Treatment Programs (OTPs) to assure evidence-based, evidence-informed, or promising practices such as adequate methadone dosing. 5. Support mobile intervention, treatment, and recovery services, offered by qualified professionals and service providers, such as peer recovery coaches, for persons with OUD and any co-occurring SUD/MH conditions, co-usage, and/or co-addiction and for persons who have experienced an opioid overdose. 6. Support treatment of mental health trauma resulting from the traumatic experiences of the opioid user (e.g., violence, sexual assault, human trafficking, or adverse childhood experiences) and family members (e.g., surviving family members after an overdose 1 51 or overdose fatality), and training of health care personnel to identify and address such trauma. 7. Support detoxification (detox) and withdrawal management services for persons with OUD and any co-occurring SUD/MH conditions, co-usage, and/or co-addiction, including medical detox, referral to treatment, or connections to other services or supports. 8. Support training on MAT for health care providers, students, or other supporting professionals, such as peer recovery coaches or recovery outreach specialists, including telementoring to assist community-based providers in rural or underserved areas. 9. Support workforce development for addiction professionals who work with persons with OUD and any co-occurring SUD/MH conditions, co-usage, and/or co-addiction. 10. Provide fellowships for addiction medicine specialists for direct patient care, instructors, and clinical research for treatments. 11. Provide funding and training for clinicians to obtain a waiver under the federal Drug Addiction Treatment Act of 2000 (DATA 2000) to prescribe MAT for OUD, and provide technical assistance and professional support to clinicians who have obtained a DATA 2000 waiver. 12. Support the dissemination of web-based training curricula, such as the American Academy of Addiction Psychiatry's Provider Clinical Support Service-Opioids web- based training curriculum and motivational interviewing. 13. Support the development and dissemination of new curricula, such as the American Academy of Addiction Psychiatry's Provider Clinical Support Service for Medication-Assisted Treatment. B. SUPPORT PEOPLE IN TREATMENT AND RECOVERY Support people in treatment for and recovery from OUD and any co-occurring SUD/MH conditions, co-usage, and/or co-addiction through evidence-based, evidence-informed, or promising programs or strategies that may include, but are not limited to, the following: 1. Provide the full continuum of care of recovery services for OUD and any co-occurring SUD/MH conditions, co-usage, and/or co-addiction, including supportive housing, residential treatment, medical detox services, peer support services and counseling, community navigators, case management, and connections to community-based services. 2. Provide counseling, peer-support, recovery case management and residential treatment with access to medications for those who need it to persons with OUD and any co-occurring SUD/MH conditions, co-usage, and/or co-addiction. 2 52 3. Provide access to housing for people with OUD and any co-occurring SUD/MH conditions, co-usage, and/or co-addiction, including supportive housing, recovery housing, housing assistance programs, or training for housing providers. 4. Provide community support services, including social and legal services, to assist in deinstitutionalizing persons with OUD and any co-occurring SUD/MH conditions, co- usage, and/or co-addiction. 5. Support or expand peer-recovery centers, which may include support groups, social events, computer access, or other services for persons with OUD and any co-occurring SUD/MH conditions, co-usage, and/or co-addiction. 6. Provide employment training or educational services for persons in treatment for or recovery from OUD and any co-occurring SUD/MH conditions, co-usage, and/or co- addiction. 7. Identify successful recovery programs such as physician, pilot, and college recovery programs, and provide support and technical assistance to increase the number and capacity of high-quality programs to help those in recovery. 8. Engage non-profits, faith-based communities, and community coalitions to support people in treatment and recovery and to support family members in their efforts to manage the opioid user in the family. 9. Provide training and development of procedures for government staff to appropriately interact and provide social and other services to current and recovering opioid users, including reducing stigma. 10. Support stigma reduction efforts regarding treatment and support for persons with OUD, including reducing the stigma on effective treatment. C. CONNECT PEOPLE WHO NEED HELP TO THE HELP THEY NEED (CONNECTIONS TO CARE) Provide connections to care for people who have — or are at risk of developing — OUD and any co-occurring SUD/MH conditions, co-usage, and/or co-addiction through evidence- based, evidence-informed, or promising programs or strategies that may include, but are not limited to, the following: 1. Ensure that health care providers are screening for OUD and other risk factors and know how to appropriately counsel and treat(or refer if necessary) a patient for OUD treatment. 2. Support Screening, Brief Intervention and Referral to Treatment(SBIRT) programs to reduce the transition from use to disorders. 3. Provide training and long-term implementation of SBIRT in key systems (health, schools, colleges, criminal justice, and probation), with a focus on youth and young adults when transition from misuse to opioid disorder is common. 3 53 4. Purchase automated versions of SBIRT and support ongoing costs of the technology. 5. Support training for emergency room personnel treating opioid overdose patients on post-discharge planning, including community referrals for MAT, recovery case management or support services. 6. Support hospital programs that transition persons with OUD and any co-occurring SUD/MH conditions, co-usage, and/or co-addiction, or persons who have experienced an opioid overdose, into community treatment or recovery services through a bridge clinic or similar approach. 7. Support crisis stabilization centers that serve as an alternative to hospital emergency departments for persons with OUD and any co-occurring SUD/MH conditions, co- usage, and/or co-addiction or persons that have experienced an opioid overdose. 8. Support the work of Emergency Medical Systems, including peer support specialists, to connect individuals to treatment or other appropriate services following an opioid overdose or other opioid-related adverse event. 9. Provide funding for peer support specialists or recovery coaches in emergency departments, detox facilities, recovery centers, recovery housing, or similar settings; offer services, supports, or connections to care to persons with OUD and any co- occurring SUD/MH conditions, co-usage, and/or co-addiction or to persons who have experienced an opioid overdose. 10. Provide funding for peer navigators, recovery coaches, care coordinators, or care managers that offer assistance to persons with OUD and any co-occurring SUD/MH conditions, co-usage, and/or co-addiction or to persons who have experienced on opioid overdose. 11. Create or support school-based contacts that parents can engage with to seek immediate treatment services for their child; and support prevention, intervention, treatment, and recovery programs focused on young people. 12. Develop and support best practices on addressing OUD in the workplace. 13. Support assistance programs for health care providers with OUD. 14. Engage non-profits and the faith community as a system to support outreach for treatment. 15. Support centralized call centers that provide information and connections to appropriate services and supports for persons with OUD and any co-occurring SUD/MH conditions, co-usage, and/or co-addiction. 16. Create or support intake and call centers to facilitate education and access to treatment, prevention, and recovery services for persons with OUD and any co- occurring SUD/MH conditions, co-usage, and/or co-addiction. 4 54 17. Develop or support a National Treatment Availability Clearinghouse — a multistate/nationally accessible database whereby health care providers can list locations for currently available in-patient and out-patient OUD treatment services that are accessible on a real-time basis by persons who seek treatment. D. ADDRESS THE NEEDS OF CRIMINAL-JUSTICE-INVOLVED PERSONS Address the needs of persons with OUD and any co-occurring SUD/MH conditions, co- usage, and/or co-addiction who are involved — or are at risk of becoming involved — in the criminal justice system through evidence-based, evidence-informed, or promising programs or strategies that may include, but are not limited to, the following: 1. Support pre-arrest or post-arrest diversion and deflection strategies for persons with OUD and any co-occurring SUD/MH conditions, co-usage, and/or co-addiction, including established strategies such as: a. Self-referral strategies such as the Angel Programs or the Police Assisted Addiction Recovery Initiative (PAARI); b. Active outreach strategies such as the Drug Abuse Response Team (DART) model; c. "Naloxone Plus" strategies, which work to ensure that individuals who have received naloxone to reverse the effects of an overdose are then linked to treatment programs or other appropriate services; d. Officer prevention strategies, such as the Law Enforcement Assisted Diversion (LEAD) model; e. Officer intervention strategies such as the Leon County, Florida Adult Civil Citation Network or the Chicago Westside Narcotics Diversion to Treatment Initiative; f. Co-responder and/or alternative responder models to address OUD-related 911 calls with greater SUD expertise and to reduce perceived barriers associated with law enforcement 911 responses; or g. County prosecution diversion programs, including diversion officer salary, only for counties with a population of 50,000 or less. Any diversion services in matters involving opioids must include drug testing, monitoring, or treatment. 2. Support pre-trial services that connect individuals with OUD and any co-occurring SUD/MH conditions, co-usage, and/or co-addiction to evidence-informed treatment, including MAT, and related services. 3. Support treatment and recovery courts for persons with OUD and any co-occurring SUD/MH conditions, co-usage, and/or co-addiction, but only if these courts provide referrals to evidence-informed treatment, including MAT. 5 55 4. Provide evidence-informed treatment, including MAT, recovery support, or other appropriate services to individuals with OUD and any co-occurring SUD/MH conditions, co-usage, and/or co-addiction who are incarcerated in jail or prison. 5. Provide evidence-informed treatment, including MAT, recovery support, or other appropriate services to individuals with OUD and any co-occurring SUD/MH conditions, co-usage, and/or co-addiction who are leaving jail or prison have recently left jail or prison, are on probation or parole, are under community corrections supervision, or are in re-entry programs or facilities. 6. Support critical time interventions (CTI), particularly for individuals living with dual- diagnosis OUD/serious mental illness, and services for individuals who face immediate risks and service needs and risks upon release from correctional settings. 7. Provide training on best practices for addressing the needs of criminal-justice- involved persons with OUD and any co-occurring SUD/MH conditions, co-usage, and/or co-addiction to law enforcement, correctional, or judicial personnel or to providers of treatment, recovery, case management, or other services offered in connection with any of the strategies described in this section. E. ADDRESS THE NEEDS OF PREGNANT OR PARENTING WOMEN AND THEIR FAMILIES, INCLUDING BABIES WITH NEONATAL ABSTINENCE SYNDROME Address the needs of pregnant or parenting women with OUD and any co-occurring SUD/MH conditions, co-usage, and/or co-addiction, and the needs of their families, including babies with neonatal abstinence syndrome, through evidence-based, evidence-informed, or promising programs or strategies that may include, but are not limited to, the following: 1. Support evidence-based, evidence-informed, or promising treatment, including MAT, recovery services and supports, and prevention services for pregnant women — or women who could become pregnant—who have OUD and any co-occurring SUD/MH conditions, co-usage, and/or co-addiction, and other measures to educate and provide support to families affected by Neonatal Abstinence Syndrome. 2. Provide training for obstetricians or other healthcare personnel that work with pregnant women and their families regarding treatment of OUD and any co-occurring SUD/MH conditions, co-usage, and/or co-addiction. 3. Provide training to health care providers who work with pregnant or parenting women on best practices for compliance with federal requirements that children born with Neonatal Abstinence Syndrome get referred to appropriate services and receive a plan of safe care. 4. Provide enhanced support for children and family members suffering trauma as a result of addiction in the family; and offer trauma-informed behavioral health treatment for adverse childhood events. 6 56 5. Offer enhanced family supports and home-based wrap-around services to persons with OUD and any co-occurring SUD/MH conditions, co-usage, and/or co-addiction, including but not limited to parent skills training. 6. Support for Children's Services — Fund additional positions and services, including supportive housing and other residential services, relating to children being removed from the home and/or placed in foster care due to custodial opioid use. PART TWO: PREVENTION F. PREVENT OVER-PRESCRIBING AND ENSURE APPROPRIATE PRESCRIBING AND DISPENSING OF OPIOIDS Support efforts to prevent over-prescribing and ensure appropriate prescribing and dispensing of opioids through evidence-based, evidence-informed, or promising programs or strategies that may include, but are not limited to, the following: 1. Training for health care providers regarding safe and responsible opioid prescribing, dosing, and tapering patients off opioids. 2. Academic counter-detailing to educate prescribers on appropriate opioid prescribing. 3. Continuing Medical Education (CME) on appropriate prescribing of opioids. 4. Support for non-opioid pain treatment alternatives, including training providers to offer or refer to multi-modal, evidence-informed treatment of pain. 5. Support enhancements or improvements to Prescription Drug Monitoring Programs (PDMP5), including but not limited to improvements that: a. Increase the number of prescribers using PDMPs; b. Improve point-of-care decision-making by increasing the quantity, quality, or format of data available to prescribers using PDMPs or by improving the interface that prescribers use to access PDMP data, or both; or c. Enable states to use PDMP data in support of surveillance or intervention strategies, including MAT referrals and follow-up for individuals identified within PDMP data as likely to experience OUD. 6. Development and implementation of a national PDMP — Fund development of a multistate/national PDMP that permits information sharing while providing appropriate safeguards on sharing of private health information, including but not limited to: a. Integration of PDMP data with electronic health records, overdose episodes, and decision support tools for health care providers relating to OUD. 7 57 b. Ensuring PDMPs incorporate available overdose/naloxone deployment data, including the United States Department of Transportation's Emergency Medical Technician overdose database. 7. Increase electronic prescribing to prevent diversion or forgery. 8. Educate Dispensers on appropriate opioid dispensing. G. PREVENT MISUSE OF OPIOIDS Support efforts to discourage or prevent misuse of opioids through evidence-based, evidence- informed, or promising programs or strategies that may include, but are not limited to, the following: 1. Corrective advertising or affirmative public education campaigns based on evidence. 2. Public education relating to drug disposal. 3. Drug take-back disposal or destruction programs. 4. Fund community anti-drug coalitions that engage in drug prevention efforts. 5. Support community coalitions in implementing evidence-informed prevention, such as reduced social access and physical access, stigma reduction — including staffing, educational campaigns, support for people in treatment or recovery, or training of coalitions in evidence-informed implementation, including the Strategic Prevention Framework developed by the U.S. Substance Abuse and Mental Health Services Administration (SAMHSA). 6. Engage non-profits and faith-based communities as systems to support prevention. 7. Support evidence-informed school and community education programs and campaigns for students, families, school employees, school athletic programs, parent- teacher and student associations, and others. 8. School-based or youth-focused programs or strategies that have demonstrated effectiveness in preventing drug misuse and seem likely to be effective in preventing the uptake and use of opioids. 9. Support community-based education or intervention services for families, youth, and adolescents at risk for OUD and any co-occurring SUD/MH conditions, co-usage, and/or co-addiction. 10. Support evidence-informed programs or curricula to address mental health needs of young people who may be at risk of misusing opioids or other drugs, including emotional modulation and resilience skills. 11. Support greater access to mental health services and supports for young people, including services and supports provided by school nurses or other school staff, to 8 58 address mental health needs in young people that (when not properly addressed) increase the risk of opioid or other drug misuse. H. PREVENT OVERDOSE DEATHS AND OTHER HARMS Support efforts to prevent or reduce overdose deaths or other opioid-related harms through evidence-based, evidence-informed, or promising programs or strategies that may include, but are not limited to,the following: 1. Increase availability and distribution of naloxone and other drugs that treat overdoses for first responders, overdose patients, opioid users, families and friends of opioid users, schools, community navigators and outreach workers, drug offenders upon release from jail/prison, or other members of the general public. 2. Provision by public health entities of free naloxone to anyone in the community, including but not limited to provision of intra-nasal naloxone in settings where other options are not available or allowed. 3. Training and education regarding naloxone and other drugs that treat overdoses for first responders, overdose patients, patients taking opioids, families, schools, and other members of the general public. 4. Enable school nurses and other school staff to respond to opioid overdoses, and provide them with naloxone, training, and support. 5. Expand, improve, or develop data tracking software and applications for overdoses/naloxone revivals. 6. Public education relating to emergency responses to overdoses. 7. Public education relating to immunity and Good Samaritan laws. 8. Educate first responders regarding the existence and operation of immunity and Good Samaritan laws. 9. Expand access to testing and treatment for infectious diseases such as HIV and Hepatitis C resulting from intravenous opioid use. 10. Support mobile units that offer or provide referrals to treatment, recovery supports, health care, or other appropriate services to persons that use opioids or persons with OUD and any co-occurring SUD/MH conditions, co-usage, and/or co-addiction. 11. Provide training in treatment and recovery strategies to health care providers, students, peer recovery coaches, recovery outreach specialists, or other professionals that provide care to persons who use opioids or persons with OUD and any co- occurring SUD/MH conditions, co-usage, and/or co-addiction. 12. Support screening for fentanyl in routine clinical toxicology testing. 9 59 PART THREE: OTHER STRATEGIES I. FIRST RESPONDERS In addition to items C8, D 1 through D7, H 1, H3, and H8, support the following: 1. Current and future law enforcement expenditures relating to the opioid epidemic. 2. Educate law enforcement or other first responders regarding appropriate practices and precautions when dealing with fentanyl or other drugs. J. LEADERSHIP, PLANNING AND COORDINATION Support efforts to provide leadership, planning, and coordination to abate the opioid epidemic through activities, programs, or strategies that may include, but are not limited to, the following: 1. Community regional planning to identify goals for reducing harms related to the opioid epidemic, to identify areas and populations with the greatest needs for treatment intervention services, or to support other strategies to abate the opioid epidemic described in this opioid abatement strategy list. 2. A government dashboard to track key opioid-related indicators and supports as identified through collaborative community processes. 3. Invest in infrastructure or staffing at government or not-for-profit agencies to support collaborative, cross-system coordination with the purpose of preventing overprescribing, opioid misuse, or opioid overdoses, treating those with OUD and any co-occurring SUD/MH conditions, co-usage, and/or co-addiction, supporting them in treatment or recovery, connecting them to care, or implementing other strategies to abate the opioid epidemic described in this opioid abatement strategy list. 4. Provide resources to staff government oversight and management of opioid abatement programs. K. TRAINING In addition to the training referred to in various items above, support training to abate the opioid epidemic through activities, programs, or strategies that may include, but are not limited to, the following: 1. Provide funding for staff training or networking programs and services to improve the capability of government, community, and not-for-profit entities to abate the opioid crisis. 2. Invest in infrastructure and staffing for collaborative cross-system coordination to prevent opioid misuse, prevent overdoses, and treat those with OUD and any co- occurring SUD/MH conditions, co-usage, and/or co-addiction, or implement other 10 60 strategies to abate the opioid epidemic described in this opioid abatement strategy list (e.g., health care, primary care, pharmacies, PDMPs, etc.). L. RESEARCH Support opioid abatement research that may include, but is not limited to, the following: 1. Monitoring, surveillance, and evaluation of programs and strategies described in this opioid abatement strategy list. 2. Research non-opioid treatment of chronic pain. 3. Research on improved service delivery for modalities such as SBIRT that demonstrate promising but mixed results in populations vulnerable to opioid use disorders. 4. Research on innovative supply-side enforcement efforts such as improved detection of mail-based delivery of synthetic opioids. 5. Expanded research on swift/certain/fair models to reduce and deter opioid misuse within criminal justice populations that build upon promising approaches used to address other substances (e.g. Hawaii HOPE and Dakota 24/7). 6. Research on expanded modalities such as prescription methadone that can expand access to MAT. 11 EXHIBIT B 61 Local County Government ° Adams County Adams County 0.1638732475% Hatton Lind Othello Ritzville Washtucna County Total: 0.1638732475% Asotin County Asotin County 0.4694498386% Asotin Clarkston County Total: 0.4694498386% Benton County Benton County 1.4848831892% Benton City Kennewick 0.5415650564% Prosser Richland 0.4756779517% West Richland 0.0459360490% County Total: 2.5480622463% Chelan County Chelan County 0.7434914485% Cashmere Chelan Entiat Leavenworth Wenatchee 0.2968333494% County Total: 1.0403247979% Clallam County Clallam County 1.3076983401% Forks Port Angeles 0.4598370527% Sequim County Total: 1.7675353928% *** - Local Government appears in multiple counties B-1 EXHIBIT B 62 Local County Government ° Clark County Clark County 4.5149775326% Battle Ground 0.1384729857% Camas 0.2691592724% La Center Ridgefield Vancouver 1.7306605325% Washougal 0.1279328220% Woodland*** Yacolt County Total: 6.7812031452% Columbia County Columbia County 0.0561699537% Dayton Starbuck County Total: 0.0561699537% Cowlitz County Cowlitz County 1.7226945990% Castle Rock Ka lama Kelso 0.1331145270% Longview 0.6162736905% Woodland*** County Total: 2.47208 28165% Douglas County Douglas County 0.3932175175% Bridgeport Coulee Dam*** East Wenatchee 0.0799810865% Mansfield _ Rock Island Waterville County Total: 0.4731986040% Ferry County Ferry County 0.1153487994% Republic County Total: 0.1153487994% *** - Local Government appears in multiple counties B-2 EXHIBIT B 63 Local County Government ° Franklin County Franklin County 0.3361237144% Connell Kahlotus Mesa Pasco 0.4278056066% County Total: 0.7639293210% Garfield County Garfield County 0.0321982209% Pomeroy County Total: 0.0321982209% Grant County Grant County 0.9932572167% Coulee City Coulee Dam*** Electric City Ephrata George Grand Coulee Hartline Krupp Mattawa Moses Lake 0.2078293909% Quincy Royal City Soap Lake Warden Wilson Creek County Total: 1.20108 66076% *** - Local Government appears in multiple counties B-3 EXHIBIT B 64 Local County Government ° Grays Harbor County Grays Harbor County 0.9992429138% Aberdeen 0.2491525333% Cosmopolis Elma Hoquiam McCleary Montesano Oakville Ocean Shores Westport County Total: 1.2483954471% Island County Island County 0.6820422610% Coupeville Langley Oak Harbor 0.2511550431% County Total: 0.9331973041% Jefferson County Jefferson County 0.4417137380% Port Townsend County Total: 0.4417137380% *** - Local Government appears in multiple counties B-4 EXHIBIT B 65 Local County Government ° King County King County 13.9743722662% Algona Auburn*** 0.2622774917% Beaux Arts Village Bellevue 1.1300592573% Black Diamond Bothell*** 0.1821602716% Burien 0.0270962921% Carnation Clyde Hill Covington 0.0118134406% Des Moines 0.1179764526% Duvall Enumclaw*** 0.0537768326% Federal Way 0.3061452240% Hunts Point Issaquah 0.1876240107% Kenmore 0.0204441024% Kent 0.5377397676% Kirkland 0.5453525246% Lake Forest Park 0.0525439124% Maple Valley 0.0093761587% Medina Mercer Island 0.1751797481% Milton*** Newcastle 0.0033117880% Normandy Park North Bend Pacific*** Redmond 0.4839486007% Renton 0.7652626920% Sammamish 0.0224369090% SeaTac 0.1481551278% Seattle 6.6032403816% Shoreline 0.0435834501% Skykomish Snoqualmie 0.0649164481% Tukwila 0.3032205739% Woodinville _ 0.0185516364% Yarrow Point County Total: 26.0505653608% *** - Local Government appears in multiple counties B-5 EXHIBIT B 66 Local County Government ° Kitsap County Kitsap County 2.6294133668% Bainbridge Island 0.1364686014% Bremerton 0.6193374389% Port Orchard 0.1009497162% Poulsbo 0.0773748246% County Total: 3.5635439479% Kittitas County Kittitas County 0.3855704683% Cle Elum Ellensburg 0.0955824915% Kittitas Roslyn South Cle Elum County Total: 0.4811529598% Klickitat County Klickitat County 0.2211673457% Bingen Goldendale White Salmon County Total: 0.2211673457% Lewis County Lewis County 1.0777377479% Centralia 0.1909990353% Chehalis Morton Mossyrock Napavine Pe Ell Toledo Va der Winlock County Total: 1.2687367832% *** - Local Government appears in multiple counties B-6 EXHIBIT B 67 Local County Government ° Lincoln County Lincoln County 0.1712669645% Almira Creston _ Davenport Harrington _ Odessa Rea rda n Sprague Wilbur County Total: 0.1712669645% Mason County Mason County 0.8089918012% Shelton 0.1239179888% County Total: 0.9329097900% Okanogan County Okanogan County 0.6145043345% Brewster Conconully Coulee Dam*** Elmer City Nespelem Oka nogan Oma k Oroville f Pateros Riverside Tonasket Twisp Winthrop County Total: 0.6145043345% Pacific County Pacific County 0.4895416466% Ilwaco Long Beach Raymond South Bend County Total: 0.4895416466% *** - Local Government appears in multiple counties B-7 EXHIBIT B 68 Local County Government ° Pend Oreille County Pend Oreille County 0.2566374940% Cusick lone Meta line Metaline Falls Newport County Total: 0.2566374940% Pierce County Pierce County 7.2310164020% Auburn*** 0.0628522112% Bonney Lake 0.1190773864% Buckley Carbonado DuPont Eatonville Edgewood 0.0048016791% Enumclaw*** 0.0000000000% Fife 0.1955185481% Fircrest Gig Harbor 0.0859963345% Lakewood 0.5253640894% Milton*** Orting Pacific*** Puyallup 0.3845704814% Roy Ruston South Prairie Steilacoom Sumner 0.1083157569% Tacoma 3.2816374617% University Place 0.0353733363% Wilkeson County Total: 12.0345236870% San Juan County San Juan County 0.2101495171% Friday Harbor County Total: 0.2101495171% *** - Local Government appears in multiple counties B-8 EXHIBIT B 69 Local County Government ° Skagit County Skagit County 1.0526023961% Anacortes 0.1774962906% Burlington 0.1146861661% Concrete Hamilton La Conner Lyman Mount Vernon 0.2801063665% Sedro-Woolley 0.0661146351% County Total: 1.6910058544% Skamania County Skamania County 0.1631931925% North Bonneville_ _ Stevenson County Total: 0.1631931925% Snohomish County Snohomish County 6.9054415622% Arlington 0.2620524080% Bothell*** 0.2654558588% Brier Da rrington Edmonds 0.3058936009% Everett 1.9258363241% Gold Bar Granite Falls Index Lake Stevens 0.1385202891% Lynnwood 0.7704629214% Marysville 0.3945067827% Mill Creek 0.1227939546% Monroe 0.1771621898% Mountlake Terrace 0.2108935805% Mukilteo 0.2561790702% Snohomish 0.0861097964% Stanwood Sultan Woodway County Total: 11.8213083387% *** - Local Government appears in multiple counties B-9 EXHIBIT B 70 Local County Government ° Spokane County Spokane County 5.5623859292% Airway Heights Cheney 0.1238454349% Deer Park Fairfield La to h Liberty Lake 0.0389636519% Medical Lake Millwood Rockford Spangle Spokane 3.0872078287% Spokane Valley 0.0684217500% Waverly County Total: 8.8808245947% Stevens County Stevens County 0.7479240179% Chewelah Colville Kettle Falls Marcus Northport Springdale County Total: 0.7479240179% Thurston County Thurston County 2.3258492094% Bucoda Lacey 0.2348627221% Olympia 0.6039423385% Rainier Tenino Tumwater 0.2065982350% Yelm County Total: 3.3712525050% Wahkiakum County Wahkiakum County 0.0596582197% Cathlamet County Total: 0.0596582197% *** - Local Government appears in multiple counties B-10 EXHIBIT B 71 Local County Government ° Walla Walla County Walla Walla County 0.5543870294% College Place Prescott Waitsburg Walla Walla 0.3140768654% County Total: 0.8684638948% Whatcom County Whatcom County 1.3452637306% Bellingham 0.8978614577% Blaine Everson Ferndale 0.0646101891% Lynden _ _ 0.0827115612% Nooksack Sumas County Total: 2.3904469386% Whitman County Whitman County 0.2626805837% Albion Colfax Colton _ Endicott _ Farmington Garfield LaCrosse Lamont Malden Oakesdale Palouse Pullman 0.2214837491% Rosa l is St. John Tekoa Uniontown County Total: 0.4841643328% *** - Local Government appears in multiple counties B-11 EXHIBIT B 72 Local County Government ° Yakima County Yakima County 1.9388392959% Grandview 0.0530606109% Granger Harrah Mabton Moxee Naches Selah Sunnyside 0.1213478384% Tieton Toppenish Union Gap _ Wapato Yakima _ _ 0.6060410539% Zillah County Total: 2.7192887991% *** - Local Government appears in multiple counties B-12 Exhibit C 74 KING COUNTY REGIONAL AGREEMENT King County intends to explore coordination with its cities and towns to facilitate a Regional Agreement for Opioid Fund allocation. Should some cities and towns choose not to participate in a Regional Agreement, this shall not preclude coordinated allocation for programs and services between the County and those cities and towns who elect to pursue a Regional Agreement. As contemplated in C.5 of the MOU, any Regional Agreement shall comply with the terms of the MOU and any Settlement. If no Regional Agreement is achieved, the default methodology for allocation in C.4 of the MOU shall apply. Exhibit K Subdivision and SpecidDishct Settlement Participation Form Governmental Entity: State: Authorized Signatory: Address 1: Address 2: City,State, Zip: Plicate: Email: The governmental entity identified above ("Governmental Fntiv"), in order to cbtain and in considention for the berefrts provided to the Govenunerdal Entity pursuant to the Agreement dated November 22, 2722 ("Peva Settlemsrd7, and acting tluough the undersigned authorized official, hereby elects to participate in the Teva Settlement, release all Released Claims against all Released Entities, and agrees as follows. 1. The Governmental Entity is aware of and leas reviewed the Teva S ettlemend,understands that all terns in this Election and Release have the meaning defined therein, and agree that by this Election,the Govenunental Entity elects to participate inure Teva Settlement as provided therein. 2. Fohoving the execution of this S ettlenerd Participation Form, the Governmental Entity shall comply withSection 111.B of fie Ten Settlenentregarding Ce sation of Litigation Activities. 3. The Governmental Entity shall,within 14 days of the Rekrenre Date and prior to the filing of the Consent Judgment, file arequest to dismiss withprejudice asry Released Claims that it has filed. With respect to any Released Claims pending in In re Nationd Prescription Opiate Litigation, 1vIDL No. 2304, fie Govenunentd Entity authorizes the PlaintifB' Executive Committee to execute and file onbelalf oftle GovenmentalEntitya Stipnlatien of Dismissal With Prejudice substantially in the form found athtm< llnetiorralopioidAottlonnntcoru. 4. Tire Govenurentd Entity zgrees to the tenor of fie Teva Settlement pertarvg to Subdivisions as defrred therein. 5. Byagreeing to the terns of the Teva Settlement and becoming a Releaso; the Govenmantd Endityis entitled to the benefits provided therein; irebading, if applicable, nnretanypaymen b begimdng after the Effective Date. 6. Tire Governmental Entity agrees to use any monies it receives though the Teva S ettlemend solely for the pnposes provided therein 7. Tire Governmental Entity submits to the jurisdiction of the cant in fie Governmental Entity's state where the Consent Judgment is filed for pupae limited to that caut's role as provided in,and for resolving dsptes to the extend provided in, the Ten Settlement. 1 O 76 8. The Goverzeumtal Elfin/has fie la to nfone fie Teva S et-dankaz monied final 9 Tie G© d Enfity, aS a Partpann Sbdii© © Partpang Sremal Dunn, libyb © a Rks© f© all pnposes m the Teva Settleme* ach,ling but rot Immted t© allponnogs of Sechon V (Release), and © vnth all departments, agemes, dii© bong, columnsnen thstacts, nufignentalahes of anr knn &ft© y and wry person m then' captly ekcted © app=101 t© serve an, ©f the thg©i ani anY ageng Peron © other erthty dallIMIg by © fivongh any ©f fie finnan& au any other enhtY Klerdrnned m fie dthuff© ©f Rds©; ponies thr a rekase t© the idlest extant ©f its antIonty. As a Rks© fie Govenmental Enhty lereby absohtely, gmconithonally, and mengably © t nt t©bang, file, © damn © t© cause, assut © pennd t©beI:gown fileg or clamed, or to ©Jenne seek to g tablish haighty thr any Rekased Clams &gamut any Rekned Enfity m any thrnn whatsoever Tie rekases ponied f© m fie Teva Settlement an mtemied by Released Enhtles au the Govenmental Enfity th be bmad and shall be adeneted so as t© nye the Released Erdnes the noadgt rossk bar agangt any Lab Ility @Lang Many way to Rekaed Clams au extend t© fie flu extent of the rower of the Governmental Etty t© nkase clamus Tie Teva Settlement shall be a congkte bar t© anyRekased Clam 10 Tie G© d army lenby takes © all nghts th]ifli© s ©f a Partpahrg Sbdii© or Partpang SpecnIgunct a Set nag=fie Teva Settlement II Inconrectonvnthtle nkases monied for m the Teva Settlement, eachGovenmentalErhtY ennessly waves, nkag, f© thscInges any au all ponnons, nen, au benefits cornened by any law ©f any state © ttht©y©f fie glutei States © ©tier jidiff©4 © pammple ©f comugn law, winch is =lag comparable, © eqmvalent t© § 1542 ©f the Cabfonna Clvil CodewInclueads GeneralRekese; edent A gererahelease d© rot extend t©damns that fie dit© oneleasng panynes not laggl! or suspect t©nast th his or he favor at fie the of execvng the !glean that, Slmonnby Imn or ler,woild have matenally affected his or her settlemed vnth the dbt© © nk.ased party. A Rls© may Innatler dis © fads one' than © difignnt flan those winch It Inn's, believes, © asumes th be bye wIth respect t© the Rekased Clams,but each Governmental Enhty henb y expessly wanes anl gllly, anl f© settles, rekases and thschang, nrontheEffichve Dag, any au all Rekned Clams thannayenst a5 of suchdate butwInch R4s© d© ©t Inn, or suspect t© enst, whefier tholgh cm:awn% over WU, engg neagerge or Jun&no faultwhatnever, and winch Shown matenally affect the GovenmentalErdnes' decnonto parnnate mthe Teva Settlemed 12 Notlmg hennns mtemied to modify m anyway fie terms of fie Teva S damn* to winch G© d Enfity lereby agnes T© fie C(terd thIS EleCt011 au Release Is aderpeted difigrentlyfromthe TevaSettlementmanygn red, fie Teva Settlement corthols 2 3 Exhibit K iilsderirionvsd 'gx:alDisfiet Sefement Participation Form Govenuental Entity. State: Authorized Signatory: Address 1: Address 2: City,State, Zip: Phone: Email: The govemunental entity identified above ("Governmental j?nti v"), in order to obtain and in comideretion for the benefits provided to the Govenmental Entity pursuant to the Agreement dated November 22, 2022 ("Atlwrgn Sanlanaou'l, and acting tluough the undersigned authorized official, herebyelects to participate inthe AllerganS ettlement, release all Released Claims against all Released Entities,and agrees as &lions. 1. The Governmental Entity is aware of and has reviewed the Allergen S ettlement, understands that all terms in this Election and Release have the meaning defined therein, and agrees that by this Election, tie Governmental Entity elects to participate in the Allergen S ettlenrent as provided therein. 2. Following the execution of this S ettlenrent Participation Farm, the Governmental Entity shall comply with Section IlI.B of to Allergen Settlement regarding Cessation of Litigation Activities. 3. The Governmental Entity shall,within fourteen (14) days of the Rekrence Date and prior to the filing of to Commit Judgment, file a request to dismiss with prejudice airy Released Claims that it has filed. With respect to any Released Claims pending in In ra Nasio,aal Prescription Opiate litignxtiwr, MDL No. 2804, the Govemmntal Entity authorizes the MDL Plaintiff? Executive Cornnittee to execute and file onbelalf of the Governmental Entity a Stipulation of Dismissal With Prejudice substantially in the form Sound at httos:lhationalopioidsettlenend.com. 4. The Governmental Entity agrees to the temps of the Allergen Settlement pertaining to Subdivisions and S pecialD shicts as defined therein. 5. By agreeing to the tenor of the Allergen Settlement and becomwg a Releasce, the Governmental Entity is entitled to tie benefits provided therein, hrluding, if applicable, monetarypay ents begimcng after the Effective Date. 6. The Govenuntal Entity agrees to use any worries it receives tlnatgh the Allergen Settlement solely for to purposes provided therein 1 O 55 7. The GovemmentalEnthy submuts to tle junsdthon of tle ©TM III tie GovemtheltalEnthis state wlere the onsent Judgment Is filed thr puroses Mulled th that can's lole as povIded mb and for resolvmg thsputes to tie ertentmonded m the Allelgan Settlement 8 Tie GovenvneltalEnbtyllas tle nee etforce the AllelganSettlementas movIded 9 Tie G© t Etty, a5 a Partpang Subdthslon or Partpahrg SpecIal DIsffict, heleby becomes a Rekasor for all puroses m the Allegan Settlement achdralg, but rot lraluted to, all pisi© ©f Section V (Rekese), and alorg wth alldeparthmts, agemes, dmslons, boalds, commussums, Subdthslom, dIStl[b, ralsthraneldalrbes ©f any land all attorale”, and any person ralthevollimal capaywhetler elected © app.:anted t©serve any of the thg©i an:I any agency, p& ©4 or other enfity claranng by or &lough any ©f the folegowg, and any other enfitylderdafied mule decuthonof Releasor, pondes thr a lelease to the fillest ertent©fits althonty As a Rekasor, the Govemmental afity beleby absohtelY. urromithonally, and mevocably covenants rot th b file, or clam; or th cause, assut th bamgmg., or remnt to be braght, filet or clamed, or th otlennse seek th establish habilltY for my Rekased Clams &gamut Rekased Etty m any fonth whatsoever Tle rekases movIded thr mtle Allelgan Settlement ale thended to be bload ani shallbe therpeted so a to glve the Rekased Enthes tie bmadest rossk bax agamst any habil-11-y lelathg manYwaY th Rekased Clams ani tM th the fun C(terd of the paxer of tle Goveratmental Enbty to rekase damns The Allegan Settlement shallbe a complete bax to anyRekaed Gann 10 The Govemmental Etty lenby takes on all rIghts and cbhgatom of a Partpathg Subdmslon or Partpahrg SpecIalThstact as set frail=tle AllerganSettlement II In connecton wth tle rekases movIded for In the Allegan S ettleme* each Govethental EntIty expessly waves, leleas¢, ani folever thschugesw ani allmonslom, rIghts, and belefits col&rredby my lay of mystate or temtolyof the Muted States or otlerjunsdthon, or puomk of common law, winch is undar, compaxabk, or eqmvalent to § 1542 of the alithmua 3.vil ccle,winch leads GeneralRekese;camt. A gereral release dces rot el-tend t© clams that tle crefitor or lekasulg party does not how or susrect to exist Inks or Ile favor at tle 'LIR &eXPalffilg tie lekase that, Lf lawmby I=or ler,wall hare Inatenally affected It settlelnedwIththe debtor or rekased palti A Rls© may heleatler dis © fads other than © dLffirent flan those winch ithows, believes, © assumes t© be Ale wIth respect t© the Rekased thralls, but each Govenmeltal Enhty heeby ermessly waves aml 61.11y, finally, aml thlever settles, rekases and thschuges, uron tle Effecthe Date, any and all Rekaed Clams that may C<ISt a50f5LIClidate but winch Releasors do not Imax or 51.15red th elast, wlether Oval& 3gmorame, ovemat, emoS neagerre or 011.0101110 fault whatscever, and winch, if Imaxm would matally affect tle Govenmental Enthes' deculon th pthepate m the Allergan Settlement 12 Nothrag lerem is mtenied t© modify ral any way the terms of the Aileron S ettlenent t© winch the Govenmental Enthy heleby &glees To the el-tent ths Settlement Pancmaton Foam is mtemleted duTelently (km the Allergan Settlement In any lespeth the Allegan Settlementcothols 2 3 EXHIBIT K Sub division Participation and Release Form Govenunental Entity: I State: Authorized Signatory: Address 1: Address 2: _ City,State, Zip: Phone: Email: The govenunental entity identified above ("Governmental Endo"), in order to obtain and in consideration for the berefits provided to the Governmental Entity pursuant to the Settlement Agreement dated Decenrber9, 2022("CNSSattlementl, and acting tluoughtheundersigned arthorized official, hereby elects to participate in the CVS Settlement, release all Released Claims against all Released Entities, and agrees as follows. 1. The Governmental Entity is aware of and has reviewed the CVS Settlenrend,undeatands that all terms inthis Participation and Release Form have the n anwgs defined therein, and agrees that by executing this Participation and Release Forn, fie Governmental Entity elects to participate inthre CVS Serilerrentandbecorre a Participating Subdivisionas provided therein. 2. The Governmental Entity shall promptly, and in airy event in later than 14 days after the Reference Date and prior to the filing of the Convent Judgment, dismiss with prejudice any Released Claims that it has filed. With respect to any Released Claims pending in la ra National Prescription C Eate litigation, MDL No. 2304, the Governmental Entity authorizes the Plaintiffs'fs'Executive Committee to execute and file onbehalfofthe Govemmrental Entitya Stipulation of Dismissal with Prejudice substantially in the fora Sound at htt llratinrralnpinidcettlenend rim 3. The Governmental Entity agrees to the terns of the CVS Settlement pertaining to Participating Subdivisions as defired therein. 4. By agreeing to the tenor of the CVS Settlement and becoming a Releaso; fie Govenunental Entity is entitled to the berefnts provided therein, iwluding, if applicable, monetary payments beginning after the Effective Date. 5. The Governmental Entity agrees to use any nnries it receives tluough the CVS Settlement solelyfor the punpeses provided therein. 1 0 6 The G© t Enthy subnuts t© the &ff© ©f the cowl tht1e G© d Enthy's state wlere the Consent Judgmenbs filed f© pnposes Ltd t©that comts mk as monded ani f© lesolvmg thsputes t© the ertent monded m the CVS Setfiemmt The G© d Etty hkevnse ag2e¢ t© abthate bethre the Natonal AlbMatonPaxel a5 movuled i all f© resolvmg thsplt¢ to tle ertent othewnse p! ddi the CVS Sefflemmt 7. Tie Govenmental Enfity has fie la to elicece fie CVS Sethenent ponded&mem 8. The G© d Enfity, .as a PancIpathg S, bdii©4 helebybecomes a Rks© for all Pthrosesth the CVS S ettlene* mcludmg wItIout Lttff© all plonsIons ©f Sff© XI (Rekase), 1© mill all deparinents, agemes, dansIons, b© commsslom, thsffids, nuthmentathes of my kmi &tt© y and anyperson Jen. capay ekded © appomted t©serve am/of the folegoag ani aary agency, per ory © other et ty clammg by© though am/ of the folegomg, ani my other etty Identhed m fie dthiff© of Rekaso5 Plondes f© a lekase t© the fullest extent ©fits authonty As a Rekasor, the G© d Enthy heleby absohtely, thconthonally, ani mevocably © t ©t t© bnng, file, © clam; or to callse, assut or penult t© be blough{ filed, or clamed, or to otlewnse seek t© establish habillty thr any Released Clams &gamut y Rekased Enhty m wthrym whatscenm The leleas¢ ponded for m tle CVS Setfiemmt thended by tle Pates tobe bmad all shall be mtemleted so as t© pve the Released Enthes the bloadest plbk bax aganut habthlylelatag m anyway to Released Clanns and eetmd to the ffill eetent of fie Paxer of the G© d Enthy t©rekase clanns The CVS Setfienent shallbe a complete bar t©myRekased Clam 9 The G© t Etty lereby tak¢ all It all oblcafions ©f a Partpang S, bdi $!© s set frail=tle CVS Setfiemmt 10 In conrectonwIth tle lekases ponded f© m the CVS Settlenent, each Govenmentil Etty erm¢sly waves, rekases, and f© thschuges all all plonsIons, ngth, ani benefits confmed by my lav of my state © ttht©w ©f the Unded States © other jSdiff©4 © PthcIple ©f conumn law, winch Is sunilax, conmanbk, © equwalent t© § 1542 ©f tle CalfonnaCmICcae,winch leads GenmalRekese; cdolt. A galena lelease d© not ellend t© that the crethtor or lekasmg pay-do¢ kmw © suspect to emst mins ©rlie!. favor at tle the of executhg tle lekase that Lf Imaxnbylumor ler wall have matmally affected It or he. setfienent wIth the dbt© or rekaed Pad') A Rekasor may hmeafter di © fads othm than © dffelent fiom Jose winch It Imaxs, btheves, or assthes t©b the mill lespect to tle Rekased Clanns,but esliGovenmental EnthY hueby ermessly walv¢ 611y, fthlly, and folevut& lekases and thschalges, upon tle Effecthe Date,my all all Rekaed Clams that marmst as of suchdate but wInchReka ors d© not how or suspect t©elast wletlerthaglugrorame,ovemet els% reagens © thloughm fltwhatscever, and winch if hown would matenally &ffict the Goventhmtal Erthes' deculonto pancmate mtleCVS Setfienent 2 II Nothng bele3211s 3ntencled t© modify many way the 0.m tie CVS Settlement t© winch behalf of the Govemnental Ent2tY :Gs EXHIBIT K Sub division Partici.atiun and SeleaseForm Governmental Entity: I State: Authorized Signatory: Address I: Address 2: City,State, Zip: Phone: Email: The govenurental entity identified above ("Governmental Endo"), in order to obtain and in consideration for the berefits provided to the Govennnnental Entity pursuant to the Settlement Agreement dated Decennber 9, 2022 ("Wdgreetu Senlammntl, and acting through the unniersigred autlreized official, hereby elects to participate in the Walgreens Settlement, release all Released Claims against all Released Entities, and agree as follovs. 1. The Governmental Entityis aware of and has reviewed the Walgreens Settlement,understands that all terms in this Participation and Release Form have tle manwgs defined therein, and agrees thatbyexecuting this Participationannd Release Form, tle GovemnpntalEntityelects to participate in the Walgreens Settlement and become a Participating Subdivision as provided therein. 2. The Governmental Entity shall promptly, and in army event nn later than 14 days after the Reference Date and prior to the filing of the Convent Judgment, dismiss with prejudice any Released Claims that it has filed. With respect to any Released Claims pendug ill In re Maiota l Prescription Oya'ate litigation, MDL No. 2304, the Governmental Entity authorizes the Plaintiffs'fs'Executive Committee to execute and file on behalf of the Goveuurnntd Entity a Stipulation of Dismissal with Prejudice substantially in the form bind at htt: ll:n€nnolnpinid<ontamr,d nW 3. The Govenurental Entity agrees to the terns of the Walgreens Settlement perta ni g to Participating Subdivisions as defined therein. 4. By agreeing to the terns of the Walgreens Settlenrend and becoming a Releasar, the Governmental Entity is entitled to the benefits provided therein, irebuding, if applicable, monetarypaymends beginuninng after the Effective Date. 5. The Govemrrental Entity agrees to use army monies it receives through the Walgreens Settlement solelyfor the purposes provided therein. 1 0 es 6 Tie Govenurental Enfity subnuts to the junsthchon of the cowl tht1e Govemmental Enfity's state wlere the Consent Judgmentls filed for pmoses Ltd to that coats rok as movIded ani thr resolvmg thspltes to tle ertent movIded ay the Walgrems Settlement Tie Govemmental Etty hkevnse &pees th attlate befole the Raton,' Albthafion Parel as Monded ani for resolnng thsputes th the eetent ofiennse monded ay fie Walgreem Settlement 7. Tio Gove=tal Enfity has fie nghtto etf=e the Walgreem Setdement.as ponded Jelem 8. Tio Govemmerdal Enfity, .as a Pancmathg Subdmslon hembybecomes a Rek.asor for all Imposes nolo Walpeens Settlement mcludag vntlout Imutatonall ponslom of SectonXI (Rekase), ani alorg mill all departments, agemes, dmslons, boaths, conumsnom, thstacts, nuMumelltalMes of any kaki ani attome”, and any rersonmthea ofthmal capacIty elected or appoInted to serve an/of the foregoag ani an/agency, per ory or other et ty claanng by or fluough an/ of tie folegomg, ani any oiler enfity Idelthfied m the dethuton of Rekaso5 Mondes for a lek.ase to fie thll¢t eetent of Its auflonty. As a Rek.aso5 the Govemmerdal Enhty hemby absohtely, tmcondMonally, ani mevocably covmants not th bmg, filo or clam or to callse, assut or rennt th be 1)=0* filed, or clamed, or to otlennse seek th establish habillty thr any Released Clams &gamut any Rekased auto In any fonum whatscevuThrekases movIded form the Walpeem Settlenent ale adended by the Panes tobe bmad anislellbe mtelmeted so a5 to glve the Rekased Enthes the bmadest plbk bar agamst any habilltyrelathg m anyway to Released Clams and eetmd to the eetent of fie Paxer of the G000tt000ntot auto to lelease damns The Walvems Settlemmt shall be a completebaxto anyRekased Clam 9 Ile Govenmental netto lereby tak¢ on all la ani oblcahons of a Partpang Subdmslonas set&dim tle Walpeem Settlement 10 In comectonvnth tle rekases povIded for!nth Walpeem Settlenent each Govmmental netto expessly mkases, ani folever thschuges any ani fl ponslom, rclds, and benefits col&rredby any law of any state or temtor/of tle Muted States or otlerjunsthcflon or pmcmle of conmon winch Is sanfia; compaxabk, or epavalent th § 1542 of the CalifonuaCm1 Code,whchreads GeneraIRekesq camt. A genual rekae does rot ertend to clams that the crethtor or lekasmg party does not how or susredth elast mlus or ler favor at the the of execuMg tle lelease that Lf Imaxn by hum or ler wall have matmallyaffEcted It On!!SetaPIRIltVatilfie dEbtoror mk.ased party. A Reka or may hematler thscover fads oiler than or dffelent flan tlose winch It hows, btheves, or assum¢ th be the vnth respect to the Rekased Clams, but eachGovernmental nett, lereby erm¢sly waves and filly, finally, ani folever settles, rekases ani thschuges, uronthe Effecfive Date, any ani all Released Clams that mayemst as of suchdate but winch Rekasors do rot Imo?! or 511Sped th elast vaetler tholgh 3gmorame, over cht, error, nEgligmce or travel ro fault whatsoever, and wrack If k ldmatenally affEct the Govemmental Enthes' deculonto pancmate mtle Walpeens Settlement 2 3 EXHIBIT K 4h division Partirjpatinnf orm Govenunental Entity. I State Authorized Official: Address 1: Address 2: City,State, Zip: Phone: Email: The governmental entity identified above ("Governmental Eiifi ), inorderto obtain and in consideretionfor the benefits provided to the Governmental Entity pusuantto the Settlenent Agreement dated November 14, 2022 ("Walmart Settlement'),and acting thneughthe unde:sivied authorized official,limb yelects to participate in the Walmart Sentiment,release allReleased Claims against all Released Ennbties,and agrees as follows. 1. The Govenurental Entity is aware of and has reviewed the Walmart Settlement,understands that all team inthus Election and Release have the neadngs defiled therein,and agrees tlut bythis Election, the GovenunentalEntityelects to participate inthe Wahnunt Settlenrentand become a Participating Subdivisionas provided therein. 2. The Governmental Enttityshallpronptiy,and inanyevendwithin 14 days of tie Effective Date and prior to the filhg of the Consent Judgment,dismiss withprejudice am/ Released Claims that it has filed.Withrespect to airy Released Claims pending inlnre National PrescriptionOpiate Litigation MDL No. 2304,the Govenurendal Entity authorizes the Plaintiff? Executive Committee to execute and file onbelalf ofthe Governmental Entity Stipulation of Dismissal WithPrejudice subs taidially in the formated at httos://nationalatioidsettlement.com/. 3. The Governmental Entity agrees to the tems of the Walmait Settlenrend pedainisg to Subdivisions as defnred therein. 4. By agreeing to the teens of the Wahuart Settlement andbecomisg a Releaso5 the Governmental Entity is entitled to the berefits provided therev, ireluding, ifapplicable, monetary payments begimcng after the Effective Date. 5. The Govenurental Entity agrees touse anymonie it receives 0uough the Walnut Settlement solely for the purposes provided therein. 1 O '7O ge n 6 The Govenurental Enetysubnuts to the junsthceonof the courtmthe Govenmental Etty's state when file Consentlu.dgment is filed forpuroses Imuted to that comts rok a5 pondedm anIforrescbug thsput¢ to fie ertentmovIdedm the Wahnut Settlement 7. 'Ile GovenmentalEnttylns fie ddt© etforce the Wahnut Settlenentas movnled 8 'Ile GovenmentalEntty, a5 aPartpahrg SubthnsumbIlembybecomes Rekasor for all Pmloses mule Wahnut Settlene* mcludmgbut not Imuted to all ponslom of Sect:al% (Rekase),anl alongwIthalldepannents,agencles,dmsnms,boads,comnusslom,thstnts, mstmnentahtes ©fan/landau attoneysond annelson mfien.&flail capamty elected or appomted to serve ally&fie folegomg and am/agemy.per my or other enttyclamm6 by©e.tholgh aryof the folegomg and anyother enttynlentfied mule definthon of Rekasor,movnles thr nkase to the flllestertent©fits autionty.As a Rekaso5 fie GovenmentalEnttylienbyabsolutely,mmnIthonallyonl mevocablycovenads not to bamg, file, or clam or to cause, assutorpeannt tobe blovglt filed,or damn& ©do ofielwIse seek to establislthabilltyfor myRekaed Clams agamstmyReleased Enttym themnwhalsoeverThnkases movnled for mile Wahnat Settlementan mtenled by the Pates tobebloadanl shallbe mtelmeted so as to pve the Rekased Enthes fie bloadest Poss bar.gamst myhabilltyrelatmg manywayto Rekased Clams anl e<ten1 to fie full extent of fie rower&fie GoventmmtalEnttyto nkase clams 'Ile Wahnalt SettlementsInllbe a complete bar to myRekased Clam 9 IncomectonwIththerekases povnled thrm fie Wahnalt Settlement each GovenmentalEnttyexpesslywaves, nkases, anIfonvuthschuges my and all Monslons,nghts, allberefits confenedbymylaw of mystate or temtoriof fie Uniled States or otherjunsdnton ormurmk commonlaw,wInclus sunilax, comparabk, or equIvalentto § 1542 of the Caro=CmICole,wInchreals GeneraIRelease;cant A gemral nkase does rotexten1 to clums Junin crethtororleleasug party do¢ lot how orsuspectto elast m It ©1.11ufavor&MIA the Of eXPalillIg tiEleleasethat7fflmaxnbylmnor ler,would have matenallY afficted Ins ceiersettlementwIth fie debtor or nkasedputY A Rekasormay lereafter thscover facts other thmor thffeentfromthosewInclutImaxs, btheves, or asmnes tobetvewIthrespect to He Rekased Clams,but eachGovenmental Enttylerebyexpesslywaves fnly, thnversettles, leleas¢ and thschuges, vronfie Effectve Date,anyanl all Rekased Clams thatmayemsta5 of suchdatebutwInch Rekason do not how 01'511511Pa tO C<ISt Iltfilertillailghlg2114.11EP, ovesIgId.eno5 negligence or thbvglino faultwhatsceverondwIncly Ilmmnywould matenallyaffecttle Govenmental Enthes' deculontopancmate mile Wahnut Settlement 10 NotImg lerenus mtenled to molify manyway fie teams of fie Wahnat Settleme* to winch Govenmental Enhtylereby&pees To the extent tins Electonanl Rekaeis mtemnteddLffirently fiom fie Wahnalt Settlemmt maw nspect7 the WahnutS ettlenent contols 2 3