HomeMy WebLinkAboutWORKSHOP re Opioid Settlements Regular Agenda
JEFFERSON COUNTY
BOARD OF COUNTY COMMISSIONERS
AGENDA REQUEST
TO: Board of Commissioners
Josh Peters, County Administrator
FROM: Philip C. Hunsucker, Chief Civil Deputy Prosecuting Attorney
DATE: October 20,2025
RE: Status of Pending Nine New Opioid Settlements
STATEMENT OF ISSUE:
On September 15, 2025, the Board of County Commissioners approved opting into 9 new
settlements are with Purdue Pharma and the Sackers, who own the controlling interest in
Purdue Pharma and 8 other manufacturers (the G8):
1. Alvogen, Inc.
2. Amneal Pharmaceuticals, Inc.;
3. Apotex Inc.;
4. Hikma Pharmaceuticals USA Inc.;
5. Indivior Inc.;
6. Mylan Pharmaceuticals Inc.;
7. Sun Pharmaceutical Industries, Inc.; and,
Zydus Pharmaceuticals(USA), Inc.
As with all prior settlements, all of these 9 new settlements require the all local jurisdictions to
opt into the settlements. There was an opt in form for the Purdue Pharma/Sackler settlement
and one opt in form for the G8 settlements. Both of these opt in forms were filed on behalf of
Jefferson County on September 16, 2025 and receipt was confirmed on September 17, 2025.
At the time the forms were filed, the Purdue Pharma/Sackler opt in was due on September 30,
2025 and opt in form for the G8 settlements was due October 8, 2025. These deadlines were
subsequently extended to October 30, 2025 and November 5, 2025 respectively.
1
Regular Agenda
ANALYSIS:
A memorandum from the Prosecuting Attorney's Office was provided with the agenda request
for September 15, 2025, which explains the settlements. A copy of the PAO's memorandum
is attached.
FISCAL IMPACT:
The previous opioid settlements have generated about $2 million in recoveries for the county.
With 100 percent local government participation in the settlements,the Washington Attorney
General's Office estimates that the Jefferson County's share of the 9 settlements will be
$2,556,418.26, paid out over time.
RECOMMENDATION:
Listen to a briefing from the PAO on the status of the settlements. Then, schedule another
briefing from the PAO on the settlements on November 10, 2025, after the extended deadlines
have passed.
DEPARTMENT CONTACT:
Philip C. Hunsucker, Chief Civil Deputy Prosecuting Attorney at Extension 219.
REVIEWED BY:
//
Josh D. Peters, County Administrator Date
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November 10, 2025 OPIOIDS STATUS 1
Opioid Litigation Overview ..
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(:,;" :: Jefferson County sued manufacturers, distributors, and pharmacies who created the
‘ opioid crisis in the MDL in the U.S. District Court for the Northern District of Ohio.
Keller Rohrback represents Jefferson County and other Washington municipalities on a
FCR contingent fee.
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Jefferson because created a ublic nuisance in Jefferson
Pillif County joinedbig pharmap
County and the PAO determined there was a potential for recovery.C One Washington Settlement created an allocation model for distribution of
0.4417137380% to Jefferson County of settlement amounts paid to WA State.
SBH-ASO Salish Behavioral Health Administrative Services Organization (SBH-ASO) ensures all
-- settlements are used for Opioid Abatement, which is broadly defined.
November lb 2O25 OPIOIDS STATUS
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All Settlements Must Be Used for Opioid Abatement
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"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." One
Washington Settlement at 2.
Opioid settlement funds only can be used to: "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," including those listed in
Exhibit A. One Washington Settlement, Exhibit A.
November 10,2025 OPIOIDS STATUS
a(1N
Opioid Litigation — Settlements So Far About $2 Million
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Jefferson County's Opioid Settlement Recoveries as of " `'`,
November 10 2025
Distributor Settlement $896,804.78
Janssen J&J Settlement 1h. $218,933.00
Walmart Settlement $129,632.68
Aller• en Settlement $103, 100.73
Teva Settlement $173,059.73
CVS Settlement $228,917.95
Wal • reens Settlement $248,924.30
TOTAL $1 ,999,373. 17
November 10, 2025 OPIOIDS STATUS
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0 ioid Settlements So Far — Est. Annual Payments to the Countyw ��,
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Payment I .'Sf1INU
Year Distributor Janssen WalMart•• Allergan Teva CVS Walgreens
2022 $70,766.72
2023 $36,262.38 $71,485.24 $13,265.27 $11,989.61 $14,744.11 $28,716.20
2024 $45,387.50 $27,013.38 $13,265.27 $11,989.61 $11,754.75
2025 $45,387.50 $28,043.55 $14,145.35 $11,989.61 $23,490.87 $11,417.98
2026 $45,387.50 $1,030.17 $15,606.21 $11,989.61 $23,490.87 $11,417.98
2027 $45,387.50 $1,030.17 $15,606.21 $12,257.83 $26,964.61 $11,417.98
2028 $60,295.72 $1,030.17 $15,606.21 $14,105.43 $27,636.32 $11,417.98
2029 $62,801.38 $15,606.21 $14,105.43 $26,255.60 $11,729.39
2030 $62,801.38 $14,105.43 $24,874.88 $20,350.85
2031 $52,790.90 $14,105.43 $24,852.97 $20,350.85
2032 $52,790.90 $14,105.43 $24,852.97 $20,350.85
2033 $52,790.90 $14,105.43 $20,350.85
2034 $52,790.90 $14,105.43 $20,350.85
2035 $52,790.90 $14,105.43 $20,350.85
2036 $52,790.90 $40,701.69
2037 $52,790.90
2038 $52,790.90
Totals: $896,804.78 $129,632.68 $103,100.73 $173,059.71 $228,917.95 $248,924.30
•Local Government allocation of LG Share(50%)of Washington State Base and maximum incentive Abatement
Payments less estimated Government Fee Fund withholding.
"Worst case maximum payment scenario. WalMart payments may be completed in as few as 3 years.
November 10, 2025 OPIOIDS STATUS
,ON k0
Opioid Litigation — 9 New Settlements
The Sacklers will pay $1 .5 billion and Purdue will pay approximately $900 million in the first payment,
followed by $500 million after one year, an additional $500 million after two years, and $400 million after
PURDUE three years. The AGO values the Washington payout on this settlement at "$105.6 million payable over
15 years." This settlement is the nation's largest settlement to date with companies responsible for the
opioid crisis.
QAlvogen Alvogen, Inc. to immediately pay up to approximately $19 million.
Amneal Pharmaceuticals, Inc. to pay up to approximately $74 million over 10 years, and to provide either
i mneaI approximately $177 million of its generic version of the drug Narcan or up to an additional approximately
$44 million in cash.
November 10,2025 OPIOIDS STATUS
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Opioid Litigation — 9 New Settlements
o`SEtl NC;C
SCSC Aponte Inc. to immediately pay up to approximately $65 million.
Hikma Pharmaceuticals USA Inc. to immediately pay up to approximately $98 million, and to provide
hikma. either approximately $35 million of its naloxone product or up to an additional approximately $7 million
in cash
Indivior Inc. to pay up to approximately $75 million over five years, a portion of which, at the election of
An INDIVIOR the state, could be paid in the form of Indivior's branded buprenorphine or nalmefene products with a
value of up to $140 million.
November 10,2025 OPIOIDS STATUS
,oN
Opioid Litigation — 9 New Settlements „.
III Mylan Mylan Pharmaceuticals Inc. to pay up to approximately $290 million over nine years.
SUN Sun Pharmaceutical Industries, Inc. to immediately pay up to approximately $32 million.
PHARMA
/41 zydu Zydus Pharmaceuticals (USA), Inc. to immediately pay up to approximately $15 million.
November 10, 2025 OPIOIDS STATUS
`,ON c,
Opioid Litigation — 9 New Settlements
„.
Washington Attorney General's Office (AGO): Since all cities and counties
participate in all of the settlements, local governments in Washington "will
collectively receive approximately $61 .1 million over 15 years."
The AGO estimates that the Jefferson County's share of the 9 settlements will be
$2,556,418.26, paid out over time.
The Purdue Pharma/Sackler settlement is dependent on Purdue's ongoing
bankruptcy proceedings, which could be subject to a lengthy appeals process, we
do not yet know when payments are likely to begin.
N
G8 settlements are expected to be finalized in early January 2026 with payments
potentially starting in the first quarter of 2026.
November 10, 2025 OPIOIDS STATUS
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Thank you
Questions .?
_.......
November 10,2025 10
OPIOIDS STATUS
� ON C'
it. JAMES M. KENNEDY
Jefferson County Prosecuting Attorney
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Philip C.Hunsucker,Chief Civil Deputy Prosecutor Jefferson County Prosecutor's Office
Christopher R.Ashcraft,Chief Criminal Deputy Prosecutor 1820 Jefferson Street
Melissa Pleimann,Civil Deputy Prosecutor Post Office Box 1220
Arid Speser,Civil Deputy Prosecutor Port Townsend,WA 98368
Holly Graham,Deputy Prosecutor Phone:(360)385-9180
Jeremiah Luther,Deputy Prosecutor Fax:(360)385-9186
Jeffrey Chalfant,Deputy Prosecutor www.co.Jefferson.wa.us/prosecutor
Jim Funaro,Victim Services
Lysa Phillis,Child Support Enforcement Officer
MEMORANDUM
Date: September 8, 2025
To: Board of County Commissioners
From: Philip C. Hunsucker,Chief Civil DPA
Re: Nine New Opioid Settlements — Request for Authorization to Join All
Settlements
Commissioners:
It is rare that a legal department is the source of funds for its client. Previous opioid settlements
have generated about$2 million in recoveries for the county.
Jefferson County's Opioid Settlement Recoveries as of September 5,2025
Distributor Settlement $896,804.78
Janssen(J&J) Settlement $218,933.00
Walmart Settlement $129,632.68
Allergen Settlement $103,100.73
Teva Settlement $173,059.73
CVS Settlement $228,917.95
Walgreens Settlement $248,924.30
TOTAL $1,999,373.17
Under the leadership of James Kennedy,the PAO is happy to report that 9 new nationwide opioid
settlements in principle (the 9 settlement) have been reached that likely will result in up to
$2,556,418.26 in new recoveries for the county, provided the county opts into them.
On August 28, 2025, the Washington Attorney General's Office (AGO) wrote to strongly
encourage all local jurisdictions in Washington opt in to all of the 9 settlements. According to the
September 8,2025
Page 2
Washington Attorney General's Office (AGO), if all cities and counties participate in all of the
settlements, local governments in Washington "will collectively receive approximately $61.1
million over 15 years." The AGO estimates that the Jefferson County's share of the 9 settlements
will be$2,556,418.26, paid out over time.
The PAO and the county's outside counsel, Keller Rohrback, also recommend that the county opt
in to all of the 9 settlements for the reasons discussed below.
The 9 Settlements
The 9 settlements are with Purdue Pharma and the Sacker family,who own the controlling interest
in Purdue Pharma, and another 8 manufacturers of opioids being referred to as"the G8:"
1. Alvogen, Inc.
2. Amneal Pharmaceuticals, Inc.;
3. Apotex Inc.;
4. Hikma Pharmaceuticals USA Inc.;
5. Indivior Inc.;
6. Mylan Pharmaceuticals Inc.;
7. Sun Pharmaceutical Industries, Inc.; and,
8. Zydus Pharmaceuticals(USA), Inc.
As with all prior settlements, all of the 9 settlements require the all local jurisdictions to opt into
the settlements to receive the top settlement amount. There is an opt in form for the Purdue
Pharma/Sackler settlement due September 30, 2025 and another form for all the G8 settlements
due October 8, 2025. All of necessary forms have been completed and signed by me. All are
attached. The BoCC should authorize me to send the forms to the settlement administrator on or
before September 30, 2025. These forms require a contact person for the county, and having the
PAO be the place of contact makes the most sense since we have guided all prior finalizations of
opioid settlements.
We will not know until after October 8, 2025 the level of participation of all local governments,
which affects the payouts in the settlements. Therefore,the county cannot count on the funds from
the 9 settlements yet. All the prior opioid settlements had 100% participation by local
governments. It is reasonable to expect the same with the 9 settlements.
September 8,2025
Page 3
I suggest we have a workshop to discuss the 9 settlements, including the payouts to the county the
second Monday after October 8.That will give everyone the necessary time to calculate the amount
of recovery for the 9 settlements. More detailed information on the 9 settlements is below.
Purdue/Sackler Direct Settlement and the Purdue Bankruptcy Plan
Purdue Pharma is the largest and worst-behaved opioid manufacturer. States and local
governments, including Jefferson County, have fought for many years to achieve this settlement.
According to a story by National Public Radio, the National Prescription Opiate Litigation
Plaintiffs'Executive Committee said, "After five years of litigation and three years in bankruptcy,
we are pleased that all 55 eligible states and territories have unanimously agreed to accept" the
Purdue Pharma/Sackler settlement. The county's outside counsel, Keller Rohrback, is a member
of this executive committee.
As reported to you on June 13,2025,the AGO joined the Purdue Pharma/Sacker settlement;along
with 100% of the other eligible states and territories. All the eligible states and territories agreed
to the Government Entity Settlement Agreement or"GESA,"which requires payment of a total of
$7.4 billion.
This settlement includes a direct settlement with the Sackler family and a connected new
bankruptcy plan for Purdue Pharma, which has been approved by the Bankruptcy Court.
The AGO also agreed that the Purdue Pharma/Sackler settlement is subject to the One Washington
Agreement to which Jefferson County is a party,which allocates to local governments 50%of the
settlement proceeds. Jefferson County's percentage of the recovery (0.4417137380%) is
determined by the formula in the One Washington Agreement.
The Sacklers will pay $1.5 billion and Purdue will pay approximately $900 million in the first
payment, followed by$500 million after one year, an additional $500 million after two years,and
$400 million after three years. The AGO values the Washington payout on this settlement at
"$105.6 million payable over 15 years." This settlement is the nation's largest settlement to date
with companies responsible for the opioid crisis.
You may recall that both Purdue Pharma and the Sackler family were part of an earlier effort to
settle all their opioid liability as part of the Purdue Pharma bankruptcy. The first Purdue Pharma
bankruptcy plan was approved by the bankruptcy court and was appealed up to the U.S. Supreme
Court. The Supreme Court held in a 5/4 decision that the Bankruptcy Code does not authorize a
release and injunction that,as part of a plan of reorganization under Chapter 11,effectively sought
to discharge claims against the Sacklers who were not bankruptcy debtors,without the consent of
affected claimants. Harrington v. Purdue Pharma L.P.,603 U.S.204,204, 144 S.Ct.2071,2074,
219 L.Ed.2d 721, 725 (2024). This Supreme Court decision overturned jurisprudence that
prevailed in the majority of U.S. appellate courts that promoted comprehensive resolution of
complex personal injury and property damage litigation.
September 8,2025
Page 4
Recently, the new settlement that includes the Sackler family and Purdue Pharma was reached.
The new settlement includes a separately approved new Purdue Pharma Bankruptcy Plan and a
separate direct settlement of the claims of states and local governments, who must opt in to the
settlement to participate.
Alvogen,Amneal,Apotex, Hikma, Indivior, Mylan, Sun, and Zydus(G8) Settlements
As reported to you on July 15, 2025, proposed nationwide settlement agreements have been
reached that would resolve opioid litigation brought by states, local political subdivisions, and
special districts against eight opioids manufacturers, Alvogen, Amneal, Apotex, Hikma, Indivior,
Mylan, Sun, and Zydus.
The G8 settlements will provide a maximum of approximately$720 million in cash to participating
states and subdivisions to remediate and abate the impacts of the opioid crisis. Depending on
participation by states and subdivisions,the G8 settlements require:
Alvogen, Inc.to immediately pay up to approximately$19 million;
Amneal Pharmaceuticals,Inc.to pay up to approximately$74 million over 10 years,and to provide
either approximately $177 million of its generic version of the drug Narcan or up to an additional
approximately$44 million in cash;
Apotex Inc. to immediately pay up to approximately $65 million;
Hikma Pharmaceuticals USA Inc. to immediately pay up to approximately $98 million, and to
provide either approximately $35 million of its naloxone product or up to an additional
approximately $7 million in cash;
Indivior Inc. to pay up to approximately $75 million over five years, a portion of which, at the
election of the state, could be paid in the form of Indivior's branded buprenorphine or nalmefene
products with a value of up to$140 million.;
Mylan Pharmaceuticals Inc. to pay up to approximately $290 million over nine years;
Sun Pharmaceutical Industries, Inc. to immediately pay up to approximately $32 million; and
Zydus Pharmaceuticals(USA), Inc. to immediately pay up to approximately $15 million.
The G8 settlements also contain injunctive relief governing opioid marketing,sale,distribution,or
distribution practices and require the G8 to implement safeguards to prevent diversion of
prescription opioids. According to the AGO,the"Washington reached settlement agreements with
[the G8] totaling up to $16.7 million, with payment schedules ranging from one to ten years."
(Emphasis in original.)
September 8, 2025
Page 5
Recommendations:
1. The county should opt into all of the 9 settlements before September 9, 2025.
2. The BoCC should authorize me to send the necessary opt in forms to the settlement
administrator on or before September 30, 2025.
All of the necessary forms have been completed and signed by me. All are attached to this
memorandum.
The BoCC's authorization can be done by a motion approved by the majority of the BoCC
as follows:I move to authorize Chief Civil Deputy Prosecuting Attorney Philip Hunsucker
to sign and send in the necessary opt in forms for Jefferson County to participate in the
Purdue Pharma/Sacker settlement and the G8 settlement.
3. The BoCC should have a workshop on October 20, 2025 to discuss the final payout
amounts, since total local government participation will not be known until after October
8,2025.
If you have questions or comments,please let me know.
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11110
''s"a�c't°~ Philip C. Hunsucker
Chief Civil Deputy Prosecuting Attorney
pronouns: he/him/his
Jefferson County Prosecuting Attorney's Office
P.O. Box 1220, Port Townsend, WA 98368
Ph: 360-385-9219 (direct)
Email: phunsucker@co.jefferson.wa.us
cc: James Kennedy,Ariel Speser, and Melissa Pleimann
EXHIBIT K
Subdivision Participation and Release Form
Governmental Entity: Jefferson County State: Washington
Authorized Official: Philip C. Hunsucker,Chief Civil DPA
Address 1: 1820 Jefferson Street
Address 2: P.O.Box 1220
City, State, Zip: Port Townsend, WA 98368
Phone: (360)385-9129
Email: paochiefcivil@co.jefferson.wa.us
The governmental entity identified above ("Governmental Entity"), in order to obtain and
in consideration for the benefits provided to the Governmental Entity pursuant to that certain
Governmental Entity & Shareholder Direct Settlement Agreement accompanying this
participation form (the "Agreement")', and acting through the undersigned authorized official,
hereby elects to participate in the Agreement, grant the releases set forth below, and agrees as
follows.
1. The Governmental Entity is aware of and has reviewed the Agreement, and agrees that by
executing this Participation and Release Form, the Governmental Entity elects to
participate in the Agreement and become a Participating Subdivision as provided therein.
2. The Governmental Entity shall promptly after the Effective Date, and prior to the filing of
the Consent Judgment, dismiss with prejudice any Shareholder Released Claims and
Released Claims that it has filed. With respect to any Shareholder Released Claims and
Released Claims pending in In re National Prescription Opiate Litigation,MDL No.2804,
the Governmental Entity authorizes the Plaintiffs' Executive Committee to execute and file
on behalf of the Governmental Entity a Stipulation of Dismissal with Prejudice
substantially in the form found at https://nationalopioidsettlement.com.
3. The Governmental Entity agrees to the terms of the Agreement pertaining to Participating
Subdivisions as defined therein.
4. By agreeing to the terms of the Agreement and becoming a Releasor, the Governmental
Entity is entitled to the benefits provided therein, including, if applicable, monetary
payments beginning following the Effective Date.
5. The Governmental Entity agrees to use any monies it receives through the Agreement
solely for the purposes provided therein.
6. The Governmental Entity submits to the jurisdiction of the court in the Governmental
Entity's state where the Consent Judgment is filed for purposes limited to that court's role
as and to the extent provided in, and for resolving disputes to the extent provided in, the
Capitalized terms used in this Exhibit K but not otherwise defined in this Exhibit K have the meanings given to
them in the Agreement or,if not defined in the Agreement,the Master Settlement Agreement.
K-1
Agreement. The Governmental Entity likewise agrees to arbitrate before the National
Arbitration Panel as provided in, and for resolving disputes to the extent otherwise
provided in,the Agreement.
7. The Governmental Entity has the right to enforce the Agreement as provided therein.
8. The Governmental Entity, as a Participating Subdivision, hereby becomes a Releasor for
all purposes in the Agreement, including without limitation all provisions of Article 10
(Release), and along with all departments, agencies, divisions, boards, commissions,
districts, instrumentalities of any kind and attorneys, and any person in his or her official
capacity whether elected or appointed to serve any of the foregoing and any agency,person,
or other entity claiming by or through any of the foregoing, and any other entity identified
in the definition of Subdivision Releasor,to the maximum extent of its authority, for good
and valuable consideration, the adequacy of which is hereby confirmed, the Shareholder
Released Parties and Released Parties are, as of the Effective Date, hereby released and
forever discharged by the Governmental Entity and its Subdivision Releasors from: any
and all Causes of Action,including,without limitation,any Estate Cause of Action and any
claims that the Governmental Entity or its Subdivision Releasors would have presently or
in the future been legally entitled to assert in its own right (whether individually or
collectively), notwithstanding section 1542 of the California Civil Code or any law of any
jurisdiction that is similar, comparable or equivalent thereto (which shall conclusively be
deemed waived), whether existing or hereinafter arising, in each case, (A) directly or
indirectly based on, arising out of, or in any way relating to or concerning, in whole or in
part, (i) the Debtors, as such Entities existed prior to or after the Petition Date, and their
Affiliates, (ii)the Estates, (iii)the Chapter 11 Cases, or (iv) Covered Conduct and (B) as
to which any conduct, omission or liability of any Debtor or any Estate is the legal cause
or is otherwise a legally relevant factor(each such release,as it pertains to the Shareholder
Released Parties, the "Shareholder Released Claims", and as it pertains to the Released
Parties other than the Shareholder Released Parties, the "Released Claims"). For the
avoidance of doubt and without limiting the foregoing: the Shareholder Released Claims
and Released Claims include any Cause of Action that has been or may be asserted against
any Shareholder Released Party or Released Party by the Governmental Entity or its
Subdivision Releasors (whether or not such party has brought such action or proceeding)
in any federal, state, or local action or proceeding (whether judicial, arbitral, or
administrative)(A)directly or indirectly based on, arising out of,or in any way relating to
or concerning, in whole or in part, (i)the Debtors, as such Entities existed prior to or after
the Petition Date, and their Affiliates, (ii) the Estates, (iii) the Chapter 11 Cases, or (iv)
Covered Conduct and (B)as to which any conduct, omission or liability of any Debtor or
any Estate is the legal cause or is otherwise a legally relevant factor.
9. As a Releasor, the Governmental Entity hereby absolutely, unconditionally, and
irrevocably covenants not to bring,file,or claim,or to cause,assist or permit to be brought,
filed, or claimed, or to otherwise seek to establish liability for any Shareholder Released
Claims or Released Claims against any Shareholder Released Party or Released Party in
any forum whatsoever, subject in all respects to Section 9.02 of the Master Settlement
Agreement. The releases provided for herein (including the term "Shareholder Released
K-2
Claims" and "Released Claims") are intended by the Governmental Entity and its
Subdivision Releasors to be broad and shall be interpreted so as to give the Shareholder
Released Parties and Released Parties the broadest possible release of any liability relating
in any way to Shareholder Released Claims and Released Claims and extend to the full
extent of the power of the Governmental Entity to release claims. The Agreement shall be
a complete bar to any Shareholder Released Claim and Released Claims.
10. To the maximum extent of the Governmental Entity's power, the Shareholder Released
Parties and the Released Parties are, as of the Effective Date, hereby released and
discharged from any and all Shareholder Released Claims and Released Claims of the
Subdivision Releasors.
11. The Governmental Entity hereby takes on all rights and obligations of a Participating
Subdivision as set forth in the Agreement.
12. In connection with the releases provided for in the Agreement, each Governmental Entity
expressly waives, releases, and forever discharges any and all provisions, rights, and
benefits conferred by any law of any state or territory of the United States or other
jurisdiction, or principle of common law, which is similar, comparable, or equivalent to
§ 1542 of the California Civil Code, which reads:
General Release; extent. A general release does not extend to claims that
the creditor or releasing party does not know or suspect to exist in his or her
favor at the time of executing the release that,if known by him or her,would
have materially affected his or her settlement with the debtor or released
ply.
A Releasor may hereafter discover facts other than or different from those which it knows,
believes, or assumes to be true with respect to the Shareholder Released Claims or such
other Claims released pursuant to this release, but each Governmental Entity hereby
expressly waives and fully, finally, and forever settles, releases and discharges, upon the
Effective Date, any and all Shareholder Released Claims or such other Claims released
pursuant to this release that may exist as of such date but which Releasors do not know or
suspect to exist,whether through ignorance,oversight,error,negligence or through no fault
whatsoever, and which, if known, would materially affect the Governmental Entities'
decision to participate in the Agreement.
13.Nothing herein is intended to modify in any way the terms of the Agreement, to which
Governmental Entity hereby agrees. To the extent any portion of this Participation and
Release Form not relating to the release of,or bar against,liability is interpreted differently
from the Agreement in any respect,the Agreement controls.
14.Notwithstanding anything to the contrary herein or in the Agreement, (x) nothing herein
shall (A)release any Excluded Claims or(B)be construed to impair in any way the rights
and obligations of any Person under the Agreement; and (y)the Releases set forth herein
shall be subject to being deemed void to the extent set forth in Section 9.02 of the Master
Settlement Agreement.
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I have all necessary power and authorization to execute this Participation and Release Form
on behalf of the Governmental Entity.
0. C
Signature:
Name: Philip C. Hunsucker
Title: Chief Civil Deputy Prosecuting Attorney
Date: September 8, 2025
K-4
EXHIBIT K
Secondary Manufacturers' Combined Subdivision Participation and Release Form
("Combined Participation Form")
Governmental Entity: Jefferson County State: Washington
Authorized Official: Philip C. Hunsucker
Address 1: 1820 Jefferson Street
Address 2: P.O. Box 1220
City, State,Zip: Port Townsend, WA 98368
Phone: (360) 385-9129
Email: paochiefcivil@co.jefferson.wa.us
The governmental entity identified above ("Governmental Entity"), in order to obtain and
in consideration for the benefits provided to the Governmental Entity pursuant to each of the
settlements which are listed in paragraph 1 below(each a"Secondary Manufacturer's Settlement"
and collectively, "the Secondary Manufacturers' Settlements"), and acting through the
undersigned authorized official, hereby elects to participate in each of the Secondary
Manufacturers' Settlements, release all Released Claims against all Released Entities in each of
the Secondary Manufacturers' Settlements, and agrees as follows.
1. The Participating Entity hereby elects to participate in each of the following Secondary
Manufacturers' Settlements as a Participating Entity:
a. Settlement Agreement for Alvogen, Inc. dated April 4, 2025.
b. Settlement Agreement for Apotex Corp. dated April 4, 2025.
c. Settlement Agreement for Amneal Pharmaceuticals LLC dated April 4, 2025.
d. Settlement Agreement for Hikma Pharmaceuticals USA Inc.dated April 4, 2025.
e. Settlement Agreement for Indivior Inc. dated April 4, 2025.
f. Settlement Agreement for Viatris Inc. ("Mylan")dated April 4, 2025.
h. Settlement Agreement for Sun Pharmaceutical Industries, Inc. dated April 4,2025.
i. Settlement Agreement for Zydus Pharmaceuticals (USA)Inc. dated April 4, 2025.
2. The Governmental Entity is aware of and has reviewed each of the Secondary
Manufacturers' Settlements, understands that all capitalized terms not defined in this
Combined Participation Form have the meanings defined in each of the Secondary
Manufacturers' Settlements, and agrees that by executing this Combined Participation
Form, the Governmental Entity elects to participate in each of the Secondary
Manufacturers' Settlements and become a Participating Subdivision as provided in each of
the Secondary Manufacturers' Settlements.
3. The Governmental Entity shall promptly, and in any event no later than 14 days after the
Reference Date and prior to the filing of the Consent Judgment,dismiss with prejudice any
Released Claims that it has filed against any Released Entity in each of the Secondary
Manufacturers' Settlements. With respect to any Released Claims pending in In re
National Prescription Opiate Litigation, MDL No. 2804, the Governmental Entity
K-1
authorizes the Plaintiffs' Executive Committee to execute and file on behalf of the
Governmental Entity a Stipulation of Dismissal with Prejudice for each of the
manufacturers listed in paragraph 1 above substantially in the form found at
https://nationalopioidsettlement.com/additional-settlements/.
4. The Governmental Entity agrees to the terms of each of the Secondary Manufacturers'
Settlements pertaining to Participating Subdivisions as defined therein.
5. By agreeing to the terms of each of the Secondary Manufacturers' Settlements and
becoming a Releasor, the Governmental Entity is entitled to the benefits provided therein,
including, if applicable, monetary payments beginning after the Effective Date.
6. The Governmental Entity agrees to use any monies it receives through each of the
Secondary Manufacturers' Settlements solely for the purposes provided therein.
7. The Governmental Entity submits to the jurisdiction of the court and agrees to follow the
process for resolving any disputes related to each Secondary Manufacturer's Settlement as
described in each of the Secondary Manufacturers' Settlements.'
8. The Governmental Entity has the right to enforce each of the Secondary Manufacturers'
Settlements as provided therein.
9. The Governmental Entity, as a Participating Subdivision, hereby becomes a Releasor for
all purposes in each of the Secondary Manufacturers' Settlements, including without
limitation all provisions related to release of any claims,2 and along with all departments,
agencies, divisions, boards, commissions, districts, instrumentalities of any kind and
attorneys, and any person in his or her official capacity whether elected or appointed to
serve any of the foregoing and any agency, person, or other entity claiming by or through
any of the foregoing,and any other entity identified in the definition of Releasor,provides
for a release to the fullest extent of its authority. As a Releasor, the Governmental Entity
hereby absolutely, unconditionally, and irrevocably covenants not to bring, file, or claim,
or to cause,assist or permit to be brought,filed,or claimed,or to otherwise seek to establish
liability for any Released Claims against any Released Entity in each of the Secondary
Manufacturers' Settlements in any forum whatsoever. The releases provided for in each
of the Secondary Manufacturers' Settlements are intended by the Parties to be broad and
shall be interpreted so as to give the Released Entities in each of the Secondary
Manufacturers' Settlements the broadest possible bar against any liability relating in any
' See Settlement Agreement for Alvogen, Inc. Section VII.F.2; Settlement Agreement for Apotex Corp. Section
VII.F.2; Settlement Agreement for Amneal Pharmaceuticals LLC Section VII.F.2; Settlement Agreement for Hikma
Pharmaceuticals USA Inc.Section VII.F.2;Settlement Agreement for Indivior Section VI.F.2;Settlement Agreement
for Mylan Section VI.F.2;Settlement Agreement for Sun Pharmaceutical Industries,Inc.Section VII.F.2;Settlement
Agreement for Zydus Pharmaceuticals(USA)Inc.Section VII.F.2.
2 See Settlement Agreement for Alvogen, Inc. Section XI; Settlement Agreement for Amneal Pharmaceuticals LLC
Section X; Settlement Agreement for Apotex Corp. Section XI; Settlement Agreement for Hikma Pharmaceuticals
USA Inc. Section XI; Settlement Agreement for Indivior Section X; Settlement Agreement for Mylan Section X;
Settlement Agreement for Sun Pharmaceutical Industries, Inc. Section XI; Settlement Agreement for Zydus
Pharmaceuticals(USA)Inc.Section XI.
K-2
way to Released Claims and extend to the full extent of the power of the Governmental
Entity to release claims. Each of the Secondary Manufacturers' Settlements shall be a
complete bar to any Released Claim against that manufacturer's Released Entities.
10. The Governmental Entity hereby takes on all rights and obligations of a Participating
Subdivision as set forth in each of the Secondary Manufacturers' Settlements.
11. In connection with the releases provided for in each of the Secondary Manufacturers'
Settlements, each Governmental Entity expressly waives, releases, and forever discharges
any and all provisions,rights,and benefits conferred by any law of any state or territory of
the United States or other jurisdiction, or principle of common law, which is similar,
comparable, or equivalent to § 1542 of the California Civil Code, which reads:
General Release; extent. A general release does not extend to claims that
the creditor or releasing party does not know or suspect to exist in his or her
favor at the time of executing the release that, if known by him or her would
have materially affected his or her settlement with the debtor or released
party.
A Releasor may hereafter discover facts other than or different from those which it knows,
believes,or assumes to be true with respect to the Released Claims in each of the Secondary
Manufacturers' Settlements, but each Governmental Entity hereby expressly waives and
fully,finally,and forever settles,releases and discharges,upon the Effective Date,any and
all Released Claims that may exist as of such date but which Releasors do not know or
suspect to exist,whether through ignorance,oversight,error,negligence or through no fault
whatsoever, and which, if known, would materially affect the Governmental Entities'
decision to participate in each of the Secondary Manufacturers' Settlements.
12. The Governmental Entity understands and acknowledges that each of the Secondary
Manufacturers' Settlements is an independent agreement with its own terms and
conditions. Nothing herein is intended to modify in any way the terms of any of the
Secondary Manufacturers' Settlements,to which Governmental Entity hereby agrees,aside
from the exceptions in paragraph 13 below. To the extent this Combined Participation
Form is interpreted differently from any of the Secondary Manufacturers' Settlements in
any respect,the individual Secondary Manufacturer's Settlement controls.
13. For the avoidance of doubt, in the event that some but not all of the Secondary
Manufacturers' Settlements proceed past their respective Reference Dates,all releases and
other commitments or obligations shall become void only as to those Secondary
Manufacturers' Settlements that fail to proceed past their Reference Dates.All releases and
other commitments or obligations (including those contained in this Combined
Participation Form) shall remain in full effect as to each Secondary Manufacturer's
Settlement that proceeds past its Reference Date, and this Combined Participation Form
need not be modified, returned, or destroyed as long as any Secondary Manufacturer's
Settlement proceeds past its Reference Date.
K-3
I have all necessary power and authorization to execute his Co bined Participation Form
on behalf of the Governmental Entity. �+
Signature: `
Name: Philip C. Hunsucker
Title: Chief Civil Deputy Prosecuting Attorney
Date: September 8, 2025
K-4
WASHINGTON STATE ALLOCATION AGREEMENT GOVERNING THE
ALLOCATION OF FUNDS PAID BY THE PURDUE BANKRUPTCY,SACKLERS,
AND CERTAIN OPIOID MANUFACTURERS
JULY 24,2025
This Washington State Allocation Agreement Governing the Allocation of Funds Paid by
the Purdue Bankruptcy, Sacklers, and Certain Opioid Manufacturers(the"Allocation Agreement
IV")governs the distribution of funds obtained from (1)the Purdue Bankruptcy and Sackler
Direct Claims Settlement, (2)the Alvogen Settlement, (3)the Amneal Settlement, (4)the Apotex
Settlement, (5)the Hikma Settlement, (6)the Indivior Settlement, (7)the Mylan Settlement, (8)
the Sun Settlement, and(9)the Zydus Settlement in connection with the resolution of any and all
claims by the State of Washington and the eligible counties,cities, and towns in Washington
State("Local Governments")against the Settling Entities defined in the respective Settlement
Agreements via the following settlements and bankruptcy plan of reorganization:
• (1)The 13th Amended Joint Chapter 11 Plan of Reorganization of Purdue Pharma
L.P. and its Affiliated Debtors(the"Purdue Plan") , including and amendments
thereto and all "Plan Documents"as defined therein, if the"Effective Date"as
defined therein has occurred; (2)the Master Settlement Agreement By and
Among the Master Disbursement Trust, Each of the Parties Listed On Exhibit A
Hereto, Each of the Parties Listed on Exhibit B Hereto,the Sackler Parties'
Representative and PR L.P. and any subsequent amendments, and(3)
Government Entity& Shareholder Direct Settlement Agreement and any
subsequent amendments(collectively, the"Purdue Bankruptcy and Sackler Direct
Claims Settlement").
• Alvogen Settlement Agreement dated April 4, 2025 and any subsequent
amendments("Alvogen Settlement").
• Amneal Settlement Agreement dated April 4, 2025 and any subsequent
amendments("Amneal Settlement").
• Apotex Settlement Agreement dated April 4,2025 and any subsequent
amendments("Apotex Settlement").
• Hikma Settlement Agreement dated April 4, 2025 and any subsequent
amendments("Hikma Settlement").
• Indivior Settlement Agreement dated April 4, 2025 and any subsequent
amendments("Indivior Settlement").
• Mylan Settlement Agreement dated April 4, 2025 and any subsequent
amendments("Mylan Settlement").
• Sun Settlement Agreement dated April 4,2025 and any subsequent amendments
("Sun Settlement")
1
• Zydus Settlement Agreement dated April 4, 2025 and any subsequent
amendments("Zydus Settlement")
Collectively, the Purdue Bankruptcy and Sackler Settlement, Alvogen Settlement,Amneal
Settlement, Apotex Settlement, Hikma Settlement, Indivior Settlement, Mylan Settlement, Sun
Settlement,and the Zydus Settlement shall be referred to as"the Settlements". The Settlements
can be accessed at https://nationalopioidsettlement.com/and the Purdue Plan can be accessed at
https://restructuring.ra.krol I.com/purduepharma/Home-
Docketlnfo?DocAttribute=4218&DocAttrName=PlanDisclosureStatement&MenuID=9013&Att
ributeName=Plan%20%26%20Disclosure%20Statement.The terms and definitions of each of the
respective Settlements are incorporated into this Allocation Agreement IV, and any undefined
terms in this Allocation Agreement IV are as defined in the Settlements.
1. This Allocation Agreement IV is intended to be a State-Subdivision Agreement as
defined in the Settlements. This Allocation Agreement IV shall be interpreted to
be consistent with the requirements of a State-Subdivision Agreement in the
Settlements.
2. This Allocation Agreement IV shall become effective with respect to a Settlement
only if all of the following occur:
A. The State of Washington joins such Settlement and becomes a Settling
State as provided for in the respective Settlement and, with respect to the
Purdue Bankruptcy and Sackler Settlement the State of Washington votes
in favor of the Purdue Plan or does not vote against the Purdue Plan, and
does not object to the confirmation of the Purdue Plan.
B. Such Settlement becomes final and effective and a Consent Judgment that
applies to Washington is filed and approved as provided for in the
respective Settlement. For the Purdue Bankruptcy,the"Effective Date"as
defined in the Purdue Plan has occurred.
C. The number of Local Governments that execute and return this Allocation
Agreement IV satisfies the participation requirements for a State-
Subdivision Agreement as specified in such Settlement.
3. Requirements to become a Participating Local Government. To become a
Participating Local Government that can participate in this Allocation Agreement
IV 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 IV.
B. The Local Government must do the following:
i. Release its claims against the Settling Entities identified in the
respective Settlements and agree to be bound by the terms of the
2
Settlements by timely executing and returning the Participation
Form for that Settlement and any other necessary documents.
ii. Additionally, for the Purdue Bankruptcy and Sackler Direct Claims
Settlement,either(1)vote in favor of or(2)abstain from voting on
the Chapter 11 Plan of Reorganization of Purdue Pharma L.P. and
its Affiliated Debtors,and(3)not object to the confirmation of the
Purdue Plan.
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 Local Government that is eligible to participate in this Allocation
Agreement IV 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 1. By executing
this Allocation Agreement IV,the Local Government agrees and affirms
that the MOU applies to and shall govern the LG Share, as defined below,
as modified by this Allocation Agreement IV 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. The allocations set forth in this Allocation Agreement IV apply to the following,
all of which collectively shall be referred to as the"Washington Abatement
Amount":
A. For the Purdue Bankruptcy and Sackler Settlement, all amounts
(collectively, "Washington Distributions")that are apportioned to
Washington as Estate Distributions or from the Shareholder Direct
Settlement Portion, including, without limitation, those to Washington's
State Fund, Remediation Accounts Fund, Subdivision Fund, Direct
Payment, Earned Direct Payment, and Estate Distributions for Washington
and all Participating Local Governments for the Purdue Bankruptcy and
Sackler Settlement,provided, however,that for the purposes of the
allocations set forth in this Allocation Agreement IV, Washington
Distributions shall not include State's Fees and Costs(as defined below).
This Allocation Agreement IV shall be considered a State-Subdivision
3
Agreement under the Government Entity& Shareholder Direct Settlement
Agreement.
B. For the Alvogen Settlement,the State of Washington's(1) Statewide
Payment Amount and (2)Additional Remediation Amount.
C. For the Amneal Settlement,the State of Washington's(1) State Allocation
and (2)Additional Remediation Amount.
D. For the Apotex Settlement,the State of Washington's(1) Statewide
Payment Amount and(2)Additional Remediation Amount.
E. For the Hikma Settlement, the State of Washington's(1) Statewide
Payment Amount and (2)Additional Remediation Amount.
F. For the Indivior Settlement,the State of Washington's(1) Statewide
Payment Amount and(2)Additional Remediation Amount.
G. For the Mylan Settlement,the State of Washington's(1) Statewide
Payment Amount and(2)Additional Remediation Amount.
H. For the Sun Settlement,the State of Washington's(1) Statewide Payment
Amount and(2)Additional Remediation Amount.
I. For the Zydus Settlement,the State of Washington's(1) Statewide
Payment Amount and(2)Additional Remediation Amount.
As specified in each of the Settlements,the Washington Abatement Amount will
vary depending on the percentage of Participating Local Governments and
whether there are any Later Litigating Subdivisions.
5. The(1)Amneal Settlement, (2)Hikma Settlement, and(3) Indivior Settlement
each provide 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 as specified in those Settlements 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 for each of those Settlements. If the State elects to obtain Settlement
Product for a particular Settlement,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 IV,the Settlement Product allocated to Washington shall be
considered"State Share"and shall have the cash conversion value assigned to it
in the respective Settlement Agreements, i.e.,the"Settlement Product Cash
Conversion Amount"or the"Cash Conversion Amount" identified in those
settlements.
4
6. The allocations set forth in this Allocation Agreement IV do not apply to(i)the
State Cost Fund, State AG Fees and Costs, State Expense Fund, State AG Fees,
State Direct Expenses, or any attorneys' fees, fees,costs,or expenses referred to
in the Settlement or via Fee Petitions or that are paid directly or indirectly via the
Settlements or court order to the State of Washington and/or its outside counsels
("State's Fees and Costs")or to(ii)any payments made to Participating
Subdivisions pursuant to section 5.9 of the Purdue Plan, which provides for a
Local Government Fee Fund.
7. This Allocation Agreement IV 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 IV 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
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 IV shall be used to fund the
Government Fee Fund("GFF")referred to in Paragraph 12 of this Allocation
Agreement IV 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 1 as amended and modified in this Allocation
Agreement IV.
12. For purposes of this Allocation Agreement IV only, the MOU is modified as
follows and any contrary provisions in the MOU are struck:
5
A. Exhibit A of the MOU is replaced by the Exhibit specifying the List of
Opioid Remediation Uses for each of the respective Settlements,which
generally can be found at Exhibit E 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 and shall also include any local government that notified
Judge Polster in Case No. 1:17-md-02804-DAP of its intent to sue any of
the settling entities that are covered by this Allocation Agreement.
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 and expressly includes the Chapter 11 Plan of Reorganization
of Purdue Pharma L.P.and its Affiliated Debtors.
E. The MOU is amended to add new Section C.4.g.vIV,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
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.IVi 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 MOU and 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).
6
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 Settlement 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
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.
I. 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 a 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, as well as the Purdue Plan, amounts due to
Participating Litigating Subdivisions' attorneys under this Allocation
Agreement IV 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
7
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 as well as any
payments made to Participating Subdivisions pursuant to section 5.9 of the
Purdue Plan shall be included when calculating whether the
aforementioned fifteen percent(15%)maximum percentage(or less if the
provisions of Paragraph l 0.J of this Allocation Agreement IV apply)of
any Litigating Local Government contingency fee agreement referred to
above has been met.
L. To the extent there are any excess funds in the GFF,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
IV,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 IV 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 IV 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 IV.
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.
8
18. Venue for any legal action related to this Allocation Agreement IV(separate and
apart from the MOU or the Settlements)shall be in King County, Washington.
Washington law shall govern any dispute.
19. Each party represents that all procedures necessary to authorize such parry's
execution of this Allocation Agreement IV have been performed and that such
person signing for such party has been authorized to execute this Allocation
Agreement IV.
9
FOR THE STATE OF WASHINGTON:
NICHOLAS W. BROWN
Attorney General
JEF Y .
Division C 'e
Date: —
10
FOR THE PARTICIPATING LOCAL GOVERNMENT:
Name of Participating Local Government: Jefferson County, Washington
Authorizedsignature:s g ature:
Name: Philip C. Hunsucker
Title:
Chief Civil Deputy Prosecuting Attorney
September 8. 2025
Date:
11
EXHIBIT 1
One Washington Memorandum of Understanding Between Washington Municipalities
12
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. Definitions
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
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 11 of the United States Code, irrespective of the extent to
which Participating Local Governments vote in favor of or otherwise support such
plan of reorganization.
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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
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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
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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
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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.
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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.
(iii) 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.
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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
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Government Fee Fund("GFF")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.
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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
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]
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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
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EXHIBIT A
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
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
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
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
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
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
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
(PDMPs), 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
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
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
PART THREE: OTHER STRATEGIES
I. FIRST RESPONDERS
In addition to items C8, D1 through D7, H1, 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
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
Local
County Government %Allocation
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
Local
County Government %Allocation
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 la ma
Kelso 0.1331145270%
Longview 0.6162736905%
Woodland***
County Total: 2.4720828165%
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
Local
County Government %Allocation
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: 1.2010866076%
*** - Local Government appears in multiple counties B-3
EXHIBIT B
Local
County Government %Allocation
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
Local
County Government %Allocation
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 0.0435834-5-01%
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
Local
County Government %Allocation
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
Vader
Winlock
County Total: 1.2687367832%
*** - Local Government appears in multiple counties B-6
EXHIBIT B
Local
County Government %Allocation
Lincoln County
Lincoln County 0.1712669645%
Almira
Creston
Davenport
Harrington
Odessa
Reardan
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
Okanogan
Omak
Oroville
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
Local
County Government %Allocation
Pend Oreille County
Pend Oreille County 0.2566374940%
Cusick
lone
Metaline
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
Steilacoo_m
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
Local
County Government %Allocation
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
Darrington
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
Local
County Government %Allocation
Spokane County
Spokane County 5.5623859292%
Airway Heights
Cheney 0.1238454349%
Deer Park
Fairfield
Latah
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%
Cathiamet
County Total: 0.0596582197%
*** - Local Government appears in multiple counties B-10
EXHIBIT B
Local
County Government %Allocation
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%
Rosalia
St.John
Tekoa
Uniontown
County Total: 0.4841643328%
*** - Local Government appears in multiple counties B-11
EXHIBIT B
Local
County Government %Allocation
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
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.