HomeMy WebLinkAboutResolution - 2021-R0446 - Texas Opioid Abatement Fund Council & Settlement Allocation Term Sheet 11.1.21Resolution No. 2021-R0446
Item No. 6.9
November 1, 2021
RESOLUTION
BE IT RESOLVED BY THE CITY COUNCIL OF THE CITY OF LUBBOCK:
THAT the Mayor of the City of Lubbock is hereby authorized and directed to
execute for and on behalf of the City of Lubbock, the Adoption of the Texas Opioid
Abatement Fund Council and Settlement Allocation Term Sheet, and related documents
including any settlement Participation Forms. Said Agreement is attached hereto and
incorporated in this resolution as if fully set forth herein and shall be included in the
minutes of the City Council.
Passed by the City Council on November 1, 2021
DANIEL M. P E, MAYOR
ATTEST:
Retie a Garza, City Se et
APPROVED AS TO CONTENT:
W. Jarre Atkinson, City Manager
APPROVED AS TO FORM:
AfAarltdell, Chief Litigation Attorney
;s/RES.Agrmt-Opioid Class Action
13, 2021
Resolution No. 2021-R0446
ADOPTION OF TEXAS ABATEMENT FUND
COUNCIL AND SETTLEMENT ALLOCATION TERM SHEET
WHEREAS, CITY OF LUBBOCK obtained information indicating that certain drug
companies and their corporate affiliates, parents, subsidiaries, and such other defendants as may
be added to the litigation (collectively, "Defendants") have engaged in fraudulent and/or reckless
marketing and/or distribution of opioids that have resulted in addictions and overdoses; and
WHEREAS, these actions, conduct and misconduct have resulted in significant financial
costs to the City of Lubbock; and
WHEREAS, on May 13, 2020, the State of Texas, through the Office of the Attorney
General, and a negotiation group for Texas political subdivisions entered into an Agreement
entitled Texas Opioid Abatement Fund Council and Settlement Allocation Term Sheet (hereafter,
the Texas Term Sheet) approving the allocation of any and all opioid settlement funds within the
State of Texas. The Texas Tenn Sheet is attached hereto; and
WHEREAS, Special Counsel and the State of Texas have recommended that local
governmental entities in the State of Texas support the adoption and approval of the Texas Term
Sheet in its entirety.
NOW, THEREFORE, BE IT RESOLVED that we, the City of Lubbock:
1. Support the adoption and approval the Texas Term Sheet in its entirety; and
2. finds as follows:
a. There is a substantial need for repayment of opioid-related expenditures and
payment to abate opioid-related harms in and about the City of Lubbock; and
b. The City of Lubbock supports in its entirety and hereby adopts the allocation
method for opioid settlement proceeds as set forth in the STATE OF TEXAS AND
TEXAS POLITICAL SUBDIVISIONS' OPIOID ABATEMENT FUND
COUNCIL AND SETTLEMENT ALLOCATION TERM SHEET, attached
hereto. The City of Lubbock understands that the purpose of this Texas Term Sheet
is to permit collaboration between the State of Texas and Political Subdivisions to
explore and potentially effectuate resolution of the Opioid Litigation against
Pharmaceutical Supply Chain Participants as defined therein. The City of Lubbock
understands that an additional purpose is to create an effective means of distributing
any potential settlement funds obtained under this Texas Term Sheet between the
State of Texas and Political Subdivisions in a manner and means that would
promote an effective and meaningful use of the funds in abating the opioid epidemic
in the City and throughout Texas.
EXECUTED on this 1st day of
November
By:
DANIEL M
2021.
MAYOR
TEXAS OPIOID ABATEMENT FUND COUNCIL AND
SETTLEMENT ALLOCATION TERM SHEET
WHEREAS, the people of the State of Texas and its communities have been harmed
through the National and Statewide epidemic caused by licit and illicit opioid use
and distribution within the State of Texas; and now,
WHEREAS, the State of Texas, though its elected representatives and counsel,
including the Honorable Ken Paxton, Attorney General of the State of Texas, and
certain Political Subdivisions, through their elected representatives and counsel, are
separately engaged in litigation seeking to hold those entities in the supply chain
accountable for the damage caused; and now,
WHEREAS, the State of Texas, through its Attorney General and its Political
Subdivisions, share a common desire to abate and alleviate the impacts of the
epidemic throughout the State of Texas; and now,
THEREFORE, the State of Texas and its Political Subdivisions, subject to
completing formal documents effectuating the Parties' agreements, enter into this
State of Texas and Texas Political Subdivisions' Opioid Abatement Fund Council
and Settlement Allocation Tenn Sheet (Texas Term Sheet) relating to the allocation
and use of the proceeds of any Settlements as described.
A. Definitions
As used in this Texas Tenn Sheet:
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1. "The State" shall mean the State of Texas acting through its Attorney
General.
2. "Political Subdivision(s)" shall mean any Texas municipality and county.
3. "The Parties" shall mean the State of Texas, the Political Subdivisions, and
the Plaintiffs' Steering Committee and Liaison Counsel (PSC) in the Texas
Opioid MDL, In Re: Texas Opioid Litigation, MDL No. 2018-63587, in
the 152d District Court of Harris County, Texas.
4. "Litigating Political Subdivision" means a Political Subdivision that filed
suit in the state courts of the State of Texas prior to the Execution Date of
this Agreement, whether or not such case was transferred to Texas Opioid
MDL, or removed to federal court.
5. "National Fund" shall mean any national fund established for the benefit
of the Texas Political Subdivisions. In no event shall any National Fund
be used to create federal jurisdiction, equitable or otherwise, over the
Texas Political Subdivisions or those similarly situated state -court litigants
who are included in the state coalition, nor shall the National Fund require
participating in a class action or signing a participation agreement as part
of the criteria for participating in the National Fund.
6. "Negotiating Committee" shall mean a three -member group comprising
four representatives for each of (1) the State; (2) the PSC; and (3) Texas'
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Political Subdivisions (collectively, "Members"). The State shall be
represented by the Texas Attorney General or his designees. The PSC shall
be represented by attorneys Mikal Watts, Jeffrey Simon, Dara Hegar, Dan
Downey, or their designees. Texas' Political Subdivisions shall be
represented by Clay Jenkins (Dallas County Judge), Terrence O'Rourke
(Special Assistant County Attorney, Harris County), Nelson Wolff (Bexar
County Judge), and Nathaniel Moran (Smith County Judge) or their
designees.
7. "Settlement" shall mean the negotiated resolution of legal or equitable
claims against a Pharmaceutical Supply Chain Participant that includes the
State and Political Subdivisions.
8. "Opioid Funds" shall mean monetary amounts obtained through a
Settlement as defined in this Texas Term Sheet.
8. "Approved Purpose(s)" shall mean those uses identified in Exhibit A
hereto.
9. "Pharmaceutical Supply Chain" shall mean the process and channels
through which opioids or opioids products are manufactured, marketed,
promoted, distributed, or dispensed.
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10."Pharmaceutical Supply Chain Participant" shall mean any entity that
engages in or has engaged in the manufacture, marketing, promotion,
distribution, or dispensing of an opioid analgesic.
11. "Texas Opioid Council" shall mean the Council described in Exhibit A
hereto, which has the purpose of ensuring the funds recovered by Texas
(through the joint actions of the Attorney General and the Texas Political
Subdivisions) are allocated fairly and spent to remediate the opioid crisis
in Texas, using efficient and cost-effective methods that are directed to the
hardest hit regions in Texas while also ensuring that all Texans benefit
from prevention and recovery efforts.
B. Allocation of Settlement Proceeds
1. All Opioid Funds distributed in Texas shall be divided with 15° o going to
Political Subdivisions ("Subdivision Share"), 70% to the Texas Opioid
Abatement Fund through the Texas Opioid Council (Texas Abatement
Fund Share) identified and described on Exhibits A and C hereto, and 15%
to the Office of the Texas Attorney General as Counsel for the State of
Texas ("State Share"). Out of the Texas Opioid Abatement Fund,
reasonable expenses up to 110 shall be paid to the Texas Comptroller for
the administration of the Texas Opioid Council pursuant to the Opioid
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Abatement Fund (Texas Settlement) Opioid Council Agreement, Exhibit
A hereto.
2. The Subdivisions Share shall be allocated in accordance with the division
of proceeds on Exhibit B hereto.
3. The Texas Abatement Fund Share shall be allocated to the Opioid Council
to be apportioned in accordance with the guidelines of Exhibit A, and
Exhibit C hereto.
4. In the event a Subdivision merges, dissolves, or ceases to exist, the
allocation percentage for that Subdivision shall be redistributed as directed
by the settlement document, and if not specified, equitably based on the
composition of the successor Subdivision. If a Subdivision for any reason
is excluded from a specific settlement, the allocation percentage for that
Subdivision shall be redistributed as directed by the settlement document,
and if not specified, equitably among the participating Subdivisions.
5. Funds obtained from parties unrelated to the Litigation, via grant, bequest,
gift or the like, separate and distinct from the Litigation, may be directed
to the Texas Opioid Council and disbursed as set forth below.
6. The Subdivision share shall be initially deposited and paid in cash directly
to the Subdivision under the authority and guidance of the Texas MDL
Court, who shall direct any Settlement funds to be held in trust in a
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segregated account to benefit the Subdivisions and to be promptly
distributed as set forth herein and in accordance with Exhibit B.
7. Nothing in this Texas Term Sheet should alter or change any Subdivision's
rights to pursue its own claim. Rather, the intent of this Texas Term Sheet
is to join all parties to disburse settlement proceeds from one or more
defendants to all parties participating in that settlement within Texas.
8. Opioid Funds from the Texas Abatement Fund Share shall be directed to
the Texas Opioid Council and used in accordance with the guidelines as
set out on Exhibit A hereto, and the Texas Abatement Fund Share shall be
distributed to the Texas Opioid Council under the authority and guidance
of the Texas MDL Court, consistent with Exhibits A and C, and the by-
laws of the Texas Opioid Council documents and disbursed as set forth
therein, including without limitation all abatement funds and the 1%
holdback for expenses.
9. The State of Texas and the Political Subdivisions understand and
acknowledge that additional steps may need to be undertaken to assist the
Texas Opioid Council in its mission, at a predictable level of funding,
regardless of external factors.
C. Payment of Counsel and Litigation Expenses
C
1. Any Master Settlement Agreement settlement will govern the payment of
fees and litigation expenses to the Parties. The Parties agree to direct
control of any Texas Political Subdivision fees and expenses to the "Texas
Opioid Fee and Expense Fund," which shall be allocated and distributed
by the Texas MDL Court, In re: Texas Opioid Litigation, MDL No. 2018-
63587, in the 152nd District Court of Harris County, Texas, and with the
intent to compensate all counsel for Texas Political Subdivisions who have
not chosen to otherwise seek compensation for fees and expenses from any
federal MDL common benefit fund.
2. The Parties agree that no portion of the State of Texas 150.6 allocation
share from any settlement shall be administered through the National
Fund, the Texas MDL Court, or Texas Opioid Fee and Expense Fund,
but shall be directed for payment to the State of Texas by the State of
Texas.
3. The State of Texas and the Texas Political Subdivisions, and their
respective attorneys, agree that all fees — whether contingent, hourly,
fixed or otherwise — owed by the Texas Political Subdivisions shall be
paid out of the National Fund or as otherwise provided for herein to the
Texas Opioid Fee and Expense Fund to be distributed by the 152nd
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District Court of Harris County, Texas pursuant to its past and future
orders.
4. From any opioid-related settlements with McKesson, Cardinal Health,
ABDC, and Johnson & Johnson, and for any future opioid-related
settlements negotiated, in whole or in part, by the Negotiating
Committee with any other Pharmaceutical Supply Chain Participant,
the finds to be deposited in the Texas Opioid Fee and Expense Fund
shall be 9.39250.0 of the combined Texas Political Subdivision and
Texas Abatement Fund portions of each payment (annual or otherwise)
to the State of Texas for that settlement, plus expenses from the
National Fund, and shall be sought by Texas Political Subdivision
Counsel initially through the National Fund. The Texas Political
Subdivisions' percentage share of fees and expenses from the National
Fund shall be directed to the Texas Opioid Fee and Expense Fund in
the Texas MDL, as soon as is practical, for allocation and distribution
in accordance with the guidelines herein.
S. If the National Fund share to the Texas Political Subdivisions is
insufficient to cover the guaranteed 9.3925%, plus expenses from the
National Fund, per subsection 4, immediately supra, or if payment from
the National Fund is not received within 12 months after the date the
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first payment is made by the Defendants pursuant to the settlement, then
the Texas Political Subdivisions shall recover up to 12.5% of the Texas
Political Subdivision Share to make up any difference.
6. If the National Fund and the Texas Political Subdivision share are
insufficient to cover the guaranteed 9.3925%, plus expenses from the
National Fund, or if payment from the National Fund is not received
within 12 months after the date the first payment is made by the
Defendants pursuant to the settlement, then the Texas Political
Subdivisions shall recover up to 8.75°0 of the Abatement Fund Share
to make tip any difference. In no event shall the Texas Political
Subdivision share exceed 9.39250o of the combined Texas Political
Subdivision and Texas Abatement Fund portions of any settlement,
plus expenses from the National Fund. In the event that any payment
is received from the National Fund such that the total amount in fees
and expenses exceeds 9.39251-0, the Texas Political Subdivisions shall
return any amounts received greater than 9.3925% of the combined
Texas Political Subdivision and Texas Abatement Fund portions to
those respective Funds.
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7. For each settlement utilizing a National Fund, the Texas Political
Subdivisions need only make one attempt at seeking fees and expenses
there.
8. The total amount of the Texas Opioid Fee and Expense Fund shall be
reduced proportionally, according to the agreed upon allocation of the
Texas Subdivision Fund, for any Texas litigating Political Subdivision
that (1) fails to enter the settlement; and (2) was filed in Texas state
court, and was transferred to the Texas MDL (or removed before or
during transfer to the Texas MDL) as of the execution date of this
Agreement.
D. The Texas Opioid Council and Texas Abatement Fund
The Texas Opioid Council and Texas Abatement Fund is described in detail
at Exhibit A, incorporated herein by reference.
E. Settlement Negotiations
1. The State and Negotiating Committee agree to inform each other in
advance of any negotiations relating to a Texas -only settlement with a
Pharmaceutical Supply Chain Participant that includes both the State and
its Political Subdivisions and shall provide each other the opportunity to
participate in all such negotiations. Any Texas -only Settlement agreed to
with the State and Negotiating Committee shall be subject to the approval
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of a majority of litigating Political Subdivisions. The Parties further agree
to keep each other reasonably informed of all other global settlement
negotiations with Phannaceutical Supply Chain Participants and to include
the Negotiating Committee or designees. Neither this provision, nor any
other, shall be construed to state or imply that either the State or the
Negotiating Committee is unauthorized to engage in settlement
negotiations with Phannaceutical Supply Chain Participants without prior
consent or contemporaneous participation of the other, or that either party
is entitled to participate as an active or direct participant in settlement
negotiations with the other. Rather, while the State's and Negotiation
Committee's efforts to achieve worthwhile settlements are to be
collaborative, incremental stages need not be so.
2. Any Master Settlement Agreement (MSA) shall be subject to the approval
and jurisdiction of the Texas MDL Court.
3. As this is a Texas -specific effort, the Committee shall be Chaired by the
Attorney General. However, the Attorney General, or his designees, shall
endeavor to coordinate any publicity or other efforts to speak publicly with
the other Committee Members.
4. The State of Texas, the Texas MDL Plaintiff's Steering Committee
representatives, or the Political Subdivision representatives may withdraw
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from coordinated Settlement discussions detailed in this Section upon 10
business days' written notice to the remaining Committee Members and
counsel for any affected Pharmaceutical Supply Chain Participant. The
withdrawal of any Member releases the remaining Committee Members
from the restrictions and obligations in this Section.
5. The obligations in this Section shall not affect any Party's right to proceed
with trial or, within 30 days of the date upon which a trial involving that
Party's claims against a specific Phannaceutical Supply Chain Participant
is scheduled to begin, reach a case specific resolution with that particular
Pharmaceutical Supply Chain Participant.
F. Amendments
The Parties agree to make such amendments as necessary to implement the
intent of this agreement.
Acknowledgment of Agreement
We, the undersigned, have participated in the drafting of the above Texas
Term Sheet, including consideration based on comments solicited from Political
Subdivisions. This document has been collaboratively drafted to maintain all
individual claims while allowing the State and its Political Subdivisions to cooperate
in exploring all possible means of resolution. Nothing in this agreement binds any
party to any specific outcome. Any resolution under this document will require
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acceptance by the State of Texas and a majority of the Litigating Political
Subdivisions.
We, the undersigned, hereby accept the STATE OF TEXAS AND TEXAS
POLITICAL SUBDIVISIONS' OPIOID ABATEMENT FUND COUNCIL AND
SETTLEMENT ALLOCATION TERM SHEET. We understand that the purpose of
this Texas Term Sheet is to permit collaboration between the State of Texas and
Political Subdivisions to explore and potentially effectuate earlier resolution of the
Opioid Litigation against Pharmaceutical Supply Chain Participants. We also
understand that an additional purpose is to create an effective means of distributing
any potential settlement funds obtained under this Texas Term Sheet between the
State of Texas and Political Subdivisions in a manner and means that would promote
an effective and meaningful use of the funds in abating the opioid epidemic
throughout Texas.
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Executed this 13 day of May, 2020.
FOR THE STATE OF TEXAS:
I **';'
KENNETH PAXTON, JR.
ATTORNEY GENERAL
FOR THE SUBDIVISIONS
AND TEXAS MDL PSC:
MIKAL WATTS
WATTS GUERRA LLP
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SiMON G ENSTONE PANA1'IER, PC
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EXHIBIT A
Opioid Abatement Fund (Texas) Settlement
Opioid Council
As part of the settlement agreement and upon its execution, the parties will form the Texas Opioid
Council (Council) to establish the framework that ensures the funds recovered by Texas (through
the joint actions of the Attorney General and the state's political subdivisions) are allocated fairly
and spent to remediate the opioid crisis in Texas, using efficient and cost-effective methods that
are directed to the hardest hit regions in Texas while also ensuring that all Texans benefit from
prevention and recovery efforts.
I. Structure
The Council will be responsible for the processes and procedures governing the spending of the
finds held in the Texas Abatement Fund, which will be approximately 70% of all funds obtained
through settlement and or litigation of the claims asserted by the State and its subdivisions in the
investigations and litigation related to the manufacturing, marketing, distribution, and sale of
opioids and related pharmaceuticals.
Money paid into the abatement fiend will be held by an independent administrator, who shall be
responsible for the ministerial task of releasing funds solely as authorized below by the Council,
and accounting for all payments to and from the fund.
The Council will be formed when a court of competent jurisdiction enters an order settling the
matter, including any order of a bankruptcy court. The Council's members must be appointed
within sixty (60) days of the date the order is entered.
►A
The Council shall be comprised of the following thirteen (13) members:
1. Statewide Members.
Six members appointed by the Governor and Attorney General to represent the State's
interest in opioid abatement. The statewide members are appointed as follows:
a. The Governor shall appoint three (3) members who are licensed health
professionals with significant experience in opioid interventions;
b. The Attorney General shall appoint three (3) members who are licensed
professionals with significant experience in opioid incidences; and
c. The Governor will appoint the Chair of the Council as a non -voting member.
The Chair may only cast a vote in the event there is a tie of the membership.
2. Regional Members.
Six (6) members appointed by the State's political subdivisions to represent their
designated Texas Health and Human Services Commission "HHSC" Regional Healthcare
Partnership (Regions) to ensure dedicated regional, urban, and rural representation on the
Council. The regional appointees must be from either academia or the medical profession
with significant experience in opioid interventions. The regional members are appointed as
follows:
a. One member representing Regions 9 and 10 (Dallas Ft -Worth);
b. One member representing Region 3 (Houston);
c. One member representing Regions 11, 12, 13, 14, 15, 19 (West Texas);
d. One member representing Regions 6, 7, 8, 16 (Austin -San Antonio);
e. One member representing Regions 1, 2, 17, 18 (East Texas); and
f. One member representing Regions 4, 5, 20 (South Texas).
All members of the Council are appointed to serve staggered two-year terms, with the terms of
members expiring February 1 of each year. A member may serve no more than two consecutive
terms, for a total of four consecutive years. For the first term, four (4) members (two (2) statewide
and two (2) for the subdivisions) will serve a three-year term. A vacancy on the Council shall be
filled for the unexpired tenn in the same manner as the original appointment. The Governor will
appoint the Chair of the Council who will not vote on Council business unless there is a tic vote,
and the subdivisions will appoint a Vice -Chair voting member from one of the regional members.
I. Administration
The Council is attached administratively to the Comptroller. The Council is an
independent, quasi -governmental agency because it is responsible for the statewide
distribution of the abatement settlement funds. The Council is exempt from the following
statutes:
a. Chapter 316 of the Government Code (Appropriations);
b. Chapter 322 of the Government Code (Legislative Budget Board);
c. Chapter 325 of the Government Code (Sunset);
d. Chapter 783 of the Government Code (Uniform Grants and Contract
Management):
e. Chapter 2001 of the Government Code (Administrative Procedure);
f. Chapter 2052 of the Government Code (State Agency Reports and Publications);
g. Chapter 2261 of the Government Code (State Contracting Standards and
Oversight);
h. Chapter 2262 of the Government Code (Statewide Contract Management);
2
i. Chapter 262 of the Local Government Code (Purchasing and Contracting
Authority of Counties); and
j. Chapter 271 of the Local Government Code (Purchasing and Contracting
Authority of Municipalities, Counties, and Certain Other Local Governments).
1. Ti•ansparenct•
The Council will abide by state laws relating to open meetings and public information,
including Chapters 551 and 552 of the Texas Government Code.
i. The Council shall hold at least four regular meetings each year. The Council may
hold additional meetings on the request of the Chair or on the written request of
three members of the council. All meetings shall be open to the public, and public
notice of meetings shall be given as required by state law.
ii. The Council may convene in a closed, non-public meeting:
a. if the Commission must discuss:
1. Negotiation of contract awards; and
2. Matters specifically exempted from disclosure by federal and
state statutes.
b. All minutes and documents of a closed meeting shall remain under seal,
subject to release only order of a court of competent jurisdiction.
3. Authorih-
The Council does not have rulemaking authority. The terms of each Judgment, Master
Settlement Agreement, or any Bankruptcy Settlement for Texas control the authority of
the Council and the Council may not stray outside the bounds of the authority and power
vested by such settlements. Should the Council require legal assistance in determining
their authority, the Council may direct the executive director to seek legal advice from the
Attorney General to clarify the issue.
The independent administrator will set aside up to one (1) percent of the settlement funds for the
administration of the Council for reasonable costs and expenses of operating the foregoing duties,
including educational activities.
1. Execut&e Director
The Comptroller will employ the executive director of the Council and other personnel as
necessary to administer the duties of the Council and carry out the functions of the Council.
The executive director must have at least 10 years of experience in government or public
administration and is classified as a Director V'1330 under the State Auditor's State
Classification. The Comptroller will pay the salaries of the Council employees from the
one (I) percent of the settlement fitnds set aside for the administration of the Council. The
Comptroller will request funds from the Texas Abatement Fund Point of Contact.
1. Ti-ave/ Rei►nbursen:ent
A person appointed to the Council is entitled to reimbursement for the travel expenses
incurred in attending Council duties. A member of the Council may be reimbursed for
actual expenses for meals, lodging, transportation, and incidental expenses in accordance
with travel rates set by the federal General Services Administration.
11. Duties/Roles
It is the duty of the Council to determine and approve the opioid abatement strategies and finding
awards.
FAMWAI n el KolvTo W."I.
The Council will develop the approved Texas list of abatement strategies based on but not limited
to the existing national list of opioid abatement strategies (see attached Appendix A) for
implementing the Texas Abatement Fund.
1. The Council shall only approve strategies which are evidence -informed strategies.
2. The Texas list of abatement strategies must be approved by majority vote. The majority
vote must include a majority from both sides of the statewide members and regional
members in order to be approved, e.g., at least four (4) of six (6) members on each side.
The Council will determine a single point of contact called the Abatement Fund Point of Contact
(POC) to be established as the sole entity authorized to receive requests for funds and approve
expenditures in Texas and order the release of funds from the Texas Abatement Fund by the
independent administrator. The POC may be an independent third party selected by the Council
with expertise in banking or financial management. The POC will manage the Opioid Council
Bank Account (Account). Upon a vote, the Council will direct the POC to contact the independent
administrator to release funds to the Account. The Account is outside the State Treasury and not
managed by any state or local officials. The POC is responsible for payments to the qualified
entities selected by the Council for abatement fund awards. The POC will submit a monthly
financial statement on the Account to the Council.
An independent auditor appointed by the Council will perform an audit on the Account on an
annual basis and report its findings, if any, to the Council.
L�91OUTS!"., I l e
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The Council is the sole decision -maker on the funding allocation process of the abatement funds.
The Council will develop the application and award process based on the parameters outlined
below. An entity seeking funds from the Council mast apply for funds; no funds will be awarded
without an application. The executive director and personnel may assist the Council in gathering
and compiling the applications for consideration; however, the Council members are the sole
decision -makers of awards and funding determination. The Council will use the following
processes to award funds:
Statewide Funds. The Council will consider, adopt and approve the allocation
methodology attached as Exhibit C, based upon population health data and prevalence
of opioid incidences, at the Council's initial meeting. Adoption of such methodology
will allow each Region to customize the approved abatement strategies to fit its
communities' needs. The statewide regional funds will account for seventy-five (75)
percent of the total overall funds, less the one (1) percent administrative expense
described herein.
2. Taigeted Fund.5. Each Region shall reserve twenty-five (25) percent of the overall
funds, for targeted interventions in the specific Region as identified by opioid incidence
data. The Council must approve on an annual basis the uses for the targeted abatement
strategies and applications available to every Region, including education and outreach
programs. Each Region without approved uses for the targeted funds from the Council,
based upon a greater percentage of opioid incidents compared to its population, is
subject to transfer of all or a portion of the targeted funds for that Region for uses based
upon all Regions' targeted funding needs as approved by the Council on an annual basis.
3. Annual Allocation. Statewide regional finds and targeted funds will be allocated on an
annual basis. If a Region lapses its funds, the funds will be reallocated based on all
Regions' funding needs.
The Council will establish an appeal process to pen -nit the applicants for funding (state or
subdivisions) to challenge decisions by the Council -designated point of contact on requests for
funds or expenditures.
1. To challenge a decision by the designated point of contact, the State or a subdivision
must file an appeal with the Council within thirty (30) days of the decision. The Council
then has thirty (30) days to consider and rule on the appeal.
2. If the Council denies the appeal, the party may file an appeal with the state district court
of record where the final opioid judgment or Master Settlement Agreement is filed. The
Texas Rules of Civil Procedure and Rules of Evidence will govern these proceedings.
The Council may request representation from the Attorney General in these proceedings.
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In making its determination, the state district court shall apply the same clear error
standards contained herein that the Council must follow when rendering its decision.
3. The state district court will make the final decision and the decision is not appealable.
4. Challenges will be limited and subject to penalty if abused.
5. Attorneys' fees and costs are not recoverable in these appeals.
The Council may detennine that a percentage of the funds in the Abatement Fund from the targeted
funds be used to develop an education and outreach program to provide materials on the
consequences of opioid drug use, prevention and interventions. Any material developed will
include online resources and toolkits for communities.
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Exhibit A
TEXAS SUBDIVISION AND SPECIAL DISTRICT
ELECTION AND RELEASE FORM
This Election and Release Form for Texas Participating Subdivisions, resolves opioid-
related Claims against Endo/Par under the terms and conditions set forth in the Endo/Par Texas
State -Wide Opioid Settlement Agreement between Endo/Par, the State of Texas, and the Counties
of Dallas, Bexar, Harris and Tarrant (the "Agreement"), the provisions of which are here
incorporated by reference in their entirety. Upon executing this Election and Release Form, a
Participating Subdivision agrees that, in exchange for the consideration described in the
Agreement, the Participating Subdivision is bound by all the terms and conditions of the
Agreement, including but not limited to the Release found in Section VII of the Agreement and
the provisions concerning participation by Subdivisions or Special Districts in Section VIII, and
the Participating Subdivision and its signatories expressly represent and warrant on behalf of
themselves that they have, or will have obtained on or before the Effective Date or on or before
the execution of this Election and Release Form if executed after the Effective Date, the authority
to settle and release, to the maximum extent of the Subdivision's and Special District's power, all
Released Claims related to Covered Conduct. If this Election and Release Form is executed on or
before the Initial Participation Date, the Participating Subdivision shall dismiss Endo/Par and all
other Released Entities with prejudice from all pending cases in which the Participating
Subdivision has asserted Covered Claims against Endo/Par or a Released Entity no later than the
Initial Participation Date. If this Election and Release Form is executed after the Initial
Participation Date, the Participating Subdivision shall dismiss Endo/Par and all other Released
' The Agreement defines a "Participating Subdivision" as a Subdivision or Special District that sips this Election
and Release Form and meets the requirements for becoming a Participating Subdivision under subsection V1 II.A. of
the Agreement.
A-1
745274877.20
Entities with preJudice from all pending cases in which the P,1rtiC1I)ati11g Subdivision has asserted
Covered Claims against E'rido/1"ar or a Released Entity C011CUrrently with the execution 01' this
forni. By executing this Election and Release Form, the Participating Subdivision SUbIllitS to the
Jurisdiction of"the Honorable Robert Schaffer, In Re.- 7exa.,N- Opioid Liligevion, MDI,No. 18-0358,
Master File No. 20 18-63587, in the 152nd Judicial District Court, Harris County, Texas.
Dated:
Texas Subdivisi4n Name:
By: V---4 -�—
[NAME] /V,. Fee,
[TITLE] /A 7
[ADDRESS]
[EMAIL A DDRESS]
A-2
7,15274877,20
EXHIBIT B
Exhibit H: Municipal Area Allocations: 15'., of Total ($150 million)
(County numbers refer to (list ribmtion to the count% governments after pa,•meut to cities within
count• burders has been made. Minimum (list tibutiom to each count• is $1000.)
Municipal Area
Allocation
Municipal Area
Allocation
Ablx,tt
$633
Lakeport
$463
AbernatIlY
$110
Lakeside
$4.474
Abilene
$563.816
Lakeside City
$222
Ackeriv
$21
Lakeview
$427
Addison
$58.091
Lakewav
331.657
Adrian
$161
Lakewoud Village
$557
Agua Dulce
$13
Lamar County
$1 11.596
Alamo
$22.121
Land) Count•
$50.681
Alamo Ileight
$26.198
Lames,
$29.656
Alba
$3.196
Lan►pasz►s
$28.211
AlbanY
$130
Lan►pas►s Omlltv
$12.818
Alf -do
$331
Lancaster
$90.653
.lice
$71.291
Laredo
$763.171
Allen
`5315.081
Latexu
$121
Ahlld
$1.107
Lavaca C:ountx
$15.973
Alpine
$29 666
LIN un
$7.135
Alto
$3.767
Lim-11
$.56
Alton
$11.510
League CitN•
$:302.118
AIvarado
$29.029
Leakev
$256
Mvin
$113.962
Lcandei
$61*3.61 l
AIvord
3353
LearN
$797
Amarillo
$987.661
Lev County
$30.457
Allies
$:,.571
Lefor-,
$159
Amherst
$22
Leon Count•
$67.393
Anahuac
3512
Leon Vallee
$23.256
Anderson
$19
Leona
$363
Anderson County
$266.763
Leonard
$b 505
Andrews
$18.963
LeroN
$176
Alid re\t•s C'ount\
$37.606
Lei el land
346.8 16
Angelina Comm-
'3229.956
ille
$362.091
Angleton
$62.791
Lexington
$2.316
Angus
3331
Libel t•
S72.313
Anna
39.075
Liberty' County
$531.212
.Annetta
35.956
Libert• Hill
$2.730
Annetta North
$31
Limestone Count•
$135.684
(Table continues on multiple pages below
Annetta South
$602
Lincoln Prink
$677
.kunona
$738
Lindalt'
$21.202
Anson
$5.131
Linden
$3.661
Anthom
$4.511
Lindaa%
$1.226
Anton
$44 1
Lipan
$1 t
.kpplebv
$1.551
Lipecomb C'ouniv
$10.132
.kquilla
$206
Little Elm
$69.326
.kransas Count}'
$266.512
Little Rkef-.kcadeniv
$796
.kransa, Pass
$57.813
Littlefield
$7.673
Archer Cih'
$10.551
Li\ e Oak
$32.740
Archer C ollutY
$45.534
Lix e Oak County
$39.716
AI -cola
$7.290
Liverpool
.k1,91-Ic,
$11.106
Living ton
S73.165
Arlington
$735.603
Llano
$23.121
Armstrong C Cuing
$91 1
Plano C.'omltv
$115.617
Arp
$2.009
Lockhart
$19.050
.kshertoll
$112
Luckne\
$3.301
Aspernlont
$9
Log; Cabin
$1.960
Atascosa C'onutY
$176903
Lumeta
$1.176
.-\then,
$105.912
Lune Oak
$1.705
Atlanta
$30.995
Lune Stal
$6.233
:kubrev
$15.1-11
Lon vices
$182.251
Al fun'a
S1.619
Loraine
$l g
Austin C'011111C
$76.030
Lorena
$3.390
Austin
$1.677.716
Lorenzo
$11.358
Austwell
$109
Los Fresno,
$11.185
Ave►v
$1.36
Los Indio,
$159
A inger
$1.115
Los Ybanez
$0
Azle
$32.213
Lot t
$1.516
Bailey'
$9.50
$219
Bailer County
$15.377
Loving County
$1.000
Bailey's Prairie
$5.60-1
Lu►rr\• Crossing
$763
Baird
$2.502
Lubbock
$319.867
Balch Sprim-,
$27.356
Lubbock County
$1.379,719
Balcunes Heights
$23.611
Lucas
$5.266
Ballinger
$9.17'2
Lueders
$506
Balmorhea
$63
Llllkin
$261.592
Bandera
$2.693
Luling;
$29.121
Bandera Cuunty
$86.315
Lumberton
$36.609
Bangs
$3.050
LYford
$3.071
Paq,
Bardwell
Bat nY
Barstow
Bartlett
Bartonville
Bastrop
Bastrop Count•
Bay Cite
Baylor Counts•
Bayou Vista
Bayside
Baytown
13aN•cien-
Beach City
Bear Creek
Beaslet•
Beamnout
Beck\ ille
Bedford
Bedia-s
Bec Ca\ e
Bev Ceulm
Bee\ ille
Bell Count
Bellaire
Bellevue
Bellmead
Bells
Bellville
Belton
Beuavide,
Bcnbrook
Benjamin
Berrvville
Bertram
Bey erl� IIills
Bevil Oaks
Bexar County
Bib Lake
Big Sanrh
$362
$200
$61
$3.373
$8.88 7
$16.320
S313.960
$57.912
$29.832
`;;6.240
5242
"216.066
$11
$12.505
3906
3130
y663.010
51.217
$91.31 1
13.175
$12.663
$97.6 11
$21.027
5650.748
$11.261
$56
$1 1.167
S 1.891
$7.-186
$ 7 2.680
3152
$13.919
39.51
$1 1.379
3162
31.336
$549
S7.007.1i,2
$547
*34.579
L�•nn Count\
Lyt le
\lab►tnk
Madison Ceunh•
Madisonville
Magnolia
Malakoff
Malone
Matter
Mansfield
lam'el
Marble fall,
Marra
Marietta
Marion
Marion Ceuut\
Marlin
Ia ryuei
Marshall
Mart
Martin CeuntY
Martindale
\[awe
\la>„n C ount.\-
Matader
Matagorda Counts
MatIIis
Maud
Mavc-rick CeuntY
Maypearl
McAllen
MccauteY
McGregor
McKinnec
McLean
McLendon -Chisholm
Mcculloch County
Mclennan Count•
NIClllullen Count•
\leaden•
$6.2 7 5
$7.223
$19.443
$19.192
$11.158
$26.031
$12.61 1
$139
S 12.499
$150.788
S12.305
S37.039
$65
$338
$275
S51.726
S21.631
$ l 322
$108 371
$92�
S10.,�62
$2.137
$777
$3.134
$1.203
$135.239
S15.720
$123
$115.919
$966
$361.421
$512
$9.155
$150.383
$14
$Ill
320.021
$529.611
$1.000
$1.121
Pro?
Bib Spring
$189.928
\teadowlakes
$905
Big Wells
$236
Meaclowb Place
$18.148
Bishop
$3.213
Medi►ia Couilty
348.355
Bishop Hill.,
3323
\legargel
$611
Blackwell
$31
Melissa
515.351
Blanco
$6.191
Melvi►i
$315
Blanco CotuttY
$49.223
Memphis
$7.203
Blanket
3147
Menard
$991
Bloontburg
$1.010
\ Lenard Cotutt \
S11.717
Blooming Grove
$352
Mercedes
S21.-141
Blossom
$193
Meridian
$3.5-16
Blue Mound
32.336
Merkel
310.117
Bltte fudge
S1.315
Mertes,
$239
13111111
-�1.622
Mertzo►►
$29
Boerne
$15.576
Mesquite
$310.709
Bogata
S3.649
Mexia
321.096
Bonham
S100.909
Miami
$155
Bonnev
52.510
Midland Cutint\
$279.927
Booker
31.0:36
Midland
$521.819
Burden County
31.110t1
Midlothian
S9•5.799
Burger
$69.680
Midway
S76
Bosytnv County
$71.073
Milattt Couatv
S97.3�6
Boviva
$173
Milauo
MI
Bowie
$83.620
Mildred
$266
BoNvie Cotutt\
$233.190
\Liles
S93
Bowl
-S6.953
Milford
$6.177
Braekettv ille
$J
Miller', Cove
397
Brad'
327. ISO
Milliean
$117
Brazoria
$11 537
Mills ConntY
$19.931
Braiuria Count\
31.021.090
\[illsap
S31
Brazos Bend
$162
Mineola
118.719
Brazos Country
$902
Mineral Wells
$92.061
Brazos Count\-
$312.067
Min -us
$169
Breckenridge
$23.976
\fission
$12-1.763
Bren►ond
`;;5.551
Missouri City
$209.633
Brenham
$54.750
Mitchell CountY
$20.850
Brewster Count'
$60.087
Moheetie
S52
Briarcliff
$572
Mobile Cite
$2.031
Briaruaks
$57
\tottahans
$5.849
Bridge City
$60.756
Aunt Belvieu
$19.669
Pow, ;
Bridgeport
$33.301
Montague Coulav
$94.796
Briscoe C'otmh•
$977
Montgomen
$1.331
Bruaddus
$31
Nloll tgo►uert' Count)
$2.700.911
Bronte
$99
Mooch'
$823
Brooks Cotinh
$20.710
Moore Cotultc
$10.627
Brookshire
$6.106
Moure Station
$772
Brookside Villa e
$1.110
Moran
$50
Brown C ount%
$193.117
Morgan
$605
Browndell
$152
Mor"kin's Point
$3.105
Brownfield
$14.452
Morg:ut's Point Resort
$3.021
Browitshoro
$3.176
Morris C'ounh
$53.32�
Browilm ille
$125.057
Morton
$167
Brownwood
$166.572
C'utu►t\-
$3.314
Brrtceville-F.dch
$1.692
Moulton
$999
Brvau
$216.897
Mount Calm
$605
Brt-so❑
$1.226
Mount Enterprise
$1.,-+32
Buc•kholts
$1.113
\fount Pleecs.utt
$65.661
Buda
$10.73-1
Mottnt Vernon
$6.019
Buffalo
$11.866
Mountain C'ily
$1.51s
Buffalo Gap
$6's
\Ittenster
$1.656
Buffalo Springs
$186
Muleshoe
$1.910
Bullard
37.487
\lullin
$3 1
Buh-erde
$11.136
Muncl,tc
'S2.017
Bunker hill Village
$472
\lulchisurt
$2.302
Burkhurnett
$37.611
Mulpin-
$51.693
Burke
$I.11l
\Itutan,
$7
13urlcsun ['ount�
$70.211
Mustang Ridge
12.462
Burlcsuu
$131.779
Nacogdocht�s
$205.992
Burnet
$33.3-15
Nacogdoches (.;uunt)'
$198.583
Burnet C'ountr
$189.829
Naples
$1.221
Burton
3937
Nash
$7.999
B}•e►s
$77
Nassau Bay
311.217
BYnuu►
.3360
Natalia
$625
Cactus
$1.779
Navarro
$331
Caddo \lilts
$13
Navarro Cuuntv
$103.513
Caldwell
$18.215
Navasota
337.676
Caldwell Cuuntc
$66.113
Nazareth
$121
CaIIlUu❑ Comtt Y
$127.926
Nederland
311.55
Callahan Count\
$12.894
Needville
$10.341
Callishtttg
$101
Nevada
$237
CLAINelt
$772
New Berlin
$4
Cauleron
$11.091
New Rohhm
$6.953
Cameron CotultY
$537.026
Nete Rratulfels
$307.313
Camp Cotulty
$28.851
Nexv Chapel Hill
$233
Camp Wood
$122
Deal
$338
Campbell
$1.116
New Fain iew
$2.334
Canadian
$1.090
New home
$9
Caner Cit--
$2.005
New hope
$1.024
Canton
$56.734
New London
$4.129
Calivo❑
$26.251
New Stuunmrfield
$412
Carbon
$620
New Waverh-
$2.562
Carl's Corner
$13
Newark
$520
C'arnlille
$3w5
Newcastle
$911
C,arrl/.o Spring,"
51.611
Newtoll
$6.102
Carrollton
$310.255
Newton C.omAN
$158.006
Carson Cotlut\-
$29.193
NeYlalldville
$163
carthagc
$18.927
Niederwald
$16
Cashion Conuntlnitv
.3322
Nixon
$2.263
Ca-,-, County-
$93.155
Noeona
$16.536
Ca."He hills
$12.760
Nolall (-'ount\-
S50.262
Caatro C.olulty
) 1. 120
Nolanville
$1.217
Ca"trot-ille
$4.525
Nulne
$391
Cedar hill
$70.127
Noolulav
$226
Cedar Park
$135.567
Nordheiui
$697
Celeste
31.260
Normangee
$6.192
Celina
$18.263
North Cleveland
$105
Center
$53.838
North Richland llilh
$116.119
Centerville
$385
Northlake
$6.905
C'hauihers Connh
`3153.166
\uric(.
$76
Chandler
$17.361
Nnece, C'onntc
$1.367.932
Charming
$2
O'Brien
$76
Charlotte
31.257
O'Donnell
.327
Cherokee Counts
$156.612
Oak Grove
$2. 669
Chester
$1.174
Oak Leaf
$612
Chico
$2.926
Oak Point
$9.011
Childre»
$37.916
Oak Ridge
$356
Childreab Count'
$-50.562
Oak Ridge North
$33.512
Chillicothe
$172
Oak \ alter
$7
China
$522
Oakwood
$143
China Grove
$598
Ochiltree Count
$15.476
Chireno
$1.568
Oder►
$7.420
Christine
$354
Odessa
$559.163
Cibolu
$13.690
Ogle hr
$29
Cisco
$7.218
Old Rivet-Winfiee
$21.653
Clarendon
$114
Oldham► Cotuth
$10.318
Clarksville
$20.891
Ohmus Park
$9.801
Clarksville Cite
$51
OlueN
$6.088
Claude
$26
Olton
$1.197
Clad• C.UUnt.%
172.050
Omaha
$1.185
Clear Lake Sho►ea
$6.682
Onalaska
$31.651
Cleburne
1228.184
Opd'-ke Weat
$479
Cleveland
$96.897
Or.uage
`6311.339
Clifton
$9.939
Orange County
$639.518
Clint
$375
Orange Grove
$1.677
Clute
`F51.350
Orchard
$867
Clvde
$17.267
Ore CRY
$6.806
Cuahoma
$2.291
Overton
$7.900
Cochran Count•
$3.389
Ovilla
$13.391
Cockrell Hill
-$:j12
OYiter Creek
$9.633
Coffee Cit..
$LOS7
Paducalt
$125
Coke County
5.522
Paint Ruck
$141
Coldspring
$117
Pahwio .s
$1 1.036
Coleman
$5.112
Palestine
$178.009
Coleman Cotmle'
..34.164
Palisades
$240
College Station
$258.117
I'ahn Valle•
'$1.917
ColleYville
$16.049
Palmer
$12.666
Collin Count v
$1.266.721
Palnhurst
$1.660
Cullingswurth County
$19.231
Palnn•iew
$7.577
Collinsville
$1.831
Palo Pinto Counte•
$12.1.621
Cohuesmeil
$2.211
Pampa
$67.227
Colorado City
$8.-10:j
Panhandle
$9.536
Colorado Count)
$19.084
Pauula Comm.
$80.699
Columbus
$6.867
Panorama Village
$1.292
Cumal Count'
$396.1-12
Pantegu
312.698
Comanche
$16.503
Paradise
$52
C'outat►che CuuntY
$50.961
Paris
$201.180
Combe;
$1.710
Parker
-310.307
Combine
$1.892
Parker CutultY
$476.251
Commerce
$33.869
Parmer County
$15.866
Como
$415
Pasadena
$356.536
Prue 7
Concho Colu►h
$3.K9
Pattison
$1.148
Conroe
$466.671
Patton Pillage
$9.265
Converse
$27.693
Payne Sprint;,
$1.770
Cooke Cutultc
$200.151
Pearland
$333.752
Cool
$731
Pearsall
$11.570
Coolidge
$213
Pe< <ul Gap
$719
Cooper
$362
Pecatl [till
$229
Coppell
$66.593
Peco,
$7.622
Copper Cam'on
$459
Pecos C'ountY
$16.997
Copperas Cure
$133.192
Pelican 13aY
>1.199
Corinth
$75.298
Penelope
$115
Corpus Christi
$1 812.707
Penita,
$312
Corral Cite
$1.13
Perrvton
$23.361
Corrigan
$21.31 J
Pet er,burg
$1.691
Corsicana
$S7.310
Petrolia
$17
Col -Yell Cotlntv
$123.659
Petronila
$5
Cottle Coullty
$875
Pflugerville
$66.106
Cottonwood
$289
Plian
$111.721
Cottonwood Shore,
$1.203
Pilot Point
311.613
Cot 1111a
$1.251
Pine Forest
$3.691
Cotlpland
$266
Pine Iaaud
$3.1 11
Cove
$3S7
Pinehnr,t
$32.671
Covington
3519
Piueland
$1.135
Covote Flat,
$1.472
Pi►►e,v Point Pillage
115.738
Crandall
$12.094
Pittsbul-A
$20.526
Craule
$10.599
Plains
'h 129
Crane Count v
$26.1 1G
Plainview
'S60.296
Cranfill, Gap
$12ti
Plano
$1.151.608
Crawford
S 353
Pleak
$270
Creedinoor
$16
Pleasant Palle'
$308
C►•esaotl
$1.0•�G
Pleasanton
$29.011
Crockett
$23.403
Plum Grove
$258
Crockett County
$18.210
Point
$1.519
Crosby Cotutty
$16.366
Point Blank
$355
Crosbyton
$1.496
Point Comfort
$-1-17
Cross Plains
$1.677
Point Venture
$585
Cross Road,
$214
Polk Countv
$370.831
Cross Timber
$512
Ponder
$1.252
Crowell
$6.335
Port Aransau
$31.022
Crowle'
$22.3-15
Port .Arthur
$367.915
pl"?,
Crymal Cite
$19.412
Port Isabel
$9.802
Cuero
$24.689
Port Lataca
$11.752
Culhersun Cuullh
$769
Port Neches
$38.849
CunlbY
$5.320
Portland
$76.517
Cuuev
$606
Punt
$2.332
Cushing
$1.120
Post Oak Bend City
$1.031
Cut and Shout
$2.141
Potect
$6.767
DISH
$19
Potll
$3.974
Daingerfield
$12.476
Putter Coulltv
$371,701
Daisetta
$5.370
Pott,boro
$12.302
Dalliart
$11.609
Powell
$110
Dallaul Count\
$21.686
PoYllur
$1.1s0
Dallas County
$8.538.291
Prairie Vivw
$7.600
Dallas
$2.999.902
Prenlunt
$3.321
Dalworthington Gardens
$6.060
Presidio
$148
Daubury
S 1.231
Presidia Couutc
$737
Darrutlzett
3101
Prinaera
$2.955
Daw"on
3600
Princeton
519.245
Dawson Cuunh
316.911
Progress,
$3.072
DaYtort
$17.122
Progreso Lakes
$39
Dax•ton Lak+-,
$36
Praaper
'5322.770
De Kalb
31.03-,
Providence Villa"'v
$508
De Lean
36.215
Putnam
3t I
De Witt Counts
$68.895
Pvote
322
DeCordora
$13.778
Quanah
$207
Desoto
$72.400
Queen Cit\
$ L-N37
Deaf Smith Cotultv
$31.532
Quinlan
$7.301
Dean
$111
Quintana
$492
Dcultell.
$56.669
Quitaque
$6
Deer Park
$49.366
Quitnlarl
$15.619
Del Rio
$59.056
Rain Counh
$53.190
Dell City
$15
Ralh
$3.967
Delta CuuntY
$30.564
liancho Vie.lo
$3.636
Denison
$210.126
Randall Count•
$273.126
Denton
$4.56.334
Ranger
$12.186
Denton Culuttv
$1.132.296
Rankin
$1.613
Denver City
$2.101
Ransom Ceuta on
$930
Deport
$42
Ravenna
$635
Detroit
$965
Ravinondville
$7.466
Devers
$191
Reagan Comm-
$25.215
J-�j,
Devine
$4.354
Real Count%
$5.073
Diboll
$25.533
Red Lick
$23
Dickens
$ 7 1
Red Oak
$26.843
Dickens Count%
$1.873
Red River Cot►► h
$29.306
Dickinson
$83.683
Redwater
$1.059
Dille%
$2.633
Reeves County
$103.350
Dir►unit Count%
$33.291
Refugio
$6.839
Di►nmitt
$1.012
Refugio Count-
$46.216
Dodd City
$1.211
Reklaw
$1.136
Dodson
$1 l7
Reno
$3.791
Domino
$196
Reno
$11.164
Do►►lei' Cotmty
$22.370
Retreat
$52
Donna
$1:3.798
Rhou►e
$12.2�5
Dorchester
$231
Rice
$1.972
Double Oak
$1.765
Richardson
$260.315
Dougla-"'villa
$574
Richland
$210
Dipping Sp►mg,
$el l
Richland Ildl,
S21.138
Dri,coll
$39
Richland Spriug,
$2.231
Dublin
511.176
Richmond
577.606
Dunu►s
'326.229
RichwOod
S12.112
Duncamille
$58.328
Rirsel
$1.116
Dural Co►►nt\
$ 19.109
Ric, Bravo
$8.513
Eagle Lake
S1.86'2
Rio GrandeCits•
$25.917
Eagle Pass
$56.005
Rio Honda,
$3.550
EarIv
$11.838
Rio Vista
$1.119
Earth
5212
Rising Star
$1.933
East Berna►d
$5.5.51
Rivcr Oaks
511.917
Fast Mountain
$2. 194
Riverside
$656
East ' im-akoni
$2.72.3
Roanoke
$275
E ,t land
$ 15.696
Homing Springs
$ 161
Eastland Co►mtY
$52.275
Robert Lce
$65
Easton
S:3'29
Roberts Cotu►ty
$547
F.ctor
51.108
Robertson Count-
S 11.642
Ector Count'
3160.000
Robinscl t
316.002
Edcouch
S 1.101
Robstown
1310.15 l
Edell
$197
Robe
$428
Edgecliff Village
52.232
Rochester
$674
Edgewood
$13.151
Rockdale
120.97:3
Edinburg
$120.684
Rockport
$54.253
Ednun►son
$136
Rocksprings
325
Puff, !c,
Edna
$18.194
Rockwall
$114.306
Eclom
$2.119
Rockwall Count\
$168.820
Edwards County
$975
Rocky Mound
$280
El Campo
$31.700
Roger,
$3.816
El Ceniro
$621
Rollingwood
$1.751
El Laoo
$5.604
Roma
$16.629
El Paso
$1.221.371
Roman Fore,t
$8.610
El Paso Count•
$2.592.121
Ropesville
$2.122
Eldorado
$50
Roscoe
$ 7 7zs
Elect ra
$15.716
Rose C'ih-
$1.012
Elgin
$26.261
Rose dill Acres
$2.311
Elkhart
$301
Rosebud
$1.189
Ellis Count.
$315.372
Rosenberg
$126.593
Elmendorf
$ 7 -l6
Ross
$1 17
Elsa
$7.720
Rosser
$519
Etnhottse
$63
Rotan
$1.193
Emor\
$3.676
Round Momram
$151
Enchanted Oaks
$1.299
Round Rock
$175.992
Encinal
$1.515
Round Top
$1 10
Ennis
$�,1.�39
Rowlett
$99.963
Erath CountY
$102.616
Roxton
$17
Escobares
$10
Ro\,e City
$23.191
Estelline
$909
Rule
$600
Euless
$92.824
Runaa-a-- Bay
$6.931
Eureka
$334
Rrtil"c
$255
Etistace
$2.069
1Znnnels C'uttilt\-
$.33.831
Evant
$2.066
Rusk
$17.991
Everutan
$7.692
Rusk County
$151.390
Fair Oaks Ranch
$8.077
Sabinal
$1.811
Fairchild,
$81
Sabine
$16.179
Fairfield
$1.215
Sachse
$23.100
Fairview
$32.215
Seidler
$92.5
Falfurria,
$2.221
Saginaw
.331.973
Fall, City
$11
Salado
$3.210
Falls Count•
$3 L522
San Angelo
$536.509
Fannin Count\
$131.653
San Antonio
$1.365.116
Farmers Brani li
$91.532
San Augu,tine
.325.162
Farmersville
$10.532
San Augustine C'onnt\
$37.851
Farwell
$343
Sail Benito
$40.015
Fate
$3.473
San Diego
$11.771
f aq. I!
Fa�•ette Ccu nt�•
$92.440
San Elizario
$7.831
Fayetteville
$391
San Felipe
$1.198
Ferris
$13.673
San Jacinto County
$197.398
Fisher Counh
$5.515
Saul Jlldn
$28.845
Flatouia
$5.661
Saul Leanna
$36
Florence
$3.949
San Marcos
$325.688
Floresville
$21.699
San Patricio
$4.213
Flower Mound
$215.256
San Patrie:io C'ountY
$271.916
FloYd Count\
$9.049
San Perlita
$2.219
FloYclada
$6.3•-57
San Saba
$10.057
Foard Count\
$5.761
Sall Saba Colll►t\•
$17.562
Follett
$212
Sanctuary
$17
Forest hill
$26.132
Sandy Oak>
$9.863
ForneN
$,,,0.112
Sarldv Point
$1.637
For;saln
$576
Sanford
$308
Fort Bend Counry
51.506.719
Sanger
122.237
Fort Stockton
51.111
Sansom Park
$223
Fort Worth
S2.120.790
Santa Anna
$329
Franklin
53.931
Santa Clara
Sal
Franklin ColultY
$25.763
Santa Fe
5.3:3.272
Frankston
5271
Santa ItuSa
32.13's
Fredericksburg
$56.1w6
SavoY
$2.349
Freeport
$72.973
Schertz
S60.I10
Freer
$3.271
Schicicher County
$5.695
Freestone Count\
$50.195
Schulenburg
$2.560
Friendsll ood
$1 10.330
Scotland
D 1 IS
Frio Count\
$19.954
Scottsville
$708
Friona
$2.S I6
Scurry
$1.110
Frisco
$405.309
Scurry C'ountY
$73.116
Fritch
$1.51S
Seabrook
$30.270
Fro,t
5321
Seadrift
$991
Fruit ale
52.311
Seagoville
$17.106
Fulshem
$5.272
Seagraves
$7.531
Fulton
$1.602
Sea1v
$20.637
Gaines County
$51.317
Seguin
$376.53N
Gainesville
$153.960
Sellim
$22.129
Galena Park
$13.093
Seminole
$16.092
Gallatin
$1.253
Seven Oaks
$3.917
Galveston
$186.187
Seven Points
$7.152
Gahe:stou County
$1.124.093
Seymour
$11.218
f agc 1
Ganado
$5 510
Shackelford Count}-
$1.288
Garden Ridge
$11.351
Shade Shores
$591
Garland
$120.211
Shallowater
$1.907
Garrett
$2.510
Shamrock
$4.328
Garrison
$3.555
Shavauo Park
$3-178
Gars Cit\
$450
Shelb\ County
$109.925
Gar/a Count\
.8.911
Shenandoah
$17.122
Gatesville
$26.991
Shepherd
$117
George West
$6.207
Sherman
$330.585
Geoi-geto\\-n
$225.696
Sherman Count-
$7.930
Gholson
$1.505
Shiner
$1.042
Giddings
$12.671
Shoreac•res
$958
Gillespie Count-
$63.191
Silsbee
$66.4-12
Gilmer
$33.951
Sih-ertun
$11
Gladewater
$21.638
Simonton
$1.906
Glasscock Count-
$1.000
Sintoll
$23.658
Caen Rose
$510
Skellctown
$100
Glenn lleihhl,
$16.593
Slaton
$I51
Godley'
$3.115
Smiler
$655
Goldsrllit h
$67 7
Smith Count v
$758.961
Goldtllwalte
S1.22•,
Slllltliville
$11.009
Goliad
$3.563
Slmver
$300
Guliad Couch'
$34.660
Snook
$1.122
Goliuda
$100
Sm-del'
$9.013
Goncalcy
$14.852
Soc•orro
$11.125
Gonzales Comll.
$33.230
Somerset
$1.527
Goodlow
$221
Somervell Count\
3.i7.076
Goodrich
$9.643
Somerville
$3.806
Gordon
$365
Sonora
$7.337
Goree
$719
Suer Lake
S17.856
Gorman
$3.107
South Ifouston
525.6.20
Graford
$23
Sulith Mountain
$151
Graham
$235.128
South Padre Island
530.629
Granbury
$71.73.
Suuthlake
370.616
Grand Prairie
$115.139
SouthmaYd
$7.096
Grand Saline
$36.113
Suuthside Place
$665
Grandfalls
$65
Spearman
S14.000
Grandview
$6.600
Splendora
$7.756
Graliger
$2.741
Spofford
$7
Granite Shoals
$11.831
Spring Vallev Village
$16.401
Yaq. !
Granjeno
$43
Springlake
$3
Grapeland
$7.257
Springtown
$11.211
Grapevine
$129.195
Spur
$427
Graff• Count-
$65.38-1
St. Hedwig
$111
Grays Prairie
$17
St. Jo
$7.360
Grayson Count•
$539.083
St- Paul
$21
Greenville
$203.112
Stafford
$75.145
Gregg Counh
$243.711
Stagecoach
$3.036
Gregor'
$1.697
Staillford
$393
Grey' Forest
$171
Stanton
$3.833
Grimes Count•
$91.878
Staple,
$19
Groesbeck
$5.715
Star H.u-hol
$151
Groo►rl
$965
Starr Cotultv
$99.896
Grove,
$40.752
Stephens Cotilltc
135.244
Groveton
$6.327
Stephenville
$83.172
Grin'er
$1.166
Sterling Cit%
$62
Guadalupe Count•
$1-16.52-1
Sterling Count'
$939
Gun Barrel Cit-
$36.302
Stinnett
$1.097
Gunter
$1.609
Stockdale
$711
Gu,tine
$31
Stollett-all Cottllt\
$1.622
Hackberry
$91
Stratford
$3.373
Hale Center
$6.012
Strawtl
$967
Hole Cotult.N•
$79.150
Streetiltan
$5
Hall Colult
$6.933
Sudan
$32
11allett.,ville
$6.895
Sugar Land
$321.561
Hxllsburg
S212
Stlllivoll City-
$6.121
Halh: ille
$10.239
Sulphur Springy
$121.603
Haltom Cite
$71.600
Still Valle:-
$a
Hamilton
$3.561
Sundim-n
$2.592
Hamilton Count\
`566.:357
Stuun:ale
$3.216
Hamlin
$1.6-56
Sttnnt,N•
$2.571
Hanford Count'
$16.116
Stlnli,e Beach Village
$2.0J3
Happy-
$327
sllll."et Vallee
$9.125
1[a1-denlan Cotu1 c
$15.219
SurE,ide Beach
$6.530
Hardin
$100
Sutton Count'
$6.511
Hardin Count-
$379.600
sweem
S L503
Marker 1iti-lath
$113.681
Sweetwater
S68.243
Harlingen
$165429
Swkhel Count•
$7251
Harris Count
$14.966.202
Taft
$5.861
Harrison Count%
$165.910
Tahoka
S430
p(op 1.1
Hart
$66
Talco
$372
Hartley C'ountY
$766
Taltr
$9.124
Haskell
$10.829
Tarrant Couch'
$6.171.159
Haskell County
$22.011
Tatum
$972
Haslet
$1.908
Taylor
$57.945
Hawk Cove
$67 1
Ttt''lor County
$351.078
Hawkins
$7.932
Taylor Lake Village
$412
Hawle%
$931
Taylor Landing
$153
Hay,
$506
Teague
$1.711
IIays County
$529.189
'Felutacana
$12
Hearne
$16.821
'Temple
$280.717
Heath
$28.751
Tenaha
$1.716
I lebron
$667
'Terrell
$148.706
Hedim
$70
Terrell Count
$5.737
Hudwig Village
$13.067
'Terrell hills
$9.858
I lelote,
$15.790
Teri t• Cottnt r
$25.123
Hemphill
$8.035
Texarkana
$192.091
Hemphill CotttitY
$1 1.391
'Texas Cih-
$296.702
11etttpstcad
$21.210
Texhouta
$156
1lender,ou
$59.966
Te:xline
$865
Henderson Cot1111Y
$327.965
The Colon'
$11-1.297
Henrietta
$2.720
The Hilh
$1.001
Hereford
$20.123
Thorttp,on,
$1.697
1lewitt
$19.776
Thorndale
$1.595
Ilickory Cieek
$16.510
'Thornton
$270
11ico
$5.531
'Thorntoil viIle
$67
Hidalgo
$26.621
Thrall
$825
Hidalgo County
$1.2-53.103
'Three River,
$4.669
Hideawa\
$922
'Throc•ktnorton
$29
Ifiggiu,
$13
Throcktnorton Count'
$5.695
Highland Haven
$320
'Tiki bland
$2.178
Highland Park
$13.363
Tiutbercreek Canvon
$369
highland Village
$50.315
Timp,on
$12.612
Hill Country' Village
$6.165
Tioga
$2.390
Hill CotuttY
$127.177
Tint
$185
hillcrest
$5.345
'Titus Count
$70.611
Hill,boro
$16.609
Toco
$4
Hilshire Village
$859
Todd Mission
$1.680
Hitchcock
$26.796
Tolar
$2.369
Hocklev Count\
$46.407
Tom Beau
$2.293
Ifolidav Lakes
$1.795
Tom Green Cotuth•
$282.427
Holland
$77
Tomball
$34.620
Holliday'
$5.910
Tool
$14.787
Hollvwuod Park
$9.424
Tu. alt
$40
Ilonclo
$115.288
Travis Count%
$1.703.473
Hone• Grove
$7.196
Trent
$63
Hood Count•
$292.105
Trenton
$3.089
Hooks
$2.702
Trinidad
$5.859
IIopkins Count%
$119.518
Trinity
$23.652
Horizon City
$7.520
Trinity Counh•
$105.766
Hor�esltue Bay
$18.173
Trophy Club
$29.370
Houston CottntN
$78.6-18
Troup
$7.918
Ilou,tu►t
$7.021.793
Troy
$5.320
Howard Cuuntv
$59.330
'I•ulia
$8.911
I-lowardwick
$81
Turkey
$737
1lowe
$9.177
'I'tticula
$138
Ilttbbard
$3.635
TYe
$1.766
Iludsun
$6.810
Tvler
$723.629
lludunt Oaks
$15.637
Tyler CuuntY
$131.7 13
Hud,peth C'uuntY
$985
l;liland
$1 .515
Ilugln:�Spri�g,
$1.112
Cne(.rtailt
$165
Humble
$73952
Union Grupe
$991
hunt Cuttnt\
Union Valley
$666
Ilunten-, Creek \•illal;e
$14.70,�
Universal Cit}
$28.428
Huntington
$6.792
Universit-v Park
$50.633
Huntsville
$30.373
1'p,h111. CuuntY
$128.300
II►ust
$99.157
Vptun
$8.199
Hutchins
$9.551
Utalde
$18.439
1lilt rhinu,n County
y71.630
Uvalde Collnty
$36.211
Ilutto
$38,316
VA Verde C ount\
$117.815
llttxlev
$735
Valentine
$207
Idaluu
$1.999
Valley Mill-,
$2.228
Impart
$,
Valley View
$I.521
Indian Lake
$473
Van
$6.206
ludustt�
$601
\'an .\l4vile
$13.749
Ingleside on the F3av
$1 12
\•an Hurst
$211
Ingleside
$10.167
Vau Zandt County
$218.747
Ingrain
$5.243
Vega
$971
Iola
$3.161
VetTtls
$9.792
Iowa C01011V
$1.090
Vernon
$61.337
Puy,* 11,
Iowa Park
$23.487
Victoria
$84.598
Iraall
$56
Victoria Counts
$520.536
Iredell
$216
Vidor
$95.620
Ifion Coulttt'
S9.105
Vinton
$622
Irving
$127.818
Volente
$333
Itak
S5.319
Vun 01 lilt
$513
Itasca
53.691
Waco
$512.007
Ivanhoe
$26
Wwelder
$3.127
Jacinto City
$14.141
Wake Village
$171
.Jack Count'
$1 1.799
Walker County
$181.621
Jacksbon)
$23.251
\Valler Cotlnh
$126.206
Jackson Cuttnty
$37.981
Waller
$11.295
Jacksonville
$60.179
Wallis
$2.69A
Jamaica Beach
$1.913
Walnut Spriuw,
$133
.Jarrell
$2.12.3
Ward CouritY
S67.920
Jaspo'
$76.422
Warren City-
S66
Jaspef Cuttut\
$213.355
Washiilgton County
S6.3.727
JaYton
$63
Waskom
$5.316
.Jeff Davis Count\
36.500
Watallgit
S3.3.216
Jeffersoll
$11.191
Waxahaellie
$152.094
Jefferson CountY
$756.611
Weatherford
$207672
.lessee Village
$36.317
Webb Cutult\
$505 301
jewet t
$9.336
Webber v ille
$1.260
Jim Ilogg Cululh
$12.716
Webste►
$53.202
Jim Welk Cuttllh
$166.539
Wein►ar
$5.630
Joaquin
$810
Weiuert
IM 1
Johnson City'
$3.561
Weir
It' -113
.Johnson Count.
$108.692
Wellington
$9.111
JollY
$26
Welhnan
S333
.lone, Colulty
S23.001
Wells
$1.357
.Junes Creek
$5.076
Weslaco
$13.919
Jone'towil
$6.119
\Pest
$3.522
Josephine
$661
West Columba
$17.956
Ju�hua
$20.619
West Lake Ililk
$17.056
Jotll'da►llo►l
$9.600
West Orange
$ 12. 152
.]unction
$4.825
West Tateakoni
$6.995
Just ill
$3.575
West ulliversitY Place
$31.672
Karnes City'
$11.632
Westbrook
$13
Kal lips Cutultt
$35.219
Westlake
$11.540
Katc
$52.167
Weston
S266
Post: I'
Kaufman
$27.607
Weaton Lake:,
$139
Katlf Ilan County
$353.017
Westover hills
$1.509
Keene
$38.296
\Westworth Village
$7.342
Keller
$79.189
Wharton
.331.700
Kemah
$26.325
Wharton Count\
$72.387
Kemp
$6.119
Wheeler
$447
Kempner
$330
Wheeler Count\
$26.273
Kendall Count
$100.613
White Deer
$1.273
Kendletuu
$13
White Oak
$15.305
Kenedy
$676
White Settlement
$23.301
Kenedy Colurtr
$1.000
Whiteface
$155
Kenefick
$116
Whitehouse
$29.017
Kennard
$132
Whitesboru
$18.932
Kennedale
$21.021
Whitewright
$7.096
Kent Count•
$939
Whitnec
$73
Kerens
$1.924
Wichita County
$552371
Kermit
$5.652
Wichita Fall.
$632.571
Kerr Coullh
$216.152
\Wickett
$67
Kerrville
$190.357
\Wilburgel Comte
$55.121
Kilgore
$10.5.563
\Willoc'v Count\
$21.581
Killeen
$5:35.650
\Williaulson Cotulte
$1.195.987
Kimble County
$20.180
Willis
$21.38-1
King County
$1.000
Willow Park
$26.737
Kingsyille
$20.063
\Will's Point
$43.765
KilllleY Countj
$2.142
Wilmer
$ 126
Kirby
$8.752
Wilson
$12
KirbYt ille
$10.690
Wil,on COtlllt\
$121.031
Kin in
$2
1Wiutbel le.
$ 724
Kleberg CouutY
$12-1.109
\Windcro-A
$12.908
Knollwood
$1.160
Windom
$1.067
Knox City
51.962
\Wiudthor,t
$3.365
Knox Colult\
$11.730
Winfield
$290
Kosse
$2.465
Wink
$120
Kountze
$19.716
Winkler Count'
$61.163
Kres
S186
\Wiunsburu
$26.791
KIIlgel\iIle
$1.305
Winona
$319
Krum
$9.661
Winters
$6.229
Kul tell
$666
Wise Count'
$289.071
Kyle
$51.83.5
Wixon Valley
$4-11
Lit Feria
$10.381
Wolfe Cih-
$5.466
pwit 1.4
La Grange
$9.623
Wolfforth
$4.022
La Grulla
$1.708
Wood Cou ntY
$267.018
La Jo} a
$8.157
Woudbranch
$9.617
La Marque
S%.930
\ oodcreek
$358
La Porte
$91.532
Woodloch
$1.012
La Salle County
$1 1.975
\\'ouclsboru
$1.130
La Vernia
$3.217
Woodson
$122
La Villa
$572
\\'oucl+ ill+•
$20.310
La Ward
$321
\\'ucx way
$25.713
LaCoste
$159
\\'urtIlaill
$376
Lack' -Lakeview
$1 1.599
\\' 'lie
$114.708
Laduuia
S2.011
Yantis
$2.072
Lagu Vista
$13.766
Yoakum County
$31.924
Laguna Vista
$3.669
Yoakum
$20.210
Lake Bridgeport
$232
Yorktown
$5.117
Lake City'
$2.916
Young Cuuruty
$11.120
Lake Dallas
$25.31 1
'Zapata CuuntY
$56.180
Lake Jackson
`+75.731
zavala County
$36.1 17
Lake Tauglewood
$613
G:n<+Ila
$L083
Lake Worth
$20.051
Exhibit B
TEXAS SUBDIVISION AND SPECIAL DISTRICT
ELECTION AND RELEASE FORM
This Election and Release Form for Texas Participating Subdivisions' resolves opioid-
related Claims against Teva under the terms and conditions set forth in the Teva Texas State -
Wide Opioid Settlement Agreement between Teva, the State of Texas, and the Counties of
Dallas, Bexar, Harris and Tarrant (the "Agreement"), the provisions of which are here
incorporated by reference in their entirety. Upon executing this Election and Release Form, a
Participating Subdivision agrees that, in exchange for the consideration described in the
Agreement, the Participating Subdivision is bound by all the terms and conditions of the
Agreement, including but not limited to the Release found in Section VII of the Agreement and
the provisions concerning participation by Subdivisions or Special Districts in Section VIII, and
the Participating Subdivision and its signatories expressly represent and warrant on behalf of
themselves that they have, or will have obtained on or before the Effective Date or on or before
the execution ofthis Election and Release Form if executed after the Effective Date, the authority
to settle and release, to the maximum extent of the Subdivision's and Special District's power,
all Released Claims related to Covered Conduct. If this Election and Release Form is executed
on or before the Initial Participation Date, the Participating Subdivision shall dismiss the
Released Claims with prejudice and sever Teva and all other Released Entities from all pending
cases in which the Participating Subdivision has asserted Covered Claims against Teva or a
Released Entity no later than the Initial Participation Date. If this Election and Release Form is
executed after the Initial Participation Date, the Participating Subdivision shall dismiss the
The Agreement defines a "Participating Subdivision" as a Subdivision or Special District that
signs this Election and Release Form and meets the requirements for becoming a Participating
Subdivision under subsection VIII.A. of the Agreement.
Released Claims with prejudice and sever, Teva and all other Released Entities from all pending
cases in which the Participating Subdivision has asserted Covered Claims against Teva or a
Released Entity concurrently with the CXCCUtiOII Of this Con-n. By executing this Election and
Release Foi-n), the Pat-ticipating Subdivision submits to tlICjLIHSdiCtiOII of the Honorable Robei-t
Schaffer, In Re., Teacts QpioidLiti,,-('Won, MDL No. 18-0358, N/lastcr- File No. 2018-63587, in the
152nd Judicial District COLII-t, Flal-1-iS COL111t), Texas.
Dated: � / ( / -L'-Z"
Texas SubdiNiIA)n Name:
BY:
[NAME -
'I q
[TITLE] AA6,vlor-
[ADDRESS] ili-t Avg,
[TE L F- 1) 1-1 ON 1"'] 12p(, — 7
[EMAIL ADDRESS] mil,
2
EXHIBIT C
Exhibit C: TX Opioid Council k Health Care Region Allocations plus AdminlStratt\'e Costs
_►0`/ of Total ($700 million)
Health Care Region Allocatiuu*: $693 Million; Administrative Costs: $7 million
Region Counties in Health Care Region ,allocation
Anderson. Bowie. Camp. Casa Cherokee. Delta. Fannin. Franklin. Freestone. Gregg.
1 Harrison. Henderson. Hopkins. Houston. Hunt. Lamar. Marion. Morris. Panola. Rains.
Red. River. Rusk. Smith. Titus. Trinity. Upshur. Van. Zandt. Wood $36.223.336
2 Angelina. Braroria. Galveston. Hardin. Jasper. Jefferson. Liberty. Nacogdoches. Newton.
Orange. Polk. Sabine. San Augustine. San Jacinto. Shelby. Tyler $51.149.215
3 Austin. Calhoun. Chambers. Colorado. Fort Bend. Harris. Matagorda. Waller. Wharton S120965.680
d Aransas. Bee. Bruuks. De Witt Duval. Guliad. Gonzales. Jackson. Jim Wells. Karnes.
Kened\•. Kleberg. Lavaca. Live Oak. Nueces. Refugio. San Patricio. Victoria $27.017.477
3 Cameron. Ilidalgo. Starr. Willacy $17.619.875
G Atascusa. Bandera. Bear. C'onml. Dimmit. Edwards. Frio. Gillespie. Guadalupe. Kendall.
Kerr. Kinnev. La Salle. McMullen. Nledina. Real. Uvalde. Val Verde. Wilson. Za\ala $68.228.017
7 Bastrop. Caldwell. Favette. Hays. Lee. Travis $50.489.691
6 Bell. Blanco. Burnet. Lampasas. Llano. Milani. \lills. San Saba. Williamson $21.220.521
9 Dallas. Kaufman $66.492.091
10 Ellis. Krath. Hood. Johnson. Navarro. Parker. Somervell. Tarrant. Wise $65.538.114
11
Brown. Callahan. Comanche. Eastland. Fisher. Haskell. Jones. Knox. Mitchell. Nolan.
Palo Pinto. Shackelford. Stephens. Stonewall.Ta\•lor
$9.509.818
.`r1111t rang. Basle\. Burdett. Briscoe. Carson. Castro. Childress. Cochran. Collingsworth.
Cottle. Crosby. Daflatn. Dawson. Deaf Smith. Dickens. Donle\v. FloYd. Gaines. Garza.
12
Gray. hale. Hall. Hanford. Hartle'•. Hemphill. Hot-. Hutchinsuu. Kent. King. Land).
Lipscomb. Lubbock. Lynn. Moore. Nlotle\-. Ochiltree. Oldham. Partner. Putter. Randall.
Roberts. Scurry. Sherman. Swisher. Terry. Wheeler. Yoakum
$23.496.027
Coke. Coleman. Concha. Crockett. Irion. Kiutble. Mason. McCulloch. Munard. Pecos.
13
Reagan. Runnels. Schleicher. Sterling. Sutton. Terrell. Tuns Green
$5.195.605
Andrews. Brewmer. Crane. Culberson. Ector. Glasscock. Howard. Jeff Davis. Loving,
11
Martin. Midland. Presidio. Reeves. Upton. Ward. Winkler
$12.121.351
15
El Paso. Hudspeth
.317.991.265
16
Basque. Cui-Yell. Falls. Hamilton. fill. Limestone. McLennan
$9.152.016
17
Brazos. Burleson. Griines. Levu. \laclison. Montgunter.'. Robertson. Walker. Washington
323.042.947
13
Collin. Denton. Grayson. Rockwall
$39.737.684
Archer. Ba\'lor. Clad•. Cooke. Foard. Hardeman. Jack. Nlontagne. 'I hruckuun•ton. Wichita.
19
Wilbarger. Young
$12.665.268
20
Jim flugg. Maverick. Webb. Zapata
$6.755.656
Administrative Costs
$7.000.000
* Each Region shall reserve 25',; of its allocation for Targeted Funds under the guidelines of Exhibit A
Governmental Entil
Authorized Official
Address 1:
Address 2:
City, State, Zip:
Phone:
Email:
EXHIBIT K
Subdivision Settlement Participation Form
City of Lubbock State: Texas
Daniel M. Pope, Mayor
1314 Avenue K
P.O. Box 2000
Lubbock, TX 79457
(806)775-2010
dpope@mylubbock.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 the Settlement
Agreement dated July 21, 2021 ("Distributor Settlement"), and acting through the undersigned
authorized official, hereby elects to participate in the Distributor Settlement, release all Released
Claims against all Released Entities, and agrees as follows.
1. The Governmental Entity is aware of and has reviewed the Distributor Settlement,
understands that all terms in this Participation Form have the meanings defined therein,
and agrees that by signing this Participation Forin, the Governmental Entity elects to
participate in the Distributor Settlement and become a Participating Subdivision as
provided therein.
2. The Governmental Entity shall, within 14 days of the Reference Date and prior to the
filing of the Consent Judgment, secure the dismissal with prejudice of any Released
Claims that it has filed.
3. The Governmental Entity agrees to the tenns of the Distributor Settlement pertaining to
Subdivisions as defined therein.
4. By agreeing to the terms of the Distributor Settlement and becoming a Releasor, the
Governmental Entity is entitled to the benefits provided therein, including, if applicable,
monetary payments beginning after the Effective Date.
5. The Governmental Entity agrees to use any monies it receives through the Distributor
Settlement 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 provided in, and for resolving disputes to the extent provided in, the Distributor
Settlement. 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 Distributor Settlement.
K-1
The Governmental Entity has the right to enforce the Distributor Settlement as provided
therein.
3. The Governmental Entity, as a Participating Subdivision, hereby becomes a Releasor for
all purposes in the Distributor Settlement, including, but not limited to, all provisions of
Part XI, and along with all departments, agencies, divisions, boards, commissions,
districts, instrumentalities of any kind and attorneys, and any person in their official
capacity 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 any forum whatsoever. The releases provided for in the Distributor
Settlement are intended by the Parties to be broad and shall be interpreted so as to give
the Released Entities the broadest possible bar against any liability relating in any way to
Released Claims and extend to the full extent of the power of the Governmental Entity to
release claims. The Distributor Settlement shall be a complete bar to any Released
Claim.
9. The Governmental Entity hereby takes on all rights and obligations of a Participating
Subdivision as set forth in the Distributor Settlement.
10. In connection with the releases provided for in the Distributor Settlement, 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, and 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, 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 knov%'n, would materially affect the Governmental Entities' decision to
participate in the Distributor Settlement.
K-2
11. Nothing herein is intended to modify in any way the terms of the Distributor Settlement,
to which Governmental Entity hereby agrees. To the extent this Participation Form is
interpreted differently from the Distributor Settlement in any respect, the Distributor
Settlement controls.
I have all necessary power and authorization to execute this ation Form on behalf of the
Governmental Entity.
Signature:
Name: Daniel M. Pope
Title: Mayor
Date: November 1, 2021
K-3
EXHIBIT K
Settlement Participation Form
Governmental Entity: City of Lubbock
State: Texas
Authorized Official: Daniel M. Pope, Mayor
Address 1: 1314 Avenue K
Address 2: P.O. Box 2000
City, State, Zip: Lubbock, TX 79457
Phone: (806) 775-2010
mylubbock.us
Email: dpope@rnylubbock.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 the Settlement
Agreement dated July 21, 2021 ("Janssen Settlement"), and acting through the undersigned
authorized official, hereby elects to participate in the Janssen Settlement, release all Released
Claims against all Released Entities, and agrees as follows.
1. The Governmental Entity is aware of and has reviewed the Janssen Settlement,
understands that all terms in this Election and Release have the meanings defined therein,
and agrees that by this Election, the Governmental Entity elects to participate in the
Janssen Settlement and become a Participating Subdivision as provided therein.
2. The Governmental Entity shall, within 14 days of the Reference Date and prior to the
filing of the Consent Judgment, dismiss with prejudice any Released Claims that it has
filed.
3. The Governmental Entity agrees to the terms of the Janssen Settlement pertaining to
Subdivisions as defined therein.
4. By agreeing to the terms of the Janssen Settlement and becoming a Releasor, the
Governmental Entity is entitled to the benefits provided therein, including, if applicable,
monetary payments beginning after the Effective Date.
5. The Governmental Entity agrees to use any monies it receives through the Janssen
Settlement 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 fled for purposes limited to that court's role
as provided in, and for resolving disputes to the extent provided in, the Janssen
Settlement.
7. The Governmental Entity has the right to enforce the Janssen Settlement as provided
therein.
8. The Governmental Entity, as a Participating Subdivision, hereby becomes a Releasor for
all purposes in the Janssen Settlement, including but not limited to all provisions of
86
Section IV (Release), and along with all departments, agencies, divisions, boards,
commissions, districts, instrumentalities of any kind and attorneys, and any person in
their official capacity 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 any forum whatsoever. The releases provided for
in the Janssen Settlement are intended by the Parties to be broad and shall be interpreted
so as to give the Released Entities the broadest possible bar against any liability relating
in any way to Released Claims and extend to the full extent of the power of the
Governmental Entity to release claims. The Janssen Settlement shall be a complete bar to
any Released Claim.
9. In connection with the releases provided for in the Janssen Settlement, each
Governmental Entity expressly waives, releases, and forever discharges any and all
provisions, rights, and benefits conferred by any law of and 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, 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 the Janssen Settlement.
10. Nothing herein is intended to modify in any way the terms of the Janssen Settlement, to
which Governmental Entity hereby agrees. To the extent this Election and Release is
interpreted differently from the Janssen Settlement in any respect, the Janssen Settlement
controls.
I have all necessary power and authorization to execute this Elec n and Release on behalf of
the Governmental Entity.
Signature:
Name: Daniel M. Pope
Title:
Mayor
Date: November 1, 2021
Chad Weaver
From:
Opioids <opioids@oag.texas.gov>
Sent:
Tuesday, March 1, 2022 3:38 PM
To:
Venita Wadsworth
Cc:
Chad Weaver; Jeffrey Hartsell
Subject:
RE: Texas Subdivision and Special District Election and Release Form
WARNING: This message was sent from outside the City of Lubbock's email system
It could contain harmful attachments or links to harmful web pages.
Thank you very much for sending these documents, this is to confirm receipt. We will reach out if we have any questions!
Caroline Griggs
Government Relations Manager
Government Relations Division
1\ 4
Office of the Attorney General s 209 W. 1411' Street i
Austin, Texas 78701
Office: 512-936-2108 1 Cell: 512-289-4672
Carol ine.G rieesGiloae.lexas.eov
From: Venita Wadsworth<VWadsworth@mail.ci.lubbock.tx.us>
Sent: Tuesday, March 1, 2022 2:41 PM
To: Opioids <opioids@oag.texas.gov>
Cc: Caroline Griggs<Caroline.Griggs@oag.texas.gov>; Chad Weaver<CWeaver@mail.ci.lubbock.tx.us>; Jeffrey Hartsell
<JHartsell @ mail.ci.l ubbock.tx. us>
Subject: Texas Subdivision and Special District Election and Release Form
Please see executed exhibits A & B in the above referenced matter.
Thank you for your time and attention.
Legal Assistant
City Attorney's Office
P O Box 2000
Lubbock, Texas79457
806-775-2219
Fax 806-775-3307
vwadswonh a mvlubbock us