Upland City Council
March 27, 2023

C-258
State Subdivision/Special
District Case Caption Case No. Jurisdiction
Litigation I
(UT -
Summit
County,
Silver
Summit
Division)
(State MDL)
UT County of San Juan San Juan County v. Purdue Pharma L.P., et al.
180700011 /
180500119
(coordinated)
MDL - In the
Matter of the
Utah Opioid
Litigation I
(UT -
Summit
County,
Silver
Summit
Division)
(State MDL)
UT County of Sanpete Sanpete County v. Purdue Pharma L.P., et al.
180600095 /
180500119
(coordinated)
MDL - In the
Matter of the
Utah Opioid
Litigation I
(UT -
Summit
County,
Silver
Summit
Division)
(State MDL)
UT County of Sevier
Sevier County, Juab County, Emery
County, Wayne County and Piute County
v. Purdue Pharma L.P., et al.
190500430 /
180500119
(coordinated)
MDL - In the
Matter of the
Utah Opioid
Litigation I
(UT -
Summit
County,
Silver
Summit
Division)
(State MDL)
UT County of Summit Summit County Utah v. Purdue Pharma L.P., et al.
190500354 /
180500119
(coordinated)
MDL - In the
Matter of the
Utah Opioid
Litigation I
(UT -
Summit
County,
Silver
Summit
Division)
(State MDL)

C-259
State Subdivision/Special
District Case Caption Case No. Jurisdiction
UT County of Tooele Tooele County, Utah v. Purdue Pharma L.P., et al.
190500355 /
180500119
(coordinated)
MDL - In the
Matter of the
Utah Opioid
Litigation I
(UT -
Summit
County,
Silver
Summit
Division)
(State MDL)
UT County of Uintah
Uintah County, Utah; Duchesne County,
Utah; Daggett County, Utah and Tri-
County Health Department v. Purdue
Pharma L.P., et al.
190500359 /
180500119
(coordinated)
MDL - In the
Matter of the
Utah Opioid
Litigation I
(UT -
Summit
County,
Silver
Summit
Division)
(State MDL)
UT County of Utah Utah County, Utah v. Purdue Pharma,
Inc., et al. 1:18-op-46184 N.D. Ohio
(Federal)
UT County of Wasatch Wasatch County, Utah v. Purdue Pharma L.P., et al.
190500357 /
180500119
(coordinated)
MDL - In the
Matter of the
Utah Opioid
Litigation I
(UT -
Summit
County,
Silver
Summit
Division)
(State MDL)
UT County of
Washington
Washington County, Kane County, Beaver
County and Garfield County, Utah v.

Purdue Pharma L.P., et al.
190500361 /
180500119
(coordinated)
MDL - In the
Matter of the
Utah Opioid
Litigation I
(UT -
Summit
County,
Silver
Summit
Division)
(State MDL)
UT County of Wayne
Sevier County, Juab County, Emery
County, Wayne County and Piute County
v. Purdue Pharma L.P., et al.
190500430 /
180500119
(coordinated)
MDL - In the
Matter of the
Utah Opioid
Litigation I
(UT -
Summit
County,
Silver

C-260
State Subdivision/Special
District Case Caption Case No. Jurisdiction
Summit
Division)
(State MDL)
UT County of Weber Weber County, Utah v. Purdue Pharma
L.P., et al.
190500358 /
180500119
(coordinated)
MDL - In the
Matter of the
Utah Opioid
Litigation I
(UT -
Summit
County,
Silver
Summit
Division)
(State MDL)
VA City of Alexandria City of Alexandria v. Purdue Pharma L.P., et al. 1:19-op-45246 N.D. Ohio
(Federal)
VA City of Bristol City of Bristol, Virginia v. Purdue
Pharma L.P., et al. 1:19-op-45719 N.D. Ohio
(Federal)
VA City of Buena Vista City of Buena Vista, Virginia v. Teva Pharmaceuticals USA, Inc., et al. 1:20-op-45159 N.D. Ohio (Federal)
VA City of Chesapeake City of Chesapeake, Virginia v. Purdue Pharma L.P., et al., 1:19-op-45712 N.D. Ohio
(Federal)
VA City of Covington City of Covington, Virginia v. Purdue Pharma L.P., et al. 1:19-op-45799 N.D. Ohio
(Federal)
VA City of Danville
City of Danville, Virginia v.

AmerisourceBergen Drug Corporation, et
al.
1:19-op-45730 N.D. Ohio
(Federal)
VA City of Emporia City of Emporia, Virginia v. Purdue
Pharma L.P., et al. 1:19-op-46850 N.D. Ohio
(Federal)
VA City of Fairfax City of Fairfax, Virginia v. Teva
Pharmaceuticals USA, Inc., et al. 1:20-op-45177 N.D. Ohio (Federal)
VA City of
Fredericksburg
City of Fredericksburg, Virginia v.

Purdue Pharma L.P., et al. 1:19-op-45898 N.D. Ohio
(Federal)
VA City of Galax City of Galax, Virginia v. Purdue Pharma L.P., et al. 1:19-op-45243 N.D. Ohio
(Federal)
VA City of Hopewell City of Hopewell, Virginia v. Purdue Pharma L.P., et al. 1:19-op-45433 N.D. Ohio
(Federal)
VA City of Lexington City of Lexington, Virginia v. Purdue Pharma L.P., et al. 1:19-op-45693 N.D. Ohio
(Federal)
VA City of Martinsville City of Martinsville, Virginia v. Purdue Pharma L.P., et al. CL18000240
VA - Circuit
Court for the
City of
Martinsville
(State)
VA City of Norfolk
City of Norfolk, Virginia v.

AmerisourceBergen Drug Corporation, et
al.
1:19-op-45926 N.D. Ohio
(Federal)
VA City of Norton City of Norton, Virginia v. Purdue
Pharma L.P., et al. 1:19-op-45249 N.D. Ohio
(Federal)
VA City of Portsmouth City of Portsmouth v. Purdue Pharma L.P., et al. 1:19-op-45856 N.D. Ohio
(Federal)
VA City of Radford City of Radford, Virginia v. Purdue
Pharma L.P., et al. 1:19-op-46154 N.D. Ohio
(Federal)

C-261
State Subdivision/Special
District Case Caption Case No. Jurisdiction
VA City of Richmond City of Richmond v. AmerisourceBergen Drug Corporation, et al. 1:19-op-45546 N.D. Ohio
(Federal)
VA City of Roanoke City of Roanoke, Virginia v. Purdue
Pharma L.P., et al. 1:19-op-45696 N.D. Ohio
(Federal)
VA City of Salem City of Salem, Virginia v. Purdue Pharma L.P., et al. 1:19-op-45697 N.D. Ohio
(Federal)
VA City of Virginia
Beach
City of Virginia Beach and Sheriff of the
City of Virginia Beach v.

AmerisourceBergen Drug Corporation, et
al.
1:18-op-46137 N.D. Ohio
(Federal)
VA City of Waynesboro The City of Waynesboro, Virginia v.

Purdue Pharma L.P., et al. 1:19-op-46152 N.D. Ohio
(Federal)
VA City of Winchester City of Winchester, Virginia v. Teva Pharmaceuticals USA, Inc., et al. 1:20-op-45176 N.D. Ohio (Federal)
VA County of
Accomack
Accomack County, Virginia v. Purdue
Pharma L.P., et al. 1:19-op-45715 N.D. Ohio
(Federal)
VA County of
Alleghany
Alleghany County, Virginia v. Purdue
Pharma L.P., et al. 1:19-op-45700 N.D. Ohio
(Federal)
VA County of Amherst Amherst County, Virginia v. Purdue Pharma L.P., et al. 1:20-op-45046 N.D. Ohio
(Federal)
VA County of Arlington
(County Board)
The County Board of Arlington County,
Virginia v. Purdue Pharma L.P., et al. 1:21-op-45078 N.D. Ohio (Federal)
VA County of Bland
Bland County, Virginia v.

AmerisourceBergen Drug Corporation, et
al.
1:18-op-46065 N.D. Ohio
(Federal)
VA County of Botetourt Botetourt County, Virginia v. Purdue Pharma L.P., et al. 1:20-op-45064 N.D. Ohio
(Federal)
VA County of Buchanan Buchanan County, Virginia v. Purdue Pharma L.P., et al. 1:19-op-45253 N.D. Ohio
(Federal)
VA County of Carroll
Carroll County, Virginia v.

AmerisourceBergen Drug Corporation, et
al.
1:18-op-46068 N.D. Ohio
(Federal)
VA County of Charlotte Charlotte County, Virginia v. Purdue Pharma L.P., et al. 1:19-op-45851 N.D. Ohio
(Federal)
VA County of
Chesterfield
Chesterfield County, Virginia v. Teva
Pharmaceuticals USA, Inc., et al. 1:20-op-45173 N.D. Ohio (Federal)
VA County of Culpeper Culpeper County, Virginia v. Purdue Pharma L.P., et al. 1:19-op-45849 N.D. Ohio
(Federal)
VA County of
Cumberland
Cumberland County, Virginia v. Purdue
Pharma L.P., et al. 1:19-op-46153 N.D. Ohio
(Federal)
VA County of
Dickenson
Dickenson County v. Purdue Pharma
L.P., et al. 1:19-op-45252 N.D. Ohio
(Federal)
VA County of
Dinwiddie
Dinwiddie County, Virginia v. Purdue
Pharma L.P., et al. 1:20-op-45291 N.D. Ohio
(Federal)
VA
County of Fairfax
(Board of
Supervisors)
Fairfax County, Virginia, by its Board of
Supervisors v. Purdue Pharma L.P., et al. 1:19-op-45766 N.D. Ohio (Federal)
VA County of Fauquier Fauquier County, Virginia v. Purdue Pharma L.P., et al. 1:19-op-45686 N.D. Ohio
(Federal)
VA County of Floyd Floyd County, Virginia v. Purdue Pharma L.P., et al. 1:19-op-45698 N.D. Ohio
(Federal)
VA County of Franklin Franklin County, Virginia v. Purdue Pharma L.P., et al. 1:19-op-45701 N.D. Ohio
(Federal)

C-262
State Subdivision/Special
District Case Caption Case No. Jurisdiction
VA County of Frederick Frederick County, Virginia v. Teva Pharmaceuticals USA, Inc., et al. 1:20-op-45233 N.D. Ohio (Federal)
VA County of Giles Giles County v. Purdue Pharma L.P., et al. 1:19-op-45236 N.D. Ohio
(Federal)
VA County of
Goochland
Goochland County, Virginia v. Teva
Pharmaceuticals USA, Inc., et al. 1:20-op-45175 N.D. Ohio (Federal)
VA County of Grayson
Grayson County, Virginia v.

AmerisourceBergen Drug Corporation, et
al.
1:18-op-46069 N.D. Ohio
(Federal)
VA County of
Greensville
Greensville County v. Purdue Pharma
L.P., et al. 1:19-op-45848 N.D. Ohio
(Federal)
VA County of Halifax Halifax County, Virginia v. Purdue Pharma L.P., et al. 1:19-op-45692 N.D. Ohio
(Federal)
VA County of Henrico Henrico County, Virginia v. Teva
Pharmaceuticals USA, Inc., et al. 1:20-op-45172 N.D. Ohio (Federal)
VA County of Henry Henry County, Virginia v. Purdue
Pharma L.P., et al. 1:19-op-45245 N.D. Ohio
(Federal)
VA County of Isle of
Wight
Isle of Wight County, Virginia v. Teva
Pharmaceuticals USA, Inc., et al. 1:20-op-45145 N.D. Ohio (Federal)
VA County of King and
Queen
King and Queen County, Virginia v. Teva
Pharmaceuticals USA, Inc., et al. 1:20-op-45138 N.D. Ohio (Federal)
VA County of Lee Lee County, Virginia v. Purdue Pharma
L.P., et al. 1:19-op-45251 N.D. Ohio
(Federal)
VA County of Loudoun Loudoun County, Virginia v. Purdue Pharma L.P., et al. 1:19-op-45842 N.D. Ohio
(Federal)
VA County of Louisa Louisa County, Virginia v. Purdue
Pharma L.P., et al. 1:19-op-45720 N.D. Ohio
(Federal)
VA County of Madison Madison County, Virginia v. Purdue Pharma L.P., et al. 1:19-op-45702 N.D. Ohio
(Federal)
VA County of
Mecklenburg
Mecklenburg County, Virginia v. Purdue
Pharma L.P., et al. 1:20-op-45174 N.D. Ohio
(Federal)
VA County of
Montgomery
Montgomery County, Virginia v. Purdue
Pharma L.P., et al. 1:19-op-45234 N.D. Ohio
(Federal)
VA County of
Northampton
Northampton County, Virginia v. Teva
Pharmaceuticals USA, Inc., et al. 1:20-op-45144 N.D. Ohio (Federal)
VA County of
Northumberland
Northumberland County, Virginia v.

Purdue Pharma L.P., et al. 1:19-op-45688 N.D. Ohio
(Federal)
VA County of Page Page County v. Purdue Pharma L.P., et al. 1:19-op-45275 N.D. Ohio
(Federal)
VA County of Patrick Patrick County, Virginia v. Purdue Pharma L.P., et al. 1:19-op-46149 N.D. Ohio
(Federal)
VA County of
Pittsylvania Pittsylvania v. Purdue Pharma L.P., et al. 1:19-op-45247 N.D. Ohio (Federal)
VA County of Prince
George
Prince George County, Virginia v. Purdue
Pharma L.P., et al. 1:19-op-45929 N.D. Ohio
(Federal)
VA
County of Prince
William (Board of
County Supervisors)
The Board of County Supervisor of Prince
William County v. Purdue Pharma L.P.,
et al.
1:19-op-45687 N.D. Ohio
(Federal)
VA County of Pulaski
Pulaski County, Virginia v.

AmerisourceBergen Drug Corporation, et
al.
1:18-op-46076 N.D. Ohio
(Federal)
VA County of
Richmond
City of Richmond v. AmerisourceBergen
Drug Corporation, et al. 1:19-op-45546 N.D. Ohio
(Federal)

C-263
State Subdivision/Special
District Case Caption Case No. Jurisdiction
VA County of Roanoke Roanoke County, Virginia v. Purdue Pharma L.P., et al. 1:19-op-45695 N.D. Ohio
(Federal)
VA County of
Rockbridge
Rockbridge County, Virginia v. Purdue
Pharma L.P., et al. 1:19-op-45694 N.D. Ohio
(Federal)
VA County of Russell
Russell County, Virginia v.

AmerisourceBergen Drug Corporation, et
al.
1:18-op-46073 N.D. Ohio
(Federal)
VA
County of Scott
(Board of
Supervisors)
Scott County Board of Supervisors v.

AmerisourceBergen Drug Corporation, et
al.
1:18-op-46074 N.D. Ohio
(Federal)
VA County of
Shenandoah
Shenandoah County, Virginia v. Purdue
Pharma L.P., et al. 1:19-op-46150 N.D. Ohio
(Federal)
VA County of Smyth
Smyth County, Virginia v.

AmerisourceBergen Drug Corporation, et
al.
1:18-op-46077 N.D. Ohio
(Federal)
VA County of Stafford Stafford County, Virginia v. Teva Pharmaceuticals USA, Inc., et al. 1:20-op-45178 N.D. Ohio (Federal)
VA County of Tazewell
Tazewell County, Virginia v.

AmerisourceBergen Drug Corporation, et
al.
1:18-op-46167 N.D. Ohio
(Federal)
VA County of Warren
Westmoreland County, Virginia;
Richmond County, Virginia; Warren
County, Virginia v. McKesson
Corporation, et al.
1:19-op-45993 N.D. Ohio
(Federal)
VA County of
Washington
Washington County, Virginia v. Purdue
Pharma L.P., et al. 1:19-op-45254 N.D. Ohio
(Federal)
VA County of
Westmoreland
Westmoreland County, Virginia;
Richmond County, Virginia; Warren
County, Virginia v. McKesson
Corporation, et al.
1:19-op-45993 N.D. Ohio
(Federal)
VA
County of Wise
(Board of
Supervisors)
Wise County Board of Supervisors v.

Purdue Pharma L.P., et al. 1:19-op-45907 N.D. Ohio
(Federal)
VA County of Wythe
Wythe County, Virginia v.

AmerisourceBergen Drug Corporation, et
al.
1:18-op-46072 N.D. Ohio
(Federal)
VA Sheriff of Virginia
Beach City
City of Virginia Beach and Sheriff of the
City of Virginia Beach v.

AmerisourceBergen Drug Corporation, et
al.
1:18-op-46137 N.D. Ohio
(Federal)
VA Town of Richlands The Town of Richlands, Virginia v. Teva Pharmaceuticals USA, Inc., et al. 1:20-op-45193 N.D. Ohio (Federal)
VT City of St. Albans City of St, Albans, Vermont v. Purdue Pharma L.P., et al. 1:19-op-45721 N.D. Ohio
(Federal)
WA City of Anacortes
City of Anacortes and Sedro-Woolley
School District v. Purdue Pharma L.P., et
al.
1:19-op-45029 N.D. Ohio
(Federal)
WA City of Bainbridge
Island
City of Bainbridge Island v. Purdue
Pharma L.P., et al. 1:19-op-45981 N.D. Ohio
(Federal)
WA City of Burlington
Skagit County, City of Mount Vernon,
City of Sedro-Woolley, City of Burlington,
LA Conner School District and Mount
1:18-op-45173 N.D. Ohio
(Federal)

C-264
State Subdivision/Special
District Case Caption Case No. Jurisdiction
Vernon School District v. Purdue Pharma
L.P., et al.

WA City of Everett City of Everett v. Purdue Pharma L.P., et al. 1:17-op-45046 N.D. Ohio
(Federal)
WA City of Kent City of Kent v. Purdue Pharma L.P., et al. 1:18-op-45590 N.D. Ohio (Federal)
WA City of Kirkland City of Kirkland v. Teva Pharmaceuticals USA, Inc., et al. 1:20-op-45121 N.D. Ohio
(Federal)
WA City of Lakewood City of Lakewood v. Purdue Pharma, Inc., et al. 1:19-op-45221 N.D. Ohio
(Federal)
WA City of Mount
Vernon
Skagit County, City of Mount Vernon,
City of Sedro-Woolley, City of Burlington,
LA Conner School District and Mount
Vernon School District v. Purdue Pharma
L.P., et al.
1:18-op-45173 N.D. Ohio
(Federal)
WA City of Olympia City of Olympia v. Purdue Pharma L.P., et al. 1:18-op-46021 N.D. Ohio
(Federal)
WA City of Seattle City of Seattle v. Purdue Pharma L.P., et al.
17-2-25504-
1SEA
WA - King
County
Superior
Court (State)
WA City of Sedro-
Woolley
Skagit County, City of Mount Vernon,
City of Sedro-Woolley, City of Burlington,
LA Conner School District and Mount
Vernon School District v. Purdue Pharma
L.P., et al.
1:18-op-45173 N.D. Ohio
(Federal)
WA City of Spokane City of Spokane v. Teva Pharmaceuticals USA, Inc., et al. 1:19-op-46092 N.D. Ohio
(Federal)
WA City of Tacoma City of Tacoma v. Purdue Pharma L.P., et al. 1:17-op-45047 N.D. Ohio
(Federal)
WA City of Vancouver City of Vancouver v. Purdue Pharma L.P., et al. 1:19-op-45908 N.D. Ohio
(Federal)
WA County of Chelan Chelan County v. Purdue Pharma L.P., et al. 1:18-op-46139 N.D. Ohio
(Federal)
WA County of Clallam Clallam County v. Purdue Pharma L.P., et al. 1:18-op-45612 N.D. Ohio
(Federal)
WA County of Clark Clark County v. Purdue Pharma L.P., et al. 1:18-op-45410 N.D. Ohio
(Federal)
WA County of Franklin Franklin County v. Purdue Pharma L.P., et al 1:18-op-45944 N.D. Ohio
(Federal)
WA County of Island Island County v. Purdue Pharma L.P., et al. 1:18-op-45982 N.D. Ohio
(Federal)
WA County of Jefferson Jefferson County v. Purdue Pharma, Inc., et al. 1:18-op-46023 N.D. Ohio
(Federal)
WA County of King King County v. Purdue Pharma L.P., et al. 1:18-op-45231 N.D. Ohio
(Federal)
WA County of Kitsap Kitsap County v. Purdue Pharma L.P., et al. 1:18-op-45956 N.D. Ohio
(Federal)
WA County of Kittitas Kittitas County v. Purdue Pharma, Inc., et al. 1:18-op-46008 N.D. Ohio
(Federal)
WA County of Lewis Lewis County, Washington v. Purdue
Pharma L.P., et al. 1:18-op-46301 N.D. Ohio
(Federal)

C-265
State Subdivision/Special
District Case Caption Case No. Jurisdiction
WA County of Lincoln Lincoln County v. Purdue Pharma L.P., et al. 1:19-op-45962 N.D. Ohio
(Federal)
WA County of Pierce Pierce County v. Purdue Pharma L.P., et al 1:18-op-45195 N.D. Ohio
(Federal)
WA County of San Juan San Juan County v. Purdue Pharma L.P., et al. 1:18-op-46291 N.D. Ohio
(Federal)
WA County of Skagit
Skagit County, City of Mount Vernon,
City of Sedro-Woolley, City of Burlington,
LA Conner School District and Mount
Vernon School District v. Purdue Pharma
L.P., et al.
1:18-op-45173 N.D. Ohio
(Federal)
WA County of
Snohomish
Snohomish County v. Purdue Pharma
L.P., et al. 1:19-op-45370 N.D. Ohio
(Federal)
WA County of Spokane Spokane County v. Purdue Pharma L.P., et al. 1:18-op-45943 N.D. Ohio
(Federal)
WA County of Thurston Thurston County v. Purdue Pharma L.P., et al. 1:18-op-45409 N.D. Ohio
(Federal)
WA County of Walla
Walla
Walla Walla County v. Purdue Pharma
L.P., et al. 1:18-op-46010 N.D. Ohio
(Federal)
WA County of Whatcom Whatcom County v. Purdue Pharma L.P., et al. 1:18-op-45954 N.D. Ohio
(Federal)
WA County of Whitman Whitman County v. Purdue Pharma L.P., et al. 1:18-op-46009 N.D. Ohio
(Federal)
WA La Conner School
District
Skagit County, City of Mount Vernon,
City of Sedro-Woolley, City of Burlington,
La Conner School District and Mount
Vernon School District v. Purdue Pharma
L.P., et al.
1:18-op-45173 N.D. Ohio
(Federal)
WA Mount Vernon
School District
Skagit County, City of Mount Vernon,
City of Sedro-Woolley, City of Burlington,
La Conner School District and Mount
Vernon School District v. Purdue Pharma
L.P., et al.
1:18-op-45173 N.D. Ohio
(Federal)
WA Sedro-Woolley
School District
City of Anacortes and Sedro-Woolley
School District v. Purdue Pharma L.P., et
al.
1:19-op-45029 N.D. Ohio
(Federal)
WI City of Cudahy The City of Cudahy v. Actavis Pharma, Inc., et al. 1:21-op-45097 N.D. Ohio
(Federal)
WI City of Franklin The City of Franklin v. Actavis Pharma, Inc., et al. 1:21-op-45101 N.D. Ohio
(Federal)
WI City of Greenfield The City of Greenfield v. Actavis Pharma, Inc., et al. 1:21-op-45102 N.D. Ohio
(Federal)
WI City of Kenosha City of Kenosha, Wisconsin v. Teva
Pharmaceuticals USA, Inc., et al. 1:20-op-45011 N.D. Ohio (Federal)
WI City of Marinette City of Marinette v. Teva
Pharmaceuticals USA, Inc., et al. 1:19-op-46181 N.D. Ohio (Federal)
WI City of Milwaukee City of Milwaukee, Wisconsin v. Teva Pharmaceuticals USA, Inc., et al. 1:20-op-45044 N.D. Ohio (Federal)
WI City of Oak Creek The City of Oak Creek v. Actavis Pharma, Inc., et al. 1:21-op-45103 N.D. Ohio
(Federal)
WI City of South
Milwaukee
City of South Milwaukee v. Actavis
Pharma, Inc., et al. 2021CV002934
WI - Circuit
Court of
Milwaukee

C-266
State Subdivision/Special
District Case Caption Case No. Jurisdiction
County
(State)
WI City of Superior City of Superior v. Purdue Pharma L.P., et al. 1:19-op-45331 N.D. Ohio
(Federal)
WI City of Wauwatosa The City of Wauwatosa v. Actavis
Pharma, Inc., et al. 1:21-op-45104 N.D. Ohio
(Federal)
WI City of West Allis The City of West Allis v. Actavis Pharma, Inc., et al. 1:21-op-45105 N.D. Ohio
(Federal)
WI County of Adams Adams County v. Purdue Pharma L.P., et al. 1:17-op-45093 N.D. Ohio
(Federal)
WI County of Ashland Ashland County v. Purdue Pharma L.P., et al. 1:17-op-45130 N.D. Ohio
(Federal)
WI County of Barron
Barron County, La Crosse County,
Lafayette County and Menominee County
v. Purdue Pharma L.P., et al.
1:18-op-45277 N.D. Ohio
(Federal)
WI County of Bayfield Bayfield County v. Purdue Pharma L.P., et al. 1:17-op-45168 N.D. Ohio
(Federal)
WI County of Brown
Brown County, Crawford County, Iron
County, Juneau County, Kewaunee
County, Outagamie County, v. Purdue
Pharma L.P., et al.
1:18-op-45117 N.D. Ohio
(Federal)
WI County of Buffalo Buffalo County v. Purdue Pharma L.P., et al. 1:17-op-45141 N.D. Ohio
(Federal)
WI County of Burnett Burnett County v. Purdue Pharma L.P., et al. 1:17-op-45131 N.D. Ohio
(Federal)
WI County of Calumet Calumet County v. Purdue Pharma L.P., et al. 1:17-op-45142 N.D. Ohio
(Federal)
WI County of Chippewa Chippewa County v. Purdue Pharma L.P., et al. 1:17-op-45132 N.D. Ohio
(Federal)
WI County of Clark Clark County v. Purdue Pharma L.P., et al. 1:17-op-45150 N.D. Ohio
(Federal)
WI County of Columbia Columbia County v. Purdue Pharma L.P., et al. 1:17-op-45118 N.D. Ohio
(Federal)
WI County of Crawford
Brown County, Crawford County, Iron
County, Juneau County, Kewaunee
County, Outagamie County, v. Purdue
Pharma L.P., et al.
1:18-op-45117 N.D. Ohio
(Federal)
WI County of Dane
Dane County, Wisconsin v.

AmerisourceBergen Drug Corporation, et
al.
1:18-op-45802 N.D. Ohio
(Federal)
WI County of Dodge Dodge County v. Purdue Pharma L.P., et al. 1:17-op-45143 N.D. Ohio
(Federal)
WI County of Door Door County v. Purdue Pharma L.P., et al. 1:17-op-45104 N.D. Ohio
(Federal)
WI County of Douglas Douglas County v. Purdue Pharma L.P., et al. 1:17-op-45107 N.D. Ohio
(Federal)
WI County of Dunn Dunn County v. Purdue Pharma L.P., et al. 1:17-op-45133 N.D. Ohio
(Federal)
WI County of Eau
Claire
Eau Claire County v. Purdue Pharma
L.P., et al. 1:17-op-45112 N.D. Ohio
(Federal)
WI County of Florence Florence County v. Purdue Pharma L.P., et al. 1:17-op-45125 N.D. Ohio
(Federal)

C-267
State Subdivision/Special
District Case Caption Case No. Jurisdiction
WI County of Fond du
Lac
Fond du Lac County v. Purdue Pharma
L.P., et al. 1:17-op-45106 N.D. Ohio
(Federal)
WI County of Forest Forest County v. Purdue Pharma L.P., et al. 1:17-op-45134 N.D. Ohio
(Federal)
WI County of Grant Grant County v. Purdue Pharma L.P., et al. 1:17-op-45115 N.D. Ohio
(Federal)
WI County of Green Green County v. Purdue Pharma L.P., et al. 1:17-op-45096 N.D. Ohio
(Federal)
WI County of Green
Lake
Green Lake County, Taylor County and
Vilas County v. Purdue Pharma L.P., et
al.
1:18-op-45832 N.D. Ohio
(Federal)
WI County of Iowa Iowa County v. Purdue Pharma L.P., et al. 1:17-op-45099 N.D. Ohio
(Federal)
WI County of Iron
Brown County, Crawford County, Iron
County, Juneau County, Kewaunee
County, Outagamie County, v. Purdue
Pharma L.P., et al.
1:18-op-45117 N.D. Ohio
(Federal)
WI County of Jackson Jackson County v. Purdue Pharma L.P., et al. 1:17-op-45121 N.D. Ohio
(Federal)
WI County of Jefferson Jefferson County v. Purdue Pharma L.P., et al. 1:17-op-45122 N.D. Ohio
(Federal)
WI County of Juneau
Brown County, Crawford County, Iron
County, Juneau County, Kewaunee
County, Outagamie County, v. Purdue
Pharma L.P., et al.
1:18-op-45117 N.D. Ohio
(Federal)
WI County of Kenosha Kenosha County v. Purdue Pharma L.P., et al. 1:17-op-45144 N.D. Ohio
(Federal)
WI County of
Kewaunee
Brown County, Crawford County, Iron
County, Juneau County, Kewaunee
County, Outagamie County, v. Purdue
Pharma L.P., et al.
1:18-op-45117 N.D. Ohio
(Federal)
WI County of La Crosse
Barron County, La Crosse County,
Lafayette County and Menominee County
v. Purdue Pharma L.P., et al.
1:18-op-45277 N.D. Ohio
(Federal)
WI County of Lafayette
Barron County, La Crosse County,
Lafayette County and Menominee County
v. Purdue Pharma L.P., et al.
1:18-op-45277 N.D. Ohio
(Federal)
WI County of Langlade Langlade County v. Purdue Pharma L.P., et al. 1:17-op-45124 N.D. Ohio
(Federal)
WI County of Lincoln Lincoln County v. Purdue Pharma L.P., et al. 1:17-op-45167 N.D. Ohio
(Federal)
WI County of
Manitowoc
Manitowoc County v. Purdue Pharma
L.P., et al. 1:17-op-45135 N.D. Ohio
(Federal)
WI County of Marathon Marathon County v. Purdue Pharma L.P., et al. 1:17-op-45095 N.D. Ohio
(Federal)
WI County of Marinette Marinette County v. Purdue Pharma L.P., et al. 1:17-op-45145 N.D. Ohio
(Federal)
WI County of
Marquette
Marquette County v. Purdue Pharma
L.P., et al. 1:17-op-45136 N.D. Ohio
(Federal)
WI County of
Menominee
Barron County, La Crosse County,
Lafayette County and Menominee County
v. Purdue Pharma L.P., et al.
1:18-op-45277 N.D. Ohio
(Federal)

C-268
State Subdivision/Special
District Case Caption Case No. Jurisdiction
WI County of
Milwaukee
Milwaukee County, Wisconsin v.

AmerisourceBergen Drug Corporation, et
al.
1:18-op-45402 N.D. Ohio
(Federal)
WI County of Monroe
Monroe County, Wisconsin v.

AmerisourceBergen Drug Corporation, et
al.
1:17-op-45146 N.D. Ohio
(Federal)
WI County of Oconto
Oconto County, Wisconsin v.

AmerisourceBergen Drug Corporation, et
al.
1:17-op-45120 N.D. Ohio
(Federal)
WI County of Oneida
Oneida County, Wisconsin v.

AmerisourceBergen Drug Corporation, et
al.
1:17-op-45129 N.D. Ohio
(Federal)
WI County of
Outagamie
Brown County, Crawford County, Iron
County, Juneau County, Kewaunee
County, Outagamie County, v. Purdue
Pharma L.P., et al.
1:18-op-45117 N.D. Ohio
(Federal)
WI County of Pierce
Pierce County, Wisconsin v.

AmerisourceBergen Drug Corporation, et
al.
1:17-op-45165 N.D. Ohio
(Federal)
WI County of Price
Price County, Wisconsin v.

AmerisourceBergen Drug Corporation, et
al.
1:17-op-45126 N.D. Ohio
(Federal)
WI County of Rock Rock County v. Purdue Pharma L.P., et al. 1:17-op-45108 N.D. Ohio
(Federal)
WI County of Rusk
Rusk County, Wisconsin v.

AmerisourceBergen Drug Corporation, et
al.
1:17-op-45116 N.D. Ohio
(Federal)
WI County of Sauk
Sauk County, Wisconsin v.

AmerisourceBergen Drug Corporation, et
al.
1:17-op-45098 N.D. Ohio
(Federal)
WI County of Sawyer
Sawyer County, Wisconsin v.

AmerisourceBergen Drug Corporation, et
al.
1:17-op-45137 N.D. Ohio
(Federal)
WI County of Shawano
Shawano County, Wisconsin v.

AmerisourceBergen Drug Corporation, et
al.
1:17-op-45119 N.D. Ohio
(Federal)
WI County of
Sheboygan
Sheboygan County, Wisconsin v.

AmerisourceBergen Drug Corporation, et
al.
1:17-op-45128 N.D. Ohio
(Federal)
WI County of St. Croix St. Croix County v. Purdue Pharma L.P., et al. 1:17-op-45147 N.D. Ohio
(Federal)
WI County of Taylor
Green Lake County, Taylor County and
Vilas County v. Purdue Pharma L.P., et
al.
1:18-op-45832 N.D. Ohio
(Federal)
WI County of
Trempealeau
Trempealeau County v. Purdue Pharma
L.P., et al. 1:17-op-45138 N.D. Ohio
(Federal)
WI County of Vernon
Vernon County, Wisconsin v.

AmerisourceBergen Drug Corporation, et
al.
1:17-op-45148 N.D. Ohio
(Federal)
WI County of Vilas
Green Lake County, Taylor County and
Vilas County v. Purdue Pharma L.P., et
al.
1:18-op-45832 N.D. Ohio
(Federal)

C-269
State Subdivision/Special
District Case Caption Case No. Jurisdiction
WI County of Walworth
Walworth County, Wisconsin v.

AmerisourceBergen Drug Corporation, et
al.
1:18-op-45988 N.D. Ohio
(Federal)
WI County of
Washburn
Washburn County, Wisconsin v.

AmerisourceBergen Drug Corporation, et
al.
1:17-op-45123 N.D. Ohio
(Federal)
WI County of
Washington
Washington County, Wisconsin v.

AmerisourceBergen Drug Corporation, et
al.
1:17-op-45114 N.D. Ohio
(Federal)
WI County of
Waukesha
Waukesha County, Wisconsin v.

AmerisourceBergen Drug Corporation, et
al.
1:18-op-45978 N.D. Ohio
(Federal)
WI County of Waupaca
Waupaca County, Wisconsin v.

AmerisourceBergen Drug Corporation, et
al.
1:17-op-45166 N.D. Ohio
(Federal)
WI County of Waushara
Waushara County, Wisconsin v.

AmerisourceBergen Drug Corporation, et
al.
1:17-op-45139 N.D. Ohio
(Federal)
WI County of Wood
Wood County, Wisconsin v.

AmerisourceBergen Drug Corporation, et
al.
1:17-op-45127 N.D. Ohio
(Federal)
WI Village of Pleasant
Prairie
Village of Pleasant Prairie, Wisconsin v.

Teva Pharmaceuticals USA, Inc., et al. 1:20-op-45010 N.D. Ohio (Federal)
WI Village of
Sturtevant
The Village of Sturtevant v. Actavis
Pharma, Inc. f/k/a Watson Pharma, Inc.,
et al.
2021CV000999
WI - Circuit
Court of
Racine
County
(State)
WY City of Casper City of Casper, Wyoming v. Purdue
Pharma L.P., et al. 1:19-op-45079 N.D. Ohio
(Federal)
WY City of Cheyenne City of Cheyenne v. Purdue Pharma L.P., et al. 1:19-op-45280 N.D. Ohio
(Federal)
WY City of Green River City of Green River, Wyoming v. Purdue Pharma L.P., et al. 1:19-op-45764 N.D. Ohio
(Federal)
WY City of Riverton City of Riverton, Wyoming v. Purdue Pharma L.P., et al. 1:19-op-45558 N.D. Ohio
(Federal)
WY City of Rock
Springs
City of Rock Springs, Wyoming v. Purdue
Pharma L.P., et al. 1:19-op-45265 N.D. Ohio
(Federal)
WY County of Carbon County of Carbon v. Purdue Pharma L.P., et al. 1:18-op-45625 N.D. Ohio
(Federal)
WY County of
Sweetwater
Sweetwater County, Wyoming v. Purdue
Pharma L.P., et al. 1:19-op-45031 N.D. Ohio
(Federal)

D-1

EXHIBIT D
[Intentionally Omitted]

E-1

EXHIBIT E
List of Opioid Remediation Uses
Schedule A
Core Strategies
Settling States and Exhibit G Participants may choose from among the abatement strategies listed in Schedule B. However, priority may be given to the following core abatement strategies (“Core Strategies”).1
A. NALOXONE OR OTHER FDA-APPROVED DRUG TO REVERSE OPIOID

OVERDOSES

1. Expand training for first responders, schools, community support groups and families; and

2. Increase distribution to individuals who are uninsured or whose insurance does not cover the needed service.

B. MEDICATION-ASSISTED TREATMENT (“MAT”) DISTRIBUTION AND

OTHER OPIOID-RELATED TREATMENT

1. Increase distribution of MAT to individuals who are uninsured or whose insurance does not cover the needed service;

2. Provide education to school-based and youth-focused programs that discourage or prevent misuse;

3. Provide MAT education and awareness training to healthcare providers, EMTs, law enforcement, and other first responders; and

4. Provide treatment and recovery support services such as residential and inpatient treatment, intensive outpatient treatment, outpatient therapy or counseling, and recovery housing that allow or integrate medication and with other support services.

C. PREGNANT & POSTPARTUM WOMEN

1. Expand Screening, Brief Intervention, and Referral to Treatment (“SBIRT”) services to non-Medicaid eligible or uninsured pregnant women;

2. Expand comprehensive evidence-based treatment and recovery services, including MAT, for women with co-occurring Opioid Use Disorder (“OUD”) and other

1 As used in this Schedule A, words like “expand,” “fund,” “provide” or the like shall not indicate a preference for new or existing programs.

E-2
Substance Use Disorder (“SUD”)/Mental Health disorders for uninsured individuals for up to 12 months postpartum; and

3. Provide comprehensive wrap-around services to individuals with OUD, including housing, transportation, job placement/training, and childcare.

D. EXPANDING TREATMENT FOR NEONATAL ABSTINENCE SYNDROME (“NAS”)

1. Expand comprehensive evidence-based and recovery support for NAS babies;

2. Expand services for better continuum of care with infant-need dyad; and

3. Expand long-term treatment and services for medical monitoring of NAS babies and their families.

E. EXPANSION OF WARM HAND-OFF PROGRAMS AND RECOVERY SERVICES

1. Expand services such as navigators and on-call teams to begin MAT in hospital emergency departments;

2. Expand warm hand-off services to transition to recovery services;

3. Broaden scope of recovery services to include co-occurring SUD or mental health conditions;

4. Provide comprehensive wrap-around services to individuals in recovery, including housing, transportation, job placement/training, and childcare; and

5. Hire additional social workers or other behavioral health workers to facilitate expansions above.

F. TREATMENT FOR INCARCERATED POPULATION

1. Provide evidence-based treatment and recovery support, including MAT for persons with OUD and co-occurring SUD/MH disorders within and transitioning out of the criminal justice system; and

2. Increase funding for jails to provide treatment to inmates with OUD.

G. PREVENTION PROGRAMS

1. Funding for media campaigns to prevent opioid use (similar to the FDA’s “Real Cost” campaign to prevent youth from misusing tobacco);

E-3

2. Funding for evidence-based prevention programs in schools;

3. Funding for medical provider education and outreach regarding best prescribing practices for opioids consistent with CDC guidelines, including providers at hospitals (academic detailing);

4. Funding for community drug disposal programs; and

5. Funding and training for first responders to participate in pre-arrest diversion programs, post-overdose response teams, or similar strategies that connect at-risk individuals to behavioral health services and supports.

H. EXPANDING SYRINGE SERVICE PROGRAMS

1. Provide comprehensive syringe services programs with more wrap-around services, including linkage to OUD treatment, access to sterile syringes and linkage to care and treatment of infectious diseases.

I. EVIDENCE-BASED DATA COLLECTION AND RESEARCH ANALYZING THE

EFFECTIVENESS OF THE ABATEMENT STRATEGIES WITHIN THE STATE

E-4
Schedule B
Approved Uses
Support treatment of Opioid Use Disorder (OUD) and any co-occurring Substance Use Disorder or Mental Health (SUD/MH) conditions through evidence-based or evidence-informed programs or strategies that may include, but are not limited to, the following:

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 through evidence-based or evidence-informed programs or strategies that may include, but are not limited to, those that:2

1. Expand availability of treatment for OUD and any co-occurring SUD/MH conditions, including all forms of Medication-Assisted Treatment (“MAT”) approved by the U.S. Food and Drug Administration.

2. Support and reimburse evidence-based services that adhere to the American Society of Addiction Medicine (“ASAM”) continuum of care for OUD and any co-occurring SUD/MH conditions.

3. Expand telehealth to increase access to treatment for OUD and any co -occurring SUD/MH conditions, 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 or evidence-informed practices such as adequate methadone dosing and low threshold approaches to treatment.

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 and for persons who have experienced an opioid overdose.

6. Provide treatment of trauma for individuals with OUD (e.g., violence, sexual assault, human trafficking, or adverse childhood experiences) and family members (e.g., surviving family members after an overdose or overdose fatality), and training of health care personnel to identify and address such trauma.

2 As used in this Schedule B, words like “expand,” “fund,” “provide” or the like shall not indicate a preference for new or existing programs.

E-5

7. Support evidence-based withdrawal management services for people with OUD and any co-occurring mental health conditions.

8. Provide training on MAT for health care providers, first responders, 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.

10. Offer fellowships for addiction medicine specialists for direct patient care, instructors, and clinical research for treatments.

11. Offer scholarships and supports for behavioral health practitioners or workers involved in addressing OUD and any co-occurring SUD/MH or mental health conditions, including, but not limited to, training, scholarships, fellowships, loan repayment programs, or other incentives for providers to work in rural or underserved areas.

12. 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.

13. Disseminate 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.

14. Develop and disseminate 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 recovery from OUD and any co-occurring SUD/MH conditions through evidence-based or evidence-informed programs or strategies that may include, but are not limited to, the programs or strategies that:

1. Provide comprehensive wrap-around services to individuals with OUD and any co- occurring SUD/MH conditions, including housing, transportation, education, job placement, job training, or childcare.

2. Provide the full continuum of care of treatment and recovery services for OUD and any co-occurring SUD/MH conditions, including supportive housing, peer support services and counseling, community navigators, case management, and connections to community-based services.

E-6

3. 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.

4. Provide access to housing for people with OUD and any co-occurring SUD/MH conditions, including supportive housing, recovery housing, housing assistance programs, training for housing providers, or recovery housing programs that allow or integrate FDA-approved mediation with other support services.

5. Provide community support services, including social and legal services, to assist in deinstitutionalizing persons with OUD and any co-occurring SUD/MH conditions.

6. 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.

7. Provide or support transportation to treatment or recovery programs or services for persons with OUD and any co-occurring SUD/MH conditions.

8. Provide employment training or educational services for persons in treatment for or recovery from OUD and any co-occurring SUD/MH conditions.

9. 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.

10. 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 support the person with OUD in the family.

11. Provide training and development of procedures for government staff to appropriately interact and provide social and other services to individuals with or in recovery from OUD, including reducing stigma.

12. Support stigma reduction efforts regarding treatment and support for persons with OUD, including reducing the stigma on effective treatment.

13. Create or support culturally appropriate services and programs for persons with OUD and any co-occurring SUD/MH conditions, including new Americans.

14. Create and/or support recovery high schools.

15. Hire or train behavioral health workers to provide or expand any of the services or supports listed above.

E-7

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 through evidence-based or evidence-informed programs or strategies that may include, but are not limited to, those that:

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. Fund SBIRT programs to reduce the transition from use to disorders, including SBIRT services to pregnant women who are uninsured or not eligible for Medicaid.

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.

4. Purchase automated versions of SBIRT and support ongoing costs of the technology.

5. Expand services such as navigators and on-call teams to begin MAT in hospital emergency departments.

6. Provide training for emergency room personnel treating opioid overdose patients on post-discharge planning, including community referrals for MAT, recovery case management or support services.

7. Support hospital programs that transition persons with OUD and any co -occurring SUD/MH conditions, or persons who have experienced an opioid overdose, into clinically appropriate follow-up care through a bridge clinic or similar approach.

8. Support crisis stabilization centers that serve as an alternative to hospital emergency departments for persons with OUD and any co-occurring SUD/MH conditions or persons that have experienced an opioid overdose.

9. 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.

10. 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 or to persons who have experienced an opioid overdose.

E-8

11. Expand warm hand-off services to transition to recovery services.

12. 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.

13. Develop and support best practices on addressing OUD in the workplace.

14. Support assistance programs for health care providers with OUD.

15. Engage non-profits and the faith community as a system to support outreach for treatment.

16. 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.

D. ADDRESS THE NEEDS OF CRIMINAL JUSTICE-INVOLVED PERSONS

Address the needs of persons with OUD and any co-occurring SUD/MH conditions who are involved in, are at risk of becoming involved in, or are transitioning out of the criminal justice system through evidence-based or evidence-informed programs or strategies that may include, but are not limited to, those that:

1. Support pre-arrest or pre-arraignment diversion and deflection strategies for persons with OUD and any co-occurring SUD/MH conditions, 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; or

f. Co-responder and/or alternative responder models to address OUD-related 911 calls with greater SUD expertise.

E-9

2. Support pre-trial services that connect individuals with OUD and any co-occurring SUD/MH conditions to evidence-informed treatment, including MAT, and related services.

3. Support treatment and recovery courts that provide evidence-based options for persons with OUD and any co-occurring SUD/MH conditions.

4. Provide evidence-informed treatment, including MAT, recovery support, harm reduction, or other appropriate services to individuals with OUD and any co- occurring SUD/MH conditions who are incarcerated in jail or prison.

5. Provide evidence-informed treatment, including MAT, recovery support, harm reduction, or other appropriate services to individuals with OUD and any co- occurring SUD/MH conditions who are leaving jail or prison or 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 to law enforcement, correctional, or judicial personnel or to providers of treatment, recovery, harm reduction, 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, and the needs of their families, including babies with neonatal abstinence syndrome (“NAS”), through evidence-based or evidence-informed programs or strategies that may include, but are not limited to, those that:

1. Support evidence-based or evidence-informed 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, and other measures to educate and provide support to families affected by Neonatal Abstinence Syndrome.

2. Expand comprehensive evidence-based treatment and recovery services, including MAT, for uninsured women with OUD and any co-occurring SUD/MH conditions for up to 12 months postpartum.

E-10

3. Provide training for obstetricians or other healthcare personnel who work with pregnant women and their families regarding treatment of OUD and any co- occurring SUD/MH conditions.

4. Expand comprehensive evidence-based treatment and recovery support for NAS babies; expand services for better continuum of care with infant-need dyad; and expand long-term treatment and services for medical monitoring of NAS babies and their families.

5. 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 NAS get referred to appropriate services and receive a plan of safe care.

6. Provide child and family supports for parenting women with OUD and any co- occurring SUD/MH conditions.

7. Provide enhanced family support and child care services for parents with OUD and any co-occurring SUD/MH conditions.

8. 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.

9. Offer home-based wrap-around services to persons with OUD and any co-occurring SUD/MH conditions, including, but not limited to, parent skills training.

10. Provide 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

A. 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 or evidence-informed programs or strategies that may include, but are not limited to, the following:

1. Funding medical provider education and outreach regarding best prescribing practices for opioids consistent with the Guidelines for Prescribing Opioids for Chronic Pain from the U.S. Centers for Disease Control and Prevention, including providers at hospitals (academic detailing).

E-11

2. Training for health care providers regarding safe and responsible opioid prescribing, dosing, and tapering patients off opioids.

3. Continuing Medical Education (CME) on appropriate prescribing of opioids.

4. Providing Support for non-opioid pain treatment alternatives, including training providers to offer or refer to multi-modal, evidence-informed treatment of pain.

5. Supporting 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, 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 in a manner that complies with all relevant privacy and security laws and rules.

6. Ensuring PDMPs incorporate available overdose/naloxone deployment data, including the United States Department of Transportation’s Emergency Medical Technician overdose database in a manner that complies with all relevant privacy and security laws and rules.

7. Increasing electronic prescribing to prevent diversion or forgery.

8. Educating dispensers on appropriate opioid dispensing.

B. PREVENT MISUSE OF OPIOIDS

Support efforts to discourage or prevent misuse of opioids through evidence-based or evidence- informed programs or strategies that may include, but are not limited to, the following:

1. Funding media campaigns to prevent opioid misuse.

2. Corrective advertising or affirmative public education campaigns based on evidence.

3. Public education relating to drug disposal.

4. Drug take-back disposal or destruction programs.

E-12

5. Funding community anti-drug coalitions that engage in drug prevention efforts.

6. Supporting 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”).

7. Engaging non-profits and faith-based communities as systems to support prevention.

8. Funding evidence-based prevention programs in schools or evidence-informed school and community education programs and campaigns for students, families, school employees, school athletic programs, parent-teacher and student associations, and others.

9. 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.

10. Create or support community-based education or intervention services for families, youth, and adolescents at risk for OUD and any co-occurring SUD/MH conditions.

11. 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.

12. Support greater access to mental health services and supports for young people, including services and supports provided by school nurses, behavioral health workers or other school staff, to address mental health needs in young people that (when not properly addressed) increase the risk of opioid or another drug misuse.

C. PREVENT OVERDOSE DEATHS AND OTHER HARMS (HARM REDUCTION)

Support efforts to prevent or reduce overdose deaths or other opioid-related harms through evidence-based or evidence-informed programs or strategies that may include, but are not limited to, the following:

1. Increased availability and distribution of naloxone and other drugs that treat overdoses for first responders, overdose patients, individuals with OUD and their friends and family members, schools, community navigators and outreach workers, persons being released from jail or prison, or other members of the general public.

2. Public health entities providing free naloxone to anyone in the community.

E-13

3. Training and education regarding naloxone and other drugs that treat overdoses for first responders, overdose patients, patients taking opioids, families, schools, community support groups, and other members of the general public.

4. Enabling school nurses and other school staff to respond to opioid overdoses, and provide them with naloxone, training, and support.

5. Expanding, improving, or developing 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. Educating first responders regarding the existence and operation of immunity and Good Samaritan laws.

9. Syringe service programs and other evidence-informed programs to reduce harms associated with intravenous drug use, including supplies, staffing, space, peer support services, referrals to treatment, fentanyl checking, connections to care, and the full range of harm reduction and treatment services provided by these programs.

10. Expanding access to testing and treatment for infectious diseases such as HIV and Hepatitis C resulting from intravenous opioid use.

11. Supporting mobile units that offer or provide referrals to harm reduction services, 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.

12. Providing training in harm reduction 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.

13. Supporting screening for fentanyl in routine clinical toxicology testing.

PART THREE: OTHER STRATEGIES

A. FIRST RESPONDERS

In addition to items in section C, D and H relating to first responders, support the following:

1. Education of law enforcement or other first responders regarding appropriate practices and precautions when dealing with fentanyl or other drugs.

E-14

2. Provision of wellness and support services for first responders and others who experience secondary trauma associated with opioid-related emergency events.

B. LEADERSHIP, PLANNING AND COORDINATION

Support efforts to provide leadership, planning, coordination, facilitations, training and technical assistance to abate the opioid epidemic through activities, programs, or strategies that may include, but are not limited to, the following:

1. Statewide, regional, local or community regional planning to identify root causes of addiction and overdose, goals for reducing harms related to the opioid epidemic, and areas and populations with the greatest needs for treatment intervention services, and to support training and technical assistance and other strategies to abate the opioid epidemic described in this opioid abatement strategy list.

2. A dashboard to (a) share reports, recommendations, or plans to spend opioid settlement funds; (b) to show how opioid settlement funds have been spent; (c) to report program or strategy outcomes; or (d) to track, share or visualize key opioid- or health-related indicators and supports as identified through collaborative statewide, regional, local or 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, 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.

C. TRAINING

In addition to the training referred to throughout this document, support training to abate the opioid epidemic through activities, programs, or strategies that may include, but are not limited to, those that:

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. Support 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, or implement other strategies to abate the opioid epidemic described in this opioid abatement strategy list (e.g., health care, primary care, pharmacies, PDMPs, etc.).

E-15
D. RESEARCH

Support opioid abatement research that may include, but is not limited to, the following:

1. Monitoring, surveillance, data collection 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 novel harm reduction and prevention efforts such as the provision of fentanyl test strips.

5. Research on innovative supply-side enforcement efforts such as improved detection of mail-based delivery of synthetic opioids.

6. 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).

7. Epidemiological surveillance of OUD-related behaviors in critical populations, including individuals entering the criminal justice system, including, but not limited to approaches modeled on the Arrestee Drug Abuse Monitoring (“ADAM”) system.

8. Qualitative and quantitative research regarding public health risks and harm reduction opportunities within illicit drug markets, including surveys of market participants who sell or distribute illicit opioids.

9. Geospatial analysis of access barriers to MAT and their association with treatment engagement and treatment outcomes.

F-1
EXHIBIT F-1
List of States and Pre-Credit Overall Allocation Percentages Alabama 1.5958653635%
Alaska 0.2283101787%
American Samoa 0.0171221696%
Arizona 2.3755949882%
Arkansas 0.9322152924%
California 9.9213830698%
Colorado 1.6616291219%
Connecticut 1.2938102647%
Delaware 0.4420285052%
District of Columbia 0.1799774824%
Florida 7.0259134409%
Georgia 2.7882080114%
Guam 0.0480366565%
Hawaii 0.3246488040%
Idaho 0.4919080117%
Illinois 3.3263363702%
Indiana 2.2168933059%
Iowa 0.7419256132%
Kansas 0.7840793410%
Kentucky 1.9963344879%
Louisiana 1.4650905059%
Maine 0.5293231313%
Maryland 2.1106090494%
Massachusetts 2.3035761083%
Michigan 3.4020234989%
Minnesota 1.2972597706%
Mississippi 0.8624327860%
Missouri 2.0056475170%
Montana 0.3125481816%
N. Mariana Islands 0.0167059202%
Nebraska 0.4171546352%
Nevada 1.2017657135%
New Hampshire 0.5784834777%
New Jersey 2.7551354545%
New Mexico 0.7989379794%
New York 5.3903813405%
North Carolina 3.2502525994%

F-2
North Dakota 0.1700251989%
Ohio 4.3567051408%
Oklahoma 1.5322312508%
Oregon 1.3741405009%
Pennsylvania 4.5882419559%
Puerto Rico 0.7101195950%
Rhode Island 0.4465429178%
South Carolina 1.5393083548%
South Dakota 0.1982071487%
Tennessee 2.6881474977%
Texas 6.2932157196%
Utah 1.1466798699%
Vermont 0.2544890561%
Virgin Islands 0.0315673573%
Virginia 2.2801150757%
Washington 2.3189040182%
West Virginia 1.0567416533%
Wisconsin 1.7582560561%
Wyoming 0.1668134842%

F-3
EXHIBIT F-2
List of Eligible Settling States and Overall Allocation Percentages Alabama 1.89200243102%
Alaska 0.27067660158%
American Samoa 0.02029944832%
Arizona 2.81642273552%
Arkansas 1.10520200495%
California 11.44545606988%
Colorado 1.96996965401%
Connecticut 1.53389641887%
Delaware 0.52405361097%
District of Columbia 0.21337503900%
Georgia 3.30560237492%
Guam 0.05695058797%
Hawaii 0.38489232262%
Idaho 0.58318901784%
Illinois 3.94358862758%
Indiana 2.62827154459%
Iowa 0.87960118435%
Kansas 0.92957717690%
Kentucky 2.36678468650%
Maine 0.62754708146%
Maryland 2.50226462938%
Massachusetts 2.73103965821%
Michigan 4.03332065304%
Minnesota 1.53798603302%
Mississippi 1.02247029410%
Missouri 2.37782588971%
Montana 0.37054624593%
N. Mariana Islands 0.01980595749%
Nebraska 0.49456401641%
Nevada 1.42477160259%
New Hampshire 0.68582987703%
New Jersey 3.26639270254%
New Mexico 0.94719306138%
North Carolina 3.85338635698%
North Dakota 0.20157595806%
Ohio 5.16515798008%
Oklahoma 1.81656004174%

F-4
Oregon 1.62913315104%
Pennsylvania 5.43965996948%
Puerto Rico 0.84189307619%
South Carolina 1.82495040990%
South Dakota 0.23498749685%
Tennessee 3.18697411246%
Texas 7.46101752221%
Utah 1.35946374363%
Vermont 0.30171336741%
Virgin Islands 0.03742516012%
Virginia 2.70322507443%
Washington 2.74921189468%
Wisconsin 2.08452718413%
Wyoming 0.19776826088%

G-1

EXHIBIT G
Subdivisions and Special Districts Eligible to Receive Direct Allocations from the Subdivision Fund and Subdivision Fund Allocation Percentages The Subdivisions and Special Districts set forth on this Exhibit G are eligible to receive direct allocations from the Subdivision Fund, if such Subdivisions and Special Districts are otherwise eligible to receive such funds under this Agreement. By default, the Subdivisions and Special Districts set forth on this Exhibit G shall include all Subdivisions and Special Districts set forth on Exhibit G of the national opioid settlement agreement dated July 21, 2021 with Janssen Pharmaceuticals, Inc., et al., including all amendments up to the Preliminary Agreement Date of this agreement. A State may elect to add any additional Subdivisions and Special Districts to this Exhibit G at any time prior to the Initial Participation Date.

Immediately upon the effectiveness of any State-Subdivision Agreement, Allocation Statute, Statutory Trust, or voluntary redistribution allowed by subsection VIII.E.3 (or upon the effectiveness of an amendment to any State-Subdivision Agreement, Allocation Statute, Statutory Trust, or voluntary redistribution allowed by subsection VIII.E.3) that addresses allocation from the Subdivision Fund, whether before or after the Initial Participation Date, this Exhibit G will automatically be amended to reflect the allocation from the Subdivision Fund pursuant to the State- Subdivision Agreement, Allocation Statute, Statutory Trust, or voluntary redistribution allowed by subsection VIII.E.3.

For the avoidance of doubt, inclusion on this Exhibit G shall not create any claim for any amount of the Settlement Fund, and no such amounts shall be allocated or distributed to any Subdivision or Special District included herein if such Subdivision or Special District does not otherwise meet all requirements to receive any such funds pursuant to the Agreement. (List Forthcoming)

H-1

EXHIBIT H
[Intentionally Omitted]

I-1

EXHIBIT I
Subdivisions with a Population Greater than 10,0001
(See Distributors’ Exhibit I)

1 Entities denoted with an asterisk (*) are Primary Subdivisions with a population greater than 30,000. All other entities listed have populations greater than 10,000 but less than 30,000.

J-1
EXHIBIT J-1
AbbVie Entities

Exhibit 21
List Of Subsidiaries

The following is a list of subsidiaries of AbbVie Inc. as of December 31, 2021. AbbVie is not a subsidiary of any other corporation.

Domestic Subsidiaries Incorporation
AbbVie Aviation LLC Illinois
AbbVie Biopharmaceuticals LLC Delaware
AbbVie Bioresearch Center Inc.Delaware
AbbVie Biotech Ventures Inc.Delaware
AbbVie Biotherapeutics Inc.Delaware
AbbVie Domestic Holdings Inc.Delaware
AbbVie Endocrine Inc.Delaware
AbbVie Endocrinology Inc. (d/b/a Pharmacy Solutions)Delaware AbbVie Finance Corporation Delaware
AbbVie Finance LLC Delaware
AbbVie Global Inc.Delaware
AbbVie Global Holdings Inc.Delaware
AbbVie Holdco Inc.Delaware
AbbVie Holdings Inc.Delaware
AbbVie International Inc.Delaware
AbbVie Investments Inc.Delaware
AbbVie Pharma Inc.Delaware
AbbVie Pharmaceuticals LLC Delaware
AbbVie Products LLC Georgia

AbbVie Purchasing LLC Delaware
AbbVie Resources Inc.Delaware

AbbVie Resources International Inc.Delaware
AbbVie Respiratory LLC Delaware
AbbVie Sales Inc.Delaware
AbbVie Services Inc.Delaware
AbbVie Stemcentrx LLC Delaware
AbbVie Subsidiary LLC Delaware
AbbVie US Holdings LLC Delaware
AbbVie US LLC Delaware
AbbVie Ventures LLC Delaware
Aeropharm Technology, LLC Delaware
AGN International Inc.Delaware
AGN Kythera, LP Delaware
AGN Labs LLC Delaware
AGN LLC Delaware
AGN Sundry, LLC Delaware
Allergan Akarna LLC Delaware
Allergan Finance, LLC Nevada
ALLERGAN FINCO 2 INC.Delaware
ALLERGAN FINCO INC.Delaware
Allergan GI Corp Delaware

Allergan GP Holding LLC Delaware

Allergan Holdco US, Inc.Delaware
Allergan Holdings B1, Inc.Delaware
Allergan Holdings, Inc.Delaware
Allergan, Inc.Delaware
Allergan Laboratories, LLC Delaware
Allergan Lending 2 LLC Delaware
Allergan Lending LLC Delaware
Allergan Pharma Inc.Delaware
Allergan Property Holdings, LLC Delaware
Allergan Puerto Rico Holdings, Inc.Delaware
Allergan Sales Puerto Rico, Inc.California
Allergan Sales, LLC (d/b/a Allergan; d/b/a Bioscience Laboratories)Delaware Allergan Therapeutics LLC Delaware
Allergan USA, Inc. (d/b/a Pacificom / Pacific Communications)Delaware Allergan W.C. Holding Inc.Delaware
Anterios, Inc.Delaware
Aptalis Pharma US, Inc.Delaware
AqueSys, Inc.Delaware
BioDisplay Technologies, Inc.Illinois
Bonti, Inc.Delaware

Cearna Aesthetics, Inc.Delaware

Chase Pharmaceuticals Corporation Delaware
Del Mar Indemnity Company LLC Hawaii
Durata Holdings, Inc.Delaware
Durata Therapeutics, Inc.Delaware
Durata Therapeutics U.S. Limited Delaware
Eden Biodesign, LLC Delaware
Envy Medical, Inc.Delaware
Exemplar Pharma, LLC Delaware
Foresight Vision5, Inc.Delaware
Fremont Holding L.L.C.Delaware
Furiex Pharmaceuticals LLC Delaware
IEP Pharmaceutical Devices, LLC Delaware
Keller Medical, Inc.Delaware
Knoll Pharmaceutical Company New Jersey
KOS Pharmaceuticals, Inc.Delaware
Life Properties Inc.Delaware
LifeCell Corporation Delaware
MAP Pharmaceuticals, LLC Delaware
Mavupharma, Inc.Delaware
MPEX Pharmaceuticals, Inc.Delaware

Naurex Inc.Delaware
Oculeve, Inc.Delaware

Organics L.L.C.Delaware
Pacific Pharma, Inc.Delaware
Pharmacyclics LLC Delaware
Pharmax Holding Limited Delaware
Repros Therapeutics Inc.Delaware
Rowell Laboratories, Inc.Minnesota
RP Merger Sub, Inc.Delaware
Sapphire Merger Sub, Inc.Delaware
Silicone Engineering, Inc.California
Soliton Inc.Delaware
Suffolk Merger Sub, Inc.Delaware
TeneoOne, Inc.Delaware
Tobira Therapeutics, Inc.Delaware
Topokine Therapeutics, Inc.Delaware
Transderm, Inc.Delaware
Unimed Pharmaceuticals, LLC Delaware
Venice Subsidiary LLC Delaware
Vicuron Pharmaceuticals LLC Delaware
Vitae Pharmaceuticals, LLC Delaware
Warner Chilcott Leasing Equipment Inc.Delaware

Warner Chilcott Sales (US), LLC Delaware
Zeltiq A LLC Delaware
Zeltiq Aesthetics, Inc.Delaware
Zeltiq International, LLC Delaware

Foreign Subsidiaries Incorporation
AbbVie S.A.Argentina
Allergan Productos Farmaceuticos S.A.Argentina
Allergan Australia Pty Limited Australia
Elastagen Pty Ltd Australia
Kythera Biopharmaceuticals Australia Pty Ltd Australia
AbbVie Pty Ltd Australia
AbbVie GmbH Austria
AbbVie Bahamas Ltd.Bahamas
AbbVie SA Belgium
Allergan N.V.Belgium
Odyssea Pharma SPRL Belgium
AbbVie Ltd Bermuda
AbbVie Biotechnology Ltd Bermuda
AbbVie Finance Limited Bermuda
AbbVie Global Enterprises Ltd.Bermuda
AbbVie Holdings Unlimited Bermuda
Allergan Development Ventures I, LP Bermuda
Allergan Holdings B Ltd.Bermuda
Allergan Holdings B2, Ltd.Bermuda
Kythera Holdings Ltd Bermuda

Warner Chilcott Holdings Company II, Limited Bermuda

Warner Chilcott Holdings Company III, Limited Bermuda
Warner Chilcott Limited Bermuda
AbbVie d.o.o.Bosnia
AbbVie Farmacêutica Ltda.Brazil
Allergan Productos Farmaceuticos Ltda.Brazil
AbbVie EOOD Bulgaria
Allergan Bulgaria EOOD Bulgaria
AbbVie Corporation Canada
AbbVie Holdings Corporation Canada
Allergan Inc.Canada
Aptalis Pharma Canada ULC Canada (Alberta)
Allergan Holdings C, Ltd.Cayman Islands
Allergan Overseas Holding Cayman Islands
Pharmacyclics Cayman Ltd.Cayman Islands
Stemcentrx Cayman Ltd.Cayman Islands
AbbVie Productos Farmacéuticos Limitada Chile
Allergan Laboratorios Limitada Chile
AbbVie Pharmaceutical Trading (Shanghai) Co., Ltd.China Allergan (Chengdu) Medical Aesthetics Clinic Co., Ltd.China

Allergan Information Consulting (Shanghai) Co., Ltd.China Allergan Medical Device (Shanghai) Co., Ltd.China

AbbVie S.A.S.Colombia
Allergan de Colombia S.A.Colombia
Allergan Costa Rica S.R.L.Costa Rica
AbbVie d.o.o.Croatia
AbbVie Limited Cyprus
AbbVie s.r.o.Czech Republic
Allergan CZ, s.r.o.Czech Republic
AbbVie A/S Denmark
Allergan ApS Denmark
AbbVie, S.R.L.Dominican Republic
AbbVie L.L.C.Egypt
AbbVie OÜ Estonia
AbbVie Oy Finland
Allergan Finland Oy Finland
AbbVie SAS France
Allergan France SAS France
Allergan Holdings France SAS France
Allergan Industrie SAS France

Eurand France S.A.S.France
Forest Holdings France S.A.S.France
AbbVie Biotechnology GmbH Germany
AbbVie Deutschland GmbH & Co. KG Germany

AbbVie Komplementär GmbH Germany
AbbVie Pharmaceuticals GmbH Germany
AbbVie Real Estate Management GmbH Germany
Allergan GmbH Germany
AbbVie (Gibraltar) Holdings Limited Gibraltar
AbbVie (Gibraltar) Limited Gibraltar
AbbVie Pharmaceuticals Societe Anonyme Greece
Allergan Hellas Pharmaceuticals S.A.Greece
AbbVie, Socieded Anonima Guatemala
AbbVie Limited Hong Kong
Allergan Hong Kong Limited Hong Kong
AbbVie Gyogyszerkereskedelmi Korlatolt Felelossegu Tarsasag Hungary Allergan Hungary Kft.Hungary
Allergan Healthcare India Private Limited India
Allergan India Private Limited*India
AbbVie International Holdings Unlimited Company Ireland AbbVie Ireland Holdings Unlimited Company Ireland
AbbVie Ireland Unlimited Company Ireland

AbbVie Limited Ireland
AbbVie Manufacturing Management Unlimited Company Ireland

Allergan Botox Unlimited Company (In voluntary liquidation)Ireland Allergan Equities Unlimited Company Ireland
Allergan Furiex Ireland Limited (In voluntary liquidation)Ireland Allergan Holdings Unlimited Company Ireland
Allergan Ireland Holdings Unlimited Company Ireland
Allergan Ireland Limited Ireland
Allergan Limited Ireland
Allergan Pharma Limited Ireland
Allergan Pharmaceuticals Holdings (Ireland) Unlimited Company (In voluntary liquidation)Ireland
Allergan Pharmaceuticals International Limited Ireland
Allergan Pharmaceuticals Ireland Unlimited Company Ireland Allergan Services International, Unlimited Company Ireland Allergan WC Ireland Holdings Limited Ireland
Forest Laboratories Ireland Limited Ireland
Fournier Laboratories Ireland Limited Ireland
Pharmacyclics (Europe) Limited Ireland

Tosara Exports Limited (In voluntary liquidation)Ireland Warner Chilcott Intermediate (Ireland) ULC Ireland
Zeltiq Ireland International Holdings Unlimited Company Ireland Zeltiq Ireland Unlimited Company Ireland
AbbVie Biopharmaceuticals Ltd.Israel

Allergan Israel Ltd.Israel
Marbelle Threads Ltd.Israel
AbbVie S.r.l.Italy
Allergan S.p.A.Italy
Aptalis Pharma S.r.l.Italy
AbbVie GK Japan
Allergan International YK Japan
Allergan Japan KK Japan
Allergan K.K.Japan
Allergan NK Japan
AbbVie Ltd Korea, South
Allergan Korea Ltd.Korea, South
AbbVie SIA Latvia
AbbVie UAB Lithuania
Allergan Baltics, UAB Lithuania
AbbVie Biotherapeutics S.àr.l.Luxembourg

AbbVie Holdings S.à r.l.Luxembourg
AbbVie Global S.à r.l.Luxembourg
Allergan AHI S.à r.l.Luxembourg
Allergan Capital 2 S.à r.l.Luxembourg
Allergan Capital S.à r.l.Luxembourg
Allergan Europe S.à r.l.Luxembourg

Allergan Finance S.à r.l.Luxembourg
Allergan Funding SCS Luxembourg
Allergan Global S.à r.l.Luxembourg
Allergan Holdings S.à r.l.Luxembourg
Allergan International Holding S.à r.l.Luxembourg
Allergan Luxembourg International S.à r.l.Luxembourg
Allergan WC 1 S.à r.l.Luxembourg
Allergan WC 2 S.à r.l.Luxembourg
AbbVie Sdn. Bhd.Malaysia
Allergan Malaysia Sdn Bhd Malaysia
Allergan Malta Holding Limited Malta
Allergan Malta II Limited Malta

Allergan Malta Limited Malta
AbbVie Farmacéuticos, S.A. de C.V.Mexico
Allergan Servicios Profesionales, S. de R.L. de C.V.Mexico Allergan, S.A. de C.V.Mexico
AbbVie B.V.Netherlands
AbbVie Central Finance B.V.Netherlands
AbbVie Enterprises B.V.Netherlands
AbbVie Finance B.V.Netherlands
AbbVie Ireland NL B.V.Netherlands

AbbVie Japan Holdings B.V.Netherlands
AbbVie Logistics B.V.Netherlands
AbbVie Nederland Holdings B.V.Netherlands
AbbVie Pharmaceuticals B.V.Netherlands
AbbVie Research B.V.Netherlands
AbbVie Venezuela B.V.Netherlands
AbbVie Venezuela Holdings B.V.Netherlands
Allergan B.V.Netherlands
Aptalis Holding B.V.Netherlands
Aptalis Netherlands B.V.Netherlands
Forest Finance B.V.Netherlands
Warner Chilcott Nederland B.V.Netherlands

AbbVie Limited New Zealand
Allergan New Zealand Limited New Zealand
AbbVie AS Norway
Allergan AS Norway
AbbVie, S. de R.L.Panama
Allergan Healthcare Philippines, Inc.Philippines
AbbVie Polska Sp. z o.o.Poland
AbbVie Sp. z o.o.Poland
Allergan Sp. z o.o.Poland
AbbVie, L.da Portugal

AbbVie Promoção, L.da Portugal
AbbVie Corp Puerto Rico
Knoll LLC Puerto Rico
AbbVie S.R.L.Romania
AbbVie Trading S.R.L.Romania
Allergan S.R.L.Romania
AbbVie Limited Liability Company Russia
Allergan C.I.S. S.a.r.l.Russia
Allergan Saudi Arabia LLC*Saudi Arabia
Allergan d.o.o. Beograd Serbia
AbbVie Operations Singapore Pte. Ltd.Singapore
AbbVie Pte. Ltd.Singapore

Allergan Singapore Pte. Ltd.Singapore
AbbVie Holdings s.r.o.Slovakia
AbbVie s.r.o.Slovakia
Allergan SK s.r.o.Slovakia
AbbVie Biofarmacevtska druzba d.o.o.Slovenia
AbbVie (Pty) Ltd.South Africa
Allergan Pharmaceuticals (Proprietary) Limited South Africa AbbVie Spain, S.L.Spain
Allergan S.A.Spain

AbbVie AB Sweden
Allergan Norden AB Sweden
AbbVie AG Switzerland
AbbVie Biopharmaceuticals GmbH Switzerland
Allergan AG Switzerland
Pharmacyclics Switzerland GmbH Switzerland
VarioRaw Percutive S.à r.l.Switzerland
Warner Chilcott Pharmaceuticals S à rl Switzerland
Allergan Pharmaceuticals Taiwan Co. Ltd.Taiwan
AbbVie Ltd.Thailand
Allergan (Thailand) Limited Thailand
AbbVie Sarl Tunisia
AbbVie Tıbbi İlaçlar Sanayi ve Ticaret Limited Şirketi Turkey

Allergan Ilaclari Ticaret Anonim Sirketi Turkey
Allergan Ukraine LLC Ukraine
Allergan Middle East Limited United Arab Emirates
AbbVie Australasia Holdings Limited United Kingdom
AbbVie Biotherapeutics Limited United Kingdom
AbbVie Investments Limited United Kingdom
AbbVie Ltd United Kingdom
AbbVie Trustee Company Limited United Kingdom
AbbVie UK Holdco Limited United Kingdom

Akarna Therapeutics, Limited United Kingdom
Allergan Holdco UK Limited United Kingdom
Allergan Holdings Limited United Kingdom
Allergan Limited United Kingdom
Lifecell EMEA Limited (In voluntary liquidation)United Kingdom Renable Pharma Ltd.United Kingdom
Zeltiq Limited (In voluntary liquidation)United Kingdom AbbVie S.A.Uruguay
AbbVie Pharmaceuticals SCA.Venezuela
* Ownership of such subsidiary is less than 100% by AbbVie or an AbbVie subsidiary

J-2
EXHIBIT J-2
Allergan Entities

EX-21.1 10 agn-ex211_448.htm EX-21.1
Exhibit 21.1
Name JurisdicƟon of IncorporaƟon
AGN InternaƟonal Inc.US ‐ Delaware
AGN Kythera, L.P.US‐ Delaware
AGN Labs LLC US ‐ Delaware
AGN LLC US ‐ Delaware
AGN Sundry LLC US ‐ Delaware
Akarna TherapeuƟcs, Limited UK
Allergan  WC 1 S.a r.l.Luxembourg
Allergan (Chengdu) Medical AestheƟcs Clinic Co., Ltd. China Allergan (Thailand) Limited Thailand
Allergan AG Switzerland
Allergan AHI  S.à r.l. Management (DIFC Branch) UAB
Allergan AHI S.á r.l.Luxembourg
Allergan AHI S.á r.l.,  Luxembourg, Zweigniederlassung Zug Branch Switzerland Allergan Akarna LLC US ‐ Delaware
Allergan ApS Denmark
Allergan AS Norway
Allergan Australia Pty Limited Australia
Allergan B.V.Netherlands, The
Allergan BalƟcs, UAB Lithuania
Allergan BalƟcs, UAB EesƟ filiaal Estonia Branch
Allergan BalƟcs, UAB Latvijas filias Latvia
Allergan Biologics Ltd.UK
Allergan Botox Unlimited Company  Ireland
Allergan Bulgaria EOOD Bulgaria
Allergan C.I.S. SARL Russian FederaƟon
Allergan Capital  S.à r.l.  Luxembourg
Allergan Capital 2 S.à r.l.Luxembourg
Allergan Capital 2 Sarl, Luxembourg, Zweigniederlassung, Zug Switzerland Allergan Capital S.à r.l., Luxembourg, Zweigniederlassung Zug Branch Switzerland Allergan Cayman Islands Irish Branch Ireland
Allergan Costa Rica S.R.L Costa Rica
Allergan CZ, s.r.o.Czech Republic
Allergan d.o.o. Beograd Serbia
Allergan de Colombia S.A.Colombia
Allergan de Venezuela, C.A.Venzuela
Allergan Development Ventures  I Ireland Unlimited Company Ireland Allergan Development Ventures  I LP Bermuda
Allergan Development Ventures  I UK  UK
Allergan EquiƟes Unlimited Company Ireland
Allergan Europe S.à r.l.Luxembourg
Allergan Finance  S.à r.l.  Luxembourg
Allergan Finance, LLC US ‐ Nevada
Allergan Finco 2 Inc.US ‐ Delaware
Allergan Finco Inc.US ‐ Delaware
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Exhibit 21.1
Allergan Finland Oy Finland
Allergan France SAS France
Allergan Funding SCS Luxembourg
Allergan Furiex Ireland Limited Ireland
Allergan GI Corp.US ‐ Delaware
Allergan Global S.à r.l.Luxembourg
Allergan GmbH Germany
Allergan GP Holding LLC US‐ Delaware
Allergan Healthcare India Private Limited India
Allergan Healthcare Philippines, Inc. Philippines
Allergan Hellas PharmaceuƟcals S.A. Greece
Allergan Holdco UK Limited UK
Allergan Holdco US, Inc.US ‐ Delaware
Allergan Holdings B Ltd.Bermuda
Allergan Holdings B1, Inc.US ‐ Delaware
Allergan Holdings B2 Limited Bermuda
Allergan Holdings C Ltd Cayman Island
Allergan Holdings France SAS France
Allergan Holdings Limited UK
Allergan Holdings S. à r.l.Luxembourg
Allergan Holdings Unlimited Company Ireland
Allergan Holdings, Inc.US ‐ Delaware
Allergan Hong Kong Limited Hong Kong
Allergan Hungary KŌ.Hungary
Allergan Ilaclari Ticaret A.S.Turkey
Allergan Inc.  Canada
Allergan India Private Limited India
Allergan Industrie SAS France
Allergan InformaƟon ConsulƟng (Shanghai) Co., Ltd. China Allergan InternaƟonal Holding  S.à r.l. Luxembourg
Allergan InternaƟonal YK Japan
Allergan Ireland Finance Limited  Ireland
Allergan Ireland Holdings Unlimited Company Ireland
Allergan Ireland Limited  Ireland
Allergan Israel Limited Israel
Allergan Japan KK Japan
Allergan KK Japan
Allergan Korea Ltd Korea
Allergan Laboratories, LLC US ‐ Delaware
Allergan Laboratorios Limitada Chile
Allergan Lending 2 LLC US ‐ Delaware
Allergan Lending LLC US ‐ Delaware
Allergan Limited UK
Allergan Luxembourg InternaƟonal S.à r.l.  Luxembourg
Allergan Malaysia Sdn. Bhd.Malaysia
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Exhibit 21.1
Allergan Malta Holding Limited Malta
Allergan Malta II Limited Malta
Allergan Malta Limited Malta
Allergan Medical Device  (Shanghai) Co., Ltd. China
Allergan Middle East Limited  United Arab Emirates
Allergan N.V.Belgium
Allergan New Zealand Ltd.New Zealand
Allergan NK Japan
Allergan Norden AB Sweden
Allergan Norden AB Finnish branch Finland
Allergan Overseas Holding Cayman Island
Allergan Pharma Inc.US ‐ Delaware
Allergan Pharma Limited Ireland
Allergan PharmaceuƟcals  (Proprietary) Ltd. South Africa Allergan PharmaceuƟcals Holdings (Ireland) Unlimited Company Ireland Allergan PharmaceuƟcals InternaƟonal Limited Ireland
Allergan PharmaceuƟcals InternaƟonal Limited Jordan Office Jordan Allergan PharmaceuƟcals InternaƟonal Limited Lebanon Office Lebanon Allergan PharmaceuƟcals Ireland Ireland
Allergan PharmaceuƟcals Taiwan  Co. Ltd. Taiwan
Allergan Productos FarmaceuƟcos S.A. ArgenƟna
Allergan Produtos FarmaceuƟcos Ltda. Brazil
Allergan Property Holdings, LLC US ‐ Delaware
Allergan Puerto Rico Holdings, Inc. US ‐ Delaware
Allergan S.A.Spain
Allergan S.p.A.Italy
Allergan Sales Puerto Rico, Inc. US ‐ California
Allergan Sales, LLC (d/b/a Allergan; d/b/a Bioscience Laboratories) US ‐ Delaware Allergan Saudi Arabia LLC Saudi Arablia
Allergan ScienƟfic Office Egypt
Allergan Services InternaƟonal Unlimited Company Ireland Allergan Servicios Profesionales, S. de R.L. de C.V. Mexico Allergan Singapore Pte. Ltd.Singapore
Allergan Singapore Pte. Ltd. Indonesia Rep Office Indonesia Allergan Singapore Pte. Ltd. Vietnam Rep Office Vietnam Allergan SK s.r.o.Slovak Republic
Allergan Sp. z.o.o.Poland
Allergan S.R.L.Romania
Allergan TherapeuƟcs LLC US‐ Delaware
Allergan UK LLP UK
Allergan Ukraine, LLC Ukraine
Allergan USA, Inc. (d/b/a Pacificom / Pacific CommunicaƟons) US ‐ Delaware Allergan W.C. Holding Inc.US ‐ Delaware
Allergan WC 2 S.a r.l.Luxembourg
Allergan WC Ireland Holdings Ltd. Ireland
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Exhibit 21.1
Allergan, Inc.US ‐ Delaware
Allergan, S.A. de C.V.Mexico
Anterios, Inc.US ‐ Delaware
Aptalis Holding B.V.Netherlands, The
Aptalis Netherlands B.V.Netherlands, The
Aptalis Pharma Canada ULC Canada
Aptalis Pharma S.r.l.Italy
Aptalis Pharma UK Limited UK
Aptalis Pharma US, Inc.US ‐ Delaware
AqueSys, Inc.US ‐ Delaware
BonƟ, Inc.US ‐ Delaware
Cearna AestheƟcs, Inc US ‐ Delaware
Chase PharmaceuƟcals CorporaƟon US ‐ Delaware
Collagen Luxembourg SA Luxembourg
Del Mar Indemnity Company, LLC US ‐ Hawaii
Durata Holdings, Inc.US ‐ Delaware
Durata TherapeucƟcs U.S. Limited US ‐ Delaware
Durata TherapeuƟcs, Inc.US ‐ Delaware
Eden Biodesign, LLC US ‐ Delaware
Elastagen Pty Limited Australia
Envy Medical, Inc.US ‐ Delaware
Eurand France S.A.S.France
Exemplar Pharma LLC US ‐ Delaware
Forest Finance B.V.Netherlands, The
Forest Holdings France S. A.S.France
Forest Laboratories Holdings Limited Ireland
Forest Laboratories Ireland Ltd Ireland
ForSight VISION5, Inc.US ‐ Delaware
Furiex PharmaceuƟcals, LLC US ‐ Delaware
Keller Medical, Inc.US ‐ Delaware
Kythera BiopharmaceuƟcals Australia Pty Ltd. Australia
Kythera Holdings Ltd.Bermuda
LifeCell CorporaƟon US ‐ Delaware
LifeCell EMEA Limited UK
LifeCell EMEA Limited Austria branch Austria
LifeCell EMEA Limited Italy branch Italy
LifeCell EMEA Limited Sucursal en EspaňaSpain
LifeCell EMEA Limited, Zweigniederlassung Zürich Switzerland LifeCell Medical Resources Limited in voluntary liquidaƟon Ireland MAP PharmaceuƟcals LLC US ‐ Delaware
McGhan Ireland Holdings Ltd.Ireland
McGahn Limited Ireland
MPEX PharmaceuƟcals, Inc.US ‐ Delaware
Naurex Inc.US ‐ Delaware
Northwood Medical InnovaƟon, Ltd. UK
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Exhibit 21.1
Oculeve, Inc.US ‐ Delaware
Odyssea Pharma SPRL Belgium
Pacific Pharma, Inc.US ‐ Delaware
Pharm‐Allergan GmbH Austria branch Austria
Pharmax Holding Limited US ‐ Delaware
Renable Pharma Limited UK
Repros TherapeuƟcs Inc,.US‐ Delaware
RP Merger Sub, Inc.US ‐ Delaware
Seabreeze Silicone Unlimited Company Ireland
Silicone Engineering Inc.US ‐ California
Tobira  TherapeuƟcs, Inc.US ‐ Delaware
Topokine  TherapeuƟcs, Inc.US ‐ Delaware
Tosara  Exports  Limited Ireland
Transderm, Inc.US ‐ Utah
Varioraw  PercuƟve Sàrl Switzerland
Vicuron PharmaceuƟcals LLC US ‐ Delaware
Viokace LLC US ‐ Delaware
Vitae PharmaceuƟcals LLC US ‐ Delaware
Warner ChilcoƩ Holdings Company II, Limited Bermuda
Warner  ChilcoƩ Holdings Company III, Limited Bermuda
Warner  ChilcoƩ Intermediate (Ireland) Limited Ireland
Warner  ChilcoƩ Leasing Equipment Inc. US ‐ Delaware
Warner  ChilcoƩ Limited Bermuda
Warner  ChilcoƩ Nederland B.V. Netherlands, The
Warner ChilcoƩ PharmaceuƟcals S. àr.l. Switzerland
Warner ChilcoƩ Sales (US), LLC US ‐ Delaware
ZELTIQ A, LLC US ‐ Delaware
ZELTIQ AestheƟcs, Inc.US ‐ Delaware
ZELTIQ InternaƟonal, LLC US ‐ Delaware
ZELTIQ InternaƟonal, LLC ‐ Singapore Branch Singapore
ZELTIQ Ireland InternaƟonal Holdings UC Ireland
ZELTIQ Ireland Unlimited Company Ireland
ZELTIQ Limited United Kingdom
ZelƟq Limited Spanish branch Spain
Zenpep LLC US ‐ Delaware
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J-3
EXHIBIT J-3
Divested Entities

LA_LAN01:289784.8A
OC\2075745.21
Schedule 4.6(c) - Transferred Group

Ownership interest of Seller Parent and its Subsidiaries is 100% unless otherwise indicated.

Company Name Jurisdiction of
Incorporation

1. Warner Chilcott Company, LLC Puerto Rico

2. Warner Chilcott (Ireland) Limited Ireland

3. Warner Chilcott Finance LLC. Delaware

4. Warner Chilcott Australia Pty. Ltd. Australia

5. Warner Chilcott Pharmaceuticals B.V.B.A. Belgium

6. Warner Chilcott France SAS France

7. Warner Chilcott Italy S.r.l. Italy

8. Actavis Pharma Iberia S.L. (f/k/a Warner Chilcott Iberia S.L.) Spain

9. Robin Hood Holdings Ltd. Malta

10. Paomar plc Cyprus

11. Actavis Pharma Pty Ltd. Australia

12. Makoff R&D Laboratories, Inc. California

13. R&D Pharmaceutical, Inc. California

14. R&D Ferriecit Capital Resources, Inc. California

15. R&D Research & Development Corp. California

16. R&D New Media Services, Inc. California

17. Royce Laboratories, Inc. Florida

18. Royce Research Group, Inc. Florida

19. Royce Research & Development Limited Partnership I Florida

20. The Rugby Group, Inc. New York
CONFIDENTIAL - SUBJECT TO PROTECTIVE ORDER ALLERGAN_TX_00037736Page 2445 of 2516

LA_LAN01:289784.8A
OC\2075745.21
Company Name Jurisdiction of
Incorporation

21. Watson Laboratories, Inc. Ohio New York

22. Rugby Laboratories, Inc. New York

23. Changzhou Siyao Pharmaceuticals Co., Ltd. (25%) China

24. Watson Pharmaceuticals (Asia) Ltd. BVI

25. WP Holdings, Ltd. BVI

26. Watson Pharmaceuticals, China Ltd BVI

27. Med All Enterprise Consulting (Shanghai) Co. Ltd. China

28. Nicobrand Limited Northern Ireland

29. Watson Pharmaceuticals International Ltd. BVI

30. Watson Diagnostics, Inc. Delaware

31. Actavis Laboratories NY, Inc. New York

32. Circa Pharmaceuticals West, Inc. California

33. Circa Sub New York

34. Andrx LLC Delaware

35. Andrx South Carolina I, Inc. South Carolina

36. Andrx Pharmaceuticals (Mass), Inc. Florida

37. Andrx Pharmaceuticals Equipment #1, LLC Florida

38. Andrx Pharmaceuticals (NC) Inc. Florida

39. Andrx Pharmaceuticals, (NC) Equipment LLC Delaware

40. SR Six, Inc. Florida

41. RxAPS, Inc. Florida

42. Andrx Pharmaceuticals Sales and Marketing, Inc. Florida

43. Actavis Laboratories FL, Inc. Florida
CONFIDENTIAL - SUBJECT TO PROTECTIVE ORDER ALLERGAN_TX_00037737Page 2446 of 2516

LA_LAN01:289784.8A
OC\2075745.21
Company Name Jurisdiction of
Incorporation

44. Watson Management Corporation Florida

45. Watson Therapeutics, Inc. Florida

46. Andrx Pharmaceuticals, LLC Delaware

47. Andrx Labs LLC Delaware

48. Andrx Laboratories (NJ) Inc. Delaware

49. Watson Cobalt Holdings, LLC Delaware

50. Watson Manufacturing Services, Inc. Delaware

51. Natrapac, Inc. Utah

52. Coventry Acquisition, LLC Delaware

53. Cobalt Laboratories, LLC Delaware

54. Watson Pharma Private Ltd. India

55. Watson Laboratories, LLC Delaware

56. Actavis Puerto Rico Holdings Inc. Delaware

57. Actavis US Holding LLC Delaware

58. Actavis LLC Delaware

59. Actavis South Atlantic LLC Delaware

60. Actavis Elizabeth LLC Delaware

61. Actavis Kadian LLC Delaware

62. Actavis Mid Atlantic LLC Delaware

63. Actavis Totowa LLC Delaware

64. Actavis Pharmaceuticals NJ, Inc. Delaware

65. Watson Laboratories, Inc. Connecticut

66. Watson Laboratories, Inc. – Arizona Delaware
CONFIDENTIAL - SUBJECT TO PROTECTIVE ORDER ALLERGAN_TX_00037738Page 2447 of 2516

LA_LAN01:289784.8A
OC\2075745.21
Company Name Jurisdiction of
Incorporation

67. Schein Bayer Pharmaceutical Services, Inc. Delaware

68. Schein Pharmaceutical International, Inc. Delaware

69. Schein Pharmaceutical Ltd Bermuda

70. Marsam Pharma, LLC Delaware

71. MSI, Inc. Delaware

72. Actavis Holding 2 Sàrl Luxembourg

73. Actavis Services (Asia) Ltd. Malta

74. Arrow Laboratories, Ltd. Malta

75. Arrow Supplies, Ltd.* Malta

76. Marrow Pharmaceuticals Research & Development Co Ltd. (50%) China

77. Actavis S.à.r.l. Luxembourg

78. “Specifar” Greece

79. Alet Greece

80. Ascent Pharmahealth Pty Ltd Australia

81. Actavis Australia Pty Ltd Australia

82. Ascent Australia Pty Ltd Australia

83. Actavis Pty Ltd Australia

84. Ascent Pharma Pty Ltd. Australia

85. Ascent Pharmahealth Asia Pte Ltd Singapore

86. Drug Houses of Australia Pte Ltd. Singapore

87. Ascent Pharmahealth Hong Kong Ltd. Hong Kong

88. Actavis Sdn. Bhd. Malaysia

89. Arrow Group ApS Denmark
CONFIDENTIAL - SUBJECT TO PROTECTIVE ORDER ALLERGAN_TX_00037739Page 2448 of 2516

LA_LAN01:289784.8A
OC\2075745.21
Company Name Jurisdiction of
Incorporation

90. Arrow ApS Denmark

91. Makewhey Products Pty. Ltd.** South Africa

92. Actavis Holdings South Africa (Pty) Ltd. South Africa

93. Actavis Pharma (Pty) Ltd. South Africa

94. Actavis (Pty) Ltd. South Africa

95. Scriptpharm Marketing (Pty) Ltd South Africa

96. Referral-Net (Pty) Ltd.* South Africa

97. Spear Pharmaceuticals (Pty) Ltd South Africa

98. Pharmascript Pharmaceuticals Ltd. (64.8%) South Africa

99. Arrow Pharma Tender (Pty) Ltd.** (65%) South Africa 100. Zelphy 1308 (Pty) Ltd. South Africa
101. Arrowblue Produtos Farmaceuticos SA Portugal
102. Bowmed Ltd UK
103. Selamine Ltd. Ireland
104. Seeker Investments Ltd. BVI
105. SC Pharma (Pty) Ltd. (25%) Australia
106. Willow Pharmaceuticals Pty Ltd. Australia
107. Medis Pharma Pty Ltd Australia
108. Eremad Pty Ltd. Australia
109. Arrow Läkemedel AB Sweden
110. Arrow Generics Ltd. UK
111. Arrow No 7 Ltd UK
112. Breath Ltd UK
CONFIDENTIAL - SUBJECT TO PROTECTIVE ORDER ALLERGAN_TX_00037740Page 2449 of 2516

LA_LAN01:289784.8A
OC\2075745.21
Company Name Jurisdiction of
Incorporation
113. Soosysoo Ltd. (50%)** BVI
114. Actavis New Zealand Limited New Zealand
115. Watson Laboratories, S. de R.L. de C.V Mexico
116. Actavis Pharma Company Canada
117. Abri Pharmceuticals Company Canada
118. Actavis Pharma Holding 4 ehf. (APH4) Iceland
119. Actavis Pharma Holding 5 ehf. (APH5) Iceland
120. Actavis Group ehf. Iceland
121. Actavis Group PTC ehf. Iceland
122. Actavis Dutch Holding BV Netherlands
123. LLC Actavis Russia
124. Actavis Ilaclari AS # Turkey
125. Actavis ehf. Iceland
126. Medis ehf. Iceland
127. Medis Pharma France SAS France
128. Medis-Danmark A/S.* Denmark
129. Actavis Ireland Ltd. Ireland
130. Actavis Italy S.p.A. Italy
131. Actavis Isle of Man Ltd. Isle of Man
132. Actavis Nordic A/S Denmark
133. Actavis Oy Finland
134. UAB Actavis Baltics Lithuania
135. Actavis Holding AB Sweden
CONFIDENTIAL - SUBJECT TO PROTECTIVE ORDER ALLERGAN_TX_00037741Page 2450 of 2516

LA_LAN01:289784.8A
OC\2075745.21
Company Name Jurisdiction of
Incorporation
136. Actavis AB Sweden
137. Actavis Holding Germany GmbH Germany
138. Medis Pharma GmbH Germany
139. Actavis A/S Denmark
140. Actavis Norway AS Norway
141. Actavis, S. de. R.L. de C.V. Mexico
142. Actavis Pharma S. de R.L. de C.V. Mexico
143. Actavis Hungary Kft. Hungary
144. Arrow Pharm (Malta) Ltd. Malta
145. Medis Pharma BV Netherlands
146. PharmaPack International B.V. Netherlands
147. Actavis Polska Sp. z.o.o. Poland
148. Actavis International Ltd. Malta
149. Actavis Malta Ltd. Malta
150. Actavis Export International Ltd. Malta
151. Actavis Ltd. (Note: 1 share owned by Dr. Vella) Malta 152. Actavis GmbH Austria
153. Actavis Holdings UK Ltd. UK
154. Actavis Holdings UK II Ltd. UK
155. Actavis UK Ltd. UK
156. Warner Chilcott Acquisition Limited UK
157. Chilcott UK Limited Northern Ireland
158. Warner Chilcott Research Laboratories Ltd. Northern Ireland CONFIDENTIAL - SUBJECT TO PROTECTIVE ORDER ALLERGAN_TX_00037742Page 2451 of 2516

LA_LAN01:289784.8A
OC\2075745.21
Company Name Jurisdiction of
Incorporation
159. Warner Chilcott UK Limited Northern Ireland
160. Warner Chilcott Pharmaceuticals UK Limited UK
161. Millbrook (NI) Limited Northern Ireland
162. Auden Mckenzie Holdings Ltd. UK
163. Auden Mckenzie (Pharma Division) Ltd. UK
164. NRIM Ltd. UK
165. Lime Pharma Ltd. UK
166. D3 Pharma Ltd. (38%) UK
167. Actavis d.o.o. Belgrade Serbia
168. Lotus Laboratories Private Ltd. India
169. Actavis Ukraine LLC Ukraine
170. Zdravlje AD Serbia
171. Actavis Switzerland AG Switzerland
172. Oncopharma AG Switzerland
173. Sindan Pharma SRL Romania
174. Actavis SRL Romania
175. Actavis CZ a.s. Czech Republic
176. Actavis S.r.o. Slovak Republic
177. Biovena Pharma Sp. z.o.o. Poland
178. Actavis (Cyprus) Ltd. Cyprus
179. Actavis Operations EOOD Bulgaria
180. Balkanpharma Troyan AD (98.32%) Bulgaria
181. Balkanpharma Dupnitsa AD (98.05%) Bulgaria
CONFIDENTIAL - SUBJECT TO PROTECTIVE ORDER ALLERGAN_TX_00037743Page 2452 of 2516

LA_LAN01:289784.8A
OC\2075745.21
Company Name Jurisdiction of
Incorporation
182. Balkanpharma Security EOOD Bulgaria
183. Balkanpharma Healthcare International (Cyprus) Ltd.* Cyprus 184. Actavis EAD Bulgaria
185. Actavis Istanbul Ilac Sanayive Ticaret Ltd. Sirketi Turkey 186. Actavis (MEEA) FZE UAE
187. Actavis Farmacêutica Limitada Brazil
188. Actavis Holding Asia BV Netherlands
189. Actavis Hong Kong Limited Hong Kong
190. China Medicinal & Chemical Industrial Development Group Ltd. (10% interest)
Hong Kong
191. Actavis Pharma Development Centre Private Ltd. India 192. Actavis Pharma Private Ltd. India
193. PT Actavis Indonesia Indonesia
194. Actavis KK Japan
195. Actavis (Asia Pacific) Pte. Ltd. Singapore
196. Silom Medical Co., Ltd Thailand
197. Silom Medical International Co., Ltd. Thailand
198. Forest Laboratories UK Ltd. UK
199. Pharmax Ltd. UK
200. Forest Pharma BV Netherlands
201. Forest Laboratories Osterreich GmbH Austria
202. Forest Laboratories France S.A.S. France
203. Forest Laboratories Deutschland GmbH Germany
CONFIDENTIAL - SUBJECT TO PROTECTIVE ORDER ALLERGAN_TX_00037744Page 2453 of 2516

LA_LAN01:289784.8A
OC\2075745.21
Company Name Jurisdiction of
Incorporation
204. Forest Laboratories Italy S.r.L. Italy
205. Forest Laboratories Spain, SL Spain
206. Axcan France (Invest) SAS France
207. Aptalis Pharma SAS France
208. Forest Tosara Ltd. Ireland
209. Actavis Laboratories UT, Inc. Delaware
210. Watson Laboratories, Inc. Nevada
211. Actavis Pharma, Inc. Delaware
212. Arrow International Ltd. Malta
213. Allergan UK Group Ltd. UK
214. Actavis Finance ehf. Iceland
215. Actavis Holdco US, Inc. Delaware

* In Liquidation ** De-Registered
CONFIDENTIAL - SUBJECT TO PROTECTIVE ORDER ALLERGAN_TX_00037745Page 2454 of 2516

K-1

EXHIBIT K
Subdivision and Special District Settlement Participation Form

Governmental Entity: State:

Authorized Official:

Address 1:

Address 2:

City, State, Zip:

Phone:

Email:

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 Agreement dated November 22, 2022 (“Allergan Settlement”), and acting through the undersigned authorized official, hereby elects to participate in the Allergan Settlement, release all Released Claims against all Released Entities, and agrees as follows.

1. The Governmental Entity is aware of and has reviewed the Allergan 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 Allergan Settlement as provided therein.

2. Following the execution of this Settlement Participation Form, the Governmental Entity shall comply with Section III.B of the Allergan Settlement regarding Cessation of Litigation Activities.

3. The Governmental Entity shall, within fourteen (14) days of the Reference Date and prior to the filing of the Consent Judgment, file a request to dismiss with prejudice any Released Claims that it has filed. With respect to any Released Claims pending in In re National Prescription Opiate Litigation, MDL No. 2804, the Governmental Entity authorizes the MDL 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 [link to national settlement website page to be provided].

4. The Governmental Entity agrees to the terms of the Allergan Settlement pertaining to Subdivisions and Special Districts as defined therein.

5. By agreeing to the terms of the Allergan 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.

6. The Governmental Entity agrees to use any monies it receives through the Allergan Settlement solely for the purposes provided therein.

K-2

7. 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 Allergan Settlement.

8. The Governmental Entity has the right to enforce the Allergan Settlement as provided therein.

9. The Governmental Entity, as a Participating Subdivision or Participating Special District, hereby becomes a Releasor for all purposes in the Allergan Settlement, including, but not limited to, all provisions of Section V (Release), and along with all departments, agencies, divisions, boards, commissions, Subdivisions, districts, instrumentalities of any kind and attorneys, and any person in their 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 in bringing, 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 Allergan Settlement are intended 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 Allergan Settlement shall be a complete bar to any Released Claim.

10. The Governmental Entity hereby takes on all rights and obligations of a Participating Subdivision or Participating Special District as set forth in the Allergan Settlement.

11. In connection with the releases provided for in the Allergan 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 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

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materially affect the Governmental Entities’ decision to participate in the Allergan Settlement.

12. Nothing herein is intended to modify in any way the terms of the Allergan Settlement, to which the Governmental Entity hereby agrees. To the extent this Settlement Participation Form is interpreted differently from the Allergan Settlement in any respect, the Allergan Settlement controls.

I have all necessary power and authorization to execute this Settlement Participation Form on behalf of the Governmental Entity.

Signature: _____________________________

Name: _____________________________

Title: _____________________________

Date: _____________________________

L-1

EXHIBIT L
Settlement Fund Administrator
(Plaintiffs to Add)

M-1
EXHIBIT M-1
Payment Schedule
EXHIBIT M-1: PAYMENT SCHEDULE

Payment Year Additional
Restitution
Amount & All
Attorneys’ Fees
& Costs Funds
Base Payments
(45%)

Incentives

A, B, & C
(maximum)
(48%)
Incentive D
Part 1
(maximum)
(3.5%)
Incentive D
Part 2
(maximum)
(3.5%)
Total
Abatement
Overall
Total

Year 1
2023: Effective
Date + 30 days
$55,774,789.29 $257,026,678.71 --- ---
---

$257,026,678.71 $312,801,468.00
Year 2
July 15, 2024
$55,774,789.29 $113,091,738.63 $143,934,940.08 --- --- $257,026,678.71 $312,801,468.00 Year 3
July 15, 2025
$55,774,789.27 $113,091,738.63 $143,934,940.08 --- --- $257,026,678.71 $312,801,467.98 Year 4
July 15, 2026
$55,774,789.27 $81,605,970.49 $143,934,940.08 $31,485,768.14 --- $257,026,678.71 $312,801,467.98 Year 5
July 15, 2027
--- $81,605,970.50 $143,934,940.08 $31,485,768.14 --- $257,026,678.72 $257,026,678.72 Year 6
July 15, 2028
--- $81,605,970.50 $143,934,940.08 --- $31,485,768.14 $257,026,678.72 $257,026,678.72 Year 7
July 15, 2029
--- $81,605,970.49 $143,934,940.08 --- $31,485,768.15 $257,026,678.72 $257,026,678.72

Total

$223,099,157.12

$809,634,037.95

$863,609,640.48

$62,971,536.28

$62,971,536.29

$1,799,186,751.00

$2,022,285,908.12

NOTES:

1. All figures for the base and incentive payments are maximum figures that reflect the following:
- The credits amount of $350,686,276 for prior settlements, including San Francisco, have already been applied. - An assumption that all Eligible States are Settling States. - An assumption that all incentives are earned.

M-2

2. The Additional Restitution Amount and the state and subdivision fees and costs amounts are broken out into separate columns i n Exhibit M-2.

3. Any offsets under Section VII.C for Non-Settling States would be deducted from the base payments and the maximum incentive payments (A, B & C and D) by subtracting from all payments the amount of the payment times the State Allocation Percentage assigned to each Non- Settling State in Exhibit F-2.

EXHIBIT M-2: PAYMENT SCHEDULE FOR FEE FUNDS, COST FUNDS AND ADDITIONAL RESTITUTION (Breakdown of Second Column in Exhibit M-1)

Payment Year Attorney Fee and
Cost Fund
(Subdivisions)
State Cost Fund State Outside
Counsel Fee Fund
Additional
Restitution
Amount
Total
(Shown in Ex. M-1,
2nd Column)
Year 1
2023: Effective Date
+ 30 days

$46,778,855.53

$3,598,373.50

$2,698,780.13

$2,698,780.13

$55,774,789.29
Year 2
July 15, 2024
$46,778,855.53 --- $4,497,966.88 $4,497,966.88 $55,774,789.29 Year 3
July 15, 2025
$46,778,855.52 --- $4,497,966.88 $4,497,966.87 $55,774,789.27 Year 4
July 15, 2026
$46,778,855.52 --- $4,497,966.87 $4,497,966.88 $55,774,789.27 Total $187,115,422.10 $3,598,373.50 $16,192,680.76 $16,192,680.76 $223,099,157.12

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N-1

EXHIBIT N
Additional Restitution Amount Allocation
Alabama 2.3235064275%
American Samoa 0.0249290899%
Arizona 3.4587568289%
Arkansas 1.3572625067%
California 14.4450765453%
Colorado 2.4192554291%
Connecticut 1.8837281232%
District of Columbia 0.2620389205%
Guam 0.0699391581%
Illinois 4.8429924684%
Indiana 3.2276944929%
Iowa 1.0802095029%
Kansas 1.1415833881%
Maine 0.7706700866%
Maryland 3.0729495134%
Massachusetts 3.3539006587%
Michigan 4.9531894399%
Minnesota 1.8887504448%
Missouri 2.9201303591%
Montana 0.4550557494%
N. Mariana Islands 0.0243230499%
Nebraska 0.6073579252%
New Hampshire 0.8422452854%
New Jersey 4.0113502576%
North Carolina 4.7322180042%
North Dakota 0.2475488543%
Oregon 2.0006852452%
Pennsylvania 6.6802688492%
South Carolina 2.2411620291%
Tennessee 3.9138188795%
Texas 9.1626320793%
Utah 1.6695130485%
Vermont 0.3705243381%
Virgin Islands 0.0459606175%
Virginia 3.3197424763%
Washington 3.3762173891%
Wisconsin 2.5599397925%
Wyoming 0.2428727457%

O-1

EXHIBIT O
Adoption of a State-Subdivision Agreement
A State-Subdivision Agreement shall be applied if it meets the requirements of Section VIII and is approved by the State and by the State’s Subdivisions as follows:

1. Requirements for Approval. A State-Subdivision Agreement shall be deemed as agreed to when it has been approved by the State and either (a) Subdivisions whose aggregate “Population Percentages,” determined as set forth below, total more than sixty percent (60%), or (b) Subdivisions whose aggregate Population Percentages total more than fifty percent (50%) provided that these Participating Subdivisions also represent fifteen percent (15%) or more of the State’s counties or parishes (or, in the case of Settling States whose counties and parishes do not function as local governments, 15% of or more of the Settling State’s non-county Subdivisions), by number.

2. Approval Authority. Approval by the State shall be by the Attorney General. Approval by a Subdivision shall be by the appropriate official or legislative body pursuant to the required procedures for that Subdivision to agree to a legally binding settlement.

3. Population Percentage Calculation. For purposes of this Exhibit O only, Population Percentages shall be determined as follows: For States with functional counties or parishes1, the Population Percentage of each county or parish shall be deemed to be equal to (a) (1) two hundred percent (200%) of the population of such county or parish, minus (2) the aggregate population of all Primary Incorporated Municipalities located in such county or parish, divided by (b) two hundred percent (200%) of the State’s population. A “Primary Incorporated Municipality” means a city, town, village or other municipality incorporated under applicable state law with a population of at least 25,000 that is not located within another incorporated municipality. The Population Percentage of each Primary Incorporated Municipality shall be equal to its population (including the population of any incorporated or unincorporated municipality located therein) divided by two hundred percent (200%) of the State’s population; provided that the Population Percentage of a Primary Incorporated Municipality that is not located within a county shall be equal to two hundred percent (200%) of its population (including the population of any incorporated or unincorporated municipality located therein) divided by two hundred percent (200%) of the State’s population. For all States that do not have functional counties or parishes, the Population Percentage of each non-county Subdivision

1 Certain states do not have counties or parishes that have functional governments, including Alaska, Connecticut, Massachusetts, Rhode Island, and Vermont.

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(including any incorporated or unincorporated municipality located therein), shall be equal to its population divided by the State’s population.

4. Preexisting Agreements and Statutory Provisions. A State may include with the notice to its Subdivisions an existing agreement, a proposed agreement, or statutory provisions regarding the distribution and use of settlement funds and have the acceptance of such an agreement or statutory provision be part of the requirements to be an Initial Participating Subdivision.

5. Revised Agreements. A State-Subdivision Agreement that has been revised, supplemented, or refined shall be applied if it meets the requirements of Section VIII and is approved by the State and by the State’s Subdivisions pursuant to the terms above.

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EXHIBIT P
Injunctive Relief

I. DEFINITIONS
A. “Health Care Provider(s)” means any physician or other health care practitioner who is licensed to provide health care services or to prescribe pharmaceutical medications and any medical facility, practice, hospital, clinic, pharmacy, or any other health facility that provides health care services or prescribes or dispenses pharmaceutical medications.

B. “In-Kind Support” means payment or assistance in the form of goods, commodities, services, or anything else of value.

C. “Lobby” and “Lobbying” shall have the same meaning as “lobbying activities” and “lobbying contacts” under the federal lobbying disclosure act, 2 U.S.C. § 1602 et seq., and any analogous state or local provisions governing the person or entity being lobbied. As used in this document, “Lobby” and “Lobbying” include Lobbying directly or indirectly, through grantees or Third Parties.

D. “Opioid(s)” means all naturally occurring, synthetic, or semisynthetic substances that interact with mu-opioid receptors primarily in the central nervous system and have demonstrated addictive properties.

E. “Opioid-Induced Side Effects Treatment Product(s)” shall mean any pharmaceutical product that has been approved by the U.S. Food & Drug Administration (“FDA”) and expressly indicated for the treatment of a specified “Opioid-induced” side effect (such as Movantik® which is “an opioid antagonist indicated for the treatment of opioid-induced constipation”). The term “Opioid- Induced Side Effects Treatment Product(s)” shall not include pharmaceutical products that may treat medical conditions that may also be side effects of Opioids or Opioid Products or that may treat someone who uses or has a history of using Opioids or Opioid Products and was diagnosed with certain medical conditions (e.g., anxiety, depression, and Hepatitis C), unless the FDA approved indication states that it is approved to treat a specific “Opioid-induced” side effect by expressly referencing that the side effect was caused by an Opioid or Opioid Product (e.g., “Opioid-induced”). Also, by way of example, the term “Opioid- Induced Side Effects Treatment Product(s)” shall not include the following pharmaceutical medications: BOTOX®, CELEXA®, FETIZMA®, HUMIRA®, LEXAPRO®, LINZESS®, NIMBEX®, ORIAHNN®, ORILISSA®, QULIPTA®, RINVOQ®, SAVELLA®, UBRELVY®, ULTANE®, ULTANE NOVAPLUS®, VIBERZI®, or VIEKIRA PAK®.

F. “Opioid Product(s)” means all past, current, and future medications containing Opioids approved by the FDA and listed by the U.S. Drug Enforcement Agency (“DEA”) as Schedule II, III, or IV drugs pursuant to the federal Controlled

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Substances Act (including but not limited to buprenorphine, codeine, fentanyl, hydrocodone, hydromorphone, meperidine, methadone, morphine, oxycodone, oxymorphone, tapentadol, and tramadol). The term “Opioid Product(s)” shall not include (1) methadone, buprenorphine, and other substances when used exclusively to treat opioid abuse, addiction, OUD, or overdose; or (2) raw materials, immediate precursors, and/or active pharmaceutical ingredients (“APIs”) used in the manufacture or study of Opioids or Opioid Products, but only when such materials, immediate precursors, and/or APIs are sold or marketed exclusively to DEA- licensed manufacturers or DEA-licensed researchers. Also, by way of example, the terms “Opioid(s)” and “Opioid Product(s)” shall not include pharmaceutical medications that may relieve pain but not by interacting with mu-opioid receptors primarily in the central nervous system, such as BOTOX®, CELEXA®, FETIZMA®, HUMIRA®, LEXAPRO®, LINZESS®, NIMBEX®, ORIAHNN®, ORILISSA®, QULIPTA®, RINVOQ®, SAVELLA®, UBRELVY®, ULTANE®, ULTANE NOVAPLUS®, VIBERZI®, or VIEKIRA PAK®.

G. “OUD” means opioid use disorder defined in the Diagnostic and Statistical Manual of Mental Disorders, Fifth Edition (DSM–5), as updated or amended.

H. “Settling State” shall mean each State or United States territory that meets the participation requirements for becoming a Settling State under Section II of the Allergan Public Global Settlement Agreement and then participates in the Allergan Public Global Settlement Agreement.

I. “Promote,” “Promoting,” “Promotion,” and “Promotional” shall mean dissemination of information or other practices intended or that could reasonably be anticipated to increase the sale, prescription, or utilization of prescription products or that attempt to influence prescribing practices or formulary decisions in the Settling States.

J. “Third Party(ies)” means any person or entity other than Allergan or a Releasor.

K. “Treatment of Pain” means the provision of therapeutic modalities to alleviate or reduce pain.

L. “Unbranded Information” means any information that does not identify a specific branded or generic product.

II. INJUNCTIVE RELIEF
Allergan does not currently manufacture, sell, Promote, or Lobby for any Opioids or Opioid Products. As provided below, Allergan shall not manufacture, sell, Promote, or Lobby for any Opioids or Opioid Products in or for distribution in the Settling States or in a manner that directly affects the Settling States. However, the Parties acknowledge that certain Opioids or Opioid Products sold by Allergan prior to 2021 may still be circulating in the marketplace outside the possession and control of Allergan and the same is not a breach of any terms within this Exhibit P. Further, Allergan does not currently manufacture, sell, Promote, or Lobby for any Opioid - Induced Side Effects Treatment Products, and does not have any current intentions to do so in the

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future. For the avoidance of doubt, only the Settling States shall have the ability to enforce the terms of this Agreement.

For purposes of this Exhibit P only, Allergan means Allergan Finance, LLC (f/k/a Actavis, Inc., which, in turn, was f/k/a Watson Pharmaceuticals, Inc.), Allergan Limited (f/k/a Allergan plc which, in turn, was f/k/a Actavis plc), and AbbVie Inc., and each of their respective parents (as applicable), subsidiaries, successors, affiliates, and officers, directors, employees, representatives, and agents under the control of the foregoing.

A. Compliance Duration

1. Unless addressed in Section II.A.2 below, each term of Section II of this Exhibit P shall be effective for ten (10) years from the Effective Date and is limited to conduct that involves or affects the Settling States.

2. The provisions of Section II.H.1, Section II.H.2, and Section II.I shall not be subject to any term.

3. Nothing in this Exhibit P shall relieve Allergan of its independent obligation to fully comply with the laws of the Settling States before or after expiration of the injunction period specified in this subsection.

B. Ban on Selling and Manufacturing Opioids

1. Allergan shall not manufacture or sell any Opioids or Opioid Products for distribution in the Settling States. Allergan represents that Kadian® and Norco® were voluntarily discontinued by the end of 2020 and that the last inventory shipped will expire on or before June 30, 2023.

C. Ban on Promotion

1. Allergan shall not engage in Promotion of Opioids or Opioid Products, including but not limited to, by:
a. Employing or contracting with sales representatives, Health Care Providers, any Third Party, or other persons to Promote Opioids or Opioid Products to (i) Health Care Providers, (ii) patients, (iii) third- party payors (e.g., any entity, other than an individual, that pays or reimburses for the dispensing of prescription medicines, including but not limited to manage care organizations and pharmacy benefit managers), or (iv) persons involved in determining formulary access or treatment guidelines to Promote Opioids or Opioid Products; b. Using speakers, key opinion leaders, thought leaders, lecturers, and/or speaking events for Promotion of Opioids or Opioid Products;

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c. Creating or distributing (directly or indirectly through Third Parties) Promotional materials (such as advertisements) that Promote Opioids or Opioid Products, including but not limited to brochures, newsletters, pamphlets, journals, books, guides, websites or internet advertisements, social media accounts or networks, and providing hyperlinks, engaging in internet search engine optimization, or otherwise directing internet traffic by improving rankings or making content appear among the top results in an internet search or otherwise be more visible or more accessible to the public on the internet to Promote Opioids or Opioid Products; and
d. Disseminating Unbranded Information (such as about a medical condition or disease state) that contains links to branded Promotional information about Opioids or Opioid Products or that generates data that Allergan uses to Promote Opioids or Opioid Products.

2. Allergan shall not engage in the following specific Promotion of Treatment of Pain to Promote Opioids or Opioid Products.
a. Allergan shall not Promote the Treatment of Pain to Promote Opioids, except that Allergan may continue to Promote the Treatment of Pain with non-Opioids.
b. Allergan shall not knowingly Promote the Treatment of Pain to Promote Opioids through Third Parties, except that Allergan may continue to Promote the Treatment of Pain with non-Opioids. c. Allergan shall not Promote the concept that pain is undertreated to Promote Opioids or Opioid Products.
d. Allergan shall not knowingly Promote the concept that pain is undertreated through Third Parties to Promote Opioids or Opioid Products.

3. Allergan shall not engage in the following specific Promotion of Opioid- Induced Side Effects Treatment Products to Promote Opioids or Opioid Products.
a. Allergan shall not Promote Opioid-Induced Side Effects Treatment Products with or by referring directly to Opioids or Opioid Products (including with Unbranded Information).
b. Allergan shall not knowingly Promote Opioid-Induced Side Effects Treatment Products with or by referring directly to Opioids or Opioid Products through Third Parties.

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c. Nothing in this section shall prevent Allergan from conveying the information contained in an FDA-approved label in the course of Promotion of Opioid-Induced Side Effects Treatment Products.

4. Section II.C.1-3 is not intended and shall not be interpreted to prohibit or restrict any and all discussions or references to Opioids or Opioid Products or any Allergan conduct (including Promotion) related to non-Opioid Products (including those that are approved for the Treatment of Pain or Opioid-Induced Side Effects Treatment Products) when doing so is not to Promote Opioids or Opioid Products, including, for example, (a) if certain patient populations, such as those with a history of abuse of Opioids or Opioid Products, are identified as having a higher prevalence of other conditions, such as Hepatitis C, or being appropriate candidates for treatment of those other conditions, (b) if such discussions or references relate to products that may treat medical conditions that may also be side effects of Opioids or Opioid Products (e.g., anxiety, depression, and Hepatitis C), and/or (c) if such discussions or references relate to the Promotion of BOTOX®, CELEXA®, FETIZMA®, HUMIRA®,
LEXAPRO®, LINZESS®, NIMBEX®, ORIAHNN®, ORILISSA®,
QULIPTA®, RINVOQ®, SAVELLA®, UBRELVY®, ULTANE®,
ULTANE NOVAPLUS®, VIBERZI®, or VIEKIRA PAK®.

5. Notwithstanding Sections II.C.1-3 directly above, Allergan may engage in non-Promotional conduct, including but not limited to the following:
a. Maintain a corporate website that includes Opioid Products on company’s list of products that contains principally the following content: the FDA-approved package insert, medication guide, and labeling;
b. Maintain a product website for any Opioid Product that contains principally the following content: the FDA-approved package insert, medication guide, and labeling, and a statement directing patients or caregivers to speak with a licensed Health Care Provider; c. Provide the following factual information about Opioid Products sold by Allergan prior to 2021 which may still be circulating in the marketplace outside the possession and control of Allergan: an Opioid Product’s NDC, SKU, or other relevant information such as formulation, package size, dosage, or pricing;
d. Provide or collect information or support the provision or collection of information as expressly required by law or any state or federal government agency with jurisdiction in the Settling State where the information is provided (including but not limited to collecting and/or reporting adverse events related to Opioid Products);

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e. Provide the following by mail, electronic mail, on or through Allergan’s corporate or product websites, or through other electronic or digital methods: FDA-approved package insert, medication guide, and labeling for Opioid Products, or other prescribing information for Opioid Products that are published or approved by a state or federal government agency with jurisdiction in the Settling State where the information is provided; f. Provide scientific and/or medical information in response to an unsolicited request by a Health Care Provider consistent with FDA standards, rules, regulations, and/or guidance, including, but not limited to, Responding to Unsolicited Requests for Off-Label Information About Prescription Drugs and Medical Devices (Dec. 2011) as updated or amended by the FDA, and Guidance for Industry, Good Reprint Practices for the Distribution of Medical Journal Articles and Medical or Scientific Reference Publications on Unapproved New Uses of Approved Drugs and Approved or Cleared Medical Devices (Jan. 2009) as updated or amended by the FDA;
g. Provide a response to any unsolicited question or request from a patient or caregiver, directing the patient or caregiver to the FDA- approved package insert, medication guide, and labeling for Opioid Products, to speak with a licensed Health Care Provider without describing the safety or effectiveness of any Opioid Product or naming any specific Health Care Provider , or to speak with their health insurance carrier regarding coverage of an Opioid Product; h. Provide Health Care Economic Information, as defined at 21 U.S.C. § 352(a), to a payor, formulary committee, or other similar entity with knowledge and expertise in the area of health care economic analysis consistent with FDA standards, rules, regulations, and/or guidance, including, but not limited to, FDA’s Draft Questions and Answers Guidance for Industry and Review Staff, Drug and Device Manufacturer Communications With Payors, Formulary
Committees, and Similar Entities (Jan. 2018), as updated or amended by the FDA;
i. Conduct or provide financial support or In-Kind Support for bona fide scientific research; and
j. Draft, publish, or provide financial support or In-Kind Support for bona fide scientific publications.

6. To the extent that Allergan engages in conduct permitted by Section II.C.4 and 5 above, Allergan shall do so in a manner that is truthful, non - misleading, accurate, and non-deceptive.

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D. No Financial Reward or Discipline Based on Volume of Opioid Product Sales

1. Allergan shall not provide financial incentives to its sales and marketing employees or discipline its sales and marketing employees based upon sales volume or sales quotas for Opioid Products.

2. Allergan shall not offer or pay any remuneration (including any compensation or rebate), directly or indirectly (e.g., through Third Parties), to any person in return for the prescribing, sale, use, or distribution of an Opioid Product (except to the extent a pre-existing contractual or legal requirement exists related to Opioid Products sold by Allergan before 2021).

E. Ban on Funding/Grants to Third Parties

1. Allergan shall not directly or indirectly provide financial support or In- Kind Support to any Third Party regarding conduct that Promotes Opioids or Opioid Products, including educational programs, brochures, newsletters, pamphlets, journals, books, guides, websites, or social media accounts or networks that Promote Opioids or Opioid Products, including Promoting Opioids or Opioid Products through the Promotion of Treatment of Pain, but excluding financial support otherwise required by this Exhibit P, a court order, a federal or state agency (e.g., FDA-approved Risk Evaluation and Mitigation Strategy (REMs)), or a federal or state law or regulation.

2. Allergan shall not directly or indirectly provide financial support or In- Kind Support to any Third Party for medical education programs to Promote Opioids or Opioid Products.

3. Allergan shall not create, sponsor, provide financial support or In-Kind Support to, or otherwise operate or control, any medical society or patient advocacy group related to conduct that Promotes Opioids or Opioid Products (including Promoting Opioids or Opioid Products through the Promotion of Treatment of Pain).

4. Allergan shall not provide links to any Third Party website or materials or otherwise distribute materials created by a Third Party for the purpose of Promoting Opioids or Opioid Products (including Promoting Opioids or Opioid Products through the Promotion of Treatment of Pain).

5. Allergan shall not use, assist, or employ any Third Party to engage in any activity that Allergan itself would be prohibited from engaging in pursuant to this Exhibit P. To the extent Allergan supports trade groups engaged in Lobbying, Allergan shall notify the trade groups at the time it makes its trade association payments that Allergan’s support shall not be used to encourage the use of Opioids or Opioid Products or discourage the use of non-Opioids or Opioid Products for the purpose of indirectly encouraging

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the use of Opioids or Opioid Products (but shall not be responsible for how the trade group ultimately uses the support provided because it is outside of Allergan’s control).

6. Allergan shall not enter into any contract or agreement with any person or entity or otherwise attempt to influence any person or entity in such a manner that has the purpose or foreseeable effect of limiting the dissemination of information regarding the risks and side effects of using Opioids or Opioid Products.

7. No officer or Vice President -level employee of Allergan may concurrently serve as a director, board member, employee, agent, or officer of any entity that primarily engages in conduct that Promotes Opioids or Opioid Products. Nothing in this provision shall preclude an officer or Vice President -level employee of Allergan from concurrently serving on the board of a hospital.

8. Allergan shall play no role in appointing persons to the board, or hiring persons to the staff, of any Third Party that primarily engages in conduct that Promotes Opioids or Opioid Products. For avoidance of doubt, nothing in this paragraph shall prohibit Allergan from fully and accurately responding to unsolicited requests or inquiries about a person’s fitness to serve as an employee or board member at any such Third Party.

F. Lobbying Restrictions

1. Allergan shall not Lobby for the enactment of any federal, state, or local legislative or regulatory provision that:
a. Encourages or requires Health Care Providers to prescribe Opioids or Opioid Products or sanctions Health Care Providers for failing to prescribe Opioids or failing to treat pain with Opioids; b. Has the effect of limiting access to any non-Opioid alternative pain treatments; or
c. Pertains to the classification of any Opioid or Opioid Product as a scheduled drug under the Controlled Substances Act.

2. Allergan shall not Lobby against the enactment of any federal, state, or local legislative or regulatory provision that supports:
a. The use of non-pharmacologic therapy and/or non-Opioid pharmacologic therapy to treat chronic pain over or instead of Opioids or Opioid Products , including but not limited to Third Party payment or reimbursement for such therapies;

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b. The use and/or prescription of immediate release Opioids or Opioid Products instead of extended-release Opioids or Opioid Products when an Opioid or Opioid Product is initiated, including but not limited to Third Party reimbursement or payment for such prescriptions;
c. The prescribing of the lowest effective dose of an Opioid or Opioid Product, including but not limited to Third Party reimbursement or payment for such prescriptions;
d. The limitation of initial prescriptions of Opioids or Opioid Products to treat acute pain;
e. The prescribing and other means of distribution of naloxone to minimize the risk of overdose, including but not limited to Third Party reimbursement or payment for naloxone;
f. The use of urine testing before starting use of Opioids or Opioid Products and annual urine testing when Opioids or Opioid Products are prescribed, including but not limited to Third Party reimbursement or payment for such testing;
g. Evidence-based treatment (such as using medication-assisted treatment with buprenorphine or methadone in combination with behavioral therapies) for OUD, including but not limited to Third Party reimbursement or payment for such treatment; or
h. The implementation or use of disposal systems when solely related to Opioids or Opioid Products (versus of general applicability to all pharmaceutical medications, for example).

3. Allergan shall not Lobby against the enactment of any federal, state, or local legislative or regulatory provision expanding the operation or use of Prescription Drug Monitoring Programs (“PDMPs”), including but not limited to provisions requiring Health Care Providers to review PDMPs when Opioid Product use is initiated and with every prescription thereafter.

4. Notwithstanding the foregoing restrictions in Sections II.F.1-3, the following conduct is not restricted:
a. Challenging the enforcement or interpretation of (including, but not limited to, suing for declaratory or injunctive relief) any laws, rules, or regulations;
b. Communications by Allergan in response to a law, rule, regulation, or order requiring such communication;

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c. Communications by an Allergan representative appearing before a federal or state legislative, administrative, or regulatory body, committee, or subcommittee as a result of a mandatory order or subpoena commanding that person or Allergan’s designee to testify; d. Responding, in a manner consistent with this Exhibit P, to an unsolicited request for the input on the passage of legislation or the promulgation of any rule or regulation when such request is submitted in writing specifically to Allergan from a government entity directly involved in the passage of that legislation or promulgation of that rule or regulation; or
e. Lobbying for or against provisions of legislation, rule, or regulation that address subjects other than those identified in Sections II.F.1-3, so long as Allergan does not support specific portions of such legislation, rule, or regulation covered by Section II.F.1 or oppose specific portions of such legislation, rule, or regulation covered by Sections II.F.2-3. Allergan may Lobby for or against any legislation, rule, or regulation that may be covered by Sections II.F.1-3, if such legislation, rule, or regulation has general or specific provisions that affect medications beyond Opioids or Opioid Products, so long as Allergan’s intent and purpose of doing so is not to Promote Opioids or Opioid Products.

G. Ban on Prescription Savings Programs

1. Allergan shall not directly or indirectly offer any discounts, coupons, rebates, or other methods which have the effect of reducing or eliminating a patient’s co-payments or the cost of prescriptions (e.g., free trial prescriptions) for any Opioid Product (except to the extent a pre-existing contractual or legal requirement exists related to Opioid Products sold by Allergan before 2021).

2. Allergan shall not directly or indirectly provide financial support to any Third Party for discounts, coupons, rebates, or other methods which have the effect of reducing or eliminating a patient’s co-payments or the cost of prescriptions (e.g., free trial prescriptions) for any Opioid Product (except to the extent a pre-existing contractual or legal requirement exists related to Opioid Products sold by Allergan before 2021).

3. Allergan shall not directly or indirectly assist patients or Health Care Providers with the claims and/or prior authorization process required for third-party payors to approve payment for any Opioid Product.

4. Allergan may directly or indirectly provide financial support or In-Kind Support for non-Opioids to any Third Party that provides patient assistance

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or support services for the purposes of helping patients afford and gain access to the medications prescribed to them.

H. General Terms

1. Allergan shall not make any written or oral statement about Opioids or any Opioid Product that is unfair, false, misleading, deceptive or unconscionable as defined under the law of the Settling States. For purposes of this paragraph, “Opioid Product” shall also include methadone, buprenorphine, and other substances when used exclusively to treat opioid abuse, addiction, or overdose.

2. Allergan shall not represent that Opioids or any Opioid Product(s) have approvals, characteristics, uses, benefits, or qualities that they do not have.

For purposes of this paragraph, “Opioid Product” shall also include methadone, buprenorphine, and other substances when used exclusively to treat opioid abuse, addiction, or overdose.

3. This Exhibit P shall not be construed or used as a waiver or limitation of any defense otherwise available to Allergan or any Released Entity in any action, and nothing in this Exhibit P is intended to or shall be construed to prohibit Allergan or any Released Entity in any way whatsoever from taking legal or factual positions with regard to any Opioid Products in prosecution or defense of litigation or other legal proceedings.

4. Upon the request of the Attorney General of any Settling State, Allergan shall provide the Attorney General with copies of the following, within forty-five (45) days of the request:
a. Any litigation or civil or criminal law enforcement subpoenas or CID relating to Allergan’s Opioid Product(s) that Allergan received after the Effective Date of the Agreement; and
b. Warning or untitled letters issued by the FDA regarding Allergan’s Opioid Product(s) and all correspondence between Allergan and the FDA related to such letters that Allergan received after the Effective Date of the Agreement.

5. Nothing in this Exhibit P shall be construed to limit or impair Allergan’s ability to:
a. Communicate its positions and/or respond to media inquiries concerning litigation, investigations, or other proceedings or matters relating to Allergan or its Opioid Products.
b. Maintain a website explaining its litigation positions and responding to allegations concerning Allergan or its Opioid Products.

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I. Compliance with All State Laws and Regulations Relating to the Sale, Promotion, and Distribution of Any Opioid Product

1. Allergan shall comply with all applicable State laws and regulations that relate to the sale, Promotion, distribution, and disposal of Opioids or Opioid Products in the Settling States, provided that nothing in this paragraph requires Allergan to violate federal law or regulations, including but not limited to:
a. State Controlled Substances Act, including all guidance issued by the applicable state regulator(s);
b. State Consumer Protection Laws; and
c. State laws, regulations, and guidelines related to the prescribing, distribution, and disposal of Opioid Products.

J. Clinical Data Transparency

1. Allergan agrees to make available to an independent Third-Party data center or platform owner (e.g., Vivli) anonymized clinical data generated from Allergan-sponsored Phase II-IV interventional clinical studies—regardless of whether that data was submitted to a regulatory authority (e.g., FDA)— for branded opioid drugs that are Opioids or Opioid Products that have received an initial marketing authorization from a regulatory authority to the extent Allergan conducts a reasonable, good faith investigation to locate any such data and it is in Allergan’s possession. Anonymized clinical data includes:
a. Full analyzable data set(s) (including individual participant-level data de-identified);
b. The clinical study report(s) redacted for commercial or personal identifying information;
c. The full protocol(s) (including the initial version, final version, and all amendments); and

2. Full statistical analysis plan(s) (including all amendments and documentation for additional work processes); and Dataset Specifications, which describe the available dataset variables (such as age, race, blood pressure, lab values, etc.).

3. The independent Third Party will facilitate the disclosure of such clinical data to qualified researchers with a bona fide scientific research proposal as reviewed and approved by an independent review panel for scientific merit consistent with the panel’s assessment criteria and pursuant to an agreed upon data use agreement.

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4. Allergan shall not interfere with decisions made by the staff or reviewers associated with the independent Third-Party data center or platform owner.

5. Allergan shall bear all costs for making clinical data available pursuant to Section II.J.1 of this Exhibit P.

III. DOCUMENT DISCLOSURE
A. Documents Subject to Public Disclosure
The following documents must be provided to each Settling State and are subject to public disclosure in perpetuity, except for the redactions authorized by section B:

1. All Allergan-produced documents admitted as trial exhibits in In re Opioid Litigation, Index No. 400000/2017 (N.Y. Sup. Ct., Suffolk County), The City and County of San Francisco, California and the People of the State of California, acting by and through San Francisco City Attorney David Chiu v. Purdue Pharma L.P., et al., Case No. 3:18-cv-07591 (N.D. Cal.), The State of West Virginia ex rel. Patrick Morrisey, Attorney General v. Teva Pharmaceutical Industries Ltd., et al., Civil Action No. 19-C-104 BNE (W.

Va. Cir. Ct., Boone County), or The People of the State of California, acting by and through Santa Clara County Counsel James R. Williams, Orange County District Attorney Tony Rackauckas, Los Angeles County Counsel Mary C. Wickham, and Oakland City Attorney Barbara J. Parker v. Purdue Pharma L.P., et al., Case No. 30-2014-00725287-CU-BT-CXC (Cal. Super.

Ct., Orange County), together with complete trial transcripts.

2. All Allergan deposition transcripts, and exhibits from or produced in the matters identified in subsection III.A.1, as well as in In re Nat’l Prescription Opiate Litig., No. 1:17-md-02804 (N.D. Ohio).

3. All summary judgment filings, proposed findings of fact and law, and expert reports relating to the claims against Allergan that were filed in the matters identified in subsections III.A.1 and III.A.2, together with related exhibits.

4. All documents provided under this provision must be provided in an appropriate electronic format with appropriate metadata.

5. In addition, Allergan shall not object to public disclosure of the following documents, without further redaction: Acquired_Actavis_00000001- Acquired_Actavis_02689490.

B. Information That Allergan May Redact

1. The following categories of information are exempt from public disclosure:

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a. Information subject to trade secret protection. A “trade secret” is information, including a formula, pattern, compilation, program, device, method, technique or process, that (a) derives independent economic value, actual or potential, from not being generally known to the public or to other persons who can obtain economic value from its disclosure and use; and (b) is the subject of efforts that are reasonable under the circumstances to maintain its secrecy. Even if the information falls within the definition, “trade secret” does not include information reflecting sales or promotional strategies, tactics, targeting, or data, or internal communications related to sales or promotion or information in documents dated more than five (5) years before the disclosure required by this section.
b. Confidential personal information. “Confidential personal information” means individual Social Security or tax identification numbers, personal financial account numbers, passport numbers, driver license numbers, home addresses, home telephone numbers, personal email addresses, and other personally identifiable information protected by law from disclosure. “Confidential personal information” does not include the names of Allergan’s officers, directors, employees, consultants, agents, or attorneys or of prescribers or of officials of a government agency.
c. Information that is inappropriate for public disclosure because it is subject to personal privacy interests recognized by law (e.g., HIPAA), or contractual rights of third parties that Allergan may not abrogate.
d. Information regarding Allergan employees’ personal matters unrelated to Allergan, including emails produced by Allergan custodians discussing vacation or sick leave, family, or other personal matters.
e. Information that is protected by the attorney–client or attorney work product privilege.
f. Financial documents designated as “Highly Confidential” or “Highly Confidential Information” under Case Management Order No. 2 in In re Nat’l Prescription Opiate Litig., No. 1:17-md-02804 (N.D. Ohio) and produced in response to the April 3, 2019 Ruling Regarding Jurisdictional Discovery on Defendants Allergan, Teva, and Mallinckrodt, including tax returns including all schedules and attachments, policies regarding accounting, and annual reports.

C. Redaction of Documents Containing Protected Information

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1. Whenever a document contains information subject to a claim of exemption pursuant to section B, Allergan will provide the document in redacted form.

Such redactions must indicate that trade secret and/or private information, as appropriate, has been redacted. Redactions are limited to the minimum redactions possible, consistent with section B.

2. Allergan must provide to each Settling State a log noting each document redacted. The log must also provide fields stating the basis for redacting the document, with sufficient detail to allow an assessment of the merits of the assertion. The log is subject to public disclosure in perpetuity. The log shall be provided by the production deadline.

3. In addition to the redacted documents, Allergan shall, upon any Settling State’s request, also produce all documents identified in subsection III.A above in unredacted form to such Settling State at the same time, but only to the extent the document was produced by Allergan in an unredacted form in the underlying litigation, and only for the purpose of permitting a merits assessment and potential challenge of the redaction pursuant to Section IV herein.

D. Public Disclosure Through a Document Repository

1. Each Settling State may publicly disclose all documents covered by this section through a public repository maintained by a governmental, non- profit, or academic institution. Each Settling State may specify the terms of any such repository’s use of those documents, including allowing the repository to index and make searchable all documents subject to public disclosure, including the metadata associated with those documents.

E. Timeline for Production

1. Allergan shall produce all documents required by Section A within nine months from the Effective Date.

F. Support Payment

1. Within thirty (30) calendar days of the Effective Date, Allergan will make one-time payments totaling $1,375,000 to the University of California, San Francisco Foundation (UCSF Foundation) and The Johns Hopkins University, to be used to support a public repository of documents subject to this section.

IV. ENFORCEMENT
A. For the purposes of resolving disputes with respect to compliance with Exhibit P, should any of the Settling States have reason to believe that Allergan has violated a provision of Exhibit P, then such Settling State shall notify Allergan in writing of the specific objection, identify with particularity the provisions of Exhibit P that

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the practice appears to violate, and give Allergan thirty (30) days to respond to the notification (“Response Period”).

B. Upon receipt of written notice from any of the Settling States, Allergan shall provide a written response to the Settling State’s notification, containing either a statement explaining why Allergan believes it is in compliance with Exhibit P, or a detailed explanation of how the alleged violation occurred and a statement explaining how and when Allergan intends to remedy or has remedied the alleged violation. Allergan may request a reasonable amount of additional time to cure any violation through such remedial measures (“Cure Period”) and the Settling State shall not unreasonably withhold approval of such request.

C. The Settling State may not take any action concerning the alleged violation of Exhibit P during the Response and Cure Periods. Nothing shall prevent the Settling State from agreeing in writing to provide Allergan with additional time beyond the thirty (30) days to respond to the notice. However, the Settling State may take any action, including, but not limited to legal action to enforce compliance with the Consent Judgment, without delay if the Settling State believes that a threat to the health or safety of the public requires immediate action.

D. The Settling State may bring an action against Allergan to enforce the terms of Exhibit P, but only after providing Allergan an opportunity to respond to the notification and, if agreed upon, a period to cure any violation, as described above, or within any other period as agreed to by Allergan and the Settling State.

E. Nothing in this Consent Judgment shall be interpreted to limit any Settling State’s Civil Investigative Demand (“CID”) or investigative subpoena authority, to the extent such authority exists under applicable state law.

F. Nothing herein shall be construed to exonerate any failure to comply with any provision of Exhibit P after the Effective Date, or to compromise the authority of any Settling State to take action for any failure to comply with Exhibit P, consistent with this section.

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EXHIBIT Q
[Intentionally Omitted]

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EXHIBIT R
Agreement on Attorneys’ Fees, Costs, and Expenses
This Agreement on Attorneys’ Fees, Expenses, and Costs (“Fee Agreement”) is entered between Teva, Allergan, and the Plaintiffs’ Executive Committee appointed in the multidistrict litigation in the Northern District of Ohio, In re National Prescription Opiate Litigation, No. 1:17- md-02804 (“MDL PEC”), in connection with the Teva Global Opioid Settlement Agreement (“Teva Agreement”) and the Allergan Public Global Opioid Settlement Agreement (“Allergan Agreement”). This Fee Agreement becomes effective on the Effective Date of the Teva Agreement and Allergan Agreement or the date that the Consent Judgments anticipated under the Teva Agreement and Allergan Agreement become final in 25 Settling States (whichever is later).

I. Definitions
A. This Fee Agreement incorporates all defined terms in the Teva Agreement and Allergan Agreement, unless otherwise defined herein, and shall be interpreted in a manner consistent with the Teva Agreement and Allergan Agreement.

B. “Allergan.” Allergan Finance, LLC (f/k/a Actavis, Inc., which, in turn, was f/k/a/ Watson Pharmaceuticals, Inc.) and Allergan Limited (f/k/a Allergan plc, which, in turn, was f/k/a Actavis plc). Allergan does not include Teva Pharmaceuticals Industries Ltd. (“Teva Ltd.”), Teva Pharmaceuticals USA, Inc. (“Teva USA”), Cephalon, Inc. (“Cephalon”), Actavis LLC (f/k/a Actavis Inc.) (“Actavis LLC”), Watson Laboratories, Inc. (“Watson”), Actavis Pharma, Inc. (f/k/a Watson Pharma, Inc.) (“Actavis Pharma”), Actavis Elizabeth LLC (“Actavis Elizabeth”), Actavis Kadian LLC (“Actavis Kadian”), Actavis Laboratories FL, Inc. (f/k/a Watson Laboratories, Inc. - Florida) (“Actavis Labs FL”), Actavis Laboratories UT, Inc. (f/k/a Watson Laboratories, Inc. - Utah) (“Actavis Labs UT”), Actavis Mid Atlantic LLC (“Actavis Mid”), Actavis South Atlantic LLC (“Actavis South”), Actavis Totowa LLC (“Actavis Totowa”), or Anda, Inc. (“Anda”).

C. “Applicant.” Any Attorney or MDL Participating Counsel who seeks an award of attorneys’ fees from the Attorney Fee Fund pursuant to the procedures established by the MDL Court and the Fee Panel.

D. “Attorney.” Any of the following retained through a legal contingency fee or hourly fee contract: a solo practitioner, multi-attorney law firm, or other legal representative of a Participating Subdivision or MDL Participating Counsel. This does not include Subdivision in-house attorneys.

E. “Attorney Fee Fund.” An account consisting of funds allocated to pay attorneys’ fees approved pursuant to Section III of this Fee Agreement established by Order of and under the ongoing jurisdiction of the MDL Court, as provided below.

F. “Common Benefit.” Work performed for the benefit of all Participating Subdivisions or Tribal Nations, including, but not limited to, pretrial matters,

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discovery, trial preparation, trial, settlement negotiations, and all other work that advances the interests of the Participating Subdivisions.

G. “Common Benefit Fund.” The sub fund of the Attorney Fee Fund described in subsection III.E.

H. “Contingency Fee Fund.” The sub fund of the Attorney Fee Fund described in subsection III.F.

I. “Cost and Expense Fund Administrator.” The administrator appointed by the MDL Court on August 12, 2021 (MDL Docket No. 3828), to administer the Cost Fund and its sub funds as provided in the Fee Agreement.

J. “Court Common Benefit Fund.” The Common Benefit Fund established by the MDL Court in its orders of July 22, 2021, MDL Docket No. 3794, and May 9, 2022, MDL Docket No. 4428.

K. “Fee Entitlement.” Any right, entitlement, or expectation, including but not limited to a fee contract, contingent fee contract, agreement, referral arrangement, co- counsel arrangement, State Back-Stop agreement, or any other arrangement by which counsel could receive compensation or other consideration. For the avoidance of doubt, the scope of Fee Entitlement under subparagraph III.G.3.a does not include any Attorneys’ fees associated with representation of a State.

L. “Fee Panel.” The three-person panel appointed by the MDL Court on August 12, 2021 (MDL Docket No. 3828), to administer and make recommendations for the allocation and distribution of the Attorney Fee Fund and its sub funds as provided in the Fee Agreement.

M. “Later Litigating State.” A State that first files a lawsuit bringing a Released Claim against a Released Entity after the Preliminary Agreement Date.

N. “MDL Court.” United States District Court for the Northern District of Ohio Eastern Division, Case No. 1:17-md-02804, Judge Dan Aaron Polster.

O. “MDL Direct Cost Fund.” The cost fund described in subparagraph II.A.3.a below.

P. “MDL Participating Counsel.” MDL Participating Counsel includes an attorney or firm authorized by MDL 2804 Lead Counsel to perform work for the Common Benefit of Participating Subdivisions. By way of example, it would i nclude insurance counsel and appellant counsel.

Q. “MDL PEC.” The Plaintiffs’ Executive Committee appointed by the MDL Court.

R. “Non-Participating Litigating Subdivision.” A Litigating Subdivision that is not a Participating Subdivision.

S. “Non-Participating State.” A State that is not a Participating State.

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T. “Participating Litigating Subdivision.” A Litigating Subdivision that is also a Participating Subdivision.

U. “Participation Agreement.” An agreement executed by an Attorney that acknowledges the obligation to pay an appropriate MDL Common Benefit Assessment.

V. “Qualified Tribal Representation.” Representation by an attorney of a Participating Tribal Government regarding Released Claims against Released Entities. Such counsel are eligible for Common Benefit Fee consideration. The Teva Tribal Global Settlement and the Allergan Tribal Global Settlement will provide for the contribution to the Common Benefit Fund as determined by the MDL Court.

W. “Qualifying Representation.” Legal services provided for representation of the MDL PEC or Participating Litigating Subdivision regarding Released Claims against Released Entities.

X. “State Back-Stop Agreement.” Any agreement by a Settling State and private counsel for Participating Subdivisions in that State (or legislation enacted in that State) to provide, adjust, or guarantee attorneys’ fees and costs, whether from the Attorney Fee Fund or any other source recognized in the agreement or legislation.1 Y. “Subdivision Cost and Expense Fund.” The fund created to pay approved Subdivision and Tribal Nations costs and expenses as set forth in subparagraph II.A.3.b.

Z. “Teva” means (i) Teva Pharmaceutical Industries Ltd. and (ii) all of its respective past and present direct or indirect parents, subsidiaries, divisions, affiliates, joint ventures, predecessors, successors, assigns, including but not limited to Teva Pharmaceuticals USA, Inc., the Actavis Generic Entities, and Anda Inc.

II. MDL Direct Cost Fund and Subdivision Cost and Expense Fund (“Cost Fund”) A. The total Cost Fund shall be $30 million dollars funded as set forth below.

1. Total cost to be paid by Teva in each of the relevant Payment Years2 under this Agreement shall be up to the following amounts, subject to the provisions set forth below:

Cost Fund

1 Nothing herein shall be understood to indicate approval for additional State Back -Stop Agreements or modifications of existing State Back-Stop Agreements.
2 Payment Year shall have the same meaning for Teva as set forth in the Teva Agreement and Teva Exhibits M -1 and M-3. Payment Year shall carry the same definition for Allergan as set forth in the Allergan Agreement and Allergan Exhibits M-1 and M-2.

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Payment
Year 1 $9,000,000.00
Payment
Year 2 $9,000,000.00

2. Total cost to be paid by Allergan in each of the relevant Payment Years under this Agreement shall be up to the following amounts, subject to the provisions set forth below:

Cost Fund
Payment
Year 1 $6,000,000.00
Payment
Year 2 $6,000,000.00

3. The Cost Fund shall be split into the MDL Direct Cost Fund and the Subdivision Cost and Expense Fund.
a. The MDL Direct Cost Fund shall be Seven Million Five Hundred Thousand Dollars ($7,500,000), payable 50% in Year One, and 50% in Year Two. The MDL Direct Cost Fund shall make payment without any delay to reimburse the MDL PEC for an agreed-to portion of the expenses incurred, provided the costs have been approved by the Cost and Expense Fund Administrator appointed by the Court. The MDL Direct Cost Fund will be paid directly to the MDL Opiate Capital Account. The Cost and Expense Fund Administrator may include costs incurred by the MDL PEC in furtherance of litigation, mediation, implementation, and management of the Settlements.
b. The Subdivision Cost and Expense Fund shall be Twenty-Two Million Five Hundred Thousand Dollars ($22,500,000), payable 50% in Year One and 50% in Year Two.
c. It is the intention of the Parties that the Cost Fund shall be administered by the Cost Fund and Expense Fund Administrator (MDL Docket No. 3828), who will be governed by the provisions of this Agreement and shall design the process and procedures for the allocation of costs pursuant to this Agreement and the MDL Court’s Order.
d. The costs of the Cost and Expense Fund Administrator shall be paid from the Cost Fund and allocated by the Cost and Expense Fund Administrator between the MDL Direct Cost Fund and the

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Subdivision Cost and Expense Fund to fairly charge each fund the cost incurred in implementing and supervising the specific fund. e. The Cost and Expense Fund Administrator shall set the process and procedures for submission of and criteria for applications for payment of Subdivisions’ and Tribal Nations’ costs and expenses.

The Cost and Expense Fund Administrator shall receive and evaluate applications from Participating Litigating Subdivisions and litigating Tribal Nations, whether filed in Federal Court or State Court, to seek reimbursement for eligible costs in pursuit of claims against Allergan or Teva. The process shall require a showing that the costs or expenses sought were reasonably incurred in furtherance of active litigation of a designated state or federal bellwether trial- set case, or Common Benefit. The Cost and Expense Fund Administrator shall require transparency from all applicants as to any other sources for compensating Attorneys for Subdivisions and Tribal Nations for costs incurred. If funds remain after the reimbursement of approved out-of-pocket costs, the Cost and Expense Fund Administrator may consider reasonable and
appropriate payment for client time, costs, or expenses incurred by recognized trial bellwether plaintiffs. At the conclusion of the process, any funds not allocated by the Cost and Expense Fund Administrator shall be transferred to the Common Benefit Fund established in this Exhibit R.

4. In the event that States and Subdivisions enter into an additional global settlement with a party or parties other than Teva or Allergan that is (a) under the jurisdiction of the MDL Court in MDL No. 2804, (b) creates a separate cost fund, and (c) unless the parties agree to another date, such agreement has an effective date prior to June 30, 2023, the Cost and Expense Fund Administrator shall have the authority to aggregate the Cost Fund with the cost fund created under that global settlement agreement. The Cost and Expense Fund Administrator shall have the authority to address the appropriate procedures and required information to allow the costs to be funded from the appropriate cost fund or shared by two or more cost funds.

III. Attorney Fee Fund
A. An Attorney Fee Fund shall be paid in the following amounts and years:

Teva Shall Pay Allergan Shall Pay
Payment
Year 1 $ 46,215,837.93 $ 40,778,855.53
Payment
Year 2 $ 46,215,837.93 $ 40,778,855.53
Payment
Year 3 $ 55,215,837.92 $ 46,778,855.53

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Payment
Year 4 $ 55,215,837.92 $ 46,778,855.53
Payment
Year 5 $ 55,215,837.92 $ 0.00
Payment
Year 6 $ 55,215,837.92 $ 0.00

B. The Attorney Fee Fund shall consist of the Contingency Fee Fund and the Common Benefit Fund.

2. It is the intention of the Parties that the Contingency Fee Fund and the Common Benefit Fund shall be administered by the Fee Panel (MDL Docket No. 3828), which will be governed by the provisions of this Fee Agreement and shall design the process and procedures for the allocation of fees pursuant to this Fee Agreement and the MDL Court’s Order.

C. The fees to be paid under this Fee Agreement are available for Attorneys engaged in Qualifying Representations and Qualified Tribal Representations only. Fees to be paid under this Fee Agreement are not available prior to the Effective Date of the Teva Agreement and Allergan Agreement or if the Teva Agreement does not proceed past Teva’s determination in subsection XI.A of the Teva Agreement or if the Allergan Agreement does not proceed past Allergan’s determination in subsection X.A of the Allergan Agreement. Fees to be paid under this Fee Agreement are not available for representation of States, Non-Participating Subdivisions or Non-Litigating Subdivisions and are not available for representation of private hospitals, third-party payors, NAS claimants, personal injury/wrongful death claimants, or any entity other than Participating Litigating Subdivisions. In addition, fees under this Fee Agreement are not available for representation of any individual or entity in matters other than those claims against Released Entities, but may include a reasonable share of representations that involve development of facts for pursuit of opioid-related claims against multiple defendants in the pharmacy, manufacturing, and distribution chain.

D. Attorney Fee Fund and Sub Funds.

1. There shall be a split of the Attorney Fee Fund into the Contingency Fee Fund and the Common Benefit Fund. The split shall be 40% to the Contingency Fee Fund and 60% to the Common Benefit Fund.

2. In no event shall Teva or Allergan be required to pay more into the Attorney Fee Fund in any Payment Year than the maximum amount specified for that Payment Year in subsection III.A., which amounts are reflected in Exhibit M to the Teva Agreement and Allergan Agreement. The amounts allocated to the Contingency Fee Fund and the Common Benefit Fund set by the Fee Panel shall be subject to the reductions and offsets set forth below.

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3. Awards of fees from the Contingency Fee Fund shall be available to Attorneys with Qualifying Representations of Participating Litigating Subdivisions eligible to receive an allocation under the Teva Agreement and Allergan Agreement, as set forth in Exhibits F-2 and G to the Teva Agreement and Exhibits F and G to the Allergan Agreement, and shall be made applying the Mathematical Model attached as Exhibit “A” to this Fee Agreement. The collection of the data and calculations for the Mathematical Model has been a cooperative effort among private counsel for a large number of Litigating Subdivisions. The analysis has been spearheaded by Joseph Tann and Andrew Arnold. The Fee Panel is encouraged to continue working with those counsel in application of the Model. The Fee Panel shall oversee the application of the Model and resolve any questions or disputes concerning the eligibility of a Counsel to participate as required in subsection III.G. The Panel is empowered to hear disputes concerning and ensure the accuracy of the mathematical calculation.

4. As to awards from the Contingency Fee Fund, there shall be no right of appeal.

5. Any appeal of an award of the Fee Panel from the Common Benefit Fund will be made to the MDL Court and be reviewed under an abuse of discretion standard.

E. Common Benefit Fund (60% of the Attorney Fee Fund).

1. Funds in the Attorney Fee Fund shall be allocated to the Common Benefit Fund according to the schedule set forth below, subject to the adjustments described in paragraph III.E.6. The payments are to be made on the following yearly schedule, subject to the adjustments set forth below:

Teva Shall Pay Allergan Shall Pay
Payment
Year 1 $ 27,729,502.76 $ 24,467,313.32
Payment
Year 2 $ 27,729,502.76 $ 24,467,313.32
Payment
Year 3 $ 33,129,502.75 $ 28,067,313.32
Payment
Year 4 $ 33,129,502.75 $ 28,067,313.32
Payment
Year 5 $ 33,129,502.75 $ 0.00
Payment
Year 6 $ 33,129,502.75 $ 0.00

2. The Common Benefit Fund shall be available to compensate Attorneys engaged in Qualifying Representations of Participating Litigating

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Subdivisions and Qualified Tribal Representation of Tribal Participating Governments who:
a. have performed work for the Common Benefit of all Participating Subdivisions and/or Tribal Nations consistent with the provisions to the guidelines established by Judge Polster set forth in MDL 2804 and the May 1, 2018 Order, under docket number 358, which is incorporated herein by reference; and
b. satisfy the eligibility criteria set forth in subsection III.G.

3. For purposes of Common Benefit Fund distribution, Attorneys representing Tribal Nations litigating against Teva or Allergan have also reached a settlement for Released Claims with Teva and Allergan. These settlements shall be the subject of separate agreements with Teva and Allergan.

Attorneys representing Tribal Nations are eligible for Common Benefit consideration, provided such agreements with Teva and Allergan become effective under their terms. Such Attorneys must meet the eligibility criteria in subsection III.G.

4. For purposes of Common Benefit Fund distribution, MDL Participating Counsel not engaged in Qualifying Representations of Participating Litigating Subdivisions but who performed work for the Common Benefit pursuant to authorization from the MDL Co-Leads and meet the eligibility criteria in subsection III.G shall be eligible.

5. The Common Benefit Fund shall be overseen by the Fee Panel, which shall determine the allocation of funds to eligible Attorneys consistent with this Fee Agreement and the May 1, 2018 Order.

6. In assessing the benefits that an Applicant has conferred to Participating Subdivisions (including non-Litigating Subdivisions) and/or Tribes for purposes of any compensation decision, the Fee Panel shall give significant weight to the extent to which (i) the Applicant and his or her clients have contributed to increasing (or reducing) the Initial Participation in the Teva Agreement or the Allergan Agreement, and (ii) the Applicant and his or her clients have contributed to increasing (or reducing) the amounts achieved under Incentive Payments A-D through participation in the Teva Agreement, including the Teva Tribal Agreement, or the Allergan Agreement, including the Allergan Tribal Agreement. The Fee Panel shall also consider additional fee recoveries the Applicant may potentially obtain, including, but not limited to, from attorney fee funds under other settlement agreements, State Back-Stop Agreements, representations of States or Tribal Nations, representations of other clients in opioids-related matters, or through the representation of Subdivision clients, whether they participated in the Teva Agreement or Allergan Agreement or not. It is the intent of this provision to recognize that the goal of the Teva Agreement

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and Allergan Agreement is to provide for maximum participation by the Subdivisions, maximum abatement funding for all Subdivisions nationally, and the maximum peace for Released Entities. Therefore, representing one or more Non-Participating States or Non-Participating Subdivisions does not further the goal of the Teva Agreement or Allergan Agreement, and should not be considered Common Benefit because it does not increase funds available to Participating Subdivisions’ abatement programs.

Representing one or more Later Litigating States or Later Litigating Subdivisions is antithetical to the Teva Settlement and the Allergan Agreement and detracts from Common Benefit. The Fee Panel shall consider this concept of “common detriment” set forth in this paragraph in all of its decision making with respect to the allocation of the Attorney Fee Fund among Applicants, as well as, in its discretion, any offsets provided to Teva or Allergan as set forth in subsection III.H. The Fee Panel shall consider the totality of the Applicant’s Participating Litigating Subdivisions as compared to the Applicant’s Non-Participating Litigating Subdivisions; the Parties recognize that, although the goal is for 100% participation, Applicants with a greater number of clients have a greater probability of having one or more Non-Participating Litigating Subdivisions. As used in this paragraph, “client” or “representing” a Subdivision shall include any Litigating Subdivision as to which the Applicant has a Fee Entitlement.

7. As set forth in subsection III.H, the Fee Panel must consider the factors described in paragraph III.E.6 to determine how and whether to reduce the amounts to be paid by Teva or Allergan under this Fee Agreement and to determine how to allocate funds among Applicants. They may also, at their discretion, consider other factors. Any reduction in payment obligation or credit to be given Teva or Allergan in this Fee Agreement shall be applied against the last Payment Year for that defendant and working backwards.

Any reduction to an Applicant not credited to Teva or Allergan shall be allocated to attorneys whose Litigating Subdivision clients participated in the settlement by the Initial Participation Date.

8. The MDL PEC will seek, and the Attorneys General for Settling States, Teva, and Allergan, will not oppose, a Common Benefit Fee Order requiring an assessment of 7.5% on the gross recovery (by judgment or settlement) of any Non-Participating Subdivision that is subject to the federal court jurisdiction, represented by a MDL PEC firm, represented by any Attorney receiving fees from the Common Benefit Fund, represented by any Attorney that signed a Participation Agreement or paid in a case otherwise under the jurisdiction of the MDL Court.

9. If Teva and Allergan agree to go forward with their respective Agreements under subsections [XI.A and X.A] of their respective Agreements, they shall pay the full Common Benefit (60%) Fee into the Common Benefit Fund without regard to the number of Settling States or Participating Subdivisions. Should Teva and/or Allergan pay a judgment to, or settle

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with, a Non-Participating State or a Non-Participating Litigating Subdivision subsequent to the Reference Date, and such settlement or judgment results in a common benefit fee assessment paid into the Common Benefit Fund or the Court Common Benefit Fund, the following shall apply:
a. Teva or Allergan shall be credited dollar-for-dollar for the amount paid for the fee assessment up to 7.5% of the abatement amount derived from the application of the State Global Allocation Percentage as set forth in Exhibit F-1 or the abatement amount derived from the application of the Subdivision and Special District Allocation Percentage as set forth in Exhibit G that the Non- Participating State or Non-Participating Litigating Subdivision would have received if it had participated in the Settlement Agreement;
b. Except as set forth below in subparagraph III.E.9.c, for any settlement or judgment that meets the requirements of paragraph III.E.9 that exceeds the abatement amount derived from the application of the State Global Allocation Percentage as set forth in Exhibit F-1 or the abatement amount derived from the application of the Subdivision and Special District Allocation Percentage as set forth in Exhibit G, no credits shall be taken against Teva or Allergan’s obligation to make payments into the Common Benefit Fund for that portion of the settlement or judgment in excess of the abatement amount derived from the application of the State Global Allocation Percentage as set forth in Exhibit F-1 or the abatement amount derived from the application of the Subdivision and Special District Allocation Percentage as set forth in Exhibit G; c. For any settlement or judgment that meets the requirements of paragraph III.E.9 that exceeds the abatement amount derived from the application of the State Global Allocation Percentage as set forth in Exhibit F-1 or the abatement amount derived from the application of the Subdivision and Special District Allocation Percentage as set forth in Exhibit G that the Later Litigating State or Later Litigating Subdivision would have received if it had participated in the Settlement Agreement, where the Later Litigating State or Later Litigating Subdivision is represented by any member of the MDL PEC or that member’s law firm, Teva or Allergan shall be credited dollar-for-dollar for the full amount of the 7.5% common benefit fee assessment paid into the Common Benefit Fund or the Court Common Benefit Fund;
d. If a credit is made to Allergan or Teva pursuant to subparagraph III.E.9.c., then that amount shall be calculated as a direct reduction to any common benefit fee award made under this Fee Agreement

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to the MDL PEC firm(s) that represented the Later Litigating State or Later Litigating Subdivision;
e. Any credits shall be taken first against Teva’s or Allergan’s payment to the Common Benefit Fund in Teva’s or Allergan’s respective final Payment Year as set forth in paragraph III.E.1 (for Teva Year 6; for Allergan Year 4), up to the full amount of Teva’s or Allergan’s final year payment obligation, then from the next-to-final Payment Year’s payment obligation, and so on;
f. Teva and Allergan shall not be entitled to any credits against the Common Benefit Fund for settlements or judgments paid after Teva’s or Allergan’s final fee Payment Year.

F. Contingency Fee Fund (40% of the Attorney Fee Fund).

1. Funds from the Attorney Fee Fund shall be allocated to the Contingency Fee Fund on the following yearly schedule, subject to the adjustments set forth below:

Teva Shall Pay Allergan Shall Pay
Payment
Year 1 $ 18,486,335.17 $ 16,311,542.21
Payment
Year 2 $ 18,486,335.17 $ 16,311,542.21
Payment
Year 3 $ 22,086,335.17 $ 18,711,542.21
Payment
Year 4 $ 22,086,335.17 $ 18,711,542.21
Payment
Year 5 $ 22,086,335.17 $ 0.00
Payment
Year 6 $ 22,086,335.17 $ 0.00

2. The Contingency Fee Fund shall be available to compensate Attorneys engaged in Qualifying Representations of Participating Litigating Subdivisions that meet the criteria set forth in subsection III.G. a. The Contingency Fee Fund shall be available to Attorneys who represent Litigating Subdivisions that are Participating Subdivisions, whether their actions are filed in state or federal court, and meet the eligibility criteria of subsection III.G.
b. Participation in the Contingency Fee Fund by counsel that have a case that is not subject to the jurisdiction of the MDL Court shall not create, provide, or waive jurisdiction of the MDL Court over that Litigating Subdivision, that case or Attorneys, other than to oversee

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the fairness of the distribution process, and enforcement of this Fee Agreement.
c. Under the terms of the Teva Agreement and Allergan Agreement Litigating Subdivisions must become a Participating Litigating Subdivision under both Agreements to be eligible to participate.

Therefore, Exhibit R applies jointly to Teva and Allergan with the Attorneys’ Fee Fund and MDL Cost Fund to include the combined payment from Teva and Allergan.

3. Teva and/or Allergan shall each be entitled to a pro-rata reduction to their own portion of the Contingency Fee Fund payment(s) in accordance with subsection III.F.4., unless, by the Payment Date for the Initial Year Payment, (i) 41 states are Settling States for Teva or 43 states are Settling States for Allergan, (ii) 98% of all Litigating Subdivisions are Participating Subdivisions and/or Subdivisions Subject to a Bar, Case-Specific Resolution, and, (iii) 97% of all Non-Litigating Subdivisions with Populations over 10,000 as listed in Exhibit I are Participating Subdivisions and/or Subdivisions Subject to a Bar, Case-Specific Resolution, in which case no offset shall be applied.

4. If the participation conditions in paragraph III.F.3 are not met, then the amounts owed by Teva and/or Allergan to the Contingency Fee Fund shall be reduced as follows:
a. For Non-Settling States, the Contingency Fee Fund payments shall first be reduced by the amounts identified by the Fee Panel, pursuant to paragraph III.H.7, that would have been owed to counsel for Litigating Subdivisions in Non-Settling States, had those States and those Litigating Subdivisions been Settling States and Participating Subdivisions.
b. Following the calculation in subparagraph III.F.4.a., the Contingency Fee Fund payments shall be reduced to reflect the non- joinder of Litigating Subdivisions in Settling States by subtracting the amounts identified by the Fee Panel, pursuant to paragraph III.H.7, that would have been owed to counsel for Non-Participating Litigating Subdivisions in Settling States had such Litigating Subdivisions been Participating Subdivisions.

5. In the event that after the date of the Settlement Agreement Teva, prior to the Effective Date of the Teva Agreement, or Allergan, prior to the Effective Date of the Allergan Agreement, settles with any Litigating Subdivision that would have been eligible to participate in the defendant’s Agreement, and, under such settlement agreement pays attorneys’ fees, the Fee Panel shall treat those Litigating Subdivisions as Participating Litigating Subdivisions and, applying the same criteria applicable to all Attorneys for Participating

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Litigating Subdivisions, determine what amount they would have been paid from the Contingency Fee Fund if they had become Participating Subdivisions under the Teva Agreement or the Allergan Agreement without such prior settlement. That sum, rather than being paid to the Attorney for the previously settling Litigating Subdivision, shall be credited and/or returned to Teva or Allergan as if determined under (a)(ii) above, except that such credit shall not be greater than the amount paid to the Attorneys under the Litigating Subdivision’s prior settlement agreement and credits apply equally over the Fee Payment Years.

6. During the period between the Preliminary Agreement Date and the Effective Date, the MDL PEC, as well as Litigating Subdivisions’ Attorneys, shall make best efforts to cease litigation activity against Teva and Allergan, including by jointly seeking stays or severance of claims against Teva and Allergan, where feasible, or postponements if a motion to stay or sever is not feasible or is denied, so long as such actions are not otherwise detrimental to the Litigating Subdivision.

G. Eligibility.

1. It is the intention of all parties participating in the Fee Panel process that there should be total transparency to the Fee Panel and to all fund participants. In connection with the process to be developed by the Fee Panel, any and all monies in attorney’s fees received or awarded, including prior or future Contingency Fees, Common Benefit Fees, referral fees, expenses paid, promises for payment, or any other Fee Entitlement, to any Applicant in any opioid litigation shall be disclosed to the Fee Panel as a condition of participating in the Attorney Fee Fund and prior to an award from the Fee Panel. Any payment, expectation of payment or perceived entitlement to participate in a State Back-Stop Agreement or any other agreement reached with a Settling State or any Subdivision or any other source regarding payment of fees must be disclosed to the Fee Panel.

Similarly, any right to payment from any other fund, for example a fund for payment to lawyers representing Settling States or Tribal Nations or Subdivisions shall be disclosed to the Fee Panel. Because it is anticipated that there will be multiple firms listed on contingent fee agreements with Litigating Subdivisions, the Fee Panel shall establish procedures, with input from Attorneys for Participating Litigating Subdivisions, for who should petition for fees from such groups and to whom the fee shall be paid and thereafter distributed to co-counsel in accordance with applicable agreements. For the avoidance of doubt, all Attorneys that are part of such groups must meet the eligibility criteria in paragraph III.G.3, must be subject to the criteria set forth in subsection III.C, and must be disclosed to the Fee Panel.

2. An Applicant may apply for and recover attorneys’ fees from the Common Benefit Fund, the Contingency Fee Fund, and any fund created by a past or

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future State Back-Stop Agreement, provided the Applicant satisfies the requirements relevant to each such fund and requirements for disclosure to the Fee Panel.

3. An Attorney may not receive any payment from the Attorney Fee Fund (which includes both the Contingency Fee Fund and the Common Benefit Fund) unless the following eligibility criteria are met and annually certified by the Attorney:
a. The Attorney must expressly waive the enforcement against the Litigating Subdivision client of all Fee Entitlements (other than under State Back-Stop Agreements) arising out of or related to any or all Qualifying Representations of any Participating Litigating Subdivision prior to applying for attorneys’ fees from the Attorney Fee Fund. All applications for attorneys’ fees under this Fee Agreement shall include an affirmation by the Attorney of such waiver and notice to the client(s) of such waiver. Such waiver shall not preclude the Attorney from submitting such Fee Entitlements to the Fee Panel as a factor for consideration in allocating payments from the Attorney Fee Fund or in connection with a State Back-Stop Agreement. For the avoidance of doubt, no Attorney may recover fees under this Fee Agreement unless the Attorney expressly agrees not to enforce Fee Entitlements as to each and every Participating Litigating Subdivision represented by that Attorney, but such Attorneys may participate in and receive funds from a State Back- Stop Agreement.
b. The Attorney must represent that s/he has no present intent to represent or participate in the representation of any Later Litigating Subdivision or Later Litigating State with respect to Released Claims against Released Entities.
c. The Attorney must represent that s/he has not and will not engage in any advertising or solicitation related to Released Claims against Released Entities where such advertising or solicitation relates to a representation of a Subdivision eligible to be a Participating Subdivision after the Reference Date unless the Attorney is recommending participation in the Agreement.
d. The Attorney must represent s/he will not charge or accept any referral fees for any Released Claims brought against Released Entities by Later Litigating Subdivisions or Later Litigating States.

This representation shall not prohibit Attorneys from receiving allocated shares of any future common benefit assessments arising out of settlements or judgments with Later Litigating Subdivisions or Later Litigating States that are the result of the MDL Court’s Common Benefit order.

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e. The Attorney may not have and must represent that s/he does not have a Fee Entitlement related to a Later Litigating Subdivision or Later Litigating State, other than a potential Common Benefit Fee. f. The Attorney must fully disclose the participation, or the anticipation of participation, in any agreement with a Settling State or Participating Subdivision concerning fees arising out of or related to the Teva Agreement or Allergan Agreement, including any fees paid or anticipated to be paid or any State Back-Stop Agreement. g. The Attorney must identify for the Fee Panel whether s/he utilized state litigation work product or MDL work product, including but not limited to ARCOS data, document repositories, experts developed in the MDL, trial transcripts, or deposition transcripts.

The Attorney must identify whether s/he signed the MDL
Participation Agreement.
h. Any Attorney who applies for fees from one or both Funds must represent that, having exercised his/her independent judgment, s/he believes the Teva Agreement and the Allergan Agreement to be fair and will make or has made best efforts to recommend both Agreements to his or her Subdivision clients in Settling States. For avoidance of doubt, each Attorney is expected to exercise his or her independent judgment in the best interest of each client individually before determining whether to recommend joining the settlement.

All applications for attorneys’ fees or costs under this subsection shall include an affirmation by the Attorney in compliance with the foregoing subparagraphs.

4. No Attorney receiving fees under this Fee Agreement may apply for or recover from the Attorney Fee Fund fees arising from representing a Non- Participating Subdivision except Common Benefit Fees as described in paragraph III.E.2. All applications for attorneys’ fees under this subsection shall include an affirmation by the Attorney of compliance with this paragraph.

5. An Attorney who has filed an application under this subsection and received an award of attorneys’ fees shall provide a certification of compliance with the requirements of this Fee Agreement annually during the years upon which they are still entitled to receive attorneys’ fee payments under this Agreement. This certification will be done as directed by the Panel.

6. If, at any time, the Attorney is unable to make the representations set forth in this subsection, such representations become untrue, or the Attorney falsely represents compliance with the eligibility criteria, the Attorney shall cease to be eligible to receive funds from the Attorney Fee Fund until further

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review by the Fee Panel of the Attorney’s eligibility under and compliance with this subsection.

7. If an Attorney has a Fee Entitlement with a Later Litigating Subdivision or Later Litigating State or otherwise becomes unable to reaffirm compliance with the eligibility criteria set forth above, the Attorney shall notify the Fee Panel. For the avoidance of doubt, any Attorney who undertakes any new representation of, or has a Fee Entitlement with, a Later Litigating Subdivision or Later Litigating State shall be prohibited from receiving any future funds from the Attorney Fee Fund. If an Attorney fails to notify the Fee Panel of such Fee Entitlement with a Later Litigating Subdivision or Later Litigating State, the Attorney shall be required to refund amounts previously paid. The Fee Panel shall notify Teva and Allergan when it receives notification.

8. To the extent an Attorney who has received compensation from the Attorney Fee Fund based on Qualifying Representations of Participating Litigating Subdivisions under the Teva Agreement or the Allergan Agreement, represents a Later Litigating Subdivision or Later Litigating State, such Attorney shall be obligated to refund such amounts received as compensation from the Attorney Fee Fund to Teva or Allergan. Teva, Allergan, or such Attorney may bring any dispute as to whether such Attorney shall be obligated to refund such amounts received from the Attorney Fee Fund to Allergan or Teva to the Fee Panel. Nothing herein shall require a multi-attorney law firm that has received compensation from the Attorney Fee Fund to refund such amounts if an attorney of the firm that is no longer affiliated with such law firm, after such departure, represents a Later Litigating Subdivision or Later Litigating State, provided that (a) neither the law firm nor any of its other attorneys have any contractual or financial arrangement regarding, stand to benefit directly or indirectly from, or directly or indirectly provide financial or other support of any kind to, the former attorney’s representation of the Later Litigating Subdivision or Later Litigating State and (b) if the former attorney was a partner or owner of the multi-attorney law firm at the time that the law firm received compensation from the Attorney Fee Fund, the former attorney shall be obligated to refund such amounts as the former attorney earned as a result of the compensation that the law firm received from the Attorney Fee Fund.

9. In the event that an Attorney is deemed ineligible by the Fee Panel (whether based on its initial application or subsequent recertification), the Fee Panel shall provide notice to the Attorney and give the Attorney 30 days to provide additional information such that the Fee Panel could re-consider the Attorney’s eligibility.

10. To the extent that an Attorney has a Fee Entitlement with a Participating Subdivision and is authorized to bring Released Claims against Released Entities, but such authorization is, in scope, less broad than the category of

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Released Claims set forth in the Teva Agreement or Allergan Agreement, such Attorney may participate fully in both the Contingency Fee Fund and the Common Benefit Fund, without any reduction imposed by the Fee Panel due to the scope of the authorization, so long as the Participating Subdivision fully releases all Released Claims against Released Entities.

11. Attorneys applying to the Attorney Fee Fund knowingly and expressly agree to be bound by the decisions of the Fee Panel, subject to the limited appeal rights set forth in this Fee Agreement, and waive the ability to assert the lack of enforceability of the allocation reached through the procedures outlined herein.

12. Applicants are under an ongoing obligation to inform the Fee Panel in writing of any additional fees earned, expected, or received related to any Opioid litigation throughout the period of the Fee Panel’s operation.

H. Calculation of Amounts Due.

1. The Fee Panel shall be solely responsible for determining the amount of fees to be paid to each Applicant. None of the Released Entities shall have any responsibility, obligation, or liability of any kind whatsoever with respect to how attorneys’ fees are calculated under this subsection, except that the Fee Panel may receive information from Teva or Allergan as to (a) the identity of Participating, Non-Participating, Litigating, Later Litigating, and Non-Litigating Subdivisions; (b) the impact of non-participation by a Litigating Subdivision as is relevant to the Fee Panel’s determination in paragraph III.E.6; and (c) such other information as Teva or Allergan may voluntarily elect to provide.

2. The Fee Panel shall establish procedures for making determinations under this Fee Agreement consistent with this Fee Agreement and orders of the MDL Court. Such procedures may include submission of documentary and/or other evidence, interviews with Applicants and/or other counsel (including counsel for Teva and Allergan) that the Fee Panel deems appropriate, and/or other means of creating a record upon which fee awards will be based.

3. In making determinations under this Fee Agreement, the Fee Panel must apply the eligibility criteria set forth in subsection III.G of this Fee Agreement and the criteria set forth in paragraph III.E.2. In addition, the Fee Panel will give consideration in regard to Common Benefit Fund awards to the Johnson factors, as well as the following factors (which factors may be applied and given relative weight in the Fee Panel’s discretion):
a. The Applicant’s contemporaneously recorded time and labor dedicated to Qualifying Representations along with the Applicant’s

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financial commitment to such Qualifying Representations. Claimed “time” will not be automatically accepted by the Fee Panel but will be critically reviewed and given substantially more weight and consideration if such time was subject to the audit process described in any Pretrial Order(s) governing the collection of common benefit time;
b. The novelty, time, and complexity of the Qualifying
Representations;
c. The skill requisite to perform legal services properly and undesirability of the case;
d. The preclusion of other employment by the Applicant due to time dedicated to Qualifying Representations;
e. The Common Benefit, if any, alleged to have been conferred by the Applicant and whether such Common Benefit work product by that Applicant was used by others in parallel litigations against Released Entities whether within or outside the MDL, provided that any Applicant claiming that s/he substantially benefited cases other than those in which s/he entered an appearance as counsel must substantiate such claims by proffering factual support, such as proper supporting affidavits or other documents as determined by the Fee Panel with input from Attorneys for Participating Litigating Subdivisions;
f. Any “common detriment,” as set forth in paragraph III.E.6. g. Any contingent fee agreement or other Fee Entitlement with Participating Subdivisions, enforcement of which, except for State Back-Stop Agreements, are waived in conjunction with the application, the nature and extent of any work for those Participating Subdivisions, whether such Participating Subdivisions actively litigated and, if so, the nature and procedural history of such case(s); h. The experience, reputation, and ability of the Applicant; i. Whether the Applicant’s clients brought Released Claims against Released Entities;
j. The status of discovery in cases primarily handled by the Applicant; k. The nature of any work by the Applicant on “bellwether” cases or cases that were similarly active in litigation;

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l. Any pressure points successfully asserted by the Applicant in cases against Teva or Allergan or any risk for Teva or Allergan created by the Applicant in cases against them;
m. Any risk for defendants created by Applicants in cases against Teva or Allergan;
n. Successful and unsuccessful motion practice in cases worked on by the Applicant;
o. The date of filing of any cases filed by the Applicant; p. Obtaining consolidation of the litigation in the Applicant’s jurisdiction;
q. The number and population of entities represented by the Applicant and the fees that would have been awarded under extinguished contingent fee arrangements;
r. Whether the Applicant’s clients brought claims against Teva or Allergan;
s. Whether the Applicant has had a leadership role in the litigation, whether in state or federal court;
t. Whether the Applicant has had a leadership role in any negotiations aimed at resolving the litigation;
u. Whether the Applicant’s cases have survived motions to dismiss; v. The extent to which the Applicant contributed to the work product used for the common benefit of opioids litigants, including, without limitation, work on ARCOS data, Prescription Data Monitoring Programs, IQVIA data, depositions, document production and analysis experts, motions, briefs and pleadings, trial preparations, and trials;
w. The extent to which litigation was done prior to and contributed to completion of settlement negotiations, as distinct from litigation that was done litigating after the announcement of the Teva Agreement or Allergan Agreement, such latter litigation both being of less value and potentially resulting a common detriment to the settlement process; and
x. Any other factors that the Fee Panel finds to be appropriate to consider after input from Applicants to the Attorney Fee Fund.

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4. In the event that States and Subdivisions enter into an additional global settlement with a party or parties other than Teva or Allergan that is (a) under the jurisdiction of the MDL Court in MDL No. 2804, (b) creates a separate common benefit fund to be administered by the Fee Panel, and (c) unless the parties agree to another date, such agreement has an effective date prior to June 30, 2023, the Fee Panel may:
a. Consolidate the Common Benefit approval process to include evaluation of all Common Benefit Applications for all settlements entered after November 14, 2022;
b. Determine the fair and equitable allocation of the Aggregate Common Benefit Fees that come after November 14, 2022;
c. Give consideration to the amount and timing of each settlement, including the amount and timing of Common Benefit Fees; d. The Fee Panel shall abide by the applicable Attorney Fee Agreement in each of the Settlements in Allocating the Common Benefit Fees provided for in the Settlement; and
e. Be guided in their work by the Orders of the Court related to Fees and Costs.

5. The Fee Panel shall develop procedures for receiving a single application, which may be updated or amended based on new information (such as participation by additional Litigating Subdivisions) from each Applicant seeking compensation from each sub fund of the Attorney Fee Fund pursuant to processes and procedures developed by the Fee Panel, which shall not be inconsistent with this Fee Agreement. Any request for attorneys’ fees not included on the single application or through the updating/amendment process designed by the Fee Panel shall be deemed waived. For purposes of transparency and to permit the Fee Panel to conduct its work, the application from each Applicant shall, at a minimum, require each Applicant to:
a. Identify all Litigating Subdivisions for which s/he is seeking payment from the Attorney Fee Fund;
b. Identify all Subdivisions in both Settling and Non-Settling States (and, where applicable, Tribal Nations) with respect to which s/he has a Fee Entitlement with respect to Relevant Claims against Released Entities, and identify all co-counsel in such cases; c. Identify which of those Subdivisions are Participating Subdivisions and which are not (with similar information for Tribal Nations, where applicable);

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d. Specify the specific fund or funds within the Attorney Fee Fund from which the Attorney is seeking compensation;
e. Demonstrate his or her eligibility for compensation from the relevant sub funds within the Attorney Fee Fund pursuant to the criteria set forth for the relevant sub fund;
f. Identify any and all Fee Entitlements from representations of States, Tribal Nations, or other plaintiffs related to Released Claims against Released Entities or in opioids-related matters;
g. Notwithstanding “a-f” above, the Panel may consider a supplemental application if the Applicant shows good cause why circumstances exist that will lead to consideration for additional Common Benefit award. Examples would include, but are not limited to, an Applicant having Non-Participating Litigating Subdivision clients that subsequently become Participating Subdivisions, a Bar Date passes that increases participation or the Participation Tier, or an Allocation Agreement is reached.

6. With respect to the Common Benefit Fund, the Fee Panel shall (subject to any applicable MDL Court Order):
a. Review the applications of all Applicants seeking compensation from the Common Benefit Fund, including determining eligibility for each Applicant as set forth in subsection III.G.
b. Reduce, on an annual basis, Teva’s or Allergan’s payment obligations, as set forth in paragraph III.E.7. The Panel shall inform Teva or Allergan, and the MDL PEC of all such amounts and adjust payment obligations accordingly.
c. Using criteria set forth in subsections III.E and III.H, allocate amounts from the Common Benefit Fund to eligible Applicants, including payment amounts for each Payment Year. In making such allocations, the Panel shall apply the principles set forth in paragraph III.E.6 and shall allocate any reduction in the payments specified in paragraph III.E.7 to the amounts paid to Applicants with a Common Benefit Fee Entitlement.

7. With respect to the Contingency Fee Fund, the Fee Panel shall:
a. Review the applications of all Attorneys seeking compensation from the Litigating Subdivision Fee Fund, including determining eligibility for each Attorney as set forth in subsection III.G. b. Apply the Mathematical Model in Exhibit A to this Fee Agreement.

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c. Use such allocations to reduce on an annual basis the payment obligations of Teva or Allergan to the Attorney Fee Fund as set forth in paragraph III.F.4, and distributions therefrom, and inform Teva or Allergan and the MDL PEC of all such adjustments.

8. To the extent that there is a dispute about the calculations of the Fee Panel related to the amounts that Teva or Allergan is required to pay (including application of any reductions or offsets under this Fee Agreement), such disputes shall be presented to the Fee Panel and any disputed funds be paid into/held in escrow. The Fee Panel shall resolve such disputes expeditiously, with either Party having the right to seek review from the MDL Court.

9. For purposes of determination of fee or cost awards, allocations, reductions, and possible reversions under this Fee Agreement, unless specified otherwise a Subdivision will be considered a Non-Participating Subdivision if it is not a Participating Subdivision as of the deadline for the application for the fee at issue (or, if the determination does not involve a specific application, the date on which the record for such determination closes).

10. In the event that the Fee Panel, through the use of the Mathematical Model set forth in Exhibit A, allocates funds from the Contingency Fee Fund for an Attorney based on a Qualifying Representation of a Participating Litigating Subdivision and that Subdivision is in a Settling State in which the Consent Judgment has not been approved, such funds shall be placed into escrow until the Consent Judgment is approved, after which time they shall be released.

I. Miscellaneous.

1. The Fee Panel shall charge an hourly rate approved by the Court. The Pre- Effective Date costs associated with the Cost and Expense Fund Administrator shall be paid from funds in the Cost Fund. Post-Effective Date, the cost of the Fee Panel shall be charged against the applicable Fee Fund based on allocation by the Fee Panel and shall not be otherwise funded by Teva and Allergan.

2. The MDL PEC shall provide to Teva and Allergan information they have that identifies Attorneys who represent Litigating Subdivisions who are not Participating Subdivisions and who have an obligation to pay a common benefit assessment, either due to the MDL Court’s orders or pursuant to a Participation Agreement.

3. Participating Subdivisions agree to instruct their counsel to treat information, work product and expert materials as confidential under Rule

1.6 of the ABA Model Rules of Professional Conduct. Accordingly, an Attorney shall not share information or work product with, or experts or

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materials to, non-participants (other than the Attorney’s own current clients or their lawyers, consultants, experts or other representatives or agents).

However, nothing herein shall prevent MDL Leadership or PEC Counsel from fulfilling their obligations in any MDL and the MDL Court Order.

IV. Miscellaneous
A. Termination. If the Teva Agreement or Allergan Agreement does not proceed past the Reference Date, whether because Teva and Allergan do not determine to proceed or for any other reason, this Fee Agreement shall be null and void, neither Teva nor Allergan shall have any obligation to make any payments under this Fee Agreement other than Fee Panel costs advanced, and Teva, Allergan, and the PEC shall take such steps as are necessary to restore the status quo ante.

B. MDL Court Consideration. This Fee Agreement shall be attached as an exhibit to the Teva Agreement and Allergan Agreement. This Fee Agreement shall also be submitted by Teva, Allergan, and the MDL PEC to the MDL Court for approval pursuant to the motion and order that shall be attached, prior to the Preliminary Agreement Date of the Agreements, as Exhibit B.

1. In the event that the MDL Court, through an order, makes any change to the amounts potentially to be paid by Teva and Allergan under this Fee Agreement, makes any change to the Fee Panel’s consideration of the factors set forth in paragraph III.E.6, or any other material change to the draft Order attached as part of Exhibit B or the terms of this Fee Agreement, Teva, Allergan, and the MDL PEC shall meet and confer concerning such changes.

2. If Teva, Allergan, and the MDL PEC are unable to reach agreement and revisions to this Fee Agreement, this Fee Agreement shall be null and void, Teva and Allergan shall have no obligation to make any payments under this Fee Agreement, and Teva, Allergan, and the MDL PEC shall take such steps as are necessary to restore the status quo ante.

C. Amendment. Once the MDL Court has entered an order implementing this Fee Agreement, this Fee Agreement can only be amended by (1) written agreement of Teva, Allergan, and the MDL PEC and (2) approval by the MDL Court.

D. Jurisdiction and Enforcement. The MDL Court shall have exclusive and ongoing jurisdiction over the enforcement and implementation of this Fee Agreement as set forth herein. The MDL PEC shall be the Authorized Party to enforce this Fee Agreement, as to the payment obligations of Teva and Allergan as set forth in this subsection and as to Attorneys making application to the Funds under this Fee Agreement. Solely for purposes of assessing or allocating common benefit fees, the MDL Court will continue to have jurisdiction over the work product developed in the MDL Court by and under the direction of the MDL PEC with respect to claims against Teva or Allergan, including data and documents, depositions, expert

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reports, briefs and pleadings; and the MDL Court’s protective orders, management orders, and other decisions regarding such discovery and other work product, including but not limited to, conditions on its use, will continue in full force and effect. Nothing in this subsection authorizes the MDL Court to act contrary to this Agreement or provides the MDL Court with jurisdiction over the Teva Agreement or Allergan Agreement.

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EXHIBIT S
Agreement on the State Outside Counsel Fee Fund for Manufacturer Settlements

1. Definitions.

a. “Manufacturer” means any of Teva and Allergan, and “Manufacturers” means all of the foregoing.
b. “Multistate Manufacturer Settlement Agreement” means This Settlement Agreement along with the separate settlement of opioids-related claims among 30 or more states and the other Manufacturer.
c. “This Settlement Agreement” means the settlement agreement between the Settling States and the Manufacturer to which this Agreement is attached as an Exhibit.
d. “Settling Manufacturer” means the Manufacturer that is a party to This Settlement Agreement.
e. “Settling States” has the meaning given such term in the relevant Multistate Manufacturer Settlement Agreement.

2. Creation of a State Outside Counsel Manufacturers Fee Fund. The Settling States have agreed to the creation of a state outside counsel fee fund to pay reasonable attorneys’ fees of Settling States which have retained outside counsel in connection with litigation against one or more Manufacturers (such fund, the “State Outside Counsel Manufacturers Fee Fund”).

3. State Outside Counsel Manufacturers Fee Fund Administration. The State Outside Counsel Manufacturers Fee Fund shall be administered separately from any other funds for the payment of attorney’s fees or costs in connection with This Settlement Agreement, including any common benefit fund, contingency fee fund for subdivision counsel, state cost fund, or MDL expense fund. If necessary, a committee of Attorneys General shall be convened to oversee the State Outside Counsel Manufacturers Fee Fund (the “Manufacturers Fee Fund Committee”). The Manufacturers Fee Fund Committee shall be appointed by the Settling State Members of the Enforcement Committee and shall be comprised solely of Attorneys General of Settling States that engaged outside counsel to pursue litigation against one or more Manufacturers. The Settlement Fund Administrator (the “Fee Fund Administrator”) shall administer the State Outside Counsel Manufacturers Fee Fund according to this Exhibit and, if convened, the guidelines and directives of the Manufacturers Fee Fund Committee.

4. State Outside Counsel Manufacturers Fee Eligibility.

a. To receive any amount from the State Outside Counsel Manufacturers Fee Fund, both of the following must be true:

1. an outside counsel to a Settling State must have filed and maintained an action in the name of a Settling State or its Attorney General against a Manufacturer in a state or federal court as of November 1, 2022; and

2. the State must become a Settling State for each Multistate Manufacturer Settlement Agreement for which it is eligible.

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b. No Settling State (or its outside counsel) shall receive funds from both the State Outside Counsel Manufacturers Fee Fund and any “Additional Restitution Amount” as may be provided for in This Settlement Agreement. c. In addition to the eligibility criteria set forth in Paragraph 4.a, above, and for the avoidance of doubt, only Settling States under This Settlement Agreement are eligible to receive any funds paid into the State Outside Counsel Manufacturers Fee Fund as a result of This Settlement Agreement.

5. State Outside Counsel Manufacturers Fee Fund Amount. The Settling Manufacturer shall pay funds into the State Outside Counsel Manufacturers Fee Fund in an amount equal to, and on the schedule identified in, Exhibit M (the “Contribution”). The Settling Manufacturer’s Contribution shall be subject to a reduction as described in Paragraph 8, below.

6. State Outside Counsel Manufacturers Fee Fund Availability and Calculation of Amount.

a. The State Outside Counsel Manufacturers Fee Fund shall be available to compensate private outside counsel for Settling State Attorneys General for approved fees arising out of representation of the Settling State pursuant to the schedule attached to this agreement as Schedule I (the “Fee Schedule”). b. The Fee Schedule is intended to reflect the fee calculation in subparagraphs

6.c and d, below (the “Fee Calculation”). Subject to adjustments required by Paragraph 8, below, in the event of any discrepancy between the Fee Schedule and the Fee Calculation, the Fee Schedule shall control. Each Settling State, by becoming a Participating State in This Settlement Agreement, agrees that the Fee Schedule reflects the Fee Calculation and waives any right to contest the accuracy of the Fee Schedule, absent manifest error, the exclusion of a Settling State, or the inclusion of a Non-Settling State. The version of the Fee Schedule reflecting any necessary adjustments shall be the “Final Fee Schedule.”
c. Except as provided in Paragraph d, below, fees shall be aggregated across the Multistate Manufacturer Settlement Agreements and be calculated by adding two components: (a) a fixed amount consisting of fifty percent (50%) of the amount of remediation funds allocated to a Settling State and its Subdivisions pursuant to the Multistate Manufacturer Settlement Agreements multiplied by 4.5% (or, if lower, the applicable contingency fee percentage in the Settling State’s outside counsel contract); and (b) a proportional percentage of the remaining fee due under that Settling State’s contract with its outside counsel assuming that fifty percent (50%) of the Settling State’s recovery is allocable to a Settling State (rather than allocable to the Settling State’s Participating Subdivisions) so that the fees of all eligible Settling States (minus the fixed amount that would have been allocated to any Non-Settling States had they become Settling States) exhausts the State Outside Counsel Manufacturers Fee Fund. The proportional share percentage will be the same for each Settling State

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included in the State Outside Counsel Manufacturers Fee Fund. Except as set forth in Paragraph 6.c, fees shall be split proportionally among each Multistate Manufacturer Settlement Agreement, as set forth on the Fee Schedule.
d. Notwithstanding the foregoing, fees for the State of Oklahoma, if it becomes a Settling State under the Multistate Manufacturer Settlement Agreement with Allergan, shall be limited to Oklahoma’s share of the State Outside Counsel Manufacturers Fee Fund derived from Allergan’s Contribution.

Oklahoma’s share of the State Outside Counsel Manufacturers Fee Fund derived from Teva’s Contribution shall be reallocated proportionally among the other Settling States eligible to receive payments from the State Outside Counsel Manufacturer Fee Fund.
e. All amounts paid will be less the following:

1. Any costs or fees of the Fee Fund Administrator. The Fee Schedule reflects a holdback amount of $50,000 for such administrative expenses of the Fee Fund Administrator, the remainder of which shall be disbursed proportionally to States receiving monies from the State Outside Counsel Manufacturers Fee Fund at the conclusion of such administration.

7. Payment by the Fee Fund Administrator.

a. The Fee Fund Administrator shall hold the Contribution in escrow until the earlier of (1) both Multistate Manufacturer Settlement Agreements become effective or (2) when instructed by the Settling State Members of the Enforcement Committee.
b. Subject to eligibility pursuant to Paragraph 4, above, a Settling State’s outside counsel may receive funds from the State Outside Counsel Manufacturers Fee Fund in the following scenarios (“Payment Scenarios”):

1. The Settling State’s outside counsel agrees that the amount listed for such state on the Final Fee Schedule either satisfies in full or exceeds the amounts owed to all such Settling State’s outside counsel and such counsel has provided written notice waiving all entitlement to additional fee in respect of any Multistate Manufacturer Settlement Agreement.

2. The Settling State and its outside counsel enter into a signed writing establishing the amount owed to the counsel, which includes an agreement on the payment of the amount listed for such state on the Final Fee Schedule and waives any right of the State or its outside counsel to additional amounts from the State Outside Counsel Manufacturers Fee Fund.

3. A final judgment is entered that is no longer appealable, which judgement adjudicates the amount owed to the Settling State’s counsel in respect of This Settlement Agreement and directs the Manufacturers Fee Fund Committee how to pay the amount listed on the Final Fee Schedule for such State.

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If no Payment Scenario is applicable with respect to a Settling State, then the Settling State’s share shall be placed in an interest-bearing escrow account (less reasonable expenses of the Fee Fund Administrator) and held unless and until a Payment Scenario is applicable.
c. Upon the applicability of a Payment Scenario 1 with respect to a Settling State, the Fee Fund Administrator shall pay that Settling State’s outside counsel the amount identified on the Final Fee Schedule for such state or such lesser amount that satisfies the Settling State’s obligation to its outside counsel in full. Any remaining allocation to such State shall be paid to the Settling State.
d. Upon the applicability of a Payment Scenario 2 or 3 with respect to a Settling State, the Fee Fund Administrator shall release monies from the State Outside Counsel Manufacturers Fee Fund in either the amount held by the Fee Fund Administrator, if the amount of the agreement or judgment is equal to or more than the amount held, or the amount indicated in the agreement or in the final judgment, if the amount in the agreement or judgment is less than the amount held.
e. Nothing herein, including the amounts listed in Paragraph 5 above or on any Fee Schedule, shall prevent a Settling State from arguing in any proceeding with its outside counsel that (i) its recovery was less than fifty percent (50%) of the recovery in the settlement agreement down to and including fifteen percent (15%) of the total recovery; (ii) any payment should be discounted by an appropriate discount rate commensurate to the risk of the settlement agreement and the timeline that the Settling State is receiving its payments; (iii) the settlement amount should be lower because the amount a Settling State receives was reduced because such Settling State’s outside counsel failed to obtain joinder from a Settling State’s Subdivision(s) that the outside counsel also represented; or (iv) any limitation placed by the Settling Manufacturer bars payment of a higher fee to outside counsel. f. In the event the amount due to the Settling State’s outside counsel from an escrow account is less than the total amount of funds escrowed on the account of the Settling State, the balance shall be paid to the Settling State. In no event, other than a State becoming a Non-Settling State, shall funds revert to a Manufacturer.

8. Non-Settling States; Reversion and Redistribution. Amounts owed by the Settling Manufacturer to the State Outside Counsel Manufacturers Fee Fund shall be reduced by amounts allocated to the fixed amount for such State under This Settlement Agreement in the event that a listed State becomes a Non-Settling State. The payments for the other Settling States reflected in the Fee Schedule shall be adjusted by the Fee Fund Administrator to reflect a recalculated proportional percentage under the Fee Calculation.

9. Interpretation.

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a. This Agreement shall be an Exhibit to each Multistate Manufacturer Settlement Agreement and shall include the Fee Schedule setting forth the presumptive payment calculations for each eligible Settling State. By joining This Settlement Agreement, each State agrees on the presumptive accuracy of the Fee Schedule, absent manifest error, the inclusion of a Non-Settling State, or the exclusion of a Settling State.
b. It is the intent of all parties that the State Outside Counsel Manufacturers Fee Fund function in a similar manner, with similar calculations and mechanics, as the “State Outside Counsel Fee Fund” established in Exhibit S of that certain settlement agreement dated as of July 21, 2021 setting forth the terms of settlement between and among McKesson Corporation, Cardinal Health, Inc., and AmerisourceBergen Corporation, on the one hand, and certain settling states and certain participating subdivisions, on the other hand.

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Schedule I
Fee Schedule

State
Total Fee

Allergan Share Teva Share
Alaska $1,252,625.36 $424,966.99 $827,658.36
Delaware $2,194,254.56 $744,425.11 $1,449,829.45
Georgia $6,557,324.06 $2,224,644.65 $4,332,679.41
Hawaii $1,272,349.43 $431,658.60 $840,690.83
Idaho $1,413,869.58 $479,670.88 $934,198.70
Kentucky $5,087,998.16 $1,726,159.60 $3,361,838.56 Mississippi $1,737,202.53 $589,365.16 $1,147,837.38 Nevada
$6,279,564.47 $2,130,411.64 $4,149,152.83
New Mexico
$5,218,189.24 $1,770,328.36 $3,447,860.88
Ohio $6,831,882.94 $2,317,791.78 $4,514,091.16
Oklahoma $1,470,349.73 $1,470,349.73 $-
Puerto Rico $4,823,581.25 $1,636,453.24 $3,187,128.01 South Dakota $673,251.45 $228,408.00 $444,843.46

Admin Expense
Holdbacks
$18,047.03 $31,952.97
Total $16,192,680.76 $28,669,762.00

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EXHIBIT T
Agreement on the Joint State Cost Fund

1. Definitions.
a. “Opioids Defendant” means Teva, Allergan, or such other defendant in opioids-related litigation that enters into a Multistate Settlement after November 1, 2022, and “Opioids Defendants” means all of the foregoing. b. “Multistate Settlement” means this Settlement Agreement along with any other settlement of opioids-related claims among 30 or more states and an Opioids Defendant.
c. “Settlement Agreement” means the settlement agreement between the Settling States and the Opioids Defendant to which this Agreement is attached as an Exhibit.
d. “Settling Opioids Defendant” means the Opioids Defendant that is a party to the Settlement Agreement.
e. “Settling States” has the meaning given such term in the Settlement Agreement.

2. Creation of a State Cost Fund. The Settling Opioids Defendant and the Settling States agree to the creation of a fund to pay costs and expenses associated with litigation and investigations related to the opioids litigation (such fund, the “State Cost Fund”). The State Cost Fund shall be administered separately from any other funds for the payment of attorneys fees or costs in connection with the Settlement Agreement, including any common benefit fund, contingency fee fund for subdivision counsel, subdivision cost fund, or MDL expense fund.

However, the State Cost Fund shall be administered jointly with similar “State Cost Funds” created in other Multistate Settlements after November 1, 2022; any state cost funds jointly administered in this manner shall be referred to as the “Joint State Cost Fund.” To the extent permissible and feasible, the Joint State Cost Fund may also be jointly administered with any fund for reimbursement of states’ litigation and investigation costs established by a bankruptcy plan, including the Mallinckrodt bankruptcy plan, any plans that may emerge from the bankruptcies of Purdue and Endo, and any similar bankruptcies of opioids defendants. To the extent feasible, the Joint State Cost Fund may also be jointly administered with the State Cost Funds established pursuant to the Distributors Multistate Settlement and the Janssen Multistate Settlement.

3. State Cost Fund Amount. The Settling Opioids Defendant shall pay into the State Cost Fund in the amount listed on, and on the schedule set forth in, Exhibit M (the “Settling Opioids Defendant’s Contribution”) for the purpose paying States’ costs and expenses associated with to the opioid litigation.

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4. Joint State Cost Fund Committee. A committee of Attorneys General or their designated representatives (such committee, the “Joint State Cost Fund Committee”) shall oversee the Joint State Cost Fund. The committee shall be appointed by the Settling State Members of the Enforcement Committee, who shall aim to (i) have equal representation between states that retained contingency fee outside counsel and states that did not retain contingency fee outside counsel with respect to opioids-related litigation, and (ii) maintain consistency of committee membership across state cost funds that compose the Joint State Cost Fund. The Settling State Members of the Enforcement Committee may by majority vote add to or change the composition of the Joint State Cost Fund Committee.

5. Joint State Cost Fund Administrator.
a. The Joint State Cost Fund Committee may select an administrator (the “Joint State Cost Fund Administrator”), who shall administer the Joint State Cost Fund and direct payments to Settling States according to the guidelines and directives of the Joint State Cost Fund Committee. While the expenses of the Joint State Cost Fund Administrator shall be reimbursable pursuant to the principles and guidelines listed below, the Joint State Cost Fund Administrator shall first rely on any separate funds that may be set aside for such purpose in any Multistate Settlement.
b. The Joint State Cost Fund Administrator shall be responsible, under the direction and supervision of the Joint State Cost Fund Committee, for receiving and reviewing applications for reimbursement from the Joint State Cost Fund. This may include the creation of an audit process to ensure the integrity of submissions, as well as reimbursement rules to incentivize accurate submissions.

6. State Cost Fund Guidelines and Principles.
a. Monies in the State Cost Fund shall be released without any delay to reimburse Settling States for documented costs incurred or paid in connection with litigation and investigation related to the opioid litigation. b. In allocating the Joint State Cost Fund, the Joint State Cost Fund Committee shall seek to comply with the following principles:

1. Each State Cost Fund should be used to reimburse costs incurred by States that are Settling States in the Multistate Settlement from which funds are paid. (However, the foregoing sentence does not preclude a Non-Settling State that joins a separate Multistate Settlement from participating in the Joint State Cost Fund with respect to contributions made by other Opioids Defendants.)

2. Funds in any State Cost Fund shall be primarily used to reimburse

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costs incurred prior to the date on which the relevant Multistate Settlement was first made available for participation to eligible States. Regardless of other factors considered in prioritizing payments, all costs incurred prior to January 1, 2023, shall be paid before any costs incurred after that date are paid.

3. The Joint State Cost Fund shall prioritize the reimbursement of the following over reimbursement of any State’s litigation or investigation costs:
• the reasonable costs of the Joint State Cost Fund
Administrator;
• repayment of National Association of Attorneys General grants made in connection with opioid investigations and litigation, without regard to when the grants were made; • repayment of state-attributable costs of any mediator in connection with negotiations of a Multistate Settlement;

4. The Joint State Cost Fund shall seek to prioritize costs in the following order:
• litigation-related costs; then
• investigation-related costs; then
• settlement and negotiation related costs; then
• cost shares.

5. Costs incurred by a State’s outside counsel that the State is contractually obligated to reimburse shall be treated as costs incurred by a State.

6. As between similar categories of costs (e.g., defendant -specific litigation-related costs), the Joint State Cost Fund shall first reimburse costs incurred by a State’s outside counsel that the State is contractually obligated to reimburse out of its recovery, and then reimburse costs directly incurred by States.

7. The Joint State Cost Fund shall be available to reimburse only those costs which have not yet been reimbursed to a State from any other source, including any other fund set aside in a Multistate Settlement or bankruptcy plan for the reimbursement of costs or any individual

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state settlements.

8. The Joint State Cost Fund should not reimburse expenses that are expected to be reimbursed from another source, such as a bankruptcy debtor, unless such expected reimbursements do not come to fruition within a reasonable amount of time. This includes cost shares paid by states.

9. When coordinating among different state cost funds that each could be used to reimburse a given expense, the Joint State Cost Fund Committee may set guidelines to equitably distribute
reimbursements across all state cost funds in a manner that prioritizes costs unlikely to be otherwise reimbursed to a similarly situated State.

10. The Joint State Cost Fund may deny reimbursement of costs, on either an individual basis or a categorical basis, that a supermajority (75%+) of the Joint State Cost Fund Committee determines to be unreasonable.

11. After all costs identified in the foregoing have been reimbursed, the remaining funds in the Joint State Cost Fund shall be distributed to states in proportion to their allocation of remediation payments in the Mallinckrodt bankruptcy plan. Such distribution shall be treated as a reimbursement for States’ unenumerated costs of administering the Multistate Settlements and no subdivision shares shall be carved out of such disbursement, nor shall any attorney’s fees be assessed against such distribution (unless individually agreed to by a State). c. In applying the foregoing principles, the Joint State Cost Fund Committee shall have the discretion to vary their application in order to ensure equity among similarly situated states and to facilitate the ease and speed of administering the Joint State Cost Fund. The Joint State Cost Fund Committee may also apply percentages to approximate costs attributable to a particular Opioids Defendant (or categories of Opioids Defendants) in a manner that seeks to treat similarly situated states equitably. d. The Joint State Cost Fund Committee shall establish guidelines for the submission and approval of expenses eligible for reimbursement from the Joint State Cost Fund, which guidelines may be coordinated and consolidated with any similar cost funds in other state opioid settlements for purposes of joint administration and efficiency.
e. Unless waived by the Joint State Cost Fund Committee, the Joint State Cost

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Fund Administrator shall, in accordance with such guidelines, receive from Settling States records sufficient to demonstrate the incurrence and payment of each expense.
f. Where the Joint State Cost Fund Committee determines by a supermajority vote (75%+) that outside counsel for a Settling State has failed to exercise reasonable diligence in reviewing submitted costs for allowability, and such failure has resulted in the reimbursement of unallowed costs to such outside counsel, the Committee shall have the discretion to reduce or recover payments made to such outside counsel in an amount calculated to incentivize the exercise of reasonable diligence.

7. State Undertakings. Each State submitting for reimbursement of costs from the Joint State Cost Fund agrees:
a. to only submit costs allowable under this Joint State Cost Fund Agreement; b. to provide all back-up documentation that may be requested with respect to any submitted cost and to make itself available for any questions related to such costs;
c. to exercise reasonable diligence to ensure that all submitted costs are allowable under (i) this Joint State Cost Fund Agreement, (ii) the State’s contract with its outside counsel, if relevant, (iii) state law, and (iv) the policies and procedures applicable to the State’s retention of outside counsel, if relevant; and
d. to promptly return any excess payments made to the State or its outside counsel from the Joint State Cost Fund, including payments made for costs that were reimbursed from another source or are not allowable hereunder.