HomeMy WebLinkAbout2025 07_Settlements with Purdue PharmaRESOLUTION OF THE CITY OF OWASSO, OKLAHOMA
RESOLUTION 2025-07
September 16, 2025
A RESOLUTION TO APPROVE PARTICIPATION IN SETTLEMENTS WITH PURDUE PHARMA LP,
MEMBERS OF THE SACKLER FAMILY, ALVOGEN, INC., AMNEAL PHARMACEUTICALS, INC.,
APOTEX, INC., HIKMA PHARMACEUTICALS USA, INC., INDIVIOR, INC., MYLAN
PHARMACEUTICALS INC., SUN PHARMACEUTICAL INDUSTRIES, INC., AND ZYDUS
PHARMACEUTICALS
WHEREAS, pharmaceutical opioids have harmed the City of Owasso, Oklahoma and
its citizens. This harm was created and exacerbated by the misconduct and
illegal activities of pharmaceutical manufacturers, including Purdue
Pharma L.P. and its related entities ("Purdue"), and Sackler family members
as officers, directors, managers, and shareholders of Purdue (the
"Sackler's").
WHEREAS, the City of Owasso, Oklahoma has claims against Purdue and/or the
Sackler's, and has filed suit to address and seek recovery for the harms
caused to it and its citizens.
WHEREAS, Purdue and the Sackler's have agreed to settle claims of political subdivisions
in the Purdue bankruptcy plan (the "Plan") in Case Number 7:19-bk-23649,
currently pending in the U.S. Bankruptcy Court for the Southern District of
New York, and in the Governmental Entities Settlement Agreement
("GESA") which settlement agreement is dated June 17, 2025.
WHEREAS, the City of Owasso, Oklahoma has claims against the generic opioid
manufacturers Alvogen, Inc., Amneal Pharmaceuticals, Inc., Apotex, Inc.,
Hikma Pharmaceuticals USA, Inc., Indivior Inc., Mylan Pharmaceuticals Inc.,
Sun Pharmaceutical Industries, Inc., and Zydus Pharmaceuticals, and/or is
eligible to participate in settlement agreements with these generic opioid
manufacturers, which are dated April 4, 2025, to address the harms caused
to it and its citizens from the opioid epidemic.
THEREFORE, it was duly moved and seconded that the following resolution be adopted.
THEREFORE, BE IT RESOLVED that the City of Owasso, Oklahoma hereby acknowledges
receipt of the Disclosure Statement for Thirteenth Amended Joint Chapter
11 Plan of Reorganization of Purdue and Its Affiliated Debtors, and that it
has been informed of the material aspects of the Plan relative to its claims
against Purdue and its affiliated entities.
THEREFORE, BE IT RESOLVED that the City of Owasso, Oklahoma hereby elects to
participate, and hereby approves its participation in, the Plan and directs
its attorneys to vote on its behalf for approval of the Plan and ratifies the
vote via master ballot or otherwise by its attorneys on its behalf for approval
of the Plan.
Resolution 2025-07
Page 1 of 31
THEREFORE, BE IT RESOLVED that the City of Owasso, Oklahoma hereby authorizes the
Mayor, or the Mayor's designee, to execute the GESA Participation and
Release Form contained in the GESA as Exhibit K (including executing such
Participation Form electronically or in paper form), and agrees to the terms
set forth in the Participation Form, including release of and/or dismissal with
prejudice of the City of Owasso's claims being released in the GESA,
including claims against the Sackler's.
THEREFORE, BE IT RESOLVED that the City of Owasso, Oklahoma hereby approves the
GESA dated June 17, 2025, and further approves and ratifies the actions of
its legal counsel in executing documents necessary for the City of Owasso
to participate in the GESA dated June 17, 2025.
THEREFORE, BE IT RESOLVED that the City of Owasso, Oklahoma hereby approves the
Purdue State -Subdivision Agreement, upon execution of the Purdue State -
Subdivision Agreement by the Attorney General of the State of Oklahoma,
and further approves and ratifies the actions of its legal counsel in
executing documents necessary for the City of Owasso to participate in the
Purdue State -Subdivision Agreement.
THEREFORE, BE IT RESOLVED that the City of Owasso, Oklahoma hereby authorizes the
Mayor, or the Mayor's designee, to execute each of the Settlement
Participation and Release Forms contained in the settlement agreements
with Alvogen, Inc., Amneal Pharmaceuticals, Inc., Apotex, Inc., Hikma
Pharmaceuticals USA, Inc., Indivior Inc., Mylan Pharmaceuticals Inc., Sun
Pharmaceutical Industries, Inc., and Zydus Pharmaceuticals (including
executing such Participation Form electronically or in paper form), and
agrees to the terms set forth in the Participation Form, including release of
and/or dismissal with prejudice of the City of Owasso's claims being
released in the settlement agreements with Alvogen, Inc., Amneal
Pharmaceuticals, Inc., Apotex, Inc., Hikma Pharmaceuticals USA, Inc.,
Indivior Inc., Mylan Pharmaceuticals Inc., Sun Pharmaceutical Industries,
Inc., and Zydus Pharmaceuticals.
THEREFORE, BE IT RESOLVED that the City of Owasso, Oklahoma hereby approves the
settlement agreements with Alvogen, Inc., Amneal Pharmaceuticals, Inc.,
Apotex, Inc., Hikma Pharmaceuticals USA, Inc., Indivior Inc., Mylan
Pharmaceuticals Inc., Sun Pharmaceutical Industries, Inc., and Zydus
Pharmaceuticals, and further approves and ratifies the actions of its legal
counsel in executing documents necessary for the City of Owasso to
participate in the settlement agreements with Alvogen, Inc., Amneal
Pharmaceuticals, Inc., Apotex, Inc., Hikma Pharmaceuticals USA, Inc.,
Indivior Inc., Mylan Pharmaceuticals Inc., Sun Pharmaceutical Industries,
Inc., and Zydus Pharmaceuticals.
THEREFORE, BE IT RESOLVED that the City of Owasso, Oklahoma hereby approves
authorizes and approves its Litigation Counsel in the opioid litigation to
Resolution 2025-07
Page 2 of 31
negotiate and enter into a State -Subdivision Agreement with the State of
Oklahoma through the Attorney General on behalf of the City with respect
to the Generic/Small/Secondary Manufacturer Settlements with the
generic opioid manufacturers Alvogen, Inc., Amneal Pharmaceuticals,
Inc., Apotex, Inc., Hikma Pharmaceuticals USA, Inc., Indivior Inc., Mylan
Pharmaceuticals Inc., Sun Pharmaceutical Industries, Inc., and Zydus
Pharmaceuticals, and further approves and ratifies the actions of its legal
counsel in executing documents necessary for the City of Owasso to
participate in said State -Subdivision Agreement.
THEREFORE, BE IT RESOLVED that City of Owasso, Oklahoma, further authorizes its Mayor
and legal counsel to take all actions required by the Plan, the GESA, and
the settlement agreements with Alvogen, Inc., Amneal Pharmaceuticals,
Inc., Apotex, Inc., Hikma Pharmaceuticals USA, Inc., Indivior Inc., Mylan
Pharmaceuticals Inc., Sun Pharmaceutical Industries, Inc., and Zydus
Pharmaceuticals, referenced herein, for the benefit of the City of Owasso,
Oklahoma, including executing any documents required to finalize the
participation of the City of Owasso, Oklahoma in the Plan, GESA, and
generic manufacturer settlement agreements.
The City of Owasso, Oklahoma adopted the above Resolution on the 161h day of
September, 2025.
CITY OF OWASSO, OKLAHOMA
a" ,
Alvin Fruga, ayof
Dated this 161h day of September, 2025.
ATTEST:
G�4y OF O
� �Z
ti't' 9ifs
OFFICIAL 0
i nn M. Stevens, City Clerk
ak<AHOMP'
Resolution 2025-07
Page 3 of 31
:n:
Subdivision Participation and Release Form
Governmental Entity: City of Owasso
State: Oklahoma
Authorized Signatory: Alvin Fruga, Mayor
Address 1:200.South Main Street
Address 2:
City, State, Zip: Owasso, OK, 74055
Phone: 91 B-376-1500
Email: afruga@cityofowasso.com
The governmental entity identified above ("Governmental Entity"), in order to obtain and
in consideration for the benefits provided to the Governmental Entity pursuant to the Settlement
Agreement dated April 4, 2025 ("Alvogen Settlement'), and acting through the undersigned
authorized official, hereby elects to participate in the Alvogen Settlement, release all Released
Claims against all Released Entities, and agrees as follows.
1. The Governmental Entity is aware of and has reviewed the Alvogen Settlement,
understands that all terms in this Participation and Release Form have the meanings defined
therein, and agrees that by executing this Participation and Release Form, the
Governmental Entity elects to participate in the Alvogen Settlement and become a
Participating Subdivision as provided therein.
2. The Governmental Entity shall promptly, and in any event no later than 14 days after the
Reference Date and prior to the filing of the Consent Judgment, dismiss with prejudice any
Released Claims that it has filed. With respect to any Released Claims pending in In re
National Prescription Opiate Litigation, MDL No. 2804, the Governmental Entity
authorizes the Plaintiffs' Executive Committee to execute and file on behalf of the
Governmental Entity a Stipulation of Dismissal with Prejudice substantially in the form
found athttps://nationalopioidsettlement.com/additional-settlements/.
3. The Governmental Entity agrees to the terms of the Alvogen Settlement pertaining to
Participating Subdivisions as defined therein.
4. By agreeing to the terms of the Alvogen Settlement and becoming a Releasor, the
Governmental Entity is entitled to the benefits provided therein, including, if applicable,
monetary payments beginning after the Effective Date.
5. The Governmental Entity agrees to use any monies it receives through the Alvogen
Settlement solely for the purposes provided therein.
6. The Governmental Entity submits to the jurisdiction of the court in the Governmental
Entity's state where the Consent Judgment is filed for purposes limited to that court's role
as provided in, and for resolving disputes to the extent provided in, the Alvogen Settlement.
I;QI
The Governmental Entity likewise agrees to arbitrate before the National Arbitration Panel
as provided in, and for resolving disputes to the extent otherwise provided in, the Alvogen
Settlement.
7. The Governmental Entity has the right to enforce the Alvogen Settlement as provided
therein.
8. The Governmental Entity, as a Participating Subdivision, hereby becomes a Releasor for
all purposes in the Alvogen Settlement, including without limitation all provisions of
Section XI (Release), and along with all departments, agencies, divisions, boards,
commissions, districts, instrumentalities of any kind and attorneys, and any person in his
or her official capacity whether elected or appointed to serve any of the foregoing and any
agency, person, or other entity claiming by or through any of the foregoing, and any other
entity identified in the definition of Releasor, provides for a release to the fullest extent of
its authority. As a Releasor, the Governmental Entity hereby absolutely, unconditionally,
and irrevocably covenants not to bring, file, or claim, or to cause, assist or permit to be
brought, filed, or claimed, or to otherwise seek to establish liability for any Released
Claims against any Released Entity in any forum whatsoever. The releases provided for in
the Alvogen Settlement are intended by the Parties to be broad and shall be interpreted so
as to give the Released Entities the broadest possible bar against any liability relating in
any way to Released Claims and extend to the full extent of the power of the Governmental
Entity to release claims. The Alvogen Settlement shall be a complete bar to any Released
Claim.
9. The Governmental Entity hereby takes on all rights and obligations of a Participating
Subdivision as set forth in the Alvogen Settlement.
10. In connection with the releases provided for in the Alvogen 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
K-2
materially affect the Governmental Entities' decision to participate in the Alvogen
Settlement.
11. Nothing herein is intended to modify in any way the terms of the Alvogen Settlement, to
which Governmental Entity hereby agrees. To the extent this Participation and Release
Form is interpreted differently from the Alvogen Settlement in any respect, the Alvogen
Settlement controls.
I have all necessary power and authorization to execute this Participation and Release Form
on behalf of the Governmental Entity.
Signature:
Name: Alvin Fruga
Title: Mayor
Date: 9/16/2025
K-3
LMUI I 14
Subdivision Participation and Release Form
Governmental Entity: City of Owasso
State: Oklahoma
Authorized Signatory:Alvin Fruga, Mayor
Address 1:200 South Main Street
Address 2:
City, State, Zip: Owasso, OK, 74055
Phone: 918-376-1500
Email: afruga@cityofowasso.com
The governmental entity identified above ("Governmental Entity"), in order to obtain and
in consideration for the benefits provided to the Governmental Entity pursuant to the Settlement
Agreement dated April 4, 2025 ("Amneal Settlement"), and acting through the undersigned
authorized official, hereby elects to participate in the Amneal Settlement, release all Released
Claims against all Released Entities, and agrees as follows.
1. The Governmental Entity is aware of and has reviewed the Amneal Settlement, understands
that all terms in this Participation and Release Form have the meanings defined therein,
and agrees that by executing this Participation and Release Form, the Governmental Entity
elects to participate in the Amneal Settlement and become a Participating Subdivision as
provided therein.
2. The Governmental Entity shall promptly, and in any event no later than 14 days after the
Reference Date and prior to the filing of the Consent Judgment, dismiss with prejudice any
Released Claims that it has filed. With respect to any Released Claims pending in In re
National Prescription Opiate Litigation, MDL No. 2804, the Governmental Entity
authorizes the Plaintiffs' Executive Committee to execute and file on behalf of the
Governmental Entity a Stipulation of Dismissal with Prejudice substantially in the form
found at https://nationalopioidsettlement.com/additional-settlements/.
The Governmental Entity agrees to the terms of the Amneal Settlement pertaining to
Participating Subdivisions as defined therein.
4. By agreeing to the terms of the Amneal Settlement and becoming a Releasor, the
Governmental Entity is entitled to the benefits provided therein, including, if applicable,
monetary payments beginning after the Effective Date.
5. The Governmental Entity agrees to use any monies it receives through the Amneal
Settlement solely for the purposes provided therein.
6- The Governmental Entity submits to the jurisdiction of the court in the Governmental
Entity's state where the Consent Judgment is filed for purposes limited to that court's role
as provided in, and for resolving disputes to the extent provided in, the Amneal Settlement.
K-1
The Governmental Entity likewise agrees to arbitrate before the National Arbitration Panel
as provided in, and for resolving disputes to the extent otherwise provided in, the Amneal
Settlement.
7. The Governmental Entity has the right to enforce the Amneal Settlement as provided
therein.
The Governmental Entity, as a Participating Subdivision, hereby becomes a Releasor for
all purposes in the Amneal Settlement, including without limitation all provisions of
Section X (Release), and along with all departments, agencies, divisions, boards,
commissions, districts, instrumentalities of any kind and attorneys, and any person in his
or her official capacity whether elected or appointed to serve any of the foregoing and any
agency, person, or other entity claiming by or through any of the foregoing, and any other
entity identified in the definition of Releaser, provides for a release to the fullest extent of
its authority. As a Releasor, the Governmental Entity hereby absolutely, unconditionally,
and irrevocably covenants not to bring, file, or claim, or to cause, assist or permit to be
brought, filed, or claimed, or to otherwise seek to establish liability for any Released
Claims against any Released Entity in any forum whatsoever. The releases provided for in
the Amneal Settlement are intended by the Parties to be broad and shall be interpreted so
as to give the Released Entities the broadest possible bar against any liability relating in
any way to Released Claims and extend to the full extent of the power of the Governmental
Entity to release claims. The Amneal Settlement shall be a complete bar to any Released
Claim.
9. The Governmental Entity hereby takes on all rights and obligations of a Participating
Subdivision as set forth in the Amneal Settlement.
10. In connection with the releases provided for in the Amneal 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 Releaser 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
K-2
materially affect the Governmental Entities' decision to participate in the Amneal
Settlement.
11. Nothing herein is intended to modify in any way the terms of the Amneal Settlement, to
which Governmental Entity hereby agrees. To the extent this Participation and Release
Form is interpreted differently from the Amneal Settlement in any respect, the Amneal
Settlement controls.
I have all necessary power and authorization to execute this Participation and Release Form
on behalf of the Governmental Entity. Q n
Signature: X
Name: Alvin Fruga
Title: Mayor
Date: 9/16/2025
K-3
EXHIBIT K
Subdivision Participation and Release Form
Governmental Entity: City of Owasso
State: OK
Authorized Signatory: Alvin Fruga, Mayor
Address 1: 200 South Main Street
Address 2:
City, State, Zip: Owasso, OK, 74055
Phone: 918-376-1500
Email: afruga@cityofowasso.com
The governmental entity identified above ("Governmental Entity"), in order to obtain and
in consideration for the benefits provided to the Governmental Entity pursuant to the Settlement
Agreement dated April 4, 2025 ("Apotex Settlement"), and acting through the undersigned
authorized official, hereby elects to participate in the Apotex Settlement, release all Released
Claims against all Released Entities, and agrees as follows.
The Governmental Entity is aware of and has reviewed the Apotex Settlement, understands
that all terms in this Participation and Release Form have the meanings defined therein,
and agrees that by executing this Participation and Release Form, the Governmental Entity
elects to participate in the Apotex Settlement and become a Participating Subdivision as
provided therein.
2. The Governmental Entity shall promptly, and in any event no later than 14 days after the
Reference Date and prior to the filing of the Consent Judgment, dismiss with prejudice any
Released Claims that it has filed. With respect to any Released Claims pending in In re
National Prescription Opiate Litigation, MDL No. 2804, the Governmental Entity
authorizes the Plaintiffs' Executive Committee to execute and file on behalf of the
Governmental Entity a Stipulation of Dismissal with Prejudice substantially in the form
found at https://nationalopioidsettlement.com/additional-settlements/.
The Governmental Entity agrees to the terms of the Apotex Settlement pertaining to
Participating Subdivisions as defined therein.
4. By agreeing to the terms of the Apotex Settlement and becoming a Releasor, the
Governmental Entity is entitled to the benefits provided therein, including, if applicable,
monetary payments beginning after the Effective Date.
5. The Governmental Entity agrees to use any monies it receives through the Apotex
Settlement solely for the purposes provided therein.
6. The Governmental Entity submits to the jurisdiction of the court in the Governmental
Entity's state where the Consent Judgment is filed for purposes limited to that court's role
as provided in, and for resolving disputes to the extent provided in, the Apotex Settlement.
rAI
The Governmental Entity likewise agrees to arbitrate before the National Arbitration Panel
as provided in, and for resolving disputes to the extent otherwise provided in, the Apotex
Settlement.
7. The Governmental Entity has the right to enforce the Apotex Settlement as provided
therein.
8, The Governmental Entity, as a Participating Subdivision, hereby becomes a Releasor for
all purposes in the Apotex Settlement, including without limitation all provisions of Section
XI (Release), and along with all departments, agencies, divisions, boards, commissions,
districts, instrumentalities of any kind and attorneys, and any person in his or her official
capacity whether elected or appointed to serve any of the foregoing and any agency, person,
or other entity claiming by or through any of the foregoing, and any other entity identified
in the definition of Releasor, provides for a release to the fullest extent of its authority. As
a Releasor, the Governmental Entity hereby absolutely, unconditionally, and irrevocably
covenants not to bring, file, or claim, or to cause, assist or permit to be brought, filed, or
claimed, or to otherwise seek to establish liability for any Released Claims against any
Released Entity in any forum whatsoever. The releases provided for in the Apotex
Settlement are intended by the Parties to be broad and shall be interpreted so as to give the
Released Entities the broadest possible bar against any liability relating in any way to
Released Claims and extend to the full extent of the power of the Governmental Entity to
release claims. The Apotex Settlement shall be a complete bar to any Released Claim.
9. The Governmental Entity hereby takes on all rights and obligations of a Participating
Subdivision as set forth in the Apotex Settlement.
10. In connection with the releases provided for in the Apotex 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 Releaser may hereafter discover facts other than or different from those which it knows,
believes, or assumes to be true with respect to the Released Claims, but each Governmental
Entity hereby expressly waives and fully, finally, and forever settles, releases and
discharges, upon the Effective Date, any and all Released Claims that may exist as of such
date but which Releasors do not know or suspect to exist, whether through ignorance,
oversight, error, negligence or through no fault whatsoever, and which, if known, would
materially affect the Governmental Entities' decision to participate in the Apotex
Settlement.
K-2
11. Nothing herein is intended to modify in any way the terms of the Apotex Settlement, to
which Governmental Entity hereby agrees. To the extent this Participation and Release
Form is interpreted differently from the Apotex Settlement in any respect, the Apotex
Settlement controls.
I have all necessary power and authorization to execute this Participation and Release Form
on behalf of the Governmental Entity.
Signature:
Name: Alvin Fruga
Title: Mayor
Date: 9/16/2025
K-3
EXHIBIT K
Subdivision Participation and Release Form
Governmental Entity: City of Owasso
State: Oklahoma
Authorized Signatory: Alvin Fruga, Mayor
Address 1: 200 South Main Street
Address 2:
City, State, Zip: Owasso, OK, 74055
Phone: 919-376-1500
Email: afruga@cityofowasso.com
The governmental entity identified above ("Governmental Entity'), in order to obtain and
in consideration for the benefits provided to the Governmental Entity pursuant to the Settlement
Agreement dated April 4, 2025 ("Hikma Settlement"), and acting through the undersigned
authorized official, hereby elects to participate in the Hikma Settlement, release all Released
Claims against all Released Entities, and agrees as follows.
1. The Governmental Entity is aware of and has reviewed the Hikma Settlement, understands
that all terms in this Participation and Release Form have the meanings defined therein,
and agrees that by executing this Participation and Release Form, the Governmental Entity
elects to participate in the Hikma Settlement and become a Participating Subdivision as
provided therein.
2. The Governmental Entity shall promptly, and in any event no later than 14 days after the
Reference Date and prior to the filing of the Consent Judgment, dismiss with prejudice any
Released Claims that it has filed. With respect to any Released Claims pending in In re
National Prescription Opiate Litigation, MDL No. 2804, the Governmental Entity
authorizes the Plaintiffs' Executive Committee to execute and file on behalf of the
Governmental Entity a Stipulation of Dismissal with Prejudice substantially in the form
found athttps://nationalopioidsettlement.com/additional-settlements/.
3. The Governmental Entity agrees to the terms of the Hikma Settlement pertaining to
Participating Subdivisions as defined therein.
4. By agreeing to the terms of the Hikma 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.
The Governmental Entity agrees to use any monies it receives through the Hikma
Settlement solely for the purposes provided therein.
6. The Governmental Entity submits to the jurisdiction of the court in the Governmental
Entity's state where the Consent Judgment is filed for purposes limited to that court's role
as provided in, and for resolving disputes to the extent provided in, the Hikma Settlement.
K-1
The Governmental Entity likewise agrees to arbitrate before the National Arbitration Panel
as provided in, and for resolving disputes to the extent otherwise provided in, the Hikma
Settlement.
7. The Governmental Entity has the right to enforce the Hikma Settlement as provided
therein.
8. The Governmental Entity, as a Participating Subdivision, hereby becomes a Releasor for
all purposes in the Hikma Settlement, including without limitation all provisions of Section
X (Release), and along with all departments, agencies, divisions, boards, commissions,
districts, instrumentalities of any kind and attorneys, and any person in his or her official
capacity whether elected or appointed to serve any of the foregoing and any agency, person,
or other entity claiming by or through any of the foregoing, and any other entity identified
in the definition of Releasor, provides for a release to the fullest extent of its authority. As
a Releasor, the Governmental Entity hereby absolutely, unconditionally, and irrevocably
covenants not to bring, file, or claim, or to cause, assist or permit to be brought, filed, or
claimed, or to otherwise seek to establish liability for any Released Claims against any
Released Entity in any forum whatsoever. The releases provided for in the Hikma
Settlement are intended by the Parties to be broad and shall be interpreted so as to give the
Released Entities the broadest possible bar against any liability relating in any way to
Released Claims and extend to the full extent of the power of the Governmental Entity to
release claims. The Hikma Settlement shall be a complete bar to any Released Claim.
9. The Governmental Entity hereby takes on all rights and obligations of a Participating
Subdivision as set forth in the Hikma Settlement.
10. In connection with the releases provided for in the Hikma 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
materially affect the Governmental Entities' decision to participate in the Hikma
Settlement.
K-2
11. Nothing herein is intended to modify in any way the terms of the Hikma Settlement, to
which Governmental Entity hereby agrees. To the extent this Participation and Release
Form is interpreted differently from the Hikma Settlement in any respect, the Hikma
Settlement controls.
I have all necessary power and authorization to execute this Participation and Release Form
on behalf of the Governmental Entity.
Signature:
Name: Alvin Fruga
Title: Mayor
Date: 9/16/2025
K-3
EXHIBIT K
Subdivision Participation and Release Form
Governmental Entity: City of Owasso
State: Oklahoma
Authorized Signatory: Alvin Fruga, Mayor
Address 1: 200 South Main Street
Address 2:
City, State, Zip: Owasso, OK, 74055
Phone: 918-376-1500
Email: afruga@cityofowasso.com
The governmental entity identified above ("Governmental Entity"), in order to obtain and
in consideration for the benefits provided to the Governmental Entity pursuant to the Settlement
Agreement dated April 4, 2025 ("Indivior Settlement"), and acting through the undersigned
authorized official, hereby elects to participate in the Indivior Settlement, release all Released
Claims against all Released Entities, and agrees as follows.
The Governmental Entity is aware of and has reviewed the Indivior Settlement,
understands that all terms in this Participation and Release Form have the meanings defined
therein, and agrees that by executing this Participation and Release Form, the
Governmental Entity elects to participate in the Indivior Settlement and become a
Participating Subdivision as provided therein.
2. The Governmental Entity shall promptly, and in any event no later than 14 days after the
Reference Date and prior to the filing of the Consent Judgment, dismiss with prejudice any
Released Claims that it has filed. With respect to any Released Claims pending in In re
National Prescription Opiate Litigation, MDL No. 2804, the Governmental Entity
authorizes the Plaintiffs' Executive Committee to execute and file on behalf of the
Governmental Entity a Stipulation of Dismissal with Prejudice substantially in the form
found at https://nationalopioidsettlement.com/additional-settlements/.
3. The Governmental Entity agrees to the terms of the Indivior Settlement pertaining to
Participating Subdivisions as defined therein.
4. By agreeing to the terms of the Indivior Settlement and becoming a Releasor, the
Governmental Entity is entitled to the benefits provided therein, including, if applicable,
monetary payments beginning after the Effective Date.
5. The Governmental Entity agrees to use any monies it receives through the Indivior
Settlement solely for the purposes provided therein.
6. The Governmental Entity submits to the jurisdiction of the court in the Governmental
Entity's state where the Consent Judgment is filed for purposes limited to that court's role
as provided in, and for resolving disputes to the extent provided in, the Indivior Settlement.
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The Governmental Entity likewise agrees to arbitrate before the National Arbitration Panel
as provided in, and for resolving disputes to the extent otherwise provided in, the Indivior
Settlement.
7. The Governmental Entity has the right to enforce the Indivior Settlement as provided
therein.
8. The Governmental Entity, as a Participating Subdivision, hereby becomes a Releasor for
all purposes in the Indivior Settlement, including without limitation all provisions of
Section X (Release), and along with all departments, agencies, divisions, boards,
commissions, districts, instrumentalities of any kind and attorneys, and any person in his
or her official capacity whether elected or appointed to serve any of the foregoing and any
agency, person, or other entity claiming by or through any of the foregoing, and any other
entity identified in the definition of Releasor, provides for a release to the fullest extent of
its authority. As a Releasor, the Governmental Entity hereby absolutely, unconditionally,
and irrevocably covenants not to bring, file, or claim, or to cause, assist or permit to be
brought, filed, or claimed, or to otherwise seek to establish liability for any Released
Claims against any Released Entity in any forum whatsoever. The releases provided for in
the Indivior Settlement are intended by the Parties to be broad and shall be interpreted so
as to give the Released Entities the broadest possible bar against any liability relating in
any way to Released Claims and extend to the full extent of the power of the Governmental
Entity to release claims. The Indivior Settlement shall be a complete bar to any Released
Claim.
9. The Governmental Entity hereby takes on all rights and obligations of a Participating
Subdivision as set forth in the Indivior Settlement.
10. In connection with the releases provided for in the Indivior 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 Indivior
Settlement.
11. Nothing herein is intended to modify in any way the terms of the Indivior Settlement, to
which Governmental Entity hereby agrees. To the extent this Participation and Release
Form is interpreted differently from the Indivior Settlement in any respect, the Indivior
Settlement controls.
I have all necessary power and authorization to execute this Participation and Release Form
on behalf of the Governmental Entity.
Signature:
agww�
Name: Alvin Fruga
Title: Mayor
Date: 9/16/2025
K-3
EXHIBIT K
Subdivision Participation and Release Form
Governmental Entity: City of Owasso
State: Oklahoma
Authorized Signatory: Alvin Fruga, Mayor
Address 1: 200 South Main Street
Address 2:
City, State, Zip: Owasso, OK, 74055
Phone: 918-376-1500
Email: afruga@cityofowasso.com
The governmental entity identified above ("Governmental Entity"), in order to obtain and
in consideration for the benefits provided to the Governmental Entity pursuant to the Settlement
Agreement dated April 4, 2025 ("Mylan Settlement"), and acting through the undersigned
authorized official, hereby elects to participate in the Mylan Settlement, release all Released
Claims against all Released Entities, and agrees as follows.
1. The Governmental Entity is aware of and has reviewed the Mylan Settlement, understands
that all terms in this Participation and Release Form have the meanings defined therein,
and agrees that by executing this Participation and Release Form, the Governmental Entity
elects to participate in the Mylan Settlement and become a Participating Subdivision as
provided therein.
The Governmental Entity shall promptly, and in any event no later than 14 days after the
Reference Date and prior to the filing of the Consent Judgment, dismiss with prejudice any
Released Claims that it has filed. With respect to any Released Claims pending in In re
National Prescription Opiate Litigation, MDL No. 2804, the Governmental Entity
authorizes the Plaintiffs' Executive Committee to execute and file on behalf of the
Governmental Entity a Stipulation of Dismissal with Prejudice substantially in the form
found at https://nationalopioidsettlement.com/additional-settlements/.
The Governmental Entity agrees to the terms of the Mylan Settlement pertaining to
Participating Subdivisions as defined therein.
4. By agreeing to the terms of the Mylan 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.
The Governmental Entity agrees to use any monies it receives through the Mylan
Settlement solely for the purposes provided therein.
6. The Governmental Entity submits to the jurisdiction of the court in the Governmental
Entity's state where the Consent Judgment is filed for purposes limited to that court's role
as provided in, and for resolving disputes to the extent provided in, the Mylan Settlement.
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The Governmental Entity likewise agrees to arbitrate before the National Arbitration Panel
as provided in, and for resolving disputes to the extent otherwise provided in, the Mylan
Settlement.
7. The Governmental Entity has the right to enforce the Mylan Settlement as provided therein.
8. The Governmental Entity, as a Participating Subdivision, hereby becomes a Releasor for
all purposes in the Mylan Settlement, including without limitation all provisions of Section
X (Release), and along with all departments, agencies, divisions, boards, commissions,
districts, instrumentalities of any kind and attorneys, and any person in his or her official
capacity whether elected or appointed to serve any of the foregoing and any agency, person,
or other entity claiming by or through any of the foregoing, and any other entity identified
in the definition of Releasor, provides for a release to the fullest extent of its authority. As
a Releasor, the Governmental Entity hereby absolutely, unconditionally, and irrevocably
covenants not to bring, file, or claim, or to cause, assist or permit to be brought, filed, or
claimed, or to otherwise seek to establish liability for any Released Claims against any
Released Entity in any forum whatsoever. The releases provided for in the Mylan
Settlement are intended by the Parties to be broad and shall be interpreted so as to give the
Released Entities the broadest possible bar against any liability relating in any way to
Released Claims and extend to the full extent of the power of the Governmental Entity to
release claims. The Mylan Settlement shall be a complete bar to any Released Claim.
9. The Governmental Entity hereby takes on all rights and obligations of a Participating
Subdivision as set forth in the Mylan Settlement.
10. In connection with the releases provided for in the Mylan 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
materially affect the Governmental Entities' decision to participate in the Mylan
Settlement.
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11. Nothing herein is intended to modify in any way the terms of the Mylan Settlement, to
which Governmental Entity hereby agrees. To the extent this Participation and Release
Form is interpreted differently from the Mylan Settlement in any respect, the Mylan
Settlement controls.
I have all necessary power and authorization to execute this Participation and Release Form
on behalf of the Governmental Entity.
Signature:
Name: Alvin Fruga
Title: Mayor
Date: 9/16/2025
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EXHIBIT K
Subdivision Participation and Release Form
Governmental Entity: city of Owasso
State: Oklahoma
Authorized Official: Alvin Fru a Ma
r
Address 1: 200 South Main Street
Address 2:
City, State Zip: Owasso, OK, 74055
Phone: 918-376-1500
Email: afruga@cityofowasso.com
The governmental entity identified above ("Governmental Entity"), in order to obtain and
in consideration for the benefits provided to the Governmental Entity pursuant to that certain
Governmental Entity & Shareholder Direct Settlement Agreement accompanying this
participation form (the "Agreenient")t, and acting through the undersigned authorized official,
hereby elects to participate in the Agreement, grant the releases set forth below, and agrees as
follows.
1. The Governmental Entity is aware of and has reviewed the Agreement, and agrees that by
executing this Participation and Release Form, the Governmental Entity elects to
participate in the Agreement and become a Participating Subdivision as provided therein.
2. The Governmental Entity shall promptly after the Effective Date, and prior to the filing of
the Consent Judgment, dismiss with prejudice any Shareholder Released Claims and
Released Claims that it has filed. With respect to any Shareholder Released Claims and
Released Claims pending in In re National Prescription Opiate Litigation, MDL No. 2804,
the Governmental Entity authorizes the Plaintiffs' Executive Committee to execute and file
on behalf of the Governmental Entity a Stipulation of Dismissal with Prejudice
substantially in the form found at hgps://nationalopioidsettlement.COM.
3. The Governmental Entity agrees to the terms of the Agreement pertaining to Participating
Subdivisions as defined therein.
4. By agreeing to the terns of the Agreement and becoming a Releasor, the Governmental
Entity is entitled to the benefits provided therein, including, if applicable, monetary
payments beginning following the Effective Date.
5. The Governmental Entity agrees to use any monies it receives through the Agreement
solely for the purposes provided therein.
6. The Governmental Entity submits to the jurisdiction of the court in the Governmental
Entity's state where the Consent Judgment is filed for purposes limited to that court's role
as and to the extent provided in, and for resolving disputes to the extent provided in, the
Capitalized terms used in this Exhibit K but not otherwise defined in this Exhibit K have the meanings given to
them in the Agreement or, if not defined in the Agreement, the Master Settlement Agreement.
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Agreement. The Governmental Entity likewise agrees to arbitrate before the National
Arbitration Panel as provided in, and for resolving disputes to the extent otherwise
provided in, the Agreement.
7. The Governmental Entity has the right to enforce the Agreement as provided therein.
8. The Governmental Entity, as a Participating Subdivision, hereby becomes a Releasor for
all purposes in the Agreement, including without limitation all provisions of Article 10
(Release), and along with all departments, agencies, divisions, boards, commissions,
districts, instrumentalities of any kind and attorneys, and any person in his or her official
capacity whether elected or appointed to serve any of the foregoing and any agency, person,
or other entity claiming by or through any of the foregoing, and any other entity identified
in the definition of Subdivision Releaser, to the maximum extent of its authority, for good
and valuable consideration, the adequacy of which is hereby confirmed, the Shareholder
Released Parties and Released Parties are, as of the Effective Date, hereby released and
forever discharged by the Governmental Entity and its Subdivision Releasors from: any
and all Causes of Action, including, without limitation, any Estate Cause of Action and any
claims that the Governmental Entity or its Subdivision Releasors would have presently or
in the future been legally entitled to assert in its own right (whether individually or
collectively), notwithstanding section 1542 of the California Civil Code or any law of any
jurisdiction that is similar, comparable or equivalent thereto (which shall conclusively be
deemed waived), whether existing or hereinafter arising, in each case, (A) directly or
indirectly based on, arising out of, or in any way relating to or concerning, in whole or in
part, (i) the Debtors, as such Entities existed prior to or after the Petition Date, and their
Affiliates, (ii) the Estates, (iii) the Chapter 11 Cases, or (iv) Covered Conduct and (B) as
to which any conduct, omission or liability of any Debtor or any Estate is the legal cause
or is otherwise a legally relevant factor (each such release, as it pertains to the Shareholder
Released Parties, the "Shareholder Released Claims", and as it pertains to the Released
Parties other than the Shareholder Released Parties, the "Released Claims"). For the
avoidance of doubt and without limiting the foregoing: the Shareholder Released Claims
and Released Claims include any Cause of Action that has been or may be asserted against
any Shareholder Released Party or Released Party by the Governmental Entity or its
Subdivision Releasors (whether or not such party has brought such action or proceeding)
in any federal, state, or local action or proceeding (whether judicial, arbitral, or
administrative) (A) directly or indirectly based on, arising out of, or in any way relating to
or concerning, in whole or in part, (i) the Debtors, as such Entities existed prior to or after
the Petition Date, and their Affiliates, (ii) the Estates, (iii) the Chapter 11 Cases, or (iv)
Covered Conduct and (B) as to which any conduct, omission or liability of any Debtor or
any Estate is the legal cause or is otherwise a legally relevant factor.
9. As a Releaser, the Governmental Entity hereby absolutely, unconditionally, and
irrevocably covenants not to bring, file, or claim, or to cause, assist or permit to be brought,
filed, or claimed, or to otherwise seek to establish liability for any Shareholder Released
Claims or Released Claims against any Shareholder Released Party or Released Party in
any forum whatsoever, subject in all respects to Section 9.02 of the Master Settlement
Agreement. The releases provided for herein (including the term "Shareholder Released
K-2
Claims" and "Released Claims") are intended by the Governmental Entity and its
Subdivision Releasors to be broad and shall be interpreted so as to give the Shareholder
Released Parties and Released Parties the broadest possible release of any liability relating
in any way to Shareholder Released Claims and Released Claims and extend to the full
extent of the power of the Governmental Entity to release claims. The Agreement shall be
a complete bar to any Shareholder Released Claim and Released Claims.
10. To the maximum extent of the Governmental Entity's power, the Shareholder Released
Parties and the Released Parties are, as of the Effective Date, hereby released and
discharged from any and all Shareholder Released Claims and Released Claims of the
Subdivision Releasors.
11. The Governmental Entity hereby takes on all rights and obligations of a Participating
Subdivision as set forth in the Agreement.
12. In connection with the releases provided for in the Agreement, each Governmental Entity
expressly waives, releases, and forever discharges any and all provisions, rights, and
benefits conferred by any law of any state or territory of the United States or other
jurisdiction, or principle of common law, which is similar, comparable, or equivalent to
§ 1542 of the California Civil Code, which reads:
General Release; extent. A general release does not extend to claims that
the creditor or releasing party does not know or suspect to exist in his or her
favor at the time of executing the release that, if known by him or her, would
have materially affected his or her settlement with the debtor or released
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 Shareholder Released Claims or such
other Claims released pursuant to this release, but each Governmental Entity hereby
expressly waives and fully, finally, and forever settles, releases and discharges, upon the
Effective Date, any and all Shareholder Released Claims or such other Claims released
pursuant to this release that may exist as of such date but which Releasors do not know or
suspect to exist, whether through ignorance, oversight, error, negligence or through no fault
whatsoever, and which, if known, would materially affect the Governmental Entities'
decision to participate in the Agreement.
13. Nothing herein is intended to modify in any way the terns of the Agreement, to which
Governmental Entity hereby agrees. To the extent any portion of this Participation and
Release Form not relating to the release of, or bar against, liability is interpreted differently
from the Agreement in any respect, the Agreement controls.
14. Notwithstanding anything to the contrary herein or in the Agreement, (x) nothing herein
shall (A) release any Excluded Claims or (B) be construed to impair in any way the rights
and obligations of any Person under the Agreement; and (y) the Releases set forth herein
shall be subject to being deemed void to the extent set forth in Section 9.02 of the Master
Settlement Agreement.
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I have all necessary power and authorization to execute this Participation and Release Form
on behalf of the Governmental Entity.
Signature:
Name. Alvin Fruga
Title: Mayor
Date: 9/16/2025
K-4
EXHIBIT K
Subdivision Participation and Release Form
Governmental Entity: City of Owasso
State: Oklahoma
Authorized Official: Alvin Fruga, Mayor
Address 1:200 South Maln Street
Address 2:
City, State, Zip: Owasso, OK, 74055
Phone: 918-376.1500
Email: afruga@cityofowasso.com
The governmental entity identified above ("Governmental Entity"), in order to obtain and
in consideration for the benefits provided to the Governmental Entity pursuant to the Settlement
Agreement dated April 4, 2025 ("Sun Settlement"), and acting through the undersigned authorized
official, hereby elects to participate in the Sun Settlement, release all Released Claims against all
Released Entities, and agrees as follows.
The Governmental Entity is aware of and has reviewed the Sun Settlement, understands
that all terms in this Participation and Release Form have the meanings defined therein,
and agrees that by executing this Participation and Release Form, the Governmental Entity
elects to participate in the Sun Settlement and become a Participating Subdivision as
provided therein.
2. The Governmental Entity shall promptly, and in any event no later than 14 days after the
Reference Date and prior to the filing of the Consent Judgment, dismiss with prejudice any
Released Claims that it has filed. With respect to any Released Claims pending in In re
National Prescription Opiate Litigation, MDL No. 2804, the Governmental Entity
authorizes the Plaintiffs' Executive Committee to execute and file on behalf of the
Governmental Entity a Stipulation of Dismissal with Prejudice substantially in the form
found at https://nationalol2ioidsettlement.com/additional-settlements/.
3. The Governmental Entity agrees to the terms of the Sun Settlement pertaining to
Participating Subdivisions as defined therein.
4. By agreeing to the terms of the Sun Settlement and becoming a Releasor, the Governmental
Entity is entitled to the benefits provided therein, including, if applicable, monetary
payments beginning after the Effective Date.
5. The Governmental Entity agrees to use any monies it receives through the Sun Settlement
solely for the purposes provided therein.
6. The Governmental Entity submits to the jurisdiction of the court in the Governmental
Entity's state where the Consent Judgment is filed for purposes limited to that court's role
as provided in, and for resolving disputes to the extent provided in, the Sun Settlement.
K-1
The Governmental Entity likewise agrees to arbitrate before the National Arbitration Panel
as provided in, and for resolving disputes to the extent otherwise provided in, the Sun
Settlement.
7. The Governmental Entity has the right to enforce the Sun Settlement as provided therein.
8. The Governmental Entity, as a Participating Subdivision, hereby becomes a Releasor for
all purposes in the Sun Settlement, including without limitation all provisions of Section X
(Release), and along with all departments, agencies, divisions, boards, commissions,
districts, instrumentalities of any kind and attorneys, and any person in his or her official
capacity whether elected or appointed to serve any of the foregoing and any agency, person,
or other entity claiming by or through any of the foregoing, and any other entity identified
in the definition of Releaser, provides for a release to the fullest extent of its authority. As
a Releasor, the Governmental Entity hereby absolutely, unconditionally, and irrevocably
covenants not to bring, file, or claim, or to cause, assist or permit to be brought, filed, or
claimed, or to otherwise seek to establish liability for any Released Claims against any
Released Entity in any forum whatsoever. The releases provided for in the Sun Settlement
are intended by the Parties to be broad and shall be interpreted so as to give the Released
Entities the broadest possible bar against any liability relating in any way to Released
Claims and extend to the full extent of the power of the Governmental Entity to release
claims. The Sun Settlement shall be a complete bar to any Released Claim.
9. The Governmental Entity hereby takes on all rights and obligations of a Participating
Subdivision as set forth in the Sun Settlement.
10. In connection with the releases provided for in the Sun 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
materially affect the Governmental Entities' decision to participate in the Sun Settlement.
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11. Nothing herein is intended to modify in any way the terms of the Sun Settlement, to which
Governmental Entity hereby agrees. To the extent this Participation and Release Form is
interpreted differently from the Sun Settlement in any respect, the Sun Settlement controls.
I have all necessary power and authorization to execute this Participation and Release Form
on behalf of the Governmental Entity.
Signature:
Name: Alvin Fruga
Title: Mayor
Date. 9/16/2025
K-3
EXHIBIT K
Subdivision Participation and Release Form
Governmental Entity: City of Owasso
State: Oklahoma
Authorized Official: Alvin Fruga, Mayor
Address 1:200 South Main Street
Address 2:
City, State, Zip: Owasso, OK, 74055
Phone: 918-376-1500
Email: afruga@cltyofowasso.com
The governmental entity identified above ("Governmental Entity"), in order to obtain and
in consideration for the benefits provided to the Governmental Entity pursuant to the Settlement
Agreement dated [date] ("Zydus Settlement"), and acting through the undersigned authorized
official, hereby elects to participate in the Zydus Settlement, release all Released Claims against
all Released Entities, and agrees as follows.
1. The Governmental Entity is aware of and has reviewed the Zydus Settlement, understands
that all terms in this Participation and Release Form have the meanings defined therein,
and agrees that by executing this Participation and Release Form, the Governmental Entity
elects to participate in the Zydus Settlement and become a Participating Subdivision as
provided therein.
The Governmental Entity shall promptly, and in any event no later than 14 days after the
Reference Date and prior to the filing of the Consent Judgment, dismiss with prejudice any
Released Claims that it has filed. With respect to any Released Claims pending in In re
National Prescription Opiate Litigation, MDL No. 2804, the Governmental Entity
authorizes the Plaintiffs' Executive Committee to execute and file on behalf of the
Governmental Entity a Stipulation of Dismissal with Prejudice substantially in the form
found at https://nationalopioidseftlement.com/additional-settlements/.
3. The Governmental Entity agrees to the terms of the Zydus Settlement pertaining to
Participating Subdivisions as defined therein.
4. By agreeing to the terms of the Zydus Settlement and becoming a Releasor, the
Governmental Entity is entitled to the benefits provided therein, including, if applicable,
monetary payments beginning after the Effective Date.
5. The Governmental Entity agrees to use any monies it receives through the Zydus
Settlement solely for the purposes provided therein.
6. The Governmental Entity submits to the jurisdiction of the court in the Governmental
Entity's state where the Consent Judgment is filed for purposes limited to that court's role
as provided in, and for resolving disputes to the extent provided in, the Zydus Settlement.
K-1
The Governmental Entity likewise agrees to arbitrate before the National Arbitration Panel
as provided in, and for resolving disputes to the extent otherwise provided in, the Zydus
Settlement.
7. The Governmental Entity has the right to enforce the Zydus Settlement as provided therein.
8. The Governmental Entity, as a Participating Subdivision, hereby becomes a Releasor for
all purposes in the Zydus Settlement, including without limitation all provisions of Section
X (Release), and along with all departments, agencies, divisions, boards, commissions,
districts, instrumentalities of any kind and attorneys, and any person in his or her official
capacity whether elected or appointed to serve any of the foregoing and any agency, person,
or other entity claiming by or through any of the foregoing, and any other entity identified
in the definition of Releasor, provides for a release to the fullest extent of its authority. As
a Releasor, the Governmental Entity hereby absolutely, unconditionally, and irrevocably
covenants not to bring, file, or claim, or to cause, assist or permit to be brought, filed, or
claimed, or to otherwise seek to establish liability for any Released Claims against any
Released Entity in any forum whatsoever. The releases provided for in the Zydus
Settlement are intended by the Parties to be broad and shall be interpreted so as to give the
Released Entities the broadest possible bar against any liability relating in any way to
Released Claims and extend to the full extent of the power of the Governmental Entity to
release claims. The Zydus Settlement shall be a complete bar to any Released Claim.
9. The Governmental Entity hereby takes on all rights and obligations of a Participating
Subdivision as set forth in the Zydus Settlement.
10. In connection with the releases provided for in the Zydus 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 parry does not know or suspect to exist in his or her
favor at the time of executing the release that, if known by him or her would
have materially affected his or her settlement with the debtor or released
party.
A Releasor may hereafter discover facts other than or different from those which it knows,
believes, or assumes to be true with respect to the Released Claims, but each Governmental
Entity hereby expressly waives and fully, finally, and forever settles, releases and
discharges, upon the Effective Date, any and all Released Claims that may exist as of such
date but which Releasors do not know or suspect to exist, whether through ignorance,
oversight, error, negligence or through no fault whatsoever, and which, if known, would
materially affect the Governmental Entities' decision to participate in the Zydus
Settlement.
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11. Nothing herein is intended to modify in any way the terms of the Zydus Settlement, to
which Governmental Entity hereby agrees. To the extent this Participation and Release
Form is interpreted differently from the Zydus Settlement in any respect, the Zydus
Settlement controls.
I have all necessary power and authorization to execute this Participation and Release Form
on behalf of the Governmental Entity.
Signature:
Name: Alvin Fruga
Title. Mayor
Date: 9/16/2025
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