HomeMy WebLinkAbout2025-081-09/02/2025-APPROVING PARTICIPATION IN THE SETTLEMENT WITH AN ADDITIONAL OPIOID DEFENDANT, PURDUE, AND A RELATEDRESOLUTION 2025-081
OF THE COUNCIL OF THE CITY OF FORT COLLINS
APPROVING PARTICIPATION IN THE SETTLEMENT WITH AN
AD DITIONAL OPIOID DEFENDANT, PURDUE, AND A RELATED
WAIVER OF CLAIMS
A.Communities throughout the State of Colorado, including the City of Fort
Collins ("City), are suffering from an epidemic of opioid addiction.
B.The opioid epidemic has not only affected individuals and families across
the country, but it has also burdened the local and state governments charged with
providing the services needed to address the wave of addiction.
C.Local and state governments across the nation, including in Colorado, have
filed lawsuits against opioid manufacturers, distributors, and pharmacies for creating the
opioid epidemic.
D.The parties to the various opioid lawsuits have been negotiating settlement
agreements to resolve the litigation which include incentive payments for maximizing
participation by local governments.
E.Through extensive negotiations, local governments and the Colorado
Attorney General's Office negotiated a Memorandum of Understanding to govern how
opioids settlement funds will be allocated in Colorado, to maximize recover y from the
variety of lawsuits filed by the state and local governments across the nation ("MOU"),
along with the Subdivision Settlement Participation Forms to address opioid defendants
Johnson & Johnson, AmerisourceBergen, Cardinal Health, and McKesson.
F.On December 7, 2021, the City Council approved Resolution 2021-113,
approving participation in the Colorado Opioids Settlement and authorizing execution of
related agreements, which were signed and submitted to the Colorado Attorney General
in December 2021.
G.On May 3, 2022, the City Council approved Resolution 2022-055,
authorizing the execution of an intergovernmental agreement regarding regional opioids
settlement implementation ("IGA") and designating a City representative to the Larimer
Regional Opioid Council. Resolution 2022-055 appointed Social Sustainability
Department Director, Beth Yonce, as the City's representative to the Larimer Regional
Opioid Council until such time as the City Manager designates a different City
representative. Assistant City Manager Rupa Venkatesh has served as the alternate
representative and will replace Ms. Yonce as the City Manager's appointee.
H.The City entered into the IGA and it has since been amended to add
participation by the Town of Estes Park, pursuant to City Council's Resolution 2023-011,
adopted on January 17, 2023.
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I.On March 21, 2023, the City Council adopted Resolution 2023-028,
approving additional settlements with opioid defendants Teva, Allergan, Walmart, CVS
and Walgreens.
J.On August 20, 2024, the City Council approved Resolution 2024-096
approving additional settlements with opioid defendant Kroger.
K.A national settlement has now been negotiated on behalf of the State of
Colorado and participating local governments with additional opioid defendant, Purdue,
and the City may participate in this settlement and receive settlement payments by
executing a participation form for this opioid defendant, including an associated waiver of
claims.
L.The City desires to participate in the Colorado opioids settlement to
increase recoveries for Colorado government entities and so the City is eligible to receive
settlement funds to be used for approved purposes to abate the opioid epidemic as
defined in the MOU for the benefit of the residents of the City.
M.Accordingly, the City Council desires to approve participation in the Purdue
settlement and authorize execution of a Purdue participation form consistent in content
with the sample form attached to this Resolution as Exhibit A and incorporated herein by
this reference.
In light of the foregoing recitals, which the Council hereby makes and adopts as
determinations and findings, BE IT RES OLVED BY THE COUNCIL OF THE CITY OF
FORT COLLINS as follows:
Section 1. The City Council approves the City's part icipation in the Purdue
settlement.
Section 2. The Mayor is authorized and directed to execute on behalf of the City
a participation form consistent with th is Resolution and in a final form recommended and
presented by the City Manager and approved by the City Attorney.
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Passed and adopted on September 2, 2025.
ATTEST:
Effective Date: September 2, 2025
Approving Attorney: Jenny Lopez Filkins
Exhibit: Exhibit A -Participation Form
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EXHIBIT A TO RESOLUTION 2025-081
Docusign Envelope ID: 651 B90DA-9179-45BF-9E6A-7B 1 B8CBCCAC9
EXHIBITK
Subdivision Participation and Release Form
Governmental Entity: Fort Collins city
Authorized Signatory:
Address 1:
Address 2:
City, State, Zip:
Phone:
Email: .
I State: CO
The governmental entity identified above ("Governmental Rti::,), in order to obtain and in consideration for the benefits provided to the Government;�;i·;sp ·uant to that certain Governmental Entity & Shareholder Direct Settlement Agr:.eem nt acco panying this participation form (the "Agreement")1 , and acting through the under-igned • thorized official, hereby elects to participate in the Agreement, grant th eleases set fo l5elow, and agrees as follows.
1.The Governmental Entity is aware of gi·eement, and agrees that by executing this Participation and R emmental Entity elects to participate in the Agreement an %t. atmg u:, ivision as provided therein.
2.The Governmental Entity shal after the Effective Date, and prior to the filing of the Consent Judgment,juclice any Shareholder Released Claims and Released Claims that it espect to any Shareholder Released Claims and Released Claims •• I Prescription Opiate Litigation, MDL No. 2804, the Governmenta o ••e Plaintiffs' Executive Committee to execute and file on behalf of t ntity a Stipulation of Dismissal with Prejudice substantiall in ti. n . ps://nationalopioidsettlement.com.
3.The povernmental.Enti agrees to the terms of the Agreement pertaining to ParticipatingSubdivisions ascl,2ed•tl1erei n,
4.By agrcci1� to tli terms of the Agreement and becoming a Releasor, the GovernmentalEntity 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 Agreementsolely for the purposes provided therein.
6.The Governmental Entity submits to the jurisdiction of the court in the GovernmentalEntity's state where the Consent Judgment is filed for purposes limited to that court's roleas and to the extent provided in, and for resolving disputes to the extent provided in, the
1 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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EXHIBIT A TO RESOLUTION 2025-081
Docusign Envelope ID: 651 B90DA-9179-45BF-9E6A-7B 1 B8CBCCAC9
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 En tity 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 forcgoiJ1 ,and any agency, person,
or other entity claiming by or through any of the foregoing, aoi:l any other entity identified
in the definition of Subdivision Rclcasor, to the maximumie ·tent o '· authority, for good
and valuable consideration, the adequacy of which is hereoy, con m1ed, the Shareholder
Released Parties and Released Parties arc, as of the Effective Date, her y released and
forever discharged by the Governmental Entity and its Subdivision eleasors from: any
and all Causes of Action, including, without limit tion, any Estate Gause of Action and any
claims that the Governmental Entity or its Subdivision,Releasor would have presently or
in the future been legally entitled to assert in its o n�fit (whether individually or
collectively), notwithstanding section 15 2 of the Californ·a Civil Code or any law of any
jurisdiction that is similar, compar ble or eHui ent thereto (which shall conclusively be
deemed waived), whether existing �er inafter arising, in each case, (A) directly or
indirectly based on, arising out of, t'i any Na relating to or concerning, in whole or in
part, (i) the Debtors, as such Entitie.;\exi-s ed ptior to or after the Petition Date, and their
Affiliates, (ii) the Estate , iii) the Cha ter l Cases, or (iv) Covered Conduct and (B) as to
which any conduct, omission r ia ility of any Debtor or any Estate is the legal cause or is
otherwise a lega
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y_ relevant factor (eaeh such release, as it pertains to the Shareholder
Released Parties, tti;e "Sharehol er Released Claims", and as it pe11ains to the Released
Parties other than t e S re older Released Parties, the "Released Claims"). For the
avoidance of doubt and :v ithout limiting the foregoing: the Shareholder Released Claims
and I\e1eased Claims include any Cause of Action that has been or may be asserted against
any SHareholdec leased 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, stat or local action or proceeding (whether judicial, arbitral, or
administraf ve 1'<.} directly or indirectly based on, arising out of, or in any way relating to
or concerning, in whole or in part, (i) the Debtors, as such Entities existed prior to or after
the Petition Date, and their Affiliates, (ii) the Estates, (iii) the Chapter 11 Cases, or (iv)
Covered Conduct and (B) as to which any conduct, omission or liability of any Debtor or
any Estate is the legal cause or is otherwise a legally relevant factor.
9.As a Releasor, the Governmental Entity hereby absolutely, unconditionally, and
in-evocably 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 f01um whatsoever, subject in all respects to Section 9.02 of the Master Settlement
Agreement. The releases provided for herein (including the term "Shareholder Released
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EXHIBIT A TO RESOLUTION 2025-081
Docusign Envelope ID: 651 B90DA-9179-45BF-9E6A-781 B8CBCCAC9
Claims" and "Released Claims") are intended by the Governmental Entity and its
Subdivision Releasers 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 Releasers. _i
11.The Governmental Entity hereby takes on all rights anct/ob{gations of a Participating
Subdivision as set forth in the Agreement.
12.In connection with the releases provided for in the Agreement, ea h �mental Entity
expressly waives, releases, and forever discha� any and al rovisions, rights, and
benefits con ferred by any law of any staJe-o • ter itory of tie Un.ited Sta tes or other
jurisdiction, or principle of conunon la (whioJ.1{ s1 ilar, co para
.
ble, or equivalent to
§l 542 of the California Civil Code, �-e 1 read!(General Release; extent. Age eral relea .e does not extend to claims that the creditor or releasing party doe 1ot kQow or suspect to exist in his or her
favor at the time of executing tH ·elea e tnat, if known by him or her, would
have materially affected his or �\ se tleme1 t with the debtor or released party. '-_� �
A Releaser may heteafter d��er fact other than or different from those which it knows,
believes, or assumes o be true w-:i$ respect to the Shareholder Released Claims or such
other Claims released 1).,mant o this release, but each Governmental Entity hereby
expressly, wa�es and fi ly, final y, and forever settles, releases and discharges, upon the
Effcct"ve Date, any ancl all Shareholder Released Claims or such other Claims released
pun;uant to tl�e e-se t' at may exist as of such date but which Releasors do not know or
suspect-to exist, whet ier through ignorance, oversight, error, negligence or through no fault
whatsoeve� and tiich, 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 tenns of the Agreement, to which
Governmental Entity hereby agrees. To the extent any portion of this Participation and
Release Fonn 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 fo11h 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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EXHIBIT A TO RESOLUTION 2025-081
Docusign Envelope ID: 651890DA-9179-45BF-9E6A-78188CBCCAC9
I have all necessary power and authorization to execute this Paiiicipation and Release Form
on behalf of the Governmental Entity.
Signature:
Name:
Title:
Date:
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