CM-2025-227 - 9/19/2025 Docusign Envelope D. 140E0B5F-91B1-4186-AC4E-407DA448112B
EXHIBIT K
Secondary Manufacturers' Combined Subdivision Participation and Release Form
("Combined Participation Form")
Governmental Entity:Round Rock city State:TX
Authorized Official: ejae
Address 1: o?a2/ er}-
Address 2:
City,State,Zip: /1jj/,„,.4/ ,���p T,� 7iGG
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 each of the
settlements which are listed in paragraph 1 below(each a"Secondary Manufacturer's Settlement"
and collectively, "the Secondary Manufacturers' Settlements"), and acting through the
undersigned authorized official, hereby elects to participate in each of the Secondary
Manufacturers' Settlements,release all Released Claims against all Released Entities in each of the
Secondary Manufacturers' Settlements,and agrees as follows.
1. The Participating Entity hereby elects to participate in each of the following Secondary
Manufacturers' Settlements as a Participating Entity:
a. Settlement Agreement for Alvogen,Inc. dated April 4,2025.
b. Settlement Agreement for Apotex Corp. dated April 4,2025.
c. Settlement Agreement for Amneal Pharmaceuticals LLC dated April 4,2025.
d. Settlement Agreement for Hikma Pharmaceuticals USA Inc. dated April 4,2025.
e. Settlement Agreement for Indivior Inc. dated April 4,2025.
f. Settlement Agreement for Viatris Inc. ("Mylan")dated April 4,2025.
g. Settlement Agreement for Sun Pharmaceutical Industries,Inc. dated April 4,2025.
h. Settlement Agreement for Zydus Pharmaceuticals(USA)Inc. dated April 4,2025.
2. The Governmental Entity is aware of and has reviewed each of the Secondary
Manufacturers' Settlements, understands that all capitalized terms not defined in this
Combined Participation Form have the meanings defined in each of the Secondary
Manufacturers' Settlements, and agrees that by executing this Combined Participation
Form, the Governmental Entity elects to participate in each of the Secondary
Manufacturers' Settlements and become a Participating Subdivision as provided in each of
the Secondary Manufacturers' Settlements.
3. The Governmental Entity shall promptly, and in any event no later than 14 days after the
Reference Date and prior to the filing of the Consent Judgment,dismiss with prejudice any
Released Claims that it has filed against any Released Entity in each of the Secondary
Manufacturers' Settlements. With respect to any Released Claims pending in In re
National Prescription Opiate Litigation, MDL No. 2804, the Governmental Entity
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Docusign Envelope ID: 140E0B5F-91B1-4186-AC4E-407DA448112B
authorizes the Plaintiffs' Executive Committee to execute and file on behalf of the
Governmental Entity a Stipulation of Dismissal with Prejudice for each of the
manufacturers listed in paragraph 1 above substantially in the form found at
https://nationalopioidsettlement.com/additional-settlements/
4. The Governmental Entity agrees to the terms of each of the Secondary Manufacturers'
Settlements pertaining to Participating Subdivisions as defined therein.
5. By agreeing to the terms of each of the Secondary Manufacturers' Settlements and
becoming a Releasor,the Governmental Entity is entitled to the benefits provided therein,
including,if applicable,monetary payments beginning after the Effective Date.
6. The Governmental Entity agrees to use any monies it receives through each of the
Secondary Manufacturers' Settlements solely for the purposes provided therein.
7. The Governmental Entity submits to the jurisdiction of the court and agrees to follow the
process for resolving any disputes related to each Secondary Manufacturer's Settlement as
described in each of the Secondary Manufacturers' Settlements.'
8. The Governmental Entity has the right to enforce each of the Secondary Manufacturers'
Settlements as provided therein.
9. The Governmental Entity,as a Participating Subdivision,hereby becomes a Releasor for all
purposes in each of the Secondary Manufacturers' Settlements, including without
limitation all provisions related to release of any claims,'and along with all departments,
agencies, divisions, boards, commissions, districts, instrumentalities of any kind and
attorneys, and any person in his or her official capacity whether elected or appointed to
serve any of the foregoing and any agency,person,or other entity claiming by or through
any of the foregoing,and any other entity identified in the definition of Releasor,provides
for a release to the fullest extent of its authority. As a Releasor, the Governmental Entity
hereby absolutely,unconditionally,and irrevocably covenants not to bring,file,or claim,or
to cause, assist or permit to be brought, filed,or claimed,or to otherwise seek to establish
liability for any Released Claims against any Released Entity in each of the Secondary
Manufacturers' Settlements in any forum whatsoever. The releases provided for in each of
the Secondary Manufacturers' Settlements are intended by the Parties to be broad and shall
be interpreted so as to give the Released Entities in each of the Secondary Manufacturers'
Settlements the broadest possible bar against any liability relating in any way to Released
' See Settlement Agreement for Alvogen, Inc. Section VII.F.2; Settlement Agreement for Apotex Corp. Section
VII.F.2;Settlement Agreement for Amneal Pharmaceuticals LLC Section VII.F.2;Settlement Agreement for Hikma
Pharmaceuticals USA Inc.Section VII.F.2;Settlement Agreement for Indivior Section VI.F.2;Settlement Agreement
for Mylan Section VI.F.2;Settlement Agreement for Sun Pharmaceutical Industries,Inc.Section VII.F.2;Settlement
Agreement for Zydus Pharmaceuticals(USA)Inc.Section VII.F.2.
2 See Settlement Agreement for Alvogen,Inc.Section XI; Settlement Agreement for Amneal Pharmaceuticals LLC
Section X; Settlement Agreement for Apotex Corp. Section XI; Settlement Agreement for Hikma Pharmaceuticals
USA Inc. Section XI; Settlement Agreement for Indivior Section X; Settlement Agreement for Mylan Section X;
Settlement Agreement for Sun Pharmaceutical Industries, Inc. Section XI; Settlement Agreement for Zydus
Pharmaceuticals(USA)Inc.Section XI.
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Docusign Envelope ID. 140E0B5F-91B1-4186-AC4E-407DA448112B
Claims and extend to the full extent of the power of the Governmental Entity to release
claims. Each of the Secondary Manufacturers' Settlements shall be a complete bar to any
Released Claim against that manufacturer's Released Entities.
10. The Governmental Entity hereby takes on all rights and obligations of a Participating
Subdivision as set forth in each of the Secondary Manufacturers' Settlements.
11. In connection with the releases provided for in each of the Secondary Manufacturers'
Settlements,each Governmental Entity expressly waives,releases, and forever discharges
any and all provisions,rights,and benefits conferred by any law of any state or territory of
the United States or other jurisdiction, or principle of common law, which is similar,
comparable,or equivalent to§ 1542 of the California Civil Code,which reads:
General Release; extent. A general release does not extend to claims that
the creditor or releasing party does not know or suspect to exist in his or her
favor at the time of executing the release that,if known by him or her would
have materially affected his or her settlement with the debtor or released
part'.
A Releasor may hereafter discover facts other than or different from those which it knows,
believes,or assumes to be true with respect to the Released Claims in each of the Secondary
Manufacturers' Settlements, but each Governmental Entity hereby expressly waives and
fully,finally,and forever settles,releases and discharges,upon the Effective Date,any and
all Released Claims that may exist as of such date but which Releasors do not know or
suspect to exist,whether through ignorance,oversight,error,negligence or through no fault
whatsoever, and which, if known, would materially affect the Governmental Entities'
decision to participate in each of the Secondary Manufacturers' Settlements.
12.The Governmental Entity understands and acknowledges that each of the Secondary
Manufacturers' Settlements is an independent agreement with its own terms and
conditions. Nothing herein is intended to modify in any way the terms of any of the
Secondary Manufacturers'Settlements,to which Governmental Entity hereby agrees,aside
from the exceptions in paragraph 13 below. To the extent this Combined Participation
Form is interpreted differently from any of the Secondary Manufacturers' Settlements in
any respect,the individual Secondary Manufacturer's Settlement controls.
13.For the avoidance of doubt, in the event that some but not all of the Secondary
Manufacturers' Settlements proceed past their respective Reference Dates,all releases and
other commitments or obligations shall become void only as to those Secondary
Manufacturers'Settlements that fail to proceed past their Reference Dates.All releases and
other commitments or obligations (including those contained in this Combined
Participation Form) shall remain in full effect as to each Secondary Manufacturer's
Settlement that proceeds past its Reference Date, and this Combined Participation Form
need not be modified, returned, or destroyed as long as any Secondary Manufacturer's
Settlement proceeds past its Reference Date.
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Docusign Envelope ID:140E0B5F-91 B1-4186-AC4E-407DA448112B
I have all necessary power and authorization to execute this Combined Participation Form
on behalf of the Governmental Entity. .�
Signature:
Name: Brooks Ben'-e- 1
Title: C*'j Mafie(
Date: cti )1 1 0
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