TC Resolution 24-21 Ratifying the Approval of National Opioid Settlement with KrogerA
Avon
COLORADO
RESOLUTION 24-21
RATIFYING APPROVAL OF NATIONAL
OPIOID SETTLEMENT WITH KROGER
WHEREAS, the Town of Avon ("Town") is a home rule municipality of the State of Colorado
and is empowered to adopt policies, take action and approve agreements by Resolution; and
WHEREAS, the Town is participating, along with a great many other cities and counties in
Colorado, in a joint litigation against manufaturers and disributors of opioid medications seeking to
recover resources to help the Town deal with fallout from the ongoing nationwide opioid crisis,
which has been highly destructive to the lives and livelihoods of the residents of Avon and has
taxed Town services, particularly burdening the Town's already stressed emergency response and
recreation services; and
WHEREAS, the Town Council ("Council") has previously approved a Memorandum of
Understanding ("MOU") with the Colorado Attorney General's Office and many of the most
important municipal and county stakeholders in the State of Colorado; and
WHEREAS, this MOU set forth a consistent method for governing how any settlement funds
from the ongoing opioid litigation are to be distributed and managed among the state, local and
municipal governments to most effectively respond to the ongoing opioid crisis, including several
previously approved settlements, and the currently proposed Kroger settlement; and
WHEREAS, approving the Kroger settlement in its current form will provide the Town with
additional and substantial funds which can be used in accordance with the MOU to respond to the
opioid crisis and provide desparately needed services to the residents of the Town of Avon and its
neighboring region; and
WHEREAS, the forms approving the Kroger settlement were due on August 12, 2024, the day
before this regular Council meeting; and,
WHEREAS, due to the Council's previous support and approval of the MOU with the Colorado
Attorney General's Office, as well as several other previously approved similar settlements, the
Town Manager has signed the attached forms; and
WHEREAS, the Council finds it appropriate and beneficial to ratify such approval of the Kroger
settlement in its attached form.
NOW, THEREFORE, BE IT RESOLVED BY THE TOWN OF AVON that the Avon Town
Council hereby as follows:
1. The Kroger Settlement Participation Forms attached hereto are hereby formally approved and
the execution of same is authorized.
Resolution 24-21 Ratifying Approval of National Opooid Settlement with Kroger
August 13, 2024
Page 1 of 2
2. The recently signed Kroger Settlement Participation Forms and the approval of the National
Opioid Settlement with Kroger are hereby ratified.
ADOPTED on August 13, 2024 by the AVON TOWN COUNCIL.
N OF Alr0
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By: Attest: SEAL•:
Amy Phillips, Mayor Miguel Ja gui Casanue, twn Clerk•'�CORA��
Resolution 24-21 Ratifying Approval of National Opioid Settlement with Kroger
August 13, 2024
Page 2 of 2
Docusign Envelope ID: 3C1B5E1F-B7EB-4751-B36C-AFABA3A1D180
New National Opioids Settlement: Kroger
Opioids Implementation Administrator
opioidsparticipation()rubris. com
Avon town, CO
Reference Number: CL-790103
TO COLORADO LOCAL POLITICAL SUBDIVISIONS;
THIS PACKAGE CONTAINS DOCUMENTATION FOR COLORADO LOCAL
POLITICAL SUBDIVISIONS TO PARTICIPATE IN THENEW NATIONAL OPIOIDS
SETTLEMENT WITH KROGER. YOU MUST TAKE ACTION IN ORDER TO
PARTICIPATE.
Deadline: August 22, 2024
A new proposed national opioids settlement ("New National Opioids Settlement")
has been reached with The Kroger Co. ("Settling Defendant"). This Participation
Package is a follow-up communication to the Notice of National Opioids Settlement
recently received electronically by your subdivision.
You are receiving this Participation Package because Colorado is participating in the
Kroger settlement.
Thanks to the collaboration of Colorado's counties and municipalities, Colorado
maximized its settlement proceeds from previous opioid settlements, and we are
now asking that you review and sign -on to this settlement so that Colorado can
maximize its share of these funds.
All opioid settlement funds that are received as a result of the settlement will follow
the same Colorado Opioid Settlement Memorandum of Understanding that was
signed in 2021. Completing the participation forms does not change your decision
to "opt -out" to direct funds to the Region, or to "opt -in" to receive your direct
allocation.
To review your Colorado local government decisions to receive or redirect funds,
please see the Colorado Opioid Settlement Dashboard Local Government page at:
coag.gov/opioids/dashboard/local.
This electronic envelope contains:
The Participation Form for the Kroger settlement, including a release of any
claims.
The Participation Form must be executed, without alteration, and
submitted on or before August 12, 2024, in order for your subdivision to
be considered for initial participation calculations and payment eligibility.
Based upon subdivision participation forms received on or before August 12, 2024,
the subdivision participation rate will be used to determine whether participation is
Docusign Envelope ID: 3C1B5E1F-B7EB-4751-B36C-AFABA3A1D180
sufficient for the settlement to move forward and whether a state earns its
maximum potential payment under the settlement. If the settlement moves
forward, your release will become effective. If a settlement does not move forward,
that release will not become effective.
Any subdivision that does not participate cannot directly share in the settlement
funds, even if the subdivision's state is settling and other participating subdivisions
are sharing in settlement funds. Any subdivision that does not participate may also
reduce the amount of money for programs to remediate the opioid crisis in its state.
Please note, a subdivision will not necessarily directly receive settlement funds by
participating; decisions on how settlement funds will be allocated within a state are
subject to intrastate agreements or state statutes.
You are encouraged to discuss the terms and benefits of the New National Opioids
Settlement with your counsel, your Attorney General's Office, and other contacts
within your state. Many states are implementing and allocating funds for this new
settlement the same as they did for the prior opioids settlements with McKesson,
Cardinal, Cencora (formerly AmerisourceBergen), J&J/Janssen, Teva, Allergan, CVS,
Walgreens, and Walmart but states may choose to treat this settlement differently.
Information and documents regarding the New National Opioids Settlement and
how it is being implemented in your state and how funds will be allocated within
your state can be found on the national settlement website at
https:/Inationalopioidsettlement.com/. This website will be supplemented as
additional documents are created.
How to return signed forms:
There are three methods for returning the executed Participation Form and any
supporting documentation to the Implementation Administrator:
(1) Electronic Signature via DocuSign: Executing the Participation Form
electronically through DocuSign will return the signed form to the
Implementation Administrator and associate your form with your
subdivision's records. Electronic signature is the most efficient method for
returning the Participation Form, allowing for more timely participation and
the potential to meet higher settlement payment thresholds, and is therefore
strongly encouraged.
(2) Manual Signature returned via DocuSign: DocuSign allows forms to be
downloaded, signed manually, then uploaded to DocuSign and returned
automatically to the Implementation Administrator. Please be sure to
complete all fields. As with electronic signature, returning a manually signed
Participation Form via DocuSign will associate your signed forms with your
subdivision's records.
(3) Manual Signature returned via electronic mail: If your subdivision is unable to
return an executed Participation Form using DocuSign, the signed
Participation Form may be returned via electronic mail to
opioidsparticipationCcbrubris.com. Please include the name, state, and
Docusign Envelope ID: 3C1B5E1F-B7EB-4751-B36C-AFABA3A1D180
reference ID of your subdivision in the body of the email and use the subject
line Settlement Participation Form - [Subdivision Name, Subdivision State] -
[Reference ID].
Detailed instructions on how to sign and return the Participation Form, including
changing the authorized signer, can be found at
https:Hnationalopioidsettlement.com. You may also contact
opioidsparticipation(arubris.com.
The sign -on period for subdivisions ends on August 12, 2024.
If you have any questions about executing the Participation Form, please contact
your counsel, the Implementation Administrator at opioidsparticipation(a-rubris.com,
or the Colorado Attorney General's Opioid Response Unit at Opioids(a)coag.gov or
720-508-6904.
Thank you,
New National Opioids Settlement Implementation Administrator
The Implementation Administrator is retained to provide the settlement notice
required by the New National Opioids Settlement and to manage the collection of
the Participation Form.
Docusign Envelope ID: 3C1B5E1F-B7EB-4751-B36C-AFABA3A1D180
Subdivision Participation and Release Form
Governmental Entity: Avon town
State: CO
Authorized Signatory: Eri C Heil
Address 1: 100 Mikaela way
Address 2:
City, State, Zip: Avon Colorado 81620
Phone: 970748-4004
Email: eheil@avon.org
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 March 22, 2024 ("Kroger Settlement"), and acting through the undersigned
authorized official, hereby elects to participate in the Kroger Settlement, release all Released
Claims against all Released Entities, and agrees as follows.
1. The Governmental Entity is aware of and has reviewed the Kroger 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 Kroger 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/.
3. The Governmental Entity agrees to the terms of the Kroger Settlement pertaining to
Participating Subdivisions as defined therein.
4. By agreeing to the terms of the Kroger 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 Kroger
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 Kroger
Settlement. The Governmental Entity likewise agrees to arbitrate before the National
o
Docusign Envelope ID: 3C1B5E1F-B7EB-4751-B36C-AFABA3A1D180
Arbitration Panel as provided in, and for resolving disputes to the extent otherwise
provided in, the Kroger Settlement.
7. The Governmental Entity has the right to enforce the Kroger Settlement as provided
therein.
8. The Governmental Entity, as a Participating Subdivision, hereby becomes a Releasor for
all purposes in the Kroger 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
their official capacity elected or appointed to serve any of the foregoing and any agency,
person, or other entity claiming by or through any of the foregoing, and any other entity
identified in the definition of Releasor, provides for a release to the fullest extent of its
authority. As a Releasor, the Governmental Entity hereby absolutely, unconditionally,
and irrevocably covenants not to bring, file, or claim, or to cause, assist or permit to be
brought, filed, or claimed, or to otherwise seek to establish liability for any Released
Claims against any Released Entity in any forum whatsoever. The releases provided for
in the Kroger 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 Kroger 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 Kroger Settlement.
10.In connection with the releases provided for in the Kroger 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 Kroger Settlement.
Docusign Envelope ID: 3C1B5E1F-B7EB-4751-B36C-AFABA3A1D180
11. Nothing herein is intended to modify in any way the terms of the Kroger Settlement, to
which Governmental Entity hereby agrees. To the extent this Participation and Release
Form is interpreted differently from the Kroger Settlement in any respect, the Kroger
Settlement controls.
I have all necessary power and authorization to execute this Participation and Release
Form on behalf of the Governmental Entity. Docu Signed by:
Signature:
Name: Eric Heil
Title: Town Manager
Date: 7/30/2024
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