Agenda 09/09/2025 Item #16D 3 (To ensure Collier County has the ability to participate in the New National Opioids Settlement funds)9/9/2025
Item # 16.D.3
ID# 2025-2547
Executive Summary
Recommendation to approve and authorize the County Manager to electronically sign and submit the required
Participation Forms and any additional forms upon their arrival for the Purdue Direct Settlement # CL-1748159, and
Rubris Settlement #CL-1770333 (Alvogen, Amneal, Apotex, Hikma, Indivior, Mylan, Sun and Zydus) to allow Collier
County to ‘opt in’ to the New National Opioid Settlement.
OBJECTIVE: To ensure Collier County has the ability to participate in the New National Opioids Settlement funds to
continue addressing the opioid epidemic and advancing Collier County’s strategic objective of enhancing access health,
wellness and human services.
CONSIDERATIONS: New National Opioids Settlements have been reached with Purdue (and the Sackler family
estate), reference #CL-1748159 and Rubris (Alvogen, Amneal, Apotex, Hikma, Indivior, Mylan, Sun and Zydus),
reference #CL-1770333.
Any subdivision that does not participate cannot directly share in any of the settlement funds, even if the subdivision’s
state is settling and other participating subdivisions are sharing in settlement funds. If the state does not participate in a
particular Settlement, the subdivisions in that state are not eligible to participate in that Settlement. Florida is
participating in these settlements.
The proposed Purdue settlement has been reached with Purdue and the Sackler family. This is being implemented in
connection with Purdue’s bankruptcy proceedings, and consists of, among other things, a settlement of Purdue’s claims
against the Sackler’s and certain other parties (referred to as the “Purdue Estate Settlement”), and settlements of direct
claims against the Sackler’s held by States, local governments and other creditors (collectively, the “Purdue Direct
Settlement”, and together with the Estate Settlement, the “Purdue Settlement”).
The Rubris, another proposed nationwide settlement, has been reached that would resolve opioid litigation brought by
states, local political subdivisions, and special districts against eight opioids manufacturers, Alvogen, Amneal, Apotex,
Hikma, Indivior, Mylan, Sun, and Zydus (the “Manufacturers”). The Settlements require the settling Manufacturers to
pay hundreds of millions of dollars to abate the opioid epidemic. The Settlements will provide a maximum of
approximately $720 million in cash to participating states and subdivisions to remediate and abate the impacts of the
opioid crisis. The Settlements also contain injunctive relief governing opioid marketing, sale, distribution, and/or
distribution practices and require the Manufacturers to implement safeguards to prevent diversion of prescription
opioids.
Based upon Purdue subdivision participation forms received, the County is required on or before September 30, 2025, to
electronically sign and submit all documents. Once the County submits the required paperwork the subdivision
participation rate will be used to determine whether participation is sufficient for the Purdue Settlement to move forward
and whether a state earns its maximum potential payment under the Purdue Direct Settlement. If the Purdue Settlement
moves forward and goes into effect, then the release of funds will become effective. If the Purdue Settlement does not
move forward, then the release will not become effective.
The participation forms for the Rubris settlement are in process of receipt and must be submitted electronically on or
before October 8, 2025.
The funding for each of the above Settlements amounts is dependent upon the participation by states and
subdivisions/territories. An executive summary accompanied by a budget amendment will be brought to the Board once
funding amounts have been provided to accept funds.
Advances Collier County’s strategic objective of enhancing access health, wellness and human services.
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9/9/2025
Item # 16.D.3
ID# 2025-2547
FISCAL IMPACT: The recommended actions described in this Executive Summary have no fiscal impact associated
with them. Should funds be awarded in the future, an Executive Summary and Budget Amendment will be brought to
the Board for approval.
GROWTH MANAGEMENT IMPACT: There is no Growth Management impact associated with this item.
LEGAL CONSIDERATIONS: This item has been reviewed by the County Attorney, is approved as to form and
legality and requires a majority vote for Board approval. -JAK
RECOMMENDATIONS: To approve and authorize the County Manager to electronically sign and submit the required
Participation Forms and any additional forms upon their arrival for the Purdue Direct Settlement # CL-1748159, and
Rubris Settlement #CL-1770333 (Alvogen, Amneal, Apotex, Hikma, Indivior, Mylan, Sun and Zydus) to allow Collier
County to ‘opt in’ to the New National Opioid Settlement.
PREPARED BY: Carolyn Noble, Grant Coordinator Community and Human Services
ATTACHMENTS:
1. Purdue Participation Packet 7.28.25
2. Rubris national_opioid_settlement_notice_settlement_overview
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New National Opioids Settlement: Purdue
Opioids Implementation Administrator
opioidsparticipation@rubris.com
COLLIER COUNTY, FL
Reference Number: CL-1748159
TO LOCAL POLITICAL SUBDIVISIONS:
THIS PACKAGE CONTAINS DOCUMENTATION TO PARTICIPATE IN THE NEW
NATIONAL OPIOIDS SETTLEMENT. YOU MUST TAKE ACTION IN ORDER TO
PARTICIPATE.
Deadline: September 30, 2025
A new proposed national opioids settlement has been reached with Purdue (and
certain of its affiliates) and the Sackler family. This Participation Package is a follow-
up communication to the Notice of New National Opioids Settlement recently received
electronically by your subdivision.
The proposed settlement is being implemented in connection with Purdue’s
bankruptcy proceedings, and consists of, among other things, a settlement of
Purdue’s claims against the Sacklers and certain other parties (referred to as the
“Purdue Estate Settlement”), and settlements of direct claims against the Sacklers
held by States, local governments and other creditors (collectively, the “Purdue Direct
Settlement”, and together with the Estate Settlement, the “Purdue Settlement”). The
Purdue Direct Settlement for States and local governments is documented in the
Governmental Entity and Shareholder Direct Settlement Agreement.
You are receiving this Participation Package because all eligible States and territories,
including the State of Florida, are participating in the Purdue Direct Settlement.
This electronic envelope contains:
The Participation Form for the Purdue Direct Settlement, including a release of
any claims
The Participation Form must be executed, without alteration, and submitted
on or before September 30, 2025, in order for your subdivision to be
considered for initial participation calculations and payment eligibility under
the Purdue Direct Settlement.
Based upon subdivision participation forms received on or before September 30,
2025, the subdivision participation rate will be used to determine whether
participation is sufficient for the Purdue Settlement to move forward and whether a
state earns its maximum potential payment under the Purdue Direct Settlement. If
the Purdue Settlement moves forward and goes effective, your release will become
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effective. If the Purdue Settlement does not move forward, that release will not
become effective.
Any subdivision that does not participate in the Purdue Direct Settlement cannot
directly share in the Purdue Direct Settlement funds, even if other subdivisions in the
state are participating and sharing in those Purdue Direct 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 Purdue Settlement funds by participating; decisions on
how Purdue 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 Purdue Settlement with
your counsel, your Attorney General’s Office, and other contacts within your state.
Many states are implementing and allocating funds for the Purdue Settlement the
same as they did for the prior opioids settlements but states may choose to treat the
Purdue Settlement differently.
Information and documents regarding the Purdue Settlement, including a complete
copy of the Governmental Entity and Shareholder Direct Settlement Agreement, 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://nationalopioidsettlement.com/purdue-sacklers-settlements/. 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 opioidsparticipation@rubris.com.
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Please include the name, state, and 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://nationalopioidsettlement.com/purdue-sacklers-settlements/. You may also
contact opioidsparticipation@rubris.com.
YOU MUST PARTICIPATE IN THE PURDUE DIRECT SETTLEMENT BY
RETURNING YOUR PARTICIPATION FORM IN ORDER TO RECEIVE THE
BENEFITS OF THE PURDUE SETTLEMENT.
Please note that this is NOT a solicitation or a request for subdivisions to
submit votes on the Purdue bankruptcy plan. This settlement package only
pertains to a decision to participate in the Purdue Direct Settlement. If you
receive a package to vote on the plan you should follow the applicable
instructions for voting. PLEASE NOTE THAT VOTING ON THE PLAN IS
SEPARATE FROM PARTICIPATION IN THE PURDUE DIRECT SETTLEMENT.
The sign-on period for subdivisions ends on September 30, 2025.
If you have any questions about executing the Participation Form, please contact
your counsel, the Implementation Administrator at
opioidsparticipation@rubris.com.
Thank you,
Implementation Administrator for the Purdue Direct Settlement
The Implementation Administrator is retained to provide the settlement notice
required by the Purdue Direct Settlement to manage the collection of the participation
forms for it.
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EXHIBIT K
Subdivision Participation and Release Form
Governmental Entity: COLLIER COUNTY State: FL
Authorized Signatory: /officialname_purdue/
Address 1: /address1_purdue/
Address 2: /address2_purdue/
City, State, Zip: /cit_pd/ /state_pd/ /zi_pd/
Phone: /phone_purdue/
Email: /email_purdue/
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 “Agreement”)1, 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 https://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 terms 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
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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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 Releasor, 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 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 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
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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 terms 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:/signer_1_purdue/
Name:/name_1_purdue/
Title:/title_1_purdue/
Date:/date_1_purdue/
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National Opioids Settlements: Alvogen, Amneal, Apotex, Hikma, Indivior, Mylan, Sun, Zydus
Opioids Implementation Administrator
opioidsparticipation@rubris.com
COLLIER COUNTY, FL
Rubris Reference Number: CL-1770333
TO LOCAL POLITICAL SUBDIVISIONS AND SPECIAL DISTRICTS:
THIS NOTICE CONTAINS IMPORTANT INFORMATION ABOUT NATIONAL OPIOID
SETTLEMENTS.
SETTLEMENT OVERVIEW
Proposed nationwide settlement agreements (“Settlements”) have been reached that would
resolve opioid litigation brought by states, local political subdivisions, and special districts
against eight opioids manufacturers, Alvogen, Amneal, Apotex, Hikma, Indivior, Mylan, Sun, and
Zydus (the “Manufacturers”). Local political subdivisions and special districts are referred to as
“subdivisions.”
The Settlements require the settling Manufacturers to pay hundreds of millions of dollars to
abate the opioid epidemic. The Settlements will provide a maximum of approximately $720
million in cash to participating states and subdivisions to remediate and abate the impacts of the
opioid crisis. Depending on participation by states and subdivisions, the Settlements require:
Alvogen to immediately pay up to approximately $19 million;
Amneal to pay up to approximately $74 million over 10 years, and to provide either
approximately $177 million of its generic version of the drug Narcan or up to an additional
approximately $44 million in cash;
Apotex to immediately pay up to approximately $65 million;
Hikma to immediately pay up to approximately $98 million, and to provide either
approximately $35 million of its naloxone product or up to an additional approximately $7
million in cash;
Indivior to pay up to approximately $75 million over five years, a portion of which, at the
election of the state, could be paid in the form of Indivior’s branded buprenorphine and/or
nalmefene products with a value of up to $140 million.;
Mylan to pay up to approximately $290 million over nine years;
Sun to immediately pay up to approximately $32 million; and
Zydus to immediately pay up to approximately $15 million.
The Settlements also contain injunctive relief governing opioid marketing, sale, distribution,
and/or distribution practices and require the Manufacturers to implement safeguards to prevent
diversion of prescription opioids.
Each of the proposed settlements has two key participation steps.
First, each eligible state decides whether to participate in each Settlement. A list of participating
states for each settlement can be found at https://nationalopioidsettlement.com/ .
Second, eligible subdivisions within each participating state decide whether to participate in
each Settlement. The more subdivisions that participate, the more funds flow to that state and
its subdivisions. Any subdivision that does not participate cannot directly share in any of the
settlement funds, even if the subdivision’s state is settling and other participating subdivisions
are sharing in settlement funds. If the state does not participate in a particular Settlement, the
subdivisions in that state are not eligible to participate in that Settlement.
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WHO IS RUBRIS INC. AND WHAT IS THE IMPLEMENTATION ADMINISTRATOR?
The Settlements provide that an Implementation Administrator will provide notice and manage
the collection of participation forms. Rubris Inc. is the Implementation Administrator for these
new Settlements and was also retained for the prior national opioid settlements.
WHY IS YOUR SUBDIVISION RECEIVING THIS NOTICE?
Your state has elected to participate in one or more of the Settlements, and your subdivision
may participate in those Settlements in which your state has elected to participate. This notice is
also sent directly to counsel for such subdivisions if the Implementation Administrator has their
information.
If you are represented by an attorney with respect to opioid claims, please contact them.
Subdivisions can participate in the Settlements whether or not they filed a lawsuit or are
represented.
WHERE CAN YOU FIND MORE INFORMATION?
Detailed information about the Settlements, including each settlement agreement, may be found
at: https://nationalopioidsettlement.com. This website also includes information about how the
Settlements are being implemented in most states and how funds will be allocated within your
state.
You are encouraged to review the settlement agreement terms and discuss the terms and
benefits with your counsel, your Attorney General’s Office, and other contacts within your state.
Information and documents regarding the Settlements and your state allocation can be found on
the settlement website at https://nationalopioidsettlement.com/.
Your subdivision will need to decide whether to participate in the proposed Settlements, and
subdivisions are encouraged to work through this process before the October 8, 2025 deadline.
HOW DO YOU PARTICIPATE IN THE SETTLEMENTS?
The Settlements require that you take affirmative steps to “opt in” to the Settlements.
In the next few weeks, you will receive documentation and instructions from the Implementation
Administrator or, in some cases, your Attorney General’s Office. In order to participate in a
settlement, a subdivision must sign and return the required Participation Form for that
settlement.
Please add the following email addresses to your “safe” list so emails do not go to spam / junk
folders: dse_na3@docusign.net and opioidsparticipation@rubris.com . Please monitor your
email for the Participation Forms and instructions.
All required documentation must be signed and returned on or before October 8, 2025.
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