Agenda 03/24/2026 Item #16D 2 (Approve and authorize the County Manager to electronically sign and submit the required Participation Forms and any additional forms upon their arrival for the Six Remnant Defendants National Opioid Settlement)3/24/2026
Item # 16.D.2
ID# 2026-615
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 Six Remnant Defendants National Opioid
Settlement (Remnant Defendants Settlement), CL-2023107, and to allow Collier County to ‘opt in’ to the Six Remnant
Defendants Settlement.
OBJECTIVE: To continue participation in the National Opioid Settlement to augment existing services while
advancing Collier County’s strategic objective of enhancing access health, wellness and human services.
CONSIDERATIONS: A new national opioid settlement has been reached with six regional distributor/dispenser
defendants (Associated Pharmacies, Inc., J M Smith Corporation, Louisiana Wholesale Drug Company, Inc., Morris and
Dickson Co., North Carolina Mutual Wholesale Drug Company, Inc., and United Natural Foods, Inc.). This is one
settlement agreement covering the combined settlement with the Six Remnant Defendants.
Collier County received notice on March 5, 2026, indicating that it has been determined to be an entity eligible to
participate in this Settlement. The proposed settlement will result in the Six Remnant Defendants paying a combined
$97,625,000.00 in cash to abate the opioid epidemic. Collier County, as an Eligible Entity, will result in a one-time
settlement payment to the County. The Settlement funds must be used for the Core Strategies and Approved Uses set
forth in Exhibit D of the Remnant Settlement Agreement, attached to this item.
The settlement requires the County to electronically sign and submit the Combined Subdivision Participation and
Release Form on or before May 4, 2026, in order to receive a funding allocation.
The funding allocation for the above Settlement amount is dependent upon the participation by all Eligible Entities
across the nation. Once funds are received, an executive summary, accompanied by a Budget Amendment, will be
presented to the Board for authorization.
To advance the Collier County’s strategic objective of enhancing access health, wellness and human services.
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
RECOMMENDATION(S): 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 Six Remnant Defendants National
Opioid Settlement (Remnant Defendants Settlement), CL-2023107, and to allow Collier County to ‘opt in’ to the Six
Remnant Defendants Settlement.
PREPARED BY: Carolyn Noble, Grant Coordinator, CHS
ATTACHMENTS:
1. notice_document
2. settlement_overview_six_remnant_defendants
3. Participation Form CAO Stamped 3.17
Page 4591 of 6641
To: COLLIER COUNTY, FL
Reference Number: CL-2023107
NOTICE OF NEW NATIONAL OPIOID SETTLEMENT
AND UPCOMING ACTION NEEDED TO PARTICIPATE:
MONDAY, May 4, 2026 , DEADLINE
A new national opioid settlement has been reached with six regional distributors/dispenser
defendants (Remnant Defendants Settlement): Associated Pharmacies, Inc. (and
American Associated Pharmacies); J M Smith Corporation; Louisiana Wholesale Drug
Company, Inc.; Morris and Dickson Co.; North Carolina Mutual Wholesale Drug
Company, Inc.; and United Natural Foods, Inc. (including is subsidiaries SuperValu and
Advantage Logistics) (Six Remnant Defendants).
This is the formal Notice required by the Remnant Defendants Settlement. You are
receiving this Notice because your entity is entitled to participate (Eligible Entity). Please
read this Notice and the attached Settlement Overview carefully. The Settlement
Overview provides additional information concerning this new national opioid settlement.
Your entity may have participated in prior national opioid settlements. This Notice
concerns the opportunity to participate in this new settlement with the Six Remnant
Defendants. Your entity may participate in this new settlement even if it did not participate
in a prior national settlement.
All Eligible Entities must “opt in” to participate in this new settlement. To do so, a
person with authority must sign and return the Combined Subdivision Participation and
Release Form that will be sent via DocuSign shortly. If an Eligible Entity is unable to return
an executed Combined Subdivision Participation and Release Form using DocuSign, the
signed Combined Subdivision Participation and Release Form may be submitted via the
Rubris Platform Portal. Please utilize the link included in this Notice to upload your entity’s
Combined Subdivision Participation and Release Form directly to the Rubris Platform
Portal. DocuSign remains the preferred method of submission of the needed form.
The deadline to return the Combined Subdivision Participation and Release Form
is Monday, May 4, 2026 .
Questions about this Notice or the process for receiving and submitting the required
Combined Subdivision Participation and Release Form may be directed to your attorney
or the Notice and Claims Administrator at opioidsparticipation@rubris.com.
Please review the list of individuals on this email and contact the Notice and Claims
Administrator at opioidsparticipation@rubris.com if someone else at your entity should
receive communications about this Settlement.
182893373.1
Page 4592 of 6641
If your entity is represented by an attorney with respect to opioid claims and they
are not copied on this message, please immediately contact them concerning this
Notice.
Thank you,
National Opioids Notice and Claims Administrator for the Remnant Defendants
Settlement
The Notice and Claims Administrator is retained to provide the Settlement Notice
required by the Settlement Agreement referenced above and to manage the collection
of Subdivision Settlement Participation Forms.
182893373.1
Page 4593 of 6641
National Opioids Settlements: Six Remnant Defendants
Notice and Claims Administrator
opioidsparticipation@rubris.com
To: COLLIER COUNTY, FL
Reference Number: CL-2023107
THIS SETTLEMENT OVERVIEW CONTAINS IMPORTANT INFORMATION ABOUT
THE SIX REMNANT DEFENDANTS NATIONAL OPIOID SETTLEMENT
SIX REMNANT DEFENDANTS SETTLEMENT OVERVIEW
A new national opioid settlement has been reached with six regional distributors/dispenser
defendants (Remnant Defendants Settlement): Associated Pharmacies, Inc (and
American Associated Pharmacies); J M Smith Corporation; Louisiana Wholesale Drug
Company, Inc.; Morris and Dickson Co.; North Carolina Mutual Wholesale Drug
Company, Inc.; and United Natural Foods, Inc. (including its subsidiaries SuperValu and
Advantage Logistics) (Six Remnant Defendants). There is one settlement agreement
covering the combined settlement with the Six Remnant Defendants.
If effectuated, the proposed Remnant Defendants Settlement will result in the the Six
Remnant Defendants paying a combined $97,625,000.00 in cash for purposes of abating
the opioid epidemic. An Eligible Entity’s participation in the Remnant Defendants
Settlement, the Settlement will result in a one-time settlement payment to each Eligible
Entity. The Settlement funds must be used for the Core Strategies and Approved Uses set
forth in Exhibit D of the Remnant Defendant Settlement Agreement.
The Remnant Defendants Settlement does not include State Attorneys General or any
amount allocated to a State. Rather, this Settlement will be distributed only and directly to
any Eligible Entity that participates by signing and returning the Combined Subdivision
Participation and Release Form by the deadline.
The allocation to participating entities will be calculated using the national Denver model
but removing from the equation any amount that the Denver model would allocate to a
State Attorney General or a State allocation. Specifically, the interstate allocation formula
will be used to calculate what amount should go to all the subdivisions in each state and
then apply the intrastate allocation as between all subdivisions who are either a litigating
subdivision or a non-litigating subdivision with a population of 30,000 or more. Using that
methodology, a national pro-rata percentage was created. That allocation percentage of
participation is reflected in Exhibit E of the Remnant Defendant Settlement Agreement.
182891755.1
Page 4594 of 6641
Eligible Entities must decide whether to participate by Monday, May 4, 2026 .
WHO IS RUBRIS INC. AND WHAT IS THE NOTICE AND CLAIMS
ADMINISTRATOR?
The Settlement provides that a Notice and Claims Administrator will provide notice and
manage the collection of participation forms. Rubris, Inc. is the Notice and Claims
Administrator for this new Settlement and was also retained for the prior national opioid
settlements.
WHY IS YOUR ENTITY RECEIVING THIS NOTICE?
Your entity is eligible to participate in this Settlement. This Notice is also sent directly to
counsel for each Eligible Entity if the Notice and Claims Administrator has their
information. If you are represented by an attorney with respect to opioid claims, please
contact them.
WHERE CAN YOU FIND MORE INFORMATION?
Detailed information about the Settlement may be found at:
https://nationalopioidsettlement.com
You are encouraged to review the Settlement Agreement terms and discuss the terms
and benefits with your counsel. Each Eligible Entity will need to decide whether to
participate in the proposed Settlement, and entities are encouraged to work through this
process before the Monday, May 4, 2026, deadline.
HOW DO YOU PARTICIPATE IN THE SETTLEMENT?
The Settlement requires that each Eligible Entity take affirmative steps to “opt in” to the
Settlement. You will receive the Combined Subdivision Participation and Release Form
via DocuSign along with instructions from the Implementation Administrator. In order to
participate in this Settlement, a person with authority must sign and return the required
Combined Subdivision Participation and Release Form. DocuSign remains the preferred
method of submission of the needed form.
The participation rate will be used to determine whether participation for each Remnant
Defendant is sufficient to move forward. If the Settlement moves forward, your release will
become effective as to that Remnant Defendant. If the settlement as to any Remnant
Defendant does not move forward, the release as to that Remnant Defendant will not
become effective.
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 Form and instructions.
182891755.1
Page 4595 of 6641
All required documentation must be signed and returned on or before Monday, May 4,
2026. Upon effectuation of the Remnant Defendants Settlement, each Eligible Entity will
be provided with a link to a portal where you will enter contact and payment information
to receive settlement funds.
182891755.1
Page 4596 of 6641
I.]XHIBIT (;
Six (6) Remnant flefendants'
Comhined Subdivision Particination and Releasc Form
("Combincd Participation Form")
Govemmental Entity; COLLIER COUNTY Srate: FL
Authorized Official
Arldrcss 1:
Adtlress 2
City, State. Zip
Phone:
Email:
The governmental entity identified above ("Governmental Entity"), in order to obtain and
in consideration for the benefits provided to the Covernmental Entity pursuant to the six (6)
Remnant Defendants' Settlement Agreement ("RDSA"), dated February 3,2026, and described
Iurther in Paragraph 1, and acting through the undersigned aurhorized oltrcial. hereby elects to
participate in the RDSA, release all Released Claims against all Released Entities. and agrees as
tbllows:
2. The Governmental Entity is aware of and has reviewed the RDSA, understands that all
capitalized terms not defined in this Cornbined Participation Form have the mcanings
defined in the RDSA, and agrees that by executing this Combined Panicipation Form. the
Governmental Entity elects to participate in the RDSA and become a Participating
Subdivision as provided in the RDSAs.
-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 Rele ased Claims that ir has filed against any Released Entity in the RDSA. Wirh
respect to any Released Claims pending in ln Re National Prescription Opiute Litigatiott,
MDL No. 2804, the Governmental Entity authoriz,es the Plaintiffs' Executive
Committee to execute and file on behalf of the Governmental Entity a Stipulation of
Dismissal with Prejudice for each of six (6) Rcmnant Def'endants listcd in Paragraph I
above substantially in the fonn fbund al https://nationalopioidsenlement,com/additional-
settlentents/.
4. The Governmental Entity agrees to the terms of each of the RDSA pertaining to Participatino
E:DIO
ffi*
G-I
@
l. The Governmental Entity hereby elects to participate in the RDSA as a Participating
Subdivision with each of the following six (6) Remnant Defendants that are parties to (he
RDSA: (l) Associated Pharmacies, Inc. (and American Associated Pharrnacies), (2) J M
Smith Corporation, (3) Monis and Dickson Co., L.L.C., (4) Louisiana Wholesale Drug
Company, Inc.. (5) North Carolina Mutual Wholesale Drug Company, Inc., and (6)
United Natural Foods, lnc. (and SuperValu).
Amy Patterson
3299 Tamiami Trail E
Suite 202Naples, FL 34112
239-252-8383amy.patterson@collier.gov
Page 4597 of 6641
S ubdivisions as delined therein
-5. By agreeing to the terms of the RDSA settlements and becoming a Releasor, the
Governmental Entity is entitled to the benefits provided therein, including, if applicable,
nronetary payments beginning after the Effective Date.
6. Thc Governmental Entity agrees to use any monies it receives through the RDSA
solely for the purposes provided therein.
7. The Governrnental Entity submits to the jurisdiction of the MDL Court and agrees ro
follow the process for resolving any disputes described in the RDSA.
8. The Covernmental Entity has the right to enfbrce the RDSA as provided therein
9. The Governmental Entity, as a Participating Subdivision, hereby becomes a Releasor for
all purposes of the RDSA, including without limitation all provisions related to release of
any clainrs, 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 tbr a release to thc iullest cxtent 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 fbr any Released
Claims against any Released Entity in the RDSA in any forum whatsoever. The release
provided for in the RDSA is intcnded by the Parties to be broad and shall be interpreted so
as to give the Released Entities in the RDSA the broadest possible bar against any liability
relating in any way to Released Claims and extend to the tull extent of the power of the
Governmental Entity to relsase claims. The RDSA shall be a complete bar to any
Released Claim against the Released Entities.
10. The Governmental Entity hereby takes on all rights and obligarions of a Participating
Subdivision as set fbrth in the RDSA.
ll In connection with the releases provided in the RDSA, each Governmental Entity
expressly waives. releases, and tilrever discharges any and all provisions, rights. and
benefits conf'erred by any law of any state or territory of the United States or other
jurisdiction, or principle of comnon law, which is similar, comparable, or equivalent to g
l -542 of the Califomia 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 alfected his or her settlement with
the debtor or released party.
G-2 E-&'*E
F*fuiElc{l
@Page 4598 of 6641
A Releasor may hereatier discover facts other than or different tiom those which it knows,
believes. or assumes to be true with respect ro the Released Claims in the RDSA, but each
Governmental Entity hereby expressly waives and t'ully, finally, and forever scttles,
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 tault whatsoever. and which, if
known, would materially affecl the Governmental Entities' decision to panicipate in the
RDSA.
12. Thc Governmental Entity understands and acknowledges that norhing herein is intended
to modily in any way the terms of any of the RDSA, to which Covernmental Entity
hereby agrees. To the extent this Combined Parricipation Form is interpreted diferently
from the RDSA in any respect, the RDSA controls.
I have all necessary power and authorization to execute this Cornbined Participation Form
on behalf of the Governmental Entity.
Signature:
Name
'l'ille
Date:
8td legality
Jeffrey Attomcy
Et,!7tr
5Hfi
G-3
@
Amy Patterson
County Manager
Page 4599 of 6641