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<br />6 <br /> <br /> <br />functions, including but not limited to school districts, fire districts, healthcare & <br />hospital districts, and emergency services districts. <br />29. “State” means the State of Washington. <br />30. “State Outside and Inside Counsel Fees and Costs” means fees and costs of the <br />Washington Attorney General’s Office and State Outside Counsel. <br />31. “State Outside Counsel” means Nix Patterson, LLP and Whitten Burrage, who were <br />engaged by the Washington Attorney General’s Office for State of Washington v. <br />Johnson & Johnson, et al., King County Superior Court, Cause No. 20-2-00184- <br />8SEA. <br />32. “Subdivision” means a formal and legally recognized sub-entity of the State that <br />provides general governance for a defined area, including a county, city, town, <br />village, or similar entity. Unless otherwise specified, “Subdivision” includes all <br />functional counties and other functional levels of sub-entities of the State that <br />provide general governance for a defined area. Historic, non-functioning sub-entities <br />of the State are not Subdivisions, unless the entity has filed a lawsuit that includes a <br />Released Claim against a Released Entity in a direct, parens patriae, or any other <br />capacity. For purposes of this Agreement, the term Subdivision also includes Special <br />Districts. <br />III. Injunctive Relief <br />As part of the Consent Judgment, the Parties agree to the injunctive relief terms attached as <br />Exhibit C. <br />IV. Release <br />A. Scope. As of the Effective Date, the Released Entities will be released and forever <br />discharged from all of the Releasors’ Released Claims. The State of Washington (for itself <br />and its Releasors) and each Participating Subdivision (for itself and its Releasors) will, on or <br />before the Effective Date, absolutely, unconditionally, and irrevocably covenant not to <br />bring, file, or claim, or to cause, assist in bringing, or permit to be brought, filed, or claimed, <br />or to otherwise seek to establish liability for any Released Claims against any Released <br />Entity in any forum whatsoever. The releases provided for in the Agreement are intended by <br />the Parties to be broad and shall be interpreted so as to give the Released Entities the <br />broadest possible bar against any liability relating in any way to Released Claims and extend <br />to the full extent of the power of the State and its Attorney General to release claims. The <br />Release shall be a complete bar to any Released Claim. <br />B. Claim Over and Non-Party Settlement. <br />1. Statement of Intent. It is the intent of the Parties that: