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<br />JANSSEN WASHINGTON STATE-WIDE OPIOID SETTLEMENT AGREEMENT
<br />I. Overview
<br />This settlement agreement (the “Agreement”) sets forth the terms and conditions of a
<br />settlement agreement between and among Janssen, the State of Washington, and Participating
<br />Subdivisions (as those terms are defined below). Janssen has agreed to the below terms for the sole
<br />purpose of settlement, and nothing herein may be taken as or construed to be an admission or
<br />concession of any violation of law, rule, or regulation, or of any other matter of fact or law, or of
<br />any liability or wrongdoing, all of which Janssen expressly denies. No part of this Agreement,
<br />including its statements and commitments, shall constitute evidence of any liability, fault, or
<br />wrongdoing by Janssen. Unless the contrary is expressly stated, this Agreement is not intended for
<br />use by any third party for any purpose, including submission to any court for any purpose.
<br />II. Definitions
<br />Unless otherwise specified, the following definitions apply:
<br />1. “Agreement” means this agreement as set forth above, inclusive of all exhibits.
<br />2. “Alleged Harms” means the alleged past, present, and future financial, societal, and
<br />related expenditures arising out of the alleged misuse and abuse of opioid products,
<br />that have allegedly been caused by Janssen.
<br />3. “Attorney” means any of the following retained through a legal contract: a solo
<br />practitioner, multi-attorney law firm, or other legal representative of a Participating
<br />Subdivision.
<br />4. “Claim” means any past, present or future cause of action, claim for relief, cross-
<br />claim or counterclaim, theory of liability, demand, derivative claim, request,
<br />assessment, charge, covenant, damage, debt, lien, loss, penalty, judgment, right,
<br />obligation, dispute, suit, contract, controversy, agreement, parens patriae claim,
<br />promise, performance, warranty, omission, or grievance of any nature whatsoever,
<br />whether legal, equitable, statutory, regulatory or administrative, whether arising
<br />under federal, state or local common law, statute, regulation, guidance, ordinance or
<br />principles of equity, whether filed or unfiled, whether asserted or unasserted,
<br />whether known or unknown, whether accrued or unaccrued, whether foreseen,
<br />unforeseen or unforeseeable, whether discovered or undiscovered, whether suspected
<br />or unsuspected, whether fixed or contingent, and whether existing or hereafter
<br />arising, in all such cases, including but not limited to any request for declaratory,
<br />injunctive, or equitable relief, compensatory, punitive, or statutory damages, absolute
<br />liability, strict liability, restitution, subrogation, contribution, indemnity,
<br />apportionment, disgorgement, reimbursement, attorney fees, expert fees, consultant
<br />fees, fines, penalties, expenses, costs or any other legal, equitable, civil,
<br />administrative, or regulatory remedy whatsoever.
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