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WASHINGTON STATE ALLOCATION AGREEMENT GOVERNING THE
ALLOCATION OF OPIOID SETTLEMENT FUNDS PAID BY KROGER
JUNE 28, 2024
This Washington State Allocation Agreement Governing the Allocation of Opioid
Settlement Funds Paid by Kroger (the “Allocation Agreement III”) governs the distribution of
funds obtained from the Kroger Co. (“Kroger”) in connection with the resolution of any and all
claims by the State of Washington and the counties, cities, and towns in Washington State
(“Local Governments”) against Kroger via the Kroger Settlement Agreement dated March 22,
2024 (“Settlement”). The Settlement can be accessed at https://nationalopioidsettlement.com/.
The terms and definitions of the Settlement are incorporated into this Allocation Agreement III,
and any undefined terms in this Allocation Agreement III are as defined in the Settlement.
1.This Allocation Agreement III is intended to be a State-Subdivision Agreement as
defined in the Settlement. This Allocation Agreement III shall be interpreted to be
consistent with the requirements of a State-Subdivision Agreement in the
Settlement.
2.This Allocation Agreement III shall become effective only if all of the following
occur:
A.The State of Washington joins the Settlement and becomes a Settling State
as provided for in the Settlement.
B.The Settlement becomes final and effective and a Consent Judgment is
filed and approved as provided for in the Settlement.
C.The number of Local Governments that execute and return this Allocation
Agreement III satisfies the participation requirements for a State-
Subdivision Agreement as specified in the Settlement.
3.Requirements to become a Participating Local Government. To become a
Participating Local Government that can participate in this Allocation Agreement
III, a Local Government must do all of the following:
A. The Local Government must execute and return this Allocation
Agreement III.
B.The Local Government must release its claims against Kroger identified in
the Settlement and agree to be bound by the terms of the Settlement by
timely executing and returning the Participation Form, which is Exhibit K
of the Settlement.
C.Litigating Subdivisions, also referred to as Litigating Local Governments,
must dismiss Kroger with prejudice from their lawsuits.
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D. Each of the Local Governments that is eligible to participate in this
Allocation Agreement III has previously executed and signed the One
Washington Memorandum of Understanding Between Washington
Municipalities (“MOU”) agreed to by the Participating Local
Governments in Washington State, which is attached hereto as Exhibit 1.
By executing this Allocation Agreement III, the local government agrees
and affirms that the MOU applies to and shall govern the Local
Government Share as modified by this Allocation Agreement III for the
Settlement.
A Local Government that meets all of the conditions in this paragraph shall be
deemed a “Participating Local Government.”
4. This Allocation Agreement III applies to the State of Washington’s allocation of
the (1) Adjusted State Remediation Payment and (2) Additional Remediation
Amount, which collectively shall be referred to as the “Washington Abatement
Amount.” As specified in the Settlement, the Washington Abatement Amount will
vary dependent on the percentage of Participating Local Governments and
whether there are any Later Litigating Subdivisions.
5. This Allocation Agreement III does not apply to the State Cost Fund, State AG
Fees and Costs, or any attorneys’ fees, fees, costs, or expenses referred to in the
Settlement or that are paid directly or indirectly via the Settlement to the State of
Washington (“State’s Fees and Costs”).
6. This Allocation Agreement III and the MOU are a State Back-Stop Agreement.
Kroger is paying a portion of the Local Governments’ attorneys’ fees and costs as
provided for in the Settlement. The total contingent fees an attorney receives from
the Contingency Fee Fund in the Settlement, the MOU, and this Allocation
Agreement III combined cannot exceed 15% of the portion of the LG Share paid
to the Litigating Local Government that retained that firm to litigate against the
Settling Entities (i.e., if City X filed suit with outside counsel on a contingency
fee contract and City X receives $1,000,000 from the Settlement, then the
maximum that the firm can receive is $150,000 for fees as to the Kroger
Settlement.)
7. No portion of the State’s Fees and Costs and/or the State Share as defined in
Paragraphs 5 and 9 of this Allocation Agreement III shall be used to fund the
Government Fee Fund (“GFF”) referred to in Paragraph 11 of this Allocation
Agreement III and Section D of the MOU, or in any other way to fund any
Participating Local Government’s attorneys’ fees, costs, or common benefit tax.
8. The Washington Abatement Amount shall and must be used by the State and
Participating Local Governments for future Opioid Remediation as defined in the
Settlement, except as allowed by the Settlement.
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9. The State and the Participating Local Governments agree to divide the
Washington Abatement Amount as follows:
A. Fifty percent (50%) to the State of Washington (“State Share”).
B. Fifty percent (50%) to the Participating Local Governments (“LG Share”).
10. The LG Share shall be distributed to Participating Local Governments pursuant to
the MOU as amended and modified in this Allocation Agreement III.
11. For purposes of this Allocation Agreement III only, the MOU is modified as
follows and any contrary provisions in the MOU are struck:
A. Exhibit A of the MOU is replaced by Exhibit E of the Settlement.
B. The definition of “Litigating Local Governments” in Section A.4 of the
MOU shall mean Litigating Subdivisions as defined in the Settlement and
shall also include any local government that notified Judge Polster in Case
No. 1:17-md-02804-DAP of its intent to sue Kroger in 2023 after the
release of updated ARCOS data.
C. The definition of “National Settlement Agreement” in Section A.6 of the
MOU shall mean the Settlement.
D. The definition of “Settlement” in Section A.14 of the MOU shall mean the
Settlement.
E. The MOU is amended to add new Section C.4.g.vIII, which provides as
follows:
“If a Participating Local Government receiving a direct payment
(a) uses Opioid Funds other than as provided for in the Settlement,
(b) does not comply with conditions for receiving direct payments
under the MOU, or (c) does not promptly submit necessary
reporting and compliance information to its Regional Opioid
Abatement Counsel (“Regional OAC”) as defined at Section C.4.h
of the MOU, then the Regional OAC may suspend direct payments
to the Participating Local Government after notice, an opportunity
to cure, and sufficient due process. If direct payments to
Participating Local Government are suspended, the payments shall
be treated as if the Participating Local Government is foregoing
their allocation of Opioid Funds pursuant to Section C.4.d and
C.4.j.IIIi of the MOU. In the event of a suspension, the Regional
OAC shall give prompt notice to the suspended Participating Local
Government and the Settlement Fund Administrator specifying the
reasons for the suspension, the process for reinstatement, the
factors that will be considered for reinstatement, and the due
process that will be provided. A suspended Participating Local
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Government may apply to the Regional OAC to be reinstated for
direct payments no earlier than five years after the date of
suspension.”
F. The amounts payable to each law firm representing a Litigating Local
Government from the GFF shall be consistent with the MOU and the
process set forth in the Order Appointing the Fee Panel to Allocate and
Disburse Attorney’s Fees Provided for in State Back-Stop Agreements,
Case No. 1:17-md-02804-DAP Doc #: 4543 (June 17, 2022). All
amounts that the City of Seattle has contributed to the GFF shall be
returned to the City of Seattle by the Settlement Administrator rather than
paid to Hagens Berman Sobol Shapiro LLP.
G. The GFF set forth in the MOU shall be funded by the LG Share of the
Washington Abatement Amount only. To the extent the common benefit
tax is not already payable by the Settling Entities as contemplated by
Section D.8 of the MOU, the GFF shall be used to pay Litigating Local
Government contingency fee agreements and any common benefit tax
referred to in Section D of the MOU, which shall be paid on a pro rata
basis to eligible law firms as determined by the GFF Administrator.
H. To fund the GFF, fifteen percent (15%) of the LG Share shall be deposited
in the GFF from each LG Share settlement payment until the Litigating
Subdivisions’ contingency fee agreements and common benefit tax (if
any) referred to in Section D of the MOU are satisfied. Under no
circumstances will any Primary Subdivision or Litigating Local
Government be required to contribute to the GFF more than 15% of the
portion of the LG Share allocated to such Primary Subdivision or
Litigating Local Government. In addition, under no circumstances will
any portion of the LG Share allocated to a Litigating Local Government be
used to pay the contingency fees or litigation expenses of counsel for some
other Litigating Local Government.
I. The maximum amount of any Litigating Local Government contingency
fee agreement (from the Contingency Fee Fund of the Settlement) payable
to a law firm permitted for compensation shall be fifteen percent (15%) of
the portion of the LG Share paid to the Litigating Local Government that
retained that firm (i.e., if City X filed suit with outside counsel on a
contingency fee contract and City X receives $1,000,000 from the
Settlement, then the maximum that the firm can receive is $150,000 for
fees.) The firms also shall be paid documented expenses due under their
contingency fee agreements that have been paid by the law firm
attributable to that Litigating Local Government. Consistent with
Agreement on Attorneys’ Fees, Costs, and Expenses, which is Exhibit R
of the Settlement, amounts due to Participating Litigating Subdivisions’
attorneys under this Allocation Agreement III shall not impact (i) costs
paid by the subdivisions to their attorneys pursuant to a State Back-Stop
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agreement, (ii) fees paid to subdivision attorneys from the Common
Benefit Fund for common benefit work performed by the attorneys
pursuant to Exhibit R of the Settlement, or (iii) costs paid to subdivision
attorneys from the MDL Expense Fund for expenses incurred by the
attorneys pursuant to the Settlement.
J.Under no circumstances may counsel receive more for its work on behalf
of a Litigating Local Government than it would under its contingency
agreement with that Litigating Local Government. To the extent a law
firm was retained by a Litigating Local Government on a contingency fee
agreement that provides for compensation at a rate that is less than fifteen
percent (15%) of that Litigating Local Government’s recovery, the
maximum amount payable to that law firm referred to in Section D.3 of
the MOU shall be the percentage set forth in that contingency fee
agreement.
K. For the avoidance of doubt, both payments from the GFF and the payment
to the Participating Litigating Local Governments’ attorneys from the
Contingency Fee Fund in the Settlement shall be included when
calculating whether the aforementioned fifteen percent (15%) maximum
percentage (or less if the provisions of Paragraph 10.J of this Allocation
Agreement III apply) of any Litigating Local Government contingency fee
agreement referred to above has been met.
L.To the extent there are any excess funds in the GFF, the Settlement
Administrator shall facilitate the return of those funds to the Participating
Local Governments as provided for in Section D.6 of the MOU.
12.In connection with the execution and administration of this Allocation Agreement
III, the State and the Participating Local Governments agree to abide by the
Public Records Act, RCW 42.56 et seq.
13.All Participating Local Governments, Regional OACs, and the State shall
maintain all non-transitory records related to this Allocation Agreement III as
well as the receipt and expenditure of the funds from the Settlement for no less
than five (5) years.
14.If any party to this Allocation Agreement III believes that a Participating Local
Government, Regional OAC, the State, an entity, or individual involved in the
receipt, distribution, or administration of the funds from the Settlement has
violated any applicable ethics codes or rules, a complaint shall be lodged with the
appropriate forum for handling such matters, with a copy of the complaint
promptly sent to the Washington Attorney General, Complex Litigation Division,
Division Chief, 800 Fifth Avenue, Suite 2000, Seattle, Washington 98104.
15.To the extent (i) a region utilizes a pre-existing regional body to establish its
Opioid Abatement Council pursuant to the Section 4.h of the MOU, and (III) that
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pre-existing regional body is subject to the requirements of the Community
Behavioral Health Services Act, RCW 71.24 et seq., the State and the
Participating Local Governments agree that the Opioid Funds paid by Kroger is
subject to the requirements of the MOU and this Allocation Agreement III.
16. Upon request by Kroger, the Participating Local Governments must comply with
the Tax Cooperation and Reporting provisions of the Settlement.
17. Venue for any legal action related to this Allocation Agreement III (separate and
apart from the MOU or the Settlement) shall be in King County, Washington.
18.Each party represents that all procedures necessary to authorize such party’s
execution of this Allocation Agreement III have been performed and that such
person signing for such party has been authorized to execute this Allocation
Agreement III.
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FOR THE PARTICIPATING LOCAL GOVERNMENT:
Name of Participating Local Government:
Authorized signature:
Name:
Title:
Date:
City of Renton
Armondo Pavone
Mayor
7/30/2024
Attest:____________________________________________________________________
Jason A. Seth, City Clerk
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EXHIBIT 1
One Washington Memorandum of Understanding Between Washington Municipalities