ONE NEVADA AGREEMENT ON ALLOCATION OF OPIOID RECOVERIES

WHEREAS, the people of the State of Nevada and its communities have been harmed by

the misfeasance, nonfeasance, and malfeasance of certain individuals and entities, including licit

and illicit opioid distribution, that has created an opioid epidemic both nationally and within the

State of Nevada;

WHEREAS, on January 24, 2019, the Honorable Steve Sisolak, Governor of the State of

Nevada, in consultation with the Honorable Aaron D. Ford, Attorney General of the State of

Nevada, entered a Declaration of Findings Pursuant to NRS 228.1111(1)(a), declaring that the

State of Nevada is combating the opioid epidemic;

WHEREAS, the State of Nevada though its elected representatives and counsel,

including the Honorable Aaron D. Ford, Attorney General of the State of Nevada, and certain

Local Governments, through their elected representatives and counsel, are separately engaged in

opioid-related litigation seeking to hold various entities and individuals accountable for the

opioid epidemic in the State of Nevada based on their misconduct relating to the unlawful

manufacture, marketing, promotion, distribution, and/or dispensing of prescription opioids;

WHEREAS, the State of Nevada and its Local Governments share a common desire to

remediate and alleviate the impacts of the opioid epidemic throughout the State of Nevada;

THEREFORE, the State of Nevada and its Local Governments, desire, subject to formal

approval effectuating this One Nevada Agreement on Allocation of Opioid Recoveries

(“Agreement”) relating to the resolution or partial resolution of opioid-related litigation and the

allocation and use of the proceeds of any Recoveries as described; and

NOW THEREFORE, the Parties agree and desire to be bound as follows:

1
A. Definitions

As used in this Agreement:

1. The "State" or "State of Nevada" shall mean the State of Nevada acting through its

Attorney General.

2. “Local Governments” shall mean the Local Governments listed in Exhibit A,

attached.

3. "Litigating Counties" shall mean the following Nevada Counties: Carson City,

Churchill, Clark, Douglas, Esmeralda, Humboldt, Lincoln, Lyon, Mineral, Nye,

Washoe, and White Pine;

4. "Non-Litigating Counties" shall mean the following Nevada Counties: Elko,

Eureka, Lander, Pershing, and Storey;

5. “Litigating Cities and Districts” shall mean the Cities and Districts listed in

Exhibit B, attached;

6. “Counsel” shall mean the contingency fee retained attorneys to the State of

Nevada and each of the Litigating Counties and Litigating Cities and Districts for

their respective opioid-related litigation.

7. "The Parties" shall mean the State of Nevada and the Local Governments.

8. "Defendant" or "Defendants" shall mean one or more entities and/or individuals

responsible for the opioid epidemic in the State of Nevada based upon various

theories and causes of action asserted in pending opioid-related litigation by the

State of Nevada, the Litigating Counties, and the Litigating Cities and Districts as

listed in Exhibit C, attached.

9. "Lead Litigator Costs" shall mean the costs incurred to date for opioid-related

litigation by the State of Nevada, the Litigating Counties, and the Litigating Cities
2
 and Districts against the Defendants of at the time of any Recovery. Costs do not

include attorney fees or contingency fees for Counsel.

10. "Federal Government CMS Medicaid Costs" shall mean 22.52% of any Recovery

after deduction of the Lead Litigator Costs that may be asserted, and only if

determined to be recoverable, against the State of Nevada's Federal Government

Centers for Medicaid Services costs for claims, otherwise commonly known as

the federal share of Medicaid claims payments.

11. “Negotiating Committee" shall mean Counsel for the State of Nevada, the Nevada

Attorney General or his designees as required by NRS chapter 228.1113, et seq.,

and Counsel for the Litigating Counties, and the Litigating Cities and Districts

(collectively, "Members") in their respective opioid-related litigation.

12. "Recovery" or "Recoveries" shall mean monetary amounts obtained through the

negotiated resolution of legal or equitable claims against any Defendant in any

opioid-related litigation listed in Exhibit C, and shall include any Recoveries

against any Defendant through bankruptcy proceedings related to the opioid-

related litigation in Exhibit C to the extent the bankruptcy court allows for use of

this Agreement to allocate Recoveries.

13. "Approved Purposes" shall mean only uses to remediate the harms, impact, and

risks caused by the opioid epidemic to the State of Nevada and its residents, and

are consistent with those uses required by Senate Bill 390 (SB 390) as enrolled by

the 81st (2021) Nevada Legislative Session and signed into law by the Nevada

Governor, or uses that are listed as an approved use for abatement purposes in any

plan approved by a bankruptcy court that are not otherwise inconsistent with SB

390.
3
B. Allocation of Recoveries

1. With the exception of up to 8% for administrative costs, or unless otherwise

limited by Court Order, all Recoveries must be used for Approved Purposes.

2. Any Recovery, after deduction of Lead Litigator Costs, unless otherwise limited

by Court Order, and the Federal Government CMS Medicaid Costs, if and only if

applicable, shall be divided into percentages and allocated within these

percentages as follows:

Medicaid Match
17.37%
Local Governments
38.77%

State of Nevada
43.86%

(pie chart for illustrative purposes)

1) "State of Nevada Allocation": 43.86% to the State of Nevada;

2) "Local Governments Allocation": 38.77% to the Local Governments

to be allocated by percentage of claims data for the Local Governments as

outlined in Exhibit D, attached; and

3) "Medicaid Match Allocation": 17.37% representing what is referred

to as the Medicaid Match which amount shall be allocated among the

Counties as follows: a) 65% to Clark County, b) 14% to Washoe County,

and c) 21% to the remaining Litigating and Non-Litigating Counties by

population, as outlined in Exhibit E, attached.

4
3. Unless otherwise directed by court order, the State of Nevada shall receive and

divide and allocate any Recoveries described in Paragraph 2.

4. The State of Nevada and Local Governments shall exercise due diligence to

complete a release against any Defendant, if necessary, as a result of a Recovery

pursuant to this Agreement.

5. The State of Nevada and Local Governments shall make every reasonable effort

to coordinate any related press releases and/or press interaction concerning any

settlement or other disposition under this Agreement.

6. The State of Nevada and Local Governments are, after deduction of Lead

Litigator Costs unless otherwise limited by Court Order, and the Federal

Government CMS Medicaid Costs, if and only if applicable, from any Recovery,

each responsible for any remaining costs of that Party's litigation from that Party's

share of the Recovery after allocation.

7. The State of Nevada and Local Governments are each responsible, unless

otherwise directed by court order, for payment of any attorney fees for the use of

their Counsel in maintaining their respective opioid-related litigation from their

share of the Recoveries after allocation pursuant to the terms of their respective

contingency fee agreements. However, in the event Counsel is eligible to apply

for attorney fees or costs from a national fund created by one or more Defendants

in connection with a Recovery, Counsel will refund any amount recovered from

said national fund proportionate to the amount of attorney fees paid under each

respective contingency fee agreement.

8. Additionally, a fee adjustment of 25% shall be deducted from the share of each of

the allocation amounts to the Non-Litigating Counties described in Paragraph 2 of

5
 this Agreement. The total amount of the fee adjustment deducted pursuant to this

paragraph shall then be allocated to the Litigating Counties by total percentage of

claims data for those Litigating Counties as outlined in Exhibit F, attached.

9. In the event a Local Government merges, dissolves, ceases to exist, opioid-related

litigation is dismissed with prejudice including the exhaustion of any and all

appeals related to the Court's order of dismissal, or is excluded from a specific

recovery for any reason, the allocation percentage for that Local Government shall

be reallocated as follows:

a. If a Local Government excluded under this paragraph is a Litigating City or

District, then that Litigating City or District’s allocated share shall be added to

the share of the County in which the Litigating City or District is located in

addition to the County’s allocated share.

b. If a Local Government excluded under this paragraph is a County, then that

County’s allocated share shall be added to the State’s share minus the

allocated shares of any Litigating City or District located within the excluded

County that would otherwise be entitled to receive their shares.

10. Funds received by the State of Nevada or Local Governments, which are obtained

from entities or individuals not listed on Exhibit C, or from sources unrelated to a

Recovery, i.e., via grant, bequest, gift or the like, are excluded from this

Agreement.

11. The State of Nevada’s share of Recoveries, after deduction of any remaining costs

and attorney fees, shall be deposited in the Fund for Resilient Nevada through

Senate Bill 390 (2021).

6
 12. Nothing in this Agreement alters or intends to alter or change the right of the State

of Nevada or any Local Governments to pursue its own claims against any

Defendant through that Parties' separate opioid-related litigation. Rather, the

intent of this Agreement is to join all Parties to seek and negotiate binding global

settlement or settlements and to obtain Recoveries with one or more Defendants in

the State of Nevada or Local Governments opioid-related litigation for the benefit

of all Parties to this Agreement.

C. Waiver of Conflict of Interest. Consistent with the intent of this Agreement, the Parties

agree that there is no conflict of interest in Counsel representing the Parties to this Agreement,

but to the extent Counsel’s representation may constitute a conflict of interest, the Parties waive

any potential conflict of interest.

D. Reporting. Accountability - Prior to July 1st of each year, or as otherwise required by

any Court Order, each of the Local Governments shall provide information to the State, to the

attention of Mark J. Krueger, Chief Deputy Attorney General at mkrueger@ag.nv.gov, about

how they intend to expend, and how they did expend, their allocated shares of any

Recovery/Recoveries to ensure such Recoveries are being used for Approved Purposes only.

Local Governments shall respond and provide documents to any reasonable requests from the

State for data or information about the use of the Recoveries, including Local Government or

third-party programs, services, or infrastructure receiving the Recoveries.

E. Miscellaneous

1. Construction. With regard to each and every term and condition of this

Agreement, the Parties understand and agree that the same have or has been

mutually negotiated, prepared and drafted, and if at any time the Parties are

required to interpret or construe any such term or condition, no consideration shall

7
 be given to the issue of which Party actually prepared, drafted or requested any

term or condition thereof.

2. Severability Clause. In the event any provision or part of this Agreement is

found to be invalid or unenforceable, only that particular provision or part so

found, and not the entire Agreement, will be inoperative.

3. Entire Agreement. This Agreement, contains the entire agreement between the

Parties and supersedes and cancels all previous negotiations and agreements, if

any.

4. Governing Law. This Agreement shall be governed by and construed in

accordance with the law of the State of Nevada.

5. Amendments. Any and all amendments to this Agreement must be in writing

which must be signed by all Parties and must be approved by their respective

Commissions, Councils, or Boards.

6. Signature in Counterparts. This Agreement may be executed in any number of

counterparts, each of which shall be an original and all of which shall together

constitute one and the same instrument. This Agreement and any amendments

thereto, to the extent signed and delivered by means of a facsimile machine or

electronic scan (including in the form of an Adobe Acrobat PDF file format), shall

be treated in all manner and respects as an original agreement and shall be

considered to have the same binding legal effect as if it were the original signed

version thereof.

7. Legal Advice. The Parties acknowledge that they have been advised to have this

Agreement reviewed by their respective Deputy Attorney Generals, District

Attorneys, and City Attorneys (collectively “Government Attorneys”) and the

8
 Government Attorneys have had the opportunity to participate in the negotiation

of this Agreement.

F. Acknowledgment of Agreement and Binding Authority

This Agreement has been collaboratively drafted to maintain all individual claims and

causes of action in each Parties’ opioid-related litigations while allowing the State and its Local

Governments to cooperate in exploring all possible means of obtaining a Recovery/Recoveries

against the Defendants. This Agreement is jointly entered into by the State of Nevada and Local

Governments, is approved by the Parties' respective Commissions, Councils, and Boards, and

provides binding authority from each Party to the Agreement regarding the resolution through the

Negotiating Committee and allocation of any Recovery. However, other than those settlements or

other disposition in this Agreement, nothing in this Agreement binds any party to any specific

outcome of each Parties’ opioid-related litigation.

We, the undersigned, hereby agree to be bound by this Agreement, which shall have an

effective date of August 9, 2021.

Executed this ________ day of________, 2021.

STATE OF NEVADA

By: _______________________________ Dated:__________________

NEVADA ATTORNEY GENERAL

CHURCHILL COUNTY

By: _______________________________ Dated:__________________

REPRESENTATIVE FOR THE
LOCAL GOVERNMENT

9
CLARK COUNTY

By: _______________________________ Dated:__________________

REPRESENTATIVE FOR THE
LOCAL GOVERNMENT

DOUGLAS COUNTY

By: _______________________________ Dated:__________________

REPRESENTATIVE FOR THE
LOCAL GOVERNMENT

ELKO COUNTY

By: _______________________________ Dated:__________________

REPRESENTATIVE FOR THE
LOCAL GOVERNMENT

ESMERALDA COUNTY

By: _______________________________ Dated:__________________

REPRESENTATIVE FOR THE
LOCAL GOVERNMENT

EUREKA COUNTY

By: _______________________________ Dated:__________________

REPRESENTATIVE FOR THE
LOCAL GOVERNMENT

HUMBOLDT COUNTY

By: _______________________________ Dated:__________________

REPRESENTATIVE FOR THE
LOCAL GOVERNMENT

10
LANDER COUNTY

By: _______________________________ Dated:__________________

REPRESENTATIVE FOR THE
LOCAL GOVERNMENT

LINCOLN COUNTY

By: _______________________________ Dated:__________________

REPRESENTATIVE FOR THE
LOCAL GOVERNMENT

LYON COUNTY

By: _______________________________ Dated:__________________

REPRESENTATIVE FOR THE
LOCAL GOVERNMENT

MINERAL COUNTY

By: _______________________________ Dated:__________________

REPRESENTATIVE FOR THE
LOCAL GOVERNMENT

PERSHING COUNTY

By: _______________________________ Dated:__________________

REPRESENTATIVE FOR THE
LOCAL GOVERNMENT

STOREY COUNTY

By: _______________________________ Dated:__________________

REPRESENTATIVE FOR THE
LOCAL GOVERNMENT

11
WASHOE COUNTY

By: _______________________________ Dated:__________________

REPRESENTATIVE FOR THE
LOCAL GOVERNMENT

WHITE PINE COUNTY

By: _______________________________ Dated:__________________

REPRESENTATIVE FOR THE
LOCAL GOVERNMENT

BOULDER CITY

By: _______________________________ Dated:__________________

REPRESENTATIVE FOR THE
LOCAL GOVERNMENT

NYE COUNTY

By: _______________________________ Dated:__________________

REPRESENTATIVE FOR THE
LOCAL GOVERNMENT

CARSON CITY

By: _______________________________ Dated:__________________

REPRESENTATIVE FOR THE
LOCAL GOVERNMENT

CITY OF HENDERSON

By: _______________________________ Dated:__________________

REPRESENTATIVE FOR THE
LOCAL GOVERNMENT

12
CITY OF LAS VEGAS

By: _______________________________ Dated:__________________

REPRESENTATIVE FOR THE
LOCAL GOVERNMENT

CITY OF MESQUITE

By: _______________________________ Dated:__________________

REPRESENTATIVE FOR THE
LOCAL GOVERNMENT

CITY OF NORTH LAS VEGAS

By: _______________________________ Dated:__________________

REPRESENTATIVE FOR THE
LOCAL GOVERNMENT

CITY OF RENO

By: _______________________________ Dated:__________________

REPRESENTATIVE FOR THE
LOCAL GOVERNMENT

CITY OF WEST WENDOVER

By: _______________________________ Dated:__________________

REPRESENTATIVE FOR THE
LOCAL GOVERNMENT

CITY OF FERNLEY

By: _______________________________ Dated:__________________

REPRESENTATIVE FOR THE
LOCAL GOVERNMENT

13
CITY OF ELY

By: _______________________________ Dated:__________________

REPRESENTATIVE FOR THE
LOCAL GOVERNMENT

CITY OF SPARKS

By: _______________________________ Dated:__________________

REPRESENTATIVE FOR THE
LOCAL GOVERNMENT

NORTHERN LYON COUNTY FIRE

PROTECTION DISTRICT

By: _______________________________ Dated:__________________

REPRESENTATIVE FOR THE
LOCAL GOVERNMENT

CENTRAL LYON COUNTY FIRE

PROTECTION DISTRICT

By: _______________________________ Dated:__________________

REPRESENTATIVE FOR THE
LOCAL GOVERNMENT

14
 EXHIBIT A

LOCAL GOVERNMENT COURT CASE NO.

Carson City 1st Judicial District Court 20TRT00471B

Clark County 8th Judicial District Court A-17-765828-C

Transferred to MDL
Churchill County 10th Judicial District Court 20-10DC-0805

Douglas County 9th Judicial District Court 2020CV00139

Elko County

Esmeralda County 5th Judicial District Court CV20-5117

Eureka County

Humboldt County 6th Judicial District Court CV0022306

Lander County

Lincoln County 7th Judicial District Court CV0702620

Lyon County 3rd Judicial District Court 20-CV-00795

Nye County MDL 1:18-op-46238-DAP

Northern Lyon County Fire 3rd Judicial District Court 20-CV-00795

Protection District

Central Lyon County Fire 3rd Judicial District Court 20-CV-00795

Protection District

Mineral County 11th Judicial District Court 21CV-TT12-2020-0104

Pershing County

Storey County

Washoe County 2nd Judicial District Court CV20-01142

White Pine County 7th Judicial District Court CV-2007076

City of West Wendover 4th Judicial District Court DC-CV-20-70

1
 EXHIBIT A

City of Fernley 3rd Judicial District Court 20-CV-00796

City of Sparks 2nd Judicial District Court CV20-01152

City of Ely 7th Judicial District Court CV-2007077

City of Las Vegas 8th Judicial District Court A-19-800697-B

City of North Las Vegas 8th Judicial District Court A-19-800699-B

City of Henderson 8th Judicial District Court A-19-800695-B

City of Reno 2nd Judicial District Court CV18-01895

City of Mesquite U.S District Court, District of 2:19-cv-01058

Nevada Transferred to MDL

Boulder City U.S District Court, District of 2:19-cv-01057

Nevada Transferred to MDL

2
 EXHIBIT B

LITIGATING CITIES COURT CASE NO.

AND DISTRICTS
City of West Wendover 4th Judicial District Court DC-CV-20-70

City of Fernley 3rd Judicial District Court 20-CV-00796

City of Sparks 2nd Judicial District Court CV20-01152

City of Ely 7th Judicial District Court CV-2007077

City of Las Vegas 8th Judicial District Court A-19-800697-B

City of North Las Vegas 8th Judicial District Court A-19-800699-B

City of Henderson 8th Judicial District Court A-19-800695-B

City of Reno 2nd Judicial District Court CV18-01895

City of Mesquite U.S District Court, District of 2:19-cv-01058

Nevada Transferred to MDL

Boulder City U.S District Court, District of 2:19-cv-01057

Nevada Transferred to MDL

Northern Lyon County Fire 3rd Judicial District Court 20-CV-00795

Protection District

Central Lyon County Fire 3rd Judicial District Court 20-CV-00795

Protection District

1
 EXHIBIT C

DEFENDANTS
A&H KATSCHKE LTD dba MEADOW VALLEY PHARMACY
ACTAVIS INC f/k/a WATSON PHARMACEUTICALS INC
ACTAVIS PHARMA, INC. f/k/a WATSON PHARMA, INC
ACTAVIS PHARMA, INC.
ACTAVIS, LLC
ADAM KATSCHKE
AIDA B MAXAM
ALEC BURLAKOFF
ALEJANDRO JIMINEZ INCERA
ALLERGAN FINANCE, LLC (fka ACTAVIS, INC. fka WATSON
PHARMACEUTICALS, INC.)
ALLERGAN INC
ALLERGAN PLC f/k/a ACTAVIS PLC
ALLERGAN USA INC
AMERICAN DRUG STORES
AMERISOURCEBERGEN DRUG CORPORATION
ANDA PHARMACEUTICALS, INC.
ANDA, INC
BAILY STORES LLC dba PROFESSIONAL PHARMACY
BEACON COMPANY
BEVERLY SACKLER
BOB TUCKER, INC. dba BOB TUCKER’S UNITED DRUG
C&R PHARMACY d/b/a KEN'S PHARMACY f/k/a LAM'S PHARMACY
CARDINAL HEALTH 105, INC.
CARDINAL HEALTH 108 LLC D/B/A METRO MEDICAL SUPPLY
CARDINAL HEALTH 108, LLC
CARDINAL HEALTH 110, LLC
CARDINAL HEALTH 200, LLC
CARDINAL HEALTH 414, LLC
CARDINAL HEALTH 6 INC
CARDINAL HEALTH INC.
CARDINAL HEALTH PHARMACY SERVICES, LLC
CARDINAL HEALTH TECHNOLOGIES
CARDIOLOGY PC
CEPHALON, INC.
CVS HEALTH CORP.
CVS INDIANA
CVS PHARMACY, INC.

1
 EXHIBIT C

CVS RX SERVICES INC

CVS TN DISTRIBUTION LLC
DAVID A. SACKLER
DEPOMED, INC
DEREK BRADDIX, APRN
DEVENDRA I. PATEL
DEVENDRA I. PATEL
ECONOMY DRUG
ECONOMY DRUG INC
ENDO HEALTH SOLUTIONS INC.
ENDO INTERNATIONAL PLC
ENDO PHARMACEUTICALS, INC.
GARY C RIDENOUR A PROFESSIONAL CORPORATION dba HIGH DESERT
CLINIC
GARY C RIDENOUR dba HIGH DESERT CLINIC
GARY C. RIDENOUR MD
HOLPER OUT-PATIENTS MEDICAL CENTER, LTD
HORACE PAUL GUERRA IV
ILENE SACKLER LEFCOURT
INCERA LLC
INCERA-IUVENTUS MEDICAL GROUP PC
INSYS THERAPEUTICS, INC.
JANSSEN PHARMACEUTICA INC. n/k/a JANSSEN PHARMACEUTICALS, INC.
JANSSEN PHARMACEUTICALS, INC.
JOHN KAPOOR
JOHNSON & JOHNSON
JOLLY’S DRUG STORE LLC dba JOLLY’S DRUG STORE
JONATHAN D. SACKLER
JOSEPH A ROWAN
KATHE A. SACKLER
KROGER LIMITED PARTNERSHIP II D/B/A PEYTON’S NORTHERN
LONGS DRUG STORE CALIFORNIA LLC
MALLINCKRODT BRAND PHARMACEUTICALS INC
MALLINCKRODT LLC
MALLINCKRODT PLC
MALLINCKRODT US HOLDINGS, INC.
MASTERS PHARMACEUTICAL, LLC. f/k/a MASTERS PHARMACEUTICAL INC
MCKESSON CORPORATION
MICHAEL BABICH

2
 EXHIBIT C

MORTIMER D.A. SACKLER

NORAMCO, INC.
OMNICARE DISTRIBUTION CENTER LLC
ORTHOMCNEIL-JANSSEN PHARMACEUTICALS, INC. n/k/a JANSSEN
PHARMACEUTICALS, INC
P.F. LABORATORIES, INC.
PAR PHARMACEUTICAL COMPANIES.
PAR PHARMACEUTICAL, INC.
PATEL NORTH EASTERN NEVADA
PATEL NORTHEASTERN NEVADA CARDIOLOGY PC
PLP ASSOCIATES HOLDINGS L.P.
PURDUE HOLDINGS, L.P.
PURDUE PHARMA L.P.
PURDUE PHARMA, INC.
PURDUE PHARMACEUTICALS LP
RAND FAMILY CARE LLC
REX DRUG CO. dba REX DRUG
RICHARD M SIMON
RICHARD S. SACKLER
RITE AID CORPORATION
RITE AID OF MARYLAND, INC. D/B/A RITE AID MID-ATLANTIC CUSTOMER
SUPPORT CENTER, INC.
ROBERT D. HARVEY
ROBERT GENE RAND
ROSEBAY MEDICAL COMPANY L.P.
SAFEWAY INC. dba SAFEWAY PHARMACY #2255
SCOLARI’S FOOD & DRUG COMPANY aka SCOLARI’S PHARMACY #23
SCOLARI’S WAREHOUSE MARKETS, INC.
SHOUPING LI
SMITH’S FOOD & DRUG CENTERS, INC. D/B/A PEYTON’S PHOENIX
SPECGX LLC
STEVEN A HOLPER MD PROFESSIONAL CORPORATION;
STEVEN A. HOLPER
SUNRISE LEE
TEVA PHARMACEUTICAL INDUSTRIES, LTD.
TEVA PHARMACEUTICALS USA.
THE KROGER CO
THE PILL BOX LLC dba THE PILL BOX

3
 EXHIBIT C

THE PURDUE FREDERICK COMPANY, INC. d/b/a THE PURDUE FREDERICK

COMPANY INC.
THE PURDUE FREDERICK COMPANY, INC.
THERESA SACKLER
THRIFTY PAYLESS, INC
WALGREEN CO.
WALGREEN EASTERN CO., INC
WALGREENS BOOTS ALLIANCE, INC.;
WALMART INC.
WATSON LABORATORIES, INC.
WATSON PHARMACEUTICALS, INC. n/k/a ACTAVIS, INC.

4
 EXHIBIT D

LOCAL GOVERNMENTS ALLOCATION (38.77%)

Government Entity Percentage
CARSON CITY 1.075935%
CHURCHILL COUNTY 0.326145%
CLARK COUNTY 66.975937%
DOUGLAS COUNTY 1.045568%
ELKO COUNTY 0.637853%
ESMERALDA COUNTY 0.047413%
EUREKA COUNTY 0.143721%
HUMBOLDT COUNTY 1.000680%
LANDER COUNTY 0.548128%
LINCOLN COUNTY 0.198633%
LYON COUNTY 0.685710%
MINERAL COUNTY 0.734928%
NYE COUNTY 1.026687%
PERSHING COUNTY 0.514733%
STOREY COUNTY 0.130572%
WASHOE COUNTY 6.841995%
WHITE PINE COUNTY 1.235851%
BOULDER CITY 0.214114%
ELY CITY 0.009582%
FERNLEY CITY 0.020925%
HENDERSON CITY 3.333451%
LAS VEGAS CITY 6.835696%
MESQUITE CITY 0.212146%
NORTH LAS VEGAS CITY 3.512749%
RENO CITY 1.963939%
SPARKS CITY 0.615879%
WEST WENDOVER CITY 0.081671%
CENTRAL LYON FIRE PROTECTION DISTRICT 0.021854%
NORTH LYON FIRE PROTECTION DISTRICT 0.007505%
 EXHIBIT E

MEDICAID MATCH ALLOCATION (17.37%)

(65:14:21 - Population)
Government Entity Percentage
CARSON CITY 3.434222%
CHURCHILL COUNTY 1.529849%
CLARK COUNTY 65%
DOUGLAS COUNTY 3.003624%
ELKO COUNTY 3.241494%
ESMERALDA COUNTY 0.053617%
EUREKA COUNTY 0.124616%
HUMBOLDT COUNTY 1.033718%
LANDER COUNTY 0.339762%
LINCOLN COUNTY 0.318327%
LYON COUNTY 3.532121%
MINERAL COUNTY 0.276686%
NYE COUNTY 2.857327%
PERSHING COUNTY 0.413033%
STOREY COUNTY 0.253224%
WASHOE COUNTY 14%
WHITE PINE COUNTY 0.588380%
 EXHIBIT F

LITIGATING COUNTIES ALLOCATION

Government Entity Percentage
CARSON CITY 1.325117%
CHURCHILL COUNTY 0.401679%
CLARK COUNTY 82.487271%
DOUGLAS COUNTY 1.287717%
ESMERALDA COUNTY 0.058394%
HUMBOLDT COUNTY 1.232434%
LINCOLN COUNTY 0.244635%
LYON COUNTY 0.844517%
MINERAL COUNTY 0.905134%
NYE COUNTY 1.264463%
WASHOE COUNTY 8.426571%
WHITE PINE COUNTY 1.522068%