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Date: 10-21-2020

Case Style:

United States of America v. Purdue Pharma, L.P.

Case Number:

Judge:

Court: United States District Court for the Southern District of New York (New York County)

Plaintiff's Attorney: Deputy Attorney General Jeffrey A. Rosen; Acting Assistant Attorney General of the Civil Division Jeffrey Clark; U.S. Attorney for the District of Vermont Christina Nolan; and First Assistant U.S. Attorney for the District of New Jersey Rachael Honig. The criminal investigation was conducted by the U.S. Attorney’s Offices for the Districts of New Jersey and Vermont, the Consumer Protection Branch of the Department of Justice’s Civil Division, and the FBI’s Washington, D.C. and Newark Field Offices, with assistance by DEA. The civil settlements were handled by the Fraud Section of the Commercial Litigation Branch of the Department of Justice’s Civil Division, and the U.S. Attorney’s Offices for the Districts of New Jersey and Vermont, with assistance from the Department of Health and Human Services, Office of General Counsel and Office of Counsel to the Inspector General; the Defense Health Agency; and the Office of Personnel Management. The Purdue bankruptcy matter is being handled by the U.S. Attorney’s Office for the Southern District of New York and the Civil Division’s Commercial Litigation Branch, Corporate/Finance Section.

Defendant's Attorney: Garrett Lynam, Theodore V. Wells, Jr., Roberto Finzi, Mary Jo White, Jeffrey J. Rosen and Maura K. Monaghan

Description: New York, NY - The United States of America charged Purdue Pharma, L.P. on civil and criminal theories relating to the manufacture and sale of opoids by the Sackler family.

“The abuse and diversion of prescription opioids has contributed to a national tragedy of addiction and deaths, in addition to those caused by illicit street opioids,” said Deputy Attorney General Jeffrey A. Rosen. “With criminal guilty pleas, a federal settlement of more than $8 billion, and the dissolution of a company and repurposing its assets entirely for the public’s benefit, the resolution in today’s announcement re-affirms that the Department of Justice will not relent in its multi-pronged efforts to combat the opioids crisis.”

“Today’s resolution is the result of years of hard work by the FBI and its partners to combat the opioid crisis in the U.S.,” said Steven M. D’Antuono, Assistant Director in Charge of the FBI Washington Field Office. “Purdue, through greed and violation of the law, prioritized money over the health and well-being of patients. The FBI remains committed to holding companies accountable for their illegal and inexcusable activity and to seeking justice, on behalf of the victims, for those who contributed to the opioid crisis.”

“The opioid epidemic remains a significant public health challenge that impacts the lives of men and women across the country,” said Gary L. Cantrell Deputy Inspector General for Investigations at the U.S. Department of Health and Human Services’ Office of Inspector General. “Unfortunately, Purdue’s reckless actions and violation of the law senselessly risked patients’ health and well-being. With our law enforcement partners, we will continue to combat the opioid crisis, including holding the pharmaceutical industry and its executives accountable.”

“This resolution closes a particularly sad chapter in the ongoing battle against opioid addiction,” said Drug Enforcement Administration (DEA) Assistant Administrator Tim McDermott. “Purdue Pharma actively thwarted the United States’ efforts to ensure compliance and prevent diversion. The devastating ripple effect of Purdue’s actions left lives lost and others addicted. DEA will continue to work tirelessly with our partners and the pharmaceutical industry to address the damage that has been done, and bring an end to this epidemic that has gripped the nation for far too long.”

Purdue Pharma has agreed to plead guilty in federal court in New Jersey to a three-count felony information charging it with one count of dual-object conspiracy to defraud the United States and to violate the Food, Drug, and Cosmetic Act, and two counts of conspiracy to violate the Federal Anti-Kickback Statute. The criminal resolution includes the largest penalties ever levied against a pharmaceutical manufacturer, including a criminal fine of $3.544 billion and an additional $2 billion in criminal forfeiture. For the $2 billion forfeiture, the company will pay $225 million on the effective date of the bankruptcy, and, as further explained below, the department is willing to credit the value conferred by the company to State and local governments under the department’s anti-piling on and coordination policy. Purdue has also agreed to a civil settlement in the amount of $2.8 billion to resolve its civil liability under the False Claims Act. Separately, the Sackler family has agreed to pay $225 million in damages to resolve its civil False Claims Act liability.

The resolutions do not include the criminal release of any individuals, including members of the Sackler family, nor are any of the company’s executives or employees receiving civil releases.

While the global resolution with the company is subject to approval by the bankruptcy court in the Southern District of New York, one important condition in the resolution is that the company would cease to operate in its current form and would instead emerge from bankruptcy as a public benefit company (PBC) owned by a trust or similar entity designed for the benefit of the American public, to function entirely in the public interest. Indeed, not only will the PBC endeavor to deliver legitimate prescription drugs in a manner as safe as possible, but it will aim to donate, or provide steep discounts for, life-saving overdose rescue drugs and medically assisted treatment medications to communities, and the proceeds of the trust will be directed toward State and local opioid abatement programs. Based on the value that would be conferred to State and local governments through the PBC, the department is willing to credit up to $1.775 billion against the agreed $2 billion forfeiture amount. The department looks forward to working with the creditor groups in the bankruptcy in charting the path forward for this PBC so that its public health goals can be best accomplished.

The Criminal Pleas

As part of the plea, Purdue will admit that from May 2007 through at least March 2017, Purdue conspired to defraud the United States by impeding the lawful function of the DEA by representing to the DEA that Purdue maintained an effective anti-diversion program when, in fact, Purdue continued to market its opioid products to more than 100 health care providers whom the company had good reason to believe were diverting opioids and by reporting misleading information to the DEA to boost Purdue’s manufacturing quotas. The misleading information comprised prescription data that included prescriptions written by doctors that Purdue had good reason to believe were engaged in diversion. The conspiracy also involved aiding and abetting violations of the Food, Drug, and Cosmetic Act by facilitating the dispensing of its opioid products, including OxyContin, without a legitimate medical purpose, and thus without lawful prescriptions.

In addition, Purdue will admit to conspiring to violate the Federal Anti-Kickback Statute. Between June 2009 and March 2017, Purdue made payments to two doctors through Purdue’s doctor speaker program to induce those doctors to write more prescriptions of Purdue’s opioid products. Similarly, from approximately April 2016 through December 2016, Purdue made payments to Practice Fusion Inc., an electronic health records company, in exchange for referring, recommending, and arranging for the ordering of Purdue’s extended release opioid products – OxyContin, Butrans, and Hysingla.

The Civil Settlements

The department’s civil settlements resolve the United States’ claims as to both Purdue and its individual shareholders, members of the Sackler family.

The civil settlement with Purdue provides the United States with an allowed, unsubordinated, general unsecured bankruptcy claim for recovery of $2.8 billion. This settlement resolves allegations that from 2010 to 2018, Purdue caused false claims to be submitted to federal health care programs, specifically Medicare, Medicaid, TRICARE, the Federal Employees Health Benefits Program, and the Indian Health Service. The government alleged that Purdue promoted its opioid drugs to health care providers it knew were prescribing opioids for uses that were unsafe, ineffective, and medically unnecessary, and that often led to abuse and diversion. For example, Purdue learned that one doctor was known by patients as “the Candyman” and was prescribing “crazy dosing of OxyContin,” yet Purdue had sales representatives meet with the doctor more than 300 times. It also resolves the government’s allegations that Purdue engaged in three different kickback schemes to induce prescriptions of its opioids. First, Purdue paid certain doctors ostensibly to provide educational talks to other health care professionals and serve as consultants, but in reality to induce them to prescribe more OxyContin. Second, Purdue paid kickbacks to Practice Fusion, as described above. Third, Purdue entered into contracts with certain specialty pharmacies to fill prescriptions for Purdue’s opioid drugs that other pharmacies had rejected as potentially lacking medical necessity.

Under a separate civil settlement, individual members of the Sackler family will pay the United States $225 million arising from the alleged conduct of Dr. Richard Sackler, David Sackler, Mortimer D.A. Sackler, Dr. Kathe Sackler, and Jonathan Sackler (the Named Sacklers). This settlement resolves allegations that, in 2012, the Named Sacklers knew that the legitimate market for Purdue’s opioids had contracted. Nevertheless, they requested that Purdue executives recapture lost sales and increase Purdue’s share of the opioid market. The Named Sacklers then approved a new marketing program beginning in 2013 called “Evolve to Excellence,” through which Purdue sales representatives intensified their marketing of OxyContin to extreme, high-volume prescribers who were already writing “25 times as many OxyContin scripts” as their peers, causing health care providers to prescribe opioids for uses that were unsafe, ineffective, and medically unnecessary, and that often led to abuse and diversion.

The civil settlement also resolves the government’s allegations that from approximately 2008 to 2018, at the Named Sacklers’ request, Purdue transferred assets into Sackler family holding companies and trusts that were made to hinder future creditors, and/or were otherwise voidable as fraudulent transfers.

Today’s resolution does not resolve claims that states may have against Purdue or members of the Sackler family, nor does it impede the debtors’ ability to recover any fraudulent transfers.


SETTLEMENT AGREEMENT
This Settlement Agreement (“Agreement”) is entered into among the United States of
America, acting through the United States Department of Justice and on behalf of the Office of
Inspector General (OIG-HHS) of the Department of Health and Human Services (HHS); the
Defense Health Agency (DHA), acting on behalf of the TRICARE program; the Office of
Personnel Management (OPM), which administers the Federal Employees Health Benefits
Program (FEHBP); and the Indian Health Service (IHS) (collectively, the “United States”), and
Dr. Richard Sackler, David Sackler, Mortimer D.A. Sackler, Kathe Sackler, and the Estate of
Jonathan Sackler (collectively, the “Named Sacklers” and, with the United States, “the Parties”),
through their authorized representatives.1
RECITALS
A. The Named Sacklers are beneficiaries of trusts that indirectly own Purdue
Pharma, L.P. (“Purdue”).
B. Purdue is a Delaware Limited Partnership that is headquartered in Stamford,
Connecticut.
C. At all relevant times, Purdue, directly or through its subsidiaries, manufactured,
marketed, and sold pharmaceutical products in the United States, including OxyContin.
OxyContin is a branded, extended-release oxycodone tablet. Oxycodone is an opioid agonist 1.5
times more powerful than morphine with a high potential for addiction, abuse, and misuse.
OxyContin is approved by HHS’s Food and Drug Administration (FDA) for the management of
pain severe enough to require daily, around-the-clock, long-term opioid treatment and for which
1 To the extent the term ‘Named Sacklers’ appears in Recital A, Recital E, and the second
sentence of Recital F, in those instances the term includes Jonathan Sackler, rather than the
Estate of Jonathan Sackler.
alternative treatment options are inadequate. It is classified as a Schedule II narcotic under the
Controlled Substances Act, 21 U.S.C. § 801 et seq.
D. On September 15 and 16, 2019, Purdue and approximately twenty-three related
and affiliated entities each filed voluntary petitions under Chapter 11 of Title 11 of the United
States Code in the United States Bankruptcy Court for the Southern District of New York (the
“Debtors”). The Debtors are operating their businesses and managing their properties as debtors
in possession pursuant to section 1107(a) and 1108 of the Bankruptcy Code. On September 18,
2019, the Bankruptcy Court entered an order authorizing the joint administration and procedural
consolidation of the Debtors’ chapter 11 cases (the “Chapter 11 Cases”)2 pursuant to Rule
1015(b) for the Federal Rules of Bankruptcy Procedure under the case caption In re Purdue
Pharma L.P., et al., No. 19-23649 (Bankr. S.D.N.Y.) (Jointly Administered).
E. The United States contends that the Named Sacklers caused to be submitted
claims for payment to the Medicare Program, Title XVIII of the Social Security Act, 42 U.S.C.
§§ 1395-1395lll (“Medicare”); the Medicaid Program, 42 U.S.C. §§ 1396-1396w-5
(“Medicaid”); the TRICARE Program, 10 U.S.C. §§ 1071-1110b (“TRICARE”); and the
FEHBP, 5 U.S.C. §§ 8901-8914; and caused purchases of OxyContin by the IHS on behalf of its
federally operated programs, i.e., programs not operated by a tribal health program or an Urban
2 The Debtors in these cases, along with the last four digits of each Debtor’s registration number
in the applicable jurisdiction, are as follows: Purdue Pharma L.P. (7484), Purdue Pharma Inc.
(7486), Purdue Transdermal Technologies L.P. (1868), Purdue Pharma Manufacturing L.P.
(3821), Purdue Pharmaceuticals L.P. (0034), Imbrium Therapeutics L.P. (8810), Adlon
Therapeutics L.P. (6745), Greenfield BioVentures L.P. (6150), Seven Seas Hill Corp. (4591),
Ophir Green Corp. (4594), Purdue Pharma of Puerto Rico (3925), Avrio Health L.P. (4140),
Purdue Pharmaceutical Products L.P. (3902), Purdue Neuroscience Company (4712), Nayatt
Cove Lifescience Inc. (7805), Button Land L.P. (7502), Rhodes Associates L.P. (N/A), Paul
Land Inc. (7425), Quidnick Land L.P. (7584), Rhodes Pharmaceuticals L.P. (6166), Rhodes
Technologies (7143), UDF LP (0495), SVC Pharma LP (5717) and SVC Pharma Inc. (4014).
Indian organization, as those terms are defined in the Indian Health Care Improvement Act, 25
U.S.C. § 1603(25), (29) (collectively, the “Federal Healthcare Programs”).
F. The United States contends that it has certain civil claims against the Named
Sacklers as specified in Paragraph 4 below, for engaging in the conduct set forth in Addendum A
(hereinafter, the Covered Conduct). As a result of the conduct set forth in Addendum A, the
United States alleges that, from 2013 to 2018, the Named Sacklers knowingly caused false
and/or fraudulent claims for OxyContin to be submitted to the Federal Healthcare Programs.
G. This Agreement is neither an admission of liability by the Named Sacklers nor a
concession by the United States that the claims of the United States are not well founded. The
Named Sacklers expressly deny the allegations regarding the Covered Conduct.
To avoid the delay, uncertainty, inconvenience, and expense of protracted litigation of the
above claims, and in consideration of the mutual promises and obligations of this Settlement
Agreement, the Parties agree and covenant as follows:
TERMS AND CONDITIONS
1. The Named Sacklers shall pay or cause to be paid to the United States twohundred
twenty-five million ($225,000,000) plus interest on the Settlement Amount at the rate of
0.75% from November 5, 2020 (“Settlement Amount”), by electronic funds transfer pursuant to
written instructions to be provided by the Civil Division of the Department of Justice, on the
later of (i) fifteen (15) days after the Effective Date of this Agreement; or (ii) three (3) business
days after the date on which the Bankruptcy Court grants a Motion to Confirm (as defined in
Paragraph 2).
2. No later than two business days after the Effective Date, the Named Sacklers will
file in the Chapter 11 Cases a Notice of Settlement with the United States Department of Justice
and Motion to Confirm That Payment Thereunder Is Not Prohibited (“Motion to Confirm”). To
the extent that any funds transferred to the United States in payment of the Named Sacklers’
obligations in Paragraph 1 derive directly or indirectly from transfers from the Debtors, the
Named Sacklers will expressly disclose these facts to the Bankruptcy Court and obtain an order
from the Bankruptcy Court confirming in advance of paying the Settlement Amount that
payment is not prohibited. If the Bankruptcy Court denies the Motion to Confirm, the Motion to
Confirm is not granted in full, or the relief or Bankruptcy Court’s Order is not consistent with the
terms and conditions of this Agreement, the United States may, in its sole discretion, rescind the
Agreement.
3. The entirety of the Settlement Amount is not tax-deductible. Neither the Sacklers
nor the Released Parties as defined in Paragraph 4 will treat any portion of the Settlement
Amount as, or represent that any portion of the Settlement Amount is, tax deductible.
4. Subject to the exceptions in Paragraph 8 (concerning excluded claims) below, and
conditioned upon the full payment of the Settlement Amount, the United States releases the
Named Sacklers, their family members and the family trusts, current and former trustees and
protectors (solely in their capacity as trustees and protectors), all as identified in Addendum B
and the Purdue parent entities and the independent associated companies, all as identified in
Addendum C (collectively the “Released Family Members, Trust Parties and Entities”) from any
civil or administrative monetary claim, whether in rem or in personam, that the United States has
based on the Covered Conduct or that seeks to recover funds distributed as part of the Covered
Conduct by Purdue, under the False Claims Act, 31 U.S.C. §§ 3729-3733; the Food, Drug and
Cosmetic Act, 21 U.S.C. § 301 et seq.; the Controlled Substances Act, 21 U.S.C. § 801 et seq.;
the Civil Monetary Penalties Law, 42 U.S.C. § 1320a-7a; the Program Fraud Civil Remedies
Act, 31 U.S.C. §§ 3801-3812; the Federal Debt Collection Procedures Act, 28 U.S.C. §§
3304(a)(1), (b)(1)(A), and (b)(1)(B); Civil Forfeiture, 18 U.S.C. § 981(a)(1)(C); any statutory
provision creating a cause of action for civil damages or civil penalties which the Civil Division
of the Department of Justice has actual or present authority to assert and compromise pursuant to
28 C.F.R. Pt. 0.45(d) and 0.45(j); or the common law theories of payment by mistake, unjust
enrichment, disgorgement, fraud, and, if applicable, breach of contract. In addition, subject to
the exceptions in Paragraph 8 (concerning excluded claims) below, and conditioned upon the full
payment of the Settlement Amount, the United States releases the transferees of funds originally
distributed by Purdue (collectively, the “Released Transferees”) from any civil or administrative
monetary claim, whether in rem or in personam, that the United States has that seeks to recover
funds distributed as part of the Covered Conduct by Purdue under the Federal Debt Collection
Procedures Act, 28 U.S.C. §§ 3304(a)(1), (b)(1)(A), and (b)(1)(B) or Civil Forfeiture, 18 U.S.C.
§ 981(a)(1)(C). The Released Family Members, Trust Parties and Entities and the Released
Transferees are hereinafter referred to, collectively, as the “Released Parties.” Nothing in this
Agreement releases any claims the Debtors’ estates have the ability to bring, including but not
limited to fraudulent transfer claims and any claims that could be brought by the Debtors’ estates
by standing in the shoes of any creditors in the Chapter 11 Cases against any individuals or nondebtor
entities, including without limitation, the Debtors’ current or former owners, shareholders,
or members of their Boards of Directors.
5. OIG-HHS expressly reserves all rights to institute, direct, or maintain any
administrative action seeking exclusion against the Named Sacklers and any of the Released
Parties from Medicare, Medicaid, and all other Federal health care programs (as defined in 42
U.S.C. § 1320a-7b(f)) under 42 U.S.C. § 1320a-7(a) (mandatory exclusion), or 42 U.S.C.
§ 1320a-7(b) or 42 U.S.C. § 1320a-7a (permissive exclusion).
6. DHA expressly reserves all rights to institute, direct, or maintain any
administrative action seeking exclusion against the Named Sacklers and any of the Released
Parties from TRICARE under 32 C.F.R. § 199.9(f) (mandatory and permissive exclusions).
7. OPM expressly reserves all rights to institute, direct, or maintain any
administrative action seeking debarment against the Named Sacklers and any of the Released
Parties from the FEHBP under 5 U.S.C. § 8902a(b) (mandatory debarment), or (c) and (d)
(permissive debarment).
8. Notwithstanding the release given in Paragraph 4 of this Agreement, or any other
term of this Agreement, the following claims of the United States are specifically reserved and
are not released:
a. Any liability arising under Title 26, U.S. Code (Internal Revenue Code);
b. Any criminal liability;
c. Except as explicitly stated in this Agreement, any administrative liability,
including mandatory or permissive exclusion from Federal health care
programs;
d. Any liability to the United States (or its agencies) for any conduct other
than the Covered Conduct;
e. Any liability based upon obligations created by this Agreement;
f. Any liability of individuals or entities other than the Released Parties;
g. Any liability for personal injury or property damage (or for consequential
damages arising therefrom);
h. Any liability for claims of the states or Indian tribes in the Chapter 11
Cases or otherwise, and no setoff related to amounts paid under this
Agreement shall be applied to any recovery in connection with any claim,
action, or recovery by the states or Indian tribes;
i. For avoidance of doubt, the United States, except as expressly
contemplated by this settlement, retains all rights to recover, pursuant to
42 U.S.C. 1396b(d), the federal share of funds that have been or could be
recovered by other entities; and
j. Any liability for the following actions:
1. United States ex rel. Manchester v. Purdue Pharma, L.P., et al., No.
1:16-cv-10947 (D. Mass.); and
2. United States ex rel. [Sealed] v. [Sealed] (D. Vt.).
No setoff related to amounts paid under this Agreement shall be applied to
a recovery, if any, in connection with these actions.
9. The Released Parties agree that no amounts paid under this Agreement will be
applied to reduce amounts paid or to be paid by the Released Parties or on their behalf to the
Debtors or creditors in the Chapter 11 Cases, including pursuant to the Summary Term Sheet
filed with Bankruptcy Court, Dkt. No. 257.
10. The Released Parties waive and shall not assert any defenses they may have to
any criminal prosecution or administrative action relating to the Covered Conduct that may be
based in whole or in part on a contention that, under the Double Jeopardy Clause in the Fifth
Amendment of the Constitution, or under the Excessive Fines Clause in the Eighth Amendment
of the Constitution, this Agreement bars a remedy sought in such criminal prosecution or
administrative action.
11. The Released Parties fully and finally release the United States, its agencies,
officers, agents, employees, and servants, from any claims (including attorney’s fees, costs, and
expenses of every kind and however denominated) that the Released Parties asserted, could have
asserted, or may assert in the future against the United States, and its agencies, officers, agents,
employees, and servants related to the Covered Conduct and the United States’ investigation and
prosecution.
12. The Settlement Amount shall not be decreased as a result of the denial of claims
for payment now being withheld from payment by any Medicare contractor (e.g., Medicare
Administrative Contractor, fiscal intermediary, carrier), TRICARE, FEHB, or any state payer,
related to the Covered Conduct; and the Released Parties agree not to resubmit to any Medicare
contractor, TRICARE, FEHB, or any state payer any previously denied claims related to the
Covered Conduct, agrees not to appeal any such denials of claims, and agrees to withdraw any
such pending appeals.
13. The Released Parties agree to the following:
a. Unallowable Costs Defined: All costs (as defined in the Federal
Acquisition Regulation, 48 C.F.R. § 31.205-47; and in Titles XVIII and XIX of the Social
Security Act, 42 U.S.C. §§ 1395-1395lll-1 and 1396-1396w-5; and the regulations and official
program directives promulgated thereunder) incurred by or on behalf of the Released Parties in
connection with:
(1) the matters covered by this Agreement;
(2) the United States’ audit(s) and civil and any criminal investigation(s) of
the matters covered by this Agreement;
(3) the Released Parties’ investigation, defense, and corrective actions
undertaken in response to the United States’ audit(s) and civil and any
criminal investigation(s) in connection with the matters covered by this
Agreement (including attorney’s fees);
(4) the negotiation and performance of this Agreement; and
(5) the payment the Released Parties make to the United States pursuant to
this Agreement
are unallowable costs for government contracting purposes and under the Federal Healthcare
Programs (hereinafter referred to as Unallowable Costs).
b. Future Treatment of Unallowable Costs: Unallowable Costs shall be
separately determined and accounted for by the Released Parties, and the Released Parties shall
not charge such Unallowable Costs directly or indirectly to any contracts with the United States
or any State Medicaid program, or seek payment for such Unallowable Costs through any cost
report, cost statement, information statement, or payment request submitted by the Released
Parties or any of its subsidiaries or affiliates to the Federal Healthcare Programs.
c. Treatment of Unallowable Costs Previously Submitted for Payment: The
Released Parties further agree that within 90 days of the Effective Date of this Agreement it shall
identify to applicable Medicare and TRICARE fiscal intermediaries, carriers, and/or contractors,
and Medicaid and FEHBP fiscal agents, any Unallowable Costs (as defined in this Paragraph)
included in payments previously sought from the United States, or any State Medicaid program,
including, but not limited to, payments sought in any cost reports, cost statements, information
reports, or payment requests already submitted by the Released Parties or any of its subsidiaries
or affiliates, and shall request, and agree, that such cost reports, cost statements, information
reports, or payment requests, even if already settled, be adjusted to account for the effect of the
inclusion of the unallowable costs. The Released Parties agree that the United States, at a
minimum, shall be entitled to recoup from the Released Parties any overpayment plus applicable
interest and penalties as a result of the inclusion of such Unallowable Costs on previouslysubmitted
cost reports, information reports, cost statements, or requests for payment.
Any payments due after the adjustments have been made shall be paid to the United
States pursuant to the direction of the Department of Justice and/or the affected agencies. The
United States reserves its rights to disagree with any calculations submitted by the Released
Parties or any of their owned or controlled entities of the effect of inclusion of Unallowable
Costs (as defined in this Paragraph) on the Released Parties or any of their owned or controlled
entities’ cost reports, cost statements, or information reports.
d. Nothing in this Agreement shall constitute a waiver of the rights of the
United States to audit, examine, or re-examine the Released Parties’ or their owned or controlled
entities’ books and records to determine that no Unallowable Costs have been claimed in
accordance with the provisions of this Paragraph.
14. This Agreement is intended to be for the benefit of the Parties only. The Parties
do not release any claims against any other person or entity, except to the extent provided for in
Paragraph 4 (Released Parties) and Paragraph 15 (waiver for beneficiaries paragraph), below.
15. The Released Parties agree that they waive and shall not seek payment for any of
the health care billings covered by this Agreement from any health care beneficiaries or their
parents, sponsors, legally responsible individuals, or third party payors based upon the claims
defined as Covered Conduct.
16. In exchange for valuable consideration provided in this Agreement, the Named
Sacklers acknowledge the following:
a. The Named Sacklers have reviewed their respective financial situations
and warrant that they are solvent within the meaning of 11 U.S.C. §§ 547(b)(3) and
548(a)(1)(B)(ii)(I) and shall remain solvent following payment to the United States of the
Settlement Amount.
b. In evaluating whether to execute this Agreement, the Parties and the
Released Parties intend that the mutual promises, covenants, and obligations set forth herein
constitute a contemporaneous exchange for new value given to the Named Sacklers, within the
meaning of 11 U.S.C. § 547(c)(1), and the Parties conclude that these mutual promises,
covenants, and obligations do, in fact, constitute such a contemporaneous exchange.
c. The mutual promises, covenants, and obligations set forth herein are
intended by the Parties to, and do in fact, constitute a reasonably equivalent exchange of value.
d. The Parties do not intend to hinder, delay, or defraud any entity to which
the Named Sacklers were or became indebted to on or after the date of any transfer contemplated
in this Agreement, within the meaning of 11 U.S.C. § 548(a)(1).
e. If the Named Sacklers’ obligations under this Agreement are avoided or
rescinded for any reason (including, but not limited to, (i) through the exercise of a trustee’s
avoidance powers under the Bankruptcy Code or (ii) by the United States pursuant to Paragraph
2 (Motion to Confirm)); if the United States is required to return, disgorge, or otherwise remit
any of the Settlement Amount; or if, before the Settlement Amount is paid in full, any of the
Named Sacklers or a third party commences a case, proceeding, or other action under any law
relating to bankruptcy, insolvency, reorganization, or relief of debtors seeking any order for
relief of the Named Sacklers’ debts, or to adjudicate the Named Sacklers as bankrupt or
insolvent, or seeking appointment of a receiver, trustee, custodian, or other similar official for the
Named Sacklers or for all or any substantial part of the Named Sacklers’ assets, the United States
may elect, in its sole discretion:
(a) to rescind the releases in this Agreement and bring any civil and/or
administrative claim, action, or proceeding against the Released Parties for the claims that
would otherwise be covered by the releases provided in Paragraph 4 above; or
(b) in the event of bankruptcy, to have an undisputed, noncontingent, and
liquidated allowed claim against the Named Sacklers for at least the Settlement Amount, less
any payments received pursuant to this Agreement that are not otherwise avoided and recovered
from the United States.
f. The Named Sacklers agree that any civil and/or administrative claim,
action, or proceeding brought by the United States under Paragraph 16(e) is not subject to an
"automatic stay" pursuant to 11 U.S.C. § 362(a) because it would be an exercise of the United
States’ police and regulatory power. The Named Sacklers shall not argue or otherwise contend
that the United States' claim, action, or proceeding is subject to an automatic stay and, to the
extent necessary, consents to relief from the automatic stay for cause under 11 U.S.C. §
362(d)(1).
17. In the event that this Agreement is nullified or rescinded for any reason or in the
event the Named Sacklers’ obligations under this Agreement are avoided for any reason, the
Released Parties will not plead, argue or otherwise raise any defenses under the theories of
statute of limitations, laches, estoppel or similar theories, to any civil or administrative claims,
actions or proceedings that are brought by the United States within 180 calendar days of written
notification to the Released Parties that the releases have been rescinded, except to the extent
such defenses were available on January 15, 2020.
18. Each Party shall bear its own legal and other costs incurred in connection with
this matter, including the preparation and performance of this Agreement.
19. Each party and signatory to this Agreement represents that it freely and
voluntarily enters in to this Agreement without any degree of duress or compulsion.
20. This Agreement is governed by the laws of the United States. The exclusive
jurisdiction and venue for any dispute relating to this Agreement is the United States District
Court for the District of New Jersey. For purposes of construing this Agreement, this Agreement
shall be deemed to have been drafted by all Parties to this Agreement and shall not, therefore, be
construed against any Party for that reason in any subsequent dispute.
21. This Agreement constitutes the complete agreement between the Parties. This
Agreement may not be amended except by written consent of the Parties.
22. The undersigned counsel represent and warrant that they are fully authorized to
execute this Agreement on behalf of the persons and entities indicated below.
23. This Agreement may be executed in counterparts, each of which constitutes an
original and all of which constitute one and the same Agreement.
24. This Agreement is binding on the Released Parties’ successors, transferees, heirs,
and assigns.
25. All Parties consent to the United States’ disclosure of this Agreement, and
information about this Agreement, to the public.
26. This Agreement is effective on the date of signature of the last signatory to the
Agreement (“Effective Date of this Agreement”). Facsimiles and electronic transmissions of
signatures shall constitute acceptable, binding signatures for purposes of this Agreement.

ADDENDUM A TO SETTLEMENT AGREEMENT1
I. Introduction
1. Purdue Pharma L.P. and its affiliates (collectively, “Purdue”) is owned by trusts
for the benefit of the Sackler family. Members of the Sackler family previously served as
members of the board of directors of Purdue’s general partner, including, Dr. Richard Sackler,
Mortimer D. A. Sackler, Jonathan Sackler, Kathe Sackler, and David Sackler (the “Named
Sacklers”).
2. Purdue’s profits declined in 2010 after the introduction of its Reformulated
OxyContin, which was intended to be more difficult (though not impossible) to crush or
manipulate for purposes of abuse and misuse. The Named Sacklers and Purdue executives
tracked Purdue’s lost sales closely and regularly scrutinized sales reports and related data. They
attributed the majority of the decline to two trends: (i) individuals abusing opioids moving from
OxyContin to opioids that were easier to abuse through insufflation and injection and (ii)
increased scrutiny of prescribers, pharmacists, and other actors in the opioid distribution chain.
3. Although the Named Sacklers knew that the legitimate market for Purdue’s
opioids had contracted, the Named Sacklers nevertheless requested that Purdue executives
recapture lost sales and increase Purdue’s share of the opioid market.
4. As a result, of these requests, from at least 2013 through 2018, Purdue developed
an aggressive marketing program that focused on detailing over 100,000 doctors and nurse
practitioners nationwide each year, including thousands of prescribers that the Named Sacklers
knew or should have known were prescribing opioids that were not always for a medically
accepted indication; were sometimes unsafe, ineffective, and medically unnecessary; and that
1 All of the events, circumstances, and conduct described in this addendum constitute the
“Covered Conduct” as that term is used in the Settlement Agreement.
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were sometimes diverted for uses that lacked a legitimate medical purpose. By 2013, Purdue
intensified its detailing of the very highest-volume prescribers, i.e., those writing “25 times as
many OxyContin scripts” as their similarly situated peers, because Purdue and the Named
Sacklers knew that Purdue’s detailing was highly effective in causing these prescribers to write
more prescriptions for Purdue’s opioids. This strategy, referred to as the “Evolve to Excellence”
or “E2E” program, was approved by the Named Sacklers.
5. Through their approval of the E2E program, from 2013 to 2018, the Named
Sacklers knowingly caused the submission of false and fraudulent claims to federal health care
benefit programs for Purdue’s opioid drugs that were prescribed for uses that were unsafe,
ineffective, and medically unnecessary, and that were often diverted for uses that lacked a
legitimate medical purpose.
6. Around the same time, from approximately 2008 to 2018, at the Named Sacklers’
request, billions of dollars were transferred out of Purdue as cash distributions of profits and
transfers of assets into Sackler family holding companies and trusts. Certain of these
distributions and transfers were made with the intent to hinder future creditors and/or were
otherwise voidable as fraudulent transfers.
II. Organization of Purdue Pharma
7. Purdue carries on operations, including distributing and selling the extendedrelease
opioid drugs OxyContin, Butrans, and Hysingla. Prior to February 2018, it employed a
sales force of, at times, over five hundred representatives to market its opioid drugs.
8. Purdue was owned (through trusts) and controlled by the Sackler Family. From at
least 1996 through 2018, members of the Sackler family served at various points as directors,
officers, consultants and employees of Purdue. In these roles, members of the Sackler family
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directed and oversaw Purdue’s development, manufacture, marketing, promotion, sales, and
distribution of opioids, including OxyContin and interactions with the Drug Enforcement
Administration and the Food and Drug Administration, the Centers for Medicare & Medicaid
Services, and the Department of Health and Human Services.2
9. As Board members, the Named Sacklers were not merely passive recipients of
information.
10. Richard Sackler, Jonathan Sackler, and Kathe Sackler at times maintained offices
at Purdue’s headquarters.
11. Richard Sackler, Jonathan Sackler, Kathe Sackler, and Mortimer D.A. Sackler all
had direct communications with Purdue executives, including Sales and Marketing executives,
concerning forecasts and strategies. At times, Richard Sackler also directly communicated with
lower level employees. In addition, Richard Sackler, Mortimer D.A. Sackler, and Kathe Sackler
were involved in employment decisions regarding the CEO and Sales and Marketing leadership
positions.
12. The Named Sacklers, as members of the Purdue Board, exercised substantial
oversight over management’s operations of Purdue. In February of 2011, a memorandum
observed: “There seems to be a consensus that the role of the board and that of the management
is blurred compared with the distinctions made by other major corporations.” He further
observed that certain members of the Sackler family functioned as “executives, management,
2 The following reflects the tenures of the Sackler family members on the Purdue Pharma Inc.
Board of Directors: Richard S. Sackler (10/2/1990 – 7/24/2018); Jonathan D. Sackler (10/2/1990
– 12/8/2018); David A. Sackler (7/19/2012 – 8/14/2018); Kathe A. Sackler (10/2/1990 –
9/27/2018); Mortimer D.A. Sackler (1/15/1993 – 1/16/2019); Theresa E. Sackler (1/15/1993 –
9/7/2018); Ilene Sackler Lefcourt (10/2/1990 – 2/4/2005; 5/16/2008 – 10/9/2018); and Beverly
Sackler (approximately 1993 –10/2017).
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board, and shareholders all in one [and] worked collaboratively with other managers on a daily
basis.” As late as 2017, a high-level Purdue executive commented: “Three distinct business
types (branded Rx [including Purdue]/biosimilars, consumer/OTC, generics) are being run
through four separate regions (five if Rhodes is included), with the Board of Directors serving as
the ‘de-facto’ CEO.”
III. The Opioid Drugs Purdue Manufactured, Marketed, Promoted, and Sold
A. OxyContin
13. Oxycodone is an opioid agonist with a morphine milligram equivalent (“MME”)
of 1.5 and a high potential for abuse similar to other opioids including fentanyl, hydromorphone,
methadone, morphine, and oxymorphone.
14. It is classified as a Schedule II narcotic under the Controlled Substances Act, 21
U.S.C. § 801, et seq. (“CSA”).
15. Purdue manufactured, marketed, promoted, sold, and distributed OxyContin, a
branded extended-release oxycodone tablet, nationwide, including by sending sales
representatives to prescribers’ offices and pharmacies, to persuade healthcare providers to
prescribe and pharmacists to dispense OxyContin.
16. In April 2010, Purdue received FDA approval to market a reformulated version of
OxyContin (“Reformulated OxyContin”).
17. Reformulated OxyContin was more difficult to crush or dissolve, but FDA
cautioned that Reformulated OxyContin “is not completely tamper-resistant and those intent on
abusing this new formulation will likely find a means to do so. In addition, the product can still
be misused or abused and result in overdose by simply administering or ingesting larger than
recommended oral doses.”
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18. In August 2010, Purdue discontinued the original version of OxyContin.
B. Butrans
19. Buprenorphine is an opioid partial agonist with an MME of 12.6 that exposes
users to the risks of addiction, abuse, and misuse. It is classified as a Schedule III narcotic under
the CSA.
20. In June 2010, Purdue received FDA approval to market Butrans, a branded
buprenorphine patch, and began manufacturing, marketing, promoting, and selling Butrans
nationwide.
C. Hysingla
21. Hydrocodone is an opioid agonist with an MME of 1.0 that exposes users to the
risks of addiction, abuse, and misuse. It is classified as a Schedule II narcotic under the CSA.
22. In November 2014, Purdue received FDA approval to market Hysingla, a branded
hydrocodone tablet, and began manufacturing, marketing, promoting, and selling Hysingla
nationwide.
IV. The Named Sacklers Knowingly Caused Medically Unnecessary Prescriptions to
be Submitted to Federal Healthcare Programs
23. From 2013 to 2018, the Named Sacklers approved an initiative that intensified
marketing to high-volume prescribers and resulted in prescriptions of OxyContin that were
unsafe, ineffective, and medically unnecessary, and that were diverted for uses that lacked a
legitimate medical purpose. Such prescriptions are not reimbursable by Federal healthcare
programs.
24. The paragraphs below describe Purdue and the Named Sacklers’ scheme to cause
high-volume prescribers to write medically unnecessary OxyContin prescriptions for Federal
healthcare program beneficiaries.
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A. “Calling On” and “Detailing” Prescribers Causes Them to Write More
Prescriptions
25. The Named Sacklers knew or should have known that one of Purdue’s most
effective tools to increase and maintain opioid sales was to send sales representatives to
prescribers’ offices to meet with prescribers in person; deliver company-developed messaging;
give the prescribers meals (such as coffee, breakfast, and lunch) and marketing materials (such as
articles, brochures, posters, and other media); and provide information about pharmacies
stocking Purdue opioids and prescription coverage, including coverage under Federal healthcare
benefit programs.
26. This practice is known in the pharmaceutical industry as “calling on” or
“detailing” healthcare providers.
27. The Named Sacklers – through their many years in the pharmaceutical industry
and the data analyses and management reports to the Board that they received – knew that calling
on or detailing healthcare providers causes them to prescribe more of Purdue’s opioid drugs.
28. For example, the Named Sacklers received return-on-investment analyses
comparing the cost of detailing as compared to the OxyContin prescriptions that would not have
been written but for Purdue’s in-person marketing, as well as “sensitivity” analyses showing the
impact of Purdue’s detailing on OxyContin prescribing.
29. In sum, the Named Sacklers knew that detailing was one of the most effective
means for growing OxyContin sales and, for this reason, they took a particular interest in this
facet of Purdue’s marketing, requested regular briefings, and provided input on various
strategies. Indeed, Richard Sackler even went on a ride-along with at least one Purdue sales
representative to experience Purdue’s detailing in-person.
- 7 -
B. The Sales Revenue Purdue Calculated from Federal Healthcare Programs
30. The Named Sacklers knew that Federal healthcare programs paid claims for
Purdue’s opioid drugs, including OxyContin, and were informed by Purdue management reports
to the Board that those payments accounted for a significant percentage of Purdue’s revenue.
31. For example, an April 11, 2012, budget presentation to Purdue’s Board of
Directors showed that certain Federal healthcare benefit programs accounted for over 30% of
Purdue’s revenue from sales of OxyContin.
32. Additionally, Purdue developed messaging and marketing materials associated
with insurance coverage for OxyContin, including Federal healthcare program coverage, to
induce prescribers to write OxyContin prescriptions for Federal healthcare program
beneficiaries.
33. In sum, the Named Sacklers knew, or should have known, that Purdue’s
promotional activities for its drugs were a substantial factor in claims being submitted to Federal
healthcare programs.
C. Purdue’s Marketing of OxyContin After Reformulation.
34. Throughout the relevant time period, the Named Sacklers received regular
briefings from Purdue executives and employees concerning prescription trends and data, and,
through at least January 2014, Richard Sackler received weekly analyses of opioid prescribing
data.
35. Shortly after the introduction of Reformulated OxyContin in 2010, the Named
Sacklers received data and briefings showing that Purdue’s profits declined as some individuals
who abused OxyContin moved to more easily manipulated opioids.
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36. The Named Sacklers were also informed by Purdue management that during this
time period Purdue closely analyzed internal data not just with regard to overall sales trends, but
also to target high-volume prescribers and monitor their opioid prescriptions.
37. Purdue ranked the prescribers based on their aggregate opioid prescriptions in
deciles from numbers 1 through 10, with 10 being the highest.
D. Declining Sales and Higher Sales Goals
38. From 2010 to 2018, Purdue’s profits were almost entirely driven by its success in
selling OxyContin.
39. The Named Sacklers understood the importance of OxyContin’s sales’ success to
Purdue’s bottom line.
40. On January 25, 2010, Richard Sackler emailed other members of Purdue’s Board:
“By way of background, the most important driver of our sales growth or decline is the
performance of all the oxycodone extended release forms in the market (called OER); this is
comprised of OxyContin® tablets plus all the generics in the space.”
41. By virtue of OxyContin’s importance, the Named Sacklers were personally made
aware of sales targets, and at times challenged the targets set by Purdue executives.
42. In January 2010, Purdue executives and certain of the Named Sacklers engaged in
an exchange regarding the executives and other employees’ proposed 2010 budget.
43. Purdue executives and other employees proposed that OxyContin growth should
be pegged at 3%. Richard Sackler thought this target was too low and would “lead to an
OxyContin[] tablets forecast that is almost the same as our sales in 2009.” In response, Purdue’s
CEO informed Richard Sackler that “in looking at the recent [oxycodone extended release]
prescription growth trends and knowing the overall dynamics of the market OxyContin competes
- 9 -
in – I just can’t see a way of the prescription growth tracking to a level substantially higher than
the 3% on which this budget is based” and that the higher target suggested by Richard Sackler
would “be interpreted as an imposition as opposed to an action that will stimulate the type of
business building behaviors we want to encourage.”
44. In response, Richard Sackler, who believed that Purdue’s OxyContin growth
target should be much higher, told Purdue’s CEO “… I’m disappointed and don’t agree with
you. This is a matter that the Board will have to take up and give you a settled direction.”
45. Later that month, on January 25, 2010, Richard Sackler emailed the Board and
informed them that he had “engaged management on this subject,” referring to the proposed
2010 budget, and explained his view that management’s number was “unduly conservative.”
46. On the same day, Mortimer D.A. Sackler followed up with Theresa Sackler
regarding Richard’s proposal, stating “we should push management to agree to a higher target.”
47. After the release of Reformulated OxyContin in August 2010, OxyContin sales
immediately began to decline.
48. Purdue management presented information regarding the slipping demand for
Purdue’s OxyContin to Purdue’s Board in December 2010, showing that the total weekly
kilograms dispensed of branded OxyContin declined from August to November 2010.
49. This downward trend continued the following year. On or about June 15, 2011,
Purdue’s Associate Director of Forecasting Analytics prepared a memorandum to Purdue’s CEO,
among others, identifying an expected budget shortfall of over $1 billion. The memorandum
stated that “Kilograms dispensed have declined since the transition to the reformulated, primarily
due to fewer 40mg and 80mg tablets [,Purdue’s highest dosage tablets,] being dispensed.”
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50. In or around June 20, 2011, Purdue’s CFO shared this information with the Board
in a presentation stating, “Since the transition, 40 and 80mg tablet prescriptions have decreased
significantly. The 10mg and 20mg tablet prescriptions initially increased, but given their lower
value not enough to offset the higher strength decline.” The presentation went on to revise the
forecast of projected OxyContin sales from $3.9 billion to $2.8 billion.
51. Sales continued to trend downward in 2012.
52. On April 15, 2012, Richard Sackler emailed Purdue’s Vice President of Sales,
stating, “We should . . . discuss the sudden decline in [OxyContin] sales in the past year or two.
What are we doing to identify corrective actions?” The following day, the Vice President of
Sales forwarded Richard Sackler’s email to Purdue’s CEO, among others, stating, “I am
surprised that Dr. Richard is asking this. . . . Since the decline is related to reformulation I’m
not sure how to proceed with him.”
53. On July 17, 2012, Mortimer D.A. Sackler emailed fellow Purdue Board members
stating that Purdue should “start a search asap for a new CEO” and consider “replacing the head
of sales and marketing.”
54. In November 2012, looking back at the time period since Reformulated
OxyContin replaced original OxyContin, Purdue’s CEO reported to Purdue’s Board of Directors
that there was a “Decline in OxyContin [Prescriptions] From Late 2010 Through 2011.” The
CEO added that “2012 gross sales [of OxyContin] were 3.7% below budget [and] 2012 net sales
[of OxyContin] were 4.3% below budget due to lower prescription demand.”
55. In October 2013, Mortimer D.A. Sackler asked Purdue’s management for
additional data concerning the downward trend in sales by dosage, requesting a chart to “show
the breakdown of the OxyContin market share by strength against competitors. I would like to
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understand more the recent dynamics of the market and where the patients are shifting to that we
are losing.” Later that same day, responses to Mortimer’s questions explained that the loss of
sales was due to “the recent dynamics of the market,” the pressures of increased government
regulation, and that there were “fewer patients titrating to the higher strengths from the lower
ones.”
E. Post-Reformulation Decline Attributed to Medically Unnecessary Prescriptions
56. Purdue studied the drivers of the post-reformulation OxyContin sales decline, and
it attributed most of the decline to a reduction in medically unnecessary prescriptions, many of
which were written for abuse through insufflation or injection, and increases in safeguards
intended to hinder medically unnecessary prescribing.
57. Purdue also conducted a number of post-marketing studies of Reformulated
OxyContin.
58. Purdue’s studies and analyses showed that the decline in overall OxyContin
prescriptions was most pronounced among high-volume “Region Zero” prescribers and the
highest dosage tablets, the 40 mg and 80 mg tablets.
59. Purdue also attributed approximately 40% of the decline in OxyContin
prescriptions in 2010 and 2011 to “Region Zero” prescribers. Region Zero prescribers were
prescribers that Purdue instructed sales representatives not to call on because, based on
information maintained by its Abuse and Diversion Detection (“ADD”) Program, Purdue
determined that “there is a concern about potential abuse or diversion related activities” by them.
Purdue had detailed information (down to the number of prescriptions written, product, and
dosage) of Purdue products prescribed by Region Zero doctors and knew that Purdue had been
making a considerable profit from these prescriptions.
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60. Purdue knew that the remainder of prescribers who experienced a significant drop
in sales post-reformulation were not on Purdue’s Region Zero do-not-call list, meaning
representatives could continue detailing them.
61. In or around August 2010, the Named Sacklers, received a Board package that
included Region Zero sales data, including the names of Region Zero prescribers.
62. By December 1, 2010, the Named Sacklers were made aware of Purdue’s findings
concerning the drop in sales post-reformulation. Specifically, at a December Board briefing,
Purdue’s CEO discussed a chart stating that “Region 0 Accounts For Much Of The TRx Decline
At The Regional Level.”
63. In April 2011, Purdue prepared an excel sheet showing prescribers who
experienced significant drops in prescriptions post-reformulation. Among the 134 prescribers
listed in the prescription change analysis, Purdue was continuing to detail about one-third of
them. The spreadsheet specifically identified substantial declines in prescriptions for 80 mg
tablets.
64. On October 25, 2011, Purdue’s Board received a copy of Purdue’s September
Executive Committee Meeting Notes & Actions, which provided Board members with
information regarding the impact of Reformulated OxyContin on abuse.
65. Among the Board materials was a presentation stating that there was a “[d]ecline
in 80 mg prescriptions, esp[ecially] among ‘Do not Call’ prescribers,” and a “[s]hift in routes of
abuse, especially injecting and snorting.”
66. The study also found that some users continued to abuse Reformulated
OxyContin through insufflation or injection – albeit fewer of them. Among the remaining
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individuals who reported abusing OxyContin, the percentage reporting abuse through oral
ingestion rose from 52% to 75%.
67. The materials provided to the Board in October 2011 also included a study,
“Changes in Prescribing Patterns Following Introduction of Reformulated OxyContin: A
Window into Diversion.” The study examined a two-year period, August 2009 to July 2011, and
found that data for Region Zero prescribers showed an 86% decline in their OxyContin
prescriptions after Purdue’s introduction of its reformulated version, and especially at the highest
dosages, 40 and 80 mg tablets. The study found that prescribers suspected of abuse and
diversion also prescribed the highest dose (80 mg) of OxyContin more frequently than other
prescribers.
68. The study also found that Region Zero prescribers accounted for only 38.4% of
the overall decline in sales post-reformulation, which Purdue attributed to reduced abuse of
OxyContin. The remaining 61.6% of the decline was among other prescribers that were not on
Purdue’s Region Zero lists, meaning that sales representatives either were continuing to call on
these prescribers or were permitted to do so.
69. Figures in the presentation further showed that prescribing of immediate-release
oxycodone increased at a similar rate (an approximately 32% increase) to the decline in 80 mg
and 40 mg tablets of Reformulated OxyContin prescriptions (which experienced a 24% decrease
and 26% decrease, respectively) among the non-Region Zero comparator prescribers, indicating
that patients who had been abusing OxyContin may have been shifted to a non-reformulated
oxycodone product that they could continue to misuse.
70. Versions of the presentation, including at least one provided to Richard Sackler in
August 2013 at his request, repeated key findings, including: “Greater declines for doctors that
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were potentially problematic prescribers”; “Greater declines for high versus low dosage
strengths”; “A small number of prescribers contribute to a large proportion of potential diversion
of opioids from legal to illegal channels”; and “there were doctors in the [Purdue’s] database
who were prescribing painkillers ‘for what appears to be the wrong reasons.’”
71. In sum, the Named Sacklers knew, or should have known, that, after the release of
its Reformulated OxyContin, the product continued to be abused, but the primary method of
abuse shifted to abuse through oral ingestion. Furthermore, the Named Sacklers knew, or should
have known, that abuse and diversion appeared concentrated among a cohort of high-volume
prescribers. The Named Sacklers nevertheless endorsed a marketing effort beginning in 2013
focused on high-volume prescribers.
F. Decline in OxyContin Revenue Also Attributed to Safeguards Intended to Curb
Abuse and Diversion.
72. At the same time, Purdue also attributed declines in OxyContin prescription
revenue post-reformulation to safeguards intended to reduce medically unnecessary opioid sales,
including increased scrutiny of opioid prescribing by law enforcement, wholesalers, distributors,
and retail pharmacies.
73. For example, a Business Condition Report from a May 2-3, 2013 Board of
Directors Meeting described sales as being “$144mm behind Q12013 budget” and stated that
“[p]ossible causes of fewer tabs/Rx include increased state regulations, anti-opioid environment,
and increased DEA/law enforcement scrutiny of physicians, pharmacies and wholesalers.”
74. A consulting company that worked for Purdue since approximately the mid-2000s
similarly attributed the decline in sales, in large part, to both the reformulation and safeguards
against medically unnecessary prescriptions.
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75. In 2013, the consulting company informed Purdue and its Board, that “[t]he retail
channel, both pharmacies and distributors, is under intense scrutiny and direct risk.”
76. More specifically, the consulting company explained to Purdue and its Board
“[t]here are reports of wholesalers stopping shipments entirely to an increasing number of
pharmacies,” “[m]any wholesalers are also imposing hard quantity limits on orders based on
prior purchase levels,” and “[p]harmacy chains are implementing guidelines for which patients
can fill opioid prescriptions.”
77. Later, Purdue’s 2014 budget presentation to the Board listed these safeguards –
intended to prevent medically unnecessary prescriptions of opioids, including OxyContin –
among the “challenges” to achieving revenue goals.
78. Nevertheless, the Named Sacklers continued to press the company to recapture
lost sales and implement strategies, including the E2E program discussed below, to improve
profits without regard to whether those sales were tethered to or could be achieved based solely
on medically necessary prescriptions.
G. Re-catalyzing Medically Unnecessary Prescriptions: Turbocharging Sales
through E2E.
79. On May 28, 2013, Purdue executives executed a contract with a consulting
company to “conduct a rapid assessment of the underlying drivers of current OxyContin
performance, identify key opportunities to increase near-term OxyContin revenue and develop
plans to capture priority opportunities.”
80. Richard Sackler had direct communications with the consulting company shortly
before the contract was executed, which continued as the consulting company worked with
Purdue to develop and implement E2E.
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81. Between July 18 and August 8, 2013, the consulting company provided several
reports to Purdue’s CEO, at least two of which were provided to the Board, including the Named
Sacklers.
82. The consulting company proposed that Purdue adopt what was later referred to as
the “Evolve to Excellence” initiative, or “E2E.”
83. The reports concluded that there existed a “significant opportunity to improve
sales through better targeting.”
84. “Better targeting” primarily meant focusing sales calls on extremely high-volume
opioid prescribers and removing sales representative discretion with respect to call plans.
85. Purdue and the consulting company analyzed Purdue prescription data and other
Purdue data sources broken down by deciles based on, primarily, providers’ opioid prescribing.
According to Purdue and the consulting company’s deciling calculations, the prescribers writing
“25 times as many OxyContin prescriptions as” other providers – those within the top five
deciles – comprised less than seven percent of all prescribers nationwide, but wrote
approximately as many opioid prescriptions as the remaining 93 percent of prescribers
combined.
86. The consulting company contended that, in contrast to the decile ranking
undertaken by Purdue from 2010 to 2012, its rankings focused on “value deciles,” which
purported to be qualitatively different. In practice, the value decile ranking only enhanced
Purdue’s marketing focus on extremely high volume prescribers and ensured a focus on federal
health care benefit program beneficiaries.
87. The “value decile” analysis purported to use the following metrics: (1) overall
opioid prescriptions, including number of branded versus generic prescriptions; (2) whether the
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prescriber had rules in place prohibiting sales representatives from calling on them; (3) managed
care access, including access to Federal healthcare benefit program beneficiaries; and (4) the
number of the prescriber’s new to brand prescriptions (including new opioid patients and
switches from other opioid products).
88. The consulting company reports showed that the highest-volume prescribers were
the most susceptible to marketing: detailing resulted in a 53% increase in prescriptions
compared to only 33% for the middle decile prescribers. They also showed that, in the absence
of detailing, high-volume prescribers’ Purdue prescriptions would decline considerably.
89. The consulting company told Purdue and its Board that its proposed marketing
plan would slow or reverse that decline.
90. The memoranda asked Purdue to “make a clear go or no go decision on
Turbocharging the Sales Engine,” meaning implementing E2E.
91. On August 15, 2013, Purdue’s CEO and a Purdue executive discussed the
consulting company’s progress on evaluating growth opportunities for OxyContin with the
Board, including the Named Sacklers. Their presentation noted that the analysis would include
an examination of “relatively more sudden declines in tablets per prescriptions and prescriptions
for 40 mg and 80 mg strengths” and “prescriber segmentation and targeting.”
92. Later that same day, Richard Sackler emailed Mortimer D. A. Sackler: “The
‘discoveries’ of [the consulting company] are astonishing.”
93. Richard Sackler subsequently arranged for a face-to-face meeting for the Board
with the consulting company outside of the presence of Purdue executives.
94. On August 23, 2013, certain of the Named Sacklers met with the consulting
company and examined its “unvarnished” findings and recommendations.
- 18 -
95. Following the meeting, one of the consulting company partners that led the
meeting that included certain of the Named Sacklers memorialized in an email: “[T]he room was
filled with only family, including the elder statesman Dr. Raymond [Sackler]. . . . We went
through exhibit by exhibit for about 2 hrs. . . . They were extremely supportive of the findings
and our recommendations . . . and wanted to strongly endorse getting going on our
recommendations.”
96. Another consulting company partner further remarked in that email
correspondence that their “findings were crystal clear to” the Sacklers “and [the Sacklers] gave a
ringing endorsement of ‘moving forward fast.’”
97. After the “ringing endorsement”, Purdue, in collaboration with the consulting
company, implemented many of the consulting company’s recommendations.
98. The Named Sacklers approved the E2E program to recapture lost sales and to
improve profits.
99. The Board received a presentation on E2E’s implementation at the September
2013 Board meeting.
100. In September 2013, Richard Sackler emailed an advisor asking when Purdue
could reach out to its newly-hired CEO to brief him on E2E.
101. E2E took a multifaceted approach to increasing OxyContin prescribing and
Purdue’s profits. The consulting company recommended, among other strategies, refreshing the
marketing messaging and undertaking strategies to ensure prescriptions would be filled. At its
core, however, E2E focused on intensifying marketing to the very highest-volume prescribers in
the country by targeting them with increased frequency and minimizing sales representative
discretion in identifying prescribers to target.
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102. In late 2013, the Board received a 2014 Budget presentation again reviewing
E2E’s implementation. Board notes show the Board discussed ensuring E2E’s funding at that
meeting.
103. In sum, the Named Sacklers knew, or should have known, that E2E’s core
strategies relied on generating prescriptions from extremely high-volume prescribers and ensured
that it was implemented to increase OxyContin profits.
H. E2E’s Aggressive OxyContin Sales and Marketing Strategies.
104. E2E was overseen by the consulting company and some of Purdue’s top
executives through the creation of the E2E Executive Oversight Team (“EOT”) and Project
Management Office (“PMO”).
i. Increasing the frequency of calls on Extreme High-Volume Prescribers
105. Based on a study showing that providers in deciles 7-10 were most responsive to
sales calls and were the most prolific writers, the E2E call plans instructed sales representatives
to call on the very highest deciles of high-volume prescribers with the most frequency.
106. Specifically, Purdue instructed its sales representatives to call on the highest
volume OxyContin prescribers (i.e., those in so-called “deciles” 7 through 10) at least 24 times a
year and “heavily favor” promoting OxyContin over other Purdue opioids in their messaging.
107. Purdue executives also emphasized the focus of E2E at national sales meetings:
“The single core objective of E2E…is to make sure that we’re making calls on the highest
potential customers with the right frequency to maximize prescribing potential.”
108. An email between two Purdue executives dated October 23, 2013, entitled “S&P
Final Versions” attached Board presentations, including a 2014 Budget Presentation on
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OxyContin Tablets, which reflected that the extreme high-volume prescribers that E2E targeted
were most sensitive to Purdue’s marketing:
109. Speaker notes to this presentation discussed focusing on these top tier prescribers
because “Increased calls with decile 8-10 prescribers have a significant impact on OxyContin®
TRx growth” – an over 39% increase as compared to a decline of approximately 17% among
prescribers receiving fewer calls.
ii. Messaging to Cause High Volume Prescribers to Get More Patients on
OxyContin and Titrate Dosages
110. Purdue’s sales and marketing departments prepared scripts, visual aids, brochures,
and messaging for representatives to use with the providers they called on. A large part of this
marketing was intended to cause the highest volume prescribers in the nation to “commit” to
writing more OxyContin prescriptions.
111. At the same time, Purdue also refined its marketing message through the
S.T.A.R.T. (Supplement, Titrate, Adjust, Reassess, Tailor) initiative by focusing sales
conversations with prescribers on titrating patients to dosages.
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112. The goal of the program was to discourage patient discontinuation of OxyContin
due to perceived lack of pain relief by encouraging providers to increase the OxyContin dosage,
or “titrate up.”
113. At the November 2013 meeting concerning Purdue’s 2014 budget, a Purdue
executive discussed with the Board the company’s plans to “refine the message” of the
company’s titration up marketing campaign and specifically referenced the “Individualize the
Dose” campaign, a Conversion & Titration Guide, and the S.T.A.R.T. principles to “highlight
important elements of titration throughout the course of treatment.”
114. Briefings to the Board also showed that the E2E marketing pushed by sales
representatives in these calls specifically discussed titrating to higher dosages, initiating opioid
naïve patients on opioid therapy, and switching patients from immediate release opioids to
Reformulated OxyContin.
115. As such, the Named Sacklers knew, or should have known, that the program they
requested and approved would not only cause more prescriptions by high-volume prescribers,
but was also intended to increase the dosage of those prescriptions.
116. In December 2013 correspondence, Purdue’s CFO told the Board that “[t]he E2E
sales force focus/effectiveness initiatives [that] are being implemented starting October 2013
through April 2014 are already showing positive results.”
I. Purdue’s Internal Systems Confirm that E2E Caused Medically Unnecessary
Prescribing
117. Purdue’s Abuse and Diversion Detection (“ADD”) program and Region Zero list,
of which the Named Sacklers were aware, contain examples of high-volume prescribers detailed
during E2E that Purdue’s own employees suspected were writing medically unnecessary
prescriptions.
- 22 -
118. At all relevant times, Purdue maintained an ADD program, through which Purdue
had the means and ability to identify prescribers suspected of engaging in abuse and diversion.
119. The Named Sacklers were aware of the ADD program and Region Zero based on
briefings received through their membership in the Board, interactions with Purdue employees, and
news articles, including articles published by the Los Angeles Times.
120. The ADD program operated from approximately 2002 through February 2018 and
was governed during most of that time period by Standard Operating Procedure (“SOP”) 1.7.1.
121. SOP 1.7.1 instructed Purdue employees to refer prescribers who displayed indicia
of abuse and diversion to ADD. Employees referred these prescribers to ADD by issuing a
Report of Concern (“ROC”).
122. The indicia of abuse and diversion in SOP 1.7.1 were amended over time and
included, among other things, excessive numbers of patients; brief or nonexistent contact with
patients; high numbers of cash pay patients; information that a prescriber or his or her patients
may be diverting opioids; allegations of patient overdoses; allegations of unauthorized
individuals signing prescriptions; large numbers of patients traveling long distances; and
allegations that a prescriber is under investigation.
123. After prescribers were referred to ADD, an ADD review team comprised of
Purdue employees reviewed information concerning the prescribers to determine whether Purdue
should continue to market its opioids to them. The Named Sacklers did not sit on the ADD
review team.
124. If Purdue’s ADD review team determined a sales representative should not
continue to call on a prescriber, the prescriber was placed on the Region Zero list.
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125. The Board, including the Named Sacklers were made aware by Purdue
management reports to the Board that Region Zero providers were responsible for a major drop
in sales after Reformulated OxyContin was released, and that there were similar declines among
prescribers who were not on Region Zero that Purdue sales representatives could continue to
detail.
126. Purdue sales representatives were trained to report prescribers suspected of abuse
and diversion to ADD, and some sales representatives did so. However, many high-volume
prescribers, despite having indicia of abuse and diversion, were not reported. Further, even after
they were reported to ADD, Purdue continued to detail and generate prescriptions from highvolume
prescribers that were prescribing opioids that were not for a medically accepted
indication; were unsafe, ineffective, and medically unnecessary; and that were often diverted for
uses that lacked a legitimate medical purpose. The following are two examples of high-volume
prescribers that Purdue detailed during E2E.
Doctor-1
127. From January 2010 through May 2018, Purdue representatives detailed Doctor-1
at least 290 times, although calls after February 2018 did not promote opioid medications.
During this time, the doctor caused the submission of a high number of OxyContin claims to
Medicare.
128. Purdue knew that Doctor-1 was prescribing medically unnecessary opioids. From
2009 through 2011, Purdue received at least three different ROCs about Doctor-2.
129. In October 2009, a Purdue sales representative reported: “Pharmacist . . . says
they’ve had all kinds of problems with abuse and diversion of Oxycontin . . . [Pharmacist] said
[he] and [other doctor] are too lose [sic] when writing prescriptions of Oxycontin. He says of the
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patients he thinks are selling their prescriptions, he has notified the doctors, but nothing has
changed.”
130. In June 2010, the sales representative further reported: “the pharmacy manager,
says [the doctor] is known as the “Candyman” . . . because she will immediately put every
patient on the highest dose of narcotics she can, whether it’s Oxycontin or another product. He
says when he goes to local pharmacist meetings, when her name comes up everyone in the room
cringes and moans because of her practices. He says she is doing all kinds of wacky dosing and
tablet strengths. He says he feels like she is not doing what she should be doing with
medications. On occasion he has refused to fill prescriptions from her office . . . . He said he’s
been seeing some crazy dosing of Oxycontin coming in, especially from [Doctor-1].”
131. In July 2010, a Purdue sales representative reported: Another physician “said he
had a patient . . . from [the doctor] who was on 80 mg 5 times per day. He thought this was over
the top and asked me today what the maximum dose was. He felt this patient was definitely
exceeding it. I told him since it was a single entity opioid, there is no ceiling dose. It is only
limited by side effects. He said he would not continue this type of dose.”
132. The same representative “became concerned on March 18, 2010, when she
realized that patients were being treated by . . . a registered nurse without prescribing privileges,
in [the doctor’s] absence. According to [the representative], this ‘was not an isolated incident.’”
133. The representatives’ call notes showed other instances where Doctor-1 was absent
during business hours, including a February 2010 incident when the doctor left in the middle of
the day to get a tattoo.
134. The ADD program placed Doctor-1 on Region Zero and instructed sales
representatives to cease calling on the doctor in August 2010.
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135. However, in October 2011, Purdue instructed sales representatives to resume
calling on Doctor-1 and the sales representatives did so until May 2018.
136. Purdue’s detailing caused Doctor-1 to write medically unnecessary prescriptions
for OxyContin, claims for which were submitted to Federal healthcare programs.
Doctor-2
137. From January 2010 to May 2018, Purdue representatives detailed Doctor-2 at
least 130 times, although calls after February 2018 did not promote opioid medications.
138. During this time, Doctor-2 caused Medicare claims for OxyContin, the
overwhelming majority of which were for OxyContin 80mg tablets.
139. On September 23, 2003, a Purdue employee flagged Doctor-2 for ADD review
stating, “Have you looked at the doctor with [the doctor’s ME number]? This person is in
specialty decile 7 and has about twice the volume as anyone else in that decile.”
140. Purdue performed an ADD review in July 2004 after reviewing information
showing the doctor had abnormally high opioid volume and a high percentage of cash-paying
patients, and receiving reports that the doctor was under investigation for his opioid prescribing.
The ADD team did not place Doctor-2 on the Region Zero list at that time.
141. Doctor-2’s name came up again in 2008 and 2009 in connection with Purdue’s
internal investigation of a diverting pharmacy. The investigation revealed, in part, the following
red flags regarding the pharmacy, including: it was a high traffic pharmacy; cars observed at the
pharmacy had out of state plates; it had pharmacy clients loitering outside; it had pharmacy
clients entering and exiting vehicles not their own; and it had pharmacy clients exchanging
prescription drugs. As part of the investigation, Purdue identified Doctor-2 as one of the “Three
- 26 -
(3) Main Doctors who prescribe for [pharmacy],” but undertook no further review of the doctor
after this event.
142. Purdue sales representatives’ call notes also identified ongoing concerns
regarding abuse by the doctor’s patients. For example, a 2010 call note stated: “Had a patient
that died this week that was taking OxyContin (2 tablets of 80mg at Q12h). She was 45-48 years
old and had been seen by [the doctor] for 10 years. The patient had complained previously (was
reported) that the reformulation made her sick and tried to get a refund for the reformulation (the
pharmacy refused). She did find generic OxyContin. Patient was found dead sitting at the
kitchen table with a syringe beside her. It has been ruled as an accidental death by the police.”
143. Following the reformulation of OxyContin, Doctor-2 was flagged for review by a
December 2010 data analysis due to the doctor’s drop in Reformulated OxyContin prescription
rates. Months after the analysis, on August 1, 2011, Purdue completed an ADD review, deciding
to take no action based on Doctor-2’s explanation for why he stopped prescribing Reformulated
OxyContin
144. In early 2013, the state Board of Medical Examiners filed a complaint against
Doctor-3 outlining his practice of prescribing OxyContin and other opioids outside the course of
legitimate medical practice, which detailed the excessive amounts of OxyContin he prescribed to
certain patients.
145. On February 27, 2013, a Purdue sales representative filed a ROC that Doctor-2
was subject to disciplinary action by the Board of Medical Examiners. On April 5, 2013,
Doctor-2 was placed on the Region Zero list. Purdue representatives had detailed Doctor-2 146
times between 2007 and his addition to Region Zero in April 2013.
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146. Although under ADD review since February 27, 2013, Purdue sales
representatives called on Doctor-2 several more times until April 5, 2013.
147. Four months later, on August 26, 2013, a Purdue sales representative requested to
resume calling on the doctor. In response, the ADD program wondered if it was “[t]oo soon to
put him back on the list.” It initially recommended a “resume call” status due to a “lack of
progress on the resolution of the board’s complaint and the doctor’s continuation in practice,”
but, after further discussion, kept him on Region Zero.
148. In February 2015, the same Purdue sales representative again requested that the
doctor be removed from the Region Zero list. The doctor was removed from the list on March
2015 after an “Expedited Review” of requests to resume calling on several high-prescribing
doctors. Purdue sales representatives detailed Doctor-2 an additional 117 times between March
2015 and May 2018.
149. In sum, Purdue’s detailing caused Doctor-2 to write medically unnecessary
prescriptions for OxyContin, claims for which were submitted to Federal healthcare programs.
V. Alternative Distribution Model
150. As an additional means to circumvent safeguards intended to prevent the filling of
suspicious prescriptions, from October 2015 through 2018, Purdue and certain of the Named
Sacklers sought to find a pharmacy mechanism to fill OxyContin prescriptions for patients that
other traditional pharmacies had rejected.
151. As noted above, in July 2013, as part of the E2E program, the consulting
company relayed to Purdue management and, through briefings, the Board that OxyContin
revenues were down because, among other things, “entire pharmacies [are] being shut off by
distributors, pharmacies themselves imposing tablet limits, decreases in channel inventory
- 28 -
leading to greater stockouts, and pharmacies choosing to not stock OxyContin.” The consulting
company proposed creating an “alternative model for how patients receive OxyContin. This
model would bypass retail, likely through a third party vendor who would provide adjudication
and direct distribution to patients.”
152. On August 16, 2013, one day after the Board briefing on E2E discussed above,
Mortimer D. A. Sackler emailed Purdue’s CEO and others asking what ideas management had
for creating a new distribution system “to help relieve this problem of product access for
legitimate chronic pain patients,” which would use “an independent service to verify the
legitimacy of [the patients’] prescriptions.” Two days later, Mortimer D.A. Sackler reiterated, “I
do think there may be an opportunity here for us to set up a complimentary business to handle
this for Purdue as well as other controlled drug manufacturers. Do we have a team who could
explore this possibility?”
153. On August 18, 2013, Richard Sackler responded that he had the same idea and
expressed it to Purdue’s CEO after a Board meeting. Purdue’s CEO responded three days later
confirming Mortimer D.A. Sackler’s interest in exploring an “alternative distribution process for
all or essentially all opioid formulations.” Mortimer D.A. Sackler responded on the same day,
“To be clear, I was thinking about selling to pharmacies.”
154. Shortly thereafter, the Named Sacklers approved E2E, and the E2E program went
on to develop “multiple tactics to address these issues,” including “alternative supply channels.”
In 2015, the company entered agreements with three specialty pharmacies for Hysingla.
155. Some of the prescriptions that were filled by the specialty pharmacies, which
included other Purdue opioids, had been rejected by traditional retail pharmacies and displayed
indicia that the prescriptions were not for a medically accepted indication; for uses that were
- 29 -
unsafe, ineffective, and medically unnecessary; and that were often diverted for uses that lacked
a legitimate medical purpose.
156. Purdue’s ADD program data further confirms that some of these prescriptions
lacked medical necessity. From mid-2015 through 2018, the specialty pharmacies filled
Medicare prescriptions for Purdue opioids written by approximately 100 prescribers. Nearly
one-fourth of those prescribers were referred to ADD on suspicion of engaging in abuse and
diversion.
157. In sum, certain of the Named Sacklers suggested that Purdue find an alternative
distribution strategy to fill prescriptions that were rejected because of safeguards against
medically unnecessary prescribing. In doing so, they knew, or should have known, that the
alternative distribution model could cause the submission of false claims for Purdue opioids.
VI. The Fraudulent Transfer of Assets from Purdue
158. Beginning in 2007, the Named Sacklers discussed a strategy to remove assets
from Purdue, making the assets more difficult for future plaintiffs or creditors to reach.
159. From 2007 to at least 2017, the Named Sacklers used their control of Purdue to
remove cash and other assets from Purdue and transfer these assets to other entities controlled by
the Sackler family.
160. On May 17, 2007 (one week after a criminal plea entered by a Purdue entity and
agreement to pay over $600 million), Jonathan Sackler emailed David Sackler, Richard Sackler,
and a long-time financial advisor, stating that an investment banker once told him, “your family
is already rich, the one thing you don’t want to do is to become poor.”
161. The same day, David Sackler replied-all by email:
[W]hat do you think is going on in all of these courtrooms right now?
We’re rich? For how long? Until which suits get through to the family? I
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think [the investment banker’s] advice was just violated in a Virginia
courtroom.
My thought is to lever up where we can, and try to generate some
additional income. We may well need it. . . . Even if we have to keep it in
cash, it’s better to have the leverage now while we can get it than thinking
it will be there for us when we get sued.
162. In or about April 2008, Richard Sackler wrote a memorandum to Kathe Sackler,
Ilene Sackler, David Sackler, Jonathan Sackler, and Mortimer D. A. Sackler in which he
discussed limiting the Sackler family’s risk in the ownership of Purdue: “[T]he most certain way
for the owners to diversify their risk is to distribute more free cash flow so they can purchase
diversifying assets.”
163. On September 8, 2014, Mortimer D. A. Sackler emailed Jonathan Sackler, stating
that there had been “a huge depreciation in [Purdue’s] bottom line and more importantly
shareholder value over the past 5+ years” and that Purdue was in a “death spiral.”
164. The same day, Jonathan Sackler responded to Mortimer D. A. Sackler that “when
the business has more cash flow than is required, I’ve supported distributions, and we’ve taken a
fantastic amount of money out of the business.”
165. About a month later, on October 12, 2014, Jonathan Sackler emailed Richard
Sackler, David Sackler, and others: “I think we can continue to make money in it [opioid
analgesics] for decades to come, particularly if we are smart and diligent around emerging
markets, formulation, generics, and APIs, but in the aggregate, it’s more of a smart milking
program than a growth program.”
166. From 1997 through 2007, Purdue distributed a total of $126 million in cash to
members of the Sackler family and their holding companies and trusts.
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167. In the next decade, from 2008 to 2018, the Purdue Board approved billions in
transfers of funds out of Purdue as cash distributions of profits into Sackler family holding
companies and trusts.
168. Certain of these distributions and transfers were made with the intent to hinder
future creditors and/or were otherwise avoidable as fraudulent transfers.
169. Purdue did not fully document certain of these transfers and did not conduct full
valuations of the transferred assets.
170. Purdue did not receive reasonably equivalent value for certain of these transfers.
Addendum B
ADDENDUM B: RELEASED FAMILY MEMBERS AND TRUST PARTIES
Individual Family Members
1. David Sackler
2. Estate of Beverly Sackler, including executors thereof
3. Estate of Jonathan Sackler, including executors thereof
4. Ilene Sackler Lefcourt
5. Kathe Sackler
6. Marissa Sackler
7. Michael Sackler
8. Mortimer D.A. Sackler
9. Richard Sackler
10. Samantha Hunt
11. Theresa Sackler
12. Sophie Dalrymple
13. The spouses, children and grandchildren of the above, as enumerated on (i) a list
transmitted to the Department of Justice by Debevoise & Plimpton LLP on
October 21, 2020 and (ii) a list transmitted to the Department of Justice by Paul,
Weiss, Rifkind, Wharton & Garrison LLP on October 21, 2020.
Trusts, Trustees and Protectors
1. 1959 Irrevocable Trust
2. 1969 Irrevocable Trust
3. 1974 Irrevocable Trust fbo BS and JDS
4. 1974 Irrevocable Trust fbo BS and RSS
5. 1974 Revocable Trust
6. 533 Canal Trust
7. AJ Irrevocable Trust
8. Alexa Saunders
9. Angonoka Trust
10. Anthony Roncalli
11. AR Irrevocable Trust
12. Beacon Trust
13. Beacon Trust Company Ltd.
14. Beth B. Sackler Trust
15. Beverly Sackler 2012 Revocable Pourover Trust
16. Beverly Sackler Trust 1 f/b/o Clare Elizabeth Sackler 12/27/1989
17. Beverly Sackler Trust 1 f/b/o David Alex Sackler 12/20/1989
18. Beverly Sackler Trust 1 f/b/o Madeleine Sackler 12/26/1989
19. Beverly Sackler Trust 1 f/b/o Marianna Rose Sackler 12/21/1989
20. Beverly Sackler Trust 1 f/b/o Miles Raymond Sackler 12/29/1989
2
21. Beverly Sackler Trust 1 f/b/o Rebecca Kate Sackler 12/22/1989
22. Beverly Sackler Trust 2 f/b/o Clare Elizabeth Sackler 12/27/1989
23. Beverly Sackler Trust 2 f/b/o David Alex Sackler 12/20/1989
24. Beverly Sackler Trust 2 f/b/o Madeleine Sackler 12/26/1989
25. Beverly Sackler Trust 2 f/b/o Marianna Rose Sackler 12/21/1989
26. Beverly Sackler Trust 2 f/b/o Miles Raymond Sackler 12/30/1989
27. Beverly Sackler Trust 2 f/b/o Rebecca Kate Sackler 12/22/1989
28. Beverly Sackler Trust 3 f/b/o Clare Elizabeth Sackler 12/27/1989
29. Beverly Sackler Trust 3 f/b/o David Alex Sackler 12/20/1989
30. Beverly Sackler Trust 3 f/b/o Madeleine Sackler 12/26/1989
31. Beverly Sackler Trust 3 f/b/o Marianna Rose Sackler 12/21/1989
32. Beverly Sackler Trust 3 f/b/o Miles Raymond Sackler 12/28/1989
33. Beverly Sackler Trust 3 f/b/o Rebecca Kate Sackler 12/22/1989
34. BJSS 2010 Trust
35. BJSS 2013 Trust
36. BJSS and JHSS 2012 K Trust
37. Bowland Company Ltd.
38. BRJ Fiduciary Management LLC
39. BSS Trust 98
40. Canadian Partnership Trust
41. Cedar Cliff Fiduciary Management Inc.
42. Cedar Cliff Trust
43. Charles G. Lubar
44. Chelsea Trust Company Ltd.
45. Christopher B. Mitchell
46. Christopher M. Reimer
47. Clare E. Sackler 2012 Trust
48. Clover Trust
49. Cobo Bay Trust
50. Codan Trust Company Ltd.
51. Cornice Fiduciary Management LLC
52. Cornice Trust
53. Crystal Fiduciary Company LLC
54. Crystal Trust
55. DABB Trust
56. Data LLC
57. Data Trust
58. David A. Sackler 2012 Trust
59. Diagonal Blue Trust
60. Elizabeth A. Whalen
61. Estera Services (Bermuda) Ltd.
62. Fidinc Trust
63. Flat Creek Fiduciary Management LLC
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64. Flat Creek Purpose Trust
65. FTA Trust
66. Gorey Trust
67. Hagen Trust Company Ltd.
68. Halm Trust
69. Heatheridge Trust Company Ltd.
70. Hercules Trust
71. Hermance Schaepman
72. Hillside Trust Company Ltd.
73. Hudson Trust
74. Ian McClatchey
75. Ilene S. Lefcourt Trust 88
76. Ilene S. Lefcourt Trust 96
77. Ilene Sackler Lefcourt Revocable Trust
78. Indian Wells Hill Trust
79. Inholmes Trust
80. Irrevocable Trust under Declaration dated as of April 25, 1991
81. Irrevocable Trust under Declaration dated as of August 25, 1992
82. Irrevocable Trust under Declaration dated as of December 29, 1992
83. Irrevocable Trust under Declaration dated as of September 19, 1995 f/b/o Issue of
Jonathan D. Sackler
84. Irrevocable Trust under Declaration dated as of September 19, 1995 f/b/o Issue of
Richard S. Sackler
85. ISL 2010 Family Trust
86. ISL 2011 Family Trust
87. ISL JML OSHA Trust
88. ISL LT Children's Trust
89. Jackson River Trust
90. JDS 1992 Insurance Trust
91. JDS 2/2/98 Trust
92. JDS Fiduciary Management Trust
93. JDS Pourover Trust
94. JDS Revocable Pourover Trust
95. Jeffrey A. Robins
96. JHSS 2010 Trust
97. JHSS 2013 Trust
98. JML 2010 Family Trust
99. JML 2011 Family Trust
100. JML Investment Trust
101. JML OSHA Trust
102. JML Pour-Over Trust
103. Joerg Fischer
104. John Wilcox
4
105. Jonathan D. Sackler Life Insurance Trust
106. Jonathan D. Sackler Trust f/b/o Clare Elizabeth Sackler 4/11/90
107. Jonathan D. Sackler Trust f/b/o Madeleine Sackler 4/11/90
108. Jonathan D. Sackler Trust f/b/o Miles Raymond Corson Sackler 4/11/90
109. Jonathan D. Sackler Trust U/A 9/30/04
110. Jonathan White
111. JSS Trust 98
112. Karen Lefcourt Trust
113. KAS 2010 Family Trust
114. KAS 2011 Family Trust
115. Kathe A. Sackler 2001 Trust
116. Kathe A. Sackler Trust 88
117. Kathe A. Sackler Trust 96
118. Kerry J. Sulkowicz
119. KLT 2010 Family Trust
120. KLT 2011 Family Trust
121. KLT Pour-Over Trust
122. La Coupe Trust
123. Lauren Kelly
124. Leslie J. Schreyer
125. LSRR Family Trust
126. Lune River Trust
127. Madeleine Sackler 2012 Trust
128. Marianna R. Sackler 2012 Trust
129. Marianna R. Sackler Captain Trust
130. Mary Corson Trust
131. May Trust
132. Maydean Trust Company Ltd.
133. MCM Fiduciary Management LLC
134. MCM Fiduciary Management Trust
135. MDAS 2010 Family Trust
136. MDAS 2011 Family Trust
137. MDAS Children's Trust 2012
138. MDAS Investment Trust
139. MDS 1992 Trust
140. MDS 2002 Trust
141. MDS 2006 Trust
142. MDS Beacon 2010 Trust
143. MDS Beacon 2011 Trust
144. MDS Beacon 2012 Trust
145. MDS Beacon 2013 Trust
146. MDS Family Trust 2010
147. Medichem Trust
5
148. Meerkat Trust
149. Memphis Pharma Trust
150. MIL Trust
151. Miles R.C. Sackler 2012 Trust
152. Millborne Trust Company
153. Millennium Trust
154. Milton Trust
155. Mondai Trust
156. Mordas Consolidated Purpose Trust
157. Mortimer DA Sackler Trust 1996
158. Mortimer DA Sackler Trust 2002
159. Morvetta Trust
160. MTS 2002 Trust
161. MTS 2006 Trust
162. MTS 2013 Family Trust
163. MTS 2016 Trust
164. MTS Bare Trust
165. MTS Beacon 2013 Trust
166. MTS Beacon 2014 Trust
167. MTS Beacon 2015 Trust
168. MTS Beacon Trust 2010
169. MTS Beacon Trust 2011
170. MTS Beacon Trust 2012
171. MTS Family Trust 2010
172. MTS Trust 2006
173. Mundi Lab Trust
174. Nixie Trust
175. North Bay Trust Company Inc.
176. PALP Trust
177. Perelle Bay Trust
178. Peter Ward
179. Pickering Trust
180. Racine Trust
181. Raymond R. Sackler Credit Shelter Trust u/a 3/29/2012
182. Raymond R. Sackler GST Exempt Marital Trust u/a 3/29/2012
183. Raymond R. Sackler Marital Trust u/a 3/29/2012
184. Raymond R. Sackler Trust 1 dtd 12/23/89
185. Raymond R. Sackler Trust 1B dtd 12/23/89
186. Raymond R. Sackler Trust 2 dtd 12/23/89
187. Raymond R. Sackler Trust 2B dtd 12/23/89
188. Rebecca K. Sackler 2012 Trust
189. Rebecca K. Sackler Captain Trust
190. Reserve Trust
6
191. Richard S. Sackler Life Insurance Trust
192. Richard S. Sackler Trust f/b/o David A. Sackler 3/8/90
193. Richard S. Sackler Trust f/b/o Marianna R. Sackler 3/8/90
194. Richard S. Sackler Trust f/b/o Rebecca K. Sackler 3/8/90
195. Richard S. Sackler Trust U/A 9/30/04
196. Romas Trust 2002
197. RSS 1992 Insurance Trust
198. RSS 2/2/98 Trust
199. RSS Fiduciary Management Trust
200. RSS Pourover Trust
201. RSS Revocable Pourover Trust
202. Sandiway Trust Company Ltd.
203. SASS 2010 Trust
204. SASS 2013 Trust
205. SDS 1992 Trust
206. SDS 2002 Trust
207. SDS 2006 Trust
208. SDS Bare Trust
209. SDS Beacon 2011 Trust
210. SDS Beacon 2012 Trust
211. SDS Beacon 2014 Trust
212. SDS Family Trust 2010
213. Sheffield Trust
214. Silver Trust
215. Soft River Fiduciary Management LLC
216. Soft River Purpose Trust
217. SS Tanager Trust
218. SSH 2013 Family Trust
219. SSSH Beacon 2013 Trust
220. SSSH Trust 1996
221. SSSH Trust 2002
222. Stephen A. Ives
223. Taddeo Fiduciary Management Inc.
224. Taddeo Purpose Trust
225. Taddeo Trust
226. Tayleigh Trust Company Ltd.
227. Tenzin Trust Company Ltd.
228. TES Bare Trust
229. TES Beacon 2012 Trust
230. TES Beacon 2013 Trust
231. TES Beacon 2014 Trust
232. The 1974 Irrevocable Investment Trust
233. The Jonathan D. Sackler Revocable Pourover Trust dated September 30, 2004
7
234. The Jonathan D. Sackler Revocable Pourover Trust dated December 12, 2010
235. The Richard S. Sackler Revocable Pourover Trust
236. The RSS 2012 Family Trust
237. Themar Consolidated Purpose Trust
238. Themar Trust Company Ltd.
239. Theresa E. Sackler 1988 Trust
240. Theresa E. Sackler 2008 Trust
241. Thomas A. Russo
242. Tom & Kelly Trust
243. Trust Agreement dated August 29, 2003 f/b/o Issue of Richard S. Sackler
244. Trust Agreement dated August 29, 2003 f/b/o Mary Corson and Issue of Jonathan
D. Sackler
245. Trust B U/A 11/5/74 fbo Beverly Sackler
246. Trust U/A 11/5/74 fbo Beverly Sackler
247. Trust under agreement dated December 23, 1980 f/b/o Jonathan D. Sackler
248. Trust under agreement dated December 23, 1980 f/b/o Richard S. Sackler
249. Trust under agreement dated December 3, 1979 f/b/o Jonathan D. Sackler
250. Trust under agreement dated December 3, 1979 f/b/o Richard S. Sackler
251. Trust under agreement dated June 16, 1980 f/b/o Jonathan D. Sackler
252. Trust under agreement dated June 16, 1980 f/b/o Richard S. Sackler
253. Trust under Agreement dated the 11th day of May 2005
254. Trust under Agreement dated the 13th day of March 2009
255. Trust under Declaration of Trust dated August 23, 1988 f/b/o Jonathan D. Sackler
and Issue of Jonathan D. Sackler
256. Trust under Declaration of Trust dated August 23, 1988 f/b/o Richard S. Sackler
and Issue of Richard S. Sackler
257. Trust under Declaration of Trust dated December 17, 1991 f/b/o Jonathan D.
Sackler and Issue of Jonathan D. Sackler
258. Trust under Declaration of Trust dated December 17, 1991 f/b/o Richard S.
Sackler and Issue of Richard S. Sackler
259. Trust Under Declaration of Trust No. 1 dated November 25, 1996
260. Trust Under Declaration of Trust No. 2 dated November 25, 1996
261. Trust Under Declaration of Trust No. 2 dated November 25, 1996
262. Varus Trust
Addendum C
ADDENDUM C:
RELEASED PURDUE PARENT ENTITIES AND
INDEPENDENT ASSOCIATED COMPANIES
Purdue Parent Entities
1. Banela Corporation
2. Beacon Company
3. BR Holdings Associates Inc.
4. BR Holdings Associates L.P.
5. BRJ Fiduciary Management LLC, as Trustee of Trust B (U/A 11/4/74 fbo
Beverly Sackler) (“74B Trust”)
6. Cedar Cliff Fiduciary Management Inc., as Trustee of Trust U/A 11/5/74
fbo Beverly Sackler (“74A Trust”)
7. Cornice Fiduciary Management LLC, as Trustee of AJ Irrevocable Trust
8. Cornice Fiduciary Management LLC, as Trustee of Raymond R. Sackler
Trust 2 dtd 12/23/89 (“JDS 1989 Captain Trust A”)
9. Cornice Fiduciary Management LLC, as Trustee of Raymond R. Sackler
Trust 2B dtd 12/23/89 (“JDS 1989 Captain Trust B”)
10. Crystal Fiduciary Company LLC, as Trustee of 1974 Irrevocable Trust fbo
BS and RSS (“74-AR Trust”)
11. Crystal Fiduciary Company LLC, as Trustee of AR Irrevocable Trust
12. Data LLC, as Trustee of Raymond R. Sackler Trust 1 dtd 12/23/89 (“RSS
1989 Captain Trust A”)
13. Data LLC, as Trustee of Raymond R. Sackler Trust 1B dtd 12/23/89
(“RSS 1989 Captain Trust B”)
14. Heatheridge Trust Company Limited, as Trustee under Settlement dated
31 December 1993 F.B.O. the issue of Mortimer D. Sackler M.D., Theresa
E. Sackler and certain charitable objects
15. Linarite Holdings LLC
16. MCM Fiduciary Management LLC, as Trustee of 1974 Irrevocable Trust
fbo BS and JDS (“74-AJ Trust”)
17. Millborne Trust Company Limited, as Trustee of the Hercules Trust under
Declaration of Trust dated 2 March 1999 F.B.O. Theresa E. Sackler, the
issue of Mortimer D. Sackler, M.D. and certain charitable objects
18. Moonstone Holdings LLC
19. North Bay Trust Company Inc., as Trustee of The 1974 Irrevocable
Investment Trust (“Investment Trust”)
20. Perthlite Holdings LLC
21. Pharmaceutical Research Associates L.P. (formerly Purdue Holdings L.P.)
22. PLP Associates Holdings Inc.
23. PLP Associates Holdings L.P.
24. Purdue Pharma Inc.
25. Rosebay Medical Company L.P.
2
26. Rosebay Medical Company, Inc.
27. Roselite Holdings LLC
28. Stanhope Gate Corp.
Independent Associated Companies
1. Accardi B.V.
2. Accardi S.àr.l.
3. Alfa Generics B.V.
4. Arsago B.V.
5. Bard Pharmaceuticals (1990) Inc.
6. Bard Pharmaceuticals Limited
7. Bermag Limited
8. Boetti Corporation
9. Boldini Corporation
10. Bradenton Products B.V.
11. Bulla S.àr.l.
12. Clinical Designs Limited
13. Clovio Corporation
14. E.R.G. Realty, Inc.
15. Elvium Life Sciences GP Inc.
16. Elvium Life Sciences Limited Partnership
17. Elvium ULC
18. Euro-Celtique S.A.
19. Evening Star Services Limited
20. Filti S.àr.l.
21. Flira S.àr.l.
22. Hayez Corporation
23. Ind S.àr.l.
24. Irey S.àr.l.
25. Krugmann GmbH
26. Ladenburg B.V.
27. Lake Claire Investments Limited
28. L.P. Clover Limited
29. Lucien Holdings S.àr.l.
30. Lymit Holdings S.àr.l.
31. Maltus Corporation
32. Marnine Holdings Pte. Limited
33. Martone Holdings Pte. Limited
3
34. Mexcus Corporation
35. MN Consulting LLC
36. MNP Consulting Limited
37. Modi – Mundipharma Beauty Products Private Ltd
38. Modi – Mundipharma Healthcare Private Ltd
39. Modi – Mundipharma Private Ltd
40. Mundibiopharma Limited
41. Mundichemie GmbH
42. Mundipharma (Argentina) S.r.l.
43. Mundipharma (China) Pharmaceutical Company Limited
44. Mundipharma (Colombia) S.A.S.
45. Mundipharma (Hong Kong) Limited
46. Mundipharma (Myanmar) Co., Limited
47. Mundipharma (Proprietary) Limited
48. Mundipharma (Shanghai) International Trade Company Limited
49. Mundipharma (Thailand) Limited
50. Mundipharma A.S.
51. Mundipharma A/S
52. Mundipharma AB
53. Mundipharma AG
54. Mundipharma B.V.
55. Mundipharma Biologics GmbH
56. Mundipharma Biologics Inc.
57. Mundipharma Bradenton B.V.
58. Mundipharma Brasil Productos Médicos e Farmacȇuticos Ltda.
59. Mundipharma BV
60. Mundipharma Company
61. Mundipharma Corporation (Ireland) Limited
62. Mundipharma Corporation Limited
63. Mundipharma DC B.V.
64. Mundipharma de Mexico, S. de R.L. de C.V.
65. Mundipharma Deutschland GmbH & Co. KG
66. Mundipharma Development Pte. Limited
67. Mundipharma Distribution GmbH
68. Mundipharma Distribution Limited
69. Mundipharma EDO GmbH
70. Mundipharma Egypt LLC
71. Mundipharma Farmaceutica LDA.
4
72. Mundipharma FZ-LLC
73. Mundipharma GesmbH
74. Mundipharma GmbH
75. Mundipharma Healthcare Corporation
76. Mundipharma Healthcare LLC
77. Mundipharma Healthcare Pte. Limited
78. Mundipharma Healthcare Pty. Limited
79. Mundipharma Holding AG
80. Mundipharma International Services GmbH
81. Mundipharma International Services Limited
82. Mundipharma International Services S.ar.l.
83. Mundipharma International Corporation Limited
84. Mundipharma International Holdings Limited
85. Mundipharma International Limited
86. Mundipharma International Services GmbH
87. Mundipharma International Services Limited
88. Mundipharma International Services S.àr.l.
89. Mundipharma International Technical Operations Limited
90. Mundipharma IT GmbH
91. Mundipharma IT Services GmbH
92. Mundipharma IT Services Inc.
93. Mundipharma IT Services Limited
94. Mundipharma IT Services Pte. Limited
95. Mundipharma Kabushiki Kaishe
96. Mundipharma Korea Limited
97. Mundipharma Laboratories GmbH
98. Mundipharma Laboratories Limited
99. Mundipharma LATAM GmbH
100. Mundipharma Limited
101. Mundipharma Ltd.
102. Mundipharma Management S.ar.l.
103. Mundipharma Manufacturing Pte. Limited
104. Mundipharma MEA GmbH
105. Mundipharma Medical CEE GmbH
106. Mundipharma Medical Company
107. Mundipharma Medical Company Limited
108. Mundipharma Medical GmbH
109. Mundipharma Medical S.ar.l.
5
110. Mundipharma Middle East FZ-LLC
111. Mundipharma Near East GmbH
112. Mundipharma New Zealand Limited
113. Mundipharma Oncology Pty. Limited
114. Mundipharma Ophthalmology Corporation Limited
115. Mundipharma Ophthalmology Products Limited
116. Mundipharma Oy
117. Mundipharma Pharmaceutical Company
118. Mundipharma Pharmaceuticals (Chile) Limitada
119. Mundipharma Pharmaceuticals Argentina S.r.l.
120. Mundipharma Pharmaceuticals B.V.
121. Mundipharma Pharmaceuticals Belgium BV
122. Mundipharma Pharmaceuticals Inc.
123. Mundipharma Pharmaceuticals Industry and Trade Limited
124. Mundipharma Pharmaceuticals Limited
125. Mundipharma Pharmaceuticals Private Limited
126. Mundipharma Pharmaceuticals S.L.
127. Mundipharma Pharmaceuticals S.r.l.
128. Mundipharma Pharmaceuticals Sdn. Bhd.
129. Mundipharma Polska SP. Z.O.O.
130. Mundipharma Pte Limited
131. Mundipharma Pty Limited
132. Mundipharma Research Company Limited
133. Mundipharma Research GmbH & Co. KG
134. Mundipharma Research Limited
135. Mundipharma Research Verwaltungs GmbH
136. Mundipharma SAS
137. Scientific Office of Mundipharma MEA GmbH
138. Mundipharma Singapore Holding Pte. Limited
139. Mundipharma TK
140. Mundipharma Verwaltungsgesellschaft mbH
141. Napp Laboratories Limited
142. Napp Pension Trustees Limited
143. Napp Pharmaceutical Group Limited
144. Napp Pharmaceutical Holdings Limited
145. Napp Pharmaceuticals Limited
146. Napp Research Centre Limited
147. Nitid S.àr.l.
6
148. Nontag S.àr.l.
149. One Stamford Realty L.P.
150. Paineurope Limited
151. Par-La-Ville Properties Limited
152. Porthos S.àr.l.
153. PT. Mundipharma Healthcare Indonesia
154. Purdue BioPharma Inc.
155. Purdue BioPharma L.P.
156. Purdue Frederick Inc.
157. Purdue Pharma Inc. (Canadian Company)
158. Purdue Pharma Technologies Inc.
159. Purdue Pharma Pty. Ltd.
160. Purdue Pharma ULC
161. Qdem Pharmaceuticals Limited
162. Rafa Laboratories Ltd.
163. Sofy S.àr.l.
164. Songol S.àr.l.
165. Sonti S.àr.l.
166. Tacca B.V.
167. Taiwan Mundipharma Pharmaceuticals Limited
168. Technical Scientific Office of Mundipharma Near East GmbH
169. Tenna B.V.
170. The Napp Educational Foundation
171. The Representative Office of Mundipharma Pharmaceuticals Pte Limited
in Ho Chi Minh City
172. Vaccaro B.V.
173. Venusti B.V.
174. Win – Healthcare Private Ltd.
175. Win – Medicare Private Ltd.
176. Wuhu Haitong Kanghong Pharmaceutical Trading Co. Ltd.

Outcome: Except to the extent of Purdue’s admissions as part of its criminal resolution, the claims resolved by the civil settlements are allegations only. There has been no determination of liability in the civil matters.

Plaintiff's Experts:

Defendant's Experts:

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