R-21-34RESOLUTION NO R-21-34
A RESOLUTION APPROVING THE VIRGINIA OPIOID ABATEMENT FUND AND
SETTLEMENT ALLOCATION MEMORANDUM OF UNDERSTANDING
WHEREAS, the City of Fairfax, through its elected representatives and counsel, and the
Commonwealth of Virginia, through the Office of the Attorney General, are separately engaged
in litigation seeking to recover costs incurred and to be incurred in abating the opioid addiction
epidemic that plagues Virginia communities; and
WHEREAS, the City of Fairfax and the Commonwealth of Virginia share a common
desire to abate and alleviate the impacts of the opioid addiction epidemic and to maximize
litigation recoveries from those third parties responsible for same; and
WHEREAS, in order to advance their common interests, the City and the
Commonwealth of Virginia, through counsel, have extensively negotiated the terms of a
memorandum of understanding relating to the allocation and use of such Iitigation recoveries;
and
WHEREAS, the City's outside opioid litigation counsel has recommended that the City
approve the proposed memorandum of understanding; and
WHEREAS, the City Attorney has reviewed the available information about the
proposed memorandum of understanding and concurs with the recommendation of outside
counsel.
NOW, THEREFORE, BE IT RESOLVED, by the City Council it hereby, on behalf of
the City, authorizes and approves, or confirms prior authorization and approval, of the Virginia
Opioid Abatement Fund and Settlement Allocation Memorandum of Understanding attached
hereto and incorporated herein by reference thereto as Exhibit "A" - and authorizes and directs
the Mayor, the City Manager andior the City Attorney, as applicable, to execute, or re -execute
as necessary, and enter into such Memorandum of Understanding on behalf of the City.
Adopted: September 14, 2021
0li*M%kq _-e__
Mayor
Attest:
City Clerk
The vote on the motion to approve was recorded as follows:
VOTE:
Councilmember Harmon Aye
Councilmember Lim
Aye
Councilmember Miller
Aye
Councilmember Ross
Aye
Councilmember Stehle
Aye
Councilmember Yi
Aye
VIRGINIA OPIOID ABATEMENT FUND AND
SETTLEMENT ALLOCATION MEMORANDUM OF UNDERSTANDING
WHEREAS, the people of the Commonwealth of Virginia and its communities have been harmed
through the national and statewide epidemic caused by licit and illicit opioid use and distribution
within the Commonwealth of Virginia;
WHEREAS, the Commonwealth of Virginia, through the Office of Attorney General Mark R.
Ilerring, and certain Political Subdivisions, through their elected representatives and counsel, are
separately engaged in litigation seeking to hold those entities in the Pharmaceutical Supply Chain
accountable for the damage caused;
WHEREAS, the Commonwealth of Virginia and its Political Subdivisions share a common desire
to abate and alleviate the impacts of the opioid epidemic throughout Virginia; and now
THEREFORE, the Commonwealth of Virginia and certain of its Political Subdivisions, subject
to completing formal documents effectuating the Parties' agreements, enter into this Virginia
Opioid Abatement Fund and Settlement Allocation Memorandum of Understanding ("MOU")
relating to the allocation and use of the proceeds of any Settlements as described herein.
A. Definitions
As used in this Virginia Term Sheet:
"The Commonwealth" shall mean the Commonwealth of Virginia acting through
its Attorney General.
2. "Political Subdivision(s)" shall mean the Virginia counties and independent cities
represented by Counsel.
3. "Participating Political Subdivisions" shall mean the Political Subdivisions, along
with all Virginia counties and independent cities who agree to become signatories
to this MOU and to be bound by the terms of future Settlements.
4. "Counsel" shall mean the undersigned private attorneys representing the Political
Subdivisions.
S. "The Parties" shall mean the Commonwealth of Virginia, the Political
Subdivisions, and Counsel.
6. "Negotiating Committee" shall mean a three -member representative group of the
Parties. The Commonwealth shall be represented by the Virginia Attorney General
or his designees. The Political Subdivisions and Counsel shall be represented by
W. Edgar Spivey of Kaufman & Canoles, P.C. or his designee, and J. Burton
LeBlanc of Baron & Budd, P.C. or his designee.
7. "Settlement" shall mean the negotiated resolution of legal or equitable claims
against a Pharmaceutical Supply Chain Participant named in Complaints filed by
all the Political Subdivisions in court on or before April 30, 2020 when that
resolution has been jointly entered into by the Commonwealth, the Political
Subdivisions, and Counsel. "Settlement" also shall include the approval by a
United States Bankruptcy Court of a plan of reorganization or liquidation of a
Pharmaceutical Supply Chain Participant, or any other determination, ruling, or
decision by a United States Bankruptcy Court, in which legal or equitable claims
against the Pharmaceutical Supply Chain Participant by the Commonwealth and the
Political Subdivisions are settled, adjudicated, released, or otherwise resolved.
8. "Opioid Funds" shall mean monetary amounts obtained through a Settlement as
defined in this MOU.
9. "Approved Abatement Purposes" shall mean efforts to treat, prevent, or reduce
opioid use disorder or the misuse of opioids or to otherwise abate or remediate the
IPA
opioid epidemic, including but not limited to those efforts described in Section
C(4)(a) through 0) of this MOU. In addition, "Approved Abatement Purposes"
shall include the types of efforts approved for funding by the Authority that is
defined in Section C(1). "Approved Abatement Purposes" also shall include any
other abatement or remediation purposes to the extent such purposes are described
in a Settlement.
10. "Pharmaceutical Supply Chain" shall mean the process and channels through which
opioids or opioid products are manufactured, marketed, promoted, distributed or
dispensed.
11. "Pharmaceutical Supply Chain Participant" shall mean any entity that engages in or
has engaged in the manufacture, marketing, promotion, distribution, or dispensing
of an opioid analgesic,
B. Allocation of Settlement Proceeds
All Opioid Funds shall be initially divided with fifteen percent (15%) going to the
Participating Political Subdivisions ("Subdivision Share"), seventy percent (70%)
going to the Virginia Opioid Abatement Fund and to other Approved Abatement
Purposes as further described herein ("Opioid Abatement Share"), and fifteen
percent (15%) going to the Commonwealth of Virginia ("Commonwealth Share").
2. The Subdivision Share shall be allocated and paid to the Participating Political
Subdivisions in accordance with the division of proceeds referenced in the schedule
attached hereto as Exhibit A. The shares of Virginia counties and independent cities
who elect not to become Participating Political Subdivisions, if any, shall be
reallocated ratably to the Participating Political Subdivisions.
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3. In the event a Participating Political Subdivision merges, dissolves, or ceases to
exist, the allocation percentage for that Participating Political Subdivision shall be
redistributed equitably based on the composition of the successor subdivision.
4. The Commonwealth Share shall be deposited to the Attorney General's Regulatory,
Consumer Advocacy, Litigation, and Enforcement Revolving Trust Fund with
moneys transferred to the Commonwealth's General Fund as provided by law. To
the extent a Settlement requires that all Opioid Funds be used only for abatement
or similar purposes, then the Commonwealth Share shall be deposited and
distributed accordingly.
5. The Opioid Abatement Share of 70% of the Opioid Funds shall be allocated and
Paid as follows:
a. Fifty-five percent (55%) of the Opioid Funds shall be allocated and paid to the
Virginia Opioid Abatement Fund ("Fund)-
b. Fifteen percent (15%) of the Opioid Funds shall be allocated and paid to the
Participating Political Subdivisions and shall be used for Approved Abatement
Purposes ("Direct Subdivision Abatement Share"). Upon request, a
Participating Political Subdivision shall make publicly available information
showing the purposes for which the Participating Political Subdivision used
Direct Subdivision Abatement Share funds. The Direct Subdivision Abatement
Share shall be allocated and paid to the Participating Political Subdivisions in
accordance with the division of proceeds referenced in the schedule attached
hereto as Exhibit A. The shares of Virginia counties and independent cities who
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elect not to become Participating Political Subdivisions, if any, shall be
reallocated ratably to the Participating Political Subdivisions.
6. To the extent a Settlement requires that all Opioid Funds be used only for abatement
or similar purposes, then the Subdivision Share and the Commonwealth Share shall
be used for Approved Abatement Purposes.
7. To receive funds allocated under this MOU from any Settlement, the
Commonwealth and the Participating Political Subdivisions will comply with the
terms of any such Settlement, including, among other things, any reporting
requirements or restrictions on the use of funds for administrative purposes.
C. Virginia Opioid Abatement Fund and Virginia Opioid Abatement Authority
1. The Parties have sought creation of a Virginia Opioid Abatement Authority
("Authority") through legislation submitted to the Virginia General Assembly,
which passed in the form attached hereto as Exhibit B. The Authority shall
administer the Fund, which also shall be created through the Icgislation. The
Authority shall seek to abate and remediate the opioid epidemic in Virginia through
financial support from the Fund in the form of grants, donations, or other assistance,
for efforts to treat, prevent, and reduce opioid use disorder and the misuse of opioids
in Virginia.
2. The Authority shall be governed by a Board of Directors consisting of 11 members
as follows: (i) the Secretary of Health and Human Resources, or his designee; (ii)
the Chair of the Senate Committee on Finance and Appropriations or his designee
and the Chair of the House Committee on Appropriations or his designee; (iii) an
elected member of the governing body of a Participating Political Subdivision, to
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be selected from a list of three submitted jointly by the Virginia Association of
Counties and the Virginia Municipal League; (iv) one representative of a
community services board or behavioral health authority of an urban or suburban
region containing Participating Political Subdivisions and one representative of a
community services board or behavioral health authority of a rural region
containing Participating Political Subdivisions, each to be selected from lists of
three submitted by the Virginia Association of Community Services Boards; (v)
one sheriff of a Participating Political Subdivision, to be selected from a list of three
submitted by the Virginia Sheriffs' Association; (vi) one licensed, practicing City
or County Attorney of a Participating Political Subdivision, to be selected from a
list of three submitted by the Local Government Attorneys of Virginia; (vii) two
medical professionals with expertise in public and behavioral health administration
or opioid use disorders and their treatment; and (viii) one representative of the
addiction and recovery community.
a. The members appointed pursuant to clause (i) shall serve ex officio, and the
members appointed pursuant to clauses (iii) through (viii) shall be appointed by
the Governor.
b. After an initial staggering of terms, members of the Board shall serve terms of
four years. No member shall be eligible to serve more than two terms. Any
appointment to fill a vacancy shall be for the unexpired term. A person
appointed to fill a vacancy may be appointed to serve two additional terms. Ex
officio members shall serve terms coincident with their terms of office.
Con
c. The Board shall elect annually a chairman and vice-chairman from among its
membership. The chairman, or in his absence the vice-chairman, shall preside
at all meetings of the Board. A majority of the members of the Board serving
at any one time shall constitute a quorum for the transaction of business. The
Board shall meet annually or more frequently at the call of the chairman.
3. The Authority shall establish specific criteria and procedures for awards from the
Fund; establish requirements for the submission of funding requests; evaluate
funding requests in accordance with the criteria established by the Authority; make
awards from the Fund in a manner that distributes funds equitably among all
community services board regions of the Commonwealth, including the
establishment of minimum percentages of funds that must be awarded to each
Participating Political Subdivision; and evaluate the implementation and results of
all efforts receiving support from the Authority.
4. The Authority may make grants and disbursements from the Fund that support
efforts to treat, prevent, or reduce opioid use disorder or the misuse of opioids or
otherwise abate or remediate the opioid epidemic. Such efforts may include but
shall not be limited to the following:
a. Support treatment of opioid use disorder and any co-occurring substance use
disorder or mental health conditions through evidence -based or evidence -
informed methods, programs, or strategies.
b. Support people in recovery from opioid use disorder and any co-occurring
substance use disorder or mental health conditions through evidence -based or
evidence -informed methods, programs, or strategies;
7
c. Provide connections to care for people who have, or are at risk of developing,
opioid use disorder and any co-occurring substance use disorder or mental
health conditions through evidence -based or evidence -informed methods,
programs, or strategies;
d. Support efforts, including law -enforcement programs, to address the needs of
persons with opioid use disorder and any co-occurring substance use disorder
or mental health conditions who are involved, or are at risk of becoming
involved, in the criminal justice system through evidence -based or evidence -
informed methods, programs, or strategies;
e. Support drug treatment and recovery courts that provide evidence -based or
evidence -informed options for people with opioid use disorder and any co-
occurring substance use disorder or mental health conditions;
f. Support efforts to address the needs of pregnant or parenting women with opioid
use disorder and any co-occurring substance use disorder or mental health
conditions, and the needs of their families, including babies with neonatal
abstinence syndrome, through evidence -based or evidence -informed methods,
programs, or strategies;
g. Support efforts to prevent over -prescribing and ensure appropriate prescribing
and dispensing of opioids through evidence -based or evidence -informed
methods, programs, or strategies;
h. Support efforts to discourage or prevent misuse of opioids through evidence -
based or evidence -informed methods, programs, or strategies;
8
i. Support efforts to prevent or reduce overdose deaths or other opioid-related
harms through evidence -based or evidence -informed methods, programs, or
strategies; and
j. Support efforts to provide comprehensive resources for patients seeking opioid
detoxification, including detoxification services.
5. The Authority shall provide financial support only for efforts that satisfy the
following conditions:
a. The efforts shall be conducted or managed by a Virginia state agency or
Participating Political Subdivision;
b. No support provided by the Authority shall be used by the recipient to supplant
funding for an existing program or continue funding an existing program at its
current amount of funding;
c. No support provided by the Authority shall be used by the recipient for indirect
costs incurred in the administration of the financial support or for any other
Purpose proscribed by the Authority; and
d. Recipients of support provided by the Authority shall agree to provide the
Authority with such information regarding the implementation of the effort and
allow such monitoring and review of the effort as may be required by the
Authority to ensure compliance with the terms under which the support is
provided.
6. The Authority shall give priority to applications for financial support for efforts
that:
0
a. Collaborate with an existing program or organization that has an established
record of success treating, preventing or reducing opioid use disorder or the
misuse of opioids;
b. Treat, prevent, or reduce opioid use disorder or the misuse of opioids in a
community with a high incidence of opioid use disorder or opioid death rate
relative to population;
c. Treat, prevent or reduce opioid use disorder or the misuse of opioids in a
historically economically disadvantaged community, as that term is defined in
Va. Code § 56-576; or
d. Include a monetary match from or on behalf of the applicant, with higher
Priority given to an effort with a larger matching amount.
7. For every deposit to the Fund, the Authority shall allocate a portion to the following
purposes:
a. Fifteen percent (15%) shall be restricted for use by state agencies;
b. Fifteen percent (15%) shall be restricted for use by Participating Political
Subdivisions with these funds distributed in accordance with the division of
proceeds referenced in the schedule attached hereto as Exhibit A. The shares of
Virginia counties and independent cities who elect not to become Participating
Political Subdivisions, if any, shall be reallocated ratably to the Participating
Political Subdivisions.
c. Thirty-five percent (35%) shall be restricted for use for regional efforts (a
partnership of at least two Participating Political Subdivisions within a
community services board region); and
WC
d. Thirty-five percent (35%) shall be unrestricted and may be used to fund the
Authority's staffing and administrative costs and may be distributed for use by
state agencies, by the Participating Political Subdivisions, or for regional efforts
in addition to the amounts set forth in subparagraphs 7(a)-(c), provided that the
Authority shall ensure that such funds are used to accomplish the purposes
described above or invested as described immediately below.
8. In distributing money from the Fund, the Authority shall balance immediate and
anticipated needs with projected receipts of funds in order to best accomplish the
purposes for which the Authority is established.
9• The Board may designate any amount from the Fund to be invested, reinvested, and
managed by the Board of the Virginia Retirement System.
D. Payment of Counsel and Litigation Expenses
1. The Parties anticipate that any national Settlement will provide for payment of all
or a portion of the attorneys' fees and litigation expenses of named plaintiff
Participating Political Subdivisions. Counsel for any named plaintiff Participating
Political Subdivision that seeks to recover attorneys' fees and litigation expenses
from Settlement funds shall first seek to recover such fees and expenses from any
national Settlement fund established to pay such fees and expenses. For such
purposes, the Parties agree that the monetary recoveries obtained via Settlement are
attributable to the Commonwealth and the Political Subdivisions 50% each.
2. In addition, the Parties agree that a supplemental attorneys' fees and costs fund (the
"Deficiency Fund") will be created; provided, however, that such Deficiency Fund
may not violate the terms of any national Settlement. In such event, the Parties
11
agree to exert diligent efforts to accomplish an alternate arrangement that preserves
the payment of counsel and litigation expenses outlined hereunder. Administration
of the Deficiency Fund shall be the responsibility of the Political Subdivisions, and
the costs of administration may be paid out of the Deficiency Fund.
3. The Deficiency Fund is to be used to compensate counsel for the Participating
Political Subdivisions that filed suit on or prior to April 30, 2020. Eligible
contingent fee contracts shall have been executed on or before April 30, 2020.
4. The Deficiency Fund shall be funded as follows: from any national Settlement, the
funds deposited in the Deficiency Fund shall be 25% of the Subdivision Share and
25% of the Direct Subdivision Abatement Share of each payment (annual or
otherwise) that is allocated to the Commonwealth of Virginia (including its political
subdivisions) for that Settlement. These funds shall be deposited to the Deficiency
Fund prior to distribution to the Participating Political Subdivisions. No portion of
the Deficiency Fund shall be drawn from the Commonwealth Share or the Fund.
5. The maximum percentage of any contingency fee agreement permitted for
compensation shall be 25% of the portion of the Subdivision Share and the Direct
Subdivision Abatement Share attributable to the named plaintiff Participating
Political Subdivision that is a party to the contingency fee agreement, plus expenses
attributable to that named plaintiff Participating Political Subdivision. Under no
circumstances may counsel collect more for its work on behalf of a named plaintiff
Participating Political Subdivision than it would under its contingency agreement
with that named plaintiff Participating Political Subdivision.
12
6. To the extent that funds available in the designated amounts or percentages set forth
in this Section D are inadequate to fully pay amounts due under contingent fee
contracts, funds shall be distributed to private counsel for named plaintiff
Participating Political Subdivisions who filed suit and entered into contingent fee
contracts prior to April 30, 2020 on a pro rata basis based on the percentage of the
total population of named plaintiff Participating Political Subdivisions contained in
the named plaintiff Participating Political Subdivision that private counsel
represents.
7. Any funds remaining in the Deficiency Fund in excess of the amounts needed to
cover private counsel's representation agreements shall revert to the Participating
Political Subdivisions and be allocated to the sources from which they derived.
8. Any attorneys' fees related to representation of the Commonwealth of Virginia shall
not be paid from the Subdivision Share, the Direct Subdivision Abatement Share,
or the Fund but shall be drawn directly from the Commonwealth Share or through
other sources. Any payments of attorneys' fees related to representation of the
Commonwealth of Virginia from such other sources shall not be deemed Opioid
Funds subject to allocation under this MOU.
E. Settlement Negotiations
1. The Negotiating Committee members agree to inform each other in advance of any
negotiations relating to any Virginia -only Settlement with a Pharmaceutical Supply
Chain Participant that includes both the Commonwealth and its Political
Subdivisions and shall provide each other the opportunity to participate in such
negotiations.
13
2. The Parties further agree to keep each other reasonably informed of all other global
settlement negotiations with Pharmaceutical Supply Chain Participants. Neither this
provision, nor any other, shall be construed to state or imply that the Commonwealth
or the Political Subdivisions are unauthorized to engage in settlement negotiations
with Pharmaceutical Supply Chain Participants without prior consent or
contemporaneous participation of the other, or that either party is entitled to
participate as an active or direct participant in settlement negotiations with the other.
Rather, while the Commonwealth's and the Political Subdivisions' efforts to achieve
worthwhile settlements are to be collaborative, incremental stages need not be so.
3. As this is a Virginia -specific effort, the Negotiating Committee shall be chaired by
the Attorney General or his designee.
4. The Commonwealth of Virginia, the Political Subdivisions, or Counsel may
withdraw from coordinated Settlement discussions detailed in this Section upon 5
days' written notice to the remaining Committee Members and counsel for any
affected Pharmaceutical Supply Chain Participant. The withdrawal of any Member
releases the remaining Committee Members from the restrictions and obligations in
this Section E.
5. The obligations in this Section E shall not affect any Party's right to proceed with
trial or, within 30 days of the date upon which a trial involving that Party's claims
against a specific Pharmaceutical Supply Chain Participant is scheduled to begin,
reach a case -specific resolution with that particular Pharmaceutical Supply Chain
Participant.
14
6. Nothing in this MOU alters or changes the right of the Commonwealth or any
Political Subdivision to pursue its own claim. The intent of this MOU is to join the
Parties to reach a Settlement or Settlements.
Acknowledgment of Agreement
We, the undersigned, have participated in the drafting of the above MOU, including
comments solicited from client Political Subdivisions. This document has been collaboratively
drafted to maintain all individual claims while allowing the Commonwealth and its Political
Subdivisions to cooperate in exploring all possible means of resolution. Nothing in this agreement
binds any party to any specific outcome. Any resolution under this document will require
acceptance by the Commonwealth of Virginia and the Participating Political Subdivisions.
We, the undersigned, hereby accept the VIRGINIA OPIOID ABATEMENT FUND AND
SETTLEMENT ALLOCATION MEMORANDUM OF UNDERSTANDING. We understand
that the purpose of this MOU is to permit collaboration between the Commonwealth of Virginia
and Political Subdivisions to explore and potentially effectuate earlier resolution of the Opioid
Litigation against Pharmaceutical Supply Chain Participants. We also understand that an
additional purpose is to create an effective means of distributing any potential Settlement funds
obtained under this MOU between the Commonwealth of Virginia and the Participating Political
Subdivisions in a manner that would promote an effective and meaningful use of the funds in
abating the opioid epidemic throughout Virginia.
Executed this Z64' day of v y , 2021.
FOR THE COMMONWEALTH OF VIRGINIA:
"ate C z. �--
MARK R. HERRING
ATTORNEY GENERAL
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Executed this 20d' day of August, 2021 Signatu
Printed
KAUFMAN & CANOLES, P.C.
W. Edgar Spivey (VSB No. 29125)
Patrick H. O'Donnell (VSB No. 29637)
150 W. Main Street, Suite 2100
Norfolk, VA 23510
wespivey@kaufcan.com
phodonnell@kaufcan.com
(757) 624-3000 - phone
(888) 360-9092 - fax
SANFORD HEISLER SHARP, LLP
Grant Morris (VSB No. 16290)
Andrew H. Miller (pro hac vice)
700 Pennsylvania SE, Suite 300
Washington, DC 20003
gmorris@sanfordheisler.com
amiller@sanfordheisler.com
(202) 499-5200 - phone
(202) 499-5199 - fax
SANFORD HEISLER SHARP, LLP
Kevin Sharp (pro hac vice)
R. Johan Conrod, Jr. (VSB No. 46765)
Jonathan Tepe (pro hac vice)
611 Commerce Street, Suite 3100
Nashville, TN 37203
ksharp@sanfordheisler.com
JConrod@sanfordheisler.com
jtepe@sanfordheisler.com
(615) 434-7000 - phone
(615) 434-7020 - fax
THE CICALA LAW FIRM PLLC
Joanne Cicala (pro hac vice)
R. Johan Conrod, Jr. (VSB No. 46765)
101 College Street
Dripping Springs, TX 78620
joanne@cicalapllc.com
johan@cicalapllc.com
(512) 275-6550 - phone
(512) 858-1801 —fax
Executed this 20thday of August , 2021 Signature.
BARON & BUDD, P.C.
J. Burton LeBlanc, IV
3102 Oak Lawn Avenue, Suite
Dallas, TX 75219
(214) 521-3605 - phone
(214) 520-1181 - fax
bleblanc&baronbudd.com
KALFUS & NACHMAN, P.C.
Christopher I. Jacobs
P.O. Box 12889
Norfolk, VA 23541
(757) 461-4900 — phone
(757) 461-1518 — fax
ciigknle al.com
Printed Name: Aaron L. Harrah
HILL, PETERSON, CARPER, BEE &
1100 DEITZLER, PLLC
James C. Peterson
Aaron L. Harrah
NorthGate Business Park
500 Tracy Way
Charleston, WV 25311
(304) 345-5667 — phone
j cpetersonapcbd. com
GREENE, KETCHUM, FARRELL,
BAILEY & TWEEL LLP
Bert Ketchum
419 - 11 th Street (25701)
P.O. Box 2389
Huntington, West Virginia 25724-2389
(800) 479-0053 — phone
(304) _525-9115 - phone
(304) 529-3284 fax
bertkgreeneketchum.com
WILLIAMS & LIGHT
Mark T. Williams
317 Patton Street
Danville, VA 24541
(434) 483-5196 — phone
DANIEL THOMAS LAW
Jacob Berkley Daniel
P.O. Box 999
Yanceyville, NC 27379
(336) 694-4363
jdaniel@danielthomaslaw.com
LEVIN, PAPANTONIO, THOMAS,
MITCHELL, RAFFERTY & PROCTOR,
P.A.
Peter J. Mougey
316 S. Baylen Street, Suite 600
Pensacola, FL 32502-5996
(850) 435-7068 — phone
(850) 436-6068 — fax
mouge_y(cr�,levinlaw.com
POWELL & MAJESTRO, PLLC
Anthony J. Majestro
405 Capitol Street, Suite P-1200
Charleston, WV 25301
(304) 346-2889 — phone
(304) 346-2895 — fax
ama' estrogl2owellmaj estro.com
KILGORE LAW FIRM
Terry Kilgore
197 W. Jackson St.
P.O. Box 669
Gate City, VA 24251
(276) 386-7701 —phone
(276) 386-2377 — fax
tkilgore@,kilgorelawoffice.com
Executed this 2V day of Av� 0.5� , 2021
WAGSTAFF & CARTMELL LLP
4740 Grand Avenue, Suite 300
Kansas City, MO 64112
(816) 701-1100 - phone
(816) 531-2372 - fax
tcartmeIl,9wcllp corn
bmaddeii@wcll]).com
ebarton a,wcllp.com
s_ruane@wcllp.com
CAMPBELL LAW FIRM
Jeffrey L. Campbell
117 N. Park Street
Marion, VA 24354
(276) 783-8197
ieff@camubelllawfirmva com
Kimberly C. Haugh, PC
Kimberly C. Haugh
324 Cummings Street
Abingdon, VA 24210
(276) 676-2400 - phone
(276) 525-4359 - fax
kchlaw roup(a7gmail coin
DUMAS LAW FIRM, LLC
Joey D. Dumas
P.O. Box 3046
Mobile, AL 36652
(251) 222-6669 - phone
(251) 217-7753 - fax
ioeyQ oeydumaslaw. com
Signature:
Printed Name:
Executed thi4 day ofA44,'Ie�. 2021
WEITZ & LUXENBERG, P.C.
Paul J. Pennock
Ellen Relkin
700 Broadway
New York, NY 10003
(212) 558-5549 — phone
ppennock !jweitz.lux.com
erelkimii'. eitzlu.X.com
MARKS & HARRISON
Lee J. Bujakowski
2141 E. Hundred Road
Chester, VA 23836
(804) 458-2766 — phone
lbuiakowski-u marksandharrison.com
Signature: r
Printed Name:
A_
Executed thiso day of , 2021.
SCOTT & SCOTT, ATTORNEYS AT LAW, LLP
Donald A. Broggi
The Helmsley Building
230 Park Avenue, 17`' Floor
New York, NY 10169
(212) 223-6444 —phone
(212) 223-6334 — fax
dbraggi{iuscott-sco tt. coj1i
Signature: 2L" I'll
Printed Name: be,►wa.t_4 �3RG�C e
FURNISS, DAVIS, RASHKIND AND SAUNDERS, P.C.
James A. Cales, III (VSB No. 41371)
6160 Kempsville Circle, Suite 341 B
Norfolk, Virginia 23502
icales@fumissdavis.com
Executed this LOday of w.. , 2021
CHAP PETERSEN & ASSOCIATES, P.C.
J. Chapman Petersen
David L. Amos
3970 Chain Bridge Road Fairfax, VA 22030
(571) 459.2512 —phone
(571) 459.2307 — fax
icl2@petersenfinn.com
dlana,petersenfirm com
PINTO COATES KYRE & BOWERS.
PLLC
Jon Ward
Paul D. Coates
3203 Brassfield Road
Greensboro, NC 27410
(336) 282.8848 — phone
36) 282.8409 — fax
jward@pckb-IaNv.com
pcoates@pckb-law.com
DANIEL TI IOMAS
Jacob Berkley Daniel
139 E. Main Street
P.O. Box 999
Yanceyville, NC 27379
(336) 694-4363
Fax: (336) 694-6601
idanielndanielthomaslaw com
EDWARDS LAW FIRM
John. S. Edwards
Seven-O-Seven Building
707 S. Jefferson Street Suite 310
Roanoke, VA 24016
(540) 985.8625 — phone
(540) 345.9950 — fax
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DONALD R. VAUGHAN & ASSOCIATES
Donald R. Vaughan
612 W. Friendly Avenue
Greensboro, NC 27401
(336) 273-1415 — phone
(866) 903-1301 —fax
don.vaughankt,vaughanlaw cony
BRINSON, ASKEW, BERRY, SEIGLER,
RICHARDSON & DAVIS, LLP
J. Anderson Davis
Samuel L. Lucas
Lee B. Carter
P.O. Box 5007
Rome, GA 30162-5007
(706) 291-8853 —phone
(706) 234-3574 — fax
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slucas a�brinson-askew.cotn
Icarter@brinson-asks« com
McCAMY, PHILLIPS,
FORDHAM, LLP
Robert H. Smalley
P.O. Box 1105
Dalton, GA 30720-1105
(706) 508-4292 —phone
(706) 278-5002 — fax
rsmal ley(almccamylaw.com
TUGGLE &
THE FINNELL FIRM
Robert K. FinneIl
1 West Fourth Avenue, Suite 200
Rome, GA 30162-0063
(706) 235-7272 — phone
(706) 235-9461 —fax
bob. hfinnellfirm.com
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STREET LAW FIRM, LLP
Benjamin A. Street
Jason D. Gallagher
1142 Riverview Street
P.O. Box 2100
Grundy, VA 24614
(276) 935-2128 — phone
(276) 935-4162 — fax
bas(c�streetlawfirm com
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MICHIEHAMLETT ATTORNEYS AT LAW
David W. Thomas
J. Gregory Webb
Bryan Slaughter
310 41' Street NE
P.O. Box 298
Charlottesville, VA 22902
(434) 951-7224 - phone
(434) 951-7244 — fax
dthomas michiehamlett.com
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