Plaintiffs and the Teva Defendants therefore jointly request that the Court sever the claims against the Teva Defendants from the action, including trial in this matter.

The parties further request a stay as to the Teva Defendants with respect to all trial court proceedings.

The grant of a severance and stay is appropriately within the Court’s discretion, avoids waste of judicial resources, and is consistent with the Court’s authority to sever parties from the action and order separate trials pursuant to Federal Rules of Civil Procedure 21 and 42, respectively.

The parties intend to jointly file a stipulation to dismiss the Teva Defendants with prejudice following the finalization of the anticipated settlement, including all necessary settlement

In the meantime, a stay would promote judicial economy by allowing Plaintiffs and the Teva Defendants to devote their resources to finalizing the settlement agreements, rather than participating in motion practice and discovery efforts in connection with this litigation.

Pursuant to Local Rule 16.1(d).6, the Parties have met and conferred, and hereby jointly move the Court for entry of the Protective Order emailed to the Court on February 27, 2023.

Pursuant to Federal Rule of Civil Procedure 12(b)(6), the undersigned Manufacturer Defendants2 hereby move this Court for an Order dismissing Plaintiffs’ First Amended Petition for failure to state a claim upon which relief can be granted.

Long-standing Missouri law precludes Plaintiffs from bringing the asserted claims in their First Amended Petition.

Noramco is a manufacturer of active pharmaceutical ingredients only and does not (and did not at all material times relevant hereto) manufacture, package, brand, market, promote, distribute, or sell the finished drug products at issue in this litigation.

Noramco thus is at least one step or more removed from the alleged conduct at issue and therefore, all claims against it should be dismissed as a matter of law.

The Manufacturer Defendants incorporate by reference their Memorandum of Law in Support of this motion filed contemporaneously herewith.

COMES NOW Defendant KVK-Tech, Inc., by and through counsel and pursuant to Federal Rule of Civil Procedure 12(b)(6), and moves this Court for an Order dismissing Plaintiffs’ First Amended Petition with prejudice for failure to state a claim upon which relief may be granted.

Plaintiffs’ false marketing claims against KVK-Tech, Inc. fail in that Plaintiffs have not and cannot allege any false marketing by KVK-Tech and such claims are preempted by federal law.

Also, Plaintiffs’ claims based upon a failure-to-prevent diversion fail to state claims upon which relief may be granted.

KVK-Tech incorporates by reference its Memorandum of Law in Support of this Motion, which is filed contemporaneously herewith.

WHEREFORE, KVK-Tech, Inc. prays this Court enter an order dismissing Plaintiffs’ First Amended Petition with prejudice and for such other and further relief as the Court deems just and proper.

4 Nonetheless, the data and methods used by Plaintiff’s expert, William Legier, are reliable.

... that McKesson should not have shipped “an unspecified portion of the opioids it distributed in Missouri.” Nonetheless, to be very clear, McKesson’s shipments to Missouri are all identifiable and traceable for the relevant time and none ...

The Proposed Settlements Are Adequate in Light of the Costs, Risks, and Delay of Trial and Appeal “Although it is not the role of the Court at this stage of the litigation to evaluate the merits … it is clear that the parties could reasonably conclude that there are serious questions of law and fact that exist such that they could significantly impact the case if it were litigated.” Lucas v. Kmart Corp., 234 F.R.D.

This consideration largely overlaps with the second (“‘whether serious questions of law and fact exist, placing the ultimate outcome of the litigation in doubt’”) and third factors (“‘whether the value of an immediate recovery outweighs the mere possibility of future relief after protracted and expensive litigation’”) traditionally considered by courts in the Tenth Circuit.

The presence of serious legal and factual questions concerning the outcome of the ACH Opioids Litigation weighs heavily in favor of settlement, as “settlement outweighs the mere possibility of future relief after protracted and expensive litigation.” See Montgomery, 2021 WL 1339305, at *6; In re Qwest Commc’ns Int’l, Inc. Sec.

Considering the risks associated with continued litigation, as discussed above, the immediate, substantial relief offered by the Settlements “outweigh an uncertain result several years in the future.” Montgomery, 2021 WL 1339305, at *10; see id. at *6 (“‘[I]t has been held proper “to take the bird in the hand instead of a prospective flock in the bush.’”); In re Thornburg Mortg., Inc. Sec.

… In short, the ultimate resolution of this action on the merits (and in turn, compensation to Settlement Class Members) via trial and appeal is indefinite at best.”); Chavez Rodriguez, 2020 WL 3288059, at *3 (observing that “the costs and time of moving forward in litigation would be substantial”); Lucas, 234 F.R.D.

Any Settlement Class Member that does not timely submit a Registration Form and/or Claim Form within the time provided shall be barred from sharing in the distribution of the proceeds of the Settlement but shall nonetheless be bound ...

Based on my experience and my review ofhistorical materials, I am aware that the Navy required specific changes to the content and wording of manuals submitted by Buffalo Pumps and other naval equipment manufacturers.

delete (e} Page 1-2-1 - In the first sentence under Pi Before the "all" and substitute "Normally all rigid...." fourth sentenceadd, "However since thie pump is resi- liently mounted, flexible hoses are to be installed to reduce sound transmission and will also prevent piping 6 Teet “De - he Nes ?

Page 1-kel, Paragraph 1-h-2 in the first sentence under "Trouble Shooting" delete "Listed below are" and substitute *Table- = = lists" et end of sentence add "and remedies", (3) Page 1-he2 - Delete paragreph number 1 to 5 and substitute table in the form "Trouble, Probable Cause, Remedy" in- cluding = (1) For "No Discharge", Probable Cause should include Pump not primed, Speed too Low, Impeller completely plugged, Plugged suction line or strainer, Pusp not running and Impeller .

(3) For Insufficient Discharge Presgure, Probable Cause should include Speed too Low, Air or gases in Liquid, Wrong direction of rotation, Mechanical Defects: Nearing rings worns Impeller damaged.

(7) Add Trouble "Noisy Installation or Excessive Vibration", ProbablsCause should include Loose mounting bolts, Hecharicaldefects, Impeller or mctor imbalanced, Air or gases in liquid, Foreign matter in pump, Miealignment.

 Thomas A. Genin v. Sean H. Anthony – Calculation and rebuttal as to the fair value of the Defendant’s 50% ownership interest – Restaurant Industry  Gulf Fleet Holdings, Inc., et al., Debtors and Alan H. Goodman, Trustee (Plaintiff-in-Intervention) v. H.I.G.

McGlinchey, Stafford, Cellini & Lang Terriberry, Carroll & Yancey; Nicolls Pointing Coulson, Ltd. Blue, Williams, LLP; Hartford Steam Boiler Insurance Co. Stassi, Griffith & Conroy, LLC Exxon Company,

Maynard, Cooper & Gale, Birmingham; Merrill Lynch Reed, Smith, Shaw & McClay, Pittsburgh; The Boston Company/ Mellon Financial Services Adams & Reese, LLP Steeg & O’Connor; Sazerac Company, Inc.

Calculation of business lost profits Al J. Derbes III and Associates Lindsey Morden Claim Services, Inc. Jones Walker; Whitney Bank Satterlee, Mestayer & Freeman Lowe, Stein, Hoffman, Allweiss & Hauver

Frilot, Partridge, Kohnke & Clements, LC; Levitz Furniture Corporation House, Golden, Kingsmill & Reiss LLP Lowe, Stein, Hoffman, Allweiss & Hauver Middleburg, Riddle & Gianna

4 Including the U.S. Department of Justice 5 As identified by Ms. White, certain Missouri counties are Adair, Barry, Barton, Boone, Buchanan, Butler, Dunklin, Gentry, Greene, Jackson, Newton, Nodaway, Polk, Randolph, and Taney.

McGlinchey, Stafford, Cellini & Lang Terriberry, Carroll & Yancey; Nicolls Pointing Coulson, Ltd. Blue, Williams, LLP; Hartford Steam Boiler Insurance Co. Stassi, Griffith & Conroy, LLC Exxon Company,

Maynard, Cooper & Gale, Birmingham; Merrill Lynch Reed, Smith, Shaw & McClay, Pittsburgh; The Boston Company/ Mellon Financial Services Adams & Reese, LLP Steeg & O’Connor; Sazerac Company, Inc.

Calculation of business lost profits Al J. Derbes III and Associates Lindsey Morden Claim Services, Inc. Jones Walker; Whitney Bank Satterlee, Mestayer & Freeman Lowe, Stein, Hoffman, Allweiss & Hauver

Frilot, Partridge, Kohnke & Clements, LC; Levitz Furniture Corporation House, Golden, Kingsmill & Reiss LLP Lowe, Stein, Hoffman, Allweiss & Hauver Middleburg, Riddle & Gianna

The State of Oklahoma and McKesson Corporation hereby give notice that a settlement has been reached through mutual agreementof the parties.

The parties must take additional steps to finalize the settlement and hope to have it completed in the next 90 days, at which point a stipulation of dismissal will be filed.

The parties hereby request a stay of this case pending the stipulation of dismissal.

July 1, 2022 Respectfully submitted,

Based on information and data that have been madeavailable to me, I can attest that from January 1, 2006 through October 31, 2019, McKesson’s opioid distributions to federal PPV Contractfacilities’ in the state of Oklahoma accounted for approximately 17.1 percent of !

The statewide ARCOS data that the State references in its Petition include opioid distributions that McKesson made to PPV Contract facilities.”

For purposes ofthis declaration, “PPV Contract facilities” refers to the facilities listed on the website of the Department of Veterans’ Affairs, available at https://www.va.gov/ opal/docs/nac/ncs/ppvEligibilityListing.xIs.

McKessonis required by its PPV Contractto distribute prescription pharmaceuticals to the U.S. Government purchasers who order through the contract.

McKessonis the primary distributor of prescription pharmaceuticals to the Indian Health Services and U.S. Department of Veterans Affairs in and around the economic proximity ofthe Tribe, whichis described in the Plaintiff's Complaintfiled in this matter.

@e © s @ Home My Network Jobs Messaging Lori White : 3rd Vice President of Government at McKesson ® McKesson Carrollton, Texas, United States - Contact info 500+ connections Activity 589 followers Lori hasn't postedlately Lori’s recent posts and commentswill be displayed here.

Showall activity > Experience McKesson 22 yrs 6 mos Carrollton, Texas Vice President of Government Jul 2016 - Present - 6 yrs 4 mos Director of Government Health Systems National Accounts May 2000 - Jun 2016 - 16 yrs 2 mos (tsTeam Lead Contracts WISKE55A3192-MDH Document 69-3 Filed 10/03/22 Page 2 of 3 ® eo Home My Network ss Jobs Messaging Lead Pharmacy Technician Merck-Medco 1992 - 1999 -7 yrs Fort Worth, TX Gey, PharmacyTechnician == Albertsons 1985 - 1992 - 7 yrs Irving, TX Skills Healthcare Endorsed by 16 colleagues at McKesson $2 20 endorsements Pharmacy Endorsed by 8 colleagues at McKesson ss 11 endorsements Managed Care Endorsed by 8 colleagues at McKesson s: 10 endorsements Showall 14 skills 3 Interests influencers Companies Groups G Brian Tyler {i CEO at McKesson 28,456 followers ( + Follow )