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ASHLEY MOODY ATTORNEY GENERAL STA'T'E OF FLORIDA April 13, 2021 Chairman Joseph Flescllcr Indian River County ISO 127th St Vero Beach, FL 32960 Ji�- LESCI-IER@IRCGOV.COM RE: Opioid Litigation Dear Chairman Joseph Fleseher: OFFICE OF THE A°CTORNEY GENERAL. 111,-0 1 The Capitol Tallahassee, IT 32399-1050 Phone (8M)4 14-3300 fax (850) 487-0168 lutli:Lhrnu'• n{tJlaridnle�aLcan My name is John Guard and i am the Chief Deputy Attorney General for the State of Florida (the "State"). Since she took office, Attorney General Moody has been heavily involved in leading both the State's ongoing opioid litigation and several different negotiations with defendants in that litigation. Those negotiations have included litigation counsel representing cities and counties. y As part of those negotiations to enable Florida to achieve the maximum amount recoverable for both the State and its subdivisions, the State has been negotiating fora lengthy time with outside counsel for nearly all litigating political subdivisions within the State. After multiple sessions and significant compromise by both sides, the attached memorandum of understanding (` vfOU") has been reached. We have olfered and the lawyers for the litigating subdivisions are recommending to their clients that the attached MOU be accepted. This proposal is the result.of numerous meetings and includes feedback and comments from many local subdivisions. Based on the status of this litigation, the likely structure of any resolution, the potential litigation risks in the absence of such an agreement, the State believe that this proposal reflects a reasonable compromise betxvicen the State and its political subdivisions. The purpose of this letter is to summarize the primary terms of the MOU and attempt to anticipate questions that you, your commission, and your internal and/or other legal counsel may have regarding this litigation and allocation proposal. Page 1 of 7 53