Endo Notice of Agreements with USDOJ SRF 77238
SKADDEN, ARPS, SLATE, MEAGHER& FLOM LLP
Paul D. Leake
Lisa Laukitis
Shana A. Elberg
Evan A. Hill
One Manhattan West
New York, New York 10001
Telephone: (212) 735-3000
Fax: (212) 735-2000
Counsel to the Debtors and Debtors in Possession
UNITED STATES BANKRUPTCY COURT
SOUTHERN DISTRICT OF NEW YORK
In re Chapter 11
ENDO INTERNATIONAL plc, et al., Case No. 22-22549 (JLG)
Debtors.' (Jointly Administered)
Related Docket Nos.3687&3756
NOTICE OF AGREEMENTS WITH
UNITED STATES DEPARTMENT OF JUSTICE
PLEASE TAKE NOTICE that on January 12,2024,the Bankruptcy Court for the
Southern District of New York (the "Court") entered the Order (I) Scheduling a Combined
Hearingfor Approval of the Disclosure Statement and Confirmation of the Plan; (II) Conditionally
Approving the Adequacy of the Disclosure Statement; (III)Approving (A) Procedures for
Solicitation, (B) Forms of Ballots and Notices, (C) Procedures for Tabulation of Votes, and
(D) Procedures for Objections; and (IV) Granting Related Relief [Docket No. 3549]
(the "Disclosure Statement Order"), which, among other things, conditionally approved the
Disclosure Statement with Respect to the Second Amended Joint Chapter 11 Plan of
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' The last four digits of Debtor Endo International plc's tax identification number are 3755.Due to the large number
of debtors in these chapter 11 cases,a complete list of the debtor entities and the last four digits of their federal
tax identification numbers is not provided herein. A complete list of such information may be obtained on the
website of the Debtors' claims and noticing agent at https://restructuring.ra.kroll.com/Endo. The location of the
Debtors' service address for purposes of these chapter 11 cases is: 1400 Atwater Drive,Malvern,PA 19355.
Reorganization of Endo International plc and its Affiliated Debtors [Docket No. 3548]
(the "Disclosure Statement).
PLEASE TAKE FURTHER NOTICE that on January 25, 2024, in accordance
with the Disclosure Statement Order,the Debtors commenced solicitation on the Second Amended
Joint Chapter 11 Plan of Reorganization of Endo International plc and its Affiliated Debtors
[Docket No. 3535] (as may be modified,amended,or supplemented from time to time,the"Plan").
PLEASE TAKE FURTHER NOTICE that, as contemplated by the Plan and the
Disclosure Statement Order, on February 15, 2024, the Debtors filed the Notice of Filing of Plan
Supplement[Docket No. 3687] (as may be modified,amended,or supplemented from time to time,
the "Plan Supplement"), which attached as Exhibit 16 thereto an update on potential resolutions
with the United States Department of Justice (the "DOJ"), in connection with certain claims filed
by the DOJ against the Debtors (the "DOJ Claims").
PLEASE TAKE FURTHER NOTICE that on February 29, 2024, the Debtors
filed the Notice of Filing of Agreements with United States Department of Justice [Docket No.
3756] (the"Notice"),which attached thereto three definitive agreements(the"Agreements")2 that,
collectively, address the Claims as set forth in the Agreements.
PLEASE TAKE FURTHER NOTICE that the Agreements shall be deemed to
replace Exhibit 16 of the previously-filed Plan Supplement, and shall be deemed included in the
Plan Supplement.
PLEASE TAKE FURTHER NOTICE that attached to the Notice as Exhibit A is
a global economic agreement (the "Global Agreement"), which incorporates the terms of the
Proposed Economic Resolution and resolves those DOJ Claims not resolved pursuant to the Plea
Agreement and Civil Settlement Agreement(each as defined below).
2 Capitalized terms used herein but not otherwise defined shall have the meanings ascribed to them in the Notice
(as defined herein),the Plan(as defined herein),or the Disclosure Statement,as applicable.
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PLEASE TAKE FURTHER NOTICE that attached to the Notice as Exhibit B is
a misdemeanor plea agreement (the "Plea Agreement"), which resolves the DOJ's criminal
investigations of the Debtors.
PLEASE TAKE FURTHER NOTICE that attached to the Notice as Exhibit C is
a civil settlement agreement (the "Civil Settlement Agreement"), which resolves the DOJ's civil
investigations of the Debtors.
PLEASE TAKE FURTHER NOTICE that each of the Agreements remains
subject to, among other conditions precedent, Court approval and the confirmation and
consummation of the Debtors' Plan.
PLEASE TAKE FURTHER NOTICE that the Plan Supplement, including the
Agreements, may be obtained at no charge from the Debtors' claims and noticing agent, Kroll
Restructuring Administration, LLC ("Kroll") by visiting the website maintained by Kroll at
htts://restructurin .ra.kroll.com/Endo (the "Case Website") and (a)clicking "Plan & Disclosure
P g
Statement" located within the "Quick Links" section of the left hand navigation panel or
(b)contacting Kroll via the "Live Chat" feature at the "Info Center"panel of the landing page.
PLEASE TAKE FURTHER NOTICE that the Confirmation Hearing is
scheduled to commence on March 19,2024 at 10:00 a.m. (prevailing Eastern Time)before the
Court.
PLEASE TAKE FURTHER NOTICE that copies of the Plan, the Disclosure
Statement, and any underlying exhibits thereto can be viewed and/or obtained(i)by accessing the
Court's website at www.nysb.uscourts.gov, (ii)by contacting the Office of the Clerk of the Court
at United States Bankruptcy Court for the Southern District of New York, or (iii) on the Case
Website at https://restructuring.ra.kroll.com/Endo; or by contacting Kroll directly at
(877) 542-1878 (toll free for callers within the United States and Canada)and(929)284-1688 (for
international callers).
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Dated: February 29, 2024
New York,New York /s/Paul D. Leake
SKADDEN, ARPS, SLATE,MEAGHER&
FLOM LLP
Paul D. Leake
Lisa Laukitis
Shana A. Elberg
Evan A. Hill
One Manhattan West
New York,New York 10001
Telephone: (212) 735-3000
Fax: (212) 735-2000
Counsel to the Debtors and Debtors in
Possession
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