Documents
Below are links to copies of important documents related to the Mallinckrodt Bankruptcies.
Foundational Documents
-
2022 Plan:
-
2023 Plan:
- Restructuring Support Agreement (dated August 23, 2023)
- Final Amendment to Opioid Deferred Cash Payments Agreement (dated August 23, 2023)
- Final Amendment to Opioid MDT II Cooperation Agreement (dated August 23, 2023)
- Distribution Summary (for the August 29, 2023, payment)
- First Amended Prepackaged Joint Plan of Reorganization of Mallinckrodt (filed September 29, 2023)
- Bankruptcy Court Confirmation of Mallinckrodt's First Amended Prepackaged Joint Plan of Reorganization (filed October 10, 2023)
- Opioid Trust CVR Agreement (dated November 14, 2023)
Insurance Action (Opioid Master Disbursement Trust II a/k/a Opioid MDT II v. Ace American Insurance Company, et al., Case No. 22SL-CC02974 (Mo. Cir. Ct.))
- Opioid MDT II Insurance Coverage Petition (filed June 16, 2022) (amended July 28, 2022)
- UK Insurers' Motion to Dismiss First Amended Petition (filed October 11, 2022)
- ACE Joinder with UK Insurers' Mot. To Dismiss First Amended Petition (filed October 11, 2022)
- Aspen Joinder with UK Motion to Dismiss First Amended Petition (filed October 11, 2022)
- Aspen Motion to Dismiss First Amended Petition or Motion for More Definite Statement (filed October 11, 2022)
- Plaintiff's Response Memorandum in Opposition to Certain UK Insurers' Motion to Dismiss (filed November 23, 2022)
- Plaintiff's Response Memorandum in Opposition to ACE and Aspen's Joinder in Certain UK Insurers' Motion to Dismiss (filed November 23, 2022)
- Plaintiff's Response Memorandum in Opposition to Aspen's Motion to Dismiss and Motion for More Definite Statement (filed November 23, 2022)
- UK Insurers' Reply in Support of Motion to Dismiss (filed December 14, 2022)
- ACE Reply in Support of Joinder in Motion to Dismiss (filed December 14, 2022)
- Aspen's Reply in Support of its Joinder in UK's Motion to Dismiss and Joinder in UK's Reply (filed December 14, 2022)
- Aspen's Reply in Support of its Motion to Dismiss and Motion for More Definite Statement (filed December 14, 2022)
- Order Granting Certain UK Insurers' Motion to Dismiss (filed March 22, 2023)
- Order Granting ACE's Motion to Dismiss (filed March 22, 2023)
- Order Granting Aspen's Motion to Dismiss, Denying Motion for More Definite (filed March 22, 2023)
- Petition for Declaratory Relief (filed December 20, 2023)
- Order to Consolidate (filed January 30, 2024)
- Majority Opinion of Court of Appeals (filed March 5, 2024)
- Order Extending Preliminary Injunction (filed March 28, 2024)
- Plaintiff's Motion for Partial Summary Judgment against National Union Fire Insurance Company (filed April 16, 2024)
- Plaintiff's Memorandum of Law in Support of its Motion for Partial Summary Judgment (redacted, filed April 16, 2024)
- Appellant's Application for Transfer to Missouri Supreme Court Filed in Court of Appeals (filed April 24, 2024)
- Order Denying Appellant's Application for Transfer to Missouri Supreme Court (filed April 24, 2024)
- Appellant's Application for Transfer Filed in the Missouri Supreme Court (filed April 24, 2024)
- Denial of Transfer Application (filed June 4, 2024)
- Aspen's ACE's Memo of Law re MSJ on PCOH Coverage (filed July 17, 2024)
- REDACTED National Union and American Home Assurance Co.'s Response to Statement of Uncontroverted Facts and Statement of Additional Facts (filed July 17, 2024)
- REDACTED National Union and American Home Responsive Memorandum (filed July 17, 2024)
- Plaintiff's (1) Memorandum in Opposition to AGLIC's MPSJ and (2) Cross-Motion for Partial Summary Judgment against AGLIC (filed September 18, 2024)
- Plaintiff's (1) Memorandum in Opposition to Aspen, Ace, and Old Colony's MPSJ and (2) Plaintiff's Cross-MPSJ against Aspen, ACE, and Old Colony (filed September 18, 2024)
- Plaintiff's Reply Memorandum in Support of its MPSJ against National Union and in Opposition to AIG's Cross-Motion for Partial Summary Judgment (filed September 18, 2024)
- Plaintiff's Response to AIG Insurers' Statement of Additional Facts (filed September 18, 2024)
- Plaintiff's Response to American Guarantee and Liability Insurance Company's Statement of Uncontroverted Facts (filed September 18, 2024)
- Plaintiff's Response to Aspen's and ACE's Joint Statement of Uncontroverted Fact (filed September 18, 2024)
- Plaintiff's Statement of Uncontroverted Facts in Support of Its Cross-Motions for Partial Summary Judgment against AGLIC, Aspen, ACE, and Old Colony (filed September 18, 2024)
Covidien Spinoff Action (Opioid Master Disbursement Trust II v. Covidien Unlimited Co., et al., Adv. Pro. No. 22-50433 (Bankr. D. Del.))
- Redacted Opioid MDT II Covidien Spinoff Complaint (filed October 14, 2022, Docket #4) (unredacted version filed October 11, 2022, Docket #2)
- Redacted Covidien Motion to Dismiss (filed December 23, 2022, Docket #13) (unredacted version filed December 23, 2022, Docket #15)
- Redacted Opioid MDT II Opposition to Covidien's Motion to Dismiss (filed March 3, 2023, Docket #24) (unredacted version filed February 28, 2023, Docket #23)
- Redacted Covidien Reply Brief in Support of Its Motion to Dismiss the Complaint (filed April 5, 2023, Docket #27) (unredacted version filed March 31, 2023, Docket #26)
- Opioid MDT II Motion to Amend the Complaint (filed June 21, 2023, Docket #35)
- Redacted Opioid MDT II Covidien Spinoff Amended Complaint (filed June 21, 2023, Docket #35-2) (unredacted version filed June 15, 2023, Docket #33)
- Covidien Opposition to Motion of Opioid MDT II to Amend Complaint (filed June 29, 2023, Docket #41)
- Reply in Support of Motion of Opioid MDT II for Leave to File an Amended Complaint (filed July 10, 2023, Docket # 47)
- OPINION regarding Motion to Dismiss Adversary Proceeding and Motion for Leave to File Amended Complaint (filed January 18, 2024, Docket #57)
- Redacted Amended Complaint (filed February 14, 2024, Docket #61) (unredacted version filed February 8, 2024, Docket #59)
- Demand for Trial by Jury (filed April 8, 2024, Docket #77)
- (REDACTED) Covidien's Motion for Summary Judgment Based on the Section 546(e) Safe Harbor (filed July 15, 2024, Docket #103)
- (REDACTED) Declaration of Tim Husnik (filed July 15, 2024, Docket #104)
- (REDACTED) Declaration of Ron Garber (filed July 15, 2024, Docket #105)