Documents
Below are links to copies of important documents related to the Mallinckrodt Bankruptcies.
Foundational Documents
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2022 Plan:
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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)
- Aspen, ACE and Old Colony Consolidated Reply in Support of Their Motion for Summary Judgment (stamped) (filed November 4, 2024)
- REDACTED - National Union and American Home Reply ISO Cross-Motion for Summary Judgment (as submitted) (filed November 4, 2024)
- American Guarantee's Combined Reply In Support Of Its Motion For Summary Judgment and in Opposition To Plaintiff (unstamped) (filed November 5, 2024)
- Order re Limited Stay of Discovery and Impact on Schedule Pending Resolution of PCOH Motions (filed January 24, 2025)
- Judgment and Order Granting Insurers Motions for Summary Judgment (filed March 10, 2025)
- MDT II's Appellant's Brief (filed November 24, 2025)
- Appendix to MDT II's Appellant's Brief (filed November 24, 2025)
- Brief for Respondents Old Colony and Aspen (filed January 21, 2026)
- AGLIC Joinder Brief (filed January 21, 2026)
- ACE Joinder Brief (filed January 21, 2026)
- AIG Insurers Reply Brief (filed January 21, 2026) (redacted)
- Appendix to AIG Insurers Reply Brief (filed January 21, 2026) (redacted)
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)
- (REDACTED) Opposition of the Opioid MDT II to Covidien's Motion for Summary Judgment Based on the Section 546(e) Safe Harbor (filed December 27, 2024, Docket #147)
- (REDACTED) Covidien's Reply Brief in Support of its Motion for Summary Judgment Based on the Section 546(e) Safe Harbor (filed February 5, 2025, Docket #158)
- Declaration of Joel Millar in Support of Covidien's Reply Brief (filed February 5, 2025, Docket #159)
- Transcript regarding Hearing Held 05-09-25 RE Motion for Summary Judgement (Filed May 15, 2025, Docket #179)
- Opinion Relating to Covidien's Motion for Summary Judgment Based on the Section 546(e) (filed August 20, 2025, Docket #182)
- Order Granting in part, Denying in part Covidien's Motion for Summary Judgment Based on the 546(e) Safe Harbor (filed September 3, 2025, Docket #186)
Share Repurchase Program Action (Opioid Master Disbursement Trust II v. Argos Capital Appreciation Master Fund LP, et al., Adv. Pro. No. 22-50435 (Bankr. D. Del.))
Other Opioid Claims
- Notice of Bar Date: Other Opioid Claims (filed September 16, 2022, Docket #8198)
- Order Approving Seventh Motion of the Trustees of the Opioid Master Disbursement Trust II for an Order Extending the Deadline to Object to Other Opioid Claims (Order Signed on 9-19-2025)
- Stipulation Between MDT II and Certain Distributor Claimants
- Stipulation Between MDT II and McKesson