Dane R. Voris v. Carver, Town of - Town Clerk (SPR 20251840)

The Commonwealth of Massachusetts William Francis Galvin, Secretary of the Commonwealth Public Records Division Manza Arthur Supervisor of Records July 28, 2025 SPR25/1840 Michelle Sheehan Records Access Officer Town of Carver Carver Town Hall 108 Main Street Carver, MA 02330 Dear Ms. Sheehan: I have received the petition of Dane Voris, Esq., of Cooley LLP, appealing the response of the Town of Carver (Town) to a request for public records. See G. L. c. 66, § 10A; see also 950 C.M.R. 32.08(1). On March 3, 2025, Roya Naghepour, Esq., of Alston & Bird, requested the following records: [1] All documents and other records relating to Town of Carver’s approval to bring claims against OptumRx, Inc.; Optum, Inc.; OptumInsight, Inc.; OptumInsight Life Sciences, Inc.; OptumRx Discount Card Services, LLC; Optum Perks, LLC; OptumHealth Care Solutions, LLC; OptumHealth Holdings, LLC; Optum Health Networks, Inc.; UnitedHealth Group Incorporated; Express Scripts, Inc.; Express Scripts Administrators, LLC; Medco Health Solutions, Inc.; ESI Mail Order Processing, Inc.; ESI Mail Pharmacy Service, Inc.; Express Scripts Pharmacy, Inc.; Evernorth Health, Inc.; or Express Scripts Specialty Distribution Services, Inc. in the national opioid litigation, In re Nat’l Prescription Opiate Litig., 1:17-md-2804 (N.D. Ohio) and its member cases (the “Opioid Litigation”). [2] All documents and other records relating to Town of Carver’s approval to file any complaint in the Opioid Litigation. [3] All documents and other records relating to Town of Carver’s approval to amend or supplement its complaint in the Opioid Litigation. [4] All engagement agreements, engagement letters, memoranda of understanding, memoranda of agreement, letters of intent, contracts, or other One Ashburton Place, Room 1719, Boston, Massachusetts 02108 • (617) 727-2832• Fax: (617) 727-5914 sec.state.ma.us/pre • pre@sec.state.ma.us

Michelle Sheehan SPR25/1840 Page 2 July 28, 2025 agreements (including any amendments, restatements, or modifications to such agreements) that [the] Town entered into with any law firms, attorneys, or other professionals (including, but not limited to . . .) to prosecute or assist with the prosecution of the Opioid Litigation or claims against any party or entity. [5] All documents authorizing any individual to act outside of a public hearing to authorize, approve, or consent to Town of Carver’s filing or amending any lawsuit and all documents identifying any individuals with that authority. The Town responded on March 13, 2025, and through its counsel, provided a further response on March 17, 2025. Unsatisfied with the responses, Attorney Voris petitioned this office and this appeal, SPR25/1840, was opened as a result. Subsequently, the Town, through its counsel, provided a supplemental response on July 11, 2025. In an email dated July 24, 2025, Attorney Voris informed this office that he wishes to withdraw the appeal. Accordingly, I will now consider this administrative appeal closed. Sincerely, Manza Arthur Supervisor of Records cc: Dane Voris, Esq. Lauren Goldberg, Esq.