HomeMy WebLinkAboutResolution 2017 (53)Resolution No. 53 (2017)
T + R (JAI X [_J RJ'1 Y RESOLUTION AUTHORIZING ENGAGEMENT LETTER
-e WITH VON BRIESEN & ROPER, S.C., CRUELER DICKINSON
LLC, TOGETHER WITH SIMMONS HANLY CONROY LLC,
AS COUNSEL IN RELATION TO CLAIMS AGAINST OPIOID
MANUFACTURERS
1 WHEREAS, St. Croix County is concerned with the recent rapid rise in troubles among
2 St. Croix County citizens, residents, and visitors in relation to problems arising out of the use,
3 abuse and overuse of opioid medications, which according to certain studies, impacts millions of
4 people across the country; and
5
6 WHEREAS, issues and concerns surrounding opioid use, abuse and overuse by citizens,
7 residents and visitors are not unique to St. Croix County and are, in fact, issues and concerns
8 shared by all other counties in Wisconsin and, for that matter, states and counties across the
9 country, as has been well documented through various reports and publications, and is
10 commonly referred to as the Opioid Epidemic ("Opioid Epidemic:); and
11
12 WHEREAS, the societal costs associated with the Opioid Epidemic are staggering and,
13 according to the Centers for Disease Control and Prevention, amount to over $75 billion
14 annually; and
15
16 WHEREAS, the National Institute for Health has identified the manufacturers of certain
17 of the opioid medications as being directly responsible for the rapid rise of the Opioid Epidemic
18 by virtue of their aggressive and, according to some, unlawful and unethical marketing practices;
19 and
20
21 WHEREAS, certain of the opioid manufacturers have faced civil and criminal liability
22 for their actions that relate directly to the rise of the Opioid Epidemic; and
23
24 WHEREAS, Wisconsin counties have spent millions in unexpected and unbudgeted time
25 and resources in its programs and services related to the Opioid Epidemic; and
26
27 WHEREAS, St. Croix County is responsible for a multitude of programs and services,
28 all of which require St. Croix County to expend resources generated through state and federal
29 aid, property tax levy, fees and other permissible revenue sources; and
30
31 WHEREAS, St. Croix County's provision of programs and services becomes more and
32 more difficult every year because the costs associated with providing the Opioid Epidemic
33 programs and services continue to rise, yet St. Croix County's ability to generate revenue is
34 limited by strict levy limit caps and stagnant or declining state and federal aid to St. Croix
35 County; and
36
37 WHEREAS, all sums that St. Croix County expends in addressing, combatting and
38 otherwise dealing with the Opioid Epidemic are sums that cannot be used for other critical
39 programs and services that St. Croix County provides to St. Croix County citizens, residents and
40 visitors; and
41
42 WHEREAS, St. Croix County has been informed that numerous counties and states
43 across the country have filed or intend to file lawsuits against certain of the opioid manufacturers
44 in an effort to force the persons and entities responsible for the Opioid Epidemic to assume
45 financial responsibility for the costs associated with addressing, combatting and otherwise
46 dealing with the Opioid Epidemic; and
47
48 WHEREAS, St. Croix County has engaged in discussions with representatives of the law
- 49 firms of vonBriesen & Roper, s.c., Crueger Dickinson LLC and Simmons Hanly Conroy LLC
50 (the "Law Firms") related to the potential for St. Croix County to pursue certain legal claims
51 against certain opioid manufacturers; and
52
53 WHEREAS, St. Croix County has been informed that the Law Firms have the requisite
54 skill, experience and wherewithal to prosecute legal claims against certain of the opioid
55 manufacturers on behalf of public entities seeking to hold them responsible for the Opioid
56 Epidemic; and
57
58 WHEREAS, the Law Firms have proposed that St. Croix County engage the Law Firms
59 to prosecute the aforementioned claims on a contingent fee basis whereby the Law Firms would
60 not be compensated unless St. Croix County receives a financial benefit as a result of the
61 proposed claims and the Law Firms would advance all claim -related costs and expenses
62 associated with the claims; and
63
64 WHEREAS, all of the costs and expenses associated with the claims against certain of
65 the opioid manufacturers would be borne by the Law Firms; and
66
67 WHEREAS, the Law Firms have prepared an engagement letter, which is submitted as
68 part of this Resolution ("Engagement Letter") specifying the terms and conditions under which
69 the Law Firms would provide legal services to St. Croix County and otherwise consistent with
70 the terms of this Resolution; and
71
72 WHEREAS, St. Croix County is informed that the Wisconsin Counties Association has
73 engaged in extensive discussions with the Law Firms and has expressed a desire to assist the
74 Law Finns, St. Croix County and other counties in the prosecution of claims against certain of
75 the opioid manufacturers; and
76
77 WHEREAS, St. Croix County would participate in the prosecution of the claim(s)
78 contemplated in this Resolution and the Engagement Letter by providing infonnation and
79 materials to the Law Finns and, as appropriate, the Wisconsin Counties Association as needed;
80 and
81
82 WHEREAS, the St. Croix County Board of Supervisors believes it to be in the best
83 interest of St. Croix County, its citizens, residents, visitors and taxpayers to join with other
84 counties in and outside Wisconsin in pursuit of claims against certain of the opioid
85 manufacturers, all upon the terms and conditions set forth in the Engagement Letter; and
86
87 WHEREAS, by pursuing the claims against certain of the opioid manufacturers, St.
88 Croix County is attempting to hold those persons and entities that had a significant role in the
89 creation of the Opioid Epidemic responsible for the financial costs assumed by St. Croix County
90 and other public agencies across the country in dealing with the Opioid Epidemic.
91
92 NOW, THEREFORE, BE IT RESOLVED that the St. Croix County Board of
93 Supervisors authorizes, and agrees to be bound by, the Engagement Letter and hereby directs the
94 appropriate officer of St. Croix County to execute the Engagement Letter on behalf of St. Croix
95 County; and
96
97 BE IT FURTHER RESOLVED that St. Croix County shall endeavor to faithfully
98 perform all actions required of St. Croix County in relation to the claims contemplated herein
99 and in the Engagement Letter and hereby directs all St. Croix County personnel to cooperate
100 with and assist the Law Firms in relation thereto.
Legal— Fiscal— Administrative Approvals:
Legal Note:
Fiscal Impact: Fiscal impact is hard to estimate at this point in time. The amount of fiscal impact
would be determined on the scope of work required by staff to compile information
and the likelihood of settlement.
Cott a. Cox, Corpora oh--(oui sel 10I 3r'2017
x Ar
—1 ert Mitict, FinancetrLctor �16120t7
27 ol , 4'. a
I�atrkck'fhoi33pso€i,Go�mtyAd�t�ini'A for 10,/13r`2017
10/18/17 Administration Committee APPROVED
RESULT:
APPR(
MOVER:
Jill Anr
SECONDER: ''
Tamm)
AYES:
Roy Sji
EXCUSED:
Scottie
Vote Confirmation.
.
T
r ae
f
Roy Sjob 9, Supervisor 10/21 / 017
St. Croix County Board of Supervisors Action:
Roll Call - Vote Requirement - Majority of Supervisors Present
This Resolution was Adopted by the St. Croix County Board of Supervisors on November 7, 2017
Cindy Campbell, County Clerk
r+,,,,,✓ _ 1..✓d, , tom„ e-Sf
a
von Grimen & Roper, s,e, j Altorneys at Law
October 11, 2017
VIA EMAIL,
St. Croix County
c/o Roger Larson, Board Chair
ICE: Engagement of von Briesen & Doper, s.c., and Crueger Dickinson LLC, Together with
Simmons .meanly Conroy LLC, as Counsel in Relation to Claims Against Opioid
Manufacturers
Dear St, Croix County Officials:
The purpose of this letter ("Engagement Letter") is to set out in writing the terms and conditions
upon which the law firms of von Briesen & Roper, s.c,, and Crueger Dickinson LLC (collectively
"Counsel) will provide legal services to St. Croix County ("County") in relation to the investigation
and prosecution of certain claims against the following manufacturers and other parties involved with
the manufacture of opioid medications: Purdue Pharma L.P., Purdue Phatina Inc., The Purdue
Frederick Company, Inc., Teva Pharmaceuticals USA, Inc., Cephalon, Inc., Johnson & Johnson,
Janssen Pharmaceuticals, Inc., O1thoMcNeil-Janssen Pharmaceuticals, Inc. n/k/a Janssen
Pharmaceuticals, Inc., Janssen. Pharmaceutica, Inc. n/k/a Janssen Pharmaceuticals, Inc.; Endo Health
Solutions Inc., Endo Pharmaceuticals, Inc., Russell Portenoy, Perry Fine, Scott Fishman and Lynn
Webster (collectively "Opioid Manufacturers"). Depending upon the results of initial investigations
of the facts and circumstances surrounding the potential claim(s), there may be additional parties
sought to be made responsible and/or certain of the aforementioned parties may be removed from the
potential claim.
This Engagement Letter shall apply solely and exclusively to the services set forth herein in relation
to the investigation and Lawsuit, as defined below. This Engagement Letter does not govern, nor
does it apply to, any services of either Counsel unrelated thereto.
Counsel will work with County in the collection of information necessary to form a good faith basis
for filing a claim against the Opioid Manufacturers. County hereby authorizes Counsel to file a
lawsuit against one or all of the Opioid Manufacturers ("Lawsuit") upon the terms and conditions set
forth herein.
"WMITapff-Hunum
Counsel will prosecute the Lawsuit with diligence and keep County reasonably informed of progress
and developments, and respond to Comity's inquiries. County understands and agrees that Counsel,
on behalf of County, will engage the services of the nationally -recognized law firm Simmons Hanly
Conroy LLC, which has demonstrated experience prosecuting claims against Opioid Manufacturers
("National Law Finn") and which, in addition to Crueger Dickinson LLC, will serve as counsel of
record for County in relation to the Lawsuit. County understands and agrees that all fees paid to
Counsel and National Law Firm shall be as set forth in this Engagement Letter, County shall not be
responsible for any fees and expenses of National Law Firm beyond the fees and expenses for which
County has agreed to be responsible as set forth herein. County agrees to cooperate with Counsel
and National Law Finn in the gathering of information necessary to investigate and prosecute the
Lawsuit, County further understands and agrees that the law firm of von Briesen & Roper, s.c., shall
St, Croix County
Engagement Letter
Page -2
not be identified on any pleading as counsel of record for County in relation to the Lawsuit, but shall
be available to assist County and Counsel and National Law Firm in relation to the Lawsuit.
The following additional terms apply to the relationship between County, Counsel and National Law
Finn:
A. von Briesen & Roper, s.c., and Crueger Dickinson LLC shall remain sufficiently
aware of the performance of one another and the performance of National Law Firm
to ascertain if each firm's handling of the Lawsuit conforms to the Rules of
Professional Conduct. Both von Briesen & Roper, sx., and Crueger Dickinson LLC
shall be available to, County regarding any concerns on the part of County relating to
the performance of Counsel and/or National Law Firm. Counsel shall at all times
remain ethically and financially responsible to the County for the services of Counsel
and National Law Firm set forth herein.
B. As set forth below, County's responsibility for attorney fees and expenses is
contingent upon the successful outcome of the Lawsuit, as further defined below.
Counsel and National Law Finn have agreed in writing as to the appropriate split of
attorney fees and expenses upon the engagement of National Law Firm. Specifically,
in the event of a Recovery (as defined below), the attorney fees will be split between
the law firms as follows:
Firm Name
PercentalZe of Fees if Successful
von Briesen & Roper, s.c.
10%
Crueger Dickinson LLC
45%
Simmons Hanly Conroy LLC
45%
The split of attorneys' fees between Counsel and National Law Finn may be subject
to change. In the event of such an amendment, the County will be notified in writing
of that amendment.
C. Counsel and County understand and agree that Counsel and National Law Firm will
all be considered attorneys for County. As such, each and all of Counsel and
National Law Firm will adhere to the Rules of Professional Responsibility governing
the relationship between attorney and client,
ACTUAL AND POTENTIAL CONFLICTS OF INTEREST AND WAIVER OF CONFLICT
As County is aware, Counsel and National Law Firm contemplate entering into the same
arrangement as that set forth in this Engagement Letter with other counties and municipalities in
Wisconsin and elsewhere. Counsel and National Law Firm believe that the goals and objectives of
County are aligned with the goals and objectives of all other counties and municipalities with respect
to the Lawsuit. Counsel and National Law Firm do not believe that to achieve the goals of the
Lawsuit, either County or another county or municipality must take a position that is adverse to the
interests of the other. However, to the extent any issue may arise in this matter about which County
disagrees with another county or municipality, and one of you may wish to pursue a course that
benefits one but is detrimental to the interest of the other, we cannot advise County or assist County
or any other county or municipality in pursuing such a course. That is to say, Counsel and National
St. Croix County
Engagement Letter
Page -3
Law Firm cannot advocate for County's individual interests at the expense of the other counties or
municipalities that Counsel and National Law Firm represent in a Lawsuit. Counsel and National
Law Firm do not believe that this poses a problem because County's interests are currently aligned
with the other counties and municipalities that are or may be in the Lawsuit. Counsel and National
Law Firm are confident that their representation of County will not be limited in this matter by
representation of any other county or municipality, but County should consider these consequences
of joint representation in deciding whether to waive this conflict.
In addition to the material limitation discussed above, there are other consequences for County in
agreeing to joint representation. Because each county or municipality would be a client of Counsel
and National Law Firm, Counsel and National Law Firm owe equal duties of loyalty and
communication to each client. As such, Counsel and National Law Firm must share all relevant
information with all counties and municipalities who are clients in relation to the Lawsuit and
Counsel and National Law Firm cannot, at the request of one county or municipality, withhold
relevant information from the other client. That is to say, Counsel and National Law Firm cannot
keep secrets about this matter among the counties and municipalities who are clients of Counsel and
National Law Firm with respect to the Lawsuit. Also, lawyers normally cannot be forced to divulge
information about communications with their clients because it is protected by the attorney -client
privilege. However, because County would be a joint client in the same matter with other counties
and municipalities, it is likely that were there to be a future legal dispute between County and other
counties or municipalities that engage Counsel and National Law Firm about this matter, the
attorney -client privilege would not apply, and each would not be able to invoke the privilege against
the claims of the other.
Further, while County's position is in harmony with other counties and municipalities presently, and
the conflict discussed above is waivable, facts and circumstances may change. For example, County
may change its mind and wish to pursue a course that is adverse to the interests of another county or
municipality and the conflict may become unwaivable. In that case, depending upon the
circumstances, Counsel and National Law Firm may have to withdraw from representing either
County or another county or municipality and County would have to bear the expense, if County
chooses, of hiring new lawyers who would have to get up to speed on the matter.
County is not required to agree to waive this conflict, and County may, after considering the risks
involved in joint representation, decline to sign this Engagement Letter. By signing this Engagement
Letter, County is signifying its consent to waiving the conflict of interest discussed herein.
Other than the facts and circumstances related to the joint representation of numerous counties and
municipalities, Counsel and National Law Firm are unaware of any facts or circumstances that would
prohibit Counsel and/or National Law Firm from providing the services set forth in this Engagement
Letter. However, it is important to note that the law firm of von Briesen & Roper, s.c., is a relatively
large law firm based in Wisconsin and represents many companies and individuals. It is possible that
some present and future clients of von Briesen & Roper, s.c., will have business relationships and
potential or actual disputes with County. von Briesen & Roper, s.c., will not knowingly represent
clients in matters that are actually adverse to the interests of County without County's permission and
informed consent. von Briesen & Roper, sx, respectfully requests that County consent, on a case by
case basis, to von Briesen & Roper, s.c.'s representation of other clients whose interests are, or
maybe adverse to, the interests of County in circumstances where County has selected other counsel
and where von Briesen & Roper, s.c., has requested a written conflict waiver from County after being
advised of the circumstances of the potential or actual conflict and County has provided informed
consent.
St. Croix County
Engagement Letter
Page -4
FEES FOR LEGAL SERVICES AND RESPONSIBILITY FOR EXPENSES
A. Calculation of Contingent Fee
There is no fee for the services provided herein unless a monetary recovery acceptable to County is
obtained by Counsel and National Law Firm in favor of County, whether by suit, settlement, or
otherwise ("Recovery"). County understands and agrees that a Recovery may occur in any number
of different fashions such as final judgment in the Lawsuit, settlement of the Lawsuit, or
appropriation to County following a nationwide settlement or extinguishing of claims in lawsuits and
matters similar to the Lawsuit. Counsel and National Law Firm agree to advance all costs and
expenses of Counsel, National Law Firm and the Lawsuit associated with investigating and
prosecuting the Lawsuit provided, however, that the costs and expenses associated with County
cooperating with Counsel and National Law Firm in conjunction with the Lawsuit and otherwise
performing its responsibilities under this Engagement Letter are the responsibility of County. In
consideration of the legal services to be rendered by Counsel and National Law Firm, the contingent
attorneys' fees for the services set forth in this Engagement Letter shall be a gross fee of 25% of the
Recovery, which sum shall be divided among Counsel and National Law Firm as set forth in the
above chart.
Upon the application of the applicable fee percentage to the gross Recovery, and that dollar amount
set aside as attorneys' fees to Counsel and National Law Firm, the amount remaining shall first be
reduced by the costs and disbursements that have been advanced by Counsel and National Law Firm,
and that amount shall be remitted to Counsel and National Law Firm. By way of example only, if the
gross amount of the Recovery is $1,000,000.00, and costs and disbursements are $100,000.00, then
the fee to Counsel and National Law Firm shall be $250,000, the costs amount of $100,000 shall be
deducted from the balance of $750,000.00, and the net balance owed to County shall be $650,000.
The costs and disbursements which may be deducted from a Recovery include, but are not limited to,
the following, without limitation: court fees, process server fees, transcript fees, expert witness fees
and expenses, courier service fees, appellate printing fees, necessary travel expenses of attorneys to
attend depositions, interview witnesses, attend meetings related to the scope of this Engagement
Letter and the like, and other appropriate matter related out-of-pocket expenses. In the event that any
Recovery results in a monetary payment to County that is less than the amount of the costs incurred
and/or disbursements made by Counsel and National Law Firm, County shall not be required to pay
Counsel and National Law Firm any more than the sum of the full Recovery.
B. Nature of Contingent Fee
No monies shall be paid to Counsel or National Law Firm for any work performed, costs incurred or
disbursements made by Counsel or National Law Firm in the event no Recovery to County has been
obtained. In the event of a loss at trial due to an adverse jury verdict or a dismissal of the Lawsuit by
the court, no monies shall be paid to Counsel or National Law Firm for any work performed, costs
incurred or disbursements made by Counsel or National Law Firm. In such an event, neither party
shall have any farther rights against the other.
C. Disbursement of Recovery Proceeds to County
The proceeds of any Recovery on County's behalf under the terms of this Engagement Letter shall be
disbursed to County as soon as reasonably practicable after receipt by Counsel and National Law
Firm. At the time of disbursement of any proceeds from a Recovery, County will be provided with a
detailed disbursement sheet reflecting the method by which attorney's fees have been calculated and
the expenses of litigation that are due to Counsel and National Law Firm from such proceeds.
Counsel and National Law Firm are authorized to retain out of any moneys that may come into their
St. Croix County
Engagement Letter
Page -5
hands by reason of their representation of County the fees, costs, expenses and disbursements to
which they are entitled as determined in this Engagement Letter.
TERMINATION OF REPRESENTATION
This Engagement Letter shall cover the period from the date first indicated below until the
termination of the legal services rendered hereunder, unless earlier terminated as provided herein.
This Engagement Letter may be terminated by County at any time, and in the event of such
termination, neither party shall have any further rights against the other, except that in the event of a
Recovery by County against the Opioid Manufacturers subsequent to termination, Counsel and
National Law Firm shall have a statutory lien on any such recovery as provided by applicable law
and further maintain rights in the nature of quantum meruit to recover fees, costs and expenses
reasonably allocable to their work prior to temlination. Counsel and National Law Firm may
withdraw as County's attorneys at any time for the following reasons:
A. If Counsel and National Law Firm determine, in their sole discretion, that County's
claim lacks merit or that it is not worthwhile to pursue the Lawsuit further; or
B. For Good Cause. For purposes of this Paragraph, Good Cause may include County's
failure to honor the terms of the Engagement Letter, County's failure to follow
Counsel or National Law Firm's advice on a material matter, or any fact or
circumstance that would, in the view of Counsel or National Law Firm, impair an
effective attorney -client relationship or would render continuing representation
unlawful or unethical. If terminated for Good Cause, County will take all steps
necessary to free Counsel and National Law Firm of any obligation to perform
further, including the execution of any documents (including forms for substitution of
counsel) necessary to complete withdrawal provided, however, that Counsel and
National Law Firm shall have a statutory lien on any Recovery as provided by
applicable law and further maintain rights in the nature of quantum meruit to recover
fees, costs and expenses reasonably allocable to their work prior to termination.
SETTLEMENT
County has the authority to accept or reject any final settlement amount after receiving the advice of
Counsel and National Law Firm. County understands settlements are a "compromise" of its claim(s),
and that Counsel and National Law Firm's fee, as set forth above, applies to settlements also. For
example, if a settlement is reached, and includes future or structured payments, Counsel and National
Law Firm's fee shall include its contingent portion of those future or structured payments.
NO GUARANTEE OF RECOVERY
County understands and acknowledges that dispute resolution through litigation often takes years to
achieve. County understands and acknowledges that there is no guarantee or assurances of any kind
regarding the likelihood of success of the Lawsuit, but that Counsel and National Lam, Firm will use
their skill, diligence, and experience to diligently pursue the Lawsuit.
LIMITED LIABILITY
von Briesen & Roper, s.c., and Crueger Dickinson LLC are limited liability entities under Wisconsin
law. This means that if Counsel fails to perform duties in the representation of County and that
failure causes County damages, the firms comprising Counsel and the sharebolder(s) or principals
directly involved in the representation may be responsible to County for those damages, but the
St. Croix County
Engagement Letter
Page -6
firm's other shareholders or principals will not be personally responsible. Counsel's professional
liability insurance exceeds the minimum amounts required by the Wisconsin Supreme Court for
limited liability entities of similar size.
COMMUNICATION BY E-MAIL
Counsel and National Law Finn primarily communicate with their clients via unencrypted internet e-
mail, and this will be the way in which communications occur with County. While unencrypted e-
mail is convenient and fast, there is risk of interception, not only within internal networks and the
systems used by internet service providers, but elsewhere on the internet and in the systems of our
clients and their internet service providers.
FILE RETENTION AND DESTRUCTION
In accordance with Counsel and National Law Firm's records retention policy, most paper and
electronic records maintained are subject to a 10-year retention period from the last matter activity
date or whatever date deemed appropriate. Extended retention periods may apply to certain types of
matters or pursuant to County's specific directives.
After the expiration of the applicable retention period, Counsel and National Law Firm will destroy
records without further notice to County, unless County otherwise notifies in writing.
MISCELLANEOUS
This Engagement Letter shall be governed by and construed in accordance with the laws of the State
of Wisconsin, without regard to conflicts of law rules. In the event of any dispute arising out of the
terms of this Engagement Letter, venue for any such dispute shall be exclusively designated in the
State of Wisconsin Circuit Court for St. Croix County, Wisconsin, or in the United States District
Court for the Eastern District of Wisconsin.
It is expressly agreed that this Engagement Letter represents the entire agreement of the parties, that
all previous understandings are merged in this Engagement Letter, and that no modification of this
Engagement Letter shall be valid unless written and executed by all parties.
It is expressly agreed that if any term or provision of this Engagement Letter, or the application
thereof to any person or circumstance, shall be held invalid or unenforceable to any extent, the
remainder of this Engagement Letter, or the application of such term or provision to persons or
circumstances other than those to which it is held invalid or unenforceable, shall not be affected
thereby; and every other term and provision of this Engagement Letter shall be valid and shall be
enforced to the fullest extent permitted by law.
The parties acknowledge that they have carefully read and fully understand all of the provisions of
this Engagement Letter, and that they have the capacity to enter into this Engagement Letter. Each
party and the person signing on behalf of each party, represents that the person signing this
Engagement Letter has the authority to execute this document and thereby bind the party hereto on
whose behalf the person is signing. Specifically, County acknowledges that it is bound by this
Engagement Letter, has satisfied all conditions precedent to execution of this Engagement Letter and
will execute all the necessary documents that may be required by its governing statutes and/or code.
CONCLUSION
Counsel and National Law Firm are pleased to have this opportunity to be of service to County. If at
any time during the course of representation you have any questions or comments about our services
St. Croix County
Engagement Letter
Page -7
or any aspect of bow we provide services, please don't hesitate to call one or all of the individuals
listed below.
Very truly yours,
von BRIESEN & ROPER, s.c.
Andrew T. Phillips
SIMONS HANLY CONROY LLC (Acknowledged)
Paul J. Hanly., Jr.
Erin K. Dickinson
ST. CROIX COUNTY agrees to retain the services of Counsel and National Law Firm all upon the
terms and conditions specified above.
BY: . . . . . . Date:
Title:
cc: Corporation Counsel
292430671.DDCX