UNITED STATES DISTRICT COURT - ACLU of Rhode Island

UNITED STATES DISTRICT COURTFOR DISTRICT OF RHODE ISLANDPlaintiffs, MARGARET ROGERS; :MARGARET ROGERS AS PARENT :AND NEXT FRIEND OF GWENDOLYN :ROGERS; KATHLEEN CHURCH; :KATHLEEN CHURCH AS PARENT AND :NEXT FRIEND OF KARY CHURCH :AND KEITH CHURCH; COLLEEN :ARNESON; COLLEEN ARNESON AS :PARENT AND NEXT FRIEND OF :TAYLA AND KYLE ARNESON; ANA :DESAUTEL; ANA DESAUTEL AS :PARENT AND NEXT FRIEND OF :CASSANDRA DESAUTEL; JOANNE :BONOLLO; JOANNE BONOLLO :AS PARENT AND NEXT FRIEND OF :DESTINY BONOLLO AND ALLISON :BONOLLO; AMY BREAULT ZOLT; :AMY BREAULT ZOLT AS PARENT AND:NEXT FRIEND OF ERIK BREAULT, :MAXBREAULT, AND TYLER BREAULT:LINDA GHAZAL; and LINDA GHAZAL :AS PARENT AND NEXT FRIEND OF :TABATHA GHAZAL AND ADAM :GHAZAL ::VS. : C.A. NO.:Defendants, WILLIAM D. MULHOLLAND:in his capacity as Superintendent of the :Parks and Recreation Division for the :City of Pawtucket; JAMES E. DOYLE, in :his capacity as Mayor of The City of :Pawtucket; and JACK CARNEY, in his :Capacity as Director of Public Works :VERIFIED COMPLAINT

I. JURISDICTION1. This is a civil action brought under 42 USC §§1983 and 1988 by Plaintiffs tosecure injunctive and declaratory relief against preferential allocation of permits for use ofpublicly owned athletic fields to private, religious schools and against the granting of permitsfor the use of publicly owned athletic fields in the absolute discretion of an administrativeofficial, in violation of the First, Fifth, and Fourteenth Amendments of the United StatesConstitution and Article I, Sections 2 and 3 of the Rhode Island Constitution.2. This court has jurisdiction of the matter in controversy pursuant to 28 USC§1331, 1343, 1367, 2201, and 2202.II.PARTIESA. PLAINTIFFS3. Plaintiff Margaret Rogers is now and at all times pertinent hereto has been aresident and taxpayer of the City of Pawtucket, State of Rhode Island, and the United States ofAmerica. Plaintiff regularly pays taxes which finance, among other things, the operation of cityfacilities, including athletic fields owned by the City of Pawtucket. Plaintiff Margaret Rogers isalso the parent of Gwendolyn Rogers, who is a student at Tolman High School, a public highschool in the City of Pawtucket, and who plays interscholastic sports at Tolman High School.Plaintiff brings this matter on her own behalf and as parent and next friend of her daughterGwendolyn Rogers.4. Plaintiff Kathleen Church is now and at all times pertinent hereto has been aresident and taxpayer of the City of Pawtucket, State of Rhode Island, and the United States ofAmerica. Plaintiff regularly pays taxes which finance, among other things, the operation of cityfacilities, including athletic fields owned by the City of Pawtucket. Plaintiff Kathleen Churchis also the parent of Kary Church, who is a student at Tolman High School, a public high schoolin the City of Pawtucket, and who plays interscholastic sports at Tolman High School; and ofKeith Church, who attends Jenks Junior High School, a public junior high school in the City of2

Pawtucket. Plaintiff brings this matter on her own behalf and as parent and next friend of herchildren Kary and Keith Church.5. Plaintiff Colleen Arneson is now and at all times pertinent hereto has been aresident and taxpayer of the City of Pawtucket, State of Rhode Island, and the United States ofAmerica. Plaintiff regularly pays taxes which finance, among other things, the operation of cityfacilities, including athletic fields owned by the City of Pawtucket. Plaintiff Colleen Arneson isalso the parent of Tayla Arneson, who is a student at Tolman High School, a public high schoolin the City of Pawtucket; and Kyle Arneson who attends Jenks Junior High School, a publicjunior high school in the City of Pawtucket, and who has tried out for interscholastic sports atJenks Junior High School. Plaintiff brings this matter on her own behalf and as parent and nextfriend of her children Tayla and Kyle Arneson.6. Plaintiff Ana Desautel is now and at all times pertinent hereto has been aresident and taxpayer of the City of Pawtucket, State of Rhode Island, and the United States ofAmerica. Plaintiff regularly pays taxes which finance, among other things, the operation of cityfacilities, including athletic fields owned by the City of Pawtucket. Plaintiff Ana Desautel isalso the parent of Cassandra Desautel, who is a student at Jacqueline Walsh School, a publichigh school in the City of Pawtucket, and who plays interscholastic sports at Tolman HighSchool. Plaintiff brings this matter on her own behalf and as parent and next friend of herdaughter Cassandra Desautel.7. Plaintiff Linda Ghazal is now and at all times pertinent hereto has been aresident and taxpayer of the City of Pawtucket, State of Rhode Island, and the United States ofAmerica. Plaintiff regularly pays taxes which finance, among other things, the operation of cityfacilities, including athletic fields owned by the City of Pawtucket. Plaintiff Linda Ghazal isalso the parent of Tabatha Ghazal, who is a student at Tolman High School, a public highschool in the City of Pawtucket, and who plays interscholastic sports at Tolman High School;and of Adam Ghazal, who attends Goff Junior High School, a public junior high school in theCity of Pawtucket, and who plays interscholastic sports at Goff Junior High School. Plaintiff3

ings this matter on her own behalf and as parent and next friend of her children Tabatha andAdam Ghazal.8. Plaintiff Amy Breault Zolt is now and at all times pertinent hereto has been aresident and taxpayer of the City of Pawtucket, State of Rhode Island, and the United States ofAmerica. Plaintiff regularly pays taxes which finance, among other things, the operation of cityfacilities, including athletic fields owned by the City of Pawtucket. Plaintiff Amy Breault Zoltis also the parent of Erik Breault and Max Breault, who are students at Tolman High School, apublic high school in the City of Pawtucket; and of Tyler Breault, who attends Jenks JuniorHigh School, a public junior high school in the City of Pawtucket, and who playsinterscholastic sports at Jenks Junior High School. Plaintiff brings this matter on her ownbehalf and as parent and next friend of her children Erik, Max, and Tyler Breault.9. Plaintiff Joanne Bonollo is now and at all times pertinent hereto has been aresident and taxpayer of the City of Pawtucket, State of Rhode Island, and the United States ofAmerica. Plaintiff regularly pays taxes which finance, among other things, the operation of cityfacilities, including athletic fields owned by the City of Pawtucket. Plaintiff Joanne Bonollo isalso the parent of Destiny Bonollo, who is a student at Jacqueline Walsh School, a public highschool in the City of Pawtucket and of Allison Bonollo, who is a student at Tolman HighSchool, a public high school in the city of Pawtucket. Plaintiff brings this matter on her ownbehalf and as parent and next friend of her children Destiny and Allison Bonollo.B. DEFENDANTS10. Defendant William D. Mulholland is now and at all times pertinent hereto hasbeen employed by the City of Pawtucket as the Superintendent of the Division of Parks andRecreation. In his capacity as Superintendent of the Division of Parks and Recreation,Defendant William D. Mulholland has the authority and does in fact issue permits for the use ofathletic fields owned by the City of Pawtucket. Defendant William D. Mulholland is suedherein in his official capacity.4

11. Defendant James E. Doyle is now and at all times pertinent hereto has been theelected Mayor of the City of Pawtucket and as such has control and authority over the Divisionof Parks and Recreation and over the Department of Public Works for the City of Pawtucket.He is sued herein in his official capacity.12. Defendant Jack Carney is now and at all times pertinent hereto has beenemployed by the City of Pawtucket as the Director of Public Works. In his capacity as Directorof Public Works, Defendant Jack Carney has the authority and does in fact exercise authorityover the Parks Division and the Office of Parks and Recreation of the City of Pawtucket.Defendant Jack Carney is sued herein in his official capacity.state law.13. Defendants herein have, at all times pertinent hereto, been acting under color ofIII.STATEMENT OF FACTS14. The City of Pawtucket, Rhode Island, through its Department of Public Works,Office of Parks and Recreation, owns, operates, maintains, and issues permits for use of Cityathletic fields, including but not limited to McKinnon/Alves Soccer Complex, Doreen AnnTomlinson Field, O’Brien Field, Fairlawn Veteran’s Memorial Park, and Pariseau Field. Theaforementioned athletic fields are maintained using taxes collected by the City of Pawtucketand paid by residents of the City of Pawtucket, including Plaintiffs. Furthermore, byinformation and belief, the construction of the McKinnon/Alves Soccer Complex and therehabilitation of the O’Brien Field were both accomplished by the use of federal funds.15. The Pawtucket School Department operates three (3) public high schools in theCity of Pawtucket, namely, Tolman High School, Shea High School, and Jacqueline WalshSchool, as well as three (3) public junior high schools, namely, Goff Junior High School, JenksJunior High School, and Slater Junior High School. The public high schools and junior highschools in the City of Pawtucket are funded by a combination of funds raised by municipal,state, and federal taxes. At all times pertinent hereto, Plaintiffs have paid and continue to paytaxes to the City of Pawtucket, the State of Rhode Island, and the United States.5

16. Both the public high schools and the public junior high schools in the City ofPawtucket are operated by and under the control of the Pawtucket School Department andSchool Committee and include in their curriculum interscholastic athletic programs.17. By information and belief, over three hundred (300) public school studentsparticipate in the interscholastic athletic programs offered by the public junior high schools inthe City of Pawtucket, and over six hundred (600) public school students participate in theinterscholastic athletic programs offered by the public high schools in the City of Pawtucket.18. Certain public high school and public junior high school interscholastic athleticprograms require the use of athletic field space, for which the Pawtucket School Departmentmust obtain permission from the City of Pawtucket, and specifically from the Office of Parksand Recreation of the City of Pawtucket, by and through its Superintendent, Defendant WilliamD. Mulholland.19. The City of Pawtucket, and the Department of Public Works, Division of Parks,Office of Parks and Recreation, has no written policies governing the issuance of permits forcity owned athletic fields. The issuance of permits is wholly within the discretion of theSuperintendent of the Office of Parks and Recreation of the City of Pawtucket, namely,Defendant William D. Mulholland. The long-standing lack of written policies has enabled andcontinues to enable Defendants to provide preferential field allocation to religious schools.20. During the summer of 2009, Defendant William D. Mulholland, acting in hiscapacity as Superintendent of the City of Pawtucket’s Office of Parks and Recreation, requestedthe athletic directors of Pawtucket’s junior and senior high schools to submit a request forpermits for the use of the city’s athletic fields for public school sponsored interscholastic sportsteams. The athletic directors’ requests included the use of the O’Brien Field from Mondaythrough Friday, 2:30 p.m. to 5:00 p.m. in the fall of 2009 for the Jenks Junior High Schoolboys’ and girls’ soccer teams. Their request also included the use of all three fields at theMcKinnon/Alves Soccer Complex.6

21. By information and belief, in August 2009, Defendant William D. Mulhollanddenied public school athletic teams at the junior high school levels their requests for permits forthe use of O’Brien Field and for the use of one of the three fields at the McKinnon/AlvesSoccer Complex, all of which are athletic fields owned, operated, and maintained by the City ofPawtucket by and through its Department of Public Works, Office of Parks and Recreation.Saint Raphael’s Academy, a private sectarian high school operated by the Roman CatholicDiocese of Providence, was, however, granted a permit for the exclusive use of O’Brien Fieldfrom Monday through Friday, from 2:00 p.m. until dusk, for its school sponsored athleticprograms and was also granted a permit for the exclusive use of one of the fields at theMcKinnon/Alves Soccer Complex. By information and belief, the permits allowing SaintRaphael’s Academy the exclusive use of the aforementioned fields on week-days was issued byDefendant William D. Mulholland in his capacity as Superintendent of the Office of Parks andRecreation for the City of Pawtucket.22. By information and belief, the City of Pawtucket received approximately TwoHundred Thousand ($200,000.00) Dollars in federal money in approximately 2000 in order torefurbish the O’Brien Field.23. By information and belief, Pawtucket redeveloped the site of the formerNewman-Crosby Steel Plant into the McKinnon/Alves Soccer Complex with taxpayer funds,including $450,000.00 in state open space and recreational bond funds, $1.2 million dollarsfrom the City of Pawtucket, $400,000.00 in federal funds through the National Park Service,and $200,000.00 in federal brownfields cleanup funds through the Environmental ProtectionAgency.24. By information and belief, for most of the period before and since the O’BrienField has been refurbished through the use of public monies, Saint Raphael Academy hasenjoyed the exclusive use of said field, particularly on week-day afternoons in the fall season,despite repeated requests by various public school officials for use of O’Brien Field for publicschool sponsored interscholastic sports, submitted to the City of Pawtucket’s Office of Parksand Recreation, by and through Defendant William D. Mulholland.7

25. By information and belief, public school officials acting on behalf of JenksJunior High School, a public junior high school located in the City of Pawtucket, haverequested use of the O’Brien Field, which is located in close proximity to Jenks Junior HighSchool, for junior high school soccer team practice and games for at least the last five (5)academic years, including the current academic year. In each and every instance, the City ofPawtucket’s Office of Parks and Recreation, acting by and through its Superintendent,Defendant William D. Mulholland, denied the use of O’Brien Field to the Jenks Junior HighSchool soccer team in favor of allowing Saint Raphael Academy exclusive use of said fieldeach and every afternoon during the fall season. Ultimately, in 2008, after legal action wasthreatened with regard to the preferential treatment of St. Raphael Academy to the detriment ofthe interscholastic teams of the City of Pawtucket’s public high schools and junior highschools, Defendants ultimately withdrew an exclusive permit issued to St. Raphael Academyfor use of O’Brien Field every weekday afternoon in the fall in order to accommodate the needsof the interscholastic teams of the public schools in the City of Pawtucket; however, during thecurrent academic year Defendant William D. Mulholland again denied requests by publicschools athletic directors for use of O’Brien Field, and instead issued a permit for exclusive useof that field on weekday afternoons in the fall to St. Raphael Academy.26. By information and belief, during the current academic year, the PawtucketSchool Department’s public junior high school teams have also been denied the use ofPawtucket- owned Doreen Ann Tomlinson Field for their athletic games.27. By information and belief, during the current academic year, the PawtucketSchool Department’s public junior high school teams were denied the use of Pawtucket ownedO’Brien Field and one of the three fields located at the McKinnon/Alves Soccer Complex, bothof which have been and continue to be reserved exclusively for the use of St. RaphaelAcademy’s and/or Bishop Keough’s athletic teams. Bishop Keough is, like St. RaphaelAcademy, a private sectarian school.28. As a proximate result of Defendants’ refusal to allow the use of theaforementioned fields, the public junior high school and the public high school athletic8

programs cannot be fully accommodated because they have been assigned insufficient fieldspace for practice and for games. For example, as recently as last week, the Tolman HighSchool soccer team was unable to practice as planned because no public field was available tothem. During the time that the team’s practice would normally take place, St. Raphael’sAcademy had been granted exclusive use of O’Brien Field.29. Plaintiffs, Margaret Rogers, Kathleen Church, Colleen Arneson, Ana Desautel,Joanne Bonollo, Amy Breault Zolt, and Linda Ghazal, object to the arbitrary decisions byDefendant William D. Mulholland, in his capacity as Superintendent of the Division of Parksand Recreation of the City of Pawtucket, to reject the applications filed on behalf of variouspublic schools to use O’Brien Field, all three fields at the McKinnon/Alves Soccer Complex,and the Doreen Ann Tomlinson Field for interscholastic sports in favor of granting theexclusive use of said fields at certain times and on week-day afternoons to private, sectarianschools. Plaintiffs are the parents of children who are public school students and who havesuffered and/or are likely to suffer harm as a result of Defendants’ actions and policies relatingto the granting of permits for the use of athletic fields owned and operated by the City ofPawtucket and required for interscholastic athletics operated by the public schools in the City ofPawtucket.30. Municipal tax funds are currently used to operate and maintain the athletic fieldsowned by the City of Pawtucket, including but not limited to the O’Brien Field, theMcKinnon/Alves Soccer Complex, and the Doreen Ann Tomlinson Field.31. Plaintiffs, Margaret Rogers, Kathleen Church, Colleen Arneson, Ana Desautel,Joanne Bonollo, Amy Breault Zolt, and Linda Ghazal, are opposed to the expenditure of theirtax funds in a manner that allows preferential and exclusive allocation of publicly financed andmaintained athletic fields for sectarian schools over public schools.32. Plaintiffs have no adequate remedy at law and have suffered and will continue tosuffer irreparable harm by the arbitrary policies of Defendants to allow and/or authorizepreferential use and permitting of the City of Pawtucket’s athletic fields to private, sectarianschool students.9

IV.FIRST CAUSE OF ACTION33. Plaintiffs, Margaret Rogers, Kathleen Church, Colleen Arneson, Ana Desautel,Joanne Bonollo, Amy Breault Zolt, and Linda Ghazal, hereby incorporate paragraphs one (1)through thirty two (32) above as if fully set forth herein, and for their first cause of action allegethat the actions of Defendants described therein violate the Establishment Clause of the FirstAmendment of the United States Constitution, applicable to the City of Pawtucket through theFourteenth Amendment of the United States Constitution.V. SECOND CAUSE OF ACTION34. Plaintiffs, Margaret Rogers, Kathleen Church, Colleen Arneson, Ana Desautel,Joanne Bonollo, Amy Breault Zolt, and Linda Ghazal, hereby incorporate paragraphs one (1)through thirty three (33) above as if fully set forth herein, and for their second cause of actionallege that the actions of Defendants described therein violate Article I, Section 3 of the RhodeIsland Constitution.IVTHIRD CAUSE OF ACTION35. Plaintiffs, Margaret Rogers, Kathleen Church, Colleen Arneson, Ana Desautel,Joanne Bonollo, Amy Breault Zolt, and Linda Ghazal, hereby incorporate paragraphs one (1)through thirty-four (34) above as if fully set forth herein, and for their third cause of actionallege that the vesting of absolute authority in Defendant William D. Mulholland to issuepermits for use of city-owned athletic fields without objective, non-discriminatory standards orpolicies violates the due process and equal protection clauses of the Fifth and FourteenthAmendments of the United States Constitution.V. FOURTH CAUSE OF ACTION36. Plaintiffs, Margaret Rogers, Kathleen Church, Colleen Arneson, Ana Desautel,Joanne Bonollo, Amy Breault Zolt, and Linda Ghazal, hereby incorporate paragraphs one (1)through thirty-five (35) above as if fully set forth herein, and for their fourth cause of action10

El-Zaher and Mahrouse Chemistry Central Journal 2013, 7:90 Page 11 of 12http://journal.chemistrycentral.com/content/7/1/90is no significant difference between the proposedmethod and the reported one with respect to accuracyand precision.ConclusionA systematic and practical approach was employed todevelop an efficient and selective spectrofluorimetricmethod to quantify NF in pure and capsule forms. Experimentaldesign was successfully applied to effectivelyevaluate the main effects of factors that significantly affectedthe fluorescence intensity and to determine theirinteractions and quadratic effects with the least numberof runs. The application of response surface methodologywith face centered composite design to modelingand optimizing the performance of the suggestedmethod proved to be an economic approach forextracting large amount of information while saving timeand cost. After optimization, all the performed responsesurface, contour plots, plots of residuals, lack of fit testand ANOVA results support each other and confirm theadequacy of the model. The method was validated andthe obtained results indicate good linearity and reproducibility.The method was further compared with areported UV method and proved to be more sensitiveand selective. The proposed method is accurate, specific,and sensitive so can be applied for the routine analysisof NF in pure form and in pharmaceutical dosage form,either alone or in presence of DV.AbbreviationsNF: Nifuroxazide; DV: Drotaverine; OVAT: One variable at a time;DOE: Experimental design; FCC design: Face centered composite design;EAA: Ethylacetoacetate; ANOVA: Analysis of variance; ICH: The InternationalConference on Harmonization; SD: Standard deviation; RSD: Relative standarddeviation; LOD: Limit of detection; LOQ: Limit of quantification.Competing interestsThe authors declare that they have no conflict of interests.Authors’ contributionsAAZ collected the literature review, proposed and explained theexperimental design work, revised the manuscript critically, participated inthe results, assay validation and discussion. MAM proposed the analyticalmethod, helped in understanding DOE, performed the experimental designwork using Minitab software, analyzed the data statistically and prepared thedraft version of the manuscript. Both authors conducted the optimization ofthe assay conditions, carried out the analytical experimental work, read andapproved the final manuscript.Received: 19 January 2013 Accepted: 8 May 2013Published: 23 May 2013References1. O’Neil MJ, Heckelman PE, Koch CB, Roman KJ, Kenny CM, D'Arecca MR: TheMerck Index, An Encyclopedia of Chemicals, Drugs and Biologicals. 14thedition. Whitehouse Station, NJ, USA: Merck Research laboratories Divisionof Merck & Co., Inc; 2006:1130.2. Sweetman SC: Martindale, The Complete Drug Reference. 35th edition. London,Chicago: The Pharmaceutical Press; 2007. 274.3. The British Pharmacopoeia. London, UK: Her Majesty's Stationary Office;2010:1508.4. Khier AA, Elhenawee MM, Elmasry MS: Spectrophotometric method forthe determination of some drugs using fast red B salt. E-J Chem 2008,5(S2):1087–1097.5. Emara KM, Refaat IH, Abdelmageed OH: HPLC and spectrophotometricdetermination of nifuroxazide and its pharmaceutical formulations.Egyptian J Pharm Sci 1994, 35(1–6):313–324.6. Szuminska E, Cisak A: Polarographic and spectrophotometric determinationof nifuroxazide in pharmaceuticals. I. Nifuroxazide determination incapsules. Acta Pol Pharm 1988, 45(6):551–558.7. Szuminska E, Cisak A: Polarographic and spectrophotometric determinationof nifuroxazide in pharmaceuticals. II. Determination of nifuroxazide insuspensions. Acta Pol Pharm 1990, 47(1–2):1–2.8. Toral MI, Paine M, Leyton P, Richter P: Determination of attapulgite andnifuroxazide in pharmaceutical formulations by sequential digital derivativespectrophotometry. JAOACInt2004, 87(6):1323–1328.9. Sobanska AW: Rapid determination of nifuroxazide in tablets by near-infraredspectroscopy. Chemia Analityczna (Warsaw, Poland) 2009, 54(5):1021–1033.10. Berezkin VG, Onuchak LA, Evtyugina EN: Capillary thin-layer chromatographyof antibacterial nitrofuran derivatives. Russ J Appl Chem 2009, 82(2):312–316.11. Guinebault PR, Broquaire M, Braithwaite RA: Determination of nifuroxazidein biological fluids by automated high-performance liquid chromatographywith large-volume injection. J Chromatogr 1981, 204:329–333.12. Squella JA, Lemus I, Lonza G, Nunez-Vergara LJ: Electrochemical study ofnifuroxazide and its analytical determination in tablets. Boletin de laSociedad Chilena de Quimica 1991, 36(2):109–116.13. Radi A, El-Laban S, Kenawy IMM: Determination of nifuroxazide incapsules by differential pulse polarography. Anal Sci 1998, 14(3):607–608.14. Buchberger W, Niessner G, Bakry R: Determination of nifuroxazide withpolarography and adsorptive stripping voltammetry at mercury andcarbon paste electrodes. Fresenius J Anal Chem 1998, 362(2):205–208.15. Sreedhar NY, Samatha KR, Reddy PRK: Electrochemical reduction behaviorand analysis of nifuroxazide in formulations and urine samples. IndianDrugs 1999, 36(8):509–512.16. Radi A, El Ries MA: Determination of nifuroxazide in human serum byadsorptive stripping voltammetry. Anal Sci 1999, 15(4):385–388.17. Radi A: Voltammetric study of nifuroxazide at unmodified and Sephadexmodifiedcarbon paste electrodes. Fresenius J Anal Chem 1999, 364(6):590–594.18. Belal TS: A simple and sensitive spectrofluorimetric method for analysisof some nitrofuran drugs in pharmaceutical preparations. J Fluoresc 2008,18(5):771–780.19. Metwally FH, Abdelkawy M, Naguib IA: Determination of nifuroxazide anddrotaverine hydrochloride in pharmaceutical preparations by threeindependent analytical methods. J AOAC Int 2006, 89(1):78–87.20. Ayad MM, Youssef NF, Abdellatif HE, Soliman SM: A comparative study onvarious spectrometries with thin layer chromatography for simultaneousanalysis of drotaverine and nifuroxazide in capsules. Chem Pharm Bull2006, 54(6):807–813.21. Metwally FH: Simultaneous determination of Nifuroxazide and Drotaverinehydrochloride in pharmaceutical preparations by bivariate and multivariatespectral analysis. Spectrochim Acta A Mol Biomol Spectrosc 2008, 69A(2):343–349.22. Azhlwar S, Ravi TK: Stability indicating HPLC method for simultaneousdetermination of drotaverine and aceclofenac. Int J Pharm Pharm Sci 2011,3(1):245–250.23. Leardi R: Experimental design in chemistry: A tutorial. Anal Chim Acta 2009,652:161–172.24. Miller JN, Miller JC: Statistics and Chemometrics for Analytical Chemistry. 6thedition. England: Pearson education Limited; 2010:186–216.25. Khamanga SM, Walker RB: The use of experimental design in thedevelopment of an HPLC-ECD method for the analysis of captopril. Talanta2011, 83:1037–1049.26. Boussac N, Galmier MJ, Dauphin G, Madesclaire M, Lartigue C: Nifuroxazidephotodecomposition: Identification of the (Z)-isomer by 1H-NMR Study.Mikrochim Acta 2003, 141(3–4):179–181.27. Deming SN, Morgan SL: Experimental Design: A Chemometric Approach.2nd edition. Amsterdam, London, New York, Tokyo: Elsevier Publishers;1993:227–274. 151–169.28. Montgomery DC: Design and Analysis of Experiments. 7th edition. Asia: JohnWiley & Sons, Inc; 2009:207–263. 1–22, 60–114.29. Q2 (R1) Validation of analytical procedures, Proceedings of the InternationalConference on Harmonisation (ICH). Geneva: Commission of the EuropeanCommunities; 2005.

VERIFICATION OF COMPLAINTI, Margaret Rogers, upon oath, depose and state that I have read the within VerifiedComplaint and believe that the allegations contained therein to be true and correct to the best ofmy belief.STATE OF RHODE ISLAND______________________, SC.Margaret RogersSubscribed and sworn to before me in ____________________________ on the_______ day of ____________________, 2009.Notary PublicMy Commission Expires:________________I, Kathleen Church, upon oath, depose and state that I have read the within Verified Complaintand believe that the allegations contained therein to be true and correct to the best of my belief.STATE OF RHODE ISLAND______________________, SC.Kathleen ChurchSubscribed and sworn to before me in ____________________________ on the_______ day of ____________________, 2009.Notary PublicMy Commission Expires:________________12

I, Colleen Arneson, upon oath, depose and state that I have read the within Verified Complaintand believe that the allegations contained therein to be true and correct to the best of my belief.STATE OF RHODE ISLAND______________________, SC.Colleen ArnesonSubscribed and sworn to before me in ____________________________ on the_______ day of ____________________, 2009.Notary PublicMy Commission Expires:________________I, Ana Desautel, upon oath, depose and state that I have read the within Verified Complaint andbelieve that the allegations contained therein to be true and correct to the best of my belief.STATE OF RHODE ISLAND______________________, SC.Ana DesautelSubscribed and sworn to before me in ____________________________ on the_______ day of ____________________, 2009.Notary PublicMy Commission Expires:________________13

I, Joanne Bonollo, upon oath, depose and state that I have read the within Verified Complaintand believe that the allegations contained therein to be true and correct to the best of my belief.STATE OF RHODE ISLAND______________________, SC.Joanne BonolloSubscribed and sworn to before me in ____________________________ on the_______ day of ____________________, 2009.Notary PublicMy Commission Expires:________________I, Amy Breault Zolt, upon oath, depose and state that I have read the within Verified Complaintand believe that the allegations contained therein to be true and correct to the best of my belief.STATE OF RHODE ISLAND______________________, SC.Amy Breault ZoltSubscribed and sworn to before me in ____________________________ on the_______ day of ____________________, 2009.Notary PublicMy Commission Expires:________________14

I, Linda Ghazal, upon oath, depose and state that I have read the within Verified Complaint andbelieve that the allegations contained therein to be true and correct to the best of my belief.STATE OF RHODE ISLAND______________________, SC.Linda GhazalSubscribed and sworn to before me in ____________________________ on the_______ day of ____________________, 2009.Notary PublicMy Commission Expires:________________Plaintiffs,By and through their Attorney,Sandra A. Lanni, Esquire, #2147Cooperating Attorney for RI Affiliate, ACLU100 Jefferson Boulevard, Ste. 225Warwick, RI 02888(401) 737-4300 Telephone(401) 737-6201 TelefaxSANDRA A. LANNI WILL BE TRIAL COUNSEL IN THIS MATTER.15