Third Amended Master Long Form Complaint - Dispute Resolution ...

Richmond Pharmaceuticals, Inc.3510 Mayland Ct.Richmond, VA 23233John Doe DefendantsDefendants.PLAINTIFFS’ THIRD AMENDED MASTER LONG FORM COMPLAINT1. Plaintiffs, by the undersigned counsel, hereby submit this Third Amended MasterLong Form Complaint against the above named Defendants (hereinafter named ―Brand NameDefendants‖ and ―Generic Defendants‖) for equitable relief, monetary restitution, and/orcompensatory and punitive damages. Plaintiffs make the following allegations based upon theirpersonal knowledge, and upon information and belief, as well as upon their attorneys’investigative efforts, regarding the drug product Reglan and its generic equivalent,metoclopramide.2. This Third Amended Master Long Form Complaint is submitted pursuant to CaseManagement Order No. 1 of this Reglan/Metoclopramide Litigation Mass Tort Program, to serveonly the administrative functions of efficiency and economy of presenting certain commonclaims and common questions of fact and law for consideration by this Court in the context ofthis proceeding.This Third Amended Master Long Form Complaint does not necessarilyinclude all claims asserted in all of the actions that have been transferred to this Court, nor is itintended to consolidate for any purposes the separate claims of the Plaintiffs herein. Thosematters are set forth in the individual actions filed by each of the respective Plaintiffs. This ThirdAmended Master Long Form Complaint does not constitute a waiver or dismissal of any actions- 11 -Case ID: 100101997