9. Defendant Schwarz Pharma AG is a foreign corporation with its principal place ofbusiness in Germany. Defendant Schwarz Pharma AG is the parent company of DefendantSchwarz Pharma, Inc. and therefore liable for any and all tort liabilities of Defendant SchwarzPharma, Inc. In addition, Defendant Schwarz Pharma AG was involved in the research, testing,manufacture, distribution, marketing, promotion, sale, labeling, and design of Reglan detailedbelow. Defendant regularly conducts business in Philadelphia County, Pennsylvania. Defendantmay be served with process via The Hague Convention by serving Germany’s Central Authorityat: Die Präsidentin des Oberlandesgerichts Düsseldorf, Cecilienallee 3, 40474 Düsseldorf,Germany.10. Defendant UCB Pharma GmbH is a foreign corporation with its principal place ofbusiness in Germany. Defendant UCB GmbH is the parent company of Defendant SchwarzPharma AG and therefore liable for any and all tort liabilities of Defendant Schwarz Pharma AG.In addition, Defendant Schwarz GmbH was involved in the manufacture, distribution, marketing,sale, and labeling of Reglan detailed below.Defendant regularly conducts business inPhiladelphia County, Pennsylvania. Defendant may be served with process at Alfred-NobelStrasse 10, 40789 Monheim, Germany.11. Defendant Alaven Pharmaceutical LLC is a Delaware corporation with a principalplace of business in Marietta, Georgia. Defendant regularly conducts business in PhiladelphiaCounty, Pennsylvania.Defendant was involved in the research, testing, manufacture,distribution, marketing, promotion, sale, labeling, and design of Reglan detailed below. Pursuantto Case Management Order No. 1, Defendant may be served with process by registered mail,return receipt requested, upon: Henninger S. Bullock, Esquire, MAYER BROWN LLP, 1675Broadway, New York, NY 10019.- 14 -Case ID: 100101997
12. Defendant Baxter Healthcare Corporation is a Delaware corporation with itsprincipal place of business in Deerfield, Illinois. Defendant regularly conducts business inPhiladelphia County, Pennsylvania.Defendant was involved in the research, testing,manufacture, distribution, marketing, promotion, sale, labeling, and design of Reglan detailedbelow.Defendant may be served with process by and through its agent for service: CTCorporation System, 116 Pine St., Suite 320, Harrisburg, PA 17101.13. Defendant Wockhardt USA is a Delaware corporation with a principal place ofbusiness in New Jersey.Defendant regularly conducts business in Philadelphia County,Pennsylvania.Defendant was involved in the research, testing, manufacture, distribution,marketing, promotion, sale, labeling, and design of metoclopramide detailed below. Defendantmay be served with process by registered mail, return receipt requested, upon: Robert E.O'Malley, Esquire, SEGAL, MCCAMBRIDGE, SINGER & MAHONEY, LTD., 233 S. WackerDrive, Sears Tower - Suite 5500, Chicago, IL 60606.14. Defendant Morton Grove Pharmaceuticals, Inc. is a Delaware corporation with aprincipal place of business in Illinois. Defendant regularly conducts business in PhiladelphiaCounty, Pennsylvania.Defendant was involved in the research, testing, manufacture,distribution, marketing, promotion, sale, labeling, and design of metoclopramide detailed below.Pursuant to Case Management Order No. 1, Defendant may be served with process by registeredmail, return receipt requested, upon: Robert E. O'Malley, Esquire, SEGAL, MCCAMBRIDGE,SINGER & MAHONEY, LTD., 233 S. Wacker Drive, Sears Tower - Suite 5500, Chicago, IL60606.15. Defendants Wyeth, LLC, Wyeth Pharmaceuticals, Inc., Wyeth HoldingsCorporation, Individually and d/b/a ESI Lederle, Pfizer, Inc., Schwarz Pharma, Inc., Schwarz- 15 -Case ID: 100101997
- Page 1 and 2: IN RE ::COURT OF COMMON PLEASPHILAD
- Page 4: Sears Tower - Suite 5500Chicago, IL
- Page 7 and 8: 4 Penn Center, Suite 8001600 John F
- Page 9 and 10: Northstar Rx LLC4971 Southridge Blv
- Page 11 and 12: Richmond Pharmaceuticals, Inc.3510
- Page 13: Jersey 07940. Defendant regularly c
- Page 17 and 18: with process via The Hague Conventi
- Page 19 and 20: Pharmaceuticals USA, Inc. on Decemb
- Page 21 and 22: Case Management Order No. 1, Defend
- Page 23 and 24: 34. Defendant Watson Laboratories,
- Page 25 and 26: through its registered agent for se
- Page 27 and 28: 47. Defendant VistaPharm, Inc. is a
- Page 29 and 30: labeling, and design of metoclopram
- Page 31 and 32: metoclopramide not yet known by Pla
- Page 33 and 34: packaging and/or advertising the ph
- Page 35 and 36: 76. In addition, Philadelphia Count
- Page 37 and 38: 87. The ―indications‖ (recommen
- Page 39 and 40: e satisfied that the proposed label
- Page 41 and 42: prescribed by physicians, most of w
- Page 43 and 44: exercise of reasonable care should
- Page 45 and 46: 113. Since 1985, GENERIC DEFENDANTS
- Page 47 and 48: e. independently monitor the sales
- Page 49 and 50: disfigurement, disability, pain and
- Page 51 and 52: care industry and consumers, includ
- Page 53 and 54: associated with the ordinary, expec
- Page 55 and 56: 146. The Reglan and/or generic meto
- Page 57 and 58: 158. Each of the DRUG COMPANY DEFEN
- Page 59 and 60: 22. They failed to implement proper
- Page 61 and 62: 166. As lawful consumers of Reglan
- Page 63 and 64: duration of use - confirming they w
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involuntary movements, aggravation
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DEFENDANTS professed to Plaintiffs
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COUNT VIII - UNFAIR AND DECEPTIVE T
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loss: the difference between the pr
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214. BRAND NAME DEFENDANTS knew, or
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217. Alternatively or in addition,
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224. In addition, DRUG COMPANY DEFE
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237. The representatives of Deceden
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248. Plaintiffs also allege that th
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d) They continued to promote the sa
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(G)Such other relief as is deemed j