equested, upon George S. Thomas Esquire, LECLAIRRYAN One Riverfront Plaza, 1037Raymond Boulevard, Sixteenth Floor, Newark, NJ 07102.51. Defendant Paco Pharmaceutical Services, Inc., n/k/a West PharmaceuticalServices, Inc. is a Delaware corporation with a principal place of business in New Jersey.Defendant regularly conducts business in Philadelphia County, Pennsylvania. Defendant wasinvolved in the research, testing, manufacture, distribution, marketing, promotion, sale, labeling,and design of metoclopramide detailed below. Defendant may be served with process by andthrough its principal office: 101 Gordon Drive, Lionville, PA 19341.52. Defendant Schering Corporation is a New Jersey corporation with a principalplace of business 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 and through its principal office: 2000 GALLOPING HILL RD.,KENILWORTH, NJ 07033-1310.53. Defendant Ranbaxy Pharmaceuticals, Inc. is a Florida corporation with a principalplace of business 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 and through its principal office: 600 College Rd. E Ste. 2100,Princeton, NJ 08540.54. Defendant IVAX Pharmaceuticals, Inc. is a Florida corporation with a principalplace of business in Florida. Defendant regularly conducts business in Philadelphia Defendantwas involved in the research, testing, manufacture, distribution, marketing, promotion, sale,- 28 -Case ID: 100101997
labeling, and design of metoclopramide detailed below. Defendant may be served with processby and through its principal office: 4400 Biscayne Blvd., Miami, FL 33137.55. Defendant Goldline Laboratories, Inc., Individually and d/b/a IVAXPharmaceuticals, Inc., is a Florida Corporation with a principal place of business in Florida.Defendant regularly conducts business in Philadelphia County, Pennsylvania. Defendant wasinvolved in the research, testing, manufacture, distribution, marketing, sale, labeling, and designof metoclopramide detailed below. Defendant may be served with process by and through itsregistered agent: Corporate Creations Network Inc., 11380 Prosperity Farms Road #221E, PalmBeach Gardens, FL 33410 or through its principal office: 4400 Biscayne Blvd., Attn: LegalAffairs, Miami, FL 33137.56. Bristol Myers Squibb Co., Individually and d/b/a Apothecon, Inc. is a DelawareCorporation with a principal place of business in New York. Defendant regularly conductsbusiness in Philadelphia County, Pennsylvania. Defendant was involved in the research, testing,manufacture, distribution, marketing, promotion, sale, labeling, and design of metoclopramidedetailed below. Defendant may be served with process by and through its registered agentCorporation Trust Company, Corporation Trust Center 1209 Orange Street, Wilmington, DE19801 or through its principal office: 345 Park Ave., New York, NY 10154-000457. Defendant Apothecon Inc. is a domestic corporation, incorporated in the State ofDelaware with a principal place of business in New Jersey. Defendant regularly conductsbusiness in Philadelphia County, Pennsylvania. Defendant was involved in the research, testing,manufacture, distribution, marketing, promotion, sale, labeling, and design of metoclopramidedetailed below. Defendant may be served with process by and through its registered agent- 29 -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 and 14: Jersey 07940. Defendant regularly c
- Page 15 and 16: 12. Defendant Baxter Healthcare Cor
- 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: 47. Defendant VistaPharm, Inc. is a
- 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
- Page 65 and 66: involuntary movements, aggravation
- Page 67 and 68: DEFENDANTS professed to Plaintiffs
- Page 69 and 70: COUNT VIII - UNFAIR AND DECEPTIVE T
- Page 71 and 72: loss: the difference between the pr
- Page 73 and 74: 214. BRAND NAME DEFENDANTS knew, or
- Page 75 and 76: 217. Alternatively or in addition,
- Page 77 and 78: 224. In addition, DRUG COMPANY DEFE
- Page 79 and 80:
237. The representatives of Deceden
- Page 81 and 82:
248. Plaintiffs also allege that th
- Page 83 and 84:
d) They continued to promote the sa
- Page 85:
(G)Such other relief as is deemed j