Corporation Trust Company, Corporation Trust Center 1209 Orange Street, Wilmington, DE19801 or its principal office: P.O. Box 4500, Princeton, NJ 08543.58. Invamed Inc. is a New Jersey Corporation with a principal place of business inNew 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. Defendant may beserved with process by and through its principal office: 2400 Route 130 North, Dayton, NJ08810.59. King Pharmaceuticals Inc., Individually and d/b/a Alpharma Inc., f/k/a A.L.Pharma Inc. and a/k/a Alpharma-Barre National is a Tennessee Corporation with a principalplace of business in Tennessee. 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 registered agent: William L. Phillips, III, 501 FifthStreet, Bristol, TN 37620.60. Richmond Pharmaceuticals Inc. is a Virginia Corporation with a principal place ofbusiness in Virginia.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:3510 Maryland Court,Richmond, VA 23233-142161. Defendant John Doe Defendants are defendants involved in the research, testing,manufacture, distribution, marketing, promotion, sale, and labeling of Reglan and/or- 30 -Case ID: 100101997
metoclopramide not yet known by Plaintiffs. Pursuant to Pa. R. C. P. 2177, Plaintiffs reserve theright to amend this <strong>Complaint</strong> at a future date so that it shall be brought against the corporatename.62. Defendants Teva Pharmaceuticals USA, Inc., Teva Pharmaceutical Industries,Ltd., PLIVA, Inc., PLIVA d.d., Barr Pharmaceuticals LLC, f/k/a Barr Pharmaceuticals, Inc.,Barr Laboratories, Inc., Duramed Pharmaceuticals, Inc.,Qualitest Pharmaceuticals, Inc.,Generics Bidco I., LLC, Individually and d/b/a Qualitest Pharmaceuticals, VintagePharmaceuticals, LLC, The Harvard Drug Group LLC, Individually and d/b/aMajorPharmaceuticals, Inc., Pharmaceutical Associates, Inc., Beach Products, Inc., United ResearchLaboratories, Inc. d/b/a URL PHARMPRO, LLC, Mutual Pharmaceutical Company, Inc., SilarxPharmaceuticals, Inc., Sandoz, Inc., ANIP Acquisition Company a/k/a ANIP Pharmaceuticalsa/k/a ANI Pharmaceuticals a/k/a A & I Pharmaceuticals, Watson Laboratories, Inc., RugbyPharmaceuticals, Inc., a/k/a Rugby Laboratories, Inc., Rugby Laboratories, Inc., ActavisElizabeth LLC, Individually and as successor-in-interest to Purepac Pharmaceuticals, ActavisGroup hf, APP Pharmaceuticals, LLC, Individually and d/b/a Abraxis Pharmaceuticals,BenVenue Laboratories, Inc., Individually and d/b/a Bedford Laboratories , LLC, BedfordLaboratories, Hospira, Inc., Ipca Pharmaceuticals Inc., McKesson Corporation Individually andd/b/a Northstar Rx., LLC, , Northstar Rx, LLC, Norbrook Inc., USA, Smith & Nephew., assuccessor in-interest to SoloPak Laboratories, VistaPharm, Inc., Roxane Laboratories, Inc.,Boehringer Ingelheim Roxane, Inc., Individually and d/b/a Roxane Laboratories, Inc., ParPharmaceutical Inc., Acura Pharmaceuticals, Inc. f/k/a Halsey Drug Company, PacoPharmaceutical Services, Inc. n/k/a West Pharmaceutical Services, Inc., Schering Corporation,Ranbaxy Pharmaceuticals, Inc. , Ivax Pharmaceuticals, Inc., Goldline Laboratories, Inc.,- 31 -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 and 28: 47. Defendant VistaPharm, Inc. is a
- Page 29: labeling, and design of metoclopram
- 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
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(G)Such other relief as is deemed j