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

71. Defendants Wyeth LLC and Wyeth Pharmaceuticals, Inc. are residents ofPennsylvania because their principal places of business are in Pennsylvania.72. This is an action for damages, which exceeds fifty thousand dollars ($50,000).73. Plaintiffs have timely filed this lawsuit within two years of discovering their causeof action as defined and required by Pennsylvania 42 Pa. Cons. Stat. § 5524(2).II.Venue74. Plaintiffs incorporate by reference all of the above paragraphs75. Philadelphia County is the proper forum and venue for these causes of action.Philadelphia County is the epicenter of Reglan/Metoclopramide litigation. The defendants withthe largest roles in this litigation, Teva Pharmaceuticals USA, Inc., and therefore nowDefendants Barr Pharmaceuticals, Inc, Barr Laboratories, Inc., Duramed Pharmaceuticals Inc.,and PLIVA USA, Inc., Wyeth LLC, and Wyeth Pharmaceuticals, Inc., are located just outside ofPhiladelphia. In addition, Defendant Mutual Pharmaceuticals Company, Inc. is located withinPhiladelphia County.The other defendants, defendants’ counsel, corporate witnesses, anddocuments are located in or around Philadelphia County.In fact, Defendants agreed thatPhiladelphia County is a proper forum when they stated that a Philadelphia courtroom would be―not only convenient for all parties, but is a natural center of gravity of the pending litigation‖ 4and ―the most convenient of all forums as the overwhelming majority of defendants have theirprincipal place of business in Pennsylvania.‖ 54 Defendant Teva Pharmaceuticals USA, Inc.’s Memorandum in Response to Plaintiffs’ Motion for Transfer ofActions to the District of Nevada Pursuant to 28 U.S.C. § 1407 for Coordinated or Consolidated PretrialProceedings, 1.5 Wyeth’s Response to Plaintiffs’ Motion for Transfer of Actions to the District of Nevada Pursuant to 28 U.S.C. §1407 for Coordinated or Consolidated Pretrial Proceedings, Sec. IV, B.- 34 -Case ID: 100101997