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

disfigurement, disability, pain and suffering, psychological injury and other injuries anddamages.125. Plaintiffs’ serious and permanent injuries, and aggravation of preexistingconditions, as described above (and to be further described in Short Form Complaints), cameabout as a foreseeable and proximate result of the failure of DRUG COMPANY DEFENDANTSto monitor the safety of their drug products, to provide accurate and complete information to theFDA, to use reasonable means to correct inaccuracies appearing in their labels, and tocommunicate to the medical community, physicians, Plaintiffs’ physician, Plaintiffs and otherforeseeable users of the drug, adequate warnings about risks associated with common andforeseeable uses of their metoclopramide products. Concurrently, Plaintiffs’ injuries came aboutas a foreseeable and proximate result of defendants’inaccurate, misleading, materiallyincomplete, and otherwise false information concerning the potential effects of exposure to thedrug substance metoclopramide and the ingestion of the metoclopramide products manufacturedand sold by the DRUG COMPANY DEFENDANTS.126. As a further proximate result of the foregoing acts and omissions, Plaintiff’srequire and will require health care and services, and have incurred and will continue to incurmedical, rehabilitative, and related expenses along with lost wages and earning capacity.Plaintiffs have suffered and will continue to suffer indirect costs, including diminished quality oflife, and direct medical costs for follow-up care, including hospitalizations, and other medicalcare.- 49 -Case ID: 100101997