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

care industry and consumers, including Plaintiffs, or to their physicians, adequate warnings aboutthose risks and dangers.132. The DRUG COMPANY DEFENDANTS distributed, marketed, promoted, and/orsold an unreasonably dangerous and defective product, namely the prescription drug known asReglan and/or generic metoclopramide, without adequate warnings and other clinically relevantinformation and data to consumers, including Plaintiffs, or to their physicians or other health careproviders empowered to prescribe and dispense Reglan and/or metoclopramide. Through bothomission and affirmative misstatements, defendants severally and collectively misled and/orfailed to communicate to the medical community about the risk and benefit balance of Reglanand/or metoclopramide.133. Despite the fact that the DRUG COMPANY DEFENDANTS knew or shouldhave known that Reglan and/or metoclopramide caused unreasonable and dangerous side effects,they continued to manufacturer, sell, and distribute their metoclopramide products withouteffectively communicating to consumers, or to their physicians or other health care providers,adequate clinically relevant information and data or that there existed safer and more or equallyeffective alternative drug products.134. The DRUG COMPANY DEFENDANTS knew or should have known that a classof consumers, which include the Plaintiffs specifically, would foreseeably and needlessly sufferinjury as a result of their several and collective failure to provide adequate warnings, and/orprovide any information regarding their drug product at all.135. The DRUG COMPANY DEFENDANTS failed to communicate timely andadequate warnings to consumers, including Plaintiffs, or to their physicians, in the followingways:- 51 -Case ID: 100101997