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

146. The Reglan and/or generic metoclopramide products dispensed to andadministered to or used by Plaintiffs were defective at the time they were distributed by or leftthe control of the DRUG COMPANY DEFENDANTs that manufactured and/or sold them.147. The Reglan and/or generic metoclopramide products manufactured and/or sold bythe DRUG COMPANY DEFENDANTS were expected to and did reach patients for whom theywere prescribed, including Plaintiffs, without substantial change in their condition.148. The Reglan and/or generic metoclopramide products manufactured and/or sold bythe DRUG COMPANY DEFENDANTS were administered to or used by Plaintiffs withoutsubstantial change in their condition.149. Plaintiffs were patients for whom the products manufactured and/or sold by theDRUG COMPANY DEFENDANTS reasonably expected Reglan or metoclopramide to beprescribed, and would be expected to use or otherwise receive administration of theirmetoclopramide products.150. Each of the DRUG COMPANY DEFENDANTS was entitled to withdraw itsmetoclopramide product from the market at any time, but failed to do so in a timely andresponsible manner.151. The defects in the Reglan and/or other metoclopramide products used by oradministered to Plaintiffs were a direct and proximate cause of the injuries, damages, and deathsustained by Plaintiffs as set forth in their individual Complaints.COUNT III – NEGLIGENCE152. Plaintiffs hereby incorporate by reference all preceding paragraphs as if fully setforth herein.- 55 -Case ID: 100101997