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

duration of use – confirming they were fully aware of the problem and injuries of long term use,and consciously chose to do nothing to correct the prescribing habits of physicians.174. Defendants misrepresentations, by knowingly false statement and omission,specifically include but are not limited to, the misrepresentations as set forth in the generalallegations section of this Complaint and the following:24. They intentionally concealed or withheld fromdisclosure that the pre-clinical and clinical testing andpost-marketing surveillance were inadequate todetermine the safety and side effects of Reglancompared to the use of alternative drugs in the sameclass or to the use of no drug;25. They intentionally concealed and/or withheld fromdisclosure data showing that Reglan and/or genericmetoclopramide use, particularly in long term therapy,dramatically increase the risk for involuntarymovements and other injuries and death, eithercompared to the use of alternative drugs in the sameclass or to the use of no drug;26. They intentionally concealed and/or withheld from theinformation they disseminated about Reglan data aboutthe potential and actual risks, and nature, scope,severity, and duration of any serious side effects of thisdrug, including without limitation, the risk ofinvoluntary movements, other injuries and death, eithercompared to the use of alternative drugs in the sameclass or compared to the use of no drug;27. They concealed and/or withheld, from the informationthey disseminated about Reglan, past and present factsof which they were aware, as specifically with Wyeth,as early as the 1980s, and as late as 2004 for SchwarzPharma, including the degree of actual likelyassociation between the use of metoclopramide anddangerous side effects, including involuntarymovements;175. The above-described acts and/or omissions of defendants were performedwillfully, intentionally, and with reckless disregard for the safety of the consuming public,including the Plaintiffs.- 63 -Case ID: 100101997