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

224. In addition, DRUG COMPANY DEFENDANTS acted with a common purposeto intentionally and/or fraudulently withhold information from the medical community andphysicians regarding the safety of Reglan and generic metoclopramide for the purpose of earningprofits at the expense of Plaintiffs’ health.225. The DRUG COMPANY DEFENDANTS overtly acted, in pursuance of monetarybenefit, by failing to disclose such information safety information regarding Reglan and genericmetoclopramide and hiding it from the medical community,Plaintiffs’ physicians, andPlaintiffs.226. As a consequence of this wrongful conduct, as engaged in and/or passivelyassented to by two or more of the DRUG COMPANY DEFENDANTS, actual legal damage hasoccurred to Plaintiffs and the public.COUNT XII - LOSS OF CONSORTIUM227. Plaintiffs hereby incorporate by reference all preceding paragraphs as if fully setforth herein.228. At all times relevant hereto, the Plaintiffs’ spouses (hereinafter referred to as―Spouse Plaintiffs‖) and/or family members (hereinafter referred to as ―Family MemberPlaintiffs‖) suffered injuries and losses as a result of Plaintiffs’ injuries.229. Spouse Plaintiffs and/or Family Member Plaintiffs have necessarily paid and havebecome liable to pay for medical aid, treatment and for medications, and will necessarily incurfurther expenses of a similar nature in the future as a proximate result of the wrongful conduct ofthe DRUG COMPANY DEFENDANTS.- 77 -Case ID: 100101997