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

237. The representatives of Decedent Plaintiffs’ estates or other persons as designatedby law bring these claims on behalf of the Decedent Plaintiffs’ lawful heirs and statutorybeneficiaries.238. Defendants’ wrongful conduct has proximately caused Decedent Plaintiffs’ heirsand statutory beneficiaries to suffer the loss of Decedents’ companionship, services, society,marital association, love and consortium.239. Decedent Plaintiffs’ representatives bring these claims on behalf of DecedentPlaintiffs’ lawful heirs and statutory beneficiaries for these damages and for all pecuniary lossessustained by them.240. Decedent Plaintiffs’ representatives further plead all wrongful death damagesallowed by statute in the state or states in which the wrongful death causes of action accrued.COUNT XIV - SURVIVAL ACTION241. Plaintiffs hereby incorporate by reference all preceding paragraphs as if fully setforth herein.242. As a direct and proximate result of their exposure to metoclopramide and thewrongful conduct of DRUG COMPANY DEFENDANTS as outlined above, Decedent Plaintiffssuffered bodily injury and resulting pain and suffering, disability, disfigurement, mental anguish,loss of capacity of the enjoyment of life, shortened life expectancy, expenses of hospitalization,medical and nursing care and treatment, and loss of earnings as well as loss of ability to earnmoney prior to their deaths.243. The representatives/administrators of Decedent Plaintiffs’ estates bring this claimon behalf of Decedent Plaintiffs’ estates and Decedent Plaintiffs’ beneficiaries for damages.- 79 -Case ID: 100101997