UNITED STATES DISTRICT COURT DISTRICT of NEW JERSEY STEVEN HILL, Derivatively on Behalf of JOHNSON & JOHNSON, Plaintiff, V
Case 3:20-cv-00774-FLW-TJB Document 1 Filed 01/23/20 Page 1 of 121 PageID: 1 UNITED STATES DISTRICT COURT DISTRICT OF NEW JERSEY STEVEN HILL, Derivatively On Behalf Of Case No.:20-774 JOHNSON & JOHNSON, Plaintiff, SHAREHOLDER DERIVATIVE COMPLAINT v. ALEX GORSKY, ANNE M. MULCAHY, CHARLES PRINCE, WILLIAM D. PEREZ, IAN E. L. DAVIS, RONALD A. WILLIAMS, A. EUGENE WASHINGTON, MARK B. MCCLELLAN, D. SCOTT DAVIS, MARY C. BECKERLE, CAROL GOODRICH, MICHAEL E. SNEED, JOAN CASALVIERI, and TARA GLASGOW, Defendants, and, JOHNSON & JOHNSON, Nominal Defendant. Plaintiff Steven Hill (“Plaintiff”), by and through his undersigned counsel, derivatively on behalf of Nominal Defendant Johnson & Johnson (“J&J” or the “Company”), submits this Verified Shareholder Derivative Complaint (the “Complaint”). Plaintiff’s allegations are based upon his personal knowledge as to himself and his own acts, and upon information and belief, developed from the investigation and analysis by Plaintiff’s counsel, including a review of publicly available information, including filings by the Company with the U.S. Securities and Exchange Commission (“SEC”), press releases, news reports, analyst reports, investor conference transcripts, publicly available filings in lawsuits, and matters of public record. NATURE OF THE ACTION Case 3:20-cv-00774-FLW-TJB Document 1 Filed 01/23/20 Page 2 of 121 PageID: 2 1. This is a shareholder derivative action brought in the right, and for the benefit, of the Company against certain of its officers and directors seeking to remedy Defendants’ (as defined below) breach of fiduciary duties from February 22, 2013 to the present (”Relevant Period”). 2.
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