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Suffolk County Clerk 09/13/2019 03:56 Pm Index No FILED: SUFFOLK COUNTY CLERK 09/13/2019 03:56 PM INDEX NO. 400000/2017 NYSCEF DOC. NO. 1582 RECEIVED NYSCEF: 09/13/2019 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF SUFFOLK Index No.: 4000000/2017 IN RE OPIOID LITIGATION Part 48 Hon. Jerry Garguilo SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF SUFFOLK THE PEOPLE OF THE STATE OF NEW YORK, by Letitia James, Attorney General of the State of Index No.: 4000016/2018 New York, Part 48 Hon. Jerry Garguilo Plaintiff, -against- LETTER ROGATORY PURDUE PHARMA L.P., et al., Defendants. REQUEST FOR INTERNATIONAL JUDICIAL ASSISTANCE (LETTER ROGATORY) TO OBTAIN DISCOVERY FROM BANELA CORPORATION IN THE BRITISH VIRGIN ISLANDS The Supreme Court of the State of New York, County of Suffolk, Commercial Division, presents its compliments to the appropriate judicial authority having jurisdiction over civil claims sitting within the British Virgin Islands, and respectfully requests international judicial assistance to obtain evidence to be used in the above-captioned civil action pending before this Court. This Court requests the assistance described herein as necessary in the interests of justice. This request is made pursuant to, and in conformity with, the Hague Convention of 18 March 1970 on the Taking of Evidence Abroad in Civil or Commercial Matters, to which both the United States and the United Kingdom, including the British Virgin Islands, are a party. The Court considers that the evidence sought is directly relevant to the issues in dispute and is not within the meaning of the British Virgin Islands Reservations and Declarations regarding Article 23 of the Hague Evidence Convention. It is expected, based on existing 1 of 300 FILED: SUFFOLK COUNTY CLERK 09/13/2019 03:56 PM INDEX NO. 400000/2017 NYSCEF DOC. NO. 1582 RECEIVED NYSCEF: 09/13/2019 timetables, that the Supreme Court’s trial of this matter may commence in or about May of 2020. Background The Supreme Court of the State of New York, County of Suffolk, in the United States of America is a competent court of law and equity and has jurisdiction over the above-captioned action. This civil case brought by the People of the State of New York (the “State”) includes claims that certain Defendants engaged in constructive or intentional fraudulent conveyances under New York statute, and/or were unjustly enriched through their misconduct. The Defendants relevant to this Letter Rogatory include: Defendants Purdue Pharma, L.P., Purdue Pharma Inc., The Purdue Frederick Company Inc., The P.F. Laboratories, Inc., Defendants PLP Associates Holdings, L.P., Rosebay Medical Company, L.P., Beacon Company, Pharmaceutical Research Associates L.P. f/k/a Purdue Holdings L.P.; Defendants Richard S. Sackler, Jonathan D. Sackler, Mortimer D.A. Sackler, Kathe A. Sackler, Ilene Sackler Lefcourt, David A. Sackler, Beverly Sackler, and Theresa Sackler (collectively, “Sackler Defendants”); and Defendants Doe Entities 1-10. All parties to this litigation and their legal representatives are attached as Exhibits C and D. Need for Discovery from Banela Corporation The claims relevant to this Letter Rogatory are based on monetary transactions involving Defendants named above and their related entities. These transactions are alleged to have been made despite existing and impending investigation and litigation against the Defendants named above, and in derogation of the rights of the State and other plaintiffs, to have left the company without sufficient resources to potentially pay plaintiffs, including the State. The State further alleges that the Sackler Defendants engaged in unlawful asset transfers, including among 2 of 300 FILED: SUFFOLK COUNTY CLERK 09/13/2019 03:56 PM INDEX NO. 400000/2017 NYSCEF DOC. NO. 1582 RECEIVED NYSCEF: 09/13/2019 themselves and entities they control, designed to deny plaintiffs the means to recover on their claims against the company. The State has identified nonparty entity Banela Corporation as an entity controlled directly or indirectly by the Sackler Defendants that it has reason to believe served as conduits of monies or intermediaries between or among the Defendants and therefore has information directly relevant to this litigation. Banela Corporation, incorporated in the British Virgin Islands, is the sole owner of all Class A shares of Defendant Purdue Pharma, Inc. for the benefit of Mortimer Sackler’s family. Banela Corporation is also partial owner of BR Holdings Associates, Inc., the general partner of Defendant Pharmaceutical Research Associates, L.P. f/k/a Purdue Holdings, L.P., as well as partial owner of PLP Associates Holdings, Inc., the general partner of Defendant PLP Associates Holdings L.P. This Court finds that Banela Corporation is likely to have knowledge or documents related to the State’s claims. The particular documents sought are specified in Exhibit A. The information and documents sought by the State from Banela Corporation reside in the British Virgin Islands. The documents the State seeks cannot be obtained from Defendants because they are within the possession, custody, and control of Banela Corporation. Assistance Requested It appears to the Court that the relevant documents at Banela Corporation are in the company’s office, which is located at Wickhams Cay, Tortola, Road Town VG1110, British Virgin Islands. This Court therefore requests in furtherance of justice that you by the proper and usual process of your Court, cause Banela Corporation to produce documents in accordance with the enclosed subpoena at Exhibit A. The requested documents concern, among other topics, details of monetary transactions 3 of 300 FILED: SUFFOLK COUNTY CLERK 09/13/2019 03:56 PM INDEX NO. 400000/2017 NYSCEF DOC. NO. 1582 RECEIVED NYSCEF: 09/13/2019 among the relevant Defendants named above and their related entities and individuals listed in the subpoena, including Banela Corporation. The requested documents also concern indicia of ownership, control and relationship between and among these entities and individuals listed in the subpoena, which are among the principal issues in the common claims against the relevant Defendants named above. Reciprocity and Costs This Court respectfully expresses its willingness to provide similar assistance to the Supreme Court, at P.O. Box 418, Road Town, Tortola, Virgin Islands (British) VG1110, or any other British Virgin Islands court of similar competence. The fees and costs incurred in executing this request that are reimbursable under applicable law will be borne jointly by the State, the relevant Defendants named above and Banela Corporation. Please accept the assurance of our highest esteem. Dated: _______________ _______________________________ Justice Jerry Garguilo 4 of 300 FILED: SUFFOLK COUNTY CLERK 09/13/2019 03:56 PM INDEX NO. 400000/2017 NYSCEF DOC. NO. 1582 RECEIVED NYSCEF: 09/13/2019 Exhibit A: Subpoena Duces Tecum issued to Banela Corporation 5 of 300 FILED: SUFFOLK COUNTY CLERK 09/13/2019 03:56 PM INDEX NO. 400000/2017 NYSCEF DOC. NO. 1582 RECEIVED NYSCEF: 09/13/2019 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF SUFFOLK Index No.: 4000000/2017 IN RE OPIOID LITIGATION Part 48 Hon. Jerry Garguilo SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF SUFFOLK THE PEOPLE OF THE STATE OF NEW YORK, by Letitia James, Attorney General of the State of New York, Index No.: 4000016/2018 Part 48 Plaintiff, -against- Hon. Jerry Garguilo PURDUE PHARMA L.P., PURDUE PHARMA INC., THE PURDUE FREDERICK COMPANY, INC., THE Subpoena Duces Tecum P.F. LABORATORIES, INC., PURDUE HOLDINGS L.P., ROSEBAY MEDICAL COMPANY L.P., THE BEACON COMPANY, PLP ASSOCIATES HOLDINGS, L.P., DOE ENTITIES 1-10, RICHARD S. SACKLER, JONATHAN D. SACKLER, MORTIMER D.A. SACKLER, KATHE A. SACKLER, ILENE SACKLER LEFCOURT, DAVID A. SACKLER, BEVERLY SACKLER, THERESA SACKLER, JOHNSON & JOHNSON, JANSSEN PHARMACEUTICALS, INC., ORTHO-MCNEIL- JANSSEN PHARMACEUTICALS, INC., JANSSEN PHARMACEUTICA, INC., MALLINCKRODT PLC, MALLINCKRODT LLC, SPECGX LLC, ENDO INTERNATIONAL PLC, ENDO HEALTH SOLUTIONS INC., ENDO PHARMACEUTICALS, INC., PAR PHARMACEUTICAL, INC., PAR PHARMACEUTICAL COMPANIES, INC., TEVA PHARMACEUTICAL INDUSTRIES LIMITED, TEVA PHARMACEUTICALS USA, INC., CEPHALON, INC., ALLERGAN PLC, ALLERGAN FINANCE, LLC, ACTAVIS PHARMA, INC., ACTAVIS LLC, WATSON LABORATORIES, INC., MCKESSON CORPORATION, CARDINAL HEALTH, INC., AMERISOURCEBERGEN DRUG CORPORATION, ROCHESTER DRUG COOPERATIVE, INC., Defendants. 6 of 300 FILED: SUFFOLK COUNTY CLERK 09/13/2019 03:56 PM INDEX NO. 400000/2017 NYSCEF DOC. NO. 1582 RECEIVED NYSCEF: 09/13/2019 To: Banela Corporation Wickhams Cay, Tortola Road Town VG1110 British Virgin Islands WE COMMAND YOU, pursuant to Articles 23 and 31 of the New York Civil Practice Law and Rules, to produce to the New York State Attorney General, Letitia James, to the attention of Counsel for Opioids and Impact Litigation David E. Nachman, 28 Liberty Street, New York, New York 10005 within twenty days of service of this Subpoena, all documents and things in your possession, custody, or control in accordance with the definitions and instructions below. Failure to comply with this Subpoena is punishable as a contempt of Court and shall make you liable to the Person on whose behalf this Subpoena was issued for a penalty not to exceed fifty dollars and all damages sustained by reason of your failure to comply. DEFINITIONS 1. “Communication” means any oral or written communication of any kind, including but not limited to face-to-face communications, telephone communications (including voicemail, text messages, or any other means of communication utilizing a telephone or other electronic device), letters, memoranda, electronic mail (“email”), instant messages, or other transmittal of Documents or data through the use of a computer, server, facsimile, or any other medium or device, and includes any Document that digests, memorializes, or records a communication or any part thereof. 2. “Concerning” means directly or indirectly mentioning or describing, Relating to, referring to, regarding, evidencing, setting forth, identifying, manifesting, memorializing, created in connection with or as a result of, commenting on, embodying, evaluating, analyzing, tracking, reflecting or constituting, in whole or in part, a stated subject matter.
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