TAXOTERE (DOCETAXEL) MDL No
Case 2:16-cv-17144 Document 1 Filed 12/12/16 Page 1 of 101 IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF LOUISIANA IN RE: TAXOTERE (DOCETAXEL) MDL No. 2740 PRODUCTS LIABILITY LITIGATION SECTION “N” (5) HON. KURT D. ENGLELHARDT BARBARA EARNEST Plaintiff, MAG. JUDGE NORTH vs. COMPLAINT & JURY DEMAND SANOFI S.A., Civil Action No. __________ AVENTIS PHARMA S.A., and SANOFI-AVENTIS U.S. LLC, separately, and doing business as WINTHROP U.S HOSPIRA WORLDWIDE, INC.; and SUN PHARMA GLOBAL INC.; and McKESSON CORPORATION d/b/a McKESSON PACKAGING; and SANDOZ INC.; and ACCORD HEALTHCARE INC.; and APOTEX, INC.; and PFIZER, INC.; and ACTAVIS PHARMA, INC.; and NORTHSTAR RX LLC; and EAGLE PHARMACEUTICALS, INC. Defendants. COMPLAINT AND JURY DEMAND Plaintiff, Barbara Earnest, by and through her attorneys, Bachus & Schanker, LLC, respectfully submits the following Complaint and Jury Demand against Defendants Sanofi S.A.; Aventis Pharma S.A.; and Sanofi-Aventis U.S. LLC, separately,; and doing business as Winthrop Case 2:16-cv-17144 Document 1 Filed 12/12/16 Page 2 of 101 U.S and Hospira Worldwide, Inc.; and Sun Pharma Global Inc.; and McKesson Corporation d/b/a McKesson Packaging; and Sandoz Inc.; and Accord Healthcare Inc..; and Apotex, Inc.; and Pfizer, Inc.; and Actavis Pharma, Inc.; and Northstar Rx LLC; and Eagle Pharmaceuticals, Inc., and alleges the following upon personal knowledge, information and belief, and investigation of counsel. NATURE OF THE ACTION 1. This action seeks to recover damages for injuries sustained by Plaintiff as the direct and proximate result of the wrongful conduct of Defendants Sanofi S.A., Aventis Pharma S.A., and Sanofi-Aventis U.S.
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