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Complaint ) and Jury Demand Purdue Pharma L.P., Purdue Pharma Inc., ) Richard Sackler, Theresa Sackler, ) Kathe Sackler, Jonathan Sackler, ) Mortimer D.A

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Complaint ) and Jury Demand Purdue Pharma L.P., Purdue Pharma Inc., ) Richard Sackler, Theresa Sackler, ) Kathe Sackler, Jonathan Sackler, ) Mortimer D.A COMMONWEALTH OF MASSACHUSETTS SUFFOLK, ss. SUPERIOR COURT C.A.No. 1884-cv-01808 (BLS2) ) COMMONWEALTH OF MASSACHUSETTS, ) ) FIRST AMENDED v. ) COMPLAINT ) AND JURY DEMAND PURDUE PHARMA L.P., PURDUE PHARMA INC., ) RICHARD SACKLER, THERESA SACKLER, ) KATHE SACKLER, JONATHAN SACKLER, ) MORTIMER D.A. SACKLER, BEVERLY SACKLER, ) DAVID SACKLER, ILENE SACKLER LEFCOURT, ) PETER BOER, PAULO COSTA, CECIL PICKETT, ) RALPH SNYDERMAN, JUDITH LEWENT, CRAIG ) LANDAU, JOHN STEWART, MARK TIMNEY, ) and RUSSELL J. GASDIA ) ______________________________________________________) Complete Unredacted Corrected Version For The Public File Submitted According To Court Order January 31, 2019 I. INTRODUCTION 1. Dangerous opioid drugs are killing people across Massachusetts. Prescription medicines, which are supposed to protect our health, are instead ruining people’s lives. Every community in our Commonwealth suffers from the epidemic of addiction and death. 2. Purdue Pharma created the epidemic and profited from it through a web of illegal deceit. First, Purdue deceived Massachusetts doctors and patients to get more and more people on its dangerous drugs. Second, Purdue misled them to use higher and more dangerous doses. Third, Purdue deceived them to stay on its drugs for longer and more harmful periods of time. All the while, Purdue peddled falsehoods to keep patients away from safer alternatives. Even when Purdue knew people in Massachusetts were addicted and dying, Purdue treated doctors and their patients as targets to sell more drugs. At the top of Purdue, a small group of executives led the deception and pocketed millions of dollars. 3. On behalf of the Commonwealth, the Attorney General asks the Court to end Purdue’s illegal conduct and make Purdue and its culpable executives pay for the harm they inflicted in our state. II. PARTIES 4. The plaintiff is Attorney General Maura Healey, who brings this action in the public interest in the name of the Commonwealth of Massachusetts. 5. The defendants are two companies and seventeen individuals who engaged in a deadly, deceptive scheme to sell opioids in Massachusetts. This Amended Complaint addresses the bases for jurisdiction and liability as to each of the nineteen defendants, arising from their decade-long course of misconduct in Massachusetts that involved hundreds of deaths, hundreds of thousands of unlawful acts, and hundreds of millions of dollars. 2 6. Defendant Purdue Pharma Inc. is a drug company incorporated in New York with its principal place of business in Connecticut. It is the general partner of Defendant Purdue Pharma L.P., a limited partnership established in Delaware with its principal place of business in Connecticut. This Complaint refers to Purdue Pharma Inc. and Purdue Pharma L.P. collectively as “Purdue.” 7. The seventeen individual defendants are current and former directors and officers of Purdue Pharma Inc. In Massachusetts, directors, officers, and employees of corporations are not immune from jurisdiction or liability when they break the law. Instead, every individual is accountable for his or her actions.1 8. Defendants Richard Sackler, Beverly Sackler, David Sackler, Ilene Sackler Lefcourt, Jonathan Sackler, Kathe Sackler, Mortimer Sackler, and Theresa Sackler controlled Purdue’s misconduct. Each of them took a seat on the Board of Directors of Purdue Pharma Inc. Together, they always held the controlling majority of the Board, which gave them full power over both Purdue Pharma Inc. and Purdue Pharma L.P. They directed deceptive sales and marketing practices deep within Purdue, sending hundreds of orders to executives and line employees. From the money that Purdue collected selling opioids, they paid themselves and their family billions of dollars. 9. Defendants Peter Boer, Judith Lewent, Cecil Pickett, Paulo Costa, and Ralph Snyderman took seats on the Board and knowingly advanced the Sacklers’ scheme. 1 E.g., Kleinerman v. Morse, 26 Mass. App. Ct. 819 (1989); Hongyu Luo v. Tao Ceramics, 32 Mass. L. Rptr. 134 (Mass. Sup. Ct. 2014); Rissman, Hendricks & Oliverio v. MIV Therapeutics, 901 F. Supp. 2d 255 (D. Mass. 2012); Trans National Travel v. Sun Pacific Intern., 10 F. Supp. 2d 79 (D. Mass. 1998); Yankee Group v. Yamashita, 678 F. Supp. 20 (D. Mass. 1988); Johnson Creative Arts v. Wool Masters, 573 F. Supp. 1106 (D. Mass. 1983). “The question of personal jurisdiction over an individual, therefore, rests on whether there is an independent basis for jurisdiction based on an individual’s actions, regardless of the capacity in which those actions were taken.” Rissman, 901 F. Supp. 2d at 263. A defendant’s “status as a corporate officer and director does not insulate him from personal jurisdiction.” Id. at 264. 3 10. Defendants John Stewart, Mark Timney, and Craig Landau each directed Purdue’s deception as CEO of Purdue Pharma Inc. and Purdue Pharma L.P. Defendant Russell Gasdia carried out the misconduct as Vice President of Sales and Marketing. 11. Beverly Sackler, Jonathan Sackler, Kathe Sackler, Paulo Costa, Mark Timney, and Craig Landau reside in Connecticut. David Sackler, Ilene Sackler Lefcourt, and Mortimer Sackler reside in New York. Richard Sackler, Peter Boer, and John Stewart reside in Florida. Judith Lewent and Cecil Pickett reside in New Jersey. Ralph Snyderman resides in North Carolina. Theresa Sackler resides in the United Kingdom. Russell Gasdia resides in Massachusetts. 12. The Court has jurisdiction over all the defendants for the reasons set forth on pages 51-269 below. III. OUTLINE OF THE COMPLAINT 13. On May 15, 2007, this Court entered Judgment (“2007 Judgment”) to prohibit Purdue’s deceptive conduct in the sale of opioids. This suit addresses Purdue’s misconduct since that 2007 Judgment. 14. The Complaint begins with the story of Purdue’s misconduct in Massachusetts (pages 1-51). The Complaint then explains how each individual defendant broke the law (pages 52-256). Sections addressing jurisdiction, the counts, prayers for relief, and the jury demand then follow, as outlined in the following Table of Contents. 4 TABLE OF CONTENTS I. INTRODUCTION ....................................................................................................................2 II. PARTIES ...............................................................................................................................2 III. OUTLINE OF THE COMPLAINT ...........................................................................................4 IV. PURDUE’S DRUGS KILL HUNDREDS OF PEOPLE IN MASSACHUSETTS ..............................7 V. PURDUE TARGETED MASSACHUSETTS WITH ITS UNFAIR AND DECEPTIVE SALES CAMPAIGN .........................................................................................................................11 VI. PURDUE DECEIVED DOCTORS AND PATIENTS TO GET MORE PEOPLE ON DANGEROUS DRUGS, AT HIGHER DOSES, FOR LONGER PERIODS ..................................14 A. More People ........................................................................................................... 14 B. Higher Doses .......................................................................................................... 22 C. Longer Periods ....................................................................................................... 28 VII. PURDUE PEDDLED FALSEHOODS TO KEEP PATIENTS AWAY FROM SAFER ALTERNATIVES ..................................................................................................................34 VIII. PURDUE TARGETED DOCTORS WHO PRESCRIBED THE MOST DRUGS, EVEN WHEN THEY WROTE ILLEGITIMATE PRESCRIPTIONS AND THEIR PATIENTS DIED ..................39 IX. PURDUE PHARMA INC. AND PURDUE PHARMA L.P. ARE BOTH RESPONSIBLE FOR THE DEADLY MISCONDUCT ..............................................................................................51 X. THE INDIVIDUAL DEFENDANTS LED PURDUE’S MISCONDUCT ........................................52 A. Richard Sackler, Beverly Sackler, David Sackler, Ilene Sackler Lefcourt, Jonathan Sackler, Kathe Sackler, Mortimer Sackler, and Theresa Sackler ... 54 B. Peter Boer, Judith Lewent, Cecil Pickett, Paulo Costa and Ralph Snyderman ........................................................................................ 173 C. John Stewart, Russell Gasdia, Mark Timney, and Craig Landau ................. 197 XI. DISCOVERY RULE AND TOLLING ....................................................................................257 XII. JURISDICTION AND VENUE ..............................................................................................258 XIII. CAUSES OF ACTION .........................................................................................................270 XIV. PRAYER FOR RELIEF .......................................................................................................273 XV. JURY DEMAND .................................................................................................................274 5 KEY CHARTS AND ILLUSTRATIONS Opioid Deaths in Massachusetts ..................................................................................................7 Purdue Targeted Massachusetts ...................................................................................................11 Do You Have Patients Like Pam? ...............................................................................................21 Purdue Promotions for Higher Doses ..........................................................................................23 Impact of Changes in
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