Case 3:20-cv-06522 Document 1 Filed 09/17/20 Page 1 of 45 1 Alan M. Mansfield, SBN: 125998 WHATLEY KALLAS LLP 2
[email protected] 1 Sansome Street, 35th Floor PMB #131 3 San Francisco, CA 94104 Tel: (619) 308-5034 4 Fax: (888) 341-5048 5 Joe R. Whatley, Jr. (Pro Hac Vice application to be filed) 6
[email protected] Edith M. Kallas 7 (Pro Hac Vice application to be filed)
[email protected] 8 WHATLEY KALLAS, LLP 152 W. 57th Street, 41st Floor 9 New York, NY 10019 Tel: (212) 447-7060 10 Fax: (800) 922-4851 11 Henry C. Quillen (Pro Hac Vice application to be filed) 12
[email protected] WHATLEY KALLAS, LLP 13 159 Middle Street, Suite 2C Portsmouth, NH 03801 14 Tel: (603) 294-1591 Fax: (800) 922-4851 15 Attorneys for Plaintiff 16 UNITED STATES DISTRICT COURT 17 NORTHERN DISTRICT OF CALIFORNIA 18 SAN FRANCISCO DIVISION 19 20 JACKSONVILLE POLICE OFFICERS CASE NO. AND FIRE FIGHTERS HEALTH 21 INSURANCE TRUST, on behalf of CLASS ACTION COMPLAINT itself and all others similarly situated; (1) Violation of Section 1 of the 22 Plaintiff, Sherman Act, 15 U.S.C. § 1 23 (2) Violation of the Cartwright Act, v. Cal. Bus. & Prof. Code §§ 16700 et 24 seq. GILEAD SCIENCES, INC., CIPLA (3) Violation of Cal. Bus. & Prof. Code 25 LTD., CIPLA USA INC., §§ 17200 et seq. (“UCL”) 26 Defendants. (4) Restitution, Money Had and Received, Unjust Enrichment, 27 Quasi-Contract and/or Assumpsit (5) Violation of State Law 28 JURY TRIAL DEMANDED CLASS ACTION COMPLAINT Case 3:20-cv-06522 Document 1 Filed 09/17/20 Page 2 of 45 1 Plaintiff, on behalf of itself and all others similarly situated, upon personal 2 knowledge as to its own acts and status as specifically identified herein, and 3 otherwise upon information and belief based upon investigation as to the remaining 4 allegations, which allegations are likely to have support after a reasonable 5 opportunity for investigation and discovery, hereby alleges as follows against 6 Defendants: 7 INTRODUCTION 8 1.