THOMAS M. NOCELLA, ESQUIRE
2600 E. ALLEGHENY AVENUE
PHILADELPHIA, PA 19134 JURY TlUAL
(215) 426-3655
ATTORNEY I.D. #I4406
ATTORNEY FOR PLAINTIFFS
YUSUF ABDl.kAZ.lZ. ET AL., 1 PHILADELPHIA
CCXJRT OF COMMON
PLAINTIFFS ,'
VS. ; SEPTEMBER TERM. 1'000
CITY OF PHILADELPHIA. ET AL. ; NO,: 34:13
DEFENDANTS
ClVlL ACTION C0MPLATNJ
NOTICE
"You have been sued in court. If you wish CO "Lt ban
defend against the claims set forth in the followiag quite defcnderss dt
pages, you must take action within twenty (20) da)s pagirlas siguienrcs,
afier this complaint and notice are served, by enterifig al partir de la
a written appesuance personally or by attorney and Hate hlta asentar una
filing in writing with the court your defenses or 0 con un abogado y
objections
to the claims set forth against yw you are sus objeciones a las
warned that if you fail to do so the case may proc4 Sea avisado que si
without you and a judgment may be entered against mdidas y puede
you by the cou17 without furtk notice fm any money sin pr&o aviso o
claimed in the complaint or for any other clainl or relief puedde decidir a
requested by the plaintiff. You may lose money or usted cumpla con
property of other tights imvt to you. Usted pue& perder
derechos importanr.es
"YOU SHOULD TAKE -l'kIlS PAPER TO YOUR
LAWYER AT ONCE. IF YOU DO NOT HAVE A LLEVE ESTA DE.kI.ANDA
LAWYER OR CAN-N-NOT AFFORD ONE, GO TO OR INMEDIATAMRJTE.
TELEPHONE THE OFFICE SET FORTH BELOW To TIENE ELDlNER0
SERVICO.
FIND OUT WHERE YOU CAN GET LEGAL HELP." VAYA EN PERSONA 0
QFICMA CUYA
ABAJO PAN AVEIUCI.IAR
CONSECiLiIR ASISTENCIA
PHILADELPHIA BAR ASSOCATION
LAWYER REFERRAL AND ASOCIACION DE
SNIPPETS:
ATTORNEY FOR PLAINTIFFS
WS~,JF ABDUL,AZIZ et al., are former inmates who were incarmated at Hcdmesburg prison,
experimentation at said prison during the aforemunti0ne.d time period.
Pennsylvania and, as a penal custdian of the Plaintiffs, was responsibiz for their heaWl,
time they were incarcerated at Holmesburg Prison.
Johnson and Johnson (hereinafter "JOHNSON") is an international pharmac~tical corporation
offices located at 1 Johnson arid Johnson Plaza, New Brunswick, NJ 08933.
2030 Dow Center Midland, MI 48642.
Ivy Research Labs, Inc. is a Pennsylvania corporation founded by Defendant, Klimn
subjects of medical experimentation at said prison at Some time during the aforr:mentic:!ned
Failing, omitting and neglecting to properly sufficiently and adequatrlly supervise, inspect,
Pern&ing the other Defendzmts to inform the prisoners that the chemicals anI;!
Permitting Plaintiffs to be tested without their informed consent.
Allowing experimentation, including the use of radioactive isotopes, in area:;
Allowing harmful results caused by the medical experimentation and then not properly treating
Plaintiffs hereby incorporate by reference herein paragraphs 1 through 13 hereof as though
WHEREFORE, the plaintiffs demand jud@nent against the Defendant PH.J.LAbEILPHIA in the amount
Defendant PENN was the respbnsible entity for conducting all human medicr:ll experimentation
Wolmburg Prison during tie relevant time period.
Failing to exercise sufficient supervisory control in the testing that was cl;>nductl.:d in
unjustly enriched, along with detest, attorney fees, and other related expenses in an
A$ a result of this underpaying, Defendant PENN gained huge profits, which must be shared
Through the negligence, carelessness, and recklessrlas of Defendant IVY Plaintiffs were
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