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IN THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS
COUNTY DEPARTMENT, LAW DIVISION
CALVIN LOVERLING, JR., as Special )
Administrator of the Estate of CALVIN )
LOVERLING, deceased, individually )
and on behalf of all others similarly )
situated, )
)
Plaintiffs, )
)
v. ) No.
)
BAXTER INTERNATIONAL, INC., a ) Jury Demanded
Delaware Corporation, BAXTER
)
HEALTHCARE CORPORATION, a
)
Delaware Corporation, and
)
MINNESOTA MINING &
)
MANUFACTURING COMPANY, a
)
Delaware Corporation, )
)
Defendants. )
CLASS ACTION COMPLAINT
NOW COMES the Plaintiff, CALVIN LOVERLING, JR., as Special
Administrator of the Estate of CALVIN LOVERLING, deceased, individually and on
behalf of all others similarly situated, by and through his attorneys, KENNETH B.
MOLL & ASSOCIATES, LTD., and complaining of the Defendants, BAXTER
INTERNATIONAL, INC., a Delaware Corporation, BAXTER HEALTHCARE
CORPORATION, a Delaware Corporation, and MINNESOTA MINING &
MANUFACTURING COMPANY, a Delaware Corporation, and state as follows:
SNIPPETS:
IN THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS
Delaware Corporation, BAXTER
NOW COMES the Plaintiff, CALVIN LOVERLING, JR., as Special
Administrator of the Estate of CALVIN LOVERLING, deceased, individually and on
behalf of all others similarly situated, by and through his attorneys, KENNETH B.
MOLL & ASSOCIATES, LTD., and complaining of the Defendants, BAXTER
CORPORATION, a Delaware Corporation, and MINNESOTA MINING &
MANUFACTURING COMPANY, a Delaware Corporation, and state as follows:
This worldwide class action lawsuit is filed on behalf of all persons that
suffered personal injuries, death or other compensatory injuries as the result of A,
AF and AX series dialyzers designed, manufactured, sold, and distributed by
INC. and BAXTER HEALTHCARE CORPORATION
The BAXTER defendants have been marketing, distributing,
Dr. William Kolff sought a medical company to help develop his kidney dialysis
pursuant to the Illinois Code of Civil Procedure, 735 ILCS 5/2-801 and 2-802.
Plaintiffs seek certification of the following Class:
Defendants have a controlling interest, and their legal representatives,
Class members may be informed of the pendency of this Class
Whether the Defendants breached any implied warranties;
Plaintiffs repeat and reallege, as if fully set forth herein, each and
every allegation contained in the above paragraphs and further allege:
As a direct and proximate result of Defendants' manufacturing,
Plaintiffs and class members are at an increased risk of developing
The Defendants gave an implied warranty pursuant to 810 ILCS 5/2314.
merchantable quality and safe and fit for the use for which they were intended.
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