SCHIFFRIN & BARROWAY, LLP
Richard S. Schiffrin, Esq.
Tobias L. Millrood, Esq.
Attorney I.D. Nos. 61872 /77764
Three Bala Plaza East, Suite 400
Bala Cynwyd, PA 19004
(6 10) 667-7706
JUNE BLOCH, individually and on behalf of :
all others similarly situated,
COURT OF COMMON PLEAS
Plaintiff PHILADELPHIA C
vs. TERM,
No* 60 lT\t.t
WYETH individually and d/b/a
WYETH-AYERST RESEARCH CLASS ACTION COMPLAINT
JURY TRIAL DEMANDED
Defendants
CLASS ACTION COMPLAINT
Now comes the plaintiff, June Bloch, individually and on behalf of all others
situated, by and through their attorneys, and complaining of the defendants, Wyeth,
d/b/a Wyeth-Ayerst Research and state as follows:
I. INTRODUCTION
1. Plaintiff brings this national class action, on her own behalf and as
of a class of persons and consisting of all persons in the United States who are/were
drug Prempro (chemically known as conjugated estrogens/medroxyprogesterone
estates, administrators, or other legal representatives, heirs, or beneficiaries.
1
2. Plaintiff brings this action individually and as class representative to
SNIPPETS:
WYETH individually and d/b/a
Plaintiff brings this national class action, on her own behalf and as representatives
of a class of persons and consisting of all persons in the United States who are/were
estates, administrators, or other legal representatives, heirs, or beneficiaries.
Plaintiff brings this action individually and as class representative to recover damages
for deaths and personal injuries, restitution, refunds, and/or for equitable, injunctive, and
Wyeth and Wyeth d/b/a Wyeth-Ayerst Research (collectively "defendants"
The drug used during the trial was Prempro,
consumers of Prempro are at an increased risk of harm, establish a medical monitoring fund so
diagnosed, and is unaware of having an injury at this time, but may be at an increased risk
important objective of the trial was to examine the effect of estrogen plus progestin on the
heart attacks, strokes, and blood clots in women taking hormones.
time that the number of cases of invasive breast cancer in the estrogen plus progestin group
for cardiovascular disease and invasive breast cancer were present across racial/ethnic and
of Prempro during the relevant time period (the "Wrongful Death
who claim relief pursuant to either Pennsylvania and/or New
claims against a specific defendant (the "Consumer Protection Subclass").
Code Ann.
The relief sought includes injunctive relief and declaratory relief with respect to the
and the Class members in the early detection and treatment of illnesses caused by Prempro.
The pharmaceutical defendants have a duty to exercise reasonable care to properly
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