Karen A. Barth, Esq. (Bar No. 180234)
George W. Murgatroyd III (Bar No. 10976 1)
BAUM, HEDLUND, ARISEI, GUEFORD & Scmvo
12100 Wilshire Blvd., Suite 950
Los Angeles, CA 90025
(3 10) 207-3233
Donald J. Farber, Esq. (Bar No. 168837)
LAW OFFICES OF DONALD J. FARBER
7 Mt. Lassen Drive, Suite D-122
San Rafael, CA 94903
(41.5) 472-7181
Attorneys for Plaintiffs
,
t SUPERIOR COURT OF THE STATE OF CALIFORNL4
I( IN AND FOR THE COUNTY OF LOS ANGELES
1:
1; VERONICA GALLEGO, MONICA KELLER, Case No.:
1: NEDRA HOLDER, DR. KEVIN CWAYNA,
EFREN GONZALEZ, JOYCE ROHR, MAR& COMPLAINT FOR:
la AVARE, BETHANY BAIN-CHAMBERLAIh
JULIA BOND, JOHNNA BOWMAN, 1. FRAUD AND DECEIT;
15 MARLEE CALCOTE, RAYMOND E. NEGLIGENCE;
CHAMBERS, CHARITY FIGEARO, VERA 3* STRICT PRODUCTS
16 RAY-E GOOD, RHONDA KEENE, PENNY 4: BREACH OF EXPRESS
BILODEAU and BONNIE RASOR, WARRANTY;
17 5. BREACH OF IMPLIED
Plaintiffs, WARRANTY
18 vs.
19 DEMAND FOR JURY TRIAL
SMITHKLINE BEECHAM CORPORATION,
20 dba GLAXOSMI'THKLINE, a Pennsylvania
Corporation; and DOES l-100,
21 Defendants.
22
23
24
25
26
SNIPPETS:
SMITHKLINE BEECHAM CORPORATION,
RHONDA KEENE, PENNY BILODEAU and BONNIE RASOR, (hereinafter "Plaintiffs") who
Defendant SMITHKLINE BEECHAM CORPORATION's activities in the State of C'&fornia,
numerosity of the persons suffering from Paxil withdrawal.
and suffering experienced by each of these individuals is the direct result of SMITHKLINE
dependency/withdrawal reactions when the patient's Paxil dosage is reduced or terminated.
10 has been an antidepressant medication of the selective serotonin reuptake inhibitor class
11 (which includes Zolofi and Prozac).
17 dependency, or caused withdrawal reactions when dosage was reduced or terminated.
1 SMITHKLINE BEECHAM CORPORATION has suppressed the information about the severe
22 withdrawal reactions caused by its drug, many patients, including Plaintiffs, and their
26 because they have become dependent and feel they cannot get off the drug.
According to World Health Organization data obtained by the
addiction caused by SMITHKL INE BEECHAM CORPORATION's antidepressant drug Paxil.
recommended by SKB to their treating physicians.
inc usive, are unknown to Plaintiffs, who, therefore, sue said defendants by such fictitious
18 the events and happenings herein alleged, and that Plaintiffs' damages were proximately
24 in the package insert for the drug and further published in the "Physicians' Desk
Paxil's addictive qualities, its tendency to induce dependency, and its dangerous traits in
withdrawal symptoms when the patient reduces and/or abruptly terminates dosage were all facts
physicians, including the physician of each of the Plaintiffs, were ignorant of this danger.
Paxil's half life is 24 hours.
some aspects of psychopharmacology, Prozac clearly has an advantage over Paxil as to
offKal British entity, conducted a study of 13,741 patients who had been treated with SSRIs.
19 and that the drug's addictive and dependency and withdrawal-inducing qualities effectively
16 and representations and due to Paxil's addictive qualities, inducement of physical and
15 Plaintiffs' doctors, to prescribe Paxil, and patients, such as Plaintiffs, to purchase and
|
