MISSOURI CIRCUIT COURT

TWENTY-SECOND JUDICIAL CIRCUIT

(CITY OF ST. LOUIS)

CIVIL CASE NO.042-07388

DIVISION One (1) Track 2

PAULA BALLARD and

BRENT L. BALLARD, her husband

and

LINDA BOELK and

ARTHUR R. BOELK, her husband

and

LINDA BOLTON and

CLAUD H. BOLTON, JR., her husband

and

ELAINE BRIDEN

and

LINDA BURCHFIELD and

JOHN BURCHFIELD, her husband

and

THEDA CAGLE and

EARL D. CAGLE, her husband

and

BETSY CALMA and

ROY D. CALMA, her husband

and

BONNIE CAMPBELL

and

CATHY COODY

and

ANGELA DIPIETRO

and

BRENDA FERGUSON and

JEFF FERGUSON, her husband

and

ARNOLD J. GOZZI, Individually and as

Personal Representative of the Estate of

ANTOINETTE E. GOZZI (Deceased)

and

LEONA HAMM

and

ROMA KILLIAN and

KENNETH R. KILLIAN, her husband

and

MARY ANN LONG and

RICHARD B. LONG., her husband

and

RUTH MANCINI

and

JANET MIESENZAHL and

NELSON H. MIESENZAHL, her husband

and

SANDRA L. MOWER and

THERON MOWER, her husband

and

FRANCINE S. NECOWITZ and

ARTHUR J. NECOWITZ, her husband

and

MARGARET RUBIN-FINN

and

DEBORAH L. WILLIS and

EDGAR T. WILLIS, her husband

and

FAYE JOHNSON and

GERALD E. JOHNSON, her husband

and

RUTH MACDUFF and

MATTHEW MACDUFF, her husband

and

GAIL M. WATT

and

GRACE JUREWICZ and

JERRY JUREWICZ, her husband

and

LEONIE SCHINDLER and

FRED F. SCHINDLER, her husband

and

DOROTHY JOHNSON and

LORENZO JOHNSON, her husband

and

ANN MULLINS and

SAMBO MULLINS, her husband

and

PATRICIA MORTON and

JOE WALLACE MORTON, her husband

and

JOYCE DELOACH and

JAMES DELOACH, her husband

and

PATRICIA CUSHMAN and

RAYMOND R. CUSHMAN, her husband

and

DONNA MERWIN and

JOSEPH MERWIN, her husband

and

GAIL MCCLELLAN

and

NANCY SULLIVAN

and

MICHAEL MOUNTS, Individually and as

Personal Representative of the Estate of

LORETTA MOUNTS (Deceased)

and

WALTER MAE SHURN

and

CAROL ANDERSON

and

ANNA MAE AYERS

and

DOROTHY HULL

and

NORMA MAXFIELD

and

MAXINE HOWARD

and

LUCY GARCIA and

SALVADOR GARCIA, her husband

and

DEANNA LOUDERBACK

and

JANICE WALROD

and

DORIS GANZY and

JOHN GANZY, her husband

and

NANCY ANDREWS

and

JUDY MELENDEZ

and

ANTHONY SBROCCHI, as

Personal Representative of the Estate of

FILOMENA SBROCCHI (Deceased)

and

MARILYN CARLL

and

BETTY SYNEGAL

and

LINDA SUTER

and

TONYA WARNER

and

JEAN PARADIS

And

LINDA STAMPER and

HUGH E. STAMPER, her husband

and

DARYLLE D. WILLENBROCK and

THEODORE E. WILLENBROCK, her husband

and

ELBY F. ROGERS, SR., Individually and as

Personal Representative of the Estate of

CHARLOTTE D. ROGERS (Deceased)

and

MARILYN BILLEAU and

WILLIAM L. BILLEAU, her husband

and

BARBARA LIBERMAN

and

LORETTA PATTEN

and

LUCILLE RICHARDSON and

HOWARD CLIFTON RICHARDSON, her husband

and

JUNE SEATON

and

BEVERLY WEATHERSPOON and

LARRY WEATHERSPOON, her husband

and

LOIS BARG

and

CONNIE SIDES and

SAMMIE L. SIDES, her husband

and

BRENDA BERMAN and

BARRY J. BERMAN, her husband

and

MARGARET BICKEL and

JAMES R. BICKEL, her husband

and

CORNELIA HOBLEY and

CHARLES W. HOBLEY, her husband

and

CATHERINE KENNON

and

EVELYN M. ROSS

and

DEBORAH BRANSON

and

AECHA WILSON

and

JUDY SHEPHARD

and

MOLENA ROBERTS

and

GAYLE ULMER

and

BONNIE JOHNSON

and

MARY BRADLEY

and

MAUREEN EVERETT

and

LINDA STROH

and

SUSAN KAY GROSOR

and

MARILYN FERGUSON and

BOBBY E. FERGUSON, her husband

and

DORIS FORTNER and

WALTER FORTNER, her husband PLAINTIFFS

vs. COMPLAINT

WYETH a/k/a WYETH, INC.

(f/k/a American Home Products Corporation)

Five Giralda Farms

Madison NJ 07940

Serve: Prentice-Hall Corporation System

221 Bolivar Street

Jefferson City MO 65101

and

AMERICAN HOME PRODUCTS, INC.

Five Giralda Farms

Madison NJ 07940

Serve: Prentice-Hall Corporation System

221 Bolivar Street

Jefferson City MO 65101

and

AHP SUBSIDIARY HOLDING CORPORATION

f/k/a WYETH-AYERST LABORATORIES COMPANY

A division of WYETH

C/O Wilmington Trust SP Services, Inc.

1105 N. Market Street, Suite 1300

Wilmington DE 19801

Serve: Secretary of State (pursuant to RSMo. §351.380)

State Capitol, Room 208

600 W. Main

Jefferson City MO 63101

and

WYETH PHARMACEUTICALS a/k/a WYETH PHARMACEUTICALS, INC.

(f/k/a WYETH-AYERST PHARMACEUTICALS, INC. and AYERST

LABORATORIES, INC.)

a division of WYETH

500 Arcola Road

Collegeville PA 19426

or

150 Radnor-Chester Road

St. Davids PA 19087

Serve: Prentice-Hall Corporation System

221 Bolivar Street

Jefferson City MO 65101

and

WYETH-AYERST PHARMACEUTICALS, INC.

555 Lancaster Avenue

St. Davids PA 19087

or

150 Radnor-Chester Road

St. Davids PA 19087

Serve: Prentice-Hall Corporation System

221 Bolivar Street

Jefferson City MO 65101

and

PHARMACIA & UPJOHN COMPANY

7000 Portage Road

Kalamazoo MI 49001

Serve: CT Corporation System

120 South Central Avenue

Clayton MO 63105

and

PFIZER INC.

235 East 42^nd Street, 26^th Floor

New York NY 10017

Serve: CT Corporation System

120 South Central Avenue

Clayton MO 63105

and

ABBOTT LABORATORIES, INC.

100 Abbott Park Rd.

Abbott Park IL 60064

Serve: The Corporation Company

120 South Central Avenue

Clayton MO 63105

and

PARKE-DAVIS,

A Warner Lambert Division of PFIZER, INC.

201 Tabor Rd.

Morris Plains NJ 07950

Serve: Secretary of State (pursuant to RSMo. §351.380)

State Capitol, Room 208

600 W. Main

Jefferson City MO 63101

and

SCHERING CORPORATION

a subsidiary of

SCHERING-PLOUGH CORPORATION

2000 Galloping Hill Road

Kenilworth NJ 07033

Serve: CT Corporation System

906 Olive Street

St. Louis MO 63101

and

BARR LABORATORIES, INC.

2 Quaker Road

PO Box 2900

Pomona NY 10970-0519

Serve: Secretary of State (pursuant to RSMo. §351.380)

State Capitol, Room 208

600 W. Main

Jefferson City MO 63101

and

BARR PHARMACEUTICALS, INC.

2 Quaker Road

PO Box 2900

Pomona NY 10970-0519

Serve: Secretary of State (pursuant to RSMo. §351.380)

State Capitol, Room 208

600 W. Main

Jefferson City MO 63101

and

DURAMED PHARMACEUTICALS, INC.

a subsidiary of

BARR PHARMACEUTICALS, INC.

2 Quaker Road

PO Box 2900

Pomona NY 10970-0519

Serve: Secretary of State (pursuant to RSMo. §351.380)

State Capitol, Room 208

600 W. Main

Jefferson City MO 63101

and

WARNER CHILCOTT, INC.

a subsidiary of GALEN HOLDINGS PLC

Rockaway 80 Corporate Center

100 Enterprise Drive, Suite 280

Rockaway NJ 07866

Serve: Secretary of State (pursuant to RSMo. §351.380)

State Capitol, Room 208

600 W. Main

Jefferson City MO 63101

and

BRISTOL-MYERS SQUIBB COMPANY

345 Park Ave.

New York, New York 10154-0037

Serve: CT Corporation System

120 South Central Avenue

Clayton MO 63105

and

QUALITEST PHARMACEUTICALS, INC

130 Vintage Drive Northeast

Huntsville AL 35811-8216

Serve: Secretary of State (pursuant to RSMo. §351.380)

State Capitol, Room 208

600 W. Main

Jefferson City MO 63101

and

GREENSTONE LTD.

7000 Portage Road

Kalamazoo MI 49001

Serve: Secretary of State (pursuant to RSMo. §351.380)

State Capitol, Room 208

600 W. Main

Jefferson City MO 63101

and

MYLAN PHARMACEUTICALS, INC.

781 Chestnut Ridge Rd.

Morgantown WV 26505

Serve: Secretary of State (pursuant to RSMo. §351.380)

State Capitol, Room 208

600 W. Main

Jefferson City MO 63101

and

MYLAN LABORATORIES, INC.

1500 Corporate Drive, Suite 400

Canonsburg PA 15317

Serve: Secretary of State (pursuant to RSMo. §351.380)

State Capitol, Room 208

600 W. Main

Jefferson City MO 63101

and

WATSON LABORATORIES, INC.

311 Bonnie Circle

Corona CA 91720

Serve: Secretary of State (pursuant to RSMo. §351.380)

State Capitol, Room 208

600 W. Main

Jefferson City MO 63101

and

MONARCH PHARMACEUTICALS, INC.,

A wholly owned subsidiary of KING PHARMACEUTICALS, INC.

501 5^th Street

Bristol TN 37620

Serve: Secretary of State (pursuant to RSMo. §351.380)

State Capitol, Room 208

600 W. Main

Jefferson City MO 63101

and

KING PHARMACEUTICALS, INC.

501 5^th Street

Bristol TN 37620

Serve: Secretary of State (pursuant to RSMo. §351.380)

State Capitol, Room 208

600 W. Main

Jefferson City MO 63101

and

ORGANON USA, INC. a/k/a

ORGANON PHARMACEUTICALS, USA, INC.

56 Livingstone Ave.

Roseland NJ 07068

Serve: Secretary of State (pursuant to RSMo. §351.380)

State Capitol, Room 208

600 W. Main

Jefferson City MO 63101

and

SOLVAY PHARMACEUTICALS, INC.

901 Sawyer Rd.

Marietta GA 30062

Serve: Secretary of State (pursuant to RSMo. §351.380)

State Capitol, Room 208

600 W. Main

Jefferson City MO 63101

and

NOVO NORDISK PHARMACEUTICALS, INC.

100 College Rd. West

Princeton NJ 08540

Serve: Secretary of State (pursuant to RSMo. §351.380)

State Capitol, Room 208

600 W. Main

Jefferson City MO 63101

and

AVENTIS PHARMACEUTICALS, INC.

f/k/a HOECHST MARION ROUSSEL, INC.

a/k/a HOECHST PHARMACEUTICALS, INC.

300 Somerset Corporate Blvd.

Bridgewater NJ 08807

Serve: The Corporation Company

120 South Central Avenue

Clayton MO 63105

and

WALGREEN COMPANY

200 Wilmot Road

Deerfield, IL 60015

Serve: Prentice-Hall Corporation System

221 Bolivar Street

Jefferson City MO 65101

and

WAL-MART STORES, INC.

702 Sw 8th Street

Bentonville, AR 72716

Serve: CSC-Lawyers Inc. Service Co.

221 Bolivar Street

Jefferson City MO 65101

and

CVS PHARMACY, INC.

One CVS Drive

Woonsocket RI 02895

Serve: CT Corporation System

120 South Central Avenue

Clayton MO 63105

and

COSTCO WHOLESALE CORPORATION

999 Lake Drive

Issaquah WA 98027

Serve: CT Corporation System

120 South Central Avenue

Clayton MO 63105

and

ECKERD CORPORATION

8333 Bryan Dairy Road

Largo FL 33777-1230

Serve: CT Corporation System

120 South Central Avenue

Clayton MO 63105

and

THRIFT DRUG, INC.

8333 Bryan Dairy Road

Largo FL 33777-1230

Serve: CT Corporation System

120 South Central Avenue

Clayton MO 63105

and

THE KROGER CO.

1014 Vine Street

Cincinnati OH 45202-1100

Serve: CSC-Lawyers Inc. Service Co.

221 Bolivar Street

Jefferson City MO 65101

and

MEDICINE SHOPPE INTERNATIONAL, INC.

7000Cardinal Place

Dublin OH 43017

Serve: CSC-Lawyers Inc. Service Co.

221 Bolivar Street

Jefferson City MO 65101

and

RITE AID CORPORATION

PO Box 3165

Harrisburg PA 17105-3165

Serve: Secretary of State (pursuant to RSMo. §351.380)

State Capitol, Room 208

600 W. Main

Jefferson City MO 63101 DEFENDANTS

*** *** *** *** *** *** *** *** *** *** ***

COME NOW the Plaintiffs, and for their Complaint against Defendants, allege and aver as follows:

THE PARTIES AND JURISDICTION

1. The Defendant, Wyeth a/k/a Wyeth, Inc. (f/k/a American Home Products Corporation and hereafter referred to as “Wyeth”), is a Delaware corporation with its principal place of business in New Jersey. At all times material hereto, Wyeth was engaged in the business of testing, developing, manufacturing, labeling, marketing, distributing, promoting, and/or selling, either directly or indirectly, through third parties or related entities, hormone therapy drugs, including Premarin®, Aygestin®, Premphase®, Cycrin® and Prempro®.

2. The Defendant, American Home Products, Inc. (hereafter referred to as “AHP”), is a Delaware corporation with its principal place of business in New Jersey. At all times material hereto, AHP was engaged in the business of testing, developing, manufacturing, labeling, marketing, distributing, promoting, and/or selling, either directly or indirectly, through third parties or related entities, hormone therapy drugs, including Premarin®, Aygestin®, Premphase®, Cycrin® and Prempro®.

3. The Defendant, AHP Subsidiary Holding Corporation f/k/a Wyeth-Ayerst Laboratories Company (hereafter referred to as “Wyeth-Ayerst Labs”), is a Delaware Corporation with its principal place of business in Delaware. At all times material hereto, Wyeth-Ayerst Labs was engaged in the business of testing, developing, manufacturing, labeling, marketing, distributing, promoting, and/or selling, either directly or indirectly, through third parties or related entities, hormone therapy drugs, including Premarin®, Aygestin®, Premphase®, Cycrin® and Prempro®.

4. Defendant, Wyeth Pharmaceuticals a/k/a Wyeth Pharmaceuticals, Inc. (f/k/a Wyeth Laboratories, Inc. and Ayerst Laboratories, Inc. and hereafter referred to as “Wyeth Pharmaceuticals”), is a subsidiary or division of Wyeth, and is a Delaware corporation with its principal place of business in Pennsylvania. At all times material hereto, Wyeth Pharmaceuticals was engaged in the business of testing, developing, manufacturing, labeling, marketing, distributing, promoting, and/or selling, either directly or indirectly, through third parties or related entities, hormone therapy drugs, including Premarin®, Aygestin®, Premphase®, Cycrin® and Prempro®.

5. Defendant, Wyeth-Ayerst Pharmaceuticals, Inc. (hereafter referred to as “Wyeth-Ayerst”), is a subsidiary or division of Wyeth, and is a Delaware corporation with its principal place of business in Pennsylvania. At all times material hereto, Wyeth-Ayerst was engaged in the business of testing, developing, manufacturing, labeling, marketing, distributing, promoting, and/or selling, either directly or indirectly, through third parties or related entities, hormone therapy drugs, including Premarin®, Aygestin®, Premphase®, Cycrin® and Prempro®.

6. Defendants, Wyeth, AHP, Wyeth-Ayerst Labs, Wyeth Pharmaceuticals, and Wyeth-Ayerst, are hereafter collectively referred to as the “Wyeth Defendants.”

7. Defendant Pharmacia & Upjohn Company (hereafter “Upjohn”), is a Delaware corporation with its principal place of business in Kalamazoo, Michigan. At all times relevant hereto, Upjohn was engaged in the business of testing, developing, manufacturing, labeling, marketing, distributing, promoting, and/or selling, either directly or indirectly, through third parties or related entities hormone therapy drugs, including Estropipate (commonly referred to by its brand name, “Ogen®”), Activella®, medroxyprogesterone acetate, or MPA (commonly referred to by its brand name, “Provera®”) and other brand name and generic hormone therapy drugs (both hereafter referred to as “BG-HT Drugs”).

8. Defendant Pfizer Inc. (hereafter “Pfizer”) is a Delaware corporation with its principal place in New York. At all times relevant hereto, Pfizer was engaged in the business of testing, developing, manufacturing, labeling, marketing, distributing, promoting, and/or selling, either directly or indirectly, through third parties or related entities hormone therapy drugs, including Estropipate (commonly referred to by its brand name, “Ogen®”), Activella®, medroxyprogesterone acetate, or MPA (commonly referred to by its brand name, “Provera®”) and BG-HT Drugs.

9. Defendant Abbott Laboratories, Inc. (hereafter “Abbott”) is a Delaware corporation with its principal place of business in Illinois. At all times relevant hereto, Abbott was engaged in the business of testing, developing, manufacturing, labeling, marketing, distributing, promoting, and/or selling, either directly or indirectly, through third parties or related entities hormone therapy drugs, including Estropipate (commonly referred to by its brand name, “Ogen®”) and BG-HT Drugs.

10. Defendant Parke-Davis is a division of Pfizer with its principal place of business in New Jersey. At all times relevant hereto, Parke-Davis was engaged in the business of testing, developing, manufacturing, labeling, marketing, distributing, promoting, and/or selling, either directly or indirectly, through third parties or related entities hormone therapy drugs, including FemHRT® and BG-HT Drugs.

11. Defendants, Upjohn, Pfizer, Abbott and Parke-Davis are hereafter collectively referred to as the “Pfizer Defendants.”

12. The Defendant, Schering Corporation, a subsidiary of Schering-Plough Corporation (hereafter referred to as “Schering”), is a New Jersey corporation with its principal place of business in New Jersey. At all times material hereto, Schering was engaged in the business of testing, developing, manufacturing, labeling, marketing, distributing, promoting, and/or selling, either directly or indirectly, through third parties or related entities, hormone therapy drugs, including Estinyl® and BG-HT Drugs.

13. The Defendant, Barr Laboratories, Inc. (hereafter referred to as “Barr Labs”), is a Delaware corporation with its principal place of business in New York. At all times material hereto, Barr Labs was engaged in the business of testing, developing, manufacturing, labeling, marketing, distributing, promoting, and/or selling, either directly or indirectly, through third parties or related entities, hormone therapy drugs, including Aygestin®, medroxyprogesterone acetate, a synthetic form of progesterone (hereafter referred to as “Generic MPA”) and BG-HT Drugs.

14. The Defendant, Barr Pharmaceuticals, Inc. (hereafter referred to as “Barr Pharmaceuticals”), is a Delaware corporation with its principal place of business in New York. At all times material hereto, Barr Pharmaceuticals was engaged in the business of testing, developing, manufacturing, labeling, marketing, distributing, promoting, and/or selling, either directly or indirectly, through third parties or related entities, hormone therapy drugs, including Aygestin® and BG-HT Drugs.

15. The Defendant, Duramed Pharmaceuticals, Inc., a subsidiary of Barr Pharmaceuticals, Inc. (hereafter referred to as “Duramed”), is a Delaware corporation with its principal place of business in New York. At all times material hereto, Duramed was engaged in the business of testing, developing, manufacturing, labeling, marketing, distributing, promoting, and/or selling, either directly or indirectly, through third parties or related entities, hormone therapy drugs, including Aygestin®, Cenestin®, FemHRT®, and BG-HT Drugs.

16. Defendants, Barr Labs, Barr Pharmaceuticals and Duramed are hereafter collectively referred to as the “Barr Defendants.”

17. The Defendant, Warner Chilcott, Inc., a subsidiary of Galen Holdings PLC (hereafter referred to as “Warner Chilcott”), is a Delaware corporation with its principal place of business in New Jersey. At all times material hereto, Warner Chilcott was engaged in the business of testing, developing, manufacturing, labeling, marketing, distributing, promoting, and/or selling, either directly or indirectly, through third parties or related entities, hormone therapy drugs, including Estrace®, FemHRT® and BG-HT Drugs.

18. The Defendant, Bristol-Myers Squibb Company (hereafter referred to as “Bristol-Myers”), is a Delaware corporation with its principal place of business in New York. At all times material hereto, Bristol-Myers was engaged in the business of testing, developing, manufacturing, labeling, marketing, distributing, promoting, and/or selling, either directly or indirectly, through third parties or related entities, hormone therapy drugs, including Estrace® and BG-HT Drugs.

19. Defendants, Warner Chilcott and Bristol-Myers are hereafter collectively referred to as the “Warner Defendants.”

20. The Defendant, Qualitest Pharmaceuticals, Inc. (hereafter referred to as “Qualitest”), is an Alabama corporation with its principal place of business in Alabama. At all times material hereto, Qualitest was engaged in the business of testing, developing, manufacturing, labeling, marketing, distributing, promoting, and/or selling, either directly or indirectly, through third parties or related entities, hormone therapy drugs, including BG-HT Drugs.

21. The Defendant, Greenstone Ltd. (hereafter referred to as “Greenstone”), is a Delaware corporation with its principal place of business in Michigan. At all times material hereto, Greenstone was engaged in the business of testing, developing, manufacturing, labeling, marketing, distributing, promoting, and/or selling, either directly or indirectly, through third parties or related entities, hormone therapy drugs, including BG-HT Drugs.

22. The defendant, Mylan Pharmaceuticals, Inc. (hereafter referred to as “Mylan”), is a West Virginia corporation with its principal place of business in West Virginia. At all times material hereto, Mylan was engaged in the business of testing, developing, manufacturing, labeling, marketing, distributing, promoting, and/or selling, either directly or indirectly, through third parties or related entities, hormone therapy drugs, including BG-HT Drugs.

23. The defendant, Mylan Laboratories, Inc. (hereafter referred to as “Mylan Labs”), is a Pennsylvania corporation with its principal place of business in Pennsylvania. At all times material hereto, Mylan Labs was engaged in the business of testing, developing, manufacturing, labeling, marketing, distributing, promoting, and/or selling, either directly or indirectly, through third parties or related entities, hormone therapy drugs, including BG-HT Drugs.

24. The defendant, Watson Laboratories, Inc. (hereafter referred to as “Watson”), is a Nevada corporation with its principal place of business in California. At all times material hereto, Watson was engaged in the business of testing, developing, manufacturing, labeling, marketing, distributing, promoting, and/or selling, either directly or indirectly, through third parties or related entities, hormone therapy drugs, including BG-HT Drugs.

25. The defendant, Monarch Pharmaceuticals, Inc. (hereafter referred to as “Monarch”), is a Tennessee corporation with its principal place of business in Tennessee. At all times material hereto, Monarch was engaged in the business of testing, developing, manufacturing, labeling, marketing, distributing, promoting, and/or selling, either directly or indirectly, through third parties or related entities, hormone therapy drugs, including BG-HT Drugs.

26. The defendant, King Pharmaceuticals, Inc. (hereafter referred to as “King”), is a Tennessee corporation with its principal place of business in Tennessee. At all times material hereto, King was engaged in the business of testing, developing, manufacturing, labeling, marketing, distributing, promoting, and/or selling, either directly or indirectly, through third parties or related entities, hormone therapy drugs, including BG-HT Drugs.

27. The defendant, Organon USA, Inc. a/k/a Organon Pharmaceuticals USA, Inc. (hereafter referred to as “Organon”), is a New Jersey corporation with its principal place of business in New Jersey. At all times material hereto, Organon was engaged in the business of testing, developing, manufacturing, labeling, marketing, distributing, promoting, and/or selling, either directly or indirectly, through third parties or related entities, hormone therapy drugs, including BG-HT Drugs.

28. The defendant, Solvay Pharmaceuticals, Inc. (hereafter referred to as “Solvay”), is a Georgia corporation with its principal place of business in Georgia. At all times material hereto, Solvay was engaged in the business of testing, developing, manufacturing, labeling, marketing, distributing, promoting, and/or selling, either directly or indirectly, through third parties or related entities, hormone therapy drugs, including BG-HT Drugs.

29. The defendant, Novo Nordisk Pharmaceuticals, Inc. (hereafter referred to as “Novo Nordisk”), is a Delaware corporation with its principal place of business in New Jersey. At all times material hereto, Novo Nordisk was engaged in the business of testing, developing, manufacturing, labeling, marketing, distributing, promoting, and/or selling, either directly or indirectly, through third parties or related entities, hormone therapy drugs, including Activella® and BG-HT Drugs.

30. The defendant, Aventis Pharmaceuticals, Inc. f/k/a Hoechst Marion Roussel, Inc. a/k/a Hoechst Pharmaceuticals, Inc. (hereafter referred to as “Aventis”), is a Delaware corporation with its principal place of business in New Jersey. At all times material hereto, Aventis was engaged in the business of testing, developing, manufacturing, labeling, marketing, distributing, promoting, and/or selling, either directly or indirectly, through third parties or related entities, hormone therapy drugs, including BG-HT Drugs.

31. The Wyeth Defendants, Pfizer Defendants, Schering, Barr Defendants, Warner Defendants, Qualitest, Greenstone, Mylan, Mylan Labs, Watson, Monarch, King, Organon, Solvay, Novo Nordisk and Aventis are hereafter collectively referred to as the “Drug Defendants.”

32. Premarin®, Aygestin®, Premphase®, Cycrin®, Prempro®, Ogen®, Activella®, Provera®, Estinyl®, Cenestin®, FemHRT®, Estrace®, and BG-HT Drugs are all hereafter collectively referred to as the “HRT Drugs.”

33. The Defendant Wal-Mart Stores, Inc. (hereafter referred to as “Wal-Mart”), is a Delaware corporation with its principal place of business in Arkansas. Wal-Mart sold HRT Drugs to one or more of the Plaintiffs, and to thousands of other individuals in the regular course of its business.

34. The Defendant, Walgreens Company (hereafter referred to as “Walgreens”), is an Illinois corporation with its principal place of business in Illinois. Walgreens sold HRT Drugs to one or more of the Plaintiffs, and to thousands of other individuals in the regular course of its business.

35. The Defendant, CVS Pharmacy, Inc. (hereafter referred to as “CVS”), is a Rhode Island corporation with its principal place of business in Rhode Island. CVS sold HRT Drugs to one or more of the Plaintiffs, and to thousands of other individuals in the regular course of its business.

36. The Defendant, Costco Wholesale Corporation (hereafter referred to as “Costco”), is a Washington corporation with its principal place of business in Washington. Costco sold HRT Drugs to one or more of the Plaintiffs, and to thousands of other individuals in the regular course of its business.

37. The Defendant, Eckerd Corporation (hereafter referred to as “Eckerd”), is a Delaware corporation with its principal place of business in Florida. Eckerd sold HRT Drugs to one or more of the Plaintiffs, and to thousands of other individuals in the regular course of its business.

38. The Defendant, Thrift Drug, Inc. (hereafter referred to as “Thrift”), is a Delaware corporation with its principal place of business in Florida. Thrift sold HRT Drugs to one or more of the Plaintiffs, and to thousands of other individuals in the regular course of its business.

39. The Defendant, The Kroger Co. (hereafter referred to as “Kroger”), is an Ohio corporation with its principal place of business in Ohio. Kroger sold HRT Drugs to one or more of the Plaintiffs, and to thousands of other individuals in the regular course of its business.

40. The Defendant, Medicine Shoppe International, Inc. (hereafter referred to as “Medicine Shoppe”), is a Delaware corporation with its principal place of business in Ohio. Medicine Shoppe sold HRT Drugs to one or more of the Plaintiffs, and to thousands of other individuals in the regular course of its business.

41. The Defendant, Rite Aid Corporation (hereafter referred to as “Rite Aid”), is a Delaware corporation with its principal place of business in Pennsylvania. Rite Aid sold HRT Drugs to one or more of the Plaintiffs, and to thousands of other individuals in the regular course of its business.

42. Defendants, Wal-Mart, Walgreens, CVS, Costco, Eckerd, Thrift, Kroger, Medicine Shoppe, and Rite Aid are hereafter collectively referred to as the “Pharmacy Defendants.”

43. The Drug Defendants and Pharmacy Defendants are hereafter collectively referred to as “Defendants.”

44. This Court has personal jurisdiction over the Drug Defendants and Pharmacy Defendants pursuant to, and consistent with, RSMo. §§ 407.025 506.500, and the Constitutional requirements of Due Process in that said Defendants, acting through their agents, apparent agents, and/or independent contractors, committed one or more of the following:

a. Transacted business in the State of Missouri, RSMo. § 506.500.1(1);

b. Made or performed a contract or promise substantially connected with and/or within the State of Missouri, RSMo. § 506.500.1(2);

c. Committed, and conspired to commit, tortious acts with the State of Missouri, RSMo. § 506.500.1(3); and/or

d. Owned, used, or possessed real estate situated in the State of Missouri, RSMo. § 506.500.1(4).

Requiring Drug Defendants and Pharmacy Defendants to litigate this claim in Missouri does not offend traditional notions of fair play and substantial justice and is permitted by the United States Constitution.

45. Plaintiff, Paula Ballard, is a resident and citizen of the State of New Jersey, and resides in the County of Hunterdon. At all times relevant to this Complaint, she lived and still lives with her husband, Plaintiff, Brent L. Ballard. Beginning on or about the early 1990’s, and continuing through approximately January 30, 2002, Paula Ballard underwent hormone replacement therapy, and was prescribed and ingested drugs manufactured, marketed and sold by one or more of the Drug Defendants and/or Pharmacy Defendants. On or about January 30, 2002, Paula Ballard was diagnosed with infiltrating ductal breast cancer, and later underwent surgery consisting of a right modified radical mastectomy. The cancer and subsequent surgery, treatment, injury and damage to Paula Ballard, were caused by her use of the aforementioned drugs.

46. Plaintiff, Linda Boelk, is a resident and citizen of the State of Minnesota, and resides in the County of Koochiching. At all times relevant to this Complaint, she lived and still lives with her husband, Plaintiff, Arthur R. Boelk. Beginning on or about October 16, 1990, and continuing through approximately January 26, 1998, Linda Boelk underwent hormone replacement therapy, and was prescribed and ingested drugs manufactured, marketed and sold by one or more of the Drug Defendants and/or Pharmacy Defendants. On or about December 1, 1999, Linda Boelk was diagnosed with infiltrating ductal breast cancer, with associated ductal carcinoma in situ, and focal intramammary angiolymphatic invasion, and later underwent surgery consisting of a left mastectomy. The cancer and subsequent surgery, treatment, injury and damage to Linda Boelk, were caused by her use of the aforementioned drugs.

47. Plaintiff, Linda Bolton, is a resident and citizen of the State of Texas, and resides in the County of Angelina. At all times relevant to this Complaint, she lived and still lives with her husband, Plaintiff, Claud H. Bolton, Jr. Beginning on or about January 17, 1995, and continuing through approximately January 9, 2001, Linda Bolton underwent hormone replacement therapy, and was prescribed and ingested drugs manufactured, marketed and sold by one or more of the Drug Defendants and/or Pharmacy Defendants. On or about February 28, 2001, Linda Bolton was diagnosed with infiltrating ductal breast cancer, and later underwent surgery consisting of a left breast lumpectomy with left axillary node dissection. The cancer and subsequent surgery, treatment, injury and damage to Linda Bolton, were caused by her use of the aforementioned drugs.

48. Plaintiff, Elaine Briden, is a resident and citizen of the State of Washington, and resides in the County of Pierce. Beginning on or before 2000, and continuing through approximately February 6, 2003, Elaine Briden underwent hormone replacement therapy, and was prescribed and ingested drugs manufactured, marketed and sold by one or more of the Drug Defendants and/or Pharmacy Defendants. On or about October 31, 2003, Elaine Briden was diagnosed with invasive ductal breast cancer, and later underwent surgery consisting of a left modified radical mastectomy. The cancer and subsequent surgery, treatment, injury and damage to Elaine Briden, were caused by her use of the aforementioned drugs.

49. Plaintiff, Lynda Burchfield, is a resident and citizen of the State of Colorado, and resides in the County of Summit. At all times relevant to this Complaint, she lived and still lives with her husband, Plaintiff, John Burchfield. Beginning on or about the early 1980’s, and continuing through approximately October 5, 1998, Lynda Burchfield underwent hormone replacement therapy, and was prescribed and ingested drugs manufactured, marketed and sold by one or more of the Drug Defendants and/or Pharmacy Defendants. On or about October 5, 1998, Lynda Burchfield was diagnosed with multi-focal infiltrating ductal breast cancer, and later underwent surgery consisting of a left modified radical mastectomy. The cancer and subsequent surgery, treatment, injury and damage to Lynda Burchfield, were caused by her use of the aforementioned drugs.

50. Plaintiff, Theda Cagle, is a resident and citizen of the State of Alaska, and resides in the County of Kenai Peninsula Borough. At all times relevant to this Complaint, she lived and still lives with her husband, Plaintiff, Earl D. Cagle. Beginning in 1995 and continuing through approximately July 14, 2000, Theda Cagle underwent hormone replacement therapy, and was prescribed and ingested drugs manufactured, marketed and sold by one or more of the Drug Defendants and/or Pharmacy Defendants. On or about July 5, 2000, Theda Cagle was diagnosed with multifocal atypical lobular hyperplasia and lobular and ductal carcinoma in situ, and later underwent surgery consisting of a left modified radical mastectomy and a right simple mastectomy. The cancer and subsequent surgery, treatment, injury and damage to Theda Cagle, were caused by her use of the aforementioned drugs.

51. Plaintiff, Betsy Calma, is a resident and citizen of the State of Texas, and resides in the County of Harris. At all times relevant to this Complaint, she lived and still lives with her husband, Plaintiff, Roy D. Calma. Beginning on or about the early 1990’s, and continuing through approximately November 5, 2001, Betsy Calma underwent hormone replacement therapy, and was prescribed and ingested drugs manufactured, marketed and sold by one or more of the Drug Defendants and/or Pharmacy Defendants. On or about November 5, 2001, Betsy Calma was diagnosed with infiltrating ductal breast cancer, and later underwent surgery consisting of a bilateral mastectomy following a lumpectomy. The cancer and subsequent surgery, treatment, injury and damage to Betsy Calma, were caused by her use of the aforementioned drugs.

52. Plaintiff, Bonnie Campbell, is a resident and citizen of the State of California, and resides in the County of Tulare. Beginning on or about 1984, and continuing through approximately August 27, 2002, Bonnie Campbell underwent hormone replacement therapy, and was prescribed and ingested drugs manufactured, marketed and sold by one or more of the Drug Defendants and/or Pharmacy Defendants. On or about August 27, 2002, Bonnie Campbell was diagnosed with invasive lobular breast cancer, and later underwent surgery consisting of a left modified radical mastectomy. The cancer and subsequent surgery, treatment, injury and damage to Bonnie Campbell, were caused by her use of the aforementioned drugs.

53. Plaintiff, Cathy Coody, is a resident and citizen of the State of Georgia, and resides in the County of Bleckley. Beginning on or about May 23, 1988, and continuing through approximately June, 2002, Cathy Coody underwent hormone replacement therapy, and was prescribed and ingested drugs manufactured, marketed and sold by one or more of the Drug Defendants and/or Pharmacy Defendants. On or about May 8, 2002, Cathy Coody was diagnosed with invasive ductal breast cancer, and later underwent surgery consisting of a right breast lumpectomy and right axillary lymphadenectomy. The cancer and subsequent surgery, treatment, injury and damage to Cathy Coody, were caused by her use of the aforementioned drugs.

54. Plaintiff, Angela DiPietro, is a resident and citizen of the State of New Jersey, and resides in the County of Gloucester. Beginning on or about the early 1990’s, and continuing through approximately April, 1999, Angela DiPietro underwent hormone replacement therapy, and was prescribed and ingested drugs manufactured, marketed and sold by one or more of the Drug Defendants and/or Pharmacy Defendants. On or about April 22, 1999, Angela DiPietro was diagnosed with infiltrating ductal and lobular breast cancer, and later underwent surgery consisting of a left breast lumpectomy and axillary node dissection. The cancer and subsequent surgery, treatment, injury and damage to Angela DiPietro, were caused by her use of the aforementioned drugs.

55. Plaintiff, Brenda Ferguson, is a resident and citizen of the State of Illinois, and resides in the County of Williamson. At all times relevant to this Complaint, she lived and still lives with her husband, Plaintiff, Jeff Ferguson. Beginning on or about the early 1990’s, and continuing through approximately 2000, Brenda Ferguson underwent hormone replacement therapy, and was prescribed and ingested drugs manufactured, marketed and sold by one or more of the Drug Defendants and/or Pharmacy Defendants. On or about November 24, 2000, Brenda Ferguson was diagnosed with infiltrating breast cancer with ductal and lobular features and later underwent surgery consisting of a lumpectomy. The cancer and subsequent surgery, treatment, injury and damage to Brenda Ferguson, were caused by her use of the aforementioned drugs.

56. Plaintiff, Arnold J. Gozzi, individually and as Personal Representative of the Estate of Antoinette E. Gozzi (Deceased), is a resident and citizen of the State of New York, and resides in the County of Onondaga. Until her death, Antoinette E. Gozzi (Deceased), was a resident and citizen of the State of New York, and resided in the County of Onondaga with her husband, Arnold J. Gozzi. Beginning on or about the early 1990’s, and continuing through approximately 2002, Antoinette E. Gozzi underwent hormone replacement therapy, and was prescribed and ingested drugs manufactured, marketed and sold by one or more of the Drug Defendants and/or Pharmacy Defendants. On or about June 27, 2003, Antoinette E. Gozzi was diagnosed with adenocarcinoma of the ovary with intra-abdominal metastasis, and later underwent surgery consisting of: laparotomy, total abdominal hysterectomy, bilateral salpingo-oophorectomy, appendectomy, omentectomy, pelvic and periaortic lymph node dissection, small and large bowel biopsies and pelvic washings. She later died from complications of metastatic ovarian cancer. The cancer and subsequent surgery, treatment, injury and damage to, and death of, Antoinette E. Gozzi, were caused by her use of the aforementioned drugs.

57. Plaintiff, Leona Hamm, is a resident and citizen of the State of Ohio, and resides in the County of Guernsey. Beginning on or about the late 1990’s, and continuing through approximately April 28, 2002, Leona Hamm underwent hormone replacement therapy, and was prescribed and ingested drugs manufactured, marketed and sold by one or more of the Drug Defendants and/or Pharmacy Defendants. On or about April 19, 2002, Leona Hamm was diagnosed with invasive ductal breast cancer, and later underwent surgery consisting of a left mastectomy. The cancer and subsequent surgery, treatment, injury and damage to Leona Hamm, were caused by her use of the aforementioned drugs.

58. Plaintiff, Roma Killian, is a resident and citizen of the State of Michigan, and resides in the County of Monroe. At all times relevant to this Complaint, she lived and still lives with her husband, Plaintiff, Kenneth R. Killian. Beginning on or about 1984, and continuing through approximately November 2001, Roma Killian underwent hormone replacement therapy, and was prescribed and ingested drugs manufactured, marketed and sold by one or more of the Drug Defendants and/or Pharmacy Defendants. On or about November 21, 2001, Roma Killian was diagnosed with infiltrating ductal breast cancer, and later underwent surgery consisting of a left breast mastectomy with TRAM flap reconstruction. The cancer and subsequent surgery, treatment, injury and damage to Roma Killian, were caused by her use of the aforementioned drugs.

59. Plaintiff, Mary Ann Long, is a resident and citizen of the State of Indiana, and resides in the County of Elkhart. At all times relevant to this Complaint, she lived and still lives with her husband, Plaintiff, Richard B. Long. Beginning on or about January, 1995, and continuing through approximately May 30, 2000, Mary Ann Long underwent hormone replacement therapy, and was prescribed and ingested drugs manufactured, marketed and sold by one or more of the Drug Defendants and/or Pharmacy Defendants. On or about May 30, 2000, Mary Ann Long was diagnosed with ductal breast cancer, and later underwent surgery consisting of a lumpectomy with the removal of 15 lymph nodes. The cancer and subsequent surgery, treatment, injury and damage to Mary Ann Long, were caused by her use of the aforementioned drugs.

60. Plaintiff, Ruth Mancini, is a resident and citizen of the State of Florida, and resides in the County of Lake. Beginning on or about the early 1990’s, and continuing through approximately April, 2001, Ruth Mancini underwent hormone replacement therapy, and was prescribed and ingested drugs manufactured, marketed and sold by one or more of the Drug Defendants and/or Pharmacy Defendants. On or about January 20, 2003, Ruth Mancini was diagnosed with ductal breast cancer, and later underwent surgery consisting of a left partial mastectomy and left axillary lymphadenectomy. The cancer and subsequent surgery, treatment, injury and damage to Ruth Mancini, were caused by her use of the aforementioned drugs.

61. Plaintiff, Janet Meisenzahl is a resident and citizen of the State of New York, and resides in the County of Monroe. At all times relevant to this Complaint, she lived and still lives with her husband, Plaintiff, Nelson H. Meisenzahl. Beginning on or about the early 1990’s, and continuing through approximately September, 2001, Janet Meisenzahl underwent hormone replacement therapy, and was prescribed and ingested drugs manufactured, marketed and sold by one or more of the Drug Defendants and/or Pharmacy Defendants. On or about October 12, 2001, Janet Meisenzahl was diagnosed with ductal breast cancer, and later underwent surgery consisting of lumpectomy with removal of two (2) lymph nodes. The cancer and subsequent surgery, treatment, injury and damage to Janet Meisenzahl were caused by her use of the aforementioned drugs.

62. Plaintiff, Sandra L. Mower, is a resident and citizen of the State of Arizona, and resides in the County of Yavapai. At all times relevant to this Complaint, she lived and still lives with her husband, Plaintiff, Theron Mower. Beginning on or about 1978, Sandra L. Mower underwent hormone replacement therapy, and was prescribed and ingested drugs manufactured, marketed and sold by one or more of the Drug Defendants and/or Pharmacy Defendants. On or about June 10, 2003, Sandra L. Mower was diagnosed with infiltrating ductal breast cancer, and later underwent surgery consisting of a partial mastectomy along with sentinel lymph node mapping and biopsy. The cancer and subsequent surgery, treatment, injury and damage to Sandra L. Mower, were caused by her use of the aforementioned drugs.

63. Plaintiff, Francine S. Necowitz, is a resident and citizen of the State of New Jersey, and resides in the County of Camden. At all times relevant to this Complaint, she lived and still lives with her husband, Plaintiff, Arthur J. Necowitz. Beginning on or about 1998, Francine S. Necowitz underwent hormone replacement therapy, and was prescribed and ingested drugs manufactured, marketed and sold by one or more of the Drug Defendants and/or Pharmacy Defendants. On or about June 24, 2002, Francine S. Necowitz received an abnormal mammogram, followed by a lumpectomy on July 18, 2002, and was diagnosed with invasive well differentiated ductal breast cancer. On August 5, 2002, Francine S. Necowitz underwent a lumpectomy and lymph node biopsy, which showed metastasis to the lymph node. The cancer and subsequent surgery, biopsy, treatment, injury and damage to Francine S. Necowitz, were caused by her use of the aforementioned drugs.

64. Plaintiff, Margaret Rubin-Finn is a resident and citizen of the State of New York, and resides in the County of New York. Beginning on or about the late 1990’s, Margaret Rubin-Finn underwent hormone replacement therapy, and was prescribed and ingested drugs manufactured, marketed and sold by one or more of the Drug Defendants and/or Pharmacy Defendants. On or about June, 2002, Margaret Rubin-Finn was diagnosed with lobular and ductal breast cancer and later underwent surgery consisting of multiple lumpectomies and she likely will need to undergo a double mastectomy. The cancer and subsequent surgery, treatment, injury and damage to Margaret Rubin-Finn, were caused by her use of the aforementioned drugs.

65. Plaintiff, Deborah L. Willis is a resident and citizen of the Commonwealth of Virginia, and resides in the County of Augusta. At all times relevant to this Complaint, she lived and still lives with her husband, Plaintiff, Edgar T. Willis. Beginning on or about July 24, 2000, and continuing through approximately August, 2000, Deborah L. Willis underwent hormone replacement therapy, and was prescribed and ingested drugs manufactured, marketed and sold by one or more of the Drug Defendants and/or Pharmacy Defendants. On or about August 31, 2001, Deborah L. Willis was diagnosed with infiltrating lobular breast cancer, and later underwent surgery consisting of a right modified radical mastectomy. The cancer and subsequent surgery, treatment, injury and damage to Deborah L. Willis were caused by her use of the aforementioned drugs.

66. Plaintiff, Faye Johnson is a resident and citizen of the State of Alabama, and resides in the County of Crenshaw. At all times relevant to this Complaint, she lived and still lives with her husband, Plaintiff, Gerald E. Johnson. Beginning on or about May 9, 1997, and continuing through approximately July 5, 2002, Faye Johnson underwent hormone replacement therapy, and was prescribed and ingested drugs manufactured, marketed and sold by one or more of the Drug Defendants and/or Pharmacy Defendants. On or about June 6, 2002, Faye Johnson was diagnosed with stage II ductal cancer of the left breast with lymph node involvement and later underwent surgery consisting of a left mastectomy. She was also found to have multifocal ductal carcinoma in situ in the remaining breast. The cancer and subsequent surgery, treatment, injury and damage to Faye Johnson were caused by her use of the aforementioned drugs.

67. Plaintiff, Ruth MacDuff is a resident and citizen of the State of Pennsylvania, and resides in the County of Schuylkill. At all times relevant to this Complaint, she lived and still lives with her husband, Plaintiff, Matthew MacDuff. Beginning on or about 1989, and continuing through approximately 1998, Ruth MacDuff underwent hormone replacement therapy, and was prescribed and ingested drugs manufactured, marketed and sold by one or more of the Drug Defendants and/or Pharmacy Defendants. On or about July 20, 2000, Ruth MacDuff was diagnosed with breast cancer, and later underwent surgery consisting of a lumpectomy and right axillary node dissection. The cancer, and the subsequent, treatment, injury and damage to Ruth MacDuff were caused by her use of the aforementioned drugs.

68. Plaintiff, Gail M. Watt is a resident and citizen of New Jersey, and resides in the County of Bergen. Beginning on or about the early 1980’s, and continuing through approximately September, 2001, Gail M. Watt underwent hormone replacement therapy, and was prescribed and ingested drugs manufactured, marketed and sold by one or more of the Drug Defendants and/or Pharmacy Defendants. On or about August 13, 2003, Gail M. Watt was diagnosed with ductal breast cancer, and later underwent surgery consisting of a lumpectomy and an axillary dissection. The cancer and subsequent surgery, treatment, injury and damage to Gail M. Watt were caused by her use of the aforementioned drugs.

69. Plaintiff, Grace Jurewicz is a resident and citizen of the State of New Jersey, and resides in the County of Middlesex. At all times relevant to this Complaint, she lived and still lives with her husband, Plaintiff, Jerry Jurewicz. Beginning on or about 1990, and continuing through approximately December 30, 1999, Grace Jurewicz underwent hormone replacement therapy, and was prescribed and ingested drugs manufactured, marketed and sold by one or more of the Drug Defendants and/or Pharmacy Defendants. On or about December 30, 1999, Grace Jurewicz was diagnosed with invasive ductal breast cancer, and later underwent surgery consisting of a lumpectomy. The cancer and subsequent surgery, treatment, injury and damage to Grace Jurewicz were caused by her use of the aforementioned drugs.

70. Plaintiff, Leonie Schindler is a resident and citizen of the State of Georgia, and resides in the County of Whitfield. At all times relevant to this Complaint, she lived and still lives with her husband, Plaintiff, Fred F. Schindler. Beginning on or about the early 1980’s, and continuing through the present date, Leonie Schindler underwent hormone replacement therapy, and was prescribed and ingested drugs manufactured, marketed and sold by one or more of the Drug Defendants and/or Pharmacy Defendants. On or about June 16, 1999, Leonie Schindler was diagnosed with lobular breast cancer, and later underwent surgery consisting of a bilateral radical mastectomy. The cancer and subsequent surgery, treatment, injury and damage to Leonie Schindler were caused by her use of the aforementioned drugs.

71. Plaintiff, Dorothy Johnson is a resident and citizen of the State of Missouri, and resides in the City of St. Louis in the County of St. Louis City. At all times relevant to this Complaint, she lived and still lives with her husband, Plaintiff, Lorenzo Johnson. Beginning on or about the late 1990’s, and continuing through approximately 2002, Dorothy Johnson underwent hormone replacement therapy, and was prescribed and ingested drugs manufactured, marketed and sold by one or more of the Drug Defendants and/or Pharmacy Defendants. On or about July 30, 2002, Dorothy Johnson was diagnosed with infiltrating ductal breast cancer, and later underwent surgery consisting of a left modified radical mastectomy. The cancer and subsequent surgery, treatment, injury and damage to Dorothy Johnson were caused by her use of the aforementioned drugs.

72. Plaintiff, Ann Mullins is a resident and citizen of the State of Indiana, and resides in the County of Scott. At all times relevant to this Complaint, she lived and still lives with her husband, Plaintiff, Sambo Mullins. Beginning on or about 1994, and continuing through approximately March 31, 2000, Ann Mullins underwent hormone replacement therapy, and was prescribed and ingested drugs manufactured, marketed and sold by one or more of the Drug Defendants and/or Pharmacy Defendants. On or about April 3, 2000, Ann Mullins was diagnosed with infiltrating lobular breast cancer, and later underwent surgery consisting of a right modified radical mastectomy. The subsequent surgery, treatment, injury and damage to Ann Mullins were caused by her use of the aforementioned drugs.

73. Plaintiff, Patricia Morton is a resident and citizen of the State of Missouri, and resides in the County of Pemiscot. At all times relevant to this Complaint, she lived and still lives with her husband, Plaintiff, Joe Wallace Morton. Beginning on or about November 4, 1993, and continuing through approximately September 11, 1998, Patricia Morton underwent hormone replacement therapy, and was prescribed and ingested drugs manufactured, marketed and sold by one or more of the Drug Defendants and/or Pharmacy Defendants. On or about September 1998, Patricia Morton was diagnosed with ovarian cancer, and later underwent surgery consisting of a diagnostic laparoscopy, lysis of pelvic adhesions, lysis of adhesions, left oophorectomy, right salpingo-oophorectomy and pelvic washings. The cancer and subsequent surgery, treatment, injury and damage to Patricia Morton were caused by her use of the aforementioned drugs.

74. Plaintiff, Joyce Deloach is a resident and citizen of the State of Georgia, and resides in the County of Gwinnett. At all times relevant to this Complaint, she lived and still lives with her husband, Plaintiff, James Deloach. Beginning on or about May, 2001, and continuing through approximately April 18, 2002, Joyce Deloach underwent hormone replacement therapy, and was prescribed and ingested drugs manufactured, marketed and sold by one or more of the Drug Defendants and/or Pharmacy Defendants. On or about September 2001, Joyce Deloach was diagnosed with peripheral vascular disease and underwent a right leg amputation. At or about that same time, she also suffered a cerebrovascular accident resulting in significant loss of use of her right hand. The blood clots and stroke, and the subsequent surgery, treatment, injury and damage to Joyce Deloach were caused by her use of the aforementioned drugs.

75. Plaintiff, Patricia Cushman, is a resident and citizen of the State of Georgia, and resides in the County of Fulton. At all times relevant to this Complaint, she lived and still lives with her husband, Plaintiff, Raymond R. Cushman. Beginning on or before 1999, and continuing through approximately May 2000, Patricia Cushman underwent hormone replacement therapy, and was prescribed and ingested drugs manufactured, marketed and sold by one or more of the Defendants. On or about July 2000, Patricia Cushman was diagnosed with infiltrating ductal breast cancer and later underwent surgery consisting of bilateral mastectomies. The cancer and subsequent treatment, injury and damage to Patricia Cushman, were caused by her use of the aforementioned drugs.

76. Plaintiff, Donna Merwin is a resident and citizen of the State of New York, and resides in the County of Schoharic. At all times relevant to this Complaint, she lived and still lives with her husband, Plaintiff, Joseph Merwin. Beginning on or about the mid- to late-1990s, and continuing through approximately early 2001, Donna Merwin underwent hormone replacement therapy, and was prescribed and ingested drugs manufactured, marketed and sold by one or more of the Drug Defendants and/or Pharmacy Defendants. On or about February 2001, Donna Merwin was diagnosed with breast cancer, and later underwent surgery consisting of a lumpectomy. The cancer and subsequent surgery, treatment, injury and damage to Donna Merwin were caused by her use of the aforementioned drugs.

77. Plaintiff, Gail McClellan is a resident and citizen of the State of Maryland, and resides in the County of Washington. Beginning on or about January 1996, and continuing through approximately March 2004, Gail McClellan underwent hormone replacement therapy, and was prescribed and ingested drugs manufactured, marketed and sold by one or more of the Drug Defendants and/or Pharmacy Defendants. On or about March 2004, Gail McClellan was diagnosed with breast cancer. The cancer and subsequent treatment, injury and damage to Gail McClellan were caused by her use of the aforementioned drugs.

78. Plaintiff, Nancy Sullivan, is a resident and citizen of the State of Arizona, and resides in the County of Maricopa. Beginning on or about December 1996, and continuing through approximately 2003, Nancy Sullivan underwent hormone replacement therapy, and was prescribed and ingested drugs manufactured, marketed and sold by one or more of the Drug Defendants. On or about November 2000, Nancy Sullivan was diagnosed with gall bladder cancer and later underwent surgery consisting of laparoscopic cholecystectomy and gall stones removal. The cancer and subsequent surgery, treatment, injury and damage to Nancy Sullivan were caused by her use of the aforementioned drugs.

79. Plaintiff, Michael Mounts, individually and as Personal Representative of the Estate of Loretta Mounts (Deceased), is a resident and citizen of the State of Arizona, and resides in the County of Pinal. Until her death, Loretta Mounts (Deceased), was a resident and citizen of the State of Arizona, and resided in the County of Pinal with her husband, Michael Mounts. Beginning on or about March 1994, and continuing through approximately December 1999, Loretta Mounts (Deceased) underwent hormone replacement therapy, and was prescribed and ingested drugs manufactured, marketed and sold by one or more of the Drug Defendants. On or about December 2000, Loretta Mounts (Deceased) was diagnosed with ovarian cancer and later underwent chemotherapy and radiation treatments. The cancer and subsequent treatment, injury and damage to, and later death of, Loretta Mounts (Deceased) were caused by her use of the aforementioned drugs. Loretta Mounts died August 2002.

80. Plaintiff, Walter Mae Shurn, is a resident and citizen of the State of Texas, and resides in the County of Collin. Beginning on or about May 1990, and continuing through approximately February 2002, Walter Mae Shurn underwent hormone replacement therapy, and was prescribed and ingested drugs manufactured, marketed and sold by one or more of the Drug Defendants. On or about March 2002, Walter Mae Shurn was diagnosed with breast cancer and later underwent treatment consisting of chemotherapy and radiation treatments. The cancer and subsequent treatment, injury and damage to Walter Mae Shurn were caused by her use of the aforementioned drugs.

81. Plaintiff, Carol Anderson, is a resident and citizen of the State of Arizona, and resides in the County of Maricopa. Beginning on or about 1986, and continuing through approximately 1996, Carol Anderson underwent hormone replacement therapy, and was prescribed and ingested drugs manufactured, marketed and sold by one or more of the Drug Defendants. On or about September 1990, Carol Anderson was diagnosed with ovarian cancer and later underwent treatment. The cancer and subsequent treatment, injury and damage to Carol Anderson were caused by her use of the aforementioned drugs.

82. Plaintiff, Anna Mae Ayers, is a resident and citizen of the State of Arizona, and resides in the County of Gila. Beginning on or about 1982, and continuing through approximately 1996, Anna Mae Ayers underwent hormone replacement therapy, and was prescribed and ingested drugs manufactured, marketed and sold by one or more of the Drug Defendants. On or about January 1996, Anna Mae Ayers was diagnosed with right breast cancer and later underwent treatment and surgery consisting of chemotherapy and right mastectomy. On or about October 1997, Anna Mae Ayers was diagnosed with left breast cancer and later underwent treatment and surgery consisting of Tamoxifen, chemotherapy and left mastectomy. The cancer and subsequent surgery, treatment, injury and damage to Anna Mae Ayers were caused by her use of the aforementioned drugs.

83. Plaintiff, Dorothy Hull, is a resident and citizen of the State of Arizona, and resides in the County of Maricopa. Beginning on or about 1984, and continuing through approximately 2003, Dorothy Hull underwent hormone replacement therapy, and was prescribed and ingested drugs manufactured, marketed and sold by one or more of the Drug Defendants. On or about July 2003, Dorothy Hull was diagnosed with breast cancer, on December 2002, Dorothy Hull was diagnosed with myocardial infarction, and in the Fall of 2002, Dorothy Hull was diagnosed with congestive heart failure, and underwent treatment for each of these conditions. These conditions and the subsequent treatment, injury and damage to Dorothy Hull were caused by her use of the aforementioned drugs.

84. Plaintiff, Norma Maxfield, is a resident and citizen of the State of Arizona, and resides in the County of Maricopa. Beginning on or about 1976, and continuing through approximately December 2001, Norma Maxfield underwent hormone replacement therapy, and was prescribed and ingested drugs manufactured, marketed and sold by one or more of the Drug Defendants. On or about January 2002, Norma Maxfield was diagnosed with breast cancer and later underwent treatment consisting of lumpectomy and radiation treatments. The cancer and subsequent surgery, treatment, injury and damage to Norma Maxfield were caused by her use of the aforementioned drugs.

85. Plaintiff, Maxine Howard, is a resident and citizen of the State of Arizona, and resides in the County of Maricopa. Beginning on or about 1997, and continuing through approximately 2002, Maxine Howard underwent hormone replacement therapy, and was prescribed and ingested drugs manufactured, marketed and sold by one or more of the Drug Defendants. On or about July 2002, Maxine Howard was diagnosed with breast cancer and later underwent treatment consisting of lumpectomy, radiation and Tamoxifen. The cancer and subsequent surgery, treatment, injury and damage to Maxine Howard were caused by her use of the aforementioned drugs.

86. Plaintiff, Lucy Garcia, is a resident and citizen of the State of Arizona, and resides in the County of Maricopa. At all times relevant to this Complaint, she lived and still lives with her husband, Plaintiff, Salvador Garcia. Beginning on or about 1990, and continuing through approximately 2001, Lucy Garcia underwent hormone replacement therapy, and was prescribed and ingested drugs manufactured, marketed and sold by one or more of the Drug Defendants. On or about March 2002, Lucy Garcia was diagnosed with breast cancer and later underwent surgery and treatment consisting of lumpectomy, mastectomy, reconstruction and Tamoxifen. The cancer and subsequent surgery, treatment, injury and damage to Lucy Garcia were caused by her use of the aforementioned drugs.

87. Plaintiff, Deanna Louderback, is a resident and citizen of the State of Washington, and resides in the County of Benton. Beginning on or about 1985, and continuing through approximately 1991, Deanna Louderback underwent hormone replacement therapy, and was prescribed and ingested drugs manufactured, marketed and sold by one or more of the Drug Defendants. On or about November 2002, Deanna Louderback was diagnosed with ductal breast cancer and later underwent surgery consisting of biopsy, partial mastectomy, radiation and Tamoxifen. The cancer and subsequent surgery, treatment, injury and damage to Louderback were caused by her use of the aforementioned drugs.

88. Plaintiff, Janice Walrod, is a resident and citizen of the State of Arizona, and resides in the County of Maricopa. Beginning on or about 1992, and continuing through approximately 1998, Janice Walrod underwent hormone replacement therapy, and was prescribed and ingested drugs manufactured, marketed and sold by one or more of the Drug Defendants. On or about February 2000, Janice Walrod was diagnosed with breast cancer and later underwent surgery and treatment consisting of lumpectomy, chemotherapy, radiation and Tamoxifen. The cancer and subsequent surgery, treatment, injury and damage to Janice Walrod were caused by her use of the aforementioned drugs.

89. Plaintiff, Doris Ganzy, is a resident and citizen of the State of Arizona, and resides in the County of Maricopa. At all times relevant to this Complaint, she lived and still lives with her husband, Plaintiff, John Ganzy. Beginning on or about 1978, and continuing through approximately 1988, Doris Ganzy underwent hormone replacement therapy, and was prescribed and ingested drugs manufactured, marketed and sold by one or more of the Drug Defendants. On or about 1989, Doris Ganzy was diagnosed with breast cancer and blood clots and later underwent surgery consisting of a mastectomy. The cancer and subsequent surgery, treatment, injury and damage to Doris Ganzy were caused by her use of the aforementioned drugs.

90. Plaintiff, Nancy Andrews, is a resident and citizen of the State of Arizona, and resides in the County of Maricopa. Beginning on or about 1994, and continuing through approximately 2001, Nancy Andrews underwent hormone replacement therapy, and was prescribed and ingested drugs manufactured, marketed and sold by one or more of the Drug Defendants. On or about March 2001, Nancy Andrews was diagnosed with ductal breast cancer and later underwent surgery consisting of lumpectomy. The cancer and subsequent surgery, treatment, injury and damage to Nancy Andrews were caused by her use of the aforementioned drugs.

91. Plaintiff, Judy Melendez, is a resident and citizen of the State of Arizona, and resides in the County of Maricopa. Beginning on or about the early 1980’s, and continuing through approximately 1997, Judy Melendez underwent hormone replacement therapy, and was prescribed and ingested drugs manufactured, marketed and sold by one or more of the Drug Defendants. On or about 1997, Judy Melendez was diagnosed with breast cancer and later underwent surgery consisting of a mastectomy. The cancer and subsequent surgery, treatment, injury and damage to Judy Melendez were caused by her use of the aforementioned drugs.

92. Plaintiff, Anthony Sbrocchi (Son), Personal Representative of the Estate of Filomena Sbrocchi (Deceased), is a resident and citizen of the State of Arizona, and resides in the County of Maricopa. Until her death, Filomena Sbrocchi (Deceased), was a resident and citizen of the State of Arizona, and resided in the County of Maricopa. Beginning on or about 1993, and continuing through approximately 1995-1996, Filomena Sbrocchi underwent hormone replacement therapy, and was prescribed and ingested drugs manufactured, marketed and sold by one or more of the Drug Defendants. On or about November 1998, Filomena Sbrocchi was diagnosed with ovarian cancer and later underwent surgery consisting of hysterectomy and chemotherapy. Filomena Sbrocchi died November 2, 2003, of metastatic ovarian cancer. The cancer and subsequent surgery, treatment, injury and damage to, and death of, Filomena Sbrocchi were caused by her use of the aforementioned drugs.

93. Plaintiff, Marilyn Carll, is a resident and citizen of the State of Arizona, and resides in the County of Maricopa. Beginning on or about 1995, and continuing through approximately 2001, Marilyn Carll underwent hormone replacement therapy, and was prescribed and ingested drugs manufactured, marketed and sold by one or more of the Drug Defendants. On or about Aug/Sept. 2001, Marilyn Carll was diagnosed with breast cancer, vulvar cancer and blood clots and later underwent surgery consisting of a lumpectomy. The cancer and subsequent surgery, treatment, injury and damage to Marilyn Carll were caused by her use of the aforementioned drugs.

94. Plaintiff, Betty Synegal, is a resident and citizen of the State of Arizona, and resides in the County of Maricopa. Beginning on or about 1983, and continuing through approximately November 2003, Betty Synegal underwent hormone replacement therapy, and was prescribed and ingested drugs manufactured, marketed and sold by one or more of the Drug Defendants. On or about November 2003, Betty Synegal was diagnosed with breast cancer and later underwent treatment consisting of chemotherapy. The cancer and subsequent treatment, injury and damage to Betty Synegal were caused by her use of the aforementioned drugs.

95. Plaintiff, Linda Suter, is a resident and citizen of the State of Arizona, and resides in the County of Maricopa. Beginning on or about 1970-1971, and continuing through approximately 1996, Linda Suter underwent hormone replacement therapy, and was prescribed and ingested drugs manufactured, marketed and sold by one or more of the Drug Defendants. On or about October 1996, Linda Suter was diagnosed with breast cancer and later underwent surgery consisting of partial mastectomy, lymphadectomy, radiation and Tamoxifen. The cancer and subsequent surgery, treatment, injury and damage to Linda Suter were caused by her use of the aforementioned drugs.

96. Plaintiff, Tonya Warner, is a resident and citizen of the State of Arizona, and resides in the County of Yavapai. Beginning on or about 1995, and continuing through approximately 2002, Tonya Warner underwent hormone replacement therapy, and was prescribed and ingested drugs manufactured, marketed and sold by one or more of the Drug Defendants. On or about March 2002, Tonya Warner was diagnosed with ovarian cancer and later underwent surgery consisting of a hysterectomy in April 2002 and additional surgery on or about October 2002. The cancer and subsequent surgery, treatment, injury and damage to Tonya Warner, were caused by her use of the aforementioned drugs.

97. Plaintiff, Jean Paradis, is a resident and citizen of the State of Colorado, and resides in the County of Mesa. Beginning on or about 1986, and continuing through approximately March 2001, Jean Paradis underwent hormone replacement therapy, and was prescribed and ingested drugs manufactured, marketed and sold by one or more of the Drug Defendants. On or about March 2001, Jean Paradis was diagnosed with breast cancer and later underwent treatment consisting of taking the medication Tamoxifen. The cancer and subsequent treatment, injury and damage to Jean Paradis, were caused by her use of the aforementioned drugs.

98. Plaintiff, Linda Stamper, is a resident and citizen of the State of Arizona, and resides in the County of Maricopa. At all times relevant to this Complaint, she lived and still lives with her husband, Plaintiff, Hugh E. Stamper. Beginning on or about early 1990, and continuing through approximately 1999, Linda Stamper underwent hormone replacement therapy, and was prescribed and ingested drugs manufactured, marketed and sold by one or more of the Drug Defendants. On or about May 1999, Linda Stamper was diagnosed with breast cancer and later underwent surgery consisting of a radical mastectomy and Tamoxifen medication. The cancer and subsequent surgery and injury to Linda Stamper, were caused by her use of the aforementioned drugs.

99. Plaintiff, Darylle D. Willenbrock, is a resident and citizen of the State of Connecticut, and resides in the County of Litchfield. At all times relevant to this Complaint, she lived and still lives with her husband, Plaintiff, Theodore E. Willenbrock. Beginning in or about July 1995, and continuing through approximately August 2002, Darylle D. Willenbrock underwent hormone replacement therapy, and was prescribed and ingested drugs manufactured, marketed and sold by one or more of the Drug Defendants and/or Pharmacy Defendants. On or about August 2002, Darylle D. Willenbrock was diagnosed with intraductal and invasive ductal breast cancer, and subsequently underwent surgery consisting of a lumpectomy followed by a right modified radical mastectomy. The subsequent surgery, treatment, injury and damage to Darylle D. Willenbrock were caused by her use of the aforementioned drugs.

100. Plaintiff, Elby F. Rogers, Sr., individually and as Personal Representative of the Estate of Charlotte D. Rogers, is a resident and citizen of the State of Delaware, and resides in the County of New Castle. Until her death, Charlotte D. Rogers (Deceased), was a resident and citizen of the State of Delaware, and resided in the County of New Castle with her husband, Elby F. Rogers, Sr. Beginning on or about 1995, and continuing through approximately October 10, 2003, Charlotte D. Rogers underwent hormone replacement therapy, and was prescribed and ingested drugs manufactured, marketed and sold by one or more of the Drug Defendants and/or Pharmacy Defendants. Charlotte D. Rogers switched to Prempro beginning on or about October 10, 2003 and continued taking Prempro through approximately November 21, 2003. On or about November 21, 2003, Charlotte D. Rogers was diagnosed with a pulmonary embolism, and was hospitalized and given blood thinners. She later died of pulmonary embolism, anoxic brain injury and cardiopulmonary arrest. The pulmonary embolism and subsequent treatment, injury and damage to, and death of, Charlotte D. Rogers, were caused by her use of the aforementioned drugs.

101. Plaintiff, Marilyn Billeau, is a resident and citizen of the State of Missouri, and resides in the City of St. Louis in the County of St. Louis. At all times relevant to this Complaint, she lived and still lives with her husband, Plaintiff, William L. Billeau. Beginning on or about November 1994, and continuing through approximately March 2001, Marilyn Billeau underwent hormone replacement therapy, and was prescribed and ingested drugs manufactured, marketed and sold by one or more of the Drug Defendants and/or Pharmacy Defendants. On or about March 24, 2001, Marilyn Billeau was diagnosed with invasive lobular adenocarcinoma and low grade intraductal carcinoma in the right breast; high grade intraductal adenocarcinoma and invasive lobular carcinoma in left breast, and later underwent surgery consisting of a double radical mastectomy. The cancer and subsequent surgery, treatment, injury and damage to Marilyn Billeau, were caused by her use of the aforementioned drugs.

102. Plaintiff, Barbara Liberman, is a resident and citizen of the State of Missouri, and resides in the City of St. Louis in the County of St. Louis. Beginning on or about March 1996, and continuing through approximately October 17, 2002, Barbara Liberman underwent hormone replacement therapy, and was prescribed and ingested drugs manufactured, marketed and sold by one or more of the Drug Defendants and/or Pharmacy Defendants. On or about October 25, 2002, Barbara Liberman was diagnosed with invasive lobular breast cancer, and later underwent surgery consisting of a left radical mastectomy with sentinel lymph node dissection. The cancer and subsequent surgery, treatment, injury and damage to Barbara Liberman, were caused by her use of the aforementioned drugs.

103. Plaintiff, Loretta Patten, is a resident and citizen of the State of Missouri, and resides in the County of St. Louis. Beginning on or about April 1994, and continuing through approximately September 28, 2001, Loretta Patten underwent hormone replacement therapy, and was prescribed and ingested drugs manufactured, marketed and sold by one or more of the Drug Defendants and/or Pharmacy Defendants. On or about November 28, 2001, Loretta Patten was diagnosed with infiltrating lobular breast cancer, and later underwent surgery consisting of a lumpectomy with sentinel lymph node dissection. The cancer and subsequent surgery, treatment, injury and damage to Loretta Patten, were caused by her use of the aforementioned drugs.

104. Plaintiff, Lucille Richardson, is a resident and citizen of the State of Kentucky, and resides in the County of Lincoln. At all times relevant to this Complaint, she lived and still lives with her husband, Plaintiff, Howard Clifton Richardson. Beginning on or about July 1, 1997, and continuing through approximately April 29, 2003, Lucille Richardson underwent hormone replacement therapy, and was prescribed and ingested drugs manufactured, marketed and sold by one or more of the Drug Defendants and/or Pharmacy Defendants. On or about January 1, 1999, Lucille Richardson was diagnosed with cholecystitis, and later underwent surgery consisting of a cholecystectomy. In March, 2003, Lucille Richardson was diagnosed with a thromboembolism, and later underwent catheterization to dissolve the aforementioned condition. On or about April 15, 2003 Lucille Richardson was diagnosed with a myocardial infarction, and later underwent surgery to insert a stent. On or about August 12, 2003, Lucille Richardson was diagnosed with lobular carcinoma in situ and tubular carcinoma with ductal involvement, and later underwent surgery consisting of a right radical mastectomy. The cholecystitis, thromboembolism, myocardial infarction, cancer and subsequent surgery, treatment, injury and damage to Lucille Richardson, were caused by her use of the aforementioned drugs.

105. Plaintiff, June Seaton, is a resident and citizen of the State of Missouri, and resides in the County of St. Louis. Beginning on or about mid-1996, and continuing through approximately December 2002, June Seaton underwent hormone replacement therapy, and was prescribed and ingested drugs manufactured, marketed and sold by one or more of the Drug Defendants and/or Pharmacy Defendants. On or about January 27, 2003, June Seaton was diagnosed with lobular carcinoma in situ and infiltrating ductal carcinoma, and later underwent surgery consisting of a lumpectomy with sentinel lymph node dissection. The cancer and subsequent surgery, treatment, injury and damage to June Seaton, were caused by her use of the aforementioned drugs.

106. Plaintiff, Beverly Weatherspoon, is a resident and citizen of the State of Kansas, and resides in the County of Wyandotte. At all times relevant to this Complaint, she lived and still lives with her husband, Plaintiff, Larry Weatherspoon. Beginning on or about March 6, 1998, and continuing through approximately November 1, 2002, Beverly Weatherspoon underwent hormone replacement therapy, and was prescribed and ingested drugs manufactured, marketed and sold by one or more of the Drug Defendants and/or Pharmacy Defendants. On or about July 2003, Beverly Weatherspoon was diagnosed with ductal carcinoma in situ, and later underwent surgery consisting of a modified mastectomy with sentinel lymph node dissection. The cancer and subsequent surgery, treatment, injury and damage to Beverly Witherspoon, were caused by her use of the aforementioned drugs.

107. Plaintiff, Lois Barg, is a resident and citizen of the State of Missouri, and resides in the City of St. Louis in the County of St. Louis. Beginning on or about September 1994, and continuing through approximately July 2002, Lois Barg underwent hormone replacement therapy, and was prescribed and ingested drugs manufactured, marketed and sold by one or more of the Drug Defendants and/or Pharmacy Defendants. In January 2002, Lois Barg suffered a myocardial infarction. On or about August 14, 2002, Lois Barg was diagnosed with infiltrating intraductal carcinoma, and later underwent surgery consisting of a lumpectomy with sentinel lymph node dissection. The myocardial infarction, cancer and subsequent surgery, treatment, injury and damage to Lois Barg, were caused by her use of the aforementioned drugs.

108. Plaintiff, Connie Sides, is a resident and citizen of the State of Kansas, and resides in the County of Wyandotte. At all times relevant to this Complaint, she lived and still lives with her husband, Plaintiff, Sammie L. Sides. Beginning on or about 1995, and continuing through approximately 2002, Connie Sides underwent hormone replacement therapy, and was prescribed and ingested drugs manufactured, marketed and sold by one or more of the Drug Defendants and/or Pharmacy Defendants. On or about August 13, 2002, Connie Sides was diagnosed with infiltrating lobular carcinoma, and later underwent surgery consisting of a mastectomy with sentinel lymph node biopsy. The cancer and subsequent surgery, treatment, injury and damage to Connie Sides, were caused by her use of the aforementioned drugs.

109. Plaintiff, Brenda Berman, is a resident and citizen of the State of Arizona, and resides in the County of Maricopa. At all times relevant to this Complaint, she lived and still lives with her husband, Plaintiff, Barry J. Berman. Beginning on or about 1995, and continuing through approximately 2001, Brenda Berman underwent hormone replacement therapy, and was prescribed and ingested drugs manufactured, marketed and sold by one or more of the Drug Defendants and/or Pharmacy Defendants. On or about September 25, 2001, Brenda Berman was diagnosed with infiltrating ductal carcinoma in the right breast, and later underwent surgery consisting of a lumpectomy with sentinel lymph node biopsy. The cancer and subsequent surgery, treatment, injury and damage to Brenda Berman, were caused by her use of the aforementioned drugs.

110. Plaintiff, Margaret Bickel, is a resident and citizen of the State of Kentucky, and resides in the County of Clinton. At all times relevant to this Complaint, she lived and still lives with her husband, Plaintiff, James R. Bickel. Beginning on or about June 1996, and continuing through approximately April 2001, Margaret Bickel underwent hormone replacement therapy, and was prescribed and ingested drugs manufactured, marketed and sold by one or more of the Drug Defendants and/or Pharmacy Defendants. On or about April 26, 2001, Margaret Bickel was diagnosed with intraductal carcinoma in the right breast, and later underwent surgery consisting of a lumpectomy. The cancer and subsequent surgery, treatment, injury and damage to Margaret Bickel, were caused by her use of the aforementioned drugs.

111. Plaintiff, Cornelia Hobley, is a resident and citizen of the State of Texas and resides in the County of Harris. At all times relevant to this Complaint, she lived and still lives with her husband, Plaintiff, Charles W. Hobley. Beginning on or about July 1996, and continuing through approximately June 2002, Cornelia Hobley underwent hormone replacement therapy, and was prescribed and ingested drugs manufactured, marketed and sold by one or more of the Drug Defendants and/or Pharmacy Defendants. On or about June 21, 2002, Cornelia Hobley was diagnosed with invasive ductal adenocarcinoma in her right breast, and later underwent surgery consisting of a double radical mastectomy. The cancer and subsequent surgery, treatment, injury and damage to Cornelia Hobley, were caused by her use of the aforementioned drugs.

112. Plaintiff, Catherine Kennon, is a resident and citizen of the State of Missouri and resides in the City of St. Louis in the County of St. Louis. Beginning on or about October 13, 1999, and continuing through approximately July 2003, Catherine Kennon underwent hormone replacement therapy, and was prescribed and ingested drugs manufactured, marketed and sold by one or more of the Drug Defendants and/or Pharmacy Defendants. On or about March 2004, Catherine Kennon was diagnosed with infiltrating ductal carcinoma of the right breast, and later underwent surgery consisting of a lumpectomy with sentinel lymph node biopsy which was positive for metastatic disease. The cancer and subsequent surgery, treatment, injury and damage to Catherine Kennon, were caused by her use of the aforementioned drugs.

113. Plaintiff, Evelyn M. Ross, is a resident and citizen of the State of Texas and resides in the County of Harris. Beginning on or about 1996, and continuing through approximately 2002, Evelyn M. Ross underwent hormone replacement therapy, and was prescribed and ingested drugs manufactured, marketed and sold by one or more of the Drug Defendants and/or Pharmacy Defendants. On or about November 2002, Evelyn M. Ross was diagnosed with cancer of the right breast, and later underwent surgery consisting of a left radical mastectomy. On or about January 2004, Evelyn M. Ross was diagnosed with cancer of the left breast, and later underwent surgery consisting of a right modified mastectomy. The cancer and subsequent surgery, treatment, injury and damage to Evelyn M. Ross, were caused by her use of the aforementioned drugs.

114. Plaintiff, Deborah Branson, is a resident and citizen of the State of New Jersey, and resides in the County of Burlington. Beginning on or about October 8, 1997, and continuing through approximately May 17, 2002, Deborah Branson underwent hormone replacement therapy, and was prescribed and ingested drugs manufactured, marketed and sold by one or more of the Drug Defendants and/or Pharmacy Defendants. On or about May 17, 2002, Deborah Branson was diagnosed with lobular breast cancer, and later underwent surgery consisting of a left breast mastectomy and lymphectomy. The cancer and subsequent surgery, treatment, injury and damage to Deborah Branson, were caused by her use of the aforementioned drugs.

115. Plaintiff, Aecha Wilson, is a resident and citizen of the State of Oklahoma, and resides in the County of Oklahoma. Beginning on or about November 1994, and continuing through approximately August 1, 2000, Aecha Wilson underwent hormone replacement therapy, and was prescribed and ingested drugs manufactured, marketed and sold by one or more of the Drug Defendants and/or Pharmacy Defendants. On or about June 13, 2000, Aecha Wilson was diagnosed with infiltrating ductal carcinoma, and later underwent surgery consisting of a mastectomy. The cancer and subsequent surgery, treatment, injury and damage to Aecha Wilson, were caused by her use of the aforementioned drugs.

116. Plaintiff, Judy Shephard, is a resident and citizen of the State of Oklahoma, and resides in the County of Oklahoma. Beginning on or about February 1996, and continuing through approximately July 2000, Judy Shephard underwent hormone replacement therapy, and was prescribed and ingested drugs manufactured, marketed and sold by one or more of the Drug Defendants and/or Pharmacy Defendants. On or about July 2000, Judy Shephard was diagnosed with lobular breast cancer, and later underwent surgery consisting of a double mastectomy. The cancer and subsequent surgery, treatment, injury and damage to Judy Shephard, were caused by her use of the aforementioned drugs.

117. Plaintiff, Molena Roberts, is a resident and citizen of the State of Georgia, and resides in the County of Putnam. Beginning in approximately 1985, and continuing through approximately May 3, 2001, Molena Roberts underwent hormone replacement therapy, and was prescribed and ingested drugs manufactured, marketed and sold by one or more of the Drug Defendants and/or Pharmacy Defendants. On or about May 3, 2001, Molena Roberts was diagnosed with lobular breast cancer, and later underwent surgery consisting of a mastectomy. The cancer and subsequent surgery, treatment, injury and damage to Molena Roberts, were caused by her use of the aforementioned drugs.

118. Plaintiff, Gayle Ulmer, is a resident and citizen of the State of Alabama, and resides in the County of Monroe. Beginning in approximately 1996, and continuing through approximately September 27, 2002, Gayle Ulmer underwent hormone replacement therapy, and was prescribed and ingested drugs manufactured, marketed and sold by one or more of the Drug Defendants and/or Pharmacy Defendants. On or about September 27, 2002, Gayle Ulmer was diagnosed with infiltrating ductal carcinoma, and later underwent surgery consisting of a lumpectomy. The cancer and subsequent surgery, treatment, injury and damage to Gayle Ulmer, were caused by her use of the aforementioned drugs.

119. Plaintiff, Bonnie Johnson, is a resident and citizen of the State of Utah, and resides in the County of Utah. Beginning in approximately 1989, and continuing through approximately October 1998, Bonnie Johnson underwent hormone replacement therapy, and was prescribed and ingested drugs manufactured, marketed and sold by one or more of the Drug Defendants and/or Pharmacy Defendants. On or about October 1998, Bonnie Johnson was diagnosed with breast cancer, and later underwent surgery consisting of a lumpectomy and a mastectomy. The cancer and subsequent surgery, treatment, injury and damage to Bonnie Johnson, were caused by her use of the aforementioned drugs.

120. Plaintiff, Mary Bradley, is a resident and citizen of the State of Tennessee, and resides in the County of Wilson. Beginning on or about November, 14, 1995, and continuing through approximately August 11, 2003, Mary Bradley underwent hormone replacement therapy, and was prescribed and ingested drugs manufactured, marketed and sold by one or more of the Drug Defendants and/or Pharmacy Defendants. On or about August 11, 2003, Mary Bradley was diagnosed with infiltrating ductal carcinoma, and later underwent surgery consisting of a lumpectomy. The cancer and subsequent surgery, treatment, injury and damage to Mary Bradley, were caused by her use of the aforementioned drugs.

121. Plaintiff, Maureen Everett, is a resident and citizen of the State of Missouri, and resides in the County of St. Louis. Beginning on or about July 11, 1997, and continuing through approximately November 12, 2001, Maureen Everett underwent hormone replacement therapy, and was prescribed and ingested drugs manufactured, marketed and sold by one or more of the Drug Defendants and/or Pharmacy Defendants. On or about December 7, 2001, Maureen Everett was diagnosed with invasive adenocarcinoma and intraductal carcinoma of the left breast, and later underwent surgery consisting of a radical mastectomy. The cancer and subsequent surgery, treatment, injury and damage to Maureen Everett, were caused by her use of the aforementioned drugs.

122. Plaintiff, Linda Stroh, is a resident and citizen of the State of Missouri, and resides in the County of Franklin. At all times relevant to this Complaint, she lived and still lives with her husband, Plaintiff, Juan Stroh. Beginning on or about June 12, 1998, and continuing through approximately September 4, 2001, Linda Stroh underwent hormone replacement therapy, and was prescribed and ingested drugs manufactured, marketed and sold by one or more of the Drug Defendants and/or Pharmacy Defendants. On or about September 17, 2002, Linda Stroh was diagnosed with ductal carcinoma in situ, and lobular carcinoma in situ of the right breast, and later underwent surgery consisting of a right breast lumpectomy. The cancer and subsequent surgery, treatment, injury and damage to Linda Stroh, were caused by her use of the aforementioned drugs.

123. Plaintiff, Susan Kay Grosor, is a resident and citizen of the State of Nebraska, and resides in the County of York. At all times relevant to this Complaint, she lived and still lives with her husband, Plaintiff, Jerry Grosor. Beginning on or about December 2, 1997, and continuing through approximately August, 2003, Susan Kay Grosor underwent hormone replacement therapy, and was prescribed and ingested drugs manufactured, marketed and sold by one or more of the Drug Defendants and/or Phar