ANAPOL, SCHWARTZ, WEISS,
COHAN LEVIN FISHBEIN SEDRAN
FELDMAN & SMALLEY, P.C. AND BERMAN
BY: SOL H. WEISS, ESQUIRE BY: ARNOLD LEVIN,
ESQUIRE
I.D. NO. 15925 I.D.
NO. 02280
1900 DELANCEY PLACE 510
WALNUT STREET SUITE 500
PHILADELPHIA, PA 19103-6690 PHILADELPHIA,
PA 19106
(215) 735-1130; FAX (215)
735-2024 (215)
592-1500
GREITZER & LOCKS
BY: LEE BALEFSKY, ESQUIRE
I.D. NO. 25321
1500 WALNUT STREET, 20TH FLOOR
PHILADELPHIA, PA 19103
(215) 893-0100
PLAINTIFFS’ LIAISON COUNSEL
_____________________________________________________
IN THE COURT OF COMMON PLEAS
PHILADELPHIA COUNTY, CIVIL TRIAL
DIVISION
IN RE: BAYCOL LITIGATION : NOVEMBER TERM, 2001
IN THE PHILADELPHIA COURT :
OF COMMON PLEAS : MASTER DOCKET NO. 0001
_____________________________________________________
PLAINTIFFS’ INTERROGATORIES
(MASTER SET)
TO DEFENDANTS WARNER LAMBERT,
PARKE DAVIS & PFIZER
Pursuant to Rule 4005 et seq. of
the Pennsylvania Rules of Civil Procedure, the plaintiffs propound the
following interrogatories to the Defendants, to be answered separately and
fully, in writing, and under oath as prescribed by the Rules, within 30 days,
or at such other time as ordered by the Court.
INSTRUCTIONS
1. Each Interrogatory refers to information in the custody,
control, and possession of the defendants, or known to the defendants, as well
as in the custody, control, and possession of or known to Defendants’ counsel,
representatives, agents, servants, investigators, consultants, and other third
parties retained by the defendants, and their counsel, employees,
representatives, agents, servants, investigators and consultants.
2. If there is a claim of privilege with respect to any
document requested, the defendant shall:
(a) Identify in its Answer each document for which a privilege is
claimed;
(b) A description of the document;
(c) The date of the document;
(d) The names of the addressees and addressors;
(e) The identity and address of every person to whom a copy was
given or communicated;
(f) The general subject matter of the document;
(g) A statement of the facts constituting the basis for any claim
of privilege; and,
(h) The specific basis on which the privilege is claimed.
3. When asked to identify a person, or if the response involves
a person, for each person please state the full name, business title, and the
current and/or last known home and business addresses and telephone numbers.
4. When asked to identify a communication, or if an answer
involves a communication, for each communication please state the parties to
the communication, the nature of the communication (e.g., written, oral, and/
or recorded), witnesses to the communication, and the substance of the
communication.
5. When asked to identify a document, or when an answer
involves a document, please state the person who wrote, composed or created the
document, the intended recipients, the date originated, the date sent, the date
received, all persons having copies of the document, and the subject matter and
content. In lieu of identifying a document, a copy of the document can be
attached to these responses.
6. For each Interrogatory, identify any persons providing
information, and state whether the response is based on the personal knowledge
of the person providing the information. If the response is not based on the
personal knowledge of the person providing the information, identify the
sources (e.g. persons and/or documents) of that information.
7. If information contrary to that provided in an answer was
provided by any person to the person providing the answer, or to your
attorneys, identify each person, providing conflicting information, state the
conflicting information, and state the reasons the conflicting information was
not relied upon.
8. For each answer, identify all documents that you believe
support your response.
9. If in the course of this litigation you have produced, or
will produce, documents or exhibits that are not covered in the categories
listed in the Plaintiffs’ Request for Production of Documents, please, with
respect to each of those documents, identify each by Bates number and/or by any
other appropriate description.
10. These interrogatories shall be deemed continuing, to the full
extent required or permitted under the Pennsylvania Rule of Civil Procedure, so
as to require supplementary responses as soon as practical after you receive
information which renders any of your answers to these interrogatories
incomplete or inaccurate.
DEFINITIONS
1.
“Defendant”,
“You” and “Your” refers to every corporation, person, or entity upon which
plaintiffs serve these discovery requests, (including, but not limited to,
every manufacturer, marketer, distributor or developer of Gemfibrozil and/or
Lopid, as defined below). “Defendant”, “You” and “Your” includes every
predecessor in interest of each such company, each of its successors in
interest, and every company affiliated with each such company by common
ownership or control
2.
The term,
“Lopid,” refers to Gemfibrozil and/or Lopid.
3.
AFDA@ means the United States Food & Drug
Administration, any committee, subcommittee or advisory committee thereto, and
any person, employee or agent acting as a representative thereof.
4.
AForeign
Government Regulatory Authority@
means any agency, committee, subcommittee or advisory committee of any
government other than the United States of America, which bears responsibility
or exercises authority over the manufacture, distribution, labeling, sale
and/or marketing of pharmaceutical products or human health in any
jurisdiction, and any employee or agent acting as a representative thereof.
5.
The term
“person” is used in its broadest possible sense and includes a natural person,
corporation, firm, association, organization, business, trust, corporation,
governmental or other public entity.
6.
The term
“document” or any similar term is used in its broadest possible sense and shall
include, but is not limited to any original, reproduction or copy, and
nonidentical copy (i.e., copy with marginal notes, deletions, etc.) of any kind
of written, printed, typed, electronically created or stored, or other graphic
matter of any type, documentary material, or drafts thereof. Such “document(s)”
shall include, but are not limited to, any correspondence, memoranda,
interoffice or intra-office communications, notes, diaries, journals,
calendars, contract documents, publications, calculations, estimates, vouchers,
minutes of meetings, invoices, reports, studies, computer tapes, computer
disks, computer cards, computer files, e-mails, photographs, negatives, slides,
dictation belts, voice tapes, telegrams, notes of telephone conversations and
notes of any oral communications.
7.
The term
“communication” is used in its broadest sense and refers to any oral, written,
video, photographic, or other means utilized to express an idea, thought, or
information from one person to another, or among persons.
8.
The relevant
time period is 1992 to the present.
1. State
the corporate name of Defendant, any name under which Defendant does business,
where the Defendant is incorporated, and where the defendant’s principle place
of business is located.
ANSWER:
2. State
the full corporate name and principal address of each entity with whom you are
affiliated through common ownership and control. With respect to each such
entity, describe its past and present role in connection with the design,
testing, manufacture, marketing, sale and/or distribution of Lopid.
ANSWER:
3. If
you, or any of your divisions, subsidiaries, or other entities retained or
owned (wholly or in part) by you, manufactured, tested, licensed, sold and/or
distributed Lopid, state: (a) the generic name of the product; and (b) each of
your brand names or trade names for the product.
ANSWER:
4. Identify
each division, subsidiary, operating unit and any independent contractor or
consultant, or other third party engaged by you responsible for or involved in
the following with regard to Lopid:
i. Product
design;
ii. Pre-clinical
testing;
iii. Clinical
testing;
iv. Regulatory
approval and compliance;
v. Manufacturing;
vi. Marketing;
vii. Labeling;
viii. Promotion;
9.
Distribution;
and
x.
Post-market testing
ANSWER:
5. State
whether Defendant has given or received a license regarding the manufacture,
distribution, or sale of Lopid. If so,
state the details of such arrangements, and the identity of any licensee or
licensor.
ANSWER:
9.
State the name,
title, current or last known address and telephone number of each person who
has ever participated on any committee that approves advertising, promotions,
marketing and/or labeling for Lopid;.
ANSWER:
7. State
the name, title, current or last known address and telephone number of each
person who has ever participated on the regulatory affairs committee, any other
committee, or regulatory affairs department, however denominated, which has
supervised or directed regulatory affairs regarding Lopid .
ANSWER:
8. State
the name, title, current or last known address and telephone number of each
person who headed the following departments from 1992 to the present, stating
for each individual the inclusive dates during which they held the position and
the nature of their responsibilities pertaining to Lopid. If organizational
charts or diagrams exist containing such information, please provide each such
chart or diagram for the time set forth herein and identify the applicable time
frame.
1) Legal;
2) Manufacturing;
3) Sales,
Marketing and/or Promotion;
4) Finance;
5) Medical
Communications;
6) Research
and Development;
7) Regulatory
Affairs; and
8)
Post-marketing surveillance.
ANSWER:
9.
With regard to the previous interrogatory, also identify each person,
including name, title, current, or last known address and telephone number,
from the following departments who was assigned any supervisory duties or
responsibilities regarding Lopid:
1) Legal;
2) Manufacturing;
3) Sales,
Marketing and/or Promotion;
4) Finance;
5) Medical
Communications;
6) Research
and Development;
7)
Regulatory
Affairs;
ANSWER:
10. State
the name, title, current or last known address and telephone number of each
person who has ever been in charge or control of the following, stating for
each individual the inclusive dates during which they held the position and the
nature of their responsibilities pertaining to Lopid. If organizational charts
or diagrams exist containing such information, please provide each such chart
or diagram for the time set forth herein and identify the applicable time
frame.
8.
Pre-clinical
animal testing of Lopid or liaison with healthcare providers or organizations
or companies regarding pre-clinical animal testing of Lopid.
b. Pre-market
human or clinical testing of Lopid or liaison with healthcare providers or
organizations or companies regarding pre-market human or clinical testing of
Lopid.
c. Post-market
human or clinical testing of Lopid or liaison with healthcare providers or
organizations or companies regarding post-market human or clinical testing of
Lopid.
d. Post-market
medical surveillance of Lopid or liaison with healthcare providers or
organizations or companies regarding post-market medical surveillance of Lopid.
e. Product licensing regarding Lopid.
f. Product manager regarding Lopid.
ANSWER:
11. Identify
the following with regard to any government investigation, regulatory action,
indictment, information, charge and/or civil lawsuit that has ever been made or
brought against Defendant as it pertains to the promotion, marketing, sale or
distribution of Lopid, excluding matters filed in the Pennsylvania Court of
Common Pleas, Philadelphia County, Civil Trial Division, under the Master
Docket No. 0001:
a. The
product(s) involved;
b. The
court, agency and jurisdiction involved;
c. The
filing date;
d. The
time period at issue;
e. The
current status or disposition of the investigation, regulatory action, suit or
charge; and
f. Any
claim, file, court number docket index or other identifying information
regarding the investigation, regulatory action, suit or charge.
ANSWER:
12. If
you, or any of your divisions, subsidiaries, or other entities retained or
owned (wholly or in part) by you, manufactured, tested, licensed, sold and/or
distributed Lopid, state whether any clinical trials were ever conducted
pursuant to an Investigational New Drug Application (“IND”), New Drug
Application (“NDA”), Supplemental New Drug Application or Amended New Drug
Application (“ANDA”). With respect to each such trial, identify the following:
a. The
names and addresses of all clinical investigation sites;
b. The
names and addresses of all clinical investigators, separately identifying those
investigators in charge of such studies;
c. The
names and addresses of all sponsor-investigators;
d. The
names and addresses of all contract research organizations;
e. Whether
such clinical trials have been concluded;
f. A
description of what each clinical trial concerned, and the results of each such
clinical trial;
7.
The identity of
each person responsible for maintaining the records regarding these clinical
trials;
h. Whether
any clinical trials have been terminated at the request and/or the demand of
the FDA;
i. Whether
the FDA has ever lodged any complaints, warnings, or reprimands with respect to
the conduct of any of the clinical trials;
j. Identify
who has custody of the protocols followed in each clinical trial; and
k.
Identify all records and data from, reflecting and/or relating to each such
clinical trial.
ANSWER:
13. With
respect to each NDA, IND, Supplemental NDA, or ANDA, state whether there were
any comments, responses, or opposition made to any applications for Lopid
either in written form or in the form of testimony from any source, and if so,
please identify the objecting party and attach any such testimony, comments,
objections or responses of the objecting party.
ANSWER:
14. Identify
which, if any, of your divisions, subsidiaries, or other entities retained or
owned (wholly or in part) by you, manufactured, tested, licensed, sold and/or
distributed Lopid outside of the United States, and state the following:
a. The
location(s) outside of the United States where it was marketed
b. The
period of time when each such product was marketed, sold and/or distributed in
each such location outside of the United States;
c. The
indications, contraindications and risks reflected in the labeling which accompanied the product when
it was marketed in each such location outside of the United States (in
English); and
d. Whether
any foreign government regulatory authority took any action to prohibit or limit the manufacture, sale,
distribution or use of each such product, identifying the agency
involved and the action taken.
e. Whether
any foreign government regulatory authority ever lodged any complaints,
warnings, or reprimands with respect to conduct in the manufacturing, sale,
distribution, or use of each such product, and the action taken.
ANSWER:
15. Identify
all warnings regarding Lopid that you have ever distributed, including, but not
limited to, package inserts, product labels, brochures, product information
sheets, and/or promotional information.
ANSWER:
16. Identify
all warnings regarding Lopid, and all drafts of those warnings, that were
prepared but not distributed by you, including, but not limited to, package
inserts, product labels, brochures, product information sheets and/or
promotional information.
ANSWER:
17. Identify
each trade association, professional society or other group in which you are or
have been a member.
ANSWER:
18. With
respect to each association, society or other group, state: (a) whether the
membership includes any person or entity other than yourself who is/was engaged
in the manufacture, sale or distribution of Lopid; and (b) the dates and
locations of each meeting of each trade association, society or group to the
extent that the meeting concerned Lopid, in whole or in part.
ANSWER:
19. At
any time prior to August 2001, did you receive any information that
Rhabdomyolysis occurred in
patients using Lopid, alone and/or in combination with Baycol.
20. If
your answer is “yes,” for each such injury, disease, or condition:
(a) State
the date on which you first became aware that any of the injuries, diseases, or
conditions had occurred in any patient using Lopid alone, and/or in combination
with Baycol;
(b) Identify
each person who furnished and/or received such information;
(c) State
whether each report of such information was provided to the FDA and, if so,
when; and
(d)
Identify all documents relating, referring to or embodying such
information and/or its reporting to the FDA.
ANSWER:
21. Identify
all animal studies of which you and/or any of your divisions or subsidiaries or
affiliates are aware (regardless of whether the studies were conducted by or on
behalf of you or any of your divisions, subsidiaries, or other independent
contractor or third party retained by you) that examined the development of
Rhabdomyolysis in animals subjected to Lopid or any combination of Lopid and a
statin.
ANSWER:
22. Identify
all documents that relate, refer to, or embody all studies identified in
response to the previous interrogatory.
ANSWER:
23. State
the total amount of insurance which you believe may be available to satisfy any
claims that have been made in the past and which may be made in the future
against you, your predecessors, successors, and assigns as a result of the use
of Lopid. Specifically, and without limitation, identify every general
liability, comprehensive general liability, advertising liability or product
liability policy (and every other policy which you believe may provide coverage
to any personal injury) that you purchased or on which you are a named insured
(including policies purchased by related corporate entities), including all
excess layers and/or umbrella policies, for a minimum of the years
1992-present, or for any additional years in which you manufactured or
distributed Lopid, including the policy number, name and address of the insurer
who issued the insurance policy and indicate any self-insured retention;
ANSWER:
24. With
respect to each of the policies outlined in the previous interrogatory answer,
state the following:
(a) The
type of coverage provided by each such policy (e.g., claims made, occurrence
based, etc.);
(b) The
limits of liability per claim and in the aggregate for each such policy;
(c) The
effective dates of each such policy;
(d) Whether
each policy is consuming (e.g., whether payments of counsel fees and defense
costs consume the available limits of liability); and
(e.) The
amounts that have been paid under each such policy and the extent to which such
payments have exhausted the aggregate limits of coverage provided by each such
policy.
ANSWER:
25. State
the name, current or last known address, and telephone number of each of your
risk managers, and/or persons most knowledgeable about your insurance coverage
for the years 1992 to 2001.
ANSWER:
26. State
the name, current address, and telephone number of each of your insurance
broker(s) for the years from 1992 to the present for the insurance identified
in response to Interrogatory 23.
ANSWER:
27. State
whether or not you have tendered any claims or provided notice in this
litigation to any insurer or any insurance policy other than those identified
above. If so, include the name and address of the insurer and the policy number
and, if the policy is issued to anyone other than yourself, the insured under
the policy
ANSWER:
28. State
whether you have been notified of any reservation of rights by any carrier,
and, if so, identify all documents relating thereto.
ANSWER:
29. Describe
your document retention/destruction policies and procedures from 1985 through
the present, including:
(a) What
documents (including computer files) are routinely discarded and when; and
b) How
and where you file safety related documents, including adverse event reports.
ANSWER:
30. If
you, or any of your divisions, subsidiaries, or other entities retained or
owned (wholly or in part) by you manufactured, tested, licensed, sold and/or distributed
Lopid, state if you have ever modified the product from the original form in
which the FDA approved it for marketing, distribution, sale and use. If so,
(a) Describe
each modification;
(b) State
the date(s) on which you first notified the FDA of the modification, and;
(c) State
the reason for each modification.
ANSWER:
31. If
you, or any of your divisions, subsidiaries, or other entities retained or
owned (wholly or in part) by you, manufactured, tested, licensed, sold and/or
distributed Lopid, separately identify, enumerate and describe every
complication or physical problem of any nature which you contend has occurred
or can occur as a result of utilization of the product alone and/or in
combination with a statin.
ANSWER:
32. Describe
your involvement with every task force, council, and/or campaign including,
without limitation, any government, and/or private task force, council and/or
campaign that involved the prevention of and treatment reducing cholesterol.
Your answer must include, without limitation, the following:
(a) The
name and purpose of each task force, council and/or campaign;
(b) The
nature and time period of your involvement in each task force, council and/or
campaign;
(c) A
description of all meetings, conversations, written communications and/or any
other communications, you had with each task force, council, campaign and/or
its members and/or employees; and
(d) Any
money, financial contribution and/or financial assistance of any kind provided
by you to any task force, council and/or campaign.
ANSWER:
33. Describe
every joint effort, of any kind and any nature, with any other defendants in
this litigation, concerning the following:
a. The
development and testing of Lopid;
b. The
marketing and/or promotion of Lopid, including any marketing and/or promotion
that took place through any trade association and/or professional organization;
and,
c. Post-market
surveillance for Lopid.
ANSWER:
34. State
whether you intend to assert that you are not liable for all or any portion of
the claims against you because some other party is (other than prescribing and
treating physicians, and dispensing pharmacies).
ANSWER:
35. If
the answer to the preceding interrogatory is “yes,” identify all such parties,
and indicate why you contend these parties are liable for all or a portion of
plaintiff’s claims.
ANSWER:
36. Describe
the distribution process for Lopid. Your answer shall include, without
limitation:
a. An
identification of who encapsulated Lopid;
b. An
identification of who bottled Lopid;
c. An
identification of who distributed Lopid; and
d. A
description of how Lopid is obtained by
(i) Pharmacies;
(ii) Physicians;
(iii) Hospitals;
(iv) Diet
centers; and,
(v) Clinics.
ANSWER:
37. Identify
and describe all indemnity agreements, agreements to assume liability,
agreements to assume the defense, or any other such agreements between you,
your insurer and any other person regarding any claims pertaining to Lopid.
ANSWER:
38. Provide
the following information about your company:
a. The
identity, by name and title, of each of your current corporate officers;
b. The
identity, by name and title, of your current board of directors;
c. State
whether your company is owned in material part (50% or greater) by any other
persons or entities and, if so, identify the owners and their ownership
interests;
d. Provide
the most current financial data available regarding your company’s:
i. Gross
sales;
ii. Net
income;
iii. Total
assets;
iv. Cash;
v. Current
assets;
vi. Current
liabilities;
vii. Equity;
viii. Long-term
debt; and
10.
Short term
debt.
ANSWER:
39. Identify
the individual, including title, address, and telephone number, most
knowledgeable regarding your financial status.
ANSWER:
40. Identify
the individual, including title, address, and telephone number, most
knowledgeable regarding your insurance coverage.
ANSWER:
41. Identify
every person, including title, address, and telephone number, most
knowledgeable regarding MIS, record keeping, document cataloguing, and storage.
ANSWER:
42. Identify
every officer and employee of your company or any of your subsidiaries or
divisions, who was involved in any way in the acquisition of rights to market
Lopid, or in the development, testing, licensing, manufacture, labeling,
distribution, or sale of Lopid, and identify any documents authored or received
by those individuals relating or referring to Lopid.
ANSWER:
43. Prior
to completing your answers to these interrogatories, and your responses to
Plaintiffs’ Request for Production of Documents — Master Set, did you make a
due and diligent search of all of your books, records, documents and papers,
and a due and diligent inquiry of all of your employees, representatives, and
agents for the purpose of obtaining all information available in response to
the above-referenced discovery requests?
ANSWER:
44. Identify
with particularity, all side effects known to you prior to the first production
or sale of Lopid. In doing so, state the following:
(a) How
and when each side effect was discovered;
(b) The
name, current title, address and telephone number of each the individual who
discovered each side effect;
(c) How
and when each side effect was reported to the FDA; and,
(d) Each
step you took to prevent or warn of each side effect.
ANSWER:
45. Identify
with particularity, each contraindication known to you prior to the first
production or sale of Lopid. In doing so, state the following:
(a) How
and when the contraindication was discovered;
(b) The
name, current title, address and phone number of each individual who discovered
each contraindication;
(c) How
and when each contraindication was reported to the FDA; and,
(d) Each
step you took to prevent or warn of each contraindication.
ANSWER:
46. Identify
every printed and/or published material by, for, or funded by you from the time
Lopid was first produced to the present which refer to the use, safety,
efficacy, side effects and contraindications for Lopid in:
(a) All
sales and promotional material (including, but not limited to, letters,
directories, sales, memorandums, pamphlets, and brochures);
(b) All
press releases;
(c) All
articles and advertising prepared for publication in scientific journals and
other periodicals.
In answering, please state with
particularity:
11.
the date the
material was prepared;
12.
the date,
method, and manner in which the material was distributed;
13.
the
individual(s) or groups to whom it was distributed;
14.
if it appeared
in a publication, supply the name, issue, date, page, stock numbers or other
identifying symbols;
15.
the name,
title, address, and telephone number of the author and your relationship with
him/her/them;
16.
whether copies
have been retained and their location
17.
identify the
custodian of such records or copies.
ANSWER:
47. State
how you have documented any reports of incidents or problems with persons who
took Lopid from the time of first production to present. In answering, please
specify every written or oral protocol concerning what actions, if any, you
would take after receiving such reports.
ANSWER:
48. With
respect to the preceding interrogatory, state if and when you in any manner
communicated such reports to the FDA, heath care providers, or any governmental
entity.
ANSWER:
49. Describe
with particularity each electronic database maintained by you regarding any
reported, potential or suspected incident, problem or side effect or adverse
effect associated with Lopid, identifying the title of all such files, the
number of records contained in each such file, the official description of the
contents in such files, the date of the earliest records in such files, the
date of the most recent report in such files, and the custodian of the records
of all such files.
ANSWER:
50. Identify
every meeting that your agents, and/or employees ever had with any member of
the FDA concerning any issue relating to Lopid. In answering, identify each
date, who was present, and the subject matter of each meeting.
ANSWER:
52. Did
you ever notify the FDA, healthcare providers, and/or consumers of the
information you had regarding side effects, adverse reactions, or adverse
events associated with Lopid? If so, identify every document that provides or
refers to the information you provided.
ANSWER:
53. If
you were aware of side effects or adverse reactions or adverse events
associated with Lopid, but did not notify the FDA, healthcare providers, and/or
consumers of what you knew, set forth the reasons why the information was not
provided.
ANSWER:
54. State
whether Lopid was ever marketed outside of the United States. In answering,
please specify every brand name, and where and when it was marketed.
ANSWER:
55. If
you marketed Lopid outside of the United States, please specify whether the
warnings were different from those used in the United States.
ANSWER:
56. If
you marketed Lopid outside of the United States, identify each foreign
government or agency that sought to prohibit or limit its sale, distribution,
or use, and specify the date of each such action.
ANSWER:
57. Did
you ever consider withdrawing, and/or did you ever withdraw, Lopid from any
foreign market? If so, identify each person (including name, current address,
telephone and job title) who has relevant knowledge of this information, state
what such each person knew, and when.
ANSWER:
58. Identify
and detail your relationship with any third party that was involved in the promotion,
marketing, or sales of Lopid.
ANSWER:
67. State
the name, job title, current address and telephone number of each person who
participated in the preparation of these Answers to Interrogatories, and
indicate the specific responses or information each contributed, excluding
counsel.
ANSWER:
Respectfully submitted,
ANAPOL, SCHWARTZ, WEISS, COHAN
FELDMAN & SMALLEY, P.C.
______________________________________
SOL H. WEISS, ESQUIRE
Liaison Counsel for Plaintiffs
GREITZER & LOCKS
______________________________________
LEE BALEFSKY, ESQUIRE
Plaintiffs’ Liaison Counsel
LEVIN FISHBEIN SEDRAN & BERMAN
________________________________________
ARNOLD LEVIN, ESQUIRE
Dated: ____________________