Case: 1:21-cv-06329 Document #: 1-1 Filed: 11/26/21 Page 1 of 13 PageID #:13
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`Exhibit A
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`Case: 1:21-cv-06329 Document #: 1-1 Filed: 11/26/21 Page 2 of 13 PageID #:14
`12-Person Jury
`
`FILED
`10/19/2021 7:41 PM
`IN THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS !RIS Y. MARTINEZ
`,
`CIRCUIT CLERK
`COUNTY DEPARTMENT, LAW DIVISION
`COOK COUNTY.IL
`2021L010263
`
`:
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`15268752
`
`) )
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`ERICA V. MARTINEZ,
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`Plaintiff,
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`\
`\ v.
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`Case No.
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`) )
`
`Defendants.
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`)
`
`COMPLAINT AT LAW
`
`NOW COMESPlaintiff, ERICA V. MARTINEZ,by and throughher attorneys, NOLAN
`
`LAWGROUP, and complaining against Defendants, MYLAN PHARMACEUTICALS, INC., a
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`corporation, MYLAN TECHNOLOGIES,
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`INC., a corporation, and WALGREEN CO.,
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`a
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`corporation, and each of them,states as follows:.
`
`Introduction, Jurisdiction and Venue
`This is an action in which Plaintiff, ERICA V. MARTINEZ, seeks recovery of
`1.
`damages arising from personalinjuries she sustained from a bloodclotin her brain on October20,
`
`2019, which she alleges was caused by defective and dangerous conditionsofa transdermalbirth
`
`contro] patch product known as Xulane®, and the negligent and wrongful conduct of the
`Defendants herein,
`including their conduct related to the design, manufacturing,
`instruction,
`warnings,sale, distribution, and marketing ofthe Xulane® product,
`
`2.
`
`On October 20, 2019, and at all
`
`times relevant herein, Plaintiff, ERICA V.
`
`MARTINEZ,wasand continuesto be a citizen and resident of Cook County,Illinois.
`
`)
`)
`)
`).
`PLAINTIFF DEMANDS
`)
`MYLAN PHARMACEUTICALS, INC., a
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`corporation, MYLAN TECHNOLOGIES, INC.,_) TRIAL BY JURY
`a corporation, and WALGREENCO., a
`)
`corporation,
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`FILEDDATE:10/19/20217:41PM2021L010263
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`

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`FILEDDATE:10/19/20217:41PM20211010263
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`Case: 1:21-cv-06329 Document #: 1-1 Filed: 11/26/21 Page 3 of 13 PageID #:15
`Case: 1:21-cv-06329 Document#: 1-1 Filed: 11/26/21 Page 3 of 13 PagelD #:15
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`3,
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`On October 20, 2019, and at all
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`times herein relevant, Defendant, MYLAN
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`PHARMACEUTICALS,INC., was and continues to be a corporation organized and existing under
`the laws ofthe State of West Virginia, with its principal place of business in the State of West .
`Virginia, which did and continues to do substantial business in the State of Illinois, including
`certain business transactions from whichthis action arises.
`4,
`| On October 20, 2019, and at all
`times hereinrelevant, Defendant, MYLAN
`TECHNOLOGIES,INC., was and continuesto be a corporation organized and existing under the
`laws of the State of West Virginia with its principal place of business in the State of Vermont,
`
`which did and continues to do substantial business in the State of Illinois,
`
`including certain
`
`|
`business transactions from whichthis action arises.
`5.
`On October 20, 2019, and at all times herein relevant, Defendant, WALGREEN
`
`CO., was and continues tobe a corporation organized and existing under the laws ofthe State.of0
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`Illinois, with its principal place of business in the State ofIllinois, and which did and continues to
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`do substantial business in’Cook County, Illinois, including certain business transactions from
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`which this action arises.
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`6.
`
`Venueofthis action is proper in the Circuit Court of Cook County, Illinois under
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`735 ILCS 5/2-101, as the transactions giving rise to this action, including the commission of the
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`tort, occurred in Cook County,Illinois and the damages sought exceed the sum offifty thousand
`
`dollars ($50,000.00).
`
`Facts Relating to the Xulane® Product
`On or about December 31, 2009, Defendant, MYLAN TECHNOLOGIES,INC.,
`7.
`submitted an abbreviated new drug application (ANDA)for Xulane® (Norelgestrominand Ethinyl
`
`Estradiol Transdermal System), 150 mcg/35 mcg per day, to the United States Food and Drug
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`
`
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`

`

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`FILEDDATE:10/19/20217:41PM2021L010263
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`Case: 1:21-cv-06329 Document #: 1-1 Filed: 11/26/21 Page 4 of 13 PagelD #:16
`Case: 1:21-cv-06329 Document #: 1-1 Filed: 11/26/21 Page 4 of 13 PageID #:16
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`Administration (“FDA”) pursuant to section 505(j) ofthe Federal Food, Drug, and Cosmetic Act.
`The said ANDA wassponsored by Defendant, MYLAN PHARMACEUTICALS, INC., and was
`
`assigned ANDAApplication No. 200910 by the FDA. The ANDAwassubmitted to the FDA by
`
`INC., under the previously approved New Drug
`Defendant, MYLAN TECHNOLOGIES,
`Application (“NDA”) for the soins listed drug (“RLD”), Ortho Evra® Transdermal System of
`Janssen Pharmaceuticals, Inc.
`|
`
`=
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`8.
`Xulane® is a transdermal birth control patch. The patch contains combination
`hormone medication and is used to prevent pregnancy. It contains two hormones: a pionentn
`(norelgestromin) and an estrogen(ethinylestradiol). It is designed to workbypreventing ovulation
`
`during a woman’s menstrual cycle. It also makes vaginal fluid thicker, in order to help prevent
`sperm from reaching an egg (fertilization) and changes the lining of the uterus to prevent the
`attachmentofa fertilized _
`
`9.
`Following its approval by the FDA in 2001, the labeling for Ortho Evra® was
`edited on . different occasions,
`including changes
`to address
`issues
`related to venous
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`thromboembolism risk and exposure to contraceptive hormones seen with Ortho Evra®, as
`
`compared with certain combined oral contraceptives.
`10.
`Prior to October 20, 2019, there were numerous adverse events reported associated
`with the use ofOrtho Evra®,including venous thromboembolism and thereafter, the manufacturer
`
`\
`
`of Ortho Evra® voluntarily ceasing marketing Ortho Evra® in the United States, and the FDA
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`approved the withdrawalof the NDA for Ortho Evra®.
`It.
`| Notwithstanding, on April 16, 201 4, the FDA approved the ANDA Application No.
`
`200910 for Xulane®.
`
`

`

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`FILEDDATE:10/19/20217:41PM2021L010263
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`Case: 1:21-cv-06329 Document #: 1-1 Filed: 11/26/21 Page 5 of 13 PageID #:17
`Case: 1:21-cv-06329 Document#: 1-1 Filed: 11/26/21 Page.5 of 13 PagelD #:17
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`12.
`
`Following approval of the ANDA for Xulane® by the FDA,
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`the Defendant,
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`MYLAN PHARMACEUTICALS, INC., undertook to and did develop and provide packaging,
`
`labeling, warnings, instructions; patient pamphlets, and prescribing information for use by doctors
`
`and patients related to Xulane® products.
`
`13.
`On April 16, 2014, and upon approval of the ANDA for Xulane®, Defendants,
`MYLAN TECHNOLOGIES, INC., and MYLAN PHARMACEUTICALS, INC., and each of
`
`them, were required to thereafter provide post-marketing reporting for the ANDAsetforth in 21
`
`CFR 314.80-81 and 21 C.F.R. 314.98 and were further required to advise the FDA Office of
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`Generic Drugs of any change in the marketing status of the drug.
`14.
`Upon information and belief, subsequent to April 16, 2014, but prior to October 20,
`the FDA, as well as Defendants, MYLAN TECHNOLOGIES, INC., and MYLAN
`
`2019,
`
`a
`serious
`risk of
`fatal and
`non-fatal venous
`thromboembolism (VTE)
`and arterial
`thromboembolism associated with norelgestromin and ethinyl estradiol transdermal patches, and
`the FDA ordered certain post-marketing studies and clinical trials be designed and conducted to
`
`detect increased risk for venous thromboembolism in users of transdermal birth control patches,
`
`especially examining the age, BMI, and smokingstatus of users of the patches.
`15.
`.
`In April 2020, after Plaintiff, ERICA V. MARTINEZ, suffered a venous
`thromboembolism, Defendants, MYLAN TECHNOLOGIES,
`INC.,
`and MYLAN
`
`PHARMACEUTICALS,
`INC., and each of them, changed the packaging, warnings, and
`prescribing information to include the warning and limitation on use: “Do not use XULANEif
`your Body MassIndex (BMJ)is 30 kg/m2 or more. Women with a BMIof30 kg/m2 or more’who
`
`

`

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`FILEDDATE:10/19/20217:41PM2021L010263
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`‘Case: 1:21-cv-06329 Document#: 1-1 Filed: 11/26/21 Page 6 of 13 PagelD #:18
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`use Xulane may be at a higher risk for developing blood clots compared to women with a BMI
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`: lower than 30 kg/m*.
`Facts Relating to Plaintiffs Use of the Xulane Product
`
`16.
`
`Plaintiff, ERICA V. MARTINEZ, wasfirst prescribed Xulane® by a medical
`
`doctor on April 7, 2017, at which time she had a Body MassIndex (“BMI”) of 29.9 kg/m.
`17,
`Plaintiff, ERICA V. MARTINEZ, purchased and was dispensed the Xulane®
`products that she thereafter used from Defendant, WALGREENCO.,at its Walgreen Drug Store
`No. 215 located at or near 3045 West 26"Street, Chicago,Illinois 60623. The last three purchases
`
`of the Xulane® productprior to October 20, 2019, were on July 24, 2019, September 9, 2019, and
`
`October 16, 2019. The Xulane® product so purchased and dispensed to Plaintiff, ERICA V.
`MARTINEZ,bore National Drug Code (“NDC”) 00378-3340-53.
`18.
`The Xulane® products purchased and dispensed to Plaintiff, ERICA V.
`MARTINEZ,were developed, manufactured, marketed, packaged, labeled, and originally placed
`
`into the stream of commerce by Defendants, MYLAN TECHNOLOGIES, INC., and MYLAN
`
`PHARMACEUTICALS, INC., and each of them, either directly, or by and through their
`employees and agents.
`.
`- 19.
`At the times Plaintiff, ERICA V. MARTINEZ, purchased and vias dispensed the
`
`Xulane® products by Defendant, WALGREEN CO., she received certain patient counseling,
`
`including directions that she should apply a new patch weekly for three weeks, remove for one
`week, then repeat the cycle. However, she was not informed of the nature and extent of her
`individual risk of developing a venous thromboembolism from her use or continued use of the
`
`Xulane® drug product.
`
`

`

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`FILEDDATE:10/19/20217:41PM2021L010263
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`Case: 1:21-cv-06329 Document #: 1-1 Filed: 11/26/21 Page 7 of 13 PageID #:19
`Case: 1:21-cv-06329 Document#: 1-1 Filed: 11/26/21 Page 7 of 13 PagelD #:19
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`rawa“ee
`On October 20, 2019, and at the time she suffered a venous thromboembotism or
`20.
`clot in her brain while using the Xulane® product, Plaintiff, ERICA V. MARTINEZ,had a BMI
`of 28.32 kg/m?.
`
`21.
`
`On October 20, 2019, the physicians treating Plaintiff, ERICA V. MARTINEZ,
`
`following her venous thromboembolism diagnosis wrote: “hypercoagulable state wasfelt to be in
`
`the setting of OCPuse,specifically an estrogen patch,” and “[pJatient had a dural vein thrombosis
`
`that waslikely associated with estrogen use. There were no otherclear precipitating factors for the
`
`thrombosis.”
`
`COUNT I
`PRODUCTLIABILITY —- MYLAN PHARMACEUTICALS
`
`1-21. Plaintiff, ERICA V. MARTINEZ,adopts and alleges paragraphs |
`
`through 21,
`
`above, as paragraphs | through 21, inclusive, of Count I as though fully set forth therein.
`
`22.
`
`At the time the Xulane® drug product was placed into the stream of commerce by
`
`Defendants, MYLAN TECHNOLOGIES,INC., and MYLAN PHARMACEUTICALS,INC., and
`
`each of them,
`
`it was defective and unreasonably dangerous in one or more of the following
`
`respects:
`
`the Xulane® drug product was developed and manufactured with
`(a)
`concentrations of drugs which hadahigh risk of causing and did cause
`venous thromboembolism in persons of similar age and body mass index
`(BMD) as the Plaintiff, ERICA V. MARTINEZ, when used asdirected;
`
`(b)—the Xulane® drug product lacked proper and adequate warningsofthe risk
`of venous thromboembolism in personsof similar age and body massindex
`(BMI) as the Plaintiff, ERICA V. MARTINEZ, when used as directed;
`
`(c)
`
`the Xulane® drug product lacked proper and adequate instructionsin its
`use.
`
`23.
`
`On October 20, 2019, and as a direct and proximate result of one or more of the
`
`foregoing defective and unreasonably dangerous conditions of the Xulane® drug product,
`
`

`

`“
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`
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`FILEDDATE:10/19/20217:41PM2021L010263
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`Case: 1:21-cv-06329 Document #: 1-1 Filed: 11/26/21 Page 8 of 13 PageID #:20
`Case: 1:21-cv-06329 Document#: 1-1 Filed: 11/26/21 Page 8 of 13 PagelD #:20
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`Plaintiff, ERICA V. MARTINEZ, was causedto and did suffer a blood clot in her brain known as
`
`‘a venous thromboembolism, which further caused an acute,
`
`life-threatening parenchymal
`
`hemorrhagein the right temporal lobe of her brain and other severe and disabling injuries to her
`
`person.
`
`24.
`
`That as a result of the aforesaid injuries, Plaintiff, ERICA V. MARTINEZ, was
`
`caused to and will in the future experience great pain and suffering, has suffered and will in the
`
`future suffer disability and disfigurement, has suffered and will in the future suffer from the loss
`
`_ of a normallife, has been caused to incur and will in the future incur expenses for necessary
`
`medical care, treatment, and services, has suffered and will in the future suffer a loss of the value
`of her time, earnings, profits, and salaries, has been and will be damagedin her earning capacity,
`and has otherwise been damagedin a personal and pecuniary nature.
`|
`WHEREFORE,Plaintiff, ERICA V. MARTINEZ,praysthat judgment be entered in her
`favor and against Defendants, MYLAN TECHNOLOGIES, INC., a corporation, and MYLAN
`
`PHARMACEUTICALS, INC., a corporation, and each of them, in a sum in excess of the minimal
`Jurisdictional amountof the Circuit Courtof Cook County,Illinois, together with attorney fees,
`pre-judgmentinterest, and the costs of bringingthis action.
`|
`COUNT II
`NEGLIGENCE — MYLAN
`
`1-21. Plaintiff, ERICA V. MARTINEZ,adopts and alleges paragraphs |
`
`through 21,
`
`above, as paragraphs | through 21, inclusive, of Count II as though fully set forth herein.
`
`22.
`
`On October 20, 2019, andat all times herein relevant, it was the duty of Defendants,
`
`MYLAN TECHNOLOGIES, INC., and MYLAN PHARMACEUTICALS, INC., and each of
`
`~
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`them,to exercise the care of a reasonable pharmaceutical companyin the design, approvalprocess,
`
`manufacture, marketing, packaging, labeling, warning, sale, and instruction in use of the Xulane®
`
`

`

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`FILEDDATE:10/19/20217:41PM2021L010263
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`Case: 1:21-cv-06329 Document #: 1-1 Filed: 11/26/21 Page 9 of 13 PageID #:21
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`drug preduct and its post-market pharmacovigilance, so as not to cause injury to the persons of
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`others, including Plaintiff, ERICA V. MARTINEZ.
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`23.
`
`On October 20, 2019, and notwithstanding the aforesaid duty, Defendants,
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`MYLAN TECHNOLOGIES, INC., and MYLAN PHARMACEUTICALS, INC., and each of
`
`them, breached their duty of care to Plaintiff, ERICA V. MARTINEZ,in one or more of the
`
`following particulars:
`
`(a)
`
`(b)
`
`(c)
`
`(d).
`
`(e)
`
`negligently and carelessly manufactured, marketed, packaged, and sold
`Xulane® when they knew or should have knownof unreasonable dangers
`associated with venous thromboembolism from its intended use, which
`dangers were not obviousto product users;
`
`negligently and carelessly manufactured, marketed, packaged, and sold the
`Xulane® drug product whenit contained concentrations of drugs which had
`a high risk of causing and did cause venous thromboembolism in persons
`of similar age and body mass index (BMI) as the Plaintiff, ERICA V.
`MARTINEZ, whenused as directed;
`
`negligently and carelessly manufactured, marketed, packaged, and sold
`Xulane® whenit lacked proper and adequate warningsofthe risk of venous
`thromboembolism in persons of similar age and body mass index (BMI) as
`the Plaintiff, ERICA V. MARTINEZ, whenusedasdirected;
`
`negligently and carelessly manufactured, marketed, and sold Xulane®
`whenit lacked proper and adequate instructionsin its use; and/or
`
`negligently and carelessly failed to conduct proper and adequate post-
`market monitoring and analysis of Xulane® including pharmacovigilance
`monitoring and analysis and post-market reporting.
`
`24.
`
`On October 20, 2019, and as a direct and proximate result of the aforesaid breach
`
`of duty by Defendants, MYLAN TECHNOLOGIES, INC. and MYLAN PHARMACEUTICALS,
`
`INC., and each of them, Plaintiff, ERICA V. MARTINEZ, wascaused to and did suffer a blood
`
`clot in her brain knownas a venous thromboembolism from her use of the Xulane® drug product,
`
`which further caused an acute,life-threatening parenchymal hemorrhage in the right temporal lobe
`
`of her brain and other severe and disabling injuries to her person.
`
`
`
`
`
`

`

`a
`
`Case: 1:21-cv-06329 Document #: 1-1 Filed: 11/26/21 Page 10 of 13 PageID #:22
`Case: 1:21-cv-06329 Document#: 1-1 Filed: 11/26/21 Page 10 of 13 PagelD #:22
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`FILEDDATE:10/19/20217:41PM2021L010263
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`That as a result ofthe aforesaid injuries, Plaintiff, ERICA V. MARTINEZ, was
`25.
`caused to and will in the future experience great pain and suffering, has suffered and will in the
`future suffer disability and disfigurement, hassuffered and will inthe future suffer from the loss
`of a normal life, has been caused to incur and will in the future incur expenses for necessary
`medicalcare, treatment, and services, has suffered and will in the future suffer a loss ofthe value -
`
`of her time, earnings,profits, and salaries, has been and will be damagedin her earning capacity,
`
`and has otherwise been damagedin a personal and pecuniary nature.
`
`WHEREFORE,Plaintiff, ERICA V. MARTINEZ,prays that judgment be entered in her
`
`favor and against Defendants, MYLAN TECHNOLOGIES, INC., a corporation, and MYLAN
`
`. PHARMACEUTICALS, INC., a corporation, and each of them, in a sum in excess of the minimal
`
`jurisdictional amount of the Circuit Court of Cook County,Illinois, together with attorney fees,
`
`pre-judgmentinterest, and the costs of bringing this action.
`
`_ COUNT II
`.
`BREACH OF WARRANTY - MYLAN
`
`through 21,
`1-21. Plaintiff, ERICA V. MARTINEZ, adopts and alleges paragraphs |
`above, as paragraphs | through 21, inclusive, ofCountIII as though fully set forth herein.
`22.
`At all times material, Defendants, MYLAN TECHNOLOGIES,
`INC., and
`MYLAN PHARMACEUTICALS,
`INC., and each of them, warranted both expressly and
`
`impliedly that the condition of the Xulane® drug product was free of safe and reasonablyfit for
`
`its intended and foreseeable use and purposein persons of similar age and body mass index (BMI)
`as the Plaintiff ERICA V. MARTINEZ, when used asdirected.
`23.
`Notwithstanding the express and implied warranties of fitness for its intended use
`
`and purpose made by Defendants, MYLAN TECHNOLOGIES,
`
`INC.,
`
`and MYLAN
`
`PHARMACEUTICALS, INC., and each ofthem, the Xulane® drug product wasdefective, unsafe,
`
`

`

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`Case: 1:21-cv-06329 Document#: 1-1 Filed: 11/26/21 Page 11 of 13 PagelD #:23
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`. dangerousand unfit for its foreseeable use and purpose that created an unreasonable hazard when
`
`_
`
`the Xulane® drug product wasused in a foreseeable manner.
`24.
`On Corker 20, 2019, and as a direct and srendtnans result of the breach of
`warranties
`by
`Defendants, MYLAN
`TECHNOLOGIES,
`INC.,
`and MYLAN
`PHARMACEUTICALS, INC., and each of them, Plaintiff, ERICA V. MARTINEZ, was caused
`to and did suffer a blood clot in her brain known as a venous thromboembolismfrom her use of
`the Xulane® drug product, which further caused an acute,
`life-threatening parenchymal:
`
`
`
`FILEDDATE:40/19/20217:41PM=2021L010263
`
`
`
`hemorrhagein the right temporal lobe of her brain and other severe and disabling injuries to her
`person.
`|
`
`25;
`
`That as a result of the aforesaid injuries, Plaintiff, ERICA V. MARTINEZ, was
`
`caused to and will in the future experience great pain and suffering, has suffered and will in the
`
`future suffer disability and disfigurement, has sufferedandwill in the future sufferfromthe loss__
`
`of a normallife, has been caused to incur and will in the future incur expenses for necessary
`
`medical care, treatment, and services, has suffered and will in the future suffer a loss of the value
`
`of her time, earnings, profits, and salaries, has been and will be damaged in her earning capacity,
`
`and has otherwise been damagedin a personal and pecuniary- nature.
`WHEREFORE, Plaintiff, ERICA V. MARTINEZ,prays that judgment be entered in her
`
`favor and against Defendants, MYLAN TECHNOLOGIES,INC., a corporation, and MYLAN
`PHARMACEUTICALS,INC., a corporation, and each ofthem, in a sum in excess ofthe minimal
`jurisdictional amount of the Circuit Court of Cook County, Illinois, together with attorney fees,
`
`pre-judgmentinterest, and the costs of bringing this action.
`
`

`

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`Case: 1:21-cv-06329 Document #: 1-1 Filed: 11/26/21 Page 12 of 13 PageID #:24
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`COUNT IV
`NEGLIGENCE — WALGREENS
`
`1-21. Plaintiff, ERICA V. MARTINEZ, adopts and alleges paragraphs |
`through 21,
`above, as paragraphs | through 21, inclusive, of Count IV as though fully set forth herein.
`22.
`On October 20, 2019, and'at alltimes herein relevant, it was the duty of Defendant,
`
`WALGREENCO., individually and through its employees and agents, to exercise the care of a
`
`reasonable pharmacyand pharmacistin the sale, dispensing, and patient counseling of the drugsit
`sells so as not to cause injury to the person of its customers,
`including Plaintiff, ERICA V.
`MARTINEZ.
`|
`23.
`On October 20, 2019: and notwithstanding the aforesaid duty, Defendant,
`WALGREENCO., breachedits duty of care to Plaintiff, ERICA V. MARTINEZ,in one or more
`
`of the following particulars:
`(a)
`negligently and carelessly sold and dispensed Xulane® product bearing
`NDC 00378-3340-53 to Plaintiff, ERICA V. MARTINEZ, which was
`defective and unreasonably dangerous;
`
`(b)
`
`(c)
`
`(d)
`
`negligently and carelessly sold and. dispensed Xulane® product bearing
`NDC 00378-3340-53 to Plaintiff, ERICA V. MARTINEZ, without proper
`and adequate patient counseling including counseling on significant
`potential adverse events;
`,
`
`negligently and carelessly sold and dispensed Xulane® product bearing
`NDC 00378-3340-53 to Plaintiff, ERICA V. MARTINEZ, without proper
`and adequate warningsofthe risk of venous thromboembolism; and/or
`
`negligently and carelessly sold and dispensed Xulane® product bearing
`NDC 00378-3340-53 to Plaintiff, ERICA V. MARTINEZ, without proper
`and adequateinstructions in its use.
`
`24.
`
`On October 20, 2019, and as a direct and proximate result of the aforesaid breach
`
`of duty by Defendant, WALGREENCO., Plaintiff, ERICA V. MARTINEZ, was caused to and
`
`did suffer a blood clot in her brain known as a venous thromboembolism from her use of the
`
`x F
`
`ILEDDATE:10/19/20217:41PM2021L010263
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`
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`
`
`—
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`

`

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`FILEDDATE:10/19/20217:41PM2021L010263
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`7]
`
`Xulane® drug product, which further caused an acute,life-threatening parenchymal hemorrhage
`in the right temporallobe ofher brain and other severe and disabling injuries to her person.
`25.
`That as a result of the aforesaid injuries, Plaintiff, ERICA V. MARTINEZ, was
`caused to and will in the future experience great pain and suffering, has suffered and will in the
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`future suffer disability and disfigurement, has suffered and will in the future suffer from the loss
`
`in the future incur expenses for necessary
`of a normallife, has been caused to incur and will
`medical care, treatment and services, has suffered and will in the future suffer a loss of the value
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`of her time, earnings, profits, and salaries, has been and will be damagedin her earning capacity,
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`and has otherwise been damagedin a personal and pecuniary nature.
`WHEREFORE, Plaintiff, ERICA V. MARTINEZ,prays that judgmentbe entered in her
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`favor and against Defendant, WALGREENCO., a corporation, in a sum in excess of the minimal
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`jurisdictional amount of the Circuit Court of Cook County,Illinois,togetherwithattorneyfees,
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`pre-judgmentinterest, and the costs of bringing this action.
`
`Respectfully submitted,
`
`NOLAN LAW GROUP
`
`By:
`
`/
`
`Timothy I. McArdle
`Attorneysfor Plaintiff
`
`Attorney Code #36211
`Timothy I. McArdle, Esq.
`NOLAN LAW GROUP
`20 North Clark Street, 30" Floor
`Chicago,Illinois 60602
`Tel: (312) 630-4000
`Fax: (312) 630-4011
`
`