throbber
Case 2:22-cv-00630 Document 1-2 Filed 03/10/22 Page 1 of 14
`
`Service of Process
`Transmittal
`02/18/2022
`CT Log Number 541078132
`
`TO:
`
`RE:
`
`FOR:
`
`Lauren Groblewski
`Abbott Laboratories
`100 ABBOTT PARK RD
`NORTH CHICAGO, IL 60064-3502
`
`Process Served in Louisiana
`
`Abbott Laboratories  (Domestic State: IL)
`
`ENCLOSED ARE COPIES OF LEGAL PROCESS RECEIVED BY THE STATUTORY AGENT OF THE ABOVE COMPANY AS FOLLOWS:
`
`TITLE OF ACTION:
`
`Re: REGINALD BLANCHARD // To: Abbott Laboratories
`
`DOCUMENT(S) SERVED:
`
`--
`
`COURT/AGENCY:
`
`None Specified
`Case # 824983
`
`NATURE OF ACTION:
`
`Product Liability Litigation - Personal Injury
`
`ON WHOM PROCESS WAS SERVED:
`
`C T Corporation System, Baton Rouge, LA
`
`DATE AND HOUR OF SERVICE:
`
`By Process Server on 02/18/2022 at 08:35
`
`JURISDICTION SERVED :
`
`APPEARANCE OR ANSWER DUE:
`
`ATTORNEY(S) / SENDER(S):
`
`ACTION ITEMS:
`
`Louisiana
`
`None Specified
`
`None Specified
`
`CT has retained the current log, Retain Date: 02/18/2022, Expected Purge Date:
`02/23/2022
`
`Image SOP
`
`Email Notification,  Danielle Barberis  danielle.barberis@abbott.com
`
`Email Notification,  Lauren Groblewski  lauren.lucy@abbott.com
`
`Email Notification,  Jennifer Curtis  jennifer.curtis@abbott.com
`
`REGISTERED AGENT ADDRESS:
`
`C T Corporation System
`3867 Plaza Tower Dr.
`Baton Rouge, LA 70816
`877-564-7529
`MajorAccountTeam2@wolterskluwer.com
`The information contained in this Transmittal is provided by CT for quick reference only. It does not constitute a legal opinion, and should not otherwise be
`relied on, as to the nature of action, the amount of damages, the answer date, or any other information contained in the included documents. The recipient(s)
`of this form is responsible for reviewing and interpreting the included documents and taking appropriate action, including consulting with its legal and other
`advisors as necessary. CT disclaims all liability for the information contained in this form, including for any omissions or inaccuracies that may be contained
`therein.
`
`Page 1 of  1 / AP
`
`EXHIBIT A
`
`

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`II
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`IIII
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`II
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`II
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`II
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`II
`
`[RETURN COPY]
`
`II
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`II
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`II
`
`1111
`
`il
`
`(101) CITATION: PETITION FOR DAMAGES ;
`
`220208-9439-4
`
`24TH JUDICIAL DISTRICT COURT
`PARISH OF JEFFERSON
`STATE OF LOUISIANA
`
`REGINALD BLANCHARD
`versus
`ABBOTT LABORATORIES
`
`To: ABBOTT LABORATORIES
`THROUGH ITS REGISTERED AGENT:
`CT CORPORATION SYSTEM
`3867 PLAZA TOWER DR
`BATON ROUGE LA 70816
`
`PARISH OF JEFFERSON
`
`Case: 824-983 Div: "G"
`P 1 REGINALD BLANCHARD
`
`#8318 $39.36 SEBR
`
`You are hereby summoned to comply with the demand contained in the PETITION FOR
`DAMAGES of which a true and correct copy accompanies this citation, or make an
`appearance either by filing a pleading or otherwise, in the 24th Judicial District Court in and for
`the Parish of Jefferson, State of Louisiana, within (21) CALENDAR days after the service
`hereof, under penalty of default.
`
`This service was requested by attorney KARA H. SAMUELS and was issued by the Clerk of
`Court on the 8th day of February, 2022.
`
`/s/ Donna G. Muscarello
`Donna G. Muscarello, Deputy Clerk of Court for
`Jon A. Gegenheimer, Clerk of Court
`
`SERVICE INFORMATION
`
`(101) CITATION: PETITION FOR DAMAGES ;
`
`220208-9439-4
`
`Received:
`
`Served:
`
` Returned:
`
`Service was made:
`Personal
`
`Domicilary
`
`Unable to serve:
`
`_ Not at this address
`
`_ Vacant
`____ Moved
`____ No such address
`Other _
`
`—
`—
`_
`_
`
`Numerous attempts
`Received too late to serve
`No longer works at this address
`Need apartment / building number
`
`times
`
`Service: $ Mileage: $ Total: $
`
`Completed by:
`
`Deputy Sheriff
`Parish of:
`
`Page 1 of 1
`
`Thomas F. Donelon Courthouse: 200 Derbigny St. : Gretna LA 70053
`
`

`

`FILED FOP. REC:ORD 0210312022 1 6.:03:36
`kdaram K. AdariG, DV CLERK
`JEFFERSON PAREH, LA
`
`24TH JUDICIAL DISTRICT COURT FOR THE PARISH OF JEFFERSON
`
`NO. S2 9. ctm DIVISION:
`
`STATE OF LOUISIANA
`
`FILED:
`
`REGINALD BLANCHARD
`
`VERSUS
`
`ABBOTT LABORATORIES
`
`DEPUTY CLERK
`
`PETITION FOR DAMAGES
`
`TO THE HONORABLE 2411-1 JUDICIAL DISTRICT COURT FOR THE PARISH OF
`JEFFERSON AND THE JUDGES THEREOF:
`
`The original Petition for Damages of Reginald Blanchard, through undersigned counsel,
`
`respectfully represents:
`
`PARTIES
`
`1.
`
`Petitioner, Reginald Blanchard, is of the full age of majority and is a resident of and
`
`domiciled in the Parish of Orleans, State of Louisiana.
`
`2.
`
`Made defendant herein is ABBOTT LABORATORIES ["Abbott"), a foreign
`
`corporation, which, at all times pertinent herein, was authorized to do and doing business within
`
`the State of Louisiana and within the jurisdiction of this Honorable Court.
`
`VENUE
`
`3.
`
`Venue is proper in this judicial district pursuant to Louisiana Code of Civil Procedure
`
`article 74, as Mr. Blanchard's injuries and damages were sustained in the Parish of Jefferson,
`
`State of Louisiana.
`
`4.
`
`Defendant, Abbott Laboratories, is subject to personal jurisdiction in the State of
`
`Louisiana because, at all relevant times, it conducted substantial business in the State of
`
`Louisiana by placing products that it developed and manufactured into a stream of commerce
`
`

`

`that included distribution in the State of Louisiana. Upon information and belief, Defendant also
`
`maintains a principal business office in the State of Louisiana.
`
`FACTUAL BACKGROUND
`
`5.
`
`In August of 2015, Mr. Reginald Blanchard, had a "St. Jude DDD-R dual chamber"
`
`pacemaker device implanted due to complete heart block. According to Mr. Blanchard's St. Jude
`
`Medical Cardiac Pacemaker Patient Identification Card, the pacemaker and pacing leads
`
`implanted in August of 2015 were: PIG—Model No. PM2240, Serial No. 7668717; RV-
`
`LEAD—Model No. 1948/52, Serial No. CPCO24884; RA-LEAD—Model No. 1882TC/46,
`
`Serial No. CWE021017.
`
`6.
`
`On February 3, 2021, Mr. Blanchard had an echocardiogram (ECHO) performed at
`
`Ochsner Medical Center that revealed a mildly dilated left ventricle with moderate systolic
`
`dysfunction. Mr. Blanchard's ejection fraction was noted to be 35%. The ECHO also showed
`
`that the inferoseptum, inferior, and inferolateral walls were severely hypokinetic with the
`
`remainder of the left ventricular walls being mildly hypolcinetic, as well as mild diastolic
`
`dysfunction.
`
`7.
`
`On February 5, 2021, Mr. Blanchard presented to Dr. 011e Kjellgren who determined that
`
`in light of the pronounced wall motion abnormality, Mr. Blanchard should undergo coronary
`
`angiography.
`
`8.
`
`On February 9, 2021, Mr. Blanchard underwent coronary angiography, the results of
`
`which showed that the left anterior descending artery ("LAD") had a mid 60% lesion, and the D1
`
`a 50% stenosis; the left ventriculograrn revealed the apex to be mildly dyskinetic and the inferior
`
`wall to be alcinetic; and the ejection fraction was 35%. It was felt that Mr. Blanchard should be
`
`treated medically for his coronary artery disease, and it appeared likely that the wall motion
`
`abnormality and the left ventricular dysfunction were related to ventricular ("V") pacing.
`
`

`

`9.
`
`In February of 2021, Mr. Blanchard was referred to Dr. Paul Rogers of Ochsner to
`
`discuss an upgrade to a cardiac resynchronization therapy pacemaker ("CRT-P").
`
`10.
`
`On February 25, 2021, Mr. Blanchard presented to Dr. Rogers for a consultation for his
`
`pacemaker and cardiomyopathy. An in-clinic device interrogation noted stable lead parameters
`
`with 13% right atrial (RA) and 99% right ventricular (RV) pacing. There was intermittent non-
`
`physiologic noise on the atrial lead that was reproduced with isometric arm movement. Dr.
`
`Rogers' interpretation of an in-clinic ECG was sinus rhythm with RV pacing (QRS duration
`
`170ms). Dr. Rogers' plan following his evaluation of Mr. Blanchard was to perform a left arm
`
`venogram, if patent, and then schedule a CRT-P upgrade.
`
`1 1.
`
`On March 18, 2021, Mr. Blanchard underwent an attempted dual camber upgrade to
`
`CRT-P/pocket revision; however, when the device and leads were exposed during the procedure,
`
`there were notable insulation breaks on the RV and RA leads of the "St. Jude DDD-R dual
`
`chamber" pacemaker. The procedure was aborted for planned extraction and reimplantation with
`
`upgrade to be arranged at a later date.
`
`12.
`
`On May 3, 2021, Mr. Blanchard underwent a pocket revision and total system extraction
`
`of his cardiac implantable device followed by reimplantation of CRT-P.
`
`13.
`
`According to the medical record, the original generator, RV lead, and RA lead were
`
`extracted during Mr. Blanchard's May 3, 2021, procedure. Upon information and belief, the
`
`device identified on Mr. Blanchard's St. Jude Medical Cardiac Pacemaker Patient Identification
`
`Card was returned to the manufacturer by Ochsner.
`
`14.
`
`Following the May 3, 2021 procedure, Mr. Blanchard began experiencing chest pains,
`
`and upon interrogation of his device, it was discovered that he had periods of noncapture during
`
`deep inspiration. On May 13, 2021, he underwent an RV lead revision.
`
`

`

`15.
`
`The explanted device was LEAD TENDRIL STS 58CM, Model No. 2088TC/58, Serial
`
`No. CAW358556, Lot No. RV LEAD. The manufacturer of this device was St. Jude Medical,
`
`Inc. (now "Abbott"). Following the procedure, the defective device was returned to Abbott.
`
`16.
`
`According to St. Jude Medical's Implantable Electronic Systems Product Performance
`
`Report, 2015 First Edition, Mr. Blanchard's pacemaker had an estimated longevity of 9.4 years.
`
`17.
`
`Upon information and belief, on March 20, 2021, a recall was issued by Abbott on the
`
`pacemaker that is identified on Mr. Blanchard's St. Jude Medical Cardiac Pacemaker Patient
`
`Identification Card.
`
`18.
`
`Upon information and belief, St. Jude was acquired by Abbott Laboratories in January of
`
`2017. Upon completion of the acquisition, St. Jude Medical became a wholly-owned subsidiary
`
`of Abbott and accordingly, Abbott is legally responsible for the tortious conduct complained of
`
`herein.
`
`FIRST CAUSE OF ACTION: CONSTRUCTION OR COMPOSITION DEFECT
`UNDER LA.R.S. § 9:2800.55, LOUISIANA PRODUCTS LIABILITY ACT
`
`19.
`
`At all times pertinent herein, Defendant, Abbott, was a "manufacturer" under Louisiana
`
`Revised Statute § 9:2800.53 of the Louisiana Products Liability Act, for it was engaged in the
`
`business of manufacturing, producing, making, fabricating, constructing, designing,
`
`remanufacturing, reconditioning, and/or refurbishing medical devices, including but not limited
`
`to Mr. Blanchard's pacemaker.
`
`20.
`
`At all times pertinent herein, Defendant's pacemakers, including but not limited to Mr.
`
`Blanchard's pacemaker, were expected to reach, and did reach, consumers in the State of
`
`Louisiana, including Mr. Blanchard, without substantial change in the condition in which it was
`
`sold.
`
`

`

`21.
`
`Defendant, Abbott, expressly represented to Plaintiff, Plaintiff's healthcare providers,
`
`other consumers, and the medical community that its pacemakers, including Mr. Blanchard's
`
`pacemaker, were safe and fit for their intended purpose, were of merchantable quality, and had
`
`been adequately tested.
`
`22.
`
`At all times material to this action, Mr. Blanchard's pacemaker was designed, developed,
`
`manufactured, tested, packaged, promoted, marketed, distributed, labeled, and/or sold by
`
`Defendant in a defective and unreasonably dangerous condition at the time it was placed in the
`
`stream of commerce in ways which include, but are not limited to, one or more of the following:
`
`a.
`
`When placed in the stream of commerce, the pacemaker contained
`
`manufacturing defects, which rendered the subject product unreasonably
`
`dangerous;
`
`b.
`
`C.
`
`d.
`
`The pacemaker's manufacturing defects occurred while the product was in the
`
`possession and control of the Defendant;
`
`The pacemaker was not made in accordance with the Defendant's
`
`specifications or performance standards; and/or
`
`The pacemaker manufacturing defects existed before it left the control of the
`
`Defendant.
`
`23.
`
`The pacemaker manufactured and/or supplied by Defendant was defective in construction
`
`or composition in that, when it left the hands of Defendant, it deviated in a material way from
`
`Defendant's manufacturing performance standards, and/or it differed from otherwise identical
`
`products manufactured according to the same design formula and/or specifications. Thus, the
`
`pacemaker was unreasonably dangerous in construction or composition as provided by La. R.S.
`
`9:2800.55.
`
`

`

`Said defects in Mr. Blanchard's pacemaker were a substantial factor in causing Plaintiff's
`
`24.
`
`injuries and damages.
`
`SECOND CAUSE OF ACTION: DESIGN DEFECT UNDER LA.R.S. 9:2800.56,
`LOUISIANA PRODUCTS LIABILITY ACT
`
`25.
`
`Mr. Blanchard's pacemaker was defective in its design and/or its formulation, in that it
`
`was not reasonably fit, suitable, or safe for its intended purpose and/or its foreseeable risks
`
`exceeded the benefits associated with its design and formulation. The subject product was
`
`unreasonably dangerous in design as provided by La. R.S. 9:2800.56.
`
`26.
`
`At all times material to this action, Mr. Blanchard's pacemaker was designed, developed,
`
`manufactured, tested, packaged, promoted, marketed, distributed, labeled, and/or sold by
`
`Defendant in a defective and unreasonably dangerous condition at the time it was placed in the
`
`stream of commerce in ways which include, but are not limited to, one or more of the following
`
`particulars:
`
`A. When placed in the stream of commerce, Mr. Blanchard's pacemaker contained
`
`unreasonably dangerous design defects and was not reasonably safe as intended to be
`
`used, subjecting Plaintiff to risks that exceeded the benefits of the subject product,
`
`including but not limited to serious and permanent personal injuries;
`
`B. When placed in the stream of commerce, Mr. Blanchard's pacemaker was defective
`
`in design and formulation, making the use of it more dangerous than an ordinary
`
`consumer would expect, and more dangerous than other risks associated with the
`
`other joint replacements on the market;
`
`C. The design defect in Mr. Blanchard's pacemaker existed before it left the control of
`
`the Defendant;
`
`D. Mr. Blanchard's pacemaker was insufficiently tested;
`
`E. Mr. Blanchard's pacemaker caused harmful side effects, injuries, and/or damages that
`
`outweighed any potential utility; and/or
`
`

`

`F. Mr. Blanchard's pacemaker was not accompanied by adequate instructions and/or
`
`warnings to fully apprise Plaintiff and/or his healthcare providers, of the full nature
`
`and extent of the risks and side effects associated with its use, thereby rendering
`
`Defendant liable to Plaintiff
`
`27.
`
`Mr. Blanchard's pacemaker was designed, researched, manufactured, tested, advertised,
`
`promoted, marketed, sold and distributed by Defendant, even though it was defective in design
`
`and/or formulation, in that, when it left the hands of the Defendant, it was unreasonably
`
`dangerous, and/or it was more dangerous than an ordinary consumer would expect, for Mr.
`
`Blanchard's pacemaker was not designed and/or formulated to last.
`
`28.
`
`At all times herein mentioned, Mr. Blanchard's pacemaker was in a defective condition
`
`and unsafe, and Defendant knew, or should have known, that at all times herein mentioned, Mr.
`
`Blanchard's pacemaker was in a defective condition and was inherently dangerous and unsafe.
`
`29.
`
`In addition, at the time the pacemaker left the control of the Defendant, there was a
`
`practical and feasible alternative design that would have prevented and/or significantly reduced
`
`the risk of Mr. Blanchard's injuries without impairing the reasonably anticipated or intended
`
`function of the product. These safer alternative designs were economically and technologically
`
`feasible, and would have prevented or significantly reduced the risk of Plaintiffs injuries without
`
`substantially impairing the product's utility.
`
`30.
`
`Mr. Blanchard's pacemaker was defective in its design and/or its formulation, in that it
`
`was not reasonably fit, suitable, or safe for its intended purpose and/or its foreseeable risks
`
`exceeded the benefits associated with its design and formulation. Thus, the subject product was
`
`unreasonably dangerous in design as provided by La.R.S. 9:2800.56.
`
`

`

`Mr. Blanchard could not, by the exercise of reasonable care, have discovered the defects
`
`31.
`
`herein mentioned and/or perceived the danger in the pacemaker.
`
`32.
`
`Said defects in Mr. Blanchard's pacemaker were a substantial factor in causing Plaintiff's
`
`injuries and damages.
`
`THIRD CAUSE OF ACTION: INADEQUATE WARNING UNDER LA.R.S. 9:2800.57,
`LOUISIANA PRODUCTS LIABILITY ACT
`
`33.
`
`Mr. Blanchard's pacemaker was defective and/or unreasonably dangerous when it left the
`
`possession of the Defendant, in that it contained warnings insufficient to alert consumers,
`
`including Mr. Blanchard herein, and his health care providers, of the dangerous risks and
`
`reactions associated with the subject product. Thus, the subject product was unreasonably
`
`dangerous because an adequate warning was not provided as required by La. R.S. § 9:2800.57.
`
`Said defects in Mr. Blanchard's pacemaker were a substantial factor in causing Plaintiff's
`
`34.
`
`injuries and damages.
`
`FOURTH CAUSE OF ACTION: BREACH OF EXPRESS WARRANTY UNDER LA.R.S.
`9:2800.58, LOUISIANA PRODUCTS LIABILITY ACT
`
`35.
`
`Defendant expressly represented to Mr. Blanchard and/or to Mr. Blanchard's healthcare
`
`providers that Mr. Blanchard's pacemaker was safe and fit for its intended purposes, was of
`
`merchantable quality, and had been adequately tested.
`
`36.
`
`Mr. Blanchard's pacemaker did not conform to Defendant's express representations
`
`because it was not safe and in fact, caused him severe injuries and damages.
`
`37.
`
`At the time of the making of the express warranties, Defendant knew or should have
`
`known of the purpose for which its subject product was to be used and warranted the same to be,
`
`

`

`in all respects, fit, safe, and effective and proper for such purpose. Mr. Blanchard's pacemaker
`
`was unreasonably dangerous because it failed to conform to an express warranty of the
`
`defendants as provided by La.R.S. § 9:2800.58.
`
`FIFTH CAUSE OF ACTION: BREACH OF IMPLIED WARRANTY OF
`MERCHANTABILITY AND FITNESS
`
`38.
`
`The Defendant impliedly represented and warranted to Mr. Blanchard and/or to Mr.
`
`Blanchard's healthcare providers that Mr. Blanchard's pacemaker was safe and of merchantable
`
`quality and fit for the ordinary purpose for which said product was to be used.
`
`39.
`
`At all relevant times, Defendant knew of the use for which Mr. Blanchard's pacemaker
`
`was intended and impliedly warranted the product to be of merchantable quality and safe and fit
`
`for such use.
`
`40.
`
`Defendant was aware that Mr. Blanchard and/or his healthcare providers would use the
`
`pacemaker in the manner intended.
`
`41.
`
`Plaintiff and his healthcare providers reasonably relied upon the judgment and sensibility
`
`of Defendant in purchasing the pacemaker, but only if it was indeed of merchantable quality and
`
`safe and fit for its intended use.
`
`42.
`
`Defendant breached an implied warranty to Mr. Blanchard, as his pacemaker was not of
`
`merchantable quality or safe and fit for its intended use.
`
`43.
`
`Consumers, including Plaintiff and/or his healthcare providers, reasonably relied upon
`
`Defendant's implied warranty in purchasing and/or using the pacemaker.
`
`44.
`
`Mr. Blanchard's pacemaker reached Mr. Blanchard without substantial change in the
`
`condition in which it was manufactured and sold by Defendant.
`
`

`

`45.
`
`Nevertheless, Defendant's aforementioned representations and warranties were false,
`
`misleading, and inaccurate, for Mr. Blanchard's pacemaker was unsafe, unreasonably dangerous,
`
`improper, not of merchantable quality, and/or defective.
`
`46.
`
`Mr. Blanchard and/or his physicians and healthcare providers reasonably relied upon the
`
`skill and judgment of Defendant as to whether Mr. Blanchard's pacemaker was of merchantable
`
`quality and safe and fit for its intended use.
`
`47.
`
`Mr. Blanchard's pacemaker was placed into the stream of commerce by the Defendant in
`
`a defective, unsafe, and inherently dangerous condition, and the product was expected to and did
`
`reach Mr. Blanchard in the condition in which it was sold.
`
`48.
`
`The Defendant breached the aforesaid implied warranties, as Mr. Blanchard's pacemaker
`
`was not fit for its intended purpose and use.
`
`SIXTH CAUSE OF ACTION: REDHIBITION
`
`49.
`
`Mr. Blanchard's pacemaker contained a vice or defect which rendered it useless or
`
`otherwise, its use was so inconvenient that Mr. Blanchard would not have purchased it.
`
`50.
`
`Defendant sold and promoted pacemakers, which Defendant placed into the stream of
`
`commerce. Under Louisiana law, the seller warrants the buyer against redhibitory defects, or
`
`vices, in the thing sold. La. C.C. art. 2520. The subject product, sold and promoted by
`
`Defendant, possessed a redhibitory defect because it was not manufactured and marketed in
`
`accordance with industry standards and/or was unreasonably dangerous, as described above,
`
`which rendered the subject product useless or otherwise, so inconvenient that it must be
`
`presumed that a buyer would not have bought the subject product had she known of the defect.
`
`

`

`Pursuant to La. C.C. art. 2520, Plaintiff is entitled to obtain a rescission of the sale of the
`
`pacemaker.
`
`51.
`
`Alternatively, Mr. Blanchard's pacemaker possessed a redhibitory defect because the
`
`subject product was not manufactured and/or marketed in accordance with industry standards
`
`and/or is unreasonably dangerous, as described above, which diminished the value of the subject
`
`product, such that it must be presumed that a buyer would still have bought it, but for a lesser
`
`price. In this instance, Mr. Blanchard is entitled to a reduction of the purchase price, in addition
`
`to the damages caused by the redhibitory defect(s).
`
`SEVENTH CAUSE OF ACTION: BREACH OF WARRANTY OF FITNESS FOR
`ORDINARY USE
`
`52.
`
`In addition to warranting against redhibitory defects, Defendant warranted that the
`
`pacemaker was reasonably fit for its ordinary and intended use. La. C.C. art. 2524.
`
`53.
`
`Nevertheless, the pacemaker was not safe, had numerous and serious side effects, and
`
`caused severe and permanent injuries. As a result, Defendant's device was unfit and inherently
`
`dangerous for ordinary use.
`
`54.
`
`If any of the above-listed causes of action are found to be contradictory, they are pled in
`
`the alternative.
`
`DAMAGES
`
`55.
`
`As a result of the foregoing acts and/or omissions of Defendant, Abbott Laboratories,
`
`through its wholly owned subsidiary St. Jude Medical, Inc., Mr. Blanchard suffered severe and
`
`painful personal injuries and damages. Said injuries and damages include:
`
`A. Past and future physical pain and suffering;
`
`B. Past and future mental anguish and emotional distress;
`
`C. Past and future medical expenses;
`
`

`

`D. Future medical monitoring;
`
`E. Loss of the enjoyment of life; and/or
`
`F. Loss of the chance of a better medical outcome (pled in the alternative to the
`
`above).
`
`PRAYER
`
`56.
`
`WHEREFORE, Petitioner, Reginald Blanchard, prays that Defendant, Abbott
`
`Laboratories, be served with a copy of this Petition for Damages and that, after due proceedings,
`
`there be judgment herein in favor of Petitioner and against Defendant, for all damages as are
`
`reasonable in the premises, together with legal interest thereon from the date of judicial demand
`
`until paid, for all costs of these proceedings, including attorneys' fees, and for all general and
`
`equitable relief, as well as a trial by jury.
`
`Respectfully submitted,
`
`ICARA HADICAN SAMUELS & ASSOCIATES, LLC
`
`6tLOD ( CAQ Q14411/10sCP
`
`HADICAN SAMUELS (#29234)
`TIFFANY A. MORALES (#36594)
`4004 Canal Street
`New Orleans, Louisiana 70119
`Telephone: (504) 558-9478
`Facsimile: (504) 558-9482
`Email: kara@karasamuels.com
`Email: tiffany@karasamuels.com
`Attorneys for Plaintiff
`
`Please serve:
`
`Defendant, Abbot Laboratories
`through its registered agent:
`CT Corporation System
`3867 Plaza Tower Dr.
`Baton Rouge, LA 70816
`
`A TRUE COPY OF THE ORIGINAL
`ON FIL IN THIS PFICE.
`4fi
`-(.40Cati/A0
`DEPUTY CLERK
`24TH JUDICIAL DISTRICT COURT
`pARISti Of JEFFERSON
`
`

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