II.
PARTIES1.1 Plaintiffs/Class Representative(s).
(a) Dwight Williams is a resident of Orange County, Texas.
(b) Chana McIntyre is a resident of Orange County, Texas.
(c) Chad Pilitere is a resident of Orange County, Texas.
2.2 Service of Process
(a) The Defendant Warner-Lambert Consumer Healthcare N.K.A Pfizer, Inc. is a New Jersey corporation doing business in Texas for the purpose of accumulating monetary profit and has not designated a registered agent for service in the State of Texas and does not maintain a regular place of business in Texas. Plaintiffs hereby serve the Secretary of State of the State of Texas pursuant to the Texas Long Arm Statute Tex. Civ. Prac. & Rem. Code § 17.044 and ask the Secretary of State to serve Defendant, Warner-Lambert Consumer Healthcare N.K.A. Pfizer, Inc., at its home office via Certified Mail - Return Receipt Requested located at 1201 Tabor Rd., Morris Plains, New Jersey 07950.
(b) The Defendant Bayer Corporation is a Pennsylvania corporation doing business in Texas for the purpose of accumulating monetary profit and has not designated a registered agent for service in the State of Texas and does not maintain a regular place of business in Texas. Plaintiffs hereby serve the Secretary of State of the State of Texas pursuant to the Texas Long Arm Statute Tex. Civ. Prac. & Rem. Code § 17.044 and ask the Secretary of State to serve Defendant, Bayer Corporation, at its home office via Certified Mail - Return Receipt Requested located at 100 Bayer Road, Pittsburgh, PA 15205-9741.
(c) The Defendant Del Pharmaceutical, Inc., a wholly-owned subsidiary of Defendant Del Laboratories, Inc. is a Delaware corporation doing business in Texas for the purpose of accumulating monetary profit which has not designated a registered agent for service in the State of Texas and does not maintain a regular place of business in Texas. Plaintiffs hereby serve the Secretary of State of the State of Texas pursuant to the Texas Long Arm Statute and ask the Secretary of State to serve Defendant, Del Pharmaceuticals, Inc., at its home office located at 178 EAB Plaza, Uniondale, New York 11556.
(d) The Defendant Del Laboratories, Inc. is a Delaware corporation doing business in Texas for the purpose of accumulating monetary profit which has not designated a registered agent for service in the State of Texas and does not maintain a regular place of business in Texas. Plaintiffs hereby serve the Secretary of State of the State of Texas pursuant to the Texas Long Arm Statute and ask the Secretary of State to serve Defendant, Del Laboratories, Inc., at its home office located at 178 EAB Plaza, Uniondale, New York 11556.
(e) The Defendant Care Technologies, Inc. is a Connecticut corporation doing business in Texas for the purpose of accumulating monetary profit which has not designated a registered agent for service in the State of Texas and does not maintain a regular place of business in Texas. Plaintiffs hereby serve the Secretary of State of the State of Texas pursuant to the Texas Long Arm Statute and ask the Secretary of State to serve Defendant, Care Technologies, Inc., at its home office located at 10 Corbin Drive, Darien, Connecticut 06820.
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Lawsuit Sections
| Legal Header | |
| II | Parties to the Action |
| III | Class Action Allegations |
| IV | Class Definition |
| V | Jurisdiction and Venue |
| VI - VII | Facts as to the Plaintiffs / Defendants / Class |
| IX | Causes of Action |
| X | Breach of Implied Warranty |
| XI | Breach of Express Warranty |
| XII | Fraud |
| XIII | Negligent Misrepresentation |
| XIV | Damages |
| XV - XVI | Attorney's Fees / Request for Jury Trial |
| XVII | Stiuplations |
| XVIII | Prayer |
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