Jarreau v. Janssen Pharmaceuticals, Inc. et alMOTION for Summary JudgmentE.D. La.December 14, 2017 00458591 UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF LOUISIANA THEODORE JARREAU v. CIVIL ACTION NO. 16-12417 JUDGE: VANCE MAGISTRATE: NORTH JANSSEN PHARMACEUTICALS, INC., JOHNSON & JOHNSON, JANSSEN RESEARCH AND DEVELOPMENT, L.L.C., PATRIOT PHARMACEUTICALS, LLC, BRENN DISTRIBUTION, INC., AND ENDO PHARMACEUTICALS, INC. DEFENDANTS' MOTION FOR SUMMARY JUDGMENT NOW INTO COURT come Defendants, Janssen Pharmaceuticals, Inc., Johnson & Johnson, Janssen Research and Development, LLC, and Patriot Pharmaceuticals, LLC (hereinafter "Defendants"), who respectfully request that this Court dismiss Plaintiff's claims against Defendants with prejudice. As explained fully in the accompanying Memorandum in Support, this Motion should be granted because Plaintiff has failed to set forth any evidence — fact or expert — in support of his claims in this case, and the time to produce such expert evidence has passed. Expert evidence is required under the Louisiana Product Liability Act, LA. REV. STAT. § 9:2800.51, et seq. ("LPLA") for claims involving alleged injuries associated with pharmaceutical products. Without it, Plaintiff's claims should be dismissed. WHEREFORE, Defendants respectfully request that this Court grant their motion for summary judgment and dismiss Plaintiff's claims with prejudice, at his cost. Case 2:16-cv-12417-SSV-MBN Document 42 Filed 12/14/17 Page 1 of 2 00458591 Respectfully submitted, IRWIN FRITCHIE URQUHART & MOORE LLC BY: /s/ Gretchen F. Richards________________ JAMES B. IRWIN (La. Bar No. 7172) DOUGLAS J. MOORE (La. Bar No. 27706) MEERA U. SOSSAMON (La. Bar No. 34797) GRETCHEN F. RICHARDS (La. Bar No. 35782) 400 Poydras Street, Suite 2700 New Orleans, Louisiana 70130 Telephone: (504) 310-2100 Fax: (504) 310-2101 jirwin@irwinllc.com dmoore@irwinllc.com msossamon@irwinllc.com grichards@irwinllc.com Counsel for Defendants Janssen Pharmaceuticals Inc., Johnson & Johnson, Janssen Research and Development, LLC, and Patriot Pharmaceuticals, LLC CERTIFICATE OF SERVICE I hereby certify that on this 14th day of December, 2017, I electronically filed the foregoing with the Clerk of the Court using the CM/ECF system. And I hereby certify that I have emailed and mailed by United States Postal Service the document to the following non-CM/ECF participants: Theodore Jarreau, pro se 2549 Delery Street New Orleans, LA 70117 /s/ Gretchen F. Richards_________ Case 2:16-cv-12417-SSV-MBN Document 42 Filed 12/14/17 Page 2 of 2
