IN THE UNITED STATESDISTRICT COURT 

FOR THE SOUTHERN DISTRICT OF OHIO

WESTERN DIVISION

THE MONTGOMERY COUNTY BOARD OF 

COUNTY COMMISSIONERS; and THE STATE 

OF OHIO EX REL. MATHIAS H. HECK, JR., 

PROSECUTING ATTORNEY,

Plaintiffs,

v.

PURDUE PHARMA L.P.; PURDUE PHARMA 

INC.; THE PURDUE FREDERICK COMPANY, 

INC.; TEVA PHARMACEUTICALS USA, INC.; 

CEPHALON, INC.; JOHNSON & JOHNSON; 

JANSSEN PHARMACEUTICALS, INC.; ORTHOMCNEIL-JANSSEN PHARMACEUTICALS, 

INC. N/K/A JANSSEN PHARMACEUTICALS, 

INC.; JANSSEN PHARMACEUTICA, INC. N/K/A 

JANSSEN PHARMACEUTICALS, INC.; ENDO 

HEALTH SOLUTIONS INC.; ENDO

PHARMACEUTICALS INC.; MALLINCKRODT 

LLC; MALLINCKRODT PLC; SPECGX LLC; and

JANE DOES 1-50, 

Defendants.

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Case No. 3:18-cv-293

Action Filed: July 25, 2018

Action Served: July 26, 2018

DEFENDANT ENDO PHARMACEUTICALS INC.’S NOTICE OF REMOVAL

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Pursuant to 28 U.S.C. §§ 1332, 1441, and 1446, defendant Endo Pharmaceuticals Inc. 

hereby gives notice of removal of this action, captioned The Montgomery County Board of 

County Commissioners et al. v. Purdue Pharma L.P. et al., bearing case number 2018 CV 03413, 

from the Court of Common Pleas for Montgomery County, Ohio, to the United States District 

Court for the Southern District of Ohio. Pursuant to 28 U.S.C. § 1446(a), Endo provides the 

following statement of the grounds for removal: 

BACKGROUND

1. This action is one of more than a thousand related lawsuits filed against 

manufacturers of FDA-approved prescription opioid medications on behalf of state and local 

governments relating to alleged harms stemming from abuse of these medications. On December 

5, 2017, the Judicial Panel on Multidistrict Litigation (“JPML”) created a Multidistrict Litigation 

(“MDL”) in the Northern District of Ohio that would include this case and the many others like it, 

i.e., cases in which “cities, counties and states . . . allege that . . . manufacturers of prescription 

opioid medications overstated the benefits and downplayed the risks of the use of their opioids 

and aggressively marketed . . . these drugs to physicians.” In re Nat’l Prescription Opiate Litig., 

MDL No. 2804, Doc. 328 (Dec. 5, 2017 Transfer Order) (attached as Exhibit 1). As the JPML 

found in centralizing these cases, “centralization will substantially reduce the risk of duplicative 

discovery, minimize the possibility of inconsistent pretrial obligations, and prevent conflicting 

rulings on pretrial motions. Centralization will also allow a single transferee judge to coordinate 

with numerous cases pending in state courts.” Id. at 3. More than a thousand opioid-related 

actions have been transferred to the MDL, with more (including this action) surely to follow. 

2. On July 25, 2018, Plaintiffs filed the Complaint in this action (attached as 

Exhibit 2) in the Court of Common Pleas for Montgomery County, Ohio, against the following 

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defendants: Endo Pharmaceuticals Inc.; Endo Health Solutions Inc.; Purdue Pharma L.P.; Purdue 

Pharma Inc.; The Purdue Frederick Company Inc.; Teva Pharmaceuticals USA, Inc.; Cephalon, 

Inc.; Johnson & Johnson; Janssen Pharmaceuticals, Inc.; Ortho-McNeil-Janssen Pharmaceuticals, 

Inc. n/k/a Janssen Pharmaceuticals, Inc.; Janssen Pharmaceutica, Inc. n/k/a Janssen 

Pharmaceuticals, Inc.; Mallinckrodt LLC; Mallinckrodt plc; and SpecGx LLC. 

3. As discussed below, all Defendants are citizens of states or foreign states other 

than Ohio, and the State of Ohio is not a real party-in-interest for purposes of diversity

jurisdiction. 

4. A virtually identical opioid-related action filed by the same lawyers was recently

removed on the same grounds as this case and is pending in the MDL, where all remand issues 

will be decided. See County of Portage et al. v. Purdue Pharma L.P. et al., No. 1:18-op-45993-

DAP (N.D. Ohio), Doc. 1 (Not. of Removal). As numerous courts in opioid-related actions have 

recognized, judicial economy would be furthered if all removal questions were addressed by the 

MDL Court following the transfer of this case to the MDL. See Village of Melrose Park et al. v. 

Purdue Pharma L.P. et al., No. 1:18-cv-05288 (N.D. Ill.), Doc. 26 (August 10, 2018 Minute 

Entry Staying Case); Robinson Rancheria v. McKesson Corporation et al., No. 3:18-cv-02525-

VC (N.D. Cal.), Doc. 23 (July 16, 2018 Order Granting Motions to Stay); Polk County v. Purdue 

Pharma L.P. et al., No. 8:18-cv-1814-VMC-AAS (M.D. Fla.), Doc. 3 (July 27, 2018 Order 

Staying Case); St. Bernard Parish Gov’t v. Purdue Pharma L.P. et al., No. 2:18-cv-02717-NJBDEK (E.D. La.), Doc. 21 (Mar. 29, 2018 Order Granting Stay); County of Floyd v. Purdue 

Pharma L.P. et al., No. 7:17-cv-00186-GFVT (E.D. Ky.), Doc. 18 (Jan. 22, 2018 Order Granting 

Stay); City of Miami v. Purdue Pharma L.P. et al., No. 1:18-cv-21920-KMM (S.D. Fla.), Doc. 7 

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(May 22, 2018 Order Staying Proceedings); Levy County v. Purdue Pharma L.P. et al., No. 1:18-

cv-00100-MCR-GRJ (N.D. Fla.), Doc. 26 (July 5, 2018 Order Staying Case).

5. Endo Pharmaceuticals Inc. received the Complaint through service on July 26, 

2018. Pursuant to 28 U.S.C. § 1446(a), a copy of all process and pleadings served on Endo 

Pharmaceuticals Inc. is attached hereto as Exhibit 2. A copy of the state court docket, all orders 

served on Endo Pharmaceuticals Inc. and all documents filed in the state court action (other than 

the Complaint) is attached hereto as Exhibit 3.

VENUE AND JURISDICTION

6. Venue is proper in this Court pursuant to 28 U.S.C. §§ 115, 1391, 1441(a), and 

1446(a) because the Court of Common Pleas for Montgomery County, Ohio, where the 

Complaint was filed, is a state court within the Southern District of Ohio.

7. This Court has subject matter jurisdiction under 28 U.S.C. § 1332(a) because 

(1) there is complete diversity of citizenship between the real Plaintiffs-in-interest and all 

Defendants; (2) the amount in controversy exceeds $75,000, exclusive of interests and costs; and 

(3) all other requirements for removal have been satisfied.

I. THERE IS COMPLETE DIVERSITY OF CITIZENSHIP BETWEEN THE REAL 

PLAINTIFFS-IN-INTERST AND ALL DEFENDANTS

8. There is complete diversity of citizenship here because the real Plaintiffs-ininterest are Ohio citizens and all of the Defendants are citizens of states or foreign states other 

than Ohio. 

A. Plaintiffs-In-Interest Are Ohio Citizens

9. Plaintiff Montgomery County Board of County Commissioners is a citizen of Ohio 

for purposes of diversity jurisdiction. See Moor v. Alameda Cty., 411 U.S. 693, 721 (1973) 

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(holding that Alameda County is a California citizen for purposes of diversity jurisdiction); Brown 

v. Marshall Cty., 394 F.2d 498, 500 (6th Cir. 1968). 

B. The State of Ohio Is Not a Real Party-In-Interest

10. “[A] federal court must disregard nominal or formal parties and rest jurisdiction 

only upon the citizenship of real parties to the controversy.” Navarro Sav. Ass'n v. Lee, 446 U.S. 

458, 461 (1980). In particular, “[w]hen a state is named as a party, federal courts must determine 

the real-party-in-interest, rather than simply relying on the names of the parties, to determine if 

there is diversity jurisdiction.” Berkowitz v. Brahma Inv. Grp., Inc., No. 1:14CV543, 2014 WL 

4206946, at *2 (S.D. Ohio Aug. 25, 2014). 

11. Plaintiffs allege that one of their seven causes of action, statutory public nuisance, 

is brought “in the name of the State of Ohio pursuant to the statutory authority granted under R.C. 

§ 3767.03, to abate a public nuisance and to enjoin further maintenance of the nuisance.” (Id.

¶ 305; see also id. ¶ 28.) Putting aside the defects of this claim, this allegation does not make the 

State of Ohio a real party-in-interest for purposes of federal diversity jurisdiction. In materially

identical circumstances, this Court has held that the State of Ohio is not a real party-in-interest in 

determining diversity jurisdiction because, among other reasons, the relief sought will not inure to 

the state alone. E.g., Berkowitz, 2014 WL 4206946, at *2-3 (denying remand motion where City

of Norwood law director brought nuisance claim “in the name of the state of Ohio” under R.C. 

§ 3767.03, holding that “the State of Ohio is not the real-party-in-interest”). 

C. None of the Defendants Is a Citizen of Ohio

12. For purposes of diversity jurisdiction, a corporation is “a citizen of every State and 

foreign state by which it has been incorporated and of the State or foreign state where it has its 

principal place of business . . . .” 28 U.S.C. § 1332(c)(1). A partnership is a citizen of every state 

in which its partners are citizens. See Americold Realty Tr. v. ConAgra Foods, Inc., 136 S. Ct. 

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1012, 1015 (2016); Hooper v. Wolfe, 396 F.3d 744, 748 (6th Cir. 2005). A limited liability

company is a citizen of every state in which its members are citizens. Delay v. Rosenthal Collins 

Grp., LLC, 585 F.3d 1003, 1005 (6th Cir. 2009).

13. Applying these principles, none of the Defendants is a citizen of Ohio.

14. Defendant Endo Health Solutions Inc. is a corporation organized under the laws of 

Delaware with its principal place of business in Malvern, Pennsylvania. (Compl. ¶ 35.)

15. Defendant Endo Pharmaceuticals Inc. is a corporation organized under the laws of 

Delaware with its principal place of business in Malvern, Pennsylvania. (Id.)

16. Defendant Purdue Pharma L.P. is a limited partnership organized under the laws of 

Delaware, none of whose partners are citizens of Ohio. (See id. ¶ 29.) Its partners are citizens of 

New York, Connecticut, Delaware, Texas, the British Virgin Islands, and Jersey, Channel Islands.

17. Defendant Purdue Pharma Inc. is a corporation organized under the laws of New 

York with its principal place of business in Stamford, Connecticut. (Id.)

18. Defendant The Purdue Frederick Company, Inc. is a corporation organized under 

the laws of New York with its principal place of business in Stamford, Connecticut. (Id.)

19. Defendant Teva Pharmaceuticals USA, Inc. is a corporation organized under the 

laws of Delaware with its principal place of business in North Wales, Pennsylvania. (Id. ¶ 31.)

20. Defendant Cephalon, Inc. is a corporation organized under the laws of Delaware 

with its principal place of business in Frazer, Pennsylvania. (Id.)

21. Defendant Johnson & Johnson is a corporation organized under the laws of New 

Jersey with its principal place of business in New Brunswick, New Jersey. (Id. ¶ 33.)

22. Defendant Janssen Pharmaceuticals, Inc. is a corporation organized under the laws 

of Pennsylvania with its principal place of business in Titusville, New Jersey. (Id.)

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23. Defendant Ortho-McNeil-Janssen Pharmaceuticals, Inc. n/k/a Janssen 

Pharmaceuticals, Inc. is a corporation organized under the laws of Pennsylvania with its principal 

place of business in Titusville, New Jersey. (Id.)

24. Defendant Janssen Pharmaceutica, Inc. n/k/a Janssen Pharmaceuticals, Inc. is a 

corporation organized under the laws of Pennsylvania with its principal place of business in 

Titusville, New Jersey. (Id.)

25. Defendant Mallinckrodt plc is an Irish public limited company headquartered in 

Staines-Upon-Thames, Surrey, United Kingdom. (Id. ¶ 37.) 

26. Defendant Mallinckrodt LLC is a limited liability company organized under the 

laws of Delaware (see id.), none of whose members are citizens of Ohio. Mallinckrodt LLC’s 

sole member is Mallinckrodt Enterprises LLC. Mallinckrodt Enterprises LLC’s members are 

Mallinckrodt Enterprises Holdings, Inc., a citizen of California; Ludlow Corporation, a citizen of

Massachusetts; and Mallinckrodt ARD Finance LLC. Mallinckrodt ARD Finance LLC’s sole 

member, Mallinckrodt ARD Inc., is a citizen of California.

27. Defendant SpecGx LLC is a limited liability company organized under the laws of 

Delaware (see id.), none of whose members are citizens of Ohio. SpecGx LLC’s sole member is 

Mallinckrodt LLC. Mallinckrodt LLC’s sole member is Mallinckrodt Enterprises 

LLC. Mallinckrodt Enterprises LLC’s members are Mallinckrodt Enterprises Holdings, Inc., a 

citizen of California; Ludlow Corporation, a citizen of Massachusetts; and Mallinckrodt ARD 

Finance LLC. Mallinckrodt ARD Finance LLC’s sole member, Mallinckrodt ARD Inc., is a 

citizen of California.

28. Accordingly, all of the Defendants are citizens of states or foreign states other than 

Ohio.

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D. The Citizenship of Doe Defendants Should Be Ignored

29. The citizenship of the unnamed, unidentified Jane Doe Defendants should be 

ignored for purposes of determining whether this action is removable based on diversity of 

citizenship. See 28 U.S.C. § 1441(b)(1) (“In determining whether a civil action is removable on 

the basis of [diversity of citizenship], the citizenship of defendants sued under fictitious names 

shall be disregarded.”).

II. THE AMOUNT IN CONTROVERSY EXCEEDS $75,000

30. “[A] defendant’s notice of removal need include only a plausible allegation that 

the amount in controversy exceeds the jurisdictional threshold.” Dart Cherokee Basin Operating 

Co., LLC v. Owens, 135 S. Ct. 547, 554 (2014). “[W]hen a defendant seeks federal-court 

adjudication, the defendant’s amount-in-controversy allegation should be accepted when not 

contested by the plaintiff or questioned by the court.” Id. at 553. 

31. Plaintiffs assert that Montgomery County has spent $37.8 million “to address the 

opioid epidemic . . . including expenses related to preventative information, education, and 

programing, Naloxone and other crisis intervention services, criminal justice services, ambulatory

withdrawal management, recovery housing, residential withdrawal management, and other 

addiction treatment services.” (Compl. ¶ 291.) Plaintiffs seek compensatory damages “in an 

amount in excess of $25,000 sufficient to . . . completely compensate for all damages alleged 

herein,” as well as punitive and treble damages. (Id. Prayer for Relief ¶¶ F-H.) Plaintiffs also 

seek disgorgement of Defendants’ revenues (id. Prayer for Relief ¶ I), which Plaintiffs allege to be 

in the billions of dollars (id. ¶ 24). It is thus clear that the alleged amount in controversy exceeds 

$75,000, exclusive of interest and costs.

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III. ALL OTHER REMOVAL REQUIREMENTS ARE SATISFIED

A. This Notice of Removal Is Timely

32. This Notice of Removal is timely filed. Endo Pharmaceuticals Inc. received the 

Complaint through service on July 26, 2018. Because Endo Pharmaceuticals Inc. filed the Notice 

of Removal on August 23, 2018, removal is timely. See 28 U.S.C. § 1446(b)(1). 

B. All Properly Joined And Served Defendants Consent to Removal

33. For purposes of removal based on diversity jurisdiction under 28 U.S.C. § 1332(a) 

and pursuant to 28 U.S.C. § 1446(b), all defendants who have been properly joined and served 

must consent to removal.

34. The following properly served Defendants consent to removal, as indicated by

their signing below: Purdue Pharma L.P.; Purdue Pharma Inc.; The Purdue Frederick Company

Inc.; Teva Pharmaceuticals USA, Inc.; Cephalon, Inc.; Janssen Pharmaceuticals, Inc.; OrthoMcNeil-Janssen Pharmaceuticals, Inc. n/k/a Janssen Pharmaceuticals, Inc.; Janssen 

Pharmaceutica, Inc. n/k/a Janssen Pharmaceuticals, Inc.; Mallinckrodt LLC; and SpecGx LLC. 

See City of Cleveland v. Ameriquest Mort. Sec., Inc., 615 F.3d 496, 501 (6th Cir. 2010) (codefendants may consent to removal by filing a written consent).

35. The following Defendants have not been properly served, and thus their consent to 

removal is not required: Mallinckrodt plc, Johnson & Johnson, and Endo Health Solutions Inc. 

Nevertheless, they consent to removal. The Defendants listed in this paragraph expressly reserve, 

and do not waive, all defenses related to service of process and personal jurisdiction. 

36. By filing this Notice of Removal, neither Endo Pharmaceuticals Inc. nor any other 

Defendant waives any defense that may be available to them and reserves all such defenses. If 

any question arises as to the propriety of the removal to this Court, Endo Pharmaceuticals Inc. 

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requests the opportunity to present a brief and oral argument in support of its position that this 

case has been properly removed.

CONCLUSION

WHEREFORE, Endo Pharmaceuticals Inc. hereby removes this action from the Court of 

Common Pleas, Montgomery County, to the United States District Court for the Southern 

District of Ohio. 

DATED: August 23, 2018 /s/ Carole S. Rendon

Carole S. Rendon (0070345) 

Tera N. Coleman (0090544) 

BAKER & HOSTETLER LLP 

Key Tower

127 Public Square, Suite 2000 

Cleveland, OH 44114-1214

(216) 621-0200

crendon@bakerlaw.com

tcoleman@bakerlaw.com

Ingo W. Sprie, Jr.*

ARNOLD & PORTER KAYE SCHOLER LLP

250 West 55th Street

New York, NY 10019-9710

(212) 836-8000 

Ingo.Sprie@arnoldporter.com

Sean Morris*

ARNOLD & PORTER KAYE SCHOLER LLP

777 S. Figueroa Street

44th Floor

Los Angeles, CA 90017

(213) 243-4000

Sean.Morris@arnoldporter.com

Attorneys for Defendant

ENDO PHARMACEUTICALS INC.

* denotes national counsel who will seek pro hac 

vice admission

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WRITTEN CONSENT OF OTHER 

DEFENDANTS

Consent to removal on behalf of Defendant ENDO 

HEALTH SOLUTIONS INC.:

/s/ Carole S. Rendon

Carole S. Rendon (0070345) 

Tera N. Coleman (0090544) 

BAKER & HOSTETLER LLP 

Key Tower

127 Public Square, Suite 2000 

Cleveland, OH 44114-1214

(216) 621-0200

crendon@bakerlaw.com

tcoleman@bakerlaw.com

Ingo W. Sprie, Jr.*

ARNOLD & PORTER KAYE SCHOLER LLP

250 West 55th Street

New York, NY 10019-9710

(212) 836-8000 

Ingo.Sprie@arnoldporter.com

Sean Morris*

ARNOLD & PORTER KAYE SCHOLER LLP

777 S. Figueroa Street

44th Floor

Los Angeles, CA 90017

(213) 243-4000

Sean.Morris@arnoldporter.com

* denotes national counsel who will seek pro hac 

vice admission

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Consent to removal on behalf of Defendants 

PURDUE PHARMA L.P., PURDUE PHARMA 

INC., and THE PURDUE FREDERICK 

COMPANY INC.:

/s/ Daniel J. Buckley

Daniel J. Buckley (3772)

VORYS, SATER, SEYMOUR and PEASE LLP

301 East Fourth Street

Suite 3500, Great American Tower

Cincinnati, OH 45202

(513) 723-4002

djbuckley@vorys.com

Mark S. Cheffo*

DECHERT LLP

Three Bryant Park, 1095 Avenue of the Americas

New York, NY 10036-6797

Tel: (212) 698-3500

Fax: (212) 698-3599

Mark.Cheffo@dechert.com

* denotes national counsel who will seek pro hac 

vice admission

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Consent to removal on behalf of Defendants 

TEVA PHARMACEUTICALS USA, INC., and 

CEPHALON, INC.:

/s/ Wendy West Feinstein

Wendy West Feinstein (0064973) 

MORGAN, LEWIS & BOCKIUS LLP 

One Oxford Centre, 32nd Floor 

Pittsburgh, PA 15219-6401

(412) 560-7455

wendy.feinstein@morganlewis.com

Steven A. Reed*

MORGAN, LEWIS & BOCKIUS LLP

1701 Market Street

Philadelphia, PA 19103

(215) 963-5000

steven.reed@morganlewis.com

Brian M. Ercole*

MORGAN, LEWIS & BOCKIUS LLP

200 S. Biscayne Blvd., Suite 5300

Miami, FL 33131-2339

brian.ercole@morganlewis.com

* denotes national counsel who will seek pro hac 

vice admission

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Consent to removal on behalf of Defendants 

JOHNSON & JOHNSON, JANSSEN 

PHARMACEUTICALS, INC., ORTHO-MCNEILJANSSEN PHARMACEUTICALS, INC. N/K/A 

JANSSEN PHARMACEUTICALS, INC., and 

JANSSEN PHARMACEUTICA, INC. N/K/A 

JANSSEN PHARMACEUTICALS, INC.:

/s/ Charles C. Lifland*

Charles C. Lifland*

O’MELVENY & MYERS LLP

400 S. Hope Street

Los Angeles, CA 90071

(213) 430-6000

clifland@omm.com

* denotes national counsel who will seek pro hac 

vice admission

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Consent to removal on behalf of Defendants 

MALLINCKRODT LLC, MALLINCKRODT 

PLC

1

, AND SPECGX LLC:

/s/ Marc J. Kessler

Marc J. Kessler (0059236)

HAHN LOESER & PARKS, LLP

65 E. State Street, Suite 1400

Columbus, Ohio 43215

Telephone: (614) 221-0240

Facsimile: (614) 221-5909

mkessler@hahnlaw.com

Brien T. O’Connor*

Andrew J. O’Connor*

ROPES & GRAY LLP

Prudential Tower, 800 Boylston Street

Boston, MA 02199-3600

Telephone: (617) 235-4650

Brien.O’Connor@ropesgray.com

Andrew.O’Connor@ropesgray.com

* denotes national counsel who will seek pro hac 

vice admission

 

1 Mallinckrodt plc, an Irish Company, has not been properly served and expressly reserves all

defenses related to personal jurisdiction and service of process.

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CERTIFICATE OF SERVICE

The undersigned hereby certifies that a copy of the foregoing is being served upon the following 

by regular United States mail, postage prepaid:

Mathias H. Heck, Jr.

Montgomery County Prosecuting Attorney

301 West Third Street

P.O. Box 972

Dayton, Ohio 45422

Mary E. Montgomery

Assistant Montgomery County Prosecuting 

Attorney

Chief, Civil Division

301 West Third Street

P.O. Box 972

Dayton, Ohio 45422

Linda Singer

Elizabeth Smith

MOTLEY RICE LLC

401 9th Street NW

Suite 1001

Washington, DC 200024

Lisa Saltzburg

MOTLEY RICE LLC

28 Bridgeside Blvd.

Mount Pleasant, South Carolina 29464

Attorneys for Plaintiffs

Daniel J. Buckley

VORYS, SATER, SEYMOUR and 

PEASE LLP

301 East Fourth Street

Suite 3500, Great American Tower

Cincinnati, OH 45202

Mark S. Cheffo

DECHERT LLP

Three Bryant Park, 1095 Avenue of the 

Americas

New York, NY 10036-6797

Attorneys for Defendants Purdue Pharma L.P., 

Purdue Pharma Inc., and The Purdue Frederick 

Company Inc.

Wendy West Feinstein

MORGAN, LEWIS & BOCKIUS LLP

One Oxford Centre, 32nd Floor

Pittsburgh, PA 15219-6401

Steven A. Reed

MORGAN, LEWIS & BOCKIUS LLP

1701 Market Street

Philadelphia, PA 19103

Brian M. Ercole

MORGAN, LEWIS & BOCKIUS LLP

200 S. Biscayne Blvd., Suite 5300

Miami, FL 33131-2339

Attorneys for Defendants Teva Pharmaceuticals 

USA, Inc. and Cephalon, Inc.

Charles C. Lifland

O’MELVENY & MYERS LLP

400 S. Hope Street

Los Angeles, CA 90071

Attorneys for Defendants Johnson & Johnson, 

Janssen Pharmaceuticals, Inc., Ortho-McNeilJanssen Pharmaceuticals, Inc. n/k/a Janssen 

Pharmaceuticals, Inc., and Janssen 

Pharmaceutica, Inc. n/k/a Janssen 

Pharmaceuticals, Inc.

Marc J. Kessler

HAHN LOESER & PARKS, LLP

65 E. State Street, Suite 1400

Columbus, Ohio 43215

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Brien T. O’Connor

Andrew J. O’Connor

ROPES & GRAY LLP

Prudential Tower, 800 Boylston Street

Boston, MA 02199-3600

Attorneys for Defendants Mallinckrodt LLC, 

Mallinckrodt plc and SpecGx LLC

Dated: August 23, 2018

/s/ Carole S. Rendon

Attorney for Defendant Endo Pharmaceuticals Inc.

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