‘SUPREME COURT OF THE STATE OF NEW YORK.
COUNTY,
Soars J acres omonons DVS Sle
Plaintiffs), |
|
ae Summons
ie sacs drt coe
Date Index No. Pucchased: —sguayy2¢2018
To the above named Defendant(s)
Pet ama.
Fegite!Aget Comune Se Company, 6 Sse Ste any. NY 1207
‘You ate hereby summoned to answer the complaint in this action and to serve
‘ copy of your answer, or, if the complaint is not served with this summons, to serve
‘notice of appearance, on the Plaintiffs attorney within 20 days after the service of
this summons, exclusive of the day of service (ar within 90 davs after the service is
complete if this summons is not personally delivered to you within the State of New
‘York); and in ease of your failure to appear or answer, judgment wil be taken against
you by default for the relief demanded in the complaint.
‘The basis of venue is. Putas sce ots
Which is se\iaan tee Rena ny 48
Dated: sony 2208
by.
Miwa On, Canty Moray
‘Auorneys for Plintift
Seveuon See
eceern ea 5
Ena Weiaenremoscnt gov‘SUPREME COURT OF THE STATE OF NEW YORK
Index No, meennanne, 0/9501
against | Summons
esos acta |
Date Index No, Purchased: sgueyn ne
Defendant).
‘To the above named Defendant(s)
‘pated here Cosas Seca Conpicy 88 ate Soe Abo NY 12207
‘Yow are hereby sumone’! (o answer the complaint in this action and to serve
copy of your answer, or, if the complaint is not served with this summons, to serv>
‘a natice of appearance, on the Plaintiff's attorney within 20 days after the service of
this summons, exciusive of the day of service (or within 30 days after the service is
complete if this summons is not personally delivered to you within the State of New
York); and in case of your failure to appear or answer, judgment will be taken against
xyou by default for the relief demanded in the complaint.
‘The basis of venue is. aas pace otores
Which is sows Sax Rosen AY 4
{vos COUT YEW YORK
aie ba [Za 7K
Mien, Cowl Atarsy
tony ia
Somme
Era MtCorbmaneeconty 60
Dated: Jonny242018SUPREME COURT OF THE STATE OF NEW YORK
COUN’ *
“THE COUNTY OF MONROE | Indox No, (renner 20] $-Su!
Fins, |
against. Sammons
[oe stachad er fa come at eda)
|
[Pate index No, Purchased: aya 208
‘To the above named Defendant(s)
Regie igen Cpnts Src Conny, Se Sta Atay NY 2207
‘Yoware hereby summene'l 10 answer the complaint in this action and fo serve
‘ copy of your answer, o, ifthe complaint is not served with this summons, to serve
‘notice of appearance, on the Plaintiff's attorney within 20 days after the service of
this summons, exclusive of the day of sewvice (or within 80 days after the service is
complete if this summons is not personally delivered to you within the State of New
‘York; and in case of your failure to appear or answer, judgment will be taken against
‘you by default for the relief demanded in the complaint.
‘The basis of venue is rubste pact bane
Which is so¥. ain Sex, Roomate Wy 6
Dated: swumy24201
a z
“ees ts
Aton Pat
soma
nar MeieeDainewencnty ge
fla,
ov14SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF wosnoe
Seen ] Indes No, emtmnawnnr P01 8 “Sle |
Plants,
| Summons
ogo
rsionanntrscpntttitens |
Date Index No. Purchased: —Jeuar242018
__ Defendant, |
‘To the above named Defendant(s)
TEVAPHARWACEUTOALS USA Me,
Fae ger Coperale reson ta, 1Nadh Ml Sitch, HY 1860
‘You are hefeby suimmoned to answer the complaint in this action and to serve
‘copy of your answer or, if the complaint is not served with this summons, to serve
‘ notice of appearance, on the Plaintiff's attorney within 20 days after the service of
this summons, exclusive of the day of service (or within 80 days after the service is
complete if this summons is not personally deliveved to you within the State of New
York); and in case of your failure to appear or answer, judgment will be taken agai
you by default for the relief demancied in the complaint.
‘The basis of verue is Pers aoe orbuinese
Which is s9w usin ors och 184
Dated sansey24 20,
= coun von
Lf 2,
toe Oo, Easy ey
Atraeys fr Plinit
Ent aiusSeiemanosssry gov‘SUPREME COURT OF THE STATE OF NEW YORK
coun
Te coumvornomoe | Index No. tetany 20] § SL
Plaintifi(s), |
aginst: | Simons
eaters
Date Index No. Purchased) spay ann
Defendant
To the above named Defendant(s)
cepunton, we,
Regu get Caper 1 80
en at, Noh Se ya
‘You are Wereby summoned to answer the complaint in this ection and to serve
‘ copy of your answer, or, if the complaint is not served with this summons, to serve
a notice of appearance, on the Plaintiffs attorney within 20 days after the tervice of
this summons, exclusive of the day of service (or within 30 days after the service is
complete if this summons is not personally delivered to you within the State of New
York); and in case of your failure to appear or answer, judgment will be takten against
‘you by default for the relief demanded in the complaint.
‘The basis of venue is Pavan sicesttuinese
Which is sow. nan Soa Rete NY 1814
Dated: sen 242018
sor
by. i
“anna
Atco
oor
Ee‘SUPREME COURT OF THE STATE OF NEW YORK
econ Orne Indes No, orennenrs 0/§-5lol
Plaintiis), |
Summons
-against- |
PUROUE PHARIAL Pe |
|
beeamowerin te acegnastnen) |
Date Index No. Purchased jauayze2018
fendant(s),
‘To the above named Defendant(s)
‘re dshaen dohson Pas, New Bnew, W083
~You are Tisveby WUisioned to answer the complaint in this aclion and to serve
«8 copy of your answer, o, if the complaint is not served with this summons, to serve
«a notice of appearance, on the Plaintiff's attorney within 20 days after the service of
this summons, exclusive of the day of service (or within 30 days after the service is
complete if this summons is not personally delivered to you within the State of New
York); and in ease of your failure to appear or anawer, judgment will be taken against
xyou by default for the relief demanded in the complaint,
‘The basis of venue is. Paras pc otbsnss
Which is sev ssn tae Rebs ny ot
Dated: seuny24,2018
by
a Cae, Can aanay
Attorneys for Plaitift
207 County oe BungSUPREME COURT OF THE STATH OF NEW YORK
OUNTY OF woos
‘TH COUNTY oF Hono | Index No, teensy 90] -SLa t
|
Plaintiffs), |
Summons
against
[oe ase irra cont eendes
Date Index No, Purchased sayy 201
__Defendant(s). |
‘To the above named Defendant(s)
ANSSEN PHARMACEUTICALS
eget igo CY Conmaten Salen 90, td Sr Sie 41, Hanah PAAT101
‘You are hereby summoned to answer the complaint in this action and to serve
' copy of your answer, or, if the complaint is not served with this summons, to serve
4 notice of appearance, on the Plaintiffs attorney within 20 days after the gervice of
this summons exclusive of the day of service (or within 30 days after the service is
complete if this summons is not personally delivered to you within the State of New
York); and in case of your failure to appear or answer, judgment will be taken against
you by default for the relief demanded in the complaint.
‘The basis of venue is Panesyacectuceess
Which is spvzan seed Rech HY 816
Dated: Jonan21. 20,
1 COUNTY NW YORK
=
che Cae, Coury ary
Attorneys for Plainift
swan Sea
En teioeOngnersecgor‘SUPREME COURT OF THE STATE OF NEW YORK
4
‘ne coumrroruonwoe ] index Ne, smenvanny DIF -5U |
Pent
|
-ogainst. | Simmons
ue MAL |
tect testes) |
Date Index No, Purchased yy 24a
Defordant().
‘To the above named Defendant(s)
(SETHOMCNL IMSEN PHARUACEUTICAL, NC MUA JANSSEN PHARMACEUTICAL, NC.
Regated get CT cepomion Seta 801 a San, Ste Hae LY
~~ You ave hereby sumimoned to anawer the complaint in this action and to serve
‘ copy of your answer, or ifthe complaint is not served with this summons, o serve
' notice of appearance, on the Plaintiff attorney within 20 days after the service of
this summons, exclusive of the day of service (or within 30 days after the service is
complete if this summons is no: personally delivered to you within the State of New
York); and in case of your faiur» to appear or answer, judgment will be taken against
you by default for the relief dersanded in the complaint
‘The basis of venue is rovite pas ottuines
Which is s0¥. ainsi Roost te
Dated: Jou 24 2018
by, a >
on Ova, out Any
Attorneys for Plaintiff
sewer see
Eat icine setSeawonenn govSUPREME COURT OF THE STATE OF NEW YORK.
meee Trader, nvr fp 8-5 lo!
oe | Summons
{ee anaches Per ora compete et of cetendants) |
| Date Index No. Purchased: Aanuery 26,2008
Delonte,
‘To the above named Defendant(s)
{PNSSEN PeARQACEUTICA WNC MICA NSSEN PRARUACEUTICAL, NC,
ieee igen CF Copan Syston 50M. a Seat ae A. Hag PA 104
“You ave Tierely summoned to answer the complaint in this action and to serve
copy of your answer, or, if the complaint is net served with this summons, serve
‘ notice of appearance, on the Plaintiff's attorney within 20 days after the service of
this summons, exclusive of the day of service (or within 30 days after the service is
complete if this summons is not personally delivered to you within the State of New
York); and in case of your failure to appear or answer, judgment will be taken against
you by default for the relief demanded in the complaint.
‘The basis of venue is Panorspuee esha
Which is seWsn sia Retest Yt
Dated: sousy 24208
wd S775
eet Oe, ot May
Attorneys for Plait
Svea Sea?
Ema cheeDevagomancecouny gorSUPREME COURT OF THE STATE OF NEW YORK
ITY OF wonroe
‘ye counTvorvomoe Index No, penne gl) |G- BU |
Plaintiffs),
Summons
i
sega |
peeeeeres |
pacer tan ney
Date index No, Purchased: yay 2.2
Defendant(s). |
‘To the above named Defendant(s)
Fags Ape." Ceporwon Sem. 41 Gah Aa Nr a HY 101
‘You ate hereby summoned to answer the complaint in this action and to serve
«8 copy of your answer, or, if the complaint is not served with this summons, to serve
‘ notice of appearance, on the Plaintiff's attorney within 20 days after the service of
this summons, exclusive of the day of service (or within 80 days after the service is
complete if this summons is not personally delivered to you within the State of New
York); and in case of your failure to appear or answer, judgment will be taken against
you by default for the relief demanded in the complaint.
‘The basis of venue is mani pce fons,
Which is sow. ae Sea, Recese A 1816
Dated: sonary2e 218
ETFs
ees
Sve ue Set
Ena tcheeDevag@mowoecnuty 201‘SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF nonsoe
‘HE cousT oF woNROe ] Index No, omemmnnes J0)G - Sel
Plaintitis),
a Summons
te aches ie rion
| Date Index No. Purchased sexey24 a8
Defendant) |
‘To the above named Defendant(s)
Noo HeyLTH suLUTIONS We.
epee ge Crore Sytem, 11 Eighth vee, New ek 1041
"___Yolrare hereby summoned to answer the complaint in this action and to serve
« copy of your answer, or, if the complaint is not served with this summons, to serve
8 notice of appearance, on the Plaintiffs attorney within 20 days after the service of
‘this summons, exclusive of the day of service (or within 30 days after the service is
complete if this summons is not personally delivered to you within the State of New
York) and in case of your failure to appear or answer, judgment will be taken against
you by default for the relief demanded in the complaint.
‘The basis of venue is Puevespacettusnes
Which is sow tn srt Recent ra
Dated: suasey24 20,
‘Atorneys fr PlintifT
2 cna oes Btn
Ea Michie noreesey goSUPREME COURT OF THE STATE OF NEW YORK
JUNTY OF woxroe
Tacoma orncmam Index No. toennsnneige/& -5lel
Plainti(), |
cgcinst |
beraucnitietrsemotecttsonmn) |
Date Index No, Purchased: ayo 00
Defendant).
‘To the above named Defendant(s)
weve merwveuTCs. ne,
igtred Ape The Copan Tas Conpy, 18 Cage Ste. mon, Daa 1801
“You até Hereby summoned to answer the complaint in this action and to serve
8 copy of your answer, or, i the complaint is not served with this summons, to serve
4 notice of appeavance, on the Plaintiffs attorney within 20 days after the serviee of
this cummons, exclusive of the day of service (or within 30 days after the ssrvice is
complete if this summons is not personally delivered to you within the State of New
‘York; and in case of your failure to appear or answer, judgment will be taken against
you by default for the relief demanded in the complaint.
‘The basis of venue is Paina pc ot usbes
Which is sow mashes Rechsa ny 1484
Dated: Joumy 24208
enon com Hyon
ey 6 eyo
vw Oana
‘Atmel
Soon Sat
rrSUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF moro
nna 018-5)
‘wecourorwcinoe ] tnx No. om
Plaintifi(s), :
| Sammons
against
simmers a |
tesmcearitrsconmtatttétedeny — |
| Date Index Ne, Purchased: san aan
Defendant(s). |
‘To the above named Defendant(s)
usa Pore.
‘brn ego acne
{0Unon Some Seaham et NY S08
~~ You are hereby summored to answer the complaint in this action and to serve
‘8 copy of your answer, or, ifthe complaint is not served with this summons, to serve
' notice of appearance, on the Plaintiff's attorney within 20 days after the service of
‘this summons, exclusive of the day of service (or within 30 days after the service is
complete if this summons is not personally delivered to you within the State of New
York); and in ease of your failure to appear or answer, judgment will be taken against
‘you by default for the relief demanded in the complaint,
‘The basis of venue is Pure poet tunes
Which is anw.aan ses, Ronse 454
Dated: sana 242018
somata
Era tcheeemmoncecuny govSUPREME COURT OF THE STATE OF NEW YORK
county oF
‘recowrvoruowce ] index No, mrenriwr Dig -5U
Plaintis(s,
gains Summons
lee eed ier scope it anda)
Date Index No. Purchased: —sevay26.2018
‘To the abeve named Defendant(s)
Pa Fe. 61apeen oe, Sie 0, Sa ee Cy UT 418
You are hereby summoiied to answer the complaint in this action and to sexve
‘ copy of your answer, or, if the complaint is not served with this summons, to serve
‘a notice of appearance, on the Plaintiff's attorney within 20 days after the service of
this summons, exclusive of the day of service (or within 30 days after the setvive is
complete if this surnmons js not personally delivered to you within the State of New
‘York); and in case of your failure to appear or answer, judgment will be taken against
you by default for the relief demanded in the complaint.
‘The basis of venue is Pampa beens
Which is 20W.mainsiet Recast 48
Dated: sonar 24 298
by. Zz
ie, ont Any
‘Attorneys for Plant?
Sewer Seea‘SUPREME COURT OF THE STATE OF NEW YORK
ce Y OF monroe
= Inder, manson O18 50 |
Plains,
-agcina | Sammons
(beste on to
esas) |
| Date Index No, Purchased: seuay a zi8
Defendant(s). |
‘To the above named Defendant(s)
‘SetFahan ED re, Site 700 Soren, CABS1T
‘Youaie tieroby summoned fo answer the complaint in this action and to serve
' copy of your answer, or, if the complaint is not served with this summons, to serve
‘@ notice of appearance. on the Plaintiff's attorney within 20 days after the gervice of
this summons, exclusive of the day of service (or within 30 days after the service is
complete if this summons is not personally delivered to you within the State of New
‘York); and in case of you failure to appear or answer, judgment will be taken against
you by default for the relief demanded in the complaint,
‘The basis of vense is meni psce bees
which is sp. san sues techs HY 1
Dated: sonay24 20%
by. iS
net Coa
repo Pat
imeem
See.
SE eeSUPREME COURT OF THE STATE OF NEW YORK
‘We counTy oF oC | nds No, teehnenaes 20/8 - SU]
Plaintits),
-apoins- | Snommons
scone tte) |
(oe stact
Date Index No. Purchased: seyay 242018
an
‘To the above named Defendant(s)
‘ymin 20985. 700,22, SL Cy. UT 88
‘You are ieveby summuioned Wo answer te complaint in this action and Yo serve
‘copy of your answer, or, if the complaint is not served with this summons, to serve
4 notice of appearance, on the Plaintiff's attorney within 20 days after the service of
this summons, exclusive of the day of service (or within 30 days after the service is
complete if this sumrions is not personally delivered to you within the State of New
York) and in case of your failure to appear or answer, judgment will be taken against
‘you by default for the relief demanded in the complaint.
‘The basis of venue is. Puipacealahas
Which is sew.usn sve, Rochester WY 4614
Dated: ssuy24 2018
by. sz
‘Attorneys fr Painift
Soran sea
Eat chan Oosreroteay sor‘Supreme COURT OF THE STATE OF NEW York
Countvar Monroe
RIDER TO SUMMONS WITH A
‘Tas CoUNTYOF MonkoE,
Plaintif,
Purbue PHARMA LP. PURDUE PHARMA
INC.; THE PURDUE FREDERICK COHPANY,
INc.;TevA PHARMACEUTICALS USA, INC
(CEPHALON, INC.; JOHNSON & JOHNSON;
COMPLETE LIST OF DEFENDANTS
Index. 10/8 -5u |
‘JANSSEN PHARMACEUTICALS, INC; ORTHO | RIDER TO SUMMONS
MCNEL-JANSSEN PHARMACEUTICALS, INC.
N/K /A JANSSEN PHARMACEUTICALS, INC.;
JANSSEN PHARMACEUTICA, INC. N/K/A,
JANSSEN PHARMACEUTICALS, INC: ENDO
PHARMACEUTICALS, INC.;INSyS
‘THERAPEUTICS, INC.; RUSSELL PORTENOY;
Perry FINe; SCOTT FisHMAN; and LYNN
Weasrer,
DefendantsSUPREME COURT OF THE STATE OFNEW YORK
‘County oF Monkue
‘Tue County ur Munnoe,
Plaintif,
PunousPHaewaLP;PumovePiawen |
ines THe PurbueFRenx Conran,
INCcTEVAPHanwacsuMealsUSAIncs |
Certo, cs Jorneon Jomccns
Janssen Pusonceumea.s IesOrmio-
MCN Jansen PHAaUAcEUTCAL I,
I/k/a ansen PhaswaceuTeas es
Janssen Prasuactumcn Ne w/a
Jaxesen Pratenczumcn es ENOO
Heat Soumons ie noo
Paawunceurens Innes
Thiareoncs ine; Rossna Pomenow; |
Fry reyScor Fsuanand Lv
Worse,
yoni, |
_]
Index No.
CompLainr
Qoly-5U!
Plaintiff, the County of Monroe, New York (“Monroe County” ot “the County”
or “Plaintiff’), by and through the undersigned attorneys, for its Complaint against
Defendants Purdue Pharma L.P., Purdue Pharma Inc., The Purdue Frederick Company,
Inc, Teva Pharmaceuticals USA, Inc,, Cephalon, Inc,, Johnson & Johnson, Janssen
Pharmaceuticals, Inc, Ortho-McNeilJanssen Pharmaceuticals, Inc. n/k/a. Janssen
Pharmaceuticals Inc, Janssen Pharmaceutica, Inc. n/k/a Janssen Pharmaceuticals, Endo
Health Solutions Inc, Endo Pharmaceuticals, Inc,, Insys Therapeutics, Inc., Russell
1Portenoy, Perry Fine, Scott Fshman, and Lynn Webster (olectively, “Defendants")
alleges a follows:
Iwrropuction
1. Plaintiff spends millions of dollars each year to provide or pay forthe
health care, pharmaceutical cre, and other necessary services and programs on behalf
of indigents and otherwise eligible residents, including payments for prescription
opium-like painkillers (‘opioids’), which are manufactured, marketed, promote, sod,
and/or distributed by the Defendants.
2. Plaintiff also provides a wide range of other services on behalf of its
Fesidents including services for families and children, public assistance, emergency and
ambulatory services and law enforcement.
3. Monroe County contains one city, 19 towns, and 10 villages. Plaintiff is a
large employer in Monroe County, employing approximately 4500 people in 23
departments, offices, bureaus and agencies. Plaintiff funds its own health insurance
plan forthe benefit ofits employees, through which t pays part or allo its employees!
health care costs, including the cost of prescription drugs, including opioids, Plaintiff
also funds workers compensation and provides disability care programs for its
employees participating inthe healthcare plan.
4. Opioids include brand-name drugs like OxyContin and Percocet and
seneris lke oxyeadone and hydrocodone. They are derived from or possess properties,
similar to opium and heroin, and, as such, they are highly addictive and dangerous and,therefore ae regulated by the United States Food and Drug Administration (“FDA”) as
controlled substances.
5. Opioids provide effective treatment for short-term postsurgical and
trauma-telated pain, and for palliative end-oflfe care, They are approved by the FDA
for use inthe management of moderate to severe pain where use ofan opioid analgesic
is appropriate for more than a few days, Defendants, however, have manufactured,
promoted, and marketed opioids fr the management of pain by misleading consumers
and medical providers through mistepresentations or omissions regarding. the
appropriate uses, risks, and safety of opioids
6 Addiction encompasses a spectrum of substance use disorders that range
fom misuse and abuse of drugs to addiction. Throughout this Complaint, “addiction’
refers to the entire range of substance abuse disorders. Individuals suffer negative
consequences wherever they fall onthe substance use disorder continuum.
7. Defendants knew that, barring exceptional circumstances, opioids are too
Addictive and ‘oo debilitating for long-term use for chronic non-cancer pain lasting
three months or longer ("chronic pain’
8. Defendants knew that,
prolonged use, the effectiveness of opioids
‘wanes, requiring increases in doses to achieve pain relief and markedly increasing the
risk of significant side effects and addiction?
* Diagnostic and Statistical Manual of Mental Disorders (ted 2013) (‘DSM-V")
2 Ser, eg. Russell K, Fortenoy, Opioid Therapy for Chronic Nonmalignant Pin: Current
‘Status, 1 Progress in Pain Res. & Mgmt, 247-987 (HLL. Fields and J. Liebeskind eds,
1994),9. Defendants knew that controled studies of the safety and efficacy of
opioids were limited to short-term use (ie, not longer than $0 days) in managed
settings (¢g, hospitals) where the isk of addiction and other adverse outcomes was
significantly minimized
10. To dae, there have been no longterm studies demonstrating the safely
and effcacyof opioids fr longsterm use.
11, Despite the foregoing knowledge, in order to expand the market for
opioiis and realize blockbuster profits, Defendants sought to cicate a false perception
of the safety and efficacy of opioids in the minds of medical professionals and members
of the public that would encourage the use of opioids for longer periods of time and to
treat a wider range of problems, including such common aches and pains as lower back
pain, arthritis, and headaches.
12. Defendants accomplished that false perception through a coordinated,
sophisticated, and highly deceptive marketing campaign that began in the late 1990,
became more aggressive in or about 2006 and continues tothe prsent
13, Defendants accomplished their marketing campaign goal by convincing
doctors, patients, and others that the benefits of using opioids to treat chronic pain
couteeighed the risks, and that opioids could be safely used by mest patients
14, Defendants, individually and collectively, knowing that long-term opioid
use causes addiction, misrepresented the dangers of long-term opioid use to physicians,
pharmacists, and patients by engaging in a campaign to minimize the risks of, and to
encourage, long-term opioid use.15, Defendants’ marketing campaign has been extremely. successful in
expanding opioid use. Since 199, the amount of prescription opioids sold in the US.
nearly quadrupled in 2010, 254 million prescriptions for opioids were filled in the
US. enough to medicate every adult in America around the clock fora month. In that
Year, 20% of all doctors’ visits resulted inthe prescription ofan opioid (nearly double
the rate in 2000) While Americans represent only 4.6% of the world's population, they
consume 80% of the opioids supplied around the world and 99% of the global
hhydrocotone supply By 2014, nearly two million Americans either abused oF were
dependent on opioids
16, Defendants’ campaign has been extremely profitable for them. In 2012
alone, opioids generated $8 bilion in revenwe for drug companies, Of that amount, $3.1
billion went to Purdue for its OxyContin sales. By 2015, sales of opioids grew further to
approximately billion?
17, Defendants’ marketing campaign has been extremely harmful to
‘Americans. Overdoses from prescription pain relievers are a diving factor ina 15-year
opioid overdose deaths. Deaths from prescription opioids have also
8 CDC, Injury Prevention & Control: Opioid Overdose, Understanding the Epidemic.
Available at:_http://www.cd2gov/drugoverdose/epidemic/index.html (accessed
December 4, 017) (internal footnotes omitted).
+ M, Daubresse, et al., Ambulatory Diagnosis and Treatment of Nonmalignant Pain in
the United States, 2000-2010, 51(10) Med. Care 870-78 (2013).
° L. Manchikanti, et al,, Therapeutic Use, Abuse, and Nonmedical Use of Opioids: A
‘Ten-Year Perspective, 13 Pain Physician 401-435 (2010).
CDG, Injury Prevention & Conirol: Opioid Overdose, Prescription Opioids, Available
at: http://www cde gov /drugoverdose/opioids/ prescribed html (as viewed May 10,
2016).
71D. Crow, Drugmakers hooked on $10bn opioid habit, Financial Times (August 10, 2016)
5quadrupled since 1999, From 2000 to 2014 nearly half a million people died from such.
overdoses, Seventy-eight Americans die every ay from an opioid overdose
18, 12012, an estimated 2.1 million people in the United States suffered from
substance use disorders related to prescription opioid pain relievers? Between 30% and
40% oF long-term users of opioids experience problems with opioid use disorders.
1%, On January 1, 2016, the Centers for Disease Control arnounced that
“[olpioids, primarily prescription pain relievers and heroin, are the main drugs
associated with overdose deaths." Alarmingly, the CDC noted that in 214 there were
approximately one and a half times more drug overdose deaths in the United States
than deaths from motor vehicle crashes
20, Opivid addiction and overdose have reached epidemic levels over the
past decade. Cn March 22, 2016, the FDA recognized opioid abuse as a “public health
CDG, inary Prevention & Controk Opioid Overdose, Understanding the Epidemic,
"Substance Abuse and Mental Health Services Administration, Rests fom the 2012
National Survey on Drug Use and Heth Suamary of National Findings, NSDUH Series H-
46, HHS Publication No. (SMA) 13-4795. Rockvile, MD. Substance Abuse and Mental
Health Services Administration, 2013
27, Boscaing etal, Risk factors for drug dependence among outpatients on opioid
therapy ina large US heltare system, 105(10) Addiction 1776 (2010); Boscarine et
al, Prevalence of Prescription Opioid-Use Disorder Among Chronic Pain Patients
Comparison ofthe DSMCS vs. DSM Diagnoste Criteria, 30Q) Journal of Addiztive
Diseees 185 201)
"CDG, treeases in Drug and Opioid Overdose Deaths - United Sats, 2000-2014
Availble at hips: /worw.ede gov /mmvr/preview/mmwzhtml/mmé430x3 him
(accessed December 4, 2017)
6