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In Re: Pradaxa (Dabigatran ) Etexilate Products

January 23, 2013

IN RE: PRADAXA (DABIGATRAN ) ETEXILATE PRODUCTS LIABILITY LITIGATION


This Document Relates to:

ALL CASES

DEFENDANT FACT SHEET FOR BIPI

For each case, Boehringer Ingelheim Pharmaceuticals, Inc. must complete this Defendant Fact Sheet ("DFS") and identify or provide documents and/or data relating to each plaintiff, responsive to the questions set forth below, to the best of Defendant‟s knowledge. In completing this DFS, you are under oath and must provide information that is true and correct to the best of your knowledge. You must supplement your responses if you learn that they are incomplete or incorrect in any material respect. You must also supplement your responses in the event that additional information is provided from the Plaintiff. The DFS shall be completed in accordance with the requirements and guidelines set forth in the applicable Case Management Order. In the event the DFS does not provide you with enough space for you to complete your responses or answers, please attach additional sheets if necessary. Please identify any documents that you are producing as responsive to a question or request by bates-stamp identifiers.

This DFS must be completed and served on all counsel representing a plaintiff in the action identified in Section I below. This must be answered and served in accordance with CMO 20.

As used herein, the terms "you," "your" or "yours" means the responding defendant.

As used herein, the phrase "provided" means sold, distributed, shipped, delivered or otherwise placed into the stream of commerce.

As used herein the phrase "Prescribing Health Care Provider" means each of Plaintiff‟s physicians or medical providers who prescribed or dispensed Pradaxa to Plaintiff.

I.Case Information

This DFS pertains to the following case:

Case caption: _____________________________________________________

Civil Action No.__________________________________________________

Name and Address of all persons who provided information responsive to the questions posed in this DFS:

A: ________________________________

(Name)

________________________________ (Address)

________________________________ (Phone Number)

________________________________ (Title within Defendant Company and Company employed by)

B: ________________________________

(Name)

________________________________ (Address)

________________________________ (Phone Number)

________________________________ (Title within Defendant Company and Company employed by)

II.Contacts With Prescribing Health Care Provider

In Section VII(A) of Plaintiff‟s Fact Sheet, (s)he identifies persons or entities who prescribed or provided samples of Pradaxa to the Plaintiff. For each Prescribing Health Care Provider identified, please state the following:

A. Dear Doctor Letters:

1. Please identify the "Dear Doctor" or "Dear HealthCare Provider" letter that you contend was actually sent to the Plaintiff‟s Prescribing Health Care Provider concerning Pradaxa. _____________________________________________

_____________________________________________

_____________________________________________

NOTE: Please attach hereto a copy of each letter allegedly sent to Plaintiff's Prescribing Health Care Provider.

2. For each "Dear Doctor" or "Dear Healthcare Provider" letter that you contend was actually sent to Plaintiff‟s Prescribing Health Care Provider, please state the date that each "Dear Doctor" or "Dear HealthCare Provider" letter was actually sent to Plaintiff‟s Prescribing Health Care Provider and the person to whom each letter was sent.

_____________________________________________

_____________________________________________

_____________________________________________

_____________________________________________

3. For each "Dear Doctor" or "Dear HealthCare Provider" letter identified that you contend was actually sent to Plaintiff‟s Prescribing Health Care Provider, please identify any and all lists or databases which you contend demonstrate that these letters were actually sent, and please provide a relevant copy of same that identifies that the letter was sent.

_____________________________________________

...


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