commonwealth of massachusetts suffolk, ss. … declarations … · 7/17/2019 · pharma l.p. et...

COMMONWEALTH OF MASSACHUSETTS SUFFOLK, ss. SUPERIOR COURT

CIVIL ACTION NO. 1884-cv-01808(B)

COMMONWEALTH OF MASSACHUSETTS,

Plaintiff, v.

PURDUE PHARMA L.P., PURDUE PHARMA INC., RICHARD SACKLER, THERESA SACKLER, KATHE SACKLER, JONATHAN SACKLER, MORTIMER D.A. SACKLER, BEVERLY SACKLER, DAVID SACKLER, ILENE SACKLER LEFCOURT, PETER BOER, PAULO COSTA, CECIL PICKETT, RALPH SNYDERMAN, JUDITH LEWENT, CRAIG LANDAU, JOHN STEWART, MARK TIMNEY, and RUSSELL J. GASDIA

Defendants.

DECLARATION OF RICHARD SACKLER

I, Richard Sackler, declare as follows:

1. I am a defendant in the action Commonwealth of Massachusetts v. Purdue Pharma

L.P. et al., No. 1884-cv-01808(B) (Mass. Sup. Ct. Suffolk Cnty.), which asserts claims (the

“Claims”) based on events allegedly occurring after May 15, 2007 (the “Period”). I submit this

declaration in support of my motion to dismiss the First Amended Complaint filed in that action.

2. At the start of the Period, my primary residence was in Connecticut. I maintained

my primary residence in Connecticut until 2013, when I moved to Texas. In 2018, I moved from

Texas to Florida, which is now my primary residence. During the Period, I have not resided in

2

Massachusetts, owned or rented property in Massachusetts, or maintained an office in

Massachusetts.

3. I served as a director of the Board of Directors of Purdue Pharma Inc. (“PPI”)

throughout the Period until July 24, 2018. During the Period, I have not served as a director of

Purdue Pharma L.P. (“PPLP,” and together with PPI, the “Purdue Defendants”), which has no

directors. I have not served as an employee or officer of either company during the Period.

4. During my tenure as a director of PPI in the Period, to the best of my recollection,

knowledge, and belief:

a. No meetings of the Board of Directors of PPI took place in Massachusetts.

b. I did not conduct business on behalf of either Purdue Defendant in

Massachusetts except in connection with an investment by PPLP in Infinity

Pharmaceuticals, Inc. (“Infinity”), which ended in approximately 2013,

and a securities purchase agreement with Novelos Therapeutics, Inc.

(“Novelos”), which PPLP entered into in 2009. My understanding is that

Infinity was a company specializing in cancer treatments, Novelos was a

company that developed treatments for cancer and hepatitis, and neither

Infinity nor Novelos was involved with the manufacture, sale or marketing

of opioids. I traveled to Massachusetts on approximately 6 occasions

between 2008 and 2011 in connection with the Infinity investment and on

approximately 2 occasions in 2009 in connection with Novelos.

c. I did not direct the management of either Purdue Defendant, or any sales

representative employed by either Purdue Defendant, to visit doctors in

3

Massachusetts, send emails for savings cards to Massachusetts

practitioners, or violate the 2007 Settlement Agreement and Consent

Judgment with Massachusetts. Nor did I otherwise direct any marketing,

sales or promotional activities by PPI, PPLP or any of their subsidiaries or

affiliates, in Massachusetts.

d. Except as set forth in ¶4(b), above, I did not travel to Massachusetts on

behalf of either Purdue Defendant; my travel to Massachusetts was for

philanthropic, scientific or personal purposes, including in connection with

my service on the advisory boards of educational and research institutions in

Massachusetts.

e. I did not take any action related to the Claims in Massachusetts.

f. I never went into the field with sales representatives to promote opioids to

doctors on behalf of either Purdue Defendant in Massachusetts.

I declare, under penalty of perjury, that the foregoing is true and correct. Executed at

&,/l£c .. /4t,,, fd., f:t , this 24'1ay of March, 2019.

COMMONWEALTH OF MASSACHUSETTS

SUFFOLK, ss.

SUPERIOR COURT

CIVIL ACTION NO.

1884-cv-01808(B)


Plaintiff,

v.

PURDUE PHARMA L.P., PURDUE PHARMA INC.,

RICHARD SACKLER, THERESA SACKLER, KATHE

SACKLER, JONATHAN SACKLER, MORTIMER D.A.

SACKLER, BEVERLY SACKLER, DAVID SACKLER,

ILENE SACKLER LEFCOURT, PETER BOER,

PAULO COSTA, CECIL PICKETT, RALPH

SNYDERMAN, JUDY LEWENT, CRAIG LANDAU,

JOHN STEWART, MARK TIMNEY, and RUSSELL J.

GASDIA,

Defendants.

DECLARATION OF THERESA E. SACKLER

I, Theresa E. Sackler, declare as follows:

1. I am a defendant in the action Commonwealth of Massachusetts v. Purdue

Pharma L.P. et al., No. 1884-cv-01808(B) (Mass. Sup. Ct. Suffolk Cnty.), which asserts claims

(the “Claims”) based on events allegedly occurring after May 15, 2007 (the “Period”). I submit

this declaration in support of my motion to dismiss the First Amended Complaint based on lack

of personal jurisdiction filed in that action.

2. I currently reside in the United Kingdom. During the Period, I have not resided

in Massachusetts, owned or rented property in Massachusetts, or maintained an office in

Massachusetts.

3. I served on the Board of Directors of Purdue Pharma, Inc. ("PPI") throughout the

Period until September 7, 2018. During the Period, I have not served as a director of Purdue

Pharma L.P. ("PPLP" and, together with PPI, the "Purdue Defendants"), which has no directors. I

have not served as an employee or officer of either Purdue Defendant during the Period. ·

4. During the Period, to the best of my recollection, knowledge, and belief:


b. I have not conducted any business on behalf of either Purdue Defendant

in Massachusetts.

c. I did not direct the management of any Purdue Defendant or any sales

representative employed by any Purdue Defendant to visit doctors in


practitioners, or violate the 2007 Settlement Agreement or Consent

Judgment with Massachusetts . Nor did I otherwise direct any marketing,

sales, or promotional activities by PPI, PPLP, or any of their subsidiaries

or affiliates in Massachusetts.

d. I did not travel to Massachusetts on behalf of either Purdue Defendant.


I declare under penalty of perjury that the foregoing is true and correct.

Executed at ~ .,..

thisd-7~

Theresa E. Sackler

2

COMMONWEALTH OF MASSACHUSETTS SUFFOLK, ss.


Plaintiff,

v.

PURDUE PHARMA L.P., PURDUE PHARMA INC., RICHARD SACKLER, THERESA SACKLER, KA THE SACKLER, JONA THAN SACKLER, MORTIMER D.A. SACKLER, BEYERL Y SACKLER, DA YID SACKLER, ILENE SACKLER LEFCOURT, PETER BOER, PAULO COSTA, CECIL PICKETT, RALPH SNYDERMAN, JUDY LEWENT, CRAIG LANDAU, JOHN STEW ART, MARK TIMNEY, and RUSSELL J. GASDIA,

Defendants.

SUPERIOR COURT CIVIL ACTION NO. 1884-cv-O 1808(B)

DECLARATION OF KATHE SACKLER

I, Kathe Sackler, declare as follows:



(the "Claims") based on events allegedly occurring after May 15, 2007 (the "Period"). I submit



2. I currently reside in Connecticut. During the Period, I have not resided

in Massachusetts, owned or rented property in Massachusetts, or maintained an office

in Massachusetts.

3. I served on the Board of Directors of Purdue Phanna, Inc. ("PPI") throughout the

Period until September 27, 2018. During the Period, I have not served as a director of Purdue

Pharma L.P. ("PPLP" and, together with PPI, the "Purdue Defendants"), which has no directors.

Other than serving as a Senior Vice President of PPI and PPLP until May 31, 2007, I have not

served as an employee or officer of either Purdue Defendant during the Period.



b. I have not conducted any business on behalf of either Purdue Defendant

in Massachusetts.






sales, or promotional activities by PPI, PPLP, or any of their subsidiaries

or affiliates in Massachusetts.




Executed at A,~ 1?JI· this .J1_ day of March, 2019.

Kath~.

2



Plaintiff,

v.

PURDUE PHARMA L.P., PURDUE PHARMA INC., RICHARD SACKLER, THERESA SACKLER, KATHE SACKLER, JONATHAN SACKLER, MORTIMER D.A. SACKLER, BEYERL Y SACKLER, DAVID SACKLER, ILENE SACKLER LEFCOURT, PETER BOER, PAULO COSTA, CECIL PICKETT, RALPH SNYDERMAN, JUDITH LEWENT, CRAIG LANDAU, JOHN STEW ART, MARK TIMNEY, and RUSSELL GASDIA

Defendants.


DECLARATION OF JONATHAN SACKLER

I, Jonathan Sackler, declare as follows:



"Claims") based on events allegedly occurring after May 15, 2007 (the "Period"). I submit this


2. I reside in Connecticut, where I have maintained my primary residence throughout

the Period. During the Period, I have not resided in Massachusetts, owned or rented property in

Massachusetts, or maintained an office in Massachusetts.

3. I served as a director on the Board of Directors of Purdue Pharma Inc. ("PPI")

throughout the Period until December 8, 2018. During the Period, I have not served as a director of

Purdue Pharma L.P. ("PPLP," and together with PPI, the "Purdue Defendants"), which has no

directors. Other than serving as a Senior Vice President of PPI and PPLP until May 31, 2007, I

have not served as an employee or officer of either company during the Period.



b. I did not conduct any business on behalf either Purdue Defendant in


Pharmaceuticals, Inc. ("Infinity"), which ended in approximately 2013. My

understanding is that Infinity was a company specializing in cancer

treatments and was not involved in the manufacture, sale or marketing of

opioids. I traveled to Massachusetts on approximately 4 occasions between

2009 and 2011 in connection with the Infinity investment.


representatives employed by either Purdue Defendant, to visit doctors in

Massachusetts, send emails for savings cards to Massachusetts practitioners,

or violate the 2007 Settlement Agreement and Consent Judgment with

Massachusetts. Nor did I otherwise direct any marketing, sales or

promotional activities by PPI, PPLP or any of their subsidiaries or affiliates,

in Massachusetts.

2

d. Except as set forth in i!4(b ), above, I did not travel to Massachusetts on


philanthropic, scientific or personal purposes.

e. I did not take any action related to the Claims in Massachusetts .


~t~V"\.fc ,r J_ t c-r , this "U ,: ay of March, 2019.

81255 1

3

COMMONWEALTH OF MASSACHUSETTSSUFFOLK, ss.

SUPERIOR COURTCIVIL ACTION NO.1884- cv-01808(B)


Plaintiff,

v.

PURDUE PHARMA L.P., PURDUE PHARMA INC.,RICHARD SACKLER, THERESA SACKLER, KATHESACKLER, JONATHAN SACKLER, MORTIMER D.A.SACKLER, BEVERLY SACKLER, DAVID SACKLER,ILENE SACKLER LEFCOURT, PETER BOER,PAULO COSTA, CECIL PICKETT, RALPHSNYDERMAN, JUDY LEWENT, CRAIG LANDAU,JOHN STEWART, MARK TIMNEY, and RUSSELL J.GASDIA,

Defendants.

DECLARATION OF MORTIMER D.A. SACKLER

I, Mortimer D.A. Sackler, declare as follows:

I. I am a defendant in the action Commonwealth of Massachusetts v. Purdue Pharma

L.P. et al, No. 1884-cv-01808(B) (Mass. Sup. Ct. Suffolk Cnty.), which asserts claims (the “Claims”)

based on events allegedly occurring after May 15, 2007 (the “Period”). I submit this declaration in

support of my motion to dismiss the First Amended Complaint based on lack of personal jurisdiction

filed in that action.

2. I currently reside in New York. During the Period, I have not resided in

Massachusetts, owned or rented property in Massachusetts, or maintained an office in Massachusetts.

I attended a university in Massachusetts from September 1989 through June 1993.

I resided in Massachusetts only during the school year and did not intend to make Massachusetts

my pennanent home. To the best of my recollection, I did not vote in Massachusetts or receive an

identification card issued by the Commonwealth of Massachusetts. I owned an apartment in

Massachusetts from in or about 1991 to 1999. I did not reside in that apartment after I graduated

from the university in 1993.


Period until January 16, 2019. During the Period, I have not served as a director of Purdue

Pharma L.P. ("PPLP" and, together with PPI, the "Purdue Defendants"), which has no

directors. Other than serving as a Vice President of PPI and PPLP until May 31, 2007, I have not

served as an employee or officer of either Purdue Defendant during the Period.

4. During the Period, to the best of my recollection, knowledge, and belief.


b. I have not conducted any business on behalf of either Purdue

Defendant in Massachusetts.





Judgment with Massachusetts. Nor did I otherwise direct any

marketing, sales, or promotional activities by PPI, PPLP, or any of their

subsidiaries or affiliates in Massachusetts.

2

d. I did not travel to M assachuseus on behalf of either Purdue Defendant ;

my travel to M assachusetts was for personal purposes or on business

unrelated to the manu facture, sale or marketing of opioids.

e. I did not take any acti on related to the Claims in Massachusetts.

I declare under penalty of per:jury that the foregoing is true c1nd correct.

Executed at N~ '( 0v ~ , ~ ::1_ S.t this _v_l_ day of March. 20 19 .

Mortimer D .A. Sackler

3



Plaintiff,

v.

PURDUE PHARMA L.P., PURDUE PHARMA INC., RICHARD SACKLER, THERESA SACKLER, KATHE SACKLER, JONATHAN SACKLER, MORTIMERD.A. SACKLER, BEVERLY SACKLER, DAVID SACKLER, ILENE SACKLER LEFCOURT, PETER BOER, PAULO COSTA, CECIL PICKETT, RALPH SNYDERMAN, JUDITH LEWENT, CRAIG LANDAU, JOHN STEWART, MARK TIMNEY, and RUSSELL J. GASDIA

Defendants.


DECLARATION OF BEVERLY SACKLER

I, Beverly Sackler, declare as follows:


L.P. et al., No. 1884-cv-O 1808(B) (Mass. Sup. Ct. Suffolk Cnty.), which asserts claims (the






3. I served as a director on the Board of Directors of Purdue Phaima Inc. ("PPI")

throughout the Period until October 17, 2017. I have never been an employee or officer of PPL I

have never been an employee, officer, or director of Purdue Pharma L.P. ("PPLP," and together

with PPI, the "Purdue Defendants"), which has no directors.

4. During my tenure as a director of PPI in the Period, to the best of my recollection,

knowledge, and belief:

a. No i:neetings of the Board of Directors of PPI took place in Massachusetts.

b. I did not conduct any business on behalf of either Purdue Defendant in

Massachusetts.







in Massachusetts.

d. I did not travel to Massachusetts on behalf of either Purdue Defendant. I

only travelled to Massachusetts for philanthropic and personal purposes.


2


~

J :i.:. 3~pm 1 this )8 day of March, 2019.

Gr-e&i;,; iU, 1 dJn~ch'c_u+ _/~1_..Lb,,,___~_ . ______ _ Beverly Sackler

812625

3

COMMONWEAL TH OF MASSACHUSETTS SUFFOLK, ss.


Plaintiff,

V.

PURDUE PHARMA L.P., PURDUE PHARMA INC., RICHARD SACKLER, THERESA SACKLER, KATHE SACKLER, JONATHAN SACKLER, MORTIMER D.A. SACKLER, BEYERL Y SACKLER, DAVID SACKLER, ILENE SACKLER LEFCOURT, PETER BOER, PAULO COSTA, CECIL PICKETT, RALPH SNYDERMAN, JUDITH LEWENT, CRAIG LANDAU, JOHN STEWART, MARK TIMNEY, and RUSSELL J. GASDIA

Defendants.

SUPERIOR COURT CIVIL ACTION NO. l 884-cv-0I 808(B)

DECLARATION OF DAVID SACKLER

I, David Sackler, declare as follows:

I. I am a defendant in the action Commonwealth of Massachusetts v. Purdue Pharma

L.P. et al., No. 1884-cv-OI808(B) (Mass. Sup. Ct. Suffolk Cnty.), which asserts claims (the


declaration in support ofmy motion to dismiss the First Amended Complaint filed in that action.

2. I reside in New York, where I have maintained my primary residence throughout the

Period. During the Period, I have not resided in Massachusetts, owned or rented property in


3. I served as a director on the Board of Directors of Purdue Pharma Inc. ("PPI") from

July 19, 2012 until August 14, 2018. During the Period, I have not served as an employee or officer

of PP!, or as an employee, officer, or director of Purdue Pharma L.P. ("PPLP," and together with

PP!, the "Purdue Defendants"), which as has no directors.

belief:

4. During my tenure as a director of PP!, to the best ofmy recollection, knowledge, and

a. No meetings of the Board of Directors of PP! took place in Massachusetts.


Massachusetts.







in Massachusetts.

d. I did not travel to Massachusetts on behalf of either Purdue Defendant; my

travel to Massachusetts was for personal purposes or on business unrelated

to the manufacture, sale or marketing of opioids.


2

New York, NY 28


_________ ,this_ day of March, 2019.

cJ;2 IS --· David Saclder

812626

3



Plaintiff,

V.

PURDUE PHARMA L.P ., PURDUE PHARMA INC., RICHARD SACKLER, THERESA SACKLER, KATHE SACKLER, JONATHAN SACKLER, MORTIMER D.A. SACKLER, BEVERLY SACKLER, DAVID SACKLER, ILENE SACKLER LEFCOURT, PETER BOER, PAULO COSTA, CECIL PICKETT, RALPH SNYDERMAN, JUDY LEWENT, CRAIG LANDAU, JOHN STEWART, MARK TIMNEY, and RUSSELL J. GASDIA,

Defendants.

SUPERIOR COURT CIVIL ACTION NO. 1884-cv-01808(B)

DECLARATION OF ILENE SACKLER LEFCOURT

I, Ilene Sackler Lefcourt, declare as follows:

1. I am a defendant in the action Commonwealth of Massachusetts v. Purdue Pharma L.P.

et al., No. 1884-cv-01808(B) (Mass. Sup. Ct. Suffolk Cnty.), which asserts claims (the "Claims") based

on events allegedly occurring after May 15, 2007 (the "Period"). I submit this declaration in support of

my motion to dismiss the First Amended Complaint based on lack of personal jurisdiction filed in that

action.

2. I currently reside in New York. During the Period, I have not resided in Massachusetts,

owned or rented property in Massachusetts, or maintained an office in Massachusetts. I have a physical

disability that prevents me from travelling.


Period until October 9, 2018. During the Period, I have not served as a director of Purdue Pharma

L.P. ("PPLP" and, together with PPI, the "Purdue Defendants"), which has no directors. I have

not served as an employee or officer of either Purdue Defendant during the Period.

4. During the Period, to the best of my recollection, knowledge, and belief.


b. I have not conducted any business on behalf of either Purdue Defendant in

Massachusetts.






sales, or promotional activities by PPI, PPLP, or any of their subsidiaries or

affiliates in Massachusetts.


e. I did not take any action related to the Claims in

Massachusetts.


__ day of April, 2019.

''Irene Sackler Lefcoufi

2

COMMONWEALTH OF MASSACHUSETTS SUFFOLK, ss. SUPERIOR COURT

CIVIL ACTION NO. 1884-cv-01808(B)


Plaintiff, v.

PURDUE PHARMA L.P., PURDUE PHARMA INC., RICHARD SACKLER, THERESA SACKLER, KATHE SACKLER, JONATHAN SACKLER, MORTIMER D.A. SACKLER, BEVERLY SACKLER, DAVID SACKLER, ILENE SACKLER LEFCOURT, PETER BOER, PAULO COSTA, CECIL PICKETT, RALPH SNYDERMAN, JUDITH LEWENT, CRAIG LANDAU, JOHN STEWART, MARK TIMNEY, and RUSSELL J. GASDIA

Defendants.

DECLARATION OF PETER BOER

I, Peter Boer, declare as follows:



“Claims”) based on events allegedly occurring after May 15, 2007 (the “Period”). I submit this


2. I reside in Florida, where I have maintained my primary residence throughout the

Period. During the Period, I have not resided in Massachusetts, owned or rented property in


2

3. I have served as a director of the Board of Directors of Purdue Pharma Inc. (“PPI”)

since April 18, 2008. I have never been an employee or officer of PPI. I have never been an

employee, officer, or director of Purdue Pharma L.P. (“PPLP,” and together with PPI, the “Purdue

Defendants”), which has no directors.

4. During my tenure as a director of PPI, to the best of my recollection, knowledge, and

belief:




Pharmaceuticals, Inc. (“Infinity”), which ended in approximately 2013. My

understanding is that Infinity was a company specializing in cancer

treatments and was not involved with the manufacture, sale or marketing of

opioids. I traveled to Massachusetts on approximately 2 occasions between

2009 and 2011 in connection with the Infinity investment.

c. I did not direct the management either Purdue Defendant, or any sales






in Massachusetts.

d. Except as set forth in ¶4(b), above, I did not travel to Massachusetts on

behalf of either Purdue Defendant; my trips to Massachusetts were for

8\2629

personal purposes, or involved travel through Massachusetts airports en

·:,ute to and from destinations outside of Massachusetts.


I declare, under penalty of perjury, that the foregoing is true and conect. Executed at

this :J/ctay of March, 2019.

Peter Boer

3


SUFFOLK, ss.


Plaintiff,

V.

PURDUE PHARMA L.P., PURDUE PHARMA INC., RICHARD SACKLER, THERESA SACKLER, KA THE SACKLER, JONA THAN SACKLER, MORTIMER D.A. SACKLER, BEVERLY SACKLER, DA YID SACKLER, ILENE SACKLER LEFCOURT, PETER BOER, PAULO COSTA, CECIL PICKETT, RALPH SNYDERMAN, JUDITH LE WENT, CRAIG LANDAU, JOHN STEWART, MARK TIMNEY, and RUSSELL J. GASDIA

Defendants.

SUPERIOR COURT CIVIL ACTION NO. I 884-cv-01808(B)

DECLARATION OF PAULO COSTA

I, Paulo Costa, declare as follows:








3. I served as a director of the Board of Directors of Purdue Pharma Inc. ("PPI")

between April 25, 2012 and January 30, 2018. 1 have never been an employee or officer of PPL T

have never been an employee, officer, or director of Purdue Pharma L.P. ("PPLP ," and together


belief:



b. T did not conduct business on behalf of either Purdue Defendant in

Massachusetts.




practitioners, or violate the 2007 Settlement Agreement and Consent

Judgment with Massachusetts. Nor did I did otherwise direct any

marketing, sales or promotional activities by PPI, PPLP or any of their

subsidiaries or affiliates, in Massachusetts.

d. I did not travel to Massachusetts on behalf of either Purdue Defendant. I

only travelled to Massachusetts for a personal matter- to attend a

wedding----on one occasion.


2


c5~tviP4 1 c,r;his o27day of March, 2019. ,,#/ / ~ l r ~/~

Paulo Costa

8 12628

3


SUFFOLK, ss.

SUPERIOR COURT

CIVIL ACTION NO.

1884-cv-01808(B)


Plaintiff,

v.



SACKLER, JONATHAN SACKLER, MORTIMER D.A.

SACKLER, BEVERLY SACKLER, DAVID SACKLER,

ILENE SACKLER LEFCOURT, PETER BOER, PAULO

COSTA, CECIL PICKETT, RALPH SNYDERMAN,

JUDY LEWENT, CRAIG LANDAU, JOHN STEWART,

MARK TIMNEY, and RUSSELL J. GASDIA,

Defendants.

DECLARATION OF CECIL B. PICKETT

I, Cecil B. Pickett, declare as follows:






2. I currently reside in Florida, where I have lived since 2010. I rented an apartment in

Massachusetts from in or about September 2006 to October 2009. During that time, I worked for a

company that is not affiliated with Purdue Pharma Inc. (“PPI”), Purdue Pharma L.P. (“PPLP” and,

2

together with PPI, the “Purdue Defendants”), or any of their subsidiaries or affiliates. I never

intended Massachusetts to be my permanent home and never received a driver’s license from the

Commonwealth of Massachusetts. After my work for that company ended in October 2009, I

returned to my home in New Jersey, where I lived until I moved to Florida in 2010.

3. I have served on the Board of Directors of PPI since January 21, 2010. During

the Period, I have not served as a director of PPLP, which has no directors. I have not served

as an employee or officer of either Purdue Defendant during the Period.

4. During my tenure as a director of PPI in the Period, to the best of my

recollection, knowledge, and belief:




Pharmaceuticals, Inc. (“Infinity”), which ended in approximately 2013.

My understanding is that Infinity was a company specializing in cancer

treatments and was not involved with the manufacture, sale or marketing of

opioids. I travelled to Massachusetts on approximately 2 occasions in

connection with the Infinity investment.






sales, or promotional activities by PPI, PPLP, or any of their subsidiaries or

affiliates in Massachusetts.

d. Except as set forth in ,r4(b ), above, I did not travel to Massachusetts on


personal purposes or on business unrelated to the manufacture, sale or

marketing of opioids.


I declare mder penalty of perjury that the foregoing is true and correct.

Executed at S cY7 ~ ~ OtLJ. J FL this 21 day of March, 2019.

Cecil B. Pickett

3

COMMONWEAL TH OF MASSACHUSETTS SUFFOLK, ss.


Plaintiff,

v.

PURDUE PHARMA L.P., PURDUE PHARMA INC., RICHARD SACKLER, THERESA SACKLER, KA THE SACKLER, JONA THAN SACKLER, MORTIMER D.A. SACKLER, BEYERL Y SACKLER, DAVID SACKLER, ILENE SACKLER LEFCOURT, PETER BOER, PAULO COSTA, CECIL PICKETT, RALPH SNYDERMAN, JUDITH LEWENT, CRAIG LANDAU, JOHN STEWART, MARK TIMNEY, and RUSSELL J. GASDIA

Defendants.

SUPERIOR COURT CIVIL ACTION NO. 1884-cv-O l 808(B)

DECLARATION OF RALPH SNYDERMAN

I, Ralph Snyderman, declare as follows:





2. I reside in North Carolina, where I have maintained my primary residence

throughout the Period. During the Period, I have not resided in Massachusetts, owned or rented

property in Massachusetts, or maintained an office in Massachusetts.

3. I served as a director on the Board of Directors of Purdue Pharma Inc. ("PPI")

between August 1, 2012 and October 30, 2017. I have never been an employee or officer of PPL

have never been an employee, officer, or director of Purdue Pharma L.P. ("PPLP," and together


belief:




Massachusetts.


representatives employed by any Purdue Defendant, to visit doctors in





in Massachusetts.


only travelled to Massachusetts for academic and scientific purposes and on

business unrelated to the manufacture, sale or marketing of opioids.


2


_ ~ ___ /J_C. __ thi~~y of March, 2019.

!!1 2630

3


SUFFOLK, ss.

SUPERIOR COURT

CIVIL ACTION NO.

1884-cv-01808(B)


Plaintiff,

v.



SACKLER, JONATHAN SACKLER, MORTIMER

D.A. SACKLER, BEVERLY SACKLER, DAVID

SACKLER, ILENE SACKLER LEFCOURT, PETER

BOER, PAULO COSTA, CECIL PICKETT, RALPH

SNYDERMAN, JUDY LEWENT, CRAIG LANDAU,

JOHN STEWART, MARK TIMNEY, and RUSSELL J.

GASDIA,

Defendants.

DECLARATION OF JUDITH C. LEWENT

I, Judith C. Lewent, declare as follows:






2. I currently reside in Florida. During the Period, I have not resided in Massachusetts,

owned or rented property in Massachusetts, or maintained an office in Massachusetts.

3. I served on the Board of Directors of Purdue Phanna, Inc. (''PPI") from March 20,

2009 to December 31, 2014. During the Period, I have not seIVed as a director of Purdue Phanna L.P.

(''PPLP'' and, together with PPI, the ''Purdue Defendants"), which bas no directors. I have not served

as an employee or officer of either Purdue Defendant during the Period.

4. During my tenw-e as a director of PPI in the Period, to the best of my

recollection, knowledge, and belief


b. I have not conducted any business on behalf of either Purdue Defendant in

Massachusetts.



Massachusetts, send emails for savings cards to Massachusetts practitioners, or

violate the 2007 Settlement Agreement or Consent Judgment with

Massachusetts. Nor did I otherwise direct any marketing, sales, or promotional

activities by PPI, PPLP, or any of their subsidiaries or affiliates in Massachusetts.

d. I did not travel to Massachusetts on behalf of either Purdue Defendant; my travel

to Massachusetts was for personal prnposes or on business llllrelated to the

manufacture, sale or marketing of opioids.


I declare under penalty of perjury that the foregoing is true and con-eel

Executed at f'A(,.,"" h~, fLthis l..) ~ yofMarch,2019.

~ Lewent

2

commonwealth of massachusetts suffolk, ss. … declarations … · 7/17/2019 · pharma l.p. et...

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