Plaintiffs v. Abbott Laboratories, an Illinois Corporation, Defendant.

1 4. Plaintiff William Shearer, M.D., ("Dr. Shearer") is
2 and was, at all times mentioned herein, a citizen of the State of
3 Texas. Dr. Shearer is, and at all times herein mentioned was,
4 the Director of the AIDS Research Center at Baylor College of
5 Medicine, with an office located at Room 0-321, 6621 Fannin
6 Street, Houston, Texas 77030.
7 5. Diane Wara, M.D. ("Dr. Wara"), is and was, at all
8 times mentioned herein, a citizen of the State of California.
9 Dr. Wara is, and at all times herein mentioned was, the Director
10 of the Department of Pediatrics at Moffitt Hospital of the
11 University of California, San Francisco, with an office located
12 at 505 Parnassus, Room M-601B, San Francisco, California 94143.
13 6. Plaintiffs are informed and believe and on that
14 basis allege that defendant Abbott Laboratories is an Illinois
15 corporation organized under the laws of the State of Illinois,
16 having its principal place of business in the State of Illinois.
17 7. This Court has original jurisdiction under 28
18 U.S.C. Section 1332, in that it is a civil action between
19 citizens of different states in which the matter in controversy
20 exceeds, exclusive of costs and interest, fifty thousand dollars.
21 8. Venue is proper in the United States District Court
22 of Maryland in that it is the judicial district in which a
23 substantial part of the events or omissions giving rise to the
24 claim occurred.
25

26 Introduction
27 9. Approximately 1,800 children are born each year in I
28 the United States infected with the human immunodeficiency virus
3