In re: Just for Men Mass Tort Litigation

Filing 21

Case Management Order ("CMO") #7 regarding use of Defendant Fact Sheets. Signed by Judge David R. Herndon on 8/28/2017. (Attachments: # 1 Exhibit Defendant Fact Sheet)(ceh)

ATTACHMENT A
UNITED STATES DISTRICT COURT
FOR THE SOUTHERN DISTRICT OF ILLINOIS
EAST ST. LOUIS DIVISION

IN RE: Just For Men® Mass
Tort Litigation

Case No. 3:16-cv-00638-DRH
Master Docket – In Re: Just For Men
Mass Tort Litigation®

This Document Relates to:
Plaintiff: [Insert Plaintiff Name]
Individual Case Docket No.: [Insert Case Docket No, If Applicable]
DEFENDANTS’ FACT SHEET
This Defendant Fact Sheet (DFS) is submitted pursuant to Case Management Order 7, by
Defendants, in response to the Plaintiff’s Fact Sheet (PFS) served on [Insert Date].
I.

CASE INFORMATION

This defendant fact sheet pertains to the following case:
Case Name

II.

Docket Number (if applicable)

CONTACTS WITH HEALTHCARE PROVIDERS(S)
A. Consulting Relationships
1. Have any of the Plaintiff’s Healthcare Provider(s) identified in Section VI
(C) and/or (G) of the PFS been retained and/or compensated by
Defendants as a speaker or consultant relating to any Just For Men®
products.
Yes ____ No____
2. If so, provide the information requested below.

Healthcare Provider

Compensation

Nature of Affiliation

III.

INFORMATION REGARDING THE PLAINTIFF
A. Have you been contacted by Plaintiff or anyone acting on Plaintiff’s behalf (other
than Plaintiff’s counsel) through any 1-800 number, in writing, or through any
other source by Plaintiff?

Yes

Don’t Know

No

1. If yes, please state the name of the person(s) who contacted you and the
name, address and phone number of the person(s) who responded to the
contact on your behalf, the content of the call/written communication and
produce any documents relating to the contact or response.
Name

Address

Phone
Number

Content of the
Call/Written
Communication

Documents
Produced

B. Please produce a copy of (1) any adverse reaction /complaint form which relates
to the Plaintiff, (2) copies of all documents reflecting communications received
from Plaintiff, and (3) all written responses from Defendant to Plaintiff, including
but not limited to communications from Consumer Resources Consultants, or
Product Integrity Managers, or any other employee of Defendant.
C. State whether any named Defendant has any record of Plaintiff participating in inhouse product testing conducted by Combe Incorporated.
Yes ____ / No _____.
If yes, please provide the information requested below:
Date of
Participation

Type of
Testing

Whether
Plaintiff Was
Compensated
(Yes or No)

Type of
Compensation
(Coupon/Monetary/
Product)

2

Did Plaintiff
Sustain an
Adverse Reaction
during
participation

If
Adverse
Reaction,
treatment
offered to
Plaintiff

IV.

DISTRIBUTION OF JUST FOR MEN PRODUCTS TO RETAIL FACILITIES
IDENTIFIED BY PLAINTIFF
A. Did you sell the Just For Men® product(s) identified in Section II.A of the
Plaintiff’s Fact Sheet to the retail chain identified in Section II.A of the Plaintiff’s
Fact Sheet during the twelve (12) month period of time preceding the date of
injury?
Yes ____ No ____ Don’t Know ____
B. To the extent the “Named Store” identified in Section II.A of the Plaintiff’s Fact
Sheet is not part of a retail chain, did you sell the Just For Men® product(s)
identified in Section II.A to the store(s) identified in Section II.A of the Plaintiff’s
Fact Sheet (the “Named Store”) during the twelve (12) month period of time
preceding the date of injury?
Yes ____ No ____ Don’t Know ____

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DEFENDANTS' CERTIFICATION
I am employed by Combe Incorporated, one of the Defendants in this litigation. I am
authorized by Combe Incorporated to execute this certification on each Defendant’s behalf. I
hereby certify that the information provided in the accompanying Response to Defendants' Fact
Sheet is not within my personal knowledge, but the facts stated therein have been assembled by
authorized employees and counsel, upon which I relied. I hereby certify, in my authorized
capacity, that the responses to the aforementioned Defendants' Fact Sheet are true and complete
to the best of my knowledge on information and belief.

Name: [type printed name here and sign above line]

Date

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