Staci Walker
3 Valley Lane
Kingston, NH 03848

The Sheriff or Deputy of any County is ordered to summon each defendant to file a written appearance with the Superior Court at the address listed below by the return day of this writ, which is the first Tuesday of March 2006.

IN A PLEA OF THE CASE, that on or about May 17, 2003, Plaintiff’s dog was administered a Pro-Heart 6 injection, a preventive heartworm drug, manufactured, sold and distributed by the Fort Dodge Animal Health Division of Defendant. Shortly after the injection, Plaintiff’s dog experienced serious health problems, including but not limited to kidney and autoimmune damage. Defendant owed a duty to Plaintiff to release safe drugs after careful testing and review and warn users of its potential harm. The Defendant breached its duty to Plaintiff by releasing a drug with severe undisclosed side-effects. As a result of Defendant’s negligence, Plaintiff’s dog suffered severe pain, underwent extensive treatment, and died on February 8, 2005 due to the effects of Defendant’s product. Defendant’s negligence caused Plaintiff to suffer injuries including but not limited to emotional distress, veterinary bills, loss of wages, and loss of companionship.

IN A PLEA OF ASSUMPSIT, the Defendant breached the express and implied warranties of the product by distributing an unsafe product and failing to accurately represent the product to Plaintiff, an intended user
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IN A PLEA OF TRESPASS, the Defendant engaged in intentional infliction of emotional distress by its extreme and outrageous conduct. Defendant knew of the drug’s serious side-effects and released it into the market stream anyway. Defendant also engaged in trespass to chattels, battery, and conversion of Plaintiff’s personal property.

ALL TO THE DAMAGE OF THE PLAINTIFF, in an amount sufficient to compensate her for her losses, together with interest and costs, and within the jurisdictional limits of this Court.