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Jessica T. Simpson v. Amylin Pharmaceuticals

April 11, 2013

JESSICA T. SIMPSON, PLAINTIFF,
v.
AMYLIN PHARMACEUTICALS, INC., TODD BILLINGSLEY, DENISE PRINDIVILLE, AND CAROLINE ESPREE, DEFENDANTS.



ORDER

On March 11, 2013, the Court conducted a hearing on Plaintiff's Motion for Discovery [# 20]. After a review of the entire record in this case, the relevant legal authority, and after the benefit of oral argument, the Court entered an oral Order grant in part and denying in part the Motion [# 20]. The Court directed counsel for Plaintiff to prepare a proposed order consistent with the Court's oral Order. The Court has largely adopted the proposed order submitted by counsel for Plaintiff. Consistent with the Court's prior oral Order, the Court GRANTS in part and DENIES in part the motion [# 20].

I. Analysis

A.Interrogatories

1. Interrogatory No. 3: Defendant shall produce the laptop which Plaintiff used during her employment by April 1, 2013, and which is currently in the possession of Amylin. Plaintiff shall have one week in which to have a forensics expert examine the laptop for any relevant documents. The parties shall confer and submit a protective order stating that any information contained on the laptop that is not related to the instant case may not be disclosed to any person, for any reason.

2. Interrogatory No. 7: Defendant's objection to Interrogatory No. 7 is sustained in part, and overruled in part. Defendant shall identify each and every person who was employed from January 1, 2006, through December 31, 2010, in the positions of sales representative, sales specialist, senior sales representative, district sales manager, regional sales manager, or in any other capacity as a pharmaceutical sales representative in Maryland, District of Columbia, Virginia, North Carolina, South Carolina, Kentucky, Tennessee, Georgia, Alabama, Mississippi, Louisiana, and Florida. Defendant shall also provide the dates of employment and job titles of such persons. For those persons who are no longer employed, Defendant shall provide the reasons for their separation or termination, and identify all documents relating to the separation or termination.

3. Interrogatory No. 8: Defendant's objection to Interrogatory No. 8 is sustained in part, and overruled in part. Defendant shall identify each and every person who was employed from January 1, 2006, through December 31, 2010, in the positions of sales representative, sales specialist, senior sales representative, district sales manager, regional sales manager, or in any other capacity as a pharmaceutical sales representative in Maryland, District of Columbia, Virginia, North Carolina, South Carolina, Kentucky, Tennessee, Georgia, Alabama, Mississippi, Louisiana, and Florida, who requested paid or unpaid leave from work for a prenatal condition, pregnancy, or postpartum condition. For such persons, Defendant shall state the reason for the requested leave from work; state whether it granted or denied the leave request; state the reason for granting or denying the leave request; identify all documents relating to such request for leave, and the granting or denial of such request for leave.

4. Interrogatory No. 9: Defendant's objection to Interrogatory No.9 is sustained in part, and overruled in part. Defendant shall identify each and every person who was employed from January 1, 2006, through December 31, 2010, in the positions of sales representative, sales specialist, senior sales representative, district sales manager, regional sales manager, or in any other capacity as a pharmaceutical sales representative in Maryland, District of Columbia, Virginia, North Carolina, South Carolina, Kentucky, Tennessee, Georgia, Alabama, Mississippi, Louisiana, and Florida, who requested paid or unpaid leave from work for any reason other than a vacation leave. For such persons, Defendant shall state the reason for the requested leave from work; state whether the leave was granted or denied; state the reason for granting or denying the leave request; and identify all documents relating to such leave request, and the granting or denial of such requests for leave.

5. Interrogatory No. 10: Defendant's objection to Interrogatory No. 10 is sustained in part, and overruled in part. Defendant shall identify each and every person who was terminated from January 1, 2006, through December 31, 2010, from the positions of sales representative, sales specialist, senior sales representative, district sales manager, regional sales manager, or in any other capacity as a pharmaceutical sales representative in Maryland, District of Columbia, Virginia, North Carolina, South Carolina, Kentucky, Tennessee, Georgia, Alabama, Mississippi, Louisiana, and Florida. For each such person, Defendant shall state the job title of the person terminated; the reason(s) for the person's termination; whether any identified person was later re-employed; whether each identified person requested paid or unpaid leave from work other than vacation leave; and whether each person was granted, or denied, paid or unpaid leave; and identify all documents relating to the same.

6. Interrogatory Nos. 11 -- 14: Defendant's objections to Interrogatory Nos. 11 -- 14 are sustained in part, and overruled in part. Defendant shall identify each and every person who was employed from January 1, 2006, through December 31, 2010, in the positions of sales representative, sales specialist, senior sales representative, district sales manager, regional sales manager, or in any other capacity as a pharmaceutical sales representative in Maryland, District of Columbia, Virginia, North Carolina, South Carolina, Kentucky, Tennessee, Georgia, Alabama, Mississippi, Louisiana, and Florida, who:

(a) was alleged to have made misrepresentations regarding his/her work activities to a manger or supervisor, and for each person identified, Defendant shall state whether any investigation, counseling, or disciplinary action was taken with respect to the person, and if so, describe the investigation, counseling, or disciplinary action, and identify all documents relating to such investigation, counseling, or disciplinary action;

(b) was alleged to have entered duplicative and/or false sales call entries, and for each person identified, Defendant shall state whether any investigation, counseling, or disciplinary action was taken with respect the person, and if so, describe the investigation, counseling, or disciplinary action, and identify all documents relating to such investigation, counseling, or disciplinary action;

(c) who was alleged to have violated, or failed to comply with your policies, practices, or guidances regarding interactions or communications with healthcare professionals, and for each person identified, Defendant shall state each person's violation of the policies, practices, or guidances, and state whether any investigation, counseling, or disciplinary action was taken with respect the person, and if so, describe the investigation, counseling, or disciplinary action, and identify all documents relating to such investigation, counseling, or disciplinary action; and

(d) who was alleged to have misrepresented the fact that he/she was working during working time, when in fact, he/she was not engaged in work activities, or was away from work, and for each person identified, Defendant shall state whether any investigation, counseling, or disciplinary action was taken with respect to the person, and if so, describe the investigation, counseling, or disciplinary action; and identify all documents relating to such investigation, counseling, or disciplinary action.

For all persons identified in response to the foregoing interrogatories, Defendant shall provide the name, address(es), and telephone ...


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