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In re Lupron Marketing & Sales Practices Litigation

Citations: 221 F.R.D. 13; 2004 U.S. Dist. LEXIS 9390; 2004 WL 758393Docket: No. MDL NO. 1430; Master File No. 01-CV-10861-RGS

Court: District Court, D. Massachusetts; February 29, 2004; Federal District Court

Narrative Opinion Summary

TAP Pharmaceutical Products, Inc. (TAP) filed a motion to compel individual plaintiffs to release their personal medical, employment, and insurance records, asserting that these records are essential for discovery related to class certification and the merits of the case. TAP highlighted the importance of evidence regarding the number of Lupron® injections received, the costs incurred, and any reimbursements from third-party payors. In response, the plaintiffs indicated that they would promptly provide relevant information but questioned the necessity of their medical records. The court acknowledged TAP's need for some discovery but concluded that the plaintiffs' medical records were not pertinent to the central issue of whether the plaintiffs had paid a fraudulently inflated price for Lupron®. The court emphasized that the plaintiffs' medical motivations are irrelevant to the question of overpricing. As a result, the motion to compel was denied.

Legal Issues Addressed

Discovery Scope in Class Action Lawsuits

Application: The court evaluated the necessity of the plaintiffs' personal medical records for the purpose of class certification and merits discovery, ultimately determining that such records were not essential to the central issue of the case.

Reasoning: The court acknowledged TAP's need for some discovery but concluded that the plaintiffs' medical records were not pertinent to the central issue of whether the plaintiffs had paid a fraudulently inflated price for Lupron®.

Relevance of Medical Records in Pricing Disputes

Application: The court found that the personal medical motivations of the plaintiffs were not relevant to the allegations of fraudulent pricing, thus medical records did not need to be disclosed.

Reasoning: The court emphasized that the plaintiffs' medical motivations are irrelevant to the question of overpricing.