o      According to the April 2, 2020, second amended complaint in Gilliana R. Mills v. Johnson & Johnson, “The defective and unreasonably dangerous conditions discussed herein existed when the product left the Defendants’ control. They existed when the Defendants sold the product. They existed when they interacted with the plaintiff.

“As a direct and proximate result of the Defendants’ conduct, Plaintiff has suffered permanent injuries and is entitled to recover damage for her injuries, including lost wages, physical and mental anguish, past and future medical expenses, past and future pain and suffering, and permanent injury.”[1]

[1] Second Amended Complaint, Mills v. Johnson & Johnson, Case No. 19-cv-248, U.S. District Court, Eastern District of Kentucky, Filed April 2, 2020