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Woman injured by drugs as a girl.  She'd had 3 docs, one was now dead.  Lawyers sued the pharma companies used by the 2 living docs, and also Upjohn, assuming because it had a big market share that it was likely that the third doc used Upjohn (statute of limitations was running).  Sanctioned.

H - no likelihood add'l med records would be found, shouldn't have included Upjohn.

Sherman says - should've hired a P.I. to show they did all they could to find those records.