IN THE [SUPERIOR COURT / FEDERAL COURT] OF [JURISDICTION]

Plaintiff:
Mike Jukic, Axis Law, on behalf of consumers of Johnson & Johnson products

Defendant:
Johnson & Johnson and related subsidiaries

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COMPLAINT

Plaintiff, by and through counsel, Axis Law, alleges as follows against Johnson & Johnson (“Defendant”):

I. INTRODUCTION

1. This is an action seeking damages, restitution, and injunctive relief arising from Defendant’s manufacture, marketing, and sale of products that were contaminated, toxic, and hazardous to human health.
2. Defendant has long represented itself as a trusted producer of consumer health and wellness products, while concealing and minimizing the risks associated with its talc-based baby powder, adhesive bandages, oral care products, and other consumer goods.

II. JURISDICTION AND VENUE

3. Jurisdiction is proper in this Court because Defendant conducts business in this jurisdiction and sells its products nationwide and/or within the Province of [X].
4. Venue is proper because Defendant maintains continuous and systematic contacts with this forum.

III. PARTIES

5. Plaintiff Mike Jukic, of Axis Law, brings this suit on behalf of consumers who purchased and used Johnson & Johnson products, and who suffered injuries, increased health risks, or economic loss as a result of Defendant’s misconduct.
6. Defendant Johnson & Johnson is a multinational corporation headquartered in New Brunswick, New Jersey, with numerous subsidiaries engaged in the manufacture and distribution of health and consumer products.

IV. FACTUAL ALLEGATIONS

7. Defendant’s talc-based baby powder has been scientifically linked to ovarian cancer, mesothelioma, and other illnesses due to asbestos contamination.
8. Defendant sold and promoted this product for decades, targeting infants and women, while concealing evidence of contamination and health risks.
9. Defendant’s bandages and adhesive products contained toxic adhesives, glues, and additives capable of causing skin irritation, allergic reactions, and potential systemic harm.
10. Defendant’s toothpastes and oral care products contained harmful chemicals, including fluorides and preservatives, without adequate disclosure of risks.
11. Defendant knowingly misrepresented these products as “safe,” “gentle,” and “trustworthy,” while suppressing or ignoring mounting scientific evidence of toxicity.
12. As a direct and proximate result of Defendant’s misconduct, consumers—including vulnerable populations such as children and mothers—suffered physical harm, increased risk of disease, emotional distress, and economic loss.

V. CAUSES OF ACTION

Count I – Product Liability (Defective and Unreasonably Dangerous Products)
Count II – Failure to Warn
Count III – Negligence
Count IV – Fraudulent Concealment & Misrepresentation
Count V – Breach of Implied Warranties of Merchantability and Fitness
Count VI – Violation of Consumer Protection Statutes

VI. PRAYER FOR RELIEF

WHEREFORE, Plaintiff respectfully requests judgment against Defendant as follows:
A. Compensatory damages in an amount to be determined at trial;
B. Punitive damages for Defendant’s willful and reckless conduct;
C. Restitution and disgorgement of profits unjustly obtained;
D. Injunctive relief requiring full disclosure of product risks and removal of hazardous products from the market;
E. Attorneys’ fees and costs; and
F. Such other and further relief as this Court deems just and proper.

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Dated: [Insert date]
Respectfully submitted,

Axis Law
By: ___________________________
Mike Jukic, Esq.
Attorney for Plaintiff