Defendants. )

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF TENNESSEE

UNITED STATES OF AMERICA, ) )

�� ) )

Civil Action No. -----

V. ) )

KEYSTONE LABORATORIES, INC., a corporation,)

CONSENT DECREE OF PERMANENT INJUNCTION

MELINDA MENKE and ELIZABETH JUMET, ) individuals, )

) Defendants. )

_________________ )

Plaintiff, the United States of America, by and through its undersigned attorneys, having

filed a Complaint for Permanent Injunction against Keystone Laboratories, Inc., a corporation,

and Melinda Menke and Elizabeth Jumet, individuals (hereinafter, collectively, "Defendants"),

and Defendants having appeared and consented to entry of this Decree without contest, and

before any testimony has been taken, and the United States of America, having consented to this

Decree;

IT IS HEREBY ORDERED, ADJUDGED, AND DECREED as follows:

1. This Court has jurisdiction over the subject matter of this action and all parties to this

action. Venue is proper in this District under 28 U.S.C. § 1391(b) and (c).

2. The Complaint states a cause of action against Defendants under the Federal

Food, Drug, and Cosmetic Act, 21 U.S.C. §§ 301 et seq. (the "Act").

3. The Complaint alleges that Defendants violate 21 U.S.C. § 33 l(a) by introducing or

delivering for introduction, or causing to be introduced or delivered for introduction, into

interstate commerce articles of drug, as defined by 21 U.S.C. § 321(g)(l), that are adulterated

18-2656

Case 2:18-cv-02656-JTF-dkv Document 1-2 Filed 09/25/18 Page 1 of 26 PageID 20


























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