Plaintiff brought suit on her own behalf and on behalf of her daughter charging defendants with responsibility for birth defects suffered by the daughter as the result of use of the drug known as Norlutate and/or Norlutin, manufactured and sold by defendant-appellant Parke, Davis & Co. (Parke), and prescribed by defendant-respondent Dr. Shapiro. A notice of deposition by codefendant Shapiro requires the production by Parke, for use on the examination, of "all relevant...
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