MONTANA FIRST JUDICIAL DISTRICT COURT
LEWIS AND CLARK COUNTY
STATE OF MONTANA,
Plaintiff,
V.

PURDUE·PHARMA L.P., PURDUE
PHARMA, INC. , THE PURDUE
FREDERICK COMP ANY, and
JANE DOES 1-10
Defendants.

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) Cause No. ADV-2017-949
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). DECLARATION OF SEAN THATCHER
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I, Sean Thatcher, declare as follows:
1.

I was a Sales Representative with Purdue Pharma from September 2009 until

August 2015, when I was laid off. I was responsible for promoting OxyContin, Hysingla and
Butrans in Montana. I called on a list of approximately 100 doctors and other prescribers in
Montana, including family practitioners, anesthesiologists, pain specialists, physician assistants,
and nurse practitioners. I also hosted three to four events a year with speakers paid by Purdue to
which I invited doctors.
2.

When I began with Purdue, I attended several weeks of training at Purdue's

headquarters in Connecticut. This was followed by field training with more seasoned
representatives in the field, and my district manager periodically accompanied me on my sales
calls. I also attended annual trainings at various locations.
3.

As a Sales Representative, I received a base salary and a bonus based on the

number of Purdue opioid prescriptions written by prescribers I was assigned to visit. My main

 focus was promoting OxyContin , and OxyContin prescriptions were given greater weight in
calculating my bonus.
4.

Purdue ranked the doctors I visited based on prescription data the company

regularly purchased from a commercial source. "High decile" prescribers were those who
prescribed more of Purdue ' s drugs or, because of their prescribing of other opioids , were
potentially high prescribers. They were priority targets for the sales team.
5.

One of the primary sales messages I was trained to deliver was that OxyContin

was more convenient because it was given twice-a-day. Roughly 30% to 40% of doctors I called
on complained that pain re_lief from OxyContin did not last 12 hours, as represented , even at high
doses.
6.

I was directed to market OxyContin for chronic pain, including lower back pain

and pain from arthritis. Some of the doctors I visited had patients who were on OxyContin for a
year or more , and complained that their patients were developing a tolerance to the product. I
was trained to tell doctors that they should titrate up the dose for patients who developed
tolerance.
7.

I was also instructed to tell prescribers that OxyContin would help patients

improve their quality of life, and focused prescribers on patients who were out of work or not
able to function day to day as a result of pain. I also discussed psuedoaddiction with doctors and
spoke about patient contracts with prescribers.
8.

After OxyContin was reformulated as an abuse-deterrent , sales increased

nationwide. I was trained to reactively discuss the abuse-deterrent formulation and these
discussions often took place with prescribers who were reluctant to prescribe opioids. I was

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 trained to talk to them about proper patient selection and trying to keep the drugs out of the
hands of patients with a history of drug dependence.
9.

Sales representatives would also ask doctors and medical staff at their offices to

pull or flag the charts of patients who would be "good candidates" for Purdue's opioid products.
For example, sales representatives would encourage the offices to pull the charts of patients on
opioids manufactured by other companies so that the representative and doctor could discuss the
appropriateness of converting those patients to a Purdue product. I know of this practice based
on discussions at Purdue sales meetings , which were attended by sales representatives and
district managers. The practice of flagging patient charts was among the "best practices"
recommended by managers and discussed by various sales representatives as something that
worked well for them in the field. The practice was prevalent, and it occurred throughout the
duration of my employment with Purdue. I did not engage in this practice because I did not
believe that the providers I visited would be receptive to it.
I 0.

I was trained by Purdue to look for doctors who might be diverting or over-

prescribing drugs. Management advised sales representatives that they did not have to call on
doctors they suspected of engaging in illegal or inappropriate prescribing of Purdue's drugs or
other opioids. One doctor I visited - Dr. Christiansen - was a high opioid prescriber. I believe ,
but am not sure, that he was placed on the "do not contact" list after his clinic was raided. I was
not aware of any instance in which Purdue reported a Montana doctor to law enforcement
authorities.
I declare under penalty of perjury that the foregoing is true and correct. This Declaration
was executed in Helena, Montana, on February J.k._,
2018.

J~

Sean Thatcher

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