SAN FRANCISCO -- William Paschal and his wife Patricia accuse Bayer Healthcare Pharmaceuticals of manufacturing and releasing a compound into the market consisting of highly toxic metals that allegedly causes consumers to suffer a painful and deadly disease.

The complaint filed March 3 in U.S. District Court Northern District of California names the Division General Electric Company, GE Healthcare Inc., Mallinckrodt, Inc. and Bracco Diagnostics, Inc. as defendants, in addition to Bayer.

According to the complaint, the plaintiff allegedly contracted nephrogenic systemic fibrosis (NSF) in January through intravenous injections containing the gadolinium-based contrast (the highly toxic metal) manufactured and sold by defendants.

NSF is characterized by discoloration, thickening, tightening and swelling of the skin after injections, according to the complaint. When NSF progresses it leads to painful inhibition of the ability to use the arms, legs, hands feet and other joints. When NSF progresses to the scarring of other body organs such as the lungs, heart, liver, it can lead to their inability to function properly and may lead to death.

Attorneys for the Paschals allege that the defendants never tested the compound's safety on individuals with kidney impairments before marketing it; however plenty of tests conducted on animals showed internal and external scarring.

William Paschal claims he has suffered scarring from the compound which has impaired his kidneys.

Plaintiffs are represented by Levin, Simes Kaiser & Gornick LLP, of San Francisco.

They have demanded the defendants answer charges of failure to warn, design defect, failure to adequately test, negligence, negligent misrepresentation, fraud, concealment, suppression or omission of material facts, breach of express and implied warranty and loss of consortium.

The defendants have yet to respond.