EXHIBIT 3
Shanika Roper

Golkow Litigation Services Page 1

 1 UNITED STATES DISTRICT COURT

 2 NORTHERN DISTRICT OF FLORIDA

 3 PENSACOLA DIVISION

 4

 5

 6

 7

 8 IN RE: 3M COMBAT ARMS

EARPLUG PRODUCTS LIABILITY

 9 LITIGATION

10 CASE NO:

 3:19-md-2885-MCR-GRJ

11

 Judge M. Casey Rodgers

12 Magistrate Judge Gary R. Jones

13

14 THIS DOCUMENT RELATES TO:

SHANIKA ROPER

15

CASE NO. 7:20cv02945-MCR-GRJ

16

_____________________________

17

18

19

 The videotaped testimony via Zoom Video

20

Conferencing of SHANIKA ROPER, with the witness in

21

Atlanta, Georgia, taken on the 1st day of

22

February, 2022, commencing at approximately

23

 a.m. EST, before Jennie Q. Brown, Certified

24

Court Reporter.

25
Shanika Roper

Golkow Litigation Services Page 62

 1 that 12 hours a day indoors, what loud noises

 2 would you have been exposed to kind of on a daily

 3 basis?

 4 A. If -- a forklift, if anything at all,

 5 just for moving mail. But nothing loud, loud.

 6 Q. Okay. All right. Okay. As for the

 7 Combat Arms, do you remember when you were first

 8 given a Combat Arms earplug?

 9 A. I do not.

10 Q. Okay. Do you remember being provided

11 any instruction on the Combat Arms?

12 A. Not that I recall, I don't remember.

13 Q. Okay. And I think we talked about a

14 -- I think I asked this question earlier (audio

15 distortion) make sure.

16 You don't specifically recall what the

17 Combat Arms earplugs looked like, correct?

18 STENOGRAPHIC REPORTER:

19 Can you repeat that, please?

20 MR. BAUER:

21 We can't hear you again.

22 MR. CARTER:

23 Typical. Typical. Technology is

24 always my friend.

25 BY MR. CARTER:
Shanika Roper

Golkow Litigation Services Page 63

 1 Q. Just to clarify from earlier,

 2 Ms. Roper, you don't have any specific

 3 recollection what the Combat Arms earplug looks

 4 like, correct?

 5 A. Not that I recall.

 6 Q. Okay. Do you just generally recall

 7 ever having an earplug that had a yellow end and a

 8 green end?

 9 A. Yes.

10 Q. Okay. Tell me about those earplugs,

11 the green and yellow earplugs. What do you recall

12 about them?

13 A. We would just -- well, I would just

14 put them in my ear. I don't recall putting them

15 in any certain way, one color over the other. I

16 just remember putting them in my ear.

17 Q. And you don't recall whether you were

18 putting in the yellow end or the green end?

19 A. I do not.

20 Q. Do you remember having any discussion

21 or being given any sort of instructions about what

22 the yellow end was for, what the green end was

23 for?

24 A. No.

25 Q. Okay. Did you ever undergo any sort
Shanika Roper

Golkow Litigation Services Page 127

 1 CERTIFICATE

 2

 3

 4 I, Jennie Q. Brown, Certified Court

 5 Reporter do hereby certify that prior to the

 6 commencement of the examination, the witness was

 7 remotely sworn by me to testify to the truth, the

 8 whole truth and nothing but the truth.

 9

10 I do further certify that the foregoing is

11 a verbatim transcript of proceedings in the matter

12 aforementioned and was transcribed by me using

13 stenographic means, to the best of my ability.

14

15 I do further certify that I am neither of

16 counsel nor of kin to the parties to the action,

17 nor am I otherwise interested in the outcome of

18 this case.

19

20

21

22

JENNIE Q. BROWN, CCR

23

Certified Court Reporter

24

25