EXHIBIT 1 

Case 7:20-cv-02945-MCR-HTC Document 20-1 Filed 08/09/22 Page 1 of 7
Shanika Roper 

1 

2 

3 

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 

PENSACOLA DIVISION 

NORTHERN DISTRICT OF FLORIDA 

UNITED STATES DISTRICT COURT 

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Case 7:20-cv-02945-MCR-HTC Document 20-1 Filed 08/09/22 Page 2 of 7
Shanika Roper 

1 

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8 

9 

Q. 

A. 

Q. 

Glock? 

A. 

Q. 

Sauer? 

A. 

Q. Okay. Other than the M16 and the 

I'm not sure. 

I'm not sure. 

Was it Glock, I think? Or was it Sig 

9mm? 

Yes. 

Okay. Who made the 9mm? Was that 

10 9mm, any other -- any other heavy weapons you may 

11 have used? 

12 

13 

14 carry? 

15 

16 

A. 

Q. 

A. 

Q. 

No. 

Okay. Was your 9rnrn your everyday 

No. My everyday carry was the Ml6. 

Okay. Let's talk about the M16 just 

17 a little bit. How frequently did you use your 

18 Ml 6? 

19 

20 

A. 

Q. Okay. Outside of the range two times 

We went to the range twice a year. 

21 a year, did you ever use your M16? 

22 

23 

A. 

Q. 

No. 

Okay. And when you would go to the 

24 range, would you use hearing protection? 

25 A. Yes. 

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Case 7:20-cv-02945-MCR-HTC Document 20-1 Filed 08/09/22 Page 3 of 7
1 Q. 

Shanika Roper 

Okay. Did you use the Combat Arms 

2 earplugs? 

3 

4 

A. 

Q. 

Yes. 

Okay. Any other hearing protection 

5 devices you can remember using at the gun range? 

6 A. No. 

7 Q. Okay. Okay. The 9mrn, how often did 

8 you use the 9mrn? 

9 A. About the same. Twice a year when we 

10 would go to the range. 

11 Q. Okay. And what hearing protection 

12 did you use when firing the 9mm? 

13 A. What was provided. 

14 Q. Okay. I guess when you say what was 

15 provided, I guess every range is different 

16 sometimes. But was it something where you would 

17 show up to your station on the range and there 

18 would be hearing protection there at that station? 

19 

20 

21 ear? 

22 

A. 

Q. 

A. 

Yes. 

Okay. Was that over ear or in the 

In the ear. 

23 Q. Okay. Do you remember what the 

24 Combat Arms earplugs looked like? 

25 A. I don't. 

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Case 7:20-cv-02945-MCR-HTC Document 20-1 Filed 08/09/22 Page 4 of 7
1 Q. 

Shanika Roper 

Okay. Do you remember them having 

2 two -- I guess, two separate ends to them like a 

3 yellow end and a green end? 

4 A. Yes. I do know they had some 

5 separate ends, yes. 

6 Q. Okay. When you were at the gun range 

7 firing the Ml6 and the 9mm, which end did you put 

8 into your ear, the yellow or the green? 

9 

10 

A. 

Q. 

I don't remember. 

Okay. Did the officer in charge of 

11 the range provide you any sort of instruction or 

12 guidance on which end of the earplug you should 

13 use? 

14 

15 

A. 

Q. 

I do not recall. 

Did the officer in charge of the 

16 range, I guess, demonstrate how to use the 

17 earplugs that were -- or hearing protection that 

18 was provided? 

19 A. I don't recall. 

20 Q. And just to interject, your video 

21 rotated again so you are sideways. There you go. 

22 We are clear again. Okay. Where was I? Where 

23 was I? Okay. 

24 Outside of the Ml6 and 9mm and doing range 

25 practice approximately two times per year, just to 

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Case 7:20-cv-02945-MCR-HTC Document 20-1 Filed 08/09/22 Page 5 of 7
1 Q. 

Shanika Roper 

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 

6 

A. 

Q. 

Not that I recall. 

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 

14 

15 

A. 

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

I 

We would just -- well, I would just 

in any certain way, one color over the other. 

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 

25 

A. 

Q. 

No. 

Okay. Did you ever undergo any sort 

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Case 7:20-cv-02945-MCR-HTC Document 20-1 Filed 08/09/22 Page 6 of 7
Shanika Roper 

1 hearing protection on the range that was provided 

2 to you, where did you obtain earplugs if you 

3 needed them, you know, outside of the range 

4 context? 

5 

6 

A'. 

Q. 

Usually the unit would provide them. 

Okay. So I guess to use another sort 

7 of example, when you were taking the Humvee out to 

8 go drop mail and, you know, pick mail up from 

9 places, where would you obtain the earplugs that 

10 you would use while you rode or drove around the 

11 Humvee? 

12 

13 

A. 

Q. 

The supply section would have them. 

And when you were done with your 

14 rounds in the Humvee, what would you do with the 

15 hearing protection? 

16 A. Throw them away. 

17 Q. Did you come home from Iraq with any 

18 of the earplugs that you used over there? 

19 A. Not that I remember. I'm not sure. 

20 Q. Okay. Let's see, other than the 

21 earplugs with the green and yellow ends, are there 

22 any other earplugs that you recall using while you 

23 were in the military? 

24 

25 

A. 

Q. 

No. 

Okay. Do you remember getting any 

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