EXHIBIT 3
1

UNITED STATES DISTRICT COURT 

NORTHERN DISTRICT OF FLORIDA 

PENSACOLA DIVISION

IN RE: 3M COMBAT ARMS 

EARPLUG PRODUCTS 

LIABILITY LITIGATION

)

) CASE NO. 3:19-MD-2885

)

PLAINTIFF SHANIKA ROPER’S RESPONSES TO DEFENDANT 3M’S AMENDED 

AMENDED FIRST SET OF INTERROGATORIES TO PLAINTIFF

TO: Defendant 3M Company (“3M”), and through its Attorneys of Record: Mark Nomellini, 

Kirkland & Ellis LLP, 300 North LaSalle Chicago, IL 60654; and Mike Brock, Kirkland 

& Ellis LLP, 300 North LaSalle Chicago, IL 60654.

COMES NOW, Plaintiff, Shanika Roper, through the undersigned attorney, and in 

accordance with the Federal Rules of Civil Procedure, submits the following Plaintiff’s 

Responses to Defendant 3M’s (“Defendant” or “3M”) Amended First Set of Interrogatories to 

Plaintiff. As discovery in this matter is ongoing, Plaintiff reserves the right to amend, supplement, 

modify, or change her responses.

Dated: January 6, 2022

Respectfully submitted,

REICH & BINSTOCK, LLP

By: /S/ Dennis C. Reich

Dennis C. Reich, Esq. (TX - SBN 16739600)

Robert J. Binstock, Esq. (TX – SBN 02328250)

4265 San Felipe, Suite 1000

Houston, Texas 77027

Tel: (713) 622-7271

Fax: (713) 623-8724

dreich@reichandbinstock.com 

bbinstock@reichandbinstock.com

Attorney for Plaintiff
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CERTIFICATE OF SERVICE

 The undersigned hereby certifies that on January 6, 2022, a true and correct copy of the 

foregoing: PLAINTIFF SHANKIA ROPER’S OBJECTIONS AND RESPONSES TO DEFENDANT 3M’S 

FIRST AMENDED INTERROGATORIES TO PLAINTIFF was served as follows: [MDL Centrality]

By electronically serving the above document via the MDL Centrality Plaintiff Portal ID Number

6087.

/s/ Dennis C. Reich

Dennis C. Reich
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PLAINTIFF’S OBJECTIONS & ANSWERS TO DEFENDANT’S AMENDED FIRST SET 

OF INTERROGATORIES

INTERROGATORY NO. 1:

Identify All Persons who have knowledge of Or information Concerning Your alleged 

injuries, including but not limited to health care professionals, physicians, audiologists, nurses, 

physician assistants, treating facilities, clinics, therapists, other medical facilities Or providers that 

have examined Your ears And/Or hearing.

ANSWER:

Plaintiff objects to this Interrogatory on the ground that it is overbroad, unduly burdensome, 

vague, ambiguous, unclear, and disproportionate. As written, it asks Plaintiff to “Identify All Persons 

who have knowledge of... Your alleged injuries,” which would require Plaintiff to identify dozens 

of persons who have no substantive knowledge of or involvement in the issues in this litigation, and 

would require Plaintiff to provide information beyond her personal knowledge. Plaintiff further 

objects on the ground that this Interrogatory lacks specificity, and fails to contain any limits as to 

time or scope.

Plaintiff also objects to this Interrogatory to the extent that it seeks to require Plaintiff to 

testify as to the “information” known to or “knowledge” possessed by any Person other than herself, 

which Plaintiff cannot know.

Moreover, Plaintiff objects to this Interrogatory to the extent that it seeks information equally 

available to both Parties, in that Plaintiff has executed a release granting Defendants access to records 

that may be responsive to this Interrogatory. 

Notwithstanding said objections, and without waiving same, Plaintiff responds as follows:

Plaintiff recalls receiving treatment for her tinnitus and at the following health care facilities 

and/or clinics:

Birmingham VA Medical Center

700 19th St. South

Birmingham, AL 35233

Fox Army Health Centr

4100 Goss Rd.

Redstone Arsenal, AL 35809

INTERROGATORY NO. 2:

Describe in detail the injuries Or conditions that You allege were caused by Your use of the 

CAEv2, including but not limited to the date on which those injuries began.
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ANSWER:

Plaintiff objects to this Interrogatory to the extent that Plaintiff is not an expert and is not 

qualified with the requisite skill, knowledge, education, experience, or training to render the expert 

or legal conclusions that this Interrogatory seeks. Plaintiff objects to this Interrogatory in that it is 

overbroad, unduly burdensome and vague in that it fails to define “injury” or “condition.” Plaintiff 

also objects to this Interrogatory to the extent that the information sought is equally accessible to 

both Parties in records both Parties have received and/or will receive pursuant to the medical or other 

authorizations provided by Plaintiff.

Notwithstanding said objections, and without waiving same, Plaintiff’s injuries include 

tinnitus, from which Plaintiff began to suffer in 2018. 

INTERROGATORY NO. 3:

Describe in detail how You acquired Each pair of CAEv2 that You were issued, including 

who issued the CAEv2, And the date on which You were issued the CAEv2.

ANSWER:

Plaintiff objects to this Interrogatory on the ground that it is overbroad, vague, ambiguous 

and unclear regarding “how [Plaintiff] first acquired the CAEv2.” Plaintiff also objects to this 

Interrogatory to the extent that it is irrelevant and immaterial, and to the extent that the information 

sought is burdensome for Plaintiff to provide and is equally accessible to both Parties in records both 

Parties have received and/or will receive pursuant to the medical or other authorizations provided by 

Plaintiff. Fed. R. Civ. P. 26(b)(2)(C). Plaintiff further objects on the ground that the information 

sought by this Interrogatory may be better obtained through other discovery means. 

Notwithstanding said objections, and without waiving same, Plaintiff does not recall exactly

when and where she was issued the CAEv2 Earplugs.

INTERROGATORY NO. 4:

Describe in detail Any And All instructions, including written And oral instructions, Or 

training that You received Related To Or Concerning the CAEv2, including the Person(s) providing 

the instructions And the date of And locations at which You were provided such instructions.

ANSWER:

Plaintiff objects to this Interrogatory on the ground that it is overbroad, vague, burdensome, 

ambiguous and unclear in that it fails to contain any reasonable limitations as to time or scope, and 

fails to define “instruction(s)” or “training.” See Fed. R. Civ. P. 26(b)(1). Plaintiff objects on the 

ground that the information sought by this Interrogatory may be better obtained through other 

discovery means. Fed. R. Civ. P. 26(b)(2)(C). Plaintiff objects on the ground that the information 

sought is equally available to the requesting Party. 

Notwithstanding said objections and without waiving same, Plaintiff received instructions on 

use of the CAEv2 multiple times while in the military, including written instructions on at least one 

occasion. 
VERIFICATION

I, Shanika Roper, verify that I have read the foregoing, Plaintiff Shanika Roper’s

Answers and Objections to Defendant 3M’s First Set of Interrogatories and that the answers

contained therein are true and correct to the best of my information, knowledge, and belief. I

verify under penalty of perjury that the foregoing is true and correct.

Executed on December 11, 2021

Shanika Rope

Shanika Roper