EXHIBIT 2
1 

UNITED STATES DISTRICT COURT 

NORTHERN DISTRICT OF FLORIDA 

PENSACOLA DIVISION 

IN RE: 3M COMBAT ARMS 

EARPLUG PRODUCTS 

LIABILITY LITIGATION 

Document Relates to: 

Shanika Roper 

Civil Action No. 7:20-cv-02945-MCR-GRJ 

Case No. 3:19-md-02885 

Judge M. Casey Rodgers 

Magistrate Judge Gary R. Jones 

EXPERT REPORT OF ALAN POLLAK, M.D. 

“CONFIDENTIAL – SUBJECT TO PROTECTIVE ORDER”

 
2 

I. BACKGROUND 

A. Introduction 

Counsel for 3M has requested that I review the history and medical records of Shanika 

Roper to evaluate her hearing loss and tinnitus claims. I was further retained to review and 

evaluate the opinions submitted by Ms. Roper’s expert witnesses including the report of 

Richard Tyler, Ph.D. The opinions I offer in this report are all held to a reasonable degree of 

medical and scientific certainty. In reaching my opinions I reviewed the materials cited in 

my Report and listed in Exhibit A, Materials Considered. Further, I relied upon my education, 

and over thirty years of professional clinical experience as an Otolaryngologist/Head and 

Neck surgeon, and my clinical judgment in reaching my opinions. 

B. Professional Background and Experience 

I graduated Phi Beta Kappa with a Bachelor of Arts from Northwestern University in 

1983. I next completed a year-long clinical fellowship in Anatomic Pathology at Lutheran 

General Hospital in Park Ridge, Illinois, and then attended medical school at Rush Medical 

College in Chicago where I earned my medical degree in 1988. Following an internship in 

General Surgery at Northwestern University, McGaw Medical Center, I completed a four year 

residency at the same institution in General Surgery and Otolaryngology / Head and Neck 

Surgery. I am Board Certified by the American Board of Otolaryngology / Head and Neck 

Surgery. 

Over the past thirty years of clinical practice, I have served in many administrative 

capacities at multiple healthcare institutions. Since 2012, I have served as the Section Chief 

of Otolaryngology / Head and Neck Surgery at Mount Sinai Hospital in Chicago. I am 

currently the Chairman of the Department of Surgery at Mount Sinai Hospital. In this role, I 

am personally responsible for managing nine surgical divisions within this department for 

the past five years. 

During my ten-year period at Mount Sinai Hospital, I have also served as President of 

the Sinai Medical Group and Secretary of the medical staff. Since 2017, I have been a Clinical 

Assistant Professor of Surgery at the University of Illinois at Chicago. 

My thirty years of practice in Otolaryngology / Head and Neck Surgery has been a fulltime, patient oriented, clinical practice despite my administrative and teaching 

responsibilities. A significant component of my patient care responsibilities includes the 

diagnosis and treatment of otologic and hearing disorders. I have extensive experience in 

evaluating patient complaints of hearing loss, tinnitus, and hyperacusis arising from various 

etiologies. As an otolaryngologist, I have participated in rendering therapeutic treatment 

modalities for these conditions and have educated my patients in hearing conservation 

measures. My curriculum vitae is attached as Exhibit B. 

For this matter, I am being compensated at $250 an hour for consulting, records 

review, meetings, and drafting my report; $550 an hour for depositions; and $1,500 an hour 
3 

for trial testimony. In the past four years, I have provided expert deposition testimony in the 

following cases: C. Slama v. John Rachel, M.D. et al., Case No. 2017-L-001305, Circuit Court, 

Cook County, Illinois; K. Koryczan v. Patel, Case No. 45D01-2003-CT-00351, Lake Superior 

Court, Civil Division 7, State of Indiana . I have not testified in any trial proceeding in the last 

four years. 

C. Summary of Case-Specific Opinions 

• Surveillance Audiometric testing from April 2005 to April 8, 2017 to March 15, 

2022 inclusive of seven exams does not demonstrate any auditory deficits. 

This time period includes the time Plaintiff reportedly used the Combat Arms 

Earplugs Version 2 (“CAEv2”) hearing protection. 

• No temporary or permanent auditory threshold shifts are demonstrated from 

April 2005 to April 8, 2017 to March 15, 2022. This time period includes the 

time Plaintiff reportedly used the Combat Arms Earplugs version 2. 

• Ms. Roper’s use of the CAEv2 did not cause or contribute to any degree of 

hearing loss. 

• To the extent Ms. Roper claims audiometric threshold shifts and/or hearing 

damage as a result of her noise exposure during her military service, there are 

factors unrelated to her use of the CAEv2 which could cause and/or contribute 

to that claimed hearing damage. 

• The classification of hyperacusis described by Plaintiff’s expert does not rise 

to the level of the subtype known as recruitment. Plaintiff’s experience is 

consistent with alternate etiologies for this phenomenon and is not related to 

noise exposure while in the military. 

• Ms. Roper’s use of the CAEv2 did not cause or contribute to her complaints of 

tinnitus. 

• Ms. Roper’s medical and military history reflects factors unrelated to her use 

of the CAEv2 which could cause and/or contribute to her complaints of 

tinnitus. 

• There are medical treatments and interventions which can help with 

symptoms of hearing loss and tinnitus. 
4 

II. GENERAL BACKGROUND ON HEARING LOSS1

A. Hearing Loss 

Hearing loss can be caused by a wide variety of factors. Patients may present with the 

complaint of being unable to hear, or they may complain of difficulty understanding. Often, 

a family member brings the patient for a hearing test because of communication difficulties. 

Older individuals often complain of tinnitus, which may be described as a sound like ringing, 

buzzing, or “crickets” in the ears. While tinnitus is usually a manifestation of hearing loss, it 

may have other causes as well. Hearing loss in children may be particularly difficult to detect, 

and is often confused with inattention or speech delay. 

Depending on the specific type and etiology of the hearing loss, dramatically different 

treatments may be prescribed. It is important to determine whether the problem is with the 

conductive pathway of the ear (conductive) or with the inner ear or eighth cranial nerve 

(sensorineural). Conductive hearing loss can be due to cerumen impaction, swelling of the 

external auditory canal, tympanic membrane perforations, middle ear fluid, or ossicular 

chain abnormalities. Sensorineural hearing loss can occur as a result of injury to the hair cells 

in the cochlea or neural elements innervating the hair cells. The most common etiologic 

factors are persistent noise exposure, age-related changes of the eighth cranial nerve 

(presbycusis), genetic factors, and infectious or post-inflammatory processes. Tumor growth 

(acoustic neuroma) along the course of the eighth cranial nerve can also be the etiology of 

sensorineural loss and must be included in the differential diagnosis. 

Pure-tone audiometry (“the hearing test”) is frequently used to assess the patient’s 

hearing levels. The test requires that the patient is able and willing to cooperate. It can be 

especially difficult in the case of very young children. Hearing threshold levels are 

determined between 250 and 8000 Hertz (Hz) for pure tones and measured in decibels (dB). 

The 0-dB level is “normalized” to young, healthy adults and doesn’t mean there is absence of 

detectable sound. Some patients hear 0 dB, but reaching the threshold of hearing usually 

requires louder test signals. The higher the threshold is, the poorer the patient’s hearing. 

Thresholds higher than 25 dB are considered abnormal. 

During the audiogram, independent thresholds are determined for each ear for both 

air conduction (conductive hearing) and bone conduction (sensorineural hearing). Air 

conduction measures the ability of the external and middle ear to transmit sound to the 

cochlea. Conductive hearing loss can result from any barrier that could block sound 

transmission in this pathway (cerumen, perforation, middle ear fluid). This will create an airbone gap between the air and bone conduction thresholds on the audiogram. Sensorineural 

hearing loss can be diagnosed if the air conduction and bone conduction thresholds are equal 

but higher than 25 dB. 

1

 This information is taken primarily from the American Academy of Otolaryngology – Head and Neck Surgery 

Foundation textbook on Primary Care Otolaryngology which I find to be accurate and reliable. I have also added 

additional background information based on my education, training, and clinical experience. 
5 

Figure 6.1. A conductive hearing loss in 

the left ear due to otitis media with 

effusion. Note that bone conduction 

thresholds are normal in both ears, but air 

conduction on the left is 30 dB poorer 

than that measured on the right. 

Remember that zero (0) dB does not refer 

to absence of sound, but rather represents 

an average threshold for young, healthy 

adults. 

Our ability to hear is more complex than just listening to single pure tones in a soundproof booth. Therefore, a test of the patient’s ability to understand spoken words should be 

performed as well. In a speech discrimination test, the patient is presented with phonetically 

balanced words (i.e., love, boat, pool, sell, raise) that are amplified to a comfortable hearing 

level as necessary. The results of this test, the speech discrimination score, should be 

between 90 percent and 100 percent for “normal” speech discrimination. This test of clarity 

also assesses the function of the auditory division of the eighth cranial nerve. The ability to 

understand speech is very important, especially with respect to determining to what degree 

a hearing aid will help a particular patient. Amplifying garbled speech (with a hearing aid) 

has limited benefit for patients with very poor speech discrimination. 

Tympanometry is commonly used to evaluate the tympanic membrane (TM) and 

middle ear status. This test assesses the mobility of the TM and its response to pressure 

changes in the external auditory canal. Three common patterns are shown in Figure 6.2. 
6 

Figure 6.2. Three tympanograms 

demonstrating change in compliance of 

the middle ear (vertical axis) with 

changes in ear canal pressure. Type A is 

normal, with the greatest compliance at 

the point where the pressure in the ear 

canal is equal to that of atmospheric 

pressure (peak is at 0). Type B 

demonstrates very poor compliance at 

any frequency, suggestive of a tympanic 

membrane (TM) immobilized by fluid in 

the middle ear or a TM perforation (no 

peak). Type C represents a tympanogram 

in which the compliance of the 

membrane is greatest at a point where 

the pressure in the canal is 200 mm of 

water below that of atmospheric 

pressure (peak shifted to the left). This 

suggests inefficient eustachian tube 

function with persistent negative 

pressure in the middle ear. 

Type A plots arise when the external auditory canal is patent and the middle ear and 

TM are healthy (maximum TM mobility when pressure in the canal is atmospheric). Type B 

plots occur when the middle ear is filled with fluid or the TM has a perforation (no peak in 

eardrum mobility). The two problems can be differentiated by examining the volume read 

by the impedance bridge. Middle ear fluid will generate normal volumes, while tympanic 

membrane perforations will generate large volumes. Type C plots (peak eardrum mobility 

when pressure is sub-atmospheric) are typical of patients with retracted TMs secondary to 
7 

eustachian tube dysfunction. Tympanometry results can help detect middle ear fluid when 

the physical exam is unclear. 

B. Conductive Hearing Loss 

Careful physical examination of the ear with the aid of a microscope, tuning fork 

testing, and audiometric testing can frequently determine the cause of a conductive hearing 

loss. Most causes of conductive hearing loss can be medically or surgically corrected—they 

can be improved or resolved with treatment and without use of a hearing aid. Swelling of the 

external auditory canal secondary to otitis externa can be treated with appropriate topical 

medication. Cerumen impaction can be cleaned with irrigations, ear drops, or specialized 

instruments. Middle ear fluid, the most common cause of hearing loss in children, can be 

treated with antibiotic therapy or myringotomy tubes, and tympanic membrane 

perforations can be surgically repaired. Cholesteatoma often presents with hearing loss, and 

in the physical examination, it can be confused with cerumen. 

Conductive hearing loss present on the audiogram but not readily apparent on the 

physical exam suggests problems with the ossicular chain. One common disease process 

affecting the ossicular chain is otosclerosis, a hereditary disease process that involves bony 

proliferation within the temporal bone. These bony changes commonly occur at the footplate 

region of the stapes, causing gradual fixation of the ossicular chain. This fixation, in turn, 

decreases the mobility of the stapes footplate and creates a conductive hearing loss. Surgical 

correction— stapedotomy—is available. A stapedotomy procedure re-establishes ossicular 

continuity by removing the fixed stapes ossicle and placing a prosthesis between the incus 

and the vestibule of the inner ear. Sound vibrations can then be transmitted from the 

ossicular chain, through the prostheses and into the inner ear, restoring the patient’s 

hearing. 

C. Sensorineural Hearing Loss 

Sensorineural hearing loss (SNHL) is the most common form of hearing loss. It is 

generally not treatable with surgery, although cochlear implants and other implantable 

audiologic devices may be helpful in cases of profound sensorineural or mixed hearing loss. 

There are many causes of this type of hearing loss, but age-related changes to the cochlea 

causing presbycusis are by far the most frequent cause. As we age, the outer hair cells within 

the cochlea gradually deteriorate, causing a symmetrical SNHL that begins in the high 

frequencies (Figure 6.2). Patients with presbycusis may also complain of tinnitus and have 

difficulty with speech discrimination. 

Another common type of hearing loss is secondary to acoustic trauma or “noise 

exposure.” Noise exposure is common in certain industries and is closely regulated by a 

federal government agency, the Occupational Health and Safety Administration. 

Recreational target shooting, hunting with firearms, use of personal stereos or iPods® or 

other MP3 devices with headphones, loud music exposure, power tools, etc., can cause a 

specific type of hearing loss with a characteristic audiometric pattern. 
8 

Prevention is vital, and counseling should be part of routine health maintenance. 

Treatment consists of hearing education, noise avoidance when possible, and appropriate 

hearing protection with ear plugs or earmuffs when loud noise is present. Patients should 

also have regularly scheduled audiometric follow-up. 

Sudden sensorineural hearing loss is an acute loss of hearing that represents an ENT 

emergency and deserves special management. 

Patients with asymmetric SNHL require a more thorough evaluation to rule out a 

benign tumor of the eighth cranial nerve, known as an acoustic neuroma. Although most 

patients with an asymmetric hearing loss do not have an acoustic neuroma, hearing loss is 

by far the most common presenting complaint in patients with such tumors. In addition, 

these patients will frequently have very poor speech discrimination scores and tinnitus in 

the affected ear. They may also occasionally have disequilibrium complaints, although true 

vertigo is rare. Specialized audiometric testing can be done to assist in the diagnosis of 

acoustic neuromas, but magnetic resonance imaging (MRI) with gadolinium is the diagnostic 

test of choice. Physical exam and testing may elucidate an easily treatable cause of hearing 

loss. However, more serious causes can be present that require careful assessment and 

complex management. To ensure that diagnoses of serious conditions such as cholesteatoma 

or acoustic neuroma are made, patients with hearing loss should be referred to an 

otolaryngologist for evaluation and management of their care. For this reason, many states 

require an evaluation by a physician before a hearing aid can be fitted. 

D. Tinnitus 

Tinnitus is a symptom characterized by the perception of sound in the absence of an 

external stimulus. Jay M. Bhatt, MD et al., Otolaryngology Head and Neck Surgery, JAMA, 

2016 Oct 1, 142 (10). Tinnitus is a common problem for millions of people, as epidemiologic 

studies have reported its prevalence to between 8 and 25.3% of the population of the United 

States. Bhatt 2016. Durations of occupational and leisure time noise exposures correlated 

with rates of tinnitus and are likely targetable risk factors. Bhatt 2016. 

Furthermore, there is an elevated risk of tinnitus in people with a history of head 

injury, depressive symptoms, target shooting, arthritis, use of non-steroidal antiinflammatory drugs (NSAIDs) medications, hypertension, and smoking. Bhatt 2016. 

E. AAO-HNSF – Treatment options for tinnitus 

Treatment options for tinnitus include: 

1. Medications 

2. Hearing Aids 

3. Nutritional Supplementation 

4. Stress Reduction Methods 

5. Music Treatment 

6. Tinnitus Retraining Therapy 
9 

7. Biofeedback Therapy 

8. Wearable Masking Device 

9. Cognitive Behavioral Therapy 

“The majority of respondents in our survey noted symptoms for over 12 months. 

However, independent of symptom duration, most of the respondents with tinnitus believed 

their symptoms to be “not a problem” or “only a small problem.” Similarly, 55.5% of 

respondents in the Blue Mountains Hearing Study reported their symptoms to be “mild.” 

Bhatt 2016. Thus, it is evident that for many patients with chronic tinnitus, the severity of 

symptoms may actually be tolerable and do not require treatment. 

F. Standard Threshold Shifts

1. OSHA STS Twice: in either ear, a change of 10 dB or more in the averaging of 

hearing thresholds at 2000, 3000, and 4000 Hz is present on one annual 

audiogram and is persistent in the same ear on the next audiogram. There are 

current recommendations to increase the threshold change to 15 dB or more 

at any frequency (500, 1000, 2000, 3000, 4000, or 6000 Hz) in either ear that 

is confirmed for the same ear and frequency by a second test within 30 days 

of the first test. This recommendation has been made by National Institute of 

Occupational Safety and Health (NIOSH). 

2. American Academy of Otolaryngology – Head and Neck Surgery (AAO-HNS) 

Shift: in either ear, a change of 10 dB or more in the average of hearing 

thresholds at 500, 1000, and 2000 Hz, or 15 dB or more at 3000, 4000, and 

6000 Hz. 

G. Hyperacusis

Hyperacusis has been defined as “unusual tolerance to ordinary environmental 

sounds” and more pejoratively as “consistently exaggerated or inappropriate responses to 

sounds that are neither threatening nor uncomfortably loud to a typical person.” 

H. Noise Induced Hearing Loss

Noise induced hearing loss can be caused by an acute exposure to an intense impulse 

of sound or by a continuous steady-state long term exposure with sound pressure levels 

higher than 75-85 dB. 

Many weapons emit sounds that exceed the maximum achievable protection that 

double hearing protection can offer. Double hearing protection means both earmuffs and 

ear plugs are used. 

The Army requires personnel to wear hearing protection when exposed to impulse 

noise levels between 140 and 165 dBP. The Army also requires hearing protection for steady 

state noise levels between 85 dBA and 103 dBA. At impulse noise levels above 165 dBP, and 
10 

steady state noise levels above 103 dBA, the Army requires the use of double hearing 

protection. 

I. Ear Blast Injuries

I agree with Mizutan et al when they write “The incidence of blast injuries has 

increased recently, due to the increased use of improvised explosive devices (IEDs) by 

terrorists in civilian situations, and the increased use of explosives by military forces, such 

as in the wars in Afghanistan and Iraq. The most critical and pathognomonic injury is a 

primary blast injury. This is caused by barotrauma, which consists of over-pressurization or 

under-pressurization relative to atmospheric pressure. A blast pressure wave exerts forces 

mainly at air-tissue interfaces within the body, and therefore the auditory system is at high 

risk, “i.e., the cochlear and central auditory pathways, comprise the part of the body most 

commonly damaged by blast overpressure.” 

“The most common outcome of blast exposure is sensorineural hearing loss (SNHL), 

which has a high incidence rate in blast injured patients.” 

III. PLAINTIFF’S HISTORY 

A. Military History 

Ms. Roper was born 1982. She enlisted in the Army in August 2001 and 

ended her service on October 3, 2018. Over this 17-year period she largely served as an 

office administrator and clerk. Depo p 38. She attended basic training at Fort Jackson, South 

Carolina. Depo p. 42. She served at a base in Rome, Georgia from 2001-2004. Depo p. 36. 

She recalls being at Fort Riley, Kansas from 2005 to 2009, and then from 2009 to 2012 at 

Fort Hood, Texas. Depo p. 37. From 2012 to 2014 she was at Fort Benning, after which she 

served at the Redstone Arsenal Unit until 2018. Depo p. 37. She served a twelve month tour 

overseas from 2003 to 2004 in Baghdad, Iraq, where she worked as a postal clerk in the mail 

sorting and distribution facility. 3M_ROPER_S000540; depo p. 35. She has continued serving as 

a civilian clerk with the Department of Veterans Affairs in Atlanta, Georgia. Her right hand is her triggerfiring hand. Depo p. 20. 

B. Noise Exposure History 

Use of Hearing Protection. Plaintiff does not recall when and where she was issued 

the CAEv2 earplugs. Response to Interrogatory No. 3. She states she received written 

instruction related to the CAEv2. Response to Interrogatory No. 4. She states she was given 

verbal instruction and understood that the green end of the CAEv2 functioned “like a 

traditional ear plug” and the yellow end provided protection but “also allowed Plaintiff to 

hear some ambient noise, such as voices of those nearby.” Response to Interrogatory No. 4. 

At her deposition, however, she could not recall training or instruction provided regarding 

the use of the CAEv2 earplugs. Depo p. 62. 
11 

In her interrogatory responses Plaintiff states that she does not recall every instance 

where she wore the CAEv2, and that she believes she wore it in the following circumstances: 

Basic training, gun ranges, training exercises, operating heavy duty 

equipment, flight training, flight line, on board aircraft/military vehicles; 

patrol, during deployment, when instructed by a commanding officer, 

firefights with enemy combatants, etc. 

Response to Interrogatory 5. The reference to firefights with enemy combatants is notable 

given Plaintiff’s testimony that she never had live gunfire engagements with the enemy while 

deployed to Iraq. Depo p. 50. In response to Interrogatory 6, she limits her claims of noise 

exposure to “while at the gun range or during trips in military vehicles.” Other than the July 

2017 audiogram, Ms. Roper’s audiograms do not reflect any documentation as to the use of 

hearing protection. . She does not recall ever being instructed to utilize the CAEv2 earplugs. 

Depo. p. 50. She does not recall what the CAEv2 earplugs look like. Depo p. 53. 

Plaintiff’s deposition reflects that she frequently utilized disposable hearing 

protection when exposed to loud noise. She testified that she did not recall which hearing 

protection she used during basic training in 2001 and did not recall what hearing protection 

she used later in her military career during weapons training. Depo p. 42, 48. In response 

to being questioned whether she used the Combat Arms earplugs she said “yes,” but later 

recalled that the earplugs she used were provided at the gun range, and that after completing 

weapons training sessions at the gun firing range, she would throw away her hearing 

protection. Depo p. 42, 52, 65. The trash can she threw them into was on the site of the 

shooting range. Depo p. 76. These protection devices that she used during weapons training 

came in little bags in a box and “we would just grab the bags that were in the box.” Depo p. 

66. She said when she was given her hearing protection device it was “just a little small 

plastic bag that – it had some writing on it.” Depo p. 64. She used this same type of earplug 

during weapons training throughout her career. Depo p. 71. When asked if she ever used 

foam earplugs that “look like little pills,” she responded, “I believe once or twice before on 

the range.” Depo p. 73. She testified that the “box of earplugs” she would take a bag from 

contained “all the same” type of earplug, and she when asked if that “would have been the 

Combat Arms earplug” she responded “yes.” Depo p. 74. She recalls sometimes the in-ear 

protection she was using would loosen. Depo p. 74. As described these clearly are not the 

CAEv2 earplugs and instead fit the description of hand-formed foam earplugs. She could not 

specifically remember the hearing protection she used when riding in Humvees, but stated 

that after riding in Humvees she would throw away the hearing protection devices that she 

used. Depo p. 58, 67. She answered “yes” to the question whether she could hear fellow 

passengers when in the Humvee using the CAEv2 earplugs, but this response is inconsistent 

with her recollection of using disposable earplugs in the Humvee. Depo p. 72. She wore a 

helmet when in the Humvee which she says was not equipped with a radio. Depo p. 60. She 

could not recall which hearing protection she used when riding in a 2.5 ton truck or C 130 

aircraft. Depo p. 60, 61. At her weapons training sessions post-deployment she used the 

same throw-away type of hearing protection. Depo p. 71. 
12 

Noise Exposure in the Military. Ms. Roper’s noise exposure largely consists of 

weapons training and driving in the Humvee and 2.5 ton truck. Depo p. 49. She operated the 

Humvee at least two to three times per week. Depo p. 58. She drove the 2.5 ton truck once 

or twice. Depo p. 60. She engaged in weapons training throughout her military career, and 

recalls firing her M16 and 9mm at the range twice per year after basic training. Depo p. 48, 

51-52, 70. It is notable that Ms. Roper testifies that she cannot remember what hearing 

protection devices she used when subjected to this noise, and that her most reliable 

description of the hearing protection she utilized reflects that she used hand-formed foam 

ear protection during these noise exposures. 

Ms. Roper denies significant noise exposure in the mail room in Baghdad, saying there 

would sometimes be noise from a forklift. Depo p. 62. 

She recalls one explosion in Baghdad outside of the building she was working in and 

does not recall how far away it was. Depo p. 55. She recalled it being a “loud noise.” Depo p. 

57. She does not remember if she was wearing hearing protection when the explosion took 

place, but typically would not have been wearing hearing protection in that situation. Depo 

p. 57. Following the explosion, she was evacuated to a holding area. Depo p. 58. 

Noise Exposure Outside the Military. Ms. Roper reports engaging in outdoor 

recreational firearms shooting from 2017 to 2018, once or twice a year. Depo p. 31-32. We 

do not know the type of hearing protection used, if any, the type of weapon utilized, or the 

duration of noise exposure. 

IV. PLAINTIFF’S AUDIOLOGY AND MEDICAL HISTORY 

Audiometric data for Ms. Roper reveals that she suffered no permanent threshold 

shifts or hearing loss during her period of military service, which includes any time she 

claims she used the CAEv2 earplugs. 

A. Audiometric Testing 

Pure Tone Thresholds for Roper, Shanika Left Ear 

Date 0.25 

kHz 

0.5 

kHz 

1 kHz 2 kHz 3 kHz 4 kHz 5 kHz 6 kHz 7 kHz 8 kHz 

04/1/2005 - 5 0 0 0 0 - 20 - NT 

09/5/2006 - 25 -5 -5 -5 0 - 25 - NT 

12/3/2009 - 00 00 05 00 10 - 15 - NT 

04/2/2015 - -5 -5 0 -5 5 - 5 - NT 

04/16/2016 - 0 0 0 0 5 - 20 - NT 

04/8/2017 - 15 5 5 0 5 - 20 - NT 

07/7/2017 - 0 0 0 -5 5 - 10 - NT` 

03/15/2022 

(DME) 

15 15 10 10 10 15 - 15 - 20 
13 

Pure Tone Thresholds for Roper, Shanika Right Ear 

Date 0.25 

kHz 

0.5 

kHz 

1 kHz 2 kHz 3 kHz 4 kHz 5 kHz 6 kHz 7 kHz 8 kHz 

04/1/2005 - 5 0 0 0 5 - 20 - NT 

09/5/2006 - 0 -5 -5 -5 -5 - 20 - NT 

12/3/2009 - 00 00 00 00 05 - 10 - NT 

04/2/2015 - -5 -5 -5 -5 0 - 5 - NT 

04/16/2016 - 0 0 0 0 0 - 5 - NT 

04/8/2017 - 20 5 5 5 5 - 10 - NT 

07/7/2017 - 5 -5 0 -5 -5 - 0 - NT 

03/15/2022 

(DME) 

15 10 10 10 10 10 - 10 - 15 

B. Claim of Hearing Loss

Ms. Roper’s pleadings allege she began experiencing bilateral hearing loss and 

tinnitus starting in 2018. That allegation is inconsistent with Ms. Roper’s medical records, 

which make no mention of hearing loss throughout her time in the military and only mention 

tinnitus in the right ear, starting in approximately 2016. Ms. Roper testified in her February 

2022 deposition that she has not experienced hearing loss related to her time in the military. 

Depo p. 123 

C. Tinnitus History

Plaintiff testified that she began experiencing tinnitus in approximately 2014 or 2015, 

describing it as a “weird type of feeling in my – in my ear....it’s like something hurts but it 

itches at the same time, if that makes sense.” Depo p. 91, 92. “It feels like it’s, like, in the inner, 

inside the ear.” Depo p. 91. She added that it was a “pressure feeling.” Medical office visits 

in 2015 and 2017 fail to list tinnitus or hyperacusis as complaints of hers. 

Ms. Roper stated that the tinnitus is triggered by loud noise like the television or music. 

Depo p. 91. She states that her tinnitus is occurring less frequently because she largely avoids 

loud noises or areas where such noises are likely. Depo p. 92. She listens to music. Depo p. 

93. She testified that when this happens it lasts “about a day or so.” Depo p. 96. She testified 

that she experiences ringing in her ears approximately two times per month which “fades 

out over time during the day.” Depo p. 98. She also stated that the last time she felt pressure 

sensations was a couple of months prior to her February 2022 deposition while she was 

sleeping. Depo p. 99. She has experienced this during sleep “maybe once or twice every 

couple of months or so” and it does not wake her up every time. Depo p. 106. These 

sensations have not gotten worse since 2014-2015. Depo p. 101. It does not prevent her 

from falling asleep. Depo p. 101. She was not experiencing tinnitus at her deposition. Depo 

p. 90. She states that her tinnitus has not impacted her day to day life or her ability to work. 

Depo p. 102, 113. It has not caused any mental health issues for her. Depo p. 104. As of 

February 4, 2020, there is no VA disability claims requested or given for tinnitus or 

hyperacusis. 
14 

D. Other Conditions

The plaintiff reports and it is confirmed in reviewed medical records that she has been 

evaluated for and/or diagnosed between August 2015 and the present day with the following 

medical conditions: 

• Anxiety and Dysthymic Disorder as of August 2015 

• Major Depression was diagnosed in March 2017 with complaints of “depressed 

mood, anxiety, chronic sleep impairment, mild memory loss and some 

disturbances of motivation and mood” as of December 21, 2016. 

3M_ROPER_S000538. Plaintiff did not report tinnitus at this visit in March 2017. 

Complaints regarding Ms. Roper’s depression began in 2016. A diagnosis of 

adjustment disorder, anxiety and depression were made on October 17, 2017. She 

currently sees a psychiatrist for anxiety and depression. Depo p. 85. 

• Migraine Disorder – January 1, 2015 to present. 3M_ROPER_S000111. She relates 

that she suffers “frequent” headaches. Response to Interrogatory No. 15. 

Described migraine headaches beginning January 2015, two to three times per 

month lasting two to three hours. She took Excedrin Migraine for this. She 

testified that more recently she does not have them as often but that when she 

does “I’m usually in the bed or in the dark for maybe a day or two.” Depo p. 77. 

She recalled having migraine headaches in the military “maybe like once or twice 

a week.” Depo p. 77. 

• Obstructive Sleep Apnea was diagnosed in 2020 or 2021. Depo p. 107; 

3M_ROPER_S000111. She “occasionally” uses her CPAP machine and thus is not 

always compliant with it. Depo p. 107. She was diagnosed with chronic sleep 

problems per a February 2, 2018 medical evaluation. Inadequately treated 

obstructive sleep apnea results in excessive daytime sleepiness, mood changes, 

and exacerbation of clinically insignificant tinnitus. 

• Temporal Mandibular Joint (TMJ) Syndrome reported to have started around 

12/2016. – In a December 12, 2017 record, she complained of the symptoms of 

the teeth grinding at that visit. TMJ is noted with description of grinding teeth 

associated with anxiety and depression. It has been reported that patients who 

grind their teeth awaken with pressure and aching in their ears, and TMJ 

syndrome is associated with and is a probable causative agent in the complaint of 

aural fullness. 

• PTSD. Depo p. 104. Loud noises trigger PTSD for her. Depo p. 104. However, her 

medical records do not validate her claim of PTSD. 3M_ROPER_S000886 

• Energy drinks – she was ingesting these daily as of 9/28/2015. 
15 

• Ms. Roper has been referred for treatment for a gastrointestinal condition where 

her body does not release waste. Depo p. 85. 

• She was evaluated for atypical chest pain. 

• Serious automobile accident in December 2017 where the car was totaled. No 

information was made available on airbag deployment. Airbag deployment can 

cause or exacerbate existing tinnitus and/or hearing loss. Whiplash injuries are 

also known to cause or exacerbate tinnitus. 

All of the above conditions can exacerbate clinically insignificant tinnitus and some of these 

conditions can directly cause tinnitus. 

Ms. Roper has degenerative arthritis of the spine and lumbosacral/cervical strain. 

She describes this as throbbing back pain, and that her back hurts when sitting, standing, or 

walking for a long time. This pain may be caused by degenerative arthritis of the spine which 

began in 2003 (3M_ROPER_S000521-532; 3M_ROPER_S000111). Ms. Roper has a history of 

NSAID use. 

She was in a car accident in 2017 and experienced neck and low back pain following 

this incident. 3M_ROPER_S005118; Depo p. 28. It is not known if an airbag was deployed. 

She underwent physical therapy for this for about six months. Depo p. 87. 

V. OPINIONS 

A. Ms. Roper’s Claim of Hearing Loss is Not Attributable to Her Use of the CAEv2 

Ms. Roper’s Surveillance Audiometric testing from April 2005 to April 8, 2017 to 

March 15, 2022 inclusive of seven exams does not demonstrate any auditory deficits and 

does not reflect any temporary or permanent auditory threshold shifts. This objective 

audiometric data thus reflects that Ms. Roper does not suffer from any permanent hearing 

loss. Further, it demonstrates that any noise exposure she experienced during her military 

service did not cause any permanent hearing loss or damage. It is therefore my opinion that 

Ms. Roper’s use of the CAEv2 earplugs did not cause or contribute to any hearing loss in this 

case. 

Differential Diagnosis. In assessing Ms. Roper’s claim of hearing loss 

notwithstanding the objective data reflecting no hearing loss, to the extent Ms. Roper claims 

that she does experience hearing loss, I have considered the following factors which 

generally can be implicated in determining the cause of hearing loss in patients: 

• Military Noise Exposure with other HPDs. As described above Ms. Roper has a 

significant degree of noise exposure while using hearing protection devices other 

than the CAEv2. She was able to describe specific details about the hearing 

protection she used, and this description does not match in any way that of the 

CAEv2. Notwithstanding her affirmative responses when asked about use of the 

CAEv2, the balance of her testimony clearly suggests use of hearing protection 
16 

that is not the CAEv2. The use of this other hearing protection and the noise 

exposure during it cannot be excluded as a factor in causing or contributing to any 

hearing damage in this case. 

• Military Noise Exposure with no HPDs and Blast Exposure. It is likely that Ms. 

Roper did not have on hearing protection when the explosion occurred near her 

mail room in Iraq. Without further details as to the distance of the explosion, this 

cannot be excluded as a factor which could cause or contribute to her claimed 

hearing damage. 

• Traumatic Brain Injury. The record is silent as to whether Ms. Roper may have 

suffered a head injury during her motor vehicle accident in 2017. In the absence 

of further information, the possibility of TBI cannot be ruled out as playing a role 

in this case. 

• Conductive Hearing Loss. There is no evidence of hearing loss in this case, 

therefore conductive hearing loss does not play a role in this case. 

• Toxin exposure. There is no record of relevant toxin exposure in this case, but 

without more information, this cannot be excluded as a factor causing or 

contributing to any hearing damage. 

• Age. Ms. Roper is 40 years old. 

• Alcohol and Tobacco. This record does not reflect a relevant history of alcohol or 

smoking. 

• CAEv2 Usage. In light of the foregoing, Ms. Roper’s usage of the CAEv2 earplug can 

be ruled out as causing or contributing to her claim of hearing damage. 

B. Ms. Roper’s Tinnitus Cannot be Attributed to Her CAEv2 Use 

As set out above, the audiometric evidence in this case demonstrates that there was 

no temporary or permanent threshold shift from April 2005 to March 2022. Any symptoms 

of tinnitus experienced by Ms. Roper therefore cannot be attributed to her use of the CAEv2 

earplugs. Further, many of the symptoms Ms. Roper associates with “tinnitus” are not 

typically considered symptoms of tinnitus. The itch and ache she describes in her inner ear 

is not generally considered a symptom of tinnitus. Those symptoms are known to be 

associated with TMJ; a condition Ms. Roper has. This condition and the symptoms she 

describe is also known as a type of “somatic tinnitus.” 

Regarding her symptoms which do fit within the category of tinnitus – the ringing in 

her ear occurring twice per month – this falls within the norm of clinically insignificant 

tinnitus in the general population. 
17 

 With respect to Plaintiff’s expert’s claim of hyperacusis, it is important to note that 

hyperacusis is associated with the conditions of migraines, depression, and post-traumatic 

stress disorder. Plaintiff’s testimony that loud noises trigger a PTSD response is significant 

in this regard. Further, hyperacusis is not a condition typically associated with noise induced 

damage. Loudness recruitment, the symptoms of which plaintiff does not claim, describes 

an experience commonly associated with cochlear hearing loss and specifically with 

dysfunction of the outer hair cells of the organ of corti. With this condition, as sound level 

rises the perceived loudness of it increases faster than normal. The audiometric data in this 

case reflects no hearing loss or damage. The symptoms which Plaintiff or her expert 

attributes to hyperacusis cannot be attributed to her use of the CAEv2 earplugs. 

Differential Diagnosis. In assessing Ms. Roper’s claim of tinnitus, I have considered 

the following factors which generally can be implicated in determining the cause of tinnitus 

in patients: 

• Somatic tinnitus. Ms. Roper suffers from TMJ. The symptomatology she describes 

is entirely consistent with her TMJ. It is more likely than not that her TMJ causes 

and/or contributes to the symptoms she attributes to tinnitus. 

• Military Noise Exposure with other HPDs. As described above Ms. Roper has a 

significant degree of noise exposure while using hearing protection devices other 

than the CAEv2. She was able to describe specific details about the hearing 

protection she used, and this description does not match in any way that of the 

CAEv2. Notwithstanding her affirmative responses when asked about use of the 

CAEv2, the balance of her testimony clearly suggests use of hearing protection 

that is not the CAEv2. The use of this other hearing protection and the noise 

exposure during it cannot be excluded as a factor in causing or contributing to her 

claims of tinnitus in this case. 

• Military Noise Exposure with no HPDs and Blast Exposure. It is likely that Ms. 

Roper did not have on hearing protection when the explosion occurred near her 

mail room in Iraq. Without further details as to the distance of the explosion, this 

cannot be excluded as a factor which could cause or contribute to her claimed 

tinnitus. 

• Traumatic Brain Injury. The record is silent as to whether Ms. Roper may have 

suffered a head injury during her motor vehicle accident in 2017. In the absence 

of further information, the possibility of TBI cannot be ruled out as playing a role 

in her tinnitus. 

• Whiplash. Similarly, whiplash has been associated with tinnitus and changes in 

tinnitus in patients. The injury Ms. Roper suffered in her motor vehicle accident 

cannot be excluded as a factor which could cause or contribute to her tinnitus. 

• Conductive Hearing Loss. The audiometric evidence reflects no hearing loss, so 

conductive hearing loss is not a factor in this case. 
18 

• PTSD. PTSD is a known contributory factor for tinnitus. Ms. Roper’s PTSD cannot 

be excluded as a factor which causes or contributes to her claim of tinnitus. 

• Sleep apnea. Ms. Roper has sleep apnea and is not always compliant with use of 

her CPAP machine. Sleep apnea is a known factor which can cause or contribute 

to tinnitus. It cannot be excluded as a factor in this case which causes or 

contributes to Ms. Roper’s claim of tinnitus. 

• Depression and Anxiety. Ms. Roper has depression and anxiety and seeks 

treatment for her depression. These are both known factors which can cause or 

contribute to tinnitus. They cannot be excluded in this case as factors which could 

cause or contribute to Ms. Roper’s tinnitus. 

• Migraine. Migraine disease is known to cause or contribute to symptoms of 

tinnitus and it cannot be excluded as causing or contributing to Ms. Roper’s claim 

of tinnitus. 

• Toxin exposure. There is no record of relevant toxin exposure in this case, so this 

does not play a role in this case, but without more information, this cannot be 

excluded as a factor causing or contributing to any hearing damage. 

• Medication usage. Ms. Roper has taken Excedrin for her migraine headaches. 

Excedrin contains aspirin which is a known factor that can cause or contribute to 

tinnitus. She has taken NSAIDs which are also implicated in causing or 

contributing to tinnitus. Her use of this medication cannot be excluded as a factor 

which could cause or contribute to her tinnitus. 

• Alcohol and Tobacco. This record does not reflect a relevant history of alcohol or 

smoking. 

• CAEv2 Usage. In light of the foregoing, Ms. Roper’s usage of the CAEv2 earplug can 

be ruled out as causing or contributing to her claim of tinnitus. 

C. Plaintiff’s Expert Report 

I have reviewed Plaintiff’s expert report of Richard Tyler, Ph.D., and I disagree with 

his opinions for the below reasons: 

• Plaintiff’s expert summarily discounts sleep apnea as playing a role in Ms. Roper’s 

claimed hearing damage. I disagree that it can be discounted in this case. To the 

extent Plaintiff’s expert fails to account for other medical conditions of Ms. Roper 

relevant to her hearing damage claims, I disagree with that methodology. 

• Plaintiff’s expert states that Ms. Roper’s medication history played no role in her 

hearing damage claims. I disagree with that statement (see discussion above) 

20 

REFERENCES 

1. Baguley DM. Hyperacusis. J R Soc Med, 2003 Dec; 96(12): 582-585. doi: 

10.1258/jrsm.96.12.582 

2. Bhatt JM, et al. Tinnitus Epidemiology: Prevalence, Severity, Exposures and Treatment 

Patterns in The United States. JAMA Otolaryngol Head Neck Surg. 2016 Oct 1: 142(10): 

959-965. doi: 10.1001/jamaoto.2016.1700 

3. Bhatt JM, et al. Epidemiology of Firearm and Other Noise Exposures in the United States.

Laryngoscope. 2017 October; 127(10): E340-E346. doi: 10.1002/lary.26440 

4. Burry M. How we hear: A step-by-step explanation. https://www.healthyhear ing.com 

/report/53241-How-we-hear-explainer-hearing (2021) 

5. Danielson R. What is Considered a Standard Threshold Shift? AudiologyOnline February 

6, 2006 

6. Dougherty AL, et al. Blast-related ear injuries among U.S. military personnel. JRRD, 

Volume 5, Number 6 (2013) 

7. Folmer RL, et al. Chronic Tinnitus Resulting from Head or Neck Injuries. Laryngoscope, 

113:821-827, 2003 

8. Hasson D, et al. Acute stress induces hyperacusis in women with high levels of emotional 

exhaustion. PLoS One. 2013;8(1):e5294S. doi: 10.1371/journal.pone.0052945. Epub 2013 

Jan 2 

9. Holmes E, et al. ‘Normal’ hearing thresholds and fundamental auditory grouping 

processes predict difficulties with speech-in-noise perception. Scientific Reports (2019) 

9:16771 / https://doi.org/10.1038/s41598-019-53353-5 

10. Jokel C, et al. Noise of military weapons, ground vehicles, planes and ships. The Journal 

of the Acoustical Society of America (2019) 

11. Joseph AR, et al. Impact of Blast Injury on Hearing in a Screened Male Military 

Population. American Journal of Epidemiology, Volume 187, Issue 1, January 2018, Pages 

7-15, https://doi.org/10.1093/aje/kwx199

12. Kujawa SG, et al. Acceleration of Age-Related Hearing Loss by Early Noise Exposure: 

Evidence of a Misspent Youth. J. Neurosci, February 15, 2006, 26(7):2115-2123 

13. Lee SJ, et al. Diagnosis of Tinnitus Due to Auditory Radiation Injury Following Whiplash 

Injury: A Case Study. Diagnostics 2020, 10, 19; doi: 10.3390/diagnostics10010019 

14. Lugo A, et al. Relationship between headaches and tinnitus in a Swedish study. Sci Rep

10, 8494 (2020). https://doi.org/10.1038/s41598-020-65395-1
21 

15. MacGregor AJ, et al. Prevalence of Tinnitus and Association with Self-Rated Health among 

Military Personnel Injured on Combat Deployment. Military Medicine, Volume 185, Issue 

9-10, September-October 2020, Pages e1608-e1614, https:/ /doi.org/10.1093/milmed/ 

usaa103 

16. McBride DI, et al. Audiometric notice as a sign of noise induced hearing loss. Occup 

Environ Med 2001; 58:46-51 

17. McIlwain DS, et al. Heritage of Army Audiology and the Road Ahead: The Army Hearing 

Program. Am J Public Health, 2008;98:2167-2172. doi: 10.2105/AJPH.2007.128504 

18. Meinke DK, et al. Prevention of Noise-Induced Hearing Loss from Recreational Firearms.

Semin Hear; 2017 Nov; 38(4): 267-281 

19. Mezri S, et al. Ear blust injury in military population: A 12 months follow-up. 

Otorhinolaryngol Head Neck Surg 4: DOI: 10.15761/OHNS.1000203 (2019) 

20. Nondahl DM, et al. Notched Audiograms and Noise Exposure History in Older Adults. Ear 

Hear. 2009 December; 30(6): 696-703. doi: 10.1097/AUD.0b013e3181b1d48 

21. Petrescu N. Loud Music Listening. MJM 2008 11(2): 169-176 

22. Stewart M, et al. Hearing Loss and Hearing Handicap in Users of Recreational Firearms.

J Am Acad Audiol 13: 160-168 (2002) 

23. Williams W, et al. Clubbing: The cumulative effect of noise exposure from attendance at 

dance clubs and night clubs on whole-of-life noise exposure. Noise & Health, JulySeptember 2010, 12:48,155-8 

24. Witt B. Bad Assumptions About Hearing Protection. Occupational Health & Safety Sep 

01, 2008 

25. Wooles N, et al. Comparison of distortion product otoacoustic emissions and pure tone 

audiometry in occupational screening for auditory deficit due to noise exposure. The 

Journal of Laryngology & Otology (2015), 129, 1174-1181 

26. Yong JS, et al. Impact of noise on hearing in the military. Military Medical Research 

(2015)2:6. doi: 10.1186/s40779-015-0034-5 

Military

1. Department of the Army, Headquarters, United States Army, Maneuver Support Center of 

Excellence, Fort Leonard Wood, Missouri 65473-5000, FLW Regulation 40-7, Medical 

Services, Army Hearing Program, 27 November 2019 

2. U.S. Army Center for Health Promotion and Preventive Medicine (Hearing Conservation), 

Just the Facts, The Combat Arms Earplug 51-004-0204 
22 

3. U.S. Army Center for Health Promotion and Preventive Medicine (Hearing Conservation

Program), Noise Levels of Common Army Equipment

Publications

1. Noise-Induced Hearing Loss. NIH Publication No. 14-4233, Updated March 2014

2. Occupational Noise Exposure – Workers’ Rights. Occupational Safety and Health

Administration

3. Campbell KCM, et al. Otoacoustic Emissions. Medscape June 18, 2020

4. Music-Induced Hearing Loss: Loud Concerts, Musicians and Hearing Loss Information

for Audiologists. University of Iowa HealthCare, Iowa Head and Neck Protocols, last

modified 01/12/2022

Other

1. Azodo AP, et al. Investigation of Occupational Noise Exposure and Its Physiological Effect

on Landscape Gardeners. Conference Paper May 2018

2. Fracchetti F. Noise Levels in Jazz Clubs. An Investigation into Regulations and Hearing

Risks for Patrons. SAE Institute London, , Student Number: 97507, August 6 2021

3. Groetzinger, K. “Moab and Grand County Pass New Noise Limits to Deal with ATV 

Complaints.” KUER 90.1, Published April 28, 2021 at 8:27 PM MDT

4. Harrison RT. Basic Acoustics for OHV Noise Control. Harrison & Real Sound Training

5. Hill AJ, et al. A Case Study on Sound Level Monitoring and Management at Large-Scale

Music Festivals. Proceedings of the Institute of Acoustics, Vol. 41 Pt. 3 2019

6. Miller RV. 3M Gets Blasted With $110 Million Verdict in 11

th Earplug Bellwether Trial.

Lawsuit Information Center Blog, January 28, 2022, www.lawsuit-information-center.com

7. Miller RV. 3M Earplug Lawsuit Update. Lawsuit Information Center Blog, March 21,

2022, www.lawsuit-information-center.com

8. Settlement Agreement released July 26, 2018 by DOJ, Moldex Whistleblower lawsuit
1 

EXHIBIT A

LIST OF MATERIALS CONSIDERED FOR SHANIKA ROPER

Case Materials

All documents cited in my report that are not cited herein. Each cited document as well 

as any attachments to that document.

Expert Reports

Rule 26 Case-Specific Expert Report of Jennifer LaBorde, Au.D., dated April 14, 2022

Rule 26 Case-Specific Expert Report of James V. Crawford, M.D., dated December 30, 

2021

Rule 26 Case-Specific Expert Report of Gregory A. Flamme, Ph.D. & Mark Stephenson, 

Ph.D., dated June 6, 2021

Deposition Testimony

Shanika Roper Deposition and Exhibits

Production Documents

Document Description MDL Centrality No.

DOEHRS-HC Data

Case Census Form 278143

Verification of Census Form 278098

Verification of Census Form 278100

Plaintiff's Response to Defendants' Requests for Production 1470302

Plaintiff's Response to Defendants' Requests for Production 1461809

Plaintiff's Response to Defendants' Requests for Production 1418044

Plaintiff's Response to Defendants' Requests for 

Interrogatories

1470301

Plaintiff's Response to Defendants' Requests for 

Interrogatories

1445026
2

Document Description MDL Centrality No.

Plaintiff's Response to Defendants' Requests for 

Interrogatories

1418043

Plaintiff's Response to Defendants' Requests for Admissions 1470300

Plaintiff's Initial Disclosures 1439834

Other 35165

Notice of DME 1504123

Notice of DME 1496757

Medical Records 1451548

Form DD 214 1505183

Short Form Complaint 1166231

VA Touhy Response 913006

VA Touhy Response 913005

VA Touhy Response 901799

VA Touhy Response 901798

VA Touhy Response 901797

VA Touhy Response 901796

DOD Touhy Response 1098449

DOD Touhy Response 1098448

CAEv2 Just the facts [3M_MDL000055849-55850]

CAEv2 Photo

Wallet Card [3M_MDL000229332]

DOD Touhy Response 1588189

DME Data 1571181
3

Document Description MDL Centrality No.

Plaintiff’s Expert Disclosures 1647359
EXHIBIT B 
Curriculum Vitae

Alan C. Pollak, MD

__________________________________________________________________

Home: 55 East Erie (unit 4003)

Chicago, IL 60611

Main: 9150 North Crawford Avenue (Suite 206) - Private Practice 1993-Present

Office Skokie, IL 60076

Email: apollak@yahoo.com

Cell Phone: 847/840-8250

SINAI MEDICAL GROUP:

MOUNT SINAI HOSPITAL

Chairman, Department of Surgery 06/2017-Present

President, Sinai Medical Group 06/2017-12/2017

Interim Chairman, Department of Surgery 03/2017-05/2017

Secretary, Mount Sinai Medical Staff Office 03/2017-07/2018

Chief, Division of Otolaryngology/Head and Neck Surgery 2012-Present

UNIVERSITY OF ILLINOIS AT CHICAGO

Clinical Assistant Professor of Surgery 03/2017-Present

FRANCISCAN HAMMOND CLINIC

MUNSTER, IN

Attending Otolaryngologist 2010-2012

EDUCATION:

Undergraduate: Northwestern University, BA Phi Beta Kappa 1979-1983

Research Fellowship – Anatomic Pathology – Lutheran General Hospital 1983-1984

Medical School: Rush Medical College, MD 1984-1988

POST GRADUATE TRAINING:

Internship Northwestern University, McGaw Medical Center

General Surgery 1988-1989

Residency Northwestern University, McGaw Medical Center

General Surgery/Otolaryngology/Head and Neck Surgery 1989-1993

CERTIFICATION: American Board of Otolaryngology/Head and Neck Surgery 1994-Present
Alan C. Pollak, MD

Curriculum Vitae

Page 2

HOSPITAL AFFILIATIONS:

Lutheran General Hospital

Park Ridge, IL 1993-Present

North Shore University

Skokie, IL 1993-Present

Louis Weiss Memorial

Chicago, IL 1998-Present

Illinois Masonic Medical Center

Chicago, IL 2000-Present

St. Joseph’s Hospital

Chicago, IL 2003-Present

St. Mary’s Medical Center

Chicago, IL 2009-Present

Swedish Covenant Hospital

Chicago, IL 2010-Present

St. Bernard Hospital

Chicago, IL 2012-Present

Mount Sinai Hospital

Chicago, IL 2013-Present

St Frances Hospital

Evanston, IL 2001-2016

HOSPITAL ADMINISTRATIVE POSITIONS:

St. Mary’s and St. Elizabeth’s Medical Center

Section Chief, Otolaryngology/Head and Neck Surgery 2013-2015

Louis Weiss Memorial

Director, Head and Neck Surgery 2014-2015

Mount Sinai Hospital

Section Chief, Otolaryngology/Head and Neck Surgery 2012-Present

Mount Sinai Hospital

Interim Chairman of Surgery 03/2017-06/2017

ADDITIONAL ADMINISTRATIVE POSITIONS: 1996-2010

Surgical Advisory Committee

Credentials Committee/Medical Executive Committee

LICENSURE:

State of Illinois Physician and Surgeon 1990-Present

State of Indiana Physician and Surgeon 2011-2012

PUBLICATIONS:

Videolaryngoscopic evaluation of laryngeal intubation injury: Incidence and predictive factors.

Steven F. Ellis, MD, Alan C. Pollak, MD, Otolaryngol Head Neck Surg 1996:114:729-31.