Exhibit C

Case 2:15-md-02641-DGC Document 8220-3 Filed 10/18/17 Page 1 of 6
Deposition of:

Anne Roberts , M.D.

July 7, 2017

In the Matter of:

In Re: Bard IVC Filters Products

Liability

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Case 2:15-md-02641-DGC Document 8220-3 Filed 10/18/17 Page 2 of 6
Anne Roberts , M.D. July 7, 2017

In Re: Bard IVC Filters Products Liability

1 on which data you're talking about. I mean,

2 Kessler's report is filled with data. And some of

3 it we looked at, and some of it we didn't. So I'm

4 not sure which part of the data that you're

5 referring to.

6 BY MR. BROWN:

7 Q Did you independently verify the

8 methodology that the -- strike that.

9 Did you independently verify the

10 methodology employed by Dr. Ritchie, Dr. Kessler,

11 and Dr. Betensky?

12 MR. JOHNSON: Form.

13 THE WITNESS: I don't know that I

14 independently reviewed their methodology.

15 BY MR. BROWN:

16 Q Did you independently assess the

17 reliability of the underlying data that

18 Dr. Ritchie, Dr. Kessler, and Dr. Betensky relied

19 on?

20 MR. JOHNSON: Form.

21 THE WITNESS: I didn't -- well, again,

22 it probably depends on the data that you're

23 referring to. So I can't tell you what part of

24 the data would, you know -- you know, that we

25 looked at. But I -- and I can't remember what

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Case 2:15-md-02641-DGC Document 8220-3 Filed 10/18/17 Page 3 of 6
Anne Roberts , M.D. July 7, 2017

In Re: Bard IVC Filters Products Liability

1 data was available to us to look at to

2 independent- -- quote, independently review it.

3 BY MR. BROWN:

4 Q Did you assume for purposes of your

5 report that Dr. Ritchie, Dr. Kessler, and

6 Dr. Betensky employed reliable methodologies?

7 MR. LOPEZ: Form.

8 THE WITNESS: Well, I think they are --

9 they all have -- Kessler, in particular, appeared

10 to be reliable. So I assumed that he used

11 reliable methods to look at this. I cannot really

12 comment on the other two.

13 BY MR. BROWN:

14 Q And you assumed for purposes of your

15 report that Dr. Ritchie, Dr. Kessler, and

16 Dr. Betensky utilized reliable underlying data,

17 correct?

18 A I assume so.

19 Q Has any IVC filter manufacturer ever

20 shown you their premarket bench testing data?

21 MR. LOPEZ: Form.

22 THE WITNESS: My recollection is that

23 when we were doing the Bird's Nest filter study

24 that we had bench testing information available on

25 that filter.

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Case 2:15-md-02641-DGC Document 8220-3 Filed 10/18/17 Page 4 of 6
Anne Roberts , M.D. July 7, 2017

In Re: Bard IVC Filters Products Liability

1 A Well, he's the author on this one -- the

2 2011 one. So I suspect that he is involved in the

3 2016 one as well.

4 Q As far as discussing how those

5 guidelines were created -- the 2016 guidelines,

6 would you defer to Dr. Kalva as more knowledgeable

7 about how that came about?

8 A Yes, I would. Because I wasn't on the

9 committee and he is, so I would certainly defer to

10 him.

11 MR. BROWN: We can go off the record.

12 THE VIDEOGRAPHER: This marks the end of

13 Media No. 4 in the deposition of Dr. Anne

14 Christine Roberts, M.D. Going off the record.

15 The time is 5:25 p.m.

16 (Recess taken.)

17 THE VIDEOGRAPHER: This marks the

18 beginning of Media No. 5 in the deposition of

19 Dr. Anne Christine Roberts, M.D. This deposition

20 is being held at 4240 La Jolla Village Drive,

21 San Diego, California 92037.

22 The videographer is Scott Tanaka here on

23 behalf of Veritext Legal Solutions. Today's date

24 is July 7th, 2017. Back on the record. The time

25 is 5:35 p.m.

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Case 2:15-md-02641-DGC Document 8220-3 Filed 10/18/17 Page 5 of 6
Anne Roberts , M.D. July 7, 2017

In Re: Bard IVC Filters Products Liability

1 MR. BROWN: We're not. We have nine

2 minutes.

3 THE VIDEOGRAPHER: We are 6 hours, 53

4 minutes of record.

5 BY MR. BROWN:

6 Q You don't have any written authority

7 that you're relying on to say that the type of

8 information that you're demanding from Bard is

9 needed to satisfy the informed consent standard of

10 care, do you?

11 MR. JOHNSON: Form objection.

12 THE WITNESS: I'm saying that a patient

13 that -- if a company knows that there's a problem

14 with their device or their drugs or whatever it

15 is, that they have a duty to make sure that a

16 practitioner is aware of that; if they're going to

17 continue to sell that device, that they need --

18 the physician needs to know so they can do an

19 adequate informed consent.

20 BY MR. BROWN:

21 Q That's the Dr. Roberts' standard,

22 correct?

23 MR. LOPEZ: Form.

24 THE WITNESS: Well, we'll have to get

25 100 people in a room and find out.

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Case 2:15-md-02641-DGC Document 8220-3 Filed 10/18/17 Page 6 of 6