Exhibit A

Case 2:15-md-02641-DGC Document 8392-1 Filed 10/25/17 Page 1 of 5
Do Not Disclose - Subject to Further Confidentiality Review

Golkow Technologies, Inc. Page 1

 1 UNITED STATES DISTRICT COURT

 2 DISTRICT OF ARIZONA

 3 * * * * * * * * * * * * * * *

 4

 In Re Bard IVC Filters Products

 5 Liability Litigation

 6 No. MD-15-02641-PHX-DGC

 7

 8

 * * * * * * * * * * * * * * *

 9

 10 DO NOT DISCLOSE - SUBJECT TO FURTHER

 CONFIDENTIALITY REVIEW

 11

 VIDEOTAPED DEPOSITION OF DAVID HENRY, M.D.

 12

 TAKEN AT: Leib Knott Gaynor

 13 LOCATED AT: 219 North Milwaukee Street

 Milwaukee, WI

 14

 April 6, 2017

 15 10:07 a.m. to 12:28 p.m.

 16 REPORTED BY ANITA K. FOSS

 REGISTERED PROFESSIONAL REPORTER

 17

 18

 19

 * * * * * * * * * * * * * * *

 20

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Case 2:15-md-02641-DGC Document 8392-1 Filed 10/25/17 Page 2 of 5
Do Not Disclose - Subject to Further Confidentiality Review

Golkow Technologies, Inc. Page 72

 1 in addition to the medication?

 2 A. Well, we're not always certain how the

 3 body will react to blood thinning medication. And

 4 if the patient has a pattern of -- of getting

 5 clots, there's concern that one more clot could --

 6 could be devastating. You err on the side of

 7 caution, and you want to make sure that somehow the

 8 patient is protected. And henceforth the notion of

 9 a filter would serve that purpose.

 10 Q. Somewhat of a belt-and-suspenders

 11 approach here with the medicine and the filter?

 12 A. Yes.

 13 Q. Getting to the type of filter and your

 14 discussions with the patient. Did you have any

 15 plan or follow-up that you implemented at the time

 16 you saw Ms. Hyde for her to return so that she

 17 could be evaluated for removal of the filter?

 18 A. Yes. I said to her -- or I may have

 19 said; I don't recall specifically speaking to

 20 her -- but in the patients that I put temporary

 21 filters in, I usually say to them, depending upon

 22 how you do over the interim and many other factors,

 23 that there's the potential that this filter could

 24 be permanent or be temporary.

 25 Q. It could be either?

Case 2:15-md-02641-DGC Document 8392-1 Filed 10/25/17 Page 3 of 5
Do Not Disclose - Subject to Further Confidentiality Review

Golkow Technologies, Inc. Page 89

 1 the FDA?

 2 A. I don't know.

 3 Q. So with respect to how rigorous a process

 4 that is, you don't know what that would be;

 5 correct?

 6 A. Correct.

 7 Q. When you -- when you placed the filter in

 8 Mrs. Hyde, did you yourself have any expectation of

 9 whether that filter would definitely be permanent

 10 or whether it might be retrieved at some point?

 11 A. I would say that the patient's health

 12 care is a dynamic thing, and a patient that's had a

 13 couple of episodes of clots and pulmonary emboli,

 14 that the decision about whether it should stay or

 15 be retrieved, it's hard to speculate whether and

 16 under what circumstances that the filter may no

 17 longer be necessary.

 18 And it's hard to prejudge the

 19 situation, and so I can't speculate. But now that

 20 I understand the record -- and I don't know what's

 21 happened with this patient, but I think it would be

 22 reasonable to get a hematologist or somebody else

 23 stating that it's no longer needed rather than me

 24 try to speculate on whether it was or wasn't.

 25 Q. Is it fair to say then that at the time

Case 2:15-md-02641-DGC Document 8392-1 Filed 10/25/17 Page 4 of 5
Do Not Disclose - Subject to Further Confidentiality Review

Golkow Technologies, Inc. Page 90

 1 that you implanted her filter and selected the G2X,

 2 a retrievable filter, that one of the benefits you

 3 considered in placing the G2X filter was the fact

 4 that it did have the option to be retrieved?

 5 A. Yes. Yes, definitely. When -- when

 6 she's kind of cleared of her risk -- and that's a

 7 difficult decision; I assume that's made up by

 8 other subspecialties -- then it could potentially

 9 be retrieved. But I would probably wait for them

 10 to consult me before I would take it out without

 11 their -- without their opinion or without their

 12 knowing.

 13 Q. Right. And to your point, the decision

 14 to leave the filter or retrieve the filter is a

 15 fairly complex decision -- decision tree, if you

 16 will, that takes into consideration a lot of things

 17 about the patient; correct?

 18 A. It's extremely dynamic, yes. You phrased

 19 that well.

 20 Q. All right. What has your general

 21 experience been with the Bard G2X filter in your

 22 own clinical practice?

 23 MR. SAELTZER: Objection, vague, lacks

 24 foundation.

 25 MR. LEIB: I'm okay with it as long as

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