Exhibit B 

Case 2:15-md-02641-DGC Document 8229-2 Filed 10/18/17 Page 1 of 5
Deposition of:

David Garcia , M.D.

June 21, 2017

In the Matter of:

In Re: Bard IVC Filters Products

Liability

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Case 2:15-md-02641-DGC Document 8229-2 Filed 10/18/17 Page 2 of 5
David Garcia , M.D. June 21, 2017

In Re: Bard IVC Filters Products Liability

1 mean, sometimes we end up lumping things like that

2 together. But we maybe shouldn't always do so.

3 Q. Explain that a little bit further. I'm not

4 sure I'm following what you're saying. You're saying

5 that you should look at those individually?

6 A. Well, I'm saying that in clinical practice,

7 sometimes all we have is evidence about a product that

8 is two or three steps removed from what we're

9 contemplating using. And we may choose to apply that

10 evidence or consider that evidence, but we've got to

11 realize that it's got limitations.

12 And, I mean, to the extent possible in both of

13 these litigations, I'm trying to make my opinions as

14 pertinent to the specific products that are being

15 considered as I can.

16 Q. Okay. 'Cause as I read your report, you're

17 not offering opinions specific about, you know, one

18 manufacturer's filter versus another manufacturer's

19 filter. You're offering general opinions about IVC

20 filters vers -- their use generally versus using them

21 with anticoagulants?

22 MR. JOHNSON: Form.

23 A. So, what I would say is that I -- I do have

24 some opinions that I think are relevant to both

25 litigations, that apply to filters broadly. But I would

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Case 2:15-md-02641-DGC Document 8229-2 Filed 10/18/17 Page 3 of 5
David Garcia , M.D. June 21, 2017

In Re: Bard IVC Filters Products Liability

1 say that there are other material facts and opinions

2 that are specific to --

3 Q. (By Mr. Lerner) Okay.

4 A. -- to products. And I would say that the

5 section of the report that deals with Kessler --

6 Kessler's report is an example of, you know, Bard

7 specific --

8 Q. Okay.

9 A. -- information.

10 Q. That helps me out. So, did you do a similar

11 addendum in -- for that report in Cook litigation, that

12 involved reviewing some materials that are specific to

13 Cook -- any internal documents and regulatory history?

14 A. Yes, there are references in my Cook report to

15 internal documents as -- as well as some specific

16 clinical studies of Cook products --

17 Q. Okay.

18 A. -- that were done, you know, for the purpose

19 of registering Cook products or getting their -- getting

20 their clearance.

21 Q. Understood. But for purposes of the Bard

22 litigation, the entirety of your opinions are included

23 in your report, the addendum -- the Kessler addendum to

24 your report, and then the case specific to Jones?

25 A. Yes.

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Case 2:15-md-02641-DGC Document 8229-2 Filed 10/18/17 Page 4 of 5
David Garcia , M.D. June 21, 2017

In Re: Bard IVC Filters Products Liability

1 Q. Okay. And the general points you make in

2 your -- in this report, I assume there's large portions

3 that's copied and pasted in the Cook report?

4 A. Yeah.

5 MR. JOHNSON: Form.

6 A. I -- I would say that there's a lot of overlap

7 in between the two --

8 Q. (By Mr. Lerner) Okay.

9 A. -- regarding the general opinions about --

10 about risk and benefit, yes.

11 Q. Okay. And do you currently have any plan to

12 do any further work on your reports?

13 A. No.

14 MR. LERNER: Okay. All right. Let's turn to

15 your CV. We'll mark that -- your CV is being marked as

16 Exhibit-5.

17 (Exhibit-5 marked for identification.)

18 MR. JOHNSON: Thanks.

19 Q. (By Mr. Lerner) And just going back to your

20 Cook opinions, are you offering any opinions in that

21 case that Cook filters are safer or less safe than other

22 filters?

23 A. I don't -- I don't think I am, no.

24 Q. Okay. All right. So, this is a CV that you

25 prepared and submitted as part of your report. It's

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Case 2:15-md-02641-DGC Document 8229-2 Filed 10/18/17 Page 5 of 5