Exhibit A

Case 2:15-md-02641-DGC Document 8223-1 Filed 10/18/17 Page 1 of 7
Deposition of:

Darren Robert Hurst , M.D.

July 21, 2017

In the Matter of:

In Re: Bard IVC Filters Products

Liability

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Case 2:15-md-02641-DGC Document 8223-1 Filed 10/18/17 Page 2 of 7
Darren Robert Hurst , M.D. July 21, 2017

In Re: Bard IVC Filters Products Liability

1 across the board, 39 percent, 100 percent, and 10

2 percent migration. So, you know, it's that it had

3 all of them, it had all of those issues, not just

4 one, but all of them.

5 BY MR. NORTH:

6 Q. Any other study that you can

7 reference that supports your opinion that Bard

8 filters had a much higher complication rate than

9 other filters, besides the Deso or Deso study?

10 A. Deso study. Well, I mean, there's --

11 well, first of all, the Deso study is a meta

12 analysis, so that is multiple, multiple studies.

13 So to say any other study, we can basically just

14 go to the references for the Deso study, if you

15 would like, and just go through them. It's, you

16 know, a comprehensive list of studies that, you

17 know, describe the data that I just gave. So when

18 you say any other studies, yes, there are

19 multiple, multiple studies of which we can -- you

20 know, we can go through each one, if you would

21 like.

22 Q. Without resorting to looking at the

23 references in Deso, as you sit here today, can you

24 recall any other published study that suggests

25 that Bard filters have a much higher complication

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Case 2:15-md-02641-DGC Document 8223-1 Filed 10/18/17 Page 3 of 7
Darren Robert Hurst , M.D. July 21, 2017

In Re: Bard IVC Filters Products Liability

1 Q. Who were your --

2 A. Mike Kirksey.

3 Q. When is the last time you saw him?

4 A. I haven't seen him in years. He

5 doesn't work for Bard anymore. He works for

6 Endologix, and Endologix makes stent grafts and we

7 don't do stent grafts at our institution.

8 Q. Have you reviewed any of Bard's bench

9 testing of its filters?

10 A. I have seen some of that data, yes.

11 Q. Have you reviewed Bard's 510(k)

12 submissions to the FDA?

13 A. I have not reviewed their 510(k)

14 submissions.

15 Q. Did you review actual test reports of

16 bench data?

17 A. I have seen the tables. So I don't

18 know if it's the actual -- do you mean the whole

19 report?

20 Q. Right.

21 A. No. All I've seen are the data

22 tables.

23 Q. Have you seen any of the FDA

24 correspondence to Bard regarding its IVC filters?

25 A. Yes.

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Case 2:15-md-02641-DGC Document 8223-1 Filed 10/18/17 Page 4 of 7
Darren Robert Hurst , M.D. July 21, 2017

In Re: Bard IVC Filters Products Liability

1 Q. What sorts of correspondence?

2 A. I've seen the -- give me a moment.

3 Q. Are you referencing the warning

4 letter?

5 A. Yes.

6 Q. Other than the warning letter, have

7 you seen any of the Bard --

8 A. No, I have not.

9 Q. -- FDA correspondence?

10 A. I have not.

11 Q. And you haven't seen any of the

12 various submissions that Bard has made to the FDA

13 providing them with various test data and

14 answering questions of the agency?

15 A. I have not.

16 Q. And because you're not a regulatory

17 expert, you're not familiar with what materials of

18 Bard that the FDA may have reviewed?

19 A. Correct.

20 Q. Now, my understanding is you do

21 believe -- given the fact that you implant them

22 still, you do believe that filters are appropriate

23 in certain patients, correct?

24 A. Yes.

25 Q. And you would consider pulmonary

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Case 2:15-md-02641-DGC Document 8223-1 Filed 10/18/17 Page 5 of 7
Darren Robert Hurst , M.D. July 21, 2017

In Re: Bard IVC Filters Products Liability

1 Q. Do you know whether she has seen

2 anyone other than the first physician who

3 attempted to retrieve it, regarding retrieval?

4 A. I do not.

5 Q. You also seem to fault Bard in

6 Ms. Mulkey's case for the fact that her physician

7 implanted an Eclipse in her after the time that

8 the Meridian had already been launched as an

9 available filter, correct?

10 A. Yes.

11 Q. Do you know what her doctor -- the

12 doctor that implanted the filter in her, whether

13 he had ever implanted a Meridian filter?

14 A. I do not know.

15 Q. Do you know whether he was even aware

16 that the Meridian filter existed?

17 A. I don't know that either.

18 Q. Did you ever implant Meridian

19 filters?

20 A. No. We had stopped using Bard

21 filters at that time.

22 Q. Do you know the rates of tilt and

23 caudal migration of the Meridian filter?

24 A. I do not know. I don't know if we

25 know that.

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Case 2:15-md-02641-DGC Document 8223-1 Filed 10/18/17 Page 6 of 7
Darren Robert Hurst , M.D. July 21, 2017

In Re: Bard IVC Filters Products Liability

1 Q. Do you know how they compare with the

2 rate of tilt and migration for the G2 -- I mean,

3 for the Eclipse?

4 A. I don't know.

5 Q. So you have not tried to do a study

6 comparing the complication rates between the

7 Eclipse and the Meridian, have you?

8 A. No, I haven't.

9 Q. You would agree that you are not an

10 expert in device design, development, or

11 manufacture, correct?

12 A. I am not an expert in device design,

13 development, or manufacture; but I do work with

14 medical devices every day and have seen hundreds

15 and hundreds of devices.

16 Q. You indicated that you had not done

17 any analysis of the comparative complication rate

18 between the Eclipse and the Meridian. Have you

19 done a comparative analysis of the complication

20 rates between the G2 and the Eclipse?

21 MR. O'CONNOR: Form.

22 THE WITNESS: There's not much

23 difference between the G2 and the Eclipse except

24 for electropolishing, and I don't know if

25 electropolishing has even been shown to have any

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Case 2:15-md-02641-DGC Document 8223-1 Filed 10/18/17 Page 7 of 7