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UNOPPOSED MOTION TO SUBSTITUTE PARTY PLAINTIFF AND FOR LEAVE 

TO AMEND SHORT FORM COMPLAINT 

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IN THE UNITED STATES DISTRICT COURT 

FOR THE DISTRICT OF ARIZONA 

IN RE BARD IVC FILTERS 

PRODUCTS LIABILITY LITIGATION 

This Document Relates to: 

Bonita Jean Wilde 

Civil Action No.: 2:17-cv-01525-DGC 

No. 2:15-MD-02641 -DGC 

 

UNOPPOSED MOTION TO SUBSTITUTE PARTY PLAINTIFF AND FOR 

LEAVE TO AMEND SHORT FORM COMPLAINT 

Counsel, pursuant to Rule 25 (a)(1) of the Federal Rules of Civil Procedure, moves 

this Court for an Order substituting Blase Brennan on behalf of his mother, Bonita Jean Wilde. 

1. Bonita Wilde filed a products liability lawsuit against Defendants on May 18, 

2017, in the District of Arizona – MDL No. 2:15-MD-02641. 

2. On December 18, 2017, Plaintiff filed and served a Suggestion of Death [Doc 

9403]. 

3. Blase Brennan, surviving son of Bonita Jean Wilde, is the proper party to substitute 

for Plaintiff-decedent Bonita Jean Wilde and has proper capacity forward with the surviving 

products liability lawsuit on his behalf, pursuant to Fed. R. Civ. P. 25(a)(1). “If a party dies 

and the claim is not extinguished, the Court may order substitution of the proper party. A 

motion for substitution may be made by any party of by the decedent’s successor or 

representative.” 

Case 2:15-md-02641-DGC Document 9592 Filed 01/11/18 Page 1 of 3
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4. Blase Brennan further seeks leave to file the attached amended short form 

complaint to substitute himself as Plaintiff on behalf of Plaintiff-decedent Bonita Jean Wilde 

and to add survival action claims (see Amended Short Form Complaint, attached hereto as 

Exhibit 1). 

5. Plaintiff’s counsel has conferred with the Defendant’s counsel and Defendants do 

not oppose the filing of this motion. 

6. Based on the foregoing, Blase Brennan requests that this Court grant his request 

for substitution of Plaintiff in this action and for the leave to file the Amended Short Form 

Complaint. 

Date: January 11, 2018 Respectfully submitted, 

LOPEZ McHUGH LLP

By /s/Matthew R. Lopez 

Ramon Rossi Lopez (CA Bar No. 86361) 

 (admitted pro hac vice) 

Matthew Ramon Lopez (CA Bar No. 263134 

 (admitted pro hac vice) 

100 Bayview Circle, Suite 5600 

Newport Beach, California 92660 

Attorneys for Plaintiff

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UNOPPOSED MOTION TO SUBSTITUTE PARTY PLAINTIFF AND FOR LEAVE TO 

AMEND SHORT FORM COMPLAINT 

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CERTIFICATE OF SERVICE 

I hereby certify that on this 11th day of January, 2018, I electronically transmitted the 

attached document to the Clerk’s Office using the CM/ECF System for filing and transmittal 

of a Notice of Electronic Filing. 

/s/Matthew R. Lopez 

Case 2:15-md-02641-DGC Document 9592 Filed 01/11/18 Page 3 of 3