EXHIBIT C 

Case 2:15-md-02641-DGC Document 9879-4 Filed 01/26/18 Page 1 of 4
Do Not Disclose - Subject to Further Confidentiality Review

Golkow Technologies, Inc. Page 1

 1 IN THE UNITED STATES DISTRICT COURT

 2 FOR THE DISTRICT OF ARIZONA

 3

 4 IN RE: BARD IVC FILTERS )

 5 PRODUCTS LIABILITY LITIGATION, ) MD-15-02641-PHX-DGC

 6 ________________________________)

 7

 8 DO NOT DISCLOSE - SUBJECT TO FURTHER

 9 CONFIDENTIALITY REVIEW

 10

 11 VIDEOTAPED DEPOSITION OF JACK SULLIVAN,

 12 produced, sworn and examined on behalf of the

 13 Plaintiffs, pursuant to Notice, on Friday, the 16th day

 14 of September, 2016, between the hours of 9:08 a.m. and

 15 6:19 p.m. of that day, at the law offices of Wagstaff &

 16 Cartmell, LLP, 4740 Grand Avenue, Suite 300, in the

 17 City of Kansas City, in the County of Jackson, and the

 18 State of Missouri, before me, NAOLA C. VAUGHN, CCR No.

 19 1052, CRR, RPR, a Certified Court Reporter, within and

 20 for the State of Missouri.

 21

 22

 23

 24

 25

Case 2:15-md-02641-DGC Document 9879-4 Filed 01/26/18 Page 2 of 4
Do Not Disclose - Subject to Further Confidentiality Review

Golkow Technologies, Inc. Page 394

 1 EXAMINATION

 2 BY MS. KOWALZYK:

 3 Q. Mr. Sullivan, we've met before. I'm

 4 Brandee Kawalzyk, counsel for Bard and counsel for

 5 you as well.

 6 A. Yes.

 7 Q. And I have a few questions in

 8 follow-up to what you were asked today.

 9 Just in order to give a little bit

 10 more kind of context of who you are and

 11 everything, could you tell us where you grew up?

 12 A. I grew up in Kansas City.

 13 Q. Have you lived in Kansas City all your

 14 life?

 15 A. Yes.

 16 MR. O'CONNOR: Objection. Form.

 17 Q. BY MS. KOWALZYK: And do you have

 18 family here?

 19 A. I do.

 20 Q. Are you married?

 21 A. I am.

 22 Q. Do you have a lot of family here?

 23 A. I have two brothers and a sister. I'm

 24 sorry.

 25 Q. Do you have kids?

20 Q. Are you married?

21 A. I am.

22 Q. Do you have a lot of family here?

23 A. I have two brothers and a sister. I'm

24 sorry.

25 Q. Do you have kids?

Case 2:15-md-02641-DGC Document 9879-4 Filed 01/26/18 Page 3 of 4
Do Not Disclose - Subject to Further Confidentiality Review

Golkow Technologies, Inc. Page 395

 1 A. I do have three kids.

 2 Q. Okay. And --

 3 A. The reason why I paused on the

 4 brothers is I have a brother that passed away. So

 5 I usually say three brothers and a sister, but I

 6 wanted to be accurate here.

 7 MS. KOWALZYK: I'm sorry about that.

 8 THE DEPONENT: That's okay.

 9 MR. O'CONNOR: I am sorry about that.

 10 Q. BY MS. KOWALZYK: How old are your

 11 kids?

 12 A. My oldest son is 21, my middle

 13 daughter is 20, and my youngest is 16. And I've

 14 been married for 24 years.

 15 Q. And are your oldest two in college?

 16 A. Jack is in the Army. He's a sophomore

 17 in the military. Christine is a junior in

 18 college, and Kate is a junior in high school.

 19 Q. Would you describe your role as a

 20 regional manager during your time at BPV?

 21 MR. O'CONNOR: Object to the form of

 22 the question.

 23 A. Sure. So it -- by the time I left, I

 24 was managing one rather large customer, as I

 25 discussed earlier today, but essentially my role

1 A. I do have three kids.

2 Q. Okay. And --

3 A. The reason why I paused on the

4 brothers is I have a brother that passed away. So

5 I usually say three brothers and a sister, but I

6 wanted to be accurate here.

7 MS. KOWALZYK: I'm sorry about that.

8 THE DEPONENT: That's okay.

9 MR. O'CONNOR: I am sorry about that.

10 Q. BY MS. KOWALZYK: How old are your

11 kids?

12 A. My oldest son is 21, my middle

13 daughter is 20, and my youngest is 16. And I've

14 been married for 24 years.

15 Q. And are your oldest two in college?

16 A. Jack is in the Army. He's a sophomore

17 in the military. Christine is a junior in

18 college, and Kate is a junior in high school.

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