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Rossi Lopez - rlopez@lopezmchugh.com 

(California Bar Number 86361; admitted pro hac vice) 

Lopez McHugh LLP 

100 Bayview Circle, Suite 5600 

Newport Beach, California 92660 

949-812-5771 

Mark Stephen O’Connor (011029) – mark.oconnor@gknet.com 

Gallagher & Kennedy, P.A. 

2575 East Camelback Road 

Phoenix, Arizona 85016-9225 

602-530-8000 

Counsel for Plaintiffs 

In Re Bard IVC Filters Products 

Liability Litigation 

No. MD-15-02641-PHX-DGC 

SHERR-UNA BOOKER, an individual, 

Plaintiff, 

v. 

C.R. BARD, INC., a New Jersey 

corporation and BARD PERIPHERAL 

VASCULAR, an Arizona corporation, 

Defendants. 

PLAINTIFF SHERR-UNA 

BOOKER’S NOTICE OF FILING 

ADDITIONAL QUESTIONS TO 

BE CONSIDERED FOR JUROR 

QUESTIONNAIRE

Plaintiff Sherr-Una Booker, through co-lead counsel for Plaintiffs, hereby requests 

the Court to consider the following questions and statements for inclusion in the juror 

questionnaire.1

 Plaintiffs believe that the additional questions will help save time and 

assist the parties in making meaningful strikes: 

 

1

 Before submitting these additional questions to be considered for the jury questionnaire, 

Plaintiffs’ counsel met and conferred with Defendants’ counsel regarding them. 

Defendants object to the use of these additional questions. 

Case 2:15-md-02641-DGC Document 9381 Filed 12/15/17 Page 1 of 5
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1. How closely do you follow federal, state and local politics? (Choose one) 

 Very closely 

 Somewhat closely 

 Not very closely 

 Not at all 

2. What political party do you most closely identify with? 

 Republican  Libertarian 

 Democrat  Independent 

 Tea Party  Other 

3. Do you consider yourself to be: 

 Conservative 

 Moderate 

 Liberal 

4. Have you, your relatives or anyone close to you ever had the opportunity to sue, or 

thought about suing, but chose not to?  YES  NO 

If yes, please explain: ______________________________________________________ 

________________________________________________________________________ 

________________________________________________________________________ 

5. Do you think the media has been unfair to any of the Defendants? 

 YES  NO  DON’T KNOW 

If yes, which one(s) and please explain: 

________________________________________________________________________ 

________________________________________________________________________ 

6. Even though I have read or heard press reports about Defendants or IVC filters, I feel I 

can decide the case on the evidence presented in court and the court’s instruction of law. 

 Strongly Agree  Agree  Disagree  Strongly Disagree 

7. If the court’s jury instructions conflict with my conscience, attitude or belief about what 

the law should be, I would follow my conscience. 

 Strongly Agree  Agree  Disagree  Strongly Disagree 

8. Check the box that best fits your opinion: Lawsuits are costing us all too much money.

 Strongly Agree  Agree  Disagree  Strongly Disagree 

9. Check the box that best fits your opinion: Lawsuits against product manufacturers are 

mostly frivolous. 

 Strongly Agree  Agree  Disagree  Strongly Disagree 

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10. Check the box that best fits your opinion: Whatever the facts, I would have a hard time 

awarding money to a plaintiff suing a medical device company.

 Strongly Agree  Agree  Disagree  Strongly Disagree 

11. Check the box that best fits your opinion: Whatever the facts, I would always find against 

the company that manufactured the medical device.

 Strongly Agree  Agree  Disagree  Strongly Disagree 

12. Check the box that best fits your opinion: In a trial, it would be difficult for me to believe 

the testimony of a plaintiff suing for money damages.

 Strongly Agree  Agree  Disagree  Strongly Disagree 

13. Check the box that best fits your opinion: In a trial, it would be difficult for me to believe 

the testimony of an executive from a large medical device company.

 Strongly Agree  Agree  Disagree  Strongly Disagree 

14. I would sue if a family member was injured by the negligence of another. 

 Strongly Agree  Agree  Disagree  Strongly Disagree 

15. Check the box that best fits your opinion: Sometimes lawyers file lawsuits in an attempt to 

take unfair advantage of wealthy corporations.

 Strongly Agree  Agree  Disagree  Strongly Disagree 

16. Check the box that best fits your opinion: Most American companies are honest and 

ethical.  Strongly Agree  Agree  Disagree  Strongly Disagree 

17. I could never award punitive damages to punish a defendant even if there was evidence 

that justified it.  Strongly Agree  Agree  Disagree  Strongly Disagree 

18. If a person was seriously injured because of the negligence of another, could you award 

compensation to the person for the following: (That is, are you philosophically in favor or 

opposed to awarding compensation to the injured person for the following?) Check one: 

Could Could Not 

Medical expenses  

Lost Income  

Pain and mental anguish  

If you answered, “Could Not” to any of the above, please explain why. 

________________________________________________________________________ 

________________________________________________________________________ 

19. In a civil case, the burden of proof is by a preponderance of the evidence (more probable 

than not), in contrast to a criminal case where the burden of proof is beyond a reasonable 

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doubt. Would you require greater proof than a preponderance of the evidence before you 

could award compensate for pain and mental anguish?  YES  NO 

If yes, please explain: ______________________________________________________ 

________________________________________________________________________ 

________________________________________________________________________ 

20. If you or a family member had suffered serious bodily injury because of a defective 

product, would you sue the manufacturer?  YES  NO 

________________________________________________________________________ 

________________________________________________________________________ 

STATEMENT OF THIS CASE: 

 The plaintiff, Sheri Booker, a 48 year old woman, had a Bard G2 IVC filter placed 

in her inferior vena cava (IVC), the vein that carries blood back to the heart. An IVC filter 

is intended as a preventative measure to catch blood clots before they reach the heart or 

lungs. Defendants Bard, designed, manufactured and sold the G2 filter. Bard intended the 

G2 to remain in the body as a permanent medical device. 

 At some point, after the G2 filter was implanted, it perforated Ms. Booker's inferior 

vena cava and also fractured into pieces. One of the fractured pieces migrated to Sheri 

Booker’s heart requiring her to undergo open heart surgery. The plaintiff claims that the 

Bard G2 filter is defective and unreasonably dangerous and that Bard was negligent in 

designing, marketing and selling the filter and that Bard failed to warn the medical 

community of the known defects in their filter. Plaintiff alleges that Bard is liable for both 

compensatory and punitive damages. 

 Bard denies that their filter was defective, that they failed to warn the medical 

community of known defects in their filter, that they were negligent in designing, 

marketing or selling the IVC filter or that they are responsible for any injuries or damages 

suffered by Sheri Booker. 

RESPECTFULLY SUBMITTED this 15th day of December, 2017. 

GALLAGHER & KENNEDY, P.A. 

By:/s/ Mark S. O’Connor 

Mark S. O’Connor 

2575 East Camelback Road 

Phoenix, Arizona 85016-9225 

LOPEZ McHUGH LLP 

Ramon Rossi Lopez (CA Bar No. 86361) 

(admitted pro hac vice) 

100 Bayview Circle, Suite 5600 

Newport Beach, California 92660 

Counsel for Plaintiffs 

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CERTIFICATE OF SERVICE 

I hereby certify that on this 15th day of December 2017, 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/ Gay Mennuti 

Case 2:15-md-02641-DGC Document 9381 Filed 12/15/17 Page 5 of 5