EXHIBIT A 

Case 2:15-md-02641-DGC Document 9874-2 Filed 01/26/18 Page 1 of 3
Deposition of:

Anne Roberts , M.D.

July 7, 2017

In the Matter of:

In Re: Bard IVC Filters Products

Liability

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Case 2:15-md-02641-DGC Document 9874-2 Filed 01/26/18 Page 2 of 3
Anne Roberts , M.D. July 7, 2017

In Re: Bard IVC Filters Products Liability

Page 78

1 A Yeah. Not so much now as I was some

2 time ago. I still am on one of their committees,

3 but I haven't been as active in that -- I was much

4 more active earlier.

5 Q And you're also a member of numerous

6 other professional societies in your C.V.; is that

7 right?

8 A Yeah.

9 Q To your knowledge, have any of the

10 societies that we've mentioned -- SIR, American

11 College of Radiology, Western Angiographic and

12 Interventional Society, Radiological Society of

13 North America, American Board of Radiology,

14 American Heart Association -- have any of those

15 organizations ever taken the position that Bard's

16 retrievable IVC filters carry more risks than

17 other IVC filters?

18 MR. JOHNSON: Form.

19 THE WITNESS: If -- you mean as a

20 society statement?

21 BY MR. BROWN:

22 Q Correct.

23 A Not to my knowledge.

24 Q To your knowledge, have any of the other

25 professional societies of which you're a member of

Page 79

1 taken the position that Bard's retrievable IVC

2 filters carry more risks than other IVC filters?

3 MR. JOHNSON: Form objection.

4 THE WITNESS: Again, not to my knowledge

5 have any of them made a societal determination of

6 that.

7 BY MR. BROWN:

8 Q Your C.V. lists 106 articles that you've

9 written in peer-reviewed journals?

10 A You probably read it more recently than

11 I have. Well, a peer-reviewed -- let's see. Wait

12 a minute. I have to go and look for the

13 peer-reviewed -- let's see. 106, yes.

14 Q Your C.V. lists 76 book chapters that

15 you've written?

16 A Again, I haven't counted them recently.

17 But I'm assume you probably have counted them.

18 That's abstract.

19 Q Page 43 of the C.V. that we've marked

20 Exhibit 4 --

21 A 76, looks like.

22 Q So 76 book chapters that you've written?

23 A Yes.

24 Q And your C.V. lists 91 abstracts?

25 A Yes.

Page 80

1 Q And the C.V. that we've marked as

2 Exhibit 4 listed 682 presentations.

3 A Let's see. This one has 682. I think

4 the new one has a few more.

5 Q And your publications and presentations

6 are made to other physicians who are treating

7 patients, correct?

8 A Largely, yeah. I would say most of them

9 go -- are for other physicians. Some of them are

10 ones to other types of groups. But mostly other

11 physicians.

12 Q You've never published or presented to

13 the medical community that Bard's retrievable

14 filters have higher rates of complications than

15 other filters, have you?

16 MR. JOHNSON: Form.

17 THE WITNESS: I would say that I have

18 not published that. I've talked -- I've given

19 presentations early -- relatively early on on the

20 retrievable filters. And -- I mean, I wouldn't

21 know for sure, but I would imagine that I probably

22 -- you know, probably in the early 2000s once

23 there was a problem with the filters, I wouldn't

24 be surprised that I commented that there was a

25 problem with those filters.

Page 81

1 BY MR. BROWN:

2 Q But you can't identify anything for us

3 today, can you?

4 A I -- no. But I would think that it's

5 probably likely.

6 Q Shifting gears a little bit, what is

7 your hourly rate in this litigation?

8 A $750 an hour, I think. And I'm sorry.

9 I don't -- had my secretary given that to me --

10 and it's more for depositions, and it's more if I

11 have to testify. It's in the letter.

12 Q For the work that you've done preparing

13 the report in this case, you charge $750 an hour?

14 A Mm-hmm.

15 Q "Yes"?

16 A Yes. Sorry.

17 Q That's all right.

18 What is your hourly rate to testify at a

19 deposition?

20 A That's what I was looking for. It's

21 basically -- I have a form that, you know, my

22 administrative assistant sends out that outlines

23 all of my charges for -- whether it's doing things

24 -- you know, reviewing material or whether it's

25 doing a deposition or having to testify at a

21 (Pages 78 - 81)

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9 Q To your knowledge, have any of the

10 societies that we've mentioned -- SIR, American

11 College of Radiology, Western Angiographic and

12 Interventional Society, Radiological Society of

13 North America, American Board of Radiology,

14 American Heart Association -- have any of those

15 organizations ever taken the position that Bard's

16 retrievable IVC filters carry more risks than

17 other IVC filters?

18 MR. JOHNSON: Form.

19 THE WITNESS: If -- you mean as a

20 society statement?

21 BY MR. BROWN:

22 Q Correct.

23 A Not to my knowledge.

24 Q To your knowledge, have any of the other

25 professional societies of which you're a member of

1 taken the position that Bard's retrievable IVC

2 filters carry more risks than other IVC filters?

3 MR. JOHNSON: Form objection.

4 THE WITNESS: Again, not to my knowledge

5 have any of them made a societal determination of

6 that.

Case 2:15-md-02641-DGC Document 9874-2 Filed 01/26/18 Page 3 of 3