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James R. Condo (#005867) 

Amanda Sheridan (#005867) 

SNELL & WILMER L.L.P. 

One Arizona Center 

400 E. Van Buren 

Phoenix, AZ 85004-2204 

Telephone: (602) 382-6000 

JCondo@swlaw.com 

ASheridan@swlaw.com 

Richard B. North, Jr. (admitted pro hac vice) 

Georgia Bar No. 545599 

NELSON MULLINS RILEY & SCARBOROUGH, LLP 

Atlantic Station 

201 17th Street, NW, Suite 1700 

Atlanta, GA 30363 

Telephone: (404) 322-6000 

Richard.North@nelsonmullins.com 

Attorneys for Defendants 

C. R. Bard, Inc. and 

Bard Peripheral Vascular, Inc.

IN THE UNITED STATES DISTRICT COURT 

FOR THE DISTRICT OF ARIZONA 

IN RE: Bard IVC Filters Products Liability 

Litigation

MDL NO. 15-02641-PHX-DGC

DEFENDANTS C. R. BARD, INC.’S 

AND BARD PERIPHERAL 

VASCULAR, INC.’S ANSWER AND 

GENERAL DENIAL IN RESPONSE 

TO PLAINTIFF’S AMENDED 

COMPLAINT IN CASE NO. 

CV-17-02770-PHX-DGC; JURY TRIAL 

DEMAND

Defendants C. R. Bard, Inc. (“Bard”) and Bard Peripheral Vascular, Inc. (“BPV”) 

(Bard and BPV are collectively “Defendants”) hereby file this Answer and General Denial in 

response to the Amended Complaint served on Defendants in Nancy Watts, as Special 

Administrator for the Claims of George Watts, Deceased v. C. R. Bard, Inc., et al., AZ 

Member Case No. CV-17-02770-PHX-DGC (“Answer and General Denial”). Defendants 

Case 2:15-md-02641-DGC Document 8553 Filed 11/02/17 Page 1 of 4
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further reserve the right to file any motion to dismiss for failure to state a claim with respect 

to this case, as set forth in Amended Case Management Order No. 4. 

With respect to the allegations plaintiff(s) raise in Nancy Watts, as Special 

Administrator for the Claims of George Watts, Deceased v. C. R. Bard, Inc., et al., AZ 

Member Case No. CV-17-02770-PHX-DGC, Defendants deny, generally and specifically, 

each and every allegation in plaintiff(s)’ Complaint, the whole thereof, and each and every 

cause of action therein. Defendants further deny that the plaintiff(s) has sustained, or is 

entitled to recover, damages in any amount alleged or in any sum whatsoever. Defendants 

further deny that they are liable to the plaintiff in any amount, and further deny that the 

plaintiff has sustained injury, damage, or loss by reason of any act or omission by 

Defendants. 

As for additional defenses, and without assuming any burden of pleading or proof that 

would otherwise rest on plaintiff(s), Defendants incorporate by reference the responses and 

Affirmative Defenses set forth in Defendants’ Answer to Plaintiffs’ Master Complaint filed in 

MDL 2641 on December 17, 2015 (Doc. 366). Defendants further reserve the right to raise 

such other affirmative defenses as may be available or apparent during discovery or as may 

be raised or asserted by other defendants in this case. Defendants have not knowingly or 

intentionally waived any applicable affirmative defense. If it appears that any affirmative 

defense is or may be applicable after Defendants have had the opportunity to conduct 

reasonable discovery in this matter, Defendants will assert such affirmative defense in 

accordance with the Federal Rules of Civil Procedure. 

REQUEST FOR JURY TRIAL 

Defendants C. R. Bard, Inc. and Bard Peripheral Vascular, Inc. demand a trial by jury 

on all issues appropriate for jury determination. 

WHEREFORE, Defendants aver that the plaintiff(s) is/are not entitled to the relief 

demanded in the plaintiff(s)’ Complaint, and these Defendants, having fully answered, pray 

that this action against them be dismissed and that they be awarded their costs in defending 

Case 2:15-md-02641-DGC Document 8553 Filed 11/02/17 Page 2 of 4
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this action and that they be granted such other and further relief as the Court deems just and 

appropriate. 

This 2nd day of November, 2017. 

s/Richard B. North, Jr. 

Richard B. North, Jr. 

Georgia Bar No. 545599 

NELSON MULLINS RILEY & SCARBOROUGH, LLP 

Atlantic Station 

201 17th Street, NW / Suite 1700 

Atlanta, GA 30363 

PH: (404) 322-6000 

FX: (404) 322-6050 

Richard.North@nelsonmullins.com 

James R. Condo (#005867) 

Amanda Sheridan (#027360) 

SNELL & WILMER L.L.P. 

One Arizona Center 

400 E. Van Buren 

Phoenix, AZ 85004-2204 

PH: (602) 382-6000 

JCondo@swlaw.com 

ASheridan@swlaw.com 

Attorneys for Defendants C. R. Bard, Inc. and 

Bard Peripheral Vascular, Inc. 

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CERTIFICATE OF SERVICE 

I HEREBY CERTIFY that on November 2, 2017, I electronically filed the foregoing

with the Clerk of the Court by using the CM/ECF system which will send notification of such 

filing to all counsel of record. 

s/Richard B. North, Jr. 

Richard B. North, Jr. 

Georgia Bar No. 545599 

NELSON MULLINS RILEY & SCARBOROUGH, LLP 

Atlantic Station 

201 17th Street, NW / Suite 1700 

Atlanta, GA 30363 

PH: (404) 322-6000 

FX: (404) 322-6050 

Richard.North@nelsonmullins.com 

Attorney for Defendants C. R. Bard, Inc. and 

Bard Peripheral Vascular, Inc. 

Case 2:15-md-02641-DGC Document 8553 Filed 11/02/17 Page 4 of 4