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To: 15102671546 Page: 04 of 27 2021-06-11 00:48:31 UTC 19493344554 From: Lopez McHugh
FILED BY FAX
ALAMEDA COUNTY
Ramon Rossi Lopez, Bar No. 86361 June 11, 2021
Matthew Ramon Lopez, Bar No. 263134 CLERK OF
Amorina Patrice Lopez, Bar No. 278002 THE SUPERIOR COURT
LOPEZ McHUGH LLP By Nicole Hall, Deputy
100 Bayview Circle, Suite 3600
CASE NUMBER:
Newport Beach, California 92660
Phone: (949) 737-1501 RG21101915
Fax: (949) 737-1504
rlope opezmehugh
com
miones@@ opezmechugh
com
alopezi@lopezmehuah.com
Counsel for Plaintiffs
SUPERIOR COURT OF THE STATE OF CALIFORNIA
FOR THE COUNTY OF ALAMEDA
IN RE CORDIS IVC FILTERS CASES Individual Case No.
JERRY DUNSON, ef al, ICCP No. 4977
Plaintiffs, HON. BRAD SELIGMAN
v. DEPARTMENT 23
CORDIS CORPORATION, et al., Case No. RG16812476 (Lead Case)
(And All Related Cases}
Defendants.
DEANNA BLUE, an individual: IEANNINE
COOPER-IAMES, an mdividual; ALLEN
HITRIZ, an individual: SHALONDA JONES,
an individual; JERRY MARTIN, an SHORT-FORM COMPLAINT FOR
individual; CAROL NEELY, an individual; DAMAGES FOR INDIVIDUAL ACTIONS
ROMAINE PERKINS, an individual;
STEVEN REIGEL, an individual; DEREK
FRUENDT and SUSAN FRUENDT,
individually and as husband and wife; FELIX
SENISAIS, an mndividual, BOBBY
BY Fax
MURPIHTY, an individual, MARLENA
BAUER and LARRY BAUER, individually
and as wife and husband, ANTHONY
EDWARDS and JAZZ EDWARDS,
individually and as husband and wife, LISA
KEATON, an individual; PETER WILSON,
af-
SHORT-FORM COMPLAINT FOR DAMAGES FOR INDIVIDUAL ACTIONS
To: 15102671546 Page: 05 of 27 2021-06-11 00:48:31 UTC 19493344554 From: Lopez McHugh
an individual; ZERANA ROBINSON, an
| individual, STEVEN THOMAS, an
2 individual; LESLIE PHILLIPS, an individual:
3 SANDRA GILLISPIE, an individual;
4 Plaintiffs,
v.
5
. CORDIS CORPORATION, CONFLUENT
& MEDICAL TECHNOLOGIES, INC: and
DOES 1 through 350,
7
8 Defendants.
9
Plaintiff(s) listed in the caption above and further identified below, for their Complaint against
" Defendants CORDIS CORPORATION (“Cordis”), CONFLUENT MEDICAL TECHNOLOGIES, INC.
, (“Confluent”), and DOES | through 50. incorporate the Master Complaint for Damages filed and
° entered on April 9, 2018, in Dunson, et al. v. Cordis Corp., et al., Lead Case No. RG168 1246,
: Plaintiff(s) further show the Court as follows:
15 || Plaintiff(s) [List all Plaintiffs by namel:
16 || DEANNA BLUE, an individual, JEANNINE COOPER-JAMES. an individual, ALLEN HITRIZ. an
individual: SHALONDA JONES. an individual: JERRY MARTIN, an individual, CAROL NEELY, an
individual ROMAINE PERKINS. an individual: STEVEN REIGEL, an individual, DEREK FRUENDT
1g ||and_ SUSAN FRUENDT. individually and as busband and wile: FELIX. SENISAIS. an individual:
BOBBY MURPHY, an individual MARLENA BAUER and LARRY BAUER, individually and as wife
19 |land husband: ANTHONY EDWARDS and JAZ.7, EDWARDS, individually and as husband and wife:
LISA KEATON, an individual: PETER WILSON, an individual; ZERANA ROBINSON, an individual:
STEVEN THOMAS, an individual: LESLIE PHILLIPS. an individual: SANDRA GILLISPIE. ar
31 || Individual.
22 PARTIES AND CASE-SPECIFIC FACTS
23 1. Plaintiff/Deceased Party 1: Deanna Blue
24 a. Plaintiffts) making Loss of Consorttum claim (if amy): N/A
2s b. Other Plamtiffis) and capacity (e.g., surviving spouse or heir, actministrator, executor,
26 guardian, conservator): N/A
7 c. Plaintiffs/Decedent’s state(s) [if more than one Plaintiff] of residence at the time of
28
implant: New Jersey
wide
SHORT-FORM COMPLAINT FOR DAMAGES FOR INDIVIDUAL ACTIONS
To: 15102671546 Page: 06 of 27 2021-06-11 00:48:31 UTC 19493344554 From: Lopez McHugh
d. Plaintiff's/Decedent’s state(s) [if more than one Plaintitf] of residence at the time of injury:
New Jersey
ba
e. Plaintiffs current state(s) [if more than one Plaintiff] of residence: New_lersev
ww
f Defendants (check Defendants against whom Complaint is made):
& Cordis Corporation
J Johnsen & Johnson
*] Confluent Medical Technologies
EX Does f through 50
g. Cordis 1VC Filter(s) (check applicable IVC Filter):
_] Trapease® Vena Cava Filter
h. Date(s) of Implantation(s) for each device:
On or about June 25. 2011
i. The filter subsequently malfunctioned and caused injury, damage, and/or wrongful death
to Plaintiff/Decedent, including,> but not limited to:
Physical and emotional damages from tilt, perforation, and the resultant symptoms. As a direct
and proximate result of these malfunctions, Plainutl! suffered life-threatening iniunes and
damages and required medical care and treatment, As a further proximate result, Plaintiff has
suffered and will continue to suffer sienificant medical expenses. pain, suffering, loss of
enjoyment of life, distress and other damages.
2. Plainuff/Deccased Party 2: Jeannine Cooper-James
a. Plaintiffs) making Loss of Consortium claim (if any): N/A
b. Other Plaintiff(s) and capacity (e.g., surviving spouse or heir, administrator, executor,
guardian, conservator): N/A
Plaintiif’s/Decedent’s state(s) [if more than one Plaintiff] of residence at the time of
o
implant: Michigan
d. Plamtu?’s/Decedent’s state(s) [if more than one Plaintiff] of residence at the time of injurv:
Ju
SHORT-FORM COMPLAINT FOR DAMAGES FOR INDIVIDUAL ACTIONS
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Michigan
e. Plaintiffs current state(s) [if more than one Plaintiff] of residence: Michigan
ba
f Defendants (check Defendants against whom Complaint is made):
ww
& Cordis Corporation
So) Johnson & Johnson
&} Confluent Medical ‘Technologies
&! Does I through 50
g. Cordis IVC Filter(s) (check applicable TVC Filter):
_] Trapease® Vena Cava Filter
oS Optease® Vena Cava Filter
h. Date(s) of Implantation(s) for each device:
On or about May 29, 2009
i. The filter subsequently malfunctioned and caused injury, damage, and/or wrongful deat
to Plaintiff/Decedent, including, but not limited to:
Physical and emotional damages from tilt and perforation of the filter and the resultant
symptoms, As a direct and proximate result of these malfunctions, Plaiatiff suffered life-
threatening injuries and damapes and required medical care and treatment As a further
proximate result, Plaintiff has suffered and will continue to suffer significant medical expenses.
pain, suffering, loss of enjoyment of lite, distress and other damages.
3. Plaintiff/Deceased Party 3: Allen Hitriz
a. Plainuff{s) making Loss of Consortium claim Gf any): N/A
b. Other Plaintiff(s) and capacity (e.g., surviving spouse or heir, administrator, executor,
guardian, conservator): N/A
c. Plaintiifs/Decedent’s state(s) if more than one Plaintiff] of residence at the time of
implant: Georgia
d. Plaintiff's/Decedent’s state(s) [if more than one Plaintiff] of residence at the time of injury:
Georgia
nde
SHORT-FORM COMPLAINT FOR DAMAGES FOR INDIVIDUAL ACTIONS
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l e. Plaintiffs current state(s) [if more than one Plaintiff] of residence: Georgia
2 f. Defendants (check Defendants against whom Complaint is made):
3 & Cordis Corporation
4 ~! Johnson & Johnson
5 & Confluent Medical Technologies
6 2} Does | through 50
7 g. Cordis IVC Filter(s} (check applicable TVC Filter):
8 <] Trapease® Vena Cava Filter
9 & Optease® Vena Cava Filter
10 h. Date(s) of lmplantation(s) for each device:
tl On or about February 7. 2008
12 i. The filter subsequently malfunctioned and caused injury, damage, and/or wrongful death
13 to Plaintift/Decedent, including, but not limited to:
14 Physical and emotional damages from tilt of the filter and the resultant symptoms. As a direct
1s and proximate result of these malfunctions, Plaintiff suffered life-threatening injuries an
16 damages and required medical care and treatment. As a further proximate result, Plainuilf has
7 suffered and will continue to suffer significant medical expenses, pain, sullering, loss of
18 enjoyment of life, distress and other damages,
19
20 4. Plaintiff/Deceased Party 4. Shalonda Jones
21 a. Plaintiff(s) making Loss of Consortium claim Gf any): N/A.
22 b. Other Plaintiff(s) and capacity (¢.g., surviving spouse or heir, administrator, executor,
23 guardian, conservator): N/A.
24 c. Plaintiff’s/Decedent’s state(s) [if more than one Plaintiff] of residence at the time of
25 implant: Indiana
26 d. Plaintiff's/Decedent’s state(s) [if more than one Plaintiff] of residence at the time of injury:
27 Indiana
28 e. Plaintiffs current state(s) [if more than one Plaintiff] of residence: Indiana
we
SHORT-FORM COMPLAINT FOR DAMAGES FOR INDIVIDUAL ACTIONS
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1 f Defendants (check Defendants against whom Complaint is made):
2 & Cordis Corporation
3 CJ Johnson & Johnson
4 & Confluent Medical Technologies
5 & Does | through 50
6 g. Cordis IVC Filter(s) (check applicable IVC Filter):
7 -] Trapease® Vena Cava Filter
8 = Optease® Vena Cava Filter
9 h. Date(s} of lmplantation(s) for each device:
10 On or about December 17, 2012
ll i. The filter subsequently malfunctioned and caused injury, damage, and/or wrongful death
12 to Plaintiff/Decedent, including, but not limited to:
13 Physical and emotional damages from perforation and the resultant symptoms. As a direct an
14 proximate result of these maifunctions, Plaintiff suffered life-threatening injuries and damages
1s and required medical care and treatment. As a further proximate result, Plaintiff has suffered
16 and will continue to suffer significant medical expenses. pain, suffering, loss of enjoyment o
7 life, distress and other damages,
18
19 5. PlaintifffDeceased Party 3: Jerry Martin
20 a. Plaitiff(s) making Loss of Censortium claim Gf any): N/A
21 b. Other Plaintifi(s) and capacity (e.g., surviving spouse or heir, administrator, executor,
22 guardian, conservatory, N/A
23 c. Plaintiff’s/Decedent’s state(s) [if more than one Plaintiff] of residence at the time of
24 implant: Alabama
25 d. Plaintiff's/Decedent’s state(s) [if more than one Plaintiff] of residence at the time of injurv:
26 Alabama
27 e. Plaintiff's current state(s) [if more than one Plaintiff] of residence: Alabama
28 f Defendants (check Defendants against whom Complaint is made):
“He
SHORT-FORM COMPLAINT FOR DAMAGES FOR INDIVIDUAL ACTIONS
To: 15102671546 Page: 10 of 27 2021-06-11 00:48:31 UTC 19493344554 From: Lopez McHugh
1 & Cordis Corporation
2 —| Johnson & Johnson
3 SJ Confluent Medical Technologies
4 & Does | through 50
5 g. Cordis IVC Filter(s) (check applicable IVC Filter):
6 & Trapease® Vena Cava Filter
7 _] Optease® Vena Cava Filter
8 h. Date(s) of Implantation(s) for each device:
9 On. or about January 1.2003
10 i. The filter subsequently malfunctioned and caused injury, damage, and/or wrongful death
ll to Plaintiff/Decedent, including, but not limited to:
12 Physical_and emotional damages from_perforation_and tilt of the filter and the resultant
13 symptoms. As a direct and proximate result of these malfunctions, Plaintiff suffered life
14 threatening injuries aud damages and required medical care and treatment. As a further
1s proximate result, Plaintiff has suffered and will continue to suffer significant medical expenses,
16 pain, suffering, loss of enjoyment of life, distress and other damages.
17
18 6. Plaintiff/Deceased Party 6: Carol Neely
19 a. Plaintifi(s) making Loss of Consortium claim Cif any): N/A
20 b. Other Plaintiff(s) and capacity (e.g., surviving spouse or heir, administrator, executor,
21 guardian, conservator): N/A
22 c. Plaintiffs/Decedent’s state(s) [if more than one Plainuiff] of residence at the time of
23 implant: [lingis
24 d. Plaintiffs/Decedent’s state(s) [if more than one Plaintiff] of residence at the time of injury:
25 Ulinois
26 e. Plaimtffs current state(s) [if more than one Plaintiff] of residence: UU inois
27 f Defendants (check Defendants against whom Complaint is made):
28 = Cordis Corporation
Te
SHORT-FORM COMPLAINT FOR DAMAGES FOR INDIVIDUAL ACTIONS
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1 | Johnson & Johnson
2 &S Confluent Medical Technologies
3 & Does | through 50
4 g. Cordis VC Filter(s) (check applicable VC Filter):
5 o] Trapease® Vena Cava Filter
6 >} Optease® Vena Cava Filter
7 h. Date(s) of Invplantation(s) for each device:
8 On_or about September 5, 2010
9 i. The filter subsequently malfunctioned and caused injury, damage, and/or wrongful death)
10 to Plaintiff/Decedent, including, but not Limited to:
li Physical and emotional damages from perforation and tilt of the filter and the resultant
12 symptoms. As a direct_and proximate result of these malfunctions, Plaintiff suffered life-
13 threatening injuries and damages and required medical care and treatment. As a furihe
14 proximate result, Plaintiff has suffered and will continue to suffer significant medical expenses.
1s pain, suffering, loss of enjoyment of life, distress and other damages.
16
17 7. Plaintifi/Deceased Party 7: Romaine Perkins
18 a. Plaintiff(s) making Loss of Consortium claim (if any): N/A
19 b. Other Plaintiff(s) and capacity (e.g., surviving spouse or heir, administrator, executor,
20 guardian, conservator): N/A
21 c. Plamulls/Decedent’s state(s) [if more than one Plamtill] of residence at the time of
22 implant: New York
23 d. Plaintiff’s/Decedent’s state(s) [if mare than one Plaintiff] of residence at the time of injury:
24 New York
25 e. Plaintiffs current state(s) [if more than one Plaintiff] of residence: New York
26 f Defendants (check Defendants against whom Complaint is made):
27 & Cordis Corporation
28 [] Johnson & Johnson
Re
SHORT-FORM COMPLAINT FOR DAMAGES FOR INDIVIDUAL ACTIONS
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1 & Confluent Medical Technologies
2 & Does | through 50
3 g. Cordis PVC Filter(s) (check applicable TVC Filter):
4 ol] Trapease® Vena Cava Filter
5 X Optease® Vena Cava Filter
6 h. Date(s) of Implantation(s) for each device:
7 On or about June 10, 2008
8 i. The filter subsequently malfunctioned and caused injury, damage, and/or wrongful death
9 to Plaintiff/Decedent, including, but not limited to:
10 Physical and emotional! damages from tit of the filter and the resultant symptoms. As a direct
il and proximate result of these malfunctions, Plaintiff suffered life-threatening injuries and
12 damages and required medical care and treatment, As a further proximate result, Plaintiff has
13 suffered and will continue to suffer sienificant medical expenses. pain. suffering. loss o
14 enjoyment of life. distress and other damages.
1s
16 8 Plaintiff/Deceased Party 8: Steven Reigel
17 a. Plaintiff(s} making Loss of Consortium claim (if any): N/A
18 b. Other Plainiifi(s) and capacity (e.g. surviving spouse or heir, administrator, executor,
19 guardian, conservator): N/A
20 c. Plamtiffs/Decedent’s state(s) [if more than one Plaintiff] of residence at the time of
21 implant: Virgima
22 d. Plamntiff's/Decedent’s state(s) if more than one Plaintiff] of residence at the ime of injury:
23 Virginia
24 e. Plaintiff's current state(s) [if more than one Plaintiff] of residence: Virginia
25 Ff Detendants (check Defendants against whom Complaint is made):
26 & Cordis Corporation
27 -] Johnson & Johnson
28 & Confluent Medical Technologies
oe
SHORT-FORM COMPLAINT FOR DAMAGES FOR INDIVIDUAL ACTIONS
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& Does 1 through 50
Cordis IVC Filter(s) (check applicable 1VC Filter):
ba
(eo
& Trapease® Vena Cava Filter
ww
Ll] Optease® Vena Cava Filter
h. Date(s) of Implantation(s) for each device:
On or about May 22, 2006
i. The filter subsequently malfunctioned and caused injury, damage, and/or wrongful death
to Plaintiff/Decedent, including, but not limited to:
Physical and emotional damages from perforation, migration, uu of the filler, and the resultan
symptoms. As a direct and proximate result of these malfunctions. Plaintiff suffered lifes
threatening injuries and damages and required medical care and treatment. As a further
proximate result, Plaintiff
has suffered and will continue to suffer significant medical expenses,
pain, suffering, loss of eniovment of life, distress and other damages,
9. Plaintiff/Deceased Party 9: Derek Fruendt
a. Plaintiffis) making Loss of Consortium claim (if any): Susan Fruendt
b. Other Plaintifi(s) and capacity (e.g., surviving spouse or heir, administrator, executor,
guardian, conservator): N/A
c. Plaintiff?'s/Decedent’s state(s) [if more than one Plaintiff] of residence at the time off
implant: New York
d. Plaintiff’s/Decedent’s state(s) [if more than one Plainull] of residence at the ime of injury:
New York
Plaintiff’s current state(s) [if more than one Plaintiff] of residence: New York
8
& Defendants (check Defendants against whom Complaint is made):
& Cordis Corporation
_| Johnson & Johnson
24 Confluent Medical ‘Technologies
1 Does 1 through 50
~f0-
SHORT-FORM COMPLAINT FOR DAMAGES FOR INDIVIDUAL ACTIONS
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l g. Cordis IVC Filter(s) (check applicable IVC Filter):
2 & Trapease® Vena Cava Filter
3 ©] Optease® Vena Cava Filter
4 h. Date(s) of Implantation(s) for each device:
5 On or about Apnol 20, 2010
6 i. The filter subsequently malfunctioned and caused injury, damage, and/or wrongful death
7 to Plaintiff/Decedent, including, but not limited to:
8 Physical and emotional damages from perforation and tilt of the Alter and the resultan
9 symptoms, As a direct and proximate result of these malfunctions. Plaintiff suffered, life-
10 threatening injuries and damages and required medical care and treatment. As a further
il proximate result, Plaintiff has suffered and will continue to suffer significant medical expenses.
12 pain, suffering, loss of enjoyment of life, distress and other damages.
13
14 10. Plaintiff/Deceased Party 10: Felix Senisais
is a. Plaintiff(s) making Loss of Consortium claim Cf any): N/A
16 b. Other Plamtiff(s) and capacity (¢.g., surviving spouse or heir, administrator, executor,
17 guardian, conservator): N/A
18 c. PlamuifsDecedent’s state(s) [if more than one Plaintiff] of residence at the time o
19 implant: [ineis
20 d. Plamtiffs/Decedent’s state(s) [if more than one Plaintiff] of residence at the time of injurv:
21 Ulinois
22 e, Plaintiff's current state(s) [if more than one Plainuff] of residence: Ilinois
23 f Defendants (check Defendants against whom Complaint is made):
24 X Cordis Corporation
25 —| Johnson & Johnson
26 & Confluent Medical Technologies
27 2} Does | through 50
28 g. Cordis IVC Filter(s) (check applicable PVC Filter):
~f1-
SHORT-FORM COMPLAINT FOR DAMAGES FOR INDIVIDUAL ACTIONS
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1 co] Trapease® Vena Cava Filter
2 & Optease® Vena Cava Filter
3 h. Date(s} of Implantation(s) for each device:
4 On_or about April 27, 2014
5 i. The filter subsequently malfunctioned and caused injury, damage, and/or wrongful death
6 to Plaintiff/Decedent, including, but not limited to:
7 Physical and emotional damages from perforation and tilt of the filter and the resultan
8 symptoms. As a direct and proximate result of these malfunctions, Plaintiif suffered life-
9 threatening injuries and damages and required medical care and treaument..As a further
10 proximate result, Plaintiff has suffered and will continue to suffer significant medical expenses,
li pain, suffering, loss of enjoyment of life, distress and other damages.
12
13 11. Plaintiff/Deceased Party 11: Bobby Murphy
14 a. Plaintiff(s) making Loss of Consortium claim (if any): N/A.
is b. Other Plaintiff(s) and capacity (e.g., surviving spouse or heir, administrator, executor,
16 guardian, conservator): N/A
7 c. Plaintiff’s/Decedent’s state(s) [if more than one Plaintiff] of residence at the time of
18 implant: Virginia
19 d. Plaintiff's/Decedent’s state(s) [if more than one Plaintiff] of residence at the time of injury:
20 Virginia
21 e. Plarmtiffs current state(s) if more than one Plaintill] of residence: Virginia.
22 f Defendants (check Defendants against whom Complaint is made):
23 2 Cordis Corporation
24 o] Johnson & Johnson
25 & Confluent Medical Technologies
26 &! Does | through 50
27 g. Cordis IVC Filter(s) (check applicable IVC Filter):
28 “] Trapease® Vena Cava Filter
~f2-
SHORT-FORM COMPLAINT FOR DAMAGES FOR INDIVIDUAL ACTIONS
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i X} Optease® Vena Cava Milter
2 h. Date(s) of Implantation(s) for each device:
3 On or about April 27, 2014
4 i. The filter subsequently malfunctioned and caused injury, damage, and/or wrongful death
5 to Plaintiff/Decedent, including, but not limited to:
6 Physical and emotional damages from perforation and tilt of the filter and the resultant
7 symptoms. As a direct and proximate result of these malfunctions, Plaintiff suffered life-
8 threatening injuries and damages and required medical care and treatment As a furthe
9
10 pain. suffering, loss of enjoyment of life, distress and other damages.
ll
12 12. Plaintiff/Deceased Party 12: Marlena Bauer
13 a. Plamuff(s) making Loss of Consortium claim (if any): Larry Bauer
14 b. Other Plaintiff(s) and capacity (e.g., surviving spouse or heir, administrator, executor,
is guardian, conservator): N/A
16 c¢. Plaintii’s/Decedent’s state(s) [if more than one Plamtiff] of residence at the time of
17 implant: Colorado
is d. Plaintiif’s/Decedent’s state(s) fif more than one Plaintiff] of residence at the time of injury:
19 Colorado
20 e. Plaintiffs current state(s) [if more than one Plaintiff] of residence: Colorado
21 f Defendants (check Defendants against whom Complaint is made):
22 X! Cordis Corporation
23 —] Johnson & Johnson
24 X Confluent Medical Technologies
25 X Does | through 50
26 g. Cordis [VC Filter(s) (check applicable IVC Filter):
27 _] Trapease® Vena Cava Filter
28 = Optease® Vena Cava Filter
~[3-
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1 h. Date(s) of Implantation(s) for each device:
2 On of about 2005
3 i, The filter subsequently malfunctioned and caused injury, damage, and/or wrongful death
4 to Plaintiff/Decedent, including, but not limited to:
5 Physical and emotional damages from tilt of the filter and the resultant symptoms. As a direct
6 and proximate result of these malfunctions, Plaintiff suffered life-threatening injuries and
7 damages and required medical care and treatment, As a further proximate result, Plaintiff has
8 suffered and will continue to suffer significant medical expenses. pain, suffering, loss of
9 enjoyment of life, distress and other damages.
10
ll 13. Plaintiff/Deceased Party 13: Anthony Edwards
12 a. Plaintiff(s) making Loss of Cansortiurn claim (if any): Jazz Edwards
13 b. Other Plaintiff(s) and capacity (e.g., surviving spouse or heir, administrator, executor,
14 guardian, conservator): N/A
is ec. Plaintiff's/Decedent’s state(s) [if more than one Plaintiff] of residence at the time o
16 implant: Ulinois
17 d. Plaintiff’'s/Decedent’s state(s) [if more than one Plaintiff] of residence at the time of injurv:
is Ilingis
19 e. Plaintiffs current state(s) [if more than one Plaintiff] of residence: Illinois
20 f Defendants (check Defendants against whom Complaint is made):
21 &! Cordis Corporation
22 J Johnson & Johnson
23 & Confluent Medical Technologies
24 XS Does 1 through 50
25 g. Cordis IVC Filter(s) (check applicable TVC Filter):
26 wd Trapease® Vena Cava Filter
27 &] Optease® Vena Cava Filter
28 h. Date(s) of Invplantation(s) for each device:
“14.
SHORT-FORM COMPLAINT FOR DAMAGES FOR INDIVIDUAL ACTIONS
To: 15102671546 Page: 18 of 27 2021-06-11 00:48:31 UTC From: Lopez McHugh
On or about July 25, 2013
i. The filter subsequently malfunctioned and caused injury, damage, and/or wrongful death
ba
to Plaintiff/Decedent, including, but not limited ta:
ww
Physical and emotional damages from perforation and tilt of the filter and the resultant
syroptoms. As a direct and proximate result of these malfunctions, Plaintiff suffered life.
threatening iniuries and damaees and required medical care and treatment, As a. further
proximate result, Plaintiff has suffered and will continue to suffer significant medical expenses,
pain, suffering, loss of enjoyment of life, distress and other damages.
14. Plaintiff/Deceased Party 14: Lisa Keaton
a. Plaintiff(s) making Loss of Consortium claim (Gif any): N/A.
b. Other Plaintiff(s) and capacity (e.g., surviving spouse or heir, administrator, executor,
guardian, conservator): N/A
c. Plaintiff's/Decedent’s state(s) [if more than one Plaintiff] of residence at the time o
implant: Michigan
d. Plamtu’s/Decedent’s state(s) [if more than one Plaintiff) of residence at the time of injury:
Michigan
e. Plaintiffs current state(s) [if more than one Plaintiff] of residence: Michigan
f. Defendants (check Defendants against whom Complaint is made):
| Cordis Corporation
=) Johnson & Johnson
es Confluent Medical Technologies
&} Does | through 59
g. Cordis IVC Filter(s) (check applicable [VC Filter):
XM Trapease® Vena Cava Filter
L] Optease® Vena Cava Filter
h. Date(s) of Implantation(s) for each device:
On or about June 25, 2012
~f5-
SHORT-FORM COMPLAINT FOR DAMAGES FOR INDIVIDUAL ACTIONS
To: 15102671546 Page: 19 of 27 2021-06-11 00:48:31 UTC 19493344554 From: Lopez McHugh
1 i. The filter subsequently malfunctioned and caused injury, damage, and/or wrongful death
2 to Plaintiff/Decedent, including, but not limited to:
3 Physical and emotional damages from_perforation and tilt of the filter and the resultan
4 symptoms. As a direct and proximate result of these malfunctions, Plaintiff suffered lifes
5 threatening injuries and damages and required medical care and treatment As a further
6 proximate result, Plaintiff has suffered and will continue to suffer significant medical expenses,
7 pain, suffering, loss of enjoyment of life, distress and other damages.
8
9 15. Plaintiff/Deceased Party 15: Peter Wilson
10 a. Plaintiff(s) making Loss of Consortium claim (if any): N/A
ll b. Other Plaintiff(s) and capacity fe.g., surviving spouse or heir, administrator, executor,
12 guardian, conservator): N/A
i3 c. Plamtif’s/Decedent’s state(s) [if more than one Plaintiff] of residence at the time o
14 implant: New Jersey
is d. Plaintiff’s/Decedent’s state(s) [if more than one Plaintiff] of residence at the time of injury:
16 New Jersey
17 e. Plarntiff’s current state(s) Gf more than one Plaintiff] of residence: New Jersey
18 f. Defendants (check Defendants against whom Complaint is made):
19 & Cordis Corporation
20 ©] Johnson & Johnson
21 | Confluent Medical Technologies
22 &! Does | through 50
23 g. Cordis IVC Filter(s) (check applicable IVC Filter):
24 _] Trapease® Vena Cava Filter
25 x Optease® Vena Cava Filter
26 h. Date(s) of Implantation(s) for each device:
27 On or about June 2010
28 i. The filter subsequently malfunctioned and caused injury, damage, and/or wrongful death
-f6-
SHORT-FORM COMPLAINT FOR DAMAGES FOR INDIVIDUAL ACTIONS
To: 15102671546 Page: 20 of 27
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To: 15102671546 Page: 04 of 27 2021-06-11 00:48:31 UTC 19493344554 From: Lopez McHugh FILED BY FAX ALAMEDA COUNTY Ramon Rossi Lopez, Bar No. 86361 June 11, 2021 Matthew Ramon Lopez, Bar No. 263134 CLERK OF Amorina Patrice Lopez, Bar No. 278002 THE SUPERIOR COURT LOPEZ McHUGH LLP By Nicole Hall, Deputy 100 Bayview Circle, Suite 3600 CASE NUMBER: Newport Beach, California 92660 Phone: (949) 737-1501 RG21101915 Fax: (949) 737-1504 rlope opezmehugh com miones@@ opezmechugh com alopezi@lopezmehuah.com Counsel for Plaintiffs SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF ALAMEDA IN RE CORDIS IVC FILTERS CASES Individual Case No. JERRY DUNSON, ef al, ICCP No. 4977 Plaintiffs, HON. BRAD SELIGMAN v. DEPARTMENT 23 CORDIS CORPORATION, et al., Case No. RG16812476 (Lead Case) (And All Related Cases} Defendants. DEANNA BLUE, an individual: IEANNINE COOPER-IAMES, an mdividual; ALLEN HITRIZ, an individual: SHALONDA JONES, an individual; JERRY MARTIN, an SHORT-FORM COMPLAINT FOR individual; CAROL NEELY, an individual; DAMAGES FOR INDIVIDUAL ACTIONS ROMAINE PERKINS, an individual; STEVEN REIGEL, an individual; DEREK FRUENDT and SUSAN FRUENDT, individually and as husband and wife; FELIX SENISAIS, an mndividual, BOBBY BY Fax MURPIHTY, an individual, MARLENA BAUER and LARRY BAUER, individually and as wife and husband, ANTHONY EDWARDS and JAZZ EDWARDS, individually and as husband and wife, LISA KEATON, an individual; PETER WILSON, af- SHORT-FORM COMPLAINT FOR DAMAGES FOR INDIVIDUAL ACTIONS To: 15102671546 Page: 05 of 27 2021-06-11 00:48:31 UTC 19493344554 From: Lopez McHugh an individual; ZERANA ROBINSON, an | individual, STEVEN THOMAS, an 2 individual; LESLIE PHILLIPS, an individual: 3 SANDRA GILLISPIE, an individual; 4 Plaintiffs, v. 5 . CORDIS CORPORATION, CONFLUENT & MEDICAL TECHNOLOGIES, INC: and DOES 1 through 350, 7 8 Defendants. 9 Plaintiff(s) listed in the caption above and further identified below, for their Complaint against " Defendants CORDIS CORPORATION (“Cordis”), CONFLUENT MEDICAL TECHNOLOGIES, INC. , (“Confluent”), and DOES | through 50. incorporate the Master Complaint for Damages filed and ° entered on April 9, 2018, in Dunson, et al. v. Cordis Corp., et al., Lead Case No. RG168 1246, : Plaintiff(s) further show the Court as follows: 15 || Plaintiff(s) [List all Plaintiffs by namel: 16 || DEANNA BLUE, an individual, JEANNINE COOPER-JAMES. an individual, ALLEN HITRIZ. an individual: SHALONDA JONES. an individual: JERRY MARTIN, an individual, CAROL NEELY, an individual ROMAINE PERKINS. an individual: STEVEN REIGEL, an individual, DEREK FRUENDT 1g ||and_ SUSAN FRUENDT. individually and as busband and wile: FELIX. SENISAIS. an individual: BOBBY MURPHY, an individual MARLENA BAUER and LARRY BAUER, individually and as wife 19 |land husband: ANTHONY EDWARDS and JAZ.7, EDWARDS, individually and as husband and wife: LISA KEATON, an individual: PETER WILSON, an individual; ZERANA ROBINSON, an individual: STEVEN THOMAS, an individual: LESLIE PHILLIPS. an individual: SANDRA GILLISPIE. ar 31 || Individual. 22 PARTIES AND CASE-SPECIFIC FACTS 23 1. Plaintiff/Deceased Party 1: Deanna Blue 24 a. Plaintiffts) making Loss of Consorttum claim (if amy): N/A 2s b. Other Plamtiffis) and capacity (e.g., surviving spouse or heir, actministrator, executor, 26 guardian, conservator): N/A 7 c. Plaintiffs/Decedent’s state(s) [if more than one Plaintiff] of residence at the time of 28 implant: New Jersey wide SHORT-FORM COMPLAINT FOR DAMAGES FOR INDIVIDUAL ACTIONS To: 15102671546 Page: 06 of 27 2021-06-11 00:48:31 UTC 19493344554 From: Lopez McHugh d. Plaintiff's/Decedent’s state(s) [if more than one Plaintitf] of residence at the time of injury: New Jersey ba e. Plaintiffs current state(s) [if more than one Plaintiff] of residence: New_lersev ww f Defendants (check Defendants against whom Complaint is made): & Cordis Corporation J Johnsen & Johnson *] Confluent Medical Technologies EX Does f through 50 g. Cordis 1VC Filter(s) (check applicable IVC Filter): _] Trapease® Vena Cava Filter h. Date(s) of Implantation(s) for each device: On or about June 25. 2011 i. The filter subsequently malfunctioned and caused injury, damage, and/or wrongful death to Plaintiff/Decedent, including,> but not limited to: Physical and emotional damages from tilt, perforation, and the resultant symptoms. As a direct and proximate result of these malfunctions, Plainutl! suffered life-threatening iniunes and damages and required medical care and treatment, As a further proximate result, Plaintiff has suffered and will continue to suffer sienificant medical expenses. pain, suffering, loss of enjoyment of life, distress and other damages. 2. Plainuff/Deccased Party 2: Jeannine Cooper-James a. Plaintiffs) making Loss of Consortium claim (if any): N/A b. Other Plaintiff(s) and capacity (e.g., surviving spouse or heir, administrator, executor, guardian, conservator): N/A Plaintiif’s/Decedent’s state(s) [if more than one Plaintiff] of residence at the time of o implant: Michigan d. Plamtu?’s/Decedent’s state(s) [if more than one Plaintiff] of residence at the time of injurv: Ju SHORT-FORM COMPLAINT FOR DAMAGES FOR INDIVIDUAL ACTIONS To: 15102671546 Page: 07 of 27 2021-06-11 00:48:31 UTC 19493344554 From: Lopez McHugh Michigan e. Plaintiffs current state(s) [if more than one Plaintiff] of residence: Michigan ba f Defendants (check Defendants against whom Complaint is made): ww & Cordis Corporation So) Johnson & Johnson &} Confluent Medical ‘Technologies &! Does I through 50 g. Cordis IVC Filter(s) (check applicable TVC Filter): _] Trapease® Vena Cava Filter oS Optease® Vena Cava Filter h. Date(s) of Implantation(s) for each device: On or about May 29, 2009 i. The filter subsequently malfunctioned and caused injury, damage, and/or wrongful deat to Plaintiff/Decedent, including, but not limited to: Physical and emotional damages from tilt and perforation of the filter and the resultant symptoms, As a direct and proximate result of these malfunctions, Plaiatiff suffered life- threatening injuries and damapes and required medical care and treatment As a further proximate result, Plaintiff has suffered and will continue to suffer significant medical expenses. pain, suffering, loss of enjoyment of lite, distress and other damages. 3. Plaintiff/Deceased Party 3: Allen Hitriz a. Plainuff{s) making Loss of Consortium claim Gf any): N/A b. Other Plaintiff(s) and capacity (e.g., surviving spouse or heir, administrator, executor, guardian, conservator): N/A c. Plaintiifs/Decedent’s state(s) if more than one Plaintiff] of residence at the time of implant: Georgia d. Plaintiff's/Decedent’s state(s) [if more than one Plaintiff] of residence at the time of injury: Georgia nde SHORT-FORM COMPLAINT FOR DAMAGES FOR INDIVIDUAL ACTIONS To: 15102671546 Page: 08 of 27 2021-06-11 00:48:31 UTC 19493344554 From: Lopez McHugh l e. Plaintiffs current state(s) [if more than one Plaintiff] of residence: Georgia 2 f. Defendants (check Defendants against whom Complaint is made): 3 & Cordis Corporation 4 ~! Johnson & Johnson 5 & Confluent Medical Technologies 6 2} Does | through 50 7 g. Cordis IVC Filter(s} (check applicable TVC Filter): 8 <] Trapease® Vena Cava Filter 9 & Optease® Vena Cava Filter 10 h. Date(s) of lmplantation(s) for each device: tl On or about February 7. 2008 12 i. The filter subsequently malfunctioned and caused injury, damage, and/or wrongful death 13 to Plaintift/Decedent, including, but not limited to: 14 Physical and emotional damages from tilt of the filter and the resultant symptoms. As a direct 1s and proximate result of these malfunctions, Plaintiff suffered life-threatening injuries an 16 damages and required medical care and treatment. As a further proximate result, Plainuilf has 7 suffered and will continue to suffer significant medical expenses, pain, sullering, loss of 18 enjoyment of life, distress and other damages, 19 20 4. Plaintiff/Deceased Party 4. Shalonda Jones 21 a. Plaintiff(s) making Loss of Consortium claim Gf any): N/A. 22 b. Other Plaintiff(s) and capacity (¢.g., surviving spouse or heir, administrator, executor, 23 guardian, conservator): N/A. 24 c. Plaintiff’s/Decedent’s state(s) [if more than one Plaintiff] of residence at the time of 25 implant: Indiana 26 d. Plaintiff's/Decedent’s state(s) [if more than one Plaintiff] of residence at the time of injury: 27 Indiana 28 e. Plaintiffs current state(s) [if more than one Plaintiff] of residence: Indiana we SHORT-FORM COMPLAINT FOR DAMAGES FOR INDIVIDUAL ACTIONS To: 15102671546 Page: 09 of 27 2021-06-11 00:48:31 UTC 19493344554 From: Lopez McHugh 1 f Defendants (check Defendants against whom Complaint is made): 2 & Cordis Corporation 3 CJ Johnson & Johnson 4 & Confluent Medical Technologies 5 & Does | through 50 6 g. Cordis IVC Filter(s) (check applicable IVC Filter): 7 -] Trapease® Vena Cava Filter 8 = Optease® Vena Cava Filter 9 h. Date(s} of lmplantation(s) for each device: 10 On or about December 17, 2012 ll i. The filter subsequently malfunctioned and caused injury, damage, and/or wrongful death 12 to Plaintiff/Decedent, including, but not limited to: 13 Physical and emotional damages from perforation and the resultant symptoms. As a direct an 14 proximate result of these maifunctions, Plaintiff suffered life-threatening injuries and damages 1s and required medical care and treatment. As a further proximate result, Plaintiff has suffered 16 and will continue to suffer significant medical expenses. pain, suffering, loss of enjoyment o 7 life, distress and other damages, 18 19 5. PlaintifffDeceased Party 3: Jerry Martin 20 a. Plaitiff(s) making Loss of Censortium claim Gf any): N/A 21 b. Other Plaintifi(s) and capacity (e.g., surviving spouse or heir, administrator, executor, 22 guardian, conservatory, N/A 23 c. Plaintiff’s/Decedent’s state(s) [if more than one Plaintiff] of residence at the time of 24 implant: Alabama 25 d. Plaintiff's/Decedent’s state(s) [if more than one Plaintiff] of residence at the time of injurv: 26 Alabama 27 e. Plaintiff's current state(s) [if more than one Plaintiff] of residence: Alabama 28 f Defendants (check Defendants against whom Complaint is made): “He SHORT-FORM COMPLAINT FOR DAMAGES FOR INDIVIDUAL ACTIONS To: 15102671546 Page: 10 of 27 2021-06-11 00:48:31 UTC 19493344554 From: Lopez McHugh 1 & Cordis Corporation 2 —| Johnson & Johnson 3 SJ Confluent Medical Technologies 4 & Does | through 50 5 g. Cordis IVC Filter(s) (check applicable IVC Filter): 6 & Trapease® Vena Cava Filter 7 _] Optease® Vena Cava Filter 8 h. Date(s) of Implantation(s) for each device: 9 On. or about January 1.2003 10 i. The filter subsequently malfunctioned and caused injury, damage, and/or wrongful death ll to Plaintiff/Decedent, including, but not limited to: 12 Physical_and emotional damages from_perforation_and tilt of the filter and the resultant 13 symptoms. As a direct and proximate result of these malfunctions, Plaintiff suffered life 14 threatening injuries aud damages and required medical care and treatment. As a further 1s proximate result, Plaintiff has suffered and will continue to suffer significant medical expenses, 16 pain, suffering, loss of enjoyment of life, distress and other damages. 17 18 6. Plaintiff/Deceased Party 6: Carol Neely 19 a. Plaintifi(s) making Loss of Consortium claim Cif any): N/A 20 b. Other Plaintiff(s) and capacity (e.g., surviving spouse or heir, administrator, executor, 21 guardian, conservator): N/A 22 c. Plaintiffs/Decedent’s state(s) [if more than one Plainuiff] of residence at the time of 23 implant: [lingis 24 d. Plaintiffs/Decedent’s state(s) [if more than one Plaintiff] of residence at the time of injury: 25 Ulinois 26 e. Plaimtffs current state(s) [if more than one Plaintiff] of residence: UU inois 27 f Defendants (check Defendants against whom Complaint is made): 28 = Cordis Corporation Te SHORT-FORM COMPLAINT FOR DAMAGES FOR INDIVIDUAL ACTIONS To: 15102671546 Page: 11 of 27 2021-06-11 00:48:31 UTC 19493344554 From: Lopez McHugh 1 | Johnson & Johnson 2 &S Confluent Medical Technologies 3 & Does | through 50 4 g. Cordis VC Filter(s) (check applicable VC Filter): 5 o] Trapease® Vena Cava Filter 6 >} Optease® Vena Cava Filter 7 h. Date(s) of Invplantation(s) for each device: 8 On_or about September 5, 2010 9 i. The filter subsequently malfunctioned and caused injury, damage, and/or wrongful death) 10 to Plaintiff/Decedent, including, but not Limited to: li Physical and emotional damages from perforation and tilt of the filter and the resultant 12 symptoms. As a direct_and proximate result of these malfunctions, Plaintiff suffered life- 13 threatening injuries and damages and required medical care and treatment. As a furihe 14 proximate result, Plaintiff has suffered and will continue to suffer significant medical expenses. 1s pain, suffering, loss of enjoyment of life, distress and other damages. 16 17 7. Plaintifi/Deceased Party 7: Romaine Perkins 18 a. Plaintiff(s) making Loss of Consortium claim (if any): N/A 19 b. Other Plaintiff(s) and capacity (e.g., surviving spouse or heir, administrator, executor, 20 guardian, conservator): N/A 21 c. Plamulls/Decedent’s state(s) [if more than one Plamtill] of residence at the time of 22 implant: New York 23 d. Plaintiff’s/Decedent’s state(s) [if mare than one Plaintiff] of residence at the time of injury: 24 New York 25 e. Plaintiffs current state(s) [if more than one Plaintiff] of residence: New York 26 f Defendants (check Defendants against whom Complaint is made): 27 & Cordis Corporation 28 [] Johnson & Johnson Re SHORT-FORM COMPLAINT FOR DAMAGES FOR INDIVIDUAL ACTIONS To: 15102671546 Page: 12 of 27 2021-06-11 00:48:31 UTC 19493344554 From: Lopez McHugh 1 & Confluent Medical Technologies 2 & Does | through 50 3 g. Cordis PVC Filter(s) (check applicable TVC Filter): 4 ol] Trapease® Vena Cava Filter 5 X Optease® Vena Cava Filter 6 h. Date(s) of Implantation(s) for each device: 7 On or about June 10, 2008 8 i. The filter subsequently malfunctioned and caused injury, damage, and/or wrongful death 9 to Plaintiff/Decedent, including, but not limited to: 10 Physical and emotional! damages from tit of the filter and the resultant symptoms. As a direct il and proximate result of these malfunctions, Plaintiff suffered life-threatening injuries and 12 damages and required medical care and treatment, As a further proximate result, Plaintiff has 13 suffered and will continue to suffer sienificant medical expenses. pain. suffering. loss o 14 enjoyment of life. distress and other damages. 1s 16 8 Plaintiff/Deceased Party 8: Steven Reigel 17 a. Plaintiff(s} making Loss of Consortium claim (if any): N/A 18 b. Other Plainiifi(s) and capacity (e.g. surviving spouse or heir, administrator, executor, 19 guardian, conservator): N/A 20 c. Plamtiffs/Decedent’s state(s) [if more than one Plaintiff] of residence at the time of 21 implant: Virgima 22 d. Plamntiff's/Decedent’s state(s) if more than one Plaintiff] of residence at the ime of injury: 23 Virginia 24 e. Plaintiff's current state(s) [if more than one Plaintiff] of residence: Virginia 25 Ff Detendants (check Defendants against whom Complaint is made): 26 & Cordis Corporation 27 -] Johnson & Johnson 28 & Confluent Medical Technologies oe SHORT-FORM COMPLAINT FOR DAMAGES FOR INDIVIDUAL ACTIONS To: 15102671546 Page: 13 of 27 2021-06-11 00:48:31 UTC 19493344554 From: Lopez McHugh & Does 1 through 50 Cordis IVC Filter(s) (check applicable 1VC Filter): ba (eo & Trapease® Vena Cava Filter ww Ll] Optease® Vena Cava Filter h. Date(s) of Implantation(s) for each device: On or about May 22, 2006 i. The filter subsequently malfunctioned and caused injury, damage, and/or wrongful death to Plaintiff/Decedent, including, but not limited to: Physical and emotional damages from perforation, migration, uu of the filler, and the resultan symptoms. As a direct and proximate result of these malfunctions. Plaintiff suffered lifes threatening injuries and damages and required medical care and treatment. As a further proximate result, Plaintiff has suffered and will continue to suffer significant medical expenses, pain, suffering, loss of eniovment of life, distress and other damages, 9. Plaintiff/Deceased Party 9: Derek Fruendt a. Plaintiffis) making Loss of Consortium claim (if any): Susan Fruendt b. Other Plaintifi(s) and capacity (e.g., surviving spouse or heir, administrator, executor, guardian, conservator): N/A c. Plaintiff?'s/Decedent’s state(s) [if more than one Plaintiff] of residence at the time off implant: New York d. Plaintiff’s/Decedent’s state(s) [if more than one Plainull] of residence at the ime of injury: New York Plaintiff’s current state(s) [if more than one Plaintiff] of residence: New York 8 & Defendants (check Defendants against whom Complaint is made): & Cordis Corporation _| Johnson & Johnson 24 Confluent Medical ‘Technologies 1 Does 1 through 50 ~f0- SHORT-FORM COMPLAINT FOR DAMAGES FOR INDIVIDUAL ACTIONS To: 15102671546 Page: 14 of 27 2021-06-11 00:48:31 UTC 19493344554 From: Lopez McHugh l g. Cordis IVC Filter(s) (check applicable IVC Filter): 2 & Trapease® Vena Cava Filter 3 ©] Optease® Vena Cava Filter 4 h. Date(s) of Implantation(s) for each device: 5 On or about Apnol 20, 2010 6 i. The filter subsequently malfunctioned and caused injury, damage, and/or wrongful death 7 to Plaintiff/Decedent, including, but not limited to: 8 Physical and emotional damages from perforation and tilt of the Alter and the resultan 9 symptoms, As a direct and proximate result of these malfunctions. Plaintiff suffered, life- 10 threatening injuries and damages and required medical care and treatment. As a further il proximate result, Plaintiff has suffered and will continue to suffer significant medical expenses. 12 pain, suffering, loss of enjoyment of life, distress and other damages. 13 14 10. Plaintiff/Deceased Party 10: Felix Senisais is a. Plaintiff(s) making Loss of Consortium claim Cf any): N/A 16 b. Other Plamtiff(s) and capacity (¢.g., surviving spouse or heir, administrator, executor, 17 guardian, conservator): N/A 18 c. PlamuifsDecedent’s state(s) [if more than one Plaintiff] of residence at the time o 19 implant: [ineis 20 d. Plamtiffs/Decedent’s state(s) [if more than one Plaintiff] of residence at the time of injurv: 21 Ulinois 22 e, Plaintiff's current state(s) [if more than one Plainuff] of residence: Ilinois 23 f Defendants (check Defendants against whom Complaint is made): 24 X Cordis Corporation 25 —| Johnson & Johnson 26 & Confluent Medical Technologies 27 2} Does | through 50 28 g. Cordis IVC Filter(s) (check applicable PVC Filter): ~f1- SHORT-FORM COMPLAINT FOR DAMAGES FOR INDIVIDUAL ACTIONS To: 15102671546 Page: 15 of 27 2021-06-11 00:48:31 UTC 19493344554 From: Lopez McHugh 1 co] Trapease® Vena Cava Filter 2 & Optease® Vena Cava Filter 3 h. Date(s} of Implantation(s) for each device: 4 On_or about April 27, 2014 5 i. The filter subsequently malfunctioned and caused injury, damage, and/or wrongful death 6 to Plaintiff/Decedent, including, but not limited to: 7 Physical and emotional damages from perforation and tilt of the filter and the resultan 8 symptoms. As a direct and proximate result of these malfunctions, Plaintiif suffered life- 9 threatening injuries and damages and required medical care and treaument..As a further 10 proximate result, Plaintiff has suffered and will continue to suffer significant medical expenses, li pain, suffering, loss of enjoyment of life, distress and other damages. 12 13 11. Plaintiff/Deceased Party 11: Bobby Murphy 14 a. Plaintiff(s) making Loss of Consortium claim (if any): N/A. is b. Other Plaintiff(s) and capacity (e.g., surviving spouse or heir, administrator, executor, 16 guardian, conservator): N/A 7 c. Plaintiff’s/Decedent’s state(s) [if more than one Plaintiff] of residence at the time of 18 implant: Virginia 19 d. Plaintiff's/Decedent’s state(s) [if more than one Plaintiff] of residence at the time of injury: 20 Virginia 21 e. Plarmtiffs current state(s) if more than one Plaintill] of residence: Virginia. 22 f Defendants (check Defendants against whom Complaint is made): 23 2 Cordis Corporation 24 o] Johnson & Johnson 25 & Confluent Medical Technologies 26 &! Does | through 50 27 g. Cordis IVC Filter(s) (check applicable IVC Filter): 28 “] Trapease® Vena Cava Filter ~f2- SHORT-FORM COMPLAINT FOR DAMAGES FOR INDIVIDUAL ACTIONS To: 15102671546 Page: 16 of 27 2021-06-11 00:48:31 UTC 19493344554 From: Lopez McHugh i X} Optease® Vena Cava Milter 2 h. Date(s) of Implantation(s) for each device: 3 On or about April 27, 2014 4 i. The filter subsequently malfunctioned and caused injury, damage, and/or wrongful death 5 to Plaintiff/Decedent, including, but not limited to: 6 Physical and emotional damages from perforation and tilt of the filter and the resultant 7 symptoms. As a direct and proximate result of these malfunctions, Plaintiff suffered life- 8 threatening injuries and damages and required medical care and treatment As a furthe 9 10 pain. suffering, loss of enjoyment of life, distress and other damages. ll 12 12. Plaintiff/Deceased Party 12: Marlena Bauer 13 a. Plamuff(s) making Loss of Consortium claim (if any): Larry Bauer 14 b. Other Plaintiff(s) and capacity (e.g., surviving spouse or heir, administrator, executor, is guardian, conservator): N/A 16 c¢. Plaintii’s/Decedent’s state(s) [if more than one Plamtiff] of residence at the time of 17 implant: Colorado is d. Plaintiif’s/Decedent’s state(s) fif more than one Plaintiff] of residence at the time of injury: 19 Colorado 20 e. Plaintiffs current state(s) [if more than one Plaintiff] of residence: Colorado 21 f Defendants (check Defendants against whom Complaint is made): 22 X! Cordis Corporation 23 —] Johnson & Johnson 24 X Confluent Medical Technologies 25 X Does | through 50 26 g. Cordis [VC Filter(s) (check applicable IVC Filter): 27 _] Trapease® Vena Cava Filter 28 = Optease® Vena Cava Filter ~[3- SHORT-FORM COMPLAINT FOR DAMAGES FOR INDIVIDUAL ACTIONS To: 15102671546 Page: 17 of 27 2021-06-11 00:48:31 UTC 19493344554 From: Lopez McHugh 1 h. Date(s) of Implantation(s) for each device: 2 On of about 2005 3 i, The filter subsequently malfunctioned and caused injury, damage, and/or wrongful death 4 to Plaintiff/Decedent, including, but not limited to: 5 Physical and emotional damages from tilt of the filter and the resultant symptoms. As a direct 6 and proximate result of these malfunctions, Plaintiff suffered life-threatening injuries and 7 damages and required medical care and treatment, As a further proximate result, Plaintiff has 8 suffered and will continue to suffer significant medical expenses. pain, suffering, loss of 9 enjoyment of life, distress and other damages. 10 ll 13. Plaintiff/Deceased Party 13: Anthony Edwards 12 a. Plaintiff(s) making Loss of Cansortiurn claim (if any): Jazz Edwards 13 b. Other Plaintiff(s) and capacity (e.g., surviving spouse or heir, administrator, executor, 14 guardian, conservator): N/A is ec. Plaintiff's/Decedent’s state(s) [if more than one Plaintiff] of residence at the time o 16 implant: Ulinois 17 d. Plaintiff’'s/Decedent’s state(s) [if more than one Plaintiff] of residence at the time of injurv: is Ilingis 19 e. Plaintiffs current state(s) [if more than one Plaintiff] of residence: Illinois 20 f Defendants (check Defendants against whom Complaint is made): 21 &! Cordis Corporation 22 J Johnson & Johnson 23 & Confluent Medical Technologies 24 XS Does 1 through 50 25 g. Cordis IVC Filter(s) (check applicable TVC Filter): 26 wd Trapease® Vena Cava Filter 27 &] Optease® Vena Cava Filter 28 h. Date(s) of Invplantation(s) for each device: “14. SHORT-FORM COMPLAINT FOR DAMAGES FOR INDIVIDUAL ACTIONS To: 15102671546 Page: 18 of 27 2021-06-11 00:48:31 UTC From: Lopez McHugh On or about July 25, 2013 i. The filter subsequently malfunctioned and caused injury, damage, and/or wrongful death ba to Plaintiff/Decedent, including, but not limited ta: ww Physical and emotional damages from perforation and tilt of the filter and the resultant syroptoms. As a direct and proximate result of these malfunctions, Plaintiff suffered life. threatening iniuries and damaees and required medical care and treatment, As a. further proximate result, Plaintiff has suffered and will continue to suffer significant medical expenses, pain, suffering, loss of enjoyment of life, distress and other damages. 14. Plaintiff/Deceased Party 14: Lisa Keaton a. Plaintiff(s) making Loss of Consortium claim (Gif any): N/A. b. Other Plaintiff(s) and capacity (e.g., surviving spouse or heir, administrator, executor, guardian, conservator): N/A c. Plaintiff's/Decedent’s state(s) [if more than one Plaintiff] of residence at the time o implant: Michigan d. Plamtu’s/Decedent’s state(s) [if more than one Plaintiff) of residence at the time of injury: Michigan e. Plaintiffs current state(s) [if more than one Plaintiff] of residence: Michigan f. Defendants (check Defendants against whom Complaint is made): | Cordis Corporation =) Johnson & Johnson es Confluent Medical Technologies &} Does | through 59 g. Cordis IVC Filter(s) (check applicable [VC Filter): XM Trapease® Vena Cava Filter L] Optease® Vena Cava Filter h. Date(s) of Implantation(s) for each device: On or about June 25, 2012 ~f5- SHORT-FORM COMPLAINT FOR DAMAGES FOR INDIVIDUAL ACTIONS To: 15102671546 Page: 19 of 27 2021-06-11 00:48:31 UTC 19493344554 From: Lopez McHugh 1 i. The filter subsequently malfunctioned and caused injury, damage, and/or wrongful death 2 to Plaintiff/Decedent, including, but not limited to: 3 Physical and emotional damages from_perforation and tilt of the filter and the resultan 4 symptoms. As a direct and proximate result of these malfunctions, Plaintiff suffered lifes 5 threatening injuries and damages and required medical care and treatment As a further 6 proximate result, Plaintiff has suffered and will continue to suffer significant medical expenses, 7 pain, suffering, loss of enjoyment of life, distress and other damages. 8 9 15. Plaintiff/Deceased Party 15: Peter Wilson 10 a. Plaintiff(s) making Loss of Consortium claim (if any): N/A ll b. Other Plaintiff(s) and capacity fe.g., surviving spouse or heir, administrator, executor, 12 guardian, conservator): N/A i3 c. Plamtif’s/Decedent’s state(s) [if more than one Plaintiff] of residence at the time o 14 implant: New Jersey is d. Plaintiff’s/Decedent’s state(s) [if more than one Plaintiff] of residence at the time of injury: 16 New Jersey 17 e. Plarntiff’s current state(s) Gf more than one Plaintiff] of residence: New Jersey 18 f. Defendants (check Defendants against whom Complaint is made): 19 & Cordis Corporation 20 ©] Johnson & Johnson 21 | Confluent Medical Technologies 22 &! Does | through 50 23 g. Cordis IVC Filter(s) (check applicable IVC Filter): 24 _] Trapease® Vena Cava Filter 25 x Optease® Vena Cava Filter 26 h. Date(s) of Implantation(s) for each device: 27 On or about June 2010 28 i. The filter subsequently malfunctioned and caused injury, damage, and/or wrongful death -f6- SHORT-FORM COMPLAINT FOR DAMAGES FOR INDIVIDUAL ACTIONS To: 15102671546 Page: 20 of 27