The documents are attached [OR] I have no documents Produce all documents concerning any communication between you and the Food and Drug Administration (FDA) or between you and any employee or of the Defendants, regarding the pelvic mesh product(s) at issue, except as to those communications which are attorney client/work product privileged. i. Not Applicable ii. The documents are attached [OR] I have no documents Produce all documents in your possession, custody or control evidencing or relating to any correspondence or communication between either you or Coloplast Corp., (or any of its related companies or divisions) with any of your doctors, healthcare providers, and/or you relating to the pelvic mesh product(s), except as to those communications which are attorney client/work product privileged. Not Applicable The documents are attached [OR] I have no documents Produce any and all documents in your possession, custody or control reflecting, describing, or in any way relating to any instructions or warnings you received to implantation of any pelvic mesh product(s) concerning the risks and/or benefits of your surgery, including but not limited to any risks and/or benefits associated with the pelvic mesh product(s). Not Applicable The documents are attached [OR] I have no documents Produce any and all documents reflecting the model number and lot number of the pelvic mesh product(s) you received. Not Applicable The documents are attached [OR] I have no documents If you underwent surgery to explant in whole or in part the pelvic mesh product(s) that you received: produce any and all documents in your possession, custody or control aside from documents that may have been generated by experts retained by your counsel for litigation purposes, relating to any evaluation of the pelvic mesh product(s) and any other material that was (were) surgically removed from you.
The documents are attached [OR] I have no documents Produce all documents concerning any communication between you and the Food and Drug Administration (FDA) or between you and any employee or of the Defendants, regarding the pelvic mesh product(s) at issue, except as to those communications which are attorney client/work product privileged. i. Not Applicable ii. The documents are attached [OR] I have no documents Produce all documents in your possession, custody or control evidencing or relating to any correspondence or communication between either you or Coloplast Corp., (or any of its related companies or divisions) with any of your doctors, healthcare providers, and/or you relating to the pelvic mesh product(s), except as to those communications which are attorney client/work product privileged. Not Applicable The documents are attached [OR] I have no documents Produce any and all documents in your possession, custody or control reflecting, describing, or in any way relating to any instructions or warnings you received to implantation of any pelvic mesh product(s) concerning the risks and/or benefits of your surgery, including but not limited to any risks and/or benefits associated with the pelvic mesh product(s). Not Applicable The documents are attached [OR] I have no documents Produce any and all documents reflecting the model number and lot number of the pelvic mesh product(s) you received. Not Applicable The documents are attached [OR] I have no documents If you underwent surgery to explant in whole or in part the pelvic mesh product(s) that you received: produce any and all documents in your possession, custody or control aside from documents that may have been generated by experts retained by your counsel for litigation purposes, relating to any evaluation of the pelvic mesh product(s) and any other material that was (were) surgically removed from you.
ColoplastPlaintiffProfileForm.docx