Laloli v. C R Bard Incorporated

CourtDistrict Court, N.D. California
DecidedJuly 25, 2021
Docket4:19-cv-05679
StatusUnknown

This text of Laloli v. C R Bard Incorporated (Laloli v. C R Bard Incorporated) is published on Counsel Stack Legal Research, covering District Court, N.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Laloli v. C R Bard Incorporated, (N.D. Cal. 2021).

Opinion

1 2 3 4 UNITED STATES DISTRICT COURT 5 NORTHERN DISTRICT OF CALIFORNIA 6 7 FRANCIS LALOLI, Case No. 19-cv-05679-JST

8 Plaintiff, ORDER RE MOTIONS IN LIMINE 9 v.

10 C.R. BARD, INC., et al., Defendants. 11

12 13 The Court now rules as follows regarding the parties’ motions in limine: 14 I. Plaintiff’s Omnibus Motion in Limine No. 1 (ECF No. 156)

15 A. Motion To Preclude “Any Suggestion that Mr. Laloli’s Eclipse Filter Caught or Stopped a Clot and Saved His Life” 16 This motion is granted. Dr. Stein may not suggest that Laloli’s filter “accomplished its 17 mission” by stopping or dissolving a clot. Dr. Stein may identify the purpose of the IVC filter – to 18 stop and dissolve clots – and may note that Plaintiff Laloli appears not to have suffered a 19 pulmonary embolism after the device was implanted. What neither he nor any other witness may 20 do, however, is draw the conclusion that the Bard IVC filter necessarily stopped or dissolved a 21 clot. 22 B. Motion to Preclude “Arguments Regarding Alleged Complaint or Failure Rates or the Medical Community At-Large” 23 1. Motion to preclude “[a]ny implication that the relatively modest 24 number of complaints regarding IVC filters demonstrate that the product is ‘safe’ or that the complaint rate is equivalent to the 25 complication rate” 26 Plaintiff’s motion and Bard’s opposition each frame the motion differently. Plaintiff 27 moves to preclude Bard from introducing evidence that “the complaint rate is equivalent to the 1 To the extent the foregoing accurately characterizes Plaintiff’s motion, the motion is therefore 2 granted. To the extent the motion seeks to preclude evidence of Bard’s reported complication 3 rates – whether internal, external, or otherwise – the motion is denied. Such evidence is relevant 4 to whether Bard acted reasonably in designing the G2X.

5 2. Motion to preclude “[a]ny reference to the number of people allegedly implanted or treated with IVC filters based on the number of units 6 sold” or “[a]ny reference to the total product sales for IVC filters” 7 The Court construes these two subparts together as a motion to exclude Bard’s filter sales 8 figures. So construed, the motion is denied. Concerns about the inferences to be drawn from such 9 evidence can be addressed through cross-examination.

10 3. Motion to preclude “[a]ny reference to any specific percentage of doctors who use IVC filters” 11 The motion is granted as unopposed. 12 4. Motion to preclude “[a]ny reference as to what ‘all physicians know’ 13 regarding risks or benefits of procedures or devices, deep venous thrombosis, or similar statements” 14 Plaintiff’s entire argument in support of this motion is as follows: “These references are 15 patently speculative, unfairly prejudicial, and amount to hearsay.” ECF No. 156 at 5. Since Plaintiff 16 does not identify what “these references” are, however, it is not possible for the Court to fairly 17 evaluate, much less grant, the motion. See In re Bard IVC Filters Prod. Liab. Litig. (Booker), No. 18 CV-16-00474-PHX-DGC, 2018 WL 1109554, at *8 (D. Ariz. Mar. 1, 2018) (“Because Plaintiffs 19 identify no specific statement from any particular association, the Court cannot grant Plaintiffs’ 20 motion.”). 21 The motion is denied. 22 C. Motion to Preclude the Opinions of Trade Associations Or Other 23 Organizations Are Not Relevant to Plaintiff’s Claims and, Therefore, Should Be Excluded 24 The motion is denied. “The . . . SIR guidelines . . . are relevant to Plaintiffs’ negligence 25 and punitive damages claim. In deciding whether Defendants acted reasonably for purposes of the 26 negligence claim, the jury may consider rates of risk accepted within the medical community (the 27 SIR guidelines) and what Defendants told physicians about those risks in the IFU.” In re Bard 1 IVC Filters Prod. Liab. Litig. (Hyde), No. CV-16-00893-PHX-DGC, 2018 WL 4215028, at *4 (D. 2 Ariz. Sept. 4, 2018). 3 Although Hyde was decided under Wisconsin law, the California law the jury will apply in 4 the present case relies upon similar considerations. Under California law, “[a] product is defective 5 under the risk-benefit test if the plaintiff demonstrates that the product’s design proximately 6 caused his injury and the defendant fails to establish, in light of the relevant factors, that, on 7 balance, the benefits of the challenged design outweigh the risk of danger inherent in such 8 design.” Mariscal v. Graco, Inc., 52 F. Supp. 3d 973, 987 (N.D. Cal. 2014) (citation omitted). 9 The relevant factors include “the gravity of the danger posed by the challenged design, the 10 likelihood that such danger would occur, . . . and the adverse consequences to the product and to 11 the consumer that would result from an alternative design.” Id. (quoting Barker v. Lull Eng’g Co., 12 20 Cal. 3d 413, 431 (1978)). See also CACI 1221 (“In determining whether [defendant] used 13 reasonable care, you should balance what [defendant] knew or should have known about the 14 likelihood and severity of potential harm from the product against the burden of taking safety 15 measures to reduce or avoid the harm.”). 16 The SIR guidelines bear on these questions. Thus, to the extent Bard can demonstrate that 17 it was aware of the SIR guidelines contemporaneously, they are admissible. Bard also suggests 18 that these materials are admissible under Rule of Evidence 803(18). The Court will defer ruling 19 on that issue until trial.

20 D. Motion to Preclude Any Suggestion That Placement of An IVC Filter is a Standard or Routine Course of Treatment 21 The motion is denied. This evidence is relevant to the risk/utility analysis the jury will be 22 asked to perform. Booker, 2018 WL 1109554, at *5; Chavez v. Glock, Inc., 207 Cal. App. 4th 23 1283, 1305 (2012) (quotation omitted) (“The test of negligent design involves a balancing of the 24 likelihood of harm to be expected from a [product] with a given design and the gravity of harm if 25 it happens against the burden of the precaution which would be effective to avoid the harm.” 26 (quotation and citation omitted)). 27 / / / E. Motion to Preclude Any Reference to the Number of Documents Bard Has 1 Produced in This Litigation 2 The motion is denied.

3 F. Motion to Preclude Bard From Making “Empty Chair” Arguments

4 1. Motion to preclude reference to fault or negligence of non-parties 5 The motion is denied. Bard is entitled to present evidence of other causes of any injuries 6 suffered by Plaintiff.

7 2. Motion to Preclude reference to or adverse inference from Plaintiff not suing all potential parties 8 Bard does not respond to this portion of the motion, which is granted. 9 II. Plaintiff’s Motion in Limine No. 2 To Preclude Introductoin of or Reference to “The 10 Surgeon General’s Call to Action” (ECF No. 151) 11 This motion is denied. The Surgeon General’s report is a relevant public record that is not 12 made inadmissible by the hearsay rule. Its probative value is not outweighed by the risk of undue 13 prejudice. The Call to Action report is relevant to Plaintiff’s negligent design claim because, at 14 the very least, it is relevant to the risk-benefit analysis the jury must perform. In re Bard IVC 15 Filters Prod. Liab. Litig., No. CV-16-00893-PHX-DGC, 2018 WL 4279833, at *2-3 (D. Ariz. 16 Sept. 7, 2018).

17 III. Plaintiff’s Motion in Limine No. 3 to Exclude Any Reference to IVC Filters as Lifesaving Devices or to Statistics of Thrombi and Pulmonary Emboli (ECF No. 152) 18 This motion is denied for the reasons stated in Booker, 2018 WL 1109554, at *4. 19 IV. Plaintiff’s Motion in Limine No. 4 Sending Warning Letters to Physicians or 20 Consumers Changing the Instruction for Use To Add or Strengthen Warnings or Effectuate A Removal or Recall Without FDA Consent (ECF No.

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