On August 5, 2011, plaintiffs in the federal DePuy ASR multidistrict litigation issued a Notice of Oral and Video Deposition of DePuy International Limited pursuant to Rule 30(b)(6) of the Federal Rules of Civil Procedure.  A 30(b)(6) deposition is an important discovery tool for plaintiffs because testimony obtained during this type of deposition binds the corporation.  The deposition is scheduled to take place on September 7, 2011 in Indianapolis, Indiana.  An officer, director, managing agent, or employee of defendant DePuy International Limited will be deposed.  The focus of the deposition will be on corporate organization and structure.

DePuy ASR Metal On Metal Hip Implant Multidistrict Litigation: Topics Covered During 30(b)(6) Deposition

Since discovery in the multidistrict litigation is still in its nascent stage, the 30(b)(6) deposition is intended to yield important strategic information relating to the recalled hip replacements and covers the following topics:  (1) corporate structure; (2) the organizational structure of DePuy International Limited as it relates to DePuy ASR hip replacements; (3) operational and contractual relationships; (4) departments involved in the manufacturing, marketing, development and sale of the DePuy ASR hip replacements; (5) organizational charts; (6) individuals responsible for the manufacturing, marketing, development and sale of the DePuy ASR hip replacements; (7) capital shareholders of DePuy International Limited; (8) third parties involved in the sale or distribution of the DePuy ASR hip replacements; (9) location and storage of DePuy ASR hip replacements that have been removed from patients and delivered to DePuy; (10) individuals responsible for the storage of the explanted DePuy ASR hip replacements; and (11) individuals responsible for adverse event reports relating to the DePuy ASR hip replacements.

DePuy ASR Metal On Metal Hip Implant Multidistrict Litigation: Discovery Documents To Be Produced At 30(b)(6) Deposition

In addition to identifying topics on the DePuy ASR hip replacements plaintiffs intend to address during the 30(b)(6) deposition, plaintiffs have also identified specific discovery documents they would like defendants to produce.  Among other things, plaintiffs have requested: (1) corporate organizational charts; (2) annual reports; (3) SEC filings; (4) license agreements; (5) trademark documents, (6) royalty agreements; (7) third party agreements related to the sale or distribution of DePuy ASR hip replacements; and (8) documents relied on by deponents in preparing for the deposition.

DePuy Hip Replacements Lead To Lawsuits

If you or a loved one has experienced any problems as a result of a DePuy metal on metal hip or total hip replacement, you may be able to file a lawsuit seeking compensation for your medical expenses, pain and suffering, lost wages and more.  Contact one of our lawyers today for a free and confidential DePuy metal on metal hip lawsuit evaluation.  The lawyers at Bernstein Liebhard LLP have extensive litigation experience and have recovered billions of dollars for their clients.  In addition to being staunch advocates for your claim, our DePuy metal on metal hip replacement injury lawyers also provide personal attention to guide you through the complex litigation process.

Published August 19, 2011 by