Welcome to the Ethicon Proceed Hernia Mesh Multi-County Litigation page for plaintiffs. Below you will find links to the most important court orders and forms that you may find useful.
Welcome to the Ethicon Proceed Hernia Mesh Multi-County Litigation page for plaintiffs. Below you will find links to the most important court orders and forms that you may find useful.
| Court Orders | Link |
|---|---|
| Initial Case Management Order No. 1 | CMO 1 |
| Case Management Order No. 2 | CMO 2 |
| Case Management Order No. 2A - Plaintiffs' Steering Committee | CMO 2A |
| Case Management Order No. 2B - Amending Plaintiffs' Leadership | CMO 2B |
| Case Management Order No. 3 - Confidentiality and Protective Order | CMO 3 |
| Case Management Order No. 4 (Amended) - Records Collection | CMO 4 (Amended) |
| Case Management Order No. 5 - Pathology Protocol for Preservation, Division, and Testing of Explanted Mesh and Tissue Samples Taken From Plaintiffs | CMO 5 |
| Case Management Order No. 6 (Third Amended) - Plaintiff Profile Form | CMO 6 (Amended) |
| Case Management Order No. 7 (Sixth Amended) - Discovery, Scheduling and Case Management Initial Discovery Pool | CMO 7 (Sixth Amended) |
| Case Management Order No. 8 - Plaintiff Fact Sheet and Defendant Fact Sheet | CMO 8 |
| Case Management Order No. 9 - Management of Timekeeping, Cost Reimbursement and Related Common Benefit Issues | CMO 9 |
| Case Management Order No. 10 - Order Governing Translation of Foreign Language Documents | CMO 10 (Amended) |
| Case Management Order No. 11 - Depositions | CMO 11 |
| Case Management Order No. 12 - Cases Selected for Individual Discovery (Amended) | CMO 12 (Third Amended) |
| Case Management Order No. 13 - Psychiatric Authorizations | CMO 13 |
| Case Management Order No. 14 - Protocols for Depositions Taken During COVID-19 Pandemic | CMO 14 |
| Case Management Order No. 15 - Appearance of Local NJ Attorneys at Depositions | CMO 15 |
| Case Management Order No. 16 - Questioning of Treating Physicians | CMO 16 |
| Case Management Order No. 17 - Setting Deadlines for Parties | CMO 17 |
| Case Management Order No. 18 - Production of Ethicon Hernia Mesh Exemplars | CMO 18 |
| Case Management Order No. 19 - Procedure for Filing of Motions as to Plaintiffs Who Fail to Provide a Plaintiff Profile Form | CMO 19 |
| Order to File Motions to Dismiss in Cases in Which No Plaintiff Profile Form Has Been Served (Amended) | Order to File Motions to Dismiss (Amended) |
| Order Regarding Pro Hac Vice Admission and Appearances | Order |
| Case Management Order No. 20 - Notice of Deaths of Plaintiffs | CMO 20 (Amended) |
| Case Management Order No. 21 - Return Date of Dispositive Motions and Schedule for Submission of Papers on Dispositive Motions | CMO 21 |
| Order Replacing Therron Hughes, ATL-L-730-20, with Donald Denton, ATL-L-442-20, as a Trial Selection of the Court Pursuant to Fourth Amended CMO No. 7 | Court Trial Selection Denton |
| Case Management Order No. 23 - Procedure for Replacement of Cases Selected for Trial | CMO 23 |
| Order Replacing Albert Adamczak, ATL-L-1006-9, with Robert Lowrey, ATL-L-958-19, as a Trial Selection of Defendants Pursuant to Fourth Amended CMO No. 7 | Trial Selection of Defendants |
| Case Management Order No. 24 - Procedures for Treating Physician Fact Witnesses | CMO 24 |
| Order Replacing Jonathan Payne, ATL-L-1083-19, with Fred Martin, ATL-L-2313-19, as a Trial Selection of Defendants Pursuant to Fourth Amended Case Management Order No.7 | Trial Selection of Defendants |
| Case Management Order No. 25 - Stempler Interviews and Authorizations | CMO 25 |
| Case Management Order No. 26 - Pretrial Scheduling Order | CMO 26 |
| Scheduling Orders | Link |
|---|---|
| Order Scheduling Case Management Conferences (Amended) | Scheduling Order July-Dec 2020 (Amended) |
| Order Scheduling Case Management Conferences 2022 | Scheduling Order 2022 |
| Order w Respect to Return Date of Non-Dispositive Motions and Schedule for Submission of Papers | Scheduling Order |
| Order amending Case Management Conference April 2021 | Scheduling Order April 2021 (Amended) |
| Forms and Documents | Link |
|---|---|
| Plaintiff Profile Form - Word Format | Word Doc |
| Plaintiff Profile Form - Fillable PDF | Plaintiff Profile Form - Fillable PDF |
| Plaintiff Medical Authorization | Medical Authorization - Fillable PDF |
| Plaintiff Medicare Authorization | Medicare Authorization - Fillable PDF |
| Plaintiff Mental Health Record Authorization | Mental Health Record Authorization - Fillable PDF |
| Plaintiff SSA Authorization | SSA Authorization - Fillable PDF |
| Plaintiff IRS Form 4506 | IRS Form 4506 - Fillable PDF |
| Plaintiff IRS Form 8821 | IRS Form 8821 - Fillable PDF |
| Pathology Protocol Exhibits - Word Format | Word Doc |
| Pathology Protocol Exhibits - Fillable PDF | Fillable PDF |
| Plaintiff Fact Sheet | Word Doc |
| Plaintiff Fact Sheet PDF | Fillable PDF |
To view the Application for Multicounty Litigation Designation, click here. To view the official website for this MCL, visit the Proceed Surgical Mesh/Proceed Ventral Patch website.