Case 3:15-cv-03489-K Document 146 Filed 10/15/17 Page 1 of 1 PageID 18930

IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF TEXAS

DALLAS DIVISION
IN RE: DePuy ORTHOPAEDICS, INC. PINNACLE MDL No. 2244
HIP IMPLANT PRODUCTS LIABILITY LITIGATION Honorable Ed Kinkeade

 

This Document Relates To:

Alicea v. DePuy Orthopaedics, Inc., o. 3:15-cv-3489-K
Barzel DePuy Orthopaedics, Inc, No. 
v. DePuy Orthopaedics, Inc., No. 3:16-cv-1526-K
Miara o. DePuy Orthopaedics, Inc, o. 3:13-cv-4119-K
Stevens DePuy Orthopaedics, Inc, No. 3:14-cv-1776-K
Stevens 0. DePuy Orthopaedics, IncAFFIDAVIT OF DAVID SHEIN, M.D.
On Friday, October 13, 2017, at approximately 11:00am while I was scrubbing in for surgery at
the Monte?ore Hospital, 1 met with my DePuy sales representative Glen Swajger in connection
with a procedure that required his involvement.
Mr. Swajger looked terrible and appeared stressed, so I asked him what was going on. He said the
day before (October 12, 2017), he had been contacted by the DePuy lawyers and that discussion
made him anxious. He said the lawyers were ?on him like crazy.? They were putting ?big time
pressure? on him.
Mr. Swajger told me that as a result of the conversations with DePuy attorneys, he was worried
there could be rami?cations for me in my practice in connection with my upcoming Dallas
testimony.
He indicated the lawyers were ?peppering him?. He said the ?business in Dallas was freaking [him]
out.? He said he had a ?terrible? day on Thursday as a result of this and my going to Dallas was
driving him crazy. He said care about you.?
Mr. Swajger also told me on Friday that he knows as much about metal on metal as I do, and that
he would still want metal on metal because the wear characteristics are better than metal on poly,

and he would want me to do his surgery.

 

 

Io Is? 141??