DocuSign Envelope ID: 3937ED5A-3593-4B09-86AF-5763386E6271

Covidien Hernia Mesh Products Liability Litigation

Massachusetts State Court
Re: Covidien Hernia Mesh Plaintiff Profile Form

Individual with Covidien Product: Patrice Allen

Case Caption: Hanaa Abdou, et al v Covidien LP, and Sofradim Production SAS
Docket Number: 21-1980

10/03/2022

Patrice Allen
luvnurseallen@yahoo.com

Dear Patrice,

You are receiving this letter from your attorney, Andrew Cross, at Carey Danis & Lowe.
Enclosed is a copy of the Covidien Hernia Mesh Products Liability Litigation Massachusetts
State Court Plaintiff Profile Form for Patrice Allen. The Plaintiff Profile Form is court ordered
and is required to be submitted to defendants, including accompanying medical records and
authorizations.

Please review the document in detail. If you agree with the information, sign the Plaintiff
Certification on the last page and return this document. If you have questions or disagree with
any of the information, please contact Molly Gillespie, at Mgillespie@careydanis.com or
13147257700 to discuss. Please note that the Plaintiff Profile Form has an associated deadline,
and your certification is a requirement. Your timely response is appreciated.

Thank you,

Andrew Cross
Carey Danis & Lowe
DocuSign Envelope ID: 3937ED5A-3593-4B09-86AF-5763386E6271

COMMONWEALTH OF MASSACHUSETTS
SUPERIOR COURT DEPARTMENT OF THE TRIAL COURT

MIDDLESEX, SS. SUPERIOR COURT DEPARTMENT

CIVIL ACTION NO.: 21-1980

Patrice Allen, )
Plaintiff. )
)
v. )
) LEAD CASE: Bettie Ann Smith
COVIDIEN LP, and SOFRADIM, ) DOCKET NO: 1781CV01845
PRODUCTION, SAS, ) Q-Session
Defendants. )
)
)
)

FIRST SERVED PLAINTIFF PROFILE FORM

In completing this Plaintiff Profile Form, you must provide information that is true and correct to
the best of your knowledge. The Plaintiff Profile Form shall be completed in accordance with
the requirements and guidelines set forth in the applicable Case Management Order(s).

I. CASE INFORMATION

1. Caption: Hanaa Abdou, et al v Covidien LP, and Sofradim Production SAS

2. Docket No.: 21-1980

3. Primary attorney contact (name, address, phone and email):

Andrew Cross 8235 Forsyth Blvd. Suite 1100 St. Louis , MO 63015 13147257700
Across@careydanis.com

II. PLAINTIFF INFORMATION

1. Name of individual with Covidien product (hereinafter referred to as “you” or

“your”):
Patrice Allen

2. Gender: Female

3. Date of Birth: September 16, 1972

4. Last 4 Digits of Social Security No.: 9117

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5. List all addresses from two years before your surgery involving products
identified in Section III below to the present:
5408 Onacrest Dr Los Angeles , CA 90043

6. List all employers (including their names and addresses) from two years before
your surgery involving products identified in Section III below to the present,
including your role and period of employment:

7. Have you ever served in the military?

No
a. If yes, list years of service:

8. Are you currently married?

Yes
a. If currently married, name of spouse:
Ray Allen

9. Do you have children (biological or legally adopted)?

Yes
a. If yes, how many?
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b. If yes, name(s) of living children over the age of 18:
TO BE SUPPLEMENTED TO BE SUPPLEMENTED
TO BE SUPPLEMENTED TO BE SUPPLEMENTED

10. Are you asserting a Loss of Consortium Claim?

No

11. If individual implanted with Covidien product is deceased, name of estate

representative:

12. Within the last 10 years, have you filed bankruptcy?

No
a. If yes, what year(s)?

13. Within the last 10 years, have you filed a lawsuit alleging physical injury other
than this Covidien Hernia Mesh lawsuit?
No

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a. If yes, state the year, case number, court, and parties:

14. Are you claiming damages for lost wages in this case?
No
a. If yes, identify the time period over which you claim you have lost wages.

15. Do you currently receive (or have you ever received) disability benefits (e.g.,
Social Security Disability Benefits, short or long-term disability benefits
provided by the government or an employer)?
No
a. If yes, list types of Benefits and time periods:

16. Identify your health insurance from the time of your surgery involving any
products identified in Section III below through the present. [Fill in chart: the
name of insurance provider, the policy number, and date period of coverage.]
TO BE SUPPLEMENTED TO BE SUPPLEMENTED

III. COVIDIEN PRODUCT INFORMATION

1. Covidien Product
a. Date of implant: February 25, 2011
b. Condition sought to be treated by device: [Drop down: inguinal, femoral,
ventral, umbilical, other [with ability to write in]] Other, Epigastric Hernia
c. Name of product: Parietex Composite (PCO)
d. Lot Number: PIE00137
e. Name and address of implanting surgeon:
George Wilkinson 66041 Cadillac Ave Los Angeles , CA 90034
f. Name and address of facility where surgery was performed:
Kaiser Permanente West Los Angeles Medical Center 66041 Cadillac Ave Los
Angeles , CA 90034
g. Has this product been revised or removed? [Drop down: Yes, No, Partially,
Unknown] If you underwent more than one procedure to revise or remove
this product, enter additional procedures below. Yes
i. Date of revision or removal surgery.
May 19, 2011
1. Description of revision or removal surgery: Surgery
under general. Laparoscopy. Excision of infected
abdominal wall abscess cavity. Removal of mesh. Primary
repair of ventral hernia. Dx: Recurrent Incisional hernia.

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Abdominal wall abscess. Findings: Cystic appearing mass

lesion adherent to the undersurface of the prior ventral
hernias site which contained pus. Extended above the
peritoneal fascial level layer into the subcutaneous space.
Mesh was coated with pus.
Path: Hernia sac showing fibrosis with central abscess
formation; Foreign material (synthetic mesh), gross only.
C&S Staphylococcus lugdunensis. DC SUMM – MRSA.

2. Name and address of surgeon who performed revision

or removal surgery:
George Wilkinson, Jr., MD 66041 Cadillac Ave Los
Angeles , CA 90034
3. Name and address of facility where revision or removal
surgery was performed:
Kaiser Permanente West Los Angeles Medical Center
66041 Cadillac Ave Los Angeles , CA 90034
ii. Date of revision or removal surgery.
December 29, 2018
1. Description of revision or removal surgery: Surgery
under general. Ventral hernia repair with mesh. Dx:
Incarcerated ventral hernia.
2. Name and address of surgeon who performed revision
or removal surgery: Keira Kamm 66041 Cadillac Ave Los
Angeles , CA 90034
3. Name and address of facility where revision or removal
surgery was performed: Kaiser Permanente West Los
Angeles Medical Center 66041 Cadillac Ave Los Angeles ,
CA 90034
iii. Enter additional revision or removal surgeries by clicking here.

2. Covidien Product
h. Date of implant: December 29, 2018
i. Condition sought to be treated by device: [Drop down: inguinal, femoral,
ventral, umbilical, other [with ability to write in]] Ventral
j. Name of product: Parietex Ventral Patch
k. Lot Number: PPHO163X
l. Name and address of implanting surgeon:
Keira Kamm 66041 Cadillac Ave Los Angeles , CA 90034
m. Name and address of facility where surgery was performed:
Kaiser Permanente West Los Angeles Medical Center 66041 Cadillac Ave Los
Angeles , CA 90034

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n. Has this product been revised or removed? [Drop down: Yes, No, Partially,
Unknown] If you underwent more than one procedure to revise or remove
this product, enter additional procedures below. No
i. Enter additional revision or removal surgeries by clicking here.

[If additional product, please include on a separate sheet.]

IV. OUTCOME ATTRIBUTED TO DEVICE

1. List all injuries that you allege are attributable to products identified in Section III
above. Please specify whether your alleged injuries include: [Drop down with ability
to select multiple: acute or chronic pain, infection, hernia recurrence, hematoma,
inflammation, allergic reaction to the components of the product, adhesions (scar-
like tissue that sticks tissues together), obstruction (blockage of the large or small
intestine), bleeding, fistulas (abnormal connection between organs, vessels, or
intestines), seroma (fluid build-up at the surgical site), perforation (hole in
neighboring tissues or organs) or OTHER.
Acute Chronic Pain, Infection, Hernia Recurrence, Inflammation, Adhesions,
Obstructions, Seroma

2. If you claim you are currently experiencing symptoms related to your alleged
injuries, please describe your current symptoms in detail.
Continued abdominal pain

3. If you recall that a physician or health care provider told you that a Covidien
product caused your injuries, state the name of the physician or health care
provider who told you that a Covidien product caused your injuries.
Dr. George Ewing Wilkinson, Jr., MD; Dr. Keira Louise Kamm, MD

4. Please list any family members, friends, or other persons who have knowledge
regarding your hernia, treatment for your hernia, and any complications associated
with your hernia or the use of the Covidien product. Please also identify their
relationship to you.
Ray Allen, Husband

5. Please list all doctors or other healthcare providers you have seen for treatment of
any of the injuries you allege related to the Covidien product.

Provider Name, Address Condition(s) Treated Approximate Dates of

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and Specialty Treatment

Dr. George Ewing Wilkinson, Jr., 'Acute or Chronic Pain', 2011
MD 'Infection', 'Inflammation',
66041 Cadillac Ave., Los Angeles 'Seroma (fluid build-up at
CA 90034 the surgical site)'
General Surgeon
Dr. Keira Louise Kamm, MD 'Acute or Chronic Pain', 2018
66041 Cadillac Ave., Los Angeles 'Hernia Recurrence',
CA 90034 'Adhesions (scar-like tissue
General Surgeon that sticks tissues together)',
'Obstructions (blockage of
the large or small intestine)'

6. Other than the Covidien product(s) that is the subject of this lawsuit, have you had
any other hernia mesh products implanted by your healthcare providers?
No
a. If yes, please provide the following information:
i. Product 1:
1. Product Name:
2. Date of implant procedure:
3. Name and address of implanting doctor:

4. Name and address of implant facility:

5. Condition sought to be treated by device:

6. Has this product been removed?

a. Date of surgery:

b. Description of surgery:

c. Name and address of surgeon:

d. Name and address of explant facility:

V. MEDICAL HISTORY
1. Current Height:
5' 11"

2. Current Weight:
332 lbs.

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3. History of Pregnancy (check applicable):

a. Number of pregnancies: 2
Dates of each pregnancy resulting in a live birth; further drop down (“vaginal
delivery” or “Cesarean section”]
i. Unknown Unknown, Unknown, Vaginal Delivery
ii. Unknown Unknown, Unknown, Vaginal Delivery

4. Smoking status:
a. Current smoker:
No
i. If yes, how much do you smoke?

b. Past smoker:
No
i. If yes, how much did you smoke?

ii. If yes, when did you quit?

5. Family history of hernias:

i. Has anyone in your immediate or extended family ever had a hernia(s):
Unknown
ii. If yes, please describe the type of hernia.

6. Have you ever used prescribed narcotics as treatment for pain associated
with your Covidien hernia mesh product?
Yes

7. History of alcohol use:

i. Do you drink alcohol?
No
a. If yes, how many drinks on average per week [[Drop down: 1-2; 3-4; 5-6;
7+]:

8. List your current medications:

TO BE SUPPLEMENTED

9. Have you ever been diagnosed with any of the following?

Illness/ Yes, No, Unknown If yes, describe or If yes, approx.

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Condition identify: date of diagnosis for each

illness/condition selected
Autoimm No
une
condition
s,
including
lupus,
rheumatoi
d arthritis,
celiac
disease,
Grave’s
disease

Blood- No
related
condition
s,
including
anemia,
sickle cell
anemia,
bleeding
disorders

Cancer, No
including
benign
and
malignant
tumors
and
cancers of
the blood

Cardiova Yes Hypertension, High Unknown Unknown

scular Cholesterol
condition
s,
including
hypertensi
on,
coronary
artery
disease,

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congestive
heart
failure,
and
peripheral
vascular
disease

Chronic No
pain
condition
s,
including
fibromyal
gia,
chronic
fatigue
syndrome,
chronic
low back
pain, or
migraines

Diabetes, Yes Type II Unknown Unknown

including
type I,
type II,
pre-
diabetes

Gastroint No
estinal
condition
s,
including
IBS,
peptic
ulcer
disease,
gallbladde
r disease,
ulcerative
colitis,
Crohn’s

Mental No

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condition
s,
including
anxiety,
depression
, bipolar,
schizophre
nia
(Answer
only if
you are
claiming
mental or
emotional
injury
related to
the
product(s
) at issue.)
Respirato No
ry
condition
s,
including
COPD,
emphysem
a, chronic
bronchitis,
asthma,
chronic
cough

10. Surgical History. Please describe all prior surgical procedures you have undergone
in the abdominal, pelvic or inguinal area.

i. Surgery 1:
1. Procedure: Roux-En-Y Gastric Bypass
2. Date: December 01, 2004
3. Name and address of surgeon:
Unknown
Unknown

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4. Name and address of facility:

Kaiser Permanente West Los Angeles Medical Center
66041 Cadillac Ave., Los Angeles CA 90034
5. Condition sought to be treated by procedure:
Obesity
6. Complications [Drop down with ability to select multiple options: none;
post-surgical pain; infection; adhesions; bowel obstruction; reoperation;
other [ability to fill in]]:

ii. Surgery 2:
1. Procedure: Hysterectomy. Left Salpingo-oophorectomy
2. Date: July 10, 2013
3. Name and address of surgeon:
Dr. Elisa Landsowne
Unknown
4. Name and address of facility:
Unknown
Unknown
5. Condition sought to be treated by procedure:
Unknown
6. Complications [Drop down with ability to select multiple options: none;
post-surgical pain; infection; adhesions; bowel obstruction; reoperation;
other [ability to fill in]]:

[IF ADDITIONAL SURGERIES, PLEASE INCLUDE INFORMATION ON SEPARATE

SHEET]

VI. IDENTIFY THE NAME AND ADDRESS OF ANY PHARMACY WHERE

YOU HAVE RECEIVED/FILLED A PRESCRIPTION MEDICATION TWO
YEARS BEFORE YOUR SURGERY INVOLVING THE PRODUCTS
IDENTIFIED IN SECTION III ABOVE TO THE PRESENT:
i. Pharmacy 1
1. Name:TO BE SUPPLEMENTED
2. Address: ,
3. Year: Unknown - Present

VII. DOCUMENT REQUESTS

Please produce any and all documents in your possession or in the possession of
your attorneys that are responsive to the following requests by uploading them
to Crosslink. You should upload any responsive documents separately for each

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requested item, i.e., do not upload the same collective set of documents in
response to each request.

1. A signed copy of each of the records authorization forms (Exhibit A).

2. History and physical, operative note, product identification sticker, and

discharge summary from hospitalization where Covidien product was
implanted.

3. History and physical, operative note and discharge summary from any
removal or revision of the Covidien product.

4. History and physical, operative note and discharge summary from any
hospitalization(s) related to treatment for alleged injury from the Covidien
product.

5. To the extent it has not been produced in response to the requests above, any
other medical record related to treatment for any alleged injury from the
Covidien product.

6. To the extent it has not been produced in response to the requests above, the
history and physical, operative note and discharge summary where any other
hernia mesh was implanted, where applicable.

7. History and physical, operative note and discharge summary from any other
abdominal surgery.

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As counsel for Plaintiff, I certify that after performing a due diligence discussion with the
Plaintiff and review of medical records to secure the answers contained in this PPF, to the best of
my knowledge the answers provided are true and correct as of the date of this PPF.

Counsel Signature: s/ Andrew Cross

Andrew Cross

Carey Danis & Lowe

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I certify that to the best of my knowledge the answers provided are true and correct as of the date
of this PPF.

Signature: /signer_1/

Name: Patrice
/name_1/Allen

Date: /date_1/
10/3/2022

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