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`SUPERIOR COURT/CLD
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`J.D. OF WATERBURY
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`AT WATERBURY
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`DECEMBER 29, 2017
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`D. N.: CV-14-6025333-S
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`ROBIN SHERWOOD, et al
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`V.
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`STAMFORD HEALTH SYSTEM, INC.
`D/B/A STAMFORD HOSPITAL
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`DISCLOSURE OF EXPERT WITNESS
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`The Plaintiffs, Robin Sherwood and Greg Hoelscher, in accordance with
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`the provisions of Connecticut Practice Book §13-4, disclose that they expect the
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`following expert witness to testify at the trial of this case:
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`1. Brian J. Hines, M.D., Director of Urogynecology and Reconstructive
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`Surgery, Stamford Hospital, 30 Shelburne Road, Stamford, CT 06904;
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`Stamford Health Medical Group, 292 Long Ridge Rd., Ste. 202, Stamford, CT
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`06902 (formerly Urogynecology and Pelvic Surgery, LLC, Stamford Health
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`Integrated Practices, 1351 Washington Blvd. Stamford, CT 06901). Dr. Hines is
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`board certified in female pelvic medicine and reconstructive surgery. Dr. Hines is
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`expected to testify and offer opinions based on his education, knowledge, training
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`and experience with polypropylene mesh, as well as his treatment of Plaintiff and
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`review of her medical records and scientific and medical literature. Dr. Hines will
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`also testify based upon chart review studies done of his own patients at Stamford
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`Hospital.
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`Dr. Hines will testify regarding the defective and unsafe nature of the Prolift.
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`There was no long term data on the Prolift when Dr. Hines first began implanting the
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`Prolift in 2005. Dr. Hines will testify regarding studies done at Stamford Hospital
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`and authored and published by him regarding polypropylene mesh and that 27% of
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`the women studied developed dyspareunia after implantation of polypropylene
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`mesh.
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`Prolift mesh is made of polypropylene. Dr. Hines will testify that he was
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`trained to use the Prolift polypropylene mesh and tools in 2005 and that he continued
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`to implant the Prolift mesh into approximately 250 women per year until he
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`concluded that the Prolift was not safe to use sometime before May of 2009. Dr.
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`Hines was a paid consultant, instructor and promoter of the Prolift products. Dr.
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`Hines did not advise Ms. Sherwood in 2006 or 2007 that the complications she was
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`having were related to the defective and unsafe Prolift.
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`Dr. Hines published a study in the July/August 2008 edition of the Journal of
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`Pelvic Medicine & Surgery wherein he concluded that the Prolift was safe and
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`effective. Dr. Hines did not disclose in that publication that he was a highly paid
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`promoter and preceptor for Johnson & Johnson and Ethicon. That same study also
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`concluded that, “[d]espite the increased use of grafts, mesh there’s lack of sufficient
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`risk-benefit information.” Dr. Hines then concluded that the Prolift was unsafe for
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`use. In May 2009 Dr. Hines notified Stamford Hospital and every other hospital
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`where he had privileges that he concluded the Prolift was unsafe. Dr. Hines made
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`several phone calls to various hospitals advising them that the Prolift was unsafe, but
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`did not make any effort to reach out to the hundreds of women in whom he
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`implanted the unsafe Prolift. Dr. Hines did not retract or otherwise update his
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`published opinions with his new conclusions that the Prolift was unsafe. Dr. Hines
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`withheld from the public and Ms. Sherwood the fact that the Prolift was unsafe and
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`defective. Dr. Hines continues to keep this information from the public and his
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`patients.
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`This disclosure is intended to supplement, not replace, any previous
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`disclosures of expert witnesses.
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`Plaintiffs reserve the right to call any expert disclosed by any other party
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`and thereafter deposed. Plaintiffs also reserve the right to call additional,
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`undesignated expert witnesses as allowed by law and in particular, any of
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`Plaintiff’s medical providers. Plaintiffs further reserve the right to supplement the
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`above list should another party disclose experts in areas other than those covered
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`by the above individuals.
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`THE PLAINTIFFS,
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`BY: __/s/ Jacqueline E. Fusco
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`Jacqueline E. Fusco, Esq.
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`Tooher Wocl & Leydon, LLC
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`80 Fourth Street
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`Stamford, CT 06905
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`(203) 324-6164
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`Juris No.: 106151
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`CERTIFICATION
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`4
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`This is to certify that a copy of the foregoing was Emailed this date, to all counsel of
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`record.
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`Eric J. Stockman, Esq.
`estockman@stockmanocnnor.com
`Simon I. Allentuch, Esq.
`sallentuch@stockmanoconnor.com
`Stockman O’Connor
`10 Middle Street
`Bridgeport, CT 06604
`Counsel for Defendant Stamford Health
`System Inc. d/b/a Stamford Hospital
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` __/s/ Jacqueline E. Fusco
`Jacqueline E. Fusco, Esq.
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