ERRATA TO VERIFIED PETITION FOR PERMISSION TO PRACTICE IN THIS CASE ONLY BY ATTORNEY NOT ADMITTED TO THE BAR OF THIS COURT AND DESIGNATION OF LOCAL COUNSEL (CASEY SHPALL)

JAMES C. MAHAN, District Judge.

Defendants C. R. Bard, Inc. and Bard Peripheral Vascular, Inc. (collectively "Defendants" or "Bard") respectfully request this Court to accept this Errata to the Verified Petition for Permission to Practice in This Case Only by Attorney Not Admitted to the Bar of this Court and Designation of Local Counsel submitted by Casey Shpall, of the law firm Greenberg Traurig LLP and located in Denver, Colorado, as counsel for Defendants.

Ms. Shpall filed her petition to practice pro hac vice ("Petition") on October 4, 2019. [Dkt. 11.] The Court granted the Petition on October 9, 2019. [Dkt. 13.] Defendants respectfully request this Court to replace the Petition originally filed with the Court with the corrected pro hac vice petition attached to this Errata as Attachment 1. The revisions to the Petition include Exhibits B and C to Attachment 1.

This motion is necessary to comply with Local Rule 1A 11-2.

ATTACHMENT 1

EXHIBIT A

EXHIBIT B

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEVADA

Casey Shpall's Concurrently Filed Petitions for Permission to Practice in This Case Only by Attorney Not Admitted to the Bar of This Court

EXHIBIT C

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEVADA

I, CASEY SHPALL, being first duly sworn upon my oath, depose and state as follows:

1. I file this Affidavit pursuant to Local Rule IA 11-2(h)(2). I am an attorney with the law firm of Greenberg Traurig, LLP ("GT"). GT was retained by Defendants. R. Bard, Inc. and Bard Peripheral Vascular, Inc. (collectively "Defendants" or "Bard") to provide them legal representation for the many cases remanded to this District, and hundreds of others remanded in other states, from the Multi-District Litigation proceeding styled In re: Bard IVC Filter Litigation, No. 2:15-MD-02641-DGC, pending before Senior Judge David Campbell of the District of Arizona (the "MDL").

To date, there have been two rounds of remands from the District of Arizona MDL to the District of Nevada. In the first round of remands on August 20, 2019, fourteen (14) cases were remanded to this District. In the second round of remands on October 17, 2019, ten (10) cases were remanded to this District. The above-captioned case was in the first round of remands to this District. See Suggestion of Remand and Transfer Order (Dkt. 3.) More remands are expected in the future.

2. I am a member in good standing of the State Bar of Colorado, where I regularly practice law. I am also admitted to practice before the United States District Court for the District of Colorado, several U.S. Circuit Courts of Appeal, and the U.S. Supreme Court. See Verified Petition, No. 4.

3. I am co-counsel in this action and several of the other MDL remands to this Court with Eric W. Swanis, who is a member of the State Bar of Nevada and a GT shareholder who resides and practices law in Nevada. See Verified Petition, Exhibit B.

4. Due to the number and timing of these remands, I inadvertently neglected to identify in No. 8 of my Verified Petition the other MDL remand cases in which I had previously or simultaneously filed applications to practice pro hac vice before this Court. I have now corrected the Verified Petition to identify all actions in which I have filed applications to appear as counsel under Local Rule IA 1 1-2(b)(7) during the past three years. See Verified Petition, Exhibit B.

5. My firm has extensive experience in medical device products liability actions and represents Bard in remands of IVC filter litigation across the country. I also have had extensive interactions with client representatives concerning the facts underlying this matter and am familiar with the facts and client-specific legal strategies pertinent to this litigation.

6. The granting of my Verified Petition serves the ends of justice by ensuring that the interests of Bard are thoroughly represented by the persons most knowledgeable about the litigation.

7. I therefore submit this Affidavit to establish special circumstances and good cause to permit Bard to be defended in this matter by its counsel of choice. In my judgment, Bard would be deprived of these benefits if I were unable to represent it in this litigation.

8. For all foregoing reasons, there are special circumstances and good cause that warrant the granting of my Verified Petition.

FURTHER YOUR AFFIANT SAYETH NAUGHT.