It is my professional opinion, to a reasonable degree of medical certainty, that when implanted using the manufacturer’s prescribed method, the anterior and posterior the defendant’s transvaginally placed transverse spanning meshes act in a way to cause unpredictable combinations of pelvic pain, pelvic muscle spasm, pain with sexual intercourse, pain with defecation, difficult bowel evacuation, difficult bladder emptying, paresthesias, tingling, pain, and numbness in the vulva and perineum of women in whom it is implanted, as well as increased likelihood of eventual mesh erosion into the vagina.
Furthermore, in my professional opinion, to a reasonable degree of medical certainty, when the mesh is passed transvaginally into the vaginal clean-contaminated wound, there will inevitably be contamination of the mesh material by bacteria of rectal origin, thereby increasing the risk of an inflammatory immune response, which would cause delayed healing, extrusion, and/or erosion of the mesh material through the vaginal wall, associated with vaginal bleeding and the development of asymmetric, contracted, painful scar tissue associated with the implanted mesh main body and arms.
It is also my professional opinion that, in women who have had pelvic organ prolapse surgery, re-operation rates in women who have undergone transvaginal mesh placement are not lower when compared to abdominal sacrocolpopexy and other types of prolapse surgery and that, once the defendant’s armed mesh devices are implanted, they are almost impossible to entirely remove after erosion of the mesh into the vagina has occurred and removal of some of the mesh may not alleviate clinically significant symptoms.
In my opinion, the disproportionate and asymmetrical scar contracture and “shrinkage” of the defendant’s mesh implants cause vaginal and pelvic pain and result in erosion of the mesh into and through the vaginal wall.