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On or about (b)(6) 2016, plaintiff (b)(6) underwent an insertion of a right internal jugular vein central venous access port of an angiodynamics smartport port catheter product, model number ct96stsd, lot number 4987773.Upon information and belief, this smartport device consisted of a port body and a silicone catheter.The smartport was implanted at (b)(6).On or about (b)(6) 2016, plaintiff presented to (b)(6) hospital in (b)(6) for right arm swelling and discomfort, where she was ultimately diagnosed with right upper extremity deep vein thrombosis ("dvt") caused by her smartport device.Her treaters did not recommend removal of the device at that time, and instead plaintiff was treated by being placed on blood thinners for 6 months.Thereafter, the smartport device remained implanted, and plaintiff did not suffer further problems until on or about (b)(6) 2019, when she presented to lake regional hospital for right chest and neck pain caused by her smart port device, which was occluded and not working properly.Her smartport device was thereafter surgically removed on or about (b)(6) 2019, at (b)(6) hospital.
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