US Patent and Trademark Office
`_________________________________________
`
`Amneal Pharmaceuticals LLC
`and Par Pharmaceutical, Inc.,
`v.
`Jazz Pharmaceuticals, Inc.,
`
`_________________________________________
`
`Deposition of:
`Barry Gilman
`June 4, 2015
`
`JAZZ EXHIBIT 2033
`Amneal Pharms. et al. (Petitioners) v. Jazz Pharms., Inc. (Patent Owner)
`Case IPR2015-00554
`
`Page 1 of 83
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`_________________________________________
`
`Amneal Pharmaceuticals LLC
`and Par Pharmaceutical, Inc.,
`v.
`Jazz Pharmaceuticals, Inc.,
`
`_________________________________________
`
`Deposition of:
`Barry Gilman
`June 4, 2015
`
`JAZZ EXHIBIT 2033
`Amneal Pharms. et al. (Petitioners) v. Jazz Pharms., Inc. (Patent Owner)
`Case IPR2015-00554
`
`Page 1 of 83
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`
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`US Patent and Trademark Office
`Amneal and Par v. Jazz
`
`FINAL - June 4, 2015
`Barry Gilman
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`--------------------------------------------
`AMNEAL PHARMACEUTICALS LLC
`AND PAR PHARMACEUTICAL, INC.,
`
`Page 1
`
` Petitioners,
`v.
`JAZZ PHARMACEUTICALS, INC.,
`
` Patent Owner.
`
`Case IPR2015-00546
`Patent 7,765,106
`--------------------------------------------
`
`DEPOSITION OF
`Barry Gilman
`June 4, 2015
`New York, New York
`Lead: Evangeline Shih, Esquire
`Firm: Quinn Emanuel
`
`FINAL COPY
`JANE ROSE REPORTING 1-800-825-3341
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`FINAL - June 4, 2015
`Barry Gilman
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`Page 2
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` A P P E A R A N C E S
`
`ATTORNEYS FOR PATENT OWNER
`JAZZ PHARMACEUTICALS, INC.
`
` Evangeline Shih, Esquire
` Frank C. Calvosa, Esquire
` QUINN EMANUEL URQUHART &
` SULLIVAN, LLP
` 51 Madison Avenue, 22nd Floor
` New York, NY 10010
` evangelineshih@quinnemanuel.com
` frankcalvosa@quinnemanuel.com
` Phone: 212.849.7000
`
`ATTORNEYS FOR PETITIONER
`AMNEAL PHARMACEUTICALS LLC
`
` Dennies Varughese, Pharm.D., Esquire
` STERNE KESSLER GOLDSTEIN & FOX
` 1100 New York Avenue, NW, Suite 600
` Washington, DC 20005
` dvarughe@skgj.com
` Phone: 202.371.2600
`
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`Barry Gilman
`
` A P P E A R A N C E S (Continued)
`
`Page 3
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`ATTORNEYS FOR PETITIONER
`PAR PHARMACEUTICAL, INC.
`
` Aziz Burgy, Esquire
` ARENT FOX, LLP
` 1717 K Street, NW
` Washington, DC 20006
` aziz.burgy@arentfox.com
` Phone: 202.857.6378
`
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`US Patent and Trademark Office
`Amneal and Par v. Jazz
`
`FINAL - June 4, 2015
`Barry Gilman
`
` TABLE OF CONTENTS
`
`Witness:
`Barry Gilman
`
`Page 4
`
`Examination
`By Ms. Shih...........................Page 5
`
`Reporter Certification................Page 71
`
`Notice to Read and Sign...............Page 73
`
`Index of Exhibits.....................Page 75
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`Barry Gilman
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`Page 5
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` * * *
` NEW YORK, NEW YORK
` 2:03 p.m.
` * * *
`B A R R Y G I L M A N,
` having been duly sworn, was examined
` and testified as follows:
`EXAMINATION
`BY MS. SHIH:
` Q. Good afternoon.
` A. Good afternoon.
` Q. As I already introduced myself, my
`name is Evangeline Shih and I'm here with
`Frank Calvosa. We represent the patent
`owner, Jazz Pharmaceuticals, and I have some
`questions for you today. It should be very
`short, relatively painless, I would hope.
`Some questions about you, your work, Par and
`your declaration.
` I see you have a document in front
`of you. Is that one of the declarations that
`was submitted with the petitions?
` A. Yes, it is.
` Q. If I could have you tell me which
`one it is so that we are sort of operating on
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`FINAL - June 4, 2015
`Barry Gilman
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`Page 6
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`the same page.
` A. The case number?
` Q. Yes. That would be great.
` A. It is IPR2015-00554.
` Q. 00554. Actually, I think we have
`the case -- the declaration from case IPR
`number 2015-00546. So I think we are going
`to hand those out just so that we are all
`looking at the same document. I think that
`will be helpful.
` My understanding is that the
`declaration that you submitted in each of the
`six petitions is the same declaration; is
`that your understanding as well?
` A. That is my understanding.
` Q. You don't have any markups on your
`copy, do you, notes or markups on your copy?
` A. No. But I do have one correction
`to make.
` Q. Sure. Do you want to go ahead and
`give that to me right now?
` A. Sure. So on paragraph 2 in the
`middle where it lists the two intermediate
`holding companies, the correct title is Sky
`Growth Intermediate Holdings II Corporation.
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`
`FINAL - June 4, 2015
`Barry Gilman
`
`Page 7
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` Q. Okay.
` A. And Sky Growth Intermediate
`Holdings I Corporation.
` Q. And that is the only correction
`that you have to your declaration?
` A. That's right.
` Q. Those are the only two corrections?
` A. Yes.
` Q. Thank you. And I guess I should
`back up a little. If I could have you state
`your full name for the record.
` A. My name is Barry Gilman.
` Q. And then if you could also give an
`address?
` A.
` Q. Who are you employed by?
` A. I am employed on behalf of Par
`Pharmaceutical, Inc.
` Q. Are you employed by any other Par
`entity?
` A. There is a Par entity called Par,
`Inc. -- that's Par, comma, Inc. It may be a
`little confusing because that's how Par
`Pharmaceutical, Inc. was defined here but
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`Amneal and Par v. Jazz
`
`FINAL - June 4, 2015
`Barry Gilman
`
`Page 8
`Par, Inc. is a service provider that provides
`certain corporate administrative services to
`Par Pharmaceutical, Inc.
` Q. Are you also employed by any other
`Par entities other than Par, Inc. and Par
`Pharmaceutical, Inc.?
` A. No.
` Q. Do you -- and what is your job
`title at Par Pharmaceuticals, Inc.?
` A. Just one correction, it's Par
`Pharmaceutical, Inc.
` Q. Okay. Par Pharmaceutical, Inc.
` A. I am deputy general counsel and
`secretary.
` Q. What are your general
`responsibilities as deputy general counsel
`and secretary for -- I guess for ease of --
`sort of ease of the deposition, can we refer
`to Par Pharmaceutical, Inc., as Par, Inc.?
` A. Yes.
` Q. And unless I am referring to Par,
`Inc., I will let -- if I am doing that, I
`will let you know or you let me know. Vice
`versa.
` So I am sorry, what are your
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`Page 9
`
`general responsibilities as deputy general
`counsel and secretary?
` A. As deputy general counsel, I am
`primarily responsible for managing the legal
`department; and as secretary, I am primarily
`responsible for maintaining corporate
`records.
` Q. And what types of corporate records
`would that include?
` A. Minutes. Unanimous written
`consents.
` Q. And who do you report to?
` A. I report to Tom Haughey, Thomas
`Haughey.
` Q. What's Thomas Haughey's position?
` A. He is general counsel and chief
`administrative officer.
` Q. He's general counsel and chief
`administrative officer of Par, Inc.?
` A. Of Par Pharmaceutical, Inc. I'm
`not sure of his title with Par, Inc. I am
`sorry. I was confused.
` Q. Sorry.
` A. Par, Inc., meaning Par
`Pharmaceutical, Inc., yes.
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` Q. Is he -- okay. And is he also
`general counsel for any other Par entity?
` A. Yes.
` Q. Do you know which entities that
`might be?
` A. The parent companies that are cited
`in my declaration at paragraph 2.
` Q. Okay.
` A. And subsidiary companies below the
`Par, Inc. level.
` Q. And are you -- I guess, are you
`authorized to act on behalf of any of the
`subsidiaries such as Par Pharmaceutical
`Companies, Inc.?
` MR. BURGY: Objection. Form.
` A. What do you mean by -- you said
`"subsidiaries," but you said "Par
`Pharmaceutical Companies."
`BY MS. SHIH:
` Q. I apologize. Are you authorized to
`act on behalf of any of the parents that you
`mention in paragraph 2 such as Par
`Pharmaceuticals Companies, Inc. -- Par
`Pharmaceutical Companies, Inc.?
` MR. VARUGHESE: Objection. Form.
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`Page 11
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` A. Authorized in what way?
`BY MS. SHIH:
` Q. In any respect.
` MR. BURGY: Objection. Form.
` MR. VARUGHESE: Same objection.
` A. So just so I am clear, are we
`talking about Par Pharmaceutical Companies,
`Inc.?
`BY MS. SHIH:
` Q. Yes.
` A. I am secretary of Par
`Pharmaceutical Companies, Inc.
` Q. Are you also deputy general counsel
`for Par Pharmaceutical Companies, Inc.?
` A. No.
` Q. But you are secretary for Par
`Pharmaceutical Companies, Inc.?
` A. Yes.
` Q. What are the responsibilities of
`the secretary for Par Pharmaceutical
`Companies, Inc.?
` A. It's primarily maintaining
`corporate records.
` Q. What types of corporate records are
`you referring to in this instance?
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` A. Corporate minutes. Unanimous
`written consents.
` Q. So that was with regard to Par
`Pharmaceutical Companies, Inc. What about
`with regard to Par Pharmaceutical Holdings,
`Inc.?
` MR. VARUGHESE: Objection.
` MR. BURGY: Objection.
` MR. VARUGHESE: Sorry. Go ahead.
`BY MS. SHIH:
` Q. Are you also the secretary for Par
`Pharmaceutical Holdings, Inc.?
` A. I am the secretary for Par
`Pharmaceutical Holdings, Inc.
` Q. Do you also have any other
`responsibilities with respect to Par
`Pharmaceutical Holdings, Inc.?
` A. Not -- no.
` Q. Are you deputy general counsel for
`Par Pharmaceutical Holdings, Inc.?
` A. No. I am not.
` Q. Are you deputy general counsel for
`any of the other parent companies that are
`listed in paragraph 2 of your declaration?
` A. No, I am not.
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` Q. And are you secretary for any of
`the other parent companies that are listed in
`paragraph 2 of your declaration?
` A. Yes.
` Q. Which of those parents are you the
`secretary for?
` A. Sky Growth Intermediate Holdings II
`Corporation and Sky Growth Intermediate
`Holdings I Corporation.
` Q. Are your responsibilities as
`secretary for these parents, the Sky
`Growth parents, also maintaining corporate
`records -- the maintenance of corporate
`records?
` A. Yes.
` Q. Anything else?
` A. No.
` Q. And -- forgive me if I have already
`asked this, but do you have any authority to
`act on behalf of Par Pharmaceutical Holdings,
`Inc.?
` MR. BURGY: Objection. Form.
` MR. VARUGHESE: Objection. Form.
` A. I am not sure what you mean by act
`on behalf of.
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`BY MS. SHIH:
` Q. Are you ever -- are you ever asked
`to advise Par Pharmaceutical Holdings, Inc.?
` MR. BURGY: Objection. Form.
` A. I am -- again, I'm not sure what
`you mean. Advise in what capacity?
`BY MS. SHIH:
` Q. What confuses you about the
`question?
` A. I just am not sure advising in what
`capacity. I am secretary, so on secretarial
`matters, I could be asked to advise.
` Q. What about as a lawyer? Do you
`provide legal advice?
` A. Legal advice to Par Pharmaceutical
`Holdings, Inc.?
` Q. Yes.
` A. No.
` Q. What about to Par Pharmaceutical
`Companies, Inc.?
` A. Do I provide legal advice?
` Q. Yes.
` A. To Par Pharmaceutical Companies,
`Inc.? No.
` Q. What about to any of the other
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`Page 15
`parents that are in your paragraph 2 of your
`declaration?
` MR. BURGY: Objection. Form.
` A. Are you asking if I provide --
`BY MS. SHIH:
` Q. Yes. I apologize.
` A. Provide legal advice, no.
` Q. Have you ever been given power of
`attorney to act on behalf of Par
`Pharmaceutical Companies, Inc.?
` A. I don't recall.
` Q. And what about have you ever been
`given power of attorney to act on behalf of
`Par Pharmaceutical Holdings, Inc.?
` A. I don't recall.
` Q. What about any of the other parents
`that are listed in your paragraph 2 of your
`declaration?
` A. Are you asking if I have been given
`-- the same question?
` Q. Yes.
` A. I don't recall.
` Q. Actually, I am curious. I think we
`talked a little bit earlier and you said that
`you are employed by Par Pharmaceutical, Inc.
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`as well as Par, Inc.
` Do you have a separate -- do you
`have an employment agreement?
` MR. VARUGHESE: Objection. Form.
` MR. BURGY: Objection. Form.
` A. With which entity?
`BY MS. SHIH:
` Q. Let's start with Par
`Pharmaceutical, Inc.
` MR. VARUGHESE: Same objection.
` A. You are asking me if I have an
`employment agreement --
`BY MS. SHIH:
` Q. Yes.
` A. -- with Par Pharmaceutical, Inc.
` I guess I am wondering if this is
`covered by my declaration. I am deputy
`general counsel and secretary of Par
`Pharmaceutical, Inc. I am sorry. You are
`asking if I have a written employment
`agreement or...
` Q. Yes. Do you have a written
`employment agreement?
` MR. VARUGHESE: Same objection.
` A. With?
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`BY MS. SHIH:
` Q. With Par Pharmaceutical, Inc.
` A. With Par Pharmaceutical, Inc., no.
` Q. Do you have a written employment
`agreement with Par, Inc.?
` A. No.
` Q. Do you -- what company issues your
`paycheck?
` A. I feel like that's outside what I
`have attested to here.
` Q. I'm just trying to understand where
`-- I don't think so, but I think that I'm
`just trying to understand your employment.
` MR. VARUGHESE: Objection. Form.
` A. So if there is a question about my
`employment, as I said in my declaration, I am
`deputy general counsel and secretary for Par,
`Inc. I'm not sure what else I can answer.
`BY MS. SHIH:
` Q. Sure. I guess let me do it this
`way.
` Do you have a LinkedIn account?
` A. Yes.
` Q. And in your LinkedIn account, I
`notice that you are -- you've identified
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`Page 18
`yourself as deputy general counsel for Par
`Pharmaceutical Companies, Inc.
` So my understanding from that was
`that your employer is Par Pharmaceutical
`Companies, Inc.?
` MR. BURGY: Objection. Form.
`BY MS. SHIH:
` Q. So I was wondering -- I was sort of
`wondering what your definition of
`"employment" might be?
` MR. BURGY: Objection. Form.
` MR. VARUGHESE: Objection. Outside
` the scope.
` A. I've told you who I worked for.
`That's my definition of "employment."
`BY MS. SHIH:
` Q. But in addition to working for Par
`Pharmaceutical, Inc., I think that you've
`also answered that you work for parent
`company Par Pharmaceutical Companies, Inc.,
`the Sky Growth Companies as well as the Par
`Pharmaceutical Holdings, Inc.?
` MR. BURGY: Objection. Form.
`BY MS. SHIH:
` Q. So I was wondering why you wouldn't
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`say that you're also employed by those
`companies.
` MR. BURGY: Objection. Form.
` A. I think you've maybe misinterpreted
`or misconstrued what I answered as far as my
`role as secretary, which is an officer
`position. That's not an employment position.
`BY MS. SHIH:
` Q. Okay.
` And as an -- so as an officer of
`those companies, it's your view that you are
`not employed by those companies?
` MR. BURGY: Objection. Form.
`BY MS. SHIH:
` Q. Is that a fair understanding of
`what you're trying to tell me?
` MR. BURGY: Same objection.
` A. I guess -- of which companies now,
`because we have talked about them all?
`BY MS. SHIH:
` Q. Sure. Why don't we do this. It
`might make it easier if we talk about them
`separately.
` With regard to Par Pharmaceutical
`Companies, Inc., it is your testimony that
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`Page 20
`you are not employed by that company; is that
`correct?
` MR. BURGY: Objection. Form.
` A. I guess -- I am not an employment
`lawyer so I can't tell you exactly the
`definition or what definition you are looking
`for.
`BY MS. SHIH:
` Q. Okay. Why don't I ask it this way:
`Par Pharmaceutical Companies, Inc., do you
`have a written employment agreement with Par
`Pharmaceutical Companies, Inc.?
` A. No, I don't.
` Q. Do you have any sort of -- as an
`officer of Par Pharmaceutical Companies,
`Inc., do you have a written agreement with
`them?
` MR. BURGY: Objection. Form.
` A. You mean a written employment
`agreement?
`BY MS. SHIH:
` Q. An agreement that you are acting as
`-- acting as an officer of Par Pharmaceutical
`Companies, Inc.
` MR. BURGY: Same objection.
`
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` A. No.
`BY MS. SHIH:
` Q. And as an officer of Par
`Pharmaceutical Companies, Inc., do you -- are
`you compensated by Par Pharmaceutical
`Companies, Inc.?
` MR. BURGY: Objection. Outside the
` scope.
` A. I guess I feel like we are going
`far afield of what's in my declaration.
`BY MS. SHIH:
` Q. Are you refusing to answer the
`question?
` MR. VARUGHESE: Objection. Form.
` A. I don't think it's relevant to my
`declaration.
`BY MS. SHIH:
` Q. Sure. I understand that. But does
`that mean you are not answering the question
`for me?
` MR. VARUGHESE: Same objection?
` A. That's right.
`BY MS. SHIH:
` Q. So you are not going to answer that
`question.
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`JANE ROSE REPORTING
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`
`National Court-Reporting Coverage
`janerose@janerosereporting.com
`
`
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`Barry Gilman
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`Page 22
`
` Let me ask you this:
` Does Par Pharmaceutical Companies,
`Inc., provide you a paycheck?
` MR. VARUGHESE: Objection. Form.
` A. I still think that's beyond the
`scope of what I have attested to.
`BY MS. SHIH:
` Q. So in other words, are you going to
`answer the question?
` A. No.
` Q. Sky Growth Intermediate Holdings II
`Corporation, do you receive a paycheck from
`that company?
` MR. BURGY: Counsel, this is
` starting to get off his declaration. So
` unless you can show where you're going
` with this, I may have to instruct him
` not to answer to preserve the PTAB's
` directive that this deposition be
` limited to the factual issues raised in
` his declaration as articulated in paper
` tabs.
` MS. SHIH: I disagree with you. So
` I am going to continue to ask questions,
` and if you want to object. If you want
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`JANE ROSE REPORTING
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`
`National Court-Reporting Coverage
`janerose@janerosereporting.com
`
`
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`Page 23
`
` to have a standing objection, that's
` fine.
` Why don't we try to make it a
` little bit more efficient, and I can ask
` you with regard to the companies -- with
` regard to all of the companies' parent
` companies that are listed in paragraph
` 2, I think you have already responded
` with respect to Par Pharmaceutical
` Companies. Why don't we jump to Par
` Pharmaceutical Holdings, Inc., and I
` will ask you there, do you receive a
` paycheck from that particular company?
` MR. BURGY: Same objections as
` before.
` A. I think I told you who I work for.
` MS. SHIH: And I think -- Aziz,
` just to be clear, I think the reason why
` it's relevant is because, at the end of
` the day, there are portions of the
` declaration where Mr. Gilman is
` explaining whether certain persons
` involved in the petitions are employed
` by a particular Par entity or not
` employed by a Par entity. So I am
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`
`National Court-Reporting Coverage
`janerose@janerosereporting.com
`
`
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`
` trying to understand better the
` parameters of employment and also
` understanding the -- sort of
` understanding the parameters of what it
` means to be the secretary for Par, Inc.,
` and an officer of one of these
` companies.
` So I think that -- in order to
` understand that better, I need to
` understand issues with regard to
` compensation and what not. For me,
` that's my understanding as far as what
` may determine employment or not
` determine employment.
` MR. BURGY: And I appreciate that,
` and I want to be as reasonable as
` possible here. If you want to ask him
` about the individuals he has listed in
` his declaration and their employment
` status, you are free to do so. I am not
` going to instruct him not answer on
` those, as long as it's within the
` declaration; but as of this time, I
` don't see that you have asked him about
` those individuals. You have asked him
`
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`
`National Court-Reporting Coverage
`janerose@janerosereporting.com
`
`
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`Page 25
`
` about his employment with the Par
` entities, and I have allowed him to
` answer those questions; but it feels
` like you are getting off what Mr. Gilman
` has set out in his declaration.
` So with that caveat, you are more
` than welcome to proceed, but I just want
` to make sure that your questions are
` directed to what he has set forth in his
` declaration. So if you want to ask him
` about individuals and their employment
` status as it relates to his declaration,
` you are more than allowed to do that.
` MS. SHIH: Sure. I am just trying
` to understand because Mr. Gilman has put
` in a declaration. I am trying to
` understand what his position is and sort
` of his responsibilities and his role in
` the company or companies because he
` is -- as I understand it, is speaking on
` behalf of the companies.
` MR. BURGY: And I believe he has
` answered those questions in terms of his
` roles and responsibilities as deputy
` general counsel and secretary, so you
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`
` can proceed.
` MS. SHIH: I think we disagree,
` but...
`BY MS. SHIH:
` Q. And just so that the record is
`clear, Par Pharmaceutical Holdings, Inc., you
`are not going to answer for me whether you
`receive a paycheck from that company?
` A. I have said I am not employed by
`Par Pharmaceutical Holdings, Inc.
` Q. And I understand that, but that's a
`different question.
` Do you receive a paycheck from
`them?
` A. That's correct.
` Q. Are you compensated for your role
`as secretary for Par Pharmaceutical Holdings
`Inc. by that company?
` A. No, I am not.
` Q. Are you compensated at all in your
`role as secretary of Par Pharmaceutical
`Holdings, Inc.?
` A. I am not compensated as secretary.
` Q. And who -- what company pays your
`compensation?
`
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` MR. VARUGHESE: Objection. Form.
` A. Again, I work on behalf of Par
`Pharmaceutical, Inc. and I have explained the
`Par, Inc. relationship that provides
`corporate services, including employment
`services, and that's the entity that I am
`employed by.
`BY MS. SHIH:
` Q. Sure. But what I am trying to
`understand is who is providing you
`compensation, who is issuing your paycheck?
` MR. BURGY: Objection. Form.
` A. It's direct deposit, and I am not
`-- I would have to check.
`BY MS. SHIH:
` Q. I think just to clear up the
`record, you say you don't receive any
`compensation as secretary for Par
`Pharmaceutical Holdings, Inc.
` Do you receive compensation as
`secretary for Par Pharmaceutical, Inc.?
` A. I don't receive separate
`compensation for my role as secretary.
` Q. Do you receive any compensation
`from Par Pharmaceutical Holdings, Inc.?
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`JANE ROSE REPORTING
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`
`National Court-Reporting Coverage
`janerose@janerosereporting.com
`
`
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`
` MR. BURGY: Objection. Form.
` A. I feel like I have answered that
`question.
`BY MS. SHIH:
` Q. I am sorry. Can I have you answer
`it again, please. I forget what --
` A. Could you ask it again.
` Q. Sure. Do you receive any
`compensation from Par Pharmaceutical
`Holdings, Inc.?
` MR. BURGY: Objection. Form.
` A. I think it's outside what I have
`attested to here.
`BY MS. SHIH:
` Q. So you are not going to answer that
`for me?
` MR. BURGY: Counsel, I think,
` again, this is starting to get
` outside of what Mr. Gilman has
` provided a declaration. Unless you
` can explain how this is related, I
` don't see where this is articulated
` in his declaration.
` MS. SHIH: I think I have already
` explained why this is relevant.
`
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`JANE ROSE REPORTING
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`
`National Court-Reporting Coverage
`janerose@janerosereporting.com
`
`
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`BY MS. SHIH:
` Q. So you are not going to give me an
`answer to that question; is that correct?
` A. That's correct.
` Q. Does Par Pharmaceutical Companies,
`Inc., provide you compensation for your role
`as deputy general counsel for Par
`Pharmaceutical, Inc.?
` MR. BURGY: Objection. Form.
` A. I feel like I have answered your
`questions about my employment.
`BY MS. SHIH:
` Q. So you are not going to answer this
`specific question?
` MR. BURGY: I think he has answered
` it.
` A. I feel like I have answered it.
`BY MS. SHIH:
` Q. So does Par Pharmaceutical
`Companies, Inc., provide you compensation for
`your role as deputy general counsel for Par
`Pharmaceutical, Inc.?
` MR. BURGY: Objection. Form.
` A. Again, this seems to be going
`beyond what I have attested to in my
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`
`National Court-Reporting Coverage
`janerose@janerosereporting.com
`
`
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`Am
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