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` UNITED STATES PATENT AND TRADEMARK OFFICE
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
` COALITION FOR AFFORDABLE DRUGS V LLC;
` HAYMAN CREDES MASTER FUND, L.P.;
` HAYMAN ORANGE FUND SPC - PORTFOLIO A;
` HAYMAN CAPITAL MASTER FUND, L.P.;
` HAYMAN OFFSHORE MANAGEMENT, INC.;
` HAYMAN INVESTMENTS, LLC;
` NXN PARTNERS, LLC;
` IP NAVIGATION GROUP, LLC;
` J KYLE BASS, and ERICH SPANGENBERG,
` Petitioners,
` v.
` BIOGEN MA INC.,
` Patent Owner
`
` Case IPR2015-01993
` Patent 8,399,514 B2
`
` DEPOSITION OF SAMUEL J. PLEASURE, M.D., Ph.D.
` Washington, D.C.
` October 20, 2016
`Reported by: Linda S. Kinkade RDR CRR RMR RPR CSR
`Job No. 114306
`
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`Biogen Exhibit 2384
`Coalition v. Biogen
`IPR2015-01993
`
`Page 1 of 71
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`

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`Page 2
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`Page 3
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`A P P E A R A N C E S:
`
`On Behalf of Patent Owner:
` Finnegan, Henderson, Farabow, Garrett
` & Dunner, LLP
` 901 New York Avenue, NW,
` Washington, DC 20001
`
` By: Michael J. Flibbert, Esq.
` Maureen D. Queler, Esq.
`
`On Behalf of Petitioner:
` Carmichael IP, PLLC
` 8000 Towers Crescent Drive
` 13th Floor
` Tysons Corner, Virginia 22182
`
` By: Carol A. Spiegel, Esq.
`
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` SAMUEL J. PLEASURE, M.D., Ph.D.
` October 20, 2016
` 8:56 a.m.
`
` The following is the transcript of the
`deposition of SAMUEL J. PLEASURE, M.D., Ph.D. held
`at the offices of Regus Center, 9711 Washingtonian
`Boulevard, Suite 550, Gaithersburg, Maryland 20878,
`and reported by Linda S. Kinkade, RDR, CRR, RMR,
`RPR, CSR, and Notary Public within and for the
`state of Maryland.
`
`Page 4
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`Page 5
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` E X H I B I T S
`
`NO. DESCRIPTION PAGE
`Exhibit 1001 U.S. Patent No. 8,399,514....... 68
`Exhibit 1003 Sixteenth Meeting of the ....... 136
` European Neurological Society
`Exhibit 1012 Provisional application ........ 101
` 60/888,921
`Exhibit 1045 Declaration of Samuel J. ....... 14
` Pleasure, M.D., Ph.D.
`Exhibit 1046 Curriculum Vitae | Samuel J. ... 54
` Pleasure, M.D., Ph.D.
`Exhibit 1064 Prescribing information for .... 79
` Avonex
`Exhibit 1069 Prescribing information for .... 82
` Rebif
`Exhibit 1070 Prescribing information for .... 84
` Betaseron
`Exhibit 1071 Prescribing information for .... 86
` Copaxone
`Exhibit 1072 Prescribing information for .... 89
` Tysabri
`
`2 (Pages 2 to 5)
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` INDEX OF EXAMINATION
`
`EXAMINATION of SAMUEL J. PLEASURE, MD, PhD PAGE
` BY MR. FLIBBERT 7
` BY MS. SPIEGEL 175
`
`123456
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`Page 2 of 71
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`

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`
` S. PLEASURE
` P R O C E E D I N G S
`
` SAMUEL J. PLEASURE, M.D., Ph.D.,
` having been first duly sworn, was thereafter
` examined and testified as follows:
` EXAMINATION
` BY MR. FLIBBERT:
` Q. Good morning, Dr. Pleasure.
` A. Good morning.
` Q. My name is Mike Flibbert. I'm from the
` Finnegan firm, and I'll be asking you questions today.
` Could you please state your full name for the
` record?
` A. Sure. It's Samuel Pleasure,
` P-L-E-A-S-U-R-E.
` Q. Do you understand that you're under oath
` today?
` A. Yes.
` Q. Do you understand the transcript of your
` testimony will be a public record?
` A. Yes.
` Q. If you don't understand any questions,
` please ask me to repeat, repeat them, and I'll try to
` clarify anything you don't understand. Is that okay?
`
`Page 9
`
` S. PLEASURE
` A. Yes, I understand.
` Q. Have you been deposed before?
` A. Yes, I have.
` Q. On how many times?
` A. I think total this will make six. In
` patent-related things, I think this will make five.
` Q. Okay. And were you testifying as an expert
` in those cases?
` A. Yes.
` Q. In the prior patent cases that you have
` worked on, have you ever testified on behalf of the
` Patent Owner?
` A. No.
` Q. Did you testify at trial in any matter?
` A. Twice.
` Q. And which two cases were those?
` A. There was a case concerning lacosamide in
` federal court in Delaware, and there was a case
` concerning glatiramer acetate in federal court in
` Delaware. I don't remember the case numbers.
` Q. Do you remember the parties in those two
` cases?
` A. Generally.
` Q. Well, in the first case, which party did
`
`3 (Pages 6 to 9)
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`Page 6
`Exhibit 2058 The Lancet | Efficacy and ...... 169
` safety of oral fumarate in
` patients with
` relapsing-remitting MS
`Exhibit 2385 Sam Pleasure, Ph.D., M.D. UCSF . 30
` Medical Center
`Exhibit 2386 Commissural Connections ........ 49
` Glatiramer Acetate three times
` per week
`Exhibit 2387 Scientific Reports | Dimethyl .. 167
` fumarate blocks
` pro-inflammatory cytokine
` production
`
`Page 8
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` S. PLEASURE
` A. Yes.
` Q. As you know, the court reporter is
` transcribing your testimony, so it's important that
` you give verbal answers rather than nodding your head,
` for example. Is that okay?
` A. Yes.
` Q. And I would ask that if you could just wait
` until I finish the question so that we don't talk over
` each other so that the transcript is clear. Is that
` acceptable?
` A. I'll try.
` Q. Me too. If you need a break at any time,
` please just ask. All I would request is that, if
` there is a question pending, that you would wait until
` the question has been answered before we take the
` break, if that's acceptable.
` A. That should be fine.
` Q. Is there any reason that you can't give
` full and truthful testimony today?
` A. No.
` Q. Do you understand that I may ask some
` hypothetical questions because you're testifying as an
` expert witness and that you have to answer those
` questions to the best of your ability?
`
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`Page 3 of 71
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`

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` S. PLEASURE
` you testify on behalf of?
` A. It was a joint defense group and I was
` primarily engaged by Mylan.
` Q. And how about in the second patent case in
` Delaware?
` A. Again, it was a joint defense group, but I
` was engaged by Sandoz, I think Sandoz and Momenta.
` Q. Were you qualified as an expert in those
` cases?
` A. Yes.
` Q. What was your field of expertise that you
` were qualified in?
` A. For the lacosamide case, I was testifying
` concerning epilepsy. I have significant expertise in
` epilepsy during my career, and in addition -- and then
` in the glatiramer acetate case I was qualified as an
` expert on multiple sclerosis.
` Q. In any of the cases in which you have been
` deposed -- well, provided trial testimony, did you
` provide any opinions regarding clinical trial design?
` A. Yes.
` Q. In which case?
` A. Well, I believe it was in both of them. I
` mean, I think it depends a little bit on what you mean
`
`Page 12
`
` S. PLEASURE
` don't believe, but, you know, my recollection is a
` little bit hazy on that just in that I don't recall
` the specific month, for instance, but it wasn't years
` ago.
` Q. Do you recall who contacted you?
` A. Mr. Carmichael contacted me initially.
` Q. Do you know whether you had been contacted
` regarding your availability to provide expert
` testimony as far back as September 2015?
` A. I'd have to refer to my emails to know. I
` don't think it was -- I mean, it was -- I don't think
` it was that long ago, but I'm really not -- I'm really
` not sure.
` Q. Did you ever discuss this case with anyone
` from the Neifeld, that's N-E-I-F-E-L-D, IP law firm?
` MS. SPIEGEL: I'm going to caution you not
` to reveal any privileged attorney-client information;
` otherwise, you may answer yes or no.
` A. I have not.
` Q. Now did you speak with anyone to prepare
` for your deposition today?
` A. Yes.
` Q. With whom did you speak?
` A. With Carol Spiegel.
`
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` S. PLEASURE
` by the -- on what your definition of opinion is. I
` mean, I discussed clinical trials. I discussed the
` design of specific clinical trials. I discussed them
` in a general sense as well. So I think that that's
` what -- that would fit with what you're saying.
` Q. Okay. Have you provided any testimony
` previously involving drug dosage design?
` A. You're going to have to clarify what you
` mean by "design," I think.
` Q. Selection of doses in drug development.
` A. I think that I have, yes. I think I have,
` given your -- in the construction of your question,
` yes, particularly concerning glatiramer acetate and
` also considering concerning -- were you just asking
` about testifying or were you asking also about a
` deposition for that question?
` Q. Well, let's start with trial testimony.
` A. So for glatiramer acetate, both in
` deposition and trial. This was a significant issue of
` discussion.
` Q. When did you first become aware of this IPR
` matter involving Biogen's '514 patent?
` A. I'd have to go back into my emails to know
` exactly. It was not more than a few months ago, I
`
`Page 13
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` S. PLEASURE
` Q. Did you speak with anyone other than
` counsel?
` A. No. I'm just trying to remember if I spoke
` with Mr. Carmichael at some point but not really about
` the deposition per se.
` Q. Did you meet with counsel?
` A. Yes, we met yesterday for some time.
` Q. Do you know for approximately how many
` hours you met yesterday?
` A. Meeting time was probably about four hours.
` Q. Did you review any documents in preparing
` for today's deposition?
` A. Yes, I did.
` Q. What documents did you review?
` A. I reviewed documents that I referred to in
` my -- in my declaration and I have reviewed -- I mean,
` I'm a neurologist who takes care of patients and uses
` Tecfidera. I didn't explicitly look at new things
` concerning that drug for this deposition, but those
` things I've reviewed in the past they certainly would
` inform me. So I don't know whether that would fit the
` criteria of what you're saying, did I review them for
` the deposition. If you mean by reviewing them in the
` last couple of days, then no.
`
`4 (Pages 10 to 13)
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`Page 4 of 71
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` S. PLEASURE
` Q. Did you review any documents that were not
` cited in your declaration?
` A. There may have been one or two other
` articles that I -- that I looked over.
` Q. Do you recall their titles --
` A. Titles ...
` Q. -- or any other information on them?
` A. I did review a publication by Litjens from
` 2004, which is a different publication than the one
` that's cited in my report. It's a different
` pharmacokinetic study.
` Q. Do you know which journal that was
` published in?
` A. I don't recall offhand. I'd have to look.
` Q. You mentioned maybe another article. Do
` you recall anything about that?
` A. I can't think of any others offhand
` actually right now.
` Q. Okay.
` (Exhibit 1045 marked for
` identification: Declaration of Samuel
` J. Pleasure, M.D., Ph.D.)
` Q. Dr. Pleasure, I'm handing you what's been
` previously marked as Coalition Exhibit 1045. Could
`
`Page 16
`
` S. PLEASURE
` for my opinion are included here, though.
` Q. I understand. I'm asking generally about
` any materials you would have reviewed in the course of
` your normal work as a physician or as a professor.
` I'm simply asking for any other materials that you had
` reviewed specifically for purposes of preparing your
` declaration.
` A. Oh, yeah. No, there's nothing else that
` I'm aware of. No, I can't think of anything.
` Q. Did you ask to see any materials to review
` other than those listed in Appendix A?
` A. No.
` Q. In developing your expert testimony in this
` case did you speak with anyone other than counsel?
` A. No. I mean, I've spoken with other
` neurologists in our MS practice about this drug, but
` not having to do with this and not recently.
` Q. I understand. Did you perform any research
` or electronic searches in connection with forming your
` opinions in your declaration?
` A. I'm sure that at some point I did some
` PubMed searching, but I don't recall the search terms
` per se, and that was -- and it's possible that some of
` the documents that I found came through that route,
`
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` S. PLEASURE
` you please confirm this is a copy of the declaration
` that you've provided in this case?
` A. I believe so, yeah.
` Q. Do you have any corrections to the
` declaration that you'd like to make?
` A. I'm not aware of any mistakes at the
` moment. I didn't find any.
` Q. If you would look at paragraph 2 of your
` declaration, please. You state there that you made
` the declaration based on considering the materials
` that you discuss herein; is that correct?
` A. Yes.
` Q. The list of materials that you have relied
` on is in Appendix A of your declaration; is that
` correct?
` A. Yes.
` Q. Is that a complete list of materials that
` you reviewed before completing your declaration?
` A. No, I don't believe so. I mean, I have
` read many other things about Tecfidera, and, as
` paragraph 2 indicates, this is based on my personal
` knowledge. I didn't list everything that I've ever
` read about this drug or about this compound in this
` appendix. The materials that are, I think, necessary
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` S. PLEASURE
` some of the documents that I used, but I don't recall
` explicitly.
` Q. Okay. At any time since you were engaged
` as a consultant have you reviewed any documents or
` information not cited in your declaration to increase
` your knowledge about any topics that are relevant to
` this case?
` A. That's a pretty broad question. I mean, I
` would say that my general level of expertise in this
` area is relevant to this case. That level of
` expertise comes through many, many different sources.
` It doesn't come through attempts to explicitly educate
` myself about something in this particular case and
` those things may inform my opinion.
` So I don't think that's really possible to give
` that a very defined answer. I mean, there are no
` specific sources of other information that I can think
` of.
` Q. Do you know whether the Patent Owner,
` Biogen, submitted any expert declarations in this
` proceeding?
` A. So I think I was provided with a couple of
` those declarations, that I did read at some point, but
` I don't think they necessarily informed my opinions
`
`5 (Pages 14 to 17)
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` S. PLEASURE
` per se. I mean, I was furnished with a couple of
` those by counsel.
` MS. SPIEGEL: Again, I counsel you not to
` reveal any attorney-client privileged information.
` Q. Do you know what declarations Biogen
` submitted?
` A. I don't know which ones Biogen submitted.
` Q. Do you know the substance of Biogen's
` expert declarations?
` A. Well, I've read -- I've read Daniel Wynn's
` expert declaration, as I recall. Sitting here I don't
` recall whether -- the names of any other ones of any
` people that I've read.
` Q. Did you identify Daniel Wynn's declaration
` on your Appendix a, List of Materials Considered?
` A. Well, I don't think that it was
` particularly -- that it was informative for my
` opinion, so it wasn't listed there, I don't think. If
` it was, it would be for completeness.
` Let me take a look. No, did not.
` Q. Can you identify any of the literature
` cited in Biogen's expert declarations?
` A. No, I don't recall what they cited.
` Q. Other than reading Dr. Wynn's declaration,
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` S. PLEASURE
` A. I do not know him personally.
` Q. Have you ever worked with him in any way?
` A. No.
` Q. Do you know Dr. Richard Brundage?
` A. No.
` Q. Are you aware that Dr. Wynn was deposed in
` this matter by counsel?
` A. I presumed so, but I wasn't aware of it and
` I certainly didn't see any account of it or anything.
` Q. Have you reviewed his deposition testimony?
` A. No.
` Q. Do you know if you agree or disagree with
` the testimony that Dr. Wynn provided in his
` deposition?
` MS. SPIEGEL: Asked and answered.
` A. Since I don't know what his -- I didn't see
` his testimony, didn't read it, have any knowledge of
` it. I just presumed that he was deposed since
` witnesses in this would be deposed, but I don't have
` any specific knowledge of it.
` Q. Do you know Dr. Richard Rudick?
` A. I don't know him personally. I've heard
` his name.
` Q. Are you aware that Dr. Rudick submitted a
`
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` S. PLEASURE
` did you review any other Biogen expert declarations?
` A. I don't think that I did.
` Q. Do you know whether you agree or disagree
` with the opinions contained in Biogen's expert
` declarations?
` A. Well, I think the substance of my opinions
` here is what I would go with.
` Q. Can you summarize for me Biogen's expert
` opinions?
` A. I mean, I didn't read them with an attempt
` to sort of internalize what his opinions were or to
` have them inform my opinions. I was, you know, given
` documents by counsel and read them, I mean, at some
` point ago. It wasn't -- I mean, I don't even recall
` when it was really.
` Q. Can you recall any of the opinions that
` Dr. Wynn stated in his declaration?
` A. Well, I believe Dr. Wynn stated opinions
` that were distinct, that were sort of contrary from
` mine, but I don't, you know, I don't recall the
` details of certainly some of the grounds of his
` opinions or things like that. I didn't review it with
` that in mind.
` Q. Do you know Dr. Wynn?
`
`Page 21
`
` S. PLEASURE
` declaration in this matter?
` A. I, sitting here, don't recall whether I
` read a deposition -- a declaration from Dr. Rudick. I
` guess that wouldn't surprise me, but I don't know.
` Q. So you don't know whether or not you
` reviewed Dr. Rudick's declaration?
` A. I don't recall whether I reviewed his
` declaration.
` Q. Do you know whether he was deposed in this
` case?
` A. That I have no idea about.
` Q. It sounds like you did not review his
` deposition testimony, correct?
` A. No. Correct, I did not.
` Q. Do you know Dr. Ronald Thisted?
` A. No.
` Q. Are you aware that Dr. Thisted provided an
` expert declaration in this matter?
` A. No, I don't believe so.
` Q. Have you reviewed his expert testimony?
` A. I don't believe so.
` Q. Have you considered any declaration or
` deposition testimony from Dr. Gilmore O'Neill?
` A. From Dr. Who?
`
`6 (Pages 18 to 21)
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` S. PLEASURE
` Q. Gilmore O'Neill.
` A. No.
` Q. Have you considered any declaration from
` Dr. Katherine, with a K, Dawson?
` A. I don't believe -- I don't recall reading
` anything by that person.
` Q. Did you review the prosecution history of
` the '514 patent?
` A. Not in its full form. I don't think I
` relied on it at all either, and I don't think it
` was -- I don't think it was furnished to me. I
` wouldn't say that I didn't have some portion, that
` some portion of it might have been given to me at some
` point, but I certainly didn't spend time considering
` them, and nor do I rely on that at all for my opinions
` here. Yeah, I think -- no, I don't believe so.
` Q. Are you aware of any other experts who have
` provided testimony on behalf of the petitioner in this
` case?
` A. I know that there was another expert, but I
` don't recall his name, and I am not aware of the, you
` know, didn't review, certainly not in a way that I
` remember any explicit -- anything explicit about that.
` I don't actually recall his name. I was aware at some
`
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` S. PLEASURE
` declaration, and all of the opinions contained in this
` declaration are based on the documents I reviewed, the
` legal principles of which I've been advised, and my
` experience, knowledge and professional judgment.
` That's meant to be -- perhaps it might have been
` better to say all of the opinions contained in this
` declaration are based on documents I reviewed in
` Appendix A, you know, to be more -- for more clarity.
` As I said, I do recall seeing Dr. Wynn's
` testimony -- his declaration, but I didn't rely on his
` declaration for my opinions. And to the extent that,
` you know, at some point early in the course of this I
` might have seen other declarations, I didn't rely on
` them for my opinions.
` Q. Do you know whether you agree or disagree
` with Dr. Linberg's opinions set forth in his
` declaration?
` A. I think that in some substance, in most
` substance I do, I believe, but I'm not a hundred
` percent sure because I didn't review his opinions in
` great detail.
` As I said, I didn't actually recall his, you
` know, if I'd had to come up with his name I wouldn't
` have been able to. And I don't think that -- I'm not
`
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` S. PLEASURE
` point that there was another expert that was involved.
` Q. And his name is Dr. Steven Linberg.
` A. Okay. Yes, that's striking a bell.
` Q. And did you review Dr. Linberg's
` declaration?
` A. You know, it may have been furnished to me
` at some point, but I don't believe I -- I may have
` glanced at it, but I certainly didn't review its main
` substance. I mean, I think that I may have read it
` glancingly at the beginning of this whole proceeding
` without, you know, sort of -- I mean, I was trying to
` come at this with my own thinking.
` Q. Now in paragraph 16 you cite in forming
` your opinions you reviewed the documents listed in
` Appendix A, right?
` A. Yes.
` Q. But it sounds like you may have reviewed,
` potentially reviewed, at least Dr. Wynn's declaration
` in addition, but you're unclear about other
` declarations, whether or not you would have seen them
` or not; is that right?
` A. Well, so, I mean, as it states in paragraph
` 16, in forming my opinions herein I reviewed the
` documents listed in Appendix A attached to my
`
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` S. PLEASURE
` aware of any places where I disagree with his opinions
` per se.
` Q. What were his opinions?
` A. Well, I think the substance of them was
` that there was, you know, that are related in some
` ways to the same issues that I've written in here
` about written description and enablement and
` obviousness, and I -- and I don't -- I certainly
` didn't review the details of the grounds that he gave
` for his opinions because I formed my own opinions, but
` I think that they were in accord.
` Q. Do you know if Dr. Linberg works in the MS
` field?
` A. I don't know Dr. Linberg. I'm not sure. I
` think that Dr. Linberg is not an MS physician to my
` recollection.
` Q. Have you ever spoken with Dr. Linberg?
` A. No.
` Q. Were you aware that Dr. Linberg was deposed
` in this case?
` A. Again, aware is -- if by aware you mean did
` I have specific knowledge, no. I assume -- would have
` assumed that he would have been deposed.
` Q. Did you review his deposition testimony?
`
`7 (Pages 22 to 25)
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` S. PLEASURE
` A. No.
` Q. Did you ask to review his deposition
` testimony or any other deposition testimony?
` A. I never asked for any deposition testimony
` that I recall.
` Q. Are you aware that the petitioner in this
` case submitted a petition to the Patent Office?
` A. I am not -- you know, I at one point or
` another received a couple of documents that were
` things asking for institution and asking for not
` institution of IPR, and I didn't -- you know, there
` were mostly sort of legal, legalese-type documents,
` and I didn't -- you know, if I went through them, it
` was primarily just to familiarize myself with them a
` little bit but not really their substance. I don't
` know -- and so I don't actually know whether one of
` those would have been -- met the definition of what
` you're describing as being a petition.
` Q. Okay. Do you recall whether you agreed or
` disagreed with each statement in the petition?
` A. Certainly not. Because I don't recall -- I
` don't recall specifically reviewing it. I don't know
` whether it was the document that you're speaking of.
` I mean, I didn't rely on any of those for my opinions
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` S. PLEASURE
` filed by the Patent Owner, such as a response?
` A. I mean, I think that at some point perhaps
` a couple of months ago I did review these in the sense
` that I looked through them and, you know, but I
` actually wasn't really, you know, looking at them from
` the perspective of who filed what but more just to
` sort of see what had been -- what the -- what issues
` might have been discussed, not the substances of
` those -- of those documents.
` Q. So is it fair to say you can't summarize
` your understanding of the substantive positions in the
` Patent Owner's response?
` A. I don't think that that's -- I mean, my
` opinions are in my declaration and they're sort of
` limited to those kinds of questions. I mean, I think
` that goes beyond what I was asked to think about by
` counsel.
` Q. Have you ever reviewed the European
` Medicine Agency assessment report on Tecfidera?
` A. I don't believe so.
` Q. Dr. Pleasure, you're currently employed at
` the University of California at San Francisco School
` of Medicine, correct?
` A. Yes.
`
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` S. PLEASURE
` as expressed in my declaration.
` Q. Are you aware that the Patent Office issued
` an institution decision in this case?
` A. I'm aware of that in a general sense. I
` think that's why this is -- this proceeding is going
` on. So in that general sense I was aware of that but
` not too much about the details of that.
` Q. Did you review the institution decision?
` A. Again, I think that this may have been one
` of the documents that I was furnished at some point
` that I looked over, but, you know, if by "reviewed"
` you mean did I read, understand, internalize and use
` that as part of my thinking, that answer is no because
` I would have just sort of superficially glanced at it.
` Q. Do you know whether the Patent Owner
` submitted a Patent Owner's response in this case?
` A. I do not. I'm not aware of that. It may
` well be the case, and, again, it may be one of those
` documents that's in that same folder, but, again, I
` don't know what the, you know, what would meet the
` definition of a response versus a petition. So I'm
` not aware -- that's not where I was spending my time
` thinking about this.
` Q. Do you recall reviewing any paper that was
`
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` S. PLEASURE
` Q. What is your title at UCSF?
` A. Professor and vice chairman of neurology
` and also the Glen W. Johnson Memorial Endowed Chair of
` Neurology, which actually is an endowment for MS
` research.
` Q. What are your responsibilities in that
` role?
` A. Well, I have a variety of responsibilities.
` I run a laboratory that works on questions having to
` do with particularly regeneration and repair in the
` nervous system, including in a variety of pathologic
` situations, including things that might potentially
` lead to regeneration, repair and demyelinate disease
` such as MS.
` I see patients about 20% of my time. I have
` some administrative responsibilities towards creative
` development of young physicians in our department,
` including people who are interested in going into
` clinical or basic laboratory bench research.
` I train students, residents and fellows,
` fellows in the MS Center. I sit on a number of
` committees, research committees, promotion committees,
` facilities committees for deciding who gets how much
` space and where and things like that in the campus
`
`8 (Pages 26 to 29)
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`

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` buildings. I think that is a fair summary.
` Q. Are you currently employed anywhere else?
` A. That depends on your definition. I see
` patients also at San Francisco General Hospital now
` called Zuckerberg San Francisco General Hospital, and,
` however, that is a major affiliate of the University
` of California, San Francisco.
` I am still employed by the university, but
` during the time that I'm at that hospital, at ZSFG, I
` think may be technically working for the department of
` public health, although I'm not paid a salary by them.
` (Exhibit 2385 marked for
` identification: Sam Pleasure, Ph.D.,
` M.D. UCSF Medical Center)
` Q. Dr. Pleasure, I'm handing you what we've
` marked as Exhibit 2385. Do you recognize this
` document?
` A. I recognize -- let's see. So this is
` interesting because I think this is a -- I do
` recognize it in a general sense. I think it's
` actually a web screw-up probably, because as far as I
` know I last was on UCSF's Medical Center listed as an
` epilepsy clinician in 1997.
` I started in 2007, which is when I stopped
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` S. PLEASURE
` actually endeavor to correct it. Because this is
` not -- this must be a new, you know, attempt at an
` update that's not necessarily -- didn't ask me what
` should be there.
` MS. SPIEGEL: And we will object to this on
` the basis of authentication.
` Q. But do you have any basis to testify that
` this is