IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`ARGENTUM PHARMACEUTICALS LLC, MYLAN PHARMACEUTICALS
`INC., BRECKENRIDGE PHARMACEUTICAL, INC., AND ALEMBIC
`PHARMACEUTICALS, LTD.,
`Petitioners,
`
`v.
`
`RESEARCH CORPORATION TECHNOLOGIES, INC.,
`Patent Owner.
`
`Case No. IPR2016-002041
`Patent No. RE 38,551
`
`PATENT OWNER’S MOTION FOR OBSERVATIONS
`REGARDING THE CROSS-EXAMINATION
`TESTIMONY OF DR. BINGHE WANG
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`1 Case IPR2016-01101, Case IPR2016-01242, and Case IPR2016-01245 have been
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`joined with this proceeding.
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` DC: 6306456-4
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`
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`ARGENTUM PHARMACEUTICALS LLC, MYLAN PHARMACEUTICALS
`INC., BRECKENRIDGE PHARMACEUTICAL, INC., AND ALEMBIC
`PHARMACEUTICALS, LTD.,
`Petitioners,
`
`v.
`
`RESEARCH CORPORATION TECHNOLOGIES, INC.,
`Patent Owner.
`
`Case No. IPR2016-002041
`Patent No. RE 38,551
`
`PATENT OWNER’S MOTION FOR OBSERVATIONS
`REGARDING THE CROSS-EXAMINATION
`TESTIMONY OF DR. BINGHE WANG
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`1 Case IPR2016-01101, Case IPR2016-01242, and Case IPR2016-01245 have been
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`joined with this proceeding.
`
` DC: 6306456-4
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`
`
`
`
`I.
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`Introduction
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`IPR2016-00204
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`In accordance with: (i) The Trial Practice Guide, Federal Register Vol. 77,
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`No. 157, 48756 at 48767–68 and (ii) the Scheduling Order (Paper 20) as modified
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`by the Joint Notice of Stipulation Concerning Schedule (Paper 50), Patent Owner
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`hereby submits the instant Motion for Observations Regarding the Cross-
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`Examination Testimony of Dr. Binghe Wang, taken on December 10, 2016. The
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`transcript of this testimony has been filed as Exhibit 2194.
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`Patent Owner requests that the Board enter the instant Motion and consider
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`the observations. Observations 1–27 below pertain to the deposition testimony of
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`Dr. Binghe Wang, obtained on December 10, 2016, after Patent Owner filed its last
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`substantive paper. In addition, and in accordance with the Trial Guide, each of
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`observations 1–27 below provides in a single paragraph a concise statement of the
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`relevance of the precisely identified testimony to a precisely identified argument.
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`II. Observations
`1. In Ex. 2194 at 198:7-15, Dr. Wang agreed that the nitrogens in
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`methoxyamino groups were defined by Dr. Kohn in Exhibit 2055 as “basic C alpha
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`amino group[s].” At 198:1-6, Dr. Wang acknowledged that Dr. Kohn expressly
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`taught that “excellent protection against MES-induced seizures by 1 can be
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`achieved by incorporation of a basic C alpha amino substituent.” At 192:9-19
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`(emphasis added), Dr. Wang testified that “having a basic functional group at the
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`1
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`alpha position indeed helped to improve activity.” This testimony is relevant
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`because it contradicts Petitioners’ assertion that a POSA would expect the
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`replacement of -NH- with -CH2- in compound 3l to “maintain[] high potency.” See
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`Petition (“Pet.,” Paper 2) at 46; see also Ex. 1084 ¶ 229 (arguing that a POSA
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`would have been “motivated to improve Compound 3l by modifying the
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`methoxyamino group to the methoxymethyl group”).
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`2. In Ex. 2194 at 151:22-152:16, Dr. Wang confirmed after reviewing his
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`first declaration that it did not discuss the ’301 patent in any paragraphs other than
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`paragraphs 44 to 49 and 123. See also Ex. 1084 ¶ 26 (response declaration citing
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`only those paragraphs). This testimony is relevant to Patent Owner’s position that
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`arguments relating to the ’301 patent as rationale to support Kohn 1991 compound
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`3l are new arguments beyond the scope of a proper reply. Paper 57 at 1-2. This
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`testimony is relevant because none of paragraphs 44 to 49 and 123 in Dr. Wang’s
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`first declaration (Ex. 1002) discusses the ’301 patent disclosing or claiming the
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`methoxyamino compound 3l.
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`3. In Ex. 2194 at 193:21-22, Dr. Wang explained that “the methoxyamino
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`group is different from an amino itself.” This testimony is relevant to Petitioners’
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`argument that “a POSA would utilize the well-known concept of bioisosterism and
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`bioisosteric replacements” and substitute the “secondary amino group (-NH-)” with
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`a “methylene group (-CH2-)” in compound 3l of Kohn 1991. Pet. at 45. This
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`2
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`testimony is also relevant to Patent Owner’s argument that the “bioisosteres” for
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`substitution are not nitrogen and carbon, but rather, methoxyamino and
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`methoxymethyl. See Patent Owner’s Response (“POR,” Paper 35) at 28-30, 35-36.
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`This testimony is relevant because compound 3l includes a methoxyamino group,
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`not an amino group (Pet. at 44; see also Ex. 1012, Table 1), and the Petition
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`addresses only substituting an amino group. See, e.g., Pet. at 45 (“it was well
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`known that a methylene group (-CH2-) is a bioisosteric replacement for a
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`secondary amino group (-NH-)”).
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`4. In Ex. 2194 at 115:17-21, Dr. Wang testified that a compound with a
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`methoxyimino group is “very different” from a compound with a methoxyamino
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`group, even though those functional groups have minor structural differences. At
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`116:13-21, Dr. Wang affirmed that “looking at the differences between functional
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`groups is important.” This testimony is relevant to Petitioners’ argument that “a
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`POSA would utilize the well-known concept of bioisosterism and bioisosteric
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`replacements” and substitute the “secondary amino group (-NH-)” with a
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`“methylene group (-CH2-)” in compound 3l of Kohn 1991. Pet. at 45. This
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`testimony is also relevant to Patent Owner’s argument that the “bioisosteres” for
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`substitution are not nitrogen and carbon, but rather, methoxyamino and
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`methoxymethyl. See POR at 28-30, 35-36. This testimony is relevant because it
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`shows that a POSA would consider the entire functional group when making a
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`3
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`IPR2016-00204
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`bioisosteric change.
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` The entire functional group in compound 3l is a
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`methoxyamino group, not an amino group (Pet. at 44; see also Ex. 1012, Table 1),
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`and the Petition addresses only substituting an amino group. See, e.g., Pet. at 45
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`(“it was well known that a methylene group (-CH2-) is a bioisosteric replacement
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`for a secondary amino group (-NH-)”).
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`5. In Ex. 2194 at 177:5-22, Dr. Wang explained that his predicted “12- to
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`36-fold increase in activity,” described in ¶ 146 of his second declaration, was
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`calculated using the “experimental number” of 8.3 for ED50 of “racemic
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`lacosamide,” which he confirmed was from the ’551 patent itself (id. at 179:3-22)
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`and not available to a person of ordinary skill in the art in 1996 (id. at 182:21-
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`183:4). At 178:3-9, Dr. Wang further testified, “So in doing the calculation, I did
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`not want to use the experimental number as the way to do the calculation, right? …
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`And then I wanted to avoid that particular number.” This testimony is relevant to
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`the expected increase in activity and reasonable expectation of success from the
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`modification of compound 3l. See, e.g., Ex. 1084, ¶¶ 143-147; Pet. at 46; Reply at
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`13; see also POR at 42-43. This testimony is relevant because Dr. Wang admitted
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`that his prediction in ¶ 146 of his second declaration incorrectly relied on data from
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`the ’551 patent itself, which was not in the prior art or known to a POSA.
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`6. In Ex. 2194 at 157:17-158:14, Dr. Wang testified that one would
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`consider ED50’s in the MES test that differ by 23% to be “essentially the same.”
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`This testimony is relevant because it directly contradicts Dr. Wang’s testimony in
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`his response declaration that a 23% lower ED50 showed that an FAA with an
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`unsubstituted benzyl group “had more anticonvulsant activity” than an FAA with a
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`fluorobenzyl group. See Ex. 1084 ¶ 166. This testimony is also relevant because it
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`supports Dr. Roush’s position that FAAs with fluorobenzyl groups “were equally
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`as potent.” See Ex. 2036 (Roush Decl.) ¶ 152.
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` 7. In Ex. 2194 at 164:22-165:4, when asked whether the fluorobenzyl
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`substituents gave “essentially the same” potencies as the unsubstituted benzyl
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`groups, Dr. Wang stated, “So you know, I see what you’re saying. And these
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`differences are small. These differences are small.” At 165:11-13, Dr. Wang
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`testified, “But I completely understand what you’re saying in terms of the small
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`magnitude and how much you want to infer from that.” This testimony is relevant
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`to Petitioners’ argument that a POSA would have recognized an unsubstituted
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`benzyl group as a “preferred” substituent in a lead compound. See Pet. at 16-17,
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`47-48; see also Ex. 1084 ¶¶ 113, 166 (arguing that a POSA would have avoided
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`fluorobenzyl groups). This testimony is relevant because it suggests that Dr. Wang
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`does not disagree with the view that fluorobenzyl substituents gave “essentially the
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`same” potencies as the unsubstituted benzyl groups.
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`8. In Ex. 2194 at 168:16-169:1, Dr. Wang affirmed that Compound 3c from
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`Exhibit 1018, with a fluorobenzyl group and a furan substituent at the α position,
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`5
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`IPR2016-00204
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`had the best protective index of Dr. Kohn’s FAAs. At 169:17-170:3, Dr. Wang
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`affirmed that Compound 3b from Exhibit 1018, also with a fluorobenzyl group and
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`a furan substituent at the α position, had the second best protective index. At
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`170:19-171:10, Dr. Wang affirmed that “compounds 3b and 3c [from Exhibit
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`1018] would be good lead compounds” based on their PI values. This testimony is
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`relevant to Petitioners’ argument that a POSA would have recognized an
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`unsubstituted benzyl group as a “preferred” substituent in a lead compound. See
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`Pet. at 16-17, 47-48; see also Ex. 1084 ¶¶ 113, 166 (arguing that a POSA would
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`have avoided fluorobenzyl groups). This testimony is relevant because it shows
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`that a POSA would have known that the FAAs with the best PI values had
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`fluorobenzyl groups and furan substituents, and the POSA would have sought to
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`optimize these compounds. This testimony is also relevant because it contradicts
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`Dr. Wang’s argument that “there will be no reason to do the [fluorobenzyl]
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`substitutions in order to optimize those [FAA] compounds.” See Ex. 2194 at
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`165:9-10.
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`9. In Ex. 2194 at 204:5-21, Dr. Wang affirmed that (1) the only structural
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`difference between Compounds 1a and 1m in Exhibit 2004 is the presence of a
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`fluorobenzyl group in 1m, and (2) Compounds 1a and 1m “are essentially equal
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`potent.” At 204:22-205:8, Dr. Wang affirmed that Compound 1m had “a better
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`protective index [than 1a].” This testimony is relevant to Petitioners’ argument
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`6
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`that a POSA would have recognized an unsubstituted benzyl group as a “preferred”
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`substituent in a lead compound. See Pet. at 16-17, 47-48; see also Ex. 1084 ¶¶
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`113, 166 (arguing that a POSA would have avoided fluorobenzyl groups). This
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`testimony is relevant because it provides another example of a fluorobenzyl group
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`that maintains the potency of the unsubstituted benzyl compound, while improving
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`the toxicity profile. It is also relevant because it contradicts Dr. Wang’s argument
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`that “there will be no reason to do the [fluorobenzyl] substitutions in order to
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`optimize those [FAA] compounds.” See Ex. 2194 at 165:9-10.
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`10. In Ex. 2194 at 134:1-14, Dr. Wang affirmed that levetiracetam was “a
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`promising functionalized amino acid,” and he testified that levetiracetam “would
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`be one possible lead.” At 128:1-3, Dr. Wang testified that levetiracetam is the (S)
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`enantiomer. This testimony is relevant to Petitioners’ argument that the (S) isomer
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`of FAAs was “inactive.” Reply at 14. This testimony is relevant because it shows
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`that a promising FAA lead possessed an (S) stereocenter, and it thus supports the
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`argument that a POSA would have been motivated to make the (S) enantiomer of
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`an FAA, and not simply the (R) enantiomer.
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`11. In Ex. 2194 at 132:4-11, Dr. Wang affirmed that levetiracetam also
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`“does not have a functionalized oxygen atom two atoms removed from the alpha
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`carbon.” Since levetiracetam was “a promising functionalized amino acid” and a
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`“possible lead,” see ¶ 10 above, this testimony is relevant because it is inconsistent
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`7
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`IPR2016-00204
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`with Petitioners’ argument that “in the most potent analogues, ‘a functionalized
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`oxygen atom existed two atoms removed from the α-carbon atom.’” See Pet. p. 16;
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`see also Ex. 1084 ¶ 245 (“A POSA would have focused primarily on SAR
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`statements and data that repeatedly taught the added benefit of having a
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`‘functionalized heteroatom’ two atoms removed from the α-carbon.”).
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`12. In Ex. 2194 at 130:10-131:5, Dr. Wang also testified that the structure
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`of levetiracetam is different from the general of structure of Dr. Kohn’s FAAs,
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`shown in Figure 1 of Exhibit 1012, and at 154:3-19, he stated that levetiracetam
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`“would not be a lead compound” because he “wouldn’t go across structural
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`classes.” This testimony is relevant because it contradicts Dr. Wang’s testimony
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`that levetiracetam was a promising FAA lead (Ex. 2194 at 134:1-14), and his
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`declaration testimony that levetiracetam is a functionalized amino acid derivative
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`(Ex. 1084 ¶ 59).
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`13. In Ex. 2194 at 145:22-146:19, Dr. Wang affirmed that the racemic
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`compound, ketamine, is a hallucinogen, but its (S) enantiomer is not a
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`hallucinogen. At 146:21-147:2, Dr. Wang also affirmed that the racemic
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`compound, ketamine, is an anesthetic, but its (R) enantiomer is not an anesthetic.
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`This testimony is relevant because it contradicts Dr. Wang’s position that “[a]
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`racemic mixture is not a ‘unique compound,’ or ‘unique molecule.’” See Ex.
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`1084 ¶ 15 (emphasis in original).
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`8
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`IPR2016-00204
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`14. In Ex. 2194 at 47:17-49:21, Dr. Wang acknowledged that Eli Lilly
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`informed Dr. Kohn in a letter (i.e., Ex. 2069) that the α-furan compound
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`LY274959 “caused substantial hepatocellular necrosis, which was the basis for our
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`termination of development.” At 50:20-53:10, Dr. Wang also acknowledged that
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`Eli Lilly informed Patent Owner in a letter (i.e., Ex. 2125) that Lilly terminated its
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`license to Dr. Kohn’s FAA compounds because “we have encountered sever[e]
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`toxicity with Hal Kohn’s anticonvulsant, LY274959.” This testimony is relevant
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`because it contradicts Dr. Wang’s assertion that “Eli Lilly was not clear as to what
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`aspects of those studies caused the company to terminate its license.” See Ex.
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`1084 ¶ 106. This testimony is also relevant because it is inconsistent with Dr.
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`Wang’s statement, “it is inaccurate to assume that Eli Lilly declined to pursue
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`Compound 3l as a lead compound.” See id. at ¶ 105.
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`15. In Ex. 2194 at 50:20-51:15, Dr. Wang testified that “… the toxicity in
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`one particular compound does not impact the develop[]ability of a different one
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`within the same class.” At 232:4-13, Dr. Wang testified “And quite often, toxicity
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`issues are idiosyncratic [] unless you can demonstrate that within the same class,
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`they all have the same type of toxicity.” This testimony is relevant to Petitioners’
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`argument that “Patent Owner’s position assumes that a POSA would expect
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`success based only on actual data for a particular compound.” Reply at 13. This
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`testimony is relevant because it undercuts Petitioners’ argument and Dr. Wang’s
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`9
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`IPR2016-00204
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`assertion that “Even without specific data, a POSA would generally and
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`reasonably expect the compounds [in the ’729 and ’301 patents] to have
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`satisfactory toxicity profiles.” See Ex. 1084 ¶ 98 (emphasis added).
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`16. In Ex. 2194 at 53:15-54:2, Dr. Wang affirmed that the SAR discussion
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`beginning at paragraph 144 of his second declaration lacks citations to his first
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`declaration. This testimony is relevant because these SAR arguments were not
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`included in the portion of Dr. Wang’s first declaration addressing instituted
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`Grounds 3A & 3B. See, e.g., Ex. 1002 § VII.A.2, ¶ 92 (addressing non-instituted
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`Ground 2A).
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`17. In Ex. 2194 at 57:7-16 (Ex. 1084 ¶ 151), 58:13-21 (Ex. 1084 ¶ 152),
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`59:1-13 (Ex. 1084 ¶ 153), 61:5-62:1 (Ex. 1084 ¶ 167, sentence 2), 64:3-16 (Ex.
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`1084 ¶ 167, sentences 3 & 4), 70:15-71:5 (Ex. 1084 ¶ 167, sentence 5), 73:4-19
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`(Ex. 1084 ¶ 167, sentence 6), 115:1-5 (Ex. 1084 ¶ 40), Dr. Wang admitted that his
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`scientific arguments in paragraphs 40, 151, 152, 153 and 167 included no support
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`from the scientific literature. This testimony is relevant to the weight the Board
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`should give to Dr. Wang’s scientific arguments about molecular modeling (¶¶ 151-
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`53) and the alleged negative properties of heteroaromatic groups (¶ 167). See
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`Zimmer Biomet Holdings, Inc. v. Four Mile Bay, LLC, IPR2016-00011, Paper No.
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`8, at 11 (P.T.A.B. Apr. 1, 2016) (“Dr. Harrigan’s opinion in this respect is
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`conclusory and, therefore, unpersuasive.”) (citing Verlander v. Garner, 348 F.3d
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`10
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`IPR2016-00204
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`1335, 1371 (Fed. Cir. 2003)); General Electric Co. v. TAS Energy, Inc., IPR2014-
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`00163, Paper No. 11, at 19 (P.T.A.B. May 13, 2014) (“we note that the Declaration
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`does not disclose sufficiently any underlying facts or data forming the basis for the
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`opinion, and thus we assign little weight to the opinion”) (citing 37 C.F.R. §
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`42.65).
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`18. In Ex. 2194 at 60:1-5, Dr. Wang asserted that a methoxyamino group
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`creates “a significant risk for adverse effects, including toxicity.” This testimony
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`is relevant to Petitioners’ argument that the methoxyamino “Compound 3l had a
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`very favorable protective index, and thus had high potential for treating CNS
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`disorders.” Reply at 9. This testimony is relevant because it undercuts Petitioners’
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`argument, and directly contradicts Dr. Wang’s declaration testimony that
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`“Compound 3l was expected to have an acceptable side effect profile.” See Ex.
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`1084 ¶ 100.
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`19. In Ex. 2194 at 75:14-77:7, Dr. Wang admitted that Dr. Roush was
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`correct when he stated that the enantiomers of compound 3l had not been prepared.
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`Dr. Wang explained that “[i]t’s possible there is a typo …” in his response
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`declaration’s discussion of Dr. Roush’s statement. This testimony is relevant
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`because Dr. Wang abandoned his position that the enantiomers of compound 3l
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`had been prepared. See Ex. 1084 ¶ 88. Dr. Wang’s testimony is also relevant
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`because it confirms Dr. Roush’s position that “[c]hemists consider racemic
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`11
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`IPR2016-00204
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`compounds to be unique compounds as compared to their individual enantiomers.”
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`See Ex. 2036 ¶ 56.
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`20. In Ex. 2194 at 118:22-120:9, Dr. Wang admitted that his first
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`declaration did not argue that levetiracetam satisfied a long-felt need. At 124:17-
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`125:2, Dr. Wang admitted that Dr. Roush did not discuss levetiracetam either.
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`This testimony is relevant to Patent Owner’s position that unmet need arguments
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`based on levetiracetam are new arguments beyond the scope of a proper reply.
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`Paper 57 at 2. This testimony is relevant because these arguments could have
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`been, and should have been, included in the Petition, but instead were presented for
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`the first time with Petitioner’s Reply (Paper 52).
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`21. In Ex. 2194 at 141:11-142:14, Dr. Wang admitted that Exhibit 1155 was
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`published in 2013. This testimony is relevant because Dr. Wang relies on Exhibit
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`1155 to prove the knowledge of a POSA in 1996. See Ex. 1084 ¶¶ 15, 17.
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`22. In Ex. 2194 at 188:13-189:9, Dr. Wang explained that a POSA would
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`have viewed an ED50 of less than 10 mg/kg “as a predictor of in vivo success.” At
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`189:11-19, Dr. Wang testified that 3 compounds in the ’729 patent had potency
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`less than 10 mg/kg, and that the majority of the compounds did not. This
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`testimony is relevant to Petitioners’ argument that the ’729 patent discloses
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`“functionalized amino acids [] having ‘excellent anticonvulsant activity.’” Reply
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`at 5. This testimony is relevant because it undercuts Petitioners’ argument, and
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`12
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`IPR2016-00204
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`contradicts Dr. Wang’s assertion that a POSA would have “reasonably expected
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`compounds within the scope of the … ’729 patent to be effective for CNS
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`disorders.” See Ex. 1084 ¶ 213.
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`23. In Ex. 2194 at 190:9-12, Dr. Wang explained with respect to the
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`compounds in Table 1 of the ’729 patent that “If I look at some of these numbers
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`and I see some aromatic compounds that are -- tend to be low.” This testimony is
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`relevant because it supports Dr. Roush’s position that “compounds with non-
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`aromatic substituents, regardless of their substituted heteroatoms, displayed
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`reduced anticonvulsant activity.” See Ex. 2036 ¶ 175.
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`24. In Ex. 2194 at 205:12-206:6, Dr. Wang agreed that Dr. Kohn concluded
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`“that structural variations at the benzyl and acetate group can modulate the potency
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`and toxicity of the FAA compounds.” This testimony is relevant because it refutes
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`Dr. Wang’s argument that “a POSA would not have focused on modifications at
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`positions other than the α-carbon after considering the prior art.” See Ex. 1084
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`¶ 126.
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`25. In Ex. 2194 at 63:7-20, Dr. Wang admitted that “drugs frequently have
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`heteroaromatic groups in them.” This testimony is relevant because it is
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`inconsistent with Dr. Wang’s argument that a POSA would avoid heteroaromatic
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`groups at the α-position of the FAAs. See Ex. 1084 ¶ 167.
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`IPR2016—00204
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`26.
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`In Ex. 2194 at 68:21—69:7, Dr. Wang admitted that “a ring structure
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`could help to improve solubility or decrease hydrophobicity.
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`This testimony is
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`‘)7
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`relevant because it conflicts with Dr. Wang’s argument that a POSA would avoid
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`aromatic FAAs because “[l]arge aromatic rings increase hydrophobicity beyond
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`acceptable levels.” See Ex. 1084 11 167.
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`27.
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`In Ex. 2194 at 222:16~224:15, Dr. Wang testified that the “predicted
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`racemic lacosamide” ED50 values of 6 to about 19 were calculated using the ED5g
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`values of compound 2d and compound 3k. This testimony is relevant because
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`these predicted values were not
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`included in the portion of Dr. Wang’s first
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`declaration addressing instituted Grounds 3A & 3B. See, e. g., Ex. 1002 § VII.A.2,
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`ll 93 (addressing non—instituted Ground 2A).
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`Date: December 20 2016 Respectfully submitted,
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` Andrea G. Reiste
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`Registration No. 36,253
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`Jennifer L. Robbins
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`Registration No.: 61,163
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`Enrique D. Longton
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`Registration No.: 47,304
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`COVINGTON & BURLING LLP
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`One CityCenter, 850 Tenth Street, NW
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`Washington, DC 20001
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`(202) 662-6000
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`Attorneys for Patent Owner
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`14
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`CERTIFICATE OF SERVICE
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`Pursuant to 37 C.F.R. § 42.6,
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`I hereby certify that on this 20th day of
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`December 2016, the foregoing Patent Owner’s Motion for Observations Regarding
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`the Cross—Examination Testimony of Dr. Binghe Wang was served by electronic
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`mail, by agreement of the parties, on the following counsel of record for
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`petitioners.
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`PETITIONER (IPR2016-00204)
`Matthew J. Dowd (mjdowd@dowdp1lc.com)
`DOWD PLLC
`
`William G. Jenks (wjenks@jenksiplaw.com)
`JENKS IP LAW
`
`PETITIONER (IPR2016—O1101)
`Steven W. Parmelee (sparmelee@wsgr.com)
`Michael T. Rosato (mrosato@wsgr.com)
`Jad A. Mills (jmills@wsgr.com)
`WILSON SONSINI GOODRICH & ROSATI
`
`PETITIONER (IPR2016—O1242)
`Matthew L. Fedowitz (mfedowitz@merchantgould.com)
`Daniel R. Evans (devans@merchantgould.com)
`MERCHANT & GOULD P.C.
`
`PETITIONER (IPR2016-01245)
`Gary J. Speier (gspeier@carlsoncaspers.com)
`Jeffer Ali (jali@carlsoncaspers.com)
`CARLSON, CASPERS, VANDENBURGH, LINDQUIST & SCHUMAN, P.A.
`
`Date: December 20, 2016
`
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`Andrea G. Reis er, Esq.
`Reg. No.2 36,253
`
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