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` UNITED STATES PATENT AND TRADEMARK OFFICE
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
` CASE IPR2016-00712
` PATENT 8,927,592
`
`* * * * * * * * * * * * * * *
`MYLAN LABORATORIES LIMITED,
` Petitioner,
`v.
`AVENTIS PHARMA S.A.,
` Patent Owner.
`* * * * * * * * * * * * * * *
`
` DEPOSITION OF ALTON OLIVER SARTOR, M.D.
` New Orleans, Louisiana
` Monday, February 13, 2017
`
`Reported by:
`DEBRA AMOS ISBELL, RDR,CRR,RSA,CLR,CCR
`JOB NO. 119445
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`MYLAN - EXHIBIT 1041
`Mylan Laboratories Limited v. Aventis Pharma S.A.
`IPR2016-00712
`
`
`
` UNITED STATES PATENT AND TRADEMARK OFFICE
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
` CASE IPR2016-00712
` PATENT 8,927,592
`
`* * * * * * * * * * * * * * *
`MYLAN LABORATORIES LIMITED,
` Petitioner,
`v.
`AVENTIS PHARMA S.A.,
` Patent Owner.
`* * * * * * * * * * * * * * *
`
` DEPOSITION OF ALTON OLIVER SARTOR, M.D.
` New Orleans, Louisiana
` Monday, February 13, 2017
`
`Reported by:
`DEBRA AMOS ISBELL, RDR,CRR,RSA,CLR,CCR
`JOB NO. 119445
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`MYLAN - EXHIBIT 1041
`Mylan Laboratories Limited v. Aventis Pharma S.A.
`IPR2016-00712
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`Page 2
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` February 13, 2017
` 8:05 a.m.
`
` Deposition of ALTON OLIVER SARTOR, M.D.,
`held at the Hilton, 333 St. Charles
`Avenue, New Orleans, Louisiana, before
`Debra Amos Isbell, a Registered Diplomate
`Reporter, Certified Realtime Reporter, Realtime
`Systems Administrator, Certified Livenote
`Reporter and Certified Court Reporter for the
`State of Louisiana.
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` A P P E A R A N C E S
`
` WILSON SONSINI GOODRICH & ROSATI
` Attorneys for Petitioner
` 701 Fifth Avenue
` Seattle, WA 98104
` BY: JAD MILLS, ESQ.
` STEVE PARMELEE, ESQ.
` MATTHEW REED, ESQ.
`
` FITZPATRICK CELLA HARPER & SCINTO
` Attorneys for the Patent Owner
` 1290 Avenue of the Americas
` New York, NY 10104
` BY: DANIEL MINION, ESQ.
` WHITNEY MEIER, ESQ.
` AND
` SANOFI
` 55 Corporate Drive
` Bridgewater, NJ 08807
` BY: JIAN LIN, ESQ.
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` A. SARTOR, M.D.
` ALTON OLIVER SARTOR, M.D.
` was sworn and testified as follows:
` THE WITNESS: Yes.
` EXAMINATION
`BY MR. MILLS:
` Q. Good morning. Please state your name
`for the record.
` A. Alton Oliver Sartor.
` Q. Dr. Sartor, my name is Jad Mills. I
`represent Mylan Laboratories Limited, the
`petitioner in this matter. It's good to meet
`you, sir.
` A. It's good to meet you.
` Q. Have you been deposed before?
` A. I have.
` Q. So I'm not going to go through all of
`the rules of the deposition. I'll assume that
`you know them. But I do want to just go over a
`couple of matters to make sure that we all
`understand. So I'm going to be asking you
`questions today. Do you understand that?
` A. Uh-huh (positive response).
` Q. And your obligation is to answer my
`questions truthfully.
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` A. SARTOR, M.D.
` A. Of course.
` Q. We need to make sure that we speak one
`person at a time so that the court reporter can
`take down what we say. Do you understand that?
` A. Yes.
` Q. Is there any reason that you cannot
`provide your best answers to my questions today?
` A. I'm not sure I understand the question.
` Q. For instance, if you were feeling ill
`or had to take medication or something like that.
` A. No, no.
` Q. Okay. And I understand that you need
`to complete the deposition today by 4:30 p.m.
`local time; is that correct?
` A. Yeah. I have a 5 p.m. committee, and
`it's one the dean has appointed me to, so I
`better attend.
` Q. And 4:30 p.m. is the time we need to
`stop?
` A. Yeah. If we stop at 4:30, that will
`give me enough time to get in my car and get back
`over there by 5.
` Q. Okay. Dr. Sartor, you have submitted
`several declarations to the patent office on
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` A. SARTOR, M.D.
`behalf of the patent owner of the 592 patent; is
`that correct?
` A. Yes.
` Q. And when I refer to the 592 patent, you
`know what I'm referring to?
` A. Yes.
` Q. What did you do to prepare for your
`deposition today?
` A. I reviewed over the declarations and
`then met with the attorneys on two occasions,
`discussed issues that might arise and had a
`meeting yesterday, as a matter of fact.
` Q. Which declarations did you review in
`preparation for your deposition today?
` A. Well, it was the one that had the Mylan
`Laboratories written on it.
` Q. What's the date of that declaration?
` A. That's a good question.
` Q. Perhaps take a look at the back of the
`declaration.
` A. December 22, 2016.
` Q. Is that the only declaration that you
`reviewed in preparation for this deposition
`today?
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` A. The only way I looked at in any detail.
` Q. Do you recall submitting other
`declarations to the patent office for this
`proceeding?
` A. My memory is that there was one before,
`but then we worked and did a revision which was
`this one and then, of course, there's also the
`federal court in New Jersey for which they were
`separate.
` Q. And you also recall submitting a
`declaration during the prosecution of the 592
`patent; is that correct?
` A. I'm not quite sure the prosecution of.
`I'm not familiar with the prosecution of.
` Q. Let me try and ask the question a
`different way.
` A. Okay.
` Q. After the patenter filed an application
`for the patent --
` A. Right.
` Q. -- but before the patent was issued --
` A. Right.
` Q. -- you submitted a declaration to the
`patent office regarding the 592 patent; is that
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`correct?
` A. Yeah. It's a little bit vague, but
`yes. What I remember vividly is going up to the
`patent office and discussing it with the patent
`officers.
` Q. And when you said "it's a little bit
`vague," you don't mean that the declaration is
`vague; you mean that your memory is vague?
` A. My memory is vague.
` Q. Okay. And is it correct that each of
`these three declarations we've just discussed,
`the December 2016 declaration, the June 2016
`declaration, and the prosecution declaration are
`declarations that you submitted to the patent
`office in support of the patentability of the 592
`patent?
` A. That's my recollection.
` Q. Did you write each of your
`declarations?
` A. I did with help from the attorneys, of
`course. But in the end, I take responsibility
`for the work.
` Q. Are there any errors in any of those
`three declarations?
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` A. SARTOR, M.D.
` A. Not that I'm aware of.
` Q. Do you stand by the testimony that you
`presented in each of those three declarations?
` A. Yes.
` Q. While we're on the topic and just to
`keep the record clear, I'm going to represent to
`you that what I've handed to you are pages from
`Exhibit 1004 filed in this proceeding. If you'll
`take a look at this document and tell me if you
`recognize what it is.
` (Aventis Exhibit 1004, Declaration
` of Dr. Sartor, 7/14/2014, Bates stamped
` 00164 through 00221, marked for
` identification previously.)
` A. Yes. I was checking on the date. This
`goes back to the -- oh, wait. That's my CV that
`has 2014. Help me find the date, if you don't
`mind.
` Oh, here it is. July 14th, 2014, yes.
` Q. And what is this document?
` A. It's a filing of a declaration into the
`patent office for the examiner.
` Q. And whose declaration is this? Who
`signed and wrote this declaration?
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` A. I did, yeah. It seems kind of obvious.
` Q. Right. So this is your prosecution
`declaration; is that right? It's the declaration
`you submitted --
` A. Yes.
` Q. -- during the prosecution of the 592
`patent?
` A. Yes.
` Q. And just for the record, the Bates
`stamps at the bottom of the exhibit are 00164
`through 00221 from Exhibit 1004 in the prior
`proceeding.
` So this is the declaration that you were
`referring to before; correct?
` A. Yes. It's the one that you referred
`to, yes.
` Q. I'm handing you now what's been marked
`as Exhibit 2001 in this proceeding. Do you
`recognize this document?
` A. Yes.
` (Aventis Exhibit 2001, Declaration
` of Dr. Sartor, 6/23/2016, marked for
` identification previously.)
` Q. This is your June 2016 declaration in
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`this proceeding; correct?
` A. I'm trying to find the date. Yes;
`that's correct.
` Q. And then you already have a declaration
`in front of you that you brought with you. Does
`it have an exhibit number at the bottom?
` A. Yes, it does.
` Q. Is it Exhibit 2176?
` A. It is.
` (Aventis Exhibit 2176, Declaration
` of Dr. Sartor, 12/22/2016, Bates
` stamped 00164 through 00221, marked for
` identification previously.)
` Q. And that is your December 2016
`declaration in this proceeding; is that correct?
` A. Correct.
` Q. So these three declarations, Exhibit
`2001, Exhibit 2176, and the excerpts to Exhibit
`1004, those are your three declarations in this
`proceeding; is that correct?
` A. Yes. I didn't check your numbers, but
`I'm assuming you got them right.
` Q. Is it okay if we call those the
`December 2016 declaration, the June 2016
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`declaration, and the prosecution declaration?
` A. Sure.
` MR. MINION: Jad, do you have a copy for
`me?
` MR. MILLS: Yeah. (Complying.)
` Q. And you have already testified you
`stand by your testimony in each of these three
`declarations?
` A. Yes.
` Q. In preparation for your deposition
`today, did you review the Seth declaration?
` A. I did but not recently. But I did
`before, yes.
` Q. In preparation for your deposition
`today, did you review the Seth deposition
`transcript?
` A. I don't recall looking at the
`transcript, no. Only the declaration. Not the
`transcript, to my recollection.
` Q. Do you recall at any point in your
`participation in these proceedings reviewing the
`Seth deposition transcript?
` A. I don't recall that specifically, no.
` Q. In preparation for your deposition
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`today, did you review the institution decision in
`this case?
` A. I'm not sure what you mean.
` Q. I'll ask another question. In
`preparation for your deposition today, did you
`review a decision from the Board, the PTAB board,
`in this proceeding?
` A. No.
` Q. At any point in your participation in
`these proceedings have you reviewed an
`institution decision from the PTAB board in this
`proceeding?
` A. No. And I'm seeking a little
`clarification. Because institution, are you
`referring to the patent office?
` Q. Yes.
` A. Okay. No, I don't recall looking at a
`board decision.
` Q. Is there another decision that you're
`thinking of?
` A. Well, the original patent decision back
`in 2014 after we visited the patent office.
` Q. And when you say --
` A. I remember reviewing that.
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` Q. When you say that, are you referring to
`the 592 patent itself or something different?
` A. Oh, goodness. You know, whether or not
`it had that number, I can't quite recall. I mean
`that's -- I won't say three years ago, but it was
`awhile back.
` Q. Just so that there's no confusion, I'm
`handing you what's marked as Exhibit 1001.
` A. Thank you.
` (Mylan Exhibit 1001, U.S. Patent
` 592, Gupta, 1/6/2015, marked for
` identification previously.)
` Q. Is this the document you were referring
`to a moment ago?
` A. Okay. I'm sorry. And I'm not trying
`to be difficult. I'm trying to make sure I
`understand. The one that I referred to when I
`went to the patent office? Gosh, I don't think
`that's it because it's dated afterwards. But,
`you know, I'm having trouble remembering exactly
`what I reviewed in 2014 and whether or not this
`is the document I reviewed at that time. I'm
`uncertain. But I reviewed this more recently, of
`course.
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` Q. Is it --
` A. But not in detail. That's not -- you
`know, that's --
` Q. Is it your recollection that you
`received a decision from the patent office on the
`day that you visited the patent office for an
`interview regarding the 592 patent?
` A. You know, the decision was not rendered
`at that particular moment. You know, I was asked
`a whole series of questions, and I responded to
`those questions. And then, you know, he took
`notes. And I think later on rendered -- I mean,
`I don't recall that he rendered a decision in my
`presence.
` Q. And when you say that he took notes,
`are you referring to the examiner at the patent
`office?
` A. Yes, the patent officer.
` Q. For the 592 patent?
` A. Excuse me for clarifying. I can't
`remember if it was called the 592 at that time.
`And I mean it may have had a different number, so
`I'm just trying to be precise in my recollection.
`It was the cabazitaxel patent, but I can't
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`remember if it had this number.
` Q. Is it your understanding that the
`interview was for the application that resulted
`in this 592 patent?
` A. Yes, that was my understanding. But
`whether or not it was labeled 592 at that time, I
`don't recall.
` Q. And the examiner for the 592 patent
`asked you a series of questions during the
`interview?
` A. He did.
` Q. Were those questions given to you in
`writing?
` A. I don't think so. I'm trying to
`recollect. It was a verbal discussion. I don't
`recall that he submitted them to me in writing.
` Q. Were you provided with information
`about the questions that you would be asked
`before you entered the interview?
` A. I don't think I was given --
` MR. MINION: Hold on here.
` MR. MILLS: Do you have an objection?
` MR. MINION: I want to be careful here.
`I don't want you to start getting into any
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`privileged conversations he had with his
`attorneys. If you're limiting your questions to
`what was provided to him by the patent office,
`I'm okay with it. But you seem to be stepping
`over the line into what information -- it's just
`not clear from the question.
` MR. MILLS: Let me ask a different
`question.
` Q. Were you provided with information
`originating from the patent office about
`questions that you would be asked before you
`entered the patent office interview?
` A. I don't think so. You know, I think it
`was more of a generic discussion. It wasn't like
`a particular series of questions. But, you know,
`I'm trying to recall precisely. And, of course,
`I'm doing my best to recall accurately. But I'm
`having a little -- I don't think I had any
`correspondence from the patent office on the
`questions other than something generic. But I
`can't remember if that came directly from the
`patent office or if it may have come through the
`attorneys. I'm just -- you know, I mean this
`is -- I don't quite recall. I'm not trying to be
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`difficult, but I'm trying to be honest, of
`course.
` Q. How long was your interview with the
`patent office during the prosecution of the
`application that resulted in the 592?
` A. It was probably a couple of hours.
` Q. Who else was present at the meeting?
` A. There was an attorney from Sanofi --
`no, hired by Sanofi. I don't recall their names.
` Q. Other than the examiner and the
`attorneys hired by Sanofi and yourself, no one
`else was present at the meeting?
` A. No one else that I recall.
` Q. You don't recall the names of any of
`the attorneys that were present at the meeting?
` A. I do not.
` Q. When were you first retained to provide
`services related to the 592 patent that is at
`issue in this proceeding?
` A. My recollection is that I received -- I
`can't remember if it was a call or email, but
`probably sometime in 2014, raising the issue
`about the patent and wondering if I might be
`willing to be involved. And I said yes.
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` Q. Did you -- were you retained at that
`time?
` A. Oh, goodness. I think so, but I don't
`remember exactly.
` Q. Who retained you to provide services
`for the 592 patent?
` A. Well, initially I was talking with one
`group and then later on I talked to another.
` Q. And when you say with one group --
` A. It was attorneys, and I'm trying to
`remember who that -- I'm sorry, I don't remember
`the name of the attorney group at that time.
` Q. So are you referring to outside
`counsel?
` A. I can't remember if it was internal or
`external. I know the lawyers are very important
`to you, but I don't -- it's just not something I
`think about very much.
` Q. Do you have an understanding as to who
`the client was that retained you at that time?
` A. Yes. Sanofi was the one that had the
`issue.
` Q. And when you say "Sanofi," what do you
`mean by Sanofi? What is Sanofi?
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` A. A French pharmaceutical company, one of
`the largest in the world. Sanofi actually is a
`little bit complicated because it's been a
`roll-off between Rhone-Poulenc, between Sanofi,
`between Aventis, and I forget who else they took
`over along the way. So Sanofi today is a
`conglomerate that is comprised of historically a
`number of past entities.
` Q. And is it your testimony that you've
`been retained by Sanofi for the 592 patent since
`sometime in 2014?
` MR. MINION: Objection to form.
` A. I'm trying to remember -- I'm having a
`tough time remembering whether or not -- see, I
`want to help you understand my recollections,
`which are imperfect. I can't recall if it was
`called the 592 patent at that time. It was the
`patent on cabazitaxel. And I was called in
`advance of the meeting with the patent officer,
`and I can't remember if that was Sanofi counsel
`or someone -- or someone else. And when I went
`up there, I think there was a Sanofi
`representative present. I'm just trying to
`remember the names, and I don't recall. And
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` A. SARTOR, M.D.
`that's -- that's the truth. So I don't know what
`to say.
` Q. Do you have an understanding as to who
`was paying the bills for you from that time in
`2014?
` A. I would assume it would be Sanofi.
` Q. So is it correct that Sanofi was paying
`your bills in relation to the 592 patent or the
`application that resulted in the 592 patent since
`at least 2014?
` MR. MINION: Objection to form.
` A. I -- it sounds a little silly. I don't
`actually know who paid me. I'm going to have to
`go back and see if I can figure that out. Was it
`Sanofi? Was it the law firm? Was it -- did the
`law firm -- I mean I would assume that the money
`came in some derivative way from Sanofi, but
`exactly the route, I don't recall.
` I mean if I'm working for you and I
`submit a bill to you and you pass it on, are you
`paying the bill or is someone else paying the
`bill? And I don't always know those
`arrangements. I would assume those are internal
`arrangements. And how you handle expert opinion
`
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`I'm sure varies from firm to firm. And those
`workings, I must admit, I'm not completely sure
`of.
` Q. It was your understanding that the
`ultimate source of the moneys that you were paid
`in relation to the 592 patent from 2014 on was
`Sanofi?
` A. I would anticipate that would be the
`case, yes. I didn't -- I mean I don't -- there
`was not an explicit discussion of that, that I
`recall. And I would assume that's the case. But
`again, you know, under oath as I am now, did I
`absolutely know it was Sanofi? No. I think that
`more likely what I knew was that Sanofi might be
`ultimately responsible. But how the firms
`handled things, I don't quite recall.
` Q. Is it correct that you were not quite
`clear as to who your client was in 2014 in
`relation to the 592 patent?
` A. No. I think it was always the Sanofi
`patent. Yeah. I mean the patent is not an
`issue. It's just the methodology of payment and
`the internal workings of the payment. You know,
`if -- I mean if I'm working for you as an expert
`
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` A. SARTOR, M.D.
`witness -- now, I don't know if you have a
`blanket contract with Mylan or whether or not --
`if you're paying me, is Mylan paying me? I don't
`necessarily know all those arrangements. And I'm
`not honestly quite sure how relevant it is. But
`that's -- I guess that's for you to decide.
` Q. You do have an understanding that you
`were providing consultation services for Sanofi
`in relation to the 592 patent beginning in 2014?
` MR. MINION: Objection to the form.
` A. It's my understanding that Sanofi
`through -- either directly or through its
`intermediaries asked me to opine on the patent of
`cabazitaxel. And whether or not at that time it
`was the 592, whether or not it was an
`intermediary that was paying me -- I'm just
`trying to be accurate. I mean I guess it would
`be easy for me just to say yes, yes. But I think
`the truth is maybe a little more complex than
`that because my memory is not perfect on these
`matters.
` Q. What was your rate of compensation in
`2014 for the matters related to the 592 patent?
` A. Probably 500 an hour, but I don't
`
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`recall exactly.
` Q. And that is still your same rate of
`compensation today in relation to the 592 patent;
`is that correct?
` A. I think so. I'm not very good at that.
` Q. Who has retained you in this
`proceeding?
` A. The -- and, you know, you're probably
`going to kill me, but I can't remember what the
`name of your firm is. The New York firm with a
`representative sitting to my right. And exactly
`their name, I forget. They'll forgive me.
` Q. And they've retained you on behalf of
`the clients; is that correct?
` A. I would certainly assume so. If they
`did otherwise, I would be very surprised.
` Q. And who is the client on whose behalf
`the law firm has retained you in this proceeding?
` A. Well, you know, interesting, I refer to
`it as Sanofi, but it's actually labeled Aventis
`which was a precursor -- it used to be Sanofi
`Aventis, and so -- but it's all the same to me.
`Aventis is Sanofi.
` Q. Thank you. Prior to 2014 had you been
`
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` A. SARTOR, M.D.
`employed by Sanofi as a -- I'm going to withdraw
`that question and start over.
` Just for purposes of clarity, is it
`okay if we just refer to Sanofi one word instead
`of -- when we're talking about Sanofi or Sanofi
`Aventis or Aventis?
` A. Oh, of course.
` Q. Prior to 2014 when you were retained to
`assist with the prosecution of the application
`that resulted in the 592 patent, had you
`previously performed work on behalf of Sanofi?
` A. Yes, as a consultant. And, you know,
`as a medical oncologist as an expert in cancer.
` Q. When did you first perform consulting
`work for Sanofi?
` A. Oh, gosh, I don't remember. I mean
`it's been many years.
` Q. Has it been decades?
` A. I'm trying to remember. 2004 was the
`docetaxel issue. And it probably would have been
`around then. I mean I can't recall precisely.
`But it's probably been over a decade. Certainly
`by 2007, which would be a decade ago, the answer
`would be yes. Decades plural, probably not. I
`
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`don't recall anything with Sanofi in the '90s,
`for instance. But by 2000 -- I would guess it
`would be somewhere around 2005.
` Q. Is it correct that you have been
`consulting for Sanofi on its taxane programs for
`over a decade?
` MR. MINION: Object to the form.
` A. Yes. Well, I'm sorry. Do I -- it's my
`understanding that over a decade is an accurate
`statement. And Sanofi means, of course, the
`precursors to Sanofi.
` Q. You mentioned that you were retained by
`Sanofi as a consultant in relation to docetaxel?
` A. I remember when docetaxel first came
`out. And that would have been 2004. There were
`probably some ad boards that followed that.
`Again, you know, the exact dates, I don't recall.
`But there was lots of hoopla around the
`docetaxel. It was the first agent to prolong
`survival for men with prostate cancer and in
`many's people's mind the first effective
`treatment. So there was a lot of issues and
`meetings that revolved around that.
` Q. Is it your opinion that docetaxel
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`filled a long-felt need for increasing overall
`survival in patients with metastatic
`hormone-resistant prostate cancer?
` A. Absolutely. People have been chasing
`that forever. And that was the first
`demonstration, those back-to-back articles
`with -- SWOG 9916 and TAX 327 were game changers.
` Q. And your consultation with Sanofi
`regarding docetaxel was your first engagement
`with Sanofi?
` A. Yes. I don't recall anything prior to
`that.
` Q. And how long did your engagement with
`Sanofi regarding docetaxel continue?
` A. Oh, gosh, I don't remember exactly.
`But, you know, it kind of morphed into the next
`taxane, which was cabazitaxel. And, you know,
`when the docetaxel stopped and the cabazitaxel
`started, I can't remember. But I would probably
`say that, you know, since 2005, maybe 2004, that
`I've had intermittent contact with Sanofi, during
`that time period.
` Q. You mentioned an engagement with Sanofi
`regarding cabazitaxel; correct?
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` A. Yes.
` Q. When did that start?
` A. Well, gosh. So first of all, it wasn't
`called cabazitaxel. It was called XRP6258. And
`I'm trying to remember. Maybe that was 2006,
`maybe. I'm trying to remember. Thereabouts. I
`mean I'll say it was probably -- it could have
`been late 2005, but I don't remember that. It's
`probably 2006, but I'm not -- you know, I'm not
`swearing on that on a Bible, but that's a good
`way to look at the approximate date.
` Q. Is it fair to say that you have been
`more or less continually consulting for Sanofi on
`its taxane program since approximately 2004?
` MR. MINION: Objection to form.
` A. I personally would choose different
`words. Continuously sort of makes it sound like
`I do it continuously. Most of this has been very
`intermittent. So I would choose to be more
`accurate that intermittently I've been consulting
`with Sanofi since I'm pretty sure -- 2004, I
`can't recall. 2005, I'm pretty sure. 2006 --
`I'm quite confident in 2007 for sure.
` Q. And I understand what you're saying.
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`You actually have a day job; is that correct?
` A. I do. A rather busy one.
` Q. Right. And so when you're talking
`about intermittent, in between the times where
`Sanofi needs you to consult on their taxane
`projects, you're actually trying to prolong
`people's life and comfort; is that --
` MR. MINION: Objection to form.
` A. I try to make people live longer, live
`better. That's an incredibly important part of
`my job.
` Q. And while you've been doing that in
`your day job, in your spare time, even if you're
`not doing work every day for Sanofi, you've been
`onboard as a consultant for them on their taxane
`project?
` MR. MINION: Object to the form.
` A. The onboard nature is -- you know, I'm
`not trying to quibble with words. But typically
`in the early years, it was like: Can you come to
`a meeting? And they would often schedule it,
`say, with ASCO or AUA or something like that. So
`we would just do a meeting. So it wasn't -- I
`would kind of go to a meeting and, you know, come
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`back. I don't even remember phone conferences in
`those days.
` And then when the TROPIC trial started
`to gear up and I was asked to get involved with
`TROPIC, then at that point we ended up having a
`much more sustained relationship rather than a
`intermittent.
` Q. Let me ask it this way: It's never
`surprising to you when they call you up and ask
`you to help out again with one of their taxane
`projects?
` A. It would not surprise me, no. I've
`been working with them a long time.
` Q. If you had to estimate the total amount
`of fees that you've received from Sanofi over the
`last decade plus in relation to their taxane
`projects, what would that estimate be?
` A. You know, it's interesting. I was
`asked to try to get records, and I couldn't find
`them. And I know precisely the fees for last
`year, and that's because I got a 1099. And they
`mixed my consulting with travel, which is a bit
`irritating because, you know, that falls in
`different buckets for me. And the -- I don't
`
`TSG Reporting - Worldwide 87
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