`
` 1 UNITED STATES PATENT AND TRADEMARK OFFICE
` 2 BEFORE THE PATENT TRIAL AND APPEAL BOARD
` 3
`
` 4
`
` 5 - - - - - - - - - - - - - - - - - -X
` AMERIGEN PHARMACEUTICALS LIMITED, :
` 6 ARGENTUM PHARMACEUTICALS LLC, :
` Petitioners :
` 7 :
` VS :
` 8 :
` JANSSEN ONCOLOGY, INC., :
` 9 Patent Owner :
` - - - - - - - - - - - - - - - - - -X
` 10 Case IPR2016-00286
` Patent No. 8,822,438 B2
`
` 11
`
` 12
`
` 13
`
` 14 Videotaped deposition of SCOTT R. SERELS,
` M.D. taken at the offices of Hilton Garden Inn, 560
` 15 Main Avenue, Norwalk, Connecticut, before Clifford
` Edwards, LSR, Connecticut License No. SHR.407, a
` 16 Professional Shorthand Reporter and Notary Public,
` in and for the State of Connecticut on January 21,
` 17 2017, at 9:02 a.m.
` 18
`
` 19
`
` 20
`
` GOLKOW TECHNOLOGIES, INC.
` 21 877.370.3377 ph | 917.591.5672 fax
` deps@golkow.com
`
` 22
`
` 23
`
` 24
`
`Golkow Technologies, Inc.
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`Page 1 (1)
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`JANSSEN EXHIBIT 2127
`Mylan v. Janssen IPR2016-01332
`
`
`
`Scott R. Serels, M.D.
`Page 2
`
` 1 A P P E A R A N C E S:
` 2
`
`ON BEHALF OF THE PETITIONERS, AMERIGEN
` 3 PHARMACEUTICALS LIMITED, ARGENTUM
`PHARMACEUTICALS LLC:
` 4 CHRISTOPHER CASIERI, ESQ.
`MCNEELY, HARE & WAR LLP
` 5 12 Roszel Road, Suite C104
`Princeton, NJ 08540
` 6 609.731.3668
`chris@miplaw.com
`
` 7
` 8
`
`ON BEHALF OF THE PATENT OWNER, JANSSEN ONCOLOGY:
` 9 PAUL J. ZEGGER, ESQ.
`SIDLEY AUSTIN LLP
`10 1501 K STREET, NW
`Washington, DC 20005
`11 202.736.8060
`pzegger@sidley.com
`
`12
`13
`14 ALSO PRESENT: KEVIN MARTH, VIDEOGRAPHER
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
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`Page 4
` 1 will now swear in the witness and we may
` 2 proceed.
` 3
` 4 SCOTT R. SERELS, M.D.
` 5 residing at 12 Elmcrest Terrace, Norwalk,
` 6 Connecticut 06850, having first been duly sworn,
` 7 deposed and testified as follows:
` 8
` 9 DIRECT EXAMINATION
`10
`11 BY MR. ZEGGER:
`12 Q Good morning.
`13 A Good morning.
`14 Q Sir, let me put before you a document
`15 that bears exhibit Amerigen 1095.
`16 And let me ask you whether you recognize
`17 that as your reply declaration in the present IPR
`18 proceeding?
`19 A I do.
`20 Q Now, is that your signature on the first
`21 page?
`22 A It is.
`23 Q When did you actually sign it?
`24 A The date says January 16.
`
`Page 3
` 1 THE VIDEOGRAPHER: Good morning. We
` 2 are now on the record. My name is Kevin
` 3 Marth. I'm the legal videographer today
` 4 representing Golkow Technologies.
` 5 Today's date is January 21, 2017 and
` 6 the time is approximately 9:01 a.m. The
` 7 video deposition today is being held in
` 8 Norwalk, Connecticut in the matter of
` 9 Amerigen Pharmaceuticals Limited,
`10 Argentum Pharmaceuticals LLC vs Janssen
`11 Oncology, Inc. for the United States
`12 Patent and Trademark Office before the
`13 patent trial and appeal board. Our
`14 deponent today is Dr. Scott Serels.
`15 At this time, would counsel please
`16 identify themselves for the record.
`17 MR. ZEGGER: Paul Zegger with Sidley
`18 Austin for the patent owner Janssen
`19 Oncology, Inc.
`20 MR. CASIERI: Chris Casieri of
`21 McNeely, Hare & War representing the
`22 petitioner.
`23 THE VIDEOGRAPHER: Our court
`24 reporter today is Mr. Cliff Edwards who
`
`Page 5
`
` 1 Q Is that when you signed?
` 2 A I believe that was when I signed.
` 3 Q That was this past Monday?
` 4 A Correct.
` 5 Q You signed a previous declaration in this
` 6 IPR back in December of 2015; do you recall that?
` 7 A I -- I do recall signing something
` 8 previously.
` 9 Q And do you recall having your deposition
`10 taken back in August of last year?
`11 A Yes.
`12 Q Could you turn to paragraph four of your
`13 declaration, the reply declaration?
`14 A Yes.
`15 Q Are you there?
`16 A I am.
`17 Q And does that list the materials that you
`18 were asked to review for your reply declaration?
`19 A Yes.
`20 Q Okay. In particular, it's the expert
`21 reports of Dr. Chodak, Dr. Auchus and Dr. Velltura?
`22 A Correct.
`23 Q And also the Amerigen expert declarations
`24 Dr. Doran and Dr. Rutain (phonetic)?
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`Scott R. Serels, M.D.
`Page 6
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` 1 A Correct.
` 2 Q Did you look at any other expert
` 3 declarations?
` 4 A Not that I recall.
` 5 Q Okay. Do you recall being provided the
` 6 patent owner's response brief?
` 7 A Not in specifics, but yes.
` 8 Q Well, is that something you reviewed?
` 9 A I did, yes.
`10 Q You didn't review -- is there any reason
`11 why that's not listed in your list of materials
`12 considered in paragraph four?
`13 A I think this is something that perhaps
`14 was reviewed before this document was completed, so
`15 it wasn't included.
`16 Q I'm sorry, do you know when the patent
`17 owner's response was dated?
`18 A I don't. I don't recall.
`19 Q Okay. That was a brief back in October
`20 of 2016? I'm just trying to find out whether you
`21 recall being provided with that document?
`22 A I believe I was, but I don't recall the
`23 document specifically.
`24 Q Okay. Were you provided a -- an expert
`
`Page 8
` 1 THE VIDEOGRAPHER: Excuse me,
` 2 counsel.
` 3 Doctor, could I can you to scooch
` 4 your microphone up --
` 5 THE WITNESS: Oh, absolutely.
` 6 THE VIDEOGRAPHER: -- just a little
` 7 bit?
` 8 THE WITNESS: Absolutely.
` 9 THE VIDEOGRAPHER: Thank you, sir.
`10 BY MR. ZEGGER:
`11 Q In any event, you weren't, for purposes
`12 of your reply declaration, asked to respond to
`13 Dr. Rettig?
`14 A Correct.
`15 Q Now, in paragraph six of your reply
`16 declaration, you discuss a definition of a person of
`17 ordinary skill in the art or a PHOSITA, for short?
`18 A Correct.
`19 Q And do you agree that a PHOSITA is a
`20 urologist or oncologist with access to
`21 endocrinologist to the extent needed?
`22 A I agree.
`23 Q And do you agree that a urologist is
`24 generally not an expert in endocrinology?
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`Page 7
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`Page 9
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` 1 declaration of a Dr. Rettig?
` 2 A Dr. Rettig? Yes, I do believe I saw a
` 3 document from Dr. Rettig.
` 4 Q Okay. Is there any reason why that
` 5 wasn't listed in your list of materials considered
` 6 in paragraph four of your reply declaration?
` 7 A I thought these were most specific to the
` 8 declaration.
` 9 Q Okay. Do you know who Dr. Rettig is?
`10 A I believe he's a physician, urologist.
`11 But, again, I don't recall the specifics of his
`12 report.
`13 Q Okay. Were you asked to review it
`14 specifically?
`15 A I've seen -- you know, I've a lot of
`16 different papers and different, you know, reports
`17 pertaining to this case. So I recognize the name,
`18 but I don't recognize the -- or remember the -- or
`19 recall the specifics of what he was describing.
`20 Q Did you know that he's a medical
`21 oncologist?
`22 A I knew he was a physician. I wasn't sure
`23 exactly what his title was.
`24 Q Okay.
`
` 1 A Correct.
` 2 MR. CASIERI: Object to form.
` 3 BY MR. ZEGGER:
` 4 Q And do you agree that an oncologist is
` 5 generally not an expert in endocrinology?
` 6 MR. CASIERI: Object to form.
` 7 A Correct.
` 8 BY MR. ZEGGER:
` 9 Q Are you an expert in oncology -- in
`10 endocrinology?
`11 A No.
`12 Q Prior to your work in connection with
`13 this case, had you ever heard of a condition called
`14 CYP17 deficiency?
`15 A Yes.
`16 Q And that was prior to your work in
`17 connection with this case?
`18 A Correct.
`19 Q But in terms of your own work, if you
`20 have the need of expertise in endocrinology, you
`21 would consult a physician that has some expertise in
`22 that area; correct?
`23 A Correct.
`24 Q Now, at the time of your initial
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`Scott R. Serels, M.D.
`Page 10
` 1 declaration, you did not fully consider the various
` 2 mechanisms by which ketoconazole was known to
` 3 inhibit adrenal steroid synthesis beyond inhibiting
` 4 CYP17 enzyme synthesis; correct?
` 5 MR. CASIERI: Object to form.
` 6 A Correct.
` 7 BY MR. ZEGGER:
` 8 Q Okay. And particularly, you were
` 9 focusing on one particular mechanism of action; is
`10 that right?
`11 A As it pertained to abiraterone, which was
`12 the compound that we were most interested in.
`13 Q You agree that ketoconazole has
`14 mechanisms of action other than inhibiting CYP17
`15 enzyme synthesis?
`16 A I do agree.
`17 MR. CASIERI: Object to form.
`18 BY MR. ZEGGER:
`19 Q Now, in defending the approach that you
`20 took in this case, you cite to an article authored
`21 by a Vidal and a Dr. De bono; is that right?
`22 A Correct.
`23 Q Let me show you Amerigen Exhibit 1147.
`24 And is this the article that you relied
`
` 1 it says on the front page.
` 2 Q Okay. Does that refresh any recollection
` 3 that you have as to when you were first provided the
` 4 Vidal paper?
` 5 A You know, I've seen so many papers, I
` 6 don't recall exactly when. But if that's when he
` 7 downloaded it, I -- I really just don't know. I
` 8 mean whether his downloading pertains to when I saw
` 9 the paper, I just don't know.
`10 Q Okay. No, I'm just trying to find out
`11 how many hours or days before you signed your reply
`12 declaration on January 16th, you had the Vidal
`13 paper?
`14 A I'm not sure.
`15 MR. CASIERI: Object to form.
`16 BY MR. ZEGGER:
`17 Q All right. You cite a portion of the
`18 Vidal paper in your reply declaration, paragraph
`19 nine; is that right?
`20 I'm sorry, paragraph eight?
`21 A Correct.
`22 Q Now, is there any indication in the
`23 portion that you cite indicating that ketoconazole
`24 is a CYP17 inhibitor?
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`Page 11
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`Page 13
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` 1 upon?
` 2 A Yes.
` 3 Q When did you first see it?
` 4 A This article? I couldn't specifically
` 5 say.
` 6 Q All right. Do you see at the bottom of
` 7 the cover page there is a notation, "Download by
` 8 Mr. William Hare." And there's a date, "January 12,
` 9 2017."
`10 Do you see that?
`11 A I don't.
`12 It's on the bottom of the first page?
`13 Q The very first page.
`14 A I do.
`15 Q Do you have an understanding as to
`16 whether Mr. William Hare is Amerigen's counsel in
`17 the present IPR?
`18 A He is. I know -- I know Mr. Hare.
`19 Q Okay. And do you see that this indicates
`20 that this particular paper by Vidal was downloaded
`21 by Mr. Hare on January 12th --
`22 A Yes.
`23 Q -- 2017?
`24 A That's what it -- correct. That's what
`
` 1 A Sorry. Can you repeat the --
` 2 Q Sure.
` 3 Is there any portion of the Vidal paper
` 4 that you cite that indicates that ketoconazole is a
` 5 CYP17 inhibitor?
` 6 A Yes. I couldn't exactly find it for you,
` 7 but yes.
` 8 I think that, you know, the purpose was
` 9 that it was describing similarities between it and
`10 the compound that we are most concerned with,
`11 abiraterone, in terms of its mechanism of action,
`12 inhibiting the adrenal gland.
`13 Q Okay. In -- well, let's take it step by
`14 step here.
`15 A Uh-huh.
`16 Q Could you look at paragraph eight of your
`17 reply declaration?
`18 A Sure.
`19 Q Are you there?
`20 A I am.
`21 Q Okay. And the portion that you cite from
`22 the Vidal paper states that both ketoconazole and
`23 abiraterone acetate as treating prostate cancer by
`24 inhibiting adrenal androgen synthesis. And then you
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`Scott R. Serels, M.D.
`Page 14
` 1 quote from Vidal "Through the inhibition of key
` 2 enzymes in the adrenal steroid biosynthesis pathways
` 3 with agents such as ketoconazole or the CYP17
` 4 inhibitor, abiraterone acetate."
` 5 Do you see that?
` 6 A I do.
` 7 Q In the quoted portion that you take from
` 8 Vidal, is there any indication that ketoconazole is
` 9 a CYP17 inhibitor?
`10 A Yes. To my recollection, yes.
`11 Q Well, either the quoted material refers
`12 to ketoconazole as a --
`13 A Uh-huh.
`14 Q -- CYP17 inhibitor or it doesn't.
`15 Right?
`16 A Correct.
`17 Q Okay. Now, that's referring to
`18 abiraterone acetate as a CYP17 inhibitor; correct?
`19 A Correct.
`20 Q Okay. But it doesn't state that
`21 ketoconazole is a CYP17 inhibitor.
`22 Correct?
`23 MR. CASIERI: Object to form.
`24 A You are saying that quote doesn't? I
`
`Page 16
` 1 something being a CYP17 inhibitor is referring to
` 2 the abiraterone acetate not ketoconazole.
` 3 Correct?
` 4 MR. CASIERI: Object to form.
` 5 A I think it's subject to interpretation.
` 6 BY MR. ZEGGER:
` 7 Q Well, do you see any express statement in
` 8 the Vidal paper referring to ketoconazole as a CYP17
` 9 inhibitor?
`10 A It's -- it's more a descriptive of
`11 adrenal inhibition. I'd have to reread the article
`12 to be certain if there's anything specifically
`13 saying, CYP17.
`14 Q Okay. Well, I don't want you to --
`15 A Yup.
`16 Q -- to guess. If you could take some time
`17 looking at the Vidal article --
`18 A Sure.
`19 Q -- that you cite and if you could let us
`20 know whether you find any express statement in that
`21 article that ketoconazole is a CYP17 inhibitor?
`22 A Yeah. I think -- you know, I think what
`23 you quoted what I quoted on page eight of the
`24 article is the inference that ketoconazole inhibits
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`Page 15
`
` 1 mean, it's subject to interpretation.
` 2 And, you know, ketoconazole affects the
` 3 adrenal production, the adrenal glands production
` 4 and CYP17 inhibitors is one of the functions of the
` 5 adrenal gland.
` 6 BY MR. ZEGGER:
` 7 Q Well, my question doesn't go to whether
` 8 ketoconazole --
` 9 A Yup.
`10 Q -- is a CYP17 inhibitor.
`11 A Sure.
`12 Q My question goes to whether Vidal --
`13 A Yes.
`14 Q -- that publication is referring to
`15 ketoconazole as a CYP17 inhibitor.
`16 Do you understand?
`17 A I -- I do. It's a subtle difference.
`18 And I think, you know, that it seems to be fairly
`19 clear from the article that ketoconazole can inhibit
`20 the adrenal gland which would encompass the CYP17
`21 enzymes. So my inference would be that, yes, it
`22 does suggest that ketoconazole would inhibit the
`23 CYP17.
`24 Q Okay. But the only specific reference to
`
`Page 17
` 1 adrenal steroid biosynthesis. And it compares it to
` 2 abiraterone in terms of being a CYP17 inhibitor.
` 3 And I think that's where that quote comes from, the
` 4 specific line within page eight which describes it
` 5 as being this inhibitor of biosynthesis and it
` 6 compares it to abiraterone.
` 7 Q Okay. So is there any express statement
` 8 in the Vidal paper that ketoconazole is a CYP17
` 9 inhibitor?
`10 MR. CASIERI: Object to form.
`11 A Yeah. Other than the quote that states
`12 it comparing it to the other CYP17 inhibitor, there
`13 isn't. But that's where the quote comes from, their
`14 direct description.
`15 BY MR. ZEGGER:
`16 Q Now, could you look at paragraph nine of
`17 your declaration?
`18 A Sure.
`19 Q And there you refer to a rebuttal opinion
`20 of Dr. Doran?
`21 A Uh-huh.
`22 Q That's Amerigen's expert?
`23 A Uh-huh.
`24 Q Now, Dr. Doran's field is endocrinology.
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`Scott R. Serels, M.D.
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` 1 Is that right?
` 2 A Uh-huh. That's correct.
` 3 Q And I think you said you are not an
` 4 endocrinologist?
` 5 A That's correct.
` 6 Q And that's not your field?
` 7 MR. CASIERI: Object to form.
` 8 BY MR. ZEGGER:
` 9 Q That's not your field?
`10 A Correct.
`11 Q So the views that you are expressing in
`12 paragraph nine of your rebuttal report are those of
`13 Dr. Doran's, not independent views that you came up
`14 with.
`15 Is that right?
`16 A Well, I think it's a combination. I
`17 think, you know, that paragraph specifically talks
`18 about abiraterone and the impact it would have on
`19 ACTH and adrenal function, which is something I do
`20 understand. I think his depth of knowledge, being
`21 an endocrinologist, is going to be -- he's going to
`22 have a greater breadth of knowledge in that
`23 particular area.
`24 Q So in that respect you would defer to
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`Page 20
` 1 conclusion that he stated in a paper that he had
` 2 with Gerber?
` 3 A Correct.
` 4 Q And you quote from that. And you state
` 5 that according to Dr. Chodak, the conclusion in that
` 6 Gerber paper stated, "There appears to be a small
` 7 subgroup of patients who will derive significant
` 8 benefit from the combination of ketoconazole and
` 9 glucocorticoid replacement therapy."
`10 Is that right?
`11 A Correct.
`12 Q Now, you compare that conclusion with
`13 some of the statements that Dr. Chodak made
`14 subsequently?
`15 A Correct.
`16 Q And one of the comparisons that you did
`17 appears in paragraph 14 of your report where you
`18 compare Dr. Chodak's 1990 conclusion with that of in
`19 a 1992 response to a letter?
`20 MR. CASIERI: Object to form.
`21 A Correct.
`22 BY MR. ZEGGER:
`23 Q And you quote from the 1992 statement.
`24 Correct?
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`Page 19
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`Page 21
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` 1 Dr. Doran on issues of endocrinology?
` 2 MR. CASIERI: Object to form.
` 3 A Any -- yeah. Any detailed issues of
` 4 endocrinology, absolutely.
` 5 BY MR. ZEGGER:
` 6 Q Now, could you turn to section four of
` 7 your reply declaration?
` 8 A I'm getting there.
` 9 Okay. I'm here.
`10 Q Okay. In that section, you talk about
`11 some of Dr. Chodak's papers.
`12 Is that right?
`13 A Section four is --
`14 Q I'm sorry. Section three.
`15 A Section three. Okay.
`16 Q I misspoke. Section three starting on
`17 page seven --
`18 A Yes.
`19 Q -- of your reply declaration?
`20 A Yes.
`21 Q And there you talk about some of
`22 Dr. Chodak's publications?
`23 A Correct. That would be --
`24 Q In paragraph 11, you remark about the
`
` 1 A I do.
` 2 Q And the quote in the 1992 statement
` 3 states, "The observations by others as
` 4 well as our own findings suggest that more
` 5 investigation with ketoconazole or its analog
` 6 appears to be warranted since the drug does not --
` 7 does appear to have some clinical benefit in these
` 8 patients, in addition to its effect on serum PSA."
` 9 Is that what you are relying upon?
`10 MR. CASIERI: Object to form.
`11 A Yes.
`12 BY MR. ZEGGER:
`13 Q Now, in the 1992 response letter that you
`14 rely upon, Dr. Chodak states that there is "some
`15 clinical benefit to using ketoconazole."
`16 Correct?
`17 A Ketoconazole and prednisone, correct.
`18 Q Well, does he say anything about
`19 prednisone in the 1992 response letter?
`20 A Well, the article is based on using
`21 ketoconazole and prednisone.
`22 Q Okay.
`23 A So if he's commenting in the article,
`24 it's the two in combination.
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` 1 Q Okay. But he didn't say anything
` 2 specifically in 1992 about prednisone; right?
` 3 MR. CASIERI: Object to form.
` 4 A He's just commented on his original
` 5 conclusions.
` 6 BY MR. ZEGGER:
` 7 Q Okay. And on commenting on the original
` 8 conclusions, he's saying in 1992 that there was some
` 9 clinical benefit to using ketoconazole.
`10 Correct?
`11 MR. CASIERI: Object to form.
`12 A Yes.
`13 BY MR. ZEGGER:
`14 Q Okay. So he's backing away from the
`15 original language, where in 1990 he's said there was
`16 a significant benefit.
`17 Correct?
`18 MR. CASIERI: Object to form.
`19 A I think he's really reinforcing what he
`20 found in 1990.
`21 BY MR. ZEGGER:
`22 Q Well, the language he's using in 1992 is
`23 not the same language that he used in his original
`24 1990 paper.
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`Page 23
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` 1 Correct?
` 2 MR. CASIERI: Object to form.
` 3 A You know, I think very few people use the
` 4 same language when they are asked the same question
` 5 at different times, but what he he's saying is the
` 6 same.
` 7 BY MR. ZEGGER:
` 8 Q All right.
` 9 A He's supporting his conclusions. The
`10 original article, if I may digress, was by Chodak
`11 and Gerber in 1990. And in that article, he did a
`12 study comparing or looking at patients treated with
`13 prednisone and ketoconazole in the treatment of
`14 prostate cancer. And his conclusions were that the
`15 two, in combination, were beneficial to patients
`16 being treated for prostate cancer.
`17 There was, in 1992 --
`18 Q Well, sir, I'm just asking you to
`19 compare --
`20 A No. I understand.
`21 Q -- the language --
`22 A I understand.
`23 Q -- significant benefit to some benefit in
`24 the two --
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`Page 24
` 1 A Well -- but I think the context of where
` 2 it occurs makes some sense in this situation.
` 3 Q No, I have to ask you -- I have to ask
` 4 you to answer the questions that' I'm posing.
` 5 MR. CASIERI: He is answering your
` 6 question.
` 7 MR. ZEGGER: I'm asking whether the
` 8 language was the same or not.
` 9 MR. CASIERI: What language?
`10 MR. ZEGGER: And that was all.
`11 MR. CASIERI: He's answering your
`12 question.
`13 MR. ZEGGER: The words,
`14 significant --
`15 BY MR. ZEGGER:
`16 Q Sir --
`17 MR. CASIERI: If you don't like the
`18 answer, that doesn't mean you can
`19 interrupt him.
`20 BY MR. ZEGGER:
`21 Q Sir, the words "significant benefit" do
`22 not appear in his 1992 response letter.
`23 Correct?
`24 A I think it's gets confusing because he
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`Page 25
` 1 writes an article, and then someone makes a letter
` 2 to the editor inquiring about the article where the
` 3 author is allowed to describe his findings, and he
` 4 can either support them or discount them.
` 5 In this case, his statements although
` 6 they are not identical, are supportive of his
` 7 original conclusion.
` 8 Q Okay. The words "significant benefit" do
` 9 not appear in his 1992 letter.
`10 Correct?
`11 MR. CASIERI: Object to form.
`12 A I think it's ir- -- I mean, personally I
`13 think -- all I can say for you as a physician who
`14 reads the literature, that when I read his rebuttal
`15 to the letter to the editor, he seems to imply that
`16 he strongly supports what he's done in his original
`17 research.
`18 BY MR. ZEGGER:
`19 Q Okay. And he's reiterating in 1992 that
`20 there still needs to be more investigation.
`21 Correct?
`22 A Correct.
`23 Q Okay. In fact, in 2004 he continues to
`24 say there needs to be more investigation.
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`Page 26
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`Page 28
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` 1 Correct?
` 2 MR. CASIERI: Object to form.
` 3 A Yes.
` 4 BY MR. ZEGGER:
` 5 Q So 14 years after Chodak's original 1990
` 6 article, he's still saying to the scientific
` 7 community, We need more investigations.
` 8 Correct?
` 9 MR. CASIERI: Object to form.
`10 A Yeah. I think in general, when you look
`11 at prostate cancer, we need more investigations for
`12 most things that we do. And yes, this is certainly
`13 one of those things that we do that needs to, as
`14 everything else, until we have a perfect solution to
`15 prostate cancer, we should investigate everything as
`16 thoroughly as we can.
`17 BY MR. ZEGGER:
`18 Q Okay. And in the 2004 article of Chodak,
`19 he doesn't say that there's a significant benefit to
`20 ketoconazole.
`21 Correct?
`22 MR. CASIERI: Object to form.
`23 A He doesn't use those exact terms.
`24 MR. ZEGGER: Okay. No further
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` 1 INDEX OF EXAMINATION
` 2 PAGE
` 3 DIRECT EXAMINATION BY MR. ZEGGER 4
` 4
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`Page 27
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`Page 29
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` 1 questions.
` 2 MR. CASIERI: That's it?
` 3 MR. ZEGGER: Yeah.
` 4 MR. CASIERI: No questions.
` 5 MR. ZEGGER: Okay.
` 6 THE VIDEOGRAPHER: This concludes
` 7 the deposition. We are going off the
` 8 record at 9:25 a.m.
` 9 (Thereupon, the deposition was
`10 concluded at 9:26 a.m.)
`11
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` 1 C E R T I F I C A T E
` 2 I hereby certify that I am a Notary Public,
` 3 in and for the State of Connecticut, duly
` 4 commissioned and qualified to administer oaths.
` 5 I further certify that the deponent named in
` 6 the foregoing deposition was by me duly sworn, and
` 7 thereupon testified as appears in the foregoing
` 8 deposition; that said deposition was taken by me
` 9 stenographically in the presence of counsel and
`10 reduced to typewriting under my direction, and the
`11 foregoing is a true and accurate transcript of the
`12 testimony.
`13 I further certify that I am neither of
`14 counsel nor attorney to either of the parties to
`15 said suit, nor am I an employee of either party to
`16 said suit, nor of either counsel in said suit, nor
`17 am I interested in the outcome of said cause.
`18 Witness my hand and seal as Notary Public
`19 this _________ day of ____________________ , 2017.
`20
`21 _______________________________
`22 Clifford Edwards
`23 Notary Public
`24 My commission expires: 9/30/2021
`
`Golkow Technologies, Inc.
`
`Page 8 (26 - 29)
`
`
`
`Scott R. Serels, M.D.
`Page 30
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` 1 - - - - - -
` E R R A T A
` 2 - - - - - -
` 3
` 4 PAGE LINE CHANGE
` 5 ____ ____ ____________________________
` 6 REASON: ____________________________
` 7 ____ ____ ____________________________
` 8 REASON: ____________________________
` 9 ____ ____ ____________________________
`10 REASON: ____________________________
`11 ____ ____ ____________________________
`12 REASON: ____________________________
`13 ____ ____ ____________________________
`14 REASON: ____________________________
`15 ____ ____ ____________________________
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`17 ____ ____ ____________________________
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`22 REASON: ____________________________
`23 ____ ____ ____________________________
`24 REASON: ____________________________
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`Page 31
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` 1
` 2 ACKNOWLEDGMENT OF DEPONENT
` 3
` 4 I,_____________________, do
` 5 hereby certify that I have read the
` 6 foregoing pages, and that the same is
` 7 a correct transcription of the answers
` 8 given by me to the questions therein
` 9 propounded, except for the corrections or
`10 changes in form or substance, if any,
`11 noted in the attached Errata Sheet.
`12
`
`13
`14 _______________________________________
`15 SCOTT R. SERELS, M.D. DATE
`16
`
`17
`18 Subscribed and sworn
` to before me this
`19 _____ day of ______________, 20____.
`20 My commission expires:______________
`21
`
` ____________________________________
`22 Notary Public
`23
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`24
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`Golkow Technologies, Inc.
`
`Page 9 (30 - 31)
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`