Scott R. Serels, M.D.
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`AMERIGEN PHARMACEUTICALS LIMITED,
`ARGENTUM PHARMACEUTICALS LLC,
`Petitioners
`
`VS
`
`JANSSEN ONCOLOGY, INC.,
`Patent Owner
`
`Case IPR2016 -00286
`Patent No. 8,822,438 B2
`
`X
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`X
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`Videotaped deposition of SCOTT R. SERELS,
`M.D. taken at the offices of Hilton Garden Inn, 560
`Main Avenue, Norwalk, Connecticut, before Clifford
`Edwards, LSR, Connecticut License No. SHR.407, a
`Professional. Shorthand Reporter and Notary Public,
`in and for the State of Connecticut on January 21,
`2017, at 9:02 a.m.
`
`GOLKOW TECHNOLOGIES, INC.
`877.370.3377 ph 1 917.591.5672 fax
`deps @golkow.com
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`Golkow Technologies,__ -Inc.
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`Page 1 (1)
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`JANSSEN EXHIBIT 2018
`Wockhardt v. Janssen IPR2016-01582
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`

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`Scott R. Serels, M.D.
`Page 2
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`Page 4
`will now swear in the witness and we may
`proceed.
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`SCOTT R. SERELS, M.D.
`4
`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:
`Q Good morning.
`12
`A Good morning.
`13
`Sir, let me put before you a document
`Q
`14
`15 that bears exhibit Amerigen 1095.
`And let me ask you whether you recognize
`16
`17 that as your reply declaration in the present IPR
`18 proceeding?
`A
`I do.
`19
`Q Now, is that your signature on the first
`20
`21 page?
`22
`It is.
`A
`Q When did you actually sign it?
`A The date says January 16.
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`Page 5
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`1 APPEARANCES:
`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.corn
`
`7
`8
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`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
`
`KEVIN MARTH, VIDEOGRAPHER
`
`12
`13
`14 ALSO PRESENT:
`15
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`Page 3
`THE VIDEOGRAPHER: Good morning. We
`1
`2 are now on the record. My name is Kevin
`3 Marth. I'm the legal videographer today
`4 representing Golkow Technologies.
`Today's date is January 21, 2017 and
`5
`the time is approximately 9:01 a.m. The
`6
`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.
`At this time, would counsel please
`15
`16 identify themselves for the record.
`MR. ZEGGER: Paul Zegger with Sidley
`17
`18 Austin for the patent owner Janssen
`19 Oncology, Inc.
`MR. CASIERI: Chris Casieri of
`20
`21 McNeely, Hare & War representing the
`22 petitioner.
`THE VIDEOGRAPHER: Our court
`23
`24 reporter today is Mr. Cliff Edwards who
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`Is that when you signed?
`Q
`I believe that was when I signed.
`A
`Q That was this past Monday?
`A Correct.
`Q You signed a previous declaration in this
`5
`6 IPR back in December of 2015; do you recall that?
`I -- I do recall signing something
`A
`7
`8 previously.
`Q And do you recall having your deposition
`9
`10 taken back in August of last year?
`A Yes.
`11
`Q Could you turn to paragraph four of your
`12
`13 declaration, the reply declaration?
`A Yes.
`14
`Q Are you there?
`15
`I am.
`A
`Q And does that list the materials that you
`17
`18 were asked to review for your reply declaration?
`A Yes.
`19
`Q Okay. In particular, it's the expert
`20
`21 reports of Dr. Chodak, Dr. Auchus and Dr. Velltura?
`A Correct.
`22
`Q And also the Amerigen expert declarations
`23
`24 Dr. Doran and Dr. Rutain (phonetic)?
`
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`Golkow Technologies, Inc.
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`Page 2 (2 - 5)
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`Scott R. Serels, M.D.
`Page 6
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`A Correct.
`Q Did you look at any other expert
`2
`3 declarations?
`A Not that I recall.
`Q Okay. Do you recall being provided the
`patent owner's response brief?
`A Not in specifics, but yes.
`Q Well, is that something you reviewed?
`I did, yes.
`A
`Q You didn't review -- is there any reason
`why that's not listed in your list of materials
`considered in paragraph four?
`I think this is something that perhaps
`A
`was reviewed before this document was completed, so
`it wasn't included.
`I'm sorry, do you know when the patent
`Q
`owner's response was dated?
`I don't. I don't recall.
`A
`Q Okay. That was a brief back in October
`of 2016? I'm just trying to find out whether you
`recall being provided with that document?
`I believe I was, but I don't recall the
`A
`document specifically.
`Q Okay. Were you provided a -- an expert
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`THE VIDEOGRAPHER: Excuse me,
`counsel.
`Doctor, could I can you to scooch
`your microphone up --
`THE WITNESS: Oh, absolutely.
`THE VIDEOGRAPHER: -- just a little
`bit?
`THE WITNESS: Absolutely.
`THE VIDEOGRAPHER: Thank you, sir.
`9
`10 BY MR. ZEGGER:
`11
`In any event, you weren't, for purposes
`Q
`12 of your reply declaration, asked to respond to
`13 Dr. Rettig?
`A Correct.
`14
`is
`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.
`Q And do you agree that a PHOSITA is a
`19
`20 urologist or oncologist with access to
`21 endocrinologist to the extent needed?
`22
`A
`I agree.
`Q And do you agree that a urologist is
`23
`24 generally not an expert in endocrinology?
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`Page 7
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`Page 9
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`6
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`1 declaration of a Dr. Rettig?
`A Dr. Rettig? Yes, I do believe I saw a
`2
`3 document from Dr. Rettig.
`Q Okay. Is there any reason why that
`4
`s wasn't listed in your list of materials considered
`in paragraph four of your reply declaration?
`I thought these were most specific to the
`A
`7
`s declaration.
`Q Okay. Do you know who Dr. Rettig is?
`9
`to
`I believe he's a physician, urologist.
`A
`11 But, again, I don't recall the specifics of his
`12 report.
`Q Okay. Were you asked to review it
`13
`14 specifically?
`I've seen -- you know, I've a lot of
`15
`A
`16 different papers and different, you know, reports
`17 pertaining to this case. So I recognize the name,
`16 but I don't recognize the -- or remember the -- or
`19 recall the specifics of what he was describing.
`Q Did you know that he's a medical
`20
`21 oncologist?
`I knew he was a physician. I wasn't sure
`22
`A
`23 exactly what his title was.
`Q Okay..
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`A Correct.
`MR. CASIERI: Object to form.
`2
`3 BY MR. ZEGGER:
`Q And do you agree that an oncologist is
`4
`5 generally not an expert in endocrinology?
`MR. CASIERI: Object to form.
`A Correct.
`7
`e BY MR. ZEGGER:
`Q Are you an expert in oncology -- in
`9
`10 endocrinology?
`11
`A No.
`Q Prior to your work in connection with
`12
`13 this case, had you ever heard of a condition called
`14 CYP17 deficiency?
`A Yes.
`15
`Q And that was prior to your work in
`16
`17 connection with this case?
`19
`A Correct.
`Q But in terms of your own work, if you
`19
`20 have the need of expertise in endocrinology, you
`21 would consult a physician that has some expertise in
`22 that area; correct?
`A
`23
`Correct.
`Q Now, at the time of your initial
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`Golkow Technologies, Inc.
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`Page 3 (6 - 9)
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`Page 12
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`it says on the front page.
`Q Okay. Does that refresh any recollection
`that you have as to when you were first provided the
`3
`4 Vidal paper?
`A You know, I've seen so many papers, I
`5
`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.
`Q Okay; No, I'm just trying to find out
`10
`11 how many hours or days before you signed your reply
`12 declaration on January 16th, you had the Vidal
`13 paper?
`14
`A
`
`Scott R. Serels, M.D.
`Page 10
`1 declaration, you did not fully consider the various
`2 mechanisms by which ketoconazole was known to
`inhibit adrenal steroid synthesis beyond inhibiting
`4 CYP17 enzyme synthesis; correct?
`MR. CASIERI: Object to form.
`5
`A Correct.
`6
`7 BY MR. ZEGGER:
`Q Okay. And particularly, you were
`8
`9 focusing on one particular mechanism of action; is
`10 that right?
`A As it pertained to abiraterone, which was
`11
`12 the compound that we were most interested in.
`Q You agree that ketoconazole has
`13
`14 mechanisms of action other than inhibiting CYP17
`15 enzyme synthesis?
`I do agree.
`A
`16
`MR. CASIERI: Object to form.
`17
`18 BY MR. ZEGGER:
`Q Now, in defending the approach that you
`19
`20 took in this case, you cite to an article authored
`21 by a Vidal and a Dr. De bono; is that right?
`A Correct.
`22
`Q Let me show you Amerigen Exhibit 1147.
`And is this the article that you relied
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`3
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`I'm not sure.
`MR. CASIERI: Object to form.
`15
`16 BY MR. ZEGGER:
`Q All right. You cite a portion of the
`17
`la Vidal paper in your reply declaration, paragraph
`19 nine; is that right?
`20
`I'm sorry, paragraph eight?
`A Correct.
`21
`Q Now, is there any indication in the
`22
`23 portion that you cite indicating that ketoconazole
`is a CYP17 inhibitor?
`24
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`A
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`A Sorry. Can you repeat the --
`Sure.
`Q
`Is there any portion of the Vidal paper
`3
`4 that you cite that indicates that ketoconazole is a
`5 CYP17 inhibitor?
`A Yes. I couldn't exactly find it for you,
`6
`7 but yes.
`I think that, you know, the purpose was
`8
`9 that it was describing similarities between it and
`to the compound that we are most concerned with,
`11 abiraterone, in terms of its mechanism of action,
`12 inhibiting the adrenal gland.
`Q Okay. In -- well, let's take it step by
`13
`14 step here.
`15
`A Uh -huh.
`Q Could you look at paragraph eight of your
`16
`17 reply declaration?
`A
`18
`Sure.
`Q Are you there?
`I am.
`A
`Q Okay. And the portion that you cite from
`21
`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
`
`19
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`1 upon?
`A Yes.
`Q When did you first see it?
`A This article? I couldn't specifically
`4
`5 say.
`Q All right. Do you see at the bottom of
`6
`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?
`I don't.
`It's on the bottom of the first page?
`Q The very first page.
`A
`I do.
`Q Do you have an understanding as to
`whether Mr. William Hare is Amerigen's counsel in
`the present IPR?
`I know -- I know Mr. Hare.
`A He is.
`Q Okay. And do you see that this indicates
`that this particular paper by Vidal was downloaded
`by Mr. Hare on January 12th --
`A Yes.
`-- 2017?
`Q
`A That's what it -- correct. That's what
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`Page 4 (10 - 13)
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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."
`Do you see that?
`5
`A
`I do.
`In the quoted portion that you take from
`Q
`7
`8 Vidal, is there any indication that ketoconazole is
`9 a CYP17 inhibitor?
`A Yes. To my recollection, yes.
`10
`Q Well, either the quoted material refers
`to ketoconazole as a --
`A Uh -huh'.
`-- CYP17 inhibitor or it doesn't.
`Q
`Right?
`A Correct.
`Q Okay. Now, that's referring to
`abiraterone acetate as a CYP17 inhibitor; correct?
`A Correct.
`Q Okay. But it doesn't state that
`ketoconazole is a CYP17 inhibitor.
`Correct?
`MR. CASIERI: Object to form.
`A You are saying that quote doesn't? I
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`something being a CYP17 inhibitor is referring to
`the abiraterone acetate not ketoconazole.
`Correct?
`MR. CASIERI: Object to form.
`I think it's subject to interpretation.
`A
`BY MR. ZEGGER:
`Q Well, do you see any express statement in
`the Vidal paper referring to ketoconazole as a CYP17
`inhibitor?
`It's -- it's more a descriptive of
`A
`adrenal inhibition. I'd have to reread the article
`to be certain if there's anything specifically
`saying, CYP17.
`Q Okay. Well, I don't want you to --
`A Yup.
`-- to guess. If you could take some time
`Q
`looking at the Vidal article --
`A
`Sure.
`-- that you cite and if you could let us
`Q
`know whether you find any express statement in that
`article that ketoconazole is a CYP17 inhibitor?
`A Yeah. I think -- you know, I think what
`you quoted what I quoted on page eight of the
`article is the inference that ketoconazole inhibits
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`1 mean, it's subject to interpretation.
`And, you know, ketoconazole affects the
`2
`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:
`Q Well, my question doesn't go to whether
`7
`8 ketoconazole --
`A Yup.
`-- is a CYP17 inhibitor.
`Q
`A
`Sure.
`Q My question goes to whether Vidal --
`A Yes.
`-- that publication is referring to
`Q
`ketoconazole as a CYP17 inhibitor.
`Do you understand?
`I -- I do. It's a subtle difference.
`A
`And I think, you know, that it seems to be fairly
`clear from the article that ketoconazole can inhibit
`the adrenal gland which would encompass the CYP17
`enzymes. So my inference would be that, yes, it
`21
`22 does suggest that ketoconazole would inhibit the
`23 CYPI7.
`Q Okay. But the only specific reference to
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`adrenal steroid biosynthesis. And it compares it to
`abiraterone in terms of being a CYP1 7 inhibitor.
`And I think that's where that quote comes from, the
`specific line within page eight which describes it
`as being this inhibitor of biosynthesis and it
`compares it to abiraterone.
`Q Okay. So is there any express statement
`in the Vidal paper that ketoconazole is a CYP17
`inhibitor?
`
`MR. CASIERI: Object to form.
`A Yeah. Other than the quote that states
`it comparing it to the other CYP 17 inhibitor, there
`isn't. But that's where the quote comes from, their
`direct description.
`BY MR. ZEGGER:
`Q Now, could you look at paragraph nine of
`your declaration?
`A Sure.
`Q And there you refer to a rebuttal opinion
`of Dr. Doran?
`A Uh -huh.
`That's Amerigen's expert?
`Uh -huh.
`Now, Dr. Doran's field is endocrinology.
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`A
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`Scott R. Serels, M.D.
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`Is that right?
`A Uh -huh. That's correct.
`Q And I think you said you are not an
`endocrinologist?
`A That's correct.
`Q And that's not your field?
`MR. CASIERI: Object to form.
`BY MR. ZEGGER:
`Q That's not your field?
`A Correct.
`So the views that you are expressing in
`Q
`paragraph nine of your rebuttal report are those of
`Dr. Doran's, not independent views that you came up
`with.
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`16
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`Is that right?
`A Well, I think it's a combination. I
`think, you know, that paragraph specifically talks
`17
`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.
`So in that respect you would defer to
`Q
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`Page 20
`1 conclusion that he stated in a paper that he had
`2 with Gerber?
`A Correct.
`Q And you quote from that. And you state
`that according to Dr. Chodak, the conclusion in that
`9
`6 Gerber paper stated, "There appears to be a small
`7 subgroup of patients who will derive significant
`a benefit from the combination of ketoconazole and
`9 glucocorticoid replacement therapy."
`Is that right?
`to
`n
`A Correct.
`Q Now, you compare that conclusion with
`12
`13 some of the statements that Dr. Chodak made
`14 subsequently?
`18
`A Correct.
`Q And one of the comparisons that you did
`16
`17 appears in paragraph 14 of your report where you
`1e compare Dr. Chodak's 1990 conclusion with that of in
`19 a 1992 response to a letter?
`MR. CASIERI: Object to form.
`20
`A Correct.
`21
`22 BY MR. ZEGGER:
`Q And you quote from the 1992 statement.
`23
`Correct?
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`Dr. Doran on issues of endocrinology?
`MR. CASIERI: Object to form.
`A Any -- yeah. Any detailed issues of
`endocrinology, absolutely.
`BY MR. ZEGGER:
`Q Now, could you turn to section four of
`your reply declaration?
`I'm getting there.
`A
`Okay. I'm here.
`Q Okay. In that section, you talk about
`some of Dr. Chodak's papers.
`Is that right?
`A Section four is --
`Q I'm sorry. Section three.
`A Section three. Okay.
`Q I misspoke. Section three starting on
`page seven --
`A Yes.
`Q -- of your reply declaration?
`A Yes.
`Q And there you talk about some of
`Dr. Chodak's publications?
`A Correct. That would be --
`Q In paragraph 11, you remark about the
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`I do.
`A
`Q And the quote in the 1992 statement
`2
`3 states, "The observations by others as
`4 well as our own findings suggest that more
`9 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
`a patients, in addition to its effect on serum PSA."
`Is that what you are relying upon?
`9
`MR. CASIER!: Object to form.
`11
`A Yes.
`12 BY MR. ZEGGER:
`Q Now, in the 1992 response letter that you
`13
`14 rely upon, Dr. Chodak states that there is "some
`15 clinical benefit to using ketoconazole."
`Correct?
`16
`A Ketoconazole and prednisone, correct.
`Q Well, does he say anything about
`18
`19 prednisone in the 1992 response letter?
`A Well, the article is based on using
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`21 ketoconazole and prednisone.
`Q Okay.
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`So if he's commenting in the article,
`A
`it's the two in combination.
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`to
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`Scott R. Serels, M.D.
`Page 22
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`A Well -- but I think the context of where
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`Q No, I have to ask you -- I have to ask
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`4 you to answer the questions that' I'm posing.
`MR. CASIERI: He is answering your
`8
`question.
`MR. ZEGGER: I'm asking whether the
`language was the same or not.
`MR. CASIERI: What language?
`MR. ZEGGER: And that was all.
`MR. CASIERI: He's answering your
`question.
`MR. ZEGGER: The words,
`significant --
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`15 BY MR. ZEGGER:
`Q Sir- -
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`MR. CASIERI: If you don't like the
`answer, that doesn't mean you can
`interrupt him.
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`20 BY MR. ZEGGER:
`Q
`21
`Sir, the words "significant benefit" do
`22 not appear in his 1992 response letter.
`Correct?
`23
`I think it's gets confusing because he
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`Q Okay. But he didn't say anything
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`2 specifically in 1992 about prednisone; right?
`MR. CASIERI: Object to form.
`A He's just commented on his original
`conclusions.
`6 BY MR. ZEGGER:
`Q Okay. And on commenting on the original
`7
`8 conclusions, he's saying in 1992 that there was some
`9 clinical benefit to using ketoconazole.
`Correct?
`10
`MR. CASIERI: Object to form.
`A Yes.
`12
`13 BY MR. ZEGGER:
`Q Okay. So he's backing away from the
`14
`15 original language, where in 1990 he's said there was
`16 a significant benefit.
`Correct?
`17
`MR. CASIERI: Object to form.
`I think he's really reinforcing what he
`A
`19
`20 found in 1990.
`21 BY MR. ZEGGER:
`Q Well, the language he's using in 1992 is
`22
`23 not the same language that he used in his original
`24 1990 paper.
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`Correct?
`MR. CASIERI: Object to form.
`A You know, I think very few people use the
`3
`4 same language when they are asked the same question
`s at different times, but what he he's saying is the
`6 same.
`7 BY MR. ZEGGER:
`Q All right.
`A He's supporting his conclusions. The
`9
`to 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.
`There was, in 1992 --
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`Q Well, sir, I'm just asking you to
`18
`i9 compare- -
`I understand.
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`A No.
`-- the language --
`I understand.
`-- significant benefit to some benefit in
`Q
`the two --
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`Page 25
`1 writes an article, and then someone makes a letter
`to the editor inquiring about the article where the
`2
`3 author is allowed to describe his findings, and he
`4 can either support them or discount them.
`In this case, his statements although
`8
`they are not identical, are supportive of his
`6
`7 original conclusion.
`Q Okay. The words "significant benefit" do
`9 not appear in his 1992 letter.
`10
`Correct?
`MR. CASIERI: Object to form.
`I think it's ir- -- I mean, personally I
`12
`A
`13 think -- all I can say for you as a physician who
`14 reads the literature, that when I read his rebuttal
`to the letter to the editor, he seems to imply that
`15
`16 he strongly supports what he's done in his original
`17 research.
`18 BY MR. ZEGGER:
`Q Okay. And he's reiterating in 1992 that
`19
`20 there still needs to be more investigation.
`21
`Correct?
`A Correct.
`Q Okay. In fact, in 2004 he continues to
`23
`24 say there needs to be more investigation.
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`Scott R. Serels, M.D.
`Page 26
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`INDEX OF EXAMINATION
`PAGE
`DIRECT EXAMINATION BY MR. ZEGGER
`
`(Reporter's Note: No exhibits marked.)
`
`Correct?
`MR. CASIERI: Object to form.
`A Yes.
`BY MR. ZEGGER:
`So 14 years after Chodak's original 1990
`Q
`article, he's still saying to the scientific
`community, We need more investigations.
`Correct?
`MR. CASIERI: Object to form.
`9
`to
`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
`14
`15 prostate cancer, we should investigate everything as 15
`16 thoroughly as we can.
`16
`17 BY MR. ZEGGER:
`17
`Q Okay. And in the 2004 article of Chodak,
`18
`19 he doesn't say that there's a significant benefit to
`20 ketoconazole.
`21
`Correct?
`MR. CASIERI: Object to form.
`A He doesn't use those exact terms.
`MR. ZEGGER: Okay. No further
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`questions.
`MR. CASIERI: That's it?
`MR. ZEGGER: Yeah.
`MR. CASIERI: No questions.
`MR. ZEGGER: Okay.
`THE VIDEOGRAPHER: This concludes
`the deposition. We are going off the
`record at 9:25 a.m.
`(Thereupon, the deposition was
`concluded at 9:26 a.m.)
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`CERTIFICATE
`I hereby certify. that I am a Notary Public,
`in and for the State of Connecticut, duly
`3
`4 commissioned and qualified to administer oaths.
`I further certify that the deponent named in
`5
`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.
`I further certify that I am neither of
`13
`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.
`1s
`Witness my hand and seal as Notary Public
`day of
`19 this
`20
`
`2017.
`
`21
`22
`
`Clifford Edwards
`23
`Notary Public
`24 My commission expires: 9/30/2021
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`Scott R. Serels, M.D.
`Page 30
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`ERRATA
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`REASON:
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`REASON:
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`REASON:
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`REASON:
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`REASON:
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`REASON:
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`REASON:
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`REASON:
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`Page 31
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`ACKNOWLEDGMENT OF DEPONENT
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`, do
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`I,
`
`4
`5 hereby certify that I have read the
`foregoing pages, and that the same is
`6
`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
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`13
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`14
`is SCOTT R. SERELS, M.D.
`16
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`17
`18 Subscribed and sworn
`to before me this
`day of
`19
`20 My commission expires:
`21
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`22 Notary Public
`23
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`24
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`DATE
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`, 20
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`.
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