throbber
The King’s Gambit: Valeant’s Big Secret | Southern Investigative Reporti...
`
`http://sirf-online.org/2015/10/19/hidden-in-plain-sight-valeants-big-crazy...
`
`Southern Investigative Reporting Foundation
`
` (http://sirf-online.org/2015/10/19/hidden-in-plain-sight-valeants-big-crazy-sort-of-secret-story/)
`
`UNCATEGORIZED
`
`By Roddy Boyd October 19, 2015
`
`If the name Valeant Pharmaceuticals International doesn’t ring a bell, its business practices should. The
`Quebec-based drug manufacturer’s policy of implementing regular price increases (http://www.zerohedge.com
`/news/2015-09-28/dear-martin-shkreli-how-you-hike-drug-prices) that often run north of 100% has generated plenty of
`anger, a congressional investigation (http://www.mccaskill.senate.gov/imo/media/doc/20150923McCaskilllettertoValeant.pdf) ,
`constant press coverage (http://www.nytimes.com/2015/10/05/business/valeants-drug-price-strategy-enriches-it-but-infuriates-
`patients-and-lawmakers.html?_r=0) and a subpoena (http://ir.valeant.com/investor-relations/news-releases/news-release-details
`/2015/Valeant-Provides-Update-Regarding-Government-Inquiries/default.aspx) from the U.S. Attorneys offices in both the
`Southern District of New York and the District of Massachusetts.
`
`But as strange as it may seem, a slim legal filing in California federal court is poised to make Valeant’s world
`rockier still.
`
`The story starts 50 miles northwest of Los Angeles in Camarillo, Ca. with R&O Pharmacy, a modestly-sized
`operation co-owned by veteran compounding pharmacists Russell Reitz and Robert Osbakken.
`
`According to a lawsuit filed by R&O, Russell Reitz got a letter (http://98zo02bh3v9r369dtffl01cj.wpengine.netdna-cdn.com
`/wp-content/uploads/2015/10/1-1-Exhibit-A.pdf) from Robert Chai-Onn (http://d1lge852tjjqow.cloudfront.net/CIK-0000885590
`/731bf529-b534-4425-83ce-23fb994868ec.pdf?noexit=true) , Valeant’s general counsel and director of business
`development, requesting repayment of $69.8 million for “invoiced amounts.” This apparently struck Reitz as
`odd since R&O had done no business, at least in any direct fashion, with Valeant. Moreover, he had never
`received a single invoice from Valeant or its subsidiaries.
`
`Reitz forwarded the letter to Gary Jay Kaufman, his lawyer down in Los Angeles, who sent a letter
`(http://98zo02bh3v9r369dtffl01cj.wpengine.netdna-cdn.com/wp-content/uploads/2015/10/1-2-Exhibit-B.pdf) to Chai-Onn on
`September 8 noting that the lack of invoices from Valeant indicated to him one of two things was happening:
`Valeant and R&O were being jointly defrauded by someone, or Valeant was defrauding R&O. He suggested they
`talk it over by phone.
`
`Chai-Onn never responded and on October 6, Kaufman filed suit (http://98zo02bh3v9r369dtffl01cj.wpengine.netdna-
`cdn.com/wp-content/uploads/2015/10/1-Complaint-1-1.pdf) , seeking a determination from the court that R&O owes
`Valeant nothing.
`
`There is, however, a hook and as these things go, it’s a big one: the Southern Investigative Reporting
`Foundation has confirmed that Reitz was indeed doing business of some sort through a company called
`Philidor Rx Services (http://www.philidorrxservices.com/) and a man named Andrew Davenport.
`
`Which makes Valeant’s demand letter very interesting.
`
`To understand why, it’s important to understand what Philidor is. To the public, it describes itself as a
`“pharmacy administrator” and, according to a call service operator last Thursday, Valeant is its only client.
`Located in Hatboro about 30 miles outside Philadelphia, its corporate filings indicate both companies are
`independent of the other.
`
`Pharmacy administrator appears to be, in Philidor’s case, a term of art.
`
`A better description is a “specialty pharmacy, (http://www.drugchannels.net/2013/02/defining-specialty-pharmacy.html) ”
`filling, shipping and getting insurance approval for prescriptions of the more complex drugs Valeant makes. In
`its third quarter conference call last year, the only instance where Philidor has been publicly mentioned by an
`analyst, Valeant chief executive Mike Pearson said that perhaps 40% of its business flows through specialty
`pharmacies. In July, he reiterated the company’s guidance for up to $11.1 billion in 2015 revenue, implying that
`as much as $4.4 billion in product could move through this channel.
`
`(Note that specialty pharmacies are exempt from reporting the drugs they sell to IMS Health, the tracking
`service used by companies and analysts to monitor drug sales and inventory channels.)
`
`Like many private companies, Philidor’s financials are hard to come by but it is unmistakably an operation of
`some mass, with around 900 employees and its own legal (https://www.linkedin.com/pub/gretchen-sprigg-wisehart
`/12/341/139) unit (https://www.linkedin.com/pub/kevin-schmidt/8/8ba/228) . A Pennsylvania State Senator posted an April
`6 interview (https://www.facebook.com/senatorgreenleaf/posts/807822615960322) with company CEO Andy Davenport
`where he stated the company was on track to process between 12,000 and 15,000 prescriptions daily by
`
`1 of 4
`
`11/16/2017, 1:36 PM
`
`Page 1 of 4
`
`ACRUX DDS PTY LTD. et al.
`
`EXHIBIT 1544(a)
`
`IPR Petition for
`
`U.S. Patent No. 7,214,506
`
`

`

`The King’s Gambit: Valeant’s Big Secret | Southern Investigative Reporti...
`
`http://sirf-online.org/2015/10/19/hidden-in-plain-sight-valeants-big-crazy...
`
`Southern Investigative Reporting Foundation
`
` (http://sirf-online.org/2015/10/19/hidden-in-plain-sight-valeants-big-crazy-sort-of-secret-story/)
`
`UNCATEGORIZED
`
`By Roddy Boyd October 19, 2015
`
`If the name Valeant Pharmaceuticals International doesn’t ring a bell, its business practices should. The
`Quebec-based drug manufacturer’s policy of implementing regular price increases (http://www.zerohedge.com
`/news/2015-09-28/dear-martin-shkreli-how-you-hike-drug-prices) that often run north of 100% has generated plenty of
`anger, a congressional investigation (http://www.mccaskill.senate.gov/imo/media/doc/20150923McCaskilllettertoValeant.pdf) ,
`constant press coverage (http://www.nytimes.com/2015/10/05/business/valeants-drug-price-strategy-enriches-it-but-infuriates-
`patients-and-lawmakers.html?_r=0) and a subpoena (http://ir.valeant.com/investor-relations/news-releases/news-release-details
`/2015/Valeant-Provides-Update-Regarding-Government-Inquiries/default.aspx) from the U.S. Attorneys offices in both the
`Southern District of New York and the District of Massachusetts.
`
`But as strange as it may seem, a slim legal filing in California federal court is poised to make Valeant’s world
`rockier still.
`
`The story starts 50 miles northwest of Los Angeles in Camarillo, Ca. with R&O Pharmacy, a modestly-sized
`operation co-owned by veteran compounding pharmacists Russell Reitz and Robert Osbakken.
`
`According to a lawsuit filed by R&O, Russell Reitz got a letter (http://98zo02bh3v9r369dtffl01cj.wpengine.netdna-cdn.com
`/wp-content/uploads/2015/10/1-1-Exhibit-A.pdf) from Robert Chai-Onn (http://d1lge852tjjqow.cloudfront.net/CIK-0000885590
`/731bf529-b534-4425-83ce-23fb994868ec.pdf?noexit=true) , Valeant’s general counsel and director of business
`development, requesting repayment of $69.8 million for “invoiced amounts.” This apparently struck Reitz as
`odd since R&O had done no business, at least in any direct fashion, with Valeant. Moreover, he had never
`received a single invoice from Valeant or its subsidiaries.
`
`Reitz forwarded the letter to Gary Jay Kaufman, his lawyer down in Los Angeles, who sent a letter
`(http://98zo02bh3v9r369dtffl01cj.wpengine.netdna-cdn.com/wp-content/uploads/2015/10/1-2-Exhibit-B.pdf) to Chai-Onn on
`September 8 noting that the lack of invoices from Valeant indicated to him one of two things was happening:
`Valeant and R&O were being jointly defrauded by someone, or Valeant was defrauding R&O. He suggested they
`talk it over by phone.
`
`Chai-Onn never responded and on October 6, Kaufman filed suit (http://98zo02bh3v9r369dtffl01cj.wpengine.netdna-
`cdn.com/wp-content/uploads/2015/10/1-Complaint-1-1.pdf) , seeking a determination from the court that R&O owes
`Valeant nothing.
`
`There is, however, a hook and as these things go, it’s a big one: the Southern Investigative Reporting
`Foundation has confirmed that Reitz was indeed doing business of some sort through a company called
`Philidor Rx Services (http://www.philidorrxservices.com/) and a man named Andrew Davenport.
`
`Which makes Valeant’s demand letter very interesting.
`
`To understand why, it’s important to understand what Philidor is. To the public, it describes itself as a
`“pharmacy administrator” and, according to a call service operator last Thursday, Valeant is its only client.
`Located in Hatboro about 30 miles outside Philadelphia, its corporate filings indicate both companies are
`independent of the other.
`
`Pharmacy administrator appears to be, in Philidor’s case, a term of art.
`
`A better description is a “specialty pharmacy, (http://www.drugchannels.net/2013/02/defining-specialty-pharmacy.html) ”
`filling, shipping and getting insurance approval for prescriptions of the more complex drugs Valeant makes. In
`its third quarter conference call last year, the only instance where Philidor has been publicly mentioned by an
`analyst, Valeant chief executive Mike Pearson said that perhaps 40% of its business flows through specialty
`pharmacies. In July, he reiterated the company’s guidance for up to $11.1 billion in 2015 revenue, implying that
`as much as $4.4 billion in product could move through this channel.
`
`(Note that specialty pharmacies are exempt from reporting the drugs they sell to IMS Health, the tracking
`service used by companies and analysts to monitor drug sales and inventory channels.)
`
`Like many private companies, Philidor’s financials are hard to come by but it is unmistakably an operation of
`some mass, with around 900 employees and its own legal (https://www.linkedin.com/pub/gretchen-sprigg-wisehart
`/12/341/139) unit (https://www.linkedin.com/pub/kevin-schmidt/8/8ba/228) . A Pennsylvania State Senator posted an April
`6 interview (https://www.facebook.com/senatorgreenleaf/posts/807822615960322) with company CEO Andy Davenport
`where he stated the company was on track to process between 12,000 and 15,000 prescriptions daily by
`
`1 of 4
`
`11/16/2017, 1:36 PM
`
`Page 1 of 4
`
`

`

`The King’s Gambit: Valeant’s Big Secret | Southern Investigative Reporti...
`http://sirf-online.org/2015/10/19/hidden-in-plain-sight-valeants-big-crazy...
`December. With prescription costs regularly running into the hundreds and even thousands of dollars, the
`company could potentially handle upwards of $1.5 billion in product this year.
`
`A key cog in Valeant’s “patient access” program, patients referred to Philidor often receive coupons for reduced
`or waived co-pay requirements–given to the prescriber by Valeant’s sales representatives–and in turn, Philidor
`would appear to attempt to recoup the cost of the drug from private insurers or Medicare. Theoretically, this
`makes price increases less risky for Valeant given that a sizable population of a drug’s users frequently won’t
`observe them. Still, the patient access program is central to the company’s distribution program, and one of the
`issues the U.S. Attorney subpeonas specifically sought information on.
`
`Philidor’s business practices have generated mixed reviews (at best) on consumer message boards — including
`numerous instances of alleged unwanted refills (http://philidor-rx-services.pissedconsumer.com/beware-unwanted-refills-
`customer-service-hassle-20150904694524.html) and an allegation of the improper removal (http://philidor-rx-
`services.pissedconsumer.com/philidor-rx-services-llc-took-my-hsa-funds-20150102577512.html) of HSA funds. Another message
`board account alleges (http://philidor-rx-services.pissedconsumer.com/unethical-20150901692440.html) that to get
`reimbursement approvals, prescriptions already denied at larger insurers were “pushed through” their sister
`pharmacies. (To be sure, comments on these sites can be gamed, both by consumers and the company, and the
`Southern Investigative Reporting Foundation was unable to verify these accounts.)
`
`Several questions remain unanswered: On the assumption that there is $69.8 million due someone, why
`wouldn’t Philidor’s two in-house attorneys have issued a demand letter to R&O? Similarly, why wouldn’t
`Valeant’s high-profile general counsel, when challenged, not provide support for his demand and avoid the risk
`and expense of litigation? Additionally, if Valeant does have some sort of claim to that nearly $70 million, what
`then is their real relationship to Philidor?
`
`———————————————-
`
`The Southern Investigative Reporting Foundation was able to uncover Valeant’s financial connection to
`Philidor–one that it hasn’t disclosed to investors–as laid out below.
`
`The first task was to establish who owns Philidor. What we discovered was indeed revealing, albeit probably not
`in the way its owners intended.
`
`Put bluntly, Philidor has gone to great lengths to conceal its ownership. Start with a man named Matthew
`Davenport, the listed principal on most of Philidor’s state registrations; additionally, several states list David
`Wing, John Carne and Gregory Blaszczynski as officers, and a few more have an End Game Partnership LLP
`listed as an assistant treasurer.
`
`Given Andy Davenport’s video above, his role as Philidor’s chief executive is clear. Plugging the address of End
`Game Partnership LLP (which in turn is owned by End Game LLC, a Las Vegas-based entity) from its filings
`into a search engine turns up a match to a house Andy Davenport owns in Horsham.
`
`A Southern Investigative Reporting Foundation phone call to Philidor’s administration revealed that there is no
`Matthew Davenport, David Wing, (Edward) John Carne or Gregory Blaszczynski working at Philidor. On the
`other hand, all four work at BQ6 Media (http://www.bq6media.com/content/matt-davenport) , a pharmaceutical
`marketing company located about 2.5 miles (https://www.google.com/maps/dir/400+Horsham+Road,+Horsham,+PA
`/330+S+Warminster+Rd,+Hatboro,+PA+19040/@40.1788105,-75.1268203,15z
`
`/data=!3m1!4b1!4m13!4m12!1m5!1m1!1s0x89c6af972a4be005:0xd3b5fa645563889e!2m2!1d-
`75.1367413!2d40.183998!1m5!1m1!1s0x89c6ae360034a0b5:0x4cbed988cb578194!2m2!1d-75.101816!2d40.171785) from the
`company. At one point, prior to Philidor, Andy Davenport was its CEO (http://web.archive.org/web/20130225052836
`/http://www.bq6media.com/content/andy-davenport) . Both BQ6 (https://who.is/whois/https://www.bq6media.com) and Philidor
`(https://who.is/whois/https://www.philidorrxservices.com) share the same domain registrar, Perfect Privacy LLC. The
`company’s LinkedIn profile lists 28 employees but the majority are consultants or contract workers, with
`several listing time spent at Philidor.
`
`The Philidor state registration in North Carolina (https://www.secretary.state.nc.us/Search/profcorp/10657029) was
`particularly helpful in that it listed a broader array of owners than other states.
`
`David Cowen is a former hedge fund manager and Elizabeth Kardos (http://www.us.zolfocooper.com/our-people
`/elizabeth-s-kardos) is general counsel for restructuring consultants Zolfo Cooper (http://www.us.zolfocooper.com/about-
`us) who are married (http://98zo02bh3v9r369dtffl01cj.wpengine.netdna-cdn.com/wp-content/uploads/2015/10/WEDDINGS-
`Elizabeth-Kardos-and-David-Cowen-The-New-York-Times.pdf) and own Four Beads LLC
`(http://98zo02bh3v9r369dtffl01cj.wpengine.netdna-cdn.com/wp-content/uploads/2015/10/NJ-Four-Beads-
`BE_Copies_0400379477_5289740384.pdf) ; they did not return a message left at their house or reply to an email sent
`to Ms. Kardos. Nick Spuhler (https://www.linkedin.com/in/nickspuhler) is a BQ6 alum who could not be reached,
`David Ostrow (http://98zo02bh3v9r369dtffl01cj.wpengine.netdna-cdn.com/wp-content/uploads/2015/10/NPI-Registry-Provider-
`Details-David-Ostrow.pdf) is a Physical Therapist (http://medcenter100.com/david-ostrow-pt/) and golf swing coach
`(https://www.linkedin.com/in/davidostrow) who did not return multiple calls to his house and residence, Jeffrey
`Gottesman (https://www.jeffgottesman.com/) is an insurance agent who has a sideline as a competitive poker
`(http://forumserver.twoplustwo.com/65/mttc-live/borgata-winter-open-2011-jan-19-feb-4-a-914247/index36.html) player; reached
`on his mobile phone, he declined comment. The address listed for Gina Miller tracked to a code inspection
`
`2 of 4
`
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`
`Page 2 of 4
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`

`

`The King’s Gambit: Valeant’s Big Secret | Southern Investigative Reporti...
`http://sirf-online.org/2015/10/19/hidden-in-plain-sight-valeants-big-crazy...
`business with no apparent connection to Philidor. Alternatively, a Gina Milner (http://www.bq6media.com/content
`/gina-milner) works at BQ6, but it couldn’t be determined if she is involved. Fabien Forrester-Charles
`(https://www.linkedin.com/profile/view?id=AAkAAAFVYwsBheCoGdvBVXLG6bXlPX0fb7A4l3U&authType=NAME_SEARCH&
`
`authToken=JtoJ&locale=en_US&trk=tyah&
`
`trkInfo=clickedVertical%3Amynetwork%2CclickedEntityId%3A22373131%2CauthType%3ANAME_SEARCH%2Cidx%3A1-1-1%2CtarId%3A1445199174372%2Ctas%3Afabien%20fo
`of Hatboro, Pa. and Francis Jennings of Naples, Fla. could not be reached, and Michael Ostrow of Bala Cynwyd,
`Pa. did not return a voice message left at his house. Paula Schuler of Old Greenwich, Ct., listed as an owner
`along with her husband Timothy, said she couldn’t talk at that moment; she never returned two follow-up calls.
`
`It is not readily apparent if there are any specific relationships among group members, beyond the general ties
`to Matthew and Andy Davenport (according to an online database they appear to be brothers), BQ6 and
`Philadelphia. One that does jump out is David Cowen and Andy Davenport’s tenure together at hedge fund
`Quasar Financial between 2004 and 2008; Davenport also donated (http://www.moaf.org/ways-to-give/corporate-
`support/corp-member-list) to the Museum of American Finance, where Cowen is the president.
`
`Not every state looked kindly upon the way Philidor went about securing out-of-state pharmacy operation
`privileges. California took exception to Matthew Davenport’s attempt to register as Philidor’s principal and
`rejected (http://98zo02bh3v9r369dtffl01cj.wpengine.netdna-cdn.com/wp-content/uploads/2015/10/Davenport_Calrejection.pdf) the
`company’s application for a Non-Residency Pharmacy Permit in May 2014. The state’s Department of
`Consumer Affairs Board of Pharmacy cited a series of disclosure-related problems, specifically his swearing to
`what was termed “false statement of facts” on the application, several of which involved the failure to disclose
`Philidor’s ownership group, as well as Andrew’s 27% ownership stake.
`
`(A brief aside: Francois-Andre Philidor (http://biography.yourdictionary.com/francois-andre-philidor) was an 18th century
`French Chess master, writing a book about it, The Analysis of Chess. BQ6 Media (http://www.bq6media.com
`/introduction) is named after the chess shorthand for Bobby Fisher’s legendary move against Russian chess
`master Boris Spassky in 1972. Another popular chess move is the King’s Gambit Accepted, or as it’s often
`referred to in chess notation, KGA.)
`
`Establishing the economic connection between Valeant and Philidor was less time-consuming.
`
`As it happens, Valeant has a wholly-owned unit named KGA Fulfillment Services Inc (http://www.sec.gov/Archives
`/edgar/data/885590/000088559015000015/exhibit211.htm) ., that was formed in Delaware in November, 2014. Its only
`mention in any Valeant filings is that sole line in last year’s annual report. An exhaustive search didn’t turn up
`any references to it in trade publications, nor state and federal databases. (What the initials stand for, apart
`from the similarity to the chess strategy, is unknown.)
`
`The Southern Investigative Reporting Foundation found KGA Fulfillment Services listed as the “secured party”
`on UCC-1 liens (http://smallbusiness.chron.com/ucc-lien-15791.html) placed this January and February against the
`members of Philidor’s ownership group. These liens are the public notice that a lending entity may have an
`interest in the debtor’s personal property. In this case, Valeant/KGA lent money to Philidor’s ownership group
`and per the rules, is announcing that their equity stakes in Philidor are potentially collateral.
`
`The UCC-1 financing statements for the group are: David Cowen (http://98zo02bh3v9r369dtffl01cj.wpengine.netdna-
`cdn.com/wp-content/uploads/2015/10/NJ-UCC-David-Cowen-KGA.pdf) and Elizabeth Kardos
`(http://98zo02bh3v9r369dtffl01cj.wpengine.netdna-cdn.com/wp-content/uploads/2015/10/NJ-UCC-Elizabeth-Kardos-KGA.pdf) ,
`Timothy (http://98zo02bh3v9r369dtffl01cj.wpengine.netdna-cdn.com/wp-content/uploads/2015/10/CT-Schuler-UCC1.pdf) and
`Paula Schuler, Nick Spuhler (http://98zo02bh3v9r369dtffl01cj.wpengine.netdna-cdn.com/wp-content/uploads/2015/10/NY-UCC-
`Spuhler-KGA.pdf) , Andrew Davenport Trust (http://98zo02bh3v9r369dtffl01cj.wpengine.netdna-cdn.com/wp-content/uploads
`/2015/10/PA-UCC-Andrew-Davenport-Trust-KGA.pdf) , David Ostrow (http://98zo02bh3v9r369dtffl01cj.wpengine.netdna-cdn.com
`/wp-content/uploads/2015/10/PA-UCC-David-Ostrow-KGA.pdf) , David Wing (http://98zo02bh3v9r369dtffl01cj.wpengine.netdna-
`cdn.com/wp-content/uploads/2015/10/PA-UCC-David-Wing-KGA.pdf) , John Carne
`(http://98zo02bh3v9r369dtffl01cj.wpengine.netdna-cdn.com/wp-content/uploads/2015/10/PA-UCC-Edward-Carne-KGA.pdf) ,
`Matthew Davenport (http://98zo02bh3v9r369dtffl01cj.wpengine.netdna-cdn.com/wp-content/uploads/2015/10/PA-UCC-Matthew-
`Davenport-KGA.pdf) , Fabien Forrester-Charles (http://98zo02bh3v9r369dtffl01cj.wpengine.netdna-cdn.com/wp-content/uploads
`/2015/10/PA-UCC-Fabien-Forrester-Charles-KGA.pdf) , End Game Partnership LLP
`(http://98zo02bh3v9r369dtffl01cj.wpengine.netdna-cdn.com/wp-content/uploads/2015/10/PA-UCC-End-Game-Partnership-LP-
`KGA.pdf) , End Game LP (http://98zo02bh3v9r369dtffl01cj.wpengine.netdna-cdn.com/wp-content/uploads/2015/10/PA-UCC-End-
`Game-LP-KGA.pdf) and Michael Ostrow (http://98zo02bh3v9r369dtffl01cj.wpengine.netdna-cdn.com/wp-content/uploads/2015/10
`/PA-UCC-Michael-Ostrow-KGA.pdf) .
`
`That an important financial relationship exists between Philidor and Valeant’s KGA unit is inarguable; why it
`exists is much less clear. From the standpoint of rational self-interest, the owner of a rapidly growing business
`would almost never want to borrow against their equity stake, let alone from the newly launched subsidiary of
`the enterprise’s sole customer.
`
`————————
`
`Over several days, since coming across the California lawsuit, the Southern Investigative Reporting Foundation
`made repeated phone calls to every person or company discussed above. With the exception of Jeffrey
`
`3 of 4
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`Page 3 of 4
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`The King’s Gambit: Valeant’s Big Secret | Southern Investigative Reporti...
`http://sirf-online.org/2015/10/19/hidden-in-plain-sight-valeants-big-crazy...
`Gottesman from the Philidor ownership group and R&O Pharmacy’s lawyer, Gary Jay Kaufman–both of whom
`declined comment–every other person did not return our calls.
`
`Robert Chai-Onn did not reply to a call to his office; a call to a mobile phone registered to his name was
`answered by his wife, who said she was on the West Coast and was unsure where her husband was at that
`moment.
`
`Meghan Gavigan (http://www.sardverb.com/people/meghan-gavigan/) of Sard Verbinnen & Co., an outside
`spokeswoman for Valeant Pharmaceuticals, was unable to secure a response from the company.
`
`4 of 4
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`Page 4 of 4
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`

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