`
`CONFIDENTIAL - UNDER PROTECTIVE ORDER
`Transcript of Irene Loeffler
`
`Date: May 1, 2018
`Case: Pfizer, Inc. -v- Genentech, Inc. (PTAB)
`
`Planet Depos
`Phone: 888.433.3767
`Email:: transcripts@planetdepos.com
`www.planetdepos.com
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`WORLDWIDE COURT REPORTING | INTERPRETATION | TRIAL SERVICES
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`PFIZER and SAMSUNG v. GENENTECH
`IPR2017-01488
`PFIZER EX. 1200, Page 1
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`CONFIDENTIAL - UNDER PROTECTIVE ORDER
`Transcript of Irene Loeffler
`Conducted on May 1, 2018
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`1 (1 to 4)
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` A P P E A R A N C E S
`ON BEHALF OF PETITIONER PFIZER, INC.:
` SHARICK NAQI, ESQUIRE
` BENJAMIN LASKY, ESQUIRE
` KIRKLAND & ELLIS, LLP
` 300 North LaSalle
` Chicago, Illinois 60654
` (312) 861-2000
`ON BEHALF OF PETITIONER CELLTRION:
` LINNEA P. CIPRIANO, ESQUIRE
` (Via videoconference)
` GOODWIN PROCTER LLP
` 620 Eighth Avenue
` New York, New York 10019
` (212) 813-8800
`ON BEHALF OF PATENT OWNER GENENTECH, INC.:
` ANDREW J. DANFORD, ESQUIRE
` NORA Q.E. PASSAMANECK, ESQUIRE
` WILMER CUTLER PICKERING HALE AND DORR, LLP
` 60 State Street,
` Boston, Massachusetts 02109
` (617) 526-6022
`ALSO PRESENT:
` Joseph A. Mourgos, Videographer
` Traci Ropp, Genentech
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` I N D E X
` WITNESS PAGE
` IRENE LOEFFLER
` Examination by Mr. Naqi 10
` Examination by Mr. Danford 39
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` I N D E X O F E X H I B I T S
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`Exhibit 2001 Copy of laboratory notebook 13
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`Exhibit 2002 Copy of laboratory notebook 13
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`PLANET DEPOS
`888.433.3767 | WWW.PLANETDEPOS.COM
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` UNITED STATES PATENT AND TRADEMARK OFFICE
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` -----------------------------------
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` BEFORE THE PATENT TRIAL AND APPEAL BOARD
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` -----------------------------------
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`PFIZER, INC. and SAMSUNG BIOEPIS CO., LTD.,
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` Petitioner,
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` v.
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` GENENTECH, INC.,
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` Patent Owner.
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`1 2 3 4 5 6 7 8 9 1
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` Case Nos. IPR2017-01488, IPR2017-01489
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` CELLTRION, INC.,
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` Petitioner,
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` v.
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` GENENTECH, INC.,
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` Patent Owner.
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` Case Nos. IPR2017-01373, IPR2017-01374
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`** CONFIDENTIAL - UNDER PROTECTIVE ORDER **
`
` VIDEOTAPED DEPOSITION OF IRENE LOEFFLER
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` San Francisco, California
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` Tuesday, May 1, 2018
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` 12:59 p.m.
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`Job No.: 186258
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`Pages: 1 - 52
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`Reported By: Charlotte Lacey, RPR, CSR No. 14224
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` VIDEOTAPED DEPOSITION OF IRENE LOEFFLER, held at
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`the offices of DURIE TANGRI, 217 Leidesdorff Street,
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`PFIZER and SAMSUNG v. GENENTECH
`IPR2017-01488
`PFIZER EX. 1200, Page 2
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`

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`2 (5 to 8)
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`CONFIDENTIAL - UNDER PROTECTIVE ORDER
`Transcript of Irene Loeffler
`Conducted on May 1, 2018
`5
`Exhibit 2007 Copy of laboratory notebook 13
` number 11008 (retained by deponent)
`Exhibit 2008 Copy of laboratory notebook 13
` number 11297 (retained by deponent)
`Exhibit 2009 Copy of laboratory notebook 13
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`Exhibit 2019 Declaration of Irene Loeffler in 12
` case number IPR2017-01488 (retained
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`Exhibit 2019 Declaration of Irene Loeffler in 12
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` MS. CIPRIANO: Linnea Cipriano with Goodwin
`Procter representing Celltrion.
` THE VIDEOGRAPHER: Thank you.
` The court reporter today is Charlotte Lacey
`representing Planet Depos.
` Would the reporter please administer the oath.
` IRENE LOEFFLER,
`the witness herein, having been first duly sworn, was
`examined and testified as follows:
` MR. LASKY: Before we get started, I'm going
`to state an objection on the record. During a break in
`the earlier deposition of Len Presta, we were informed
`for the first time that counsel had brought today what
`he said were the microfilmed versions of various
`documents, notebooks that had been presented as
`exhibits -- as exhibits by Genentech in this case.
` At a subsequent break, 12:15, for the first
`time, counsel put those microfilmed versions in front of
`us. There are hundreds of pages of documents there. We
`object to the extent that counsel intends to raise these
`documents today at the deposition. We have not had the
`chance to review them. They have not been submitted as
`exhibits. We were given a very brief time to review
`them. And despite counsel's representation that the
`documents are identical to those that were already
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` P R O C E E D I N G S
` THE VIDEOGRAPHER: Here begins video number 1
`in the videotaped deposition of Irene Loeffler in the
`matter of Pfizer Incorporated versus Genentech
`Incorporated, IPR number 2017-01488 and 01489, and
`Celltrion versus Genentech, IPR number 2017-01373 and
`01374 in the United States Patent and Trademark Office
`before the Patent Trial and Appeal Board.
` Today's date is May 1st, 2018, and the time on
`the video monitor is 12:59 p.m. The videographer today
`is Joseph Mourgos representing Planet Depos. This video
`deposition is taking place at 217 Leidesdorff Street,
`San Francisco, California.
` Would counsel voice identify yourselves and
`state whom you represent.
` MR. NAQI: My name is Sharick Naqi. I'm from
`Kirkland & Ellis, and I represent Pfizer. And with me
`today is my colleague, Benjamin Lasky, also from
`Kirkland & Ellis.
` MR. DANFORD: My name is Andrew Danford from
`WilmerHale, and I represent Genentech and the witness.
`And I'm joined today by my colleague Nora Passamaneck of
`WilmerHale and Traci Ropp of Genentech.
` THE VIDEOGRAPHER: And on the telephone, we
`have...
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`produced, just in the half an hour we've had a chance to
`review them today, we've already found at least three
`differences between the microfilmed versions and the
`produced -- the versions that were produced to us.
` And so we object to the use of these documents
`during the deposition today. We object to their use in
`these proceedings as a whole.
` MR. DANFORD: I object to that colloquy. I
`mean, as I understand it, Mr. Naqi's taking the
`deposition here today, and you're in the second chair.
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`So -- that's for starters.
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` I also say we gave you sufficient time for
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`this. If you want to ask about the microfilms, you're
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`welcome to do so. We are not pressuring you to go
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`forward with this right now. You could have taken as
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`much time as you wanted to review those. There have
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`been questions raised in these proceedings about the
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`microfilms. There is no difference, from our
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`perspective, from the lab notebooks that have been
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`produced and the microfilms, and so we're making them
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`available to you now in case you had any questions about
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`them.
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` MR. LASKY: Mr. Danford, the issues of
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`microfilms have been -- have been raised since at least
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`Dr. Carter's deposition and possibly even before, and
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`PLANET DEPOS
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`PFIZER and SAMSUNG v. GENENTECH
`IPR2017-01488
`PFIZER EX. 1200, Page 3
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`

`

`CONFIDENTIAL - UNDER PROTECTIVE ORDER
`Transcript of Irene Loeffler
`Conducted on May 1, 2018
`9
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`3 (9 to 12)
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` A Verifying lab notebooks at Genentech; previous
`jobs, previous documents.
` Q And were these patent matters?
` A At Genentech?
` Q Yes.
` A I -- I don't really remember the nature of the
`case.
` Q You are currently employed at Genentech; is
`that right?
` A Yes.
` Q What is your current title at Genentech?
` A Associate Director.
` Q In general, what is your role in that
`position?
` A Records management.
` Q And could you elaborate on that?
` A Specifically for the case, we're talking about
`laboratory notebooks, so I oversee the issuing,
`tracking, recalling, scanning, indexing, and retrieving
`lab notebooks of their images.
` Q And what was your title at Genentech in 1989?
` A Whatever it said in my deposition. I don't
`remember the exact title at that time.
` Q And what was your role in 1989?
` A Records. It's been records my entire career.
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`that was days ago. There's no reason why this couldn't
`have been raised earlier. Frankly, there's no reason
`why this couldn't have been produced when the exhibits
`were produced in the first place. I can demonstratively
`prove to you that there are differences between the
`microfilms versions and the versions that were produced
`to us.
` We were not given time to review these today.
`We're here sitting in San Francisco where we've traveled
`for this deposition, and we have not had more than half
`an hour to review this. It was raised -- I don't even
`know why it wasn't raised earlier during Dr. Presta's
`deposition, why you had to wait till the second
`five-minute break that we received.
` And as for the fact that I'm not taking this
`deposition, you raised these documents first during the
`deposition of Dr. Presta, and as you're well aware, my
`colleague and I share in the duties today.
` MR. DANFORD: Well --
` MS. CIPRIANO: And if I can note for the
`record that Celltrion has not been produced -- they have
`not been provided an opportunity to review these
`documents. They were given a hard copy, and I am
`attending the deposition electronically.
` MR. DANFORD: Okay.
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` MS. CIPRIANO: And we add, for the record, we
`have the same objections as Mr. Lasky.
` MR. DANFORD: All right. Your objections have
`been noted. Let's see where this goes.
` EXAMINATION
`BY MR. NAQI:
` Q Good morning.
` A Good morning.
` Q Would you please state your full name for the
`record.
` A Irene Loeffler.
` Q Ms. Loeffler, have you had your deposition
`taken before?
` A Yes.
` Q How many times?
` A In my life, maybe four or five.
` Q And when was the first time you were deposed?
` A Previous employment, back in the -- probably
`early '80s.
` Q And your subsequent depositions, were they all
`related to your work at Genentech?
` A As I recall, I had perhaps two at my previous
`employment and maybe two or three at Genentech.
` Q And what was the subject matter of these
`depositions?
`
` Q So was it similar to your current role?
` A I've been promoted a few times, so I have more
`responsibilities as time went on.
` Q I've just handed you two documents. The first
`document has been marked as Exhibit 2019 in
`IPR2017-01488 and the other one has been marked as
`Exhibit 2019 in IPR2017-01489.
` Have you seen these documents before?
` A Yes.
` Q And are these declarations that you have
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`submitted in proceedings regarding U.S. patent
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`number 6,407,213?
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` A Yes.
`13
` Q Is it fair to say that these two declarations
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`are substantively identical in terms of their contents?
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` A Yes.
`16
` Q And to the extent that declarations were
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`submitted from you in multiple proceedings involving
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`Pfizer and Celltrion, they would be copies of the same
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`declaration?
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` A Yes.
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` Q And to the extent I ask you questions about
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`one of these, would your answers apply equally to the
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`other declarations as well?
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` A Yes.
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`PFIZER and SAMSUNG v. GENENTECH
`IPR2017-01488
`PFIZER EX. 1200, Page 4
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`

`

`CONFIDENTIAL - UNDER PROTECTIVE ORDER
`Transcript of Irene Loeffler
`Conducted on May 1, 2018
`13
`
` Q Did you review your declaration in preparation
`for this deposition?
` A Yes.
` Q Was there anything in there that you saw that
`was incorrect?
` A No.
` Q Is there anything in there that you saw that
`would change if you could write it again?
` A No.
` Q Let's turn to page 1 of your declaration. You
`can use the one marked for -- 1488. Do you see it --
`the proceedings.
` So at paragraph 4 on page 1 of your
`declaration, do you see the first sentence that says,
`"The exhibits listed below are true and authentic copies
`of several Genentech laboratory notebooks"?
` A Yes.
` Q Now, you're referring to the Genentech
`Exhibits 2001 through 2009 listed in paragraph 4 of your
`declaration; is that correct.
` A Yes.
` Q Now, do you know how the -- how the copies
`that you referred to in paragraph 4, first sentence of
`your declaration were made?
` MR. DANFORD: Objection to form.
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` Q So Genentech Exhibits 2001 through 2009 are
`the high-resolution, color-scanned copies made from the
`physical notebooks in 2016; is that correct?
` A Right.
` Q And separate copies of these notebooks were
`also made early earlier in the 1990s using microfilm
`technology?
` A Right.
` Q Now, you have not presented the microfilm
`versions of these notebooks made early in '90 -- in
`1990s in your declaration.
` A The declaration pertained to the scanned ones.
` Q So let's turn to page 6 of your declaration
`starting at the first sentence. I'm sorry. Paragraph 6
`of your declaration starting at the first sentence.
` There, you state, "I am familiar with
`Genentech's practices regarding the creation,
`modification, and keeping of its laboratory notebooks
`through my employment at Genentech."
` A Right.
` Q "Each of the laboratory notebooks listed above
`was created by Genentech personnel during the regular
`course of business."
` A Right.
` Q And then you state, "It was the regular
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` A I'm sorry?
` MR. DANFORD: I just objected to the form of
`the question.
` Q You can answer.
` MR. DANFORD: If you understand it.
` A Yeah. So the copies had been scanned, and
`then I believe what you have now are printouts.
` Q And when were these copies scanned?
` A They were on or around the time of the
`declaration.
` Q Now, on -- and when was that declaration
`prepared?
` A August 4th, 2017.
` Q So Exhibits 2001 through 2009 are copies that
`were scanned from the actual notebooks in August 2017;
`is that correct?
` A I --
` MR. DANFORD: Objection; lacks foundation.
` A I don't know exactly when they were scanned,
`but, yes, they were scanned from the original lab
`notebooks.
` Q Maybe I can help you. If you turn to page 3
`of your declaration, paragraph 7, last sentence.
` Do you see where it says --
` A Okay. So around November 2016.
`
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`practice of Genentech's personnel to create such records
`at or near the time the recorded act, event, condition,
`or opinion occurred."
` A Right.
` Q And then you state -- and you state, "It was
`the general practice of Genentech's personnel to date
`such documents as of the date the record was
`modified" -- I'm sorry -- "was created or modified."
` A Right.
` Q So here in paragraph 6, you're discussing the
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`regular practice of Genentech's personnel or the general
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`practice of -- of Genentech's personnel; is that
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`correct?
`13
` A Yes.
`14
` Q Do you have any knowledge about the practice
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`of any particular Genentech employee in terms of making
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`entries into these notebooks?
`17
` MR. DANFORD: Objection to form.
`18
` A No.
`19
` Q So you don't have any personal knowledge about
`20
`how each one of these notebooks was filled in.
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` A No.
`22
` Q And in the last sentence of paragraph 6, you
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`knowledge or from information transmitted by someone
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`PFIZER and SAMSUNG v. GENENTECH
`IPR2017-01488
`PFIZER EX. 1200, Page 5
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`

`

`CONFIDENTIAL - UNDER PROTECTIVE ORDER
`Transcript of Irene Loeffler
`Conducted on May 1, 2018
`17
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`5 (17 to 20)
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` So your -- you or your team had access to the
`notebooks during microfilming or scanning; is that
`correct?
` A Yes.
` Q What did you do with the notebooks after the
`microfilming or scanning was completed?
` A At the time of microfilming, generally, we
`would return them to the researchers for reference in
`the labs.
` Q And for Exhibits 2001 through 2009, did you
`return those to the employees?
` A I don't know specifically. I'd have to look
`it up. But generally, that would be the practice.
` Q And do you know who had access to the
`notebooks when they were not being microfilmed or
`scanned?
` A Specifically, no. It would be the
`researcher's responsibly.
` Q And do you know if the researchers -- how the
`researchers stored the notebooks?
` A Specifically, no.
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`with knowledge."
` Do you see that?
` A Right.
` Q Now, do you personally know whether these
`documents were made by a person with knowledge or from
`information transmitted by a person with knowledge of
`the events they recorded?
` MR. DANFORD: Objection to form.
` A So I don't know personally. I know the
`general practice.
` Q So for Exhibits 2001 and 2009, you don't know
`whether -- so for Exhibits 2001 through 2009, you don't
`know whether those documents were made by a person with
`knowledge or from information transmitted by a person
`with knowledge of the events they recorded.
` MR. DANFORD: Objection to form.
` A So that is the practice at Genentech is that
`the researchers would make the entries, sign, date and
`we would microfilm it.
` Q But for the particular individuals who
`prepared Exhibits 2001 through 2009, you don't
`personally know whether they were people with knowledge
`of the events they recorded or they prepared those
`entries from information transmitted by a person with
`knowledge of the events.
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` A I don't have personal knowledge.
` Q Now, let's look at paragraph 7 of your
`declaration again, starting at the first sentence.
` You state, "It was Genentech's general
`practice to recall imaging laboratory notebooks one year
`after they were issued or as soon as they were
`completed."
` Do you see that?
` A Yes.
` Q And next you say the -- next you say,
`"Genentech microfilmed the notebook until November 2007,
`at which time, Genentech began scanning the notebooks."
` A Right.
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` Q So you don't know who had access to notebooks
`when they were not being microfilmed or scanned.
` MR. DANFORD: Objection to form.
` A If they were returned to the researchers, it
`was the researcher's responsibility. I don't have
`direct knowledge.
` Q So now we discussed earlier that these
`notebooks were microfilmed, the notebooks referenced in
`Exhibits 2001 through 2009 were microfilmed at some
`point in the early 1990s. Do you remember that?
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` A Yes. Yes.
`11
` Q Now -- and then we also discussed that the
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`in November 2016. Do you remember that?
`14
` A Right.
`15
` MR. DANFORD: Objection to form.
`16
` Q So is there -- is there any way for us to tell
`17
`that the produced versions from 2016 were exactly the
`18
`same as the notebooks completed in the early 1990s?
`19
` A They could be compared.
`20
` Q But without the actual notebooks that were
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`completed in the 1990s, you could not compare them to
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`the scanned versions; is that correct?
`23
` MR. DANFORD: Objection to form.
`24
` A I don't understand the question.
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`CONFIDENTIAL - UNDER PROTECTIVE ORDER
`Transcript of Irene Loeffler
`Conducted on May 1, 2018
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` Q But wouldn't any changes made to the notebook
`in the interim be already present in the notebook when
`it's rescanned in 2016?
` MR. DANFORD: Objection to form, assumes facts
`not in evidence.
` A If -- if there's -- you look at the original
`page and you look at the scanned page, you can see that
`there are no changes.
` Q So the microfilming of the notebooks was done
`after they were completed; is that correct?
` A That's the general practice, yes.
` Q And any changes made before microfilming and
`after the notebook was completed could not be identified
`by comparing it against the microfilm version, correct?
` MR. DANFORD: Objection to form.
` A I didn't understand the question. You said
`changes made before microfilming and then what?
` Q So when the notebook is completed, there's a
`time -- there's an interim time between when it's
`completed and when it's scanned; is that right?
` MR. DANFORD: Objection to form.
` A So the notebooks were completed, and then they
`were microfilmed; later, they were scanned.
` Q Let me try to explain again. Let me try to
`clarify.
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` Q Let me rephrase. So there are physical
`notebooks that were prepared by the employees; is that
`correct?
` A Yes.
` Q So the employees completed these notebooks,
`generally,
` A Right.
` Q And those notebooks were, then, generally,
`stored by the employees when they were not being scanned
`or microfilmed, correct?
` MR. DANFORD: Objection to form.
` A Generally, yes.
` Q And you don't know who had access to those
`notebooks while they were being stored by the employees?
` MR. DANFORD: Objection to form.
` A As I stated before, it was the researchers'
`responsibility if we returned them to them.
` Q So there's no way to know that what was
`completed, the form of the notebooks were completed in
` They remained in the exact
`same form until they were scanned in 2016 and produced
`as Exhibits 21 -- 2001 through 2009?
` MR. DANFORD: Objection to form.
` A That was -- generally, when the notebook is
`complete, there are no additional entries or changes to
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`the notebooks. So they should be the same.
` Q But do you have any personal knowledge
`regarding those notebooks and any changes that might
`have been made by the employees?
` MR. DANFORD: Objection to form, lacks
`foundation.
` A Personal knowledge, no.
` Q So there is no way to really tell the
`notebooks that were in the form they were completed in
` are the exact same 20-odd-some
`years later when they were rescanned in 2016?
` MR. DANFORD: Objection to form, lacks
`foundation.
` A So they -- they can be compared.
` Q And what would you compare them to?
` A They can be compared to each other or to the
`original notebook.
` Q So if changes were made to the notebook in the
`intermediate time frame, how could you compare them to
`what was actually completed
` MR. DANFORD: Objection to form.
` A You can look at the original page, the
`original notebook. You can look at the page that was
`produced from microfilm. You can look at the page that
`was produced from the scanned image.
`
` So when the notebooks were completed, then
`they were sent for microfilming?
` A Uh-huh. Yes.
` Q Was there a period of time between -- for some
`of the notebooks or maybe all the notebooks, was there a
`time period between when they were completed and when
`they were sent for scanning?
` A I don't know.
` Q In -- if there was, assuming there was an
`interim time period, could there be changes made in the
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`notebook which you would not be able to compare against
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`the original form of the notebook and the microfilm?
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` MR. DANFORD: Objection to form.
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` A We -- we -- when we receive the notebook, it's
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`completed, and that's when we microfilm it.
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` Q Now, how about any changes made between the --
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`the date the -- a page was completed in the notebook and
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`the -- and the date the notebook was microfilmed. Could
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`those changes be identified by looking at the
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`microfilmed version?
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` MR. DANFORD: Objection to form.
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` A You're asking if there was a change to a page
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`before it was microfilmed. That certainly could be done
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`as the normal course of business.
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` Q But such a change could not be identified by
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`CONFIDENTIAL - UNDER PROTECTIVE ORDER
`Transcript of Irene Loeffler
`Conducted on May 1, 2018
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`be captured on the microfilm.
` Q And if there was a change that was not
`initialled and dated?
` A It would look the same on the page as the
`microfilm.
` Q Can you say under oath that every page in the
`microfilmed version is the same as the page on the date
`it was first completed and dated?
` MR. DANFORD: Objection to form.
` A I can say under oath that the microfilm
`represents the true and complete and accurate
`representation of the notebook at the time it was
`microfilmed.
` Q But you cannot say under oath that every page
`in the microfilmed version is the same as the page on
`the date it was first completed and signed?
` MR. DANFORD: Objection to form.
` A I have no way of responding to that.
` Q You have no way of knowing that?
` MR. DANFORD: Objection to form, asked and
`answered.
` A If the -- if a page was completed on a date
`and an entry was made later on that same date, I would
`have no way of knowing that.
` MR. LASKY: I'm not as good as him at this
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`comparing the notebook against the microfilm?
` MR. DANFORD: Objection to form.
` A It would be the same.
` Q So because the change was made in the notebook
`before it was microfilmed, it could not be identified by
`comparing the microfilm against the physical notebook?
` MR. DANFORD: Objection to form.
` A It would be the same -- they -- the microfilm
`would represent the same as the original notebook page.
` Q But it would not be the original of the book
`page, it would be the notebook page that had been
`modified?
` MR. DANFORD: Objection; lacks foundation.
` Q Let me walk you through it again.
` So when a particular page in the notebook is
`dated, between that date and the date of the -- notebook
`is microfilmed, if there's a change made to that page,
`would there be any way to compare the original entry
`versus the microfilm one?
` MR. DANFORD: Objection to form.
` A If they -- if they initialled and dated a
`change, then that would show at possibly the same or a
`different date than the date of the page.
` Q And if the changes were not initialed and
`dated, could you tell by comparing it against the
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`job.
`microfilm copy whether the original page had been
` Q Now, I've handed you what's been marked as
`changed?
`Genentech Exhibit 2001, in both the 1488 and the 1489
` MR. DANFORD: Objection to form.
` A It would be -- whatever we filmed on that date
`proceedings. This is a copy of a laboratory notebook
`would be the same as what was in the page of the
`number 10098 issued to Leonard Presta. Is that correct?
` A Yes.
`notebook at the time that we filmed it.
` Q Do you recognize this document?
` Q So changes made in between the dates when the
` A It looks like a -- the representation of the
`notebook was dated -- a notebook page was dated and the
`notebook, yes.
`microfilming could not be picked up by comparing the
` Q Is this the exhibit mentioned in paragraph 4,
`microfilm against the notebook?
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`subpart A, of your declaration?
` MR. DANFORD: Objection to form.
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` A It would look the same as the page at the time
` MR. DANFORD: Objection to form.
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` A Yes.
`we microfilmed it so...
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` Q On page 2 of Exhibit 2000 -- 001, it states
` Q So the microfilm reflects the page at the date
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`that the document was microfilmed on December 15, 1992.
`of the microfilming?
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` A Yes.
` A Yes.
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` Q Exhibit 2001 is not the microfilmed version of
` Q And there's no way to guarantee that the page
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`the notebook, is it?
`was the same on the date of microfilming as it was on
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` A This is the scanned version.
`the date the page was completed and dated?
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` Q Now, do you have any knowledge -- any personal
` MR. DANFORD: Objection to form.
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` A I can't -- I don't really know how to answer
`knowledge about Leonard Presta's practice in terms of
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`that question. We film it as it's presented to us. So
`making entries into this notebook?
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` A Personal knowledge? No.
`if a page was filled out and dated, that is what that
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`page represents when it's microfilmed. If there was a
` Q Do you know if -- do you know if Exhibit 2001,
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`change and it was initialled and dated, that also would
`this lab notebook that it represents, was stored by
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`CONFIDENTIAL - UNDER PROTECTIVE ORDER
`Transcript of Irene Loeffler
`Conducted on May 1, 2018
`29
`Leonard Presta except during the times when it was being
`scanned or microfilmed?
` MR. DANFORD: Objection to form.
` A I don't know specifically. The general
`practice was to return them to the researchers after
`microfilming.
` Q So your team only had access to this notebook
`when it was being microfilmed or scanned, correct?
` A I don't know specifically in this case if we
`stored it or returned it to the researcher.
` Q So you don't know specifically who might have
`had access to this notebook when it was not being
`microfilmed or scanned?
` MR. DANFORD: Objection to form.
` A If we returned it to the researcher, it was
`his responsibility.
` Q Now, if the researcher made any changes to
`this notebook in -- in the interim from when it was
`returned t