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` IN THE UNITED STATES DISTRICT COURT
` FOR THE DISTRICT OF NEW JERSEY
`_________________________
`HORIZON PHARMA, INC., and
`POZEN INC., Civil Action No. 3:11-02317 (JAP) (DEA)
` Plaintiffs, Civil Action No. 3:13-00091 (JAP) (DEA)
` -vs-
`DR. REDDY'S LABORATORIES, INC., and
`DR. REDDY'S LABORATORIES LTD.,
` Defendants.
`
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`_________________________
`
` CONFIDENTIAL
` VIDEOTAPED DEPOSITION OF MARK SOSTEK, MD
` PHILADELPHIA, PA
` FRIDAY, OCTOBER 27, 2017
`
`Reported by: S. ARIELLE SANTOS, RPR, CSR, CLR
`Job No. 132689
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` IN THE UNITED STATES DISTRICT COURT
` FOR THE DISTRICT OF NEW JERSEY
`_________________________
`HORIZON PHARMA, INC., and
`POZEN INC., Civil Action No. 3:11-02317 (JAP) (DEA)
` Plaintiffs, Civil Action No. 3:13-00091 (JAP) (DEA)
` -vs-
`DR. REDDY'S LABORATORIES, INC., and
`DR. REDDY'S LABORATORIES LTD.,
` Defendants.
`
`Caption Continued on Page 2
`_________________________
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` CONFIDENTIAL
` VIDEOTAPED DEPOSITION OF MARK SOSTEK, MD
` PHILADELPHIA, PA
` FRIDAY, OCTOBER 27, 2017
`
`Reported by: S. ARIELLE SANTOS, RPR, CSR, CLR
`Job No. 132689
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`FOR THE DISTRICT OF NEW JERSEY
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`Page 2
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`_________________________
`HORIZON PHARMA, INC., and
`POZEN INC.,
` Plaintiffs, Civil Action No. 3:13-cv-04022 (JAP) (DEA)
` -vs-
`MYLAN PHARMACEUTICALS
`INC., MYLAN LABORATORIES
`LTD., and MYLAN INC.,
` Defendants.
`
`_________________________
`HORIZON PHARMA, INC., and
`POZEN INC.,
` Plaintiffs, Civil Action No. 3:13-cv-03038 (JAP)(DEA)
` -vs-
`ACTAVIS LABORATORIES FL,
`INC., and ACTAVIS PHARMA,
`INC.,
` Defendants.
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`_________________________
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`_________________________
`HORIZON PHARMA, INC., and
`POZEN INC.,
` Plaintiffs, Civil Action No. 3:11-cv-04275 (JAP) (DEA)
` -vs-
`LUPIN LTD., and LUPIN
`PHARMACEUTICALS INC.,
` Defendants.
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`_________________________
`
` FRIDAY, OCTOBER 27, 2017
` 9:19 A.M.
`
` Videotaped Deposition of MARK SOSTEK, MD,
`held at the offices of Pepper Hamilton LLP,
`Two Logan Square, Eighteenth and Arch Streets,
`Philadelphia, PA, before S. Arielle Santos, a Registered
`Professional Reporter, Certified Shorthand Reporter, Certified
`Livenote Reporter and Notary Public.
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` A P P E A R A N C E S
`
`Page 4
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`ON BEHALF OF PLAINTIFF HORIZON PHARMA, INC., AND
`THE WITNESS:
`COOLEY
`500 Boylston Street
`Boston, MA 02116
`BY: ELLEN SCORDINO, ESQ.
`
`ON BEHALF OF PLAINTIFF POZEN INC.:
`BAKER BOTTS (Telephonically)
`98 San Jacinto Boulevard
`Austin, TX 78701
`BY: JEFF GRITTON, ESQ.
`
`ON BEHALF OF DEFENDANTS DR. REDDY'S LABORATORIES
`INC., AND DR. REDDY'S LABORATORIES LTD.:
`BUDD LARNER
`150 John F. Kennedy Parkway
`Short Hills, NJ 07078
`BY: DMITRY SHELHOFF, ESQ.
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` A P P E A R A N C E S (Cont.'d)
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`Page 5
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`ON BEHALF OF DEFENDANTS MYLAN PHARMACEUTICALS
`INC., MYLAN LABORATORIES LTD., AND MYLAN INC.:
`PERKINS COIE
`700 Thirteenth Street N.W.
`Washington, D.C. 20005
`BY: ROBERT SWANSON, ESQ.
`
`ON BEHALF OF THE WITNESS:
`COVINGTON & BURLING
`One CityCenter
`850 Tenth Street, N.W.
`Washington, D.C. 20001
`BY: COURTNEY FORREST, ESQ.
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`ALSO PRESENT:
`CHRISTOPHER PARKER, Legal Video Specialist
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` INDEX
` MARK SOSTEK, MD 9
` BY MR. SHELHOFF 9
` BY MR. SWANSON 178
`
` DEFENDANT EXHIBITS MARKED - ATTACHED
` Exhibit 16, printout, LinkedIn website 18
` Exhibit 17, printout, SciFinder website 39
` Exhibit 18, printout, PubMed 39
` Exhibit 19, printout, United States 63
` Patent Office website, USPTO's
` patent database
` Exhibit 20, Bates PZC_00013279 to 67
` PZC_00013299, declaration
` Exhibit 21, excerpt, deposition 82
` testimony of Dr. Mark Sostek on
` October 10, 2014, pages 139 and
` 140
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` DOCUMENT REQUESTS
` 1. Agreements 14
` 2. Dr. Ault, signed agreements with 14
` Cooley and with Covington
` Burling LLP
`
` EXHIBITS REFERENCED - PREVIOUSLY MARKED
` Defendant's Exhibit 2 66
` Defendant's Exhibit 3 67
` Defendant's Exhibit 4 79
` Defendant's Exhibit 5 80
` Defendant's Exhibit 6 124
` Defendant's Exhibit 10 126
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` MARK SOSTEK, MD - CONFIDENTIAL
` THE VIDEOGRAPHER: This is the
` start of tape-labeled Number 1 of
` the videotaped deposition of
` Mark Sostek in the matter of
` Horizon Pharma, Inc. and Pozen,
` Inc. v. Dr. Reddy's Laboratories,
` Inc., Case Number 2:15-3324 in the
` Court of United States District
` Court for the District of New
` Jersey.
` This deposition is being held
` at 3000 Two Logan Square,
` Philadelphia, Pennsylvania 19103,
` on Friday, the 27th, 2017, at
` approximately 9:10 a.m.
` My name is Christopher Parker
` from TSG Reporting, Inc., and I am
` the legal video specialist. The
` court reporter is Arielle Santos in
` association with TSG Reporting.
` Will counsel please introduce
` yourself.
` MR. SHELHOFF: Dmitry Shelhoff
` from the law firm of Budd Larner
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` representing Dr. Reddy's
` Laboratories, Inc. and Dr. Reddy's
` Laboratories LTD.
` MR. SWANSON: Robert Swanson
` from Perkins Coie LLP on behalf of
` the Mylan defendants.
` MS. FORREST: Courtney Forrest
` from Covington & Burling LLP on
` behalf of the witness.
` MS. SCORDINO: Ellen Scordino
` from Cooley LLP on behalf of
` Horizon Pharma and the witness.
` MR. GRITTON: And Jeff Gritton
` from Baker Botts LLP on behalf of
` Pozen.
` (Whereupon MARK SOSTEK, MD is
` Sworn In.)
` THE WITNESS: I do.
`
` EXAMINATION
`BY MR. SHELHOFF:
` Q Hello, Dr. Sostek.
` A Hello.
` Q So, of course, everybody in the
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` MARK SOSTEK, MD - CONFIDENTIAL
`room knows who you are and your name,
`but could you just please state it for
`the record again?
` A Certainly. Mark Sostek,
`S-O-S-T-E-K.
` Q And, Dr. Sostek, do you recall
`being deposed three years ago in a
`related matter, which also concerned
`VIMOVO®?
` A Yes.
` Q And is there anything today that
`would prevent or affect your ability to
`answer truthfully?
` A No.
` Q Is there any medication that
`might affect your ability to answer
`truthfully today?
` A No.
` Q Okay.
` So let me just go over some
`basics, which I am sure you are familiar
`with because you have been deposed
`before.
` So during this deposition, there
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` MARK SOSTEK, MD - CONFIDENTIAL
`could be objections from counsel, and
`most of those objections I think are
`made to the form of the question, and
`some questions I may choose to rephrase,
`but I don't have to do so. And you
`still must answer each question despite
`an objection unless your counsel
`expressly instructs you not to, which is
`a rare occasion.
` So let me begin by asking you,
`do you generally understand what I just
`said?
` A Yes.
` Q Okay.
` So I know it's been three years
`since you last have been deposed in
`VIMOVO®.
` So have you been deposed during
`that time in any other case?
` A No.
` Q Okay.
` Would you please state your
`current address.
` A 1650 Forest Creek Drive, Blue
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` MARK SOSTEK, MD - CONFIDENTIAL
`Bell, Pennsylvania 19422.
` Q And is this your primary
`residence?
` A Yes.
` Q And I know it's not April 2018
`yet, but are you going -- are you
`planning to file your taxes for the year
`2017 using this address?
` A Yes.
` Q Okay.
` What is -- what is the current
`position that you have?
` A I am a senior director of
`clinical research at Pfizer.
` Q And where is your company Pfizer
`located?
` A I work at Collegeville,
`Pennsylvania facility, the Pfizer
`facility.
` Q And what kind of facility is
`this, and I mean is it an R&D center?
` A It's -- yes, it's primarily an
`R&D center.
` Q Okay.
`
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` So the reason I asked you for
`your address just that maybe we might
`need to ask you to come to trial, and if
`this were the case, would you agree to
`come to trial and testify?
` A I don't know.
` Q Okay.
` So let -- let me ask you a
`couple of questions about attorneys who
`you think represent you.
`
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`
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`BY MR. SHELHOFF:
` Q Okay.
` So moving on with trial, if --
`if you're asked to testify at trial, do
`you authorize either Cooley -- either
`Covington & Burling or Cooley LLP,
`either of those firms, to receive a
`subpoena on your behalf?
` MS. FORREST: I am going to
` object on the basis that he should
` be permitted to consult with his
` counsel before answering that
` question.
`BY MR. SHELHOFF:
` Q Well, can you consult -- you can
`step outside and consult with counsel
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`and come back and --
` MS. FORREST: We can take a
` break.
` THE WITNESS: Right now?
` MS. FORREST: Yeah.
`BY MR. SHELHOFF:
` Q How about that, let's defer this
`question to the break. It's not urgent
`here, so you can consult on the break.
` Okay. So I know during the
`prior deposition in October 2014, we
`marked your LinkedIn profile, but it's
`been a couple of years since then, so I
`am going to mark -- mark it again.
` Okay. One more question about
`the representation.
`
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` Q Hm-hm.
` Did you prepare for this
`deposition today?
` A Yes.
` Q How did you prepare?
` A I met with both attorneys here
`and another attorney from Covington
`yesterday.
` Q And what was the name of that
`either attorney?
` A Einar Stole.
` MS. FORREST: Stole.
` THE WITNESS: Stole.
`BY MR. SHELHOFF:
` Q Was there anyone else from
`Cooley LLP besides Ellen Scordino here?
` A You mean yesterday?
` Q Yeah.
` A No.
` Q Any other time?
` A No.
` Q And for how long have you
`prepared for today's deposition?
` A About two hours yesterday and a
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` MARK SOSTEK, MD - CONFIDENTIAL
`couple of hours skimming through my
`prior deposition transcript.
` Q Hm-hm.
` Did you review any documents in
`preparation for today's deposition?
` A No.
` MS. FORREST: You can answer
` that "yes" or "no."
` THE WITNESS: Sorry.
` Okay. No.
`BY MR. SHELHOFF:
` Q So besides your prior deposition
`testimony, you have not reviewed any
`documents in preparation for today's
`deposition?
` A No.
` (Whereupon a Discussion is
` Held Off the Record.)
` THE REPORTER: 16.
` (Exhibit 16 is Marked.)
` MR. SHELHOFF: We marked as
` Exhibit 16, a printout from the
` LinkedIn website of Mark Sostek.
`BY MR. SHELHOFF:
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` MARK SOSTEK, MD - CONFIDENTIAL
` Q So, Dr. Sostek, have you seen
`this, what appears to be a
`representation of your LinkedIn profile?
` A Yes.
` Q And did you prepare the LinkedIn
`profile printout of which is represented
`in Exhibit 16?
` A The printout?
` Q Well, not the printout, but the
`web -- the web --
` A It appears to be consistent with
`what I have prepared --
` Q Okay.
` A -- on the computer.
` Q And does it accurately reflect
`your background and professional
`experience?
` A (Reviewing.)
` It appears to be accurate.
` Q Okay.
` Dr. Sostek, do you have an MD
`degree from Taft University School of
`Medicine?
` A Yes.
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` MARK SOSTEK, MD - CONFIDENTIAL
` Q And after graduating from Taft
`Medical School, you have worked for
`about two years as an assistant in
`medicine at Massachusetts General
`Hospital in Boston, Massachusetts,
`correct?
` A Yes.
` Q And after that, you worked for
`five years as an assistant professor of
`medicine at Boston University School of
`Medicine and at the same time as a staff
`gastroenterologist at the same center,
`correct?
` A Yes.
` Q After that you began a long and
`successful career at AstraZeneca,
`correct?
` A Yes.
` Q How many years were you with
`AstraZeneca?
` A Seventeen.
` Q And during those 17 years at
`AstraZeneca, were you involved in
`clinical research?
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` A Yes.
` Q During those years at
`AstraZeneca, were you involved in
`clinical research with esomeprazole?
` A Yes.
` Q AstraZeneca was the company that
`developed esomeprazole, correct?
` A Yes.
` Q Esomeprazole is marketed by
`AstraZeneca under the trade name
`Nexium®, correct?
` A Yes.
` Q Also frequently referred to as
`the purple pill, correct?
` A Yes.
` Q Even though formulators know
`that it should properly be referred as
`the capsule, right?
` A I don't know.
` Q So your LinkedIn profile
`reflects that for six years you have
`been what is titled US brand medical
`director/Nexium -- or hyphen Nexium®?
` A Yes.
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` Q And what did this position
`involve?
` A It involved -- for the -- after
`the approval of Nexium®, planning
`life-cycle management from a clinical
`research perspective for Nexium® focused
`on the US -- on the United States.
` Q And can you just explain a
`little bit more what is the life-cycle
`management?
` A It means after a drug is first
`approved for its first indication, it
`involves doing other research that
`involves other indications in other
`areas.
` Q Do you know when Nexium® was
`approved in the United States?
` A 2000.
` Q So at AstraZeneca, it's not only
`Nexium® -- it's not only Nexium® or
`esomeprazole that you worked with.
` You also worked with different
`proton-pump inhibitors, correct?
` A No.
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` Q So at AstraZeneca, it was only
`esomeprazole that you worked with?
` A It was the only proton-pump
`inhibitor that I did research on, yes.
` Q Okay.
` But it probably will not detract
`any from your prior answer if you also
`clarify that at least as a control in
`some of your clinical trials, you also
`used omeprazole, right?
` MS. FORREST: Objection to the
` form.
` THE WITNESS: Yeah.
` MS. FORREST: Give me a
` second.
` THE WITNESS: I'm sorry.
` Okay.
` MS. FORREST: That's okay.
` Objection to the form.
`BY MR. SHELHOFF:
` Q So you also worked with
`omeprazole, right?
` A I worked on trials in which
`omeprazole was a -- one of the agents
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`tested.
` Q Okay.
` And usually as a control?
` A I am trying to think for a
`minute. Usually as an active control,
`yes.
` Q So when you say "an active
`control" rather than control, why do you
`make that distinction?
` A Because there -- there is
`usually clinical research placebo
`controls, which consist of an inert
`inactive substance. In other trials,
`you use an active control, which is
`known to have an effect, but you're
`testing if it's a different effect than
`the drug you're testing.
` Q So both esomeprazole and
`omeprazole are proton-pump inhibitors,
`correct?
` A Yes.
` Q And omeprazole is has been
`marketed by AstraZeneca under the trade
`name Prilosec, correct?
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` A Yes.
` Q In fact, it was omeprazole that
`was the very successful proton-pump
`inhibitor developed by AstraZeneca,
`correct?
` MS. FORREST: Objection to the
` form.
` THE WITNESS: Yes.
`BY MR. SHELHOFF:
` Q So the Nexium® of AstraZeneca
`was the follow-on on the Prilosec
`product, correct?
` MS. FORREST: Object to the
` form.
` THE WITNESS: It was the
` second proton-pump inhibitor that
` AstraZeneca developed, yes.
`BY MR. SHELHOFF:
` Q And can you just explain the
`difference between esomeprazole Nexium®
`and omeprazole Prilosec?
` A Certainly. They are enantiomers
`of each other, E-N-A-N-T-I-O-M-E-R, also
`known as optical isomers. So they are
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`mirror images structurally of each
`other.
` Q So what did the character say
`that esomeprazole Nexium® is the
`enantiomer of omeprazole Prilosec?
` A Yes. It's -- yes.
` Q If you want to clarify or
`amplify your prior answer, you are free
`to do so.
` A That's okay.
` Q So I believe previously you
`testified three years ago that at
`AstraZeneca you were involved in
`generating some data on acid suppression
`of different proton-pump inhibitors.
` So just to clarify that, can you
`just explain a little bit more your
`prior testimony, whether it specifically
`pertains to esomeprazole Nexium®?
` MS. FORREST: Objection.
` Foundation. You haven't shown him
` his prior testimony.
` MR. SHELHOFF: Let me rephrase
` that.
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`BY MR. SHELHOFF:
` Q So most of your clinical
`research at AstraZeneca has been focused
`on esomeprazole Nexium®, correct?
` A No.
` Q What other products have you
`worked on?
` A Many other products. Something
`called VIMOVO®. Something called
`MOVANTIK®. Numerous biologic for
`multiple indications.
` Q Esomeprazole is one of the
`active pharmaceutical ingredients in the
`VIMOVO® product, correct?
` A I believe that's true, yes.
` Q The other one being naproxen,
`correct?
` A Correct.
` Q So esomeprazole is a proton-pump
`inhibitor, correct?
` A Yes.
` Q And naproxen is the anti --
`nonsteroidal anti-inflammatory compound,
`correct?
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` A Non-steroidal anti-inflammatory
`drug. NSAID it's abbreviated.
` Q So naproxen is one of the --
`belongs to the class of the compounds
`called NSAIDs -- commonly called NSAIDs?
` A Yes.
` Q You mentioned also one other
`specific product by name.
` What was that again?
` MS. FORREST: And I will just
` caution you not to reveal any of
` AstraZeneca's information that may
` still be confidential.
` THE WITNESS: VIMOVO®.
`BY MR. SHELHOFF:
` Q No. The other one you mentioned
`by name. I just want to get some very
`general information about it, nothing
`that specific.
` A MOVANTIK®.
` Q Yes.
` What kind of product is that?
` A It's an opioid receptor
`antagonist.
`
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` Q So it's not a proton-pump
`inhibitor?
` A No.
` Q And also you mentioned that you
`worked on several biologics when you
`were at AstraZeneca.
` Can you just, if you recall,
`name some of them.
` MS. FORREST: Same caution
` about confidentiality.
` THE WITNESS: Hm-hm. Sure.
` I worked on Anifrolumab,
` A-N-I-F-R-O-L-U-M-A-B.
`BY MR. SHELHOFF:
` Q What kind of compound is that?
` A It's an anti-interferon
`antibody.
` Q Okay.
` That's good enough for my
`purposes.
` A Okay.
` Q Anything else?
` A Something called Durvalumab,
`D-U-R-V-A-L-U-M-A-B.
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` Q What kind of compound is that?
` A It's an anti-PD-L1 antagonist.
` Q Okay.
` So it's not a proton-pump
`inhibitor?
` A No.
` Q Anything else?
` A That's what I can remember right
`now.
` Q So it's safe to say that at
`AstraZeneca the proton-pump inhibitors
`which you worked with were esomeprazole
`and omeprazole used as an active
`control, correct?
` A I did work with those two, yes.
` Q So of the 17 years at
`AstraZeneca, how many years were you
`involved in clinical research on
`esomeprazole?
` A Well, six for just esomeprazole
`by itself.
` Q And did you have -- were you
`involved at AstraZeneca with
`esomeprazole research on different
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`formulations of esomeprazole?
` A Can you clarify what you mean by
`"different formulations"?
` Q What kind of formulations of
`esomeprazole were you involved in?
` A I worked on an intravenous
`formulation. I worked on a couple of
`combination formulations where
`esomeprazole was combined with another
`agent.
` Q Okay.
` And would you understand that if
`I say IV esomeprazole, it refers to the
`intravenous formulation of esomeprazole?
` A Yes.
` Q So can you explain a little bit
`more of your work on the IV formulation
`of esomeprazole?
` A I was the lead medic for the
`regulatory submissions to get the IV
`formulation of Nexium® approved.
` Q And what does it involve to be a
`lead medic for the regulatory
`submissions?
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` A It involves planning, executing,
`interpreting the trials and then
`providing all clinical input to the
`regulatory submissions to get that
`formulation approved in various
`geographic regions.
` Q When you say "various geographic
`regions," what do you mean by that?
` A US, Canada, Europe, some parts
`of Asia.
` Q So you also mentioned that you
`worked on a couple of combination
`formulation of esomeprazole.
` What were those?
` A One was a combination of
`low-dose aspirin and esomeprazole. And
`another was a combination of Naprosyn
`with esomeprazole.
` Q And the latter one, the
`combination of Naprosyn and
`esomeprazole, that is what is known as
`under the trade name VIMOVO®, correct?
` A A specific formulation of those
`two combinations was approved as
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`VIMOVO®, yes.
` Q So by that you mean specific
`dosage forms, right?
` A Dosage forms and various
`coatings around the Naprosyn and around
`the proton-pump inhibitors in a specific
`combination.
` Q Okay.
` But the dosage forms, if you
`recall, for VIMOVO® would be 375 mgs of
`naproxen and 20 mgs of esomeprazole, and
`the second dosage form would be 500 mgs
`of naproxen and 20 of esomeprazole,
`correct?
` MS. FORREST: Objection.
` Foundation.
` THE WITNESS: When I worked on
` VIMOVO®, those are the dosage forms
` that we sought to get approval for
` and were approved.
`BY MR. SHELHOFF:
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` Q So now going back to the VIMOVO®
`product.
` Where did VIMOVO® -- where did
`the idea for the VIMOVO® product
`originate?
` MS. FORREST: Object to the
` form.
`BY MR. SHELHOFF:
` Q How did you learn about the
`VIMOVO® product?
` A I learned because I was asked to
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`go visit a company in North Carolina
`called Pozen, to go talk to them about
`an idea they had for combining
`proton-pump inhibitors with NSAIDs.
` Q And -- so when -- so to your
`knowledge, it was Pozen who approached
`AstraZeneca with respect to the
`esomeprazole/naproxen combination -- I'm
`sorry.
` So to your knowledge, it was
`Pozen who approached AstraZeneca with
`the idea of a combination product?
` MS. FORREST: Objection.
` Foundation. Mischaracterizes his
` testimony.
` THE WITNESS: Yeah, I don't
` know.
`BY MR. SHELHOFF:
` Q Okay.
` But you do know that there was a
`due diligence team from AstraZeneca,
`which went on site to North Carolina to
`investigate Pozen's proposal, correct?
` MS. FORREST: Objection.
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` Foundation.
` THE WITNESS: I do know that,
` yes.
`BY MR. SHELHOFF:
` Q So you were part of that due
`diligence team, correct?
` A Yes.
` Q And going back to the
`esomeprazole formulations that you
`worked with at AstraZeneca -- I suppose
`you are not a formulator, right?
` A I am not a formulator, no.
` Q So those IV formulation of
`esomeprazole and combination formulation
`of esomeprazole and naproxen, you worked
`with them from the perspective of
`clinical specialists should I say?
` MS. FORREST: Object to the
` form and compound.
` THE WITNESS: Clinical
` researcher.
`BY MR. SHELHOFF:
` Q Okay.
` THE REPORTER: 17.
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` (Exhibit 17 is Marked.)
`BY MR. SHELHOFF:
` Q Marking as Exhibit 17 --
` MS. FORREST: Do you have a
` copy?
` MR. SHELHOFF: Yes.
` So this is a printout from the
` SciFinder website of Dr. Sostek's
` publications.
`BY MR. SHELHOFF:
` Q So, Dr. Sostek, are you familiar
`with SciFinder?
` (Reporter Clarification.)
` A No.
` Q When you do your clinical trial
`research, how do you get your
`references?
` A I use something called Ovid or
`PubMed.
` MR. SHELHOFF: Speaking about
` PubMed, marking as Exhibit 18, a
` printout from PubMed.
` (Exhibit 18 is Marked.)
` THE WITNESS: (Reviewing.)
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`BY MR. SHELHOFF:
` Q So what you have before you in
`Exhibit 18, does it look familiar to you
`as something that one would obtain from
`PubMed?
` A (Reviewing.)
` It's a listing of some
`publications that I have been a
`co-author on.
` Q Okay.
` So this listing -- I will
`represent to you that I just did this
`search yesterday and pulled out your
`publications from PubMed. So contains
`about -- this list contains certified
`publications.
` So could you just quickly look
`through them to confirm that these are,
`in fact, your publications.
` MS. FORREST: I'm sorry.
` Dmitry, I have 20 on my list. Do
` you have a different list?
` MR. SHELHOFF: It's because --
` (Reviewing.)
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` Right. I am not sure what
` happened here. It says 1 of 20
` certified. It might have printed
` out only some of the pages rather
` than all the pages that would have
` contained certified publications.
`BY MR. SHELHOFF:
` Q Okay.
` So what we have here, though,
`is -- because it's per page, so it
`printed only the first 20.
` All right. That's fine.
` So with respect to the 20
`publications on my printout, can you
`just look through them and confirm those
`are your publications?
`
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