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`UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`-----------------------------x
`ALTAIRE PHARMACEUTICALS, INC.,
` Petitioner,
` vs.
`PARAGON BIOTECK, INC.,
` Patent Owner.
`
`Case PGR2015-00011
`
`Patent 8,859,621
`
`-----------------------------x
`
` C O N F I D E N T I A L
`
` DEPOSITION OF ASSAD SAWAYA
` Wednesday, January 20, 2016
` Riverhead, New York
`
`REPORTED BY:
`Christina Diaz, CRR, RMR, CSR, CLR
`Job Number: 102291
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`PARAGON - EXHIBIT 2034
`REDACTED 4/8/2016
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`UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`-----------------------------x
`ALTAIRE PHARMACEUTICALS, INC.,
` Petitioner,
` vs.
`PARAGON BIOTECK, INC.,
` Patent Owner.
`
`Case PGR2015-00011
`
`Patent 8,859,621
`
`-----------------------------x
`
` C O N F I D E N T I A L
`
` DEPOSITION OF ASSAD SAWAYA
` Wednesday, January 20, 2016
` Riverhead, New York
`
`REPORTED BY:
`Christina Diaz, CRR, RMR, CSR, CLR
`Job Number: 102291
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` January 20, 2016
` 9:00 a.m.
`
` Deposition of ASSAD SAWAYA, at the
`Holiday Inn Express, 1707 Old Country Road,
`Riverhead, New York, before Christina Diaz, a
`Certified Realtime and Registered Merit
`Reporter and Notary Public within and for the
`State of New York.
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` A P P E A R A N C E S
`
`DICKSTEIN SHAPIRO
`Attorneys for Petitioner
` 1825 Eye Street NW
` Washington, DC 20006
`BY: DIPU DOSHI, ESQ.
`BY: JONATHAN ENGLAND, ESQ.
`
`WILSON SONSINI GOODRICH & ROSATI
`Attorneys for Patent Owner
` 701 Fifth Avenue
` Seattle, WA 98104
`BY: ANDREW BROWN, ESQ.
`BY: SONJA GERRARD, ESQ.
`
`ALSO PRESENT:
` MICHAEL S. SAWAYA;
` Altaire Pharmaceuticals, Inc.
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` A. Sawaya - Confidential
` MR. BROWN: Andy Brown of Wilson
` Sonsini Goodrich & Rosati on behalf of
` Paragon. And with me is Sonja Gerrard.
` MR. DOSHI: Dipu Doshi from
` Dickstein Shapiro on behalf of the
` petitioner, Altaire Pharmaceuticals.
` With me is John England, also of
` Dickstein Shapiro, and Michael Sawaya of
` Altaire Pharmaceutical.
`A S S A D S A W A Y A,
` having been duly sworn by a Notary
` Public, was examined and testified as
` follows:
`EXAMINATION
`BY MR. BROWN:
` Q. Good morning, Mr. Sawaya.
` A. Good morning.
` Q. What's your full legal name?
` A. A-S-S-A-D, S-A-W-A-Y-A.
` Q. Is that Assad Sawaya?
` A. Right.
` Q. Do you also go by the name Al?
` A. Well, most people around call me Al
`for short.
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` A. Sawaya - Confidential
` Q. Have you ever been deposed before?
` A. Sure.
` Q. How many times?
` A. I don't remember. A couple of
`times.
` Q. In connection with what sort of
`matters were those depositions?
` A. I don't -- I'm not going to recall
`that at this point.
` Q. Were they patent disputes?
` A. No.
` Q. So you are likely familiar with some
`of the rules, and I expect that your attorneys
`have explained them to you as well, but I'm
`just going to cover a few things briefly.
` Is that okay?
` A. Please. Be my guest.
` Q. The first thing is the court
`reporter is taking down everything we say, and
`so please try to answer verbally and do your
`best not to talk over me, and I'll do my best
`not to talk over you.
` Okay?
` A. I'm going to be myself and I'm going
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` A. Sawaya - Confidential
`to act as I am as a person.
` Q. Wonderful.
` A. I don't care what you do.
` Q. If at any point you'd like to take a
`short break, please let me know and that's
`perfectly okay. My only request would be that
`you try to wait until after you've answered a
`question to take a break.
` Is that okay?
` A. Fine. Thank you.
` Q. Mr. Sawaya, what do you do?
` A. I work. I'm president of Altaire
`Pharmaceuticals, and so I work as the
`president and run the company.
` Q. Do you have any other jobs right
`now?
` A. No.
` Q. What are your responsibilities as
`president of Altaire Pharmaceuticals?
` A. To run the company properly under
`proper fiduciary duties, and make as much
`money as I can possibly make for the company.
` Q. Who do you report to as president of
`Altaire Pharmaceuticals?
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` A. No one.
` Q. Does Altaire Pharmaceuticals have a
`board of directors?
` A. Yes.
` Q. Who is on the board of directors of
`Altaire Pharmaceuticals?
` A. Only two people.
` Q. Who are those two people?
` A. Myself and Theresa Sawaya.
` Q. Who is Theresa Sawaya?
` A. My wife.
` Q. How long have you been married?
` A. Only going on 25 years.
` Q. You founded Altaire Pharmaceuticals,
`correct?
` A. Correct.
` Q. When did you found Altaire
`pharmaceuticals?
` A. I don't know the precise date, but
`it would have to be in the 19- -- in late
`1990s.
` Q. And you founded it with your wife?
` A. Right.
` Q. Is that where the name Altaire came
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` A. Sawaya - Confidential
`from, your first name and her first name?
` A. That's the way it worked out.
` Q. What is Theresa Sawaya's role at
`Altaire Pharmaceuticals other than being on
`the board of directors?
` A. She's basically like -- takes care
`of the accounts payable, the receivables. In
`charge of all accounting. In charge of
`purchasing and general office managerial
`capabilities as needed.
` Q. If there is a disagreement between
`yourself and Theresa Sawaya regarding a
`decision with respect to the company, whose
`vote -- who wins?
` MR. DOSHI: Objection. Beyond the
` scope.
` You can answer.
` A. I don't want to answer.
`BY MR. BROWN:
` Q. You don't want to answer?
` A. No.
` MR. DOSHI: I made the objection.
` You can answer.
` THE WITNESS: I can answer?
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` A. Sawaya - Confidential
` MR. DOSHI: Yes.
` A. Could you repeat the question?
`BY MR. BROWN:
` Q. When there's a disagreement on the
`board of directors of Altaire Pharmaceuticals,
`which consists of you and your wife, whose
`opinion wins out?
` MR. DOSHI: Same objection.
` You can answer.
` A. There's agreement where the
`decisions are made, or if there's a dispute,
`are resolved according to the need and the
`requirements of the corporation. And we go
`through the process of the pros and cons for
`the decision, and one party will eventually
`convince the other. It's only done because it
`is -- it's a good thing to do, and it's proper
`and legal.
`BY MR. BROWN:
` Q. Do you understand why we're here?
` A. Yes. You have -- you're taking my
`deposition.
` Q. Altaire Pharmaceuticals filed a
`request for a post grant review of a patent
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`owned by Paragon, is that correct?
` A. Yes.
` Q. Who at Altaire made the ultimate
`decision to file the petition for a post grant
`review?
` A. Myself is one, I'm one of them, and
`any other legal advice on --
` MR. DOSHI: I'll just caution you
` not to disclose any attorney-client
` privilege, any discussions you had with
` your attorneys on the subject.
` THE WITNESS: Right.
` MR. DOSHI: He's just asking for
` who, individuals.
` THE WITNESS: Who?
` MR. DOSHI: Yes.
` THE WITNESS: What does that mean?
` I don't understand the question.
`BY MR. BROWN:
` Q. Somebody at Altaire has ultimate
`decision-making authority, correct?
` MR. DOSHI: Objection. Assumes
` facts not in evidence.
` I made the objection. You can go
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` A. Sawaya - Confidential
` ahead and answer the question.
` A. Well, I could make that decision.
`BY MR. BROWN:
` Q. Did you make that decision?
` MR. DOSHI: Same objection.
` A. Yes, I made the decision.
`BY MR. BROWN:
` Q. Why did you feel that it was good
`for Altaire Pharmaceuticals to file the
`petition requesting post grant review?
` MR. DOSHI: Objection. Assumes
` facts not in evidence, and beyond the
` scope.
` A. I'm not going to answer that
`question because it doesn't deserve an answer.
`It's loaded with a lot of crap.
` MR. BROWN: Okay. Gentlemen, this
` is cross-examination. I'm going to
` request that we limit the amount of
` coaching that we do with the witness.
` MR. SAWAYA: Excuse me. I'm not
` coaching. I'm talking to counsel as to
` whether we want to take a break or not.
` Please don't put things on the record
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` that's not happening, Counsellor. I
` think be we need take a break.
` MR. DOSHI: Yes, let's take a break.
` MR. BROWN: Let's take a short
` break.
` (Recess: 9:11 a.m. to 9:13 a.m.)
`BY MR. BROWN:
` Q. Mr. Sawaya, during the break, were
`you speaking with your attorneys?
` A. I spoke with my son.
` Q. Who is your son?
` A. Michael.
` Q. Michael Sawaya?
` A. Yes.
` Q. And he's sitting at the end of the
`table?
` A. Yes.
` Q. Is he also your attorney?
` A. No.
` Q. What did he tell you during the
`break?
` A. To calm down.
` Q. Did he say anything else?
` A. No.
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` Q. Did you discuss the substance of
`your testimony with the attorneys from
`Dickstein Shapiro?
` A. No.
` Q. Mr. Sawaya, why did you feel that it
`was good for Altaire Pharmaceuticals to file
`the petition requesting post grant review
`against Paragon's patent?
` MR. DOSHI: Objection. Beyond the
` scope. And objection. Assumes facts not
` in evidence.
` And I caution the witness not to
` divulge any attorney-client privilege
` communications.
` A. Because in the process of the patent
`itself, it was not a very good patent and
`should not have been issued.
`BY MR. BROWN:
` Q. At the time the patent issued,
`Altaire Pharmaceuticals was an exclusive
`distributor for Paragon for the product that
`is the subject of the patent, is that correct?
` A. It was exclusive distributor and the
`only approved manufacturer for the product.
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` Q. Pardon me. I believe I misspoke. I
`should have said exclusive manufacturer. Is
`that right?
` A. The only manufacturer.
` Q. So how would Altaire Pharmaceuticals
`benefit by the patent at issue in this
`proceeding being found unpatentable?
` MR. DOSHI: Objection. Beyond the
` scope.
` A. It's not a matter of benefit,
`whether Altaire gets benefit or not. It's
`whether the patent is truthful or not. And it
`should not have been filed because it's not
`based on any science that -- it's not based on
`any sound science.
`BY MR. BROWN:
` Q. Do you have any technical degrees?
` A. Technical what?
` Q. Degrees.
` A. No.
` Q. What's the highest level of
`education you've attained?
` A. I have a lifetime of experience and
`knowledge that goes back 40 years which is
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`loaded with expertise and experience in all
`the sciences, which includes chemistry,
`microbiology, pharmaceutical development,
`industrial application, clean room technology,
`managing and supervising technical staff of
`all sorts in many different companies, in many
`different situations. So I'm an analyst. So
`if that's what you are after, this is what I
`am.
` Q. When you say you're an analyst, what
`do you mean?
` A. I can look at the data, if it's
`properly formed, and prepared and make a
`judgment as to its soundness.
` Q. Are there any sciences that you
`don't feel you're an expert in?
` MR. DOSHI: Objection. Vague.
` A. Sure. I'm not a physicist or an
`astronaut or a physician. And with regard to
`pharmaceutical and pharmaceutical application
`and development, I have a lifetime of
`considerable experience that had served me and
`all the companies and the people that I worked
`with very well.
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`BY MR. BROWN:
` Q. What's the highest level of formal
`education you've attained?
` A. I have no degrees, if that's what
`you want.
` Q. How do the shareholders of Altaire
`Pharmaceuticals stand to benefit from the
`patent at issue in this proceeding being
`deemed unpatentable?
` MR. DOSHI: Objection. Beyond the
` scope. Assumes facts not in evidence.
` A. It would return and restore the
`science of phenylephrine to where it belongs
`without any fantasy.
`BY MR. BROWN:
` Q. Who are the shareholders of Altaire
`Pharmaceuticals?
` A. Myself and my wife.
` Q. Are there any other shareholders?
` A. No.
` Q. Does your son, Michael Sawaya, have
`any role at Altaire Pharmaceuticals?
` A. He works there.
` Q. What is his job at Altaire
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`Pharmaceuticals?
` A. His title is general counsel, and he
`helps in a lot of the FDA applications for
`NDAs and ANDAs and this kind of stuff.
` Q. How many employees does Altaire
`Pharmaceuticals have?
` A. I can't say for sure what the number
`is, but I have a feeling it would -- I can
`give you an approximate number. It keeps
`shifting back and forth. Maybe around 120,
`but you can't hold me to this.
` Q. In terms of the individuals with
`executive responsibilities at Altaire
`Pharmaceuticals, is there anybody other than
`yourself and your wife, Theresa Sawaya?
` MR. DOSHI: Objection. Vague.
` A. Please explain to me what the
`question is all about.
`BY MR. BROWN:
` Q. I'm trying to determine essentially
`whether there's anybody else who helps you and
`your wife with running the company.
` A. Obviously, there is a whole lot of
`staff in there that helps run the company.
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`You have managers, quality assurance managers,
`manufacturing managers, quality control
`managers, R&D managers, pharmaceutical
`development managers, packaging managers.
`There's all kinds of, you know -- this is a
`normal corporation with managers and
`structure.
` Q. You are the president of Altaire
`Pharmaceuticals, correct?
` A. Correct. You've asked that before.
` Q. Who are the other officers of
`Altaire Pharmaceuticals?
` A. I don't understand the question.
` Q. The president of a corporation is a
`corporate officer, correct?
` A. Right.
` Q. Are there any other corporate
`officers of Altaire Pharmaceuticals?
` A. There's my wife, Theresa, corporate
`officer. And Joseph Sawaya is an officer.
` THE WITNESS: I don't know what he
` means by officers, so...
`BY MR. BROWN:
` Q. Is Theresa Sawaya the treasurer of
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`Altaire Pharmaceuticals?
` A. Yes.
` Q. Who is Joseph Sawaya?
` A. Okay. He's the sales and marketing
`manager, director, whatever.
` Q. Is he also related to you?
` A. Yes.
` Q. How is he related to you?
` A. He's my brother, and I love him.
` Q. Are there any officers of Altaire
`Pharmaceuticals that are not related to you?
` A. Perhaps if you can enlighten me and
`describe to me what do you mean, if there's a
`legal meaning to what you consider an officer
`of the corporation, because I don't understand
`what you're asking me.
` Q. You were involved in the formation
`of Altaire Pharmaceuticals, correct?
` A. Right.
` Q. And you are the president of Altaire
`Pharmaceuticals, correct?
` A. Correct. You asked that before.
` Q. But you're telling me you don't know
`who the corporate officers of Altaire
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` A. Sawaya - Confidential
`Pharmaceuticals are?
` A. I know who they are, but I don't
`understand your question as to whether there
`is any legal ramification, and so I need you
`to enlighten mean. What do you mean by that,
`an officer?
` Q. I'm afraid I can't give you legal
`advice. But I just wanted to know whether you
`knew who the corporate officers are.
` Are you telling me you don't?
` A. Well, I just told you who they are.
`Myself and my wife.
` Q. Why did you found Altaire
`Pharmaceuticals?
` MR. DOSHI: Objection. Beyond the
` scope.
` A. What kind of question is that, why?
`Because I want to be in business.
`BY MR. BROWN:
` Q. You are aware of the company Sawaya
`Aquebogue, if I'm saying that correctly?
` A. Aquebogue.
` Q. Is Sawaya Aquebogue a company that
`you founded as well?
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` A. Sawaya - Confidential
` A. It's a holding real estate company.
` Q. What was the -- sorry. Withdrawn.
` It is a limited liability company,
`correct?
` A. Right.
` Q. And it was also formed by you?
` A. It was formed by me and my wife.
` Q. And Sawaya, of course, is your last
`name, correct?
` A. Right.
` Q. Where does Aquebogue come from?
` A. That's the town where the facility
`is located.
` Q. Which facility?
` A. The Altaire manufacturing facility.
` Q. Are there any other Altaire
`facilities?
` A. There are warehousing facilities
`outside of Aquebogue.
` Q. Which real state does Sawaya
`Aquebogue hold?
` A. Sawaya Aquebogue holds the property
`which is located in Aquebogue. The property
`that was part of -- holds the property as part
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` A. Sawaya - Confidential
`of Aquebogue, and it's a substantial real
`estate holding.
` Q. Does Sawaya Aquebogue hold any real
`estate that is not currently being used by
`Altaire Pharmaceuticals?
` A. There would only be minor, minor
`real estate holdings.
` Q. Can you give me any examples of such
`minor real estate holdings?
` A. Maybe a house or things of this
`sort. Very simple.
` Q. Are you thinking of any houses in
`particular?
` A. No. Just a house that we -- you
`know, Sawaya Aquebogue might hold.
` Q. Does -- where do you presently live?
` A. I live in Baiting Hollow.
` Q. Does Sawaya Aquebogue hold your
`property in Baiting Hollow?
` A. No.
` Q. Why did you form Sawaya Aquebogue?
` MR. DOSHI: Objection. Beyond the
` scope.
` A. Okay. Now -- it was formed at the
`
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` A. Sawaya - Confidential
`time the property was issued a bond, and it
`was purchased as holding Sawaya Aquebogue.
`And it was a state bond that was where it was
`purchased, and then, since then, it's been
`satisfied. So then that's how it happens that
`Sawaya Aquebogue came into being and became a
`holding company for the property that was
`issued to it in the bond.
`BY MR. BROWN:
` Q. I believe you mentioned a state
`bond. When you mentioned that, were you
`referring to a New York State bond?
` A. Right.
` Q. Who are the members of Sawaya
`Aquebogue, LLC?
` A. There are two general partners, and
`there are -- the other three are my three
`sons.
` Q. Who are the two general partners?
` A. Myself and my wife.
` Q. And the other three members are a
`different tier than you and your wife?
` A. Okay. They are my sons, yes.
` Q. Sorry. Let me try to ask a better
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` A. Sawaya - Confidential
`question. You said you and your wife are
`general partners, correct?
` A. (Nodding affirmatively).
` Q. Your sons are also members of the
`LLC, correct?
` A. Right.
` Q. But they are not general partners?
` A. No.
` Q. What are they?
` A. Okay. They have -- they're just
`partners.
` Q. Do they have a different level of
`control over the LLC?
` A. Only in terms of percentage of
`ownership.
` Q. What percentage of ownership do they
`have?
` A. I can't say that because I don't
`know.
` Q. Can you give a rough estimate?
` A. I can't.
` Q. What percentage of ownership do you
`and your wife have in the LLC?
` A. I don't know. I can't answer the
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` A. Sawaya - Confidential
`question.
` Q. If you wanted to find out, who would
`you ask?
` A. I would ask my wife and the -- and
`the LLC trust, just check it out. I mean, I'm
`not familiar with the intricate detail of the
`percentages and who is who and what. It's
`just a holding company. That's all it is.
` Q. Who are your -- sorry. Withdrawn.
` How many sons do you have?
` A. Three sons.
` Q. And all three are members of the
`LLC?
` A. Right.
` Q. If I say the LLC, do you understand
`that I'm referring to Sawaya Aquebogue?
` A. Right.
` Q. One of your sons is Michael Sawaya,
`correct?
` A. Right.
` Q. Who are your other two sons?
` A. Alan Sawaya and Paul Sawaya.
` Q. You are the general manager of
`Sawaya Aquebogue, LLC, correct?
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` A. Sawaya - Confidential
` A. I'm one of the general partners, not
`the -- not the general -- the only general,
`you know. It's shared.
` Q. But you are the general manager,
`correct?
` A. One of the general managers.
` Q. Who are the other general managers?
` A. My wife.
` Q. And is the decision-making process
`for Sawaya Aquebogue, LLC, similar as it is
`for Altaire Pharmaceuticals?
` A. No relationship whatsoever. The
`decision process is only a process of the
`holding company, and it's like a dormant thing
`that we...
` Q. Who makes decisions for Sawaya
`Aquebogue, LLC?
` MR. DOSHI: Objection. Vague.
` A. A decision is made between the two
`general partners with consultation with our
`accountant, because this thing is nothing but
`a real estate holding that doesn't require any
`other management other than a real estate
`holding. And frankly, I don't get -- it might
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` A. Sawaya - Confidential
`be years before -- could go by before I even
`know that I have that holding. It's just a
`passive holding that doesn't require any --
`that much of my time.
` Q. If it's a passive holding, what was
`the purpose of forming it?
` MR. DOSHI: Objection. Beyond the
` scope.
` A. It was a real -- real estate
`holding, and that's all that it is. It's
`formed as a real estate holding and collects
`income, pays taxes. And all of these things
`are done through simple real estate -- normal
`real estate transactions and accountants, pay
`the taxes, and that's all there is.
`BY MR. BROWN:
` Q. You mentioned that your son, Michael
`Sawaya, is one of the members of the LLC,
`correct?
` A. He is one, yes.
` Q. Does he have any other role with the
`LLC?
` A. No.
` Q. Does the LLC have a general counsel?
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` A. Sawaya - Confidential
` A. No.
` Q. Does the LLC have any lawyers
`representing it?
` A. No.
` Q. Does Dickstein Shapiro represent the
`LLC?
` MR. DOSHI: Objection. Vague.
` A. No.
`BY MR. BROWN:
` Q. You mentioned income to the LLC.
`Where does that --
` A. Rent.
` Q. Where does the LLC receive income?
` A. It receives rent for renting the
`property to Altaire Pharmaceuticals.
` Q. Does it have any other sources of
`income?
` A. I don't know.
` Q. Who negotiated the lease agreements
`between Sawaya Aquebogue and Altaire
`Pharmaceuticals?
` A. Basically, in conjunction with our
`accountant and the general partners, one of
`the general partners, which is my wife, they
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` A. Sawaya - Confidential
`figured out the rents necessary.
` Q. Who represented Sawaya Aquebogue in
`those negotiations?
` A. Nobody. None was necessary.
` Q. Why was none necessary?
` A. Tell me why it's necessary. It's
`just a real estate holding. It owns the
`property, charges rent, collects the rent,
`pays its own taxes.
` Q. Sawaya Aquebogue also holds
`, correct?
` A. Sawaya Aquebogue holds
`.
` Q. Why would a real estate holding
`company want
`?
` MR. DOSHI: Objection. Vague.
` A. I don't know why.
`BY MR. BROWN:
` Q. You're a general part of Sawaya
`Aquebogue, correct?
` A. Right. Yes.
` Q. But you don't know why?
` A. Well, I don't know why you're asking
`
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` A. Sawaya - Confidential
`the question. It's obvious that Sawaya
`Aquebogue does hold
`, which were transferred based on the
`agreement that Paragon has with Altaire
`Pharmaceuticals.
` Q. I'm trying to determine where the
`line is between Altaire Pharmaceuticals and
`Sawaya Aquebogue.
` A. Let me explain it to you very
`bluntly.
` Q. Please do.
` A. Okay. Sawaya Aquebogue is nothing
`but a holding company. It does not transact
`anything. It's not in any business to make
`any income or anything other than the real
`estate. It's not interested or will it be
`ever interested in any kind of other business
`or any pharmaceuticals. There is no such
`thing. And Altaire is not interested in
`anything but being a manufacturer of --
`developer and manufacturer of pharmaceutical
`products. They're two separate entities.
`They don't overlap and they don't hold the
`same goal.
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` Q. When you say -- sorry. Please
`continue.
` A. No, please ask.
` Q. When you say they don't overlap,
`what do you mean?
` A. Okay. Sawaya Aquebogue is only
`involved in real estate as a holding company.
` Q. It also owns
`
`, doesn't it?
`
` A.
`
` Q. Why is a company uninterested in
`pharmaceuticals interested in owning
`?
` MR. DOSHI: Objection.
` A. Well, it's a holding company. It
`just holds
`.
`BY MR. BROWN:
`?
` Q. Why does it hold
` A. Because it was part of an agreement
`that
` were given to Sawaya
`Aquebogue to hold
`.
` Q. Why didn't Altaire take ownership of
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` A. Sawaya - Confidential
`?
` A. Because Altaire is not interested in
`owning
`
`, because
`only Altaire's interest is in strictly
`pharmaceutical development and manufacturing
`and it's not interested in holding
`.
` Q. Yet a company only interested in
`real estate and not interested in
`pharmaceuticals is interested in holding
`, correct, that's what you're
`testifying?
` A. What I'm testifying is Sawaya
`Aquebogue is just a holding company. It's not
`involved in anything else but as a holding
`company. It's just real estate, and that's
`all that it is.
` Q. Sawaya Aquebogue -- excuse me.
`Withdrawn.
` Sawaya Aquebogue is run by you and
`your wife, correct?
` MR. DOSHI: Objection.
` Mischaracterizes.
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` A. I don't know what's going on.
`BY MR. BROWN:
` Q. Sawaya Aquebogue is run by you and
`your wife, correct?
` MR. DOSHI: Same objection. Go
` ahead.
` A. We are the general partners. You've
`asked this question before. Please don't ask
`it again because you're getting me tired.
`Okay?
`BY MR. BROWN:
` Q. If you need to take a break, let me
`know and we can take one. Okay?
` A. I don't need to take a break, but
`you need to really understand, you can't keep
`asking the same question over and over again.
`Because how many times do I have to answer it?
` MR. DOSHI: Calm down.
` All right. What's the question?
`BY MR. BROWN:
` Q. Sawaya Aquebogue is run by you and
`your wife, correct?
` MR. DOSHI: Okay. Objection.
` Mischaracterizes. Asked and answered.
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` A. Sawaya - Confidential
` Go ahead.
` A. Yes. As two general partners.
`BY MR. BROWN:
` Q. Altaire Pharmaceuticals is also run
`by you and your wife, correct?
` MR. DOSHI: Objection.
` Mischaracterizes the prior testimony.
` Asked and answered.
` A. I'm president of Altaire
`Pharmaceuticals, and Altaire Pharmaceuticals
`is in the business of developing,
`manufacturing and distributing
`pharmaceuticals. My wife is also involved in
`managing Altaire Pharmaceuticals. There are
`many other staff and people that help and
`manage Altaire Pharmaceuticals. This is the
`business that we're in, developing,
`manufacturing, distributing pharmaceuticals.
`BY MR. BROWN:
` Q. Was that a yes?
` MR. DOSHI: Objection. Argumentive.
` A. I don't understand.
`BY MR. BROWN:
` Q. You and
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