`
`IN THE UNITED STATES
`PATENT AND TRADEMARK OFFICE
`-------------------
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`-------------------
`TEVA PHARMACEUTICALS USA, INC.
`Petitioner,
`
`V.
`CORCEPT THERAPEUTICS, INC.
`Patent Owner.
`------------------
`PGR2019-00048
`Patent 10,195,214 B2
`------------------
`
`VIRTUAL DEPOSITION OF DR. LAURENCE KATZNELSON
`May 26, 2020
`
`Reported by:
`ERICA L. RUGGIERI, RPR
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`800-642-1099
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`David Feldman Worldwide
`A Veritext Company
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`www.veritext.com
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`TEVA1071
`Teva Pharmaceuticals USA, Inc. v. Corcept Therapeutics, Inc.
`PGR2019-00048
`
`
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`Page 2
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`May 26, 2020
`11:02 a.m.
`
`Deposition of DR. LAURENCE
` KATZNELSON, held by Virtual Zoom
` Conference, pursuant to Notice, before
` Erica L. Ruggieri, Registered
` Professional Reporter and Notary
` Public of the State of New York.
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`A P P E A R A N C E S:
`
`ATTORNEYS FOR TEVA PHARMACEUTICALS USA, INC.:
`STERNE KESSLER GOLDSTEIN & FOX PLLC
` 1100 New York Ave NW, 6th Floor
` Washington DC 20005
` BY: UMA N. EVERETT, ESQ.
`ueverett@skgf.com
`DEBORAH A. STERLING, ESQ., Ph.D.
`dsterling@sternekessler.com
`WILLIAM MILLIKEN, ESQ.
`wmilliken@sternekessler.com
`
`ATTORNEYS FOR CORCEPT THERAPEUTICS, INC.:
`QUINN EMANUEL URQUHART & SULLIVAN LLP f
` 51 Madison Ave, 22nd Floor
` New York, New York 10010
` BY: ERIC STOPS, ESQ.
`ericstops@quinnemanuel.com
`JOHN P. GALANEK, ESQ.
`johngalanek@quinnemanuel.com
`DANIEL WIESNER, ESQ.
`danielwiesner@quinnemanuel.com
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`DR. KATZNELSON
` L A U R E N C E K A T Z N E L S O N,
` called as a witness, having been
` duly sworn by a Notary Public, was
` examined and testified as follows:
` EXAMINATION BY
` MS. EVERETT:
`Q.
`Good morning,
` Dr. Katznelson.
`A.
`Good morning.
`Q. I am Uma Everett. I am
` from Sterne Kessler Goldstein & Fox.
` I represent Teva Pharmaceuticals and
` I'll be taking your deposition
` today.
`Nice to meet you.
`A.
`Nice to meet you. Thank
`Q.
` you for your time. Dr. Katznelson,
` can you please state your full name
` for the record, please.
`A.
`Laurence Katznelson.
`Q.
`And what is your
` professional address?
`A.
`Stanford Hospital, 875
` Blake Wilbur Road, Stanford,
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`800-642-1099
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`David Feldman Worldwide
`A Veritext Company
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`www.veritext.com
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`DR. KATZNELSON
` California 94305-5821.
`Q.
`Have you ever been deposed
` before?
`I have.
`A.
`In what context?
`Q.
`I have been deposed twice,
`A.
` I believe twice, over a number of
` years. Both were cases regarding
` delay in diagnosis of disease so
` they were medical malpractice cases.
`Q.
`Were you an expert in those
` cases?
`In both I was an expert
`A.
` witness, yes.
`Q.
`Have you ever been deposed
` remotely?
`No, this is the first.
`A.
`Q. For all of us. We are
` getting used to it. So I'll just go
` over some basics which you probably
` know about but it's important we are
` both on the same page.
`As you'll note today we have a
` court reporter and she'll take down
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` DR. KATZNELSON
` my question and your answer. And
` it's more important than ever, even
` in your last ones, that we just give
` each other a pause so that I can end
` my question and you can state your
` answer completely. Mr. Stops may
` have objections through the day and
` we just have to work together to
` make sure everybody's statements are
` coming out and the court reporter
` can take it down.
` And if you need any breaks at
` any time today, please let me know,
` I'm happy to take them. Probably be
` taking them once every hour. I just
` ask that you wait till a question
` has finished, there will be no
` pending questions and then you can
` take a break.
` And you understand that today
` you are under oath?
` A. I do.
` Q. Okay. Is there any reason
` you can't testify truthfully and
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` DR. KATZNELSON
` accurately today?
` A. No.
` Q. Okay. And we talked about
` today's deposition is being
` conducted remotely, yes?
` A. Yes.
` Q. Are you in your personal
` residence?
` A. I am.
` Q. Can you describe the room
` in which you are sitting?
` A. It's my dining room.
` Q. Are you alone -- sorry, go
` on please if you wanted?
` A. No, no. It's my dining
` room. There's some birds chirping
` outside. It's -- yeah, nothing
` further.
` Q. Are you alone in your room?
` A. I am.
` Q. Do you have any materials
` with you today?
` A. I do. I have the documents
` that the attorneys sent me, my
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`800-642-1099
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` DR. KATZNELSON
` declaration. That's what I have.
` MR. STOPS: And just for
` clarity, I'll represent that we
` sent a copy of the declaration and
` the exhibits cited in, I believe,
` Exhibit B therein.
` MS. EVERETT: Okay. Terrific.
` Q. Do you have any other
` material in the room with you today?
` A. No. I have my phone with
` me, that's it.
` Q. Are you using your phone to
` communicate with anyone?
` A. No. I -- no, it's really
` just for my son if he has to reach
` me. He just want back to school in
` Boston. So if he needs any urgency,
` that's the only reason I have it on
` now.
` Q. How are you using the video
` platform now? Are you on a
` computer, a laptop computer?
` A. I'm on my Mac laptop on
` Zoom.
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` Q. Are you speaking with your
` counsel in any form other than your
` Mac laptop?
` A. No, I'm not.
` Q. Did you prepare for today's
` deposition?
` A. I did.
` Q. What did you do to prepare?
` MR. STOPS: And I'll object to
` the extent the question is seeking
` attorney-client communications. If
` you want to ask him a more specific
` question, that might not be
` objectionable.
` MS. EVERETT: What did you do
` to prepare is a pretty basic
` question, Eric. I'm not asking for
` your words. I'm asking what
` Dr. Katznelson --
` MR. STOPS: His answer could
` start divulging specifically what
` he -- what exactly we talked about.
` You can ask, you know, the basic
` questions so that he doesn't.
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` Q. Dr. Katznelson, don't
` reveal to me the specifics of what
` you discussed with Mr. Stops or any
` counsel that you met with to
` prepare, but generally what did you
` do to prepare for today's
` deposition?
` MR. STOPS: Objection. Calls
` for attorney-client communications.
` I instruct the witness not too
` answer. You can ask a more
` specific question. You are still
` asking the exact same question,
` what did you do to prepare.
` MS. EVERETT: I told him not
` to tell me about your
` communication. This is a pretty
` basic question. What did you do to
` prepare. Don't tell me about
` privileged communication. But what
` did you do. You are seriously
` instructing him not to answer?
` MR. STOPS: I guess I'm not
` sure what your question is. You
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` DR. KATZNELSON
` can ask him who, when, how long,
` what, but this is a completely
` open-ended question so I have a
` problem with the open-endedness of
` it.
` Q. Did you review any material
` to prepare for your deposition
` today, Dr. Katznelson?
` A. I reviewed the documents
` that we discussed that I received,
` including my declaration. I perused
` the patents and label and I have
` discussed this with my attorneys.
` Q. Did you speak to anybody
` besides your attorneys?
` A. I'm sorry, can you be more
` specific? In what capacity?
` Q. In preparation for your
` deposition today.
` A. I'm sorry, you are asking
` if I spoke to other individuals
` regarding the documents?
` Q. Regarding your preparation
` for your deposition today.
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` A. Oh, no. All my
` conversations have been privileged
` with the attorneys.
` Q. How long did you spend
` reviewing the materials to prepare
` for your deposition today?
` A. I spent a couple days. An
` evening or two reviewing the
` documents and a couple days
` reviewing these with the attorneys.
` Q. About how many hours did
` you prepare for your deposition
` today?
` A. I would say two days, each
` about seven hours and about several
` evenings of about two hours apiece
` approximately.
` Q. Okay. Now, I'm going to
` put in your declaration, which is
` Corcept Exhibit 2058. I'm moving it
` into the marked exhibits folder. So
` you should be able to see it in a
` moment.
` (Exhibit 2058, Declaration of
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` DR. KATZNELSON
` Dr. Laurence Katznelson, marked for
` identification, as of this date.)
` MR. STOPS: Dr. Katznelson,
` you may either have to click off of
` the folder or back on or refresh
` the page.
` A. Oh, there it is, okay.
` Q. So you can go ahead and
` either review it electronically and
` download. I know you said you have
` some paper versions of the same
` thing.
` A. Yeah, this looks very
` familiar. Okay, I am with you.
` Q. So Exhibit 2058 is the
` declaration that you submitted for
` this post grant review proceeding,
` correct?
` A. Yes.
` Q. And at the end of that is
` an Exhibit C where you have
` listed -- excuse me, Exhibit B I
` believe -- where you've listed all
` the materials you reviewed to
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` prepare your declaration?
` A. I'm sorry, which section
` are you referring to?
` Q. Exhibit B at the end of
` your declaration.
` A. Oh, Exhibit B, sorry.
` That's at the end of this? What
` page is it on? Can you help me?
` Q. Starts on 82.
` A. 82. Getting there. I wish
` there was a way to go directly to
` that page but. Okay, I see what you
` are referring to, yes.
` Q. In preparation for your
` deposition today, did you review any
` documents that are not listed in
` your Exhibit B?
` A. No.
` Q. In preparing your
` declaration did you review any
` materials that are not listed in
` Exhibit B?
` A. No.
` Q. Can you describe your
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` educational background for me,
` please?
` A. Sure. So my college I went
` to USC Berkeley, majored in
` genetics. I went to UCLA for
` medical school. After medical
` school I did a residency in internal
` medicine at the University of
` Pennsylvania.
` Following that I went to
` Massachusetts General Hospital for
` my fellowship in endocrinology and
` metabolism where I became board
` certified in endocrinology. I then
` stayed on on research and clinical
` faculty at Mass General Hospital at
` Harvard in the field of
` endocrinology, specializing in
` pituitary endocrine work where I
` became interested in diseases such
` as Cushing's disease.
` In 2004 I moved to be near
` family in the Bay area where I'm at
` Stanford University where I built
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` the pituitary program, both clinical
` research at Stanford. I am -- in my
` position I'm professor of medicines
` and neurosurgery. I'm also
` associate dean of all the graduate
` medical education so I run all the
` residency and fellowship programs at
` Stanford Hospital. And I maintain
` my interest in clinical and research
` work in pituitary disorders.
` Q. At the end you listed a
` number of roles. Can you state for
` me your current roles?
` A. Sure. One is a clinician
` so I see patients one and a half
` days a week in the clinic where it
` is pretty much focused at this point
` in my career on pituitary diseases
` such as Cushing's disease. That's a
` clinic that's also an educational
` role because the residents and
` fellows and medical students all
` rotate through.
` I have research roles where I
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` DR. KATZNELSON
` do clinical trials. My background
` is in clinical trials in the realm
` of endocrinology, mostly pituitary
` disease. Now that is the less of my
` career.
` I would say about 10 to
` 15 percent of my time is spent on
` research. And the rest of my time
` is administrative so I was director
` of our endocrinology fellowship for
` ten years and then I was appointed
` as the associate dean of all of the
` residency fellowships, you can just
` call it graduate medical education,
` which takes up about 70 percent of
` my time.
` Another 15 percent, 20 percent
` of the time -- none of this adds up,
` like all of us, 100 percent. It's
` all much more than that. Most of my
` time is spent doing education both
` regionally, nationally and
` internationally in endocrinology. I
` don't do any classroom teaching
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` these days. Most of my time is
` spent devising curriculum with new
` educational paradigms in
` endocrinology for others.
` Q. So when you described this
` last educational component, who is
` that, who are you educating?
` A. Anybody. Well, physicians,
` not anybody. Physicians.
` Endocrinologists. I do a lot work
` with the Endocrinology Society --
` Endocrine Society; for example,
` developing educational tools. I do
` a lot of medical rounds. I do a lot
` of regional, national and
` international lectures on pituitary
` diseases, mostly for society work
` such as I spoke with the END -- the
` Endocrine Society in different
` countries such as India, Indian
` Endocrine Society and -- yeah.
` Q. Okay. And so you'd
` estimate that's about 10 to
` 15 percent of your time?
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` A. That's a guesstimate.
` Q. Okay. Do you do any
` consulting work?
` A. I do. I consult for
` several medical companies.
` Q. Do you consult for Corcept
` aside from your participation in
` this post grant review?
` A. I have worked with Corcept.
` I have consulting. I believe I did
` brief advisory board consulting for
` them some years ago. I have done
` other work for Corcept as well.
` Q. What years were you working
` on an advisory board for Corcept?
` A. I believe it was -- I'm not
` sure, it was around the time that
` the seismic, that's a pivotal study,
` was done. It was brief. Most of my
` work with Corcept has been as a
` co-investigator. I was
` co-investigator with a little study,
` the seismic study. I have two times
` now spoken to their sales force to
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` discuss basic approaches to
` Cushing's disease and have been paid
` for those efforts. One was in the
` past year.
` Q. How much -- you've done --
` strike that.
` You've worked with Corcept
` sales force twice you said?
` A. I spent two two-hour
` sessions, about two-hour sessions,
` discussing how to -- teaching new
` salespeople how to approach
` Cushing's disease and how to speak
` to doctors like me essentially.
` Q. Okay. And you said you
` were paid for those efforts?
` A. I was.
` Q. How much did you receive?
` A. I know in total for all
` these efforts it was less than
` $10,000. Probably a couple
` thousand -- I mean probably about a
` thousand, 2000 each. I don't
` remember. It was on that realm. It
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` DR. KATZNELSON
` wasn't too much.
` Q. But you think in total it's
` under 10,000?
` A. Oh, yeah.
` Q. Have you ever testified at
` trial before?
` A. Once.
` Q. What was the nature of that
` trial?
` A. It was a delay in
` diagnosis, it was a malpractice case
` regarding a patient with pituitary
` disease called acromegaly. The
` patient claimed that his diagnosis
` was delayed by -- by this one
` physician and I was retained by that
` physician to side on the defense
` to -- to discuss the case, yes.
` Q. Is this in connection with
` one of the depositions that you
` mentioned a few moments ago?
` A. That would be an additional
` one. So I guess I would have been
` deposed three times. So that would
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` DR. KATZNELSON
` have been an additional one. It was
` a long time ago but, yes.
` Q. I apologize. Have you ever
` been an expert in a patent case
` before these proceedings?
` A. No.
` Q. Have you ever worked with a
` company to help them seek FDA
` approval to market a drug?
` A. Yes.
` Q. Which company was that?
` A. Ipsen, I-P-S-E-N.
` Q. And what was the indication
` for that drug?
` A. Acromegaly. Acromegaly is
` another type of pituitary disorder
` that causes too much growth hormone
` and people get very large. It's
` very debilitating, sort of like
` Cushing disease and they had a novel
` drug and I went with them to the FDA
` to discuss that.
` Q. What was your role when you
` went with Ipsen to the FDA?
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` A. I was a medical advisor.
` Q. So what responsibilities
` did you have as a medical --
` A. Answer questions about the
` data and to answer questions about
` the disease. And there were a lot
` of questions.
` MR. STOPS: And, Doctor, I
` assume if this was to the FDA, this
` was a public proceeding, but just
` bear in mind that some of your
` consulting work may be confidential
` to the companies that you did the
` work with. So no one wants you to
` reveal any confidences that you
` have with any specific companies.
` THE WITNESS: Okay.
` Q. Dr. Katznelson, you've
` published a number of articles
` through the years?
` A. Yes.
` Q. Have you ever published
` anything on CYP3A inhibitors?
` A. No.
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` Q. Have you published anything
` on a drug-drug interaction study?
` A. No.
` Q. Have you ever participated
` in a drug-drug interaction study?
` A. No.
` Q. Have you ever designed a
` drug-drug interaction study?
` A. No.
` Q. Have you ever been
` consulted on the design of a
` drug-drug interaction study?
` A. No.
` Q. Have you ever been a
` principal investigator on a
` drug-drug interaction study?
` A. No.
` Q. I'm going to refer you back
` to your CV, page 80.
` A. Is there a way to -- let me
` go to each page. Okay, page 80.
` Q. Maybe you can look at it on
` the screen. Maybe you can download
` it and then move through it a little
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` DR. KATZNELSON
` more easily.
` A. I see it now.
` Q. There is -- I'd like to
` point you to number 12. The Open
` Label Study of the Efficacy and
` Safety of Mifepristone.
` MR. STOPS: What page are you
` on, Counsel?
` MS. EVERETT: Page 80.
` Q. And Dr. Katznelson, are you
` at point 12?
` A. Yes.
` Q. In that study on the top
` line it says, "Katznelson, local
` Stanford PI 5 percent"?
` A. Yes.
` Q. What does it mean to have
` your name at the top of that line?
` A. So this -- this is in a
` section of funding. So this is
` standard presentation on a resumé or
` whenever somebody is doing a
` research. So what this says is on
` this trial which started, I guess
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` DR. KATZNELSON
` the funding started September 4th,
` 2009, that I was the local PI for a
` multicenter trial. That's what that
` means. Five percent is the minimum
` funding we have, we need for my
` research group to participate in the
` study. So I took the minimum
` funding. So 5 percent would be 5
` percent of my salary assuming that I
` recruited X number of patients.
` Q. And do you know what X
` number of patients were?
` A. For this trial I don't
` remember. I do know that it was
` fewer than we had -- than I had
` planned on. I ended up recruiting I
` believe two patients at this time.
` This is not a financial boom for me
` by any stretch.
` Q. Are you currently treating
` any patients with Cushing's
` syndrome?
` A. Many.
` Q. How many?
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` A. I have probably seen in the
` course of my career somewhere
` between 200 and 400. Probably an
` average of 300. Right now patients
` with Cushing's syndrome with active
` disease, likely around 30, somewhere
` in there.
` Q. What's your total patient
` case load?
` A. I can't even begin to
` guess. I'm not sure right now. I
` can tell you that each week I see
` three half days a week and each day
` is about ten patients and each week
` I probably see about another new
` patient with Cushing's syndrome,
` call up another few. So my whole
` case load is over a thousand. I'm
` not exactly sure.
` Q. Of the 30 patients you are
` actively seeing on Cushing's, how
` many are currently on mifepristone?
` A. I'm not sure. I'm going to
` guess about two, two right now.
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` DR. KATZNELSON
` Q. Of the 30 patients how many
` are on ketoconazole?
` A. Three or four.
` Q. How many of the patients
` are on both mifepristone and
` ketoconazole?
` A. None.
` Q. Now, I'm going to ask you
` more about your prescribing habits
` more generally. Well, you said
` you've treated on average maybe 300
` patients with Cushing's syndrome?
` A. Correct.
` Q. And of those about
` approximately how many have you
` treated with mifepristone?
` A. I believe I have treated,
` I'm not sure, I'm going to guess,
` again, I don't keep records like
` that, I believe I have treated
` probably about 15 to 20 patients
` with mifepristone. It's a guess
` though, I'm sorry.
` Q. How many patients have you
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` treated with ketoconazole?
` A. More like 40, 40 or 50.
` Q. How many patients have you
` treated with both mifepristone and
` ketoconazole?
` A. To the best of my
` recollection, none.
` Q. What are the other drugs
` that you have prescribed besides
` ketoconazole and mifepristone?
` A. There's a number of
` medicines we can use for Cushing's
` syndrome. Another one is
` Metyrapone. Metyrapone is a drug
` that was available in the United
` States under Novartis but has since
` -- Novartis dropped it and it moved
` to France to a company so it's
` harder to obtain. That was a very
` good adrenal blocker for this
` disease.
` I have used Mitotane, which is
` a chemotherapy which I don't like
` using because we use it for adrenal
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` DR. KATZNELSON
` cancer and patients the question
` quite ill with it, they get fatigued
` and have bone marrow suppression.
` Aminoglutethimide I haven't used in
` a number of years because in my
` hands almost everybody was getting
` rashes and fevers so I was very
` concerned about the safety component
` of that drug.
` There's another drug which is
` FDA approved now, pasireotide,
` Signifor, which I have stopped using
` in the recent past.
` There's one other drug called
` cabergoline, which is a dopamine
` type of agent which is not FDA
` approved for this use but in this
` handful of patients it can be used
` for it and I have used that as well.
` Q. Could you say that again?
` A. Cabergoline,
` C-A-B-E-R-G-O-L, as in Larry, -I-N,
` Nancy, -E.
` Q. You said that is not FDA
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` DR. KATZNELSON
` approved for use in Cushing's?
` A. Correct. There's only a
` couple of drugs which are FDA
` approved for Cushing's.
` Q. When do you choose to use
` this cabergoline drug on Cushing's?
` A. Usually -- there's only two
` drugs FDA approved so -- actually
` now three drugs. So there -- these
` other medications, including
` ketoconazole, are not FDA approved
` in the United States for this use.
` But like ketoconazole, cabergoline
` is oral, it has a pretty
` straightforward action, it's usually
` well tolerated, and it's usually
` used second, third or fourth line
` medical therapy in order to try to
` control the disease. There's some
` reasons to think that in a woman who
` has Cushing's syndrome and is
` pregnant it may be a nice option to
` use because of the safety profile
` but otherwise it's not used very
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` much.
` Q. So you said earlier that
` there were two FDA approved drugs
` for Cushing's?
` A. There are actually now
` three. Just recently there was a
` new one, Isturisa was approved. The
` two drugs that have been approved up
` till this one was Korlym, that's the
` subject of today, and Signifor.
` It's a Novartis preparation.
` There's a somatostatin analog called
` pasireotide and that drug is also
` FDA approved. And then there's a
` new one the last couple of months.
` Q. So there are certain
` instances in which to appropriately
` treat your patients you think you
` prescribe medicines that have not
` been approved for use in Cushing's?
` A. Correct.
` Q. In your declaration, and I
` think you said this on paragraph 37
` if you want to refer to it, I think
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` you said, "Given the high potential
` for interaction it's the
` prescriber's responsibility to be
` knowledgeable about" the known and
` unknown -- excuse me. Start that
` over. Start that again.
` In paragraph 37 of your
` declaration you've said, "Given high
` potential for interaction, it's the
` prescribers responsibility to be
` knowledgeable about both known and
` potential drug-drug interactions and
` to adjust his or her prescribing
` practices appropriately."
` A. Right. Correct.
` Q. And you agree with that
` statement today?
` A. Yes.
` Q. What do you do as a
` prescribing physician to be
` knowledgeable about those drug-drug
` interactions?
` A. Well, I do everything I can
` to stay up to date and that includes
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` reading, you know, journal articles
` that come out on this subject,
` attending conferences. I write a
` number of articles so that also
` pushes me to catch up on what is new
` with potential consequences of drug
` use, whether it's monotherapy or in
` combination. I attend meetings. I
` also when medical science liaisons
` for companies come to my office and
` they tell me -- one of the things I
` want to get out of them is what's
` new, what's understood. So I do
` everything in my power to stay up to
` date with what we know about drug
`