deposition

101 (Pages 398 to 401)
Page 398 Page 4 00
1 1 group
2 (BY MR DAVIS) 2 MR DAVIS Can you read
3 Q I m going to hand you what is 3
4 marked as Defendant s Exhibit 12 and ask 4 (BY MR DAVIS)
5 you if you can identify that document for 5 Q Well do you recall discussions
6 the record please 6 with the authors about resubmitting the
7 A This is a letter from the editor 7 Keller article to another scientific
8 of the Journal of the American Medical 8 journal 9
9 Association to Dr Keller 9 A I don t recall specific
10 Q So this is a letter from JAMA or 10 conversations
11 the Journal of the American Medical 11 Q Okay Do you know whether or not
12 Association 9 12 in fact the Keller article was submitted
13 A Yes 13 to the American Journal of Psychiatry 9
14 Q And it s dated October 22 14 A Yes
15 1999? 15 Q You believe it was 9
16 A It s very fuzzy It s hard to 16 A Based on these documents I think
17 tell I can see October 22nd I can t 17 it was submitted
18 say with certainty what the year was 18 Q Okay
19 Q All right And is your name 19 A I am a little fuzzy on that at
20 written at the top in someone s 20 this moment
21 handwriting 9 21 Q Okay Has it been some time
22 A Yes 22 since you were involved in the process of
23 Q Okay And do you recall 23 whether or not it was submitted 9
24 receiving a copy of this 9 24 A It s been a long time
25 A Do I recall receiving a copy of 25
Page 399 Page 401
1 this 9
I don t recall 1 (Defendant s Exhibit 13 marked)
2 Q Do you have any reason to doubt 2
3 that you received a copy of it 9 3 (BY MR DAVIS)
4 A No 4 Q Okay I m going to hand you
5 5 what has been marked as Defendant s
6 MR DAVIS All right Now 6 Exhibit 13 and ask if you can identify
7 there was a discussion earlier in the day 7 that document for the record please 9
8 about the fact the Journal of the 8 A This is a letter from myself to
9 American Medical Association did not 9 Jim McCafferty
10 accept for publication the Keller 10 Q Okay Is it a true and accurate
11 article Can you look at the first 11 copy of the letter 9
12 paragraph of the letter and read that 12 A I don t recall
13 for the Jury s benefit 13 Q Does it look like it s a true and
14 THE WITNESS I will attempt to 14 correct copy of the letter 9
15 do that It s very fuzzy We have 15 A It looks to be an authentic
16 completed our review of your manuscript 16 Q Is that your signature at the
17 And report that we are unable to accept 17 bottom 9
18 it for publication in JAMA This 18 A Yes it is
19 something is no reflection on the 19 Q Was this document prepared during
20 scientific quality of your manuscript 20 the ordinary course of business of STI 9
21 but the publication priorities of the 21 A Yes it was
22 journal are such that we something 22
23 something be extremely selective 23 MR DAVIS Can you read for the
24 However we believe that your paper maybe 24 Jury s benefit what the first paragraph
25 well suited for another journal in our 25 says
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