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5 (Pages 14 to 17)<br />

Page 14 Page 16<br />

1 Judge and Jury You understand that? 1 too should that case get re launched<br />

2 THE WITNESS Yes 2 MR DAVIS If the stay is lifted<br />

3 MR MURGATROYD Okay Now the 3 and those cases proceed<br />

4 Court Reporter here is here to take down 4 MR MURGATROYD Okay Great<br />

5 everything that is said And some time 5 All right<br />

6 after this <strong>deposition</strong> is completed you 6<br />

7 will get a transcript Which will 7 (BY MR MURGATROYD)<br />

8 contain the testimony that you have given 8 Q Now you understand that you re<br />

9 today 9 here today in connection with lawsuits<br />

10 At the time you receive that you 10 involving the drug Paxil?<br />

11 can review it and make any changes you 11 A Yes<br />

12 want to make But I must caution you now 12 Q Okay Are you familiar with what<br />

13 that any changes you do make can be 13 the allegations are in any of the<br />

14 commented upon at the time of trial Do 14 complaints?<br />

15 you understand that? 15 A Yes I am<br />

16 THE WITNESS Yes 16 Q Okay And what is your<br />

17 MR MURGATROYD The idea is to 17 understanding of what they are?<br />

18 give your best testimony today Okay? 18 A Well my understanding is that<br />

19 THE WITNESS Okay 19 the Plaintiffs children took their own<br />

20 MR MURGATROYD Okay Great 20 lives while taking Paroxetine<br />

21 One of last rules is that you have to 21 Q Okay<br />

22 give answers that are out loud The 22 A And that is the basis for the<br />

23 Court Reporter can t take down shrugs 23 lawsuit<br />

24 nods or gestures 24 Q Okay Are you also aware that<br />

25 And also if you would, please 25 there are other actions involving<br />

Page 15 Page 17<br />

1 wait for me to completely ask a question 1 allegations of fraud?<br />

2 before you begin to answering So that 2<br />

3 the Court Reporter can get down a clean 3 MR DAVIS Object to form<br />

4 record Is that okay? 4 THE WITNESS Yes<br />

5 THE WITNESS Yes 5<br />

6 6 (BY MR MURGATROYD)<br />

7 (BY MR MURGATROYD) 7 Q Okay Were you aware of a<br />

8 Q Okay Is there any reason why 8 lawsuit of the Attorney General Spitzer<br />

9 you can t give your best testimony 9 of the State of New York brought?<br />

10 today? 10 A Yes I am I am not familiar<br />

11 A No 11 with the details<br />

12 Q Okay 12 Q Okay Were you aware that it had<br />

13 13 to do with fraud?<br />

14 MR DAVIS Skip just for 14 A No Not specifically<br />

15 logistical issues I understand that 15 Q Okay<br />

16 Ms Laden s <strong>deposition</strong> is also being 16<br />

17 taken or the Plaintiffs want to use 17 MR DAVIS Excuse me Derek<br />

18 Ms Laden s <strong>deposition</strong> in other Baum 18 Just so we have got the ground rules here<br />

19 Hedlund pediatric cases And that this 19 too straightened out I m sorry I didn t<br />

20 <strong>deposition</strong> will serve as that function as 20 mention this earlier<br />

21 well 21 But I assume that all objections<br />

22 MR MURGATROYD That is correct 22 except as to the form of the question for<br />

23 MR DAVIS Okay Thanks 23 the responsiveness of the answer are<br />

24 MR MURGATROYD And I guess for 24 reserved until such further use of the<br />

25 that matter it would be the Smith case 25 <strong>deposition</strong> or until time of trial?<br />

2fae6cde b888 49df 9af3 286ebd9eeca0

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