deposition

88 (Pages 346 to 349)
Page 346 Page 348
1 MR MURGATROYD Okay All 1 Whether or not it s accurate or not You
2 right My question is really simple 2 take the data as it is and you put
3 3 together a report based on it 9
4 (BY MR MURGATROYD) 4 A My job is to make sure that my
5 Q You known that GSK was going to 5 work is accurate based on what I was
6 take the position that Paxil is not 6 doing
7 effective for the treatment of adolescent 7 Q Based upon what you were given
8 depression Would you have stated or 8 And the conclusions from a particular
9 allowed your name to be associated with a 9 study that are given to you It s not
10 manuscript that said just the opposite 9 10 your job to question whether or not those
11 11 conclusions are accurate or not right 9
12 MR MARGOLIS I object to that 12 Or is it 9
13 That s complete speculation You re 13 A I guess I would assume then that
14 talking about asking her about something 14 I would be an expert if I am questioning
15 five years hence 15 that and I don t consider myself an
16 MR MURGATROYD Okay She can 16 expert
17 answer 17 Q Okay And because you don t
18 THE WITNESS I have no idea what 18 consider yourself an expert you don t
19 I would have done 19 question the results the conclusions
20 MR MURGATROYD Okay Thats 20 of any particular studies that are given
21 fine I have no further questions 21 to you 9
22 MR DAVIS Mr Braslow do you 22 A Do I question the results 9
23 have questions on behalf of the clients 23 Q Is that part of your job 9
Or was
24 you represent 9
24 it part of your job 9
25 MR BRASLOW Yes I don t think 25 A My job was to accurately portray,
Page 347 Page 34 9
1 it will be too long My name is Derek 1 condense distill whatever you want to
2 Braslow I represent other Plaintiffs 2 say the data that I was given
3 involved in the Paxil litigation Good 3 Q Well you were also given
4 evening Just a follow up on the last 4 conclusions 9
5 answer that you gave 5 A Yes
6 6 Q Let s talk about the Study 329
7 CROSS EXAMINATION 7 that was talked about You were given
8 8 conclusions with respect to the data you
9 BY MR BRASLOW 9 were given right 9
10 Q I think I would like to talk to 10 A Yes
11 you just real briefly and you have 11 Q Okay And part of your job
12 gone over this many times about your job 12 responsibility was not to question those
13 responsibilities as the focus and 13 conclusions was it 9
14 primarily as the medical writer 14 A No
15 It s not part of your job 15 Q And you didn t 9
16 responsibility as a medical writer or 16
17 it wasn t to question the protocol of any 17 MR MARGOLIS Object to the
18 particular study right 9
18 form
19 A What do you mean by protocol 9
19 THE WITNESS I don t recall no
20 Q Like the protocol of the clinical 20 I don t recall if I did or not
21 trial The parameters of the clinical 21
22 trial 9 22 (BY MR BRASLOW)
23 A No 23 Q Would that have been I guess
24 Q Okay And it s not your job to 24 my question is was that part of your job
25 question the data that comes to you 9
25 responsibility to question the
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