Complaint Counsel's Post Trial Brief - Federal Trade Commission

and the tuor behind my hear has shr over 50%. . . . There are alteratives besides
chemo and radiation!" (CX 21 (emphasis in bold added)).
141. Respondent James Feijo was responsible for putting together BioGuide 3. (R15 (J. Feijo,
Dep. at 243)).
142. Patrcia Feijo was responsible for wrting the BioGuide. (R16 (P. Feijo, Dep. at 20)).
143. Bio*Shark, 7 Herb Formula, GDU, and BioMixx all appear in Respondents' Cancer
Newsletter, entitled How to Fight Cancer is Your Choice!!!. (CX 23; CX 24).
144. The Cancer Newsletter is "strctly all about the products for cancer." (R15 (J. Feijo, Dep.
at 143)).
145. The Cancer Newsletter contains descrptions of varous DCO products that "a person can
choose to use to help them fight cancer." (P. Feijo, Tr. 399). These products include
Bio*Shark, GDU, BioMixx, and 7 Herb Formula. (P. Feijo, Tr. 402-04).
146. Patrcia Feijo was responsible for wrting the Cancer Newsletter. (R16 (P. Feijo, Dep. at
26-28); P. Feijo, Tr. 395-96).
147. James and Patrcia Feijo are not doctors. (R16 (P. Feijo, Dep. at 114); P. Feijo, Tr. 404;
J. Feijo, Tr. 416).
148. James Feijo never held a position where he had to use any skills involving medicine.
(R15 (J. Feijo, Dep. at 47)).
149. James and Patrcia Feijo are not research scientists. (R16 (P. Feijo, Dep. at 114); P.
Feijo, Tr. 405).
150. Durg the July 8, 2008 DCO Healthwatch radio program, James Feijo stated that "the
FTC, the FDA, the Canadian Goverent don't like the fact that we've told people about
what to do about natual methods of
FTC-DCO 0506).
health and healing, especially cancer." (CX 5 at
151. Durng the July 14, 2008 DCO Healthwatch radio program, Patrcia Feijo stated the
following: "And while the FTC does not want us sayig that anytg natual can be used
to treat cancer and that nothing ceraiy can cure cancer, we know that the trth is
different than what they want us to say. The trth is God has given us herbs in His
creation and nutrents that can heal cancer, even cure cancer." (CX 8 at FTC-DCO
0612).
BioShark
152. Respondents publish information about Bio*Shark, including, but not limited to, the
following:
PRODUCTS
Bio*Shark: Tumors & Cysts
Pure skeletal tissue of sharks which provides a protein that inhbits angiogenesis ­
the formation of new blood vessels. Ths can stop tuor growt, and halt the
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