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Complaint Counsel's Post Trial Brief - Federal Trade Commission

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nutrtional<br />

supplements and botancal medicines in the prevention and treatment of ilness, including<br />

but not limited to cancer, and to review the evidence that exists regarding the<br />

323. Lamont's charge from Respondents is "to provide opinions on the use of<br />

mechansms of action of the major constituents of Danel Chapter One's products." (R22<br />

(LaMont, Dep. at 33)).<br />

324. LaMont is a natuopathic doctor. (R22 (LaMont, Dep. at 9, 15-16)).<br />

325. According to LaMont, natuopathc medicine "is a primar healthcare practice that<br />

focuses on health promotion and disease prevention and the treatment of disease with an<br />

aray of natual therapies that strengten the body's innate healing capacities." (R22<br />

(LaMont, Dep. at 9)).<br />

326. Natuopathic doctors "provide patient-centered care and practice what would be tered<br />

fuctional medicine, which addresses the unque genetic, environmental and lifestyle<br />

factors that contrbute to chronic disease and. . . influence our health." (R22 (LaMont,<br />

Dep. at 9)). .<br />

327. Whle engaged in natuopathic medicine, LaMont has worked in conjunction with<br />

traditional physicians. (R22 (LaMont, Dep. at 10)).<br />

LaMont fids "a diagnosis that looks like<br />

it could be cancer," she absolutely would refer the patient to a traditional physician and<br />

would comanage that patient's care with the physician. (R22 (LaMont, Dep. at 10)).<br />

328. In the course of doing a workup on a patient, if<br />

329. LaMont has not focused her natuopathic practice on natuopathc oncology; rather, she<br />

"ha(s) kept (her) practice ver general." (R22 (LaMont, Dep. at 11-12); LaMont, Tr.<br />

576).<br />

330. LaMont does not know what additional specialized traing natuopathc oncologists<br />

take. (R22 (LaMont, Dep. at 12)).<br />

331. LaMont has not done the specialized traing for natuopathc oncology. (R22 (LaMont,<br />

Dep. at 12); LaMont, Tr. 57,6-77).<br />

332. If LaMont ever found, for example, an abnormal pap smear with carcinoma inside, then<br />

she ''would refer that patient to a gyecologist for a comprehensive workup and<br />

recommend that (her) patients follow the advice of their oncologist." (R22 (LaMont,<br />

Dep. at 14)).<br />

333. LaMont's understanding is that "cancer must be treated with conventional therapies."<br />

(R22 (LaMont, Dep. at 15)).<br />

334. LaMont has seen conventional cancer therapies helpful in sometimes resolvig the<br />

condition. (R22 (LaMont, Dep. at 15)). .<br />

335. LaMont would always make a referal to a cancer specialist because "it's an important<br />

par of the treatment of cancer at ths point." (R22 (LaMont, Dep. at 15)).<br />

336. Foureen states license N.D.s. (R22 (LaMont, Dep. at 17)).<br />

30

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