Biel Deposition

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IN THE CIRCUIT COURT FOR THE TWENTIETH JUDICIAL CIRCUIT IN

LEE COUNTY, FLORIDA CIVIL DIVISION

John Szymanski,

Plaintiff,

vs 07-CA-015501

R.J. Reynolds Tobacco Company, et al

Defendants.

Deposition of MERRILL BIEL, M.D., taken pursuant

to Notice of Taking Deposition, and taken before Daniel W.

McMahon, a Notary Public in and for the County of Hennepin,

State of Minnesota, on the 6th day of May, 2011, via video

teleconference at 2200 IDS Center, 80 South Eighth Street,

Minneapolis, Minnesota, commencing at approximately 1:15

oclock p.m.

Source: http://industrydocuments.library.ucsf.edu/tobacco/docs/gmhl0191

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1 APPEARANCES:

2

3 Chad B r a z z e a l , E s q u i r e , and Cra ig R.

4 S t e v e n s , E s q u i r e , of t h e f i rm of MORGAN & MORGAN, P o s t

5 O f f i c e Box 9504, F o r t Myers , F l o r i d a 33906, a p p e a r e d

6 r e p r e s e n t i n g t h e P l a i n t i f f .

7 8 Thomas A. Duncan, E s q u i r e , of t h e

9 f i rm of SHOOK, HARDY & BACON, 2555 Grand B o u l e v a r d , Kansas 10 C i t y , M i s s o u r i 6 4 1 0 9 - 2 6 1 3 , a p p e a r e d r e p r e s e n t i n g L o r i l l a r d

11 Tobacco Company and L o r i l l a r d , I n c .

12 13 "Nicholas P. M i z e l l , E s q u i r e , of t h e

14 f i rm of CHEFFY PASSIDOMO, 621 F i f t h Avenue S o u t h , N a p l e s ,

15 F l o r i d a 34102, a p p e a r e d r e p r e s e n t i n g L o r i l l a r d Tabacco

16 Company and L o r i l l a r d , I n c .

17 18 Sean R i l e y , E s q u i r e , A t t o r n e y a t

19 Law, a p p e a r e d v i a t e l e p h o n e r e p r e s e n t i n g P h i l i p Mor r i s USA

20 I n c .

21 22 C h r i s Windham, E s q u i r e , A t t o r n e y a t

23 Law, a p p e a r e d v i a t e l e p h o n e r e p r e s e n t i n g R . J . Reynolds

24 Tobacco Company.

25 26 Sandra M i l l o r , E s q u i r e , of t he f i rm

27 of KASOWITZ BEWSOH TORRES t FRIEDMAN, 1441 B r i c k e l l Avenue,

2G S u i t e 1420, Miami, F l o r i d a 33131 , a p p e a r e d v i a t e l e p h o n e

29 r e p r e s e n t i n g L i g g e t t Group, I n c . and V e c t o r Group, L t d .

30 * * +

Page 4 1 2 MR. BRAZZEAL: Sure. Chad Brazzeal for the 3 plaintiff with also Craig Stevens for the plaintiff is 4 here as well. 5 MR. DUNCAN: Tom Duncan representing Lorillard 6 Tobacco Company. 7 MR. MIZELL; Nick Mizell of Cheffy Passidomo out of 8 Naples for Lorillard. 9 MR. RILEY: Sean Riley for Philip Morris.

10 MR. WINDHAM; Chris Windham for RJ. Reynolds. 11 Q Okay. Doctor, can you please state your professional 12 business address? 13 A It's 2211 Park Avenue South, Minneapolis, Minnesota 14 55404. 15 Q And is that Ear, Nose & Throat SpecialtyCaie of 16 Minnesota? 17 A Yes, it is. 18 Q How are you employed there? 19 A I am a full partner, part owner and physician, senior 20 physician actually in the practice. 21 Q How long have you been employed there? 22 A Since 1987. 23 (interruption) 24 MR. DUNCAN: Yes, go ahead. 25 MS. MILLOR: Hi, this is Sandra Millor from 26 Kasowitz Benson appearing on behalf of Liggett and 27 Vector. I apologize for joining you late. I've been 28 trying for the last ten minutes to figure out what 29 number this was. 30 MR. DUNCAN: No problem, we just got started.

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Page 3 l 2 WHEREUPON, the following proceedings were duly had: 3 A 3fc ifc sp

5 6 MERRILL BIEL, M.D., 7 a witness in the above-entitled 8 action, after having been first duly 9 sworn, deposes and says as follows:

10 11 CROSS-EXAMINATION 12 13 BY MR. BRAZZEAL: 14 15 Q Good afternoon, doctor, my name is Chad Brazzeal, I 16 represent the plaintiff in this case, John Szymanski. 17 Have you ever had a deposition taken before? 18 A I have. 19 Q Okay. I 'm just going to remind you then to make sure 20 that you listen to my question and if you have any 21 questions regarding the question please let me know and 22 I'll try to rephrase it for you, okay? 23 A Very good. 24 MR. DUNCAN: speak up a little bit. 25 A Very good. 26 Q Are you able to hear me okay? 27 A Yes. Can you hear me okay? 28 Q Yes, I can. 29 30 (Reporter asked for appearances)

Page 5 1 MS. MILLOR: Okay. 2 MR. BRAZZEAL: Yeah, this is Chad Brazzeal for the 3 plaintiff, you didn't miss anything except his name and 4 address and where he works. 5 MS. MILLOR: okay, thanks. 6 Q Doctor, I couldn't hear that. How long have you been 7 employed at that practice? 8 A Since 1987. 9 Q And what kind of physician are yon?

10 A I'm an otolaryngologist, head and neck surgeon. 11 Q Can you provide me with an overview of your educational 12 background starting with medical school? 13 A Sure. I went to medical school at the University of 14 Illinois in Chicago and graduated in 1981. And then I 15 did a residency in otolaryngology, head and neck surgery 16 at the University of Minnesota, which I completed in 17 1987. 18 I also at the same time obtained a Ph.D. degree in 19 otolaryngology with a minor in radiation biology and 20 anatomy at the University of Minnesota, also completed 21 in 1987. And then I did a fellowship in head and neck 22 oncology, reconstructive surgery at Washington 23 University in St. Louis, Barnes Hospital, in 1987. 24 Q And what states are you licensed to practice medicine 25 in? 26 A In Minnesota. 27 Q Do you hold any board certifications? 28 A I do. I 'm board certified in otolaryngology head and 29 neck surgery. 30 Q Did you pass your board certification exam on the first

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1 attempt? 2 A I did. 3 Q Have you ever been licensed in any other states? 4 A No. 5 Q I know we asked just a moment ago off the record about a 6 curriculum vitae. I understand we have an older one and 7 there may be a more recent one. Could you forward your 8 more recent copy to the attorney for Lorillard, please, 9 so that they can forward that on to us?

10 A I will be happy to do that. 11 Q Thank you. What type of patients do you treat in your 12 practice? 13 A About 85 percent of the patients I see are head and neck 14 tumor related. About 15 percent are general ENT. Ear 15 disease, sinus disease, et cetera. 16 Q Do you perform any surgeries? 17 A I do. That's a major part of my practice. 18 Q Okay. Do you perform laryngectomies? 19 A I do. 20 Q And do you perform neck dissections? 21 A I do. 22 Q If a patient were to need follow-up chemotherapy, would 23 you refer them to another physician? 24 A Yes. Yeah, we run a multi for our treatment of our head 25 and neck cancer patients. I actually am director of the 26 head and neck oncology program at the Virginia Piper 27 Cancer Institute. So we have a multi-specialty program 28 in which all the patients are evaluated not by people 29 like myself who are surgical oncologists in head and 30 neck but also medical oncologists and radiation

Page 8 1 five years prior. 2 Q How many cases do you think you've given a deposition in 3 over the past 15 to 20 years? 4 A Three. Three or four. 5 Q So in the past 15 to 20 years this is probably your 6 fifth deposition ever? 7 A Correct. 8 Q Have you ever testified at trial before? 9 A Once.

10 Q Okay. Where was that trial located? 11 A Bismarck, North Dakota. 12 Q What did that case involve? 13 A It involved an issue of the possible non-diagnosis, 14 non-early diagnosis of a cancer. 15 Q And who were you testifying at the request of, a 16 plaintiff or a defendant? 17 A A defendant. 18 Q Have you ever testified before either in a deposition or 19 in a trial for a, at the request of a tobacco company? 20 A No. 21 Q Have you ever been sued for medical malpractice before? 22 A I have not. 23 Q Do you know if the testimony you've given in any of 24 those cases over the years has ever been disqualified by 25 a court? 26 A No, not that I'm aware of. 27 Q Do you advertise for your services as an expert witness? 28 A I do not. 29 Q What is your understanding of how cases are typically 30 referred to you?

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Page 7 1 oncologists. 2 Q Have you ever served as an expert witness in litigation 3 before? 4 A I have. 5 Q Okay. What percentage of your time currently is devoted 6 towards serving as an expert witness? 7 A I'd say well less than one percent. 8 Q Do you hold any academic positions? 9 A I do. I have an appointment as a professor at the

10 University of Minnesota. 11 Q What do you do in that capacity? Are you teaching 12 students, are y o u conducting rounds with them? 13 A I teach students and residents both in family practice 14 and in surgery. And I'm also advisor to the residents-15 at the present time one resident in the University of 16 Minnesota Department of Otolaryngology Program in the 17 research. 18 Q When did you first start serving as an expert witness in 19 medical/legal cases? 20 A Probably 15 to 20 years ago. 21 Q And has your expert testimony always been limited to the 22 field of being an ENT? 23 A Yes. 24 Q During the last five years how would your, the 25 percentage break down for testimony that you've given at 26 the request of a plaintiff versus at the request of a 27 defendant in litigation? 28 A The last time I actually did a deposition was four or 29 five years ago for a plaintiff And the only other time 30 before that was for a defendant, but it was probably

Page 9 1 MR. DUNCAN: object to form. You mean legal or 2 medical? 3 Q Legal cases. 4 A I think they're just referred via attorneys asking other 5 attorneys who they should call to get an opinion on a 6 case. As far as I know. 7 Q What percentage of your income today is derived from 8 serving as an expert witness in litigation? 9 A Well, certainly this year zero. In the previous year,

10 it's well less than one percent. 11 Q Do you have a fee schedule for your work as an expert 12 witness? 13 A Yes. 14 Q Okay. Can you tell me what that is? 15 A I don't know the whole thing offhand. My business 16 office would have that. 17 Q Okay. 18 MR. DUNCAN: He wasn't quite finished. 19 A The only thing that I know of is there's an hourly rate 20 for a review of records and that sort of thing, which is 21 $375 an hour. 22 Q Is your fee schedule, is it a written document? 23 A I believe it is somewhere at the business office. 24 Q Okay. Is that something you could forward on to defense 25 counsel as well? 26 A Sure. 27 MR. DUNCAN: We'll do that. 28 Q All right. You said your hourly rate for records review 29 is $375. How much do you charge for deposition 30 testimony?

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Page 10 I don't know that offhand. Do you know how much you charge for trial testimony? No, I don't. This case is set in Lee County Florida, which is in southwest Florida. If you come down and testify, do you know how much you ' l l charge? No. It would be based off the fee schedule. Okay. It would be an hourly rate plus expenses? I think there's a charge for in court appearances and expenses. How much have you billed for reviewing this matter to date? Nothing. Okay. How many hours of review time or preparation time have you put into this case? About four hours. Are you intending to submit a bill any time soon for your work in this case? I am. When you were initially contacted by defense counsel to serve as an expert witness, what were you asked to do in this case? I was contacted to well, I was asked to act as an expert witness based on my clinical expertise and knowledge as a head and neck specialist, head and neck cancer specialist, to evaluate the risk of smoking as related to the possibility of development of laryngeal cancer. Do you recall who contacted you? Mr. Michelman.

Page 12 1 case of John Szymanski? 2 A No. 3 Q Have you reviewed any of Mr. Szymanski's medical 4 records? 5 A No. 6 Q Have you written any reports 7 A I have not. 8 Q for this case? 9 A No.

10 Q Have you made any notes for this case? 11 A No. 12 Q Did you have to talk to any of your colleagues in order 13 to form your opinions in this case? 14 A No, I did not. 15 Q Did you have to do any medical research in order to form 16 your opinions? 17 A No. The only thing that I looked at was some components 18 of the surgeon general's report in order to confirm what 19 I recalled as both in my experience and what I had read 20 in the past was consistent with risks of smoking. 21 Q Now, can you give me the title of that surgeon general's 22 report? 23 A Sure. It's "The Health Consequences Of Smoking: A 24 Report Of The Surgeon General". It's 2004. It 's 25 published by the U.S. Department Of Health And Human 26 Services, Public Health Service, Office Of The Surgeon 27 General. 28 Q Okay. 29 A You can get it off the CDC website. 30 Q Did you make any notes on that report that you have in

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Page 11 And do you know what law firm Mr. Michelman is with? Yes. Shook, Hardy & Bacon. Have you ever worked as an expert witness in litigation at the request of any attorneys from Shook, Hardy & Bacon in the past? I have reviewed records for them in the past. Okay. How many cases? I think three that I can recall. Have they all been at the request of I didn't write down his name. Mr. McMillan I think.

MR. DUNCAN: Michelman. Michelman. No. His name is Michelman. What attorneys have you reviewed cases for? Let's see if I can remember actually. Since I 'm terrible with names. Actually, I've reviewed a case for Mr. Duncan in the past. And I'm blanking on the other names. Okay. In the cases that you've reviewed at the request of an attorney from Shook, Hardy & Bacon, have you ever given a deposition in those cases? I have not. All right. What materials have you reviewed in this case? The only thing that I reviewed was some portions of the surgeon general's report from 2004 entitled "The Health Consequences Of Smoking". Okay. Is that a document that you obtained, or is that a document that was provided to you by an attorney? It 's a document that I obtained. Have you reviewed any of the depositions taken in this

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Page 13 front of you?

A I did not. Q Now, this health consequences of smoking report, are

there previous versions of this report available? A My well, I don't know for sure. My guess is there

probably are. Q Okay. So what I 'm trying to understand is perhaps in

the year 2000 was there a similiar report called health consequences of smoking?

A There may be. I don't know. MR. DUNCAN: Excuse me. I apologize for this but

I've got to take a really short comfort break. Do you mind?

MR. BRAZZEAL: That's fine. MR. DUNCAN: Like a minute. I'll be right back.

(At this time a recess was taken) CONTINUED BY MR. BRAZZEAL: Q Doctor, do you know if there's any more recent versions

of this report, perhaps in 2005 through 2011? A Not that I 'm aware of. Q How is it that you came to obtain this report? A I believe I printed this off a few years ago. Q Okay. What caused you to print this off a few years

ago? A I was asked to look at risk factors of smoking in a

previous case with Shook, Hardy & Bacon. Q Okay. That was a case where a plaintiff was suing for a

smoking related illness?

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Page 14 Correct. Did you testify in that case? No. When you pulled the report off the Internet a few years ago for that case, was that research that you performed on your own, or was that a document that the attorney directed you to? No, that's research I did on my own. Do you agree with everything that's in the report? I can't say whether I do or don't because I haven't read the entire report. Okay. Are there any particular portions of it that you disagree with? Not of the portions I looked at. I was basically ~ I pulled the report because it has nice summaries of studies. And so I was looking at the study summaries. Okay. Can you tell me what studies you were looking at? Sure. It's a study by Maier, M-a-i-e-r, et al, 1992. And a study by Tavani, T-a-v-a-n-i, et al, 1994. Study by Maier, M-a-i-e-r, and Tisch, T-i-s-c-h, 1997. I think those are the main ones. Okay. What were the conclusions of the first Maier's study, the 1992? The conclusion of that study was that there's a dose response relationship between the amount and duration of smoking as a risk factor for developing laryngeal cancer. So that as you increase both the intensity and time that you smoke your risk goes up, but in a nonlinear fashion. Okay. And what was the results or the conclusions drawn

Page 16 1 A No. 2 Q that we haven ' t already discussed? 3 A No. I have been provided with no other materials. 4 Q Sure. Is there any information that the attorneys have 5 provided you in this case that forms the basis of any of 6 your opinions? 7 A No. 8 Q Okay, doctor, what are your opinions in this case? 9 A Can you give me a more specific question?

10 Q Sure. I mean, your disclosure says you're expected to 11 testify regarding the etiology, risk factors and 12 diagnoses regarding the cause and development of certain 13 diseases and conditions, including the role as reported 14 in medical and scientific literature of cigarette 15 smoking. 16 A Okay. 17 Q There's a lot in that sentence. What I 'm trying to 18 understand is what testimony arc you going to provide to 19 the ju ry regarding the etiology, risk factors and 20 diagnoses regarding the cause and development of certain 21 diseases? 22 A So risk-wise that cigarette smoking is a known 23 contributor to the development of laryngeal cancer. And 24 it occurs pretty much in a dose response dependent 25 fashion. And largely, you know, dependent on the 26 intensity of smoking. 27 So that would be the number of cigarettes smoked per 28 day, for instance. Or packs of cigarettes per day. As 29 well as the length of time that that intensity of 30 smoking is ongoing. So we usually refer to that as pack

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Page 15 by the Tavani 1994 study? That - well, it was basically the same. Okay. And finally the Maier/Tisch 1997 study, what were their conclusions as you understand them to be? Their conclusions were the same as well, dose response relationship to the number of cigarettes per day and duration of smoking and pack years. In a nonlinear fashion. Do you have any opinions about John Szymanski's smoking history in this case?

MR. DUNCAN: object to form. I don't know what his smoking history was since I have not reviewed the records. Okay. So you don't have any opinions then about whether or not Mr. Szymanski was addicted to cigarettes containing nicotine? No, I do not. I haven't had a chance to review his records. I understand that you have your expert witness disclosure in front of you? Yes. All right. Did you draft the language that's in this disclosure? I approved of the language. Okay. And that was going to be one of my next questions. Is there anything in the actual language of the disclosure that you disagree with? No. Okay. Are there any other materials that the attorneys have provided you in this case ~

Page 17 1 years. You know, in a way to designate amount of 2 smoking clinically. So we typically ask people how much 3 they smoke, how much they're actively smoking, how much 4 they smoked in the past and for how long they've been 5 smoking. 6 And the risk actually changes depending on both the 7 intensity and duration of smoking. So, for instance, if 8 someone is smoking five pack years their risk of 9 developing laryngeal cancer in particular is really no

10 greater than that of a nonsmoker. When you go from five 11 to ten pack years of smoking, there' s a very minimal 12 risk associated with smoking over someone who doesn't 13 smoke as developing laryngeal cancer. 14 So very slow, minimal difference to insignificant 15 difference between five and ten pack years of smoking. 16 From ten to 20 there is an increase in risk. But it's 17 only really after 20 pack years that the risk starts 18 dramatically increasing, and substantially increases at 19 30 years and above, and then dramatically at 40 pack 20 years and above. 21 Q All right. Le t ' s take five to ten years. If an 22 individual smokes cigarettes for five to ten years, do 23 they have an increased chance of developing cancer? 24 MR. DUNCAN: Object to form. 25 Q Okay, let me rephrase that. If someone smokes 26 cigarettes for five to ten years, are they at greater 27 risk of developing any type of cancer than a nonsmoker 28 who never smoked a cigarette at all? 29 A Well, I can't speak to any other type of cancer. I can 30 speak to laryngeal cancers.

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Page 18 Okay, then we'll address laryngeal cancer. Okay. Sothe--If someone smokes yeah, if someone smokes five to ten years, are they at a greater risk of getting laryngeal cancer than a nonsmoker? Depends how much they're smoking during that five to ten years. Okay. What if they're smoking two packs a day? So if they're smoking two packs per day for ten years, that's 20 pack years. So yes, they are at a probably two to three times risk over a normal person of developing laryngeal cancer. And that would be for five to ten years of smoking two packs a day? So, no, as I said, if they were smoking, giving your example that you said they were smoking two packs per day, and so I said two packs per day for ten years, that's 20 pack years. So for somebody who's smoking 20 pack years, they've got a two to three times increased risk over a nonsmoker. Because actually nonsmokers can develop laryngeal cancers. So they have a two to three times risk over nonsmokers of developing laryngeal cancer. What about someone who smokes five years? Is someone who smokes five years more at risk for developing laryngeal cancer than a nonsmoker?

MR. DUNCAN: object to form. Are you meaning to say five pack years, or five years at some amount? I'm saying five years. Five years at one pack per day would be five pack years.

Page 20 1 Q Yes. 2 A Okay. So if they have -- and are we assuming that they 3 have no other risk factors for developing laryngeal 4 cancer? 5 Q Yeah, just for laryngeal cancer just simply from smoking 6 100 pack years. 7 A So they don't have any other history of alcohol use or 8 chronic reflux or HPV exposure or environmental 9 exposures that are risk factors for laryngeal cancer.

10 So I just want to make sure I get the hypothetical 11 correct. 12 Q That's correct. Only smoking. 13 A Okay, so they only smoke. They actually have a very 14 substantial risk of developing laryngeal cancer. It's 15 about 15 to one. Or greater depending 16 Q Does that mean they're 15 times more likely than a 17 nonsmoker then to develop laryngeal cancer? 18 A Yes. 19 Q You mentioned a few other factors such as HPV status and 20 alcohol use. Are you going to express any opinions at 21 trial regarding the relationship between those things 22 and development of laryngeal cancer? 23 A I can if I'm asked. 24 Q Okay. All right then, let's go ahead in case you're 25 asked. What is the relationship then between alcohol 26 use and laryngeal cancer, if there is any? 27 A Alcohol use actually in combination with smoking 28 increases the risk of laryngeal cancer twofold. 29 Q Okay. What do you mean by increases the risk twofold? 30 A They have a double chance over smoking alone of

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Page 19 Okay. So thank you. Thank you for making that clear. So if you're talking about five pack years of smoking, they are at no more increased risk of developing laryngeal cancer than someone who does not smoke. Are you saying that there's no health consequences at all from smoking five pack years?

MR. DUNCAN: object to form. That's not what I said at all. What I said was that they are at no more increased risk over someone who doesn't smoke in developing laryngeal cancer if they smoke five pack years. There's all sorts of other potential health consequences and I tell patients not to smoke because of that. But they're not at increased risk with five pack years of smoking of developing a laryngeal cancer. Okay. You agree that smoking is unhealthy, though, don't you? Absolutely. All right. And you do agree that smoking increases a person's chance of developing laryngeal cancer?

MR. DUNCAN: object to form. That's related to time and duration of smoking. Now, are you going to have any opinions in this case as to whether or not the plaintiff, John Szymanski, developed cancer from smoking cigarettes? No, because I haven't reviewed the records at all. Now, if an individual has a 100 pack year history what is that person's risk for developing laryngeal cancer compared to that of a nonsmoker? If that's a so is that a hypothetical question?

Page 21 1 developing a laryngeal cancer. 2 Q Does it depend upon how much alcohol that person has 3 drank? 4 A Yes, it does. Correct. 5 Q Are there ~ 6 MR. DUNCAN: He was still talking. Sorry. 7 A It's how much and what type of alcohol they drink. 8 Q All right. Are there certain alcohols that are I guess 9 more related to causing laryngeal cancer than other

10 types of alcohol? 11 A Yeah, alcohol by itself is not known to increase the 12 rate of laryngeal cancer. Studies are disputed on that 13 so there's not a clear relationship. But there actually 14 is a clear relationship between particularly drinking 15 hard alcohol and smoking increasing the rate of 16 laryngeal cancer in those people who smoke. 17 Q What about drinking beer and smoking, is there any 18 relationship that you know of there? 19 A Well, the studies that I've seen, that I recall, the 20 relationship is not nearly as clear as with hard 21 alcohol. And the amount of beer that you'd have to 22 drink would be substantial. So it's not a beer a day. 23 Q Okay. I mean, what do you mean by substantial? Is that 24 less than three beers a day? 25 A It's probably five or more. But, again, the data is not 26 clear with beer. 27 Q Why is it that alcohol by itself I guess is not as 28 strongly correlated to causing laryngeal cancer as 29 alcohol and smoking are? 30 A That's not actually fully understood.

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Page 22 Okay. It is an irritant. But clearly in many studies there actually hasn't been a demonstration of alcohol alone substantially increasing risks of head and neck cancers. All right. Your expert witness disclosure says, Dr. Biel may testify regarding the accrual of risk for the diseases claimed by plaintiff. What is your testimony in that regard? I think that's what we've been talking about with regard to laryngeal cancer. Can you tell me what risk factors Mr. Szymanski had far developing laryngeal cancers? I have no idea since I've not reviewed his records. Are you going to offer any testimony regarding the relationship between positive HPV status and the development of laryngeal cancer? I could if asked. Okay. Is there a relationship between HPV status and the development of laryngeal cancer? There is a relationship between - well, let me put it this way. Laryngeal cancers can be caused by an HPV viral infection. They are not very common. HPV in head and neck cancer is much more common in the tonsil and tongue base. But they are a known cause of laryngeal cancers in both smokers and have been found in nonsmokers, too. Are you going to offer any specific opinions about the facts of this case -- well, let me rephrase that. Are you going to offer any case specific opinions related to Mr. Szymanski?

Page 24 1 Q Two to three beers per day, is that person's alcohol use 2 a contributing factor to them developing laryngeal 3 cancer? 4 MR. DUNCAN: object to form. 5 A Hypothetically and if they had no other risk factors 6 associated with ~ that could be associated with 7 laryngeal cancer the two to three beers per day would 8 not substantially increase their risk, in my opinion. 9 Q Okay. So if you take a smoker and that smoker has a 100

10 pack year history and they also drink two to three beers 11 per day, then i t ' s your opinion that their alcohol 12 consumption would not cause them to have a greater 13 chance of developing laryngeal cancer? 14 MR. RILEY: Object to form. 15 A Not substantially. If they have no other risks. 16 Q Okay. What other risk would you want to know about in 17 order to completely answer that? 18 A Well, they can have other risks, as we talked about 19 before, with regard to HPV status, with regard to 20 history of reflux, which the alcohol use is a 21 contributor actually. Any environmental exposures at 22 work, any history of previous radiation to the area. 23 Those types of risks. 24 Q Would drinking two to three beers per day for 25 approximately 40 years increase a person's chance of 26 developing laryngeal cancer? 27 A I would say in my opinion not substantially. There may 28 be a slight increased risk. 29 Q Dr. Biel, your expert disclosure says that you may also 30 offer opinions about risk avoidance and reduction in

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Page 23 1 MR. DUNCAN: if 1 could just interrupt here and say 2 that we have not put him up for any case specific 3 opinions other than what he's already stated, which are 4 general opinions applied in this case. But we gave him 5 no materials on Mr. Szymanski. So go ahead, doctor. 6 A Ditto. 7 Q Okay. 8 A Yeah, I haven't seen the records and so I can actually 9 state nothing really related to this specific case.

10 Q Right. And that's why I'm just looking at your expert 11 disclosure, though. You know, it says, whether 12 plaintiff s alleged use of cigarettes manufactured by 13 Lorillard Tobacco Company was sufficient to constitute a 14 substantial contributing factor to his injuries. 15 I mean, as you sit here today you can't tell me how many 16 Lorillard cigarettes Mr. Szymanski smoked, can you? 17 A I have no idea. 18 Q So you wouldn't be able to tell me then whether or not 19 Mr. Szyraanski's smoking of cigarettes manufactured by 20 Lorillard caused him any injuries whatsoever? 21 A No. I think what I can tell you is what I stated in 22 general from the standpoint of the risk of development 23 of laryngeal cancer with the degree of smoking. But I 24 don't know anything about Mr. Szymanski's smoking 25 history or what he smoked. 26 Q All right. I want to give you a hypothetical question 27 then. If you assume for me that someone's had a 100 28 pack year history and they also drank two to three, four 29 beers a day ~ 30 MR. DUNCAN: Did you say two, three, four?

Page 25 1 risk for the development of cancers. 2 A Correct. 3 Q Are you able to tell me what specifically you're going 4 to inform the jury of regarding risk avoidance and 5 reduction? 6 A Well, if one stops smoking and alcohol use. But if 7 someone stops smoking, and particularly with regard to 8 laryngeal cancers and actually other head and neck 9 cancers, if they have stopped smoking for most

10 literature and most experience would say ten years, then 11 their risk of developing a laryngeal cancer becomes the 12 same as someone who has not smoked in the past There 13 are some studies that go out to 20 years but most of 14 them are around ten. 15 Q Does it depend upon how much the person had smoked in 16 the past? 17 A No. According to previous studies that's not a major 18 factor. 19 Q So if a person had smoked for 30 years two packs a day, 20 that would be a 60 pack year history, if that person 21 stopped smoking it's your opinion that ten years after 22 stopping that person would have the same risk for 23 developing laryngeal cancer as someone who had never 24 smoked a cigarette in their life? 25 A Yes, that's what population studies have demonstrated. 26 Again, some 27 Q Do you believe that 28 MR. DUNCAN: He's still talking. 29 A Again, some studies actually go out to 20 years. But 30 most of them actually refer to ten.

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Multi-Page1

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 7\ 22 23 24 25

27 28 29 30

Q A Q

A

Q

A Q

A Q A Q

A

Page 26 Do you believe that in your own experience? Yes, I do. Is it your opinion that that person's risk in regards to developing laryngeal cancer from smoking actually goes to zero?

MR. DUNCAN: object to form. Well, the risk of developing laryngeal cancer in the base population of nonsmokers is not zero. Ten percent of the people that we see with laryngeal cancers have never smoked. So there's an incidence of laryngeal cancers that exists as a baseline in nonsmokers due to other risk factors. Such as the things we talked about before. So it doesn't go down to zero. It goes down to the baseline of the normal population. Are you able to tell me what a nonsmoker's chances are of developing laryngeal cancer absent any risk factors such as HPV status, alcohol use, acid reflux? They're very low. All right. What do you mean by that?

MR. DUNCAN: object to form. It would be not common. Uncommon but not rare. You treat laryngeal cancer in your practice, don't you? That's correct. And in the majority of the patients that you treat for laryngeal cancer what was it caused by?

MR. DUNCAN: object to form. About 90 percent of them are in patients who are active smokers typically with alcohol use and may have other risk factors, particularly reflux as well. Ten percent

Page 28 1 cancers, too. So you're -2 Q Let me ask you this, is a patient that develops 3 laryngeal cancer, are they more at risk of developing a 4 recurrence of that laryngeal cancer than someone who has 5 never had laryngeal cancer in the first place? 6 A Anybody that has any cancer is at risk of developing a 7 recurrence typically within a five-year period than 8 anyone who has not had a cancer. 9 Q Your expert witness disclosure says that you may also

10 offer opinions and testimony in response to issues 11 raised by plaintiff and plaintiff's experts. And may be 12 asked to comment upon the testimony opinions of other 13 witnesses and expert reports. Do you have any such 14 opinions today? 15 A No, because I've been provided no information. 16 MR. BRAZZEAL: Can we take a break? 17 MR. DUNCAN: Yeah, that's great. 18 19 (At this time a recess was taken) 20 21 Q Doctor, have you ever received any research money from a 22 tobacco company? 23 A No, I have not. 24 Q Have you ever been employed by a tobacco company? 25 A No, I have not. 26 A Have you ever participated in any research that was 27 funded by a tobacco? 28 A No, I have not. 29 Q Have you ever been affiliated with the Roswell Park 30 Institute?

*** * *** ^^rtl f*Q

Page 27 1 of them are nonsmokers. Most of those have some other 2 risk factor, the most common being reflux. Chronic 3 reflux. 4 Q Now, I know we talked about if a person, if a smoker 5 stopped smoking after ten years their risk of developing 6 laryngeal cancer goes to that of a nonsraoker. My 7 question is does that change at all if the person has 8 already developed cancer before they quit smoking? 9 MR. DUNCAN: object to form.

10 A I 'm sorry, can you restate the question? 11 Q Yeah. Sure. We talked earlier about if a person that 12 smokes quit smoking ten years later their risk of 13 developing laryngeal cancer returns to that of a 14 nonsmoker. 15 My question is does that hold true if the smoker has 16 already developed laryngeal cancer? If they stop 17 smoking for ten years after they developed it and it 's 18 diagnosed, does their risk of developing laryngeal 19 cancer go back to that of a nonsmoker even though 20 they've already been diagnosed in the past? 21 MR. DUNCAN: Object to form. 22 A So, well, I guess I need some clarification. So if the 23 person has a history of laryngeal cancer have they been 24 treated? 25 Q Yes. 26 A Okay. And how have they been treated? 27 Q Well, that's not the question. 28 A That makes a difference as to the answer. Because if 29 they received radiation, which would actually be 30 commonly done, there are radiation induced laryngeal

Page 29 1 A I actually am on a National Institutes of Health grant 2 with them. 3 Q Okay. What does that grant involve? 4 A The grant involves treating patients with a treatment 5 called photodynamic therapy. With patients with head 6 and neck cancer they have photodynamic therapy. And 7 Roswell Park has a certain drug, it's a photosensitizer. 8 So this is a treatment that's a light activated drug 9 treatment that selectively kills tumor cells. And so

10 I'm a co-investigator on a National Institutes of Health 11 funded clinical trial. 12 Q There's an individual there named Michael Cummings. Do 13 you happen to know Mr. Cummings? 14 A No, I don't. 15 Q We talked about the 2004 surgeon general's report. Are 16 there any other areas in that report that are important 17 for you in formulating your opinions in this case? 18 A The ones I mentioned were the ones that I had examined. 19 Q Are there any other materials you'll be relying on in 20 support of your opinions? 21 A Not that I 'm aware of certainly at this time. 22 Q Is nicotine in cigarettes addictive? 23 A As I understand, it is in some people. 24 Q Do you think in some people it is not? 25 A That would be my clinical impression. 26 Q The 2004 surgeon general's report, does it discuss 27 whether or not nicotine in cigarettes is addictive? 28 A I did not read that section. I 'm not an expert on 29 addiction so -30 Q It is your understanding, though, that nicotine in

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Multi-Page1

1 2 3 4 5 6 7 8 9

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30

Page 30 cigarettes can be addictive, correct?

A Yes, it does have addictive potential, as I understand it.

Q I know we touched on this as well but I just kind of want to get the question a little more clear. What are the risk factors for developing laryngeal cancer?

A What are any risk factors? Q Yeah, what are the risk factors for developing laryngeal

cancer? A Okay. So they would include smoking. They would

include chronic reflux. They would include HPV exposure disease. Previous radiation to the area. Toxic environmental exposures. Those would be the common ones. And alcohol is a contributing one. So it's a risk factor in combination with smoking. And clinically certainly it aggravates reflux, which is a risk factor. So it's a contributor. Family history would also be another contributor.

Q Doctor, are there any other opinions that you intend to express at trial that we haven't covered today?

A Not that I'm aware of at this time. Q Okay. I don't have any other questions. Thank you.

MR. DUNCAN: Anyone on the phone? I don't have any. Nick, do you have any?

MR. MIZELL: No, I don't have any questions. MR. RILEY: This is Sean. I have no questions. MS. MILLOR: This is Sandra. I have no questions,

either. MR. BRAZZEAL: Doctor, you can read ~

* * * ]^Q

1 2 3 4 5 6 7 8 9

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30

Page 31 MR. DUNCAN: Wait a minute, wait a minute. Chris? MR. WINDHAM: I'm going to hold off. MR. DUNCAN: All right. So no questions. All

right. MR. BRAZZEAL: Doctor, you can read a copy of your

deposition if you like. MR. DUNCAN: He will. He'll read and sign. MR. BRAZZEAL: okay. Court reporter, I would like

to take a copy. Or actually I'm ordering it since I'm taking it.

* * *

l 2 3 4 5 6 7 8 9

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30

Page 32

CERTIFICATE OF READING AND SIGNING

I, MERRILL BIEL, M.D., have read the foregoing transcript of rny deposition, taken by Daniel W. McMahon, Court Reporter, and believe the same to be true and correct (or except as follows listing the page and line number and the reason):

Date Signature

es ***

l 2

3 4 5 6 7 8 9

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

*** Notes *

Page 33

STATE OF MINNESOTA ) ) ss.

COUNTY OF HENNEPIN )

Be it known that I took the deposition of MERRILL BIEL, M.D., on the 6th day of May, 2011, at 1:15 p.m.;

That I was then and there a notary public in and for the County of Hennepin, State of Minnesota, and that by virtue thereof I was duly authorized to administer an oath;

That the witness before testifying was by me first duly sworn to testify to the truth and nothing but the truth relative to said cause;

That the testimony of said witness was recorded in computerized Stenotype and thereafter transcribed by myself, and that the testimony is a true record of the testimony given by the witness to the best of my ability;

That I am not related to any of the parties herein nor interested in the outcome of the action;

That the reading and the signing has been executed as evidenced by the previous page.

WITNESS MY HAND AND SEAL THIS 6TH DAY OF MAY, 2011.

H**

Page 30 - Page 33



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20:27 21:2 21:15 21:21 24:1 24:11 26:29 30:15

a l coho l s [i] a l l eged [i] a l one [2] 20:30 a l w a y s [i] a m o u n t [4]

21:21 a n a t o m y [i] a n s w e r [2] apo log i ze [2] a p p e a r a n c e s p] a p p e a r e d [6j

2:19 2:23 appea r ing [i] applied [i] appointment [i approved [i] area [2] 24:22 areas [i] 29:16 associated pi assume [i] assuming [i] a t t e m p t [i] attorney [6]

11:19 11:28 attorneys [6]

11:13 15:29 authorized [i] available [i] Avenue p] avoidance [2] aware [4]

30:22 background [i] Bacon [5]

11:19 13:28 Barnes [i] b a s e [2] 22:24 b a s e d [2] 10:7 b a s e l i n e [2] b a s i s [i] 16:5 b e c o m e s [i] beer[4] 21:17 bee r s [6] 21:24

24-10 24-24 beha l f [l] B e n s o n [2]

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18:28

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24:6

6:8

11:4

4:13

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b e s t [ i ] 33:18 b e t w e e n [8]

20:25 21:14 Biel[6] 1:19

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32:4 33:6 bil l Li] 10:17 bi l led [ii biology [i] Bismarck [i] b i t [ i ] 3:24 blanking [i] board p] 5:27 Boulevard [i] B o x [l] 2:5 Brazzeal [13]

4:2 4:2 13:19 28:16

break p] 7:25 Brickell [i] business [3] cancer [66]

10:26 10:28 17:13 17:23 18:5 18:12 19:10 19:15 20:4 20:5 20:22 20:26 21:12 21:16 22:19 22:23 24:13 24:26 26:7 26:17 27:8 27:13 28:3 28:4 29:6 30:6

cancers [12] 22:12 22:21 25:9 26:9

capacity [i] case [29] 3:16

10:15 10:18 12:1 12:8 13:29 14:2 16:5 16:8 22:29 23:2

cases [9] 7:19 9:3 11:7

caused [4] 26:26

causing [2] CDC[i] 12:29 cells [l] 29:9 Center [i] certain [4] 29:7

certainly p]

14:25 22:15 3:6

10:11 5:19 8:11

11:16 5:28 2:9

2:3 5:2 30:30 13:12 2:27 4:12 6:25 14:27 17:27 18:23 19:20 20:9 20:28 21:28 23:23 25:11 26:23 27:16 28:5 30:9 17:30 22:25 26:11 7:11 8:12 10:22 12:10 14:5 19:23 23:4 8:2 11:13 13:25

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9:9 CERTIFICATE^] certification^] 5:30 certifications certified [i] cetera [i] C h a d [4] 2.3 chance [6]

20:30 24:13 chances 111 change [i]

[i] 5:28 6:15 3:15 15:17 24:25 26:16 27:7

$375

17:15 22:18 22:6

5:30

3:13 5:2 31:5 28:16

9:15 6:27 16:23 17:29 18:26 19:25 20:14 21:1 22:10 24:3 25:23 26:26 27:19 28:6

18:22 25:1 28:1

9:6 11:15 12:13 15:10 20:24 23:9 8:24 11:18 22:21

21:28

16:20

29:21 32:2

5:27

4:2 17:23

- change

20:21 22:20 24:29

3:15 13:14 31:8

9:23 8:14 17:9 18:1 19:4 19:28 20:17 21:9 22:16 24:7 26:4 27:6 27:23 28:8

22:4 25:8

10:4 11:23 13:28 15:30 22:28 29:17 8:29 11:20 23:20

21:8

30:17

5:2 19:20

Index Page 1


Multi-Page TM changes - experience changes [i] charge [4]

10:9 Chrffypj

17:6 9:29

2:14 chemotherapy [i] Chicago [i] C h r i s [3] 2:22 chronic p] cigarette [4] 25:24

cigarettes p3] 16:28 17:22 23:16 23:19

CIRCUIT m C i t y m 2:10 C I V I L [i] claimed [i] clarification [i] clear [6] 19:1 21:26 30:5

clearly [i] clinical p] clinically [2]

5:14 4:10 20:8 16:14

15:6 17:26 29:22 1:2

1:3 22:7 27:22 21:13

22:2 10:24 17:2

co-investigator [i] colleagues [i] combination [23 comfort [i] commencing [i comment p] common p]

27:2 30:13 commonly [i] company p]

2:24 4:6 28:24

compared [i] completed [2]

12:12 20:27 13:12

] 1:24 28:12 22:22

27:30 1:11 8:19

19:29 5:16

completely p] 24:17 components [i] 12:17 computerized [i] conclusion [i] conclusions [4]

15:5 conditions [i] conducting [i] confirm [i]

14:24 14:22

16:13 7:12 12:18

consequences [6] 13:3 13:9

consistent [i] constitute [i]

19:5 12:20 23:13

consumption [i] 24:12 contacted p] containing [11 CONTINUED contributing [3] contributor p]

30:19 COpy [3] 6:8 correct pj

20:12 21:4 32:6

correlated [i]

10:20 15:16

[ i ] 23:14 16:23

31:5 8:7 25:2

21:28

10:2

4:7 6:22

31:1 27:2 16:22

15:15 19:25 29:27 1:2

21:14

29:11 30:16 29:10

30:16

22:23

2:11 23:13

5:20

33:16

14:30

11:26 19:12

10:23

13:19 24:2 24:21

31:9 14:1 26:24

10:6

30:11 17:28

16:27 23:12 30:1

21:20

29:25

26:22

2:16 28:22

15:4

12:23

10:29

30:15 30:18

20:11 30:1

counsel [2] County p]

33:3 33:9 COUrt [5] 1:2

32:6 covered [i] Cra ig [2] 2:3

9:25 1:3

8:25

30:21 4:3

10:20 1:21

10:9

CROSS-EXAMINATION m Cummings p] curriculum [i] D a k o t a [i] D a n i e l [2] d a t a p ] 21:25 da t e p] 10:12 d e f e n d a n t [4]

8:17 D e f e n d a n t s [i] de fense p] degree pi

29:12 6:6 8:11 1:20

32:29 7:27

1:12 9:24 5:18

d e m o n s t r a t e d m d e m o n s t r a t i o n D e p a r t m e n t p] d e p e n d p] d e p e n d e n t p] d e p e n d i n g [2] deposes [13 d e p o s i t i o n [123 7:28 8:2 11:20 31:6

d e p o s i t i o n s pj d e r i v e d [i] de s igna te p] deve lop [2] d e v e l o p e d [4] 27:17

d e v e l o p i n g p2] 17:23 17:27 19:3 19:10 20:3 20:14 24:13 24:26 26:7 26:17 28:3 28:6

[ l ] 7:16 21:2 16:24 17:6 3:9 1:19 8:6 32:5 11:30 9:7 17:1 18:21 19:25

14:26 18:12 19:15 21:1 25:11 27:5 30:6

d e v e l o p m e n t p] 10:27 16:23 20:22 25:1

deve lops p] d e v o t e d [i] d i a g n o s e d p] d i a g n o s e s [2] d i a g n o s i s [i] d i f fe rence [3] d i r ec t ed p] d i r e c t o r p] d i s ag ree p] d i s c l o s u r e pj

16:10 22:5 d i s c u s s [i] d i s c u s s e d p] d i s e a s e pi d i s ea se s p] disputed p] disqualified p]

22:16

28:2 7:5 27:18 16:12 8:14 17:14 14:7 6:25 14:13 15:20 23:11 29:26 16:2 6:15 16:13 21:12 8:24

29:13

32:5

7:30

10:20 23:23 25:25 22:3 12:25 25:15 16:25 20:15

1:20 8:18 33:5

20:17 27:8

17:9 18:23 19:20 22:12 25:23 27:13 30:8 16:12 22:19

27:20 16:20

17:15

15:27 15:23 24:29

6:15 16:21

10:4

31:8

3:11

8:16

3:17 9:29

27:16

17:13 18:25 19:28 24:2 26:4 27:18

16:20 23:22

27:28

15:27 28:9

30:12 22:7

dissections 111 D i t t o [l] 23:6 DIVISION [i] d o c t o r [io]

13:20 16:8 30:30 31:5

d o c u m e n t p] 11:29 14:6

d o e s n ' t p] d o n e p ] 27:30 d o s e p ] 14:24 d o u b l e [i] d o w n p] 7:25 26:14

D r p] 22:5 d ra f t [l] 15:22

6:20

1:3 3:15 23:5

9:22

17:12

15:5 20:30 10:5

24:29

d r a m a t i c a l l y p] 17:18 d r a n k p] 21:3 d r a w n p] d r i n k p] 21:7 drinking p] drug p] 29:7 d u e p ] 26:11 d u l y [4] 3:2 Duncan [33]

4:5 4:24 9:27 11:11 15:11 17:24 21:6 23:1 26:6 26:21 28:17 30:24

duration p] 19:22

during pi Ear p] 4:15 educational p] E i g h t h [i] either p] 8:18 employed [4] 28:24

E N T p ] 6:14 entire p] 14:11 entitled p] environmental

30:13 Esquire pi

2:13 2:18 e t p ] 1:11 etiology [2] evaluate pi evaluated p] evidenced [i] examp] 5:30 examined [i] example pi except p] Excuse [i] executed p] exists [i] expected p] expenses p] experience p]

23:28 14:30 21:22 21:14 29:8

3:8 2:8 4:30 11:16 18:27 23:30 26:27 31:1 14:25

7:24 6:14 5:11 1:23 30:29 4:18

7:22

11:25 PI

2:3 2:22 6:15 16:11 10:26 6:28 33:23

29:18 18:16 5:3 13:11 33:23 26:11 16:10 10:8 12:19

4:11 28:21

11:27

19:10

16:24

11:10

17:19

24:10 21:17

33:10 3:24 9:1 13:11 19:7 24:4 27:9 31:3 15:7

18:6

4:21

20:8

2:4 2:26 14:18 16:19

32:7

10:10 25:10

5:6 30:20

11:28

26:14

26:14

24:24

33:13 4:5 9:18 13:15 19:21 25:28 27:21 31:7 17:7

5:7

24:21

2:8

14:19

26:1

Index Page 2


Multi-Page TM i n f ec t i on [i] 22:22 i n f o r m [i] 25:4 i n f o r m a t i o n [2] 16:4 in ju r i e s [2] 23:14 i n s i g n i f i c a n t [i] 17.14 i n s t a n c e [2] 16:28 I n s t i t u t e [2] 6:27 I n s t i t u t e s [2] 29:1 i n t e n d [i] 30:20 i n t e n d i n g [i] 10:17 i n t e n s i t y [4] 14:27

17:7 i n t e r e s t e d [ii 33:21 I n t e r n e t [ii 14:4 i n t e r r u p t [i] 23:1 i n t e r r u p t i o n [i] 4:23 i n v o l v e [2] 8:12 i n v o l v e d [i] 8:13 i n v o l v e s [i] 29:4 i r r i t an t [i] 22:2 i s s u e [l] 8:13 i s s u e s [l] 28:10 i t s e l f [2] 21:11 21:27 J o h n p ] 1:8 3:16

19:24 I j o i n i n g [i] 4:27 JUDICIAL [i] 1:2

| jury[2] 16:19 25:4 K a n s a s [i] 2:9 K a s o w i t z p ] 2:27 k i l l s [i] 29:9 k i n d [2] 5:9 30:4 k n o w l e d g e [i] 10:25 k n o w n [4] 16:22

33:5 l a n g u a g e pi 15:22 l a r g e l y [i] 16:25 l a r y n g e a l [62] 10:27

17:9 17:13 17:30 18:12 18:21 18:23 19:10 19:15 19:20 20:5 20:9 20:14 20:26 20:28 21:1 21:16 21:28 22:10 22:19 22:21 22:25 24:7 24:13 24:26 25:23 26:4 26:7 26:17 26:23 26:26 27:16 27:18 27:23 28:4 28:5 30:6

l a r y n g e c t o m i e s [i]

e x p e r t - l i g h t e x p e r t [i7]

7:21

3:8 33:13 7:24 17:15 18:6 18:28 19:6

7:2 9:8 15:19 28:13 10:24 28:11 20:8 20:9 20:20 14:26 30:16 13:27 20:19 26:30

8:27 10:24 11:3 24:29 28:9

e x p e r t i s e [i] e x p e r t s [i] e x p o s u r e [2] e x p o s u r e s [3] e x p r e s s [2] f ac to r [7]

25:18 27:2 f ac to r s [i4]

20:3 20:9 26:12 26:17 30:8

f ac t s [l] 22:28 f a m i l y [2] fa r [l] 9:6 f a s h i o n p] fee p] 9:11 f e l l o w s h i p [i] f ew [4] 13:24 f ie ld [l] 7:22 fifth[2] 2:14 f igure [i] f i n a l l y [i] f ine[ i ] 13:14 f i n i s h e d [i] f i r m [5] 2:4

11:1 f i r s t [6]

28:5 f ive [24]

17:10 18:3 18:28 19:2

f i v e - y e a r [i] F l o r i d a [6]

2:28 10:4 f o l l o w - u p [1] f o l l o w i n g [i] f o l l o w s [2] fo r ego ing [i] f o r m [15] 9:1

17:24 18:27 24:14 26:6 27:21

f o r m s [i] f o r m u l a t i n g [i] F o r t m 2:5 f o r w a r d [3] f o u n d [i] four [5] 7:28

23:30 FRIEDMAN [i] 2:27

7:13

14:29 9:22 5:21 13:25

8:6 4:28 15:3

9:18

2:9

5:30

7:29 17:21 18:13 18:29 19:11 28:7 1:3 10:5 6:22 3:2 3:9 32:4 12:13 19:7 26:21

16:5 29:17

6:7 22:25 8:4

f ron t [2] 13:1 ful l [ i ] 4:19 fu l ly [l] 21:30 f u n d e d [2] general p]

23:4 23:22 general's [5]

15:20

28:27 6:14

7:6 9:11 22:5 29:28

30:11 24:21 30:21 23:14 30:17 16:11 22:11 30:6

30:18

15:8 10:7

14:4

2:14

7:18

8:1 17:22 18:24 18:29 19:14

2:5

32:7

12:15 19:21 26:27

6:9

10:16

29:11 12:24

7:18 10:21 23:10

30:13

24:2

16:19 24:5 30:7

16:25

20:19

2:26

14:22

17:8 17:26 18:25 18:30 21:25

2:15

15:11 24:4 27:9

9:24

23:28

29:15 29:26 g i v e n p] 7:25 8:2

33:18 g i v i n g [i] 18:15 goes [4] 14:28 26:4 g o o d p ] 3:15 3:23 g r a d u a t e d [l] 5:14 G r a n d [i] 2:9 g r a n t p] 29:1 29:3 grea t [ i ] 28:17 g rea te r p]

20:15 24:12 G r o u p [2] 2:29 g u e s s [4] 13:5 21:8 H A N D m 33:24 h a p p y [i] 6:10 hard[2] 21:15 21:20 H a r d y p] 2:9

11:19 13:28 head[i4]5:10 5:15

6:13 6:24 6:26 10:25 22:4 22:23

h e a l t h [io] 11:25 12:26 13:3 13:8 29:1 29:10

h e a r p ] 3:26 3:27 H e n n e p i n p] 1:21 he r e in [i] 33:21 H i p ] 4:25 his tory[ i2] 15:10

20:7 23:25 23:28 24:22 25:20 27:23

h o l d [4] 5:27 7:8 H o s p i t a l [i] 5:23 h0UT[i] 9:21 h o u r l y p] 9:19 h o u r s [2] 10:14 10:16 HPV[9] 20:8 20:19

22:21 22:23 24:19 H u m a n [l] 12:25 h y p o t h e t i c a l p] 19:30 H y p o t h e t i c a l l y [i]

11:25 12:18

12:27

12:21

i d e a p ] 22:13 I D S [ i ] 1:23 I l l i no i s [i] illness in important [i] impression [i] Inc[4] 2:11 incidence [i] include PI including [i] income [i] increase pj 24:8 24:25

increased [6] 19:9 19:14

increases [4] 20:29

increasing pj individual pi induced [i]

23:17

5:14 13:30 29:16 29:25 2:16 26:10 30:10 16:13 9:7 14:27

17:23 24:28 17:18

17:18 17:22 27:30

8:23

26:14 3:25

29:4

2:29 21:27

11:2

5:21 6:29 25:8 12:23 19:5

5:6 33:3

15:12 24:10 30:18 27:15

9:28

22:15 26:18

20:10 24:5

2:20

30:11

17:16

18:20

19:19

21:15 19:27

11:20

27:6

17:10 17:26 18:4

27:22

11:4

5:28 10:25 29:5 12:25 19:12

33:9

19:27 24:20

31:2

10:8

22:18 30:11

23:26

2:29

30:11

21:11

19:3

20:28

22:4 29:12

4:28 4:27 2:19 1:3 9:1

l a s t p] l a t e [i] l a w p] L e e p] l ega l p] l e n g t h [i] l e s s [3] 7:7 l i c e n s e d \2\ l i fe [i] 25:24 L i g g e t t p] l i gh t [i] 29:8

7:24

2:23 10:4 9:3 16:29 9:10 5:24

2:29

28:15 23:20

17:7 28:30 29:10

16:26 16:29

29:3

12:1

4:26

21:11

15:24

14:26 18:1 18:26 19:28 20:17 21:9 22:12 23:23 25:8 26:9 27:6 27:30 30:8 6:18 7:28

11:1

21:24 6:3

4:26

15:9

22:24

15:26

16:23 18:4 19:4 20:3 20:22 21:12 22:16 24:2 25:11 26:10 27:13 28:3

Index Page 3


Multi-Page1 m i s s m 5:3 M i s s o u r i [i] M i z e l l [4]

30:26 m o m e n t [i] m o n e y [i] MORGAN [2] M o r r i s [2] m o s t [6] 25:9

27:1 27:2 M S [4] 4:25 m u l t i [ i ] 6:24 m u l t i - s p e c i a l t y [i] M y e r s [i] 2:5 n a m e [4] 3:15 n a m e d [i] n a m e s [2] I N a p l e s [2] N a t i o n a l [2] n e a r l y [i] n e c k [15] 5:10

6:13 6:20 10:25 10:25 29:6

n e e d [2] 6:22 n e v e r [4] 17:28 nex t [ i ] 15:25 n i ce [ i ] 14:15 N i c h o l a s [i] N i c k [2] 4:7 n i c o t i n e [4]

29:30 n o n - d i a g n o s i s [i] n o n - e a r l y [i] 8:14 n o n l i n e a r [2] 14:29 n o n s m o k e r [io] 17:10

18:20 18:26 19:29 27:14 27:19

n o n s m o k e r ' s [i] 26:16 n o n s m o k e r s [6] 18:21

26:8 26:11 27:1 nor [ i ] 33:21 n o r m a l [2] N o r t h [i] N o s e [ l ] 4:15 n o t a r y [2] n o t e s [2] 12:10 n o t h i n g [3] N o t i c e [i] NOW [5] 12:21

27:4 n u m b e r [4]

32:7 o ' c l o c k [i] o a t h m 33:11 Objec t [i3]

18:27 19:7 26:6 26:21

ob t a in [i] o b t a i n e d p] occurs [i] off [7] 6:5

l i k e l y - p e r c e n t l i ke ly [ i ] 20:16 l i m i t e d [i] 7:21 l ine[ i ] 32:7 l i s t en [i] 3:20 l i s t i n g [i] 32:7 l i t e r a t u r e [2] 16:14 l i t i g a t i o n [4] 7:2

11:3 l o c a t e d [i] 8:10 look[ i ] 13:27 l o o k e d [2] 12:17 l o o k i n g [3] 14:16 Lor i l l a rd [ io ] 2:10

2:16 4:5 4:8 23:16 23:20

L o u i s [i] 5:23 l o w [ i ] 26:19 L t d [i] 2:29 M - a - i - e - r p ] M.D[4] 1:19 M a i e r [2] M a i e r ' s [ i ] M a i e r / T i s c h [i] 15:3 m a i n [ i ] 14:21 m a j o r p j m a j o r i t y [i j m a k e s [i] m a l p r a c t i c e [i] . m a n u f a c t u r e d [2] m a t e r i a l s [5]

23:5 29:19 m a t t e r [i] m a y [ii] 1:22

24:27 24:29 33:6 33:24

M c M a h o n [ 2 ] 1:21 M c M i l l a n ^ ] 11:10 m e a n [8] 9:1 16:10

21:23 21:23 23:15 m e a n i n g [i] 18:27 m e d i c a l [s] 5:12

8:21 9:2 12:3

14:18 3:6 14:18 14:22

6:17 26:25 27:28 8:21 ] 11:22

10:11 6:7 26:29

m e d i c a l / l e g a l [i] m e d i c i n e [i] m e n t i o n e d [2] M E R R I L L [4]

33:6 M i a m i [i] M i c h a e l [i] M i c h e l m a n pi

11:12 11:12 M i l l o r [6]

5:1 5:5 m i n d [ i ] 13:13 m i n i m a l [2] M i n n e a p o l i s [2] 1:24 M i n n e s o t a [ii] 1:22

4:16 5:16 7:16 33:2

m i n o r [i] m i n u t e [3] m i n u t e s [i]

5:24 20:19 1:19

2:28 29:12 10:30

2:26 30:28

17:11

5:20 33:9 5:19 13:15 4:28

25:10 7:27

14:14 14:17 2:11 6:8

14:20 32:4 14:20

25:17

23:12 15:29

13:10 28:9

32:5

20:16 26:20

5:13 12:15 7:19

29:18 3:6

11:1

4:25

17:14 4:13 1:24 5:26

31:1

9:8

23:10 2:15 23:13

33:6

23:19 16:3

22:6 28:11

20:29

6:30 16:14

32:4

11:11

4:25

4:13 7:10

31:1

2:10 2:13

6:5 28:21 2:4 2:19 25:10

5:1

5:3 29:12 11:15 2:14 29:1 21:20 5:15 6:25 22:4

27:22 25:23

2:13 30:25 15:16

18:11 8:11

1:21 12:30 10:13 1:20 13:3

4:29

1:25

9:1 19:21 26:27 13:23 5:18 16:24 10:7

4:7

2:4 4:9 25:13

5:5

6:27

11:10

11:17 4:8 29:10

5:21 6:26 22:23

29:22

8:13

15:7 17:27 20:17

15:11 24:4 27:9

11:27

12:29

4:7

25:30

30:28

11:12

5:29 6:30 25:8

26:10 28:5

29:27

18:5 27:6

18:23 22:26

26:15

33:8

23:9

19:23

15:6

33:13

19:27

16:27

17:24 24:14 27:21

11:29

13:24

13:25 14:4 31:2 Offer [5] 22:14 22:27

28:10 offhand[2] 9:15 of f ice [4] 2:5

12:26 o l d e r [i] 6:6 O n c e m 8:9 o n c o l o g i s t s [3] 6:29 o n c o l o g y [2] 5:22 o n e [io] 6:6 6:7

9:10 15:25 18:29 30:15

o n e s [4] 14:21 29:18 o n g o i n g [i] 16:30 o p i n i o n [6] 9:5

24:27 25:21 26:3 o p i n i o n s [19] 12:13

15:14 16:6 16:8 22:27 22:29 23:3 28:10 28:12 28:14 30:20

order[4] 12:12 12:15 o rde r ing [i] 31:9 o t o l a r y n g o l o g i s t [i] o t o l a r y n g o l o g y [4]

5:28 7:16 o u t c o m e [i] 33:21 o v e r v i e w [i] 5:11 o w n [3] 14:6 14:8 o w n e r [i] 4:19 P[ i ] 2:13 p . m [ i ] 1:25 p . m . [i] 33:7 p a c k [22] 15:7 16:30

17:15 17:17 17:19 18:19 18:28 18:29 19:6 19:11 19:14 23:28 24:10 25:20

p a c k s [7] 16:28 18:8 18:16 18:17 25:19

p a g e [2] 32:7 33:23 Park[3] 4:13 28:29 p a r t [2] 4:19 6:17 p a r t i c i p a t e d [i] 28:26 p a r t i c u l a r [2] 14:12 p a r t i c u l a r l y [3] 21:14

22:29 24:30

p a r t i e s [i] p a r t n e r [i] p a s s [l] 5:30 P a s s i d o m o pi p a s t [io] 8:3

11:16 12:20 27:20

p a t i e n t [2] p a t i e n t s [9]

6:28 19:13 29:5

p e o p l e [6] 26:9 29:23

p e r [ i i ] 15:6 18:16 18:17 24:11 24:24

p e r c e n t [7]

33:21 4:19

2:14 8:5 17:4

6:22 6:11 26:25

6:28 29:24 16:27 18:29

6:13

10:1 9:16

6:30 6:26 7:7 20:15

29:18

24:8

12:16 19:23 23:4 29:17

5:10 5:15

26:1

17:8 18:10 18:30 19:27

18:9

29:7

17:9 25:7

4:7 11:5 25:12

28:2 6:13 26:28

17:2

16:28 24:1

6:14

9:23

7:1

7:15 25:6

30:14

24:11

15:9 20:20 24:30 29:20

12:18 24:17

5:19

17:11 18:18 19:2 20:6

18:14

26:30

11:6 25:16

6:25 29:4

21:16

18:9 24:7

7:7

Index Page 4


Multi-Page1 percentage - slight 9:10 26:8

p e r c e n t a g e p j p e r f o r m [3] p e r f o r m e d [i] p e r h a p s pi p e r i o d [i] p e r s o n [io]

25:19 25:20 27:11 27:23

p e r s o n ' s [5] 24:25 26:3

P h . D [ i ] 5:18 P h i l i p p] p h o n e [i] p h o t o d y n a m i c

26:28 7:5 6:16 14:5 13:7 28:7 18:11 25:22

19:20

2:19 30:24

[2] p h o t o s e n s i t i z e r [i] p h y s i c i a n [4]

6:23 P i p e r [i] 6:26 p l a c e [i] 28:5 p l a in t i f f [13]

4:3 4:3 8:16 13:29

p l a i n t i f f ' s [2] p l u s [i] 10:8 p o p u l a t i o n p ] p o r t i o n s p] p o s i t i o n s [i] p o s i t i v e [i] p o s s i b i l i t y [i] p o s s i b l e [i] P o s t [l] 2:4 p o t e n t i a l [2] p r a c t i c e [7]

6:12 6:17 p r e p a r a t i o n pi p r e s e n t [i] p r e t t y [i] p r e v i o u s [7]

24:22 25:17 p r i n t [i] 13:25 p r i n t e d [i] p r o b l e m [i] p r o c e e d i n g s [i] p r o f e s s i o n a l [i p r o f e s s o r [i] p r o g r a m p] p r o v i d e p] p r o v i d e d p j

16:5 28:15 p u b l i c p] p u b l i s h e d [i] p u l l e d [2] p u r s u a n t p i p u t pi 10:15 q u e s t i o n s [7] 30:26 30:27

q u i t [2] 27:8 q u i t e [i] 9:18 R[i ] 2:3 R . J p ] 1:11

4:19

1:9 5:3 19:24 23:12

25:25 11:24 7:8 22:15 10:27 8:13

19:12 4:20 7:13 10:14 7:15 16:24 9:9 30:12

13:24 4:30 3:2

] 4:11 7:9 6:26 5:11 11:28

1:21 12:25 14:4 1:19 22:20 3:21 30:28 27:12

2:23

26:30 7:25 6:18

13:21

21:2 27:4

19:28

4:9

29:5 29:7 4:20

2:6 7:26 22:7 28:11

26:8 14:12

30:2 5:7 26:23

13:4 33:23

6:27 16:18 15:30

12:26

14:15

23:2 15:26 31:3

4:10

9:7 6:20

25:15 27:7

24:1

29:6

5:9

3:16 7:29 28:11

26:15 14:14

5:24

13:28

7:16

16:3

33:8

30:23

r a d i a t i o n pi 27:29 27:30

r a i s ed [i] r a re [i] 26:22 r a t e [5] 9:19

21:15 r e a d pi 12:19

31:5 31:7 r ead ing pi r ea l ly [4]

23:9 r e a s o n [i] r e ca l l ed [i] r ece ived p] r ecen t p] r eces s pj r e c o n s t r u c t i v e r e c o r d [2] r e c o r d e d [ij r e co rds p]

12:4 15:13 23:8

r ecu r rence [2] r e d u c t i o n pj refer p] 6:23 re fe r red [2] r e f lux [si

26:30 27:2 r ega rd [5]

24:19 25:7 r ega rd ing p]

16:19 16:20 25:4

r ega rds [i] r e l a t ed pi

19:22 21:9

5:19 30:12 28:11

9:28

14:10 32:4 32:2 13:12

32:8 12:19 27:29 6:7 13:17

[ i l 6:5 33:16 9:20 15:18

28:4 24:30 16:30 8:30 20:8 27:3 22:8

3:21 20:21

26:3 6:14 22:29

r e l a t i onsh ip [ii] 14:25 20:25 21:13 22:15 22:18

r e l a t ive [i] r e ly ing [i] r e m e m b e r [i] r e m i n d [i] r e p h r a s e p] repor t [in

12:24 12:30 13:21 13:23 14:15 29:15

r epo r t ed [i] r epor t e r P I

21:14 22:20 33:14 29:19 11:14 3:19 3:22 11:25 13:3 14:4 29:16 16:13 3:30

repor t s P I 12:6 r ep re sen t [i] 3:16 r ep resen t ing pi 2:6

2:19 2:23 2:29 r eques t [7]

8:19 11:4 r e sea rch [6]

14:8 28:21 r e s i d e n c y [ii r e s iden t [i] r e s iden t s pi r e s p o n s e pi

28:10

7:26 11:9 7:17 28:26 5:15 7:15 7:13 14:25

6:30

10:8

29:28

33:22 17:9

28:21 6:8 28:19 5:22 33:18

9:28 19:26

28:7 25:5 25:30 9:4 24:20 30:11 22:9

16:11 22:6

10:27 23:9 15:6 21:18

17:25 12:18 13:4 14:9 29:26

31:8 28:13

2:10 4:5 7:26 11:18 12:15

7:14 15:5

24:22

21:12

30:30

17:17

13:20

11:6 22:13

26:18 30:17 24:19

16:12 22:14

13:30 33:20 20:21 21:20

22:28 12:22 13:8 14:11

32:6

2:15

8:15

14:5

16:24

r e s t a t e pi r e s u l t s [i] r e t u r n s [i] r e v i e w [4i

15:17 r e v i e w e d [ii]

11:18 11:22 15:13 19:26

r e v i e w i n g [i] R e y n o l d s p] r i g h t [14] 9:28

17:21 19:19 23:10 23:26

R i l e y pi 2:18 30:27

risk [54] 10:26 16:11 16:19 17:16 17:17 18:20 18:22 19:14 19:28 20:28 20:29 24:5 24:8 25:1 25:4 26:7 26:12 27:5 27:12 30:6 30:7

r i s k - w i s e [i] r i s k s p i 12:20

24:23 r o l e p ] 16:13 R o s w e l l p] r o u n d s [i] r u n [i] 6:24 S a n d r a pi s a y s [6] 3:9 24:29 28:9

s c h e d u l e p] School [21 sc i en t i f i c [i] S E A L p ] S e a n p ] 2:18 s e c t i o n [i] s e e p ] 6:13 s e l e c t i v e l y [i] s e n i o r [i] s e n t e n c e [i] s e rve [i] 10:21 s e r v e d [i] S e r v i c e [i] s e rv i ce s [2] s e r v i n g p] se t [ i ] 10:4 S h o o k [5j

11:19 13:28 s h o r t p ] 13:12 Sign[i] 31:7 S i g n a t u r e pi s i gn ing pi s i m i l i a r pi s i m p l y [i] s i n u s pi 6:15 s i t [ i ] 23:15 s l igh t [l] 24:28

27:10 14:30 27:13 9:20

11:6 11:24 22:13 10:11 1:11 11:22 20:24 26:20 4:9

13:27 17:6 17:27 18:25 20:3 22:6 24:16 25:11 26:17 27:18 30:8 16:22 22:4

28:29 7:12

2:26 16:10

9:11 5:12 16:14 33:24 4:9 29:28 11:14 29:9 4:19 16:17

7:2 12:26 8:27 7:6

2:9

32:29 32:2 13:8 20:5

9:28

11:13 11:30

2:23 13:15 21:8 31:3 4:9

14:26 17:8 18:4 19:3 20:9 22:11 24:28 25:22 26:30 28:3 30:15

24:15

29:7

4:25 22:5

9:22 5:13

30:27

26:9

12:26 7:18

11:2

33:22

"

10:14

11:15 12:3

4:10 15:22 22:5 31:4 24:14

14:28 17:12 18:11 19:9 20:14 23:22 24:30 26:3 27:2 28:6 30:17

24:18

30:28 23:11

10:7

9:8

11:4

Index Page 5


sl0W[l] 17:14 smoke [9]

19:4 19:10 21:16

| smoked [IO] 23:16 23:25 25:24 26:10

| smoker [4] 27:15

smokers [2] smokes [7]

18:3 18:24 smoking [59]

12:23 13:3 14:26 15:7 16:22 17:5 17:15 18:15 19:15 20:5 21:17 25:6 27:5 30:16

Multi-Page slow - vs T i s c h [ i ] 14:20 t i t l e [i] 12:21 t o b a c c o [9]

' 5 8:19 :27

t o d a y [4] 9:7 T o m [ l ] 4:5 t o n g u e [i] t o n s i l [l] 22:24 t o o [2] 22:26 t 0 0 k [ i ] 33:5 T O R R E S [i] touched [i] I towards [i] T o x i c [i] t r a n s c r i b e d [i] t r a n s c r i p t [i] t r e a t p] 6:11 t r e a t e d \i\ t r e a t i n g [i] t r e a t m e n t [4]

29:9 t r i a l p] 8:8

20:21 29:11 t r u e [3] 27:15 t r u t h [2j 33:13 t r y [i] 3:22 t r y i n g [3] tumOT[2]

14:28 19:11

16:27 25:12

24:9

16:26 17:7 18:6 18:16 19:16 20:12 21:29 25:7 27:8

17:22 18:25 10:26 13:9 15:9 16:30 17:8 18:8 18:19 19:19 20:27 23:19 25:9 27:12

27:10

1:23 10:5 17:29 10:25

25:3

23:22

4:30 5:12

4:11

6:3 20:19

33:16 2:4 25:28

17:3 19:13

17:4 25:15

24:9

22:25 26:29 17:25 27:12 11:26 13:27 15:12 17:2 17:11 18:9 19:2 19:22 20:30 23:23 25:21 27:17

17:12 18:24 25:23

2:14

17:30 10:26 4:15 22:27

s o m e o n e [13] 17:8 18:3 18:3 18:24 19:9 25:7 25:12

s o m e w h e r e [i] 9:23 soon[ i ] 10:17 s o r r y [2] 21:6 sor t [l] 9:20 sor t s [i] 19:12 S o u t h p] s o u t h w e s t [i] s p e a k p] 3:24 s p e c i a l i s t [2] S p e c i a l t y C a r e [i] s p e c i f i c ^ ] 169

23:2 23:9 s p e c i f i c a l l y [i] SS [i] 33:2 St [ i ] 5:23 s t a n d p o i n t [i] s ta r t [ i ] 7:18 s t a r t ed [i] s t a r t i ng [i] s t a r t s [i] 17:17 State[5] 1:22 4:11 23:9

33:9 s t a tes [2] 5:24 s t a t u s [5]

24:19 26:18 S t e n o t y p e [i] S t e v e n s [2] Still [2] 21:6 Stop[i] 27:16 S topped [3] 25:9 S topping [l] 25:22 Stops [2] 25:6 25:7 S t ree t [l] 1:23 s t rong ly [ i j 21:28 s t u d e n t s [2] 7:12 7:13 Studies [9] 14:16 14:17

17:13 20:13

17:28 25:19

27:4

18:3

12:20 13:30 16:15 17:3 17:12 18:13 19:6 19:25 21:15 23:24 26:4 30:10

17:25 19:4 28:4

4:13

22:29

4:3

33:2

22:15 22:18

25:21 27:5

22:2 25:13 25:17

21:12

21:19 25:29

S t u d y m 14:16 14:18 14:23 14:24 15:1

s u b m i t [i] 10:17 s u b s t a n t i a l [4] 20:14

23:14 s u b s t a n t i a l l y [5] 17:18

24:15 24:27 Such [4] 20:19 sued[ i ] 8:21 su f f i c i en t [i] s u i n g [i] 13:29 Su i t e [i] 2:28 s u m m a r i e s [2] s u p p o r t [i] su rgeon m

12:21 12:24 surger ies [i] s u r g e r y [4]

7:14 s u r g i c a l [i] s w o r n [2] S z y m a n s k i [9]

15:15 19:24 23:16

S z y m a n s k i ' s [4] 12:3 23:24

T -a -v -a -n - i [i] T - i - s - c -h [i] T a b a c c o [i] t a k i n g [2] T a v a n i [2] t e ach [i] 7:13 t e a c h i n g [i] t e l econ fe r ence [i] t e l e p h o n e [3] 2:19 t e n [21] 4:28

17:21 17:22 18:9 18:13 25:21 25:30 27:12 27:17

t e r r i b l e [i] t e s t i f i ed [2] t e s t i fy p]

22:6 33:13 t e s t i fy ing [2] t e s t i m o n y [i3]

9:30 10:2 28:10 28:12

t h a n k [4] 6:11 t h a n k s [ij t h e r a p y [2] 29: thereaf ter [ i ] 33: the reof [i] 33: t h e y ' v e [3] 17: T h o m a s [i] 2:8 th ree [i3] 8:4 8:4

18:20 18:22 21:24 24:1 24:7 24:10

T h r o a t [i] 4:15 t h r o u g h [i] 13:21 t i m e s [4] 18:11 18:20

14:19 15:3

21:22

22:4

26:13 26:18

23:13

14:15 29:20 5:10 12:26 6:16 5:15

6:29 3:9 1:8 22:11

14:19 14:20 2:15 1:20 14:19

7:11

17:11 17:26 18:17 26:8

11:15 8:8 10:5

8:15 7:21 16:18 33:15 19:1 5:5

:5 16 10 :4

14:16

11:25 29:15

5:22

33:13 3:16 22:30

15:9

31:10 15:1

1:23 2:23 17:15 18:3 25:10 26:30

8:18 14:2

33:12 7:25 22:7 33:17 19:1

29:6

11:8 23:28 24:24

25:25

14:19

21:23

24:8

28:13

12:18 29:26

5:29

12:1 23:5

23:19

2:28 17:16 18:6 25:14 27:5

16:11

8:23 22:14 33:18 30:23

18:19 27:20

18:11 23:30

1:11 23:13

28:1

2:27 30:4 7:6 30:12 33:17 32:5 26:23 27:24 29:4 6:24

8:10 30:21 32:6 33:14

TWENTIETH [i]

4:28 6:14

18:8 18:17 24:1

18:22 20:16

tWO [15] 18:16 23:30 25:19

t w o f o l d [2] t y p e [4] 6:11 t y p e s [2] 21:10 t y p i c a l l y [4]

28:7 U . S [ i ] 12:25 Uncommon [i] understand [7]

15:19 16:18 u n d e r s t o o d [ 11 u n h e a l t h y [i] U n i v e r s i t y [6]

5:23 7:10 u p [3] 3:24 U S A [ l ] 2:19 u s u a l l y [i] V e c t o r [2] v e r s i o n s [23 v e r s u s [i] v i a [5] 1:22

9:4 v i d e o [i] 1:22 v i r a l [l] 22:22 V i r g i n i a [i] v i r t u e [i] v i t a e [ i ] 6:6 v s [ i ] 1:10

18:9 18:20 24:7

20:28 17:27 24:23 8:29

26:22 6:6 29:23 21:30 19:16 5:13 7:15 14:28

16:30 2:29 13:4 7:26 2:19

6:26 33:10

2:11 2:24 28:22 28:24

23:15 28:14 30:21

22:24

26:25 27:26

29:4 29:8

8:19 10:2

33:17

13:7 16:17 29:9 1:2 18:11 18:13 18:22 23:28 24:10 24:24

20:29 17:29 21:7

17:2 26:29

13:7 15:4 30:2

5:16 5:20

23:2

4:27 13:20

2:23 2:28

Index Page 6


Multi-Page W - zero

Index Page 7


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