Complaint Counsel's Post Trial Brief - Federal Trade Commission

306. Roy did not conduct any work or tests on any product made by Respondents. (R20 (Roy,
Dep. at 8)).
307. Roy is not an expert in homeopathy. (R20 (Roy, Dep. at 12)).
308. Roy and his laboratory do "zero clincal trals." (R20 (Roy, Dep. at 13)).
309. Roy and his laboratory "have nothg to do with causing healing or not in a human
being." (R20 (Roy, Dep. at 13)).
310. Roy has not measured the effcacy of
the DCO Products. (R20 (Roy, Dep. at 14)).
311. Roy has never done any experents to measure the effcacy of any medical treatments
"at the human leveL." (R20 (Roy, Dep. at 14)).
312. Roy has no idea what the DCO Products contain. (R20 (Roy, Dep. at 24)).
313. Roy has not done any literatue searches or any literatue research concerg any of the
ingredients in DCO's products. (R20 (Roy, Dep. at 25)).
314. Roy does not have any formal traing in medicine. (R20 (Roy, Dep. at 26)).
315. Roy has never treated or consulted with healers who were treatig paricular patients.
(R20 (Roy, Dep. at 28)).
316. Roy does not know what Danel Chapter One sells. (R20 (Roy, Dep. at 43)).
317. The practice of Danel Chapter One sellng products over the Interet to people that it
had never seen, met, or examed the medical records for "obviously limts"
homeopathy. (R20 (Roy, Dep. at 50)).
318. Roy's ideal descrption of
homeopathy would not include selling products over the
Interet to persons that the seller has not met. (R20 (Roy, Dep. at 51)).
319. It is not Roy's view that all herbal remedies are effective. (R20 (Roy, Dep. at 60-61)).
320. Roy has never been involved in trg to secure FDA approval for some medication.
(R20 (Roy, Dep. at 79)).
Sallv B. LaMont. N.D.
321. Respondents offer Sally B. LaMont, N.D. ("LaMont") as "an exper in natuopathc
medical, herbal medicine, fuctional medicine. . . (and) as an exper on nutrtional
supplements and botancal medicines in the prevention and treatment of ilness and as an
expert in reviewing the evidence that supports the fuctional issues of the four products
that are the challenged products." (Deposition of
refered to as R22 (LaMont, Dep. at --) at 7-8).
Sally B. LaMont, N.D. (hereinafter
322. LaMont has never previously been asked to be an expert. (R22 (LaMont, Dep. at 54)).
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