The Highwire with Del Bigtree - THE CROSS EXAMINATION OF DR. TERESA HOLTROP

Episode Date: November 5, 2023

ICAN Lead Attorney, Aaron Siri, Esq., cross-examines Dr. Teresa Holtrop, at the time the President of the Michigan AAP (American Academy of Pediatrics) on her knowledge and understanding of childhood vaccines, the CDC’s recommended childhood vaccine schedule, and vaccine safety and policy in the U.S. This footage represents the complete available livestream of this cross examination, as originally streamed over two days by the ABC7 affiliate in Detroit, Michigan, in 2018.Become a supporter of this podcast: https://www.spreaker.com/podcast/the-highwire-with-del-bigtree--3620606/support.

So Dr. Holtra, let's start with your position as the President-Elect and now President of the American Academy of Pediatrics. The Michigan Chapter. Michigan, okay. All right. So what are your responsibilities in that role? As President of the Michigan Chapter, it is my role to interface with the rest of the board and with the public in terms of questions that arise around pediatric issues, both the public, both policy-wise, advocacy-wise, etc. All right, and did you have to fill out any paperwork upon accepting that nomination? We have to do a conflict of interest statement whenever we're part of the board.

So I actually did that long before when I was a board, regular representative to the board. All right, and I did it again. What are you required to disclose in that conflict of interest statement? We have to disclose that we are not getting any financial support from anybody that would be in conflict. what we are being asked to do. All right, and to the best of your recollection, what are the sources of financial support for you? My, currently, or at that time when I filled it out?

Currently. You just have to make sure your voice is nice and loud, okay? Okay. So, currently my only source of income is from the work that I do with the Wayne Children's Healthcare Access Program. I do not get any financial reimbursement from the MIAAAP for my role. I have gotten some honoraria in the past as my role of medical director of the Michigan Chapter, Michigan MIAAP's

developmental screening project. That was part of grant work that the MIAAP received, and as medical director I was entitled to get an honorarium. All right. And what is the main sorts of funding for the health care, way, and children's health care access program? It is primarily grant funded. All right, and what do you recall what the main grant sources are?

They've been a whole host of them, but currently they are United Way of Southeast Michigan. We get grant dollars from the McGregor Fund. We have dollars from, we've just finished up a grant with the Jewish Fund. We have, we just finished up grant dollars from the Michigan Association of United Way's. We have some grant dollars from Clearcore Detroit, who subcontracted with us on something they were getting money from the Jewish Fund, I believe, originally. We are currently receiving money from the Wayne State University Department of Family Medicine for a grant where we're subcontracted to provide community health workers, and that is an NIH-funded grant. that Wayne State receives. We have are in the process of getting a contract finalized. We're in the last few days of finalizing that with the City of Detroit Health Department. We have, I can go on. It's a long list, but you get the idea. I do. There are some reimbursements that, or not reimbursements, some contracts that we have on occasion with State of Michigan Medicaid health plans. And

We do have one currently with Aetna. All right. Next, I want to, are you still seeing children actively in practice? I am not. When did you still? In December of 2015. All right. Are you still aware of the ongoing medical issues in this state?

Absolutely. Are there any local outbreaks at the moment? Objection, Your Honor. She hasn't been qualified as an expert in infectious disease or epidemiology. She's only to be called for the adjuncts. Are there any... Just because somebody makes an objection doesn't mean that that's the end of it. What is your response to that, so then I can rule on the objection?

The outbreaks that I'm asking her about, and I didn't face the question as well as I should, are ones that are uniquely relevant to children and something that as a pediatrician she should be aware of. Okay. And it's your said. Overruled, it is not your say. Go, continue. All right. Dr. Holter?

Continue. Yes. As part of my work with the Michigan Advisory Committee on immunizations, I can continue, even though I'm not on the committee anymore, I still continue to receive their information. And as is, I think, well known in the news, there is a lot of information about outbreaks of both whooping cough, as well as hepatitis A currently. Influenza has claimed 83 lives across the United States. She's testifying about information from an ACIP publication and from newspapers. She just said she is.

You have to lay a proper foundation. I don't know where she is getting her information, so let me do. Dr. Holtrop, as part of the work that you do, you're no longer served on the committee. You still receive the reports, correct? I do. I should also mention that I am participating in a Southeast Michigan collaborative addressing immunizations and how to improve immunization rates,

and that is through the Southeast Michigan Health Authority Association. All right. So through your work with that, through your work with the South East Michigan Health Authority, are you aware of the number of hepatitis A cases in Oakland County? Again, objection, Your Honor. She hasn't been qualified as an expert in infectious disease and epidemiology. But we have established that she's an expert in pediatrics. This is something related to a committee that she's serving on.

I'm asking her if she knows the number. It's not asking her to draw an expert opinion. It's asking her what she knows. As part of your role, both in the Academy and also as a director of your clinic, is it part of your duties to apprise yourself of any outbreaks of any kind? It is. Okay. Tell me about that. And how have you, through the years done that, and why is it your responsibility to do so? Okay, so Wayne Children's Healthcare Access Program is a medical home project that works with numerous practices, across Wayne County to help improve the medical home.

One of the things that we look at is how can we help the medical practice improve immunization rates? And as part of that, it is my duty to be aware of what is going on in the community. And how do you and other medical professionals normally do that through? Typically through a number of public health notices that we receive. Okay, and those would be through... In this case, I received it from the Michigan Association of... Sorry, the Michigan Advisory Council on Immunizations from the Michigan Department of Health and Human Services. Okay. Go ahead.

I'm sorry. I'll review my objection because she's, she has been qualified again in this area and she's testifying as to information to receive from documents that are not here in this court today and which are not subject. Which, I think, qualify as a hearsay exception, but do you want a minute to look at that? I believe it does because it's a general governmental record that she's informed herself on. of that she has the ability I have the information and the record present to admit. Because they are put out by a government agency, I think they fall under one of the exceptions. I don't recall the exact letter, but because it does carry the general indicia of reliability, it's the same reason other government publications are admissible.

Why don't you cite, do you want a minute to look at the court rule? I do. Okay. Well, we'll take a five-minute break. So just so you know, and I said this a lot, don't object or respond without your court rules present. and you should have them on your table or electronically, but that's what I expect, and both of you know that already. So please follow my rules.

All right. May be seated. A email to her from. Md. H. H. These are four pages out of a bigger presentation, right? Collin Schmidt, Rouser Schmidt, 2015, 8-3-39-D-M.

Where do you smoke for next to get, standing, to next. You don't have to keep doing you. Okay, what's your response? I think 8038 allows for the admission of records of government activity in this case So because these are documents that were prepared by DHS and sent out to Dr. Vokrop Invergible as a member of this committee I think they have the addition of reliability and they fall under the specific exception There are first of all they're part of a larger They're part of a larger PowerPoint presentation apparently and they've only had a few of the pages of the whole presentation here.

So under Rule 1 of 6, they're not complete, which is the first issue. And the other thing is that there's been no testimony that this came. Well, at this juncture, you're not offering them as an exhibit. Are you? No. Okay. I don't know if you are going to or not, but with regard to what she's basing her expert opinion on, I think she can testify to it because it would come into evidence under 803.

eight so let's proceed. All right, so Dr. Volcro? Objection overwold. Dr. Volcro? Just catching up on where we left off. Are you aware of any outbreaks in Michigan right now? Alls, sir, I'm sorry. This was also not part of the exhibit list

that we were provided and so we've had no. What was the question? I asked her if she was aware of any outbreaks in Michigan right now. Right, I just ruled on this. I apologize. Okay, thank you. Sure.

All right. Okay, yes. There are outbreaks. Objection, because she's not an expert in infectious disease and epidemiology. Overrule. Continue, please. There are outbreaks currently in Michigan of hepatitis A. There are outbreaks of influenza. There are outbreaks of pertusses, whooping cough.

There are cases or have been reported within the last 12 months of tetanus, of Hib, hemophobic acid. Objection on a hearsay. Overwold. And if I'm not mistaken, of months. The exact numbers I did not bother to memorize. That is fine. So let's start with hepatitis A.

Is that geographically concentrated in any particular region? It is geographically concentrated in southeast Michigan. Your Honor, I'm asking the standing objection as to her expertise regarding infectious disease and epidemiology. You've made a record. Thank you, Your Honor. Overruled. All right. Have you seen hepatitis A?

practice. Let's back up for a second. You said in southeast Michigan, HEPA is at epidemic proportions and the health department is desperately trying to immunize as many people as possible. Hepatitis A is typically a condition that children are immunized against at one year of age and then within six to 12 months again afterwards with a second one. Have you seen any cases of hepatitis? I actually have, yes. What are the symptoms? Typically, young children when they get hepatitis A will have some nausea, vomiting, diarrhea. They can get jaundiced, meaning yellow, and those are the main ones, sometimes fever. All right, are you aware of what the mortality rate is for hepatitis A? For children, it's not very high. All right. Let's move on to

hepatitis A. Let's move on to tetanus. You mentioned that there were cases of tetanus at the moment. Correct. How common is tetanus? Tetanus is not very common primarily because we immunize against it. It is a disease that you get from spores that are in dirt. For example, if you step on a rusty nail and it penetrates the skin or if you get a dog bite, you typically need to be immunized against tetanus in order to prevent it. It is not a pretty disease. What are those symptoms of tetanus?

Spasming, seizures, and potentially death. And for a child of Faith's age, what would the mortality rate be? It would be fairly high. I am not an expert in infectious disease. I would have to look up the rate. So if you were to see a patient in practice who was not immunized against tetanus and had stepped on a rusty nail or a rose thorn, what would you do? I would immediately recommend that they get immunized against tetanus.

And that's actually what is done in the emergency department when a child comes in with that kind of a condition. What is the advantage to a child of receiving the Tetanus vaccine prior to stepping up to the acute incident? They are protected. Is the protection, does the protection differ if the vaccine is received prior to the incident versus after? I don't know. All right. And let's talk about whooping cough.

So are there any cases of that in Michigan? It is at epidemic proportions. All right. What are the symptoms of whoop and cough? Respiratory symptoms such as runny nose, bad coughing that can. get so bad that it has actually been known to cause ribs to break. All right. And with who can't pop, how long does it take for that to be diagnosed?

Because it looks like a common cold, it can sometimes, the diagnosis can sometimes be delayed. All right. And what is the treatment for that? It's an antibiotic. All right, and how long does it take? They're up after the antibiotic. It can take several weeks for the symptoms to go away. The biggest problem is that the delay and diagnosis will see.

will sometimes cause children to develop pneumonia and then to die. And there have been cases of it in southeast Michigan. Deaths related to whooping cough. Do you know how old the children were? In this case, the child was several months old, and the parents had chosen to delay immunizations with the consent of her pediatrician and is now advocating very strongly for immunizations. Yes, Your Honor.

Yes, Sister T. Can't say that. All right. And I move to strike, well, the hearsay testimony. Just look, let's proceed. I'm not going to consider it. All right. Dr. Holtrip, do you, in your role as the president or president-elect at this point?

President. As the president of the Michigan chapter of the American Academy of Pediatrics, are you aware of what the stance is of the American Academy of Pediatrics on vaccines? She actually are. She's the president. I think she can testify to that. She's not hearing the capacity, though, as representing the age. up representing the American Academy. Overruled, she can testify.

Thank you. Yes, the American Academy of Pediatrics is fully supportive of the immunization schedule as published by the American Advisory Committee on Immunization Practices. All right, and do you have any children? I do, I have two. Have you vaccinated your own children?

Absolutely. All right. In making that decision, what factors did you consider? The fact that we knew of it. We knew it was my husband and I were very much aware of the negative consequences if we did not immunize in terms of the risk to their health, having both of us seen children die from vaccine preventable diseases. So in that case, did you rely on the fact that the vaccines that the children were administered were on the approved schedule or based on your knowledge of the individual diseases? We follow the recommendations. If you were to have, if the judge were to rule that Faith should receive the age appropriate vaccines and she were to, and you were in practice and she were in your office, how would you go about catching a child out on vaccines?

In Faith's case, my understanding is that she is two and a half years old. I've gone through and looked at all the vaccines that she is behind on. It is a fact that she did not receive her immunizations according to the schedule. makes it feel very uncomfortable for us as pediatricians to have to catch her up the way we would have to, but I have done it. She is due for, at a minimum, six needlepoles, which we have done, and the best way to do that, and that is actually a recommendation from a variety of sources to immunize all at once rather than to put it off and give it spread out over a period of time. And the best way to do it is to have multiple people, staff that one immunizes here, one here, one here, one here,

and it just goes, one, two, three, go, get it done it over with. All right, and in administering these vaccines, do you care of which manufacturer rate the vaccines? No. It's not something that you look into. No, we typically, I worked in a practice that was primarily Medicaid children. I think 80 to 90% of our children were Medicaid enrolled. And for those children, we get our vaccines from the Vaccine for Children program, which is a federal program, and the manufacturer is determined by the CDC.

So it's not a choice that you make individually? No. If a child has commercial insurance, then there is a little bit of a choice that we can make. But it's, we typically don't. The business side of things, it's not us physicians making that decision. It's usually the business people within our organization that make the decision. All right. And we heard, and I believe you were here, a lot of testimony about conflicts of interest in medicine.

What steps do you take to prevent conflicts within your practice? Well, we have limited how many drug reps. whether we even interview with drug reps, and that was typically not done. I'm not sure what other conflicts of interest would arise in this situation. We do not get any money out of this. The vaccines are provided to us for free. We bill a vaccine administration fee if it is a Medicaid-enroll child. I don't know the situation here, so I really can't.

Other than drug reps, do you have any contact with the major drug manufacturing company? Occasionally there will be a, sometimes at certain conferences, sometimes the drug reps will have a separate pot of money that they will, are able to use for educational programming, but it is very, we're very careful with how we accept that money and we have gotten much more careful over the last five to ten years. And there is a, there's a policy statement out from the American Academy of PDA. I can't quote it, but it relates to that. All right. I do want to, while I have to understand, ask you some more questions about vaccine preventable diseases. Have you seen measles in children? No. All right.

Were you educated in what the symptoms are in the mortality grade? What are the symptoms? Rash, runny nose, they get some funny spots in their mouth, they get red eyes, you can, a fever, feeling of fatigue. feeling of fatigue and etc. What are in the more extreme cases? Are there any different? It can, yeah.

Measles can cause actually brain damage and it can cause death. And do you not, are you familiar with how common that is? It's not something we see very often. I have never seen a case of measles. And the main reason is because we have such high herd immunity. I'm told I myself suffered from it when I was a child. objection to your honor she's not qualified to upon on that but as to whether she had measles no as to whether or not the measles has gone down because of the vaccination that requires historical epidemiological evidence infectious disease expertise i think she can testify to that overrule

so all right and you said have you seen any other vaccine preventable illnesses and children absolutely i've seen mumps all right what are the symptoms of months swelling of the um prorotic glands right here And actually, the one case that will forever stick in my mind is a kid who came in during the a month's epidemic that was going on in the 1980s, who ended up with orchitis, which is an inflammation of his testes, and then developed early stages of encephalitis. All right. And what was the ultimate outcome for this child? He actually recovered.

Now, in terms of the orchitis, I don't know exactly. if that affected his ability to father children in the future. I don't know. You're pediatrician who don't expect your patients to father children. Well, and I did not follow him after I transferred him over. I was working at another hospital, transferred him to Children's Hospital to the intensive care unit. That's all I know about it. I have seen other cases.

Hib, Hamophilus influenza type B, as well as numerous strep pneumonia and those cases were quite striking. Number one, hemophilus influenza type B, I have seen both meningitis, as well as epiglottitis, which was an extremely frightening disease because it can cause swelling of a little flap in your throat that can cause you to suffocate within a very short period of time. When you say a very short period of time, how long do you meet? less than 24 hours. You come down with the symptoms and boom, you can be dead. Menangitis, having done spinal taps on infants that have had that and having pure pus come out from the spinal fluid instead of the normal clear watery fluid. I've seen that both in strep pneumonia as well as in hemophilis influenza type B. I'm still of an age that I experienced the time before we had vaccines for this. Most of our residents now, it's.

don't see cases of that anymore. One of the things I wanted to talk to you about is you've administered vaccines in your practice, correct? Absolutely. All right. What side effects have you seen from the vaccines? The most common side effects are redness and swelling at the side of the shot. Sometimes some low-grade fever, feelings of tiredness, sometimes they're cranky. Those are the main ones.

Are the concerning to you at all? No. All right. Why not? Because they'll get over it. Yep. And have you seen any more extreme cases? I have. Before we switched from the DTP vaccine to the DTAP vaccine, so the A stands for Acellular, P stans

for pertussis, which is whooping cough. And we used to use a whole cell whooping cough vaccine. That was the DTP. And that one had as a tendency to, would cause high fever sometimes and sometimes screaming for three hours on end or longer, and could cause seizures. And that was then a reason not to give that vaccine the next time around. But since we've switched over to the DTAP, which is the accellular whooping cough vaccine, I have never encountered another case of the high fever and the seizures, et cetera. I mean, it's still listed as possible, but quite frankly, I've immunized hundreds and hundreds of kids since then and have never had a case of that since then. Is there anything in a child's family medical history that would cause you to be concerned about vaccinated?

If you have a child who comes from a family where other siblings have had febrile seizures, you sometimes take it with a great, you want to be more concerned about. Can the fever that can be caused by the vaccines, can it cause febrile seizures? but febrile seizures are benign seizures. We, as a matter of fact, they're scary to see, but we try to educate parents as much as possible that if it happens, don't worry about it. This does not mean that your child will have epilepsy, your child will not have damage from it, et cetera, et cetera.

So that's the other thing that we have to be concerned about is if we are immunizing a child who comes from a family where there is somebody who's immune-suppressed, in the home because especially with the live vaccines, well, only with the live vaccines, which include measles, mumps, rebella, and the chickenpox vaccine. There can be some shedding of the virus, the rhodovirus actually too, but faith is not a candidate for the rhodovirus vaccine anymore because of her age. But there can be shedding of that virus, and then it can theoretically cause the disease

in an immune-suppressed child, which is actually also the argument for immune-suppressed child, which is actually also the argument for immunizing as many children as possible so that you have some herd immunity. So even if there was an immune suppressed child in the home, would you still advise vaccinating the healthy child? Typically we do, yes. Do you follow a procedure to ensure that the immune suppressed child is PEPSA? It is, you educate the family on, if possible, keeping them separate. And it's not a high risk, so it's to the immune suppressed child. The risk to the immune suppressed child is actually if the child, him or herself,

receives that live virus vaccine. So, from to change topics a little bit, are you familiar with the vaccine information sheets? I am. Did you provide those when you administered vaccines? We are required by law to provide them. All right, and what information is contained within those sheets? It- In faction hearsay.

We've already litigated. We've already litigated this, and I've allowed the vaccine sheets to be admitted. and different with different witnesses. Am I right? We've already talked about this. That's the downside of not being present for the entire period. Sorry, honor. Thank you. Okay. Appreciate it. Thank you.

What information? We have enough to argue about. We don't need to be here. What information is contained in those sheets? The VIS sheets typically will contain information about sort of a quick overview of what the disease is that is being prevented by the vaccine, what the side effects are, what to do, what the contraindications are and what to do if there is any concern about the vaccine having caused problems, who to contact, et cetera. In Michigan, we are required to hand out a vaccine information sheet that has a modification on it down at the bottom in informing about the Michigan Care Improvement Registry. And so that's the one.

What is the Michigan Care Improvement Registry? The Michigan Care Improvement Registry is a statewide registry where all immunizations are, are supposed to be registered in, in pediatrics. We use it. Oh, is that Micker? Yes, it's Micker, right. Okay. Yeah. When it first came into being, it was, which was in 1993, approximately.

It was called the Michigan Child Immunization Registry, and once you got to be 21, you would get kicked out of it. But then people started recognizing the value of having the Micker system in place and it was changed to include adults too and so now it's called mission care improvement registry I can tell you from personal experience that having that registry available has really saved a lot of children unnecessary immunizations but particularly for foster care children who would come in and we would not have a copy of their immunization records etc. So that's the only difference between the Michigan forum then and the one? Yeah, it's a little footnote at the bottom.

And why would a physician not provide vaccine information sheets? I would expect if they're not very familiar with immunizations or with the rules and regulations around it that they might not hand, especially in pediatrics. The pediatricians typically are aware of it. And what other information do you provide your patients with about the immunization that children are receiving? Well, we have a vaccine questionnaire that we typically ask that is supposed to try and pick up contraindications to immunizations.

That's not a piece of information, but it is, it gives us information. And then if the parent has any additional questions, they go above and beyond what's on the VIS sheets, we certainly go over that. So based on your years of practice as a pediatrician, do you believe that the minor child should be, in this case, should be vaccinated? I do. She's an expert. I'm asking her to form her expert. We don't argue with each other. There was no formal objection. I didn't hear one, so just continue.

That's all I have for you inactive both of your time. All right, cross-examination. Your Honor, I have a few minutes. Do you know, great? Would it be okay? If not, that's okay? No, I really want to. Okay. Thank you, Your Honor. I don't mean to make it convenient. I just want to get through this. Good morning, Dr. Holbro. Good morning. Thank for being there.

What do you understand the CDC to stand for? The Center for Disease Control. And do you consider it's publications and website a reliable authority for information regarding vaccines? I do. And what do you understand the FDA to stand for? The Food and Drug Administration. Do you consider the FDA's publications and website a reliable authority for information regarding vaccines? Yes.

What do you understand HHS or DHS to stand for? Department of Health and Human Services. Do you consider the HHS's publications and issues? agencies to be reliable authorities with regard to vaccination? Typically, yes. But they don't typically, I'm sorry, the DHS does not, I mean, they do it through the CDC. And they threw, because CDC is an agency under. DHS, yes.

Are there any other agencies under DHS that are involved in vaccination that you're aware of? Well, there's the American, the advisory committee on the administration. practices, which is an advisory committee to the CDC. Okay. Are there any other agencies that you're aware of under DHS that are involved in vaccination? Not off the top of my head. Do you aware of which agency within DHS is responsible for licensing vaccines? I believe it is the Food and Drug Administration. Are you aware of which agency is responsible for administering the vaccine injury compensation program?

It's VAIRS. Vaccine, that's all I know is a VAERS. The name of the agency, do you know the name of that agency? I don't know off the top of my head, no. What do you understand an IOM to stand for? The IOM, Institute of Medicine. Which recently changed its name, right? I have no idea. Okay.

Are you familiar with the Institute of Medicine? I am. Okay, do you consider the IOM's publications of the liable? authority regarding vaccination? There can sometimes be some difference of opinion between one authority and another. Right, right. It is not an institute that we go to for vaccine information. So the Institute of Medicine, you're not aware of their prior publication regarding vaccination? When I look for vaccine information in terms of safety and recommendations as to how to handle immunizations and children, I go to the CDC.

And you said that experts can disagree. Surely they can. Experts who are reliable authorities on both sides of an issue can certainly disagree at times, correct? Yes. Yes. But that doesn't make either one not reliable authority on an issue, right? I'm going to object. She's already answered about the IOM. He's trying to get her to say that it's a reliable authority to impeach her with their 97. Wait. She's coaching the witness. It's completely inappropriate, Your Honor. He's just answered the question. Completely inappropriate to coach the witness in our objection.

All right, stop. Your objection is what? That he's, she's asked the answer. She's answered the question as to how she feels about the Institute of Medicine and whether or not. I don't think she did answer that. I'm going to... Overwold. So, ask the question, please.

I respectfully request that speaking objections that coach the witness are not committed. I will rule on the objection as they appear. Okay. Thank you, Your Honor. So, we were actually. we were talking about whether or not reasonable experts. Experts who are in the field can disagree about things, right? Is that a yes or no?

Yes, I'm sorry. Yes. And the Institute of Medicine is comprised of leaders in their respective fields in medicine, right? Including Nobel Prize winners? I have not studied the Institute of Medicine. It is not a source that I go to for information around immunizations. Would you consider it a reliable authority, though? I would say I don't know.

Do you consider yourself a reliable authority, Dr. Holbrook? On immunizations? Yes. No, I go and ask, I look for information from others as to what to do, and that is what we are taught to do in pediatrics. Okay. And so who do you look to for information regarding the Center for Disease Control and the ASIP? The advisory community immunization practices?

Yes. And those are the only authorities that you rely on. For this information, yes. And you wouldn't consider any other governmental or non-governmental organization that studies this topic to be a reliable authority? I guess the answer is no. You know or you don't know? The answer is no. I'm not sure where you're going with this if I had a better sense of what you're trying to...

I'm just asking you to answer as truthfully as a chance. So just yes, no or you don't know? No. No. anywhere else. Would your answer change based on whether where you knew I was going with this? Would that change the truth? So here's my thought process. If the Michigan Department of Health and Human Services came along and said such-and-such is happening around this and this vaccine, I would certainly pay attention to

what they are saying and probably follow their guidelines on the assumption that they are following recommendations from the CDC and the Advisory Committee on immunization practices. I admit I may an assumption here that MDHHS is trustworthy in that. Right, because and they're relying on what CDC and ASIP are deciding. Correct. Okay. What is the National Childhood Vaccine Injury Act of 1986?

It is the act that established an entity to which reports could be made about vaccine-related adverse events. And it's also the act that granted vaccine manufacturers. immunity from liability for injuries caused by vaccines correct correct correct when you served with the subpoena to appear in a deposition in this case in February 6th 2018 I'm going to object the court's already ruled on the on the permissibility of the deposition whether or not she's been served for the subpoena is completely inappropriate right how was it about that I just want to establish that she wasn't disposed are you deposed can I just ask to choose

deposed in the case sure that's all right were you deposed in this case no Okay. Thank you. Did you discuss your anticipated testimony today with anybody? With Laura, I can never pronounce your name, with the attorney, Newsma. Anybody else? No. How did you first learn about this lawsuit? So the American Academy of Pediatrics is broken up into districts, and we are part of District 5. It was the chair of District 5 who sent an email to several of us at the MIAAAP talking about the fact that there is a case and could somebody help out. As it turned out, it happened to be in the area that I live in. And since I do have some experience in the area of immunizations, I volunteered.

Don't say where you live. Okay. And who sent that email from AAP? Dr. Rick Tuck. Okay. And what did, what is your understanding of he was specifically asking for? Somebody to be, assistance for somebody to be able to testify on behalf of the importance of immunizations in childhood. Okay, so after you got that email, what's the next step that you took in order?

Can you just speak up a little bit? Sure. Thank you. Well, after you received that email, what's the next step you took that led you to be here today on the stand? I actually contacted some colleagues of mine to see if there was anybody within the infectious disease world of those that I knew who might be interested in testifying. And who did you contact? I contacted Dr. Eric McRath, Dr. Basim Asmar, I think those were the two primary ones.

Anybody else you can remember? Not that I remember right now. And do you understand why they didn't want to testify or did? We never discussed it. They just said no. Understood. So after that, what's the next step that you took in order to become an expert in this case? Did you reach out to somebody to say, hey, I'm willing to be an expert?

What is it that you did next? I did. Okay. To who was that? the lawyer for Mike Schmidt. Directly? I'm trying to remember exactly the process and I don't recall whether it was directly to the lawyer or whether it was to Mike Schmidt himself. And how did you get that information?

It was passed on to me through Dr. Rick Tuck. Oh, from the American Academy of Pediatrics? Mm-hmm. Okay. Is that yes? Yes. I'm sorry. Do you review any documents prepared to testify today?

I reviewed the documents about the CDC recommendations, the ASIP schedule of immunizations, the VIS sheets, and the Michigan Department of Health and Human Services information that had been sent to me in February from the folks at MDHS, which I received without having requested it. And those are the only documents you reviewed hard to take, correct? Mm-hmm. You've never seen any of Fade's medical records, correct? No, I have never seen any of her medical records.

And you don't know anything about her medical history, correct? I do not know anything about her medical history. Now, earlier I believe you were being asked about what you would do to that, to nate a two-and-a-half-year-old child who received no vaccines, correct? Mm-hmm. Can we go through what vaccines you would recommend? Remember to keep your voice up. Thank you.

It might be better if you work from the podium because the mic is closer, but it's up to you. Let's, if you could kindly, Dr. Haltrow, list of vaccines that you believe a two and a half-year-old child should receive. If a two-and-a-half-year-old child has not received any previous immunization, she would be doomed. for the DTAP, polio, hepatitis B, measles, mumps, rebella, chickenpox vaccine, pneumococcal vaccine, hemophilus influenza type B vaccine, hepatitis A, did I say hepatitis B already? Yeah. I have to write it down in order to not miss anything. You know what? I think we can help with that.

Why don't we? I think we can put it demonstrative out so we can lay out. all of the vaccines so we can keep track one as we go forward we don't really if you want to do that you can set that up at some other time but I just want you to proceed now I don't want to break for that I won't break for that at all around I'll just keep going so okay so hepatitis A yes any others hepatitis A hepatitis B chickenpox vaccine which is the VZV mm-MR on DTHA AP, polio, hib, pneumococcal vaccine. I think I have them all.

Well, we're going over the same ones, I think you did. Okay, great. And then can you tell me the number of doses for D-TOP? Well, at two and a half years of age, if she's never gotten another, a previous Why would you, why do you want to put it right here? No, no, not there. Right there. Yeah. That's perfect.

I'm sorry, how many? Detach. In order to be fully immunized, she will need a total of three doses at this age. And how many doses of polio? She will need a total of at least. It depends a little bit. There's a delayed immunization schedule, and it would be a wise idea to look at that, to be sure. Normally she would have gotten three doses by now with a fourth dose after the fourth

birthday. If there is, by the time they get to their fourth birthday, if they haven't gotten the first three, then sometimes they get by with two before. It gets really... Two or three. She should have gotten three at that baby. And heftee? Hep B, she needs to have had three. MMR? She will have gotten one, and she will get her second one after the fourth birthday. Although it can be given earlier.

Chicken pox? Chicken pox the same thing. Menzoccal, which would be PCB13? Do that be the same? No, it's not the same thing. PCV-13 is the new macacal vaccine. And again, that one I double check because there is a difference, depending on what age you get it. The Hib vaccine, I always think of it as the same as the Hib vaccine.

The Hib vaccine, if she has not gotten a previous dose of it and she is now over 15 months of age, she only needs one. If I'm not mistaken, the same is true for the Numacocco vaccine. I always double-checked myself on that because it has gotten so complicated. So one for NUMACO. I believe so, and one for Hib. And you believe she won for Hib? Yes. I know one for Hid. She should have two, six months apart. Epititis B? She should have three.

They're given the first one, the next one is a month later, and the next one is six months after the first one. And PCV-13? PCV-13 is like the Hib. That's the pneumococcal vaccine. It's a one. I believe it's just one shot that she needs. That's the one I would need to double check on.

Can you tell me the, and you would admit it? administered all of these hundreds of times correct correct and and they all come in packaging I assume correct and there's a product insert inside the packaging correct and the name of the product is on the box correct and the manufacturer's on the box and the lot number and you record that information absolutely right Okay. Can you tell me the, can you please take a look at this cut out of a child? And can you tell me if this looks approximately the size of the two and a half year old child? It does.

So for the hepatitis B vaccine, you indicated that there's three doses. Can you tell me the brand names and the manufacturer? I can't tell you the manufacturer. And it depends on which... Again, this is not something that I look at all that closely because I use whatever we are provided with by the vaccine for the VFC program, primarily. Vaccines are products, right?

The vaccine product, yeah. I mean, there's... I'm sorry. We receive the package of vaccines from the CDVs, distribution site and that's what I will use. I don't bother to try and memorize the vaccine manufacturer. Okay so you don't know the manufacturers for any of the vaccines? She doesn't have it memorized. I don't have it memorized. I'm not sure what the

need for that is. Okay so you've asked for that. So let's remember about. And do you know the product names for any of them? Some of them, yeah. Okay, which ones do you know? Pedia Ricks is a combination of vaccine. For hepatitis B, I want to say there's injurics. But again, this is not something that I spend a lot of time trying to memorize because it's pointless. Doesn't matter who manufactures it doesn't. What do we do? The original exhibits, John, are those?

I'm sorry, are those still there? I don't know where your exhibits are. May I approach with the genre or handler what has been previously entered as exhibit UUU? Yes. Thank you, Your Honor. The exhibits were left here on the clerk's chair from the last time in the case that you wanted them to be left here. My copies. No, the witness's copies.

I don't know. That's true not. I don't know. Okay. You may approach you. This is a subject. Have you seen this document before Dr. Haltrow? I have seen similar documents.

Not this particular one, but... Do you see that it provides that it's from the Centers for Disease Control? I see that, yes. And you see that it lists each vaccine, including by manufacturer and product names? Yes, I see that. For the hepatitis B vaccine, which I believe you indicated, you indicated that a child of two and a half to receive three doses. Do you see who the manufacturers are? It says GlaxoSmithKline and Merck.

There are two different manufacturers. Okay, and who, and what is the product name for the Merck product? It's recombavax, HB. And for the G.S.K. Andrix B. So where would you, where would you approximately, where would you give these three doses to the child? First of all. Relevance of where she would administer the dosage.

Her expertise in where vaccines are administered is not a question for the court today. Your Honor, she testified as the vaccine's safety, this is all leading up to safety, Your Honor. She testified about adverse reactions. She testified that the child, she said herself six injections. I don't allow it. Go ahead. Over will. She would not get six or three doses of hepatitis B on the same day.

Right. You would space them out over a period of time. Correct. Absolutely. And over time, though, but you would recommend faith receive three injections. three doses of hepatitis B, correct? Yes. Okay.

And would it be, okay, and these, so hepatitis B, this, I want to keep track of all of that, so we're going to talk about. This way, you know, this way you said before you can't keep track, we'll just, we'll put them all up, and this way as we go through this, we can point to this, and we can make sure we cover each one, because each of these are a separate product, correct? Correct. Each of them have different ingredients, correct? Correct.

Each of them have different contradictions, correct? Overall, yes. Okay, each of them have a different, have different effects on the body, correct? I would say probably not that much different. Okay, well, we'll go through that, great. So we'll put up the three hepatitis Bs, and then I believe you said for D-TAP, you said, where? It doesn't matter.

arms, legs. That's where they would normally administer it, right? Arms and legs, Dr. Haltrop? Certainly not down there. Well, why don't we... Why don't we... It is administered in the deltoid. Up here. There you go. Okay. And three doses of D-TAP, right? Excuse me. If you're asking me what I would give on a given day, I don't think it is correct to put up three different doses of hepatitis B. I have not. I mean, I know it's for effect, but it's not going to help me. It's only going to mean to conclude.

She doesn't support giving a child re-vaccinations of the same. Not asking about that at all. I'm asking just, I want to understand the total number of doses that she's saying a two and a half-year-old child is received so we can represent it. You have established that already, and you're asking to do the demonstrative. So we can keep track as we go along. Well, I think what you're. trying to do is put a bunch of stickers up there to show me how many total you don't need to do that and so what she's saying is she wouldn't do it all at once

put one up there how bad then if you want to do three different times of how many she'll receive each time that would that's that's fine I don't think you need that but if that's important to you then you go ahead and do it let's just do it like that your honor so we know that we can keep track that it's three doses over time you put one up there at once because that's what she's testifying That's what she's comfortable with and you're using her testimony to do your display. She said that the child received three hepatitis V doses are on her. Not at once.

I'm not, well, we obviously can't put them all in the same spot. You're right. So, and it's not supposed to represent it one time. I'm making explicitly clear this is not about one time. This is just so we can keep track of all doses that she believes a two and a half year old should receive. It could be over, you know, it's probably going to do. take what I'm not going to argue with you anymore about this yes wrong thank you thank you I have a suggestion oh wonderful because it'll be impressive enough

the fact that this child has not gotten any immunizations previously yes means this poor child will have to be tortured with six different injections at the same time and if you would like to put those six up at the one visit and her first visit to get all these immunizations I'm happy to do that dr. Holtra up at two months of age how many injections is a child received typically if we use a combination vaccine, it is typically the DTAP polio hepatitis B, then it is the pneumococcal, and it usually can get by with three, and then the oral rotavirus. And why can't you use the combination vaccine in this situation, Dr. Hall of Rosalie?

You can. You can. I'm saying with the comments. Stop, stop. When I talk, everyone has to stop talking. Council, you can't lean down, crouch down with your voice directed towards a box and expect it to be on. Thank you, Your Honor. And why can't you use a combination vaccine in this instance?

You can use a combination vaccine. I am telling you that if you use a combination, the combination vaccines that are available, she will still need six immunizations all at once. Okay. And what would those six be all at once? It would be a combination of the DTAP, polio, hepatitis B, if you wanted to use. use that one. There's another combination one that you could also use. It would be the measles, Moms, Rubella, and Chickenpox vaccine. That is a combination one. MMRV, right? MMRV. And that is it in terms

of combination vaccines that are available. And then what would the other four Vs that you need to She will need the Nubococcal. She will need the Hib. Unless she uses a different, a, a, So backtrack a little bit. There is a combination Pediarix, which is DTAP, polio, and hepatitis B. There's also a pentacel, which is DTA, P, polio, and hip. In which case you would have to give the hepatitis B separately. There is a combination hepatitis A and B called twin ricks. So if you had that available, the problem is you can't use that until age 18, so we haven't used that.

So your hepatitis A is separate, your pneumocococcal is separate, your Hib is potentially separate, if not the Hib, then the hepatitis V is separate. So that's five shots, right? What am I leaving out? Oh, the flu vaccine. If it's been to time. Okay. So a child who goes in for their 6-1 shop, which of these would they not need to receive? It depends completely on which one of these combination vaccines he or she received in the first...

Wait, there might be a better way to say it. Yes, I'll rephrase. Okay. I'll refrain. I'm sorry. A child had their six-month shop. They would receive D-TAP, correct? Correct.

They would receive polio. Correct. Hep B. Correct. Um, um, uh, yes. Hib. It depends. It depends on the product that was used in the first two.

sessions. Same issue with catching up a two and a half row, right? Same choice. Same choice. Yeah, in this case, yes. Well, no, no. Remember, if she's over 15 months, then she only needs one dose of Hibb, and she needs one dose of pneumococcal vaccine. So it'll be less. And hepatitis A at six months? At six months after the first, if she, well, wait a minute, at six months old, you don't get the hepatitis A. You get it at 12. months. Okay, so six vaccines at two and a half is torture. And at, excuse me, at two and a half years of age, you're saying getting six vaccines of torture, but a six months old would have to receive, we just counted one, two, three, four, five vaccines, correct? That's not true.

Sir, you have me so confused at this point. Hold on. Are we talking about pox or vaccines? Some of them are combinations. I think we're talking about injections, a number of actual injections. Right. So she's saying, you're saying, you're going to be. Your testimony was you think it's torture to do that to two and a half year old to have six different injections at once. It is a balance between whether you do it and cause the pain versus you don't do it and then put this child at risk. And typically we will go ahead and do it and I have done it. Okay. And how many pokes would there be at six months of age in a routine checkup during flu season?

In a routine six-month-old? Okay. Depending on what product they got at the two-month and at the four-month visit, it isn't relevant for this child. I'm asking how many posts, Dr. Haltrop. It depends on whether she got the combination that had the Hib in it that isn't required at six months, or if she got the one that is required at six months. There are two different Hib products. and one of them is given, the PED VACs is given at two months, four months, and then at 12 months,

whereas the other two products are given at two months, four months, six months, and then at 12 to 15 months. So how many posts Dr. Haltrow up at six months? Either two or three. And what would the three be? She just testified to them. I'm not clear what the three would be. I know, and it's because you're, talking to your co-counsel and getting other things out of boxes. So if she states it one more time,

please write it down and listen to it so we don't have to do this over and over again. Absolutely, Your Honor. On the assumption that at two months and at four months, she received the Pediarix vaccine, which is the DTAP, hepatitis B, and polio, she would then, at the two-month visit, also have received the pneumocococcal vaccine, as well as the Hibib vaccine and the oral rotavirus vaccine. We can skip the oral one because that's not necessary. At four months, she would have gotten DTA-8, she would have gotten the pediorex again, even though the hepatitis B is not needed.

Since she started with the pedic, we would have given the pedic at the four-month visit. So she would get the same thing all over again. And then if she, if the, the Hib vaccine that she received at two months and at four months was the P-VACs, at the six-month visit, she would get the Pediarix, D-TAP, hepatitis B, and polio. She would get the pneumococcal vaccine, and that would be it. Flu vaccine, if it was in season, right? If it was in season, correct. And that's the earliest that she can get the flu vaccine at six months. Who manufactures the D-TAP vaccine?

Well, if you're looking at the combination vaccine, one of them is made by Glaxo-Smith-Kline, another one of them is made by Sanofi. And who manufactures the vaccine? Hold on a minute. Okay, yeah, and there are two versions of the D-TAP that's not a combination vaccine, one made by Sinoff and the other one by Glaxo-Smith-Kline. Hib is made by Sinoffi, Glaxo-Smith-Kline, and then Merkis-Mercl. makes the one that's the where you only need the two doses in the first six months. And who makes PCD 13? PCV 13 is made by Pfizer.

And the inactivated polio vaccine? Who manufactures that? Sanofi. And who manufactures a flu vaccine that would be appropriate for a two-year-old to receive? Okay. So the one that is appropriate. There's one put out by GlaxoSmithKline. There's one put out by Cinoffi.

And the MMR vaccine, who manufactures that? Merck. Who manufactures the Veracella vaccines? Merck. Who manufactures the hepatase vaccines? There's one put out by Glaxo-Smithcline, and another one put. out by Merck.

Is it okay if we refer to Glass and Smith-Con as GSC today? Correct. Correct. So every vaccine that the CDC recommends that you're saying a 2.5-year-old should be administered was produced by either Merck, Cinoffi, GSK, or Pfizer, correct? Correct. And the number of vaccines recommended for children of age two has more than doubled since the 1980s, correct? Correct.

Are you aware that Merck's total revenue for the children of age two has more than doubled since the 1980s, correct? Correct. vaccine sales in 2016 was over $5.7 billion? No. Are you aware that Sanofi's total revenue for vaccine sales in 2016 was over $4.5 billion? No. Are you aware that GSK's total revenue from vaccine sale in 2016 was over $6.4 billion? No.

Are you aware that Pfizer's total revenue from vaccine sales in 2016 was over $6 billion? No. Are you familiar with Dr. Stanley Plotkin? I've heard the name, yes. How are you familiar with him? He's mentioned in vaccine literature. What literature is that? If I'm not mistaken, he is a member of the American Academy of Pediatrics and has done stuff.

I know the name. Do you know anything about him? No. Are you aware that he was deposed as an expert for defendant in this action? No. Are you familiar with him? a textbook used in medical schools regarding vaccines? There is no one textbook used in medical school for vaccines.

Okay. What are the various textbooks used? Currently in medical school, what is used is basically resources that are published online by reputable sources. It's not a single textbook. So you told me there are multiple textbooks. Is there a textbook regarding vaccinology that you're aware of? What I'm saying is there is not one textbook that we ever used in medical school. when I was in medical school and now even more so folks aren't using textbooks and many of us have actually gotten rid of textbooks because it is primarily stuff that is available online. Isn't it true that the American Academy of Pediatrics

receives and relies upon millions of dollars of donations from pharmaceutical companies including Pfizer Merck, Glaxo, the GSK and Cinoffi? What I can tell you is that the American Academy of Pediatrics very carefully reverect views whether the donations that they receive from any source as to potential conflicts of interest. Do you want to strike the answer with non-responsive? I'm not going to strike the answer. Okay. I'll ask it again. Isn't it true that the AAP receives, the American Academy Batchez, and relies upon millions of dollars of donations from pharmaceutical companies, including the four

major vaccine manufacturers that we just went through? I have no idea. Would you consider information on the American Academy Pediatrics website to be a reliable authority? I do. And would you consider the annual American Academy Petriacist's giving report to be an reliable authority? Are you referring to their Form 990? You said that their publications are reliable authority.

So, Your Honor, Madam. approach. Well, she asked you a question to try to clear up what your question was. Sure. I... Dr. Holtrop, what was that? Are you referring to their form 990? No, I'm not. I'm referring to a document called Stepping Forward 2016 Annual Giving Report, American Academy of Pediatrics. I haven't looked at it. Okay. Well, you would consider, if it was published by the American Academy of Deiatrics, you would consider a reliable authority. I would.

May I approach your honor? May. Thank you. Please turn to the second's last page. Seconds, oh. Yes, yes, I see. Yes, go ahead. Let me know when you're at the second last page.

Okay. Thank you. In the first column, which lists the largest corporate and foundation giving, foundation donors, correct? Correct. Do you see any that seeming any companies listed there that or foundations that either manufacture vaccines or promote vaccination. Merck is listed, Pfizer is listed.

Are you aware that Nestle? Sinoffi is listed. Are you aware that AstraZeneca's involvement of vaccine development? Yes. And Johnson & Johnson is attempting to. I'm not aware of that. I don't know. And foundations like the Bill and Linda Gates Foundation, they're also involved in promoting

vaccines correct correct and the Conrad 8 and Hilton Foundation I'm not familiar with the foundation but that's possible and Nestle nutrition is also involved in promoting vaccines correct vaccination I think of them more as a nutritional company mostly thank yes okay do you do you see any companies in that column called the vaccine choice coalition in I do not see it no how about how about Do you see the physicians for informed consent listed? No. How about the Vaccine Injury Bar Association? Are they listed?

No. Isn't it true that a significant portion of the American Medical Association's revenue also comes from pharmaceutical company? I have no idea. The American Medical Academy publishes numerous journals, correct? Correct. Okay. Over a dozen journals, does that sound about right to you? I don't know. Are you aware that pharmaceutical companies are the primary advertisers in those journals?

I haven't looked at it. I could see that it might be true. Isn't it true that journal revenue from pharmaceutical companies is nearly double the amount the American Academy of PDF American Medical Association collects and membership dues? I don't know. Can you name you a single group involved with promoting vaccines that does not receive any funding from any pharmaceutical company? A single group that is involved in promoting vaccine that is not,

well, Southeast Michigan Health Association, they're involved in trying to promote immunizations in Southeast Michigan and do not receive any donations from a pharmaceutical company. What's the name of the association? Semha, Southeast Michigan Health Association. They happen to be our foundation. fiduciary for the Wayne Children's Health Care Access Program. Can you name any other group that you're aware of it does not receive any funding from pharmaceutical companies?

I don't know this for a fact, but I would think that the Michigan Department of Health and Human Services does not receive donations from pharmaceutical companies. Do these organizations receive money from the Center for Disease Control? They do. Are you aware that the Centers for Disease Controls receives money directly and indirectly from pharmaceutical companies? I am not involved in that, no. I'm sorry. I'm not involved in that.

I wouldn't know. So they may receive money from... I don't know. I don't know. She doesn't know. Right, I just want to make sure that that's... I think it's clear. She does not know.

Illulnesses, behaviors, or behaviors make her more likely develop ICPRRA from vaccination. As I have said, I have no specific knowledge of faith. Isn't it true that the rate of autoimmune disease, chronic illness, and developmental delay in children has gone from 12.8% of children in 1986 to 54% of children in 2011? I'm going to object. He gets some latitude to lead a witness on an adverse witness, but at this point he's testifying, not asking her a question. That's over-woke. Are you aware that?

I'm aware that the numbers that are reported nowadays are higher than they used to be. Is it true that the rate of chronic illness, excuse, is it true that the rate of developmental delay among children today is approximately 15 to 18% of children? It is true that we are now more aware of developmental delays than we were in the past because we were looking for them. The Michigan Department of Health and Human Services puts out an annual report of the number of the numbers, so that we're looking for them. of the number of so-called vaccine preventable diseases, correct? Correct. Okay, the last years in which they have issued these reports is in 2016 and 2015, correct? I have reports from them from 2017.

You do? Yes. Do you have them here today with you? That is what we were talking about yesterday. They're not yet available on the website, though, right? I believe not. Okay. Isn't it true that there have been no cases of polio in the last three years in Michigan?

I believe that's true. Okay. Isn't it true that there been no cases of diphtheria in the last three years? I believe that is true. Okay, and there have been no cases of Rubella? I am not sure that I believe there have been cases. Do you have more? Okay, well, the only thing available on the Michigan Public Health website is the 2016-2015, so let me ask you about those.

Have there been any cases of Rubella in 2016 and 2015 in Michigan? I'm sorry, I would not know those specific. for those years. May I approach your honor? Yes. These are the summary reports issued by the Michigan Department of Health Union Services correct regarding the rate of vaccine preventable disease in Michigan. That is the title on these sheets, yes.

Thank you. Do you have any reason to doubt? These are not from the Michigan Department of Health Human Services. I do not. Can you go to the last page of the 2016 report, which is the second page? Do you see in the first row it did list the number of cases of congenital rebella? Yes. What number does it provide for 2016?

For 2016, it says zero. And for 2015? It says zero. Isn't it true that there were zero cases of Hibb reported in 2015 and 2016? Actually, that's not, no, that's, oh, I see what it says. It has 17 cases of homophilous influenza, but zero of the serotype B. Right. And the vaccine only protects against the serotype B, correct?

Okay, so there were zero cases of Hib, right, which is Hymophilenza B, in 2016 and 2015, correct? That is correct. That is not true for 2017, though, but it's not on here. That's not, you know, that's apparently available to you, but not to the public yet. And how many cases were there? Of what? Of Hib in 2017. Zero.

Okay, isn't it true that those reports showed only one case of tetanus and an adult male? for 2015 and 2016? It reports one case. Right. And if you look right up the page under Tetnis, it says the patient was an adult male. Yes. Isn't it true that the report showed only two cases of measles

in 2015 and 2016? That is correct. Okay. And both were in adults. It's in the summary description. I accept what you say. Isn't it true that those are reports showed eight or less cases per year of men jacoccal.

It says there are a total of 14 cases of meningo-cockled disease between 2016 and 2015. Right, six cases in 2016, right? Correct. And eight in 2015? Correct. Okay. Isn't it true that those reports showed a few dozen cases of months in 2015 and in 2016? It shows 38 cases of suspected months in 2016 and 18 cases of months in 2015. Right, they're not all average. or confirm. Include suspect. Correct. Isn't it true that the Moms vaccine is known to have efficacy issues and that the, and that they're working on creating a better version that's enough doesn't have the same efficacy issues? I know that they have just made a recommendation to give a

third dose of the MMR in certain situations. Is that a yes to my question? The answer is that there, I know that there are issues with the efficacy of the MMR for which reason they have made a change in the recommendation as to the dosing, how many doses you should get. Okay. Isn't it true that those, the report that you're looking at showed a few hundred cases of pertusses each year because the FDA, but the FDA has concluded the vaccine has efficacy issues, right? Actually, I would disagree with that conclusion that you are suggesting. The rise in pertusses cases is attributed in general to a drop in immunization rate. Dr. Plotkin said that it was primarily attributable to efficacy issues and that he was personally working

on creating a better for Tustis vaccine, would you disagree with that? I cannot comment on Dr. Plotkin's testimony. But would you disagree if he testified to that? I cannot comment on his testimony. Would you disagree yes or no? You, she's answered. Okay. Has there ever been a study which looked at the total health outcomes

of children following the CDC's vaccination schedule and those that are completely unvaccinated such as data. Has there ever been a study that has looked at the outcome of those immunized versus those not immunized? I do know that there has been a large study done in another country looking at those who have been immunized against MMR versus those who have not been immunized against MMR? Were those who are not immunized against MMR? Were they otherwise not vaccinated? Meaning did they not receive any other vaccines? That was not part of the study.

That's right. So as far as you know, there's never been a study that's actually looked at total health outcomes between fully vaccinated children and children such as FACE that are completely unvaccinated, correct? Correct. If the court orders fate to be vaccinated and she has a seizure, develops an autoimmune disease, or has some other adverse reaction, do you think the pediatrician should have the discretion to stop the vaccinating thing? If she has... Can you repeat the question? Absolutely. If the court orders faith to be vaccinated and she has a seizure,

it develops an autoimmune issue, or has some other adverse reaction, do you think the pediatrician should have the discretion to stop vaccinating pain? The question is a little bit too broad because it may depend on which of the vaccines administered can be attributed to having caused the problem. and if it is a seizure, the question becomes as to whether it was a febrile seizure, which is considered to be benign, and is not a contraindication to giving further immunizations. It's complicated, right? It's very complicated.

You think that probably the pediatrician should have discretion, right? I think there are... Yes. You're asking her whether she thinks the court should decide her the pediatrician? No, no, the pediatrician should be able to have discretion to stop vaccinate or not. the court have to do with that why are you asking you know what it's not necessary to the question i i i remove that portion of the question so if if if faith i just if faith were to be if the parents decide let me try let me take a step better if if something if you had a if you were

vaccinating a child and they had adverse reactions what would you would you stop the vaccination process? Not necessarily the full vaccination process. It would depend on the reaction. It depends on the reaction. It depends on which vaccines were given that could potentially have caused it. Okay. Checking antibody levels in the blood to a disease is also known as checking titers, correct? Correct. Isn't it true that in the state of Michigan, a child that has sufficient titers for measles, mumps, rebella, hepby, or velice, or varicella, is not required to get to get a child. these vaccines, the vaccines for these diseases to attend school? That is correct. Okay. What is the vaccine adverse events reporting system? It is a reporting system where we

report adverse events that appear in association with vaccines. We do not always know the cause and the effect, but we are required to report that. And the CDC administers theirs, correct? Yes. Along with the FDA. If you say so, that's very well possible. As I testified yesterday, I don't know the details of that. Right. Right. You said you're not an expert vaccine.

Correct, right. Okay. Isn't it true that fewer than 1% of adverse vaccine events are reported to theirs? They need to be, if they, when you talk about adverse vaccine events, they have to be significant to be reported. If it's just the child developed a fever, you would not report that. that's an expected side effect? Right. So isn't it true that less than 1% of the type of events

that you're talking about that should be reported are actually reported to theirs? I'm not aware of that. Are you familiar with Harvard Medical School and the Harvard Pilgrim Health Care? I'm familiar with Harvard Medical School, and what was the other one? Harvard Pilgrim Health Care?

I'm assuming that's their health care system. Is that yes? That's my understanding, yes. And it's one of the healthcare HMOs that's part of the vaccine safety data link. You might be familiar with that, but the CDC administrators? I'm not familiar with it. Okay. Yes.

My understanding is that yes. It is the health care system that's associated with Harvard Medical School. That is my understanding. Okay. And your question was, am I familiar with it? No, I am not familiar with it. Are you familiar with Harvard Medical School? Absolutely.

Okay. Would you consider a report prepared by Harvard Medical School? school researchers under a grant from the United States Department of Health and Human Services looking at the vaccine adverse event supporting system or brought liable authority. My hesitation in answering that question is I'm not quite sure what you are implying by considering it a reliable authority. It is certainly something that I would take seriously. Would I accept it as a hundred percent gospel, not necessarily? Well, we would, most of it would accept, most things I'm going to be gospel, correct?

but you would consider it an authority. As, yes. May I approach, Your Honor? Can you kindly read the yellow highlighting the report that I just mentioned? This is from the electronic support for public health vaccine adverse event report system from 2007 to 2010, performed by the Harvard Program Health Care Incorporated. Under results, it says preliminary data were collected from June 2006, through October 2009 on 715,000 patients and 1.4 million doses of 45 different vaccines

and 1.4 million doses in parentheses of 45 different vaccines were given to 376,452 individuals. Of these doses, 35,570 possible reactions in parentheses 2.6% of vaccinations were identified. This is an average of 890 possible events. an average of 1.3 events per clinician per month. These data were presented at the 2009 AMIA conference. And then the other part that is in yellow reads, adverse events from drugs and vaccines are common but underreported. Although 25% of ambulatory patients experience an adverse drug event,

less than 0.3% of all adverse drug events, and 1 to 13% of serious events are reported to the food and drug. administration. Likewise, fewer than 1% of vaccine adverse events are reported. Isn't it true that in the last 10 years, theirs has received reports of 511 deaths, 829 permanent disabilities, and 3,021 hospitalizations following polio antigen containing vaccines? I don't know. That's not my area of expertise. But you said you consider the CDC website a reliable authority, correct? Correct.

May I question, Your Honor? Yes. I just want to object to this line of showing her these reports. The report admissible, I presume this is a reliable authority 707 argument, are admissible only for impeachment purposes. He's trying to admit these to hearsay purposes to get the evidence contained within these reports admitted by having her re-com into the record. They don't mention Dr. Holtrip.

Dr. Holtrop hasn't been qualified as an expert in immunology or vaccines. You can ask if he's aware of these. But she either is where my objection is. Okay, overruled. Do you have a question? Yes, thank you, Your Honor. So, the, you're holding a report from the CDC of reported adverse events from the polio-containing vaccines for the last 10 years.

Across some deaths, can you read it? What's the number of reports? I'm sorry, I cannot tell what this reports. It just says the vaccine adverse event reporting system bears results. Absolutely. It does not say what this is specific to. Sure. If you go to page four, okay.

Do you see the date report received line? Yes. Okay, do you see that it says January, 2017, December 2017. I do. Do you understand that to be around the 10-year period? Correct. Okay, and you see the next page that's in the products, it contains of products that have polio antigens in them.

It has, the vaccine products are numerous, and it's not all just ones that contain polio. No, I've got limited time, so I might have to just make a proper on this at the end. Or can I get a little extra time? What do you want to ask her about this? Well, I just want her to, I'm just trying to have her confirm the number of deaths, permanent disability and hospitalizations. And she looks like she's going to take a whole time to look at it out. Well, my question, my concern is that you ask me about polio, and this is not specific to polio.

This looks at all the different vaccines that are listed. These are all the vaccines that have polio-containing antics. Actually, no. The first one listed is diphtheria and tetanistoxoids. The next one is aceroprtesis. That's one vaccine. There is no way to be able to tell that that's the case. Do you see the plus symbols?

Each plus symbol denotes a different vaccine, the break between a different vaccine. If that's the case, then why is Deferian tetanus toxoid listed twice before the first plus? I did not design the VAR system. I'm just telling you that that's the way. I cannot tell what this is based on what you have handed me. Okay, that's fine. Fair enough. We're limited on time anyway. Isn't it true the last case of wild boating in the United States has more than 1979? I believe that's true. Isn't it true that in the last 10 years, Vairs have received reports of 615 deaths, 888 permanent?

disabilities and 4,666 hospitalizations following the theory of containing vaccines. I have no idea if that's true or not. Assuming it's true, since VAERS only captured a small fraction of vaccine adverse events, these numbers are likely to be higher, correct? Based on what you pointed out earlier, I would say yes. The Tennis vaccine was introduced into the routine childhood schedule in the late 1940s, correct? Correct. According to the CDC, prior to its introduction to the routine childhood schedule, there were only 500 to 600 cases, not deaths, cases, a year of tetanus, correct?

I wouldn't know. Isn't it true that in the last 10 years, Bayeris has received reports of 1,060 deaths, 1,341 permanent disabilities, and 10,974 hospitalizations following tetanus-containing vaccines? Again, this is not my area of expertise. Also, I would like to point out that when you make a report to VERS, an association does not mean causation. Right. You should do a clinical trial, which aren't done, to check those who receive a versus or don't, but those studies aren't done, right? Correct.

Okay. And assuming those statistics were true that I just read from the VERS report, isn't it, since VERS only receives a tiny fraction of vaccine adverse events, isn't it true that these numbers are likely higher? Yes. Isn't it true that there are 1.2 million people in Oakland County and that there have only been around 100 cases of Hep B total since the outbreak you mentioned yesterday? The outbreak I mentioned was not Hep B. I apologize. And say the question again? Absolutely.

Isn't it true that there are 1.2 million people in Oakland County and there have only been 100 cases of HEPA total since the outbreak you mentioned yesterday? That is not correct. She's answered that. It's actually not true anyway. Okay, what part's not true? The number. There have been more cases. In Oakland County?

Yes. Okay. You consider the Department of Community Health of Michigan at the Oracle Label Authority, right? I do. And yesterday afternoon after being in court here, I went to the Michigan Department of Health and Human Services and where an official from Michigan Medicaid presented on the hepatitis A outbreak

and presented us with data by county. Okay, and what was the number for Oakland? I don't know the exact number, but it was in the several hundreds. Your Honor, I want to strike this hearsay. You asked her a follow-up question, huh? I know. I know, but she's not... I'm not going to start here.

Let's just move on. But I, you know, that's why I thought I thought I was not about. I can't hear what you say when you duck down. We talked about this yesterday. Okay, sorry. I'll have to come back to that. All right. Aluminum adjuvants are using vaccines, correct?

Right. Correct. Why are the aluminum management using vaccines? Because they make the vaccine more effective. Okay. And how do they do that? I don't know. Okay.

What's an antigen? An antigen is typically a protein that, in this case it would be, if you're talking about vaccines, an antigen is a protein that causes a reaction and oftentimes is an infection. is an infectious agent, but not always. Antigen, okay, and antigen are contained in vaccines, correct? Correct. Antigens bind to the aluminum, correct? Correct. What are macrophages? Those are a type of cell in the blood. Only in the blood? And other parts of the body, too. What do they do? They eat up stuff that you shouldn't have in your body. Okay, and antigens bound to aluminum are taken up by macrophages, correct? Yes. Okay. And macrophages bound to aluminum are taken up by macrophages, correct?

Yes. Okay. And macrophages present the stuff they gobble up to the parts of the immune system that create antibodies, correct? I believe so. I have not studied the actual mechanism of action. And they also travel to different parts of the body, including brain, correct? Correct. And they'll deposit the materials they gobble up there, correct?

Correct. What is encephalitis? It's an inflammation of the brain. What is encephalopathy? It is a chronic condition of the brain being out of whack. What is encephomyalitis? It's cephalomyelitis. It is an inflammation of the myelin within the brain?

Isn't it true that most vaccine inserts report for most vaccines, excuse me, strike that, isn't it true that most package inserts for most vaccines report encephalitis or encephalopathy as a rebate? as a reported adverse event from vaccination? I would have to look at all the package inserts to be able to say yes or no to that. It is possible. Are you aware that all deep-tapped containing vaccines list of encephalopathy within seven days of a prior pertussis-containing vaccine as a contraindication?

Yes. Do any of the vaccines in the child's cell will contain monkey kidney cells? I do not know. Blood serum from cows? I do not know. Guinea pig cell cultures? I do not know. Gelton from pigs and cows?

I don't know. MRC-5 human diploid cells. MRC-C-5 human diploids. Those are specifics that I typically do not. Are you aware that MRC-C-5 diploid cells are cells cultured from the lung tissue and abortive fetus? I am aware that there are two vaccines out on the market. The MMR and the VZV that have

that use a cell in the production of it, use a cell line from aborted fetuses from 1962 and 1966. Those are the only two aborted fetus tissue cell lines that are used, and there is no alternative to it. So the cultures, Japan has an MMR vaccine, correct? I believe so. And theirs doesn't have any human fetal cell. I am not aware that there is one that is licensed.

in the United States other than what we have. Okay. So there are vaccines that contain the cell lines from abortive fetal tissue, correct? From 1962 and 1966, yes. But did that... Actually, the vaccine doesn't contain the cell line. The anti... the vaccine is, requires culture within those cell lines. And you're saying that none of those, none of the, aborted fetal tissue cultural cell lines actually end up in the vaccine product? The vaccine doesn't have cells in it.

The cellular pieces from the aborted feal. That is potentially possible, yes. Isn't it true that, in fact, there is more of that cellular debris in the MMR, for example, and there is actually antigen? I don't know. Okay. Isn't it true that the Havrex, the hepatitis vaccine contains millions of fragments of human DNA? Possible? I don't know.

If Dr. Plotkin said that it does, would you disagree? If he says it does, then I will agree. Isn't it true that Varyvats, the chickenpox vaccine, contains approximately 1 trillion fragments of human DNA? Again, if Dr. Plotkin says it does, then I will agree. Okay. Do any vaccines on the child's vaccine schedule contain human albumin, which is part of the human blood? Not to mind. Albumin is, yes, it is found in human blood, but it can also be produced separately, to the best of my knowledge. But you're not aware of whether it's in. I don't know if it's in there or not.

Isn't it true that a monkey virus, SV40, infected millions of Americans before was discovered in the polio vaccine? That is possible? You're not aware of it? I'm not aware of that, no. Okay. Isn't it true, are you aware that SV40 has been and continues to be found in various human tumors? I'm not aware of that. Isn't it true that an adjuvant will only, will not only bind to the target antigen that's in the vaccine, but also to the impurities and byproducts such as the animal and human parts left in the vaccine of the manufacturing process? You're asking me specifics about physiology that I am not aware. That's not my area of expertise.

Are you aware I asked Dr. Plotkin the same question? He said probably yes. As I've mentioned previously, I have no idea what you asked Dr. Plotkin. Once the aluminum adjuvant is bound to the impurities and bi-products, the body products, the body may also develop antibodies to these impurities and bribe products, correct? I suppose that would make sense from a physiologic point of view. And if Dr. Plotkin said that it might, it could, would you disagree? I would not disagree?

Isn't it true that in just one stuff? related to vaccine development conducted by Dr. Plotkin. He used 74 normally developed fetuses three months or older, many of which were electively aborted. I'm going to object to the relevance of what Dr. Plotkin did in his study. She's already testified that she's not an expert on everything he's written. He's not here today. I realize they want to spend a lot of time in teaching him, but he's not a witness. Your Honor, my client has an objection of a religious nature to vaccination that relates to the use of aborted fetuses. The use of aborted fetuses is the development of

is clearly relevant to this dispute. How well on? I've only got two more questions on it, and then I'm almost. Great. Done. Okay. All right.

Isn't it true, these 74 aborted fetuses had almost every piece of their bodies, including skin tugging and heart, cut into little cues to be used for culture? I'm not aware of any studies that Dr. Plotkin, the specifics of any studies that Dr. Plotkin did. You're aware that he's developed numerous vaccines, correct? I am aware of that, yes.

Isn't it true that at least hundreds of abortive fetuses have been sacrificed in the development of vaccines? Again, I cannot comment on that. I can comment on what the Vatican has said about the vaccines and whether to use them or not. What principles and methods did you rely upon in reaching your opinion regarding vaccine safety? I use the, again, the recommendations of the CDC and the American, the American, the advisory committee on immunization practices and the American Academy of Pediatrics to make form an opinion about the vaccine safety and also I used my experience in seeing children who have died from conditions that were vaccine preventable

once you have seen a child die from a vaccine preventable disease your focus on how you feel about vaccines changes dramatically I have seen children from Meningococcal disease very rapidly. As soon as the vaccine became available on the market, I made sure that my daughters got that vaccine. The same is true for HPV vaccine. You believe in informed consent, I presume. I believe in informed consent. Informed consent involves also knowing not just what the potential side effects are, but what the actual risks are of having the disease. That's right, but it also involves understanding the risks of the product itself, correct?

You have to balance the risks versus the benefits. In this case, the the benefits far outweigh the risks. Okay, and the basis for that opinion is the information on the CDC, the CDC is because it's a CDC recommendation, correct? Both that as well as what I have personally experienced. Okay, so your basis, so I'm saying, the principle of method is that you relied upon of reaching your opinion regarding vaccine safety and vaccine efficacy are what the CDC recommends and your claim that you've seen some people die of some diseases for which are vaccinations.

Is that correct? Correct. That's the sum in total, right? And the American Academy of Pediatrics recommendations? Okay. That's it. How we form opinions is quite complex, and you're asking me how I formed all of these opinions, and I have to say there are probably other influences that I am not thinking of.

at this point but in general in general those are the major your honor I'm on that basis those are the principles and methods she's relied upon I moved to disqualify her as an expert with regards to vaccine safety and efficacy downward standard requires principles and methods that are reliable that are reproducible that you can actually value in a peer review publication based on She's already been qualified in an expert. Right, but I'm moving to, I understand that, but I'm moving to have all of her testimony

regarding vaccine safety and efficacy. Pediatrics can be viewed broadly, Your Honor. And obviously, you know, I objected at the beginning. And so I'm in some ways in my objection in that to the extent that her qualification as a pediatrician, which is fine, I don't contest that there are certainly areas in pediatrician. she is qualified to be a, an expert.

You're welcome to brief it. It sounds like you probably should, but for now, are you done with your cross-examination? Okay, but that's an issue that you'll take under advisement, Your Honor? If you'd like to brief it, but you're going to have to come more with a two-minute oral argument with some case law. Court rules.

Anything else? Well, you know, I went through things a lot quicker than I would have normally done, given that 30-minute limit I gave you 45 minutes. It's night 45. I did pause it every time I was, I was, I had somebody else did something. I've got 30 minutes and 42 seconds, but I do appreciate that, Your Honor. I do appreciate that. What you're concluding, right?

I'm concluding just reserving for any recross, if there's something that comes up. All right. Dr. Holtrae, we'll make this pretty quick. Tends to be my habit. So let's start with, I'm going to go in reverse ground in a logical order as well. So, when there was some conversation, about aborted fetal cell lines and not a lot of... Can you tell me what you mean when you say a cell line?

A cell line is a stem cell typically, a cell that can still reproduce and in, for example, if you take tissues from lung fibroblasts, those can be made to reproduce and continue to be lung fibroblast cells and they have been reproduced year after year after a year. How are they reproduced? Those are specifics that I think I'm taught you. Are they grown in a lab? They're grown in a lab, yes. So the word aborted fetal cells has been used a lot. Is there, are there, and I'm

trying to phrase this delicately, are there new aborted cells being added to this? To the best of my knowledge, there are not new aborted cells being added to it. But again, this is vaccine. Manufacturing is not my of expertise. All right. I'm going to go to something that kind of is, so you'll appreciate that. So we talked about encephalitis and cephalopathy and myelitis, and we also spend a lot of time discussing aluminum. Have you done research on specifically metal toxicity in the human body? I have. Lead poisoning, specifically. Why isn't the aluminum and vaccines concerning to you? Or is the aluminum and vaccines concerning to you? It is not concerning to me because the amount of aluminum that we ingest in general,

just through our diet, is much higher than what we get through. vaccines. There is no reason to believe that that amount, that additional small amount is anything to be concerned about. Are you aware of the relative proportions of the aluminum that we adjust versus the aluminum that we receive? It is significantly higher what we ingest. I would, it's somewhere between 50 to 100 times more than what we get in vaccines. Okay, thank you. Let's talk about bears for a bit. Are you familiar with the process to report a vaccine injury to theirs? There is a, there is a website. site to report it on and a phone number that what can be called.

All right, is it the physicians reporting these adverse events? Yes. Can someone report their own adverse event without a position? It would be possible, yes. There's no limitation as to who makes the report. So would it be possible for a person or persons with an agenda to make reports? That is possible, I would assume. All right, and are there any standards for the timeline to make a report to bears?

You typically are required to make that report as soon as possible, as soon as you become aware of it. Is there a timeline for how long the alleged adverse reaction takes place after the administration of the vaccine? I'd have to look up the guidelines. It's generally within a few days after the vaccine. All right. And all right, so we also talked about titers a bit. And that how long, how long? would a child develop immunity that would show you a tighter? Okay so when you are, when your body is encounters an antigen, the body typically responds to it by producing an antibody. Antibodies are sort of like the little soldiers that help to fight off the antigen or the infection. Some antibodies are effective, some are not effective and that is actually part of the

process of developing a vaccine is to help the body produce antigen. antibodies that are effective in fighting off the infection. And so there was a lot of talk about the fact that a lot of vaccine preventable diseases we don't see. Correct. Why do we still vaccinate against those diseases? Because they haven't been eliminated and because in a globalized world, it is possible to be exposed to them from somebody traveling on an airplane, bringing it into the country, and we know that that has happened with a number of diseases.

All right. And next, this is almost a lot question. I give this for you. So when you're looking at a patient and making the determination as to what vaccines they should receive, what family history factors are concerned to you? One of the big family history factors that I would take into consideration is, is there a history of anybody who's immune suppressed? And actually, in certain knowing

that there are certain conditions in the family would make me more likely to immunize rather than less likely, because especially folks who have a chance of having diabetes or asthma, may, if there's a family history of it, the chance that the child might have it is higher. And then the child may be more likely to suffer the severe side effects if they were to catch that disease.

All right, and are you familiar with the Institute of Medicine at all? I'm familiar with it, yes. Can you explain briefly what it is? I can't. It's fine. I know that there are recommendations that come out from the Institute of Medicine.

And I'm sorry, I haven't looked at that in a while. That's fine. No further questions. Anything? Yeah. Just only. Only. Exactly what was going to go outside.

Okay. If I do, I'll gladly take that objection. Okay. Okay. Isn't it true that there actually has recently been a new cell line, human cell line from a border fetal tissue that's been approved for use of vaccines? I'm not aware of that. Isn't it true that the only polio vaccine using the United States is an activated polio vaccine, which is injected of muscle tissue? Incorrect. It's an inactivated polio virus vaccine. Right, and it's injected in muscle tissue.

Correct. Versus what we used to be used as important. Actually, it's not into the muscle tissue. It's given subcue typically. And isn't it, and the polio vaccine that used to be used in America and the one that still used most overall country's oral polio vaccine. Correct. Isn't it true that the World Health Organization recommendation provides that because,

strike that, polio vaccine is, polio vaccine is a, Polio is transmitted from mouth to fecal contamination, correct? Correct. Correct. Okay, so it infects and proliferates in the intestines. Correct. Is it true the World Health Organization provides that if there's an outbreak of polio in a country that uses IPV, they're supposed to switch over to OPD because IPV gives personal protection because it only creates immunity in the blood, not in the intestines.

So therefore, it... the polio vaccine can still proliferate and spread if all you have is IPV and not OPD, correct? That is correct. Right. So, right, so the poll. And that goes to the point that my opposing counsel is saying that the reason we need to strike that, the point is clear. In terms of VERS, for the very small fraction of adverse events that are reported to VERS, the CDC does follow up on some of them, correct?

Yes. And so if people were making phony reports to bears, they find out, wouldn't they? I would assume so. Have you ever read any article about phony bear's reports? I have not. Are you aware of any phony verres reports? I have not. Okay.

Last topic, aluminum, and then I'm done. So you said that the quantity of ingested aluminum is small, or excuse me, is much large in the amount. of injected aluminum and therefore you deem it safe. Correct. Are you aware that the FDA provides that in terms of ingested aluminum, eaten aluminum, 0.3% or less is actually taken up by the blood. Do you know that or not? I don't know the exact numbers.

And if it is, it's taken up in ionic form. Do you understand what I mean? I understand what you mean by that. In its smallest elemental form, that's what it's taken into the blood, right? Correct. And aluminum and ionic form is not able to cross the blood-brain barrier, correct? I am not aware that that's true. You don't know?

I don't know that that's true. Okay. If you don't know, that's fine. In contrast, injected aluminum are nanoparticles, correct? They're there to create an irritant to the immune system so that the vaccine creates antibodies, and so they're actually these nanoparticles that are in the vaccine, right? Or do not know? You're talking about specifics that are very detailed.

Aren't the details important? I mean, you said that... Not in this case, because we're talking about a metal, and we're talking about a metal that doesn't change its form in a way that is... It's not like the... There was a big controversy about mercury in vaccines. And the mercury in vaccines, the form was different than the mercury. that was typically ingested in fish, for example.

I'm not asking about mercury. I know you're not, but that concern is not present for aluminum. I'm going to ask me. The amount of... The aluminum that's injected into the body, are you aware that it's in nanoparticle form, that it is in chemistry... It is bound to something else.

I'm sorry? It is bound to something else. It's used as an adjuvant. Right, meaning you can't have ionic aluminum binding to these giant antigens. You need big pieces of aluminum to bind to the protein antigens, right? When you say big pieces of aluminum? Relative to an ion of aluminum, that would be ingest it. Sir, you're asking these specifics.

They go far beyond my area of expertise. Okay, okay, so you don't know that's fine, but there is, okay, so you're not aware that there's a difference between the form of aluminum. So when it's ingested, it's taken up an ionic form. When it's injected, it's in these nanoparticle forms. And the nanopartic forms... It hasn't presented any authority. Just let me finish.

She's almost done. And the nanoparticle forms that we discussed earlier are gobbled up by macrophages and deposited around the body, including the brain. You know, strike that. I think she's already said she doesn't know. So thank you very much, Your Honor. Thank you.

You can step down in your expertise.