Daniel Edlin — Cross/Redirect/Recross (Continued)

MR. DOWNEY: GOOD MORNING, MR. EDLIN.

MR. DOWNEY: I'D LIKE TO BEGIN TODAY BY ASKING YOU TO LOOK IN THE NOTEBOOK THAT I GAVE YOU AT EXHIBIT 7694. DO YOU RECALL YESTERDAY THAT WE WERE TALKING ABOUT THE BURN STUDY WHICH THERANOS COLLABORATED WITH DR. CHUNG?

MR. DOWNEY: WERE THE RESULTS OF THAT STUDY ULTIMATELY PUBLISHED?

MR. DOWNEY: AND IS EXHIBIT 7694 A COPY OF THAT PUBLISHED STUDY?

MR. DOWNEY: YOUR HONOR, I MOVE TO ADMIT EXHIBIT 7694.

MR. DOWNEY: IF YOU LOOK AT THE FIRST PAGE OF THAT EXHIBIT, IS THAT A SCIENTIFIC CHARACTERIZATION OF THE STUDY AND THE TITLE?

MR. DOWNEY: AND IF YOU LOOK AT -- IF I COULD DIRECT YOUR ATTENTION TO THE SEVENTH PAGE OF THE EXHIBIT, YOU'LL SEE STARTING IN THE BOTTOM LEFT-HAND CORNER, THERE'S A SERIES OF ACKNOWLEDGEMENTS?

MR. DOWNEY: AND DO YOU SEE THAT YOU AND MS. HOLMES AND DR. CHUNG WERE ACKNOWLEDGED FOR YOUR ASSISTANCE IN CONNECTION WITH THIS STUDY?

MR. DOWNEY: AND DO YOU RECALL THAT THIS STUDY TOOK PLACE OVER FOUR YEARS?

MR. DOWNEY: AND IF YOU WOULD LOOK BACK AT THE FIRST PAGE, DO YOU SEE THAT THE PUBLICATION OF THIS STUDY WAS IN EARLY 2017?

MR. DOWNEY: AND THAT WAS ABOUT FIVE YEARS AFTER THE EXHIBIT THAT THE GOVERNMENT WENT THROUGH WITH YOU WHERE YOU FORWARDED A PRESENTATION TO DR. CHUNG. DO YOU RECALL THAT?

MR. DOWNEY: LET ME ASK YOU TO LOOK BACK AT THAT EXHIBIT. IT'S IN YOUR GOVERNMENT BINDER AND IT'S EXHIBIT 551. AND I THINK YOU TESTIFIED -- DO YOU HAVE THAT?

MR. DOWNEY: AND THIS IS ALREADY ADMITTED, YOUR HONOR. I THINK YOU TESTIFIED THAT DR. CHUNG HAD BEEN INVOLVED WITH THERANOS FOR A PERIOD BEFORE YOUR INITIAL CONTACT WITH HIM; CORRECT?

MR. DOWNEY: I'D LIKE TO ASK YOU TO FLIP THROUGH, WITHOUT REALLY STUDYING, PAGES 36 AND FORWARD IN THIS PRESENTATION UNTIL THE END OF THE PRESENTATION ON PAGE 80.

MR. DOWNEY: AND DO YOU SEE THAT MOST OF THIS PRESENTATION IS DATA THAT THERANOS WAS PROVIDING TO DR. CHUNG ABOUT THE PERFORMANCE OF ITS ASSAYS?

MR. DOWNEY: AND DO YOU SEE ON PAGE 36 THAT THERE IS A LIST OF ABOUT EIGHT ASSAYS AND SOME DATA ABOUT HOW THEY PERFORM?

MR. DOWNEY: AND IS THE SIGNIFICANCE OF THIS DATA, IN LAYMAN'S TERMS, THAT THEY SHOW A STRAIGHT LINE AND YOU LOOK FOR HOW CLOSE THE DOTS ARE TO THAT LINE TO EVALUATE THE EFFECTIVENESS OF THE ASSAY?

MR. DOWNEY: OKAY. AND DO YOU SEE, IF YOU LOOK THROUGH THIS, THAT SOME OF THE CORRELATIONS ARE QUITE GOOD, LIKE ON PAGE 36 IN THE UPPER RIGHT-HAND CORNER, THE CORRELATION IS .999?

MR. DOWNEY: BUT DO YOU SEE IN OTHER PLACES IN THE PRESENTATION THAT THE CORRELATION IS LESS GOOD? LET ME DIRECT YOUR ATTENTION, FOR EXAMPLE, TO SLIDE NUMBER 48, WHICH IS ON TRIAL PAGE -- TRIAL EXHIBIT PAGE 52. AND DO YOU SEE HERE ON THE LEFT-HAND SIDE, FOR EXAMPLE, WITH ASSAYS BASED ON URINE, THERE'S A SIGNIFICANT DROP IN THE PERCENTAGE OF CORRELATION FROM .999 TO .966; CORRECT?

MR. DOWNEY: OKAY.

MR. DOWNEY: OKAY. BUT IT VARIES FROM THE .999 IN THE OTHER ASSAY?

MR. DOWNEY: AND IF YOU CONTINUE FORWARD THROUGH THE PRESENTATION, YOU SEE THAT THERE IS JUST DATA ABOUT A NUMBER OF THE ASSAYS THAT THERANOS HAD DEVELOPED; CORRECT?

MR. DOWNEY: AND ALL OF THAT WAS PRESENTED TO DR. CHUNG; CORRECT?

MR. DOWNEY: DO YOU BELIEVE THAT DR. CHUNG HAD THE ABILITY TO UNDERSTAND THAT DATA?

MR. DOWNEY: DO YOU KNOW WHAT AUDIENCE DR. CHUNG WAS PRESENTING THIS DATA TO?

MR. DOWNEY: LET ME JUST ASK YOU IF YOU LOOK BACK AT PAGE -- AT EXHIBIT 551 AT THE TOP OF PAGE 3.

MR. DOWNEY: ALL RIGHT. AND HE SUGGESTS HE'S GOING TO SHARE IT WITH THE CLINOPS GUY IN THE MILITARY?

MR. DOWNEY: DO YOU KNOW WHO CLINOPS ARE?

MR. DOWNEY: I THINK YOU'VE TESTIFIED YESTERDAY THAT YOU -- YOU CAN PUT THOSE EXHIBITS ASIDE. I THINK YOU TESTIFIED YESTERDAY THAT YOU HAD DISCUSSIONS, ON THERANOS'S BEHALF, WITH THE UNITED STATES AFRICAN COMMAND. DO YOU RECALL THAT?

MR. DOWNEY: AND YOUR PRINCIPAL CONTACT AT THE UNITED STATES AFRICAN COMMAND WAS DR. MELISSA GIVENS; IS THAT RIGHT?

MR. DOWNEY: AND THE SHORTHAND REFERENCE FOR THE UNITED STATES AFRICAN COMMAND IS AFRICOM; CORRECT?

MR. DOWNEY: AND THAT'S THE UNIFIED COMMAND OF ALL OF THE MILITARY SERVICES IN THE UNITED STATES THAT HAVE SOME OPERATION IN AFRICA; CORRECT?

MR. DOWNEY: AND COLONEL GIVENS WAS A SENIOR MEDICAL OFFICER WITHIN AFRICOM; CORRECT?

MR. DOWNEY: LET ME ASK YOU TO LOOK AT EXHIBIT 10444.

MR. DOWNEY: DO YOU HAVE THAT IN FRONT OF YOU?

MR. DOWNEY: AND IF YOU LOOK AT THE TOP OF THAT EMAIL, DO YOU SEE THAT THIS IS A SERIES OF EMAIL CHANGES BETWEEN YOU AND DR. GIVENS AND MS. HOLMES RELATED TO POTENTIAL WORK BY THERANOS WITH AFRICOM?

MR. DOWNEY: YOUR HONOR, I MOVE THE ADMISSION OF 10444.

MR. DOWNEY: COULD I DIRECT YOUR ATTENTION TO THE SECOND PAGE OF THIS EXHIBIT, WHICH I'LL DISPLAY ON THE SCREEN. AND IS THIS AN EMAIL THAT DR. GIVENS SENT TO YOU AND MS. HOLMES IN APRIL OF 2012?

MR. DOWNEY: AND DO YOU SEE IN THE FIRST PARAGRAPH SHE'S LOOKING TO SET UP A MEETING WITH YOU AND MS. HOLMES?

MR. DOWNEY: AND SHE ASKS THE QUESTION, "HAS THERE BEEN ANY PROGRESS IN CONFIGURING A SYSTEM THAT WE WOULD SOON BE ABLE TO --" AND I'M NOT SURE WHAT THE NEXT WORD IS, EITHER EMPLOY OR DEPLOY, "SOON TO AFRICA?" DO YOU SEE THAT?

MR. DOWNEY: AND HAD YOU BEEN HAVING DISCUSSIONS AT THIS TIME WITH DR. GIVENS ABOUT DEPLOYING THE SYSTEM TO AFRICA?

MR. DOWNEY: AND IF YOU LOOK AT THE SECOND PARAGRAPH, SHE GOES ON TO DETAIL THE KIND OF SYSTEM THAT SHE WOULD BE ABLE TO OPERATE WITH IN AFRICA; CORRECT?

MR. DOWNEY: AND SHE'S DESCRIBING A BLOOD ANALYZER HERE; CORRECT?

MR. DOWNEY: AND SHE'S DESCRIBING THE FEATURES OF A BLOOD ANALYZER THAT WOULD WORK FOR HER FOR, AT LEAST AN INITIAL EVALUATION AND DEPLOYMENT IN AFRICA; CORRECT?

MR. DOWNEY: AND IF YOU LOOK AT THE SECOND SENTENCE OF THAT PARAGRAPH, SHE SAYS, "I HAVE SEVERAL TRIPS TO AFRICA COMING UP IN THE NEXT FEW MONTHS AND REALLY WANT TO TEST THE EQUIPMENT/PROCESS AND THEN MOVE FORWARD WITH FIELDING IT FOR FULL TIME USE IF THE TEST RUNS GO WELL." DO YOU SEE THAT?

MR. DOWNEY: AND SHE WAS TRYING TO ARRANGE A MEETING WITH YOU AND MS. HOLMES TO PURSUE THAT; CORRECT?

MR. DOWNEY: DID YOU ULTIMATELY HAVE A MEETING WITH DR. GIVENS TO PURSUE THAT KIND OF AN ARRANGEMENT?

MR. DOWNEY: OKAY. BUT YOU CONTINUED DISCUSSIONS AFTER THIS ABOUT THE POSSIBILITY OF DEPLOYING A DEVICE IN AFRICA WITH COLONEL GIVENS?

MR. DOWNEY: DO YOU SEE IN THIS -- IN THE REFERENCE IN THE SECOND PARAGRAPH ASKING ABOUT PROGRESS, SHE REFERS TO CONFIGURING A SYSTEM. DO YOU SEE THAT?

MR. DOWNEY: WHAT DOES THAT MEAN?

MR. DOWNEY: OKAY. SO THE THERANOS ANALYZERS WEREN'T JUST OFF-THE-SHELF PRODUCTS. IF THEY WERE USED FOR A PARTICULAR PURPOSE, THEY WOULD HAVE TO BE CUSTOMIZED FOR THAT PURPOSE; IS THAT RIGHT?

MR. DOWNEY: AND THEN YOU SEE IF THE TEST WENT WELL, SHE WANTED TO MOVE FORWARD WITH DEPLOYING THE DEVICE; CORRECT?

MR. DOWNEY: AND THAT TEST DID GO FORWARD; CORRECT?

MR. DOWNEY: AND AFTER THE DISCUSSION WITH HER, DID SHE WORK ON DESIGNING A PROTOCOL FOR THAT STUDY?

MR. DOWNEY: LET ME ASK YOU TO LOOK AT EXHIBIT 13993. YOUR HONOR, MAY I APPROACH THE WITNESS?

MR. DOWNEY: THIS IS NOT IN HIS NOTEBOOK.

MR. DOWNEY: IF YOU LOOK AT THE TOP OF EXHIBIT 13993, DO YOU SEE THAT THIS IS A SERIES OF EMAILS BETWEEN YOU AND DR. GIVENS FROM JUNE OF 2012 RELATED TO DEPLOYING AN AFRICAN -- A THERANOS DEVICE FOR AFRICOM?

MR. DOWNEY: YOUR HONOR, I MOVE TO ADMIT EXHIBIT 13993.

MR. DOWNEY: WELL, I'D BE HAPPY TO SUPPLEMENT THAT, YOUR HONOR, AND I'LL FIND THE ATTACHMENT.

MR. DOWNEY: AND I'LL ATTACH IT AS EXHIBIT A TO 13993.

MR. DOWNEY: YES, SIR.

MR. DOWNEY: IF WE CAN GO ON THE SCREEN TO THE BOTTOM OF PAGE 2 OF THIS SERIES OF EMAILS.

MR. DOWNEY: DO YOU SEE THAT YOU'RE DISCUSSING HERE WITH DR. GIVENS SOME OF THE DETAILS OF THE CUSTOMIZATION OF THE DEVICE?

MR. DOWNEY: AND DO YOU SEE THAT IF YOU GO UP -- AND YOU'RE ASKING HER A SERIES OF QUESTIONS ABOUT HOW THE CARTRIDGES WILL BE STORED; CORRECT?

MR. DOWNEY: AND HOW THE DEVICE WILL BE POWERED, IF YOU LOOK AT THE LAST SECTION OF THE EMAIL?

MR. DOWNEY: AND THEN YOU ASK HER, IN THE SECOND TO LAST QUESTION THAT YOU ASKED TOWARDS THE BOTTOM OF THE EMAIL, YOU ASK, "HOW WILL THE DEVICE BE TRANSPORTED IN THE FIELD? DO YOU PLAN ON KEEPING THE DEVICE IN ITS PACKAGING IN BETWEEN USE? WHAT KIND OF CONDITIONS MIGHT BE ON THE MEDEVAC FROM GERMANY TO UGANDA?" DO YOU SEE YOU WERE ASKING THOSE QUESTIONS?

MR. DOWNEY: AND WHY WERE YOU ASKING HER THOSE QUESTIONS?

MR. DOWNEY: SO THAT WOULD BE DR. YOUNG AND PEOPLE WORKING UNDER HIM?

MR. DOWNEY: AND SHE RESPONDS TO THIS EMAIL BEGINNING ON THE PRIOR PAGE AND SHE DESCRIBES THE LOGISTICS THAT THE DEVICE WILL GO THROUGH TO GET TO AFRICA; CORRECT?

MR. DOWNEY: AND SHE DESCRIBES IN THE SECOND PARAGRAPH THAT THE EQUIPMENT WILL BE FLOWN COMMERCIALLY; CORRECT?

MR. DOWNEY: AND THEN IN THE LAST PART OF THAT PARAGRAPH, SHE DESCRIBES WHAT -- THE SITE WHERE THE DEVICE WILL BE LOCATED, THE CONDITIONS THERE; CORRECT?

MR. DOWNEY: AND SHE INDICATES THERE'S NO AIR CONDITIONING IN THE BUILDING AND THE TEMPERATURE WILL BE BETWEEN 100 AND 110 DEGREES FAHRENHEIT; CORRECT?

MR. DOWNEY: AND SHE ALSO DETAILS HOW SHE'S GOING TO SHIP THE DEVICE. AND SO YOU'RE WORKING ON ALL OF THOSE LOGISTICS WITH HER; RIGHT?

MR. DOWNEY: IF YOU LOOK TOWARD THE SECOND TO THE LAST SENTENCE, SHE GOES ON AGAIN TO EMPHASIZE THAT THE TEMPERATURES WILL RANGE FROM 100 DEGREES FAHRENHEIT WITH HIGH HUMIDITY, BUT THEN IN FLIGHT THE TEMPERATURES WILL DROP TO ABOUT 60 DEGREES FAHRENHEIT. DO YOU SEE THAT? THAT'S ON THE SECOND PAGE TOWARDS THE END OF THAT EMAIL.

MR. DOWNEY: SO YOU'RE WORKING ON THIS PROTOCOL WITH HER KNOWING THAT THIS IS GOING TO BE A DEPLOYMENT IN SEVERE WEATHER CONDITIONS POTENTIALLY?

MR. DOWNEY: AND YOU WERE INFORMING THE SCIENTISTS AT THERANOS THAT THESE WOULD BE THE CONDITIONS?

MR. DOWNEY: IN PART BECAUSE THIS WAS INFORMATION THAT THEY HAD ASKED FOR; CORRECT?

MR. DOWNEY: DO YOU KNOW WHETHER THE DEVICE WAS CONFIGURED BY THE SCIENTISTS AT THERANOS TO DEAL WITH THOSE EXTREME WEATHER CONDITIONS?

MR. DOWNEY: OKAY. YOUR HONOR, MAY I APPROACH THE WITNESS AGAIN?

MR. DOWNEY: (HANDING.)

MR. DOWNEY: I'M SHOWING YOU WHAT HAS BEEN MARKED AS EXHIBIT 13986. IS THIS AN EMAIL BETWEEN DR. YOUNG AND MS. HOLMES AND YOURSELF AND CHRISTIAN HOLMES RELATED TO THERANOS'S AFRICOM DEPLOYMENT?

MR. DOWNEY: YOUR HONOR, I MOVE TO ADMIT EXHIBIT 13986.

MR. DOWNEY: WE HAVE RECOVERED IT FROM -- WE DID NOT GET IT OUT OF THE PRODUCTION FROM THERANOS. I'D BE HAPPY TO EXPLAIN TO THE COURT HOW WE DID.

MR. DOWNEY: I THINK THE WITNESS HAS AUTHENTICATED IT.

MR. DOWNEY: I'LL SHOW YOU AND BLOW UP THE TOP OF THIS EMAIL SO IT'S EASIER TO SEE.

MR. DOWNEY: DO YOU SEE THIS IS AN EMAIL FROM DR. YOUNG TO YOU IN JUNE OF 2012 RELATED TO THE AFRICOM PROJECT?

MR. DOWNEY: AND HE'S REPORTING TO YOU ABOUT TESTING THAT HE DID ON THE DEVICE THAT IS BEING SENT TO DR. GIVENS FOR DEPLOYMENT IN AFRICA; CORRECT?

MR. DOWNEY: AND HE REPORTS THAT HE'S DONE "48 HOURS OF CONTINUAL TESTING OF THE READER AT 110 DEGREES FAHRENHEIT COMPLETED SUCCESSFULLY TONIGHT. WE RAN 100 PROTOCOLS SEQUENTIALLY - SO I FEEL VERY GOOD ABOUT RELIABILITY FOR THIS DEPLOYMENT." DO YOU SEE THAT?

MR. DOWNEY: AND DO YOU RECALL THAT THERE WAS CONFIGURATION OF THE DEVICE RELATED TO THE TEMPERATURE IN AFRICA?

MR. DOWNEY: OKAY. AND DID YOU THEN SEND THE DEVICE TO DR. GIVENS FOR DEPLOYMENT IN AFRICA?

MR. DOWNEY: CAN I ASK YOU TO LOOK AT EXHIBIT 10446.

MR. DOWNEY: IS THIS AN EMAIL EXCHANGE BETWEEN YOU AND DR. GIVENS AND MS. HOLMES RELATED TO THE AFRICOM DEPLOYMENT?

MR. DOWNEY: YOUR HONOR, I MOVE THE ADMISSION OF EXHIBIT 10446.

MR. DOWNEY: CAN WE BLOW UP THE BOTTOM HALF OF THE EMAIL.

MR. DOWNEY: IS THIS A REPORT THAT DR. GIVENS HAD GIVEN YOU AFTER SHE HAD TAKEN THE DEVICE TO AFRICA AND USED IT IN LOCATIONS OVER THERE?

MR. DOWNEY: AND DO YOU SEE SHE REPORTED, "I MADE IT BACK FROM 2 TRIPS TO AFRICA AND MANAGED TO WORK THROUGH ALL THE CASES IN THE PROTOCOL." DO YOU SEE THAT?

MR. DOWNEY: AND WHEN SHE REFERS TO THE PROTOCOL, THIS WAS NOT ACTUAL TESTING ON PATIENTS; CORRECT?

MR. DOWNEY: AND THE STUDY WAS NOT DESIGNED TO CONDUCT ACTUAL BLOOD TESTING ON PATIENTS, WAS IT?

MR. DOWNEY: AT DR. GIVENS'S REQUEST, THE RESULTS THAT WERE TO BE GENERATED WERE ARTIFICIAL RESULTS AND SHE WAS TESTING THE VIABILITY OF THE DEVICE IN A DEPLOYED ENVIRONMENT; RIGHT?

MR. DOWNEY: AND SHE GOES ON TO SAY, "THE MACHINE TRAVELED WELL AND FUNCTIONED WELL. MY ONLY COMPLAINT IS THE TOUCH SCREEN - VERY FRUSTRATING." AND WAS SHE REFERRING THERE TO THE INTERFACE ON THE FRONT OF THE THERANOS ANALYZER?

MR. DOWNEY: AND SHE HAD SOME DIFFICULTY OPERATING THAT INTERFACE?

MR. DOWNEY: OKAY. AND THEN SHE GOES ON TO REPORT THAT SHE'LL BE PREPARING A FULL REPORT AND SHE'LL HAVE SEVERAL PICTURES OF THE MACHINE BEING USED IN CAMEROON, UGANDA, AND SOUTH SUDAN. IS THIS THE FIRST TIME THAT YOU HAD LEARNED THAT SHE HAD ACTUALLY DEPLOYED THE DEVICE IN THOSE LOCATIONS?

MR. DOWNEY: AND THEN SHE GOES ON TWO PARAGRAPHS LATER TO WRITE, "BECAUSE THE MACHINE SEEMED TO FUNCTION WELL IN THE ENVIRONMENT, I AM GOING TO WRITE A PRE-PROPOSAL TO SUBMIT TO THE U.S. SOCOM." THAT'S A REFERENCE TO SPECIAL OPERATIONS; CORRECT?

MR. DOWNEY: AND SHE WAS HOPING TO GAIN FUNDING FOR A FULL PROPOSAL; CORRECT?

MR. DOWNEY: NOW, DO YOU RECALL YESTERDAY THAT MR. BOSTIC SHOWED YOU AN EXHIBIT RELATED TO QUESTIONS ABOUT THE OPERATION OF THE DEVICE IN EXTREME TEMPERATURES?

MR. DOWNEY: LET ME ASK YOU TO PULL THAT BACK UP, WHICH IS ALREADY IN EVIDENCE, AND I'LL PULL IT ON THE SCREEN. IT'S EXHIBIT 5435. AND I'LL DIRECT YOUR ATTENTION AND ASK THAT THE SCREEN BE DIRECTED TO PAGE 4 OF THAT EXHIBIT. AND DO YOU RECALL MR. BOSTIC SHOWING YOU THIS YESTERDAY WITH THE COMMENTS OF SEVERAL OF THE SCIENTISTS ABOUT WHETHER THE DEVICE COULD OPERATE IN EXTREME TEMPERATURES?

MR. DOWNEY: AND YOU HAD RAISED QUESTIONS WITH THIS -- REGARDING THIS WITH DR. YOUNG; CORRECT? THAT'S --

MR. DOWNEY: THAT'S THE REFERENCE TO DANIEL?

MR. DOWNEY: AND AT THIS TIME YOU HADN'T HEARD BACK FROM HIM; CORRECT?

MR. DOWNEY: AND THEN BELOW THAT YOU HAD ALSO ASKED QUESTIONS OF MR. FRENZEL, CORRECT, GARY FRENZEL?

MR. DOWNEY: AND MR. FRENZEL WAS NOT A HARDWARE PERSON AT THERANOS, WAS HE?

MR. DOWNEY: OKAY. AND HE SAYS, "THE EDISON DID NOT HAVE A WAY TO COOL DOWN. THEY WOULD HAVE SHUT DOWN." DO YOU SEE THAT?

MR. DOWNEY: NOW, MR. FRENZEL WAS NOT INVOLVED IN THE AFRICOM PROJECT, WAS HE?

MR. DOWNEY: AND AFTER THE DEPLOYMENT BY DR. GIVENS, THE DEVICE DID NOT SHUT DOWN, DID IT?

MR. DOWNEY: OKAY. DO YOU RECALL THAT SHE REPORTED BACK TO YOU THAT THE DEVICE FUNCTIONED WELL?

MR. DOWNEY: LET'S GO DOWN TO THE NEXT TWO COMMENTS. THESE ARE ALSO COMMENTS FROM INDIVIDUALS WHO WERE NOT INVOLVED IN THE AFRICOM DEPLOYMENT; CORRECT?

MR. DOWNEY: THAT'S TRUE OF TONY; CORRECT?

MR. DOWNEY: AND IF YOU GO TO THE BOTTOM, IT REFERENCES SUREKHA; CORRECT?

MR. DOWNEY: AND THAT'S A REFERENCE TO MS. GANGAKHEDKAR?

MR. DOWNEY: SHE DID SOMETHING SIMILAR TO WHAT MR. FRENZEL DID?

MR. DOWNEY: OTHER THAN DR. YOUNG, DO YOU KNOW WHO WAS INVOLVED IN THE PREPARATION OF THE DEVICE A YEAR BEFORE THIS EMAIL?

MR. DOWNEY: OKAY. BUT YOU DIDN'T KNOW WHO WAS ON MR. -- DR. YOUNG'S TEAM?

MR. DOWNEY: OKAY. I WANT TO ASK YOU NOW ABOUT THE RELATIONSHIP BETWEEN THERANOS AND CENTCOM. DO YOU RECALL DURING THE COURSE OF THAT RELATIONSHIP YOU HAD CONTACT WITH A DOCTOR AT CENTCOM NAMED ERIN EDGAR?

MR. DOWNEY: LET ME ASK YOU TO LOOK BACK AT EXHIBIT 588, WHICH IS IN EVIDENCE. I WANT TO SHOW YOU AT THE TOP OF THIS A DATE BY WHICH DISCUSSIONS WERE HAPPENING BETWEEN THERANOS AND CENTCOM RELATED TO A POTENTIAL DEPLOYMENT. DO YOU SEE THAT THERE WERE DISCUSSIONS AT LEAST AS EARLY AS APRIL 24TH, 2012?

MR. DOWNEY: AND DO YOU KNOW IF DISCUSSIONS BETWEEN CENTCOM AND THERANOS REGARDING A POTENTIAL THERANOS DEPLOYMENT HAD BEEN GOING ON BEFORE APRIL OF 2012?

MR. DOWNEY: ULTIMATELY I THINK YOU TESTIFIED YESTERDAY THAT CENTCOM DID APPROVE A LIMITED OBJECTIVE EXPERIMENT TO EVALUATE THERANOS'S TECHNOLOGY; CORRECT?

MR. DOWNEY: LET ME ASK YOU TO LOOK AT EXHIBIT 10457. IF YOU'LL LOOK AT THE FIRST PAGE, IS THIS AN EMAIL FROM YOU TO MS. HOLMES FORWARDING THE MILITARY'S APPROVAL OF THAT LOE?

MR. DOWNEY: AND THIS APPROVAL WAS SENT TO MS. HOLMES IN DECEMBER OF 2012; CORRECT?

MR. DOWNEY: DO YOU KNOW WHY IT TOOK FROM EARLIER IN THE YEAR, APRIL OF 2012 AT LEAST, UNTIL THE END OF THE YEAR FOR AN EXPERIMENT TO BE APPROVED BY THE MILITARY?

MR. DOWNEY: OKAY. SOME OF THAT RELATES TO CUSTOMIZATION OF THE DEVICE; CORRECT?

MR. DOWNEY: AND SOME OF IT RELATES TO THE MILITARY DECIDING WHAT ASSAYS IT WANTS TO USE IN CONNECTION WITH THE EXPERIMENT; CORRECT?

MR. DOWNEY: AND THEN THERE ARE OTHER ASPECTS TO DEALING WITH THE GOVERNMENT BUREAUCRACY THAT YOU HAD TO DEAL WITH AND CUT THROUGH TO GET THE EXPERIMENT APPROVED; CORRECT?

MR. DOWNEY: AND DO YOU SEE IN THE EMAIL AT THE TOP OF 10457 THAT YOU INDICATE THAT EVEN IN THE APPROVAL --

MR. DOWNEY: WELL, I WASN'T GOING TO ADMIT IT, BUT I'LL MOVE TO ADMIT 10547.

MR. DOWNEY: DO YOU SEE IN THE SECOND SENTENCE, MS. HOLMES -- YOU'RE TELLING MS. HOLMES THAT EVEN AS THIS WAS APPROVED, THE MILITARY HAD ADJUSTED THE ASSAYS THAT IT WANTED FOR THE LIMITED OBJECTIVE EXPERIMENT?

MR. DOWNEY: OKAY. AND IT LOOKS LIKE IT HAD ADDED ABOUT FOUR NEW ASSAYS; CORRECT?

MR. DOWNEY: NOW, AFTER THE EXPERIMENT WAS APPROVAL BY THE MILITARY, I THINK YOU TESTIFIED THAT YOU TRAVELED TO A MILITARY BASE WITH THE DEVICE; IS THAT RIGHT?

MR. DOWNEY: OKAY. AND SO YOU -- THE DEVICE WAS SHIPPED, BUT YOU ALSO WENT THERE AND SHOWED THE DEVICE TO MEMBERS OF THE MILITARY?

MR. DOWNEY: OKAY. AND WAS ONE OF THE PURPOSES OF THAT TO EVALUATE WHETHER OR NOT THE DEVICE WAS SECURE SO THAT IT COULD BE DEPLOYED?

MR. DOWNEY: AND DID THERANOS'S DEVICE PASS THOSE SECURITY TESTS?

MR. DOWNEY: WERE THERE ANY SPECIAL CONFIGURATIONS THAT HAD TO BE MADE TO THE DEVICE TO QUALIFY IT TO BE PART OF AN EXPERIMENT WITH THE MILITARY?

MR. DOWNEY: AND CAN YOU DESCRIBE THOSE?

MR. DOWNEY: WERE THERE ANY MODIFICATIONS, FOR SECURITY PURPOSES, THAT HAD TO BE MADE TO THE DEVICE FOR THIS PROGRAM?

MR. DOWNEY: AND HOW LONG DID THAT RECONFIGURATION TAKE?

MR. DOWNEY: WHEN YOU SHOWED THE DEVICE TO THE MILITARY, DID THEY HAVE A COMMENT ABOUT THE HARDWARE IN CONNECTION WITH THE MILITARY USE?

MR. DOWNEY: DO YOU RECALL THEM SAYING THAT THEY THOUGHT THE DEVICE WAS TOO BIG?

MR. DOWNEY: AND WAS THE DEVICE THAT YOU HAD TAKEN -- STRIKE THAT. WAS THE DEVICE THAT YOU HAD SHIPPED A 4.0 MONOBAY?

MR. DOWNEY: AND IN RESPONSE TO THAT FEEDBACK FROM THE MILITARY, DID THERANOS BEGIN TO WORK ON A SPECIALIZED MILITARY DEVICE?

MR. DOWNEY: AND DO YOU RECALL THE DATE OF THAT TRIP TO THE MILITARY BASE?

MR. DOWNEY: AND WAS THAT THE MACDILL AIR FORCE BASE IN TAMPA?

MR. DOWNEY: NOW, SHORTLY AFTER THAT TRIP, DID PERSONS IN THE MILITARY BEGIN TO COMMUNICATE WITH YOU SAYING THAT THEY WANTED TO DEPLOY THE DEVICE RIGHT AWAY?

MR. DOWNEY: LET ME SHOW YOU EXHIBIT 10472. IS THIS AN EMAIL FROM YOU TO VARIOUS MEMBERS OF THE MILITARY AND VARIOUS THERANOS PERSONNEL THAT IS PART OF A LONG CHAIN OF COMMUNICATIONS RELATED TO THE THERANOS CENTCOM PROJECT?

MR. DOWNEY: AND IF YOU LOOK AT THE SECOND EMAIL ON THE FIRST PAGE, THERE'S A COMMUNICATION FROM A JAMES SOMMER. DO YOU SEE THAT?

MR. DOWNEY: WHO IS JAMES SOMMER?

MR. DOWNEY: OKAY. SO HE SENT THIS IN FEBRUARY OF 2013; CORRECT?

MR. DOWNEY: AND THIS WAS JUST A COUPLE OF MONTHS AFTER THE LIMITED OBJECTIVE EXPERIMENT WAS USED; CORRECT?

MR. DOWNEY: THIS WAS JUST A COUPLE OF MONTHS AFTER THE LIMITED OBJECTIVE EXPERIMENT HAD BEEN APPROVED BY THE MILITARY?

MR. DOWNEY: LET ME JUST ASK YOU TO LOOK BACK AT EXHIBIT 10457, WHICH WAS JUST ADMITTED A MOMENT AGO, AND WE CAN DISPLAY THE FIRST PAGE OF THAT.

MR. DOWNEY: AND DO YOU SEE ON THE TOP THAT THAT'S AN EMAIL AT LEAST OF YOU FORWARDING IT TO MS. HOLMES IN DECEMBER; CORRECT?

MR. DOWNEY: AND THEN BELOW THAT THERE'S AN INDICATION THAT THE APPROVAL MAY HAVE BEEN IN NOVEMBER; CORRECT?

MR. DOWNEY: SO MR. SOMMER IS COMMUNICATING TO YOU IN FEBRUARY THAT THINGS WERE GETTING MESSED UP WITH THE SEQUESTRATION. DO YOU SEE THAT?

MR. DOWNEY: AND HE INDICATED THAT THAT WOULD AFFECT THE UPCOMING LIMITED OBJECTIVE EXPERIMENT; CORRECT?

MR. DOWNEY: AND HE SAID -- ESSENTIALLY ASKED YOU TO SHIP THE DEVICE SOON BECAUSE OTHERWISE HE WOULD NOT BE ABLE TO TRAVEL TO THEATRE WITH IT; CORRECT?

MR. DOWNEY: NOW, YOU RESPONDED TO THIS EMAIL THAT SAME DAY. DO YOU SEE THAT ABOVE?

MR. DOWNEY: OKAY. YOUR HONOR, I WOULD MOVE TO ADMIT 10472.

MR. DOWNEY: AND ON THE TOP OF THIS PAGE, DO YOU SEE THAT YOU'RE RESPONDING TO MR. SOMMER'S SUGGESTION THAT THE DEVICE HAD TO BE SHIPPED SOON. DO YOU SEE THAT?

MR. DOWNEY: I'D LIKE TO HIGHLIGHT THE PARAGRAPH THAT IS IN ITALICS. AND YOU TELL HIM IN THIS EMAIL, "AS PER OUR PREVIOUS DISCUSSIONS, THE 4S DEVICES WE ARE SHIPPING HAVE BEEN SPECIALLY BUILT FOR THE PURPOSES OF OUR LIMITED OBJECTIVE EXPERIMENT." CORRECT?

MR. DOWNEY: AND THAT WAS TRUE?

MR. DOWNEY: AND YOU SAID, "IN SO DOING WE HAVE HAD TO REVALIDATE AND RETEST EVERY ASPECTS OF THE DEVICE CONFIGURATION TO ENSURE THAT THESE SYSTEMS MEET OUR STANDARDS AND EXPECTATIONS." DO YOU SEE THAT?

MR. DOWNEY: AND YOU UNDERSTOOD FROM DR. YOUNG AND OTHERS THAT THAT WAS TRUE; CORRECT?

MR. DOWNEY: AND FROM MR. BALWANI; CORRECT?

MR. DOWNEY: OKAY. AND IN THE NEXT SENTENCE YOU SAY THAT "WE HAVE SIGNIFICANTLY ACCELERATED THERANOS'S PREVIOUSLY PLANNED RELEASE OF 4S IN ORDER TO MEET OUR OBJECTIVES FOR THIS PROGRAM." DO YOU SEE THAT?

MR. DOWNEY: AND THAT WAS TRUE AS FAR AS YOU KNEW?

MR. DOWNEY: HAD YOU BEEN FAMILIAR BEFORE WITH THE SCHEDULE FOR RELEASE OF THE MILITARY 4S?

MR. DOWNEY: WELL, DID YOU KNOW WHAT THE SCHEDULED RELEASE DATE ORIGINALLY WAS FOR THE 4S AT THERANOS?

MR. DOWNEY: OKAY. IF YOU SEE THE NEXT SENTENCE, YOU GO ON TO SAY, "FURTHER, WE HAVE ADDED ADDITIONAL FEATURES TO OUR USER INTERFACE CAPABILITIES FOLLOWING OUR VTC SESSION WITH MAJOR NELSON, AND WE HAVE BEEN INCORPORATING NEWLY RECEIVED INFORMATION FROM --" IS THAT LIEUTENANT COLONEL ROMERO?

MR. DOWNEY: "-- TO ENSURE THAT THE DEVICE IS ABLE TO OPERATE UNDER THE I.T. AND SECURITY REQUIREMENTS OF THE NETWORK IN THEATRE." AND WAS THAT A DESCRIPTION OF WHAT THE COMPANY HAD BEEN DOING AS A RESULT OF THE FEEDBACK THAT YOU GOT AT THE MEETING AT THE MACDILL AIR FORCE BASE?

MR. DOWNEY: AND YOU TOLD HIM THAT THESE PROCESSES GUIDED OUR DELIVERY TIMELINES. DO YOU SEE THAT?

MR. DOWNEY: AND THEN YOU -- YOU GO ON TO SAY IN THE LAST SENTENCE, "AS A RAPIDLY GROWING COMPANY, WE ARE" -- "AS A RAPIDLY GROWING COMPANY WE ARE MANAGING THESE TIMELINES AS BEST AS POSSIBLE WHILE MAKING SURE THAT THE INTEGRITY OF OUR PRODUCTS AND PROGRAM GOALS ARE NOT COMPROMISED." NOW, YOU COULD OBSERVE EVERY DAY THAT THIS WAS A RAPIDLY GROWING COMPANY; CORRECT?

MR. DOWNEY: AND YOU KNEW YOU WERE WORKING HARD IN CONNECTION WITH THIS PROJECT; CORRECT?

MR. DOWNEY: THIS IS A PROJECT THAT YOU WANTED -- PERSONALLY WOULD HAVE LIKED TO HAVE SEEN HAPPEN; CORRECT?

MR. DOWNEY: AND YOUR WORK HERE WAS DESIGNED TO BENEFIT BOTH THERANOS; CORRECT?

MR. DOWNEY: BUT ALSO MEMBERS OF THE MILITARY WHO MIGHT BENEFIT FROM THIS DEPLOYMENT; CORRECT?

MR. DOWNEY: AND YOU PROCEEDED IN GOOD FAITH IN TRYING TO DO THAT; CORRECT?

MR. DOWNEY: ALL RIGHT. NOW, DID YOU HAVE FURTHER DISCUSSIONS AFTER THIS EXCHANGE WITH MEMBERS OF THE MILITARY ABOUT DEPLOYING THE 4S DEVICE AT CENTCOM?

MR. DOWNEY: AND I THINK WE SAW YESTERDAY THAT THERE WAS AN EXCHANGE ABOUT REQUESTING THAT THE DEPLOYMENT BE DEFERRED UNTIL 2014. DO YOU RECALL THAT?

MR. DOWNEY: OKAY. LET ME ASK YOU TO LOOK BACK AT EXHIBIT 1027. AND IF YOU SEE ON THE TOP HERE, THIS IS AN EMAIL, DRAFT EMAIL THAT YOU SENT TO MS. HOLMES; CORRECT?

MR. DOWNEY: AND YOU PROPOSED A DATE, BASED ON YOUR CONVERSATION WITH DR. ANEKAL, OF AUGUST 1ST FOR THE DEPLOYMENT; CORRECT?

MR. DOWNEY: AND WAS THAT DEPLOYMENT THEN DEFERRED UNTIL AUGUST 1ST OF 2014?

MR. DOWNEY: CORRECT. BUT AS OF AUGUST 1ST, 2013, WAS THE DATE OF DEPLOYMENT DEFERRED UNTIL AUGUST 1ST, 2014?

MR. DOWNEY: AND DID YOU CONTINUE TO WORK IN CONNECTION WITH THIS PROGRAM AFTER AUGUST 1ST OF 2013?

MR. DOWNEY: AND YOU WERE ALSO WORKING ON A NUMBER OF ISSUES RELATED TO THE RETAIL LAUNCH; CORRECT?

MR. DOWNEY: AND YOU WERE WORKING ON A NUMBER OF ISSUES RELATED TO RAISING MONEY FOR INVESTORS; CORRECT?

MR. DOWNEY: WELL, YOU HAD SOME DUTIES THAT TOOK TIME FROM YOUR CALENDAR, DIDN'T YOU?

MR. DOWNEY: AND YOU HAD A NUMBER OF OTHER DUTIES THAT ALSO WERE IMPORTANT; CORRECT?

MR. DOWNEY: AND THIS WAS AN ENVIRONMENT THAT WAS VERY HECTIC; CORRECT?

MR. DOWNEY: AND I THINK YOU'VE TESTIFIED ON DIRECT THAT YOU OBSERVED MS. HOLMES WORKING VERY HARD EVERY DAY. CORRECT?

MR. DOWNEY: BUT YOU ALSO WERE WORKING VERY HARD EVERY DAY; CORRECT?

MR. DOWNEY: OKAY. LET'S TALK FOR A FEW MINUTES ABOUT THE RELATIONSHIP BETWEEN THERANOS AND THE SPECIAL OPERATIONS COMMAND. SPECIAL OPERATIONS COMMAND IS THE UNIFIED COMMAND FOR ALL OF THE MILITARY SERVICES SPECIAL OPERATIONS; CORRECT?

MR. DOWNEY: OKAY. LET ME ASK YOU TO LOOK BACK AT EXHIBIT 504, WHICH IS IN EVIDENCE AND WHICH MR. BOSTIC SHOWED YOU DURING HIS EXAMINATION. IF YOU LOOK AT THE TOP OF THE EMAIL ON PAGE 1, WHICH IS BLOWN UP ON YOUR SCREEN, THIS IS A DIALOGUE FROM A LITTLE BIT EARLIER IN TIME BETWEEN SPECIAL OPERATIONS AND THERANOS; CORRECT?

MR. DOWNEY: THIS IS FROM JANUARY OF 2012; CORRECT?

MR. DOWNEY: AND IN THE FIRST PARAGRAPH OF THIS DOCUMENT, YOU ASKED A REPRESENTATIVE OF SOCOM TO PROVIDE A COMPREHENSIVE LIST OF ALL OF THE ASSAYS THAT SOCOM PLANNED TO TEST IN CONNECTION WITH ITS EVALUATION OF THERANOS DEVICES; CORRECT?

MR. DOWNEY: AND WHY DID YOU NEED THAT INFORMATION?

MR. DOWNEY: LET ME ASK YOU TO LOOK AT EXHIBIT 13977, WHICH IS IN THE NOTEBOOK THAT I JUST GAVE YOU.

MR. DOWNEY: IS THIS AN EXCHANGE OF EMAILS BETWEEN YOURSELF AND REPRESENTATIVES OF THE MILITARY RELATED TO POTENTIALLY DEPLOYING THERANOS EQUIPMENT FOR SPECIAL OPERATIONS?

MR. DOWNEY: YOUR HONOR, I MOVE TO ADMIT 13977.

MR. DOWNEY: I'D LIKE TO GO TO THE BOTTOM OF PAGE 2.

MR. DOWNEY: THIS IS A DOCUMENT BEING FORWARDED TO YOU BY AN INDIVIDUAL NAMED NATHAN JORDAN. DO YOU SEE THAT?

MR. DOWNEY: AND DO YOU KNOW WHO THAT IS?

MR. DOWNEY: A MILITARY --

MR. DOWNEY: A MILITARY CONTRACTOR. AND HE'S FORWARDING YOU HERE A COUNTERSIGNED MODIFICATION FOR YOUR RECORDS; CORRECT?

MR. DOWNEY: AND DOES THAT REFER TO A MODIFICATION OF THE AGREEMENT THAT HAD BEEN ENTERED INTO BETWEEN SPECIAL OPERATIONS AND -- SPECIAL OPERATIONS COMMAND AND THERANOS TO CONDUCT AN EXPERIMENT?

MR. DOWNEY: OKAY. IF YOU RECALL THE DOCUMENT THAT I SHOWED YOU A MOMENT AGO, IT WAS DATED JANUARY 2012; CORRECT?

MR. DOWNEY: AND THE DOCUMENT WAS STILL BEING MODIFIED MORE THAN A YEAR LATER; CORRECT?

MR. DOWNEY: STRIKE THAT. AND THE TERMS OF THE RELATIONSHIP WERE STILL BEING NEGOTIATED MORE THAN A YEAR LATER; CORRECT?

MR. DOWNEY: SO THIS WAS IN FEBRUARY OF 2013; CORRECT?

MR. DOWNEY: AND IF YOU GO TO THE EMAIL ABOVE THAT -- I'M SORRY, THE NEXT EMAIL UP TOWARDS THE TOP OF THE PAGE. THIS IS AN EMAIL SENT TO YOU BY STEPHANIE ELDER. WHO WAS STEPHANIE ELDER?

MR. DOWNEY: OKAY. AND SO IN APRIL OF 2013, SHE ASKED YOU FOR AN UPDATE ON WHERE YOU ARE WITH THE DEVICES; CORRECT?

MR. DOWNEY: AND THIS IS ABOUT TWO MONTHS AFTER THE MODIFICATION HAD BEEN SIGNED; CORRECT?

MR. DOWNEY: OKAY. IF YOU GO TO THE EMAIL ABOVE THAT. DO YOU SEE THAT YOU RESPONDED TO HER SAYING, "THANK YOU FOR YOUR EMAIL; I HOPE YOU ARE DOING WELL. WE HAVE BEEN PREPARING FOR THIS AND I AM HOPING TO CONNECT WITH YOU, IF YOU THINK IT WOULD BE OF VALUE, TO DISCUSS THE PLANS FOR INITIATING OUR PROGRAM." AND YOU GIVE HER A PHONE NUMBER; CORRECT?

MR. DOWNEY: AND IF YOU CAN GO TO THE EMAIL ABOVE THAT. THIS IS ABOUT FIVE DAYS LATER. YOU SAY, "I JUST WANTED TO MAKE SURE THAT YOU SAW MY EMAIL." CORRECT?

MR. DOWNEY: AND YOU WANTED TO MAKE SURE YOU HEARD FROM HER; CORRECT?

MR. DOWNEY: AND LET'S GO TO THE NEXT EMAIL. THIS IS ABOUT A MONTH LATER; CORRECT?

MR. DOWNEY: AND YOU SENT ANOTHER EMAIL TO MS. ELDER; CORRECT?

MR. DOWNEY: AND YOU ASKED HER AGAIN TO CONNECT; CORRECT?

MR. DOWNEY: AND IF YOU GO TO THE EMAIL ABOVE THAT, YOU FOLLOWED UP AGAIN IN JULY; CORRECT?

MR. DOWNEY: SO YOU WERE TRYING TO CONNECT WITH MS. ELDER ABOUT THE DETAILS OF DEPLOYING A DEVICE, AND AT LEAST IN THIS PERIOD SHE WAS NOT BEING RESPONSIVE; CORRECT?

MR. DOWNEY: OKAY. ULTIMATELY, I THINK YOU TESTIFIED YESTERDAY, THAT YOU WERE ABLE TO SHIP SOME DEVICES TO SOCOM; CORRECT?

MR. DOWNEY: AND ARE THOSE THE MODIFIED DEVICES THAT YOU DESCRIBED EARLIER TODAY THAT WERE MODIFIED PER MR. BALWANI'S DIRECTION?

MR. DOWNEY: OKAY. WERE THEY 4S DEVICES?

MR. DOWNEY: AND DID SOCOM PERFORM THE EXPERIMENT WITH THOSE DEVICES?

MR. DOWNEY: DID YOU EVER HEAR FROM SOCOM AS TO WHY?

MR. DOWNEY: ALL RIGHT. I WANT TO TURN TO A DIFFERENT TOPIC. DO YOU RECALL DISCUSSING YESTERDAY WITH MR. BOSTIC A NUMBER OF DEMONSTRATIONS THAT THERANOS DID FOR VARIOUS VIP'S?

MR. DOWNEY: AND I THINK YOU TESTIFIED THAT YOU PLAYED SOME ROLE WITH REGARD TO THOSE DEMONSTRATIONS; CORRECT?

MR. DOWNEY: YOU WERE A COORDINATOR OF THE LOGISTICS?

MR. DOWNEY: OKAY. AND YOU WOULD DO THINGS LIKE MAKE SURE THE ROOM WAS SET UP; CORRECT?

MR. DOWNEY: AND YOU WOULD MAKE SURE THAT THE ENGINEERS HAD GOTTEN THE DEVICES INTO THE ROOM THAT MR. BALWANI OR MS. HOLMES EXPECTED; CORRECT?

MR. DOWNEY: AND YOU WOULD WORK WITH OTHERS ON THE TEAM AT THERANOS TO ENSURE THAT THE DEMONSTRATION WAS READY TO GO; CORRECT?

MR. DOWNEY: AND SOMETIMES IN A PARTICULAR DEMONSTRATION THERE MIGHT BE AS MANY AS 15 TO 20 PEOPLE INVOLVED; CORRECT?

MR. DOWNEY: LET ME STRIKE THAT. I THINK WE SAW YESTERDAY SOME EMAILS BETWEEN YOU AND A NUMBER OF PEOPLE AT THERANOS WHO WERE SCIENTISTS RELATED TO THE DEMONSTRATIONS; CORRECT?

MR. DOWNEY: AND ANY NUMBER OF THOSE SCIENTISTS MIGHT BE INVOLVED IN ONE WAY OR ANOTHER WITH THE DEMONSTRATION; CORRECT?

MR. DOWNEY: OKAY. AND DR. YOUNG WAS THE TECHNICAL LEAD FOR THE DEMONSTRATIONS; CORRECT?

MR. DOWNEY: OKAY. AND HE WOULD, HE WOULD WORK WITH THE SCIENTISTS TO GET READY FOR THE DEMONSTRATION; CORRECT?

MR. DOWNEY: AND IF ANY SCIENTIFIC OR TECHNICAL ISSUES AROSE, HE WAS THE PERSON WHO WAS THERE TO ADDRESS THEM; CORRECT?

MR. DOWNEY: IN SOME INSTANCES IT MIGHT BE SOMEBODY WORKING UNDER DR. YOUNG; CORRECT?

MR. DOWNEY: OKAY. SO THERE MIGHT BE AN EXAMPLE OF AN INSTANCE WHERE THERE WAS AN ISSUE WITH RESPECT TO THE HARDWARE AND YOU TALK TO A HARDWARE ENGINEER; CORRECT?

MR. DOWNEY: AND AT THE END, I THINK -- DID YOU SAY THAT DR. YOUNG WOULD VERIFY THE SAMPLE? OR WHAT WAS THE TERMINOLOGY THAT YOU USED?

MR. DOWNEY: NOW, NOT ALL OF THE DEMONSTRATIONS WERE THE SAME; CORRECT?

MR. DOWNEY: SOME TOOK PLACE IN LOCATIONS THAT WERE AWAY FROM THERANOS; RIGHT?

MR. DOWNEY: MS. HOLMES AND OTHERS MIGHT TRAVEL TO SOMEONE ELSE'S OFFICE AND PERFORM A DEMONSTRATION THERE; CORRECT?

MR. DOWNEY: AND SOMETIMES THE DEMONSTRATION WOULD BE AT THERANOS'S HEADQUARTERS; CORRECT?

MR. DOWNEY: AND WERE THERE INSTANCES WHERE EVEN SOME INDIVIDUALS WANTED TO GO TO THE WALGREENS STORE AND HAVE A DEMONSTRATION THERE?

MR. DOWNEY: SO THOSE WHO WENT TO WALGREENS GOT AN ACTUAL CLINICAL TEST; CORRECT?

MR. DOWNEY: THEY, THEY MIMICKED WHAT ANY PATIENT COMING IN WHO WANTED A BLOOD TEST FROM WALGREENS WOULD GET?

MR. DOWNEY: I'D LIKE TO ASK YOU TO LOOK AT EXHIBIT 7244.

MR. DOWNEY: IS THIS AN EMAIL EXCHANGE BETWEEN SEVERAL INDIVIDUALS AT THERANOS, INCLUDING YOURSELF, RELATED TO A DEMONSTRATION THAT WAS DONE IN 2012?

MR. DOWNEY: YOUR HONOR, I MOVE TO ADMIT 7244.

MR. DOWNEY: WERE RECORDS RELATED TO THE DEMONSTRATIONS THAT WERE PERFORMED AT THERANOS PREPARED CONTEMPORANEOUS WITH THE DEMONSTRATION?

MR. DOWNEY: SURE. WERE -- SOMETIMES DEMONSTRATIONS WERE PERFORMED AT THERANOS; CORRECT?

MR. DOWNEY: AND THERE WOULD BE DETAILS RELATED TO THE LOGISTICS OF SETTING UP THE DEMONSTRATION; CORRECT?

MR. DOWNEY: AND THERE MIGHT BE DETAILS ABOUT MAKING ARRANGEMENTS AFTER THE DEMONSTRATION WAS PERFORMED; CORRECT?

MR. DOWNEY: AND INDIVIDUALS AT THERANOS WOULD COMMUNICATE WITH EACH OTHER BY EMAIL OFTEN ABOUT THAT; CORRECT?

MR. DOWNEY: AND THOSE COMMUNICATIONS WOULD BE AROUND THE SAME TIME AS THE DEMONSTRATION; CORRECT?

MR. DOWNEY: AND EMAILS AT THERANOS WERE PRESERVED IN THE THERANOS SYSTEM; CORRECT?

MR. DOWNEY: OKAY. YOUR HONOR, I MOVE TO ADMIT 7244.

MR. DOWNEY: WELL, IT'S A COUPLE WEEKS AFTER BECAUSE IT'S A REPORT BACK FROM AN INDIVIDUAL WHO PARTICIPATED.

MR. DOWNEY: SURE.

MR. DOWNEY: WELL, FIRST OF ALL, LET ME ASK YOU, WAS THIS EMAIL COMMUNICATED TO MS. HOLMES?

MR. DOWNEY: YOUR HONOR, UNDER 803 I THINK I'M ENTITLED TO ADMIT IT.

MR. DOWNEY: LET ME ASK YOU TO LOOK AT THE BOTTOM HALF OF THE FIRST PAGE. DO YOU SEE THIS IS AN EMAIL FROM MR. BALWANI IN 2012 ABOUT A DEMONSTRATION; CORRECT?

MR. DOWNEY: AND IF YOU LOOK AT THE SUBJECT, IT'S ABOUT A DEMONSTRATION THAT WAS DONE IN THE MIDDLE OF JULY IN 2012 IN CHICAGO. DO YOU SEE THAT?

MR. DOWNEY: AND THAT WAS ABOUT A LITTLE OVER A YEAR BEFORE THE RETAIL LAUNCH IN WALGREENS; CORRECT?

MR. DOWNEY: AND THE REFERENCE TO CHICAGO CAUSES ME TO ASK, WAS THIS A DEMONSTRATION DONE FOR WALGREENS EXECUTIVES?

MR. DOWNEY: AND DO YOU SEE THAT MR. BALWANI WAS REPORTING BACK ON INFORMATION THAT HE LEARNED ABOUT THE DEMONSTRATION IN THE FIRST PARAGRAPH OF HIS EMAIL AT THE BOTTOM?

MR. DOWNEY: AND DO YOU SEE THAT HE'S COMMUNICATING THAT TO DR. YOUNG; CORRECT?

MR. DOWNEY: AND TO VARIOUS REPRESENTATIVES OF ASSAY TEAMS WITHIN THE COMPANY; CORRECT?

MR. DOWNEY: AND ALSO TO PERSONNEL WHO WORKED ON THE HARDWARE AT THE COMPANY; CORRECT?

MR. DOWNEY: AND TO THE CLINICAL, THEN CLINICAL LAB DIRECTOR; CORRECT?

MR. DOWNEY: AND HAD ALL OF THOSE INDIVIDUALS BEEN INVOLVED IN ONE WAY OR ANOTHER WITH PREPARING FOR THIS DEMONSTRATION?

MR. DOWNEY: OKAY. BUT OFTEN PERSONNEL, THE PERSONNEL IN ALL OF THOSE CATEGORIES WOULD BE INVOLVED IN PREPARING FOR A DEMONSTRATION?

MR. DOWNEY: BUT YOU DO RECALL OCCASIONS WHERE PERSONNEL FROM THE ASSAY TEAM, THE HARDWARE TEAM, DR. YOUNG, AND OTHER SCIENTISTS WERE INVOLVED; CORRECT?

MR. DOWNEY: ALL RIGHT. IF YOU SEE THE REPORT THAT MR. BALWANI GIVES IN THE PARAGRAPH THAT BEGINS, "I HEARD BACK," HE REPORTS THAT HE HEARD BACK FROM AN EXECUTIVE THAT THEY HAD PERFORMED A DEMONSTRATION ON, AND HE REPORTS THAT THE EXECUTIVE'S RESULTS FROM THE DEMONSTRATION WERE IDENTICAL TO RESULTS THAT THE EXECUTIVE GOT FROM A DOCTOR. DO YOU SEE THAT?

MR. DOWNEY: NOW, YOU WERE SHOWN YESTERDAY A NUMBER OF DOCUMENTS THAT RELATED TO DEMONSTRATIONS WHERE THERE WAS A DISCUSSION BETWEEN INDIVIDUALS AT THERANOS RELATED TO SOME DISCREPANCY OR UNCERTAINTY ABOUT THE RESULTS. DO YOU RECALL THAT?

MR. DOWNEY: BUT DOZENS OF DEMONSTRATIONS WERE PERFORMED AT THERANOS; CORRECT?

MR. DOWNEY: AND MANY OF THEM RESULTED IN REPORTS BACK FROM THOSE WHO RECEIVED THE DEMONSTRATION THAT THE RESULTS WERE SIMILAR OR IDENTICAL TO THOSE THAT THEY RECEIVED FROM OTHER BLOOD TESTS?

MR. DOWNEY: YOU DID NOT PARTICIPATE IN THAT?

MR. DOWNEY: OKAY. NOW, AS WELL AS BEING AT DIFFERENT LOCATIONS -- BY THE WAY, WITH REGARD TO THE DEMONSTRATION THAT WE JUST LOOKED AT, THAT'S A DEMONSTRATION WHERE THE DEVICE WAS TAKEN TO CHICAGO; CORRECT?

MR. DOWNEY: AND THAT'S A DEMONSTRATION THAT WOULD HAVE BEEN RUN WHERE THE BLOOD WAS DRAWN FROM THE EXECUTIVE; CORRECT?

MR. DOWNEY: OKAY. AND THEN THAT WOULD BE INSERTED INTO A CARTRIDGE; CORRECT?

MR. DOWNEY: AND THE CARTRIDGE WOULD BE INSERTED INTO THE ANALYZER; CORRECT?

MR. DOWNEY: AND THE BLOOD TEST RESULTS WOULD BE GENERATED FROM THAT; CORRECT?

MR. DOWNEY: AND THAT'S ONE FORM OF DEMONSTRATION; CORRECT? THERE ARE OTHER FORMS OF DEMONSTRATION; CORRECT?

MR. DOWNEY: AT SOME POINTS PEOPLE WOULD COME TO THERANOS AND THEY WOULDN'T WANT TO HAVE THEIR BLOOD DRAWN, BUT THEY WOULD WANT TO SEE HOW THE DEVICE WORKED; CORRECT?

MR. DOWNEY: AND THEY MIGHT BE INTERESTED IN THE INTERFACE OF THE DEVICE, FOR EXAMPLE?

MR. DOWNEY: AND CAN YOU DESCRIBE TO US WHAT KIND OF INFORMATION WAS CONVEYED BY THE INTERFACE OF THE THERANOS DEVICE?

MR. DOWNEY: OKAY. AND WOULD INFORMATION ABOUT THE PATIENT GETTING THE BLOOD TEST BE ENTERED INTO THE USER INTERFACE, FOR EXAMPLE?

MR. DOWNEY: AND MEDICAL HISTORY; CORRECT?

MR. DOWNEY: OKAY. AND SOME INDIVIDUALS WOULD JUST WANT TO SEE HOW THAT INTERFACE WORKED; CORRECT?

MR. DOWNEY: BUT IF YOU RAN THE DEVICE WITHOUT BLOOD IN IT, THE DEVICE WOULD AUTOMATICALLY SHUT DOWN; CORRECT?

MR. DOWNEY: OKAY. WELL, WAS THE -- WAS THERE A PROTOCOL THAT NORMALLY WAS IN PLACE ON THE DEVICE, REFERRED TO AS THE NORMANDY PROTOCOL?

MR. DOWNEY: WELL, LET'S TALK ABOUT THE NORMANDY PROTOCOL FIRST AND THEN WE'LL TALK ABOUT THE OTHER PROTOCOLS.

MR. DOWNEY: UNDER THE NORMANDY PROTOCOL, WHAT WOULD HAPPEN IF YOU INSERTED A CARTRIDGE INTO A DEVICE BUT THERE WAS NO BLOOD SAMPLE IN IT?

MR. DOWNEY: OKAY. IF YOU, IF YOU USED THE NULL PROTOCOL SOFTWARE, WHAT WOULD HAPPEN IF YOU INSERTED A CARTRIDGE AND THERE WAS NO BLOOD SAMPLE IN IT?

MR. DOWNEY: BUT NO TEST WOULD BE PERFORMED; CORRECT?

MR. DOWNEY: AND IN SOME INSTANCES, I THINK WE DISCUSSED A MOMENT AGO, INDIVIDUALS WOULD COME AND THEY WOULDN'T WANT THEIR BLOOD DRAWN; CORRECT?

MR. DOWNEY: AND THE NULL PROTOCOL COULD BE USED IN CONNECTION WITH THOSE DEMONSTRATIONS; CORRECT?

MR. DOWNEY: LET ME SHOW YOU IN THE GOVERNMENT'S BINDER AN EXHIBIT THAT WAS ADMITTED YESTERDAY, WHICH IS EXHIBIT 959.

MR. DOWNEY: IF YOU GO TO WHERE THE EMAIL CHAIN STARTS ON THE SECOND PAGE, THIS APPEARS TO BE YOU SETTING UP -- DIRECTING THE SETUP OF EQUIPMENT BASED ON DIRECTIONS YOU HAD GOTTEN FROM EITHER MS. HOLMES OR MR. BALWANI; CORRECT?

MR. DOWNEY: AND YOU'RE ASKING THAT CERTAIN THERANOS DEVICES BE SET UP IN AN INTERVIEW ROOM; CORRECT?

MR. DOWNEY: AND THESE COMMUNICATIONS WERE IN CONNECTION WITH A, WITH A PLANNED DEMONSTRATION; CORRECT?

MR. DOWNEY: AND IF YOU LOOK AT THE EMAIL TOWARDS THE -- THE SECOND EMAIL, YOU'RE ASKING, SHOULD WE USE THE NORMANDY APP OR THE DEMO APP; CORRECT?

MR. DOWNEY: AND THEN IN THE NEXT -- AND THEN IN THE SECOND TO THE LAST PARAGRAPH, YOU SAY, "IF WE RUN THE NULL PROTOCOL, WE DON'T NEED THE CARTRIDGE TO BE AS TIGHT AS IT WAS LAST TIME IN THE CONTEXT OF INSERTING THE COLLECTION CONTAINERS." DO YOU SEE THAT?

MR. DOWNEY: AND THEN DO YOU RECALL IN THE EMAIL CHAIN ABOVE MICHAEL CRAIG RECOMMENDED TO YOU THAT YOU USE THE DEMO APP; CORRECT?

MR. DOWNEY: NONE OF THIS CONVERSATION WAS ABOUT PLAYING A TRICK ON THE PEOPLE GETTING A DEMO, WAS IT?

MR. DOWNEY: THIS WAS -- THIS CONVERSATION WAS ABOUT THE VARIOUS THINGS THAT COULD HAPPEN WHEN PEOPLE CAME TO GET A DEMONSTRATION AT THERANOS; CORRECT?

MR. DOWNEY: SOMEONE MIGHT SHOW UP AND SAY, I DON'T WANT TO HAVE MY BLOOD DRAWN TODAY; CORRECT?

MR. DOWNEY: SOMEBODY MIGHT SHOW UP AND SAY, I DO WANT TO HAVE MY BLOOD DRAWN; CORRECT?

MR. DOWNEY: RIGHT. AND SO YOU NEEDED TO BE PREPARED FOR ALL OF THESE DIFFERENT SCENARIOS; CORRECT?

MR. DOWNEY: AND THERE WERE DIFFERENT PROTOCOLS DESIGNED FOR ALL OF THOSE DIFFERENT SCENARIOS; CORRECT?

MR. DOWNEY: BECAUSE AT THE END OF THE DAY, YOU WERE WORKING AS HARD AS YOU COULD TO DEMONSTRATE THE TECHNOLOGY IN THE MOST APPEALING WAY POSSIBLE; CORRECT?

MR. DOWNEY: BUT YOU WERE NOT TRYING TO DECEIVE ANYBODY IN THIS DEMONSTRATION PROCESS, WERE YOU?

MR. DOWNEY: AND YOU DID NOT UNDERSTAND THAT ANYONE ELSE AT THERANOS WAS TRYING TO DECEIVE ANYONE ELSE; CORRECT?

MR. DOWNEY: ALL RIGHT. LET ME DIRECT YOUR ATTENTION TO THE TOP OF THIS EMAIL.

MR. DOWNEY: AND THERE'S A COMMUNICATION FROM DR. ANEKAL TO YOU. DO YOU SEE THAT?

MR. DOWNEY: AND HE SAYS, IF WE BLOW UP THE FIRST PARAGRAPH OF THAT EMAIL, HE SAYS, "DAN, THE ASSAY TEAMS ARE PLANNING ON USING THE 3.5 DEVICES TOMORROW, BUT WE CAN MOVE ONE OF THE R&D UNITS IF IT'S JUST FOR SHOW-AND-TELL." DO YOU SEE THAT?

MR. DOWNEY: AND HIS REFERENCE TO SHOW-AND-TELL THERE IS A REFERENCE TO AN INSTANCE WHERE SOMEONE MIGHT JUST WANT TO SEE THE DEVICE; CORRECT?

MR. DOWNEY: LET ME ASK YOU TO LOOK AT EXHIBIT 7243.

MR. DOWNEY: IS THIS AN EMAIL BETWEEN MS. HOLMES, YOURSELF, AND DR. YOUNG REGARDING SETTING UP A DEMONSTRATION IN JULY AND AUGUST OF 2012?

MR. DOWNEY: YOUR HONOR, I MOVE THE ADMISSION OF 7243.

MR. DOWNEY: IF YOU GO TO THE EMAIL AT THE VERY BOTTOM, DO YOU SEE THAT? MS. HOLMES ASKS DR. YOUNG, "DO WE HAVE A COUPLE OF MINILABS THAT ARE FULLY ASSEMBLED WITH FUNCTIONAL SCREENS/ELECTRONICS THAT ARE EASY TO SHOW A CLIENT TOMORROW MIDDAY?" AND THEN IF YOU GO ABOVE THAT, DR. YOUNG SAYS, "YES, WE HAVE FULLY FUNCTIONAL MINILABS. I WILL MAKE SURE THE DISPLAY IS READY." AND THEN IN THE NEXT PARAGRAPH OF THAT, HE ASKS, WHERE IT BEGINS, "ALSO, DO YOU WANT ANY TESTS RUN ON THE MACHINE, OR JUST HAVE IT POWERED UP WITH THE DISPLAY SHOWING SOMETHING INTERESTING?" OKAY. AND IF YOU GO -- DO YOU SEE THAT?

MR. DOWNEY: AND IF YOU GO TO THE EMAIL ABOVE THAT, MS. HOLMES RESPONDS, "WE CAN PUT THEM IN AN INTERVIEW ROOM." CORRECT?

MR. DOWNEY: AND SHE SAYS, "IF WE CAN EASILY HAVE THEM READY TO ACCEPT CARTRIDGES WE SHOULD. ALSO YES ON THE SCREEN... WE SHOULD NOT DO A LOT OF EXTRA WORK FOR THIS." DO YOU SEE THAT?

MR. DOWNEY: AND IF YOU GO ABOVE THAT, DR. YOUNG SAYS -- I'M SORRY, TO THE EMAIL FROM DR. YOUNG, HE SAYS HE WILL GET IT SET UP IN THAT WAY, BUT HE SAYS, WE ARE NOT READY TO RUN WHOLE BLOOD SAMPLES IN THE MINILAB THAT HE'S SETTING UP; CORRECT? DO YOU SEE THAT?

MR. DOWNEY: AND DO YOU SEE THE EMAIL FROM MS. HOLMES? SHE SAYS, "WE'RE NOT RUNNING SAMPLES - JUST DEMONSTRATING THE HARDWARE." DO YOU SEE THAT?

MR. DOWNEY: NOW, I TAKE IT THAT YOU HAD A GENERAL SENSE OF WHAT THE ENGINEERING WAS RELATED TO -- WELL, STRIKE THAT. YOU'RE NOT AN ENGINEER; CORRECT?

MR. DOWNEY: AND YOU'RE NOT INTIMATELY FAMILIAR WITH ALL OF THE DEVELOPMENT OF THE SOFTWARE IN CONNECTION WITH THESE PROTOCOLS; CORRECT?

MR. DOWNEY: AND THAT WAS DONE BY MICHAEL CRAIG AND HIS TEAM; CORRECT?

MR. DOWNEY: OKAY. NOW, WE'VE BEEN TALKING ABOUT THE SCENARIO WHERE PEOPLE DON'T WANT TO GET A BLOOD TEST, BUT THERE WERE TIMES WHEN PEOPLE CAME IN AND SAID, I DO WANT TO GET A BLOOD TEST; CORRECT?

MR. DOWNEY: AND THAT YOU REFERRED, WHEN YOU WERE TESTIFYING ON DIRECT YESTERDAY, TO TWO DIFFERENT SCENARIOS WHEN SOMEONE WANTED TO GET THEIR BLOOD TESTED; CORRECT?

MR. DOWNEY: OKAY. WELL, ONE WAS THAT YOU COULD ACTUALLY TEST THE SAMPLE ON THE DEVICE; CORRECT?

MR. DOWNEY: AND THAT WAS DONE IN MANY INSTANCES; CORRECT?

MR. DOWNEY: AND THE OTHER WAS TO TEST THE SAMPLE IN THE THERANOS LABORATORY; CORRECT?

MR. DOWNEY: AND THAT, BY THE WAY, WAS NOT THE CLINICAL LABORATORY, WAS IT?

MR. DOWNEY: OKAY. BUT IT WAS DONE FOR PURPOSES OF RESEARCH AND DEVELOPMENT; CORRECT?

MR. DOWNEY: OKAY. NOW, YOU TALKED AT SOME LENGTH YESTERDAY ABOUT AN AUGUST 2013 DEMONSTRATION THAT WAS PERFORMED FOR WALGREENS EXECUTIVES. DO YOU REMEMBER THAT?

MR. DOWNEY: AND THAT WAS SHORTLY BEFORE THE LAUNCH OF RETAIL SERVICES AT WALGREENS?

MR. DOWNEY: AND IN CONNECTION WITH THIS DEMONSTRATION, THERE WERE A NUMBER OF EXECUTIVES MEETING WITH MS. HOLMES AND MR. BALWANI; CORRECT?

MR. DOWNEY: AND A DEMONSTRATION WAS GOING TO BE PERFORMED FOR THEM; CORRECT?

MR. DOWNEY: AND YOU WERE INVOLVED IN HELPING TO SET UP AND PREPARE THAT DEMONSTRATION; CORRECT?

MR. DOWNEY: LET ME SHOW YOU AGAIN 959. IF YOU WOULD LOOK AT THE SECOND -- AT THE EMAIL ON PAGE 2, LOOK AT THE FIRST PARAGRAPH AGAIN. YOU'RE DIRECTING THE EQUIPMENT THAT YOU WERE REQUESTING BE PUT IN THE INTERVIEW RAN. DO YOU SEE THAT?

MR. DOWNEY: AND THEN YOU DIRECT WHAT KIND OF PROTOCOLS ARE GOING TO BE RUN ON EACH DEVICE; CORRECT?

MR. DOWNEY: AND YOU ALSO SAY IN THE FOURTH PARAGRAPH, "MOST LIKELY WE WILL COLLECT A NUMBER OF SAMPLES AND STORE THEM IN THE SHIPPING CONTAINER LIKE THE LAST MEETING WE HAD, AND THEN PROCESS THEM SEPARATELY IN THE LAB." CORRECT?

MR. DOWNEY: AND THAT'S REFERRING TO A PRIOR DEMONSTRATION THAT YOU DID WHERE BLOOD SAMPLES WERE COLLECTED AT A MEETING; CORRECT?

MR. DOWNEY: AND THE SAMPLES, WHEN THEY WERE TAKEN, WERE PLACED IN THE TINY LITTLE NANOTAINER; CORRECT?

MR. DOWNEY: AND THE NANOTAINER WAS PLACED IN THE SHIPPING CONTAINER BOX; CORRECT?

MR. DOWNEY: AND THE BOX WAS TAKEN AND TAKEN TO THE LAB AND TESTING WAS PERFORMED THERE; CORRECT?

MR. DOWNEY: AGAIN, THAT WAS NOT DONE TO DECEIVE ANYONE, WAS IT?

MR. DOWNEY: YOU KNEW AT THE STAGE THAT THIS MEETING WAS TAKING PLACE THAT THE RELATIONSHIP BETWEEN THERANOS AND WALGREENS HAD CHANGED FROM ITS ORIGINAL CONCEPTION OF DEPLOYING DEVICES IN STORES; CORRECT? LET ME ALTER THAT. DID YOU -- YOU KNEW THAT WHEN TESTS WERE TO BE DONE AT WALGREENS STORES, THEY WOULD NOT BE PERFORMED ON SITE AT THE WALGREENS STORES; CORRECT?

MR. DOWNEY: INSTEAD WHEN A TEST WAS DONE AT A WALGREENS STORE, THE BLOOD WOULD BE TAKEN INTO THE NANOTAINER; CORRECT?

MR. DOWNEY: PLACED INTO A CARTRIDGE; CORRECT?

MR. DOWNEY: PLACED INTO A --

MR. DOWNEY: SORRY, PLACED INTO A NANOTAINER; CORRECT?

MR. DOWNEY: AND THE NANOTAINER WAS PLACED IN THE SHIPPING CONTAINER; CORRECT?

MR. DOWNEY: AND SHIPPED TO THERANOS'S CENTRAL LAB; CORRECT?

MR. DOWNEY: AND SO WATCHING THIS DEMONSTRATION IN AUGUST OF 2013 IN THE CONFERENCE ROOM AT THERANOS WOULD MIMIC THE PROCESS THAT WAS ABOUT TO HAPPEN AT WALGREENS IN A FEW WEEKS; CORRECT?

MR. DOWNEY: RIGHT.

MR. DOWNEY: IF YOU WATCHED THAT PROCESS, YOU COULD SEE EXACTLY HOW IT WAS GOING TO WORK FROM THE PERSPECTIVE OF A PATIENT AT WALGREENS; CORRECT?

MR. DOWNEY: OKAY. NOW, DURING THE DEMONSTRATION, DO YOU RECALL DISCUSSING WITH MR. BOSTIC THAT YOU ARE THE PERSON WHO ACTUALLY BROUGHT THE SAMPLES BACK TO THE LAB; CORRECT?

MR. DOWNEY: AND DO YOU RECALL HOW MANY OF THE EXECUTIVES ACTUALLY GAVE A BLOOD SAMPLE AT THAT MEETING?

MR. DOWNEY: AND DID YOU ACTUALLY DRAW THEIR BLOOD?

MR. DOWNEY: OKAY. ON SOME OCCASIONS, EVEN YOU WOULD DRAW THEIR BLOOD; CORRECT?

MR. DOWNEY: EARLY IN YOUR TIME AT THERANOS?

MR. DOWNEY: OKAY. AND BY THE WAY, THERANOS HAD BELIEVED THAT IT EVEN HAD SPECIAL PROCESSES FOR EXTRACTING BLOOD FROM THE FINGER; CORRECT?

MR. DOWNEY: AND IT OBTAINED INTELLECTUAL PROPERTY IN CONNECTION WITH THAT; CORRECT?

MR. DOWNEY: AND YOU HOLD A PATENT IN CONNECTION WITH THAT; CORRECT?

MR. DOWNEY: OKAY. I'D LIKE TO INFORM YOU IT'S BEEN GRANTED, SO CONGRATULATIONS.

MR. DOWNEY: BUT I -- AND THAT WAS JUST ANOTHER INSTANCE WHERE THERANOS THOUGHT IT WAS DEVELOPING INNOVATIVE METHODS ON ELEMENTS OF BLOOD COLLECTION; CORRECT?

MR. DOWNEY: NOW, I THINK YOU WERE SHOWN SOME EMAILS YESTERDAY BY MR. BOSTIC RELATING TO THE DISCUSSION OF THE RESULTS OF THAT DEMONSTRATION ON WALGREENS EXECUTIVES; CORRECT?