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Federal Criminal Trialtrial-daytrial-dayJohn C. BosticRobert S. LeachKatherine TrefzLance A. WadeBrian GrossmanErin TompkinscrossredirectdirectDay 34 - November 17, 2021Brian Grossman described PFM's extensive but constrained Theranos diligence, its reliance on company forecasts and Holmes's statements, and assumptions about rare venous draws and proprietary analyzers. Erin Tompkins testified about a reactive Theranos HIV screen, later negative testing, and her unsuccessful effort to obtain an explanation; argument over the permissible scope of cross-examination remained unresolved at adjournment.
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Day 34 - November 17, 2021

PFM Diligence and Reliance; Tompkins Test Results

Judge Edward J. Davila
4Proceedings
2Pages
2Witnesses
2,186Lines
Day 34 of 51
Appearing:

Brian Grossman described PFM's extensive but constrained Theranos diligence, its reliance on company forecasts and Holmes's statements, and assumptions about rare venous draws and proprietary analyzers. Erin Tompkins testified about a reactive Theranos HIV screen, later negative testing, and her unsuccessful effort to obtain an explanation; argument over the permissible scope of cross-examination remained unresolved at adjournment.

Full day summary

Defense counsel continued Brian Grossman's cross-examination about PFM's Theranos diligence, internal risk assessments, financial models, and communications with prospective investors. Grossman acknowledged concerns involving regulation, assay data, venous draws, execution, and patient experience, but said PFM lacked complete Theranos data and was restricted in sharing company-specific information with some outside experts. He testified that PFM assumed venous samples would still be processed on Theranos proprietary analyzers and that its projections relied heavily, though not exactly, on Theranos assumptions for 2014 and 2015. The projections included $249 million in 2014 revenue, $1.558 billion in 2015 revenue, and a $20.3 billion discounted-cash-flow value for the U.S. opportunity. On redirect, Grossman said Theranos had described venous draws as roughly 1 to 2 percent of tests early in the rollout, with plans to reduce that share, rather than anything near 40 percent. He testified that PFM's detailed review of the company model found no assumptions involving third-party or Siemens machines and reaffirmed that PFM relied on statements Holmes made during their introductory meeting. He also distinguished the core hub-and-spoke model underlying PFM's investment from later direct placement of devices in retail locations. Erin Tompkins testified that she chose Theranos partly because she expected conventional test information from a tiny fingerstick sample and because its service cost less, while regarding accuracy as most important. Her admitted 2015 report listed a reactive combined HIV antibody screen alongside nonreactive or undetected component results and a note stating there was no laboratory evidence of HIV-1 infection. She said she had never been diagnosed with, treated for, or experienced symptoms of HIV or AIDS, and that a screening within three months was negative. Tompkins described unsuccessfully seeking an explanation from Theranos laboratory personnel and identified a 2021 test reporting no detected HIV antigen or antibody. Cross-examination ended for the afternoon after an objection to testimony about what her physician told her; outside the jury's presence, the court indicated that a narrowed inquiry might be permitted but that Tompkins could not supply scientific interpretation beyond her expertise.

1. Brian Grossman — Cross/Redirect (Continued)

Counsel first addressed disputed Roger Parloff clip designations outside the jury's presence, followed by Brian Grossman's continued cross-examination and redirect about PFM's Theranos diligence, projections, and reliance on company representations.

Procedural
Parloff Testimony Clip Designation Status Conference

The parties narrowed four Parloff testimony-clip designations to two disputes for court review the next morning.

Cross
Brian GrossmanLance A. Wade
1732 lines

Grossman acknowledged that PFM knew of technical, regulatory, execution, venous-draw, and patient-experience risks before investing, while maintaining that PFM conducted extensive diligence, viewed many risks as limited or manageable, and relied partly on Theranos representations when access to company-specific outside review was restricted.

Redirect
Brian GrossmanRobert S. Leach
133 lines

Grossman reaffirmed that PFM relied on Theranos and Holmes for representations about venous draws, revenue forecasts, proprietary Minilabs, regulatory status, and military use.

Highlights

Brian Grossman — Crosstestimony highlightGrossman testified that PFM sought industry and regulatory expertise but could not give outside experts Theranos-specific information without company approval, leaving the team unable to obtain the specific assessment it wanted from one proposed consultant.Brian Grossman — CrossadmissionGrossman acknowledged that PFM assumed venous samples were still run on Theranos proprietary analyzers during diligence, although he could not identify a specific investment-period conversation establishing that assumption.Brian Grossman — Cross“SO OUR ASSUMPTION ALL THROUGH THE DUE DILIGENCE PROCESS WAS THAT EVEN WHEN THERE WAS A VENOUS DRAW, IT WAS STILL RUN ON THERANOS PROPRIETARY ANALYZERS.”— Brian GrossmanThe statement identifies an important diligence assumption that Grossman could not tie to a specific investment-period discussion.Brian Grossman — Crosstestimony highlightThe financial-model examination established PFM projections of $249 million in 2014 revenue, $1.558 billion in 2015 revenue, and a $20.3 billion discounted-cash-flow value for the U.S. opportunity, compared with the approximately $9 billion investment-round valuation.Brian Grossman — Cross“THE MODEL REALLY HAS TWO STAGES. IN 2014 AND 2015, WE RELIED HEAVILY ON THE THERANOS ASSUMPTIONS. WE DIDN'T TAKE THEM WORD FOR WORD, NUMBER FOR NUMBER, BUT WE RELIED ON THOSE.”— Brian GrossmanGrossman clarified the relationship between Theranos's supplied forecasts and PFM's own financial analysis after pointed questioning about the models' differing methodologies.Brian Grossman — Redirecttestimony highlightGrossman testified that Theranos described venous draws as roughly 1 to 2 percent early in the rollout, with plans to reduce that proportion below 1 percent, and that he was never told it was near 40 percent. He explained that limited venous draws were important to PFM's understanding of the technology and business.Brian Grossman — Redirecttestimony highlightGrossman reaffirmed that PFM relied on statements Holmes made during their introductory meeting, including her statement that Theranos devices were used on medevac helicopters.Brian Grossman — Redirect“WE DID RELY ON STATEMENTS FROM MS. HOLMES IN THAT MEETING.”— Brian GrossmanGrossman directly reaffirmed PFM's reliance on Holmes's statements during their initial meeting.

2. Erin Tompkins — Direct/Cross

Erin Tompkins described receiving a reactive HIV screening result from Theranos despite never having been diagnosed with HIV or AIDS. Cross-examination ended for the day after a hearsay objection, followed by argument outside the jury's presence over whether her physician's explanation could be explored.

Direct
Erin TompkinsJohn C. Bostic
199 lines

Tompkins described choosing Theranos for its perceived fingerstick technology and lower cost, receiving a reactive HIV screening result, failing to obtain a laboratory explanation, and later testing negative.

Cross
Erin TompkinsKatherine Trefz
80 lines

Tompkins recalled Theranos's lower cost and a later refund before an objection halted cross-examination and prompted a dispute over physician statements, scientific foundation, and the meaning of differing HIV test results.

Highlights

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