We're continuing cross-examination of Dr. Brenna this morning.
Brunet invites him to resume the position, which comes off as another of his awkard entende's
Young interrupts about something about 3 of 4
SUH: Are you being paid for today? What are your rates?
Q: How much time so far?
A: About 100 hours, including trip to Paris.
Q: Are you planning more grant reqs to USADA?
A: None planned?
Q: Ruling out?
Q: Are you on a working group for IRMS issues? Do you serve on any group dealing with IRMS issues?
A: I think no.
Q: Have you ever been a part of a group that deals with IRMS issues>
Q: What are they?
A: Many informal over the years; many conferences, many presentations in many contexts. Recently attended Symposium in Cologne in January, and Donakey (sp?) last year. Probably a few more in the recent past.
Q: What is the Donakey Symposium?
A: An annual event, in attendenace at previous and last (24th and 25th) in Cologne. It's a workshop, by invitation only, attended primarily by directors and members of accredited labs, and others involved in anti-doping science. Goes for a week, talks, oral presentations, and posters presentations on aspects.
Q: Who does the inviting?
A: I've gotten them from the organizers, the German Sports thing.
Q: Who pays?
A: Out of grant funds, use the USADA grant funds.
Q: You talked about reprocessing yesterday, and showed a summary.
Q: You are familiar with the numbers?
A: Yes, if you put them up, I'll remember better.
Q: The top is the actual sample values, A and B. And the bottom is the blank.
Q: You didn't think any of the values after the original resuults were a problem.
Q: Let's talk about the values. These are the
THIS IS A KEY SLIDE example, can't pick up it all. Example:
a-11k -3.51 -1.67 -1.61 -2.81 -4.01
thing original, auto, manual, zero, masslynx
Q: Masslynx can't do manual?
A: Think so; there's supposed to be a manual mode, but the masslynx crashed when they tried it.
Q: So masslynx is always automatic?
Q: So all the masslynx doesn't allow for it, so they don't do it.
A: Can't say, really, but don't believe they do it manual.
Q: you understand that from discussions with LNDD.
Q: Which person?
A: General discussion, who said what I don't recall.
Q: Who was present?
A: Corinne, ...
Q: Look around....
A: OK, Claire, she's here, Cynthia Mongongo (sp)
[ digression -- de Ceurriz is prononunce 'di seur eez' ]
Q: You look at the values, original -2.02 and reprocessed for -0.35. Is that significant?
Q: Outside the measurement uncertainty?
Q: 5a value, original -3.51, reprocess -1.61. Significant?
Q: was the same process applied to all of these during the reprocessing? Nothing was different for these two?
A: Yes, that is correct.
Q: If you saw a difference of this magnitude in your laboratory, would it cause you concern?
Q: Let's turn to the blanks. Original -1.59, auto reprocessed -3.65. Significant?
Q: do you find anything notable about that difference compared to the other two?
A: don't follow.
Q: Do you see that this now exceeds the 3 mil theshold?
A: Yes, but not the -3.8 standard that applies.
Q: Are you aware that USADA argues there is no uncertainty in the determination, and that 3.0 is the limit?
A: No, I'm not familiar with that.
Q: Let me show you what they say in their briedf paragraph 91. "under the isl, lndd statement is correct, lndd was not required to take into account uncertainty in their delta values." Do you disagree?
A: No. I don't know what it means.
Q: You don't understand what that sentence means?
A: I don't understand the rules.
Q: You understand by your calclulation the -3.51 doesn't exceed the limit?
A: I'm not usada.
Q: your statement contradicts USADA's positoin. You say thie -3.65 isn't positive because of the-.8?
Do you agree or disagree with USADA's position?
A: Not goingn to say.
Q: So your not going to disagree with anything USADA says?
A: I believe I've answered.
Q: Panel, Please direct the witness to answer.
young says the technical document doesn't require it. I don't see whether the witness is qualified to address what the technical document needs.
Q: should the reported value take into acocunt the uncertainty?
A: Yes, i think it should take it into account.
Q: In the chart when there is -1.6 in the blank turns to -3.45 . significant?
Q: Can you show me any two values that are the same?
A: Many, within the range of experimental error.
Q: Within .8?
Q: Without applying uncertainty, as USADA says you shouldn't, are any the same?
A: No. In a restricted sense, no, they are not identical.
Q: If you were to have processed your data and see this variance as a total picture, woulud it cause you concern?
A: In my lab?
Q: Looking at the bottom rectangle, in your own lab, would it have caused you concern?
[ This is the one with bad auto results; the manual reprocessings were close ]
Q: Let's turn to documents, starting with GDC1056, through GDC1075.
[ examining docs ]
q: Do you recognize what these are?
A: recognize them as log files printed at request of Dr. Davis during the May 4-5 reprocessing, from masslynx.
Q: you know the os/2 doesn't produce a log file?
A: so i'm told.
Q: Told by anyone at lndd?
A: Don't recall Davis's assertion was contradicted.
q: looking at 1056, can you explain what log files are?
a: I can't explain these log files to much degree of accuracy. I am not familiar with the masslynx, so my expertise is meager.
q: let's start at 1056. you understand the log relates to event related to testing of a speciman.
q: And these are from april 17 11:42:51 -- while you were there?
[ Opening Sample Log file ]
A: no, before I was there.
q: below start, "commencing analysis of 1704mixcalirms01"
a: same name; I can't vouch it was injected.
q: but if not, someone is lying?
q: 11:48:08 [ filename blah.raw ]
q: then at 11:49:43, starting same thing mixcal. Is that a rerun?
q: see another at 12:05. Same filename?
a: it would seem to be correct.
q: is there any record of the overwritten data in the raw file?
a: not knowing the system, I can't say for sure. If it was Windows, its essentially gone.
q: because it was saved with the same filename.
q: unless you used some forensic utility?
q: 12:06 cal mix 02.
q: and data below that at 12:16:25
q: and at 12:17:23, see mix 01 again.
[ fumbling with highlighting ]
q: again, turn to next page 1057, you see 12:32:50, mix 01.raw again. so data gone again, right?
q: 12:33:21 connecting calmix 02, so were running that again, so the first run of 02 is lost.
a: seems like it
q: page 1058, 19:52:43 Blu F2 commencing analysis. See that?
q: three lines, 2017:24 saved to f2.raw, then three lines later, starting it again.
q: and at 21:08:36, saved to same file.
[ The QC runs are being shown to be statistically invalid because they have only single runs with no checks because they overwrite the files all the time. ]
q: That's just day one. Turn attention to 1061, and look at 18:28 commencing at 1802 blank 2 f2. 19:12:30, saved to f2.raw. This is one of the quality controls talked about at length in USADAs brief. i'm gonna move on.
I'm going to skip these examples until we get to meat rather then examples.
q: do you know who larry bowers of usada is? Is he here?
q: Are you aware he sought to prevent Mr. Landis from getting these log files?
a: I don't know.
q: Without these logs, we wouldn't know about this deleted data?
q: can you point to Mr. Bowers here?
a: that guy
No further questions.
Young stands up for redirect.
Q: Whan you were asked whether you had concerns about these two [ the autos ]
a: because I looked at the original and manual results, and believed they correspond well; the auto result I have questions about, but I believe the procedure in the lab is to use these as a a QC procedure, and the -3.45 numbers are software and the QC step of manual operation would have recovered a good value in manual.
q: so the QC step fixed the problem?
[ NOTE THE MASSLYNX VALUE was AUTO ONLY, at -3.66, not the -1.6 ]
q: let's look at some of the others... If you would have seen this to cause concern, would it cause you to have concern about the other fractions?
a: I'd go back and look at the chromatograms. I woldn't be concerned about the ones that look good based on the other ones.
q: and you have gone back, and are satisfied?
q: If someone were to use the QC manual integration in masslynx would the results be better or less reliable?
a: would make them better.
[ Pulls up the "horn plot" linearity chart suh used yesterday ]
q: you said yesterday, precision, not accuracy. Explain?
a: precision is the spread in the data; at high rates, data is tight. Accuracy is where the mean of the data is right, but each point isn't necessarily.
q: does that mean the small signal is accurate, but not very precise?
q: how does the size of signal where the horn starts compare to the 5a or the pdiol?
a: they are in the higher end. the specific study went to extermely low signal levels you'd never use in this kind of work. We wouldn't be working in the range that is inprecise.
q: When Suh was asking you -- LNDD 313 -- June 26 linearity test -- you were asked to compare this document compared to the 5a signal. Is this a peak or an area measurement?
a: This column is a calculated area, from pulses of CO2. The linearity we're talking about now is different from what's in the paper. They are quite distinct.
q: go to 314. This is the next page. what is this?
a: those are the data used to derive the numbers on the preceding page. Represent CO2 into the instrument at various levels. these establish the peak height produces a linear response from low to high levels. Areas on preceding pages, heights are here.
q: so if you wanted to look at linearity, you'd look here, not at the area?
q: how far in the linearity check did they go for sizes?
a: I looked at all the peaks at issue. All the peaks are at higher intensity than the lowest linearity values.
q: here's one we've seen over and over. Where was the intensity?
a: on the check we just looked at, it was around 1.8, and what we're looking at is above that.
q: have you done that check for all the 5a and pdiols at issue?
q: Were you there for the april 16
q: When you were with Dr. Botre on May 4-5th, did Dr. Davis have a chance to reanalyze data on the Masslynx?
q: what do you recall?
a: He asked about reanalysing data on masslynx. We didn't understand, because it didn't seem to make sense, the next day, he said he didn't need to.
q: so he had a choice, and chose not to exercise it.
Reserve right to call in rebuttal.
End of Questions
q: in the hundreds of hours, did anyone from usada talk to you about the log file data?
September 07: Hearing Award
October 07: Hue's Hearing Appraisal
November 07: Major document Release
January 08: Larry's Curb Your Anticipation
Tuesday, May 15, 2007
We're continuing cross-examination of Dr. Brenna this morning.