Hearing - Tuesday, Mongangu Part Really II

Biology having been taken care of, we're now back to Mlle. Mongongu, and the new interpreter is the most popular person in the building. Bill has been relieved of the play by play, and will return to color.

We're going to run until 6:oopm

MR DUNN continues.

Q: at the time you were doing the analysis with Ms. Frelat, did you know which was Mr. Landis' and which was the one brought by Dr. Aquilera?

A: No, blind.

[MORE]


Q: Did you know how many aquilera brought?

A: yes, 3.

q: so there were 10?

a: yes.

q: how many did you analyze?

a: 6.

q: and you had no idea how many were Mr. Landis'?

a: no, didn't know at all?

q: no one told you?

a: no

q: when did you find out?

a: learned this weekend.

q: 2 or three days ago?

a: yes.

q: uncertainty range for delta delta being 0.8. How is .8 determined?

a: we perform an evaluation of the methodology.

q: was that done in a study lndd performed?

a: yes

q: did you participate in that study?

a: yes.

q: when was it done?

a: over a long period of time?

LNDD 456, exhibit 26.

q: does this contain the study?

a: yes.

q: what page is it?

a: lndd 0456

q: also the basis for 0.5 on a single metabolite delta value?

a: no.

q: different page?

a: yes

q: what page?

a: lndd 0459

q: chain of custody for A, the aliquots you handled. Please look at B pack EX 25, We know you were not involved in the B except for validation of Frelat, but turn to USADA 253 to USADA 257. What are they?

a: the chain of posession of the A and B bottles.

q: 253 and 254 are the Coc of the A and B, right?

a: yes.

q: next three pages are CoC of the aliquots?

a: yes.

q: what is your operatior number

a: 49

q: go to page lost it.

q what were you doing with the bottle?

a: it shows the insertion into the bottle.

q: making an aliquote?
a: yes

q: what time?
a: 22 jul 11:20 am.

q: page 256. you had possession, and you see your number there?

a: yes.

q: day and time?
a: 22 jul 11:20

q: same time?
a: yes.

q: then took to the sample prep room?
a: yes.

q: anyone else have posession?
a: no, i was the only one who had posession.

q: and that's true until fractionation was completed on 23-jul at 3:25pm?
a: no one else?

q: is the room behind a locked door?
a: yes.

q: you left an aliquot on the solid phase extraction machine overnight?
did any outsider have access to the sample?

a: well the people who have access to the sample prep room are my colleagues.

q: outsiders?
a: no.

q: to your knowledge, did anyone else touch the sample?
a: no.

q: to the B sample that M. Frelat analysed. Do you know if the same is true about the posession of the B sample for the IRMS?

[objection, speculation]

q: another subject. returning to the other B analyses. We established two showed positive.

EX 107. This is a table summarizing results of the other Bs. Hilight 825524 (sp?)

q: this was stage 20, you now know. -4.96
a: yes.

q: second sample we talked about was 825428, from Jul 18, after stage 15, -5.06

[ THESE BRACKET S17 TESTS of -6.14 and -6.39 ]

EX 87, '429 reanalysis.

Q: does this show exogenous at -4.80?
a: yes?

q: includes 0.8?
a: yes.

q: so on that basis, you concluded positive?
a: yes.

back to 107, the '429. Showing 5 in a row.

stage 19, jul 22

exhibit 88, page 1106; table shows 5aA at -4.09.

back to 107; sample of 13-jul is positive at -4.09.

q: based on your experience, all 6 values of those 5 stages reflect presence of exo-t?
a: yes.

[ note: 7/14 test not positive ]

Return to logfiles Suh used with Brenna. More copies being made.

q: GDC1056 through 1076, we'll call it the "log". Dates are April 2007. So these don't represent anything to the stage 17 analysis to the best of your knowledge?

a: no.

q: S17 was run using the OS/2 Optima S/w.
a: yes.

q: For the other seven samples, that was done on the Masslynx software?
a: yes.

q: Mr. Landis represented this log to have been produced by lndd during the time Dr. Botre was at LNDD observing the reprocessing of the files on May 4-5. Dr. Botre representing USADA, first to download the files, then they came back to watch you reprocess the data files.

a: yes.

q: and you did that in their presence, first using OS2 Optima.
a: yes.

q: the first time you did it the same way you did on S17 samples in 2006?
a: yes.

q: was there ever a time during this re-analysis that you attempted something 20 times but were unable to do so?
a: no.

q: 15 times?
a: no. no such recollection.

q: Nothing you did 20 times?
a: no.

q: So what Mr. Suh said in his opening statement was a mistake?
a: yes.

q: so what you did generally with the OS2 processing involved sometimes involved manual corrections for background and peak starts and stops?
a: yes.

q: tell me what you did with the OS2 originally last summer, this time, and what Dr. Davis asked you to do, and then with the Masslynx software. Not in great detail.

a: OK. When we reprocessed the results, I was asked to bring out 3 reports on the data. One dealing with the automatic reprocessing, the normal verification, and third with the subtraction of the background. And then placed the data on the Masslynx machine, and reprocessed using that.

q: that's it?
a: yes.

q: looking at the log. Have you ever seen this log before?
a: I saw it ... at the time of the reprocessing of the data.

q: ever before?
a: no.

q: ever printed something similar?
a: no.

q: you were using masslynx for that analysis?
a: yes.

q: what were you doing at the time that some of these entries appear to have been made? Let's start at 11:48:08, April 17. It says "isoprime method stop, wait till running" Let's forget that one. The one I meant was "commencing 1704 mixcalirms01" and then at 12:17:43 is says "commencing ..." which seems to suggest the same thing is running. Can you explain what you were doing and why those log entries are there?

a: If I look here at 11:48, there was no acquiting of the mixcal irms because the isoprime had stopped.

q: so was any data recorded?
a: no there was no data?

q: then what happened at 11:49?
a: then I injected a mixcal irms and then at 12:16 I injected a second and that was to charge the liner of the instrument.

q: then down at 11:49:43 mixcal irms s01, then at 12:17:43 also mixcal irms s01. Why are there two?
a: as i said before, I charged the liner, injected the solution and then did the injection to perform the verification that corresponds to the 12:17

q: so you are just priming the machine?
a: yes.

q: were you ever intendingn to collect data from that injection?
a: no absolutely not.

q: so the second entry is the run you intended to collect data from?
a: yes.

q: so you were not erasing previously collected data intended to be used for the analysis?
a: no.

q: just an injection to prime the machine?
a: yes.

[ SCOTT SMILES; SUH JOKING WITH HIM ]

q: Let's look at another sheet, GDC 1057. 12:33:21, "commencing analysis" mixcalIRMSS02.
a: yes.

q: Previous page at 12:06, If you compare "commencing..." is this the same explanation as the other one?
a: yes, two injections and then restarted it.

q: so the first time is a simply a prime of the machine, never intended to generate data?
a: yes; no.

q: these are just examples, I'm sure there are many others. Page 1058. Look at 19:52:43, commencing 1704 blu 1F2. Fraction 2 of the blank?
a: yes.

q: 20:24:29, "commencing..." explanation?
a: at 19;52 the analysis did not have a complete process because there was no injection; if we go back during the sequence of the injections, I have to add the liquid nitrogen in a cold trap so the remainder of the injections may take place. At that point I pause on the level of the sequences because I have to wait until the last injection is finished. Then I fill up the cold trap with LN. So I have to leave the trap to become stable and then when I stop the pause, then it goes to the sample that will then be injected following that. At this point in this specific case, and so when you start the 1704, the software open the sample.

q: let me restate. during this analysis, the LN needed to be refilled?
a: yes.

q: so you had to stop the run, refill, and rerun?
a: yes, waiting until it was stabilized, and continue on with the sequence?

q: any data lost?
a: no.

q: one or two more.

[ It's 5:40; probably no cross today. ]

q: another log, 11:26:19 , mixcalAcetate01 commencing; 12:22:45, same description. Is there another? Please explain?
a: because there must have been an inversion on the level of the vial standards (?); when I performed the 3 mixcal irms, and then I add another line for mixcal acetate, and if I forget to increase the bottle, and then it doesn't inject the acetate, but the mixcal irms's, then the the mixcal acetates do not correspond, because what was injected was the alkanes. So when I realize that has happened, I restart the right bottle.

q: summarizing -- a bottle that got mixed up, a little vial, you saw the data was wrong.
a: yes.

q: then fixed the problem and re-ran to generate correct data.
a: yes.

q: now we don't have enough time to go into more of these. Did any of these cause you to -- strike.

q: you didn't mix up the bottles, you copied the wrong line of text?
a: yes, I didn't increment a copy and paste on the level of the instrument I finished a copy and on the level of the bottle, it stayed the same as on the alkane.

q: we can put that aside. Minute to confer?

[ Landis is smiling ]

NO FURTHER QUESTIONS.

Brunet: we give you an A+, thank you.

Suh: would she like to read the briefs?
All: yes.

Witnesses tomorrow: We'll go back and look again. Ms. Frelat, Dr. Ayotte, various LNDD personnel, maybe Esther, Rudi and probably not beyond that.

ADJOURNED