richar~ l. vanderheyden condenselt! · 1/28/2000 · richard l. vanderheyden condenselt! ™ page...
TRANSCRIPT
1 Richar~ L. Vanderheyden Condenselt! ™
1 STATE OF WISCONSIN CIRCUIT COURT BROWN COUNTY
KATHLEEN A. PAASOt/S,
l'laintitf,
v. Case No. 99 CV 548
RICHARD L. VANDERHEYDEN, D.D.S., 6 and CONTIIIENTAl, CAS1J1lLTY COMPANY,
Detondants,
10 VIDEOTAPED DEPOSITION OF RICHARD L. VANDERHEYDEN
!l
12
13 ,Videotaped cieposition of P.ICHARD L.
H VAND£1UlE'l'.DEN, to.Ken betore me at the Law otHces of Bouresa11 ,
l!> Pdt.teson, S.C., in tr1e City o:: Green boy, Brow.:i County,
16 Wisconsira, on the 28th day of Jo.nuary, 2000, A.O., otherwiB&
17 than a.s a witness on the trial, in a certain action now
18 pending in Circuit Cour:., Brown Count)', Wisconsin, wherein the
19 parties thereto o.re os set forth 11.bove.
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l,ee F. behnke xegistered Merit Reporte:
Cer:.itied Ree.ltime Reporte:
APPEARANCES
BOURESSA' PATTESON, s.c., of Green B4y,
Wis~onsin: MR. TERENCE J. BOUR~SSA o! th4~ fi:m appeared
on behalf of the pla.i.n tiff, Ka thloen A. Pt1 rnons .
HANNAN, SIESENNOP, SULLIVAN, of Milwnukee,
Wisconsin; MR. w. PATRICK SULLIVAN of that firm appe4red
on behal! of the defendants, Richard L.
Vanderheyden, D.o.s. a.nd Continental casualty Compa.ny.
INDEX TO EXAMINATION
14 Examination l:>y Mr. Bouress4 •••••••• , .•••.••..••••••.•.••.•• 3
1.5
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19 EXHIBIT NUMBER
INDEX TO EXHIBITS
PAGE MAR.l<l!:D
20 l - Dr. va11derheyden• s file on Kathy Parsons , •..•.•• , ••..•• 3
21 2 - Kathleen A, Parsons, 31970.S.OOS, Drug Inventory . , , .... 49
22
23 (Originlll. exhibit l retained by tho witness: original
24 exhibit. 2 placed with original transcript.I
25
Pagel
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Page 3 Said RICHARD L. VANDERHEYDEN.having been fast
duly sworn by the videographer to testify the truth, the whole truth and nothing but the truth relative to said cause, in answer to oral interrogatories, deposed and made answer as follows:
(The examination began at 10: 04 a.m. on January 28, 2000.)
(Exhibit marked for identification as exhibit 1.)
12 EXAMINATION
13 BY MR. BOURESSA:
14 Q Would you please state your full legal name for the 15 .
16 A
17 Q
· 18 A
19 Q
20 A
21 Q
22 A
23 Q
24 A
25 Q
IA
2 Q 3
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s Q 6 A
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14 Q
record. Richard L. Vanderheyden. And what is your residence address, Dr. Vanderheyden? 1670 Hawthorne Heights, De Pere, Wisc~nsin. How long have you lived at that address? I believe since '90. 'Where did you live prior to the Hawthorne Street address? 528 Gwen. That's Green Bay. And how long did you live at that address? Approximately eight years.
You are a dentist; is that correct?
Page 4 Yes. And you are presently licensed to practice dentistry in the state of Wisconsin? Yes. Wnat is the address of your dental practice?
2313 South Webster Avenue. Do you practice with anyone at that address presently? No. Pm sorry? No. Have you ever practiced with any other dentist at that address? Yes. And what dentist is that?
15 A Dr. Mike Pias. 16 Q Can you spell his last name, please. 17 A P-1-A-S. 18 Q 19
And during what period of time did you practice with
Dr. Pias? 20 A I'm not sure of the exact dates, but it was -- he was in 21 the practice about nine months, around 1989 to 190. 22 There were two other dentists that also practiced with 23 me. 24 Q Okay. Could you give me their names and when they 25 practiced with you?
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Page 7 Page 5 1 A Dr. Dave Grady, and I'm not sure of those dates, but it l whatever the Department of Regulation and Licensing 2 was about four or five years ago. And then Dr. Tom
3 Mayhew, which would have been from -- I'm not sure when
4 he started. He was there about a year and left the
2 journal is. 3 Q Now, Dr. Van Allsburg is a chiropractor; true? 4 A Correct.
5 practice in June of this year - or last year. 5 Q And had you referred patients to Dr. Van Allsburg for 6 Q June of 1999?
7 A Correct.
8 Q V.'hat type of dentist was Dr. Mayhew?
9 A General dentist.
6 chiropractic treatment? 7 A No. 8 Q Did he refer patients to you? 9 A Yes.
l O Q And Dr. Grady?
11 A General dentist.
12 Q And Dr. Pias?
13 A General dentist.
10 Q \Vhat was the nature of the allegations regarding the 11 billing discrepancies? 12 A It had to do with patients submitting to Medicare or 13 Medicaid. I'm not sure; I don't know those organiz.ations
14 Q ls your dental practice the only business located at 1 4 real well. 15 2313 South Webster Avenue -- 15 Q Have you ever been the subject of any other disciplinary 16 A No. 16 proceeding by the State of Wisconsin Department of 17 Q -- or are there other businesses in that building as
18 well?
19 A There's another dentist in the building.
20 Q And who is that?
21 A Dr. Paul Vander Kelen.
22 Q Any other tenants of that building at the present time?
23 A No.
24 Q At some point in time, was there a chiropractor who had
25 spac.e in that building, a Dr. Von Allsburg?
Page 6
17 Regulation and Licensing? 18 A No.
19 Q You graduated from high school in 1971? 20 A Correct. 21 Q And what high school did you graduate from? 22 A Preble. 23 Q You then went on to study at the University of 24 Wisconsin-Oshkosh? 25 A Correct.
I A Yes. 1 Q Did you ever receive a degree from the University of
2 Q And during what period of time was Dr. Van Allsburg 2 Wisconsin-Oshkosh?
3 located at 2313 South Webster A venue? 3 A No.
4 A That would have been somewhere around 1989. 4 Q Were you fo any fonn of a pre-dental program at
5 Q And during what period of time was he in the building? 5 uw-oshkosh?
6 A I don1t know the specifics on that. 6 A They do not have a formal pre-dental program.
Page 8
7 Q Was Dr. Van Allsburg in -- Strike that. Was 7 Q What criteria did you need to meet between 1971 nnd 1974
S Dr. Van Allsburg a tenant at 2313 South Webster Avenue 8 in order to be eligible to apply to Marquette University
9 during the time _period that Kathy Parsons was your 9 School of Dentistry?
10 patient? 10 A Ninety credits, and rm not sure if there's a grade-point
11 A I believe so. 11 requirement.
12 Q In response to interrogatory nwnber 20, you provided some 12 Q Did those 90 credits have to be within certain
13 information that suggested that you received a reprimand 13 parameters; that is, certain prerequisites?
14 from the dental examining board because of what you 14 A Yes, there were certain science courses that had to be
15 characterize as fee splitting and billing code 15 met. 16 discrepancy with Dr. Van Allsburg; is that true? 16 Q Did you eotr.r the University of Wisconsin with the 17 A Correct. 17 intention of ultimately going to dental school? 18 Q And can you give me more detail on what occurred in 18 A Yes, I did.
19 connection with that disciplinary action? 19 Q And you graduated from Marquette Dental School in 1978? 20 A I paid a fine, and I believe there was just a reprimand. 20 A Yes. 21 Q Was it a private or a public reprimand? 21 Q And you passed your boards the first time?
22 A I do not remember. 22 A Yes. ,_ 23 Q Do you know whether it was published in any dental 23 Q You don't hold yourself out as a specialist in any given
24 journals or publications? 24 area, but rather consider yourself to be a general
25 A I believe it was published in the dental -- Umin, 25 dentist; is that true?
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Richard L. Vanderheyden Condenselt! ™
Page 9 1 A Yes. 2 Q And is that true of the entire time that you 1ve practiced 3 dentistry? 4 A Yes. S Q Define for me, in your own words, what a general dentist 6 is. 7 A A general dentist is a dentist that treats the patient 8 without being restricted to any specialist activities. 9 Q In your practice, are there certain types of treatment
l 0 that you do not provide, and refer out as a matter of 11 course? 12 A Yes. 13 Q And what types of cases are those? 14 A Umm, root canal therapy, any, you know~ severe 15 maxillofacial surgery, periodontal surgeries, 16 orthodontics. 17 Q Have you completed your answer? 18 A Yes. 19 Q Do you refer out any extraction cases? 20 A Yes. 21 Q .And what criteria do you look to to detennine whether or 22 not an extraction case is one that you can handle at your
office or one which should be referred?
Page 1 J 1 problem at the office. 2 Q And that -· those problems began in 1986, the cash flow 3 and the severe shoulder -- separated shoulder? 4 A That seems kind of long, but time flies. I believe that 5 was the time. 6 Q Have you ever considered renewing your membership with 7 the Wisconsin Dental Association? 8 A Yes. 9 Q Have you done that as of today?
10 A No, I have not. 11 Q Do you have any present intention to renew your 12 · membership with the Wisconsin Dental Association? I 3 A I have discussed that with my office manager. 14 Q What is the Bay Lakes Dental Society? 15 A Bay Lakes Dental Study Club? 16 Q Okay. 17 A Yeah. 18 Q It's listed in your answers as "Bay Lakes Dental 19 Society." What is the correct name? 20 A Bay Lakes Dental Study Club. 21 Q And what is that? 22 A lt 1s a group of dentists that met-· Tiu-ough the years, 23 the amount of time we've met has varied, but we would
24 A I would refer out full bony hnpactions, umm, a tooth that 24
25 would be broken down to the point where I did not feel 25
meet just to discuss dentistry, new things, and we had different programs where we I d bring speakers in. It: s a
Page 10 I that it would be an extraction that I would be 2 comfortable with doing. 3 Q Any other factors that you look to in determining whether 4 a case·- an extraction case is appropriate for referral? 5 A If somebody would want general anesthesia.
6 Q Is performing extractions considered to be a regular part 7 of your practice as a general dentist? 8 A Yes. 9 Q And you have never practiced at any other location other
10 than 2313 South Webster; is that true? 11 A Yes. 12 Q Did you ever work, at any period in time, under the 13 supervision of any other dentist? 14 A No. 15 Q You indicated, in your answers to interrogatories, that 16 you were a member of the Wisconsin Dental Association 17 between 1979 and 1986. Is that accurate? 18 A Yes. 19 Q And why did your membership with the Wisconsin Dental 20 Association lapse in 1986? 21 A Because I chose not to renew it. 22 Q And were there reasons for your decision not to renew? 23 A Yes. 24 Q What were those decisions? 25 A I had separated my shoulder and had a severe cash-flow
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Page 12 study club.
When' s the last time you would have attended a meeting of
the Bay Lakes Dental Study Club?
It would have been approximately a year ago. The club
has been disbanded. Actually, I'm not sure if it's a
true disbanding. It's just kind of on bold, last 1 know.
'What is the International Academy of Oral Medicine and
Toxicology?
Uh, that is a group of dentists that is studying the
toxic effe.cts of materials for dental patients.
Where are their headquarters located, if you know?
I don't know.
Do you receive any sort of publication as a result of
your membership in that academy?
No. At this point, I get a brochure from them
occasionally.
Is that academy involved in the research or the effects of silver amalgam fillings?
Yes. Do you believe that silver amalgam fillings are toxic to
the human body?
(Pause.) As the question is stated, I would have to say no. Do you believe mercury as a component of a silver amalgam
filling is toxic to the human body?
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lA
Page 13 Yes. l Q
Page 15 What _was necessary in order to maintain staff privileges
2 Q 2 at St. Vincent Hospital? 3
4 A
Do all silver ~nalgarn fillings have mercury as a component? Yes.
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4
A You had to attend regular meetings. I I rn not sure if there w~ more requirements than that.
5 Q
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7 A
Are there types of silver amalgam fill.ings that you do not believe are toxic to the human body?
To the best of my knowledge of anything on the market, I believe that they are all containing mercury, that I am aware of. If something recent has come out that I'm not aware of, then I 1m not sure.
5 Q 6 7 A
Did you actually avail yourself of the staff privileges at St. Vincent Hospital between 1978 and 1982? Yes.
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Q And what types of cases, or what kinds of services did you perfonn at St. Vincent Hospital while you had staff privileges?
11 Q
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11 A
12 Q 13 A
Wisdom teeth extractions. Any other procedures? No.
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15 A
Okay. So to the extent of your knowledge of what is available in connection with silver amalgam fillings, they would all contain mercury, and they would all be toxic to the human body~ true? True.
14 Q
15
And those would be cases, I take it, that would require a
general anesthetic?
16 Q 16 A Yes. 17
18 A
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All right. What is the Great Lakes Association of Clinical Medicine? That is a group made up of osteopaths, M.D .s, I believe some chiropractors, dentists. That, again, is another study group.
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Q And based upon your prior answer, do I understand, then, at some point in time you made the determination that you would instead refer those types of cases -- meaning those that require general anesthetic -- to oral surgeons?
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ls that a local study group? No. \\ 7here do its members come from? Are they nationwide? Nationwide. Do you attend any sort of meetings with that association?
Page 14 I A Not presently. 2 Q Okay. When is the last time you would have attended any 3 sort of function in connection with your membership with 4 the Great Lakes Association of Clinical Medicine?
21 A
22 Q 23 A
24 Q
25 A
l Q 2 A
3 Q 4 A
Correct. Does Cindy Peat, P-E-O-T, still work with you?
Yes. Does Laura Gales still work with you?
Yes.
Does Michelle Nickel still work with you?
Yes.
How about Kris Dcmerath?
No.
5 Q 5 A It was a couple years ago. I do not remember the How about Angel Janssen?
6 A 6 specific date. No. 7 Q 7 Q And are there specific issues with which that association 'When did Kris Demerath leave your practice?
8 A 8 concerns itself, or is it just more of a general I believe approximately six years ago.
9 Q 9 association of professionals that deals with a wide range Is that her married name, if you know, Demerath?
10 of different issues? l 0 A Yes.
11 A They deal with a wide range of different issues. 11 Q And do you know her husband's name?
12 Q Do you receive any publication as a result of your 12 A Jim.
13 membership in that association? 13 · Q And do you know if they live in the Green Bay area?
14 A Brochures only, at this point. 14 A Best of my knowledge, yes. 15 Q Are there other health care professionals locally that 15 Q Do you know what Kris is currently doing?
16 you know of who belong to the Great Lakes Association of 16 A Last I knew, Kris was a dental hygienist at a different 17 Clinical Medicine? 17 office. 18 A Currently, I'm not sure. 18 Q Do you know whose office she's working for?
Page 16
19 Q You indicated, in your answers to interrogatories, that 19 A Last I know, it was a dental office down the street from 20 you had full staff dental privileges at St. Vincent 20 me, that Dr. Schumacher is in, but I'm not recalling what
21 Hospital between '78 and '82; is that true? 21 the dentist that she worked for in that building, or who 22 A Correct. 22 he is. .._ 23 Q And why did your staff privileges tenninate in 1982? 23 Q And what were the circumstances surrounding Kris Demeratb
24 A I was not using the hospital facilities, so I decided to 24 leaving your practice? 25 not pursue having hospital privileges anymore. 25 A She bad a personal conflict with my office manager,
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1 Cindy. 2 Q Was she tenninated or did she quit? 3 A She quit. 4 Q Do you know whether Kris Demerath ever provided care or 5 treatment to Kathy Parsons? 6 A l don't know. It might be tn my chart. 7 Q And throughout the course of this deposition, whenever 8 you need to review your chart to refresh your 9 recollection, feel free to do so. Why don 1t you take a 10 · minute and see if you can detennine whether or not, from 11 your chart, Kris Demerath provided care or treatment to 12 Kathy Parsons.
· 13 A (Pause.) Yes, she did. 14 Q And what specifically about your chart allows you to 15 recogniz.e that Kris Demerath provided care or treatment 16 to Kathy Parsons? 17 A On 10-23 of '89, there's a reference to a prophy, with 18 the initials "K. D. 11 after it. 19 Q Would it be fair to say that if we looked through your 20 chart and we found any other entries that would be 21 followed by the initials 11K. D." that those entries would 22 have been made by Kris Demerath? 23 A Yes. 24 Q Did Angel Janssen ever participate in the care of Kathy 25 Parsons?
l A I believe so. That, I would have to verify by office
2 employment records and check dates, nnd I don't have
3 those with me.
4 Q As a dental assistant, she would not make entries in the
5 chart; correct?
6 A She may make entries in the chart, and I'm not sure I
7 would recognize her handwriting.
8 Q And when did Angel Jans sen leave your practice?
9 A It would have been approximately three years ago.
Page 18
10 Q And do you know whether that's her married name, Janssen?
11 A Her married name, when she worked for me, was Angel
12 Davis. Her maiden µame wns Janssen.
13 Q Okay. Was her name Angel Davis at the time she left your
14 practice?
15 A Yes. 16 Q Okay. And do you know her husband 1s name?
17 A Don. 18 Q And do you know what Angel Davis is doing?
19 A Yes. She is working as a massage therapist.
20 Q Do you know where?
21 A In De Pere.
22 Q Do you know the name of the employer for whom she works?
23 A ~he works with her brother, Dr. Jack Janssen. I believe
24 she's independent from him. I'm not sure what their
25 • association is.
l Q 2 A
3 Q 4 A 5 Q
. 6 A
7 Q
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10 Q
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Page 19 Okay. Do you know what Don does for a living? Don works for Quality Assured Office Machine. Do you know what Jim Demerath does for a living? The last I know, Jim was a private investigator. Did he work for API?
I don't know. And what were the circumstances surrounding Angel Janssen Is leaving your practice? Angel wanted to be a massage therapist.
Was she studying to become a massage therapist? Yes. Is it more likely than not that Angel Janssen would have been involved in at least assisting in the dental care of Kathy Parsons? To the best of my recollection, yes. Would Cindy Peot have had contact with Kathy Parsons during the time period that Kathy was a patient in your office? Yes. Same question as to Laura Gales. Would she have had contact with Kathy Parsons? From a front-office standpoint, yes. And what about M:ichelle Nickel? Again, front office, yes. So the only persons who would have actually had contact
Page20 1 with Kathy in an operatory setting would have been Cindy 2 Peot, Kris Demerath and Angel Janssen? And yourself, 3 obviously. 4 A Yes, I bel.ieve so, yes. 5 Q Anyone else that you can think of that would have been 6 actually involved in Kathy's dental care or in assisting 7 with regard to Kathy's dental care, other than who we've 8 already talked about? 9 A One of the other doctors may have seen her for a brief
IO visit, but I'm not sure of that. 11 Q Okay. 12 A lt'sapossibility. 13 Q If that happened, who would that have been? 14 A I believe it would have been Dr. Grady, if anybody. 15 Q I'm going to direct your attention to interrogatory 16 response nwnber 17, which contains the names of 17 some -- the identities of some other cases where you 18 provided, I believe, deposition testimony, and I1d like 19 to ask you a general question first: In each of those 20 cases, were you testifying in the capacity of a treating 21 dentist for injuries that a given patient had sustained? 22 A Yes. ', 23 Q Okay. You weren't testifying on standard-of-care issues, 24 for example? 25 A No.
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Page 21 I Q Have you been contacted by the State of Wisconsin Board 2 of Dental Examiners in connection with any of the 3 allegations that Kathy Parsons has raised in this 4 litigation? 5 A No. 6 Q Would you agree or disagree with the statement that the 7 goal of a general dentist is to preserve -- is the
8 preservation of pennanent teeth for the lifetime of the 9 patient?
10 A I would disagree. 11 THE REPORTER: You would disagree? 12 THE WITNESS: l would disagree. 13 BY MR BOURESSA:
I 4 Q Vlhat would you consider to be the primary goal of the 15 general dentist? 16 A To maintain the oral structures of the mouth for the best 17 · health of the patient. 18 Q TI1e license that you've been granted by the state of 19 Wisconsin to practice dentistry carries with it certain 20 privileges and certain limitations; would you agree with 21 that? 22 A Yes. 23 Q Do you believe that the prnctice of dentistry limits 24 itself to the diagnosis and treatment of the human teeth,
25 alveolar process, gums, jaws, and associated structures?
Page 22
1 A Yes. 2 Q Do you believe that the practice of dentistry restricts 3 itself to services that can be performed in and around 4 the oral cavity? 5 A Yes. 6 Q Do you have any other licenses, other than a license to 7 practice dentistry? 8 A At this point? 9 Q Yes.
10 A I have a massage therapy license. 11 Q And when did you receive that?
12 A Last June. 13 Q And what is necessary in order to be licensed in the 14 field of massage therapy in the state of Wisconsin? 15 A I believe it is 550 hours of class at an accredited 16 massage therapy school. 17 Q And what school did you attend? 18 A Fox Valley School of Massage. 19 Q Is massage therapy, then, presently a part of your 20 practice? Strike that. Do you presently practice 21 massage therapy? 22 A Yes. ', 23 Q And is that a practice that is separate and distinct from 24 your dental practice, or do you treat certain patients 25 both within the field of dentistry and within the field
Page23 I of massage therapy? 2 A I would have to· say that it's treating both. 3 Q Can you give me an example as to when a dental patient 4 may require massage therapy? 5 A After extraction of a wisdom tooth, and the internal 6 pterygoids go into spasm and need to be released. 7 Q Do you provide massage therapy for non-dental-related
8 problems? 9 A Yes.
10 Q Do you have patients that are exclusively massage therapy 11 patients; that is, they're not a patient within your 12 dental practice? 13 A Yes. 14 Q Do you receive .any publications, either at home or in 15 your office, related to your dental practice --
16 A Yes. 17 Q -- on a regular basis? 18 A Yes. 19 Q Which ones come to mind? 20 A Dental Products Report. I can't recall any others at 21 this point. 22 Q You treated Kathy Parsons between December 15th, 1988, 23 and December 20th of 1996; is that true? 24 A Yes. 25 Q Do you know how she became your patient?
Page 24 1 A She was referred to me from Dr. Sturgis. 2 Q What kind of doctor is Dr. Sturgis? 3 A He is a chiropractor. 4 Q Did you have an occasion to speak with Dr. Sturgis before 5 you saw Kathy Parsons for the first time as a patient in 6 your office? 7 A I do not remember. 8 Q Do you have a specific memory of Kathy Parsons' first 9 visit to your office on December 15th, 1988? And I guess
10 I'm asking you independent of your chart. I mean, if I 11 ask you to think back to that date, do you have a 12 specific memory? 13 A No. 14 Q 'What -- Strike that. Without looking at your chart, do 15 you have a recollection of what problems Kathy Parsons 16 was experiencing that she came to see you about? 17 A I remember pain. That's what comes to mind. 18 Q And more specifically, what pain complaints, in what 19 location?. 20 A I don't remember the specifics. 21 Q I asked you to provide me with the names of specialists 22 where you may have referred Kathy Parsons, and you 23 indicated, in response to that interrogatory, which is 24 number 15, Douglas Cook. Do you know Douglas Cook? 25 A Yes.
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'/ Richard L. Vanderheyden Condenselt! ™
1 Q How long have you known Douglas Cook? 2 A Approximately 15 years.
Page 25
3 Q And he, wnm, at least was a dentist practicing in Suring, 4 Wisconsin? 5 A Yes. 6 Q Do you know whether he's presently licensed to practice 7 dentistry? 8 A I believe he is. 9 Q Did you refer Kathy Parsons to Douglas Cook?
10 A Kathy saw Dr. Cook before she saw me. 11 Q Did you have access to Dr. Cook 1 s records at the time you 12 saw Kathy for the first time? 13 A No. 14 Q Did you ever have occasion to speak to Dr. Cook about 15 Kathy's condition before you began treating her? 16 A I do not remember. 17 Q At any time during the ti.me period that Kathy was a 18 patient in your office, did you ever have access to 19 Dr. Cook's records, which I would -- which I would deem 20 to include x-rays? 21 A Yes. 22 Q And can you give me a rough idea as to when during the 23 course of that treatment that infonnation would have been 24 made available to you? 25 A The x ·rays \Vere available at the start.
Page 26 1 Q Did you ever have access to his cha.'1:, Dr. Cook's chart, 2 while you were treating Kathy? 3 A No. 4 Q Directing your attention to your chart; specifically, the
5 first entry, which is December 12th of 1988. Do you have 6 that in front of you? 7 A Yes. 8 Q It says "J>hysical therapy" as an entry on the 12th. Can 9 you explain what that entry means, please.
IO A That would have been Dr. Van Allsburg, a visit with 11 Dr. Van Allsburg, is the best that I can recall on that. 12 Q Was Dr. Van Allsburg at that time located in the same 13 building as your dental practice? 14 A He worked out of one room in my office, very briefly. 15 Q And he was providing chiropractic services out of that 16 room in your office? 17 A No. 18 Q What was he doing? 19 A Physical therapy. 20 Q And how long did that continue? 21 A I believe only a month or two. 22 Q The next entry appears to be dated 12-15-8 8; is that 23 correct? 24 A Correct. 25 Q And what does that say?
IA
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Page 27 Umm, "Check and test resin from Dr. Cook." Actually, it does not say "Doctor," it says "from Cook." And what does that mean? That means that we wanted to find out what resins he had put in, because I wanted to know what they were. What is a resin? A resin is a white composite filling. And what is its purpose? To restore decayed or broken teeth. Is· it, in layman I s tem1, a filling? Yes. And did Kathy have resin fillings in her teeth at the time you first saw her? Yes. And is that true of all the teeth that had fillings, that they were of a resin composition? Yes. And had Dr. Cook previously removed all the silver amalgam fillings in Kathy's mouth and replaced them with resin, if you know? Unun, yes, I believe that was the case. Okay. And did you perform the check. and test that's referenced on December 15th, '88? Yes. And what type of tests were perfonned?
Page 28 1 A Uh, that test, I used, umm, an EA v machine, to see if it 2 showed an autonomic system response to that material. 3 Q Does 11EAV'1 stand for 11Electroacupuncture According to 4 Voll," V-O-L-L. 5 A Yes. 6 Q Is that the same thing as a Dennatron, or are they 7 different? 8 A They're different.
9 Q Is a Dermatron a computer device of some sort? Let me 1 O strike that. Tell me what a Dennatron is. 11 A A dennatron is an instrument that measures skin 12 resistance. 13 Q And how is that different than an EA V?
14 A EA v is more of a general tenn describing the whole 15 procedures and theory behind it. 16 Q Can a dennatron be used to perform EA v testing? 17 A Yes; 18 Q ·what is an -- What is Intero, I-N-T-E-R-O?
19 Q An Intero is a computer system that does the same type of 20 testing. 21 Q Are Dennatrons and Interos the same thing? 22 A Depending how specific you want to be with that. They 23 could be categorized generally as the same type of 24 equipment. 25 Q Dermatrons and Interos can perfonn EAV testing?
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1 Richct;rd L. Vanderheyden Condenselt! TM
Page 29 lA Yes.
2 Q Okay. Well. let's be specific. 'What is -- What is the
3 difference between a J;)ermatron and an lntero?
4 A An Intero is a compu:ter system that has infonnation
5 stored within the computer, whereas a Dermatron is just a
6 measuring device.
7 Q Wjthout attempting to be too general, UI1U11, could one
8 consider the Dermatron to be the hardware and then the
9 Intero to be the software?
10 A Yes, ·with the explanation that the Intero has the same
11 measuring capabilities of a Dennatron.
12 Q Are those brand names, Dermatron and lmero?
13 A Yes.
14 Q And on December 15th, 1988, did you haven Dem1atron
15 device in your office?
16 A I believe I did.
17 Q How else would you have done EA v testing for the resin if
18 you did not have a Dennatron device?
19 A I would have had the Im.era.
20 Q Okay. At some point in time between '88 and '96, did you
21 hove both of these devices, or one or the otl1cr?
22 A One or the other. .., ... -J Q Did you replace tl1e lntero with the Dennatron?
24 A Replaced the Dennntron with the lntero.
25 Q Okay. How long did you have the Dennatron?
Page 30 lA Couple of years.
2 Q You started practicing in 1978. Did you have a Dem1atron
3 at that time?
4 A No.
5 Q \Vhcn did you first put a Dennatron into use in your
6 practice?
7 A I would have to look at records to be specific. It would
8 have been approximately somewhere between 1980 and '82, I
9 believe.
10 Q Okay.
11 A I'm not specific on that.
12 Q "What records would you need to look at in order to verify
13 the dates that you would have had .a Dermatron in your
14 office?
15 A I could verify that roughly by looking at when I attended
16 a course by Dr. Voll, and I may have records of a
17 purchase date of that, possibly.
18 Q Okay. Where was the course that you attended with
19 Dr. VollJ at what location?
20 A In Chicago.
21 Q And who sponsored that course?
22 A I don't know.
23 Q Do you still have records that relate to your attendance
24 at that course? 25 A I do not know.
1 Q
2
3 A
4 Q
5 6 A
7 Q
8
9 A
10 Q
11
12 A
13 Q
14 A
15 Q
16
17 A
18 Q
19
20 A
21 Q
22 A
23 Q
24 A
~5 Q
I 2 A 3 Q 4
5 A
6 Q 7
8 A
9 10 Q
11 A 12 Q
13
14 A
15 Q
16.
17 A 18 19 Q
20 A 21 Q 22 A
23 Q 24 A 25 Q
Page 31 Where was the Dennatron kept in your office during the time period that you had it?
In a room that I would call my office.
So would you have replaced the Dennatron with the lntero sometime in 1982? I don't know. Was there a time period when you had neither a Dennatron nor an lntero present in your office? I believe there was, but I'm not sure. 'Where was the lntero device kept during the time period you had it in your office? In the office part. Do you still have an lntero in your office? At this point, no. Okay. When did you last have the Intero device in your office? Uh, just recently. Can you give me your best estimate as to when it would have been removed from your office? I removed it, umm, at the end of the year. The end of 1999? Yes. And why did you remove it at that ti.me?
I had brought it home. ls the Intero device being used out of your home at the.
Page 32 present time?
1 was using it for my family.
So as of December of 1999 -- Well, strike that. .A.re you
using EA v testing in your practice at the present time?
Yes.
Okay. And what device are you using in order to perform
the EA v testing at the present time?
At the present time, I was going to bring the Intero back
to the office.
Is it still at your home?
No, it is back at the office now.
Was there a time period where you were not doing EAV
testing in your office?
Briefly, yes. Why was it that the Intcro device was brought home for
that period of time? My family members were having problem with flus and colds
nnd ...
Where did you purchase the Dermatron?
It was from a company called Petterling Electronics.
Is that n Canadian company?
German.
German? Was it shipped to you directly from Germany?
I don't remember.
Do you recall purchasing it through any either retail or
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Page 33 I wholesale outlet in the United States? l A Pain in the teeth.
Page 35
2 A I don't remember. 2 Q Were you trying to determine whether the reaction was 3 Q Where did you purchase the Intern device? 3 coming from a source other than her teeth? 4 A Uh, through a company in Utah. 4 A Yes. 5 Q Do you know where the lntero device was manufactured? 5 Q And what possible sources did you consider as being a 6 A I believe it was manufactured in Utah. 6 cause of the pain in her teeth, other than the teeth 7 Q Do you know whether either a Dennatron or an lntero 7 themselves, or the tooth structure itself? 8 device are authorized for use by the FDA? 8 A Myofascial pain, cervical vertebral referrals. 9 A I'm not 100 percent sure whether they are. 9 Q And what course of treatment was then available to you
lO Q Let me ask a more precise question: Do you 1-mow whether 10 after you made that detennination as to the resins that 11 or not Dennatron or lntero devices are approved by the 11 you had tested? 12 FDA for the dic1;.C1T1osis and treatment of dental~related 12 A The first course that I tried was to give her a 13 problems? 13 homeopathic for the resin material. 14 A I do not know. And what homeopathic was that? 14 Q
15 Q So based upon your testimony, then, do I understand I'm blanking on the name. It's a specific homeopathic 15 A
16 16 correctly that it would have been the lntero device that for resins. 17 would have been used to check and test resin with Kathy Beginning on December 28th, 1988, there is a series of 17 Q
18 18 cm December 15th of 1988? entries, umm, which includes the initials 11IRM temp"; is 19 A Yes. that correct? 19
20 A 20 Q Okay. Describe for me what an lntero device is. Correct. 21 Physically, what does it look like? How do you use it? And is that an intermediary restorative material? 21 Q
22 A 22 A It is a computer system. You have a handheld probe: and Yes. ~3 then you have a pointed probe, and you test certain And so did you replace the resin \Vith IRM? 23 Q
24 autonomic skin rei,-ponse points. 25 Q \VhHe you're testing, is the patient holding something?
Page 34 1 A Yes.
2 Q 'What are they holding?
3 A They're holding a brass cylinder in one hand.
4 Q V/lmt does the brass cylinder do?
5 A It provides contact to create an electrical loop.
6 Q Tell me specifically what you would have done with the
7 Intero device to check the resins in Kathy's mouth on
8 December 15th, 1988.
9 A I would have checked the measurements of the lymphatic
10 point relating to the dental area. I would have checked
11 points relating to 1he allergy system and to the nerve
12 degeneration system.
13 Q And what are you tcsti~g for?
14 A You're testing for skin response.
15 Q And what type of skin response are you looking for to
16 determine whether the resins are an appropriate filling
17 material?
18 A A change in a meter reading.
19 Q And what did you find after you perfonned those tests?
20 A It appeared that Kathy was reacting to the resins that
21 Dr. Cook had placed.
22 Q Did that reaction create symptoms?
23 A Yes. 24 Q And what symptoms would she have been experiencing that
25 you would believe constituted a reaction to the resins?
24 A Yes. 25 Q And why did you do that?
Page 36 1 A Because she did not respond to the resin, the teeth were 2 still creating pain, her health history indicated 3 reactions to materials. 4 Q What type of material is -- Strike that. What type of 5 material did you use as an intermediary restorative 6 material? 7 A It is a product called "JRM."
8 Q Okay. What's its composition, if you know? 9 A Umm, there's some eugenol, zinc oxide, and I'm not sure
10 of the exact rest ingredients. 11 Q Were you confident that Kathy would not react adversely 12 to the IRMs?
13 A No. 14 Q Why did you feel the IRMS would be a better alternative 15 than the resin? 16 A Because the IRMs are designed as an intermediate 17 restorative material to calm teeth down. 18 Q And their purpose is just that, to be utilized on a 19 temporary basis only; correct? 20 A Yes. 21 Q They're not designed to be a long-tenn solution as far as 22 fillings go? 23 A .Correct. 24 Q And let me just ask you a couple of questions to 25 understand how you go about charting. There appears,
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Page 37 1 from what I've seen in your record, I'm going to just 2 generally describe it as being some entries on the 3 left-hand side of the chart and then some entries on the 4 right-hand side of the chart, generally speaking. 5 A Correct. 6 Q Can you just tell me who makes the entries and how the 7 .chart, you know, kind of flows together, so I can 8 understand what you1re recording here? 9 A Uh, through the course of the years, it has varied.
10 Predominantly, I would make most of the entries on the 11 right, sometimes on the left. Assistants would sometimes 12 make entries on the left in reference to procedures done, 13 and office people would make entrances on the right 14 referring to insurances and paperwork. 15 Q Okay. Could I just take a look at the original, please? 16 (Pause.) Directing your attention, as an example, to 17 January 4th of 1989, begins -- the entry begins "Last 18 night, teeth pain. 11 Do you see that? 19 A Mm-hmm. 20 Q And it goes down through an enL--y which begins, 21 number 19, "Infected bone." Do you see that? 22 A Yes. 23 Q From where I started in that entry to where I just ended, 24 is that all your hand\·vriting? 25 A Yes.
1
2
3
4
5 Q
6
7 A
8 Q
9
JO A
11 Q
12
13 A
14
15 Q
16
17 A
18
19
20
21 Q
22 23 A
24 Q
25
Page 39 just looking at what is there, and at this point in time, I may have even done a just quick bite adjustment, but it would be, wnm, usually extremely just simple, quick visit.
If specific treatment would be rendered in connection with an office visit, would you have noted it? I 1m not sure how we were doing the records at that time. By January 3rd of 1989, had you replaced all of the resin fillings put in by Dr. Cook with IRMs?
I believe so. What was your treatment plan after you had replaced the resin fiUings with the IRM temporary fillings? To restore them with a more compatible pure porcelain cast material. And when did you anticipate doing that as of the time that you did the replacement of the resin fillings? That is determined by how the patient responds to the temporaries. I normally like teeth to be calmed down for at least a two-to-three-month period of time before replacing. And would you detennine the calmness of the tooth, if you will, by the use of the lntero device? No. How would you detennine when -- whether a tooth was irritated or whether a tooth was cahning dovm?
Page 38 Page 40 i Q And below that we1ve got two entries on January 4, which l A Patient sensitivity1 percussion, hot and cold response. 2 appear to relate to charges. That would have been done 2 Q Did you ever utilize the Intero device to detennine 3 by a clerical person; is that what you 're telling me? 3 whether or not Kathy was reacting to the IRM temporary 4 A Yes. 4 fillings? 5 Q And the entries -- all the entries that are put in on the 5 A I don't remember. 6 28th of December, 1998 -- 1988 that say "MOD-IRM temp," 6 Q Is it possible that that occurred? 7 are those made by a staff member? 7 A It is possible. s A Yes. 8 Q On January 4th of 1989, there's an entry. Why don 1t you 9 Q And do you know who would have made those entries? 9 just read that into the record, if you would, please.
10 A No, I do not. 10 A "MENS treating masseter, temporalis, slight change in jaw 11 Q As we go through the chart, there are entries -- For i 1 position--" I'm sorry -- "jaw tension. Internal 12 example, if you look at January 23rd, 1989, it simply 12 pterygoid feels looser. Neck still bad." 13 says, "Office visit.11 13 Q Where is the internal pterygoid located? 14 A Yes. 14 A It is behind the lower teeth and runs up the side of the 15 Q Can you give me a general description of what would are 15 throat. 16 occurred on an office visit? And what I 1m trying to 16 Q Is that a muscle? 17 avoid is the prospect of having to go through each office 17 A Yes. 18 visit to detennine what occurred, because there seems to 18 Q And is that, the looseness, something you palpated? 19 be some sort of general entry to that effect. And maybe 19 A Yes. 20 I'm being presumptuous, but can you answer that question, 20 Q 'What does the "MENS treating" signify?
21 wh~t would generally occur in connection with a visit 21 A Umm -- (Pause.) I1m blanking on what the 11M11 stands 22 that is entered in the chart as, quote, "office visit," 22 for, but the other part is "Electrical Neural 23 unquote? 23 Stimulation.11 I'm not sure what the "M" is for. 24 A When I would have something as an office visit, just as 24 Q Explain to me what that treatment is. 25 that, that would normally constitute a person coming in, 25 A It is an electrical stimulater, similar to a TENS unit.
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Page 41 Page 43 1 On the basis of a TENS unit, to cause a relaxation in the 2 muscle. 3 Q And where is at that device placed on the body? 4 A You have two pr~bes that you place on various areas of 5 the muscle. 6 Q And are the muscles you' re referring to the masseter and 7 the temporalis? 8 A Masseter, ternporalis and internal pterygoid. 9 Q So you would have touched those muscles with a probe,
10 which would have introduced some sort of electrical 11 stimulation into the muscle? 12 A Correct. 13 Q And the note there says, "In chair for two hours. 11 Is 14 there a reason that the amount of time is noted at that 15 time? 16 A Umm, I'm not sure. That's not my noting there. The only 17 reason I can assume that it would be there was that we 18 had her there for a long time, with the exam and treating 19 that. 20 Q So that would have been an unusually long visit that 21 would justify a notation that it took two hours? 22 A Yes. Yeah. The charges are fairly low for that amount 23 of chair time in a dental office. 24 Q On January 9th, 19 8 9, did you ex tract tooth number 15? 25 A Yes.
Page 42 I Q 'Why?
2 A She was having pain and needed relief.
3 Q 'What -- Was that tooth vital at the time it was
4 extrncted?
5 A No.
6 Q And what tests did you utilize to determine that the
7 tooth was not vital prior to its extraction?
8 A We used patient symptoms, we used pulp testing, we used
9 hot-and-cold diagnosis.
10 Q And is there any entry in connection with that extraction
11 that would reflect the results of the pulp testing or the
12 hot-and-cold testing?
13 A No.
14 Q And you bad put an lRM temporary in tooth number 15 back
15 on December 28th of 1988?
16 A Yes. 17 Q Was the tooth -- Was 1S vital on December 28th of 19887
18 A I do not know.
19 Q Did you believe that the tooth warranted a temporary
20 filling as of December 28th of 1988, as opposed to being
21 extracted? 22 Q I'm sorry; I ·missed your date.
23 A Going back to December 28th of 1988, my question is: Did
24 you feel the tooth justified an IRM temporary filling, as
25 opposed to an extraction, when you evaluated that tooth
1
2 A
3 Q 4
5
6 A
7 Q 8 A
9 Q
10
11
12
13 A
14
15 Q
16 A
17
18 Q
19 A
20 Q
21
22 A
23
24 Q
25 A
1 Q 2
3 A 4 Q
5
6
7 A 8 Q
9 A
10 Q 11
12 A
13 Q
14
15
16 A
17 Q
18 19
20 21
22 A
23
24 Q 25
on the 28th of December in 1998. Yes.
What occurred between Dec~mber 28th, 1988 and January 9th, 1989, which caused you to believe an extraction was appropriate? Uh, the symptoms that she was having with it. And what symptoms were those? Pain. On January 4th of 1989, on the right-hand side of the chart, there is an entry number -- Well, starting with number 19, would you please read what you have written there. Yes. "Number 19, infected bone. Number 15, 30, 31, possible 2 or 3." And what does that mean, that entry? That means that when I looked at the x -rays, the bone around those particular teeth looked questionable. Including 15? Yes. Okay. And when did you take the x-rays that revealed what you just testified to? Uh, those, to the best of my recollection, were based off a full·mouth set of x-rays I received when she came in. ~nd who took those x-rays? Dr. Kollath, I believe.
Page 44 And throughout the course of your treatment of Kathy Parsons, you never took full-mouth x -rays; is that true? Correct. What do you believe to be the standard of care with regard to the frequency of taking full-mouth x-rays in a patient? Every three to five years. And why was that not done in Kathy's case, then? At the patient's request not to have radiation exposure. At any point during the time that you treated Kathy Parsons, could you have refused to continue to treat her? Yes. If you felt that you needed to perfonn diagnostic tests in order to make infonned decisions, and she refused, could you refuse to go forward with the treatment? Yes. On January 17th, 1989, there's an entry reading 11Physical therapy.11 There's also an entry on January 23rd and January 24th. Again, would those are physical therapy treatments with Dr. Van Allsburg from a location within your office? --Because they're in my chart, I have to assume they were done in my office. Okay. Why was the Intero device kept in your office, as opposed to be in the operatory during -- where you would
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1
2
3 A
4 Q 5
6 A
7 Q
8 A
9 Q 10 A
11 Q
12
13 A
14 Q
IS A
16 Q
17 A
18 Q
19 A
20 Q
21 A
22 "'" .t.J
24
25 Q
1
2 A
3
4
5
6 7 Q
8 A
9 Q
10
11 A
12
13
14
15 Q
16 17
18 A
19 Q
20
21 A
22 Q
23
Page 45 have, I assume, perfom1ed the examination and treatment of various dental conditions? Convenience. It was more convenient to have the lntero device in your office'? Yes. Who is Dr. Galvez? Dr. Galvez is a physician in the Madison area,
What type of physician is he? Uh, an M.D. And what sort of treatment did you understand that Dr. Galvez was providing to Kathy Parsons? He was not providing any treatment for her at that time. What was his involvement in her care, if you know? I do not believe he had seen her at that time. On January 7th, 1989, did you call Dr. Galvez? I believe that is the 9th. Okay. Umm, and yes, I did. And why? I did that because Kathy had been complaining about chest pain at numerous times, and I had suggested that she sec a physician and had resistance to that idea, so I also suggested the possibility of Dr. Galvez. Okay. What is it about Dr. Galvez that caused you to
Page 46 believe that he might. be an appropriate referral?
Because Kathy had been doing more with alternative people
and had a history of wanting to work with alternative
people, and be also worked with, I believe, an Intero
type of device and could possibly help her, and he had
the license to work with those conditions.
Such as, for example, chest pain?
Yes.
Okay. When you use the terminology '1alternative people,"
alternative to what?
That is a general term that people use, I think, to
include anybody who isn't extremely specific to certain
therapi~. I don't really know how to describe that
term.
Do you consider medical professionals who use Intero
devices to be providing alternative treatment to their
patients?
Not necessarily.
'What about providing patients with homeopathic -
homeopathies? Is that considered alternative treatment?
I don't know.
So as of January 9th, 1989, Kathy was reluctant to be
referred to a traditional physician?
24 A That was my understanding, yes.
25 Q On January 26th, 1989, did Kathy complain about a rash on
Page 47 l her legs?
2 A Yes. 3 Q And did you address that situation with her? 4 A No.
5 Q Was there a reason you made a notation about a rash on 6 her legs on January 26th of J 989? 7 A Yes. 8 Q Okay. And what would be the reason that you would make a
9 notation about a rash on her legs?
10 A Anytime a patient gives me new infonnation about their
11 medical history, I try to note it in the chart.
1.2 Q Then there I s a series of letters that follow the word
13 "legs." First of all, what are those lcners?
14 A "H'1 and 11C." That has to do with again asking her if
15 there were any hot and cold symptoms witl1 her teeth.
16 Q And does it say that they're okay?
17 A Yes.
18 Q Okay. What is a homeopathic?
19 A A homeopathic is a substance that is made up nnd
20 prescribed homeopathic method. I don't know how to ...
21 Q Is it appropriate to use the tenn '1prescribe" in
22 connection with homeopathies?
23 A No.
24 Q Did you provide Kathy Parsons \\·ith homeopathies during
25 the time period she treated in your office?
l A Yes.
2 Q And how are homeopathies made?
3 A They are made from a base substance, through a serial
4 dilution process.
5 Q Is the Intero device involved in making•homeopathics?
6 A No.
7 Q Is there any device that is necessary in order to create
8 or make homeopathies?
9 A No.
10 Q What is a "serial dilution process"?
11 A You take an original what is called a mother tincture
12 solution -
13 Q Can you spell that, please?
14 A T-I-N -- I'm not a good speller.
15 Q Just trying to help out the court reporter.
16 A -- N-C·T·U-R, I believe.
17 MR. SULLIVAN: T+N-C·T·U·R·E. Tincture.
18 THE WITNESS: Thank you.
19 MR. SULLIVAN: Sure.
Page 48
20 A And from that solution, you take one part of that to nine 21 parts of water and redilute, and you continue that 22 process. ··
23 Q The mother tincture solution, does that come in a small
24 vial?
25 A Urnm, no. With homeopathies, usually you do not have the
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Page 49 Page 51 1 mother tincture solution unless you are specifically 2 making that homeopathic yourself. 3 Q Okay. 'Why is the dilution process important? 4 A Toe body appears to respond to different potencies of -5 homeopathies differently. 6 Q So as the _.: Does the patient take one potency of the 7 homeopathic, and if it doesn't respond properly, it's 8 diluted further? Is that how it works? 9 A Not exactly.
10 Q Okay. Ex.plain to me how it works. 11 A Umm, the nonnal course of a homeopathic treatment, you 12 would start at a particular potency, the person would 13 respond, and then you I d go to another increasing potency, 14 and you go through a series till you get the desired 15 effect. 16 (Exhibit marked for identification as 17 exhibit 2.) 18 BY MR. BOURESSA:
19 Q I'm going to show you what the court reporter has marked 20
21
22 ., .. -J
24
25
A
Q
as exhibit number 2, and I'll?-not going to ask you to identify the document, because I know you haven 1t seen it before, but 11111 going to ask you whether you recognize any of the homeopathies that are listed on exhibit 2. I do recognize some of these. Do you recognize certain of those homeopathies as being
Page 50 1 homeopathies that were provided to Kathy Parsons? 2 A No, I do not. Some may. I don't remember. 3 MR. BOURESSA: Do you want to take a break, or 4 do you want to go right up until --5 MR. SULLIVAN: Sure. Well, let's take a break. 6 This is a good spot. 7 MR. BOURESSA: Let's take a break. 8 THE VIDEOGRAPHER: You're off the record. 9 (Break taken, 11:36 until 11:55 a.m.)
10 TIIE VIDEOGRAPHER: You' re back on the record. 11 MR. BOURESSA: Thank you. 12 BY MR. BOURESSA:
13 Q Going back to Dr. Galvez for a minute, did you ever speak 14 with Dr. Galvez regarding Kathy's situation? 15 A I don't recall. 16 Q Do you know whether Dr. Galvez provided Kathy with 17 homeopathies? 18 A Again, I don 1 t recall. 19 Q Before you inserted the IRM temps, did you do any 20 preparation to the teeth -- to the teeth where the IRMs
21 were placed?, 22 A Yes. I just -- 'l removed the existing resins. 23 Q Did you do anything else in preparation for the temporary 24 fillings, other than the removal of the existing resins? 25 A No.
1 Q
2
3
4 A
5 Q 6 7 A
8
9 Q
10
11 A
12 Q
13 A
14
15
16
17
18
19 Q
20
21 A
22 Q .., .. _., 24
25 A
1
2
3 Q
4
5 A
6
7 Q
8
9 A
10 Q
11
12
13 A
14
15 Q
16 A
17 Q
18
19 A
20 Q
21 A
22 23 Q
24 A
25 Q
Explain for me, in as much detail as you ·can. how you
prepare a homeopathic. There is a preparation process:
correct? In other words --
Yes.
-- you just don't take a bottle of the homeopathic: it's
got to be mixed or something?
The question -- Yau mean me personally, or how
homeopathies are made?
Well, let's start with the more general question of how
they're made.
Again, you start with the mother tincrure solution.
What fonn does that-take, a mother tincture solution?
Umm, I -- I don't know that part of it, because I pretty
much have used the prepared solutions. But you could,
theoretically, you would have a strep, if you're making
it from strep, they would have a culture of strep, and
then they would start diluting it. the same way that you
do like for a vaccination, vaccines, same process.
Do you provide patients like Kathy with homeopathies from
your office?
I do on occasion.
'What fonn do they take? What are they -- I mean,
what do -- How arc they administered, and what do they
come in? Are they in a container?
Two fonns. We have the ones from -- that come in vials,
Page 52 that you give people, and then they can be made
energetically.
When they come in vials, is there a set potency for that
vial?
You can get all one potency, you can get a series of
potencies.
And then how does -- bow is the homeopathic that comes in
the vial administered to the patient?
Sub lingual.
I'm not sure that I understand - I understand what that
means, but I'm not sure, practically, what that means.
How is it physically administered?
If it's a class vial, you pour it into a cup, put it
under your tongue, let it sit there, and swallow.
Okay.
Okay? Same as you would with nitroglycerin, okay? Okay. You also said that some homeopathies can be made
energetically? Is that what you said?
Yes. What does that mean?
The Intero computer will store the infon:nation and can be
made into a water solution. What information does the Intero systein store?
I don't know. That's proprietary toward them.
Okay. What do you physically do to energetically make a
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Page 53 1 after the energization has been completed?
2 A You put a bottle of, usualiy, distilled water, and then 2 A No.
Page 55
3 the computer will make that into a homeopathic. 3 Q What fonn does the source materia_l take when it's put in 4 Q Okay. \\'here do you put the distilled water? 5 A In a bottle. 6 Q Okay. Andtthen where's the bottle placed in relationship 7 to the lntero? 8 A It's on a tray. 9 Q And then what does the Intero do to the distilled water
IO to turn it into a homeopathic?
4 the well? 5 A It can be physical liquid. 6 Q In a vial? 7 A Can be in a vial. 8 Q What else could it be in? 9 A Paper cup.
10 Q Okay. But the actual solutions aren't transferred from 11 A I don't know. That's proprietary. 11 one source to the other; I mean, you don't physically 12 Q Is it some sort of-· Just generally, is there some sort 12 have the contents of the vial go into the distilled water 13 of electrical stimulation? 13 by some means? 14 A 1 don't know. 14 A Correct. 15 Q You don't have any idea. Okay. Does the bottle of 15 Q Okay. 'When you're all done you have distilled water on l 6 distilled water, is there any visible change to it after 16 one side, and you still have a remaining vial of some 17 the Intero -· 1 7 sort of liquid on the other -- in the other well? I 8 A No. 18 A Correct. 19 Q -· energizes it? 19 Q Did you ever provide Kathy Parsons with such a device so 20 A No. 20 that she could make homeopathies on her own? 21 Q Can homeopathies be energetically created by means other 21 A I had a device in my office for a while, that I did give
. -22 than with an Intero device? 22 to her. 23 A There were other devices. I don't know if there still 23 Q Okay. And did you instruct her on how to use it? 24 are. 24 A For as much as I knew. 25 Q \Vhat other type of devices were there? 25 Q Was there any kind of instructions that \>\'ere with it?
lA
2 Q
3
Urnm, I'm not even sure what the name was.
Well, can you describe what they are and bow they
function?
Page 54
4 A
5
Basically, it would be something where you would have two
separate wells with electrical wires going in between.
6
7 Q
8
9
10 A
11 Q
12
13
14 A
15 Q
16
That's as much as I know.
Is the theory, at least, behind that. method of energizing
homeopathies the same as the theory behind what the
lntero device docs?
I'm not sure. So you've got a device with t'Wo wells, you put distilled water in one side, the homeopathic in the other? Is that
what you're saying? In the other well?
Your source material.
Source material. Okay. And then there is some sort of
electrical connection between the distilled water and the
17 source material?
18 A Mm-hmm.
19 Q And then this machine is turned on or-· \\That does -· 20 A There is an energy transfer. That's all I know about it.
21 Q Okay. What is the source of the energy that \his device
22 uses? 23 A ldon'tknow.
24 Q And in that process. is there anything visible that 25 l1appens to the distilled water and the source material
Page 56 l A No.
2 Q Where did you acquire this device?
3 A I don't remember.
4 Q Did you use it on any regular basis, or did you rely on
5 your lntero device to energize the homeopathies?
6 A I relied mostly on bought homeopathies and Intero.
7 Q So you dido 't do a lot of energization, if you will, in
8 your office?
9 A No.
10 Q These -- On exhibit number 2, these listings under
11 homeopathic ampoules, A-M-P-0-U-L·E •• and I don't know
12 if one of them is a better example than another, but are
13 the ampoules the equivalent of a vial; do you know?
14 A It should be.
15 Q Okay. And then these particular source materials are
16 designed to address certain ailments; is that correct?
17 A Umm, not necessarily.
18 Q Why would - Why would one take a bomeopathlc, other
19 than to address a physical ailment?
20 A To open up the lymphatic systems.
21 Q Okay. Any other reason a person would take a
22 homeopathic?
23 A Uh, yeah. They can be used for treating specific, Ulmn,
24 you know. things.
25 Q Was Kathy instructed as to which type of homeopathic
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. Rich~d L. Vanderheyden Condense It! ™ Page 57
1 would be appropriate for certain types of symptoms that 2 she may be experiencing? 3 A I lrnow when I gave her the homeopathic for the resin from 4 Dr. Cook, I had explained that. 5 Q Okay, Let's tum back to the chart, if we can. I'm now 6 looking at the date of March 23rd of 1989. It looks like 7 you1re working on teeth numbers 4, 5 and 29; is that 8 correct? 9 A Yes.
10 Q Okay. And what are you doing with regard to those teeth? 11 A Inserting dicor inlays. 12 Q And what is dicor inlay? 13 A A dicor inlay is an all -porcelain filling. 14 Q Did you do anything to prepare the tooth -- Strike that.
15 Was the.dicor inlay intended to be a pennanent filling or 16 temporary? 17 A In layman's tenns, a permanent filling. I will argue the 18 point that gold is probably the only real truly permanent 19 filling. 20 Q Okay. Was cost a factor in detennining to use dicor as 21 opposed to gold? 22 A No. 23 Q Okay. What was the reason gold was not. used, if you feel 24 that1s the only appropriate permanent filling? ~5 A Yes, I felt that was the only appropriate penn~nent
1 filling.
2 Q You inserted -- What is dicer?
3 A Dicor is the porcelain.
4 .Q Okay. Why did you choose porcelain over gold?
5 A There was concerns, on the courses that I was taking in
6 Germany, that people can react to all sorts of metals,
7 including gold. Kathy had had numerous things, so I
8 wanted to try to go to the absolute best biologic,
9 without trying to get into any complications, that we
10 _possibly could. 11 Q What courses did you take in Germany?
Page 58
12 A No, that was the Germans, Dr. Voll and Dr. Thompson, who
13 was with Dr. Voll at the initial lecture.
14 Q Those are the courses you originally discussed with me
15 earlier?
l 6 A Correct;
17 Q And was any preparation of the tooth -· of these teeth,
18 4, 5 and 29, done before the dicer inlays were placed?
19 A Yes,
20 Q What was done? 21 A The temporary was removed and an impression taken.
22 Q Okey. Were there any other steps, other than what you've
23 just described, that were done to prepare the tooth
24 · before the permanent filling was put in place? 25 A The only other possibility, if there would be a slight
]
2
3 Q 4
. 5.
6 A
7 Q 8 A
9 Q 10
11
12 A
13
14 Q 15 A
16
17 Q
18
19
20 A
21 Q
.22 A
23 Q
24
25 A
Page 59 undercut in a preparation, that would be straightened out. Okay. Did you utilize a sedative-based cement to insulate the nerve before the pennanent filling was placed? No. I'm sorry? No. Is that something you nonnally would not do, or was there some special consideration giving that you didn't do it in this case? I routinely will not do that in people that express chemical sensitivity. And what is your reasoning behind that? The bases that are used, they contain certain chemicals that a person could react to.
Then it indicates, on the 23rd, that you -- It appears to read that you took impressions, or that impressions were taken?
Yes. And are those upper and lower impressions? Yes. And what was the reason impressions were taken at that time? That would be to look at the further treau11ent to restore
Page 60 l where any other missing teeth were. 2 Q And do you remember specifically what restorative work 3 you were anticipating that resulted in you taking the 4 impressions at that ti.me? 5 A No, I do not. 6 Q Did Kathy have tooth number 30 present in her mouth at 7 the time that she initially began treating with you?
8 A Number 30? 9 Q Yes.
10 A Yes. 11 Q Did you extract that number 30 at some point in time? 12 A Yes. 13 Q And when was that tooth extracted? 14 A 2-23-98. 15 Q And what was the status of that tooth at the time that it 16 was -- it was extracted? 17 A Irreversible pulpitis. 18 Q And what does 11pulpitis11 mean? 19 A Inflammation of the pulp tissµe. 20 Q · And what treatment options are available to a patient who 21 has pulpitis, other than extracting the tooth? 22 A Root canal therapy. 23 Q Did you discuss with Kathy root canal therapy in 24 connection with tooth number 30? 25 A Yes.
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, Rich~d L. Vanderheyden Condenselt! ™
Page 61 1 Q And what do you -- Strike that. Do you recall what you 2 discussed with her? 3 A Specifically? 4 Q Yes. 5 A _No. 6 Q Is there any notation regarding your discussion with her 7 about the extraction of tooth number 30? 8 A No. 9 Q Did you discuss a referral to an endodontist to perfonn
10 root canal therapy on tooth nwnber 30 before it was 11 extracted? 12 A I'm not sure. 13 Q I think you i11dicated -- and correct me if l 1m wrong --14 earlier that part of your practice does not include 15 performing root canal therapy'? 16 A Correct. 17 Q Was that true back in 188 and '89 also? 18 A
19
20 Q
21
22
23
24 A
I'm not exactly sure at what point I stopped doing them completely. Was the decision to stop doing root canal therapy based upon the fact that you yourself didn't feel competent to perfonn that treatment or that you didn't believe that such treatment, as a general rule, was effective? I just didn't like doing them.
25 Q Okay. On March 15th, 1989, you provided some further
Page 62 1 treatment to tooth number 30; is that correct? 2 A To tooth number 3 0 area. 3 Q Okay. Because the tooth was gone at that point. 4 A Correct. 5 Q What did you do in the area of tooth number 30 at that 6 time? 7 A Did a hand curettement of the socket site. 8 Q And what does that mean? 9 A That means you take ·a little spoon excavator, go into the
lO area, scrape a little bit, and reinitiate the bleeding 11 response. 12 Q Following the extraction of tooth nwnber 30, was Kathy 13 prescribed any medications, either for pain or for 14 potential development of an infection or irritation in 15 that area? 16 A No. 17 Q Your license does allow you to prescribe prescription 18 medications, does it not? 19 A Yes. 20 Q Including pain medications'? 21 A Yes. 22 Q Did you, as a matter of p~fosophy throughout the course 23 of your treatment of Kathy Parsons, not prescribe 24 prescription medications? 25 A I did when appropriate.
Page 63 1 Q Okay. Do you have a philosophy in your practice about 2 utilizing prescription medications for your patients? 3 A Yes. 4 Q Okay. And what is your philosophy about providing 5 prescriptions for treatment of conditions or for --
7
8 A
9
6 Strike that. What is your philosophy with regard to prescribing prescription medications for your patients? I try to prescribe prescription medications only when
necessary. 10 Q 11
12 A
13
14 Q
15 A
16 Q 17
18 A
19 Q 20 21
22 A
23 Q
24
25 A
I Q
2
3 A
4 Q
5 6 A
7 Q
8
9 IO
11 A
12 Q
13
14 A
15 Q 16 A 17
18 Q 19 A
20 Q
21
22 A
23 Q 24 A
25 Q
On March 27th, 1989, it says, "EAV. check homeo." \1\l11at does that mean? That means I was checking the homeopathies I had given her to help heal that area. And that was done with use of the lntero? Yes. Whenever we see the initials in your chart "EAV." does that mean you 're utilizing the Intero? Yes. Okay. Beginning in April of 1989, it appears, you prepared tooth number 12, 13 and 14 for porcelain inlays; i.s that correct? Yes. And are those porcelain inlays then inserted, it appears,
on May 10th of 189? Yes.
Page64 And I don't see 14 -- or am I just missing it? -- as
receiving a porcelain inlay. I do not see it either. Okay. But it appears that it was prepped for a porcelain inlay on the 19th of April 1 1989; correct? Correct. It appears, then, 011 May 25th of 19 8 9, and maybe even earlier than that, it appears that during that time frame, you were -- she was experiencing some problems with tooth number 19?
Yes. What kind of problems was she having with regard to tooth number 19? Pain. And what type of treatment did you provide her? Umm, tooth number 19 was previously extracted by a dentist, prior to coming to me. So again we're talking about the area of tooth number 19? Correct. Okay. I apologize. What type of treatment was provided to the area then? Surgical curettement. Was anesthetic also introduced into that area? Yes. Okay. And how was that introduced?
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. Richard L. Vanderheyden Condenselt! ™
Page 65 Page 67 l A Uh, typical ~veolar nerve block. 2 Q And where was the injection performed in order to address 3 the problems with tooth number 19? 4 A The typical lower alveolar nerve block prior to entering 5 the mandible. 6 Q So that injection is not made, then, in the socket or the 7 gingiva itself surrounding the area where the tooth was 8 extracted? 9 A Correct.
10 Q Okay. It appears as though the area around 19 continues 11 to be a problem through, oh, June and July of 1989?
12 A Yes. 13 Q Okay. And the problems she's having, again, are pain? 14 A Yes. 15 Q And the treatment that's provided is curetting the area? 16 A Yes. 17 Q And introducing anesthetic? 18 A (No response.) 19 Q Directing your attention to July 18th, 1989.
20 A July 18th. (Pause.) With anesthetic, yes. 21 Q Okay. And are you also attempting to address her 22 problems through ti1e .use of homeopathies? 23 A Yes. 24 Q Is that generally true throughout the time period that
25 you treated her, that you would address various concerns
Page 66 1 that she had with homeopathies? 2 A Yes, I used homeopathies to help the healing of the
3 mouth. 4 Q On August 15th, 1989, it appears some treaunent was 5 rendered to tooth number 18? Or is that -- Is that what 6 that shows? 7 A Yes. 8 Q Okay. And what -- what was the problem there? 9 A
10 Q
11 A
12 Q 13
14
15 A 16 Q 17
18 A
19 Q
Again, pain in that area. Okay. Was 18 present, or had it been extracted? (No response.) It appears it was one of the teeth that you initially filled with a zinc phosphate temporary filling on December 28th of '88. ls that correct? Yes. So what is being done with regard to tooth number 18 in
August of 1989'7 (Pause.) I'm not sure.
It appears that some curetting was done at that point; 20 correct? 21 A Correct. 22 Q And you don't specifically recall where or why that 23 curetting was being done? 24 A Con:ect. 25 Q Let me just ask you about a couple of abbreviations at
1
2
3 A
4
5 Q
6 A
7 Q
8
9 A
10
11 Q
12
13
14 A
15 Q
16
17
18
19 Q
20 21 A
22 Q
23 A
24 Q
25 A
l
2 Q
3 A
4
5 Q
6 A
7 Q
8 A
9 Q
10 A
ll_Q
12 A
13 Q
14 A
15
16
17
18
the top of that page. June 13th, '89. It appears to read
"CK s 1. ~ Or asking it another way, what is that entry?
Umm, that entry, we used 51 as a provider, me, when I was
doing more TMJ-related than the regular dentistry.
What about 11TPT stim," S-T+M?
That's 11trigger point stimulation."
And do you know what trigger points are being stiinula~ed
at that time, in June and July of 1989?
That would have been the three muscles that were
described before.
Looking at the final entry on the right-hand side of the
chart, appears to read "March 17th, 1989." Can you read
that entry into the record, please.
I'm sorry?
Pm asking you about the entry which appears to read
"March 17th, 1989 ." It• s on the right-hand side of the
chart.
MR. SULLIVAN: August?
I'm sorry; August. Looks like a "3" on 1ny copy. I
apologize: 8-17-89.
"8-17-89: Open, left open. Dr. Ratner technique."
And then continue with that entry. 11KVI, Org. insu-Rum." What does that mean?
Well, the "Ruta" in thnt would be homeopathic for
Page 68 healing. I'm not sure what the "KVI" stands for anymore. Who is Dr. Ratner, R-A-T-N-E-R? Dr. Ratner was a doctor that first described the NICO
type bone lesions. Can you spell the word you just used?
NICO?
Yeah? It1s N-I-C-O. And what does that mean? Neuralgia Inducing Cavitational Ostitis.
Okay. And was that condition present in August of 1989? Yes. And which tooth was affected by that condition? Umm, 19 for sure; possibly 18.
THE VIDEOGRAPHER: Excuse me; I must interrupt you. We are at the end of this videotape.
(Short break taken.) THE VIDEOGRAPHER: You're back on the record
19 with tape number 2. 20 BY MR. BOURESSA:
21 Q Directing your attention to July 27th, 1989, it,appears 22 that a lower impression was taken at that point: Is that 23 correct'] 24 A Yes. 25 Q And what was the purpose of the lower impression?
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Richard L. Vanderheyden Condenselt! ™
IA
2 Q
3 A
4 Q
5
6 A
7 Q
8
9
Page 69 As a study model to make a lower pain-relief splint. Was that for a TMJ-related problem? It was for her pain syndrome. And on -- Directly beneath that entry, the word "balanced" appears. What is the reason for that entry? (Pause.) I don't know. Moving up the page to June 27th, 1989, the word "balance/spleen II appears. What does -- Why does that entry appear?
IO A I'm not sure what the balance was, but Kathy was, at that 11 point then, mentioning something, she thought her spleen 12 was bothering her.
Page 71 l BY MR. BOURESSA:
2 Q Did you have· a conversation with her -- Strike that. As
3 part of your treatment with her in your dental office, 4 did you have conversations Vt~tb her about 5 _ non-dental-related problems, medical problems, that she 6 was having? 7 A Would you rephrase that one more time, please?
8 Q Sure. As part of -- Strike that. Let I s use the 10-9-89 9 entry as an example. You apparently discussed with her
l O problems she was having with her colon at that point; 11 correct? 12 A She brought up that she was having trouble with her
13 Q ls there something known as "balancing organs"? Are you 13 colon. 14
15 A
16 Q
17
18 A
familiar with that phrase'? I believe that's used in acupuncture. Okay. Did you ever engage in any activities designed to balance Kathy's organs? No.
19 Q Directing your attention to the entry of October 10th, 20 1989. Appears to read "IRM temps"? 21 A Yes. 22 Q Okay. \7\'hat is that -- What is the significance of that 23 entry? 24 A Uh, that would mean that I just added to, if some of the
14 Q Did you suggest to her that there was anything you could 15 do, as her dentist, to alleviate the problems she was 16 having with her colon? 1 7 A What I expressed was that I would treat her teeth. You 18 know, if other things happened, that wasn't -- you know,
19 could be related, could not be. Can't be proven. 20 Q Did you believe that treatment of dental conditions could 21
22 A
23 Q
24
alleviate other medical problems she was having? Other medical problems relating to ·sinus, yes.
25 temporaries were wearing do\\rn, I would just have added a , 25
Did you ever specifically tell her that providing her with certain dental treaunent could alleviate problems with her colon, for example?
Page 70 I little bit to them.
2 Q So as of October 10th, 1989, certain teeth still had the
3 IRM fillings in them that you put in back in December of
4 1988?
5 A Apparently.
6 Q And do you know which te.e1.h would have still had IRM
7 fillings in them at that time?
8 A I believe it would have been 29, 30, 31. (Pause.) Yes.
9 Q On October 9th, 1989, in the right-hand side of the
lO chart, could you read that entry, please.
11 A "Had relief after visit yesterday. Today her colon was
12 bothering her. Jaw improved with drops and relates to
13 colon."
14 Q What does "Jaw improved with drops11 mean?
15 A The homeopathic improved the pain she had in her jaw.
16 Q And then what does the balance of that entry mean, "and
17
18 A
19
20 Q 21 22 23 24
25
relates to colon"?
She expressed that it seemed that when the teeth were not
bothering her, her colon felt better.
Did you regularly discuss with Kathy problems -- medical
problems that she had that were non-dental~lated?
MR. SULLIVAN: Well, let me object to the fonn,
'What do you mean by "discusse.d"? We just have an example
of a patient making a comment to the doctor. I don't --
I don't know what you mean by "discussed."
l A
2 Q 3 4
5 A 6 Q 7
8
9 A
10
11 Q
12
13 14
15 A
16 Q
Page 7'2 I do not remember doing that. There are entries throughout your record about submitting documentation to housing allowance. First of all, am I correct with regard to that statement? Yes. And what was the -- Can you just explain to me how housing allowance, at least as you understood it, is involved in your treatment of Kathy? Just to do with the amount of money that she spends in my office. In your answers to interrogatories -- specifically, interrogatory number 14 -- you set forth the extractions that you perfonned and the dates you performed them. Do you see that? Yes. Okay. And did you -- Strike that. As to each of those
1 7 extractions, did you conduct certain testing on those 18 teeth to determine whether those teeth were vital before l 9 they were extracted? 20 A Yes.
21 Q And was the same type of ~sting done on each occasion? 22 A Yes.
23 Q And is that the testing that you previously discussed 24 with me, the --25 A Yes.
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Richard L. Vanderheyden Condenselt! ™ Page 73
1 Q ·-pulp testing, the percussion testing and the
2 hot-and-cold testing?
3 A And-symptom review.
4 Q Okay. What do you mean by "symptom review"?
5 A Umm, how much pain she was having, how long was the pain,
6 responses.
7 Q Did you ever extract a tooth simply because of a pain
8 complaint, without doing vitality testing on the tooth?
9 A To the best of my knowledge, no.
10 Q Directing your attention to entries of March 13th, 1993.
11 A (Pause.) Yes.
12 Q Okay. On that date, did you extract certain teeth?
13 A Yes.
14 Q And did you extract teeth 7, 8, 9 and 10?
15 A Yes.
16 Q Do you have charted, in connection with those
17 extractions, vitality testing or symptom review that
18 occurred at or about the time the extractions took place?
19 A No.
20 Q Do you know why you extracted those teeth at that time?
21 A We extracted those teeth because she was still having
22 some symptoms with them and was having a great deal of
23 difficulty with wearing the upper partial, and we had
24 discussed that the upper denture would be probably a
25 better appliance for her than trying to keep those teeth.
Page 74 1 And I believe I had talked to her about keeping those 2 teeth. 3 Q Do you have a specific memory of discussing with her the 4 alternatives to extraction as to 7, 8, 9 and 1 O? 5 A No. 6 Q Is there anything in your chart which would reflect the 7 discussion you had with her before those teeth were 8 extracted? 9 A No.
10 Q Were those teeth vital at the time they were extracted? 11 A I do not know. 12 Q In an attempt to shortcut this, Doctor, rather than 13 attempting to go through each individual extraction, let 14 me ask you this: Do you have a specific recollection of 15 any conversations with Kathy Parsons regarding proposed 16 extractions as you sit here today, as to any of these 17 e:l\.1ractions? 18 A Specific? No.
19 Q Sp~cific to that particular tooth being extracted at that 20 particular time. 21 A No. 22 Q Okay. So ifl were to go through and ask you what 23 conversation did you have with Kathy· Parsons before you 24 extracted tooth number 15, other than what may be your 25 standard protocol, you couldn't tell me specifically what
Page 75 1 was discussed; is that true? 2 A Correct. 3 Q Is it also correct that you did not specifically chart 4 the results of the testing that you did on those teeth at S the time they were extracted? 6 A Correct. 7 Q And when you testify about the tests you performed, is it 8 · correct that you were testifying based upon what you 9 typically would have done in the same or similar
10 circumstances, with regard to testing, before extractions 11 take place? 12 A Yes. 13 Q And when I ask you questions about conversations you may 14 have had with Kathy leading up to the extractions, would 15 it again be correct that you're testifying about what 16 your standard practice was in connection with discussing 17 extractions with patients at the time the extractions are 18 anticipated? 19 A Yes. 20 Q Okay. At some point in time, did you discuss with Kathy
21 that she was destined to lose all of her pennanent teeth?
22 A Uh, I would have to say yes. We ended up with full
23 dentures, yes.
24 Q Do you recall having a discussion with her where you
25 explained to her that she -- Strike that. Did Kathy at
1
2
3
4 A
5 Q 6
7 8 A
9 Q 10
11 A
12
13
14
15 16
17
18 Q 19
20 A
21 Q 22
23
24 A
25
,. Page 76 some point have an option of attempting to save permanent teeth as opposed to having them extracted in anticipation of dentures? Yes. Okay. And what do you -- If I asked specifically when you had that conversation and specifically what was discussed, would you be able to tell me? No. Okay. If I asked you generally what you recall about what you discussed with her, what do you recall? I recall, particularly when we had the first extraction, looking at the options and her expressing that she had problems with the previous root canals that were done, and that she did not want root canals, and at that point, umm, the option did not seem that she wanted a root cao1!1 at all, and we went through that the only choice, when a tooth dies, is to extract or to do a root canal. Is it your testimony that all of the teeth that you extracted were dead? No. Can you sit here today and tell me specifically which teeth were vital and which were dead at the time they were extracted? The teeth that could have been vital at extraction would have been 7, 8, 9, 10, 24, 25 and 26.
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· Richard L. Vanderheyden Condenselt! ™
Page 77 lQ And I take it, then, it was determined that despite the 2 fact that they were vital, that a decision was made to 3 extract them so that the option of denture could be 4 pursued? 5 A Yes. 6 Q Did any of the teeth that you extracted still have the 7 IRM fillings in them? 8 A Possibly. Do you want me to go through all my notes? 9 Q Yeah. Well, do you know, without having to go through
10 the entire time period of when you treated her, which 11 would have still had IRM fillings in? 12 A If any, it would have been 29, 30, 31. 13 Q With the rest of those, the rest of the teeth, is it your 14 testimony that they were replaced with the porcelain 15 inlays? 16 A I believe so, yes. 17 Q And with regard to any of the teeth that were -- had the 18 IRMs replaced with porcelain inlays, is it true that as 19 to none of those teeth, you would have used a
20 sedative-based cement? 21 A Correct. 22 Q Is it your position in this case, Dr. Vanderheyden, that 23 Kathy Parsons forced you to extract teeth that you 24 were -- that you refused to extract? 25 A Yes.
Page 78 l Q And by what means did she force you to do so?
2 A Begging to be out of pain.
3 Q Were there instances where Kathy was begging you to get
4 her out of pain where you disagreed that it would be
5 appropriate, given the presentation of the tooth absent
6 the pain complaints, to extract it?
7 A Yes. 8 Q And if I asked you which specific extractions those were.
9 could you tell me? 10 A On number 29, we're absolutely sure it's documented.
11 Q Okay. Okay. Tell me what you documented with regard to 12 tooth number 29, which apparently you extracted on
13 March 7th of 1990. If you would just address the chart
14 and what appears in the chart that ties into your prior
15 answer.
16 A Okay. Uinm, on 1-31 of '90, Kathy wanted me to check
17 tooth number 29, and I could not find anything. That's
18 why I have the note "asymptomatic." Then on 2-1 of '90, 19 we had found that the gingival tissue was sore around
20 that tooth. 21 Q Which, if I can interrupt you, would you not be
22 sufficient, in and of itself, to warrant an extraction;
23 correct?
24 A Correct.
25 Q Okay.
Page 79 l A Then on 2-20 of '90, I curetted the tissue around 29; 2 2-21-90, I curetted the tissue; 2-22, I curetted. the 3 tissue; 2-25, I did a pulp test, and at that p_oint the 4 tooth was testing as vital, and curetted it that date. I 5 did the same again on 2-26, 2-27, 2-29, on l ·30. On 3-5 6 of '90, we discussed the pain not subsiding. I did 7 another pulp test. At that point, it was showing 8 nonvital. We discussed root canal versus extraction 9 again. On 3-6 of 190, I opened it up and filed the
10 tooth, and then on 3-7 of '90, we extracted it. 11 Q When you say you opened it and filed the tooth, was that 12 to institute a root canal procedure? 13 A Yes, that is the start of a root canal procedure. 14 Q Did you finish the root canal? 15 A No. I would have ref erred out to an endodontist if that 16 was her choice at that point. 17 Q So you began a root canal on March 6th? 18 A Correct. 19 Q And the decision was made to extract on March 7th? 20 A Correct. 21 Q Was some sort of filling material used in the area that 22 was filed out on the 6th of March, or was the tooth left 23 open? 24 A I'm not sure. 25 Q And if I'm understanding you correctly, then, it 1s your
Page 80 l testimony that you advised Kathy against having 29 2 extracted? 3 A Yes. 4 Q And you told her she should go see an endodontist? 5 A I'm not sure I specifically told her to go see one. We 6 went over the option again. 7 Q If you were going to refer her to an endodontist for the 8 root canal, why did you begin the procedure on March 6th? 9 A To get her out of pain.
1 O Q Did Kathy refuse to go see an endodontist? 11 A Yes. 12 Q And is that charted anywhere? 13 A No. 14 Q Who did you refer her to? 15 A I didn1t refer her, because she did not want to have the 16 root canal.
17 Q As a -- As a dentist, isn't it true that~ at any point 18 in time, you can refuse to provide treatment to a patient 19 if you don't feel it's in the patient's best interest? 20 Yes.
21 Do you believe it would appropriate to extract a tooth 22 simply based upon a pain ~omplaint? 23 A No.
24 Q So did that tooth go from essentially being vital to 25 non vital between March -- excuse me, January 31st and
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Richard L. Vanderheyden Condenselt! TM
Page 81 1 March 6th? 2 A According to electrical pulp testing data, yes. 3 Q Did you utili~ the Intero in any way in connection with 4 the diagnosing the condition of tooth number 29? 5 A· No. 6 Q And I may have asked you this already, and if I did, I 7 apologiz.e. Have you ever used the lntero device to 8 diagnose the condition of a tooth when giving 9 consideration to the extraction of that tooth?
10 A I'm not sure I can answer the question the way you stated 11 it. 12 Q Okay. All I'm trying to find out -- and I can follow up, 13
14
15
16
17
18 A
19 Q
20 21 A
22 23 Q 24 25 A
if you can just give me an answer to the general question -- is whether the Intero device is utilized in any fashion in the -- in your process of diagnosing the condition of a tooth when you 're trying to determine whether it's appropriate for extraction or not. In the general terms that you're saying, I would say yes. In what -- What do you utiliz.e the Intero device for? What di~onostic role does it play? I would use it only just to confinn the diagnosis I retrieved from the clinical evidence that was present. Which is the tests we've discussed throughout this deposition? Yes.
Page 82 1 Q Okay. Okay. Any other specific extraction that you 2 recall refusing to perform the extraction because you did 3 not feel it was in Kathy's best interests? 4 A No. 5 Q Would it be fair, as a general statement, that following 6 the final series of extractions you performed on --7 appears to be November 8th of 1994, that the majority of 8 :the treatment you rendered was TMJ-related? 9 A Yes.
1 0 Q After her teeth ·were extracted, did Kathy express 11 difficulty wearing her dentures? 12 A Yes. 13 Q And throughout the ti.me period following the extractions, 14 up until she finally left your practice, were efforts 15 made to adjust the dentures so that they would be more 16 comfortable for her? 17 A Yes. 18 Q Do you believe you were successful in fitting her with
19 dentures that fitted properly and were comfortable for 20 heruse? 21 A No. 22 Q And is that because you feel you weren't given the 23 opportunity to do so because she left your practice, 24 or --25 A In part.
1 Q 2
3 4 A
5
6 Q
7 8 A
9
10 Q
11
12
13
14 15 A
16
17
18
19 Q
20
21
22. A 23
24
25
Page 83 Okay. What is -- What is the reasons that you believe
you were unable to achieve a satisfactory result with the dentures that you provided for her?
Because Kathy was uncooperative about following the
treatments that I wanted to do.
Okay. What treatments did y9u want to do that she was uncooperative about?
Umm, when we were having relines she wouldn I t wear them enough, different things of that nature.
Okay. I'd like for you to be as specific as you can in
terms of what steps you believe Kathy did not take as she
was instructed to take, which you feel contributed toward
the improper fitting of the dentures. I'm trying to get
more specific as to the "things of that sort" answer. Yes. And it's hard to get specific. There were numerous
times that I had wanted to reline, and she would come in
and say, "Oh, I'm too sick. You can't do that today,"
and that happened very frequently.
Anything else that you feel Kathy did or failed to do
which contributed towards the improper fitting of the
dentures? We had discussed her bone loss, nutrition, and she had
informed me that she was working with other people on her
nutrition, and also had said that she did not follow up
with what they said, often.
Page84 1 Q And what -- what role do you believe nutrition had to
2 play in connection with the proper fitting of her 3 dentures? 4 A It could have contributed to the bone loss. 5 Q And what bone loss are you referring to? 6 A The generalized alveolar bone loss after the extractions. 7 Q And did you provide her -- Strike that. Did you advise 8 Kathy that she needed to follow certain nutritional 9 guidelines in order to avoid generalized bone loss
l 0 following the extractions? 11 A It was discussed. 12 Q And was it charted? 13 A No. 14 Q What was discussed, again, based upon your best 15 recollection? 16 A That she appeared to be having more than normal bone 17 loss, which is why we had to reline frequently. And that 18 was my concern. 19 Q But specifically, what nutritional advice would you have 20 given her -- Strike that. I'm not so sure you answered 21 my last question, and that is: Did you explain to Kathy 22 the importance of nutrition in attempting to prevent 23 further bone loss? ' -24 A Yes, I believe I did. 25 Q And what, specifically, did you tell her about that?
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Richard L. Vanderheyden Condenselt! ™ Page 85
1 A That if the bone kept deteriorating, it would be harder Page 87
1 Q I just -- Well, let's go both ways. During your 2 and harder to fit dentures. 3 Q What type of nutrition -- nutritional guidelines did you 4 provide her in order to assist her in addressing the bone 5 loss issue? 6 A She had expressed that she was working with other people 7 and that she was working with nutrition on her own.
2 treatment, did you consult with other health care 3 providers that she was dealing with? 4 A Unun, yes. 5 Q Who? 6 A I had talked to Nancy V anden Put. 7 Q Okay. And who is she?
8 Q If she had not told you that, is nutrition counseling 8 A She was a lady that was dealing with the nutrition. 9 part of what you did as a dentist? 9 Q Okay. Anyone else that you recall talking to during hei
10 A Umm, rarely, I will suggest ~PJ"tain supplements for 1 O treatment? 11 people. 11 A Dr. Sturgis, Dr. Van Allsburg. 12 Q Wnat supplements assist in retarding bone loss? 12 Q Now let Is shift gears into the time frame after she left 13 A Uh, the literature shows that your calcium, magnesium, 13 your practice. Have you spoken with any health care 14 boron. There are some other elements in there. 14 providers about any care or treatment that she may have 15 Q Did you suggest that she take certain homeopathies in an 15 received after she left your practice? 16 effort to prevent bone loss? 16 A No. 17 A Yes. 18 Q Was she noncompliant with your suggestion that she take
17 Q Okay. ~ave you ever reviewed Dr. Cook's records? 18 A Yes.
19 homeopathies? 19 Q Okay. I'm going to show you a part of Dr. Cook's record 20 A I don't recall specifically. 20 entitled "Specimen Collection Data," and ask you if you
21 Q Was there any particular area where you appreciated a 21 know what that document is intended to reflect. 22 greater degree of bone loss than other areas following 22 A No, I do not. 23 the extractions? 23 Q Does that appear that -- And I don't want you to guess, 24 A I do not specifically remembei any one area. 24 but does that appear, based upon your experience, that 25 Q Have you reviewed anything other than your chart in 25 that's a urine test?
Page 86 Page 88 1 preparation for your deposition today? 1 A Umm, it's -- What I can get out of this is it looks like 2 A Anything other than my chart? 2 urine and salivary pHs. So looks like it would be a 3 Q Right. 3 urine and salivary. I'm not a hundred percent sure of 4 A Umm, the previous dentists' charts. 4 that. 5 Q And that specifically would be Dr. Cook and Dr. Kollath? 5 Q Do you have any idea at all why Dr. Cook would have 6 A Kollath. 6 conducted those tests? 7 Q Kollath? Anything else that you've reviewed? 7 A No. 8 A No. 8 Q Is that something you consider to be within the -- within 9 Q Okay. You haven 1t looked at any records relating to 9 the scope of the practice of dentistry?
10 Kathy's treatment after she left your practice, have you? 10 A I'm not sure what his intentions were. 11 A No. 11 Q Okay. I'm going to show you another page that I've 12 Q You haven't looked at any medical provider records during 12 tabbed. And what is the title of the document that 13 any th-ne frame with regard to Kathy's medical treatment? 13 you're looking at?
14 A Uh, I'm sorry -- 14 A "Standard Data Collection Fonn.11
15 Q That was a bad question. I apologize. Have you looked 15 Q And do you know what -- Are you familiar with that 16 at any medical records, excluding dental records from 16 document? 17 that definition? 17 A Yes. 18 A No. 18 Q %at is it?
19 Q Have you spoken with any doctors or dentists that Kathy 19 A Umm, this looks like the -- a record of EAV readings. 20 may have treated with i.n the last ten years? 20 Q Okay. Do those -- Does that tell you anything about 21 A Yes. 21 Kathy's condition at the point that those EAV readings
22 Q Who have you spoke with? 22 ' were taken? ,, 23 A Dr. Sturgis. 23 A Umm, not specifically. 24 Q Okay. 24 Q Okay. Did you ever supply Kathy Parsons with syringes 25 A Now, you're talking during treatment or after? 25 and anesthetic to inject sockets after extractions?
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_ Rlchard °L. Vanderheyden Condenselt! ™
Page 89 Page 91 1 A I do not recall doing that.
2 Q Does that mean it's possible that you may have?
3 A I don't ever remember doing that for anybody.
4 Q Do you have a recollection of ever supplying Kathy with
5 curenes to ~urette sockets after extractions?
6 A I don't remember doing it. That is possible.
7 Q Are curettes essentially a type of scalpel?
8 A No.
9 Q Describe a curette. You may have already done this, too,
10 but -
) 1 A A curette is an instrument-that has a very small little
12 spoon at the end of it.
13 Q And what do you do with it?
14 A Yau use that to either remove decay in a tooth, or in the
15 siruntion that we're discussing here, you would use it
16 just to scrape the tissue a little bit, to initiate
17 bleeding.
18 Q Were there occasions when you provided treatment to Kathy
19 in the fonn of lymph drainage?
20 A Yes.
21 Q What is lymph drainage?
22 A Umm, there's -- The lymph drainage tlmt I did, or what's
23 considered l)'1nph drainage?
24 Q Well, let's talk ubout the lymph drainage that you did.
25 A Okay. That would be to get the lymphatic draining out of
1 the head area, into the neck.
2 Q How is that accomplished?
3 A With basic massage types of techniques.
4 Q And what is massaged?
5 A The uh, the lymph nodes, lymph areas, and then also
6 certain muscles that would cause the lymphatics to be
7 constricted.
8 Q And having your lymphatics restricted is a bad thing?
9 A Yes.
Page 90
10 Q Okay. And what problems arise by having restricted lymph
11 drainage?
12 A You can have problems with healing and problems with
13 pain.
14 Q And again, I may have alluded to this earlier, but did
15 you ever place your hands on certain parts of Kathy's
16 body in an effort to balance her organs?
17 A I don't ever remember doing that.
18 Q Did you ever provide Kathy with homeopathies to treat
19 non·dental~related problems?
20 A No. 21 Q Did you ever manipulate or work on Kathy's sternum?
22 A Yes.
23 Q And what -- what did you do in that regard'?
24 A I tried to fr~ up the muscle attachments to it.
25 Q Did you do cranial-sacral treatments to Kathy?
1 A Yes. 2 Q And what are cranial-sacral treatments? 3
4
A Cranial treatments are a technique to allow the normal movement of the cranial bones.
5 Q Okay. And the sacral treatment involves what? 6
7
A Uh, that would be doing -- situation where you free up the sacrum.
8 Q 9 A
10 Q
11 A
12 Q
13 A
14 Q
Okay. And the sacrum is in your lower back? It is your tailbone. And that is a -- Is that a hands-on treatment? Yes. Did you perform acupuncture on Kathy? No. Did you refer her for acupuncture treatments?
15
16
A I do not remember referring her for an acupuncture treatment.
17
18
19
Q Do you recall at any point in time being aware, during the time period that Kathy was treating with you, that she was also undergoing acupuncture treatment?
20 A That sounds familiar, but, urnm, not specifically. 21 Q Did you ever treat Kathy for sinus problems? 22 A
23
24
I may have done some things to eliminate whether her pain in her teeth were coming -- would differentiate between sinus and teeth.
25 Q Did you ever provide homeopathies for treatment of sinus
l problems? 2 A I may have. 3 Q Did you ever treat rib spasms? 4 A No. 5 Q Did you ever perform injections on her feet? 6 A I don It remember ever doing that.
Page 92
7 Q Do you ever remember injecting scar tissue, for any 8 reason, while you treated Kathy? 9 A In the mouth, there were some injections.
1 0 Q Any areas other than the mouth where you may have 11 injected scar tissue?
12 A I don 1t recall. 13 Q Did you ever provide Kathy·with access to the Intero 14 machine, so that she could use it on her own?
15 A Yes, I did. 16 Q Did you provide her with instruction on how to utilize 17 the Intero at that time? 18 A Just the basic operations, how you ... 19 Q 'What types of uses did you instruct Kathy on with regard 20 to the lntero? 21 A I don I t remember. 22 Q Did you always make your chart entries contemporaneous 23 with Kathy1s visits? 24 A No. 25 Q Were there times when you would chart certain entries
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Richard L. V anderbeyden Condenselt! ™
1
2 A
3 Q 4
5 A
6 Q 7 A 8 Q 9 A
days after the visits had actually occurred?
Yes. And was that a practice of yours during certain time
periods that you were treating Kathy?
Yes. Did you ever treat Kathy Parsons in your home?
(Pause.) I believe I did.
On how many occasions?
I -· I can only think of once or twice.
Page 93
10 Q
11
Do you know whether you treated her nl both the Hawthorne
Street address and the Gwen address'!
12 A
13 Q
14
15 A
16
17 Q
18 A
19 Q
20 21
22 A ,, .. -J Q 24
25
I don't know.
'Vl'hnt type of treatment would you provide-to Kathy in your
home?
That would have had to have been something extremely
simple, like just to curene nn area.
Do you specifically recall the visits in your home?
No.
Well, assuming it was not your general practice to
provide treatment to your patient -- your dental patients
in your home?
Correct.
Would you agree that the frequency with which Kathy
appeared in your office, especially during the last
couple of years oi her care with you, was unusual?
Page 94 1 A Yes.
2 Q Was there a point nt which you refused to continue to
3 provide treatment to Kathy?
4 A Yes.
5 Q And -- And then you, thereafter, despite expressing your
6 desire not to treat her, did in fact continue to treat
7 her; correct?
8 A Yes.
9 Q And why was that?
lO A Because ~he begged.
11 Q Do you believe that the use of an lntero device in any
l 2 respect is consistent _with the standard of care for a
13 dentist in the state of Wisconsin?
14 A I don't know.
15 Q What about the providing of homeopathies? Do you believe
16 that's consistent with the standard of care for a dentist
17 in Wisconsin?
18 A Yes. 19 Q Do you know any other dentist in the greater Green Bay
20 area who provides homeopathies to their patients?
21 A Uhi Dr. Cook, I would believe.
22 Q Anyone else?
23 A Not that I'm aware of.
24 Q Are you familiar with the work of Christian Frederick
25 Honam.en as it relates to the laws of homeopathy?
1 A
2 Q
3 A
4 Q 5 6.A
7 Q 8
9
10 A
11 Q 12
13
14 A
15 Q 16
17
18 A
19 Q
20
21
22 A
23 Q 24 .25
1
2 A
3 Q
4
5 A
6
7 Q
8
9 10 A
11 Q
12
13
14
15 A
16 Q
17
18
19 A
20 Q
21
22 A
23 Q
24
25
Page 95 Umm, vaguely. Are you familiar with the laws of homeopathy?
Yes.
And where did ·- How did you become familiar with those
con~ts?
With the lectures with Dr. Voll.
Wnen you learned about BAV and homeopathy, did you learn
that those are two tools that should be used together
with one another?
Yes.
Okay. In other words -- Well. strike that. Is EA v
testing of any importance io the absence of considering
the use of homeopaths -- homeopathies; excuse me?
I'm not sure I understand the question.
Okay. Does the use of an lntero have any value, by
itself, when you're not using it to consider what-would
be an appropriate homeopathic remedy?
Yes. Okay. And what-· what specifically does the lntero
device allow you to do in the absence of considerations
of providing homeopathies?
To gain more infonnation about the oral structures.
A.nd we talked about the successive-dilutions concept with
hpmeopathics, I think briefly, and is there some sort of
shaking that bas to occur bet\.vecn the successive
Page 96 dilutions of the homeopathies? There are people that believe that is true.
Okay. And do you understand what their belief is in that
regard? Umm, my understanding of it is that that shaking is what imparts energy into it. So that would be a method of energizing the homeopathic, if you don't have an Intero or one of these other devices? That is standard homeopathic preparation. I guess I don 1t understand it. Is one way to energize homeopathies with the use of either an lntero or the other device you described. and the other's, what you call standard, the physical shaking of the homeopathic?
Yes. Okay. And is it correct that the higher the dilution of the homeopathic, the greater the potency of' the
homeopathic? Yes. Is it also correct that only one homeopathic remedy should be utilized at any given time with the patient?
I would say no. --
Okay. Do you believe that symptoms that a patient may experience should, in certain instances, not be suppressed, but rather should be allowed to continue to
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Richard L. Vanderheyden Condenselt! ™ Page 97
1 present themselves, as a healing method? 2 A Yes. 3 Q Are you familiar with the tenn "holistic" as it relates 4 to an approach to· treatment? 5 A Yes. 6 Q What does that mean to you? 7 A Well, the concept is to treat the body as a whole, not as 8 individual parts. 9 Q Do you believe that -- that, from a traditional medical
10 standpoint, if a particular symptom is treated and 11 suppressed, that that symptom may appear in another, 12 weaker area of the body? 13 A No. 14 Q Within the concept of holism or the holistic approach, do 15 you believe that a person's psychological makeup and 16 their physical makeup are one? 17 A No. 18 Q Are you aware that there may -- that certain persons in 19 the holistic field do believe that to be the case? 20 A Oh, yes. 21 Q Are you aware a, to whether or not either the American 22 Dental Association or the Wisconsin Dental Association 23 has recognized homeopathy as a recobrnized fom1 of dental 24 treatment? 25 A I'm not aware.
Page 98 1 Q Do you agree that a single dose of a homeopathic 2 treatment has effects for eight to twelve weeks? 3 A No. 4 Q Do you agree that it takes homeopathic treatments 12 to 5 24 months to gradually undo an illness that someone has 6 progressively developed over time? 7 A No. 8 Q Do you agree that upon taking a homeopathic, a person 9 should expect an aggravation or a healing crisis?
10 A No. 11 Q Would y~u expect a person starting on a homeopathic to 12 initially demonstrate an increase in symptoms? 13 A They may. 14 Q Is that a suggestion that the homeopathic is appropriate? 15 A It can be. 16 Q U a homeopathic is provided and no results are seen, 17 does that mean that it's the incorrect remedy for the 18 problem? 19 A Not necessarily. 20 Q As a person undergoes homeopathic treatment, are 21 flare-ups of their underlying symptoms desirable? 22 A No. ~ .. 23 Q When a person is -- Strike that. Are there certain 24 antidotes to homeopathies? 25 A Yes.
Page 99 l Q And would those include coffee, Anacin, Excedrin, as 2 examples? 3 A Yeah, if Anacin and Excedrin both have caffeine in it, 4 then it would be considered, yes. 5 Q Okay. Do you advise patients who you provide 6 homeopathies to stay away from those an antidotes? 7 A Yes.
8 Q Other antidotes things like Ben Gay, Tiger Balm and 9 Chapstik?
l 0 A I 1m not familiar with those. 1 J Q Do you believe that in providing homeopathies, one should 12 refrain from using medications unless it 1 s absolute} y 13 necessary? 14 A No. 15 Q Are you familiar with the work of Dr. Hal A. Huggins, 16 H-U-G-G-I-N-S? 17 A Yes. 18 Q Do you follow his work? 19 A By "follow," do you mean read or do things the way he 20 does? 21 Q I'll ask you the first question. Have you read his work? 22 A l 've read some of his work. 23 Q Okay. And do you do things the way he does? 24 A Not necessarily. 25 Q Based upon your knowledge of Dr. Huggins' work, did he
Page 100 1 believe that you can balance body chemistry by
2 nuLritional methods?
3 A Yes.
4 Q Do you agree that that's the case?
5 A I believe that nutrition can affect the body chemistry.
6 Q Do you know whether the American Dental Association bas
7 taken a position on whether nutrition is a proper means
8 to attempt to control body chemistry?
9 A I do not know.
10 Q Do you know whether the American Dental Association has
11 taken a position on the removal of amalgam fillings as a
12 means to address toxicity in the body?
13 A I'm not sure what their stance is at this point.
14 Q Are you aware as to whether or not Dr. Huggins has
15 advanced the theory that removal of silver amalgam
16 fillings can prevent muscular - well, let me strike
17 that -· that he believes ~t the removal of silver
18 amalgam fillings can prevent the onset of certain
19 diseases?
20 A I believe be believes that, yes.
21 Q Do you believe that to be the case?
22 A (Pause.) Yes.
23 Q And are there certain diseases you believe can be avoided
24 by the removal of amalgam fillings?
25 A Not specifically.
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Richard L. Vanderheyden Condenselt! ™ Page 101
1 Q . Does the presence of amalgam fillings contribute to the
2 onsel of Alzheimer's, in your opinion?
3 A No.
4 Q Do you know whether the American Dental Association has a
5 position that no dentist shall remove an otherwise
6 serviceable amalgam filling for the sole purpose of
7 curing a systemic disorder?
8 MR. SULLIVAN: Object to fonn. That's an
9 incomplete statement of their position. But subject to
10 that, you may answer.
11 A I believe they've made that statement.
12 DY MR BOURESSA:
13 Q Do you know whether the Journal of the American Dental
14
15 16 A
Association has stated that dental amalgam is a safe,
durable and cost-effective material?
They have.
17
18
19
Q Do you know whether or not the FDA •s Dental Products
Panel has found that there's no reason to remove amalgam
fillings?
20 A I don't know.
21
22 23
Q Do you know whether the U.S. Public Health Service has
found that there's no support that removal of amalgams
have a beneficial effect cm health? ., ~ _., A l don't know .
25 Q C~n the removal of amalgam teeth -- amalgam fillings
Page 102 l cause structural damage to healthy teeth? 2 A Yes. 3 Q Do you believe that electrical currents between various 4 metals in and on teeth cause irritations in the nervous
5 system? 6 A I believe it could. 7 Q Okay. Can EAV testing determine the ~ealth of an organ? 8 A No. 9 Q ls it used by some people to detennine the health of an
10 organ? 11 A I believe physicians, some do. 12 Q Have you ever been involved in injecting a homeopathic 13 remedy into an acupuncture point? 14 A Umm, no. I've injected anesthetic. 15 MR. SULLIVAN: Excuse me. 16 MR. BOURESSA: Take a break? 17 MR. SULLIVAN: We have three minutes on our --18 MR. BOURESSA: Let's go off. 19 THE VIDEOGRAPHER: We're off the record. 20 (Break taken, 1:38 p.m. until 1:54 p.m.) 21 TI-IE VIDEOGRAPHER: You're back on the record. 22 BY MR. BOUR.ESSA:
23 Q Are you familiar with the term "hololinguistics? 24 THE VIDEOGRAPHER: Would you please replace 25 your microphone.
Page 103 l MR. BOURESSA: Yes, I will. Sorry about that. 2 BY MR. BOURESSA:
3 Q Are you familiar with the term "hololinguistics"? 4 A Vaguely.
5 Q Are you familiar with a school of thought that 6 essentially states that the lntero device is able to 7 communicate with the subconscious? 8 A Umm, I've heard that. 9 Q That it taps into a storehouse of infonnation that our
10 conscious brain is not aware of? Do you believe the 11 lntero device has the ability to do that? 12 A No. 13 Q And that it can -- that the Intero device can answer the 14 body's questions? 15 A No. 16 Q That it can translate conditions into questions that you 17 can in turn ask the patient? 18 A No. 19 Q During the time period that Kathy treated with you, di~ 20 you ever prescribe prescription medications for her? 21 A Yes. (Pause.) Did you wa11t more? 22 Q Yes, I think you can anticipate my next question. On how 23 many occasions did you prescribe prescription 24 medications? Do you literally have to go through each 25 and every entry to make that determination?
lA
2 Q
3
4
5 A
6
7 8 9 Q
10 A
11 Q 12
13 A
14
15 Q 16 17 A
18 Q 19
20 A
21 Q 22
23 24 A
25 Q
Page 104 Yes, I do. Well, that's not productive. Do you have a recollection of the frequency with which you would have prescribed medications? Umm, I believe there was one pain medication that she was taking, called Soma, that I was not primary prescriber, but I believe I did, on occasion, prescribe some of that
for her. "What is Soma? It's a muscle relaxant. Other than Soma, do you have a recollection of prescribing any other medications? The only other thing I could think of is if we had used an antibiotic on occasion, but I'm not sure. If you prescribed an antibiotic, would that be reflected in your chart? Yes. Do you believe it's inconsistent to utilize homeopathies and antibiotics at the same time? No, I do not. Directing your attention to exhibit number 2. Did you provide this list of homeopathies to Kathy Parsons? Not the list, but the actual homeopathies themselves. I don1t remember. Can you state with certainty that these are not
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Richard L. Vanderheyden Condenscltt™
1
2
Page 105 homeopa1hics that you would have provided to Kathy Parsons?
3 A Uh, no, I can't.
4 Q What is a nosode, N-O-S-O-D-E?
5 A A nosode means that it is a homeopathic. that is 1nade up 6 from, umm, like a bacteria or a virus, something like 7 that.
8 Q Is it believed that certain homeopathies can address 9 problems that a patient experiences that come to them
1 O through heredity? 11 A Yes. 12 Q And is it correct that there are some homeopathies that 13 can address those hereditary problems as they relate to J4 the father's side versus the mother's side, for example? 15 A Yes. 16 Q And are there examples of that distinction on the list, 17 where that homeopathic would have been utilized in an 18 attempt to address a genetic problem that Kathy brought 19 to the table that came from one of her parents versus the 20 other? 21 A J don't see anything that -- You know, not that I'm '.:.2 aware of. 23 Q One of the homeopathies is Listed as "salt ,vater. 11 ls 24 t'1at a homeopathic that would have been prnvided to
25 Kathy?
Page 106 1 A Uh --2 Q Let me ask you this: ls salt water a homeopathic? 3 A Not that I Im aware of. 4 Q Okay. At any point in time during the course of your 5 treatment of Kathy Parsons, did you pro~1ide her with a 6 treatment plan? 7 A I do not see a treatment plan here. 8 Q What is a treatment plan? 9 A Uh, a treatment plan is an idea of what treatment that
1 o you 're going to render to that patient. 11 Q Are there patients with whom you have treatment plans?
12 A Yes. 13 Q And is that a formal, written description of the 14 anticipated treatment you' re going to provide to that 15 patient? 16 A Yes. 17 Q Is that a practice that you've developed over time, or is I 8 that something that you've always done; that is, the 19 prepai--ation of a treatment plan? 20 A I've developed that more over time. 21 Q And do you have an actual form, if you will, or some sort 22 of guideline that you use in developing a treatment plan 23 for a patient, so that you cover given i.ssues with them? 24 A Yes. 25 Q Do you believe that certain teeth can have EAV testing
Page 107 1 done on them and, in turn, reveal problems with other 2 organs in the body? 3 A No.
4 Q For example, in some of the reading I did, there was a 5 reference that the third tooth may have a special 6 re~ationship to the hip joint. Have you ever heard --
7 Regardless of whether you believe it or not --8 A Yes. 9 Q -- is that something you've heard of?
10 A Yes.
11 Q So that's not a practice you believe in; that is,
12 utilizing EA v testing on tooth structure to diagnose or 13
14 A
15 Q
16 17
18 A
19 Q
20 21
22 A
23
24 Q
25 A
appreciate problems in other areas of the body? No. Now, as I understood your prior description of the Intero, the person perfonning the EA v testing has a probe in their hand~ is that correct? Yes. And in connection with your use of the Intero in Kathyts situation, where would that probe be placed, specifically, in order to, uh, do the testing? Umm, the typical points are on the hands, and sometimes points are used on the feet. ls the probe ever piaced on the teeth? Yes.
Page 108 1 Q And what is being looked for when the device is placed on 2 a tooth? 3 A You're stimulating the tooth and seeing if there'll be a 4 response in the autonomic nervous system. 5 Q Okay. Is some sort of electrical impulse introduced into 6 the tooth structure from the probe? 7 A Into the bone by the tooth. 8 Q So it's actually placed on the gum tissue below the 9 tooth?
1 O A Correct. 11 Q Okay. And that is supposed to create a response in. the 12 body; correct? In the neurological syste1n, I think you 13 said. 14 A Correct. 15 Q And how do you appreciate that response? 16 A By seeing if they get a change in the reading. 17 Q Okay. And how do you know what, s causing -- what the 18 origin is that's causing the change in the reading? Or 19 don't you? 20 A You sometimes don't. You just know that there was a 21 response. 22 Q Okay. Do certain responses indicateJhat a specific part 23 of the neurological system is being affected? 24 A Well, not necessarily the whole neurologic system, but 25 certain specific points.
920-733-1835 HENES, PHILLIPS & WILLEFORD 1-800-434-39\5 Page 105: Page 108 Q 0
Richard L. Vanderheyden Condenselt! ™
Page 109 1 Q Can you give me an example of how you would place the 2 probe on the bony structure by a tooth and appreciate 3 that there is a specific neurological response within the 4 body and the origin of that response? 5 A Okay. If you had a reading in -- it's called the 6 "lymph 2 point, 11 arid then you stimulate -- and if this 7 reading was 50, for example, and you stimuiate in the 8 mouth and the reading shoots up to 70 or 80, something 9 happened.
10 Q Okay. And then are you able to pinpoint what happened? 11 A No. 12 Q And as I understand your testimony, the lntero does not 13 provide you \vi.th infonnation about the vitality of a 14 given tooth. Is that correct or incorrect? 15 A There are people that believe it does. I personally 16 don't believe that. 17 Q Did you ever provide either adjustments, manipulations or 18 therapy to any area of Kathy's body other than her oral 19 cavity and jaw and head? 20 A Neck, shoulders. 21 Q Okay. Did you ever adjust her hips'? 22 A No. 23 Q Did you ever use the probe on Kathy1s feet? 24 A 1 may have. 25 Q Does this lntero device have to be serviced or maintained
1 Q
2 A
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5 6 A
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Page 111 Are you speaking about her chemical sensitivity disorder? Yes. Are there p~ople who do not suffer from chemical sensitivity disorder that would be appropriate candidates for the Intero?
May be a candidate, but doesn't mean you would necessarily use it.
Okay. And is the Intero and the homeopathies always used in combination with one another? No.
Do you use the homeopathies without using the Intern? Yes.
I think I may have asked you this, and I don I t mean to be repetitive, I just want to make sure I understand. You use the lntero without the use of homeopathies? Yes. Okay. There are certain -- Strike that. You 're aware that Huggins is also a person who is adverse to the use of root canal therapy? Yes. And again, that is not a philosophy you follow -- is that true? -- that you 're not adverse to root canal therapy as a rule; you just may not do it because you 're not comfortable doing it? Correct.
Pagel10 l in any fashion?
Page 112 1 Q As a general question, are there things that you believe
2 A No. 2 Kathy did or should have done that could have allowed her 3 Q
4
Does it have -- you know, and I'm thinking about a computer, and maybe this is a bad comparison, but do you get software updates or infonnational updates about new uses for it or things like that?
3 to avoid the extractions that we've discussed in some 4 detail earlier?
5 6
7 A Umm, sometimes. 8 Q And does that come from the manufacturer, or do you see 9 that in other literature that you read on a regular
5 A 6 Q
7 A
8
9
10 basis? l O
11 A Things I had seen had come from the manufacturer. 11 Q
12 Q Do you use the Intero device on all of your dental 12
13 patients? 13
14 A No. 14 A
15 Q Do you use homeopathies with all of your dental patients? 1 S
16 A No. 16
17 Q 'What factors do you take into account when you decide 17
18 that you're going to use the Intero with a given patient? 18 Q
19 A 'When the person is not responding to the conventional, 19 A
20 you know, type therapy. 20
21 Q Okay. What was it about Kathy's condition, when she 21
22 entered your practice, that caused you to believe that 22 Q
23 the Intero device would be a valuable tool in treating 23
24 her? 25 A Because of her health history.
24 A
25
Yes. Okay. And what would those things be? Umm, she had expressed numerous times that she felt she had certain sensitivity to certain foods in certain groups, and then she would continue to eat those things. That was one of the main areas. And her then consumption of foods to which she was sensitive had what interplay with the deterioration of the teeth to the point where they needed to be extracted? Well, it's in a general fonn that I'm concerned with, where it would affect her overall nutrition. Not wearing the partials the way she should, which traumatizes the teeth more. Because of occlusal problems? Because of sometimes occlusal problems, but a lot of the time just felt that she was reacting to them and couldn't wear them. Okay. But I'm saying how does the partial affect the other teeth, which ultimately were subject to extraction? You 1re traumatizing the other teeth if you don't have the partial in there for full support.
920-733-1835 HENES, PIDLLIPS & WILLEFORD 1_;800-434-3915 Page 109 - Page 112 C) 0
Richard L. Vanderheyden Condenseit! ™
Page 113 I Q And that's an occlusal issue; right? 2 A Correct. 3 Q Okay. So she didn't follow proper nutritional 4 counseling; she didn't properly wear her partial, as you 5 suggested. Are there other things you believe she did or 6 should have done that could have potentially avoided the 7 extractions? 8 A I can't come up with anything right now.
9 Q Have you ever had a patient that you saw with the 10 frequency that you saw Kathy Parsons? 11 A No. 12 Q Throughout the time period that you treated Kathy 13 Parsons, through and including your final dates of 14 treatment, did you assure her that you would be able to 15 competently address her dental problems? 16 A I'm having trouble with the wording of that question. 17 Q Okay. Let me see if I can rephrase it. Did you, 18 throughout the course of your treatment of her, even 19 after the extractions had occurred and towards the end: 20 when you were having difficulty with the dentures, did
21 you attempt to reassure her that you would be able to 22 provide the dental care that she needed?
23 A Yes. 24 MR. BOURESSA: I think that 1s all that I have.
25 THE VIDEOGRAPHER: We 're off the record.
Page 114 (Discussion off the record.)
2 BY MR. BOURESSA:
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Doctor, is it correct that we1ve marked as exhibit number 1 the original of your chart as it relates to the care and treatment of Kathy Parsons? Yes. And does that include all the x-rays you had taken of
her? Yes.
MR. BOURESSA: Okay. That1s all I have. Thank
you. (Viitness excused at 2:19 p.m.)
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STATE OF WISCONSIN ) Page 115
) ss.
COUNTY OF FOND DU LAC)
I, Lee F. Behnke, Registered Merit Reporter and
Notary Public in and for the State of Wisconsin, do
hereby certify that the attached and fqregoing deposition
was taken before me at the Law Offices of Bouressa &
Patteson, S.C., in the City of Green Bay. Brown County,
Wisconsin, on the 28th day of January, 2000, A.O., at
10:04 a.m.: that it was taken at the request of the
adverse parties, upon oral interrogatories: that said
RICHARD L. VANDERHEYDEN was sworn to tell the truth, the
whole truth nnd nothing but the trutl1 relative to said
cause.
Dated this ~ day of February, 2000.
HEN'ES, PHILLIPS & WILLEFORD COURT REPORTING SERVICE
f"', ~ <t;-4., ... ,.;;· ~. \ \ 1 ~7 ... t p~~ 11 6
l S'rATEOFWISCONSIN CIRCUITCOUR. ·1 ~R.OWN.GQ~..--. i·? 1 i ·,J./':"'a:l. ,!":.:f7
KA Tiri' A. PARSONS, •· ..-, r.' /i • y _f_":-.:.. ;r~
4
Y~\ : .. \\. ,£~ (i . \t:"' ·,. I!.~,:) U -V:~-.; .. ,. S ·~ .. k"I/.
Ngp,~TuOF FIL~~:~~~c·~)/v· . ORIGINAL TRANsalPt"'-'~F· \t.i\Jv\ \ ~ ~ ,~
Plaintiff,
5 v. Case No. 99 CV S4B ......_~-
6 RICHARD L. VANDERHEYDEN, DD.S. and CONTINENTAL CASUALTY COMPAl\'Y,
7 Defendant. 8 ____________________ _
9 To: Clerk of Courts' Office Brown County Courthouse
10 Or:cn Bny, WI S4301
l l Attorney W. Patrick Sullivon Milwaukee, WI53202
12
13
14 PI.EASE TAKE NOTICE lrult the origirnll transcript of the
15 videompcd deposition of lllCHARD L. VANDERHEYDEN, taken
16 Jnnuary 28, 2000, ww; served upon Attorney Terence J.
17 Bourcssa, Green Bay, Wisconsin, as per Section 804.05 (7) of
1 B the Wisconsin Statutes.
19 Dated this~ day of Fcbrun.'}', 2000.
20
21
22
23
24
HENES, PHILLIPS & WILLEFORD COURT .REPORTING SER.VICE
V> 1i13.~ ~ ...:J·. ~JP,.) . ~-· Lee F. Behnke Rcgist.crcd Merit Reporter
25 ee: Attorney T crencc J. Bouressa
~20-733-1835 BENES, PHILLIPS & WILLEFORD 1-800-434-3915 Page 113 - Page 116
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920-733-1835 HENES, PIDLLIPS & WILLEFORD 1-800-434-3915 Index Page 1 "
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920-733-1835 HE~S, PIDLLIPS & WILLEFORD 1-800-434-3915 Index Page 2 0
Richard L. Vanderheyden Condenselt! ™ concepts - documented concepts c11 95:5 conversations [JJ 71 :4 currents c11 102:3 101:5 46:16 53:23.25 96:9 concern r11 84: 18 74:15 75:13 CV r2J 1:4 116:5 dentistry r121 4:2 8:9 9:3 diagnose r21 81:8 107:12 concerned r1J 112:14 Cook r1s1 24:24,24 25:l cylinder 121 34:3,4 11 :24 21: 19,23 22:2,7,25 diagnosing r21 81 :4,15 concerns £31 14:8 58:5 25:9,10,14 27:1.2,18 25:7 67:4 88:9
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920-733-1835 BENES, PHILLIPS & WILLEFORD 1-800-434-3915 Index Page~ 0
Richard L. Vanderheyden Condenselt! ™ doesE'tr21 49:7111:6 eligibler11 8:8 excusedr11 114:12 father 1sr11 105:14 Don (3J 18:17 19:1,2 eliminater11 91:22 exhibitc121 2:19,23.24 FDAc21 33:8,12 doner2s111:929:17 34:6 employerc11 18:22 3:I0,1149:16,17,20,23 FDA 1sr 11 101:l7 37:1238:239:24~:8,23 employmentc1118:2 - 56:10104:21114:3 Februaryc21115:16 55:15 58:18.20,23 63:14 endcsJ 31.2021 68.16 EXHIBITS[lJ 2:18 116:19 66:l 6,19,23 72:21 75:9 89 .12 113:19' · existing f2l 50:22 24 fi 6.15 76:1389:991:22106:18 · · • • eer11 . 107:1 112:2 113:6 ended r21 37:23 75:22 expec~ r21 98:9,11 feels r11 40:12
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920-733-1835 ~NES, PHILLIPS & WILL_EFORD 1-800-434-3915 Index Page 4 Q 0
Rfohard L. Vanderheyden Condenselt! ™ graduated - known graduated r21 7:19 8:19 hips r11 109:21 95:12 instructed [21 56:25 Grady f3I s:1,10 20:14 history £41 36:2 46:3 important r11 49:3 83:12 -J-grantedr11 21:18 47:l 1 110:25 impression [31 58:21 instruction c11 92:16 J [3] 2:4 1 I 6:16,25 great [4] 13:16 14:4,16 hold £21 8:23 12:6 68:22,25 instructions r11 55:25 Jack r11 18:23
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H [l] 47:14 48:25 49:5,23,25 50:1,17 24:10 32:15 33:3,5,7.11,16.20 67:1,8 69:7 51 :8,19 52:17 53:21 54:8 INDEX [21 2:13,18 34:7 39:22 40:2 44 :24 justified [IJ 42:24 H-U-G-G-1-N-S c11 55:20 56:5,6 63:12 65:22 45:4 46:4,15 48:5 52:21
99:16 66:1.2 85:15,19 90:18 indicate c11 108:22 52:23 53:7,9,17.22 54:9 justify r11 41:21
Hal [l] 99:15 91 :25 94: 15.20 95:13.21 indicated rsJ 1 O: 15 56:5,6 63:14.17 81:3,7.14 Hanamcn fll 94:25
95:24 96: 1,12 98:24 99:6 14: 19 24:23 36:2 61 :13 81:19 92:13,17,20 94:11 -K-hand [3J 34:3 62:7 107:17
99:11 104:18,22,23 105:l indicates r11 59:17 95:15,19 96:8.12 103:6 Kr21 17:18.21 105:8,12.23 110:15 111:8 individu.al r21 74:13 103:11.13 107: 16.19 handheld Pl 33:22 111:11,15 97:8 109:12.25110:12.18.23 Kathleen [3J 1 :2 2:5,21 handle r11 9:22 homeopaths [11 95:13 Inducing r11 68:10 111:5,8,11,15 Kathy rn1 2:20 6:9 17:5 hands r2J 90:15 107:22 homeopathy [41 94 :25 Interos r21 28:21.25 17:12,16,24 19:14.16.17
hands-on [11 91 :10 95:2,7 97:23 infected r21 37:21 43:13 interplay fl] 112:12 . 19:21 20:1 21:3 23:22
infection r11 62: 14 24:5.8,15,22 25:9,l 0.12 handwriting [21 18:7 hospital £61 14:21,24.25
Inflammation fl 1 60: 19 interrogatories cs1 3:4 25:17 26:2 27:12 33:17 37:24 15:2,6,9 10:15 14:19 72:11 115:11 34:20 36:11 40:3 44:1.10
HANNAN r11 2:6 hot r21 40:1 47:.15 information[9J 6:13 interrogatory [4] 6:12 45:12,21 46:2,22,25 47:24 25:23 29:4 47:10 52:21 hard r11 83:15 hot-and-cold [31 42:9 52:23 95:22 103:9 109:13 20:15 24:23 72:12 50:1,16 51:19 55:19 56:25
harder £21 85:1.2 42:12 73:2
informational [ll 110:5 interrupt c21 68:15 78:21 58:7 60:6.23 62:12,23 hours [3] 22:15 41 :13,21 introduced £41 41:10 69: l O 70:20 72:8 74:15
hardware [lJ 29:8 housing [21 72:3,7 informed [21 44:14 83:23 64:23,25 108:5 74:23 75:14,20,25 77:23
Hawthorne Pl 3:18.21 ingredients r11 36:10 78:3,16 80:1,10 82:10 93:10 Huggins (31 99: 15
initial [11 58:13 introducing (1 J 65: 17 83:4.11,19 84:8,21 86:19
head r21 90:1 109:19 100:14 111:18 Inventory[11 2:21 88:24 89:4,18 90:18,25
headquarters c11 12: 11 Huggins' (11 99:25 initials [41 17:18,21 investigator c11 19:4 91: 12,18,21 92:8,13,19 human cs1 12:21,25 13:6 35:18 63:16
involved [GJ 12: 1 7 19: 13 93:4,6,13,23 94:3 103:19 heal c11 63:13 13:14 21 :24 initiate c11 89:16 20:6 48:5 72:8 102:12
104:22 105:1,18,25 106:5 healingrs1 66:2 68:1 hundred c11 88:3 inject r11 88:25 involvement [Il 45:14
112:2 113:10,12 114:S 90:12 97:1 98:9 injected r21 92:11 102:14 116:2
health (loJ 14:15 21:17 husband's [ll 16:11 involves r11 91:5 Kathy's [19] 20:6,7 25:15 36:2 87:2,13 101:21,23 18:16 injecting c21 92:7 102: 12 IRM [131 35:18,23 36:7 27:19 34:7 44:8 50:14 102:7,9 110:25 hygienist u] 16: 16 injection c21 65:2,6 39:12 40:3 42:14,24 50:19 69: 17 82:3 86:10,13 88:21
healthy c11 l 02: l injections c21 92:5,9 69:20 70:3,6 77 :7, 11 90:15,2192:23107:19
heard [31 103:8 107:6,9 -1- injuries c11 20:21 IRMs [6J 36:12,14,16 109:18,23 110:21
Heights c11 3:18 l-N-T-E-R-O [l] 28:18 inlay [SJ 57:12,13,15 64:2 39:9 50:20 77: 18 keep [ll 73 :25
help t4J 46:5 48:15 63:13 idearSJ 25:22 45:23 53:15 64:5 Irreversible c11 60:17 keeping c11 74:l
66:2 88:5 106:9 inlays £6J 57:11 58:18 irritated c11 39:25 Kelen r11 5:21
HENES C2l 115:19 identification r21 3:10 63:20,23 77:15,18 irritation r11 62:14 kept£4l 31:1,1044:24 116:20 49:16 inserted [31 50:19 58:2 irritatio_ns c11 l 02:4 85:l
hereby c11 115:6 identify c11 49:21 63:23 issue c21 85:5 113:1 kind £61 11 :4 12:6 24:2
hereditary c11 105:13 identities c11 20: 17 Inserting c11 57: 11 issues [5J 14:7,10,11 37:7 55:25 64:12
heredity r11 105: 10 illness c11 98:5 instances c21 78:3 96:24 20:23 106:23 kinds c11 15:8
high c21 7:19,21 impa~tions c11 9:24 instead c11 15:19 itself [7] 14:8 21:24 22:3 knewr21 16:16·-55:24
higherpJ 96:16 imparts c11 96:6 institute c11 79: 12 35:7 65:7 78:22 95:16 knowledge [SJ 13:7,11
hip [l] 107:6 importance [21 84:22 instruct c21 55:23 92:19 16: 14 73:9 99:25 kno·wn c21 25:1 69:13
920-733-1835 HENES, PIDLLIPS & WILLEFORD 1-800-434-3915 · Index Page 5
Richard L. Vanderheyden Condenselt! ™ Kollatb - numbers Kollatb £41 43:25 86:5,6 live [31 3:21,23 16:13 80:25 81:1115:24' mentioning c11 69:11 56:17 98:19 99:24 108:24 86:7 lived r11 3:19 marked [SJ 2:19 3:10 mercury [41 12:24 13:2 111 :7
Kris c101 16:3,7,15.16,23 living c21 19:1,3 49:16.19 114:3 13 :8,13 necessary rs1 15:1 22:13 17:4,11,15,22 20:2 local c11 13:21 marketr11 13:7 Merit £41 1:24 115:4,22 48:7 63:9 99:13
KVI r2J 67:23 68: 1 locally r11 14:15 Marquette c21 8:8.19 116:24 neck [31 40: 12 90~ 1
married [3J 16:9 18: lo met [31 8: 15 11 :22,23 109:20
-L- located cs1 5:14 6:3 metals c21 58:6 102:4 need [4J 8:7 17:8 23:6 12:11 26:12 40:13 18:11
30:12 L[9J 1:5,10,13 2:8 3:1.16 location [41 10:9 24:19 massage [14J 18:19 19:9 meterr11 34:18
neededcs1 42:2 44:13 115:12 116:6,15 30: 19 ·44 :20 19:10 22:l0.i4.16,18,19 method [41 47:20 54:7 84:8 112:13 113:22 LAC Pl 115:2 long-term c11 36:21 22:2123:1.4.7,1090:3 96:7 97:1
lady [lJ 87:8 look £8) 9:21 10:3 30:7 massaged c11 90:4 methods r11 100:2 neither [lJ 31 :7
Lakes fBJ 11 :14.15.18,20 30:12 33:21 37: 15 38: 12 massetc:r [31 40: 1 o 41 :6 Michelle r21 16:1 19:23 nerve [4J 34:11 59:4 65:1 65:4
12:3 13:16 14:4,16 59:25 41:8 microphone [lJ 102:25 lapse r11 10:20 lookedp1 17:19 43:16 material [l6J 28:2 34:17 might c21 17 :6 46: 1
nervous c21 102:4 J 08:4
43:17 86:9,12,15 108:1 35:13,21 36:4,5,6,17 Neural r11 40:22 last [14J 4:16 5:5 12:2,6
looking [81 24 :14 30:15 39:14 54:14115,17,25 55:3 Mik:e[lJ 4:15 Neuralgia [lJ 68: 1 O 14:2 16:16.19 19:4 22:12 79:21 101 :15 Milwaukee r21 2:6 31:1'5 37:17 84:21 86:20 34:15 39:1 57:6 67:11
materials [31 12:10 36:3 116:11 neu.rologic r11 108:24 93:24 76:12 88:13
mind C21 23:19 24:17 neurological £31 108:12 Laura r21 15:24 19:20 looks rs1 57:6 67:19 88:1 56:15 l 08 :23 109:3
Law r21 1:14 115:7 88:2,19 matterr21 9:10 62:22 minute t21 17: 1 o 50: 13 never r21 10:9 44:2
laws r21 94:25 95:2 loop c11 34:5 maxillofacial r11 9:15 minutes [IJ 102:17 new Pl 11:24 47:10 110:5
layman's [21 27:10 looseness r11 40:18 may [31J 18:6 20:9 23:4 missed [JJ 42:22 next r21 26:22 103:22 24:22 30:16 39:2 50:2 missing [21 60:1 64:1 57:17 looser(lJ 40:12 57:2 63:24 64:7 74:24 mixed C11 51:6_ Nickel t21 16:1 19:23
lcadingr11 75:14 lose c11 75:21 75:13 81:6 86:20 87:14 NICO r21 68:3,6 learn r11 95:7 loss r11J 83 :22 84 :4.5,6.9 89:2,9 90: 14 91 :22 92:2 MOD-IRM [l] 38:6 night Pl 37: 18 learned [tJ 95:7 84: 17.23 85:5.12.16.22 92:10 96:23 97:11.18 model Pl 69:1 nine c21 4:21 48:20
low c11 41 :22 98:13 101:10107:5 money c11 72:9 least rs1 19:13 25:3 39:19 109:24 111:6,13.23 Ninety r11 8:10 54:7 72:7 lower r11 40:14 59:21
Mayhew c2J 5:3,8 month [IJ 26:21 nitroglycerin Pl 52:16
leave (2J 16:7 18:8 65:4 68:22,25 69:l 91:8 months [2j 4:21 98:5 lymph [91 89:19.21,22.23 mean f25J 24:10 27:3 nodes Pl 90:5
leaving r21 16:24 19:8 43:15 51:7,22 52:20 55:11 mostrIJ 37:10 non-dental-related £41 89:24 90:5,5.l O 109:6 mostly r11 56:6 lecture [ll 58:13 lymphatic [3J 34:9 56:20 60:18 62:8 63:11.17 67:24 23:7 70:2171:590:19 lectures c11 95:6 89:25 68:9 69:24 70:14,16.23 motherrs1 48:11,23 49:J noncompliant r11 85:18 Lee [41 1 :24 115:4,22 lymphatics [21 90:6.8
70:25 73:4 89:2 97:6 51 :11,12 none [lJ 77:19 98:17 99:19 111 :6,13 mother's r11 105:14 116:23 meaning [tJ 15:19 nonvital r21 79:8 80:25
left[11J 5:4 18:13 37:11 -M- mouth rc1 21:16 2i:19 nor [11 31:8 37:12 67:21 79:22 82:14 means [13J 26:9 27:4 34:7 60:6 66:3 92:9,10 82:23 86:10 87:12,15 M r21 40:21,23 43:16 52:11,11 53:21 109:8 normal [31 49:11 84:16
left-hand [l'J 37:3 M.D Ul 45:10 55:13 62:9 63:12 78:1 movement r11 91 :4 91 :3
legal [11 3:14 M.D.s r11 13:18 100:7,12 105:5 Moving r11 69:7 normally [3J 38:25 39:18
measurements [IJ 34:9 59:9 legs [41 47:1,6,9,13 machine £41 19:2 28:1 measures [lJ 28:11
muscle [61 40: 16 4 i :2,5 nosode c21 105:4,5 lesions [IJ 68:4 54:19 92:14 41:11 90:24 104:10
Madison r11 45:8 measuring c21 29:6,11 muscles (41 41:6,9 67:9 Notary r11 115:5 letters t21 47:12,13
magnesium [1J 85:13 Medicaidt11 7:13 90:6 notation [41 41:21 47:5 licenser51 21:18 22:6,10 medical r101 46:15 47.:I I muscular[1] 100:16 47:9 61:6 46:6 62:17 maiden r11 18:12 70:20 71:5,21,22 86:12 mustc11 68:15 note [31 41:13 47:11 78:18
licensed [31 4:2 22:13 main c11 112:10 86:13,16 97:9 Myofascial u1 35:8 noted c21 39:6 41:14 25:6 maintain £21 15:1 21:16 Medicare r11 7: 12 notes c11 77:8
licenses [11 22:6 maintained [11 109:25 medication [lJ 104:5 -N- nothing c:z.1 3:3 115:13 Licensing c21 7:1,17 majority r11 82:7 medications [121 62:13 NOTICE r21 116:3,14 lifetime [l] 21 :8 makes r11 37:6 62:18,20,24 63:2,7,8 N-C-T-U-R[l] 48:16 noting r11 41:16 likely c11 19:12 makeup r21 97:15,16 99:12 103:20,24 104:4,12 N-I-C-0 r11 68:8 Novemberc11 82:7 limitations c11 21:20 -managerc21 11:13 16:25 Medicine [41 12:7 13:17 N-O-S-O-D-E [I]
DO'W[S] 1:17 7:3 32:11 limits [l] 21 :23 mandible r11 65:5 14:4,17 105:4 57:5 86:25 87:12 107:15 liquid c21 55:5,17 manipulate r11 90:21 meet c21 8:7 11 :24 name [13] 3:14 4:16 11:19 113:8 list [31 104:22,23 105:16 meeting [l] 12:2 16:9,11 18:10,11,12,13 m1.D3berr4oJ 2:19 6:12 manipulations r11 18:16,22 35:15 54:1 listed [31 11: 18 49:23 109:17 meetings r21 13:25 15:3 20:16 24:24 37:21 41:24
105:23 · manufactured c21 33:5 member [21 1 O: 16 38:7 names [41 4:24 20:16 42: 14 43:10,11,13,13
listings [IJ 56:10 33:6 members r21 13:23 32:17 24:21 29:12 49:20 56:10 60:6,8,11,24
Nancyc11 87:6 61 :7,10 62:1,2,5,12 63:20 literally c11 103:24 manu.facturer[2.J 110:8 membership [61 10:19 nationwide r21 13:23 64:10,13,16,18 65:3 66:5 literature c21 85:13 110:11 11 :6,11.12:14 14:3,13 13:24 66:16 68:19 72:12 74:24
110:9 March [141 57:6 61 :25 memory [3J 24:8,12 74:3 nature 121-7:10 83:9 78: 10,12.17 81:4 104:21 litigation c11 21 :4 63: 10 67:12,16 73: 10 . MENS [21 40:10,20 necessarily [61 46:18
114:4 78:13 79:17,19,22 80:8 nu-:mbers r11 57:7
920-733-1835 HENES, PlllLLIPS & WILLEFORD 1-800-434-3915 Index Page 6
Richard L. Vanderheyden Condenselt! ™ numerous - procedure numerous [41 45:22 58:7 65:2 84:9 85:4 107:21 parties c21 1 : 19 115: 11 116:20 88:9 93:3.19 106:17
83:15 112:7 Org c11 67:23 parts f3J 48:21 90:15 97:8 philosophy rs1 62:22 107:11 110:22 nutrition r111 83:22,24 organ c21 102:7,10 passed [lJ 8:21 63:1,4,6 111 :21 practiced [SJ 4:11,22,25 84:1.22 85:3,7,8 87:8 organizations r11 7:13 patient [321 6: Jo 9:7 phosphate r11 66:13 9:2 10:9 100:5,7 112:15 - practicing [21 25:3 30:2
nutritional rs1 84:8,19 organs [41 69:13,17 90:16 19:17 20:21 21:9,17 23:3 phrase r11 69: 14
107:2 23:11,25 24:5 25:18 33:25 pHs c11 88:2 pre-dental r21 8:4,6 85:3 100:2 113:3
origin c21 108: 18 109:4 39:17 40:1 42:8 44:6 physical [BJ 26:8.19 Preble c11 7:22 47:10 49:6 52:8 60:20
-0- original rs1 2:2323.24 70:24 80:18 93:20 96:21 44:17,19 55:5 56:19 96:14 precise c11 33:10 37:15 48:11114:4 116:4 96:23 103:17 105:9 97:16 Predominantly [IJ ·
object[2J 70:22 101:8 116:14 106:10,15,23 110:18 physically f4l 33:21 37:10 obviously r11 20:3 originally r11 58:14 113:9 52:12,25 55: 11 preparation rsJ 50:20 occasion [6J 24 :4 25: 14 orthodontics c11 9:16 patient's r21 44:9 80:19 physician [41 45:8.9,23 50:23 51:2 58:17 59:1 51:21 72:21 104:7.14 osteopaths Pl 13:18 patients [I9J 7:5,8,12 46:23 86:1 96:10 106:19
occasionally r11 12:16 Ostitis r11 68:10 12:10 22:24 23:10.l 1 physicians c11 102:11 prepare[3J 51:2 57:14
occasions [3J 89:l 8 93:8 otherwise r21 1: 16 1 o 1:5 46:17,19 51:19 63:2,7 Pias [31 4:15,19 5:12 58:23
103:23 75:17 93:20 94:20 99:5 pinpoint c1J 109: 1 o prepared r2J 51 :14 63:20
occlusal [31 112:18,19 outlet [tJ 33:1 106:11 110:13,15 place [6J 41 :4 58:24 prepped c11 64:4
113:1 overall r11 J 12:15 Patrick r21 2:7 116:1 I 73:18 75:11 90:15 109:1 prerequisites (IJ 8:13
occur [21 38:21 95:25 own [4] 9:5 55:20 85:7 Patteson £31 1 :15 2:3 placed r111 2:24 34:21 prescribe [7J 47:21
occurred csJ 6:18 38:16 92:14 115:8 41:3 50:21 53:6 58:18 62:17,23 63:8 103:20,23
38:18 40:6 43:3 73:18 oxide [IJ 36:9 Paul c11 5:21 59:5 107:20,24 108:1,8 104:7 93:1 113:19 Pau.ser121 12:22 17:13 plaintiff [3J 1 :3 2:5 prescribed [41 47:20
0ctobeT[3J 69:19 70:2,9 -P- 37:16 40:21 65:20 66:18 116:3 62:13 104:3,15
off [6] 43:22 50:8 102: I 8 P-E-0-T c11 15:22 69:6 70:8 73:l 1 93:7 plan [7] 39:l 1 106:6,7,8,9 prescriber[1J 104:6 102:19 113:25 114:1 P-1-A-S [l} 4:17
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pendingc11 1:18 plans c11 106:11 104:12 16:17,18.19,25 18:1 19:2 page (41 2: I 9 67: 1 69:7
people [1S1 37:13 4 6:2.4 playc21 81:20 84:2 prescription [7] 62: 17 19:18,24 23:15 24:6,9 46:9,11 52:l 58:6 59:12 point [36J 5:24 9:25 12:15 62:24 63:2,7,8 103:20.23 25:18 26:14,16 29:15 88:11 83:23 85:6.11 96:2 102:9
paid r11 6:20 109: 15 111 :3 14:14 15:18 22:8 23:21 prescriptions Pl 63:5 30:14 31:1,3.8,11,12,13 29:20 31:14 34:l O 39:l 31:16,19 32:9,11,13 37:13 pain [30J 24:17,18 35:1.6 Peot £31 15:22 19:16 20:2 44:10 57:18 60:ll 61:18
presenccc11 101:l
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26:14 29:7,21,22 34:3 Paper c11 55:9 27:25 34:19 45:1 65:2 67:7 107:22,23 108:25 presumptuous c11 38:20
48:20 49:6 52:5 54: 12 paperwork[IJ 37:14 72:13,13 75:7 82:6 porcelain [91 39:13 58:3 pretty r11 51 :13 55:11,16 ~6:12,18 66:12 parameters Pl 8:13 performing [.31 J 0:6
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l 04:5 105: 19,23 111 :9 Parsons [37J 1 :2 2:5,20 periodr201 4:18 6:2,5.9 100:7,11 101:5,9 previous c21 76:13 86:4 112:10 2:216:917:5,12,16,25 10:12 19:17 25:17 31:2,7 possibility £31 20:12 previously [31 27:18
ones c21 23:19 51:25 19:14,16.21 21 :3 23:22 31:10 32:12,16 39:19 64:16 72:23 24:5,15,22 25:9 44:2,11 47:25 65:24 77:10 82:13 45:24 58:25
primary [21 21:14 104:6 onset c21 100:18 101 :2 45:12 47:24 50:l 55:19 91:18 103:19 113:12 possible [61 35:5 40:6,7 open [41 56:20 67:21,21 62:23 74:15,23 77:23 periodontal c11 9:15 43:14 89:2,6 private c2J 6:21 19:4 79:23 88:24 93:6 104:22 105:2 possibly cs1 30:17 46:5 privileges (71 14:20,23
opened c21 79:9,11 106;5 113:10,13 114:5 periods c11 93:4 58:10 68:14 77:8 14:25 15:1,5,10 21:20
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920-733-1835 HENES, PfilLLIPS & WILLEFORD 1-800-434-3915 Index Page 7 (I
Richard L. Vanderheyden Condenselt! ™ procedures - science 80:8, pursue c11 14:25 record [141 3:15 37:1 40:9 rely c11 56:4 restorative [41 35:21
procedures [31 15:12 pursued c11 77:4 50:8.10 67:13 68:18 72:2 remaining r11 55:16 36:5,17 60:2 28:l 5 37:12 put [131 27:5 30:5 38:5 87
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proceeding r11 7:16 39:9 42:14 52:13 53:2.4 l lJ: .. ~l l4:l 98:17 102:13 59:25 process [91 21 :25 48:4 54:11 55:3 58:24 70:3 recor ng c11 37:8 remember r221 6:22 14:5 restricted [31 9:8 90:8
48:10,22 49:3 Sl:2.l8 87:6 records [131 18:2 25:11 24:7,17.20 25:l6 32 :24 90:10 54:24 81:15 ________ 25:19 30:7,12,16,23 39:7 33:2 40:S 50:2 56:3 60:2 restricts r11 22:2
product c11 36:7 -Q- 86:?·12•16•16 87:17 72:l 85:24 89:3,6 90:17 result (3J 12:13 14:12
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Pf~~~cts r21 23:20 questionable r11 43:17 15:19 25:9 80:7,14,15 100:15,17.24 101:22,25 results [31 42:l l
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programs [IJ 11:25 quote c11 38:22 referral [31 10:4 46:1 render r11 106:10 ret~ding [ll 85=12
progressively r11 98:6 ________ 61 :9 rendered [ll 39:5 66:5 retrieved r11 81 :22 proper[3J 84:2 100:7 -R- referrals [IJ 35:8 82:8 reveal c11 107:1
113:3 R-A-T-N-E-RriJ 68:2 referred £6J 7:5 9:23 24:1 renew [31 10:21.22 11 :11 revealed r11 43:20 properly [3J 49:7 82:19 24:22 46:23 79:15 renewing [ll 11 :6 review f4J 17:8 73:3.4,17
113·4 radiation r11 44:9 i · 37 14 41 6 · · reviewed [31 85:25 86:7 .h 7 17 raised c11 21:3 re e!D-ng (41 : : repetitive c11 111 :14 prop yc11 1: 84:,91:15 rephrasec21 71:7113:17 87:17 proposed (JJ 74:15 range r21 14:9,11 reflect [31 42:11 74:6 replace [
31 29:23 35:23 rib r11 92:3
-proprietary r21 52:24 rarely [ll 85:10 87:21 102:24 Richard [91 1:5,10.13 2:8 53:11 rash[3146:2547:5,9 refle~tedr11 104:15 replaced[7J 27:19 29:24 3:1.16 115:12 116:6,15
prospectr11 38:17 ratherc31 8:24 74:12 refram r11 99:12 31:4 39:8,ll 77:14,18 right [7] 13:16 37:11.13 protocolcl] 74:25 96:25 refreshc 11 17:8 replacementpJ 39:16 50:4 86:3 113:1,8 provenr11 71:19 Ratner[3l 67:21 68:2,3 refusep 1 44:1580:10,18 replacingriJ 39:20 right-handrSJ 37:4 43:9 providep4J 9:1023:7 react.r31 36:1158:659:16 refusedc 41 44:11,14 ReportriJ 23:20
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providedc1s16:1217:4 readc1JJ 40:9 43:11 59:18 86:13 ~0:23 92:19 96:4 reprimand[3J 6:13.20 80:8.16111:19.22 l7:l l,l5 20:l8 50:1,16 67:1.12,12,15 69:20 70:10 regardmg £41 7:10 50:14 6:21 rough [IJ 25:22
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providerr 21 67:~ 86:12 107:4108:16,18109:5,7 Registered[4l 1:24 requirement[ll 8:ll rule [2161:23111:23 providers r21 87:3,14 109·~ l lS:4,22 l l6: 24 • runs c11 40:14 provides [2J 34:5 94:20 readings r21 88:19,21 regular[GJ 10:6 15:3 requirements r11 15:4 Ruta c11 67:25
Providing poJ 26:lS real c21 7:14 57:18 23:17 56:4 67:4 110:9 research [11 12:17
45:12,l3 46:16,19 63:4 really r11 46:13 regularly r11 70:20 residence c11 3:17 71:23 94:15 95:21 99:11 Realtime r11 1:25 Regulation r21 7:1,17 resin [16J 27:1,6,7.12,16
psychological r11 97:15 reason r10J 41:14,17 47:5 reinitiate [11 62:10 27:20 29:17 33:17 35:13
4,., g 56 21 57 23 59 23 l 35:23 36:1,15 39:8,12,16 pterygoid (31 40:12,13 1 : : : : re ate [31 30:23 38:2 57:3
41:8 69=5 92
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pterygoids r11 23:6 reasoning r11 s9:l 4 related r21 23:15 71:19 34:20,25 35:10,16 50:22 public [31 6:21 101 :21 reasons r21 10:22 83:1 relates rs1 70:12,17 94:25 50:24
115:5 reassure r11 113:21 97:3 114:4 resistance r2J 28:12 publication c21 12:13 recalling r11 16:20 relating [41 34:10,11 45:23
14:12 receive cs1 8:1 12:13 71:22 86:9 respectc11 94:12 publications r21 6:24 14:12 22:11 23:14 relationship r21 53:6 respond [4l 36:1 49:4,7 23:14 received £31 6:13 43:23 107:6 49:13
published r21 6:23,25 87:15 relative £21 3:3 115:13 responding r11 110:19 pulp f7l 42:8,11 60:19 receiving r11 64:2 relaxant 111 104:10 responds [ll 39:17 73:1 79:3,7 81 :2 recent [l] 13:9 relaxation r11 41:l response [17] 6:12 20:16
pulpitis [31 60:17,18,21 recently c11 31:17 released r11 23:6 24:23. 28:2 33:24 34:14 purchase(JJ 30:17 32:19 recognizers] 17:15 18:7 reliedc 11 56:6 34:15 40:1 62:11 65:18
33:3 . 49:22,24,25 relief [2l 42:2 ?0:l l 66:11 108:4,11,15,21 purchasmg [11 32:25 recognized c21 97:23,23 reline c21 83:16 84:17 109:3,4 --pure [11 39:13 recollection (91 17:9 relines c11 83:8 r~~f:i~ses c21 73:6
purpose (41 27:8 36:l 8 19=15 24:l 5 43
=22 74:l 4 reluctant c11 46:22 rest [31 36:10 77:13,13
68:25 101:6 84:15 89:4 104:2,11
920-733-1835 HENES, PIDLLIPS & WILLEFORD 1-800-434-3915
-s-S-T-1-M lll 67:5 s.c [3) 1:15 2:3 115:8 sacral c11 91 :5 sacrum r21 91:7,8 safe r11 101:14 salivary r21 88:2,3 salt [21 105:23 l 06:2 satisfactory c11 83:2
save r11 76:1 saw [71 24:5 25:10,10,12 27: 13 113:9,10
says cs1 26:8 27:2 38:13 41:13 63:10
scalpel r11 89:7 scar r21 92:7, 11 school [9J 7:19,21 8:9,17 8:19 22:16J7,18 103:5
Schumacher r11 16:20 science r11 8:14
Index Page 8 0
Richard L. Vanderheyden Condenselt! ™ scope - terms SCOP,e [l] 88:9 single r11 98: 1 74:25 75:3 76:5,6,21 80:5 straightened [lJ 59:1 symptom [SJ 73:3,4,17 scrape r21 62:10 89:16 sinus [41 71 :22 91:21 ,24 84:19,25 85:20,24 86:5 streett3J 3:21 16:19 97: 10.11
Sectiono1 116:17 91:25 88:23 91:20 93:17 95:19 93:11 symptoms r111 34:22,24
sedative-based r21 59:3 sit [3J 52:14 74:16 76:21 100:25 107:21 strep f3l 51:15,16,16 42:8 43:6,7 47:15 57:l
77:20 site r11 62:7 specifics c21 6:6 24:20 strike [l9J 6:7 22:20 73:22 96:23 98: 12,21
see c111 17:10 24:16 28:1 situation cs1 47:3 50:14 Specimen c11 87:20 24:14 28:10 32:3 36:4 syndrome c11 69:3
37:18.21 45:22 63:16 64:1 89:15 91 :6 107:20 spell [3J 4:16 48:13 68:5 57:14 61 :1 63:6 71:2.8 syringes c11 88:24 64:3 72:14 80:4,5.10 Six [l] 16:8 speller c11 48:14 72:16 75:25 84:7,20 95:11 systemc121 28:2,19 29:4 105.:21 106:7 110:8 skin l4J 28:11 33:24 34:l 4 spends r11 72:9 98:23 100:16 111 :17 33:22 34:11,12 52:23 113: 17 34:15 spleen [11 69:11 structural r11 102: 1 102:5 108:4.12.23.24
seeing [21 108:3,16 slight r21 40: 10 58:25 splint [lJ 69:1 structure £4J 35:7 107:12 systemic r11 101 :7 seem r11 76: 15 small r21 48:23 89: 11 splitting r11 6:15
108:6 109:2 systems c11 56:20 sensitive r11 112:12 Society r21 11 :14.l 9 spoke r11 86::!2
structures [3J 21 : l 6.2 5
sensitivity [51 40: 1 95:22 -T-59:13111:1.4112:8 socket r21 62:7 65:6 spoken c21 86:19 87:13 study rsJ 7:23 11: 1 s.20
separate r21 22:23 54 :5 sockets c21 88:25 89:5 sponsored [IJ 30:21 12:1,3 13:20,21 69:1 T-I-N r11 48:14
separated c21 10:25 11 :3 software c21 29:9 110:5 spoon r21 62:9 89:12 studying r21 12:9 19:10 T-I-N-C-T-U-R-Ec11 sole c11 101 :6 spot [IJ 50:6 Sturgis rSJ 24:1,2,4 86:23 48: 17
serial c21 48:3,10 solution [BJ 36:21 48:12 ss [l l 115: 1 87:11 tabbed fll 88:12
series [51 3 s: 1 7 4 7: 12 48:20,23 49:1 51:11.12 St £41 14:20 15:2,6,9 subconscious c11 103:7 table c11 105:19 49:14 52:5 82:6 52:22 subject [31 7:15 101:9 tailbone r11 91:9
servedr11 116:16 staff r6J 14:20,23 15:1,5
Service [3J 101:21 solutions [21 51:14 15:9 38:7 112:23 takes r11 98:4
55:10 stance r11 100:13 Sublingu.al [11 52:9 taking cs1 44:5 58:5 60:3 115:19 116:21 Soma[3J 104:6,9,11 serviceable [11 101 :6 stand r11 28:3 submitting r21 7: 12 72:2 98:8 104:6
serviced [lJ 109:25 someone [IJ 98:5 standard cs1 44:4 74:25 subsiding [ll 79:6 tape c11 68: 19
services [31 15:8 22:3 sometime [11 31:5 75:16 88:14 94:12,16 substance r21 47:19 48:3 taps c11 103:9
26:15 sometimes [61 37: 11,11 96:10,14 successful r11 82: 18 technique 121 67:21 91:3 107:22 108:20 110:7 standard-of-care r11 successive [IJ 95:25 techniques c11 90:3 set [41 1:19 43:23 52:3 112:19 20:23 successive-dilutions teeth [6JJ 15:11 21 :8,24 72:12 somewhere r21 6:4 30:8
setting r11 20:1 standpoint r21 19:22 [l] 95:23 27:9.12,15 35:1,3.6.6 36:l sore r11 78:19 97:10 such[3J 46:7 55:19 61:23 36: 17 37:18 39:18 40:14
scverC[3J 9:14 10:25 sorry rs1 4 :9 40:11 42:22 stands r21 40:21 68: 1 43: 17 47:15 50:20,20 57:7 11 :3 59:7 67:14,19 86:14 103:1 start [61 25:25 49:12 51:9
suffer Pl 111 :3 57: 10 58:17 60:1 66:12 shaking [3J 95:25 96:5 sort (16J 12:13 13:25 14:3 51:11.1779:13 sufficient c11 78:22 70:2,6.18 71:17 72:18.18 96:14 28:9 38:19 41:10 45:11 started [31 5:4 30:2 37:23 suggest [31 71 :14 85:10 73: 12,14,20.21.25 74:2.7
shall[l] 101:5 53:12,12 54:15 55:17 85:15 74: 10 75:4.21 76:2,18.22
shift [ll 87:12 79:21 83:14 95:24 106:21 startingr21 43:1098:11 suggested [41 6:13 45:22 76:24 77:6,13,17,19,23
shipped [tl 32:23 108:5 state r121 1:1 3:14 4:3 45:24 113:5 82:10 91:23.24 101:25 7:16 21:1.18 22:14 94:13 suggestion c21 85:18
102:1,4 106:25 107:24 shoots r11 I 09:8 sorts [lJ 58:6 104:25 115:1,5 116:l 112: 13.17,23.24 Short r11 68:17 sounds c11 91 :20 statement rs1 21 :6 72:4
98:14 telling c11 38:3 shortcut r11 74:12 sourcec9J 35:354:14,15 82:5 101:9,11 Sullivan c111 2:6,7 48:17 temp c21 35:18 38:6 shoulderc3J 10:25 11 :3
54:17,21,25 55:3,11 56:15 states c21 33:l 103:6 48:19 50:5 67:18 70:22
temporalis [31 40:10 sources c11 35:S 101:8 102:15,17 116:11
11 :3 status r11 60:15 supervision c11 10:13 41 :7,8 shoulders [11 109:20 South cs1 4:6 5:15 6:3,8 Statutes c11 116:18 supplements 121 85:1 o temporaries r21 39:18 showr3l 49:19 87:19
10:10 69:25 space c11 5:25 stay c11 99:6 85:12
88:11 steps c21 58:22 83:11 supply r11 88:24 tem.porary c101 36:19 showed r11 28:2 spasm [lJ 23:6
stem um c11 90 :21 supplying r11 89:4 39:12 40:3 42:14,19,24
showing c11 79:7 spasms c11 92:3 50:23 57:16 58:21 66:13
shows [21 66:6 85:13 speak [31 24:4 25:14 still c15J 15:22.24 16:1 support c21 1 o l :22 temps c21 50:19 69:20 30:23 31:13 32:10 36:2 112:25
sick c11 83:17 50:13 40:12 53:23 55:16 70:2,6 supposed r11 l 08: 11
ten c11 86:20
side ca1 37:3,4 40:14 speakers c11 11 :25 73:21 77:6,11 suppressed c2.1 96:25 tenant [11 6:8
43:9 54:12 55:16 67:11 speaking c21 37:4 111:1 Stun [l) 67:5 97:11 tenants c11 5:22 67:16 70:9 105:14,14 special c21 59:10 107:5 stimulate c21 109:6,7 surgeons c11 15:20 TENS c21 40:25 41:l
SIESENNOP [l] 2:6 specialist c21 8:23 9:8 stimulated c11 67:7 surgeries c11 9: l 5 tension c11 40:11 significance c11 69:22 specialists c11 24:21 stimulater [ll 40:25 surgery c11 9:15 Terence [31 2:4 116:16 signify [l] 40:20 specific [241 14:6,7 24:8 stimulating 111 108:3 Surgical r11 64:22
116:25
silver [91 12: 18,20,24 24:12 28:22 29:2 30:7,11 term.cs1 27:10 28:14 13:2,5,12 27:18 100:15 35:15 39:5 46:12 56:23 stimulation [41 40:23 Suring c11 25:3 46: 11,14 47:21 97:3
74:3,14,18,19 78:8 82:1 41:11 53:13 67:6 surrounding £31 16:23 102:23 103:3 100:17 stop c11 61:20 similar c21 40:25 75:9 83:10,14,15 108:22,25 19:7 65:7 terminate r11 14:23
simple c21 39:3 93: 16 ·· -109:3 . stopped c11 61 :18 sustained c11 20:21 terminated [Il 17:2
specifically c211 17: 14 store [21 52:21,23 swallow r11 52:14 simply [31 38:12 73:7 24:18 26:4 34:6 49:l 60:2 stored c11 29:5 terminology c11 46:9
80:22 61:3 66:22 71:23 72:11 storehouse [I J 103 :9 sworn c21 3:2 115:12 term.sr3J 57:17 81:18
920-733-1835 BENES, PillLLIPS & WILLEFORD 1-800-434-3915 Index Page 9 .
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Richard L. Vanderheyden Condenselt! ™ test - wires 83:1) TMJ-related [31 67:4 106:11,14,19,22 113:14 underlying r11 98:21 2:20
test [BJ 27:1,22 28:l 33:17 69:2 82:8 113:18 114:5 understand c121 15:I 7 variedc21 11:23 37:9 33:23 79:3,7 87:25 today [6J 11 :9 70:11 treatments [BJ 44:20 33:15 36:25 37:8 45:11 various [41 41 :4 45:2
tested [ll 35:11 74:16 76:21 83:17 86:1 83:5,6 90:25 91:2,3,14 52:10,10 95:14 96:3,11 65:25 102:3 testified r11 43:21 together c21 37:7 95:8 98:4 109: 12 111 : 14 verify[3J 18:1 30:12,15
testify r21 3:2 75:7 Tom r11 5:2 treats r11 9:7 understood c21 72:7 versus [3J 79:8 105:14 testifying [41 20:20,23 tongue r11 52:14 trialr11 1:17 l 07:15
105:19
75:8.15 too [31 29:7 83:17 89:9 tried c21 35:12 90:24 undo r11 98:5 vertebral [11 35:8 testimony [61 20: 18 took rs1 41 :21 43:24 44:2 trigger r21 67:6.7 unit r21 40:25 41: 1 vial £9J 48:24 52:4.8,13· 33:15 76:18 77:14 80:1 59:1873:18 trouble r21 71:12 113:16 United c1J 33:1 55:6.7,12!16 56:13 109:12 tool [lJ 110:23 tru.e[l9J 6:16 7:3 8:25 9:2 University f4l 7:.23 8:1 vials [2J 51 :25 52:3
testing p11 28:16.20.25 tools c1J 95:8 10:10 12:6 13:14.!S 14:21 8:8,16 videographer [91 3 :2 29:17 32:4,7,13 33:25 tooth f6BJ 9:24 23:5 35:7
23:23 27:15 44:2 61 :17 unless [21 49:1 99:12 50:8,10 68:15.18 102:19 34:13,14 42:8,l 1,12 72:17 39:21,24.25 41:24 42:3,7 65:24 75:1 77:18 80:17 unquote Pl 38:23 102:21,24 113:25 72:21.23 73:1,1.2,8,17 42:14,17.19.24.25 57:14
96:2 111 :22 unusual r11 93:25 videotape [ll 68:16 75:4,10 79:4 81 :2 95: 12 58:17.23 60:6.13.15,21 tru1yc11 57:18 unusually [IJ 41:20 videotaped [31 1:10,13 102:7 106:25 107:12,16 60:24 61:7.10 62:1,2,3.5 truth 161 3:2.3.3 115:12 107:21 up r1s1 13:18 40:14 47:19 116:15
62:12 63:20 64:10.12,16 115:13.13 tests r7J 27:25 34: 19 42:6 64:18 65:3,7 66:5.16 try [3] 47:l l 58:8 63:8
50:4 56:20 69:7 71: 12 Vincent [41 14:20 15:2.6
44:13 75:7 81:23 88:6 68:13 73:7,8 74:19.24 75:14,22 79:9 81:12 62:14 15:9
Thank [31 48:18 50:11 76:17 78:5,12,17,20 79:4 trying rs1 35:2 38:16 83:24 90:24 91:6 105:5 virus r11 105:6 48:15 58:9 73:25 81:12 109:8 113:8
114:10 79:10,11,22 80:21.24 81:4 81:16 83:13 updates c21 110:5,5
visibler21 53:16 54:24
themselves f3l 35:7 97:1 81:8,9.16 89:14 107:5,12 visit £131 20:10 24:9 104:23 108:2.3.6,7.9 109:2,14 tum [41 53:10 57:5 103:17 upper [31 59:21 73:23.24 26: 10 38:13.16,18,21.22
theoretically [11 51:15 top [l] 67:1 107: 1 urine (31 87:25 88:2.3 38:24 39:4,6 41 :20 70:11
theory[4J 28:1554:7,8 touched ll 1 4 I :9 tu.med Pl 54:19 used f23] 28: 1,16 31 :25 visits [3J 92:23 93: 1,17
100:15 toward r21 52:24 83:12 twelve r11 98:2 33:17 42:8,8.8 51:14 vital poJ 42:3,7,17 72:18
therapiesp1 46:13 towards r21 83:20 113:19 twice r11 93:9 56:23 57:23 59:15 66:2 74: lO 76:22,24 77:2 79:4
therapist [31 18:19 19:9 toxic LSJ 12:10.20,25 13:6 two [JO) 4 :22 26:21 38:l 67:3 68:5 69:15 77:19 80:24
41 :4.13.21 51 :25 54:4,11 79:21 81:7 95:8 102:9 vitality [3J 73 :8.17 19:10 13:14 95:8 104:13 107:23 111 :8
therapy [23J 9: J 4 ::!2: lo toxicity [IJ 100:12 109: 13
two-to-three-month uses [3 J 54 :22 92: 19 Voll £61 28:4 30:16,19 22:14,16.19.21 23:1,4,7 Toxicology Pl 12:8 [1) 39: 19 110:6 58: 12,13 95:6 23:10 26:8,19 44:18.19 TPT rlJ 67:5 type (19J 5:8 27:25 28:19 using [7J 14:24 32:2,4,6
60:22.23 61 :10.15.20 109:18 110:20 111 :19.22 traditional r21 46:23 28:23 34:15 36:4,4 45:9 95:1699:12111:11 -w-
there'll [1] 108:3 97:9 46:5 53:25 56:25 64:15 usually [3J 39:3 48:25
transcript [JJ 2:24 116:4 64:20 68:4 72:21 85:3 53:2 W [2] 2:7 116:11 thereafter [ll 94:5 116: 14 89:7 93:13 110:20 Utah r21 33:4,6 · wanting c11 46:3 thereto r11 1 :19 transfer c11 54:20 types rs1 9:9,13 13:5 15:8 utilize [71 40:2 42:6 59:3 warrant c11 78:22 they've c11 101 :11 transferred £11 55: 10 15:19 57:1 90:3 92:19 81:3,19 92:16 104:18 warranted r11 42:19 thinlcing[lJ 110:3 translate c11 103:16
typical [3] 65:1,4 107:22 utilized f4l 36:18 81:14 waterr131 48:21 52:22 third [lJ 107:5 traumatizes r11 112:16
typically ri1 75:9 96:21 105:17 53 :2.4,9,16 54: 12.16.25 Thompson c11 58:12 traumatizing r1J 112:24
utilizing [31 63:2,17 55: 12,15 105;23 106:2
thought [21 69: 11 103:5 -u- 107:12 ways r11 87:1 tray (l] 53:8 UW-Oshkosh r11 8:5 three [41 18:9 44:7 67:9 treat [lOJ 22:24 44:11 U .s [1] 101 :21 weakerc11 97:12 102:17 71:17 90:18 91:21 92:3 ultimately c21 8:17 wear [31 83:8 112:21
throat [ll 40:15 93:6 94:6,6 97:7 112:23 -v- 113:4
throughc201 11:2217:19 treated r111 23:22 44:1 o umm [4SJ 6:25 9:14,24 V [2} 1:4 116:5 wearing £41 69:25 73:23 32:25 33:4 37:9,20 38:11 47:25 65:25 77:10 86:20 25:3 27:1,21 28:1 29:7 V-0-L-L (l] 28:4
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Websterrs1 4:6 5:15 6:3 65:22 74:13.22 76:16 77:8 113:12 40:2141:1645:19 48:25 6:8 10:10 77:9 103:24 105:10 treating c121 20:20 23:2 49:11 51:13 54:1 56:17 vaccines c11 51 :18 weeks r11 98:2 113: 13 25:15 26:2 40:10,20 41:18 56:23 64:16 67:3 68:14 vaguely r21 95:1 103:4 wells r21 54:5,11 throughout [91 17:7 44:1 56:23 60:7 91:18 93:4 73:5 76:15 78:16 83:8 Valley r11 22: 18 whereas r11 29:5 62:22 65:24 72:2 81:23 110:23 85:10 86:4 87:4 88:1,19 valuable r11 110:23 82:13 113:12,18 88:23 89:22 91:20 95:1 wherein c11 1: 18
ties [ll 78:14 treatment [69J 7:6 9:9 96:5 102:14 103:8 104:5 value [IJ 95: l S whitec11 27:7 17:5,11,15 21:24 25:23 105:6107:22110:7 112:7 Van c121 5:25 6:2,7 ,8,16 Tiger c11 99:8 33:12 35:9 39:5,11 40:24
unable r11 83:2 7:3,5 26:10,11,12 44:20 wholecs1 3:3 28:14 97:7
times [41 45:22 83:16 44:1,15 45:1,11.13 46:16 87:11
108:24 115:13
92:25 112:7 46:20 49:11 59:25 60:20 uncooperative r21 83:4 Vanden r11 87:6
wholesale c11 33:1
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920-733-1835 BENES, PIDLLIPS & WILLEFORD 1-800-434-3915 Index Page 10
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920-733-1835 HENES, PffiLLIPS & WILLEFORD 1-800-434-3915 Index Page 11
DEPosmoN ~ EXHIBIT
KATHLEEN A. PARSONS R-V4rr)erf4e,vfr?l4 379705.005
. /-~8-00 ~ .
Drug Inventory
HOMEOPATIDC (AMPOULE} NUMBER QUANTITY Acute Pulpitis Z15 10 - 1 ml Aerobacter Cum. Coli. B30 10 - 1 ml Aerobacter Aerogenes SDF103 10 - 1 ml Allergy Malus S19 10 -1 ml Angina F ollicularis H8 10 - 1 ml Angina Plaut Vincent H7 10 - l ml Appendicitis Necrotans Nosode B32 10 - 1 ml Appendicitis N osode B24 10 - 1 ml Argentum Met. HlvI48 5 -1 ml
Argentum Nitric ffiv.[16 5 -1 ml Amica Montana FIM36 10 - 1 ml Arthritis Urica G2 10 -1 ml Asbestos Q47 5 -1 ml
Ascites Nosode F45 10 - 1 ml '/
Asiengrippe A C23 10-lml Aspartame SDF197 5 -1 ml
Asthma Bronchiale C25 5 -1 ml Avrum.Met. HMSO 5 -1 ml
Bacteroides Nosode A34 10 - 1 ml Bilirubinum ST015 5 -1 ml
BladderTBC M8 10 -1 ml
Bolulinum B8 5 -1 ml I Cadmium Sulfuricum FIM361 10 - 1 ml
CadxniumMet SDF196 10-1 ml
Campylobacter . SDF121 10- 1 ml
Campylobacter SDF153 10- 1 ml
Chalzion 04 10 - 1 ml
Cholera Nosode B29 10-lml
Cholesteatminum Nosode Al3 10-lml
Cholesterinum ST0l 5 -1 ml
Cnron. -Bact. Ostitis of Jaw 238 10 _, 1 ml
au-onic Hyperplastic Tonsillitis Hl2 10- l ml
Chronic Tonsillitis Nosode H6 10- 1 ml
Citroen Allergy S20 5-1 ml
Clostridium Para putrificium SDF 161 10 - 1 ml Colon Ascend.ans Nosode DEGDB 10- 1 ml
Colon Descendans Nosode DEGDC 10 - l ml Colon Ascendans Nosode DEGDB 10- 1 ml Conjunctivitis Nosode 05 10- 1 ml Conjunctivitis Follicularis D6 10- 1 ml
Coxsackie DA30 10- 1 ml
Cresolum P29 10- 1 ml
.: Page -1-. C, n
-KATHLEEN A. PARSONS
379705.005 Drug Inventory
HOMEOPATHIC (AMPOULE) NUMBER . QUANTITY CuprumMet. 'HJvf79 5-1 ml Cuprum Aceticum HN.1217 5-1 ml Cuprum Formicicum HM132 5-1 ml Cuprum Sulfuricum HM368 5-1 ml Cuprum .Arsenicosum HN.1298 5-1 ml Diazepam P30 5-1 ml Diphterinum Nosode Fl 10 - 1 ml Dysentery Nosode B9 10 - 1 ml Ear Polyp N os<?de H4 10-1 ml Eichoccinum Nosode F38 10-1 ml Elephantiasis Nosode A22 10-1 ml Enteroccinum N osode B19 10 -1 ml
. Epidermolysis Bullosa Nosode N22 5 -1 ml
Eschericia Nosode · Bl 10 - 1 ml Exudative Ostitis Nosode 230 10 - 1 ml Faekalinis Alkaligenes Nosode Bll 10 -1 ml Fishpyrogenium (Saltwater) A18 10 -1 ml Fishpyrogenium (Freshwater) A19 10 -1 ml
Flower Pollen S14 10 -1 ml Flue 79 SDF 120 ·10-1m1
Flue 80 SDF121 20 -1 ml
F onnaldehyde P21 10 -1 ml
Fungs Flora Nosode 18 S -1 ml
Gaertner Nosode BS 10 -1 ml Gallbladder Nosode DEGGA 5-1 ml
Gasoedem Nosode Fll5 10 -1 ml
Gonococcinum Nosode E2 10-1 ml
Grass Pollen S16 10 -1 ml Hepatitis B & EB Virus SDF173 10 -1 ml
Hepatitus Nosode F7 10 -1 ml
Herpes Progenitalig DA31 10 -1 ml
Histidinum ST09 5 -1 ml Indol STO20 5-1 ml
Infected Lymph . A23 10 -1 ml Influencinum Toxicum C14 10 - 1 ml Influencinum (Berlin 5 5) C17 10-1 ml
KI 14 (2, 3, 5 -T - Ester) R24 10 -1 ml
KI 15 (Parquat) R25 10 -1 ml
Klebsiella Pneumoniae Nosode SDF125 10 -1 ml
Kobalt - Chrom - Alloy SDF126 10 -1 in.I
Kreosotium HM:14 10 -1 ml
Page -2-
KATHLEEN A. PARSONS 379705".005
HOMEOPATHIC (AMPOULE) Lamblia Intestinalis .Nosode Leptosperosirium Nosode Leptospirosis Canicola Nosode Leptospirosis ICT.-HA.E. Nosode Listerosis Nosode Luesinum Lupus Erythematosis Nosode Lupus Nosode Lymphadentits Nosode Lymphnode Abscess Nosode Lymphorrhoe Nosode Lymphorrhoe.Nosode Lymphplaques Nosode Malathion Mastoiditis Nosode Maxillary Polyp Nosode Medorrhinum Meniingitis Nosode Meningoccinum Nosode Mercaptin Mercuric Sulfate Mercuris Bijodatus Mercurius Solubilis Mercurius Bijodatus Monilia Albican.s Morgan Nosode Mykosis Fungoides Nosode Nickel-Chr.-Gall. Molybdaen-Leq. Nickel-Chrom-Beryllium.-Le. Nocardia Asteroides NOS. Varizellen Ornithose Nosode Osteo-Sinusitis Max. Osteomyelitis ,No·sode Palladium Parathyroidinum Nosode Pasturellose Nosode PCB-Polycarbonated Biphenyls Pemphigus Nosode Pertussin Nosode Petroleum Pneumoccin Nosode
Drug Inventory
NUMBER BlS F28 F35 FlO F19 El NS Nl5 B34 A12 A21 A21 Hl3 R20 H3 Hl AJ DA27 DA2 ST052 HMlll HMll0 HM31 HMllO N20 B4 N8 SDF 136 SDF137 SDF252 F48 F4. Hl0 A8 HlvfllS P32 A31 Q38 Nll C4 H:M:68 C3
~age-3-; Cl
· QUANTITY 10 -1 ml 10-lml 10 -1 ml 10-lml 10 -1 ml 10 -1 ml ·5-lml 5-1 ml
10 -1 ml 10 -1 ml 5 -1 ml
10 -1 ml 5 -1 ml
10 - 1 ml 10 -1 ml 10 - 1 ml
5 -1 ml 10 - 1 ml 10 -1 ml 5 -1 ml
10 -1 ml 10 -1 ml
5 -1 ml 10 - 1 ml 10-1 ml 10 -1 ml
5-1 ml 5-1 ml 5-1 ml
10-1 ml 10 -1 ml
5 -1 ml 10 - 1 ml 10-1 ml 10 - 1 ml 10 - 1 ml 10 -1 ml 5-1 ml 5-1 ml
10-1 ml 10-1 ml 10-1 ml
KATHLEEN A. PARSONS 379705.005
Drug Inventory
HOMEOPATHIC (AMPOULE) NUMBER QUANTITY Pneumococcinum Mixed Flor Nosode Cl6 5 -1 ml Polyarthritis DA29 10-lml Polypeptide A.KA P43 5 -1 ml Polypeptide AGR P24 5 - 1 ml Progressive Muscular Dystrophie NOS DA25 10 - 1 ml Proteus Nosode B2 10 -1 ml Pyrogenium Al 10 - 1 ml Pyrogenium Ex Ovo Al6 10 - 1 ml Pyrogenium Su.is Al5 10 - 1 ml Q-F ever Nosode FSl 10-lml Rheum.a Nosode G8 10-lml Salmonella TP Nosode B31 10 -1 ml Scarlatinum Nosode F2 10 - 1 ml SDF Bleomycin SDF173 10 - 1 ml SDF. NOS. Cytomegalie SDF 250 10-lrnl SDF. Nos. Epstein-Barr SDF249 10 - 1 ml Seine Influencinum F39 10 - 1 ml Selenium Hlv173 10 - 1 ml Serotonin S13 10 - 1 ml Sigmoid Nosode DEGDF 20 -1 ml Silberamalgam ? 10 - 1 ml Sinusitis Frontalis Nosode H2 10 - 1 ml
Skatol STO32 5 - 1 ml Sreotonin S13 5 .. 1 ml
Staphloccin Nosode A4 5 -1 ml Staphylo-Streptococcinum Nosode A28 10-lm1 Staphyloccus Aureus Nosode A26 10 -1 ml
S taphylococcin Nosode A4 10 -1 ml Staphylococcinum (Insecticide) A4 10 - 1 ml Staphylococcus Aureus Nosode A26 10-lml
S treptococcin Nosode A5 10-1 ml Streptococcus Viridans Nosode A29 10 - 1 ml
Streptococcus Haemolyticu~ Nosode A30 10-lml S ubtilis Nosode B21 10 -1 ml S ulfanilamide P4 10-lml Sulpher · FIM1 10-lml Tabacum HM 5-1 ml Testreihe SDF. Palad (D6-D400) ? 10-lml
Thioether ST054 5 -1 ml Tonsilla Palatina Nosode Al0 10-lml
Tonsilla Pharyngea Nosode All 10-lml
Page-4-
,.
KATHLEEN~- PARSONS 379705.005
Drug Inventory
HOMEOPATHIC (AMPOULE) ·NUMBER Tonsilla Pharyngea N osode All Tonsillarabscess A9 Tooth Treated at the Root Z24 Toxoplasmosis Nosode DA9 Trichinosis Nosode B26 Tuberculinum Nosode E3 Tuberculinum A vaire Nosode E7 Tuberculinum Klebs E5 Tularemie Nosode DAl0
· Typhoidinum Nosode B3 UVAURSI 1™35 V-Gripe Nosode cs V2 - Grippe Nosode C7 V75 - Grippe Nosode C29 V76 - Grippe Nosode C30 Vaccininum Nosode DAS V aricellinu.m Nosode F48 V ariolinum N osode F36 Wilson Nosode F22 Zincum Cyantum HM207 Zincum Picratum HM208 Zincum Metallicum Hlvf35
BOTTLES Dental Cond. Meningpor Metal. Radiation Rubella Sulfasalazine SulsaPt. Super Phos.
DROPS Staph Lysol
INJECTIONS Octocaine Polocaine
Page-5-
QUANTITY 10 - 1 ml 10 - 1 ml 10 - 1 ml 10 - 1 ml 5 - 1 ml
10 - 1 ml 5 -1 ml 5-1 ml
10- 1 ml 10 - 1 ml 5 -1 ml
10 - 1 ml 10-1 ml 10-lml 10-1 ml 10 - 1 ml 10 -1 ml 5 -1 ml
10-lml 5-1 ml 5-1 ml
10 -1 ml
QUANTITY 1 bottle 1 bottle 1 bottle 1 bottle 1 bottie 1 bottle 1 bottle 1 bottle
QUANTITY 1 bottle 1 bottle
QUANTITY
. Cl