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|21:10-22:22||Corporate acronyms||Witness DNK if there is a list or index of acronyms common to company employees to facilitate document requests but there may be someone in witness’ group who knows.
|22:20-24:4||Research and Development Department hierarchy||
Angel Perez is witness’ boss; he is the head of R&D.
Ann Smith is the senior director above Perez.
There is a corporate organizational chart of R&D that witness could obtain, but she is not aware of a list of acronyms.
|40:8-41:13||Page 3 of Exhibit 1; how to request standard or derived databases||
Page 3 shows examples of data sets for one particular study. This study may have more datasets, but the screenshot just shows one study.
A request for a derived database would be a clear enough description; there are only standard and derived databases.
There are lists of clinical studies. There is not a single glossary that captures all the studies on the J drive, but by looking at the J drive, you can see what is there.
Witness could easily generate a list of clinical studies for the drug at issue.
Steven Williams is the person with the most knowledge of the Lightside system. If the attorneys requested particular documents, they would have to go through Lightside or regulatory, not witness’ department.
The electronic pdfs are kept by data management, along with case report forms and electronic case report forms, so analytical science is involved.
Analytical science is the larger department that works closely with data management.
The company is unable to edit or change the actual data, if there is a question about anything; they go back to the sites and query it and it is updated either in paper or electronically.
Witness DNK if Lightside electronically scans everything; Jim Risuvio will be able to answer that question.