49
I I I I I I :- 1 I I le I I I ,I :1 I I IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA IN AND FOR THE COUNTY OF SAN DIEGO RHONA GILKEY AND JOHN GILKEY, . . PLAINTIFF, vs. ' NO. 698885 ' JACOB SWILLING, PAMELA SWILLING, TOM HAMILTON, DR. WENZEL, FRANK . SALAMAN, MAUREEN SALAMAN, ROBERT . BRADFORD, CAROLE BRADFORD, INSTITUTO GENESIS WEST-PROVIDA, AMERICAN BIOLOGICS, S.A., MICHAEL L. CULBERT, RODRIGO RODRIGUEZ, JORGE AGUILAR, VICTOR LOUSTANAU; AND DOES 1 THROUGH 200, INCLUSIVE, DEFENDANTS. . I DEPOSITION OF ROBERT BRADFORD SAN DIEGO, CALIFORNIA Fivecoat & With CertifiedShorthand Reporters, Inc. 701 B Street Suite 760 San Diego, California92101 MAY 6, .1997 MAY 2 7 1997 • ii/ I ( :..,_., i f f ' KATRINA F. BURLASON, CSR-NO. 5898

RHONA GILKEY AND JOHN GILKEY, I - quackwatch.org › wp-content › uploads › sites › 33 › quackwatc… · RHONA GILKEY AND JOHN GILKEY, . . PLAINTIFF, vs. ' NO. 698885 ' JACOB

  • Upload
    others

  • View
    3

  • Download
    0

Embed Size (px)

Citation preview

Page 1: RHONA GILKEY AND JOHN GILKEY, I - quackwatch.org › wp-content › uploads › sites › 33 › quackwatc… · RHONA GILKEY AND JOHN GILKEY, . . PLAINTIFF, vs. ' NO. 698885 ' JACOB

I I I I I I

:-1 I I

le I I I ,I :1 I I

IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA

IN AND FOR THE COUNTY OF SAN DIEGO

RHONA GILKEY AND JOHN GILKEY, . .

PLAINTIFF,

vs. ' NO. 698885 '

JACOB SWILLING, PAMELA SWILLING, •

TOM HAMILTON, DR. WENZEL, FRANK . SALAMAN, MAUREEN SALAMAN, ROBERT . BRADFORD, CAROLE BRADFORD,

◄ INSTITUTO GENESIS WEST-PROVIDA, AMERICAN BIOLOGICS, S.A., ◄

MICHAEL L. CULBERT, RODRIGO •

RODRIGUEZ, JORGE AGUILAR, VICTOR ◄ LOUSTANAU; AND DOES 1 THROUGH 200,

INCLUSIVE, ◄

DEFENDANTS. ◄ . I

DEPOSITION OF ROBERT BRADFORD

SAN DIEGO, CALIFORNIA

Fivecoat & With Certified Shorthand Reporters, Inc. 701 B Street Suite 760 San Diego, California 92101

MAY 6, .1997

MAY 2 7 1997 • ii/ I ( :..,_., i

f f '

KATRINA F. BURLASON, CSR-NO. 5898

Page 2: RHONA GILKEY AND JOHN GILKEY, I - quackwatch.org › wp-content › uploads › sites › 33 › quackwatc… · RHONA GILKEY AND JOHN GILKEY, . . PLAINTIFF, vs. ' NO. 698885 ' JACOB

I I I I I I

:-1 I I

le I I I I I I I

I N D E X

DEPONENT: ROBERT BRADFORD

By Mr. Hi 11

EXAMINATION

4

FOR THE PLAINTIFFS:

No. 1

No. 2

No. 3

No. 4

No. 5

INDEX OF EXHIBITS

Amer;can B;ologics-Mexico

S.A. Medical Center card

Science Corner: "Cancer

Protective Mechanisms Give

Therapy Clues"

Science Corner: "Another

'Secret' Weapon in Metabolic

Therapy"

Science Corner: "Hydrogen

Peroxide Administration:

Facts, Fancies and Metabolic

Peri 1 s

Science Corner: "A Major

New Weapon"

PAGE

37

38

38

39

39

2

Page 3: RHONA GILKEY AND JOHN GILKEY, I - quackwatch.org › wp-content › uploads › sites › 33 › quackwatc… · RHONA GILKEY AND JOHN GILKEY, . . PLAINTIFF, vs. ' NO. 698885 ' JACOB

I I I I I I

► I I I

-I I I I I I I

APPEARANCES:

FOR THE PLAINTIFFS:

Law Offices of John E. Hill By John E. Hill, Esq. First Floor 30 Hotaling Place San Francisco, California 94111

FOR DEFENDANTS THE BRADFORDS AND MICHAEL CULBERT:

Law Offices of Richard A. Higgins By Richard A. Higgins, Esq. 4403 Park Boulevard San Diego, California 92116

FOR DEFENDANTS THE SWILLINGS:

PERSONS PRESENT:

Law offices of James E. McElroy By James E. McElroy, Esq. Suite 1200 401 West A Street San Diego, California 92101

Carole Bradford

Deposition of Robert Bradford

taken by Plaintiffs at 110 Laurel Street, San Diego,

California, on Tuesday, the 6th day of May, 1997, at

1:22 p.m., before Katrina F. Burlason, CSR No. 5898,

3

Page 4: RHONA GILKEY AND JOHN GILKEY, I - quackwatch.org › wp-content › uploads › sites › 33 › quackwatc… · RHONA GILKEY AND JOHN GILKEY, . . PLAINTIFF, vs. ' NO. 698885 ' JACOB

I I 1

2

I 3

4

I 5

I 6

7

I 8

9

.. 10

11

I 12

I 13

14

I 15

16

I 17

le 18

19

I 20

21

I 22

I 23

24

I 25

26

I 27

28

I I

ROBERT BRADFORD,

Having been duly sworn, testified as follows:

EXAMINATION

BY MR. HILL:

Q. Please state your name.

A. Robert W. Bradford.

Q. What is your address?

A. 1180 Walnut Avenue, Chula Vista.

Q. Have you had your deposition taken before,

Dr. Bradford?

A. believe so. It's so many years ago, I

don't know what it was about.

Q. How do you prefer that I address you?

A. Oh, just Bob is all right.

Q. It has to be forma 1. I mean would it be

Mr. Bradford or Dr. Bradford?

A. You can either use Professor Bradford or

Dr. Bradford, either one.

Q. All right. I'm sure that your attorney has

explained the deposition procedure to you, but let me go

over it while we're on the record so that you understand

what will be taking place and we can clear up questions.

A. That would be helpful, because it's been a

long time.

Q. So that if there are any questions you have

about what we're doing, we can clear those up before we

launch into it.

4

Page 5: RHONA GILKEY AND JOHN GILKEY, I - quackwatch.org › wp-content › uploads › sites › 33 › quackwatc… · RHONA GILKEY AND JOHN GILKEY, . . PLAINTIFF, vs. ' NO. 698885 ' JACOB

I I I I I I

~ I I I

-I I I I I I I

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

First of all, you can't talk while I talk,

because it makes it hard for her, the court reporter, if

two people are talking at the same time. So I may even

hold up my hand to motion to wait until my question is

finished.

You have been administered the oath to tell

the truth, which is the same oath that's administered 1n a

courtroom in a court of law. We sit here informally, but

·the same penalties of perjury apply here that would apply

1n a courtroom.

Everything that we say will be taken down by

the court reporter unless we go off the record, and only

the attorneys go off the record, so so long as we're -- so

long as you're talking, you're on the record, unless one

of us has taken it off the record.

She will arrange to have what we say typed up

into a booklet form after the deposition showing the

questions and the answers. You will have the opportunity

to review that booklet and make any ~hanges in your

testimony that you feel should be made. If, however, you

make changes, those changes can be commented upon at the

time of the trial in the matter. So that you don't have

to make changes, therefore, it's important that you not

guess or speculate as to what your testimony, accurate

testimony, is or what my question was. And in that

connection, please ask me to rephrase, restate, clear up

any questions that you're having any trouble with. I '11

be more than happy to do that.

5

Page 6: RHONA GILKEY AND JOHN GILKEY, I - quackwatch.org › wp-content › uploads › sites › 33 › quackwatc… · RHONA GILKEY AND JOHN GILKEY, . . PLAINTIFF, vs. ' NO. 698885 ' JACOB

I I 1

2

I 3

4

I 5

I 6

7

I 8

9

~ 10

11

12

I 13

14

I 15

16

I 17

le 18

19

I 20

21

I 22

I 23

24

I 25

26

I 27

28

I I

If dur;ng the course of the proceed;ngs you

need to take a break for personal conven1ence, just speak

up, and you'll be accommodated. Okay?

A. Fine.

Q. Do you have any quest;ons

A. No.

Q. -- about the procedure?

You broke the first rule. You talked wh;le

was still talk;ng. It's very important that you not do

that.

A. Okay.

Q. And when you respond to a question, it has to

be audible, because she can't take ;t down otherwise. And

"uh-huhs" and "huh-uhs" are no good, because those are

hard to distinguish between. So it should be "yes" for

affirmatives and "no" for negatives. All right?

A. Yes.

MR. HIGGINS: Perfect.

BY MR. HILL:

Q. Okay. Dr. Bradford, I understand you were

born March 21, 1931.

A. March 22nd, 1931.

Q. In preparation for your deposition today,

have you reviewed any documents or writings or papers or

records?

A. No.

Q. Have you had any discussions with anyone

other than your attorney concerning your deposition?

6

Page 7: RHONA GILKEY AND JOHN GILKEY, I - quackwatch.org › wp-content › uploads › sites › 33 › quackwatc… · RHONA GILKEY AND JOHN GILKEY, . . PLAINTIFF, vs. ' NO. 698885 ' JACOB

I I 1

2

I 3

I 4

5

I 6

7

I 8

9

~ 10

11 I 12

I 13

14

I 15

I 16

17

.. 18

19

I 20

21

I 22

I 23

24

I 25

26

I 27

I 28

I

A. No.

Q. Did you graduate from Palo Alto High School

1n 1950?

A. Correct.

Q. And then 1n your answers to interrogatories

you ind;cate that you received an honorary bachelor's

degree from Stanford ;n 1965?

A. Yes.

Q. What 1s an honorary bache·lor's?

MR. HIGGINS: Object;on, may call for

speculation or legal opinion.

Answer if you can.

A. Okay. Bas;cally Stanford University has on a

number of occas1ons g;ven various degrees to staff members

that are working on the university as a result of the;r

exper1ence. And I just happen to be one of those.

BY HR. HILL:

Q. All right. And then you attended the

University of Hedic;na, H-e-d-i-c-i-n-a, Alternat;va,

A-1-t-e-r-n-a-t-;-v-a, ;n Shalanka, S-h-a-1-a-n-k-a,

Norway

A. No.

Q. -- 1s that correct?

A. No.

MR. HIGGINS: We may have had some typos. Go

ahead.

BY HR. HILL:

Q. What's incorrect about it?

7

Page 8: RHONA GILKEY AND JOHN GILKEY, I - quackwatch.org › wp-content › uploads › sites › 33 › quackwatc… · RHONA GILKEY AND JOHN GILKEY, . . PLAINTIFF, vs. ' NO. 698885 ' JACOB

I I 1

2

I 3

4

I 5

I 6

7

I 8

9

.. 10

11

I 12

I 13

14

I 15

16

I 17

le 18

19

I 20

21

I 22

23

I 24

I 25

26

I 27

28

I I

A. Well, I have a degree from University

Medicina Alternativa that got 1n the Netherlands, but

I 1 ve never been to Shalanka.

Q. All right. So you got a Doctor of Science

from that institution

A. Correct.

Q. -- from that institution 1n 1976?

A. That's appr~ximately right.

Q. And the institution is located where?

A. The university is located in Shalanka.

Q. In Norway?

A. No. In -- I don't remember. In the

eastern --

there.

MRS. BRADFORD: It's in I nd i a .

THE WITNESS: It's in Asia or India.

HR. HIGGINS: Please wait. It's his turn.

THE WITNESS: The point is I 1 ve never been

BY MR. HILL:

Q. To Shalanka, Norway.

Let me just show you your answers so there's

no mystery about this. 1 'm not saying that Sri Lanka.

A. I understand.

Q. It's Shalanka. Referring to your answer to

Interrogatory No. 2.7.

A. Okay. Let me see. Correct. Correct. Okay.

University of Medicina Alternativa, Shalanka 1 Norway,

Doctor of Science, correct. University of Stockholm,

8

Page 9: RHONA GILKEY AND JOHN GILKEY, I - quackwatch.org › wp-content › uploads › sites › 33 › quackwatc… · RHONA GILKEY AND JOHN GILKEY, . . PLAINTIFF, vs. ' NO. 698885 ' JACOB

I I 1

2

I 3

4

I 5

I 6

7

I 8

9

·~

10

11

I 12

I 13

14

I 15

16

I 17

.. 18

19

I 20

21

I 22

I 23

24

I 25

26

I 27

28

I I

Sweden, honorary Ph.D. ;n s;ochem;stry, correct.

MR. HIGGINS: That's it. Maybe I can help.

The university is in Shalanka. He received the Doctorate

of Science -- the honorary Doctorate of Science was

awarded in Norway.

Is that correct?

THE WITNESS: Um-hmm.

MR. HIGGINS: Okay.

THE WITNESS: Shalanka 1s a campus 1n Norway.

MR. HIGGINS: The name of the university is

Medicina Alternat;va.

THE WITNESS: It's one of the largest

integrative un;versities in the world, and they have

campuses all over the world.

BY MR. HILL:

Q. All r;ght. And which campus did you obtain

your degree from?

A. Norway.

Q. And I'm confused why you said you didn't go

there.

A. No. You asked if I'd been to Shalanka, and I

said no. Or I misunderstood your question, one way or the

other.

Q. All right. Did you obtain your Doctor of

Science from th;s un;versity in Shalanka, Norway?

A. Actua 11 y, I received it from Medici na

Alternativa, which is -- whose corporate headquarters 1s

in Shalanka.

9

Page 10: RHONA GILKEY AND JOHN GILKEY, I - quackwatch.org › wp-content › uploads › sites › 33 › quackwatc… · RHONA GILKEY AND JOHN GILKEY, . . PLAINTIFF, vs. ' NO. 698885 ' JACOB

I I I I I I

:-1 I I

.. I I I I I I I

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

Q. Right.

A. Okay.

Q. And where did you do your study?

A. In the Netherlands and Norway. actually

did a Ph.D. thesis in oxidology. And as a result of

submitting that thesis, I was awarded a Doctor of Science.

Q. All right. And that was for -- did you do

any course work or is this a

A. This is a Ph.D. thesis. I did no course

work.

Q. So you got your Doctor of Science by

prepar1ng a dissertation or a thesis?

A. Correct.

Q. And what's the name of the dissertation or

Actually, it has to do with coagulation

mechanisms, HLB blood tests.

Q.

A.

Q.

A.

Q.

Does it have a title?

"HLB Blood Tests."

Was it published?

Yes.

Where?

A. It's been published quite extensively

throughout the world. It's published in the book

"Oxidology," which ,s the book that submitted. It has

to do with free radical mechanisms, of which the HLB blood

test ,s one of the assessment tools.

Q. All right. And is that book available 1n a

10

Page 11: RHONA GILKEY AND JOHN GILKEY, I - quackwatch.org › wp-content › uploads › sites › 33 › quackwatc… · RHONA GILKEY AND JOHN GILKEY, . . PLAINTIFF, vs. ' NO. 698885 ' JACOB

I I

1

2

I 3

4

I 5

6

I 7

I 8

9

~ 10

11

I 12

I 13

14

I 15

16

I 17

18

- 19

I 20

21

I 22

23

I 24

I 25

26

I 27

28

I I

1;brary somewhere?

A. It 1s available, and it's currently be;ng

upgraded. It's out of print, but the new one's being

upgraded and will probably go to the printer this week, as

a matter of fact.

Q. With respect to the thesis that you got your

Doctor of Science Degree for, where could one go to get a

copy of that thesis?

A. American Biologics, I guess, would be one

place.

Q. All right. And then on your answers to

interrogatories you indicate that you received an honorary

Ph.D. in Biochemistry, 1983, from the University of

Stockholm, Sweden. Is that correct?

A. I don't think that's correct.

Q. Okay. Well, we all make mistakes, so if

there's a mistake there, correct it.

A. Where is this?

THE WITNESS: Which one 1s this?

MR. HIGGINS: The last one.

A. Ph.D. was from the university 1n Washington,

D.C. It was not from Stockholm, to the best of my memory.

And I don't know where the University of Stockholm came

from.

Do you?

MR. HIGGINS: That's fine. Try to clear it

up.

BY MR. HILL:

11

Page 12: RHONA GILKEY AND JOHN GILKEY, I - quackwatch.org › wp-content › uploads › sites › 33 › quackwatc… · RHONA GILKEY AND JOHN GILKEY, . . PLAINTIFF, vs. ' NO. 698885 ' JACOB

I I 1

2

I 3

4

I 5

I 6

7

I 8

9

:-10

11

12

I 13

14

I 15

16

I 17

le 18

19

I 20

21

I 22

23

I 24

I 25

26

I 27

28

I I

Q. All right. So it's your testimony you did

not rece1ve a Ph.D. from any university in Sweden; is that

correct?

A. No, that's correct.

Q. You testified you received a Ph.D. from a

university in Washington, D.C.?

A. Correct.

Q. What is the name of that university?

A. Roundtable University.

Q. Was that an honorary Ph.D. or --

A. I don't know.

Q. What is Roundtable University?

A. I don't know.

Q. Do you know whether they are accredited or

not?

A. No, I don't.

Q. Did you do course work to obtain that Ph.D.?

A. No. I submitted a thesis to them.

Q. Was that the same thesis as the one you

submitted to the u n i ve rs i ty - -

A. In basically the same subject, yeah, free

radical pathology.

Q. Was it a separate thesis or the same --

A. Same one.

Q. Same one?

All right. Then you indicate you were

convicted of a felony in 1977, for -- is that Laetril

distribution? Is that correct?

12

Page 13: RHONA GILKEY AND JOHN GILKEY, I - quackwatch.org › wp-content › uploads › sites › 33 › quackwatc… · RHONA GILKEY AND JOHN GILKEY, . . PLAINTIFF, vs. ' NO. 698885 ' JACOB

I I 1

2

I 3

4

I 5

I 6

7

I 8

9

► 10

11

12

I 13

14

I 15

16

I 17

-18

19

I 20

21

I 22

23

I 24

I 25

26

I 27

28

I I

A. I believe that's correct.

Q. And is that the only felony you've been

convicted of?

A. Yes.

Q. Dr. Bradford, can you tell me what your

employment has been, starting with the time period

starting let's say 1966.

A. No.

Q. What's the first employment that you recall?

A. Plus or minus a couple of years, I can

probably go through it for you.

Q. All right. Would you do that.

A. Yes. I got out of the Air Force ,n 1955.

went to work for General Electric and left General

Electric in about 1965. And I joined the staff at

Stanford around 1965. took a sabbatical in about 1977

and left the university in about 1978.

Q. Let me just interject. Did you teach at

Stanford during the time you were there?

A. I was on the technical staff.

Q. And that was in -- Was that in the field of

electrical engineering?

A. Yeah, electrical engineering and physics.

Q. And as a member of the technical staff, what

did you do?

A. Actually, I helped develop the switch tubes

for the linear accelerator. And I'm co-author of the

definitive book on the Stanford linear accelerator.

13

Page 14: RHONA GILKEY AND JOHN GILKEY, I - quackwatch.org › wp-content › uploads › sites › 33 › quackwatc… · RHONA GILKEY AND JOHN GILKEY, . . PLAINTIFF, vs. ' NO. 698885 ' JACOB

I I 1

2

I 3

4

I 5

I 6

7

I 8

9

.. 10

11

I 12

I 13

14

I 15

16

I 17

re 18

19

I 20

21

I 22

I 23

24

I 25

26

I 27

28

I I

Q. What's the t;tle of that?

A. The Stanford two-mi le 1 inear accelerator.

Q. All right. Then after --

A.

Afterwards

So that basically that's what I was do;ng.

went to work in the physics department of the

accelerator and worked there for a couple of years until I

terminated.

Q. And when did you terminate there?

A. Around '77, '78.

Q. Then what d;d you do?

A. I ran the Committee for Freedom of Choice 1n

Medic;ne till the mid '80s. And then we started a

hospital 1n Mexico sometime around

late '70s. I just collaborated to

I 'm not sure, the

we were working with

hospitals down there and then collaborated on getting what

is now American Biologics-Mexican hosp;tal. And then

essentially have curtailed most of my activity in the last

few years with the hospital in Mexico and I'm chairman of

the microbiology and microscopy at Capital University 1n

Washington, D.C., where I currently teach integrative

medicine.

Q. All right. You testified that you started a

hospital in Mexico in the mid-'70s; is that correct?

A. Wel 1, I collaborated in starting a hospital.

I was co-founder of one, yes.

Q. What was the name of that hospital?

A. American Biologics Hospital.

Q. And whom did you collaborate with?

14

Page 15: RHONA GILKEY AND JOHN GILKEY, I - quackwatch.org › wp-content › uploads › sites › 33 › quackwatc… · RHONA GILKEY AND JOHN GILKEY, . . PLAINTIFF, vs. ' NO. 698885 ' JACOB

I I 1

2

I 3

4

I 5

I 6

7

I 8

9

:-10

11

12

I 13

14

I 15

16

I 17

.. 18

19

I 20

21

I 22

23

I 24

I 25

26

I 27

28

I I

A. Dr. Rodriguez.

Q. And for how long did that collaboration at

the American Biologics Hospital in Mexico last?

A. A couple, three years. And the collaboration

extends today at a much lower level than it did initially.

Q. Okay. Referring specifically to the time

period around 1992, what was the extent of your

collaboration with Dr. Rodriguez in the American Biologics

Hospital in Mexico?

HR. HIGGINS: Objection, vague.

Go ahead and answer.

A. Okay. A consultant -- or, actually, I was a

consultant and director of research. And I don't remember

just when those -- but basically that's what I was doing

and have done and continue to do.

BY MR. HILL:

Q. How did you and Dr. Rodriguez go about

starting the hospital?

A. I don't understand the question.

Q. You've testified you participated 1n starting

this hospital in the mid-'70s and said you collaborated

with Dr. Rodriguez in starting it. I don't know, how do

you start a hospital? What do you do?

A. I do._n't know, I guess Dr. Rodriguez -- he's a

nuclear medicine man, and he was consulting with vanous

hospitals in Mexico in nuclear medicine, and he wanted to

start his own integrative hospital. So basically he came

15

Page 16: RHONA GILKEY AND JOHN GILKEY, I - quackwatch.org › wp-content › uploads › sites › 33 › quackwatc… · RHONA GILKEY AND JOHN GILKEY, . . PLAINTIFF, vs. ' NO. 698885 ' JACOB

I I 1

2

I 3

4

I 5

I 6

7

I 8

9

► 10

11

12

I 13

14

I 15

16

I 17

-18

19

I 20

21

I 22

I 23

24

I 25

26

I 27

28

I I

to me and asked me ;f I would help him do that.

Q. What ;s an ;ntegrative hospital?

A. Basically an integrative hospital 1n western

med;cine would be starting out with classic western

medicine and then integrating alternative--that is,

alternative to classical medicine--so that you then

integrate natural healing methods along with standard

allopathic therap;es.

Q. And the natural healing methods are us1ng

natural --

A. Well, ;t comes down to -- you can get into

all kinds of areas. It's not only the treatments but it's

the assessment, ;t's the philosophy. Basically ;t would

be ;nto the chiropractic end, the dental end. Although

you m;ght cons;der those standard allopathic, it isn't 1n

terms of a medical doctor integrat;ng those with;n his

practice. So that would be -- naturopathy, dietary

implicat;ons, herbal implications, so forth. These are

not commonly ;ntegrated ;nto a allopathic M.D. practice.

Q. All right. So he asked you to help him start

the hospital, and what role did you play 1n start;ng it?

A. Basically as a consultant to do research, to

help set the therapeutic protocols that would be used at

that time.

Q. Is there a building involved 1n American

Biologics?

A. There is.

MR. HIGGINS: Objection, vague as to time.

16

Page 17: RHONA GILKEY AND JOHN GILKEY, I - quackwatch.org › wp-content › uploads › sites › 33 › quackwatc… · RHONA GILKEY AND JOHN GILKEY, . . PLAINTIFF, vs. ' NO. 698885 ' JACOB

I I 1

2

I 3

4

I 5

I 6

7

I 8

9

:-10

11

12

I 13

14

I 15

16

I 17

,. 18

19

I 20

21

I 22

23

I 24

I 25

26

I 27

28

I I

Go ahead.

BY MR. HILL:

Q. At some point was a building obtained for the

hospital?

A. Yes.

Q. What role, if any, did you play with respect

to that?

A. None.

MR. HIGGINS: Let him finish.

I'm going to interpose an objection as vague

as to time.

And your answer, now, 1s

A. I didn't really have any role in the hospital

itself, other than maybe consulting in terms of what was

needed in the hospital. But I had no role in actually

building or financing or anything of that sort.

BY MR. HILL:

Q. Is American Biologics-Mexico a corporation?

A. Yes.

HR. HIGGINS: Objection, calls for a legal

conclusion.

Now you can answer.

A. Okay. As far as I know, it is a legal entity

1n Mexico. I don't know whether you would call that a

corporation._. in Mexico. I think it's an S.A., as I

remember, rather than incorporated. American

Biologics-Mexico S.A. Hospital I think is the total name

of the hospital. So I don't think they use the term Inc.

17

Page 18: RHONA GILKEY AND JOHN GILKEY, I - quackwatch.org › wp-content › uploads › sites › 33 › quackwatc… · RHONA GILKEY AND JOHN GILKEY, . . PLAINTIFF, vs. ' NO. 698885 ' JACOB

I I 1

2

I 3

4

I 5

I 6

7

I 8

9

:-10

11

12

I 13

14

I 15

16

I 17

re 18

19

I 20

21

I 22

I 23

24

I 25

26

I 27

28

I I

BY MR. HILL:

Q. Do you know who the shareholders are?

A. No. know who some of them are, but I don't

know whq/~nd what percentage of stock they hold. i

,/Q. Do you hold any? /

A. No.

Have you ever held any?

No. /

Q. ~~ect interest ,n the

profits of American Biologics-Mexico?

MR. HIGGINS: Objection, vague and ambiguous.

You can answer if you understand the

question.

A. I don't think I understand the question.

BY MR. HILL:

Q. Sure.

Do you rece1ve any of the profits produced by

American Biologics-Mexico?

you.

A. No.

MR. HIGGINS: Objection, vague.

That's your answer?

THE WITNESS: Should I wait till you've -­

MR. HIGGINS: Yeah, give it a pause. Thank

BY MR. HILL:

Q. Do you rece1ve the beneficial interest from

any of the shares held by any Mexican citizens in American

Biologics-Mexico?

18

Page 19: RHONA GILKEY AND JOHN GILKEY, I - quackwatch.org › wp-content › uploads › sites › 33 › quackwatc… · RHONA GILKEY AND JOHN GILKEY, . . PLAINTIFF, vs. ' NO. 698885 ' JACOB

I I 1

2

I 3

4

I 5

I 6

7

I 8

9

~ 10

11

12

I 13

14

I 15

16

I 17

le 18

19

I 20

21

I 22

23

I 24

I 25

26

I 27

28

I I

MR. HIGGINS: Object;on, vague.

Go ahead.

A. No.

BY MR. HILL:

Q. Do you rece1ve any funds -- w;thdraw.

Have you ever rece;ved any funds from work;ng

at Amer;can s;ologics-Mexico?

A. Yes.

Q. Can you describe the form of those funds.

A. There was a period of time when I was

spend;ng a lot of time down there in the late '80s and

they were pay1ng me a consulting fee at that time.

Q. Were you paid for your time?

A. Yes.

Q. Is there an American Biologics 1n the United

States?

A. Yes.

Q. Is that a corporation?

MR. HIGGINS: Objection, calls for a legal

conclusion.

Go ahead and answer.

A. I don't know.

BY MR. HILL:

Q. Do you have any involvement with American

Biologics 1n the United States?

A. I don't know how to answer that question.

I'm -- Could you be more specific.

Q. Are you employed by American Biologics?

19

Page 20: RHONA GILKEY AND JOHN GILKEY, I - quackwatch.org › wp-content › uploads › sites › 33 › quackwatc… · RHONA GILKEY AND JOHN GILKEY, . . PLAINTIFF, vs. ' NO. 698885 ' JACOB

I I

1

2

I 3

4

I 5

I 6

7

I 8

9

:-10

11

12

I 13

14

I 15

16

I 17

le 18

19

I 20

21

I 22

23

I 24

I 25

26

I 27

28

I I

A. No.

Q. Do you own the name American Biologics --

A. No.

Q. -- 1n the United States?

A. I'm sorry. No.

Q. Do you know who does?

A. Yes.

Q. Who?

A. Carole Bradford.

MR. HIGGINS: For the record, Counsel, let me

add to the extent that any of this can be established

through public record, I think that that's going to be the

f i na 1 say. I think you ' 11 find that the re is a CRB, Inc. ,

which 1s a California corporation and is doing business in

the county of San Diego as American Biologics. You will

also find an American Biologics, Inc., although I haven't

checked that for several years, which has a location in La

Jolla, that has no affiliation to this entity and was

notified in the late '80s that the successor -­

predecessor to CRB, Inc., Carole Bradford, had possession

of that name and right to use that name under common law.

And we have no record of American Biologics, Inc. ever

utilizing that name in the county of San Diego.

BY MR. HILL:

Q. All right. So CRB, Inc. owns the name -- has

proprietary interest in the name American Biologics?

MR. HIGGINS: That's correct.

BY MR. HILL:

20

Page 21: RHONA GILKEY AND JOHN GILKEY, I - quackwatch.org › wp-content › uploads › sites › 33 › quackwatc… · RHONA GILKEY AND JOHN GILKEY, . . PLAINTIFF, vs. ' NO. 698885 ' JACOB

I I I I I I

:-1 I I

I I I I I I I

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

Q. Who owns CRB, Inc.? Is that Carole Bradford?

A. That's correct.

MR. HIGGINS: Actually, it's owned by a

trust. The shareholder's a trust.

THE WITNESS: Okay. You would know.

MR. HIGGINS: It's a family trust created by

Caro 1 e Bradford.

BY MR. HILL:

Q. All right. Has CRB, Inc. authorized American

Biologics 1n Mexico to use that name --

HR. HIGGINS: Objection.

BY HR. HILL:

Q. -- to your knowledge?

A. It's my understanding that there 1s an

agreement between A.B.-USA and A.B.-Mexico to use that

name.

Q. Is that in writing?

A . As fa r as I kn ow , it 1 s .

Q. During the time period 1992, what activities

did you perform from which you earned income?

HR. HIGGINS: Objection, assumes facts not 1n

evidence.

Go ahead and answer, if you can.

A. don't -- the term "income" is the one

that's slowing me up. don't earn an 1ncome. I have my

expenses paid if I incur expenses. But I don't earn an

1ncome.

BY MR. HILL:

21

Page 22: RHONA GILKEY AND JOHN GILKEY, I - quackwatch.org › wp-content › uploads › sites › 33 › quackwatc… · RHONA GILKEY AND JOHN GILKEY, . . PLAINTIFF, vs. ' NO. 698885 ' JACOB

I I 1

2

I 3

4

I 5

I 6

7

I 8

9

► 10

11

12

I 13

14

I 15

16

I 17

~ 18

19

I 20

21

I 22

I 23

24

I 25

26

I 27

28

I I

Q. All right. And what act;v;t;es do you

perform for which you were compensated for expenses?

A. Well, I have a very active research

institute, the Bradford Research lnst;tute. I'm

compensated for specific research and so forth that we do.

That's ;nvolved primarily in cl;n;cal research, which

is -- the hospital benefits from. The Bradford Research

Institute is a 501(()(3), and I derive no salary from that

research institute. At this time I'm semi-retired.

still work in the research institute. I still teach at

the University, but I derive no salary from either one.

Q. Okay. Do you have a retirement 1ncome --

what I'm getting at: Obviously a person has to have food

and shelter and those kinds of things.

A. Hy wife is

Go ahead.

Q. So my question 1s where do you obtain the

money that you need to provide your food and shelter and

clothing and those kinds of things?

A. Well, part of it is Social Security. I'm on

Social Security. The major part of it is my wife is the

primary bread winner to the family. And I'm really just

the supporting spouse.

Q. And what does your wife do to earn income?

A. She's CEO of American Biologics.

MR. HIGGINS: I think he meant to say CRB,

Inc., doing business as American Biologics.

BY HR. HILL:

22

Page 23: RHONA GILKEY AND JOHN GILKEY, I - quackwatch.org › wp-content › uploads › sites › 33 › quackwatc… · RHONA GILKEY AND JOHN GILKEY, . . PLAINTIFF, vs. ' NO. 698885 ' JACOB

I I 1

2

I 3

4

I 5

I 6

7

I 8

9

► 10

11

12

I 13

14

I 15

16

I 17

-18

19

I 20

21

I 22

I 23

24

I 25 ..

26

I 27

28

I I

Q. All r;ght. And what are her duties as CEO of

CRB, Inc., doing bus;ness as American Biologics?

A. Well, she's CEO of the company, so that she

would have the same duties that any CEO would have of any

company that's running. She's being -- you know, just

and I'm not familiar enough with running a corporation to

be able to answer that question ;n detail.

Q. Is American Biologics located at 1180 Walnut

Avenue, Chula Vista?

A. Yes, it 1s.

Q. What ,s the business of American Biologics?

MR. HIGGINS: You're talking about CRB, Inc.,

doing business as American Biologics?

MR. HILL: Right.

MR. HIGGINS: Answer if you can.

A. A number of areas. There's a number of hats

that she -- involved 1n American Biologics. One of them

is the contract that we mentioned before with the Mexican

corporation using our name in Mexico, American

Biolog;cs-Mexico, so that we have a contract with them to

supply certain services and so forth, which American

Biologics ;s then paid for. So that's one phase. There's

another phase that is involved in vitamin, m;neral, enzyme

supplements. And Amer;can Biologics has some hundred-plus

products that they develop and market and d;stribute

throughout the world. So that's another area.

Another area involves med;cal electronics.

Amer;can Biologics builds, researches, develops, sells

23

Page 24: RHONA GILKEY AND JOHN GILKEY, I - quackwatch.org › wp-content › uploads › sites › 33 › quackwatc… · RHONA GILKEY AND JOHN GILKEY, . . PLAINTIFF, vs. ' NO. 698885 ' JACOB

I I 1

2

I 3

4

I 5

I 6

7

I 8

9

~ 10

11

12

I 13

14

I 15

16

I 17

~ 18

19

I 20

21

I 22

I 23

24

I 25

26

I 27

28

I I

m1croscopes, variable projection m1croscopy systems.

American Biologics is also involved in doing research,

other than the Bradford Research Institute, in

bioelectrical devices.

of it.

think that probably covers most

BY MR. HILL:

Q. What serv1ces are provided by CRB doing

business as American Biologics to American Biologics 1n

Mexico?

A. I can't really answer that in detail. I'm

not involved ,n that. We do supply a referral service for

patients to the hospital.

Q. Can you explain to me how the referral system

works.

A. Basically patients call in to American

Biologics and want information on the American Biologics

Hospital. That information is forwarded to them. If they

elect to and we have counselors there that will talk to

patients or prospective patients or physicians --

Q. This is at American Biologics in Chula Vista?

A. In Chula Vista, um-hmm.

So either the patients or the doctors of

patients, you know, if they want to know specifically what

the hospital is doing in Mexico, then we have counselors

to provide that information. And if they want detailed

information, then the counselors will get a hold of a

doctor to call either the doctor or patient. If the

patients elect to come to the hospital, American Biologics

24

Page 25: RHONA GILKEY AND JOHN GILKEY, I - quackwatch.org › wp-content › uploads › sites › 33 › quackwatc… · RHONA GILKEY AND JOHN GILKEY, . . PLAINTIFF, vs. ' NO. 698885 ' JACOB

I I

1

2

I 3

4

I 5

I 6

7

I 8

9

► 10

11

12

I 13

14

I 15

16

I 17

~ 18

19

I 20

21

I 22

23

I 24

I 25

26

I 27

28

I I

will schedule the patients 1n. Really they don't schedule

them in, they notify the hosp;tal and the hospital then

schedules them in -- notify the hospital that a patient

wants to come down. They'll usually get information as to

the logistics, what airplane they're coming in or how

they're gett;ng down there, and forward that information

to the hospital. I think that's the pr;mary -- we supply

~ts to the hospital and to the patients leaving the

hospital; that is, American Biologics does.

Q. Right.

Do you know why people call American

B;ologics in Chula Vista about the hospital in Mexico

rather than calling the hospital in Mexico?

MR. HIGGINS: Objection, calls for

speculation.

A. Well, it's been set up that way. It's all I

can tell you.

BY MR. HILL:

Q. When you say, "it's been set up that way,"

what do you mean?

A. That 1s to say, for numbers of reasons, I

guess the pr1mary one is trying to get in contact through

a Mexican phone system is not easily done to begin with.

So part of the service, then, of American Biologics with a

contract from the hospital is to provide this service.

You know, I don't know what other -- at one time they were

providing bookkeeping service. don't know if they're

still doi~t. See, I'm not involved in it.

25

Page 26: RHONA GILKEY AND JOHN GILKEY, I - quackwatch.org › wp-content › uploads › sites › 33 › quackwatc… · RHONA GILKEY AND JOHN GILKEY, . . PLAINTIFF, vs. ' NO. 698885 ' JACOB

I I 1

2

I 3

4

I 5

I 6

7

I 8

9

:-10

11

12

I 13

14

I 15

16

I 17

,. 18

19

I 20

21

I 22

23

I 24

I 25

26

I 27

28

I I

MR. HIGGINS: I'm go1ng to caution the

deponent to the extent he is basing his answer on

information and belief and estimations, that's fine. To

the extent that you're speculating, I'd caution you not to

go further. You've been premising a lot of what you're

say1ng, on "I'm not really sure, 1 'm not involved in

that." He is entitled to your best testimony, but I

caution you not to guess or to overly speculate. You can

use your best estimation.

BY MR. HILL:

Q. Dr. Bradford, with respect to the patients

that go to American Biologics in Mexico, do you know what

percentage of those patients are interviewed or screened

by American Biologics in Chula Vista?

A. No.

(Interruption at the door)

MR. HILL: Let's go off the record, take a

short break.

BY MR. HILL:

Q. All right. Back on the record.

Dr. Bradford, is the Bradford Research

Institute a partnership, sole proprietorship, corporation,

do you know?

MR. HIGGINS: Objection.

Go ahead. If you know.

A. I don't know. It's a research institute, and

don't know under the laws of the IRS how that's -- I

don't know.

26

Page 27: RHONA GILKEY AND JOHN GILKEY, I - quackwatch.org › wp-content › uploads › sites › 33 › quackwatc… · RHONA GILKEY AND JOHN GILKEY, . . PLAINTIFF, vs. ' NO. 698885 ' JACOB

I I I I I I

► I I I

I I I I I I I

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

BY HR. HILL:

Q. Do you know who owns it?

A. don't think anybody owns the research

institute. It belongs to the people. It's a 501(()(3),

tax-deductible research institute. I'm the president -­

or I'm the director of the research institute. I'm not

even sure who the president is.

Q. Are there any directors other than you, or

are you the only one?

A. There are several other directors.

Q. Who are they?

A. We have the Bradford Research Institute 1n

Washington, O.C., and the director there is Dr. John

Williams. Other than that, we have no other research

institute.

Q. Are there any paid employees of the Bradford

Research Institute?

A. No. have one biochemist who's paid by the

Bradford Research Institute.

Q. Who is that?

A. That's Henry Allen, A-1-1-e-n.

Q. In the time period of the '80s and '90s, did

you devote any time, yourself, to the activities of the

Bradford Research Institute as director?

A. I continuously devote myself to the Bradford

Research Institute, so I would see no reason why those

time periods I wasn't involved in it. I would have been,

yes.

27

Page 28: RHONA GILKEY AND JOHN GILKEY, I - quackwatch.org › wp-content › uploads › sites › 33 › quackwatc… · RHONA GILKEY AND JOHN GILKEY, . . PLAINTIFF, vs. ' NO. 698885 ' JACOB

I I 1

2

I 3

4

I 5

I 6

7

I 8

9

:-10

11

12

I 13

14

I 15

16

I 17

,. 18

19

I 20

21

I 22

I 23

24

I 25

26

I 27

28

I I

Q. As director of the Bradford Research

Institute, what have you done?

A. The research institute has published a number

of papers 1n the peer-reviewed literature. We published

three textbooks. We have some 55 in the order 55 to 60

research papers on various aspects of biochemical industry

and clinical chemistry, therapeutic protocols. We -­

We've just recently got (LAA approval for our blood

morphologies that we have been developing since the late

'70s.

MR. HIGGINS: What was that acronym?

A. Clinical Laboratory Approval Act, CLAA, it's

a federal agency that regulates laboratory procedures.

And within the last six months they approved the Bradford

peripheral blood morphologies and correlations.

MRS. BRADORD: Accepted.

A. Now, they don't approve anything. They

accepted them.

BY MR. HI LL:

stand corrected.

Q. Is there a separate Robert Bradford Research

Institute from the Bradford Research Institute?

A. It's one and the same. I use the term

i nterchangeab 1 y. It's actua 11 y the Robert W. Bradford

Research Institute is the full name.

Q. In 1992, were you spending any time at .

American Biologics-Mexico?

A. Well, I'm sti 11 consultant to the hospital.

And I would suspect in 1992 nothing had changed, so I

28

Page 29: RHONA GILKEY AND JOHN GILKEY, I - quackwatch.org › wp-content › uploads › sites › 33 › quackwatc… · RHONA GILKEY AND JOHN GILKEY, . . PLAINTIFF, vs. ' NO. 698885 ' JACOB

I I I I I I

:-1 I I

.. I I I I I I I

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

would still be a research consultant at the hospital.

Q. And did you spend time on the prem;ses there

1n

A. Yes.

Q. How much t;me?

A. I wouldn't know.

MR. HIGGINS: He's entitled to your best

estimate.

So I '11 ;nterpose an objection it's vague as

to time.

Would a narrow1ng of time during 1992 assist

you at all in formulating an answer?

A. A couple of days a week back 1n those times.

BY MR. HILL:

Q. Wh;le you were there in 1992, did you meet

the plaintiff, Rhona Gilkey, or the pla;ntiff, John

G;lkey?

A. No. I was not at the hospital when they were

there.

Q. Did you ever have an occas;on to discuss the

care they received with anyone other than your attorney?

A. No.

Q. Did you have any knowledge of the reason that

Mrs. Gilkey entered American Biologics-Mexico?

A. No.

Q. Do you have any knowledge concern1ng the

treatment she received?

A. No.

29

Page 30: RHONA GILKEY AND JOHN GILKEY, I - quackwatch.org › wp-content › uploads › sites › 33 › quackwatc… · RHONA GILKEY AND JOHN GILKEY, . . PLAINTIFF, vs. ' NO. 698885 ' JACOB

I I 1

2

I 3

4

I 5

I 6

7

I 8

9

:-10

11

12

I 13

14

I 15

16

I 17

.. 18

19

I 20

21

I 22

23

I 24

11 25

26

I 27

28

I I

Q. Have you ever reviewed her medical records?

A. No.

Q. Were you ever the administrator of American

Biologics-Mexico?

A. Yes.

Q. When was that?

A. I don't remember when that was terminated.

At one

administrator, back in the late '70s-early '80s. And then

the t;tle was changed to research d; rector.

Q. Who appointed you as admi n; strator?

j A. Dr. Rodr;guez.

Q. Were you ever the president of American

B;olog;cs-Mexico?

MR. HIGGINS: Objection, calls for a legal

conclus;on.

Go ahead and answer.

A. I don't know.

BY MR. HILL:

Q. Is American Biolog;cs -- w;thdraw.

Does American Biologics-Mexico have its

international admissions office at 1180 Walnut Avenue,

Chula Vista?

A. I don't know.

Q. Let me show you what has been marked as

Plaintiffs' 1, which is the back cover of the Summer of

'93 issue of "The Choice," and ask you to look at that,

and specifically ask if you would look here at the bottom,

30

Page 31: RHONA GILKEY AND JOHN GILKEY, I - quackwatch.org › wp-content › uploads › sites › 33 › quackwatc… · RHONA GILKEY AND JOHN GILKEY, . . PLAINTIFF, vs. ' NO. 698885 ' JACOB

I I 1

2

I 3

4

I 5

I 6

7

I 8

9

► 10

11

12

I 13

14

I 15

16

I 17

~ 18

19

I 20

21

I 22

I 23

24

I 25

26

I 27

28

I ~.

where it says, "International Administrative Office,ll and

see if that

A. Admissions office?

Q. Right.

A. Yeah. That's what this says, yeah.

Q. Wait for my question. Hy question is, by

referring to Plaintiffs' 1 wherein underneath American

Biologics-Mexico S.A. Medical Center, states,

"International administrative office, 1180 Walnut Avenue,

Chula Vista, California, et cetera.

I ask you to review that, and my question 1s

does that refresh your recollection whether the

international administrative office for American

Biologics-Mexico S.A. is at 1180 Walnut Avenue, Chula

Vista, California.

MR. HIGGINS: Objection. know this 1s

unintentional, Counsel, but the document says

international admissions office, not administrative. And

what he's asking you with respect to refreshing your

recollection 1s not because you see it here, but by seeing

it here does it refresh for you -- Jog 1n your memory a

knowledge or understanding that this is the location of

the international admissions office for American

Biologics-Mexico S.A. Medical Center.

A. The answer 1s no.

BY MR. HILL:

Q. In the summer of 1993, what position, if any,

did you have with the magazine, "The Choice"?

31

Page 32: RHONA GILKEY AND JOHN GILKEY, I - quackwatch.org › wp-content › uploads › sites › 33 › quackwatc… · RHONA GILKEY AND JOHN GILKEY, . . PLAINTIFF, vs. ' NO. 698885 ' JACOB

I I 1

2

I 3

4

I 5

I 6

7

I 8

9

:-10

11

12

I 13

14

I 15

16

I 17

.. 18

19

I 20

21

I 22

23

I 24

I 25

26

I 27

28

I I

A. I'd have to look at "The Cho;ce." I'm a

consultant to American Biologics as well as American

B;ologics Hospital, but -- and I usually put in a

scientific corner. In this particular one, I'm sure

have one here someplace. So the research institute would

usually contribute a scientific corner to the magazine.

This one that you've shown me was our research on systemic

Candida. But that's the extent that I have anything to do

with the magaz1ne.

HR. HILL: When I refer to Plaintiffs'

Exhibit 1, did

deposition?

indicate that was from Hr. Culbert's

THE REPORTER: don't think so.

MR. HILL: Well, let me just state for the

record that was from Mr. Culbert's deposition, not -­

MR. HIGGINS: And for the record, that was

"The Choice" magaz1ne, 1s that what --

MR. HILL: Summer of '93, correct.

BY MR. HILL:

Q. Okay. One of the articles that was marked as

a group Exhibit 3 in Hr. Culbert's deposition includes a

three page pamphlet, "Robert W. Bradford Research

Institute." And let me show you that, Dr. Bradford. If

you would just look at it, I have a couple of questions.

A. Okay.

MR. HIGGINS: For the record, the title of

the document appears to be "Management of Chronic Fatigue

Syndrome (aka Chronic Fatigue/Immune Dysfunction Syndrome)

32

Page 33: RHONA GILKEY AND JOHN GILKEY, I - quackwatch.org › wp-content › uploads › sites › 33 › quackwatc… · RHONA GILKEY AND JOHN GILKEY, . . PLAINTIFF, vs. ' NO. 698885 ' JACOB

I I I I I I

:-1 I I

I I I I I I I

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

at Amer;can B;olog;cs-Mex;co, S.A."

BY MR. HILL:

Q. Is that a paper put out by the Robert W.

Bradford Research lnst;tute?

A. bel;eve th;s 1s a paper that was written by

M;ke Culbert. And I probably rev;ewed the article at the

t;me just for any errors. Th;s isn't --

MR. HIGGINS: The question 1s was this paper

put out by the Robert W. Bradford Research lnst;tute.

A. th;nk ;nasmuch as it's on the research

;nstitute letterhead and Michael Culbert wrote ;t, then it

would have been, I guess, legally put out by the Bradford

Research Institute.

BY MR. HILL:

Q. All right. And it's your recollection that

you rev;ewed it for m;stakes or accuracy or what have you?

A. No. just said I probably would have.

really don't recogn;ze the art;cle.

Q. It states, s,r, "As of 1993, this research

hospital had seen more than 2,200 patients since 1980

suffering from a variety of complaints," and then it lists

them. When the article states, "this research hospital,"

what research hospital does that have reference to?

MR. HIGGINS: Objection, misstates the

testimony. He's testified he is not the author, nor does

he recall the article. 1 '11 also interpose the objection

that it's irrelevant, immaterial, and not likely to lead

to admissible evidence.

33

Page 34: RHONA GILKEY AND JOHN GILKEY, I - quackwatch.org › wp-content › uploads › sites › 33 › quackwatc… · RHONA GILKEY AND JOHN GILKEY, . . PLAINTIFF, vs. ' NO. 698885 ' JACOB

'

I I I I I I

► I I I

~ I I I I I I I

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

A.

BY MR. HILL:

Q.

You can answer, ;f you can, Dr. Bradford.

I'm sorry, I forgot the quest;on.

Sure. The f;rst sentence says, nAs of 1993,

th;s research hospital had seen more than 2,200 pat;ents

s;nce 1980 suffer;ng from a var;ety of complaints," and

then goes on to 1;st them. I'm ask;ng what research

hospital 1s referred to there.

A. I assume, s1nce the heading is American

Biologics, S.A., that's what he was referring to.

know what he's referring to on the 2,200 patients.

to me may or may not be the case.

don't

That

MR. HIGGINS: He's entitled to your best

estimate. don't want you speculating as to any answers.

THE WITNESS: Yeah. So I -- I really don't

know. don't know -- chronic Epstein-Barr v1rus, acute

candidias;s, universal reactor syndrome, mixed multiviral

syndrome, environmental poisoning --

MR. HIGGINS: She's trying to take down what

you're say1ng, so if you're going to read --

THE WITNESS: I'm mumbling to myself. Sorry.

The various -- symptoms that are discussed 1n

this first chapter can be involved in chronic fatigue

syndrome but not necessarily so.

BY HR. HILL:

Q. My question was directed specifically,

Doctor, to which research hospital was being referred to.

A. I assume it's in the American Biologics

34

Page 35: RHONA GILKEY AND JOHN GILKEY, I - quackwatch.org › wp-content › uploads › sites › 33 › quackwatc… · RHONA GILKEY AND JOHN GILKEY, . . PLAINTIFF, vs. ' NO. 698885 ' JACOB

\

I I I I I I

:-1 I I

.. I I I I I I I

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

Hospital, because that's what he's quoting up 1n the

title.

HR. HIGGINS: In the title of American

Biologics-Mexico S.A.?

THE WITNESS: Um-hmm.

MR. HIGGINS: Is that correct?

THE WITNESS: That 1s correct.

I forget she can't transcribe grunts.

MR. HIGGINS: She can, but then we have to

call her in as a witness.

BY MR. HILL:

Q. Let me show you what was marked as

Plaintiffs' 4 to Mr. Culbert's deposition and ask if you

either prepared for or contributed to it.

A. Okay. What was the question, again? I was

reading.

Q. Did you prepare that document?

A. No.

Q. Did you participate ,nits preparation 1n any

way by contributing any information that's included

therein?

A.

Q.

No.

Let me show you what we marked as Plaintiffs'

5 to Mr. Culbert's deposition and ask whether you prepared

Plaintiffs' 5 or any part of it, and if it's a part, what

part.

MR. HIGGINS: Counsel, while he's rev1ew1ng

it, was Exhibit 4 a stand-alone exhibit?

35

Page 36: RHONA GILKEY AND JOHN GILKEY, I - quackwatch.org › wp-content › uploads › sites › 33 › quackwatc… · RHONA GILKEY AND JOHN GILKEY, . . PLAINTIFF, vs. ' NO. 698885 ' JACOB

I I 1

2

I 3

4

I 5

I 6

7

I 8

9

~ 10

11

I 12

I 13

14

I 15

16

I 17

.. 18

19

I 20

21

I 22

23

I 24

I 25

26

I 27

28

I I

MR. HILL: A what?

MR. HIGGINS: Was ;ta stand-alone exh;b;t or

was it part of a package?

MR. HILL: It was a stand-alone, to my

recollect;on, and it's

A. Th;s Exhibit 4 --

MR. HIGGINS: This 1S

BY MR. HILL:

Q. -- 5.

A. This Exhibit 5 15 a brochure on the hospital

that has been developed over a number of years.

MR. HIGGINS: Is there a pending question?

What is it?

BY MR. HILL:

Q. Did you prepare 5 or any part of 5, and if

so, what pa rt?

A. would have -- I don't remember just to what

extent, but I would have been involved -- certainly when

they talk about various therapies and assessments, that

sort of thing, I would have been involved from a

counseling point of view. This is a marketing brochure,

and I think a lot of people would have been involved in

the production of that.

Q. Specifically with respect to the description

of who Robert W. Bradford is, . .did you prepare that? And

that's on Page -- well, the document's not numbered, but

the only page with your picture.

A. On the only page with my picture.

36

Page 37: RHONA GILKEY AND JOHN GILKEY, I - quackwatch.org › wp-content › uploads › sites › 33 › quackwatc… · RHONA GILKEY AND JOHN GILKEY, . . PLAINTIFF, vs. ' NO. 698885 ' JACOB

I I I I I I

I I I

.. I I I I I I I

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

I don't know if I actually developed the

wording to this, but they certainly would have consulted

with me before they put this together.

Q.

A.

Does that accurately reflect who you are?

Well, let's see. Probably at this time,

whenever this time frame was, it's probably reasonably

correct as far as I can tell, just scann1ng it.

Q. When you say "this time,n what time period

would that have been when that would have been accurate?

A. It's essentially accurate today, so I said

don't know when it was written. The reason why I say

that: It said 35 research papers, and now we have over

50. So it must have been written a couple of years ago.

Q. Okay. Dr. Bradford, I'm go1ng to g1ve you a

pile of pamphlets here and ask if you would go through

them and select out those pamphlets or papers that were

written by you. And if you could just set them in a

separate pile for me, please.

HR. HILL: And let's go off the record to do

this.

(Discussion off the record)

BY MR. HILL:

Q. Okay. Back on the record.

Dr. Bradford, let me show you now what I've

marked as Plaintiffs' 1, which 1s a colored brochure

entitled, "American Biologics."

(Plaintiffs' Exhibit 1

marked for identification)

37

Page 38: RHONA GILKEY AND JOHN GILKEY, I - quackwatch.org › wp-content › uploads › sites › 33 › quackwatc… · RHONA GILKEY AND JOHN GILKEY, . . PLAINTIFF, vs. ' NO. 698885 ' JACOB

I I 1

2

I 3

4

I 5

I 6

7

I 8

9

:-10

11

12

I 13

14

I 15

16

I 17

.. 18

19

I 20

21

I 22

I 23

24

I 25

26

I 27

28

I I

BY MR. HILL:

Q. What, if any, involvement did you have with

the preparation of Plaintiffs' 1?

A. None.

Q. Were you consulted with respect to

Plaintiffs' 1?

A. really don't know. Not to my recollection.

(Plaintiffs' Exhibit 2

marked for identification)

BY MR. HILL:

Q. Showing you Plaintiffs' 2, Science Corner:

uCancer Protective Mechanisms,u is that something that you

wrote?

A. This would have been something that I would

have been involved in, yes, very definitely.

Q. All right. Is that

A. Basically the research institute put it

together. So that could involve any number of people that

I would have wanted to get involved in it, depending upon

the complexity and so forth.

Q. What

A. But, yes, I would have been definitely

involved ,n putting it together.

Q. A 11 right. Would that have been something

that you would have reviewed before it was published?

A. Yes.

(Plaintiffs' Exhibit 3

marked for identification)

38

Page 39: RHONA GILKEY AND JOHN GILKEY, I - quackwatch.org › wp-content › uploads › sites › 33 › quackwatc… · RHONA GILKEY AND JOHN GILKEY, . . PLAINTIFF, vs. ' NO. 698885 ' JACOB

I I 1

2

I 3

4

I 5

I 6

7

I 8

9

:-10

11

12

I 13

14

I 15

16

I 17

.. 18

19

I 20

21

I 22

23

I 24

I 25

26

I 27

28

I I

BY HR. HILL:

Q. Let me show you 3, another reprint from

Science Corner, "Another 'Secret' Weapon in Metabolic

Therapy."

Is 3 something that is a reprint of something

that you either wrote or approved before publication?

A. Yes. Same thing: would have been involved

with that publication.

(Plaintiffs' Exhibit 4

marked for identification)

BY MR. HILL:

Q. Okay. Let me show you what we've marked as

Plaintiffs' 4, appears to be another reprint from Science

Corner: "Hydrogen Peroxide Administration: Facts,

Fantasies, and Metabolic Perils."

Is that something you either wrote or

approved before it was published?

MR. HIGGINS: Inasmuch as this document seems

to include other items, I want you to be specific in your

response.

A. I would have been involved in the hydrogen

peroxide part of this and the exhibits that are here. But

the advertising, and certainly the hospital advertising,

this is part of the magazine that I wouldn't have had

anything to do with.

(Plaintiffs' Exhibit 5

marked for identification)

BY HR. HILL:

39

Page 40: RHONA GILKEY AND JOHN GILKEY, I - quackwatch.org › wp-content › uploads › sites › 33 › quackwatc… · RHONA GILKEY AND JOHN GILKEY, . . PLAINTIFF, vs. ' NO. 698885 ' JACOB

I I I I I I

I I I

.. I I I I I I I

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

Q. All right. Let me show you what we've marked

as Plaintiffs' 5, which 1s a re- --

MR. HIGGINS: Do you want them marked?

THE REPORTER: That would be good, if you

have time.

BY MR. HILL:

Q. What? They've got numbers on them.

Let me show you what we've marked Plaintiffs'

5, a research newspaper, nA Major New Weapon.n want to

know if that's something you authored or approved before

publication.

A. Again, the uScience CornerH would have been

something that I would have certainly reviewed. The

advertising part of it, I would have not been involved.

That would have been the editorial part of the magazine,

which I'm not involved ,n.

HR. HILL: Okay. I have no further

questions.

MR. HIGGINS: Jim?

MR. McELROY: No. Thank you.

MR. HIGGINS: Okay. You want to offer a

stipulation or --

MR. HILL: Yeah, same stipulation, I guess.

Is that okay with everyone?

MR. HIGGINS: Sure. The original coming to

my office, and I '11 notify counsel in accordance with

whatever the first stipulation was. And I '11 maintain the

odginal.

40

Page 41: RHONA GILKEY AND JOHN GILKEY, I - quackwatch.org › wp-content › uploads › sites › 33 › quackwatc… · RHONA GILKEY AND JOHN GILKEY, . . PLAINTIFF, vs. ' NO. 698885 ' JACOB

I I I I I I

► I I I

.. I I I I I I I

J

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

MR. HILL: Okay.

MR. McELROY: So stipulated.

MR. HILL: Fine.

Shall we take a short break and then do

Mrs. Bradford?

MR. HIGGINS: Certainly.

MR. HILL: have 2:45.

I declare under the penalty of perJury that

the foregoing testimony is true and correct.

Executed on ______ , 1997, at ____ _

ROBERT BRADFORD

41

Page 42: RHONA GILKEY AND JOHN GILKEY, I - quackwatch.org › wp-content › uploads › sites › 33 › quackwatc… · RHONA GILKEY AND JOHN GILKEY, . . PLAINTIFF, vs. ' NO. 698885 ' JACOB

I I I ·1 I I

► I I I

.. I I I I I I I

STATE OF CALIFORNIA ) . ss .

COUNTY OF SAN DIEGO )

I I ~,ch--/,-it{. J. f?u--r/ q,-3,,_, , a Certified Shorthand

Reporter in and for the County of San Diego, State of

California, do hereby certify:

That the deponent in the foregoing deposition was by me

duly sworn; that the deposition was then taken before me

at the time and place herein set forth; that the testimony

and proceedings were reported stenographically by me and later

transcribed into typewriting under my direction; that the

foregoing is a true record of the testimony and proceedings

taken at that time.

() That the deponent was notified in writing that the

original deposition was available for reading and signing

pursuant to Code of Civil Procedure section 2025(q)(1) and

that the deponent did not exercise that right or contact the

deposition officer.

() That ~he deponent made changes to the deposition as

indicated by:

() Changes made upon the original deposition.

() Changes made by attached correspondence.

In witness whereof, have subscribed my name this

/9/t( day of _e21 _____ 3 ___ . 19.f.Z.

Page 43: RHONA GILKEY AND JOHN GILKEY, I - quackwatch.org › wp-content › uploads › sites › 33 › quackwatc… · RHONA GILKEY AND JOHN GILKEY, . . PLAINTIFF, vs. ' NO. 698885 ' JACOB

I

I·.•,· :_:-:::_ : .

• I:· . . '

:1iii:ii!~~t)'.~ i(Iill:Jitt~

I: I._;.

·, .. · ·:•::

I

. . I.; . i

I

~ ~u,"S1 EXH. I , I FOR ID TO DEPO. OF @S't., aRJi. ~P,¢ QATE ____ s_-_;,.~_-_1_7~-

~1.1qt.ASON

Page 44: RHONA GILKEY AND JOHN GILKEY, I - quackwatch.org › wp-content › uploads › sites › 33 › quackwatc… · RHONA GILKEY AND JOHN GILKEY, . . PLAINTIFF, vs. ' NO. 698885 ' JACOB

I SCIENCE CORNER --1·~-t-"s" EXH .,

- . - FOR /0 TO DEPO. OF ,i;;gse -DATE - T ~ .b£p ,td

I Cancer protective mechanisms give the}apY~~s-

1 I I I

By ROBERT W. BRADFORD . (Mr. Bredlord la preald•nl of American 8lolo9lca. llMt Bredlord Foundellon end the Com­mltlH lor FrHdom of Choice In Cenc•r Th•r•pr .)

As its _growth continues, cancer uses various devices to assure its survival and to protect itself from destruction by the host. Some of these protective mechanisms are now understood at the molecular level.

As cancer's protective mechanisms for the assurance of survival become fully understood such knowledge becomes a powerful tool against cancer by suggesting various methods of treatment at the molecular level. Several forms of anti­cancer treatment are already available based on this knowledge.

Research into the area of cancer protective devices has led to the

I administration of such enzymes as catalase, superoxide dlsmutase (S.O.D.) and glulathione peroxidase as well as the chemical DMSO s important weapons against malignancy.

I I I

One method of selectively destroying cancer cells is to take dvantage of the absence of one of the two superoxide dismutases S.O.D.), manganese S.O.D., in cancer cells and to develop a selec­

tive inhibitor of copper-zinc S.O.D. (Potentially damaging superoxides are produced by the normal

utilization of oxygen in animal cells. No animal cell can survive with­out the destruction of superoxides. Their damaging effects are pre­vented by the presence of S.O.D. enzymes. There are two basic types of S.O.D., but manganese S.0.D. is known to have disappeared in virtually every kind of cancer cellJ

(The first reaction product which results from the destruction of superoxides by S.O.D. is hydrogen peroxide, elevated amounts of which cause great destruction throughout the body. II has been shown that cancer cells generate substantial amounts of hydrogen peroxide, the primary invasive mechanism.)

-If 1uperoxlde1 are not destroyed, they may combine with hydrogen peroxide and generate the even more potentially damag-

,_ ng hydroxyl free radical. Paradoxically, the hydroxyl radical ctually stimulates the enzyme guanylate cyclase, which is respon­ible for the formation of cyclic-GMP, a known stimulator of cell divi-

I I I I I I I

sion. Higher levels of both guanylate cyclase and cyclic-GMP are found in malignant cells.

The enzyme catalase and the chemical dimethyl sulloxide (DMSO). a known scavenger of free radicals, are utilized in helping to control the damaging ellecls of hydroxyl radicals.

A part of the normal blood clotting mechanism is the end-to-end linking of a protein present in the blood known as fibrinogen. which forms the soft clot. This protein normally is dormant or inactive. When activated by remaining sialic acid during wound healing, for example, the ends link together, forming long strands of proteins in the form of a loose network, constituting a gel-like mass.

It has been discovered that tumors secrete a substance which activates fibrinogen, causing the formation of a cocoon or shield around them. This shield protects the tumor surface from being con­tacted by antibodies which could otherwise lead to the destruction of the cancer cells. Through this mechanism the tumor uses the nor­mal wound healing process and tricks it to act as if the cancer were a wound to be healed. Ongoing research using anti-clotting agents hopes to prevent the formation of this protective shield.

When fibrinogen is activated to a form capable of linking end-to­end forming long threads of protein a type of sugar-acid known as sialic acid is liberated. II has been shown that when sialic acid alone is removed from fibrinogen a soft clot is formed.

Ongoing experiments in our laboratory show that the formation of fibrinogen filaments or the soft clot resulting trom the removal of sialic acid is related to the formation of tree hydrogen peroxide.

When 1 mg of the enzyme catalase (which destroys hydrogen peroxide) is coupled with 1 mg of super-oxide dismutase (S.O.O.) and administered per day to a 70 kg adult the blood is cleared of activated fibrinogen.

It Is known that the sedimentation rate of whole blood is lower for cancer patients than normal individuals. An increase in the viscosity of the plasma or fluid part of the blood is responsible for the slower settling of red blood cells. The presence of any type of polymer formed from fibrinogen will lead to an increased viscosity of plasma.

It is speculated that there are two reasons tumors produce more hydrogen peroxide than normal tissues: (1) the absence of manganese S.O.D. from tumor cells, leading to an increased produc­tion (and survival) of superoxides, which results in greater amounts of peroxide (even in the ab_sence of S.O.D.); and (2) lowered activity by catalase (an enzyme that destroys peroxide) and glutathione peroxidase (an enzyme that destroys peroxide in the presence of glutathionel. In the light of these facts, combined with the removal of fibrin polymers from the blood following ca la lase administration, it is highly likely that the factor responsible for the formation of the cocoon or fibrin net around malignant tumors is hydrogen peroxide.

Whenever the body is exposed to foreign material, the immune system is triggered to destroy it through both cellular and chemical means. The cellular aspect consists of attack by white cells, the lymphocytes, macrophages and others.

The chemical aspect involves the production of antibodies which are nothing more than custom-made proteins fashioned to neutral­ize the particular structures present in the invading material.

It has been shown that even though malignant cells are a part of the body they may be recognized by the immune system as foreign. One might wonder how a tumor could survive such a highly elabor­ate system of detection and destruction. The tumor accomplishes this through the sialic acid protein coat and fibrin net which cover and mask the surface, preventing contact with white cells and thP transfer of information to the antibody-producing cells.

Efforts have been made to remove this coat, thereby exposing the surface antigens (chemical groups which identify the surface as being abnormal). The glycoprotein coat contains sialic acid, which is capable of binding calcium. The calcium may be removed through the action of ethylenediamine tetraacellc acid (EDT Al, well known as a chelation therapy agent. Enzymes may then be applied for the purpose of removing both the sialic acid protein coafand fibrin net.

In animal experiments with transplanted lymphosarcoma striking results have been found which demonstrate that certain aspects of cancer metabolism can take control of certain vital cellular pro­cesses. During the first 7 days after receiving the transplant the activity of catalase increases arising from the body's response lo an increased production of hydrogen peroxide, this enzyme's sub­strate. During the next 7 days the activity falls below that of normal control animals and continues to fall to less than one tenth of these values. Eventually catalase synthesis totally ceases.

The cause of the imbalance and cessation of synthesis results from an excess of a factor which normally regulates the level of this enzyme. An excess ot the inhibitory tactor is somehow generated by an aspect of cancer metabolism not understood. These results have been found to apply additionally to glutathione peroxidase and giutathione reductase. two enzymes also concerned with the destruction of hydrogen peroxide.

The final confirmation of the concept of normal cell metabolism being taken over and controlled by the malignant slate is that follow­ing the destruction or removal of the tumor, the normal levels of both enzyme synthesis and activity are restored.

The next In this series of articles will be "Dramatic Therapeutic Effects of the Unsung Enzyme."

Page 45: RHONA GILKEY AND JOHN GILKEY, I - quackwatch.org › wp-content › uploads › sites › 33 › quackwatc… · RHONA GILKEY AND JOHN GILKEY, . . PLAINTIFF, vs. ' NO. 698885 ' JACOB

SCIENCE CORNER

I Another 'secret' weapon in metabolic therapy I By ROBERT _W. BRADFORD

President, Bradford Research Institute

I A Tennessee physician. Cecil Pitard. is completely free of Stage Ill lymphocytic lymphoma. 18 months after he was diagnosed with the disease at the Mayo

I Clinic. That single tact is amazing enough,

since this kind of cancer i:s incurable. But · even more amazing was the therapy that

I Dr. Pitard researched and used on · himself - the common fatty acid sodium butyrate and an anti-bacterial llu vaccine (staphage lysate).

I Both these modalities are now available at the American-Biologics Mexico Hospital.

Our Bradford Research Institute research has turned up a tremendous amount of inlormation about the unsung substance

I sodium butyrate - or. simply, butyric acid or butyrate. Incredibly enough. a lairly extensive literature exists on this substance. but it

s not been generally advanced in this country for cancer. We

ume this is because butyric aci.d is not patentable and is fairly xpensive to buy. OUR RESEARCH also turned up links between butyric acid and

s1alic acid metabolism. Readers ot this Corner may t?e now be familiar

with the revolutionary HLB Blood Test which the BAI is advancing on

I a world scale. Sialic acid metabolism is a major regulating mechanism involved in ~irtually every system in lhe body. Sialic acid abnormalities appear in all degenerative disease states. and are implicit in the readings of the HLB Blood Test. We'll cover the

I subject ot sialic acid in a subsequent Science Corner. Not only is Dr. Pitard's lymphocytic lymphoma under control - or

cured - but butyric acid in high dosage levels (up to 10 grams per day with no trace of side effects) has been used successfully in

I breast. pancreatic and liver cancer as well. We can now confidently state that butyric acid (found in, other

things, cottage cheese, butler, Parmesan cheese and sunflower seeds). is a major adjunctive therapy in the treatment ot cancer and .

..

·ndeed. of degenerative disease in general. N TERMS of cancer cells, the literature shows that it:

Reduces contact inhibition. thus helping block the tendency toward metastasis.

I I I I

• Inhibits de-acetylation of histones and increases the half-lite ot unstable acetyl groups up to 150 times. both elements in "normalizing" cancer cells.

• Causes beneficial acetylation and inhibition ol DNA synthesis. thus inhib1llng cancer cell growth.

• Disperses abnormal lilaments found in hepatoma cells. helping them return to a normal state.

• Induces erythroteukemic cells to produce embryonic hemoglobin. an example ol dillerentiation or reverting of the cell back to a normal red blood cell.

• Causes Friend leukemic cells to differentiate (DMSO does this also). and decreases fluidity of Friend-leukemic cells. thus ··normalizing·· white blood ce_lls.

• Restores 1wo normal polypeptides that are known to be absent in cancer cells. thereby reducing 1umorgen1city.

In terms ol the all-important s1alic acid metabolism. butyric acid

I activates sialytransferase. a primary enzyme involved rn s1alic acid metabolism. and is this involved in auto-immune diseases as well as cancer.

I I

AMONG OTHER uselul actions. bulyric acid • Increases the number ol neurolransmiller recep101 sites. which

has implications in neurological dyslunct1ons. • Decreases inteslinal peristalsis. hence helping weight gain • Increases the release ol acetytchohne lrom nerve end1n9s.

' which has implications in Alzheimer's Disease. as well as some other neurological deliciencies.

• Inhibits oxynitrilase, which prevents the abnormal breakdown of amygdalin (laetrile, Vitamin 817) to hydrogen cyanide. and is thus key in amygdalin metabolism.

• Increases the production of interferon by human lymphoblasts and is thus anti-viral.

• Helps restore the insulin release in pancreatic beta cells. and thus has implications in diabetes.

• Increases prostaglandin synthesis. hence having more borad metabolic implications.

WITH ALL this, and much more. to recommend butyric acid. you might think it would be in general therapeutic use. But it isn·t Selected literature MINI-REVIEW: BUTYRIC ACID: Life Sciences 27 1351 (1980) DIFFERENT ACCESSIBILITIES IN CHROMATIN TO HISTONE ACETYLASE: J. Biol. Chem. 254-1716 (1979). STUDIES ON THE KINETICS OF CYNOHYTRIN SYNTHESIS AND CLEAVAGE BY THE FLAVOENZYME OXYNITRILASE: J. Biochimica et Biophysica Acta 613 203 (1980). AGGREGATES OF FILAMENTS IN CULTURED HEPATOMA CELLS AND THEIR DISPERSAL BY BUTYRATES: Experimental Cell Research 127-215 (1980). A detailed monograph on butyric acid is available from The Bradford Foundation, P.O. Box 1003, Los Altos, CA 94022 ($15).

NEXT ISSUE: Sialic acid, a major unsung body regulator.

'. . . ·, · .. ·. ) . .. . .•, ·.· . ; .. . . :·. ' . . . . . . . ' -~_ .. ..;.;·;:.·>.,--_

THEBRADFORO::~E_SEARCH _INS°JITUIE· .. :.

On the forefront of research and development in metabolic medicine.

Donations to the B.R.I. are tax-deductible.

BRADFORD RESEARCH INSTITUTE

1180 WALNUT AVENUE CHULA VISTA, CA 91911

(619) 429-8200

ID TO DEPO. OF/w.M.J?T -bi"tbFo.~

DATE .S- t,_q 2 v•-..~•••·

_ .. _,

Page 46: RHONA GILKEY AND JOHN GILKEY, I - quackwatch.org › wp-content › uploads › sites › 33 › quackwatc… · RHONA GILKEY AND JOHN GILKEY, . . PLAINTIFF, vs. ' NO. 698885 ' JACOB
Page 47: RHONA GILKEY AND JOHN GILKEY, I - quackwatch.org › wp-content › uploads › sites › 33 › quackwatc… · RHONA GILKEY AND JOHN GILKEY, . . PLAINTIFF, vs. ' NO. 698885 ' JACOB
Page 48: RHONA GILKEY AND JOHN GILKEY, I - quackwatch.org › wp-content › uploads › sites › 33 › quackwatc… · RHONA GILKEY AND JOHN GILKEY, . . PLAINTIFF, vs. ' NO. 698885 ' JACOB

I A ma;ur rtew V\lf::,UJIUI l

By OR. ROBERT W. BRADFORD President, Bradford Research Institute

I (Excerpted from, and in part serving as an addendum to, the monograph Exogenous Oxidative Mechanisms In Combating /nt.ctlous Agentll, a 1986 publication of the Bradford Research Institute, Chula Vista CA. Authors: R. W. Bradford, D.Sc.; Henry

I W. Allen; Michafi L. Culbert, D.Sc. Inquiries are invited at the B.R.I., 1180 Walnut Ave., Chula Vista CA 92011.)

Dioxychlor4, one of a dass of inorganic oxidants, has been found useful against the three major classes of infective agents - virus. I bacteria and fungi - and to have tremendous potential use in such refractory conditions as acquired immune deficiency syndrome (AIDS). It is also extremely effective against an impressive array

I of viral, bacterial and fungal infections, including demonstrated inhibition of Candida albicans.

University research has indicated the in vitro effectiveness of Dioxychlor4 - the premier inorganic oxidant - against the putative

I "AIDS virus" (HTLV-111/HIV), hepatitis-B, Epstein-Barr virus, cytomegalovirus, polio, and other viral strains. Ongoing in vivo research by the Mexican division of the Bradford Research Institute has confirmed substantial effectiveness against Candida, Epstein­Barr, and conditions related to AIDS and AIDS-Related Complex (ARC), Universal Reactor Syndrome (URS), and many lesser

nditions. At the same time. the use of Dioxychlor«> and the development of specialized microscopy have helped establish what we may call "the pleomorphic founda­tion of environmental illness." For it has been with the advent of the 7000X phase-contrast video-enhanced com­puterized imaging system that the sys­temic invasion of such substances as Candida, mycoplasmas, and pleo­morphic or "L-forms" (as observed in the blood) may be established. Such microscopy also prqvides a tool with which to observe the elimination of fungi and bacteria and - with confirma-

tory electron microscopy -the elimination of viruses. This new rnension in microscopic observation allows the detection of the

ailed "L-forms" (pleomorphic forms) which have long puzzled

nee. The explosive overgrowth of the latter in the body is now

I being recognized as a virtual market for allergies, sensitivities and immune depression.

Research on Dioxychlor4 and its effects is in alignment with the concept of oxidology - the study of reactive oxygen toxic species

I (ROTS) and their metabolism in health and disease - as enun­ciated by this Institute last year.• Such research also places Dioxychlor4 as the major oxidant. of demonstrated effectiveness

I I I I

superior to hydrogen peroxide and ozone. both of which - as indicated below - may be seen as double-edged-sword oxidative therapies.

Universal Reactor Syndrome

This Institute continues to find evidence that environmental disease - particularly the multiple-sensitivity condition generally denominated "universal reactor syndrome" (URS), almost always characterized by systemic Candida and multiple allergies and sen­sitivities with increasing autoimmune disorders - is to a large extent iatrogenic in nature.

Jhis is because one of the mechanisms that generate the so­called "L-forms" (pleomorphic forms) is the use of antibiotics, par­ticularly such broad-spectrum ones as tetracycline. so that the short-term relief of infection provided by such agents is countered

1·--.

by a possible long-term negative: that is, the antibiotics may not actually be killing the target bacteria but converting them to pleo­morphic forms which may not only be reactivated at a later date but continue to produce toxins and lead to URS. The conversion of bacteria to such L-forms may thus be providing relief of symptoms - but at the same time setting the stage for a later pathology.

Our continuing research indicates that there are two types of pleomorphic forms - reversible and irreversible. One of the primary mechanisms in activating reversible L-forms is the classic oxidative generation response, as in inflammation, antibody-antigen activity, the influenza viruses, and physical and psychological stress.

A classic example is the URS patient - an environmentally ill individual who may be sensitive to everything from hydrocarbons. pesticides and paint to a wide spectrum of foods. In reality these sensitivities are initiating systemic ROTS (''free radical'') substances which in turn activate pleornorphic forms and trigger a clinical crisis reaction which may be far more acute than the sensitivity which set it off.

..,.

~-::72-~~;, /!IDS' VIRUS DEMOLISHED-In vitro destruction of the puro­tive "AIDS virus" (HTLV-lll/HIV} by Dioxychlor4 as observed through the electron microscope. Above, cenrer. a clusrer of identi­fied virus, before the addition of Dioxychlor® .

The above problem is exacerbated by the toxins that are produced by pleomorphic forms. which in turn inhibit the "mixed­function oxidase system," an enzyme complex which is responsible for detoxifying environmental chemicals, be they organic or inorganic. II the mixed-function oxidase system is blocked or seriously impaired it leaves the body defenseless against such sub­stances as the environmental chemicals.••·"·"·"·"·,.

Indeed. a vicious cycle is set up along these lines: Step One: Long-term (or even high-concentration, short-term)

abuse of antibiotics, anticontraception pills. corticosteroids, "recrea­tional" drugs, metal toxicity, etc .. leads to a general lowering of

the immune system.PlrJ'' EXH c- / • V / FOR ID

TO DEPO. OF ~6WT p,~.r!fi?&0. ---OATE s--&-'1 7

Page 49: RHONA GILKEY AND JOHN GILKEY, I - quackwatch.org › wp-content › uploads › sites › 33 › quackwatc… · RHONA GILKEY AND JOHN GILKEY, . . PLAINTIFF, vs. ' NO. 698885 ' JACOB

I

DIOXYCHLOR body in counteracting these infectious agents which, if not adequately neu tralized, will ll'l6>sl certainly lead to disease.

Dioxychlor«' in pure form (anhydrous) is a liquid at 0°C. having a deep red color. When mixed with water and at high dilution it is colorless.•

Bohr atomic models indicate a "coordinate covalent" bond between the elements of Dioxychlor«'. This type of bond represents the sharing of a pair of electrons between two atoms as in the "covalent" bond, but in this bond both electrons are contributed by one of the atoms (chlorine) and none by the other. In the covalent bond one electron is contributed by each of the atoms forming the bond.

When Dioxychlor«' reacts as an oxidizing agent the oxygen atom first binds to a single atom (the one being oxidized) and then is dissociated I from chlorine. An electron is then given up to chlorine forming the chloride ion. When one realizes that there are 5.3 g. of chlorine ion per liter of human plasma it becomes obvious that the small amount of chloride generated through the use of Dioxychlor«' is negligible. I Other Cytotoxic Oxidizing Agents Used Cllnlcally

Dioxychlor«' is not the only oxidizing agent in clinical use. Another agent also providing active oxygen is hydrogen peroxide, which has been used i treatment of arthritis, cancer and other metabolic diseases. Hydrogen

xide is commercially available in low concentrations for the treatment pical microbial infections.

I one is being use~. both in Europe and at the American Biologics Hospital in Mexico to treat various diseases including cancer, blood coagu-lation disorders and liver diseases, among others.ru . .,

II is a developing precept of oxidology that the success of oxidative

I therapies depends on the type used, the concentration of the oxidant and the target of use. For example, hydrogen peroxide may be used effec­tively as an anti-viral sterilizing agent orally and topically, but if used intravenously, great caution should be exercised since, among other things,

I cancer cells produce prodigious quantities of hydrogen peroxide and the IV administration of this substance may induce cancer to proliferate. This is not true, for example, of either ozone or Dioxychlor«'.

Ozone is a power1ul oxidant which can be used effectively at the right I concentration, time and place - for example, as an intratumoral therapy in cane.Jr or in the ozonation of blood to oxidize it and destroy potentially harmf:il viruses. But any administrative route which increases oxidative pror-..esses in the lung is injurious and should be handled with great care:

the caveat on intravenous ozone administration. ychlor«' is currently used as a topical gel ("C2" - complexed with ers), or as homeopathic drops ("C3"), (!r as a cryogenically purified

I intravenous infusion material ("C4").

Cytotoxlclty of Dloxchlor

Proof that Dioxychlor«' is cytotoxic to bacteria, fungus and virus clinically

I is shown by data indicating its effectiveness as a disinfectant (outside the bod~ .

Dioxychlor«> has been found to inactivate the organism causing Legionnaire's Disease (Legionella pneumophila).••

I Th~ chemically related compound sodium periodate (NalOJ inhibited the virulence, decreased the respiration of and increased the sensitivity to phagocytosis of the common pathogen Listeria monocytogenes."

A germicidal solution has been developed containing Dioxychlor«' at an lacid pH (lactic acid). The solution gave complete kill of Staphylococcus aureus, Pseudomonas and Candida albicans spores within 10 minutes. If used in an uhrasound cleaning device complete killing occurred in less than five minutes." I The bacterial ~rus 12 was rapidly inactivated with Dioxychlor4'. At pH 5-9 only GMP (guanosine monophosph/ite) reacted while the amino acids cystine, tryptophan and tyrosine reacted rapidly.••

I Dioxych~or«' a_pplied to polio virus separated the RNA from the protein coat (capsid). D1oxychlor«-reacted with the capsid protein and prevented the adsorption, penetration and normal unc:oating of the virus. It also reacted

1---·•-•'"••··--

with the viral RNA and impaired the ability of the nucleic aC".id to act as a template for replication."

(NOTE: The Bradford Research Institute (BR/) will present a paper on the

pleomorphic foundation of hypersensitivities at the annual convention of

the American Academy of Medical Preventics AAMP Nov. 20-23 at the

Anaheim Marriott Hotel, Anaheim, CA.)

REFERENCES

1 . Oxidology: The Study of Reactive Oxygen Toxic Species (ROTS) and Their Melaboksm in Heatth and Oisease, Bradto,d. R. W., Allen, H. W. and Culbert, M. L. (1985) The Robert

W. Bradford Foundation, A TRUST, Los Altos, CA. 2. Kirk-Olhmer Encyclopedia ol Chemical Technology, 3rd ed., McGraw-Hm Book Co., New

Yo,k. "Chlo,ine Oxygen Acids and Satts." pg. 612. 3, Journal ol Apphed Bacteriology 54 417 (1983), Baldry, M. G. C., "The Bactericidal,

Fungicidal and Sporicidal Properties ol Hydrogen Peroxide and Peracetic Acid."

4. Nuovi Ann. lg. Mictobio. 34 63 (1983), Mastroeni, P. el al.. "Kinalics of the Antibacterial and Anlimycolic Activity ol an Antiseplic Solution on Oitterent Subslrales." Chem. Absls.

JOI 35812x (1984). 5. Science 209931 (1980), Swee\, F. el al., "Ozone Selectivily Inhibits the Growth of Human

Cancer Cells.·· • 6. Proceedings· Fo,um on Ozone Oisinfaction 1976 (publ. 1977), Fochlman, E.G., ed. Peleg.

M. el al •• "Chemical and Viricidal lnvesliQation ol the Ozonization ol WaSl-ater Systems." 7. Ertahrungsheilkunde 24 123 (1975), Wollt, H., "Normal Cases of Ozone Therapy." 8. ibid. 24 129 (1975), Viebahn, R., "Physicochemical BaSls ol Ozone Therapy.'"

9. ibid. 29 957 (1980), Kief, H .. "New Possibilities in Ozone Therapy.'' 10. Report 1984. EPA-600/0-84-005; Order No. P884-129360. Jwaijable NTIS. Berg, J. 0.,

et al., "Growth ol Legionella pneumophila in Continuous Cullure and hs Sensi1ivity to

Inactivation by Chlorine Oioxide.'' Chem. Absls. IOI 20407v (1984). 11. Dold. Bolg. Akad. Nauk32103 (1979), Velyanov, D. et al., "8iological Changes in LJSleria

Monocytoganes Aller Treatment with Some Chemical Substances." Chem. Absls. 91 14514m (1979).

12. German Patent 2,817,942, Oc!Ober 25, 1979, Alliger, H., "Germicidal Composition." 01etn. Absls. 92 (1980).

13. Water Chlorination: Environ. Impact Health Elf. 1983. 4 (Book 2) 1077, Noss, C. I. el al., "Reactivity ol Chlonne Otoxide with Nucleic Acids and Proteins." Chem. Absls. 98 212722k

(1983). 14. Applied Envirorvnenlal Mictolliology 44 1064 (1982), Alvarez. M. E. et al., "Mechanisms

of lnac:1iva11on ol PollOVirus by Chlo,ine Dioxide and Iodine." 15. Mrcrobial and Plant Protopfasts (Proc. Int. Symp. Yeast and other Protoplasts), 4th, 1975.

(Publ. 1976) Peberdy, J.E., ed., Academic Press, N.Y., p. 201. 16. Ann. Review Mrcrobiology 26 55 (1972), Cfasener, H., "Pathogenicity of the L•Phase of

Bac:leria." 17. The Mycoplasmatales and the L·Phase ol Bac:leria, Haytloc:11, L, ed. Appleton-Century-Crofts.

N.Y. 18. Cell Wall Deficient Forms (1974), Manrnan, L., CRC Press, Cleveland. 19. The Bacteria, a Treatise on Struclure and FuncllOn, vol. I, Gunsalus. I. C., al al., eds. (1972).

Academic Press, N.Y ., Chap 7. 20. Membranes and Transport, vol. I, 283 (1982), Razin, S., "lhe Call Membranes of

Mycoplasrnas.''

On the forefront of research and development In metabolic medicine.

Donations to the B.R.I. are tax-deductible.

• BRADFORD

RESEARCH INSTITUTE 1 i80 WALNUT AVENUE

CHULA VISTA. CA 91911 1619) 429-8200

S--=>