JACKSON V AEG July 2

nd
2013 Please support us to provide you future transcripts
Dr. Sidney Schnoll
(Expert in Pharmacology, Neurology, Psychiatry; Addiction Medicine Specialist)
Plaintiffs' Expert Witness.
Direct examination by Michael Koskoff:
Q. Dr. Schnoll, can you tell us where it is that you reside?
A. I reside? Westport, Connecticut.
Q. And where were you born?
A. Newark, New Jersey.
Q. Now, following your undergraduate education -- by the way, where did you go to college?

A. I went to college at union college in schenectady, New York.

Q. And following your graduation from college, did you go on to medical school?
A. Yes.
Q. Or to some other form of higher education?
A. I went -- I went to medical school.
Q. And what was the school you went to, sir?
A. I went to New Jersey College of Medicine and Dentistry, which is now the University of
Medicine and Dentistry of New Jersey.
Q. And did you graduate from that school in 1967?
A. Yes.
Q. And following graduation from medical school, did you get an M.D. degree then?
A. Yes.
Q. Okay. Did you further your education?
A. Yes.
Q. And what did you do after medical school?
A. I had a general medical internship at Jefferson Hospital in Philadelphia, and then did a
residency in Neurology at Jefferson Hospital.
Q. So you had -- first you had an area of -- an intern?
A. Yes.
Q. Is that right? And that was at -- you said Thomas Jefferson University Hospital in
Philadelphia?
A. Yes.
Q. And then you did a residency in Neurology. And can you tell the jury what Neurology is?
A. Neurology is the study of the nervous system.
Q. And was there any particular facet of it, or was that just a general Neurology residence?
A. It was just a general Neurology residency.

Q. And did that residency last for three years?

A. Yes.
Q. So that brought you to 1971, and now you've got your m.D., you've completed your
Neurology residency. And then after that, did you continue your education?
A. Yes.
Q. And what -- what did you do in furtherance of your education after your Neurology
residency?
A. I -- I went back to school and got a Ph.D. In Pharmacology, also at Jefferson, with a grant
-- a special fellowship grant from n.I.H. To do that work.
Q. A couple of terms, please. First of all, "Pharmacology." what is Pharmacology?
A. Pharmacology is the study of drugs.
Q. And is there any particular facet of the study of drugs that Pharmacology deals with?
A. Well, it deals broadly with all drugs, although you can specialize in -- in one area of
Pharmacology or another.
Q. And did you specialize in one area?
A. I mainly worked in drugs that affect the central nervous system, primarily drugs that people
can abuse.
Q. So -- and you got a ph.D. In this field of Pharmacology?
A. Yes.
Q. And did you, in the course of that residency, learn about various drugs that can affect
human beings and be abused?
A. Yes.
Q. When was it that you complete- -- I'm sorry. And that was -- you said it was a special grant
from N.I.M.H.
A. N.I.M.H., yes.
Q. What is N.I.M.H.?
A. The national institute of mental health. It's part of the national institutes of health.
Q. And what does it mean to get a special grant to do this?

A. Well, you have to -- you have to write a grant that you submit to the n.I.H. It is reviewed by
a committee of peers who then decide whether or not it should be funded. And so it's not
something that you just get automatically.
Q. So you had to apply for it and you got special funding to do this -- this program and
fellowship, special fellowship?
A. Yes. That was for my Ph.D. work.
Q. That was for your Ph.D. And then after that, did you get -- have any further fellowships?
A. Yes. I had what's called a career teacher fellowship, also from n.I.H. That was from
national institute on alcoholism and alcohol abuse, and that career teacher fellowship was to
study addiction further. The purpose of that particular fellowship was to try and get a faculty
member in every medical school in the country who had expertise in addiction.
Q. Why was it that the -- they were trying to get faculty members in every university to have
specialization in addiction?
A. Well, the feeling was that there weren't enough people who understood the problems of
addiction and how to treat it, how to diagnose it. And by getting a faculty member into the
medical school, then it was possible to teach medical students how to do this. But without a
trained faculty member, it would be very difficult to teach the medical students.
Q. Then after that second fellowship was completed, you had your m.D., you had your ph.D.,
you had two fellowships, time to get a job?
A. Well, yes. Those fellowships did not pay very well.
Q. And did you then go on to -- what did you do after completing those fellowships?
A. I became medical director at a hospital that specialized in the treatment of addictive
diseases.
Q. And what was that hospital?
A. Eagleville hospital and rehabilitation center.
Q. And what -- what kinds of patients did you -- you said you became medical director of the
hospital?
A. Yes.
Q. And what kinds of patients did they take at Eagleville?
A. Eagleville took all kinds of patients. A -- a large number of the patients we treated were
people who came directly from the prison or were placed there by the courts.
Q. And are these people who had addiction disorders?

A. Yes.
Q. And what kinds of drugs did they have addiction -- were they addicted to?
A. I guess probably 40 to 50 percent of the people had alcohol problems. There was -- the
rest had various drugs; cocaine, heroin, benzodiazepines. I mean, just about everything, we
saw there.
Q. We've heard a little bit about benzodiazepines in the trial so far, and I think the jury
probably all knows now about lorazepam and midazolam and diazepam and all those. But
what, generally, do these drugs do?
A. The benzodiazepines are sedatives, they calm down the central nervous system. Also,
they treat seizure disorders. They're used to help people to sleep. Those are the main -- main
uses of the benzodiazepines.
Q. And are these drugs that are in common usage throughout society?
A. Yes, yes, they're very --
Q one of the most commonly used kind of pharmaceuticals?
A. They're very widely prescribed drugs, yes.
Q. And can people become addicted to them?
A. Yes.
Q. And can people become dependent on them?
A. Yes.
Q. We're going to talk about these two words in a few minutes, but -- now, in addition -- after
eagle --
A. Eagleville.
Q. -- Eagleville -- how long did you remain at Eagleville, approximately?
A. I was there for four years.
Q. And then what did you do?
A. Then I accepted a faculty position at Northwestern University Medical School.
Q. And so -- and what was that faculty position you took at northwestern at that time?
A. I was an associate professor of Psychiatry, and later got a joint appointment in the

department of Pharmacology.
Q. Okay. Now, you are not a psychiatrist; is that correct?
A. That is correct.
Q. But you can teach in -- in the school of Psychiatry?
A. In the department. It's a department within the medical school.
Q. And, also, by the way, did you work as a medical director in the health free clinic in
philadelphia?
A. Yes. That was before I went to Chicago.
Q. Okay. And you were medical director there?
A. Yes.
Q. What was the health -- what is the health free clinic?
A. It was a free medical clinic in the central part of Philadelphia that treated people with drug
and alcohol problems. But it -- the whole purpose was to provide free care.
Q. Did you get paid for that position?
A. No.
Q. And were you there for 11 years as Medical Director?
A. Yes.
Q. Did you also work with the -- at the Wilmington Veterans Administration Hospital?
A. Yes.
Q. What did you do there?
A. I was one of the Neurology attendings there, and also ran their drug abuse program.
Q. And did the -- did you also have a teaching appointment at the University of
Pennsylvania?
A. Yes, when I was in my career teacher fellowship, the one I mentioned after the first
fellowship, that's when I had an appointment assistant professor at the university of
pennsylvania medical school.
Q. And was that in the field of Pharmacology?

A. Well, I had an appointment in Pharmacology; I also had an appointment in the department

of Psychiatry.
Q. Now, have you also served at -- had a professorship at Thomas Jefferson Hospital in
Philadelphia?
A. Yes.
Q. And what -- what fields was that in? Were they -- what fields -- you know what I mean?
A it was Psychiatry.
Q. In what fields?
A. It was in Psychiatry.
Q. In Psychiatry. Okay. The -- I see on your C.V. That you're listed as Co-chief, chemical
dependence program at the Institute of Psychiatry at Northwestern Memorial.
A. Yes. When I first went to Northwestern, there was another person there who was senior
who had been head of that program for many years, and I was brought in as he was retiring to
replace him. And so he remained a few years, and then I took over the program.
Q. And then following Northwestern, where did you go?
A. After Northwestern, I went to the Medical College of Virginia in Richmond, Virginia, which
is part of Virginia commonwealth university.
Q. And what positions have you held at Medical Mollege of Virginia?
A. At medical college of Virginia, I was professor of internal medicine, professor of Psychiatry,
Professor of Pharmacology and Psychology.
Q. And these are all professorships?
A. Yes.
Q. Now, you have said you were a professor in the field of internal medicine. Are you certified
an internist?
A. No, I'm not.
Q. How does it work out that you, as a -- as a pharmacologist, Ph.D. In Pharmacology and
addiction specialist, teach in the field of -- in the internal medicine school?
A. Well, it turned out that at the Medical College of Virginia, the substance abuse programs
were in the Department of Internal Medicine; so as director of the program, I had my primary
appointment in the Department of Internal Medicine.

Q. And you also had an appointment, you said, in Psychiatry. Did you teach psychiatrists
about --
A. Yes.
Q. -- drug abuse, as well?
A. Yes.
Q. And did you remain at the University of Virginia Medical College?
A. As the faculty there would say, it's not the University of Virginia, it's Virginia commonwealth
university. We're the ones who went to the basketball semifinals a couple of years ago. So
differentiate.
Q. Important point.
A. Yes.
Q. And did you remain there for some period of time?
A. Yes. I was there almost 15 years.
Q. And then after that, where did you go?
A. After that, I took a position at Purdue Pharma.
Q. And that's what brought you to Connecticut, is Purdue Pharma of Connecticut
corporation?
A. Purdue Pharma is in Stanford, Connecticut; and that's what brought me to Connecticut.
Q. And at Purdue Pharma, what was your position there?
A. My job there was to develop the risk management program for one of their drugs because
of problems of abuse with the drug.
Q. Had there been problems related to one of their drugs that they asked you to come in and
work on?
A. Yes. They asked me to come in and develop the program to try to understand more the
problems with abuse, how to address them. That's what a risk management program does.
Q. And then did there come a time when you left there?
A. Yes. I was there four years, and then I left Purdue Pharma.
Q. And where did you go after Purdue Pharma?

A. I took a position with Penny Associates.

Q. Now, would you tell the jury a little bit about penny associates? What kind of an
organization it is, and what kind of clients you have, and what its reputation and status is in
the community?
A. Yes. Penny Associates is a small consulting firm. It's -- we call ourselves a science-based
public health consulting firm, and we're -- we consist of about 25 full-time staff with five pretty
much almost full-time consultants who work with us. And we work primarily with
pharmaceutical companies to help them do abuse liability studies of their drugs, to help them
develop the drug, develop clinical protocols, to study their drugs and to -- to design and
implement risk management programs for them.
Q. And are these programs that you work with -- do they specifically address the addiction
potential of these drugs?
A. Yes, that's the primary reason that we are often called in to look at the drug, will the drug
be -- have abuse potential, what's the level of that, how to address that most effectively.
Q. And does it become -- do you become involved in deciding on the risks that are
associated with the drug?
A. Yes.
Q. And do you investigate treatment methods for those who become dependent or addicted
to the drugs?
A. We look at how to most effectively address the problems when people become addicted,
and advise the companies on those issues.
Q. Now, I think one thing I haven't asked you about so far is your work treating patients. And
for how many years did you treat patients
For drug-related addiction problems?
A. Probably starting shortly after I graduated from medical school, I started to work in a free
clinic. And that particular clinic was a place where people would come who were trying to get
into a methadone program. It was at the very early days of methadone treatment. And we
would do the histories and physicals on those people. So really from shortly after the time I
graduated from medical school up until 2001 when I went to Purdue Pharma, I was treating
patients consistently.
Q. And you graduated medical school -- I think you said '67?
A. Yes.
Q. '77, '87, '97, 2- -- it was about 34 years you were treating patients?
A. Yes.

Q. And can you say approximately how many patients' lives you intersected with over those
34 --
A. Over that time, probably tens of thousands of patients I've seen.
Q. Did you become familiar with the methods in treating drug addiction?
A. Yes.
Q. And with the diagnosis of drug addiction?
A. Yes.
Q. Now, in addition to the various faculty positions and educational backgrounds that you
have, do you -- have you also had occasion to consult for various entities, private entities,
outside of the university setting?
A. Yes.
Q. Okay. The -- have you served as a consultant to the national football league association?
A. Yes.
Q. Have you served -- now, there's a -- there's a --
A. It's the national football players Association.
Q. National Football Players Association?
A. Yes.
Q. They're the ones who hired you?
A. Yes.
Q. Okay. And have you also -- I'm going to ask you a little bit more about this later, but
worked with a group called -- let me see if I can get the title right -- the Chicago National
League Franchise? Is that the right title for the group I'm referring to?
A. That's the right title, but it's more commonly known as the Chicago Cubs.
Q. The Chicago Cubs?
A yes. But that's not its official name.
Q. Its official name is Chicago National Franchise whatever?
A. Yeah.

Q. I'm going to ask you a little bit more about that a little later. And have you also had
occasion to publish in the learned journals concerning addiction over the years?
A. Yes.
Q. And I'm certainly not going to read all your publications, but have you served on editorial
boards for many publications?
A. Yes.
Q. Have you had -- have you served as an editor for the Journal of Addiction Medicine?
A. Yes.
Q. The Journal of Maintenance in Addiction?
A. Yes.
Q. The American Journal of Drug and Alcohol Abuse?
A. Yes.
Q. The Addiction Medicine Education Series?
A. Yes.
Q. The Journal of Addicted Diseases?
A. Yes.
Q. The Journal of Psychoactive Drugs?
A. Yes.
Q. Substance abuse -- a journal called "Substance Abuse"?
A. Yes.
Q. And "Medical Monograph Series and Contemporary Drug Problems." Are those all
publications that you have been -- served as an editor for?
A. Those are all publications for which I've served on the editorial board, yes.
Q. And have you also published 116 articles now in various learned journals?
A. Yes, those are the articles I've published in peer-reviewed journals.
Q. Peer-reviewed journals. And do those include the Journal of the American Medical
Association?

A. Yes.
Q. And Archives of Internal Medicine?
A. Yes.
Q. And the New England Journal of Medicine?
A. Yes.
Q. And have you also written chapters in textbooks?
A. Yes.
Q. Do you know approximately how many?
A. About 40 some odd chapters at this point.
Q. And is that all in the field of addiction?
A. Not all, but the overwhelming majority is in the field of addiction.
Q. What other areas do you go into where it's not completely addiction? Is it Pharmacology?
A. Well, the first few publications I had while I was a medical student were in immunology. I
was studying with a very famous biochemist who discovered the Rheumatoid factor, so --
Q. Discovered the Rheumatoid factor?
A. Yes.
Q. And so you thought you might go into that area, and then you decided to go into addiction
medicine?
A. Yes.
Q. Have you -- and you have chapters now that are waiting for publication?
A. Yes, there are two chapters that are waiting for publication.
Q. And are these in the field of addiction medicine?
A. Yes.
Q. Now, in the course of your work -- by the way, and you stopped seeing patients when?
Approximately when?
A. 2001.

Q. And that's when you went to --

A. Purdue Pharma.
Q. -- to Purdue Pharma. Okay. And since that time, have you -- you have not seen patients,
and you're not in active medical practice, is that --
A. That's correct.
Q. Now, have you also had occasion to serve as a medical coordinator for various music
groups?
A. Yes.
Q. And in what capacity have you done that?
A. In the 1970's, I set up the medical facilities at large outdoor concerts where people would
come and spend time, and I provided the medical care for them.
Q. And did you do that for Fleetwood Mac?
A. Yes.
Q. And the Rolling Stones?
A. Yes.
Q. Did you do it for Philadelphia Folk Festival?
A. Yes.
Q. Ann arbor Blues Festival?
A. Yes.
Q. And the Kickaboo Creek Rock Festival?
A. Yes.
Q. And why is it that you would have facilities for drug-related things at a rock concert, of all
places?
A. Well, there would be people who use drugs at a rock concert; but we also provided
general medical care in addition to what -- what would happen at the -- people were outside,
they would be walking around barefoot, cut their feet, get sunburned. There were many things
that happened.
Q. Now, what is addiction medicine?

A. Addiction medicine is the study of the problems of addiction.

Q. And does it encompass -- what -- with your backgrounds in Pharmacology and in
Neurology, what -- what -- what kinds of things do you look at as a -- as an addiction medicine
specialist?
A. Well, you know, I used to teach my students that many years ago, it used to be said if you
knew tuberculosis, you knew medicine. I think today, if you know addiction medicine, you
know medicine because it encompasses so many areas of healthcare and medicine because
of all the complications that can be associated with addiction. So it's a very broad, broad area.
Q. So do you have to know medicine to know addiction medicine?
A. Yes.
Q. And a certain amount of this study of the brain and Neurology?
A. Neurology, Psychiatry.
Q. And with your background in Pharmacology, does that involve also knowing something
about chemistry?
A. The chemistry of the brain, the chemical effects of the drugs on the brain, yes.
Q. And as a part of your work now with penny associates, are you required to remain abreast
of the world's literature on an ongoing basis as it relates to addiction?
A. Yes.
Q. And how do you -- by the way, I want to ask you something. Penny associates, as you
said, is a consulting firm that consults with the pharmaceutical industry. Does it get involved
usually in having witnesses appear in lawsuits?
A. No. It -- it does sometimes, we're invited. I think our company was very involved in the
tobacco industry lawsuits. And one of the things we're most proud of is we were the company
that helped bring nicotine replacement products over the counter.
Q. And did -- and have you in the past ten years -- how many times have you testified in
court?
A. None.
Q. So this is your first time in about ten years. 15 years, how about that?
A. Probably close to 15 years since I've testified in court.
Q. So since you've really been in penny associates, you really haven't had occasion to

testify?
A. That's correct.
Q. Now, one of the things that we discussed a little bit earlier is that you did have an occasion
to work for this national league franchise the chicago cubs. And tell me a little bit about why it
is, what brought you to work for the chicago cubs. What -- and when was it, approximately?
A. That, I think started in 1982. And that was at a time when major league baseball was
becoming quite concerned about drug use in baseball players, and they sent out a memo to
every team requesting that each team have somebody on board to address issues of drug
abuse in the baseball players.
Q. And when you got to the Chicago Cubs, can you tell us in terms of drug abuse what kind
of a condition was it that you saw there?
A. Well, I was -- I was actually quite concerned my first day that I arrived there. I went into the
training room where the players go to get rubdowns, take care of any problems they have,
and right on the counter in the training room was a bottle of amphetamine pills which the
ballplayers called greenies because they were green in color. And it was right there for the
players to take at any time they wanted it. And, also, they had a beer tap right in the
clubhouse, so the players could just go in and pull the lever and get their beer.
Q. I can swear I just saw Mr. Panish signal that what's wrong with that, but I'm sure he didn't
say that. So was there something that concerned you when you arrived as an addiction
specialist?
Ms. Cahan: Objection; relevance.
Judge: Overruled.
A I was -- I was quite concerned and said that if I'm going to be an addiction specialist with
you and treat these problems, that was inappropriate to have available.
Q. And did a drug-monitoring -- did you start a drug-monitoring and testing program at that
point?
A. Yes.
Q. And can you tell me what was the -- what happened with that drug-monitoring and testing
program? Was that later --
A. Well, that was --
Q. What was the destiny of that program?
A. Well, that became the model program for Major League Baseball at that time.

Q. Doctor, have you also consulted for the Chicago Bulls?

A. Yes.
Q. Now -- and then lastly, you consulted for -- for us, our legal -- the lawyers representing
Mrs. Jackson and her family --
A. Yes.
Q. -- is that right? And when we got to you -- do you know how we got to you?
A. The way I understand it, you contacted Penny Associates, particularly one of my
colleagues, Dr. Henningfield. And when the situation was explained to him, he said that he
didn't feel he was the appropriate person, and that I would probably be the appropriate
person.
Q. And then we gave you a large number of records to review?
Ms. Cahan: Objection; leading.
Q. Did we give you records to review?
A. Yes.
Q. And did you review medical records?
A. Yes.
Q. Did you review depositions?
A. Yes.
Q. Did you review transcripts?
A. Yes.
Q. And how many -- and -- and then you had your deposition taken at one point; is that right?
A. Yes.
Q. And following that, have you continued to review materials?
A. Yes.
Q. By the way, in the course of your review, did you have occasion to review testimony by a

Dr. Earley?
A. Dr. Hurly? That name is not familiar.
Q. Paul Earley?
A. Oh, Earley. I thought you said hurly. I'm sorry.
Q. No, no. Earley.
A. I misunderstood you. I'm sorry.
Q. Yes.
A. No. I -- yes, I -- I reviewed Dr. Earley's, but that -- I didn't know a Dr. Hurly. I'm sorry.
Q. Okay. And you know -- you know who Dr. Earley is, as well, right?
A. Yes, I know him.
Q. You've served on committees with him?
A. Yes.
Q. And did you review testimony by a Dr. Levounis?
A. Yes.
Q. And did you also review all of the documents that they reviewed?
A. Yes.

Ms. Cahan: Objection; calls for speculation.
Mr. Koskoff: It's not speculation. They have been listed, the documents were attached
to the deposition.
Ms. Cahan: The documents that they relied upon were identified at their depositions;
but not everything they reviewed, your honor, so this necessarily calls for speculation.
Mr. Koskoff: I will amend the question.
Q. Did you review all of the documents they relied upon as stated in the list attached to their
deposition?
A yes.

Q. And do you -- now, we have been -- I think we've used the term "addiction" in sort of a
broad sense to refer to people who have drug problems. Can you tell me what -- from a point
of view of a -- of a specialist in the field of addiction medicine, is there any distinction between
the words "addiction" and "dependence"?
A. Yes.
Q. Okay. So first let's talk about what is drug dependence?
A. Drug dependence is the pharmacologic effect of a drug to the point where if you take it
continuously and suddenly stop taking it, you will go through a withdrawal syndrome. And in
addition, if you continue to take it, you will develop tolerance to some of the effects of the
drug.
Q. So let me first ask you about the word "tolerance." what is tolerance to a drug?
A. Tolerance is the need to take more of the drug in order to get the desired effect of the
drug.
Q. And when you said -- and so is tolerance, then, one of the factors that enters into drug
dependence?
A. Yes. Tolerance and withdrawal are the two key factors in drug dependence.
Q. And what is withdrawal? What does that refer to?
A. Withdrawal, when you take certain drugs, if you suddenly stop the drug, you go through a
characteristic withdrawal syndrome, which is some symptoms that usually are opposite of the
effect of the drug. So an example. Opioids normally cause constipation; so when somebody
goes into withdrawal, they'll have diarrhea. So that's an example.
Q. So the withdrawal tends to be the opposite of the effect that the drug has, then?
A. That's -- that's typically. It's not 100 percent, but that's typically what happens.
Q. And for how long -- question withdrawn. Can you tell me whether or not people who are
undergoing treatment, proper treatment, can become drug dependent?
A. Yes.
Q. And is that something that has -- that you have -- that is commonly experienced?
A. Yes.
Q. For how long can a person remain drug-dependent under the care of a physician and
function normally?
A. They could maintain that for the remainder of their life if they needed the medication and it
was properly prescribed to them.

Q. And on some occasions, do people become drug-dependent and not function normally?
A. Yes.
Q. And what -- what causes that?
A. Well, that can be prescribing too much to the individual. Sometimes prescribing too little
can cause that, also.
Q. And even -- we're still talking just about dependence, not addiction. But even if a person is
not a drug addict, can withdrawal from drugs sometimes be difficult?
A. Yes.
Q. Can it -- does it require any special expertise to -- to manage that?
A. Yes.
Q. And does it require any particular work on behalf of the person undergoing withdrawal to
get out of the dependence sometimes?
Ms. Cahan: Objection; vague.
Judge: It is a little vague. What do you mean, "work"?
Mr. Koskoff: Yeah.
Q. What is required, if anything, about the person who is undergoing withdrawal? What kind
of a commitment do they have to make?
Judge: To what?
Mr. Koskoff: To get through a withdrawal.
The witness: They have to be willing to come off of the drug in order to go through the
withdrawal.
Q. And can that -- is that something that happens in a very short time or can it take a long
time?
A. It depends on the drug, it depends on the amount of time the person has taken the drug,
and it depends on the individual characteristics of that person. So there are a number of
factors that are involved in doing this, so I -- it's not everybody does it in three days or five
days. It's a very individualized kind of thing.

Q. And are there people who have a specialty in helping people through withdrawal?
A. Well, addiction specialists, the people in addiction medicine, are hopefully all trained in
doing that properly.
Q. Now, we've talked a little bit about dependency. Now, what is addiction?
A. Addiction is a chronic disease that's characterized by craving, compulsive use of a drug,
continued use despite evidence of harm.
Q. And what is the -- do the people who are addicted take a drug for a purpose other than
relief of their symptoms?
A. Well, they might take the drug for relief of withdrawal; but they're not taking the drug for,
say, relief of pain or relief of some other underlying disorder that is being appropriately treated
by that drug.
Q. And is there often -- what types of behaviors are associated with addiction?
Ms. Cahan: Objection; vague.
Judge: What kind of behaviors?
Mr. Koskoff: Yes.
Judge: Overruled.
A. Well, people will display what we call drug-seeking behavior. They will try to get the drug at
any cost, so they may go to people on the street to buy the drug, they may commit crimes in
order to get the money to purchase the drug. They will -- as I mentioned, the continued use of
the drug leads to problems so that they may ignore family, jobs, schoolwork, things of that sort
in order to continue to take and use the drugs.
Q. And is there a stigma associated with this sort of behavior?
A. Unfortunately, society has created stigma for that, yes.
Q. And can you tell me whether or not addiction is considered a disease?
A. Yes, it is.
Q. If it's a disease, what is the primary factor that causes the disease, or that leads to the
disease?
A. Well, the primary factor is usually genetics.

Q. In order to label someone an addict, to characterize them, or -- as an addict, what kind of

evidence would you, as an addiction specialist, need to see to determine that the person was
an addict?
A. I would have to see behaviors that showed me that they had this craving for the drug; that
they were using the drug in a compulsive way; that they were giving up normal things that
they would do in order to get the drug. These are things that I would want to see in an
individual who I would then give the diagnosis of addiction.
Q. Do the -- do addicts take drugs to get high?
A. Yes.
Q. And do they often engage in criminal behavior?
A. Yes.
Q. Now, you said that there is something which you called drug-seeking behavior. What --
what is that?
A. Well, that's when somebody makes an effort to get a specific drug or set of drugs, so they
are seeking that drug out. And there could be two factors associated with that. One, if a
person is an addict, they're seeking the drug in order to address their needs as an addict to
get high, to address the craving and compulsive use of the drug. And there also may be
somebody, as I mentioned earlier, who's inappropriately treated and not getting enough drug,
let's say, to treat pain, who may also be seeking that drug in order to get appropriate
treatment for their pain.
Q. So would you say that there are two types of people who may be looking for a drug?
A. Yes.
Q. Again, just outline for the jury what those sort of two types of people looking for a drug are.
A. Well, as I said, you have one, the person who's exhibiting addictive behaviors in relation to
the drug, and the other is a person who is seeking the drug to treat an underlying medical
condition that is not being appropriately treated for whatever reason.
Q. And is there a difference, then, between a person who can be drug dependent looking for
drugs and a person who is addicted looking for drugs?
A. Yes.
Q. Now, I'm going to go into this a little bit more; but how do you determine, as an addiction
specialist, whether a person is drug dependent looking for drugs and a person is an addict
looking to get high?
A. That can often take some time and effort to do; but what you try to do is look at that

person's behaviors around the use of that drug, how do they deal with the drug. For instance,
if you reviewed the drug -- using pain as an example, if you prescribe the drug for pain,
usually what we do is look at a zero to ten scale, zero being the absence of pain, ten being
the most severe pain the person can imagine. So what you do is you titrate the drug to the
level that that person says, "I'm now getting relief."
Q. What's the word titrate mean?
A. Titrate means adjust the dose of the drug to get the appropriate level needed for that
person.
Q. Okay. Now, that -- that -- now, how do you -- so that's -- now you're talking about what you
do to treat a patient; is that right?
A. Well, but this is -- say a person comes to me and they are -- somebody says, well, this
person is in pain, I think they're abusing their drugs, they're an addict. Let me, maybe, step
back and give a simpler example. This is actually a case that I had of a young woman who
was sent to me who had severe headaches. And she kept on asking her physicians for more
and more pain medication; and they said, "This is too much. She's an addict, she's abusing
these medications." well, when she came to me, I took her off of all of her medication and I
had her fill out a pain diary where she kept track of every day exactly when she felt the pain,
when she didn't feel the pain. Also, what she was doing. Was she working? Was she eating?
Was she sleeping? All of the things she was doing. And when I looked at her pain diary,
something jumped right out at me. And what jumped out at me was, one, she always had her
headaches at about 4:00 o'clock every day, except weekends. The other thing I noticed when
I carefully looked at her pain diary, she never ate lunch when she was at work during the
week, but she ate lunch on weekends. And so I said to her, "I think your headaches are due to
hypoglycemia, low blood sugar, that's causing your headache." and she said, "No, that's --
that can't be it." and so I said, "Let's do a glucose tolerance test; and I want you, as the test is
going on, to say whether or not you have a headache." and in a glucose tolerance test, the
blood sugar goes up, and then it goes down, and her headaches came on as the blood sugar
went down. The solution to her headaches was to eat three meals a day, and she had no
more headaches and didn't need any more drugs.
Q. She didn't ask for narcotic drugs any more?
A. No, no. She needed no more narcotics after that. Her pain was appropriately treated. And
so that's what I'm saying. You -- often it takes time and effort to determine what the underlying
cause of a person's pain mror whatever symptoms they're having, sleep disorders or
whatever, in order to get the proper treatment for that person.
Judge: Why don't we stop right here. Okay. I'm going to ask the ladies and gentlemen of the
jury to return at 10:00 o'clock tomorrow morning. Okay. Thank you. Goodnight. And you, too.
10:00 o'clock for you.
The witness: I'll be here.

(the following proceedings were held in open court, outside the presence of the
jurors):
Judge: Okay. Is Dr. Schnoll going all day tomorrow, or do you have somebody else?
Mr. Panish: I would think it's a safe assumption that he'll be for the day, he'll take up the day.
Mr. Koskoff: We are going to try to finish him tomorrow.
Judge: Is that right?
Ms. Cahan: Probably.
Judge: I just want to know so if there's somebody else, I can -- then I'll be prepared. All right.
See you tomorrow at 10:00.
Ms. Cahan: Thank you, your honor.
Court adjourned