Politics and Medicine - Device-Maker Medtronic Weighed Down With Lawsuits

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Device-Maker Medtronic Weighed Down With Lawsuits

Ilena Rose

2006-09-19, 9:33 pm

On July 31, 2006, Jacqueline Kay Poteet, a whistleblower in a lawsuit
against the giant medical device maker, Medtronic, filed a motion in a
Memphis federal court to oppose the US Justice Department’s plan to
settle her case, along with another whistleblower's case, for $40
million.

Critics point out that the identity of the other whistleblower remains
a secret and question why it has never been made public.

Ms Poteet's motion alleges that “this case has not been adequately
investigated” by the government, and that the $40 million amount is
“woefully inadequate.”

Her attorney, Andrew Carr Jr, also claims that one of the lawyers
involved in the case from the DOJ, had an undisclosed relationship
with an attorney for one of the defendants.

On July 18, 2006, the Medtronic announced that it had reached a
settlement agreement with the DOJ which requires the government to
seek dismissal of the two qui tam civil suits. And on July 19, 2006,
the DOJ issued a press release announcing the settlement in which the
company agreed to pay $40 million to settle charges that it paid
kickbacks to doctors to increase the sales of its products.

Medtronic was also required to sign a 5-year corporate integrity
agreement which requires the company to file regular reports with the
Inspector General and track all non-sales related customer
transactions. The company must also set up an outside review
organization, improve training and employee screening practices, and
make a compliance officer a member of senior management who will
report directly to the chief executive and have access to the
company's board of directors

In discussing the terms of the settlement, the Assistant Attorney
General for the Civil Division of the DOJ, Peter Keisler, stated in
the press release, "Today’s settlement reflects the progress we are
making in the ongoing fight against abusive and illegal practices in
the healthcare industry.”

“Kickbacks to physicians are incompatible with a properly functioning
health care system," he wrote. “They corrupt physicians’ medical
judgment and they cause overutilization and misallocation of vital
health care resources."

The $40 million settlement agreement comes on the heels of a $1.35
billion settlement in 2005, to settle charges in a patent infringement
action filed by Dr Gary Michelson, a Los Angeles inventor and surgeon.
According to Medtronic's latest SEC filings, the company first became
aware of the DOJ's investigation on September 4, 2003, when it was
informed that the government was investigating allegations that
certain payments and other services provided to physicians constituted
improper inducements under the Anti-Kickback Statute. The allegations
were made as part of a civil qui tam complaint brought pursuant to the
federal False Claims Act.

A year later, on September 2, 2004, Medtronic received a copy of Ms
Poteet's qui tam complaint asserting similar allegations under the
FCA. "The Company," the SEC filing states, "views the second complaint
as having arisen out of essentially similar facts and circumstances as
the first qui tam complaint."

The lawsuit allege that Medtronic violated the Anti-Kickback Statute
between 1998 and 2003, by paying kickbacks through sham consulting and
royalty agreements and sponsoring all-expense-paid trips for doctors
to exotic locations.

Ms Poteet now contends that the government's motion to dismiss her
lawsuit is an attempt to keep the terms of the settlement secret and
to avoid having to pay her or any other whistleblower a percentage of
the settlement, in the case titled United States of America, ex rel
Jacqueline Kay Poteet v Medtronic, Inc, No 03-2979, WD Tenn, W Div.

Her lawsuit charges Medtronic with violating the FCA which prohibits
the submission of false claims to the federal government, and imposes
liability on any person who "knowingly presents, or causes to be
presented, ... a false or fraudulent claim for payment or approval,"
or who "knowingly makes, uses, or causes to be made or used, a false
record or statements to get a false or fraudulent claim paid or
approved by the Government."

The fundamental element of a FCA violation, is the existence of an
actual false claim that has been presented to the government. The FCA
authorizes private individuals to bring qui tam actions on behalf of
the US government.

FCA recoveries over the past two decades total more than $17 billion,
with most of that amount coming from the pharmaceutical industry,
according to the Washington DC based policy group, Taxpayers Against
Fraud.

If a qui tam lawsuit is successful, under the FCA, the private
plaintiff is entitled to a percentage of any financial award and, in
some cases, to reimbursement for expenses and attorneys' fees.

The basic policy underlying the qui tam provisions is based on what
Congress perceived to be a necessity for enlisting private individuals
to assist in discovering and prosecuting frauds against the government
and encouraging private citizens to come forward.

In 1986, Congress set out to encourage more private actions. To that
end, through 1986 amendments to the FCA, Congress increased financial
awards to plaintiffs, lowered a plaintiff's burden of proof, and
allowed a private plaintiff to participate in actions in which the
government chooses to intervene.

Under the rules of the FCA, the private plaintiff must serve a copy of
the complaint and disclose all evidence in the plaintiff's possession
to the federal government. The government then investigates the claim
and decides whether to intervene and prosecute the case. If the
government chooses not to intervene, the private plaintiff still has
the right to prosecute the action on behalf of the government.

With the 1986 amendments, Congress attempted to strike a balance
between encouraging private individuals to disclose information and
prohibiting "parasitic" actions where an opportunistic plaintiff takes
advantage of information already in the public domain.

However, qui tam actions that contain similar allegations, or even
identical allegations to publicly disclosed information are not
necessarily parasitic. Actions are parasitic only when the plaintiff's
allegations are actually derived from the public disclosure.

In the amendments, Congress also repealed the limitation which barred
all lawsuits based on information already in the government's
possession, noting that simply because the government possesses
information regarding fraud does not mean that the government is in a
position to prosecute those claims. When enacting the amendments,
Congress affirmatively determined information "that the government
'has,' but that was never publicly disclosed does not bar a qui tam
suit."

The text of the FCA requires only that an original source: (1) have
independent knowledge of the fraud alleged in the complaint; (2) have
direct knowledge of that fraud; and (3) have disclosed his information
to the government before filing suit.

Under the FCA, an original source is defined as "an individual who has
direct and independent knowledge of the information on which the
allegations are based and has voluntarily provided the information to
the Government before filing an action under this section which is
based on the information."

A plaintiff's knowledge is considered "direct" when the plaintiff
acquires it through the plaintiff's own efforts without an intervening
agency, and "independent" if it is not dependent upon information
contained in any public disclosures.

Experts say the traditional "original source" is an inside
whistleblower, whose knowledge derives from his or her own
investigation conducted prior to any public disclosure of information.

In this case, Ms Poteet qualifies as an original source because
through her position at Medtronic, she personally uncovered evidence
of unlawful conduct and presented it with her complaint, and
therefore, her knowledge is both direct and independent.

According to the lawsuit, Ms Poteet, was a former senior manager of
travel services for Medtronic until 2003, responsible for setting up
travel arrangements for doctors to attend conferences, and is familiar
with the efforts to curry favor with the doctors.

In an amended complaint, Ms Poteet, alleges the company continued to
make the improper payments to doctors in 2004 and 2005, leading them
to perform unnecessary spinal surgeries.

She charges that any changes made in scaling back payments to doctors
were temporary. Its "bribery program," she alleges, "has not only
failed to cease, but continues unabated with increased payments made
to many physicians."

She points out that although some payments to doctors were lowered in
2004, when the investigation began, the payments went back up in 2005.
For instance, in 2003, Dr Hallett Mathews, was paid $300,000 in
consulting fees, but in 2004, he was only paid $75,000. But then the
next year, in the first 9 months of 2005, he was paid nearly $700,000
in consulting fees.

Her lawsuit alleges that Medtronic paid doctors at least $50 million
in kickbacks over a 4-year period. Internal company documents filed
with the lawsuit, provide indepth details of the company's campaign to
influence doctors. Wisconsin physician, Dr Thomas Zdeblick, listed as
a defendant in the action, in 1998 signed a 10-year $400,000
consultant contract with Medtronic that only required him to "consult"
for eight days each year.

The complaint alleges that Medtronic hosted medical conferences where
the "principal objective" was to "induce the physician, through any
financial means necessary" to use its devices. According to Ms Poteet,
Medtronic targeted surgeons while they were still in training, and
paid for doctors to attend any of 200 professional meetings a year.

When doctors would visit Memphis, she says, they were sometimes taken
to the "Platinum Plus" strip club, and the expenses for the outing
were recorded as an evening at the ballet.

According to an industry newsletter, Orthopedic Network, the cost of
the spinal implant device is around $13,000. Because the devices are
so profitable, the money spent by Medtronic on doctors "is peanuts," a
former employee who still works in the industry, said in the January
24, 2006, Ledger. Sales representatives earn generous commissions, he
said, so they will work hard to satisfy the doctors' demands.

"You're going to make sure you do whatever he wants, whatever it is,"
he told the Ledger.

Critics say the device makers have become a primary source of income
for surgeons, and many come to rely on it. "The amount of money is
astronomical," says Dr James Herndon, a former president of the
American Academy of Orthopedic Surgeons, in the Ledger.

The device makers "know the volumes these surgeons have," he noted.
"They seek them out, and they seek relationships with them."

Critics within the industry say doctors gravitate to the company with
the highest paying consulting contracts in exchange for using the
company's product. According to court filings, many doctors were paid
consulting fees far higher than the $3,000 a day that a surgeon might
expect to earn.

A former employee of several device makers, including Medtronic, who
declined to be identified because he still works in the industry, says
"it is very difficult to compete legitimately, to get a doctor to look
at ones product when there are so many bought physicians in the
industry."

While working for one company, he says, it was decided prior to the
American Academy of Orthopedic Surgeons meeting in Chicago, that the
goal would be to write 25 consulting contracts with doctors. He said,
several doctors asked what project they would be working on, and the
answer was always "we'll find something."

In his position, he was responsible for documenting the doctor's work
product each month, and says that it was a real struggle to come up
with 8 hours of valid work product for these physicians. But even
though some never had work product, he noted, "their consulting check
was always mailed."

Each month the industry employee said, he received spreadsheets that
showed how much business each doctor did with the company, and then it
was discussed whether the doctor's consulting contract would continue
based on the amount of business that was generated.

Internal company documents filed with Ms Poteet's lawsuit prove that
Medtronic tracked the use of its devices by each doctor who attended
the conferences the company paid for.

A June 2003 spreadsheet for a conference in California, lists over 200
doctors and includes an estimate of the dollar amount of the devices
each doctor uses in surgery. One surgeon is described as "a 100
percent compliant M.S.D. customer" (Medtronic Sofamor Danek), and
other doctors were described as needing "special attention."

For Dr K Daniel Riew, also named as a defendant in the lawsuit, it was
noted on the spreadsheet that he was using a substantial amount of
competing devices. "He will be designing a new plate with M.S.D.," the
document says, "so all of his business will gravitate our way in the
near future."

The industry employee also echoed allegations of perks similar to
those made in the Poteet lawsuit. "The owners of the company were very
well known for frequenting strip clubs," he said, "and prostitutes
were known for being at the national sales meeting to be in the owners
rooms for the late night meetings."

Experts agree that industry employees like this guy have good reason
to be afraid of speaking publicly. Attorney, Mark Cohen, works with
the Government Accountability Project which assists whistleblowers.
People who come forward he says, do so at great personal risk.
"Speaking up puts their current job in jeopardy and it threatens to
brand them as trouble-makers with other employers."

This is especially true for those who go up against the Pharmaceutical
industry, says attorney, Jason Zuckerman, of the Washington DC Law
Office of Jason M. Zuckerman. "Whistleblowers in the pharmaceutical
industry," he warns, "really face an uphill battle, a David versus
Goliath struggle."

In fact, experts say whistleblowers who interfere with the highly
profitable Medicate fraud often find themselves out of work
permanently. "My clients whose only infraction was committing the
truth," Mr Zuckerman states, "have found themselves unemployed and
suffer permanent damage to career and reputation."

Medtronic no doubt will try hard to settle the Poteet lawsuit before
it goes to trial, because under a key provision of the FCA, a jury can
order the company to pay a triple damage award.

But in any event, Medtronic's entanglements with law enforcement
officials are not limited to the Poteet case. According to its latest
SEC filing, Medtronic received a subpoena from the Office of the US
Attorney for the District of Massachusetts issued under the Health
Insurance Portability & Accountability Act of 1996, on October 24,
2005, requesting documents relating to pacemakers and defibrillators;
monitoring equipment and services; benefits to persons in a position
to recommend purchases of such devices; and the company’s training and
compliance materials relating to the fraud and abuse and federal
Anti-Kickback statutes.

"The Company intends to fully cooperate with the Office of the United
States Attorney for the District of Massachusetts," the filing states,
"with respect to this subpoena."

In addition to the lawsuit filed by Ms Poteet and the various
investigations by government agencies, the company is also facing a
wide range of other lawsuits related to its products.

On February 11, 2005, Medtronic began advising doctors about a
potential battery shorting that may occur in implantable cardioverter
defibrillators (ICDs) and cardiac resynchronization therapy
defibrillators (CRT-Ds), including certain of the Marquis VR/DR and
Maximo VR/DR ICDs and certain of the InSync I/II/III Marquis and
InSync III CRT-D devices.

The company provided physicians with a list of potentially affected
patients and recommended that physicians communicate with those
patients so they could manage the issue in a manner they felt was
appropriate for their patients.

Subsequently, the FDA classified the recall a Class II Recall, and a
large number of lawsuits were filed against Medtronic by either
individuals claiming personal injury or third party payors seeking
reimbursement of costs associated with the recall, including a claim
by an individual acting on behalf of the Center for Medicare &
Medicaid Services.

The company waited until February 2005, to tell patients that their
defibrillators might fail. However, company documents filed in the
California lawsuit, Randall v Medtronic, No C-05-3707-JW, show
Medtronic knew about the flaw back in 2003, and continued to sell the
faulty devices for two more years.

"Medtronic has been taking products they know are not quite right and
putting them into people rather than take the loss," according to
Hunter Shkolnik, a New York attorney, who said in a February 13, 2006,
interview with Bloomberg News that he represents more than 200 people
whose Medtronic devices were recalled.

"If you know there's a problem with a component," he said, "you don't
put it out and sell it to people."

Another batch of devices came under scrutiny six months after the
first recall. In a June 9, 2005 letter, the FDA told Medtronic that it
had failed to correct manufacturing problems and investigate its
LifePak 12 external defibrillators and failed to follow through with
preventive action after inspections of the company's Redmond,
Washington plant.

The LifePak 12 defibrillators, used to shock the heart back to a
normal rhythm, are similar to the LifePak 500 devices that the company
had recalled. At the time, about 60,000 LifePak 12 defibrillators were
in use worldwide, company spokesman Rob Clark said.

In the warning letter, the FDA said Medtronic did not investigate all
complaints related to the malfunctions, including one involving a
patient's death, and warned that failure to correct the problems could
result in legal and civil penalties.

According to the company's description of current lawsuits filed
against Medtronic in its latest SEC filing, the "personal injury
complaints generally alleged strict liability, negligence, warranty
and other common law and/or statutory claims; and seek compensatory as
well as punitive damages."

The cases filed in federal court have been consolidated and assigned
to one federal judge under a Multidistrict Litigation process.
According to Medtronic, there are currently approximately "240 federal
cases," most of which have been consolidated in the MDL and the
company expects that all federal cases will be transferred to the MDL.
There are also approximately 30 state court cases that are not part of
the MDL, and five putative class actions filed in Canada, according to
filings with the SEC.

Medtronic attorneys note that separate master complaints were filed in
the MDL for the personal injury and third party payor claims and that
the third party payor complaint contains class allegations and lawyers
for the plaintiffs have informed Medtronic that they will request
permission to amend the personal injury complaint to add class
allegations which were omitted.

The company says it intends to challenge any attempt at class
certification because it believes individual issues far outweigh any
common issues in the various cases.

In attempt to get rid of many of the lawsuits, Medtronic has filed a
summary judgment motion to dismiss the personal injury claims, based
upon in part, the legal theory of federal preemption.

Medtronic argues that FDA regulations for medical devices preempt
lawsuits in state courts and claims the FDA has special authority over
lifesaving or life-sustaining devices, such as defibrillators. "Any
warning has to be regulated by the FDA," said Medtronic attorney,
Michael Brown.

But attorneys for the plaintiffs claim Medtronic "glossed over" the
problem in an October 2003, filing with the FDA that sought approval
of a new defibrillator model, according to a July 11, 2006, article by
the Associated Press.

The motion was heard on July 10, 2006 and a decision by the court is
expected this fall.

There is also a pending a motion to dismiss the third party payor
cases that was filed by Medtronic in March 2006.

On an interesting note, according to its SEC filing, Medtronic has not
recorded an expense related to damages in connection with the various
Marquis related lawsuits because potential losses are not currently
probable or reasonably estimable.

At this point, Medtronic has provided patients with new devices for
free and agreed to give them up to $2,500 for out-of-pocket expenses
related to replacement surgery. But the company does not pick up the
hospital and doctor bills and therefore, public health care plans like
Medicare and Medicaid, and private insurers are stuck with the tab.

Medtronic told the New York Times on February 18, 2006, that the
medical costs of a replacement surgery were effectively offset by its
provision of a free device and the out-of-pocket payments.

The total cost of the operations is unknown but experts say the amount
could run as high as hundreds of millions of dollars.

On February 18, 2006, the New York Times, reported that the cases
filed appear to mark the first time that plaintiffs' lawyers have
filed so-called private attorney general actions against device makers
to recoup expenses paid by Medicare on behalf of its beneficiaries.

CMS officials told the Times, "that they were aware of only three
settlements over the last two decades in which the agency had
recovered more than $1 million from manufacturers, the largest being
$30 million from makers of silicone breast implants."

But the CMS may be ahead of the game with Medtronic. Jerry Walters,
director of the financial services group at the CMS, told the Times
that the government and Medtronic "were looking at where the
responsibility and liability for payment lies."

In addition to the cost of surgery, according to Bloomberg News, on
February 16, 2006, based on "Medtronic's estimate of a 2 percent to 5
percent post-implantation infection rate, 380 to 950 patients may have
developed infections after replacement of their devices."

According to Bloomberg, the cost of the defibrillator replacement at a
Des Moines hospital and post-operative complications reached $100,000,
for Jim Strasko, an unemployed 45-year-old father of six, who was
uninsured and disabled when Medtronic sent him a letter about
replacing his defibrillator.

Indebtedness drove him to the "humiliation" of bankruptcy and problems
in his new marriage, Mr Strasko told Bloomberg in an interview.

Apparently uninterested, Medtronic spokesman, Rob Clark, told
Bloomberg that the company doesn't keep track of deaths, disabilities
or extra medical costs resulting from such complications.

More information for injured parties can be found at Lawyers and
Settlements.com

Vernon

2006-10-13, 9:33 pm

"Ilena Rose" <BIA@mundo.com> wrote in message
news:4q01h2h5809u8pgbguc20220iq15h4j3td@4ax.com...

When you or a loved one is in the hospital with severe arrhythmia or uneven
heart beat, remember not to deal with Medtronic.

Pick one or the companies with a worse history.

Oh, yes, you can choose to die.

There is ABSOLUTELY no alternative to this or other companies other than in
SOME cases ablation.

Mark Probert

2006-10-14, 4:28 pm

Vernon wrote:
> "Ilena Rose" <BIA@mundo.com> wrote in message
> news:4q01h2h5809u8pgbguc20220iq15h4j3td@4ax.com...
>
> When you or a loved one is in the hospital with severe arrhythmia or uneven
> heart beat, remember not to deal with Medtronic.
>
> Pick one or the companies with a worse history.
>
> Oh, yes, you can choose to die.
>
> There is ABSOLUTELY no alternative to this or other companies other than in
> SOME cases ablation.

Agreed. Medtronic implantable cardiac devices are the best available.
Interestingly, Medtronic is now working on battery research to extend
the lives of the implants batteries so that replacement surgeries are
fewer and further in between.

My son has an implanted Medtronic Synchromed Baclofen Pump...and so does
his girlfriend.

Jan Drew

2006-10-14, 9:34 pm

"Mark Probert" <markprobert@lumbercartel.com> wrote in message
news:TS6Yg.106$5h6.103@trndny04...
> Vernon wrote:

Who wrote?

What happened to your UDP??

Poor Mark.[vbcol=seagreen]
>
> Agreed. Medtronic implantable cardiac devices are the best available.
> Interestingly, Medtronic is now working on battery research to extend the
> lives of the implants batteries so that replacement surgeries are fewer
> and further in between.
>
> My son has an implanted Medtronic Synchromed Baclofen Pump...and so does
> his girlfriend.
>
>

Vernon

2006-10-15, 2:29 am

"Jan Drew" <jdrew1374@sbcglobal.net> wrote in message
news:FQgYg.14884$6S3.3050@newssvr25.news.prodigy.net...
>
> "Mark Probert" <markprobert@lumbercartel.com> wrote in message
> news:TS6Yg.106$5h6.103@trndny04...
>
> Who wrote?
>
> What happened to your UDP??
>
> Poor Mark.

They are up to 5 years now.
[vbcol=seagreen]
>
>

Vernon

2006-10-15, 4:28 pm

"Jan Drew" <jdrew1374@sbcglobal.net> wrote in message
news:FQgYg.14884$6S3.3050@newssvr25.news.prodigy.net...
>
> "Mark Probert" <markprobert@lumbercartel.com> wrote in message
> news:TS6Yg.106$5h6.103@trndny04...
>
> Who wrote?
>
> What happened to your UDP??
>

Please explain the link to this subject, or are you just hate filled?

Mark Probert

2006-10-15, 4:28 pm

Vernon wrote:

[vbcol=seagreen]
>
> They are up to 5 years now.

For my son's pump, they are up to eight years.

>
>
>

Jan Drew

2006-10-15, 4:28 pm

"Vernon" <athere@athere> wrote in message
news:45323c9d$0$18946$882e0bbb@news.ThunderNews.com...
>
> "Jan Drew" <jdrew1374@sbcglobal.net> wrote in message
> news:FQgYg.14884$6S3.3050@newssvr25.news.prodigy.net...
>
> Please explain the link to this subject, or are you just hate filled?
>
You really are that dense. or are you here and there and everywhere.
YOU very well know who wrote it. And BLEW is over and over.

The point Mark dishonestly left of that you were replying to me.

Peter Bowditch

2006-10-15, 9:33 pm

"Vernon" <athere@athere> wrote:

>
>"Jan Drew" <jdrew1374@sbcglobal.net> wrote in message
>news:FQgYg.14884$6S3.3050@newssvr25.news.prodigy.net...
>
>Please explain the link to this subject, or are you just hate filled?
>

Bingo!

See, Jan, Vernon and I might disagree about a lot of things but that
doesn't mean we disagree about all things.
--
Peter Bowditch aa #2243
The Millenium Project http://www.ratbags.com/rsoles
Australian Council Against Health Fraud http://www.acahf.org.au
Australian Skeptics http://www.skeptics.com.au
To email me use my first name only at ratbags.com

Vernon

2006-10-15, 9:33 pm

"Mark Probert" <markprobert@lumbercartel.com> wrote in message
news:wHrYg.345$kG5.240@trndny07...
> Vernon wrote:
>
>
>
>
> For my son's pump, they are up to eight years.
>

That's what they are designed for or even more.
So far the actual (empirical) life is 5 years (and still going).

Rich

2006-10-16, 2:31 am

"Jan Drew" <jdrew1374@sbcglobal.net> wrote in message
news:K7wYg.13151$GR.8837@newssvr29.news.prodigy.net...
>

> You really are that dense. or are you here and there and everywhere.
> YOU very well know who wrote it. And BLEW is over and over.
>
> The point Mark dishonestly left of that you were replying to me.

Wow! I was going to give you another Remedial English lesson, but I don't
know where to begin. No part of what you wrote makes any sense whatsoever,
and I haven't a clue what you were trying to say. "You really are that
dense," is a declarative sentence, but you follow it with what appears to be
a clause to turn it into a question. This strange construction has a period
at the end though, not a question mark. You didn't capitalize the first
word, which makes it appear that you meant to attatch it to "dense," but
that ended in a period. "or are you..." can't stand alone as a sentence,
it's incomplete. Even if you connect it with the first sentence, it still
doesn't make sense. "Or are you" implies contradiction or opposites, and
being "here there and everywhere" is certainly not incompatible with being
"dense."

"YOU very well know who wrote it," is a sentence, but still makes little
sense. If Vernon "very well know(s) who wrote it" then he's better at
parsing Janspeak than I, because I not only cannot figure out "who," I have
no idea what "it" is. Nevertheless, I can help a little with style;

"You know very well who wrote it," is better. There is no need for
emphasizing "you," and placing the adverbial "very well" after the verb is
smoother and more idiomatic.

"And BLEW is over and over." What can I say? This collection of words LOOKS
a little like a sentence, but it says nothing at all. It doesn't even hint
at what you were trying to say. It will go into my collection of Janspeak
howlers.

Finally: "The point Mark dishonestly left of that you were replying to me."
This makes even less sense than the last! The first two words promise that
there will be a point, but the jumbled mess of words that follow fails to
keep that promise. You obviously aren't paying attention to our little
lessons, Jan, because your writing is getting WORSE, if that is even
possible.

Remedial English, Jan.
--

--Rich

Recommended websites:

http://www.ratbags.com/rsoles
http://www.acahf.org.au
http://www.quackwatch.org/
http://www.skeptic.com/
http://www.csicop.org/