Hope National Medical Center in June 1978. ER718, ¶ 8. During her tenure, in July of 1979, Dr.
Ruoslahti moved his laboratory from the City of Hope to the La Jolla Cancer Research Foundation.
Uotila, ER718, ¶ 10. She continued employment in Dr. Ruoslahti’s laboratory until September, 1980.
Uotila, ER718-19, ¶ 10. Dr. Uotila was assigned the task of developing monoclonal antibodies to
AFP and to develop immunoassays using the antibodies. Uotila, ER718, ¶ 8. She states that she
recorded her experimental work in six notebooks. Uotila, ER725, ¶ 22. She testified that she entered
data into the notebook “generally” in chronological order. ER725, ¶ 22. She also indicated she only
occasionally dated her work. Uotila, ER725, ¶ 22. Our review of the notebooks shows that the
pages are rarely dated and that the notebook pages are neither signed nor witnessed.
It is alleged that Dr. Uotila carried out a one-step, two-site ELISA sandwich assay using two
different monoclonal antibodies to human alphafeto protein. Engvall Brief, pp. 51-64. According
to Engvall, Dr. Uotila performed several sandwich immunoassays for human alphafeto protein using
two different monoclonal antibodies. Engvall Brief, pp. 51-62 and 80-94. The antibodies used were
designated 50/3, 73/3 and 73/8. Engvall Brief, p. 59. Dr. Uotila testified that the raw data for the
first successful sandwich assay is reported at page 0041 of her Notebook V (Exhibits 5 and 5A ) in 63
the upper right hand corner under column 8. Uotila, ER759, ¶ 83; Uotila, ER760, ¶ 85. She said that
she used this raw data to plot a dose response curve appearing in red in the center of page 0043D of
Notebook V (Exhibit E5A). This data was replotted by Dr. Uotila during her redirect examination
as Exhibit E109 and reproduced on page 58 of Engvall’s Brief.
The portions of Engvall’s brief directed to these alleged successful assays (Engvall Brief, pp.
51-68 and 80-94) do not mention the affinity constant of the antibodies used. Only a part of
Engvall’s Statement of Facts, Section II. F. (Engvall Brief, pp. 64-68), directly discusses the affinity
constants of the antibodies used in the alleged reductions to practice. Engvall there relies only on
subsequent testing to show that antibodies 50/3, 73/3 and 73/8 had affinity constants for AFP of at
least about 10 liters per mole. These tests were performed ex parte in 1988, during the pendency8
of this interference, to show that antibodies 50/3, 73/3 and 73/8 met the “at about 10 liters per mole”8
limitation of the count. Engvall Brief, pp. 64-68. According to Engvall, samples of antibodies 50/3,
63
E5 and E5A appear to be identical but the latter is a color rather than a black and white copy.
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