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FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 4/14/2021 | OSCAR NO. 601202 | PUBLIC PUBLIC

UNITED STATES OF AMERICA 

BEFORE THE FEDERAL TRADE COMMISSION 

OFFICE OF ADMINISTRATIVE LAW JUDGES 

In the Matter of 

HEALTH RESEARCH LABORATORIES, LLC, 

a limited liability company, 

WHOLE BODY SUPPLEMENTS, LLC, 

a limited liability company, and DOCKET NO. 9397 

KRAMER DUHON, 

individually and as an officer of 

HEALTH RESEARCH LABORATORIES, LLC 

and WHOLE BODY SUPPLEMENTS, LLC. 

COMPLAINT COUNSEL’S OPPOSITION TO RENEWED MOTION TO QUASH 

Respondents have made their prior counsel, Olshan Frome Wolosky LLP (“Olshan”), 

central to this matter by blaming consultants engaged at Olshan’s suggestion for Respondents’ 

admittedly unlawful advertising. Consequently, what those consultants told Respondents before 

they chose to run their deceptive advertising is crucial to determining the appropriate scope of 

relief. Yet Respondents refuse to produce their consultants’ work, and their consultants 

dubiously claim they no longer possess it. As a result, Complaint Counsel had no choice but to 

seek this important nonprivileged material from Olshan directly. 

Respondents claim attorney-client privilege, but their blanket assertion that everything 

Olshan may possess is allegedly “confidential” does not meet their burden. To prove consulting 

materials are privileged, Respondents must establish that the consultants worked exclusively to 

help Olshan provide legal advice, or that they are the “functional equivalent” of Respondents’

own employees. Here, neither is true. Accordingly, because Olshan possesses relevant, 

nonprivileged documents not available elsewhere, Respondents’ motion must be denied.1 

1 Complaint Counsel’s March 30 motion to reschedule the evidentiary hearing to permit

more time for discovery is pending before the Commission. 
 

 

 

 

 

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BACKGROUND 

A. Whether Respondents Acted Deliberately 

Importantly, Respondents have asserted to Complaint Counsel that both Olshan and 

certain consultants Olshan directed them to engage approved the advertisements at issue.

2 CCXA ¶2. Of course, whether Respondents acted deliberately is relevant to the scope of relief. See, 

e.g., Telebrands Corp. v. FTC, 457 F.3d 354, 358 (4th Cir. 1996). Following the legitimate 

advice of qualified professionals counsels against broad relief whereas ignoring or failing to 

obtain such advice suggests deliberateness. As such, nonprivileged communications with 

consultants that Olshan possesses are critical to the scope of relief.

3 

B. Natropathic Consultant Inna Yegorova 

Communications with Olshan’s “go-to” substantiation consultant, Inna Yegorova, are 

particularly important. Significantly, Yegorova’s work commenced years before the FTC began 

investigating the supplements at issue on December 18, 20184 —Respondents engaged Olshan on 

January 7, 2015. CCX-B ¶2. Olshan suggested that Respondents hire Yegorova on January 19, 

2015, and Respondents engaged her directly as a consultant. See CCX-A ¶4. 

which is alternative medicine 

“that employs an array of pseudoscientific practices branded as ‘natural,’ ‘non-invasive,’ or 

2 In fact, Respondents have refused to pay Olshan’s last invoice and demanded that 

Olshan put its liability carrier on notice. CCX-A ¶3. 

3 Notwithstanding the ALJ’s order compelling production, Respondents have stated that 

they may not comply fully, or at all. CCX-A ¶13; see also Mtn. to Reconsider (Apr. 13, 2021) at 

3 (“advis[ing] the ALJ that the Respondents do not intend to produce documents”) (emphasis 

added). However, assuming Respondents eventually produce the communications within their 

custody, Olshan possesses documents from their file that Respondents do not. CCX-A ¶11. 

4 On January 7, 2015, the FTC sent a CID to Respondents, CCX-B ¶2, which did not 

cover diabetic neuropathy claims. It encompassed cardiovascular health claims, although the 

FTC narrowed it to exclude them later that month. CCX-C, Att. 1. The FTC first expressed 

“concerns” about the claims at issue on December 19, 2018, during a separate investigation by a 

different division. CCX-C, Att. 2. 

2 
 

 

 

 

 

 

 

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promoting ‘self-healing.’”5 

In fact, Respondents previously planned to call Yegorova to 

testify about the supplements’ “[d]evelopment, review, revision, and/or approval of advertising 

and marketing,” as well as “substantiation related to claims” in that advertising. Witness List 

(Jan. 29, 2021) at 4-5. 

Notably, Yegorova performed similar functions for other marketers that engaged Olshan 

attorneys Sheldon and Andrew Lustigman. For instance, the Commission secured an industry 

ban against Glenn Braswell, a promoter who marketed pills that supposedly treated emphysema 

and Alzheimer’s disease, among other things.6 Sheldon Lustigman represented Braswell,7 and 

testimony from one of Braswell’s marketers revealed that Yegorova served as his scientific 

“director” who sometimes reviewed ads. CCX-C, Att. 5 188:15-19; 204:8-205:6. 

Likewise, the FTC sued Olshan client Nordic Clinical in 2017 for claiming through direct 

mail that their supplements could relieve pain “26 times longer” than competitors, and accelerate 

recovery in physical therapy by “368%.”8 Yegorova testified that she { 

5 Natropathy, Wikipedia (accessed Mar. 1, 2021); see also CCX-C ¶4 Att. 4, Kimball 

Atwood, M.D., Natropathy: A Critical Appraisal, www.medscape.com (Mar. 1, 2021). 

6 FTC v. Braswell, No. 3-cv-3700 (C.D. Cal. May 27, 2003) (ECF No. 1). 

7 FTC v. Braswell, No. 3-cv-3700 (ECF No. 759) at 29. Sheldon Lustigman then worked 

for his own firm. 

8 FTC v. Mile High, No. 20-cv-21622 (S.D. Fla. Apr. 17, 2020) (ECF No. 1). 

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As Complaint Counsel’s prior discovery motions made plain, Respondents generally 

refused to produce documents, including Yegorova’s materials. That refusal continues and, in 

any event, Respondents likely do not possess all relevant communications with Yegorova. See 

supra at 2 n.2. Complaint Counsel also subpoenaed Yegorova directly. However, consistent 

with her questionable document destruction practices, Yegorova denies possessing responsive 

material. CCX-C, Att. 7. 

C. Marketing Consultant Kent Komae 

While working with Olshan, Respondents engaged other consultants including Kent 

Komae, who 

CCX-A ¶6. Notably, the FTC sued A.S. Research for 

claiming through direct mail that their supplements could, among other things, reduce pain 

“83%” in a month and provide a “30% increase in flexibility in just 7 days”—improvements 

substantial enough that mobility-limited patients could give up their walkers.9 

Unsurprisingly, the A.S. Research ads are strikingly similar to Respondents’ ads (and, in fact, 

both sets are strikingly similar to the Nordic Clinical ads referenced above). CCX-D ¶2 Att. 1 

(visually illustrating similarities). 

Respondents have not produced Komae’s materials. When Complaint Counsel 

subpoenaed Komae, he responded: “I did not work on the projects mentioned in the Subpoena . . 

9 FTC v. A.S. Research, No. 19-cv-3423 (D. Colo. Dec. 5, 2019) (ECF No. 1) at 10. In 

both Mile High and A.S., the Commission secured a monetary judgments and detailed conduct 

relief through consent orders. 

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Consequently, as with Yegorova, it is likely Olshan has 

relevant, nonprivileged communications from Komae.10 

I have no. . documents[.]” CCX-C Att. 9, (Komae’s emphasis). 

D. Respondents’ Position 

Respondents’ position concerning the Olshan subpoena has varied. First, before moving 

to quash initially,

11 Respondents explained that they cannot access their file at Olshan, CCX-A 

¶11, although Olshan cannot withhold them “absent a substantial showing of good cause[.]” 

Sage Realty Corp. v. Proskauer Rose, 294 A.D.2d 190, 191 (N.Y. App. 2002). According to 

Respondents, Olshan will not produce the files until Respondents pay Olshan’s bill, but 

Respondents refuse given Olshan’s alleged malpractice. CCX-A ¶11. 

Second, also before moving to quash initially, Respondents asserted that seeking 

information from former counsel is improper, CCX-A ¶12, which makes little sense because 

Respondents have refused to comply with discovery generally and, in any event, they deny 

possessing everything Olshan does. Furthermore, Complaint Counsel’s attempts to obtain the 

material from the consultants directly have failed because they deny possessing any documents, 

although (as also discussed above), 

Third, Respondents’ motion cites privilege, but it contains no argument or detailed 

evidentiary support. In fact, its only support is a declaration from Respondents’ CEO who states 

that the subpoenaed materials are “confidential,” CCX-B ¶2—he does not assert, let alone 

establish, any privilege. 

10 There are other consultants as well. For example, Respondents proposed to call Dr. 

yet Respondents have produced only limited material 

Richard Cohen to testify about substantiation. Witness List 6.at Dr. Cohen

reflecting this review, CCX-A ¶9, and Dr. Cohen denied possessing any, id. ¶10. 

11 Respondents filed an earlier motion that the ALJ denied without prejudice. 

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FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 4/14/2021 | OSCAR NO. 601202 | PUBLIC PUBLIC

Notably, Respondents’ motion does not contend that the subpoena seeks irrelevant 

information. Nor could Respondents honestly so contend, because their communications with 

consultants are plainly relevant to whether they acted deliberately. 

Legal Standard 

As the party asserting a privilege, Respondents must “provide sufficient underlying facts 

to establish the privilege claim.” Hoechst Marion, 124 F.T.C. 649, 659 (1997) (quotation 

omitted). 

Argument 

I. Blanket “Confidentiality” Assertions Are Inadequate. 

Respondents’ motion simply asserts that all subpoenaed documents are necessarily 

privileged because Olshan represented Respondents. However, this “blanket assertion of 

attorney-client . . . privilege[] is insufficient to satisfy [Respondent’s] burden.” Hoechst Marion, 

124 F.T.C. 649, 659 (1997) (quotation omitted); see also Union Oil Co., No. 9305, 2003 WL 

21642422, *4 (June 30, 2003) (“Turner’s bald assertion, with no detail or explanation . . . is not 

sufficient to sustain its burden.”). In fact, Respondents’ two-paragraph declaration asserts only 

that the materials are “confidential,” CCX-B ¶ 2, however “the fact a document may be 

‘confidential’ alone does not insulate it from discovery.” Brown-Thomas v. Hynie, 2020 WL 

6737757, *8 (D.S.C. Nov. 17, 2020); see also U.S. Bank Nat’l Ass’n v. PHL Variable Ins. Co., 

2016 WL 1258466, *2 (D. Minn. Mar. 30, 2016) (“[A] document is not automatically privileged 

merely because it involves an attorney and a client or because it is labeled privileged or 

confidential.”). Because blanket “confidentiality” assertions cannot satisfy Respondents’ burden, 

their motion must be denied. 

II. Respondents Have Not Established That Consultant Materials Are Privileged. 

Communications with consultants are privileged in only two situations: (1) when the 

consultant’s role “is limited to helping a lawyer give effective [legal] advice,” Export-Import 

Bank v. Asia Pulp & Paper, 232 F.R.D. 103, 113 (S.D.N.Y. 2005) (citing U.S. v. Kovel, 296 F.2d 

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FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 4/14/2021 | OSCAR NO. 601202 | PUBLIC PUBLIC

918, 922 (2d Cir. 1961)); and (2) the consultant is “so thoroughly integrated” into the company 

that she qualifies as the “functional equivalent” of an employee, see Export-Import, 232 F.R.D. 

at 113. Neither circumstance applies here. 

A. Respondents Have Not Proven Their Consultants Limited Their Work To 

Helping Olshan. 

As discussed above, Respondents make clear—in communications to the FTC through 

Olshan—that their consultants’ functions included, among other things, 

Thus, they were 

“not employed by [Olshan] attorneys specifically to assist them in rendering legal advice,” and 

they had functions other than placing “information gained from [Respondents] into usable form

for their attorneys to render legal advice[.]” USPS v. Phelps Dodge Ref. Corp., 852 F. Supp. 

156, 161 (E.D.N.Y. 1994); see also FTC v. TRW, Inc., 628 F.2d 207, 209-12 (D.C. Cir. 1980) 

(explaining communications with consultant hired to study “[a] company’s complex 

computerized credit reporting system” would have been privileged if consultant was hired to put 

company’s computerized credit reporting system into a more understandable form for lawyers); 

In re G-I Holdings, 218 F.R.D. 428, 434 (D.N.J. 2003) (privilege only where the consultant 

functions as a “translator” between the attorney and client); U.S. v. Chevron Texaco Corp., 241 

F. Supp.2d 1065, 1072 (N.D. Cal. 2002) (for privilege to apply, consultant must “interpret[] the 

client’s otherwise privileged communications or data to enable the attorney to understand” 

them). Because the consultants here had roles beyond helping Olshan give advice, their 

communications are not privileged unless Respondents have proven they are de facto 

employees—which, as discussed below, they were not. 

B. Respondents Have Not Proven That the Consultants Are the “Functional

Equivalent” of Employees. 

To determine whether a consultant is a de facto employee, courts consider various factors 

including their responsibilities, what information they possess, and “whether there was a 

continuous and close working relationship” with the company “on matters critical to the 

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company’s position in litigation.” Export-Import, 232 F.R.D. at 113 (citation omitted). 

Critically, Respondents’ have the burden to show the consultants’ integration into their corporate 

structure, see id., which requires “a detailed factual showing,” A.H. v. Evenflo Co., 2012 WL 

1957302, *4 (D. Colo. May 31, 2012); see also Energy Capital Corp. v. United States, 45 Fed. 

Cl. 481, 492 (2000) (“[A] detailed factual showing is necessary to establish the relationship 

between a third party that is sought to be included within the . . . attorney-client privilege[.]”).

Importantly, Respondents have made no such showing, nor could they. At least with 

respect to the supplements at issue, the consultants could not have worked entirely “on matters

critical to [Respondents’] position in litigation,” Export-Import, 232 F.R.D. at 113, because, as 

discussed above, their work started before the FTC began investigating the supplements at issue 

in the Complaint and, in fact, before the FTC filed any action against Respondents.12 Indeed, if 

they were working in anticipation of litigation, they violated their document retention obligations 

by failing to preserve material. See, e.g., Osf Healthcare Sys., No. 9349, 2012 WL 1561035, *2 

(Mar. 27, 2012) (“[T]he duty to preserve evidence arises when a party knows or should know 

that certain evidence is relevant to pending or future litigation.”).

Additionally, at least some consultants spent considerable time working for other 

parties—at minimum, as explained above, Yegorova and Komae worked for other FTC 

defendants at approximately the same time. See Export-Import, 232 F.R.D. at 113 (consultant 

working 80-85% for principal insufficient). There is also no evidence that these consultants 

“ever appeared on behalf of” Respondents, “corresponded with third parties as a representative 

of [Respondents],” have “been viewed by others” as Respondents’ employees, or “maintained an 

office” with Respondents. Steinfeld v. IMS Health, 2011 WL 6179505, *3-*4 (S.D.N.Y. Dec. 9, 

2011) (citing these factors). 

12 See FTC v. Health Research Laboratories, No. 17-cv-467 (D. Me. Nov. 30, 2017) 

(concerning other products and claims than those at issue here). 

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Finally, there is no evidence that the consultants had any decision-making authority. See, 

e.g., Narayanan v. Sutherland Glob. Holdings Inc., 285 F. Supp. 3d 604, 617 (W.D.N.Y. 2018) 

(consultant not functional equivalent of employee where company, not consultant, retained 

authority to make decisions about the subject the consultant was hired to address). In short, 

Respondents have not proven their consultants are de facto employees, nor could they. See, e.g., 

In re Currency Conversion Fee, No. MDL-1409, 2003 WL 22389169, *2 (S.D.N.Y. Oct. 21, 

2003) (consultant providing “standard trade service” not functional equivalent of employee). 

Conclusion 

For these reasons, Respondents’ motion must be denied. 

Respectfully submitted, 

s/ Jonathan Cohen 

Elizabeth J. Averill 

Jonathan Cohen 

Federal Trade Commission 

600 Pennsylvania Ave, NW, CC-9528 

Washington, DC 20580 

(202) 326-2993 (Averill); -2551 (Cohen) 

Eaverill@ftc.gov; Jcohen2@ftc.gov 

(202) 326-3197 (facsimile) 

Complaint Counsel 

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STATEMENT CONCERNING CONFIDENTIALITY 

The content of the foregoing submission and certain exhibits contain information 

designated confidential or otherwise subject to confidential treatment pursuant to the standing 

Protective Order. Accordingly: 

▪ Complaint Counsel has attached a copy of the Protective Order; 

▪ Complaint Counsel will immediately provide notice to two third-party submitters of 

confidential material (this Statement serves as notice to Respondents); 

▪ Complaint Counsel has attached a copy of each page of this filing on which confidential 

material appears; and 

▪ If the Commission intends to disclose any confidential material in a final decision, it 

should contact: 

With respect to CCX-A ¶6 and CCX-C ¶8: 

Albert Shawe Watkins, Esq. 

Kodner Watkins, LC 

7733 Forsyth Boulevard, Suite 600 

St. Louis, Missouri 63105 

(314) 727-9111; AlbertSWatkins@kwklaw.net 

With respect to CCX-A ¶6 and CCX-C ¶8: 

Sheldon S. Lustigman, Esq. 

Oslan Frome Wolosky LLP 

1325 Avenue of the Americas 

New York, New York 10019 

(212) 451-2262; SLustigman@OlshanLaw.com 

With respect to all other confidential material: 

Joel Reese, Esq. 

Reese Marketos LLP 

750 N. Saint Paul St., Suite 600 

Dallas, Texas 75201 

Joel.reese@rm-firm.com 

Counsel to Respondents 

Complaint Counsel disagrees with certain of Respondents’ “confidential” designations 

and reserves the right to challenge those designations. 

s/ Jonathan Cohen 

Jonathan Cohen 

Federal Trade Commission 

600 Pennsylvania Ave, NW, CC-9528 

Washington, DC 20580 

(202) 326-2551; jcohen2@ftc.gov 

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CERTIFICATE OF SERVICE 

I certify that I served a copy of the public version of Complaint Counsel’s Opposition to 

Motion to Quash on counsel for the Respondents on April 14, 2021 via electronic mail, and the 

nonpublic version via SFTP. 

Joel Reese 

Joshua Russ 

Reese Marketos LLP 

750 N. Saint Paul St., Suite 600 

Dallas, Texas 75201 

Joel.reese@rm-firm.com 

Josh.russ@rm-firm.com 

I also served one electronic copy of both public and nonpublic versions via the Administrative EFiling System and one electronic courtesy copy to the Office of the Secretary via email to 

ElectronicFilings@ftc.gov. 

I served one electronic courtesy copy via email to the Office of the Administrative Law Judge: 

The Honorable D. Michael Chappell 

Administrative Law Judge 

600 Pennsylvania Ave, N.W., Room H-110 

Washington, DC 20580 

s/ Jonathan Cohen 

Jonathan Cohen 

Federal Trade Commission 

600 Pennsylvania Ave, NW, CC-9528 

Washington, DC 20580 

(202) 326-2551; jcohen2@ftc.gov 

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________________________________________________ 

________________________________________________ 

PUBLIC

UNITED STATES OF AMERICA 

BEFORE THE FEDERAL TRADE COMMISSION 

OFFICE OF ADMINISTRATIVE LAW JUDGES 

In the Matter of 

HEALTH RESEARCH LABORATORIES, LLC, 

a limited liability company, 

WHOLE BODY SUPPLEMENTS, LLC, 

a limited liability company, and DOCKET NO. 9397 

KRAMER DUHON, 

individually and as an officer of 

HEALTH RESEARCH LABORATORIES, LLC 

and WHOLE BODY SUPPLEMENTS, LLC. 

DECLARATION OF JONATHAN COHEN 

I have personal knowledge of the facts set forth below. If called as a witness, I could and 

would testify as follows: 

1. I am a United States citizen and am over eighteen years of age. I am employed by 

the Federal Trade Commission (“FTC”) as an attorney in the Division of Enforcement, Bureau of 

Consumer Protection. I am acting as Complaint Counsel in the above-captioned matter. 

2. During multiple teleconferences, Respondents’ counsel has repeatedly asserted 

that Olshan Frome Wolosky LLP (“Olshan”) directed them to engage particular consultants, and 

that Olshan and some of the consultants approved the advertisements at issue. 

3. According to Respondents, they have refused to pay Olshan’s last invoice,

demanded that Olshan put its liability carrier on notice, and will consider a malpractice claim 

after this matter concludes. 
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4. In a teleconference with Respondents’ current counsel, Respondents’ current

counsel stated that Respondents engaged Yegorova at Olshan’s suggestion on January 19, 2015. 

In a teleconference with Sheldon Lustigman, acting in his capacity as counsel to Inna Yegorova, 

Lustigman explained that Respondents engaged Yegorova directly. 

5. 

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PUBLIC

10. In response to a subpoena from Complaint Counsel, Dr. Cohen denied possessing 

documents reflecting his review of the supplements at issue. 

11. Through their current counsel, Respondents have represented to Complaint 

Counsel that Olshan refuses to provide them with their entire file until Respondents pay Olshan’s 

bill, which Respondents will not do because they contend Olshan breached its duties to 

Respondents through the allegedly erroneous advice Olshan gave. 

12. Respondents have informed Complaint Counsel that seeking the information at 

issue from their former counsel is improper. 

13. Respondents have informed Complaint Counsel that they will not comply with the 

April 6, 2021 order compelling production. 

I declare under penalty of perjury under the laws of the United States that the foregoing is 

true and correct. 

Executed on: April 13, 2021 /s/ Jonathan Cohen 

Washington, D.C. 

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PUBLIC 

UNITED STATES OF AMERICA 

BEFORE THE FEDERAL TRADE COMMISSION 

OFFICE OF THE ADMINISTRATIVE LAW JUDGES 

In the Matter of 

HEALTH RESEARCH LABORATORIES, LLC, 

a limited liability company, 

DOCKET NO. 9397 

WHOLE BODY SUPPLEMENTS, LLC, 

a limited liability company, and 

KRAMER DUHON, 

individually and as an officer of HEALTH 

RESEARCH LABORATORIES, LLC and 

WHOLE BODY SUPPLEMENTS, LLC 

DECLARATION OF KRAMER DUHON 

I. Kramer Duhon, hereby declare: 

I. My name is Kramer Duhon. I am the CEO of HeaJth Research Laboratories, LLC 

and Whole Body Supplements. LLC. I make this declaration based on personal knowledge ofthe 

facts set forth herein. 

2. On or about January 7, 2015, l received a Civil Investigative Demand ("CID") from 

the Federal Trade Commission ("FTC") and immediately hired the law firm of Olshan Frome 

Wolosky LLP to represent the Respondents in connection with CID and all other legal issues 

related to the FTC. From January 7, 2015 until approximately November 13, 2019, the 

lawyers at Olshan represented me and provided legal advice regarding all issues and 

disputes with FTC. The Respondents have had no relationship with Olshan or its attorneys 

other than an attorney-client relationship. I, and the other Respondents, consider all ofthe 
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documents, files, and communications within Olshan's possession, custody or control to be 

confidential. 

Pursuant to 28 U.S. C. § I 746, I declare under pen f perjury that the foregoing is true 

and correct based on my personal knowledge. 
________________________________________________ 

________________________________________________ 

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UNITED STATES OF AMERICA 

BEFORE THE FEDERAL TRADE COMMISSION 

OFFICE OF ADMINISTRATIVE LAW JUDGES 

In the Matter of 

HEALTH RESEARCH LABORATORIES, LLC, 

a limited liability company, 

WHOLE BODY SUPPLEMENTS, LLC, 

a limited liability company, and DOCKET NO. 9397 

KRAMER DUHON, 

individually and as an officer of 

HEALTH RESEARCH LABORATORIES, LLC 

and WHOLE BODY SUPPLEMENTS, LLC. 

DECLARATION OF GRANT WELBY 

I have personal knowledge of the facts set forth below. If called as a witness, I could and 

would testify as follows: 

I am a United States citizen over the age of 18. I received a bachelor’s degree from The 

Johns Hopkins University in 2018. I am employed by the Federal Trade Commission (“FTC”) as 

an Honors Paralegal in the Bureau of Consumer Protection, where I was assigned to work on In 

the Matter of Health Research Laboratories, Docket No. 9397. 

1. A true and correct copy of correspondence from Mary Engle to Andrew and 

Sheldon Lustigman, dated January 30, 2015, is Attachment 1 hereto. 

2. A true and correct copy of correspondence from Robert Frisby to Andrew 

Lustigman, dated December 19, 2018, is Attachment 2 hereto. 
 

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4. A true and correct copy of Natropathy: A Critical Appraisal, by Kimball C. 

Atwood IV, MD is Attachment 4 hereto. I retrieved this article from Medscape.com on March 

1, 2021. 

5. A true and correct copy of excerpts of the deposition of Ernst M. Kloetzili, taken 

in FTC v. Braswell, No. 3-cv-3700 (C.D. Cal.), is Attachment 5 hereto. 

7. A true and correct copy of Inna Yegorova’s subpoena response is Attachment 7 

hereto. 

9. A true and correct copy of an email from Kent Komae to Elizabeth Averill, dated 

January 12, 2021, is Attachment 9 hereto. 

10. I researched two institutions from which Inna Yegorova claims to hold doctorates: 

Clayton College of Natural Health (“Clayton”) and Westbrook University (“Westbrook”). 

11. Information online, including on Wikipedia, discloses that Clayton was a distance 

learning school located in Alabama that ceased operations in 2010. I also reviewed public 

information that the Department of Education makes available, as well as public information that 

the Council for Higher Education Accreditation (“CHEA”) makes available. Based on this 

research, Clayton never held any accreditation that the Department of Education or CHEA 

recognize. 
 

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12. Information online, including on Wikipedia, discloses that Westbrook is a 

distance learning school currently located in West Virginia. I also reviewed public information 

that the Department of Education makes available, as well as public information that the Council 

for Higher Education Accreditation (“CHEA”) makes available. Based on this research, 

Westbrook never held any accreditation that the Department of Education or CHEA recognize. 

13. On February 25, 2021, I spoke with Dr. Lizabeth Gregg, who I understood to be 

the President of Westbrook University. Gregg informed me that Westbrook no longer accepts 

new students, and will entirely cease operations once its remaining students complete their 

coursework. 

I declare under penalty of perjury under the laws of the United States that the foregoing is true 

and correct. 

Executed on: April 13, 2021 /s/ Grant Welby 

Washington, D.C. 
FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 4/14/2021 | OSCAR NO. 601202 | PUBLIC

PUBLIC 

Attachment 1 

4 
FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 4/14/2021 | OSCAR NO. 601202 | PUBLIC

PUBLIC 

Uniled States ofAmerica 

FEDERAL TRADE COMMISSION 

Washington, D.C. 20580 

Division ofAdvenising Pn!ctices 

January 30, 2015 

Via Email and Federal Express 

Andrew B. Lustigman, Esq. 

Sheldon S. Lustigman, Esq. 

OlshanFrome Wolosky LLP 

Park A venue Tower 

65 E. 55th Street 

New York, NY I 0022 

ALustigman@olshanlaw.com 

SLustigman@olshanlaw.com 

Re: CIDs issued to Health Research Laboratories, LLC (Matter Number 142-3021) on 

De.cem ber 3 I, 2014 

Dear Misters Lustigman: 

This letter is in resJX>nse to your request to James Prunty, Carolyn Hann, and David 

Frankel ("FTC staff'' or "staff') for an extension ofthe deadline for resJX>nding to the Civil 

Investigative Demand ("CID") served by the Federal Trade Commission on your c.lient, Health 

Research Laboratories, LLC ("HRL"). Although the deadline for responding to the CID 

currently expires today, FTC staff advised me that you and they agreed to a rolling production 

schedule to accommodate your client's time constraints and recent inclement weather. 

Pursuant to those discussions, I am writing to inform you ofthe following: First, my 

understanding is that for the purJX>ses of HRL's resJX>nses to this CID, FTC staff and you have 

agreed to limit the scope of the defined term, Product(s), holding the remainder ofthis definition 

in abeyance witil further notice. The revised definition of "Product(s)" shall be limited to the 

following products: Biollepatocyte, BioTherapex, BioZyme Liver Rejuvenation, Telomed, 

NeuroPlus, Skinny Green Coffee, and Rejuvalife Rx. 

In addition, HRL agrees to provide exemplar direct mail pieces for the following 

products: Adult Stem Cell Booster 2.1, Adult Stem Ce.II Booster 2.0 (also known as ASCB 2.0), 

Biostem Blue, CTG 1.92%, Green Algae Supplement, Maximum T, T-Amp, and T-Plus 

Rejuvenation. Each such direct mail piece must be several pages long, with complete product 

descriptions and narratives. HRL also agrees to provide two product samples of Maximum T as 

well as two product samples each of BioHepatocyte, BioTherapex, BioZyme Liver Rej uvenation, 

Telomed, NeuroPlus, Skinny Green Coffee, and Rejuvalife Rx as part of its resJX>nsive to 

Document Specification 2. 

CCX-C Att. 1 at 1 
FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 4/14/2021 | OSCAR NO. 601202 | PUBLIC

Andrew B. Lustigman, Esq. 

Sheldon S. Lustigman, Esq. 

January 30, 2015 

Page 2 

Second, I am writing to inform you that the deadlines by which HRL must provide its 

responses are as follows: 

Round 1: Friday, January 30, 2015 

• Interrogatory Specifications 1-3.

Round 2: Friday, February 20, 2015 

• Interrogatory Specifications 4-10, 12-17, 21-28, and 31; and

• Document Specifications 1, 2 (including Maximum T), 3-7, 8, 1 9 (limited to any

documents that provide a general description of the codes that appear on direct mail

pieces, with the remainder held in abeyance),13-14, 15 (including general training as well

as any specific training relating to a Product), and 17 (any communications from

consumers seeking refunds or chargebacks for any of the Product(s)).

Round 3: Monday, March 2, 2015 

• Interrogatory Specifications 11, 18-20, and 29; and

• Document Specifications 10-12, 16 (all responsive recordings available by this date), and

17 (remainder of all responsive documents, including all documents relating to any

communications with or about consumers seeking refunds or charge backs for any of the

Product( s)).

Round 4: Monday, March 16, 2015 

• Interrogatory Specifications 30 and 32-34; and

• Document Specifications 16 (remainder of responsive recordings) and 18 (limited to the

Applicable time period, with the remainder held in abeyance), 19 (limited to conduct

other than tardiness and attendance, with the remainder held in abeyance), and 20.

1 As you have discussed with FTC staff, I agree that the phrase, "or the Company," that appears in the first sence of 

Document Specification 8 should be omitted. 

CCX-C Att. 1 at 2
FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 4/14/2021 | OSCAR NO. 601202 | PUBLIC

Andrew B. Lustigman, Esq. 

Sheldon S. Lustigman, Esq. 

January 30, 2015 

Page 3 

Other Issues 

First, I understand from FTC staff that you have asserted that recordings responsive to 

Document Specification 16, which were created by a third-party vendor pursuant to a contract 

with HRL, may be beyond HRL's custody and control. Like staff, I respectfully disagree with 

this assertion. FTC staff is happy to discuss this issue with you further and to review any 

documents (e.g., contracts between HRL and its vendor) relevant to this position. 

Second, I understand that you have advised HRL to preserve all documents and other 

evidence in its possession and to cease all document destruction or erasure, as provided by 

Instruction ILE of the CID. 

Finally, during this investigation, FTC staff reserves the right to request additional 

responses to any interrogatory or document specifications that have been fully or partly held in 

abeyance. You should provide any responsive search results within fourteen (14) days of 

receiving staffs request for additional searches. 

If you have any questions or concerns about this production schedule, please contact Mr. 

Prunty at 202-326-2439 or Ms. Hann at 202-326-2745. 

Very truly yours, 

��-�/2$11 

Mary K. Engle 

Associate Director 

cc: James A. Prunty 

Carolyn L. Hann 

David P. Frankel 

(All via email only) 

CCX-C Att. 1 at 3
PUBLIC 

FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 4/14/2021 | OSCAR NO. 601202 | PUBLIC

2 Attachment 

5 
FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 4/14/2021 | OSCAR NO. 601202 | PUBLIC

PUBLIC 

UNITED STATES OF AMERICA 

FEDERAL TRADE COMMISSION 

WASHINGTON, D.C. 20S80 

BureauofCals1D1er Pro!lldion 

Division ofEn&Jrccmcot 

Roba1 M. Frisby 

Money 

Email: rfiishy@fb:!JZV 

Direct Diat 202-326-2098 

December 19. 20 l 8 

.VIA ELECTRONIC MAIL., 

Andrew B. Lustigman, Esq. 

Olshan Frome Wolosky LLP 

1325 A venue ofthe Americas 

New York, NY 10019 

ALustigman@olshanlaw.com 

Re: FTC and State ofMaine v. Health Research Laboratories, UC. FTC No. XI 80007 

Dear Mr. Lustigman: 

We have completed our review ofthe documents you submitted in June 2018 in response 

to the FTC's May 21, 2018 compliance requests. Based on our review ofthe defendants• 

advertising, we have identified a number ofrepresentations raising concerns under the Order, 

including: (1) disease cure, mitigation, or treatment representations covered by section II.H; 

(2) other health benefit representations covered by section III; (3) representations regarding 

scientific testing covered by section IV; and ( 4) representations relating to the defendants' "free 

trial guarantee" covered by sections VIII and IX.A ofthe Order. 

We need additional information to assess whether these representations violate the Order 

or warrant fwther investigation. Accordingly, pursuant to section XIX, please submit the 

following information and documents by January 16, 2019: 

1. Total revenue received by defendants for each of the following products sold by 

Health Research Laboratories or Whole Body Supplements sincetheentryofthe 

Orderin January2018: BioStem, Black Garlic Botanicals, BG-18, Ultimate Heart 

Formula, BladderEZE, Neupathic, BladderSecur, NeuroCare, Thyroid Essentials, 

Betarol, Maximum T, T-Plus, Regimen, The Ultimate Cardio Cleanse, and Clear 

Colon Defense; 

2. The chargeback, return, and reftmd volume and rate for each product listed in item 

Page I of 7 

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: 

I 

one above, and the overall chargeback, return, and refund volume and rate, since 

entry of the Order in January 2018; 

3.e Any complaint received by the defendants from a consumer, the Better Businesse

Bureau, or any law enforcement agency referring or relating to the defendants' "freee

trial guarantee," any other refund offer, or any failure to provide a refund since entrye

of the Order in January 2018; ande

'4. For each advertising testimonial or other statement identified in the chart below, the 

evidence defendants possess and rely upon to substantiate that the statement is true. 

For consumer testimonials, please provide evidence that the statement is true and that 

consumers generally experience similar results using the product if such is the case. 

If defendants do not possess clinical testing of the product, or of an Essentially 

Equivalent Product, as that term is defined in the Order (as opposed to testing of 

individual ingredients), please so state. 

Product Advertising Statements 

And scientific studies have shown that the premium quality superfood BioStem it contains, harvested from Klamath Lake in Oregon, possess [sic] 

properties specific to stem cells which allow it to: 

I.e Stimulate the release of stem cells from your own bone marrowe

with an increase in production of25% to 30% (that is approximately 3e

million additional stem cells).e

2.e Stimulate the shifting of your stem cells towards damagede

tissue for faster and more active, "site-·specific" rejuvenation.e

"Black Garlic helps to repair age damaged skin. Uniquely colored due Black Garlic to its fermentation process, Black Garlic contains twice the 

Botanicals antioxidants as regular garlic ... and restores skin cells damaged by 

the aging process."~ Dr. Oz 

and 

"My blood sugar numbers are now close to normal and I haven't had 

a headache since I started using Black Garlic Botanicals" ~ Gus H. BG-18 

"I made the switch to Black Garlic Botanicals and within the span of 3 

months my LDL levels have reduced from 300 to 150. This product 

works!"~ Gerald W. 

"I now have my blood pressure under control with Black Garlic 

Botanicals. This is a quality product!"~ RolfM. 

SEE INSIDE to discover a natural nutrient that is up to 95% 

EFFECTIVE at maintaining clear arteries and reducing risk of a heart 

problem! 

Page 2 of7 

CCX-C Att. 2 at 2
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Ultimate 

Heart 

Formula 

Helps to mitigate out-of-control cell growth and naturally activates 

your body's ability to heal itself without damaging side effects. 

Instead, right before you is a simple, safe, inexpensive, non-painful 

and preventative option that could help you say goodbye to your heart 

surgeon and avoid an angioplasty. 

Two studies reported in the medical journal, Pharmacotherapy, that 

51 % and 43% of people were able to get off blood-pressure and 

cardiovascular medication with the help of CoQl0 treatment. In 

another CoQI0 study, reported in the medical journal, Clinical 

Investigator, 100% of patients with serious heart problems experienced 

an improvement in their symptoms. And 80% experienced beneficial 

blood pressure levels. Furthermore, in yet another study involving 

2,664 heart patients over a 3-month period, the results showed that 

75% of people experienced fewer skipped heartbeats and 63% 

experienced a reduction in irregular heartbeats. And according to 

studies reported in the Cardiovascular Drugs Therapy medical journal, 

CoQ 10 can improve the condition of 91 % of patients who have 

suffered a disastrous interruption of blood-flow to the heart. In even 

MORE studies, heart patients taking CoQ 10 were found to have less 

than one-third as much chest pain and 75% fewer heart rhythm 

problems than those not taking CoQlO. Best of all: There have been 

more than 1,000 published papers that PROVE CoQlO is completely 

safe. Long term trials have even shown that supplementing with 

CoQ 10 is absolutely safe and non-toxic even after 8-years of use. 

The Ultimate Heart Formula also contains a powerful, clot-busting 

agent! The Ultimate Heart Formula gives you the power of a Japanese 

soy plant called Natto, with a 1,000-year-old medicinal history! And 

recent scientific studies have shown it has the uncanny ability to 

liquefy blood-clots and help prevent them from occurring at all! ... 

Like EDTA and CoQ 10, the results from the clinical studies carried 

out on Natto have been remarkable! For example, researchers from 

· JCR Pharmaceuticals, Oklahoma State University, and Miyazakie

Medical College, gave people 200-grams ofNatto before breakfast.e

The result ... Natto was able to reduce the time it took their bodies toe

dissolve a dangerous blood-clot by 48% within just two hours ofe

treatment. Plus, their bodies retained this enhanced ability to dissolvee

blood-clots for up to eight hours.e

And that's not all ... In another study, performed by Miyazakie

Medical College, people were given Natto. Within just two hours,e

their systolic blood pressure decreased, on average, from 173mmHg toe

155mmHg. And their diastolic blood pressure decreased frome

Page 3 of7 

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I 

BladderEZE 

lOlmmHg to 91mmHg. And according to Dr. Martin Milner, a 

researcher of cardiology and pulmonary medicine at the Center for 

Natural Medicine in Oregon ... [,] ''Natto represents the most exciting 

development in the prevention and treatment of cardiovascular related 

problems. We have finally found a potent natural agent that can help 

thin and dissolve clots effec;tively, without side-effects." 

EDTA is up to 95% effective at maintaining clear arteries and helping 

to reduce the risk of a heart problem! It's true, Ethylene Diamine 

Tetraacetic Acid or EDTA has shown to be 95% effective in helping 

maintain arteries in over 1,823 scientific studies. EDTA is a natural 

amino acid that eliminates dangerous blockages from your veins and 

arteries - blockages that prevent blood and oxygen from reaching your 

heart and brain helping to reduce your risk of a heart attack. In a 

study conducted by Dr. Norman Clarke M.D., a cardiologist and Chief 

of Research at the Providence Hospital Detroit, several hundred 

patients with chest pains and plaque-filled arteries were given EDT A. 

The results were absolutely amazing: 95% of them made a dramatic 

recovery and experienced remarkable improvements in their health. In 

another study, published in the Journal of Chronic Diseases, 100% of 

patients who used EDTA for 90-days saw a reduction in their bloodpressure levels. In addition, 70% experienced reductions in their 

cholesterol levels too. 

Furthermore, according to Dr. Michael Janson, who's been treating 

heart patients with EDT A for many years, 90% of his patients report 

remarkable relief from chest discomfort as a result of EDTA treatment. 

And according to Dr. Gary Null, Ph.D., founder and director of the 

Nutritional Institute of America, "EDTA brought relief to more than 

93% of patients suffering from heart disease and it can help avoid 

bypass surgery in 85% of cases. Thousands of stories from patients 

and physicians support its effectiveness and safety." 

Clinical studies of isoflavones show up to 82% of participants 

suffering from urgent, frequent urination and leakage improved control 

of their bladders as quickly as a week. 

In an eight week clinical study, this new pumpkin seed extract worked 

far better at strengthening the bladder and urinary tract. · As a result, it 

slashed frequent urination and leakage up to 57%. 

· Soy isoflavones have been the subject of thousands of studies

published in leading medical journals and books over the past several

decades.

It works like nothing we've ever seen before three clinical trials

Page 4 of7 

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document success (the gold standard in clinical research.). Together, 

this dynamic duo rapidly reduced the number of frequent urinations 

and episodes ofleakage. Just take a look at the cutting-edge research . 

. . In a clinical study, participants reported a quick and dramatic 

reduction in urinary frequency and leakage. 

The improvement in urinary frequency, leakage and sleep statistically 

increased with the duration of the study, indicating a steady 

improvement when taken longer than six to eight weeks. Participmts 

in a Clinical Study REDUCED Nightly Frequency and Leakage 79%! 

In one clinical study, participants experienced an average of 7 .3 

episodes ofleakage at night. After just six weeks, the number dropped 

to 1.5 episodes - that's an amazing reduction in leakage and 

frequency! 

Vinpocetine is an all-natural extract from the periwinkle plant. Even a 

very small dose has been shown to naturally relax the smooth muscle 

of your bladder without the side effects of prescription drugs. In a 

small clinical trial in Germany [sic] patients who did not respond to 

pharmaceutical drugs had some astonishing results. An incredible 

58% improved bladder function. These patients reported: 

0 Less urgency to go 

0 Less frequency going 

0 Overall less leakage. 

Can BladderEZE help me with my symptoms of Urinary 

Incontinence? YES! BladderEZE gives you a proprietary blend of the 

best, scientifically documented natural bladder and pelvic muscle 

strengthening ingredients in every capsule. It has never been easier to 

regain bladder control and lessen frequency and leakage day or night 

while saving money. 

Cut Your Risk of Bladder Leakage and Frequent Urination in Half 

Research published in the National Health and Nutrition Examination 

Survey examined 1,961 women. They found those with vitamin D 

levels in the normal range experienced a 45% reduction in risk of 

urinary leakage. Another study in the Journal of Endocrinology and 

Metabolism found vitamin D works by strengthening the bladder's all 

important detrusor muscle. 

BladderEZE gives you natural bladder strengthening ingredients 

clinically researched to dramatically reduce a woman's frequent 

urination and leakage day or night in as little as seven days. 

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Neupathic Neupathic was formulated to support healthy nerve endings and help 

ease some of the following issues associated with nerve endings: 

• Burning

• Tingling

• Itching

•Numbness

• Constant coldness

• Swelling and heaviness

• Cramps and restlessness

This "Perfect" Nerve Pain easing pill combines special nutrients to 

restore circulation and soothe nerve pain associated with diabetes! 

Studies show that there IS a natural, effective treatment for diabetic 

nerve pain! 

A "perfect" nerve pain supplement that was formulated from the 

ground up to improve your circulation and ease the numbness, 

tingling, itching, burning and swelling from excess fluid trapped in 

your legs. 

If you have diabetic nerve pain, you could suffer with any or all of the 

symptoms below. 

Shooting pain 

Burning 

Pins and needles 

Electric shock-like pain 

Extra sensitivity 

Numbness 

Throbbing 

Tingling 

Stinging 

Stabbing 

Radiating 

Neupathic was specifically formulated with 6 distinct.nutrients to help 

address ALL these issues and more. 

If your own legs and feet are swollen, inflamed, heavy, tired, achy or 

numb regardless of anything else, your legs need some help from 

Neupathic. 

"Great reduction of pain. No more nerve pain in my feet. I also 

hardly notice any leg cramps. This product is great!" Ruth J. 

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PUBLIC 

''My circulation is now much better."" -Marion M. 

"No burning, stabbing pain. No more stiffne~. More energy. Move 

better. Neupathic is fantastic. I love it! It should be available at the 

drug store." Naomi R. 

"Neupathic isa great 'miracle-like product' which starts working the 

very first day you use it. 1ben it continues to control your pain every 

day. My feet have began [sic] to feel normal. Neupathic has 

improved my life. My nerve pain is gone and I will continue to take 

Neupathic until my numbness is gone too!" - Gloria R. 

04My feet no longer bum, especially after an hour or so ofinactivity. I 

definitely feel more comfortable." Margaret J. 

Already, thousands ofpeople have tried Neupathic and LOVED the 

soothing results. They literally tell stories ofamazing relief from their 

agonizing symptoms within just days of use. 

Neupathic is recognized as one ofthe more powerful natural nerve 

painreliefoptions available. 

Finally, our review of advertising submitted to the FTC by consumers indicates that 

Whole Body Supplements markets BladderSecur by making bladder control and related health 

representations similar to those made for BladderEZE, and markets NeuroCare by making 

diabetic nerve pain and related health representations similar to those made for Neupathic. For 

these two products, please submit the evidence defendants possess and rely upon to substantiate 

that these representations are true. In addition, ifdefendants do not possess clinical testing of 

BladderSecur and NeuroCare, or ofan Essentially Equivalent ProduC4 as that term is defined in 

th:! Order (asopposedto testing ofindividual ingredients), please so state. 

Ifyou have additional questions, please contact me at (202) 326-2098 or at 

rfrislzy@ftc,eov, 

Sincerely, 

Robert M. Frisby 

CC: DEbrief@ftc.gov 

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FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 4/14/2021 | OSCAR NO. 601202 | PUBLIC
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Attachment 4 

7 
3/9/2021 https://www.medscape.com/viewarticle/465994_print 

FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 4/14/2021 | OSCAR NO. 601202 | PUBLIC PUBLIC

www.medscape.com 

Naturopathy: A Critical Appraisal 

Kimball C. Atwood IV, MD 

Two naturopaths were recently appointed to the US Medicare Coverage Advisory Committee (MCAC).I1

I This contradicts the

conclusions of an inquiry made by the US Department of Health, Education, and Welfare (HEW; now the Department of Health 

Abstract and Introduction 

Abstract 

"Naturopathic medicine" is a recent manifestation of the field of naturopathy, a 19th-century health movement espousing "the 

healing power of nature." "Naturopathic physicians" now claim to be primary care physicians proficient in the practice of both 

"conventional" and "natural" medicine. Their training, however, amounts to a small fraction of that of medical doctors who 

practice primary care. An examination of their literature, moreover, reveals that it is replete with pseudoscientific, ineffective, 

unethical, and potentially dangerous practices. Despite this, naturopaths have achieved legal and political recognition, including 

licensure in 13 states and appointments to the US Medicare Coverage Advisory Committee. This dichotomy can be explained in 

part by erroneous representations of naturopathy offered by academic medical centers and popular medical Web sites. 

Introduction 

and Human Services), the department that houses Medicare itself. 

In 1968, naturopaths asked HEW to consider Medicare reimbursement for their practices. The department conducted an 

investigation and chose not to do so. Its report concluded: 

Naturopathic theory and practice are not based on the body of basic knowledge related to health, disease, and health care 

that has been widely accepted by the scientific community. Moreover, irrespective of its theory, the scope and quality of 

2 turopathic education do not prepare the practitioner to make an adequate diagnosis and provide appropriate treatment. ! r

These conclusions are still valid. Thirty-five years later investigators from Simon Fraser University in British Columbia reported 

similar findings: 

In our research for this chapter, we provided naturopaths and their professional associations ample opportunity to refute 

the conclusions of several major commissions of inquiry over the years that deemed their therapeutic rationale lacking in 

scientific credibility. None of our informants was able to convince us that the field had taken these earlier critiques to heart; 

in fact, precious few seemed to recognize that a problem still exists. [O]ur own bibliographic searches failed to discover 

any properly controlled clinical trials that supported claims of the profession, except in a few limited areas where 

naturopaths' advice concurs with that of orthodox medical science. Where naturopathy and biomedicine disagree, the 

evidence is uniformly to the detriment of the former. 

We therefore conclude that clients drawn to naturopaths are either unaware of the well-established scientific deficiencies of

naturopathic practice or choose willfully to disregard them on ideological grounds. 1

31 

What follows is a summary of the current state of "naturopathic medicine." Much of it comes from the position papers and other 

articles on the Web site of the American Association of Naturopathic Physicians (AANP); from the Textbook of Natural Medicine,

the only general textbook of the field, coedited and largely coauthored by one of the Medicare appointeesI4,

5I; and from the 

most visible naturopathic school, Bastyr University in Kenmore, Washington, where the coeditor of the Textbook was founder 

and president and where the other new MCAC appointee is associate dean. Thus, it reflects the health beliefs of these 2

appointees and of the uppermost levels of "naturopathic medicine." 

Brief History and Current Status 

https://www.medscape.com/viewarticle/465994_print CCX-C Att. 4 at 1 1/8 
3/9/2021 https://www.medscape.com/viewarticle/465994_print 

"Naturopathic physicians" are a recent manifestation of the field known as naturopathy, the origins of which were in the 19thFEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 4/14/2021 | OSCAR NO. 601202 | PUBLIC PUBLIC

century German "natural living" movement. Early naturopaths objected to contemporary medical advances, such as the germ 

theory and vaccinations, but espoused the "water cure," fasting, herbs, homeopathy, colonic "detoxification," and other popular 

methods of the era. 

The content of the field has changed little since then, but the trappings have become modern. A subset of naturopaths now 

seeks to distinguish itself from "traditional naturopaths": it professes to practice "a distinct form of primary health care," 

according to the official definition on the Web site of its national organization, the AANP.I6I At the National College of

Naturopathic Medicine in Portland, Oregon, "naturopathic physicians" are described as 

... primary care physicians, most of whom are in general private practice [and] trained to be the doctor first seen by 

the patient for general healthcare, for advice on keeping healthy, and for the diagnosis and treatment of acute and 

chronic conditions. 171 

"Naturopathic doctors" (NDs), as they also call themselves, state that they have received training appropriate to the practice of 

medicine, including a basic science curriculum equivalent to that taught in medical schools. This training occurs at 1 of 4 schools 

in the United States or 1 in Canada, each of which offers a 4-year, on-campus curriculum but no significant hospital or residency 

experience. Four of the schools are not attached to larger universities; the fifth, the University of Bridgeport College of 

Naturopathic Medicine in Connecticut, is owned by Reverend Sun Myung Moon's Unification Church. 

These naturopaths are now licensed in 13 states (Alaska, Arizona, California, Connecticut, Hawaii, Kansas, Maine, Montana, 

New Hampshire, Oregon, Utah, Vermont, and Washington) and the District of Columbia. Their scope of practice is typically 

limited only by prohibitions against performing major surgery and prescribing controlled substances.18I In all of these states they

are free to make broad claims of medical expertise. In Washington, an "every category of provider" law forces private insurers to 

reimburse naturopaths.I9I 

The Naturopathic Belief System 

Naturopathic beliefs -- including those of "naturopathic physicians" -- are rooted in vital ism, the pre-20th-century assertion that 

biological processes do not conform to universal physical and chemical principles. Naturopaths describe a "healing power of 

nature," which is compromised by modern medicine.11°I They state that they "treat the cause of a problem, rather than to merely 

eliminate or suppress the symptoms:•I6I They state that they treat "the whole person." They state that they can "boost the

immune system" with herbs and homeopathic preparations. They profess knowledge about preventive medicine that is, 

implicitly, unknown to medical doctors, public health experts, nurses, nutritionists, and others. They profess special expertise in 

nutrition and in the use of "natural remedies" made from animal, vegetable, and mineral sources. 

Naturopaths invoke a few simplistic theories to explain the causes of disease. These include the actions of ubiquitous "toxins" 

(including most pharmaceuticals); widespread food allergies; dietary sugar, fat, and gluten; inadequate vitamin and mineral 

intake; epidemic candidiasis; vertebral misalignments; intestinal "dysbiosis"; imbalances of Qi; and a few others. To diagnose 

these entities, naturopaths use an assortment of nonstandard methods, among which are iridology or iris diagnosis, which holds 

that the entire body is represented on the iris of the eyel11I; applied kinesiology, by which an allergy to a food is detected by 

placing the food particle in one hand of a patient and observing a resulting weakness in the other; hair analysis for alleged toxins 

and vitamin and mineral deficiencies; electrodiagnosis, which can purportedly detect parasites and other problems by measuring 

the skin's resistance to a tiny electric current; "live cell analysis"; "pulse" and "tongue" diagnosis; and others.I12•

131

Naturopathic Treatments 

Naturopathic treatments include colonic irrigation (enemas) and fasting for "detoxification," hydrotherapy (wrapping part or all of 

the body in wet towels), homeopathy, acupuncture, chiropractic manipulation, aromatherapy, arduous dietary regimens, 

intravenous vitamin C, hydrogen peroxide and ozone, whole enzyme pills, herbs, desiccated animal organs, and other "natural 

remedies." Naturopaths sell these preparations to their clients at a profit, a practice that is both formally approved and joined by 

the AANP.114-

161 

How does this translate into the practice of naturopathic medicine? The following recommendations and practices are 

representative: 

• The repudiation of standard treatments of streptococcal pharyngitis,I17I acute otitis media,I18I and other childhood

infectious diseases, offering instead homeopathy, hydrotherapy, and "natural antibiotics" (eg, herbs such as

Goldenseal).

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• Affiliation with the antivaccination movement.11UJ

• The repudiation of standard treatments of asthma, offering instead, for example, a hydrogen peroxide bath to "bring

extra oxygen to the entire surface of the skin, thus making the lungs somewhat less oxygen hungry" or "gems and

minerals ... worn as jewelry, or placed around the home in special places."1191 This quotation is from "Articles

written by Naturopathic Physicians for the general public" (on the AANP Web site). The author is listed as a "senior

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editor of the Journal of Naturopathic Medicine, the official publication of the AANP."

• Recommendations, by the Bastyr University AIDS Research Center, for treatment of HIV-positive patients with St.

John's wort and garlic (both of which have been shown to reduce blood levels of highly active antiretroviral therapy

agents), "acupuncture detoxification auricular program," whole-body hyperthermia, "adrenal glandular,"

homeopathy, "cranioelectrical stimulation," digestive enzymes, colloidal silver, and nearly 100 other dubious

methods.120,21 1

• Warnings against proven medical and surgical treatments for hypertension, hyperlipidemia, and atherosclerosis,

while instead recommending herbs and EDTA chelation.1221

• The insertion of endonasal balloons, followed by their inflation in the nasopharynx, to "release tensions stored in

the connective tissue and return the body to its original design," thus curing learning disorders and a host of other ,24 problems.1 1 23

• Treatment of the acute stroke patient for at least 20 minutes with an "ice-cold compress ... over the carotid arteries

under the jaw bone on the neck" (which "may even abort the stroke") and subtle energy medicine.1251 The author of

these recommendations is listed as a "senior editor of the Journal of Naturopathic Medicine, the official publication

of the American Association of Naturopathic Physicians."

• The early detection of multiple sclerosis by "pulse" and "tongue" diaijnosis, such as to effect a cure by

hydrotherapy, homeopathy, acupuncture, diet, and other methods.12 I The author of these claims is Chief Medical

Officer of the Southwest College of Naturopathic Medicine. 

• The prevention and cure of breast cancer by an assortment of nonstandard tests and "supplements."1271 The author

of these claims "has lectured regularly at the Canadian College of Naturopathic Medicine on breast health and

stress management."

• The treatment of cancer of the prostate with "electrical current in the form of positive galvanism, applied

transrectally."1281 This recommendation is from "Articles written by Naturopathic Physicians for the general public"

(on the AANP Web site). The author is Chief Medical Officer of the Southwest College of Naturopathic Medicine.

• Ubiquitous "toxin" claims, including antifluoridation statements, warnings against most proven pharmaceuticals, and

the assertion that "25% of Americans suffer from heavy metal toxicity. 111291

• "Natural childbirth care in an out-of-hospital setting" using a "naturopathic approach [that] strengthens healthy body

functions so that complications associated with pregnancy may be prevented_"[?]

• Nearly 100 nonstandard uses for vitamin C recommended by the Textbook of Natural Medicine.141

• The promotion and sale of "dietary supplements" for virtually all complaints.

Naturopaths have not subjected their basic tenets to critical scrutiny, apparently because they are already convinced that they 

are correct. For example, the AANP position paper on treatment of streptococcal pharyngitis, offering no supporting evidence, 

makes this claim: "naturopathic physicians ... have been successfully treating Strep pharyngitis with very low incidence of 

poststrei:>tococcal sequelae, using various natural antibiotics, and natural immune enhancing therapies, for close to one hundred 

years ... "1171

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A 1999 survey of the small number of NDs in Massachusetts, performed by 2 investigators from Children's Hospital in Boston, is 

consistent with these findings. They reported that only 20% of those surveyed would recommend that parents have their 

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fJo�dren vaccinated and that only 40% would refer a 2-week-old infant with a temperature of 101 ° F for definitive medical care.

Implications for Medicare 

In an interview for the Seattle Times, one of the new MCAC appointees offered examples of how he might affect the process of 

selecting therapies for Medicare coverage: 

[The new appointee] said he plans to push for more emphasis on prevention and health promotion. He also wants 

well-proven and cost-effective alternative techniques to be covered by Medicare. 

Examples could include natural ear-infection treatments for infants and acupuncture treatments for those suffering 

sports injuries or drug addiction, he said. 1

11

Naturopathic literature suggests that by prevention and health promotion this Medicare adviser is referring to "detoxification," 

"cleansing programs" for "food allergies" and "candidiasis," enemas, "constitutional" homeopathic preparations, and so forth. 

"Natural ear-infection treatments for infants" are not only unproved but are implausible and dangerous. Acupuncture treatments 

for sports injuries are unlikely and unproven, and acupuncture for drug addiction has been convincingly disproved.I31I

Elsewhere, the same appointee recommends a flower pollen extract for benign prostatic hy2ertrophy,I32I an "intranasal douche

with hydrastis tea" for bacterial sinusitis,I

33I a "general bowel detoxification diet" for autism,!34I and oral bromelain (a protein

extracted from pineapples) for the "lumpy skin around varicose veins."I35I For cervical dysplasia and pelvic inflammatory

disease, he recommends "vaginal depletion packs," 1 by 3-inch cotton tampons containing a tar-like mixture of botanical oils, left 

in place for 24 hours at a time and repeated weekly.I36I

Formal criteria require that appointees to the MCAC be "from among authorities in clinical and administrative medicine, biologic 

and physical sciences, public health administration, health care data and information management and analysis, the economics 

of health care, medical ethics, and other related professions:•I37I How were the 2 naturopaths selected? On February 18, 2003,

I sent a letter to Thomas A. Scully, the Administrator of the Centers for Medicare & Medicaid Services, making points similar to 

those in this article and implicitly asking that question. There were 30 cosignatories.* Mr. Scully had not replied as of December. 

*Lee S. Anderson, Marcia Angell, Seth Asser, Robert Baratz, R. Christopher Barden, Stephen Barrett, Heather Brock, Carl E.

Bartecchi, Henry N. Claman, E. Patrick Curry, John E. Dodes, Bruce L. Flamm, Laura J. Fochtmann, Timothy Gorski, Saul

Green, Arthur P. Grollman, James J. Kenney, Jeffrey M. Lohr, Janice Lyons, Peter Madras, Frederick L. Merian, Steven Novella,

Arnold Reiman, John A. Robinson, Barbara Rockett, Francis X. Rockett, Linda Rosa, Wallace Sampson, Sally Satel, Gerald

Weissmann

Dissent From the White House Commission on Complementary and Alternative Medicine Policy 

Two dissenting members of the recently adjourned White House Commission on Complementary and Alternative Medicine 

Policy warned, in a letter to Department of Health and Human Services Secretary Tommy Thompson, of the problems 

introduced by official endorsements of naturopaths and other "complementary and alternative medicine" (CAM) practitioners: 

Vulnerable Populations 

Patients will often resort to "CAM" practices, modalities and practitioners upon the diagnosis of a debilitating, chronic 

or terminal condition. Recent Senate hearings have documented the special vulnerability of the elderly [emphasis 

added] on fixed-incomes to these phenomena. 

[CAM practitioners] are not positioned for equivalency with conventional primary care providers. Efforts to equate 

their degree of training, or the scientific basis of their practice, with that of the designated primary care specialties 

puts the public at risk of receiving unvalidated and non-evidence based primary care . 

... "CAM" "health promotion" and "prevention practices" also include preventing disease by "balancing qi," 

"eliminating parasites and toxins," "cleansing the liver" and/or by "cleansing the blood" via a multitude of supplements 

and questionable practices. Our uncritical acceptance of "CAM" wellness and health promotion can be interpreted as 

an endorsement of these claims. It is absolutely unclear what role, if any, "CAM" practices play in preventing disease 

and to what extent patients are burdened with useless treatments and products in their pursuit of "wellness." 

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In sum, generic pronouncements about "CAM" neither serve the public interest nor protect the public health. It is 

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essential to separate the effective from the ineffective, the safe from the unsafe and to contextualize these practices 

against conventional modalities before [emphasis added] any of them can be recommended for incorporation into the 

Nation's healthcare system. 1

381

Even if Medicare itself successfully resists the efforts of its new advisers, their appointments are already being trumpeted to the 

40 public as evidence that the federal government considers naturopathic practices to be valid_l39. J This will likely help

naturopaths in their pursuit of universal state licensure and reimbursement by health insurers. Because licensed health care 

providers determine their own standards of care,1411 it would be detrimental to the public if naturopaths were successful in this

pursuit. 1

421

Comment 

"Naturopathic medicine" is an eclectic assortment of pseudoscientific, fanciful, and unethical practices. Implausible naturopathic 

claims are still prevalent and are no more valid now than they were in 1968. The current wave of unexamined CAM fascination, 

however, appears to have helped naturopaths convince some that they have special abilities and that they are trained to be 

primary care physicians. 

Most treatises on naturopathy that physicians and the public are likely to read are uncritical promotions that simply restate what 

naturopaths claim. Yet these views are found on the Web sites of academic medical centers and the large commercial sites for 

the general public. For several years, the Caregroup/Harvard Medical School Web site urged readers, without further comment, 

to "please consult your local telephone yellow pages" for "naturopathic physicians" and other CAM practitioners.1431 The Web

site of the University of Washington School of Medicine portrays "naturopathic physicians" as well trained to practice "primary 

care integrative natural medicine," with a "scope of practice [that] includes all aspects of family and primary care, from pediatrics 

to geriatrics, and all natural medicine modalities." It further asserts that "naturopathic diagnosis and therapeutics are supported 

by scientific research drawn from peer-reviewed journals from many disciplines:•1441 None of these statements can withstand 

rigorous scrutiny. 

lnteliHealth, a joint venture between Harvard Medical School and Aetna, promises to "[provide] credible information from the 

most trusted sources:•1451 As recently as the spring of 2002 lnteliHealth stated, "NDs are trained as family physicians"; they

"treat the whole patient, not just the disease symptoms"; they "successfully combine so many therapies"; "Naturopathic doctors 

throughout the country are becoming increasingly recognized as primary care providers.'' The article suggested that if the reader 

were already consulting an ND, she might reasonably choose not to see an MD.1461 When lnteliHealth replaced this article with a

new one, it did so without explanation, failing to warn readers of the dangers of having trusted the previous information. The 

replacement article, moreover, approvingly describes naturopaths as "[concentrating] on principles of holistic health (pertaining 

to body, mind and soul), prevention and self-care.'' It does not address the serious shortcomings of the field.1471

WebMD, the parent corporation of Medscape, offers this: 

A naturopathic doctor often combines many different complementary therapies to enhance the body's natural vital force. 

A licensed naturopathic physician (ND) attends a 4-year, graduate-level naturopathic medical school and is educated in the 

same basic sciences as a medical doctor (MD). 1

481

Naturopathic medicine is used for health promotion, the prevention of disease, and treatment of illness. Most naturopaths 

can treat earaches, allergies, and other common medical problems. Naturopathic medicine tries to find the underlying 

cause of the person's condition rather than focusing solely on symptomatic treatment. 1

491

The WebMD treatise also advises, "Naturopathy should not replace conventional methods of treatment for certain conditions," 

1

491 but how is the patient to know? The assumption is that naturopaths will act responsibly, but they have neither the medical

training nor the requisite scientific skepticism to do so. On the contrary, they portray themselves as primary care physicians. The 

unwary reader might conclude that naturopaths are trained to provide "conventional methods" when appropriate, but NDs have 

had only a small fraction of the training of primary care MDs. Instead they have been steeped in homeopathy and other highly 

implausible, ineffective practices. It is unlikely that readers of WebMD and the other sources mentioned here will appreciate this 

dichotomy. 

The National Center for Complementary and Alternative Medicine (NCCAM) has had 3 naturopaths on its advisory council in the 

past 3 years.1501 It proposes to conduct research into CAM methods advocated by "licensed/certified CAM practitioners (Doctors

of chiropractic, naturopathy, [etc.l).''1511 The NCCAM advises citizens who consult CAM practitioners to ask about licensure or

certification early in the process.1"521

Like the NCCAM, WebMD also admonishes readers to seek only licensed naturopaths: "without licensing standards, individuals 

with little or no formal education may proclaim themselves naturopathic physicians without medical school education or board 

testing.''1481 The clear message is that such licensing implies competence. There is, however, no evidence that "educated"

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naturopaths -- the most prominent of whom provided the clinical examples for this article -- are more competent than others.191 If

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anything, "traditional naturopaths" (ie, those who did not attend the "approved" schools) may be less of a threat to public health 

because they do not pretend to be primary care physicians. 

Graduates of campus-based, 4-year naturopathic programs who have passed a standardized examination may demonstrate 

consistency from one practitioner to the next. But that says nothing about the validity of what they do -- which can be determined 

only by reference to the facts of nature and by rigorous testing of biologically plausible claims. At least one leading CAM 

researcher has acknowledged this fact: 

Those who believe that regulation is a substitute for evidence will find that even the most meticulous regulation of 

nonsense must still result in nonsense. 1

531

Conclusion 

This is the first article in a mainstream medical journal that critically summarizes the field of "naturopathic medicine." If 

physicians continue to consider naturopaths and other "alternative" practitioners as inconsequential -- or, if the only articles on 

CAM that most physicians read are uncritical -- pseudoscience will continue to make inroads into patient care and health policy. 

The information presented herein illustrates why official sanctioning of naturopaths as health care providers, including their 

appointments to the MCAC, should be considered unwise. 

References 

1. Perry N. 2 naturopathic physicians from Bastyr appointed to Medicare advisory group. Seattle Times. January 27, 2003.

Available at:

http://archives.seattletimes.nwsource.com/cgi-bin/texis.cgi/web/vortex/display?

slug=bastyr27e&date=20030127&query=pizzorno (requires free registration). Accessed: December 2003.

2. HEW Report on Naturopathy (1968). Available at:

http://www.q uackwatch.com/01 QuackeryRelatedTopics/Natu ropathy/hew. html. Accessed December 2003.

3. Beyerstein BL, Downey S. Naturopathy. In: Sampson W, Vaughn L, eds. Science Meets Alternative Medicine: What the

Evidence Says About Unconventional Treatments. Amherst, NY: Prometheus Books; 2000:141-163. Available in draft

form at:

http://www.sfu.ca/psychology/groups/faculty/beyerstein/research/articles/21 Naturopathy.doc Accessed December 2003.

4. Pizzorno JE, Murray MT, eds. Textbook of Natural Medicine. 2nd ed. London, England: Churchill Livingstone; 1999.

5. Reiman AS. Book review of Pizzorno JE and Murray MT, eds. Textbook of Natural Medicine, 2nd ed. (Op cit). Presented

to the Massachusetts Special Commission on Complementary and Alternative Medical Practitioners; January 2001.

Available at:

http://www.quackwatch.org/01 QuackeryRelatedTopics/Naturopathy/relman1 .html. Accessed December 2003.

6. AANP Position Paper on "Definition of Naturopathic Medicine." Available at:

http://www.naturopathic.org/naturopathic_medicine/definitions.html. Accessed December 2003.

7. Modalities. National College of Naturopathic Medicine Web site. Available at:

http://web.archive.org/web/20020222231837 /http://ncnm.edu/modalities.html. Accessed December 2003.

8. The Alliance Legislative Workbook. Available at:

http://www.allianceworkbook.com/. Accessed December 2003.

9. Atwood KC, Ryder WJ. Minority Report of the Massachusetts Special Commission on Complementary and Alternative

Medical Practitioners, In Opposition to the Licensure of Naturopaths. Reported to the state legislature January 2002.

Available at:

http://www.state.ma.us/reg/currenU2002medp/rminor.pdf. Accessed December 2003.

10. Atwood KC, Barrett S. Naturopathic opposition to immunization. Quackwatch. 2001. Available at:

http://www.q uackwatch.com/01 QuackeryRelatedTopics/Natu ropathy/i mmu. html. Accessed December 2003.

11. Iris analysis 1-2. Bastyr University course catalogue 2002-2003, p. 101. Available at:

http://www.bastyr.edu/ftp/Catalog02-03.pdf. Accessed December 2003.

12. Atwood KC. Naturopathy: A Monograph. (Previous title: Naturopathy: Not Recommended for Licensure in

Massachusetts.) Presented April 2001 to the Massachusetts Special Commission on Complementary and Alternative

Medical Practitioners. Available at:

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13. Barrett S. A close look at naturopathy. Quackwatch. Available at:

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http://www.q uackwatch.com/01 QuackeryRelatedTopics/Natu ropathy/naturopathy. html. Accessed December 2003.

14. AANP Position Paper on "Medication Sales by Physicians." Available at:

http://www.naturopathic.org/positions/medications.html. Accessed December 2003.

15. Mothernature.com announces strategic alliances with two healthcare organizations. Press release. January 2000.

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http:! /web.archive .org/web/20010109011600/http://www. natu ropath ic. org/PressRelease/MotherNatu re. html. Accessed

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16. Frequently Asked Questions about the MotherNature.com partnership with AANP. January 2003. Available at:

http://web.archive.org/web/20020219113703/http://aanp.neUMotherNatureFAQ.html. Accessed December 2003.

17. AANP Position Paper on Treatment of Strep Pharyngitis. Available at:

http://www.naturopathic.org/positions/strep.html. Accessed December 2003.

18. Pizzorno JE, Murray MT, eds. Textbook of Natural Medicine. 2nd ed. London, England: Churchill Livingstone, 1999:1463-

1467.

19. Kane E. Asthma. Available at:

http://web.archive.org/web/20010219051416/http://www.healthy.neUaanp/Library/articles.lay/EK.Asthma1 .html. Accessed

December 2003.

20. Standish LJ, Ruhland JF, DiDomenico B, Gmeiner K. HIV/AIDS: naturopathic medical principles and practice. In:

Pizzorno JE, Murray MT, eds. Textbook of Natural Medicine. 2nd ed. London, England: Churchill Livingstone; 1999:1277-

1302.

21. See also: Bastyr University AIDS Research Center: Current Scientific Activities (2003). Available at:

http://www.bastyr.edu/research/buarc/activities.asp. Accessed December 2003.

22. Pizzorno JE, Murray MT, eds. Textbook of Natural Medicine. 2nd ed. London, England: Churchill Livingstone, 1999:1078-

1082.

23. Barrett S. Be Wary of NeuroCranial Restructuring (NCR). Chirobase Web site. Available at:

http://www.chirobase.org/06DD/ncr.html. Accessed December 2003.

24. Bastyr University course catalog, 2001. "Binasal Specifics." Available at:

http://web.archive.org/web/20010423130039/http://bastyr.edu/catalog/courses/default.asp?PID=PM. Accessed May

2003.

25. Kane E. Stroke. AANP Web site. Available at:

http://web.archive.org/web/20010817032330/http:l/aanp.neULibrary/articles.lay/EK.stroke.html. Accessed December

2003.

26. Kruzel T. Multiple sclerosis. Available at:

http://www.scnm.edu/news/uploads/ms.pdf. Accessed December 2003.

27. The Healthy Breast Program. Available at:

http://www. healthybreastprogra m .on .ca/healthy_ breast_program _ home _page. htm. Accessed December 2003.

28. Kruzel T. Cancer of the prostate: a naturopathic perspective. AANP Web site. Available at:

http:! /web.archive .org/web/20020314041713/http://www. healthy. neUaa np/Li bra ry/articles. lay/ProstateCancerTK. html.

Accessed December 2003.

29. Pizzorno JE, Murray MT, eds. Textbook of Natural Medicine. 2nd ed. London, England: Churchill Livingstone, 1999:438.

30. Lee CCL, Kemper K. Homeopathy and naturopathy: practice characteristics and pediatric care. Arch Pediatr Adoles Med.

2000;154:75-80.

31. Margolin A, Kleber HD, Avants SK, et al. Acupuncture for the treatment of cocaine addiction: a randomized controlled

trial. JAMA. 2002;287:55-63. Abstract

32. Pizzorno JE, Murray MT, eds. Textbook of Natural Medicine. 2nd ed. London, England: Churchill Livingstone, 1999:1151.

33. Pizzorno JE, Murray MT, eds. Textbook of Natural Medicine. 2nd ed. London, England: Churchill Livingstone, 1999:1145.

34. Pizzorno JE, Murray MT, eds. Textbook of Natural Medicine. 2nd ed. London, England: Churchill Livingstone, 1999:1141.

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Emeritus and Associate Dean to Lend Expertise on Natural Medicine. HealthWorld online. 1/27/03. Available at:

http://web.archive.org/web/20030210053952/http://healthy.neUscr/news.asp?ld=6539. Accessed December 2003.

40. Testimony by a naturopath at a public hearing of the Massachusetts Joint Health Care Committee regarding Bill Number:

MA03RHB 2603. An Act Providing for the Registration of Naturopathic Doctors. May 28, 2003.

41. Studdert DM, Eisenberg DM, Miller FH, Curto DA, Kaptchuk T J, Brennan TA. Medical malpractice implications of

alternative medicine. JAMA. 1998;280:1610-1615. Abstract

42. Atwood KC. Testimony opposing naturopathic licensure in Massachusetts. May 28, 2003. Available at:

http://www.quackwatch.org/01 QuackeryRelatedTopics/Naturopathy/atwood .html. Accessed December 2003.

43. Caregroup/Harvard Medical School Center for Alternative Medicine Research and Education. Available at:

http:! /web.archive .org/web/20010802182032/http://www. bid me. harvard .ed u/med icine/camr/index. html. Archived

November 2001.Accessed December 2003.

44. Complementary and Alternative Medicine (CAM): Naturopathic Medicine. Web site of the University of Washington

School of Medicine, Department of Family Medicine. Available at:

http://www.fammed.washington.edu/predoctoral/CAM/naturmed.html. Accessed December 2003.

45. About us. lnteliHealth Web site. Available at:

http://www. i ntel i health .com/I H/i htl H/WSI HW000/356/356/236954. html?d=d mtContent. Accessed December 2003.

46. lnteliHealth. Naturopathic medicine. Available at:

http://www.intelihealth.com/lH/ihtlH/WSIHW000/8513/28801.html. Accessed March 2002. [This page is no longer

accessible, but the identical treatise on naturopathy is available at:

http://www.consultdrminas.com/eng/04_medinfo/topics/07 _alternative/12.php Accessed December 2003.]

47. lnteliHealth. Naturopathy. Available at:

http://www.intelihealth.com/lH/ihtlH?d=dmtContent&c=347253&p=~br,IHWl~st,85131~r,WSIHWOOOl~b,*I- Accessed

December 2003.

48. WebMD Health. Naturopathic Physician (ND). Available at:

http://my.webmd.com/contenUhealthwise/118/29437. Accessed December 2003.

49. WebMD. Naturopathic Medicine. Available at:

http://my.webmd.com/contenUhealthwise/83/20752. Accessed December 2003.

50. Atwood KC. T he ongoing problem with the National Center for Complementary and Alternative Medicine. Skeptical

Inquirer. 2003;27:23-29. Available at:

http://www.csicop.org/si/2003-09/alternative-medicine.html. Accessed December 2003.

51. Project concept review. NCCAM Web site. Available at:

http://nccam.nih.gov/research/concepts/consider/crpg.htm#skipnav. Accessed December 2003.

52. 5Selecting a complementary and alternative (CAM) practitioner. NCCAM Web site. Available at:

http://nccam.nih.gov/health/practitioner/index.htm. Accessed December 2003.

53. Ernst E. The role of complementary and alternative medicine. BMJ. 2000;321 :1133-1135. Abstract

© 2003 Medscape 

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1 IN THE UNITED STATES DISTRICT COURT 

2 CENTRAL DISTRICT OF CALIFORNIA 

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4 

5 FEDERAL TRADE COMMISSION, 

6 Plaintiff, Case No. 

7 v. CV03-3700-DT (PJWX) 

8 BRASWELL, et al., 

9 Defendants. 

10 

11 

12 VOLUME I 

13 

Monday, June 6, 2005 

Hoevet & Boise, P.C. 

16 1000 S.W. Broadway, Suite 1500 

17 Portland, Oregon 97203 

18 

20 

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22 

For The Record, Inc. 

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1 P R O C E E D I N G S (9:33 a.m.) 

2 VIDEOGRAPHER: We are now on record. My 

3 name is Gordy Foster. I work for Limelight Video 

4 Productions at 2636 Northwest 26th Avenue in 

Portland, Oregon. This deposition is being held on 

6 June 6, 2005, in Portland, Oregon. 

7 The case 

8 caption is the Federal Trade Commission versus 

9 A. Glenn Braswell, et al., pending in the

U.S. District Court for the Central District of 

11 California, Case Number CV03-3700-DT, and in parens 

12 PJWX. Deponent is Ernest M. Kloetzli -- Kloetzli? 

13 THE WITNESS: Kloetzli. 

14 VIDEOGRAPHER: Kloetzli. You told me and 

I spaced it out. 

16 And would the parties present please 

17 identify themselves for the record? 

18 THE WITNESS: Ernest M. Kloetzli. The 

19 person who you're asking questions to. 

MR. FRANKEL: Good morning, this is 

21 David Frankel for the Plaintiff Federal Trade 

22 Commission. 

23 MS. LEE: I'm Christine Lee, also with 

24 the Federal Trade Commission. 

MS. NORTHRUP: Linda Northrup 

For The Record, Inc. 

(301) 870-8025 - www.ftrinc.net - (800) 921-5555

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1 Q. Did you ever pay a subscription to -­

2 A. No, never did.

3 Q. Do you know anyone who paid for a

4 subscription to the Journal of Longevity? 

A. No, I don't.

6 Q. You mentioned before the lunch break that

7 you were provided with studies anywhere between one 

8 inch and sometimes two inches thick from the 

9 companies as you were preparing advertisements; is 

that correct? 

11 A. Before -- before I started, yes. I mean, 

12 before I started a project. 

13 Q. First, who -- who gave you those

14 materials? 

A. Many times it was -- it was Ron Tepper or

16 Audrey Beim, his administrative assistant. The 

17 actual compilation of those packages is the 

18 responsibility of Inna Yegorova, who's like their 

19 director of like science. That was her thing. I 

forget the name of her assistant, but they were the 

21 ones who pulled together all the scientific stuff. 

22 Q. How do you know that Inna Yegorova put

23 together the materials? 

24 A. Do you mean, did -- I think a couple

times she handed it to me. Her title would indicate 

For The Record, Inc. 

(301) 870-8025 - www.ftrinc.net - (800) 921-5555

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1 that she was responsible for the compilation. Not 

2 maybe -- not maybe for the physical collation, 

3 but -- but certainly for the compilation. 

4 Q. And do you recall any occasions where she

handed to you what those products were that you were 

6 about to write ads for? 

7 A. No. It could have been -- it could have

8 been anything. I don't remember specific stuff. 

9 Q. Did you have any discussions with

Inna Yegorova about the materials that she gave to 

11 you? 

12 A. Sometimes I would. And she would maybe, 

13 you know, write something down. If I had a a 

14 hair-brained idea about something she would you 

know, she would be the first person to put her thumb 

16 down on it. 

17 But, quite frankly, she's -- well, 

18 she's it's a Russian name, and she has a very, 

19 very, very, very heavy accent, and it's -- it's 

oral communication is very difficult with her. 

21 True. 

22 Q. Of the -- of the things that she wrote

23 and gave to you, do you still have copies of that? 

24 A. No. No, I would have put that in the --

and returned that or either trashed that with the --

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1 He walks -- he wears a white coat. He 

2 walks around. And, I don't know, he's an expert. 

3 I've never really had any professional dealings with 

4 him. And I've sat in a room with him and he knows 

me by face, and he's very polite and everything, 

6 but ... 

7 Q. How is his role different from the role

8 of Inna Yegorova? 

9 A. That's a good question. I think 

that -- I think that he is more maybe -- his 

11 background is more -- is more like in research. 

12 Where Inna's background is more scientific. She 

13 goes through -- through professional journals and 

14 and compilates -- you know, compilates studies on 

individual ingredients and formulas. And keeps 

16 records of those things so that when writers are 

17 working on things, you know, that she can -- you 

18 know, she can dish that out. 

19 But that's a very good question. I think 

there's a pretty subtle difference. Now that I 

21 think of it, you know, who was that masked man? He 

22 was a man in a white coat. He was with a 

23 research Ph.D. from the University of Chicago. 

24 Impresses me. 

Q. Do you know what his subject -- the

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1 subject of his Ph.D. is in? 

2 A. No. It was in the I think it was in 

3 the -- on the masthead of the of the Journal of 

4 Longevity. In fact, he's written -- he's written 

some articles in there. And it was -- and under his 

6 byline was a short bio describing some of his stuff. 

7 But I was I was very impressed with him. 

8 Q. To your knowledge, has Mohammad Kahlid

9 ever reviewed ads that you have drafted? 

A. I don't know that.

11 Q. And the same question with respect to the

12 Inna Yegorova? 

13 A. I think that -- that -- that Inna has,

14 yes. Because I can remember definitely sometimes 

when you're doing a project at the last minute or 

16 there's a deadline the compression means that you're 

17 able to see more clearly different people's roles. 

18 And I remember there was a case where I 

19 delivered something to Ron, and then he immediately 

made a Xerox of it and got it over to Inna, and then 

21 Inna had some concerns by -- by that afternoon. 

22 That was a -- so I guess she does. I'd 

23 just never seen -- seen her in the process 

24 of approval until that point. 

Q. Did Inna Yegorova convey her concerns

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1 with something she wrote directly to you? 

2 A. I think she -- she had a question of

3 something if something was -- was phrased, if that 

4 was the best way to like phrase from a purely 

scientific thing, from a purely scientific 

6 viewpoint. 

7 I think that -- that -- that she raised 

8 some -- some issues. I was -- with -- with both Ron 

9 and I, but I don't recall what those were. You have 

different levels. You have the scientific approval, 

11 you have a legal approval, you have a marketing 

12 approval. And all of those address totally 

13 different concerns. 

14 Q. Did she express her concerns directly to

you, or did she express her concerns to you through 

16 someone else? 

17 A. Well, I was sitting there, too. She 

18 expressed those to like -- to like Ron, and to me 

19 because I was sitting there in the office, too. 

Q. So there was a meeting of the three of

21 you? 

22 A. Yeah, it was one of those impromptu

things. And someone sticks their head in with 

24 with a draft, and in saying -- saying, well, 

maybe -- I forget what her issue was, and I guess it 

For The Record, Inc. 

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CCX-C Att 5 at 7
PUBLIC 

FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 4/14/2021 | OSCAR NO. 601202 | PUBLIC

6 Attachment 

9 
FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 4/14/2021 | OSCAR NO. 601202 | PUBLIC
FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 4/14/2021 | OSCAR NO. 601202 | PUBLIC
FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 4/14/2021 | OSCAR NO. 601202 | PUBLIC
FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 4/14/2021 | OSCAR NO. 601202 | PUBLIC
FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 4/14/2021 | OSCAR NO. 601202 | PUBLIC
FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 4/14/2021 | OSCAR NO. 601202 | PUBLIC
FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 4/14/2021 | OSCAR NO. 601202 | PUBLIC
FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 4/14/2021 | OSCAR NO. 601202 | PUBLIC
FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 4/14/2021 | OSCAR NO. 601202 | PUBLIC
FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 4/14/2021 | OSCAR NO. 601202 | PUBLIC

PUBLIC 

Attachment 7 

10 
FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 4/14/2021 | OSCAR NO. 601202 | PUBLIC

PUBLIC 

DECLARATION OF RECORDS CUSTODIAN 

PURSUANT TO FED R. EVID. 803(6) AND 902 (11) 

1, .Jt1na \JG.JicRov& , being of legal age, do hereby declare and depose as 

follows: 

1. I am a custodian of records for Inna Yegorova ("Yegorova"). In that capacity, I 

am responsible for the compilation and maintenance of records pertaining to business Yegorova 

conducts. Due to my responsibilities, I have personal knowledge of the manner in which the 

subpoenaed party creates and maintains records of the business that it conducts. 

2. On January / 6, 2021, in response to a subpoena dated January 4, 2021 issued by 

the Federal Trade Commission, Yegorova transmitted to the Federal Trade Commission true and 

accurate copies of records maintained by the subpoenaed party consisting of __J}__ pages, and 

0 files. 

3. The docmnents produced are tme and accurate copies of records maintained by 

the subpoenaed party in the regular course ofbusiness. 

4. The records produced in response to the Federal Trade Commission's subpoena 

were made at or near the time of the occurrence of the matters and transactions set forth therein 

by, or from information transmitted by, a person with knowledge of those transactions. 

4. Yegorova made the records produced to the Federal Trade Commission in 

response to the subpoena as part ofregular practice in its regularly conducted business. 

S. Y egorova kept the records produced to the Federal Trade Commission in response 

to the subpoena in the course of its regularly conducted business. 

I declare under penalty of perjury that the foregoing is true and correct under 28 U.S.C. § 

1746(2). 

Executed on J"a11vaR:J' lh; , 2021, in rJ PB lk~,'1p c, California. 

Prmted name 

-OIA!A.'.J--R Inn,li (,r,n<.' ;(Lt}..!£_____ 

Title ofrecords custodian '(I 

CCX-C Att. 7 at 1 
FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 4/14/2021 | OSCAR NO. 601202 | PUBLIC

PUBLIC 

Attachment 8 

11 
FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 4/14/2021 | OSCAR NO. 601202 | PUBLIC
FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 4/14/2021 | OSCAR NO. 601202 | PUBLIC
FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 4/14/2021 | OSCAR NO. 601202 | PUBLIC
FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 4/14/2021 | OSCAR NO. 601202 | PUBLIC
FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 4/14/2021 | OSCAR NO. 601202 | PUBLIC
FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 4/14/2021 | OSCAR NO. 601202 | PUBLIC
FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 4/14/2021 | OSCAR NO. 601202 | PUBLIC

UNITED STATES OF AMERICA 

BEFORE THE FEDERAL TRADE COMMISSION 

OFFICE OF ADMINISTRATIVE LAW JUDGES 

PUBLIC

In the Matter of 

HEALTH RESEARCH LABORATORIES, LLC, 

a limited liability company, 

Docket No. 9397 

WHOLE BODY SUPPLEMENTS, LLC, 

a limited liability company, 

KRAMER DUHON, 

individually and as an officer of 

HEALTH RESEARCH LABORATORIES, LLC 

and WHOLE BODY SUPPLEMENTS, LLC. 

DECLARATION OF CELIA GARRETT 

PURSUANT TO 28 U.S.C. § 1746 

I have personal knowledge of the facts set forth below and am competent to testify about 

them. If called as a witness, I could and would testify as follows: 

I am a United States citizen over the age of 18. I received a bachelor’s degree from Duke

University in 2019. I am employed by the Federal Trade Commission (“FTC”) as an Honors

Paralegal in the Bureau of Consumer Protection. I have held this position since September of 

2019. My business address is 600 Pennsylvania Avenue, N.W., Mail Drop 9528, Washington, 

DC 20580. On October 29, 2020, I was assigned to work on the case In the Matter of Health 

Research Laboratories, Docket No. 9397. 

1. In February 2021, I was assigned to review mailer advertisements in this matter, Health 

Research Laboratories, as well as in two other FTC matters: A.S. Research, LLC and 

Mile High Madison Group, Inc. I selected advertising materials marketing products 
FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 4/14/2021 | OSCAR NO. 601202 | PUBLIC

____________________ 

PUBLIC

connected to the companies named in the three identified matters. 

2. In the Adobe Acrobat program, I identified certain PDF pages of the various mailers and 

then individually extracted each page to a new file. I converted these pages to image files 

that I then pasted into a PowerPoint file. I captioned each image with the name of the 

matter connected to the image and associated mailer. A true and accurate copy of this 

document is attached as Attachment A. 

I state under penalty of perjury, that the foregoing is true and correct. 

Executed on April 13, 2021, in Washington, DC 

Celia Garrett 
FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 4/14/2021 | OSCAR NO. 601202 | PUBLIC PUBLIC

Attachment A 
FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 4/14/2021 | OSCAR NO. 601202 | PUBLIC

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CCX-D 
FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 4/14/2021 | OSCAR NO. 601202 | PUBLIC Meet Dr. Richard Cohen, M.D. 

Richard Cohan, M.D. Is a nationally recognlnd medlcal expert. As a specialist in nutritional medicine, he brings over two decades 

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is permanent. 

s. .,,,,,, _ fff1 •• ,.,,, 111 

(continued) 

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..,l,ooJ 11.1 b.wouo ... 

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But ii ....,u\•odl 1 

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FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 4/14/2021 | OSCAR NO. 601202 | PUBLIC The Japanese Smoke & Have High Bl ood Pressure - Yet, Low Cholesterol! Japanese have lowest incidence of heart attacks in the world. Why? Whatareyourtreatmentoptions The Miraculous Solution in Japan: Black Garlic is the ... lorhcartd1•08se? Black Garlic "perfect human health food." !~"=~~!i~:1 tactorthat pub pi ~~':'~~t:!;!.:!'::Wo!~~~ Black Garlic antioxidant capacity is the '"""'"'"""••-"""""""~.,,.,, ""-"'"""'~""""'""c~"'- best in more than 300 kinds of food! guaranloc lowcrwlg cholesterol, bbod pre1sure, Popidu In A.°'1n Qil,lnc,. Bladt Gwlii: II fermmt~ uodcr ortr\l~ldes(atypeotfat. ln ,,ourblood). a OmMh DW:Veryittilwiggle room for food ~~=-~'::Z:-!:~0~::~~tu choi~. only 10% of c:alorie,s can come from ••Pffl-trved frull. w;ed.wa lJ)keora:iod.lmtllt.andd>c :~~nbepriceyfor pl'OOI.ICe,wtloleg1 1\8, garlke&incu ~ iaed tobrrwtea. 

• ~O.t:Notastn.lcl!Jred 

diet. wit's up to you to figure out on your own 

how ma") calories you need to eat lo lcce or 

ma.ntul well# & how actrta )'OIJ 'II be. 

• Veg., DNe Nci animal products allowc11:li 

evendal1yand eggs.Takesworitttl 1111911"11 

youQ«:$ufficienta.rmurtsotMYnutrienta. 

Limit!ldoptionsfor ealir1Qod., may r~irea 

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PHYSICAL ACTIVITY 

Reconnn!lrdsd exercise e.l least 30 mimdes a 

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GENETICS 

Many heartconclo)n;are pasoed on from 

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andprepIre yourbodyand your mindforany 

patentialupa,mingc:hallenge:swlth natun1I 

pl'8¥entatN'8solul:ioos. 

STATIIIII 

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pain, Iver d8Il11Qe, kioney fa~ure. eYell death. 

A Natural Supplement lmprowfng LivH 

Bladt Gulicgalnnl. popularity ail:u Hhoukl UllivenVy 

p~JinitiS1..&1.ki.waw..-d tt..t lll.,di;Gclic hM• 

lume6.daleffed(m.lunmulcd.l,,iathe•ooir -thc1aiu.1 

iaeaJdi w .. coaduttrd 1Ulll!IM!itcprik.anddldnotykJd the 

1m1c raull.. 

m.di:Gu:11., m111tbe fumtllltdlnpretllecoo.dli.l0.1116owi60 dily5 

with ilK;Kallli!~ thcloqrcr iti:nncm. lt~ 18 k1Ddt <:L 

aunloo acids Qttded by the bulll,IUI body. 

--

e...-wili!-up in aria.II am Ind. kl unlic:illhy hart c:DDdiiom. 

m.di; Ganic:hdp.bsplioodvnnh b.rrlufTNto,ffft.ol1moolhflc,wr, 

whidicaildaddn,•symp;01D11oi£alleu.e, Hiuyal8olnhibil.clildu111 

blndlns whk.b 11; raponilbla br arte.rtal plaqut bin.tt\on. 

................ cart... ..... ,,.., ......... 

Dbd!: Garllc\r.bringte«tdlnbolbpcpul,itionw&Anddmicaltrl.lh 

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....................... .........., BJ.Ks: Garll.chelpl mlilll:al..D. bl!&lltryli.oodr--wv. chnlai1eml .lW 

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Som.tf.wtilallOfma.lfunctiono(Whu.man bodyand hdpf toJqJLllatc 

bl.oods~ But. bdJr&t inputnlubaKDiitivityto imalia, and C::&11 

oftcntrlggfflhc body's mtlll3I fuooloncipwnpl.ng !n1ulln. 'Ib.Jsaa 

QWllli 111cttbolk ryndront~. whkh •YY furtlwr dew]np lllfo h\p1 blood 

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- -

The miraculousjoint-p · 

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Thcyh&\'Coneo!thelonge5tandbealthiest lifespans 

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Thefudllationwithalongmdhealthylik 

ill reflec.1:ed intheir hlstory wbell! it isreported 

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For over 2,100 years, their 

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their~rlyh~tory.d:t.e~ 

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ago Judah Tbe 

rrevokedag.awtthe 

rful, well-armed Seleucid 

of Judea andem.crgcd 

rimH..2,1.00)T.&DRgo, 

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t defeatedanentire 

' I 

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il 0Irao 

re

b

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Health Research Labs (Nordic Cl

CCX-D 
FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 4/14/2021 | OSCAR NO. 601202 | PUBLIC On the other hand, heart/ cardio medications are notorious for their ugly side effects, because those chemicals just aren't good for your body. llalurally ,1111181:t stl'8llglhen your llearl and alterles. .. Reply now 11111% ltsk lree lor 811-llllluml Ullmale Hean Formula! If you knew how truly debilitating a heart attack or stroke would be for you, taking away your ability to walk, talk, eat by yourseU, or even move ... You would take this matte r very seriowly. It would make your decision to reply now for our Ultimate Heart Fonnula a no-brai ner. It is simply among the most potent,. natural heart formulas on the market today! As a medical doctor, I'm 100% confident it can support your heart and artery health to help lower your cardio health risk. So you don't have to worry about the damage it will do to your body. Don't wait ... Reply now to join our thousands of .satisfied users and get special, first time-buyer-only low pricing. You can also get a greatly discounted price on the perfect companion produc~ and FREE Shipping! Don't roll the dire on your good health or yow life! Take this easy step now to keep your heart strong and your arteries clear. 

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HRL005080 

r- ...... - , ~ .• ' 

ljf.i Wi "Early clinical studies show if ;,+-:, %J 

you 

b

oost nitric oxide formation 

School of Medicine in the 

brain, you can support 

memory and learning:• 

---D, Laws lgncno, Ph.D Nobel Prize .,-.,,..i I'rofe=r 

of~ogyd//,eua.4SdwJo/ofMet.icine 

'1.1. '/bm you start mil:placlogyotir byl .•• 

• J\.l eatalfati&:Ue ~t. -1. f( VY forpttingfacaandnamefl ••• orbaYingth0:.1e • Fo,pfl,1- [!J'- "'Renlor moment!" - aR you secretly woodering ••• • Difficulty t:oncentrating · .:_I 1 :..,, 

Am I losing it?" 

Mw. folks over40 assume mcotal decline i-sjusl a 

oa1ural part ofoging- and ao they jun put up with the 

foq,>elful=s ••• meul<ll fug •• .and brain dram. 

• Poor recognition or 

fac:a and numbers 

• Blue moods 

lhmlenooomg<:y<)<IW 

IIy N-0 Sangua,ol ml SEe 1he But research oonductcd by Nobel Pri:ze winner Dr. 

Louis lgnarm reveals mmtal decline may just \:l!i )'OllJ' 

brain'11ayformoreN-O! 

diO'~ hcallhy bluotl circulslion ron have oo your 

brain! And 1he good IhiDg ~-•• 

Without adequate .levels ofN-0-blocxl flow to 

your brain can plummet- and that can CllllllC smilar 

symptoms as a~ mental decline. So ifyoo're 

cxpcricncing ... 

... you don't have to wait long to sec ifN-0 

Sa.ngue,:JOI is wolldng foryru. Most folks apincncc a 

noticeable improvarent-mrtfng with dleyery tint 

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Now that N-0 Sangucnol is 

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have a scientifically srudied fumw. 

la to unleash the power ofN-0 fur 

healthy circulation ... higher energy 

levels._ sharper thinkillg... deeper 

blClll:b.ing. .• and a healthier and longer life! 

Here's to scicncc-ba.scd healing 

rrrirack,, 

'h.... ~JLG-.,~ 

Dr.AllenGmm 

P.S.1 forgot to ircntioo one important lbing: When you respond wilhin 

7 days - I've got a special gift i,, 

sendyou. 

In:nlizethismaybe~firsttime 

you've mdly lhuugbt about nitric 

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EAT your way to heelChrer N-O 

l=l,! 

··::useN-Oforopti- ·~·;:;~

n~ 

a... _ _ · 

mwn""'ltsl tti 

Turn DOWN 

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Secret cause of Aleep-deprtvation! Cwld dais he why yoo'rc 

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CCX-D 
FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 4/14/2021 | OSCAR NO. 601202 | PUBLIC Qualities of Black Garlic Antioxidants Helps Maintain Healthy Blood Pressure Heart Protection Supports Healthy & Balanced Cholesterol Anti-Bacterial Circulation Support Strong Immunity "'Black Garlic Botan icals relievedtf1e pain i11 my legs andfeet. My circulation is better than it lwsbeen in a long time. T11isproduct is amazing and I 

can't live witliout it '" ~ John J.• 

You can improve your life now, too! 

"'Black Garlic lielps 

me !Jeep better at nigfzt - 1 can't believe 

liow rested I feel ill 

t}ie mornings now!'" 

- MichelleM." Try it free risk-free today - only pay if you see results. 

More Black Garlic Benefits 

HEALTHY WEIGHT MANAGEMENT 

"A thicker waistline increases heart attack risk." says 

Nieca Goldberg, MD. Stomach fat is linked to high 

blood sugar. increased blood pressure, and raised levels 

of triglycerides, a ll of which are major risk factors fo r 

heart disease. Belly fat is also called visceral fat, which is 

closer to internal organs, and can be related to hormones 

- that's why many women start seeing their tummies 

thkken during menopa~. 

Black Garlic is an excellent addition to a healthy diet 

and exercise for overall health. Sustainable weight 

management is the most sensible and practical option for 

anyone concerned about heart health. 

IMMUNITY BOOSTER 

Black Garlic addresses inflammation. boosts immune 

function. and is toxic to i.nvading bodies. The allicin in 

garlic, a sulfur-rich compound, is a powerful weapon 

against harmful conditions and promotes overall health. 

Black Garlic contains twice the antioxidant punch of fresh 

garlk, because of the fermentation process. This makes it 

an ideal health booster for every season. 

.h,,t 2 cap- 8D1.y! 

AGE DEFYING 

Black Garlic is a great energize r and helps prolong 

a healthy lifestyle! It also helps repair damaged skin 

with double the amount of antioxidants than regular 

garlic. Like rust attacking metal, free radicals eat away 

at cells and destroy them, causing the aging effect. 

Blade Garlic positively impacts cellula r immunity, 

causin a reJuvenated appearance. 

DETOX 

Black Garlic acts as a blood purifie r and cleanses 

the body in general. It has antibacterial, anli-fungal 

properties that c reate a hostile environment for 

Candida albicans and can decrease bacteria linked to 

stomach ulcers. Your gut is also known as yow second 

brajn, because the health of your gastrointestinal 

system is extremely important to your overall 

wellbeing. Black Garlic supports cell regeneration 

and alkalinizes your body to form a habit at resistant 

to takeover. It also features abWldantly rich oxygen for healthy cell activity. so you can discover eve n more wond.:rful overall health with just 2 capsules per day! 

HEALTH RESEARCH LABS - BREAKING NEWS CARDIOVASCULAR ISSUE HRL004994 11 

winning discovery 

your legs, feet, and 

-with one dose! 

Japanese researchers report 

up to an 85% decline in N-0 by the 

time you reach your 70s 

N~::!\!:~:=aoo 

org;m uf your body, from your 

musck:s lo your hr.tin. ·n,is chemical tells arteries 10 .. relax" which 

allows more oxygen into ti:.sut:S 

by increasing blood flow. 

lJnfortunatt:ly, most adults 

Ove'l'40don't produce enough. ln 

f.x.:1, by~ lime you reach your 

70s and 80s,you'rc 1xoducing up 

your blood vessels - cal.led your 

endothelium. And as it turns out... 

.. .it's N-0 that sends 

the signal for your 

arteries to OPEN 

and RELAX! 

Discovering that N•O is lhc 11.t,")' 

to opening blood vessels is nothing 

short ofa breakthrough. I len:'s why ... 

... One of the fin;t things we learn 

in medical school is UJC critical impor1ance of BLOOD FLOW. If your 

blood is sluggish and trickling -

then your body woo't work properly. Why? 

Ek:caust: nulrit:nl-ric.h, o,i.ygenutOO blood can't get to your organs 

- so they start ta wither away. Yes, 

starve! 

l to II swgi..~g 85% less mak­ ing you \'efY susceptibk: for high 

blood pressure, cardiovascular 

di.sc:lseandstrolce. 

One oft11e best U1ing.,. you can 

do for your vascular system and 

hCJ.lth is to ensure optimal levels 

of nitric oidde. Aod now you can 

aJ<ln.ss N-0 ck:fidcncics with a 

single, money-saving dose of an 

astounding new breakthrough 

-~ I) 

g "' ]_ .,- -

] M R 

O 10 20 JO 40 SO {,(l XI 

Age[•)'>loi 

That means ... 

• FEELING NUMBI Legs ... arms ... 

and oti1t:r parts Jose sensation 

several times throughout the day 

- and night! 

e aJI.D HANDS AND FEETI Without healthy blood Oow to your 

extn::mities temperature regulation is downrigltt difficult! 

• NltFUl. SWEUJNG! Legs, feel, 

and ankles become swollen and 

puffy due lo the built.I u1> of excess fluid in the tissues. 

e VARICOSE VEINSI Valves pum~ 

ins blood are not working properly, resulting in burning, cram~ ing and throbbing in your legs. 

• .NIINTS HURl1 l.acJ.: nf oxygcnah.-d blood means LJlTLE nutricnts an: getting to those joints! • And so much more! Now that scientist• uncovered the power of N-0 to open blood vessels and deliver crilicol nutrients and oxy­ bten to your entire circulatoiy system CtN11im1i!U on ne.r:I page. .. The all-natural breakthrough for limb problems caused by poor blood flow: t/Throbbing legs VCold hands and feet t/ Numbness and tingling 

CallTolHree 1-800-750-0326 I 3 

~----- 

icant de

deep w

The molecule is hya]uron

component of your synovial 

Hyaluronic acid is an ama

molecu1e able to 'f<§1 up to ~ 

water. This make11Tdeal for 

Yet as you age. levels ofhy

body and your joints decreas

sagging ,kin and painful join

This is why, since the earl

acid has been injected into jo

molecules• and boost synovia

But these shot.a arc pain

only work on the joint treate

temporary relief. 

That", why rm <>cit.a to 

hyaluronic acid tn a pill ... 

(Co

Oral hyaluronic 

popular pain re

In a clinical study, 70 patien

pain took oral hyaluronic a

medication to see which one 

reducing pain and swelling. 

After just 30 days, more t

taking oral hyaluronic add h

However, only 2 out of 10 pe

medication experienced red

And for severe swelling. 

found in the hyaluronk acid 

w11 1~ offectlvo It qut

Compare that to 9 out of 

pain medication who still ha

12) ltllli: L.tll.CIIIU-~2IXII 

For fastest ordering, call TO

Encore Plus Solutions 

Health Research Labs (Nordic Clinical) A.S. R

CCX-D 
FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 4/14/2021 | OSCAR NO. 601202 | PUBLIC BUT ... I call Neupathic the "perfect " solution because it was formulated based on the latest medical research, and recen t science has 

now shown these 6 ingredients get the job done 

better, and work better~-

The fact is, you need powerful nerve 

treatment at the cellular level to help you. And 

you will NOT find any other formulas, with this 

proven nutri ent lineup, or at this precise, high 

dosage . \Vhich leaves a.Jl other products lacking 

for effective relief. 

Already, thousands of peopl e have tried 

Neupathic and LOVED the soolhing resuJts. 

They literally tell stories of amazing relief 

from their agonizing symptoms within just 

days of use . 

lloll't wait any longer ... 

Stay a step ahead of tlntfmg, 

llumin!, nmnbness and more! 

The reason why Neupathic is 1he best choice 

today for long-lasting nerve reliefis because it 

More Comments from 

Happy Neupathic 

Customers ... 

"I used to f•el Ilk• 

someone was putting a 

needle In my toes. I no 

longer feel that and I am 

quite happy!'' 

-Wil/arrfC. 

"Neupathlc has helped to 

relieve the nearopathy In my feet." 

-HenryF' 

~lll'lfYllly. IIH:;e.vere.1'1Be1S W&tl re.1l 1t1i1.JIIS. 

contains the 6 KNOW nerve pain, and lower 

leg heaJth hel ping nutri ents. 

You'll help quiet those agitated nerves, and 

help restore comfort, health aod mobility to your 

legs, hands and feet! 

v_ou area 

per[l;!t.:l candidi:ile 

for Neupathic if: 

find it 

difficult to walk 

because you can't 

feel lhe ground 

under your feet. 

can't stop 

the itching, burning, 

Slabbing, pins and 

needles or tingling in 

your leg-; and feet. 

hands, 

feet and legs ore 

always cold. 

don't ge1 a restful night's sleep 

because of pain and discomfort. 

It's hard to keep your balance on unsteady 

legs and feet. 

It's hard to walk, move, exercise, bend, or 

enjoy your favorite activiti es. 

feel trapped and immobile because of 

your unhealthy legs and feet. 

condition is worsening ... as your pain 

gets worse and your legs become m(lre swollen 

and heavy and tired. 

If this describes you r life today, I urge 

you to lry the sootfiing relier that comi:s 

from. ~eupathic! 

Neupathic will go to 

W(lrk fast to senle 

your paini ease your burning and tingling and numbness, and restore health and mobility to 

your legs. 

10 • Soothe Diabetic Nerwe Pain and More! Call Now Toll Free 111--711 -SOS 

HRL005045 

Proof ... Proof ... and more 

scientific PROOF! N-O 

Sanguenol not only WORKS 

-it WORKS FAST! 

Laboruto1y tests - as well as human trials-show the in• 

gredients in N-0 Sang1>Cnol 

de.liver antioxidant protection fmm 

all 5 types of free radicals - starting 111 as litllc as two hours! 

Please know this: In the scientif• 

ic field this k:vcl of antioxidant 

protcc.1ion - ftom all 5 typcS of 

frtt radicals-i1 nothlni short of 

AMAZING! Herc's the: proof; 

Ooe stutly 1-cpone<l SpccO"B in 

N-0 Sangut:nol signillC3ntly reduced: 

SUptrmdde free radicals -

which attack your arteries and 

tlam3gc0NAI 

Nydrulq1 - the fn:c radical:,; 

that dumagc ccllulur membrane. 

Ptnaxynltrlll - which break 

Double Your N-0! 

i 10 ,,, -

:I' ' 

Q •" I 

N-0 Sanguenol can doWle 'iOAJE 

nltrk oxkle lewis, allowing you,­

blood to f!o'!W like a rtverl 

20 / Joumnl of Circulatory flealtl1 

down collagen in I~ sk in and 

~ini:::lct oxyaen fn:e radicals 

lhat wreak h3voc with cholesterol - al!.O dropped within 

hoors! 

And take o. look ut thi!!.: 

ti All S type, of free r•dluli 

found in lhc mitochondria -

which is your cell's nucleus -

were reduced by 42% within 

2hoors! 

ti Cellular inftamm.tlion caused 

by Al,L5frttradiarl typn ­

dropped as mocha! 35%1 

ti TNCREASF.O cell's 11bility to 

consume healthy oxygen levels 

hy a whopping 1411/. - with• 

Int hour! 

But hen:'s even MORE good 

news ... 

Spectra" actually 

BOOSTS N-O levels 

by up to 99%! (Yes -

nearly DOUBI.ED!) 

I' ll be lhe first to admit lhat 

I wanted Spcctr,t"" in my N-0 

Sa11gucnol formula because of 

lhc antioxidanl PUNCH it de· livers t.o free radicals. In my scientific opinion - NOTHiNG 

lh,t-"-IIG!bteo........rli,oftroaclllid(-.g........._ 

TWl~•,_,...-dl,jmdillJ!O'i",IIM.<in:OI""""" .. 

Most pain reliever.; give y

simply mask pain ... or trick y

you have less pain. But they 

cause of your pain. And they 

(think ncedles) ... or have dan

can rip up your stomach or w

That's not acceptable for 

orme. 

So we've turned to Mole

that work at the molecular l

joint cartilage an<l tissues. 

NJ you'll see, MPRs rest

joint lubrir.ati.ng fluids and 

pain in a way that's far supe

found in natural or convent

And which MPR is deliv

It's the FIRST ot th

painkillers ... a pill 

that's been a "life-res

all across A

Just imagine ¢ting reli

N

At ag

bega

of his 

Airer 

one w

50% 

After 

was g

more 

Injections! Georges. 

of Pennsylvania needed 

to sec his doctor for 

knee iajcctions. Now 

he gratefully writes, 

•1 have noticed an 

improvement in my 

knee joints after using 

Synovia for only one 

month. My right knee 

is feeling much better 

without needing shots.• 

nM!lal /BJtl,._,-,_ Mf1-,- dhs-.d,

Encore Plus Solutions 

Health Research Labs (Nordic Clinical) A.S. R

CCX-D 
FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 4/14/2021 | OSCAR NO. 601202 | PUBLIC We have been flooded with testimonials for our Ultimate Heart Formula! "My blood p~ssure 

Is normal .• Tastes good 

I also have more energy 

and a more stable pulse.­

-John A Jones 

"Ezcellent Results. No Pain! Easy to Take! 

Thank you for the Ultlmate Heart FOl'mula. 

II gives me more energy. It's easy to take, 

has no unwanted side effects. It makes lite 

easier with no pain In my heart. I highly 

~ommend the Ultimate Heart Formula 

to anyone who has h.art problems:."" 

-DBwn SimonetJJ 

"I ha• no huirt problems 

since s tarting Ultimate 

Heart Formula many ,-airs: 

ago. Thank God for the ad I 

read years ago. I am now 81 

and going slrong. Sorry I'm 

bragging now."' -!Acid Miles 

''Most products that we send fcr through the mai l 

do not do what Is claimed. I had PVC's which 

I hated so much. After using the Ul:imate 

Heart Formula I f•I great and am so 

happy."" -Dilrlene H. Juhl 

'1 had occasional rapid heart 

beal!i and irregular heart beats. 

After taking Ultimate Heart 

Formula I ,._I gNat and 

haw felt great since. I have 

..__,""':::....---' been taking this product almos t 

12 months. It's easy to take and quick to work. 

Cof'Nlltnlienee. Taste. Aesul:s."" 

-Fred Memmer 

t Is taken orally. I have 

n f,-- from chest pains 

ce th• s tart. It gives me 

· klenc• wt.n I go to bed 

night that I will awaka to 

I am 85 and was diagnosed 

apse many years ago.-

no longer 

vetowony 

tt.art 

lems. 

father 

chelation for 

the heart­

-Chrlsfine Fbtbins 

"I f-1 moN posl:lw and moN 

active. My art.Ms and lMins 

a~ clear. I feel 50 years old .... 

- JOBfl £ Johnson 

11,-;·-

Vltim11U 

Heart 

,-=::-. 

call Tall-R'ee 811&-462-9386 lor Ullmalt learl Ftrnila lns1anl ai-pll111 drops! 

lrdllllkN.:11 IB&lltsl1'8YV31Y, W3QU¥~1:B)OJwll belhl$1)1tductcr}OUrlllCfleYba:;k. 

PAGE 1DJ JOINT HEALTH NEWS 

Real people have beaten 

pain and gotten their lives 

back with Hydraftexin! 

No mora shoulder 

pain ... 

"lhlclpti11buildillg11J>inlll)'lhaoldm 

aod mm.fur-a awnber ofymn briln 

NUtin&1jru.1JUppl-1regmB.I'm 

ffIYpleutdwithH)'dnr/lwa,·i:aylhoaldef 

baa;ac,1bothc:rc,d moat all Ji'ocelbef;111111iiDSitabool l2 

moathlqo.-

Feels better than she 

did when she was 30 ••• 

"l-78111dtlillwamll(f'll!Mimr.IW 

bdla'-llawhenfwulOlh__."tllO 

aa:-.,UIOOllklbanl.'ywalkbecautc 

ofdle~i:nm,Jdblee.l"'emed(lbl" 

jomiprcdidl.batcmly~tlbsawaymyplinatd 

ttia,ti,ffmm. l i.o«rccaulyandlbcagbla.ybcldco"l 

nccdlllll)'!lllld-~~tberifmellc:amt1-:k!N.,..J 

WVlldn'tbewilllxdlt. ..... 

No mora momlng stiffnessknee pain gone ••• 

"Hydrt:t,/lo:tl,me..»lno\cmgaWl&01"'.tliifanrith 

paiaia.Dl)'kDec..rm71landltlllWtllmllUboordlp.Mlll 

mad.~Godalillk~vm.Icboole_"Ood ~ ",lhlmk.~li::it~him•band.llib~wayit 

bdpeuireplll-myl:rieeby~thcl'JIIO-..liliPd• 

-ll•thcplinididl'wbccnlwn,:Hydraftainbnevly 

11":lycaa.'-

Severa bumlng, 

stiffness, and pain 

in elbow rasolvad ... 

MAbcma,a.,110,J~ 

tlru:ddlt'-"mlDl.-islll'flFf 

efboow-.ItlmCIIIIMll!.modemeal~ 

pa.i.mm-.,uwtll••-bamini!;..iial. Thue 

lmbeto.~~inmydb;nrrC"Ya"sillcd 

A.ftimdQf • • .Jmroclucedp:1Caprolim:tc:aIW 

~blbttalcl~pmbablywork.ma:hmaR 

dfecti'l'tly~daelllk-dlb:ts .• .DtnlJOell:.llaff 

t-lUilit-~lDC&eclbtbkvdofpaia.AJ,.l> 

lbet,niqtmadtlDian.,d)ow~dimmilbedma 

i,ab"decre61m:iwllml wat llk:mgMmia.mdAleYl:!" 1 

.. ,.,,.......,.... 

... ~JW 

From despair to 

hope ... 

"!CYhadli--,.lllifr 

alpufi&I. I'w: lbop riridl 

lnmyi:tt.IW>voryl(IW!m, 

11;1mcdk:atiomllld~ilb 

NSAID1 bcm11e 1:rmc110thn:nwiih 

evmuoer-nJH)ldrrtlaJ,rlllWIDIWlhe~bdwa::11 

~..tdD!p.iE.Jt',acMillymlllk:my~~by 

mnaiQamypaiilml~p,iylmctlm. .... 

BO% healed from 

-..pain ... 

"'.lam.a~oomat:tmllldworit 

OQ~~n.pu1:1addcd111UD 

•tbelipneala.'Ibtre-•.3moalb 

pmcdoftimt:wbcnJcoulduot--­

htotneapanlnoticcdn&f"wilhin 

-11/dtlt.~t:r(>'.EA 

a •'D ofllkinaHydnjlointhatl 

bmlte.paln.l~thatbctwom•-.-l~m:i 

Hp~ 1113'1a1dtflrdl.,._.1hmiflllldiaiptolfm;,• 

foct I am no- aboul-80% 1-1m.-• 

.....,-diw\t(.bmnttldQ,CA 

Zero pain-sleeps like a baby ... 

"lllmyiSO'tl~-,c:w!il=rmpfWlbGlbmk 

of•~Jo1Moroll!mmck110,llqlhitd.il:C>JUWnd 

berq,airm. l llUQhr,,c~lim,it.-l.lhmac:ic:ik:t. 

NS>JlllcmlCldmyal(Jl:l)eCb!l)b1-iandp~DEm:Jlllmoi 

IIPI)'. Hyd-ctJlab,.il dll!IM!Wning-.:udiandpnsm1111Ya"1b: 

-.,.n'aonlywhmfabtwoadlydiacmypul!.gontnnro 

DI.Ip10doc,p-O.- -l'M!Jt.~C:0 

Swea111 by Hytlratlex/n for 

knee pain ... 

"Myhwtudbldaknotpn:,blc:m.Ghr.mmiimaid 

Qondroilia did DOt hdp. He_.. by !be relid.l:{,l:t'<!l'fm,r 

hupoYided t.iln. }19.-M IOOllacmp!Aimnawtacn -r1ill0Ul 

fira&wd.)'trccalt!y ... --'tti.nnmirla;oi.a~ 

- l.oid#.S.~NJ 

Reduced pain, 

stiffness, and 

swelling by 85% ... 

,o11mwm:..,wi1at:.Jr.-=be.lliff 

mdi:.-l.liQatr,..il'vehads;qoy011.my 

[.-l.10tatc~Mlgsb,;s~ 

lbt•h10lidtdl'cdlandgotll'Olriadwtlm'Vlao:..,; 

~lolJl'iliemllbt.l~mlo::ietlarypllic. 

~&lldlhll~UlmyftnglnbyllOO.ltffl(,,,lllllo 

~111bebclp!lllmyatm.-

------

.. 

-------·--···-·---·-~-

Remarlrable case s

No more b

no more in

For yea,s, William B. ofTume

suffered from bone-on-bone a

The pain wu ,o bad, he bad 1

every two month& 

But since taking SynotJia. reli

his,rords, •Ah,olutelywonderful

swelling had disappeared with no 

Thank you-I am back living nor

» Barbara's 

1118 1111181 fo

anc1iu-1 

Barl>ara B. 

knows what it'

bad back. Afte

w1,11 "killing"' h

She took shots and tried every

mxiaunend t.o no avail 

But now she happily reports, 

S!f11(1fM for one and half months

Now, I wake up eveey morning w

"'I've abo bad my knees replao

problems with my knees. I'd r=m

to an)l,ody in pain-bad< pain, sh

poiDL !just re-ordered two bottl

very much." 

12 

Encore Plus Solutions 

Health Research Labs (Nordic Clinical) A.S. R

CCX-D