Sam Stone Flashcards

Please state your name for the record

My name is Sam Stone

What do you specialize in?

I am an expert in chemical engineering and the effects of drugs and other substances on dogs and other domestic pets.

What level of education do you have?

I graduated from Metropolitan University with a master’s degree in chemical engineering.

What is your current occupation?

I’ve been the lead investigator for Petzicon for the past 15 years.

How long have you been working at Petzicon in total?

I’ve been working at Petzicon for over 25 years.

What roles have you held within Petzicon?

I initially started in the chemical division and worked in research and development, testing chemicals for their effects on animals.

Thank you for explaining your background. At this time, I'd like to submit Sam Stone as an expert witness. As an investigator, have you published or shared any findings in your work?

I have written articles and given lectures on the effects of special chemicals for animal health.

What are some of your responsibilities as an investigator?

A large part of my job is to investigate the use of products and their effects on animals.

What happens when an unusual reaction occurs?

I advise the company and all distributors of potential risks. The final decision is made by upper management.

Can you give an example of a specific incident?

Yes. Five years ago there was an issue where improper mixing of a shampoo led to hair and weight loss in dogs.

What was the outcome of that situation?

We had a class-action lawsuit brought against us, but we were not found to be negligent and the matter was resolved.

So moving on, can you walk me through how the investigation process works?

Yes. When an animal has an adverse reaction to a Petzicon product, we launch an investigation to discover the cause.

What are some of the initial steps you take when investigating?

I begin with contacting the owner, in this case, Carmen Capella, to discuss the feeding, care, grooming and general health of the animal.

During this conversation, is there anything in particular that you’re looking for?

I focus on how the product was used; meaning the dosage, any other products used, and the pet’s medical history.

Just to clarify, does Petzicon make its consumers aware of the correct way to use their products?

Of course. On the label of every product we include the directions for how to use it, the expiration date, and all known and potentially harmful effects.

What about the mixing of products?

Yes, we include specific information on how our products should be used alone or in conjunction with other products.

Is there any other support provided to consumers?

We have a customer service hotline for anyone who has questions about our products.

Focusing on Sally’s investigation, what were your initial investigation steps?

At the time I was called to conduct this investigation, Sally’s body was no longer available for viewing.

Since her body wasn’t available, were there any reports you could look at?

Unfortunately, there were no toxicology reports, veterinary reports, nor was a necropsy performed.

How, if at all, did that affect your investigation?

Without a necropsy, we are unable to determine the cause of Sally’s death.

You mentioned contacting the owner before– did you ever meet with Carmen Capella?

Yes, I did.

Could you elaborate on what you discussed?

She mentioned that a trainer groomed Sally for 2 days before her most recent competition, but she didn’t know what products were used.

From your past investigations, have you noticed anything about the products groomers use?

Groomers tend to mix different products, which can lead to adverse reactions.

Moving on, what did M_. Capella report about Sally following the competition?

Sally began itching once they returned home. She assumed it was fleas and washed Sally with a shampoo. When the itching persisted, she applied a flea treatment to Sally’s neck.

Just to clarify, was M_. Capella certain if Sally had fleas?

No. Itching can indicate many conditions, not just fleas.

Would Sally’s persistent itching have any indication about her health?

It suggests that she wasn’t in good health before arriving home, so before the flea treatment would have been used.

You mentioned looking out for the manner in which the product was used–did you and M_. Capella ever discuss this?

She stated that she didn’t use much of the flea treatment. However, Sally’s reaction contrasts this statement.

In what way?

The fact that an adverse reaction occurred within 15 minutes suggests the product was over-applied, which was likely made worse by Sally’s small size.

Did Carmen Capella have any knowledge of the products that she used on her pet?

She assumed the flea treatment was a Petzicon product but didn’t know how old it was and had already disposed of it.

If it was a Petzicon product, would it have stated all the warning labels you mentioned before?

Yes, absolutely. We provide these directions because the product can deteriorate after a year.

Based on your investigation, what is your expert opinion on Sally’s cause of death?

Due to uncertainties like the lack of a necropsy and inconsistencies in product use, I cannot conclude that Sally’s death was caused by a Petzicon product.