AFFIDAVIT

ON THE MATTER OF ESSIAC PRODUCTS

I, Pierre Gaulin, of Broward County, Florida, take oath and declare the following:

1- That I personally talked to Rene Caisse in 1975, but could not obtain the products from her, possible because I was a doctor.

2- That, in 1987, a patient was brought to my office by a confrere, Dr. J.R. Lacroix. This patient was taking Essiac for her neoplastic condition.

3- That, after a lengthy discussion with the patient, the patient stated that she benefited greatly from Essiac. Stressing to her that possibly some of my patients could benefit from this product, I requested the source of her Essiac. She did not want to divulge the source because she honestly thought that if she did, the source would be shut down and she could not continue to obtain the product for herself. I requested the patient to ask the supply source to give me a telephone call. The name given of that person would be Jacques. She promised that she would relay this request.

4- Shortly thereafter (2 days) I received a telephone call from one Gilbert, who was supplying and manufacturing the products since late 1977 or 1978. The patient, to protect the identity of the source, gave a false name.

5- Gilbert and I met soon thereafter, and discussed in general phytotherapy and applications of Essiac. I was told how Gilbert Blondin received this recipe directly from the hands of Rene Caisse. Furthermore I was told that he had this original document written in Rene Caisse's own handwriting.

6- Subsequent meetings were held. Finally we decided to incorporate and make this product available to all who wanted and needed these Essiac formulas.

7- A partnership was made and received the incorporation under Easy-Ac Product Service Ltd., 333 Besserer St., Ottawa, Ont., Canada, and that this company would manufacture the Essiac formulas.

8- During the first year (see #9, why this short period), significant results were obtained from patients being treated with Essiac and other modalities. These cases were medically documented and could stand medical scrutiny.

9- In July, 1988, the F.D.A. raided the premises of Easy-Ac Product Service Ltd. Two inspectors posing as tourists and one inspector's own dying child (leukemia) wanted to purchase one bottle of Essiac (entrapment). I, being away in Alabama, Gilbert, for humanitarian reasons, sold a bottle to the inspectors.

Subsequently, the company and Gilbert and myself were each charged with 16 counts of Manufacturing a drug, Selling a drug, Having in possession a drug for the intention of distribution, and Advertising a drug.

10- A 17 day trial was held and the defense stand was that Essiac was not a drug as charged, but was a food supplement. This defense theory was held constantly as irrelevant and non pertinent. The stand of the defense was a food because the composition of the recipe was 100% natural plants and all are edible as such.

11- After the trial the tribunal reserved judgement for one year before rendering its judgement. On the judgement day, the government motioned the court with an amendment to change all the charges and replace the word drug with the word food. This was allowed by the tribunal. Then the word food became relevant and pertinent to the case. The defense had prosecuted itself.

12- The tribunal, having accepted the government motion, found the company and its principals guilty of: 1- possession of a food; 2- manufacturing a food; 3- selling a food; 4- advertising a food; and were condemned to each pay a one thousand dollar fine, that is, $3,000.00. Guilt was found even in absencia. In my case I was not even in the country at the time of the alleged infractions.

13- The convicted persons are the only ones ever convicted of possession of a food, etc.

14- My case was appealed up to the Canadian Supreme Court, which denied leave to appeal and, therefore, maintained the guilt of the Company and its principals, making them convicted persons in Canadian law. Guilty of possession of a food, etc.

15- In 1988, Pierre Gaulin moved to Florida, with the plan to incorporate Essiac in the USA - Essiac Products Services Inc. (# K 78360 0) - and thereafter applied for and obtained trademark (# 1,625,600).

16- Thereafter the company applied for other countries' trademarks. Mexico, with the Mexico # 452389, and other countries' trademarks are pending.

17- I hereby state and take oath, that Essiac Products Services Inc. is the only company that has the only true, complete, original formulas of Rene Caisse, that is, the decoction, injectables, salve, RMC kidney pills, and enema.

18- That Essiac Products Services Inc. has in its possession, the original formulas written in Rene Caisse's own handwriting, as written and given to Gilbert Blondin.

19- That Essiac Products Services Inc. has the original transcripts from the Ontario Commission of Cancer (1938), the original 55,000 name petition which was presented to the Ontario Government (1938), the original carbon copies of letters and clinical reports of Dr. Emma Carson, original voice tapes of her lectures, numerous newspaper articles (originals and copies), photographs of Rene Caisse's patients and many other documents relevant to the Essiac products, which includes Rene Caisse's clinical and medical reports.

20- I hereby certify that Essiac Products Services Inc., P.O. Box 1387, Ft. Lauderdale, FL, 33301, has the ONLY true, complete original formulas. Therefore one can only deduce that all the other manufacturers, sellers, or presenters of a direct or indirect association would be COUNTERFEITS; FRAUDULENT; DECEITFUL products, with the intent to take advantage of the reputation of the true, complete original formulations of Essiac Products Services Inc.

21- That, as a doctor, I have obtained significant results when treating patients with serious degenerative diseases. These treatments were always made with complete medical history and obtaining a conformation of the patient's condition and status. Furthermore, other modalities have been used as adjuncts to the Essiac protocols and this according to the patient's conformation.

22- That I have used and recommended Essiac products in cases of cancer, AIDS, and degenerative diseases; that I never found any negative side effects with the Essiac products. In certain cases health enhancement was obtained and in other cases regression of the conditions. I have also evaluated some of Rene Caisse's cure patients (a cure is 25 years in remission).

23- That I have reviewed scientific research by Sloan Kettering, Brusch Medical Center, and other research made with Essiac. The deduction of this study is if the right Rene Caisse protocol is followed, one had significant results. If the protocol was modified, the results suffered the errors made in the protocol. Furthermore, a LD50 was made by myself and found that I could not kill rabbits.

24- That I have personally known Rene Caisse's co-worker, Mary McPherson, and her husband, Clifford, and Rene's executor, Mr. Stan Darling, and many other persons in her environment.

25- That I have, in 1988, met with a confrere, Dr. Charles Brusch, in Cambridge, Mass., and that, on numerous occasions, we have discussed the Essiac products. That my confrere, Dr. Charles Brusch, also became my patient in consultation, and consulted with me on other patients which he was treating. That Dr. Brusch told me that he did not know the whole formula of the decoction, the salve, the enema, and the kidney pills, that he had only worked with the injectables and had modified the injectables with Rene Caisse. Dr. Brusch stated to me that he knew of the basic 4 herbs and that Rene Caisse always added other herbs in secrecy. He also stated that the taste and smell of the Essiac products supplied by myself were the same as Rene Caisse's.

26- That Dr. Charles Brusch always obtained the Essiac products from me and this from 1988 until his death in 1993. Furthermore, he obtained products from me for one Patrick McGrail and other patients which he was still following for years. These patients were on Essiac since his association with Rene Caisse.

27- That Dr. Charles Brusch gave an affidavit to the Canadian courts stating his opinion that the Essiac products (Easy-Ac) made in Canada by Gilbert Blondin and myself were authentic and, to the best of his knowledge, were produced in the same fashion as Rene Caisse's, and that it was not a drug, but a food.

28- That, to his knowledge, the Canadian company, Respirin Corporation, never had the whole recipe, this because Rene wanted to see if they would abide with her conditions. To his knowledge, she gave them 4 herbs, which was a tonic, but not the complete anti-cancer formulas. When he was shown the original document of Rene Caisse to Gilbert Blondin, he first acknowledged that it was her handwriting, and, after reading the part on injectables, he affirmed that this was the formula he knew, and therefore satisfied me that it was the whole complete formulations to the 5 basic Essiac products.

Dr. Pierre A. Gaulin