1. Opening Statement on Behalf of Floyd Landis Winner of the 2006 Tour de France Monday, May 14th, 2007

2. In Order To Believe USADA
Floyd, knowing that he would be tested while in the lead or attempting to gain the lead in the Tour
Took Testosterone, a drug that does not have a beneficial effect during a race like the Tour,
In an amount too small to raise his testosterone level above that of the average male
Then entered his system and was metabolized in a way contrary to the known science about testosterone
That in 4 out of the 5 tests alleged to be positive, his screening tests were absolutely normal
That in his 5 confirmation tests, the values vary in a way contrary to the known science about testosterone
That when the electronic files from stage 17 were reprocessed, the results were entirely not reproducible
MOST IMPORTANTLY: That all of the ISL Violations that are at the heart of this case, UTTERLY DID NOT MATTER.
Floyd, Knowing that he would be tested while in the lead or attempting to gain the lead in the Tour, 2

3. In Order To Believe USADA
Floyd, knowing that he would be tested while in the lead or attempting to gain the lead in the Tour
Took Testosterone, a drug that does not have a beneficial effect during a race like the Tour,
In an amount too small to raise his testosterone level above that of the average male
Then entered his system and was metabolized in a way contrary to the known science about testosterone
That in 4 out of the 5 tests alleged to be positive, his screening tests were absolutely normal
That in his 5 confirmation tests, the values vary in a way contrary to the known science about testosterone
That when the electronic files from stage 17 were reprocessed, the results were entirely not reproducible
MOST IMPORTANTLY: That all of the ISL Violations that are at the heart of this case, UTTERLY DID NOT MATTER.
Took Testosterone, a drug that does not have a beneficial effect during a race like the Tour, 3

4. In Order To Believe USADA
Floyd, knowing that he would be tested while in the lead or attempting to gain the lead in the Tour
Took Testosterone, a drug that does not have a beneficial effect during a race like the Tour,
In an amount too small to raise his testosterone level above that of the average male
Then entered his system and was metabolized in a way contrary to the known science about testosterone
That in 4 out of the 5 tests alleged to be positive, his screening tests were absolutely normal
That in his 5 confirmation tests, the values vary in a way contrary to the known science about testosterone
That when the electronic files from stage 17 were reprocessed, the results were entirely not reproducible
MOST IMPORTANTLY: That all of the ISL Violations that are at the heart of this case, UTTERLY DID NOT MATTER.
In an amount too small to raise his testosterone level above that of the average male, 4

5. In Order To Believe USADA
Floyd, knowing that he would be tested while in the lead or attempting to gain the lead in the Tour
Took Testosterone, a drug that does not have a beneficial effect during a race like the Tour,
In an amount too small to raise his testosterone level above that of the average male
Then entered his system and was metabolized in a way contrary to the known science about testosterone
That in 4 out of the 5 tests alleged to be positive, his screening tests were absolutely normal
That in his 5 confirmation tests, the values vary in a way contrary to the known science about testosterone
That when the electronic files from stage 17 were reprocessed, the results were entirely not reproducible
MOST IMPORTANTLY: That all of the ISL Violations that are at the heart of this case, UTTERLY DID NOT MATTER.
Then entered his system and was metabolized in a way contrary to the known science about testosterone 5

6. In Order To Believe USADA
Floyd, knowing that he would be tested while in the lead or attempting to gain the lead in the Tour
Took Testosterone, a drug that does not have a beneficial effect during a race like the Tour,
In an amount too small to raise his testosterone level above that of the average male
Then entered his system and was metabolized in a way contrary to the known science about testosterone
That in 4 out of the 5 tests alleged to be positive, his screening tests were absolutely normal
That in his 5 confirmation tests, the values vary in a way contrary to the known science about testosterone
That when the electronic files from stage 17 were reprocessed, the results were entirely not reproducible
MOST IMPORTANTLY: That all of the ISL Violations that are at the heart of this case, UTTERLY DID NOT MATTER.
That in 4 out of the 5 tests alleged to be positive, his screening tests were absolutely normal 6

7. In Order To Believe USADA
Floyd, knowing that he would be tested while in the lead or attempting to gain the lead in the Tour
Took Testosterone, a drug that does not have a beneficial effect during a race like the Tour,
In an amount too small to raise his testosterone level above that of the average male
Then entered his system and was metabolized in a way contrary to the known science about testosterone
That in 4 out of the 5 tests alleged to be positive, his screening tests were absolutely normal
That in his 5 confirmation tests, the values vary in a way contrary to the known science about testosterone
That when the electronic files from stage 17 were reprocessed, the results were entirely not reproducible
MOST IMPORTANTLY: That all of the ISL Violations that are at the heart of this case, UTTERLY DID NOT MATTER.
That in his 5 confirmation tests, the values vary in a way contrary to the known science about testosterone 7

8. In Order To Believe USADA
Floyd, knowing that he would be tested while in the lead or attempting to gain the lead in the Tour
Took Testosterone, a drug that does not have a beneficial effect during a race like the Tour,
In an amount too small to raise his testosterone level above that of the average male
Then entered his system and was metabolized in a way contrary to the known science about testosterone
That in 4 out of the 5 tests alleged to be positive, his screening tests were absolutely normal
That in his 5 confirmation tests, the values vary in a way contrary to the known science about testosterone
That when the electronic files from stage 17 were reprocessed, the results were entirely not reproducible
MOST IMPORTANTLY: That all of the ISL Violations that are at the heart of this case, UTTERLY DID NOT MATTER.
That when the electronic files from stage 17 were reprocessed, the results were entirely not reproducible 8

9. In Order To Believe USADA
Floyd, knowing that he would be tested while in the lead or attempting to gain the lead in the Tour
Took Testosterone, a drug that does not have a beneficial effect during a race like the Tour,
In an amount too small to raise his testosterone level above that of the average male
Then entered his system and was metabolized in a way contrary to the known science about testosterone
That in 4 out of the 5 tests alleged to be positive, his screening tests were absolutely normal
That in his 5 confirmation tests, the values vary in a way contrary to the known science about testosterone
That when the electronic files from stage 17 were reprocessed, the results were entirely not reproducible
MOST IMPORTANTLY: That all of the ISL Violations that are at the heart of this case, UTTERLY DID NOT MATTER.
MOST IMPORTANTLY: That all of the ISL violations that are at the heart of this case, UTTERLY DID NOT MATTER. 9

10. Burden Of Proof
USADA "shall have the burden of establishing that an anti-doping rule violation has occurred."
UCI Cycling Regulations, Art. 16
World Anti-Doping Code, Art. 3.1 10

11. Rebuttable Presumption
The Rider may rebut this presumption by establishing that a departure from the International Standard occurred.
UCI Cycling Regulations, Art. 18 11

12. Burden Shifts Back
USADA shall have the burden to establish that the departure did not cause the Adverse Analytical Finding.
WADA Code Art 12

13. Standard of Proof
USADA must present evidence of a doping violation to the "comfortable satisfaction of the hearing body bearing in mind the seriousness of the allegation which is made."
UCI Anti-Doping Regulations, Article 16
Article 3.1 of the World Anti-Doping Code 13

14. Very high standard – as close to beyond a reasonable doubt as possible
Standard of Proof
Very high standard – as close to beyond a reasonable doubt as possible
The importance of this case / Seriousness of the allegations 14

15. Poor Chromatography: LNDD Incompetence15

16. Poor Chromatography: LNDD Incompetence
Poor Chromatograms throughout this case
Good Chromatography REQUIRED For Accurate Results
Confirmation methods for Non-threshold Substances must be validated. Examples of factors relevant to determining if the method is fit for the purpose are: Matrix interferences. The method should avoid interference in the detection of Prohibited Substances or their Metabolites or Markers by components of the sample matrix. 16

17. Poor Chromatography: LNDD Incompetence
Poor Chromatograms throughout this case
Good Chromatography REQUIRED For Accurate Results
Confirmation methods for Non-threshold Substances must be validated. Examples of factors relevant to determining if the method is fit for the purpose are: Matrix interferences. The method should avoid interference in the detection of Prohibited Substances or their Metabolites or Markers by components of the sample matrix. 17

18. Stage 17 (IRMS)
USADA0349 (Fraction 3) 18

19. Stage 11 19

20. Stage 17 (GC/MS) Sample A 20

21. Stage 17 (GC/MS) Sample B 21

22. MANUAL PROCESSING OF DATA: INCOMPETENCE22

23. MANUAL PROCESSING OF DATA: INCOMPETENCE
We Almost Never Knew 23

24. MANUAL PROCESSING OF DATA: INCOMPETENCE
We Almost Never Knew 24

25. UNSCIENTIFIC RESULTS -2.58 -3.99 -2.15 -6.14 -2.02 -3.51 -2.65 -6.39
Original result
A Sample
E-11K
-2.58
A-11K
-3.99
5B-P
-2.15
5A-P
-6.14
B Sample
E-11K
-2.02
A-11K
-3.51
5B-P
-2.65
5A-P
-6.39 25

26. UNSCIENTIFIC RESULTS -2.58 -2.32 -3.99 -3.65 -2.15 -1.70 -6.14 -5.65
Original result
Reprocessed (20 times!)
A Sample
E-11K
-2.58
-2.32
A-11K
-3.99
-3.65
5B-P
-2.15
-1.70
5A-P
-6.14
-5.65
B Sample
E-11K
-2.02
-0.35
A-11K
-3.51
-1.61
5B-P
-2.65
-3.05
5A-P
-6.39
-7.19 26

27. SELECTED ION MONITORING27

28. SELECTED ION MONITORING28

29. SELECTED ION MONITORING29

30. LNDD - One Ion SIM 30

31. UCLA – Three Ion SIM 31

32. We challenge USADA and LNDD with their army of experts to prove that:
Their chromatograms are good
That they actually document their manual processing
That they used proper confirmation techniques.
And prove that none of these ISL violations caused the adverse analytical finding 32

33. Other ISL Violations Violations of rules regarding chain of custody
Violations of rules regarding the preparation of laboratory documents
Identifying nonexistent compounds
Violations of rules regarding running quality controls
Violations of rules requiring reference collection standards 33

34. “Everyone is entitled to their own opinion, but not their own facts.”
The Honorable Daniel Patrick Moynihan