Dr Pedro Celaya’s involvement in doping

Dr. Pedro Celaya replaced Dr. Prentice Steffen as team physician for the U.S. Postal Service team for the 1997 season.653 It is acknowledged by those who were on the team at this time that the organized team doping program for the U.S. Postal Service Cycling team began at this point.654 One of the first things that Celaya did upon meeting the riders was to measure their hematocrit.655

In contrast to Dr. del Moral, who was described as impatient and gruff, Dr. Celaya was generally viewed as kind and caring.656 Most of the riders felt that Dr. Celaya truly cared about

646 _{Affidavit of George Hincapie, ¶ 67; Affidavit of Tyler Hamilton, ¶ 75.}

647 _{Affidavit of Tyler Hamilton, ¶¶ 76, 79; Affidavit of Floyd Landis, ¶¶ 21, 29, 30.} 648 _{Affidavit of Floyd Landis, ¶¶ 32, 36.}

649 _{Affidavit of George Hincapie, ¶ 74.}

650 _{Affidavit of Tyler Hamilton, ¶¶ 74-76, 79.} 651 _{Affidavit of George Hincapie, ¶ 74.}

652 _{Affidavit of Floyd Landis, ¶¶ 21, 29.} 653 _{Affidavit of Tyler Hamilton, ¶¶ 17-19.}

654 _{See, e.g., Affidavit of Emma O’Reilly, ¶¶ 26 (describing staff involvement, including that of} Celaya, in the doping program in 1997), 28.

655 _{Affidavit of Tyler Hamilton, ¶ 20.}

656 _{Christian Vande Velde said, “Dr. del Moral was gruff, aggressive and always seemed in a} hurry. . . Dr. Celaya would take the time to explain things.” Affidavit of Christian Vande Velde, ¶ 48.

Page | 119 the rider’s health657 and even shielded some of the younger riders from drugs at the outset of their careers, waiting until they were more established before suggesting that they begin to use performance enhancing drugs.658 Nonetheless, it was recognized that Celaya was not as conservative as some other team doctors in the sport.659

Celaya’s affable nature was also an asset in helping him to convince some young riders to try new drugs. For instance, when Dr. Celaya gave testosterone660 to Tyler Hamilton for the first time Celaya said, “this is not doping, this is for your health.”661 Similarly, after the Tour of Basque Country in 2005 Celaya approached Tom Danielson about receiving a cortisone injection.662 Celaya said, “I can give you cortisone for the Tour of Georgia, we’ll just say it is for your knee.”663 Danielson responded that he was alright and did not need the drug.664 Initially, Danielson did not want to the use cortisone as he did not know its potential side effects.665 However, Celaya responded, “it is good for your muscles, it will give you more power.”666 As a consequence, Danielson said he “relented and had intramuscular injections of cortisone for the Tour of Georgia.”667

Moreover, once a cyclist was on the “program”668 Dr. Celaya became an active participant in the doping. Supplying and injecting (or supervising the injection of) a

657 _{See, e.g., Affidavit of Jonathan Vaughters, ¶ 43.} 658 _{Affidavit of Jonathan Vaughters, ¶ 43.}

659 _{Affidavit of Frankie Andreu, ¶ 44.}

660 _{Celaya also introduced Hamilton to EPO. Affidavit of Tyler Hamilton, ¶ 27.} 661 _{Affidavit of Tyler Hamilton, ¶ 25.}

662 _{Affidavit of Tom Danielson, ¶ 63.} 663 _{Affidavit of Tom Danielson, ¶ 63.} 664 _{Affidavit of Tom Danielson, ¶ 63.} 665 _{Affidavit of Tom Danielson, ¶ 63.} 666 _{Affidavit of Tom Danielson, ¶ 63.} 667 _{Affidavit of Tom Danielson, ¶ 63.}

668 _{“The term ‘program’ was a euphemism but one with a very specific and well understood} meaning on the team. The terms ‘program’ and ‘preparation’ were specifically used to refer to

Page | 120 pharmacopeia of banned performance enhancing drugs such as EPO,669 testosterone,670 human growth hormone671 and cortisone,672 and assisting with the blood doping operation.673

In 1998 Dr. Celaya advised riders like Jonathan Vaughters, “how [EPO] was used and injected].”674 At that time, prior to the development of the EPO test, EPO injections were given subcutaneously (i.e., under the skin, as opposed to in the vein).675 At the beginning of 1998, prior to the Festina doping scandal, the use of EPO on the team was quite open among those riders using the drug, and EPO was even distributed in U.S. Postal Service water bottles. As Jonathan Vaughters described:

Dr. Celaya would deliver EPO to riders on the team in U.S. Postal Service water bottles with EPO vials packed in ice in the bottles. On the side of the bottle would be the name of the rider and the doses of EPO in the bottle. For instance, I might receive a bottle that would say “Jonathan – 5 x 2” meaning that the bottle held 5 vials of EPO containing 2,000 international units each.676

This degree of openness would change somewhat following the Festina scandal which prompted a bit more caution on the team about drug related communications. Nonetheless, amongst the initiated on the team, the use of drugs was well understood, accepted, and frequently discussed, albeit in somewhat euphemistic, but well understood, terminology whereby doping

combining drugs and training to bring the rider to a level of peak performance.” Affidavit of Christian Vande Velde, ¶ 61.

669 _{Affidavit of Tom Danielson, ¶ 72; Affidavit of Tyler Hamilton, ¶ 27; Affidavit of George} Hincapie, ¶ 37; Affidavit of Jonathan Vaughters, ¶¶ 26, 28; Affidavit of David Zabriskie, ¶ 49. 670 _{Affidavit of Tyler Hamilton, ¶ 25.}

671 _{Affidavit of George Hincapie, ¶ 38.} 672 _{Affidavit of Tom Danielson, ¶¶ 63, 117.}

673 _{Affidavit of Tom Danielson, ¶ 104 (took out two bags of blood).} 674 _{Affidavit of Jonathan Vaughters, ¶ 26.}

675 _{Affidavit of Jonathan Vaughters, ¶ 26.} 676 _{Affidavit of Jonathan Vaughters, ¶ 28.}

Page | 121 was referred to as the “program” or “preparation”677 and drugs were referred to as “Poe,”678 “Edgar,”679 the “oil,”680 and “Giaca”681 among other things.

As the Festina scandal mushroomed at the 1998 Tour de France and police raids were feared, Dr. Celaya’s easygoing nature disappeared, and he became very nervous.682 Team employee Emma O’Reilly believed “Dr.Celaya was frantic because he knew he would be held responsible if the U.S. Postal Service team was busted and found to be in possession of banned performance enhancing substances during the Tour de France.”683 Dr. Celaya’s anxiety was only relieved when at a stage in the middle of the Tour the team staff flushed tens of thousands of dollars of doping products down the toilet of the team camper.684

By 1998 the UCI had implemented a rule that riders with a hematocrit (i.e., percentage of red blood cells) at 50% or over would be kept out of races. The effect of EPO is to raise

hematocrit through stimulating the production of red blood cells. Therefore, it was necessary to measure the riders’ hematocrit levels to ensure that they did not lose eligibility by exceeding the hematocrit threshold; this was done through use of a centrifuge. In the event that a rider was at or over the hematocrit threshold due to EPO use it was necessary to administer a saline infusion so that the rider’s hematocrit value would be reduced.

677 _{Affidavit of Christian Vande Velde, ¶ 61.}

678 _{Referring to EPO. Affidavit of Tyler Hamilton, ¶ 50. Or as “Po.” Affidavit of George} Hincapie, ¶ 59; Affidavit of Christian Vande Velde, ¶ 88. Lance’s favorite term for EPO was “Po.” Affidavit of Jonathan Vaughters, ¶ 58.

679 _{Referring to EPO. Affidavit of Christian Vande Velde, ¶ 88.}

680 _{Referring to an Andriol (testosterone) and olive oil mixture that was taken under the tongue.} Affidavit of Christian Vande Velde, ¶¶ 82, 89, 94.

681 _{Affidavit of George Hincapie, ¶ 59.} 682 _{Affidavit of Emma O’Reilly, ¶¶ 49-51} 683 _{Affidavit of Emma O’Reilly, ¶ 50.}

684 _{Affidavit of Emma O’Reilly, ¶¶ 51-57. Unbeknownst to Dr. Celaya, however, the staff had} missed some vials of EPO in a thermos in the refrigerator of the team camper and these vials remained in the refrigerator through the end of the Tour. Affidavit of Emma O’Reilly, ¶¶ 58-62.

Page | 122 At the 1998 Vuelta, at which Lance Armstrong, Jonathan Vaughters and Christian Vande Velde competed, Dr. Celaya brought a centrifuge to measure the riders’ hematocrit levels.685 Jonathan Vaughters described most of the riders’ values being near the threshold throughout the race, likely indicating EPO use.686

At the 1998 World Championships Dr. Celaya pulled off a daring maneuver to get Lance Armstrong a saline infusion practically under the eyes of a UCI tester. Celaya smuggled a bag of saline under his rain coat, getting it past the tester and administering saline to Armstrong before Armstrong was required to provide a blood sample.687 Later, Celaya and Vaughters chuckled about the close call.688

Despite the ready support Celaya provided to the EPO doping program going on within the U.S. Postal Service team at the time, Armstrong did not feel that Celaya was aggressive enough in running the “program,” i.e., in supplying performance enhancing drugs.689 Dr. Celaya was replaced as the team physician for the start of the 1999 season, and Dr. Celaya moved on to the Spanish team ONCE which, like the U.S. Postal Service team, had a well organized doping program in which the team doctors were heavily involved.690

Dr. Celaya continued his doping practices with the ONCE team.691 _{Former ONCE rider} Jörg Jaksche has testified to Dr. Celaya’s involvement in doping while Jaksche was on the ONCE team during the 2001 through 2003 time period.692

685 _{Affidavit of Jonathan Vaughters, ¶ 39.} 686 _{Affidavit of Jonathan Vaughters, ¶ 39.}

687 _{Affidavit of Jonathan Vaughters, ¶ 46; see also Affidavit of Christian Vande Velde, ¶ 38.} 688 _{Affidavit of Jonathan Vaughters, ¶ 47.}

689 _{Affidavit of Jonathan Vaughers, ¶ 42.}

690 _{Affidavit of Jörg Jaksche, ¶¶ 22-27; Affidavit of Christian Vande Velde, ¶ 133 (Liberty} Seguros, the successor to the ONCE team, had “an organized doping program in which the team doctors were very involved in providing performance enhancing drugs”).

Page | 123 Five years after his departure from the U.S. Postal Service team, Dr. Celaya returned to the U.S. Postal Service team for the 2004 season after Dr. del Moral fell out of favor with Armstrong, apparently due in part to Armstrong feeling like del Moral had some blame for Armstrong’s weaker performance in the 2003 Tour than in his previous Tour winning

performances. After returning to the team in 2004 Dr. Celaya picked up where he had left off, continuing his involvement in providing banned drugs to riders693 and his participation in the team blood doping program.694 Also, like Dr. del Moral before him, Celaya continued the practice of injecting the riders with substances he would not identify even when asked.695

The heavy involvement of Dr. Celaya in the team doping program on the U.S. Postal Service/Discovery Channel team during 1997 through 1998 and 2004 through 2005 corroborates USADA’s substantial direct evidence of Lance Armstrong’s doping and strongly supports the conclusion that Lance Armstrong engaged in doping as charged by USADA.