Fertile mind indeed:
"I, Wayne Celia, declare that:
....
2) I have been working with, developing, and producing foam products since 1975. I am considered one of the most formidable experts in the area of hydrophilic urethane manufacturing. Many of the foam products that I developed sell in the medical, cosmetic and footwear industries throughout the world.
3) I attended Fairleigh Dickinson University majoring in Physiological and Experimental Psychology.
...."
From our new R & D director in a sworn affidavit.