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Kessler-Exhibit-34 EXHIBIT 34 SUPERIOR COURT OF NEW JERSEY HUDSON COUNTY LAW DIVISION Michael Ferguson, Benjamin Unger, Sheldon DOCKET NO. L-5473-12 Bruck, Chaim Levin, Jo Bruck, Bella Levin, Plaintiffs, V. JONAH (Jews Offering New Alternatives for Healing f/k/a Jews Offering New Alternatives to Homosexuality), Arthur Goldberg, Alan Downing, Alan Downing Life Coaching, LLC, Defendants. EXPERT REPORT OF CHRISTOPHER DOYLE, M.A.• L.C.P.C. I. QUALIFICATIONS AND PUBLICATIONS. My name is Christopher Doyle. I am a licensed clinical professional counselor in the state of Maryland and the Director of the International Healing Foundation (IHF), of which I have been providing psychotherapy for clients who experience unwanted same-sex attractions and/or are gay-identified, for nearly five years. I hold a Master of Arts in Professional Counseling from Liberty University. In my five years of clinical experience, I have treated approximately 150 men who experience conflicts with their sexuality or sexual orientation. Most of these men do not accept a gay identity for their lives, and seek counseling to overcome unwanted homosexual desires and attractions and increase opposite sex attractions. I have also worked with countless parents and families, both in individual consultations, family healing sessions, and group psychotherapy retreats. I am the co-creator of several different therapeutic retreats at IHF, including the Breakthrough Healing Weekend for men with unwanted same-sex attractions, Key to Your Child's Heart Healing Weekend for fathers of same-sex attracted children, and Key to Your Child's Heart Healing Weekend for mothers of same-sex attracted children. I am also the author of several publications on adolescent sexual health and bullying prevention, and a former associate editor of the peer-reviewed scientific journal Adolescent & Family Health. I speak and write often on issues related to sexual orientation, sexuality, relationships, and sexual identity. My columns are regularly published at The Christian Post and I am also a contributor to Barbwire.com, and was the first ever recipient of the Dr. Joseph Nicolosi Award for early career excellence, presented by the National Association for Research and Therapy of Homosexuality. I am also a former same-sex attracted man, and have not had a homosexual impulse, attraction, or desire for over ten years. I have been married to my wife for eight years, and together, we have three children. Please also see my curriculum vitae which is attached hereto as Exhibit 1. II. STATEMENT OF OPINIONS AND BASIS THEREFOR. A. Background and Development of Homosexuality and Rationale for Psycho- Therapeutic Interventions to Reduce and/or Eliminate Unwanted Same-Sex Attractions. The focus of this expert report will be to discuss, describe, and defend the various techniques that JONAH, Alan Downing, and People Can Change (PCC) employ in their psychotherapeutic and coaching to reduce and/or eliminate unwanted same-sex attractions (SSA), also knowu as sexual orientation change effort (SOCE) therapy. However, the author finds it necessary to first discuss some important considerations for the socio-political background of sexual orientation, development of SSA, and the rationale for SOCE interventions. In their efforts to secure equality, the gay rights movement has taken homosexual behavior, once widely considered to be a clinical condition that could be successfully treated to various degrees (Phelan 2014, Phelan et el. 2009), and has turned it into a socio-political identity. The terms gay, lesbian, bisexual, transgender, queer (LGBTQ) - along with the over fifty gender identities recognized in LGBTQ circles - have no scientific basis whatsoever, but rather, are social constructs created by homosexual activists to achieve desired political ends (Doyle, 2014). Indeed, while critics of SOCE therapy often contend that its methods and techniques are not grounded in science (Beckstead, 2012), these accusations are not only untrue, as this report will 1 demonstrate, but quite actually, a projection of their own lack of scientific proficiency for an alternative to interventions that seek to change homosexual behavior. No example is clearer than the American Psychological Association's 2009 Task Force on SOCE (APA, 2009). Called the Report of the American Psychological Association on Appropriate Therapeutic Responses to Sexual Orientation, the six member Task Force consisted of either gay-identified or gay-affirming psychologists who had previously gone on the record as opposing SOCE for philosophical reasons (Phelan et al., 2012, p. 55). According to the APA Ethical Principles, psychologists should refrain from taking on interests that impair their objectivity (APA, 2002). One of the Task Force's principle rationales for the creation of its Report was that "Advocates [those who opposed SOCE (e.g., Drescher, 2003) and those who promoted SOCE (e.g., Nicolosi, 2003)] asked" for such a report (p. 12). However, when it came to assembling the Task Force, advocates who were pre-opposed to SOCE (i.e., Drescher, 2003; Glassgold, 2007) were actually chosen to be members of the Task Force, while no proponents of SOCE were chosen (Nicolosi, n.d.). Although the authors said that "Guidelines and standards for practice are created through a specific process that is outside the purview of the Task Force" (APA, 2009, footnote, p. 65, emphasis added), they made recommendations for public policy. Despite their own principle to not overtly influence public affairs (Tyler, 1969), this has been a recent trend for the APA. 1n several recent cases the APA has directly advocated for legal and policy changes (APA, 1998, 2003, 2005, 2008a). The Task Force undoubtedly was well aware that its report would be used as such and would be voted on by the APA's governing Council of Representatives at its annual convention. 1n fact, the report's authors asked for such a resolution. The policy aspect was passed without much scrutiny. Likewise, it did not accomplish a survey of its own membership, the mental health profession, or the general population for approval/disapproval, nor was there an established review period for feedback, despite the fact that the voice of the APA's members is generally solicited when the APA governance wishes to issue a major statement or resolution on behalf of the association (APA, n.d.). Unsurprisingly, the Task Force report's overall conclusion was unsupportive of SOCE interventions, and explicitly stated that the appropriate therapeutic intervention for all clients who experience same-sex attractions was to affirm that such behavior is natural, normal, and healthy - regardless of the client's goals, values, or religious beliefs. 1n his book, Destructive Trends in Mental Health: The Well-Intentioned Path to Harm, former APA President, Dr. Nicholas A. Cummings, describes the current milieu of political correctness that is clouding honest scientific inquiry within the ranks of the APA: 1n 1973, American Psychological Association (APA) President Leona Tyler enunciated the principle which we would advocate in the name of psychology and when we would do so as concerned citizens. This principle became APA policy. 1n speaking as psychologists, our advocacy should be based on scientific data and demonstrable professional experience. Absent such validation, psychologists are free to speak as any concerned citizen, either as individuals or collectively through dedicated advocacy organizations. This separation is necessary if society is to ascribe credibility to advocacy when psychologists are speaking authoritatively as psychologists. Violation of this principle erodes the credibility 2 of the science and profession to represent fact and evidence, and we become another opinionated voice shouting to be heard in the vast arena. Since enunciation of this principle, advocacy for scientific professional concerns has been usurped by agenda-driven ideology who show little regard for either scientific validation or professional efficacy. Although I am in agreement with many of APA's stances, I am opposed to the process that has diminished its credibility. It is no longer perceived as an authority that presents scientific evidence and professional facts. The AP A has chosen ideology over science, and thus has diminished its influence on the decision makers in our society (xiv). It is important to note, that in an affidavit filed in 2013 in this lawsuit, Dr. Cummings, who headed the mental health division of Kaiser Permanente, said he personally treated over 2,000 people with same-sex attraction, and his staff treated an additional 16,000. Of those of his patients who wanted to change their sexual orientation to heterosexual, "hundreds" were successful, going on to lead normal heterosexual lives (Cummings, 2013). Ethical considerations aside, there were multiple problems with the Task Force's report, including methodological concerns, a failure to review and report all evidence, inconsistent application of standards for SOCE compared to gay-affirmative therapy, a lack of respect for client's autonomy and right of self-determination, questionable standards in evaluating the efficacy of SOCE, definitional problems for sexual orientation and sexual identity, false pretentions about sexual orientation and biology, and conclusions on what constitutes "harm" (Phelan et al, 2012). 1. Etiology and development of same-sex attractions In spite of their agenda-driven ideology, one year prior to the AP A's Task Force report in 2009, the AP A issued a statement
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