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UNITED STATES DISTRICT COURT EASTERN DISTRICT OF NEW YORK
DR. DAVID SCHWARTZ, Case No.: 1:19-CV-463-RJD-ST
Plaintiff,
v. PLAINTIFF DAVID SCHWARTZ’S REPLY IN SUPPORT OF MOTION THE CITY OF NEW YORK and FOR PRELIMINARY INJUNCTION LORELEI SALAS, in her official capacity as Commissioner of the Department of Consumer Affairs,
Defendants.
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Table of Contents
Table of Authorities ...... ii INTRODUCTION ...... 1 I. Dr. Schwartz’s counseling speech is fully protected...... 2 A. Conversations between a psychotherapist and patient are speech...... 2 B. Counselor-patient conversations are immune to content censorship...... 3 C. Strict scrutiny applies to the Counseling Censorship Law...... 5 D. The Counseling Censorship Law fails strict scrutiny...... 6 E. Dr. Schwartz has standing to defend the rights of his patients...... 8 II. The Counseling Censorship Law is unconstitutionally vague...... 9 III. The Counseling Censorship Law violates free exercise rights...... 9 IV. A preliminary injunction is proper and necessary...... 10
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Table of Authorities
Cases
Boos v. Barry, 485 U.S. 312 (1988) ...... 7
Boy Scouts of America v. Dale, 530 U.S. 640 (2000) ...... 2
Brown v. Entertainment Merchants Association, 564 U.S. 786 (2011) ...... 4, 7, 8
Chabad of Southern Ohio & Congregation Lubavitch v. City of Cincinnati, 363 F.3d 427 (6th Cir. 2004) ...... 10
Church of the Lukumi Babalu Aye, Inc. v. City of Hialeah, 508 U.S. 520 (1993) ...... 5, 10
Edenfield v. Fane, 507 U.S. 761 (1993) ...... 8
Harris v. Quinn, 573 U.S. 616 (2014) ...... 3
Illinois, ex rel. Madigan v. Telemarketing Associates, Inc., 538 U.S. 600 (2003) ...... 4
Irish Lesbian & Gay Organization v. Giuliani, 918 F. Supp. 732 (S.D.N.Y. 1996) ...... 10
Kass v. City of New York, 864 F.3d 200 (2d Cir. 2017)...... 7
King v. New Jersey, 767 F.3d 216 (3d Cir. 2014)...... 2
NAACP v. Button, 371 U.S. 415 (1963) ...... 3, 7
National Council of Arab Americans v. City of New York, 331 F. Supp. 2d 258 (S.D.N.Y. 2004)...... 10
NIFLA v. Becerra, 138 S. Ct. 2361 (2018) ...... 2, 3, 4
United States v. Alvarez, 567 U.S. 709 (2012) ...... 7
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Virginia State Board of Pharmacy v. Virginia Citizens Consumer Council, Inc., 425 U.S. 748 (1976) ...... 7
Virginia v. Black, 538 U.S. 343 (2003) ...... 7
Wollschlaeger v. Florida, 848 F.3d 1293 (11th Cir. 2017) ...... 2
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INTRODUCTION
Dr. Schwartz’s patients come to him voluntarily, bringing a wide range of human
problems. If they return, it is because they find his thoughts helpful. There is no coercion, no
isolation, no promise of results. For those who come struggling with unwanted same-sex
attractions, as for those who bring other concerns, Dr. Schwartz offers a listening ear, questions
to help patients understand themselves, and ways of thinking—that is, ideas—to help those
patients towards their own goals for their lives, and towards adherence to the teachings of their
Orthodox Jewish faith. Pl.’s Mem. in Supp. of Mot. for Prelim. Inj. (Pl. Br.) 2-6.
In an unprecedented intrusion into private conversations (the “first bill of its kind” (Decl.
of Alan Schoenfeld in Supp. of Def. Opp’n to Pl.’s Mot. for Prelim. Inj. (Schoenfeld Decl.), Ex.
B at 64)), the City of New York has declared those conversations illegal, and is actively
recruiting anonymous informers to ferret out forbidden speech. It is impossible to square such
things with the plain words and rich precedent of the First Amendment, and the City’s attempt
involves mind-bending contortions in which it declares that idea-laden speech about the most
sensitive matters of personal identity, philosophy, faith, and personal goals is “not speech.”
But Dr. Schwartz’s discussions with his patients—whether compensated or
uncompensated—are core speech, fully protected by the First Amendment. Extended arguments
by the City (and amicus The Trevor Project) that efforts to help an individual achieve
congruence between his body and his sexual identity and attractions may sometimes be harmful
are simply irrelevant to the analysis. If the Government has the power to punish the
dissemination of ideas because it deems them hazardous, then the First Amendment is
extinguished.
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I. Dr. Schwartz’s counseling speech is fully protected.
A. Conversations between a psychotherapist and patient are speech.
The City attempts to evade free speech strictures by citing Pickup and scattered progeny
to assert that conversations between a psychotherapist and his patient are “conduct,” “not
speech.” Def. Mem. in Opp’n to Pl.’s Mot. for Prelim. Inj. (Def. Br.) 10. This is objectively
untrue; a video recording of Dr. Schwartz’s work would detect nothing but speech; there is no
“conduct” for this speech to be “incidental” to. The censorship law “directly and immediately”
regulates Dr. Schwartz’s speech. Boy Scouts of Am. v. Dale, 530 U.S. 640, 659 (2000). The
contrary holding of Pickup was always an unconvincing legal fiction; now it is clearly bad law.
The Ninth Circuit’s attempt to declare the speech of a professional counselor to be “not speech”
has been expressly rejected by both the Eleventh and Third Circuits,1 and accepted by no other
circuit. In NIFLA, the Supreme Court—citing Pickup only to reject its analysis, NIFLA v.
Becerra, 138 S. Ct. 2361, 2371 (2018)—cited Wollschlaeger with approval to conclude that the
professional speech of medical professionals is fully protected speech, id. at 2374-75. See Pl. Br.
9-12.
The City ignores this line-up of post-Pickup authority. It does not cite Wollschlaeger, or
mention this aspect of the holding in King. It ignores the several cases in which circuit courts
have stricken laws that presumed to censor speech between doctor and patient. Pl. Br. 10. It
attempts to brush aside the binding analysis of NIFLA as “inapplicable” on the irrelevant basis
that NIFLA “is a compelled speech case” (Def. Br. 13), and it tries to repackage Pickup’s
discredited “conduct, not speech” argument by characterizing the pure and idea-laden speech of
1 See Wollschlaeger v. Florida, 848 F.3d 1293, 1309 (11th Cir. 2017) (“characterizing speech as conduct is a dubious constitutional enterprise”); King v. New Jersey, 767 F.3d 216, 224 (3d Cir. 2014) (“[W]e disagree [with characterizing SOCE counseling as conduct], and hold that the verbal communication that occurs during SOCE counseling is speech.”).
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Dr. Schwartz as “a procedure” and therefore “conduct rather than speech.” Def. Br. 13-14. This
reading—and the City’s assertion that NIFLA calls for “at most” intermediate scrutiny of
censorship of the professional speech of psychotherapists (see Def. Br. 10) or any other speech
that “serves a function” (Def. Br. 12)2—is untenable. “[A] State cannot foreclose the exercise of
constitutional rights by mere labels.” NAACP v. Button, 371 U.S. 415, 429 (1963).
We will pause to note the wide implications of the City’s position. What it means to be
man or woman; the relationship between objective body and subjective mental states; when and
in what relationships sexual and reproductive relationships are right or wrong; how individuals
should respond when their inclinations or conduct fail to match their moral convictions; and
whether humans have free will and the capacity to change, or are helpless agents of chemistry—
these are timeless questions of philosophers, religious teachers, moralists, and indeed
psychologists. Pl. Br. 22. If the City of New York has the power to censor speech on these topics
by the expedient of declaring them to be “medical” questions, and counseling on these topics
therefore to be “medical procedures,” then the walls are fast closing in on both free speech and
free exercise in areas at the very heart of human nature and human well-being.
B. Counselor-patient conversations are immune to content censorship.
The City emphasizes that the Counseling Censorship Law reaches only conversations for
which a fee is charged, asserting that Dr. Schwartz is free to offer to his patients any ideas he
wants so long as he does not charge. See, e.g., Def. Br. 14, 19, 25. But the City does not and
cannot argue that this is “commercial speech,”3 and short of that, the fee is absolutely irrelevant
2 Essentially all speech “serves a function.” Here, the “function” is the patient’s pursuit of happiness, a natural reproductive family, and obedience to his or her faith. 3 See Harris v. Quinn, 573 U.S. 616, 648 (2014) (defining “commercial speech as ‘speech that does no more than propose a commercial transaction.’”).
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to the First Amendment analysis, as made plain by NIFLA. The New York Times is a for-profit
corporation, but no less protected for that. Either the City has the power to prohibit all
counseling—and perhaps all conversations—intended to steer an individual towards congruence
between the reproductive potential of his body and his sexual attractions or sense of identity, or it
does not. The City likewise cannot fit counseling speech into the bottles of “obscenity,”
“incitement,” or “fighting words,” and the City may not extend government control to new
categories of speech based on its conclusion that “certain speech is too harmful to be tolerated.”
Brown v. Entm’t Merchs. Ass’n, 564 U.S. 786, 791 (2011); see also NIFLA, 138 S. Ct. at 2371
(emphasizing the Court’s “reluctan[ce] to mark off new categories of speech for diminished
constitutional protection”).
The City repeatedly describes therapeutic speech it opposes as “fraud” and “deception.”
See, e.g., Def. Br. 6, 11, 15-16, 18-19. But “[s]imply labeling an action one for ‘fraud,’ of course,
will not carry the day.” Illinois, ex rel. Madigan v. Telemarketing Assocs., Inc., 538 U.S. 600,
617 (2003). Fraud involves a knowingly false statement. A false statement is not an element of a
violation of the Law, nor does the City ever identify anything false or misleading in the counsel
that Dr. Schwartz provides. The City does not dispute that Dr. Schwartz never gives promises of
particular results. Pl. Br. 5; Decl. of David Schwartz in Supp. of Pl.’s Mot. for Prelim. Inj.
(Schwartz Decl.) ¶ 31. The City would like to leave an impression that it is “false” that
individuals can ever change their sexual attractions, thoughts, and conduct, but it dares not say
that, because that position is indefensible. Extensive literature in the field (as well as widespread
experience), teaches that large numbers of individuals have done exactly that.4 Similarly, the
4 See Expert Decl. of Lawrence S. Mayer, M.D., Ph.D. in Supp. of Pl.’s Mot. for Prelim. Inj. (Mayer Decl.) 3-6.
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City does not dispute that Dr. Schwartz himself has worked with individuals who have
succeeded in making that change and achieved the marriages and natural families that they
desired (Pl. Br. 5-6; Schwartz Decl. ¶ 36), nor that the globally respected religious leader, the
Lubavitcher Rebbe, taught that such change is possible (Schwartz Decl. ¶¶ 50-52). Similarly, a
large majority of young people who experience gender dysphoria ultimately “desist”—that is,
achieve comfort in the identity defined by their sex. Mayer Decl. 6. The Counseling Censorship
Law cannot pass as an anti-fraud law.
C. Strict scrutiny applies to the Counseling Censorship Law.
Dr. Schwartz has detailed the content-based, non-neutral nature of the Law that triggers
strict scrutiny. Pl. Br. 11-12. The City’s response essentially restates the argument that
counseling is not speech. Def. Br. 14. Its denial that the statute was targeted against religious
groups and individuals (Def. Br. 23 n.12) is cursory. The express denunciation of religious
groups that the City dismisses as from “a single report” is repeated in each of the only two
committee reports submitted to the City Council justifying the Law.5 The supporting testimony
repeatedly aimed at religious groups. Pl. Br. 7; Schoenfeld Decl., Ex. B at 66, 68, 74, 89. The
City’s declarant (as well as other authorities) have elsewhere identified faith as the primary
reason that individuals seek the counseling that the Law censors.6 And denouncing religious
organizations such as Higher Ground without identifying them as religious may “mask[ ]” the
City’s hostility, see Church of the Lukumi Babalu Aye v. City of Hialeah, 508 U.S. 520, 534
(1993), but does not cure it.
5 Decl. of Jeana Hallock in Supp. of Pl.’s Mot. for Prelim. Inj. ¶ 2, Ex. 1 (Hallock Decl.); See Decl. of Jeffrey Shafer in Supp. of Pl.’s Mot. for Prelim. Inj., Ex. 1. 6 Mayer Decl. 17.
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D. The Counseling Censorship Law fails strict scrutiny.
The City repeatedly asserts that “conversion therapy” is “discredited,” “harmful,” and
“ineffective.” E.g., Def. Br. 2, 3, 4. These bold assertions go far beyond the sources it cites,
which assert only that efforts to change orientation or identity “may” not be successful, that they
“potentially” lead to psychological distress. See, e.g., Def. Br. 3-4 (citing sources). The
American Psychological Association’s 2009 report on which the City and its declarant Dr.
Haldeman rely expressly stated that there is so little “credible evidence” that “we cannot draw a
conclusion regarding whether recent forms of SOCE are or are not effective.” Decl. of Douglas
C. Haldeman in Supp. of Def. Opp’n to Pl. Mot. for Prelim. Inj. (Haldeman Decl.), Ex. B at 28,
43.7 Multiple published studies report that some individuals are able to change sexual attractions
with the aid of psychotherapy, and without a decrease in mental health. Mayer Decl. 3-6. This
alone proves that the Counseling Censorship Law fails strict scrutiny.
But we will stand on principle: Such debates are irrelevant to the question before this
Court. The large fact of our First Amendment freedom is that government is not entitled to
silence the promulgation of ideas based on a conclusion that those ideas are mistaken, or that
those ideas may be harmful to society or individuals. Government has no cognizable interest in
protecting citizens from upset caused by exposure to ideas and advice that they want to hear.
Government may not silence counsel, psychotherapy, moral teaching, or any other speech on the
grounds that it might induce feelings of “guilt,” “low self-esteem,” “discouragement,” or more.
7 Meanwhile, anecdotal evidence of distress among those who seek to bring their sexual attractions or gender identity in line with their biological reproductive reality is not probative of causation, given that homosexual and transgender populations across the board suffer far higher incidents of depression, suicidal ideation and attempts, and other indicia of distress than does the heterosexual population and those who identify with their biological sex. See Mayer Decl. 10-16.
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Def. Br. 3.8 Persons have the right to pursue goals other than submission to subjective attraction
or fears, including goals of forming a natural family, honoring vows made to a wife or husband,
or living consistently with the ethical teachings of their faith. Pl. Br. 8-9; Schwartz Decl. ¶¶ 41-
45, 57.9 Equally, government may not suppress speech and the dissemination of ideas because it
concludes that they are “wrong.”10 Even in the face of consensus, a lone voice has the right to
speak in dissent, and those who wish to hear that voice have a right to do so. Pl. Br. 20.11
It also remains true that the law is overinclusive (Pl. Br. 14-15), underinclusive (Pl. Br.
15-16), and not the least restrictive alternative with respect to any legitimate government
interests (Pl. Br. 16). Space requires that Dr. Schwartz rely primarily on his opening brief on
those points. We note, however, the disconnect between the City’s urgent claims of grave harms,
and its mild assurance that so long as Dr. Schwartz doesn’t charge a fee, he is free to provide the
same counsel. Def. Br. 10. This underbreadth undermines the City’s claimed compelling interest.
Conversely, the APA’s finding regarding the lack of evidence concerning “recent forms
of SOCE” (that is, ordinary conversational psychotherapy and counseling) sufficient to enable
any conclusions about efficacy (supra p. 6) makes glaring the overbreadth of the Counseling
8 See United States v. Alvarez, 567 U.S. 709, 717 (2012) (claimed right to limit free speech based on “balancing of relative social costs and benefits” is “startling and dangerous”); Brown, 564 U.S. at 792 (same); Boos v. Barry, 485 U.S. 312, 322 (1988) (citing “longstanding refusal” to censor speech because it “may have an adverse emotional impact on the audience”). 9 Va. State Bd. of Pharmacy v. Va. Citizens Consumer Council, Inc., 425 U.S. 748, 770 (1976) (rejecting censorship of speech based on “paternalistic” assumption that it is “harmful” and that it refuses to let individuals “perceive their own best interests”). 10 See Button, 371 U.S. at 444–45 (speech protected “without regard … to the truth, popularity, or social utility of the ideas and beliefs [expressed]”); Virginia v. Black, 538 U.S. 343, 358 (2003) (speech protected even if “a vast majority of its citizens believes [it] to be false and fraught with evil consequence.”); Alvarez, 567 U.S. at 718 (“some false statements are inevitable” in the “public and private conversation” protected by the First Amendment). 11 See Kass v. City of New York, 864 F.3d 200, 207 (2d Cir. 2017) (reiterating “right to listen and receive information”).
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Censorship Law. That is, even if the City had unambiguous scientific evidence of harm
associated with the types of strange or extreme methods it prefers to highlight, no amount of
such evidence would even tend to prove that voluntary, non-coercive conversation between
consenting adults is harmful or ineffective. A mere trick of name-calling, collectively labelling it
all with the prejudicial tag of “conversion therapy,” cannot plug that evidentiary hole.
In order to demonstrate that a restriction on speech “furthers” a governmental interest and
is “narrowly drawn” as strict scrutiny requires, the City must demonstrate that the “curtailment
of free speech [is] actually necessary.” Brown, 564 U.S. at 799-800 (emphasis added). The
acknowledged lack of evidence makes it impossible to carry this burden as to mere
conversational psychotherapy. “[A]mbiguous proof will not suffice,” and the legislature may not
“make a predictive judgment” of harm “based on competing psychological studies.” Id.12
E. Dr. Schwartz has standing to defend the rights of his patients.
Dr. Schwartz cited Supreme Court authority to detail why he has standing to assert the
free speech and free exercise rights of his patients. Pl. Br. 18-20. The City responds to none of
this authority or logic, simply asserting lack of standing based on the weak reed of Pickup and its
progeny. Def. Br. 9 n.3. The right of Dr. Schwartz’s patients to receive information and advice
that they desire, and to seek help from anyone they want as they seek to conform their lives to
the teachings of their faith, are of the highest constitutional importance, and are rightly
represented by Dr. Schwartz.
12 Because the Law furthers no legitimate government purpose, and is radically overbroad in comparison to “treatments” that might be legitimately regulated as “conduct,” it would also fail intermediate scrutiny. See Edenfield v. Fane, 507 U.S. 761, 777 (1993) (noting that “comprehensive bans on certain categories of commercial speech would be … inconsistent with the results reached in a number of our prior cases.”).
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II. The Counseling Censorship Law is unconstitutionally vague.
Dr. Schwartz has detailed the ways in which the Law—including the definition of
“conversion therapy”—is fatally vague. Pl. Br. 16-18. The City offers no substantive response,
no solution to any of the uncertain scenarios posed by Dr. Schwartz, and no clarification of any
term. Def. Br. 20-21. The City relies instead on mere say-so (“these terms carry plain,
commonplace meaning”), and the circular argument that since Dr. Schwartz fears that the law
could cover his counseling (he has never said “clearly”), then there cannot be a vagueness
problem. Def. Br. 20.
III. The Counseling Censorship Law violates free exercise rights.
The City’s brief treats the religious convictions and rights of Dr. Schwartz and his
patients cavalierly, essentially avoiding any mention of the faith of Dr. Schwartz and his patients.
The City neither disputes nor acknowledges the centrality of Jewish law concerning sexual
relationships, family, and procreation to the Orthodox Jew. Pl. Br. 3-5; Schwartz Decl. ¶¶ 46-59;
Weinreb Decl. ¶¶ 22-29. The City’s brief conspicuously avoids any mention at all of the
biological facts of procreation, or any recognition that those facts might as a matter of both faith
and teleological reason motivate a person to deliberately pursue and seek help to pursue certain
attractions and relationships. The City neither disputes nor acknowledges the clear teachings of
the Lubavitcher Rebbe concerning both the obligation and the ability of individuals to work to
change same-sex desires—nor the Rebbe’s example in providing counsel to help a fellow Jew
succeed in that change. Pl. Br. 3-5; Schwartz Decl. ¶¶ 49-53; Weinreb Decl. ¶¶ 23, 29.
In sum, the City neither disputes nor acknowledges the heavy burden that the Counseling
Censorship Law inflicts on an Orthodox Jew who desires to live according to the religious
requirements of the Torah, Jewish law, and the teachings of the Lubavitcher Rebbe, and who
seeks professional help to do so. Nor does the City offer any substantive response to the
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precedents that demonstrate that the Free Exercise Clause “just says no” to this type of intrusion
into long-standing and core religious convictions and functions, quite apart from any Smith
analysis. See Pl. Br. 21-23. For the reasons explained above, the law is also targeted against
religious groups and individuals both in terms of intent and as applied. Supra p. 5; Pl. Br. 7, 24.
Indeed, the City ignores one key element of Lukumi—that “the effect of a law in its real
operation is strong evidence of its object.” Lukumi, 508 U.S. at 535. Here, the City’s declarant as
well as other authorities acknowledge that most of those who seek the counseling that the City
outlaws do so out of faith conviction. Mayer Decl. 17.
IV. A preliminary injunction is proper and necessary.
Dr. Schwartz is not guilty of “inexcusable … delay” in seeking a preliminary injunction.
Def. Br. 8. The Counseling Censorship Law is young, and it was only during preparation of the
Complaint that Dr. Schwartz learned of the City’s active solicitation of anonymous informants
and its promise to investigate all such anonymous complaints. Pl. Br. 8; Hallock Decl. ¶ 3, Ex 2.
Obviously, by filing his lawsuit Dr. Schwartz has made himself a likely target for just such
complaints, and he is currently treating patients who are experiencing unwanted same-sex
attractions. Schwartz Decl. ¶¶ 40, 60-61. Given that the City has argued that the law is not vague
because Dr. Schwartz knows he is guilty (Def. Br. 20), interim relief is all the more needed. See
Chabad of S. Ohio & Congregation Lubavitch v. City of Cincinnati, 363 F.3d 427, 436 (6th Cir.
2004). The City does not contend that Dr. Schwartz’s supposed delay has in any way prejudiced
the City’s ability to prepare its case. Compare Nat’l Council of Arab Ams. v. City of New York,
331 F. Supp. 2d 258, 266, 749 (S.D.N.Y. 2004); Irish Lesbian & Gay Org. v. Giuliani, 918 F.
Supp. 732, 749 (S.D.N.Y. 1996). The preliminary relief requested by Dr. Schwartz (Pl. Br. 25) is
appropriate.
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Respectfully submitted this 11th day of April, 2019.
/s/ Roger G. Brooks
Barry Black Roger G. Brooks NELSON MADDEN BLACK LLP Jeffrey A. Shafer The French Building Jeana J. Hallock * 551 Fifth Ave., 31st Floor ALLIANCE DEFENDING FREEDOM New York, NY 10176 15100 N. 90th Street 212-382-4300 (T) Scottsdale, Arizona 85260 (480) 444-0020 (T) [email protected] [email protected] [email protected]
ATTORNEYS FOR PLAINTIFF
* Admitted Pro Hac Vice
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UNITED STATES DISTRICT COURT EASTERN DISTRICT OF NEW YORK
DR. DAVID SCHWARTZ, Case No.: 1:19-CV-463
Plaintiff,
v. EXPERT DECLARATION OF LAWRENCE S. MAYER, M.D., Ph.D., IN THE CITY OF NEW YORK and SUPPORT OF PLAINTIFF DR. DAVID LORELEI SALAS, in her official capacity as SCHWARTZ’S MOTION FOR Commissioner of the Department of PRELIMINARY INJUNCTION Consumer Affairs, Defendants.
I, Dr. Lawrence S. Mayer, declare as follows: Qualifications 1. While retained as a private consultant in this matter, I serve as a Visiting Fellow
in Integrative Knowledge and Human Flourishing at Harvard University.
2. I have been asked to offer my opinions on the state of science on the issues of
sexual orientation and gender identity with a focus on the published quantitative literature.
3. I am a research physician, epidemiologist, and biostatistician; one of the few
physicians with training in psychiatry, clinical epidemiology and a Ph.D. in Mathematics and
Statistics.
4. I have served as a tenured (and nontenured) professor at major universities for
over four decades. My professorial (and research) appointments have been at Arizona State
University, Johns Hopkins University, The Ohio State University, The Mayo Clinic, Princeton
University, Stanford University, University of Michigan, University of Pennsylvania, and
Virginia Tech. I am currently a Visiting Fellow at Harvard University where my research focuses
Case 1:19-cv-00463-RJD-ST Document 25-1 Filed 04/11/19 Page 2 of 49 PageID #: 1434
on the integration of the quantitative methods of the social sciences with more classical
biostatistical and epidemiological methods.
5. My appointments have been in 23 disciplines including statistics, biostatistics,
epidemiology, public health, mental health, social methodology, psychiatry, mathematics,
sociology, political science, economics, and biomedical informatics. My primary focus has been
on the intersection among biostatistics, epidemiology, medicine, and public health.
6. I have reviewed as a biostatistician, epidemiologist, physician, and social
methodologist hundreds of manuscripts submitted for publication to many of the major medical,
statistical, and public health journals, including The New England Journal of Medicine, The
Journal of the American Statistical Association, and The American Journal of Public Health. I
have served as an associate editor for The Journal of the American Statistical Association and
Social Methods and Research. I am a founding member of the editorial board of the journal
Social Methodology and the Sage series on Social Methodology.
7. I am a Fellow of the Royal Statistical Society.
8. I attach as Exhibit A a copy of my current Professional Vita, which lists my
education, appointments, publications, research, and other professional experience.
9. In this declaration, I present, in the headings marked with Roman numerals or
capital letters, certain of my opinions about the current state of scientific knowledge about
health, mental health, fluidity, and therapies in populations that are identified by their sexual
orientation or gender identities. For each of these opinions, I then provide a non-exhaustive list
of citations to studies published in science journals or other respected sources that support and
provide in part the basis of my opinion, quoting or summarizing relevant findings of each article.
2
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10. I begin by noting that the concepts at the core of these discussions—sexual
orientation and gender identity—are complex, not well defined, and disputed. Widely cited
researchers in the field, Lisa Diamond and Clifford Rosky, state that “sexual orientation is not
easy to define or measure. This ambiguity poses a problem for research.... Sexual orientation is a
multifaceted phenomenon, incorporating sexual attractions, sexual arousal, sexual fantasy, sexual
behavior, and sexual identity.... Different researchers have emphasized different facets, and the
facets themselves do not always coincide.” Lisa M. Diamond & Clifford J. Rosky, Scrutinizing
Immutability: Research on Sexual Orientation & U.S. Legal Advocacy for Sexual
Minorities, 53:4-5 J. OF SEX RESEARCH 363, 365 (2016).
11. Similarly, there is no precise, unambiguous, let alone agreed upon, definition of
“gender” or “gender identity.”
I. Numerous published studies suggest that sexual orientation is fluid across the life span; for many persons, their orientation is not immutable.
1. Lisa M. Diamond & Clifford J. Rosky, Scrutinizing Immutability: Research on Sexual Orientation & U.S. Legal Advocacy for Sexual
Minorities, 53:4-5 J. OF SEX RESEARCH 363, 365 (2016):
a) Studies “unequivocally demonstrate that same-sex and other-sex attractions do change over time in some individuals. The degree of change is difficult to reliably estimate, given differences in study measures, but the occurrence of change is indisputable.” (368-67)
b) “[A]rguments based on the immutability of sexual orientation are unscientific, given that scientific research does not indicate that sexual orientation is uniformly biologically determined at birth or that patterns of same-sex and other-sex attractions remain fixed over the life course.” (364)
3
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c) These authors summarized findings from the Ott et al. Growing Up Today Study (GUTS) (2011) (http://nhs2survey.org/gutswordpress/) that involved more than 13,000 youth this way: “Of the 7.5% of men and 8.7% of women who chose a nonheterosexual descriptor at ages 18 to 21, 43% of the men and 46% of the women chose a different category by age 23. Among the same-sex-attracted youth who changed, 57% of the men’s changes and 62% of the women’s changes involved switching to completely heterosexual.” (369-70)
d) These authors also summarized findings from the Dunedin Multidisciplinary Health and Development Study (DMHD) (available at https://dunedinstudy.otago.ac.nz/) this way: “[R]ates of change do not appear to decline as respondents get older. Rates of change in attractions among same-sex-attracted men ranged from 26% to 45%, and rates of change in same-sex-attracted women ranged from 55% to 60%. Among the same-sex attracted men reporting change, between 67% and 100% of the changes were toward heterosexuality, and this also was true for 83% to 91% of the same-sex-attracted women undergoing changes.” (368)
e) These authors summarized findings from the National Survey of Midlife Development in the United States (MIDUS I and II) this way: “[F]ew respondents (less than 1% among both men and women) described themselves as homosexual or bisexual. Yet among this group 64% of the women and 26% of the men identified their sexual orientation differently 10 years later (Mock & Eibach, 2012). Half of the men’s changes and 55% of the women’s changes involved switching to heterosexuality.” (370) (Information about this survey is available at http://midus.wisc.edu/scopeofstudy.php, as is access to the many papers published from the survey.)
2. Deborah L. Tolman et al, eds., APA Handbook of Sexuality & Psychology, (vol. 1, American Psychological Association, 2014) (available at http://dx.doi.org/10.1037/14193-000):
a) “...research on sexual minorities has long documented that many recall having undergone notable shifts in their patterns of sexual attractions, behaviors, or identities over time." (636)
b) “Although change in adolescence and emerging adulthood is understandable, change in adulthood contradicts the prevailing view of consistency in sexual orientation." (562)
c) “Over the course of life, individuals experience the following: (a) changes or fluctuations in sexual attractions, behaviors, and romantic partnerships;..." (619)
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3. Ritch C. Savin-Williams & Geoffrey L. Ream, Prevalence and Stability of Sexual Orientation Components During Adolescence and Young Adulthood, 36
ARCHIVES OF SEXUAL BEHAVIOR 385 (2007):
a) “Migration over time among sexual orientation components was in both directions, from opposite-sex attraction and behavior to same-sex attraction and behavior and vice versa.” (385)
b) “Evidence to support sexual orientation stability among nonheterosexuals is surprisingly meager. . . . Support for the instability of sexual orientation is far more prevalent—in both adult and adolescent populations. Among the 14% of Dutch adult males who reported ever having physical attraction to other males, about half noted that these feelings disappeared later in life (Sandfort, 1997).” (386)
c) “Although most (97%) heterosexuals maintained their heterosexual identity, nonheterosexuals frequently changed their identity label over the life course: 39% of gay males, 65% of lesbians, 66% of male bisexuals, and 77% of female bisexuals. The dimensional assessments of fantasy, attraction, and behavior reflected similar trends. Although roughly 90% of heterosexually identified individuals had none or one point changes during their lifetime, the majority of gay (52%), lesbian (80%), and bisexual (90%) identified individuals had multiple changes on the dimensional variables.” (387)
d) “The data … highlight the high proportion of participants with same- and both-sex attraction and behavior that migrated into opposite- sex [heterosexual] categories between waves.” (388)
e) “All attraction categories other than opposite-sex were associated with lower likelihood of stability over time. That is, individuals reporting any same-sex attractions were more likely to report subsequent shifts in their attractions than were individuals without any same-sex attractions.” (389)
4. Steven E. Mock & Richard P. Eibach, Stability and Change in Sexual
Orientation Identity Over a 10-year Period in Adulthood, 41 ARCHIVES OF
SEXUAL BEHAVIOR 642, 646 (2011) (summarizing findings from National Survey of Midlife Development in the United States (MIDUS I and II) this way: “Overall, 55 (2.15%) participants reported a different sexual orientation identity at Wave 2 compared to Wave 1. Among women, 1.36% with a heterosexual identity changed, 63.3% with a homosexual identity changed, and 64.71% with a bisexual
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identity changed. Among men, 0.78% with a heterosexual identity changed, 9.52% with a homosexual identity changed, and 47.06% with a bisexual identity changed.”).
5. American Psychiatric Association, “Position Statement on Issues Related to Homosexuality” (2013) (Glassgold Decl. Ex. D) (acknowledging non-fixity in sexual orientation: “The American Psychiatric Association believes that the causes of sexual orientation (whether homosexual or heterosexual) are not known at this time and likely are multifactorial including biological and behavioral roots which may vary between different individuals and may even vary over time.”).
II. The studies available, although limited, indicate that for a significant number of individuals who suffer gender dysphoria, most of whom identify as transgender, gender identity is not immutable.
1. American Psychiatric Association, Diagnostic and Statistical Manual of Mental Disorders 455 (5th Ed., 2013) (“Rates of persistence of gender dysphoria from childhood into adolescence or adulthood vary. In natal males, persistence has ranged from 2.2% to 30.0%. In natal females, persistence has ranged from 12% to 50%.” Quoted in Kenneth J. Zucker, The Myth of Persistence: Response to “A Critical Commentary on Follow-up Studies and ‘Desistance’ Theories About Transgender & Gender Nonconforming Children” by Temple Newhook et
al., 19:2 INT’L J. OF TRANSGENDERISM 1, 3 (2018).
2. Wylie C. Hembree et al., “Endocrine Treatment of Transsexual Persons:
An Endocrine Society Clinical Practice Guideline,” 94:9 J. CLIN. ENDOCRINOL.
METAB. 3132, 3132-33 (2009) (Glassgold Decl., Ex. T at 3132-33) (“Given the high rate of remission of GID [gender identity disorder] after the onset of puberty, we recommend against a complete social role change and hormone treatment in prepubertal children with GID.”).
3. Stephen B. Levine, Informed Consent for Transgendered Patients, J. OF
SEX & MARITAL THERAPY 7 (2018), DOI: 10.1080/0092623X.2018.1518885 (“It is important for parents to be told that the majority of cross-gender identified
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children desist from their current identities after puberty (Steensma, McGuire, Kreukels, Beekman, & Cohen-Kettenis, 2013; Zucker, 2018).”).
4. Stephen B. Levine, Ethical Concerns About Emerging Treatment
Paradigms for Gender Dysphoria, J. OF SEX & MARITAL THERAPY 10 (2017), DOI: 10.1080/0092623X.2017.1309482 (“A surgical group reported on a series of seven male-to-female patients requesting surgery to transform their surgically constructed female genitalia back to their original male form (Djordjevic, Bizic, Duisin, Bouman, & Buncamper, 2016).”).
III. Multiple studies report that voluntary therapeutic counsel is effective for some persons who are highly motivated to change sexual thoughts, attractions, and behavior.
1. American Psychological Association, “Report of the Am. Psychol. Ass’n Task Force on Appropriate Therapeutic Responses to Sexual Orientation,” (2009) (Haldeman Decl., Ex. B).
a) “Former participants in SOCE reported diverse evaluations of their experiences: Some individuals perceived that they had benefited from SOCE, . . . [These] individuals reported that SOCE was helpful—for example, it helped them live in a manner consistent with their faith. Some individuals described finding a sense of community through religious SOCE and valued having others with whom they could identify.” (3)
b) “For instance, participants reporting beneficial effects in some studies perceived changes to their sexuality, such as in their sexual orientation, gender identity, sexual behavior, sexual orientation identity….” (49)
2. Stanton L. Jones & Mark A. Yarhouse, A Longitudinal Study of Attempted
Religiously Mediated Sexual Orientation Change, 37 J. OF SEX & MARITAL
THERAPY 404 (2011) (23% of study participants experienced substantial reduction in homosexual attraction and substantial increase in heterosexual attraction and functioning. An additional 30% of participants experienced that homosexual attraction remained present only incidentally or in a way that did not seem to bring about distress, allowing them to live contentedly without overt sexual activity.).
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3. Robert L. Spitzer, Can Some Gay Men and Lesbians Change Their Sexual Orientation? 200 Participants Reporting a Change from Homosexual to
Heterosexual Orientation, 32:5 ARCHIVES OF SEXUAL BEHAVIOR 403, 413 (2003) (“This study indicates that some gay men and lesbians, following reparative therapy, report that they have made major changes from a predominantly homosexual orientation to a predominantly heterosexual orientation. The changes following reparative therapy were not limited to sexual behavior and sexual orientation self-identity. The changes encompassed sexual attraction, arousal, fantasy, yearning, and being bothered by homosexual feelings. The changes encompassed the core aspects of sexual orientation. Even participants who only made a limited change nevertheless regarded the therapy as extremely beneficial.”).
4. Elan Y. Karten & Jay C. Wade, Sexual Orientation Change Efforts in Men: A Client Perspective, 18:1 The J. of Men’s Studies 84 (2010).
a) Participants “experienced a decrease in homosexual feelings and behavior, an increase in heterosexual feelings and behavior, and a positive change in psychological functioning.” (97)
b) “Participants perceived the most helpful interventions to be a men's weekend/retreat, a psychologist, and a mentoring relationship.” (98)
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IV. Available science does not permit a conclusion that voluntary therapeutic conversations aiming for change in sexual attraction, thoughts, behavior, or orientation, or of gender-identity, are harmful to most patients.
1. 2009 APA Task Force Report (Haldeman Decl., Ex. B).
a) “Although the recent studies do not provide valid causal evidence of the efficacy of SOCE or of its harm, some recent studies document that there are people who perceive that they have been harmed through SOCE… just as other recent studies document that there are people who perceive that they have benefited from it. . . . . We conclude that there is a dearth of scientifically sound research on the safety of SOCE. Early and recent research studies provide no clear indication of the prevalence of harmful outcomes among people who have undergone efforts to change their sexual orientation or the frequency of occurrence of harm because no study to date of adequate scientific rigor has been explicitly designed to do so. Thus, we cannot conclude how likely it is that harm will occur from SOCE.” (42)
b) “[I]t is still unclear which techniques or methods may or may not be harmful.” (91)
2. Jones & Yarhouse (2011) (“The attempt to change sexual orientation did not appear to be harmful on average for these participants. The only statistically significant trends that emerged…indicated improving psychological symptoms.”). (424)
V. Available science does not permit a conclusion that voluntary therapeutic conversations aiming for change in sexual attraction, thoughts, behavior, or orientation, or of gender-identity, are ineffective.
1. 2009 APA Task Force Report (Haldeman Decl., Ex. B).
a) “We found that nonaversive and recent approaches to SOCE have not been rigorously evaluated. Given the limited amount of methodologically sound research, we cannot draw a conclusion regarding whether recent forms of SOCE are or are not effective.” (43)
b) “We thus concluded that there is little in the way of credible evidence that could clarify whether SOCE does or does not work in changing same-sex sexual attractions.” (28)
c) “There are no studies of adequate scientific rigor to conclude whether or not recent SOCE do or do not work to change a person’s sexual orientation.” (120)
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VI. Anecdotal stories, no matter how tragic, of suicide, depression, or distress in homosexual or transgender individuals who have undergone any particular treatment or therapy, do not constitute scientific evidence for causation or even correlation. This is because persons identifying as lesbian, gay, bisexual, and transgender exhibit substantially higher rates of suicidal ideation and attempts, and worse mental and physical health, than the general population.
A. Suicidal ideation, attempts, and completed suicide are more prevalent in the population of people who identify as homosexual or transgender.
1. John R. Blosnich et al., Suicidality & Sexual Orientation: Characteristics
of Symptom Severity, Disclosure, & Timing Across the Life Course, 86:1 AM. J.
ORTHOPSYCHIATRY 69, 69 (2016) (“Sexual minority men and women were more likely than heterosexual men and women to have disclosed suicide attempts to a medical professional.”).
2. Ron de Graaf et al., Suicidality & Sexual Orientation: Differences Between Men & Women in a General Population-Based Sample from the
Netherlands, 35:3 ARCHIVES OF SEXUAL BEHAVIOR 253, 253 (2006) (“This study suggests that even in a country with a comparatively tolerant climate regarding homosexuality, homosexual men were at much higher risk for suicidality than heterosexual men.”).
3. Daniel M. Fergusson et al., Is Sexual Orientation Related to Mental
Health Problems & Suicidality in Young People?, 56 ARCHIVES OF GEN.
PSYCHIATRY 876, 876-80 (1999) (found that non-heterosexual young people were at increased risk for suicidal behavior and ideation, major depression, generalized anxiety disorder, conduct disorder, tobacco dependence, and multiple disorders compared to the heterosexual subsample).
4. Robin M. Mathy et al., The Ass’n Between Relationship Markers of Sexual
Orientation & Suicide, 46 SOCIAL PSYCHIATRY AND PSYCHIATRIC EPIDEMIOLOGY 111, 111 (2011) (“The estimated age-adjusted suicide mortality risk for [men in same-sex registered domestic partnerships] was nearly eight times greater than for men with positive histories of heterosexual marriage and nearly twice as high for men who had never married.”).
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5. Ann P. Haas et al., Suicide & Suicide Risk in Lesbian, Gay, Bisexual, &
Transgender Populations: Rev. & Recommendations, 58 J. OF HOMOSEXUALITY 10 (2011).
a) Population-based surveys of U.S. adolescents since the 1990s indicate that suicide attempts are “two to seven times” more likely in “high school students who identify as LGB.” (17)
b) Studies cited in the report show that lesbian or bisexual women are likelier, on average, to experience suicidal ideation, that gay or bisexual men are more likely, on average, to attempt suicide, and that lifetime suicide attempts among non-heterosexuals are greater in men than in women. (15-19)
6. Martin Plöderl et al., Suicide Risk and Sexual Orientation: A Critical Rev.,
42 ARCHIVES OF SEXUAL BEHAVIOR 715, 722 (2013).
a) Among psychiatric patients, homosexual or bisexual populations are over-represented in “serious suicide attempts.” (722)
b) In nonclinical population-based studies, non-heterosexual status is found to be one of the strongest predictors of suicide attempts. (722)
c) “The most exhaustive collation of published and unpublished international studies on the association of suicide attempts and sexual orientation with different methodologies has produced a very consistent picture: nearly all studies found increased incidences of self-reported suicide attempts among sexual minorities.” (723)
d) “Given the evidence presented, sexual minority individuals are at greater risk for suicides and suicide attempts, compared to their heterosexual counterparts.” (724)
7. Mathy et al. (2011) (After reviewing the impact of sexual orientation on suicide rates in Denmark during the first twelve years after the legalization of same-sex registered domestic partnerships (RDPs), this study found that the estimated age-adjusted suicide rate for men in same-sex registered domestic partnerships was nearly eight times the rate for men in heterosexual marriages, and nearly twice the rate for men who had never married.). (112)
8. Martin Plöderl et al., The Relation Between Sexual Orientation & Suicide
Attempts in Austria, 39 ARCHIVES OF SEXUAL BEHAVIOR 1403, 1408 (2010) (“In
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our study, increased rates of suicide attempts among sexual minority individuals occurred for all dimensions of sexual orientation: sexual behavior, sexual fantasies, partner preference, and self-identification.”).
9. Haas et al. (2011) (reporting and discussing “a dramatic increased risk of completed suicide” in transgender populations) (26-28).
10. Jean M. Dixen et al., Psychosocial Characteristics of Applicants
Evaluated for Surgical Gender Reassignment, 13:3 ARCHIVES OF SEXUAL
BEHAVIOR 269, 272 (1984) (A clinical sample of transgender individuals requesting sex-reassignment surgery showed suicide attempt rates between 19% and 25%.).
11. Robin M. Mathy, Transgender Identity & Suicidality in a Nonclinical Sample: Sexual Orientation, Psychiatric History, & Compulsive Behaviors, 14:4
J. OF PSYCHOL. & HUMAN SEXUALITY 47, 47-65 (2003) (A large national survey in 2000 found transgender persons to report higher rates of suicide attempts than any group except lesbians.).
12. Anne P. Haas et al., Suicide Attempts Among Transgender & Gender Non- Conforming Adults: Findings of the National Transgender Discrimination Survey, Am. Found. for Suicide Prevention & the Williams Institute (2014).
a) “The prevalence of suicide attempts among respondents to the National Transgender Discrimination Survey (NTDS), conducted by the National Gay and Lesbian Task Force and National Center for Transgender Equality, is 41 percent, which vastly exceeds the 4.6 percent of the overall U.S. population who report a lifetime suicide attempt, and is also higher than the 10 – 20 percent of lesbian, gay and bisexual adults who report ever attempting suicide.” (2)
b) The authors note that “respondents who said they had received transition- related health care or wanted to have it someday were more likely to report having attempted suicide than those who said they did not want it.” (8)
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13. Kristen Clements-Nolle et al., HIV Prevalence, Risk Behaviors, Health Care Use, & Mental Health Status of Transgender Persons: Implications for
Public Health Intervention, 91:6 AM. J. OF PUBLIC HEALTH 915 (2001).
a) Of 392 male-to-female and 123 female-to-male transgender persons in study, 62% of the male-to-female and 55% of the female-to- male transgender persons were depressed at the time of the study, and 32% of each population had attempted suicide. (919)
b) “The prevalence of suicide attempts among male-to-female and female-to-male transgender persons in our study was much higher than that found in US household probability samples and a population-based sample of adult men reporting same-sex partners.” (919)
14. Centers for Disease Control & Prevention, “Youth Risk Behavior Survey: Data Summary & Trends Report 2007-2017,” CDC (2018), https://www.cdc.gov/healthyyouth/data/yrbs/pdf/trendsreport.pdf.
a) “Significantly higher percentages of lesbian, gay, or bisexual students (47.7%) and students not sure of their sexual identity (31.8%) seriously considered attempting suicide than heterosexual students (13.3%).” (84)
b) “Significantly higher percentages of lesbian, gay, or bisexual students (38.0%) and students not sure of their sexual identity (25.6%) made a suicide plan than heterosexual students (10.4%).” (85)
c) “Significantly higher percentages of lesbian, gay, or bisexual students (23.0%) and students not sure of their sexual identity (14.3%) attempted suicide than heterosexual students (5.4%).” (86)
d) “Significantly higher percentages of lesbian, gay, or bisexual students (7.5%) and students not sure of their sexual identity (5.6%) were injured in a suicide attempt than heterosexual students (1.7%).” (87)
B. Mental health problems other than suicidal ideation, attempts, and completions are more prevalent in the population of people who identify as homosexual.
1. 2018 CDC Report (“Significantly higher percentages of lesbian, gay, or bisexual students (63.0%) and students not sure of their sexual identity (46.4%) experienced persistent feelings of sadness or hopelessness than heterosexual students (27.5%).”) (83).
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2. Theo G. Sandfort et al., Same-Sex Sexual Behavior & Psychiatric
Disorders, 48 ARCHIVES OF GEN. PSYCHIATRY 85, 85 (2001) (discussing findings from the 2001 Netherlands Mental Health Survey and Incidence Study (NEMESIS): “…people with same-sex sexual behavior are at greater risk for psychiatric disorders.”).
3. D. Bradford Reich et al., Sexual Orientation & Relationship Choice in Borderline Personality Disorder Over Ten Years of Prospective Follow-up, 22:6
J. OF PERSONALITY DISORDERS 564, 564 (2008) (Study showed that individuals with borderline personality disorders “were significantly more likely than comparison subjects [with other personality disorders] to report homosexual or bisexual orientation and intimate same-sex relationships.”).
4. Michael King et al., A Systematic Rev. of Mental Disorder, Suicide, &
Deliberate Self Harm in Lesbian, Gay, & Bisexual People, 8:70 BMC
PSYCHIATRY 1, 1 (2008) (Non-heterosexual people face a “higher risk of mental disorder, suicidal ideation, substance misuse, and deliberate self-harm than heterosexual people,” with 2.47 times higher lifetime risk than heterosexuals for suicide attempts; twice as likely to experience depression over a 12-month period; and approximately 1.5 times as likely to experience anxiety disorders.).
5. Wendy B. Bostwick et al., Dimensions of Sexual Orientation & the
Prevalence of Mood & Anxiety Disorders in the United States, 100:3 AM. J. PUB.
HEALTH 468, 471 (2010) (Lesbian and bisexual women reported higher rates of anxiety disorder; also of lifetime mood disorders than women who identified as heterosexual: 44% in lesbians, 58.7% in bisexuals, compared to 30.5% in heterosexuals. Gay men had more than double the prevalence of lifetime mood disorders compared to men who identified as heterosexual (42.3% vs. 19.8%), and more than double the rate of any lifetime anxiety disorder (41.2% vs. 18.6%).).
6. Susan D. Cochran & Vickie M. Mays, Physical Health Complaints Among Lesbians, Gay Men, & Bisexual & Homosexually Experienced Heterosexual
Individuals: Results from the Ca. Quality of Life Survey, 97:11 AM. J. PUB.
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HEALTH 2048, 2048 (2007) (Non-heterosexual populations are at a higher risk of physical health problems in addition to mental health problems.).
7. Christine E. Grella et al., Influence of Gender, Sexual Orientation, & Need on Treatment Utilization for Substance Use & Mental Disorders: Findings from
the Ca. Quality of Life Survey, 9:52 BMC PSYCHIATRY 1, 1 (2008) (More than twice as many LGB individuals, compared to heterosexuals, had reported receiving treatment in the past twelve months (48.5% compared to 22.5%).).
8. Theo G.M. Sandfort et al., Sexual Orientation & Mental & Physical
Health Status: Findings From a Dutch Population Survey, 96:6 AM. J. PUB.
HEALTH 1119, 1119 (2006) (Non-heterosexual respondents reported experiencing higher numbers of acute mental health problems and reported worse general mental health than heterosexuals; lesbian and gay respondents were more likely to report chronic health problems.).
9. Haas et al. (2011) (Combined worldwide studies showed up to 50% higher rates of mental disorders and substance abuse among persons self-identifying in surveys as lesbian, gay, or bisexual; lesbian or bisexual women showed higher levels of substance abuse, while gay or bisexual men had higher rates of depression and panic disorder.).
C. Mental health problems other than suicidal ideation, attempts, and completions are more prevalent in the population of people who identify as transgender.
1. Riittakerttu Kaltiala-Heino et al., Two Years of Gender Identity Service for Minors: Overrepresentation of Natal Girls with Severe Problems in Adolescent
Development, 9:9 CHILD & ADOLESCENT PSYCHIATRY & MENTAL HEALTH 1, 5 (2015) (Reports 2015 Finland gender identity service statistics: 75% of adolescents assessed “had been or were currently undergoing child and adolescent psychiatric treatment for reasons other than gender dysphoria.”).
2. Lisa Littman, Parent Reports of Adolescents & Young Adults Perceived to Show Signs of a Rapid Onset of Gender Dysphoria, PLOS ONE at 13 (2018) (Parental survey concerning adolescents exhibiting Rapid Onset Gender
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Dysphoria reported that 62.5% of gender dysphoric adolescents had “a psychiatric disorder or neurodevelopmental disability preceding the onset of gender dysphoria.”).
3. Azadeh Mazaheri Meybodi et al., Psychiatric Axis I Comorbidities among
Patients with Gender Dysphoria, 2014 PSYCHIATRY J. 1 (2014).
a) “Eighty-three patients requesting sex reassignment surgery (SRS) were recruited and assessed … for DSM-IV Axis I disorders:” 62.7% had one or more. 33.7% had major depressive disorder, 20.5% had specific phobia, and 15.7% had adjustment disorder (the three most common). (1)
b) “Consistent with most earlier researches, the majority of patients with gender dysphoria had psychiatric Axis I comorbidity.” (1)
4. Gunter Heylens et al., Psychiatric Characteristics in Transsexual
Individuals: Multicentre Study in Four European Countries, 204 THE BRITISH
JOURNAL OF PSYCHIATRY 151, 151 (2014) (In a sample from four nations in Europe: 38% with GID have a current DSM-IV-TR Axis I Diagnosis, mostly affective and anxiety disorders. Nearly 70% had “a current and lifetime diagnosis.”).
5. Sari L. Reisner et al., Mental Health of Transgender Youth in Care at an Adolescent Urban Community Health Center: A Matched Retrospective Cohort
Study, 56:3 J. OF ADOLESCENT HEALTH 274, 279 (2015) (Transgender youth had an elevated risk of depression (50.6% vs. 20.6%) and anxiety (26.7% vs. 10.0%); a higher risk of suicidal ideation (31.1% vs. 11.1%), suicide attempts (17.2% vs. 6.1%), and self-harm without lethal intent (16.7% vs. 4.4%) relative to the matched controls; and a significantly greater proportion of transgender youth accessed inpatient mental health care (22.8% vs. 11.1%) and outpatient mental health care (45.6% vs. 16.1%) services.).
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VII. Multiple authors have reported data that show that the majority of individuals seeking counseling or therapy to change sexual orientation are motivated by religious convictions.
1. 2009 APA Task Force Report (Haldeman Decl., Ex. B).
a) “From our survey of recent publications and research, most SOCE currently seem directed to those holding conservative religious and political beliefs, and recent research on SOCE includes almost exclusively individuals who have strong religious beliefs.” (25)
b) “The recent literature on those who participate in SOCE identifies a population of predominantly White men who are strongly religious and participate in conservative faiths.” (52)
2. Diamond & Rosky (2016) (“[T]he majority of individuals seeking to change their sexual orientation report doing so for religious reasons rather than to escape discrimination.”) (6).
3. American Counseling Association, “Ethical issues related to conversion or reparative therapy,” ACA (Jan. 16, 2013) (Glassgold Decl., Ex. O at 4) (“Conversion therapy as a practice is a religious, not psychologically-based, practice…. The treatment may include techniques based in Christian faith-based methods….”).
4. Douglas C. Haldeman, The Pseudo-science of Sexual Orientation Conversion Therapy, 4:1 ANGLES 1, 2 (1999) (“Historically, most conversion therapy occurred in religious settings….”).
5. Douglas C. Haldeman, When Sexual & Religious Orientation Collide: Considerations in Working with Conflicted Same-Sex Attracted Male Clients, 32
THE COUNSELING PSYCHOLOGIST 691, 693 (2004) (“[T]he vast majority of those seeking sexual orientation change because of internal conflict have strong religious affiliations.”).
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EXHIBIT A Case 1:19-cv-00463-RJD-ST Document 25-1 Filed 04/11/19 Page 20 of 49 PageID #: 1452
LAWRENCE S. MAYER, MD, MS, PhD Professional Vita
April 2019
Primary interests: Biostatistical methods, applications and interpretations used in public health, epidemiology, medicine and social policy. Development implementation and evaluation of statistical methods for assessing health effects of preventive interventions and environmental exposures including life-style variables. Analysis of statistical and epidemiological issues arising from applying evidence-based medicine in a clinical or policy environment. Analysis of the statistical issues arising from applying epidemiological models in the diagnosis, treatment, and prognosis of disease. Particularly interested in the intersections among medicine, public health, epidemiology and statistics.
Current Positions:
Visiting Fellow in Human Flourishing, Harvard University, 2018- https://www.iq.harvard.edu/people/lawrence-s-mayer (for identification only)
Independent Scholar and Consultant: Working and consulting on the application of epidemiology, clinical trials and related methodologies in policy and legal settings.
Address:
4 Via Corsica Dana Point, CA 92629 949-291-7027
Recent Addresses:
Johns Hopkins Medicine Department of Psychiatry 5300 Alpha Commons Drive Baltimore, MD 21224-2764
Mayo Clinic Samuel C. Johnson Research Building 13212 East Shea Boulevard Scottsdale, AZ 85259
Arizona State University Department of Economics Tempe, AZ 85258
Education:
Undergraduate: Arizona State University (1963-64) and Ohio State University: Psychology (Pre-med), Page 1 of 30 Case 1:19-cv-00463-RJD-ST Document 25-1 Filed 04/11/19 Page 21 of 49 PageID #: 1453
BS, 1967, Phi Beta Kappa, magna cum laude with distinction in psychology. President’s award for outstanding graduate.
Professional: Ohio State University College of Medicine (pre-clinical), dual enrollment, 1966-68; Guy’s Hospital Medical School, London, MB (British MD), 1969; Junior House Officer, Associated Medical Schools, British Virgin Islands 1969-1970, MD qualified to practice as a Public Health Physician (psychiatric epidemiologist), British Health Service, 1970
Graduate: Ohio State University, Mathematics, MS, 1969; Mathematics (Statistics and Biostatistics); PhD, 1971
Other: MA in Arts and Letters, honoris causa, University of Pennsylvania, 1981
Previous Appointments:
Scholar in Residence, Department of Psychiatry, Johns Hopkins School of Medicine, 2016-2017
Professor of Statistics, Biostatistics, and Economics, Arizona State University, 1995-2016
(Affiliate) Professor, Mayo Clinic/ASU Program in Biomedical Informatics, 2008-2016
Professor of Psychiatry and Public Health (Part-time), School of Medicine and Bloomberg School of Public Health, Johns Hopkins University, 1989-2016
Detective (Fully Sworn), Prosecutor’s Office, Maricopa County, Arizona 1998-2016 (retired) and State Resource Officer (Fully Sworn), State of Arizona, 1983-1998
Professor of Epidemiology, College of Public Health, University of Arizona, 2000-2016
Research Staff Member, Mayo Clinic, 2014-2016
Consultant in Psychiatric Epidemiology, Banner Alzheimer’s Institute, Phoenix, 2003-2016
Chief, Epidemiology and Biostatistics Section, Integrated Fellowship in Cardiology, Phoenix, 1998- 2016
Faculty Member, Medical Education, Banner Good Samaritan Medical Center, Phoenix, 1993-2016
Visiting Professor, Division of Neuropsychiatry, Department of Psychiatry, Johns Hopkins Medicine, 2003-2004
Visiting Professor, Department of Biostatistics, Johns Hopkins School of Public Health, 1996-1997, 1989-1990
Director of Research, Maricopa Integrated Health System, 2003-2006
System Director, Research and Director and Medical Director of the Banner Health Research Institute, Banner Health System, Phoenix, 2001-2003
Director, Wharton Analysis Center, Wharton School; Associate Professor of Statistics, Public and Urban Policy, and Epidemiology, University of Pennsylvania, 1979-1983
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Visiting Professor, Department of Statistics, Stanford University, 1982-1983
Research Statistician and Lecturer with Rank of Associate Professor, Department of Statistics; Member, Center for Energy and Environmental Studies; Associate Master and Fellow, Princeton Inn College; Instructor, Woodrow Wilson School of Public Affairs; Princeton University, 1974-1979
Assistant Professor of Statistics (with secondary appointments in Political Science, Sociology, and Education) Virginia Polytechnic Institute and State University, 1971-1974
Assistant Professor, Department of Political Science, The Ohio State University, 1971
Teaching Assistant, Department of Mathematics, The Ohio State University, 1967-1968
Visiting Scholar, Department of Statistics, Stanford University, Summer Semesters, 1984-1988
Instructor, Summer Programs, Inter-University Consortium for Political and Social Research, Institute for Social Research, University of Michigan, 1971-1980
Other Major Appointments:
Clinical Professor, College of Medicine, University of Arizona, 1997-2006
Chair, Division of Research, Medical Professionals of Arizona, Phoenix, 2003-2006
Director, Good Samaritan Research Institute, Phoenix, 1999-2001
Consultant in Biostatistics and Clinical Epidemiology, Good Samaritan Medical Center, Phoenix, 1993-2000
Thesis Advisor, Masters in Public Health, School of Public Health, University of Arizona, 1996-1998
Member, Committee on Statistics, Graduate College, Arizona State University, 1989-2004
Member, Program on Law and the Social Sciences, Arizona State University, 1983-2004
Member, Committee on Malpractice Reform, Arizona Supreme Court, 1989-1993
Erskine Fellow, Occupational Medicine, University of Canterbury, Christchurch, New Zealand, 1989- 90
Scholarly Publications:
Hruz, PW, McHugh, PR, and Mayer, LS (2017) Growing Pains: Problems with Puberty Suppression in Treating Gender Dysphoria, The New Atlantis, Spring;(51): 1-24
Mayer, LS, and McHugh, PR (2016) Sexuality and Gender: Findings from the Biological, Psychological, and Social Sciences, The New Atlantis, Fall;(50): 7-143 (the entire issue – an invited issue)
Samus QM, Onyike CU, Johnston D, Mayer L, McNabney M, Baker AS, Brandt J, Rabins PV, Lyketsos CG, Rosenblatt A (2013) 12-month incidence, prevalence, persistence, and treatment of mental disorders among individuals recently admitted to assisted living facilities in Maryland. Int Psychogeriatr. 2013 May;25(5):721-731 Page 3 of 30 Case 1:19-cv-00463-RJD-ST Document 25-1 Filed 04/11/19 Page 23 of 49 PageID #: 1455
Kozubal DE, Samus QM, Bakare AA, Trecker CC, Wong HW, Guo H, Cheng J, Allen PX, Mayer LS, Jamison KR, Kaplin AI Separate may not be equal: a preliminary investigation of clinical correlates of electronic psychiatric record accessibility in academic medical centers. Int J Med Inform. 2013 Apr;82(4):260-7.
Bicket M, Samus Q, McNabney M, Onyike C, Mayer L, Brandt J, Rabins P, Lyketsos C, Rosenblatt A (2010) The Physical Environment Influences Neuropsychiatric Symptoms and Other Outcomes in Assisted Living Residents Int J Geriatr Psychiatry. Oct;25(10):1044-54.
Ramsey CM, Leoutsakos JM, Mayer LS, Eaton WW, Lee HB (2010) History of manic and hypomanic episodes and risk of incident cardiovascular disease: 11.5 year follow-up from the Baltimore Epidemiologic Catchment Area Study. J Affective Disord. Sep;125(1-3):35-41.
Samus QM, Rosenblatt A, Steele C, Baker A, Harper M, Brandt J, Mayer, LS, Rabins PV, and Lyketsos CG (2009) The Impact of Neuropsychiatric Symptoms and Environmental Characteristics on Quality of Life in Assisted Living Residents with Dementia. Journal of the American Geriatric Society (in press)
Samus QM, Mayer L, Onyike CU, Brandt J, Baker A, McNabney M, Rabins PV, Lyketsos CG, Rosenblatt A. (2009) Correlates Of Functional Dependence Among Recently Admitted Assisted Living Residents With And Without Dementia. J Am Med Dir Assoc. Jun;10(5):323-9.
Hayden KM, Zandi PP, West NA, Tschanz JT, Norton MC, Corcoran C, Breitner JC, Welsh- Bohmer KA; Cache County Study Group. Effects of family history and apolipoprotein E epsilon4 status on cognitive decline in the absence of Alzheimer dementia: the Cache County Study.Arch Neurol. 2009 Nov;66(11):1378-83.
Welsh-Bohmer KA, Ostbye T, Sanders L, Pieper CF, Hayden KM, Tschanz JT, …, Mayer L, … (2009) Neuropsychological performance in advanced age: influences of demographic factors and Apolipoprotein E: findings from the Cache County Memory Study. Clin Neuropsycho 2009 Jan;23(1):77-99. Epub 2008 Jun 10.
Samus QM, Mayer L, Baker A, McNabney M, Brandt J, Onyike CU, Rabins PV, Lyketsos CG, Rosenblatt A. (2008) Characteristics And Outcomes For Assisted Living Residents With Dementia: Comparing Dementia-Specific Care Units With Non-Dementia-Specific Care Units. Journal of the American Geriatric Society. July;56(7)1361-3
Rao V, Spiro J, Samus QM, Steele C, Baker A, Brandt J, Mayer L, Lyketsos CG, Rosenblatt A. (2008) Insomnia And Daytime Sleepiness In People With Dementia Residing In Assisted Living: Findings From The Maryland Assisted Living Study. Int J Geriatr Psychiatry. Feb(23)199-206 Rosenblatt A, Samus QM, Onyike CU, Baker AS, McNabney M, Mayer LS, Brandt J, Lyketsos CG. (2008) Acetylcholinesterase Inhibitors In Assisted Living: Patterns Of Use And Association With Retention. Int J Geriatr Psychiatry Feb;23(2):178-84.
Tighe SK, Leoutsakos JM, C Carlson M, Onyike CU, Samus Q, Baker A, Brandt J, Rabins PV, Mayer L, Rosenblatt A, Lyketsos CG. (2008) The Association Between Activity Participation And Time To Discharge In The Assisted Living Setting Int J Geriatr Psychiatry Jun:23(6):586-91
Steinberg M, Shao H, Zandi P, Lyketsos CG, Welsh-Bohmer KA, Norton MC, Breitner JC, Steffens DC, Tschanz JT…Mayer, L….(2008) Point and 5-year period prevalence of neuropsychiatric symptoms in dementia: the Cache County Study Int J Geriatr Psychiatry Feb;23(2):170-7. Page 4 of 30 Case 1:19-cv-00463-RJD-ST Document 25-1 Filed 04/11/19 Page 24 of 49 PageID #: 1456
Lyketsos CG, Samus QM, Baker A, McNabney M, Onyike CU, Mayer LS, Brandt J, Rabins P, Rosenblatt A. (2007) Effect Of Dementia And Treatment Of Dementia On Time To Discharge From Assisted Living Facilities: The Maryland Assisted Living Study. J Am Geriatr Soc;55(7):1031-7
Mayer LS, Bay RC, Politis A, Steinberg M, Steele C, Baker AS, Rabins PV, Lyketsos CG. Comparison Of Three Rating Scales As Outcome Measures For Treatment Trials Of Depression In Alzheimer Disease: Findings From DIADS (2006) Int J Geriatr Psychiatry. Oct;21(10):930-6
Maust DT, Onyike CU, Sheppard JM, Mayer LS, Samus QM, Brandt J, Rabins PV, Lyketsos CG, Rosenblatt A. (2006) Predictors Of Caregiver Unawareness And Nontreatment Of Dementia Among Residents Of Assisted Living Facilities: The Maryland Assisted Living Study. Am J Geriatr Psychiatry. 2006 Aug;14(8):668-75
Khachaturian AS, Zandi PP, Lyketsos CG, Hayden KM, Skoog I, Norton MC, Tschanz JT, Mayer LS, Welsh-Bohmer KA, Breitner JC. (2006) Antihypertensive Medication Use And Incident Alzheimer Disease: The Cache County Study. Arch Neurol. 2006 May;63(5):686-92
Mayer LS, Bay RC, Politis A, Steinberg M, Steele C, Baker AS, Rabins PV, Lyketsos CG. (2006) Comparison Of Three Rating Scales As Outcome Measures For Treatment Trials Of Depression In Alzheimer Disease: Findings From DIADS Int J Geriatr Psychiatry. 21(10):930-6
Watson, Lea C., Lehmann, Susan, Mayer, Lawrence, Samus, Quincy, Baker, Alva, Brandt, Jason, Steele, Cynthia, Rabins, Peter, Rosenblatt, Adam, Lyketsos, Constantine (2006) Depression in Assisted Living Is Common and Related to Physical Burden Am. J. Geriatr. Psychiatry.14: 876-883
Samus, Quincy M., Rosenblatt, Adam, Onyike, Chiadi, Steele, Cynthia, Baker, Alva, Harper, Michael, Brandt, Jason, Mayer, Lawrence, Rabins, Peter V., Lyketsos, Constantine G. (2006) Correlates of Caregiver-Rated Quality of Life in Assisted Living: The Maryland Assisted Living Study J Gerontol B Psychol Sci Soc Sci 2006 61: P311-314
Maust, Donovan T., Onyike, Chiadi U., Sheppard, Jeannie-Marie E., Mayer, Lawrence S., Samus, Quincy M., Brandt, Jason, Rabins, Peter V., Lyketsos, Constantine G., Rosenblatt, Adam (2006) Predictors of Caregiver Unawareness and Nontreatment of Dementia Among Residents of Assisted Living Facilities: The Maryland Assisted Living Study Am. J. Geriatr. Psychiatry.14: 668-675
Burdick DJ, Rosenblatt A, Samus QM, Steele C, Baker A, Harper M, Mayer L, Brandt J, Rabins P, Lyketsos CG. (2005) Predictors of functional impairment in residents of assisted-living facilities: the Maryland Assisted Living study. J Gerontol A Biol Sci Med Sci. Feb;60(2):258-64
Rao V, Spiro JR, Samus QM, Rosenblatt A, Steele C, Baker A, Harper M, Brandt J, Mayer L, Rabins PV, Lyketsos CG. (2005) Sleep disturbances in the elderly residing in assisted living: findings from the Maryland Assisted Living Study Int J Geriatr Psychiatry. 2005 Oct;20(10):956-66
Samus QM, Rosenblatt A, Steele C, Baker A, Harper M, Brandt J, Mayer L, Rabins PV, Lyketsos CG. (2005) The association of neuropsychiatric symptoms and environment with quality of life in assisted living residents with dementia Gerontologist. 45 Spec No 1(1):19-26
Politis, AM, Vozzella S, Mayer LS, Onyike CU, Baker A, and Lyketsos, CG (2004) A randomized, controlled, clinical trial of activity therapy for apathy in patients with dementia residing in long-term care, Intl Jour Geriatric Psychiatry, November, 2004, 19(11), 2069-2079
Khachaturian AS, Corcoran, CD, Mayer LS, Zandi PP, and Breitner JC (2004) Apolipoprotein E Epsilon4 Count Affects Age At Onset Of Alzheimer’s Disease, But Not Lifetime Susceptibility: The Page 5 of 30 Case 1:19-cv-00463-RJD-ST Document 25-1 Filed 04/11/19 Page 25 of 49 PageID #: 1457
Cache County Study (2004) Archives of General Psychiatry, May, 61(5), 518-24
Politis AM, Mayer LS, Passa M, Maillis A, and Lyketsos, CG (2004) Validity and Reliability of the Newly Translated Hellenic Neuropsychiatry Inventory (H-NPI) Applied to Greek Outpatients with Alzheimer’s Disease: A study of Disturbing Behaviors Among Referrals to a Memory Clinic (2004) Int Jour Geriatric Psychiatry (2004) March, 2004, 19(3), 203-8
Zandi, P. Carlson, C., Plassman, B., Welsh-Bolmer, K., Mayer, L., Steffens, D., and Breitner, J. (2002) Hormone Replacement Therapy and the Incidence of Alzheimer Disease in Older Women: The Cache County Study, Journal of the American Medical Association, 288 (17), November, 2123-2129
Zandi, P., Anthony, J. Hayden, K. Mehta, D., Mayer, L., and Breitner, J. (2002) Reduced Incidence Of AD With NSAIDS But Not H2 Receptor Antagonists, Neurology, 59:880-886
Miech, R., Breitner, J.C.S., Zandi, P.P., Khachaturian, A.S., Anthony, J. and Mayer, L. (2002) Incidence of AD May Decline in the Early 90’s for Men, Later for Women: The Cache County Study, Neurology, 58 (2), 209-218
Merrill, R., Merrill, A., and Mayer, L. (2000) “Factors Associated with No Surgery or Radiation Therapy for Invasive Cervical Cancer in Black and White Women”, Ethnicity and Disease, 10(2), 248-256
Rebok, G., Hawkins, W., Kellam, S., and Mayer, L. (1997) The Role of Concentration Problems on the Course of Aggressive and Shy Behavior in an Epidemiologically-Based Preventive Trials, Child Development, 23, 465-486
Rebok, G. W., Hawkins, W. E., Krener, P., Mayer, L.S., and Kellam, S.G. (1996) "The Effect of Concentration Problems on the Malleability of Children's Aggressive and Shy Behavior, Journal of the American Academy of Child and Adolescent Psychiatry, 35, 193-203
Kellam, S., Mayer, L., Rebok, G. and Hawkins, W. (1996) "The Effects of Improving Achievement on Aggressive Behavior and of Improving Aggressive Behavior on Achievement Through Two Preventive Interventions: An Investigation of Causal Paths", in Dohrenwend (ed.) Adversity, Stress and Psychopathol- ogy , American Psychiatric Press, American Psychiatric Association, [a refereed journal published as a monograph series]
Kellam, S., Rebok G., Mayer, L., Ialongo, N. and Kalodner, C. (1994) "Depressive Symptoms Over First Grade and Their Response to a Developmental Epidemiologically Based Preventive Trial Aimed at Improving Achievement" , Development and Psychopathology, 6, 463-481
Kellam, S.G., Rebok, G.W., Wilson, R. and Mayer, L.S.(1994) "The Social Field of the Classroom: Context for the Developmental Epidemiological Study of Aggressive Behavior", in Adolescence in Context: The Interplay of Family, School, Peers, and Work in Adjustment, Silbereisen, R. K. and Todt, E. (eds), New York: Springer-Verlag, 390-408
Kellam, S., Rebok G., Ialongo, N., and Mayer, L. (1994) "The Course and Malleability of Aggressive Behavior from Early First Grade Into Middle School: Results of a Developmental Epidemiological Based Preventive Trial", The Journal of Child Psychology and Psychiatry, 35(2), 259-281
Mayer, L. S. (1994) "On Cross-Lagged Panel Studies with Serially Correlated Errors," Frontiers in Econometrics, G. Maddala (ed), Springer-Verlag, 336-345
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Dolan, L. J., Kellam, S. G., Brown, C. H., Werthamer-Larson, L., Rebok, G. W., Mayer, L. S., Laudolff, J. and Turkkan, J. S.(1993) "The Short-term Impact of Two Classroom-based Preventive Interventions on Aggressive and Shy Behaviors and Poor Achievement", Journal of Applied Developmental Psychology, 14, 317-345
Kellam, S. G., Werthamer-Larson, L., Dolan, L. J., Brown, C. H., Mayer, L. S., Rebok, G. R., Anthony, J. C., Laudolff, J. and Edelsohn, G.(1991) "Developmental Epidemiologically Based Preventive Trials: Baseline Modelling of Early Target Behaviors and Depressive Symptoms", American Journal of Community Psychology, 19, 563-584
Rebok, G.R., Kellam, S. G., Dolan, L. J., Werthamer-Larsson, L., Edwards, E. J., and Mayer, L. S., and Brown, G.H. (1991) "Preventing Early Risk Behavior: Process Issues and Problem Areas in Prevention Research", The Community Psychologist, 24, 18-21
Mayer, L.S. and Carroll, S.S. (1991) "Modeling the Contemporaneous Relationship in a Continuous Variable Panel Model", Communications in Statistics, 17, 463-477
Mayer, L.S. and Carroll, S.S. (1988) "Measures of Dependence for Cross-Lagged Panel Models," Sociological Methods and Research, 17(1) August, 248-260
Mayer, L.S. and Carroll, S.S. (1987) "Testing for Homogeneity in Cross-Lagged Panel Studies, Communications in Statistics, 16(9), 2487-2510
Mayer, L.S. and Carroll, S.S. (1987) "Testing for Lagged, Cotemporal, and Total Dependence in Cross-Lagged Panel Analysis, Sociological Methods and Research, 16(2), 187-217
Mayer, L.S. (1986) "Statistical Inferences for Cross-Lagged Panel Models Without the Assumption of Normal Errors," Social Science Research, 15, 28-42
Mayer, L.S. and Carroll, S.S. (1986) "Detecting Serial Correlation in the Error Structure of a Cross- Lagged Panel Model," Communications in Statistics, 15, 347-366
Carroll, S.S. and Mayer, L.S. (1986) "Analysis of the Cross-Effects in a Cross-Lagged Panel Study," Communication in Statistics, 15, 3361-3395
Mayer, L.S. (1986) "On Cross-Lagged Panel Studies with Serially Correlated Errors," Journal of Business and Economic Statistics, 4, 347-357
Mayer, L.S. (1981). "A Comment on 'Estimating Volumes of Remaining Fossil Fuel Resources'," Journal of the American Statistical Association, 76, 551-554
Mayer, L.S. and Horowitz, C.E. (1979). "The Effect of Price on the Residential Demand for Electricity: A Statistical Study," Energy, 4, 87-99
Mayer, L.S. (1978). "Estimating the Effects of the Onset of the Energy Crisis on Residential Energy Demand," Resource and Energy, 1, 57-92
Mayer, L.S. and Benjamin, Y. (1978). "Modeling Residential Demand for Natural Gas as a Function of the Coldness of the Month," Energy and Buildings, 1, 301-312
Mayer, L.S., Hoyer, R.W., and Bernd, J.L. (1977). "Some Problems in the Validation of Mathematical and Stochastic Models of Political Phenomena: The Case of the Supreme Court," American Journal of Political Science, 21, 381-403 Page 7 of 30 Case 1:19-cv-00463-RJD-ST Document 25-1 Filed 04/11/19 Page 27 of 49 PageID #: 1459
Mayer, L.S. and Younger, M.S. (1976). "Estimation of Standardized Regression Coefficients," Journal of the American Statistical Association, 71, 154-157
Mayer, L.S. and Robinson, J.A. (1977). "Measures of Association for Multiple Regression Models with Ordinal Predictor Variables," Sociological Methodology, 1978, Jossey-Bass, 141-162
Jensen, D.R. and Mayer, L.S. (1977). "Some Variational Results and Their Applications to Problems in Multiple Inference," Annals of Statistics, 5, 922-931
Horowitz, C.E. and Mayer, L.S. (1977). "The Relationship Between the Price and Demand for Natural Gas: A Partially Controlled Study," Energy Research, 1, 193-222
Hoyer, R.W. and Mayer, L.S. (1976). "On Electoral Equilibria in a Spatial Analysis Based on the Theory of Games," Journal of Politics, 38, 116-171
Hoyer, R.W. and Mayer, L.S. (1975). "On Social Preference Orderings Under Majority Rule," Econometrica, 43, 803-806
Mayer, L.S., and Good, I.J. (1975). “Is Minimax Regret Applicable to Voting Decisions? American Political Science Review, 69, 916-917
Good, I.J. and Mayer, L.S. (1975). "Estimating the Efficacy of a Vote," Behavioral Science, 20, January, 25-33
Mayer, L.S. and Younger, M.S. (1975). "Multiple Indicators and the Relationship Between Abstract Variables," Sociological Methodology, 1975, 191-211
Jensen, D.R. and Mayer, L.S. (1975). "Normal-Theory Approximations to Tests for Linear Hypotheses," Annals of Statistics, 3, 429-444
Jensen, D.R., Mayer, L.S. and Myers, R.H. (1975). "Optimal Designs and Large-Sample Tests for Linear Hypotheses," Biometrika, 62, 71-78
Hoyer, R.W. and Mayer, L.S. (1974). "Comparing Strategies in a Spatial Model of Electoral Competition," American Journal of Political Science, 18, 501-523
Bush, W. and Mayer, L.S. (1974). "Some Implications of Anarchy for the Distribution of Property," Journal of Economic Theory, 4, 401-411
Mayer, L.S., Singh, J. and Willke, T.A. (1974). "Utilizing Initial Estimates in Estimating the Coefficients in a Linear Model," Journal of the American Statistical Association, 69, 219-222
Mayer, L.S. and Younger, M.S. (1974). "Procedures for Estimating Standardized Regression Coefficients from Sample Data," Sociological Methods and Research, 1, 431-453
Mayer, L.S. and Good, I.J. (1974). "On Ordinal Prediction Problems," Social Forces, 52 (4), 543- 549
Mayer, L.S. (1974). "On the Use of Non-Random Exogenous Variables in Path Analysis," American Sociological Review, 39, 891-893
Klemmack, D.L., Leggette, T.A. and Mayer, L.S. (1973). "Non-Random Exogenous Variables in Path Analysis," American Sociological Review, 38 (December), 778-784 Page 8 of 30 Case 1:19-cv-00463-RJD-ST Document 25-1 Filed 04/11/19 Page 28 of 49 PageID #: 1460
Mayer, L.S. and Hendrickson, A. (1973). "A Method for Constructing an Optimal Regression Design After an Initial Set of Input Values Has Been Selected," Communications in Statistics, 2(5), 465-477
Mayer, L.S. and Willke, T.A. (1973). "On Biased Estimation in Linear Models," Technometrics, 15, 497-508
Mayer, L.S. (1973). "Estimating a Correlation Coefficient When One Variable is Not Directly Observed," Journal of the American Statistical Association, 68, 420-421
Burgess, P.M. and Mayer, L.S. (1973). "Simulation and Society, A Review Essay," Journal of Regional Science, 12, 303-311
Good, I.J. and Mayer, L.S. (1973). "On Surfaces of Constant Societal Loss in a Model of Social Choice," Journal of Mathematical Sociology, 2, 209-219
Mayer, L.S. (1972). "Using Monotone Regression to Estimate a Correlation Coefficient," Sociological Methodology, (Herbert Costner, ed.), Jossey-Bass: San Francisco, 200-212
Mayer, L.S. (1972). "An Analysis of Measures of Crosscutting and Fragmentation," Comparative Politics, 4, 405-415
Mayer, L.S. (1971). "Comment on 'The Assignment of Numbers to Rank Order Categories'," American Sociological Review, 35, 916-917
Mayer, L.S. (1971). "A Note on Treating Ordinal Data as Interval Data," American Sociological Review, 36, 519-520 `` Mayer, L.S. (1971). "A Note on An Axiomatic Model of Voting Bodies," American Political Science Review, 65, 764-65
Mayer. L.S. (1971). "A Method of Cluster Analysis When There Exists Multiple Indicators of a Theoretic Concept," Biometrics, 27, 143-155
Mayer, L.S. (1971). "A Comment on 'A Theorem on Voting'," American Political Science Review, 65, 779-780
Research Monographs:
Energy Consumption Measurement: Data Needs for Public Policy, (1977) Committee on Measurement of Energy Consumption, Washington: National Academy of Science
Mayer, L.S. (1976). An Analysis of Alternative Voter Registration Systems, Modules in Applied Mathematics, Washington: Mathematical Association of America
Chapters in Research Monographs:
Mayer, L. S. (1994) "On Cross-Lagged Panel Studies with Serially Correlated Errors," Frontiers in Econometrics, G. Maddala (ed), 154-165
Mayer, L.S. (1980). "The Effects of Price on Energy Demand: Econometrics Versus Exploratory Data Analysis," in Evaluation of Econometric Models (J. Kmenta and J. Ramsey, eds.), Academic Press, 15-45 Page 9 of 30 Case 1:19-cv-00463-RJD-ST Document 25-1 Filed 04/11/19 Page 29 of 49 PageID #: 1461
Mayer, L.S. and Benjamin, Y. (1980). "Modelling Residential Demand for Natural Gas as a Function of the Coldness of the Month," in Saving Energy in the Home, (R. Socolow, ed.) New York: Ballinger
Bush, W. and Mayer, L.S. (1976). "On the Economics of Human Fertility," in Essays on Unorthodox Economic Strategies: Anarchy, Politics and Population, (A.T. Denzau and R.J. Mackay, eds.), University Publications, 163-181
Mayer, L.S. (1974). "Optimal Voting Behavior in a Two-Party Primary", in Applications of Mathematics in Political Science, Vol. VIII, (J. Herndon and J. Bernd, eds.), Charlottesville: University of Virginia Press, 4-14
Published Book Reviews:
On the Verge: The Legal Fight of Travellers in England for their Rights (many authors), Romani Studies, 2001, 144-146
Firms and Markets (C. Tucker and R. Fuller, eds.), Perspective, Winter, 1988, 41
Social Science and Social Policy (R. Shotland and M. Mark, eds.), Perspective, April, 1986, 60
Principles of Epidemiology (Kleinbaum, Kupper and Morgenstern) Journal of the American Statistical Association, July/August 1984, 108
U.S. Interests and Global Natural Resources (Castle and Price, eds.), Perspective, September, 1984, 725-726
Proximity and Preference: Problems in the Multidimensional Analysis of Large Data Sets (R. Golledge and J. Raynor, eds.), Journal of the American Statistical Association, September, 1983, 78, 734
Statistical Applications in the Spatial Sciences (N. Wrigley, ed.), Journal of the American Statistical Association, June, 1983, 78, 509-510
Power, Voting, and Voting Power (Manfred J. Holler, ed.), Perspective, February, 1983
Exploratory Data Analysis (J. Tukey), Evaluation and Program Planning , 1981, 4, 195-196
On the Social Use of Information (A. Wissel), Perspective, June, 1977, Vol. 6, No. 5
Simulation Model Building: A Statistical Approach to Modeling in the Social Sciences With The Simulation Method (U. Norlen), Perspective, March 1977, Vol. 6, No. 2
Research Methods in the Social Sciences (D. Nachimas and C. Nachimas), Perspective, November 1976, Vol. 5, No. 9
Registering Voters by Mail: The Maryland and New Jersey Experience (R. Smolka), Perspective, October 1975, Vol. 4, No. 8
Other Professional Activities:
Guest Lecture, Statistics and Epidemiology in Court, University of Maryland Law School, March, 2012
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Editorial Board Member, Journal of Cardiology Research, 2003-
Member, Development Board, Copper Ridge Institute, Sykesville, MD, 1998-2000
Member, Expert Panel, Sexually Transmitted Disease and Teens, W. T. Grant Foundation, 2000-2001
Advisor, Sexually Transmitted Diseases & the Internet, American Social Health Association, 2000-2001
Invited Member, Panel on Mental Health Problems of Asylum Seekers, University of Greenwich, July 2000
Invited participant, Expert Panel on Mortality Associated with Alternative Fuels, Department of Energy, Carmel, May, 2000
Chief, Epidemiology and Biostatistics Branch, Phoenix Integrated Residency in Cardiology, 1999-
Clinical Professor, Prevention Center, College of Medicine, University of Arizona, 1999-
Member, Faculty of the Psychiatry Residency Program, Good Samaritan, 1998 –
Member of the Board of Directors, Palms Clinic, Phoenix, 1998-
Invited Participant, US Environmental Protection Agency Expert Panel on Cryptosporidium, October, 1998
Member, Evaluation Panel, Graduate Programs, University of Greenwich, London, August, 1998
Expert Witness, Appropriations Hearing on NIH Budget, US Senate, October, 1997-
Member, Expert Review Committee on Grant Applications and Awards, Health Care and Promotion Fund, Hong Kong, 1996-1998
Member, Clinical Committee, Health Services Advisory Group, Arizona, [the arm of the Medicare system that advises Medicare on reimbursements], 1994-1996
Alternate Member, Institutional Review Board, Samaritan Health Systems 1994-2001
Invited Attendee, Workshop on Psychosocial Research, American Psychiatric Association, Massachusetts General Hospital, Boston, October, 1996
Invited Attendee, Risk Estimation Conference, Environmental Protection Agency, Durham, North Carolina, September, 1996
Invited Attendee, Society for Prevention Research, Annual Conference, Puerto Rico, May, 1996
Proposal Evaluation Site Visit, Raptor Research Center, Boise State University, March 1996
Workshop Attendee, The Epidemiology of Avian Mortality, California Energy Commission, Sacramento, California, January, 1996
Invited Attendee, Prevention Science and Methodology Conference, Baltimore, MD, October, 1995
Invited Attendee, Avian Windpower Planning Meeting, Palm Springs, September, 1995
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Invited Attendee, US Department of Energy Course on Risk Assessment, Boulder, July 1995
Invited Attendee, Mini-conference on Measuring Health Outcomes, Phoenix, March 1995
Invited Attendee, Private Conference on Wind Energy Research, California Energy Commission, Grand Island, California, December, 1994
Invited Participant, Workshop on Prevention Methodology, University of South Florida, Baltimore, December, 1994
Invited Participant, National Conference on Prevention Research, Washington, DC, December, 1994
Invited Consultant, California Energy Commission, Flagstaff, Arizona, November, 1994
Invited Participant, Workshop on the Science of Prevention, NIMH, Baltimore, December, 1994
Invited Participant, Meeting on Renewable Energy, California Energy Commission, Flagstaff, Arizona, November, 1994
Invited Participant, Workshop on Prevention Methodology, Oregon Social Learning Center, Eugene Oregon, August, 1994
Invited Technical Advisor, National Planning Meeting on Wind Power and Avian Mortality, Lakewood, CO, July, 1994
Invited Participant, Workshop on Biostatistical Methods in Preventive Mental Health Research, College of Public Health, University of South Florida, Tampa, March, 1994
Invited Participant, Biomedical Effects of Renewable Energy, Invited Conference, US Department of Energy, Washington, DC February, 1994
Member, Special Study Section, National Institute of Health, 1993-
Invited Participant, Avian Mortality Taskforce Meeting, October, Pleasonton, CA, December, 1993
Invited Participant, Conference on Avian Mortality and Wind Energy, Pacific Gas and Electric, Livermore, CA, October, 1993
Invited Participant, Prevention Center Directors Meeting, National Institute of Mental Health, Tysons Corner, September, 1993
Invited Participant, National Conference on Prevention Research, McLean, Virginia, April, 1993.
Invited Participant, Prevention Center Directors Meeting, National Institute of Mental Health, Rockville, September, 1992
Invited Participant, Prevention Center Directors Meeting, National Institute of Mental Health, Rockville, September, 1991
Invited Participant, Conference on the Future of Prevention Research, National Institute of Mental Health, Washington, DC, July, 1991
Invited Participant, Workshop on Development of Delinquency, National Academy of Science, Page 12 of 30 Case 1:19-cv-00463-RJD-ST Document 25-1 Filed 04/11/19 Page 32 of 49 PageID #: 1464
Woods Hole Study Center, July, 1991
Invited Participant, Workshop on Preventive Research, National Institute of Mental Health, October, 1990
Invited Lecturer, Exploratory Data Analysis, The Bootstrap and Panel Models in Occupational Medicine, lecture series, College of Business Administration, University of Canterbury, Christchurch, New Zealand, September - October, 1989
Invited Host, Mini-conference on The Epidemiology of Bladder Cancer, August, 1988, Lenox, Massachusetts
Expert Witness, Department of Public Health, Commonwealth of Massachusetts, July, 1988
Expert Witness, Department of Labor and Industry, Commonwealth of Massachusetts, July, 1988
Invited Participant, Workshop in Multidimensional Analysis, Information Theory and Asymptotic Methods, Stanford University, July 1983
Assisted in Preparation and Coordination, Conference on Science and Technology in the Soviet Union, Stanford University, July, 1983
Session Organizer, International Conference on Energy Use Management, Berlin, October, 1981
Member, Committee on Industrial Use of Solar Energy, Solar Energy Research Institute, Golden, Colorado, 1979-1981
Press Conference on Wharton's Support to Litigation Project Award, April, 1981, Philadelphia
Invited Participant, Workshop on Model Validation, Department of Economics, New York University, April, 1980.
Expert Witness, Hearings on Energy Tax Exemptions, Energy Committee, Pennsylvania State Assembly, April, 1980
Lecturer, Workshop in Environmental Policy, Florida Atlantic University, March, 1980
Interviewed on Feasibility of Philadelphia's Refinery Tax Proposal, WUSL Radio, Philadelphia, November, 1980
Member, Committee on Health Manpower Training, Department of Health, New Jersey, 1976-79.
Interviewed on Model Validation, WPEN Radio, Philadelphia, November, 1979.
Interviewed on Value of Energy Forecasts, Philadelphia Inquirer, October, 1979.
Invited Panelist, Panel on Energy Models in Energy Policy-making, Program in Science Technology and Public Policy, George Washington University, Washington, D.C., October, 1979
Organizer, Workshop on Resource Estimation, Department of Energy Statistical Symposium, Gatlinburg, Tennessee, October, 1979
Session Chairperson, Special Topics Meetings on Regression, Institute of Mathematical Statistics, Page 13 of 30 Case 1:19-cv-00463-RJD-ST Document 25-1 Filed 04/11/19 Page 33 of 49 PageID #: 1465
October, 1979
Invited Participant, Workshop on the Measurement and Interpretation of Model Confidence, National Bureau of Standards, U.S. Department of Commerce, Washington, D.C., October, 1979
Invited Participant, Workshop on Measuring Model Confidence, National Bureau of Standards, Gaithersburg, MD, October 1979
Expert Witness, Hearings on State Health Benefits, Ohio State Assembly, February, 1979
Member, Committee on Model Evaluation, General Accounting Office, United States Congress, 1977-1978.
Participant, Workshop on Assessment of Energy Models, Massachusetts Institute of Technology, October, 1978.
Organizer, Session on Multivariate Statistics, Annual Meeting, Institute of Mathematical Statistics, August, 1978
Lecturer, Program on Environmental Management, Florida Atlantic University, April, 1978
Expert Witness, Hearings on Local Energy Policies, Subcommittee on Energy and Power, Committee on Interstate and Foreign Commerce, U.S. House of Representatives, May, 1978
Invited Panelist, Policy Workshop on Energy Policy, Swarthmore College, March, 1978
Chairperson, Committee on Membership, Institute of Mathematical Statistics, 1974-78
Invited Participant, Workshop on Energy Information, Stanford University, December 1977
Invited Participant, Conference on Criteria for Evaluation of Econometric Models, University of Michigan, June 1977
Expert Witness, Hearings on Health Impacts of Energy Conservation, Commerce Committee, US House Representatives, April, 1977
Conference Chair, Conference on the Analysis of Large Data Sets, Institute of Mathematical Statistics and American Statistical Association, Dallas, February 1977
Panelist, Seminars on Models and Energy Policy, Program in Public Policy, George Washington University, February, 1977
Invited Participant, Workshop on Stochastic Models of Social Structure Carnegie-Mellon University, MSSB Workshop, Pittsburgh, December, 1977
Interviewed on Energy Policy, West Virginia Public Television Network, October, 1976
Member, Committee on Measurement of Energy Consumption, National Academy of Sciences, 1975-76
Interviewed on Energy Policy, West Virginia Public Television Network, October, 1976
Participant, Workshop on Model Building, Mathematical Association of America, Cornell University, Page 14 of 30 Case 1:19-cv-00463-RJD-ST Document 25-1 Filed 04/11/19 Page 34 of 49 PageID #: 1466
August, 1976
Organizer and Chair, Session on Voting Models, Annual Meeting of the Public Choice Society, Roanoke, VA, April, 1976
Instructor, Short Course on Advances in Data Analysis, Princeton University, April, 1976
Member, Organizing Committee, Annual Convention, Institute of Mathematical Statistics, 1975-76
Member, Site Review Committee, University of Texas, San Antonio, National Science Foundation, 1975
Participant, Workshop on Validation of Econometric Models, National Science Foundation, Vail, Colorado, June, 1975
Participant, Workshop on Decentralization Theory, National Science Foundation, Princeton University, March, 1975
Member of the Council, Polymetrics Section, International Studies Association, 1973-75
Member, Committee on Education of Gifted Children, Department of Education, Virginia, 1973-74
Member, Committee on Health Training, State Council of Higher Education, Virginia, 1973-74
Instructor, Workshop on Survey Research, University of Cologne, Cologne, West Germany, 1973
Lecturer, Institute on Model Building, National Science Foundation, Blacksburg, Virginia, August, 1973
Clinical Assistant [Clinical Rotations], Associated Medical Schools, British Virgin Islands, 1969-1970
Summer Fellow, College of Medicine, University of Michigan, Summer, 1970
Major Consulting Appointments (Other than Public and Non-profit):
Play an active advisory role to several CEO's, corporate medical directors, courts, boards, and non-profits on specific health issues, which are confidential, private, proprietary or privileged. I would be glad to discuss these activities in an executive session. They are not appropriate for open documentation.
Major Consulting Appointments (Public and Non-profit):
Consultant in Research Compliance, Maricopa Integrated Medical System, 2002-2003
Consultant, California Energy Commission, 1994-2002
Consultant, National Renewable Energy Laboratory, 1992-1996
Consultant, Department of Mental Hygiene, Johns Hopkins Medical Institutions, June-August, 1990 -1993
Consultant, Program on Delinquency, Child and Maternal Health, Harvard School of Public Health, 1991.
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Consultant, Committee on the Courts, Arizona Supreme Court, 1988-1989.
Consultant, Bonneville Power Authority, 1986-1988.
Consultant, Special Counsel, Department of Energy, 1979-82.
Consultant, National Governors Association, 1979-81
Consultant, Environmental Monitoring Project, Environmental Protection Agency, 1979
Consultant, Energy Office, State of New York, 1976-78
Consultant, Department of Health, City of New York, 1976-78
Consultant, Center for the Study of Emergency Health Services, University of Pennsylvania, 1977
Consultant, Chancellor, The University of Missouri, 1976
Consultant, National Commission on Water Quality, 1974-76
Consultant, Trout Unlimited, 1976
Consultant, Policy Analysis Division, Department of Housing and Urban Development, 1974
Consultant, Department of Political Science, Ohio State University, 1974
Consultant, Committee on State Employee Benefits, Assembly of the State of Ohio, 1973
Consultant, Department of Preventive Medicine, Ohio State University, 1972-73
Editorial Service:
Abstract Review Board, Annual Meeting, Society for General Internal Medicine, 1995
Member, Editorial Board, Sociological Methodology, Publication of the American Sociological Association, 1979-1983
Associate Editor, Series on Social Methodology, Sage Publications, 1974-81
Member, Editorial Board, Journal of Politics, 1974-81
Associate Editor, Journal of the American Statistical Association, 1977-79
Abstracter, Executive Sciences Incorporated, 1974-79
Abstracter, Mathematical Reviews, 1974-76
Proposal reviewer for a variety of public agencies. In 1991-93 reviewed proposals for NIH, NIMH, NSF, DOE, EPA and others
Manuscript reviewer for several publishers including John Wiley and Sons and Wadsworth
Honors and Awards: Page 16 of 30 Case 1:19-cv-00463-RJD-ST Document 25-1 Filed 04/11/19 Page 36 of 49 PageID #: 1468
Listed in the International Who's Who in Medicine, 1997-
Listed in Who's Who in Medicine, 1994-
Honorary Member, Phi Beta Phi, Honorary Society, inducted 1991
Distinguished Research Professor, Arizona State University, 1987-88
Fellow, Royal Statistical Society, elected November, 1984.
Listed in Who's Who in the West, 1983-
Listed in Who's Who in Medical Research, 1982-
Listed in Personalities in America, 1981-
Listed in Distinguished Educators, 1982-
Member, Phi Beta Kappa, inducted 1967
Member, Alpha Iota Delta (Decision Science Honorary Society), elected 1986
Distinguished Alumni Award, Ohio State University, 1971
Awardee, Graduate Scholarship, National Science Foundation, 1967
Recipient, President's Scholarship Award, Ohio State University, 1968
Recipient, President's Scholarship Award, Ohio State University, 1967
Research Grants and Contracts:
Co-Principal Investigator, Alzheimer’s Disease and Anti-Inflammatory Prevention: Is Elevated Serum Cholesterol Predictive of Developing AD?, D. Larry Sparks, PI, Institute for the Study of Aging, funded, March 2001, 360,000
Biostatistical Problems in Research Methodology, Samaritan Health Services, Principal Investigator: L.S. Mayer, 1996-2003, approximate award 450,000
Statistical Problems in Developing Intermediate Outcome Models of the Role of Apolipoprotein E in Alzheimer’s Disease, Office of Research, Arizona State University, 1994-95, approximate award 20,000.
Biostatistical Problems in Research Methodology, Samaritan Health Services, Principal Investigator: L.S. Mayer, 1995-96, approximate award 26,000
Co-Principal Investigator, Prevention Research Training Grant, awarded by the Prevention Branch, National Institute of Mental Health, to the Prevention Center, Department of Mental Hygiene, Johns Hopkins School of Hygiene and Public Health. Principal Investigator: S. G. Kellam, 1994-1999, approximate award 500,000
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Co-Principal Investigator, Epidemiological Prevention Center for Early Risk Behavior, awarded by the Prevention Branch, National Institute of Mental Health, to the Prevention Center, Department of Mental Hygiene, Johns Hopkins School of Hygiene and Public Health. Principal Investigator: S. G. Kellam, 1990-1995, approximate award, 5,000,000
Biostatistical Problems in Research Methodology, Samaritan Health Services, Principal Investigator: L.S. Mayer, 1994-95, approximate award 26,000
Biostatistical Problems in Research Methodology, Samaritan Health Services, Principal Investigator: L.S. Mayer, 1993-94, approximate award 25,000
Wharton Support to Litigation Project, awarded by the Office of the Special Counsel, Department of Energy to the Wharton Analysis Center, Wharton School, University of Pennsylvania. Principal Investigator: L.S. Mayer, 1981-83, approximate award: 2,200,000
Wharton Energy Allocation Project, awarded by the Department of Energy to the Wharton Analysis Center, Wharton School, University of Pennsylvania, Principal Investigator: L.S. Mayer, 1981-83, approximate award: 100,000
Wharton Energy Data Analysis Project, awarded by Oak Ridge National Laboratory to the Wharton Analysis Center, Wharton School, University of Pennsylvania, Principal Investigator: L.S. Mayer, 1980-81, approximate award: 450,000
Wharton Petroleum Data Analysis Project, awarded by CEXEC, Inc. to the Wharton Analysis Center, Wharton School, University of Pennsylvania, Principal Investigator: L.S. Mayer, 1980-81, approxi- mate award: 100,000
Wharton Model Evaluation Project, awarded by the Energy Information Administration, Department of Energy to the Wharton Analysis Center, Wharton School, University of Pennsylvania, Principal Investigator: L.S. Mayer, 1979-81, approximate award: 900,000
Wharton Energy Assessment Project, awarded by Oak Ridge National Laboratory to the Wharton Analysis Center, Wharton School, University of Pennsylvania, Principal Investigator: L.S. Mayer, 1980-81, approximate award: 100,000
Princeton Resource Estimation and Validation Project, awarded by the Energy Information Administration, Department of Energy, to the Departments of Statistics and Geology, Princeton University, Principal Investigators: K. Deffeyes, G. Watson, and L. Mayer, 1978-79, approximate award: 450,000
Analysis of Residential Energy Demand, awarded by the Office of Conservation, Department of Energy to the Center for Energy and Environmental Studies, Princeton University, Principal Investigators: R. Socolow, D. Harrje, L. Mayer and F. Sinden, 1977-78, approximate award: 300,000
Analysis of Statistical Issues Arising from Energy Studies, awarded by the National Science Foundation to the Center for Energy and Environmental Studies, Princeton University, Principal Investigator: L.S. Mayer, 1977-78, approximate award: 50,000
Analysis of Residential Energy Demand, awarded by the Energy Research and Development Administration to the Center for Energy and Environmental Studies, Princeton University, Principal Investigators: R. Socolow, D. Harrje and L. Mayer, 1976-77, approximate award: 300,000
Assessing the Value of Econometric Energy Models, awarded by the Department of Commerce to Page 18 of 30 Case 1:19-cv-00463-RJD-ST Document 25-1 Filed 04/11/19 Page 38 of 49 PageID #: 1470 the Center for Energy and Environmental Studies, Princeton University, Principal Investigator: L.S. Mayer, 1976-77, approximate award: 25,000
Energy Husbandry in Residential Housing, awarded by the National Science Foundation to the Center for Environmental Studies, Princeton University, Principal Investigators: R. Socolow, D. Harrje and L. Mayer, 1975-76, approximate award: 300,000
On Comparing Factor Matrices, awarded by the National Institute of Mental Health to the Department of Statistics, Princeton University, Principal Investigator: L.S. Mayer, 1974 - 1975, approximate award: 15,000
Measuring the Relationship Between Abstract Variables, awarded by the National Institute of Mental Health to the Department of Statistics, Virginia Polytechnic Institute and State University, Principal Investigator: L.S. Mayer, 1972-74, approximate award: 15,000
Component Analysis of Variance, awarded by the National Institute of Mental Health to the Behavioral Sciences Laboratory, Ohio State University and the Department of Statistics, Virginia Polytechnic Institute and State University, Principal Investigator: L.S. Mayer, 1971-72, approximate award: 15,000
Papers Presented at Professional Meetings:
Depression in Assisted Living is Common and Related To Physical Burden, Gerontology Society Annual Meeting, Washington DC, November 2004
“Methodological Issues In Modeling The Incidence Of Alzheimer's Disease As A Function Of Age", World Congress of Epidemiology, Toronto, June, 2001
“Biostatistical Problems in Forecasting the Prevalence of Alzheimer’s Disease” World Psychiatric Congress, Baltimore, March, 2001
“Using Latent Growth Models and Exploratory Methods to Assess the Relationship Between Responses in a Bivariate Prevention Model (with M. Reiser) Society for Prevention Research, Annual Meeting, Washington DC, May 1997
“Standard Metrics and Methods for Conducting Avian Wind Energy Interaction Studies (with R. Anderson) American Wind Energy Association Conference, Austin Texas, June, 1997
“A Randomized Clinical Trial of a Group Empowerment Program for Somatizing Patients: Six Months Follow-up Results”, (with J. C. Peirce, A. Miller and J. Westley), invited lecture, Society for General Internal Medicine, Washington, DC, May 1997
“Measuring Effectiveness: Lessons from Heparinizing Patients with Deep Vein Thrombosis and Pulmonary Embolism” (with J. C. Peirce and R. A. Raschke), invited lecture, Society for General Internal Medicine, Washington, DC, May 1997
"Latent Growth Models of the Impact of Intervention on a Bivariate Longitudinal Response", invited lecture, Society for Research on Child Development, Washington, DC, March, 1997
"Developmental Epidemiology and its Implications for Prevention Research" invited lecture (with Sheppard Kellam), Life History Society Annual Meeting, London, December, 1996
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“Standard Methods for Conducting Avian Mortality Studies”, with R. L. Anderson, European Wind Energy Conference, Rome, October, 1996
"Using Multilevel Models to Tease Out Variability in Individual Behavior", invited lecture, Association for Clinical Psychosocial Research, American Psychiatric Association, Boston, October, 1996
“Statistical Issues Arising from Application of the Proximal-Distal Model in Prevention Research, Society for Prevention Research, San Juan, Puerto Rico, June, 1996.
“Recent Advances in Prevention Methodology: Multilevel Models”, invited lecture, Prevention Methodology Conference, Tempe, Arizona, May 1996
"Advances in the Methods of Prevention Research", invited lecture, National Forum on Prevention, McLean, VA, May, 1996
"Multilevel Models in Prevention Science", invited presentation, Prevention Science Methodology Group meeting, College of Public Health, University of South Florida, Tampa, March, 1996
"Prevented Fractions and Attributable Risk in Proximal Distal Prevention Models", invited lecture, College of Public Health, University of South Florida, Tampa, February, 1996
"Prevented Fractions and Attributable Risks in Preventive Trials", invited paper, Prevention Science and Methodology Conference, Baltimore, MD, October, 1995
"The Use of Epidemiological Measures to Estimate the Effects of Adverse Factors and Preventive Interventions", Workshop on Avian Mortality, Palm Springs, September, 1995
"The Use of Epidemiological Measures to Estimate the Effects of Adverse Factors and Preventive Interventions", invited presentation, Workshop on Avian Mortality and Avian Windpower Planning Meeting, Department of Energy, Palm Springs, September, 1995
"Methodological Advances in Prevention Research", with S. Kellam and J. Anthony, invited symposium, Prevention Research Society, Scottsdale Arizona, June 1995
"Multilevel Modeling and the Development of Aggressive Behavior", invited paper, World Psychiatric Association, New York, May, 1995
"Attributable Risk and Preventive Fractions in Prevention Research", invited lecture, Workshop on the Science of Prevention, NIMH, Baltimore, December, 1994
"Reduction of Aggressive Behavior Among First Graders and Its Consequences for Later Antisocial Behavior and Drug Use", with S. Kellam, H. Chilcoat, J. Anthony, G. Rebok, and N. Ialongo, invited lecture, Society for Prevention Research, Washington, June, 1994
"The Impact of Failure on Boys and Girls: Preventive Intervention Studies on Achievement and Depression" with S. Kellam, G. Rebok, and N. Ialongo, Society for Life History, Durham, November, 1993
"The Course and Malleability of Aggressive Behavior", with S. Kellam, G. Rebok, and N. Ialongo, invited lecture, American Society of Criminology, Annual Meeting, Phoenix, October, 1993
"Mediated Effects in Structural Equation Models", invited paper, American Statistical Association Annual Meeting, August, 1992 Page 20 of 30 Case 1:19-cv-00463-RJD-ST Document 25-1 Filed 04/11/19 Page 40 of 49 PageID #: 1472
"The Course and Malleability of Aggressive Behavior in Young Children", invited presentation, with S. Kellam, et. al., National Academy of Science Institute of Medicine, Committee on Prevention of Mental Disorders, June, 1992
"Developmental Epidemiology and the course of Aggressive Behavior", Life Course Development Society, Philadelphia, April, 1992
"Modeling the Cotemporal Effects in a Cross-Lagged Panel Model", ASA Annual Meeting, New Orleans, August, 1988
"Estimating Multivariate Continuous Variable Panel Models", ASA Annual Meeting, San Francisco, August, 1987
"Inferences in Cross-Lagged Panel Models," invited paper, AIDS Convention, Phoenix, March, 1986
"Recent Advances in Cross-Lagged Panel Analysis," invited lecture, Southwest Social Science Convention, San Antonio, March, 1986
Hypothesis Testing with Continuous Variable Panel Data," Annual Meeting, Biometrics Society (WNAR), San Luis Obispo, June, 1985
"Multivariate Cross-Lagged Panel Models: Does IQ Cause Achievement?" invited lecture, Regional Meeting, Institute of Mathematical Statistics, Humboldt State University, Arcata, CA, June, 1983
"Analysis of the U.S. Short-Term Integrated (Energy) Forecasting System," invited lecture, International Energy Conference, Berlin, October 1981
"Assessing Energy Models: A Policy Process Approach," invited lecture, Workshop on Energy Model Validation, National Bureau of Standards, January 1979
"Energy Use and Potential for Conservation," (with David Harrje et al.), invited lecture, International Conference on Energy Use Management, Tucson, October 1977
"Large Data Sets and the Meta-Theorems of Exploratory Data Analysis," invited lecture, American Statistical Association, Special Topic Meeting, Dallas, 1977
"The Internalization of Cosmopolitan-Local Orientations Among College Students," (with W. Snizek), invited lecture, Southern Sociological Association, Washington, D.C., April 1975
"Equivalent Estimation and a Special Group Structure," (with T. Woteki), invited lecture, Regional Meeting, Institute of Mathematical Statistics, Minneapolis, March 1975
"The Use and Abuses of Probability in Voting Theory Models," invited lecture, Annual Meeting, Public Choice Society, New Haven, April 1974
"Some Problems with the Theory of Coalitions as Applied to the Judiciary," invited paper, Annual Meeting, American Political Science Association Convention, Chicago, August 1974
"On Principal Components and Clusters," invited lecture, Annual Meeting, International Classification Society, Atlanta, Georgia, April, 1973
"On Biased Estimation in Linear Models," invited lecture, Annual Meeting, American Statistical Page 21 of 30 Case 1:19-cv-00463-RJD-ST Document 25-1 Filed 04/11/19 Page 41 of 49 PageID #: 1473
Association, New York, December, 1973
"Invariant Estimation with Applications to Linear Models," (with M.S. Younger), Institute of Mathematical Statistics, Blacksburg, Virginia, Academy of Science, May, 1972
"On Biased Estimation in Linear Models," invited lecture, Virginia Academy of Science, Lexington, Virginia, May, 1972
"Methods of Cluster Analysis Which Utilize Principle Components," invited lecture, International Classification Society Convention, Chicago, Illinois, April 1972
"A Method of Cluster Analysis," invited lecture, Annual Meeting, Biometrics Society, Fort Collins, Colorado, August, 1971
"Measures of Association," invited lecture, International Studies Association, San Juan, Puerto Rico, March, 1971
"Utilizing Initial Estimates in Estimating the Coefficients in a General Linear Model," Annual Meeting, Institute of Mathematical Statistics, Laramie, Wyoming, August 1970
Speeches, Presentations, Lectures and Colloquia:
“Validating Biomarkers in Psychiatry”, Department of Psychiatry, University of Athens, Athens, Greece, October, 2006
“Fitting Failure Models to the Incidence of Alzheimer’s Disease: Methodological Problems”, invited lecture, Johns Hopkins School of Public Health, Noon conference series on Mental Heath, January, 2001
“Psychiatric Epidemiology”, Residency Program in Psychiatry, Samaritan Health System, September, 2000
“Critical Appraisal in Internal Medicine”, invited speaker, Good Samaritan Internal Medicine Program. April, 2000
“Psychiatric Epidemiology”, Residency Program in Psychiatry, Samaritan Health System, September, 1999
“Tradeoffs Between Latent Growth Models and Epidemiological Models of Preventive Interventions, invited colloquium, Department of Mental Hygiene, Johns Hopkins School of Hygiene and Public Health, October, 1998
“Psychiatric Epidemiology”, Residency Program in Psychiatry, Samaritan Health System, September, 1998
“Advances in Psychiatric Epidemiology”, Clinical Epidemiology Section, Royal Medical Society (Edinburgh), August, 1998
“Latent Growth Models and Attributable Risks”, luncheon speaker, Fellowship in Drug Epidemiology, Johns Hopkins University, April 1998
“Attributable Risk Measure in Mediational Impact Models: Somatizing Behavior”, invited colloquium, Department of Mental Hygiene, Johns Hopkins School of Hygiene and Public Health, March, 1998 Page 22 of 30 Case 1:19-cv-00463-RJD-ST Document 25-1 Filed 04/11/19 Page 42 of 49 PageID #: 1474
“Statistical Issues in Using Attributable Risk Measures in Intermediate Outcome Models”, Department of Statistics, The University of Lancaster, Lancaster, England, June, 1997
“Statistical Problems that Arise in Applying Intermediate outcome Models in Prevention Research”, invited lecture, Department of Statistics, Virginia Polytechnic Institute and State University, Blacksburg, Virginia, May, 1997
"The Epidemiology of Thyroid Disease", invited lecture, Grand Rounds in Endocrinology, Samaritan Health Services, April, 1997
"Attributable Risk and Preventive Fractions in Prevention Research", invited lecture, Workshop on the Science of Prevention, NIMH, Baltimore, December, 1994
"Advances in Prevention Methodology", invited lecture, Prevention Research Center, Johns Hopkins University, September, 1994
"Multi-level Modeling in Prevention Research", invited colloquium, Prevention Research Center, Arizona State University, April, 1994
"Multi-level Modeling of Health Data; The Effects of Intervention on Aggressive Behavior", invited lecture, Program in Developmental Biology, University of North Carolina, April, 1994
"Mediation in Intermediate Variable Models", Department of Epidemiology and Biostatistics, College of Public Health, University of South Florida, March, 1994
"Assessing the Impact of Interventions on Proximal and Distal Outcomes" NIMH Prevention Research Center Directors Meeting, October 1993 with Reiser, M. and Warsi, G
"Epidemiology and Social Methodology: Complementarity in Prevention Research", invited presentation, with S. Kellam, et. al., NIMH Prevention Research Conference, Tysons Corners, VA, April, 1993
"Statistical Issues in Prevention Research", invited lecture, Directors' Meeting, Prevention Research Center Directors Meeting, National Institute of Mental Health, Rockville, Maryland, October, 1992
"The Course and Malleability of Aggressive Behavior in Young Children", invited presentation, with S. Kellam, et. al., National Academy of Science Institute of Medicine, Committee on Prevention of Mental Disorders, June, 1992
"Causal Models in Prevention Research: Mediation Moderation and Confounding", invited seminar, Carl A. Taube Memorial Colloquium Series in Psychiatry and Mental Health, Johns Hopkins University, May, 1992
"Breast Implants, Risk Surveillance and Health Statistics", invited lecture, MBA Special Colloquium Series, Arizona State University, March, 1992
"Proximal/Distal Effects on Two Developmental Epidemiologically-Based Preventive Interventions", invited seminar, Colloquium Series in Mental Health, Johns Hopkins School of Hygiene and Public Health, February, 1992
"Analyzing Subgroups and Contextual Effects" [with Sheppard Kellam], invited presentation, Direc- tors' Meeting, Prevention Research Center Directors Meeting, National Institute of Mental Health, Page 23 of 30 Case 1:19-cv-00463-RJD-ST Document 25-1 Filed 04/11/19 Page 43 of 49 PageID #: 1475
Rockville, Maryland, September, 1991
"Proximal/Distal Effects on Two Developmental Epidemiologically-Based Preventive Interventions" [with Sheppard Kellam, et. al.], invited seminar, Carl A. Taube Memorial Colloquium Series in Mental Health, Johns Hopkins School of Hygiene and Public Health, September 1991
"The Epidemiology of Preventive Care in the Workplace", invited lecture, Phoenix Chapter, Association of Corporate Fitness Directors, Phoenix, May 1991.
"Statistics, Medicine and the Law", Invited Lecture, East Mesa Doctors Club, November 1990
"Statistical Models in the Analysis of Panel Data", invited lecture, Department of Biostatistics, Johns Hopkins School of Hygiene and Public Health, April, 1990
"Applications of Statistics to Occupational Health Problems", invited lecture, Department of Statistics, MacQuarie University, Australia, October, 1989
"Panel Models and Policy Analysis", invited lecture, Lincoln College, Christchurch, New Zealand, September 1989
"Panel Analysis and Occupational Health Analysis", invited lecture, University of Otago, New Zealand", September 1989
"Current Trends in Data Analysis, invited lecture, MBA colloquium, University of Canterbury, Christchurch, New Zealand, September 1989
"Managing the Health of Workers and the Health of the Firm", invited banquet speech, Conference on Analysis of Occupational Health Risks, Phoenix, August 1987
"Panel Models, Covariance Structures and the Exclusion of Liberals from 'Death-Sentence' Juries", invited colloquium, Department of Statistics, Stanford University, August, 1986
"A Statistician Looks at Panel Analysis or a Perfidious Peek at Pundits and Pookas," invited lecture, Arizona Chapter, American Statistical Association, March, 1984.
"A Statistician Looks at Panel Analysis", invited lecture, College of Business, University of Tennessee, June, 1983
"The Use of Panel Models in Non-experimental Research", invited lecture, College of Medicine, University of California, San Francisco, June, 1983
"Competing Approaches to Analysis of Panel Data", invited lecture, Econometrics Seminar, Stanford University, May 1983
"Science Analysis in Politics and the Politics of Science Analysis", invited lecture, Butler University, Indianapolis, March, 1983
"Statistical Problems in Panel Models", invited lecture, College of Education, Stanford University, March, 1983
"A Statistician Looks at Panel Analysis or a Perfidious Peek at Pundits and Pookas", invited lecture, Department of Computer and Information Sciences, University of California, Santa Cruz, February, 1983 Page 24 of 30 Case 1:19-cv-00463-RJD-ST Document 25-1 Filed 04/11/19 Page 44 of 49 PageID #: 1476
"A Statistician Looks at Panel Analysis or a Perfidious Peek at Pundits and Pookas", invited lecture, Department of Computer and Information Sciences, University of Santa Clara, February, 1983
"Statistical Problems in Panel Analysis", invited lecture, Department of Mathematics, University of California, Santa Barbara, February, 1983
"A Statistician Looks at Panel Analysis", invited lecture, Department of Statistics, University of Arizona, February, 1983
"A Crossed Lagged Penal Analysis of Cross-Lagged Panel Analysis", invited colloquium, Department of Statistics, Stanford University, January, 1983
"Some Exciting Problems in Energy Modeling", invited lecture, Department of Mathematics, Arizona State University, August, 1982
"Statistical Problems in Short-term Energy Forecasting", invited lecture, Energy Information Administration, Washington, D.C., February, 1982
"Problems in Forecasting Energy Supplies", Decision Sciences Seminar, Wharton School, September, 1981
"Energy Policy: Myth and Reality", invited lecture, Philadelphia Business Seminar, April, 1981
"Energy Management: Building Image and Minimizing Liabilities", invited lecture, Wharton Executive Development Seminar, April, 1981
"Evaluating Energy Models", invited lecture, Delaware Chapter, American Statistical Association, University of Delaware, May, 1980
"Evaluating Models of Resource Depletion", invited lecture, Department of Economics, New York University, April, 1980.
"Exploratory Methods and the Art of Data Analysis", Dinner speech, Philadelphia Chapter, American Statistical Association, October, 1979
"Models of Domestic Oil Resources: Science Products and Political Agents", invited lecture, Thayer School of Engineering, Dartmouth College, March, 1979
"Models of Sequential Voting", invited lecture, Department of Political Science, Dartmouth College, March, 1979
"Estimating Oil Reserves: The Methods, Models and Policy Issues", invited lecture, School of Public and Urban Policy, University of Pennsylvania, December, 1978
"Estimating the Domestic Crude Oil Resource Base: Examining the King's Approach", invited lecture, Department of Statistics, University of Pennsylvania, November, 1978
"Picking a Multivariate Test Function, The Eenie-Meany Principle", invited lecture, Montreal Joint Statistics Colloquium, Montreal, November, 1977
"Econometric Energy Models: The Emperor's Quantitative Suit", invited lecture, Department of Commerce, October, 1977 Page 25 of 30 Case 1:19-cv-00463-RJD-ST Document 25-1 Filed 04/11/19 Page 45 of 49 PageID #: 1477
"Exploratory Data Analysis as an Alternative to the Econometric Analysis of Social Problems," invited lecture, Department of Psychology, College of William and Mary, April, 1977
"Analyzing Energy Policy: The Competing Roles of the Economist, Engineer and Mathematician", invited lecture, Department of Mathematics, University of South Carolina, April, 1977
"Analyzing Political Data: What Can Statistics Tell Us?," invited lecture, School of International Studies, University of Denver, May, 1976
"Schur-Convexity and the Equivalence of Multivariate Tests", invited seminar, Department of Statistics, Rutgers University, October, 1975
"On Communal Indifference Curves," (with I.J. Good), invited seminar, Mathematical Economics Seminar, Virginia Polytechnic Institute and State University, October, 1975
"The Statistical Analysis of Energy Problems: Who Should We Believe?", invited lecture, Office of Energy Analysis, Department of Commerce, October, 1975
"Energy Research and Residential Housing", invited lecture, The Federal Energy Administration, September, 1975
"Consumer Reaction to the Energy Crisis: The Long Underwear Effect", invited address, West Virginia University, February, 1975
"Mathematical Models and other Forms of Hocus-Pocus", invited lecture, Department of Political Science, West Virginia University, February, 1975
"Factor Analysis: The Short Bed Problem", invited lecture, Department of Statistics and Operations Research, University of Pennsylvania, March, 1975
"LSD and Political Science: Distinguishing Uppers and Downers", invited address, Western New England College, November, 1974
"Probability, Statistics and the Theory of Democracy", invited lecture, Department of Statistics, University of Connecticut, October, 1974
"Statistical Policy Analysis: Assessing the Unobservable", invited lecture, Department of Statistics, Princeton University, January, 1974
"On Procedures for Comparing Factor Matrices", invited lecture, Department of Statistics, University of Connecticut, January, 1974.
"A Mathematician's Doubts About Econometric Solutions to Political Problems", invited lecture, Department of Political Science, Ohio State University, May, 1973
"Estimating the Relationship Between Unobserved Variables, or Can We Sell the Second Canonical Correlation to the Social Scientists?", invited lecture, Department of Statistics, Ohio State University, May, 1973
"Generalized Spatial Models of Voting Theory", invited lecture, Center for Public Choice, Virginia Polytechnic Institute and State University, February, 1973
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"Estimating the Relationship Between Ordinal Variables", invited lecture, Department of Statistics, Harvard University, 1973.
"Some Statistical Problems in Spatial Models", invited colloquium, Department of Statistics, Carnegie-Mellon University, Pittsburgh, October, 1972.
"Sex, the Generation Gap, and Fermat's Last Theorem", invited speech, Tidewater Council of Teachers of Mathematics, Norfolk, Virginia, September, 1972
"Mathematics: Is it Irrelevant by Necessity or Design?", invited lecture, Department of Mathematics, Emory and Henry College, Emory, Virginia, April, 1972
"Is There Reason for a Mathematician to help a Social Scientist?", invited to deliver annual Phi Mu Epsilon Lecture, Blacksburg, Virginia, 1972
"Probability Without Calculus and Statistics Without Mathematics", invited lecture, Virginia Mathematics Teachers Annual Convention, Roanoke, Virginia, November, 1972
"If Educators Educate Educators, Who Educates the Educated?", banquet address, State Mathematics Teachers Convention, Norfolk, Virginia, 1971
"Two-Stage Estimation in linear Models", invited lecture, Department of Statistics, Pennsylvania State University, January, 1971
"Problems in Cluster Analysis", invited lecture, Department of Applied Statistics, University of Minnesota, January 1971
Papers in Proceedings:
Mayer, L. S. and Reiser M.(1992) "Mediation and Confounding in Panel Models of Prevention Research" Proceedings of the Social Statistics Section, American Statistical Association
Mayer, L. S. and Carroll, S. S.(1988) "Modeling the Cotemporal Effect in a Cross-Lagged Panel Model," Proceedings of the Business and Economics Section, American Statistical Association
Carroll, S. S. and Mayer, L. S. (1987) "Testing for Serial Correlation in Cross-Lagged Panel Studies," Proceedings of the Business and Economics Section, American Statistical Association
Carroll, S. S. and Mayer, L. S. (1986) "Evaluation of the Cross Effects Parameters in a Cross-Lagged Panel Model," Proceedings of the Business and Economic Section, American Statistical Association
Mayer, L. S. (1985) "Hypothesis Testing in Cross-Lagged Panel Models," Proceedings of the Social Statistics Section, American Statistical Association
Mayer, L. S. and Carroll, S. S. (1985) "Testing for Serial Correlation in Cross-Lagged Panel Studies," Proceedings of the Business and Economics Section, American Statistical Association
Mayer, L.S. et. al. (1982). "Analysis of the U.S. Short-Term Integrated (Energy) Forecasting System," Proceedings of the International Conference on Energy Use Management, New York: Pergamon Press, 971-982
Harrje, D. and Mayer, L.S. (1978). "Energy Use and the Potential for Conservation," Proceedings of the International Conference on Energy Use Management,, Volume II, R. Fazzolare and C. Smith Page 27 of 30 Case 1:19-cv-00463-RJD-ST Document 25-1 Filed 04/11/19 Page 47 of 49 PageID #: 1479
(eds.), New York: Pergamon Press, 749- 771
Mayer, L.S. (1978). "The Use of Semi-Controlled Experiments in the Analysis of Residential Energy Demand," Proceedings of the 1978 Department of Energy Symposium, Washington: Government Printing Office
Mayer, L.S. (1978). "The Value of the Econometric Approach to Forecasting Our Energy Future," Proceedings of the International Conference on Energy Use Management,, Volume III, R. Fazzolare and C. Smith (eds.), New York: Pergamon Press, 1073-1082
Mayer, L.S. (1978). "Difficulty in Developing Local Energy Policy," expert testimony, Hearings on Local Energy Policy, Washington: U.S. Congress
Mayer, L.S. (1977). "Exploratory Data Analysis and Classical Statistics: Their Abilities to Shed Light on Energy Issues," Proceedings of the 1977 Department of Energy Symposium, 27-32, Washington: Government Printing Office
Published Abstracts:
"Equivariant Estimation and A Special Group Structure", (with T. Woteki), Bulletin of the Institute of Mathematical Statistics, 1975
"A Fortran Program for Linear Log Odds Analysis", (with P.J. Pichotta), Behavior Research Methods and Instrumentation, 1974, 6, p. 521
"Invariant Estimation in the Social Sciences", (with M. S. Younger), Bulletin of the Institute of Mathematical Statistics, 1973
"On Principal Components and Clusters", Bulletin of the International Classification Society, 1973
“Methods of Cluster Analysis Which Utilize Principal Components", Bulletin of the International Classification Society, 1972
"Utilizing Initial Estimates in Estimating the Coefficients in General Linear Model", Annals of Mathematical Statistics, October 1970
Society Membership:
Society for Epidemiological Research, Society for Environmental Epidemiology, Royal Statistical Society, Society for Medical Decision Making, American Statistical Association, Biometrics Society, Institute for Mathematical Statistics, Psychometric Society, Econometric Society, American Association for the Advancement of Science, American Political Science Association, American Sociological Association, and Council for Applied for Social Research.
Courses Taught at Arizona State University and Banner Good Samaritan Medical Center
Epidemiology, Epidemiology Methodology, Clinical Epidemiology, Panel Analysis, Biostatistics, Multiple Regression, Time Series Modeling, Applied Forecasting Methods, Stochastic Processes, Exploratory Data Analysis, Seminar in Multivariate Analysis, Advanced Topics in Statistical Infer- ence, Advanced Topics in Linear Models, Advanced Research Methods.
Courses taught at other Universities:
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Undergraduate:
Biostatistics, Data Analysis, Nonparametric Methods, Regression Analysis, Mathematical Statistics, Mathematical Modeling, Design of Experiments, Statistics for the Social Sciences, Educational Statistics, Statistics and Public Policy, Computers and Society, Forecasting.
Graduate:
Biostatistics, Clinical Epidemiology, Statistical Forecasting, Exploratory Data Analysis, Epidemio- logical Methods, Econometrics, Applied Multivariate Statistics, Advanced Multivariate Statistics, Stochastic Processes, Advanced Probability, Linear Models, Advanced Inference, Time Series, Sampling Theory, Quantitative Methods of Policy Analysis, Philosophy of Science, Advances in Social Methodology.
Professional:
Statistics and Public Policy (Woodrow Wilson School, Princeton University); Advanced Study in Energy Analysis (Wharton MBA Program, University of Pennsylvania); Advanced Study in Statistics and Law (Law School, University of Pennsylvania): Medical Statistics (College of Medicine, Ohio State University)
Notable University Committees:
Member, Graduate Committee on Ph.D. program in Health Services Administration and Policy, Arizona State University (ASU) 1991-1992
Member, Executive Board, Program on Law and the Social Sciences, ASU, 1983-1989
Faculty Senate (elected), ASU, 1987-89
University Services Committee, ASU, 1988-89
Council on Research and Creative Activities, ASU, 1986-1988
Sunset Review Committee, Meteorite Center, ASU, 1987
Sunset Review Committee, Energy Research Center, ASU, 1987
Chair, Sunset Review Committee, Center for Advanced Research in Transportation, ASU, 1987
Women Studies Research Awards Committee, ASU, 1984-1989
Board, Ph.D. Program in Justice Studies, ASU, 1987-1989
Biomedical Research Committee, ASU< 1986-1988
Notable Previous University Committee Assignments:
Member, Health Professions Advisory Board, University of Pennsylvania, 1980-83
Member, Environmental Task Force Committee, Office of the Provost, University of Pennsylvania, 1979-82
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Member, Committee on Undergraduate Student Life, Princeton University, 1976
Member, Council of Masters, Princeton University, 1976-79
Fellow, Princeton Inn College, Princeton University, 1975-76
Member, Chair Search Committee, Department of Statistics, Virginia Polytechnic Institute and State University, 1972-74
Page 30 of 30 Case 1:19-cv-00463-RJD-ST Document 25-2 Filed 04/11/19 Page 1 of 7 PageID #: 1482
Alliance Defending Freedom 15100 N. 90th Street Scottsdale, Arizona 85260 (480) 444-0020
UNITED STATES DISTRICT COURT Eastern District of New York Dr. David Schwartz, Case No.: 1:19-CV-463 Plaintiff,
v. DECLARATION OF RABBI DR. The City of New York and TZVI HERSH WEINREB Lorelei Salas, in her official capacity as Commissioner of the Department of Consumer Affairs, Defendants.
Rabbi Dr. Tzvi Hersh Weinreb declares as follows:
1. I am the Executive Vice President Emeritus of the Union of Orthodox Jewish
Congregations of America (“OU”). I am the Editor-in-chief of the Koren Talmud Bavli, a bilingual
edition of the Talmud (Koren Publishers).
2. I am the former Executive Vice President of the OU and Senior Rabbi of
Congregation Shomrei Emunah of Baltimore, Maryland.
3. My educational credentials include a B.A. from Brooklyn College, an M.A. from
the New School for Social Research, a Ph.D. in Human Development from the University of
Maryland and a Certificate in Group Psychotherapy from the Washington School of Psychiatry. I
received my Rabbinic Ordination from the Rabbi Jacob Joseph Seminary. Case 1:19-cv-00463-RJD-ST Document 25-2 Filed 04/11/19 Page 2 of 7 PageID #: 1483
4. For many years I practiced as a licensed psychologist in the State of Maryland,
where I served as Chief Psychologist of the Potomac Foundation for Mental Health in Bethesda,
MD. I was also the Senior School Psychologist of Prince George’s County, Maryland, and have
held various other positions in the fields of psychology and education.
5. I am an active member of the Rabbinical Council of America, the American
Psychological Association and the American Group Psychotherapy Association.
The Lubavitcher Rebbe (“the Rebbe”)
6. Rabbi Menachem Mendel Schneerson was the leader of the very large Chassidic
movement, known alternatively as either Lubavitch or Chabad, from the year 1951 until his
passing in 1994. As such, he was the supreme authority of a movement of thousands of Jews
throughout the world.
7. Rabbi Schneerson’s influence extended well beyond the members of his movement
to include Jews and of all backgrounds as well as members of other faiths and traditions.
8. Indeed, though the term “rebbe” (literally, “teacher”) is generically used to refer to
a religious leader or teacher, only Rabbi Schneerson – as a reflection of his global impact and
universal acclaim – came to be known to all as simply “the Rebbe.”
9. The Rebbe’s guidance and blessings were sought by political leaders from mayors
of New York City to prime ministers of Israel. His accomplishments were recognized far beyond
the Jewish community and included world-famous scientists, artists, writers, and world leaders,
including Presidents of the United States of America.
10. His worldview was informed by his advanced secular education in the universities
of pre-World War II France and Germany. His published works number in the hundreds, and
2 Case 1:19-cv-00463-RJD-ST Document 25-2 Filed 04/11/19 Page 3 of 7 PageID #: 1484
include many volumes of his personal correspondences which offer sophisticated and humane
counseling and advice to individuals of all religions and from all walks of life.
11. The Rebbe was born in 1902. He studied mathematics, physics, and philosophy at
the University of Berlin. In 1933, after the rise of the Nazi party in Germany, Schneerson left
Berlin and moved to Paris, France. He continued studying mechanics and electrical engineering at
the distinguished ESTP, one of Grandes Ecoles (the leading French institutions for engineering
and management) and graduated July 1937. In November 1937, he enrolled at the Sorbonne, where
he studied mathematics until World War II broke out in 1939.
12. In 1951, he accepted the position of the seventh rebbe of the Lubavitcher Hasidic
Jewish community, a dynasty extending back into the 18th century.
The Rebbe’s Teachings and Impact
13. The Rebbe became recognized as a uniquely gifted teacher and an ultimate
authority on Judaism and Jewish ethics. He was particularly noted for his ability to offer practical
and informed guidance on all aspects of human life. His advice was invariably based upon his rare
combination of faith, erudition, compassion, humanity, good humor, and common sense.
14. With time, the Rebbe became recognized as the most influential Jewish leader of
the 20th century. Upon his passing, Israeli Prime Minister Yitzhak Rabin cited Schneerson’s
contribution to world Jewry, proclaiming: “The Rebbe’s loss is a loss for all the Jewish people.”
Similar acclaim was heard from Jewish leaders of every persuasion and from all corners of the
world.
15. Perhaps most remarkable was the Rebbe’s universal influence. He was recognized
far beyond the boundaries of the Jewish community as a moral guide whose message was relevant
to all mankind.
3 Case 1:19-cv-00463-RJD-ST Document 25-2 Filed 04/11/19 Page 4 of 7 PageID #: 1485
16. President Carter honored the Rebbe by declaring 1977 the “Year of Education.”
That year, the United States of America celebrated its first “Education Day, USA” on the Rebbe’s
Hebrew birthday. A joint congressional resolution, signed by the Congress and the President,
stated:
Congress recognizes a need for the Nation to set aside on the calendar a day devoted to the importance of education to the lives of its citizens and to the general well- being of the Nation; and the Lubavitch Movement, which conducts educational activities at more than sixty centers in twenty-eight States as well as around the world, is especially committed to the advancement of education and has proposed the establishment of an “Education Day, U.S.A.”; and world Jewry marked in 1977 the seventy-fifth birthday of the revered and renowned Jewish leader, the head of the worldwide Lubavitch Movement., Rabbi Menachem Mendel Schneerson. . . . The following year, President Carter issued Proclamation 4562 (1978), which declared:
I, JIMMY CARTER, President of the United States of America, do hereby proclaim Tuesday, April 18, 1978, as Education Day, U.S.A. and I ask all Americans to observe that day in such manner as reflects their commitment to education and their recognition of its importance to the welfare of this Nation. 17. In 1982, President Reagan issued Proclamation 4921, designating April 4,1982, the
Rebbe’s 80th birthday, as “National Day of Reflection:”
A Proclamation Amid the distractions and concerns of our daily existence, it is appropriate that Americans pause to reflect upon the ancient ethical principles and moral values which are the foundation of our character as a nation.
We seek, and steadfastly pursue, the benefits of education. But education must be more than factual enlightenment—it must enrich the character as well as the mind. One shining example for people of all faiths of what education ought to be is that provided by the Lubavitch movement, headed by Rabbi Menachem Schneerson, a worldwide spiritual leader who will celebrate his 80th birthday on April 4, 1982. The Lubavitcher Rebbe’s work stands as a reminder that knowledge is an unworthy goal unless it is accompanied by moral and spiritual wisdom and understanding. He has provided a vivid example of the eternal validity of the Seven Noahide Laws, a moral code for all of us regardless of religious faith. May he go from strength to strength. In recognition of the Lubavitcher Rebbe’s 80th birthday, the Senate and the House of Representatives of the United States in Congress assembled have issued House Joint Resolution 447 to set aside April 4, 1982, as a “National Ante, p. 60. Day of Reflection.”
4 Case 1:19-cv-00463-RJD-ST Document 25-2 Filed 04/11/19 Page 5 of 7 PageID #: 1486
18. Further testimony to the Rebbe’s significant impact was the letter of condolence
tended by the President Clinton upon the Rebbe’s passing. It read in part: “He was a monumental
man who, as much as any other individual, was responsible over the last half-century for advancing
the instruction of ethics and morality to our young people.”
19. Rabbi Schneerson was posthumously awarded the Congressional Gold Medal for
his “outstanding and enduring contributions toward world education, morality, and acts of charity.”
In the words of President Clinton, “the late Rebbe’s eminence as a moral leader for our country
was recognized by every President since Richard Nixon.”
The Rebbe’s Influence Upon Me
20. I am not a member of, nor in any way officially affiliated with, the Lubavitcher
Hasidic movement. However, I have found Rabbi Schneerson’s writings invaluable to me in my
roles as a husband, father and grandfather, as a professional psychologist, as a teacher and writer,
and as a rabbinic leader in the segment of Orthodox Jewry usually known as Modern or Centrist
Orthodoxy.
21. I had only one conversation with the Rebbe, which has remained with me for almost
50 years. In it he encouraged me to trust my own judgment, to have self-confidence, and to think
for myself.
The Rebbe’s Teachings Concerning Family Life, Same-Sex Attractions, and the Human Capacity for Personal Change 22. The Rebbe taught that human beings are obligated to struggle against wrong
inclinations in order to conform to spiritual goals and commands. He insisted that humans have
the capacity to control their passions and instincts.
5 Case 1:19-cv-00463-RJD-ST Document 25-2 Filed 04/11/19 Page 6 of 7 PageID #: 1487
23. He further taught that Jews are obligated to help each other obey God’s commands.
The Rebbe personally exemplified this teaching, designating and sending thousands of “shluchim”
(emissaries) to even the most remote locations worldwide, for the sole purpose of returning the
wayward back to their Jewish roots, known as “kiruv r’chokim” (bringing the distant closer).
24. A primary value for the Rebbe was the importance of marriage and family. He
emphasized that for traditional Judaism marriage is a monogamous heterosexual relationship
whose major purpose is to raise up future generations to follow in the Almighty’s path. According
to the Rebbe, Jewish faith commands observance of and adherence to these principles.
25. The Rebbe authored a well-known letter to a man struggling against same-sex
attraction. In this letter he warmly conveys his understanding of the correspondent’s predicament,
but emphasizes his conviction that we are all obligated to strive against even “congenital”
tendencies if they are contrary to divine law. He encouraged the correspondent by enunciating his
conviction, based upon evidence that he well knew, that the individual has the ability to overcome
even the strongest of internal tendencies.
26. The Rebbe believed and taught that every individual has the ability and affirmative
religious duty to control, regulate, modify and even overcome internal tendencies of all sorts,
including same-sex proclivities.
27. Moreover, the Rebbe believed and taught that it is every Jew’s religious obligation
to overcome such tendencies, and to help other Jews overcome them.
28. The Rebbe’s teachings were by no means merely philosophical or theoretical; they
were rooted in Torah, halacha (Jewish law) and deep-seated Jewish traditions. For example, the
Rebbe’s emphasis on “ahavat Yisael,” helping other Jews return to their faith, was well-grounded
in the ancient tradition of “kol Yisrael arevim zeh lazeh” (all Israel is responsible for one another),
6 Case 1:19-cv-00463-RJD-ST Document 25-2 Filed 04/11/19 Page 7 of 7 PageID #: 1488
and in the biblical directive “ve’ahavta le’re’acha kamocha” (love for fellow person as yourself)
(Leviticus 19:18).
29. Even today, some 25 years after the Rebbe’s passing, his teachings remain central
to the religious obligations of his followers. To Lubavitcher Hassidim, the “mitzvah”
(“commandment,” i.e., religious obligation) of helping another Jew become closer to his or her
faith and live in the ways of the Torah is a religious imperative.
Concluding remarks
30. There can be no question that Rabbi Schneerson was a broad-minded, sophisticated,
well educated, humane individual whose moral teachings are relevant to all mankind, especially
in our times.
31. Those of us who are aware of his moral teachings are well-advised to take them
very seriously.
32. Those who are affiliates of the Lubavitcher movement are duty bound to abide by
the Rebbe’s guidance in their personal and professional lives.
I declare under penalty of perjury under the laws of the United States that the foregoing is
true and correct, and that this declaration was executed on April 10, 2019.
______Rabbi Dr. Tzvi Hersh Weinreb
7 Case 1:19-cv-00463-RJD-ST Document 25-3 Filed 04/11/19 Page 1 of 24 PageID #: 1489
UNITED STATES DISTRICT COURT EASTERN DISTRICT OF NEW YORK
DR. DAVID SCHWARTZ, Case No.: 1:19-CV-463-RJD-ST
Plaintiff,
v. DECLARATION OF JEFFREY A. SHAFER IN SUPPORT OF THE CITY OF NEW YORK and PLAINTIFF’S MOTION FOR LORELEI SALAS, in her official capacity as PRELIMINARY INJUNCTION Commissioner of the Department of Consumer Affairs, Defendants.
I, Jeffrey A. Shafer, declare as follows: 1. I am one of the attorneys representing Plaintiff Dr. David Schwartz in this action. 2. I submit this declaration in support of Plaintiff’s Motion for Preliminary Injunction.
3. Attached as Exhibit A is a true and correct copy of a report from the Committee on Civil Rights submitted to the City Council before Law Number 2018/22 was passed, dated June 19, 2017, which I personally downloaded from the New York City Council website. I declare under penalty of perjury under the laws of the United States that the foregoing is true and correct. Dated: April 11, 2019
/s/ Jeffrey A. Shafer Jeffrey A. Shafer Alliance Defending Freedom 15100 N. 90th Street Scottsdale, AZ 85260 (480) 444-0020 [email protected]
Case 1:19-cv-00463-RJD-ST Document 25-3 Filed 04/11/19 Page 2 of 24 PageID #: 1490
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