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121-Reeves-Declaration Case 2:17-cv-00050-CCC-CLW Document 121 Filed 02/06/20 Page 1 of 4 PageID: 1494 UNITED STATES DISTRICT COURT DISTRICT OF NEW JERSEY : Honorable Claire C. Cecchi, U.S.D.J. JIONNI CONFORTI, : Honorable Cathy L. Waldor, U.S.M.J. : Plaintiff, : : Case No. 2:17-cv-00050 (CCC/CLW) v. : : ST. JOSEPH’S HEALTHCARE SYSTEM, : INC., ST. JOSEPH’S HOSPITAL AND : MEDICAL CENTER D/B/A ST. JOSEPH’S : REGIONAL MEDICAL CENTER, and : FATHER MARTIN D. ROONEY, : : Defendants. : DECLARATION OF DONALD RAYMOND REEVES, JR., M.D. DONALD RAYMOND REEVES, JR., M.D. declares as follows: 1. I have been retained by counsel for Defendants St. Joseph’s Health, Inc., St. Joseph’s University Medical Center, Inc., and Father Martin D. Rooney (collectively, “Defendants”) to serve as an expert witness in this matter. 2. I am a physician specializing in psychiatry, licensed in the States of New Jersey and New York, and board certified in Psychiatry and the subspecialty of Forensic Psychiatry. My Curriculum Vitae is included with this declaration as Attachment A. If called as a witness, I could and would competently testify to these facts as set forth herein. 3. By way of brief biographical background, I obtained my undergraduate degree from Princeton University with a major in psychology in 1986 and obtained my medical degree from the University of Texas Southwestern Medical Center in 1991. Thereafter, I attended my medical residency in psychiatry and participated in a fellowship program in psychiatry, both at St. ME1 32583901v.1 Case 2:17-cv-00050-CCC-CLW Document 121 Filed 02/06/20 Page 2 of 4 PageID: 1495 Vincent’s Hospital in New York, New York. I presently maintain a private practice at my medical office, Hydrangea Hill Psychiatric Associates, Inc., located at 112 Raymond Avenue, South Orange, New Jersey 07079. 4. I have written numerous peer-reviewed bibliographies and participated in countless lectures and conferences relating to the field of psychiatry. Among other lectures and conferences, on August 7, 2014, I participated in a statewide lecture for University Correctional Health Care clinicians concerning the diagnosis and treatment of gender dysphoria. 5. My psychiatric experience has been diverse. In my practice of psychiatry, I have extensive experience in diagnosing and treating patients with mental disorders. I have treated psychiatric in-patients and out-patients for serious and less serious mental conditions and have extensive experience in short- and long-term psychotherapy, as well as pharmacotherapy. I am familiar with the Diagnostic and Statistical Manual of Mental Disorders (DSM-5), including the DSM-5’s definition of the condition known as “gender dysphoria.” I have the competency and experience to diagnose gender dysphoria. I am also familiar with treatments for gender dysphoria. 6. My proposed examination of plaintiff Jionni Conforti, if allowed by the Court, would consist of a mental status examination, a developmental history, a psychiatric history (including treatments for psychiatric and psychological conditions), a family history, an education and work history, and the history of Plaintiff’s alleged gender dysphoria. This would include taking a history of Mr. Conforti’s present psychiatric complaints, including subjective psychological symptoms and objective signs, as well as inquiring into causal factors. This will include a history of the changes over time in Mr. Conforti’s psychological and/or emotional signs or symptoms since the onset of any psychological or emotional distress reportedly 2 ME1 32583901v.1 Case 2:17-cv-00050-CCC-CLW Document 121 Filed 02/06/20 Page 3 of 4 PageID: 1496 connected to the denial of his request for a hysterectomy to be performed at St. Joseph’s as described in the Complaint. In addition, I will inquire into any past history of emotional distress and psychological symptoms and signs, including any similarity or contribution to Mr. Conforti’s claim of emotional distress, psychological symptoms and signs, and impairment and/or disability, if any. I will ask Mr. Conforti about any past psychiatric, psychological and/or mental health treatment, as well as the hysterectomy that I understand was performed at a hospital other than St. Joseph’s to determine the effectiveness of such treatment and whether he had any residual emotional distress, psychological symptoms and signs, and psychiatric impairment and/or disability, if any. Drug and alcohol history also reveals important information about potential causal factors of past and current psychiatric disability. 7. I intend to assess the following topics if I am permitted to examine Mr. Conforti: Plaintiff’s alleged emotional distress, depression and anxiety that purportedly were caused by Defendants’ conduct described in the Complaint, including the extent and duration of same, other potential causes of Plaintiff’s alleged distress/depression/anxiety and the treatment Plaintiff has undergone (including medications) for same; and Plaintiff’s claimed gender dysphoria and the impact on the dysphoria symptoms of the hysterectomy that Plaintiff underwent at a different hospital. 8. Based on my review of Mr. Conforti’s allegations in the Complaint, his deposition testimony in this matter, and medical records from various medical providers who have evaluated and treated Mr. Conforti, my professional opinion is that a comprehensive forensic psychiatric clinical examination of Mr. Conforti, given his known preexisting psychiatric disorder, is necessary to assess the psychiatric distress he claims he suffered as a result of the denial of his hysterectomy. 3 ME1 32583901v.1 Case 2:17-cv-00050-CCC-CLW Document 121 Filed 02/06/20 Page 4 of 4 PageID: 1497 9. If permitted by the Court, I would conduct the mental examination of Mr. Conforti at my medical office, which I believe is approximately 15 miles from his residence. I declare under penalty of perjury that the foregoing is true and correct. Donald Raymond Reeves, Jr., M.D. Dated: February 5, 2020 4 ME1 32583901v.1 Case 2:17-cv-00050-CCC-CLW Document 121-1 Filed 02/06/20 Page 1 of 14 PageID: 1498 EXHIBIT A Case 2:17-cv-00050-CCC-CLW Document 121-1 Filed 02/06/20 Page 2 of 14 PageID: 1499 Donald (Rusty) Raymond Reeves, Jr., M.D. Curriculum Vitae PERSONAL DATA: Name: Donald (Rusty) Raymond Reeves Jr., MD Private Practice: Hydrangea Hill Psychiatric Associates, Inc., 112 Raymond Ave., South Orange, New Jersey 07079; (973)-378-9599; fax: (973) 378-9599; e-mail: [email protected] University Office: Dept. of Psychiatry, Rutgers U. – Robert Wood Johnson Medical School 671 Hoes Lane, Piscataway, NJ 08854; (732) 235-4433; e-mail: [email protected] UCHC Office: P.O. Box 863, Bates Building, 2 nd Floor, Whittlesey Road, Trenton, NJ 08625 (609) 292-3096 x5228; fax: (609) 341-9380 EDUCATION: Undergraduate: Princeton University, Princeton, New Jersey, 1982 to 1986; Degree: B.A. with Highest Honors; Major: Psychology Medical School: University of Texas Southwestern Medical Center, Dallas, Texas, September, 1986 to May, 1988, and July, 1989 to May, 1991; Degree: M.D. POSTDOCTORAL TRAINING: Internship: St. Vincent's Hospital, New York, New York, July, 1991 to June, 1992 Residency: Psychiatry, St. Vincent's Hospital, New York, New York, July, 1992 to June, 1995 Fellowship: Forensic psychiatry, St. Vincent's Hospital, New York, New York, July, 1997 to June, 1998 LICENSURE: New Jersey – #25MA06641000, expiration 06/30/21 New York – #192287, expiration 11/30/20 CERTIFICATIONS: Distinguished Fellow of the American Psychiatric Association, December 15, 2015 American Board of Psychiatry and Neurology, Diplomate in Psychiatry, #43883, expiration 12/31/27 Case 2:17-cv-00050-CCC-CLW Document 121-1 Filed 02/06/20 Page 3 of 14 PageID: 1500 American Board of Psychiatry and Neurology Diplomate in Forensic Psychiatry, #1184, expiration 12/31/27 NARCOTICS CERTIFICATION: New Jersey CDS #D076483, expiration 10/31/19 DEA #BR4142270, expiration 04/30/21 DEA #FR1278868, expiration 04/30/21 UNIVERSITY APPOINTMENTS: Instructor, New York Medical College, July 1994 to June, 1995 Assistant Professor of Psychiatry and Behavioral Sciences, New York Medical College 1997 to 1999 Assistant Professor of Psychiatry, University of Medicine and Dentistry of New Jersey, 1999 to April, 2005 Associate Professor of Psychiatry, Rutgers University (formerly University of Medicine and Dentistry of New Jersey), April, 2005 to June, 2017 Professor of Psychiatry, Clinical Educator Track, Rutgers University July, 2017 to present HOSPITAL APPOINTMENTS: Atlanticare Hospital, Lynn, Massachusetts, July, 1995 to January, 1996 Bayridge Hospital, Lynn, Massachusetts, January, 1996 to June, 1997 St. Vincents Hospital, New York, New York, 1997 to 2000 Kirby Forensic Psychiatric Center, New York, New York, 1998 to 1999 University Hospital, Newark, NJ, 1999 to 2005 PROFESSIONAL POSITIONS: St. Vincent's Hospital, Westchester Branch, moonlighting, 1993 to June, 1995 Atlanticare Hospital (Choate Health Systems), Lynn, Massachusetts, staff psychiatrist, July 1995 to January, 1996 Bayridge Hospital (Choate Health Systems), Lynn, Massachusetts, staff psychiatrist, January 1996 2 Case 2:17-cv-00050-CCC-CLW Document 121-1 Filed 02/06/20 Page 4 of 14 PageID: 1501 to June 1997 St. Vincent's Hospital, New York, New York, attending community consultation psychiatrist, July 1997 to April, 1998 (job sites: Flemister House, a day-treatment program for persons with AIDS; Manhattan Detention Center (the Manhattan jail), July 1997 - December 1997) St. Barnabus Hospital, January, 1998 to July,
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