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UNITED STATES DISTRICT COURT DISTRICT OF NEW JERSEY TRENTON DIVISION TARA KING, ED.D., individually and on behalf of her patients, RONALD NEWMAN, PH.D., individually and on behalf of his patients, NATIONAL ASSOCIATION FOR RESEARCH AND THERAPY OF HOMOSEXUALITY (NARTH), AMERICAN ASSOCIATION OF CHRISTIAN COUNSELORS (AACC), Plaintiffs, v. CHRISTOPHER J. CHRISTIE, Governor of the State of New Jersey, in his official capacity, ERIC T. KANEFSKY, Director of the New Jersey Department of Law and Public Safety: Division of Consumer Affairs, in his official capacity, MILAGROS COLLAZO, Executive Director of the New Jersey Board of Marriage and Family Therapy Examiners, in her official capacity, J. MICHAEL WALKER, Executive Director of the New Jersey Board of Psychological Examiners, in his official capacity; PAUL JORDAN, President of the New Jersey State Board of Medical Examiners, in his official capacity, Defendants. Case No. 13-cv-5308
PLAINTIFFS’ RESPONSE TO INTERVENOR-DEFENDANT’S OBJECTIONS TO EVIDENCE SUBMITTED IN SUPPORT OF PLAINTIFFS’ RESPONSE IN OPPOSITION TO DEFENDANTS’ CROSS-MOTIONS FOR SUMMARY JUDGMENT1
Plaintiffs note that the State Defendants have not objected to Plaintiffs’ tendered declarations, nor have they responded to Plaintiffs’ objections against their expert witness. Nevertheless, dozens of pages consisting in the minutia of technical points of evidence have been filed together with hundreds of pages of declarations and exhibits between Intervenor-Defendant Garden State Equality and Plaintiffs, just as Plaintiffs’ counsel cautioned would happen if GSE were allowed to intervene.
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Plaintiffs, by and through counsel and pursuant to Fed. R. Civ. P. 56 and L.Civ.R. 56.1, submit this response in opposition to Defendant-Intervenor’s Objections to Plaintiffs’ Evidence in Support of their Response to Defendants’ Cross-Motions for Summary Judgment. RESPONSE TO GENERAL OBJECTIONS Defendant-Intervenor Garden State Equality (GSE) objects to the entire declaration of Dr. Judith Reisman on the unfounded basis that her qualifications are insufficient under FRE 702. (GSE Objections at 1) (citing FRE 702 and Daubert v. Merrell Dow Pharms., Inc., 509 U.S. 579 (1993)). In support of its position, GSE notes that Dr. Reisman’s degree is not in the field of mental health. However, as any first year law student knows, the qualifications for an expert witness are not narrowly limited to education, but are broadly defined to include “knowledge, skill, experience, training, or education.” FRE 702 (emphasis added) (“A witness who is qualified as an expert by knowledge, skill, experience, training, or education may testify in the form of an opinion . . .”). As Dr. Reisman’s exhaustive C.V. makes quite clear, she has extensive experience, knowledge, skill, and training in the fields of science fraud, human sexuality, child sexual abuse, and the like, and she has authored numerous books and articles in these fields as well as in the field of sexual orientation. (See Declaration of Dr. Judith Reisman at 2-3); (see also id. Ex. A) (detailing her books, articles, and authoritative role in various capacities). In addition, Dr. Reisman has been qualified as an expert witness in a wide variety of international settings, including the United States Senate, a Presidential Commission, the U.S. Attorney General’s Commission on Pornography, the U.S. Attorney General’s Task Force on Domestic Violence, the Australian Parliament, and various state governments. Indeed, Dr. Reisman is likely the world’s foremost expert on Alfred Kinsey and his deeply flawed and far too influential “research,” which undergirds the entire edifice on which Defendants’ theory of sexuality rests. 2
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(See id. Ex. A); see also Judith Reisman, Kinsey, Crimes & Consequences, The Institute for Media Education (Crestwood, KY, 1998, 2000, 2003, 2011) and Judith Reisman et al., Kinsey, Sex and Fraud (Huntington House, Lafayette, LA, 1990). Dr. Reisman’s extensive qualifications are more than adequate to meet the modest requirements of FRE 702. GSE’s other general objections are equally unavailing. Dr. Rosik’s testimony (Rosik Decl. ¶¶ 9-16) are relevant here because of the undue emphasis Defendants place on the Ninth Circuit panel’s decision in Pickup v. Brown, No. 12-17681, 2013 WL 4564249 (9th Cir. Aug. 29, 2013). Finally, GSE’s gratuitous comment opining as to the effect of this Court applying rational basis review (which it should not) is neither appropriate nor well taken. Accordingly, GSE’s general objections should be overruled in their entirety. RESPONSE TO PARTICULAR OBJECTIONS GSE challenges several specifics of Plaintiffs’ testimony as irrelevant to the case at hand. These objections, however, ignore the language of the relevancy rule and the precedent that has interpreted that rule. “‘Relevant evidence’ means evidence having any tendency to make the existence of any fact that is of consequence to the determination of the action more probable or less probable than it would be without the evidence.” Fed. R. Evid. 401; see also Daubert, 509 U.S. at 587. “The Rule’s basic standard of relevance thus is a liberal one.” Id. All of the statements objected to as irrelevant have the tendency to make a fact of consequence more probable or less probable. Certainly under the very liberal standard applied to relevant evidence, GSE has not and cannot make any showing that the testimony does not have any tendency to makes facts more or less probable. As such, these objections should be overruled. GSE also objects to numerous statements by Plaintiffs’ witnesses as lacking foundation or lacking personal knowledge. This objection also ignores the language of the rule and the 3
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precedent interpreting it. “A witness may not testify to a matter unless evidence is introduced sufficient to support a finding that the witness has personal knowledge of the matter.” Fed. R. Evid. 602. Proof of personal knowledge can be shown by, inter alia, the witness’s own testimony. Id. A trial court has discretion to determine whether a witness has personal knowledge about a matter to which he is testifying, and the court has adequate justification for finding that a witness has personal knowledge “when other evidence indicates that the witness has a personal connection to the subject matter,” and “there is nothing to suggest that the witness did not have or could not have had such knowledge.” United States v. Davis, 792 F.2d 1299, 1304 (5th Cir. 1986). Moreover, this personal knowledge requirement does not mandate that a witness be absolutely certain about the matter to which he is testifying. A witness’s testimony need not “rise to the level of absolute certainty. Evidence is inadmissible under this rule only if in the proper exercise of the trial court’s discretion it finds that the witness could not have actually perceived or observed that which he testifies to.” M.B.A.F.B. Fed. Credit Union v. Cumis Ins. Soc., Inc., 691 F.2d 930, 932 (4th Cir. 1982) (emphasis added). GSE also objects to numerous statements as hearsay. To the extent that any of these statements is hearsay under the definition establish by Rule 801(c), they all either fall into an exception to the hearsay requirements or are being offered for reasons other than to prove the truth of the matter asserted. “‘Hearsay’ is a statement, other than one made by the declarant while testifying at the trial or hearing, offered in evidence to prove the truth of the matter asserted.” Fed. R. Evid. 801(c). Nevertheless, there are numerous exceptions to this rule that allow statements falling under that definition to be admitted despite being hearsay. The applicable exception to nearly all of GSE’s objections in this case derives from statements made for the purposes of medical diagnosis or treatment. See Fed. R. Evid. 803(4). 4
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Any objections to statements made by the Plaintiff psychologists or the Does are not well taken and should be rejected. See United States v. Balfany, 965 F.2d 575, 581 (8th Cir. 1992) (applying FRE 801(c) exception to statements made to psychologists). This exception has also extended to statements made by parents of a minor patient. See United States v. Yazzie, 59 F.3d 807 (9th Cir. 1995). “In most circumstances, we believe that statements to a doctor by a parent of an injured child could easily qualify as a statement for purposes of obtaining a proper medical diagnosis.” Id. at 813 (emphasis added); see also Stull v. Fuqua Indus., Inc., 906 F.2d 1271, 1273-74 (8th Cir. 1990) (noting that this exception applies not just to patients but also “in some instances from someone with a special relationship to the person seeking treatment, such as a parent”). In accordance with the above principles and in response to GSE’s particular objections, Plaintiffs state as follows:
Paras. 6, 7, 17, 18, 21, 23, 25, 29, 41, 45 – Dr. Rosik’s assertions are relevant because they go to the credibility of Defendants’ experts, and credibility is always and unquestionably relevant. Para. 39 – This is relevant both to Plaintiffs’ vagueness claim and to the damages/harm claims.
Para. 5 – This is appropriate because (a) Dr. Newman represents clients here, and (b) the hindrance of psychologists is based on his own knowledge, expertise, and experience. Paras. 6, 7, 8, 9, 11, 17 – These assertions go to bias, as well as to Plaintiffs’ Free Exercise claim.
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Para. 10 – This assertion goes to bias and the lack of any legitimate state interest that is being served by A3371. Moreover, its foundation is based on Dr. Newman’s own education and experience. Para. 13 – This assertion goes to damages and the need for injunctive relief, and it is based on Dr. Newman’s perceived effect of the law and his response thereto. Paras. 14, 15, 16 – These assertions go to the need for injunctive relief and Plaintiffs’ free speech claims. Para. 18 – This assertion is based on Dr. Newman’s own experience. Para. 22 – This is based on Dr. Newman’s first hand knowledge. It is not hearsay because it falls within the exception of FRE 803(4).
Para. 5 – GSE’s objection on the basis of lack of foundation is not well taken and is itself without foundation, as Dr. Reisman’s qualifications attest to her expertise. As for relevance, the statement is offered merely by way of background information and is therefore relevant. Paras. 5-9 – These paragraphs set forth Dr. Reisman’s background, training, experience, and expertise, and are therefore relevant. They are also amply supported by way of adequate foundation. (See Decl. Reisman at Ex. A). The objection based on speculation is utterly without any basis and should be denied out of hand. Para. 12 – Dr. Reisman’s work on HR 2749 is detailed in the Congressional Record and elsewhere, and the objections are therefore not well taken. Paras. 14-16 – These paragraphs are relevant to Dr. Reisman’s expertise and the impact that the fraudulent research of Dr. Kinsey has had on many nations. The statements contained in these
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paragraphs are based upon Dr. Reisman’s own personal knowledge, as well as the reports from the nations themselves. Paras. 19-23 – To these paragraphs, GSE objects most strenuously – and for good reason, because Dr. Reisman’s statements decimate the very foundation of Defendants’ entire position. Nonetheless, they are highly probative and relevant to the entirety of the testimony of Defendants’ experts and the legitimacy of A3371 and its reliance on the alleged “consensus.” They are indeed prejudicial, but certainly not in a manner violative of the rules of evidence. Indeed, all evidence exposing the fundamental flaws of a party’s defense is prejudicial, but only because it reveals the baseless nature of a party’s claim. All probative evidence condemning a party’s argument is prejudicial, but this does not implicate the standard for prejudice contemplated by the rules of evidence. Dr. Reisman’s statements are thoroughly grounded on both her own personal knowledge and experience, but also in the numerous citations to authoritative sources contained in these paragraphs themselves. They are not argumentative, but merely hard-hitting and therefore admissible. Defendant’s objections should be overruled. Indeed, Dr. Reisman’s careful examination and exposé of Kinsey’s horrific methodology is exactly what Defendants and the APA Task Force Report purport to do to the research supporting SOCE. Their objections therefore fail not only under the rules of evidence, but under rules of equity as well: If Dr. Reisman’s thorough exposition of Kinsey’s fraudulent research, upon which Defendants’ theories depend entirely, is improper or inadmissible, then so too is all of the testimony of Defendants’ expert witnesses, as well as the APA Task Force Report itself. Dr. Reisman’s testimony is admissible. Paras. 23-25 – These paragraphs continue the discussion and testimony concerning a brief history of the purported legitimization of homosexuality as “normative,” resulting entirely from 7
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the ideological and political change by the APA wholly unrelated to science, and they are relevant, non-argumentative, supported by an adequate foundation, and admissible for the same reasons as set forth in the immediately preceding paragraphs. These paragraphs are also relevant to Plaintiffs’ claim of viewpoint discrimination. In a nutshell, as Dr. Reisman’s Declaration establishes, Defendants’ position is founded not on science, but on mere opinion and viewpoint. As such, A3371 is invalid as an act of viewpoint discrimination, and Dr. Reisman’s testimony is admissible to demonstrate the facts and developments underlying this claim. Paras. 26 and 27 – See response to Paras. 23-25 above. Paras. 28-30 – See response to Paras. 23-25 above. Paras. 31-39 – See response to Paras. 23-25 above. In addition, Dr. Drescher, the State’s expert witness, specifically cites Kinsey with approval, as noted by Dr. Reisman. (Reisman’s Decl. at ¶¶ 33-36). These citations, as well as the reliance of all of Defendants’ experts on Kinsey’s fatally flawed “research,” only heightens the relevance of Dr. Reisman’s testimony. As Dr. Reisman’s quotation of Dr. Drescher’s claimed expert in sex history so accurately put it: “Politics and science go hand in hand. In the end it is Gay activism which determines what researchers say about gay people.” (Id. ¶37) (emphasis added). What Defendants cannot tolerate is researchers who do not tow the party line. Moreover, as Dr. Reisman states, (Reisman Decl. ¶38), “scientifically, homosexual youth do not exist.” (Id. ¶38) (emphasis original). To claim such insights are “irrelevant” is absurd under these circumstances, where the fundamental presupposition of A3371 is that homosexual youth do exist, naturally occur, and cannot change. Otherwise, why would the draconian prohibition on SOCE even be necessary? Defendants’ objections are thus seen to be motivated
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not by the rules of evidence, but by partisan advocacy, which is evident by the ideological position statements specifically cited in A3371. Paras. 40-55 – See response to Paras. 23-25 above. In addition, Plaintiffs state that GSE has not offered the testimony of Dr. Drescher; he is the State’s witness, and the State has not objected. Therefore, these objections should be given little weight in any event. Moreover, the glaring inconsistency of Dr. Drescher’s unfounded assertion (rank speculation that it is) that minors are incapable of voluntarily consenting to SOCE under any circumstances and his organization’s zealous advocacy of precisely the opposite position when it comes to minors consenting to sex with pedophiles is highly relevant to Dr. Drescher’s questionable credibility. (See Decl. Reisman ¶ 40). So, too, is Dr. Drescher’s wholesale adoption of Kinsey’s fraudulent research. (Id. ¶¶ 4144). In the same vein, Dr. Drescher’s candid admissions that it was political pressure, not scientific principle that led to the declassification of homosexuality as a disorder are quite relevant to the entire premise on which A3371 is based, and the mantra that “[b]eing lesbian, gay, or bisexual is not a disease, disorder, illness, deficiency, or shortcoming.” (Id. ¶ 27 (quoting A3371); (id. ¶¶ 45-46). Additionally, Dr. Reisman sets out the data concerning the extraordinarily high percentage of self-identifying homosexuals who admit that they were sexually abused by adults and/or had sex before the age of 13. (Id. at ¶ 51). This testimony is highly relevant to the issues presented here because the Act purports to protect children, who according to the authoritative data cited by Dr. Reisman are peculiarly at risk for sexual abuse, yet the Act renders help for those desiring counseling for unwanted sexual confusion off limits to them. The attraction of homosexuals to underage boys is further underscored by Dr. Reisman’s testimony describing the disturbing images made the mascots of The Advocate and The Queen’s Vernacular, the leading 9
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mainline homosexual publication and the first mainline dictionary for homosexuals, respectively, are similarly relevant to the theme of the protection of children and whether the Act serves its ostensible purpose at all. (Id. ¶¶ 52-53). Dr. Reisman’s testimony and analysis of Dr. Drescher’s declaration is at least as admissible as Dr. Drescher’s declaration, and likely much more so. GSE’s objections should be overruled. Paras. 56 and 57 – GSE objects to Dr. Reisman’s insightful observations as to the inconsistency of Dr. Davies’ testimony concerning the critical issue of whether SOCE is appropriate for children who have been sexually molested. (Id. ¶ 56). Again, Dr. Reisman’s critique of Dr. Davies’ testimony rises or falls with Dr. Davies’ own testimony – if the one is admissible, so is the other. Dr. Reisman’s testimony cites to the all-too-relevant findings of no less an authority than the U.S. Department of Justice, which document that 64% of forcible sodomy victims are boys. (Id. ¶ 57). The resulting sexual confusion cries out for a remedy, but A3371 slams the door in the face of these poor children who have already suffered so much. Dr. Reisman’s testimony should be admitted. Paras. 59-61 – GSE fails to object to ¶58, which contains a quote from Dr. Davies’ declaration as well as her citation to a particular authority, and then proceeds to object vociferously to Dr. Reisman’s critique of that authority and explanation of the presuppositions on which the authority’s position is based. This is both inconsistent and unavailing. (Id. ¶¶ 59-61). Paras. 62-63 – These paragraphs are relevant to the basis on which the New Jersey legislature has disfavored the interests of children, which Dr. Reisman then links to the passage of A3371. Paras. 64-73 – See response to Paras. 23-25 above. Paras. 74-82 -- See response to Paras. 23-25 above. Dr. Reisman’s conclusion set forth in ¶¶ 7982 are especially relevant as a summation of her detailed research and analysis of the 10
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incalculable harm that has been occasioned as a result of reliance on the fraudulent data foisted upon a naïve public by Alfred Kinsey and his allies, and upon which Defendants still rely. GSE’s objections should be overruled. Exhibit B – GSE also objects to Exhibit B, Dr. Reisman’s paper succinctly summarizing the flawed methodology of Kinsey’s “research” and the incredible effect his data has had on the development of sexual research. It should be admitted.
Para. 3 – This testimony is based on Doe’s own personal knowledge, and includes merely the designation of his particular disorder as diagnosed by his licensed counselor. Regardless of the precise categorization of his illness, the essence of his story remains highly relevant to this case because he is one upon whom A3371 operates directly. Para. 6 – Doe’s statement that his parents were aware of his suicidal tendencies is not essential to his story, and in any event is corroborated by the testimony of his parents. Paras. 7-9 – This testimony is corroborated by Doe’s parents, and his recitation of his understanding of what his therapist explained is telling because it shows the speculations of Defendants’ experts as to the inability of minors to understand or consent to SOCE is false. Para. 11 – Doe’s explanation of the lowering of his voice is obviously based on his own personal knowledge, regardless of the lack of precision in his terminology. It should be admitted. Para. 12 – That Doe believes his same-sex attractions have lessened is relevant and admissible regardless whether his numerical designation is correct. Paras. 13 and 15 – Doe’s expressions of hope for the future and concern because of the negative impact of A3371 on his relationship with his counselor go to the heart of the issues in this case
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and are not speculative insofar as they are admissible under the then-existing mental condition provided by FRE 803(3).
Paras. 2 and 4 – The statement regarding the invasion of the rights of the Does is admissible as setting forth Mrs. Doe’s own interpretation of the Act and its effect on her family. As well, her statements regarding her son and his inclinations are plainly based on personal observation and knowledge and are therefore admissible. Paras. 5-7 – These statements are Mrs. Doe’s personal observations and recollections of the pertinent events concerning her son’s digression into sexual confusion and the salient events informing that slide. As such, they are relevant, admissible, and not subject to the hearsay objection. Paras. 8-10 – Mrs. Doe’s background is relevant to inform the Court as to her credibility and ability to assess the situation involving her son. The incident involving her son’s use of homosexual pornography is relevant for the purpose of explaining his tendency toward homosexual behavior and his actions consistent with such tendencies. The testimony in ¶10 regarding the qualifications and religious affiliation of their therapist is relevant to Plaintiffs’ claims concerning a violation of their free exercise rights, as well as their claim of viewpoint discrimination and the lack of secular counselors who address or even understand clients desiring SOCE. The Court may take judicial notice of the representations set forth in footnote 1. Paras. 11-14 – GSE’s hearsay objections are not well taken, because the theory on which the Doe’s therapist proceeded informs the dispute at issue here regarding the cause of homosexual tendencies, the need for SOCE, and the accuracy of the various theories undergirding the practice. The statement in ¶12 regarding John Doe’s goals for the therapy are not hearsay 12
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because they inform the purpose and desire for seeking and receiving SOCE, which is directly at issue here. The statements in ¶13 are relevant in rebuttal to Defendants’ experts’ assertions that SOCE counselors coerce their clients and offer inaccurate and incomplete information. (See, e.g., Decl. Drescher at ¶¶ 11, 19, 20). The statements in ¶14 are based on the first-hand knowledge of Mrs. Doe, and are therefore admissible. Paras. 15-16 – Mrs. Doe’s statement regarding the possible need of John Doe for therapy the rest of his life is based not on speculation, but on a reasoned inference drawn from Mrs. Doe’s first hand observations and experience, and is therefore admissible. Her beliefs related in ¶16 are admissible for the same reason. Paras. 17-21 – The hearsay objection to the statement in ¶17 is well taken. The remaining statements in that paragraph and the following paragraph, however, are admissible as Mrs. Doe’s reasoned conclusions and genuine concerns as to the effects of A3371. The objection to ¶19 is well taken. The statements in ¶¶20-21 are relevant to Plaintiffs’ claims of interference with parental rights and are therefore admissible.
Paras. 2 and 4 – Mr. Doe’s statement as to the invasion of his rights is founded on his personal knowledge and experience with the impact of the law and is thus admissible. The statement in ¶4 regarding the factors that the Does and their therapist believe gave rise to John Doe’s sexual confusion are relevant to the need for SOCE and whether it actually protects or in fact harms children. They should therefore be admitted. Paras. 5-7 – The statements in these paragraphs regarding John Doe’s tendencies while young are relevant to the development of his unwanted sexual confusion. Defendant simply disagrees as to the significance of these facts, but that disagreement does not render them inadmissible. 13
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Paras. 8-11 – The statements in ¶8 are relevant because they reinforce Plaintiffs’ position that the hostility against practitioners (and clients) of SOCE tend to be of a secular viewpoint while those favoring SOCE are more religious. The statements in ¶9 are relevant to demonstrate the progress that John Doe has made as a result of SOCE. The statement in ¶10 is based upon personal knowledge and observation and is therefore admissible. Finally, the statements in ¶11 are relevant to Plaintiffs’ claims for damages and irreparable harm, and are based on Mr. Doe’s personal experience with the Act and its impact on his family. Respectfully submitted, /s/ Demetrios Stratis Demetrios Stratis New Jersey Bar No. 022391991 Mathew D. Staver* Stephen M. Crampton* Daniel J. Schmid* Liberty Counsel Attorneys for Plaintiffs P.O. Box 11108 Lynchburg, VA 24502 Tel. 434-592-7000 Fax: 434-592-7700 court@LC.org * Admitted Pro Hac Vice
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CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing was filed electronically with the court on September 28, 2013. Service will be effectuated by the Court’s electronic notification system upon all counsel of record.
/s/ Demetrios Stratis Demetrios Stratis New Jersey Bar No. 022391991 Mathew D. Staver* Stephen M. Crampton* Daniel J. Schmid* Liberty Counsel Attorneys for Plaintiffs P.O. Box 11108 Lynchburg, VA 24502 Tel. 434-592-7000 Fax: 434-592-7700 court@LC.org *Admitted Pro Hac Vice Attorneys for Plaintiffs
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