The defense in last year’s civil lawsuit against Jews Offering New Alternatives for Healing, or JONAH (the acronym formerly stood for Jews Offering New Alternatives to Homosexuality), offered six men it claimed were “expert” witnesses. The six Joseph Berger, Christopher Doyle, Joseph Nicolosi, James Phelan, John Diggs and Rabbi Avrohom Stulberger were presented as people who could, based on evidence generally accepted by the scientific community, explain and defend the practices of JONAH. As such, they were each required to submit an expert report in advance of trial explaining their opinions, and also had to submit to depositions taken by the plaintiffs’ lawyers, who worked hard to discredit them. The plaintiffs’ attorneys later argued to the judge that the experts should be excluded largely because their testimony was based on the assertion that homosexuality is a disorder, despite the fact that no authoritative medical organization agrees. In the cases of Diggs and Stulberger, New Jersey Superior Court Judge Peter F. Bariso Jr. excluded their testimony because Diggs’ assertion that homosexual behavior involves health risks and Stulberger’s expertise on Orthodox Judaism’s view of homosexuality were irrelevant to the issues at trial. Bariso also excluded the much more important testimony of the other four men, who are longtime proponents of reparative therapy and well known in their field (with a narrow exception allowing one of them to testify that it was unusual that one of the plaintiff’s therapist’s notes did not make more mention of JONAH). Bariso ruled that “the universal acceptance” of the “scientific conclusion” that homosexuality is not a disorder “requires that any expert opinion to the contrary be barred,” along with any opinion based on that claim. As Judge Bariso concluded, “[T]he theory that homosexuality is a disorder is not novel but like the notion that the earth is flat and the sun revolves around it instead is outdated and refuted.” He also asserted that one of the proffered experts had plagiarized others’ work for his expert report to the court. What follows are excerpts from depositions taken from Berger, Doyle, Nicolosi and Phelan by plaintiffs’ lawyers in late 2014, in advance of trial.

DR. JOSEPH BERGER

Dr. Joseph Berger is a Jewish psychiatrist and psychotherapist who has long been part of the conversion therapy movement, although he is married to a woman and says he has never experienced same-sex attractions (SSA) himself. Trained in the United States, Berger practices from offices in Ontario, Canada, where he has treated men with SSA and in which country, in 2006, he addressed a parliamentary committee in order to urge it not to afford “special rights” to transgender people. (If such people claim that they are, for instance, a “woman trapped in a man’s body,” Berger described them as a clinically “psychotic.” If they say they merely feel that way, but recognize that they are not one sex trapped in another’s body, then they are simply unhappy, Berger testified, and “[t]he proper treatment of emotional unhappiness is not surgery,” a reference to gender reassignment surgery.)

Berger wrote a 1994 article in the American Journal of Psychotherapy, entitled “The Psychotherapeutic Treatment of Male Homosexuality,” that, he claimed, “confirms that such patients can indeed be understood and treated successfully,” with many of them becoming “comfortably and fulfillingly heterosexual.” Berger has been closely aligned with the National Association for Research & Therapy of Homosexuality (NARTH), guest editing a NARTH bulletin some years ago, giving a presentation to a NARTH conference in 2013 on “When the Persecuted Become the Prosecutors,” accepting NARTH patient referrals, and joining NARTH’s scientific advisory committee. He also has performed many independent evaluations of disability benefits claimants for the Canadian government and others, and written a book on that topic. Berger said he was motivated to testify by “the false allegations made by the plaintiffs.”

Is homosexuality a disorder?

Is it a disorder? The official diagnostic nomenclature decided that it would exclude it in terms of being considered a disorder. I’m not going up and fighting against them, so it doesn’t, any more, enter sort of that realm of our terminology.

… What I consider it to be, in terms of generalizing, that it is a failure to reach full psychosexual development. And I define full psychosexual development as the ability to relate intimately in a long-term relationship with somebody of the opposite sex.

Do you think transgender children should be ridiculed by their peers?

… No, I don’t think transgender children should be ridiculed by their peers.

When you wrote on the NARTH website that transgender children should be ridiculed by their peers?

No, I didn’t. You’re getting a distortion from Mr. [Wayne] Besen [an activist who forcefully opposes conversion therapy and who publicized Berger’s 2006 Internet comment about transgender children]. That is a distortion. I didn’t write that, I never said that, and I never thought it. It is a distortion.

So you did not write the words [advocating letting children who want to go to school wearing clothing associated with the opposite sex to do so]: “On the contrary, don’t interfere, and let the other children ridicule the child who has lost that clear boundary between play acting at home and the reality needs of the outside world. Maybe in this way, the child will re-establish that necessary boundary.” … Dr. Berger, did you or did you not write those words?

I’m not aware of writing those words. I am aware of participating in a discussion, a hypothetical discussion, that I think has been distorted by Mr. Wayne Besen, and publicized around. So that even people who have no idea of the original context have misquoted, misread and distorted it, so I don’t know.

What is your explanation for homosexual behavior in animals?

… People claim that. I don’t, in a sense, I don’t understand their claims, because I don’t really relate animals to human beings. There are some aspects of animal behavior that we can observe that can be helpful in terms of our understandings, and other things not. I wouldn’t necessarily interpret such things as so-called homosexual behavior in animals as being analogous in any way to us as humans.

Why not?

Because I don’t. I don’t think it relates to us as humans. I think we’re different.

And then what follows [in a 2002 study of harm reported by people undergoing conversion therapy, Changing Sexual Orientation: A Consumers’ Report, by Ariel Shidlo and Michael Schroeder, published in Professional Psychology: Research and Practice] is, essentially, a list of various harms that participants in the study reported. Does that not trouble you?

… This is not harm, per se. This is people’s feelings of unhappiness and distress. That’s not necessarily harm, per se. … One of them goes as far as to say that she wanted to die, yes. Another one says, “I think it harmed me.” … But to me, it’s not necessarily it’s not necessarily objective harm… . Harm is somebody comes along and breaks your arm, if somebody comes along and hits you in the head and you’re concussed and have the possibilities of internal brain hemorrhage that’s harm.

… At the bottom of this column, it says: “We found that 11 participants had reported suicide attempts since the end of conversion therapy. Of these, only three had attempted prior to conversion therapy. Of the 11 participants, three had attempted during conversion therapy.” That doesn’t trouble you either?

… You want to extract from this one or two statements by some people, yes, undoubtedly there were people who say they were harmed. But that doesn’t necessarily mean to say that that is objective harm. That’s a very subjective thing.

What is your understanding of what gay affirmative therapy is?

My understanding … is trying to make people who identify themselves as homosexual, comfortable with who they are as a homosexual. And the problem, from my perspective, is, especially if it’s dealing with younger people in the teens, for example, that really, they may be confused. They’re not necessarily homosexual, per se, they’re identifying with it for certain reasons, such as to draw attention; to be the different one in the class; to be cool, or whatever.

CHRISTOPHER DOYLE, MA, LCPC

Describing himself as a psychotherapist, licensed clinical counselor and “prominent clinician in this field,” Christopher Doyle is a longtime member of the ex-gay movement who says that to his “astonishment,” he shifted his own sexual orientation to heterosexual at the age of 23 without the use of conversion therapy.

Doyle has an undergraduate degree in political science and history from a Christian college in Pennsylvania and a master’s in counseling from Liberty University, the conservative Christian college started by Jerry Falwell. He also says he has years of training from ex-gay advocates including the National Association for Research & Therapy of Homosexuality, the conversion therapy group that he has been a part of since 2008.

Today, he is the executive director of the Institute for Healthy Families (IHF, formerly known as the International Healing Foundation), another ex-gay group whose board includes Arthur Goldberg — who was one of the defendants in the lawsuit heard last year against JONAH — and also runs his own Northern Virginia Christian Counseling agency out of his home. Doyle said last year that he had treated some 150 clients in the prior five years and was active in lobbying for ex-gay causes, both for IHF and for two similar non-profits, Voice of the Voiceless and Equality and Justice for All.

Do you think homosexuality is a disease or disorder?

I believe it’s a maladaptive condition.

What does a maladaptive condition mean?

I believe that in most … development of individuals, I believe that development that typically occurs is bonding with the same sex, and that leads to one experiencing primarily heterosexual feelings. … So I think that because of the lack of bonding and attachment with the same sex, I think that the — it’s a maladaptive condition, meaning that the normal development does not occur.

I’m trying to figure out, you know, why it is that you think you can rely on that information [a claim by a certain counselor that he and his staff treated 18,000 cases of same-sex attraction] in your report when you don’t know anything about it.

Well, I’ve relied on a lot of research studies in my report [expert report to the court] that I don’t necessarily know all the specific methodological functions and how they did that. … I mean, there are hundreds of citations.

So how do you know that … Dr. Cummings’ numbers are valid?

I don’t.

You don’t?

No.

But you think you can rely on it even though you have no idea about the validity?

Well, I don’t think Dr. Cummings is lying. … If Cummings said he [personally] treated … over 2,000 individuals who are homosexual and hundreds changed, if he was really lying or trying to make a point, wouldn’t he say that more than a few hundred changed?

You wrote this report?

I did. It’s all my work.

And you wrote it by yourself?

I did.

[H]ow did you come to these various citations?

Well, some of them I researched myself. Some of them I got in other documents that I reviewed that were already — that I’ve already reviewed these studies and made conclusions.

Uh-huh. So did you read each one of these additional sources?

In its entirety?

Yeah.

No.

Did you read every one of these in some partial form?

Yes.

So these citations are things you went back and independently reviewed?

Some of them I have. Some of them I relied on reviews of other people.

Would that be Whitehead [a 2014 book by Neil and Briar Whitehead, My Genes Made Me Do It! Homosexuality and the Scientific Evidence]?

Including Whitehead.

… Right. But would it surprise you to know that each one of these studies listed [in Doyle’s report] are directly listed in Whitehead’s bibliography?

I don’t know if that’s to be the truth. … I don’t know. There may be overlap.

… What’s not included in Whitehead’s analysis? … Because to me it looks like there is perfect overlap between Whitehead and what’s listed here [in Doyle’s report], and, in fact, in the same order as Whitehead’s chapter. … [D]id you go and you look at these studies again, or did you just look at Whitehead and pull from Whitehead?

I did for some Whitehead and some of them I looked at myself.

Which ones?

I don’t recall all the ones I looked at myself. I reviewed hundreds of studies for this.

And in particular, it appears to me that you did draw this from [James] Phelan [who wrote the 2014 book, Successful Outcomes of Sexual Orientation Change Efforts: An Annotated Bibliography] word for word from Phelan. The first sentence you say, “According to Phelan 2009,” and then you have the sentence “homosexual men,” then it goes [on]. And that’s directly from just cut and pasted from Phelan. Correct?

Yeah. I said that I drew a lot of this from Phelan’s review.

Right. And the citation then the long citational cite just is also just cut and pasted from Phelan?

Yes.

…Basically, what you have in your report tracks directly Phelan?

From this section, yes. … I looked at a couple of them, but I relied more exclusively on Phelan’s reporting for this, yes.

... So you didn’t add anything independently based on your expertise to anything that Phelan said in this section of the report?

No, I didn’t think it was necessary to reinvent the wheel.

… Well, in the examples we showed before you didn’t summarize. You took exactly what Phelan said and plugged it into your report, didn’t you?

Not exactly, no.

You didn’t? So let’s look at Bailey. Okay? So this is Section 3, if you look on page 79. Now compare to page 79 of Phelan. It says, “Bailey’s 1999 conclusions about Herrell.”

Right. This, I did this, I did yes, I did copy it.

[W]hat is this Powell work? …

The Powell article is a it’s a manuscript. It’s a review of literature on I believe on catharsis.

Is it published?

I don’t know if it’s published. …

Where did you find it?

In my research on in my research on the Internet.

…You think that it’s okay to just rely on an unpublished document you found on the Internet?

In some instances, yes.

… So … the contents of this paragraph are also just pulled from the unpublished Powell piece. Right?

Yeah. Yep. That seems to be the it what I did.

What is sociometry? Or sociometry?

I am not familiar with the definition of that word, actually.

Yet you use it in your report?

Yes.

You then have a sentence right after that we were looking at on page 21 from Aaron 2006. Who is that?

… I believe Aaron is a therapist.

… You don’t know?

I believe it’s a therapist.

Do you know … she’s a massage therapist? Is that the kind of therapist you were thinking about?

… So you’re saying Aaron is a massage therapist?

Yep.

I didn’t know that.

Then you go down in your report and say when you say, “According to Zur and Nordmarken,” and you don’t use quotes, everything after that is [word for word] from Zur and Nordmarken. Is that how you operate?

Typically, yes.

You think that there’s a scientific basis that nudity [in therapy] can help resolve sexual orientation issues?

I think it can help resolve underlying issues that cause same-sex attractions, yes.

You have a lot of stuff in your report about [Edward] Bindrim, and you have a citation to Bindrim. … And my question is, how did you rely on that piece of work in forming your opinions in this case? I don’t recall.

… Do you think you read it?

I don’t know. It’s possible.

… The title of the article well, first of all, the journal is the Journal of Parapsychology. Did you rely on anything from the Journal of Parapsychology?

This article, apparently.

…So the title of this article from 1947 is “A New Displacement Effect in ESP.” … Did you know Bindrim was a believer in extrasensory perception?

… It was my intention to report that there was a scientific basis to the use of nudity, and I did find that in Bindrim’s work as well as in some others.

Are you familiar with a NARTH board member, Gerald [J.M.] van den Aardweg?

I’ve heard of his book [The Battle for Normality: Self-Therapy for Homosexual Persons, published in 1997]. I’ve never met the man personally.

In fact, you cite to him in your bibliography several times, don’t you?

Uh-huh.

… Van den Aardweg said there’s a correlation between homosexuality and muscle weakness. Do you subscribe to that view?

No, I don’t know of any evidence that suggests that.

JOSEPH NICOLOSI, PH.D.

Joseph Nicolosi is a licensed California psychologist, the founder and clinical director of the Thomas Aquinas Psychological Clinic, one of the three original founders of the National Association for Research & Therapy of Homosexuality (NARTH), and the best known living conversion therapy advocate in the country. Nicolosi, a Catholic who at one point did work for the Los Angeles Archdiocese, was a very early advocate of secular ex-gay therapy, writing his first book on the subject, Reparative Therapy of Male Homosexuality, a year before becoming one of three founders of NARTH (along with Benjamin Kaufman and the late Charles Socarides) in 1992.

In the years that followed, Nicolosi produced three similar titles: Healing Homosexuality: Case Stories of Reparative Therapy (1993), A Parent’s Guide to Preventing Homosexuality (2002, with his wife, Linda Ames Nicolosi), and Shame and Attachment Loss: The Practical Work of Reparative Therapy (2009). Nicolosi is still closely aligned with NARTH, having served as its president for several years, regularly attended its conferences, and currently serving on both the group’s board of directors and its overseeing board of trustees.

In addition, NARTH’s official headquarters was for years at Nicolosi’s Aquinas Clinic, which is located in Encino, Calif., and was started in 1980. (NARTH has since moved to Salt Lake City, Utah.) In 2012, Nicolosi was a plaintiff in a lawsuit filed against the state of California that challenged the constitutionality of a new law banning the use of conversion therapy with minors; the suit failed, meaning the law went into effect and Nicolosi had to stop treating minors for same-sex attraction at his clinic.

And I think a number of your articles have been published in the journal of Psychological Reports?

Yes.

… Is it affiliated with any kind of research institute or an academic institute?

Not that I know of.

Were you required to make payments per page in order to have any of these articles that appeared in Psychological Reports published?

No.

Are you aware that this is a practice that the journal utilizes [as reflected on its website, which says authors are charged $35 a page]?

I’m not aware of that practice at all.

Turn to page 6 of your bibliography [attached to Nicolosi’s expert report to the court], please. There’s an entry that lists author Rekers, G. I take it that’s George Rekers?

Yes.

And who is he?

Rekers did research on GID, gender identity disturbed children.

He formerly was affiliated with NARTH, correct?

Correct.

What was his position?

He was a NARTH member. I think he joined the board for a brief time, yes.

And he left NARTH at some point, correct?

That’s right.

What were the circumstances?

There was some kind of controversy about the fact that he was traveling with some person and there might have been some, I don’t know, compromise in their physical contact.

Well, in fact, he was photographed traveling with a gentleman he had located via rentboy.com [a male escort service], correct?

That’s not my understanding.

What is your understanding?

George Rekers said to me that he was walking on the beach where he lives and he ran into a man. And they were talking about travel and George said to this man that he has to do traveling but that he can’t lift his luggage. And this man said, “Well, I know of a young guy who would be willing to do that for you, to accompany you, if you could pay for his airfare.” And George met this young man through the man he met on the beach. This is what George Rekers said to me.

Do you believe him?

I know George and I believe him, yes.

Dr. Nicolosi, you told me you also served [the Archdiocese of Los Angeles] as a psychological consultant for cases of possession.

Yes.

What did that consist of?

Well, luckily for me it was only one case, and this woman was sent to my clinic because she saw demons. And it was kind of spooky. You know, I mean, you have someone sitting there and she says, “Oh, well, I see demons.” She’s like an old lady, you know, she had a little rouge, so she looked like Rosemary what was it?

Rosemary’s baby?

Something really creepy. So I said, “Do you see any around you now?” And she says, “No.” I was relieved. Anyway, I saw that as a psychological problem and it could be explained psychologically, so it didn’t give grounds for exorcism.

In any event, though, you believe there is at least a valid debate about the validity of your belief with respect to heterosexuality being the norm?

Absolutely.

And that view is not generally accepted?

I wouldn’t say that.

Why not?

… Again, we go back to the question … who are we asking the question to? … Because many psychologists will tell me, “I privately agree with you but I won’t say it publicly.”

Can you name one for me?

No, I wouldn’t name because I would disclose a number of rather prominent psychologists and psychiatrists. … [T]hat would be a violation of confidentiality.

Confidentiality because they were your patients at the time?

No, because they’re, they said it to me in private and I would not want to disclose their names.

What is the basis for your opinion that traditional psychology envisions humankind as part of a universal heterosexual natural order?

Well, again, human anatomy. The male and female fit together in a very compatible way.

So, if you could again tell me what pre-gender and post-gender mean?

Okay. So the gender identified phase is from 1½ to 3 years old, where the child, where the boy we’ll talk about the boy has disidentified with the mother and bonded with the father. If the trauma … happened before the gender identity phase, gender identity period, then that is the pre-gender type. That’s the more effeminate type of male. Because he never internalized masculinity, he maintained his identification with his mother. The post-gender type is the one who successfully went through the gender identity phase, disidentified with the mother, bonded with the father, but then afterwards experienced trauma regarding his masculinity. And that can happen in the form of a mean father, he was [nevertheless] good enough to make the transition, a cruel brother, a crazy making mother, sexual abuse, severe bullying for whatever reason.

Tell me what it looks like when a man is being assertive to a woman [as Nicolosi recommends that same- sex attracted men act as part of their therapy]?

… He’s on a date, my client is on a date, and he’s walking down the street, and he has in mind this nice little Italian restaurant that he’s going to take her to. And she says, “Oh, let’s go to that Chinese restaurant there.” If he stays in his assertion, he’s going to say, “You know what, I’m really looking forward to this Italian restaurant. I’d like to go there tonight.” But what he does instead was he acquiesces, he gives in. “Okay, we’ll go to where you want to go.” So, already he’s disconnected. He’s resenting her, he’s disconnected from her. She has no idea, she’s chatting away, but he’s already disconnected. And then he finds the waiter attractive and he doesn’t know why. That’s an example.

Do you recall agreeing to the statement [in a questionnaire on the Catholic Therapists website] that homosexual acts are acts of great depravity?

I don’t remember answering that question.

... Do you recall whether you agreed that, quote, “homosexual acts are intrinsically disordered”?

I don’t remember answering that, but I would say yes.

… Do you agree with the statement that “yoga is at odds with Christian faith and, therefore, is to be rejected”?

… No, I don’t.

… If in fact you previously did agree that yoga is at odds with Christian faith and, therefore, is to be rejected, are you telling me now that that would have been an error on your part to agree to that statement?

Correct.

The Washington Times also apparently talked to you in 1993. Do you recall that?

The story of my life you have there. ...

In any event, that story reported that you said 90% of your patients who stick with the program for about two years are able to abandon homosexuality permanently.

Oh, no. Terrible.

You don’t think you would have said that?

No, of course not.

… Do you remember going to a conference in London in 2009?

Yes.

Did you ever say at that conference that 75% of your clients were completely cured?

No. Of course not. Completely cured, no.

I have similar questions with respect to the use of nudity [in conversion therapy or life coaching]. … Are you aware of any such common observations [by therapists using nudity in group therapy] that have been shared with respect to the use of nudity in helping clients overcome SSA?

I can only respond from my own experience, where clients who have had those experiences [at weekend retreats] have had very positive experiences. Where for the first time they experience no attraction being around naked guys and they thought they would be aroused. And sometimes there’s an initial arousal, but then it goes down and they just feel really connected in a brotherly way with men that they would normally find attractive but there’s no attraction.

So one of the ways you’ve written fathers can affirm the masculinity of their sons is to take showers with them, correct?

That’s one possibility, yes. … Taking a shower with the boy so there can be this familiarity. Again, getting back to the nudity concept. The familiarity. I’m a boy, daddy is a boy, we have penises, mommy doesn’t. …

Can you give me as complete a list as you can …. [of] advice that you recall giving to fathers to help the fathers affirm the masculinity of sons?

Yeah. Make your son feel good about being a boy. “Being a boy is special. You, me and your brother, we’re lucky, we’re special, we’re boys. And mommy and the sisters, too bad for them, they’re not.” A little sexist, but it’s important. … [L]ife is a gendered life. Male/female design is fundamental to society, to culture. So that’s what we’re doing, we’re preparing the child for life.

You’ve written about the Sambia tribe of New Guinea, for example? … Tell me why you’ve written about them and their practices.

… [T]he Sambia tribe … [wi]ll take a bunch of boys from the tribe and with the older men go into the woods for three or four days and do all these kinds of activities. Activities that challenge the boy. Can you do this dangerous thing, can you do that dangerous thing? And when they survive it, it’s like a, it’s like a rite of passage. That happens to be male psychology.

One of the things that happens is that the older men use sharp sticks to poke the boys’ noses so they bleed profusely. Are you?

Well, I never read that. That’s an interesting.

And you know that there is sexual contact between the older men and the younger boys?

Yes, there is. Yes, there is sexual contact, there is. And by the way, that’s fine because it’s the bonding, it’s not the sexual behavior. That fits reparative therapy. It’s not the sexual activity that’s important, it’s the emotional bonding.

One of the things that people have written the older Sambians do with the youngers is have the youngers consume as much semen as they possibly can?

True, true, true.

... And the older men oftentimes engage in intercourse, anal intercourse, with the younger boys?

That, I did not I never heard of.

But you knew that they do ask the boys to perform fellatio on the olders?

Yes, they do.

JAMES E. PHELAN, MSW, PH.D.

James Phelan describes himself as a “consultant, social worker, researcher and author.” He worked as a conversion therapy counselor from 1994 to 2001 and then again during 2005. For several years, he was on the scientific advisory board of the National Association for Research & Therapy of Homosexuality, long the premier secular promoter of ex-gay therapy, and he still acts as a consultant on matters related to “unwanted same-sex attractions” (SSA).

A lifelong Baptist who claims that he once experienced SSA but does so no longer, Phelan is probably best known for his self-published 2014 book, Successful Outcomes of Sexual Orientation Change Efforts: An Annotated Bibliography, a compilation of proreparative therapy titles.

[Y]our book reports on the reported outcomes in the studies?

Yes. Yes.

It makes no assessment of the validity of those outcomes?

No.

You credit all anecdotal reports of success of conversion therapy from the literature you report you reviewed?

Yes.

You don’t credit anecdotal reports of harm of conversion therapy?

No.

Why not?

It’s that’s not what I was discussing. We are not looking at harm here, we are just looking at success.

… Because the focus of the book was on successful outcomes.

[Studies of homosexuality] are equally valid if they are from decades ago, from the ’50s and ’60s?

Sure. That was a great era.

Why was it a great era?

Lots of good things happened in those times. The civil rights movement happened in the ’60s. I was born… .

Would you be surprised if your literature review includes 35 sources that obviously favor aversion therapy [such as electroshock or noxious smelling chemicals administered in association with images of gay sex]? … You don’t criticize those therapies in your book?

I don’t criticize them. I just list them as, you know, they did report successful outcomes. … I don’t think anybody said that, scientifically, they don’t work. They do work. There is a place there was a place in an era for those therapies.

What empirical study would convince you that conversion therapy is harmful?

I haven’t found one that convinces me that it’s harmful.

What would be entailed in that study in order to convince you that it’s harmful?

That there is a majority of the people commit suicide.

Anything short ?

Or there is anything operational in terms of, like, their functioning, if they left therapy and they were, like, psychologically paralyzed, crippled, couldn’t function.

You report in your [2014] book on a drug called metrazol. That’s also been reported in your book as having some value for people who want to convert to heterosexual.

Okay.

Are you aware that the FDA revoked approval for that drug in 1982?

No.

Are you aware that that drug causes seizures?

No.

On pages 93 through 97 [of Phelan’s 2006 book, Practical Exercises for Men in Recovery of Same-Sex Attraction (SSA)], you offer a list of 326 activities clients can participate in when they feel homosexual urges. These activities include bowling, singing, watching the sky, reading maps, caring for house plants, going to a revival or a crusade, crying, seeing or smelling a flower, going to a drive-thru, bird watching, smiling at people, playing Frisbee, going to auctions. What do such activities have to do with a person wanting to become heterosexual?

These are common behavioral strategies for … someone who is saying, “Hey, listen, okay, I don’t I’m having a same-sex attraction, I don’t want to have it, and I want to get away from that thought.”… They do this all the time in cognitive behavioral restructuring.

In Exercise 27, you detail masturbation inventory.

… How are clients supposed to inventory their masturbation?

Just by using these 10 items. … [T]his is for clients who are disturbed by compulsive masturbation with SSA fantasies… .

In Exercise 56, that’s the exercise where clients write a goodbye letter to their same-sex attraction? … Can someone find greater freedom from homosexuality by writing a letter saying goodbye to it?

This is indicated for somebody that’s wanting to leave one or two or more elements of the same-sex attraction. … So it’s more of a closure exercise.

In that message [an Oct. 16, 2006, email from Phelan], you go on record to say that homosexuality is a mental disorder?

Yes.

And developmental arrest?

Uh-huh. Yes.

And it can be healed with therapy?

Yes. This was my discussion… .

This [a June 15, 2011, email] appears to be a message from you with respect to [ex-gay psychologist and then NARTH board member George] Rekers, who had recently been found as a person, I believe, associated with NARTH, who had been discovered with a rent boy [male prostitute] on vacation?

Hmm.

I would like to draw your attention to … where you say, furthermore, if and only if a therapist gives a patient a gun and tells him to shoot himself yes, literally and no one in their right mind does that?

Right.

Then they would be liable for their death.

Right. Nobody would do that.