1

IN THE CIRCUIT COURT OF THE ELEVENTH JUDICIAL CIRCUIT

IN AND FOR MIAMI-DADE COUNTY, FLORIDA


CATHERINA PARETO and KARLA ARGUELLO;
JUAN CARLOS RODRIGUEZ and DAVID PRICE;
VANESSA ALENIER and MELANIE ALENIER;
TODD DELMAY and JEFFREY DELMAY;
SUMMER GREENE and PAMELA FAERBER; DON
PRICE JOHNSTON and JORGE DIAZ; and
EQUALITY FLORIDA INSTITUTE, INC.,
Plaintiffs,
v.
HARVEY RUVIN, as Clerk of the Courts of Miami-
Dade County, Florida, in his official capacity,
Defendant.
___________________________________________/






CASE NO. 2014-1661-CA-01


DECLARATION OF JUDITH G. REISMAN, PH.D., IN SUPPORT OF AMICI CURIAE
FLORIDA FAMILY ACTION, INC., FLORIDA DEMOCRATIC LEAGUE, AND
PEOPLE UNITED TO LEAD THE STRUGGLE FOR EQUALITY


I, Dr. Judith G. Reisman, do hereby declare as follows:

1. I am over the age of 18 and am submitting this Declaration in support of the
memorandum of Amici Florida Family Action, Inc. (FFAI), Florida Democratic League, Inc.
(FDL), and People United to Lead the Struggle for Equality, Inc. (PULSE) in opposition to
Plaintiffs Motion for Summary Judgment. The statements in this Declaration are true and
correct, and if called upon to testify to them I would and could do so competently.
2. I am an expert in the fields of Science Fraud, Human Sexuality, Child Sexual
Abuse, and Mass Media Effects. I hold a Masters and a Doctorate in Communications, both from
Case Western Reserve University, Cleveland, Ohio. I am currently a Visiting Professor of Law at
Filing # 14930331 Electronically Filed 06/17/2014 10:45:29 PM
2

Liberty University School of Law and am the Director of the Center for Child Protection at
Liberty University School of Law.
3. I am a former consultant to four U.S. Department of Justice administrations, the
U.S. Department of Education, as well as the U.S. Department of Health and Human Services.
My expertise in Media Forensics, the scientific analysis of recorded media in the form of audio,
video, and still imagery as evidence in litigious proceedings.
1

4. I am a former consultant to the California Judicial Investigative Task Force and
the American Legislative Exchange Council (ALEC) on Sex Science Fraud, which published my
findings on Alfred Kinseys criminal and fraudulent scientific data and methods, and the
invalidity of subsequent academic works and policy decisions derived from him and from those
who followed and used his work as legitimate science.
5. I am the author of the 2014 report and medical-legal-historical overview of
modern sex laws entitled Kinsey: Sexual Psychopath - How Do We Undo the Legalized
Destruction That Stands on Kinseys Documented Criminal Frauds and Child Sex Atrocities?
6. The United States Department of Justice has published my report on the Role of
Pornography and Media Violence in Family Violence, Sexual Abuse and Exploitation, and
Juvenile Delinquency where I was tasked as Principal Investigator for Images on Children,
Crime and Violence, Grant No. 84-JNAXKOO7.
7. I have lectured on these topics at American universities such as Princeton, Notre
Dame, Georgetown, and Pepperdine; and internationally at the University of Jerusalem,
University of Haifa, Tel Aviv University, and the Medical School in Zagreb, Croatia.

1
National Center for Media Forensics, University of Colorado Denver, College of Arts and
Media, (May 8, 2014), available at http://www.ucdenver.edu/academics/colleges/CAM/Centers/
ncmf/Pages/ncmf.aspx.
3

Additionally, I have lectured at Johns Hopkins University School of Medicine, the Rutherford
Institute, the Council for National Policy, the Federal Bureau of Investigation at Quantico,
Virginia, and the United States Air Force Academy, among many other institutions.
8. I have been cited by or appeared on a lengthy list of media sources, including The
London Times, Time Magazine, The Los Angeles Times, Newsweek, The Washington Post,
Entertainment Tonight, Larry King Live, Donahue, The Today Show, Crossfire, The New York
Times, Ted Baehrs Movieguide, and many more.
9. I have earned honors including listings in Whos Who in Science and
Engineering, Whos Who of American Women, International Whos Who in Education,
The Worlds Whos Who of Women, Whos Who in Sexology, and others.
10. I have authored many books and articles and have been cited in numerous
scholarly works. Among my published works are Kinsey, Sex and Fraud (1990), Sexual
Sabotage (2010), Kinsey: Crime and Consequences (1998), (2000), and Soft Porn Plays
Hardball (1991), Stolen Honor, Stolen Innocence (2013).
11. I have been an expert witness in many court, military, and civil hearings
concerning child pornography, pornography, homosexuality, sexual harassment, and media
issues. My works have been referenced in a number of lower court decisions, and in the
following United States Supreme Court cases: Oakes v. Massachusetts, 491 U.S. 576 (1989) and
Osborne v. Ohio, 495 U.S. 103 (1990). My scholarly works have also been the impetus behind
the proposed child protection legislation HR 2749 (Washington D.C., 1995), The Child
Protection and Ethics in Education Act. My works have been referenced in the United States
District Court for the District of Columbia, as well as the D.C. Court of Appeals decision
upholding the prohibition on open homosexual sodomy under the U.S. Military Uniform Code of
4

Military Justice (UCMJ). In that decision my work, including my books, identifying Kinseys
sex crimes against boy babies and youths, and as inventor of the 10% homosexuality fraud and
my research as Principal Investigator of A content analysis of two decades of The Advocate and
The 1991 Gayellow Pages (July 5, 1972 - July 2, 1991), and Partner Solicitation Language as a
Reflection of Male Sexual Orientation, The Briefing Book, were used in successful litigation.
12. In addition to the numerous books and scholarly articles that I have written and
the extensive education I have received in the United States, I have also participated in numerous
international training seminars including in the Philippines, the Vatican, Austria, Ireland, Israel,
Switzerland, and Croatia.
13. In Croatia, as a direct result of my documentation of the fraudulent research of
Alfred Kinsey on May 22, 2013, Croatias Supreme Court, the Croatian Constitutional Court,
abolished the Health Education Curriculum, which took effect in February 2013, and ordered
that until the adoption of a new curriculum, Health Education be taught according to the
curriculum that had been in force before the start of the 2013 school year.
14. I have specialized and personal knowledge concerning the Plaintiffs claims in
this case concerning the inherent harms of homosexual behavior and the effects it has on
children.
RISKY BEHAVIOR DRIVES DISEASE NOT STIGMA
15. Proponents of same-sex marriage often assert that homosexual sexual behavior,
behavior which is bound up with homosexual sexual practices, is not the real cause of significant
health harms within the homosexual population, but rather that it is societal stigma which
results in the transmission of STDs and AIDS. Proponents similarly assert that it is due to this
stigma that homosexuals may be less likely to seek medical treatment.
5

16. If eliminating societal stigma - by overturning laws against men engaging in
anal intercourse (sodomy) with other men; participating in sexual acts leading to the completion
of anal intercourse (sodomy) with other men; and gross indecency between men - truly
reduced the spread of HIV/AIDS, then we should have seen a lowering of AIDS transmission
rates in cities such as San Francisco and in countries where there is less stigma, or on the
opposite extreme, where there is full societal acceptance of homosexual behavior.
17. New research shows that these theories about discussion of condoms, stigma,
discrimination, and health outcomes have gotten things backwards. A longitudinal study of gay
and bisexual men found that,
in contrast to the causal predictions made by most theories of health
behavior, attitudes and norms did not predict sexual risk behavior over time.
Rather, sexual risk behavior at [the first studied interval] was associated with
changes in norms and attitudes at [at the later studied interval]. These findings
are more consistent with a small, but growing body of investigations that suggest
instead that engaging in healthy behaviors can also influence attitudes and beliefs
about those behaviors.
2

18. Thus, reduced stigma, coupled with new safe-sex norms and attitudes did not
lead to reduced unprotected anal intercourse; rather, participants engagement in such HIV risk
behavior appeared to change how they thought and felt about the behavior and enhanced their
willingness to engage in it. These findings raise serious concerns about the impact of
encouraging or facilitating such behaviors by modifying marriage laws in Florida, in that a law
encouraging homosexual behaviors statistically increases HIV risk and negative health outcomes
and thus creates a danger both to the individuals engaging in these behaviors as well as to society
at large.

2
D.M. Huebner, et al., Sorting through Chickens and Eggs: A Longitudinal Examination
of the Associations between Attitudes, Norms, and Sexual Risk Behaviors, 30(1) Health
Psychology 110-18 (2011).
6

19. So called stigma and discrimination (directed against the practice of known,
proven, harmful and thus unhealthy behavior) are not universal explanations for greater
psychiatric and health risks among homosexuals. These psychiatric and health risks are largely
grounded in the biology of certain sexual practices. Health risks among gay men, such as HIV
transmission, are ultimately grounded in biological reality. A recent comprehensive study found
an overall 1.4% per-act probability of HIV transmission for anal intercourse (sodomy) and a
40.4% per-partner probability.
3
The other authors noted, The 1.4% per-act probability is
roughly 18-times greater than that which has been estimated for vaginal intercourse.
4

20. Proponents of same-sex marriage often attribute this probability to stigma and
claim that it has nothing to do with the biological reality of the harmful nature of acts of
homosexuality (both to the individual practitioners and the general public). This ignores reality
and fact. Recent United States Centers for Disease Control statistics indicate that the rate of new
HIV diagnoses in the United States among men who have sex with men is more than 44 times
that of other men.
5
Young boys and men identifying themselves as gay and bisexual ages 13-29
accounted for 27% of all new HIV infections in 2009 and were the only group for whom new
HIV infections increased between 2006 and 2009.
6

21. In 2010, the Centers for Disease Control reported that:
Gay, bisexual, and other men who have sex with men (MSM) represent
approximately 2% of the United States population, yet are the population most
severely affected by HIV. In 2010, young MSM (aged 13-24 years) accounted for
72% of new HIV infections among all persons aged 13 to 24, and 30% of new

3
C. Beyrer, et al., Global Epidemiology of HIV Infection in Men who have Sex with Men,
380 The Lancet 366-77 (July 28, 2012).
4
Id. at 5 (emphasis added).
5
Centers for Disease Control, HIV and AIDS among Gay and Bisexual Men. (2011),
available at http://www.cdc.gov/nchhstp/newsroom/docs/2012/CDC-MSM-0612-508.pdf.
6
J. Prejean, et al., Estimated HIV incidence in the United States, 2006-2009, 6 PLos ONE
1-13 (2011).
7

infections among all MSM. At the end of 2010, an estimated 489,121 (56%) persons
living with an HIV diagnosis in the United States were MSM or MSM-IDU [MSM-
injection drug use].
7


22. According to 2011 CDC statistics, we find that male-to-male sexual contact
(without any injection drug use) accounted for 90.8% of all HIV diagnoses for males aged 20-24,
(thus most were infected as boys), and 92.8% of all HIV diagnoses for males aged 13-19 (thus all
were infected as boys).
8
The notion of societal stigma being the real culprit behind the
disproportionately high rate of HIV infection of and spread amongst these MSB (male sex with
boys) and MSM is not borne out by reality or biology. Male/female copulation is remarkably
different than same-sex penetration and other behaviors encouraged or discouraged by marriage
laws. The risk of HIV transmission through unprotected anal sex is astronomically high.
23. Moreover, the FDA, even after looking at AIDS studies for roughly 40 years, has
never approved a condom for use in oral/anal or penile-rectal sex. the illusion of condom
protected penile-rectal acts is fully refuted by the fact that there is no condom approved by the
FDA. The Federal Drug Administration warns Americans, on its website, that anal sex is
simply too dangerous to practice.
9
An ad for a proposed penile-rectal condom states: The
standard rolled latex condoms have never been tested or FDA approved for anal use.
10


7
HIV Among Gay, Bisexual, and Other Men Who Have Sex With Men, Centers for Disease
Control and Prevention (Sep. 26 2013), available at
http://www.cdc.gov/hiv/risk/gender/msm/facts (emphasis added).
8
HIV Surveillance in Adolescents and Young Adults. Rep., Centers for Disease Control and
Prevention, National Center for HIV/AIDS, Viral Hepatitis, STD & TB Prevention 7 (2011),
available at http://www.cdc.gov/hiv/pdf/statistics_surveillance_Adolescents.pdf.
9
Judith G. Reisman, The Sexual Devolution: Condoms Never FDA-approved for Sodomy,
WorldNetDaily (Mar. 13, 2014), available at http://mobile.wnd.com/2014/03/condoms-never-
fda-approved-for-sodomy/.
10
Id.
8

24. In 2010, a study of HIV statistics in the International Journal of Epidemiology
(IME) found the respective risks of HIV transmission through different types of sexual activity.
11

That same year, Londons National AIDS Manual Publications, which exists to support the
fight AIDS with independent, accurate, accessible and comprehensive information,
12

highlighted the most glaring aspect of the IME study: the risk of HIV transmission from
receptive anal sex may be eighteen times greater than during vaginal intercourse.
13

25. A 2004 study showed that 88% of all anal cancer was directly tied to human
papillomavirus, a sexually transmitted disease.
14
That same study also reported:
men who were not exclusively heterosexual were at increased risk of anal cancer.
In this study, nearly half of the men with anal cancer (47.1%) were not
exclusively heterosexual, compared with 6.0% of male controls.
15


26. According to the United States National Cancer Institute, only 65.6% of people
diagnosed with anal cancer live five years or more after a diagnosis of the cancer.
16

27. Contrary to the notion that stigma is to blame for many harms that result from
homosexual conduct, from an overall perspective, the meta-analytic research, which summarizes
results over multiple studies, on the association between perceived discrimination and health

11
Baggaley, Rebecca F., Richard G. White, and Marie-Claude Boily, HIV Transmission
Risk through Anal Intercourse: Systematic Review, Meta-analysis and Implications for HIV
Prevention, 39 International Journal of Epidemiology 1048-63 (2010), available at
http://ije.oxfordjournals.org/content/39/4/1048.long.
12
What We Do, HIV & AIDS Information. National AIDS Manual Publications, available
at http://www.aidsmap.com/aboutus/What-we-do/page/1277746.
13
HIV Transmission Risk during Anal Sex 18 times Higher than during Vaginal Sex, HIV &
AIDS Information. National AIDS Manual Publications (June 28 2010), available at
http://www.aidsmap.com/HIV-transmission-risk-duringanal-sex-18-times-higher-than-during-
vaginal-sex/page/1446187.
14
Daling, Janet R., Ph.D., Human Papillomavirus, Smoking, and Sexual Practices in the
Etiology of Anal Cancer 101.2 (2004): p. 270. Wiley Online Library. Wiley Interscience,
available at http://onlinelibrary.wiley.com/doi/10.1002/cncr.20365/full.
15
Id. at 278.
16
SEER Stat Fact Sheets: Anal Cancer Surveillance, Epidemiology, and End Results
Program, available at http://seer.cancer.gov/statfacts/html/anus.html.
9

outcomes among MSM or MSB indicates that the strength of this relationship is small.
17

Furthermore, research has found no significant role for theoretically linked factors such as social
support and identification with ones group. For example, data suggest that the impact of
internalized homophobia for understanding risk behavior among MSM and MSB is now
negligible, and [t]he current utility of this construct for understanding sexual risk taking of
MSM and MSB is called into question.
18

SAME-SEX PARENTING IS NOT IDENTICAL TO TRADITIONAL CHILD
REARING AND NEGATIVELY IMPACTS CHILDREN

28. Studies also show that children raised by their wedded biological parents fare best
in
educational achievement: literacy and graduation rates, emotional health: rates of
anxiety, depression, substance abuse, and suicide, familial and sexual
development: strong sense of identity, timing of onset of puberty, rates of teen and
out-of-wedlock pregnancy, and rates of sexual abuse, and child and adult
behavior: rates of aggression, attention deficit disorder, delinquency, and
incarceration.
19

29. Rutgers University sociologist David Popenoe concluded: The two sexes are different to
the core, each is necessary -- culturally and biologically -- for the optimal development of a human
being.
20

30. The peer-reviewed Regnerus study, published in the Journal of Social Science
Research, also found that children raised by lesbian mothers (LM) and gay fathers (GF) fared far
worse than children raised by their biological intact families (IBF).
21


17
E.A. Pascoe & L.S. Richman, (2009). Perceived Discrimination and Health: A Meta-
analytic Review, 135 Psychological Bulletin 531-54 (2009).
18
M.E. Newcomb & B. Mustanski, Moderators of the Relationship Between Internalized
Homophobia and Risky Sexual Behavior in Men who have Sex with Men: A Meta-analysis, 40
Archives of Sexual Behavior 189 (2011).
19
Girgis What is Marriage? at 42 (emphasis in original).
20
David Popenoe, Life without Father: Compelling New Evidence that Fatherhood and
Marriage are Indispensable for the Good for Children and Society 146, 197 (1996) (emphasis
added).
10

31. The Regnerus study revealed:
Just under half of all IBFs reported being employed full-time at present, compared
with 26% of LMs. While only 8% of IBF respondents said they were currently
unemployed, 28% of LM respondents said the same. LMs were statistically less
likely than IBFs to have voted in the 2008 presidential election (41% vs. 57%),
and more than twice as likely -- 19% vs. 8% -- to report being currently (or within
the past year) in counseling or therapy for a problem connected with anxiety,
depression, relationships, etc., an outcome that was significantly different after
including control variables.
22


32. In addition, children raised by lesbians fare worse on educational attainment,
family-of-origin safety/security, negative impact of family-of-origin, a depression index,
physical health, and household incomes than to do respondents from still-intact biological
families.
23
They also think their current romantic relationships are in trouble more frequently.
24

33. Those raised by gay fathers also reported less education, worse scores on the family-of-
origin safety/security indexes, greater depression, and more likely to think that their current relationship is
in trouble.
25

34. In addition, those raised by lesbian mothers and gay fathers were more likely to smoke, to
have been arrested, and to have pled guilty to non-minor offenses.
26
Thus, children appear most apt to
succeed well as adults -- on multiple counts and across a variety of domains -- when they spend their
entire childhood with their married mother and father, and especially when the parents remain married to
the present day.
27


21
Mark Regnerus, How Different are the Adult Children of Parents Who have Same-sex
Relationships? Findings from the New Family Structures Study, 41 JOURNAL OF SOCIAL SCIENCE
RESEARCH 752, 761 (2012).
22
Id. at 761-62.
23
Id. at 763.
24
Id.
25
Id.
26
Id. at 764.
27
Id. at 766 (emphasis added).