New trial exhibits in Doe v. Ladapo: DOH worked with Genspect leaders Stella O’Malley and Joe Burgo in July 2022; Hilary Cass met SEGM’s Patrick Hunter to discuss Florida’s anti-trans report; Jamie Reed’s attorney Vernadette Broyles chose the lineup of detransitioners speaking at the Board of Medicine

Doe v. Ladapo is the case brought by transgender plaintiffs in Florida challenging SB 254, a law prohibiting gender-affirming medical treatment for minors and severely restricting access to care for trans adults since its enactment on May 17, 2023. In addition to outlawing treatment for trans minors, SB 254 requires adults to see a physician in-person before starting hormone therapy, and excludes nurse practitioners from prescribing any hormone therapy for the purposes of transitioning. In October, Doe was certified as a class action that includes all trans adults and minors seeking gender-affirming treatment in Florida (ECF 166). The trial itself is scheduled to begin on December 13 (ECF 165), and the plaintiffs and state defendants have now filed their exhibits in advance of the trial.

Exhibit and witness lists:

Trial briefs:

Dozens of these exhibits offer significant new details describing how Florida’s Executive Office of the Governor, Department of Health, Agency for Health Care Administration, Board of Medicine, and Board of Osteopathic Medicine worked with anti-trans groups throughout 2022 to achieve the predetermined outcome of restricting gender-affirming care. We now know that the state was covertly assisted in this effort by the leadership of the anti-trans group Genspect, Child & Parental Rights Campaign lawyer Vernadette Broyles, and Riittakerttu Kaltiala of Finland’s Tampere University youth gender clinic; Hilary Cass of NHS England’s Cass Review also privately expressed an interest in the sham report against gender-affirming care commissioned by Florida’s AHCA. Several individuals worked behind the scenes with Patrick Hunter, a leading member of the anti-trans Society for Evidence-Based Gender Medicine (SEGM). After being appointed by Governor Ron DeSantis to the Board of Medicine, Hunter arranged for extensive anti-trans testimony from SEGM associates to be submitted to the Boards of Medicine and Osteopathy. We’ve highlighted this and other notable new findings that expose the plot against gender-affirming care in Florida and beyond.

New document from the governor’s office: An Alliance Defending Freedom-branded booklet quoting several anti-trans religious groups and highlighting the shortage of physicians in Florida

Florida SB 254’s restrictions on nurse practitioners prescribing gender-affirming care are unprecedented. Nurse practitioners are practitioners and can prescribe medications in the same manner as physicians (MDs and DOs), including controlled substances like testosterone; this was the case in every state before the passage of SB 254 and is still the case in every state other than Florida. Despite the implied danger of these medications that supposedly warrants such regulation, the law irrationally allows nurse practitioners to prescribe estrogen, testosterone, and other hormonal medications for purposes other than gender transition. Because an estimated 80% of trans adults on gender-affirming hormone therapy in Florida received their prescription from a nurse practitioner rather than a doctor, SB 254’s restrictions have dramatically impacted the entire community’s access to care: the relatively few physicians providing gender-affirming care are now overwhelmed with patients no longer able to access care via their previous provider, with waiting lists reportedly growing to several months.

An undated booklet provided by the executive office of the governor, labeled “Alliance Defending Freedom Binder” in the exhibit list, suggests the state was aware of a shortage of physicians in Florida and may have recognized that nurse practitioners could be targeted in order to curtail access to care. Titled “Guaranteeing Florida Families Access to Ethical Health Care”, the document claims that unnamed national medical associations “support harmful, untested gender transition procedures for children, advocate for abortion up to the moment of birth, and promote assisted suicide being legalized across the country”:

Branded with the Alliance Defending Freedom logo on several pages, the booklet promotes the “Family MED Act” model legislation (variously “Family and Medical Ethics Defense Act” or “Medical Ethics & Diversity Act”), arguing that conscience protections for providers who refuse to participate in these procedures are necessary in order to protect the supply of physicians in Florida.

In order to entice more students to enter the medical profession, Florida needs to guarantee that they will not be forced to participate in abortion, gender transitions, assisted suicide, or other procedures that violate their moral or ethical beliefs.

Tab 8 of the booklet includes pages v-viii of the IHS Markit “Florida Statewide and Regional Physician Workforce Analysis: 2019 to 2035” report (December 2021), which note that the supply of physicians in Florida is lower than the demand, whereas the supply of APRNs is projected to exceed the demand. Page vi:

Estimated 2019 physician supply was approximately 3,835 FTEs [full-time equivalents] lower than estimated demand, suggesting that supply in Florida was adequate to meet 93% of estimated demand relative to national averages. Supply adequacy varies by physician specialty. If current trends continue, projected 2035 supply and demand suggest a shortfall of about 17,924 FTE physicians (Exhibit ES-1) with supply sufficient to meet 77% of projected demand.

Page vii-viii:

Estimated 2019 supply of APRNs in Florida was 29,311 FTEs. This number is projected to nearly double over the projection period, reaching 57,780 FTEs (28,469 FTE or 97% growth) by 2035. While the 31% 2019-2035 projected APRN demand growth is well above the 21% rate of projected population growth, it is significantly below the projected supply growth. In 2019 the supply of APRNs was an estimated 6,446 FTEs below the level that would be expected based on national average levels of care use and delivery. Due to the rapid growth in APRN supply, by 2035 there will be an estimated 10,765 FTEs beyond what is needed to maintain current national average physician-to-APRN staffing ratios.

Tab 2 of the ADF booklet includes a review by James Cantor of 11 articles purportedly about “desistance” in trans youth – but most of these studies were not about gender dysphoria. Notably, Tab 4 features endorsements of the model conscience legislation from several anti-LGBT religious organizations, including the American College of Pediatricians, Christian Medical & Dental Associations, and Catholic Medical Association.

ACPEDS, CMDA and CMA have declared that for religious reasons, their membership absolutely opposes any social or medical gender affirmation of trans people; several members of these groups, including Michelle Cretella, Quentin Van Meter, Patrick Lappert, G. Kevin Donovan, Andre Van Mol, and Patrick Hunter, extensively assisted Florida agencies in drafting and promoting the trans youth care ban.

Patrick Hunter, an SEGM leader with a religious commitment against gender-affirming care, collected anti-trans testimony from other SEGM advisors and associates after being appointed to the Florida Board of Medicine

The plaintiffs’ trial brief and associated filings indicate that Sven Román, an advisor to the anti-trans group SEGM, has now been retained by Florida as an expert witness (Sven Román CV; SEGM About Us page), although any expert declarations by Román have not been publicly filed at this time. Román, an opponent of Covid-19 lockdown restrictions and vaccination requirements, has baselessly implied that Covid vaccines cause rapidly-growing ‘turbo cancers’ (this claim is not supported by evidence, and is not consistent with what is known about the causes and progression of cancer); he previously submitted an expert declaration in Tennessee’s trans youth care ban case L.W. v. Skrmetti. The plaintiffs’ brief includes an excerpt from an unfiled deposition of Román where he was asked about Florida Board of Medicine member Patrick Hunter’s role within SEGM:

Dr. Hunter is also a leading member of the organization Society for Evidence Based Medicine (SEGM), which opposes standard medical care for transgender people. (Trial Ex. 99; Trial Ex. 100; Depo Tr. of Dr. Roman, at 68:21-69:14) (“Q: What is Dr. Hunter’s role in SEGM? A: I think that he is one of the leading persons in SEGM.”).

Patrick Hunter at CMA

Although SEGM claims to promote “evidence-based medicine”, Patrick Hunter is also a member of the Catholic Medical Association, a far-right advocacy group that is absolutely opposed to transgender identity and gender-affirming care on a religious basis. CMA’s resolutions (ECF 184-8) state that “the Catholic Medical Association and its members reject all policies that condition all persons with gender dysphoria to accept as normal a life of chemical and surgical impersonation of the opposite sex”. Further, the CMA’s executive director declared in November 2021 in American College of Pediatricians v. Becerra that its members will not state in their professional opinion that gender-affirming care is safe, beneficial, or the standard of care:

69. The gender identity mandate requires CMA members to engage in various practices to which our members objection on medical and ethical grounds, including the following: … (m) Saying in their professional opinions that these gender intervention procedures are the standard of care, are safe, are beneficial, are not experimental, or should otherwise be recommended; … 70. The objectionable practices violate the teachings of the Church, and our organization’s members cannot carry them out in good conscience.

(A near-identical declaration on behalf of the American College of Pediatricians states that members of ACPEDS hold the same absolute commitment against offering professional opinions favorable to gender-affirming care.) A July 2019 article from the Diocese of Orlando indicates that Hunter is a member of the Orlando CMA, and Hunter is listed as a faculty advisor for the CMA student guild at UCF College of Medicine. Most recently, Hunter spoke at CMA’s 92^nd Annual Educational Conference in September 2023 (ECF 184-9), concluding “that light is the truth, that light is the word, and the word was made flesh”, a reference to the belief that the Christian deity was once incarnated as a human being.

Hunter holds a master’s degree in bioethics (ECF 184-9) through a joint program on “Catholic bioethical analysis in health care” with the Catholic-run University of Mary and the anti-LGBT National Catholic Bioethics Center; the NCBC, an “allied organization” of CMA, is also extensively opposed to any form of transitioning at any age. Another SEGM associate, Paul Hruz (an expert witness in Dekker v. Weida), serves as a fellow of the NCBC, and stated in the NCBC’s Transgender Issues in Catholic Health Care that even the idea of medical transition treatment should be excluded from consideration because of Catholic religious teachings (Hruz, 2021):

Pope St. John Paul Il’s teaching on the Theology of the Body, with its understanding of human dignity and bodily integrity, can inform the ethical boundaries that must be established when working with people who experience gender dysphoria. Continued efforts to provide the best possible care must remain centered on the ultimate good of affected persons as dignified members of the entire human family. Hypotheses based on asserting that experimental intervention will realign an individual’s body with his or her so-called true self as male or female according to the individual’s mind distort the objective biological understanding of sex and are therefore untenable. If viewed in light of an intrinsic body-soul unity, the hypothesis essentially asserts that separating what cannot be separated is beneficial.

All of this is necessary to understand the unreconciled conflict held by Patrick Hunter (and other CMA/ACPEDS members and NCBC alumni) as they engaged with the process of developing and defending Florida’s trans care bans: no amount of evidence that gender-affirming care is beneficial would overcome their preexisting religious commitment to say that it isn’t. As such, their demands for more high-quality evidence are utterly disingenuous and should be viewed as seeking pretext and confirmation for a decision they had already made.

Recruiting associates of ACPEDS and SEGM

Exhibits filed in the case indicate that Patrick Hunter played an extensive and ongoing role in gathering testimony against gender-affirming care both before and after he was appointed to the Board of Medicine by Ron DeSantis on June 17, 2022. Three days before Hunter was appointed, Florida’s anti-trans expert Andre Van Mol emailed AHCA’s Jason Weida to ask about “this Patrick Hunter gentleman who contacted me that he is organizing testimony” (“Fwd: Florida item”). As a member of ACPEDS, Van Mol would hold the same commitment against offering any favorable professional opinion on gender-affirming care.

In September 2022, Hunter went on to email Paul Vazquez, executive director of the Board of Medicine, recommending that Michael Biggs and Kristopher Kaliebe offer anti-trans testimony before the Board (“Michael Biggs CV”; “Florida Psychiatrist”). Biggs is an advisor to SEGM, while Kaliebe – a state expert in Dekker v. Weida – recently presented at SEGM’s October 2023 conference. On October 22, 2022, Hunter emailed Vazquez a copy of a paper by SEGM members Stephen Levine, Evgenia “Zhenya” Abbruzzese and Julia Mason, stating: “please add to public record”.

Behind the scenes with Riittakerttu Kaltiala

Additional email exhibits provide further background to the long-running collaboration between Hunter and Finnish child psychiatrist Riittakerttu Kaltiala, leader of a controversial youth gender clinic at Tampere University. Right-wing sources have increasingly cited Kaltiala and her role in Finland’s restrictions on youth gender care as a model for healthcare bans in the US, even as Finland’s policies are guidelines rather than mandates or statutory bans. Despite the absence of any ban, Kaltiala has reportedly contacted Finnish child services when a family legally sought treatment for their trans child via a private provider outside of her clinic. Hunter declared in May 2022 in Brandt v. Rutledge that he had lectured with Kaltiala in Finland, and both Hunter and Kaltiala attended SEGM’s April 25, 2022 meeting with the US HHS Office for Civil Rights (ECF 184-13); Kaltiala was also a presenter at SEGM’s October 2023 conference.

In a September 16, 2022 email to Paul Vazquez and Board member Dr. David Diamond, Hunter stated that Kaltiala “wants to submit something to the Florida Board of Medicine” without it looking like she wants to submit something (“Riittakerttu Kaltiala”):

I met with Ritta Kaltiala this morning via Zoom. I have known her for over year now, and we meet regularly. She and I conducted an ethics conference on this issue at Nemours in December 2021. She is a child and adolescent psychiatrist, and was instrumental in standing up the Finnish youth transition clinics, and subsequently instrumental is severely restricting these in 2020, due to the harms seen. She is very well published in this area. Her bio and CV are attached.

She wants to submit something to the Florida Board of Medicine, but would like it to be formally requested. This is due to cultural and political issues in her country surrounding this issue.

Is that something I can request as a board member, or would that be better coming from you or Dr. Diamond?

Hunter and Kaltiala at Nemours

Hunter’s mention of Nemours may refer to nine pediatric endocrinologists and pediatric endocrine nurse practitioners at Nemours Jacksonville who submitted a letter to the Board against gender-affirming care on September 23, 2022 (ECF 180-7). Hunter had earlier told Vazquez on September 12 (“Re: Workshop”):

The only ones I know who provide care for gender dysphoria youth in Florida are affirmative and transition kids. I know of two in Jacksonville who used to do puberty blockers, did not like what they saw, want to stop, but are getting pressure to continue from their employer. That group may be submitting a letter of concern. But people fear they will be ostracized and lose jobs for speaking out.

The “two in Jacksonville” are likely Matthew Benson and Monica Mortensen, coauthors of the September 23 letter who were later appointed by DeSantis to the Board of Medicine and Board of Osteopathic Medicine in December 2022. In an excerpt from an unfiled deposition, Mortensen admits that Benson is not an expert in gender dysphoria and does not provide treatment for gender dysphoria (Plaintiffs’ trial brief):

Dr. Benson, who works with Dr. Mortensen at Nemours, and with whom he co-authored a letter in support of the Boards’ bans on treatment of gender dysphoria in minors, is not an expert on gender dysphoria. (See Mortensen Deposition Tr. at 130:22-25 (“Q: You mentioned earlier to the best of your knowledge, Dr. Benson has not provided treatment for gender dysphoria, correct? A: Correct.”); 102:10-12 (“Q: Does Dr. Benson provide treatment for gender dysphoria? A: Not to my knowledge.”); see also 123:8-10. … None of the signatories to the Open Letter, including Defendants Dr. Mortensen and Dr. Benson, had any experience providing the gender transition medical care at issue in their letter.

Hunter meets with Hilary Cass

Further correspondence in July and September 2022 shows that Riittakerttu Kaltiala introduced Hunter to Hilary Cass, leader of NHS England’s Cass Review of youth gender services (“Re: Connecting Patrick Hunter – Hilary Cass”):

Dr. Cass,

I am interested in learning more about your work in this area. I am a general pediatrician in Florida. I also have a background in bioethics. I have been appointed to the Florida Board of Medicine. The board licenses physicians and can regulate to practice of medicine. The board is considering adopting rules regarding youth gender transition.

I have been studying gender dysphoria and gender medicine since about 2015, when I first started seeing patients in my clinic. My focus has been on the history and scientific literature, but in the last year I have also forged relationships with 20 plus patients who have detransitioned.

I look forward to talking to you. Please let me know a time that works well for you.

A followup email from Hunter indicates that he met with Cass on September 22, 2022 (ECF 184-1). Even as Paul Vazquez wanted to invite Cass to the Board of Medicine hearing as a subject matter expert, Hunter felt that would put her “in a difficult position”:

Dear Dr. Cass,

Thank you for meeting today and please thank your staff for their time. Below is the link to the Florida Department of Health. The Agency for Health Care Administration (AHCA) is the agency within the department of health that oversees Medicaid. Attachment C is the evidence review from McMaster University. I have attached the pdf of the McMaster report also.

I asked the board of medicine’s executive director, Mr. Paul Vazquez, if an email sent to me, as a board member, with information from your review attached would be proper protocol. He said it would be. He wants to invite you to present virtually to the board. I think that will put you in a difficult position. If he does send you an invite, please do what is most appropriate for you.

Again, thank you for your time, and I’d like to stay in touch.

Patrick

https://ahca.myflorida.com/letkidsbekids/

In an October 4, 2022 email to Vazquez, Hunter added that Cass took an interest in Florida’s anti-trans expert report Attachment C by McMaster University’s Romina Brignardello-Petersen and Wojtek Wiercioch (“Fwd: Connecting Patrick Hunter – Hilary Cass”):

Paul,

See attached information sent to me from the Cass Review. I forgot to mention that they were very interested in the Florida evidence review, especially the report from McMaster University. She recognized the work done at that institution under the leadership of Gordon Guyatt. At Dr. Cass’s request, I sent them a copy of the Florida evidence review.

Hunter and Brignardello-Petersen previously appeared together in a prospectively registered systematic review of social transition dated May 5, 2022 (CRD42022308739), conducted as “part of a large research project funded through a research agreement between the Society for Evidence-based Gender Medicine (SEGM), the sponsor, and McMaster University”. Despite the oft-cited eminence of McMaster University as the “birthplace of evidence-based medicine”, McMaster’s Romina Brignardello-Petersen was producing a report to justify a process that was already laid out to end in “Care Effectively Banned”. AHCA’s chief litigation counsel Andrew Sheeran suggested she model her report after an anti-trans expert declaration on behalf of an anti-gay conversion therapist in ADF’s case Tingley v. Ferguson – a report produced to advocate for one side of a court case, not an apolitical open-ended assessment of evidence conducted by a state health agency on behalf of the public.

Why were nine detransitioners first in line to speak at the October 28, 2022 Boards of Medicine hearing? Vernadette Broyles

The October 28, 2022 joint hearing of the Board of Medicine and Board of Osteopathic Medicine featured a public comment period that suspiciously began with testimony from nine anti-trans detransitioners in a row. Following the hearing, BOM member Zachariah P. Zachariah told the press that he had called these names in an order given by the Department of Health. The newly filed exhibits show that FLDOH was provided with a list of detransitioners and anti-trans parents by attorney Vernadette Broyles, president of the anti-trans Child & Parental Rights Campaign.

Broyles is a prolific anti-trans activist and religious zealot who believes trans youth are the property of her deity, as she explained in a January 2020 email to a private working group of anti-trans legislators and advocacy groups (Fred Deutsch emails):

Know that many have prayed and are praying for you this day. Do not back down, nor should you be afraid. Know that the Lord is with you. The children of South Dakota belong to him. He is jealous over them. Let his jealousies be spoken forth in the House of Representatives of South Dakota today so that his children would be made safe. Know you are HIS representative today. Do not be afraid. Stand firm in what is right.

Vernadette

Sent from my iPhone

At a January 2020 presentation for the right-wing Eagle Forum, Broyles declared that gender-affirming policies are “an existential threat to our culture” (17:36), and described gender-affirming care as “horrid Nuremberg-like experiments” (19:15). Notably, Broyles endorsed the belief that “everything” is “underneath our savior’s feet”, “so that we can turn around and enforce that on the earth” (21:44):

We as adults, who believe in something larger than ourselves, we need to overcome our identity crisis in order to help them overcome theirs. Why? Because who do we have living in us? We have the same spirit that raised Christ from the dead. And if he who raised Christ from the dead is in us, he gives life to our mortal body. But he also gives us courage and strength. And you know what? He put everything underneath our savior’s feet. Why? For us, so that we can turn around and enforce that on the earth. We have got to overcome our identity crisis and who we are, so that we can step out, put ourselves on the line, and help our children overcome the identity crisis the other side wants them to have.

Elsewhere, Broyles and her law firm represented anti-trans parent January Littlejohn in the case that led to Florida’s “Don’t Say Gay” law; the CPRC even helped draft the language of the bill. In 2023, Broyles went on to represent Missouri “whistleblower” Jamie Reed, whose unsubstantiated claims against the St. Louis Children’s Hospital gender clinic have been widely refuted by trans youth and their parents. Much like Patrick Hunter, Broyles appears to believe any evidence in favor of gender-affirming care can be dismissed a priori, groundlessly asserting that any reports of positive outcomes are due to a “honeymoon phase”; because Broyles does not define the length of such a “phase”, her claim is unfalsifiable.

Most recently, Broyles spoke at Genspect’s November 2023 conference in Denver, where she called training on gender identity a “cancer” within the judicial system and described detransitioners and anti-trans parents as essential to passing anti-trans policy (see Appendix B, “The Bigger Picture Conference Denver Private Live Stream”). The trial exhibits in Doe show how Broyles played a central role in organizing detransitioners to testify in favor of the trans youth care bans, with the willing cooperation of Board of Osteopathic Medicine director Danielle Terrell. On October 25, 2022, Broyles’ coworker emailed Terrell a list of nine detransitioner “testifiers for Friday”, along with anti-trans expert witness Michael Laidlaw (ECF 179-11):

Danielle,

I work with Vernadette Broyles and she asked me to send you the list of testifiers for Friday:

Expert
Dr. Laidlaw
Detransitioner
Zoe Hawes
Rachel Foster
Chloe Cole
Camille Kiefel
ShapeShifter
Billy Burleigh
Cat Cattinson
Helena Kerschner
Ted Halley
Parent
Yaacov Sheinfeld

The next day, Terrell replied to Broyles to confirm that these individuals would appear first during the public comment period of the October 28 hearing (October 26, 11:38 AM email):

Good morning,

Thank you for taking time to speak with me yesterday. I have received the list below. The Florida Boards of Medicine and Osteopathic Medicine Joint Rules/Legislative Committee Workshop will be conducted on October 28, 2022, from 8:00 a.m. EDT to 1:00 p.m. EDT. Within that timeframe, we must ensure that subject matter expert presentations and public comments are received and rule development and discussion is conducted. As discussed, they will be first to speak during the public comments portion of the workshop.

Terrell then immediately emailed Paul Vazquez and FLDOH employee Bettye Cherise Strickland, instructing them to fill out public comment cards on behalf of the detransitioners and anti-trans parent Yaacov Sheinfeld:

Please see the list of people below that will be the first to make public comment. We need to ensure that cards are filled out for all detransitioners and the parent.

Strickland confirmed the cards would be prepared:

Received. We will pre-fill out speaker cards for the detransitioners and parent on the list and have them waiting.

Vernadette Broyles and her coworker emailed Terrell twice to add more anti-trans witnesses (October 27, 10:16 AM email), growing to 21 names in all, and even requested that they appear in a particular order (October 27, 4:44 PM email). Terrell replied to confirm that the Boards would do their best to call everyone on Broyles’ wishlist:

Thank you for providing the additional information. During the public comment period allocated, the Board will include as many of the individuals identified that time permits.

At the October 28 hearing, Broyles’ witnesses variously testified that “I think it’s against God” (Yaacov Sheinfeld), discussed detransitioning after “a life-changing encounter with Jesus” (Zoe Hawes), and blamed “an echo chamber of far-left ideology” and “an anti-science movement” for their decision to transition (Chloe Cole).

A July 2022 roundtable between state agencies and Genspect leaders Stella O’Malley and Joe Burgo

Genspect is an increasingly influential anti-trans group founded by Irish psychotherapist Stella O’Malley, who also serves as an advisor to SEGM and as vice president of Lisa Littman’s Institute for Comprehensive Gender Dysphoria Research (ICGDR). SEGM and Genspect fill complementary roles within the ecosystem of anti-trans discourse: while SEGM is primarily a think tank and a source of expert witnesses using common industry tactics to discredit the science on gender-affirming medical care (Goldberg & Vandenberg, 2021), Genspect offers an alternative approach of trans-invalidating counseling practices and public policy, promoting “gender exploratory” non-affirming therapies and becoming increasingly enmeshed with the anti-trans “parents’ rights” movement.

Genspect has previously recommended that schools “ban all binding and tucking”, and currently offers templates for parent “support group” meetings using language from religious 12-step programs; founder O’Malley has claimed that gender dysphoria in adolescent trans girls is “porn induced” and “a compulsion”, while their vice-director Joe Burgo has an adult trans son who refuses to have anything to do with him.

“Part of the problem has been that WPATH has been advocating for the affirmative care model, which puts people like Stella and me out of business, basically.” –Joe Burgo (Gender: A Wider Lens episode 108)

Other Genspect achievements include:

Sending thousands of dollars to Oregon therapist Stephanie Winn to subsidize therapy for detransitioners; Winn previously suggested that anti-trans parents force their children to undergo unnecessary acupuncture to discourage them from transitioning, an approach reminiscent of aversion techniques used in conversion practices.
Inviting religious ideologue Paul Hruz to speak at their 2022 symposium.
Publishing a “Gender Framework” (coauthored by O’Malley) as an alternative to WPATH standards of care, containing a model “Conversion Therapy Prohibition” (section 8.4) that would appear to penalize providers who offer gender-affirming therapy rather than Genspect’s non-affirming “exploratory therapy” (“any mental health provider who approves medical gender transition of any person without a comprehensive assessment and without engaging in a therapeutic process for the purpose of making differential diagnosis shall be liable”).

Most recently, O’Malley declared on behalf of Genspect that “We too are wary of autogynephiles”, referring to a widely challenged hypothesis of “autogynephilia” which asserts that queer trans women’s gender identities develop as an outgrowth of a sexual fetish (heterosexual trans women are alleged to be trans for other sexual reasons). O’Malley goes on to describe this as “dangerous” and a “type[] of sexual deviancy”, claiming that “this makes them more likely to commit sexual offences”:

There are many types of sexual deviancy – fetishism, voyeurism, exhibitionism, paedophilia, sadism, masochism, frotteurism, and autogynephilia and the more the public knows, the better society will be able to tackle it. Although autogynephilia is not very well-known, it appears to be increasingly prevalent. And it is dangerous. Just last week the clinical psychologist and sexologist, James Cantor, testified under oath at the Amy Hamm trial that autogynephilic men are more likely to have other “paraphilic sexual patterns, such as sadism” and this makes them more likely to commit sexual offences. Autogynephiles tend to seek validation from the public as part of their sexual gratification and this is one of the reasons why many gender critical people are rightfully leery of autogynephiles appearing anywhere.

This argument uses raw sexual fear of the “other” to hopscotch past reason, compelling cisgender audiences to consider that if we aren’t outwardly pretending to be cis men, then this is tantamount to forcing a sexual act on a non-consenting public – deftly skirting the fact that no one else needs to “consent” to us leaving the house while wearing our clothes. Because more than 60% of trans women are lesbian, bi, pan, or queer (James et al., 2016; National LGBT Survey, 2018; Reisner et al., 2023), Genspect has baselessly slurred a majority of us as a sexual threat, encouraging our communities to regard any trans woman as most likely an aspiring sex offender.

On the morning before the July 8, 2022 hearing on AHCA’s proposed coverage exclusion, Genspect leaders Stella O’Malley and Joe Burgo met with the Florida Department of Health for a previously unknown conference call on gender dysphoria “talking points” (ECF 180-4), accompanied by Matthew Benson and several detransitioners and anti-trans parents who would later speak at the Boards of Medicine (Sophia Galvin, Chloe Cole, Amy Atterberry, Wendell Perez, Clifton Francis “Billy” Burleigh, Erin Brewer, Abel Garcia, “Richie”, “Alex”, “Forrest”, “Greta”, and “Tish”). In the meeting outline, FLDOH made clear that the purpose of the call was to focus on the experiences of anti-trans detransitioners, a minority representing approximately 1% of those who transition:

This isn’t just a meeting. This is a fact-finding mission and, most importantly, a conversation.

I want to hear from you, directly.

These stories matter, and we are here to listen.

At this point, FLDOH had already decided that they would campaign for “protection” of that 1%, even offering that “we are here for them if they need anything”:

Thank the participants for joining and let them know that we are here for them if they need anything.

We hope this experience will allow us to provide the protection that they should have had before their trauma.

Let them know that their stories will be provided to the Board of Medicine and that we will follow up to make sure their stories are told.

“Gender-exploratory therapy” was emphasized throughout the meeting outline, with O’Malley and Burgo advertised as members of GETA and invited to comment on “alternatives to ‘gender-affirming care’” and “how gender exploratory therapy differs from ‘gender-affirming care’”:

Stella O’Malley – ask her to explain the rise in transgender identifying youth, how activists weaponize suicide, the ideas behind the “gender-affirming care” model, and alternatives to “gender-affirming care.”

[…]

Joe Burgo – ask about treatment models in the clinical setting and how gender exploratory therapy differs from “gender-affirming care.”

Suicide is not a “weapon” of activists, it is a stark reality faced by our community; Genspect enabled Florida’s state health agencies in their choice to disregard the harm to 99% of us while listening to the most extreme fringe of the 1%. In public, the state acted as though trans people need to be protected from our own healthcare and medical decisions – while working behind the scenes with those who believe the public must be protected from us. ■

Glossary of anti-trans groups

ACPEDS – American College of Pediatricians
ADF – Alliance Defending Freedom
CMA – Catholic Medical Association
CMDA – Christian Medical & Dental Associations
CPRC – Child & Parental Rights Campaign
GETA – Gender Exploratory Therapy Association
NCBC – National Catholic Bioethics Center
SEGM – Society for Evidence-Based Gender Medicine

Key individuals and affiliations

Matthew Benson (Florida Board of Medicine; Nemours Jacksonville pediatric endocrinology)
Michael Biggs (advisor to SEGM; expert witness in Dekker v. Weida)
Vernadette Broyles (CPRC; represents Jamie Reed; Fred Deutsch working group emails)
Joe Burgo (vice-director of Genspect; therapist with GETA; coauthor of Genspect Gender Framework)
Hilary Cass (NHS England; author of Cass Review of England’s youth gender services)
Patrick Hunter (Florida Board of Medicine; leading member of SEGM; Catholic Medical Association; recipient of National Catholic Bioethics Center bioethics degree)
Kristopher Kaliebe (SEGM presenter; expert witness in Dekker v. Weida)
Riittakerttu Kaltiala (chief psychiatrist of Tampere University Hospital youth gender clinic; presenter at SEGM October 2023 conference)
Michael Laidlaw (former ACPEDS member; Pediatric and Adolescent Gender Dysphoria Working Group; likely early member of SEGM; Fred Deutsch working group emails; expert witness in Dekker v. Weida)
Stephen Levine (advisor to SEGM; coauthor of GETA Clinical Guide; coauthor of Genspect Gender Framework; expert witness in Dekker v. Weida)
Monica Mortensen (Florida Board of Osteopathic Medicine; Nemours Jacksonville pediatric endocrinology
Stella O’Malley (founder of Genspect; advisor to SEGM; coauthor of GETA Clinical Guide; coauthor of Genspect Gender Framework)
Sven Román (advisor to SEGM)

Selected documents

Internal documents from Executive Office of the Governor and Department of Health

“Guaranteeing Florida Families Access to Ethical Health Care” (undated)
“Gender Affirming Guidance Event – TBD” (undated)
“Gender Dysphoria/Transgender Health Care Legislation” (undated)
- Expert declaration of Stephen Levine in Tingley v. Ferguson (ECF 187-2, 187-3, 187-4)
“Recent Media Inquiries & Response / Week of May 13, 2022”, 2022-05-13
“Gender Dysphoria Roundtable – Talking Points”, 2022-07-08
“Safeguarding Kids from Gender Surgeries & Drugs” (September or October 2022)

CVs and bibliographies of state experts

Plaintiffs’ expert reports

Transcripts of public hearings

2022-08-05 Board of Medicine meeting (ECF 178-1, 180-1)
2022-10-28 Boards of Medicine and Osteopathy meeting
2022-11-04 Boards of Medicine and Osteopathy meeting
2023-02-10 Boards of Medicine and Osteopathy rule hearing (ECF 178-4, 180-2)
2023-02-21 Florida House of Representatives Health and Human Services Committee hearing
2023-06-23 Boards of Medicine and Osteopathy meeting
2023-06-30 Boards of Medicine and Osteopathy meeting
2023-08-03 Boards of Medicine and Osteopathy meeting

Complaints by Gender Analysis to the Florida Boards of Medicine and Osteopathy

Background on SEGM, Genspect and “gender exploratory therapy”

Anti-LGBT positions of the Catholic Medical Association and related groups

Role of the American College of Pediatricians hate group in Florida

Appendix A: 2022 timeline

April

April 8: Internal document “Florida Department of Health Updates” from Katie Strickland, deputy chief of staff for Ron DeSantis.
April 20: The Florida Department of Health issues the press release “Treatment of Gender Dysphoria for Children and Adolescents”.
April 25: Patrick Hunter attends SEGM’s meeting with the US HHS Office for Civil Rights, listing his affiliation as “Society for Evidence-Based Gender Medicine”; Riittakerttu Kaltiala is also in attendance.

May

May 13: Internal document “Recent Media Inquiries & Response / Week of May 13, 2022” from Executive Office of the Governor.

Finally, I want to make sure you’ve seen the Florida Department of Health’s recently released official guidance on the treatment of gender dysphoria in children and adolescents. I am including this because it cites copious research indicating that the push to “affirm” minors who think they might be trans or nonbinary can do more harm than good.

The idea that schools should indoctrinate kids with gender theory and “affirm” that a minor must be trans because he or she might feel dysphoric, or might not conform to stereotypes about his or her sex, is simply not grounded in the best available evidence. And the argument that government schools have the right to overrule parents in this matter is fundamentally wrong.

June

June 2: Anti-trans GAPMS determination is published by AHCA; FLDOH letter announces release of GAPMS report and encourages Board of Medicine to establish a standard of care.
June 14: Email “Fwd: Florida item” at 10:33 AM from Andre Van Mol to AHCA’s Jason Weida.

Hi, Jason.

A friend of mine, a pediatrician in Florida with good knowledge on the subject (see his message below), wishes to testify on behalf of the policy. Do I put him in contact with you, or this Patrick Hunter gentleman who contacted me that he is organizing testimony?

June 17: Patrick Hunter is appointed by Governor Ron DeSantis to the Florida Board of Medicine.

July

July 8: “Gender Dysphoria Roundtable – Talking Points” meeting from 9:00 – 11:00 AM.
July 8: AHCA hearing on gender-affirming care coverage exclusion Rule 59G-1.050(7).
July 28: FLDOH files petition to initiate rulemaking with the Florida Board of Medicine.
July 29: Email at 4:01 AM from Riittakerttu Kaltiala to Patrick Hunter.

Dear Patrick

I am connecting you with Dr Hilary Cass from the Cass review. I shortly mentioned her your position and needs in learning more about what is going on in gender identity issues concerning children and adolescents in selected European countries. She’ll be much away August but is asking the project office to find a date, so a copy to Cass Review email.

July 29: Email “Re: Connecting Patrick Hunter – Hilary Cass” from Patrick Hunter to Riittakerttu Kaltiala, Hilary Cass (drhilarycass@gmail.com) and Cass Review (cass.review@nhs.net) (ECF 184-1).

Dr. Cass,

I am interested in learning more about your work in this area. I am a general pediatrician in Florida. I also have a background in bioethics. I have been appointed to the Florida Board of Medicine. The board licenses physicians and can regulate to practice of medicine. The board is considering adopting rules regarding youth gender transition.

I have been studying gender dysphoria and gender medicine since about 2015, when I first started seeing patients in my clinic. My focus has been on the history and scientific literature, but in the last year I have also forged relationships with 20 plus patients who have detransitioned.

I look forward to talking to you. Please let me know a time that works well for you.

Patrick Hunter

August

August 5: The Florida Board of Medicine holds a meeting on the proposed trans youth care ban.
August 10: Text message at 9:14 AM from Jason Weida to Andre Van Mol regarding Tom Benton, co-founder of the American College of Pediatricians (ACPEDS).

From Quentin:

“Tom Benton of Gainesville has agreed to speak at the Friday meeting. He should be calling you. His email address is notneb@bellsouth.com.”

August 12: The Florida Board of Osteopathic Medicine holds a meeting on the parallel proposed trans youth care ban for doctors of osteopathy. Tom Benton is the only speaker present.

September

September 12: Email “Fwd: My Breasts Were a Scapegoat” at 2:02 PM from Patrick Hunter to Paul Vazquez.

I know Laura, and spoke to her this past week. She just posted this video yesterday. She wants to be heard, but can’t speak publicly due to the effects a hostile crowd would have on her emotionally. But these are the stories that need to be heard.

September 12: Email “Re: Workshop” at 4:47 PM from Patrick Hunter to Paul Vazquez.

Paul,

The only ones I know who provide care for gender dysphoria youth in Florida are affirmative and transition kids. I know of two in Jacksonville who used to do puberty blockers, did not like what they saw, want to stop, but are getting pressure to continue from their employer. That group may be submitting a letter of concern. But people fear they will be ostracized and lose jobs for speaking out.

It is a highly charged atmosphere as you know. Because of that we fail to focus on evidence, efficacy and ethics. But rather ideology, in my opinion.

Did you see the video I sent you from Laura?

September 14: Email “Michael Biggs CV” at 2:27 PM from Patrick Hunter to Paul Vazquez.

Paul,

Michael Biggs wants to be present to express his concerns to the board. He is planning on coming October 5th. Before he purchases his tickets and flies in from England, he want to assure that he will have an opportunity to talk to the board.

Please let me know.

September 16: Email “Riittakerttu Kaltiala” at 8:18 AM from Patrick Hunter to Paul Vazquez and David Diamond.

Paul,

I met with Ritta Kaltiala this morning via Zoom. I have known her for over year now, and we meet regularly. She and I conducted an ethics conference on this issue at Nemours in December 2021. She is a child and adolescent psychiatrist, and was instrumental in standing up the Finnish youth transition clinics, and subsequently instrumental is severely restricting these in 2020, due to the harms seen. She is very well published in this area. Her bio and CV are attached.

She wants to submit something to the Florida Board of Medicine, but would like it to be formally requested. This is due to cultural and political issues in her country surrounding this issue.

Is that something I can request as a board member, or would that be better coming from you or Dr. Diamond? Her email address is riittakerttu.kaltiala@tuni.fi.

Thank you.

September 22: Email “Re: Connecting Patrick Hunter – Hilary Cass” at 4:21 AM from Patrick Hunter to Cass Review (ECF 184-1).

Dear Dr. Cass,

Thank you for meeting today and please thank your staff for their time. Below is the link to the Florida Department of Health. The Agency for Health Care Administration (AHCA) is the agency within the department of health that oversees Medicaid. Attachment C is the evidence review from McMaster University. I have attached the pdf of the McMaster report also.

I asked the board of medicine’s executive director, Mr. Paul Vazquez, if an email sent to me, as a board member, with information from your review attached would be proper protocol. He said it would be. He wants to invite you to present virtually to the board. I think that will put you in a difficult position. If he does send you an invite, please do what is most appropriate for you.

Again, thank you for your time, and I’d like to stay in touch.

Patrick

https://ahca.myflorida.com/letkidsbekids/

September 22: Email “RE: Connecting Patrick Hunter – Hilary Cass” at 6:07 AM from Cass Review (cass.review@nhs.net) to Patrick Hunter (ECF 184-1).

Dear Patrick,

Thank you for your email. Further to your request, please see links below to share with the Florida Board of Medicine.

Letter to NHS England.

Accompanying blog – Research.

Follow up blog — beyond the headlines.

NHS England response to the initial letter – Implementing advice from the Cass Review.

If you haven’t already done so, please subscribe to our mailing list to stay up to date on latest news and progress of the Review.

Best regards
Review team

September 22: Email “Florida Psychiatrist” at 9:12 PM from Patrick Hunter to Paul Vazquez (ECF 184-2).

Paul,

Today I was sent Dr. Kristopher Kaliebe’s CV, an article in the Journal of Adolescent and Child Psychiatry, and a letter to the editor that he has submitted for publication in response to the letter. Dr. Kaliebe is on faculty at University of South Florida College of Medicine. He is triple board certified in Child and Adolescent Psychiatry, General Psychiatry, and Forenseic Psychiatry. He wants to be present in Tallahasee to testify before the board regarding this issue.

His contact information is in his CV.

September 23: Matthew Benson, Monica Mortensen, and seven of their coworkers in the pediatric endocrinology department at Nemours Jacksonville submit a letter against gender-affirming care to the Florida Board of Medicine.

October

October 4: Email “Fwd: Connecting Patrick Hunter – Hilary Cass” at 11:41 PM from Patrick Hunter to Paul Vazquez and David Diamond (ECF 184-1).