· providing demographicinfonn~tion, physical exam, drg use. timeline, data . about childhood...

Roy S. Haber, OSB No. 800501haberpc(qcyber-dyne.comROY S. HABER P.C.570 East 40th AvenueEugene, OR 97405Telephone: 541.485.6418FAX: 541.434.6360Don H. Marmaduke, OSB No. 53072don.marmaduke(qtonkon.comTONKON TORP LLP1600 Pioneer Tower888 SW Fifth AvenuePortland, OR 97204-2099Direct Dial: 503.802.2003Direct FAX: 503.972.3703

Gilbert Paul Carrasco, California Bar No. 90838

(Appearing pro hac vice)carasco(qwillamette.eduNo. 451245 Winter Street SESalem, OR 97301Telephone: 503.370.6432FAX: 503.370.6375

Attorneys for Plaintiffs

IN THE UNITED STATES DISTRICT COURT

DISTRICT OF OREGON

(Medford Division)

THE CHURCH OF THE HOLY LIGHT OFTHE QUEEN, a/k/a The Santo Daime Church,an Oregon religious corporation, on its ownbehalf and on behalf of all of its members,JONATHAN GOLDMAN, individually and asSpiritual Leader of the "Santo Daime Church,"JACQUELYN PRESTIDGE, MARY ROW,M.D., MIRAM RAMSEY, ALEXADRABLISS YEAGER and SCOTT FERGUSON,members of the Santo Daime Church,

Plaintiffs,

Civil No. 08-cv-03095-PA

AMNDED EXPERT WITNESSSTATEMENT OF DR. JOHNHALPERN

v.

- . AMNDED EXPERT WITSS STATEMENT OF DR. JOHN HALPERN

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MICHAEL B. MUKAEY, Attorney Generalof the United States; KARIN J. lMMERGUT,United States Attorney, Distrct of Oregon;HENRY M. PAULSON, Secretary of the U.S.Deparment of the Treasur,

Defendants.

My name is John H. Halpern, M.D.

I have been asked to provide my expert opinions regarding thesacramental use of the Daime Tea used by the Santo Daime Church. Inpreparation for this report, I have reviewed the statement of Dr. Glacus DeSouza Brito, dated March 2, 2000; the declaration of Charles S. Grob, M.D.,dated March 30, 2000; the declaration of Charles Schuster, Ph.D., datedJune 20, 2000; the declaration of David E. Nichols, Ph.D., dated June 22,2000;the declaration of Natalia P. Urtiew, dated January 23,2001; the declaration ofGary T. Sheridan, dated Januar 24,2001; the declaration of Robert E. Dalton,dated January 24,2001; the second declaration of David E. Nichols, Ph.D.,dated February 7,2001; the second declaration of Charles S. Grob, M.D., datedFebruary 8,2001; and the declaration of Mark Albert Kleiman, Ph.D., datedFebruary 9,2001. In addition, I have referenced many scientific journals in myaccompanying Joural Article. Plaintiffs' Exhibit "7." In addition I haveattended a Santo Daime ceremony in Brazil and have spoken with plaintiffJonathan Goldman about Church practices. At the request of the plaintiffs, Iattended a ceremony in Oregon two years ago. I have also interviewed32 members of the Oregon Santo Daime Church as part of my study. I servedas a research assistant to Dr. Rick Strassman who did a study on the effects ofDMT in a controlled setting. See citation in Footnote 5, page 5, below. I alsoconducted a study with NIDA fuds (in a Mentored Patient-Oriented ResearchCareer Development Award) regarding the mental health and neurocogntiveeffects of sacramental use of peyote by members of the Native AmericanChurch.

I have testified as an expert in tral or at deposition twice since2000. A list of those occurences can be found on page 14 of my currculumvitae which is attached hereto as Exhibit A.

. AMENDED EXPERT WITNESS STATEME OF DR. JOHN HALPERN

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THE MEDICAL AND PsCWATRlC SAFETY QERwGlQUS "AYAHlJCAn I ISS

INTRPUCION

~'Aya1uascalt is a liquid brewed from the vine Banisteriopsis caapi alongwith usualy the leaves of Psychotria viridis. These plants are 'native to theAmazon Ba~in of South America and are collected in the wild and by ,cultivation. Ayahuasca is used by many indigenous South American cultures'whose customs have shiftd over time due to'WestemlEuropean infuences.Ayabasca has different fuctions for theso people, includig the .

preservati-on an continuity of their religious and medical traaitian, much ofwhich .dates back a few thousand years. In the 20th Ceiitury, syncreticreligions of Christian and indigenqus beliefs were formed in Brazil, which .tdentitY a,yahuasca as their holy religous sacrament. The two largest, theSanto Daime which evolved in the 1920's, and the União do Vegetal (UDV)'whièh began in the 1960's, have been.reøognized since the 1980's by theBrazlian Governent as having a.1egitiate right to inge~t an ayahuascasacrament and are therefore aforded the full measure: of religious protectionunder the iaw in Brazil. i To avoid oonfusion, it should be noted that the .brew does have niary names dependin~ on geographical.looation, religion,and p'eople. In addition to "ayahuasca' then, other synonymous termsinclude IIhoascall or "oasoa," "yajé" or lIyage," lIoaapi" or "kàhpf," "cip6, ntI.n~tß1a" or "natein," "dapa," "mihi," "vegetal," "tea," and uDaime." For the

'. purposes oftbjs report, I will use the ter "Dairne," as it is the.chosen namefor t1e Santo Dairne's ayahuasca sacraient. .

1 Dr. Halper. Dr. Juan Sanohoz-Ramos. and Professor Jimmy Gurule submitt an Amioua Curiae Briefon Septembe S. 2005. supportng the position of the UDV in GongJn yi 0 Centro Bapiri. No,Q4- i Q8~.

.On WÒt of Çmior to th Suremo Court. For pulposes of thiBDeolaraüon. i Cully adopt tho .'Interest ofthe Amici C\dii" and "II. Tho Oo'Venent Does Not Have A Compellng Interest in ProseoutiniiSacriiinntal Uses.aftho HOBsoa," Pagos 19-30. "Hoasea" is tho to uBc.d by the UDV for their .

saoramental ayabUBSOB. Daie and Hoasoa are both mado from tho iame ingrdients an all statements

made in theso seotions of tho Amicus Brief apply with equal force to tbe Santo Daimo.. ayahuasoåsacrament. "Diame." .. .

- AMENDED EXPERT WITNESS STATEMNT OF DR. JOHN HALPERN

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. Bantsteriopsts caapi is a large, rugged vine containng three cheitical ß..carboline alkaoids with mechaisms of action similar to cei1ain FDA.approved anti..depressant, hypnotic/sedative, ånd anxiolytic medications.Psychoactivity commences within 1 hour of drnking a "sufficient amountUand, contiues for 1 to 2 hours, unless re..ingested. Yawnng, ~mesis, and .

. diarhea often follows ingestion, but there are no known reports of chronicadverse reactions in the medical or anthopological literatue. Th~ threealkaloids are haraline, harine, and 1,2,~A..t~trahydroharine anØ are notlisted in any Schedule of the Controlled Substances Act (eSA) of 1970 andsuccessive Amendments.

Psychotrta viridis is a small plant containng the Schedule I hallucinogenN,N-5,S..diethyltrptaine (DMT). Numerous other treés, shrubs, andplants found in the Western Hemisphere (including the United States2) also

. .contai DMT, a few of which are also used ceremonially, but not by the~bove-mentioned Brazilian religions. Neither of the plant species mentionedaboye 'are controlled substaces. DMT is a ver short-acting powerfl,hallucinogen when smoked, intranasa11y insufflated, or injected .

intravenously or intramuscularly. DMT is not orally ab~orbed' (and thereforenot psychoactive) unless a gut-lined enzme, monoamine oxidase (MAO), is. destroyed or temporarily inactivatëd. The thee abqye..mentioned alkaloidsof the B. caapi vine all posses reversible tie-limited MAO inhibition,thereby permtting DMT absorption into the bloodstream and subsequentcrossing of the blood-brain barer. The two plants taken in combination, thetypical Daime brew t steadily induces a psychoactive effect as increasingMAO inhbition enables more remaing DMT to be absorbed tnough thegastrointestinm tract. With the 'first ingestiotl, DMT intoxication occurswithin the first hour and then gradually subsides over the next 1 to 2 hours.DMT likely will be absorbed mQre efficiently on re..ingestión while MAOinhibition continues from the earlier and additional consumption of B. caapi.. .PiireDMT is not often us~d for illcit hil11ucinogen intoxication in America.

, aid there are no known report of ayahuasca, in generalt and Daimet in.paricular, being divertd to an ilicit market anywhere. Huran dose-responae studies have been perforied with synthetic DMT and some

2 Halper JH. Halhicinogens and Dissociative Agents Naturally Growing in the UnitedStates. Pharmacology & Therapeutics. 102(2): 131-138.2004. Paper first presented atworkshop: UPsychoactive Botanieal Products." Offce of Dietary Supplements & NationalInstitute on Drug Abuse, Rockvile. MD, 9/9/03.

- AMNDED EXERT WITNESS STATEMENT OF DR.IOHN HALPERN

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neUropsychological, anthopological, and neuroendocrine stu~ies have beenconducted with members of the UDV. These early studies conclude thatDMT can safely be administered ill a research or specific religious settingand that ayahuasca drnkers appear healthy iad neurocognitively intact.

Indeed, under my direction, 32 (of approximately 40) CUlent Americanmemb~rs. of one branch of the Santo Daime Church were interviewedproviding demographicinfonn~tion, physical exam, drg use. timeline, data .about childhood conduct disorder, and carèfu psychiatrc semi..strctured

interview and questionnaires about anxiety¡ depression, and general mentalhealth were completed. Subjects were asked-about extent of Churchparoipation, what is liked least and most about Daie, and what healthbenefits or hans they attibute to Dairne. These members usual¡y attendservces weekly (lifetime 269:l314.7 cereonies; range 20..1300). Physica.l. exam and test scores revealed healthy subjects. Members claimed .psychol~gica1 and physical benefits from Daiine. 19 subjects met lifetimecriteria for a psychiatrc disorder, with 6 in parial remission, 13 in ñ,11remission, and 8 reportng induction of remission. though Churchpari~ipation. 24 subjects had drg or alcohol abuse or dependence historieswith 22 in fu remission, and al~ S with prior alcohol dependence describingChurch parcipation as the turng point in their re.covery. This data waspíesented at a Postèr Session of the 70th Anual Scien.tific Meeting of the.College on Problepis of Drug Dependence (CPDD), held in S~ Juan, PuertoRico, June 14,:19,2008. This study's abstract, as par ófCPDD'sproceedings, will be published in the peer..reviewed joural' Drug andAlcohol Dependence; the full manusoript will be published in a peer..reviewed medical journ to be .determined.3 The research reveals that thereare no apparent short or long term il health affects associated. With

sacraental ingestion ofDiaie.

.

Turning to the research condncted thus far regaring the pharacologiceffects ofDMT) as a chemical in the P. viridis piant, taken in' combinationwith MAO inhbitors, a,s chemicals in the B. caapi plant, reveals that there isvirtally no 'possibility of a h,nai being consuming a sufficient quantity ofthe Daiine to c.auseany jmmediate toxic or lethal effect.4.S .. . .3 HDlpem JR. Sheiwood AR. Passie T, Blackwell Ke, Ruttcnber AI (submitted for publication). .

Bvldencp of health and safety in American members of a religion that uses a hallucinogenio sacrament.4 Callaway ie (1995). PhannahuQloa and contomporaiy cthnophamacoloaY. Cum,.; i 8:39S-398.

S Strassman RJ (1996). Human psyohopharacology of M.N-dimethyltryptamine: BBhav.Braln Rea..73:121-124.

./ ..AMENDED EXPERT WITNESS STATEMENT OF DR. JORN HALPBRN

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PßPAMTIQ:N OF IlIME

As mentioned above, Daime is made by haiesting the vine B.. caapi and theleaves of P. viridis. Rituals and prayers are par of the collection and.preparation procesa for the Santo Daime. Veneraton of their holy sacramentincludes .pilgrmages for collectg the ingredients~ and preparing tl1e brew

for a stated purpose such 'as for a specific prayer, religious. holiday, orhealing session. The traditional preparat~on of B. caapt is strenuous andtime-consuining because the vine is a rugged) had wood. Sections of. thevine are cut and then beaten for hours in arde); to strp the bark and breakapart the vine prior to boiling. This prooess maximizes the extraction of the~.carbolines. SantÇ) Daime church members ~pnd throug~ this day..longritual by sharing in the preparation of their holy. sacrament and by offeringhymn and prayer during this wo~k. Typioally, the preparation process is a.happy tiiae ror churoh members and alows individuals to carefully reflecton. their intentions for the comig \1e of their sacrllent. Member's prayersòver the bre~g Daie may also extend to p~aying fur the good heàlth .andem~tional weí~-:being of the exteded churçh community that Will eventulyingest this sacrament, even though they wèr unavailable for assisting in.thepreparation of Daie. The bóili'Qg of Bo' caapt takes many hours, 'with watercarefuly added such that thee are several reductions of the brew. The leavesof P. viridis are typically added towads the end' of the boiling of the B.caapt vine, as DMT quickly dissolves into.the bre. .

Ti,RmIQIOUS USB QFD.IMB 1s niSrINCl FROM ILLIci DilQ US5

The Santo Daiine religion reveals a clear and consistent religious doctrinestriving to promote community and famly values as well as a healthy work.ethic.. The use of Dåime as a holy sácrament is the central facet in the.expression of religious faith for members. This is a ,vita distinction to be .

. appreiated, as the coitumption of Daime as a sacrament is. literally then thenon-drug use of DMT.

It is scientifically inappropriate to refer to. Daime as a hallucinogenic drug ascompaed to synthetic DMl. The Santo Daime's ingestion of theirsacr~ment then has no relation to recreational drug use of synthetic DMT. .

- AMENDED EXPERT WITNESS STATEMENT OF DR. JOHN HALPER

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Recreational drug use of DMl remains ilegal as set ,fort by this drug'siist~ng in Schedule I of the eSA. Ingestion of Daime to "get high" isanathema to membt(rs and especially the leadership of Santo Dairne, whoconsider the protectiôn of Daime for omy proper sacramental pu:rposes asone of their highest responsibilities.

, In fact, there is very clear precedent in the United States for permitting thesacramenta ingestion of Dairne, ,all the while aclaowledging that it alsocöntans a small amount of a cheinicallisted as a Schedule I substance inclrcum.stances outside of an approved religious setti;ng. Speçifically, 1 referto the protetion of the sacramenta use of the peyote cactus (Laphophora

. wllliamsii) by American citizens who belong to the Narive American Church(NAC). .With ,reference to the neurocogiutive risks from Daime use it 'might behelpful to consider siniUar evaluations of peyote. With grats fr-om HarvardMeaical School, the Heffter Research Institute, and especially the NationalIiititute on Drug Abuse, I complète a. study that focused en the .

neurooognitive effects from lifelong ingestion of peyote by members of theNAC. Final results concluded NAC members are just as neuroòøgntively

.: .healthy. as non-peyote using contrôls.6lt is also readily apparent-that thereligious' and visionary experiences NAC members experience auring thepeyote ceremony should not be properly defined as a halluoinolenicintoxication. Nevertheiess, the peyote cactus, ana it~ principle psychoactivealkàloid, mescaline, are both listed in SchedUle I of.the CSA. In the late

. 1800's through early 1900's in Ameriai,. the NAC, a syncretic Cbtistianreliglon, enierged in which peyote is employed as a sacrament. ~he NAC isnow well established in the United States, despite peyote being a "Schedule Idrug." NAC members are deeply affended when people unamiliar with their.religion question the Sincerity of their faith and their custos, wluch theyknow to be heathy, healing. and promoting the type of family values thatdominant American cUlture actually reveres. Indeed, the use of the term. uhallucinogen'~ is both misleadng and inaccurate when describing

. sacramenta peyote use as well as sacramentalDaime use. The NAC hasover 300,000 members in the United States, making it the largest religionamong Native American peoples. Ov~r 2 milion peyote "buttons" are. .6 Halpern JH. Sherwood AR. Hudson JI. Yurgelun-Todd D. Pope HO Jr. Payoholo¡ioal anLl cognitive

effects of long-ten peyote use among Native Amerioans. 8101081o.al P,ychlatr. 58:624.631. 2005.

- AMBNDED EXPERT WITNESS STATEMENT OF DR. JOHN HALPERN

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consumed annually in the United States through a regUlated system designedin paretslÍp between the DBA. the Texas Department of Publi~ Safety ~ and

the NAC. This quietly successful partnerslup offers positive proof that it isPQssible to safely regulate the wide distrbution of an otherwise. Schedule Ihallucinogen in Amenca when l'eUgious freedoir hangs in the balance., .There are other importat similarities between the religious' use or'Daimeand peyote. .Both have thousands of years of ritual use in the Wes,ternHemisphere. Both may induce'nausea and voindng. They have amy rarely

been studied.and described in peer-reviewed scientific journals. There are nopublished reports for either peyote or Daime indicating that their religioususe causes Hallu~inogen Persisting Perceptual Disorder. There are nopublished report of either D~ime or peyote causing any significant medical

, or psychological harm to members of these religions. Nor ha$ peyote ev:erbeen. repoit to be a popular product of the nIleit dmg market in the UnitedStates. And Daime ha never been reported to be associated in any way withilicit drug markets. It is doubtful that either peyote or Daime has ever been aminor drug trafficking problem in the United States. Moreover, both theleaderøhip of the Santo Daime and the NAC consistently state that theywould infonn law e1Ûorcement should they lean of any such ilicit drugtrafficking of their respective sacraments. These similarties may provideanother layer of reassurance at the public policy level that Daime, likepeyote, appears safe for human consumption when taen in strct accordancewith bona fide. traditionally accepted religious practices.. .. . .Ti REAL AND POTENIAL RISKS OF PAlMB TO l~niyinUALS AND TO IRSGIlNBRL POPULATION'. 'As a physician, I am concerned that proven allopathic medicine not besupplanted with untested, unproved faith healing. I am familar with theSanto Daime religious traditi~n and am aware tht the Church leaders do notpreach that the ingestion of the sacramental Daime w.ill Ilcure" a disease.Wht'they do preach is that tag the sacrament and following the doctrne

Witl promote psychological and physical health in a holistic maer forChurch members. I have not found any evidence to question this expressionof their faith but have found evidence in support (see Footnote 3 above). .. ,

. The :United States has àn important tradition of providing religious freedomeven when the resultig exemptions have caused concern amongst the

. traditional m~dicai community of which. I am a member. Thus, religious

- AMENDED EXPERT WITNESS STATEMENT OF DR. JOHN HALPERN

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exemptions have been granted fromvaccinatioii (several religions),treatment by faith-based healers outside allopathic medicine (ChristianScientists), denial of mental illness/opposition to the use of therapeuticpsychophaacological treatments by membership (Scientology), refusal oftransfsion of blood products even iflmown to be lifesaving (Jehova'sWitnesses), atd opposition to pregnøncy abortion when the mother's life isclearly .at risk (several religions or specific factions). I note again that the .exemption request in ths case does' nòt rase any of the real health concernsreferred to in the aforementioned exemptions. .

Seripus medical consequences from ingestion are the rare exceptions with allhallucinogens and physical trauma is tyically secondar to activitiespeifonned while under the influence of the'drg,' Moreaver, wh~n acardiovascular or other serious medical condition arses PQst hal1ucinogenirgestion, emergency medical teams generally correctly presume that theindividual has taken a compound adulterated with a dangerous non-hallucinogenic substance.8 . . ., .The psychoactive substances such as Daie and peyote àre'not known toinduce physical dependece. Tolerance is quite rapid,. precluding a .

theoretical scenaro in which daily ingestion (which is not a feature of eitherreligion) might lead to physiqlogical dependence. In general, then. thesesubstances have a ver low dependence liability,' Generally, those whooppose the religious, medical, or p.sychotherapeutic use ofha1lucinogens .have incorrctly labeled them as toxic to the eNS resulting in sonie sort ofcognitlveor emotional impairment. My review of the literature, whichappeard in the CPDn sponsored joural Drug and Alcohol Dependence,lo

places, these beliefs in seIous question as evidence to date supportscontinued intact cognitive functioning. There are, of course, risks associatedwith the ingestion of virtally ever chemical substance, including thoseavailable over the counter, paricularly when they aie not utili:ied according

. to directions.

7 Carey PM (1998). Drug Action In the Cantral NeI'oul Sy,iøm. New York: Oxford University Press.365. . ·.8 Hlllburt KM (1991). Drug-induoed psychoses, EmørgenCJ Medloln, Clinic, of North Amerloa. 9: 31.

52.9 Carvey PM (1998):DrugAcllon In the C,niral Ne;"Qui Syitem. Now York: Oxford UlUverity Press,366. .i 0 Halpern ¡J. Pope HO Ir (1999). Do Hallucinogens Cause Rosidual Neuopsyohological Toxioity?

Drug A.lcohol D,pl1nd,nc,~ 53:247.256.

- AMENDED BXPERT WITNESS STATEMBN:r OF DR. JOHN RALPERN

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Most traditional users and healers in South America do not screen forspecific medical problems because they view the sacramental substance as adirect vehicle for religious and healing sessions, in general, and assisting indiagnosing the nature of the disease presenting before them, in parcular.

When a Santo Daime congregant wishes to become a Church leader"Padrhol~' he/she undergoes extensive training, which includes evaluating

, each person who desires to become a new church member to detenninewhether there are åny conditionß or predisposition to any ilness that mightrender ingestion of the Daime undesirable. For example. the Santo DaitneChurch has developed a form entitled "Confidential Medical Record" that itproposes to use"prior to permitting any parcipation in Church activities'where the Daime inight be' consume.d. These fonns are strctured to

carefuy soreen for a variety of medical and. psychlatric condttions that canthen be reviewed by a physician shou\d there b~ any questions about risks to

physical or mental health. The documents clearly indicat that should therebe any question about health, a new physical and access to medical andpsychiatrc recQrds could be requested by Church offcials. For example:i theform asks, individuals if they have ever taken certain psychotropic .'medications and whether they ever rèquired a psychiatrc hospitalization,

. and t1s question doea provide an indirect way of inquiring apout remotemajor psyoliiatrc ilness ånd psycnotropic medication use.

I'

~ONCLUSIONS,....

I have recently reviewed tJe Brazilan Government 2006 CONAD report onthe religious use of ayahuasca.l1 The CONAD report states:

" For decades, the ritualistic use of AyøhlUica - a drink obtained from the

, decoction of the vine BøniBterloprl, C4pl Qagube, ni.-rlrl, ete.) and the leavesof P,ychotr ",lii, (ehacrona, ralnba ete.) - bas been rlcoinlzed by BrazÐlan

society as a legltlmate religious practlce,ii such that the COllcluslons of the

reports and ftndJnls that resulted from tbe multidisciplinary studiesdetermined by the former CONFEN in 1985 are more than current, when th.ey

i 1 C.ONAD is a' druB polley am of SISNAD, th~ National System of PubUo Polioy on Drugs, and ita. deoisions "must be complied with by organs and entitles of thó Brazilan Governent" November 23, 2006.

The MultidisoipUnøi Working Group, that wrote tho CONAD report, was composed of abc members. ThefJaito Daime and tho UDV eaoh prvided two niembera. Another member was Dr. Edwar 10M Bap1istadas Nevos MacRae. who was advising the Multidisciplinary Working Grup on issues'reJating to

. phannaoology and bioohemistry. This member. Dr. MacRae, is now serving 88 an expert for the plaintifsin this oase.12 For the Santo Daimo and UDV reUgions.

- AMENDED EXERT WITNESS STATEMENT OF DR. JOHN HALlBRN

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had verified that Kt¡or many decad" tho u" of Ayaliuarca hai boen ocurrliigwithout leading to any known iocllll dama". II '.

The empirical ,evidence to date fails to. establish any thieat to inøividual Orlong..tenn health issues but does point to relative safety and possibleadditional physical and menta health benefits. There is no traficking inDaime in the United States. Daime is not a recreational drug by anyderuuûon and is not likely to ever be a concern to the goals of drugenforcement for ,which the DBA has been chartred. Absent direct evidence

tht the Daime is a serious health risk, arid such evidence does not curentlyexist, there appears. to be no scientific or medically valid reasòn to prohibitits ingestion as a bona fide religious sacrament. Finally, a Schedule I drug is,by definition, a drug with a '¡ugh potential for abuse, which the I?aimeclearly is not. In this regard then, there are no public health concerns thatwould justify criminaizing the Santo Daime'susa of thei ayahuascasacrament, Daime.

To the extent that control over the Daime is an interest we all have. I amconvinced that the leadership of the Church, no less so then the leaders ofthe p'eyote religion, control the distrbution of the sacrament limitig itsavailability to direct use only åt prayer servces. .

The DEA aleady has in plaoe an elaborate soheme for règisterng,controlling and accounting for thousand of dmgs th~t .ar made ot: importedinto ths countr. Registering the importation of the Daie "and requiring a

. strict accountig.for its dissemination is expected to be a routine matter forthe DBA without s~bstantiai burden on manpower and resources.

The members of the Santo Daime Church should ~e granted the right toingest its sacrament Daime at religious servces .without theat of'arest or

criiinal prosecution in the United.States. . .'.

- AMENDED EXPERT WITNESS STATEMENT OF DR. JOHN HALPERN

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In regard to this present legal matter, since 1999, I have beencompensated at the rate of $ 150/hour for relevant research and preparation ofmy declaration. I have been paid approximately $2,000 to date.

My qualifications are set forth in my Curiculum Vitae, attachedhereto as Exhibit A.

Pursuant to 28 USC § .1746, I declare under penalty of perjury thatthe foregoing is tre and correct.

DATEDthis,5!!day of ;JWíJlt/¡tL., 2008.

~

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c

EXHIBIT A(CURRICULUM VITAE)

TOAMENDED EXPERT WITNESS

STATEMENT OFJOHN HALPERN, M.D.

Case No. 08-cv-03095-PA

E-filed 12/1/08

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JOHN H. HALPERN, M.D.

Home Address:143 Hudson RoadStow, MA 01775-1216Phone: (617) 283-2133FAX: (309) 276-6231EMAIL: john _ halpern~hms.harvard.edu

om ce Address:Alcohol & Drug Abuse Research CenterMcLean Hospital115 Mill StreetBelmont, MA 02478-9106Phone: (617) 855-3703FAX: (617) 855-3585

Education

1986 Hackley School, Tarrtown, NY.

1990 B.A. The University of Chicago, Chicago, IL. Biological Sciences with Honors.

1994 M.D. The State University of New York Health Science Center at Brooklyn,College of Medicine.

Post Graduate Training

7/94-12/94 Medical Internship, Carney Hospital, Boston, MA.

6/94-6/98 Psychiatry Resident, Harvard Longwood Psychiatry Residency TrainingProgram, Boston, MA.Clinical Fellow in Psychiatry, Harvard Medical School, Boston, MA.

7/97-6/03 Research Fellow, Clinical Neuroendocrinology Laboratory, Alcohol andDrug Abuse Research Center, Harvard Medical School-McLean Hospital,Belmont, MA.

7/97-6/03 Research Fellow, Biological Psychiatr Laboratory, Alcohol and DrugAbuse Research Center, Harvard Medical School-McLean Hospital,Belmont, MA.

7/98-6/99 Ethel Dupont-Warren Fellow, Harvard Medical School, Boston, MA.

Past Academic Position

7/98-3/06 Instructor in Psychiatry, Harvard Medical School, Boston, MA.

Current Academic Position

4/06- Assistant Professor of Psychiatry, Harvard Medical School, Boston, MA.

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Current Positions

6/03- Associate Director of Substance Abuse Research, Biological PsychiatryLaboratory, Alcohol and Drug Abuse Research Center, McLean Hospital,Belmont, MA.

Director, Laboratory for Integrative Psychiatry, Addictions Division,McLean Hospital, Belmont, MA.

Current Hospital Privileges

8/08-

4/06-7/98-3/06

Associate Psychiatrist, McLean Hospital, Belmont, MA.Assistant Psychiatrist.

Awards and Grants

1997 APA Young Investigator Award. The lS0th Annual Meeting of theAmerican Psychiatric Association, San Diego, CA.

7/97-6/98; 8/99-6/00 National Research Service Award, National Institute on Drug Abuse,Rockvile, MD. T32-DA-72S2. Support for Postdoctoral Fellowship indrug abuse research, Alcohol and Drug Abuse Research Program, Alcoholand Drug Abuse Research Center, Harvard Medical School-McLeanHospital, Belmont, MA.

1998 1998 Laughlin Fellow of The American College of Psychiatrists.

7/98-6/99 Ethel Dupont-Warren Fellowship Award, Research Committee of theConsolidated Department of Psychiatry, Harvard Medical School, Boston,MA. Support for independent Postdoctoral Fellowship, Alcohol and DrugAbuse Research Program, Alcohol and Drug Abuse Research Center,Harvard Medical School-McLean Hospital, Belmont, MA.

7/98-6/99 Peter Livingston Fellowship Award, Research Committee of theConsolidated Department of Psychiatry, Harvard Medical School, Boston,MA.

7/98-6/02 Research Grant Award. The Heffter Research Institute, Santa Fe, NM.

Support for protocol "Cognitive Effects of Substance Use in NativeAmericans. "

9/00-8/04 Mentored Patient-Oriented Research Career Development Award (K23).

National Institute on Drug Abuse, Rockvile, MD. K23-DA00494.Support for career development, protocol "Cognitive Effects of SubstanceUse in Native Americans" (use of peyote or alcohol), and protocol"Neurocognitive Consequences of Long-Term Ecstasy Use."

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9/01-2/06 Research Grant Award. The Multidisciplinary Association for PsychedelicStudies, Sarasota, FL. Support for protocols "Cognitive Effects ofSubstance Use in Native Americans," "Neurocognitive Consequences ofLong-Term Ecstasy Use," and "Phase II Dose-Response Pilot Study of+/-3,4-methylenedioxymethamphetamine (MMA)-assisted Psychotherapy

in Subjects with Anxiety Associated with Advanced Stage Cancer."

Original Research Grant, National Institute on Drug Abuse, Rockvile,MD, 1 R01 DA01 7953-01AL. NI grant support for protocol"Neurocognitive Consequences of Long-Term Ecstasy Use."

9/04-

2005- Listed in Marquis' Who's Who in America.

5/06- Major Donation. Mr. Peter Lewis. Support for protocol "Phase II Dose-Response Pilot Study of +/-3,4-methylenedioxymethamphetamine(MMA)-assisted Psychotherapy in Subjects with Anxiety Associatedwith Advanced Stage Cancer."

Prior Research Experience

1 989 The University of Chicago, Chicago, IL.Research Assistant under Morris Goldman, M.D. Project in self-inducedwater intoxication and schizophrenia. Volunteer at Ilinois StatePsychiatric Institute. .

1989- 1 990 Ben May Institute, The University of Chicago, Chicago, IL.Research Assistant under Jeffrey Bluestone, M.D. Project in cloning andcharacterization of murine T-cell receptor genes. Participated inengineering DNA constructs for injection into transgenic mice.

1994 The University of New Mexico, Albuquerque, NM.Fourth year medical student Psychiatry Research Elective under RickStrassman, M.D. Assisted in the collection of data on the dose response ofthe hallucinogen dimethyltryptamine (DMT) in human volunteers.

7/97 -6100 Alcohol and Drug Abuse Research Program, Alcohol and Drug Abuse

Research Center, Harvard Medical School, Harvard University, McLeanHospital, Belmont, MA.Research Fellowship under Jack Mendelson, M.D. Partcipated in projectson potential pharmacotherapy of cocaine dependency and cocaine's acuteneuroendocrine and immunologic effects in humans. Separate project ranconcurrently under Harrison G. Pope, Jr., M.D. on the neurocognitiveeffects of chronic hallucinogen use or alcoholism in a Native Americanpopulation; project continued under above-noted K23 CareerDevelopment Award.

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Publications

Peer Reviewed Articles

John H. Halpern, M.D.

Halpern JH. The Use of Hallucinogens in the Treatment of Addiction.Addiction Research, 4(2):177-189,1996.

Halpern JH, Pope HG Jr. Do Hallucinogens Cause ResidualNeuropsychological Toxicity? Drug and Alcohol Dependence, 53:247-256, 1999.

Halpern JH, Pope HG Jr. Hallucinogens on the Internet: A Vast NewSource of Underground Drug Information. American Journal ofPsychiatry, 158(3):481-483,2001.

Mendelson JH, Mello NK, Sholar MB, Siegel AJ, Mutschler N, Halpern J.Temporal Concordance of Cocaine Effects on Mood States andNeuroendocrine Hormones. Psychoneuroendocrinology, 27:71-82, 2002.

Halpern JH, Pope HG Jr. Hallucinogen Persisting Perception Disorder:What Do We Know After 50 Years? Drug and Alcohol Dependence,69(2):109-119,2003.

Halpern JH, Sholar MB, Glowacki J, Mello NK, Mendelson JH, SiegelAJ. Diminished Interleukin-6 Response to Pro-Inflammatory Challenge inMen and Women After I.V. Cocaine Administration. Journal of ClinicalEndocrinology and Metabolism, 88: I 188-1 193,2003.

Duckworth K, Halpern JH, Schutt RK, Gilespie C. Use of Schizophreniaas Metaphor in U.S. Newspapers. Psychiatric Services, 54:1402-1404,2003.

Halpern JH. Hallucinogens and Dissociative Agents Naturally Growing inthe United States. Pharmacology & Therapeutics, 102(2):131-138,2004.

Halpern JH, Pope HG Jr, Sherwood AR, Barry S, Hudson n, Yurgelun-Todd D. Residual Neuropsychological Effects ofllicit 3,4-Methylenedioxymethamphetamine (MDMA) in Individuals with MinimalExposure to Other Drugs. Drug and Alcohol Dependence, 75(2): 135-147,2004.

Halpern AL, Halpern JH, Freedman AM. Now is the Time for AAL toDemonstrate Leadership by Advocating Positions of Social Importance.Journal of the American Academy of Psychiatr and the Law, 32(2): 1 80-183,2004.

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Halpern JH, Sherwood AR, Hudson JI, Yurgelun-Todd D, Pope HG Jr.Psychological and Cognitive Effects of Long-Term Peyote Use AmongNative Americans. Biological Psychiatr, 58:624-631, 2005.

Halpern JH, Sewell RA. Hallucinogenic Botanicals of America: AGrowing Need for Focused Drug Education and Research. Life Sciences,78(5):519-526,2005.

Sewell R, Halpern JH, Pope HG Jr. Response of Cluster Headache toPsilocybin and LSD. Neurology, 66(12):1920-1922, 2006.

Boyer EW, Babu KM, Adkins IE, McCurdy CR, Halperr JH. Self-Treatment of Opioid Withdrawal Using Kratom. Addiction, 103: l048-1050,2008.

Halpern JH, Sherwood AR, Passie T, Blackwell KC, Ruttenber AI.Evidence of Health and Safety in American Members of a Religion WhoUse a Hallucinogenic Sacrament. Medical Science Monitor, 14(8):SR15-22,2008.

Passie T, Halpern JH, Stichtenoth DO, Emrich HM, Hintzen A. ThePharmacology of Lysergic Acid Diethylamide: A Review. CNSNeuroscience & Therapeutics, in press.

Invited Articles/Book Chapters

Halpern JH. Hallucinogens, Anesthetic Agents, and Amphetamines.Pharmaceutical News, 7(5):21-29, 2000.

Halpern JH. Counterpoint: Addiction is a Disease. Psychiatric Times,XIX(10), 2002. http://ww.psychiatrictimes.com/p0210ctpt.html

EI-Mallakh RS, Halpern JH, Abraham RD. Substance Abuse:Hallucinogen- and MDMA-Related Disorders (Chapter 57). In: Tasman A,Lieberman J, Kay J, editors. Psychiatr. 2nd edition. London: John Wiley& Sons, pp. 1046-1065,2003.

Halpern JH. Hallucinogens: An Update. Current Psychiatr Reports,

5(5):347-354,2003.

Sewell RA, Halpern JH. Response of Cluster Headache to LSD andPsilocybin. In: Winkelman M, Roberts T, editors. Psychedelic Medicine:Scientifc Evidence for Hallucinogenic Substances as Treatments, Volume1. Westport, CT and London: Praeger Publishers, pp. 97-124, 2007.

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Abstracts


Halpern JH. Hallucinogens in the Treatment of Alcoholism and OtherAddictions. In: Winkelman M, Roberts T, editors. Psychedelic Medicine:Scientifc Evidence for Hallucinogenic Substances as Tre,atments, Volume2. Westport, CT and London: PraegerPublishers, pp. 1-14,2007.

El-Mallakh RS, Halpern JH, Abraham RD. Substance Abuse:Hallucinogen- and MDMA-Related Disorders (Chapter 60). In: Tasman A,Maj M, First MB, Kay J, Lieberman JA, editors. Psychiatry. 3rd edition.London: John Wiley & Sons, pp. 1100-1126,2008.

Suzuki J, Halpern JH, Passie T, Huertas PE. Hallucinogens andDissociative Drugs (Chapter 20). In: Cohen LM, Collns FL, Young AM,McChargue DE, Leffingwell TR, editors. The Pharmacology andTreatment of Substance Abuse: An Evidence Based Approach. London:Taylor & Francis, in press, 2009.

Halpern JH, Huerts PE, Passie T. Hallucinogens. Johnson BA, editor.Addiction Medicine: Science and Practice, Heidelberg: Springer-Verlag,in press, 2009.

Halpern JH, Huerts PE,Passie T. Hallucinogen Abuse and Dependence.

Stolerman I, editor-in-chief. Encyclopedia of Psychopharmacology,Heidelberg: Springer-Verlag, inpress, 2009.

Halpern, JH, Halpern, AL. Addiction treatment in the 21st Century: NewTherapeutic Approaches and Their Forensic Implications. Proceedings ofthe American Academy ofF orensic Sciences, III: 179-180, 1997.

Halpern, JH, Halpern, AL. The Violence-Prone Offender in the CriminalJustice System: Prospects for Prevention and Treatment in the 21stCentury. Proceedings of the World Congress on Violence, 84, 1998.

Halpern JH, Mendelson JH, Glowacki J, Sholar MB, Lesieur-Brooks A,Siegel AJ, Pesok AL. Diminished Cytokine IL-6 Response in Men andWomen After I.V. Cocaine Administration. NIDA Research Monograph,179:46, 1998.

Mendelson JH, Sholar MB, Mello NK, Siegel AJ, Halpern JH. CocainePharmacokinetics in Men and in Women During Two Phases of theMenstrual Cycle. NIDA Research Monograph, 179:149,1998.

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Sholar ME, Mendelson JH, Mello NK, Siegel AJ, Halpern JH. GenderDifferences in ACTH and Cortisol Responses to 1 V. CocaineAdministration. NIDA Research Monograph, 179: l50, 1998.

Sholar ME, Mendelson JH, Mello NK, Siegel AJ, Halpern JH. ACTH,DHEA, and Cortisol Increases After 0.2 mg/kg Cocaine LV.Administration. NIDA Research Monograph, 180:207, 1999.

Halpern JH, Pope HG Jr. Hallucinogens on the Internet: A VastUnderground Psychedelic Resource. NIDA Research Monograph,180:149, 1999.

Halpern JH, Pope HG Jr, Sherwood A, Hudson II, Yurgelun-Todd D.Neuropsychological Effects of Long-Term Hallucinogen Use in NativeAmericans. Drug and Alcohol Dependence, 63(S I): S62, 2001.

Halpern JH, Pope HG Jr, Sherwood A, Hudson II, Yurgelun-Todd D.Neuropsychological Effects of Long-Term Hallucinogen Use VersusAlcoholism in Native Americans: Cultural Limitations of Tests. Drug andAlcohol Dependence, 66(SI):S73-S74, 2002. .

Halpern JH. Residual Neuropsychological Effects ofllicit 3,4-Methylenedioxymethamphetamine (MDMA) in Individuals with MinimalExposure to Other Drugs: Pilot Data From "Pure" Users versus Controls.International Journal ofNeuropsychopharmacology, 7(SI):S85, 2004.

Letters to the Editor

John H. Halpern, MD.

Halpern JH. Involvement of Physicians in Capital Punishment. New YorkState Journal of Medicine, 91(6):271-272, 1991.

Halpern JH. HM.O. Gag Rules. The New York Times, p.A24, January 11,1996.

Halpern JH. It's Time to Wake Up to Drug War's Failure: California'sGood Sense. The New York Times, p.A24, November I9, 1996.

Halpern JH. Native American Rites. The New York Times, p.A24,December 29, 1997.

Halpern JH. Treatment of Attention-Deficitlyperactivity Disorder. TheJournal of the American Medical Association, 281(16):1491, 1999.

Halpern JH. The Census and the Question About Race. The New YorkTimes, p.A22, April 25, 2000.

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Halpern JH, Pope HG Jr. Drugs on the Internet (In Reply). AmericanJournal of Psychiatry, 158(12):2095,2001.

Halpern JH: Addiction: Choice or Disease (In Reply). Psychiatric Times,XX(2):13,2003.

Halpern JH. Iraq's Reconstruction. The New York Times, p.A24,December 23, 2003.

Halpern JH, Pope HG, Sherwood AR Barr S, Hudson JI, Yurgelun- ToddDA. Reply to Lyvers and Hasking (2004) (Commentary). Drug andAlcohol Dependence, 75(2):153,2004.

Posters I Presentations

John H. Halpern, MD.

Halpern JH. The Use of Hallucinogens in the Treatment of Addiction.Harvard Research Day. Consolidated Department of Psychiatry, HarvardMedical School, Boston, MA, 3/14/96.

Halpern JH. The Use of Hallucinogens in the Treatment of Addiction.NEDH Scientific Symposium. New England Deaconess Hospital, Boston,MA, 5/11/96.

Halpern JH. Group Psychotherapy in the Detox Setting (Grand Rounds).Detox Unit, Dimock Community Health Center, Roxbury, MA, 1/24/97.

Halpern JH, Halpern AL. Addiction Treatment in the 21st Century: NewTherapeutic Approaches and its Forensic Implications. The 49th AnnualMeeting of the American Academy of Forensic Sciences, New York, NY,2/22/97.

Halpern JH, Halpern AL. Anti-craving Chemotherapy: Anticipated Boonfor Courts, Corrections, and the Addict Offender. The 6th InternationalConference of The International Association for Forensic Psychotherapy,London, England, 4/26/97.

Halpern JH, Pope HG. Neurocognitive Deficits in a Peyote ConsumingPopulation. The Young Investigators' Research Colloquium of the 150th

Annual Meeting of the American Psychiatric Association, San Diego, CA,5/18/97.

Halpern JH, Mendelson J, Glowacki J, Sholar M, Lesieur-Brooks A,Pesok A. Diminished Cytokine IL-6 Response in Men and Women AfterI.V. Cocaine Administration. Harvard Research Day. ConsolidatedDepartment of Psychiatry, Harvard Medical School, Boston, MA, 4/22/98.

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Halpern JH, Mendelson JH, Glowacki J, Sholar MB, Lesieur-Brooks A,Siegel AJ, Pesok AL. Diminished Cytokine IL-6 Response in Men andWomen After I.V. Cocaine Administration (oral presentation). SixtiethAnnual Scientific Meeting of the College on Problems of DrugDependence, Scottsdale, AZ, 6/14/98.

Mendelson JH, Sholar MB, Mello NK, Siegel AI, Halpern JH. CocainePharmacokinetics in Men and in Women During Two Phases of theMenstrual Cycle. Sixtieth Annual Scientific Meeting of the College onProblems of Drug Dependence, Scottsdale, AZ, 6/14/98.

Sholar MB, Mendelson JH, Mello NK, Siegel AJ, Halpern JH. GenderDifferences in ACTH and Cortisol Responses to I.V. CocaineAdministration. Sixtieth Annual Scientific Meeting of the College onProblems of Drug Dependence, Scottsdale, AZ, 6/14/98.

Halpern JH. Neurocognitive Evaluation of a Peyote ConsumingPopulation (Grand Rounds). The Massachusetts General Hospital, Boston,MA, 4/28/99.

Halpern JH, Pope HG Jr. Hallucinogens on the Internet: A VastUnderground Psychedelic Resource. Sixty-First Annual Scientific Meetingof the College on Problems of Drug Dependence, Acapulco, Mexico,6/15/99.

Halpern JH. Neurocognitive Effects of Chronic Hallucinogen Use(Neuroscience Seminar Series). McLean Hospital, Belmont, MA, 9/20/99.

Halpern JH. Assessment of the Neurocognitive Functioning of Long-TermHallucinogen Users: Implications for Clinical Hallucinogen Research.Third International Congress of the European College for the Study ofConsciousness, Basel, Switzerland, 11/13/99.

Halpern JH. Hallucinogens: Ilicit Use, Religious Use, and AmericanResearch (Psychopharmacology Grand Rounds). McLean Hospital,Belmont, MA, 10/19/00.

Halpern JH. Controversial Drugs in Health Care (Lecture sponsored by theMCPHS Faculty Development Committee). Massachusetts College ofPharmacy and Health Sciences, Boston, MA, 11/16/00.

Halpern JH. Legal Invasion of Privacy: Psychiatrists Beware! Presented atWorkshop on "The Individual versus the State: Patients' Privacy andAbuses of Psychiatry," 154th Annual Meeting of the American PsychiatricAssociation, New Orleans, LA, 5/8/01.

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Halpern JR. Hallucinogens: Religious Use, llicit Use, and CurrentPsychiatric Research. Presented at (and Co-Chair of) Workshop on"Hallucinogens: Religious Use, Ilicit Use, and Current PsychiatricResearch," I 54th Annual Meeting of the American PsychiatricAssociation, New Orleans, LA, 5110/01.

Halpern JR, Pope HG Jr. Neuropsychological Effects of Long-TermHallucinogen Use in Native Americans (oral presentation). Sixty-ThirdAnnual Scientific Meeting of the College on Problems, of DrugDependence, Scottsdale, AZ, 6118/01.

Halpern JR (Co-chair). Debate: The Use of Psychedelics in Therapy.Addictions 2001 Meeting of the International Society of AddictionMedicine, Tel Aviv, Israel, 9/9/01.

Halpern JR. Neurocognitive Consequences ofMDMA and Marijuana.Addictions 2001 Meeting of the International Society of AddictionMedicine, Tel Aviv, Israel, 9110/01.

Halpern JR. Mescaline: Clinical Neurocognitive Toxicity and TreatmentProfie for Severe Alcoholism. Addictions 2001 Meeting of theInternational Society of Addiction Medicine, Tel Aviv, Israel, 9110/01.

Halpern JR. Ethnopharmacology of Psychedelics: From Ancient Rites toModem Therapies. Regional Meeting of the American' Chemistry Society,Cambridge, MA, 5/16/02.

Halpern JH. Lecture and Discussant. Workshop: "Youth, the Internet, andDrug Use." National Institute on Drug Abuse, Rockvile..MD, 6/6/02.

Halpern JR, Pope HG Jr,Sherwood A, Hudson JI, Yurgelun-Todd D.Neuropsychological Effects of Long-Term Hallucinogen Use VersusAlcoholism in Native Americans: Cultural Limitations of Tests. Sixty-Forth Annual Scientific Meeting of the College on Problems of DrugDependence, Quebec, Canada, 6118/02.

Halpern JR. Lecture and Discussant. Workshop: "Psychoactive BotanicalProducts." Offce of Dietary Supplements & National Institute on DrugAbuse, Rockvile, MD, 9/9/03.

Halpern JR. Lecture and Discussant. Residual Neuropsychological Effectsofllicit 3,4-Methylenedioxymethamphetamine (MDMA) in Individualswith Minimal Exposure to Other Drugs: Pilot Data from "Pure" Usersversus Controls. For symposium, "MDMA Neurotoxicity in Humans:Current Status and Future Prospects." Collegium Internationale Neuro-Psychopharmacologicum, xxv Congress, Paris, 6/24/04.

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Halpern JR. Lecture and Discussant. Workshop: "Naturceuticals (NaturalProducts), Nutraceuticals, Herbal Botanicals, and Psychoactives: DrugDiscovery and Drug-Drug Interactions." National Institute on Drug Abuse,Baltimore, MD, 11/05/04.

Sewell RA, Halpern JR, Pope HG Jr. "The Treatment of ClusterHeadaches with Indole-Ring Hallucinogens." Harvard Departent of

Psychiatry Research Day, Boston, MA, 3/30/05.

Halpern JR. Lecture. Hallucinogens: Neurocognitive Sequelae FromLong-Term Use and the Importance of Re-Investigating Their Medico-Therapeutic Potentials. Behavioral Pharmacology Research Unit,Department of Psychiatry, Johns Hopkins School of Medicine, JohnsHopkins University, Baltimore, MD, 5/3/05.

Halpern, JR. Lecture and Panelist. Cognitive Effects of Substance Abusein Native Americans. For the session "Advances in Clinical Neuroscience,Development, and Behavioral Treatment Research" of the conference"Bridging Science and Culture to Improve Drug Abuse Research inMinority Communities." National Institute on Drug Abuse, Atlanta, GA,10/24/05.

Halpern JR. The Research ofMDMA-Assisted Psychotherapy as aTreatment for the Clinical Anxiety of the Dying (Grand Rounds). McLeanHospital, Belmont, MA, 11/03/05.

Sewell RA, Halpern JR. Response of Cluster Headache to LSD andPsilocybin. 1 ih Annual Meeting of the American NeuropsychiatricAssociation, 2/21/06.

Halpern JR. Hallucinogens: Harms, Potentials, and Religious Users. 4thAnnual Symposium, "Current Trends in Drug Abuse Research." TheCenter for Drug Discovery, Northeastern University, Boston, MA 4/12/06.

Sewell RA, Hal~ern JH. Response of Cluster Headache to LSD andPsilocybin. 114t Annual Meeting of the American PsychiatricAssociation, 5/21/06.

Halpern JR. Advances in the Treatment of Alcohol and Drug Addiction.American Conference on Psychiatric Disorders, New York, NY, 6/24/06.

Halpern JR. Ecstatic States in Psychotherapy and Their Relevance forMental Health. International Congress on Ecstatic States:. Phenomenon,Experience, Healing. Hannover Medical School, Hannover, Germany,5/24/2008.

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Halpern JR. Update on Therapeutic Research of Hallucinogens (InvitedLecture). Department for Psychiatry, Social Psychiatry andPsychotherapy, Hannover Medical School, Hannover, Germany,5/28/2008.

Halpern JR, Sherwood A, Passie T, Ruttenber J. Use of a HallucinogenicSacrament by American Members of the Santo Daime Church: Evidenceof Safety (Poster). Seventy-First Annual Scientific Meeting of the Collegeon Problems of Drug Dependence, San Juan, PR, 6/17/08.

Peer Review Services

1999 The Oxford Handbook of Clinical Medicine: American Edition. Oxford UniversityPress, Inc., 1999 (ISBN: 019512572X).

2002 American Journal of Psychiatry

2003 Archives of General Psychiatry.

Drug and Alcohol DependenceJournal of Clinical PsychiatrySocial Science & Medicine

2004 American Journal of PsychiatryDrug and Alcohol DependenceJournal of Clinical PsychiatryPrimary Psychiatr

2005 American Journal of PsychiatryCognitive and Behavioral NeurologyDrug and Alcohol DependenceExperimental & Clinical PsychopharmacologyForensic Science InternationalJournal of Clinical Psychiatry

2006 Archives of General PsychiatryDrug and Alcohol DependenceEvidence Based Complementary and Alternative MedicineExperimental & Clinical PsychopharmacologyJournal of Clinical PsychiatrySubstance Abuse Treatment, Prevention, and Policy

2007 Drug and Alcohol DependenceExperimental & Clinical PsychopharmacologyForensic Science International

Journal of Clinical PsychiatryJournal of Psychopharmacology

John H. Halpern, M.D. Page 12

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Journal of Psychosomatic ResearchPharmacological ResearchPhilosophy, Ethics, and Humanities in Medicine

2008 Biological PsychiatryJournal of PsychopharmacologyJournal of Psychosomatic Research

Dissertation Committee

2006 "Metamemory, Memory and Executive Function in Recreational Ecstasy-Polydrug Users." Gil Inder Bedi, Ph.D. Candidate, Monash University,Melbourne, Australia.

Nll Review Services

11/04/05 Member, Center for Scientific Review Special Emphasis Panel, ZRG 1BBBP-D (03): Drug Effects on Biobehavioral Regulation.Reviewer, NIA Small Business Innovative Research (SBIR) project,"Discovery and Study of Psychoactive Components of Botanicals.

"

Member, Center for Scientific Review Special Emphasis Panel, 2009/01ZRG1 DIG-A (50)R: Native American Research Centers for Health.

6/04/07

10/20-21/08

Editorial Board

2005-2008-

American Psychiatry News (formerly eNS News)ISL-Psychiatry Research, Editor-in-Chief. (18t

Organizations

1990-20061990-1990-1995

1992-19951995-2006-2009

1995-1995-20011996-1997-20011997-

2003-

Member, American Medical Association.Member, Sigma Xi.Member, Medical Society of The State of New York.

Member, Drug Abuse Committee.Member, American Psychiatric Association.

Member, Committee on Training and Education in Addiction PsychiatryMember, Massachusetts Psychiatric Society.Special Consultant, Heffter Research Institute.Member, Massachusetts Medical Society.Fellow, Boston Medical Library.Member, American Academy of Forensic Sciences.

Member, Psychiatry & Behavioral Science Section Task Force onAddiction.

Member, American Academy of Psychiatry and the Law.Member, American College of Psychiatrists.Regular Member, College on Problems of Drug DependenceMember, Underrepresented Populations Committee

2001-2004-2007-

2008-


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Licensure

19951996-

Diplomate, National Board of Medical Examiners (USMLE).Medical License, Board of Registration in Medicine, Commonwealth ofMassachusetts (#150283).

DEA ii-v Registration (#BH4926878) .Diplomate, American Board of Psychiatry and Neurology (BoardCertification # 46440)DEA Buprenorphine Registration (#XH4926878)

1997-1999-

2004-

Expert Witness Testimony2000 State of Florida v. Valessa Robinson. Case No. 98-11873. Murder case

involving hallucinogen intoxication.2002 State of Michigan, in the Circuit Court for the County of Newaygo,

Family Division. Case No. 98-000744-DM; In the Matter of Fowler v.Fowler. Family Court hearing involving Native American parental rightsto include a child in peyote prayer services of the Native AmericanChurch.


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STATEMENT OF DR. JOHN HALPERN on:

Eric Joseph Beane / Brigham J. Bowen / Julie Straus / Lily FarelCivil Division, Federal Programs BranchU.S. Deparent of JusticeP.O. Box 883, Room 7124Washington, DC 20044

Attorneys for Defendants

D by mailng a copy thereof in a sealed, first-class postage prepaid envelope,addressed to each attorney's last-known address and depositing in the U.S. mail at Portland,Oregon on the date set forth below; .

D by causing a copy thereof to be hand-delivered to said .attorneys at eachattorney's last-known office address on t~e date set forth below;

D by sending a copy thereofvia overnight courer in a sealed, prepaid envelope,addressed to each attorney's last-known address on the date set forth below;

D by faxing a copy thereof to each attorney's last-known facsimile number onthe date set fort below; or

rø by filing electronical~t via the cour's CMlECF system.

DATED this J po day of~~r:W08.

ROY S. HABER, P.C.

ByRoyS. HaberOSB No. 800501Direct Dial:

Direct Fax:Email:

541.485.6418541.434.6360haberpc(qcyber-dyne.com

TONKON TORP LLP

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