Case 2:11-cv-04027-LDD Document 1 Filed 06/20/11 Page 1 of 23

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF PENNSYLVANIA

P.V., a minor, by and through his

)

Parents, Pedro Valentin and Yolanda )

Cruz, individually, and on behalf of all )

others similarly situated,

) Civil Action No. _______________

)

M.M., a minor, by and through his Parent, Carla Murphy, individually, and on behalf of all others similarly situated,

) ) COMPLAINT -- CLASS ACTION ) ) )

)

J.V., a minor, by and through his

)

Parents, Sharon Vargas and Ismael )

Vargas, individually, and on behalf of )

all others similarly situated,

)

)

R.S., a minor, by and through his Parents, Heather Sanasac and Matthew Sanasac, individually, and on

) ) ) )

behalf of all others similarly situated, )

)

Plaintiffs,

)

)

v.

)

)

The School District of Philadelphia, ) )

Arlene Ackerman, Superintendent, in her official capacity as Superintendent of the School District of Philadelphia,

) ) ) )

) Linda Williams, in her official capacity )

as the Interim Deputy Chief of Special )

Education for the School District of

)

Philadelphia,

)

)

The School Reform Commission, as )

the Board of the School District of

)

Philadelphia,

) )

Defendants.

) )

)

)

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I. PRELIMINARY STATEMENT 1. This action is brought on behalf of thousands of Philadelphia school children with autism seeking elimination of an illegal policy that adversely affects them. Children with autism have difficulty with transitioning from one environment to another as a result of impairments in communication and social interaction skills. In direct conflict with this well-known difficulty of children with autism, the School District of Philadelphia (the “District”) transfers students with autism automatically from one school to another simply because they complete a certain grade. The District uses this Automatic Autism Transfer Policy (the “Policy”) to routinely assign and/or transfer students with autism, including rising third graders with autism to different schools for grades 3 through 5, and rising fifth graders with autism to different schools for grades 6 through 8 based on their status as children with autism. Non-disabled children enjoy continued and uninterrupted attendance in K-5 schools or K-8 schools. 2. The Policy, as established and as implemented, violates the purpose and intent of the Individuals with Disabilities Education Act, 20 U.S.C. § 1400 et seq. (“IDEA”) and Chapter 14 of the Pennsylvania Code (“Chapter 14”) as it occurs with little or no parental notice or involvement, without required consideration of children’s individualized circumstances, and in direct violation of the mandated individual planning process of the IDEA. Furthermore, this admitted policy of the District is based solely on the fact that the children have autism contrary to Section 504 of the Rehabilitation Act (“Section 504”), and Title II of the Americans with Disabilities Act (“ADA”). 3. Plaintiffs bring this claim on their own behalf and on behalf of all other students within the District who are or will be subjected to the District’s Policy (the “Class”). Class relief
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is necessary because of the systemic nature of the Defendants’ conduct and because the large number of children harmed by the Policy makes joinder of all Class members impracticable.
II. JURISDICTION AND VENUE 4. The claims herein arise under the IDEA, 20 U.S.C. § 1400 et seq. (2004) and 34 Code of Federal Regulations Chapter 300, Chapter 14, 22 Pa. Code § 14.1 et seq., the ADA, 42 U.S.C. § 12132 et seq., and Section 504, 29 U.S.C. § 794. This Court has subject matter jurisdiction over the federal law claims pursuant to 28 U.S.C. § 1331 and 20 U.S.C. §§ 1415(i)(2) and 1415(i)(3)(A). 5. The claims herein for declaratory and injunctive relief pending the resolution of this matter are authorized by 28 U.S.C §§ 2201 and 2202. 6. This Court may exercise supplemental jurisdiction over the state law claims pursuant to 28 U.S.C. § 1367. Chapter 14 of the Pennsylvania Code is the state special education law that must be consistent with the IDEA. 22 Pa. Code § 14.1 et seq. 7. The claims for injunctive relief in the form of enforcement of Plaintiffs’ and the Class’ right to remain in current educational placements during the pendency of this proceeding (“Stay-Put Relief”) is authorized by 20 U.S.C. § 1415(j). 8. Venue in this district is proper under 28 U.S.C. § 1391(b). 9. Plaintiffs have exhausted or are not required to exhaust administrative remedies pursuant to the IDEA, 20 U.S.C. §§ 1415(i)(2) and 1415(i)(3)(A).
a. Where, as here, a district is engaged in a policy that violates the IDEA and that is inconsistent with the individualized nature of the IDEA, such a policy can evade review through the administrative process and may properly be brought before the Court without exhaustion of administrative remedies. Honig v. Doe, 484 U.S. 305 (1988) (state suspension policy could evade review); Christopher S. v. Stanislaus County, 384 F.3d 1205 (9th Cir. 2004) (shortened school day for children with autism was policy and not subject to exhaustion of administrative remedies).
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b. Even if administrative exhaustion pursuant to the IDEA were required, which it is not, Plaintiffs P.V. and M.M. have already exhausted through the IDEA hearing process, each of them receiving a hearing officer decision dated April 15, 2011, attached hereto as Ex. A. and Ex. B. respectively. (Ex. A., P.V. v. SDP, ODR No. 01541-1011 and Ex. B., M.M. v. SDP, ODR No. 01539-1011.) In those decisions, the Hearing Officer (“H.O.”) found for the families but ordered the District to re-propose placement for the 2011-2012 school year requiring the families to again object through the administrative hearing process for a second time. The Hearing Officer stressed that with regard to the District’s Automatic Transfer Policy he “lack[ed] authority to order wholesale changes to the District’s procedures” and he “encouraged the District to alter its procedures on a broader scope.” (Ex. A. at 15; Ex. B. at 15) (emphasis added). This Complaint constitutes an appeal from the administrative proceedings by P.V. and M.M.
c. Furthermore, were administrative exhaustion pursuant to the IDEA required, Plaintiffs J.V. and R.S. and the rest of the Class are exempted from the IDEA’s usual administrative exhaustion requirement because exhaustion is clearly futile given the District’s Automatic Autism Transfer Policy and the holding of the hearing officer in the prior two cases that he does not have the power to order a District wide-systemic change, essentially requiring families to exhaust and re-exhaust indeterminably. Beth V. v. Carroll, 87 F.3d 80, 90 (3d Cir. 1996) (noting exhaustion not required where it would be futile or inadequate or where the agency cannot grant adequate relief, or where exhaustion would work a severe harm); see also R.B. v. Mastery Charter Sch., No. 2:10-cv-06722, 2010 WL 5464892, at *6 (E.D. Pa. Dec. 29, 2010). Moreover, J.V. and R.S. together filed a joint complaint with the Pennsylvania Department of Education, Bureau of Special Education about the issues of over-enrollment as they impact transfer practices. (Ex. A. at 3-5; Ex. B. at 35.) Also, J.V. and R.S. each have requested an individual hearing, though they believe that as to the Transfer Policy, the hearings are futile.
10. The Rehabilitation Act and Title II of the Americans with Disabilities Act
incorporate the remedies and procedures of Title VI of the Civil Rights Act of 1964, 42 U.S.C. §
2000d et seq. See 29 U.S.C. § 794a; 42 U.S.C. § 12133. Title VI has no exhaustion requirement.
See Herring v. Chichester Sch. Dist., No. 06-5525, 2007 WL 3287400 (E.D. Pa. Nov. 6, 2007).
III. STATUTORY FRAMEWORK
11. The IDEA requires public schools that receive federal funds to provide a free and
appropriate public education (“FAPE”) to all students with disabilities ages 3 to 21 based on the
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individual unique needs of the student and subject to certain procedural requirements to ensure meaningful parental participation in the process of the child’s education. 20 U.S.C. § 1400, § 1412(a), § 1414, § 1415, and see 34 Code of Federal Regulations Chapter § 300. The named minor Plaintiffs and Class members each qualify as “child[ren] with a disability” under the statute, and each has an Individual Education Plan (“IEP”) that governs his or her education. 20 U.S.C. § 1401(3), § 1414(d), § 1415. The District receives federal funds pursuant to the IDEA and is bound by the IDEA.
12. Each named plaintiff and Class member has an IEP Team that is comprised of parents and school staff who are to make educational decisions for the child, including school placement. The IDEA mandates that decisions about a child’s educational placement are to be made individually through the IEP team process and with the parent’s meaningful involvement. Specifically, the IDEA provides that “each local educational agency shall ensure that the parents of each child with a disability are members of any group that makes decisions on the educational placement of their child.” 20 U.S.C. § 1414(e); see also 20 U.S.C. § 1415; 34 C.F.R. § 300.327. The District’s Automatic Autism Transfer Policy constitutes a “one-size fits all” approach which is in direct conflict with the statutory framework of the IDEA which mandates parental involvement and individual planning through the IEP team process.
13. The ADA mandates that “no qualified individual with a disability shall, by reason of such disability, be excluded from participation in or be denied the benefits of the services, programs, or activities of a public entity, or be subjected to discrimination by any such entity.” 42 U.S.C § 12132. The District is a public entity within the meaning of 42 U.S.C § 1231(1). The named minor Plaintiffs and Class members are qualified individuals with a disability, protected from discrimination on the basis of their disability. 42 U.S.C. § 1231(2); 28 C.F.R. §
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35.104. The District’s Automatic Autism Transfer Policy excludes or limits children with autism from experiencing the typical school attendance procedures that non-disabled children enjoy which includes continued attendance at one elementary school or middle school until and through the last grade of said school absent a family move, disciplinary matter, or parental request for move.
14. Section 504 of the Rehabilitation Act prohibits disability discrimination in federally funded programs. It mandates that “[n]o otherwise qualified individual with a disability in the United States . . . shall, solely by reason of her or his disability, be excluded from the participation in, be denied the benefits of, or be subjected to discrimination under any program or activity receiving Federal financial assistance . . . .” 29 U.S.C. § 794(a). The District is a federal funds recipient within the meaning of 29 U.S.C. § 794(b)(2)(B). The named minor Plaintiffs and Class members are “disabled” students who were otherwise qualified to participate in school activities and who are entitled to the protection of Section 504. The District’s Automatic Autism Transfer Policy excludes or limits children with autism from experiencing the typical school attendance procedures that non-disabled children enjoy which includes continued attendance at one elementary school, or middle school until and through the last grade of said school absent a family move, disciplinary matter, or parental request for move.
IV. PARTIES 15. Nine year-old Plaintiff, P.V., is a third grader who resides with his parents, Plaintiffs Pedro Valentin and Yolanda Cruz (“Parents of P.V.”) in Philadelphia, Pennsylvania within the boundaries of the School District of Philadelphia. He attends Richmond Elementary School, a Kindergarten through Grade 5 school. P.V. has autism and receives autistic support, necessitating his access to an autism support (“AS”) classroom. P.V. is entitled to the
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protections of the IDEA and is a qualified individual with a disability entitled to the protections of the Americans with Disabilities Act and Section 504. At the end of the 2009-2010 school year, the District announced to P.V.’s parents that he would not be allowed to remain at Richmond to complete his third grade year during the 2010-2011 school year because of the District’s Automatic Autism Transfer Policy. Very shortly before the start of the 2010-2011 school year, it was not clear where P.V. should attend, so he returned to Richmond. P.V.’s family filed for an administrative hearing, requested “Stay Put” protection, and eventually secured a hearing officer’s order which resulted in P.V.’s being allowed to stay at Richmond for the completion of his third grade year. (Ex. A, P.V. v. SDP, H.O. Decision, April 15, 2011.) On June 16, 2011, once again because of the District’s Automatic Autism Transfer Policy, the District administration abruptly proposed P.V.’s move to McKinley Elementary School, which move will occur absent this complaint and appeal entitling P.V. to “Stay Put” pursuant to 20 U.S.C. § 1415(j). In stark contrast, non-disabled rising fourth graders are not required to transfer from Richmond Elementary or other K-5 schools in the District.
16. Nine year-old Plaintiff M.M. is currently a third grade student who resides with his parent, Plaintiff Carla Murphy (“Parent of M.M”) in Philadelphia, Pennsylvania within the boundaries of the School District of Philadelphia. He attends Richmond Elementary School. M.M. has autism and receives autistic support, necessitating his access to an autism support classroom. M.M. is entitled to the protections of the IDEA and is a qualified individual with a disability entitled to the protections of the ADA and Section 504. In late spring 2010, the District advised M.M.’s mother via his home-school notebook that he would not be allowed to remain at Richmond to complete his third grade year during the 2010-2011 school year because of the District’s Automatic Autism Transfer Policy. In the fall of 2010, it was not clear where
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M.M. was to attend school, so M.M. returned to Richmond. In early September 2010, M.M.’s family filed for an administrative hearing, requested “Stay Put” protection, and eventually secured a hearing officer’s order which resulted in M.M.’s being allowed to stay for the completion of the year. (Ex. B, M.M. v. SDP, H.O. Decision, April 15, 2011.) As of the filing of this complaint, Ms. Murphy presently does not know if M.M. will be allowed to return to Richmond for his fourth grade year, absent this complaint and appeal entitling M.M. to “Stay Put” pursuant to 20 U.S.C. § 1415(j). Nondisabled rising fourth graders are not required to transfer out of Richmond Elementary School or other K-5 schools in the District.
17. Eight year-old Plaintiff J.V. is currently a second grade student who resides with his parents, Plaintiffs Sharon Vargas and Ismael Vargas (“Parents of J.V.”) in Philadelphia, Pennsylvania within the boundaries of the District. He currently attends Richmond Elementary School, a Kindergarten through Grade 5 school. J.V. has autism and receives autistic support, necessitating his access to an autism support classroom. There is no dispute that J.V. is entitled to the protections of the IDEA and is a qualified individual with a disability entitled to the protections of the Americans with Disabilities Act and Section 504. As of the filing of this complaint, J.V.’s parents have received no Notice of Recommended Educational Placement/Prior Written Notice (“NOREP/PWN”) that J.V. will be allowed to return to Richmond for the 20112012 school year, absent their acceptance of a “settlement” offer made by the District in connection with a due process complaint that is currently pending. In contrast, non-disabled rising third graders are not required to leave Richmond, a K-5 school.
18. Eight year-old Plaintiff R.S. is a second grade student who resides with his parents, Heather Sanasac and Matthew Sanasac in Philadelphia, Pennsylvania within the boundaries of the District. He is presently attending Richmond Elementary School. R.S. has
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autism and receives autistic support, necessitating his access to an autism support classroom. R.S. is entitled to the protections of the IDEA and is a qualified individual with a disability entitled to the protections of the Americans with Disabilities Act and Section 504. As of the filing of this complaint, R.S. has not received written confirmation through a Notice of Recommended Placement/Prior Written Notice (“NOREP/PWN”) that he will be allowed to return to Richmond, absent a “settlement” offer made by the District in connection with a due process complaint that is currently pending. In contrast, non-disabled rising third graders are not required to leave Richmond, a K-5 school.
19. Defendant, the School District of Philadelphia, is a school district within the Commonwealth Pennsylvania organized pursuant to the Public School Code of 1949, Act of March 10, 1949, P.L. 30, as amended, 24 P.S. 1-101 et seq. The District’s headquarters and principal place of business is located at 440 N. Broad Street Philadelphia, Pennsylvania. The District is the Local Educational Agency responsible to ensure that Plaintiffs receive a free appropriate public education pursuant to the IDEA and Chapter 14. The District also operates as Intermediate Unit 26. The District, as a public entity, receives federal funds and is subject to the Americans with Disabilities Act and Section 504.
20. Defendant School Reform Commission (“SRC”) is the five member governing body of the District. It acts as the School Board and was established in December 2001 when oversight of the School District shifted to the Commonwealth of Pennsylvania. The SRC chairman, Robert L. Archie, Jr. can be contacted at the District’s headquarters, at 440 N. Broad Street, Suite 101, Philadelphia, Pennsylvania.
21. Defendant Arlene Ackerman is the Superintendent of the School District of Philadelphia and is named herein in her official capacity. Ackerman is responsible for the
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effective operation of the District and the implementation of policies and procedures adopted by the District and the SRC.
22. Defendant Linda Williams is the Interim Deputy Chief of Special Education of the School District of Philadelphia and is named herein in her official capacity. Williams is directly responsible for the District’s compliance with the requirements of the IDEA and Chapter 14.
V. CLASS ACTION ALLEGATIONS 23. Plaintiffs bring this suit individually and as a Class Action pursuant to Fed. R. Civ. P. 23(b)(2) and 23(b)(3) on behalf of all similarly situated individuals. The Class that Plaintiffs seek to represent is composed of: All children with autism in the School District of Philadelphia in grades kindergarten through eight (“K-8”) who have been illegally transferred, are in the process of being transferred, or are at risk of being illegally transferred, as a result of the District’s Automatic Autism Transfer Policy, the parents and guardians of those children, and future members of the class. 24. The Class is so numerous that joinder of all members is impracticable. Currently, there are at least 3,000 to 4,0001 students in autism support classes in the District and thousands more that will be affected by the Automatic Autism Transfer Policy in the future. The exact number of Class members is not fully known to Plaintiffs at present but can be ascertained by Defendants. Despite repeated requests for the number of students in autism support classes and a list of where those classes are located, the District has declined to provide exact information. Upon information and belief, based upon testimony of District staff during administrative hearings, there are approximately 60 autism support classrooms within the District, which
1 Upon information and belief, there may be even more children with autism in the District. The number quoted is in reliance on the oral testimony of District representative Maria Monras-Sender during a recent hearing involving J.V.
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include autism support classrooms for children grades K-2, 3-5, and 6-8. As recently as June 16, 2011, during a meeting with District representatives and their counsel, the District indicated that it did not have a list of the locations of autism support classrooms within the District.
25. There are questions of law and fact common to the Class and that predominate over any questions affecting only individual members of the Class. Specifically, there are questions as to the legality of Defendants’ systemic acts or omissions with respect to the District’s autism support programs, as a result of the impact of the District’s Automatic Autism Transfer Policy, under the IDEA, Chapter 14, Section 504, and the ADA.
26. Plaintiffs’ claims are typical of the claims of the Class as all members are similarly affected by Defendants’ conduct in violation of the law that is complained of herein.
27. Plaintiffs will fairly and adequately protect the interests of the Class. 28. Counsel for Plaintiffs are experienced in handling federal class action litigation and will adequately and zealously represent the interests of the Class. The Public Interest Law Center has litigated many federal class actions to protect the civil rights of persons and children with disabilities. Dechert LLP is likewise experienced in complex federal litigation. 29. Defendants have acted or refused to act on grounds that apply generally to the Class, so that final injunctive relief or declaratory relief is appropriate respecting the Class as a whole. P.V. and M.M. filed administrative hearings in early September 2010 challenging the legality of the District’s Automatic Transfer Policy. On April 15, 2011, the District was warned by an IDEA administrative hearing officer that it should “alter its procedures [regarding transfers of children with autism] on a broader scope, if only to avoid a plethora of identical claims from similarly situated students.” (Ex. A. at 15; Ex. B. at 15) (emphasis added). The same hearing officer believed his authority was limited, thus precluding his ability to decide whether “the
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District’s AS [“autistic support”] programs as a whole are structurally flawed.” (Ex. A. at 3; Ex. B at 3.) In May 2011, the District received J.V.’s hearing request and admitted that it still had no Grade 3-5 Autism Support classroom at Richmond Elementary School. As of June 16, 2011, despite the hearing officer’s pronouncements, the District would not confirm abandonment of the faulty Automatic Autism Transfer Policy and proposed transfer (again) of P.V. The District appears committed to the Policy as a matter of administrative convenience.
30. A class action is superior to any other available method for fairly and efficiently adjudicating this controversy in that there is no interest by members of the Class in individually controlling the prosecution of separate actions; upon information and belief no similar litigation concerning the claims herein has already begun by any Class member; it is desirable to concentrate the litigation of the claims made herein in a single proceeding; and whatever difficulties may exist in the management of the Class will be greatly outweighed by the class action process, including, but not limited to, providing Class members with a method for redress of claims more fairly, efficiently, and consistently than individual litigation may provide.
31. It would be futile to require Plaintiffs to exhaust or re-exhaust administrative remedies since the District has adopted a systemic policy of transferring children with autism, and as a result Pennsylvania’s special education administrative hearing system cannot, as expressly noted by the hearing officer, adequately remedy the systemic problem. Furthermore, upon information and belief, there are not enough special education hearing officers available to timely handle the number of due process hearing requests that would be necessary.
32. Plaintiffs P.V. and M.M. seek no individual compensatory education relief pursuant to the IDEA as they have been awarded compensatory education for their loss of educational benefit by the hearing officer’s decisions. They seek only to have the Policy
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declared illegal so that they will no longer be subject to it and will instead be treated fairly within the IDEA process as to their placements in future years.
33. Plaintiffs J.V. and R.S. seek to have the Policy declared illegal so that they will no longer be subject to it and will instead be treated fairly within the IDEA process as to their placements for third grade and in future years. Any individual compensatory education relief to which they are entitled can be ordered by a hearing officer and they have requested relief from same in the hearings now pending. The hearing officers assigned, will not, however, be able to provide them relief from being subjected to the illegal Policy now or in the future.
VI. FACTS The Automatic Autism Transfer Policy And The Hearing Officer’s Decisions Of April 15, 2011 34. Each of the named Plaintiffs and the rest of the Class have been subjected to and continue to be adversely affected by the District’s Automatic Autism Transfer Policy. 35. The District operates schools that serve children grades K-5 and K-8. Nondisabled children who attend a K-5 school or a K-8 school are not transferred unless the family moves, a transfer is requested, or the child is transferred for disciplinary reasons. 36. The District maintains autism support classrooms throughout the District in its K5 and K-8 schools. In the District, elementary autism support classes are divided based on age, specifically, Kindergarten through Second Grade (“K-2”) and Grade Three through Grade Five (“3-5”). The District has some Grade six through Grade eight (“6-8”) autism support classes. 37. The K-2, 3-5 and 6-8 autism support classrooms are randomly placed throughout the District. The exact number and location of autism support classrooms is not known at this
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time. However, it is known that a K-5 school may not have both a K-2 and 3-5 autism support classroom and a K-8 school may not have autism support classrooms for K-2, 3-5 and 6-8.2
38. Children with autism are transferred from one school to another school under the Automatic Autism Transfer Policy without regard to their individual unique needs, without parental notice or participation, and outside of the IEP team process. Individuals other than the child’s teacher or even school principal make the transfer decision. For example, pursuant to the District’s Automatic Autism Transfer Policy, second graders in autism support placements are regularly forced to move to different schools for third grade while their non-disabled peers can continue on in their same schools until fifth grade (if a K-5 school) or eighth grade (if a K-8 school). These students with autism are forced to move solely because of their disability.
39. According to the District’s website, there are more than 54 K-2 autism support classes in the District and an unknown number of 3-5 autism support classes. However, upon information and belief, there are few K-5 schools or Kindergarten through Eighth grade (“K-8”) schools that have both a K-2 and 3-5 autism support classroom. District representatives assert that there are K-8 schools with a K-2, 3-5 and 6-8 classroom, but the only one identified by those representatives, McKinley Elementary School (a K-8) school was visited by the parents and does not currently have a 6-8 classroom.
40. Richmond Elementary School, a K-5 school, contains one K-2 autistic support classroom, but no 3-5 autistic support classroom. On May 5 and May 25, 2011, in answers to hearing requests from J.V. and R.S., the District twice stated that it had no 3-5 classroom at Richmond and defended its failure to have a 3-5 classroom. Recently, in June 2011, presumably
2 For example, District representatives have asserted that McKinley Elementary School, a K-8 school “will have” a K-2, 3-5 and 6-8 autism support classroom. The latest plans submitted to the Pennsylvania Department of Education list McKinley as having only a K-2 and two 3-5 classrooms.
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in response to the hearing officer’s decision, District administrators suggested that they intend to develop a 3-5 autistic support classroom there during 2011-2012. However, no teacher has been hired to date and no 3-5 teachers have been trained to support inclusive opportunities for children who would attend a 3-5 autistic support classroom at Richmond. Furthermore, District administrators have proposed moving P.V. from Richmond Elementary School which is inconsistent with the creation of a 3-5 autistic support classroom at Richmond. Upon information and belief, there are other elementary schools in the District that contain either a K-2 autistic support classroom or a 3-5 autistic support classroom, but not both.
41. The District has wholly admitted to its practice of setting up K-2 autism support programs in schools separate from the 3-5 autism support programs and to implementing the Automatic Autism Transfer Policy, regardless of the fact that violates applicable federal and state law. The Hearing Officer found that in Richmond, non-disabled children start in kindergarten and transfer to another building after fifth grade unless the family moves, the parents request a building transfer or the student is moved for disciplinary reasons, but that students who require an autism support classroom are upper leveled after second grade because there is no 3-5 autism support classroom in that building. (Ex. A at 5; Ex. B at 5.)
42. Some of the details of the Automatic Autism Transfer Policy were explored at the joint administrative hearings for P.V. and M.M. that was held from December 2010 through February 2011, including the testimony of Maria Monras-Sender, the Executive Director of the Office of Specialized Instruction (“OSIS”), Cathy Roccia-Meier of the Philadelphia Right to Education Local Task Force, Anthony Ciampoli, Principal of Richmond Elementary School, and Leah Taylor, Special Education Teacher at Richmond Elementary School.
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43. In the hearing decisions for P.V. and M.M., both dated April 15, 2011, Hearing Officer Ford found that “the District violated the Parents’ right to participation by reassigning the Student to a different school building without sending IDEA-compliant prior written notice.” The Hearing Officer further stated: “Although the Hearing Officer lacks authority to order wholesale changes to the District’s procedures, it is well within the Hearing Officer’s authority to compel the District to issue a NOREP and a Procedural Safeguards Notice every time it proposes a building reassignment for this Student.” (Ex. A at 15, Ex. B at 15.)
44. At the administrative hearings for P.V. and M.M. Executive Director MonrasSender admitted that the District does not even maintain a list of the schools that have K-2 or 3-5 autism support classes. (Transcript of Due Process Hearing Proceedings for M.M. and P.V. (“Hearing Tr.”), vol. 3, 487-89, Feb. 4, 2011.)
45. Ms. Monras-Sender testified that the District does not transfer non-disabled rising third graders to different schools. (Hearing Tr. vol. 3, 477, Feb. 4, 2011). Furthermore, it already has been found in the administrative hearing process that “[w]hen a [typical] student in the District reaches the end of his or her building age level, he or she is moved to another building.” This is simply not the case for children with autism because of the Automatic Autism Transfer Policy. As has been found in the administrative hearing process, at Richmond for example, “non-disabled children start in kindergarten and transfer to another building after fifth grade unless the family moves, the parents request a building transfer or the student is moved for disciplinary reasons.” (Ex. A at 5; Ex. B at 5.)
46. Ms. Monras-Sender acknowledged that when a child with autism is transferred to a new building for third grade, there is no way for either a parent or an IEP team to appeal the building placement. (Hearing Tr. vol. 3, 547, Feb. 4, 2011.)
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47. Ms. Monras-Sender conceded that if there was list of all the locations of the K-2 and 3-5 classes that “there’s no reason that a list cannot be provided” to the parents. (Hearing Tr. vol. 3, 487-89, Feb. 4, 2011.)
48. As a result of Pennsylvania Ass’n for Retarded Children (PARC) v. Commonwealth, 334 F. Supp. 1257 (E.D. Pa. 1971), Philadelphia has a Right to Education Local Task Force. The Philadelphia Right to Education Local Taskforce’s website is found at www.philadelphialtf.org. On or about 2004, the Philadelphia Right to Education Local Task Force specifically informed the District that its system of scattered K-2, 3-5 and 6-8 classes interrupted the K-5 and K-8 experience of children with autism and that such policy is contrary to appropriate programming for children with autism. Cathy Roccia-Meier of the Local Task Force testified at the P.V. and M.M. hearings that “one of the major recommendations [of the Task Force] was that any school that had an autistic support program should cover the grade ranges of students in that school. If it’s K to 8, we recommended it be K to 8. If it was K to 5, it should be K to 5, of course, because transition is one of the most difficult areas for students with disabilities.” (Hearing Tr. vol. 1, 38-39, Dec. 10, 2010) (emphasis added).
49. The District is aware that its Policy has been criticized by the Right to Education Local Task Force, but has done nothing in the past seven years to fix the problem. (Hearing Tr. vol. 3, 493, Feb. 4, 2011.)
50. District Special Education Administrator Ms. Monras-Sender testified that she favors continuity of services and programming for children with autism. (Hearing Tr. vol. 3, 494, 533-34, Feb. 4, 2011.)
51. Ms. Monras-Sender admitted that the District has no specific plan to provide continuity of services for children with autism. (Hearing Tr. vol. 3, 495, Feb. 4, 2011.)
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52. As late as May 25, 2011, the District admitted that “it has not made a decision yet whether Richmond will have an AS classroom that would serve third graders for the 2011-2012 school year.” (District’s Answer, May 25, 2011.)
53. Instead of involving parents in the process to determine even where a child would be transferred, through the mandated IEP team process, administrators or their staff who are not part of the IEP team and often who have never met the child unilaterally make transfer decisions without even first consulting with parents and the IEP team, including the child’s teacher. “Both IEPs and NOREPs specify the building that the Student is [currently] assigned to” yet “[n]either a NOREP nor a procedural safeguards letter is sent” before transferring the child. (Ex. A at 6; Ex. B at 6.) The District takes the position that parents have no right to be involved in or even be timely informed of the location of their child’s services.
54. In addition to the per se illegal nature of the Automatic Autism Transfer Policy, there are additional negative consequences to children with autism as a result of the haphazard nature of the District’s placement of autistic support classrooms throughout the District. Children with autism are relegated to classrooms that are over-enrolled and that lack sufficiently trained staff and resources to ensure inclusive opportunities for children with autism, and children with autism are frequently not educated in the Least Restrictive Environment. In both P.V. and M.M.’s case, they were denied access to regular education settings as a result of overenrollment, insufficient staff and insufficiently trained staff. In J.V. and R.S.’s case, their parents filed complaints with the Pennsylvania Department of Education, Bureau of Special Education. (Ex. A at 3; Ex. B at 3). Richmond Elementary School’s special education autism support teacher, Leah Taylor, forthrightly testified that her K-2 autism support classroom at Richmond Elementary School was over-enrolled in December 2010 and has been for the past
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Case 2:11-cv-04027-LDD Document 1 Filed 06/20/11 Page 19 of 23
three years. (Hearing Tr. vol. 1, 109-10, Dec. 10, 2010.) Ms. Taylor noted that over-enrollment causes her to be “spread too thin” (Hearing Tr. vol. 1, 128, Dec. 10, 2010) and that the children would be making more progress if her class was not over-enrolled. (Hearing Tr. vol. 2, 414, Feb. 3. 2011.) Despite the District’s suggestion that it might create a 3-5 classroom at Richmond Elementary School, the District has failed to take any necessary steps to ensure District-wide that children with autism who are grades K-8 would have access to regular education classrooms with sufficient staff and resources, or taken any steps to ensure that over-enrollment does not continue as a result of the haphazard Automatic Autism Transfer Policy.
VII. LEGAL CLAIMS Count One: Violation of the Individuals with Disabilities Education Act 55. Plaintiffs incorporate the preceding paragraphs of this Complaint as if set forth in full herein. 56. The District’s Automatic Autism Transfer Policy is established and implemented in a manner that is completely contrary to the IDEA because the decisions about the placement of children into different schools and classes are made without regard to the individual unique needs of each child, substantially infringe upon meaningful parental involvement in the process and are made wholly outside of the procedural safeguards and requirements of the IDEA. 20 U.S.C. § 1414(d); 20 U.S.C. § 1415. 57. Wherefore, Plaintiffs and the Class demand judgment in their favor and against Defendants for declaratory and injunctive relief set forth herein.
Count Two: Violation of Chapter 14 58. Plaintiffs incorporate the preceding paragraphs of this Complaint as if set forth in full herein.
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59. The District’s Automatic Autism Transfer Policy is established and implemented in a manner that is completely contrary to the IDEA because the decisions about the placement of children into different schools and classes are made without regard to the individual unique needs of each child, substantially infringe upon meaningful parental involvement in the process and are made wholly outside of the procedural safeguards and requirements of Chapter 14. The Policy is contrary as well to the requirements of Chapter 14 of the Pennsylvania Code, specifically Section 14.145 that children be educated in the least restrictive environment.
60. Wherefore, Plaintiffs and the Class demand judgment in their favor and against Defendants for declaratory and injunctive relief set forth herein.
Count Three: Violation of the Americans with Disabilities Act 61. Plaintiffs incorporate the preceding paragraphs of this Complaint as if set forth in full herein. 62. The Defendants have violated the rights of the Plaintiffs and Class by the establishment and implementation of the Automatic Autism Transfer Policy resulting in the random assignment of students into various autistic support classes. By requiring the Plaintiffs and Class to transfer to different schools at ages when non-disabled students are not required to transfer to new schools because of age, the District has discriminated against the Plaintiffs and Class because of their disability of autism. 63. Wherefore, Plaintiffs and the Class demand judgment in their favor and against Defendants for declaratory relief, injunctive relief, and damages set forth herein.
Count Four: Violation of Section 504 of the Rehabilitation Act 64. Plaintiffs incorporate the preceding paragraphs of this Complaint as if set forth in full herein.
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65. The Defendants violate Plaintiffs’ and the Class’ Section 504 rights by requiring students with autism to transfer to a different school at a certain age solely because they are disabled as a result of autism. The Defendants have admitted that non-disabled students are not subjected to the Policy.
66. Wherefore, Plaintiffs and the Class demand judgment in their favor and against Defendants for declaratory relief, injunctive relief, and damages set forth herein.
VIII. RELIEF REQUESTED WHEREFORE, Plaintiffs request that: 1. The Court take jurisdiction of this matter, and certify the matter as a Class Action. 2. Order that the “The Automatic Autism Transfer Policy” is illegal, and contrary to the
IDEA, Section 504, the ADA, and may no longer be used. 3. Order that the named plaintiffs are protected pursuant to the IDEA’s “Stay Put”
provision at 20 U.S.C. § 1415(j) and permit them to stay in their placements unless otherwise agreed by the parents and the District. 4. Order that the District immediately create and publicly disseminate a list of all of the schools within the District that house any autistic support classroom for grades K-8 (K-2, 3-5, or 6-8). This list shall be provided to the Philadelphia Right to Education Local Task Force. 5. Order that consistent with the IDEA’s IEP process provisions discussed supra, the District will establish a new written plan and pattern and policy to provide continuity of programming for students with autism. The plan shall be developed with parental involvement. The plan shall provide that as the District develops or changes classrooms, the District shall ensure that any school which contains an autism support
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Case 2:11-cv-04027-LDD Document 1 Filed 06/20/11 Page 22 of 23 classroom shall offer autism programming for the same years that the school provides programming for children who are not disabled. Such programs shall cover grades K8 to provide the same opportunity for meaningful integration into the school community for students with autism as their non-disabled peers.
6. Order that consistent with IDEA parental participation requirements, the District maintain an accurate list of where the autism support classes are currently located and this list be published annually and provided to parents of children with autism at each IEP meeting so that they may be involved in the process to determine where their child will attend school.
7. Order that consistent with IDEA parental participation/prior written notice requirements that an IEP meeting shall be held and a Notice of Recommended Educational Placement/Prior Written Notice shall be issued indicating what school the child will attend before reassigning a child with autism to another school;
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Case 2:11-cv-04027-LDD Document 1 Filed 06/20/11 Page 23 of 23

8. Award to Plaintiffs their costs and attorneys fees; and 9. Grant such other and further relief as may be just and proper.

Dated: June 20, 2011

Respectfully,
Sonja Kerr (I.D. No. 310800) skerr@pilcop.org
PUBLIC INTEREST LAW CENTER OF PHILADELPHIA 1709 Benjamin Franklin Parkway, Second Floor Philadelphia, PA 19103 Telephone: (215) 627-7100 Facsimile: (215) 627-3183 Co-Counsel for Plaintiffs
Cheryl Krause (I.D. No. 90297) cheryl.krause@dechert.com
Tara L. Kelly (I.D. No. 201822) tara.kelly@dechert.com
Darla D. Woodring (I.D. No. 306866 ) darla.woodring@dechert.com
DECHERT LLP Cira Centre 2929 Arch Street Philadelphia, PA 19104-2808 Telephone: (215) 994-4000 Facsimile: (215) 994-2222 Co-Counsel for Plaintiffs

23

 </s> IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF PENNSYLVANIA

P.V., a minor, by and through his Parents, Pedro Valentin and Yolanda Cruz, individually, and on behalf of all others similarly situated, et al.,
Plaintiffs,
v.
The School District of Philadelphia, et al.
Defendants.

: CIVIL ACTION : : : : : : : : : NO. 2:11-cv-04027 : :

MEMORANDUM

Legrome D. Davis, J.

October 31, 2011

I. Factual Background and Procedural History This lawsuit concerns the School District of Philadelphia’s (the “District”) treatment of,
and policies governing, school children with autism. The four (4) named plaintiffs in the purported class action Complaint, P.V., M.M., J.V., and R.S., are all autistic second- or third-grade students at Richmond Elementary School, a Kindergarten through Grade 5 (“K-5") school in the District. (Doc. No. 1 ¶¶ 15-18). Plaintiffs contend that the District transfers students with autism automatically from one school to another, simply because they complete a certain grade, more frequently than the District transfers non-disabled students who therefore, unlike autistic children, enjoy continued, uninterrupted attendance in K-5 schools or K-8 schools. (Doc. No. 1 ¶ 1). This is

1

particularly problematic because children with autism have difficulty transitioning from one environment to another. (Doc. No. 1 ¶ 1). Plaintiffs’ Complaint alleges that the District transfers autistic students with little or no parental notice or involvement, and without the required consideration of the children’s individualized circumstances. (Doc. No. 1 ¶ 2). Plaintiffs style these transfers as an “Automatic Autism Transfer Policy” (the “Policy”), a characterization that Defendants vigorously dispute. (Doc. No. 1 ¶ 1; Doc. No. 12, at 10 (arguing that the alleged “Automatic Autism Transfer Policy” does not exist)).
According to Plaintiffs, the District’s Policy violates the Individuals with Disabilities Education Act, 20 U.S.C. §§ 1400 et seq. (“IDEA”), Chapter 14 of the Pennsylvania Code, Section 504 of the Rehabilitation Act, and Title II of the Americans with Disabilities Act (“ADA”). Plaintiffs seek relief on their own behalf, as well as class relief on behalf of all other students within the District who are or will be subject to the Policy. (Doc. No. 1 ¶ 3). The plights of the four (4) named plaintiffs are said to illustrate the effect of the District’s Policy on children with autism.
P.V., a third grader with autism, attends Richmond Elementary School. At the end of the 2009-10 school year, the District announced to P.V.’s parents that P.V. would not be allowed to remain at Richmond to complete third grade during the 2010-11 school year. (Doc. No. 1 ¶ 15). P.V.’s family filed for an administrative hearing, requested “Stay Put” protection, and eventually secured a hearing officer’s order which resulted in P.V.’s being allowed to attend Richmond for third grade. (Id.) On June 16, 2011, the District proposed transferring P.V. to McKinley Elementary School for fourth grade. In contrast, the District does not require non-disabled rising fourth graders to transfer from Richmond Elementary or other K-5 schools in the District. (Id.)
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Like P.V., M.M. is a third grader with autism who attends Richmond Elementary School. (Doc. No. 1 ¶ 16). In late spring of 2010, the District advised M.M.’s mother via his home-school notebook that he would not be allowed to remain at Richmond for his third grade year during the 2010-11 school year. (Id.) In early September, 2010, M.M.’s family filed for an administrative hearing and secured a hearing officer’s “Stay Put” order which resulted in M.M.’s being allowed to stay at Richmond to complete third grade. (Id.) At the time Plaintiffs filed their Complaint, M.M.’s mother did not know if M.M. would be allowed to return to Richmond for his fourth grade year. (Id.)
Plaintiff J.V. is a second grader with autism who attends Richmond Elementary School. (Doc. No. 1 ¶ 17). As of the filing of the Complaint in this matter, J.V.’s parents had received no Notice of Recommended Educational Placement / Prior Written Notice (“NOREP/PWN”) that J.V. will be allowed to return to Richmond for the 2011-12 school year, absent their acceptance of a “settlement” offer made by the District in connection with a due process complaint that is currently pending. (Id.)
Finally, Plaintiff R.S., like Plaintiff J.V., is a second grader with autism who attends Richmond Elementary School. (Doc. No. 1 ¶ 18). Similar to J.V., as of the filing of the Complaint, R.S.’s parents had received no Notice of Recommended Educational Placement / Prior Written Notice (“NOREP/PWN”) that R.S. will be allowed to return to Richmond, absent their acceptance of a “settlement” offer made by the District in connection with a due process complaint that is currently pending.1 (Id.)
1According to Defendants, the District has now offered all four named plaintiffs a placement in Richmond Elementary’s new 3-5 autism support classroom until the fifth grade.
(continued...) 3

These four (4) plaintiffs brought this suit against the School District of Philadelphia; the School Reform Commission; Arlene Ackerman, Superintendent of the School District of Philadelphia, in her official capacity; and Linda Williams, Interim Deputy Chief of Special Education for the School District of Philadelphia, in her official capacity, seeking various forms of relief from the allegedly illegal “Automatic Autism Transfer Policy.” (Doc. No. 1, at 21-23). Most broadly, Plaintiffs ask the Court to declare that the Policy violates IDEA, Section 504, and the ADA, and may no longer be used. (Doc. No. 1, at 21). Plaintiffs emphasize that they cannot obtain this structural relief through an administrative hearing, so judicial intervention is necessary. Specifically, Brian Jason Ford, the hearing officer presiding over P.V.’s and M.M.’s administrative hearings, concluded that “the District violated the Parent’s right to participation by reassigning the Student [P.V. and M.M.] to a different school building without sending IDEA-compliant prior written notice.” (Doc. No. 1-4, at 15; Doc. No. 1-5, at 15). However, Ford noted that he “lacks authority to order wholesale changes to the District’s procedures,” so he merely encouraged the District “to alter its procedures on a broader scope, if only to avoid a plethora of identical claims from similarly situated students.” (Doc. No. 1-4, at 15; Doc. No. 1-5, at 15).
Also on a broad scale, Plaintiffs request that we order the District to (1) create, maintain, and publicly disseminate a list of all the schools within the District that house any autistic support classroom; (2) develop a new policy, with parental involvement, to provide continuity of programming for students with autism; and (3) conduct Individualized Education Program (“IEP”) meetings, again with parental involvement, before reassigning a child with autism to another
1
(...continued) (Doc. No. 11, at 21).
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school (Doc. No. 1, at 22). More narrowly, Plaintiffs additionally request that we order the District to permit them to remain at Richmond Elementary unless otherwise agreed by the Plaintiffs’ parents and the District. (Doc. No. 1, at 21).
Procedurally, this matter remains in its infancy. Defendants have not yet filed an answer to Plaintiffs’ Complaint, we have not issued a scheduling order, discovery has not yet begun, and neither party has moved for class certification under Rule 23.2 At this early stage of the proceedings, Defendants have moved to strike Plaintiffs’ class action allegations (Doc. No. 12), and to dismiss Plaintiffs’ claims against all defendants pursuant to Federal Rule of Civil Procedure 12(b)(1) and the claims against the individual, official capacity defendants pursuant to Rule 12(b)(6). (Doc. No. 11). Plaintiffs oppose the motions, which are now ripe for disposition. For the reasons discussed below, we deny Defendants’ motion to strike and motion to dismiss. II. Legal Analysis
A. Motion to Strike Class Action Allegations According to Federal Rule of Civil Procedure 23(d)(1)(D), formerly Rule 23(d)(4), a court may “require that the pleadings be amended to eliminate allegations about representation of absent persons and that the action proceed accordingly” in conducting a class action. One leading treatise describes the close interaction of this provision with the class certification decision: Subdivision (d)(4) [now (d)(1)(D)] is procedurally inseparable from subdivision (c)(1)(A), which provides that “when a person sues or is sued as a representative of a class, the court must—at an early practicable time—determine by order whether to certify the action as a class action.”
After a determination has been made that a class action is not proper under Rule 23(c)(1), courts typically issue
2Pursuant to our Order of September 28, 2011 (Doc. No. 15), Plaintiffs have thirty (30) days from the conclusion of discovery to move for class certification in this matter.
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, an order requiring that the pleadings be amended to reflect that decision although this often is done without reference to Rule 23(d)(4) [now (d)(1)(D)]. 7B Charles Alan Wright, Arthur R. Miller, Mary Kay Kane, & Richard L. Marcus, Federal Practice & Procedure § 1795 (3d ed. 2011) (emphasis added). This description of Rule 23(d)(1)(D) suggests that, in general, a court should wait to resolve a motion to strike class allegations until someone moves for class certification. Another well-respected treatise agrees, noting that, while a “motion to strike class action allegations may properly be filed before plaintiffs have filed a motion for class certification,” “[i]f the viability of a class depends on factual matters that must be developed through discovery, a motion to strike will be denied pending the full-blown certification motion.” 1 Joseph M. McLaughlin, McLaughlin on Class Actions § 3:4 (7th ed. 2010). While the Third Circuit Court of Appeals has not yet directly addressed this issue, district courts in the Third Circuit typically deny as premature motions to strike class action allegations filed before the plaintiff moves for class certification. For example, in Korman v. Walking Co., 503 F. Supp. 2d 755 (E.D. Pa. 2007), the Eastern District of Pennsylvania observed that a “motion to strike class allegations under Rule 23(d)(4) seems, for all practical purposes, identical to an opposition to a motion for class certification.” Id. at 762. The Korman court denied the defendant’s motion to strike class allegations as premature, concluding that there was “no good reason for this case not to proceed down the normal path, i.e., with the Court setting a deadline for Plaintiff to file a motion for class certification and the parties litigating the propriety of maintaining the action as a class under the traditional Rule 23(c) rubric.” Id. at 763. Similarly, in NBL Flooring, Inc. v. Trumball Ins. Co., Civil Action No. 10–4398, 2011 WL 4481918 (E.D. Pa. Sept. 27, 2011), the Eastern District of Pennsylvania denied the
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defendants’ motion to strike class allegations “because Defendants have not established that this case is among ‘the rare few where the complaint itself demonstrates that the requirements for maintaining a class action cannot be met.’” Id., at *1-2 (quoting Landsman & Funk PC, 640 F.3d at 93 n.30). In analyzing the issue, the NBL Flooring court cautioned that “[a] motion to strike should not be granted when it is in the nature of an opposition to class certification, or if discovery is a necessary prerequisite to determining whether class certification is appropriate.” Id., at *1.
Many other Third Circuit district court decisions also view pre-certification motions to strike class allegations as premature. See, e.g., Mills v. Serv. First Credit Union, Civil Action No. 4:11–CV–686, 2011 WL 3236313, at *1 (M.D. Pa. July 28, 2011) (concluding that “the instant case is not one of the ‘rare’ or ‘few’ cases in which the court should dismiss or strike class claims with no discovery, solely on the basis of the pleadings,” especially in light of the Third Circuit’s “emphasi[s] [on] the importance of discovery as part of the class certification process.”); Vlachos v. Tobyhanna Army Depot Fed. Credit Union, Civil Action No. 3:11–CV–0060, 2011 WL 2580657, at *2 (M.D. Pa. June 29, 2011) (denying defendants’ motion to strike class allegations as premature because the plaintiff had not yet moved for class certification); Martin v. Ford Motor Co., 765 F. Supp. 2d 673, 680-81 (E.D. Pa. 2011) (holding that “[i]t would be premature to address the merits of Defendant’s Motion [to strike class allegations] before a motion to certify a class is filed or even when discovery on this issue may be ongoing.”).
Courts have good reason to decline to hastily strike class action allegations early in the litigation life cycle. Specifically, unless the parties have completed discovery and at least one
7

party has moved for class certification, a court very rarely has the information necessary to
conduct the “rigorous analysis” inherent in the class certification decision. The Third Circuit
recently articulated its concern with premature class certification in Landsman & Funk PC v.
Skinder-Strauss Associates, 640 F.3d 72 (3d Cir. 2011). In Landsman & Funk, the Third Circuit
disapproved of the district courts’ premature class certification decision at the motion to dismiss
stage when there had been no motion for class certification and no discovery. See id. at 93. The
Landsman & Funk court reasoned that such an early, uninformed evaluation of class certification
in conjunction with a motion to dismiss did not comport with the “rigorous analysis” required to
resolve every class certification question:
To determine if the requirements of Rule 23 have been satisfied, a district court must conduct a “rigorous analysis.” In doing so, a “court may ‘delve beyond the pleadings to determine whether the requirements for class certification are satisfied.’”...In most cases, some level of discovery is essential to such an evaluation. In Weiss v. Regal Collections, 385 F.3d 337 (3d Cir.2004), we emphasized the importance of discovery as part of the class certification process. “It seems appropriate,” we said, “that the class action process should be able to ‘play out’ according to the directives of Rule 23 and should permit due deliberation by the parties and the court on the class certification issues.” Accordingly, “[a]llowing time for limited discovery supporting certification motions may ... be necessary for sound judicial administration.”
Landsman & Funk, 640 F.3d at 93 (internal citations omitted).
Here, Defendants have not convinced us that this is one of the rare cases in which we
should entertain a motion to strike class allegations before discovery even begins. As discussed
supra, Plaintiffs’ Complaint alleges that the District operates pursuant to an “Automatic Autism
Transfer Policy” under which the District transfers autistic students from one school to another,
with little or no parental notice or involvement, more frequently than the District transfers non-
disabled students. Defendants vehemently deny the existence of any such policy, stating that
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“plaintiffs use the phrase ‘Automatic Autism Transfer Policy’ to misdescribe that some schools have both the capacity and demand to accommodate autism support for all grades, while others have more limited capacity and demand and cannot accommodate autism support for all grades.” (Doc. No. 12, at 10). At this stage of the proceedings, we simply do not have the information necessary to analyze and resolve this factual dispute. The nature, existence, scope, and implementation of the so-called “Automatic Autism Transfer Policy”3 should certainly be considered in making a class certification decision in this matter, but the limited information available to us at this time curtails our ability to rigorously analyze the issue as required by Third Circuit law. See Landsman & Funk, 640 F.3d at 93.
Defendants argue that Plaintiffs’ claims are fundamentally unsuited to class-wide treatment. Specifically, Defendants argue that the relief Plaintiffs seek precludes class certification because the requested relief “boils down to forbidding any school that is incapable of offering autism support classes to all grade levels from offering [autism support] to any grade levels in that school, certainly not the desired outcome for all members of the class. This is especially true because this result will require the elimination of autism support classes in many neighborhood schools.” (Doc. No. 22-2, at 3-4). This argument fails to persuade us that Plaintiffs’ claims and requested relief are “fundamentally unsuited to class-wide treatment.”
As discussed supra, Plaintiffs request various forms of prospective relief, including a declaration that the “Automatic Autism Transfer Policy” violates IDEA, Section 504, and the
3Even if the District does not have an official “Automatic Autism Transfer Policy,” discovery should still shed light on the frequency with which the District transfer autistic students vis-a-vis non-disabled students, as well as the procedure by which the District transfers students with autism. This information may very well inform our class certification analysis and decision.
9

ADA, and may no longer be used; and an order directing the District to create, maintain, and publicly disseminate a list of all the schools within the District that house any autistic support classroom; develop a new policy, with parental involvement, to provide continuity of programming for students with autism; and conduct IEP meetings, again with parental involvement, before reassigning a child with autism to another school (Doc. No. 1, at 21-22). Plaintiffs certainly do not explicitly request that we forbid “any school that is incapable of offering autism support classes to all grade levels from offering [autism support] to any grade levels in that school” or eliminate “autism support classes in many neighborhood schools.” Defendants merely speculate that forcing the District to change its practices regarding transferring autistic students will have the aforementioned results. Unlike Defendants, we will not jump to that conclusion at this time, early in the proceedings and before discovery has even begun.
Additionally, much of Plaintiffs’ requested relief focuses on providing parents of autistic children with more information and a greater opportunity to get involved with their children’s educational placement. We cannot see how this relief would divide the Plaintiffs’ proposed class to such an extent that an inherent conflict of interest among the class members would prohibit class certification. Parents may or may not take advantage of the opportunity to participate in the decisions that affect their children’s education. However, merely giving parents the option to do so, as well as the information necessary to make informed decisions, would not appear to be a particularly controversial or divisive issue among the autistic community.
For the aforementioned reasons, Defendants’ motion to strike the class action allegations is denied as premature. As such, the Court does not address the merits of Defendants’
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substantive arguments regarding the Rule 23 requirements of numerosity, commonality, typicality, adequacy, cohesiveness, and predomination, at this time.
B. Motion to Dismiss for Failure to Exhaust Administrative Remedies Defendants challenge our subject matter jurisdiction in this case under Rule 12(b)(1), arguing that Plaintiffs have failed to exhaust their administrative remedies; Plaintiffs’ claims are moot because the District has offered the four (4) named plaintiffs placements in their preferred school; and Plaintiffs lack standing because they have suffered no injury. To withstand a Rule 12(b)(1) challenge to subject matter jurisdiction, “[t]he plaintiff has the burden of persuasion to convince the court it has jurisdiction.” Gould Elecs., Inc. v. Untied States, 220 F.3d 169, 178 (3d Cir. 2000). However, “[a] claim may be dismissed under Rule 12(b)(1) only if it ‘clearly appears to be immaterial and made solely for the purpose of obtaining jurisdiction’ or is ‘wholly insubstantial and frivolous.’” Id. (quoting Kehr Packages, Inc. v. Fidelcor, Inc., 926 F.2d 1406, 1409 (3d Cir. 1991)). Preliminarily, we note that “[a] Rule 12(b)(1) motion may be treated as either a facial or factual challenge to the court’s subject matter jurisdiction.” Gould, 220 F.3d at 176. When considering a facial attack, we “only consider the allegations of the complaint and documents referenced therein and attached thereto, in the light most favorable to the plaintiff.” Id. Conversely, when evaluating a factual challenge to our subject matter jurisdiction, we “may consider evidence outside the pleadings.” Id. Here, Defendants introduced extrinsic materials to support their motion to dismiss, (see Doc. No. 11 Exs. A-F), and Defendants dispute the existence of the “Automatic Autism Transfer Policy.” Therefore, the Court will treat
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Defendants’ 12(b)(1) motion as a factual attack and may consider materials outside the pleadings as appropriate.
We begin by considering Defendants’ exhaustion arguments. In general, those who wish to bring claims under IDEA must first exhaust their administrative remedies before bringing a civil action in federal court. See 20 U.S.C. § 1415(i)(2)(A) (“Any party aggrieved by the findings and decision made under subsection (f) or (k) who does not have the right to an appeal under subsection (g), and any party aggrieved by the findings and decision made under this subsection, shall have the right to bring a civil action...”); 20 U.S.C. § 1415(l); Komninos v. Upper Saddle River Bd. of Educ., 13 F.3d 775, 778 (3d Cir. 1994) (declaring that “it is clear from the language of [IDEA] that Congress intended plaintiffs to complete the administrative process before resorting to federal court.”). Relatedly, when plaintiffs file a civil suit under the Constitution, the ADA, Title V of the Rehabilitation Act, or other federal laws protecting the rights of children with disabilities, seeking relief also available under IDEA, those plaintiffs must exhaust their IDEA-created administrative remedies “to the same extent as would be required had the action been brought under” IDEA. See 20 U.S.C. § 1415(l).
However, our courts have crafted certain exceptions to IDEA’s exhaustion requirement. Specifically, in the Third Circuit, claimants may bypass the administrative process: (1) where exhaustion would be futile or inadequate; (2) where the issue presented is purely a legal question; (3) where the administrative agency cannot grant relief; and (4) when exhaustion would work severe or irreparable harm upon a litigant. Beth V. v. Carroll, 87 F.3d 80, 88-89 (3d Cir. 1996). Additionally, federal court plaintiffs need not have exhausted their administrative remedies if “they allege systemic legal deficiencies and, correspondingly, request system-wide relief that
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cannot be provided (or even addressed) through the administrative process.” Id. at 89. This exhaustion exception “flows implicitly from, or is in fact subsumed by, the futility and no-administrative-relief exceptions.” Id.
The question then becomes how to properly define “systemic.” The Third Circuit has not yet tackled the issue, but several courts have concluded that an IDEA claim is systemic “if it implicates the integrity or reliability of the IDEA dispute resolution procedures themselves, or requires restructuring the education system itself in order to comply with” IDEA, while a claim is not systemic “if it involves only a substantive claim having to do with limited components of a program, and if the administrative process is capable of correcting the problem.” Doe v. Ariz. Dep’t of Educ., 111 F.3d 678, 682 (9th Cir. 1997); MG v. Caldwell-West Caldwell Bd. of Educ., No. 09–1869, 2011 WL 2607523, at *7 (D.N.J. June 30, 2011) (citing Grieco v. N.J. Dep’t of Educ., 2007 WL 1876498, at *6 (D.N.J. June 27, 2007)).
Here, two (2) of the named plaintiffs, P.V. and M.M., have sought and obtained at least some relief from an administrative hearing officer. The other two (2) named plaintiffs, J.V. and R.S., had not participated in a due process hearing before bringing this suit. Nevertheless, we find that the named plaintiffs in this purported class action need not exhaust their administrative remedies because “they allege systemic legal deficiencies and, correspondingly, request system-wide relief that cannot be provided (or even addressed) through the administrative process.” Beth V., 87 F.3d at 89.
To reach this conclusion, we first recognize that the “systemic legal deficiency / systemwide relief” exhaustion exception is simply a subset of the well-established “futility” and “no administrative relief” exceptions. See id. If an educational system is broken and requires a
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system-wide fix that an administrative hearing officer cannot provide, then requiring plaintiff after plaintiff to exhaust his or her administrative remedy before filing suit would undoubtedly be futile. In this case, Plaintiffs’ Complaint alleges that the District has an “Automatic Autism Transfer Policy” pursuant to which the District improperly transfers students with autism without parental involvement and at a higher rate than the District transfers non-autistic students. Plaintiffs seek various forms of broad-based relief from this allegedly illegal Policy. Tellingly, the hearing officer in P.V.’s and M.M.’s administrative hearings explicitly stated that he “lacks authority to order wholesale changes to the District’s procedures,” so he simply encouraged the District “to alter its procedures on a broader scope, if only to avoid a plethora of identical claims from similarly situated students.” (Doc. No. 1-4, at 15; Doc. No. 1-5, at 15).
These facts illustrate the prototypical case in which a court should permit IDEA plaintiffs to bypass IDEA’s administrative dispute resolution process. Two of the named plaintiffs, P.V. and M.M., sought and obtained some relief from an administrative hearing officer, but the hearing officer candidly admitted that he had no power to grant the kind of system-wide relief requested in this suit. Requiring P.V., or M.M., or J.V., or R.S., or any other autistic student in the District, to repeatedly ask an administrative hearing officer for broad-based, structural relief that he cannot provide seems wasteful and would ultimately prove fruitless. Additionally, if each autistic student with similar grievances “is forced to assert his or her claims through the administrative process, there is a high probability that there will be inconsistent results and the alleged ‘systematic’ deficiency” in the District’s procedures regarding autistic students will likely remain unaddressed and unresolved. N.J. Prot. & Advocacy, Inc. v. N.J. Dep’t of Educ., 563 F. Supp. 2d 474, 477-78 (D.N.J. 2008).
14

Relying on several district court decisions, Defendants argue that exhaustion is not futile “if the administrative process is capable of providing Plaintiffs form of relief.” See, e.g.,
some Brandon V. v. Chichester School Dist., Civil Action No. 06-4687, 2007 WL 2155722, at *5 (E.D. Pa. July 25, 2007); Hesling v. Avon Grove School Dist., 428 F. Supp. 2d 262, 275 (E.D. Pa. 2006) (concluding that “[i]n light of the availability of some of the relief sought, exhaustion is required.”). We believe Defendants stretch the “some form of relief” line of cases too far.
The Third Circuit has never endorsed the general proposition that IDEA claimants must exhaust their administrative remedies whenever the administrative process can grant some, but not all, of claimants’ requested relief. In fact, the “some form of relief” doctrine grew out of a district court’s attempt to distinguish the Third Circuit’s decision in W.B. v. Matula, 67 F.3d 484 (3d Cir. 1995), that exhaustion is not required when “the only relief sought-compensatory damages-was unavailable in the IDEA administrative proceedings.” See Hesling, 428 F. Supp. 2d at 274-76. Specifically, the Hesling court opined that the “Third Circuit's determination that exhaustion was excused in W.B. is not controlling here, as at least part of the relief sought by Ms. Hesling-declaratory relief for violation of her rights under the IDEA-is available through the statute’s administrative proceedings.” Id. at 275.
The Hesling decision makes sense when put in context. In W.B. v. Matula, the Third Circuit arguably left open the possibility that an IDEA claimant’s request for compensatory damages may be sufficient to escape IDEA’s exhaustion requirement. Such a result would incentivize enterprising IDEA plaintiffs to seek compensatory damages in an effort to improperly circumvent the exhaustion requirement. Read in this light, the Hesling court’s statement that
15

exhaustion is required if the administrative process can afford claimants some form of relief may be seen as an attempt to discourage this strategic behavior.
However, taken too far, the “some form of relief” doctrine would eviscerate the futility exception to exhaustion. Administrative hearing officers can almost always fashion some kind of relief for an IDEA claimant. Therefore, if we made IDEA claimants exhaust their administrative remedies every time the administrative process could provide the claimants relief, the
some futility exception would become a nullity. Additionally, the Supreme Court has made it clear that IDEA claimants “may bypass the administrative process where exhaustion would be futile or inadequate.” Honig v. Doe, 484 U.S. 305, 326-27 (emphasis added). If read broadly, as suggested by Defendants, the “some form of relief” line of cases would improperly run afoul of the Honig decision.
Here, even though an administrative hearing officer may be able to provide Plaintiffs with some of their requested relief, the hearing officer admittedly cannot order the District to make the structural changes to the District’s autistic student transfer procedures that Plaintiffs seek. Therefore, exhaustion would be “futile or inadequate,” Honig, 484 U.S. at 326-27, so Plaintiffs properly bypassed the administrative process in this case. Because we have excused Plaintiffs from pursuing their claims administratively, we need not, and do not, decide whether Plaintiffs have in fact adequately exhausted their administrative remedies.
C. Plaintiffs’ Claims Are Not Moot A case becomes moot “when the issues presented are no longer ‘live’ or the parties lack a legally cognizable interest in the outcome.” Donovan v. Punxsutawney Area Sch. Bd., 336 F.3d 211, 216 (3d Cir. 2003) (citation omitted). The heart of a mootness inquiry is whether the court
16

“can grant effective relief.” Id. More specifically, “an offer for the entirety of a plaintiff's claim will generally moot the claim.” Weiss v. Regal Collections, 385 F.3d 337, 342 (3d Cir. 2004). This flows naturally from basic mootness principles because parties do not have a “legally cognizable interest in the outcome” of a case once the alleged wrongdoer offers the aggrieved party complete relief.
In evaluating mootness, we must pay particular attention to circumstances in which the alleged wrongdoing recurs over a period of time. In particular, the Supreme Court has determined that a case is not moot if the conduct complained of is “capable of repetition, yet evading review.” Honig, 484 U.S. at 318-20 (citation omitted). For conduct to be “capable of repetition, yet evading review,” there must be a “reasonable expectation” or a “demonstrated probability” that the same controversy will recur. Id. at 318 n.6 (citation omitted). “This exception applies when (1) the challenged action [is] in its duration too short to be fully litigated prior to its cessation or expiration, and (2) there [is] a reasonable expectation that the same complaining party [will] be subjected to the same action again.” Diop v. ICE/Homeland Sec., No. 10–1113, 2011 WL 3849739, at *4 (3d Cir. Sept. 1, 2011) (citations omitted).
Courts have repeatedly denied mootness challenges to IDEA claims, concluding that the conduct giving rise to such claims is capable of repetition but evades review. See, e.g., LV v. N.Y.C. Dep’t of Educ., No. 03 Civ. 9917, 2005 WL 2298173, at *5 n.4 (S.D.N.Y. Sept. 20, 2005) (concluding “that defendants’ conduct fell within the ‘capable of repetition, yet evading review’ exception, such that there exists a ‘reasonable expectation’ that plaintiffs could be subject to the same conduct again based on (1) plaintiffs’ continued eligibility for educational services under the IDEA; (2) the nature of their disabilities; and (3) allegations that the delays are
17

due to defendants’ systemic failure to ensure timely enforcement”) (citation omitted); D.E.R. v. Bd. of Educ. of Borough of Ramsey, No. Civ.A.04-2274, 2005 WL 1177944, at *4-5 (D.N.J. May 18, 2005) (rejecting mootness challenge because “[a] school year is not long enough for the administrative due process and judicial review proceedings provided under the IDEA to take their course,” and “the determination of the least restrictive environment (‘LRE’) is an issue that must be addressed each time an IEP is prepared and has been a recurring issue throughout D.R.'s education.”); Coale v. State Dep’t of Educ., 162 F. Supp. 2d 316, 319 n.3 (D. Del. 2001) (recognizing that “[i]t is well established that the passage of the school year at issue does not moot an IDEA lawsuit. Due to the inevitable delays in litigation, a contrary rule would make the IDEA largely unenforceable. Thus, jurisdiction is deemed proper pursuant to the ‘capable of repetition yet evading review’ exception to the mootness doctrine.”).
Here, Defendants argue that Plaintiffs’ claims are moot because Defendants have offered all four (4) named plaintiffs a position in an autism support classroom in their preferred school. (Doc. No. 11, at 21). This argument fails in several respects. First, Defendants have not offered Plaintiffs complete relief because Plaintiffs seek much more than temporary placement at their preferred school. Plaintiffs also seek system-wide changes in the way the District operates with respect to autistic students. (See Doc. No. 1, at 21-23). Defendants have not offered Plaintiffs such broad-based relief, so Plaintiffs retain a “legally cognizable interest in the outcome” of this case. See Donovan, 336 F.3d at 216.
Second, Plaintiffs’ claims fall squarely within the special “capable of repetition, yet evading review” category of mootness cases. In general, educational placements remain in effect for only one school year. Therefore, the Plaintiffs in this case will be subject to the District’s
18

allegedly deficient autistic student placement policy each year. We agree with our sister courts in LV v. N.Y.C. Dep’t of Educ., D.E.R., and Coale that we cannot likely resolve IDEA-based disputes of this kind within a school year, and concluding that such cases are moot would render IDEA largely unenforceable, at least with respect to claims of systemic wrongdoing. Since we have a “reasonable expectation” that the plaintiffs here will be subject to the same allegedly deficient “Automatic Autism Transfer Policy” year after year, and the challenged Policy will evade review due to the short amount of time between placements (one year), the Plaintiffs’ claims are not moot. See Honig, 484 U.S. at 318-20.
D. Plaintiffs Have Standing The three “irreducible” constitutional elements of standing are: (1) an injury in fact that is actual or imminent, not “conjectural” or “hypothetical”; (2) a causal connection between the injury and the conduct complained of—the injury must be fairly traceable to the challenged action of the defendant; and (3) a showing that it is likely, as opposed to merely speculative, that a favorable decision will redress the injury. Lujan v. Defenders of Wildlife, 504 U.S. 555, 560–61 (1992). Plaintiffs need not demonstrate actual harm or monetary damages to establish standing. On the contrary, “the actual or threatened injury required by Art. III may exist solely by virtue of statutes creating legal rights, the invasion of which creates standing.” Alston v. Countrywide Fin. Corp., 585 F.3d 753, 763 (3d Cir. 2009). More specific to this matter, IDEA claimants who allege a statutorily deficient, systemic failure in educational policy have standing to challenge that policy because it will likely affect them year after year, until they complete their education. For example, in CG v. Commonwealth of Pa. Dep’t of Educ., No. 1:06-CV-1523, 2009 WL 3182599 (M.D. Pa. Sept. 29, 2009),
19

plaintiffs sought “an injunction requiring the Pennsylvania Secretary of Education to abandon the current funding formula and to distribute special-education funds based upon the actual number of disabled students and the actual cost of their special-education needs.” Id., at *2. The court held that the plaintiffs had standing because they alleged “that all Plaintiffs are subject to the systemic failure to provide FAPE caused by the funding formula.” Id., at *3. Similarly, the Eastern District of Missouri recently denied a motion to dismiss for lack of standing in a case in which the plaintiff alleged “past patterns of practice that have denied him access to a free appropriate public education and ongoing discrimination in education on the basis of his disability,” in the absence of evidence to the contrary. B.A. v. Missouri, No. 4:09CV1269, 2010 WL 1254655, at *4 (E.D. Mo. Mar. 24, 2010).
Here, Defendants argue that Plaintiffs do not have standing because (1) none of the Plaintiffs was transferred from his or her preferred school, negating any possible “injury in fact,” and (2) the District has offered Plaintiffs placement in their preferred school until the fifth grade, so any injury and associated relief would be merely speculative. This argument does not persuade us. As discussed supra, an imminent injury, including an imminent violation of statutory rights under IDEA, confers standing. See Alson, 585 F.3d at 763; CG, 2009 WL 3182599, at *3. Even though Plaintiffs currently attend their preferred school, Plaintiffs will continue to be subject to the District’s allegedly IDEA-deficient educational placement process from year to year. As such, Plaintiffs’ injuries are imminent, not merely conjectural or hypothetical, and a favorable court decision will likely redress the systemic failures, if any, in the District’s practices regarding the educational placement and transfer of autistic students. Therefore, under Lujan, Plaintiffs have standing to pursue their claims.
20

E. Plaintiffs’ Claims Against Individual Defendants in Their Official Capacity Defendants ask us to dismiss all claims against the individual, official capacity defendants in this case as redundant of the claims against the District. We decline to do so at this time. To begin, we note that there is nothing inherently improper about naming both entity defendants and individual, official capacity defendants in an IDEA lawsuit. N.J. Prot. & Advocacy, 563 F. Supp. 2d at 491-92 (acknowledging “that in many circumstances it is appropriate for a plaintiff to assert IDEA and Rehabilitation Act claims against individuals in their ‘official capacities’ as school administrators, school district personnel, or school board members.”). While some courts have dismissed claims against individual, official capacity defendants as redundant, they have done so after satisfying themselves that the remaining entity defendant(s) were willing to take responsibility for the individual defendants’ action. See Blunt v. Lower Merion School Dist., 559 F. Supp. 2d 548, 567-68 (E.D. Pa. 2008) (dismissing individual defendants, in part because the “non-individual defendants do not seek to avoid liability by removing these individual defendants but instead acknowledge that any wrongdoing by those individual defendants is attributable to them.”). Additionally, retaining individual official capacity defendants in a case may streamline the discovery process. See Abdullajeva v. Club Quarters, Inc., No. 96 CIV. 0383, 1996 WL 497029, at *1-2 (S.D.N.Y. Sept. 3, 1996) (noting that “[i]t is not anomalous to permit individuals to be named as defendants, even though no judgment can be collected from them,” in part because the Federal Rules of Civil Procedure facilitate discovery against parties). Here, the entity Defendant, The School District of Philadelphia, has not yet represented to the Court that the District will willingly accept the wrongdoing, if any, of the individual official
21

capacity Defendants, who are both School District officials. Therefore, it would be imprudent to dismiss Plaintiffs’ claims against the individual Defendants as redundant at this time. III. Conclusion
For the aforementioned reasons, Defendants’ motions to file reply briefs (Doc. No. 21, Doc. No. 22) are GRANTED. Defendants’ motion to strike class action allegations (Doc. No. 12) is DENIED, and Defendants’ motion to dismiss (Doc. No. 11) is also DENIED.
BY THE COURT: /s/ Legrome D. Davis Legrome D. Davis, J.
22

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF PENNSYLVANIA

P.V., a minor, by and through his Parents, Pedro Valentin and Yolanda Cruz, individually, and on behalf of all others similarly situated, et al.,
Plaintiffs,
v.
The School District of Philadelphia, et al.
Defendants.

: CIVIL ACTION : : : : : : : : : NO. 2:11-cv-04027 : :

ORDER

AND NOW, this 31st day of October, 2011, upon consideration of (1) Defendants’ Motion to Dismiss (Doc. No. 11), (2) Plaintiffs’ Memorandum of Law in Opposition to Defendants’ Motion to Dismiss (Doc. No. 17), (3) Defendants’ Motion for Leave to File a Reply Brief in Support of Defendants’ Motion to Dismiss Plaintiffs’ Complaint (Doc. No. 21), (4) Reply Brief in Support of Defendants’ Motion to Dismiss (Doc. No. 21-1), (5) Motion by Defendants to Strike Class Action Allegations (Doc. No. 12), (6) Plaintiffs’ Response to Defendants’ Motion to Strike Class Action Allegations (Doc. No. 18), (7) Defendants’ Motion for Leave to File a Reply Brief in Support of Defendants’ Motion to Strike Plaintiffs’ Class Action Allegations (Doc. No. 22), and (8) Reply Brief in Support of Defendants’ Motion to Strike Plaintiffs’ Class Action Allegations (Doc. No. 22-2), and in accordance with the reasoning set forth in the accompanying Memorandum, it is hereby ORDERED as follows:
1

1. Defendants’ Motion for Leave to File a Reply Brief in Support of Defendants’ Motion to Dismiss Plaintiffs’ Complaint (Doc. No. 21) is GRANTED. The Clerk of Court is directed to enter Doc. No. 21-1 as “Reply Brief in Support of Defendants’ Motion to Dismiss.”
2. Defendants’ Motion for Leave to File a Reply Brief in Support of Defendants’ Motion to Strike Plaintiffs’ Class Action Allegations (Doc. No. 22) is GRANTED. The Clerk of Court is directed to enter Doc. No. 22-2 as “Reply Brief in Support of Defendants’ Motion to Strike Plaintiffs’ Class Action Allegations.”
3. Defendants’ Motion to Strike Class Action Allegations (Doc. No. 12) is DENIED. 4. Defendants’ Motion to Dismiss (Doc. No. 11) is DENIED.
BY THE COURT: /s/ Legrome D. Davis Legrome D. Davis, J.
2

 </s> Case 2:11-cv-04027-LDD Document 48-36 Filed 07/13/12 Page 1 of 84
EXHIBIT 32

Case 2:11-cv-04027-LDD Document 48-36 Filed 07/13/12 Page 2 of 84
	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  

1920	
  Briarcliff	
  Road	
  NE	
   Atlanta,	
  GA	
  30329-­‐4010	
   404-­‐785-­‐5762	
   404-­‐785-­‐9043	
  fax	
  
	
  
ami.klin@emory.edu	
   www.marcus.org	
  
Ami	
  Klin,	
  Ph.D.	
   Director,	
  Marcus	
  Autism	
  Center	
   Children’s	
  Healthcare	
  of	
  Atlanta	
   	
   Professor	
  and	
  Division	
  Chief	
   Autism	
  and	
  Related	
  Disorders	
   Department	
  of	
  Pediatrics	
   Emory	
  School	
  of	
  Medicine	
   	
   Center	
  for	
  Translational	
  	
   Social	
  Neuroscience	
   Emory	
  University	
   	
   Georgia	
  Research	
  Alliance	
   Eminent	
  Scholar	
  
	
  

DEVELOPMENTAL	
  DISABILITIES	
  CONSULTATION	
  

Report	
  issued	
  on	
  June	
  8	
  2012	
  

	
  

	
  

	
  

01.	
  Background	
  of	
  Developmental	
  Disabilities	
  Consultation:	
  

	
  

I	
   have	
   been	
   retained	
   by	
   plaintiffs’	
   counsel	
   to	
   provide	
   opinions	
   on	
   certain	
  

issues	
   related	
   to	
   P.V.,	
   et	
   al.,	
   v.	
   The	
   School	
   District	
   of	
   Philadelphia,	
   et	
   al.,	
   E.D.	
  

Pa.	
  Civil	
  Action	
  No.	
  2:11-­‐cv-­‐04027.	
  These	
  issues	
  include:	
  

	
  

a. Difficulty	
  of	
  children	
  with	
  autism	
  spectrum	
  disorders	
  (ASD)	
  adjusting	
  to	
  

change	
   in	
   their	
   environment	
   and	
   with	
   transitions	
   more	
   generally.	
   My	
  

focus	
   was	
   on	
   children	
   with	
   ASD	
   attending	
   kindergarten	
   to	
   grade	
   8	
  

levels	
  of	
  educational	
  placement;	
  

b. Consequences	
  of	
  unplanned	
  transitions	
  upon	
  these	
  children’s	
  learning	
  

ability	
  and	
  rate,	
  and	
  on	
  behavioral	
  challenges	
  typically	
  associated	
  with	
  

their	
  condition;	
  

c. The	
   role	
   of	
   planning	
   and	
   preparation	
   toward	
   transitions	
   and,	
   more	
  

generally,	
   principles	
   and	
   standards	
   known	
   to	
   attenuate	
   deleterious	
  

effects	
  of	
  change	
  and	
  transitions;	
  and	
  

d. The	
   role	
   of	
   parents	
   in	
   the	
   management	
   of	
   transitions,	
   and	
   more	
  

generally,	
   principles	
   and	
   standards	
   associated	
   with	
   parental	
  

involvement	
   in	
   the	
   establishment	
   of	
   Individualized	
   Education	
  

Programs	
  (IEP)	
  and	
  their	
  implementation.	
  	
  

	
  

My	
   opinions,	
   which	
   are	
   set	
   forth	
   more	
   fully	
   below,	
   can	
   be	
   summarized	
   as	
  

follows:	
   Based	
   on	
   my	
   personal	
   clinical	
   experience,	
   substantial	
   literature	
  

reviewed,	
   and	
   the	
   materials	
   made	
   available	
   to	
   me	
   on	
   this	
   case	
   -­‐	
   with	
   a	
  

reasonable	
   degree	
   of	
   certainty	
   and	
   within	
   the	
   limitations	
   also	
   described	
  

below	
   -­‐	
   the	
   School	
   District’s	
   practices	
   associated	
   with	
   the	
   transitioning	
   of	
  

children	
   with	
   ASD	
   from	
   one	
   educational	
   setting	
   to	
   another	
   appear	
   to	
   be	
  

inconsistent	
   with	
   best	
   practices	
   and	
   standards,	
   and	
   not	
   appropriate.	
   There	
   is	
  

concern	
  that	
  procedures	
  for	
  transitioning	
  special	
  education	
  children	
  with	
  ASD	
  

(1)	
   do	
   not	
   reflect	
   adequate	
   parental	
   involvement,	
   and	
   (2)	
   are	
   not	
   evaluated	
  

fully	
   or	
   managed	
   proactively	
   in	
   compliance	
   with	
   the	
   spirit	
   of	
   the	
   relevant	
  

statutes	
  and	
  in	
  accordance	
  with	
  consensual,	
  clinical	
  science	
  directives.	
  	
  

	
  

The	
   presentation	
   of	
   my	
   opinions	
   is	
   organized	
   in	
   terms	
   of	
   the	
   following	
   order	
  

of	
   topics:	
   a	
   brief	
   description	
   of	
   autism	
   spectrum	
   disorders,	
   and	
   of	
   specific	
  

issues	
   related	
   to	
   change	
   in	
   their	
   environment	
   and	
   transitions	
   generally;	
  

potentially	
   deleterious	
   impact	
   of	
   change	
   and	
   transitions	
   on	
   these	
   children’s	
  

learning	
   performance	
   and	
   behavioral	
   patterns;	
   principles	
   and	
   standards	
   for	
  

management	
   of	
   transitions;	
   the	
   relationship	
   between	
   management	
   of	
  

11 	
  

	
  

Case 2:11-cv-04027-LDD Document 48-36 Filed 07/13/12 Page 3 of 84

	
  

P.V.	
  ex	
  rel.	
  Valentin	
  and	
  Cruz,	
  et	
  al.,	
  v.	
  School	
  District	
  of	
  Phila.,	
  et	
  al.	
  (E.D.	
  Pa.)	
  –	
  Consultation	
  by	
  Ami	
  Klin	
  PhD	
  

transitions	
  and	
  the	
  IEP	
  process;	
  and	
  the	
  role	
  of	
  parental	
  involvement	
  in	
  the	
  IEP	
  process.	
  	
   	
   For	
  the	
  expression	
  of	
  my	
  opinions	
  I	
  rely	
  on	
  my	
  personal	
  clinical	
  experience,	
  on	
  pertinent	
  clinical	
   science	
   literature	
   found	
   in	
   peer-­‐review	
   publications,	
   on	
   compilations	
   of	
   principles	
   and	
   standards	
   of	
   educational	
   programming	
   assembled	
   by	
   experts	
   under	
   the	
   auspices	
   of	
   authoritative	
   agencies	
   charged	
   with	
   review	
   and	
   evaluation	
   of	
   extant	
   clinical	
   science	
   literature	
   on	
   behalf	
   of	
   the	
   community	
   of	
   clinical	
   scientists,	
   clinical	
   service	
   providers,	
   educational	
   professionals,	
   and	
   families	
   impacted	
   by	
   ASD,	
   on	
   pertinent	
   statutes	
   and	
   regulations,	
   and	
   information	
  provided	
  by	
  plaintiffs’	
  counsel	
  as	
  listed	
  below.	
  	
   	
   My	
   personal	
   experience	
   comes	
   from	
   a	
   27-­‐year	
   history	
   of	
   involvement	
   in	
   clinical	
   service	
   provision	
  and	
  clinical	
  investigation	
  of	
  ASD,	
  beginning	
  in	
  graduate	
  school	
  in	
  London	
  (1983-­‐1988;	
   PhD	
  work	
  at	
  the	
  Medical	
  Research	
  Council,	
  Cognitive	
  Development	
  Unit,	
  University	
  of	
  London;	
   National	
   Autistic	
   Society	
   and	
   associated	
   special	
   schools	
   for	
   children	
   with	
   ASD,	
   London	
   and	
   environs;	
   Lauriston	
   Road	
   Residential	
   Unit	
   for	
   Adults	
   with	
   Developmental	
   Disabilities,	
   Hackney,	
   London),	
   Autism	
   Program	
   at	
   the	
   Yale	
   Child	
   Study	
   Center,	
   Yale	
   University	
   School	
   of	
   Medicine	
   (1989-­‐2010;	
   Post-­‐doctoral	
   fellowships,	
   Professor	
   and	
   Director	
   of	
   Autism	
   Program),	
   and	
   the	
   Marcus	
   Autism	
   Center,	
   Children’s	
   Healthcare	
   of	
   Atlanta	
   and	
   Division	
   of	
   Autism	
   &	
   Developmental	
   Disabilities	
   at	
   Emory	
   University	
   School	
   of	
   Medicine	
   (2011-­‐present;	
   Director,	
   Professor	
  &	
  Division	
  Chief).	
  	
   	
   The	
   2	
   main	
   authoritative	
   compilations	
   of	
   principles	
   and	
   standards	
   defining	
   appropriate	
   educational	
  programming	
  for	
  children	
  with	
  ASD	
  relied	
  upon	
  in	
  this	
  report	
  are:	
  	
   	
  
1) The	
   report	
   issued	
   by	
   the	
   National	
   Research	
   Council,	
   Committee	
   on	
   Educational	
   Interventions	
   for	
   Children	
   with	
   Autism	
   (NRC,	
   2001).	
   This	
   committee	
   was	
   convened	
   because	
   of	
   consensus	
   that	
   education,	
   both	
   directly	
   of	
   children,	
   and	
   of	
   parents	
   and	
   teachers,	
  is	
  the	
  primary	
  form	
  of	
  treatment	
  for	
  ASDs.	
  The	
  education	
  of	
  children	
  with	
  ASD	
   was	
   accepted	
   as	
   a	
   public	
   responsibility	
   under	
   the	
   Education	
   for	
   All	
   Handicapped	
   Children	
   Act	
   in	
   1975.	
   At	
   the	
   request	
   of	
   the	
   US	
   Department	
   of	
   Education’s	
   Office	
   of	
   Special	
   Education	
   Programs,	
   the	
   National	
   Research	
   Council	
   formed	
   the	
   Committee	
   on	
   Educational	
   Interventions	
   for	
   Children	
   with	
   Autism	
   and	
   charged	
   the	
   committee	
   to	
   integrate	
   the	
   scientific,	
   theoretical,	
   and	
   policy	
   literature	
   and	
   create	
   a	
   framework	
   for	
   evaluating	
   the	
   scientific	
   evidence	
   concerning	
   the	
   effects	
   and	
   features	
   of	
   educational	
   interventions	
   for	
   children	
   with	
   autism.	
   Their	
   primary	
   charge	
   focused	
   on	
   early	
   intervention,	
   preschool,	
   and	
   school	
   programs	
   designed	
   for	
   children	
   with	
   autism	
   from	
   birth	
   to	
   age	
   8.	
   The	
   charge	
   included,	
   among	
   others,	
   the	
   rights	
   of	
   children	
   with	
   autism	
   under	
  the	
  Individuals	
  with	
  Disabilities	
  Education	
  Act	
  (IDEA).	
  This	
  publication	
  reviews	
  the	
   evidence	
  and	
  expresses	
  conclusions	
  and	
  recommendations.	
  	
  
	
   2) The	
   report	
   issued	
   by	
   the	
   National	
   Autism	
   Center	
   through	
   their	
   National	
   Standards	
   Project	
   addressing	
   the	
   needs	
   for	
   evidence-­‐based	
   practice	
   guidelines	
   for	
   ASD	
   (NAC,	
   2009).	
  This	
  project	
  was	
  undertaken	
  to	
  compile	
  and	
  evaluate	
  the	
  evidence	
  of	
  treatment	
  

2	
  

	
  

Case 2:11-cv-04027-LDD Document 48-36 Filed 07/13/12 Page 4 of 84

	
  

P.V.	
  ex	
  rel.	
  Valentin	
  and	
  Cruz,	
  et	
  al.,	
  v.	
  School	
  District	
  of	
  Phila.,	
  et	
  al.	
  (E.D.	
  Pa.)	
  –	
  Consultation	
  by	
  Ami	
  Klin	
  PhD	
  

and	
  intervention	
  practices	
  for	
  individuals	
  with	
  ASD.	
  This	
  project	
  included	
  review	
  of	
  775	
  

intervention	
  studies	
  conducted	
  from	
  1957	
  to	
  2007.	
  	
  

	
  

In	
   addition,	
   a	
   sample	
   of	
   peer-­‐review	
   research	
   pertinent	
   to	
   the	
   questions	
   addressed	
   in	
   this	
  

report	
  was	
  utilized	
  to	
  substantiate	
  specific	
  points	
  addressing	
  the	
  questions	
  of	
  this	
  consultation.	
  	
  

	
  

I	
   am	
   compensated	
   at	
   the	
   rate	
   of	
   $500	
   per	
   hour	
   for	
   my	
   study	
   and	
   testimony	
   in	
   this	
   case.	
   My	
  

hourly	
  rate	
  is	
  not	
  contingent	
  on	
  my	
  opinions	
  in	
  this	
  matter.	
  	
  

	
  

	
  

02.	
  Documents	
  Provided	
  by	
  Plaintiffs’	
  Counsel:	
  

	
  

The	
  following	
  documents	
  were	
  provided	
  by	
  plaintiffs’	
  counsel	
  and	
  reviewed	
  by	
  this	
  consultant:	
  

	
  

#	
  01:	
  Complaint,	
  P.V.,	
  et	
  al.,	
  v.	
  The	
  School	
  District	
  of	
  Philadelphia,	
  et	
  al.,	
  dated	
  June	
  20,	
  2011;	
  

#	
  02:	
  Exhibit	
  A	
  to	
  Complaint,	
  Decision	
  and	
  Order	
  P.V.	
  Case,	
  dated	
  April	
  15,	
  2011;	
  

#	
  03:	
  Exhibit	
  B	
  to	
  Complaint,	
  Decision	
  and	
  Order	
  M.M.	
  Case,	
  dated	
  April	
  15,	
  2011;	
  

#	
   04:	
   Memorandum	
   by	
   Court,	
   denying	
   Defendants'	
   motion	
   to	
   strike	
   and	
   motion	
   to	
   dismiss,	
  

dated	
  October	
  31,	
  2011;	
  

#	
  05:	
  Defendants'	
  Answer	
  to	
  Complaint,	
  dated	
  November	
  14,	
  2011;	
  

#	
  06:	
  Declaration	
  of	
  Linda	
  Williams,	
  Deputy	
  Chief	
  of	
  OSIS,	
  dated	
  February	
  27,	
  2012	
  (OSIS:	
  Office	
  

of	
  Specialized	
  Instructional	
  Services);	
  

#	
   07:	
   Chart,	
   DEF000993,	
   produced	
   by	
   Defendants	
   in	
   discovery	
   on	
   February	
   10,	
   2012	
   (students	
  

with	
  autism	
  2008	
  –	
  2012);	
  

#	
  08:	
  Special	
  Education	
  Facilities	
  Master	
  Plan,	
  DEF006473,	
  dated	
  January	
  14,	
  2011,	
  produced	
  by	
  

Defendants	
  in	
  discovery	
  on	
  March	
  22,	
  2012;	
  	
  

#	
   09:	
   Office	
   of	
   Specialized	
   Instructional	
   Services,	
   Upper	
   Level	
   Transfers	
   for	
   September	
   2011,	
  

DEF006472,	
  dated	
  February	
  2,	
  2011;	
  	
  

#	
  10:	
  Excerpt	
  of	
  Hearing	
  Transcript,	
  including	
  testimony	
  of	
  Cathy	
  Roccia-­‐Meier	
  and	
  Leah	
  Taylor,	
  

dated	
  December	
  10,	
  2010;	
  

#	
  11:	
  Excerpt	
  of	
  Hearing	
  Transcript,	
  including	
  testimony	
  of	
  Leah	
  Taylor,	
  dated	
  February	
  3,	
  2011;	
  

#	
   12:	
   Excerpt	
   of	
   Hearing	
   Transcript,	
   including	
   testimony	
   of	
   Maria	
   Monras-­‐Sender,	
   dated	
  

February	
  4,	
  2011;	
  

#	
   13:	
   Excerpt	
   of	
   Hearing	
   Transcript,	
   including	
   testimony	
   of	
   Carla	
   Murphy	
   and	
   Maria	
   Monras-­‐

Sender,	
  dated	
  February	
  9,	
  2011;	
  

#	
  14:	
  A	
  teacher's	
  note	
  received	
  by	
  the	
  parent	
  of	
  a	
  putative	
  class	
  member,	
  PLF03037,	
  dated	
  May	
  

9,	
  2011;	
  

#	
   15:	
   A	
   letter	
   received	
   by	
   the	
   parent	
   of	
   a	
   putative	
   class	
   member,	
   PLF03038-­‐39,	
   dated	
   July	
   1,	
  

2011;	
  

#	
  16:	
  Deposition	
  Transcript	
  of	
  Heather	
  Sanasac,	
  dated	
  April	
  3,	
  2012;	
  

#	
  17:	
  Deposition	
  Transcript	
  of	
  Kim	
  Hunt,	
  dated	
  May	
  11,	
  2012;	
  

#	
  18:	
  Deposition	
  Transcript	
  of	
  Matthew	
  Sanasac,	
  dated	
  April	
  3,	
  2012;	
  

#	
  19:	
  Deposition	
  Transcript	
  of	
  Maria	
  Monras-­‐Sender,	
  dated	
  May	
  10,	
  2012;	
  

#	
  20:	
  Deposition	
  Transcript	
  of	
  Linda	
  Williams,	
  dated	
  May	
  21,	
  2012;	
  

#	
  21:	
  Deposition	
  Transcript	
  of	
  Sharon	
  Vargas,	
  Parts	
  I	
  and	
  II,	
  April	
  6,	
  2012	
  &	
  May	
  18,	
  2012;	
  

3	
  

	
  

Case 2:11-cv-04027-LDD Document 48-36 Filed 07/13/12 Page 5 of 84

	
  

P.V.	
  ex	
  rel.	
  Valentin	
  and	
  Cruz,	
  et	
  al.,	
  v.	
  School	
  District	
  of	
  Phila.,	
  et	
  al.	
  (E.D.	
  Pa.)	
  –	
  Consultation	
  by	
  Ami	
  Klin	
  PhD	
  

#	
  22:	
  Deposition	
  Transcript	
  of	
  Yolanda	
  Cruz,	
  dated	
  April	
  12,	
  2012;	
  

#	
  23:	
  Deposition	
  Transcript	
  of	
  Jane	
  Cordero,	
  dated	
  May	
  15,	
  2012;	
  

#	
  24:	
  Deposition	
  Transcript	
  of	
  Cathy	
  Roccia-­‐Meier,	
  dated	
  May	
  16,	
  2012;	
  	
  

#	
  25:	
  Deposition	
  Transcript	
  of	
  Cecelia	
  Thompson,	
  dated	
  May	
  17,	
  2012;	
  

#	
  26:	
  Deposition	
  Transcript	
  of	
  Lovlei	
  L.	
  McKinnie,	
  dated	
  May	
  18,	
  2012.	
  

	
  

	
  

03.	
  Autism	
  Spectrum	
  Disorders	
  and	
  Problems	
  with	
  Transitions:	
  

	
  

	
  

	
  

Difficulties	
  with	
  Transition	
  as	
  a	
  Defining	
  Feature	
  of	
  Autism:	
  

	
  

Autism	
   Spectrum	
   Disorders	
   (ASDs)	
   are	
   a	
   family	
   of	
   highly	
   prevalent	
   neurodevelopmental	
  

disorders	
   of	
   strongly	
   genetic	
   origins,	
   which	
   are	
   marked	
   by	
   impairments	
   in	
   social	
   and	
  

communicative	
   functioning,	
   imagination	
   and	
   play,	
   as	
   well	
   as	
   repetitive	
   behaviors,	
   and	
   narrow	
  

interests	
   and	
   rigidities	
   (Volkmar	
   et	
   al.,	
   2005).	
   There	
   is	
   great	
   heterogeneity	
   in	
   the	
   behavioral	
  

manifestation	
  of	
  ASDs,	
  covering	
  the	
  entire	
  IQ	
  range	
  (from	
  profound	
  intellectual	
  disability	
  to	
  the	
  

gifted	
  range),	
  language	
  range	
  (from	
  nonverbal	
  to	
  highly	
  verbal),	
  and	
  social	
  and	
  communicative	
  

ability	
   range	
   (from	
   profoundly	
   aloof	
   to	
   frequent	
   but	
   intrusive	
   and	
   non-­‐reciprocal	
   approaches).	
  

Despite	
   the	
   tens	
   of	
   genes	
   already	
   implicated	
   in	
   their	
   etiology,	
   ASDs	
   are	
   a	
   well-­‐defined	
  

syndrome	
  (Jones	
  &	
  Klin,	
  2009)	
  and	
  amongst	
  the	
  most	
  well-­‐studied	
  and	
  reliably	
  diagnosed	
  of	
  all	
  

psychiatric	
  disorders	
  (Volkmar	
  et	
  al.,	
  2004;	
  Lord	
  et	
  al.,	
  2012).	
  	
  

	
  

From	
  the	
  time	
  of	
  its	
  first	
  description	
  by	
  Leo	
  Kanner	
  (Kanner,	
  1943),	
  there	
  has	
  been	
  emphasis	
  on	
  

the	
   rigidities	
   displayed	
   by	
   children	
   with	
   ASD.	
   In	
   fact,	
   in	
   his	
   description	
   Kanner	
   emphasized	
   the	
  

profound	
  social	
  and	
  communicative	
  disability	
  (hence	
  the	
  Greek	
  term	
  “autism”),	
  and	
  a	
  cluster	
  of	
  

behaviors	
   that	
   he	
   captured	
   under	
   the	
   term	
   “insistence	
   in	
   sameness”.	
   This	
   term	
   referred	
   to	
  

what	
  now	
  corresponds	
  to	
  the	
  third	
  cluster	
  of	
  defining	
  symptoms	
  of	
  autism	
  in	
  DSM-­‐IV	
  and	
  ICD-­‐

10	
   (Volkmar	
   et	
   al.,	
   1994)	
   –	
   “Restricted	
   repetitive	
   and	
   stereotyped	
   patterns	
   of	
   behavior,	
  

interests	
   and	
   activities”	
   as	
   manifested	
   by	
   encompassing	
   preoccupations	
   with	
   stereotyped	
   and	
  

restricted	
   patterns	
   of	
   interest,	
   compulsive	
   adherence	
   to	
   specific,	
   nonfunctional	
   routines	
   or	
  

rituals,	
  stereotyped	
  and	
  repetitive	
  motor	
  mannerisms,	
  and	
  persistent	
  preoccupation	
  with	
  parts	
  

of	
   objects.	
   These	
   defining	
   features	
   of	
   autism	
   encompass	
   a	
   wide	
   range	
   of	
   challenges	
   typically	
  

displayed	
  by	
  children	
  with	
  ASD.	
  Their	
  “insistence	
  in	
  sameness”	
  means	
  that	
  they	
  have	
  difficulty	
  

with	
   changes	
   in	
   their	
   environment	
   (e.g.,	
   minor	
   changes	
   in	
   familiar	
   places	
   or	
   people),	
   routines	
  

(e.g.,	
  changes	
  in	
  daily	
  schedules),	
  learned	
  sequences	
  of	
  behavior	
  and	
  activity	
  (e.g.,	
  unexpected	
  

alteration	
   of	
   a	
   learned	
   sequence),	
   relationships	
   (e.g.,	
   changes	
   in	
   caregiving	
   or	
   educational	
  

staff),	
   among	
   many	
   aspects	
   of	
   their	
   daily	
   lives	
   (Volkmar,	
   Klin,	
   Schultz	
   &	
   State	
   2009).	
   And	
  

although	
  the	
  specific	
  expressions	
  of	
  these	
  rigidities	
  vary	
  from	
  child	
  to	
  child,	
  and	
  typically	
  takes	
  

different	
   manifestations	
   associated	
   with	
   the	
   child’s	
   intellectual	
   skills	
   (Klin	
   et	
   al.,	
   2007),	
   it	
   is	
  

virtually	
   universal	
   among	
   all	
   individuals	
   with	
   ASD,	
   though	
   varying	
   individually	
   in	
   terms	
   of	
  

intensity	
   and	
   disruptive	
   impact	
   on	
   daily	
   lives	
   of	
   the	
   children,	
   at	
   school	
   and	
   at	
   home.	
   In	
   school	
  

life,	
   these	
   challenges	
   typically	
   impact	
   on	
   their	
   ability	
   to	
   maintain	
   attention	
   without	
   external	
  

structure	
  and/or	
  supports,	
  preference	
  for	
  only	
  one	
  or	
  a	
  few	
  activities	
  (and	
  resistance	
  to	
  engage	
  

in	
   others),	
   difficulty	
   with	
   transitions,	
   changes	
   in	
   routine	
   and	
   unexpected	
   events,	
   difficulty	
  

moving	
  from	
  one	
  activity	
  to	
  another,	
  and	
  failure	
  to	
  pick	
  up	
  on	
  the	
  “gist”	
  of	
  a	
  situation	
  or	
  activity	
  

4	
  

	
  

Case 2:11-cv-04027-LDD Document 48-36 Filed 07/13/12 Page 6 of 84

	
  

P.V.	
  ex	
  rel.	
  Valentin	
  and	
  Cruz,	
  et	
  al.,	
  v.	
  School	
  District	
  of	
  Phila.,	
  et	
  al.	
  (E.D.	
  Pa.)	
  –	
  Consultation	
  by	
  Ami	
  Klin	
  PhD	
  

and	
  consequent	
  expressions	
  of	
  confusion	
  and	
  disruptive	
  reactions	
  (e.g.,	
  tantrums)	
  (Olley,	
  2005).	
  

The	
   current	
   definition	
   of	
   ASD	
   in	
   the	
   IDEA	
   regulations	
   is:	
   “Autism	
   means	
   a	
   developmental	
  

disability	
   significantly	
   affecting	
   verbal	
   and	
   nonverbal	
   communication	
   and	
   social	
   interaction,	
  

generally	
   evident	
   before	
   age	
   three,	
   that	
   adversely	
   affects	
   a	
   child’s	
   educational	
   performance.	
  

Other	
   characteristics	
   often	
   associated	
   with	
   autism	
   are	
   engagement	
   in	
   repetitive	
   activities	
   and	
  

stereotyped	
   movements,	
   resistance	
   to	
   environmental	
   change	
   or	
   change	
   in	
   daily	
   routines,	
   and	
  

unusual	
   responses	
   to	
   sensory	
   experiences”.	
   (34	
   CFR	
   §	
  300.8(c)(1);	
   see	
   also	
   autism	
   in	
   DSM-­‐IV	
  

and	
   ICD-­‐10	
   (Volkmar	
   et	
   al.,	
   1994)).	
   In	
   the	
   proposed	
   DSM-­‐5	
   criteria	
   for	
   ASD	
   (APA,	
   2011),	
  

Criterion	
  #	
  2	
  of	
  Cluster	
  B	
  states	
  “Excessive	
  adherence	
  to	
  routines,	
  ritualized	
  patterns	
  of	
  verbal	
  

or	
  nonverbal	
  behavior,	
  or	
  excessive	
  resistance	
  to	
  change	
  (such	
  as	
  motoric	
  rituals,	
  insistence	
  on	
  

same	
  rote	
  or	
  food,	
  repetitive	
  questioning	
  or	
  extreme	
  distress	
  at	
  small	
  changes)”.	
  	
  

	
  

	
  

	
  

Difficulties	
  with	
  Transition	
  and	
  Problem	
  Behaviors:	
  

	
  

Problem	
   behaviors	
   of	
   children	
   with	
   ASD	
   are	
   among	
   the	
   most	
   challenging	
   and	
   stressful	
   issues	
  

faced	
  by	
  schools	
  and	
  parents	
  in	
  their	
  efforts	
  to	
  provide	
  appropriate	
  educational	
  programs	
  (NRC,	
  

2001).	
   Problem	
   behaviors,	
   ranging	
   from	
   tantrum,	
   to	
   physical	
   aggression,	
   self-­‐injury	
   and	
  

property	
  destruction	
  are	
  major	
  barriers	
  to	
  effective	
  social	
  and	
  educational	
  development	
  (NRC,	
  

2001).	
   Such	
   behaviors	
   put	
   young	
   children	
   at	
   risk	
   for	
   exclusion	
   and	
   isolation	
   from	
   social,	
  

educational,	
  family	
  and	
  community	
  activities.	
  Concerns	
  about	
  school	
  behavior	
  problems	
  led	
  to	
  

new	
   standards	
   and	
   procedures	
   for	
   discipline,	
   student	
   suspension,	
   and	
   expulsion	
   in	
   the	
   1997	
  

amendments	
   to	
   the	
   IDEA.	
   Specifically,	
   the	
   regulations	
   include	
   provisions	
   for	
   the	
   use	
   of	
  

functional	
  behavioral	
  assessments	
  and	
  positive	
  behavioral	
  interventions	
  and	
  support.	
  	
  

	
  

Understanding	
  what	
  causes	
  these	
  problem	
  behaviors	
  to	
  emerge	
  and	
  what	
  maintains	
  them,	
  and	
  

what	
   evokes	
   their	
   moment-­‐to-­‐moment	
   expression	
   has	
   been	
   the	
   subject	
   of	
   a	
   large	
   number	
   of	
  

research	
   studies	
   (NRC,	
   2001;	
   Berkson	
   &	
   Tupa,	
   2000).	
   This	
   area	
   of	
   research	
   is	
   critical	
   because	
  

once	
  moderate	
  to	
  severe	
  problem	
  behaviors	
  become	
  an	
  established	
  part	
  of	
  a	
  child’s	
  repertoire,	
  

children	
  with	
  ASD	
  do	
  not	
  usually	
  outgrow	
  them	
  without	
  appropriate	
  intervention,	
  and	
  they	
  may	
  

worsen	
  (Schroeder	
  et	
  al.,	
  1986).	
  Typical	
  behavioral	
  challenges	
  include	
  aggression,	
  destruction	
  of	
  

property,	
   disruption	
   of	
   activities,	
   self-­‐injury,	
   stereotypic	
   behavior,	
   and	
   inappropriate	
   verbal	
  

behavior	
  (NRC,	
  2001).	
  	
  

	
  

While	
  some	
  of	
  these	
  behaviors,	
  and	
  particularly	
  repetitive	
  and	
  stereotyped	
  behaviors	
  as	
  well	
  as	
  

self-­‐injurious	
   behaviors,	
   may	
   have	
   constitutional	
   origins	
   (i.e.,	
   organicity)	
   (Symons	
   et	
   al.,	
   1999;	
  

Lewis,	
   1996;	
   Thompson	
   et	
   al.,	
   1995),	
   research	
   on	
   educational	
   interventions	
   for	
   problem	
  

behaviors	
   has	
   revealed	
   specific	
   triggers	
   and/or	
   ‘exacerbators’	
   of	
   disruptive	
   behaviors	
   in	
  

children	
   with	
   ASD.	
   Not	
   unlike	
   the	
   finding	
   by	
   the	
   School	
   District	
   involved	
   in	
   this	
   case,	
   which	
  

conducted	
   a	
   functional	
   behavior	
   assessment	
   (FBA)	
   and	
   concluded	
   that	
   transitions	
   that	
   are	
  

unexpected	
   can	
   trigger	
   outbursts	
   (e.g.,	
   Exhibit	
   A	
   to	
   Complaint,	
   Decision	
   and	
   Order	
   P.V.	
   Case,	
  

para.	
   19,	
   dated	
   April	
   15,	
   2011),	
   the	
   literature	
   on	
   problem	
   behaviors	
   and	
   their	
   adequate	
  

management	
   in	
   school	
   settings	
   has	
   also	
   focused	
   on	
   the	
   impact	
   of	
   unexpected	
   change	
   and	
  

transitions	
  on	
  behavioral	
  patterns	
  of	
  children	
  with	
  ASD	
  (e.g.,	
  Schreibman	
  et	
  al.,	
  2000;	
  Dettmer	
  

et	
   al.,	
   2000;	
   Briody	
   &	
   McGarry,	
   2005).	
   As	
   a	
   result	
   of	
   the	
   consensus	
   emerging	
   from	
   this	
  

5	
  

	
  

Case 2:11-cv-04027-LDD Document 48-36 Filed 07/13/12 Page 7 of 84

	
  

P.V.	
  ex	
  rel.	
  Valentin	
  and	
  Cruz,	
  et	
  al.,	
  v.	
  School	
  District	
  of	
  Phila.,	
  et	
  al.	
  (E.D.	
  Pa.)	
  –	
  Consultation	
  by	
  Ami	
  Klin	
  PhD	
  

literature,	
   the	
   vast	
   majority	
   of	
   evidence-­‐based	
   treatments	
   provide	
   procedures	
   for	
   managing	
   transitions,	
   from	
   activity	
   to	
   activity,	
   from	
   setting	
   to	
   setting,	
   and	
   from	
   period	
   of	
   instruction	
   to	
   period	
  of	
  instruction	
  (shorter	
  or	
  longer	
  periods	
  of	
  time)	
  (NRC,	
  2001).	
  While	
  this	
  focus	
  existed	
  in	
   special,	
   model	
   treatments	
   since	
   the	
   early	
   1970’s,	
   with	
   IDEA’s	
   directives	
   of	
   Free	
   Appropriate	
   Public	
  Education	
  (FAPE)	
  in	
  Least	
  Restrictive	
  Environments	
  (LRE),	
  and	
  the	
  resulting	
  access	
  gained	
   by	
  children	
  with	
  ASD	
  to	
  regular	
  school	
  setting,	
  there	
  was	
  renewed	
  interest	
  in	
  teaching	
  children	
   with	
  ASD	
  to	
  transition	
  smoothly	
  across	
  educational	
  activities	
  and	
  settings	
  (Wolery	
  et	
  al.,	
  1998a,	
   b;	
  2002).	
  The	
  importance	
  of	
  this	
  topic	
  is	
  summarized	
  in	
  a	
  volume	
  by	
  Rous	
  &	
  Hallam	
  (2006).	
  This	
   work,	
  in	
  this	
  volume	
  as	
  well	
  as	
  more	
  globally,	
  as	
  summarized	
  in	
  the	
  consensual	
  conclusions	
  of	
   the	
   National	
   Research	
   Council	
   (NRC,	
   2001),	
   focuses	
   not	
   only	
   on	
   child-­‐specific	
   recommendations,	
   but	
   also	
   on	
   institutional	
   ones,	
   as	
   the	
   collaborative	
   engagement	
   of	
   schools	
   and	
   their	
   personnel	
   is	
   thought	
   to	
   be	
   cardinal	
   elements	
   of	
   effective	
   procedures	
   for	
   managing	
   transitions	
  of	
  children	
  with	
  ASD.	
  	
   	
   When	
  addressing	
  disruptive	
  behaviors	
  by	
  students	
  with	
  ASD,	
  The	
  NRC	
  executive	
  summary	
  built	
   on	
   a	
   vast	
   and	
   growing	
   literature	
   (e.g.,	
   Dawson	
   &	
   Osterling,	
   1997;	
   Rogers,	
   1998),	
   bringing	
   attention	
   to	
   elements	
   of	
   educational	
   programming	
   that	
   need	
   to	
   be	
   addressed	
   in	
   order	
   to	
   contextualize,	
  and	
  better	
  manage,	
  the	
  challenges	
  of	
  these	
  students	
  (NRC,	
  2001).	
  Among	
  these	
   are:	
   highly	
   supportive	
   teaching	
   environments	
   and	
   generalization	
   strategies;	
   predictability	
   and	
   routine;	
  a	
  functional	
  approach	
  to	
  problem	
  behaviors;	
  plans	
  for	
  transition	
  from	
  classrooms;	
  and	
   family	
   involvement.	
   Echoing	
   a	
   time	
   in	
   which	
   children’s	
   disruptive	
   behaviors	
   were	
   discussed	
   without	
   a	
   discussion	
   of	
   the	
   educational	
   environment	
   and	
   supports,	
   the	
   committee	
   stated	
   that	
   “Programs	
   that	
   do	
   not	
   include	
   these	
   features	
   should	
   be	
   re-­‐evaluated	
   for	
   suitability	
   before	
   discussing	
  the	
  ‘suitability’	
  of	
  the	
  disruptive	
  student”	
  (p.	
  120).	
  	
  	
   	
   Subsequent	
   task	
   forces	
   in	
   the	
   US	
   and	
   in	
   other	
   countries	
   made	
   the	
   same	
   conclusions	
   and	
   recommendations.	
  Attention	
  to	
  the	
  management	
  of	
  transitions	
  was	
  emphasized	
  in	
  educational	
   literature	
  (e.g.,	
  Iovannone	
  et	
  al.,	
  2003),	
  in	
  large	
  scale	
  reviews	
  of	
  the	
  clinical	
  science	
  literature	
  in	
   the	
   US	
   (NAC,	
   2009),	
   as	
   well	
   as	
   in	
   the	
   UK	
   (Charman	
   et	
   al.,	
   2011).	
   One	
   key	
   recommendation	
   stated	
  the	
  need	
  for	
  effective	
  transfer	
  of	
  information	
  and	
  knowledge	
  about	
  the	
  pupil	
  with	
  ASD	
  in	
   the	
  transition	
  from	
  primary	
  to	
  secondary	
  school,	
  and	
  from	
  school	
  setting	
  to	
  school	
  setting	
  more	
   generally.	
  	
   	
   The	
   centrality	
   and	
   importance	
   of	
   these	
   principles	
   have	
   grown	
   over	
   the	
   years	
   in	
   authoritative	
   texts	
  focused	
  on	
  educational	
  programming	
  for	
  children	
  with	
  ASD.	
  A	
  recent	
  compilation	
  (Prelock	
   &	
  McCauley,	
  2012)	
  highlighted	
  the	
  increasing	
  recognition	
  in	
  policies	
  and	
  research	
  that	
  parents	
   must	
   be	
   at	
   the	
   core	
   of	
   all	
   decision-­‐making	
   about	
   their	
   children	
   with	
   ASDs	
   (as	
   previously	
   emphasized	
   in	
   NRC,	
   2001;	
   Iovannone	
   et	
   al.,	
   2003;	
   NAC,	
   2009);	
   and	
   that	
   procedures	
   for	
   managing	
   transitions	
   are	
   key	
   standards	
   of	
   educational	
   programming	
   for	
   children	
   with	
   ASD	
   (as	
   previously	
   emphasized	
   by	
   a	
   vast	
   clinical	
   science	
   literature;	
   e.g.,	
   Dettmer	
   et	
   al.,	
   2000;	
   Briody	
   &	
   McGarry,	
  2005;	
  Schreibman	
  et	
  al.,	
  2000).	
  	
   	
   The	
  standards	
  for	
  adequately	
  managing	
  transitions,	
  though	
  varying	
  on	
  the	
  basis	
  of	
  the	
  children	
   served,	
   all	
   emphasize	
   anticipation	
   and	
   preparation	
   (Handleman	
   &	
   Harris,	
   2000).	
   This	
   is	
   usually	
  

6	
  

	
  

Case 2:11-cv-04027-LDD Document 48-36 Filed 07/13/12 Page 8 of 84

	
  

P.V.	
  ex	
  rel.	
  Valentin	
  and	
  Cruz,	
  et	
  al.,	
  v.	
  School	
  District	
  of	
  Phila.,	
  et	
  al.	
  (E.D.	
  Pa.)	
  –	
  Consultation	
  by	
  Ami	
  Klin	
  PhD	
  

done	
   as	
   a	
   process	
   that	
   occurs	
   across	
   the	
   child’s	
   last	
   months	
   prior	
   to	
   program	
   exit,	
   beginning	
   with	
  staff	
  visits	
  to	
  future	
  schools	
  to	
  assess	
  the	
  match	
  of	
  child	
  with	
  placement	
  and	
  to	
  determine	
   specific	
   skills	
   the	
   child	
   will	
   need	
   to	
   function	
   successfully	
   in	
   the	
   next	
   environment.	
   Receiving	
   teachers	
   are	
   invited	
   to	
   get	
   an	
   understanding	
   of	
   the	
   child’s	
   history,	
   including	
   responses	
   to	
   management	
   and	
   teaching	
   characteristics,	
   and	
   follow-­‐up	
   consultation	
   is	
   offered	
   to	
   receiving	
   classrooms,	
   among	
   many	
   other	
   transition	
   procedures	
   (Handleman	
   &	
   Harris,	
   2000).	
   In	
   the	
   absence	
   of	
   these	
   procedures,	
   a	
   whole	
   range	
   of	
   results	
   may	
   occur:	
   learning	
   rates	
   may	
   slow	
   down	
   or	
   the	
   child	
   may	
   actually	
   regress	
   from	
   achievement	
   levels	
   reached	
   in	
   the	
   previous	
   environment;	
   management	
   lessons	
   accrued	
   over	
   the	
   period	
   of	
   the	
   child’s	
   attendance	
   to	
   the	
   previous	
   environment	
   (e.g.,	
   from	
   the	
   teacher’s	
   experience,	
   from	
   IEP	
   discussions,	
   from	
   Functional	
   Behavioral	
   Assessments	
   (FBAs))	
   may	
   not	
   transfer,	
   and	
   in	
   fact,	
   the	
   child’s	
   behaviors	
   may	
   be	
   exacerbated	
   as	
   old,	
   maladaptive	
   contingencies	
   recur;	
   and	
   more	
   generally,	
   given	
   the	
   novelty	
   of	
   the	
   physical	
   environment,	
   children	
   “mix”,	
   routines	
   and	
   procedures,	
   all	
   of	
   which	
   signifying	
   major	
   changes	
   in	
   the	
   child’s	
   rigid	
   expectations,	
   the	
   likelihood	
   of	
   major	
   disruption	
   in	
   positive	
  adaptation	
  and	
  of	
  exacerbation	
  of	
  maladaptive	
  patterns	
  of	
  adaptation	
  is	
  great,	
  and	
  can	
   pose	
   a	
   major	
   threat	
   to	
   the	
   child’s	
   ability	
   to	
   fit	
   in	
   the	
   new	
   educational	
   setting	
   (Olley,	
   2005;	
   Handleman	
  &	
  Harris,	
  2000;	
  Prelock	
  &	
  McCauley,	
  2012;	
  NRC,	
  2001).	
  	
   	
   The	
   clinical	
   science	
   literature	
   on	
   the	
   association	
   between	
   transitions	
   and	
   behavioral	
   problems	
   in	
  ASD	
  is	
  too	
  voluminous	
  to	
  summarize	
  here	
  in	
  greater	
  detail.	
  Equally	
  large	
  is	
  the	
  literature	
  on	
   strategies	
   to	
   manage	
   transitions	
   so	
   as	
   to	
   minimize	
   disruption	
   and	
   problem	
   behaviors.	
   But	
   this	
   literature,	
   consensually,	
   integrates	
   several	
   decades	
   of	
   research	
   and	
   its	
   integration	
   into	
   educational	
  practices	
  in	
  terms	
  of:	
   	
   (1)	
  a	
  clear	
  and	
  frequent	
  causative	
  association	
  between	
  the	
  characteristics	
  of	
  children	
  with	
  ASD	
   and	
  disruptive	
  effects	
  on	
  learning	
  and	
  behavioral	
  patterns	
  related	
  to	
  transitions;	
   (2)	
   the	
   importance	
   of	
   using	
   consensual	
   tools	
   for	
   managing	
   and	
   attenuation	
   of	
   the	
   deleterious	
   effects	
  of	
  transitions	
  proactively,	
  including	
  parental	
  involvement	
  (discussed	
  further	
  below);	
  and	
   (3)	
  the	
  centrality	
  of	
  these	
  considerations	
  to	
  compliance	
  with	
  IDEA	
  statutes.	
   	
   (Sterling-­‐Turner	
  &	
  Jordan,	
  2007;	
  Prelock	
  &	
  McCauley,	
  2012;	
  Hume,	
  2008;	
  Dettmer	
  et	
  al.,	
  2000;	
   Flannery	
  &	
  Honer,	
  1994;	
  Flannery	
  et	
  al.,	
  1995;	
  Mesibov	
  et	
  al.,	
  2005;	
  Sainato	
  et	
  al.,	
  1987;	
  Schmit	
   et	
   al.,	
   2000;	
   Sterling-­‐Turner	
   &	
   Jordan,	
   2007;	
   McCord	
   et	
   al.,	
   2001;	
   Schreibman	
   et	
   al.,	
   2000;	
   Tustin,	
  1995;	
  Wilder	
  et	
  al.,	
  2006).	
   	
   Both	
  summarizing	
  the	
  preceding	
  body	
  of	
  data,	
  and	
  presaging	
  the	
  thrust	
  of	
  educational	
  research	
   in	
   the	
   following	
   decade,	
   the	
   NRC	
   Committee	
   stipulated	
   the	
   following	
   quality	
   indicators	
   for	
   programs	
  serving	
  children	
  with	
  ASD	
  (NRC,	
  2001):	
   	
   (1)	
  child-­‐specific	
  curricula;	
  	
   (2)	
  highly	
  supportive	
  instructional	
  environments;	
   (3)	
  maintenance	
  and	
  generalization	
  strategies;	
   (4)	
  predictable	
  routines;	
   (5)	
  functional	
  behavior	
  management	
  procedures;	
  

7	
  

	
  

Case 2:11-cv-04027-LDD Document 48-36 Filed 07/13/12 Page 9 of 84

	
  

P.V.	
  ex	
  rel.	
  Valentin	
  and	
  Cruz,	
  et	
  al.,	
  v.	
  School	
  District	
  of	
  Phila.,	
  et	
  al.	
  (E.D.	
  Pa.)	
  –	
  Consultation	
  by	
  Ami	
  Klin	
  PhD	
  

(6)	
  systematic	
  transitional	
  planning;	
  

(7)	
  collaborative	
  family	
  involvement;	
  

(8)	
  family	
  supports;	
  

(9)	
  low	
  student-­‐to-­‐staff	
  ratios;	
  

(10)	
  highly	
  trained	
  staff;	
  

(11)	
  comprehensive	
  professional	
  resources;	
  and	
  

(12)	
  staff	
  supervision	
  and	
  program	
  review	
  mechanisms.	
  	
  

	
  

	
  

04.	
  Transitions,	
  Problems	
  Behaviors,	
  and	
  the	
  Individualized	
  Education	
  Program	
  (IEP)	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  

	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  Process:	
  

	
  

As	
   summarized	
   in	
   the	
   NRC	
   document	
   (NRC,	
   2001),	
   no	
   single	
   intervention	
   has	
   been	
   shown	
   to	
  

deal	
   effectively	
   with	
   problem	
   behaviors	
   for	
   children	
   with	
   ASD.	
   The	
   consensus	
   among	
  

developmental,	
   psychosocial,	
   applied	
   behavior	
   and	
   legal	
   experts	
   is	
   that	
   prevention	
   of	
   such	
  

problems	
  should	
  be	
  a	
  primary	
  focus	
  (Berkson	
  &	
  Tupa,	
  2000;	
  Schroeder	
  et	
  al.,	
  1986;	
  Iovannone	
  

et	
   al.,	
   2003).	
   There	
   is	
   also	
   a	
   consensus	
   that	
   the	
   most	
   effective	
   form	
   of	
   prevention	
   of	
   problem	
  

behaviors	
   is	
   the	
   provision	
   and	
   implementation	
   of	
   an	
   appropriate	
   Individualized	
   Education	
  

Program	
   (IEP).	
   In	
   this	
   way,	
   plans	
   and	
   educational	
   decisions	
   build	
   on	
   the	
   individual	
   child’s	
  

strengths	
   and	
   vulnerabilities,	
   as	
   well	
   as	
   the	
   child’s	
   patterns	
   of	
   responses	
   to	
   specific	
   teaching	
  

and	
   management	
   strategies.	
   The	
   NRC	
   report	
   also	
   quotes	
   a	
   report	
   by	
   the	
   New	
   York	
   State	
  

Department	
   of	
   Health	
   panel	
   that	
   developed	
   the	
   state’s	
   Clinical	
   Practice	
   Guidelines	
   for	
   Autism	
  

and	
  Pervasive	
  Developmental	
  Disorders	
  (NYSD,	
  1999):	
  “The	
  use	
  of	
  an	
  ineffective	
  assessment	
  or	
  

intervention	
  method	
  [is]	
  a	
  type	
  of	
  indirect	
  harm	
  if	
  its	
  use	
  supplants	
  an	
  effective	
  assessment	
  or	
  

intervention	
  method	
  that	
  the	
  child	
  might	
  have	
  otherwise	
  received”.	
  	
  

	
  

The	
   1999	
   U.S.	
   Department	
   of	
   Education	
   Regulations	
   for	
   the	
   1997	
   Amendments	
   to	
   the	
  

Individuals	
   with	
   Disabilities	
   Education	
   Act	
   (IDEA)	
   provides	
   for	
   scientifically	
   supported	
  

Interventions	
   (e.g.,	
   20	
   U.S.C.	
   §	
  1400(4)).	
   The	
   IDEA	
   further	
   requires	
   that	
   schools	
   must	
   confirm,	
  

before	
  any	
  changes	
  of	
  placement	
  due	
  to	
  a	
  behavioral	
  problem	
  can	
  be	
  considered,	
  that	
  the	
  IEP	
  

and	
   placement	
   were	
   appropriate	
   and	
   that	
   special	
   education	
   services,	
   supplementary	
   aids	
   and	
  

services,	
   and	
   behavior	
   intervention	
   strategies	
   were	
   provided	
   consistent	
   with	
   the	
   IEP	
   and	
  

placement	
   (34	
   C.F.R.	
   §§	
  300.523,	
   1999;	
   Turnbull	
   et	
   al.,	
   1999).	
   In	
   summary,	
   before	
   assessing	
  

deficiencies	
  in	
  a	
  child	
  who	
  is	
  displaying	
  disruptive	
  behaviors,	
  it	
  is	
  critical	
  to	
  assess	
  the	
  adequacy	
  

of	
  the	
  intervention	
  program	
  the	
  child	
  is	
  receiving.	
  IDEA	
  requires	
  that	
  interventions	
  must	
  show	
  

demonstrable	
  benefits	
  to	
  be	
  continued.	
  For	
  these	
  conditions	
  to	
  hold,	
  the	
  IEP	
  process	
  needs	
  to	
  

be	
  implemented,	
  and,	
  for	
  a	
  child	
  about	
  to	
  move	
  school	
  setting,	
  the	
  transition	
  elements	
  of	
  this	
  

IEP	
   need	
   to	
   be	
   carefully	
   conceived,	
   in	
   an	
   individualized	
   fashion,	
   with	
   participation	
   of	
   all	
   those	
  

pertinent	
  who	
  know	
  the	
  child	
  well	
  but	
  certainly	
  the	
  teachers	
  and	
  parents,	
  and	
  with	
  integration	
  

of	
   past	
   information	
   (e.g.,	
   the	
   corpus	
   of	
   evaluations	
   and	
   observations	
   on	
   the	
   child	
   in	
   the	
  

previous	
   setting)	
   and	
   future	
   setting	
   (e.g.,	
   an	
   evaluation	
   of	
   the	
   match	
   between	
   child	
   and	
   new	
  

setting	
  with	
  full	
  support	
  of	
  educational	
  professionals	
  who	
  will	
  take	
  over	
  the	
  child’s	
  educational	
  

programming).	
   In	
   this	
   context,	
   it	
   is	
   worth	
   re-­‐iterating	
   the	
   principles	
   and	
   standards	
   of	
  

appropriate	
   programming	
   highlighted	
   by	
   the	
   NRC	
   report	
   and	
   singled	
   out	
   in	
   their	
   executive	
  

8	
  

	
  

Case 2:11-cv-04027-LDD Document 48-36 Filed 07/13/12 Page 10 of 84

	
  

P.V.	
  ex	
  rel.	
  Valentin	
  and	
  Cruz,	
  et	
  al.,	
  v.	
  School	
  District	
  of	
  Phila.,	
  et	
  al.	
  (E.D.	
  Pa.)	
  –	
  Consultation	
  by	
  Ami	
  Klin	
  PhD	
  

summary	
  (NRC,	
  2001,	
  pp.	
  119-­‐120),	
  among	
  which,	
  the	
  most	
  pertinent	
  to	
  the	
  current	
  discussion	
  

are:	
  	
  

	
  

(1)	
   Curriculum	
   content	
   that	
   emphasize	
   direct	
   instruction	
   in	
   basic	
   skills	
   domains	
   and	
   abilities:	
  

attending	
   to	
   elements	
   of	
   the	
   environment	
   that	
   are	
   essential	
   for	
   learning,	
   especially	
   to	
   social	
  

stimuli;	
   imitating	
   others;	
   comprehending	
   and	
   using	
   language;	
   playing	
   appropriately	
   with	
   toys,	
  

and	
  interacting	
  socially	
  with	
  others;	
  	
  

(2)	
  Highly	
  supportive	
  teaching	
  environments	
  and	
  generalization	
  strategies;	
  

(3)	
  Predictability	
  and	
  routine;	
  

(4)	
  Functional	
  approach	
  to	
  problem	
  behaviors;	
  

(5)	
  Plans	
  for	
  transitions;	
  and	
  

(6)	
  Family	
  involvement.	
  

	
  

None	
  of	
  these	
  standards	
  can	
  be	
  implemented	
  without	
  implementation	
  of	
  the	
  IEP	
  process	
  in	
  the	
  

spirit	
  of	
  the	
  statute	
  and	
  in	
  the	
  way	
  that	
  it	
  is	
  implemented	
  in	
  compliant	
  school	
  settings	
  (i.e.,	
  with	
  

a	
   focus	
   on	
   the	
   individual	
   child’s	
   profile	
   of	
   strengths	
   and	
   weaknesses,	
   and	
   with	
   parental	
  

participation).	
  	
  

	
  

Given	
   the	
   association	
   between	
   transitions	
   and	
   problem	
   behaviors	
   in	
   children	
   with	
   ASD,	
   the	
  

implementation	
  of	
  the	
  IEP	
  process	
  and	
  its	
  importance	
  is	
  further	
  highlighted	
  by	
  considering	
  one	
  

key	
  requirement	
  of	
  the	
  IDEA	
  statute.	
  This	
  point	
  receives	
  great	
  attention	
  in	
  the	
  NRC	
  report	
  (NRC,	
  

2001).	
   IDEA	
   requires	
   that	
   if	
   a	
   child’s	
   behavior	
   impedes	
   his	
   or	
   her	
   learning	
   or	
   the	
   learning	
   of	
  

others,	
  the	
  IEP	
  team	
  must	
  consider	
  strategies	
  and	
  supports	
  to	
  address	
  that	
  behavior	
  (20	
  U.S.C.	
  

§	
  1414(d)(3)(B)(i),	
   1999;	
   34	
   C.F.R.	
   §	
  300.346(a)(2)(i),	
   1999).	
   As	
   summarized	
   by	
   Turnbull	
   and	
  

colleagues	
  (1999)	
  for	
  the	
  NRC	
  Committee	
  (NRC,	
  2001),	
  these	
  intervention	
  and	
  supports	
  include:	
  

	
  

(1)	
   systems	
   change	
   (e.g.,	
   the	
   process	
   of	
   considering,	
   modifying,	
   or	
   substantially	
   changing	
   an	
  

agency’s	
  policies,	
  procedures,	
  practices,	
  personnel,	
  organization,	
  environment,	
  or	
  funding);	
  

(2)	
   environmental	
   alterations	
   (including	
   building	
   on	
   a	
   child’s	
   strengths	
   and	
   preferences,	
  

connecting	
  the	
  child	
  with	
  community	
  supports,	
  increasingly	
  the	
  quality	
  of	
  the	
  student’s	
  physical	
  

environment,	
  making	
  environmental	
  alterations);	
  

(3)	
   skill	
   instruction	
   (consisting	
   of	
   instruction	
   for	
   both	
   the	
   student	
   and	
   those	
   who	
   interact	
   with	
  

him	
   or	
   her	
   on	
   the	
   whole	
   range	
   of	
   educational	
   and	
   social/communicative	
   and	
   adaptive	
   goals);	
  

and	
  

(4)	
   behavioral	
   consequences	
   (promoting	
   adaptive	
   behavior	
   and	
   minimizing	
   disruptive	
  

behavior).	
  	
  

	
  

	
  

05.	
  The	
  Role	
  of	
  Parental	
  Involvement	
  in	
  the	
  Individualized	
  Education	
  Program	
  	
   	
  	
  	
  	
  	
  

	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  (IEP)	
  Process:	
  

	
  

A	
  key	
  aspect	
  of	
  model	
  programs	
  of	
  intervention	
  in	
  the	
  country	
  conceived	
  in	
  the	
  1970’s	
  through	
  

the	
   1990’s,	
   as	
   summarized	
   by	
   Handleman	
   &	
   Harris	
   (2000),	
   was	
   families’	
   active	
   involvement	
   in	
  

their	
   children’s	
   intervention.	
   This	
   element	
   takes	
   different	
   forms	
   but	
   typically	
   includes	
  

participation	
   in	
   individual	
   meetings	
   with	
   professionals	
   at	
   the	
   educational	
   setting,	
   some	
  

9	
  

	
  

Case 2:11-cv-04027-LDD Document 48-36 Filed 07/13/12 Page 11 of 84

	
  

P.V.	
  ex	
  rel.	
  Valentin	
  and	
  Cruz,	
  et	
  al.,	
  v.	
  School	
  District	
  of	
  Phila.,	
  et	
  al.	
  (E.D.	
  Pa.)	
  –	
  Consultation	
  by	
  Ami	
  Klin	
  PhD	
  

instruction	
   and/or	
   training	
   on	
   promoting	
   consistency	
   of	
   approaches	
   across	
   environments,	
   and	
  

pooling	
   of	
   information	
   across	
   settings	
   in	
   order	
   to	
   better	
   inform	
   –	
   both	
   the	
   educational	
  

professionals	
   and	
   the	
   family	
   –	
   discussions	
   on	
   optimal	
   strategies	
   to	
   promote	
   learning	
   and	
  

decrease	
  disruptive	
  behaviors	
  while	
  advancing	
  generalization	
  of	
  skills	
  across	
  settings.	
  The	
  NRC	
  

Committee’s	
   (NRC,	
   2001)	
   summary	
   of	
   this	
   work	
   concludes	
   that	
   all	
   model	
   programs	
   reviewed	
  

place	
   a	
   high	
   priority	
   on	
   parental	
   involvement	
   in	
   the	
   education	
   of	
   their	
   children	
   with	
   ASD,	
   and	
  

commented	
   on	
   the	
   trend	
   towards	
   broadened	
   parent	
   supports	
   reflecting	
   the	
   consensual	
  

appreciation	
  of	
  the	
  challenges	
  faced	
  by	
  these	
  families.	
  	
  

	
  

This	
   appreciation	
   is	
   also	
   part	
   of	
   the	
   IDEA	
   statute,	
   where	
   parental	
   participation	
   is	
   discussed	
  

explicitly	
   and	
   in	
   detail.	
   Consistent	
   with	
   the	
   literature	
   on	
   the	
   importance	
   of	
   parental	
  

involvement	
   in	
   programming	
   for	
   students	
   with	
   ASDs,	
   parents	
   are	
   to	
   be	
   included	
   in	
   the	
  

development	
  of	
  the	
  Individualized	
  Education	
  Program	
  (IEP),	
  and	
  all	
  that	
  it	
  entails.	
  	
  

	
  

The	
  role	
  of	
  families	
  and	
  their	
  effective	
  participation	
  in	
  educational	
  programming	
  is	
  reviewed	
  in	
  

great	
   detail	
   in	
   the	
   NRC	
   report	
   (NRC,	
   2001):	
   “Parents	
   can	
   learn	
   to	
   successfully	
   apply	
   skills	
   to	
  

changing	
   their	
   children’s	
   behavior.	
   Parents’	
   use	
   of	
   effective	
   teaching	
   methods,	
   support	
   from	
  

within	
   the	
   family	
   and	
   the	
   community,	
   and	
   access	
   to	
   balanced	
   information	
   about	
   ASD	
   and	
   the	
  

range	
   of	
   appropriate	
   services	
   can	
   contribute	
   to	
   successful	
   child	
   and	
   family	
   functioning.	
   It	
   is	
  

crucially	
   important	
   to	
   make	
   information	
   available	
   to	
   parents	
   to	
   ensure	
   their	
   active	
   role	
   in	
  

advocacy	
   for	
   their	
   children’s	
   education”	
   (p.	
   4	
   of	
   the	
   Executive	
   Summary;	
   NRC,	
   2001).	
   Their	
  

recommendation	
   is	
   expressed	
   thus:	
   “The	
   committee	
   recommends	
   that	
   families’	
   participation	
  

should	
   be	
   supported	
   in	
   education	
   through	
   consistent	
   presentation	
   of	
   information	
   by	
   local	
  

school	
  systems,	
  through	
  ongoing	
  consultation	
  and	
  individualized	
  problem	
  solving,	
  and	
  through	
  

the	
   opportunity	
   to	
   learn	
   techniques	
   for	
   teaching	
   their	
   children	
   new	
   skills	
   and	
   reducing	
  

behavioral	
   problems.	
   Although	
   families	
   should	
   not	
   be	
   expected	
   to	
   provide	
   the	
   majority	
   of	
  

educational	
  programming	
  for	
  their	
  child,	
  the	
  parents’	
  concerns	
  and	
  perspectives	
  should	
  actively	
  

help	
   shape	
   educational	
   planning”	
   (p.	
   4	
   of	
   the	
   Executive	
   Summary;	
   NRC,	
   2001).	
   These	
  

conclusions	
   are	
   based	
   on	
   a	
   large	
   body	
   of	
   literature	
   on	
   parental	
   involvement	
   in	
   ASD	
   children’s	
  

educational	
   and	
   treatment	
   planning.	
   This	
   literature	
   spans	
   the	
   areas	
   of	
   advocacy,	
   fostering	
  

generalization	
  of	
  skills,	
  addressing	
  and	
  managing	
  problem	
  behaviors,	
  attenuating	
  the	
  effects	
  of	
  

transitions,	
  generating	
  a	
  comprehensive	
  view	
  of	
  the	
  child	
  beneficial	
  to	
  families	
  and	
  educational	
  

professionals	
  alike,	
  among	
  many	
  others	
  (several	
  chapters	
  of	
  this	
  compilation	
  include	
  pertinent	
  

discussion	
  on	
  this	
  topic;	
  Volkmar	
  et	
  al.,	
  2005).	
  	
  

	
  

	
  

06.	
  Unplanned	
  Transitions	
  and	
  the	
  Individualized	
  Education	
  Program	
  (IEP)	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  

	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  Process:	
  

	
  

The	
  requirements	
  for	
  determining	
  the	
  placement	
  of	
  a	
  child	
  with	
  a	
  disability	
  are	
  included	
  in	
  the	
  

IDEA	
  Part	
  B	
  regulations	
  at	
  34	
  CFR	
  §§	
  300.114	
  through	
  300.118.	
  These	
  regulations	
  provide	
  that	
  

to	
   the	
   maximum	
   extent	
   appropriate,	
   children	
   with	
   disabilities,	
   including	
   in	
   public	
   or	
   private	
  

institutions	
  or	
  other	
  care	
  facilities,	
  are	
  to	
  be	
  educated	
  with	
  children	
  who	
  are	
  not	
  disabled	
  and	
  

that	
   special	
   classes,	
   separate	
   schooling	
   or	
   other	
   removal	
   of	
   children	
   with	
   disabilities	
   from	
   the	
  

regular	
   educational	
   environment	
   occurs	
   only	
   if	
   the	
   nature	
   or	
   severity	
   of	
   the	
   disability	
   is	
   such	
  

10	
  

	
  

Case 2:11-cv-04027-LDD Document 48-36 Filed 07/13/12 Page 12 of 84

	
  

P.V.	
  ex	
  rel.	
  Valentin	
  and	
  Cruz,	
  et	
  al.,	
  v.	
  School	
  District	
  of	
  Phila.,	
  et	
  al.	
  (E.D.	
  Pa.)	
  –	
  Consultation	
  by	
  Ami	
  Klin	
  PhD	
  

that	
   education	
   in	
   regular	
   classes	
   with	
   the	
   use	
   of	
   supplementary	
   aids	
   and	
   services	
   cannot	
   be	
   achieved	
   satisfactorily.	
   These	
   regulations	
   also	
   require	
   that	
   the	
   placement	
   decision	
   for	
   each	
   child	
  be	
  made	
  by	
  a	
  group	
  of	
  persons,	
  including	
  the	
  parents,	
  and	
  other	
  persons	
  knowledgeable	
   about	
   the	
   child,	
   the	
   meaning	
   of	
   the	
   evaluation	
   data,	
   and	
   the	
   placement	
   options.	
   A	
   child’s	
   placement	
  must	
  be	
  determined	
  on	
  an	
  individual,	
  case-­‐by-­‐case	
  basis,	
  depending	
  on	
  each	
  child’s	
   unique	
   needs	
   and	
   circumstances,	
   made	
   at	
   least	
   annually,	
   based	
   on	
   the	
   child’s	
   Individualized	
   Education	
  Program	
  (IEP),	
  and	
  be	
  as	
  close	
  as	
  possible	
  to	
  the	
  child’s	
  home.	
  Recognizing	
  that	
  there	
   is	
   no	
   “one	
   size	
   fits	
   all”	
   approach,	
   and	
   that	
   placements	
   in	
   regular	
   classes	
   may	
   not	
   be	
   the	
   least	
   restrictive	
   placement	
   for	
   every	
   child	
   with	
   a	
   disability,	
   the	
   IDEA	
   regulations	
   specify	
   that	
   each	
   public	
  agency	
  is	
  to	
  ensure	
  that	
  a	
  continuum	
  of	
  alternative	
  placements	
  (including	
  instruction	
  in	
   regular	
   classes,	
   special	
   classes,	
   special	
   schools,	
   home	
   instruction,	
   and	
   instruction	
   in	
   hospitals	
   and	
  institutions)	
  is	
  available	
  to	
  meet	
  the	
  needs	
  of	
  children	
  with	
  disabilities	
  for	
  special	
  education	
   and	
  related	
  services.	
  	
  	
   	
   As	
   these	
   regulations	
   make	
   clear,	
   placement	
   decisions	
   must	
   be	
   made	
   on	
   an	
   individual	
   basis.	
  	
   Placements	
   that	
   are	
   determined	
   based	
   solely	
   on	
   the	
   category	
   of	
   a	
   child’s	
   disability	
   are	
   not	
   consistent	
  with	
  the	
  regulations.	
  A	
  child	
  may	
  be	
  placed	
  in	
  a	
  special	
  purpose	
  school	
  for	
  students	
   with	
   ASD	
   only	
   if	
   the	
   placement	
   team,	
   consistent	
   with	
   34	
   CFR	
   §§	
   300.114	
   through	
   300.117,	
   determines	
   that	
   placement	
   to	
   be	
   necessary	
   to	
   meet	
   the	
   needs	
   of	
   that	
   child	
   and	
   that	
   the	
   child	
   cannot	
  be	
  educated	
  satisfactorily	
  in	
  a	
  less	
  restrictive	
  setting,	
  even	
  with	
  the	
  use	
  of	
  appropriate	
   supplementary	
  aids	
  and	
  services.	
  	
   	
   In	
   the	
   context	
   of	
   this	
   consultation,	
   there	
   are	
   some	
   points	
   to	
   highlight	
   in	
   regards	
   to	
   placement	
   decisions.	
   A	
   blanket	
   policy	
   that	
   children	
   with	
   ASD	
   are	
   to	
   be	
   placed	
   in	
   a	
   given	
   “autism-­‐ready	
   school”	
  or	
  another	
  school	
  from	
  year	
  to	
  year	
  means	
  that	
  they	
  are	
  not	
  being	
  programmed	
  for	
  as	
   individual	
   learners.	
   These	
   children	
   are	
   entitled	
   to	
   receive	
   Free	
   Appropriate	
   Public	
   Education	
   (FAPE)	
  in	
  the	
  Least	
  Restrictive	
  Environment	
  (LRE).	
  If	
  this	
  environment	
  is	
  judged	
  not	
  to	
  be	
  their	
   home	
   school,	
   this	
   decision,	
   per	
   IDEA,	
   has	
   to	
   be	
   based	
   on	
   having	
   substantiated	
   that	
   the	
   child	
   cannot	
  learn	
  appropriately	
  with	
  the	
  use	
  of	
  supplementary	
  aid	
  and	
  services,	
  as	
  outlined	
  in	
  Part	
  B	
   of	
  IDEA.	
  These	
  determinations	
  cannot	
  be	
  made	
  outside	
  the	
  IEP	
  process,	
  and,	
  therefore,	
  need	
  to	
   be	
  in	
  compliance	
  with	
  the	
  IEP	
  elements	
  of	
  the	
  IDEA	
  statutes,	
  which	
  is	
  in	
  accord	
  with	
  pertinent	
   clinical	
   science	
   literature.	
   In	
   summary,	
   significant	
   unplanned	
   transitions,	
   defined	
   here	
   as	
   transitions	
   that	
   do	
   not	
   comply	
   with	
   discussions	
   and	
   determinations	
   by	
   the	
   IEP	
   team,	
   are	
   inconsistent	
  with	
  the	
  IEP	
  statutes’	
  language,	
  spirit,	
  and	
  goals.	
  By	
  these	
  statutes,	
  consistent	
  with	
   clinical	
  science	
  literature,	
  parental	
  involvement	
  is	
  an	
  essential	
  element	
  of	
  the	
  IEP	
  process.	
  And,	
   as	
  the	
  literature	
  above	
  points	
  out,	
  the	
  IEP	
  process	
  not	
  only	
  determines	
  a	
  child’s	
  needs	
  relative	
   to	
  an	
  undetermined	
  future	
  program,	
  but,	
  in	
  order	
  to	
  consider	
  the	
  potentially	
  deleterious	
  effects	
   of	
  transitions,	
  the	
  IEP	
  process	
  also	
  considers	
  the	
  adequacy	
  of	
  placements	
  AND	
  operationalizes	
  a	
   plan	
  for	
  achieving	
  successful	
  transitions.	
  	
   	
   Finally,	
  as	
  part	
  of	
  the	
  review	
  of	
  materials	
  provided	
  by	
  plaintiffs’	
  counsel,	
  I	
  had	
  the	
  opportunity	
   to	
   read	
   Ms.	
   Williams’s	
   declaration	
   and	
   deposition.	
   Although	
   these	
   materials	
   provided	
   some	
   information	
   about	
   the	
   organizational	
   structure	
   for	
   decisions	
   on	
   special	
   education	
   placements	
   carried	
  out	
  in	
  the	
  School	
  District,	
  there	
  was	
  no	
  information	
  on	
  content	
  or	
  procedures	
  assuring	
  

11	
  

	
  

Case 2:11-cv-04027-LDD Document 48-36 Filed 07/13/12 Page 13 of 84

	
  

P.V.	
  ex	
  rel.	
  Valentin	
  and	
  Cruz,	
  et	
  al.,	
  v.	
  School	
  District	
  of	
  Phila.,	
  et	
  al.	
  (E.D.	
  Pa.)	
  –	
  Consultation	
  by	
  Ami	
  Klin	
  PhD	
  

that	
   transitions	
   decided	
   upon	
   for	
   special	
   education	
   children	
   with	
   ASD	
   (1)	
   both	
   involved	
   and	
   were	
  fully	
  discussed	
  with	
  parents,	
  and	
  (2)	
  were	
  a.	
  evaluated	
  fully,	
  b.	
  managed	
  proactively,	
  and	
   c.	
   thoughtfully	
   executed,	
   in	
   compliance	
   with	
   the	
   IEP	
   statute’s	
   spirit	
   and	
   procedural	
   recommendations	
   as	
   well	
   as	
   with	
   the	
   NRC	
   recommendations	
   (NRC,	
   2001).	
   In	
   fact,	
   Ms.	
   Williams’s	
   declaration	
   and	
   deposition	
   affirmatively	
   suggest	
   parents	
   are	
   not	
   meaningfully	
   involved	
   in	
   significant	
   unplanned	
   transitions.	
   Although,	
   clearly,	
   I	
   have	
   not	
   evaluated	
   the	
   children’s	
  actual	
  transitions	
  (e.g.,	
  making	
  direct	
  observations	
  of	
  children	
  and	
  of	
  classrooms),	
  the	
   parents’	
   depositions	
   point	
   to	
   their	
   strong	
   perceptions	
   and	
   observations	
   indicating	
   that	
   the	
   proposed	
  transitions	
  were	
  managed	
  very	
  poorly	
  (even	
  when	
  transitions	
  did	
  not	
  occur	
  because	
   of	
  the	
  “stay	
  put”	
  statute).	
  According	
  to	
  the	
  parents’	
  depositions,	
  transitions	
  were	
  announced	
  in	
   a	
   surprising,	
   haphazard	
   and	
   unsupported	
   fashion,	
   creating	
   hardships	
   for	
   children	
   and	
   families	
   alike,	
   and	
   failing	
   to	
   support	
   sending	
   and	
   receiving	
   teachers	
   (who	
   presumably	
   were	
   critically	
   aware	
  of	
  a.	
  the	
  importance	
  of	
  standards	
  and	
  procedures	
  described	
  above	
  in	
  this	
  report,	
  and	
  b.	
   are	
  critically	
  aware	
  of	
  the	
  potentially	
  disruptive	
  effects	
  upon	
  all	
  concerned	
  associated	
  with	
  not	
   following	
   these	
   recommendations).	
   In	
   sum,	
   as	
   explained	
   above,	
   the	
   School	
   District’s	
   practices	
   associated	
  with	
  the	
  transitioning	
  of	
  children	
  with	
  ASD	
  from	
  one	
  educational	
  setting	
  to	
  another	
   appear	
  to	
  be	
  inconsistent	
  with	
  best	
  practices	
  and	
  standards,	
  and	
  not	
  appropriate.	
   	
   I	
   remain	
   available	
   to	
   address	
   any	
   further	
   questions	
   related	
   to	
   the	
   topics	
   of	
   this	
   consultation,	
   and	
  appreciate	
  the	
  opportunity	
  to	
  try	
  and	
  contribute	
  to	
  this	
  important	
  discussion.	
  	
   	
   I	
   declare	
   under	
   penalty	
   of	
   perjury	
   that	
   the	
   foregoing	
   is	
   true	
   and	
   correct.	
   	
   Executed	
   on	
   June	
   8,	
   2012.	
   	
  

	
   	
  

Ami	
  Klin	
  PhD	
  

Director,	
  Marcus	
  Autism	
  Center,	
  Children’s	
  Healthcare	
  of	
  Atlanta	
  

Georgia	
  Research	
  Alliance	
  Eminent	
  Scholar	
  Professor	
  &	
  Chief,	
  Division	
  of	
  Autism	
  &	
  Related	
  

Disorders	
  

Department	
  of	
  Pediatrics,	
  Emory	
  University	
  School	
  of	
  Medicine	
  

	
  

	
  

12	
  

	
  

Case 2:11-cv-04027-LDD Document 48-36 Filed 07/13/12 Page 14 of 84

	
  

P.V.	
  ex	
  rel.	
  Valentin	
  and	
  Cruz,	
  et	
  al.,	
  v.	
  School	
  District	
  of	
  Phila.,	
  et	
  al.	
  (E.D.	
  Pa.)	
  –	
  Consultation	
  by	
  Ami	
  Klin	
  PhD	
  

	
  

	
  

	
  References	
  Cited:	
  

	
  

	
   APA	
  (2011).	
  American	
  Psychiatric	
  Association,	
  DSM-­‐5	
  Proposed	
  Revision	
  of	
  Criteria	
  for	
  Autism	
  

	
  

Spectrum	
  Disorder.	
  Arlington,	
  VA.	
  

	
  

http://www.dsm5.org/proposedrevisions/pages/proposedrevision.aspx?rid=94	
  	
  

	
  

	
  

Berkson	
  G.,	
  &	
  M.	
  Tupa	
  (2000).	
  Early	
  development	
  of	
  stereotyped	
  and	
  self-­‐injurious	
  behaviors.	
  

	
  

Journal	
  of	
  Early	
  Intervention,	
  23(1),	
  1-­‐19.	
  

	
  

	
  

Briody,	
  J.,	
  &	
  McGarry,	
  K.	
  (2005).	
  Using	
  social	
  stories	
  to	
  ease	
  children’s	
  transitions.	
  Young	
  	
  

	
   	
   Children,	
  60,	
  38–43.	
  

	
  

Charman,	
  T.,	
  Pellicano,	
  L.,	
  Peacey,	
  L.	
  V.,	
  &	
  Peacey,	
  N.	
  (2011).	
  Centre	
  for	
  Research	
  in	
  Autism	
  and	
  	
  

	
   	
   Education,	
  Department	
  of	
  Psychology	
  &	
  Human	
  Development,	
  Institute	
  of	
  Education.	
  	
  

	
   	
   What	
  is	
  good	
  practice	
  in	
  autism	
  education?	
  London:	
  University	
  of	
  London.	
  	
  

	
  

Dawson,	
  G.,	
  &	
  Osterling,	
  J.	
  (1997).	
  Early	
  intervention	
  in	
  autism:	
  Effectiveness	
  and	
  common	
  	
  

	
   	
   elements	
  of	
  current	
  approaches.	
  In	
  M.	
  J.	
  Guralnick	
  (ed).	
  The	
  Effectiveness	
  of	
  Early	
  	
  

	
   	
   Intervention:	
  Second	
  Generation	
  Research	
  (pp.	
  307-­‐326).	
  Baltimore,	
  MD:	
  Paul	
  H.	
  Brookes	
  

	
   	
   Publishing.	
  

	
  

Dettmer,	
  S.,	
  Simpson,	
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  Myles,	
  B.,	
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  (2000).	
  The	
  use	
  of	
  visual	
  supports	
  to	
  facilitate	
  	
  

	
   	
   transitions	
  of	
  students	
  with	
  autism.	
  Focus	
  on	
  Autism	
  and	
  Other	
  Developmental	
  	
   	
  

	
   	
   Disabilities,	
  15(3),	
  163–169.	
  

	
  

Flannery,	
  K.	
  B.,	
  O’Neill,	
  R.	
  E.,	
  &	
  Horner,	
  R.	
  H.	
  (1995).	
  Including	
  predictability	
  in	
  functional	
  	
  

	
  

assessment	
  and	
  individual	
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  development.	
  Education	
  and	
  Treatment	
  of	
  Children,	
  

	
  

18,	
  498–	
  509.	
  

	
  

	
  

Flannery,	
  K.	
  &	
  Horner,	
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  (1994).	
  The	
  relationship	
  between	
  predictability	
  and	
  problem	
  behavior	
  

	
  

for	
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  Journal	
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Handleman,	
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  S.,	
  &	
  Harris,	
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  Preschool	
  Education	
  Programs	
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  Children	
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2nd	
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  Austin,	
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Hume,	
  K.	
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  Transition	
  Time:	
  Helping	
  Individuals	
  on	
  the	
  Autism	
  Spectrum	
  move	
  

	
  

successfully	
  from	
  one	
  activity	
  to	
  another.	
  The	
  Report,	
  13(2),	
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Jones,	
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  Heterogeneity	
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  the	
  

	
  

role	
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  Journal	
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  Child	
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  Adolescent	
  

	
  

Psychiatry,	
  48(5),	
  471-­‐3.	
  

	
  

13	
  

	
  

Case 2:11-cv-04027-LDD Document 48-36 Filed 07/13/12 Page 15 of 84

	
  

P.V.	
  ex	
  rel.	
  Valentin	
  and	
  Cruz,	
  et	
  al.,	
  v.	
  School	
  District	
  of	
  Phila.,	
  et	
  al.	
  (E.D.	
  Pa.)	
  –	
  Consultation	
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  Ami	
  Klin	
  PhD	
  

	
  

Kanner,	
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  Autistic	
  disturbances	
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Klin,	
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  Danovitch,	
  J.	
  H.,	
  Dohrmann,	
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  Volkmar,	
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  Circumscribed	
  

	
  

interests	
  in	
  higher-­‐functioning	
  individuals	
  with	
  autism	
  spectrum	
  disorders:	
  an	
  

	
  

exploratory	
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  Research	
  and	
  Practice	
  for	
  Persons	
  with	
  Severe	
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  32(2),	
  89-­‐

	
  

100.	
  	
  

	
  

	
  

Lewis,	
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  Psychopharmacology	
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Developmental	
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Lord,	
  C.,	
  Petrova.,	
  E.	
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  Gan,	
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  Lu,	
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  al.	
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  A	
  multiside	
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diagnosis	
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  spectrum	
  disorders.	
  Archives	
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  69(3),	
  

	
  

306-­‐13.	
  

	
  

	
  

Lovannone,	
  R.,	
  Dunlap,	
  G.,	
  Huber,	
  H.,	
  &	
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  Effective	
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students	
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  Focus	
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  Autism	
  and	
  Other	
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Disabilities,	
  18(3),	
  150–165.	
  

	
  

McCord,	
  B.	
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  Thomson,	
  R.	
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  Functional	
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  Self-­‐

	
  

Injury	
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  Journal	
  of	
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  Behavior	
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  34(2),	
  195-­‐210.	
  	
  

	
  

	
  

Mesibov,	
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  The	
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disorders.	
  New	
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NAC	
  (2009).	
  National	
  Autism	
  Center:	
  National	
  Standards	
  Project—findings	
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  conclusions:	
  

	
  

Addressing	
  the	
  needs	
  for	
  evidence-­‐based	
  practice	
  guidelines	
  for	
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disorders.	
  Randolph,	
  MA.	
  

	
  

NRC	
  (2001).	
  National	
  Research	
  Council,	
  Committee	
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  Interventions	
  for	
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with	
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  Division	
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McGee,	
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Press.	
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NYSDH	
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  New	
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Guideline	
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  Developmental	
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http://www.health.ny.gov/community/infants_children/early_intervention/disorders/a

utism/	
  	
  

	
  

	
  

Olley,	
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Cohen	
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Volume	
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  New	
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Prelock,	
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  Treatment	
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   based	
  intervention	
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  for	
  communication	
  and	
  social	
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  New	
  York,	
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14	
  

	
  

Case 2:11-cv-04027-LDD Document 48-36 Filed 07/13/12 Page 16 of 84

	
  

P.V.	
  ex	
  rel.	
  Valentin	
  and	
  Cruz,	
  et	
  al.,	
  v.	
  School	
  District	
  of	
  Phila.,	
  et	
  al.	
  (E.D.	
  Pa.)	
  –	
  Consultation	
  by	
  Ami	
  Klin	
  PhD	
  

	
   	
   Paul	
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  Brookes	
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Rogers,	
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   autism.	
  Journal	
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Rous,	
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  Tools	
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for	
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  New	
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Sainato,	
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  Facilitating	
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handicapped	
  preschool	
  children:	
  A	
  comparison	
  between	
  peer	
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prompt	
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  Journal	
  of	
  Applied	
  Behavior	
  Analysis,	
  20,	
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Schmit,	
  J.,	
  Alper,	
  S.,	
  Raschke,	
  D.,	
  &	
  Ryndak,	
  D.	
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  Effects	
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package	
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  school	
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  a	
  child	
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Retardation,	
  38,	
  131-­‐137.	
  

	
  

	
  

Schreibman,	
  L.,	
  Whalen,	
  C.,	
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  Stahmer,	
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  The	
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   disruptive	
  transition	
  behavior	
  in	
  children	
  with	
  autism.	
  Journal	
  of	
  Positive	
  Behavior	
  	
  

	
   	
   Interventions,	
  2(1),	
  3–11.	
  

	
  

Schroeder,	
  S.	
  R.,	
  Bickel,	
  W.	
  K.	
  &	
  Richmond,	
  G.	
  (1986).	
  Primary	
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  secondary	
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injurious	
  behaviors:	
  A	
  life-­‐long	
  problem.	
  Advances	
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  Learning	
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Disabilities,	
  5,	
  63-­‐85.	
  

	
  

	
  

Sterling-­‐Turner,	
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  Interventions	
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individuals	
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Disorders,	
  4(7),	
  681–690.	
  	
  

	
  

	
  

Symons,	
  F.	
  J.,	
  Butler,	
  M.	
  G.,	
  Sanders,	
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behavior	
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  American	
  

	
  

Journal	
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Thompson,	
  T.,	
  Symons,	
  F.,	
  Delaney,	
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  Self-­‐injurious	
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endogenous	
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Disabilities	
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Turnbull,	
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Education	
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Committee	
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Council,	
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  University	
  of	
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Tustin,	
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behavior.	
  Journal	
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  Behavior	
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  28,	
  91–92.	
  

	
  

15	
  

	
  

Case 2:11-cv-04027-LDD Document 48-36 Filed 07/13/12 Page 17 of 84

	
  

P.V.	
  ex	
  rel.	
  Valentin	
  and	
  Cruz,	
  et	
  al.,	
  v.	
  School	
  District	
  of	
  Phila.,	
  et	
  al.	
  (E.D.	
  Pa.)	
  –	
  Consultation	
  by	
  Ami	
  Klin	
  PhD	
  

	
  

Volkmar,	
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American	
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Volkmar,	
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developmental	
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Volkmar,	
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Developmental	
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Volkmar,	
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disorders.	
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edition	
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Wilder,	
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  Brief	
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and	
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Applied	
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Wolery,	
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transitions,	
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117-­‐131.	
  

	
  

	
  

Wolery,	
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  A.	
  (1998).	
  Classroom-­‐based	
  practices	
  for	
  preschoolers	
  with	
  

	
  

	
  

disabilities.	
  Intervention	
  in	
  School	
  and	
  Clinic,	
  34(3)	
  95-­‐102,	
  117.	
  

	
  

	
  

Wolery,	
  M.,	
  Anthony,	
  L.,	
  Caldwell,	
  N.	
  K.,	
  Snyder,	
  E.	
  D.,	
  &	
  Morgante,	
  J.	
  D.	
  (2002).	
  	
  Embedding	
  	
  

	
  

	
  

and	
  distributing	
  constant	
  time	
  delay	
  in	
  circle	
  time	
  and	
  transitions.	
  	
  Topics	
  in	
  Early	
  

	
  

Childhood	
  Special	
  Education,	
  22,	
  14-­‐25.	
  

	
  

	
  

16	
  

Case 2:11-cv-04027-LDD Document 48-36 Filed 07/13/12 Page 18 of 84

Ami	
  Klin,	
  PhD	
  	
  	
  	
  	
  	
  	
  	
  	
  

	
  

	
  

	
  

	
  Page	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  1	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
   	
  	
  

EMORY	
  UNIVERSITY	
  SCHOOL	
  OF	
  MEDICINE	
  

CURRICULUM	
  VITAE	
  

	
  

Revised:	
  05/31/2012	
  

1.	
  	
   Name:	
  Ami	
  Klin	
  

	
  

2.	
  	
   Office	
  Address:	
  	
  

	
  

	
  

Marcus	
  Autism	
  Center	
  

	
  

	
  

1920	
  Briarcliff	
  Road	
  NE	
  

	
  

	
  

Atlanta,	
  GA	
  30329-­‐4010	
  

	
  

	
  

Tel.:	
  404	
  785	
  5762	
  

	
  

	
  

Fax:	
  404	
  785	
  9485	
  

	
  

	
  

	
  

3.	
  	
   E-­‐mail	
  Address:	
  ami.klin@emory.edu	
  	
  

	
  

4.	
  	
   Citizenship:	
  US	
  

	
  

5.	
   Current	
  Titles	
  and	
  Affiliations:	
  

	
  

	
  

a.	
  	
   Academic	
  appointments:	
  

	
  

	
  

	
  

I.	
  	
   Primary	
  appointment:	
  

	
  

	
  

	
  

Georgia	
  Research	
  Alliance	
  Eminent	
  Scholar	
  Professor	
  and	
  Chief,	
  Division	
  of	
  Autism	
  &	
  

	
  

	
  

	
  

Related	
  Disorders,	
  Department	
  of	
  Pediatrics,	
  Emory	
  University	
  School	
  of	
  Medicine,	
  

	
  

	
  

	
  

Atlanta	
  GA	
  [2011	
  –	
  present]	
  

	
  

	
  

	
  

	
  

	
  

	
  

II.	
   Joint	
  and	
  secondary	
  appointments:	
  

	
  

	
  

	
  

Department	
  of	
  Psychology,	
  Emory	
  University	
  	
  [2011	
  –	
  present]	
  

	
  

	
  

	
  

Center	
  for	
  Translational	
  Social	
  Neuroscience,	
  Emory	
  University	
  	
  [2011	
  –	
  present]	
  

	
  

	
  

b.	
   Clinical/Administrative	
  appointments:	
  

	
  

	
  

	
  

	
  

	
  

	
  

Director,	
  Marcus	
  Autism	
  Center,	
  Children’s	
  Healthcare	
  of	
  Atlanta,	
  Atlanta	
  GA	
  

	
  

	
  

	
  

	
  

[2011	
  –	
  present]	
  

	
  

	
  

	
  

	
  

	
  

Chief	
  of	
  Autism	
  and	
  Related	
  Disorders,	
  Children’s	
  Healthcare	
  of	
  Atlanta,	
  Atlanta	
  GA	
  

	
  

	
  

	
  

	
  

[2011	
  –	
  present]	
  

	
  

6.	
   Previous	
  Academic	
  and	
  Professional	
  Appointments:	
  

	
  

	
  

[1992	
  –	
  1993]	
   Instructor	
  in	
  Developmental	
  Psychopathology,	
  Yale	
  Child	
  Study	
  Center,	
  	
  

Yale	
  University	
  School	
  of	
  Medicine,	
  New	
  Haven,	
  CT	
  

	
  

[1993	
  –	
  1999]	
   Assistant	
  Professor	
  of	
  Child	
  Psychology	
  &	
  Psychiatry,	
  Yale	
  Child	
  Study	
  Center,	
  	
  

Yale	
  University	
  School	
  of	
  Medicine,	
  New	
  Haven,	
  CT	
  

Case 2:11-cv-04027-LDD Document 48-36 Filed 07/13/12 Page 19 of 84

Ami	
  Klin,	
  PhD	
  	
  	
  	
  	
  	
  	
  	
  	
  

	
  

	
  

	
  

	
  Page	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  2	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
   	
  	
  

	
  

[1999	
  –	
  2009]	
   Harris	
  Associate	
  Professor	
  of	
  Child	
  Psychology	
  &	
  Psychiatry,	
  Yale	
  Child	
  Study	
  Center,	
  	
  

Yale	
  University	
  School	
  of	
  Medicine,	
  New	
  Haven,	
  CT	
  

	
  

[2002	
  –	
  2010]	
   Secondary	
  Appointment	
  at	
  Department	
  of	
  Psychology,	
  Yale	
  University,	
  New	
  Haven	
  CT	
  

	
  

[2006	
  –	
  2010]	
   Faculty	
  Member,	
  Cognitive	
  Science	
  Program,	
  Yale	
  University,	
  New	
  Haven	
  CT	
  	
  

[2009	
  –	
  2010]	
  Harris	
  Professor	
  of	
  Child	
  Psychology	
  &	
  Psychiatry,	
  Yale	
  Child	
  Study	
  Center,	
  

	
  

	
  

	
  

	
  

Yale	
  University	
  School	
  of	
  Excellence,	
  New	
  Haven,	
  CT	
  

	
  

	
  

7.	
   Previous	
  Administrative	
  and/or	
  Clinical	
  Appointments:	
  

	
  

	
  

[2002	
  –	
  2004]	
   Chief	
  of	
  Psychology,	
  Yale	
  Child	
  Study	
  Center,	
  New	
  Haven,	
  CT	
  	
  

	
  

[2006	
  –	
  2010]	
  	
 D  irector,	
  Autism	
  Program,	
  Yale	
  Child	
  Study	
  Center,	
  Yale	
  University	
  School	
  of	
  Medicine,	
  

	
  

	
  

	
  

	
  

New	
  Haven	
  CT	
  

[2008	
  –	
  2010]	
   Director	
  and	
  Principal	
  Investigator,	
  NIH	
  Autism	
  Center	
  of	
  Excellence,	
  Autism	
  Program,	
  

	
  Yale	
  Child	
  Study	
  Center,	
  Yale	
  University	
  School	
  of	
  Medicine,	
  New	
  Haven	
  CT	
  

	
  

8.	
   Licensures/Boards	
  

	
  

	
  

	
  

American	
  Psychological	
  Association	
  and	
  State	
  of	
  Connecticut	
  Department	
  of	
  Public	
  Health,	
  	
  

	
  

	
  

	
  

Clinical	
  Psychology:	
  License	
  #	
  001812	
  [1992]	
  

	
  

	
  

American	
  Psychological	
  Association	
  and	
  State	
  of	
  Georgia	
  Department	
  of	
  Public	
  Health,	
  	
  

	
  

	
  

	
  

Clinical	
  Psychology:	
  License	
  #	
  PSY003545	
  [2012]	
  

	
  

	
  

9.	
  	
   Specialty	
  Boards:	
  N/A	
  

	
  

10.	
  	
   Education:	
  

	
  

	
  

[1983]	
  B.A.,	
  Psychology,	
  Political	
  Science	
  &	
  History,	
  Hebrew	
  University	
  of	
  Jerusalem,	
  Israel	
  

	
  

[1988]	
   PhD,	
  Psychology	
  (Cognitive	
  Science	
  &	
  Developmental	
  Psychopathology),	
  

	
  

	
  

	
  

University	
  of	
  London	
  (LSE	
  &	
  MRC	
  Cognitive	
  Development	
  Unit),	
  London,	
  UK.	
  	
  

	
  

	
  

	
  

Supervisors:	
  Professors	
  Rob	
  Farr,	
  Uta	
  Frith,	
  &	
  John	
  Morton	
  

	
  

11.	
   Postgraduate	
  Training:	
  

	
  

	
  

[1989	
  –	
  1991]	
   Post-­‐doctoral	
  Fellow	
  in	
  Developmental	
  Psychopathology,	
  Yale	
  Child	
  Study	
  Center,	
  	
  

Yale	
  University	
  School	
  of	
  Medicine,	
  New	
  Haven,	
  CT	
  

	
  

[1991	
  –	
  1992]	
   Post-­‐doctoral	
  Fellow	
  in	
  Clinical	
  Child	
  Psychology,	
  Yale	
  Child	
  Study	
  Center,	
  

Yale	
  University	
  School	
  of	
  Medicine,	
  New	
  Haven,	
  CT	
  

	
  

12.	
   Military	
  or	
  Government	
  Service:	
  N/A	
  

	
  

13.	
  	
   Committee	
  Memberships	
  and	
  Public	
  Service:	
  

	
  

	
  

	
  

a.	
   National	
  and	
  International:	
  

Case 2:11-cv-04027-LDD Document 48-36 Filed 07/13/12 Page 20 of 84

Ami	
  Klin,	
  PhD	
  	
  	
  	
  	
  	
  	
  	
  	
  

	
  

	
  

	
  

	
  Page	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  3	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
   	
  	
  

	
  

	
  

	
  

Autism	
  Science	
  Foundation,	
  Scientific	
  Advisory	
  Board,	
  2009	
  –	
  present.	
  

Autism	
  Science	
  Foundation,	
  Mentorship	
  Grant	
  Program,	
  2009	
  	
  

	
  

	
  

NICHD	
  Council	
  ZHD1	
  DSR-­‐H	
  WA,	
  P01	
  (Program	
  Project)	
  Study	
  Section,	
  2009.	
  	
  

NIH	
  Special	
  Emphasis	
  Panel	
  ZRG1	
  BBBP-­‐L,	
  ARRA	
  Challenge	
  Grants,	
  2009.	
  

NSF,	
  ad	
  hoc	
  review,	
  Social	
  Neuroscience,	
  2009.	
  

NIH:ZMH1	
  ERB-­‐I(C3),	
  NIMH	
  Loan	
  Repayment	
  Program,	
  Developmental	
  

	
  

	
  

	
  

Psychopathology	
  and	
  Developmental	
  Cognitive	
  Neuroscience,	
  2009.	
  

	
  

	
  

Autism	
  Spectrum	
  News,	
  Editorial	
  Board,	
  2008	
  –	
  present.	
  	
  

Autism	
  Speaks,	
  Treatment	
  Grant	
  Review:	
  2008	
  Grant	
  Reviews,	
  2008.	
  

	
  

	
  

Connecticut	
  Academy	
  of	
  Arts	
  &	
  Sciences,	
  Honorary	
  Member,	
  2008	
  –	
  present	
  	
  

	
  

	
  

Medical	
  Research	
  Council	
  (UK)	
  Developmental	
  Cognitive	
  Neuroscience	
  Grant	
  Reviews,	
  2007.	
  

NIH:	
  ZRG1	
  BBBP-­‐L	
  (CPDD),	
  Exploratory	
  Applications	
  in	
  Child	
  Psychopathology,	
  2007.	
  

Autism	
  Speaks,	
  Basic	
  and	
  Clinical	
  Research:	
  2007	
  Grant	
  Reviews,	
  2007.	
  

	
  

	
  

State	
  of	
  Connecticut	
  Department	
  of	
  Mental	
  Retardation,	
  Steering	
  Committee	
  –	
  Services	
  for	
  

	
  

	
  

	
  

Individuals	
  with	
  Autism	
  without	
  Intellectual	
  Disabilities,	
  2006	
  –	
  2007.	
  	
  

	
  

	
  

NIH:	
  ZRG1	
  BBBP-­‐L	
  (CPDD),	
  Exploratory	
  Applications	
  in	
  Child	
  Psychopathology,	
  2006.	
  

National	
  Alliance	
  for	
  Autism	
  Research	
  and	
  Autism	
  Speaks	
  Grant	
  Reviews,	
  2006.	
  	
  

NIH:	
  BBBP-­‐4	
  (CP):	
  Cognition	
  and	
  Perception	
  Study	
  Section,	
  2005.	
  	
  

NIH:	
  BBBP-­‐6	
  (CPDD):	
  Behavioral	
  Science	
  Track	
  award	
  for	
  Rapid	
  Transition	
  (B/START),	
  2005	
  

Autism	
  Speaks,	
  Ad	
  Council	
  Advisory	
  Board,	
  2005	
  –	
  present.	
  	
  

	
  

	
  

Chapel	
  Haven,	
  Transition	
  into	
  Independent	
  Adulthood	
  Program,	
  Board	
  Member,	
  2005	
  –	
  	
  

	
  

present.	
  

	
  

	
  

NIH:	
  BBBP-­‐6	
  (CPDD):	
  Child	
  Psychopathology	
  and	
  Developmental	
  Disabilities	
  Study	
  Section,	
  	
  

	
  

	
  

	
  

2004.	
  	
  

New	
  Roads	
  High	
  School,	
  Santa	
  Monica,	
  California,	
  Advisory	
  Board,	
  2004-­‐present.	
  	
  

MAAP	
  Services	
  for	
  Autism	
  and	
  Asperger	
  Syndrome,	
  Advisory	
  Board,	
  2004-­‐present.	
   	
  

Berkshire	
  Centers	
  for	
  Independent	
  Living,	
  Advisory	
  Board,	
  2004-­‐present.	
   	
  

National	
  Autistic	
  Society	
  (UK):	
  ad	
  hoc	
  reviewer	
  of	
  grant	
  applications,	
  2003.	
  

NIH:	
  BBBP-­‐6	
  (CPDD):	
  Behavioral	
  Science	
  Track	
  award	
  for	
  Rapid	
  Transition	
  (B/START),	
  2003.	
  

PPP	
  Foundation	
  (UK):	
  ad	
  hoc	
  reviewer	
  of	
  grant	
  applications	
  for	
  Themed	
  Grants:	
  Children	
  &	
  	
  

	
  

Adolescents	
  Programme,	
  2002.	
  

National	
  Institute	
  on	
  Drug	
  Abuse,	
  I/START	
  (Imaging-­‐Science	
  Track	
  Award	
  for	
  Research	
  

Transition):	
  ad	
  hoc	
  reviewer,	
  2002.	
  

NIH:	
  STAART	
  (Studies	
  to	
  Advance	
  Autism	
  Research	
  and	
  Treatment)	
  Centers	
  (BBBP-­‐6):	
  Program	
  

Projects	
  Study	
  Section,	
  2001.	
  

Nuffield	
  Foundation,	
  London,	
  England:	
  ad	
  hoc	
  reviewer	
  of	
  grant	
  applications	
  on	
  autism,	
  	
  

	
  

2001.	
  

NIH:	
  Special	
  Emphasis	
  Panel	
  on	
  Autism,	
  2001.	
  

Cure	
  Autism	
  Now:	
  ad	
  hoc	
  reviewer	
  of	
  grant	
  applications,	
  2000.	
  

Autism	
  Society	
  of	
  America	
  Foundation:	
  Applied	
  Autism	
  Research	
  Grants	
  Review	
  Panel,	
  2000	
  

American	
  Psychiatric	
  Association,	
  DSM-­‐IV	
  Test	
  Revision	
  Child	
  Work	
  Group,	
  responsibility	
  for	
  

Mental	
  Retardation,	
  Autism	
  and	
  Pervasive	
  Developmental	
  Disorders,	
  and	
  Language	
  

Disorders,	
  1998	
  –	
  2000.	
  	
  

Case 2:11-cv-04027-LDD Document 48-36 Filed 07/13/12 Page 21 of 84

Ami	
  Klin,	
  PhD	
  	
  	
  	
  	
  	
  	
  	
  	
  

	
  

	
  

	
  

	
  Page	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  4	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
   	
  	
  

ASPEN	
  (Asperger	
  Syndrome	
  Education	
  Network,	
  Inc.),	
  Advisory	
  Board,	
  1997	
  –	
  present.	
  

Calvin	
  Hill	
  Day	
  Care	
  Center,	
  Board	
  of	
  Directors,	
  1997-­‐2010	
  

ASC-­‐U.S.,	
  Inc.	
  (Asperger	
  Syndrome	
  Coalition	
  of	
  the	
  United),	
  Advisory	
  Board,	
  1997	
  –	
  2002.	
  

NIH:	
  Special	
  Emphasis	
  Panel	
  on	
  Autism,	
  1997.	
  

Learning	
  Disabilities	
  Association	
  of	
  America,	
  Chair,	
  Task	
  Force	
  on	
  Nonverbal	
  Learning	
  

	
  

Disabilities	
  and	
  Asperger’s	
  Syndrome,	
  1995	
  –	
  1997.	
  	
  

American	
  Psychiatric	
  Association,	
  DSM-­‐IV	
  Field	
  Trials	
  and	
  Text	
  Preparation,	
  responsibility	
  for	
  

Pervasive	
  Developmental	
  Disorders	
  and	
  Mental	
  Retardation	
  (assisted	
  Dr.	
  Fred	
  R.	
  

Volkmar),	
  1993	
  –	
  1994.	
  	
  

	
  

b.	
   Regional	
  and	
  State:	
  

	
  

Kennedy	
  Center	
  Autism	
  Program,	
  Honorary	
  Committee,	
  2nd	
  Annual	
  “Magic	
  Moments”,	
  

	
  

	
  

	
  

Trumbull,	
  CT,	
  September	
  2nd,	
  2008.	
  

	
  

	
  

New	
  Jersey	
  Governor’s	
  Council	
  for	
  Autism,	
  Council	
  Member,	
  2005.	
  	
  

	
  

	
  

c.	
   Institutional:	
  

	
  

	
  

	
  

Membership	
  of	
  the	
  Yale	
  School	
  of	
  Medicine	
  Senior	
  Appointments	
  and	
  Promotions	
  Committee,	
  

2009	
  –	
  2010.	
  

	
  

Chair,	
  Assistant	
  Professorship	
  Search	
  Committee	
  (Behavioral	
  Social	
  Neuroscience),	
  Yale	
  Child	
  

Study	
  Center,	
  Yale	
  University	
  School	
  of	
  Medicine,	
  2009.	
  

Chair,	
  Assistant	
  Professorship	
  Search	
  Committee	
  (Clinical	
  Psychology),	
  Yale	
  Child	
  Study	
  Center,	
  	
  

	
  

Yale	
  University	
  School	
  of	
  Medicine,	
  2008.	
  

Assistant	
  Professorship	
  Search	
  Committee	
  (Child	
  Psychiatry),	
  Yale	
  Child	
  Study	
  Center,	
  Yale	
  	
  

	
  

University	
  School	
  of	
  Medicine,	
  2008.	
  

Associate	
  Professorship	
  Search	
  Committee	
  (Developmental	
  Neuroimaging),	
  Yale	
  Child	
  Study	
  	
  

Center,	
  Yale	
  University	
  School	
  of	
  Medicine,	
  2008.	
  

Business	
  Manager	
  Search	
  Committee,	
  Yale	
  Child	
  Study	
  Center,	
  Yale	
  University	
  School	
  of	
  	
  

	
  

Medicine,	
  2007.	
  

Professorship	
  Search	
  Committee	
  (Communication	
  Disorders),	
  Yale	
  Child	
  Study	
  Center,	
  Yale	
  	
  

	
  

University	
  School	
  of	
  Medicine,	
  2007.	
  	
  

Directorship	
  of	
  the	
  Yale	
  Child	
  Study	
  Center,	
  Liaison	
  Committee,	
  Yale	
  University	
  School	
  of	
  

Medicine,	
  2005	
  –	
  2006.	
  

Assistant	
  Professorship	
  Search	
  Committee,	
  (Developmental	
  Disabilities	
  and	
  Infancy),	
  Yale	
  Child	
  

Study	
  Center,	
  Yale	
  University	
  School	
  of	
  Medicine,	
  2003.	
  

Assistant	
  Professorship	
  Search	
  Committee,	
  (Child	
  Development	
  and	
  Social	
  Policy),	
  Yale	
  Child	
  

Study	
  Center,	
  Yale	
  University	
  School	
  of	
  Medicine,	
  2003.	
  	
  

	
  

14.	
  	
   Consultantships:	
  N/A	
  

	
  

15.	
   Editorships	
  and	
  Editorial	
  Boards:	
  

	
  

	
  

Molecular	
  Autism,	
  Editorial	
  Board,	
  2009	
  -­‐	
  present.	
  

Case 2:11-cv-04027-LDD Document 48-36 Filed 07/13/12 Page 22 of 84

Ami	
  Klin,	
  PhD	
  	
  	
  	
  	
  	
  	
  	
  	
  

	
  

	
  

	
  

	
  Page	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  5	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
   	
  	
  

	
  

Klin,	
  A.	
  &	
  Mercadante,	
  M.T.	
  (Eds.).	
  (2006).	
  Special	
  supplement	
  on	
  autism.	
  	B
   razilian	
  Journal	
  of	
  	
  

	
  

	
  

Psychiatry	
  (Revista	
  Brasileira	
  de	
  Psiquiatria),	
  28.	
  	
  (Supl	
  I).	
  

	
  

Klin,	
  A.,	
  &	
  Baron-­‐Cohen,	
  S.	
  (Eds.).	
  (2006).	
  The	
  cognitive	
  neuroscience	
  of	
  Asperger	
  syndrome.	
  	
  

Brain	
  &	
  Cognition,	
  61.	
  

	
  

Volkmar,	
  F.R.,	
  &	
  Klin,	
  A.	
  (Eds.)	
  (2005).	
  Special	
  issue	
  on	
  Asperger	
  Syndrome.	
  Journal	
  of	
  Autism	
  	
  

and	
  Developmental	
  Disorders,	
  35(2).	
  

	
  

Klin,	
  A.,	
  &	
  Volkmar,	
  F.R.	
  (Eds.)	
  (2003).	
  Asperger	
  Syndrome.	
  Special	
  issue	
  of	
  Child	
  and	
  Adolescent	
  

Psychiatric	
  Clinics	
  of	
  North	
  America,	
  12.	
  

	
  

Infanto,	
  The	
  Journal	
  of	
  the	
  Brazilian	
  Association	
  of	
  Child	
  Neurology	
  &	
  Psychiatry,	
  Editorial	
  Board,	
  

	
  

	
  

2000	
  –	
  2004.	
  

	
  

	
  

16.	
  	
   Manuscript	
  Reviewer	
  (1995	
  –	
  present):	
  

	
  

Nature	
  	
  

	
  

	
  

	
  

	
  

	
  

Social	
  Cognitive	
  &	
  Affective	
  Neuroscience	
  

Science	
  

	
  

	
  

	
  

	
  

	
  

Child	
  Development	
  

New	
  England	
  Journal	
  of	
  Medicine	
   	
  

	
  

Brain	
  &	
  Cognition	
  

Journal	
  of	
  Neuroscience	
   	
  

	
  

	
  

Journal	
  of	
  Autism	
  &	
  Developmental	
  Disorders	
  

Archives	
  of	
  General	
  Psychiatry	
   	
  

	
  

Neuropsychology	
  

American	
  Journal	
  of	
  Psychiatry	
   	
  

	
  

Journal	
  of	
  Clinical	
  &	
  Experimental	
  Neuropsychology	
  

Trends	
  In	
  Cognitive	
  Sciences	
   	
  

	
  

	
  

American	
  Journal	
  of	
  Mental	
  Retardation	
  

Biological	
  Psychiatry	
   	
  

	
  

	
  

	
  

Journal	
  of	
  Child	
  Psychology	
  &	
  Psychiatry	
  

Philosophical	
  Transactions	
  of	
  the	
  Royal	
  Society,	
   Development	
  &	
  Psychopathology	
  

	
  

Biological	
  Sciences	
   	
  

	
  

	
  

Journal	
  of	
  Child	
  Neurology	
  

Journal	
  of	
  Physiology	
   	
  

	
  

	
  

	
  

Child	
  Neuropsychology	
  

Developmental	
  Science	
   	
  

	
  

	
  

Bulletin	
  of	
  the	
  Menninger	
  Clinic	
   	
  

	
  

	
  

Developmental	
  Psychology	
   	
  

	
  

	
  

Emotion	
  

Psychological	
  Bulleting	
   	
  

	
  

	
  

Autism	
  

Journal	
  of	
  Speech	
  Language	
  &	
  Hearing	
  Research	
   European	
  Child	
  &	
  Adolescent	
  Psychiatry	
  

Consciousness	
  &	
  Cognition	
   	
  

	
  

	
  

Autism	
  Research	
  

Psychiatry	
  Research	
   	
  

	
  

	
  

	
  

Israel	
  Journal	
  of	
  Psychiatry	
  

British	
  Journal	
  of	
  Psychology	
   	
  

	
  

	
  

Child	
  Abuse	
  &	
  Neglect	
  

	
  

17.	
   Honors	
  and	
  Awards:	
  

	
  

	
  

	
  

‘Emily	
  Cavaliere	
  Puzio	
  and	
  Frank	
  Mauro	
  Puzio	
  Award	
  for	
  Commitment	
  and	
  Dedication	
  to	
  Improving	
  the	
  

Quality	
  of	
  Life	
  of	
  Individuals	
  with	
  Autism’,	
  Eden	
  Autism	
  Services	
  and	
  Princeton	
  University,	
  	
  

Princeton,	
  NJ,	
  June	
  3,	
  2011.	
  	
  

‘Annual	
  Award	
  for	
  Clinical	
  Science,	
  Service	
  and	
  Advocacy	
  on	
  Behalf	
  of	
  Individuals	
  with	
  Autism’,	
  	
  

	
  

	
  

Fordham	
  University,	
  Los	
  niños	
  Services,	
  New	
  York	
  City,	
  NY.	
  Eighth	
  Annual	
  Young	
  Child	
  Expo	
  &	
  

Conference,	
  April	
  7	
  2011,	
  New	
  York	
  City,	
  NY.	
  	
  

The	
  Foote	
  School	
  –	
  Plaque	
  at	
  Frank	
  M.	
  Perrine	
  Library	
  honoring	
  ‘Dr.	
  Klin’s	
  expertise,	
  passion,	
  and	
  

wisdom	
  in	
  his	
  work	
  with	
  children	
  with	
  developmental	
  disabilities’,	
  New	
  Haven,	
  CT,	
  	
  

October	
  24,	
  2010.	
  

US	
  Department	
  of	
  Health	
  &	
  Human	
  Services,	
  Interagency	
  Autism	
  Coordinating	
  Committee	
  mention	
  	
  

Case 2:11-cv-04027-LDD Document 48-36 Filed 07/13/12 Page 23 of 84

Ami	
  Klin,	
  PhD	
  	
  	
  	
  	
  	
  	
  	
  	
  

	
  

	
  

	
  

	
  Page	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  6	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
   	
  	
  

	
  

of	
  2009	
  paper	
  as	
  one	
  of	
  the	
  three	
  most	
  promising	
  papers	
  of	
  the	
  year	
  in	
  autism	
  [Klin,	
  A.,	
  Lin,	
  D.J.,	
  

	
  

Gorrindo,	
  P.,	
  Ramsay,	
  G.,	
  &	
  Jones,	
  W.	
  (2009).	
  Two-­‐year-­‐olds	
  with	
  autism	
  fail	
  to	
  orient	
  towards	
  

	
  

human	
  biological	
  motion	
  but	
  attend	
  instead	
  to	
  non-­‐social,	
  physical	
  contingencies.	
  Nature,	
  459,	
  

	
  

257-­‐261.	
  [NIHMS	
  #	
  103019];	
  2009.	
  	
  

	
  

US	
  Department	
  of	
  Health	
  &	
  Human	
  Services,	
  Interagency	
  Autism	
  Coordinating	
  Committee	
  mention	
  of	
  

	
  

	
  

2008	
  paper	
  as	
  one	
  of	
  the	
  top	
  autism-­‐related	
  papers	
  of	
  the	
  year	
  2008	
  [Jones,	
  W.,	
  Carr,	
  K.,	
  Klin,	
  A.	
  

	
  

	
  

Absence	
  of	
  preferential	
  looking	
  to	
  the	
  eyes	
  of	
  approaching	
  adults	
  predicts	
  level	
  of	
  social	
  	
  

	
  

	
  

disability	
  in	
  2-­‐year-­‐olds	
  with	
  autism.	
  Archives	
  of	
  General	
  Psychiatry.	
  2008,	
  65(8):946-­‐54.];	
  2009.	
  

	
  

Nature,	
  ‘Making	
  the	
  Paper:	
  Ami	
  Klin’.	
  Nature.	
  2009,	
  459,	
  138	
  (Highlighted	
  researcher	
  of	
  Nature	
  issue	
  

	
  

	
  

#	
  459);	
  2009.	
  	
  

	
  

Researcher	
  of	
  the	
  Year,	
  “Healthcare	
  Heroes”,	
  Business	
  New	
  Haven	
  in	
  collaboration	
  with	
  Yale	
  -­‐	
  New	
  	
  

	
  

	
  

Haven	
  Hospital	
  &	
  ConnectiCare;	
  2008.	
  	
  

	
  

Pearl	
  H.	
  Rieger	
  Award	
  for	
  Excellence	
  in	
  Clinical	
  Science,	
  Rush	
  NeuroBehavioral	
  Center,	
  Rush	
  Medical	
  

	
  

	
  

Center,	
  Chicago,	
  IL;	
  2007.	
  	
  

	
  

‘You	
  Make	
  the	
  Difference	
  Award’	
  by	
  the	
  Connecticut	
  Autism	
  Spectrum	
  Resource	
  Center,	
  New	
  Haven,	
  	
  

	
  

	
  

CT;	
  2006.	
  	
  

	
  

“Portraits	
  of	
  Inspiration	
  Award”,	
  The	
  Asperger’s	
  Association	
  of	
  New	
  England;	
  2006.	
  	
  

	
  

Distinguished	
  Award	
  for	
  Clinical	
  Services	
  and	
  Research,	
  Asperger	
  Syndrome	
  Education	
  Network	
  	
  

	
  

	
  

of	
  America;	
  2001.	
  	
  

	
  

Distinguished	
  Award	
  for	
  Research,	
  Autism	
  Society	
  of	
  America	
  Foundation;	
  2001.	
  	
  

	
  

Nominated	
  Fellow	
  to	
  the	
  National	
  Center	
  for	
  Clinical	
  Infant	
  Programs	
  [Zero	
  to	
  Three];	
  1992	
  –	
  1994.	
  	
  

	
  

Robert	
  McKenzie	
  Prize	
  for	
  Outstanding	
  Ph.D.	
  Thesis,	
  University	
  of	
  London;	
  1988.	
  	
  

	
  

Ph.D.	
  Distinction,	
  University	
  of	
  London;	
  1988.	
  	
  

	
  

Economic	
  and	
  Social	
  Research	
  Council	
  Award,	
  University	
  of	
  London;	
  1984	
  –	
  1986.	
  	
  

	
  

Argov	
  Scholarship	
  Award,	
  University	
  of	
  London;	
  1983	
  –	
  1984.	
  	
  

	
  

Dean’s	
  List	
  of	
  Academic	
  Achievement,	
  Hebrew	
  University	
  of	
  Jerusalem;	
  1980	
  –	
  1983.	
  	
  

	
  

18.	
   Society	
  Memberships:	
  

	
  

	
  

International	
  Society	
  for	
  Autism	
  Research,	
  2001	
  –	
  present.	
  

	
  

Society	
  for	
  Research	
  in	
  Child	
  Development,	
  1995	
  –	
  present.	
  

	
  

New	
  York	
  Academy	
  of	
  Sciences,	
  2010	
  –	
  present.	
  	
  

	
  

	
  

19.	
  	
   Organization	
  of	
  National	
  or	
  International	
  Conferences:	
  

	
  

	
  

a.	
   Administrative	
  Positions:	
  	
  

	
  

	
  

	
  

IMFAR	
  2012	
  (International	
  Meeting	
  for	
  Autism	
  Research,	
  Toronto,	
  Canada),	
  Scientific	
  Program	
  

	
  

	
  

and	
  Organizing	
  Committees.	
  

	
  

IMFAR	
  2011	
  (International	
  Meeting	
  for	
  Autism	
  Research,	
  San	
  Diego,	
  CA),	
  Scientific	
  Program	
  

	
  

	
  

and	
  Organizing	
  Committees.	
  	
  

	
  

Autism	
  –	
  Europe,	
  Honorary	
  Scientific	
  Committee,	
  IX	
  International	
  Congress,	
  Catania,	
  Italy,	
  	
  

	
  

	
  

October	
  8-­‐10,	
  2010.	
  

	
  

IMFAR	
  2010	
  (International	
  Meeting	
  for	
  Autism	
  Research,	
  Philadelphia,	
  PA),	
  Scientific	
  Program	
  

Case 2:11-cv-04027-LDD Document 48-36 Filed 07/13/12 Page 24 of 84

Ami	
  Klin,	
  PhD	
  	
  	
  	
  	
  	
  	
  	
  	
  

	
  

	
  

	
  

	
  Page	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  7	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
   	
  	
  

	
  

	
  

Committee.	
  	
  

	
  

IMFAR	
  2009	
  (International	
  Meeting	
  for	
  Autism	
  Research,	
  Chicago,	
  IL),	
  Scientific	
  Program	
  

	
  

	
  

Committee.	
  	
  

	
  

IMFAR	
  2008	
  (International	
  Meeting	
  for	
  Autism	
  Research,	
  London,	
  UK),	
  Scientific	
  Program	
  

	
  

	
  

Committee.	
  	
  

	
  

Autism	
  –	
  Europe,	
  Honorary	
  Scientific	
  Committee,	
  VIII	
  International	
  Congress,	
  Oslo,	
  Norway,	
  	
  

	
  

	
  

October	
  15-­‐17,	
  2007.	
  

	
  

International	
  Congress	
  on	
  Autism,	
  President	
  of	
  Organizing	
  Committee,	
  Fortaleza,	
  Brazil,	
  

	
  

	
  

June	
  5-­‐7,	
  2006.	
  

	
  

IMFAR	
  2006	
  (International	
  Meeting	
  for	
  Autism	
  Research,	
  Montreal,	
  Canada),	
  Scientific	
  Program	
  

	
  

	
  

Committee.	
  

	
  

IMFAR	
  2005	
  (International	
  Meeting	
  for	
  Autism	
  Research,	
  Boston,	
  MA),	
  Scientific	
  Program	
  

	
  

	
  

Committee.	
  

	
  

International	
  Meeting	
  for	
  Autism	
  Research,	
  Abstract	
  Selection	
  Committee,	
  2005	
  –	
  2009.	
  	
  

	
  

Autism	
  Europe:	
  Honorary	
  Committee,	
  Seventh	
  International	
  Autism	
  Europe	
  Congress	
  in	
  Lisbon,	
  

	
  

	
  

Portugal,	
  2003.	
  

	
  

	
  

b.	
  	
   Sessions	
  as	
  Chair:	
  	
  

	
  

	
  

Chair,	
  State-­‐of-­‐the-­‐art	
  Lecture	
  delivered	
  by	
  Professor	
  Sir	
  Michael	
  Rutter:	
  “Research	
  into	
  autism:	
  	
  

	
  

	
  

accomplishments,	
  puzzles	
  and	
  challenges”,	
  The	
  8th	
  International	
  Congress	
  Autism	
  –	
  Europe,	
  	
  

	
  

	
  

Oslo,	
  Norway;	
  2007.	
  	
  

	
  

Chair,	
  Symposium	
  on	
  Visual	
  Attention	
  and	
  Perception	
  in	
  Autism	
  Spectrum	
  Disorders,	
  The	
  8th	
  	
  

	
  

	
  

International	
  Congress	
  Autism	
  –	
  Europe,	
  Oslo,	
  Norway;	
  2007.	
  	
  

	
  

Chair,	
  Symposium	
  on	
  Emotions	
  and	
  Social	
  Interactions,	
  6th	
  Annual	
  Meeting,	
  International	
  Meeting	
  	
  

	
  

	
  

for	
  Autism	
  Research	
  (IMFAR),	
  Seattle,	
  Washington;	
  2007.	
  	
  

	
  

Chair,	
  Symposium	
  on	
  Social-­‐Emotional	
  and	
  Language	
  Abilities	
  in	
  Nonretarded	
  Children	
  with	
  Autism:	
  	
  

	
  

	
  

Etiologic	
  and	
  Interpersonal	
  Implications	
  Biennial	
  Meeting	
  of	
  the	
  Society	
  for	
  Research	
  in	
  Child	
  	
  

	
  

	
  

Development,	
  Albuquerque,	
  New	
  Mexico;	
  1999.	
  	
  

	
  

Chair,	
  Symposium	
  on	
  Adaptive	
  Behavior,	
  Theory	
  of	
  Mind,	
  and	
  Emotional	
  	
   Understanding	
  in	
  Autism,	
  	
  

	
  

	
  

Biennial	
  Conference	
  of	
  the	
  Society	
  for	
  Research	
  in	
  Child	
  Development,	
  New	
  Orleans,	
  Louisiana;	
  

	
  

	
  

1993.	
  	
  	
  

	
  

Chair,	
  Symposium	
  on	
  Preschool	
  Developmental	
  Disabilities:	
  Diagnosis	
  and	
  Outcome,	
  Learning	
  	
  

	
  

	
  

Disabilities	
  Association	
  of	
  America	
  International	
  Conference.	
  Atlanta,	
  Georgia;	
  1992.	
  

	
  

	
  

20.	
  	
   Research	
  Focus:	
  

	
  

	
  

My	
  research	
  focuses	
  on	
  cognitive	
  science	
  studies	
  of	
  evolutionary	
  highly-­‐conserved,	
  and	
  

	
  

developmentally	
  early-­‐onset,	
  mechanisms	
  of	
  socialization	
  and	
  their	
  disruptions	
  in	
  infants,	
  toddlers,	
  

	
  

children	
  and	
  adolescents	
  with	
  autism	
  spectrum	
  disorders.	
  In	
  the	
  recent	
  past,	
  my	
  lab	
  has	
  developed	
  

	
  

new	
  technologies	
  and	
  methods	
  for	
  the	
  detection	
  of	
  autism	
  in	
  the	
  first	
  year	
  of	
  life.	
  

	
  

21.	
  	
   Patents:	
  

	
  

Case 2:11-cv-04027-LDD Document 48-36 Filed 07/13/12 Page 25 of 84

Ami	
  Klin,	
  PhD	
  	
  	
  	
  	
  	
  	
  	
  	
  

	
  

	
  

	
  

	
  Page	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  8	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
   	
  	
  

	
  

a.	
   	
  Issued:	
  	
   US	
  Patent	
  App	
  #	
  20060189886.	
  System	
  and	
  method	
  for	
  quantifying	
  and	
  mapping	
  

	
  

	
  

	
  

	
  

visual	
  salience.	
  	
  Inventors:	
  W.	
  Jones	
  and	
  A.	
  Klin.	
  

	
  

	
  

b.	
   Pending:	
  	
   None.	
  

	
  

22.	
   Grant	
  Support:	
  	
  

	
  

	
  

a.	
  	
   Active	
  Support:	
  

	
  

	
  

	
  

I.	
   Federally	
  funded:	
  

	
  

	
  

	
  

Agency:	
  

National	
  Institute	
  of	
  Mental	
  Health	
  

	
  

	
  

I.D.#	
   	
  

RC1	
  MH088676	
  ARRA	
  	
  

	
  

	
  

Title:	
   	
  

“Performance	
  Indices	
  of	
  Social	
  Disability	
  in	
  Toddlers	
  with	
  Autism”	
  

	
  

	
  

P.I.:	
   	
  

Ami	
  Klin,	
  PhD	
  

	
  

	
  

Percent	
  effort:	1
   0%	
  

	
  

	
  

Direct	
  costs	
  per	
  year:	
  	
 $  	
  317,328	
  

	
  

	
  

Total	
  costs	
  for	
  project	
  period:	
  	
  $	
  995,164	
  

	
  

	
  

Project	
  period:	
  

10/01/2009	
  –	
  09/30/2011	
  

	
  

	
  

	
  

	
  

	
  

	
  

Agency:	
  

National	
  Institute	
  of	
  Mental	
  Health	
  

	
  

	
  

I.D.#	
   	
  

RC1	
  MH088676-­‐01S1	
  Supplement	
  ARRA	
   	
  

	
  

	
  

Title:	
   	
  

“Performance	
  Indices	
  of	
  Social	
  Disability	
  in	
  Toddlers	
  with	
  Autism”:	
  Increasing	
  	
  

	
  

	
  

	
  

	
  

the	
  Scientific	
  Yield	
  of	
  the	
  National	
  Database	
  for	
  Autism	
  Research	
  (NDAR)	
  

	
  

	
  

P.I.:	
   	
  

Ami	
  Klin,	
  PhD	
  

	
  

	
  

Percent	
  effort:	2
   %	
  

	
  

	
  

Direct	
  costs	
  per	
  year:	
  	
 $  	
  73,404	
  

	
  

	
  

Total	
  costs	
  for	
  project	
  period:	
  	
  $	
  121,484	
  

	
  

	
  

Project	
  period:	
  

06/01/2010	
  –	
  05/31/2011	
  	
  

	
  	
  

	
  

	
  

Agency:	
  

National	
  Institute	
  of	
  Mental	
  Health	
  

	
  

	
  

I.D.#	
   	
  

R01	
  MH83712	
  	
  

	
  

	
  

Title:	
   	
  

“Perception	
  of	
  social	
  and	
  physical	
  contingencies	
  in	
  infants	
  with	
  ASD”	
  

	
  

	
  

P.I.:	
   	
  

Ami	
  Klin,	
  PhD	
  

	
  

	
  

Percent	
  effort:	1
   5%	
  

	
  

	
  

Direct	
  costs	
  per	
  year:	
  	
 $  	
  250,000	
  

	
  

	
  

Total	
  costs	
  for	
  project	
  period:	
  	
  $2,068,750	
  

	
  

	
  

Project	
  period:	
  

04/01/2009	
  –	
  03/31/2014	
  	
  

	
  

	
  

	
  

Agency:	
  

National	
  Institute	
  of	
  Mental	
  Health	
  

	
  

	
  

I.D.#	
   	
  

R01	
  MH083727	
   	
  

	
  

	
  

Title:	
   	
  

“The	
  Ontogeny	
  of	
  Social	
  Visual	
  Engagement	
  in	
  Infants	
  at	
  Risk	
  for	
  Autism”	
  

	
  

	
  

P.I.:	
   	
  

Ami	
  Klin,	
  PhD	
  

Case 2:11-cv-04027-LDD Document 48-36 Filed 07/13/12 Page 26 of 84

Ami	
  Klin,	
  PhD	
  	
  	
  	
  	
  	
  	
  	
  	
  

	
  

	
  

	
  

	
  Page	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  9	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
   	
  	
  

	
  

	
  

Percent	
  effort:	3
   0%	
  

	
  

	
  

Direct	
  costs	
  per	
  year:	
  	
 $  	
  430,000	
  

	
  

	
  

Total	
  costs	
  for	
  project	
  period:	
  	
  $3,547,500	
  

	
  

	
  

Project	
  period:	
  

07/01/2008	
  –	
  06/30/2013	
  	
  

	
  

	
  

	
  

Agency:	
  

National	
  Institute	
  of	
  Mental	
  Health	
  and	
  National	
  Institute	
  on	
  Deafness	
  	
  

	
  

	
  

	
  

	
  

and	
  Other	
  Communication	
  Disorders	
  	
  

	
  

	
  

I.D.#	
   	
  

P50	
  MH081756-­‐01	
  (Center	
  Grant,	
  NIH	
  Autism	
  Center	
  of	
  Excellence)	
   	
  

	
  

	
  

Title:	
   	
  

“Mechanisms	
  of	
  Social	
  Engagement	
  in	
  ASD”	
  

	
  

	
  

P.I.:	
   	
  

Ami	
  Klin,	
  PhD.	
  and	
  PI	
  Project	
  I,	
  Director	
  Administrative	
  Core	
  and	
  Assessment	
  

	
  

	
  

	
  

	
  

Core	
  

	
  

	
  

Percent	
  effort:	2
   9%	
  

	
  

	
  

Direct	
  Costs:	
  $1,572,567,	
  $1,573,199,	
  $1,547,848,	
  $1,575,685,	
  $1,573,266	
  

	
  

	
  

Total	
  costs	
  for	
  project	
  period:	
  	
  $12,416,533	
  

	
  

	
  

Project	
  period:	
  

04/01/2008	
  –	
  03/31/2013	
  

	
  

	
  

	
  

Agency:	
  

National	
  Institute	
  of	
  Child	
  Health	
  and	
  Human	
  Development	
  

	
  

	
  

I.D.#	
   	
  

P01	
  HD003008-­‐39	
   	
  

	
  

	
  

Title:	
   	
  

“Autism	
  and	
  Related	
  Disorders:	
  Development	
  and	
  Outcome”	
  

	
  

	
  

P.I.:	
   	
  

Fred	
  Volkmar,	
  MD	
  

	
  

	
  

Role:	
   	
  

Co-­‐PI	
  of	
  Grant,	
  PI	
  of	
  Assessment	
  Core,	
  Investigator,	
  Projects	
  1	
  &	
  2	
  

	
  

	
  

Percent	
  effort:	1
   8%	
  

	
  

	
  

Direct	
  Costs:	
  	
   $704,800,	
  $683,201,	
  $702,979,	
  $723,349,	
  $744,331	
  

	
  

	
  

Total	
  costs	
  for	
  project	
  period:	
  	
  $5,768,879	
  

	
  

	
  

Project	
  period:	
  

09/03/2006	
  –	
  08/31/2011	
  

	
  

	
  

	
  

II.	
   Private	
  Foundation	
  funded:	
  

	
  

	
  

	
  

Agency:	
  

The	
  Simons	
  Foundation	
  

	
  

	
  

I.D.#	
   	
  

Private	
  Foundation	
  Program	
  Project	
  Award	
   	
  

	
  

	
  

Title:	
   	
  

“Brain-­‐Behavior	
  Growth	
  Charts	
  of	
  Altered	
  Social	
  Engagement	
  in	
  ASD	
  Infants”	
  

	
  

	
  

P.I.:	
   	
  

Ami	
  Klin,	
  PhD	
  (Project	
  PIs:	
  Ami	
  Klin,	
  PhD	
  &	
  Warren	
  Jones,	
  PhD,	
  Kevin	
  Pelphrey,	
  	
  

	
  

	
  

	
  

	
  

PhD,	
  and	
  James	
  Mcpartland,	
  PhD)	
  

	
  

	
  

Percent	
  effort:	1
   5%	
  

	
  

	
  

Direct	
  Costs	
  per	
  year:	
  $	
  1,200,000	
  

	
  

	
  

Total	
  costs	
  for	
  project	
  period:	
  	
  $	
  4,500,000	
  

	
  

	
  

Project	
  period:	
  

08/01/2010	
  –	
  07/31/2013	
  	
  

	
  

	
  

	
  

Agency:	
  

The	
  Simons	
  Foundation	
  

	
  

	
  

I.D.#	
   	
  

Private	
  Foundation	
  Grant	
   	
  

	
  

	
  

Title:	
   	
  

“Simons	
  Simplex	
  Consortium	
  Genetics	
  Project	
  –	
  Yale	
  Site”	
  

	
  

	
  

P.I.:	
   	
  

Ami	
  Klin,	
  M.D.	
  (Co-­‐PI	
  Matthew	
  W.	
  State,	
  M.D.,	
  Ph.D.)	
  

	
  

	
  

Percent	
  effort:	3
   %	
  

	
  

	
  

Direct	
  Costs	
  per	
  year:	
  $391,671,	
  $375,000,	
  	
  

Case 2:11-cv-04027-LDD Document 48-36 Filed 07/13/12 Page 27 of 84

Ami	
  Klin,	
  PhD	
  	
  	
  	
  	
  	
  	
  	
  	
  

	
  

	
  

	
  

	
  Page	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  1	
  	
  	0
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
   	
  	
  

	
  

	
  

Total	
  costs	
  for	
  project	
  period:	
  	
  $879,111	
  

	
  

	
  

Project	
  period:	
  

10/15/2006	
  –	
  03/31/2010	
  (renewable	
  for	
  additional	
  third	
  year)	
  

	
  

	
  

	
  

Agency:	
  

The	
  Simons	
  Foundation	
  

	
  

	
  

I.D.#	
   	
  

Private	
  Foundation	
  Award	
   	
  

	
  

	
  

Title:	
   	
  

“Simons	
  Physical	
  and	
  Clinical	
  Infrastructure	
  for	
  Research	
  on	
  Infants-­‐at-­‐Risk”	
  

	
  

	
  

P.I.:	
   	
  

Ami	
  Klin,	
  PhD	
  	
  

	
  

	
  

Percent	
  effort:	
  5%	
  

	
  

	
  

Direct	
  Costs	
  per	
  year:	
  $	
  1,200,000	
  

	
  

	
  

Total	
  costs	
  for	
  project	
  period:	
  	
  $	
  720,000	
  

	
  

	
  

Project	
  period:	
  

08/01/2010	
  –	
  07/31/2013	
  	
  

	
  

	
  

	
  

	
  

III.	
  	
   Contracts:	
  None.	
  

	
  

B)	
   Previous	
  support:	
  

	
  

	
  

	
  

Agency:	
  

The	
  Simons	
  Foundation	
  

	
  

	
  

I.D.#	
   	
  

Private	
  Foundation	
  Program	
  Project	
  Award	
   	
  

	
  

	
  

Title:	
   	
  

“Identification	
  of	
  Vulnerabilities	
  for	
  Autism	
  in	
  Infancy”	
  

	
  

	
  

P.I.:	
   	
  

Ami	
  Klin,	
  PhD	
  

	
  

	
  

Percent	
  effort:	1
   5%	
  

	
  

	
  

Direct	
  Costs	
  per	
  year:	
  $1,444,118,	
  $1,239,940	
  

	
  

	
  

Total	
  costs	
  for	
  project	
  period:	
  	
  $	
  3,220,870	
  

	
  

	
  

Project	
  period:	
  

07/01/2008	
  –	
  06/30/2010	
  

	
  

	
  

	
  

	
  

Agency:	
  

National	
  Institute	
  of	
  Mental	
  Health	
   	
  

	
  

	
  

I.D.#	
   	
  

U54	
  MH66494	
  (Center	
  Grant,	
  NIH	
  Studies	
  to	
  Advance	
  Autism	
  Research	
  	
  

	
  

	
  

	
  

	
  

and	
  Treatment)	
   	
  

	
  

	
  

Title:	
   	
  

“The	
  Social	
  Neuroscience	
  of	
  Autism	
  and	
  Related	
  Disorders”	
  

	
  

	
  

P.I.:	
   	
  

Fred	
  R.	
  Volkmar,	
  MD	
  

	
  

	
  

Role	
  on	
  Project:	
  Co-­‐PI	
  Yale	
  STAART,	
  PI	
  Project	
  I,	
  Investigator	
  Projects	
  II	
  &	
  V,	
  	
  

	
  

	
  

	
  

	
  

Co-­‐Director	
  Administrative	
  Core,	
  Director	
  Assessment	
  Core,	
  PI	
  for	
  Yale	
  STAART	
  	
  

	
  

	
  

	
  

	
  

competitive	
  extension	
  (07/01/2007	
  –	
  12/3102008)	
  	
  

	
  

	
  

	
  

	
  

Percent	
  effort:	3
   0%	
  

	
  

	
  

	
  

	
  

Total	
  costs	
  for	
  project	
  period:	
  	
  $8,587,720	
  

	
  

	
  

Project	
  period:	
  

09/27/2002	
  –	
  06/30/2008	
  

	
  

	
  

	
  

Agency:	
  

The	
  Simons	
  Foundation	
  

	
  

	
  

I.D.#	
   	
  

Private	
  Foundation	
  Project	
  Award	
   	
  

	
  

	
  

Title:	
   	
  

“Establishment	
  of	
  a	
  Model	
  Diagnostic	
  Laboratory	
  for	
  Infants	
  at	
  Risk	
  for	
  Autism”	
  

	
  

	
  

P.I.:	
   	
  

Ami	
  Klin,	
  PhD	
  

	
  

	
  

Percent	
  effort:	1
   5%	
  

Case 2:11-cv-04027-LDD Document 48-36 Filed 07/13/12 Page 28 of 84

Ami	
  Klin,	
  PhD	
  	
  	
  	
  	
  	
  	
  	
  	
  

	
  

	
  

	
  

	
  Page	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  1	
  	
  	1
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
   	
  	
  

	
  

	
  

Total	
  costs	
  for	
  project	
  period:	
  	
  $	
  2,576,000	
  

	
  

	
  

Project	
  period:	
  

07/01/2004	
  –	
  06/30/2008	
  

	
  

	
  

	
  

Agency:	
  

National	
  Science	
  Foundation	
  

	
  

	
  

I.D.#	
   	
  

NSF	
  0532610	
   	
  

	
  

	
  

Title:	
   	
  

“Quantitative	
  measures	
  of	
  a	
  social	
  response	
  for	
  autism	
  diagnosis”	
  

	
  

	
  

P.I.:	
   	
  

Brian	
  Scassellati,	
  PhD	
  

	
  

	
  

Role	
  in	
  Project:	
  Co-­‐PI	
  

	
  

	
  

Percent	
  effort:	3
   %	
  Concurrent	
  	
  

	
  

	
  

Total	
  costs	
  for	
  project	
  period:	
  	
  $641,214	
  

	
  

	
  

Project	
  period:	
  

11/15/2005	
  –	
  10/31/2008	
  	
  

	
  

	
  

	
  

Agency:	
  

National	
  Institute	
  of	
  Mental	
  Health	
  

	
  

	
  

I.D.#	
   	
  

R01	
  MH07084	
  	
  

	
  

	
  

Title:	
   	
  

“The	
  Fusiform	
  and	
  Amygdala	
  in	
  the	
  Pathobiology	
  of	
  Autism”	
  

	
  

	
  

P.I.:	
   	
  

Robert	
  T.	
  Schultz,	
  PhD	
  (PI	
  Left	
  Yale)	
  

	
  

	
  

Role	
  on	
  Project:	
  Investigator	
  

	
  

	
  

Percent	
  effort:	5
   %	
  

	
  

	
  

Total	
  costs	
  for	
  project	
  period:	
  	
  $1,990,000	
  

	
  

	
  

Project	
  period:	
  

02/25/2005	
  –	
  01/31/2010	
  

	
  

	
  

	
  

Agency:	
  

National	
  Institute	
  of	
  Child	
  Health	
  and	
  Human	
  Development	
  

	
  

	
  

	
  

I.D.#	
   	
  

R01	
  HD42127	
   	
  

	
  

	
  

Title:	
   	
  

“Eye-­‐tracking	
  Studies	
  of	
  Social	
  Visual	
  Pursuit	
  in	
  Autism”	
  

	
  

	
  

P.I.:	
   	
  

Ami	
  Klin,	
  PhD	
  

	
  

	
  

Percent	
  effort:	3
   0%	
  

	
  

	
  

Total	
  costs	
  for	
  project	
  period:	
  	
  $1,998,285	
  

	
  

	
  

Project	
  period:	
  

09/27/2002	
  –	
  08/31/2007	
  

	
  

	
  

	
  

Agency:	
  

National	
  Alliance	
  for	
  Autism	
  Research	
  

	
  

	
  

I.D.#	
   	
  

Private	
  Foundation	
  Grant	
   	
  

	
  

	
  

Title:	
   	
  

“Listening	
  Preferences	
  in	
  Toddlers	
  with	
  Autism:	
  The	
  Playtest	
  as	
  an	
  Early	
  

	
  

	
  

	
  

	
  

Screening	
  Device”	
  

	
  

	
  

P.I.:	
   	
  

Ami	
  Klin,	
  Ph.D.	
  

	
  

	
  

Percent	
  effort:	2
   0%	
  

	
  

	
  

Total	
  costs	
  for	
  project	
  period:	
  	
  $120,000	
  

	
  

	
  

Project	
  period:	
  

07/01/2004	
  –	
  12/312006	
  

	
  

	
  

	
  

Agency:	
  

Maternal	
  &	
  Child	
  Health	
  Bureau	
   	
  

	
  

	
  

I.D.#	
   	
  

R01	
  	
   	
  

	
  

	
  

Title:	
   	
  

“Early	
  detection	
  of	
  autism:	
  Comparison	
  of	
  Three	
  Screening	
  Instruments”	
  

	
  

	
  

P.I.:	
   	
  

Deborah	
  A.	
  Fein,	
  PhD	
  

	
  

	
  

Role:	
   	
  

Investigator	
  

	
  

	
  

Percent	
  effort:	4
   %	
  

Case 2:11-cv-04027-LDD Document 48-36 Filed 07/13/12 Page 29 of 84

Ami	
  Klin,	
  PhD	
  	
  	
  	
  	
  	
  	
  	
  	
  

	
  

	
  

	
  

	
  Page	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  1	
  	
  	2
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
   	
  	
  

	
  

	
  

Total	
  costs	
  for	
  project	
  period:	
  	
  $282,012	
  (Yale	
  sub-­‐award	
  only)	
  

	
  

	
  

Project	
  period:	
  

09/01/01	
  –	
  07/31/05	
  

	
  

	
  

	
  

Agency:	
  

Korczak	
  Foundation,	
  the	
  Netherlands	
  

	
  

	
  

	
  

I.D.#	
   	
  

Private	
  Foundation	
  Project	
  Grant	
   	
  

	
  

	
  

Title:	
   	
  

“Nosology,	
  Neuropsychology	
  and	
  Social	
  Cognition	
  of	
  Autism	
  and	
  Related	
  

	
  

	
  

	
  Conditions”	
  

	
  

	
  

P.I.:	
   	
  

Ami	
  Klin,	
  PhD	
  

	
  

	
  

Percent	
  effort:	6
   %	
  

	
  

	
  

Total	
  costs	
  for	
  project	
  period:	
  	
  $	
  200,000	
  

	
  

	
  

Project	
  period:	
  

03/01/2002	
  –	
  02/25/2006	
  

	
  

	
  

	
  

Agency:	
  

National	
  Institute	
  of	
  Child	
  Health	
  and	
  Human	
  Development	
  

	
  

	
  

I.D.#	
   	
  

P01	
  HD003008	
  (Program	
  Project)	
   	
  

	
  

	
  

	
  

Title:	
   	
  

“Mental	
  Retardation	
  and	
  Developmental	
  Psychopathology”	
  

	
  

	
  

	
  

P.I.:	
   	
  

Fred	
  Volkmar,	
  MD	
  

	
  

	
  

Role	
  on	
  project:	
  	
  PI	
  Project	
  III,	
  Investigator	
  Project	
  IV	
  

	
  

	
  

Percent	
  effort:	3
   0%	
  

	
  

	
  

Total	
  costs	
  for	
  project	
  period:	
  	
  $4,034,169	
  

	
  

	
  

Project	
  period:	
  

04/01/2000	
  –	
  03/31/2005	
  

	
  

	
  

	
  

Agency:	
  

National	
  Alliance	
  for	
  Autism	
  Research	
   	
  

	
  

	
  

I.D.#	
   	
  

Private	
  Foundation	
  Grant	
   	
  

	
  

	
  

Title:	
   	
  

“Mentor-­‐based	
  Post-­‐Doctoral	
  Fellowship	
  in	
  Social	
  Neuroscience”	
  (Melissa	
  

	
  

	
  

	
  

	
  

Preissler,	
  PhD)	
  

	
  

	
  

P.I.:	
   	
  

Ami	
  Klin,	
  PhD	
  

	
  

	
  

Percent	
  effort:	5
   %	
  

	
  

	
  

Total	
  costs	
  for	
  project	
  period:	
  	
  $80,000	
  

	
  

	
  

Project	
  period:	
  

07/01/2003	
  –	
  06/30/2005	
  

	
  

	
  

	
  

Agency:	
  

Doris	
  Duke	
  Charitable	
  Foundation	
   	
  

	
  

	
  

I.D.#	
   	
  

Private	
  Foundation	
  Grant	
   	
  

	
  

	
  

Title:	
   	
  

“A	
  Humanoid	
  Robot	
  as	
  an	
  Interactive	
  Diagnostic	
  Device	
  in	
  Autism”	
  

	
  

	
  

P.I.:	
   	
  

Brian	
  Scassellati,	
  Ph.D.	
  

	
  

	
  

Role	
  on	
  the	
  Project:	
  Co-­‐PI	
  

	
  

	
  

Percent	
  effort:	5
   %	
  

	
  

	
  

Total	
  costs	
  for	
  project	
  period:	
  	
  $90,000	
  

	
  

	
  

Project	
  period:	
  

07/01/2004	
  –	
  06/30/2005	
  

	
  

	
  

	
  

Agency:	
  

National	
  Alliance	
  for	
  Autism	
  Research	
   	
  

	
  

	
  

I.D.#	
   	
  

Private	
  Foundation	
  Grant	
   	
  

	
  

	
  

Title:	
   	
  

“Mentor-­‐based	
  Post-­‐Doctoral	
  Fellowship	
  in	
  Social	
  Neuroscience”	
  (Celine	
  

	
  

	
  

	
  

	
  

Saulnier,	
  PhD)	
  

	
  

	
  

P.I.:	
   	
  

Ami	
  Klin,	
  PhD	
  

Case 2:11-cv-04027-LDD Document 48-36 Filed 07/13/12 Page 30 of 84

Ami	
  Klin,	
  PhD	
  	
  	
  	
  	
  	
  	
  	
  	
  

	
  

	
  

	
  

	
  Page	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  1	
  	
  	3
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
   	
  	
  

	
  

	
  

Percent	
  effort:	5
   %	
  

	
  

	
  

Total	
  costs	
  for	
  project	
  period:	
  	
  $80,000	
  

	
  

	
  

Project	
  period:	
  

07/01/2002	
  –	
  06/30/2004	
  

	
  

	
  

	
  

Agency:	
  

National	
  Alliance	
  for	
  Autism	
  Research	
   	
  

	
  

	
  

I.D.#	
   	
  

Private	
  Foundation	
  Grant	
   	
  

	
  

	
  

Title:	
   	
  

“Studies	
  Of	
  Social	
  Visual	
  Pursuit	
  in	
  Non-­‐Human	
  Primates	
  with	
  Mesiofrontal-­‐	
  

	
  

	
  

Limbic	
  Lesions	
  Previously	
  Shown	
  to	
  Offer	
  a	
  Successful	
  Animal	
  Model	
  of	
  Autism”	
  

	
  

	
  

	
  P.I.:	
   	
  

Co-­‐PI	
  Ami	
  Klin,	
  PhD	
  (Co-­‐PI	
  Jocelyne	
  Bachevalier,	
  PhD)	
  

	
  

	
  

Percent	
  effort:	5
   %	
  

	
  

	
  

Total	
  costs	
  for	
  project	
  period:	
  	
  $91,730	
  

	
  

	
  

Project	
  period:	
  

07/01/2001	
  –	
  06/30/2003	
  

	
  

	
  

	
  

Agency:	
  

National	
  Alliance	
  for	
  Autism	
  Research	
   	
  

	
  

	
  

I.D.#	
   	
  

Private	
  Foundation	
  Grant	
   	
  

	
  

	
  

Title:	
   	
  

“Precursors	
  of	
  Joint	
  Attention	
  Skills	
  in	
  Autism	
  and	
  Related	
  Conditions”	
  

	
  

	
  

P.I.:	
   	
  

Kasia	
  Chawarska,	
  Ph.D.	
  

	
  

	
  

Role	
  on	
  Project:	
  Investigator	
  

	
  

	
  

Percent	
  effort:	5
   %	
  

	
  

	
  

Total	
  costs	
  for	
  project	
  period:	
  	
  $	
  120,000	
  

	
  

	
  

Project	
  period:	
  

07/01/2000	
  –	
  06/30/2002	
  

	
  

	
  

	
  

Agency:	
  

National	
  Alliance	
  for	
  Autism	
  Research	
   	
  

	
  

	
  

I.D.#	
   	
  

Private	
  Foundation	
  Grant	
   	
  

	
  

	
  

Title:	
   	
  

“Visual	
  Scanning	
  Patterns	
  and	
  Mental	
  Representations	
  of	
  Social	
  Interaction	
  	
  

	
  

	
  

	
  

	
  

in	
  Infants	
  and	
  Toddlers	
  Suspected	
  of	
  having	
  Autism”	
  

	
  

	
  

P.I.:	
   	
  

Ami	
  Klin,	
  PhD	
  

	
  

	
  

Percent	
  effort:	5
   %	
  

	
  

	
  

Total	
  costs	
  for	
  project	
  period:	
  	
  $97,080	
  

	
  

	
  

Project	
  period:	
  

07/01/2000	
  –	
  06/30/2002	
  

	
  

	
  

	
  

Agency:	
  

National	
  Alliance	
  for	
  Autism	
  Research	
   	
  

	
  

	
  

I.D.#	
   	
  

Private	
  Foundation	
  Grant	
   	
  

	
  

	
  

Title:	
   	
  

“Mentor-­‐based	
  Post-­‐Doctoral	
  Fellowship	
  in	
  Social	
  Neuroscience”	
  (The	
  Roland	
  D.	
  	
  

	
  

	
  

	
  

	
  

Ciaranello,	
  MD	
  Memorial	
  Fellowship	
  in	
  Basic	
  Research)	
  

	
  

	
  

P.I.:	
   	
  

Ami	
  Klin,	
  PhD	
  

	
  

	
  

Percent	
  effort:	5
   %	
  

	
  

	
  

Total	
  costs	
  for	
  project	
  period:	
  	
  $80,000	
  

	
  

	
  

Project	
  period:	
  

07/01/1999	
  –	
  06/30/2001	
  

	
  

	
  

	
  

Agency:	
  

Korczak	
  Foundation,	
  the	
  Netherlands	
  	
  

	
  

	
  

I.D.#	
   	
  

Private	
  Foundation	
  Grant	
   	
  

	
  

	
  

Title:	
   	
  

“Neuroscientific	
  Research	
  in	
  Autism”	
  

	
  

	
  

P.I.:	
   	
  

Donald	
  J.	
  Cohen,	
  MD	
  

Case 2:11-cv-04027-LDD Document 48-36 Filed 07/13/12 Page 31 of 84

Ami	
  Klin,	
  PhD	
  	
  	
  	
  	
  	
  	
  	
  	
  

	
  

	
  

	
  

	
  Page	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  1	
  	
  	4
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
   	
  	
  

	
  

	
  

Role	
  on	
  Project:	
  PI	
  Project	
  I	
  

	
  

	
  

Percent	
  effort:	6
   %	
  

	
  

	
  

Total	
  costs	
  for	
  project	
  period:	
  	
  $	
  150,000	
  

	
  

	
  

Project	
  period:	
  

04/15/1998	
  –	
  03/30/2002	
  

	
  

	
  

	
  

Agency:	
  

National	
  Institute	
  of	
  Child	
  Health	
  and	
  Human	
  Development	
  

	
  

	
  

I.D.#	
   	
  

P01	
  HD035482	
  (Program	
  Project,	
  Collaborative	
  Projects	
  of	
  Excellent	
  in	
  Autism)	
   	
  

	
  

	
  

Title:	
   	
  

“Neurobiology	
  and	
  Genetics	
  of	
  Autism	
  and	
  Related	
  Conditions”	
   	
  

	
  

	
  

P.I.:	
   	
  

Fred	
  R.	
  Volkmar,	
  MD	
  (Yale	
  CPEA)	
  

	
  

	
  

Role	
  on	
  project:	
  	
  Co-­‐PI	
  Project	
  IV,	
  Co-­‐Director	
  Assessment	
  Core	
  

	
  

	
  

Percent	
  effort:	2
   3%	
  

	
  

	
  

Total	
  costs	
  for	
  project	
  period:	
  	
  $5,754,109	
  

	
  

	
  

Project	
  period:	
  

06/01/1997	
  –	
  05/31/2002	
  

	
  

	
  

	
  

Agency:	
  

Autism	
  Society	
  of	
  America	
  Foundation	
   	
  

	
  

	
  

I.D.#	
   	
  

Private	
  Foundation	
  Grant	
   	
  

	
  

	
  

Title:	
   	
  

“Attributing	
  Meaning	
  to	
  Social	
  Movement	
  in	
  Autism”	
  

	
  

	
  

P.I.:	
   	
  

Ami	
  Klin,	
  PhD	
  

	
  

	
  

Percent	
  effort:	5
   %	
  

	
  

	
  

Total	
  costs	
  for	
  project	
  period:	
  	
  $30,093	
  

	
  

	
  

Project	
  period:	
  

07/01/1998	
  –	
  06/30/1999	
  

	
  

	
  

	
  

Agency:	
  

National	
  Institute	
  of	
  Child	
  Health	
  and	
  Human	
  Development	
  

	
  

	
  

I.D.#	
   	
  

P01	
  HD003008	
  

	
  

	
  

	
  

	
  

Title:	
   	
  

“Mental	
  Retardation	
  and	
  Developmental	
  Psychopathology”	
  

	
  

	
  

	
  

P.I.:	
   	
  

Donald	
  J.	
  Cohen,	
  MD	
  

	
  

	
  

Role	
  on	
  project:	
  	
  Co-­‐PI,	
  Project	
  III	
  	
  

	
  

	
  

Percent	
  effort:	2
   5%	
  

	
  

	
  

Total	
  costs	
  for	
  project	
  period:	
  $	
  4,345,000	
  

	
  

	
  

Project	
  period:	
  

09/15/1992	
  –	
  09/14/1999	
  

	
  

23.	
   Clinical	
  Service	
  Contributions:	
  

	
  

As	
  a	
  clinician	
  and	
  scientist,	
  the	
  former	
  was	
  always	
  the	
  inspiration	
  for	
  the	
  latter.	
  My	
  conviction	
  is	
  that	
  

our	
  very	
  best	
  research	
  hypotheses	
  are	
  derived	
  from	
  our	
  play	
  rooms,	
  and	
  indeed,	
  my	
  work	
  in	
  cognitive	
  

science	
  has	
  been	
  an	
  attempt	
  to	
  objectify	
  and	
  quantify	
  –	
  via	
  new	
  technologies	
  and	
  methods	
  –	
  the	
  

intuitive	
  judgments	
  that	
  we	
  make	
  as	
  clinicians.	
  Since	
  autism	
  is	
  a	
  social	
  disability,	
  as	
  clinicians,	
  we	
  are	
  

walking	
  laboratories	
  of	
  social	
  engagement.	
  As	
  scientists,	
  we	
  bring	
  this	
  experience	
  to	
  bear	
  on	
  the	
  design	
  

of	
  our	
  experiments,	
  on	
  our	
  scientific	
  constructs,	
  and	
  in	
  our	
  writing.	
  I	
  have	
  received	
  several	
  awards	
  for	
  

my	
  work	
  as	
  a	
  clinician	
  and	
  advocate	
  (see	
  #	
  17,	
  above).	
  But	
  I	
  believe	
  that	
  one	
  of	
  my	
  proudest	
  

accomplishments	
  was	
  to	
  expand	
  and	
  refine	
  one	
  of	
  the	
  leading	
  clinical	
  services	
  in	
  the	
  country	
  for	
  

individuals	
  with	
  autism	
  and	
  their	
  families	
  at	
  the	
  Yale	
  Child	
  Study	
  Center.	
  Building	
  on	
  the	
  pioneering	
  

work	
  of	
  Dr.	
  Donald	
  Cohen	
  and	
  collaborating	
  with	
  Dr.	
  Fred	
  Volkmar	
  during	
  the	
  1990’s,	
  I	
  was	
  able	
  to	
  

expand	
  the	
  clinical	
  services	
  provided	
  by	
  our	
  clinics	
  several	
  fold,	
  fully	
  integrate	
  it	
  with	
  our	
  program	
  of	
  

Case 2:11-cv-04027-LDD Document 48-36 Filed 07/13/12 Page 32 of 84

Ami	
  Klin,	
  PhD	
  	
  	
  	
  	
  	
  	
  	
  	
  

	
  

	
  

	
  

	
  Page	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  1	
  	
  	5
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
   	
  	
  

clinical	
  science,	
  establish	
  outreach	
  services,	
  expand	
  the	
  faculty	
  body	
  7-­‐fold,	
  create	
  a	
  pioneering	
  toddler	
  

clinic,	
  and	
  built	
  the	
  most	
  comprehensive	
  and	
  intensive	
  program	
  focused	
  on	
  infants	
  at	
  risk	
  for	
  ASD	
  in	
  

the	
  country,	
  averaging	
  3	
  children	
  per	
  day.	
  Functioning	
  as	
  the	
  hub	
  of	
  the	
  Autism	
  Program	
  at	
  Yale,	
  our	
  

clinical	
  services	
  grounded	
  our	
  program	
  of	
  research,	
  allowed	
  us	
  to	
  train	
  the	
  next	
  generation	
  of	
  clinical	
  

leaders	
  in	
  the	
  field	
  in	
  several	
  pertinent	
  disciplines	
  (child	
  psychiatry,	
  developmental	
  pediatrics,	
  clinical	
  

psychology,	
  speech-­‐language	
  pathology,	
  and	
  clinical	
  social	
  work),	
  and	
  placed	
  us	
  at	
  the	
  center	
  of	
  

information	
  dissemination	
  and	
  advocacy	
  efforts	
  in	
  our	
  community,	
  locally,	
  nationally,	
  and	
  

internationally.	
  The	
  move	
  to	
  Atlanta	
  in	
  2011	
  brought	
  these	
  models	
  to	
  what	
  is	
  the	
  largest	
  center	
  of	
  

clinical	
  care	
  of	
  children	
  and	
  adolescents	
  with	
  autism	
  in	
  the	
  country	
  –	
  the	
  Marcus	
  Autism	
  Center,	
  

leveraging	
  the	
  community	
  outreach	
  of	
  the	
  largest	
  system	
  of	
  pediatric	
  healthcare	
  in	
  the	
  country	
  –	
  

Children’s	
  Healthcare	
  of	
  Atlanta,	
  within	
  the	
  context	
  of	
  an	
  academic	
  and	
  scientific	
  home	
  –	
  the	
  especially	
  

created	
  Division	
  of	
  Autism	
  &	
  Related	
  Disorders	
  at	
  the	
  Department	
  of	
  Pediatrics,	
  Emory	
  University	
  

School	
  of	
  Medicine,	
  and	
  through	
  special	
  collaborative	
  relationships	
  with	
  cutting	
  edge	
  scientific	
  

institutions	
  such	
  as	
  the	
  Emory	
  Department	
  of	
  Human	
  Genetics	
  and	
  Yerkes	
  National	
  Primate	
  Research	
  

Center.	
  Our	
  thriving	
  research	
  program	
  now	
  encompasses	
  studies	
  that	
  range	
  from	
  genes	
  to	
  social	
  mind	
  

and	
  brain,	
  to	
  model	
  systems	
  and	
  creation	
  of	
  community-­‐viable	
  systems	
  of	
  care.	
  At	
  the	
  Marcus	
  Autism	
  

Center,	
  our	
  focus	
  is	
  on	
  the	
  Science	
  of	
  Clinical	
  Care,	
  and,	
  particularly,	
  bringing	
  science	
  to	
  bear	
  on	
  

practice	
  at	
  a	
  community	
  level.	
  The	
  translational	
  focus	
  of	
  our	
  research	
  is	
  in	
  line	
  with	
  current	
  priorities	
  at	
  

the	
  National	
  Institutes	
  of	
  Health,	
  and	
  is	
  reflected	
  in	
  our	
  central	
  membership	
  of	
  Emory	
  Center	
  for	
  

Translational	
  Social	
  Neuroscience.	
  	
  

	
  

24.	
   Formal	
  Teaching:	
  

	
  

	
  

a.	
   Medical	
  Student	
  Teaching:	
  

	
  

	
  

Yale	
  University	
  School	
  of	
  Medicine,	
  2nd	
  Year	
  Medical	
  Students	
  (YMS-­‐II),	
  Clinical	
  Psychiatry	
  Module:	
  	
  

	
  

	
  

Module	
  on	
  autism	
  and	
  related	
  disorders	
  and	
  on	
  intellectual	
  disabilities,	
  2000	
  –	
  2010.	
  	
  	
  

	
  

	
  

b.	
   Graduate	
  Programs:	
  

	
  

	
  

Yale	
  Child	
  Study	
  Center	
  and	
  Department	
  of	
  Psychiatry,	
  Yale	
  School	
  of	
  Medicine,	
  Psychiatry	
  Residents	
  II	
  

	
  

	
  

(PGY-­‐II),	
  Module	
  on	
  Autism	
  and	
  related	
  disorders,	
  2002-­‐2010.	
  	
  

	
  

Yale	
  Child	
  Study	
  Center,	
  Child	
  Psychiatry	
  Residents	
  I,	
  Module	
  on	
  Autism	
  and	
  related	
  disorders,	
  	
  

	
  

	
  

2004-­‐2010.	
  

	
  

Yale	
  New	
  Haven	
  Hospital,	
  Pediatric	
  Dentistry	
  Residents,	
  Module	
  on	
  Autism	
  and	
  related	
  disorders,	
  	
  

	
  

	
  

2005	
  -­‐	
  2006.	
  

	
  

	
  

c.	
   Other	
  categories:	
  

	
  

	
  

	
  

Yale	
  College:	
  Psychology	
  350a	
  –	
  Autism	
  and	
  related	
  disorders:	
  Seminar	
  and	
  Practicum,	
  	
  

	
  

	
  

2002-­‐2010.	
  	
  

	
  

Course	
  Director,	
  Yale	
  Child	
  Study	
  Center,	
  NIMH,	
  Yale	
  STAART	
  (Studies	
  to	
  Advance	
  Autism	
  Research	
  	
  

	
  

	
  

and	
  Treatment)	
  Summer	
  Training	
  in	
  Autism	
  (from	
  2006:	
  Yale	
  Autism	
  Program	
  Summer	
  	
   	
  

	
  

	
  

Institute),	
  2001-­‐2010.	
  

Case 2:11-cv-04027-LDD Document 48-36 Filed 07/13/12 Page 33 of 84

Ami	
  Klin,	
  PhD	
  	
  	
  	
  	
  	
  	
  	
  	
  

	
  

	
  

	
  

	
  Page	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  1	
  	
  	6
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
   	
  	
  

	
  

Regular	
  (1	
  per	
  semester)	
  guest	
  lectures	
  at	
  the	
  following	
  programs	
  and	
  departments:	
  Yale	
  Department	
  

	
  

	
  

of	
  Statistics,	
  Computer	
  Science,	
  Psychology,	
  Bioethics	
  Program,	
  Cognitive	
  Science;	
  and	
  Yale	
  

	
  

	
  

School	
  of	
  Medicine	
  Interdepartmental	
  Neuroscience	
  Program,	
  Pediatrics,	
  Developmental	
  

	
  

	
  

Pediatrics,	
  as	
  well	
  as	
  occasional	
  special	
  events	
  (e.g.,	
  Alumni	
  Week).	
  	
  

	
  

25.	
  	
   Supervisory	
  Teaching:	
  	
  

	
  

	
  

	
  

a.	
  Post-­‐doctoral	
  (direct	
  mentorship	
  only):	
  

	
  

	
  

	
  

Trainee	
  Name:	
  

	
  

Kevin	
  Pelphrey,	
  PhD	
  [mentor,	
  NIMH	
  K-­‐award;	
  Yale	
  Child	
  Study	
  Center]	
  

	
  

Training	
  Period:	
   	
  

2008	
  -­‐	
  2010	
  

	
  

Title	
  of	
  Research	
  Project:	
   Career	
  Development	
  Award:	
  Functional	
  Neuroimaging	
  of	
  Children	
  	
  

	
  

	
  

	
  

	
  

	
  

	
  

with	
  Autism	
   	
  

	
  

Other	
  Mentors:	
   	
  

Marcel	
  Just,	
  PhD	
  

	
  

Current	
  Position:	
  	
   	
  

Harris	
  Associate	
  Professor,	
  Yale	
  Child	
  Study	
  Center,	
  Yale	
  University	
  	
  

	
  

	
  

	
  

	
  

	
  

School	
  of	
  Medicine	
  

	
  

	
  

Trainee	
  Name:	
  

	
  

Rojer	
  Jou,	
  MD	
  [mentor,	
  American	
  Psychiatric	
  Association	
  Minority	
  	
  

	
  

	
  

	
  

	
  

	
  

Research	
  Training	
  in	
  	
  

	
  

	
  

	
  

	
  

	
  

Psychiatry,	
  and	
  PhD,	
  Investigative	
  Medicine	
  Program,	
  Yale	
  School	
  of	
  	
  

	
  

	
  

	
  

	
  

	
  

	
  

Medicine	
  

	
  

	
  

	
  

	
  

	
  

Training	
  Period:	
  2007	
  -­‐	
  2010	
  

	
  

	
  

	
  

	
  

	
  

Title	
  of	
  Research	
  Project:	
  Diffusion	
  Tensor	
  Imaging	
  studies	
  of	
  children	
  	
  

	
  

	
  

	
  

	
  

	
  

	
  

with	
  autism	
   	
  

	
  

Other	
  Mentors:	
   	
  

Kevin	
  Pelphrey,	
  PhD	
  

	
  

Current	
  Position:	
  	
   	
  

PhD	
  candidate,	
  Investigative	
  Medicine	
  Program,	
  Yale	
  School	
  of	
  Medicine	
  

	
  

	
  

Trainee	
  Name:	
  

	
  

Susan	
  Williams	
  White,	
  PhD	
  [advisor,	
  NIMH	
  K	
  Award]	
  	
  

	
  

Training	
  Period:	
   	
  

2007	
  -­‐	
  2010	
  

	
  

Title	
  of	
  Research	
  Project:	
   A	
  Cognitive-­‐Behavioral	
  Intervention	
  for	
  Children	
  with	
  Autism	
  	
   	
  

	
  

	
  

	
  

	
  

	
  

	
  

Spectrum	
  Disorders	
   	
  

	
  

Other	
  Mentors:	
   	
  

Lawrence	
  Scahill,	
  PhD	
  

	
  

Current	
  Position:	
  	
   	
  

Assistant	
  Professor	
  of	
  Psychiatry,	
  Virginia	
  Commonwealth	
  University	
  	
  

	
  

	
  

	
  

	
  

	
  

	
  

School	
  of	
  Medicine	
  

	
  

	
  

Trainee	
  Name:	
  

	
  

Judith	
  Danovitch,	
  PhD	
  [mentor	
  and	
  research	
  advisor,	
  post-­‐doctoral	
  	
  

	
  

	
  

	
  

	
  

	
  

	
  

fellow,	
  NIMH	
  T32;	
  Yale	
  Child	
  Study	
  Center]	
  

	
  

Training	
  Period:	
   	
  

2006	
  -­‐	
  2008	
  

	
  

Title	
  of	
  Research	
  Project:	
   Understanding	
  special	
  interests	
  in	
  higher	
  functioning	
  individuals	
  with	
  	
  

	
  

	
  

	
  

	
  

	
  

	
  

autism	
  spectrum	
  disorders	
   	
  

	
  

Current	
  Position:	
  	
   	
  

Assistant	
  Professor,	
  Department	
  of	
  Psychology,	
  Michigan	
  State	
  University	
  

	
  

	
  

Trainee	
  Name:	
  

	
  

Alexander	
  Westphal,	
  MD	
  [mentor,	
  NIMH	
  Loan	
  Repayment	
  Program,	
  and	
  	
  

	
  

	
  

	
  

	
  

	
  

	
  

PhD,	
  Yale	
  Child	
  Study	
  Center]	
  

Case 2:11-cv-04027-LDD Document 48-36 Filed 07/13/12 Page 34 of 84

Ami	
  Klin,	
  PhD	
  	
  	
  	
  	
  	
  	
  	
  	
  

	
  

	
  

	
  

	
  Page	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  1	
  	
  	7
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
   	
  	
  

	
  

Training	
  Period:	
   	
  

2006	
  -­‐	
  2008	
  

	
  

Title	
  of	
  Research	
  Project:	
   Novel	
  applications	
  of	
  eye-­‐tracking	
  to	
  autism	
  research:	
  eye	
  contrast	
  	
  

	
  

	
  

	
  

	
  

	
  

	
  

polarity,	
  perceptual	
  shifting,	
  and	
  novel	
  outcome	
  measures	
  	
  

	
  

Other	
  Mentors:	
   	
  

Warren	
  Jones,	
  PhD,	
  Gordon	
  Ramsay,	
  PhD	
  

	
  

Current	
  Position:	
  	
   	
  

PhD	
  candidate,	
  Investigative	
  Medicine	
  Program,	
  Yale	
  School	
  of	
  Medicine	
  

	
  

	
  

Trainee	
  Name:	
  

	
  

James	
  McPartland,	
  PhD	
  [mentor	
  and	
  advisor,	
  pre-­‐	
  &	
  post-­‐doctoral	
  fellow,	
  

	
  

	
  

	
  

	
  

	
  

	
  

NIMH	
  R03,	
  Yale	
  CTSA	
  Scholar	
  Program,	
  NIMH	
  K-­‐award;	
  Yale	
  Child	
  

	
  

	
  

	
  

	
  

	
  

	
  

	
  Study	
  Center]	
  

	
  

Training	
  Period:	
   	
  

2004	
  -­‐	
  present	
  

	
  

Title	
  of	
  Research	
  Project:	
   Neural	
  correlates	
  of	
  perceptual	
  expertise	
  in	
  autism;	
  The	
  role	
  of	
  	
  

	
  

	
  

	
  

	
  

	
  

	
  

context	
  in	
  face	
  processing	
  –	
  ERP	
  studies	
  of	
  adolescents	
  with	
  	
  

	
  

	
  

	
  

	
  

	
  

	
  

autism;	
  Electrophysiologic	
  studies	
  of	
  infants	
  at	
  risk	
  for	
  autism.	
  	
   	
  

	
  

Other	
  Mentors:	
   	
  

Linda	
  Mayes,	
  MD;	
  Charles	
  Nelson,	
  PhD	
  

	
  

Current	
  Position:	
  	
   	
  

Assistant	
  Professor,	
  Yale	
  Child	
  Study	
  Center,	
  Yale	
  University	
  School	
  of	
  	
  

	
  

	
  

	
  

	
  

	
  

	
  

Medicine	
  

	
  

	
  

Trainee	
  Name:	
  

	
  

Melissa	
  Preissler,	
  PhD	
  [mentor,	
  mentor-­‐based	
  post-­‐doctoral	
  fellowship,	
  

	
  

	
  

	
  

	
  

	
  

	
  

	
  National	
  Alliance	
  for	
  Autism	
  Research)	
  	
  

	
  

Training	
  Period:	
   	
  

2003	
  -­‐	
  2005	
  

	
  

Title	
  of	
  Research	
  Project:	
   The	
  development	
  of	
  symbolic	
  capacities	
  in	
  toddlers	
  with	
  autism	
  

	
  

Other	
  Mentors:	
   	
  

Paul	
  Bloom,	
  PhD	
  

	
  

Current	
  Position:	
  	
   	
  

Dr.	
  Melissa	
  Allen,	
  Assistant	
  Professor,	
  Psychology	
  Department,	
  Fylde	
  

	
  

	
  

	
  

	
  

	
  

	
  

Building,	
  Lancaster	
  University,	
  UK	
  

	
  

	
  

Trainee	
  Name:	
  

	
  

Celine	
  Saulnier,	
  PhD	
  [mentor,	
  mentor-­‐based	
  post-­‐doctoral	
  fellowship,	
  	
  

	
  

	
  

	
  

	
  

	
  

	
  

National	
  Alliance	
  for	
  Autism	
  Research)	
  	
  

	
  

Training	
  Period:	
   	
  

2002	
  -­‐	
  2004	
  

	
  

Title	
  of	
  Research	
  Project:	
   Social	
  ability	
  and	
  disability	
  in	
  autism	
  spectrum	
  disorders	
  

	
  

Current	
  Position:	
  	
   	
  

Clinical	
  Director	
  for	
  Research,	
  Marcus	
  Autism	
  Center,	
  Children’s	
  	
   	
  

	
  

	
  

	
  

	
  

	
  

	
  

Healthcare	
  of	
  Atlanta	
  and	
  Assistant	
  Professor,	
  Division	
  of	
  Autism	
  	
  

	
  

	
  

	
  

	
  

	
  

	
  

and	
  Developmental	
  Disorders,	
  Department	
  of	
  Pediatrics,	
  Emory	
  	
  

	
  

	
  

	
  

	
  

	
  

	
  

University	
  School	
  of	
  Medicine	
  

	
  

	
  

Trainee	
  Name:	
  

	
  

Katarzyna	
  Chawarska,	
  PhD	
  [mentor,	
  post-­‐doctoral	
  fellowship]	
  	
  

	
  

Training	
  Period:	
   	
  

2000	
  -­‐	
  2002	
  

	
  

Title	
  of	
  Research	
  Project:	
   Programmatic	
  research	
  on	
  infant	
  cognition	
  and	
  toddlers	
  with	
  autism	
  

	
  

Current	
  Position:	
  	
   	
  

Director,	
  Toddler	
  Developmental	
  Disabilities	
  Clinic,	
  Associate	
  Professor,	
  	
  

	
  

	
  

	
  

	
  

	
  

	
  

Yale	
  Child	
  Study	
  Center,	
  Yale	
  University	
  School	
  of	
  Medicine	
  	
  

	
  

	
  

	
  

	
  

	
  

Trainee	
  Name:	
  

	
  

Katherine	
  Tsatsanis,	
  PhD	
  [mentor,	
  mentor-­‐based	
  post-­‐doctoral	
  	
  

	
  

	
  

	
  

	
  

	
  

	
  

fellowship,	
  Roland	
  D.	
  Ciaranello,	
  MD	
  Memorial	
  Fellowship	
  in	
  	
  

	
  

	
  

	
  

	
  

	
  

	
  

Basic	
  Research,	
  National	
  Alliance	
  for	
  Autism	
  Research)	
  	
  

Case 2:11-cv-04027-LDD Document 48-36 Filed 07/13/12 Page 35 of 84

Ami	
  Klin,	
  PhD	
  	
  	
  	
  	
  	
  	
  	
  	
  

	
  

	
  

	
  

	
  Page	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  1	
  	
  	8
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
   	
  	
  

	
  

Training	
  Period:	
   	
  

1999	
  -­‐	
  2001	
  

	
  

Title	
  of	
  Research	
  Project:	
   The	
  neuropsychology	
  of	
  autism	
  spectrum	
  disorders	
  

	
  

Current	
  Position:	
  	
   	
  

Associate	
  Research	
  Scientist,	
  Yale	
  Child	
  Study	
  Center,	
  Yale	
  University	
  

	
  

	
  

	
  

	
  

	
  

	
  

	
  School	
  of	
  Medicine	
  

	
  

	
  

b.	
  Pre-­‐doctoral	
  (only	
  direct	
  mentorship;	
  active	
  supervision	
  from	
  year	
  2000	
  only):	
  

	
  

	
  

	
  

Trainee	
  Name:	
  

	
  

Jennifer	
  Moriuchi	
  [mentor,	
  Marcus	
  Graduate	
  Fellowship	
  in	
  Autism	
  and	
  	
  

	
  

	
  

	
  

	
  

	
  

	
  

Developmental	
  Disabilities]	
  

	
  

Training	
  Period:	
   	
  

2011	
  -­‐	
  2015	
  

	
  

Title	
  of	
  Research	
  Project:	
   Project	
  1:	
  Aversion	
  or	
  Indifference:	
  Mechanisms	
  underlying	
  atypical	
  eye	
  	
  

	
  

	
  

	
  

	
  

	
  

	
  

contact	
  in	
  Autism	
  	
  

	
  

	
  

	
  

	
  

	
  

Project	
  2:	
  Gender	
  and	
  Cognitive	
  Profile	
  as	
  Predictors	
  of	
  Functional	
  	
  

	
  

	
  

	
  

	
  

	
  

	
  

Outcomes	
  in	
  School-­‐aged	
  Children	
  with	
  Autism	
  Spectrum	
  	
   	
  

	
  

	
  

	
  

	
  

	
  

	
  

Disorders	
  

	
  

Other	
  Mentors:	
   	
  

Warren	
  Jones	
  PhD,	
  Celine	
  Saulnier	
  PhD	
  

	
  

Current	
  Position:	
  	
   	
  

Graduate	
  Student,	
  Clinical	
  Psychology,	
  Emory	
  University	
  Department	
  of	
  	
  

	
  

	
  

	
  

	
  

	
  

	
  

Psychology	
  

	
  

	
  

Trainee	
  Name:	
  

	
  

Jennifer	
  Moriuchi	
  [mentor-­‐based	
  Predoctoral	
  Fellowship	
  award,	
  Autism	
  	
  

	
  

	
  

	
  

	
  

	
  

	
  

Science	
  Foundation]	
  

	
  

Training	
  Period:	
   	
  

2012	
  -­‐	
  2013	
  

	
  

Title	
  of	
  Research	
  Project:	
   Gender	
  and	
  Cognitive	
  Profile	
  as	
  Predictors	
  of	
  Functional	
  Outcomes	
  in	
  	
  

	
  

	
  

	
  

	
  

	
  

	
  

School-­‐aged	
  Children	
  with	
  Autism	
  Spectrum	
  Disorders	
  

	
  

Other	
  Mentors:	
   	
  

Warren	
  Jones	
  PhD	
  

	
  

Current	
  Position:	
  	
   	
  

Graduate	
  Student,	
  Clinical	
  Psychology,	
  Emory	
  University	
  Department	
  of	
  	
  

	
  

	
  

	
  

	
  

	
  

	
  

Psychology	
   	
  

	
  

	
  

Trainee	
  Name:	
  

	
  

Tawny	
  Tsang	
  [mentor,	
  predoctoral Donald J. Cohen Fellowship in

Developmental Social Neuroscience, Marcus Autism Center]	
  

	
  

Training	
  Period:	
   	
  

2011	
  -­‐	
  present	
  

	
  

Title	
  of	
  Research	
  Project:	
   Development	
  of	
  Oculomotor	
  Function	
  from	
  Birth	
  Until	
  3	
  Years	
  of	
  Age	
  in	
  	
  

	
  

	
  

	
  

	
  

	
  

	
  

Typically-­‐Developming	
  Infants	
  and	
  Infants	
  At-­‐Risk	
  for	
  Autism	
  

	
  

Other	
  Mentors:	
   	
  

Warren	
  Jones	
  PhD,	
  Gordon	
  Ramsay	
  PhD	
  

	
  

Current	
  Position:	
  	
   	
  

Predoctoral	
  Research	
  Fellow,	
  Marcus	
  Autism	
  Center	
  and	
  Emory	
  Pediatrics	
  

	
  

	
  

Trainee	
  Name:	
  

	
  

Serene	
  Habayeb	
  [mentor,	
  predoctoral Donald J. Cohen Fellowship in

Developmental Neuroscience, Yale Child Study Center, Marcus

Autism Center]	
  

	
  

	
  

Training	
  Period:	
   	
  

2011	
  -­‐	
  present	
  

	
  

Title	
  of	
  Research	
  Project:	
   Dynamic	
  Measures	
  of	
  Social	
  Visual	
  Engagement	
  in	
  12-­‐	
  to	
  24-­‐Month-­‐Old	
  	
  

	
  

	
  

	
  

	
  

	
  

	
  

Infants	
  with	
  Autism	
  Spectrum	
  Disorders	
  

	
  

Other	
  Mentors:	
   	
  

Warren	
  Jones	
  PhD,	
  Gordon	
  Ramsay	
  PhD	
  

	
  

Current	
  Position:	
  	
   	
  

Predoctoral	
  Research	
  Fellow,	
  Marcus	
  Autism	
  Center	
  and	
  Emory	
  Pediatrics	
  

Case 2:11-cv-04027-LDD Document 48-36 Filed 07/13/12 Page 36 of 84

Ami	
  Klin,	
  PhD	
  	
  	
  	
  	
  	
  	
  	
  	
  

	
  

	
  

	
  

	
  Page	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  1	
  	
  	9
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
   	
  	
  

	
  

	
  

Trainee	
  Name:	
  

	
  

Maria	
  Ly	
  [mentor,	
  Simons Fellowship in Design Engineering, Marcus

Autism Center]	
  

	
  

Training	
  Period:	
   	
  

2011	
  -­‐	
  present	
  

	
  

Title	
  of	
  Research	
  Project:	
   Measures	
  of	
  Haptic	
  Intersubjectivity	
  in	
  School-­‐Age	
  Children	
  with	
  Autism	
  

	
  

Other	
  Mentors:	
   	
  

Warren	
  Jones	
  PhD,	
  Gordon	
  Ramsay	
  PhD	
  

	
  

Current	
  Position:	
  	
   	
  

Predoctoral	
  Research	
  Fellow,	
  Marcus	
  Autism	
  Center	
  and	
  Emory	
  Pediatrics	
  

	
  

	
  

Trainee	
  Name:	
  

	
  

Sarah	
  Glazer	
  [mentor,	
  Simons Fellowship in Computational

Neuroscience, Marcus Autism Center	
  

	
  

Training	
  Period:	
   	
  

2011	
  -­‐	
  present	
  

	
  

Title	
  of	
  Research	
  Project:	
   Interactional	
  Synchrony	
  in	
  Live	
  Mother-­‐Infant	
  Interactions	
  in	
  the	
  First	
  6	
  	
  

	
  

	
  

	
  

	
  

	
  

	
  

Months	
  of	
  Life	
  

	
  

Other	
  Mentors:	
   	
  

Warren	
  Jones	
  PhD,	
  Gordon	
  Ramsay	
  PhD	
  

	
  

Current	
  Position:	
  	
   	
  

Predoctoral	
  Research	
  Fellow,	
  Marcus	
  Autism	
  Center	
  and	
  Emory	
  Pediatrics	
  

	
  

Trainee	
  Name:	
  

	
  

Kristin	
  Muench	
  [mentor,	
  Research	
  Specialist,	
  Marcus	
  Autism	
  Center]	
  

Training	
  Period:	
   	
  

2011	
  -­‐	
  present	
  

Title	
  of	
  Research	
  Project:	
   Prenatal	
  responses	
  to	
  speech	
  in	
  fetuses	
  at	
  risk	
  for	
  autism	
  

Other	
  Mentors:	
   	
  

Gordon	
  Ramsay	
  PhD	
  

Current	
  Position:	
   	
  

Research	
  Specialist,	
  Marcus	
  Autism	
  Center	
  and	
  Emory	
  Pediatrics	
  

	
  

	
  

Trainee	
  Name:	
  

	
  

Jeremy	
  Borjon	
  [mentor,	
  predoctoral	
  Simons	
  Fellowship	
  in	
  Computational	
  	
  

	
  

	
  

	
  

	
  

	
  

Neuroscience,	
  Yale	
  Child	
  Study	
  Center,	
  Marcus	
  Autism	
  Center]	
  

	
  

Training	
  Period:	
   	
  

2010	
  -­‐	
  2012	
  

	
  

Title	
  of	
  Research	
  Project:	
   Social	
  Monitoring	
  in	
  Rhesus	
  Monkeys	
  with	
  Lesions	
  to	
  Either	
  the	
  	
   	
  

	
  

	
  

	
  

	
  

	
  

	
  

Amygdala,	
  Hippocampus,	
  or	
  Orbitofrontal	
  Cortex	
  

	
  

Other	
  Mentors:	
   	
  

Warren	
  Jones	
  PhD,	
  Gordon	
  Ramsay	
  PhD	
  

	
  

Current	
  Position:	
  	
   	
  

Predoctoral	
  Research	
  Fellow,	
  Marcus	
  Autism	
  Center	
  and	
  Emory	
  Pediatrics	
  	
  

	
  

	
  

Trainee	
  Name:	
  

	
  

Andrea	
  Trubanova	
  [mentor,	
  predoctoral	
  Donald	
  J.	
  Cohen	
  Fellowship	
  in	
  	
  

	
  

	
  

	
  

	
  

	
  

	
  

Developmental	
  Social	
  Neuroscience,	
  Yale	
  Child	
  Study	
  Center,	
  	
  

	
  

	
  

	
  

	
  

	
  

	
  

Marcus	
  Autism	
  Center]	
  

	
  

Training	
  Period:	
   	
  

2010	
  -­‐	
  2012	
  

	
  

Title	
  of	
  Research	
  Project:	
   Inducing	
  Change	
  in	
  Visual	
  Scanning	
  of	
  Natural	
  Scenes	
  in	
  Infants	
  with	
  ASD	
  	
  

	
  

	
  

	
  

	
  

	
  

	
  

by	
  Manipulating	
  Physical	
  Contingencies	
  

	
  

Other	
  Mentors:	
   	
  

Warren	
  Jones	
  PhD,	
  Gordon	
  Ramsay	
  PhD	
  

	
  

Current	
  Position:	
  	
   	
  

Predoctoral	
  Research	
  Fellow,	
  Marcus	
  Autism	
  Center	
  and	
  Emory	
  Pediatrics	
  	
  

	
  

	
  

Trainee	
  Name:	
  

	
  

Jessica	
  Jones	
  [mentor,	
  predoctoral	
  Donald	
  J.	
  Cohen	
  Fellowship	
  in	
  	
   	
  

	
  

	
  

	
  

	
  

	
  

	
  

Developmental	
  Social	
  Neuroscience,	
  Yale	
  Child	
  Study	
  Center,	
  	
  

	
  

	
  

	
  

	
  

	
  

	
  

Marcus	
  Autism	
  Center]	
  

	
  

Training	
  Period:	
   	
  

2010	
  -­‐	
  2012	
  

	
  

Title	
  of	
  Research	
  Project:	
   Dynamic	
  Allocation	
  of	
  Visual	
  Resources	
  in	
  the	
  First	
  6	
  Months	
  

Case 2:11-cv-04027-LDD Document 48-36 Filed 07/13/12 Page 37 of 84

Ami	
  Klin,	
  PhD	
  	
  	
  	
  	
  	
  	
  	
  	
  

	
  

	
  

	
  

	
  Page	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  2	
  	
  	0
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
   	
  	
  

	
  

Other	
  Mentors:	
   	
  

Warren	
  Jones	
  PhD,	
  Gordon	
  Ramsay	
  PhD	
  

	
  

Current	
  Position:	
  	
   	
  

Predoctoral	
  Research	
  Fellow,	
  Marcus	
  Autism	
  Center	
  and	
  Emory	
  Pediatrics	
  	
  

	
  

	
  

Trainee	
  Name:	
  

	
  

Kate	
  Rice	
  [mentor,	
  predoctoral	
  Donald	
  J.	
  Cohen	
  Fellowship	
  in	
  	
   	
  

	
  

	
  

	
  

	
  

	
  

Developmental	
  Social	
  Neuroscience,	
  Yale	
  Child	
  Study	
  Center]	
  

	
  

Training	
  Period:	
   	
  

2009	
  -­‐	
  2011	
  

	
  

Title	
  of	
  Research	
  Project:	
   Sensitivity	
  and	
  response	
  to	
  direct	
  and	
  averted	
  gaze	
  in	
  toddlers	
  with	
  ASD.	
  

	
  

Other	
  Mentors:	
   	
  

Warren	
  Jones	
  PhD,	
  Gordon	
  Ramsay	
  PhD	
  

	
  

Current	
  Position:	
  	
   	
  

Graduate	
  student	
  in	
  Developmental	
  Psychology,	
  University	
  of	
  Maryland	
  

	
  

	
  

Trainee	
  Name:	
  

	
  

Jennifer	
  Moriuchi	
  [mentor,	
  predoctoral	
  Donald	
  J.	
  Cohen	
  Fellowship	
  in	
  	
  

	
  

	
  

	
  

	
  

	
  

	
  

Developmental	
  Social	
  Neuroscience,	
  Yale	
  Child	
  Study	
  Center]	
  

	
  

Training	
  Period:	
   	
  

2009	
  -­‐	
  2011	
  

	
  

Title	
  of	
  Research	
  Project:	
   Distinguishing	
  gaze	
  aversion	
  from	
  gaze	
  indifference	
  in	
  two-­‐year-­‐olds	
  with	
  

	
  

	
  

	
  

	
  

	
  

	
  	
   autism.	
  	
  

	
  

Other	
  Mentors:	
   	
  

Warren	
  Jones	
  PhD,	
  Gordon	
  Ramsay	
  PhD	
  

	
  

Current	
  Position:	
  	
   	
  

Graduate	
  Student,	
  Clinical	
  Psychology,	
  Emory	
  University	
  Department	
  of	
  	
  

	
  

	
  

	
  

	
  

	
  

	
  

Psychology	
   	
  

	
  

	
  

Trainee	
  Name:	
  

	
  

Jennings	
  Xu	
  [mentor,	
  predoctoral	
  Simons	
  Fellowship	
  in	
  Computational	
  	
  

	
  

	
  

	
  

	
  

	
  

	
  

Neuroscience,	
  Yale	
  Child	
  Study	
  Center]	
  

	
  

Training	
  Period:	
   	
  

2008	
  -­‐	
  2010	
  

	
  

Title	
  of	
  Research	
  Project:	
   Social	
  and	
  visual	
  factors	
  impacting	
  on	
  social	
  visual	
  engagement	
  in	
  	
  

	
  

	
  

	
  

	
  

	
  

	
  

2-­‐year-­‐olds	
  with	
  autism	
  

	
  

Other	
  Mentors:	
   	
  

Warren	
  Jones	
  PhD,	
  Gordon	
  Ramsay	
  PhD	
  

	
  

Current	
  Position:	
  	
   	
  

MD	
  PhD	
  Program	
  at	
  Case	
  Western	
  Reserve	
  University	
  School	
  of	
  Medicine	
  

	
  

	
  

Trainee	
  Name:	
  

	
  

Jessie	
  Northrup	
  [mentor,	
  predoctoral	
  Donald	
  J.	
  Cohen	
  Fellowship	
  in	
  	
  

	
  

	
  

	
  

	
  

	
  

	
  

Developmental	
  Social	
  Neuroscience,	
  Yale	
  Child	
  Study	
  Center]	
  

	
  

Training	
  Period:	
   	
  

2008	
  -­‐	
  2010	
  

	
  

Title	
  of	
  Research	
  Project:	
   Perception	
  of	
  Audiovisual	
  Synchrony	
  Under	
  Varying	
  Degrees	
  of	
  Social	
  	
  

	
  

	
  

	
  

	
  

	
  

	
  

Context	
  in	
  Infants	
  with	
  Autism	
  

	
  

Other	
  Mentors:	
   	
  

Warren	
  Jones	
  PhD,	
  Gordon	
  Ramsay	
  PhD	
  

	
  

Current	
  Position:	
  	
   	
  

PhD	
  Program	
  in	
  Clinical	
  and	
  Developmental	
  Psychology,	
  University	
  of	
  

	
  

	
  

	
  

	
  

	
  

	
  

Pittsburgh	
  

	
  

	
  

Trainee	
  Name:	
  

	
  

Laura	
  Edwards	
  [mentor,	
  predoctoral	
  Donald	
  J.	
  Cohen	
  Fellowship	
  in	
  	
  

	
  

	
  

	
  

	
  

	
  

	
  

Developmental	
  Social	
  Neuroscience,	
  Yale	
  Child	
  Study	
  Center]	
  

	
  

Training	
  Period:	
   	
  

2008	
  -­‐	
  2010	
  

	
  

Title	
  of	
  Research	
  Project:	
   Visual	
  scanning	
  of	
  dynamic	
  faces	
  in	
  relation	
  to	
  varying	
  positive	
  and	
  

	
  

	
  

	
  

	
  

	
  

	
  

	
  negative	
  affect	
  in	
  toddlers	
  with	
  autism	
  	
  

	
  

Other	
  Mentors:	
   	
  

Warren	
  Jones	
  PhD,	
  Gordon	
  Ramsay	
  PhD	
  

	
  

Current	
  Position:	
  	
   	
  

PhD	
  Program	
  in	
  Human	
  Development	
  and	
  Education,	
  Harvard	
  University	
  	
  

	
  

Case 2:11-cv-04027-LDD Document 48-36 Filed 07/13/12 Page 38 of 84

Ami	
  Klin,	
  PhD	
  	
  	
  	
  	
  	
  	
  	
  	
  

	
  

	
  

	
  

	
  Page	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  2	
  	
  	1
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
   	
  	
  

	
  

Trainee	
  Name:	
  

	
  

Marilyn	
  Ackerman	
  [mentor,	
  predoctoral	
  Simons	
  Fellowship	
  in	
  

	
  

	
  

	
  

	
  

	
  

	
  	
   Engineering	
  &	
  Experimental	
  Design,	
  Yale	
  Child	
  Study	
  Center]	
  

	
  

Training	
  Period:	
   	
  

2008	
  –	
  present	
  

	
  

Title	
  of	
  Research	
  Project:	
   Sensitivity	
  to	
  social	
  touch	
  in	
  school-­‐age	
  children	
  with	
  autism	
  	
  

	
  

Other	
  Mentors:	
   	
  

Warren	
  Jones	
  PhD,	
  Gordon	
  Ramsay	
  PhD	
  

	
  

Current	
  Position:	
  	
   	
  

Predoctoral	
  Fellow,	
  Yale	
  Child	
  Study	
  Center,	
  Yale	
  University	
  School	
  of	
  

	
  

	
  

	
  

	
  

	
  

	
  

	
  Medicine	
  

	
  

	
  

Trainee	
  Name:	
  

	
  

Anna	
  Krasno	
  [mentor,	
  predoctoral	
  Donald	
  J.	
  Cohen	
  Fellowship	
  in	
  	
   	
  

	
  

	
  

	
  

	
  

	
  

	
  

Developmental	
  Social	
  Neuroscience,	
  Yale	
  Child	
  Study	
  Center]	
  

	
  

Training	
  Period:	
   	
  

2007	
  –	
  2009	
  

	
  

Title	
  of	
  Research	
  Project:	
   Eye-­‐tracking	
  measures	
  of	
  social	
  monitoring	
  in	
  children	
  with	
  autism	
  

	
  

Other	
  Mentors:	
   	
  

Warren	
  Jones	
  PhD,	
  Gordon	
  Ramsay	
  PhD	
  

	
  

Current	
  Position:	
  	
   	
  

PhD	
  Program	
  in	
  Clinical	
  Psychology,	
  University	
  of	
  California	
  Santa	
  

	
  

	
  

	
  

	
  

	
  

	
  

Barbara	
  

	
  

	
  

Trainee	
  Name:	
  

	
  

Casey	
  Zampella	
  [mentor,	
  predoctoral	
  Donald	
  J.	
  Cohen	
  Fellowship	
  in	
  	
  

	
  

	
  

	
  

	
  

	
  

	
  

Developmental	
  Social	
  Neuroscience,	
  Yale	
  Child	
  Study	
  Center]	
  

	
  

Training	
  Period:	
   	
  

2007	
  -­‐	
  2009	
  

	
  

Title	
  of	
  Research	
  Project:	
   Oculomotor	
  behavior	
  in	
  toddlers	
  with	
  autism	
  during	
  naturalistic	
  viewing	
  	
  

	
  

	
  

	
  

	
  

	
  

	
  

of	
  social	
  scenes	
  

	
  

Other	
  Mentors:	
   	
  

Warren	
  Jones	
  PhD,	
  Gordon	
  Ramsay	
  PhD	
  

	
  

Current	
  Position:	
  	
   	
  

PhD	
  Program	
  in	
  Neuroscience,	
  University	
  of	
  Rochester,	
  NY	
  

	
  

	
  

Trainee	
  Name:	
  

	
  

Christine	
  Foley	
  [external	
  advisor,	
  PhD	
  Clinical	
  Psychology,	
  Boston	
  	
  	
  

	
  

	
  

	
  

	
  

	
  

	
  

University]	
  

	
  

Training	
  Period:	
   	
  

2007	
  -­‐	
  2010	
  

	
  

Title	
  of	
  Research	
  Project:	
   Do	
  executive	
  dysfunction,	
  weak	
  central	
  coherence	
  and	
  theory	
  of	
  mind	
  	
  

	
  

	
  

	
  

	
  

	
  

	
  

predict	
  social	
  	
   competence	
  in	
  non-­‐autistic	
  school-­‐age	
  children?	
  

	
  

Current	
  Position:	
  	
   	
  

PhD	
  candidate,	
  Department	
  of	
  Psychology,	
  Boston	
  University	
  

	
  

	
  

Trainee	
  Name:	
  

	
  

David	
  Lin	
  [mentor,	
  predoctoral	
  Simons	
  Fellowship	
  in	
  Computational	
  	
  

	
  

	
  

	
  

	
  

	
  

	
  

Neuroscience,	
  Yale	
  Child	
  Study	
  Center]	
  

	
  

Training	
  Period:	
   	
  

2006	
  -­‐	
  2008	
  

	
  

Title	
  of	
  Research	
  Project:	
   Preferential	
  attention	
  to	
  human	
  biological	
  motion	
  and	
  non-­‐social	
  physical	
  

	
  

	
  

	
  

	
  

	
  

	
  

contingencies	
  in	
  2-­‐Year-­‐olds	
  with	
  autism	
  

	
  

Other	
  Mentors:	
   	
  

Warren	
  Jones	
  PhD,	
  Gordon	
  Ramsay	
  PhD	
  

	
  

Current	
  Position:	
  	
   	
  

MD	
  candidate,	
  Division	
  of	
  Health	
  Sciences	
  and	
  Technology,	
  	
  

	
  

	
  

	
  

	
  

	
  

	
  

	
  

Harvard	
  Medical	
  School	
  

	
  

	
  

Trainee	
  Name:	
  

	
  

Kelley	
  Knoch	
  [mentor,	
  predoctoral	
  Donald	
  J.	
  Cohen	
  Fellowship	
  in	
  	
   	
  

	
  

	
  

	
  

	
  

	
  

	
  

Developmental	
  Social	
  Neuroscience,	
  Yale	
  Child	
  Study	
  Center]	
  

	
  

Training	
  Period:	
   	
  

2006	
  -­‐	
  2008	
  

Case 2:11-cv-04027-LDD Document 48-36 Filed 07/13/12 Page 39 of 84

Ami	
  Klin,	
  PhD	
  	
  	
  	
  	
  	
  	
  	
  	
  

	
  

	
  

	
  

	
  Page	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  2	
  	
  	2
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
   	
  	
  

	
  

Title	
  of	
  Research	
  Project:	
   Eye-­‐tracking	
  studies	
  of	
  the	
  “adaptive	
  saccade”	
  in	
  adolescents	
  with	
  autism	
  

	
  

	
  

	
  

	
  

	
  

	
  

spectrum	
  disorders	
  

	
  

Other	
  Mentors:	
   	
  

Warren	
  Jones	
  PhD	
  

	
  

Current	
  Position:	
  	
   	
  

PhD	
  candidate,	
  Clinical	
  Neuropsychology,	
  Department	
  of	
  Psychology,	
  	
  

	
  

	
  

	
  

	
  

	
  

	
  

University	
  of	
  Connecticut	
  

	
  

	
  

Trainee	
  Name:	
  

	
  

Sarah	
  Shultz	
  [mentor,	
  predoctoral	
  Donald	
  J.	
  Cohen	
  Fellowship	
  in	
  	
  

	
  

	
  

	
  

	
  

	
  

	
  

Developmental	
  Social	
  Neuroscience,	
  Yale	
  Child	
  Study	
  Center;	
  	
  

	
  

	
  

	
  

	
  

	
  

	
  

PhD	
  advisor,	
  Department	
  of	
  Psychology,	
  Yale	
  University]	
  

	
  

Training	
  Period:	
   	
  

2006	
  -­‐	
  present	
  

	
  

Title	
  of	
  Research	
  Project:	
   Eye	
  blinking	
  as	
  an	
  index	
  of	
  stimulus	
  salience	
  in	
  children	
  with	
  autism;	
  

	
  

	
  

	
  

	
  

	
  

	
  

subsequently,	
  Processing	
  of	
  biological	
  motion	
  in	
  infants	
  at	
  risk	
  	
  

	
  

	
  

	
  

	
  

	
  

	
  

for	
  autism	
  spectrum	
  disorders.	
  	
  

	
  

Other	
  Mentors:	
   	
  

Warren	
  Jones	
  PhD,	
  Gordon	
  Ramsay	
  PhD	
  

	
  

Current	
  Position:	
  	
   	
  

PhD	
  candidate,	
  Yale	
  University	
  Department	
  of	
  Psychology	
  

	
  

	
  

Trainee	
  Name:	
  

	
  

Adam	
  Naples,	
  PhD	
  [research	
  advisor	
  for	
  PhD;	
  Department	
  of	
  Psychology,	
  	
  

	
  

	
  

	
  

	
  

	
  

	
  

Yale	
  University]	
  

	
  

Training	
  Period:	
   	
  

2004	
  -­‐	
  2007	
  

	
  

Title	
  of	
  Research	
  Project:	
   Hyperlexia	
  in	
  autism	
  spectrum	
  disorders	
   	
  

	
  

Other	
  Mentors:	
   	
  

Elena	
  Grigorenko,	
  PhD	
  

	
  

Current	
  Position:	
  	
   	
  

Post-­‐doctoral	
  Fellow	
  (NIMH	
  T32),	
  Yale	
  Child	
  Study	
  Center,	
  Yale	
  	
   	
  

	
  

	
  

	
  

	
  

	
  

	
  

University	
  School	
  of	
  Medicine	
  

	
  

	
  

Trainee	
  Name:	
  

	
  

Katelin	
  Carr	
  [mentor,	
  predoctoral	
  Donald	
  J.	
  Cohen	
  Fellowship	
  in	
  	
   	
  

	
  

	
  

	
  

	
  

	
  

	
  

Developmental	
  Social	
  Neuroscience,	
  Yale	
  Child	
  Study	
  Center]	
  

	
  

Training	
  Period:	
   	
  

2004	
  -­‐	
  2006	
  

	
  

Title	
  of	
  Research	
  Project:	
   Eye-­‐tracking	
  studies	
  of	
  social	
  engagement	
  in	
  toddlers	
  with	
  autism	
  

	
  

Other	
  Mentors:	
   	
  

Warren	
  Jones	
  PhD	
  

	
  

Current	
  Position:	
  	
   	
  

PhD	
  candidate,	
  Clinical	
  Neuropsychology,	
  Department	
  of	
  	
   	
  

	
  

	
  

	
  

	
  

	
  

	
  

	
  

Psychology,	
  University	
  of	
  Connecticut	
  

	
  

	
  

Trainee	
  Name:	
  

	
  

Phillip	
  Gorrindo	
  [mentor,	
  predoctoral	
  Simons	
  Fellowship	
  in	
  	
   	
  

	
  

	
  

	
  

	
  

	
  

	
  

Computational	
  Neuroscience,	
  Yale	
  Child	
  Study	
  Center]	
  

	
  

Training	
  Period:	
   	
  

2004	
  -­‐	
  2006	
  

	
  

Title	
  of	
  Research	
  Project:	
   Attention	
  to	
  human	
  biological	
  motion	
  and	
  non-­‐social	
  physical	
  	
   	
  

	
  

	
  

	
  

	
  

	
  

	
  

contingencies	
  in	
  point-­‐light	
  Displays	
  of	
  human	
  action	
  

	
  

Other	
  Mentors:	
   	
  

Warren	
  Jones	
  PhD	
  

	
  

Current	
  Position:	
  	
   	
  

MD	
  PhD	
  candidate,	
  Neuroscience	
  Graduate	
  Program	
  at	
  Vanderbilt	
  	
  

	
  

	
  

	
  

	
  

	
  

	
  

Kennedy	
  Center	
  for	
  Research	
  on	
  Human	
  Development,	
  	
  

	
  

	
  

	
  

	
  

	
  

	
  

Vanderbilt	
  University	
  

	
  

	
  

	
  

Trainee	
  Name:	
  

	
  

Giacomo	
  Vivanti	
  	
  [mentor	
  and	
  supervisor,	
  research	
  internship	
  for	
  	
 	 
  

	
  

	
  

	
  

	
  

	
  

foreign	
  scholars]	
  

Case 2:11-cv-04027-LDD Document 48-36 Filed 07/13/12 Page 40 of 84

Ami	
  Klin,	
  PhD	
  	
  	
  	
  	
  	
  	
  	
  	
  

	
  

	
  

	
  

	
  Page	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  2	
  	
  	3
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
   	
  	
  

	
  

Training	
  Period:	
   	
  

2002	
  -­‐	
  2003	
  

	
  

Title	
  of	
  Research	
  Project:	
   Asperger’s	
  syndrome:	
  clinical	
  and	
  neuropsychological	
  characteristics	
  

	
  

Other	
  Mentors:	
   	
  

Fred	
  Volkmar,	
  MD	
  

	
  

Current	
  Position:	
  	
   	
  

Post-­‐doctoral	
  Associate,	
  Cognitive	
  Science,	
  MIND	
  Institute,	
  UC	
  Davis	
  

	
  

	
  

Trainee	
  Name:	
  

	
  

Warren	
  Jones	
  [senior	
  thesis	
  advisor,	
  Yale	
  College,	
  and	
  PhD	
  advisor,	
  	
  

	
  

	
  

	
  

	
  

	
  

	
  

Interdepartmental	
  Neuroscience	
  Program,	
  Yale	
  School	
  of	
  	
   	
  

	
  

	
  

	
  

	
  

	
  

	
  

Medicine	
  

	
  

Training	
  Period:	
   	
  

1999	
  -­‐	
  2009	
  

	
  

Title	
  of	
  Research	
  Project:	
   Co-­‐creation	
  of	
  our	
  programmatic	
  research	
  in	
  social	
  neuroscience	
  

	
  

	
  

	
  

	
  

	
  

	
  	
   involving	
  multiple	
  projects	
   	
  

	
  

Other	
  Mentors:	
   	
  

Todd	
  Constable,	
  PhD,	
  James	
  Mazer,	
  PhD	
  

	
  

Current	
  Position:	
  	
   	
  

Director	
  of	
  Research,	
  Marcus	
  Autism	
  Center,	
  Children’s	
  Healthcare	
  of	
  	
  

	
  

	
  

	
  

	
  

	
  

	
  

Atlanta,	
  Assistant	
  Professor,	
  Division	
  of	
  Autism	
  and	
  Related	
  	
  

	
  

	
  

	
  

	
  

	
  

	
  

Disorders,	
  Department	
  of	
  Pediatrics,	
  Emory	
  University	
  School	
  of	
  	
  

	
  

	
  

	
  

	
  

	
  

	
  

Medicine	
  

	
  

	
  

Trainee	
  Name:	
  

	
  

Jason	
  Lang,	
  PhD	
  [research	
  advisor,	
  predoctoral	
  study]	
  	
  

	
  

Training	
  Period:	
   	
  

1998	
  -­‐	
  1999	
  

	
  

Title	
  of	
  Research	
  Project:	
   Inter-­‐rater	
  reliability	
  of	
  clinical	
  diagnosis	
  and	
  DSM-­‐IV	
  criteria	
  for	
  	
   	
  

	
  

	
  

	
  

	
  

	
  

	
  

autistic	
  disorders:	
  the	
  DSM-­‐IV	
  autism	
  field	
  trial	
  

	
  

Other	
  Mentors:	
   	
  

Fred	
  Volkmar,	
  MD;	
  Domenic	
  Cicchetti,	
  PhD	
  

	
  

Current	
  Position:	
  	
   	
  

Coordinator,	
  (statewide)	
  Connecticut	
  Trauma	
  Focused	
  Cognitive	
  	
   	
  

	
  

	
  

	
  

	
  

	
  

	
  

Behavioral	
  Therapy	
  Program	
  

	
  	
  

	
  

c.	
  	
   Undergraduate	
  (from	
  year	
  2000	
  only):	
  

	
  

	
  

	
  

I	
  had	
  152	
  Yale	
  undergraduate	
  students	
  under	
  my	
  direct	
  supervision	
  between	
  2000	
  and	
  2010.	
  	
  

	
  

	
  

	
  

Supervision	
  involved	
  both	
  a	
  research	
  project	
  or	
  research	
  review,	
  and	
  a	
  clinical	
  aspect	
  	
  

	
  

	
  

	
  

focused	
  on	
  the	
  students’	
  direct	
  experiences	
  in	
  available	
  clinical	
  placements.	
  	
  

	
  

	
  

d.	
  	
   Web	
  Courses	
  (sample):	
  

	
  

	
  

	
  

“Social	
  Development	
  in	
  Autism”	
  	
  

	
  

	
  

http://sciencestage.com/v/31024/social-­‐development-­‐in-­‐autism-­‐dr-­‐ami-­‐klin.html	
  	
  

	
  

	
  

	
  

“Overview	
  of	
  Autism”	
  

	
  

	
  

http://sciencestage.com/v/31026/overview-­‐of-­‐autism,-­‐dr.-­‐ami-­‐klin.html	
  	
  

	
  

	
  

	
  

“How	
  Autism	
  Creates	
  Itself”	
  

	
  

	
  

http://tedxtalks.ted.com/video/TEDxPeachtree-­‐Ami-­‐Klin-­‐Autism-­‐D;search%3Atedxpeachtree	
  

	
  

	
  

	
  

	
  

	
  

e.	
  	
   External	
  Reading	
  Committees:	
  

Case 2:11-cv-04027-LDD Document 48-36 Filed 07/13/12 Page 41 of 84

Ami	
  Klin,	
  PhD	
  	
  	
  	
  	
  	
  	
  	
  	
  

	
  

	
  

	
  

	
  Page	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  2	
  	
  	4
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
   	
  	
  

	
  

	
  

	
  

Jojanneke	
  A.C.J.	
  Bastiaansen:	
  PhD	
  reading	
  committee,	
  ‘Neural	
  correlates	
  of	
  emotion	
  processing	
  

in	
  autism,	
  schizophrenia,	
  and	
  mental	
  health’.	
  Mentor:	
  Christian	
  Keysers,	
  PhD.	
  The	
  

Netherlands	
  Institute	
  for	
  Neuroscience	
  at	
  the	
  Royal	
  Netherlands	
  Academy	
  of	
  Arts	
  and	
  	
  

Sciences,	
  and	
  University	
  Medical	
  Center	
  Groningen,	
  The	
  Netherlands.	
  July	
  2011.	
  	
  

	
  

26.	
   Invited	
  regional,	
  national	
  and	
  international	
  clinical	
  lectures,	
  workshops	
  and	
  community	
  outreach	
  	
  

	
  

	
  

(Over	
  200	
  Keynote	
  Presentations,	
  Invited	
  Lectures	
  and	
  Daylong	
  Clinical	
  Workshops):	
  

	
  

2012	
   	
  

Center	
  for	
  Autism	
  Research	
  Lecture	
  Series:	
  “	
  DSM-­‐V,	
  Definitions	
  and	
  Persistent	
  Realities”.	
  	
  

	
  

	
  

Children’s	
  Hospital	
  of	
  Philadelphia	
  and	
  University	
  of	
  Pennsylvania.	
  	
  Philadelphia,	
  PA,	
  April	
  12,	
  

	
  

	
  

2012.	
  

2012	
   	
  

Wolfson	
  Children’s	
  Hospital,	
  University	
  of	
  North	
  Florida	
  Autism	
  Symposium:	
  “The	
  Challenges	
  of	
  	
  

	
  

	
  

Social	
  Learning	
  in	
  Adolescents	
  with	
  Autism	
  Spectrum	
  Disorders	
  and	
  Their	
  Early	
  Childhood”.	
  	
  

	
  

	
  

Jacksonville,	
  FL,	
  March	
  14,	
  2012.	
  

2012	
   	
  

Kids	
  Health	
  First	
  Annual	
  Meeting,	
  Keynote	
  Address:	
  “A	
  new	
  system	
  of	
  health	
  care	
  deliver	
  for	
  	
  

	
  

	
  

infants	
  and	
  toddlers	
  with	
  ASD	
  Pediatrician’s	
  Central	
  Role”.	
  Atlanta,	
  GA,	
  February	
  28,	
  2012.	
  

2012	
   	
  

CARD,	
  Albany,	
  2012	
  Annual	
  Distinguished	
  Guest	
  Lecture	
  in	
  Autism:	
  “DSM-­‐V,	
  Definitions,	
  	
  

	
  

	
  

Realities,	
  and	
  Real	
  Science	
  We	
  Need”.	
  Albany,	
  NY,	
  January	
  25,	
  2012.	
  

2011	
   	
  

Simons	
  Foundation	
  Autism	
  Research	
  Initiative,	
  Invitational	
  Workshop	
  on	
  ‘Autism	
  Biomarkers’:	
  

‘The	
  metrics	
  of	
  sociability:	
  quantification	
  of	
  social	
  entrainment	
  in	
  typical	
  and	
  atypical	
  	
  

development”.	
  Simons	
  Center	
  for	
  Geometry	
  and	
  Physics,	
  Stony	
  Brook,	
  NY,	
  July	
  22-­‐24,	
  2011.	
  	
  

2011	
   	
  

Georgia	
  Council	
  on	
  Developmental	
  Disabilities,	
  Invited	
  Address:	
  “Challenges	
  and	
  Opportunities	
  

in	
  Autism	
  Spectrum	
  Disorders:	
  New	
  models	
  of	
  health	
  care	
  delivery”.	
  Atlanta,	
  GA,	
  July	
  22,	
  2011.	
  	
  	
  

2011	
   	
  

Daylong	
  research	
  and	
  clinical	
  workshop,	
  2011	
  Florida	
  State	
  University	
  Training	
  Institute	
  on	
  	
  

	
  

	
  

Autism:	
  “New	
  Research	
  on	
  Social	
  Engagement	
  Deficits	
  in	
  Young	
  Children	
  with	
  Autism:	
  

Implications	
  for	
  Clinical	
  Practice”.	
  Tallahassee,	
  FL,	
  June	
  24,	
  2011.	
  

2011	
   	
  

Community	
  Physician	
  Advisory	
  Council	
  (CPAC)	
  Retreat:	
  “Infants	
  at	
  Risk”.	
  Buford,	
  GA,	
  April	
  13,	
  	
  

	
  

	
  

2011.	
  

2011	
   	
  

Fordham	
  University,	
  Losniños	
  Services,	
  New	
  York	
  City,	
  NY,	
  Keynote	
  Address	
  and	
  Award:	
  

	
  “Annual	
  Award	
  for	
  Clinical	
  Science,	
  Service	
  and	
  Advocacy	
  on	
  Behalf	
  of	
  Individuals	
  with	
  Autism”.	
  	
  

	
  

	
  

Keynote	
  Address:	
  ‘Autism:	
  DSM-­‐V	
  Definitions,	
  Realities	
  and	
  Real	
  Science	
  We	
  Need’.	
  Eighth	
  

	
  Annual	
  Young	
  Child	
  Expo	
  &	
  Conference,	
  April	
  7	
  2011,	
  New	
  York	
  City,	
  NY.	
  	
  

2011	
   	
  

Dekalb	
  Autism	
  Support	
  Group,	
  Marcus	
  Autism	
  Center:	
  “Baby	
  Steps:	
  Diagnosing	
  Autism	
  in	
  	
  

	
  

	
  

Children	
  within	
  the	
  First	
  Year	
  of	
  Life”.	
  Atlanta,	
  GA,	
  April	
  6,	
  2011.	
  

2010	
  

YAI	
  Network	
  Annual	
  Conference,	
  Daylong	
  Workshop:	
  “Contemporary	
  issues	
  in	
  autism	
  spectrum	
  

disorders”.	
  New	
  York	
  City,	
  November	
  10,	
  2010.	
  	
  

2010	
  

Foote	
  School:	
  “Integrating	
  children	
  with	
  autism	
  in	
  the	
  school	
  environment”.	
  New	
  Haven,	
  CT,	
  

October	
  12,	
  2010.	
  	
  

2010	
  

IX	
  International	
  Congress,	
  Autism-­‐Europe:	
  “A	
  discussion	
  forum	
  for	
  adults	
  with	
  autism	
  spectrum	
  

disorders	
  from	
  Slovenia”.	
  Catania,	
  Italy,	
  October	
  9,	
  2010.	
  	
  

2010	
  

Asperger’s	
  Association	
  of	
  New	
  England,	
  Annual	
  Conference,	
  Keynote	
  Address:	
  “DSM-­‐V,	
  

Definitions,	
  Realities,	
  and	
  Real	
  Science	
  We	
  Need”.	
  Marborough,	
  MA,	
  September	
  25,	
  2010.	
  	
  

Case 2:11-cv-04027-LDD Document 48-36 Filed 07/13/12 Page 42 of 84

Ami	
  Klin,	
  PhD	
  	
  	
  	
  	
  	
  	
  	
  	
  

	
  

	
  

	
  

	
  Page	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  2	
  	
  	5
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
   	
  	
  

2010	
   2010	
   2009	
   2009	
   2009	
   2008	
   2008	
   2008	
   2008	
   2008	
   2008:	
   2008:	
   2008:	
   2008:	
   2008:	
   2008:	
  
2008:	
  

2010	
  National	
  Autism	
  Conference,	
  Pennsylvania	
  State	
  University:	
  “Clinical	
  and	
  research	
  issues	
   in	
  infancy	
  and	
  toddlerhood	
  of	
  children	
  with	
  autism	
  spectrum	
  disorders”.	
  State	
  College,	
  PA,	
   August	
  2,	
  2010.	
  	
   Opportunity	
  House	
  (Residential	
  Units	
  for	
  Adults	
  with	
  Autism):	
  “Challenges	
  and	
  opportunities	
  for	
   middle	
  age	
  individuals	
  with	
  autism”,	
  New	
  Haven,	
  CT,	
  May	
  24,	
  2010.	
  	
   District	
  75	
  Schools	
  of	
  New	
  York	
  City	
  Annual	
  Administrators	
  Meeting,	
  Keynote	
  Address:	
  “Social	
   development	
  and	
  social	
  skills	
  in	
  autism	
  spectrum	
  disorders:	
  highlights	
  of	
  current	
  research	
  and	
   implications	
  for	
  educational	
  programming”.	
  New	
  York,	
  NY,	
  September	
  2,	
  2009.	
  	
   Commonwealth	
  of	
  Pennsylvania	
  Department	
  of	
  Education,	
  2009	
  National	
  Autism	
  Conference:	
   Progress	
  Through	
  Partnership,	
  Keynote	
  Address:	
  “Clinical	
  implications	
  of	
  new	
  research	
  on	
   infants	
  and	
  toddlers	
  with	
  autism	
  spectrum	
  disorders”.	
  State	
  College,	
  PA,	
  August	
  3,	
  2009.	
  	
   Eastern	
  Illinois	
  University:	
  “Clinical	
  management	
  of	
  infants	
  and	
  toddlers	
  with	
  autism	
  spectrum	
   Disorders”.	
  Charleston,	
  IL,	
  May	
  13,	
  2009.	
   Shoreline	
  Child	
  Study	
  Group,	
  Guilford	
  Police	
  Building:	
  “Awareness	
  of	
  autism	
  in	
  our	
  community”.	
   Guilford,	
  CT,	
  December,	
  11,	
  2008.	
   Morristown	
  Memorial	
  Hospital,	
  Pervasive	
  Developmental	
  Disorder,	
  The	
  State-­‐of-­‐the-­‐art	
   Conference:	
  “Asperger	
  Syndrome	
  and	
  Pervasive	
  Developmental	
  Disorder-­‐Not	
  Otherwise	
   Specified:	
  Diagnosis	
  and	
  Assessment”.	
  Morristown,	
  NJ,	
  November	
  20,	
  2008.	
   Guilford	
  Community	
  TV:	
  “Public	
  Awareness	
  of	
  Autism”.	
  Program,	
  Guilford,	
  CT,	
  November	
  18,	
   2008.	
   Le	
  Centre	
  de	
  Formacion	
  et	
  de	
  Recherche	
  Abe	
  Bold,	
  Miriam	
  Foundation,	
  Colloque	
  2008:	
  “Some	
   priorities	
  for	
  Educational	
  and	
  Treatment	
  Programs	
  for	
  Higher	
  Functioning	
  Individuals	
  with	
   Autism	
  Spectrum	
  Disorders”.	
  Montreal,	
  Canada,	
  October	
  30-­‐31,	
  2008.	
   The	
  Yale	
  Child	
  Study	
  Center	
  Lecture	
  Series	
  at	
  Greenwich	
  Hospital:	
  “Optimizing	
  Outcomes	
  in	
   Autism	
  Spectrum	
  Disorders”.	
  Greenwich,	
  CT,	
  October	
  28,	
  2010.	
   Inaugural	
  Pennsylvania	
  Autism	
  Training	
  Conference,	
  Pennsylvania	
  Department	
  of	
  Public	
   Welfare,	
  Keynote	
  Address:	
  “Differential	
  Diagnosis	
  in	
  Autism	
  Spectrum	
  Disorders	
  and	
  Treatment	
   of	
  Challenging	
  Behaviors”.	
  Lancaster,	
  PA,	
  May	
  29,	
  2008.	
   Inaugural	
  Pennsylvania	
  Autism	
  Training	
  Conference,	
  Pennsylvania	
  Department	
  of	
  Public	
   Welfare,	
  Keynote	
  Address:	
  “Real-­‐Life	
  Skills	
  and	
  Circumscribed	
  Interests	
  in	
  Autism	
  Spectrum	
   Disorders”.	
  Lancaster,	
  PA,	
  May	
  28,	
  2008.	
   The	
  Southern	
  Connecticut	
  Consortium	
  for	
  Staff	
  Development:	
  “Understanding	
  and	
  treating	
   autism	
  spectrum	
  disorders”.	
  Stratford,	
  CT,	
  May	
  9,	
  2008.	
   Chapel	
  Haven	
  Annual	
  Parent	
  Meeting:	
  “Lessons	
  from	
  research	
  in	
  autism	
  spectrum	
  disorders:	
   focus	
  on	
  transition	
  and	
  adulthood”.	
  New	
  Haven,	
  CT,	
  April	
  25,	
  2008.	
   Yale	
  Child	
  Study	
  Center	
  Conference,	
  The	
  Road	
  to	
  Post	
  Secondary	
  Education:	
  What	
  Parents	
  Need	
   to	
  Know	
  to	
  Prepare	
  Students	
  with	
  Autism	
  Spectrum	
  Disorders:	
  “The	
  role	
  of	
  assessment	
  in	
   planning	
  post-­‐secondary	
  education”.	
  New	
  Haven,	
  CT,	
  April	
  25,	
  2008.	
   UJA-­‐Federation	
  Autism	
  Symposium,	
  From	
  the	
  Lab	
  to	
  the	
  Field:	
  Applying	
  Research	
  on	
  Best	
   Practices	
  in	
  Community-­‐Based	
  Settings,	
  New	
  York	
  City:	
  “Some	
  priorities	
  for	
  educational	
  and	
   treatment	
  programs	
  for	
  individuals	
  with	
  autism	
  spectrum	
  disorders”.	
  New	
  York,	
  NY,	
  April	
  8,	
   2008.	
   Wilton	
  Public	
  Schools:	
  “Social	
  development	
  in	
  autism	
  spectrum	
  disorder;	
  and	
  Priorities	
  for	
   educational	
  and	
  treatment	
  programming	
  in	
  the	
  school	
  setting”.	
  Wilton,	
  CT,	
  March	
  31,	
  2008.	
  

Case 2:11-cv-04027-LDD Document 48-36 Filed 07/13/12 Page 43 of 84

Ami	
  Klin,	
  PhD	
  	
  	
  	
  	
  	
  	
  	
  	
  

	
  

	
  

	
  

	
  Page	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  2	
  	
  	6
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
   	
  	
  

2008:	
   2008:	
  
2008:	
  	
  
2008:	
  	
   2007:	
   2007:	
  
2007:	
   2007:	
   2007:	
  
2007:	
   2007:	
   2007:	
   2007:	
   2007:	
   2007:	
   2006:	
   2006:	
   2006:	
   2006:	
   2006:	
  

The	
  Foundation	
  School:	
  “Translating	
  research	
  into	
  best	
  practices	
  in	
  the	
  classroom”.	
  Orange,	
  CT,	
   February	
  1,	
  2008.	
   15th	
  Annual	
  Centers	
  for	
  Autism	
  and	
  Related	
  Disabilities	
  (CARDs)	
  of	
  Florida,	
  Keynote	
  Address:	
   “Some	
  priorities	
  for	
  educational	
  and	
  treatment	
  programs	
  for	
  higher	
  functioning	
  individuals	
  with	
   Autism	
  Spectrum	
  Disorders”.	
  Orlando,	
  FL,	
  January	
  27,	
  2008.	
   Jewish	
  Family	
  &	
  Children’s	
  Services:	
  “Autism,	
  Asperger’s	
  Syndrome	
  and	
  related	
  conditions:	
   Clinical	
  features,	
  assessment,	
  and	
  treatment	
  and	
  interventions”.	
  Princeton,	
  NJ,	
  January	
  24,	
   2008.	
   Jewish	
  Family	
  &	
  Children’s	
  Services:	
  “The	
  two	
  endpoints	
  of	
  Autism	
  Spectrum	
  Disorders:	
  Exciting	
   new	
  developments	
  and	
  new	
  challenges”.	
  Princeton,	
  NJ,	
  January	
  23,	
  2008.	
  	
   ARC	
  Greenwich	
  Autism	
  Program	
  and	
  Autism	
  Speaks:	
  “Autism	
  Every	
  Day:	
  The	
  Early	
  Years	
  and	
   Beyond”.	
  Greenwich,	
  CT,	
  November	
  29,	
  2007.	
   Ohel	
  Bais	
  Ezra	
  (Children’s	
  Home	
  and	
  Family	
  Services),	
  Baruch	
  College:	
  “Implications	
  of	
  current	
   research	
  for	
  the	
  assessment	
  and	
  treatment	
  of	
  individuals	
  with	
  autism	
  spectrum	
  disorders”.	
   New	
  York	
  City,	
  NY,	
  November	
  15,	
  2007.	
   Yale	
  Child	
  Study	
  Center	
  Conference	
  on	
  Autism	
  in	
  Infants	
  and	
  Young	
  Children:	
  “Research	
  in	
   infants	
  at	
  risk	
  for	
  autism	
  spectrum	
  disorders”.	
  New	
  Haven,	
  CT,	
  November	
  9,	
  2007.	
   Sheppard	
  Pratt	
  Health	
  System:	
  “Asperger	
  Syndrome	
  through	
  the	
  lifespan:	
  clinical	
  implications	
   of	
  research”.	
  Baltimore,	
  MD,	
  October	
  5,	
  2007.	
   Autism	
  Speaks	
  and	
  Clínica	
  Mexicana	
  de	
  Autismo.	
  Universidad	
  Iberoamericana:	
  “Autism	
   Spectrum	
  Disorders:	
  Clinical	
  features,	
  assessment,	
  and	
  treatment	
  interventions”.	
  Mexico	
  City,	
   July	
  4,	
  2007.	
   New	
  England	
  Educational	
  Institute:	
  “Autism	
  and	
  Asperger	
  syndrome:	
  Clinical	
  features,	
   assessment,	
  and	
  treatment/interventions”.	
  Albany,	
  NY,	
  May	
  22,	
  2007.	
   Bluegrass	
  Regional	
  Mental	
  Health	
  –	
  Mental	
  Retardation	
  Board:	
  “Autism	
  and	
  Asperger	
   syndrome:	
  Advances	
  in	
  understanding	
  and	
  interventions”.	
  Lexington,	
  KY,	
  April	
  19,	
  2007.	
   New	
  England	
  Educational	
  Institute:	
  “Autism	
  and	
  Asperger	
  syndrome:	
  Clinical	
  features,	
   assessment,	
  and	
  treatment/interventions”.	
  Jacksonville,	
  FL,	
  February	
  8,	
  2007.	
   New	
  England	
  Educational	
  Institute:	
  “Autism	
  and	
  Asperger	
  syndrome:	
  Clinical	
  features,	
   assessment,	
  and	
  treatment/interventions”.	
  Orlando,	
  FL,	
  February	
  7,	
  2007.	
   New	
  England	
  Educational	
  Institute:	
  “Autism	
  and	
  Asperger	
  syndrome:	
  Clinical	
  features,	
   assessment,	
  and	
  treatment/interventions”.	
  Los	
  Angeles,	
  CA,	
  January	
  26,	
  2007.	
   New	
  England	
  Educational	
  Institute:	
  “Autism	
  and	
  Asperger	
  syndrome:	
  Clinical	
  features,	
   assessment,	
  and	
  treatment/interventions”.	
  San	
  Francisco,	
  CA,	
  January	
  25,	
  2007.	
   New	
  England	
  Educational	
  Institute:	
  “Autism	
  and	
  Asperger	
  syndrome:	
  Clinical	
  features,	
   assessment,	
  and	
  treatment/interventions”.	
  New	
  Haven,	
  CT,	
  December	
  15,	
  2006.	
   New	
  England	
  Educational	
  Institute:	
  “Autism	
  and	
  Asperger	
  syndrome:	
  Clinical	
  features,	
   assessment,	
  and	
  treatment/interventions”.	
  Suffern,	
  NY,	
  December	
  13,	
  2006.	
   New	
  England	
  Educational	
  Institute:	
  “Autism	
  and	
  Asperger	
  syndrome:	
  Clinical	
  features,	
   assessment,	
  and	
  treatment/interventions”.	
  Edison,	
  NJ,	
  December	
  13,	
  2006.	
   New	
  England	
  Educational	
  Institute:	
  “Autism	
  and	
  Asperger	
  syndrome:	
  Clinical	
  features,	
   assessment,	
  and	
  treatment/interventions”.	
  Louisville,	
  KY,	
  December	
  1,	
  2006.	
   New	
  England	
  Educational	
  Institute:	
  “Autism	
  and	
  Asperger	
  syndrome:	
  Clinical	
  features,	
   assessment,	
  and	
  treatment/interventions”.	
  Saint	
  Louis,	
  MO,	
  November	
  30,	
  2006.	
  

Case 2:11-cv-04027-LDD Document 48-36 Filed 07/13/12 Page 44 of 84

Ami	
  Klin,	
  PhD	
  	
  	
  	
  	
  	
  	
  	
  	
  

	
  

	
  

	
  

	
  Page	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
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  	7
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
   	
  	
  

2006:	
   2006:	
   2006:	
  
2006:	
   2006:	
   2006:	
   2006:	
   2006:	
   2006:	
   2006:	
   2006:	
   2006:	
   2006:	
  
2006:	
   2006:	
   2006:	
   2006:	
   2005:	
   2005:	
   2005:	
   2005:	
  

New	
  England	
  Educational	
  Institute:	
  “Autism	
  and	
  Asperger	
  syndrome:	
  Clinical	
  features,	
   assessment,	
  and	
  treatment/interventions”.	
  Memphis,	
  TN,	
  November	
  29,	
  2006.	
   New	
  Jersey	
  Psychological	
  Association:	
  “Autism	
  and	
  related	
  conditions:	
  clinical	
  features,	
   assessment,	
  treatment	
  and	
  intervention,	
  and	
  research	
  highlights”.	
  Iselin,	
  NJ,	
  October	
  28,	
  2006.	
   Columbus	
  Children’s	
  Autism	
  Conference.	
  Children’s	
  Hospital,	
  Keynote	
  Address:	
  “Understanding	
   and	
  educating	
  individuals	
  with	
  autism	
  and	
  Asperger	
  syndrome”.	
  Columbus,	
  OH,	
  October	
  26,	
   2006.	
   Columbus	
  Children’s	
  Hospital:	
  “Asperger	
  syndrome:	
  A	
  transition	
  plan	
  into	
  adulthood”.	
   Columbus,	
  OH,	
  October	
  25,	
  2006.	
   National	
  Security	
  Agency:	
  “Developmental	
  disabilities:	
  transition	
  into	
  adulthood”.	
  Hanover,	
  MD,	
   July	
  28,	
  2006.	
   New	
  England	
  Educational	
  Institute:	
  “Autism	
  and	
  Asperger	
  syndrome:	
  Clinical	
  features,	
   assessment,	
  and	
  treatment/interventions”.	
  Burlington,	
  VT,	
  May	
  24,	
  2006.	
   New	
  England	
  Educational	
  Institute:	
  “Autism	
  and	
  Asperger	
  syndrome:	
  Clinical	
  features,	
   assessment,	
  and	
  treatment/interventions”.	
  San	
  Antonio,	
  TX,	
  May	
  19,	
  2006.	
   New	
  England	
  Educational	
  Institute:	
  “Autism	
  and	
  Asperger	
  syndrome:	
  Clinical	
  features,	
   assessment,	
  and	
  treatment/interventions”.	
  Tulsa,	
  OK,	
  May	
  18,	
  2006.	
   New	
  England	
  Educational	
  Institute:	
  “Autism	
  and	
  Asperger	
  syndrome:	
  Clinical	
  features,	
   assessment,	
  and	
  treatment/interventions”.	
  Memphis,	
  TN,	
  May	
  17,	
  2006.	
   New	
  England	
  Educational	
  Institute:	
  “Autism	
  and	
  Asperger	
  syndrome:	
  Clinical	
  features,	
   assessment,	
  and	
  treatment/interventions”.	
  Richmond,	
  VA,	
  May	
  12,	
  2006.	
   New	
  England	
  Educational	
  Institute:	
  “Autism	
  and	
  Asperger	
  syndrome:	
  Clinical	
  features,	
   assessment,	
  and	
  treatment/interventions”.	
  Minneapolis,	
  MN,	
  April	
  27,	
  2006.	
   New	
  England	
  Educational	
  Institute:	
  “Autism	
  and	
  Asperger	
  syndrome:	
  Clinical	
  features,	
   assessment,	
  and	
  treatment/interventions”.	
  Chicago,	
  IL,	
  April	
  26,	
  2006.	
   Connecticut	
  General	
  Assembly,	
  State	
  Capitol,	
  Legislative	
  Informational	
  Hearing,	
  Public	
  Health	
   Committee:	
  “The	
  needs	
  of	
  adults	
  with	
  autism	
  spectrum	
  disorders	
  without	
  mental	
  retardation”.	
   Hartford,	
  CT,	
  March	
  6,	
  2006.	
   New	
  England	
  Educational	
  Institute:	
  “Autism	
  and	
  Asperger	
  syndrome:	
  Clinical	
  features,	
   assessment,	
  and	
  treatment/interventions”.	
  New	
  York,	
  NY,	
  February	
  10,	
  2006.	
  February	
  3,	
  2006.	
   New	
  England	
  Educational	
  Institute:	
  “Autism	
  and	
  Asperger	
  syndrome:	
  Clinical	
  features,	
   assessment,	
  and	
  treatment/interventions”.	
  Baltimore,	
  MD,	
  February	
  3,	
  2006.	
   New	
  England	
  Educational	
  Institute:	
  “Autism	
  and	
  Asperger	
  syndrome:	
  Clinical	
  features,	
   assessment,	
  and	
  treatment/interventions”.	
  St.	
  Louis,	
  MO,	
  January	
  26,	
  2006.	
   New	
  England	
  Educational	
  Institute:	
  “Autism	
  and	
  Asperger	
  syndrome:	
  Clinical	
  features,	
   assessment,	
  and	
  treatment/interventions”.	
  Kansas	
  City,	
  Mo,	
  January	
  25,	
  2006.	
   New	
  England	
  Educational	
  Institute:	
  “Autism	
  and	
  Asperger	
  syndrome:	
  Clinical	
  features,	
   assessment,	
  and	
  treatment/interventions”	
  Phoenix,	
  AZ,	
  December	
  9,	
  2005.	
   New	
  England	
  Educational	
  Institute:	
  “Autism	
  and	
  Asperger	
  syndrome:	
  Clinical	
  features,	
   assessment,	
  and	
  treatment/interventions”.	
  Los	
  Angeles,	
  CA,	
  December	
  8,	
  2005.	
   New	
  England	
  Educational	
  Institute:	
  “Autism	
  and	
  Asperger	
  syndrome:	
  Clinical	
  features,	
   assessment,	
  and	
  treatment/interventions”.	
  San	
  Diego,	
  CA,	
  December	
  7,	
  2005.	
   New	
  England	
  Educational	
  Institute:	
  “Autism	
  and	
  Asperger	
  syndrome:	
  Clinical	
  features,	
   assessment,	
  and	
  treatment/interventions”.	
  Buffalo,	
  NY,	
  December	
  1,	
  2005.	
  

Case 2:11-cv-04027-LDD Document 48-36 Filed 07/13/12 Page 45 of 84

Ami	
  Klin,	
  PhD	
  	
  	
  	
  	
  	
  	
  	
  	
  

	
  

	
  

	
  

	
  Page	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  2	
  	
  	8
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
   	
  	
  

2005:	
   2005:	
   2005:	
   2005:	
   2005:	
   2005:	
   2005:	
   2005:	
  
2005:	
   2005:	
   2005:	
   2005:	
  	
  
2005:	
   	
  
2005:	
   	
  
2005:	
   2005:	
   2005:	
  

Autism	
  Society	
  of	
  Delaware:	
  “What	
  is	
  Asperger	
  Syndrome?”.	
  Dover,	
  DE,	
  November	
  17,	
  2005.	
   Delaware	
  Autism	
  Program,	
  Autism	
  Society	
  of	
  Delaware,	
  and	
  Center	
  for	
  Disabilities	
  Studies	
  of	
   University	
  of	
  Delaware:	
  “Asperger	
  syndrome:	
  issues	
  in	
  diagnosis	
  and	
  intervention,	
  a	
  daylong	
   workshop”.	
  Dover,	
  DE,	
  November	
  17,	
  2005.	
   New	
  England	
  Educational	
  Institute:	
  “Autism	
  and	
  Asperger	
  syndrome:	
  Clinical	
  features,	
   assessment,	
  and	
  treatment/interventions”.	
  Portland,	
  ME,	
  November	
  16,	
  2005.	
   New	
  England	
  Educational	
  Institute:	
  “Autism	
  and	
  Asperger	
  syndrome:	
  Clinical	
  features,	
   assessment,	
  and	
  treatment/interventions”.	
  Danbury,	
  CT,	
  November	
  4,	
  2005.	
   New	
  England	
  Educational	
  Institute:	
  “Autism	
  and	
  Asperger	
  syndrome:	
  Clinical	
  features,	
   assessment,	
  and	
  treatment/interventions”.	
  Chicago,	
  IL,	
  October	
  26,	
  2005.	
   New	
  England	
  Educational	
  Institute:	
  “Autism	
  and	
  Asperger	
  syndrome:	
  Clinical	
  features,	
   assessment,	
  and	
  treatment/interventions”.	
  Detroit,	
  MI,	
  October	
  25,	
  2005.	
   Benhaven	
  School	
  and	
  Residences:	
  “Clinical	
  implications	
  of	
  current	
  social	
  cognitive	
  research	
  on	
   autism	
  spectrum	
  disorders”.	
  New	
  Haven,	
  CT,	
  October	
  19,	
  2005.	
   Annual	
  National	
  Alliance	
  for	
  Autism	
  Research	
  Keynote	
  Address	
  –	
  Fifteenth	
  Annual	
  Educational	
   Profile	
  of	
  School	
  Age	
  Children	
  with	
  High	
  Functioning	
  Autism,	
  Asperger’s	
  Syndrome	
  and	
  other	
   Pervasive	
  Developmental	
  Disorders.	
  Eastern	
  Suffolk	
  BOCES:	
  “What’s	
  hot	
  and	
  what’s	
  not	
  in	
  the	
   science	
  of	
  autism”.	
  Holbrook,	
  NY,	
  October	
  24,	
  2005.	
   Montreal	
  Children’s	
  Hospital,	
  McGill	
  University:	
  “Asperger	
  syndrome:	
  clinical	
  features	
  and	
   clinical	
  issues”.	
  Montreal,	
  Quebec,	
  Canada,	
  August	
  26,	
  2005.	
   2005	
  National	
  Autism	
  Conference,	
  Pennsylvania	
  State	
  University:	
  “Asperger	
  syndrome:	
  Clinical	
   features,	
  assessment,	
  and	
  treatment/intervention”.	
  State	
  College,	
  PA,	
  August	
  3,	
  2005.	
   Autismo,	
  Centro	
  Conviver:	
  “Importância	
  do	
  Diagnóstico	
  Precoce	
  de	
  Crianças	
  com	
  Autismo”	
   [“The	
  importance	
  of	
  early	
  diagnosis	
  in	
  children	
  with	
  autism”].	
  Curitiba,	
  Brazil,	
  June	
  30,	
  2005.	
   Simpósio	
  Internacional	
  Diagnóstico	
  e	
  Tratamento	
  do	
  Autismo:	
  Um	
  desafio	
  para	
  o	
  Brazil,	
  Casa	
  da	
   Esperança:	
  “Disfunção	
  do	
  olhar	
  do	
  portador	
  do	
  autismo”	
  [“Seeing	
  in	
  individuals	
  with	
  autism”]	
   and	
  “Teoria	
  da	
  Mente”	
  [“Theory	
  of	
  Mind”]	
  [workshops	
  on	
  implications	
  of	
  social	
  cognitive	
   research	
  to	
  daily	
  work	
  with	
  individuals	
  with	
  autism].	
  Fortaleza,	
  Brazil,	
  June	
  24,	
  2005.	
   Simpósio	
  Internacional,	
  Diagnóstico	
  Precoce	
  de	
  Autismo:	
  Um	
  desafio	
  para	
  o	
  Brasil.	
  Simpósio	
   Internacional	
  Diagnóstico	
  Precoce	
  de	
  Autismo:	
  Desafio	
  para	
  Educação	
  e	
  Saúde.	
  Faculdade	
  de	
   Educação	
  da	
  Pontifícia	
  Universidade	
  Católica:	
  “Importância	
  do	
  Diagnóstico	
  Precoce	
  de	
  Crianças	
   com	
  Autismo”	
  [“The	
  importance	
  of	
  early	
  diagnosis	
  in	
  children	
  with	
  autism”].	
  Porto	
  Alegre,	
   Brazil,	
  June	
  23,	
  2005.	
   Filogênese	
  e	
  Ontogênese	
  do	
  Aprender:	
  uma	
  reflexão.	
  I	
  Simpósio	
  sobre	
  Desenvolvimento	
   Humano	
  Da	
  Universidade	
  Presbiteriana	
  MacKenzie:	
  “Autismo:	
  o	
  que	
  a	
  pesquisa	
  nos	
  informa	
   sobre	
  a	
  natureza	
  das	
  alterações	
  do	
  desenvolvimento	
  social”	
  [“Autism:	
  what	
  research	
  informs	
  us	
   about	
  disruptions	
  in	
  social	
  development”].	
  São	
  Paulo,	
  Brazil,	
  June	
  22,	
  2005.	
   New	
  England	
  Educational	
  Institute:	
  “Autism	
  and	
  Asperger	
  syndrome:	
  Clinical	
  features,	
   assessment,	
  and	
  treatment/interventions”.	
  Austin,	
  TX,	
  May	
  25,	
  2005.	
   New	
  England	
  Educational	
  Institute:	
  “Autism	
  and	
  Asperger	
  syndrome:	
  Clinical	
  features,	
   assessment,	
  and	
  treatment/interventions”.	
  Dallas,	
  TX	
  May	
  24,	
  2005.	
   The	
  4th	
  Annual	
  Conference	
  on	
  Developmental	
  Disabilities.	
  Center	
  for	
  the	
  Disabled:	
  “Asperger’s	
   syndrome”.	
  Albany,	
  NY,	
  May	
  13,	
  2005.	
  

Case 2:11-cv-04027-LDD Document 48-36 Filed 07/13/12 Page 46 of 84

Ami	
  Klin,	
  PhD	
  	
  	
  	
  	
  	
  	
  	
  	
  

	
  

	
  

	
  

	
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2005:	
   2005:	
   2005:	
   2005:	
   2005:	
   2005:	
   2005:	
  	
  
2004:	
   2004:	
   2004:	
   2004:	
   2004:	
   2004:	
   2004:	
   2004:	
   2004:	
  
2004:	
   2004:	
   2004:	
   2004:	
  

New	
  England	
  Educational	
  Institute:	
  “Autism	
  and	
  Asperger	
  syndrome:	
  Clinical	
  features,	
   assessment,	
  and	
  treatment/interventions”,	
  Providence,	
  RI,	
  May	
  5,	
  2005.	
   New	
  England	
  Educational	
  Institute:	
  “Autism	
  and	
  Asperger	
  syndrome:	
  Clinical	
  features,	
   assessment,	
  and	
  treatment/interventions”.	
  Springfield,	
  MA,	
  May	
  4,	
  2005.	
   New	
  England	
  Educational	
  Institute:	
  “Autism	
  and	
  Asperger	
  syndrome:	
  Clinical	
  features,	
   assessment,	
  and	
  treatment/interventions”.	
  Marlborough,	
  MA,	
  May	
  3,	
  2005.	
   New	
  England	
  Educational	
  Institute:	
  “Autism	
  and	
  Asperger	
  syndrome:	
  Clinical	
  features,	
   assessment,	
  and	
  treatment/interventions”.	
  Atlanta,	
  GA,	
  April	
  8,	
  2005.	
   New	
  England	
  Educational	
  Institute:	
  “Autism	
  and	
  Asperger	
  syndrome:	
  Clinical	
  features,	
   assessment,	
  and	
  treatment/interventions”.	
  New	
  Haven,	
  CT,	
  March	
  30,	
  2005.	
   New	
  England	
  Educational	
  Institute:	
  “Autism	
  and	
  Asperger	
  syndrome:	
  Clinical	
  features,	
   assessment,	
  and	
  treatment/interventions”.	
  Worcester,	
  MA,	
  March	
  29,	
  2005.	
   Connecticut	
  General	
  Assembly	
  Legislative	
  Informational	
  Hearing,	
  Committee	
  on	
  Higher	
   Education	
  and	
  Employment	
  Advancement:	
  “The	
  needs	
  of	
  adults	
  with	
  autism	
  spectrum	
   disorders	
  without	
  mental	
  retardation”.	
  Hartford,	
  CT,	
  February	
  10,	
  2005.	
   New	
  England	
  Educational	
  Institute:	
  “Autism	
  and	
  Asperger	
  syndrome:	
  Clinical	
  features,	
   assessment,	
  and	
  treatment/interventions”.	
  Portland,	
  ME,	
  December	
  9,	
  2004.	
   New	
  England	
  Educational	
  Institute:	
  “Autism	
  and	
  Asperger	
  syndrome:	
  Clinical	
  features,	
   assessment,	
  and	
  treatment/interventions”.	
  Manchester,	
  NH,	
  December	
  8,	
  2004	
   New	
  England	
  Educational	
  Institute:	
  “Autism	
  and	
  Asperger	
  syndrome:	
  Clinical	
  features,	
   assessment,	
  and	
  treatment/interventions”.	
  Boston,	
  MA,	
  December	
  3,	
  2004.	
   New	
  England	
  Educational	
  Institute:	
  “Autism	
  and	
  Asperger	
  syndrome:	
  Clinical	
  features,	
   assessment,	
  and	
  treatment/interventions”.	
  Chicago,	
  IL,	
  November	
  17,	
  2004.	
   Autism	
  Spectrum	
  Resource	
  Center:	
  “Understanding	
  circumscribed	
  interests	
  in	
  autism	
  spectrum	
   disorders:	
  Implications	
  for	
  educational	
  interventions”.	
  New	
  Haven,	
  CT,	
  November	
  4,	
  2004.	
   New	
  England	
  Educational	
  Institute:	
  “Autism	
  and	
  Asperger	
  syndrome:	
  Clinical	
  features,	
   assessment,	
  and	
  treatment/interventions”.	
  Pittsburgh,	
  PA,	
  May	
  21,	
  2004.	
   New	
  England	
  Educational	
  Institute:	
  “Autism	
  and	
  Asperger	
  syndrome:	
  Clinical	
  features,	
   assessment,	
  and	
  treatment/interventions”.	
  Lancaster,	
  PA,	
  May	
  20,	
  2004.	
   New	
  England	
  Educational	
  Institute:	
  “Autism	
  and	
  Asperger	
  syndrome:	
  Clinical	
  features,	
   assessment,	
  and	
  treatment/interventions”.	
  Philadelphia,	
  PA,	
  May	
  19,	
  2004.	
   	
   One-­‐day	
  Seminar	
  for	
  Mental	
  Health	
  Professionals,	
  Teachers,	
  Parents,	
  and	
  Children’s	
  Service	
   Providers	
  provided	
  by	
  the	
  Developmental	
  Disabilities	
  Section,	
  Yale	
  Child	
  Study	
  Center	
  (Course	
   directors:	
  Fred	
  Volkmar	
  and	
  Ami	
  Klin):	
  “Autism	
  Spectrum	
  Disorders:	
  an	
  Update	
  on	
   Interventions”.	
  Westbrook,	
  CT,	
  May	
  5,	
  2004.	
   New	
  England	
  Educational	
  Institute:	
  “Autism	
  and	
  Asperger	
  syndrome:	
  Clinical	
  features,	
   assessment,	
  and	
  treatment/interventions”.	
  Cincinnati,	
  OH,	
  April	
  22,	
  2004.	
   New	
  England	
  Educational	
  Institute:	
  “Autism	
  and	
  Asperger	
  syndrome:	
  Clinical	
  features,	
   assessment,	
  and	
  treatment/interventions”.	
  Columbus,	
  OH,	
  April	
  21,	
  2004.	
   New	
  England	
  Educational	
  Institute:	
  “Autism	
  and	
  Asperger	
  syndrome:	
  Clinical	
  features,	
   assessment,	
  and	
  treatment/interventions”.	
  Greenbay,	
  WI,	
  April	
  2,	
  2004.	
   New	
  England	
  Educational	
  Institute:	
  “Autism	
  and	
  Asperger	
  syndrome:	
  Clinical	
  features,	
   assessment,	
  and	
  treatment/interventions”.	
  Minneapolis,	
  MN,	
  April	
  1,	
  2004.	
  

Case 2:11-cv-04027-LDD Document 48-36 Filed 07/13/12 Page 47 of 84

Ami	
  Klin,	
  PhD	
  	
  	
  	
  	
  	
  	
  	
  	
  

	
  

	
  

	
  

	
  Page	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
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2004:	
   2004:	
   2004:	
   2004:	
   2004:	
   2004:	
   2003:	
   2003:	
   2003:	
   2003:	
   2003:	
  
2003:	
   2003:	
   2003:	
   2003:	
   2003:	
   2003:	
   2003:	
   2003:	
  
2003:	
  

	
   Jewish	
  Social	
  Service	
  Agency	
  of	
  Metropolitan	
  Washington:	
  “Understanding	
  and	
  Treating	
   Asperger	
  Syndrome	
  and	
  other	
  Severe	
  Social	
  Disabilities”.	
  Chevy	
  Chase,	
  MD.	
  March	
  8,	
  2004.	
   New	
  England	
  Educational	
  Institute:	
  “Autism	
  and	
  Asperger	
  syndrome:	
  Clinical	
  features,	
   assessment,	
  and	
  treatment/interventions”.	
  Atlanta,	
  GA,	
  February	
  26,	
  2004.	
   New	
  England	
  Educational	
  Institute:	
  “Autism	
  and	
  Asperger	
  syndrome:	
  Clinical	
  features,	
   assessment,	
  and	
  treatment/interventions”.	
  Tallahassee,	
  FL,	
  February	
  25,	
  2004.	
   New	
  England	
  Educational	
  Institute:	
  “Autism	
  and	
  Asperger	
  syndrome:	
  Clinical	
  features,	
   assessment,	
  and	
  treatment/interventions”.	
  Miami,	
  FL,	
  February	
  24,	
  2004.	
   New	
  England	
  Educational	
  Institute:	
  “Autism	
  and	
  Asperger	
  syndrome:	
  Clinical	
  features,	
   assessment,	
  and	
  treatment/interventions”.	
  Dallas,	
  TX,	
  January	
  30,	
  2004.	
   New	
  England	
  Educational	
  Institute:	
  “Autism	
  and	
  Asperger	
  syndrome:	
  Clinical	
  features,	
   assessment,	
  and	
  treatment/interventions”.	
  Austin,	
  TX,	
  January	
  29,	
  2004.	
   New	
  England	
  Educational	
  Institute:	
  “Autism	
  and	
  Asperger	
  syndrome:	
  Clinical	
  features,	
   assessment,	
  and	
  treatment/interventions”.	
  Philadelphia,	
  PA,	
  December	
  5,	
  2003.	
   New	
  England	
  Educational	
  Institute:	
  “Autism	
  and	
  Asperger	
  syndrome:	
  Clinical	
  features,	
   assessment,	
  and	
  treatment/interventions”.	
  Lancaster,	
  PA,	
  December	
  4,	
  2003.	
   New	
  England	
  Educational	
  Institute:	
  “Autism	
  and	
  Asperger	
  syndrome:	
  Clinical	
  features,	
   assessment,	
  and	
  treatment/interventions”.	
  Pittsburgh,	
  PA,	
  December	
  3,	
  2003.	
  
	
   Seventh	
  International	
  Autism	
  Europe	
  Congress:	
  “Addressing	
  parents’	
  questions”.	
  Lisbon,	
   Portugal,	
  November	
  15,	
  2003.	
  
	
   APPDA	
  (Portuguese	
  Association	
  for	
  Individuals	
  with	
  Autism	
  Spectrum	
  Disorders):	
  “Autism	
  and	
   associated	
  disorders:	
  clinical	
  assessment,	
  treatment	
  and	
  interventions”.	
  Lisbon,	
  Portugal,	
   November	
  13,	
  2003.	
   New	
  England	
  Educational	
  Institute:	
  “Autism	
  and	
  Asperger	
  syndrome:	
  Clinical	
  features,	
   assessment,	
  and	
  treatment/interventions”.	
  Chicago,	
  IL,	
  November	
  21,	
  2003.	
   New	
  England	
  Educational	
  Institute:	
  “Autism	
  and	
  Asperger	
  syndrome:	
  Clinical	
  features,	
   assessment,	
  and	
  treatment/interventions”.	
  Madison,	
  WI,	
  November	
  20,	
  2003.	
   New	
  England	
  Educational	
  Institute:	
  “Autism	
  and	
  Asperger	
  syndrome:	
  Clinical	
  features,	
   assessment,	
  and	
  treatment/interventions”.	
  Trenton,	
  NJ,	
  November	
  7,	
  2003.	
   New	
  England	
  Educational	
  Institute:	
  “Autism	
  and	
  Asperger	
  syndrome:	
  Clinical	
  features,	
   assessment,	
  and	
  treatment/interventions”.	
  Pleasantville,	
  NY,	
  November	
  6,	
  2003.	
   New	
  England	
  Educational	
  Institute:	
  “Autism	
  and	
  Asperger	
  syndrome:	
  Clinical	
  features,	
   assessment,	
  and	
  treatment/interventions”,	
  Minneapolis,	
  MN,	
  October	
  2,	
  2003.	
   New	
  England	
  Educational	
  Institute:	
  “Autism	
  and	
  Asperger	
  syndrome:	
  Clinical	
  features,	
   assessment,	
  and	
  treatment/interventions”.	
  Sioux	
  Falls,	
  SD,	
  September	
  25,	
  2003.	
   New	
  England	
  Educational	
  Institute.	
  Bismarck,	
  North	
  Dakota:	
  “Autism	
  and	
  Asperger	
  syndrome:	
   Clinical	
  features,	
  assessment,	
  and	
  treatment/interventions”	
  September	
  24,	
  2003.	
  
	
   The	
  Autism	
  Spectrum	
  Resource	
  Center	
  of	
  Greater	
  New	
  Haven:	
  “Preparing	
  advocates	
  to	
  help	
   parents	
  of	
  children	
  with	
  autism	
  to	
  secure	
  appropriate	
  programs	
  of	
  intervention:	
  the	
  Individual	
   Education	
  Plan	
  process”.	
  New	
  Haven,	
  CT,	
  October	
  23,	
  2003.	
  
	
   American	
  Academy	
  of	
  Child	
  and	
  Adolescent	
  Psychiatry	
  50th	
  Anniversary	
  Meeting:	
  “Institute	
  on	
   Autism,	
  Asperger	
  syndrome,	
  and	
  related	
  disorders”.	
  Miami,	
  FL,	
  October	
  17,	
  2003.	
  

Case 2:11-cv-04027-LDD Document 48-36 Filed 07/13/12 Page 48 of 84

Ami	
  Klin,	
  PhD	
  	
  	
  	
  	
  	
  	
  	
  	
  

	
  

	
  

	
  

	
  Page	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  3	
  	
  	1
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
   	
  	
  

2003:	
   2003:	
   2003:	
   2002:	
   2002:	
   2002:	
   2002:	
   2002:	
   2002:	
   2002:	
   2002:	
   2002:	
   2002:	
   2002:	
  
2002:	
  
2002:	
  

	
   Education	
  Connection,	
  Connecticut	
  Department	
  of	
  Education:	
  “Autism	
  and	
  related	
  conditions:	
   workshop	
  on	
  clinical	
  and	
  management	
  issues	
  for	
  directors	
  of	
  special	
  services”.	
  Lakeville,	
  CT,	
   May	
  9,	
  2003.	
  
	
   Autism	
  Society	
  of	
  Minnesota	
  Annual	
  Conference:	
  “Asperger	
  syndrome:	
  clinical	
  features,	
   assessment,	
  interventions,	
  and	
  highlights	
  of	
  clinical	
  research”.	
  Minneapolis,	
  MN,	
  April	
  24,	
  2003.	
  
	
   The	
  Pervasive	
  Developmental	
  Disorders	
  /	
  International	
  Disorders	
  Association	
  of	
  Houston.	
  Texas	
   Medical	
  Center:	
  “Autism	
  and	
  related	
  conditions:	
  current	
  research	
  and	
  choosing	
  effective	
   treatments”.	
  Houston,	
  TX,	
  January	
  25,	
  2003.	
  
	
   The	
  Asperger’s	
  Association	
  of	
  New	
  England	
  8th	
  Annual	
  Conference:	
  “Behavioral	
  and	
   neuroimaging	
  studies	
  of	
  social	
  cognition	
  in	
  autism	
  and	
  related	
  conditions”.	
  Waltham,	
  MA,	
   October	
  26,	
  2002.	
  
	
   The	
  Geneva	
  Centre	
  International	
  Symposium	
  on	
  Autism:	
  A	
  Global	
  Perspective:	
  “Treatment	
  and	
   educational	
  interventions	
  for	
  individuals	
  with	
  severe	
  social	
  disabilities”.	
  Toronto,	
  Ontario,	
   October	
  25,	
  2002.	
  
	
   The	
  Gray	
  Center	
  for	
  Social	
  Learning	
  and	
  Understanding:	
  “The	
  social	
  mind	
  and	
  the	
  social	
  brain:	
   research	
  and	
  clinical	
  implications”.	
  Grand	
  Rapids,	
  MI,	
  October	
  16,	
  2002.	
  
	
   Nefesh	
  International:	
  “Asperger	
  syndrome:	
  Research	
  and	
  clinical	
  practice”.	
  New	
  York	
  City,	
  NY,	
   October	
  6,	
  2002.	
  
	
   The	
  MAAP	
  Annual	
  Conference:	
  “The	
  social	
  mind	
  and	
  the	
  social	
  brain:	
  lessons	
  from	
  autism”.	
   Kansas	
  City,	
  MO,	
  October	
  4,	
  2002.	
  
	
   Grand	
  Rounds,	
  Rockland	
  Children’s	
  Psychiatric	
  Center:	
  “Asperger	
  syndrome”.	
  Orangeburg,	
  NY,	
   September	
  10,	
  2002.	
  
	
   The	
  Sixth	
  Annual	
  S.	
  Gail	
  Mayfield	
  Training	
  Institute,	
  Virginia	
  Autism	
  Resource	
  Center	
  and	
   Grafton,	
  Shenandoah	
  University:	
  “Asperger	
  syndrome”.	
  Winchester,	
  VA,	
  July	
  31	
  and	
  August	
  1,	
   2002.	
  
	
   Northwest	
  Mental	
  Health	
  Institute:	
  “Behavioral	
  and	
  neurobiological	
  aspects	
  of	
  autism	
  and	
   related	
  conditions”.	
  Portland,	
  OR,	
  June	
  28th,	
  2002.	
  
	
   Institute	
  on	
  Autism	
  at	
  Florida	
  State	
  University:	
  “Asperger	
  syndrome:	
  clinical	
  features,	
   assessment,	
  treatment,	
  and	
  research”.	
  Tallahassee,	
  FL,	
  June	
  20,	
  2002.	
  
	
   Neurobiological	
  Basis	
  of	
  Developmental	
  Disabilities	
  –	
  Developmental	
  Disabilities	
  Across	
  the	
   Lifespan.	
  The	
  Stanley	
  S.	
  Lamm	
  Institute	
  for	
  Child	
  Neurology	
  and	
  Developmental	
  Medicine	
  and	
   Long	
  Island	
  College	
  Hospital:	
  “Asperger	
  syndrome”.	
  Brooklyn,	
  NY,	
  May	
  22,	
  2002.	
  
	
   Neurobiological	
  Basis	
  of	
  Developmental	
  Disabilities	
  –	
  Developmental	
  Disabilities	
  Across	
  the	
   Lifespan.	
  The	
  Stanley	
  S.	
  Lamm	
  Institute	
  for	
  Child	
  Neurology	
  and	
  Developmental	
  Medicine	
  and	
   Long	
  Island	
  College	
  Hospital:	
  “Growing	
  up	
  with	
  an	
  autistic	
  spectrum	
  disorder”.	
  Brooklyn,	
  NY,	
   May	
  22,	
  2002.	
  
	
   Neurobiological	
  Basis	
  of	
  Developmental	
  Disabilities	
  –	
  Developmental	
  Disabilities	
  Across	
  the	
   Lifespan.	
  The	
  Stanley	
  S.	
  Lamm	
  Institute	
  for	
  Child	
  Neurology	
  and	
  Developmental	
  Medicine	
  and	
   Long	
  Island	
  College	
  Hospital:	
  “Autism:	
  Clinical	
  issues	
  across	
  the	
  lifespan”.	
  Brooklyn,	
  NY,	
  May	
  22,	
   2002.	
  
	
   23rd	
  Annual	
  International	
  Conference	
  on	
  Mental	
  Retardation	
  and	
  Developmental	
  Disabilities,	
   National	
  Institute	
  for	
  People	
  with	
  Disabilities:	
  “Asperger	
  syndrome:	
  clinical	
  features,	
   educational	
  interventions,	
  and	
  advocacy”.	
  New	
  York	
  City,	
  NY,	
  May	
  5,	
  2002.	
  

Case 2:11-cv-04027-LDD Document 48-36 Filed 07/13/12 Page 49 of 84

Ami	
  Klin,	
  PhD	
  	
  	
  	
  	
  	
  	
  	
  	
  

	
  

	
  

	
  

	
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2002:	
   2002:	
   2002:	
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2002:	
   2002:	
  
2002:	
  
2002:	
   2002:	
  
2001:	
  
2001:	
   2001:	
  
2001:	
   2001:	
  
2000:	
   2000:	
   2000:	
   2000:	
  

	
   Spurwink	
  Institute:	
  “Asperger	
  syndrome:	
  implications	
  of	
  neuropsychological	
  and	
  social	
   cognitive	
  research	
  for	
  educational	
  interventions”,	
  Portland,	
  ME,	
  May	
  4,	
  2002.	
  
	
   Minnesota	
  Association	
  of	
  Child	
  Psychologists:	
  “Asperger	
  syndrome:	
  clinical	
  features,	
   assessment,	
  and	
  intervention”.	
  Minneapolis,	
  MN,	
  April	
  26,	
  2002.	
  
	
   Connecticut	
  Society	
  of	
  Pediatric	
  Dentists.	
  Yale	
  New	
  Haven	
  Hospital:	
  “Autism	
  and	
  related	
   conditions:	
  Suggestions	
  for	
  dental	
  care	
  providers”.	
  New	
  Haven,	
  CT,	
  April	
  10,	
  2002.	
  
	
   Pennsylvania	
  Child	
  and	
  Adolescent	
  Service	
  System	
  Program,	
  Training	
  and	
  Technical	
  Assistance	
   Institute.	
  Center	
  for	
  Community	
  Action	
  and	
  Research	
  in	
  Penn	
  State	
  Harrisburg’s	
  School	
  of	
   Behavioral	
  Sciences	
  and	
  Education:	
  “Social	
  characteristics	
  of	
  individuals	
  with	
  autism	
  and	
  related	
   conditions”.	
  State	
  College,	
  PA,	
  April	
  4,	
  2002.	
  
	
   7th	
  Annual	
  Autism	
  Spectrum	
  Disorder	
  Symposium:	
  “Intervention	
  implications	
  of	
  recent	
  social	
   cognitive	
  research	
  in	
  autism	
  and	
  related	
  conditions”.	
  Providence,	
  RI,	
  March	
  15,	
  2002.	
  
	
   The	
  Connecticut	
  State	
  Department	
  of	
  Education	
  (Special	
  Education	
  Resource	
  Center):	
   “Implications	
  of	
  current	
  research	
  for	
  practitioners	
  working	
  with	
  children	
  with	
  autism	
  spectrum	
   disorders”.	
  Hartford,	
  CT,	
  February	
  7,	
  2002.	
  
	
   The	
  State	
  of	
  Connecticut	
  Department	
  of	
  Mental	
  Retardation:	
  “Autism	
  and	
  the	
  pervasive	
   developmental	
  disorders:	
  An	
  overview	
  of	
  assessment	
  and	
  treatment”.	
  Norwich,	
  CT,	
  January	
  24,	
   2002.	
  
	
   The	
  Connecticut	
  Autism	
  Spectrum	
  Resource	
  Center:	
  “Treatment	
  implications	
  from	
  new	
  social	
   cognitive	
  research	
  in	
  autism”.	
  Cheshire,	
  CT,	
  January	
  23,	
  2002.	
  
	
   The	
  Connecticut	
  State	
  Department	
  of	
  Education	
  (Special	
  Education	
  Resource	
  Center,	
  Directors	
   of	
  Special	
  Education	
  Meeting:	
  “Assessment	
  and	
  treatment	
  of	
  children	
  with	
  autism	
  and	
  related	
   disorders”.	
  Farmington,	
  CT,	
  February	
  7,	
  2002.	
  	
  	
  
	
   The	
  Maryland	
  State	
  Department	
  of	
  Education,	
  the	
  Intensive	
  Behavior	
  Management	
  Program,	
   and	
  the	
  [State	
  of	
  Maryland]	
  Developmental	
  Disabilities	
  Administration:	
  “Asperger	
  syndrome:	
   clinical	
  features,	
  assessment,	
  treatment,	
  and	
  research	
  highlights”.	
  Hagerstown,	
  MD,	
  November	
   9	
  -­‐	
  10,	
  2001.	
  
	
   Connecticut	
  Community	
  Providers	
  Association:	
  “Assessment	
  and	
  treatment	
  of	
  pervasive	
   developmental	
  disorders”.	
  Farmington,	
  CT,	
  November	
  2,	
  2001.	
  
	
   Texas	
  Medical	
  Association,	
  Child	
  and	
  Adolescent	
  Psychiatry,	
  Annual	
  Meeting:	
  “Autism	
  and	
  the	
   pervasive	
  developmental	
  disorders:	
  Concepts,	
  assessment,	
  and	
  treatment”.	
  Galveston,	
  TX,	
  July	
   27,	
  2001.	
  
	
   5th	
  Annual	
  Conference	
  on	
  Autism.	
  Mount	
  Sinai	
  School	
  of	
  Medicine:	
  “Asperger	
  syndrome:	
   Clinical	
  features	
  and	
  treatment	
  guidelines”.	
  New	
  York	
  City,	
  NY,	
  April	
  22nd,	
  2001.	
  
	
   Regional	
  Autism	
  Project,	
  Autism	
  Society	
  of	
  America:	
  “Behavioral	
  and	
  neuroimaging	
  studies	
  of	
   social	
  cognition	
  in	
  autism:	
  Implications	
  for	
  treatment	
  and	
  interventions”.	
  Saint	
  Paul,	
  MN,	
   January	
  25,	
  2001.	
  
	
   SERC,	
  Connecticut	
  State	
  Department	
  of	
  Education:	
  “Asperger	
  syndrome	
  and	
  higher	
  functioning	
   autism”.	
  Meriden,	
  CT,	
  December	
  8,	
  2000.	
  
	
   National	
  Association	
  for	
  Continuing	
  Education	
  and	
  University	
  of	
  Massachusetts	
  Medical	
  School:	
   “Asperger	
  syndrome”.	
  Washington,	
  D.C.,	
  November	
  28,	
  2000.	
  
	
   Autism	
  Society	
  of	
  America,	
  Providence,	
  Rhode	
  Island	
  Chapter,	
  and	
  Developmental	
  Disabilities	
   Program,	
  Bradley	
  Hospital:	
  “Asperger	
  syndrome”.	
  Providence,	
  RI,	
  November	
  15,	
  2000.	
  
	
   Arc	
  of	
  Washington	
  County:	
  “Asperger	
  syndrome”.	
  Hagerstown,	
  MD,	
  June	
  22,	
  2000.	
  

Case 2:11-cv-04027-LDD Document 48-36 Filed 07/13/12 Page 50 of 84

Ami	
  Klin,	
  PhD	
  	
  	
  	
  	
  	
  	
  	
  	
  

	
  

	
  

	
  

	
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   New	
  Jersey	
  Association	
  of	
  School	
  Psychologists	
  Annual	
  Meeting:	
  ”Asperger	
  syndrome:	
  Clinical	
   features,	
  assessment,	
  and	
  educational	
  interventions”.	
  Jamesburg,	
  NJ,	
  May	
  5,	
  2000.	
  
	
   Eagle	
  Hill	
  School’s	
  Symposium	
  2000:	
  Strategies	
  for	
  Learning	
  Disabilities	
  in	
  the	
  Millennium.	
  Eagle	
   Hill	
  School:	
  “Asperger	
  syndrome:	
  Clinical	
  features	
  and	
  treatment/intervention	
  guidelines;	
  and	
   Creating	
  social	
  understanding:	
  Current	
  research	
  in	
  basic	
  mechanisms	
  of	
  socialization”.	
   Greenwich,	
  CT,	
  April	
  28,	
  2000.	
  
	
   Training	
  workshops	
  on	
  assessment,	
  intervention,	
  and	
  neurobiology	
  of	
  autism	
  and	
  related	
   conditions,	
  Foundation	
  for	
  Education	
  and	
  Research	
  Concerning	
  Children	
  and	
  Adolescents:	
   “Overview	
  of	
  clinical	
  assessment	
  and	
  intervention	
  in	
  autism	
  and	
  related	
  conditions”.	
  Modena,	
   Italy,	
  March	
  21,	
  2000.	
  
	
   Second	
  annual	
  Reaching	
  for	
  Potential:	
  Strategies	
  and	
  methodologies	
  for	
  children	
  and	
  youth	
   with	
  autism	
  spectrum	
  disorders.	
  Colorado	
  Department	
  of	
  Education:	
  “Asperger	
  Syndrome:	
   Clinical	
  features,	
  assessment,	
  intervention,	
  and	
  update	
  on	
  research”.	
  Denver,	
  CO,	
  February	
  24	
  -­‐ 25,	
  2000.	
  
	
   National	
  Institute	
  for	
  People	
  with	
  Disabilities:	
  “Asperger	
  Syndrome:	
  Clinical	
  features,	
   assessment,	
  intervention,	
  and	
  update	
  on	
  research”.	
  New	
  York	
  City,	
  NY,	
  February	
  7,	
  2000.	
  
	
   Autism:	
  Current	
  Status	
  and	
  Future	
  Trends,	
  The	
  Center	
  for	
  the	
  Study	
  of	
  Human	
  Development	
  at	
   Brown	
  University,	
  The	
  Rhode	
  Island	
  Autism	
  Project,	
  and	
  the	
  Groden	
  Center:	
  ”	
  Creating	
  social	
   understanding:	
  Social,	
  cognitive,	
  and	
  neuroimaging	
  in	
  autism”.	
  Providence,	
  RI,	
  February	
  5,	
   2000.	
   Grand	
  Rounds,	
  Four	
  Winds	
  Hospital:	
  “Asperger	
  Syndrome:	
  Clinical	
  features,	
  and	
  treatment	
  and	
  	
   intervention	
  guidelines”.	
  Katonah,	
  NY,	
  November	
  19,	
  1999.	
   The	
  Jewish	
  Community	
  Center,	
  full-­‐day	
  workshop:	
  “Treatment	
  approaches	
  for	
  individuals	
  with	
  	
   Asperger	
  syndrome”.	
  Clifton,	
  NJ,	
  November	
  3rd,	
  1999.	
  	
   6th	
  Annual	
  Jewish	
  Social	
  Service	
  Agency	
  of	
  Metropolitan	
  Washington	
  Professional	
  Symposium:	
  	
   Helping	
  your	
  child	
  with	
  Asperger	
  syndrome	
  understand	
  social	
  events	
  and	
  concepts:	
  “Social	
  skills	
   training	
  for	
  the	
  treatment	
  of	
  individuals	
  with	
  Asperger	
  syndrome”.	
  Washington	
  D.C.,	
  October	
  	
   28,	
  1999.	
  	
   The	
  American	
  Psychiatric	
  Association	
  and	
  The	
  Ohio	
  Psychiatric	
  Association,	
  Salt	
  Fork	
  State	
  Park	
  	
   Lodge,	
  Invited	
  address	
  at	
  Psychiatric	
  Care	
  Across	
  the	
  Life	
  Cycle:	
  “Asperger	
  syndrome	
  and	
  r	
   elated	
  disorders:	
  Clinical	
  features	
  and	
  highlights	
  of	
  current	
  	r
   esearch”.	
  Cambridge,	
  OH,	
  October	
  	
   10,	
  1999.	
  	
   ASPEN	
  (Asperger	
  Syndrome	
  Education	
  Network)	
  Inc.:	
  “Beyond	
  the	
  diagnosis:	
  Guidelines	
  for	
  	
   Intervention”.	
  Edison,	
  NJ,	
  October	
  3,	
  1999.	
  	
   2nd	
  Annual	
  Mark	
  P.	
  Wilson	
  Memorial	
  Grand	
  Rounds,	
  Section	
  of	
  Adolescent	
  Medicine,	
  Children’s	
  	
   Mercy	
  Hospital:	
  “Asperger	
  Syndrome:	
  Diagnostic	
  features,	
  clinical	
  assessment,	
  treatment,	
  and	
  	
   research	
  highlights”.	
  Kansas	
  City,	
  MO,	
  September	
  30,	
  1999.	
   National	
  Association	
  for	
  Continuing	
  Education	
  and	
  the	
  University	
  of	
  Massachusetts	
  Medical	
  	
   School,	
  Featured	
  speaker	
  at	
  Across	
  the	
  Spectrum:	
  Learning	
  Disabilities,	
  ADHD,	
  and	
  Asperger’s	
  	
   Disorder	
  -­‐	
  Current	
  Research	
  and	
  Practice:	
  “Asperger’s	
  disorder:	
  diagnosis,	
  neurobiology,	
  and	
  	
   treatment”.	
  Chicago,	
  IL,	
  September	
  23,	
  1999.	
   The	
  Third	
  Annual	
  S.	
  Gail	
  Mayfield	
  Institute,	
  Virginia	
  Autism	
  Resource	
  Center,	
  Shenandoah	
  	
   University:	
  “The	
  autism	
  spectrum	
  disorders,	
  and	
  Neurobiological	
  issues	
  in	
  autism”.	
  Winchester,	
  	
   VA,	
  August	
  2,	
  1999.	
  	
  	
  

Case 2:11-cv-04027-LDD Document 48-36 Filed 07/13/12 Page 51 of 84

Ami	
  Klin,	
  PhD	
  	
  	
  	
  	
  	
  	
  	
  	
  

	
  

	
  

	
  

	
  Page	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  3	
  	
  	4
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
   	
  	
  

1999:	
   	
  

	
  

	
  

	
  

	
  

	
  

	
  

	
  

	
  

1999:	
   	
  

	
  

	
  

	
  

	
  

	
  

	
  

1999:	
   	
  

	
  

	
  

	
  

	
  

1999:	
   	
  

	
  

	
  

	
  

	
  

1999:	
   	
  

	
  

	
  

1999:	
   	
  

	
  

	
  

	
  

	
  

	
  

	
  

1999:	
   	
  

	
  

	
  

	
  

	
  

	
  

	
  

1999:	
   	
  

	
  

	
  

	
  

	
  

1999:	
   	
  

	
  

	
  

	
  

	
  

1999:	
   	
  

	
  

	
  

	
  

	
  

1999:	
   	
  

	
  

	
  

	
  

	
  

1999:	
   	
  

	
  

	
  

	
  

	
  

1998:	
   	
  

	
  

	
  

	
  

	
  

Course	
  provided	
  at	
  the	
  First	
  Pervasive	
  Developmental	
  Disorders	
  Symposium,	
  Association	
  of	
  	
   Parents	
  and	
  Friends	
  of	
  the	
  Exceptional	
  Child	
  and	
  Mackenzie	
  University	
  Post-­‐Graduate	
  programs	
   in	
  Developmental	
  Disorders,	
  Keynote	
  Address:	
  “Autism	
  and	
  pervasive	
  developmental	
  disorders:	
   Clinical	
  features,	
  assessment,	
  intervention,	
  and	
  research	
  update”.	
  São	
  Paulo,	
  Brazil,	
  July	
  1-­‐2,	
  	
   1999.	
   National	
  Autism	
  and	
  Asperger	
  Syndrome	
  Conference,	
  Autism/Asperger	
  Syndrome	
  Resource	
  	
   Center,	
  Kansas	
  University	
  Medical	
  Center,	
  Keynote	
  Address:	
  “Research	
  issues	
  in	
  autism	
  and	
  	
   Asperger	
  syndrome:	
  Neuropsychology,	
  social	
  cognition,	
  neuroimaging,	
  and	
  genetics”.	
  Kansas	
  	
   City,	
  KS,	
  June	
  24,	
  1999.	
   Autism:	
  Shaping	
  the	
  Future	
  Today,	
  Emory	
  Autism	
  Resource	
  Center	
  and	
  Emory	
  University	
  School	
  	
   of	
  Medicine,	
  Keynote	
  Address:	
  “Asperger	
  syndrome:	
  Clinical	
  and	
  research	
  issues”.	
  Atlanta,	
  GA,	
  	
   June	
  19,	
  1999.	
   Asperger	
  Syndrome	
  Connections	
  1999,	
  The	
  Asperger	
  Syndrome	
  Association	
  of	
  New	
  England,	
  	
   Keynote	
  Address:	
  “Asperger	
  syndrome:	
  Highlights	
  of	
  current	
  research	
  and	
  guidelines	
  for	
  	
   intervention”.	
  June	
  12,	
  1999.	
   The	
  Jewish	
  Family	
  Services:	
  “Autism	
  and	
  related	
  pervasive	
  developmental	
  disorders:	
  A	
  	
   	
   workshop	
  for	
  parents	
  and	
  professionals”.	
  Clifton,	
  NJ,	
  June	
  4,	
  1999.	
   Annual	
  conference	
  of	
  the	
  South	
  Dakota	
  University	
  Affiliated	
  Program	
  (Autism),	
  Department	
  of	
  	
   Pediatrics,	
  School	
  of	
  Medicine,	
  The	
  University	
  of	
  South	
  Dakota:	
  “Autism	
  spectrum	
  disorders:	
  	
   Differential	
  diagnosis,”	
  Keynote	
  address,	
  and	
  “Asperger	
  syndrome:	
  Diagnosis	
  and	
  intervention	
  	
   techniques”.	
  Sioux	
  Falls,	
  SD,	
  April	
  29,	
  1999.	
   Autism	
  Preconference,	
  Contemporary	
  Forums	
  8th	
  Annual	
  Conference	
  and	
  National	
  Institute	
  of	
  	
   Child	
  Health	
  and	
  Human	
  Development:	
  The	
  Child	
  with	
  Special	
  Needs:	
  “Asperger	
  syndrome:	
  	
   Clinical	
  features,	
  assessment,	
  intervention,	
  and	
  highlights	
  of	
  current	
  research”.	
  Washington	
  	
   D.C.,	
  April	
  24,	
  1999.	
  	
   The	
  Broome-­‐Tioga	
  Autism	
  Society	
  of	
  America	
  1999	
  Spring	
  Conference:	
  “Autism	
  and	
  related	
  	
   conditions:	
  Clinical	
  features,	
  assessment,	
  intervention,	
  and	
  research”.	
  Binghamton,	
  NY,	
  April	
  	
   23,	
  1999.	
   1999	
  Annual	
  Conference	
  on	
  Learning	
  Disabilities	
  for	
  Parents,	
  Persons	
  with	
  LD/ADHD,	
  and	
  	
   Professionals,	
  Learning	
  Disabilities	
  Association	
  of	
  Connecticut,	
  Keynote	
  Address:	
  “Asperger	
  	
   syndrome:	
  An	
  update	
  on	
  clinical	
  and	
  research	
  issues”.	
  Hartford,	
  CT,	
  March	
  27,	
  1999.	
   5th	
  Annual	
  Professional	
  Symposium	
  of	
  the	
  Jewish	
  Social	
  Service	
  Agency	
  of	
  Metropolitan	
  	
   	
   Washington:	
  “Understanding	
  and	
  treating	
  Asperger	
  syndrome	
  and	
  other	
  pervasive	
  	
   	
   developmental	
  disorders	
  in	
  children	
  and	
  adolescents”.	
  Washington	
  D.C.,	
  March	
  18,	
  1999.	
  	
   Yale	
  University	
  Child	
  Study	
  Center	
  Conference	
  on	
  Autism,	
  Asperger	
  syndrome	
  and	
  related	
  	
   conditions:	
  “Guidelines	
  for	
  treatment	
  and	
  intervention	
  for	
  more	
  able	
  individuals	
  with	
  severe	
  	
   social	
  disabilities”.	
  New	
  Haven,	
  CT,	
  March	
  13,	
  1999.	
   Birth	
  to	
  Three	
  providers,	
  State	
  of	
  Connecticut,	
  Department	
  of	
  Mental	
  Retardation,	
  DMR:	
  	
   “Interventions	
  for	
  children	
  with	
  autism	
  and	
  related	
  conditions”	
  New	
  Haven,	
  CT,	
  January	
  13,	
  	
   1999.	
   3rd	
  Annual	
  Symposium,	
  “Asperger	
  syndrome	
  and	
  high	
  functioning	
  autism:	
  Toward	
  an	
  	
   	
   understanding	
  of	
  the	
  condition	
  and	
  improvement	
  of	
  service	
  provision,”	
  The	
  Cleveland	
  Clinic	
  	
   Foundation	
  and	
  the	
  Autism	
  Society	
  of	
  Greater	
  Cleveland,	
  Keynote	
  Address:	
  “Asperger	
  	
   	
  

Case 2:11-cv-04027-LDD Document 48-36 Filed 07/13/12 Page 52 of 84

Ami	
  Klin,	
  PhD	
  	
  	
  	
  	
  	
  	
  	
  	
  

	
  

	
  

	
  

	
  Page	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  3	
  	
  	5
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
   	
  	
  

	
  

	
  

syndrome:	
  Clinical	
  features,	
  assessment,	
  intervention,	
  and	
  research	
  highlights”.	
  Cleveland,	
  OH,	
  	
  

	
  

	
  

1998:	
   	
  

December	
  11,	
  1998.	
   Telemedicine	
  Broadcast,	
  Cleveland	
  Clinic	
  Westlake,	
  and	
  Learning	
  Assessment	
  Clinic	
  3rd	
  Annual	
  	
  

	
  

	
  

Seminar,	
  The	
  Cleveland	
  Clinic	
  Foundation,	
  Keynote	
  Address:	
  “Treatment	
  and	
  Intervention:	
  	
  

	
  

	
  

Some	
  guidelines	
  for	
  parents.	
  “Living	
  with	
  high	
  functioning	
  autism,	
  Asperger	
  syndrome	
  and	
  	
  

	
  

	
  

PDD”.	
  Cleveland,	
  OH,	
  December	
  10,	
  1998.	
  	
  

1998:	
   	
  

State-­‐wide	
  teleconference,	
  Instructional	
  Support	
  System	
  of	
  Pennsylvania,	
  Pennsylvania	
  	
   	
  

	
  

	
  

Department	
  of	
  Education:	
  “Asperger’s	
  syndrome:	
  Implications	
  for	
  education”.	
  Gibsonia,	
  PA,	
  	
  

	
  

	
  

December	
  8,	
  1998.	
  	
  

1998:	
   	
  

Current	
  Trends	
  in	
  Autism	
  Conference,	
  The	
  Autism	
  Research	
  Foundation	
  (Massachusetts	
  General	
  

	
  

	
  

Hospital):	
  “Asperger’s	
  syndrome:	
  Clinical	
  and	
  research	
  issues”.	
  Danvers,	
  MA,	
  November	
  6,	
  	
  

	
  

	
  

1998.	
  

1998:	
   	
  

New	
  Mexico	
  Autism	
  Conference,	
  “Autism	
  Over	
  the	
  Lifetime”,	
  The	
  New	
  Mexico	
  Autism	
  Society:	
  	
  

	
  

	
  

“Intervention	
  strategies	
  for	
  children	
  and	
  adults	
  with	
  Asperger’s	
  syndrome”.	
  Albuquerque,	
  NM,	
  	
  

	
  

	
  

October	
  24,	
  1998.	
  

1998:	
   	
  

New	
  Mexico	
  Autism	
  Conference,	
  “Autism	
  Over	
  the	
  Lifetime”,	
  the	
  New	
  Mexico	
  Autism	
  Society,	
  	
  

	
  

	
  

Keynote	
  Address:	
  “Asperger’s	
  syndrome”.	
  Albuquerque,	
  NM,	
  October	
  24,	
  1998.	
  

1998:	
   	
  

Nassau/Suffolk	
  Autism	
  Society	
  of	
  America:	
  “Asperger’s	
  syndrome:	
  Clinical	
  features,	
  treatment,	
  	
  

	
  

	
  

and	
  educational	
  interventions”.	
  Long	
  Island,	
  RI,	
  October	
  4,	
  1998.	
  

1998:	
  	
   	
  

The	
  Child	
  with	
  Special	
  Needs:	
  The	
  National	
  Conference	
  Addressing	
  Issues	
  in	
  Early	
  Development.	
  

	
  

	
  

Contemporary	
  Forums	
  and	
  the	
  National	
  Institute	
  of	
  Child	
  Health	
  and	
  Human	
  Development:	
  	
  

	
  

	
  

“Asperger’s	
  syndrome:	
  Overview	
  of	
  clinical	
  features,	
  assessment	
  and	
  intervention,	
  and	
  	
   	
  

	
  

	
  

highlights	
  of	
  current	
  research”.	
  Anaheim,	
  CA,	
  April	
  28,	
  1998.	
  

1996:	
   	
  

Connecticut	
  Alliance	
  for	
  the	
  Mentally	
  Ill	
  (CAMI)’s	
  annual	
  conference	
  “Children’s	
  Mental	
  Health:	
  	
  

	
  

	
  

Pathway	
  to	
  Success”:	
  “Diagnosis	
  and	
  treatment	
  of	
  autism	
  and	
  other	
  pervasive	
  developmental	
  	
  

	
  

	
  

disorders”.	
  Hartford,	
  CT,	
  October	
  5,	
  1996.	
  

1992:	
  	
   	
  

Hillel,	
  Yale	
  University:	
  “The	
  little	
  size	
  of	
  a	
  cataclysmic	
  reality:	
  Children	
  of	
  the	
  Holocaust”.	
  New	
  	
  

	
  

	
  

Haven,	
  CT,	
  March	
  30,	
  1992.	
  

1990:	
   	
  

B'Nai	
  B'rith	
  Women	
  of	
  Greater	
  New	
  Haven	
  meeting	
  on	
  "The	
  Realities	
  of	
  Raising	
  Emotionally	
  	
  

	
  

	
  

Healthy	
  Children,"	
  Yale	
  University:	
  “Cross-­‐cultural	
  perspectives	
  on	
  emotional	
  development”.	
  	
  

	
  

	
  

New	
  Haven,	
  CT,	
  November	
  2,	
  1990.	
  

	
  

27.	
   Invited	
  research	
  presentations	
  in	
  national	
  and	
  international	
  meetings	
  and	
  professional	
  organizations	
  

	
  

(Over	
  150	
  Keynote	
  Presentations,	
  Invited	
  lectures,	
  Grand	
  Rounds	
  and	
  Presentations	
  in	
  Professional	
  	
  

	
  

Meetings):	
  

	
  

2012	
   	
  

Morehouse	
  School	
  of	
  Medicine,	
  Department	
  of	
  Pediatrics	
  Grand	
  Rounds:	
  “	
  A	
  new	
  system	
  of	
  	
  

	
  

	
  

healthcare	
  delivery	
  for	
  infants	
  &	
  toddlers	
  with	
  autism.”	
  Atlanta,	
  GA,	
  May	
  23,	
  2012.	
  

2012	
   	
  

Center	
  for	
  Autism	
  Research	
  Lecture	
  Series:	
  “New	
  Research	
  on	
  Social	
  Engagement	
  Deficits	
  in	
  	
  

	
  

	
  

Young	
  Children	
  with	
  Autism:	
  Implications	
  for	
  Clinical	
  Practice”.	
  Philadelphia,	
  PA,	
  April	
  12,	
  2012.	
  

2012	
   	
  

NIH	
  Biomarkers	
  Consortium:	
  “Diagnostic	
  and	
  Prescriptive	
  Quantifiers	
  of	
  Social	
  Disability	
  in	
  	
  

	
  

	
  

Autism”.	
  Washington	
  D.C.,	
  March	
  28,	
  2012.	
  

2012	
   	
  

Wolfson	
  Children’s	
  Hospital,	
  University	
  of	
  North	
  Florida	
  Autism	
  Symposium:	
  “The	
  Unfolding	
  of	
  	
  

	
  

	
  

Social	
  Learning	
  in	
  Toddlers	
  with	
  Autism	
  Spectrum	
  Disorder”.	
  Jacksonville,	
  FL,	
  March	
  14,	
  2012.	
  

Case 2:11-cv-04027-LDD Document 48-36 Filed 07/13/12 Page 53 of 84

Ami	
  Klin,	
  PhD	
  	
  	
  	
  	
  	
  	
  	
  	
  

	
  

	
  

	
  

	
  Page	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  3	
  	
  	6
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
   	
  	
  

2012	
   	
  

	
  

	
  

2012	
   	
  

	
  

	
  

2012	
   	
  

	
  

	
  

	
  

	
  

2011	
   	
  

	
  

	
  

2011	
   	
  

	
  

	
  

	
  

	
  

2011	
   	
  

2011	
   	
  

	
  

	
  

2011	
   	
  

2011	
   	
  

2011	
   	
  

	
  

	
  

2011	
   	
  

2011	
   	
   2011	
   	
  

2011	
   	
  

2011	
   	
  

	
  

	
  

2011	
   	
  

	
  

	
  

	
  

	
  

2010	
   	
  

	
  

	
  

	
  

	
  

Wolfson	
  Children’s	
  Hospital,	
  University	
  of	
  North	
  Florida	
  Autism	
  Symposium:	
  “Science-­‐based	
  	
   Early	
  Detection	
  of	
  Autism	
  in	
  the	
  First	
  Year	
  of	
  Life”.	
  	
   Jacksonville,	
  FL,	
  March	
  14,	
  2012.	
   Simon’s	
  Regression	
  Workshop:	
  “	
  What	
  is	
  that	
  we	
  call	
  ‘regression’	
  in	
  autism:	
  the	
  ‘developmental’	
   in	
  neurodevelopmental	
  disorders”.	
  New	
  York,	
  NY,	
  February	
  12	
  –	
  13,	
  2012.	
   CARD,	
  Albany,	
  2012	
  Annual	
  Distinguished	
  Guest	
  Lecture	
  in	
  Autism:	
  “New	
  Research	
  on	
  Social	
  	
   Engagement	
  Deficits	
  in	
  Young	
  Children	
  with	
  Autism:	
  Implications	
  for	
  Clinical	
  Practice”.	
  Albany,	
  	
   NY,	
  January	
  25,	
  2012.	
   Cell	
  Symposia	
  2011:	
  “New	
  Research	
  on	
  Social	
  Engagement	
  Deficits	
  in	
  Young	
  Children	
  with	
  	
   Autism:	
  Implications	
  for	
  Clinical	
  Practice”.	
  Arlington,	
  VA,	
  November	
  11,	
  2011.	
   15th	
  Annual	
  Conference,	
  Interdisciplinary	
  Council	
  on	
  Developmental	
  and	
  Learning	
  Disabilities:	
  	
   “Early	
  Diagnostic	
  Indicators	
  and	
  Predictors	
  of	
  Outcome	
  in	
  Autism	
  Spectrum	
  Disorders”.	
  	
   	
   Washington	
  D.C.,	
  November	
  11,	
  2011.	
   TedXPeachtree:	
  “How	
  Autism	
  Created	
  Itself”.	
  Atlanta,	
  GA,	
  November	
  4,	
  2011.	
   Georgia	
  Chapter	
  of	
  AAP,	
  keynote	
  address:	
  Research	
  on	
  Social	
  Engagement	
  Deficits	
  in	
  Young	
  	
   Children	
  with	
  Autism:	
  Implications	
  for	
  Clinical	
  Practice”.	
  Atlanta,	
  GA,	
  November	
  3,	
  2011.	
   Autism	
  Speaks	
  Board	
  Meeting:	
  “	
  	
   American	
  Psychological	
  Association	
  119th	
  Annual	
  Convention,	
  Invited	
  Presentation	
  for	
  Division	
   33:	
  ‘Early	
  Diagnostic	
  Indicators	
  in	
  Autism	
  Spectrum	
  Disorders:	
  Implications	
  for	
  a	
  New	
  Model	
  of	
   Health	
  Care	
  Delivery’.	
  Washington,	
  DC,	
  August	
  6,	
  2011.	
  	
   National	
  Autism	
  Conference,	
  Pennsylvania	
  State	
  University,	
  Pennsylvania	
  Department	
  of	
  	
   Education:	
  “Clinical	
  and	
  research	
  issues	
  in	
  infancy	
  and	
  toddlerhood	
  of	
  children	
  with	
  autism	
   spectrum	
  disorders”.	
  State	
  College,	
  PA,	
  August	
  1,	
  2011.	
  	
   Opening	
  Keynote	
  Presentation,	
  42nd	
  National	
  Conference	
  of	
  the	
  Autism	
  Society	
  of	
  America:	
   “Translational	
  social	
  neuroscience,	
  community	
  impact,	
  and	
  opportunities	
  for	
  optimizing	
  the	
   outcome	
  of	
  individuals	
  with	
  autism	
  through	
  early	
  diagnosis	
  and	
  intervention”.	
  Orlando,	
  FL,	
  July	
   7,	
  2011.	
  	
   Grand	
  Rounds,	
  Department	
  of	
  Psychiatry	
  and	
  Behavioral	
  Sciences,	
  Emory	
  University	
  School	
  of	
   Medicine:	
  ‘Diagnostic	
  indicators	
  of	
  autism	
  in	
  the	
  first	
  6	
  months	
  of	
  life	
  and	
  the	
  bioethical	
   imperative	
  to	
  implement	
  early	
  intervention’.	
  Atlanta,	
  GA,	
  June	
  8,	
  2011.	
  	
   Seventeenth	
  Annual	
  Eden	
  Autism	
  Services	
  and	
  Princeton	
  Lecture	
  Series,	
  Keynote	
  Address	
  and	
   Award	
  (Emily	
  Cavaliere	
  Puzio	
  and	
  Frank	
  Mauro	
  Puzio	
  Award	
  for	
  Commitment	
  and	
  Dedication	
  to	
   Improving	
  the	
  Quality	
  of	
  Life	
  for	
  Individuals	
  with	
  Autism):	
  “Early	
  indicators	
  and	
  predictors	
  of	
   outcome	
  in	
  infants	
  and	
  toddlers	
  on	
  the	
  autism	
  spectrum”.	
  Princeton	
  University,	
  Princeton,	
  NJ,	
   June	
  3,	
  2011.	
   Scottish	
  Autism	
  National	
  Conference,	
  Keynote	
  Address:	
  “Early	
  indicators	
  and	
  predictors	
  of	
   outcome	
  in	
  infants	
  and	
  toddlers	
  on	
  the	
  autism	
  spectrum”.	
  Glasgow,	
  Scotland,	
  May	
  22,	
  2011.	
   Enlightment	
  Luncheon:	
  “Transforming	
  Services	
  for	
  Children	
  with	
  Autism”.	
  Atlanta,	
  GA,	
  April	
  11,	
  	
   2011.	
  	
   Simons	
  Foundation	
  Autism	
  Research	
  Initiative,	
  Invitational	
  Workshop	
  on	
  the	
  Neuroscience	
  of	
  	
   Attention:	
  “Social	
  Visual	
  Attention	
  and	
  Entrainment	
  in	
  Toddlers	
  with	
  Autism	
  Spectrum	
  	
   Disorders”.	
  New	
  York	
  City,	
  NY,	
  February	
  28,	
  2011.	
   The	
  New	
  York	
  Academy	
  of	
  Sciences,	
  Autism	
  Spectrum	
  Disorders:	
  Early	
  Behavioral	
  Predictors	
   and	
  Biomarkers:	
  “Early	
  indicators	
  and	
  predictors	
  of	
  outcome	
  in	
  infants	
  and	
  toddlers	
  with	
   autism”.	
  New	
  York	
  City,	
  NY,	
  December	
  1,	
  2010.	
  	
  

Case 2:11-cv-04027-LDD Document 48-36 Filed 07/13/12 Page 54 of 84

Ami	
  Klin,	
  PhD	
  	
  	
  	
  	
  	
  	
  	
  	
  

	
  

	
  

	
  

	
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  	7
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
   	
  	
  

2010	
   	
  

	
  

	
  

	
  

	
  

2010	
   	
  

	
  

	
  

	
  

	
  

2010	
   	
  

	
  

	
  

2010	
   	
  

	
  

	
  

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2009	
  

2009	
  

2009	
  

2009	
   	
  

	
  

	
  

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2009	
   	
  

	
  

	
  

2009	
  

2009	
   	
  

	
  

	
  

2008	
  

2008	
  

2008	
  

7th	
  National	
  Annual	
  Conference	
  –	
  Autism,	
  a	
  Hands	
  On	
  Approach,	
  The	
  University	
  of	
  Manchester	
  	
   and	
  Stockport	
  Postgraduate	
  Medical	
  Education	
  Centre,	
  Invited	
  Presentation:	
  “Grand	
  challenges	
   in	
  science	
  and	
  clinical	
  care	
  in	
  autism	
  spectrum	
  disorders”.	
  Stockport,	
  UK,	
  November	
  10,	
  2010.	
  	
   Forty-­‐Eighth	
  Annual	
  New	
  Horizons	
  in	
  Science,	
  Council	
  for	
  the	
  Advancement	
  of	
  Science	
  Writing:	
   “Early	
  indicators	
  and	
  predictors	
  of	
  outcome	
  in	
  infants	
  and	
  toddlers	
  with	
  autism”.	
  	Y
   ale	
  	
  	
   	
   University,	
  New	
  Haven,	
  CT,	
  November	
  9,	
  2010.	
  	
   IX	
  International	
  Congress,	
  Autism-­‐Europe,	
  Keynote	
  Address:	
  “Early	
  indicators	
  and	
  predictors	
  of	
   outcome	
  in	
  infants	
  and	
  toddlers	
  with	
  autism”.	
  Catania,	
  Italy,	
  October	
  9,	
  2010.	
  	
   Simons	
  Foundation	
  Autism	
  Research	
  Initiative:	
  “Early	
  indicators	
  and	
  predictors	
  of	
  outcome	
  in	
   infants	
  and	
  toddlers	
  with	
  autism”.	
  Washington,	
  D.C.,	
  September	
  13,	
  2010.	
   Yale	
  School	
  of	
  Medicine	
  Department	
  of	
  Genetics,	
  Grand	
  Rounds:	
  Sociality	
  in	
  the	
  first	
  two	
  years	
  	
   of	
  life:	
  “Cognitive	
  science	
  frontiers	
  in	
  research	
  of	
  autism	
  spectrum	
  disorders”.	
  New	
  Haven,	
  CT,	
  	
   May	
  5,	
  2010.	
   Interdisciplinary	
  Center	
  on	
  Bioethics,	
  Disability	
  Interest	
  Group,	
  Yale	
  University:	
  “Bioethical	
  	
   issues	
  related	
  to	
  research	
  on	
  early	
  detection	
  of	
  autism”.	
  	
  New	
  Haven,	
  CT,	
  March	
  30,	
  2010.	
   56th	
  American	
  Academy	
  of	
  Child	
  and	
  Adolescent	
  Psychiatry	
  Annual	
  Meeting:	
  “Autism	
  	
   as	
  a	
  neurodevelopmental	
  disorder	
  of	
  social	
  engagement:	
  new	
  research	
  and	
  implications	
  for	
  	
   assessment”.	
  Hawaii,	
  October	
  29-­‐30,	
  2009.	
   8th	
  Annual	
  International	
  Meeting	
  for	
  Autism	
  Research	
  (IMFAR):	
  “Perception	
  of	
  audiovisual	
   synchrony	
  under	
  varying	
  degrees	
  of	
  social	
  context	
  in	
  infants	
  with	
  autism”.	
  Chicago,	
  IL,	
  May	
  9,	
   2009.	
   8th	
  Annual	
  International	
  Meeting	
  for	
  Autism	
  Research	
  (IMFAR):	
  “Perception	
  of	
  physical	
  and	
   social	
  contingencies	
  in	
  infants	
  with	
  autism”.	
  Chicago,	
  IL,	
  May	
  8,	
  2009.	
   8th	
  Annual	
  International	
  Meeting	
  for	
  Autism	
  Research	
  (IMFAR:	
  “Altered	
  face	
  scanning	
  and	
   impaired	
  recognition	
  of	
  biological	
  motion	
  in	
  2-­‐year-­‐olds	
  with	
  autism”.	
  Chicago,	
  IL,	
  May	
  7,	
  2009.	
   Inaugural	
  Lecture,	
  Autism	
  Science	
  Foundation.	
  “Autism	
  spectrum	
  disorders	
  in	
  the	
  second	
  year	
  	
   of	
  life:	
  Research	
  and	
  challenges”.	
  New	
  York	
  City,	
  NY,	
  May	
  12,	
  2009.	
   3rd	
  Annual	
  Conference,	
  Mind	
  &	
  Body	
  in	
  Autism,	
  Teachers	
  College,	
  Columbia	
  University:	
  	
  “Social	
  	
   engagement	
  in	
  infants	
  and	
  toddlers	
  with	
  autism	
  spectrum	
  disorders”.	
  New	
  York	
  City,	
  NY,	
  April	
  	
   18,	
  2009.	
   Invited	
  Discussion	
  of	
  Symposium	
  on	
  Neural	
  Systems,	
  Cognition	
  and	
  Behavior,	
  Simons	
  	
   	
   Foundation,	
  SFARI	
  Annual	
  Meeting,	
  New	
  Orleans,	
  April	
  2,	
  2009.	
   II	
  Congreso	
  Internacional	
  Síndrome	
  de	
  Asperger,	
  Keynote	
  Address:	
  	
  “Quo	
  Vadis	
  Asperger	
   Syndrome:	
  Clinical	
  Realities	
  and	
  Future	
  Research”.	
  	
  Sevilla,	
  Spain,	
  February	
  20,	
  2009.	
   II	
  Congreso	
  Internacional	
  Síndrome	
  de	
  Asperger,	
  Keynote	
  Address:	
  “Where	
  it	
  all	
  	
   begins:	
  Studies	
  of	
  social	
  engagement	
  in	
  infants	
  and	
  toddlers”.	
  Sevilla,	
  Spain,	
  February	
  19,	
  2009.	
   Connecticut	
  Academy	
  of	
  Arts	
  and	
  Sciences,	
  Invited	
  Presentation:	
  “The	
  emergence	
  of	
  social	
   mind,	
  social	
  brain,	
  and	
  autism”.	
  New	
  Haven,	
  CT,	
  November	
  14,	
  2008.	
   Le	
  Centre	
  de	
  Formacion	
  et	
  de	
  Recherche	
  Abe	
  Bold	
  Miriam	
  Foundation,	
  Colloque	
  2008,	
  Keynote	
   Address:	
  “Recherches	
  récentes	
  sur	
  les	
  nourrissons	
  et	
  les	
  tout-­‐petits	
  souffrant	
  de	
  troubles	
   envahissants	
  de	
  developpement”.	
  Montreal,	
  Canada,	
  October	
  31,	
  2008.	
   The	
  Organization	
  for	
  Autism	
  Research,	
  The	
  Sixth	
  Annual	
  Applied	
  Autism	
  Research	
  and	
   Intervention	
  Conference,	
  Keynote	
  Address:	
  “Social	
  engagement	
  in	
  the	
  first	
  two	
  years	
  of	
  life	
  in	
   autism	
  spectrum	
  disorders”.	
  Arlington,	
  VA,	
  October	
  24,	
  2008.	
  

Case 2:11-cv-04027-LDD Document 48-36 Filed 07/13/12 Page 55 of 84

Ami	
  Klin,	
  PhD	
  	
  	
  	
  	
  	
  	
  	
  	
  

	
  

	
  

	
  

	
  Page	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  3	
  	
  	8
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
   	
  	
  

2008	
  

2008	
  

2008	
  

2008	
  

2008:	
   	
  

	
  

	
  

2008:	
  

2008:	
  

2008:	
  

2007:	
  

2007:	
   	
  

	
  

	
  

	
  

	
  

2007:	
  

2007:	
  

2007:	
  

2007:	
   2007:	
   2007:	
  

Grand	
  Rounds,	
  Department	
  of	
  Pediatrics,	
  Yale	
  University	
  School	
  of	
  Medicine:	
  The	
  first	
  two	
  years	
   of	
  life	
  of	
  children	
  with	
  autism	
  spectrum	
  disorders:	
  new	
  science	
  and	
  new	
  goals”.	
  New	
  Haven,	
  CT,	
   October	
  22,	
  2008.	
   35th	
  Carnegie	
  Symposium	
  on	
  Cognition:	
  Development	
  and	
  Brain	
  Systems	
  in	
  Autism.	
  Carnegie	
   Mellon	
  University,	
  Invited	
  Presentation:	
  “Studies	
  of	
  social	
  engagement	
  in	
  the	
  first	
  two	
  years	
  of	
   life	
  in	
  autism	
  spectrum	
  disorders”.	
  Pittsburgh,	
  PA,	
  October	
  18,	
  2008.	
   Simons	
  Foundation	
  Invited	
  Workshop,	
  How	
  can	
  cognitive	
  science	
  inform	
  investigations	
  of	
  the	
   cognitive	
  phenotype	
  in	
  autism?	
  Invited	
  Presentation:	
  “In	
  search	
  of	
  a	
  biologically	
  relevant	
   phenotype	
  in	
  autism”.	
  New	
  York	
  City,	
  NY,	
  September	
  6-­‐7,	
  2008.	
   Yale	
  School	
  of	
  Medicine	
  Reunion	
  Weekend,	
  Yale	
  School	
  of	
  Medicine:	
  Invited	
  Scientific	
   Presentation:	
  “Identifying	
  autism	
  in	
  the	
  first	
  year	
  of	
  life”.	
  New	
  Haven,	
  CT,	
  June	
  7,	
  2008.	
   7th	
  Annual	
  International	
  Meeting	
  for	
  Autism	
  Research	
  (IMFAR:	
  “Perception	
  of	
  physical	
  	
   	
   and	
  social	
  contingencies	
  in	
  infants	
  with	
  autism”.	
  London,	
  May	
  16,	
  2008.	
   7th	
  Annual	
  International	
  Meeting	
  for	
  Autism	
  Research	
  (IMFAR):	
  “Altered	
  face	
  scanning	
  and	
   impaired	
  recognition	
  of	
  biological	
  motion	
  in	
  2-­‐year-­‐olds	
  with	
  autism”.	
  London,	
  May	
  16,	
  2008.	
   STAART	
  Annual	
  Meeting,	
  National	
  Institutes	
  of	
  Health:	
  “The	
  Yale	
  STAART:	
  	A
   ccomplishments	
   2003	
  –	
  2007”.	
  Bethesda,	
  MD,	
  April	
  24,	
  2008.	
   15th	
  Annual	
  Centers	
  for	
  Autism	
  and	
  Related	
  Disabilities	
  (CARDs)	
  of	
  Florida:	
  Keynote	
  Address:	
   “Looking	
  at	
  and	
  thinking	
  about	
  people:	
  Studies	
  of	
  social	
  engagement	
  in	
  the	
  first	
  2	
  years	
  of	
  life	
  in	
   Autism	
  Spectrum	
  Disorders”.	
  Orlando,	
  FL,	
  January	
  27,	
  2008.	
   STEP	
  Science	
  for	
  All	
  series:	
  Autism:	
  What	
  do	
  we	
  know	
  now?	
  National	
  Institutes	
  of	
  Health:	
   Invited	
  Presentation:	
  	
  “Autism:	
  science	
  and	
  clinical	
  practice”.	
  Bethesda,	
  MD	
  December	
  11,	
   2007.	
   Scientific	
  address	
  upon	
  receipt	
  of	
  Pearl	
  H.	
  Rieger	
  Award,	
  Rush	
  NeuroBehavioral	
  Center,	
  Rush	
  	
   Medical	
  Center:	
  “Identifying	
  children	
  with	
  autism	
  in	
  the	
  first	
  2	
  years	
  of	
  life”.	
  Chicago,	
  IL,	
  	
  	
   October	
  18,	
  2007.	
   19th	
  Annual	
  New	
  York	
  Mental	
  Health	
  Symposium,	
  NARSAD,	
  Invited	
  Presentation:	
  ”A	
  potential	
   method	
  of	
  screening	
  for	
  autism	
  in	
  the	
  first	
  months	
  of	
  life”.	
  New	
  York	
  City,	
  NY,	
  October	
  19th,	
   2007.	
   The	
  8th	
  International	
  Congress	
  Autism	
  –	
  Keynote	
  Address:	
  ”Eye-­‐tracking	
  studies	
  of	
  social	
   engagement	
  in	
  autism	
  spectrum	
  disorders:	
  the	
  formation	
  of	
  the	
  social	
  mind	
  and	
  social	
  brain”.	
   Europe,	
  Oslo,	
  Norway,	
  September	
  1,	
  2007.	
   International	
  Congress	
  for	
  Autism	
  Research:	
  Invited	
  Presentation:	
  	
  “Eye-­‐tracking	
  studies	
  of	
   social	
  engagement	
  in	
  individuals	
  with	
  autism	
  spectrum	
  disorders:	
  from	
  babyhood	
  to	
   adulthood”.	
  Mexico	
  City,	
  July	
  5,	
  2007.	
   Cold	
  Spring	
  Harbor	
  Laboratory	
  workshop	
  for	
  basic	
  scientists.	
  Invited	
  Presentation:	
  “Autism	
   Spectrum	
  Disorders:	
  Clinical	
  Science”.	
  Cold	
  Spring	
  Harbor,	
  NY,	
  June	
  14,	
  2007.	
   6th	
  Annual	
  Meeting,	
  International	
  Meeting	
  for	
  Autism	
  Research	
  (IMFAR:	
  “The	
  social	
   neuroscience	
  of	
  autism	
  spectrum	
  disorders”.	
  Seattle,	
  WA,	
  May	
  3,	
  2007.	
   39th	
  Annual	
  Meeting,	
  International	
  Society	
  for	
  Developmental	
  Psychobiology,	
  and	
  Society	
  for	
   Neuroscience:	
  Sackler	
  Symposium,	
  Invited	
  Presentation:	
  	
  “Eye-­‐tracking	
  studies	
  of	
  social	
   engagement	
  in	
  infants	
  and	
  toddlers	
  with	
  autism	
  spectrum	
  disorders”.	
  Atlanta,	
  GA,	
  October	
  14,	
   2007.	
  

Case 2:11-cv-04027-LDD Document 48-36 Filed 07/13/12 Page 56 of 84

Ami	
  Klin,	
  PhD	
  	
  	
  	
  	
  	
  	
  	
  	
  

	
  

	
  

	
  

	
  Page	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  3	
  	
  	9
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
   	
  	
  

2006:	
   2006:	
   2006:	
   2006:	
   2006:	
  
2005:	
   2005:	
   2005:	
   2005:	
   2005:	
   2005:	
   2005:	
   2005:	
   2004:	
   2004:	
  

Congresso	
  Internacional	
  de	
  Sindrome	
  de	
  Asperger,	
  Autism	
  Europe	
  and	
  Associação	
  Portuguesa	
   de	
  Síndrome	
  de	
  Asperger,	
  Keynote	
  Address:	
  	
  “Research	
  on	
  Asperger	
  syndrome:	
  Where	
  are	
   we?”.Oporto,	
  Portugal	
  September	
  25,	
  2006.	
   Society	
  of	
  Biological	
  Psychiatry,	
  61st	
  Annual	
  Scientific	
  Convention	
  &	
  Program,	
  Invited	
   Presentation:	
  “The	
  social	
  neuroscience	
  of	
  autism”.	
  Toronto,	
  Ontario,	
  May	
  20,	
  2006.	
   Mayo	
  Clinic	
  College	
  of	
  Medicine,	
  Dana	
  Child	
  Development	
  and	
  Learning	
  Disorders	
  Program:	
  	
   “Asperger	
  syndrome:	
  Clinical	
  features,	
  assessment	
  and	
  intervention	
  guidelines,	
  and	
  highlights	
   of	
  current	
  research”.	
  Rochester,	
  MN,	
  April	
  28,	
  2006.	
  	
  	
   2006	
  Cognitive	
  Science	
  Society	
  Annual	
  Meeting:	
  “Swimming	
  in	
  the	
  underlying	
  stream:	
   computational	
  models	
  of	
  gaze	
  in	
  a	
  comparative	
  behavioral	
  analysis	
  of	
  autism”.	
  Vancouver,	
   Canada,	
  July	
  26,	
  2006.	
   Brain	
  Development	
  and	
  Disorders	
  Project,	
  Colloquium	
  Series,	
  Department	
  of	
  Brain	
  and	
   Cognitive	
  Sciences,	
  Massachusetts	
  Institute	
  of	
  Technology:	
  Invited	
  Presentation:	
  	
  “Looking	
  at	
   and	
  thinking	
  about	
  people	
  in	
  individuals	
  with	
  autism	
  through	
  the	
  lifespan:	
  Eye-­‐tracking	
  studies	
   of	
  social	
  visual	
  pursuit”.	
  Cambridge,	
  MA,	
  April	
  19,	
  2006.	
   Mind,	
  Brain,	
  Culture,	
  and	
  Consciousness,	
  Whitney	
  Humanities	
  Center	
  at	
  Yale	
  University:	
  Invited	
   Presentation:	
  	
  “Social	
  minds:	
  Perspectives	
  from	
  eye-­‐tracking	
  studies	
  with	
  individuals	
  with	
   autism”.	
  New	
  Haven,	
  CT,	
  December	
  13,	
  2005.	
   Annual	
  Scientific	
  Meeting	
  of	
  the	
  NIH	
  Networks	
  for	
  Autism	
  Research	
  (CPEA	
  and	
  STAART):	
  “Eye-­‐ tracking	
  studies	
  of	
  looking	
  at	
  and	
  thinking	
  about	
  people	
  in	
  toddlers	
  with	
  autism:	
  Watching	
  a	
   face	
  but	
  not	
  seeing	
  a	
  person?”	
  Bethesda,	
  MD,	
  November	
  8,	
  2005.	
   Montreal	
  Children’s	
  Hospital,	
  McGill	
  University:	
  Invited	
  Presentation:	
  “Eye-­‐tracking	
  studies	
  of	
   visual	
  social	
  engagement	
  in	
  autism	
  spectrum	
  disorders:	
  from	
  toddlerhood	
  to	
  adulthood”.	
   Montreal,	
  Quebec,	
  Canada,	
  August	
  26,	
  2005.	
   Distinguished	
  Lecture	
  Series,	
  UC	
  Davis	
  M.I.N.D.	
  Institute:	
  “Eye-­‐tracking	
  studies	
  of	
  social	
  visual	
   pursuit	
  in	
  autism	
  spectrum	
  disorders”.	
  Sacramento,	
  CA,	
  June	
  8,	
  2005.	
   UCLA	
  –	
  Autism	
  Affinity	
  Group	
  Lecture	
  Series,	
  Departments	
  of	
  Neurology	
  and	
  Psychiatry,	
  UCLA:	
   Invited	
  Presentation:	
  “Looking	
  and	
  thinking	
  about	
  people:	
  recent	
  social	
  cognitive	
  research	
  in	
   autism	
  spectrum	
  disorders”.	
  Los	
  Angeles,	
  CA,	
  June	
  3,	
  2005.	
   NICHD	
  and	
  NAAR	
  High	
  Risk	
  Baby	
  Sibs	
  Research	
  Consortium	
  2005	
  Annual	
  Meeting:	
   “Quantification	
  of	
  social	
  visual	
  pursuit	
  when	
  viewing	
  naturalistic	
  situations	
  using	
  eye-­‐tracking	
   technology”.	
  Rockville,	
  MD,	
  March	
  30,	
  2005.	
   Autism	
  Think	
  Tank:	
  The	
  Neural	
  Basis	
  of	
  Autism.	
  Columbia	
  University	
  and	
  the	
  Simons	
   Foundation:	
  “Imaging	
  the	
  world	
  through	
  the	
  eyes	
  of	
  individuals	
  with	
  autism:	
  eye-­‐tracking	
   studies	
  of	
  visual	
  social	
  engagement”.	
  New	
  York	
  City,	
  NY,	
  February	
  26,	
  2005.	
   Grand	
  Rounds,	
  Department	
  of	
  Neuroscience	
  and	
  Department	
  of	
  Psychiatry,	
  University	
  of	
   Florida:	
  “Eye-­‐tracking	
  studies	
  of	
  social	
  engagement	
  in	
  autism	
  and	
  related	
  disorders”.	
   Gainesville,	
  FL,	
  January	
  21,	
  2005.	
   Dr.	
  Harry	
  A.	
  Waisman	
  Memorial	
  Lecture,	
  Waisman	
  Institute,	
  University	
  of	
  Wisconsin:	
  “Eye-­‐ tracking	
  studies	
  of	
  visual	
  engagement	
  in	
  autism	
  spectrum	
  disorders”.	
  Madison,	
  WI,	
  November	
   19,	
  2004.	
   25th	
  Annual	
  TEACCH	
  Conference.	
  The	
  Department	
  of	
  Psychiatry,	
  The	
  University	
  of	
  North	
   Carolina	
  at	
  Chapel	
  Hill,	
  Invited	
  Presentation:	
  	
  “Understanding	
  circumscribed	
  interests	
  in	
  autism	
   spectrum	
  disorders”.	
  Chapel	
  Hill,	
  NC,	
  May	
  27,	
  2004.	
  

Case 2:11-cv-04027-LDD Document 48-36 Filed 07/13/12 Page 57 of 84

Ami	
  Klin,	
  PhD	
  	
  	
  	
  	
  	
  	
  	
  	
  

	
  

	
  

	
  

	
  Page	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
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  	0
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
   	
  	
  

2004:	
   2004:	
   2004:	
   2003:	
   2003:	
   2003:	
   2003:	
   2002:	
   2002:	
   2002:	
  
2001:	
   2001:	
   2001:	
   2001:	
   2000:	
   2000:	
  
2000:	
  

Herbert	
  G.	
  Birch	
  Services	
  Seventh	
  Annual	
  New	
  York	
  City	
  Area	
  Conference:	
  Invited	
  Presentation:	
  	
   “Behavioral	
  and	
  neuroimaging	
  studies	
  of	
  social	
  cognition	
  in	
  autism:	
  Implications	
  to	
  clinical	
   practice	
  and	
  educational	
  strategies”.	
  New	
  York	
  City,	
  NY,	
  March	
  10,	
  2004.	
   Clinical	
  Luncheon	
  at	
  the	
  Yale	
  University	
  Department	
  of	
  Psychology:	
  “From	
  looking	
  at	
  to	
  thinking	
   about	
  people:	
  lessons	
  from	
  autism”.	
  New	
  Haven,	
  CT,	
  February	
  19,	
  2004.	
   Yale	
  University	
  PACE	
  Center	
  grand	
  rounds:	
  “Social	
  cognitive	
  studies	
  in	
  autism”.	
  New	
  Haven,	
  CT,	
   February	
  2,	
  2004.	
   Developmental	
  Science	
  and	
  Psychoanalysis:	
  Integration	
  and	
  Innovation.	
  The	
  Yale	
  Child	
  Study	
   Center	
  and	
  the	
  Anna	
  Freud	
  Centre:	
  “Social	
  cognition	
  as	
  embodied	
  traces	
  of	
  social	
  inter-­‐action:	
   lessons	
  from	
  autism”.	
  New	
  Haven,	
  CT,	
  December	
  12,	
  2003.	
   Seventh	
  International	
  Autism	
  Europe	
  Congress,	
  Keynote	
  Address:	
  “Behavioral	
  and	
   neuroimaging	
  studies	
  of	
  social	
  cognition	
  in	
  autism”.	
  Lisbon,	
  Portugal,	
  November	
  15,	
  2003.	
   American	
  Academy	
  of	
  Child	
  and	
  Adolescent	
  Psychiatry	
  50th	
  Anniversary	
  Meeting:	
  “Research	
  on	
   social	
  behavior	
  in	
  infants	
  with	
  autism”.	
  Miami,	
  FL,	
  October	
  17,	
  2003.	
   The	
  US	
  Congressional	
  Biomedical	
  Research	
  Caucus.	
  Capitol	
  Hill:	
  Invited	
  Presentation:	
  “Progress	
   in	
  Autism	
  Research”.	
  Washington,	
  D.C.,	
  September	
  10,	
  2003.	
   Developmental	
  Luncheon	
  (Grand	
  Rounds)	
  at	
  the	
  Department	
  of	
  Psychology,	
  Yale	
  University:	
   “The	
  social	
  mind	
  and	
  the	
  social	
  brain:	
  lessons	
  from	
  autism”.	
  New	
  Haven,	
  CT,	
  October	
  23,	
  2002.	
   Università	
  Degli	
  Studi	
  Di	
  Modena	
  e	
  Regio	
  Emilia,	
  Invited	
  Presentation:	
  “Nuovi	
  strumenti	
  di	
   ricerca	
  e	
  di	
  intervento	
  nell’Autismo	
  e	
  nei	
  Disturbi	
  Pervasivi	
  dello	
  Sviluppo“.	
  Modena,	
  Italy,	
  May	
   27,	
  2002.	
  	
  	
   Autismo	
  Italia	
  and	
  Autisme	
  Europe,	
  Conferenza	
  Internazionale	
  in	
  memoria	
  di	
  Donald	
  Cohen,	
  Un	
   Patto	
  Per	
  L’Autismo	
  Fra	
  Istituzioni,	
  Comunita	
  Scientifica	
  e	
  Famiglie.	
  La	
  Sapienza	
  University,	
   Invited	
  Presentation:	
  “Lo	
  sguardo	
  e	
  il	
  pensiero	
  dell’autismo	
  sugli	
  altri.	
  Aspetti	
  Neurobiologici	
   Dell’Autismo”.	
  Rome,	
  Italy,	
  May	
  24,	
  2002.	
   Third	
  Annual	
  Issues	
  in	
  Autism	
  Conference,	
  The	
  social	
  brain.	
  University	
  of	
  Miami,	
  Center	
  for	
   Autism	
  and	
  Related	
  Disabilities,	
  Invited	
  Presentation:	
  “The	
  Yale	
  eye	
  tracking	
  studies	
  in	
  autism”.	
   Miami,	
  FL,	
  March	
  31,	
  2001.	
   National	
  Institutes	
  of	
  Child	
  Health	
  and	
  Human	
  Development,	
  Collaborative	
  Projects	
  of	
   Excellence	
  in	
  Autism:	
  “Eye-­‐tracking	
  studies	
  of	
  social	
  visual	
  pursuit	
  in	
  autism:	
  viewing	
  naturalistic	
   situations”.	
  New	
  Haven,	
  CT,	
  May	
  2,	
  2001.	
   5th	
  Annual	
  Conference	
  on	
  Autism.	
  Mount	
  Sinai	
  School	
  of	
  Medicine:	
  Invited	
  Presentation:	
  “Eye-­‐ tracking	
  studies	
  of	
  social	
  cognition	
  in	
  autism”.	
  New	
  York	
  City,	
  NY,	
  April	
  22,	
  2001.	
   National	
  Alliance	
  for	
  Research	
  Annual	
  Meeting,	
  Invited	
  Presentation:	
  “Studies	
  of	
  the	
  social	
  mind	
   and	
  the	
  social	
  brain:	
  Implications	
  for	
  treatment	
  and	
  intervention”.	
  Ft.	
  Lauderdale,	
  FL,	
  February	
   3,	
  2001.	
   Grand	
  Rounds,	
  Bradley	
  Hospital	
  and	
  Brown	
  School	
  of	
  Medicine:	
  “Asperger	
  syndrome:	
  Clinical	
   and	
  research	
  issues”.	
  Providence,	
  RI,	
  November	
  15,	
  2000.	
   John	
  D.	
  and	
  Catherine	
  T.	
  MacArthur	
  Foundation	
  and	
  James	
  S.	
  McDonnell	
  Foundation,	
  Research	
   Network	
  on	
  Early	
  Experience	
  and	
  Brain	
  Development:	
  Meeting	
  on	
  Face	
  Recognition,	
  Invited	
   Presentation:	
  “Eye	
  tracking	
  studies	
  of	
  social	
  visual	
  pursuit	
  in	
  autism”.	
  New	
  York,	
  NY,	
  November	
   11-­‐12,	
  2000.	
   6th	
  Annual	
  Current	
  Trends	
  in	
  Autism	
  Conference,	
  The	
  Autism	
  Research	
  Foundation	
  and	
   Massachusetts	
  General	
  Hospital	
  for	
  Children,	
  Invited	
  Presentation:	
  “Seeing	
  people	
  and	
  thinking	
  

Case 2:11-cv-04027-LDD Document 48-36 Filed 07/13/12 Page 58 of 84

Ami	
  Klin,	
  PhD	
  	
  	
  	
  	
  	
  	
  	
  	
  

	
  

	
  

	
  

	
  Page	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  4	
  	
  	1
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
   	
  	
  

2000:	
   2000:	
  

1999:	
   	
  

	
  

	
  

	
  

	
  

	
  

	
  

1999:	
  	
   	
  

	
  

	
  

1999:	
  	
   	
  

	
  

	
  

	
  

	
  

1999:	
  	
   	
  

	
  

	
  

	
  

	
  

	
  

	
  

1999:	
  	
   	
  

	
  

	
  

	
  

	
  

1998:	
  	
   	
  

	
  

	
  

1998:	
  	
   	
  

	
  

	
  

	
  

	
  

1998:	
  	
   	
  

	
  

	
  

	
  

	
  

1998:	
   	
  

	
  

	
  

	
  

	
  

1998:	
   	
  

	
  

	
  

1998:	
   	
  

	
  

	
  

1998:	
   	
  

	
  

	
  

1998:	
   	
  

	
  

	
  

about	
  people:	
  Eye	
  tracking	
  studies	
  in	
  autism	
  and	
  related	
  conditions”.	
  Danvers,	
  MA,	
  October	
  21,	
   2000.	
   National	
  Institutes	
  of	
  Child	
  Health	
  and	
  Human	
  Development,	
  Collaborative	
  Projects	
  of	
   Excellence	
  in	
  Autism:	
  “Looking	
  at	
  people:	
  Eye	
  tracking	
  studies	
  in	
  autism”.	
  Denver,	
  CO,	
   September	
  25,	
  2000.	
   Congresso	
  Internazionale,	
  L’autismo	
  e	
  i	
  disturbi	
  pervasivi	
  dello	
  sviluppo:	
  nuove	
  conoscenze	
  per	
   nuovi	
  interventi.	
  Fondazione	
  per	
  lo	
  Studio	
  e	
  la	
  Ricerca	
  Sull’	
  Infanzia	
  e	
  L’Adolescenza,	
  Invited	
   Presentation:	
  “The	
  development	
  of	
  social	
  competence:	
  Precursors	
  and	
  neurobiological	
   underpinnings”.	
  Bologna,	
  Italy,	
  March	
  20,	
  2000.	
   National	
  Institute	
  of	
  Child	
  Health	
  and	
  Human	
  Development	
  (NICHD),	
  Network	
  on	
  the	
  	
   	
   Neurobiology	
  and	
  Genetics	
  of	
  Autism:	
  Collaborative	
  Programs	
  of	
  Excellence	
  in	
  Autism:	
  “A	
  	
   paradigm	
  for	
  assessing	
  social	
  cognition:	
  the	
  Social	
  Attribution	
  Task”.	
  Washington,	
  D.C.,	
  	
   	
   September	
  29,	
  1999.	
  	
   NIDCD	
  Symposium	
  for	
  Research	
  in	
  Child	
  Language	
  Disorders:	
  “Linguistic	
  characteristics	
  of	
  	
   individuals	
  with	
  higher	
  functioning	
  autism	
  and	
  Asperger	
  syndrome”.	
  Madison,	
  WI,	
  June	
  8,	
  1999.	
  	
   Biennial	
  Meeting	
  of	
  the	
  Society	
  for	
  Research	
  in	
  Child	
  Development:	
  “Understanding	
  the	
  broader	
   phenotype	
  of	
  autism:	
  Behavioral	
  profiles	
  of	
  immediate	
  relatives	
  of	
  individuals	
  with	
  autism	
  and	
  	
   Asperger	
  syndrome”.	
  Albuquerque,	
  NM,	
  April	
  16,	
  1999.	
  	
   Biennial	
  Meeting	
  of	
  the	
  Society	
  for	
  Research	
  in	
  Child	
  Development:	
  “Discussant	
  for	
  Drs.	
  Lisa	
  	
   Capps	
  and	
  Marian	
  Sigman’s	
  symposium	
  on	
  Social-­‐Emotional	
  and	
  Language	
  Abilities	
  in	
  	
   	
   Nonretarded	
  Children	
  with	
  Autism:	
  Etiologic	
  and	
  Interpersonal	
  Implications”.	
  Albuquerque,	
  	
   NM,	
  April	
  16,	
  1999.	
  	
   Yale	
  University	
  Child	
  Study	
  Center	
  Conference	
  on	
  Autism,	
  Asperger	
  syndrome	
  and	
  related	
  	
   conditions:	
  “Neuropsychology	
  and	
  social	
  cognition	
  in	
  Asperger	
  syndrome:	
  Update	
  on	
  current	
  	
   research”.	
  New	
  Haven,	
  CT,	
  March	
  12,	
  1999.	
   Grand	
  Rounds,	
  Haskins	
  Laboratories:	
  “Speech,	
  language	
  and	
  communication	
  disabilities	
  in	
  	
   autism”.	
  New	
  Haven,	
  CT,	
  October	
  8,	
  1998.	
  	
   Center	
  for	
  Autism	
  and	
  Related	
  Disorders,	
  Kennedy-­‐Krieger	
  Institute,	
  Johns	
  Hopkins	
  School	
  of	
  	
   Medicine:	
  “Social	
  cognition	
  in	
  autism:	
  Behavioral	
  and	
  neuroimaging	
  research.	
  Clinical	
  and	
  	
   Research	
  Applications	
  of	
  Research	
  on	
  Social	
  Cognition”.	
  Baltimore,	
  MD,	
  September	
  19,	
  1998.	
   Second	
  Annual	
  Learning	
  Disorders	
  Symposium,	
  The	
  H.E.L.P.	
  Group	
  -­‐	
  U.C.L.A.	
  Neuropsychology	
  	
   Program:	
  “Asperger’s	
  Syndrome:	
  Treatment	
  and	
  Intervention”.	
  Los	
  Angeles,	
  CA,	
  September	
  	
   18,	
  1998.	
  	
   Second	
  Annual	
  Learning	
  Disorders	
  Symposium,	
  The	
  H.E.L.P.	
  Group	
  -­‐	
  U.C.L.A.	
  Neuropsychology	
  	
   Program:	
  “Nonverbal	
  Learning	
  Disabilities	
  and	
  Asperger’s	
  Syndrome:	
  Experimental	
  	
   	
   approaches”.	
   Los	
  Angeles,	
  CA,	
  September	
  18,	
  1998.	
  	
   American	
  Psychological	
  Association	
  106th	
  Annual	
  Convention:	
  “NLD	
  impact	
  on	
  socialization:	
  	
   Developmental	
  and	
  experimental	
  perspectives”.	
  San	
  Francisco,	
  CA,	
  August	
  14,	
  1998.	
   American	
  Psychological	
  Association	
  106th	
  Annual	
  Convention:	
  “NLD	
  and	
  Asperger’s	
  syndrome:	
  	
   Issues	
  for	
  future	
  research”.	
  San	
  Francisco,	
  CA,	
  August	
  14,	
  1998.	
   International	
  Neuropsychological	
  Society:	
  “NLD	
  and	
  Asperger’s	
  syndrome:	
  Further	
  evidence	
  of	
  	
   association”.	
  Budapest,	
  Hungary,	
  July	
  6,	
  1998.	
  	
   The	
  Spectrum	
  of	
  Developmental	
  Disabilities	
  XX.	
  Johns	
  Hopkins	
  University:	
  “Asperger’s	
  	
   	
   syndrome:	
  Clinical	
  and	
  social	
  cognitive	
  aspects”.	
  Baltimore,	
  MD,	
  March	
  31,	
  1998.	
  	
  

Case 2:11-cv-04027-LDD Document 48-36 Filed 07/13/12 Page 59 of 84

Ami	
  Klin,	
  PhD	
  	
  	
  	
  	
  	
  	
  	
  	
  

	
  

	
  

	
  

	
  Page	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  4	
  	
  	2
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
   	
  	
  

1998:	
   	
  

	
  

	
  

	
  

	
  

1998:	
   	
  

	
  

	
  

	
  

	
  

1998:	
   	
  

	
  

	
  

	
  

	
  

	
  

	
  

1998:	
   	
  

	
  

	
  

	
  

	
  

1997:	
   	
  

	
  

	
  

	
  

	
  

1997:	
   	
  

	
  

	
  

	
  

	
  

1997:	
   	
  

	
  

	
  

	
  

	
  

1997:	
   	
  

	
  

	
  

1997:	
   	
  

	
  

	
  

1997:	
   	
  

	
  

	
  

	
  

	
  

1996:	
   	
  

	
  

	
  

1996	
   	
  

	
  

	
  

	
  

	
  

1996:	
   	
  

	
  

	
  

1996:	
   	
  

	
  

	
  

	
  

	
  

1996:	
   	
  

	
  

	
  

	
  

	
  

L’Autismo	
  ed	
  i	
  Disturbi	
  Pervasivi	
  dello	
  Sviluppo	
  in	
  età	
  evolutiva:	
  Incontro	
  tra	
  Famiglie,	
  Servizi	
  e	
  	
  

Istituzioni:	
  “Clinical	
  aspects,	
  social	
  cognitive	
  research,	
  and	
  intervention	
  in	
  autism	
  and	
  related	
  	
  

conditions”.	
  Modena,	
  Italy,	
  March	
  28,	
  1998.	
  	
  

Modena	
  International	
  Conference	
  on	
  Autism	
  and	
  Pervasive	
  Developmental	
  Disorders:	
  	
   	
  

“Asperger’s	
  syndrome	
  and	
  other	
  pervasive	
  developmental	
  disorders”.	
  Modena,	
  Italy,	
  March	
  26,	
  

1998.	
  	
  

International	
  Association	
  for	
  Child	
  and	
  Adolescent	
  Psychiatry	
  and	
  Allied	
  Professions	
  (IACAPAP),	
  	
  

International	
  Conference	
  on	
  Autism	
  and	
  Pervasive	
  Developmental	
  Disorders:	
  	
   	
  

	
  

“Neuropsychological	
  and	
  social	
  cognitive	
  approaches	
  to	
  research	
  on	
  the	
  Pervasive	
  	
   	
  

Developmental	
  Disorders”.	
  Venice,	
  Italy,	
  March	
  23,	
  1998.	
  

International	
  Academy	
  of	
  Child	
  and	
  Adolescent	
  Psychiatry	
  and	
  Allied	
  Professions	
  (IACAPAP),	
  	
  

International	
  Conference	
  on	
  Autism	
  and	
  Pervasive	
  Developmental	
  Disorders:	
  “Asperger’s	
  	
  

syndrome”.	
  Venice,	
  Italy,	
  March	
  23,	
  1998.	
  

Autism:	
  Emerging	
  issues	
  in	
  prevalence	
  and	
  etiology,	
  Center	
  for	
  Disease	
  Control	
  and	
  Prevention:	
  	
  

“Operational	
  definition	
  of	
  autism	
  and	
  related	
  conditions	
  for	
  surveillance	
  and	
  epidemiologic	
  	
  

purposes”.	
  Atlanta,	
  GA,	
  November	
  6,	
  1997.	
  	
   44th	
  Annual	
  Meeting	
  of	
  the	
  American	
  Academy	
  of	
  Child	
  and	
  Adolescent	
  Psychiatry:	
  “Asperger’s	
  	
  

disorder:	
  The	
  utility	
  of	
  broad	
  vs.	
  narrow	
  definitions”.	
  Toronto,	
  Ontario,	
  Canada,	
  October	
  17,	
  	
  

1997.	
   44th	
  Annual	
  Meeting	
  of	
  the	
  American	
  Academy	
  of	
  Child	
  and	
  Adolescent	
  Psychiatry:	
  	
   	
  

“Neuropsychological	
  and	
  social	
  cognitive	
  mechanisms	
  contributing	
  to	
  the	
  social	
  disability	
  in	
  	
  

individuals	
  with	
  autism	
  and	
  related	
  conditions”.	
  Toronto,	
  Ontario,	
  Canada,	
  October	
  16,	
  1997.	
   44th	
  Annual	
  Meeting	
  of	
  the	
  American	
  Academy	
  of	
  Child	
  and	
  Adolescent	
  Psychiatry:	
  “Asperger’s	
  	
  

syndrome:	
  Diagnosis	
  and	
  phenomenology”.	
  Toronto,	
  Ontario,	
  Canada,	
  October	
  16,	
  1997.	
  

Grand	
  rounds,	
  Institute	
  of	
  Living:	
  “Asperger’s	
  syndrome:	
  Clinical	
  features	
  and	
  current	
  research”.	
  

Hartford,	
  CT,	
  September	
  10,	
  1997.	
   34th	
  Annual	
  International	
  Conference	
  of	
  the	
  Learning	
  Disabilities	
  Association	
  of	
  America,	
  	
  

Keynote	
  Address:	
  “Asperger	
  syndrome:	
  Clinical	
  features	
  and	
  neurobiology”.	
  Chicago,	
  IL,	
  	
  	
  

February	
  20,	
  1997.	
  	
  

Grand	
  Rounds,	
  Department	
  of	
  Pediatrics	
  Yale	
  University	
  School	
  of	
  Medicine	
  and	
  Yale	
  -­‐	
  New	
  	
  

Haven	
  Hospital:	
  “Asperger’s	
  Syndrome”.	
  New	
  Haven,	
  CT,	
  December	
  11,	
  1996.	
   8th	
  Annual	
  International	
  Conference	
  of	
  CH.A.D.D.,	
  Children	
  and	
  Adults	
  with	
  Attention	
  Deficit	
  	
  

Disorders,	
  Keynote	
  Address:	
  “Severe	
  disorders	
  of	
  socialization:	
  Asperger’s	
  Syndrome	
  and	
  other	
  	
  

Pervasive	
  Developmental	
  Disorders”.	
  Chicago,	
  IL,	
  November	
  14,	
  1996.	
  

43rd	
  Annual	
  Meeting	
  of	
  the	
  American	
  Academy	
  of	
  Child	
  and	
  Adolescent	
  Psychiatry:	
  “Stoppage	
  	
  

rules	
  in	
  the	
  PDDs	
  revisited”.	
  Philadelphia,	
  PA,	
  October	
  25,	
  1996.	
  	
  

43rd	
  Annual	
  Meeting	
  of	
  the	
  American	
  Academy	
  of	
  Child	
  and	
  Adolescent	
  Psychiatry:	
  “Asperger’s	
  

syndrome:	
  diagnosis,	
  neuropsychology,	
  neuroimaging,	
  and	
  genetic	
  aspects”.	
  Philadelphia,	
  PA,	
  	
  

October	
  25,	
  1996.	
  	
  

43rd	
  Annual	
  Meeting	
  of	
  the	
  American	
  Academy	
  of	
  Child	
  and	
  Adolescent	
  Psychiatry:	
  	
   	
  

“Symposium	
  on	
  diagnostic	
  issues	
  in	
  autism	
  and	
  related	
  conditions”.	
  Philadelphia,	
  PA,	
  October	
  	
  

24,	
  1996.	
  	
  

Case 2:11-cv-04027-LDD Document 48-36 Filed 07/13/12 Page 60 of 84

Ami	
  Klin,	
  PhD	
  	
  	
  	
  	
  	
  	
  	
  	
  

	
  

	
  

	
  

	
  Page	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  4	
  	
  	3
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
   	
  	
  

1996:	
   	
  

	
  

	
  

	
  

	
  

1996:	
   	
  

	
  

	
  

	
  

	
  

1996:	
   	
  

	
  

	
  

	
  

	
  

1995:	
   	
  

	
  

	
  

1995:	
   	
  

	
  

	
  

1994:	
   	
  

	
  

	
  

1994:	
   	
  

	
  

	
  

	
  

	
  

1994:	
   	
  

	
  

	
  

1994:	
   	
  

	
  

	
  

1994:	
   	
  

	
  

	
  

1993:	
   	
  

	
  

	
  

1993:	
   	
  

	
  

	
  

	
  

	
  

1993:	
   	
  

	
  

	
  

1993:	
   	
  

	
  

	
  

1993:	
   	
  

	
  

	
  

1993:	
   	
  

	
  

	
  

	
  

	
  

1993:	
   	
  

	
  

	
  

	
  

	
  

1993:	
   	
  

	
  

	
  

19th	
  Annual	
  Mid-­‐Year	
  Meeting	
  of	
  the	
  International	
  Neuropsychological	
  Society:	
  “A	
  	
   	
  
developmental	
  psychopathological	
  model	
  of	
  Asperger	
  Syndrome”.	
  Veldhoven,	
  The	
  Netherlands,	
  
June	
  10,	
  1996.	
   16th	
  Annual	
  Spring	
  Meeting,	
  Division	
  of	
  Psychoanalysis	
  (39),	
  American	
  Psychological	
  	
   	
  
Association:	
  “Asperger	
  syndrome:	
  The	
  inner	
  world	
  experiences	
  of	
  an	
  individual	
  with	
  a	
  	
   	
  
neuropsychologically-­‐	
 b  ased	
  social	
  disability”.	
  New	
  York,	
  NY,	
  April	
  16,	
  1996.	
   33rd	
  Annual	
  International	
  Conference	
  of	
  the	
  Learning	
  Disabilities	
  Association	
  of	
  America,	
  	
  
Keynote	
  Address:	
  “Asperger	
  syndrome:	
  Toward	
  an	
  understanding	
  of	
  the	
  condition	
  and	
  	
   	
  
improvement	
  of	
  service	
  provision”.	
  Dallas,	
  TX,	
  March	
  4,	
  1996.	
  	
   42nd	
  Annual	
  Meeting	
  of	
  the	
  American	
  of	
  Child	
  and	
  Adolescent	
  Psychiatry:	
  “Asperger	
  Syndrome:	
  	
  
Nosology,	
  Neuropsychology	
  and	
  Current	
  Research”.	
  New	
  Orleans,	
  LA,	
  October	
  19,	
  1995.	
  
International	
  Conference	
  of	
  the	
  Learning	
  Disabilities	
  Association	
  of	
  America,	
  Keynote	
  Address:	
  	
  
“Asperger	
  syndrome”.	
  Orlando,	
  FL,	
  March	
  23,	
  1995.	
  	
  
Annual	
  Conference	
  of	
  Brazilian	
  Association	
  of	
  Child	
  Neurology	
  and	
  Psychiatry,	
  Keynote	
  Address:	
  
“Autism	
  and	
  related	
  disorders”.	
  São	
  Paulo,	
  Brazil,	
  December	
  15,	
  1994.	
   41st	
  Annual	
  Meeting	
  of	
  the	
  American	
  Academy	
  of	
  Child	
  and	
  Adolescent	
  Psychiatry:	
  “Childhood	
  	
  
Disintegrative	
  Disorder:	
  Differences	
  from	
  "Early"	
  and	
  "Late"	
  onset	
  autism”.	
  New	
  York,	
  NY,	
  
October	
  17,	
  1994.	
   41st	
  Annual	
  Meeting	
  of	
  the	
  American	
  Academy	
  of	
  Child	
  and	
  Adolescent	
  Psychiatry:	
  “Asperger	
  	
  
syndrome:	
  Clinical	
  and	
  research	
  issues”.	
  New	
  York,	
  NY,	
  October	
  17,	
  1994.	
   41st	
  Annual	
  Meeting	
  of	
  the	
  American	
  Academy	
  of	
  Child	
  and	
  Adolescent	
  Psychiatry:	
  	
   	
  
“Neuropsychological	
  issues	
  in	
  Asperger	
  syndrome”.	
  New	
  York,	
  NY,	
  October	
  16,	
  1994.	
  	
   41st	
  Annual	
  Meeting	
  of	
  the	
  American	
  Academy	
  of	
  Child	
  and	
  Adolescent	
  Psychiatry:	
  “Eligibility	
  	
  
for	
  Birth-­‐to-­‐Three	
  services	
  in	
  a	
  sample	
  of	
  inner-­‐city	
  children”.	
  New	
  York,	
  NY,	
  October	
  15,	
  1994.	
  
Grand	
  Rounds,	
  Department	
  of	
  Psychology,	
  Yale	
  University,	
  New	
  Haven:	
  “The	
  emergence	
  of	
  a	
  	
  
new	
  syndrome:	
  Asperger	
  syndrome”.	
  New	
  Haven,	
  CT,	
  October	
  30,	
  1993.	
   40th	
  Annual	
  Meeting	
  of	
  the	
  American	
  Academy	
  of	
  Child	
  and	
  Adolescent	
  Psychiatry:	
  “Asperger	
  	
  
syndrome:	
  Diagnosis,	
  neuropsychological	
  aspects,	
  and	
  interventions”.	
  San	
  Antonio,	
  TX,	
   	
  
October	
  23,	
  1993.	
   40th	
  Annual	
  Meeting	
  of	
  the	
  American	
  Academy	
  of	
  Child	
  and	
  Adolescent	
  Psychiatry:	
  Workshop	
  	
  
on	
  childhood	
  schizophrenia.	
  San	
  Antonio,	
  TX,	
  October	
  22,	
  1993.	
   40th	
  Annual	
  Meeting	
  of	
  the	
  American	
  Academy	
  of	
  Child	
  and	
  Adolescent	
  Psychiatry:	
  “DSM-­‐IV	
  	
  
Autism	
  and	
  Pervasive	
  Developmental	
  disorders	
  Field	
  Trial”.	
  San	
  Antonio,	
  TX,	
  October	
  22,	
  1993.	
   40th	
  Annual	
  Meeting	
  of	
  the	
  American	
  Academy	
  of	
  Child	
  and	
  Adolescent	
  Psychiatry:	
  “Diagnosis	
  	
  
and	
  Assessment	
  of	
  Autism	
  and	
  PDDs”.	
  San	
  Antonio,	
  TX,	
  October	
  21,	
  1993.	
  
International	
  Neuropsychological	
  Society	
  Twenty-­‐First	
  Annual	
  Meeting:	
  “Higher	
  functioning	
  	
  
autism,	
  Asperger	
  syndrome,	
  and	
  Nonverbal	
  Learning	
  Disabilities	
  Syndrome”.	
  Galveston,	
  TX,	
  
February	
  18,	
  1993.	
  
Eight	
  Biennial	
  National	
  Training	
  Institute,	
  Zero	
  to	
  Three	
  National	
  Center	
  for	
  Clinical	
  Infant	
  	
  
Programs:	
  “Challenges	
  to	
  Researching	
  and	
  Serving	
  Children	
  in	
  Culturally	
  Diverse,	
  High-­‐Risk	
  	
  
Families”.	
  Washington	
  D.C.,	
  December	
  14,	
  1993.	
  
1993	
  Biennial	
  Conference	
  of	
  the	
  Society	
  for	
  Research	
  in	
  Child	
  Development:	
  “Autistic	
  social	
  	
  
dysfunction:	
  Primary	
  and	
  pervasive”.	
  New	
  Orleans,	
  LA,	
  April	
  21,	
  1993.	
  

Case 2:11-cv-04027-LDD Document 48-36 Filed 07/13/12 Page 61 of 84

Ami	
  Klin,	
  PhD	
  	
  	
  	
  	
  	
  	
  	
  	
  

	
  

	
  

	
  

	
  Page	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  4	
  	
  	4
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
   	
  	
  

1993:	
   	
  

1993	
  Biennial	
  Conference	
  of	
  the	
  Society	
  for	
  Research	
  in	
  Child	
  Development:	
  “Higher	
  functioning	
  

	
  

	
  

autism,	
  Asperger's	
  syndrome,	
  and	
  Nonverbal	
  Learning	
  Disabilities	
  syndrome”.	
  New	
  Orleans,	
  

	
  

	
  

LA,	
  April	
  21,	
  1993.	
  

1993:	
   	
  

1993	
  Biennial	
  Conference	
  of	
  the	
  Society	
  for	
  Research	
  in	
  Child	
  Development:	
  “Discussant	
  for	
  Dr.	
  	
  

	
  

	
  

Marian	
  Sigman	
  et	
  al.'s	
  Symposium	
  on	
  Adaptive	
  Behavior,	
  Theory	
  of	
  Mind,	
  and	
  Emotional	
  	
  

	
  

	
  

Understanding	
  in	
  Autism”.	
  New	
  Orleans,	
  LA,	
  April	
  20,	
  1993.	
  

1993:	
   	
  

National	
  Center	
  for	
  Clinical	
  Infant	
  Programs:	
  “The	
  ‘Who's	
  Who’	
  of	
  inner-­‐city	
  toddlers:	
  Setting	
  up	
  

	
  

	
  

1992:	
   	
  

a	
  home-­‐based	
  early	
  intervention	
  program”.	
  Seattle,	
  WA,	
  March	
  2,	
  1993.	
   39th	
  Annual	
  Meeting	
  of	
  the	
  American	
  Academy	
  of	
  Child	
  and	
  Adolescent	
  Psychiatry:	
  “Asperger's	
  	
  

	
  

	
  

syndrome,	
  Autism,	
  and	
  Nonverbal	
  Learning	
  Disabilities:	
  Convergence	
  and	
  	d
   ivergence”.	
  	
   	
  

	
  

	
  

1992:	
   	
  

Washington	
  D.C.,	
  October	
  20,	
  1992.	
   39th	
  Annual	
  Meeting	
  of	
  the	
  American	
  Academy	
  of	
  Child	
  and	
  Adolescent	
  Psychiatry:	
  “Assessment	
  

	
  

	
  

of	
  young	
  children	
  with	
  Autism/PDD”.	
  Washington	
  D.C.,	
  October	
  19,	
  1992.	
  

1992:	
   	
  

Learning	
  Disabilities	
  Association	
  of	
  America	
  International	
  Conference:	
  “Discussant	
  for	
  Dr.	
  	
  

	
  

	
  

Isabelle	
  Rapin’s	
  symposium	
  on	
  Preschool	
  Developmental	
  Disabilities:	
  Diagnosis	
  and	
  Outcome”.	
  	
  

	
  

	
  

1991:	
   	
  

Atlanta,	
  GA,	
  March	
  27,	
  1992.	
   7th	
  Biennial	
  National	
  Training	
  Institute	
  of	
  the	
  National	
  Center	
  for	
  Clinical	
  Infant	
  Programs:	
  

	
  

	
  

“Contributions	
  of	
  social	
  context	
  to	
  the	
  young	
  child's	
  reactions	
  to	
  incongruity:	
  The	
  emergent	
  	
  

	
  

	
  

appreciation	
  of	
  metaphor	
  and	
  irony”.	
  Washington	
  D.C.,	
  December	
  9,	
  1991.	
  

1991:	
   	
  

1991	
  Biennial	
  Conference	
  of	
  the	
  Society	
  for	
  Research	
  in	
  Child	
  Development:	
  pre-­‐Conference	
  	
  

	
  

	
  

symposium	
  on	
  “Theory	
  of	
  Mind	
  in	
  Autism	
  Social	
  development	
  in	
  autism:	
  Historical	
  and	
  clinical	
  	
  

	
  

	
  

perspectives”.	
  Seattle,	
  WA,	
  April	
  14,	
  1991.	
  

1991:	
   	
  

1991	
  Biennial	
  Conference	
  of	
  the	
  Society	
  for	
  Research	
  in	
  Child	
  Development:	
  pre-­‐Conference	
  	
  

	
  

	
  

symposium	
  on	
  “Theory	
  of	
  Mind	
  Experiencing	
  self	
  and	
  others	
  in	
  Autism:	
  A	
  psychoanalytic	
  	
  

	
  

	
  

perspective	
  on	
  Theory	
  of	
  Mind	
  and	
  Autism”.	
  Seattle,	
  WA,	
  April	
  14,	
  1991.	
  

1991:	
   	
  

1991	
  Biennial	
  	
  Conference	
  of	
  the	
  Society	
  for	
  Research	
  in	
  Child	
  Development:	
  “Autistic	
  social	
  	
  

	
  

	
  

dysfunction:	
  Some	
  limitations	
  of	
  the	
  Theory	
  of	
  Mind	
  Hypothesis”.	
  Seattle,	
  WA,	
  April	
  16,	
  1991.	
  

1990:	
   	
  

National	
  Autistic	
  Society	
  meeting	
  on	
  "Experimental	
  Psychology	
  and	
  the	
  Autistic	
  Syndromes"	
  	
  

	
  

	
  

Durham,	
  University:	
  “Young	
  autistic	
  children's	
  listening	
  preferences	
  in	
  regard	
  to	
  	
   	
  

	
  

	
  

	
  

speech.	
  Durham,	
  England,	
  October	
  16,	
  1990.	
  

	
  

27a.	
   Posters	
  and	
  Abstracts	
  in	
  International	
  Meetings:	
  

	
  

There	
  have	
  been	
  numerous	
  posters	
  and	
  abstracts	
  presented	
  and/or	
  published	
  as	
  abstracts	
  in	
  

international	
  meetings	
  over	
  the	
  years.	
  For	
  example,	
  in	
  the	
  last	
  International	
  Meeting	
  for	
  Autism	
  

Research	
  (IMFAR)	
  (San	
  Diego,	
  CA,	
  May	
  17-­‐19,	
  2011),	
  there	
  were	
  5	
  oral	
  presentations	
  (presenter	
  

or	
  co-­‐presenter)	
  and	
  8	
  posters.	
  	
  

	
  

28.	
   Other	
  activities:	
  Media	
  coverage:	
  

	
  

	
  

	
  

There	
  have	
  been	
  numerous	
  media	
  appearances	
  over	
  the	
  years,	
  which	
  included	
  press	
  coverage	
  	
  

	
  

	
  

of	
  our	
  scientific	
  work,	
  advocacy	
  work	
  and/or	
  autism	
  awareness	
  work.	
  The	
  following	
  is	
  a	
  select	
  	
  

	
  

	
  

sample:	
  

	
  

Case 2:11-cv-04027-LDD Document 48-36 Filed 07/13/12 Page 62 of 84

Ami	
  Klin,	
  PhD	
  	
  	
  	
  	
  	
  	
  	
  	
  

	
  

	
  

	
  

	
  Page	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  4	
  	
  	5
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
   	
  	
  

	
  

	
  

Nature	
  Podcast:	
  “A	
  New	
  Finding	
  About	
  Autism”	
  

	
  

	
  

http://www.nature.com/nature/podcast/v458/n7238/nature-­‐2009-­‐04-­‐02.html	
  	
  

	
  

	
  

	
  

“Making	
  the	
  Paper”	
  

	
  

	
  

Nature.	
  2009,	
  459,	
  138.	
  	
  Highlighted	
  research	
  profile	
  of	
  Nature	
  issue	
  #	
  459.	
  	
  

	
  

	
  

	
  

Studio	
  360,	
  Public	
  Radio	
  International:	
  “Windows	
  to	
  the	
  Soul”	
  

	
  

	
  

http://www.studio360.org/episodes/2008/03/28	
  	
  

	
  

	
  

	
  

“This	
  Emotional	
  Life:	
  Autism	
  and	
  Loneliness”,	
  PBS	
  

	
  

	
  

http://www.pbs.org/thisemotionallife/	
  	
  

	
  

	
  

Featured	
  research	
  in	
  documentary	
  on	
  human	
  emotions	
  and	
  Asperger’s	
  Syndrome.	
  

	
  

	
  

	
  

“Ami	
  Klin	
  &	
  Warren	
  Jones:	
  Melding	
  art	
  and	
  science	
  for	
  autism	
  research“	
  

	
  

	
  

http://sfari.org/news/ami-­‐klin-­‐warren-­‐jones-­‐melding-­‐art-­‐and-­‐science-­‐for-­‐autism-­‐research	
  	
  

	
  

	
  

The	
  Simons	
  Foundation	
  (6	
  May	
  2008)	
  -­‐	
  By	
  Virginia	
  Hughes.	
  

	
  

	
  

	
  

“New	
  Techniques	
  Promise	
  Early	
  Diagnosis	
  for	
  Autism”	
  

	
  

	
  

http://sfari.org/news/new-­‐techniques-­‐promise-­‐early-­‐diagnosis-­‐for-­‐autism	
  	
  

	
  

	
  

The	
  Simons	
  Foundation	
  (17	
  April	
  2008)	
  -­‐	
  By	
  Alica	
  Opar	
  	
  

	
  

	
  

	
  

“Mapping	
  the	
  Social	
  Mind“-­‐	
  Yale	
  Medicine	
  (Summer	
  2004)	
  -­‐	
  By	
  Peter	
  Farley	
  	
  

	
  

	
  

	
  

“In	
  Focus:	
  Yale	
  Child	
  Study	
  Center”	
  -­‐	
  Yale	
  Bulletin	
  (04	
  April	
  2008)	
  -­‐	
  By	
  Karen	
  N.	
  Peart	
  

	
  

	
  

	
  

“Lifting	
  the	
  Veils	
  of	
  Autism,	
  One	
  by	
  One	
  by	
  One”	
  –	
  The	
  New	
  York	
  Times,	
  (24	
  February	
  2004)	
  -­‐	
  By	
  

	
  

	
  

Erica	
  Goode	
  

	
  

	
  

	
  

“Experiment	
  Offers	
  Look	
  Through	
  Eyes	
  of	
  Autism”	
  –	
  The	
  New	
  York	
  Times	
  (11	
  June	
  2002)	
  -­‐	
  By	
  	
  

	
  

	
  

John	
  O’Neil	
  

	
  

	
  

	
  

“Inside	
  Autism”	
  -­‐	
  Yale	
  Alumni	
  Magazine	
  (November	
  2002)	
  -­‐	
  By	
  Bruce	
  Fellman	
  

	
  

	
  

	
  

“Understanding	
  Autism”	
  -­‐	
  Newsweek	
  (31	
  July	
  2002)	
  -­‐	
  By	
  Geoffrey	
  Cowley	
  

	
  

	
  

	
  

“Asperger’s	
  Syndrome”	
  -­‐	
  ABC	
  -­‐	
  Good	
  Morning	
  America	
  	
  

	
  

	
  

	
  

“Autism:	
  Paying	
  the	
  Price“	
  -­‐	
  CNBC	
  	
  

	
  

	
  

	
  

“Autism“	
  -­‐	
  NYT	
  -­‐	
  Science	
  Times	
  	
  

	
  

	
  

	
  

“Autism:	
  The	
  Hidden	
  Epidemic?”	
  -­‐	
  NBC	
  Nightly	
  News	
  

	
  

	
  

Case 2:11-cv-04027-LDD Document 48-36 Filed 07/13/12 Page 63 of 84

Ami	
  Klin,	
  PhD	
  	
  	
  	
  	
  	
  	
  	
  	
  

	
  

	
  

	
  

	
  Page	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  4	
  	
  	6
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
   	
  	
  

29.	
   Bibliography	
  (Over	
  190	
  Research	
  Articles,	
  Editorials,	
  Reviews,	
  Book	
  Chapters,	
  Special	
  Journal	
  Editions	
  

	
  

and	
  Edited	
  Books):	
  

	
  

	
  

a.	
  	
   Published	
  and	
  in	
  press	
  research	
  articles:	
  	
  

	
  

	
  

Klin,	
  A.	
  (1991).	
  Young	
  autistic	
  children's	
  listening	
  preferences	
  in	
  regard	
  to	
  speech:	
  A	
  possible	
  	
   	
  

	
  

	
  

characterization	
  of	
  the	
  symptom	
  of	
  social	
  withdrawal.	
  Journal	
  of	
  Autism	
  and	
  Developmental	
  	
  

	
  

	
  

Disorders,	
  21(1),	
  29-­‐42.	
  (Reprinted	
  in	
  Digest	
  Neuropsych,	
  1993,	
  59,	
  104)	
  [PMID:	
  1376327]	
  

	
  

	
  

Klin,	
  A.	
  (1992).	
  Listening	
  preferences	
  in	
  regard	
  to	
  speech	
  in	
  four	
  children	
  with	
  developmental	
  	
   	
  

	
  

	
  

disabilities.	
  Journal	
  of	
  Autism	
  and	
  Developmental	
  Disorders,	
  33(4),	
  763-­‐769.	
  [PMID:	
  1376327]	
  

	
  

	
  

Klin,	
  A.,	
  Volkmar,	
  F.	
  R.,	
  &	
  Sparrow,	
  S.	
  (1992).	
  Autistic	
  social	
  dysfunction:	
  Some	
  limitations	
  of	
  the	
  theory	
  	
  

	
  

	
  

of	
  mind	
  hypothesis.	
  Journal	
  of	
  Autism	
  and	
  Developmental	
  Disorders,	
  33(5),	
  861-­‐876.	
  	
   	
  

	
  

	
  

[PMID:	
  1378847]	
  

	
  

	
  

Volkmar,	
  F.	
  R.,	
  Klin,	
  A.,	
  Siegel,	
  B.,	
  Szatmari,	
  P.,	
  Lord,	
  C.,	
  Campbell,	
  M.,	
  Freeman,	
  B.	
  J.,	
  Cicchetti,	
  D.	
  V.,	
  	
  

	
  

	
  

Rutter,	
  M.,	
  &	
  Kline,	
  W.	
  (1994).	
  Field	
  trial	
  for	
  autistic	
  disorder	
  in	
  DSM-­‐IV.	
  The	
  American	
  Journal	
  	
  

	
  

	
  

of	
  Psychiatry,	
  151(9),	
  1361-­‐1367.	
  (Reprinted	
  in	
  DSM-­‐IV	
  Sourcebook,	
  4,	
  607-­‐626,	
  Washington,	
  	
  

	
  

	
  

D.C.:	
  American	
  Psychiatric	
  Association)	
  [PMID:	
  8067493]	
  

	
  

	
  

Mayes,	
  L.	
  C.,	
  Klin,	
  A.,	
  &	
  Cohen,	
  D.	
  J.	
  (1994).	
  The	
  effect	
  of	
  humor	
  on	
  children's	
  developing	
  theory	
  of	
  	
  

	
  

	
  

mind.	
  British	
  Journal	
  of	
  Developmental	
  Psychology,	
  12,	
  555-­‐561.	
  

	
  

	
  

Cicchetti,	
  D.	
  V.,	
  Volkmar,	
  F.	
  R.,	
  Klin,	
  A.,	
  &	
  Showalter,	
  D.	
  (1995).	
  Diagnosing	
  autism	
  using	
  ICD-­‐10	
  criteria:	
  	
  

	
  

	
  

A	
  comparison	
  of	
  Neural	
  Networks	
  and	
  Standard	
  Multivariate	
  Procedures.	
  The	
  Journal	
  of	
  	
 	 
  

	
  

	
  

Neuropsychiatry	
  and	
  Clinical	
  Neurosciences,	
  1(1),	
  26-­‐37.	
  

	
  

	
  

Mayes,	
  L.	
  C.,	
  Klin,	
  A.,	
  Tercyak,	
  K.	
  P.,	
  Jr.,	
  Cicchetti,	
  D.	
  V.,	
  &	
  Cohen,	
  D.	
  J.	
  (1996).	
  Test-­‐retest	
  reliability	
  for	
  	
  

	
  

	
  

false-­‐belief	
  tasks.	
  .	
  Journal	
  of	
  Autism	
  and	
  Developmental	
  Disorders,	
  37(3),	
  313-­‐319.	
  [PMID:	
  	
  

	
  

	
  

8707914]	
  

	
  

	
  

Klin,	
  A.,	
  Volkmar,	
  F.	
  R.,	
  Sparrow,	
  S.	
  S.,	
  Cicchetti,	
  D.	
  V.,	
  &	
  Rourke,	
  B.	
  P.	
  (1995).	
  Validity	
  and	
  	
   	
  

	
  

	
  

neuropsychological	
  characterization	
  of	
  Asperger	
  syndrome.	
  The	
  Journal	
  of	
  Child	
  Psychology	
  	
  

	
  

	
  

and	
  Psychiatry,	
  36(7),	
  1127-­‐1140.	
  (Reprinted	
  in	
  R.	
  Takagi.,	
  M.	
  Rutter,	
  &	
  E.	
  Schopler,	
  (Eds.),	
  	
  	
  

	
  

	
  

Advances	
  in	
  Research	
  	
  on	
  Autism	
  and	
  Developmental	
  Disorders,	
  1997,1:245-­‐258;	
  Reprinted	
  in	
  	
  

	
  

	
  

M.E.	
  Hertzig,	
  &	
  E.A.	
  Farber,	
  (Eds.)	
  Annual	
  Progress	
  in	
  Child	
  Psychiatry	
  and	
  Child	
  Development.	
  	
  

	
  

	
  

1997,	
  241-­‐259).	
  New	
  York:	
  Brunner/Mazel)	
  	
  [PMID:	
  8847376]	
  

	
  

	
  

Volkmar,	
  F.	
  R.,	
  Klin,	
  A.,	
  &	
  Pauls,	
  D.	
  (1998).	
  Nosological	
  and	
  genetic	
  aspects	
  of	
  Asperger’s	
  syndrome.	
  	
  

	
  

	
  

Journal	
  of	
  Autism	
  and	
  Developmental	
  Disorders,	
  28,	
  456-­‐463.	
  [PMID:	
  9813781]	
  

	
  

Case 2:11-cv-04027-LDD Document 48-36 Filed 07/13/12 Page 64 of 84

Ami	
  Klin,	
  PhD	
  	
  	
  	
  	
  	
  	
  	
  	
  

	
  

	
  

	
  

	
  Page	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  4	
  	
  	7
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
   	
  	
  

	
  

Buitelaar,	
  J.	
  K.,	
  van	
  der	
  Gaag,	
  R.,	
  Klin,	
  A.,	
  &	
  Volkmar,	
  F.	
  (1999).	
  Exploring	
  the	
  boundaries	
  of	
  PDD:	
  	
  

	
  

	
  

Analysis	
  of	
  data	
  from	
  the	
  DSM-­‐IV	
  autistic	
  disorder	
  field	
  trial.	
  Journal	
  of	
  Autism	
  and	
  	
   	
  

	
  

	
  

Developmental	
  Disorders,	
  29(1),	
  33-­‐43.	
  [PMID:	
  10097993]	
  

	
  

	
  

Martin,	
  A.,	
  Scahill,	
  L.,	
  Klin,	
  A.,	
  &	
  Volkmar,	
  F.	
  R.	
  (1999).	
  Higher-­‐functioning	
  pervasive	
  developmental	
  	
  

	
  

	
  

disorders:	
  Rates	
  and	
  patterns	
  of	
  psychotropic	
  drug	
  use.	
  Journal	
  of	
  the	
  American	
  Academy	
  of	
  	
  

	
  

	
  

Child	
  and	
  Adolescent	
  Psychiatry,	
  38(7),	
  923-­‐931.	
  [PMID:	
  10405512]	
  

	
  

	
  

Klin,	
  A.,	
  Sparrow,	
  S.	
  S.,	
  de	
  Bildt,	
  A.,	
  Cicchetti,	
  D.	
  V.,	
  Cohen,	
  D.	
  J.,	
  &	
  Volkmar,	
  F.	
  R.	
  (1999).	
  A	
  normed	
  	
  

	
  

	
  

study	
  of	
  face	
  recognition	
  in	
  autism	
  and	
  related	
  disorders.	
  Journal	
  of	
  Autism	
  and	
  Developmental	
  	
  

	
  

	
  

Disorders,	
  29(6),	
  497-­‐507.	
  [PMID:	
  10638462]	
  

	
  

	
  

Landau,	
  E.	
  C.,	
  Cicchetti,	
  D.	
  V.,	
  Klin,	
  A.,	
  &	
  Volkmar,	
  F.	
  R.	
  (1999).	
  Season	
  of	
  birth	
  in	
  autism:	
  A	
  fiction	
  	
  

	
  

	
  

revisited.	
  	
  Journal	
  of	
  Autism	
  and	
  Developmental	
  Disorders,	
  29(5),385-­‐393.	
  [PMID:	
  10587885]	
  

	
  

	
  

Schultz,	
  R.	
  T.,	
  Gauthier,	
  I.,	
  Klin,	
  A.,	
  Fulbright,	
  R.,	
  Anderson,	
  A.,	
  Volkmar,	
  F.	
  R.,	
  Skudlarski,	
  P.,	
  Lacadie,	
  C.,	
  	
  

	
  

	
  

Cohen,	
  D.	
  J.,	
  &	
  Gore,	
  J.C.	
  (2000).	
  Abnormal	
  ventral	
  temporal	
  cortical	
  activity	
  among	
  individuals	
  	
  

	
  

	
  

with	
  autism	
  and	
  Asperger	
  syndrome	
  during	
  face	
  discrimination.	
  Archives	
  of	
  General	
  Psychiatry,	
  	
  

	
  

	
  

57(4),	
  331-­‐340.	
  [PMID:	
  10768694]	
  

	
  

	
  

Grossman,	
  J.	
  B.,	
  Klin,	
  A.,	
  Carter,	
  A.	
  S.,	
  &	
  Volkmar,	
  F.	
  R.	
  (2000).	
  Verbal	
  bias	
  in	
  recognition	
  of	
  facial	
  	
  

	
  

	
  

emotions	
  in	
  children	
  with	
  Asperger	
  syndrome.	
  The	
  Journal	
  of	
  Child	
  Psychology	
  and	
  	
   	
  

	
  

	
  

Psychiatry,	
  41(3),	
  369-­‐379.	
  [PMID:	
  10784084]	
  

	
  

	
  

Klin,	
  A.,	
  Lang,	
  J.,	
  Cicchetti,	
  D.	
  V.,	
  &	
  Volkmar,	
  F.	
  R.	
  (2000).	
  	
  Interrater	
  reliability	
  of	
  clinical	
  diagnosis	
  and	
  	
  

	
  

	
  

DSM-­‐IV	
  criteria	
  for	
  autistic	
  disorder:	
  Results	
  of	
  the	
  DSM-­‐IV	
  autism	
  field	
  trial.	
  Journal	
  of	
  Autism	
  	
  

	
  

	
  

and	
  Developmental	
  Disorders,	
  30(2),	
  163-­‐167.	
  [PMID:	
  10832781]	
  

	
  

	
  

Klin,	
  A.	
  (2000).	
  Attributing	
  social	
  meaning	
  to	
  ambiguous	
  visual	
  stimuli	
  in	
  higher	
  functioning	
  autism	
  and	
  	
  

	
  

	
  

Asperger	
  syndrome:	
  The	
  Social	
  Attribution	
  Task.	
  The	
  Journal	
  of	
  Child	
  Psychology	
  and	
  Psychiatry,	
  

	
  

	
  

41(7),	
  831-­‐846.	
  [PMID:	
  11079426]	
  

	
  

	
  

Arnold,	
  L.	
  E.,	
  Aman,	
  M.	
  G.,	
  Martin,	
  A.,	
  Collier-­‐Crespin,	
  A.,	
  Vitiello,	
  B.,	
  Tierney,	
  E.,	
  Asarnow,	
  R.,	
  Bell-­‐	
  

	
  

	
  

Bradshaw,	
  F.,	
  Freeman,	
  B.	
  J.,	
  Gates-­‐Ulanet,	
  P.,	
  Klin,	
  A.,	
  McCracken,	
  J.	
  T.,	
  McDougle,	
  C.	
  J.,	
  	
  

	
  

	
  

McGough,	
  J.	
  J.,	
  Posey,	
  D.	
  J.,	
  Scahill,	
  L.,	
  Swiezy,	
  N.	
  B.,	
  Ritz,	
  L.,	
  &	
  Volkmar,	
  F.	
  R.	
  	
  (2000).	
  	
   	
  

	
  

	
  

Assessment	
  in	
  multisite	
  randomized	
  	
 c  linical	
  trials	
  of	
  patients	
  with	
  autism	
  disorder:	
  The	
  	
   	
  

	
  

	
  

autism	
  RUPP	
  Network.	
  Journal	
  of	
  Autism	
  and	
  Developmental	
  Disorders,	
  30(2),	
  99-­‐111.	
  	
   	
  

	
  

	
  

[PMID:	
  10832774]	
  

	
  

	
  

Shriberg,	
  L.	
  D.,	
  Paul,	
  R.,	
  McSweeny,	
  J.	
  L.,	
  Klin,	
  A.,	
  Cohen,	
  D.	
  J.,	
  &	
  Volkmar,	
  F.	
  R.	
  (2001).	
  Speech	
  and	
  	
  

	
  

	
  

prosody	
  characteristics	
  of	
  adolescents	
  and	
  adults	
  with	
  high	
  functioning	
  autism	
  and	
  Asperger	
  	
  

	
  

	
  

syndrome.	
  Journal	
  of	
  Speech,	
  Language	
  and	
  Hearing	
  Research,	
  44,	
  1097-­‐1115.	
  [PMID:	
  	
   	
  

	
  

	
  

11708530]	
  

	
  

Case 2:11-cv-04027-LDD Document 48-36 Filed 07/13/12 Page 65 of 84

Ami	
  Klin,	
  PhD	
  	
  	
  	
  	
  	
  	
  	
  	
  

	
  

	
  

	
  

	
  Page	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  4	
  	
  	8
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
   	
  	
  

	
  

Klin,	
  A.,	
  Jones,	
  W.,	
  Schultz,	
  R.,	
  Volkmar,	
  F.,	
  &	
  Cohen,	
  D.	
  (2002).	
  Visual	
  fixation	
  patterns	
  during	
  viewing	
  	
  

	
  

	
  

of	
  naturalistic	
  social	
  situations	
  as	
  predictors	
  of	
  social	
  competence	
  in	
  individuals	
  with	
  autism.	
  	
  

	
  

	
  

Archives	
  of	
  General	
  Psychiatry,	
  59(9),	
  809-­‐816.	
  [PMID:	
  12215080]	
  

	
  

	
  

Grigorenko,	
  E.	
  L.,	
  Klin,	
  A.,	
  Pauls,	
  D.	
  L.,	
  Senft,	
  R.,	
  Hooper,	
  C.,	
  &	
  Volkmar,	
  F.	
  (2002).	
  A	
  descriptive	
  study	
  of	
  	
  

	
  

	
  

hyperlexia	
  in	
  a	
  clinically	
  referred	
  sample	
  of	
  children	
  with	
  developmental	
  delays.	
  	
  Journal	
  of	
  	
  

	
  

	
  

Autism	
  and	
  Developmental	
  Disorders,	
  32(1),	
  3-­‐12.	
  (Reprinted	
  in	
  Giornale	
  Italiano	
  delle	
  Disabilità	
  

	
  

	
  

(Italian	
  Journal	
  Disability	
  Studies),	
  VI(1),	
  34-­‐49,	
  2006)	
  [PMID:	
  11916330]	
  

	
  

	
  

Klin,	
  A.,	
  Jones,	
  W.,	
  Schultz,	
  R.,	
  Volkmar,	
  F.,	
  &	
  Cohen,	
  D.	
  (2002).	
  Defining	
  and	
  quantifying	
  the	
  social	
  	
  

	
  

	
  

phenotype	
  in	
  autism.	
  	
  The	
  American	
  Journal	
  of	
  Psychiatry,	
  159(6),	
  895-­‐908.	
  (Reprinted	
  in	
  	
  

	
  

	
  

Advances	
  in	
  R	
  on	
  Autism	
  and	
  Developmental	
  Disorders,	
  8,	
  2004,	
  212-­‐231)	
  [PMID:	
  12042174]	
  

	
  

	
  

Tsatsanis,	
  K.	
  D.,	
  Dartnall,	
  N.,	
  Cicchetti,	
  D.	
  V.,	
  Sparrow,	
  S.	
  S.,	
  Klin,	
  A.,	
  &	
  Volkmar,	
  F.	
  R.	
  (2003).	
  Concurrent	
  

	
  

	
  

validity	
  and	
  classification	
  accuracy	
  of	
  the	
  Leiter	
  and	
  Leiter-­‐R	
  in	
  low-­‐functioning	
  children	
  	
   	
  

	
  

	
  

with	
  autism.	
  Journal	
  of	
  Autism	
  and	
  Developmental	
  Disorders,	
  33(1),	
  23-­‐30.	
  [PMID:	
  12708577]	
  

	
  

	
  

Klin,	
  A.,	
  Jones,	
  W.,	
  Schultz,	
  R.	
  T.,	
  &	
  Volkmar,	
  F.	
  R.	
  (2003).	
  The	
  Enactive	
  Mind	
  –	
  from	
  actions	
  to	
  	
   	
  

	
  

	
  

cognition:	
  Lessons	
  from	
  autism.	
  Philosophical	
  Transactions	
  of	
  the	
  Royal	
  Society,	
  Biological	
  	
  

	
  

	
  

Sciences,	
  358,	
  345-­‐360.	
  (Reprinted	
  in	
  U.	
  Frith	
  &	
  E.	
  L.	
  Hill	
  (Eds.)	
  (2004),	
  Autism:	
  Mind	
  and	
  Brain,	
  	
  

	
  

	
  

127-­‐159.	
  Oxford:	
  Oxford	
  University	
  Press.	
  Reprinted	
  in	
  F.R.	
  Volkmar,	
  R.	
  Paul,	
  A.	
  Klin,	
  &	
  D.J.	
  	
  

	
  

	
  

Cohen	
  (Eds.)	
  (2005),	
  Handbook	
  of	
  autism	
  and	
  pervasive	
  developmental	
  disorders,	
  Vol.	
  1	
  (3rd	
  	
  

	
  

	
  

ed.),	
  682-­‐703.	
  Hoboken,	
  NJ:	
  Wiley)	
  [PMID:	
  12639332]	
  

	
  

	
  

Schultz,	
  R.	
  T.,	
  Grelotti,	
  D.,	
  Klin,	
  A.,	
  Kleinman,	
  J.,	
  van	
  der	
  Gaag,	
  C.,	
  Marois,	
  R.,	
  &	
  Skudlarski,	
  P.	
  (2003).	
  	
  

	
  

	
  

The	
  role	
  of	
  the	
  fusiform	
  face	
  area	
  in	
  social	
  cognition:	
  Implications	
  for	
  the	
  pathobiology	
  of	
  	
  

	
  

	
  

autism.	
  Philosophical	
  Transactions	
  of	
  the	
  Royal	
  Society,	
  Biological	
  Sciences,	
  358,	
  415-­‐427.	
  	
  

	
  

	
  

[PMID:	
  12639338]	
  

	
  

	
  

Tsatsanis,	
  K.	
  D.,	
  Rourke,	
  B.	
  P.,	
  Klin,	
  A.,	
  Volkmar,	
  F.	
  R.,	
  Cicchetti,	
  D.,	
  &	
  Schultz,	
  R.	
  T.	
  (2003).	
  Reduced	
  	
  

	
  

	
  

thalamic	
  volume	
  in	
  high-­‐functioning	
  individuals	
  with	
  autism.	
  Biological	
  Psychiatry,	
  53(2),	
  121-­‐	
  

	
  

	
  

129.	
  [PMID:	
  12547467]	
  	
  

	
  

	
  

Chawarska,	
  K.,	
  Klin,	
  A.,	
  &	
  Volkmar,	
  F.	
  R.	
  (2003).	
  	
  Automatic	
  attention	
  cueing	
  through	
  eye	
  

	
  	
   	
  

movement	
  in	
  2-­‐year-­‐old	
  children	
  with	
  autism.	
  Child	
  Development,	
  74(4),	
  1108-­‐1122.	
  [PMID:	
  	
  

	
  

	
  

12938707]	
  

	
  

	
  

Morgan,	
  T.	
  M.,	
  Fernandez,	
  T.,	
  Davis,	
  N.,	
  Klin,	
  A.,	
  Morris,	
  A.,	
  Lifton,	
  R.	
  P.,	
  &	
  State,	
  M.	
  W.	
  (2004).	
  	
   	
  

	
  

	
  

Disruption	
  of	
  Contactin	
  4	
  (CNTN4)	
  results	
  in	
  developmental	
  delay	
  and	
  other	
  features	
  of	
  3p	
  	
  

	
  

	
  

deletion	
  syndrome.	
  The	
  American	
  Journal	
  of	
  Human	
  Genetics,	
  74(6),	
  1286-­‐93.	
  [PMID:	
  	
   	
  

	
  

	
  

15106122]	
  

	
  

	
  

Paul,	
  R.,	
  Miles,	
  S.,	
  Cicchetti,	
  D.,	
  Sparrow,	
  S.,	
  Klin,	
  A.,	
  Volkmar,	
  F.,	
  Coflin,	
  M.,	
  &	
  Booker,	
  S.	
  (2004).	
  	
  

	
  

	
  

Adaptive	
  behavior	
  in	
  autism	
  and	
  pervasive	
  developmental	
  disorder	
  –	
  not	
  otherwise	
  specified:	
  	
  

Case 2:11-cv-04027-LDD Document 48-36 Filed 07/13/12 Page 66 of 84

Ami	
  Klin,	
  PhD	
  	
  	
  	
  	
  	
  	
  	
  	
  

	
  

	
  

	
  

	
  Page	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  4	
  	
  	9
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
   	
  	
  

	
  

	
  

Microanalysis	
  of	
  scores	
  on	
  the	
  Vineland	
  Adaptive	
  Behavior	
  Scales.	
  Journal	
  of	
  Autism	
  and	
  	
  

	
  

	
  

Developmental	
  Disorders,	
  34(2),	
  223-­‐228.	
  [PMID:	
  15162940]	
  

	
  

	
  

Ozonoff,	
  S.,	
  Cook,	
  I.,	
  Coon,	
  H.,	
  Dawson,	
  G.,	
  Joseph,	
  R.	
  M.,	
  Klin,	
  A.,	
  McMahon,	
  W.	
  M.,	
  Minshew,	
  N.,	
  	
  

	
  

	
  

Munson,	
  J.	
  A.,	
  Pennington,	
  B.	
  F.,	
  Rogers,	
  S.	
  J.,	
  Spence,	
  M.	
  A.,	
  Tager-­‐Flusberg,	
  H.,	
  Volkmar,	
  F.	
  R.,	
  	
  

	
  

	
  

&	
  Wrathall,	
  D.	
  (2004).	
  Performance	
  on	
  Cambridge	
  Neuropsychological	
  Test	
  Automated	
  Battery	
  	
  

	
  

	
  

subtests	
  sensitive	
  to	
  frontal	
  lobe	
  function	
  in	
  people	
  with	
  autistic	
  disorder:	
  evidence	
  from	
  the	
  	
  

	
  

	
  

Collaborative	
  Programs	
  of	
  Excellence	
  in	
  Autism	
  Network.	
  Journal	
  of	
  Autism	
  and	
  Developmental	
  	
  

	
  

	
  

Disorders,	
  34(2),	
  139-­‐150.	
  [PMID:	
  15162933]	
  

	
  

	
  

Klin,	
  A.,	
  Chawarska,	
  K.,	
  Paul,	
  R.,	
  Rubin,	
  E.,	
  Morgan,	
  T.,	
  Wiesner,	
  L.,	
  &	
  Volkmar,	
  F.	
  R.	
  (2004).	
  Autism	
  in	
  a	
  	
  

	
  

	
  

15-­‐month-­‐old	
  child.	
  The	
  American	
  Journal	
  of	
  Psychiatry,	
  161(11),	
  1981-­‐1988.	
  [PMID:	
  15514396]	
  

	
  

	
  

Koenig,	
  K.,	
  Klin,	
  A.,	
  &	
  Schultz,	
  R.	
  T.	
  (2004).	
  Deficits	
  in	
  social	
  attribution	
  ability	
  in	
  Prader-­‐Willi	
  syndrome.	
  	
  

	
  

	
  

Journal	
  of	
  Autism	
  and	
  Developmental	
  Disorders,	
  34(5),	
  573-­‐582.	
  	
  [PMID:	
  15628610]	
  

	
  

	
  

Grelotti,	
  D.	
  J.,	
  Klin,	
  A.,	
  Volkmar,	
  F.	
  R.,	
  Gauthier,	
  I.,	
  Skudlarski,	
  P.,	
  Cohen,	
  D.	
  J.,	
  Gore,	
  J.	
  C.,	
  &	
  Schultz,	
  	
  

	
  

	
  

R.	
  T.	
  (2005).	
  fMRI	
  activation	
  of	
  the	
  fusiform	
  gyrus	
  and	
  amygdala	
  to	
  cartoon	
  characters	
  but	
  not	
  	
  

	
  

	
  

to	
  faces	
  in	
  a	
  boy	
  with	
  autism.	
  Neuropsychologia,	
  43(3),	
  373-­‐385.	
  [PMID:	
  15707614]	
  

	
  

	
  

Klin,	
  A.,	
  Pauls,	
  D.,	
  Schultz,	
  R.,	
  &	
  Volkmar,	
  F.	
  R.	
  (2005).	
  Three	
  diagnostic	
  approaches	
  to	
  Asperger	
  	
  	
  

	
  

	
  

syndrome:	
  implications	
  for	
  research.	
  Journal	
  of	
  Autism	
  and	
  Developmental	
  Disorders,	
  	
   	
  

	
  

	
  

35(2),	
  221-­‐234.	
  [PMID:	
  15909408]	
  

	
  

	
  

Woodbury-­‐Smith,	
  M.,	
  Klin,	
  A.,	
  &	
  Volkmar,	
  F.	
  R.	
  (2005).	
  Asperger’s	
  syndrome:	
  a	
  comparison	
  of	
  clinical	
  	
  

	
  

	
  

diagnoses	
  and	
  those	
  made	
  according	
  to	
  the	
  ICD-­‐10	
  and	
  DSM-­‐IV.	
  Journal	
  of	
  Autism	
  and	
  	
   	
  

	
  

	
  

Developmental	
  Disorders,	
  35(2),	
  235-­‐240.	
  [PMID:	
  15909409]	
  

	
  

	
  

O’Shea,	
  A.	
  G.,	
  Fein,	
  D.	
  A.,	
  Cillessen,	
  A.	
  H.	
  N.,	
  Klin,	
  A.,	
  &	
  Schultz,	
  R.	
  T.	
  (2005).	
  Source	
  memory	
  in	
  children	
  	
  

	
  

	
  

with	
  autism	
  spectrum	
  disorders.	
  Developmental	
  Neuropsychology,	
  27(3),	
  337-­‐360.	
  [PMID:	
  	
  

	
  

	
  

15843101]	
  

	
  

	
  

Paul,	
  R.,	
  Augustyn,	
  A.,	
  Klin,	
  A.,	
  &	
  Volkmar,	
  F.	
  R.	
  (2005).	
  Perception	
  and	
  production	
  of	
  prosody	
  by	
  	
  

	
  

	
  

speakers	
  with	
  autism	
  spectrum	
  disorders.	
  Journal	
  of	
  Autism	
  and	
  Developmental	
  Disorders,	
  	
  

	
  

	
  

35(2),	
  205-­‐220.	
  [PMID:	
  15909407]	
  

	
  

	
  

Paul,	
  R.,	
  Shriberg,	
  L.	
  D.,	
  McSweeny,	
  M.	
  S.,	
  Cicchetti,	
  D.	
  V.,	
  Klin,	
  A.,	
  &	
  Volkmar,	
  F.	
  R.	
  (2005).	
  Relations	
  	
  

	
  

	
  

between	
  prosodic	
  performance	
  and	
  communication	
  and	
  socialization	
  ratings	
  in	
  high	
  functioning	
  

	
  

	
  

speakers	
  with	
  autism	
  spectrum	
  disorders.	
  Journal	
  of	
  Autism	
  and	
  Developmental	
  Disorders,	
  	
  

	
  

	
  

35(2),	
  205-­‐220.	
  [PMID:	
  16283080]	
  

	
  

	
  

Klin,	
  A.,	
  &	
  Jones,	
  W.	
  (2006).	
  Attributing	
  social	
  and	
  physical	
  meaning	
  to	
  ambiguous	
  visual	
  displays	
  in	
  	
  

	
  

	
  

individuals	
  with	
  higher	
  functioning	
  autism	
  spectrum	
  disorders.	
  Brain	
  and	
  Cognition,	
  61,	
  40-­‐53.	
  	
  

	
  

	
  

[PMID:	
  16497422]	
  

Case 2:11-cv-04027-LDD Document 48-36 Filed 07/13/12 Page 67 of 84

Ami	
  Klin,	
  PhD	
  	
  	
  	
  	
  	
  	
  	
  	
  

	
  

	
  

	
  

	
  Page	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  5	
  	
  	0
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
   	
  	
  

	
  

	
  

White,	
  S.	
  W.,	
  Scahill,	
  L.,	
  Klin,	
  A.,	
  Koenig,	
  K.,	
  &	
  Volkmar,	
  F.	
  R.	
  (2007).	
  Educational	
  placements	
  and	
  service	
  

	
  

	
  

use	
  patterns	
  of	
  individuals	
  with	
  autism	
  spectrum	
  disorders.	
  Journal	
  of	
  Autism	
  and	
  	
   	
  

	
  

	
  

Developmental	
  Disorders,	
  37(8),	
  1403-­‐12.	
  [PMID:	
  17082975]	
  

	
  

	
  

Saulnier,	
  C.	
  A.,	
  &	
  Klin,	
  A.	
  (2007).	
  Social	
  and	
  communication	
  abilities	
  and	
  disabilities	
  in	
  higher	
  	
   	
  

	
  

	
  

functioning	
  individuals	
  with	
  autism	
  and	
  Asperger	
  syndrome.	
  Journal	
  of	
  Autism	
  and	
  	
   	
  

	
  

	
  

Developmental	
  Disorders,	
  37(4),	
  788-­‐93.	
  [PMID:	
  17160458]	
  

	
  

	
  

Klin,	
  A.,	
  Saulnier,	
  C.	
  A.,	
  Sparrow,	
  S.	
  S.,	
  Cicchetti,	
  D.	
  V.,	
  Volkmar,	
  F.	
  R.,	
  &	
  Lord,	
  C.	
  (2007).	
  Social	
  and	
  	
  

	
  

	
  

communication	
  abilities	
  and	
  disabilities	
  in	
  higher	
  functioning	
  individuals	
  with	
  autism	
  spectrum	
  	
  

	
  

	
  

disorders.	
  Journal	
  of	
  Autism	
  and	
  Developmental	
  Disorders,	
  37(4),	
  748-­‐59.	
  [PMID:	
  17146708]	
  

	
  

	
  

Chawarska,	
  K.,	
  Klin,	
  A.,	
  Paul,	
  R.,	
  &	
  Volkmar,	
  F.	
  R.	
  (2007).	
  Autism	
  spectrum	
  disorders	
  in	
  the	
  second	
  	
  

	
  

	
  

year:	
  stability	
  and	
  change	
  in	
  syndrome	
  expression.	
  The	
  Journal	
  of	
  Child	
  Psychology	
  and	
  	
   	
  

	
  

	
  

Psychiatry,	
  48(2),	
  128-­‐	
  138.	
  [PMID:	
  17300551]	
  

	
  

	
  

Kleinman,	
  J.	
  M.,	
  Ventola,	
  P.	
  E.,	
  Pandey,	
  J.,	
  Boorstein,	
  H.	
  C.,	
  Esser,	
  E.	
  L.,	
  Wilson,	
  L.	
  B.,	
  Rosenthal,	
  M.	
  A.,	
  	
  

	
  

	
  

Sutera,	
  S.,	
  Verbalis,	
  A.	
  D.,	
  Marshia,	
  G.,	
  Baron,	
  M.,	
  Hodgson,	
  S.,	
  Green,	
  J.,	
  Dumont-­‐Mathieu,	
  T.	
  	
  

	
  

	
  

M.,	
  Robins,	
  D.	
  L.,	
  Volkmar,	
  F.	
  R.,	
  Klin,	
  A.,	
  &	
  Fein,	
  D.	
  (2007).	
  The	
  Modified	
  Checklist	
  for	
  Autism	
  in	
  	
  

	
  

	
  

Toddlers:	
  A	
  follow-­‐up	
  study	
  investigating	
  the	
  early	
  detection	
  of	
  autism	
  spectrum	
  	
 	 
  

	
  

	
  

	
  

disorders.	
  Journal	
  of	
  Autism	
  and	
  Developmental	
  Disorders,	
  38(5),	
  827-­‐839.	
  [PMID:	
  17882539]	
  

	
  

	
  

Chawarska,	
  K.,	
  Paul,	
  R.,	
  Klin,	
  A.,	
  Hannigen,	
  S.,	
  Dichtel,	
  L.	
  E.,	
  &	
  Volkmar,	
  F.	
  R.	
  (2007).	
  Parental	
  	
   	
  

	
  

	
  

recognition	
  of	
  developmental	
  problems	
  in	
  toddlers	
  with	
  autism	
  spectrum	
  disorders.	
  Journal	
  of	
  	
  

	
  

	
  

Autism	
  and	
  Developmental	
  Disorders,	
  37(1),	
  62-­‐72.	
  [PMID:	
  17195921]	
  

	
  

	
  

Cicchetti,	
  D.	
  V.,	
  Lord,	
  C.,	
  Koenig,	
  K.,	
  Klin,	
  A.,	
  &	
  Volkmar,	
  F.	
  R.	
  	
  (2007).	
  Reliability	
  of	
  the	
  ADI-­‐R:	
  Multiple	
  	
  

	
  

	
  

examiners	
  evaluate	
  a	
  single	
  case.	
  Journal	
  of	
  Autism	
  and	
  Developmental	
  Disorders,	
  38(4),	
  764-­‐	
  

	
  

	
  

770.	
  [PMID:	
  18058216]	
  

	
  

	
  

Klin,	
  A.,	
  Danovitch,	
  J.	
  H.,	
  Dohrmann,	
  E.	
  H.,	
  Merz,	
  A.	
  B.,	
  &	
  Volkmar,	
  F.	
  R.	
  (2007).	
  Circumscribed	
  interests	
  	
  

	
  

	
  

in	
  higher-­‐functioning	
  individuals	
  with	
  autism	
  spectrum	
  disorders:	
  an	
  exploratory	
  study.	
  	
  	
  	
  

	
  

	
  

Research	
  and	
  Practice	
  for	
  Persons	
  with	
  Severe	
  Disabilities,	
  32(2),	
  89-­‐100.	
  	
  

	
  

	
  

Bakkaloglu,	
  B.,	
  O’Roak,	
  B.	
  J.,	
  Louvi,	
  A.,	
  Gupta,	
  A.	
  R.,	
  Abelson,	
  J.	
  F.,	
  Morgan,	
  T.	
  M.,	
  Chawarska,	
  K.,	
  Klin,	
  	
  

	
  

	
  

A.,	
  Ercan-­‐Sencicek,	
  G.,	
  Stillman,	
  A.	
  A.,	
  Tanriover,	
  G.,	
  Abrahams,	
  B.	
  S.,	
  Duvall,	
  J.	
  A.,	
  Robbins,	
  E.J.,	
  	
  

	
  

	
  

Geschwind,	
  D.	
  H.,	
  Biederer,	
  T.,	
  Gunel,	
  M.,	
  Lifton,	
  R.	
  P.,	
  &	
  State,	
  M.	
  W.	
  (2008).	
  Molecular	
  	
  	
  

	
  

	
  

cytogenetic	
  analysis	
  and	
  resequencing	
  of	
  Contactin	
  Associated	
  Protein-­‐Like	
  2	
  in	
  autism	
  	
   	
  

	
  

	
  

spectrum	
  disorders.	
  The	
  American	
  Journal	
  of	
  Human	
  Genetics,	
  82,	
  165-­‐173.	
  [PMCID:	
  	
   	
  

	
  

	
  

PMC2253974]	
  [PMID:	
  18179895]	
  

	
  

	
  

Kim,	
  H.	
  G.,	
  Kishikawa,	
  S.,	
  Higgins,	
  A.,	
  Seong,	
  I-­‐S.,	
  Donovan,	
  D.,	
  Shen,	
  Y.,	
  Lally,	
  E.,	
  Weiss,	
  L.,	
  Najm,	
  J.,	
  	
  

	
  

	
  

Kutsche,	
  K.,	
  Descartes,	
  M.,	
  Holt,	
  L.,	
  Braddock,	
  S.,	
  Troxell,	
  R.,	
  Kaplan,	
  L.,	
  Volkmar,	
  F.,	
  Klin,	
  A.,	
  	
  

Case 2:11-cv-04027-LDD Document 48-36 Filed 07/13/12 Page 68 of 84

Ami	
  Klin,	
  PhD	
  	
  	
  	
  	
  	
  	
  	
  	
  

	
  

	
  

	
  

	
  Page	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  5	
  	
  	1
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
   	
  	
  

	
  

	
  

Tsatsanis,	
  K.,	
  Noens,	
  I.,	
  Pauls,	
  D.,	
  Daly,	
  M.	
  J.,	
  MacDonald,	
  M.	
  E.,	
  Morton,	
  C.C.,	
  Quade,	
  B.	
  J.,	
  &	
  	
  

	
  

	
  

Gusella,	
  J.	
  F.	
  (2008).	
  Disruption	
  of	
  neurexin	
  1	
  (NRXN1)	
  associated	
  with	
  autism	
  spectrum	
  	
   	
  

	
  

	
  

disorder.	
  Journal	
  of	
  Human	
  Genetics,	
  82,	
  199-­‐207.	
  [PMID:	
  18179900]	
  

	
  

	
  

Paul,	
  R.,	
  Bianchi,	
  N.,	
  Augustyn,	
  A.,	
  Klin,	
  A.,	
  &	
  Volkmar,	
  F.	
  R.	
  (2008).	
  	
  Production	
  of	
  syllable	
  stress	
  in	
  	
  

	
  

	
  

speakers	
  with	
  autism	
  spectrum	
  disorders.	
  Research	
  in	
  Autism	
  Spectrum	
  Disorders,	
  2,	
  110-­‐124.	
  	
  

	
  

	
  

[PMCID:	
  PMC2662623]	
  [PMID:	
  19337577]	
  

	
  

	
  

Klin,	
  A.,	
  &	
  Jones,	
  W.	
  (2008).	
  Altered	
  face	
  scanning	
  and	
  impaired	
  recognition	
  of	
  biological	
  motion	
  in	
  a	
  	
  

	
  

	
  

15-­‐month-­‐old	
  infant	
  with	
  autism.	
  Developmental	
  Science,	
  11(1),	
  40-­‐6.	
  [PMID:	
  18171365]	
  

	
  

	
  

Jones,	
  W.,	
  Carr,	
  K.,	
  &	
  Klin,	
  A.	
  (2008).	
  Absence	
  of	
  preferential	
  looking	
  to	
  the	
  eyes	
  of	
  approaching	
  adults	
  	
  

	
  

	
  

predicts	
  level	
  of	
  social	
  disability	
  in	
  2-­‐year-­‐olds	
  with	
  autism.	
  Archives	
  of	
  General	
  Psychiatry,	
  	
  

	
  

	
  

65(8),	
  946-­‐54.	
  [PMID:	
  18678799]	
  

	
  	
  

	
  

Vanbergeijk,	
  E.,	
  Klin,	
  A.,	
  &	
  Volkmar,	
  F.	
  R.	
  (2008).	
  Supporting	
  more	
  able	
  students	
  on	
  the	
  autism	
  	
   	
  

	
  

	
  

spectrum:	
  college	
  and	
  beyond.	
  Journal	
  of	
  Autism	
  and	
  Developmental	
  Disorders,	
  38(7),	
  1359-­‐70.	
  	
  

	
  

	
  

[PMID:	
  18172747]	
  

	
  

	
  

Reichow,	
  B.,	
  Salamak,	
  S.,	
  Paul,	
  R.,	
  Volkmar,	
  F.	
  R.,	
  &	
  Klin,	
  A.	
  (2008).	
  Pragmatic	
  assessment	
  in	
  	
  

	
  

	
  

speakers	
  with	
  autism	
  spectrum	
  disorders:	
  a	
  comparison	
  of	
  a	
  standard	
  measure	
  with	
  parent	
  	
  

	
  

	
  

report.	
  Communication	
  Disorders	
  Quarterly,	
  29(3),	
  169-­‐176.	
  [PMCID:	
  PMC2952952]	
  [PMID:	
  	
  

	
  

	
  

20948979]	
  

	
  

	
  

Goldstein,	
  G.,	
  Allen,	
  D.	
  N.,	
  Minshew,	
  N.	
  J.,	
  Williams,	
  D.	
  L.,	
  Volkmar,	
  F.	
  R.,	
  Klin,	
  A.,	
  &	
  Schultz,	
  R.	
  T.	
  (2008).	
  

	
  

	
  

The	
  structure	
  of	
  intelligence	
  in	
  children	
  and	
  adults	
  with	
  high	
  functioning	
  autism.	
  	
  	
  

	
  

	
  

	
  

Neuropsychology,	
  22(3),	
  301-­‐12.	
  [PMID:	
  18444708]	
  

	
  

	
  

Pandey,	
  J.,	
  Verbalis,	
  A.,	
  Robins,	
  D.	
  L.,	
  Boorstein,	
  H.,	
  Klin,	
  A.,	
  Babitz,	
  T.,	
  Chawarska,	
  K.,	
  Volkmar,	
  F.,	
  	
  

	
  

	
  

Green,	
  J.,	
  Barton,	
  M.,	
  &	
  Fein,	
  D.	
  (2008).	
  Screening	
  for	
  autism	
  in	
  older	
  and	
  younger	
  toddlers	
  with	
  

	
  

	
  

the	
  Modified	
  Checklist	
  for	
  Autism	
  in	
  Toddlers.	
  Autism,	
  12(5),	
  513-­‐35.	
  [PMID:	
  18805945]	
  

	
  

	
  

Fernandez,	
  T.,	
  Morgan,	
  T.	
  M.,	
  Davis,	
  N.,	
  Klin,	
  A.,	
  Morris,	
  A.,	
  Farhi,	
  A.,	
  Lifton,	
  R.	
  P.,	
  &	
  State,	
  M.	
  W.	
  	
  

	
  

	
  

(2008).	
  Disruption	
  of	
  Contactin	
  4	
  (CNTN4)	
  results	
  in	
  developmental	
  delay	
  and	
  other	
  features	
  of	
  	
  

	
  

	
  

3p	
  deletion	
  syndrome.	
  American	
  Journal	
  of	
  Human	
  Genetics,	
  82(6),	
  1385.	
  [PMCID:	
  	
   	
  

	
  

	
  

PMC2661627]	
  [PMID:	
  18551756]	
  

	
  

	
  

Klin,	
  A.,	
  Lin,	
  D.	
  J.,	
  Gorrindo,	
  P.,	
  Ramsay,	
  G.,	
  &	
  Jones,	
  W.	
  (2009).	
  Two-­‐year-­‐olds	
  with	
  autism	
  fail	
  to	
  orient	
  	
  

	
  

	
  

towards	
  human	
  biological	
  motion	
  but	
  attend	
  instead	
  to	
  non-­‐social,	
  physical	
  contingencies.	
  	
  

	
  

	
  

Nature,	
  459,	
  257-­‐261.	
  [PMCID:	
  PMC2758571]	
  [PMID:	
  19329996]	
  

	
  

	
  

Chawarska,	
  K.,	
  Klin,	
  A.,	
  Paul,	
  R.,	
  Macari,	
  S.,	
  &	
  Volkmar,	
  F.	
  (2009).	
  A	
  prospective	
  study	
  of	
  toddlers	
  with	
  	
  

	
  

	
  

autism	
  spectrum	
  disorders:	
  Short-­‐term	
  diagnostic	
  and	
  cognitive	
  outcomes.	
  Journal	
  of	
  Child	
  	
  

	
  

	
  

Psychology	
  &	
  Psychiatry,	
  50(10),	
  1235-­‐1245.	
  [PMID:	
  19594835]	
  

Case 2:11-cv-04027-LDD Document 48-36 Filed 07/13/12 Page 69 of 84

Ami	
  Klin,	
  PhD	
  	
  	
  	
  	
  	
  	
  	
  	
  

	
  

	
  

	
  

	
  Page	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  5	
  	
  	2
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
   	
  	
  

	
  

	
  

Wang,	
  K.,	
  Zhang,	
  H.,	
  Ma,	
  D.,	
  Bucan,	
  M.,	
  Glessner,	
  G.T.,	
  Abrahams,	
  B.	
  S.,	
  Salyakina,	
  D.,	
  Imielinski,	
  M.,	
  	
  

	
  

	
  

Bradfield,	
  J.	
  P.,	
  Sleiman,	
  P.	
  M.	
  A.,	
  Kim,	
  C.	
  E.,	
  Chiavacci,	
  R.,	
  Takahashi,	
  N.,	
  Sakurai,	
  T.,	
  Rappaport,	
  	
  

	
  

	
  

E.,	
  Lajonchere,	
  C.	
  A.,	
  Munson,	
  J.,	
  Estes,	
  A.,	
  Korvatska,	
  O.,	
  Piven,	
  J.,	
  Sonnenblick,	
  L.	
  I.,	
  Retuerto,	
  	
  

	
  

	
  

A.	
  I.	
  A.,	
  Herman,	
  E.	
  I.,	
  Dong,	
  H.,	
  Hutman,	
  T.,	
  Sigman,	
  M.,	
  Ozonoff,	
  S.,	
  Klin,	
  A.,	
  Owley,	
  T.,	
  	
   	
  

	
  

	
  

Sweeney,	
  J.	
  A.,	
  Brune,	
  C.	
  W.,	
  Cantor,	
  R.,	
  Bernier,	
  R.,	
  Gilbert,	
  J.	
  R.,	
  Cuccaro,	
  M.	
  L.,	
  Wassink,	
  T.	
  H.,	
  	
  

	
  

	
  

McMahon,	
  W.	
  M.,Coon,	
  H.,	
  Miller,	
  J.,	
  Nurnberger,	
  Jr.,	
  State,	
  M.	
  W.,	
  Haines,	
  J.	
  L.,	
  Levy,	
  S.	
  E.,	
  	
  

	
  

	
  

Sutcliffe,	
  J.	
  S.,	
  Cook,	
  E.	
  H.,	
  Minshew,	
  N.	
  J.,	
  Buxbaum,	
  J.	
  D.,	
  Dawson,	
  G.,	
  Grant,	
  S.	
  F.	
  A.,	
  	
   	
  

	
  

	
  

Geschwind,	
  D.	
  H.,	
  Pericak-­‐Vance,	
  M.	
  A.,	
  Schellenberg,	
  G.	
  D.,	
  &	
  Hakonarson,	
  H.	
  (2009).	
  Common	
  	
  

	
  

	
  

genetic	
  variation	
  in	
  the	
  intergenic	
  region	
  between	
  CDH10	
  and	
  CDH9	
  is	
  associated	
  with	
  	
   	
  

	
  

	
  

susceptibility	
  to	
  autism	
  spectrum	
  disorders.	
  Nature,	
  459(7246),	
  528-­‐33.	
  [PMID:	
  19404256]	
  

	
  

	
  

New,	
  J.	
  J.,	
  Schultz,	
  R.	
  T.,	
  Wolf,	
  J.,	
  Niehaus,	
  J.	
  L.,	
  Klin,	
  A.,	
  German,	
  T.	
  C.,	
  &	
  Scholl,	
  B.	
  J.	
  (2010).	
  The	
  scope	
  	
  

	
  

	
  

of	
  social	
  attention	
  deficits	
  in	
  autism:	
  Prioritized	
  orienting	
  to	
  people	
  and	
  animals	
  in	
  static	
  natural	
  

	
  

	
  

scenes.	
  Neuropsychologia,	
  48,	
  51-­‐59.	
  [PMID:	
  19686766]	
  

	
  

	
  

White,	
  S.	
  W.,	
  Albano,	
  A.	
  M.,	
  Johnson,	
  C.,	
  Kasari,	
  C.,	
  Ollendick,	
  T.,	
  Klin,	
  A.,	
  Oswald,	
  D.,	
  &	
  Scahill,	
  L.	
  	
  

	
  

	
  

(2010).	
  Development	
  of	
  a	
  cognitive-­‐behavioral	
  intervention	
  program	
  to	
  treat	
  anxiety	
  and	
  	
  

	
  

	
  

social	
  deficits	
  in	
  teens	
  with	
  high-­‐functioning	
  autism.	
  Clinical	
  Child	
  and	
  Family	
  Psychology	
  	
  

	
  

	
  

Review,	
  13(1),	
  77-­‐90.	
  [PMID:	
  200091348]	
  

	
  

	
  

Chawarska,	
  K.,	
  Volkmar,	
  F.,	
  &	
  Klin,	
  A.	
  (2010).	
  Limited	
  attentional	
  bias	
  for	
  faces	
  in	
  toddlers	
  with	
  autism	
  	
  

	
  

	
  

spectrum	
  disorders.	
  Archives	
  of	
  General	
  Psychiatry,	
  67(2),	
  178-­‐185.	
  [PMID:	
  201241117]	
  	
   	
  

	
  

	
  

Kaiser,	
  M.	
  D.,	
  Hudac,	
  C.	
  M.,	
  Shultz,	
  S.,	
  Lee,	
  S.	
  M.,	
  Cheung,	
  C.,	
  Berken,	
  A.	
  M.,	
  Deen,	
  B.,	
  Pitskel,	
  N.	
  B.,	
  	
  

	
  

	
  

Sugrue,	
  D.	
  R.,	
  Voos,	
  A.	
  C.,	
  Saulnier,	
  C.	
  A.,	
  Ventola,	
  P.,	
  Wolf,	
  J.	
  M.,	
  Klin,	
  A.,	
  Vander	
  Wyk,	
  B.	
  C.,	
  &	
  	
  

	
  

	
  

Pelphrey,	
  K.	
  A.	
  (2010).	
  Neural	
  signatures	
  of	
  autism.	
  Proceedings	
  of	
  the	
  National	
  Academy	
  of	
  	
  

	
  

	
  

Sciences,	
  107(49),	
  21223-­‐8.	
  [PMID:	
  21078973]	
  	
  

	
  

	
  

Vander	
  Wyk,	
  B.	
  C.,	
  Ramsay,	
  G.	
  J.,	
  Hudac,	
  C.	
  M.,	
  Jones,	
  W.,	
  Lin,	
  D.,	
  Klin,	
  A.,	
  Lee,	
  S.	
  M.,	
  &	
  Pelphrey,	
  K.	
  A.	
  	
  

	
  

	
  

(2010).	
  Cortical	
  integration	
  of	
  audio-­‐visual	
  information.	
  Brain	
  Cognition,	
  74(2),	
  97-­‐106.	
  [PMID	
  	
  

	
  

	
  

20709442]	
  

	
  

	
  

Paul,	
  R.,	
  Fuerst,	
  Y.,	
  Ramsay,	
  G.,	
  Chawarska,	
  K.,	
  &	
  Klin,	
  A.	
  (2011).	
  Out	
  of	
  the	
  mouths	
  of	
  babes:	
  vocal	
  	
  

	
  

	
  

production	
  in	
  infant	
  siblings	
  of	
  children	
  with	
  ASD.	
  Journal	
  of	
  Child	
  Psychology	
  &	
  Psychiatry,	
  	
  

	
  

	
  

52(5),	
  588-­‐98.	
   doi:10.1111.	
  [PMID:	
  21039489]	
  

	
  

	
  

Shic,	
  F.,	
  Bradshaw,	
  J.,	
  Klin,	
  A.,	
  Scassellati,	
  B.,	
  &	
  Chawarska,	
  K.	
  (2011).	
  Limited	
  activity	
  monitoring	
  in	
  	
  

	
  

	
  

toddlers	
  with	
  autism	
  spectrum	
  disorder.	
  Brain	
  Research,	
  1380,	
  246-­‐254.	
  doi:	
  	
   	
  

	
  

	
  

	
  

10.1016/jbrainres.2010.11.074.	
  [PMID:	
  21129365]	
  	
  

	
  

	
  

Chawarska,	
  K.,	
  Campbell,	
  D.,	
  Chen,	
  L.,	
  Shic,	
  F.,	
  Klin,	
  A.	
  &	
  Chang,	
  J.	
  (2011).	
  Early	
  generalized	
  overgrowth	
  	
  

	
  

	
  

in	
  boys	
  with	
  autism.	
  Archives	
  of	
  General	
  Psychiatry,	
  68(10),	
  1021-­‐31.	
  [PMID	
  21969460]	
  	
  

	
  

Case 2:11-cv-04027-LDD Document 48-36 Filed 07/13/12 Page 70 of 84

Ami	
  Klin,	
  PhD	
  	
  	
  	
  	
  	
  	
  	
  	
  

	
  

	
  

	
  

	
  Page	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  5	
  	
  	3
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
   	
  	
  

	
  

McPartland,	
  J.	
  C.,	
  Wu,	
  J.,	
  Bailey,	
  C.	
  A.,	
  Mayes,	
  L.	
  C.,	
  Schultz,	
  R.	
  T.,	
  &	
  Klin,	
  A.	
  (2011).	
  Atypical	
  neural	
  	
  

	
  

	
  

specialization	
  for	
  social	
  percepts	
  in	
  autism	
  spectrum	
  disorder.	
  Social	
  Neuroscience,	
  6(5-­‐6),	
  436-­‐	
  

	
  

	
  

51.	
  [PMID	
  21777159]	
  	
  

	
  

	
  

Shultz,	
  S.,	
  &	
  Klin,	
  A.,	
  &	
  Jones,	
  W.	
  (2011).	
  	
  Inhibition	
  of	
  eye	
  blinking	
  reveals	
  subjective	
  perceptions	
  of	
  	
  

	
  

	
  

stimulus	
  salience.	
  Proceedings	
  of	
  the	
  National	
  Academy	
  of	
  Sciences,	
  108(52),	
  21270-­‐5.	
  [PMID	
  	
  

	
  

	
  

22160686]	
  	
  

	
  

	
  

Tsatsanis,	
  K.	
  D.,	
  Noens,	
  I.	
  L.	
  J.,	
  Illmann,	
  C.	
  L.,	
  Pauls,	
  D.	
  L.,	
  Volkmar,	
  F.	
  R.,	
  Schultz,	
  R.	
  T.,	
  &	
  Klin,	
  A.	
  (2011).	
  

	
  

	
  

Managing	
  complexity:	
  impact	
  of	
  organization	
  and	
  processing	
  style	
  on	
  nonverbal	
  memory	
  in	
  	
  

	
  

	
  

autism	
  spectrum	
  disorders.	
  Journal	
  of	
  Autism	
  Developmental	
  Disorders,	
  41(2),	
  135-­‐47.	
  [PMID:	
  	
  

	
  

	
  

21128108]	
  

	
  

	
  

Ventola,	
  P.,	
  Saulnier,	
  C.,	
  Steinberg,	
  E.,	
  Chawarska,	
  K.,	
  &	
  Klin,	
  A.	
  (2011).	
  Early-­‐Emerging	
  Social	
  Adaptive	
  	
  

	
  

	
  

Skills	
  in	
  Toddlers	
  with	
  Autism	
  Spectrum	
  Disorders:	
  An	
  Item	
  Analysis.	
  Journal	
  of	
  Autism	
  and	
  	
  

	
  

	
  

Developmental	
  Disorders	
  [DOI:	
  10.1007/s10803-­‐011-­‐1278-­‐x]	
  online	
  first	
  

	
  

	
  

Rice,	
  K.,	
  Moriuchi,	
  J.,	
  Jones,	
  W.,	
  &	
  Klin,	
  A.	
  (2012).	
  Parsing	
  heterogeneity	
  in	
  autism	
  spectrum	
  disorders:	
  	
  

	
  

	
  

visual	
  scanning	
  of	
  dynamic	
  social	
  scenes	
  in	
  school-­‐age	
  children.	
  Journal	
  of	
  the	
  American	
  	
  	
  

	
  

	
  

Academy	
  of	
  Child	
  and	
  Adolescent	
  Psychiatry,	
  (51)3,	
  238-­‐248.	
  

	
  

	
  

Macari,	
  S.	
  L.,	
  Campbell,	
  D.,	
  Grace,	
  W.G.,	
  Saulnier,	
  C.,	
  Klin,	
  A.,	
  &	
  Chawarska,	
  K.	
  (2012).	
  Predicting	
  	
  

	
  

	
  

Developmental	
  Status	
  from	
  12	
  to	
  24	
  Months	
  in	
  Infants	
  at	
  Risk	
  for	
  Autism	
  Spectrum	
  Disorder:	
  A	
  	
  

	
  

	
  

Preliminary	
  Report.	
  Journal	
  of	
  Autism	
  and	
  Developmental	
  Disorders,	
  37(1).	
  [PMID:	
  22484794]	
  	
  

	
  

	
  

[epub	
  ahead	
  of	
  print]	
  

	
  

	
  

	
  

Lord,	
  C.,	
  Petkova,	
  E.,	
  Hus,	
  V.,	
  Gan,	
  W.,	
  Lu,	
  F.,	
  Martin,	
  D.	
  M.,	
  Ousley,	
  O.,	
  Guy,	
  L.,	
  Bernier,	
  R.,	
  Gerdts,	
  J.,	
  	
  

	
  

	
  

Algermissen,	
  M.,	
  Whitaker,	
  A.,	
  Sutcliffe,	
  J.,	
  Warren,	
  Z.,	
  Klin,	
  A.,	
  Saulnier,	
  C.,	
  Hanson,	
  E.,	
  Hundley,	
  

	
  

	
  

R.,	
  Piggot,	
  J.,	
  Fombonne,	
  E.,	
  Steiman,	
  M.,	
  Miles,	
  J.,	
  Kanne,	
  S.,	
  Goin-­‐Kochel,	
  R.	
  P.,	
  Peters,	
  S.	
  U.,	
  	
  

	
  

	
  

Cook	
  ,	
  E.	
  H.,	
  Guter,	
  S.,	
  Tjernagle,	
  J.,	
  Green-­‐Snyder,	
  L.,	
  Bishop,	
  S.,	
  Esler,	
  A.,	
  Gotham,	
  K.,	
  Lyuster,	
  	
  

	
  

	
  

R.,	
  Miller,	
  F.,	
  Olson,	
  J.,	
  Richler,	
  J.,	
  &	
  Risi,	
  S.	
  (2012).	
  A	
  Multisite	
  Study	
  of	
  the	
  Clinical	
  Diagnosis	
  of	
  	
  

	
  

	
  

Different	
  Autism	
  Spectrum	
  Disorders.	
  Archives	
  of	
  General	
  Psychiatry,	
  69	
  (3).	
  [epub	
  ahead	
  of	
  	
  

	
  

	
  

print]	
  

	
  

	
  

Steiner,	
  A.	
  M.,	
  Gengoux,	
  G.	
  W.,	
  Klin,	
  A.,	
  &	
  Chawarska,	
  K.	
  (2012).	
  Pivotal	
  Response	
  Treatment	
  for	
  Infants	
  

	
  

	
  

At-­‐Risk	
  for	
  Autism	
  Specturm	
  Disorders:	
  A	
  Pilot	
  Study.	
  	
  Journal	
  of	
  Autism	
  and	
  Developmental	
  	
  

	
  

	
  

Disorders.	
  [PMID:	
  22573001]	
  [epub	
  ahead	
  of	
  print]	
  

	
  

	
  

b.	
   Manuscripts	
  submitted	
  or	
  in	
  preparation:	
  

	
  

	
  

Jones,	
  W.,	
  &	
  Klin	
  A.	
  	
  Entrainment	
  to	
  social	
  context	
  in	
  typically-­‐developing	
  two-­‐year-­‐olds	
  and	
  the	
  	
  

	
  

	
  

absence	
  thereof	
  in	
  autism.	
  

	
  

Case 2:11-cv-04027-LDD Document 48-36 Filed 07/13/12 Page 71 of 84

Ami	
  Klin,	
  PhD	
  	
  	
  	
  	
  	
  	
  	
  	
  

	
  

	
  

	
  

	
  Page	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  5	
  	
  	4
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
   	
  	
  

	
  

Klin,	
  A.,	
  &	
  Jones,	
  W.	
  The	
  development	
  of	
  social	
  visual	
  engagement	
  from	
  birth	
  until	
  age	
  three.	
  

	
  

	
  

Jones,	
  W.,	
  &	
  Klin,	
  A.	
  Diagnostic	
  indicators	
  of	
  autism	
  in	
  the	
  first	
  6	
  months	
  of	
  life.	
  

	
  

	
  

Jones,	
  W.,	
  Knoch,	
  K.,	
  &	
  Klin,	
  A.	
  Shifting	
  visual	
  attention	
  in	
  adolescents	
  with	
  autism:	
  reaction	
  times	
  are	
  	
  

	
  

	
  

equivalent	
  but	
  first	
  fixations	
  are	
  random.	
  

	
  

	
  

Knoch,	
  K.,	
  Klin,	
  A.,	
  &	
  Jones,	
  W.	
  Shifting	
  visual	
  attention	
  in	
  school-­‐age	
  children	
  with	
  autism.	
  

	
  

	
  

	
  

Jones,	
  W.,	
  Zampella,	
  C.,	
  &	
  Klin,	
  A.	
  	
  Oculomotor	
  function	
  in	
  children	
  with	
  ASD	
  during	
  a	
  natural	
  viewing	
  	
  

	
  

	
  

task.	
  

	
  

	
  

Jones,	
  W.,	
  Krasno,	
  A.,	
  &	
  Klin,	
  A.	
  	
  Measures	
  of	
  implicit	
  social	
  attribution	
  by	
  visual	
  scanning	
  in	
  children	
  	
  

	
  

	
  

with	
  autism.	
  

	
  

	
  

Jones,	
  W.,	
  Edwards,	
  L.	
  A.,	
  and	
  &	
  Klin,	
  A.	
  Visual	
  scanning	
  of	
  dynamic	
  faces	
  in	
  relation	
  to	
  varying	
  	
   	
  

	
  

	
  

positive	
  and	
  negative	
  affect.	
  	
  

	
  

	
  

Shultz,	
  S.,	
  Jones,	
  W.,	
  Klin,	
  A.,	
  &	
  McPartland,	
  J.	
  	
  Social	
  context	
  modulates	
  neural	
  responses	
  to	
  human	
  	
  

	
  

	
  

faces.	
  

	
  

	
  

Sharp,	
  W.	
  G.,	
  Berry,	
  R.	
  C.,	
  McCracken,	
  C.,	
  Nuhu,	
  N.	
  N.,	
  Marvel,	
  E.,	
  Saulnier,	
  C.,	
  Klin,	
  A.,	
  Jones,	
  W.,	
  &	
  	
  

	
  

	
  

Jaquess,	
  D.	
  Feeding	
  problems	
  and	
  nutrient	
  intake	
  in	
  children	
  with	
  autism	
  spectrum	
  disorders:	
  A	
  	
  

	
  

	
  

meta-­‐analysis	
  and	
  comprehensive	
  review	
  of	
  the	
  literature.	
  

	
  

	
  

c.	
  	
   Editorials,	
  case	
  reports,	
  letters,	
  book	
  forewords,	
  book	
  reviews	
  :	
  

	
  

	
  

Klin,	
  A.,	
  &	
  Volkmar,	
  F.	
  R.	
  (1993).	
  Elective	
  mutism	
  and	
  mental	
  retardation.	
  Journal	
  of	
  the	
  American	
  	
  

	
  

	
  

Academy	
  of	
  Child	
  and	
  Adolescent	
  Psychiatry,	
  32(4),	
  860-­‐864.	
  [PMID:	
  8340310]	
  

	
  

	
  

Volkmar,	
  F.	
  R.,	
  Klin,	
  A.,	
  Schultz,	
  R.	
  B.,	
  Bronen,	
  R.,	
  Marans,	
  W.	
  D.,	
  Sparrow,	
  S.	
  S.,	
  &	
  Cohen,	
  D.	
  J.	
  (1996).	
  

	
  

	
  

Asperger’s	
  syndrome.	
  Journal	
  of	
  the	
  American	
  Academy	
  of	
  Child	
  and	
  Adolescent	
  Psychiatry,	
  	
  

	
  

	
  

35(1),	
  118-­‐123.	
  [PMID:	
  8567603]	
  

	
  

	
  

Volkmar,	
  F.	
  R.,	
  Klin,	
  A.,	
  Schultz,	
  R.,	
  Rubin,	
  E.,	
  &	
  Bronen,	
  R.	
  (2000).	
  Asperger’s	
  disorder.	
  American	
  	
  

	
  

	
  

Journal	
  of	
  Psychiatry,	
  157(2),	
  262-­‐267.	
  [PMID:	
  10671397]	
  

	
  

	
  

Klin,	
  A.,	
  Schultz,	
  R.,	
  Rubin,	
  E.,	
  Bronen,	
  R.,	
  &	
  Volkmar,	
  F.	
  (2001).	
  Asperger’s	
  disorder:	
  Dr.	
  Klin	
  and	
  	
  

	
  

	
  

colleagues	
  reply.	
  American	
  Journal	
  of	
  Psychiatry,	
  158(3),	
  502-­‐503.	
  

	
  

	
  

Volkmar,	
  F.	
  R.	
  &	
  Klin,	
  A.	
  (2001).	
  Forward.	
  In	
  L.	
  Wing	
  (Ed.)	
  The	
  Autistic	
  Spectrum:	
  A	
  Parent’s	
  Guide	
  to	
  	
  

	
  

	
  

Understanding	
  and	
  Helping	
  Your	
  Child	
  (pp.	
  	
  ix).	
  Berkley,	
  CA:	
  Ulysses	
  Press,	
  2001.	
  	
  

	
  

Case 2:11-cv-04027-LDD Document 48-36 Filed 07/13/12 Page 72 of 84

Ami	
  Klin,	
  PhD	
  	
  	
  	
  	
  	
  	
  	
  	
  

	
  

	
  

	
  

	
  Page	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  5	
  	
  	5
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
   	
  	
  

	
  

Volkmar,	
  F.	
  R.,	
  Anderson,	
  G.	
  M.,	
  Klin,	
  A.,	
  &	
  Paul,	
  R.	
  (2002).	
  Obituary:	
  Donald	
  J.	
  Cohen	
  1940-­‐2001.	
  	
  

	
  

	
  

Journal	
  of	
  Autism	
  and	
  Developmental	
  Disorders,	
  32(3),	
  241-­‐242.	
  

	
  

	
  

Klin,	
  A.	
  (2002).	
  Bright	
  splinters	
  of	
  the	
  mind:	
  A	
  personal	
  story	
  of	
  research	
  with	
  autistic	
  savants:	
  by	
  Beate	
  

	
  

	
  

Hermelin.	
  The	
  Journal	
  of	
  Child	
  Psychology	
  and	
  Psychiatry,	
  43(6),	
  824-­‐825.	
  

	
  

	
  

Klin,	
  A.,	
  Jones,	
  W.,	
  Schultz,	
  R.	
  T.,	
  &	
  Volkmar,	
  F.	
  R.	
  (2003).	
  Defining	
  and	
  quantifying	
  the	
  social	
  phenotype	
  

	
  

	
  

in	
  autism.	
  Dr.	
  Klin	
  and	
  colleagues	
  reply.	
  The	
  American	
  Journal	
  of	
  Psychiatry,	
  160(7),	
  1359-­‐1360.	
  	
  

	
  

	
  

Volkmar,	
  F.	
  R.,	
  &	
  Klin,	
  A.	
  (2004).	
  Invited	
  commentary	
  on	
  “Behavioural	
  and	
  learning	
  problems	
  in	
  	
  	
  

	
  

	
  

school	
  children	
  related	
  to	
  cognitive	
  test	
  data”.	
  Acta	
  Paediatrica,	
  93,	
  1-­‐3.	
  	
  

	
  

	
  

Klin,	
  A.	
  (2004).	
  Invited	
  commentary	
  on	
  “Challenging	
  Case”.	
  Journal	
  of	
  Developmental	
  &	
  Behavioral	
  	
  

	
  

	
  

Pediatrics,	
  25(3),	
  190-­‐195.	
  

	
  

	
  

Klin,	
  A.	
  (2004).	
  Autism	
  and	
  difficulty	
  levels	
  in	
  social	
  visual	
  pursuit.	
  Dr.	
  Klin	
  replies.	
  American	
  Journal	
  of	
  	
  

	
  

	
  

Psychiatry,	
  161(5),	
  933-­‐934.	
  

	
  

	
  

Klin,	
  A.,	
  Jones,	
  W.,	
  Schultz,	
  R.,	
  &	
  Volkmar,	
  F.	
  (2004).	
  Autism,	
  movement,	
  and	
  facial	
  processing.	
  Dr.	
  Klin	
  	
  

	
  

	
  

and	
  colleagues	
  reply.	
  American	
  Journal	
  of	
  Psychiatry,	
  161(9),	
  1719-­‐1720.	
  

	
  

	
  

Klin,	
  A.	
  (2004).	
  The	
  cradle	
  of	
  thought:	
  Exploring	
  the	
  origins	
  of	
  thinking.	
  American	
  Journal	
  of	
  Mental	
  	
  

	
  

	
  

Retardation,	
  109(3),	
  267-­‐269.	
  	
  

	
  

	
  

Klin,	
  A.	
  &	
  Volkmar,	
  F.	
  R.	
  (2005).	
  	
  Editorial	
  preface	
  to	
  special	
  edition:	
  Aspergers	
  syndrome.	
  	
   	
  

	
  

	
  

Journal	
  of	
  the	
  American	
  Academy	
  of	
  Child	
  &	
  Adolescent	
  Psychiatry,	
  35(2),	
  141-­‐143.	
  	
  

	
  

	
  

Baron-­‐Cohen,	
  S.,	
  &	
  Klin,	
  A.	
  (2006).	
  What’s	
  so	
  special	
  about	
  Asperger	
  Syndrome?	
  	
  	
  

	
  

	
  

	
  

	
  

The	
  cognitive	
  neuroscience	
  of	
  Aspergers	
  syndrome.	
  	
  Brain	
  Cognition,	
  61(1),	
  1-­‐4.	
  [PMID:	
  	
   	
  

	
  

	
  

16563588]	
  

	
  

	
  

Klin,	
  A.	
  &	
  Mercadante,	
  M.	
  T.	
  (2006).	
  	
  Editorial	
  preface	
  to	
  special	
  supplement	
  on	
  autism:	
  	
  	
  

	
  

	
  

	
  

Autism	
  and	
  the	
  Pervasive	
  Developmental	
  Disorders.	
  Brazilian	
  Journal	
  of	
  Psychiatry	
  (Revista	
  	
  

	
  

	
  

Brasileira	
  de	
  Psiquiatria),	
  28	
  (Supl	
  I),	
  S1-­‐2.	
  

	
  

	
  

Klin,	
  A.	
  (2006).	
  The	
  social	
  neuroscience	
  of	
  autism.	
  Biological	
  Psychiatry,	
  59,	
  192S.	
  	
  

	
  

	
  

Shic,	
  F.,	
  Jones,	
  W.,	
  Klin,	
  A.,	
  &	
  Scassellati,	
  B.	
  (2006).	
  Swimming	
  in	
  the	
  underlying	
  stream:	
  computational	
  	
  

	
  

	
  

models	
  of	
  gaze	
  in	
  a	
  comparative	
  behavioral	
  analysis	
  of	
  autism.	
  The	
  Cognitive	
  Science	
  Society	
  	
  

	
  

	
  

2006	
  meeting,	
  Vancouver,	
  Canada.	
  This	
  paper	
  was	
  the	
  recipient	
  of	
  the	
  Best	
  Applied	
  Modeling	
  	
  

	
  

	
  

Paper.	
  	
  

	
  

	
  

Klin,	
  A.	
  (2008).	
  In	
  the	
  eye	
  of	
  the	
  beholden:	
  tracking	
  developmental	
  psychopathology.	
  Journal	
  of	
  the	
  	
  

	
  

	
  

American	
  Academy	
  of	
  Child	
  and	
  Adolescent	
  Psychiatry,	
  47(4),	
  362-­‐3.	
  [PMID:	
  18356702]	
  

Case 2:11-cv-04027-LDD Document 48-36 Filed 07/13/12 Page 73 of 84

Ami	
  Klin,	
  PhD	
  	
  	
  	
  	
  	
  	
  	
  	
  

	
  

	
  

	
  

	
  Page	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  5	
  	
  	6
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
   	
  	
  

	
  

	
  

Klin,	
  A.	
  (2008).	
  Three	
  things	
  to	
  remember	
  if	
  you	
  are	
  a	
  functional	
  magnetic	
  resonance	
  imaging	
  	
   	
  

	
  

	
  

researcher	
  of	
  face	
  processing	
  in	
  autism	
  spectrum	
  disorders.	
  Biological	
  Psychiatry,	
  64(7),	
  549-­‐51.	
  

	
  

	
  

[PMID:	
  18778978]	
  	
  

	
  

	
  

Klin,	
  A.	
  (2009).	
  Embracing	
  the	
  challenge	
  of	
  bold	
  theories	
  of	
  autism.	
  British	
  Journal	
  of	
  Psychiatry,	
  100,	
  	
  

	
  

	
  

29-­‐32.	
  [PMID:	
  19012812]	
  

	
  

	
  

Jones,	
  W.,	
  &	
  Klin,	
  A.	
  	
  (2009).	
  Heterogeneity	
  and	
  homogeneity	
  across	
  the	
  autism	
  spectrum:	
  the	
  role	
  of	
  	
  

	
  

	
  

development.	
  Journal	
  of	
  the	
  American	
  Academy	
  of	
  Child	
  and	
  Adolescent	
  Psychiatry,	
  48(5),	
  471-­‐	
  

	
  

	
  

3.	
  [PMID:	
  19395902]	
  

	
  

	
  

d.	
   Reviews	
  &	
  Chapters:	
  

	
  

	
  

Klin,	
  A.	
  (1989).	
  Understanding	
  early	
  infantile	
  autism:	
  An	
  application	
  of	
  G.H.	
  Mead's	
  theory	
  of	
  the	
  	
  

	
  

	
  

emergence	
  of	
  mind.	
  London	
  School	
  of	
  Economics	
  Quarterly,	
  4(3),	
  336-­‐356.	
  

	
  

	
  

Klin,	
  A.	
  (1993).	
  	
  Auditory	
  brain	
  stem	
  responses	
  in	
  autism:	
  brain	
  stem	
  dysfunction	
  or	
  peripheral	
  	
   	
  

	
  

	
  

hearing	
  loss?	
  Journal	
  of	
  Autism	
  and	
  Developmental	
  Disorders,	
  23(1),	
  15-­‐35.	
  [PMID:	
  8463195]	
  

	
  

	
  

Cohen,	
  D.	
  J.,	
  Volkmar,	
  F.	
  R.,	
  Anderson,	
  G.,	
  &	
  Klin,	
  A.	
  (1993).	
  Integrating	
  biological	
  and	
  behavioral	
  	
  

	
  

	
  

perspectives	
  in	
  the	
  study	
  and	
  care	
  of	
  autistic	
  individuals:	
  The	
  future	
  ahead.	
  Israel	
  Journal	
  of	
  	
  

	
  

	
  

Psychiatry	
  and	
  Related	
  Sciences,	
  30(1),	
  15-­‐32.	
  [PMID:	
  8101835]	
  

	
  

	
  

Klin,	
  A.	
  &	
  Volkmar,	
  F.	
  R.	
  (1993).	
  The	
  development	
  of	
  individuals	
  with	
  autism:	
  Implications	
  for	
  the	
  	
  

	
  

	
  

Theory	
  of	
  Mind	
  hypothesis.	
  In	
  Baron-­‐Cohen,	
  S.,	
  Tager-­‐Flusberg,	
  H.,	
  and	
  Cohen,	
  D.	
  J.	
  (Eds.),	
  	
  

	
  

	
  

Understanding	
  Other	
  Minds:	
  Perspectives	
  From	
  Autism	
  (pp.	
  317-­‐331).	
  Oxford,	
  United	
  Kingdom:	
  	
  

	
  

	
  

Oxford	
  University	
  Press.	
  

	
  

	
  

Volkmar,	
  F.	
  R.,	
  &	
  Klin,	
  A.	
  (1993).	
  Social	
  development	
  in	
  autism:	
  Historical	
  and	
  clinical	
  perspectives.	
  In	
  	
  

	
  

	
  

Baron-­‐Cohen,	
  S.,	
  Tager-­‐Flusberg,	
  H.,	
  and	
  Cohen,	
  D.	
  J,	
  (Eds.),	
  Understanding	
  Other	
  Minds:	
  	
  

	
  

	
  

Perspectives	
  From	
  Autism	
  (pp.	
  40	
  –	
  55).	
  Oxford,	
  United	
  Kingdom:	
  Oxford	
  University	
  Press.	
  

	
  

	
  

Mayes,	
  L.	
  C.,	
  Cohen,	
  D.	
  J.,	
  &	
  Klin,	
  A.	
  (1993).	
  Desire	
  and	
  fantasy:	
  A	
  psychoanalytic	
  perspective	
  on	
  	
  

	
  

	
  

Theory	
  of	
  Mind	
  and	
  autism.	
  In	
  Baron-­‐Cohen,	
  S.,	
  Tager-­‐Flusberg,	
  H.	
  and	
  Cohen,	
  D.	
  J.	
  (Eds.),	
  	
  

	
  

	
  

Understanding	
  Other	
  Minds:	
  Perspectives	
  From	
  Autism	
  (pp.	
  450-­‐465).	
  Oxford,	
  United	
  Kingdom:	
  	
  

	
  

	
  

Oxford	
  University	
  Press.	
  

	
  

	
  

Klin,	
  A.	
  (1994).	
  Behavioral	
  issues	
  in	
  autism.	
  American	
  Journal	
  of	
  Mental	
  Retardation,	
  101(1),	
  92-­‐95.	
  	
  

	
  

	
  

New	
  York,	
  NY:	
  Plenum	
  Press.	
  	
  

	
  

	
  

Klin,	
  A.	
  	
  (1994).	
  Asperger	
  Syndrome.	
  Child	
  and	
  Adolescent	
  Psychiatric	
  Clinics	
  of	
  North	
  America,	
  3(1),	
  	
  

Case 2:11-cv-04027-LDD Document 48-36 Filed 07/13/12 Page 74 of 84

Ami	
  Klin,	
  PhD	
  	
  	
  	
  	
  	
  	
  	
  	
  

	
  

	
  

	
  

	
  Page	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  5	
  	
  	7
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
   	
  	
  

	
  

	
  

131-­‐148.	
  (Reprinted	
  in	
  the	
  Official	
  Newsletter	
  of	
  the	
  Autism	
  Society	
  of	
  America	
  (July	
  1994);	
  	
  

	
  

	
  

Partially	
  reprinted	
  in	
  the	
  Newsletter	
  of	
  the	
  Learning	
  Disabilities	
  Association	
  of	
  America	
  	
   	
  

	
  

	
  

(September	
  1994).	
  

	
  

	
  

Klin,	
  A.	
  &	
  Shepard,	
  B.	
  	
  (1994).	
  Psychological	
  assessment	
  of	
  autistic	
  children.	
  Journal	
  of	
  the	
  American	
  	
  

	
  

	
  

Academy	
  of	
  Child	
  and	
  Adolescent	
  Psychiatry,	
  3(1),	
  53-­‐70.	
  

	
  

	
  

Klin,	
  A.,	
  &	
  Cohen,	
  D.	
  J.	
  (1994).	
  The	
  immorality	
  of	
  not	
  knowing:	
  The	
  ethical	
  imperative	
  to	
  conduct	
  	
  

	
  

	
  

research	
  in	
  child	
  psychiatry.	
  In	
  Y.	
  Hattab	
  (Ed.),	
  Ethics	
  in	
  Child	
  Psychiatry	
  (pp.	
  217-­‐232).	
  	
   	
  

	
  

	
  

Jerusalem:	
  Gefen	
  Publishers.	
  (A.	
  Martin	
  &	
  R.	
  A.	
  King,	
  (Eds.),	
  Reprinted	
  in	
  Donald	
  J.	
  Cohen:	
  Life	
  Is	
  

	
  

	
  

With	
  Others,	
  Selected	
  Writings	
  in	
  Child	
  Psychiatry.	
  Yale	
  University	
  Press,	
  New	
  Haven,	
  CT.,	
  1994,	
  	
  

	
  

	
  

pp.	
  207-­‐224).	
  	
  

	
  

	
  

Klin,	
  A.,	
  Sparrow,	
  S.	
  S.,	
  Volkmar,	
  F.	
  R.,	
  Cicchetti,	
  D.	
  V.,	
  &	
  Rourke,	
  B.	
  P.	
  (1995).	
  Asperger	
  syndrome.	
  In	
  	
  

	
  

	
  

B.	
  P.	
  Rourke	
  (Ed.),	
  Syndrome	
  of	
  Nonverbal	
  Learning	
  Disabilities:	
  Neurodevelopmental	
  	
   	
  

	
  

	
  

Manifestations	
  (pp.	
  93-­‐118).	
  New	
  York,	
  NY:	
  Guilford	
  Press.	
  

	
  

	
  

Klin,	
  A.	
  &	
  Cohen,	
  D.J.	
  (1994).	
  Theoretical	
  perspectives	
  on	
  autism.	
  Signal,	
  the	
  Newsletter	
  of	
  the	
  	
  

	
  

	
  

World	
  Association	
  of	
  Infant	
  Mental	
  Health,	
  2(2),	
  7-­‐12.	
  (Reprinted	
  in	
  Psychiatrie	
  de	
  l’enfant,	
  	
  

	
  

	
  

XXXVIII,	
  2,	
  477-­‐494,	
  1995).	
  [PMID:	
  8657798]	
  

	
  

	
  

Klin,	
  A.	
  &	
  Volkmar,	
  F.	
  R.	
  (1995).	
  Autism	
  and	
  the	
  Pervasive	
  Developmental	
  Disorders.	
  Child	
  &	
  	
   	
  

	
  

	
  

Adolescent	
  Psychiatric	
  Clinics	
  of	
  North	
  America,	
  4(3),	
  617-­‐630.	
  

	
  

	
  

Klin,	
  A.,	
  Mayes,	
  L.	
  C.,	
  Volkmar,	
  F.	
  R.,	
  &	
  Cohen,	
  D.	
  J.	
  (1995).	
  Multiplex	
  Developmental	
  Disorder.	
  Journal	
  	
  

	
  

	
  

of	
  Developmental	
  &	
  Behavioral	
  Pediatrics,	
  16(3),	
  S7-­‐S11.	
  	
  [PMID:	
  7560130]	
  

	
  

	
  

Volkmar,	
  F.	
  R.,	
  Klin,	
  A.,	
  Marans,	
  W.,	
  &	
  Cohen,	
  D.	
  J.	
  (1996).	
  	
  The	
  pervasive	
  developmental	
  disorders.	
  	
  

	
  

	
  

Child	
  &	
  Adolescent	
  Psychiatric	
  Clinics	
  of	
  North	
  America,	
  5(4),	
  963-­‐977.	
  

	
  

	
  

Klin,	
  A.,	
  &	
  Volkmar,	
  F.	
  R.	
  (1996).	
  The	
  pervasive	
  developmental	
  disorders:	
  Nosology	
  and	
  profiles	
  of	
  	
  

	
  

	
  

development.	
  In	
  S.,	
  Luthar,	
  J.	
  Burack,	
  D.	
  Cicchetti,	
  &	
  J.	
  Wiesz	
  (Eds.),	
  Developmental	
  	
   	
  

	
  

	
  

Perspectives	
  on	
  Risk	
  and	
  Psychopathology	
  (pp.	
  208-­‐226).	
  New	
  York,	
  NY:	
  Cambridge	
  	
   	
  

	
  

	
  

University	
  Press.	
  

	
  

	
  

Volkmar,	
  F.	
  R.,	
  Klin,	
  A.,	
  Marans,	
  W.	
  D.,	
  &	
  McDougle,	
  C.	
  J.	
  (1996).	
  Autistic	
  Disorder.	
  	
  In	
  F.	
  R.	
  Volkmar,	
  

	
  

	
  

(Ed.),	
  Psychoses	
  and	
  Pervasive	
  Developmental	
  Disorders	
  in	
  Childhood	
  and	
  Adolescence	
  (pp.	
  129-­‐	
  

	
  

	
  

190).	
  Washington,	
  D.C.:	
  American	
  Psychiatric	
  Press,	
  Inc.	
  	
  

	
  

	
  

Klin,	
  A.,	
  &	
  Volkmar,	
  F.	
  R.	
  (1997).	
  Asperger’s	
  syndrome.	
  In	
  D.	
  J.	
  Cohen	
  &	
  F.	
  R.	
  Volkmar	
  (Eds.)	
  	
  	
   	
  

	
  

	
  

Handbook	
  of	
  Autism	
  and	
  Pervasive	
  Developmental	
  Disorders,	
  2nd	
  edition	
  (pp.	
  94-­‐122).	
  New	
  	
  

	
  

	
  

York,	
  NY:	
  Wiley.	
  

	
  

Case 2:11-cv-04027-LDD Document 48-36 Filed 07/13/12 Page 75 of 84

Ami	
  Klin,	
  PhD	
  	
  	
  	
  	
  	
  	
  	
  	
  

	
  

	
  

	
  

	
  Page	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  5	
  	
  	8
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
   	
  	
  

	
  

Klin,	
  A.,	
  Carter,	
  A.,	
  Volkmar,	
  F.	
  R.,	
  Cohen,	
  D.	
  J.,	
  Marans,	
  W.	
  D.,	
  &	
  Sparrow,	
  S.	
  S.	
  (1997).	
  Assessment	
  	
  

	
  

	
  

issues	
  in	
  children	
  with	
  autism.	
  In	
  D.J.	
  Cohen	
  &	
  F.R.	
  Volkmar	
  (Eds.),	
  Handbook	
  of	
  Autism	
  and	
  	
  

	
  

	
  

Pervasive	
  Developmental	
  Disorders,	
  2nd	
  edition	
  (pp.	
  411	
  –	
  418).	
  New	
  York,	
  NY:	
  Wiley	
  

	
  

	
  

Klin,	
  A.,	
  Carter,	
  A.,	
  &	
  Sparrow,	
  S.	
  S.	
  (1997).	
  Psychological	
  assessment.	
  In	
  D.	
  J.	
  Cohen	
  &	
  F.	
  R.	
  Volkmar	
  	
  

	
  

	
  

(Eds.),	
  Handbook	
  of	
  Autism	
  and	
  Pervasive	
  Developmental	
  Disorders,	
  2nd	
  edition	
  (pp.	
  418-­‐427).	
  	
  

	
  

	
  

New	
  York,	
  NY:	
  Wiley.	
  

	
  

	
  

Volkmar,	
  F.	
  R.,	
  Klin,	
  A.,	
  &	
  Cohen,	
  D.	
  J.	
  (1997).	
  Diagnosis	
  and	
  classification	
  of	
  autism	
  and	
  related	
  	
   	
  

	
  

	
  

conditions:	
  Consensus	
  and	
  issues.	
  	
  In	
  D.	
  J.	
  Cohen	
  &	
  F.	
  R.	
  Volkmar	
  (Eds.)	
  Handbook	
  of	
  Autism	
  and	
  

	
  

	
  

Pervasive	
  Developmental	
  Disorders,	
  2nd	
  edition	
  (pp.	
  5-­‐40).	
  New	
  York,	
  NY:	
  Wiley.	
  

	
  

	
  

Klin,	
  A.,	
  &	
  Cohen,	
  D.	
  J.	
  (1997).	
  Ethical	
  issues	
  in	
  research	
  and	
  treatment.	
  In	
  D.J.	
  Cohen	
  &	
  F.R.	
  Volkmar	
  	
  

	
  

	
  

(Eds.),	
  Handbook	
  of	
  Autism	
  and	
  Pervasive	
  Developmental	
  Disorders,	
  2nd	
  edition	
  (pp.	
  828-­‐841).	
  	
  

	
  

	
  

New	
  York,	
  NY:	
  Wiley.	
  

	
  

	
  

Volkmar,	
  F.	
  R.,	
  Klin,	
  A.,	
  Marans,	
  W.,	
  &	
  Cohen,	
  D.	
  J.	
  (1997).	
  Childhood	
  Disintegrative	
  Disorder.	
  	
  In	
  D.	
  J.	
  	
  

	
  

	
  

Cohen	
  &	
  F.	
  R.	
  Volkmar	
  (Eds.),	
  Handbook	
  of	
  Autism	
  and	
  Pervasive	
  Developmental	
  Disorders,	
  2nd	
  	
  

	
  

	
  

edition	
  (pp.	
  47-­‐59).	
  	
  New	
  York,	
  NY:	
  Wiley.	
  

	
  

	
  

Volkmar,	
  F.	
  R.,	
  Carter,	
  A.,	
  Grossman,	
  J.,	
  &	
  Klin,	
  A.	
  (1997).	
  Social	
  development	
  in	
  autism.	
  In	
  D.	
  J.	
  Cohen	
  	
  

	
  

	
  

&	
  F.	
  R.	
  Volkmar	
  (Eds.),	
  Handbook	
  of	
  Autism	
  and	
  Pervasive	
  Developmental	
  Disorders,	
  2nd	
  edition	
  

	
  

	
  

(pp.	
  173-­‐194).	
  New	
  York,	
  NY:	
  Wiley.	
  

	
  

	
  

Klin,	
  A.,	
  &	
  Volkmar,	
  F.	
  R.	
  (1997).	
  Autism	
  and	
  the	
  Pervasive	
  Developmental	
  Disorders.	
  In	
  J.	
  D.	
  Noshpitz,	
  	
  

	
  

	
  

S.	
  Greenspan,	
  S.	
  Wieder,	
  &	
  J.	
  Osofsky	
  (Eds.),	
  Handbook	
  of	
  Child	
  and	
  Adolescent	
  Psychiatry.	
  	
  

	
  

	
  

Volume	
  One:	
  Infants	
  and	
  Preschoolers:	
  Development	
  and	
  syndromes	
  (pp.	
  536-­‐560).	
  New	
  	
  

	
  

	
  

York,	
  NY:	
  Wiley.	
  	
  

	
  

	
  

Volkmar,	
  F.R.,	
  &	
  Klin,	
  A.	
  (1998).	
  Asperger	
  syndrome	
  and	
  nonverbal	
  learning	
  disabilities.	
  In	
  E.	
  Schopler	
  	
  

	
  

	
  

&	
  G.	
  B.	
  Mesibov	
  (Eds.),	
  Asperger	
  Syndrome	
  or	
  High	
  Functioning	
  Autism	
  (pp.107-­‐122).	
  New	
  York,	
  	
  

	
  

	
  

NY:	
  Plenum	
  Press.	
  	
  

	
  	
  

	
  

Volkmar,	
  F.	
  R.,	
  Klin,	
  A.,	
  Schultz,	
  R.,	
  &	
  Cohen,	
  D.	
  J.	
  (1998).	
  The	
  nonautistic	
  pervasive	
  developmental	
  	
  

	
  

	
  

disorders.	
  In	
  C.	
  E.	
  Coffey,	
  &	
  R.	
  A.	
  Brumback,	
  (Eds.),	
  Textbook	
  of	
  Pediatric	
  Neuropsychiatry	
  (pp.	
  	
  

	
  

	
  

429-­‐447).	
  Washington	
  D.C.:	
  American	
  Psychiatric	
  Press.	
  

	
  

	
  

Klin,	
  A.,	
  &	
  Volkmar,	
  F.	
  R.	
  (1999).	
  Autism	
  and	
  the	
  pervasive	
  developmental	
  disorders.	
  In	
  S.	
  Goldstein,	
  &	
  	
  

	
  

	
  

C.	
  R.	
  Reynolds	
  (Eds).	
  Handbook	
  of	
  Neurodevelopmental	
  and	
  Genetic	
  Disorders	
  in	
  Children	
  (pp.	
  	
  

	
  

	
  

247-­‐274).	
  New	
  York,	
  NY:	
  Guilford	
  Press.	
  

	
  

	
  

Paul,	
  R.	
  Cohen,	
  D.,	
  Klin,	
  A.,	
  &	
  Volkmar,	
  F.	
  (1999).	
  Multiplex	
  developmental	
  disorders:	
  The	
  role	
  of	
  	
  

	
  

	
  

communication	
  in	
  the	
  construction	
  of	
  a	
  self.	
  	
  Child	
  &	
  Adolescent	
  Psychiatric	
  Clinics	
  of	
  North	
  	
  

	
  

	
  

America,	
  8(1),	
  189-­‐203.	
  [PMID:	
  9894036]	
  

Case 2:11-cv-04027-LDD Document 48-36 Filed 07/13/12 Page 76 of 84

Ami	
  Klin,	
  PhD	
  	
  	
  	
  	
  	
  	
  	
  	
  

	
  

	
  

	
  

	
  Page	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  5	
  	
  	9
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
   	
  	
  

	
  

	
  

Volkmar,	
  F.	
  R.,	
  &	
  Klin,	
  A.	
  (2000).	
  The	
  pervasive	
  developmental	
  disorders.	
  In	
  H.	
  Kaplan	
  &	
  B.	
  Sadock	
  	
  

	
  

	
  

(Eds.),	
  Comprehensive	
  Textbook	
  of	
  Psychiatry,	
  7th	
  edition	
  (pp.	
  2659-­‐2678).	
  Philadelphia,	
  PA:	
  	
  

	
  

	
  

Lippincott	
  Williams	
  &	
  Wilkins.	
  	
  

	
  

	
  

Klin,	
  A.,	
  Volkmar,	
  F.	
  R.,	
  &	
  Sparrow,	
  S.	
  S.	
  (2000).	
  Introduction.	
  In	
  A.	
  Klin,	
  F.	
  R.	
  Volkmar	
  &	
  S.	
  S.	
  Sparrow	
  	
  

	
  

	
  

(Eds.),	
  Asperger	
  Syndrome	
  (pp.	
  1-­‐21).	
  New	
  York,	
  NY:	
  Guilford	
  Press.	
  

	
  	
  

	
  

Volkmar,	
  F.R.	
  &	
  Klin,	
  A.	
  (2000).	
  Diagnostic	
  issues	
  in	
  Asperger	
  syndrome.	
  	
  In	
  A.	
  Klin,	
  Volkmar,	
  F.	
  R.	
  &	
  	
  

	
  

	
  

S.	
  S.	
  Sparrow	
  (Eds.),	
  Asperger	
  Syndrome	
  (pp.	
  25-­‐71).	
  New	
  York,	
  NY:	
  	
  Guilford	
  Press.	
  	
  

	
  

	
  

Klin,	
  A.,	
  Sparrow,	
  S.	
  S.,	
  Marans,	
  W.	
  D.,	
  Carter,	
  A.,	
  &	
  Volkmar,	
  F.	
  R.	
  (2000).	
  Assessment	
  issues	
  in	
  	
   	
  

	
  

	
  

Asperger	
  syndrome.	
  In	
  A.	
  Klin,	
  F.R.	
  Volkmar	
  &	
  S.	
  S.	
  Sparrow	
  (Eds.),	
  Asperger	
  Syndrome	
  (pp.	
  309-­‐	
  

	
  

	
  

339).	
  New	
  York,	
  NY:	
  Guilford	
  Press.	
  	
  

	
  

	
  

Klin,	
  A.	
  &	
  Volkmar,	
  F.	
  R.	
  (2000).	
  Treatment	
  and	
  intervention	
  guidelines	
  for	
  individuals	
  with	
  Asperger	
  	
  

	
  

	
  

syndrome.	
  In	
  A.	
  Klin,	
  F.	
  R.	
  Volkmar	
  &	
  S.	
  S.	
  Sparrow	
  (Eds.),	
  Asperger	
  Syndrome	
  (pp.340-­‐366).	
  	
  

	
  

	
  

New	
  York,	
  NY:	
  Guilford	
  Press.	
  	
  

	
  

	
  

Klin,	
  A.,	
  Schultz,	
  R.,	
  &	
  Cohen,	
  D.	
  (2000).	
  Theory	
  of	
  Mind	
  in	
  action:	
  developmental	
  perspectives	
  on	
  social	
  

	
  

	
  

neuroscience.	
  In	
  S.	
  Baron-­‐Cohen,	
  H.	
  Tager-­‐Flusberg,	
  &	
  D.	
  Cohen	
  (Eds.),	
  Understanding	
  Other	
  	
  

	
  

	
  

Minds:	
  Perspectives	
  from	
  Developmental	
  Neuroscience,	
  2nd	
  edition	
  (pp.357-­‐388).	
  Oxford,	
  	
  

	
  

	
  

United	
  Kingdom:	
  	
  Oxford	
  University	
  Press.	
  

	
  

	
  

Koenig,	
  K.,	
  Rubin,	
  E.,	
  Klin,	
  A.,	
  &	
  Volkmar,	
  F.	
  R.	
  (2000).	
  Autism	
  and	
  the	
  pervasive	
  developmental	
  	
   	
  

	
  

	
  

disorders.	
  In	
  C.	
  H.	
  Zeanah	
  (Ed.),	
  Handbook	
  of	
  Infant	
  Mental	
  Health,	
  2nd	
  edition	
  (pp.298-­‐310).	
  	
  

	
  

	
  

New	
  York,	
  NY:	
  Guilford	
  Press.	
  

	
  

	
  

Volkmar,	
  F.	
  R.	
  &	
  Klin,	
  A.	
  (2000).	
  Autism	
  and	
  the	
  pervasive	
  developmental	
  disorders.	
  In	
  M.	
  G.	
  	
  

	
  

	
  

Gelder,	
  J.	
  J.	
  López-­‐Ibor,	
  &	
  N.	
  Andreasen	
  (Eds.),	
  New	
  Oxford	
  Textbook	
  of	
  Psychiatry,	
  Volume	
  2	
  	
  

	
  

	
  

(pp.	
  1723-­‐1734).	
  Oxford,	
  United	
  Kingdom:	
  Oxford	
  University	
  Press.	
  

	
  

	
  

Volkmar,	
  F.	
  R.	
  &	
  Klin,	
  A.	
  (2001).	
  	
  Asperger’s	
  disorder	
  and	
  higher	
  functioning	
  autism:	
  Same	
  or	
  	
   	
  

	
  

	
  

different?	
  In	
  L.	
  M.	
  Glidden	
  (Ed.),	
  International	
  Review	
  of	
  Research	
  in	
  Mental	
  Retardation	
  (23,	
  	
  

	
  

	
  

83-­‐110).	
  New	
  York,	
  NY:	
  Academic	
  Press.	
  

	
  

	
  

Volkmar,	
  F.	
  R.,	
  &	
  Klin,	
  A.	
  (2001).	
  Asperger’s	
  syndrome.	
  In	
  M.	
  J.	
  Aminoff	
  &	
  R.	
  B.	
  Daroff	
  (Eds.),	
  	
   	
  

	
  

	
  

Encyclopedia	
  of	
  the	
  Neurological	
  Sciences,	
  (pp.	
  284-­‐85).	
  San	
  Diego,	
  CA:	
  Academic	
  Press.	
  

	
  

	
  

Schultz,	
  R.	
  T.	
  &	
  Klin,	
  A.	
  (2002).	
  The	
  neural	
  foundations	
  of	
  autism.	
  Journal	
  of	
  the	
  American	
  Academy	
  	
  

	
  

	
  

of	
  Child	
  and	
  Adolescent	
  Psychiatry,	
  41(10),	
  1259-­‐1262.	
  

	
  

Case 2:11-cv-04027-LDD Document 48-36 Filed 07/13/12 Page 77 of 84

Ami	
  Klin,	
  PhD	
  	
  	
  	
  	
  	
  	
  	
  	
  

	
  

	
  

	
  

	
  Page	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  6	
  	
  	0
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
   	
  	
  

	
  

Volkmar,	
  F.	
  R.,	
  Lord,	
  C.,	
  Klin,	
  A.,	
  &	
  Cook,	
  E.	
  Jr.	
  (2002).	
  Autism	
  and	
  the	
  pervasive	
  developmental	
  	
   	
  

	
  

	
  

disorders.	
  In	
  M.	
  Lewis	
  (Ed.),	
  Child	
  and	
  Adolescent	
  Psychiatry:	
  a	
  comprehensive	
  textbook,	
  3rd	
  	
  

	
  

	
  

edition	
  (pp.587-­‐597).	
  New	
  York,	
  NY:	
  Lippincott	
  Williams	
  &	
  Wilkins.	
  

	
  

	
  

Volkmar,	
  F.	
  R.,	
  Klin,	
  A.,	
  Schultz,	
  R.,	
  Chawarska,	
  K.,	
  &	
  Jones,	
  W.	
  (2003).	
  The	
  social	
  brain	
  in	
  autism.	
  In	
  M.	
  	
  

	
  

	
  

Brüne,	
  H.	
  Ribbert,	
  &	
  W.	
  Schienfenhövel	
  (Eds.),	
  The	
  Social	
  Brain:	
  Evolution	
  and	
  Pathology	
  (pp.	
  	
  

	
  

	
  

167-­‐196).	
  New	
  York,	
  NY:	
  John	
  Wiley	
  and	
  Sons.	
  

	
  

	
  

Klin,	
  A.	
  &	
  Volkmar,	
  F.	
  (2003).	
  Preface	
  to	
  issue	
  on	
  Asperger	
  syndrome.	
  	
  Child	
  &	
  Adolescent	
  Psychiatric	
  	
  

	
  

	
  

Clinics	
  of	
  North	
  America,	
  12:xiii-­‐xvi.	
  	
  

	
  

	
  

Klin,	
  A.	
  &	
  Volkmar,	
  F.	
  (2003).	
  Asperger	
  syndrome:	
  diagnosis	
  and	
  external	
  validity.	
  Child	
  &	
  Adolescent	
  	
  

	
  

	
  

Psychiatric	
  Clinics	
  of	
  North	
  America,	
  12,	
  1-­‐13.	
  [PMID:	
  12512395]	
  

	
  

	
  

Klin,	
  A.	
  (2003).	
  Asperger	
  syndrome:	
  An	
  update.	
  Revista	
  Brasileira	
  de	
  Psiquiatria,	
  25(2),	
  103-­‐9.	
  [PMID:	
  	
  

	
  

	
  

12975708]	
  

	
  

	
  

Grigorenko,	
  E.L.,	
  Klin,	
  A.,	
  &	
  Volkmar,	
  F.	
  (2003).	
  Annotation:	
  Hyperlexia:	
  disability	
  or	
  superability?	
  	
  	
  

	
  

	
  

Journal	
  of	
  Child	
  Psychology	
  and	
  Psychiatry,	
  44(8),	
  1079-­‐1091.	
  [PMID:	
  14626452]	
  

	
  

	
  

Klin,	
  A.	
  (2003).	
  History,	
  definition,	
  and	
  diagnostic	
  markers	
  of	
  Asperger	
  syndrome.	
  Perspectives	
  on	
  	
  

	
  

	
  

Language	
  Learning	
  and	
  Education,	
  American	
  Speech-­‐Language-­‐Hearing	
  Association,	
  Division	
  1,	
  	
  

	
  

	
  

10(3),	
  2-­‐4.	
  	
  

	
  

	
  

Klin,	
  A.	
  &	
  Volkmar,	
  F.R.	
  (Eds.).	
  (2003).	
  Asperger	
  Syndrome.	
  	
  Child	
  &	
  Adolescent	
  Psychiatric	
  Clinics	
  of	
  	
  

	
  

	
  

North	
  America,	
  12(1),	
  xiii-­‐xvi.	
  [PMID:	
  12512394]	
  

	
  

	
  

Stein,	
  M.	
  T.,	
  Klin,	
  A.,	
  Miller,	
  K.	
  	
  (2004).	
  When	
  Asperger’s	
  syndrome	
  and	
  a	
  nonverbal	
  learning	
  disability	
  	
  

	
  

	
  

look	
  alike.	
  Journal	
  of	
  Developmental	
  &	
  Behavioral	
  Pediatrics,	
  25(3),	
  190-­‐193.	
  	
  (Reprinted	
  in	
  	
  

	
  

	
  

Journal	
  of	
  Developmental	
  &	
  Behavioral	
  Pediatrics.	
  25(5S),	
  S59-­‐S64).	
  [PMID:	
  15502535]	
  

	
  

	
  

Volkmar,	
  F.	
  R.	
  &	
  Klin,	
  A.	
  (2004).	
  Autism	
  and	
  Asperger’s	
  syndrome.	
  Encyclopedia	
  of	
  Psychology,	
  

	
  

	
  

1,	
  257-­‐260.	
  

	
  

	
  

Volkmar,	
  F.	
  R.,	
  Lord,	
  C.,	
  Bailey,	
  A.,	
  Schultz,	
  R.	
  T.,	
  Klin,	
  A.	
  (2004).	
  Autism	
  and	
  pervasive	
  developmental	
  	
  

	
  

	
  

disorders.	
  The	
  Journal	
  of	
  Child	
  Psychology	
  and	
  Psychiatry,	
  45(1),	
  135-­‐70.	
  [PMID:	
  14959806]	
  

	
  

	
  

Volkmar,	
  F.	
  R.	
  &	
  Klin,	
  A.	
  (2004).	
  Behavioral	
  and	
  learning	
  problems	
  in	
  school	
  children	
  related	
  to	
  	
   	
  

	
  

	
  

cognitive	
  test	
  data.	
  Acta	
  Paediatrica,	
  93,	
  1-­‐3.	
  

	
  

	
  

Klin,	
  A.,	
  Chawarska,	
  K.,	
  Rubin,	
  E.,	
  &	
  Volkmar,	
  F.	
  R.	
  (2004).	
  Clinical	
  assessment	
  of	
  toddlers	
  at	
  risk	
  of	
  	
  

	
  

	
  

autism.	
  In	
  R.	
  DelCarmen-­‐Wiggins	
  &	
  A.	
  Carter	
  (Eds).,	
  Handbook	
  of	
  Infant	
  and	
  Toddler	
  Mental	
  	
  

	
  

	
  

Health	
   Assessment	
  (pp.	
  311-­‐336).	
  Oxford,	
  United	
  Kingdom:	
  Oxford	
  University	
  Press.	
  Portuguese	
  

Case 2:11-cv-04027-LDD Document 48-36 Filed 07/13/12 Page 78 of 84

Ami	
  Klin,	
  PhD	
  	
  	
  	
  	
  	
  	
  	
  	
  

	
  

	
  

	
  

	
  Page	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  6	
  	
  	1
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
   	
  	
  

	
  

	
  

translation:	
  Avaliação	
  clínica	
  de	
  crianças	
  com	
  risco	
  de	
  autismo.	
  Educação,	
  ano	
  XXIX,	
  n.	
  1	
  	
  	
  

	
  

	
  

(58),	
  11-­‐53.	
  	
  

	
  

	
  

Volkmar,	
  F.	
  R.,	
  Klin,	
  A.,	
  &	
  Schultz,	
  R.	
  T.	
  (2005).	
  The	
  pervasive	
  developmental	
  disorders.	
  In	
  Sadock,	
  B.	
  J.	
  	
  

	
  

	
  

and	
  Sadock,	
  V.	
  A.	
  (Eds.),	
  Comprehensive	
  Textbook	
  of	
  Psychiatry,	
  8th	
  edition	
  (pp.	
  3164-­‐3182).	
  	
  	
  

	
  

	
  

Philadelphia,	
  PA:	
  Lippincott	
  Williams	
  &	
  Wilkins.	
  

	
  

	
  

Volkmar,	
  F.	
  R.,	
  Klin,	
  A.,	
  &	
  Paul,	
  R.	
  (2005).	
  Preface.	
  In	
  F.R.	
  Volkmar,	
  R.	
  Paul,	
  A.	
  Klin,	
  &	
  D.J.	
  Cohen	
  (Eds.),	
  	
  

	
  

	
  

Handbook	
  of	
  Autism	
  and	
  Pervasive	
  Developmental	
  Disorders,	
  3rd	
  edition	
  (pp.	
  XV-­‐XIX).	
  New	
  	
  

	
  

	
  

York,	
  NY:	
  Wiley	
  &	
  Sons.	
  	
  

	
  	
  

	
  

Volkmar,	
  F.	
  R.	
  &	
  Klin,	
  A.	
  (2005).	
  Issues	
  in	
  the	
  classification	
  of	
  autism	
  and	
  related	
  conditions.	
  In	
  F.	
  R.	
  	
  

	
  

	
  

Volkmar,	
  R.	
  Paul,	
  A.	
  Klin,	
  &	
  D.	
  J.	
  Cohen	
  (Eds.),	
  Handbook	
  of	
  Autism	
  and	
  Pervasive	
  	
 	 
  

	
  

	
  

	
  

Developmental	
  Disorders,	
  3rd	
  edition	
  (pp.	
  5-­‐41).	
  	
  New	
  York,	
  NY:	
  	
  Wiley	
  &	
  Sons.	
  

	
  

	
  

Klin,	
  A.,	
  McPartland,	
  J.,	
  &	
  Volkmar,	
  F.	
  R.	
  (2005).	
  Asperger	
  syndrome.	
  In	
  F.	
  R.	
  Volkmar,	
  R.	
  Paul,	
  A.	
  Klin,	
  &	
  	
  

	
  

	
  

D.	
  J.	
  Cohen	
  (Eds.),	
  Handbook	
  of	
  Autism	
  and	
  Pervasive	
  Developmental	
  Disorders,	
  3rd	
  edition	
  	
  

	
  

	
  

(pp.	
  88-­‐125).	
  	
  New	
  York,	
  NY:	
  Wiley	
  &	
  Sons.	
  

	
  

	
  

Carter,	
  A.	
  S.,	
  Davis,	
  N.	
  O.,	
  Klin,	
  A.,	
  &	
  Volkmar,	
  F.	
  R.	
  (2005).	
  Social	
  development	
  in	
  autism.	
  In	
  F.	
  R.	
  	
  

	
  

	
  

Volkmar,	
  R.	
  Paul,	
  A.	
  Klin,	
  &	
  D.J.	
  Cohen	
  (Eds.),	
  Handbook	
  of	
  Autism	
  and	
  Pervasive	
  Developmental	
  

	
  

	
  

Disorders,	
  3rd	
  edition	
  (pp.	
  312-­‐334).	
  New	
  York,	
  NY:	
  Wiley	
  &	
  Sons.	
  

	
  	
  	
  

	
  

Klin,	
  A.,	
  Saulnier,	
  C.,	
  Tsatsanis,	
  K.,	
  &	
  Volkmar,	
  F.	
  R.	
  (2005).	
  	
  Clinical	
  evaluation	
  in	
  autism	
  spectrum	
  	
  

	
  

	
  

disorders:	
  psychological	
  assessment	
  within	
  a	
  transdisciplinary	
  framework.	
  In	
  F.	
  R.	
  Volkmar,	
  R.	
  	
  

	
  

	
  

Paul,	
  A.	
  Klin,	
  &	
  D.	
  J.	
  Cohen	
  (Eds.),	
  Handbook	
  of	
  Autism	
  and	
  Pervasive	
  Developmental	
  Disorders,	
  	
  

	
  

	
  

3rd	
  edition	
  (pp.	
  772-­‐798).	
  	
  New	
  York,	
  NY:	
  Wiley	
  &	
  Sons.	
  

	
  

	
  

Volkmar,	
  F.R.,	
  Chawarska,	
  K.,	
  &	
  Klin,	
  A.	
  (2005).	
  	
  Autism	
  in	
  infancy	
  and	
  early	
  childhood.	
  In	
  A.	
  Kazdin	
  	
  

	
  

	
  

(Ed.),	
  Annual	
  Review	
  of	
  Psychology,	
  56,	
  315-­‐36.	
  [PMID:	
  15709938]	
  

	
  

	
  

McPartland,	
  J.	
  &	
  Klin,	
  A.	
  (2006).	
  Asperger’s	
  Syndrome.	
  Adolescent	
  Medicine	
  Clinic,	
  17,	
  771-­‐788.	
  [PMID:	
  	
  

	
  

	
  

17030291]	
  

	
  

	
  

Klin,	
  A.	
  (2006).	
  Autism	
  and	
  Asperger	
  Syndrome:	
  an	
  overview.	
  Brazilian	
  Journal	
  of	
  Psychiatry	
  (Revista	
  	
  

	
  

	
  

Brasileira	
  de	
  Psiquiatria),	
  28	
  (Supl	
  I),	
  S3-­‐11.	
  [PMID:	
  16791390]	
  

	
  

	
  

Paul,	
  R.,	
  Chawarska,	
  K.,	
  Klin,	
  A.,	
  &	
  Volkmar,	
  F.	
  (2006).	
  Dissociations	
  in	
  the	
  development	
  of	
  early	
  	
	 
   

	
  

	
  

communication	
  in	
  autism	
  spectrum	
  disorders.	
  In	
  R.	
  Paul	
  (Ed.),	
  Language	
  Disorders	
  from	
  a	
  	
  

	
  

	
  

Developmental	
  Perspective:	
  Essays	
  in	
  Honor	
  of	
  Robin	
  S.	
  Chapman	
  (pp.	
  163-­‐194).	
  Mahwah,	
  NJ:	
  	
  

	
  

	
  

Lawrence	
  Erlbaum.	
  

	
  

Case 2:11-cv-04027-LDD Document 48-36 Filed 07/13/12 Page 79 of 84

Ami	
  Klin,	
  PhD	
  	
  	
  	
  	
  	
  	
  	
  	
  

	
  

	
  

	
  

	
  Page	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  6	
  	
  	2
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
   	
  	
  

	
  

Volkmar,	
  F.	
  R.,	
  Lord,	
  C.,	
  Klin,	
  A.,	
  Schultz,	
  R.,	
  &	
  Cook,	
  E.	
  (2006).	
  The	
  pervasive	
  developmental	
  disorders.	
  	
  

	
  

	
  

In	
  A.	
  Martin	
  &	
  F.R.	
  Volkmar	
  (Eds.),	
  Lewis’s	
  Child	
  and	
  Adolescent	
  Psychiatry:	
  A	
  Comprehensive	
  	
  

	
  

	
  

Textbook,	
  4th	
  edition	
  (pp.384-­‐400).	
  New	
  York,	
  NY:	
  Lippincott	
  Williams	
  &	
  Wilkins.	
  

	
  

	
  

Klin,	
  A.	
  &	
  Jones,	
  W.	
  (2007).	
  Embodied	
  psychoanalysis?	
  Or	
  on	
  the	
  confluence	
  of	
  psychodynamic	
  	
  	
  

	
  

	
  

theory	
  and	
  developmental	
  science.	
  In	
  L.	
  Mayes,	
  P.	
  Fonagy,	
  &	
  M.	
  Target	
  (Eds.),	
  Developmental	
  	
  

	
  

	
  

Science	
  and	
  Psychoanalysis:	
  Integration	
  and	
  Innovation	
  (pp.	
  5-­‐38).	
  London,	
  United	
  Kingdom:	
  	
  

	
  

	
  

Karnac	
  Books.	
  

	
  

	
  

Zwaigenbaum,	
  L.,	
  Thurm,	
  A.,	
  Stone,	
  W.,	
  Baranek,	
  G.,	
  Bryson,	
  S.,	
  Iverson,	
  J.,	
  Kau,	
  A.,	
  Klin,	
  A.,	
  	
  

	
  

	
  

Lord,	
  C.,	
  Landa,	
  R.	
  Rogers,	
  S.,	
  &	
  Sigman,	
  M.	
  (2007).	
  Studying	
  the	
  emergence	
  of	
  autism	
  spectrum	
  	
  

	
  

	
  

disorders	
  in	
  high-­‐risk	
  infants:	
  methodological	
  and	
  practical	
  issues.	
  Journal	
  of	
  Autism	
  and	
  	
  

	
  

	
  

Developmental	
  Disorders,	
  37(3),	
  466-­‐80.	
  [PMID:	
  16897376]	
  

	
  

	
  

Klin,	
  A.,	
  Saulnier,	
  C.,	
  Chawarska,	
  K.,	
  &	
  Volkmar,	
  F.	
  (2008).	
  Case	
  studies	
  of	
  infants	
  first	
  evaluated	
  in	
  the	
  	
  

	
  

	
  

second	
  year	
  of	
  life.	
  In	
  K.	
  Chawarska,	
  A.	
  Klin,	
  &	
  F.R.	
  Volkmar	
  (Eds.),	
  Autism	
  Spectrum	
  Disorders	
  in	
  	
  

	
  

	
  

Infants	
  and	
  Toddlers:	
  Diagnosis,	
  Assessment	
  and	
  Treatment	
  (pp.141-­‐169).	
  New	
  York,	
  NY:	
  	
  	
  

	
  

	
  

Guilford	
  Press.	
  

	
  

	
  

Volkmar,	
  F.	
  R.,	
  Chawarska,	
  K.,	
  &	
  Klin,	
  A.	
  (2008).	
  	
  Autism	
  spectrum	
  disorders	
  in	
  infants	
  and	
  toddlers:	
  an	
  	
  

	
  

	
  

introduction.	
  In	
  K.	
  Chawarska,	
  A.	
  Klin,	
  &	
  F.	
  R.	
  Volkmar	
  (Eds.),	
  Autism	
  Spectrum	
  Disorders	
  in	
  	
  

	
  

	
  

Infants	
  and	
  Toddlers:	
  Diagnosis,	
  Assessment	
  and	
  Treatment	
  (pp.1-­‐22).	
  New	
  York:	
  Guilford	
  Press.	
  

	
  

	
  

Klin,	
  A.,	
  Chawarska,	
  K.,	
  &	
  Volkmar,	
  F.R.	
  (2008).	
  	
  Opportunities	
  for	
  research:	
  concepts	
  and	
  future	
  	
  

	
  

	
  

directions.	
  In	
  K.	
  Chawarska,	
  A.	
  Klin,	
  &	
  F.R.	
  Volkmar	
  (Eds.),	
  Autism	
  Spectrum	
  Disorders	
  in	
  Infants	
  	
  

	
  

	
  

and	
  Toddlers:	
  Diagnosis,	
  Assessment	
  and	
  Treatment	
  (pp.327-­‐336).	
  New	
  York,	
  NY:	
  Guilford	
  	
  

	
  

	
  

Press.	
  

	
  

	
  

Klin,	
  A.	
  (2008).	
  Subtyping	
  the	
  autism	
  spectrum	
  disorders:	
  theoretical,	
  research,	
  and	
  clinical	
  	
  

	
  

	
  

considerations.	
  In	
  S.	
  Goldstein,	
  J.	
  Naglieri,	
  &	
  S.	
  Ozonoff	
  (Eds.),	
  Assessment	
  of	
  Autism	
  Spectrum	
  	
  

	
  

	
  

Disorders	
  (pp.	
  91-­‐116).	
  New	
  York,	
  NY:	
  Guilford	
  Press.	
  

	
  

	
  

Jones,	
  W.,	
  &	
  Klin,	
  A.	
  (2008).	
  Altered	
  salience	
  in	
  autism:	
  developmental	
  insights,	
  consequences,	
  and	
  	
  

	
  

	
  

questions.	
  In	
  E.	
  McGregor,	
  M.	
  Nunez,	
  K.	
  Cebula,	
  J.	
  C.	
  Gomez	
  (Eds.),	
  Autism:	
  an	
  Integrated	
  View	
  	
  

	
  

	
  

from	
  Neurocognitive,	
  Clinical,	
  and	
  Intervention	
  Research	
  (pp.62-­‐82).	
  Malden,	
  MA:	
  Blackwell	
  	
  

	
  

	
  

Publishing.	
  	
  

	
  

	
  

Volkmar,	
  F.	
  R.,	
  Klin,	
  A.,	
  Schultz,	
  R.	
  T.,	
  &	
  State,	
  M.	
  (2009).	
  The	
  pervasive	
  developmental	
  disorders.	
  In	
  	
  

	
  

	
  

H.	
  Kaplan	
  &	
  B.	
  Sadock	
  (Eds.),	
  Comprehensive	
  Textbook	
  of	
  Psychiatry,	
  8th	
  edition	
  (pp.	
  3540-­‐	
  

	
  

	
  

3559).	
  	
  Philadelphia,	
  PA:	
  Lippincott	
  Williams	
  &	
  Wilkins.	
  	
  

	
  

	
  

Volkmar,	
  F.	
  R.,	
  State,	
  M.,	
  &	
  Klin,	
  A.	
  (2009).	
  Autism	
  and	
  autism	
  spectrum	
  disorders:	
  diagnostic	
  issues	
  for	
  

	
  

	
  

the	
  coming	
  decade.	
  The	
  Journal	
  of	
  Child	
  Psychology	
  and	
  Psychiatry,	
  50(1-­‐2),	
  108-­‐115.	
  [PMID:	
  	
  

	
  

	
  

19220594]	
  

Case 2:11-cv-04027-LDD Document 48-36 Filed 07/13/12 Page 80 of 84

Ami	
  Klin,	
  PhD	
  	
  	
  	
  	
  	
  	
  	
  	
  

	
  

	
  

	
  

	
  Page	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  6	
  	
  	3
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
   	
  	
  

	
  

	
  

Koenig,	
  K.,	
  De	
  Los	
  Reyes,	
  A.,	
  Cicchetti,	
  D.,	
  Scahill,	
  L.,	
  &	
  Klin,	
  A.	
  (2009).	
  Group	
  intervention	
  to	
  promote	
  	
  

	
  

	
  

social	
  skills	
  in	
  school-­‐age	
  children	
  with	
  pervasive	
  developmental	
  disorders:	
  Reconsidering	
  	
  

	
  

	
  

efficacy.	
  Journal	
  of	
  Autism	
  and	
  Developmental	
  Disorders,	
  39(8),	
  1163-­‐72.	
  [PMID:	
  19326199]	
  

	
  

	
  

Zwaigenbaum,	
  L.,	
  Bryson,	
  S.,	
  Lord,	
  C.,	
  Rogers,	
  S.,	
  Carter,	
  A.,	
  Carver,	
  L.,	
  Chawarska,	
  K.,	
  Constantino,	
  J.,	
  	
  

	
  

	
  

Dawson,	
  G.,	
  Dobkins,	
  K.,	
  Fein,	
  D.,	
  Iverson,	
  J.,	
  Klin,	
  A.,	
  Landa,	
  R.,	
  Messinger,	
  D.,	
  Ozonoff,	
  S.,	
  	
  

	
  

	
  

Sigman,	
  M.,	
  Stone,	
  W.,	
  Tager-­‐Flusberg,	
  H.,	
  &	
  Yirmiya,	
  N.	
  (2009).	
  Clinical	
  assessment	
  and	
  	
  	
  

	
  

	
  

management	
  of	
  toddlers	
  with	
  suspected	
  autism	
  spectrum	
  disorder:	
  insights	
  from	
  studies	
  of	
  	
  

	
  

	
  

high-­‐risk	
  infants.	
  Pediatrics,	
  123(5),	
  1383-­‐1391.	
  [PMID:	
  19403506]	
  

	
  

	
  

VanBergeijk,	
  E.,	
  Klin,	
  A.,	
  &	
  Volkmar,	
  F.R.	
  (2010).	
  What	
  can	
  help	
  people	
  with	
  ASC	
  find	
  and	
  keep	
  	
   	
  

	
  

	
  

employment?	
  In	
  Bolte	
  &	
  Jallmayer	
  (Eds.),	
  Autism	
  Spectrum	
  Conditions	
  (pp.	
  239-­‐242).	
  	
   	
  

	
  

	
  

Cambridge,	
  MA:	
  Hogrefe	
  Publishing.	
  

	
  

	
  

Cicchetti,	
  D.	
  V.,	
  Koenig,	
  K.,	
  Klin,	
  A.,	
  Volkmar,	
  F.	
  R.,	
  Paul,	
  R.,	
  &	
  Sparrow,	
  S.	
  S.	
  (2011).	
  From	
  Bayes	
  through	
  

	
  

	
  

marginal	
  utility	
  to	
  effect	
  sizes:	
  a	
  guide	
  to	
  understanding	
  the	
  clinical	
  and	
  statistical	
  significance	
  	
  

	
  

	
  

of	
  autism	
  research	
  studies.	
  Journal	
  of	
  Autism	
  and	
  Developmental	
  Disorders,	
  41(2),	
  168-­‐74.	
  	
  

	
  

	
  

[PMID:	
  20490646]	
  	
  	
  

	
  

	
  

	
  

	
  

Saulnier,	
  C.,	
  Quirmbach,	
  L.,	
  &	
  Klin,	
  A.	
  (2011).	
  Clinical	
  evaluation	
  of	
  children	
  with	
  autism	
  spectrum	
  	
  

	
  

	
  

disorders.	
  In	
  E.	
  Hollander,	
  A.	
  Kolevzon,	
  &	
  J.	
  Coyle	
  (Eds.),	
  American	
  Psychiatric	
  Publishing	
  Inc.	
  	
  

	
  

	
  

Textbook	
  of	
  Autism	
  Spectrum	
  Disorders	
  (pp.	
  25-­‐38).	
  Arlington,	
  VA:	
  American	
  Psychiatric	
  	
   	
  

	
  

	
  

Publishing,	
  Inc.	
  	
   	
  

	
  

	
  

McPartland,	
  J.,	
  Klin,	
  A.,	
  Westphal,	
  A.,	
  &	
  Volkmar,	
  F.R.	
  (in	
  press).	
  The	
  autism	
  spectrum	
  disorders.	
  	
  

	
  

	
  

In	
  A.	
  Tasman,	
  J.	
  Kay,	
  J.	
  Lieberman,	
  M.	
  First	
  &	
  M.	
  Maj	
  (Eds.),	
  Psychiatry,	
  3rd	
  edition.	
  New	
  York,	
  	
  

	
  

	
  

NY:	
  John	
  Willey.	
  

	
  

	
  

Volkmar,	
  F.R.,	
  Klin,	
  A.,	
  &	
  Shultz,	
  R.T.	
  	
  (in	
  press).	
  Autism	
  and	
  the	
  pervasive	
  developmental	
  	
  

	
  

	
  

disorders.	
  In	
  M.	
  G.	
  Gelder,	
  J.	
  J.	
  López-­‐Ibor,	
  &	
  N.	
  Andreasen	
  (Eds.),	
  New	
  Oxford	
  Texbook	
  of	
  	
  

	
  

	
  

Psychiatry,	
  2nd	
  edition,	
  Volume	
  2.	
  Oxford,	
  United	
  Kingdom:	
  Oxford	
  University	
  Press.	
  

	
  

	
  

	
  

Saulnier,	
  C.,	
  Quirmbach,	
  L.,	
  &	
  Klin,	
  A.	
  (in	
  press).	
  Clinical	
  evaluation	
  of	
  children	
  with	
  Autism	
  Spectrum	
  	
  

	
  

	
  

Disorders.	
  In	
  C.	
  Araújo,	
  J.	
  Perissinoto,	
  &	
  J.S.	
  Schwartzman	
  (Eds.),	
  Autismo	
  e	
  outros	
  transtornos	
  	
  

	
  

	
  

do	
  espectro	
  autista.	
  	
  São	
  Paulo,	
  Brazil:	
  Editora	
  Memnon.	
  	
  

	
  

	
  

Klin,	
  A.	
  (in	
  press).	
  Asperger’s	
  syndrome:	
  from	
  Asperger	
  to	
  modern	
  day.	
  In	
  D.G.	
  Amaral,	
  G.	
  Dawson,	
  &	
  	
  

	
  

	
  

Geschwind,	
  D.H.	
  (Eds.),	
  Autism	
  Spectrum	
  Disorders	
  (pp.	
  44	
  –	
  59).	
  Oxford,	
  United	
  Kingdom:	
  	
  

	
  

	
  

Oxford	
  University	
  Press.	
  

	
  

	
  

Jones,	
  W.,	
  &	
  Klin,	
  A.	
  (in	
  press).	
  Social	
  engagement	
  in	
  the	
  first	
  two	
  years	
  of	
  life	
  in	
  autism	
  spectrum	
  	
  

	
  

	
  

disorders.	
  In	
  M.	
  Just	
  &	
  K.	
  Pelphrey	
  (Chair),	
  Development	
  and	
  Brain	
  Systems	
  in	
  Autism.	
  	
   	
  

Case 2:11-cv-04027-LDD Document 48-36 Filed 07/13/12 Page 81 of 84

Ami	
  Klin,	
  PhD	
  	
  	
  	
  	
  	
  	
  	
  	
  

	
  

	
  

	
  

	
  Page	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  6	
  	
  	4
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
   	
  	
  

	
  

	
  

Symposium	
  conducted	
  at	
  the	
  meeting	
  of	
  Carnegie	
  Mellon	
  University,	
  New	
  York,	
  NY:	
  Psychology	
  	
  

	
  

	
  

Press.	
  

	
  

e.	
   Books	
  and	
  Special	
  Journal	
  Issues:	
  

	
  

	
  

Klin,	
  A.,	
  Volkmar,	
  F.	
  R.,	
  &	
  Sparrow,	
  S.	
  S.	
  (Eds.).	
  (2000).	
  Asperger	
  Syndrome.	
  New	
  York,	
  NY:	
  Guilford	
  	
  

	
  

	
  

Press.	
  

	
  

	
  

Klin,	
  A.,	
  &	
  Volkmar,	
  F.	
  R.	
  (Eds.)	
  (2003).	
  Asperger	
  Syndrome.	
  Special	
  issue	
  of	
  Child	
  and	
  Adolescent	
  	
  

	
  

	
  

Psychiatric	
  Clinics	
  of	
  North	
  America,	
  12.	
  

	
  

	
  

Volkmar,	
  F.	
  R.,	
  Paul,	
  R.,	
  Klin,	
  A.,	
  &	
  Cohen,	
  D.	
  J.	
  (Eds.).	
  	
  (2005).	
  Handbook	
  of	
  Autism	
  and	
  Pervasive	
  	
  

	
  

	
  

Developmental	
  Disorders,	
  3rd	
  edition.	
  New	
  York,	
  NY:	
  Wiley	
  &	
  Sons.	
  

	
  

	
  

Volkmar,	
  F.	
  R.	
  &	
  Klin,	
  A.	
  (Eds.).	
  (2005).	
  Special	
  issue	
  on	
  Asperger	
  Syndrome.	
  Journal	
  of	
  Autism	
  	
   	
  

	
  

	
  

Developmental	
  Disorders,	
  35(2).	
  

	
  

	
  

	
  

Klin,	
  A.	
  &	
  Baron-­‐Cohen,	
  S.	
  (Eds.).	
  (2006).	
  The	
  cognitive	
  neuroscience	
  of	
  Asperger	
  syndrome.	
  Brain	
  	
  

	
  

	
  

Cognition,	
  61.	
  	
  

	
  

	
  

Klin,	
  A.	
  &	
  Mercadante,	
  M.	
  T.	
  (Eds.).	
  (2006).	
  Special	
  supplement	
  on	
  autism.	
  Brazilian	
  Journal	
  of	
  	
   	
  

	
  

	
  

Psychiatry	
  (Revista	
  Brasileira	
  de	
  Psiquiatria),	
  28	
  (Supl	
  I),	
  S1-­‐2.	
  [PMID:	
  16791386]	
  

	
  

	
  

Chawarska,	
  K.,	
  Klin,	
  A.,	
  &	
  Volkmar,	
  F.	
  R.	
  (Eds.).	
  (2008).	
  Autism	
  Spectrum	
  Disorders	
  in	
  Infants	
  and	
  	
  

	
  

	
  

Toddlers:	
  diagnosis,	
  assessment	
  and	
  treatment.	
  New	
  York,	
  NY:	
  	
  Guilford	
  Press.	
  

	
  

	
  

	
  

	
  

	
  

Case 2:11-cv-04027-LDD Document 48-36 Filed 07/13/12 Page 82 of 84
Legal	
  consultations	
  from	
  January	
  1	
  2008	
  through	
  June	
  8	
  2012	
   Ami	
  Klin	
  PhD	
   	
   	
  
2008	
   	
   01.	
   Beverly	
  A.	
  Sandacz	
   Roetzel	
  &	
  Andress	
   1375	
  East	
  Ninth	
  Street	
   One	
  Cleveland	
  Center,	
  Ninth	
  Floor	
   Cleveland	
  OH	
  	
  44114	
   Tel.:	
  216	
  615	
  4834	
   	
   Consultation	
  only;	
  no	
  deposition	
  or	
  trial.	
  	
   	
   02.	
  	
   Mr.	
  Curt	
  J.	
  Schiner	
   Lester	
  Schwab	
  Katz	
  &	
  Dwyer,	
  LLP	
   120	
  Broadway	
   New	
  York	
  NY	
  	
  10271-­‐0071	
   Tel.:	
  (212)	
  341-­‐4462	
   e-­‐mail:	
  cschiner@lskdnylaw.com	
  	
   	
   Consultation	
  only;	
  no	
  deposition	
  or	
  trial.	
  	
   	
   03.	
  	
   Guadalupe	
  Ayala	
   Mitigation	
  Specialist,	
  CLU	
   State	
  Appellate	
  Public	
  Defender	
   State	
  of	
  Idaho,	
  Office	
  of	
  the	
  State	
  Appellate	
  Public	
  Defender	
   3647	
  Lake	
  Harbor	
  Lane	
   Boise	
  ID	
  	
  83703	
   Tel.:	
  (208)	
  334-­‐2712	
   	
   Consultation	
  only;	
  no	
  deposition	
  or	
  trial.	
  	
   	
   04.	
   Mr.	
  Mark	
  Sherman	
   Sherman,	
  Richichi	
  &	
  Hickey,	
  LLC	
   27	
  Fifth	
  Street	
   Stamford	
  CT	
  	
  06905-­‐5082	
   Tel:	
  203	
  324	
  2296	
   Fax:	
  203	
  348	
  7313	
  

Case 2:11-cv-04027-LDD Document 48-36 Filed 07/13/12 Page 83 of 84
www.srh-­‐law.com	
   	
   Consultation	
  only;	
  no	
  deposition	
  or	
  trial.	
  	
   	
   	
  
2009	
   	
   05.	
   Gregory	
  K.J.	
  Wells	
   Shadoan,	
  Michael	
  &	
  Wells,	
  LLP	
   Attorneys	
  at	
  Law	
   108	
  Park	
  Avenue	
   Rockville,	
  Maryland	
  20850	
   Tel.:	
  301-­‐762-­‐5150	
   	
   Consultation	
  and	
  deposition;	
  no	
  trial.	
  	
   	
   06.	
   Mr.	
  Joseph	
  J.	
  Bottiglieri	
  	
   Bonner	
  Kiernan	
  Trebacho	
  Crociata,	
  LLP	
   1233	
  20th	
  St.,	
  NW	
   Suite	
  800	
   Washington	
  DC	
  20036	
   	
   Consultation,	
  deposition,	
  and	
  trial.	
  	
   	
   07.	
   Mr.	
  Michael	
  E.	
  Reed	
  and	
  Ms.	
  Erin	
  M.	
  Diaz	
   Law	
  Offices,	
  Wicker,	
  Smith,	
  O’Hara,	
  McCoy	
  &	
  Ford,	
  P.A.	
   100	
  North	
  Tampa	
  Street,	
  Suite	
  3650	
   P.O.Box	
  2152	
   Tampa,	
  Florida	
  33602	
   	
   Consultation	
  only;	
  no	
  deposition	
  or	
  trial.	
  	
   	
   08.	
   Attorney	
  Stuart	
  G.	
  Glass	
   Kimberly	
  Davidson,	
  Legal	
  Assistant	
   Lester	
  Schwab	
  Katz	
  &	
  Dwyer,	
  LLP	
   120	
  Broadway	
   New	
  York	
  NY	
  10271-­‐0071	
   Tel.:	
  212-­‐964-­‐6611	
   Fax:	
  212-­‐267-­‐5916	
   Tel.	
  direct:	
  212-­‐341-­‐4222	
  

Case 2:11-cv-04027-LDD Document 48-36 Filed 07/13/12 Page 84 of 84
e-­‐mail:	
  kdavidson@lskdnylaw.com	
  	
   	
   Consultation	
  only;	
  no	
  deposition	
  or	
  trial.	
  	
   	
   	
  
2010	
   09.	
   Kirsten	
  R.	
  Daniel	
   Clerk:	
  Sara	
  B.	
  Goodman	
   Oldfather	
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 </s> IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF PENNSYLVANIA

P.V., a minor, by and through his Parents,

:

Pedro Valentin and Yolanda Cruz,

individually, and on behalf of all others

:

similarly situated, et al.,

:

Plaintiffs,

:

v.

:

The School District of Philadelphia, et al.,

CIVIL ACTION NO. 2:11-cv-04027

Defendants.

:

Legrome D. Davis, J.

MEMORANDUM

February 19, 2013

I. BACKGROUND A. Statutory Framework of IDEA The crux of Plaintiffs’ case relates to alleged violations of the Individuals with
Disabilities Education Act (“IDEA”), 20 U.S.C. § 1400 et seq. (1996). Before addressing the facts, it is helpful to understand the statutory framework of the IDEA. The IDEA seeks to provide all children with disabilities with “a free appropriate public education [“FAPE”] which emphasizes special education and related services to meet their unique needs.” 20 U.S.C. § 1400. To ensure that the disabled child receives an educational program tailored to his or her specific needs, the child’s parents, teacher, and a representative of the local education agency collaborate to design an “individualized education program” (“IEP”) for the child. 20 U.S.C. § 1414. Based on the child’s individual needs, the IEP sets forth the child’s educational level,

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performance, and goals. After the IEP is drafted, the School District issues a Notice of Recommended Educational
Placement (“NOREP”),1 which contains a form to either approve or disapprove the IEP. The NOREP must include a description and explanation of the action taken by the school district and a disclosure that the child’s parents may challenge the school district’s decision. See § 1415(c). To ensure parents retain the opportunity to stay involved on decisions affecting their child’s IEP, the parents must also be provided with a NOREP whenever the school district “proposes to initiate or change” the “educational placement of the child.” 20 U.S.C. § 1415.
B. Factual Background and Procedural History This class action was initiated by parents of students with autism, who allege that the School District of Philadelphia (the “School District”) transfers autistic students in kindergarten through eighth grade (“K-8") without providing the level of parental notice and involvement required under state and federal law. Seeking systemic relief for the alleged violations, Plaintiffs filed a motion for class certification, which we granted.2 In the 2011-2012 school year, 1,684 students in K-8 in the School District were identified as having autism (See Doc. No. 51, Ex. 8), most of whom require access to an autistic support
1 NOREP is essentially the state version of “Prior Written Notice” under § 1415 of the IDEA. (See Doc. No. 51, Ex. 3, at 12). The two phrases will be used interchangeably throughout this opinion.
2 The class is defined as: All children with autism in the School District of Philadelphia in grades kindergarten through eight (“K-8") who have been transferred, are in the process of being transferred, or are at risk of being transferred, as a result of the School District’s upper-leveling process, the parents and guardians of those children, and future members of the class. 2

classroom. (See Doc. No. 51, Ex. 21, at 55). Depending on the child’s age, he or she will be
placed into one of three autistic support classrooms based on “grade level”: kindergarten through
second grade (“K-2"), third grade through fifth grade (“3-5"), and sixth grade through eighth
grade (“6-8"). (See Doc. No. 51, Ex. 3, at ¶ 2). Although there are three different groups, a
school sometimes offers only one grade level of autistic support. When a student requiring
autism support completes the highest grade level provided in his or her current school, the School
District transfers that student to a different school where those services can continue to be provided.3 (See Doc. No. 49, Ex. L, at 43; Ex. G, at 104). This process is referred to as an “upper-level transfer” or “upper leveling.”4 (See Doc. No. 49, Ex. L, at 38; Doc. No. 51-1, at ¶
10; Doc. No. 51, Ex. 3, at ¶¶ 14-16).
The building assignment decision is not made by a student’s IEP team and parents are
generally not involved in the process. (See Doc. No. 51, Ex. 21, at 57; Doc. No. 51, Ex. 3, at ¶
23; Doc. No. 54, at ¶ 25). Rather, the building assignment is determined “pretty much
unilaterally” by the School District’s division directors. (Doc. No. 51, Ex. 3, at ¶ 23; see also
Doc. No. 49, Ex. L, at 55). To make the determination, the directors first consider the number of
3 For example, a student may be in a K-2 program, but the school does not have a 3-5 program. Once that student reaches the end of his K-2 program, he would be transferred to a different school in the district that has a 3-5 program. In contrast, a non-disabled student attending a K-5 school generally continues at that school for all six grade levels unless she moves or is transferred for disciplinary reasons.
4 “Upper-leveling” does not seem to be limited to the transfer of students with autism. Rather, it seems to refer more generally to the transfer of any student, including non-disabled students, that reach the end of their age-limit grade. (See Doc. No. 49, Ex. M, at 38; Doc. No. 54, Ex. 8, at 38). However, for purposes of this Memorandum, “upper-leveling” refers strictly to the transfer of children with autism to different schools within the School District when they reach the end of their age-limit grade.
3

students coming to the School District known to require services in an autistic support program, as well as building locations with available space for autistic support classrooms. The directors then consider each student’s IEP and “place[] each student with autism in the school that [they feel] will best meet that student’s needs.” (Doc. No. 51, Ex. 20, at ¶ 8).
The School District concedes that it provides parents with no written notice prior to the building assignment decision. Rather, the School District generally does not advise parents that their child will be transferred until after the decision concerning the transfer has been made. (See Doc. No. 54-1, at ¶ 31). The first notification to the student’s parents about their child’s transfer comes from the student’s school, and is usually issued in late spring. There is no formal procedure for the initial notification; parents may be informed of the transfer through a meeting, phone call, or simply an email. (See Doc. No. 48, Ex. 21, at 66-67). A few weeks later, the division directors send a “follow up” letter to “ensure that the parent is informed.” (Id.).
Although the School District eventually notifies parents that their child will be transferred, it admits that is has no formal policy governing the adequateness of that notification. (See Doc. No. 54-1, at ¶ 36). The discovery materials provided by Plaintiffs reflect that the notification given to parents about the transfer of their autistic child is often terse, at best. In one instance, for example, a student with autism was sent home with only a “strip” of paper, stating that the child would be attending a different school the following year. The strip of paper did not include the location of the student’s new school, of which the parents were not informed until only a few weeks before the new school year. (See Doc. No. 51-1, Ex. 22; Ex. 32, at 50-53; see also Doc. No. 51-1, at ¶ 40; Doc. No. 54-1, at ¶ 40).
In another instance, the mother of an autistic child received only an oral comment from
4

her child’s teacher, telling her that her child might be transferred from Richmond Elementary to another school in the fall. Despite receiving no formal or written notice about the possibility of a transfer for her child, the mother began receiving transportation letters, indicating that her child would be attending Feltonville Elementary School that fall. When the school year started, however, the child’s mother was informed through a secretary that her son would actually remain at Richmond. (See Doc. No. 51-1, Ex. 31, at 583-84; see also Doc. No. 51-1, at ¶ 39; Doc. No. 41, at ¶ 39). Plaintiffs present additional evidence, reflecting similar scenarios.5
Plaintiffs now bring this class action lawsuit against the School District of Philadelphia, seeking systemic relief from the allegedly unlawful process of “upper leveling.” Throughout this litigation process, the declaratory and prospective injunctive relief sought by Plaintiffs has seemingly varied between the Complaint and subsequent motions. On a very broad scale, Plaintiffs ask this Court to order the School District to completely discontinue the upper-leveling transfer process, and require “that any school which contains an autism support classroom shall offer autism programming for the same years that the school provides programming for children who are not disabled.” (Doc. No. 1, at 21-22; see also Doc. No. 48, at 1-2). Short of eliminating the upper-leveling process in its entirety, Plaintiffs seek this Court to order the School District to provide for a level of parental notice and involvement prior to the transfer decision that is consistent with the requirements set forth by state and federal education law. (See Doc. No. 1, at 8; Doc. No. 17, at 2l Doc. No. 48, at 2). To obtain that level of parental involvement, Plaintiffs
5 See, e.g., Doc. No. 61, Ex. 39 (An internal School District email states: “I received a call from the parent of an [autistic support] student . . . he is part of the upper level process . . . no one sent the father a letter stating where his son will attend in September . . . shall we send him a letter . . . please advise.” As of July 27, 2010, the response indicated that the “[transfer] letters had not gone out yet.”).
5

maintain that the School District must publicly disseminate a list of all the schools within the School District that house any autistic support classroom. (See Doc. No. 1, at 21; Doc. No. 17, at 2; Doc. No. 48, at 2).
Plaintiffs emphasize that they cannot obtain this structural relief through an administrative hearing, so judicial intervention is necessary. Specifically, Brian Jason Ford, the hearing officer presiding over P.V.’s and M.M.’s (two of the four named plaintiffs) administrative hearings, concluded that “the District violated the Parent’s right to participation by reassigning the Student [P.V. and M.M.] to a different school building without sending IDEAcompliant prior written notice.” (Doc. No. 51, Ex. 3, at 15; Ex. 4, at 16). Ford noted, however, that he “lacks authority to order wholesale changes to the District’s procedures,” so he merely encouraged the School District “to alter its procedures on a broader scope, if only to avoid a plethora of identical claims from similarly situated students.” (Id.).
Plaintiffs bring this class action seeking systemic relief from the School District’s process of upper-leveling children with autism. In the first two counts of the Complaint, Plaintiffs allege that the process of upper-leveling violates the Individual and Disabilities Act, 20 U.S.C. § 1400 et seq. (“IDEA”) and Chapter 14 of the Pennsylvania Code (“Chapter 14"), “as it occurs with little or no parental notice or involvement, without required consideration of children’s individualized circumstances, and in direct violation of the mandated individual planning process of the IDEA.” In the other two counts, Plaintiffs contend that upper-leveling violates § 504 of the Rehabilitation Act (“§ 504"), and Title II of the American with Disabilities Act (“ADA”), because the transfer “is based solely on the fact that children have autism.” (Doc. No. 1, at ¶ 2). Both parties have filed motions for summary judgment, which are now ripe for disposition.
6

II. LEGAL ANALYSIS A. Standard of Review 1. Summary Judgment Under Federal Rule of Civil Procedure 56(a), we must “grant summary judgment if the
movant shows that there is no genuine dispute as to any material fact and the movant is entitled to judgment as a matter of law.” Summary judgment is appropriate where “the nonmoving party has failed to make a sufficient showing on an essential element of her case with respect to which she has the burden of proof.” Celotex Corp. v. Catrett, 477 U.S. 317, 323 (1986). Accordingly, the nonmoving party cannot avoid summary judgment “merely by restating the allegations of his complaint, but must point to concrete evidence in the record that supports each and every essential element of his case.” Orsatti v. New Jersey State Police, 71 F.3d 480, 484 (3d Cir. 1995) (citing Celotex, 477 U.S. at 322). “The mere existence of a scintilla of evidence in support of the [non-movant]’s position will be insufficient; there must be evidence on which the jury could reasonably find for the [non-movant].” Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 252 (1986). Where, as here, the parties file cross-motions for summary judgment, the Court “construes facts and draws inferences in favor of the party against whom the motion under consideration is made." Pichler v. UNITE, 542 F.3d 380, 386 (3d Cir. 2008) (quotation omitted).
2. Review of Administrative Record The Third Circuit makes clear that a district court must review an IDEA decision by a state administrative agency under a “modified” de novo standard. L.E. v. Ramsey Bd. of Educ., 435 F.3d 384, 389 (3d Cir. 2006). Under this modified standard, we must afford “due weight” to the factual findings from the administrative proceedings, and consider those facts “prima facie”
7

correct. See id., S.H. v. State-Operated School Dist. of City of Newark, 336 F.3d 260, 270 (3d Cir. 2003). The District Court may, as the case here, consider evidence in addition to the factual record developed at the administrative level. “[W]here the District Court hears additional evidence it is ‘free to accept or reject the agency findings depending on whether those findings are supported by the new, expanded record and whether they are consistent with the requirements of the [IDEA].’” Id. (quoting Oberti v. Bd. of Educ. of the Borough of the Clementon Sch. Dist., 995 F.2d 1204, 1220 (3d Cir. 1993)).
Notably, the “due weight” given to the factual findings from the administrative proceedings is “‘not implicated with respect to the issues of law, such as the proper interpretation of the [IDEA] and its requirements,’ that is, the district court owes no deference to conclusions of law drawn by a state or local educational agency.” In re: Educational Assignment of Joseph R., 318 Fed. Appx. 113, 118 (3d Cir. 2009) (non-precedential) (quoting Lillbask ex rel. Mauclaire v. Conn. Dep’t of Educ., 397 F.3d 77, 82 (2d Cir. 2005)).
B. Standing The three “irreducible” constitutional elements of standing are: (1) an injury in fact that is actual or imminent, not “conjectural” or “hypothetical”; (2) a causal connection between the injury and the conduct complained of – the injury must be fairly traceable to the challenged action of the defendant; and (3) a showing that it is likely, as opposed to merely speculative, that a favorable decision will redress the injury. Lujan v. Defenders of Wildlife, 504 U.S. 555, 56061 (1992). Plaintiffs need not demonstrate actual harm or monetary damages to establish standing. On the contrary, “the actual or threatened injury required by Art. III may exist solely by virtue of statutes creating legal rights, the invasion of which creates standing.” Alston v.
8

Countrywide Fin. Corp., 585 F.3d 753, 763 (3d Cir. 2009). Here, Defendants once again contend that Plaintiffs lack standing because they were
never physically transferred pursuant to the District’s upper-leveling process, and therefore, have suffered no “injury in fact.” Defendants raised this same argument at the motion to dismiss level, which we rejected. We explained that:
Even though Plaintiffs currently attend their preferred school, Plaintiffs will continue to be subject to the District’s allegedly IDEA-deficient educational placement process from year to year. As such, Plaintiffs’ injuries are imminent, not merely conjectural or hypothetical, and a favorable court decision will likely redress the systemic failures, if any, in the District’s practices regarding the educational placement and transfer of autistic students. Therefore, under Lujan, Plaintiffs have standing to pursue their claims. P.V. v. Sch. Dist. of Phila., No. 2:11-cv-04027, 2011 WL 5127850, at *11 (E.D. Pa. Oct. 31, 2011). Defendants further argue that Plaintiffs provide no evidence of “any student whose academic or behavioral progress has ever been adversely affected by transfer.” (Def.’s Mot. for Sum. Judgment, at 12). Regardless, Defendants fail to realize that the crux of Plaintiff’s IDEA claim stems from the School District’s lack of parental involvement leading up to the transfer decision of their student. As we discuss infra, Plaintiffs do provide evidence that the School District provides almost no parental involvement or notice prior to the transfer decisions, which Plaintiffs allege is a violation of the IDEA. For all the foregoing reasons, Plaintiffs have standing under Lujan to pursue their claims.
9

C. IDEA & Chapter 146 Courts generally conduct a two-step inquiry to determine whether a school district complied with the IDEA. First, courts determine whether the school district complied with the procedural safeguards set forth by the IDEA and state law. Second, the court evaluates whether the IEP is reasonably calculated to enable the child to receive educational benefit. D.S. v. Bayonne Bd. of Educ., 602 F.3d 553, 565 (3d Cir. 2010). However, the second step is unnecessary if the violation of the IDEA’s procedure “results in a loss of educational opportunity for the student, seriously deprives parents of their participation rights, or causes a deprivation of educational benefits.” Id. Accordingly, our inquiry begins with whether the School District violated any procedural safeguards under the IDEA.
1. The Meaning of “Educational Placement” Under the IDEA Both parties recognize that under the procedural safeguards of the IDEA, the School District must provide for meaningful parental participation and prior written notice whenever it initiates or proposes to change the “educational placement” of a child.7 Plaintiffs allege that the School District’s process of upper-leveling autistic students violates the IDEA’s procedural safeguards because it changes an autistic student’s educational placement without notifying
6 Chapter 14 reflects Pennsylvania’s compliance with the IDEA requirements, and incorporates federal IDEA regulations. 22 Pa. Code § 14.102.
7 See 20 U.S.C. § 1415(b)(1),(3) (stating that there must be “[a]n opportunity for the parents of a child with a disability . . . to participate in meetings with respect to the . . . educational placement of the child . . .” and provision of “[w]ritten prior notice to the parents of the child, in accordance with subsection (c)(1), whenever the local educational agency proposes to initiate or change . . . the . . . educational placement of the child . . .”); see also 20 U.S.C. § 1414(e) (requiring “that the parents of each child with a disability are members of any group that makes decisions on the educational placement of their child”).
10

parents prior to the decision and also precludes parents from participating in the transfer decision. The School District contends that there is no legal requirement to involve parents in the transfer decision because upper-leveling does not change a student’s educational placement.
Specifically, Defendants argue that “educational placement” refers only to “educational programming and services – not the location at which a student receives educational programming and services.” (Doc. No. 54, at 7). Because there is no proof or claim that the programming and services provided at different schools within the district vary in any relevant respect, Defendants contend that upper-leveling is simply changing the physical location of where an autistic student receives his IEP. Thus, this Court must resolve whether transferring students with autism to a different a school building within the same school district constitutes a change in “educational placement” for purposes of requiring parental involvement under the IDEA.
Unfortunately, neither the text nor legislative history of the IDEA defines the term “educational placement.” The Third Circuit has stated, however, that “given the remedial purposes of the [IDEA], the term . . . should be given an expansive reading.” DeLeon v. Susquehanna Cmty. School Dist., 747 F.2d 149, 153 (3d Cir. 1984). The touchstone of whether a modification in a child’s school day should be considered a change in his or her educational placement is “whether the decision is likely to affect in some significant way the child’s learning experience.” Id. Thus, “[t]he question of what constitutes a change in educational placement is, necessarily, fact specific.” Id. at 153.
“As a general matter, the location of the services is not conclusive in determining what
11

constitutes the educational placement of the student.” George A. v. Wallingford Swarthmore School Dist., 655 F. Supp. 2d 546, 550 (E.D. Pa. Sep. 3, 2009). However, “[location] cannot be entirely divorced from the inquiry.” Id. For instance, courts in the Third Circuit have recognized that distance between classrooms, available facilities, or a student’s history at a particular school are relevant to the determination of educational placement. See, e.g., R.B. v. Mastery Charter School, 762 F. Supp. 2d 745, 763 (E.D. Pa. Dec. 29, 2010); George A., 655 F. Supp. 2d at 551. Thus, “[t]he meaning of ‘educational placement’ falls somewhere between the physical school attended by a child and the abstract goals of a child’s IEP.” R.B., 762 F. Supp. 2d at 763 (citations and internal quotation marks omitted).
To support its contention that upper-leveling is not a change in an autistic student’s educational placement, the School District relies on In re Educ. Assignment of Joseph R., 318 Fed. Appx. 113 (3d Cir. 2009). Even in this non-precedential opinion, the Third Circuit recognizes that determining what constitutes a change in educational placement is a factintensive inquiry. Based on the facts before it, the court in Joseph R., held that relocating a student with learning disabilities from a resource classroom to an inclusion classroom within the same building did not amount to a “change in educational placement” under the IDEA. In Joseph R., plaintiffs provided no evidence that the move to an inclusion room would likely affect the student’s learning experience in any significant way. The student received the same educational services on a daily basis, with the same special education teacher, but in a different room in the building.
While seemingly similar to Joseph R. at first glance, the facts in this case are materially
12

distinguishable and warrant different considerations. Unlike Joseph R., upper-leveling does not involve moving a child to a new classroom within the same school; rather, it relocates a child to an entirely novice infrastructure. Unlike an intra-school transition, as was the case in Joseph R., a transfer to a different school building often requires a longer commute on the bus, separation from former classmates, and acclimation to an unfamiliar environment. (See Doc. No. 51, Ex. 16, at 195).
The physical adjustments accompanied by an upper-level transfer are significant because of another major factual distinction: the students being transferred in this case have autism. In Joseph R., there was no indication that because the student had a learning disability, a change in his physical location may affect his learning experience. In contrast, an unplanned transition for children with autism is likely to affect their learning rate and learning sequences. (See Doc. No. 49, Ex. Q, at 31). This is because difficulty with transition is one of the defining characteristics of children with autism. (See Doc. No. 51, Ex. 1, at 4). Thus, despite the School District’s contention to the contrary, upper-leveling students with autism does not merely change their physical surroundings; the transition is likely to have a significant impact on their learning experience. Accordingly, we must conclude that under the particular facts of our case, upperleveling students with autism to a separate school building in the School District constitutes a change in their “educational placement” under the IDEA.
The cases outside of the Third Circuit to which the School District cites do not suggest a different outcome. From the number of out-of-circuit appellate decisions purported to support its contention, the School District lists only one that involves a student with autism: T.Y. v. N.Y.
13

City Department of Education, 584 F.3d 412 (2d Cir. 2009). The Third Circuit has never adopted T.Y., and regardless, its holding is not contrary to our conclusion. The court in T.Y., “simply [held] that an IEP's failure to identify a specific school location will not constitute a
per procedural violation of the IDEA.” Id. at 420. Notably, the parents in T.Y. participated in se selecting the school for their child prior to the final assignment and “worked cooperatively” with the school district in arriving at the decision. Therefore, the School District’s reliance on T.Y., in this case is misplaced.
The only factually analogous case that the School District cites is an unreported opinion that stems from the Middle District of Florida. In L.M. v. Pinellas County School Board, the district court found that the transfer of a student with autism from one school to another in the district “does not amount to a change in her educational placement within the meaning of the stay-put provision.” No. 10-539, 2010 U.S. Dist. LEXIS 46796, at *5 (M.D. Fla. April 11, 2010). In reaching its conclusion, the short opinion relied upon cases outside the Third Circuit, and gave short shrift to the role of transition for children with autism. Thus, beyond its nonbinding effect in the Third Circuit, the L.M. opinion is simply not persuasive.
3. Parental Participation and Prior Written Notice Requirements Because we conclude that upper-leveling constitutes a change in “educational placement” for students with autism, we must now determine whether the School District’s current level of parental participation and prior written notice suffices under the procedural safeguards of the IDEA. The School District concedes it does not permit the students’ parents to participate in the transfer decisions on any meaningful level. Instead, parents learn of the new building assignment
14

only after it has been unilaterally decided upon by division directors, with no opportunity for parents to contribute to the discussion. The notification is sometimes no more than one sentence on a strip of paper, informing the parent that their child will be attending a different school in the fall.
Moreover, the notification is generally sent only weeks prior to the start of the next school year, leaving parents minimal time to plan for their autistic child’s transition from one educational setting to another. Such terse notification falls short of the IDEA’s procedural safeguards, which require, among other things, a written explanation of why the transfer is proposed, what other options were considered, and why those other options were rejected. See § 1415(c). We therefore conclude that the School District’s process of upper-leveling children with autism violates the procedural safeguards under the IDEA, and “seriously deprives” parents the opportunity to participate in the decision-making process regarding the educational placement of their autistic child. Accordingly, the School District is ordered to alter its upper-leveling process for children with autism to provide prior written notice and a level of parental participation that complies with the procedural requirements under the IDEA.8
We emphasize that the School District retains “‘significant authority to select the school site, as long as it is educationally appropriate.’” Lebron v. North Penn School Dist., 769 F. Supp. 2d 788, 800 (E.D. Pa. Feb. 14, 2011) (quoting White ex rel. v. Ascension Parish Sch. Bd., 343
8 Because we conclude that the School District’s violation of the IDEA’s procedural safeguards seriously deprives parents of their participation rights, we need not address Plaintiffs’ claim that upper-leveling fails to comport with IEP requirements.
15

F.3d 373, 382 (2003).9 By no means does our holding suggest that parents of children with autism are entitled to any type of “veto power” over the final location decision. We simply conclude that under the IDEA, the School District cannot categorically deny parents the opportunity to provide input and receive notice about the educational placement of their autistic child.
E. ADA & § 504 of the Rehabilitation Act In addition to alleging violations of the IDEA and Chapter 14, Plaintiffs also contend that the School District’s process of upper-leveling violates the ADA and § 504 of the Rehabilitation Act. Unlike their IDEA claim, however, Plaintiffs seem not to allege that the violation stems from a lack of parental participation or prior notice. Rather, Plaintiffs argue that transferring autistic students at a grade earlier than non-disabled children constitutes discrimination and an unreasonable accommodation in violation of the ADA and § 504. (See Doc. No. 51, at 23). To establish a violation of § 504 of the Rehabilitation Act,10 Plaintiffs must prove that (1) they are disabled; (2) they are “otherwise qualified” to participate in school activities; (3) the School District received federal financial assistance; and (4) they were excluded from
9 For that reason, we refuse to force the School District to provide parents a list of the building locations of autistic support classrooms. Beyond conclusory allegations, Plaintiffs provide no evidence that such a list is necessary to effectuate the School District’s compliance with the procedural requirements of the IDEA.
10 The elements of a claim under the ADA and § 504 are nearly identical. The only difference is that § 504 also requires the entity against whom the violation is alleged to receive federal assistance. See Muhammad v. Court of Common Pleas of Allegheny Cnty., Pa, 483 Fed. Appx. 759, 762-763 (3d Cir. 2012) (citing Helen L. v. DiDario, 46 F.3d 325, 330 n.7 (3d Cir. 1995)).
16

participation in, denied the benefits of, or subject to discrimination by the School District. Ridley School Dist. v. M.R. 680 F.3d 260, 280 (3d Cir. 2012) (citing Ridgewood Bd. of Educ. v. N.E. ex rel. M.E., 172 F.3d 238, 253 (3d Cir. 1999)). The parties do not dispute the first three elements. (See Doc. No. 49, at 37). Rather, the only issue is whether Plaintiffs were denied the benefit of an education program or were subject to discrimination by the School District.
Plaintiffs allege that the School District’s upper-leveling policy creates an inference of discrimination. (See Doc. No. 62, at 23). Courts in the Third Circuit have observed that for purposes of ADA and § 504, discrimination can be inferred from a school district’s “deliberate indifference” toward its students with disabilities. See, e.g., Chambers v. School Dist. of Philadelphia Bd. of Educ., 827 F. Supp. 2d 409, 425 (E.D. Pa. Oct. 24, 2011); Adam C. v. Scranton Sch. Dist., No. 3:07-cv-532, 2011 WL 4072756, at *5-6 (M.D. Pa. Sept. 13, 2011). Here, Plaintiffs contend that the School District is deliberately indifferent to students with autism because it will “knowingly upper-level transfer students without regard to their individual needs.” (Doc.No. 64, at 12). The record makes clear, however, that the School District does not make any transfer decisions until taking into account each student’s individualized education plan. (See Doc. No. 51, Ex. 19, at 8). Moreover, the School District ensures that the student is transferred to the appropriate school building nearest to his or her home. (See Doc. No. 54, Ex. 8, at 72). Despite the lack of parental involvement in these decisions, there is no indication that the School District knew about the accommodations required for students with autism and chose deliberately to ignore them. To the contrary, the School District upper-levels students with autism in order to provide them with adequate accommodations.
17

Plaintiffs also contend that transferring students with autism to different schools within the district is not a reasonable accommodation under the ADA and § 504. Plaintiffs argue that this Court should require the School District to “ensure that any [K-8] school which contains an autism support classroom shall offer autism programming for the same years that the school provides programming for children who are disabled.” (Doc. No. 1, at 22).
Under § 504, a “school district must reasonably accommodate the needs of the handicapped child so as to ensure meaningful participation in educational activities and meaningful access to educational benefits.” Ridley School Dist. v. M.R. 680 F.3d 260, 280 (3d Cir. 2012) (citations omitted). “However, § 504 does not mandate ‘substantial’ changes to the school's programs, and courts should be mindful of the need to strike a balance between the rights of the student and h[er] parents and the legitimate financial and administrative concerns of the [s]chool [d]istrict.” Id., at 180-81 (internal quotation marks and citation omitted).
Here, presumably due to financial and administrative concerns, the School District does not provide autistic support in every grade level at every school in the District. As a result, the School District must sometimes transfer a student with autism to a different school to ensure that he or she receives the services and programs set forth in his or her IEP in an age-appropriate setting. As we discussed at length earlier, such a transition is likely to affect the educational experience of a child with autism. Beyond that, however, Plaintiffs provide no proof that the services received by a transferred student with autism are deficient, so as to prevent that student from gaining a meaningful access to educational benefits. Compare Adam C., 2011 U.S. Dist. LEXIS 102981. To the contrary, the students are transferred to ensure they continue to receive
18

adequate services pursuant to their IEP. For that reason, we cannot find that transferring students with autism to ensure they receive their IEP in an age-appropriate setting is an unreasonable accommodation under the ADA or § 504. III. CONCLUSION
First, we conclude that Plaintiffs have standing to pursue their claims. Second, we conclude that the School District’s process of upper-leveling children with autism violates the procedural safeguards under the IDEA, and seriously deprives parents the opportunity to participate in the decision-making process regarding the educational placement of their autistic child. Third, we conclude that the School District’s process of upper-leveling children with autism does not violate the ADA or § 504 of the Rehabilitation Act. Accordingly, Plaintiffs’ Motion for Summary Judgment (Doc. No. 51) is GRANTED in part and DENIED in part. Similarly, Defendants’ Motion for Summary Judgment (Doc. No. 49) is GRANTED in part and DENIED in part. An appropriate Order follows this Memorandum.
BY THE COURT: /s/ Legrome D. Davis Legrome D. Davis, J.
19

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF PENNSYLVANIA

P.V., a minor, by and through his Parents,

:

Pedro Valentin and Yolanda Cruz,

:

individually, and on behalf of all others

:

similarly situated, et al.,

:

:

Plaintiffs,

:

:

v.

:

:

The School District of Philadelphia, et al.

:

:

Defendants.

:

CIVIL ACTION NO. 2:11-cv-04027

ORDER

AND NOW, this 19th day of February 2013, upon consideration of Defendants’ Motion for Summary Judgment (Doc. No. 49), Plaintiffs’ Motion for Summary Judgment (Doc. No. 51), Defendants’ Response to Plaintiffs’ Motion for Summary Judgment (Doc. No. 54), Plaintiffs’ Response to Defendants’ Motion for Summary Judgment (Doc. No. 62), Defendants’ Reply Brief in Further Support of their Motion for Summary Judgment (Doc. No. 63), Plaintiffs’ Reply Brief in Further Support of their Motion for Summary Judgment (Doc. No. 64), Defendants’ Surreply in Opposition to Plaintiffs’ Motion for Summary Judgment (Doc. No. 67), Plaintiffs’ Supplemental Memorandum (Doc. No. 69), and all exhibits attached thereto, it is hereby ORDERED as follows:

1. Defendants’ Motion for Summary Judgment (Doc. No. 49) is GRANTED in part and DENIED in part.

2. Plaintiffs’ Motion for Summary Judgment (Doc. No. 51) is GRANTED in part and DENIED in part.

3. Accordingly, the Philadelphia School District is ORDERED to alter its upper-leveling process for students with autism such that it provides class members with prior written notice and a level of parental participation consistent with the procedural requirements of the Individuals with Disabilities Education Act (“IDEA”), 20 U.S.C. § 1400 et seq. (1996).

4. No claims remain in this matter. Accordingly, the Clerk of Court is directed to close this matter for statistical purposes. BY THE COURT:

/s/ Legrome D. Davis Legrome D. Davis, J.

 </s> IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF PENNSYLVANIA

P.V., a minor, by and through his Parents,

:

Pedro Valentin and Yolanda Cruz,

individually, and on behalf of all others

:

similarly situated, et al.,

:

Plaintiffs,

:

v.

:

The School District of Philadelphia, et al.,

CIVIL ACTION NO. 2:11-cv-04027

Defendants.

:

MEMORANDUM

Legrome D. Davis, J.

February 19, 2013

This lawsuit concerns the School District of Philadelphia’s (the “School District”)

treatment of, and policies governing, school children with autism. The four (4) named plaintiffs

in the purported class action lawsuit, P.V., M.M., J.V., and R.S.,1 are all autistic students at

Richmond Elementary School, a Kindergarten through Grade 5 (“K-5") school in the

Philadelphia School District (the “School District”). (Doc. No. 1, at ¶¶ 15-18). Plaintiffs

contend that the School District transfers students with autism automatically from one school to

another, simply because they complete a certain grade, more frequently than the School District

transfers non-disabled students who therefore, unlike autistic children, enjoy continued,

1 Because the four named plaintiffs are all minors, this lawsuit was brought by and through their parents. Specifically, P.V. by and through his parents Pedro Valentin and Yolanda Cruz; M.M. by and through his parent Carla Murphy; J.V. by and through his parents Sharon Vargas and Ismael Vargas; and R.S. by and through his parents Heather Sanasac and Matthew Sanasac.
1

uninterrupted attendance in K-5 schools or K-8 schools. (Doc. No. 1, at ¶ 1). Plaintiffs further allege that the decision-making process leading up to the transfer of an autistic student is conducted with little to no parental notice or involvement, and without the required consideration of the children’s individualized circumstances. (Doc. No. 1, at ¶ 2). Plaintiffs contend that this is particularly problematic because children with autism have difficulty transitioning from one environment to another. (Doc. No. 1, at ¶ 1).
Claiming that the School District’s policy of transferring autistic students violates several statutes, the four (4) plaintiffs filed suit against the School District; the School Reform Commission; Arlene Ackerman, Superintendent of the School District of Philadelphia, in her official capacity; and Linda Williams, Interim Deputy Chief of Special Education for the School District of Philadelphia, in her official capacity (collectively, “Defendants”). Seeking systemic relief from the allegedly unlawful transfer policy, Plaintiffs filed a motion for class certification, which is now ripe for disposition. I. FACTS
Because we write primarily for the parties involved, we discuss only the facts relevant to resolving the instant motion. Unless stated otherwise, the following facts are not in dispute. In the 2011-2012 school year, over 1600 students in K-8 in the School District were identified as having autism. (See Doc. No. 48, Ex. 28; Doc. No. 50, Ex. 11; see also Doc. No. 48, Ex. 18, at 36). The School District provides autism support classrooms for these children, which are generally divided into three “grade levels” based on age: kindergarten through second grade (“K2"), third grade through fifth grade (“3-5"), and sixth grade through eighth grade (“6-8"). (See Doc. No. 1, at ¶ 36; Doc. No. 50, at 3). Although there are three different grade levels, a school
2

sometimes offers only one grade level of autism support. When a student requiring autism support completes the highest grade level provided in his or her current school, the School District transfers that student to a different school where those services can continue to be provided.2 (See Doc. No. 48, Ex. 21, at 43; Doc. No. 50, at 5). This process is referred to as an “upper-level transfer” or “upper-leveling.” (See Doc. No. 48, Ex. 21, at 37-39, 42-43; Doc. No. 50, Ex. 13, at 37-38).
The building assignment decision is not made by a student’s Individualized Education Program (“IEP”) team and parents are generally not involved in the process. (See Doc. No. 48, Ex. 2, at 3, ¶ 2; Doc. No. 50, at 5). Rather, the building assignment is determined predominantly by the School District’s division directors. (Doc. No. 48, Ex. 2, at 6; Ex. 3, see also Doc. No. 50, Ex. 12, at 55). To make that determination, the directors first consider the number of students coming to the School District known to require services in an autism support program, as well as building locations with available space for autism support classrooms. The directors then consider each student’s IEP and “place[] each student with autism in the school that [they feel] will best meet that student’s needs.” (Doc. No. 50, Ex. 16, at ¶ 8).
The School District concedes that it provides parents with no written notice prior to the building assignment decision. Rather, the School District generally does not advise parents that their child will be transferred until after the decision concerning the transfer has been made. (See
2 For example, a student may be in a K-2 autism support program, but the school does not offer a 3-5 program. Once that student reaches the end of his K-2 program, he would be transferred to a different school in the district that has a 3-5 program. In contrast, non-disabled students attending a K-5 school usually continue at that school for all six grade levels unless the family moves, the family requests the transfer, or for disciplinary reasons. (See Doc. No. 48, Ex. 2, at 5).
3

Doc. No. 50, Ex. 16, at 10). The first notification to the student’s parents about their child’s transfer comes from the student’s school, and is usually issued in late spring. There is no formal procedure for the initial notification; parents may be informed of the transfer through a meeting, phone call, or simply an email. (See Doc. No. 48, Ex. 21, at 66-67). A few weeks later, the division directors send a “follow up” letter to “ensure that the parent is informed.” (Id.). Although the School District eventually notifies parents that their child will be transferred, it admits that is has no formal policy governing the adequateness of that notification. (See Doc. No. 48, Ex. 21, at 72-75; Ex. 23, at 86-87).
Plaintiffs allege that the experiences of the named plaintiffs illustrate the inadequacies of the School District’s process of upper-leveling students with autism in grades K-8. For instance, P.V. is a student with autism who attends Richmond Elementary School. At the end of the 200910 school year, when P.V. was finishing second grade, Richmond offered only K-2 autism support in its building. Accordingly, the School District planned to transfer P.V. to another school when he finished second grade. At the end of the school year, P.V.’s mother received only a verbal warning from P.V.’s teacher that P.V. might be transferred from Richmond Elementary to another school in the fall. (Doc. No. 48, Ex. 11, at 583-84). Despite receiving no formal or written notice about the possibility of a transfer for her child, P.V.’s mother began receiving transportation letters over the summer, indicating that P.V. would be attending Feltonville Elementary School that fall. (Id.). When the school year started, however, P.V.’s mother was informed through a secretary that P.V. would in fact remain at Richmond. (Id.).
Like P.V., M.M. is a student with autism who attends Richmond Elementary School. On or around June 15, 2010, the School District advised M.M.’s mother via M.M.’s home-school
4

notebook that M.M. could no longer remain at Richmond for his third grade year during the 2010-11 school year. The note did not indicate to what school M.M. would be transferred. (See Doc. No. 48, Ex. 8, at 623-25). Throughout the summer of 2010, M.M.’s mother received no other information on the potential transfer until a few weeks prior to the start of the school year, and only after she contacted the School District directly.3 (See id. at 625-26).
Uncertain about where their children would be attending school that fall, the parents of P.V. and the parents of M.M. both filed for an administrative hearing in 2010, challenging, among other things, the School District’s upper-leveling process. (See Doc. No. 48, Exs. 1 and 2). In a consolidated ruling, the hearing officer, Brian Jason Ford, concluded that “the District violated the Parent’s right to participation by reassigning the Student [P.V. and M.M.] to a different school building without sending IDEA-compliant prior written notice.” (Doc. No. 48, Exs. 1 and 2, at 15). Ford noted, however, that he “lacks authority to order wholesale changes to the District’s procedures,” so he merely encouraged the School District “to alter its procedures on a broader scope, if only to avoid a plethora of identical claims from similarly situated students.”
3 Evidence produced during discovery suggests that absent class members have shared similar experiences with respect to notification and parental involvement throughout the upperleveling decision-making process. (See, e.g., Doc. No. 48, Ex. 16; Ex. 20, at 50-53 (student with autism sent home with only a “strip” of paper, stating that the child would be attending a different school the following year, but no indication as to the location of the student’s new school, of which the parents were not informed until only a few weeks before the new school year); Doc. No. 61, Ex. 39 (An internal School District email states: “I received a call from the parent of an [autistic support] student . . . he is part of the upper level process . . . no one sent the father a letter stating where his son will attend in September . . . shall we send him a letter . . . please advise.” As of July 27, 2010, the response indicated that the “[transfer] letters had not gone out yet.”); see also Doc. No. 61, at 8-9).
5

(Id.). 4 Plaintiffs bring this lawsuit seeking systemic relief from the School District’s allegedly
unlawful policy of upper-leveling children with autism.5 Plaintiffs emphasize that because they cannot obtain structural relief through an administrative hearing, judicial intervention and class action certification are necessary. The injunctive relief specifically sought by Plaintiffs has somewhat varied throughout their Complaint and subsequent motions. On a very broad scale, Plaintiffs ask this Court to order the School District to completely discontinue the upper-leveling transfer process, and require “that any school which contains an autism support classroom shall offer autism programming for the same years that the school provides programming for children who are not disabled.” (Doc. No. 1, at 21-22; see also Doc. No. 48, at 1-2). Short of eliminating the upper-leveling process in its entirety, Plaintiffs seek this Court to order the School District to provide for a level of parental notice and involvement prior to the transfer decision that is consistent with the requirements set forth by state and federal education law. (See Doc. No. 1, at 8; Doc. No. 17, at 2l Doc. No. 48, at 2). To obtain that level of parental involvement, Plaintiffs maintain that the School District must publicly disseminate a list of all the schools within the School District that house any autism support classroom. (See Doc. No. 1, at 21; Doc. No. 17, at
4 Plaintiffs J.V. and R.S. had similar experiences. The School District attempted to upper-level J.V. and R.S. – who both have autism and attend Richmond Elementary – after the second grade without issuing prior written notice or providing their parents with any meaningful level of participation in the decision-making process. According to Plaintiffs, J.V. and R.S. prevented their transfer from Richmond only after they each filed a due process complaint. (See Doc. No. 1, at ¶¶ 17-18; Doc. No. 48, at 11; Ex. 3, at 4; Ex. 14).
5 Other than a demand for costs and attorney’s fees, Plaintiffs seek solely injunctive and declaratory relief. Plaintiffs do not seek compensatory education or compensatory damages. (See Doc. No. 1, at 21-23).
6

2; Doc. No. 48, at 2). The relief sought by Plaintiffs is based upon the violation of four separate statutes.
Specifically, Plaintiffs allege that the process of upper-leveling violates the Individual and Disabilities Act, 20 U.S.C. § 1400 et seq. (“IDEA”) and Chapter 14 of the Pennsylvania Code (“Chapter 14"), “as it occurs with little or no parental notice or involvement, without required consideration of children’s individualized circumstances, and in direct violation of the mandated individual planning process of the IDEA.” (Doc. No. 1, at ¶ 2; see also ¶ 56 (citing U.S.C. § 1414(d) and § 1415)). Plaintiffs contend that upper-leveling also violates § 504 of the Rehabilitation Act (“§ 504"), and Title II of the American with Disabilities Act (“ADA”), because the transfer “is based solely on the fact that children have autism.” (Doc. No. 1, at ¶ 2).
Plaintiffs bring this instant motion, seeking class action certification. Specifically, Plaintiffs seek to certify a class consisting of students with autism in grade levels K-8 in the School District who have been transferred, are in the process of being transferred, or are subject to being transferred pursuant to the School District’s upper-leveling policy. The proposed class definition also includes all parents and guardians of those children, and future members of the class. (See Doc. No. 48, at 12).
Defendants argue that Plaintiff’s class certification motion should be denied for three separate reasons. First, Defendants argue that the named Plaintiffs lack standing. Second, Defendants contend that Plaintiffs fail to satisfy the numerosity, commonality, typicality, and adequate representation prongs of Rule 23(a). Finally, Defendants aver that Plaintiffs do not meet the certification requirements under Rule 23(b)(2). We address each argument in turn.
7

II. STANDING The existence of Article III standing is a necessary prerequisite to class certification. See
McNair v. Synapse Grp., Inc., 672 F.3d 213, 223 n.10 (3d Cir. 2012) (noting that standing is a “necessary threshold issue” to review of class certification). “[I]f none of the named plaintiffs purporting to represent a class establishes the requisite of a case or controversy with the defendants, none may seek relief on behalf of himself or any other member of the class.” O’Shea v. Littleton, 414 U.S. 488, 493 (1973). The three “irreducible” constitutional elements of standing are: (1) an injury in fact that is actual or imminent, not “conjectural” or “hypothetical”; (2) a causal connection between the injury and the conduct complained of – the injury must be fairly traceable to the challenged action of the defendant; and (3) a showing that it is likely, as opposed to merely speculative, that a favorable decision will redress the injury. Lujan v. Defenders of Wildlife, 504 U.S. 555, 560-61 (1992).
Defendants argue that the named Plaintiffs lack standing to bring claims against the School District because they were never physically transferred, and thus cannot “claim to have suffered an injury to their academic or behavioral progress from the purported policy they seek to challenge.” (Doc. No. 50, at 11). However, Plaintiffs need not demonstrate actual harm or monetary damages to establish standing. On the contrary, “the actual or threatened injury required by Art. III may exist solely by virtue of statutes creating legal rights, the invasion of which creates standing.” Alston v. Countrywide Fin. Corp., 585 F.3d 753, 763 (3d Cir. 2009). Consistent with that precedent, we rejected Defendant’s same argument at the motion to dismiss level, where we explained:
Even though Plaintiffs currently attend their preferred school, Plaintiffs will
8

continue to be subject to the District’s allegedly IDEA-deficient educational placement process from year to year. As such, Plaintiffs’ injuries are imminent, not merely conjectural or hypothetical, and a favorable court decision will likely redress the systemic failures, if any, in the District’s practices regarding the educational placement and transfer of autistic students. Therefore, under Lujan, Plaintiffs have standing to pursue their claims P.V. v. Sch. Dist. of Phila., No. 2:11-cv-04027, 2011 WL 5127850, at *11 (E.D. Pa. Oct. 31, 2011). Although this reasoning was provided over a year ago, the circumstances are such that the language remains applicable. The named Plaintiffs are in grades K-8 and attend a school in the School District, continually subjecting them to the School District’s allegedly IDEA-deficient educational placement process. Therefore, for the same reasons provided at the motion to dismiss level, Plaintiffs have met the necessary prerequisite of Article III standing to pursue class certification. III. CLASS ACTION CERTIFICATION A. Legal Standard for Class Certification A class action is “an exception to the usual rule that litigation is conducted by and on behalf of the individual named parties only.” Califano v. Yamasaki, 442 U.S. 682, 700-01 (1979). Certification of a class action “is proper only ‘if the trial court is satisfied, after a rigorous analysis, that the prerequisites’ of [Federal Rule of Civil Procedure 23] are met.” In re: Hydrogen Peroxide Antitrust Litig., 552 F.3d 305, 309 (3d Cir. 2009) (citation omitted). This “rigorous analysis” may delve beyond the pleadings and will often “entail some overlap with the merits of the plaintiff’s underlying claim.” Wal-Mart Stores, Inc. v. Dukes, 131 S. Ct. 2541, 2551 (2011). However, plaintiffs are not required to establish the validity of their claims at this stage. Rather, a preliminary inquiry into the merits of the case is necessary only to “determine
9

whether the requirements of Rule 23—namely, that the elements of the claim can be proved ‘through evidence common to the class rather than individual to its members’—are met.” Sullivan v. DB Investments, Inc., 667 F.3d 273, 306 (3d Cir. 2011) (quoting In re: Hydrogen Peroxide Antitrust Litig., 552 F.3d at 311-12)).
B. Rule 23(a) Requirements To obtain class action certification, Plaintiffs bear the burden to “establish that all four requisites of Rule 23(a) and at least one part of Rule 23(b) are met.” Baby Neal v. Casey, 43 F.3d 48, 55 (3d Cir. 1994). Rule 23(a) states: One or more members of a class may sue or be sued as representative parties on behalf of all members only if: (1) the class is so numerous that joinder of all members is impracticable; (2) there are questions of law or fact common to the class; (3) the claims or defenses of the representative parties are typical of the claims or defenses of the class; and (4) the representative parties will fairly and adequately protect the interests of the class. The four requirements under Rule 23(a), generally known as numerosity, commonality, typicality, and adequacy, “assure both that class action treatment is necessary and efficient and that it is fair to the absentees under the particular circumstances. While numerosity addresses the first of these concerns, . . . the last three requirements help determine whether the class action can be maintained in a fair and efficient manner.” Baby Neal, 43 F.3d at 55. We review each requirement in turn.
1. Numerosity Rule 23(a)(1) requires that the class be “so numerous that joinder of all members is impracticable.” No minimum number of plaintiffs is required to satisfy the numerosity requirement. Stewart v. Abraham, 275 F.3d 220, 226 (3d Cir. 2001). In general, however, “if the
10

named plaintiff demonstrates that the potential number of plaintiffs exceeds 40, the first prong of Rule 23(a) has been met.” Id., at 226-227.
Here, Plaintiffs assert that the class will include at least 1600 individuals, representing the number of K-8 students in the School District who currently require autism support. (See Doc. No. 61, at 2; see also Doc. No 48, Ex. 23, at 27; Ex. 26). Defendants do not dispute that over 1600 students in the School District currently require autism support. (See Doc. No. 50, at 3 (“For the 2011-2012 school year, 1,684 [K-8] students were identified as requiring access to an autism support classroom.”)). Rather, Defendants contend that the putative class does not include these students because Plaintiffs provide no proof that any of the K-8 autistic students in the School District were ever transferred pursuant to upper-leveling.
While Defendants’ assertion is correct, the evidence makes clear, and Defendants admit, that any autistic student who attends the K-8 grade level in the School District will be upperleveled if his or her school can no longer provide age-appropriate autism support. (See Doc. No. 50, at 5). Defendants go on to explain that whether autism support is offered at a particular location depends on a number of external considerations, including the number of students requiring autism support in the school that year. (See Doc. No. 50, at 4). Based on those considerations, the School District could presumably decide to remove a grade level of autism support from a particular school location, forcing an autistic student to be transferred to a different school. (See id.). Consequently, students with autism in grade levels K-8 in the School District are constantly subject to the risk of being transferred pursuant to the process of upperleveling.
Here, Plaintiffs seek to represent those students at risk of being transferred pursuant to
11

upper-leveling, as well as those already transferred. Therefore, the putative class correctly encompasses all K-8 students with autism in the School District. Considering there are over 1600 such students, we find that joinder of these individuals would be impracticable. Moreover, the proposed class includes future members who are necessarily unidentifiable, which makes joinder even more impracticable. Accordingly, Plaintiffs have satisfied the numerosity requirement.
2. Commonality Under Rule 23(a)(2), Plaintiffs must establish that “there are questions of law or fact common to the class.” The Third Circuit has stated that “[t]he commonality requirement will be satisfied if the named plaintiffs share at least one question of fact or law with the grievances of the prospective class.” Baby Neal, 43 F.3d at 56. Moreover, factual differences among the claims of the putative class members do no preclude commonality. Id. at 56. Rather, “[b]ecause the [commonality] requirement may be satisfied by a single common issue, it is easily met.” Id. at 57. “This is especially true where plaintiffs request declaratory and injunctive relief against a defendant engaging in a common course of conduct toward them, and there is therefore no need for individualized determinations of the propriety of injunctive relief.” Id. at 57 (emphasis in original); see, e.g., C.G. v. Pennsylvania, No. 1:06-cv-1523, 2009 WL 3182599, at *5-6 (M.D. Pa. Sept. 29, 2009) (commonality satisfied where “the class members [consisting of disabled students] each were in factually distinct situations in terms of their receipt of FAPE, but the challenge and the desired [injunctive] relief were common to all members”). Defendants contend that in order to prevail, Plaintiffs will have to obtain individualized proof of how each class member was affected by the School District’s “policy” of upper-leveling.
12

Defendants argue that class certification should therefore be barred, on the basis that the Plaintiff’s individualized factual situations foreclose a finding of commonality.6 Defendants fail
to recognize, however, that the central tenet of Plaintiffs’ Complaint alleges a systemic failure,
not a failure of the policy as applied to each member individually. Plaintiffs claim that the
School District’s “policy” of upper-leveling K-8 autistic students, which allegedly involves little
to no parental involvement or consideration of autistic students’ individual needs, constitutes a
violation of the IDEA, Chapter 14, ADA, and § 504.
Plaintiffs correctly point out that their systemic challenge requires a number of factual
and legal determinations, common to all class members. These common questions of fact or law
include whether the School District upper-levels autistic students without meaningful parental
involvement, whether the School District upper-levels autistic students without providing prior
written notice to the parents, whether the School District considers the individual needs of
autistic students prior to deciding where to upper-level that student, and whether the School
District’s “policy” of upper-leveling deprives putative class members of a free and appropriate
public education. Therefore, Plaintiffs have satisfied the commonality requirement.
6 To support their argument, Defendants cite Blunt v. Lower Merion Sch. Dist., 262 F.R.D. 481, 489-90 (E.D. Pa. 2009) for the proposition that individualized proof is necessary to determine whether a school district violates the IDEA. However, unlike this case, the plaintiffs in Blunt who moved for class certification sought “not only injunctive and declaratory relief, but also compensatory education for each of the named plaintiffs and members of the class who were deprived an adequate education.” Id. at 490. As the Third Circuit has explained, a request for damages typically requires individualized determinations of harm. See Baby Neal, 43 F.3d at 57 (noting that because “they do not also involve an individualized inquiry for the determination of damage awards, injunctive actions by their very nature often present common questions satisfying Rule 23(a)(2)”). Therefore, Defendants’ reliance on Blunt to negate a finding of commonality here is misplaced.
13

3. Typicality To satisfy Rule 23(a)(3), Plaintiffs must prove that their claims or defenses are “typical of the claims or defenses of the class.” The typicality requirement is intended to ensure that the incentives of the named plaintiffs align with those of absent class members. Baby Neal, 43 F.3d at 57. The common claims should be “comparably central to the claims of the named plaintiffs” and not create a potential conflict. Id. (citing Weiss v. York Hosp., 745 F.2d 786, 810 (3d Cir. 1984)). The Third Circuit has also articulated that “cases challenging the same unlawful conduct which affects both the named plaintiffs and the putative class usually satisfy the typicality requirement irrespective of the varying fact patterns underlying the individual claims. . . . Actions requesting declaratory and injunctive relief to remedy conduct directed at the class clearly fit this mold.” Id. at 58 (internal citation omitted). Here, named Plaintiffs and the putative class challenge the same allegedly unlawful conduct of upper-leveling students with autism, and seek injunctive relief to remedy that conduct. The systemic challenge to the School District’s process of upper-leveling autistic students is clearly the central issue to all claims. Defendants contend, however, that Plaintiffs’ claims do not align with the incentives of the representative class because “the best placement for a particular student [in the putative class] might not be in a school building that offers autism support for all grades.” (Doc. No. 50, at 16). Defendants’ argument may be persuasive if Plaintiffs sought for this Court to require
only schools that offer autism support for any grade level to offer autism support for every grade level in that building. On the contrary, the crux of Plaintiffs’ requested relief focuses on providing parents of autistic children with more information and a greater opportunity to get involved with
14

the decision to transfer their child. Defendants do not address how providing greater parental involvement conflicts with the incentives of the representative class members to place their children in the most appropriate learning environment. Providing parents the opportunity to participate in the decisions that affect their children’s education, as well as the information necessary to make informed decisions, would seem only to help ensure the parent’s child is placed in his or her most appropriate classroom environment. We therefore find that the typicality requirement is met.
4. Adequacy of Representation To meet the fourth and final 23(a) prong, Plaintiffs must prove that the “representative parties will fairly and adequately protect the interests of the class.” Fed. R. Civ. P. 23(a)(4). The primary purpose of Rule 23(a)(4) is “to uncover conflicts of interest between named parties and the class they seek to represent.” In re Warfarin Sodium Antitrust Litig., 391 F.3d 516, 532 (3d Cir. 2004). Proof of “‘[a]dequate representation depends on two factors: (a) the plaintiff's attorney must be qualified, experienced, and generally able to conduct the proposed litigation, and (b) the plaintiff must not have interests antagonistic to those of the class.’” New Directions Treatment Servs. v. City of Reading, 490 F.3d 293, 313 (3d Cir. 2007) (quoting Wetzel v. Liberty Mut. Ins. Co., 508 F.2d 239, 247 (3d Cir. 1975)). Defendants do not dispute the qualifications of proposed class counsel. Instead, Defendants largely reiterate their typicality argument by contending that an intra-class conflict exists because some putative class member may prefer not to “attend schools that have autism support for all grades.” (Doc. No. 50, at 18). We already rejected this argument when Defendants moved to strike class action allegations prior to discovery, under the following
15

rationale:
Plaintiffs certainly do not explicitly request that we forbid “any school that is incapable of offering autism support classes to all grade levels from offering [autism support] to any grade levels in that school” or eliminate “autism support classes in many neighborhood schools.” Defendants merely speculate that forcing the District to change its practices regarding transferring autistic students will have the aforementioned results.
Additionally, much of Plaintiffs’ requested relief focuses on providing parents of autistic children with more information and a greater opportunity to get involved with their children’s educational placement. We cannot see how this relief would divide the Plaintiffs’ proposed class to such an extent that an inherent conflict of interest among the class members would prohibit class certification. Parents may or may not take advantage of the opportunity to participate in the decisions that affect their children’s education. However, merely giving parents the option to do so, as well as the information necessary to make informed decisions, would not appear to be a particularly controversial or divisive issue among the autistic community.
P.V. v. Sch. Dist. of Phila., No. 2:11-cv-04027, 2011 WL 5127850, at *5-6 (E.D. Pa. Oct. 31,
2011) (alterations in original). No additional evidence or authority has been presented to this
Court to make the reasoning provided in our previous Order any less applicable.7 We therefore
conclude that Plaintiffs have satisfied all four of the Rule 23(a) factors, including adequate
representation.
7 The reasoning provided in McClendon v. Sch. Dist. of Phila., No. 04-1250, 2005 WL 549532 (E.D. Pa. Mar. 7, 2005), on which Defendants rely, is not applicable to this case. Unlike here, the plaintiffs in McClendon sought compensatory damages based on each plaintiff’s individual agreement. It was precisely because the plaintiffs in McClendon sought compensatory relief that the court determined “[c]ertification of a class would compromise the individual plaintiff’s freedom to resolve their individual cases.” The McClendon court expressly recognized that its case was distinguishable from Baby Neal, where the plaintiffs sought only injunctive relief. McClendon, 2005 WL 549532, at *4; see also Baby Neal, 43 F.3d at 63 (“It bears remembering that the plaintiffs here seek only injunctive and declaratory relief; there are no other claims that could compromise the named plaintiffs' pursuit of the class claims.”).
16

C. Rule 23(b)(2) Analysis Rule 23(b)(2) authorizes class action treatment for cases that seek injunctive relief.8 The Third Circuit has held that Rule 23(b)(2) “is almost automatically satisfied in actions primarily seeking injunctive relief” from systemic violations of basic rights. Baby Neal, 43 F.3d at 58, 64; see also Weiss v. York Hosp., 745 F.2d 786, 811 (3d Cir. 1984) (“When a suit seeks to define the relationship between the defendant(s) and the world at large, as in this case, (b)(2) certification is appropriate.”). What is important for purposes of satisfying Rule 23(b)(2) is that the relief sought by the named plaintiffs benefits the entire class. Id. at 59. Defendants argue that given the binding effects of a 23(b)(2) class certification, “absent members of the putative class at issue will effectively be forced to cede to the named plaintiffs and their counsel control over critical decisions regarding their children’s education.” (Doc. No. 50, at 20). Defendants contend that such a result goes directly against the purpose of the IDEA, “which is to create a framework that enables parents and educational professionals to work together.” (Id.). Defendants’ familiar argument once again fails to consider the extent of the relief sought by Plaintiffs. Despite Defendants’ persistent contention to the contrary, Plaintiffs do not seek to dictate where to locate the autism support programs provided to children in the School District. Rather, as already discussed, Plaintiffs mainly seek systemic relief that will provide the opportunity for greater parental involvement to all putative class members in making decisions that allegedly affect the educational placement of their children—relief that is entirely consistent with the IDEA’s promotion of parent-school cooperation. Because the injunctive relief sought by
8 Rule 23(b)(2) states: “A class action may be maintained if Rule 23(a) is satisfied and if . . . the party opposing the class has acted or refused to act on grounds that apply generally to the class, so that final injunctive relief or corresponding declaratory relief is appropriate respecting the class as a whole.”
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Plaintiffs will benefit the entire class, we conclude that this action is within the type that Rule 23(b)(2) was designed to authorize.9 III. CONCLUSION
Based on the foregoing considerations, the Court finds that all the requirements for class certification are met. Accordingly, this action is certified as a class action pursuant to Federal Rule of Civil Procedure 23(a) and 23(b)(2) on behalf of the following class: All children with autism in the School District of Philadelphia in grades kindergarten through eight (“K-8") who have been transferred, are in the process of being transferred, or are at risk of being transferred, as a result of the School District’s upper-leveling process, the parents and guardians of those children, and future members of the class. An appropriate order follows this memorandum.
BY THE COURT: /s/ Legrome D. Davis Legrome D. Davis, J.
9 Because Plaintiffs need only satisfy one subparagraph of Rule 23(b) to certify a class, we need not address Plaintiff’s alternative argument that this case also satisfies the requirements of Rule 23(b)(3).
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IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF PENNSYLVANIA

P.V., a minor, by and through his Parents,

:

Pedro Valentin and Yolanda Cruz,

individually, and on behalf of all others

:

similarly situated, et al.,

Plaintiffs,

:

v.

:

The School District of Philadelphia, et al.,

Defendants.

CIVIL ACTION NO. 2:11-cv-04027

ORDER

AND NOW, this 19th day of February 2013, upon consideration of Plaintiff’s Motion for Class Certification (Doc. No. 48), Defendant’s Response in Opposition thereto (Doc. No. 50), and Plaintiff’s Reply Brief in Further Support of Motion for Class Certification (Doc. No. 61), we hereby ORDER as follows:

1. Plaintiff’s Motion for Class Certification (Doc. No. 48) is GRANTED.

2. This action is certified as a class action pursuant to Federal Rule of Civil Procedure 23(a) and 23(b)(2) on behalf of the following class:

All children with autism in the School District of Philadelphia in grades kindergarten through eight (“K-8") who have been transferred, are in the process of being transferred, or are at risk of being transferred, as a result of the School District’s upper-leveling process, the parents and guardians of those children, and future members of the class.

3. Plaintiffs P.V. and his parents Pedro Valentin and Yolanda Cruz; M.M. and his parent Carla Murphy; J.V. and his parents Sharon Vargas and Ismael Vargas; and R.S. and his parents Heather Sanasac and Matthew Sanasac, are appointed as class representatives.

4. The Public Interest Law Center of Philadelphia (“PILCOP”) and Dechert, LLP are appointed as class counsel. BY THE COURT:

/s/ Legrome D. Davis Legrome D. Davis, J.

 </s> Case 2:11-cv-04027-LDD Document 114 Filed 04/15/14 Page 1 of 17

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF PENNSYLVANIA

P.V., a minor, by and through his Parents, Pedro Valentin and Yolanda Cruz, individually, and on behalf of all others similarly situated, et al.,
Plaintiffs, v. The School District of Philadelphia, et al.,
Defendants.

) ) ) Civil Action No. 2:11-cv-04027 ) ) ) ) ) ) ) ) )

JOINT MOTION FOR PRELIMINARY APPROVAL OF SETTLEMENT AGREEMENT

Defendant, the School District of Philadelphia and Plaintiffs, students with autism by and

through their parents, hereby jointly request this Court to: (1) preliminarily approve the Settlement

Agreement attached hereto as Exhibit A; (2) approve the notice to the class in the form attached

hereto as Exhibit B; and (3) schedule a hearing pursuant to Federal Rule of Civil Procedure 23(e)

to determine that the Settlement Agreement is a “fair, reasonable and adequate” settlement of this

class action. The Settlement Agreement was negotiated and approved by all parties to this

litigation in the course of a mediation before Magistrate Judge Timothy R. Rice. The reasons in

support of this motion are set forth in the accompanying Memorandum.

Dated: April 15, 2014

Respectfully,
/s/ Sonja Kerr Sonja Kerr (I.D. No. 95137)
skerr@pilcop.org PUBLIC INTEREST LAW CENTER OF PHILADELPHIA 1709 Benjamin Franklin Parkway, Second Floor Philadelphia, PA 19103 Telephone: (215) 627-7100 Facsimile: (215) 627-3183

Case 2:11-cv-04027-LDD Document 114 Filed 04/15/14 Page 2 of 17
Co-Counsel for Plaintiffs Cheryl Krause (I.D. No. 90297)
cheryl.krause@dechert.com David J. Stanoch (I.D. No. 91342)
david.stanoch@dechert.com Darla D. Woodring (I.D. No. 306866)
darla.woodring@dechert.com DECHERT LLP Cira Centre 2929 Arch Street Philadelphia, PA 19104-2808 Telephone: (215) 994-4000 Facsimile: (215) 994-2222 Co-Counsel for Plaintiffs
/s/ David Smith David Smith (I.D. No. 21480)
dsmith@schnader.com Benjamin D. Wanger (I.D. No. 209317)
bwanger@schnader.com SCHNADER HARRISON SEGAL & LEWIS LLP 1600 Market Street, Suite 3600 Philadelphia, PA 19103-7286 Telephone: (215) 751-2000 Facsimile: (215) 751-2205 Counsel for Defendants
2

Case 2:11-cv-04027-LDD Document 114 Filed 04/15/14 Page 3 of 17

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF PENNSYLVANIA

P.V., a minor, by and through his Parents, Pedro Valentin and Yolanda Cruz, individually, and on behalf of all others similarly situated, et al.,
Plaintiffs, v. The School District of Philadelphia, et al.,
Defendants.

) ) ) Civil Action No. 2:11-cv-04027 ) ) ) ) ) ) ) ) )

MEMORANDUM IN SUPPORT OF JOINT MOTION FOR PRELIMINARY APPROVAL OF SETTLEMENT AGREEMENT
Defendant, the School District of Philadelphia (the “School District”) and Plaintiffs,

students with autism and their parents (collectively the “Parties”) move for the preliminary

approval of a Settlement Agreement that they have reached in the above-referenced class action,

as well as for approval of a class notice. The Parties submit that the Settlement Agreement (Ex.

A) meets the standards for preliminary approval of a class action settlement and that such approval

should be granted. The Parties also submit the proposed Notice to be sent to class members (Ex.

B) for the Court’s approval.

INTRODUCTION
On June 20, 2011, Plaintiffs filed this class action against the School District, the School
Reform Commission (“SRC”), and two School District personnel. As found by this Court:
Plaintiffs contend[ed] that the School District transfers students with autism automatically from one school to another, simply because they complete a certain grade, more frequently than the School District transfers non-disabled students who therefore, unlike autistic children, enjoy continued, uninterrupted attendance in K-5 schools or K-8 schools. (Doc. No. 1, at ¶ 1). Plaintiffs further allege[d] that the decision-making process leading up to the transfer of an autistic

Case 2:11-cv-04027-LDD Document 114 Filed 04/15/14 Page 4 of 17
student is conducted with little to no parental notice or involvement, and without the required consideration of the children’s individualized circumstances. (Doc. No. 1, at ¶ 2). Document 72, at 1-2. Plaintiffs asserted claims under the Individuals with Disabilities Education Act, 20 U.S.C. § 1400 et seq. and as amended (“IDEA”), Chapter 14 of the Pennsylvania Code of Education Regulations, 22 Pa. Code § 14 et seq. (“Chapter 14”), Title II of the Americans with Disabilities Act, 42 U.S.C. § 12131 et seq. and as amended (“ADA”), and Section 504 of the Rehabilitation Act, 29 U.S.C. § 794 (“Section 504”). On October 31, 2011, the Court denied the Defendants’ motions to dismiss and strike class allegations (Docs. 23 and 24). Discovery began in early 2012, and consisted of depositions of numerous employees of the School District, Plaintiff parents, and experts. Plaintiffs prevailed on their motion to compel during discovery (Doc. 39) and Defendants produced over 17,000 documents. Discovery closed on June 11, 2012. The Parties engaged in lengthy class certification and summary judgment briefing, including surreplies. By Orders and Memorandum Opinions entered on February 19, 2013, the Court granted in part and denied in part cross motions for summary judgment (Docs. 74 and 75) and granted Plaintiffs’ motion for class certification under Federal Rules of Civil Procedure 23(a) and 23(b)(2) with respect to the claims on which summary judgment was entered for Plaintiffs (Docs. 72 and 73). The Court granted summary judgment in favor of the Defendants on Plaintiffs’ claims that the School District transfers students with autism automatically from one school to another, simply because they complete a certain grade, more frequently than the School District transfers non-disabled students who therefore, unlike children with autism, enjoy continued, uninterrupted attendance in K-5 schools or K-8 schools. The Court granted summary judgment in favor of the Plaintiffs on Plaintiffs’ claims that the decision-making process leading up to the transfer of a student with autism is conducted with little to no parental notice or involvement, and
2

Case 2:11-cv-04027-LDD Document 114 Filed 04/15/14 Page 5 of 17
without the required consideration of the child’s individualized circumstances. Accordingly, the Court ordered the School District to “alter its upper-leveling process for children with autism to provide prior written notice and a level of parental participation that complies with the procedural requirements under the IDEA.” (Doc. 74).
Defendants filed a motion for reconsideration (Doc. 76) on February 27, 2013 and the Court held a hearing on the motion on April 16, 2013. On August 14, 2013, after denying the Defendants’ motion for reconsideration (Doc. 101), the Court re-opened this matter (Doc. 100) to determine the “specific contours of injunctive relief” or alternatively to give the Parties an opportunity to settle. Id. The Parties began settlement negotiations in May 2013.
The Parties’ settlement negotiations progressed and after enlisting the help of Magistrate Judge Rice, the Parties have negotiated a comprehensive Settlement Agreement dated April 15, 2014 covering the issues in the case. See Ex. A. The negotiations were at arm’s length. Each side fully understands the terms, and has compromised to reach the Agreement.
As noted above, the remaining issues in this lawsuit relate to notice and participation by parents in decisions to upper-level their children (grades K-8) with autism. The Settlement Agreement provides three ways that parents of class members will receive this critical information.
First, although the Court had granted summary judgment for Defendants on this issue, Defendants have agreed to publish annually a list of all the schools within the School District that have Autistic Support (“AS”) classrooms in grades K-8.1 Plaintiffs regard this list as an integral piece of information necessary to enable parents to effectively understand and potentially engage the School District about upper-leveling decisions. 1 The list may be published with appropriate disclaimers regarding its accuracy and that school configurations are subject to change at any time throughout the year.
3

Case 2:11-cv-04027-LDD Document 114 Filed 04/15/14 Page 6 of 17
The School District has also agreed to provide two letter notices to class members who will likely be upper-leveled the following school year in a manner consistent with the sample notice letters attached hereto at Exhibit C.
The first letter will be sent on or about January 17 and will notify parents of the transfer and inform them that they can talk to a School District designee or their child’s classroom teacher about upper-leveling or request an IEP meeting to discuss their child’s needs.
A second letter will be sent on or about June 12 and include building assignment information, enclose the most current version of “Parents’ Rights: Understanding the Procedural Safeguards Notice” booklet and inform parents they can contact a School District designee, call the Office for Dispute Resolution or contact any organization listed in the booklet for more information about mediation or filing a due process request.
Thus, the terms of the proposed Settlement Agreement provide notice and an opportunity for parental participation. Indeed, because the Court did not order the School District to provide a public list of classrooms, the Settlement exceeds the relief received by Plaintiffs. Two notices, giving parents two opportunities to provide input into the upper-leveling decision process, is consistent with and satisfies the Court’s order that parents be given prior written notice. Prior written notice, as defined by 34 C.F.R. § 300.503 requires that parents receive notice of an action proposed or refused by the School District, an explanation of the action proposed or refused, and information about their rights and sources for assistance a reasonable time before the School District acts to propose or refuse an action affecting the child’s special education. By providing
2 As the effective date of the Settlement Agreement is April 2014, class members will only receive the June notice for the current (2013-2014) school year and that letter will not include the language from the sample at Exhibit C that prior notice was given. Furthermore, because June 1, 2014 is a Sunday, the notice letters will be sent by June 2, 2014.
4

Case 2:11-cv-04027-LDD Document 114 Filed 04/15/14 Page 7 of 17
parents two separate notices, one in January and one in June, the School District will afford parents with information in the spirit of the prior written notice required.
Although the Settlement Agreement calls for the dismissal of all claims, the Court will retain limited jurisdiction to enforce the Settlement Agreement until January 2, 2017. If the Parties believe that the Settlement Agreement has been breached, they must meet and confer in good faith and if they are unable to resolve the issue, the matter will be referred to Magistrate Judge Rice to enforce the Settlement Agreement and apply an appropriate remedy. The release provisions cover all claims that were or could have been brought by Plaintiffs for prospective injunctive relief challenging the School District’s policy or practice, but exclude all individual claims by class members regarding upper-level transfers that they have a statutory right to bring. Finally, the Settlement Agreement provides for $325,000 in attorneys’ fees and expenses to class counsel (payable in three installments), which are at a substantial discount from the lodestar. Thus, the settlement will “remedy current conditions and provide[] a viable mechanism” for compliance in the future. See Collier v. Montgomery County Hous. Auth., 192 F.R.D. 176, 186 (E.D. Pa. 2000). Notice will be provided via first-class mail, and publication via newspaper and website.
Given that the Settlement Agreement will terminate this lengthy litigation and will benefit class members fairly and adequately, for the reasons expressed more fully below, the School District and Plaintiffs jointly request the Court preliminarily approve the Settlement Agreement and notice to the Class.
5

Case 2:11-cv-04027-LDD Document 114 Filed 04/15/14 Page 8 of 17
ARGUMENT I. The Settlement Agreement Fully Satisfies The Standards For Preliminary Approval Of A
Class Action Settlement. When approving a class action settlement, the court must ultimately evaluate “whether the
settlement is fair, adequate, and reasonable.” Walsh v. Great Atl. & Pac. Tea Co., 726 F.2d 956, 965 (3d Cir. 1983). “The law looks favorably upon class action settlements because avoiding a trial [and appeal] conserves scarce judicial resources.” Perry v. FleetBoston Fin. Corp., 229 F.R.D. 105, 114 (E.D. Pa. 2005). The Court must give its “initial blessing” to the preliminary settlement, i.e., before class notice is given and a formal fairness hearing is held. See id.
“In evaluating a proposed settlement for preliminary approval . . . the Court is required to determine only whether ‘the proposed settlement discloses grounds to doubt its fairness or other obvious deficiencies such as unduly preferential treatment of class representatives or segments of the class, or excessive compensation of attorneys, and whether it appears to fall within the range of possible approval.’” Mehling v. New York Life Insur. Co., 246 F.R.D. 467, 472 (E.D. Pa. 2007) (quoting Thomas v. NCO Fin. Sys., 2002 U.S. Dist. LEXIS 14157, at *14 (E.D. Pa. July 31, 2002)). Courts also typically evaluate if the settlement resulted from serious arm’s-length negotiations. Id. at 472.
The Settlement Agreement meets the standard for preliminary approval. Class members have obtained the relief to which the Court found they were entitled—parental notice prior to transfer, an opportunity for parental participation in the transfer decision, and, in addition, some of the relief to which the Court found they were not entitled—information regarding where K-8 AS classrooms are located within the School District. The Settlement Agreement also provides a mechanism for enforcing the Settlement Agreement by allowing this Court and by extension
6

Case 2:11-cv-04027-LDD Document 114 Filed 04/15/14 Page 9 of 17
Magistrate Judge Rice to retain limited jurisdiction until January 2017. A separate enforcement action can be brought after that time.
The Settlement Agreement should be preliminarily approved for the following reasons. A. The Settlement Negotiations Were Serious, Informed And At Arm’s-Length. The negotiations that led to the proposed Settlement Agreement were undoubtedly at arm’s length. It came only after lengthy vigorously contested litigation, with extensive briefing including motions to strike, dismiss, compel, class certification, summary judgment and reconsideration. The Parties also had the advantage of a review of the evidence by autism and special education experts. The Parties first engaged in settlement negotiations after the Court held a hearing on the School District’s motion for reconsideration. To avoid a time-consuming and costly appeal, the Parties began settlement negotiations in May 2013 and, with the assistance of Magistrate Judge Rice, reached a preliminary settlement of the merits in late December 2013. The Settlement Agreement reflects not only the interests of the class, but importantly maintains the statutory rights of individual class members. Settlement of the substantive provisions was completed in principle prior to final determination of any payment of attorneys’ fees and costs on February 28, 2014. Clearly, this Settlement Agreement did not come early in the litigation, but only after extensive discovery, merits briefing and, indeed, substantive class and merits rulings by this Court. Thus, the Parties were able to evaluate their respective positions based on the robust amount of information available to them.
7

Case 2:11-cv-04027-LDD Document 114 Filed 04/15/14 Page 10 of 17
B. The Proposed Settlement Agreement Contains No Obvious Deficiencies. The proposed Settlement Agreement contains no obvious deficiencies such as preference to certain class members or excessive attorneys’ fees, and is within the range for approval. The Settlement Agreement provides the Plaintiff class with a remedy that exceeds the relief ordered by this Court: (1) the School District will publish a list of all the schools within the School District that have AS classrooms3 and the grade range of those classrooms; (2) the School District will provide two letter notices to class members prior to transferring them; and (3) the School District will inform parents that they can discuss the proposed transfer at an IEP meeting and retain their rights to challenge their own individual transfer. The relief gained through this Settlement Agreement benefits each class member and will be applied uniformly to all class members. This settlement proposal is certainly within the range of possible approval. Attorneys’ fees are reasonable as class counsel will obtain $325,000 in fees and costs from the School District, which is substantially less than their lodestar rate. See Samuel v. Equicredit Corp., 2002 U.S. Dist. LEXIS 8234 at *5 n. 4 (E.D. Pa. May 6, 2002) (a $625,000 settlement preliminarily approved where fees were equal to or less than plaintiffs’ lodestar). Class counsel will receive no additional fees or costs for monitoring implementation of the Settlement Agreement. C. The Settlement Agreement Is Fair And Reasonable. After notice and a fairness hearing are provided, a court must determine if the final settlement is fair and reasonable. A court “should presume a class settlement is fair when four factors apply: ‘(1) the settlement negotiations occurred at arm’s length; (2) there was sufficient discovery; (3) the proponents of the settlement are experienced in similar litigation; and (4) only a
3 Classrooms serving children in grades K-8.
8

Case 2:11-cv-04027-LDD Document 114 Filed 04/15/14 Page 11 of 17
small fraction of the class objected.’” Chester Upland Sch. Dist. v. Commonwealth, 284 F.R.D. 305, 323 (E.D. Pa. 2012) (quoting In re Warfarin, 391 F.3d 516, 535 (3d Cir. 2004)).
Here, the Settlement Agreement easily satisfies the fairness presumption. As discussed supra, the negotiations were at arm’s-length. Moreover, settlement occurred after discovery which included the production of thousands of documents and numerous depositions of School District representatives, Plaintiff parents, and experts. The Parties’ counsel are experienced in similar litigation as PILCOP has litigated many federal class actions to protect the civil rights of individuals with disabilities. Dechert LLP is an international law firm with 26 offices in the United States, Europe, Asia and the Middle East. Dechert is highly experienced in handling complex litigation and class action matters. Schnader Harrison Segal & Lewis LLP is a reputable mid-sized law firm with many decades of experience in class action litigation. As this action was for injunctive relief, the class has not yet had an opportunity to object or react to the settlement.
Additionally, to determine if a proposed settlement under Federal Rule of Civil Procedure 23(e) is fair, reasonable, and adequate, the Third Circuit in Girsh v. Jepson, 521 F.2d 153 (3d Cir. 1975) enumerated nine factors courts should consider:
(1) the complexity, expense and likely duration of the litigation; (2) the reaction of the class to the settlement; (3) the stage of the proceedings and the amount of discovery completed; (4) the risks of establishing liability; (5) the risks of establishing damages; (6) the risks of maintaining the class action through trial; (7) the ability of the defendants to withstand a greater judgment;
9

Case 2:11-cv-04027-LDD Document 114 Filed 04/15/14 Page 12 of 17
(8) the range of reasonableness of the settlement fund in light of the best possible recovery; and (9) the range of reasonableness of the settlement fund to a possible recovery in light of all the attendant risks of litigation. Id. at 157. An analysis of these factors confirms that the proposed Settlement Agreement is fair and reasonable. (1) The complexity, expense and likely duration of the litigation. Although the Court granted partial summary judgment on the IDEA claim in favor of Plaintiffs and denied the School District’s motion for reconsideration, the Court indicated that it would hold a hearing, if the case did not settle, to determine the exact contours of the injunctive relief requiring additional expense and effort by counsel. Furthermore, the legal issues were challenging and the possibility of appeal by the School District was strong. An appeal would have delayed the implementation of relief to the class. (2) The reaction of the class to the settlement. This factor can only be assessed after notice and hearing; however, Plaintiffs are in favor of the settlement, and class counsel are not aware of any class members who have expressed a negative reaction to it. (3) The stage of the proceedings and the amount of discovery completed. This factor “captures the degree of case development . . . prior to settlement” and “[t]hrough this lens, courts can determine whether counsel had an adequate appreciation of the merits of the case before negotiating.” In re GMC Pick-Up Truck Fuel Tank Prods. Liab. Litig., 55 F.3d 768, 813 (3d Cir. 1995). Counsel’s appreciation of the merits was well-developed in the present case by at least February 19, 2013, when the Court certified the class and resolved cross motions for summary judgment, revealing the strengths and weaknesses of the case.
10

Case 2:11-cv-04027-LDD Document 114 Filed 04/15/14 Page 13 of 17
(4) The risks of establishing liability. This Court granted in part and denied in part cross motions for summary judgment. Some of the issues presented to the Court were relatively novel and untested in this jurisdiction. All parties faced significant risks in the further proceedings ordered by this Court and, if an appeal were to be filed, in the Third Circuit Court of Appeals.
(5) The risks of establishing damages. Because this was an action for injunctive relief, the fifth Girsh factor does not apply. Hawker v. Consovoy, 198 F.R.D. 619, 632 (D.N.J. 2001).
(6) The risks of maintaining the class action through trial. The class was certified prior to trial and the action was decided on cross motions for summary judgment; thus, there is little risk associated with this factor.
(7) The ability of the defendants to withstand a greater judgment. Because this action sought injunctive and declaratory relief, this factor is inapplicable.
(8) The range of reasonableness of the settlement fund in light of the best possible recovery and (9) the range of reasonableness of the settlement fund to a possible recovery in light of all the attendant risks of litigation. In evaluating these factors in a case seeking injunctive relief, courts compare the relief accorded by the settlement to the relief Plaintiffs could expect to receive after trial, in light of the risks of litigation. D.M. v. Terhune, 67 F. Supp. 2d 401, 410-11 (D.N.J. 1999). Here, the settlement addresses the crux of the relief ordered by the Court and, indeed, some of the relief denied by the Court. The Settlement Agreement provides a conduct-driven remedy that was specifically attuned to the unique issues presented in this case by capable parties and counsel well-versed in educational settings, processes, and law. Further, as noted above, there are risks and costs associated with continuing the litigation. Plaintiffs could lose or achieve less than this Settlement Agreement after the Court defines “the specific contours
11

Case 2:11-cv-04027-LDD Document 114 Filed 04/15/14 Page 14 of 17
of injunctive relief” or after the Third Circuit reviews the case. The settlement is a fair resolution of Plaintiffs’ claims, in light of all the attendant risks of litigation. II. The Proposed Notice To Class Members Is Adequate.
The Parties propose that notice be given to class members through a variety of methods, including notifying identifiable parents of students with autism in grades K-8, and identifiable parents of rising kindergarten students currently enrolled in early intervention, by first class mail by the School District, additionally through publication in the Philadelphia Inquirer, the Philadelphia Daily News, the Philadelphia Tribune, and the Notebook (an educational newspaper) as well as publication on the School District’s website and PILCOP’s website. The School District shall bear the costs, other than for PILCOP’s website.
As this class action was certified under Federal Rule of Civil Procedure 23(a) and 23(b)(2) (Doc. 72), the notice requirements are less stringent than for Rule 23(b)(3) class actions which typically involve money damages. Rule 23(c)(2)(A) states that “[f]or any class certified under Rule 23(b)(1) or (b)(2), the court may direct appropriate notice to the class.” Rule 23(e) governs proposed settlements and requires the court to “direct notice in a reasonable manner to all class members who would be bound by the proposal.” Fed. R. Civ. P. 23(e)(1); see also Daniel B. v. O’Bannon, 633 F. Supp. 919, 926 (E.D. Pa. 1986) (“The court complied with Fed. R. Civ. P. 23(e) by ordering notice of the proposed settlement sent by first class mail to all class members as well as to parents, guardians or family representatives. Any additional notice in a Rule 23(b)(2) case is not obligatory but discretionary with the court.”). Generally to comply with Rule 23(e) the notice must be reasonable and “the best practicable under the circumstances.” Daniel B., 633 F. Supp. at 922; Harris v. City of Phila., No. 82-CV-1847, 2000 U.S. Dist. LEXIS 12579, at *34 (E.D. Pa. Aug. 30, 2000).
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Here the notice is fair and reasonable and the best practicable under the circumstances. Dissemination is more than satisfactory—not only will the vast majority of class member receive the notice by mail, but the School District’s website, PILCOP’s website and four Philadelphia newspapers will also contain the notice. Finally, the form of notice is adequate to inform class members of their rights. The notice provides a summary of the content of the lawsuit and its procedural history, details the history of settlement negotiations, and explains the settlement terms in simple/plain language. The notice also provides instructions on obtaining information relevant to the litigation, gives contact information for inquiries concerning the Settlement Agreement, sets forth the process for objecting to the Settlement Agreement, and explains that individual claimants reserve their rights.
CONCLUSION For the foregoing reasons, the Parties respectfully request that the Court preliminarily approve the proposed Settlement Agreement, approve the Parties’ proposed form of notice and proposal for providing notice, and set this matter for a fairness hearing.

Dated: April 15, 2014

Respectfully,
/s/ Sonja Kerr Sonja Kerr (I.D. No. 95137)
skerr@pilcop.org PUBLIC INTEREST LAW CENTER OF PHILADELPHIA 1709 Benjamin Franklin Parkway, Second Floor Philadelphia, PA 19103 Telephone: (215) 627-7100 Facsimile: (215) 627-3183
Co-Counsel for Plaintiffs
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Case 2:11-cv-04027-LDD Document 114 Filed 04/15/14 Page 16 of 17
Cheryl Krause (I.D. No. 90297) cheryl.krause@dechert.com
David J. Stanoch (I.D. No. 91342) david.stanoch@dechert.com
Darla D. Woodring (I.D. No. 306866) darla.woodring@dechert.com
DECHERT LLP Cira Centre 2929 Arch Street Philadelphia, PA 19104-2808 Telephone: (215) 994-4000 Facsimile: (215) 994-2222 Co-Counsel for Plaintiffs
/s/ David Smith David Smith (I.D. No. 21480)
dsmith@schnader.com Benjamin D. Wanger (I.D. No. 209317)
bwanger@schnader.com SCHNADER HARRISON SEGAL & LEWIS LLP 1600 Market Street, Suite 3600 Philadelphia, PA 19103-7286 Telephone: (215) 751-2000 Facsimile: (215) 751-2205 Counsel for Defendants
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IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF PENNSYLVANIA

P.V., a minor, by and through his Parents, Pedro Valentin and Yolanda Cruz, individually, and on behalf of all others similarly situated, et al.,
Plaintiffs, v. The School District of Philadelphia, et al.,
Defendants.

) ) ) Civil Action No. 2:11-cv-04027 ) ) ) ) ) )

[PROPOSED] ORDER AND NOW, this _____ day of ____________, 2014, upon consideration of Joint Motion for Preliminary Approval of Settlement Agreement and the Memorandum in Support of the Joint Motion, it is hereby ORDERED that: (1) The Settlement Agreement as proposed by the Parties is preliminarily approved; (2) A hearing to determine if the Settlement Agreement is “fair, reasonable and adequate” pursuant to Fed. R. Civ. P. 23(e) shall be held on ______ 2014 at ____ o’clock in Courtroom _____ U.S. Courthouse, 601 Market Street, Philadelphia, PA 19106; (3) The notice to class submitted with the Joint Motion is approved and the School District of Philadelphia is directed to provide notice by first class mail to all class members it can identify from its records, and publish the notice in four publications, the Philadelphia Inquirer, the Philadelphia Daily News, the Philadelphia Tribune, and the Notebook. In addition, the School District of Philadelphia and the Public Interest Law Center of Philadelphia are directed to post the notice on their websites.
BY THE COURT: _______________________________
Davis, J

Case 2:11-cv-04027-LDD Document 114-1 Filed 04/15/14 Page 1 of 13
Exhibit A

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SETTLEMENT AGREEMENT
AND NOW, this 15th day of April, 2014, the undersigned parties, as further described herein, in consideration of the mutual promises and covenants further contained herein, and intending to be legally bound, hereby agree as follows:
I. BACKGROUND A. Parties. This Settlement Agreement (“Agreement”) is made by and between: (1) the School District of Philadelphia (the “School District”) and the School Reform Commission (“SRC”)1 (collectively “Defendants”) and (2) P.V., M.M., J.V., and R.S., by and through their parents (“Plaintiffs”) and the class certified by the Court in P.V. v. The School District of Philadelphia, 289 F.R.D. 227, 236 (E.D. Pa. 2013): All children with autism in the School District of Philadelphia in grades kindergarten through eight (“K-8”) who have been transferred, are in the process of being transferred, or are at risk of being transferred, as a result of the School District’s upper-leveling process, the parents and guardians of those children, and future members of the class. (the “Class” or “Plaintiff Class”). B. Terminology. As used herein, the term “Upper-Leveling” or “UpperLevel Transfer” refers to when a student whose Individualized Education Program (“IEP”) requires use of an Autistic Support (“AS”) classroom completes the highest grade level for which an AS classroom is provided in his or her current school building and the School District transfers that student to a different school where those services can continue to be provided, despite that students completing the same grade level who do not require use of an AS classroom can continue to the next grade level in the same school building.
1 None of the individual defendants named in the complaint is currently employed by the School District.
1

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C. Resolution of Pending Litigation and Claims. This Agreement concerns the resolution and dismissal of all Class claims seeking prospective injunctive relief challenging the School District’s Upper-Leveling of class members which are or could have been asserted in P.V. v. The School District of Philadelphia, No. 2:11-cv-4027 (E.D. Pa.) (the “P.V. matter”), in exchange for the consideration specifically set forth herein.
II. SETTLEMENT TERMS A. List of AS Classrooms. By October 15 of each school year, the School District shall publish a list of all the schools within the School District that have AS classrooms for children in grades K-8. The list may be published with appropriate disclaimers regarding its accuracy and that school configurations are subject to change at any time throughout the school year. The list shall be published on the School District’s website in a conspicuous and clear manner. B. Notice. The School District shall provide parents of children with autism two notice letters, – one in January and one in June2 – prior to any potential UpperLeveling of any Class member. The notice letters and list of classrooms (see supra Part II(A)), together, shall constitute and satisfy the spirit of prior written notice. All letters shall be copied (“cc’d”) to the child’s entire IEP team. The draft letters speak for themselves and are attached hereto as Exhibit 1, but for further clarification:
2 As the effective date of the Settlement Agreement is April 2014, class members will only receive the June notice for the current (2013-2014) school year and that letter will not include the language from the sample at Exhibit C that prior notice was given. Furthermore, because June 1, 2014 is a Sunday, the notice letters will be sent by June 2, 2014.
2

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(i) The first letter will be sent on or about January 17 and will notify parents of a potential Upper-Level Transfer and inform them that they can talk to a School District designee or their child’s classroom teacher about Upper-Leveling or request an IEP meeting to discuss their child’s needs.
(ii) The second letter will be sent on or about June 1 and include building assignment information, enclose the most current version of “Parents’ Rights: Understanding the Procedural Safeguards Notice” booklet and inform parents that they can contact a School District designee, call the Office for Dispute Resolution or contact any other organization listed in the booklet for more information about mediation or filing a due process request.
C. Maintenance of Individual Rights. Individual Class members shall retain their statutory rights to challenge the circumstances of their own Upper-Level Transfer, including those contained within 20 U.S.C. § 1415 and 34 C.F.R. § 300, et seq.
D. Enforcement of Settlement Agreement. (i) Continuing Limited Jurisdiction. The Parties agree that the Court
shall retain jurisdiction through January 2, 2017, for the sole and limited purpose of enforcing compliance with this Agreement in accordance with the terms of this paragraph. Such jurisdiction shall automatically terminate effective January 3, 2017, except that with respect to any enforcement action commenced in accordance with the provisions of this section prior to January 3, 2017, but remaining open as of that date, such matter shall continue to final resolution; otherwise, after January 3, 2017, the
3

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Court shall be fully and completely divested of jurisdiction with respect to the enforcement of this Agreement.
(ii) Enforcement. If at any time from the final Court approval of the Agreement through January 3, 2017, Class counsel have a reasonably justified and colorable grievance regarding compliance with this Agreement on a Class-wide, and not individualized, basis, Class counsel shall give written notice to the School District with a copy to counsel for the School District. The School District shall have 60 calendar days to resolve the alleged concern on the basis described in such grievance and developed through further communication between the Parties. If, after the expiration of such resolution period, Class counsel is not reasonably satisfied with any proposed action or resolution, they may make a filing with Magistrate Judge Rice to enforce the Agreement. Judge Rice shall apply an appropriate remedy with respect to the specific matters addressed in the written complaint only and no others. The mechanism set forth in this Paragraph II(D)(ii) shall not be used to resolve grievances regarding specific Class members who may invoke appropriate administrative processes regarding their individual rights. For avoidance of doubt, this Agreement survives the divestment of the Court’s jurisdiction, and may be enforced after January 3, 2017 via other legal process or action.
E. Class Action Settlement Approval. The Parties agree to cooperate and cause to be filed on or before April 15, 2014, a joint motion for preliminary approval of settlement agreement, and to otherwise facilitate approval of the Agreement including the submission of a form of notice to the Class under Fed. R. Civ. P. 23 as required by
4

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rule and/or other Order of the Court. The Parties understand and agree that the burden of proof and persuasion concerning the fairness, reasonableness and adequacy of this Agreement shall rest with the Plaintiff Class regarding approval of this Agreement. Thus Plaintiffs will take the lead in drafting and Defendants shall have the opportunity to review the motion and Class notice form prior to submission to the Court. It is further understood and agreed by the Parties that the motion for settlement agreement approval and related papers filed with the Court shall note that the Defendants join the petition of the Plaintiffs.
III. RELEASE A. Class Claims. The Parties hereby remise, release, quitclaim and forever discharge each other and their respective successors, assigns, affiliates, employees, agents, directors, officers, boards, divisions, bureaus, sections and all other related entities, whether or not officially constituted, of and from all and any manner of actions, causes of actions, judgments, suits, debts, accounts, and claims for services or fines, monies, fees, expenses and/or other amounts, arising out of or relating to the P.V. matter, except as specifically outlined herein in Paragraphs II(C) and III(B). B. No Individual Waiver. Nothing in Paragraph III(A), or anywhere else in the Agreement, shall be construed or is intended to mean that any individual Class member is waiving any right or opportunity to file an individual due process complaint or to seek other recourse with respect to any issue arising in the course of the School District’s provision of special education programs and services to him or her, including, e.g., to file a special education complaint with the Pennsylvania Department of
5

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Education, or to take any action to enforce individual rights under the Individuals with Disabilities Education Act, 20 U.S.C. § 1400 et seq. and as amended (including 20 U.S.C. § 1415), Chapter 14 of the Pennsylvania Code of Education Regulations, 22 Pa. Code § 14 et seq., Title II of the Americans with Disabilities Act, 42 U.S.C. § 12131 et seq. and as amended, and Section 504 of the Rehabilitation Act, 29 U.S.C. § 794, or other applicable rules or laws. Nothing in this Agreement shall constitute in any way a waiver of the provisions of the LeGare Consent Decree for those Class members in grade 8.
IV. GOVERNING LAW This Agreement shall be governed by the laws of the Commonwealth of Pennsylvania. V. ATTORNEYS’ FEES AND COSTS The Parties agree that the School District will pay the Public Interest Law Center of Philadelphia (“PILCOP”), as Class counsel, $325,000 in attorneys’ fees and costs in three installments. The School District’s first payment of $100,000 is due 60 calendar days after receiving final approval from the Court. The School District shall make its second payment of $125,000 on or before October 15, 2014. The School District shall make its third and final payment of $100,000 on or before July 15, 2015. Plaintiffs’ counsel agree to waive and shall not be entitled to any additional fee for monitoring or administering this Agreement except to the extent it may be a prevailing party in any proceeding to enforce it, including enforcement of the attorneys’ fees and costs referenced herein. With the exception of the amounts set forth in this Paragraph V, the
6

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Parties hereto are otherwise each responsible for the payment of their own respective attorneys’ fees, expenses and costs incurred in connection with the P.V. matter.
VI. CLASS NOTICE The School District shall administer and bear the costs associated with disseminating notice to class members of the Agreement via first-class mail within ten business days of the Court’s preliminary approval of the Agreement. Within five business days of mailing the notice, the School District shall certify in writing to Plaintiffs’ counsel how many letters it has mailed. The School District also shall cause and bear the costs associated with the publication of the class notice, no less than ¼ of one page in size, in the Philadelphia Inquirer, Philadelphia Daily News, Philadelphia Tribune, and Philadelphia Notebook, to be run weekly for at least two full weeks within ten business days of the Court’s preliminary approval of the Agreement. Within five business days of arranging for newspaper publication, the School District shall certify in writing to Plaintiffs’ counsel the size, frequency, and run dates for the notice to be published. The School District also shall publish the class notice on its website, via a clear and conspicuous link that shall be active through final approval, within ten business days of the Court’s preliminary approval of the Agreement. Within three business days of arranging for website publication, the School District shall certify in writing to Plaintiffs’ counsel the link, manner, and format of the notice’s publication on the School District’s website. VII. ENTIRE AGREEMENT This Agreement is the entire agreement of the Parties with respect to the subject matter hereof, there are no other agreements, express or implied, choate or inchoate,
7

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relating to the subject matter hereof, and, if there is, and it is not set forth and referenced specifically herein, it is hereby declared null, void and of no further force, influence, consequence or effect. No promise or inducement not herein expressed has been made to any of the Parties, by any of the Parties, and no party hereto relies on any statement or representation made by any person, whether or not a party hereto, which is not specifically set forth in this Agreement.
VIII. COUNSEL Counsel are executing this Agreement on behalf of the Parties hereto, and counsel hereby represent and warrant that their respective clients have consulted with them or other counsel of their choice regarding the content, meaning and effect of this Agreement, and that their mutual execution on behalf of their clients indicates that they are authorized to act on their client’s behalf, and that such client acted freely, willingly and upon being fully informed of its or their legal rights, without duress, coercion or otherwise. The Parties hereto agree that this Agreement was jointly drafted and that it shall not, in the event of any dispute, be construed or construable against any of them on the basis of the source of draftsmanship.
8

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IN WITNESS WHEREOF, this Settlement Agreement has been duly executed by counsel, authorized to do so as indicated herein:
PLAINTIFF CLASS

Dated: April 15, 2014

/s/ Sonja Kerr Sonja Kerr, Esq.

Dated: April 15, 2014

DEFENDANTS
/s/ David Smith David Smith, Esq.

9

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Exhibit 1

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January 17, 20__
VIA REGULAR MAIL Parent(s) of Class Member 1234 Broad Street Philadelphia, PA 191xx
Re: Notice of Change Dear Parent: Your child is currently in the [insert current grade] and assigned to a [insert current classroom grade range] Autistic Support (“AS”) classroom at [insert name of current school]. That school will not have an AS program available for students in grades [insert next classroom grade range] next year. If your child continues to need a supplemental level of autistic support for the next school year, your child will be assigned next year to a new school building that has a grade-appropriate AS classroom. The School District is currently in the process of determining a location. You will receive a letter in June notifying you of your child’s new school assignment. [Your child will be assigned to X building next year (if known replace previous 2 sentences)]. Please do not hesitate to contact me at [insert designee’s telephone number] regarding this transfer. You can also speak with your child’s classroom teacher regarding transition issues, or request an IEP meeting to discuss your child’s needs.
Sincerely,
[School District designee]
cc: IEP Team LEA, SEL, and Special Education Teacher

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June 1, 20__
VIA REGULAR MAIL Parent(s) of Class Member 1234 Broad Street Philadelphia, PA 191xx
Re: Notice of Change Dear Parent: We informed you previously that your child will be assigned to a new school building next year because your child’s current school building will not have a grade-appropriate Autistic Support (“AS”) classroom for your child. Your child will be assigned to [next school building] for the 20__-__ school year. I am available to answer questions or to discuss any concerns you may have. My telephone number is [insert designee’s telephone number]. I have enclosed the “Parents’ Rights: Understanding the Procedural Safeguards Notice” pamphlet published by the Pennsylvania Department of Education Bureau of Special Education which can provide you with more information. You can call the Office for Dispute Resolution (“ODR”) at 1-800-222-3353 or any organization listed in the pamphlet for more information about mediation or to file a request for a due process hearing. If, after talking to the ODR or other organizations listed, you intend to mediate or to file for a due process hearing, please notify me at the above number as well. Sincerely,
[School District designee]
cc: IEP Team LEA, SEL and Special Education Teacher

Case 2:11-cv-04027-LDD Document 114-2 Filed 04/15/14 Page 1 of 4
Exhibit B

Case 2:11-cv-04027-LDD Document 114-2 Filed 04/15/14 Page 2 of 4
Notice to Parents of Students with Autism in the School District of Philadelphia
Notice of Hearing to Settle Class Action Litigation:
This Notice describes a proposed Settlement Agreement between parents of students with autism who attend school in the School District of Philadelphia and the School District of Philadelphia (the “Parties”). This Notice tells you what the Parties have agreed to, how to get more information regarding the Settlement, and how to object to the proposed Settlement Agreement if you think it is not fair as it relates to the provision of special education services in the School District.
On January 20, 2011, Plaintiffs, students with autism and their parents sued the School District of Philadelphia and challenged the School District’s policy and practice of automatically transferring, or “upper-leveling,” K-8 students with autism to different schools, without prior notice or input from parents or other Individualized Education Program (“IEP”) team members. This case is called P.V. v. The School District of Philadelphia, No. 2:11-cv-4027 (E.D. Pa.).
By Orders and Memorandum Opinions entered on February 19, 2013, the Court granted in part and denied in part cross motions for summary judgment (Docs. 74 and 75) and granted Plaintiffs’ motion for class certification under Federal Rules of Civil Procedure 23(a) and 23(b)(2) with respect to the claims on which summary judgment was entered for Plaintiffs (Docs. 72 and 73). The Court granted summary judgment in favor of the Plaintiffs on Plaintiffs’ claims that the decision-making process leading up to the transfer of a student with autism is conducted with little to no parental notice or involvement, and without the required consideration of the child’s individualized circumstances. Accordingly, the Court ordered the School District to “alter its upper-leveling process for children with autism to provide prior written notice and a level of parental participation that complies with the procedural requirements under the IDEA.” (Doc. 74).
To avoid further litigation, the Parties have reached a Settlement Agreement and have filed a motion requesting the Court to approve it.
On ______ 2014 at ____ o’clock in Courtroom _____ of the U.S. Courthouse, 601 Market Street, Philadelphia, PA 19106, Judge Davis will hold a fairness hearing to receive testimony on whether to approve the Settlement Agreement.

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Notice to Parents of Students with Autism in the School District of Philadelphia
The Settlement Agreement does not affect the rights of any individual students or their parent(s)/guardian(s) to claim the student was denied special education programs or services which he or she was entitled to receive under state or federal law and seek appropriate relief.
The Settlement Agreement simply mandates that the School District must provide notice and an opportunity for parental participation before upper-leveling class members. Once the Settlement Agreement is effective, the School District must:
(1) publish a list of all the schools within the School District that have Autistic Support classrooms, and the grade range of those classrooms, by October 15 of each year;
(2) provide two letter notices – one in January and one in June – to class members prior to transferring them; and
(3) inform parents that they can discuss the proposed transfer and their child’s needs at an IEP meeting and retain their rights to challenge their child’s individual transfer.
The Parties agreed to end the lawsuit in exchange for this Settlement Agreement. (Again, however, no individual student is waiving his or her right to file a due process complaint regarding his/her education.) Class counsel will receive a payment toward its fees, expenses and costs from the School District of $325,000. Class counsel will receive no additional fee for monitoring the Settlement Agreement.
Copies of the Settlement Agreement and Complaint in the case can be found on the website of the School District, http://www.phila.k12.pa.us/, or class counsel, www.pilcop.org. For further information about the Settlement or fairness hearing you can contact class counsel, The Public Interest Law Center at PVAutismsettlement@pilcop.org or at 215-627-7100 ext. 258.

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Notice to Parents of Students with Autism in the School District of Philadelphia
HOW TO OBJECT TO THIS SETTLEMENT AGREEMENT IF YOU THINK IT IS UNFAIR
If you do not want to object to this proposed Settlement Agreement, it is not necessary for you to do anything. If, however, you want to comment on the proposed Settlement Agreement or object to it as not being fair, you or someone on your behalf may file written comments or objections on or before ________, 2014. Written comments and objections should be submitted to this address: Office of the Clerk, United States District Court for the Eastern District of Pennsylvania, 601 Market Street, Philadelphia, PA 19106. Attn: ___________.
You should also send a copy of your comments to the attorneys for each party at the addresses below:
Attorneys for Plaintiff Class: PUBLIC INTEREST LAW CENTER OF PHILADELPHIA c/o Sonja Kerr 1709 Benjamin Franklin Parkway, 2nd Floor Philadelphia, PA 19103 Or via email to: skerr@pilcop.org
Attorneys for the School District: SCHNADER HARRISON SEGAL & LEWIS LLP c/o David Smith 1600 Market Street, Suite 3600 Philadelphia, PA 19103

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Exhibit C

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January 17, 20__
VIA REGULAR MAIL Parent(s) of Class Member 1234 Broad Street Philadelphia, PA 191xx
Re: Notice of Change Dear Parent: Your child is currently in the [insert current grade] and assigned to a [insert current classroom grade range] Autistic Support (“AS”) classroom at [insert name of current school]. That school will not have an AS program available for students in grades [insert next classroom grade range] next year. If your child continues to need a supplemental level of autistic support for the next school year, your child will be assigned next year to a new school building that has a grade-appropriate AS classroom. The School District is currently in the process of determining a location. You will receive a letter in June notifying you of your child’s new school assignment. [Your child will be assigned to X building next year (if known replace previous 2 sentences)]. Please do not hesitate to contact me at [insert designee’s telephone number] regarding this transfer. You can also speak with your child’s classroom teacher regarding transition issues, or request an IEP meeting to discuss your child’s needs.
Sincerely,
[School District designee]
cc: IEP Team LEA, SEL, and Special Education Teacher

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June 1, 20__
VIA REGULAR MAIL Parent(s) of Class Member 1234 Broad Street Philadelphia, PA 191xx
Re: Notice of Change Dear Parent: We informed you previously that your child will be assigned to a new school building next year because your child’s current school building will not have a grade-appropriate Autistic Support (“AS”) classroom for your child. Your child will be assigned to [next school building] for the 20__-__ school year. I am available to answer questions or to discuss any concerns you may have. My telephone number is [insert designee’s telephone number]. I have enclosed the “Parents’ Rights: Understanding the Procedural Safeguards Notice” pamphlet published by the Pennsylvania Department of Education Bureau of Special Education which can provide you with more information. You can call the Office for Dispute Resolution (“ODR”) at 1-800-222-3353 or any organization listed in the pamphlet for more information about mediation or to file a request for a due process hearing. If, after talking to the ODR or other organizations listed, you intend to mediate or to file for a due process hearing, please notify me at the above number as well. Sincerely,
[School District designee]
cc: IEP Team LEA, SEL and Special Education Teacher

P.V. et al v. THE SCHOOL DISTRICT OF PHILADELPHIA et al, Docket No. 2:11-cv-04027 (E.D. Pa. Jun 20, 2011), Court Docket
General Information

Court
Federal Nature of Suit Docket Number Status

United States District Court for the Eastern District of Pennsylvania; United States District Court for the Eastern District of Pennsylvania Civil Rights - Disabilities - Other[446] 2:11-cv-04027 CLOSED

© 2017 The Bureau of National Affairs, Inc. All Rights Reserved. Terms of Service // PAGE 39

 </s> Case: 2:11-cv-4027 As of: 10/27/2017 01:25 AM EDT 1 of 14
CLOSED,SPECIAL
United States District Court Eastern District of Pennsylvania (Philadelphia) CIVIL DOCKET FOR CASE #: 2:11−cv−04027−LDD

P.V. et al v. THE SCHOOL DISTRICT OF PHILADELPHIA et Date Filed: 06/20/2011

al

Date Terminated: 06/04/2014

Assigned to: HONORABLE LEGROME D. DAVIS

Jury Demand: None

related Cases: 2:11−cv−04482−LDD

Nature of Suit: 446 Civil Rights:

2:13−cv−04654−ER 2:15−cv−00237−GEKP

Americans with Disabilities − Other Jurisdiction: Federal Question

Cause: 20:1400 Civil Rights of Handicapped Child

Plaintiff

P.V. A MINOR, BY AND THROUGH HIS PARENTS, PEDRO VALENTIN AND YOLANDA CRUZ, INDIVIDUALLY, AND ON BEHALF OF ALL OTHERS SIMILARLY SITUATED

represented by DANIEL G. BOWERS DECHERT LLP 1775 I STREET NW SUITE 1100 WASHINGTON, DC 20006 202−261−3455 Email: daniel.bowers@dechert.com TERMINATED: 04/19/2013 LEAD ATTORNEY

SONJA D. KERR THE PUBLIC INTEREST LAW CENTER OF PHILA 1709 BENJAMIN FRANKLIN PKWY 2ND FLOOR PHILADELPHIA, PA 19103 215−627−7100 Email: skerr@pilcop.org LEAD ATTORNEY ATTORNEY TO BE NOTICED

CHERYL A. KRAUSE DECHERT LLP 2929 ARCH STREET PHILADELPHIA, PA 19104 215−994−2139 Email: cheryl.krause@dechert.com ATTORNEY TO BE NOTICED

DARLA D. WOODRING DECHERT LLP 2929 ARCH STREET PHILADELPHIA, PA 19104 215−994−2472 Email: darla.woodring@dechert.com ATTORNEY TO BE NOTICED

DAVID J. STANOCH GOLOMB & HONIK, P.C. 1515 Market Street Suite 1100 PHILADELPHIA, PA 19102 215−985−9177 Fax: 215−985−4169 Email: dstanoch@golombhonik.com ATTORNEY TO BE NOTICED

JEFFREY W. RUBIN

Case: 2:11-cv-4027 As of: 10/27/2017 01:25 AM EDT 2 of 14

DECHERT LLP CIRA CENTRE 2929 ARCH ST PHILADELPHIA, PA 19104 215−994−2807 Email: jeffrey.rubin@dechert.com TERMINATED: 02/21/2012

TARA L. KELLY DECHERT LLP 2929 ARCH STREET PHILADELPHIA, PA 19104 215−994−2287 Fax: 215−994−2222 Email: tara.kelly@dechert.com TERMINATED: 02/17/2012

Plaintiff
M.M. A MINOR, BY AND THROUGH HIS PARENT, CARLA MURPHY, INDIVIDUALLY, AND ON BEHALF OF ALL OTHERS SIMILARLY SITUATED

represented by DANIEL G. BOWERS (See above for address) TERMINATED: 04/19/2013 LEAD ATTORNEY
SONJA D. KERR (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

CHERYL A. KRAUSE (See above for address) ATTORNEY TO BE NOTICED

DARLA D. WOODRING (See above for address) ATTORNEY TO BE NOTICED

DAVID J. STANOCH (See above for address) ATTORNEY TO BE NOTICED

JEFFREY W. RUBIN (See above for address) TERMINATED: 02/21/2012

TARA L. KELLY (See above for address) TERMINATED: 02/17/2012

Plaintiff
J.V. A MINOR, BY AND THROUGH HIS PARENTS, SHARON VARGAS AND ISMAEL VARGAS, INDIVIDUALLY, AND ON BEHALF OF ALL OTHERS SIMILARLY SITUATED

represented by SONJA D. KERR (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
CHERYL A. KRAUSE (See above for address) ATTORNEY TO BE NOTICED

DARLA D. WOODRING (See above for address) ATTORNEY TO BE NOTICED

DAVID J. STANOCH (See above for address)

Case: 2:11-cv-4027 As of: 10/27/2017 01:25 AM EDT 3 of 14

ATTORNEY TO BE NOTICED

JEFFREY W. RUBIN (See above for address) TERMINATED: 02/21/2012

TARA L. KELLY (See above for address) TERMINATED: 02/17/2012

Plaintiff
R.S. A MINOR, BY AND THROUGH HIS PARENTS, HEATHER SANASAC AND MATTHEW SANASAC, INDIVIDUALLY, AND ON BEHALF OF ALL OTHER SIMILARLY SITUATED

represented by DANIEL G. BOWERS (See above for address) TERMINATED: 04/19/2013 LEAD ATTORNEY
SONJA D. KERR (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

CHERYL A. KRAUSE (See above for address) ATTORNEY TO BE NOTICED

DARLA D. WOODRING (See above for address) ATTORNEY TO BE NOTICED

DAVID J. STANOCH (See above for address) ATTORNEY TO BE NOTICED

JEFFREY W. RUBIN (See above for address) TERMINATED: 02/21/2012

TARA L. KELLY (See above for address) TERMINATED: 02/17/2012

V.
Defendant
THE SCHOOL DISTRICT OF PHILADELPHIA

represented by DAVID SMITH SCHNADER HARRISON SEGAL AND LEWIS L.L.P. 1600 MARKET STREET SUITE 3600 PHILADELPHIA, PA 19103 215−751−2190 Fax: 215−972−7409 Email: dsmith@schnader.com LEAD ATTORNEY ATTORNEY TO BE NOTICED
BENJAMIN D. WANGER SCHNADER HARRISON SEGAL & LEWIS LLP 1600 MARKET ST STE 3600 PHILADELPHIA, PA 19103 215−751−2824 Email: bwanger@schnader.com

Case: 2:11-cv-4027 As of: 10/27/2017 01:25 AM EDT 4 of 14

ATTORNEY TO BE NOTICED

Defendant
ARLENE ACKERMAN SUPERINTENDENT, IN HER OFFICIAL CAPACITY AS SUPERINTENDENT OF THE SCHOOL DISTRICT OF PHILADELPHIA

represented by DAVID SMITH (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
BENJAMIN D. WANGER (See above for address) ATTORNEY TO BE NOTICED

Defendant
LINDA WILLIAMS IN HER OFFICIAL CAPACITY AS THE INTERIM DEPUTY CHIEF OF SPECIAL EDUCATION FOR THE SCHOOL DISTRICT OF PHILADELPHIA

represented by DAVID SMITH (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
BENJAMIN D. WANGER (See above for address) ATTORNEY TO BE NOTICED

Defendant
THE SCHOOL REFORM COMMISSION AS THE BOARD OF THE SCHOOL DISTRICT OF PHILADELPHIA

represented by DAVID SMITH (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

BENJAMIN D. WANGER (See above for address) ATTORNEY TO BE NOTICED

Date Filed 06/20/2011
06/20/2011 06/23/2011 06/23/2011 06/23/2011 07/14/2011 07/27/2011

# Docket Text
1 COMPLAINT against ARLENE ACKERMAN, THE SCHOOL DISTRICT OF PHILADELPHIA, THE SCHOOL REFORM COMMISSION, LINDA WILLIAMS ( Filing fee $ 350 receipt number 045165.), filed by M.M., R.S., P.V., J.V..(rt) (Additional attachment(s) added on 6/21/2011: # 1 Civil Cover Sheet, # 2 Designation Form, # 3 Case Management Track Form) # 4 Exhibit, # 5 Exhibit) (rt). (Entered: 06/21/2011)
Summons Issued as to ARLENE ACKERMAN, THE SCHOOL DISTRICT OF PHILADELPHIA, THE SCHOOL REFORM COMMISSION, LINDA WILLIAMS. Four Forwarded To: Counsel on June 21, 2011 (rt) (Entered: 06/21/2011)
2 NOTICE of Appearance by DARLA D. WOODRING on behalf of J.V., M.M., P.V., R.S. with Certificate of Service(WOODRING, DARLA) (Entered: 06/23/2011)
3 NOTICE of Appearance by CHERYL A. KRAUSE on behalf of J.V., M.M., P.V., R.S. with Certificate of Service(KRAUSE, CHERYL) (Entered: 06/23/2011)
4 NOTICE of Appearance by TARA L. KELLY on behalf of J.V., M.M., P.V., R.S. with Certificate of Service(KELLY, TARA) (Entered: 06/23/2011)
5 NOTICE of Appearance by DAVID SMITH on behalf of ARLENE ACKERMAN, THE SCHOOL DISTRICT OF PHILADELPHIA, THE SCHOOL REFORM COMMISSION, LINDA WILLIAMS (SMITH, DAVID) (Entered: 07/14/2011)
6 SUMMONS Returned Executed by M.M., R.S., P.V., J.V. re: William Alexander served Summons and Complaint upon ARLENE ACKERMAN by Summons in a Civil Action. ARLENE ACKERMAN served on 7/6/2011, answer due 7/27/2011. (WOODRING, DARLA) (Entered: 07/27/2011)

Case: 2:11-cv-4027 As of: 10/27/2017 01:25 AM EDT 5 of 14

07/27/2011 07/27/2011
07/27/2011 07/28/2011 08/26/2011 08/26/2011 09/06/2011
09/19/2011 09/28/2011
09/30/2011 09/30/2011 09/30/2011 10/01/2011 10/01/2011 10/07/2011

7 SUMMONS Returned Executed by M.M., R.S., P.V., J.V. re: William Alexander served Summons and Complaint upon THE SCHOOL REFORM COMMISSION by Summons in a Civil Action. THE SCHOOL REFORM COMMISSION served on 7/6/2011, answer due 7/27/2011. (WOODRING, DARLA) (Entered: 07/27/2011)
8 SUMMONS Returned Executed by M.M., R.S., P.V., J.V. re: Williams Alexander served Summons and Complaint upon THE SCHOOL DISTRICT OF PHILADELPHIA by Summons in a Civil Action. THE SCHOOL DISTRICT OF PHILADELPHIA served on 7/6/2011, answer due 7/27/2011. (WOODRING, DARLA) (Entered: 07/27/2011)
9 SUMMONS Returned Executed by M.M., R.S., P.V., J.V. re: William Alexander served Summons and Complaint upon LINDA WILLIAMS by Service to Betty Prizill. LINDA WILLIAMS served on 7/6/2011, answer due 7/27/2011. (WOODRING, DARLA) (Entered: 07/27/2011)
10 Stipulation Extending Time to Answer the complaint. ARLENE ACKERMAN answer due 8/26/2011; THE SCHOOL DISTRICT OF PHILADELPHIA answer due 8/26/2011; THE SCHOOL REFORM COMMISSION answer due 8/26/2011; LINDA WILLIAMS answer due 8/26/2011, with Clerk's approval. (jl, ) (Entered: 07/28/2011)
11 MOTION to Dismiss Complaint filed by ARLENE ACKERMAN, THE SCHOOL DISTRICT OF PHILADELPHIA, THE SCHOOL REFORM COMMISSION, LINDA WILLIAMS.Memorandum, Certificate of Service. (Attachments: # 1 Exhibit A−F)(SMITH, DAVID) (Entered: 08/26/2011)
12 MOTION to Strike 1 Complaint, Class Action Allegations filed by ARLENE ACKERMAN, THE SCHOOL DISTRICT OF PHILADELPHIA, THE SCHOOL REFORM COMMISSION, LINDA WILLIAMS.Memorandum, Certificate of Service.(SMITH, DAVID) (Entered: 08/26/2011)
13 ORDER THAT PLAINTIFFS WILL HAVE UNTIL AND INCLUDING 9/30/11 TO RESPOND TO DEFENDANTS MOTION TO DISMISS AND MOTION TO STRIKE CLASS ACTION ALLEGATIONS; ETC.. SIGNED BY HONORABLE LEGROME D. DAVIS ON 9/6/11. 9/6/11 ENTERED AND E−MAILED.(jl, ) (Entered: 09/06/2011)
14 Consent MOTION for Extension of Time to File Class Certification Motion filed by J.V., M.M., P.V., R.S..Brief, certificate of service.(RUBIN, JEFFREY) (Entered: 09/19/2011)
15 ORDER THAT PLAINTIFFS UNOPPOSED MOTION TO EXTEND TIME TO MOVE FOR CLASS CERTIFICATION IS GRANTED. PLAINTIFFS SHALL FILE THEIR MOTION FOR CLASS CERTIFICATION ON OR BEFORE THIRTY DAYS AFTER THE CLOSE OF DISCOVERY IN THIS MATTER; ETC.. SIGNED BY HONORABLE LEGROME D. DAVIS ON 9/26/11. 9/28/11 ENTERED AND E−MAILED.(jl, ) (Entered: 09/28/2011)
18 RESPONSE to Motion re 12 MOTION to Strike 1 Complaint, Class Action Allegations filed by J.V., M.M., P.V., R.S.., with CERTIFICATE OF SERVICE. (tomg, ) (Entered: 10/03/2011)
19 MEMORANDUM of Law in Opposition to Defendants' MOTION to Dismiss together with Certificate of Service filed by J.V., M.M., P.V., R.S. (ti, ) (Entered: 10/03/2011)
20 EXHIBITS A AND B TO DEFENDANTS MOTIONT TO DISMISS by ARLENE ACKERMAN, THE SCHOOL DISTRICT OF PHILADELPHIA, THE SCHOOL REFORM COMMISSION, LINDA WILLIAMS.. (kk, ) (Entered: 10/03/2011)
16 RESPONSE to Motion re 12 MOTION to Strike 1 Complaint, Class Action Allegations filed by J.V., M.M., P.V., R.S.. (Attachments: # 1 Exhibit Ex. A, # 2 Exhibit Ex. B)(WOODRING, DARLA) (Entered: 10/01/2011)
17 RESPONSE in Opposition re 11 MOTION to Dismiss Complaint filed by J.V., M.M., P.V., R.S.. (WOODRING, DARLA) (Entered: 10/01/2011)
21 MOTION for Leave to file REPLY BRIEF IN SUPPORT OF 11 MOTION to Dismiss Complaint filed by ARLENE ACKERMAN, THE SCHOOL DISTRICT OF PHILADELPHIA, THE SCHOOL REFORM COMMISSION, LINDA WILLIAMS,

Case: 2:11-cv-4027 As of: 10/27/2017 01:25 AM EDT 6 of 14

10/07/2011
10/31/2011
10/31/2011
10/31/2011 10/31/2011 11/07/2011 11/09/2011 11/14/2011 11/29/2011 12/07/2011 12/09/2011 12/13/2011 12/14/2011

(REPLY BRIEF ATTACHED). (Attachments: # 1 Reply Brief in Support of Defendants' Motion to Dismiss, # 2 Text of Proposed Order)(SMITH, DAVID) Modified on 10/11/2011 (nd). Modified on 10/12/2011 (afm, ). (Entered: 10/07/2011)
22 MOTION for Leave to File Reply in Support of Defendants' Motion to Strike Class Action Allegations filed by ARLENE ACKERMAN, THE SCHOOL DISTRICT OF PHILADELPHIA, THE SCHOOL REFORM COMMISSION, LINDA WILLIAMS.Brief, Certificate of Service. (Attachments: # 1 Text of Proposed Order, # 2 Brief in Support of Motion to Strike Class Action Allegations)(SMITH, DAVID) (Entered: 10/07/2011)
23 MEMORANDUM AND ORDER THAT DEFENDANTS MOTION FOR LEAVE TO FILE A REPLY BRIEF IN SUPPORT OF DEFENDANTS MOTION TO DISMISS PLAINTIFFS COMPLAINT IS GRANTED. DEFENDANT MOTION FOR LEAVE TO FILE A REPLY BRIEF IN SUPPORT OF DEFENDANTS' MOTION TO STRIKE PLAINTIFFS CLASS ACTION ALLEGATIONS IS GRANTED. DEFENDANTS MOTION TO STRIKE CLASS ACTION ALLEGATIONS IS DENIED. DEFENDANTS MOTION TO DISMISS IS DENIED; ETC.. SIGNED BY HONORABLE LEGROME D. DAVIS ON 10/31/11. 10/31/11 ENTERED AND E−MAILED.(jl, ) (Entered: 10/31/2011)
24 ORDER THAT DEFENDANTS MOTION FOR LEAVE TO FILE A REPLY BRIEF IN SUPPORT OF DEFENDANTS MOTION TO DISMISS PLAINTIFFS COMPLAINT IS GRANTED. DEFENDANT MOTION FOR LEAVE TO FILE A REPLY BRIEF IN SUPPORT OF DEFENDANTS' MOTION TO STRIKE PLAINTIFFS CLASS ACTION ALLEGATIONS IS GRANTED. DEFENDANTS MOTION TO STRIKE CLASS ACTION ALLEGATIONS IS DENIED. DEFENDANTS MOTION TO DISMISS IS DENIED; ETC.. SIGNED BY HONORABLE LEGROME D. DAVIS ON 10/31/11. 10/31/11 ENTERED AND E−MAILED.(jl, ) (Entered: 10/31/2011)
25 DEFENDANTS REPLY BRIEF IN SUPPORT OF DEFENDANTS MOTION TO DISMISS. (jl, ) (Entered: 10/31/2011)
26 DEFENDANTS REPLY BRIEF IN SUPPORT OF DEFENDANTS MOTION TO STRIKE PLAINTIFFS CLASS ACTION ALLEGATIONS. (jl, ) (Entered: 10/31/2011)
27 Administrative Record. (jl, ) (Entered: 11/07/2011)
28 NOTICE of Appearance by BENJAMIN D. WANGER on behalf of ARLENE ACKERMAN, THE SCHOOL DISTRICT OF PHILADELPHIA, THE SCHOOL REFORM COMMISSION, LINDA WILLIAMS with Certificate of Service(WANGER, BENJAMIN) (Entered: 11/09/2011)
29 ANSWER to 1 Complaint, by ARLENE ACKERMAN, THE SCHOOL DISTRICT OF PHILADELPHIA, THE SCHOOL REFORM COMMISSION, LINDA WILLIAMS with affirmative defenses, Certificate of Service. (WANGER, BENJAMIN) Modified on 11/16/2011 (nd, ). (Entered: 11/14/2011)
30 NOTICE of Hearing: RULE 16 CONFERENCE SET FOR THURSDAY, DECEMBER 15, 2011, AT 4:30 P.M. IN JUDGE CHAMBERS ROOM 6614 BEFORE THE HONORABLE LEGROME D. DAVIS. 11/29/2011 ENTERED, COPIES EMAILED, AND MAILED. (miah,) (Entered: 11/29/2011)
31 NOTICE of Hearing: RULE 16 CONFERENCE HAS BEEN RESCHEDULED TO TUESDAY, DECEMBER 13, 2011, AT 3:00 P.M. IN JUDGE CHAMBERS ROOM 6614 BEFORE THE HONORABLE LEGROME D. DAVIS. 12/7/2011 ENTERED, COPIES EMAILED, AND MAILED. (miah,) (Entered: 12/07/2011)
32 Discovery Plan by All Parties.(RUBIN, JEFFREY) (Entered: 12/09/2011)
33 Minute Entry for proceedings held before HONORABLE LEGROME D. DAVIS: Pretrial Conference held on 12/13/11. (jl, ) (Entered: 12/13/2011)
34 SCHEDULING ORDER THAT ALL DISCOVERY SHALL CLOSE ON 5/25/12. PLAINTIFFS' MOTION FOR CLASS CERTIFICATION SHALL BE FILED BY 6/15/12. DISPOSITIVE MOTIONS SHALL BE FILED ON OR BEFORE 6/15/12;

Case: 2:11-cv-4027 As of: 10/27/2017 01:25 AM EDT 7 of 14

02/17/2012 02/17/2012 02/17/2012
02/21/2012 02/22/2012 02/22/2012
02/27/2012
03/01/2012 03/01/2012
03/05/2012 03/08/2012
03/09/2012 04/13/2012

ETC.. SIGNED BY HONORABLE LEGROME D. DAVIS ON 12/14/11. 12/14/11 ENTERED AND E−MAILED.(jl, ) (Entered: 12/14/2011)
35 NOTICE of Withdrawal of Appearance by TARA L. KELLY on behalf of All Plaintiffs (KELLY, TARA) (Entered: 02/17/2012)
36 NOTICE of Appearance by DAVID J. STANOCH on behalf of J.V., M.M., P.V., R.S. with Certificate of Service(STANOCH, DAVID) (Entered: 02/17/2012)
37 MOTION to Compel The Production of Documents and Responses to Interrogatories, and Request for Expedited Briefing filed by J.V., M.M., P.V., R.S..Memorandum, Certificate of Compliance, Certificate of Service. (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D, # 5 Exhibit E, # 6 Exhibit F, # 7 Exhibit G, # 8 Exhibit H, # 9 Exhibit I)(WOODRING, DARLA) (Entered: 02/17/2012)
38 NOTICE of Withdrawal of Appearance by JEFFREY W. RUBIN on behalf of All Plaintiffs (RUBIN, JEFFREY) (Entered: 02/21/2012)
Set/Reset Deadlines as to 37 MOTION to Compel The Production of Documents and Responses to Interrogatories, and Request for Expedited Briefing. RESPONSES DUE BY 2/27/2012. (jl, ) (Entered: 02/22/2012)
39 ORDER THAT PLAINTIFFS EXPEDITED MOTION TO COMPEL THE PRODUCTION OF DOCUMENTS IS GRANTED. ANY BRIEF IN OPPOSITION TO PLAINTIFFS MOTION SHALL BE FILED ON OR BEFORE 2/27/12; ETC.. SIGNED BY HONORABLE LEGROME D. DAVIS ON 2/22/12. 2/22/12 ENTERED AND E−MAILED.(jl, ) (Entered: 02/22/2012)
40 RESPONSE to Motion re 37 MOTION to Compel The Production of Documents and Responses to Interrogatories, and Request for Expedited Briefing filed by ARLENE ACKERMAN, THE SCHOOL DISTRICT OF PHILADELPHIA, THE SCHOOL REFORM COMMISSION, LINDA WILLIAMS. (Attachments: # 1 Text of Proposed Order Proposed Order, # 2 Exhibit Exhibit A, # 3 Exhibit Exhibit B, # 4 Exhibit Exhibit C, # 5 Exhibit Exhibit D)(WANGER, BENJAMIN) (Entered: 02/27/2012)
Set/Reset Scheduling Order Deadlines: DISCOVERY DUE BY 6/11/2012. MOTIONS DUE BY 6/25/2012. (jl, ) (Entered: 03/01/2012)
41 MEMORANDUM ORDER AND OPINION THAT PLAINTIFFS EXPEDITED MOTION TO COMPEL THE PRODUCTION OF DOCUMENTS AND RESPONSES TO INTERROGATORIES IS GRANTED IN PART AND DENIED IN PART. ALL DISCOVERY SHALL CLOSE ON 6/11/12. PLAINTIFFS' MOTION FOR CLASS CERTIFICATIONN SHALL BE FILED BY 6/25/12. DISPOSITIVE MOTIONS SHALL BE FILED ON OR BEFORE 6/25/12; ETC.. SIGNED BY HONORABLE LEGROME D. DAVIS ON 3/1/12. 3/1/12 ENTERED AND E−MAILED.(jl, ) (Entered: 03/01/2012)
42 MOTION for Clarification Plaintiffs' Motion for Minor Clarification of the Court's March 1, 2012 Order filed by J.V., M.M., P.V., R.S..Certificate of Service. (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D)(STANOCH, DAVID) (Entered: 03/05/2012)
43 RESPONSE to Motion re 42 MOTION for Clarification Plaintiffs' Motion for Minor Clarification of the Court's March 1, 2012 Order filed by ARLENE ACKERMAN, THE SCHOOL DISTRICT OF PHILADELPHIA, THE SCHOOL REFORM COMMISSION, LINDA WILLIAMS. (WANGER, BENJAMIN) (Entered: 03/08/2012)
44 ORDER THAT PLAINTIFF'S MOTION FOR MINOR CLARIFICATION OF THE COURT'S 3/1/12 ORDER IS DENIED; ETC.. SIGNED BY HONORABLE LEGROME D. DAVIS ON 3/9/12.3/9/12 ENTERED AND E−MAILED.(jl, ) (Entered: 03/09/2012)
45 APPLICATION by J.V., M.M., P.V., R.S.. FOR DANIEL G. BOWERS TO APPEAR PRO HAC VICE, STATEMENT, CERTIFICATE OF SERVICE. (FEE PAID) (jl, ) (Entered: 04/13/2012)

Case: 2:11-cv-4027 As of: 10/27/2017 01:25 AM EDT 8 of 14

04/19/2012 05/09/2012 07/13/2012
08/03/2012 08/03/2012 08/03/2012
08/06/2012 08/20/2012

46 AMENDED SCHEDULING ORDER THAT ALL DISCOVERY, INCLUDING EXPERT DEPOSITIONS, SHALL CLOSE ON 7/6/12. PLAINTIFFS' MOTION FOR CLASS CERTIFICATION SHALL BE FILED ON OR BEFORE 7/13/12. DISPOSITIVE MOTIONS SHALL BE FILED ON OR BEFORE 8/3/12; ETC.. SIGNED BY HONORABLE LEGROME D. DAVIS ON 4/18/12. 4/19/12 ENTERED AND E−MAILED.(jl, ) (Entered: 04/19/2012)
47 ORDER THAT THE APPLICATION OF DANIEL G. BOWERS TO APPEAR PRO HAC VICE IS GRANTED; ETC.. SIGNED BY HONORABLE LEGROME D. DAVIS ON 5/9/12. 5/9/12 ENTERED AND COPIES MAILED, E−MAILED.(jl, ) (Entered: 05/09/2012)
48 MOTION to Certify Class Plaintiffs' Motion for Class Certification filed by J.V., M.M., P.V., R.S..Memorandum in Support, Proposed Order, Certificate of Service. RESPONSES DUE BY 8/3/2012. (Attachments: # 1 Exhibit 1, # 2 Exhibit 2, # 3 Exhibit 3, # 4 Exhibit 4, # 5 Exhibit 5, # 6 Exhibit 6, # 7 Exhibit 7, # 8 Exhibit 8, # 9 Exhibit 9, # 10 Exhibit 10, # 11 Exhibit 11, # 12 Exhibit 12, # 13 Exhibit 13, # 14 Exhibit 14, # 15 Exhibit 15, # 16 Exhibit 16, # 17 Exhibit 17, # 18 Exhibit 18, # 19 Exhibit 19, # 20 Exhibit 20, # 21 Exhibit 21, # 22 Exhibit 22, # 23 Exhibit 23, # 24 Exhibit 24, # 25 Exhibit 25−1, # 26 Exhibit 25−2, # 27 Exhibit 26, # 28 Exhibit 27, # 29 Exhibit 28, # 30 Exhibit 29, # 31 Exhibit 30−1, # 32 Exhibit 30−2, # 33 Exhibit 31−1, # 34 Exhibit 31−2, # 35 Exhibit 31−3, # 36 Exhibit 32, # 37 Exhibit 33)(STANOCH, DAVID) (Entered: 07/13/2012)
49 MOTION for Summary Judgment filed by ARLENE ACKERMAN, THE SCHOOL DISTRICT OF PHILADELPHIA, THE SCHOOL REFORM COMMISSION, LINDA WILLIAMS.Memorandum, Certificate of Service. (Attachments: # 1 Text of Proposed Order, # 2 Exhibit A, # 3 Exhibit B, # 4 Exhibit C, # 5 Exhibit D, # 6 Exhibit E, # 7 Exhibit F, # 8 Exhibit G, # 9 Exhibit H, # 10 Exhibit I, # 11 Exhibit J, # 12 Exhibit K, # 13 Exhibit L, # 14 Exhibit M, # 15 Exhibit N, # 16 Exhibit O, # 17 Exhibit P, # 18 Exhibit Q, # 19 Exhibit R, # 20 Exhibit S, # 21 Exhibit T, # 22 Exhibit U, # 23 Exhibit V)(WANGER, BENJAMIN) (Entered: 08/03/2012)
50 Memorandum in Opposition re 48 MOTION to Certify Class Plaintiffs' Motion for Class Certification filed by ARLENE ACKERMAN, THE SCHOOL DISTRICT OF PHILADELPHIA, THE SCHOOL REFORM COMMISSION, LINDA WILLIAMS. (Attachments: # 1 Text of Proposed Order, # 2 Exhibit 1, # 3 Exhibit 2, # 4 Exhibit 3, # 5 Exhibit 4, # 6 Exhibit 5, # 7 Exhibit 6, # 8 Exhibit 7, # 9 Exhibit 8, # 10 Exhibit 9, # 11 Exhibit 10, # 12 Exhibit 11, # 13 Exhibit 12, # 14 Exhibit 13, # 15 Exhibit 14, # 16 Exhibit 15, # 17 Exhibit 16, # 18 Exhibit 17, # 19 Exhibit 18, # 20 Exhibit 19, # 21 Exhibit 20, # 22 Exhibit 21, # 23 Exhibit 22, # 24 Exhibit 23)(WANGER, BENJAMIN) Modified on 8/6/2012 (lisad, ). (Entered: 08/03/2012)
51 MOTION for Summary Judgment Plaintiffs' Motion for Summary Judgment filed by J.V., M.M., P.V., R.S..Memorandum of Law in Support of Plaintiffs' Motion for Summary Judgment, Certificate of Service. (Attachments: # 1 Statement of Facts, # 2 Exhibit 1, # 3 Exhibit 2, # 4 Exhibit 3, # 5 Exhibit 4, # 6 Exhibit 5, # 7 Exhibit 6, # 8 Exhibit 7, # 9 Exhibit 8, # 10 Exhibit 9, # 11 Exhibit 10, # 12 Exhibit 11, # 13 Exhibit 12, # 14 Exhibit 13, # 15 Exhibit 14, # 16 Exhibit 15, # 17 Exhibit 16, # 18 Exhibit 17, # 19 Exhibit 18, # 20 Exhibit 19, # 21 Exhibit 20, # 22 Exhibit 21, # 23 Exhibit 22, # 24 Exhibit 23, # 25 Exhibit 24, # 26 Exhibit 25, # 27 Exhibit 26, # 28 Exhibit 27, # 29 Exhibit 28, # 30 Exhibit 29, # 31 Exhibit 30, # 32 Exhibit 31, # 33 Exhibit 32, # 34 Exhibit 33, # 35 Exhibit 34−1, # 36 Exhibit 34−2, # 37 Exhibit 34−3, # 38 Exhibit 35, # 39 Exhibit 36, # 40 Exhibit 37−1, # 41 Exhibit 37−2, # 42 Exhibit 38, # 43 Exhibit 39, # 44 Exhibit 40)(STANOCH, DAVID) (Entered: 08/03/2012)
52 MOTION for Leave to File Joint Motion For Leave to File Replies and to Amend Briefing Schedule filed by ARLENE ACKERMAN, J.V., M.M., P.V., R.S., THE SCHOOL DISTRICT OF PHILADELPHIA, THE SCHOOL REFORM COMMISSION, LINDA WILLIAMS.Certificate of Service. (Attachments: # 1 Exhibit A−−Proposed Stipulated Amended Scheduling Order)(STANOCH, DAVID) (Entered: 08/06/2012)
53 ORDER THAT THE JOINT MOTION FOR LEAVE TO FILE REPLIES AND TO AMEND BRIEFING SCHEDULE (DOC. NO. 52) IS GRANTED. AS STIPULATED THE PARTIES MAY FILE REPLY MEMORANDA ACCORDING TO THE FOLLOWING SCHEDULE: PLAINTIFFS' MEMORANDUM IN OPPOSITION TO

Case: 2:11-cv-4027 As of: 10/27/2017 01:25 AM EDT 9 of 14

08/30/2012 08/30/2012 08/30/2012 08/30/2012 08/30/2012 08/30/2012 08/30/2012 08/30/2012 08/30/2012
09/11/2012

DEFENDANTS' MOTION FOR SUMMARY JUDGMENT SHALL BE FILED ON OR BEFORE 8/30/2012. DEFENDANTS' MEMORANDUM IN OPPOSITION TO PLAINTIFF'S MOTION FOR SUMMARY JUDGMENT SHALL BE FILED ON OR BEFORE 8/30/2012. OTHER INSTRUCTIONS ARE AS OUTLINED HEREIN. SIGNED BY HONORABLE LEGROME D. DAVIS ON 08/20/2012.08/20/2012 ENTERED AND COPIES E−MAILED.(jmf, ) (Entered: 08/20/2012)
54 RESPONSE in Opposition re 51 MOTION for Summary Judgment Plaintiffs' Motion for Summary Judgment filed by ARLENE ACKERMAN, THE SCHOOL DISTRICT OF PHILADELPHIA, THE SCHOOL REFORM COMMISSION, LINDA WILLIAMS. (Attachments: # 1 Supplement Response to Undisputed Facts, # 2 Text of Proposed Order Proposed Order)(WANGER, BENJAMIN) (Entered: 08/30/2012)
55 EXHIBIT 1 to 5 to 54 Response in Opposition to Plaintiffs' Motion for Summary Judgment by ARLENE ACKERMAN, THE SCHOOL DISTRICT OF PHILADELPHIA, THE SCHOOL REFORM COMMISSION, LINDA WILLIAMS. (Attachments: # 1 Exhibit 2, # 2 Exhibit 3, # 3 Exhibit 4, # 4 Exhibit 5)(WANGER, BENJAMIN) Modified on 8/30/2012 (md). (Entered: 08/30/2012)
56 EXHIBIT 6 to 54 Response in Opposition to Plaintiffs' Motion for Summary Judgment by ARLENE ACKERMAN, THE SCHOOL DISTRICT OF PHILADELPHIA, THE SCHOOL REFORM COMMISSION, LINDA WILLIAMS. (WANGER, BENJAMIN) Modified on 8/30/2012 (nd, ). Modified on 8/30/2012 (md). (Entered: 08/30/2012)
57 EXHIBIT 7 to 8 to 54 Response in Opposition to Plaintiffs' Motion for Summary Judgment by ARLENE ACKERMAN, THE SCHOOL DISTRICT OF PHILADELPHIA, THE SCHOOL REFORM COMMISSION, LINDA WILLIAMS. (Attachments: # 1 Exhibit 8)(WANGER, BENJAMIN) Modified on 8/30/2012 (md). (Entered: 08/30/2012)
58 EXHIBIT 9 to 11 to 54 Response in Opposition to Plaintiffs' Motion for Summary Judgment by ARLENE ACKERMAN, THE SCHOOL DISTRICT OF PHILADELPHIA, THE SCHOOL REFORM COMMISSION, LINDA WILLIAMS. (Attachments: # 1 Exhibit 10, # 2 Exhibit 11)(WANGER, BENJAMIN) Modified on 8/30/2012 (nd, ). (Entered: 08/30/2012)
59 EXHIBIT 12 to 14 to 54 Response in Opposition to Plaintiffs' Motion for Summary Judgment by ARLENE ACKERMAN, THE SCHOOL DISTRICT OF PHILADELPHIA, THE SCHOOL REFORM COMMISSION, LINDA WILLIAMS. (Attachments: # 1 Exhibit 13, # 2 Exhibit 14)(WANGER, BENJAMIN) Modified on 8/30/2012 (nd, ). (Entered: 08/30/2012)
60 EXHIBIT 15 to 18 to 54 Response in Opposition to Plaintiffs' Motion for Summary Judgment by ARLENE ACKERMAN, THE SCHOOL DISTRICT OF PHILADELPHIA, THE SCHOOL REFORM COMMISSION, LINDA WILLIAMS. (Attachments: # 1 Exhibit 16, # 2 Exhibit 17, # 3 Exhibit 18)(WANGER, BENJAMIN) Modified on 8/30/2012 (nd, ). (Entered: 08/30/2012)
61 RESPONSE in Support re 48 MOTION to Certify Class Plaintiffs' Motion for Class Certification Reply Memorandum in Further Support of Plaintiffs' Motion for Class Certification filed by J.V., M.M., P.V., R.S.. (Attachments: # 1 Exhibit 34, # 2 Exhibit 35, # 3 Exhibit 36, # 4 Exhibit 37, # 5 Exhibit 38, # 6 Exhibit 39, # 7 Exhibit 40, # 8 Exhibit 41, # 9 Exhibit 42, # 10 Exhibit 43, # 11 Exhibit 44, # 12 Exhibit 45)(STANOCH, DAVID) (Entered: 08/30/2012)
62 Memorandum In Opposition re 49 MOTION for Summary Judgment Plaintiffs' Memorandum of Law in Opposition to Defendants' Motion for Summary Judgment filed by J.V., M.M., P.V., R.S.. (Attachments: # 1 Response to Statement of Material Facts, # 2 Exhibit 41, # 3 Exhibit 42, # 4 Exhibit 43, # 5 Exhibit 44, # 6 Exhibit 45, # 7 Exhibit 46, # 8 Exhibit 47, # 9 Exhibit 48, # 10 Exhibit 49, # 11 Exhibit 50, # 12 Exhibit 51, # 13 Exhibit 52, # 14 Exhibit 53, # 15 Exhibit 54)(STANOCH, DAVID) (Entered: 08/30/2012)
63 REPLY in Further Support of the 49 MOTION for Summary Judgment filed by ARLENE ACKERMAN, THE SCHOOL DISTRICT OF PHILADELPHIA, THE SCHOOL REFORM COMMISSION, LINDA WILLIAMS, Certificate of Service.

Case: 2:11-cv-4027 As of: 10/27/2017 01:25 AM EDT 10 of 14

09/11/2012 09/20/2012
09/27/2012 09/27/2012 10/05/2012 10/09/2012 10/11/2012 10/11/2012 02/19/2013 02/19/2013
02/19/2013

(Attachments: # 1 Exhibit Exhibit 1, # 2 Exhibit Exhibit 2)(WANGER, BENJAMIN) Modified on 9/13/2012 (fh) (Entered: 09/11/2012)
64 Reply Memorandum in Further Support of PLAINTIFFS' 51 MOTION for Summary Judgment filed by J.V., M.M., P.V., R.S., Certificate of Service. (Attachments: # 1 Exhibit 55, # 2 Exhibit 56, # 3 Exhibit 57, # 4 Exhibit 58, # 5 Exhibit 59, # 6 Exhibit 60)(STANOCH, DAVID) Modified on 9/13/2012 (fh) (Entered: 09/11/2012)
65 MOTION for Leave to File Surreply to Plaintiffs' Reply Brief in Support of their Motion for Summary Judgment filed by ARLENE ACKERMAN, THE SCHOOL DISTRICT OF PHILADELPHIA, THE SCHOOL REFORM COMMISSION, LINDA WILLIAMS.Memorandum, Brief, Affidavit, Declaration, Certificate of Counsel or Certificate of Service. (Attachments: # 1 Exhibit Exhibit 1 − Surreply, # 2 Text of Proposed Order Proposed Order)(WANGER, BENJAMIN) (Entered: 09/20/2012)
66 ORDER THAT DEFENDANTS MOTION FOR LEAVE TO FILE A SURREPLY IN OPPOSITION TO PLAINTIFFS MOTION FOR SUMMARY JUDGMENT IS GRANTED; ETC.. SIGNED BY HONORABLE LEGROME D. DAVIS ON 9/27/12. 9/27/12 ENTERED AND E−MAILED.(jl, ) (Main Document 66 replaced on 9/28/2012) (afm, ). (Entered: 09/27/2012)
67 SURREPLY OF DEFENDANTS ARLENE ACKERMAN, THE SCHOOL DISTRICT OF PHILADELPHIA, THE SCHOOL REFORM COMMISSION, LINDA WILLIAMS IN OPPOSITION TO PLAINTIFFS' MOTION FOR SUMMARY JUDGMENT. (jl, ) (Entered: 09/27/2012)
68 NOTICE by ARLENE ACKERMAN, THE SCHOOL DISTRICT OF PHILADELPHIA, THE SCHOOL REFORM COMMISSION, LINDA WILLIAMS re 49 MOTION for Summary Judgment Notice of Supplemental Authority (Attachments: # 1 Supplement)(WANGER, BENJAMIN) (Entered: 10/05/2012)
69 MOTION for Leave to File Plainitiffs' Motion for Leave to File Supplemental Memorandum of Law to Address Defendants' Notice of Supplemental Authority, and in Opposition to Defendants' Motion for Summary Judgment filed by J.V., M.M., P.V., R.S..Certificate of Service. (Attachments: # 1 Exhibit A)(STANOCH, DAVID) (Entered: 10/09/2012)
70 ORDER THAT PLAINTIFFS MOTION FOR LEAVE TO FILE SUPPLEMENTAL MEMORANDUM OF LAW TO ADDRESS DEFENDANTS NOTICE OF SUPPLEMENTAL AUTHORITY IS GRANTED; ETC.. SIGNED BY HONORABLE LEGROME D. DAVIS ON 10/9/12. 10/11/12 ENTERED AND E−MAILED.(jl, ) (Entered: 10/11/2012)
71 PLAINTIFFS' SUPPLEMENTAL MEMORANDUM OF LAW TO ADDRESS DEFENDANTS NOTICE SUPPLEMENTAL AUTHORITY AND IN OPPOSITION TO DEFENDANTS MOTION FOR SUMMARY JUDGMENT, CERTIFICATE OF SERVICE. (jl, ) (Entered: 10/11/2012)
72 MEMORANDUM AND ORDER THAT PLAINTIFFS MOTION FOR CLASS CERTIFICATION IS GRANTED; ETC.. SIGNED BY HONORABLE LEGROME D. DAVIS ON 2/19/13. 2/19/13 ENTERED AND E−MAILED.(jl, ) (Entered: 02/19/2013)
73 ORDER THAT PLAINTIFF'S MOTION FOR CLASS CERTIFICATION IS GRANTED. THIS ACTION IS CERTIFIED AS A CLASS ACTION PURSUANT TO FEDERAL RULE OF CIVIL PROCEDURE 23 (a) AND 23 (b)(2). THE PUBLIC INTEREST LAW CENTER OF PHILADELPHIA AND DECHERT LLP ARE APPOINTED AS CLASS COUNSEL; ETC.. SIGNED BY HONORABLE LEGROME D. DAVIS ON 2/19/13. 2/19/13 ENTERED AND E−MAILED.(jl, ) (Entered: 02/19/2013)
74 MEMORANDUM AND ORDER THAT DEFENDANTS MOTION FOR SUMMARY JUDGMENT IS GRANTED IN PART AND DENIED IN PART. PLAINTIFF'S MOTION FOR SUMMARY JUDGMENT IS GRANTED IN PART AND DENIED IN PART; ETC.. SIGNED BY HONORABLE LEGROME D. DAVIS ON 2/19/13. 2/19/13 ENTERED AND E−MAILED.(jl, ) (Entered: 02/19/2013)

Case: 2:11-cv-4027 As of: 10/27/2017 01:25 AM EDT 11 of 14

02/19/2013
02/27/2013 03/01/2013 03/06/2013 03/13/2013 03/15/2013 03/18/2013
03/20/2013 03/21/2013
03/21/2013 03/25/2013 04/18/2013 04/19/2013 04/25/2013

75 ORDER THAT DEFENDANTS MOTION FOR SUMMARY JUDGMENT IS GRANTED IN PART AND DENIED IN PART. PLAINTIFF'S MOTION FOR SUMMARY JUDGMENT IS GRANTED IN PART AND DENIED IN PART. THE CLERK OF COURT IS DIRECTED TO CLOSE THIS MATTER FOR STATISTICAL PURPOSES; ETC. SIGNED BY HONORABLE LEGROME D. DAVIS ON 2/19/13. 2/19/13 ENTERED AND E−MAILED.(jl, ) (Entered: 02/19/2013)
76 MOTION for Reconsideration re 75 Order (Memorandum and/or Opinion), filed by THE SCHOOL DISTRICT OF PHILADELPHIA.Memorandum, Certificate of Service. (Attachments: # 1 Text of Proposed Order, # 2 Exhibit A, # 3 Exhibit B)(WANGER, BENJAMIN) (Entered: 02/27/2013)
77 MOTION for Extension of Time to File Motion For Attorney's Fees and Costs filed by J.V., M.M., P.V., R.S..Motion and Memorandum.(WOODRING, DARLA) (Entered: 03/01/2013)
78 ORDER THAT PLAINTIFFS UNOPPOSED MOTION TO EXTEND TIME TO MOVE FOR ATTORNEY'S FEES AND COSTS IS GRANTED; ETC.. SIGNED BY HONORABLE LEGROME D. DAVIS ON 3/6/13.3/6/13 ENTERED AND E−MAILED.(jl, ) (Entered: 03/06/2013)
79 RESPONSE in Opposition re 76 MOTION for Reconsideration re 75 Order (Memorandum and/or Opinion), filed by J.V., M.M., P.V., R.S.. (Attachments: # 1 Exhibit 1, # 2 Exhibit 2)(WOODRING, DARLA) (Entered: 03/13/2013)
80 SUGGESTION OF DEATH Upon the Record as to Arlene Ackerman by THE SCHOOL DISTRICT OF PHILADELPHIA, THE SCHOOL REFORM COMMISSION, LINDA WILLIAMS. (WANGER, BENJAMIN) (Entered: 03/15/2013)
81 ORDER THAT COUNSEL SHALL APPEAR AT 2:00 P.M. ON 4/16/13 FOR ORAL ARGUMENT ON THE SCHOOL DISTRICT OF PHILADELPHIA'S OUTSTANDING MOTION FOR RECONSIDERATION; ETC.. SIGNED BY HONORABLE LEGROME D. DAVIS ON 3/18/13. 3/18/13 ENTERED AND E−MAILED.(jl, ) (Entered: 03/18/2013)
82 MOTION for Leave to File Reply Brief in Support of Motion for Reconsideration filed by ARLENE ACKERMAN, THE SCHOOL DISTRICT OF PHILADELPHIA, THE SCHOOL REFORM COMMISSION, LINDA WILLIAMS.Certificate of Service.(WANGER, BENJAMIN) (Entered: 03/20/2013)
83 ORDER THAT DEFENDANT'S UNOPPOSED MOTION FOR LEAVE TO FILE A REPLY BRIEF IN SUPPORT OF ITS MOTION FOR RECONSIDERATION AND TO ALTER OR AMENDED JUDDGMENT IS GRANTED. DEFENDANT MUST FILE ITS REPLY BRIEF ON OR BEFORE 3/25/13; ETC.. SIGNED BY HONORABLE LEGROME D. DAVIS ON 3/20/13. 3/21/13 ENTERED AND E−MAILED.(jl, ) (Entered: 03/21/2013)
Set/Reset Deadlines as to 76 MOTION for Reconsideration re 75 Order (Memorandum and/or Opinion), . REPLIES DUE BY 3/25/2013. (md) (Entered: 03/22/2013)
84 REPLY Brief in Support re 76 MOTION for Reconsideration re 75 Order (Memorandum and/or Opinion), filed by THE SCHOOL DISTRICT OF PHILADELPHIA. (WANGER, BENJAMIN) Modified on 3/26/2013 (lisad, ). (Entered: 03/25/2013)
85 Minute Entry for proceedings held before HONORABLE LEGROME D. DAVIS: Motion Hearing held on 4/16/13 re 76 MOTION for Reconsideration re 75 Order (Memorandum and/or Opinion), filed by THE SCHOOL DISTRICT OF PHILADELPHIA Court Reporter: DONNA CROCE. (jl, ) (Entered: 04/18/2013)
86 NOTICE of Withdrawal of Appearance by DANIEL G. BOWERS on behalf of J.V., M.M., P.V., R.S.(BOWERS, DANIEL) (Entered: 04/19/2013)
87 TRANSCRIPT of Proceedings held on 4/16/13 before Judge DAVIS. Court Reporter: DONNA CROCE. ORAL ARGUMENT (jl, ) (Entered: 04/25/2013)

Case: 2:11-cv-4027 As of: 10/27/2017 01:25 AM EDT 12 of 14

05/02/2013
05/13/2013 05/22/2013 05/23/2013
05/23/2013 05/29/2013 06/03/2013 06/07/2013
06/27/2013 08/01/2013 08/07/2013 08/12/2013 08/14/2013

88 ORDER THAT THE SCHOOL DISTRICT LETTER REQUESTING AN EXTENSION OF TIME IS GRANTED. ACCORDINGLY, THE PARTIES SHALL, IN WRITING, UPDATE THIS COURT AS TO THE STATUS OF THE PARTIES EFFORTS TO REACH AN AGREEMENT ON THE ISSUES IN THIS LITIGATION NO LATER THAN 6/5/13; ETC.. SIGNED BY HONORABLE LEGROME D. DAVIS ON 5/1/13. 5/2/13 ENTERED AND E−MAILED.(jl, ) (Entered: 05/02/2013)
89 NOTICE by ARLENE ACKERMAN, THE SCHOOL DISTRICT OF PHILADELPHIA, THE SCHOOL REFORM COMMISSION, LINDA WILLIAMS re 76 MOTION for Reconsideration re 75 Order (Memorandum and/or Opinion), of Supplemental Authority (SMITH, DAVID) (Entered: 05/13/2013)
90 MOTION for Leave to File Memorandum of Law filed by J.V., M.M., P.V., R.S..Motion for Leave to File Supplemental Memorandum of Law. (Attachments: # 1 Exhibit A (Memorandum of Law))(WOODRING, DARLA) (Entered: 05/22/2013)
91 ORDER THAT PLAINTIFFS MOTION FOR LEAVE TO FILE A SUPPLEMENTAL MEMORANDUM OF LAW IS GRANTED. THE CLERK OF COURT IS DIRECTED TO FILE PLAINTIFFS SUPPLEMENTAL MEMORANDUM (DOC. 90−1) AS A REPLY BRIEF IN THIS CASE.. SIGNED BY HONORABLE LEGROME D. DAVIS ON 5/23/13. 5/23/13 ENTERED AND COPIES EMAILED.(rf, ) (Entered: 05/23/2013)
92 PLAINTIFFS SUPPLEMENTAL MEMORANDUM OF LAW IN RESPONSETO DEFENDANTS NOTICE OF SUPPLEMENTAL AUTHORITY IN SUPPORTOF DEFENDANTS OF MOTION FOR RECONSIDERATION, CERTIFICATE OF SERVICE(rf, ) (Entered: 05/23/2013)
93 REPLY to Response to Motion re 90 MOTION for Leave to File Memorandum of Law filed by THE SCHOOL DISTRICT OF PHILADELPHIA. (Attachments: # 1 Exhibit A −− Reply Brief)(WANGER, BENJAMIN) (Entered: 05/29/2013)
94 AMENDED TRANSCRIPT of Proceedings held on 4/16/13 before Judge DAVIS. Court Reporter: DONNA CROCE. ORAL ARGUMENT (jl, ) (Entered: 06/03/2013)
95 ORDER THAT PLAINTIFF'S LETTER REQUESTING AN ADDITIONAL THREE WEEKS FOR THE PARTIES TO RESUME THEIR EFFORTS TO RESOLVE THIS MATTER IS GRANTED. THE PARTIES SHALL, IN WRITING, UPDATE THIS COURT AS TO THE STATUS OF THE PARTIES EFFORTS TO REACH AN AGREEMENT OF THE ISSUES IN THIS LITIGATION NO LATER THAN 6/26/13; ETC.. SIGNED BY HONORABLE LEGROME D. DAVIS ON 6/6/13. 6/7/13 ENTERED AND E−MAILED.(jl, ) (Entered: 06/07/2013)
96 ORDER THAT THE PARTIES SHALL, IN WRITING, UPDATE THIS COURT AS TO THE STATUS OF THE PARTIES EFFORTS TO REACH AN AGREEMENT ON THE ISSUES IN THIS LITIGATION NO LATER THAN 7/26/13; ETC.. SIGNED BY HONORABLE LEGROME D. DAVIS ON 6/27/13. 6/27/13 ENTERED AND E−MAILED.(jl, ) (Entered: 06/27/2013)
97 ORDER THAT A SETTLEMENT CONFERENCE IS SCHEDULED FOR 8/14/13 AT 9:30 A.M.; ETC.. SIGNED BY HONORABLE LEGROME D. DAVIS ON 8/1/13. 8/1/13 ENTERED AND E−MAILED.(jl, ) (Entered: 08/01/2013)
98 ORDER THAT THE SETTLEMENT CONFERENCE IS RESCHEDULED FOR 8/9/13 AT 9:30 A.M.. THE DOCUMENTS PREVIOUSLY DUE ON 8/9/13, ARE DUE NO LATER THAN 8/8/13 AT 5:00 P.M.; ETC.. SIGNED BY HONORABLE LEGROME D. DAVIS ON 8/7/13. 8/7/13 ENTERED AND E−MAILED.(jl, ) (Entered: 08/07/2013)
99 Minute Entry for proceedings held before HONORABLE LEGROME D. DAVIS: Settlement Conference held on 8/9/2013. (jmg, ) (Entered: 08/12/2013)
100 ORDER THAT THE CLERK OF COURT IS HEREBY DIRECTED TO RE−OPEN THIS MATTER TO PERMIT DETERMINATION OF THE APPROPRIATE AND SPECIFIC CONTOURS OF INJUNCTIVE RELIEF IN THIS MATTER; ETC.. SIGNED BY HONORABLE LEGROME D. DAVIS ON 8/14/13. 8/14/13 ENTERED AND E−MAILED.(jl, ) (Entered: 08/14/2013)

Case: 2:11-cv-4027 As of: 10/27/2017 01:25 AM EDT 13 of 14

08/14/2013 08/14/2013
08/23/2013 08/26/2013
10/21/2013
11/15/2013
12/11/2013 12/31/2013
01/15/2014 02/21/2014 03/04/2014 03/27/2014 03/31/2014 03/31/2014

101 ORDER THAT DEFENDANTS MOTION FOR RECONSIDERATION IS DENIED; ETC.. SIGNED BY HONORABLE LEGROME D. DAVIS ON 8/14/13. 8/14/13 ENTERED AND E−MAILED.(jl, ) (Entered: 08/14/2013)
102 ORDER THAT ON OR BEFORE 10/15/13, THE PARTIES SHALL PROVIDE TO THIS COURT IN WRITING A STATUS UPDATE, INDICATING WHETHER THE PARTIES HAVE REACHED A SETTLEMENT IN THIS CASE; ETC.. SIGNED BY HONORABLE LEGROME D. DAVIS ON 8/14/13. 8/14/13 ENTERED AND E−MAILED.(jl, ) (Entered: 08/14/2013)
103 MOTION for Extension of Time to File Motion for Attorney's Fees and Costs filed by J.V., M.M., P.V., R.S..Memorandum.(WOODRING, DARLA) (Entered: 08/23/2013)
104 ORDER THAT PLAINTIFFS' UNOPPOSED MOTION TO EXTEND TIME TO MOVE FOR ATTORNEY'S FEES AND COSTS(DOC. NO. 103) IS GRANTED. OTHER INSTRUCTIONS ARE AS OUTLINED HEREIN. SIGNED BY HONORABLE LEGROME D. DAVIS ON 8/26/2013.8/26/2013 ENTERED AND COPIES E−MAILED.(jmg, ) (Entered: 08/26/2013)
105 ORDER THAT ON OR BEFORE 11/14/13, THE PARTIES SHALL INFORM THE COURT IN WRITING WHETHER THE PARTIES HAVE REACHED A SETTLEMENT IN THIS CASE; ETC.. SIGNED BY HONORABLE LEGROME D. DAVIS ON 10/18/13. 10/21/13 ENTERED AND E−MAILED.(jl, ) (Entered: 10/21/2013)
106 ORDERED THAT THE CLERK SHALL REFER THIS MATTER TO THE HONORABLE TIMOTHY RICE, UNITED STATES MAGISTRATE JUDGE, FOR A SETTLEMENT CONFERENCE; ETC.. SIGNED BY HONORABLE LEGROME D. DAVIS ON 11/15/13. 11/15/13 ENTERED AND E−MAILED.(jl, ) (Entered: 11/15/2013)
107 NOTICE of Hearing: SETTLEMENT CONFERENCE SET FOR 12/30/2013 AT 1:30 P.M., IN JUDGE'S CHAMBERS BEFORE MAGISTRATE JUDGE TIMOTHY R. RICE.(cms) (Entered: 12/11/2013)
108 ORDER DISMISSING ACTION WITH PREJUDICE PURSUANT TO LOCAL RULE 41.1(b). THIS COURT SHALL RETAIN JURISDICTION OVER THIS MATTER THROUGH MONDAY, JANUARY 2, 2017, FOR PURPOSES OF ENFORCING THE SETTLEMENT AGREEMENT. THIS MATTER SHALL CONTINUE TO BE REFERRED TO THE HONORABLE TIMOTHY R. RICE, UNITED STATES MAGISTRATE JUDGE. THE CLERK OF COURT SHALL MARK THIS MATTER CLOSED FOR STATISTICAL PURPOSES. SIGNED BY HONORABLE LEGROME D. DAVIS ON 12/31/2013. 12/31/2013 ENTERED AND COPIES E−MAILED. (miah, ) (VACATED PER ORDER 116 ) (Entered: 12/31/2013)
109 NOTICE of Hearing: SETTLEMENT CONFERENCE RESET FOR 1/27/2014 AT 9:30 A.M., IN JUDGE'S CHAMBERS BEFORE MAGISTRATE JUDGE TIMOTHY R. RICE.(cms) (Entered: 01/15/2014)
110 NOTICE of Hearing: SETTLEMENT CONFERENCE RESET FOR 2/28/2014 AT 1:30 P.M., IN JUDGE'S CHAMBERS BEFORE MAGISTRATE JUDGE TIMOTHY R. RICE.(cms) (Entered: 02/21/2014)
111 Minute Entry for proceedings held before MAGISTRATE JUDGE TIMOTHY R. RICE: Settlement Conference held on 2/28/14. (jl, ) (Entered: 03/04/2014)
112 Joint MOTION to Vacate 108 Order Dismissing Case − 41(b), filed by THE SCHOOL DISTRICT OF PHILADELPHIA.Memorandum, Brief, Affidavit, Declaration, Certificate of Counsel or Certificate of Service.(WANGER, BENJAMIN) Modified on 4/3/2014 (afm, ). (Entered: 03/27/2014)
Set/Reset Scheduling Order Deadlines: MOTIONS DUE BY 4/14/2014. (jl, ) (Entered: 03/31/2014)
113 ORDER THAT, ON OR BEFORE 4/14/14, THE PARTIES SHALL EITHER (A) SUBMIT THEIR PROPOSED SETTLEMENT AGREEMENT AND MOTION FOR PRELIMINARY APPROVAL, OR (B)JOINTLY ADVISE THE COURT IN

Case: 2:11-cv-4027 As of: 10/27/2017 01:25 AM EDT 14 of 14

04/15/2014 05/06/2014 05/06/2014 05/12/2014
05/28/2014
06/03/2014 06/03/2014 06/03/2014 06/04/2014
07/10/2014

WRITING OF THE STATUS OF THIS MATTER; ETC.. SIGNED BY HONORABLE LEGROME D. DAVIS ON 3/31/14. 3/31/14 ENTERED AND E−MAILED.(jl, ) (Entered: 03/31/2014)
114 Joint MOTION for Settlement Approval filed by J.V., M.M., P.V., R.S..Memorandum. (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C)(WOODRING, DARLA) (Entered: 04/15/2014)
Set/Reset Hearings: MISCELLANEOUS HEARING SET FOR 6/3/2014 09:30 AM BEFORE HONORABLE LEGROME D. DAVIS. (jl, ) (Entered: 05/06/2014)
115 ORDER THAT THE PARTIES JOINT MOTION FOR PRELIMINARY APPROVAL OF SETTLEMENT AGREEMENT IS APPROVED. A HEARING TO DETERMINE IF THE SETTLEMENT AGREEMENT IS FAIR REASONABLE AND ADEQUATE SHALL BE HELD ON 6/3/14 AT 9:30 A.M.; ETC.. SIGNED BY HONORABLE LEGROME D. DAVIS ON 5/6/14. 5/6/14 ENTERED AND E−MAILED.(jl, ) (Entered: 05/06/2014)
116 ORDER THAT UPON CONSIDERATION OF THE PARTIES' JOINT MOTION TO VACATE DISMISSAL TO CONSIDER CLASS SETTLEMENT 112 , IT IS HEREBY ORDERED THAT THE MOTION IS GRANTED. ACCORDINGLY, IT IS FURTHER ORDERED THAT THE CLERK OF COURT'S ORDER DATED 12/31/2013 108 IS VACATED. SIGNED BY HONORABLE LEGROME D. DAVIS ON 5/12/14.5/12/14 ENTERED AND COPIES E−MAILED.(ti, ) (Entered: 05/12/2014)
117 ORDER AND NOTICE THAT THE COURT HAVING RECEIVED PLAINTIFFS REQUEST FOR GUIDANCE AS TO WHETHER THE COURT ANTICIPATES BRIEF STATEMENTS FROM THE ATTORNEYS AND CLASS MEMBERS OR PREFERS THE PARTIES TO ELICIT FORMAL TESTIMONY FROM CLASS MEMBER WITNESS AT THE FAIRNESS HEARING SCHEDULED FOR 6/3/14. WE EXPECT THAT BRIEF STATEMENTS WILL BE SUFFICIENT. THE COURT WILL ALSO HEAR ANY TESTIMONY THAT COUNSEL WITH TO PRESENT. WE LEAVE THE DECISION OF HOW TO PROCEED TO COUNSEL'S PROFESSIONAL JUDGMENT; ETC.. SIGNED BY HONORABLE LEGROME D. DAVIS ON 5/28/14. 5/28/14 ENTERED AND E−MAILED.(jl, ) (Entered: 05/28/2014)
118 Declaration of Benjamin Wanger re Compliance with Terms of Settlement Agreement by ARLENE ACKERMAN, THE SCHOOL DISTRICT OF PHILADELPHIA, THE SCHOOL REFORM COMMISSION, LINDA WILLIAMS. (WANGER, BENJAMIN) (Entered: 06/03/2014)
119 EXHIBIT 1−4 by J.V., M.M., P.V., R.S... (Attachments: # 1 Exhibit 2 from 6/3/14 fairness hearing, # 2 Exhibit 3 from 6/3/14 fairness hearing, # 3 Exhibit 4 from 6/3/14 fairness hearing)(WOODRING, DARLA) (Entered: 06/03/2014)
120 Minute Entry for proceedings held before HONORABLE LEGROME D. DAVIS: HEARING TO DETERMINE IF THE SETTLEMENT AGREEMENT IS FAIR, REASONABLE AND ADEQUATE held on 6/3/14. Court Reporter: DONNA CROCE. (jl, ) (Entered: 06/03/2014)
121 ORDER THAT THE PROPOSED SETTLEMENT, SET FORTH IN THE PARTIES SETTLEMENT AGREEMENT IS APPROVED. THE COURT ALSO FINDS THAT THE PROPOSED PAYMENT OF $325,000 IN ATTORNEYS FEES AND EXPENSES TO PLAINTIFFS IS REASONABLE AND APPROPRIATE. PLAINTIFFS CLAIMS ARE DISMISSED WITH PREJUDICE. THE CLERK OF COURT SHALL MARK THIS MATTER CLOSED FOR STATISTICAL PURPOSES; ETC.. SIGNED BY HONORABLE LEGROME D. DAVIS ON 6/3/14. 6/4/14 ENTERED AND E−MAILED.(jl, ) (Entered: 06/04/2014)
122 TRANSCRIPT of Proceedings held on 6/3/14 before Judge DAVIS. Court Reporter: DONNA CROCE. SETTLEMENT AGREEMENT HEARING (jl, ) (Entered: 07/10/2014)


[CONTENT] June 20, 2011 | Philadelphia | the School District of Philadelphia | the U.S. District Court | the Eastern District | Pennsylvania | the Individuals with Disabilities Education Act | IDEA | the Rehabilitation Act | American | ADA ||| the Public Interest Law Center | Philadelphia | IDEA | ADA |||  ||| October 31, 2011 | the District Court | Legrome D. Davis ||| P.V. ||| Valentin v. Sch ||| Philadelphia | 2011 WL 5127850 | E.D. Pa. ||| Oct. 31, 2011 ||| February 19, 2013 | Davis ||| P.V. ||| Valentin v. Sch ||| Philadelphia | 2013 | 618540 | E.D. Pa. ||| Feb. 19, 2013 ||| Court | IDEA | Section 504 | ADA ||| Court | IDEA ||| Court ||| P.V. ||| Valentin v. Sch ||| Philadelphia | 289 | 228 | E.D. Pa. 2013 ||| the School District of Philadelphia | eight | the School District's ||| May 2013 ||| April 15, 2014 ||| 1 | two | 2 | 3 | Jan. 2, 2017 ||| 325,000 ||| June 4, 2014 ||| 2017 |||  [SUMMARY] On June 20, 2011, Philadelphia school children with autism filed a class action lawsuit against the School District of Philadelphia in the U.S. District Court for the Eastern District of Pennsylvania, under the Individuals with Disabilities Education Act (IDEA), the Rehabilitation Act (Section 504), the American with Disabilities Act (ADA) and relevant state law. The plaintiffs, represented by attorneys from the Public Interest Law Center of Philadelphia and private counsel, sought declaratory and injunctive relief, alleging that the District's Automatic Autism Transfer Policy was illegal under the IDEA, Section 504 and the ADA. The challenged policy routinely transferred students with autism from school to school at a certain age solely because they were disabled as a result of autism.

On October 31, 2011, the District Court (Judge Legrome D. Davis) denied the defendant's motion to strike class action allegations and motion to dismiss the suit. P.V. ex rel. Valentin v. Sch. Dist. of Philadelphia, 2011 WL 5127850 (E.D. Pa. Oct. 31, 2011). 

On February 19, 2013, Judge Davis granted the plaintiffs' motion for summary judgment in part and denied it in part and granted the defendant's motion for summary judgment in part and denied in part. P.V. ex rel. Valentin v. Sch. Dist. of Philadelphia, 2013 WL 618540 (E.D. Pa. Feb. 19, 2013). The Court concluded that the policy violated the IDEA, but that it did not violate Section 504 or the ADA. The Court ordered the school district to alter its policy to meet the procedural requirements under the IDEA and provide parents the opportunity to participate in the decision-making process regarding the educational placement of their autistic children. 

In addition, the Court granted the plaintiffs' motion for class certification. P.V. ex rel. Valentin v. Sch. Dist. of Philadelphia, 289 F.R.D. 227, 228 (E.D. Pa. 2013). The class included all children with autism in the School District of Philadelphia in grades Kindergarten through eight who had been transferred, were in the process of being transferred, or were at risk of being transferred, as a result of the School District's upper-leveling process; the parents and guardians of those children; and future members of the class. 

The parties entered into settlement negotiations in May 2013. The parties filed their preliminary settlement agreement on April 15, 2014. The proposed class settlement:
(1) required the district to publish a list of all of its schools with autistic-support classrooms and provide notice of these schools in two separate letters to the parents of children with autism, 
(2) allowed class members to retain their individual rights to challenge the circumstances of their particular transfers, and 
(3) provided for the court to retain jurisdiction over the agreement's settlement through Jan. 2, 2017, though the agreement was to remain enforceable after this time. 
The parties also agreed to $325,000 in attorneys’ fees and costs. The court granted final approval of the agreement on June 4, 2014. 

The settlement ended in 2017 without any further litigation. The case is now closed. 