..
DECLARATION OF DR. ALAN L. BERMAN
FILED WITH THE FRANKLIN COUNTY SUPERIOR COURT
June 2002

(As part of our lawsuit against the Pasco School District, it had to be proven, or argued, that Jared became depressed as a result of bullying and an assault by another student at McLoughlin Middle School.  Dr. Berman was retained and paid to give his professional opinion to support our case.  Bold print and underlining is emphasized by my, Brenda High's initiative.  Below is his report.)

Alan L. Berman hereby declares, under penalty of perjury, as follows:

"My professional practice and study has focused on the subject of suicide for at least 25 years.  Throughout that time, I have been particularly interested in the causes and prevention of adolescent suicide, including suicides of young people in Jared High's age range.  I have testified in trials and depositions throughout the United States, in both state and federal courts, as an expert in suicide.  A frequent task for me in such cases is to form an expert opinion on the causal relationship between a given event and an individual's suicide, and I have testified as an expert on that subject on numerous occasions.  A substantial portion of my time is and has for years been working clinically with suicidal patients, including young people and adolescents.

"...I have received and have reviewed at least the following materials:

1.   Family video clips, ...audio recording of the interview he (Jared) gave to the school district's claim investigator...
2.   State of Washington Uniform Incident Report concerning the assault on Jared High, May 6, 1998.
3.   Notebook of Pasco Public School District's Answers to... Interrogatories...
      school records and a transcript of the above recorded interview.
4.   Notebooks of Plaintiffs' Answers ...interrogatories ...records ...material from McLoughlin...
5.   Deposition... chiropractor... medical chart...
6.   Deposition ...vice principals ...teachers.
7.   Deposition ...vice principal who disciplined both Jared High and his assailant, A.S. (A.S. = The Bully)
8.   Deposition of A.S.
9.   Records of C.H., who counseled A.S. at various times, starting in 1991.
10.  Excerpts of A.S. ...medical records, ...showing that he was 65 inches and weighed 177 pounds, at 14 years of age.
11.  Deposition of ...Jared's older brother.
12.  Deposition of Jared's mother...
13.  Deposition of Jared's father...
14.  The police report of Jared High's death...
15.  Transcript of ...former expert witness
16.  Written statements by Jared's older sister, ... and his grandmother...
17.  The HMS student weekly progress report ...less than two weeks before his death.
18.  A note (on an) arithmetic test sheet addressed to Jared's counselor at HMS... from the HMS math teacher...

"I have interviewed Jared High's parents, older sister, ...adult leader of Jared's Boy Scout Troop... ...Jared's schoolmates... ...medical doctor, father of a girl Jared was rumored to have some sort of relationship with at HMS briefly before his death....

"...The following are my professional opinions, within a reasonable degree of psychological certainty, based upon my training, education, experience and study of the psychology of suicide and my investigations in this case:

"Jared High did not exhibit the symptoms of clinical depression prior to the May 6, 1998 incident with Andrew S. at McLoughlin Middle School and its subsequent disciplinary aftermath.  In the weeks and months following, however, Jared High developed the symptoms of a major depressive episode.  By the nature of the diagnosis, a major depressive episode develops over time.  By September, 1998, Jared High had a diagnosable condition of clinical depression.  In my opinion, the May 6, 1998 physical altercation at the hands of Andrew S. and the subsequent discipline of Jared High by McLoughlin Middle School Vice Principal L.A. are significant causal factors in the development of that depression, such that it is unlikely that Jared would have developed that depression and the impulse to commit suicide if those events had not occurred.

"It is my professional opinion that Jared High's state of mind at the time of his suicide was distorted and irrational, that his thinking at the time was characterized by feelings of hopelessness and 'tunnel vision' such that he could see no alternatives.  Such feelings and thoughts are a direct result of processes over which Jared High had no volitional control, based in both the biological and psychological roots of his depression.  Because of these factors, Jared High was unable to resist the impulse to end his suffering through suicide.

"It is further my opinion that clinical depression and suicide are a forseeable consequences of a school district's failure to constrain a known bully from victimizing other students. This is not just my opinion, but is a view widely held among those who study suicide, based upon repeated scientific studies.  Some of the more well-known studies are:

Kaltiala-Heino, R., Rimpela, M. et al. (1999). Bullying, depression, and suicide ideation in Finnish adolescents: School survey. British Medical Journal , 319 (7206), 348-351.

National School Safety Center (1995). School bullying and victimization: NSSC Resource Paper (7th Printing). (31 pp).

Batsche, G M. & Knoff, H. M. (1994). Bullies and their victims: Understanding a pervasive problem in the schools. School Psychology Review, 23 (2). 165-174.

Harvard Education Letter (1987, November). Bullies and their victims, 3 (6), 1-3.

"At my deposition, I provided defense counsel with thirty-four pages of information, including abstracts of journal articles and bibliographies of other articles, about the relationship between bullying, depression and suicide.  Bullying is a professionally discussed problem and an issue of professional import for schools around the world, including the United States.  The rates of bullying are remarkably consistent around the world.  Bullies and their victims display significantly more psychiatric symptoms than other children.  Bullying has been shown to cause victims to become emotionally distressed and, in particular, to develop clinical depression.  Clinical depression is one of the greatest risk factor for suicide among all age groups, and particularly so for youths and adolescents.  Bullied students are 5 times more likely to develop depression than students who have not been so victimized, according to a study in England published in 1998.   A 1999 Finnish study showed bullied students were at increased risk for depression and suicide, with victims four times more likely than non-victims to become depressed and twice as likely to develop severe suicidal ideation.  These studies go back at least to 1987."

Dr. Alan L. Berman is a Clinical Psychologist, practicing in Washington D.C.
 

HEAR JARED'S VOICE - PLAY - From an interview with Pasco School District investigators concerning the assault.  This is a recording of a recording and it isn't real clear, but worth the download effort.  Jared had a real mellow voice.   Note: If you have a slow load wav, wait for it to load entirely and then play again from the start.   5 minutes long

TRIAL ISSUES
http://www.jaredstory.com/trial_brief01.html
http://www.jaredstory.com/trial_brief02.html
http://www.jaredstory.com/trial_brief03.html
http://www.jaredstory.com/trial_brief04.html
http://www.jaredstory.com/trial_brief06.html
http://www.jaredstory.com/trial_brief08.html
http://www.jaredstory.com/trial_brief09.html
http://www.jaredstory.com/trial_brief10.html
http://www.jaredstory.com/trial_brief11.html

 

HIGH v. PASCO SCHOOL DISTRICT
The Lawsuit

PLAINTIFFS' TRIAL BRIEF & FACTUAL BACKGROUND
The Complaint for Damages
THE SETTLEMENT
The Rest of the Story
The Assault
Suicide - The Forseeable Consequences of Bullying
Why the Pasco School District wouldn't help Jared

Court Case about Videos on a bus & bullying

 

 

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Check out: The National Center of Victims of Crime - www.ncvc.org or call 1-800-394-2255

 

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