Medical Affidavits and Expert Opinions on Sri Nithyananda Swami's Medical Condition
| Reference number | UAN-LEGAL-MedicalExper-MedicalAffidavit-20150000-1 |
|---|---|
| Title | Medical Affidavits and Expert Opinions on Sri Nithyananda Swami's Medical Condition |
| Type of record | Affidavit |
| Collection | Legal Records |
| Issued or submitted to | Nine individual physicians (Richard Sokolov M.D., Mark W. Vogel M.D., Robert Di Loreto M.D., Michael A. McIlroy M.D., Umakant Khetan M.D., Gerald Brock M.D., K. Ravindran Nair M.D., and Bradford T. Black M.D.) |
| Author of the record | Richard Sokolov M.D.; Mark W. Vogel M.D.; Robert Di Loreto M.D.; Michael A. McIlroy M.D.; Umakant Khetan M.D.; Gerald Brock M.D.; K. Ravindran Nair M.D.; Bradford T. Black M.D. |
| Date | 2015 — Latest affidavit dated January 2015; document compilation spans 2013–2015 |
| Language | English |
| Extent of the transcription | 6,944 words |
| Provenance | The document as filed is the record. It is reproduced on this page, and the text below it is a transcription of it, published so that the record can be searched, quoted and read by machine. The transcription was read from the document by optical character recognition and is published as the machine read it, with no editorial correction and no correction by any language model. Read it against the document before quoting it. Read the document. |
- Medical expert opinions on physical examination findings and laboratory test results from hospitals in India
- Analysis of hormone levels, vascular function, and sexually transmitted disease status based on medical records
- Comparison of medical findings between two individuals involved in a legal matter.
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The transcription of this record is withheld from print. The full text is published at https://docs.unitedancientnations.org/legal/bnzlkdileeajcueqcdkhvbexvndj. For a certified copy of the document as filed, write to [email protected], quoting reference UAN-LEGAL-MedicalExper-MedicalAffidavit-20150000-1.
AFFIDAVIT OF RICHARD SOKOLOV, M.D. 1 2 STATE OF CALIFORNIA ) ) ss. 3 ) COUNTY OF LOS ANGELES 4 5 1, RICHARD SOKOLOV M. D., being first duly sworn, deposes and states that: 6 I am over the age of 18 years and am a resident of the State of California. 1. 7 I have personal knowledge of the facts set forth below, and if called upon, could and 2. 8 would competently testify to the facts set forth herein. 9 IhavehospitalaffliationswithCedars-SinaiMedicalCenterinBeverlyHills, 3. 10 California. Attached hereto as Exhibit "A" is a true and correct copy of my Curriculum Vitae. 11 I am an Internal Medicine and Infectious Diseases physician in Los Angeles County 4. 12 since1984andhavehadmyommprivatepracticeinConsulrativeInfectiousDiseaseformorethan 13 25 years. 14 IamBoardCertifiedbytheAmericanBoardofInternalMedicinesince1988. 5. 15 IamBoardCertitiedbytheAmericanBoardofInfectiousDiseasesince1990. 6. 16 AttachedheretoasExhibit"B"isatrueandcorrectcopyoftheVictoriaHospital 7. 17 ntda Swami ("Swamiji"). medical records of Sri Nithyanande 18 Attached hereto as Exhibit "C" is a true and correct copy of the allegations of Aarthi 8. 19 Rao("TRao"),underthealias"Amla",intheIndiancriminalcaseCRNo:141/2010and142/2010. 20 I have had an oppprtanity to review the medical records of Rao from the University 9. 21 of Michigan Health System. Attached herero as Exhibit "D" is a true and correct copy of University 22 of Michigan Medical Records of Mrs. Aarthi Rao. 23 Rao alleges, in Exhibit C, that she came in skin-to-skin physical contacr with Swamiji 10. 24 on a number of occasions. 25 Based upon my training, knowledge, and experience, my opinion is as follows below: 11. 26 Mrs.Rao'smedicalrecordsinExhibitDrevealthat,sinceatleast2004,shewas 12. 27 infectedwithatleastfourhighiyinfecioussexuallytransmitteddiseases(her"Condition"):; 28 1 AFFIDAVIT OF RICHARD SOKOLOV, M.D. Exhibit E SD:0I 9T03/9/90 9600 TO 390d
HerpesSimplexVirusI(morecommonlyknownas"oralherpes") 1. 1 Herpes Simplex Virus II (more commonly known as "genital herpes") 2. 2 Recurrent Genital Herpes 3. 3 Herpes Gladiatorum. 4. 4 Any skin-to-skin contact with Mrs. Rao orally or by sexual intercourse would place one at risk for 5 the spread of her Condition. 6 ThemedicalreportsofSwamijifromVictoriaHospitalinExhibitB,ontheother 13, 7 hand, reveals that Sri Nithyananda Swami does not have any sexually transmitted diseases. 8 Rao'sConditionislifelongandchronic.ThereisnoknowncurefortheHerpes 14. 9 SimplexVirus.Onceapersonhasthevirus,itremainsinthebodyforever.Further,sincethe 10 Victoria Hospital Medical records show that Sri Nithyananda Swami does not have the antibodies 11 for the Herpes Simplex Virus, this indicates he was never infected by that virus. 12 Rao'sConditioniscontagiousandcanbetransmittedtootherswhethersheishaving 15. 13 an outbreak or not and her Condition would very likely spread to another person even if she is 14 asymptomatic. 15 SinceHerpesistransmittedbyskin-to-skincontact,itmaybetransmittedevenif 16. 16 there is no sexual intercourse. Condoms are most effective at preventing sexually transmitted 17 diseases that are spread through ejaculate and vaginal fluid, but there is no absolute guarantee that 18 using a condom would prevent the spread of her Condition. 19 Rao'sConditionishighlycontagiousandcanshedfrommultiplesitesfromherbody 17. 20 atdifferenttimes.SincethemajorityofshedingisclusteredaroundaHerpesoutbreak,Raowould 21 therefore be most contagious seven days before and seven days after an outbreak. 22 BaseduponmyreviewofthemedicalrecordsandMrs.Rao'sallegations,Ifindher 18. 23 claimsnottobereasonablycrediblenorbasedonfact.IfherclaimsinExhibitCweretrue,Mrs.Rao 24 wouldlikelyhavepassedthishighlyinfectioussexuallytransmitteddiseasctoSwaniji.However, 25 giventhehighlycontagiousnatureofhercondition;thefactthatMrs.Raowouldhaveregular 26 monthly flare-ups; the high number of instances that Rao alleges skin-to-skin physical contact with 27 Swamiji;andthefacrthatthemedicalrecordsshowthatSwamijidoesnotpresentanyindicationof 28 2 AFFIDAVIT OF RICHARD SOKOLOV, M.D. Sb:0T 9T0Z/92/90 860880 20390d
beinginfectedbythishighlycontagiousdiseaseprovethatMrs.Rao'sallegationsofrapeand/or 1 sexual abuse are false. 2 IdeclareunderpenaltyofperjuryunderallthelawsoftheUnitedStatesofAmericathatthe 3 foregoing is true and correct. Executed this day of June, 2015 in Beverly Hills, California. 4 pu W 5 6 RICHARD SOKOLOV, M.D. 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 3 AFFIDAVIT OF RICHARD SOKOLOV, M.D. St :0I 9T0Z/9Z/90 98600 394
AFFIDAVIT OF MARK W. VOGEL, M.D., F.A.C.S. I, MARK VOGEL, M.D., declare as follows: 1. I have over 31 years of experience as an urologist. A true and correct copy of my fullCurriculumVitaeisattachedheretoasExhibitA. 2. I am board-certified urologist in the State of California (USA) and a member of the teaching faculty for the Urology Residency Program at Cedars-Sinai Medical Center. 3. I was the past chief of the Division of Urology and Vice-Clinical Chief of the Department of Surgery at Cedars-Sinai Medical Center, with staff positions at Cedars-Sinai and University of Southern California (USC). 4. My practice emphasizes in all areas of urology. 5. I am a Qualified Medical Evaluator (QME) for the State of California. 6. In addition to being a fellow of the American College of Surgeons, I am a member of numerous local, state and national medical organizations. 7. I completed my medical education at the USC Keck School of Medicine and completed my internship and residency at the Los Angeles County-USC Medical Center. 8. I actively teach at the University of Southern California, where I am a clinical professor of Urology and Family Medicine. 9.IhavereviewedthemedicalrecordsofSriNithyanandaSwami(the"Patient"), produced by the Bangalore Medical College & Research Institute, Victoria Hospital,Bangalore("VictoriaHospitalReport")atachedheretoasExhibitB.I also reviewed the medical records of the Patient, produced by Fortis Hospital ("Fortistestresults")whichisattachedheretoasExhibitC.(collectively, "Victoria Hospital Report" and "Fortis test results" are referred herein as the "Swamiji Medical Reports"). 10.IalsoreviewedtheIndianchargesheetallegations("IndianChargesheet")ofMrs. Aarthi Rao submitted under the alias "Amala", specific to her allegations of uuur AFFIDAVITOFMARKW.VOGEL,M.D.,F.A.C.S.
sexual abuse against the Patient from the beginning of 2005 through end of 2009. Specifically, Mrs. Rao alleges to have been forced into having sexual intercourse and giving oral sex on numerous occasions, that she was touched and kissed by the Patient and that in the course of these acts. Attached as Exhibit D is Mrs. Rao's Indian chargesheet allegations. 11. I also reviewed the Washtenaw court-ordered medical records from the University of Michigan Hospitals and Health Centers of Mrs. Aarthi Rao, spanning 2004 through2009("RaoMedicalReports").AttachedasExhibitEisthereferenced court order from the Washtenaw County Trial Court in Ann Arbor, Michigan. Also attached as Exhibit F is the Rao Medical Reports. 12. Based on my review of Mrs. Rao's claims and based on a comparison of those claims against Swamiji's Medical Reports and Rao's Medical Reports, I find Mr. Rao's claims of sexual abuse by the Patient to be unbelievable: 1) The Patient's medical records clearly show he is neither interested in sex nor is sexually active and 2) Mrs. Rao is a carrier of highly contagious sexually transmitted disease and the Patient is not. My report further describes the medical support offered in support of these conclusions. 13. Swamiji's Medical Reports indicate that the he has a longstanding history of erectile dysfunction based on the following: a. Swamiji's Medical Reports clearly indicate that the Patient has very low levels of testosterone (anorchid levels) and low levels of luteinizing hormone ("LH"). Sex drive or "Libido" is triggered by an arousal mechanism relating to these hormones in the brain. The Patient's condition leaves the Patient with extremely low hormone levels sufficient to establish any libido and is a strong indicator of erectile dysfunction. If there is no/low libido, then there is no need for any sexual gratification. b.Thereisampleevidenceincurrentmedicalliteratureofacutoffpeak systolic velocity of 15 cm/see in the flaccid penile Doppler test. There are also studies done on Indian patients in India who have taken a lower cut offof10cm/sec.TheDopplertestresultsindicatethatSriNithyananda Swami's peak systolic velocity, in a flaccid state, is only 6.7 cm/sec on the right side, which indicates insignificant blood flow and is significantly lower than normal and is sufficient to be considered a vascular cause of erectile dysfunction. The same test recorded the left side was recorded at 14.1 cm/sec. Normally, the peak systolic velocity is near equal on both sides, but this is not the case with Syj Mithyananda Swami and this is also AFFIDAVTOFMARKW.VOGEL,M.D.,F.A.C.S.
indicativeoferectiledysfunction.[Source:DGolijanin,etal,Doppler cvaluation of erectile dysfunction - Part 2, International Journal of Impotence Research, (2007) 19, 43-48] TheVictoriaHospitalreportregardingthephysicalexaminationdescribed "moon faced" (facies) and gynecomastia, which could also be evidence of an endocrine disorder that could cause impotence. d. Further, it should be noted that it takes a long time for hormonal levels to reach such low levels, particularly with the presence of gynecomastia, as indicatedbytheVictoriaHospitalreport.Thisisadefiniteindicatorofa chronic and longstanding disorder. e. In addition, Sri Nithyananda Swami's results indicate that he has diabetes, hypertension and dyslipidemia-all of which are well known in the medical literature to cause erectile dysfunction. Thetesticularvolumes,recordedbyVictoriaHospitalontheultrasound studyat12.04cc's(right)and11.4cc's(left),arelowerthanaccepted normal volumes for functional male testes, ranging from 12.5 ce's to 19 cc's. which is supportive of hypogonadism. [Sources: Kim, W. et al, US MR Imaging Correlation in Pathologic Conditions of the Scrotum. Radiographics27(5)1239-53;VinayakaU.S,etal"CorrelationBetween Testicular Volume & Sperm Count in Infertile South Indian Male Patients". Journal of Evolution of Medical and Dental Sciences 2014; Vol. 3,Issue36,August18;Page:9478-9483,DOI: 10.14260/jemds/2014/3223.] TheScrotalDopplerexaminationintheVictoriaHospitalreportshows, "significant varicocele seen on either side", another contributing factor to erectile dysfunction, which along with low testicular volume is another contributing factor to testicular dysfunction [hypogonadism].. h. The Fortis test results indicate that the Patient also has poor nocturnal tumescence,whichindicatesthatthePatientisunabletohavesexual intercourse or sustain an erection (erectile dysfunction). TheVictoriaHospitalReportalsoreferstothepsychologicalassessment of Sri Nithyananda Swami. When questioned during his psychological examination, the Patient gives a clear history of his body being AFFIDAVITOFMARKW.VOGEL,M.D.,F.A.C.S.
unresponsive to sexual urge, no sexual activities during his lifetime, no history of masturbation or wet dreams or any erections. The Victoria Hospital medical team refers to the psychological exam in their report and has not disputed these unique findings in their report. j.Futher,thesystemicexaminationconductedbytheVictoriaHospital medicalexaminationteamobservedthePatient'sjudgmenttobe"intact" and that his thought stream as "Normal". Also, the psychological examination did not reveal any evidence of psychopathology. In my opinion and experience, these findings go to the reliability of the Patient's statements referred to in the previous point. k. The Victoria Hospital records conclude that there is no evidence of "unnatural sex" 14.ThePatientmanifestsallthethreecausesoferectiledysfunction:vasculogenic, hormonal and psychological. Further, the Patient's low hormone levels and poor nocturnal tumescence could not manifest overnight. Rather, it is likely he has had these conditions for a number of years. 15. Mrs. Rao's allegations indicate that the Patient has a strong sex drive and is highly sexually active, yet there is nothing in the medical facts to support these claims. In fact Mrs. Rao's Medical Reports indicate that she was sexual active during the time period of the allegations in the Indian Charge sheet and that she had multiple partners and multiple STDs. The reports state: "The Patient is concerned she had exposure to a new partner 1 year ago and reports using condoms for contraception. She wonders if through oral sex or that episodes of vaginal intercourse she was exposed to sexually transmitted disease. Exceprt from June 3, 2010 doctor's visit. P. 10 of report 16. Rao Medical Reports also reveal: a. That, since at least 2004, she was infected with at least four highly infectious sexually transmitted diseases (STDs): Herpes Simplex Virus I, Herpes Simplex Virus II, Recurrent Genital Herpes and Herpes Gladiatorum. b. She contracted the aforementioned STDs from a partner other than her husband. AFFIDAVIT OF MARK W. VOGEL, M.D., F.A.C.S.
17. On the other hand, Swamiji's test at Fortis and Victoria for STD (HSV1, HSV2) are consistently negative indicating no previous or current exposure to HSV1 and HSV2 (as seen by the lgG and 1gM antibodies). 18. In my 30 years of experience, and based on my review of ample medical evidence, I find: a. Swamiji's Medical Reports provide clear medical and psychological evidence that he is physically incapable of sexual acts and has no desire for sex. Mrs.Rao'sclaimsofsexualabusebySwamijitobeincredulousand false. I declare under penalty of perjury under all the laws of the United States of America that 益 the foregoing is true and correct. Mlu VoylMAD MARK VOGEL, M.D. AFFIDAVIT OF MARK W. VOGEL, M.D., F.A.C.S.
CIVIL CODE § 1189 CALIFORNIA ALL-PURPOSE ACKNOWLEDGMENT AA EAAS5SAS55AFR A notary public or other officer completing this certificate verifies only the identity of the individual who signed the document to which this certificate is attached, and not the truthfulness, accuracy, or validity of that document. State of California ) e. Bren Nennss, Ary Palie On Tily 28, 20т5 .before mé, HereInsertNameandTitle-oftheOfficer Date Merk Vogel, M.D. personally appeared Name(sj of Signer(s) who proved to me on the basis of satisfactory evidence to be the person(s) whose name(s) is/are" subscribed to the within instrument and acknowledged to me that he/she/they executed the same in his/her/their authorized capacity(ies), and that by his/ber/their signature(s) on the instrument the person(s), or the entity upon behalf of which the person(s) acted, executed the instrument. IcertifyunderPENALTYOFPERJURYunderthelaws of the State of California that the foregoing paragraph is true and correct. BRIAN NORCROSS 3А Signature Los Angeles County Signature of Notary Public Place Notary Seal Above OPTIONAL Thoughthissectionisoptional,completingthisinformationcandeteralterationofthedocumentor fraudulent reattachment of this form to an unintended document. Description of Attached Document Mt at nek vegel ocument Date: Signer(s) Other Than Named Above: Number of Pages: Capacity(ies) Claimed by Signer(s) Signer's Name: Signer's Name: 1 Corporate Officer - Title(s): Corporate Officer - Title(s): Partner - General " Limited General Limited Partner - l Attorney in Fact I Attorney in Fact Individual Individual I Guardian or Conservator I Guardian or Conservator ] Trustee 1 Trustee Other: Other: Signer Is Representing: Signer Is Representing: UON ©2014NationalNotaryAssociation.www.NationalNotary.org.1-800-USNOTARY(1-800-876-6827)Item#5907
AFFIDAVIT OF ROBERT Di LORETO, M.D. I, Robert Di Loreto, M. D., being first duly sworn, deposes and states that: I am over the age of 18 and am a resident of the State of Michigan. 1. I have personal knowledge of the facts set forth below, and if called upon, could 2. and would competently testify to the facts set forth herein. I am one of the founding partners of Michigan Institute of Urology (MIU). 3. I am currently Co- President and CEO of MIU. 4. IhavepracticedUrologyinMetropolianDetroitsince1979. 5. I am Board Certified in the specialty of Urology by the American Board of 6. Urology since 1982. I specialize in all areas of adult Urology, with an emphasis on the management 7. and treatment of Erectile Dysfunction. I have hospital affiliations with St. John's Hospital and Medical Center and 8. Beaumont Grosse Pointe Hospital. IserveasPanelMemberandConsultanttotheU.S.FoodandDrug 9. Administration, Center for Device Evaluation and the division of Urology and Gastroenterology since 1989. I currently serve as the Chairman of Urology at St. John Hospital and Medical 10. Center in Detroit, Michigan. I am a past President of the medical staff of the St. John Hospital and Medical 11. Center. IamapastChairmanoftheCredentialCommitteeoftheSt.JohnHospitaland 12. Medical Center. 1
I am a past Chairman of the Board of the St. John Hospital and Medical Center, as 13. well as Board Member of St. John Health System. I am currently a member of the American Urology Association and Michigan 14. Urology Association. I have had an opportunity to review a certified copy of the medical records of Sri 15. NithyanandaSwamifromVictoriaHospital,Bangalore.(PleaseseeattachedExhibitA.) Sri Nithyananda Swami's testosterone levels are low and consistent with a low 16. libido. His testosterone levels are also consistent with the inability to achieve, let alone maintain an erection, Sri Nithyananda Swami's negative HSV test results reveal that he is negative for 17. all Herpes virus variations. Sri Nithyananda Swami's VDRL test results confirm that he does not have 18. Syphilis. Sri Nithyananda Swami's physical examinations were normal and did not reveal 19. i any visible signs of Sexually Transmitted Diseases. Sri Nithyananda Swami's Herpes titer levels were all negative, confirming that he 20. is not a carrier of any Herpes strain. Sri Nithyananda Swami's test results reveal that he is negative for HIV. 21. г Sri Nithyananda Swami's test results reveal that he is negative for Hepatitis. 22. SriNithyanandaSwamihashaddiabetesandhypertensionformorethan10 23. years, which can cause erectile dysfumction by nerve and blood vessel impairment and ultimatcly blocking sufficient vascular flow to create erections. 2
SriNithyanandaSwami'ssmalltestesvolume(12.04cc'sontherightand11.4 24. ce's on the left) is below the normal volume (12.5 ce's to 19 ec's) for men between 30 to 40 years old. 25. The Tanner scale, also known as the Tanner stages is a scale of physical developoentinchildren,acdolescentsandaduts. The Tanner scale defines physical measurements of development based on 26. external primary and secondary sex characteristics, including testicular volume. Based on the Tanner classification system, Sri Nithyananda Swami would clearly be classified as a Tanner III. SignificantlylowtestesvolumeisacommoncharacteristicofTanner1throughTannerII!. Tanner III levels correspond with extremely low levels of testosterone, which inhibit libido or i "sex drive" and can cause erectile dysfunction. Genitals (male) Tanner1-prepubertal(testicularvolumelessthan1,5ml;smallpenisof3cmorless)[typicallyage9andyounger]. Tanner II - testicular volume between 1.6 and 6 ml; skin on scrotum thins, reddens and enlarges; penis length unchanged [9-11]. Tanner III - testicular volume between 6 and 12 ml; scrotum enlarges further; penis begins to lengthen to about 6 cm [11-12.5]. Tanner IV - testicular volume between 12 and 20 ml; scrotum enlarges further and darkens; penis inereases in length to 10 em and eireumference [12.5-14]. Tanner V - testicular volume greater than 20 ml; adult scrotum and penis of 15 em in length [14+] 3
IV JS V 25 LawrenceS.Neinstein,M.D.:AdolescentMedicine-Children'sHospitalLosAngeles CA. 1 Sri Nithyananda Swami has hypogonadism as revealed by his below castration 27. levels of testosterone the normal testosterone level for men are listed below. Sri Nithyananda Swami's testosterone levels of 12.5 ng/dl are significantly below the normal range. Ingeneral,thenormalrangeinmalesisabout270to1070ng/dL,withan average level of 679 ng/dL. A normal male testosterone level peaks at about age 20,thenitslowlydeclines.Testosteronelevelsaboveorbelowthenormalrange areconsideredbymanytobeoutofbalance.CharlesPatrickDavis,MD,PhD, http://www.medicinenet.com/high_and_low_testosterone_levels_in_men/views.ht m. Notably, it takes many years for hormone levels to go so low and particularly with the presence of gynecomastia, as was observed by the Victoria Hospital, Bangalore results, which i can be associated with low testosterone and impotence. SriNithyanandaSwamihaslowLHlevels.LHbloodlevelsarelistedbelow. 28. Clin Chem Lab Med 2002;40(11):1151-1160. Reference Values - Males: 0-14 days: not established 4
15 days-10 years: 0.3-2.8 IU/L 11 years: 0.3-1.8 IU/L 12 years: 0.3-4.0 IU/L : 13 years: 0.3-6.0 IU/L 14 years: 0.5-7.9 IU/L 15-16 years: 0.5-10.8 IU/L 17 years: 0.9-5.9 IU/L > or =18 years: 1.8-8.6 IU/L 29. Sri Nithyananda Swami is 0.216 MIU/ml, which indicates that the pituitary gland is not producing the amount of LHI that is normally produced in an infant. These low LH levels alsoindicatethatthedeficiencyiseitheroriginatingfromthepituitaryglandorthe hypothalamus. The Penile Doppler test showed that Sri Nithyananda Swami's peak systolic 30. velocity(PSV)cutoffoflessthan6.7cmlsflowintherightcaverosalarteryand14.1cm/sin the left cavernosal artery in flaccid cavernosal artery is low, which indicates a blood flow insufficienttocauseanerection,andisconsideredabnormal.Basedonthestudy,"Penile DuplexSonographyintheDiagnosisofVenogenicImpotence",[JVascSurg.1991 Jan;13(1):75-82;discussion82-3.BassiounyHS,LevineLA.DepartmentofSurgery,University of Chicago Medical Center, IL 60637], Sri Nithyananda Swami's PSV measurements would be classifiedunder"GiroupC,"whichwasagroupofpalientshaving"bothvenousleakageand arterialinsufficiency"-commoncausesoferectiledysfunction. 5 1
31. Both the findings in the study referenced in Paragraph 30 and my review of the Victoria Hospital, Bangalore medical records of Sri Nithyananda Swami are further supported by the medical analysis I provided in a previous affidavit, dated June 11, 2013. Exhibit B. Based upon my experience, education, training, and review of the Victoria 32. Hospital,BangaloreRecords(ExhibitA),itismyopinionthattheStiNithyanandaSwami suffers from all the primary and common secondary causes of erectile dysfunction. Further, it is my medical opinion that the likelihood of Sri Nithyananda Swami 33. achieving and maintaining an erection is highly unlikely and therefore impossible that Sri Nithyananda Swami committed the sexual acts that he is accused of. Further, Affiant sayeth not. RROwuk- Robert Di Loreto, M.D. Subscribed and sworn to before this 28 day of April, 2015. ANNETTE MARIE MIANECKI Notary Public - Michigan Owndht Honi h uanch Macomb County , Notary Public Acting in the County of MAC2M4o MAEOMB County, Michigan My Commission Expires: 5/a/2020 Acting in MAcOMS County 6
AFFIDAVIT OF MICHAEL A. McILROY, M.D., E.A.C.P. I, Michael A. Mcllroy, M. D., F.A.C.P., being first duly sworn, deposes and states that: I am over the age of 18 and am a resident of the State of Michigan. 1. I have personal knowledge of the facts set forth below, and if called upon, could 2. and would competently testify to the facts set forth herein. I have hospital affiliations with St. John's Hospital and Medical Center, William 3. BeaumontHospitalofGrossePointeandSelectSpecialtyHospitalofGrossePointe.(Pleasesee Curriculum Vitae, attached hereto as Exhibit A.) I am an Internal Medicine and Infectious Disease physician in Southeastern 4. Michigan since 1982. I am a faculty member of Oakland University William Beaumont School of 5. Medicine. I am a Fellow of American College of Physicians (F.A.C.P.). 6. IamaClinicalAssociateProfessorofWayneStateUniversitySchoolof 7. Medicine. I am Board Certified in the specialty of Internal Medicine since 1985. 8. I am Board Certified in the specialty of Infectious Diseases since 1988. 9. I am a member of the Michigan Infectious Disease Society. 10. I am also a member of the Infectious Disease Society of America. 11. I am a member of the Federal Bureau of Investigation Citizens Academy since 12. 2008. I have had an opportunity to review the medical records of Sri Nithyananda 13. Swami("Swami").(PleaseseeatachedExhibitB.)
I have had an opportunity to review the detailed claims of Aarthi Rao ("Rao") in 14. her Indian witness statements under the alias "Amla". (Please see attached Exhibit C). I have had an opportunity to review the medical records of Rao from the 15. UniversityofMichiganHealthSystem.(PleaseseeattachedExhibitD).Thesedetailedrecords clearlyindicatethatMs.Raohas,ataminimum,HerpesSimplexVirusIandII,recurrent GenitalHerpesandHerpesGladiatorumsinceatleast2004. Rao claims in Exhibit C that she and Swami had skin-to-skin physical contact on 16. several occasions. Herpes is defined as any inflammatory skin disease marked by the formation of 17. small vesicles in clusters; the term is usually restricted to such diseases caused by herpes viruses. Genital Herpes is an infection of the genitals, buttocks, or anal area caused by 18. Herpes Simplex Virus. Most Genital Herpes is caused by Herpes Simplex Virus II. 19. MostcasesofGenitalHerpesarecausedbyHerpesSimplexVirusII.InHerpes Simplex Virus II, the infected person may have sores around the genitals or rectum. Although Herpes Simplex Virus II sores may occur in other locations, these sores are usual found below the waist. SymptomsofHerpesSimplexVirustypicallyappearasablisterorasmultiple 20. blisters on or around affected arcas, usually the mouth, genitals, or rectum. The blisters break, leaving tender sores. There is no cure for Herpes Simplex Virus. Once a person has the virus, it 21. remains in the body forever. Based upon my experience as an Infectious Disease and Internal Medicine expert, 22. andbaseduponmyreviewoftherecords,havethefollowingopinion: 2
: : RaohadrecurrentGenitalHerpes,HerpesSimplexVirusIandIIand A. Herpes Gladiatorum (Rao's "Condition") prior to the time that she met Swami in 2004. Rao is highly infectious with her Condition. B. Rao's Condition is contagious whether she is having an outbreak or not. C. Her Condition can spread to another person even if her infection is D. asymptomatic. Any skin-to-skin contact places one at risk for the spread of her Condition. E. Condoms are most effective at preventing Sexually Transmitted Diseases F. ("STD") that are spread through ejaculate and vaginal fluid. CondomsarenotasprotectiveforherConditionastheyareforHIV, G. Chlamydia or Gonorrhea. HerConditionishighlycontagiousandcanshedfrommultiplesitesat H. different times. HerpesGladiatorumisaskininfectioncausedbyHerpesSimplexVirus. I. The majority of shedding is clustered around a Herpes outbreak. J. Raowouldthereforebemostcontagioussevendaysbeforeandsevendays K. after an outbreak. Having sex around this time of an outbreak significantly increases the risk L. of infecting a partner. The average time for transmission of Herpes with a new couple where one M. partner has it and one does not, is two months. Her Condition is a chronic, lifelong infection. N.
& If the facts contained in the attached charge sheet (Exhibit C) are accurate, 0.1 it is extremely likely that Rao would have passed this highly infectious Sexually Transmitted Disease to Swami. Upon review of Swami's medical records (please see Exhibit B), Swami is P. notinfectedwithHerpesoranyotherSexuallyTransmittedDisease. Further,areviewofSwami'smedicalrecordsrevealshehasextremely Q. low testosterone levels. Based upon my review of the facts, including the objective medical R. records, I find it very unlikely that Rao's version of events included in Exhibit C is true. Further, Affiant sayeth not. 1530 Michael A. Mellroy, M.D., F.A.C.P. Subscribed and sworn to before this 13 day of September, 2013. Or , Notary Public My Commission Expires: Dec S,0019 Acting in Waympa County NOTARY PUBLIC - MICHIGAN ACTING IN THE COUNTY OF Wayn! 4
Umakant Khetan M.D.; F.A.C.S. Vrology & Vascular Acess Surgery 1245 Wilshire Blvd. suite 306 13-802-0105 Email - [email protected] Losangeles,Ca90017;phone#213-802-01 AFFIDAVIT I, DR. UMAKANT KHETAN, declare as follows: 1. I have over 36 years of experience as an urologist. My full Curriculum Vitae, Exhibit 1, is attached. a)IcompletedmyMBBSfromKEMHospital,Bombay,Indiain1973. b) I obtained an MS in General Surgery, which included a Urology residency from KEM Hospital, Bombay, India 1978. c) I completed a formal residency in Urology, at the University of Minnesota in 1982. d) I completed my board certification in Urology in 1986, and my present California license is A-38780, 1982. e) I am a past chairman of The Department of Urology, St. Vincent Medical Centre, LA, California f) I am a Medical Director and advisor to, The National Institute of Clinical Research. g) I have published 15 peer-reviewed articles in International journals. h) I have contributed to 2 book chapters. This is my opinion and conclusions with respect to the medical records of 2. Sri Nithyananda Swami, who was examined at Victoria Hospital and institute of Nephro -Urology, in Bangalore -560002, India and the subsequent report givenbytheexaminingteamatVictoriaHospitalinBangalore,Karnataka. ("Report").Ihavehadanopportunitytoreviewtheattached,Exhibit2,in preparation of this Report and conclude as follows: Sri Nithyananda Swami's tests show that his blood flow to the penis is 3. not normal, which would result in poor erectile function and difficulty in having sexual intercourse. His hormone levels are extremely low, which would result in almost No 4. sexual Desire or Libido. This degree of hypogonadism would also affect the
Umakant Khetan M.D.; F.A.C.S. Vrology & Vascular Acess Surgery 1245 Wilshire Blvd. suite 306 Losangeles,Ca90017;phone#213-802-0100;fax#[email protected] erectile and sexual function of the person, making it very difficult to have sexual intercourse. Physical finding of bilateral gynecomastia is further evidence of 5. feminizing characteristics that make the erectile function very poor. Further, it takes several years for the hormonal levels of Testosterone to 6. reach anorchid levels and gynecomastia to develop. This indicates a chronic disorder of long standing. Inthefindingsrelatingtothepsychiatricandpsychologicalassessment 7. of Sri Nithyananda Swami, there is a clear history of his body being unresponsive to sexual urge, no sexual activity during his lifetime, no history of masturbation, wet dreams or erections. The psychiatric team has not disputed this history in the report, though these findings indicate a psychological cause of Erectile Dysfunction. All they have reported is that Sri Nithyananda Swami has an intact judgment and there was no evidence of psychopathology. Notably, there are glaring discrepancies between the actual results of the 8. Hospital report. Finally,havinglongstandingdiabetes,hypertensionandDyslipidemia, 9. along with the medications one has to take for these conditions, has a significant negative impact on the vascular and neuropathic flow to the penis, again causing significant compromise of the erectile function. In conclusion, in my more than 30 years of experience, having seen and 10. treated hundreds of cases of erectile dysfunction, I can say that a person with these objective and subjective findings would most likely, not be able to have spontaneous erections or sexual intercourse. I declare under penalty of perjury under all the laws of the United States of America that the foregoing is true and correct. This declaration is signed on the /2 day of December 2014 at lev é h UAKANT KHETAN, MD ANA ROSA HURTADO Commission # 1933434 Notary Public - California Los Angeles County TL 1T My Comm. Expires Apr 22, 2015
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S Schulich Western MEDICINE & DENTISTRY Gerald Brock, MD FRCSC Professor Department of Surgery Division of Urology Schulich School Of Medicine and Dentistry Western University London Ontario RE: Sri Nithyananda Swami 1,Dr.GeraldB.Brock,UrologistandSurgeon,oftheCityofLondon,ProvinceofOntario, hereby MAKE OATH AND SAY: IamaProfessorofSurgery,intheFacultyofMedicine,DivisionofUrology,atthe 1. UniversityofWesternOntario,inLondonOntario.Iattachacopyofmycurrentcurriculum vitae as Exhibit "A". Qualifications IreceivedaB.Sc.inPhysiologyin1981andanM.D.in1986,bothfromMcGill 2. University. From 1986 to 1991, I trained as a urology resident at McGill University. I passed my Urology Royal College board exams in 1991. From1991to1993,IwasaresearchfellowattheUniversityofCaliforniaatSan 3. Francisco (UCSF). There, my research centered on neuro-urology, under the direction of Drs. Tom Lue and Emile Tanagho, both leading researchers in the area of erectile dysfunction. The focus of my research was on the causes and treatments of erectile dysfunction. 4. One specific area I studied during this time was the non-adrenergic non-cholinergic (NANC) pathway, and the neuro-regulation of erections in rats, dogs and humans. &A
I have received awards for my research in the urology field, and in particular relating to 5. investigations into erectile dysfunction. These are set out fully in my attached curriculum vitae, butsomeofthemoreprominentandrelevantawardsIreceivedare: The 1992 Jean-Paul Ginestie Prize for research relating to the three-dimensional (a) structure of the human tunica albuginea: anatomical and ultrastructural levels, atthe1992VthWorldMeetingonImpotence;asaco-author. (b) First prize in the 1993 Joseph F. McCarthy Essay Contest run by the American UrologicalAssociation,WesternSection,formypapertitled"NitricOxide Synthase:AnewdiagnostictestforneurogenicImpotence".Ialsoreceiveda similarawardfromtheQuebecUrologicalAssociationforthesamepaperin 1993; Firstprizeinthe1994CanadianUrologicalAssociationEssayContestformy (c) papertitled"Isnitricoxidesynthasetestosteronedependent:ananimalmodel". IalsoreceivedtheJean-PaulGinestiePrizeforthisresearchatthe1994VIth World Meeting on Impotence, run by the International Society for Impotence Research; Secondplaceinthe1995JackLapidesEssayContest,runbytheAmerican (d) UrologicalAssociation,forapapertitled"Erectionisatestosterone-dependent event: an animal model"; The2003OutstandingUrologyTeachingAward,fromtheUniversityofWestern (e) Ontario. IamamemberoftheCanadianUrologicalAssociation,theAmericanUrological 6. Association,theCanadianMedicalAssociation,theCanadianFertilityandAndrology Association,theCanadianMaleSexualHeaithCouncil,SexualMedicineSocietyofNorth America(SMSNA)andtheCanadianUrologyResearchConsortium(CURC).Ihaveattendedall CanadianUrologicalAssociationandAmericanUrologicalAssociationmeetingsdatingfrom 1992onward.IwaspreviouslytheSecretaryoftheSMSNA.IamthetreasureroftheCURC 9l and the chair of the Canadian Urology Association, Office of Education.
I currently hold, or have held, seats on national and international committees relating 7. to erectile dysfunction and its treatments, including the chair of the Canadian Urological Association'sSexualHealthEducationCouncil,theHeartandStrokeFoundation's CardiovascularSafety-VIAGRApanel,andtheWorldHealthOrganizationConsensusPanel onImpotence.AtthelastWHOConsensusConferenceonImpotenceinParis,Iservedasa member of the pharmacologic therapeutics committee that evaluated PDE5. I am the chair of the 2015 ISSM Consensus Meeting on Sexual Medicine in association with ICUD (International Consensus of Urological Disease). Since 1993 I have taught and supervised undergraduate and graduate medical students, 8. post-doctoralresearchfellows,andurologyresidents.Myteachinghasfocusedoninfertility and erectile dysfunction, including the causes, known and established treatments, and researchregardingnewtheoriesoftreatment.IhavebeentheurologyresidencyProgram Director at Western University since 2010. 1 am presently a contributor to the Royal College of Physicians and Surgeons of Canada for urology. From 2000-2004, I was a member of the test committee for the Royal College of Physicians and Surgeons of Canada for urology and served as a core examiner for the test committee from 2004-2009. From 1994 to 1998 I was a UrologyinTrainingexamineratMcGillJniversity.IsitontheeditorialboardsofTheCanadian Journal of Urology, the Journal of Andrology, and the Journal of Sexual Medicine. I am also an ad hoc reviewer for the Journal of Urology, Urology, American Journal of Physiology, American SocietyofHospitalMedicine,PharmacistsAHFSDrugInformation,CanadianMedical Association Journal, and Asian Journal of Urology. I am an author on over 150 peer reviewed publications and book chapters, and almost 9. 100additionalpresentationabstracts,mostrelatingtoerectiledysfunction.Ihavealsobeenan invitedspeakeratmanyinstitutionsaroundtheworld,againmostlyrelatingtoerectile dysfunction. Details are set out in my curriculum vitae. 10. Ihave,since1986,keptabreastofthescientficliteraturerelatingtourology,and erectiledysftunctioninparticular,byregularlyreadingprominentjournalssuchasUrology, Journal of Urology, Canadian Journal of Urology, International Journal of Impotence Research, NewEnglandJournalofMedicine,Circulation,CirculatoryResearch,AmericanJournalof Physiology,andBritishJournalofUrology.Ihaveparticularlyfollowedthescientficliteratur "al
relatingtotheelucidationofthepathwaysinvolvedinthepenileerectionprocess,andnew theories and developments relating to the causes and treatments of erectile dysfunction. 11. Asaresultofmyeducationalandprofessionalexperience,IbelieveIamqualifiedto express the opinions set out below. 12. IhavereviewedtherelevantdocumentsfromtheBangaloreMedicalCollegeand ResearchInstitute,VictoriaHospital,relatedtotheabovematterandbelieveIcanprovideyou withanexpertmedicalopinion,basedonmytrainingandknowledgeinthisareaofmedicine, attached as Exhibit "B". IhavereviewedthemedicalreportsyouprovidedtomeindetailandbelieveIcan 13. provideyouwithanopinion,wherepossible,Ihaveattemptedtoquantifythedegreeof medical certainty my statements are based upon. Ihavereviewedthemedicalrecordsofthedefendantpertainingtothegovernment 14. based assessment of Sri Nithyananda Swami and they serve as the basis of my opinion. Over thepastdecadetherelationshipbetweentestosteronelevelsandsexualfunctionhave becomemuchmoreapparent.Testosteroneisthoughttobeanessentialelementinup- regulating the neurotransmitter for erectile function, nitric oxide via its direct action on nitric oxide synthase. In addition to neural signaling, testosterone has been shown to directly alter thestructureofthepeniswithlossofnormalveno-occlusion(VOD)asafrequentcauseof erectile dysfunction in hypogonadal men. In fact, low testosterone animal models are used to studyVOD.Inthiscase,smalltestesvolume,withlowLHlevelsandlowtestosterone measured levels are reported. Althoughhavingdataontheerectilecapacitywithavasoactiveintra-penileinjection 15. wouldhavebeenvaluable,itwouldnothavebeendefinitiveinanycase.Overthepast25 years I have seen many men who cannot achieve any erectile penile rigidity but will achieve rigiditywhentheyareinjectedwithavasoactivedrug.Particularlywhenneuralcausesare etiologic,whichmaybethecasehere,asheisknowtohavebothhypertension(vascular disease), endocrinologic causes (low testosterone, small testes, low LH) and diabetes (neural pl cause).
Thelaboratoryvaluesallconfirmahypogonadalstate,inwhichtestosterone,LHand 16. testes size are all below the normal range. The evidence would support his claims about absentsexualdriveandwouldbeconsistentwithahigherprobabilityofimpairedorabsent function.Additionally,amongmenwithlongstandinghypogonadism,thelikelihoodof impairedveno-occlusionisthoughttoelevatedandprobablyrepresentsasignificant contributing factor in many men under age 50 who have erectile dysfunction. Based upon my review of defendant's attached records,the tests have shown no 17. evidence of a sexually transmitted disease. This would be another piece of evidence that would serve in my opinion, to discount the claims of unprotected sexual intercourse between defendant and his accuser. 18.ItseemscuriousthatthefinalevaluationoftheGovernmentMedicalPanelwas inconsistent with the vascular study in which impaired cavernosal arterial was noted, the ultrasoundreportwherereducedtesticularsizemeasuredandthebiochemicalanalysisof testosteronewhichisclearlydeficient,yettheybelievethedefendanthasnoevidenceof impaired erectile function. Additionally, his medical history of diabetes and hypertension would increase his risk of erectile dysfunction statistically to greater than 50% likelihood, in the absence of any other evidence, of which there is an abundance. 19. My opinion based on the available evidence as cited above, is that, the balance of probability would support the defendant's claim of impaired erectile function. Sworn begmenie A tis l&m dey Deel 2o14 oz December 17, 2014 Division of Urology, Department of Surgery Schulich School of Medicine & Dentistry . Western University St. Joseph's Hospital, London, Ontario N6A 4V2
q.odu-qa Rs. 100* ONE #0.@ I.trU.NDRED=RUPEES;I R-€ieqqi ATT-I INDIA I ()O'r oo"r oOoU I C)() co)- -lr oo(o- il l N DIA 1NONltl U DICllfr[, G6o8o *ra rrneI"e ? AP 514647 I AFFIDAVIT E f. I Dr.(Col)K. Ravindran Nair, BSc, MBBS , MS, MCh ( Urology)'do hereby' I solemnlY swear that : a I completed my MBBS in 1970 and then underwent training in General Surgery and Military Surgery atAFMC' Pune from 't973- 't975' I lthen obtained MS in General Surgery in 1978. d. I underwent training in Urology from 1983-1985 at Trivandrum Medical . college and obtained MCh,in Urology, in 1985, from Kerala University. I am a ' I trained Andrologist since 1991 . 4.. I served in the Armed Forces of lndia as Medical officer, surgeon and E Urolog\Qt and retired in the rank of Colonel, and was holdilg$t appointment ;is?rik\drit* in Surgery and Urology. A. q VY.A.C & NOTARY Dr.(Col)K. Ravindran Nair t LIN€ 2* FLOOR, JESUS BUILOING . cocHlN - 3 l Roll No Mob l.rb.h.&lf VATUE OF SOLO r r{. u. Aa9*AUEEZ HIGH g;-eOdIu.JtRrTr VEIT'VI DOI t
lwas also in the academic faculty of AFMC, Department of Urology,and INHS, Ashvini, Naval Hospital , Mumbai , in the subject of Surgery and Urology, for Bombay University. 6. I have 41 years of experience in General Surgery and 3lyears as Urologist and Andrologist. 7. I was past senior advisor in Surgery and urology for the Armed Forces of lndia. 8. I was the past convener of the Andrological section of Urological Society of lndia. 9. I am currently President of lndian Multidisciplinary Society of Men's Health and Healthy Ageing. 10. I am currently the Medical Director and Senior Consultant in Andrology at Dr.Promodu's lnstitute of sexual and marital health , Kochi, Kerala. 11. I have presented over 52 papers at National Conferences with Publications in International and peer reviewed journals. 12. lwas commended for distinguished service at Command Hospital, Northern Command, Jammu and Kashmir. ( Appendix A). 13. I have critically evaluated the relevant medical documents from Victoria Hospital, lnstitute of Nephro-Urology, Bangalore, on tests conducted on Sri.Nithyananda Swami, dated 8-09-2014 (Appendix B). 14. Sri. Nithyananda Swami has extremely low levels of Testosterone (Anorchid or below Castration levels). Such low levels of testosterone , by itself causes alteration in the structure of the Penis, especially the tunica albuginea , leading to Veno-Occlusive dysfunction( VOD), which is a common cause of Erectile Dysfunction in Hypogonadal Men. 15. Simultaneously, the low level of Leutinising Hormone(LH), produced by the Pituitary Gland, suggest a Central cause of Hypogonadism- Hypogonadotrophic Hypogonadism, which is an important cause of Erectile Dysfunction , due to a Pituitary or Hypothalamic condition. An MRl, might have added value to the same. A.C. & NOTARY Dr.(Col)K. Ravindran Nair t\{88S, tlts. M.Ch RS LINE--/ Sr (onrulhn, in lndrolo0y 2d & lJrolc! FLOOF S AUILDING Reg. OPP OLD uRT. No. TC[i COCHTN d32B - 31 /355/95 l\,!ob 984 29732 DEVI. l. c\ \ rnrunxurr-m \ +
16. The scientif t""nn,ore of measuring i: Fraccid *H',,un,'*" fiffi,roffiffi: This study wa 17 -***rffiffiffi;,*: 18. Significant r IIf .,{;JH j:l",ffi :i::"*"J[T".,i:t+ jk:::,%:;fit: Also the dia srand;;;1,.?""jil;:J,::;,.""J:re and after varsarva in 19 ryins and Calcification ,"mhi,.:""ml.;fi ,:f ,:;,,3x,Jl,xii^ilf ,.#i,:i,;: 20. The presence ffiJJ;",.*":,lr;;A;ll;TnjfJ#:;"j,:,. 21 a,so not been uased on Vict nitft l,*: ttt5t3,,i;#"#Jil: bff ;.,ffi 1i,i,"H?;xH? 22. Below . c_a_s-t.r,a_t.ir,on Libido. levels of testosterone, leads to severe loss of 23. Jj;:,nj^ jr,.:" cavernosar injection Bi!',?,:flil; *'" -",i.ffi'jlfi.,l,:: "oi:::i^"oy has n61 6u"n 3J#:[]",":s*ilJfi :i,:*,:"p1,:1"'fl i;:',:ffi;?{ff 24. ,,,J:,:no_occrJsive,li:i,"*H::r::,.1r*Eikl,:g:,Ti,,,; Aus us t, - stn io i;ifi iBT:,'i".T, ilX;:flT o;.l:TJ*,, L LOOR LINE I JESUS L 8-UILOING UR cHtN _ 3., 5 /95 29732 '* / innrei<ill;M\+ I I R.e.No. 4l7t I \ \\ E 6r\Uxo irv ' Datr:29.i7.201}7 ' 7 T
25. The blood biochemical studies confirm, testosterone with low Anorchid LH, levels .rgg"rting of Hypogonadotrophic Hypogonadism. 26. The colour Duplex Doppler study following lntra cavernosal of. Prostaglandin injection suggest Veno-occtusiie Jysirnction minute post lcl , pSV at the 25 and EDV. 27. It is highly likely that further structural changes would have continued to occur due to the row testosterone revelJ and the Veno-occrusive dysfunction would have worsened from 2012_2014. 28. Blood test done at Magnus Lab, Bangalore 2011 , also showAnorchid level of testosterone with low LH.( Appendix D). 29. ln my expert opinion, based on available data, Sri. Nithyananda Swami, meets all the criteria to diagnose Erectile Dysfunction due to Hypogonadotrophic Hypogonadism, with Secondary Veno_Occlusive Dysfunction. Dr.Col.K. Ravindran Nair BSc, MBBS, MS, MCh(Urotogy) Medical Director and Andrologist aatr.t dn tl..O r rtl.i aaloit .E li .fii- .r lrrrbht Dr.Promodu's lnstitute of Sexual and Marital 11".111 p!?A-e{o*@of 20t)- Pathadipallam, Edapally PO, South Kalamassery, Kochi, Kerala 682024 i'-. (fif,Ji .4.C. 1_''twi*rlr.;rri._ & \u /\\ ,-1E {InU,\1lr9.t 1', ', . LOO)+il NF JESUS BUILDING (CIr l\I.> OLD HIG4I C uRT. COCHTN - 31 Roll No 355/95 29732 Nota ri a I Reg i ste r pa rticu I ars SI, N,, 0 f vor. !O p6ss r''1..,6 / Mv c<)mmiss;on expires on 29.07 .20l ,
Affidavit of Bradford T. Black, M.D., FACS STATE OF OHIO ) ) sS Stark COUNTY OF ) I, Dr. Bradford T. Black, being first duly sworn, deposes and states that under the penalty of perjury under the laws of the State of Ohio and United States, as follows: 1. I am over the age of eighteen (18) years, an Ohio resident, and I am competent to testify. 2. I have first-hand knowledge of the facts and opinions set forth herein. 3. Currently, I am a practicing physician and President of Northeastern Ohio Urological Surgeons, Inc. 4. I specialize in all areas of general urology. 5. I also am staff member/courtesy staff member at the following hospitals in Northeastern Ohio: (i) Alliance Community Hospital (Alliance); (ii) Salem Community Hospital (Salem); and (iii) Timken Mercy Hospital (Canton). 6. In 1984, I received a Bachelor of Science in Agriculture and a doctorate in Medicine at the University of Arkansas. 7. Prior to joining Northeastern Ohio Urological Surgeons, Inc., I completed an internship andresidenciesinGeneralSurgeryandUrologyattheUniversityofKansas. 8. I am certified by the American Board of Urology. 9. Further, I have an advanced certification and designation as a Fellow, American College of Surgeons (FACS). 10. I also am a member of American Urology Association, North Central Section of Urology of the American Urological Association, Ohio Urologic Association; American Medical Association; Ohio Medical Association; and Stark County Medical Association. 11. I have reviewed the medical records ("Medical Records") of Sri Nithyananda Swami (the "Patient"), which are from the Victoria Hospital in Bangalore, India and are attached hereto as Exhibit A. According the Medical Records, the Patient was 37 years old at the time the Medical Records and testing referenced therein were done. B B3
E 12.Inadditiontomytraining,education,andyearsofexperience,theMedicalRecordsform thesolebasisformymedicalopinions,whicharemadetoareasonabledegreeofmedical certainty and are set forth as follows: a. The Patient has low levels of Luteinizing Hormone (LH). Specifically, the typical LH blood levels are 0.7 to 7.9 mIU/ml. The Patients' LH level is 0.216 MIU/ml. b. The Patient also has anorchid testosterone levels and suffers from hypogonadism. The normal testosterone level for men between 30 and 40 is a range between 300 ng/ml and 1000 ng/ml. The Patient's testosterone levels12.5 ng/dl-are significantly below the normal range and are consistent with those of a prepubescent boy. In my medical opinion, I do not believe that he could have an erection. c. Gynecomastia, which is also evidence of an endocrine disorder that could cause impotence, was also observed by the medical team. d. The penile Doppler test showed that Patient's peak systolic velocity (PSV) cutoff of less than 6.7 cm/s flow in the right cavernosal artery and 14.1 cm/s in the left cavernosal artery in flaccid cavernosal artery is low, shows a blood flow insufficient to create an erection, and is abnormal since it is not balanced. e. Moreover, the Patient's testicular volume (12.04 cc's on the right and 11.4 cc's on the left) is below the normal volume (12.5 cc's to 19 cc's) for men between 30 to 40 year old. f. There is no indication from the Medical Records that the Patient has any sexually transmitteddisease,includingHSV-1(IgGandIgM),HSV-2(IgGandIgM), HIV, VDRL, Hepatitis B. g. The test results also show that the Patient has diabetes, hypertension, and dyslipidemia. All of these conditions can cause erectile dysfunction. h. The below normal test results contained in the Medical Records and mentioned herein do not occur over-night, but likely have existed for numerous years. For example,ittakesalongtimeforhormonelevelstogosolowandparticularly with the presence of gynecomastia, this is an undeniable indicator of a chronic disorder. 126
ThePatienthasbeendiagnosedwithhypertensionsince2003anddiabetessince 2004. This results in years of blood vessels being destroyed and ultimately blocking sufficient vascular flow to create erections. Baseduponmyexperience,education,training,andreviewoftheMedical Records, it is my opinion that the Patient suffers from all the primary and most common causes of erectile dysfunction: hormonal and vasculogenic secondary to diabetes and hypertension. Baseduponmyexperience,education,training,andtheevidencecontainedinthe Medical Records, in my medical opinion, I do not believe that he could have an erection to have sexual relations. Affiant further sayeth naught. OszMe1 Madlh Dr. Bradford T. Black, M.D., FACS SWORN TO before me and subscribed in my presence this 81h day of January 2015. خً Notary Public ACTHASER Jeffrey A. Willis, Attomey At Law NOTARY PUBLIC - STATE OF OHIO * My commission has no expiration date Sec. 147.03 R.C. AAES ТНА Br
Richard Sokolov M.D.; Mark W. Vogel M.D.; Robert Di Loreto M.D.; Michael A. McIlroy M.D.; Umakant Khetan M.D.; Gerald Brock M.D.; K. Ravindran Nair M.D.; Bradford T. Black M.D., Medical Affidavits and Expert Opinions on Sri Nithyananda Swami's Medical Condition (2015). United Ancient Nations Documents Collection, reference UAN-LEGAL-MedicalExper-MedicalAffidavit-20150000-1. https://docs.unitedancientnations.org/legal/bnzlkdileeajcueqcdkhvbexvndj
