American Brain Forensics, LLC

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1 American Brain Forensics Client Evaluation Report Date: 07/16/2012 Client Information Name: Defendant Gender: male Handedness: mixed Date of Birth: 06/13/1972 Age: 39 Medications: Depakote, Klonipin, Seroquel, Lamictal Referral Source: Hillsborough County Public Defender s Office Reason(s) for Study: Expert testimony An Executive Summary of this report may be found on pages Client History The Defendant is a 39 year old male who reports to be dual sided. He states he is able to write with both hands, but he prefers his right hand. He throws using both hands and shoots pool left handed. The Defendant sights with his left eye, but shoots with his right hand. The Defendant states his father was in the military. He moved with his parents and lived in military housing. The family was stationed in Guantanamo, where the Defendant was exposed to the Spanish/Caribbean language. He reports he spoke the language as a child. The Defendant states he worked for the department of corrections as a correctional officer for 9 to 10 years before his incarceration. The Defendant notes he was once married for 3 to 4 years with no children. He is now divorced. He describes his early childhood environments as healthy and stable. He notes living with a younger sister (born in 1976) and describes their relationship as rocky growing up. He states they beat each other up repeatedly and relates this to his lifelong problem with anger. He recalls hating his sister back then, though he does not know why. At the age of 15 years, the Defendant attempted suicide with a gun, noting the bullet did not penetrate his skull, but instead glanced off. The Defendant reports he does not know why he did this other than he hated who and what he was, knew he was dangerous, and wanted to avoid fights because he knew he could kill someone. He reports having been involved in many fights in high school and 1

2 claims he always prevailed in fights if he wanted to. The Defendant was born one month pre term. At the age of 2 weeks, the Defendant reports he ran a fever of 103 F. He was prescribed antibiotics for the infection and states he was overdosed severely. He describes many repeated infections of the tonsils, which he had removed at the age of 5-6 years. He reports no issues with this until he contracted pneumonia twice at the ages of 15 years and years, which was treated both times with antibiotics. He reported delayed development which he claims is related to a streptomycin overdose at the age of 2 weeks. He notes he was prescribed with 0.03 milligrams of the medication, but was delivered 300 milligrams instead. He was diagnosed with hearing loss at the age of 16 years, which is presumed to be permanent. In addition, the Defendant claims he suffers from post traumatic stress disorder. The Defendant has experienced multiple losses of consciousness from both motor vehicle and motorcycle accidents. He reports multiple football injuries, hits, and concussions. In February 1992, the Defendant reports he was involved in another motorcycle accident when he struck a dog and was ejected from the bike. He notes he struck the ground with his head and broke his helmet. He was diagnosed with a concussion at the Meese County Hospital. In 1994 he experienced another motorcycle accident when struck by a car. He states, again his helmet was broken and his bike fell on him. He states he experienced a loss of consciousness for 1-2 minutes and sustained a broken leg. He reports one accident without a helmet. He struck a van and struck his head, experiencing a major concussion. The Defendant is unaware of any sequelae, but suspects so. In addition, the Defendant played football from 7 th to 11 th grades, sustaining multiple head injuries and losses of consciousness. In 2003, the Defendant had a roux-en-y gastric bypass and lost 270 lbs. He states he gained 125 lbs back, which he claims is due to his medication. He reports no issues with the use of general anesthesia. He also reports 4 bilateral hernia repairs after his gastric bypass. He underwent surgery for a MRSA infection that he describes as extensive. The Defendant has had various other hospitalizations for cuts, lacerations, and the like. He reports no infectious diseases of the brain and reports one high fever during infancy of unknown etiology but related to bacterial infection, as previously noted. No seizure history is reported and no absences are described per se. The Defendant reports blackouts from alcohol and drugs, as well as sleep apnea. The Defendant reports he began taking pain pills at the age of 15 years for injuries including playing football with broken hands. He notes taking Percocet, Vicodin, and other opioid medications. He states he tried THC once, but did not like it. He states he used LSD once, but also did not like it, stating the high lasted 13 hours. He reports he abused crack and cocaine (mostly cocaine) from

3 until 2006 or He claims no dependence, but when married, he states it became a problem, noting he would consume about 1 ounce in 2 or 3 days. The Defendant reports his wife was an exotic dancer and made a fair amount of money. He worked in the department of corrections from 1993 or 1994 until He states he quit due to his paranoia from cocaine and then divorced his wife. The Defendant states he abused alcohol from the age of 13 years until his by-pass surgery. He notes the alcohol abuse became a problem with his wife and he would often times combine the alcohol it with cocaine. He states his abuse of pain pills continued overall and throughout his life. The Defendant states he has previously worked with a psychologist for his anger issues and bipolar disorder. He states he was diagnosed with bipolar disorder type I in Currently, the Defendant is taking Depakote at a rate of milligrams, Seroquel at a rate of milligrams, Lamictal at a rate of 25.0 milligrams, klonopin at a rate of 2.0 milligrams, and Celexa at a rate of milligrams. In addition, the Defendant takes omeprazole for his high acid in his stomach. With regard to relevant family history, he reports oppositional defiant disorder (O.D.D.) runs in his family. He also reports his family to have several drug and alcohol problems. In reference to educational history, the Defendant reports he was in SLD for language issues related to learning. He states he became bored of schoolwork claiming he was way ahead of the class. He did not do his homework, but claims he scored well on tests. The Defendant is a high school graduate. He claims to have a large number of college credits and states he is close to having a four year degree. When asked what brought him to where he is today, The Defendant states he ended up in trouble due to multiple reasons including drugs and medication issues as well as an attempted suicide. He notes he self-medicated to compensate for a lack of psychiatric medications. He also states his abuse of cocaine led to a prolonged bout of amphetamine psychosis. Tests Administered Interactive Diagnostic Interview with Defendant and Dr. Lambos Personality Assessment Inventory (PAI) CNS-Vital Signs (CNS-VS) Weschler Adult Intelligence Scale-III (WAIS-III) Woodcock-Johnson-III (WJ-III) Quantitative Electroencephalogram (qeeg) 3

4 Test Results Personality Assessment Inventory (PAI)- PAI is a general questionnaire-based assessment that is intended to identify both personality variables of interest and to screen for evidence of psychopathology. The results of the PAI can be seen in the graphs following this text. The PAI clinical profile, for the Defendant, is marked by significant elevations across several scales, including the SOM (somatic), ARD (anxiety-related disorders), DEP (depression), SCZ (schizophrenia), BOR (borderline), ANT (antisocial), ALC (alcohol abuse), and DRG (drug abuse), which indicates a broad range of clinical features and increasing the possibility of multiple diagnoses. Given certain response tendencies (the high NIM (negative impression management), it is possible that the clinical scales may over represent or exaggerate the actual degree of psychopathology. Nonetheless, profile patterns of this type are usually associated with marked distress and, unless there is extensive distortion or exaggeration of symptomatology, severe impairment in functioning is typically present. The configuration of the clinical scales suggests a person with a history of polysubstance abuse, including alcohol as well as other drugs. When disinhibited by the substance use, other acting-out behaviors may become apparent as well. The substance abuse is probably causing severe disruptions in his social relationships and his work performance, with these difficulties serving as additional sources of stress and perhaps further aggravating his tendency to drink and use drugs. The Defendant indicates that his use of drugs has had many negative consequences on his life at a level that is above average even for individuals in specialized treatment for drug problems. Such a pattern indicates that his use of drugs has had numerous ill effects on his functioning. Problems associated with drug abuse are probably found across several life areas, including strained interpersonal relationships, legal difficulties, vocational failures, financial hardship, and/or possible medical complications resulting from prolonged drug use. He reports having little ability to control the effect that drugs are having on his life. With this level of problems it is increasingly likely that his history of drug dependence and withdrawal symptoms may play an important role in the present clinical picture and his history of criminal behavior. The Defendant reports that his use of alcohol has had a negative impact on his life to an extent that is higher than average even among individuals in treatment for alcohol problems. Such a pattern indicates that his use of alcohol has had a number of adverse consequences on his life. Numerous alcoholrelated problems are probable, including difficulties in interpersonal relationships, difficulties on the job, and possible health complications. He is likely 4

5 to have been unable to cut down on his drinking despite repeated attempts at sobriety. Given this pattern, it is increasingly likely that he was alcoholdependent and has suffered the consequences in terms of physiological signs of withdrawal, lost employment, strained family relationships, and financial hardship. The Defendant describes numerous problematic personality traits of a severity uncommon even in clinical samples. This pattern is typically associated with personality functioning within the borderline range, and such individuals are often presenting in a state of crisis. He reports problems of many different types. He is likely to be quite emotionally labile, manifesting fairly rapid and extreme mood swings and, in particular, probably experiences episodes of poorly controlled anger. He appears uncertain about major life issues and has little sense of direction or purpose in his life as it currently stands. It is likely that he has a history of involvement in intense and volatile relationships and tends to be preoccupied with consistent fears of being abandoned or rejected by those around him. He is also quite impulsive and prone to behaviors likely to be selfharmful or self-destructive, such as those involving spending, sex, and/or substance abuse; he may also be at increased risk for self-mutilation or suicidal behavior. This pattern of behaviors is consistent with a diagnosis of Borderline Personality Disorder. It is also consistent with known indicators of executive and frontal lobe brain pathology. With respect to suicidal ideation, the Defendant reports experiencing intense and recurrent suicidal thoughts at a level typical of individuals placed on suicide precautions. The potential for suicide should be evaluated immediately and appropriate interventions should be implemented without delay. Furthermore, concerns about his potential for suicide are heightened by the presence of a number of features, such as situational stresses, poor impulse control, and a lack of social support, that have been found to be associated with suicide risk. With respect to anger management, the pattern of responses suggests considerable problems with temper and aggressive behavior. Such behaviors are likely play a prominent role in the clinical picture. His responses suggest that he is an individual who is easily angered, has difficulty controlling the expression of his anger, and is perceived by others as having a hostile, angry temperament. He is not intimidated by confrontation and he will tend to display his anger readily when it is experienced; he may be verbally aggressive at relatively low levels of provocation. More extreme displays of anger, including damage to property and threats to assault others, would not be unexpected. It is likely that those around him are intimidated by his temper and the potential for verbal abuse or displays of physical violence. It should also be noted that his risk for aggressive behavior is further exacerbated by the presence of a number of features, such as agitation, a limited capacity for empathy, and affective 5

6 lability, that have been found to be associated with increased potential for violence. The Defendant describes a personality style with numerous antisocial character features to a degree that is unusual even in clinical samples. Such a pattern is typically associated with prominent features of Antisocial Personality Disorder; he is likely to be unreliable and irresponsible and has probably sustained little success in either the social or occupational realm. His responses suggest that he has a history of antisocial behavior and may have manifested a conduct disorder during adolescence. He may have been involved in illegal occupations or engaged in criminal acts involving theft, destruction of property, and physical aggression toward others. His behavior is also likely to be reckless and impulsive; he can be expected to entertain risks that are potentially dangerous to himself and to those around him. The Defendant reports a number of difficulties consistent with a significant depressive experience. He is likely to be plagued by thoughts of worthlessness, hopelessness, and personal failure. He admits openly to feelings of sadness, a loss of interest in normal activities, and a loss of sense of pleasure in things that were previously enjoyed. He is likely to show a disturbance in sleep pattern, a decrease in level of energy and sexual interest, and a loss of appetite and/or weight. Psychomotor slowing might also be expected. He also demonstrates an unusual degree of concern about physical functioning and health matters and probable impairment arising from somatic symptoms. He is likely to report that his daily functioning has been compromised by numerous and varied physical problems. He feels that his health is not as good as that of his age peers and likely believes that his health problems are complex and difficult to treat successfully. Physical complaints are likely to include symptoms of distress in several biological systems, including the neurological, gastrointestinal, and musculoskeletal systems. The item endorsement pattern indicates that he reports symptoms consistent with both conversion and somatization disorders. He is likely to be continuously concerned with his health status and physical problems. His social interactions and conversations tend to focus on his health problems, and his self-image may be largely influenced by a belief that he is handicapped by his poor health. A number of aspects of the Defendant s self-description suggest noteworthy peculiarities in thinking and experience. He is likely to be a socially isolated individual who has few interpersonal relationships that could be described as close and warm. He may have limited social skills, with particular difficulty interpreting the normal nuances of interpersonal behavior that provide the meaning to personal relationships. His social isolation and detachment may serve to decrease a sense of discomfort that interpersonal contact fosters. His thought processes are likely to be marked by confusion, distractibility, and 6

7 difficulty concentrating and he may experience his thoughts as being somehow blocked or disrupted. However, active psychotic symptoms such as hallucinations or delusions do not appear to be a prominent part of the clinical picture at this time. The Defendant indicates that he is experiencing specific fears or anxiety surrounding some situations. The pattern of responses reveals that he is likely to display significant symptoms related to traumatic stress. He has likely experienced a disturbing traumatic event in the past-an event that continues to distress him and produce recurrent episodes of anxiety. Whereas the item content of the PAI does not address specific causes of traumatic stress, possible traumatic events involve victimization (e.g., rape, abuse), combat experiences, life-threatening accidents, and natural disasters. The Defendant mentions that he is experiencing some degree of anxiety and stress; this degree of worry and sensitivity is still within what would be considered the normal range. Additionally, the Defendant describes certain problems potentially associated with elevated and variable mood. His relationships with others are probably under stress, due to his frustration with the inability or unwillingness of those around him to keep up with his plans and possibly unrealistic ideas. At its extreme, this irritability may result in accusations that significant others are attempting to thwart his plans for success and achievement. He describes himself as being more wary and sensitive in interpersonal relationships than the average adult. Others are likely to see him as tough-minded, skeptical, and somewhat hostile. The self-concept of the Defendant appears to be poorly established and his attitude about himself is likely to fluctuate. His self-perception will vary from states of harsh self-criticism and severe self-doubt to periods of relative selfconfidence and intact self-esteem. His self-perception will tend to vary as a function of the current status of close relationships; apart from a sense of identity established from such relationships, he likely feels incomplete, unfulfilled, and inadequate. As a result, his self-esteem is quite fragile and is likely to plummet in response to slights or oversights by other people. Associated with these drops in self-esteem are corresponding shifts in identity and attitudes about major life issues. The Defendant s interpersonal style seems best characterized as exploitative and egocentric. He is likely to view relationships more as an opportunity for selfenhancement rather than as a source of enjoyment. As a result, his relationships are likely to be pragmatic and he likely takes more from them than he gives. He is probably quite competitive in relationships; he tends to be skeptical of close attachments and he will tend to avoid commitment, perhaps viewing it as a sign of dependency or weakness. He is not one to forgive a social slight and may have a reputation as someone who nurtures a grudge. In considering the social environment of the Defendant with respect to perceived stressors and the 7

8 availability of social supports with which to deal with these stressors, his responses indicate that he is likely to be experiencing notable stress and turmoil in a number of major life areas. He may have relatively few close relationships or be dissatisfied with the quality of these relationships. With respect to DSM diagnostic considerations, the PAI results suggest the following possible diagnoses: Axis I Diagnostic Considerations: Alcohol Dependence Other (or Unknown) Substance Dependence (Psychoactive substance dependence) Major Depressive Disorder, Single Episode, Unspecified Posttraumatic Stress Disorder Bipolar II Disorder Undifferentiated Somatoform Disorder Axis II Diagnostic Considerations: Borderline Personality Disorder Antisocial Personality Disorder 8

9 PAI, Full Scale Profile 9

10 PAI, Subscale Profile 10

11 CNS-VITAL SIGNS (CNS-VS)- CNS-VS is a multimodal clinical assessment that includes both appropriate neurocognitive tests and evidence based symptom, behavioral and functional rating scales. The battery employs standardized measures to evaluate psychological and neuropsychological performance and functioning relative to normative data. CNS-VS yields consistent and accurate measurement of minute cognitive changes, such as those associated with drug effects and cognitive impairments. The results of the Defendant s performance on the CNS-VS can be seen in the following table. His scores on Composite and Visual Memory are considered to be in the Above range and his Verbal Memory and Processing Speed are in the Average range. Psychomotor speed and Social Acuity are deemed to be in the Low Average range. His abilities on the Reasoning, Reaction Time, Working Memory and Sustained Attention domains are in the Low range and Executive Function, Complex Attention and Cognitive Flexibility are in the Very Low range. Defendant s overall Neurocognition Index (NCI) is considered to be Very Low. This degree of variability across domain scores is quite unusual. It is rare to see individuals with scores ranging from the 1 st to the 86 th percentiles. The pattern of discrepancies, moreover, is one associated with frontal lobe deficits and/or pathology: working memory, executive functioning, and cognitive flexibility are all strongly associated with frontal lobe functioning. In combination with the other results in this report, a consistent pattern emerges of an individual who has severe frontal lobe dysfunction, damage and pathology. This is highly relevant, as the frontal lobes are also associated with the ability to control impulses, to understand the consequences of one s actions, and to see the world from another individual s point of view. CNS-VS, Patient Profile 11

12 Weschler Adult Intelligence Scale-III (WAIS-III)- The WAIS is a general test of intelligence which provides information on Verbal Comprehension, Perceptual Reasoning, Working Memory, Processing Speed, and General Ability to identify general cognitive ability. The Defendant s scores on the WAIS-II can be seen in the following tables and graphs. The results of his performance on the WAIS-II can be seen in the following tables. All his IQ scores are in the Average range: Performance IQ = 91 (95% Conf. Interval = 58 to 98), which has a Percentile Rank of 27. His Verbal IQ = 106 (95% Conf. Interval = 101 to 111) which is associated with the 66 th percentile, and his Full Scale IQ = 100 (95% Conf. Interval = 96 to 104), Percentile Rank 0f 50%. The scores for Perceptual Organization are in the 21 st percentile (Index Score = 88). Scores for Processing Speed are in the 32 nd percentile (Index Score = 93) while Defendantscored at the 79 th percentile in Verbal Comprehension (Index Score = 112). Finally, his scores for Working Memory place him in the 42 nd percentile (Index Score = 97). Although these scores fall within the normal range, there is considerable variability between domains (see below). Importantly, the Defendant s IQ scores show significant discrepancies between domain scores. The second Table below, WAIS IQ and Index Differences, shows that the discrepancies between his verbal and performance subtest measures are statistically significant for 4 out of 7 comparisons and all significant differences are between subtests in the verbal vs. the performance domains. Such a discrepancy is considered definitive for a nonverbal learning and/or executive functioning disorder. Moreover, this type of learning disorder is commonly associated with organic brain damage. His Verbal and Performance IQ scores are considered to be Average as well as his Full Scale IQ. His index scores show Verbal Comprehension to be in the 79 th percentile. Working Memory is deemed to be in the 42 nd percentile and Processing Speed is in the 32 nd percentile. Perceptual Organization is shown to be Defendant s strongest weakness, at the 21 st percentile, when compared to a database of his peers. In summary, although the Defendant s IQ scores fall within the normal range, there are broad and significant discrepancies across functional domains that imply some level of organic brain pathology. 12

13 WAIS, Scores Summary WAIS, IQ and Index Differences 13

14 Woodcock Johnson-III (WJ-III)- The WJ-III provides a comprehensive system for measuring general intellectual ability, specific cognitive abilities, scholastic aptitude, oral language, and academic achievement. The Defendant s abilities as tested by the WJ-II can be seen in the following tables and graphs. He scored Limited on his ability to perform broad Reading, Academic Skills, Letter-Word Identification, Spelling, and Writing Fluency. Scores on Broad Written Language, Academic Fluency, Written Expression Reading Fluency, Math Fluency, and Written Samples came in at the Limited to Average range. All other scores are deemed to be in the Average range. THE Defendant s overall Total Achievement is considered to be in the Limited to Average range. Defendant s abilities are measured to be those of an individual with substantially less education than is claimed by the defendant, or by any normal adult with even a high school education. In addition, as with the WAIS, there is quite broad variability across academic achievement domains. Although some of this may be related to his history of polysubstance abuse, much may also be related to his history of multiple and successive concussions and traumatic brain injuries sustained while playing football in high school. 14

15 WJ-III, Age Band Profile 15

16 WJ-III, Summary Report 16

17 Quantitative EEG Study (qeeg). qeeg is a scientifically established method for evaluating brain function based on mapping the brain s electrical activity. In this form of functional brain imaging, the brain's electrical activity, as measured in 19 to 25 sites on the scalp, is analyzed using complex mathematical and statistical tools in comparison to published and FDA registered norms or averages. These norms are based on the electrical activity of thousands of individuals from several populations. The largest subset of qeeg norms, used for all comparisons other than the discriminant functions, are derived from individuals with no known neurological, developmental, or psychiatric disorder. Other subsets (those used for the discriminant function analyses) are based on individuals with a known history and established diagnosis of traumatic brain injury or documented learning disability. This method of assessing brain function provides information about patterns of brain activation and communication that can then be related to difficulties in daily life functioning such as problems with attention, anxiety, mood, learning, executive functioning or violent behavior. For a broader discussion, we direct the reader to or, for a more detailed publication, to Data were collected under Judge s ex parte order at Hillsborough County Jail Falkenberg Road Facility, Tampa, FL and in the presence of Carolyn Fulgeria, Mitigation Specialist with the Hillsborough County Public Defender s Office. Quantitative EEG Study QEEG Information & Methodology QEEG Client#: QEEG Date: 05/14/2012 Conditions tested: Eyes closed and Eyes open Report Date: 05/30/2012 QEEG Acquired Location: Hillsborough County Jail Falkenberg Road Facility, Tampa, FL. Analysis and Recommendations by: William A. Lambos, Ph.D., BCIA-EEG Reference Database(s) used: NeuroGuide v QEEG Analysis: # Q1 A 19-channel electrode cap with leads placed according to the International System was applied to achieve a standardized 19 channel EEG recording. The recording amplifier used was a Deymed Medical Systems Model TruScan 17

18 32, using associated software from Deymed. A referential montage was used with linked earlobes. Electrode impedance of less than 15K Ohms was acquired at all sites prior to the initiation of recording. EEG signals were digitized 128 samples per second with a high pass at 1 Hz and low pass at 70 Hz. The client underwent a series of standardized tests, each lasting approximately 4 minutes, which included one run each of 1) eyes closed at rest awake, and 2) eyes open rest. EEG data were subjected to manual and automatic artifact detection algorithms that identified noncerebral sources of input such as ocular, muscular, and equipment-related artifact. This was supplemented by a manual review of the record for removal of residual undetected artifact. Spectral analysis using fast Fourier transformation on this uncorrupted EEG data were evaluated using a variety of descriptive and statistical displays including data tables, spectral maps, topometrics, topographic maps, and network brain maps. Statistical analysis compared client data to an age-appropriate FDA-registered normative database corrected for significant state variations and transitions. QEEG Results Raw Tracings, Power Frequency Distribution and Z-Score Frequency Distribution: See Figures 1a-1d. Figures 1a and 1b each show a raw wave sample, a spectral distribution of the absolute power in the EEG epochs included in the analysis (upper right panel), and the z-scored spectral distribution (lower right panel), which compares the spectral distribution to the reference population norms. Figure 1a shows the linked ear montage, and Figure 1b presents the same raw data analyzed in the Laplacian montage. The linked ear (LE) montage compares the EEG measured on the scalp to the electrical activity measured at the earlobes, subtracting all common electrical signals from ear lobes (so-called common mode rejection analysis), and is the standard montage used in qeeg analysis. The Laplacian (LAP) montage is another standard of EEG analysis, but one designed to enhance localization, by sensor, of the same scalp-derived EEG signal. In the Laplacian montage, the signal for each sensor is compared to the signals generated by the surrounding sensors, subtracting the signal of these sensors such that the closer each sensor is to the individual sensor (for each channel), the more heavily its common signal is weighted in the subtraction algorithm. Thus the Laplacian montage isolates the contribution of each individual sensor channel and gives a better rendering of what location in the brain is contributing to each channel than does the linked ear montage. The important point is that the Laplacian montage increases localization of EEG findings to each individual sensor site, and thus allows better inferences as to the underlying location in the cortex that is generating the signal at each site. When attempting to correlate brain function or disregulation to known symptoms, the Laplacian montage can often add information of significance. 18

19 Raw wave morphology appears to be free of epileptiform activity or paroxysms. However, there is notable artifact from cardiac ballast (heartbeat artifact) throughout both recordings. None of this artifact was used in this analysis. The linked ears recording montage shows a defined dominant frequency peak, however, not as defined as would be expected in neurotypical individuals. Amplitudes, for both montages, are significantly above the normative population throughout the beta frequency range. Elevations in amplitudes are seen at frontal and central sites. Z-Scored FFT Summary Information: See Figures 2a-2i. These figures are brain maps plotted with sensor placements distributed over the scalp as they were measured. In Figures 2a and 2b, absolute EEG spectral power by single Hertz frequency is shown for every sensor site. Figures 2a and 2b show the Z-scored power for the Linked Ear and Laplacian montages (respectively) for the defendant. Figure 2c shows the same z-scored data for a neurotypical subject. All data are relative to the reference database population. Any areas or lines with blue coloration reflect lower power or connectivity relative to the norm, whereas areas colored in red reflect excess power or connectivity relative to the expected values. For the Defendant, the linked ears absolute power maps show excess beta range amplitudes at a number of anterior, central and posterior sites. The linked ears montage shows the power excess in the low beta range to be highly aberrant to a statistically significant degree at over half the sites on the scalp at the fronto-central sites. The Laplacian montage shows the beta excess to be significant at central sites from 13 Hz to 30 Hz. The Laplacian montage also shows excess delta power at right temporal sites. It should be noted that the additional localization seen in the Laplacian montage shows a degree of aberration, at central sites, from the reference norms that is quite severe, and well beyond that seen in the linked ears montage. With respect to connectivity measures, amplitude asymmetry and phase lag disregulation is seen in nearly every frequency bandwidth. Hypocoherence is clinically significant in every frequency band, however most notably in the delta, theta and beta bands, where disregulation (hypocoherence) occurs across the whole cortex and is significant between nearly every electrode pair. Hypercoherence is also evinced in the beta (15 Hz- 18 Hz) band at several electrode pairs. LORETA Source Localization Analysis: See Figures 3a-3j and 4a-4b. LORETA is an acronym for Low Resolution Electromagnetic Tomography Analysis. It uses an inverse mathematical algorithm to determine the source of EEG signals within 19

20 the brain based on EEG measured at the scalp. In that sense, it functions much like GPS systems in cars. Each LORETA figure shows a slice view, followed by a 3D image of disregulation. The cingulate gyrus, a structure within the limbic system, shows excess current source density measures at 11 and 14 Hz. Also a structure in the limbic system, the parahippocampal gyrus shows excess current source density measures at 28 Hz. Additionally the right inferior temporal gyrus shows hyperactivation at 2 Hz and the middle frontal gyrus shows hyperactivation at 10 Hz. Summary of Results and Impression The Defendant s clinical interview and personality assessment reveal an individual with profound problems and strong evidence of serious psychopathology. He meets the diagnostic criteria for PTSD, Bipolar Disorder, Antisocial Personality Disorder, and Borderline Personality Disorder, among other DSM-IV-TR criteria. The Defendant claims to have completed high school and also to have accumulated many college credits. However, his academic achievement scores show a much lower level than would be expected of someone with this level of education. His assessment on the neurocognitive battery show extreme variability across functional domains. On the intelligence and achievement batteries, he is also consistent in showing a significant discrepancy in functioning between neuropsychological domains. This is true of every measure of assessment of neurocognitive functioning. Such a discrepancy is considered definitive for a learning disorder, and one that is commonly associated with organic brain damage. The brain mapping study of the Defendant reveals this defendant to have a highly abnormal qeeg. The analysis shows extreme abnormalities in qeeg metrics of surface power, connectivity among and between brain areas, and current source density, all when compared to the neurotypical reference population. This defendant s brain damage is entirely consistent with acquired brain injuries obtained from multiple sources. There is evidence of both trauma and substance-related cortical damage. 20

21 Such brain damage renders the victim incapable of the same ability as a neurotypical (undamaged) person to control impulses, understand the consequences of his actions, or to be able to see the world from another person s point of view. This individual is, with the highest level of probability, severely compromised in these areas of behavioral management and mental functioning. The abnormalities are consistent with a pattern of frontal lobe asymmetry and anterior-posterior disconnection typical of several brain pathologies, but in this case most consistent with severe bipolar disorder (probable type II) and traumatic brain injury of at least mild to moderate severity. The maps are wholly unlikely to evince this degree of disregulation and pathology for reasons of measurement error, artifact (including drug artifact), or other non-cerebral origins. Respectfully submitted and electronically signed. William A. Lambos William A. Lambos, Ph.D.; BCIA-EEG 21

22 Appendix I Figure 1a, Q1, Defendant s FFT Frequency Distribution, Linked Ears Montage, eyes closed Figure 1b, Q1, Defendant s FFT Frequency Distribution, Laplacian Montage, eyes closed 22

23 Figure 1c, Q1, Neurotypical FFT Frequency Distribution, Linked Ears Montage, eyes closed Figure 1d, Q1, Neurotypical FFT Frequency Distribution, Laplacian Montage, eyes closed 23

24 Figure 2a, Q1, Defendant s FFT Absolute Power, Linked Ears Montage, eyes closed 24

25 Figure 2b, Q1, Defendant s FFT Absolute Power, Laplacian Montage, eyes closed 25

26 Figure 2c, qeeg, Neurotypical FFT Absolute Power, Linked Ears, eyes closed 26

27 Figure 2d, Q1, Defendant s Z-scored Amplitude Asymmetry, Linked Ears Montage, eyes closed Figure 2e, qeeg, Neurotypical Z-scored Amplitude Asymmetry, Linked Ears Montage, eyes closed 27

28 Figure 2f, Q1, Defendant s Z-scored Coherence, Linked Ears Montage, eyes closed Figure 2g, qeeg, Neurotypical Z-scored Coherence, Linked Ears Montage, eyes closed 28

29 Figure 2h, Q1, Defendant s Z-scored Phase Lag, Linked Ears Montage, eyes closed Figure 2i, qeeg, Neurotypical Z-scored Phase Lag, Linked Ears Montage, eyes closed 29

30 Figure 3a, Q1, Defendant s 02 Hz, eyes closed Figure 3b, Q1, Defendant s 02 Hz, 3D view, eyes closed 30

31 Figure 3c, Q1, Defendant s 10 Hz, eyes closed Figure 3d, Q1, Defendant s 10 Hz, 3D view, eyes closed 31

32 Figure 3e, Q1, Defendant s 11 Hz, eyes closed Figure 3f, Q1, Defendant s 11 Hz, 3D view, eyes closed 32

33 Figure 3g, Q1, Defendant s 14 Hz, eyes closed Figure 3h, Q1, Defendant s 14 Hz, 3D view, eyes closed 33

34 Figure 3i, Q1, Defendant s 28 Hz, eyes closed Figure 3j, Q1, Defendant s 28 Hz, 3D view, eyes closed 34

35 Figure 4a, Neurotypical 10 Hz, eyes closed Figure 4b, Neurotypical 10 Hz, 3D view, eyes closed 35