Gage Declaration

Filed: 04/25/2025 09:10:05 Fourth Judicial District, Ada County Trent Tripple, Clerk of the Court
By: Deputy Clerk-Waters, Renee
LATAH COUNTY PROSECUTOR'S OFFICE

WILLIAM W. THOMPSON, JR., ISB No, 2613
PROSECUTING ATTORNEY

ASHLEY S. JENNINGS, ISB No. 8491
SENIOR DEPUTY PROSECUTING ATTORNEY

JOSHUA D. HURWIT, ISB No. 9527
SPECIAL DEPUTY PROSECUTING ATTORNEY

Latah County Courthouse P.O. Box 8068 Moscow, ID 83843
Phone: (208) 883-2246 ISB No. 2613 paservice@latahcountyid.gov
IN THE DISTRICT COURT OF THE FOURTH JUDICIAL DISTRICT OF

THE STATE OF IDAHO, IN AND FOR THE COUNTY OF ADA

STATE OF IDAHO, Case No. CR01-24-31665 Plaintiff,
DECLARATION OF JASON D.

V. GAGE, PH.D.

BRYAN C. KOHBERGER, Filed Under Seal Defendant.

COMES NOW Jason D. Gage, Ph.D., who declares and represents the following in support of the State's Motion for an Examination of Defendant Pursuant to Idaho Code § 18-207 and for Motion for an Extension of Time to Complete Rebuttal Penalty Phase Expert Disclosures:
1. I received my Ph.D. in Clinical Psychology from Utah State University in 2002.

Throughout graduate school, my primary focus was neurodevelopmental conditions such as ADHD and autism. I then joined the Army and completed my internship at Tripler Army Medical Center where my primary focus was neuropsychology. Following my internship, I served as the DECLARATION OF JASON D. GAGE, Ph.D. 1

Chief of Mental Health Services at Fort Lee, VA. I then continued military service at Mountain Home Air Force Base for two years as a civilian psychologist. Since 2008, I have specialized in neuropsychology and worked in private practice at Mountain States Counseling and Psychological Services. I previously worked on a brain injury team at St. Alphonsus Rehabilitation Services from 2008 until 2022. My current interests and specialties include traumatic brain injuries, aeromedical psychology, PTSD, and ADHD / autism. I am currently completing approximately three neuropsychological evaluations for adult ADHD and / or adult autism per week.

2. Attached hereto as Exhibit S-5 is my curriculum vitae.

3. I have been engaged by the Latah County Prosecuting Attorney's Office to evaluate the reports of Defendant's expert witnesses that relate to my professional field and to conduct a neuropsychological examination of Defendant.

4. In my professional opinion, including broader testing of personality and psychopathology is important for several reasons. First, these tests contain the most sensitive symptom validity measures that help determine if the examinee is reporting information in a consistent and reliable manner without significant over-reporting (exaggeration) or underreporting (defensiveness). In her evaluation of Defendant, it does not appear that Dr. Rachel Orr, PsyD, ABPP-CN, administered any tests that formally evaluate symptom validity to this level.

These validity measures help ensure that the results of other self-report measures that do not contain validity scales are valid. Second, not only is it important to rule in diagnoses such as those that have already been diagnosed, but also to rule out diagnoses that could account for the same symptom presentation. The diagnostic criterion for many disorders includes that the symptoms are not attributed to, or are not better accounted for, by another condition. Therefore, ruling out DECLARATION OF JASON D. GAGE, Ph.D. 2

those conditions is important. Third, with autism specifically, there are certain personality characteristics that are common and supportive of that diagnosis. Obtaining information about those characteristics helps ensure a proper diagnosis. The battery of testing that I propose would be significantly less than the testing battery already completed by Dr. Orr. The battery would serve to supplement the battery that Dr. Orr completed and provide some additional valuable information. In my professional judgment, I would not administer the Hare PCL-R that is discussed in the report of defense expert John F. Edens, Ph.D.

5. In my professional opinion, it is inappropriate for several reasons to have any third parties in the room during my examination of defendant, even defendant's attorney. First, the normative population that the defendant is compared to consists of individuals who completed testing one-on-one with an examiner without a third party in the room with them. Second, additional people can serve as a distraction and affect the validity of the results. Some tests can only be given once since the defendant will start to learn the answers. If distractions occur and that test has to be prematurely terminated, that data will no longer be valid. Third, test security is of paramount importance as these testing measures influence decisions about public safety in many settings. Section 9.11 of the American Psychological Association ethics code states “ Psychologists make reasonable efforts to maintain the integrity and security of test materials and other assessment techniques consistent with law and contractual obligations, and in a manner that permits adherence to this Ethics Code. ” Having third party individuals present who do not need to know all of the questions and answers jeopardizes test security for psychologists in the future. This is one reason why raw data is only ethically transferred between psychologists.

6. I have conducted at least three mental examinations of defendants in criminal cases, DECLARATION OF JASON D. GAGE, Ph.D. 3

including one murder case. I have also conducted many examinations of plaintiffs and defendants in civil cases. In these examinations, attorneys have never been present.

7. On April 18, 2025, Dr. Orr, contacted me to provide the results from her neuropsychological testing of Defendant. I received those materials on April 19, 2025.

8. When I spoke with Dr. Orr, I inquired if any of Defendant's attorneys had been present in the room during her examination of Defendant. She told me that they were not.

I declare under penalty of perjury pursuant to the law of the State of Idaho that the foregoing is true and correct.

RESPECTFULLY SUBMITTED this 25 day of April, 2025.

SigPlus 1
04/25/2025 07:44:58 am JASON D. GAGE, Ph.D.

DECLARATION OF JASON D. GAGE, Ph.D. 4

CERTIFICATE OF DELIVERY

I hereby certify that true and correct copies of the DECLARATION OF JASON D. GAGE, Ph.D. were served on the following in the manner indicated below:
Anne Taylor Mailed Attorney at Law E-filed & Served / E-mailed PO Box 9000 Faxed Coeur D Alene, ID 83816-9000 Hand Delivered Dated this 25 day of April, 2025.

DECLARATION OF JASON D. GAGE, Ph.D. 5

Updated 01/29/2025
CURRICULUM VITAE

Jason D. Gage 3380 W. Americana Terrace, Ste 320; Boise, ID 83706
Work: (208) 375-6402; Fax: (208) 323-1850 jgage@mscps.us
LICENSE AND EDUCATION

01 / 06-Present Idaho State Board of Psychologist Examiners – License # PSY-202302 05 / 04-10 / 06 Alabama Board of Examiners in Psychology – License # 1297 05/02 Ph.D. Combined (Clinical / Counseling / School) Psychology Utah State University (APA Accredited) 05/98 M.S. Clinical Psychology, University of Idaho 05/96 B.S. Psychology, University of Idaho
WORK EXPERIENCE

03 / 08-Present Licensed Psychologist-Private Practitioner Mountain States Counseling and Psychological Services 3380 W. Americana Terrace, Ste. 320; Boise, ID 83706 Work as a private practice psychologist conducting psychological and neuropsychological evaluations for children, adolescents, and adults for a wide array of issues including traumatic brain injuries, dementia, sports concussion management, autism, ADHD / learning disorders, personality, and psychopathology. Conduct clinical and forensic work including evaluations for the FAA (credentialed). Therapy specialties included anxiety, anger, PTSD, and ADHD.

03 / 08-11 / 22 Contract Neuropsychologist Saint Alphonsus Rehabilitation Services (STARS) 717 N. Liberty; Boise, ID 83704 Conducted neuropsychological evaluations and treatment as part of the brain injury and rehabilitation team.

03 / 06-03 / 08 Supervisory Clinical Psychologist Mountain Home Air Force Base; Mountain Home, ID 83648 Served as a contract psychologist and Chief, Reintegration Health. Organized all appropriate medical / psychological screening and follow-up care for troops returning from deployments. In charge of “ Battlemind ” program that involved postdeployment / critical incident debriefings and preventative care for all Security Forces (military police) troops, Explosive Ordinance troops, and those heavily involved in convoys; debriefings completed for 68 troops. Worked with pilots and other special populations (e.g., air traffic control). Conducted fitness for duty evaluations with all populations. Conducted all neuropsychological screening and the majority of psychological assessments for the clinic. Implemented and served as head of child therapy services. Served as a Behavioral Health Consultant in family practice and STATE'S EXHIBIT exhibitsticker.com 1
S-5

CR01-24-31665

Updated 01/29/2025 pediatric clinics providing health psychology interventions and consultation regarding treatment and referrals. Developed and conducted group therapy program for adults with ADHD and related behavioral difficulties. Supervised mental health technicians, social workers, and an unlicensed psychologist. Organized a new outcome assessment program to tracked treatment progress with standardized measures. Consulted with commanders, flight surgeons, primary care, and the ER.

10 / 02-02 / 06 Chief, Community Mental Health Service Kenner Army Health Clinic; Fort Lee, VA 23801 As the sole psychologist for Fort Lee, managed all psychological services provided to a population of approximately 9000 service members. Supervised all mental health technicians and staff. Provided neuropsychological and psychological assessments, therapy, prevention services, consultation to commanders and primary care, training, and served on committees. Treated and supervised treatment of 250-300 patient contacts per month, doubling the standard expected for Army psychologists. Headed all postdeployment and critical incident debriefings to include programs for special populations such as mortuary affairs and military police to include PTSD and concussion related symptomology. Implemented group therapy module for posttraumatic stress. Conducted fitness for duty evaluations. Expanded services and established telepsychiatry program using video teleconference technology to help supplement staff shortage. Implemented coordinated care system among commanders, inpatient / intensive outpatient facilities and CMHS that decreased costs by over $ 500,000 in two years.

06 / 01-07 / 02 Internship in Clinical Psychology -- APA Accredited (2000+ hours) Tripler Army Medical Center; Honolulu, HI 96859 Commissioned and worked as an active-duty officer in the Army. Core experience included outpatient assessment and treatment of adults. Completed multiple rotations in neuropsychology and focused heavily on cognitive and psychological assessment.

Completed rotations in health, and military psychology. Consulted in family practice, inpatient wards, and emergency room.

ADDITIONAL POSITIONS HELD

11 / 12-10 / 20 Chairman & Board Member, Idaho Board of Psychologist Examiners Appointed by the Governor to the licensing board for two terms.

2009-2014 Idaho Psychological Association Served on the continuing education committee.

ADDITIONAL CLINICAL EXPERIENCE

08 / 98-05 / 01 Graduate Assistant Department of Psychology and Center for Persons with Disabilities Utah State University, Logan UT 84322 Completed approximately 2000 clinical hours conducting comprehensive multidisciplinary psychological and neuropsychological assessments with children.

Focused on ADHD, learning disorders, pervasive developmental disorders, and various 2

Updated 01/29/2025 neurological conditions. Conducted therapy with children / adolescents. Received formal training regarding interdisciplinary health care and Americans with Disabilities Act.

08 / 96-05 / 01 Graduate Assistant Department of Psychology and University Counseling Centers University of Idaho and Utah State University Completed approximately 1500 clinical hours conducting therapy and psychological assessment with adults. Performed comprehensive LD and ADHD assessment batteries with adults.

01 / 97-08 / 98 Registered Counselor Wilson Psychological Services, Pullman WA 99163 Performed psychological / neuropsychological testing and counseling in a private practice. Assisted with custody evaluations and pre-employment screenings for police officers. Supervised by Dr. Gregory Wilson.

PROFESSIONAL MANUSCRIPTS AND PRESENTATIONS

Professional Manuscripts Gage, J. D. & Wilson, L. J. (2000). Acceptability of interventions for attention deficit hyperactivity disorder: A comparison of parents. Journal of Attention Disorders, 4 (3), 174-182.

Braun, C. C., Gage, J. D., Booth, C, & Rowe, A. L. (2001). Creating and evaluating alternatives to the 10 standard orders and 18 watch-out situations. International Journal of Cognitive Ergonomics, 5 (1), 23-35.

Professional Presentations Gage, J. D. (4/27/18). Idaho Board of Psychologist Examiners: Legislation and Laws Update.

Idaho Psychological Association. Meridian, ID.

Gage, J. D. & Holley, H. (4/28/17). Idaho Rules and Ethics: Review of Two New Licensure Rules and Details on Prescription Privileges Law. Idaho Psychological Association. McCall, ID.

Gage, J. D. (2/4/2017). Neuropsychological Assessment for Cognitive Deficits and Pain in Forensic Settings. Idaho Trial Lawyers Association, Boise, ID.

Gage, J. D. (7/29/17). Recognizing Post-Concussion Risk Factors. Idaho Athletic Trainers ' Association, Boise, ID.

Gage, J. D. with Board of Psychologist Examiners (4/22/16). Update on Telepsychology and Service Extenders. Idaho Psychological Association, Sun Valley, ID.

Gage, J. D. with Board of Psychologist Examiners (4/25/15). Interpreting Dual Relationships:
What would you do? Idaho Psychological Association, Sun Valley, ID.

3

Updated 01/29/2025 Gage, J. D. with Board of Psychologist Examiners (5/3/14). Continuing Education Rules for Psychologists Licensed in Idaho. Idaho Psychological Association, Boise, ID.

Gage, J. D. (3/11/14). How to Estimate Premorbid Abilities; Saint Alphonsus Rehabilitation Services (In-service presentation). Boise, ID.

Gage, J. D. & Every, D. (5/3/13). What Veterans Wish Their Civilian Providers Knew. Idaho Psychological Association. Sun Valley, ID.

Gage, J. D. (2/12/13). Dealing with the Agitated Patient; Saint Alphonsus Rehabilitation Services (In-service presentation). Boise, ID.

Gage, J. D. " Ask the Neuropsychologist " (11/1/12). Treasure Valley Brain Injury Support Group. Boise, ID.

Gimpel, G. A., Collett, B., Gunderson, T., Gage, J., & Greenson, J. (2001, November).

Predictors of treatment outcome in parent training. Poster to be presented at the international conference, Association for Behavior Analysis, Venice, Italy.

Collett, B. R., Ehrlick, A., Johnson, C., Veeder, M., Burgloff, H., Gunderson, T., Gage, J. D., Jones, T., Gimpel, G. A., & Odell, J. D. (in preparation). Differentiating ADHD subtypes in clinical practice. Poster accepted for presentation at the annual conference of the American Psychological Association (August, 2001). San Francisco, CA.

Gage, J. D. & Tranchita, A. (2000, April). Effectiveness of psychotropic medications for alcohol dependence. Poster session presented at Western Psychological Association, Portland, OR.

Tranchita, A. & Gage, J. D. (2000, April). Effectiveness of brief interventions for alcohol dependence. Poster session presented at Western Psychological Association, Portland, OR.

Gage, J. D. (2000, March). Factors affecting parents ' acceptability of interventions for attention deficit hyperactivity disorder. Paper presented at National Association of School Psychologists, New Orleans, LA.

Gage, J. D. & Tranchita, A. (2000, March). Effectiveness of school-based alcohol / drug prevention programs: A comprehensive review. Paper presented at National Association of School Psychologists, New Orleans, LA.

Gimpel, G. A., Hlavaty, S., Gunderson, T., Gage, J. D., Collett, B., Greenson, J., Rollins, L., & Hoff, K. (2000, March). The use of homework assignments in a parent training program. Poster session presented at National Association of School Psychologists, New Orleans, LA.

Gimpel, G. A., Greenson, J. N., Rollins, L., Collette, B., Hoff, K., Gage, J. D., Gunderson, T., & Hlavaty. (1999, November). Characteristics of child therapy drop-outs at a university training clinic.

Poster session presented at Association for Advancement of Behavior Therapy, Toronto, Ontario.

Roberts, R. N., Morris, C. & Gage, J. D. (1999, June). State, tribal, and parent collaboration in early intervention programs. Poster session presented at 12th Annual Convention of Native American Psychologists and Psychology Graduate Students, Logan, UT.

4

Updated 01/29/2025 Gage, J. D., Wilson, L. J., & Yoder, S. M. (1998, April). Acceptability of interventions for attention deficit hyperactivity disorder: A comparison of parents.

Poster session presented at Rocky Mountain Psychological Association-Western Psychological Association, Albuquerque, NM.

Wilson, L. J., Gage, J. D., & Greenson, J. N. (1997, April). Sexual victimization, coping strategies, and psychopathology among male college students. Poster session presented at Western Psychological Association, Seattle, WA.

Greenson, J. N., Gage, J. D., & Wilson, L. J. (1997, April). Adult survivors of childhood sexual abuse: Acceptability of partners in treatment. Poster session presented at Western Psychological Association, Seattle, WA.

Braun, C. C., Glusker, S. & Gage, J. D. (1996, April). Engineering information requirements for high stress work environments. Poster session presented at American Psychological Association, Toronto, Ontario.

ADDITIONAL RESEARCH EXPERIENCE

08 / 98-05 / 00 Parents ' and Teachers ' Acceptability of Treatments for Attention-Deficit Hyperactivity
Disorder: Effects of Presentation and Information Delivery Department of Psychology, Utah State University (Dissertation) --Examined the effects of providing parents and teachers with treatment rationales and a behavior therapy model to increase their acceptability of treatment options for ADHD.

08 / 98-05 / 00 Opening Doors into Rural Communities Monitoring and Measuring Community-Based Systems of Care Early Intervention Research Institute, Utah State University Completed approximately 1500 clinical hours conducting outcome assessment and research of home and community-based early interventions.

08 / 96-05 / 98 Acceptability of Interventions for Attention-Deficit Hyperactivity Disorder: A Comparison of Parents Department of Psychology, University of Idaho (Thesis) --Evaluated differences in parents ' acceptability of treatments for ADHD. Compared three treatments and differences between parents of children with and without ADHD.

TEACHING EXPERIENCE

08 / 96-05 / 99 Taught undergraduate courses in introductory psychology and research methods. Served as a teaching assistant for nine additional courses including perception and psychophysics, psychometrics, advanced research methods / statistics (graduate course), psychology of aging, abnormal psychology, psychology of emotion, and engineering psychology.

SPECIALITY TRAINING

9 / 2018-Present Trained in CogScreen and HIMS programs; credentialed for completing FAA neuropsychological and psychological evaluations.

5

Updated 01/29/2025 2008 Credentialed ImPACT Consultant for concussion management.

2001-2008 Completed approximately 25 quarterly trainings regarding Critical Incident Stress Debriefings / Critical Event Debriefings through the US Army and Air Force. Also completed additional training on this topic at the Officer Basic Course.

10 / 02-10 / 02 Graduated Aeromedical Psychology Training Course; a thre