The Dhillon Law Group and LiMandri & Jonna LLP, in conjunction with the Center for American Liberty, filed a motion today for leave to add a claim for punitive damages to Chloe Cole’s complaint against the Permanente Medical Group, Kaiser Foundation Hospitals, and the doctors who fraudulently coerced her into a medical gender transition when she was 13-17 years old.

The following comes from the memorandum in support of the motion.

“Chloe’s experience is a perfect example of what happens when social and political ideologies drive medical models of care instead of scientific evidence. When Chloe arrived in June 2017 and said she was transgender, the appropriate medical sequence of events was assumed. There was no gender evaluation.

“A simple request of “Tell me the story” would have unearthed that the origin of her gender dysphoria was feelings of inadequacy about her breast size and the shape of her shoulders and hips. It would have included knowing about how she had been influenced on social media, and what her contacts there had told her. That would have led to a discussion of what she had learned that was valid and what was unreasonable pressure from people who did not know her and likely had their own political interests at heart.

“There was no discussion of core gender identity and how she had felt being a girl up to age 11, prior to online pressure. There was no discussion about gender role behavior and the style of a boy or girl she saw herself as. There was no discussion about her awareness of her own sexuality. Since she
sees herself as androphilic, a discussion of the experience of transmen in the gay
male community would have been appropriate.

“Instead, the moment she said she was transgender, it was assumed that no further evaluation was necessary. There is no evidence that the person she saw for her first evaluation (Dr. Asulyan) had any experience in evaluating transgender children or adolescents, and her clinical notes would indicate she
didn’t. She simply put Chloe on a medical conveyor belt, and before the next session had already made an inquiry about an appointment for Chloe for evaluation for puberty blockers and hormones.

“The first time Chloe saw a true gender specialist, Dr. Watson, was for the evaluation of appropriateness for mastectomy in July 2019. Dr. Watson saw the changes Chloe had made, and that she had been
living as male. Dr. Watson did not know or question that the original diagnosis was
made by Chloe, not a gender specialist following a careful evaluation.

“As an institution, Kaiser is well aware of that there are serious risks and critical knowledge
gaps in this area. In Dec. 2017, Kaiser published a study of 6456 transgender patients at Kaiser
from 2006 to 2014, in which Kaiser admits as follows: “Critical knowledge gaps include the effect
of HT [hormone therapy] and surgery on gender dysphoria (the feeling of distress when natal sex
does not match gender identity) and other mental health issues, hematological side effects of HT
and risk of cardiovascular disease, metabolic or endocrine disorders and cancer following hormonal
or surgical gender affirmation.”

“Despite being well aware of and publishing a study identifying these critical risks and knowledge gaps, Kaiser follows a policy of doing whatever the patient asks in this area without disclosing any of these risks….”

From the Center for American Liberty