Farley affidavit April 08.pdf - Myweb.dal.ca

BETWEEN:
Form 4D - AFFIDAVIT
Rules of Civil Procedure (Rule 4.06)
ONTARIO
SUPERIOR GOURT OF JUSTICE
07-cv-329807PD1
TERRI JEAN BEDFORD, AMY LEBOVITCH, VALERIE SGOTT
and
ATTORNEY GENERAL OF GANADA
AFFIDAVIT OF DR. MELISSA FARLEY
Applicants
Respondent
l, Melissa Farley, of the City of San Francisco, in the State of California,
United States, make oath and say:
OVERVIEW OF MY AFFIDAVIT
1. The purpose of my affidavit is to describe, on the basis of my 40 years of
research and practice as a clinical psychologist, the conclusions that I have
reached on the harmful effects that prostitution has on the physical and
psychological health of women that are engaged in it.

OVERVIEW OF MY EXPERTISE
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2. I have worked as a research and clinical psychologist
in practice
for 40
years. From 1993-2000, I was a principal investigator on research grants at a
large health care system in the US where I collaborated with a team of researchers
studying the long term effects of violence against women on their health and how
that violence impacts preventive health care for women. Several peer-reviewed
publications have resulted from this work. Attached to this my affidavit as Exhibit
"A"
is a copy of my curriculum vitae
3. My opinion is based on my years in practice as a research and clinical
psychologist, on study of and expert testimony on the topic of sexual exploitation,
posttraumatic stress disorder ('PTSD'), and prostitution. I have consulted with and
presented workshops and seminars for universities, governmental agencies, and
community groups addressing prostitution.
4. My opinion is based on approximately 900 interviews with women, girls,
men, boys, and transgendered people in prostitution in 10 countries. My opinion is
also based on several hundred interviews with johns. Most of what I have learned
about prostitution
is a result of talking with these people in depth about their
experiences.
5. I am currently on the editorial board of the Journal of Psychological Trauma.
I also review articles on prostitution and trafficking for governmental and
nongovernmental agencies. I review articles submitted for publication on the topic
of prostitution and tnafficking for other peer reviewed journals such as Violence
against Women, lnterpersonal Violence, AIDS Care, Women and Criminal Justice,
and British Medical Journal.

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6. I am an associate scholar with the Center for World lndigenous Studies,
located just south of Vancouver in Olympia, Washington.
7. Since 1995, my work has focused on research which has contributed to a
greater knowledge of prostitution and sex trafficking. As a result of my research
and collaborations with other researchers, I have published 17 peer-reviewed
articles on prostitution, and an additional12 peer reviewed articles on related
topics.
8. I am the Executive Director of Prostitution Research & Education, a nonprofit
organization that is dedicated to providing educational resources and information
about prostitution and trafficking to survivors of prostitution, law enforcement
personneljudges, mental health professionals, college and high school and
graduate students, governmental agencies, and the public. Our website,
www.prostitutionresearch.com, receives about 50,000 page views per month. The
organization is funded by private foundations, research grants and individual
donors.
9. I have provided testimony on prostitution to the governments of South Africa
and New Zealand. My research has been used by other governments as they
grapple with prostitution policy, including the government of lsrael. I recently
(2007) provided a research report to the U.S. government in a Congressional
Hearing on prostitution and trafficking in Nevada. The research was produced for
the Trafficking in Persons Office of the U.S. State Department.
10. In my affidavit, based principally on my own research and that of other
experts in the field of prostitution, I shall address the following:
o the links between prostitution and violence, in different cultural contexts,
different countries, and in cl,ifferent physical locations (indoor and outdoor

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prostitution), in illegal and legal contexts;
o the relation of childhood sexual abuse and childhood physical abuse to later
prostitution;
e the fact that most women in prostitution want to escape it, regardless of
prostitution's location or legal status;
o the extremely high HIV risk and other health risks posed by prostitution,
regardless of its legal status or physical location;
. the psychological consequences of prostitution, specifically posttraumatic
stress disorder (PTSD) and dissociation;
o the ways that prostitution damages women's sexuality;
. verbal abuse and the use of drugs and alcohol as a defense against the
emotional abuse and the physical pain of prostitution;
o prostitution more severely harms indigenous women because of their
economic vulnerability, because of social and legal discrimination against
them, and because of their lack of alternatives;
. the pervasiveness of pimps in all prostitution, and their violence against
prostituted women;
r the bond/ relationship between pimp and prostitute as similar to that between
batterer and that between batterer and a battered partner;
o the mistaken assumption that women in prostitution are always located either
outdoors or indoors;
. that johns pose serious threats of physical and emotional violence to women
in prostitution, and present some new data on johns in Scotland;
. that legalization does not reduce the stigma of prostitution, using examples
from Nevada and elsewhere, and that legal prostitution has not been shown
to make prostitution safer than illegal prostitution;
o that pimps use means to control the women who work for them as victims.,
using methods that are similar to those used by torturers;

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o the reasons why prostitution cannot be considered a free choice in the usual
meaning of that word;
o that recent research in Scotland has revealed that there is a statistical
correlation between men's purchase of sex and their sexually violent
behaviors toward wives and girlfriends; and
. finally, some of the assertions by Dr. John Lowman in his affidavit.
11. My expert opinion is based in part on the following research. Additional
sources are footnoted in the body of my affidavit:
o Farley, M., Cotton, A., Lynne, J., Zumbeck, S., Spiwak, F., Reyes, M.E.,
Alvarez, D., Sezgin, U. (2003) Prostitution and Trafficking in 9 Countries:
Update on Violence and Posttraumatic Stress Disorder. Journal of Trauma
Practice 2 Qla):33-74
. Farley, M. (2006) Prostitution, Trafficking, and Cultural Amnesia: What We
Must Nof Know in Order To Keep the Business of Sexual Exploitation Running
Smoothly. Yale Journal of Law and Feminism 18:109-144.
. Farley, M. (2007) Prostitution and Traffickino in Nevada: Makino the
Connections. San Francisco: Prostitution Research and Education.
. Farley, M, Lynne, J, and Cotton, A (2005) Prostitution in Vancouver: Violence
and the Colonization of First Nations Women. Transcultural Psvchiatrv 42:
242-271.
. Farley, M. (2004)
"Bad
for the Body, Bad for the Heart:" Prostitution Harms
Women Even lf Legalized or Decriminalized. Violence Aqainst Womenl0:
1087-1125
. Farley, Melissa (2005) Prostitution Harms Women Even if Indoors.
Violence Aqainst Women 11 (7\:950-964 July 2005
o Farley, M. (2003) Prostitution and the Invisibility of Harm. Women &
Therapy 26(31 4\: 247 -280.
. Farley, M. and Seo, S. (2006) Prostitution and Trafficking in Asia. Harvard
Asia Pacific Review Volume 8 Number 2 pages 9-12

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. Farley, Melissa (2004) Prostitution is Sexual Violence. Psychiatric Times.
October 2004 Special Edition. p7-10
. Farley, M (2003) (Editor) Prostitution. Traffickinq. and Traumatic Stress.
Binghamton, NY: Haworth.
. Farley, M and Kelly, V (2000) Prostitution: a critical review of the medical and
social sciences literature Women & Criminal Justice, 11 (4):29-64.
o Cotton, A, Farley, M and Baron, R (2002) Attitudes toward Prostitution and
Acceptance of Rape Myths. Journal of Applied Social Psycholoqy 32 (9): 1790-
1796.
o Ross, C., Farley, M., & Schwartz, H. (2003) Dissociation among Women in
Prostitution Journal of Trauma Practice 2(3/4).
o Ugarte, M.8., Zarate, L., & Farley, M. (2003) Prostitution and Trafficking of
Women and Children from Mexico to the United States. Journal of Trauma
Practice 2(314\.
Attached as Exhibits
"8"
through to
"O"
are copies of each of these reports or
articles, except that, for my two books ("D" and "K"), only copies of the Table of
Contents are appended.
Vocabulary
12. lt is important for the purposes of this affidavit to define a number of
key terms relating to my research on the psychological harms of prostitution:
a) Diagnosis of posttraumatic
stress disorder ("PTSD")
PTSD encompasses symptoms resulting from traumatic events, including
the trauma of prostitution. PTSD can result when people have experienced
"extreme
traumatic sfressors involving direct personal experience of an
event that involves actual or threatened death or serious injury; or other
threat to one's personal integrity; or witnessing an event that involves death,

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injury, or a threat to the physical
integrity of another person; or learning
about unexpected or violent death, serious harm, or threat of death or injury
experienced by a family member or other c/ose associafe."l PTSD is
characterized by anxiety, depression, insomnia, irritability, flashbacks,
emotional numbing, and hyperalertness. Symptoms are more severe and
longlasting when the stressor is of human design.
Exposure to paid or unpaid sexual violence may result in symptoms of PTSD.
Symptoms are grouped into three categories: 1) traumatic re-experiencing of
events, or flashbacks; 2) avoidance of situations which are reminiscent of the
traumatic events, and a protective emotional numbing of responsiveness; and 3)
autonomic nervous system hyperarousal (such as jittery irritability, being super-
alert or insomnia). The symptoms of PTSD may accumulate over one's lifetime.
PTSD is not only related to the overall number of traumatic events, but it is also
directly related to the severity of that violence.
b) Dissociation
Dissociation is a compartmentalization of memory, a psychological process that
occurs in response to ovenruhelming and inescapable threat to the self, most often
in response to prolonged and intense coercive persuasion. lt permits
psychological survival by means of a shattering of the self. ln prostitution, multiple
selves are created so that the prostituting self is separate from the rest of the self.
Symptoms of dissociation include memory loss,
"blanking
out," numbing, inability to
recall information that is too extensive to be explained by ordinary forgetfulness.
Dissociation is common in prisoners of war who are tortured, children who have
been victims of incest, and women who are prostituted.
1
American Psychiatric Association. (1994). Diaqnostic and statistical manual of mental
disorders. (4th ed.). Washington, DC: American Psychiatric Press

c) Somatoform dissociation
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Somatoform dissociation is the numbing of specific areas of the body that are
exploited or harmed by johns. This process serves the same purpose as other
kinds of dissociation, through the trauma of a woman prostituting her body.
Because of the trauma of prostitution itself, the body is compartmentalized
in the same way that traumatic emotions and memories exist in states of
d issociated consciousness.
d) Pimp
A pimp is a person, most often a man, who procures women in prostitution by
enticing or kidnapping them into it, and who physically controls women in
prostitution via rape or other violence. A pimp exploits women financially, at times
taking all their money. A commonly used definition of pimp is "a person who is
supported by the earnings of a prostitute".
e) John
The term john was first used by men who buy sex to conceal their identities. lt is
now used in a slightly derogatory manner by women in prostitution
to refer to all
men who buy sex.
f) Stockholm Syndrome
Stockholm Syndrome is the emotional bonding to an abuser under conditions of
captivity has been described as the Stockholm Syndrome. Attitudes and behaviors
which are part of this syndrome include: 1) intense gratefulness for small favors
when the captor holds life and death power over the captive; 2) denial of the extent
of violence and harm which the captor has inflicted or is obviously capable of
inflicting; 3) hypervigilance with respect to the captor or pimp's needs and
identification with the pimp's perspective on the world (an example of this was
Patty Hearst's identification with her captors' ideology); 4) perception of those
trying to assist in escape as enemies and perception
of captors as friends; 5)

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extreme difficulty leaving one's captor/pimp, even after physical release has
occurred. Paradoxically, women in prostitution may feel that they owe their lives to
pimps.
g) Traumatic brain injury (TBl)
TBI is an injury to the brain that occurs as a result of physical trauma to the head.
TBI is one consequence of intimate partner violence. ln prostitution, TBI is caused
by closed-fisted blows to the head or face by pimps or johns, kicks to the head, or
the woman's head slammed against walls or dashboards of cars.
h) lndoor or Outdoor Prostitution
The terms indoor or outdoor prostitution refer to the physical location of the
purchase of sex by the john. Indoor locations include lap dance clubs, brothels
(both legal and illegal), massage parlors, the john's or the prostitute's home.
Outdoor locations include vehicle or street. In most of the literature on prostitution,
the term indoor prostitution refers to the location of the person in prostitution at the
time the researcher interviewed her or at the time of her arrest. The term does not
include concurrent locations where the person prostituted (the same day), and it
does not reference locations where the person prostituted on the previous day or in
previous years.
13. The conclusions that I have reached based on the research I have
conducted and based on a review of the medical and social science literature on
prostitution
are as follows.
A. Prostitution is internationally recognized as a form of violence against
women that is linked to many other forms of violence against women.
B.
Prostitution is linked to violence around the world, in many different
cultural contexts.

ENTRY INTO PROSTITUTION
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C. Childhood sexual abuse overwhelmingly precedes entry into
prostitution.
D. Battering in childhood is common among women who later enter
prostitution.
VIOLENCE IN PROSTITUTION AND ITS CONSEQUENCES
E. Prostitution causes severe emotional stress at a level equivalent
to the most emotionally traumatized populations ever studied by
psychologists.
F, Prostituted women use dissociation as a psychological defense
against ovenarhelming physical pain, emotional distress, and the
feeling that prostitution is inescapable.
G. Prostitution more severely harms indigenous women because of
their economic vulnerability, because of social and legal
discrimination against them, and because of their lack of
alternatives.
PIMPS
H. A majority of women in legal and illegal prostitution have pimps
who control them either mentally or physically.
l. Pimps use many of the methods used by torturers to mentally control
women in prostitution.
J. Pimps commonly engage in mentally and physically violent behavior
against women in prostitution. These behaviors are the same as the
behaviors experts currently define as being characteristic of
relationships involving domestic violence.
K. The traumatic bond established between women in prostitution
and their pimp/ captors is the same as the bond between battered
women and their batterers or kidnapped women and their captors.
L. Drug and alcohol abuse are associated with prostitution - but not
in the ways commonly assumed.

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M. Women in prostitution suffer from serious physical health
problems that are unrelated to prostitution's legal status or to its
indoor or outdoor location.
N.
Prostitution in any legal context places women in prostitution at
the highest risk for HIV of any group that has been studied.
INDOOR AND OUTDOOR PROSTITUTION GOMPARED
O. There is little difference in prostitution's link with violence
whether the prostitution takes place indoors or outdoors.
P. There is no evidence for the assumption that women either
prostitute indoors or outdoors but not both. The same women are
prostituted in both indoor and outdoor locations.
Q. Prostitution damages women's sexuality, regardless of its
physical location or its legal status.
R. Most research comparing indoor to outdoor prostitution has
addressed only physical violence and not emotional violence.
S. There are anecdotal and also empirical research accounts from
many countries that johns in indoor prostitution present serious
threats of physical and emotional violence to prostituted women.
T. The emotional harm of prostitution is the sa'me in indoor and
outdoor prostitution, accoriling to both research evidence and
anecdotal reports.
U. Verbal abuse from johns in indoor prostitution poses a threat to
prostituted women's mental health.
V. The overwhelming majority of women in prostitution want to
escape it, regardless of prostitution's legal status.
W. Legalization of prostitution does not reduce the stigma of
prostitution.
X. In Nevada, despite legal prostitution, the women in it are strongly
stigmatized. They are treated as social outcasts.

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Y. Legalization of prostitution does not make prostitution safer than
illegal prostitution.
JOHNS
Z. Men who strongly support the institution of prostitution also tend
to express a tolerance for rape.
AA.Recent research provides new empirical findings on the attitudes
and behaviors of men who buy sex in indoor and outdoor
prostitution.
BB. Men who paid for sex in Scotland held deeply contradictory
attitudes about prostitution.
GG. The johns we interviewed endorsed a number of rape-tolerant
attitudes.
DD. The johns' frequency of use of women in prostitution impacted
their behavior toward non-prostituting women.
EE. Prostitution is not a choice according to the usual definition of
the word choice which implies free selection of an option among
several available alternatives.
14. My affidavit is organized in the following way:
1. I shall address each one of the above conclusions;
ll. I shall address the methodology that I have used in my empirical
research and the specifics of the rigors of peer-review to which it has been
subjected; and, finally,
lll. I shall directly address a number of the specific assertions made by Dr.
John Lowman in his affidavit.

I. MY CONCLUSIONS
13-
A. Prostitution is internationally recognized as a form of violence against
women that is linked to many other forms of violence against women.
15. Violence is commonplace in prostitution whether it is legal or
illegal. The following table2 summarizes the violence I will be discussing, based on
my own research, and that of others.
Cliniral Findings Regarding Violnnce in
All Types of Prostitulion
. 95?1, of thnse in prostitution experienced sexual harassrnent that u*sulcl he legally
actionable in another iob setting.
. B5?;-95% of those in prastitutinn r,,rant tn escape it, hut have n0 othef options fnr
survival.
" 80?;-gfl% 0f those in prnstitution have experienred verbalabLrse and social
contempt, which has adversely alfected them.
. 75% of thnse in prnstitution have been hameless at sorne paint.
. 70%-95% lvere physically assaulted ln prostitution.
. 68% nf 854 people in several different types of prostitution in nine countries met
criteria fnr PTSD.
. 65$'o-S51:o of thnse in prostitLrtion i',lere sexually assaulted as children.
. 6\oh-75olo viere raped in prostitrrtion.
Sourcu: Farley M i2tJCI4i: data lrnm FarlBy 0t al. (2ili3l.
16. Prostitution is better understood as domestic violence than as a job. One
woman explained that prostitution
is "/rke domestic violence taken to the extreme."3
'Table
1 found in Exhibit
"J"
(Farley, Melissa (2004) Prostitution is Sexual Violence.
lsychiatric Times. October 2004 Special Edition. pages 7-10)
"
Leone, D. (2001) 1 in 100 Children in Sex Trade, Study Says. Honolulu Star Bulletin
Monday September 10,2001. Quoting Jayne B.

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B Prostitution is linked to violence around the world, in many different
cultural contexts.
17. A Canadian observer noted that 99% women in prostitution were victims of
violence, with more frequent injuries
"than workers in [those] occupations
considered . . . most dangerous, like mining, forestry, and firefighting.'a
18. ln a Canadian study, we found that 90% of women in prostitution had been
physically assaulted in prostitution, 78% had been raped in prostitution.
19. In the United States, 70% of women in prostitution
in San Francisco,
California were raped.5 A study in Portland, Oregon found that prostituted women
were raped on average once a week.6 Eighty-five percent of women in
Minneapolis, Minnesota had been raped in prostitution.T
20. ln the Netherlands (where prostitution is legal), 60% of prostituted women
suffered physical assaults; 70o/o experienced verbal threats of assault,40o/o
experienced sexual violence and 40o/o were forced into prostitution and/ or sexual
abuse by acquaintances. Vanwesenbeeck found that two factors were associated
with greater violence in prostitution. The greater the poverty, the greater the
o
Gibbs, Erin, Van Brunschot et al. (1999) lmages of Prostitution: The Prostitute and Print
Media, Women and Criminal Justice 10:47
u
Silbert, M.H. & Pines, A. M. (1982) Victimization of street prostitutes. Victimotogy-7 (1-4).
122-133
6
Hunter, S. K. (1994) Prostitution is cruelty and abuse to women and children. Michiqan
Journal of Gender and Law 1. 1-14.
'
Parriott R. (1994) Health Experiences of Twin Cities Women Used ln Prostitution.
Unpublished survey initiated by WHISPER, Minneapolis, MN.

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violence; and the longer one is in prostitution, the more likely one is to experience
violence.s
21. I conducted research on prostitution in 9 countries with colleagues in
Canada, Colombia, Germany, Mexico, South Africa, Thailand, Turkey, United
States, and Zambia. We found that prostitution was multitraumatic: 71o/o of 854
people in prostitution had been physically assaulted in prostitution; 63% were
raped; 75%had been homeless.s
ENTRY INTO PROSTITUTION
G. Ghildhood sexual abuse overwhelmingly precedes entry into
prostitution.
22. Prostituted children are often termed "child prostitutes" in psychological,
sociological, and legal literature, referring to those prostituted while under the age
of majority (18 in most places). The age of consent for sexual activity varies from
country to country. Nonetheless, the term "child prostitute" obscures the fact that
when prostituted, a child is by definition being sexually abused and is a victim of
sexual exploitation.
23. Most prostituted people enter the sex industry as adolescents. Adult and
child prostitutes
are thus not two different classes of people, but the same people
at two different points in time. lt is questionable
that an abusive situation one
enters as a child suddenly disappears when one turns 18.
I
Vanwesenbeeck l. (1994) Prostitutes'Well-Beino and Risk. Amsterdam: VU University
Press;
Vanwesenbeeck 1., de Graaf, R., van Zessen, G., Straver, C.J. & Visser, J.H. (1995).
Professional HIV risk taking, levels of victimization, and well-being in female prostitutes in the
Netherlands. Archives of Sexual Behavior 24(5):503-515
nSeerxnioi ynne,J',Zumbeck,S.,Spiwak,F',Reyes,M'E',
Alvarez , D., Sezgin, U. (2003) Prostitution and Trafficking in 9 Countries: Update on
Violence and Posttraumatic Stress Disorder. Journal of Trauma Practice 2 Ql4):33-74)

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24. In Canada, S2o/o of 100 women prostituting in Vancouver had a history
of childhood sexual abuse. The women told us that on average, they had
suffered sexual abuse from an average of 4 perpetrators.lo
25. Seventy percent of the adult women in prostitution
in another study
said that their childhood sexual abuse led to entry into prostitution.ll
26. Boyer and colleagues interviewed 60 women prostituting in escort,
street, strip club, phone sex, and massage parlors (brothels) in seatile,
washington. All of them began prostituting between the ages of i2 and i4.12
27. Nadon found that 89% had begun prostitution before the age of 16.13
28. In another research study, 78% of 200 adult women in prostitution
began prostituting as juveniles and 68% began prostitution when they were
younger than 16 years of age.1a
tosee
Exhibit
""E" (Farley, M, Lynne, J, and cotton, A (2005) prostitution in Vancouver:
Violence and the Colonization of First Nations
tt
Women. Transcultural Psvchiatrv 42:242-271)
Mimi H. Silbert & Ayala M. Pines, Early Sexual Exploitation as an tnftuenCei
Prostitution, 28 SoclAL Wonx 285 (1983). See also Mrvrr H. SrLeERr Er AL., Srxunl
AssRulr oF PRosrlrures (National Center for the Prevention and Control of Rape,
National lnstitute of Mental Health, Washington,
'2
D.C. 1gB2)
Boyer, D., Chapman, L., & Marshall, B.K:(1993). Survival Sex in Kinq Countv:
Helpinq women out. Report Submitted to King county women's Advisory Board.
Seattle: Northwest Resource Associates
tt
Nadon, S.M., Koverola, C., Schludermann, E.H. (1gg8). Antecedents to
Prostitution: Childhood Victimization. Journal
1o
of Interpersonal Violence 13.206-221
Silbert, M.H.& Pines, A.M. (1g82a).Entrance into Prostitution. Youih & Societv 13:
471-500

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29. 23oh of a group of women that I interviewed in Nevada legal
prostitution
had entered prostitution
as children.l5
30. One Canadian study indicated that women enter prostitution as
children at an average age of 15.16 Another Canadian study found that75%
of 50 Canadian youth (mostly female) entered prostitution before the age of
16.17
D. Battering in childhood is common among women who later enter
prostitution.
31. In two separate studies of hundreds of women, both found that 90% of
prostituted women had been physically battered in childhood.ls
VIOLENCE IN PROSTITUTION AND ITS CONSEQUENGES
E. Prostitution causes severe emotional stress at a level equivalent to the
most emotionally traumatized populations ever studied by psychologists.
32. Although the physical violence of prostitution is brutal and pervasive, the
emotional trauma of prostitution is worse.
tu
See Exhibit
"D"
(Farley, Melissa (2007) Prostitution and Traffickinq in Nevada: Making the
Connections. San Francisco: Prostitution Research and Education)
c
nssistant Oeputy Ministers' Committee on Prostitution and the Sexual Exploitation of
Youth, (2000) Sexual exploitation of vouth in British Columbia. Vancouver: Ministry of the
Attorney General
tt
Mclntyre, S. (1995) The youngesf profess ion: The o/dest oppression Doctora,
dissertation, Department of Law, University of Sheffield
18
Giobbe, E., Harrigafl, M., Ryan, J. & Gamache, D. (1990). Prostitution: A Matter
of Violence aqainst Women. Minneapolis: WHISPER, Hunter, S. K. (1994)
Prostitution is cruelty and abuse to women and children. Michiqan Journal of Gender
and Law 1:1-14

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33. The diagnosis of posttraumatic stress disorder (PTSD) encompasses
symptoms resulting from traumatic events, including the trauma of
prostitution.
PTSD can result when people
have experienced
"extreme
traumatic stressors involving direct personal experience of an event that
involves actual or threatened death or serious injury; or other threat to one's
personal integrity; or witnessing an event that involves death, injury, or a
threat to the physical integrity of another person; or learning about
unexpected or violent death, serious harm, or threat of death or injury
experienced by a family member or other close associate." PTSD is
characterized by anxiety, depression, insomnia, irritability, flashbacks,
emotional numbing, and hyperalertness. Symptoms are more severe and
longlasting when the stressor is of human design.
34. We found a PTSD prevalence rate of 68% among those in prostitution
in 9 countries. Two thirds of those in prostitution met clinical criteria for a
diagnosis of PTSD. This rate was among the highest for any group of people
whose traumatic stress was evaluated. This rate of PTSD is comparable to
the rates of PTSD among battered women seeking shelter, rape survivors,
combat veterans, and survivors of state-sponsored torture.ls
35. Vanwesenbeeck noted symptoms among women in legal Dutch prostitution
that are consistent with symptoms of PTSD.2o Results from two studies of
tn ""B"
See Exhibit (Farley, M., Cotton, A., Lynne, J., Zumbeck, S., Spiwak, F., Reyes,
M.E., Alvarez , D., Sezgin, U. (2003) Prostitution and Trafficking in 9 Countries: Update on
Violence and Posttraumatic Stress Disorder. Journal of Trauma Practice 2
2o
Qlfl.33-74)
Vanwesenbeeck found that ninety percent of women who were prostituted primarily in
clubs, brothels, and windows reported
"extreme nervousness."

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prostituted Korean women reflect the women's intense psychological distress with
PTSD prevalence rates of 78% and B0% seventy-eight and eighty percent.2l
F. Prostituted women use dissociation as a psychological defense against
overwhelming physical pain, emotional distress, and the feeling that
prostitution is inescapable.
36. Dissociation occurs during extreme stress among prisoners of war who are
tortured, among children who are being sexually assaulted, and among women being
battered, raped, or prostitu ted.22
37. Dissociative disorders are common among those in escort, street, massage,
strip club and brothel prostitution. Women report that they cannot prostitute unless
they dissociate since the dissociation protects them from the massive invasion they
are subjected to by johns who, as one put it, "rent
an organ for 10 minutes" in
prostitution. Chemical dissociation via use of drugs and alcohol facilitates
psychological dissociation, and also functions as analgesic for injuries from violence.
38. Dissociation in prostitution results from both childhood sexual violence and
sexual violence in adult prostitution. The dissociation that is necessary to survive rape
in prostitution is the same as that used to endure familial sexual assault.
Vanwesenbeeck noted that a dissociative proficiency contributed to what she
described as "professional
attitudes" among women in prostitution in the Netherlands.
39. A woman I interviewed explained the gradual development of a dissociated
identity during the years she prostituted in strip clubs, an indoor prostitution venue.
"
See Exhibit
"l"
(Farley, M. and Seo, S. (2006) Prostitution and Trafficking in Asia. Harvard
Asia Pacific Review Volume 8 Number 2 pages 9-12)
@2)
Trauma and Recoverv. New york, Basic Books.

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You start changing yourself to fit a fantasy role of what they
think a woman should be. In the real world, fhese women don't
exisf. They sfare at you with this staruing hunger. It sucks you
dry; you become this empty shell. They're not really looking at
you, you're not you. You're not even there.'"
40. Another woman described a dissociative response to the trauma of
prostitution:
41. And also:
Prostitution is like rape. lt's like when I was 15 years
old and I was raped. I used to experience leaving my
body. I mean that's what I did when that man raped
me. I went to the ceiling and I numbed myself because I
didnt want to feelwhat I was feeling. I was very
frightened. And while lwas a prostituted I used to do
that allthe time. I would numb my feelings. I wouldn't
even feel like I was in my body. I would actually leave
my body and go somewhere e/se with my thoughts and
with my feelings until he got off and it was over with. I
donT know how else to explain it except that it felt like
rape. lt was rape to me. 'o
lf anything a prostitute treats herself like a chair for
someone to sit on. Her mind goes blank. Sheiusf /ies
there. You becomeTusf an obiect....After a while it
becomes just a normal thing.'"
42, A woman in a legal New Zealand massage parlor explained:
Memory is an amazing thing. I leave here [brothel] and I cant
remember a thing.'"
"
See Exhibit
"F"
(Farley, M.
"Bad
for the Body, Bad for the Heart: Prostitution Harms
Women Even if Legalized or Decriminalized" Violence Aqainst Women 10: 1087-1125
'"
Giobbe, E. (1991) Prostitution, Buying the Right to Rape, in Burgess, A.W. (ed.) Rape
and Sexual Assault lll: a Research Handbook. New York: Garland Press
25
Mcleod, E. 91982) Women working: Prostitution Now. London: Croom Helm
26 Farley, M. (2003) Preliminary Report: New Zealand Prostitution. Unpublished Paper:
Wellington, New Zealand. May 14,2003 attached to this my Affidavit as Exhibit
"P"

-21 -
G. Prostitution more severely harms indigenous women because of their
economic vulnerability, because of social and legal discrimination against
them, and because of their lack of alternatives.
43. Race, sex, and class are multiplicative risk factors for prostitution.
Nonetheless, those who promote legal prostitution rarely address class, race, and
ethnicity as factors that make women significantly more vulnerable to the violence
and health risks of prostitution.
44 Within the gendered institution of prostitution, race and class create a
familiar hierarchy with indigenous women at its lowest point. Especially vulnerable
to violence from wars or economic devastation, indigenous women are brutally
exploited in prostitution - for example Mayan women in Mexico City, Hmong
women in Minneapolis, Atayal girls in Taipei, Karen or Shan women in Bangkok,
and First Nations women in Vancouver.
45. Aboriginal or First Nations women in Canada are at higher risk for all of the
factors that increase vulnerability to prostitution: family violence including an
epidemic of sexual violence, life-threatening poverty including homelessness, lack
of educational and job opportunities, lack of health services throughout their
lifetimes, and lack of culturally appropriate social services.
46. Indigenous people of Canada have suffered the brutal harms of colonization
that affect every aspect of their lives. Compared to other groups, indigenous people
in North America have suffered multiple and cumulative trauma. Prostitution is one
specific legacy of colonization although it is infrequently understood or analyzed as
such.
47. When we compared Maorii Pacific lslander New Zealanders in prostitution to
European-origin New Zealanders in prostitution, the Pacific lslander/ Maoriwere

-22-
more likely to have been homeless and to have entered prostitution at a young age.
Mama Tere, an Auckland community activist, referred to NZ prostitution as an
"apartheid
system."27 Plumridge & Abel similarly described the New Zealand sex
industry as "segmented"
noting thatT% of the population in Christchurch were Maori,
but 19% of those in Christchurch prostitution were Maori.28 Similar findings from
Australia have been reported.
48. Among women in legal prostitution in New South Wales, Australia, Aboriginal
women in prostitution were more likely to have entered prostitution at a very young
age, more likely to have been homeless, and to have significantly more symptoms of
depression than non-Aboriginal women in prostitution.2e
49. ln a study of Vancouver prostitution, we noted that 52o/o of the women in
prostitution we interviewed were women from Canada's First Nations. Yet First
Nations people in Vancouver generally comprise only 1.7-7% of the population.
They experienced a horrific violence in prostitution: 90% had been physically
assaulted in prostitution and 78o/o had been raped in prostitution. 72% of the
Canadian women we interviewed met clinical criteria for a diagnosis of PTSD
(symptomatic of intense emotional distress), which is among the highest of any
groups studied.
50. A retrospective study of violence in the lives of 47 women in prostitution in three
Western Canadian provinces indicates that Aboriginal Canadians are
overrepresented in prostitution relative to their representation in the general
"
See Exhibit
"P"
Farley, M. (2003) Preliminary Report: New Zealand Prostitution.
Unpublished Paper: Wellington, New Zealand. May 14, 2003
28
Plumridge, L & Abel, G. (2001) A
"segmented"
sex industry in New Zealand: sexual and
personal safety of female sex workers . Australian and New Zealand Journal of Public
Health 15(1): 78-83.
2e
Roxburgh, A., Degenhardt, L. and Copeland, J. (2000) Posttraumatic stress disorder
among female street-based sex workers in the greater Sydney area, Australia. BMC
Psychiatry 6:24. Available at
http://wlw. pubmedcentral.nih. gov/articlerender.fcgi?artid= 1 48 1 550

-24-
prostitute, drugging and forced addiction, and forced pregnancy.
J. Pimps commonly engage in mentally and physically violent behavior
against women in prostitution. These behaviors are the same as the
behaviors experts currently define as being characteristic of relationships
involving domestic violence.
54. Prostituted women are unrecognized victims of domestic violence by
pimps.31 Pimps use methods of coercion and controljust like those of other
batterers: economic exploitation, social isolation, verbal abuse, threats, physical
violence, sexual assault, captivity, minimization and denial of physical violence and
abuse.32
55. Recruitment of women into prostitution often begins with brutal violence
designed to break the victim's will. After physical control is gained, pimps use
psychological domination and brainwashing. Pimps establish emotional
dependency as quickly as possible, beginning with changing a woman's name.
This removes her previous
identity and history, and also isolates her from her
community. The purpose of pimps' violence is to convince women of their
worthlessness and social invisibility, as well as to establish physical control and
captivity. Over time, escape from prostitution
becomes more difficult as the woman
is repeatedly overwhelmed with terror. She is forced to commit acts which are
sexually humiliating and that cause her to betray her own principles. The contempt
and violence aimed at her are eventually internalized, resulting in a virulent self-
hatred which then makes it even more difficult to defend herself. Survivors report a
31
Stark, C. & Hodgson, C. (2003) Sister Oppressions: A Comparison of Wife Battering and
Prostitution. ln M. Farley (ed.) Prostitution, Traffickinq, and Traumatic Stress. Binghamton:
Haworth (see Exhibit
"K")
32
Giobbe, E. (1991) Prostitution, Buying the Right to Rape, in Ann W. Burgess, (ed.) Raoe
and Sexual Assault lll: a Research Handbook. New York: Garland Press p 143-160;
Giobbe, E. (1993) An Analysis of Individual, lnstitutionaland Cultural Pimping, Michiqan
Journal of Gender & Law 1:33-57.; Giobbe, E., Harrigan, M., Ryan, J., Gamache, D. (1990)
Prostitution: A Matter of Violence aqainst Women. WHISPER, Minneapolis, MN.

-25_
sense of contamination, of being different from others, and self-loathing which last
many years after breaking away from prostitution.
56. Sometimes pimps deliberately exploit the shame associated with
prostituting.
K. The traumatic bond established between women in prostitution and
their pimp/ captors is the same as the bond between battered women and
their batterers or kidnapped women and their captors.
57. Unless human behavior under conditions of captivity is understood, the
emotional bond between those prostituted and pimps is difficult to comprehend. In
escapable situations, humans form bonds with their captors. ln the absence of
other emotional attachments, women appear to choose their relationships with
pimps and may be psychologically at home with men who exercise coercive control
over them.
58. The terror created in the prostituted woman by the pimp causes a sense of
helplessness, dependence, and paradoxically, bonding with the kidnapper/
batterer/ pimp. The Stockholm syndrome is a psychological strategy for survival in
captivity. Attitudes and behaviors which are part of this syndrome include: 1)
intense gratefulness
for small favors when the captor holds life and death power
over the captive; 2) denial of the extent of violence and harm which the captor has
inflicted or is obviously capable of inflicting; 3) hypervigilance with respect to the
pimp's needs and identification with the pimp's perspective on the world; 4)
perception
of those trying to assist in escape as enemies and perception
of captors
as friends; 5) extreme difficulty leaving one's captor/pimp, even after physical
release has occurred. Paradoxically,
women in prostitution
may feel that they owe
their lives to pimps.

-26-
59. ln order for a woman to survive prostitution on a day-to-day basis, she
must deny the extent of harm that pimps and johns are capable of inflicting.
since her survival may depend on her ability to predict others' behavior, she
vigilanfly attends to the pimp's needs and may ultimately identify with his
worldview. This increases her chances for survival, as in the case of Patty
Hearst who temporarily identified with her captors' ideology.33
L. Drug and alcohol abuse are associated with prostitution - but not in the
ways commonly assumed.
60. A misconception about prostitution is that a large majority of prostitutes are
drug-abusing women who begin prostituting to pay for a drug habit' Women in
prostitution use drugs and alcohol to dealwith the overwhelming emotions
experienced while turning tricks. Drugs and alcohol function as analgesics for the
traumatic physical and sexual assaults by johns and pimps that commonly occur in
prostitution. A number of studies have shown that women increase recreational drug
use to the point of addiction after entry into prostitution.
61. One group of addiction researchers found that B% of women receiving
treatment for addiction reported that their drug abuse preceded prostitution, whereas
39% reported that the prostitution preceded drug abuse'34
62. ln another study, 60% of a group of Venezuelan women in prostitution began
abusing drugs and alcohol only after entry into prostitution.35
..
Barry, K. (1995) The Prostitution of Sexualitv NEY Y9Y, NYU PRESS
*r-,nti"'w.n.,B;@der,F.R',&Cone,E.J.(1989)TheLexington
addicti, ig1i-1g72:'Demographic characteiistics drug use patterns, an! s-el^e^c!ed infectious
disease experience. The liteinationalJournal of the AddicJions 24(7).609-626
";d;ililJ.c',o'ynes,H.P',Rodriguez,Z'R.,andSantos,
A.2OO2\A Comparative Studv of Women irafficked in the Miqration Process. Amherst, MA'
Coalition Against Trafficking in Women

-27 -
63. Pimps and traffickers control prostitutes by coercively addicting them to
drugs. In a similar way, perpetrators of sexual abuse against children drug them in
order to facilitate sexual attacks or to disorient and silence them.
M. Women in prostitution suffer from serious physical health problems that
are unrelated to prostitution's legal status or to its indoor or outdoor
location.
64. Chronic health problems result from sexual assault, battering, untreated health
problems, and ovenruhelming stress and violence. Prostituted women suffer from all
of these. Many of the chronic symptoms of women in prostitution are similar to the
physical and emotional consequences of torture.
65. The longer women remained in prostitution, the higher their rates of sexually
transmitted diseases. Women in the Netherlands who serviced more customers in
prostitution
reported more severe physical symptoms.
66. Cervical cancer is common among women who have been in prostitution.
Two risk factors for cervical cancer are younger age at first sexual activity and
overall number of sexual partners. Prostituted women have an increased risk of
cervical cancer and also chronic hepatitis.
67. Traumatic brain injury (TBl) occurs in prostitution as a result of being beaten,
hit, kicked in the head, strangled, or having one's head slammed into objects such
as walls or furniture or car dashboards. Strangulation is relatively more common in
indoor prostitution.
68. 75o/o of the Canadian women we interviewed suffered injuries from violence
that occurred during prostitution. These included stabbings and beatings,
concussions, broken bones (broken jaws, ribs, collar bones, fingers, spines, skulls).
50% of the Canadian women in prostitution reported traumatic and violent assaults

-28-
to their heads during prostitution that resulted in alteration of consciousness.36
Long term symptoms resulting form injuries to their brains reported by the Canadian
women included trouble concentrating, memory problems, headaches,
pain/numbness in hands/feet, vision problems, dizziness, problems with balance,
and hearing problems.
69. ln a study of prostituted women from three countries, 30% of Filipino women,
33% of Russian women, andTToh of US women reported head injuries.3T
70. Common medical problems of women in prostitution included tuberculosis,
HlV, diabetes, cancer, arthritis, tachycardia, syphilis, malaria, asthma, anemia, and
hepatitis. Across many countries, about 25% of women in prostitution reported
reproductive symptoms including sexually transmitted diseases (STD), uterine
infections, menstrual problems, ovarian pain, abortion complications, pregnancy,
hepatitis B, hepatitis C, infertility, syphilis, and HlV.
71 . 15% reported stress-related gastrointestinal symptoms such as ulcers, chronic
stomachache, diarrhea, and colitis. 14% of these women and children in prostitution
reported respiratory problems such as asthma, lung disease, bronchitis, and
pneumonia. 14% reported joint pain, including hip pain, knee pain, backache,
arthritis, rheumatism, and nonspecific multiple-site joint pain.
72. We compared women in prostitution, with those who had escaped and who
had been out of prostitution on av?rage 1.5 years. once women were out of
prostitution, awareness of the severity of the violence increased, with, for example,
tu
See Exhibit
"E"
(Farley, M, Lynne, J, and Cotton, A (2005) Prostitution in Vancouver:
Violence and the Colonization of First Nations Women. Transcultural Psvchiatry 42:242-271)
.'Raymond,J.,D'CUnha,J'Dzuhayatin,S.R'.,Hynes,@z,Z',and
Santos, A. (2002). A Comparative Study of Women Trafficked in the Migration Process:
Patterns, Profiles and Health Consequences of Sexual Exploitation in Five Countries
(lndonesia, the Philippines, Thailand, Venezuela and the United States). N. Amherst, MA:
Coalition Against Trafficking in Women (CATW)

73.
-29-
g5% of the exited women reporting violent injuries resulting from prostitution,
including a95% incidence of traumatic head injury.38
N. prostitution in any legal context places women in prostitution at
the highest risk for Hlv of any group that has been studied.
Current science regarding HIV is that women with multiple partners are at
highest risk.3e The greater the number of sex partners, the higher that person's
risk for HlV. Since women in prostitution have many sex partners, some having
serviced thousands of johns, they are at the highest risk for HlV. Women in
prostitution are frequently raped, and since rape also poses a grave HIV threat, this
is an additional HIV risk factor for them.
74. In a study of prostitution in Cambodia and Thailand, the more johns
serviced, and the greater the number of sex partners, the greater the risk for HIV.
Larson and Narain found that the higher the number of johns, and the higher the
number of overall sex partners, the higher women's rate of HIV in Cambodia and
Thailand.ao
75. While some people assume that johns generally use condoms, this is a
myth. A number of studies indicate that a majority of johns do not use condoms.
,u "B"
See Exhibit (Farley, M., Cotton, A., Lynne, J., Zumbeck, S., Spiwak, F., Reyes, M.E.,
Alvarez , D., Sezgin, U. (2003) Prostitution and Trafficking in 9 Countries: Update on
Violence and Posttraumatic Siress Disorder. Journal of Trauma Practice 2 Ql4):33-74)
3e
Terri Coles (2006) Muttipte partnerships fueting A/DS epidemic. Reuters U.K. August 15,
2006. Discussing a'paper by Daniel Halperin, USAID, Southern Africa, presented at the
16th Global AIDS conference in Toronto, Canada.
o0
Heidi J. Larson and Jai P. Narain (2001) Beyond 2000: Responding to HIV/AIDS in the
new millennium. New Delhi: World Health Organization (WHO) Regional Office for South-
East Asia. Retrieved November 15, 2005 from
http://w3.whosea.org/EN/Sectionl0/Sectionl S/Section356/Section410.htm, page 17

-30-
Eighty-nine percent of Canadian johns refused condoms in one study.al Given the
poverty and homelessness associated with prostitution -- 75% of women in
prostitution had been homeless in the 9-country study which included Canada -
women in prostitution are vulnerable to being pressured or coerced by johns and
pimps
into not using condoms.
76. An economic analysis of condom use in India found that when
women used condoms, they were paid 66% to 79% less by johns.a' UK
researchers concluded that because customers paid more money for not using
condoms, extremely risky sex acts "can always be purchased."43
77. ln another study, 47% of women in U.S. prostitution stated that men
expected sex without a condom:73o/o reported that men offered to pay more for
sex without a condom; and 45% of women said that men became abusive if they
insisted that men use condoms.oo
INDOOR AND OUTDOOR PROSTITUTION COMPARED
O. There is little difference in prostitution's link with violence whether the
prostitution takes place indoors or outdoors.
78 The sex industry morphs and expands in part as a result of developments in
web technology, law, and community opinion. Phone sex and Internet sex via live
ot
Cunningham, L.C. & Christense1, C. (2001) Viotence against women in Vancouver's
streef level sex trade and the police response. Vancouver: PACE Society
o'
Rao, V, Gupta, l, Lokshin, M, Jana, S. (2003) Sex Workers and the Cost of Safe Sex:
The Compensating Differentialfor Condom Use in Calcutta. Journal of Development
Economics. Vol 7 1 (2): 585-603
ot
Loff, B, Overs, C, and Longo, P (2003) Can health programmes lead to
mistreatment of sex workers? Lancet 36: 1982-3. June 7 2003.
oo
Raymond, J., Hughes, D. & Gomez, C. (2001). Sex Trafficking of Women in the United
States: Links Between International and Domestic Sex lndustries. N. Amherst. MA:
Coalition Against Trafficking in Women

-31 -
video chat are forms of prostitution that were not developed at the time that the
laws were enacted. lndoor prostitution includes massage brothels, escort
prostitution, gentlemen's clubs, topless clubs, the commercial marriage market,
sauna and nail parlor prostitution, strip clubs, lap dance clubs, and peep shows.
Outdoor prostitution includes street locations, and automobiles or vans owned by
johns or pimps.
79 Homes or apartments are rented for use as brothels for escort prostitution.
The relative invisibility of indoor prostitution may increase its danger. When
women prostitute indoors, the community is less likely to see then or notice their
abuse. Sometimes when prostitution is indoors, neighbors do not even know that
prostitution is occurring next door. No one lodges complaints until neighbors
become irritated about a lack of parking space or until neighbors become
suspicious about the steady stream of men going in and out of the house in 20
minute intervals.
80. Reports from many countries indicate that residential brothels and massage
parlors are locations to which women are secretly trafficked from other countries
and used in prostitution.
81. Women and children can be controlled in indoor prostitution in ways that they
can not be controlled on the street. They can be locked in their rooms, heavily
drugged, restrained, and beaten. Pimps who run indoor prostitution are no less
dangerous than pimps who are visible on the street.
82. There is a myth that class privilege protects some women in prostitution.
Demystifying this, Giobbe explained what lies beneath the trappings of class in
prostitution:

-32-
My experience in prostitution gives the lie to . . . common beliefs about the
hierarchy of prostitution, the sfreefs being the worst-case scen ario and ...[escort]
seruice being the best. ... all I can say is, whether you turn tricks in a car by the
Holland tunnel or in the Plaza Hotel, you still have to take off your clothes, get on
your knees or lie on your back, and let this stranger use you in any way he
pleases.... a5
P. There is no evidence for the assumption that women either prostitute
indoors or outdoors but not both. The same women are prostituted in both
indoor and outdoor locations.
83. lt is an error to assume that women prostitute
in one location and stay there.
In fact, they move between different kinds of prostitution,
depending on the location of
johns, the level of police harassment, and where the most money can be made - for
example, near military bases or at sports events or business conventions.
84. Kramer found that 59% of 1 19 women in the US had been in one or more type
of indoor prostitution - strip club, massage parlor, and/or escort prostitution - in
addition to street prostitution. 33% had been prostituted indoors for the longest period
of time while 66% were involved in street prostitution for the longest time.a6
85. ln similar findings, I found that 46 NZ interviewees had been prostituted in
many different kinds of prostitution, including escort, strip club, phone sex, internet
prostitution, peep show, bar prostitution, street prostitution, brothel prostitution, and
prostitution
associated with a military base.aT
86. In Nevada's system of legal prostitution, half of the women we interviewed had
also prostituted
in strip clubs or lap dance clubs, and another 50% also prostituted
via
a5
Giobbe, E. (1991) the Vox Fights, Vox, Winter 1991
ou
Kramer, L. (2003) Emotional Experiences of Performing Prostitution. ln M. Farley
(ed.) Prostitution. Trafffickinq, and Traumatic Stress. Binghamton: Haworth.
ot
See Exhibit
"P"
(Farley, fr4. tZOOg) Preliminary Report: New Zealand Prostitutron.
Unpublished Paper: Wellington, New Zealand. May 14,2003)

-33-
escort agencies. Many had prostituted in illegal massage parlors, street prostitution,
phone sex venues, peep shows, and at military bases.as
8T. These findings are paralleled by a recent study of Scottish men who bought
sex. 56% bought sex outdoors and 80% bought sex indoors, with many men buying
sex both in and outdoors.
ae
O. Prostitution damages women's sexuality, regardless of its physical
location or its legal status.
88. For the person in it, prostitution is harmful to her sexuality. Women in
prostitution have described it as "paid
rape" and experts have understood it as
sexual annihilation. Most people who have been in prostitution for any length of
time have tremendous difficulty with sexual intimacy. Sex becomes a job, rather
than an act of love or passion. Since the sex acts of prostitution mimic the sex acts
of freely chosen sex, her chosen partner feels to her like a john.
89. Men who prostitute experience similar damage to their sexuality and to their
sense of self, as well as symptoms of traumatic stress that are identical to
women's.
gO. The assault on women's sexuality in prostitution is overwhelming, yet
invisible to most people. Survivors of prostitution and those analyzing and
researching prostitution from the Netherlands, Norway, Australia, and the United
States have described this process of sexual destruction. When women are
turned into objects that men masturbate into or as an organ that is rented for 10
ou "D"
See Exhibit (Farley, Melissa (2007) Prostitution and Traffickinq in Nevada: Makinq
the Connections. San Francisco: Prostitution Research and Education.
40
MacleodJ=arley, M., Anderson, L., and Golding, J. (2008) Challenqinq Men's Demand for
Prostitution in Scotland: A Research Report Based on lnterviews with 110 Men Who Bouqht
Women in Prostitution. Glasgow:Women's Support Project

-34-
minutes, as one john explained - it causes immense harm to the person who is
acting as receptacle.
Prostitution and sexual liberation have got nothing to
do with each other, they're exactly the opposite. I
donT feel free with my body, I feel bad about it, I feel
se/f-conscious. / donT really feel like my,Qody's alive,
I think of it more as bruised, as a weight.""
91. Women in prostitution at first may make a conscious decision to mentally
disconnect themselves from the specific parts of the body rented out by johns.
Stating,
"l save my vagina for my lover," one woman performed only oral sex or
masturbation.sl Over time, however, this piecing-out of parts of the body in
prostitution (johns get this part of the body, lovers get that one) results in
somatoform dissociation. Sexual and other areas of her body are numbed. Her
body itself becomes an internalized commodity. Her body itself is
compartmentalized because of the trauma of prostitution.
R. Most research comparing indoor to outdoor prostitution has addressed
only physical violence and not emotional violence.
92. On pages 1099-1 103 of the research review article,
"'Bad
for the Body, Bad
for the Heart:' Prostitution Harms Women Even if Legalized or Decriminalized"
(Exhibit
'F"),
I reviewed 10 published reports and research studies that address
violence in indoor prostitution, including discussion of similarities and differences
between indoor and outdoor prostitution. Several studies found either no differences
between the violence in indoor and outdoor prostitution or increased psychiatric
symptoms among women in strip club prostitution.
50
Jaget, C. (1980). Prostitutes - Our Life. Bristol: Falling Wall Press.
ut
Pheterson, G. (1996). The Prostitution Prism. Amsterdam: Amsterdam University
Press

-35-
93. The same frequency of rape is reported by women in both escort and street
prostitution.s2 Although some studies report greater physical violence in outdoor
prostitution, other studies report equal violence regardless of the physical location
of prostitution (see South African research study below).
94. When we think of what most people consider to be reasonable physical risk
- the differences between indoor and outdoor prostitution are minimal. 81% of
women prostituting on the street in Glasgow experienced violence at the hands of
johns. Yet 48% of the women prostituting indoors were subject to frequent and
seyere violence.s3
S. There are anecdotal and also empirical research accounts from many
countries that johns in indoor prostitution present serious threats of physical
and emotional violence to prostituted women.
95. Boyer, Chapman & Marshall suggested that *or"n in indoor
prostitution (such as strip clubs, massage brothels and pornography) had
/ess control over the conditions of their lives and probably faced greater risks
of exploitation, enslavement, and physical harm, than women prostituting on
the street.sa
52
Raphael, J. & Shapiro, D.L. (2002) Sisters Speak Out: The Lives and Needs of
Prostituted Women in Chicago. Chicago, lllinois: Center for lmpact Research
53
Church S, Henderson M, Barnard M, Hart G. Violence by clients towards female
prostitutes in different work settings. questionnaire survey. BMJ. 2001;322:524-525. (3
March.)
uo
Boyer, D., Chapman, L., & Marshall, B.K. (1993). Suruival Sex in King County:
Helping Women Ouf. Report Submitted to King County Women's Advisory Board.
Seattle. Northwest Resource Associates

-36-
96. Some women in prostitution
have told me that they felt safer in street prostitution
as compared to indoor brothels in USA and in New Zealand where they were not
permitted by legal pimps to reject potentialjohns. They explained that on the street they
could refuse violent-appearing or intoxicated customers. On the street, they reported,
friends could also make a show of writing down the john's car license plate number,
which they considered a deterrent to customer violence. A john could be easily traced
using such methods, whereas a brotheljohn's identity would likely be protected by the
brothel owning pimps, making it difficult to identify or prosecute him for violent behavior.
97. Women in brothels or escort agencies or strip clubs are not encouraged to
complain about violence to pimp/owners. Sometimes, even after johns rape them, they
are fired for their protests.
98. Sex Workers' Education and Advocacy Taskforce (SWEAT) in South Africa
addressed the dangers of indoor escort prostitution by distributing a list of safety tips.
These included the recommendation that while undressing, the prostitute should
"accidentally"
kick a shoe under the bed, and while refrieving it, should check for knives,
handcuffs or rope. The SWEAT flyer also noted that fluffing up the pillow on the bed
would permit searching there for weapons.
99. An indoor brothel owner in the Netherlands complained about an ordinance
requiring that brothels have pillows in the rooms: "You don't want a pillow in the
[brothe|s] room. lt's a murder weapon " 55 Familiar with how customers treated women
in prostitution, the Dutch pimp understood that johns are regularly murderous toward
women.
"
Daley, S. (2001) New Rights for Dutch Prostitutes, but No Gain. Neyv York Times.
August 12,2001. Accessed 8-25-2001 at:
http://www. nyti mes. co m12001 | 081 1 2linternalional/1 2D UTC. html

-37 -
100. A San Francisco organization suggested to women in indoor escort prostitution:
"be
aware of exits and avoid letting your customer block access to those exits,"
"be
aware of where your client (trick) is at alltimes, as much as possib/e," "shoes should
come off easily or be appropriate for running in," and "avoid necklaces, scaryes, across-
the-body shoulder bags or anything e/se that can be accidentally or intentionally be
tightened around your throat." 56
101 . At the 1Sth lnternational AIDS conference in Bangkok (July 11-16,2004),
several sex worker groups presented information about the occupational health
and safety of prostitutes. A Bangkok organization instructed women in indoor bar
prostitution how to insert and pull out razor blades from their vaginas. This is
understood to be a job requirement in the indoor bar prostitution setting where
johns are sexually excited by the possibility of the genital mutilation of Thai women.
T. The emotional harm of prostitution is the same in indoor and outdoor
prostitution, according to both research evidence and anecdotal reports.
102. Like Plumridge & Abel in New Zealand,sT my colleagues and I found more
physical violence in street compared to brothel prostitution in South Africa.
However, we found no difference in the incidence of extreme emotional distress or
PTSD in these two types of prostitution. I conclude from this finding that the
emotional experience of prostitution is intrinsically traumatizing regardless of its
indoor or outdoor location.ss
uu
St James lnfirmary Q0O4 2nd edition) Occupational Health and Safety Handbook.
San Francisco: Exotic Dancers Alliance and STD Prevention and Control Services of the
Qity and County of San Francisco
''
Plumridge, L & Abel, G. (2001) A
"segmented"
sex industry in New Zealand: sexual
and personal safety of female sex workers. Australian and New Zealand Journal of
Public Health 15(1): 78-83
"o
Farley, M; Baral, l; Kiremire, M; & Sezgin, U. (1998) Prostitution in Five Countries:Violence
and Posttraumatic Stress Disorder. Feminism & Psvcholoqv, 8 (4): 405-426)
I

-38-
103. ln a separate study, we compared strip club/ massage, brothel, and street
prostitution in Mexico and found no differences in the prevalence of physical assault
and rape in prostitution, of childhood sexual abuse, or symptoms of PTSD. We also
found no differences in the percentages of Mexican women in brothel, street, or
strip clubl massage prostitution
who wanted to escape prostitution.5e
104. Documenting the profound emotional distress experienced by women in two
kinds of prostitution,
a Canadian study compared strip club (indoor prostitution)
and
street prostitution. The authors found that women prostituted in strip clubs had
higher rates of dissociative symptoms and other serious psychiatric symptoms when
compared to women in street prostitution.60
105. Similarly, Vanwesenbeeck noted substantial emotional distress among
women in legal indoor prostitution in the Netherlands. Investigating emotional
distress in women who were prostituted primarily in clubs, brothels, and windows,
Vanwesenbeeck found that g0% of the women reported
"extreme nervousness."
U. Verbal abuse from johns in indoor prostitution poses a threat to
prostituted women's mental health.
'
106. The harm of toxic verbal assaults from johns against those in prostitution is
emotionally devastating, often outlasting the physical injuries. Yet the verbal abuse
in prostitution is socially invisible just as other sexual harassment in prostitution is
normalized and invisible to many people. Yet it is pervasive: 88% of 315
un
See Exhibit
"B"
(Farley, M., Cotton, A., Lynne, J., Zumbeck, S., Spiwak, F., Reyes, M.E.,
Alvarez , D., Sezgin, U. (2003) Prostitution and Trafficking in 9 Countries: Update on
Violence and Posttraumatic Stress Disorder. Journal of Trauma Practice 2 (314): 33-74)
60RoSS,C.A',Anderson,G;Heber,s;aruorton@nandAbuse
Among Multiple Personality Patients, Prostitutes and Exotic dancers. Hospital and
Community Psychiatry 41. 328-330.

-39-
prostituting women and adolescents in Canada, Colombia and Mexico described
verbal abuse as intrinsic to prostitution.6l
107. Verbal assaults in all types of prostitution are likely to cause acute and long-
term psychological symptoms. Explaining this process, one woman explained that
over time, "lt is internally damaging. You become in your own mind what these
people do and say with you. You wonder how could you let yourself do this and why
do fhese peopte want to do this to you?'62
PROBLEMS OF LEGALIZATION
V. The overwhelming majority of women in prostitution want to escape it,
regardless of prostitution's legal status.
108. Women in prostitution tell researchers and service providers that what they
want are the same things in life that most people want: stable housing, a job that
affords them dignity and self-respect while paying for the basics in life,'medical
care, and protection and schooling for their children.
109. A Toronto, Canada report found that g0% of women in prostitution wanted to
leave prostitution but could not.63 Our study in Vancouver, Canada revealed that
95% of women in Canadian prostitution wanted to escape it. s
u'
See Exhibit
"B"
(Farley, M., Cotton, A., Lynne, J., Zumbeck, S., Spiwak, F., Reyes, M.E.,
Alvarez , D., Sezgin, U. (2003) Prostitution and Trafficking in 9 Countries: Update on
Violence and Posttraumatic Stress Disorder. Journal of Trauma Practice 2 pl$:33-74
u'See
Exhibit
"H"
(Farley, M. (2003) Prostitution and the Invisibility of Harm. Women &
Therapv 26Ql $: 247 -280)
63
Elizabeth Fry Society of Toronto. (1987). Streetwork outreach with adult female
prostitutes: Final Report, 5: 12-13
uo
See Exhibit
"E" (Farley, M, Lynne, J, and Cotton, A (2005) Prostitution in Vancouver:
Violence and the Colonization of First Nations Women. Transcultural Psvchiatrv 42:242-271

-40-
110. ln a multicountry study of 854 people in prostitution in 9 countries including
Canada, we found that 89% of those in it wanted to escape prostitution.
111. In a study of legal Nevada prostitution, Slo/o told us they wanted to escape
it.66
W. Legalization of prostitution does not reduce the stigma of prostitution.
112. According to advocates of legalization or decriminalization of prostitution, the
primary harm of prostitution is the social stigma against prostitution. Those on all
sides of the debate agree that women in prostitution
are stigmatized. Socially
invisible as full human beings, those in prostitution often internalize toxic contempt,
misogyny, and racism directed against them.
1 13. Some have suggested that legalization or decriminalization would remove this
social prejudice against women in prostitution. Yet the shame of those in prostitution
remains after legalization or decriminalization.
114. Women in legal Dutch prostitution were concerned about their loss of
anonymity in systems of legal prostitution. Once officially registered as prostitutes,
Dutch women feared that this designation would pursue them for the rest of their
lives. Despite the fact that they would accrue pension funds if officially registered as
prostitutes, the women still preferred anonymity. They wanted to leave prostitution as
quickly as possible with no legal record of having been in prostitution.
65
See Exhibit
"B"
(Farley, M., Cotton, A., Lynne, J., Zumbeck, S., Spiwak, F., Reyes, M.E.,
Alvarez , D., Sezgin, U. (2003) Prostitution and Trafficking in 9 Countries: Update on
Violence and Posttraumatic Stress Disorder. Journal of Trauma Practice 2 QlQ.33-74)
uu
See Exhibit
"D"
(Farley, Melissa (2007) Prostitution and Traffickinq in Nevada. Makinq the
Connections. San Francisco: Prostitution Research and Education)
6s

-41 -
115. No one wants the business of prostitution operating in his community. Thus,
zoning of the physical locations of sex businesses is a sine qua non of legalization or
decriminalization. The regulation of prostitution by zoning is a physical manifestation
of its social/ psychological stigma. Whether in Turkish genelevs (walled-off multi-unit
brothel complexes) or in Nevada brothels (ringed with barbed wire or electric
fencing), women in state-zoned prostitution are physically isolated and socially
rejected by the rest of society.
X. In Nevada, despite legal prostitution, the women in it are strongly
stigmatized. They are treated as social outcasts.
1 16. The social stigma of Nevada brothel prostitution can be seen in everyday
conversation, in social practices, and in legal and illegal practices that isolate the
women in the brothels from the rest of the community.
Y. Legalization of prostitution does not make prostitution safer than illegal
prostitution.
117. A survivor of prostitution stated,
There are thousands of books and classes that provide women
with information on self-defense and rape "avoidance"
sfrafegies. Some of the basic /essons they teach us are not to
walk alone at night on dark deserted sfreefs, not to get into cars
with strange men, not to pick up guys in a bar, not to even let a
delivery man into your home when you're by yourself. Yef fhis is
what the "job" of prostitution requires; that women put
themselves in jeopardy every time they turn a trick. And then
we ask, "How do you prevent it from leading to danger?" The
answer is, you can't. Count the bodies."'
67
Evelina Giobbe (1991) The Vox Fights, VoX Winter 1991

-42-
1 18. Both legal and illegal sex businesses are places where sexual harassment,
sexual exploitation, and sexual violence occur with impunity. The definition of the
'Job"
of prostitution is sexual harassment and sexual exploitation.
119. lt is not possible to protect the health of someone whose 'Job" means that she
faces a statistical probability of weekly rape. A Canadian woman in prostitution
explained that"what is rape for others, is normalfor us."68 A woman at a brothel in
Nevada explained that legal prostitution was "like you sign a contract to be raped."6e
120. A majority of women in German, South African, andZambian prostitution
told
us that they did not think that legal prostitution
would make them physically
safer than
illegal prostitution.
121 . ln a 20A7 study of Nevada prostitution and ttafficking, we found that2To/o of
the women had been pressured or coerced into an act of prostitution in the legal
brothels, 24o/ohad been physically assaulted in legal prostitution, and 15% had been
threatened with a weapon in the legal brothels.
70
JOHNS
Z. Men who strongly support the institution of prostitution also tend to
express a tolerance for rape.
122. Among 783 college undergraduates in the US, those men who were
most accepting of statements rationalizing prostitution were also the most
accepting of rape myths (attitudes
that justify rape, for example:
'women say no but
uu
See Exhibit
"E"
(Farley, M, Lynne, J, and Cotton, A (2005) Prostitution in Vancouver:
Violence and the Colonization of First Nations Women.
un
Transcultural Psvchiatrv 42:242-271
see Exhibit
"D"
(Farley, Melissa (zoo7) Prostitution affi Makinq
the connections. san Francisco: Prostitution
ddsee
Research and Education)
Exhibit
"D" (Farley, Melissa (2007) Prostitution and Traffickinq in Nevada: Makinq the
Connections. San Francisco: Prostitution Research and Education)

-43-
mean yes,' 'dressing
provocatively causes rape,'
'women
lie about having been
raped').71
123. ln related findings, a study found a positive correlation between having
used a prostituted woman and finding rape generally
"appealing." 72 Another study
noted that arrested johns who purchased prostitutes at least once a week strongly
endorsed rape myths.73
AA. Recent research provides new empirical findings on the attitudes and
behaviors of men who buy sex in indoor and outdoor prostitution.
124. It has been established that violent behaviors against women are
associated with attitudes that promote men's beliefs that they are entitled to sexual
access to women, that they are superior to women, and that they have license for
sexual aggression.Ta
125. Prostitution Research & Education, the educational organization I am
affiliated with, has begun a cross-cultural study of men who buy sex. In
collaboration with agencies in India, Scotland, Cambodia, Spain, and USA, we
have interviewed hundreds of johns. These interviews have shed light on some of
the underlying attitudes and behaviors that drive men's demand for purchased sex.
7'
See Exhibit
"M"
(Cotton, A., Farley, M., Baron, R. (2002) Attitudes toward prostitution and
acceptance of rape myths. Journal of Applied Social Psychology 32: 1-8)
t'Sullivan,
E., & Simon, W. (1998). The client: A social, psychological, and behavioral look at the
unseen patron of prostitution. ln J. E. Elias, V. L. Bullogh, V. Elias, & G. Brewer (Eds.),
Prostitution: On whores. hustlers. and iohns (pp.134-154). New York: Prometheus Books
edictorsofrapemythacceptanceamongthema|e
clients of female street prostitutes. Paper presented at the Annual Meeting of the Pacific
Sociological Association. San Francisco, CA
to
White,J.W. & Koss, M.P. (1993). Adolescent Sexual Aggression Within
Heterosexual Relationships: Prevalence, Characteristics, and Causes. In Barbaree,
H.E., Marshall, W.L. & Laws, D.R.(eds.) The Juvenile Sex Offender. New York:
Guilford Press; Koss, M., Goodman, A., Browne, L., Fitzgerald, G., Keita, G., Russo,
N. (1994). No Safe Haven.Washington, D.C.: American PsychologicalAssociation

-44-
126. A man we interviewed explained that in prostitution,
Guys get off on controlling women, they use physical power to control
women, really. lf you look at it, it's paid rape. You're making them
subseryient during that time, so you're the dominant person She has
to do what you want.75
127 . We have recently completed data analysis on 1 10 johns in Scotland. A
2008 study, Challenging Men's Demand for Prostitution in Scotland: A Research
Repoft Based on lnteruiews with 110 Men Who Bought Women in Prostitufion, was
authored by Jan Macleod, Lynn Anderson, Jacqueline Golding and me. Some of
our findings are set out below.
BB. Men who paid for sex in Scotland held deeply contradictory attitudes
about prostitution.
128. Almost all (96%) of the men stated that to a significant extent (50% or more
of the time) prostitution was a consenting act between two adults. At the same
time, they held diametrically opposing attitudes about prostitution:73oh observed
that women prostitute strictly out of economic necessity and 85% stated that
women did not enjoy the sex of prostitution.
CG. The johns we interviewed endorsed a number of rape-tolerant attitudes.
129. A third of the johns stated that rape happens because men get sexually carried
away or their sex drive gets "ouf of control." 12o/o told us that the rape of a prostitute
or call girl was not possible. 10% asserted that the concept of rape simply does not
apply to women in prostitution. 22o/o of the men explained that once paid for, the
customer is entitled to do whatever he wants to the woman he buys.
tt "C"
See Exhibit (Melissa Farley (2000) Prostitution, Trafficking, and Cultural Amnesia: What
We Must Not Know in Order To Keep the Business of Sexual Exploitation Running Smoothly.
Yale Journal of Law and Feminism 18:109-144\

-45-
130. These attitudes clarify why prostitution is so dangerous for the women in it.
One of the men we interviewed stated, "They'll basically do anything for money." The
belief that the money they paid cancelled out the harm or exonerated the punter was a
recurring theme in our interviews.
DD. The iohns' frequency of use of women in prostitution impacted their
behavior toward non-prostituting women.
131 . Johns who were more frequent users of women in prostitution were also
significantly more likely to have committed sexually coercive acts against nonprostituting
women.
CONCLUSION
EE. Prostitution is not a choice according to the usual definition of the
word choice which implies free selection of an option among several
avai lable alternatives.
132. Just as wife beating was historically viewed as having been provoked by
the victim, prostitution
is still viewed by some as a job choice to which the victim
consents. This is an error. The great majority of those in prostitution - 85-95% -
tell us that they do not have alternatives to prostitution for survival.
133. Prostitution
is "chosen" as a job by those who have the fewest real
choices available to them. Women in legal Dutch prostitution describe it as
"volunteer
slavery." Women who are marginalized because of a lack of education,
because of race and ethnic discrimination, poverty, previous physical and
emotional harm and abandonment are the people who are purchased by the john
for prostitution.
134. lt is confusing to many that women in prostitution appear to consent to
prostitution. lt is only when one looks carefully at both the context of the consent,

-46_
as well as past traumatic abuses, that this apparent consent to and promotion of
prostitution by some women in the sex industry can be understood.
135. The critical question with respect to sex, race, and class-based
discrimination in prostitution is not "did she consent?" but "has she been offered
the real choice to exist without prostituting?" ln the following three cases, each
woman said that she consented to prostitution but in each situation, her living
conditions made prostitution necessary for survival. An Indian woman said that
prostitution was "better
pay for what was expected of her in her last job, anyway;"
women in most jobs in West Bengal, India, were expected to tolerate bosses'
sexual exploitation in order to keep their jobs.76 A woman in Zambia, which had a
ninety percent unemployment rate at the time, stated that she volunteered to
prostitute in order to feed her family.77 ATurkish woman was divorced, and had no
means of support in a fundamentalist state that discouraged women from working
outside the home. She applied to work in a state-run brothel where police guarded
the entrance.Ts
ll. Gomment Regarding the Methodology Used in my Research
136. ln psychology, the larger the number of interviews conducted using
standardized measures that can be replicated, the weightier the empirical
evidence. This is simply common sense: a single interview carries far less weight
than 850 interviews. When standardized conditions and measures are used to
assess large numbers of people, greater confidence is permitted in drawing
conclusions.
tu
Chattopadhyay, M., Bandyopadhyay, S., & Duttagupta, C. (1994). Biosocial
Factors Influencing Women to Become Prostitutes in India. Social Bioloqv 41.252-
259
77
Interview with Anonymous prostituting woman in Lusaka, Zambia (Feb. 17, 1996).
78
Interview with anonymous prostituted woman in lstanbul, Turkey (June 6, 1999)

-47-
137. ln my research, I use both quantitative and qualitative means of drawing
conclusions. The statistical analyses are conducted on the quantitative data. The
qualitative portion of the research -- individual respondents' comments and
testimony - are used to exemplify and clarify the empirical findings.
138. All research is permeated with values. Researchers have our opinions,
especially where gross violations of human rights are studied. tt is dangerously
naiVe for any researcher to assume that he or she is capable of absolute neutrality.
Generally, psychologists agree that all of us approach research with a certain
perspective in mind, and that we then posit hypothetical relationships, test them,
and draw conclusions. I have made my perspectives and the hypotheses that I
was evaluating clear in my research.
139. The research that I am presenting here - both my own and others' - has
been subject to peer review. When submitted to a psychology or social science or
medicaljournal, 3 reviewers who are experts in the field are asked by a journal
editor to do a blind review, that is, a review of the article that has the authors'
names removed. Each criticism and suggestion from every reviewer must be
considered and responded to in order to be considered for publication. This
process usually takes 6 months to a year.
140. Experts in psychological research who have reviewed my research have not
questioned the samples selected for study. When studying people who are
prostituting, it is understood by those who have done large-scale studies of
prostitution that anything resembling what is called a "random
sample" is
impossible. Each researcher does his or her best to clarify who was interviewed,
and how those people were contacted. This has been made very clear in all my
research.

-48-
141. ln psychological research, what is important is that the methodology is
clearly specified, how the samples are obtained is specified, and also that the
research questionnaires are described so that psychologists know what is being
used. Psychological tests are rarely if ever offered in their entirety in journals, as
this would compromise their future use by psychologists. Instead, author contact
information is given, so that only qualified individuals are supplied with the
measures so that they can replicate the research. Some of my research has been
replicated by other individuals.
142. When I began the study of prostitution, like other researchers, I assumed
that when I interviewed someone on the street, that was the only location where
they prostituted. I assumed that when I interviewed someone in a strip club, that
was the only location where she prostituted. And when I interviewed someone in a
coffee shop who told me that she worked in a massage parlor, I assumed that was
the only location where she prostituted. I was wrong. I have discovered that
almost everyone prostitutes in more than one location, often several locations, both
indoors and outdoors. Furthermore, the longer someone is in prostitution, the
more likely they are to prostitute in a great many locations, sometimes up to 5 or 6
different kinds of venues. Thus the absolute distinction between "street"
and
"indoor"
prostitution is outdated.
143. The assumption that if legal prostitution exists then the person will prostitute
only in legal venues - is also outdated. Researchers have now found that people
move back and forth between legal and illegal venues, depending on the money
earned and other factors.

-49-
III. DIRECT RESPONSES TO DR. LOWMAN'S ASSERTIONS
Direct response to Assertion #3 on page 148 of Dr. John Lowman's Affidavit
144. Dr. Lowman defines as opportunistic that prostitution in which
"a person
makes a choice to prostitute mainly because of the financial reward in a situation
where they do have other economic choices." He defines sexual slavery as a
situation where
"a person forces another to prostitufe" and survival sex as "a
person chooses to prostitute in a situation where they have very few or no other
choices."
145. Distinctions between opportunistic prostitution, sexual slavery, and
survival sex are impossible to detect in the real lives of women in prostitution. As I
point out in my Affidavit, 89% of the 854 women and men I have interviewed in g
countries stated that they were in prostitution because of a lack of alternatives. Dr.
Lowman's Assertion #3 does not clarify the nature of force or coercion which might
be poverty in some instances or a prior history of interpersonal abuse or violence in
others.
146. Historical analyses have distinguished more severe from less severe
harms associated with intrinsically harmful human institutions. Wife battering and
slavery serve as examples.
147. People in prostitution tell us that the harms that are invisible and that
leave no physical marks -relentless and toxic verbal abuse from pimps and johns
alike, mental degradation, brainwashing, social isolation, the requirement that they
smile while being harmed or else their children will be harmed - are the harms that
last the longest, leave the most damaging emotional scars, and in some instances
never heal. These are also precisely the harms that are ignored when we futilely
attempt to distinguish opportunistic prostitution, survival sex, and sexual slavery.

-50-
148. This categorization of different types of prostitution ignores the structural
inequities of sex inequality, poverty and class privilege, and racism that relentlessly
channel women into prostitution. These are forces that truly coerce women into
making the "choice"
of prostitution. As one survivor eloquently stated, prostitution
is the "choice
that is not a choice."
Direct response to Assertion #26 on page 158 of Dr. John Lowman's Affidavit
149. While the extreme violence that Dr. Lowman refers to as "overkill"
is
dramatic to the obseryor, many homicides of prostituted women occur by the john's
strangulation or suffocation of her in indoor prostitution.
Direct response to Assertion #30 on page 161 of Dr. John Lowman's Affidavit
150. Dr. Lowman stated that ". ..the vast maiority of women working in
massage parlours, escorf seryices or as independent operators have not
experienced any violence." There is an assumption here that physical violence is
the only kind of violence in prostitution. This is an error. My Affidavit has
described other kinds of interpersonal, mental, and emotional violence.
Direct response to Assertion #31 on page 162-'164 of Dr. John Lowman's
Affidavit
151. Some studies comparing indoor and outdoor prostitution have found
higher rates of violence in outdoor prostitution. Yet violence also occurs in indoor
prostitution at a level that is unacceptable. ln Dr. Lowman's charts from Tamara
O'Doherty's thesis, some rates of violence against women in indoor prostitution are
given.

-51
152. The difference between
"independents"
and "escorts"
is not clear unless
it is the case that "escorts"
are prostituting for a pimp who owns an agency.
Following are some examples of violence in these charts. Decimals are rounded
up or down based on whether the value is less than 5 or 5 or greater:
153. In escort prostitution,29o/o
were threatened by johns and 17o/o
threatened by a boss or pimp. 17o/owere threatened with a weapon. 25ohwere
physically assaulted by johns and 13% were sexually assaulted by johns. 21%
reported kidnapping by johns. These are significant rates of violence.
154. ln massage parlors, women reported that 13% were physically assaulted
and 137o were sexually assaulted by significant others. This finding speaks to the
surround of violence in prostitution, whether or not these significant others were
pimps, as is often the case. The assumption seems to be made that significant
others or bosses are not pimps, when this may not be true.
155. In independent prostitution, 15o/o of women reported threats from clients.
12% had been physically
assaulted and 1 2% had been sexually assaulted. 8%
reported kidnapping.
156. See my comments about indoor and outdoor prostitution stated in my
conclusions
"O
to
"Y"
above.
Direct response to Assertion #33 on page 164 of Dr. John Lowman's Affidavit
157. Dr. Lowman stated that women who prostitute in street prostitution
"begin
their work at quite a young age." ln our study of legal indoor Nevada
prostitution,23o/o also told us that they began prostituting as children.

-52-
Direct response to Assertion #41 on page 169 of Dr. John Lowman's Affidavit
158. The presence of a maid indoors does not protect women from rape,
attempted rape, strangulation or other physical violence. lt does not protect
women from toxic verbal abuse or emotional distress in response to acts of
prostitution. Even panic buttons in brothels fail to elicit a speedy enough response
from bouncers or security guards or maids to prevent johns' rapes or other
violence.
159. Flats are locations where extremely violent prostitution and trafficking of
Eastern European women into London takes place. Flats are also the locations
into which Asian women are increasingly trafficked into brothel prostitution on the
western coast of North America.
Direct response to Assertion#42 on page 170 of Dr. John Lowman's Affidavit
160. Dr. Lowman states that those in prostitution "combine"
prostitution on
the street with indoor locations. lt is obvious in this Assertion and as I have also
pointed out in this Affidavit that we can not separate the street and indoor
prostitution. Women are moved to wherever the demand for prostitution exists.
Direct response to Assertion #45 on page 171-2 of Dr. John Lowman's
Affidavit
161 . Dr. Lowman summarized the extreme violence reported in indoor
prostitution by Raphael and Shapiro: 50% of women in escort prostitution reported
rape, 51% of strip club dancers had been threatened with a weapon, 33% of
women using their homes as brothels had been threatened with rape or raped.
Where Dr. Lowman cites research studies with larger samples, his Affidavit bears
more similarity to the empirical studies that I am citing here.

-53-
162. On the other hand, anecdotal reports, often provided by individuals with
a political agenda to legalize prostitution, are simply one person's opinion rather
than scientific findings.
Direct response to Assertion #45 on page 172 of Dr. John Lowman's Affidavit
163. There is no evidence that survivors of prostitution are biased
interviewers any more than any other interviewer is biased. Libby Plumridge, a
New Zealand researcher whose data Dr. Lowman cites, employed currently
prostituting
women as interviewers.
164. As Ine Vanwesenbeeck drily remarked out in her landmark 1994 book
on Dutch prostitution, the most common bias in our field is that researchers tend to
view prostitution
from the john's perspective.
165. I make this affidavit in response to this application, and for no other or
improper purpose.
SWORN before me at the City of San
Francisco, in the State of California, on
this day of April, 2008.
Commissioner for Taking Affidavits Melissa Farley

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-23-
Canadian population, and also that they tended to stay in prostitution for a longer
time than non-Aboriginal women. The authors interpret this to reflect the Aboriginal
women's poverty and lack of access to other opportunities because of racism. The
Aboriginal women reported being more frequently sexually harassed or assaulted by
police than non-Aboriginal women.3o
PIMPS
H. A majority of women in legal and illegal prostitution have pimps who
control them either mentally or physically.
51. lt is an error to assume that legal prostitution will remove the crime of
pimping. Half of the women interviewed in a recent study of legal Nevada
prostitution reported that they had pimps. Furthermore, they usually did not define
their husbands and boyfriends as pimps even though they were supporting these
men vra prostitution. Thus the actual percentage of women in legal prostitution
who are controlled by pimps may be even higher than 50%.
52. Legal brothels often have a "double
layer" of pimps: the legal pimp who runs
the brothel and an illegal pimp who controls the woman's income, outside the legal
brothel.
l. Pimps use many of the methods used by torturers to mentally control
women in prostitution.
53. These techniques include social isolation, sensory deprivation/ torture,
deliberately induced exhaustion and physical debilitation, threats to the woman in
prostitution and to her family, occasional reprieves and indulgences, posturing as
omnipotent, degradation and enforced dependency, enforcing capricious rules,
deliberate creation of dissociated parts of the self who happily and willingly
to
Nixon, K. Tuttly, L., Down P., Gorkoff, K., Ursel, J. (2002)
"The
Everyday Occurrence:
Violence Against Women", Vol. 8, No. 9: 1016-1043