Exhibit A - Dr. Mintz Report — USA v. Qureshi (Dkt. 20-1, D. Md.)

Record facts

U.S. District Court for the District of Maryland · No. 1:22-cr-00330-JKB · Doc. 20-1 · 2023-08-29 · Docket on CourtListener

Full text

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COMPETENCY EVALUATION 
Confidential 
 
Name:  
 
  Ayaz Qureshi 
Dates of Evaluation:   February 1 & February 6, 2023 
Evaluator:            
  Michael Mintz, Psy.D. 
 
Date of Report:  
  February 23, 2023 
 
EVALUATION PROCEDURES 
 
● Clinical interview 
● Collateral interview with Sarwad Naheed (wife) 
● Test of Memory Malingering (TOMM) 
● Wechsler Adult Intelligence Scales – Fourth edition (WAIS-IV) 
● Woodcock-Johnson Tests of Oral Language 
● Select subtests from the Woodcock-Johnson IV Test of Achievement (WJ-A) 
● Wisconsin Card Sorting Test (WCST) 
● Behavioral Rating Inventory of Executive Function – Second edition (BRIEF-2) 
                          -Adult informant form, completed by Ms. Naheed 
   
 
The testing measures and interviews were administered in English. The evaluation is based on 
approximately five hours of face-to face contact. The first session took place in-person in 
Washington, D.C., while the second session took place via a HIPAA-compliant telemedicine 
program (Zoom).  
 
Identifying Information and Reason for Referral 
Ayaz Qureshi is a 53-year-old, married male from Pakistan. He has been living in the United 
States since approximately age 30. He was referred by his attorney for a psychological 
evaluation to assess his cognitive functioning as it pertains to the crimes of which he has been 
accused. The evaluation also aims to consider whether he has the cognitive or reading skills to 
comprehensively understand the arrangements of his plea bargain.  
 
Behavioral Observations and Mental Status 
Mr. Qureshi appears to be his stated age. He arrived on time to the evaluation and noted that he 
had arrived at the building three hours early to ensure that he would not be late. During the 
evaluation, he seemed well-oriented to person, place, and time, and he showed no signs of 
thought disorder. He was friendly and cooperative throughout the evaluation. His reported mood 
was neutral/normal, and his affect during the evaluation matched his reported mood. His speech 
was normal in pitch, rate, and volume.  
 
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Mr. Qureshi answered questions and was open and forthcoming throughout the evaluation, 
However, his responses were tangential, as he provided winding responses that, in many 
instances, were only indirectly related to the question posted. More generally, he had difficulty 
providing a cohesive and coherent narrative, even in respect to his broader biography. Some of 
these challenges may have been associated with the fact that English is not his first language. 
However, he also struggled to answer simple biographical questions, such as those associated 
with his educational history. Mr. Qureshi admitted that he always has difficulty recalling dates 
and timeframes, and he was not able provide the years (or what age he was) when specific events 
took place. More generally, the examiner had to repeat questions numerous times, as Mr. Qureshi 
seemed not to understand the content of the question.  
 
Mr. Qureshi had difficulty on formal cognitive testing, particularly in respect to verbal tasks. Of 
note, Urdu is his first language, and he indicated that, when presented with verbal information, 
he had to mentally translate the verbal prompts into Urdu in order to fully understand them. 
Given the referral question (i.e., associated with criminal activity and plea deals presented in 
English), the administration of these measures without interpreting the items into Urdu is 
appropriate, as his verbal deficits accurately reflect his cognitive and verbal functioning in the 
English language (i.e., reading, listening, comprehending, and/or writing in English).  
 
Based on formal testing measures administered as part of this evaluation, Mr. Qureshi’s 
intelligence is estimated to be in the borderline range of functioning, at least in terms of his 
verbal skills in English. It is likely that Mr. Qureshi would have performed better in his native 
language of Urdu. Of note, Mr. Qureshi performed in the borderline range on several nonverbal 
tasks, as well, suggesting broader cognitive deficits (even if linguistic issues are accounted for).  
 
Relevant History  
Mr. Qureshi was the youngest of eight children born and raised in Lahore, Pakistan. He was 
primarily raised by his mother, as his father lived out of the home in order to earn a living in as a 
laborer in a shipyard.  
 
Mr. Qureshi’s mother physically abused him throughout much of his early childhood, in part 
because he “could not pay attention.” He often felt that his mother “was hitting [him even though 
he] was not doing anything wrong.”  
 
Mr. Qureshi only briefly attended school, and he struggled academically and socially. He “was 
shy and quiet” at school, and he did not adjust well to school. He had learning problems 
throughout his brief academic career. He only attended school for a few years before dropping 
out and, even then, his attendance was inconsistent.  
 
Mr. Qureshi started working at young age, as his mother asked his brother-in-law to teach him 
how to earn money by trading at the local market. He started working alongside his brother-in-
law around age 14 or 15, and he worked in market for year or two. At that point, his brother-in-
law and his brother helped him open his own business, as his brother had started importing goods 
to Pakistan by that time.  
 
In 2000, Mr. Qureshi came to the United States, along with his first wife, who was a United 
States citizen. The marriage did not last, however, and he returned to Pakistan, where he met Ms. 
Naheed in 2004; they were married just a few days later (i.e., arranged marriage).  
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Mr. Qureshi then returned to the United States, visiting Ms. Naheed in Pakistan and having two 
children prior to her immigration a few years later. Mr. Qureshi worked at a gas station and later 
worked for the post office (doing nighttime deliveries), delivering pizza, and delivering auto 
parts. Mr. Qureshi and Ms. Naheed had their third child together in the United States. Their 
second child was later diagnosed with an autism spectrum disorder (ASD) and an attention-
deficit/hyperactivity disorder (ADHD). 
 
Mr. Qureshi tried to learn various trades, though he struggled as a business owner. He invested in 
a friend’s beauty supply business, though his business partner had a stroke, leaving Mr. Qureshi 
with approximately $150,000 worth of supplies and no means to sell it. Around that time, 
another friend (Mustapha) suggested that they open a pizza shop together, and Mr. Qureshi 
invested $27,000 in the business. By this time, Mr. Qureshi’s credit score had diminished, and 
Mustapha suggested that they met with the partner’s acquaintance (Adam) who was an expert in 
improving credit scores. Adam also told Mr. Qureshi that he could help him obtain a government 
loan. (Mr. Qureshi hoped to help finance a project in Pakistan.) 
 
Adam told Mr. Qureshi that he had to sign documents that very day, noting that the window to 
apply for the loan was closing quickly. Mr. Qureshi blindly trusted Adam. He was excited when 
the loan came through, though he was worried to learn that the loan was for much more money 
than Mr. Qureshi originally wanted. Mr. Qureshi planned to repay the loan in total, and he 
returned large sums to Adam with the expectation that Adam would pay off some of the loan.  
 
In retrospect, Mr. Qureshi recognizes that Adam took advantage of him, as Adam seems to have 
recognized that Mr. Qureshi did not have the awareness or reading abilities to understand the 
complex paperwork he had signed without reviewing properly. Mr. Qureshi stated that he had 
every intention of paying back the loan and that he never understood that it was a loan based on 
previously paid salaries (i.e., a PPP loan).  
 
Collateral interview (wife) 
Ms. Naheed met Mr. Qureshi met in Pakistan in 2004, and they were married a few days later; 
the marriage was arranged by their families. Mr. Qureshi returned to the United States a few 
weeks later, and they maintained the marriage via long-distance. They had two children over the 
following years, and Ms. Naheed joined him in Pasadena, Maryland, in 2008. At that time, Mr. 
Qureshi was doing driving and delivery work. Their youngest child was born in 2013.  
 
Ms. Naheed indicated that “everything changed” for Mr. Qureshi when his brother was murdered 
in 2006 in Pakistan. Ms. Naheed and Mr. Qureshi later learned that his brother had been 
murdered by his wife. Mr. Qureshi was devastated by his brother’s death, as they had been 
extremely close.  
 
Several years ago, Ms. Naheed’s and Mr. Qureshi’s second child was diagnosed with an autism 
spectrum disorder (ASD) and an attention-deficit/hyperactivity disorder (ADHD). Ms. Naheed 
noted that Mr. Qureshi “has the same thing” as their daughter, as he has difficulty focusing on 
conversations or tasks. He also has a poor memory and needs reminding to complete tasks, for 
example. He does not read well and often gets distracted when trying to read something. Ms. 
Naheed noted that Mr. Qureshi did not have much education in Pakistan.  
 
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Due to his attention and reading problems, Ms. Naheed manages the family’s finances. She does 
not trust Mr. Qureshi to manage bills and other financial documents due to his academic and 
attention deficits.  
 
Ms. Naheed believes that Mr. Qureshi was “pressured into” signing the documentation 
requesting a PPP loan. She described Mr. Qureshi as overly trusting of others, noting that “he 
will believe anything.” She also noted that he does not have the reading abilities or the attention 
span to read documentation thoroughly before signing it.  
 
TEST RESULTS 
The instruments utilized in this evaluation have been normed on a United States population. 
Individuals from south Asia (including Pakistan) are included in the normative sample in 
numbers that approximate their percentage of the overall United States population. However, the 
normative sample may not include individuals who speak Urdu as their primary language. This 
should be taken into account when considering the results of these tests. Nevertheless, the tests 
yield valuable information concerning the subject.  
 
Scoring Conventions and Abbreviations: AE=Age Equivalent; PR=Percentile Rating; 
SS=Standard Score 
 
Standard scores have a median of 100 and variances in either direction of 15 points or more are 
considered significant; Percentile Ratings indicate what percentage of peers have lower scores. 
For example, a score in the 38th percentile means the performance is superior to 38% of peers. 
Scaled Scores are based on a mean of 10, with differences of three or more being significant.  
 
Test of Memory Malingering 
The Test of Memory Malingering (TOMM) is a 50-question visual memory recognition test that 
discriminates between true memory impairment and malingering, with two learning trials and an 
optional retention trial following a delay. Mr. Qureshi’s performance (46 out of a best possible 
score of 50) on the TOMM is not indicative of malingering or intentionally exaggerating 
symptoms. As such, it is very likely that Mr. Qureshi was putting forth his best effort on all 
testing measures he attempted.  
 
Intellectual Functioning: WAIS-IV 
Mr. Qureshi was administered ten subtests of the Wechsler Adult Intelligence Scale - Fourth 
edition (WAIS-IV) from which his composite scores are derived. Mr. Qureshi’s unique set of 
thinking and reasoning abilities make his overall intellectual functioning difficult to summarize 
by a single score on the WAIS-IV. His nonverbal reasoning abilities are much better developed 
than his verbal reasoning abilities. Processing complex visual information by forming spatial 
images of part-whole relationships and/or by manipulating the parts to solve novel problems 
without using words is a strength. Making sense of complex verbal information and using verbal 
abilities to solve novel problems are weaknesses for Mr. Qureshi. 
 
Verbal Comprehension 
Mr. Qureshi’s verbal reasoning abilities as measured by the Verbal Comprehension Index (VCI) 
are in the borderline range and above those of only 3% of his peers (VCI = 72; 95% confidence 
interval = 67-79). The VCI is designed to measure verbal reasoning and concept formation. Mr. 
Qureshi’s performance on the verbal subtests contributing to the VCI presents a diverse set of 
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verbal abilities, as he performed much better on some verbal tasks than others. The degree of 
variability is unusual and may be noticeable to those who know him well. Examination of Mr. 
Qureshi’s performance on individual subtests provides additional information regarding his 
specific verbal abilities. 
 
Mr. Qureshi demonstrated his weakest performance among the verbal reasoning tasks on the 
Similarities and Vocabulary subtests. His weak performances on the Similarities and Vocabulary 
subtests were far below that of most of his peers. On the Similarities subtest, Mr. Qureshi was 
required to respond orally to a series of word pairs by explaining how the words of each pair are 
alike. This subtest examines his ability to abstract meaningful concepts and relationships from 
verbally presented material (Similarities scaled score = 3). On this subtest, Mr. Qureshi often 
provided concrete aspects of related items (i.e., stating that two animals are alike by remarking 
on their common characteristic of having “four legs…and a tail” rather than simple noting that 
they are both animals). When queried for more details, he repeatedly started describing how two 
items or concepts are different (i.e., stating that an automobile drives on the street while a boat 
floats in the water). On several occasions, he required redirection to the task of focusing on 
similarities. In response to a few prompts, he simply stated that the two concepts are not alike. 
 
The Vocabulary subtest required Mr. Qureshi to explain the meaning of words presented in 
isolation. As a direct assessment of word knowledge, the subtest is one indication of his overall 
verbal comprehension. Performance on this subtest also requires abilities to verbalize meaningful 
concepts as well as to retrieve information from long-term memory (Vocabulary scaled score = 
4). On this subtest, Mr. Qureshi often used the specific word in a sentence or otherwise related 
the word to his own experience, such as by defining curious as: “when I was young, I was 
watching drama…watching how it happened.”  
 
Perceptual Reasoning 
Mr. Qureshi’s nonverbal reasoning abilities as measured by the Perceptual Reasoning Index 
(PRI) are in the average range and above those of approximately 39% of his peers (PRI = 96; 
95% confidence interval = 90-102). The PRI is designed to measure fluid reasoning in the 
perceptual domain with tasks that assess nonverbal concept formation, visual perception and 
organization, visual-motor coordination, learning, and the ability to separate figure and ground in 
visual stimuli. Mr. Qureshi presents a diverse set of nonverbal abilities, performing much better 
on some nonverbal tasks than others. The degree of variability is unusual for individuals his age 
and may be noticeable to those who know him well. 
 
Mr. Qureshi’s performance was significantly better on the Block Design and Visual Puzzles 
subtests than his own mean score. Furthermore, he performed better than most of his peers, thus 
demonstrating strong abilities on the Visual Puzzles subtest. 
 
The Block Design subtest required Mr. Qureshi to use two-color cubes to construct replicas of 
two-dimensional, geometric patterns. This subtest assesses nonverbal fluid reasoning and the 
ability to mentally organize visual information. More specifically, this subtest assesses his ability 
to analyze part-whole relationships when information is presented spatially. Performance on this 
task also may be influenced by visual-spatial perception and visual perception-fine motor 
coordination, as well as planning ability (Block Design scaled score = 10). On Block Design, Mr. 
Qureshi took a methodical approach, trying to match his blocks to the image one-by-one.  
 
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The Visual Puzzles subtest required Mr. Qureshi to view a completed puzzle and select three 
response options that, when combined, reconstruct the puzzle, and do so within a specified time 
limit. This subtest is designed to measure nonverbal reasoning and the ability to analyze and 
synthesize abstract visual stimuli. Performance on this task also may be influenced by visual 
perception, broad visual intelligence, fluid intelligence, simultaneous processing, spatial 
visualization and manipulation, and the ability to anticipate relationships among parts (Visual 
Puzzles scaled score = 13). Mr. Qureshi performed better on this subtest than on any other 
subtest of the WAIS-IV, reflecting a relative strength for him.  
 
Working Memory 
Mr. Qureshi’s ability to sustain attention, concentrate, and exert mental control is in the low 
average range. He performed better than approximately 18% of his peers in this area (Working 
Memory Index [WMI] = 86; 95% confidence interval 80-94). 
 
Mr. Qureshi’s abilities to sustain attention, concentrate, and exert mental control are better 
developed than his verbal reasoning abilities but not as robust as his perceptual reasoning 
abilities. Mr. Qureshi performed in the low average range when asked simple arithmetic 
questions orally (Arithmetic scaled score = 8). He performed slightly less well on Digit Span 
(scaled score = 7), which required him to recite number sequences.  
 
Processing Speed 
Mr. Qureshi’s ability in processing simple or routine visual material without making errors is in 
the extremely low range when compared to his peers. He performed better than approximately 
0.3% of his peers on the processing speed tasks (Processing Speed Index [PSI] = 59; 95% 
confidence interval 55-71). Processing visual material quickly is an ability that Mr. Qureshi 
performs poorly as compared to his nonverbal reasoning ability. Processing speed is an 
indication of the rapidity with which Mr. Qureshi can mentally process simple or routine 
information without making errors. Because learning often involves a combination of routine 
information processing (such as reading) and complex information processing (such as 
reasoning), a weakness in the speed of processing routine information may make the task of 
comprehending novel information more time-consuming and difficult for Mr. Qureshi. Thus, this 
weakness in simple visual scanning and tracking may leave him less time and mental energy for 
the complex task of understanding new material. Of note, the subtests that comprise the PSI 
(Coding and Symbol Search) are devoid of language (aside from the initial instructions, which 
are quite basic). As such, his poor performance on these tasks indicates that his cognitive deficits 
are not exclusively associated with the fact that the WAIS-IV was administered in English 
(versus his native language of Urdu).  
 
Tests of Oral Language: WJ-IV 
Mr. Qureshi’s oral language skills were assessed using the Woodcock-Johnson Tests of Oral 
Language. Mr. Qureshi’s performance on this test will be described using Standard Scores, 
which provides an estimate of how he compares to individuals of his age group. Standard Scores 
of 90-110 are considered to be in the average range. Percentile rankings (PR) indicate where he 
stands in relationship to his peers on a percentile basis (i.e., a PR of 47 indicates he performs 
better than 47% of his peers). In addition, his performance will be described using the Relative 
Proficiency Index (RPI), which provides a more accurate understanding of the level of difficulty 
that the student may experience when attempting to master a skill in the classroom. RPI scores 
indicate the level of proficiency of the individual, compared to the level of proficiency expected 
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for the average individual of his age. Scores higher than 82/90 are considered age appropriate, 
and individuals who perform at this level or higher are expected to find those particular tasks 
manageable. The lower the score is below 82/90, the greater the difficulty the individual is likely 
to have managing those tasks. Mr. Qureshi’s performance on this test will also be described 
using Age equivalents (AE), which indicate the performance of the average child of that age.  
  
On the Woodcock-Johnson Tests of Oral Language, Mr. Qureshi performed in the very low range 
on the majority of subtests. His Oral Language standard score of 51 (PR=<0.1; RPI=4/90) has an 
age-equivalence of 6 years, 7 months, suggesting that his overall oral language skills are on par 
with the average child of this age.  
 
Mr. Qureshi displayed relative strengths on subtests of the WJ-IV Tests of Oral Language that 
were solely based on sounds (rather than specific words). He performed in the average range on 
the Phonetic Coding cluster (SS=90; PR=25; RPI=67/90; AE=8-6). This suggests a relative 
strength in respect to perceiving specific sounds.  
 
Aside from the Phonetic Coding cluster, all other cluster scores are in the very low range. His 
Broad Oral Language cluster standard score is 51 (PR=<0.1; RPI=7/90; AE=6-7). His Oral 
Expression cluster standard score is <40 (PR=<0.1; RPI=0/90; AE=4-9), indicating that his 
ability to express himself orally is approximately as poor as his ability to comprehend oral 
language (i.e., Listening Comprehension cluster standard score is 49 (PR=<0.1; RPI=8/90; 
AE=6-2).  
 
Taken as a whole, Mr. Qureshi’s oral language skills are extremely poor, even when taking into 
account the fact that English is not his first language. 
 
Achievement: WJ-IV 
 
Mr. Qureshi’s academic achievement skills were assessed using select subtests from the WJ-IV. 
The Woodcock-Johnson IV Tests of Achievement (WJ-IV) is a nationally standardized measure 
of academic achievement. In Mr. Qureshi’s case, subtests were administered in the areas of 
reading, math, and writing. Mr. Qureshi’s performance on the WJ-IV will be described using 
Standard Scores, which provides an estimate of how he compares to individuals of his age group. 
Standard Scores of 90-110 are considered to be in the average range. Percentile rankings (PR) 
indicate where he stands in relationship to his peers on a percentile basis (i.e., a PR of 47 
indicates he performs better than 47% of his peers). In addition, his performance will be 
described using the Relative Proficiency Index (RPI), which provides a more accurate 
understanding of the level of difficulty that the student may experience when attempting to 
master a skill in the classroom. RPI scores indicate the level of proficiency of the individual, 
compared to the level of proficiency expected for the average individual of his age. Scores higher 
than 82/90 are considered age appropriate, and individuals who perform at this level or higher 
are expected to find those particular tasks manageable. The lower the score is below 82/90, the 
greater the difficulty the individual is likely to have managing those tasks. 
 
Overall, Mr. Qureshi’s performance on the WJ-IV ranged between the low average and the very 
low range of academic functioning.  
 
 
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Reading  
Mr. Qureshi’s performance on Reading is in the very low range. His performance on Passage 
Comprehension (SS = 57; PR = 0.2; RPI = 1/90) as in the very low range, as he displayed a poor 
ability to understand simple sentences and fill in the blank with the appropriate word. His 
performance on Reading Fluency (SS = 47; PR = <0.1; RPI = 0/90) was even lower, as he read 
short, simple sentences at a slow rate.  
 
Math  
Mr. Qureshi’s performance on Calculation (SS=83; PR=13; RPI = 36/90) was in the low average 
range, which is a relative strength of his academic profile.  
 
Writing 
Mr. Qureshi’s performance on Writing Samples (SS=57; PR = 0.2; RPI = 2/90) is in the very low 
range, as he was unable to write even simple complete sentences. His Spelling skills are also in 
the very low range (SS = 62; PR = 1; RPI = 1/90).  
 
Executive Functions & Attention: WAIS-IV; WJ-IV; BRIEF; WCST 
Executive functions involve the organization and integration of behaviors needed to achieve a 
goal. It involves the ability to initiate and maintain problem-solving behavior, abstract thought 
and to change behavior when circumstances dictate.  
 
The WCST is a test of shift, sustaining attention, flexibility of thinking and the use of conceptual 
level thinking to solve a problem. Mr. Qureshi’s performance on the WCST was notable for 
rigidity and poor cognitive flexibility. He adjusted his approach on a few occasions but did not 
persist when he stumbled upon an approach that was working, instead returning to failing 
approaches. His scores were particularly poor in respect to Perseverative Responses (4th 
percentile), indicating a lack of flexibility in thinking when problem-solving and a relative 
inability to incorporate error messages into his problem-solving approach. Although given direct 
feedback that his strategy was not working, he was unable to adapt and find a different strategy, 
so he continued to use a failed strategy. He did not make use of conceptual thinking to help him 
solve problems on this test. Mr. Qureshi performed slightly better on other aspects of the WCST, 
with all other scores ranging between the 21st and 32nd percentiles.  
 
The Behavior Rating Inventory of Executive Function (BRIEF) is a questionnaire completed by 
a parent or domestic partner. In Mr. Qureshi’s case, it was completed by his wife (as noted 
above). The BRIEF is designed to provide a better understanding of an individual’s self-control 
and problem-solving skills by measuring eight aspects of executive functioning. The executive 
functions are mental processes that direct an individual’s thought, action, and emotion, 
particularly during active problem solving. Specific skills include (a) selecting appropriate goals 
for a particular task, (b) planning and organizing an approach to problem solving, (c) initiating a 
plan, (d) inhibiting (blocking out) distractions, (e) holding a goal and plan in mind, (f) flexibly 
trying a new approach when necessary, and (g) checking to see that the goal is achieved, (h) 
keeping emotions under control. The executive functions are also responsible for controlling an 
individual’s emotional responses, thereby allowing for more effective problem solving. 
 
On the BRIEF, high T-scores (and high percentiles) are indicative of challenges in terms of 
executive functioning. Low T-scores (and low percentiles) are not indicative of executive 
functioning challenges. Of note, none of the validity scales were elevated to significant degree, 
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as there was no indication that Ms. Naheed was overreporting symptoms, underreporting 
symptoms, or responding inconsistently to similar items.  
 
On Mr. Qureshi’s BRIEF profile, both index scales of the BRIEF were elevated in the clinically 
significant range. The Behavior Regulation Index score of 71 places Mr. Qureshi in the 95th 
percentile compared to peers, and the Metacognition Index score of 83 places him in the 99th 
percentile compared to peers. Both scores are indicative of severe deficits in terms of executive 
functioning. Additionally, ratings of Mr. Qureshi’s behavior across the nine specific scales of 
executive functioning assessed in the BRIEF generated the following results: 
 
1. Inhibit is the ability to resist impulses and to stop one’s behavior at the appropriate time. Mr. 
Qureshi’s score on the Inhibit scale of the BRIEF was elevated in respect to inhibition (T = 78, 
%ile = 99).  
 
2. The Self-Monitor scale assesses awareness of the impact of one’s own behavior on other people 
and outcomes. It captures the degree to which an individual is aware of the effect that his or his 
behavior has on others and how it compares with standards or expectations for behavior. Mr. 
Qureshi’s score on the Self-Monitor scale is elevated (T = 72, %ile = 96).  
 
3. The Shift scale assesses the ability to move freely from one situation, activity, or aspect of a 
problem to another as the circumstances demand. Key aspects of shifting include the ability to 
make transitions, tolerate change, problem solve flexibly, switch or alternate attention between 
tasks, and change focus from one task or topic to another. Mild deficits may compromise 
efficiency of problem solving and result in a tendency to get stuck or focused on a topic or 
problem, whereas more severe difficulties can be reflected in perseverative behaviors and 
marked resistance to change. Mr. Qureshi’s score on the Shift scale is elevated (T = 73, %ile = 
97). This suggests that Mr. Qureshi has difficulties adjusting to changes flexibly, such as changes 
in environment, plans, place, or demands.  
 
4. The Emotional Control scale measures the impact of executive function problems on emotional 
expression and assesses an individual’s ability to modulate or regulate his or his emotional 
responses. Mr. Qureshi’s score on the Emotional Control scale is within normal limits (T = 58 
%ile = 81).  
 
5. The Initiate scale reflects an individual’s ability to begin a task or activity and to independently 
generate ideas, responses, or problem-solving strategies. Mr. Qureshi’s score on the Initiate scale 
is elevated (T = 78, %ile = 99).  
 
6. The Working Memory scale measures online representational memory—that is, the capacity to 
hold information in mind for the purpose of completing a task; encoding information; or 
generating goals, plans, and sequential steps to achieve goals. Working memory is essential to 
carrying out multistep activities, completing mental manipulations such as mental arithmetic, and 
following complex instructions. Mr. Qureshi’s score on the Working Memory scale is elevated 
(T = 82, %ile = >99).  
 
7. The Plan/Organize scale measures an individual’s ability to manage current and future-oriented 
task demands. The scale has two components: Plan and Organize. The Plan component captures 
the ability to anticipate future events, to set goals, and to develop appropriate sequential steps 
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ahead of time to carry out a task or activity. The Organize component refers to the ability to 
bring order to information and to appreciate main ideas or key concepts when learning or 
communicating information. Mr. Qureshi’s score on the Plan/Organize scale is elevated 
compared with peers (T = 85, %ile = 99). This suggests that Mr. Qureshi has a particular 
difficulty with planning and organizing information. 
 
8. The Task-Monitor scale assesses task-oriented monitoring or work-checking habits. The scale 
captures whether an individual assesses his or his own performance during or shortly after 
finishing a task to ensure accuracy or appropriate attainment of a goal. Mr. Qureshi’s score on 
the Task-Monitor scale is elevated (T = 77, %ile = >99).  
 
9. The Organization of Materials scale measures orderliness of work, play, and storage spaces (e.g., 
desks, lockers, backpacks, and bedrooms). Caregivers and teachers typically can provide an 
abundance of examples describing an individual’s ability to organize, keep track of, or clean up 
his or his belongings. Mr. Qureshi’s score on the Organization of Materials scale is elevated (T = 
76, %ile = 98).  
 
SUMMARY & IMPRESSIONS: 
Ayaz Qureshi was referred by his attorney to assess his cognitive functioning as it pertains to the 
crimes of which he has been accused. The evaluation also aims to consider whether he has the 
cognitive or reading skills to comprehensively understand the arrangements of his plea bargain.  
 
Based on comprehensive cognitive testing, Mr. Qureshi’s verbal abilities are very poor. Of note, 
English is not Mr. Qureshi’s primary language. As such, his poor performance on verbal tasks is 
related, at least in part, to the fact that testing was administered in English. Testing was 
administered in English based on broad limitations (i.e., the examiner is not proficient in Urdu, 
and materials in Urdu were not available). However, given the nature of the case (i.e., the alleged 
crimes were based on forms completed in English), Mr. Qureshi’s English-language abilities are 
particularly relevant. Not only does Mr. Qureshi display verbal deficits in the extremely low 
range, but his reading abilities are generally on-par with the average reading abilities of seven-
year-old child. His oral language skills are similarly impaired.  
 
Mr. Qureshi’s broader cognitive profile is notable in that his nonverbal reasoning abilities are 
much better developed than his verbal reasoning abilities. His nonverbal reasoning abilities are in 
the average range. Despite the fact that his nonverbal reasoning abilities are a relative strength, 
Mr. Qureshi struggled on several subtests lacking a verbal component, suggesting that his 
cognitive deficits are not exclusively language-based and/or associated with the fact that English 
is not his primary language. He performed particularly poorly on tests assessing his processing 
speed. His processing speed is in the extremely low range and is even more impaired than his 
language skills. Mr. Qureshi also struggled on other tasks associated with sustained attention, 
and he may meet diagnostic criteria for attention-deficit/hyperactivity disorder (ADHD) (though 
further testing would be necessary to confirm the diagnosis).  
 
Mr. Qureshi’s executive functioning skills are also impaired. On the WCST, his performance 
was notable for rigidity and poor cognitive flexibility. Furthermore, based on his wife’s 
responses on a questionnaire assessing executive functioning, Mr. Qureshi has severe deficits 
across domains. He is disorganized and has trouble carrying tasks to completion.  
 
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11 
 
Based on the clinical findings detailed above, it is highly unlikely that Mr. Qureshi would have 
the verbal or executive functioning skills to manage the complex documentation required to 
navigate a complex, multi-step process on his own. Furthermore, his verbal deficits are likely to 
directly interfere with, and compromise his understanding of, complex legal proceedings. It is 
highly unlikely that he would be able to understand legal documentation in written or spoken 
form.  
 
Mr. Qureshi’s verbal deficits and executive functioning deficits may also impair his ability to 
assist his legal counsel in respect to any legal proceedings. Recommendations for optimizing his 
participation in such proceedings are as follows:  
 
1. Use simple language. (e.g., using the word “lawyer” rather than the word “attorney.”)  
2. Speak slowly, clearly, and calmly. Do not raise your voice or push the client too hard. 
Increasing his anxiety will only make it harder for Mr. Qureshi to understand.  
3. Use concrete terms and ideas.  
4. Avoid questions with multiple parts. (e.g., “Given what you said about X, how would you 
explain Y?” 
5. Mr. Qureshi’s attorney should be permitted to ask leading questions, as well as simple 
‘yes/no questions.’ Additionally, follow-up questions may be necessary in order to clarify 
his response.  
6. Repeat questions from a slightly different perspective using slightly different language. 
This will help make sure that Mr. Qureshi is not merely parroting answers.  
7. Proceed slowly and give praise and encouragement.  
8. Avoid frustrating questions about time, complex sequences, or reasons for behavior. (e.g., 
avoid asking, “How long ago was that?” as Mr. Qureshi may struggle to keep track of 
dates.)  
9. Be sure that not to show potential frustration towards Mr. Qureshi, as he will likely sense 
it and become overwhelmed, anxious and/or less cooperative.  
10. Highlight important information to improve memory retention. (For example, say, “Now 
pay attention. What I’m about to say is very important and you need to remember this... 
[then provide the information].”)  
11. Repeat important information. This also helps with memory retention.  
12. Cut down on distractions, such as the amount of people in the room.  
13. If Mr. Qureshi does not communicate effectively or responds inappropriately to 
questions, give his direct, explicit feedback. (e.g., “No, that’s not right” or “You’re 
saying it too fast - slow down.”)  
 
I would be happy to be of further assistance in this matter, as long as the appropriate consent 
form is signed by Mr. Qureshi.  
 
 
 
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12 
 
 
TABLE OF SCORES 
 
 
Composite Score Summary 
Scale 
Sum of 
Scaled Scores 
Composite 
Score 
Percentile 
Rank 
95% Conf. 
Interval 
Qualitative 
Description 
Verbal 
Comprehension 
15 
VCI
72 
3 
67-79 
Borderline 
Perceptual Reasoning 
28 
PRI
96 
39 
90-102 
Average 
Working Memory 
15 
WMI
86 
18 
80-94 
Low Average 
Processing Speed 
5 
PSI
59 
0.3 
55-71 
Extremely Low 
Full Scale 
63 
FSIQ
75 
5 
71-80 
Borderline 
General Ability 
43 
GAI
81 
10 
77-87 
Low Average 
Confidence Intervals are based on the Overall Average SEMs. 
The GAI is an optional composite summary score that is less sensitive to the influence of 
working memory and processing speed. Because working memory and processing speed are vital 
to a comprehensive evaluation of cognitive ability, it should be noted that the GAI does not have 
the breadth of construct coverage as the FSIQ. 
 
 
Note. The vertical bars represent the standard error of measurement (SEM). SEM values are 
based on the examinee's age. 
 
 
ANALYSIS 
 
Index Level Discrepancy Comparisons 
Comparison 
Score 1 
Score 2 
Difference 
Critical 
Value 
.05 
Significant 
Difference 
Y/N 
Base Rate by 
Overall 
Sample 
VCI - PRI 
72 
96 
-24 
7.78 
Y 
3.7 
VCI - WMI 
72 
86 
-14 
8.31 
Y 
14.1 
VCI - PSI 
72 
59 
13 
11.76 
Y 
20.3 
PRI - WMI 
96 
86 
10 
8.81 
Y 
23.7 
PRI - PSI 
96 
59 
37 
12.12 
Y 
0.8 
WMI - PSI 
86 
59 
27 
12.47 
Y 
4.3 
FSIQ - GAI 
75 
81 
-6 
3.29 
Y 
12.4 
Base Rate by Overall Sample. 
Statistical significance (critical value) at the .05 level. 
 
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13 
 
Verbal Comprehension Subtests Summary 
Subtest 
Raw Score Scaled Score 
Percentile 
Rank 
Reference 
Group Scaled 
Score 
SEM 
Similarities 
10 
3 
1 
3 
1.04 
Vocabulary 
12 
4 
2 
4 
0.73 
Information 
11 
8 
25 
9 
0.73 
 
Perceptual Reasoning Subtests Summary 
Subtest 
Raw Score Scaled Score 
Percentile 
Rank 
Reference 
Group Scaled 
Score 
SEM 
Block Design 
38 
10 
50 
8 
0.95 
Matrix Reasoning 
8 
5 
5 
4 
0.95 
Visual Puzzles 
18 
13 
84 
11 
0.85 
 
Working Memory Subtests Summary 
Subtest 
Raw Score Scaled Score 
Percentile 
Rank 
Reference 
Group Scaled 
Score 
SEM 
Digit Span 
21 
7 
16 
6 
0.73 
Arithmetic 
12 
8 
25 
9 
0.90 
 
Processing Speed Subtests Summary 
Subtest 
Raw Score 
Scaled Score 
Percentile 
Rank 
Reference 
Group Scaled 
Score 
SEM 
Symbol Search 
13 
3 
1 
3 
1.56 
Coding 
22 
2 
0.4 
1 
1.20 
 
Subtest Level Discrepancy Comparisons 
Subtest Comparison 
Score 1 
Score 2 
Difference 
Critical 
Value 
.05 
Significant 
Difference 
Y/N 
Base 
Rate 
Digit Span - Arithmetic 
7 
8 
-1 
2.57 
N 
42.20 
Symbol Search – 
Coding 
3 
2 
1 
3.41 
N 
42.60 
Statistical significance (critical value) at the .05 level. 
 
 
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14 
 
 
TESTS ADMINISTERED 
Woodcock-Johnson IV Tests of Oral Language (Norms based on age 53-8) 
Woodcock-Johnson IV Tests of Achievement Form A and Extended (Norms based on age 53-8) 
TABLE OF SCORES 
Woodcock-Johnson IV Tests of Oral Language (Norms based on age 53-8) 
CLUSTER/Test 
AE GE RPI SS (95% Band) SS Classification PR 
ORAL LANGUAGE 
6-7 
1.2 
4/90 
51 (43-59) 
Very Low 
<0.1 
BROAD ORAL LANGUAGE 6-7 
1.2 
7/90 
51 (45-57) 
Very Low 
<0.1 
ORAL EXPRESSION 
4-9 <K.0 0/90 <40 (<40-46) 
Very Low 
<0.1 
LISTENING COMP 
6-2 K.8 
8/90 
49 (41-56) 
Very Low 
<0.1 
PHONETIC CODING 
8-6 
3.1 67/90 
90 (84-96) 
Average 
25 
SPEED of LEXICAL 
ACCESS 
7-10 2.4 30/90 
69 (60-78) 
Very Low 
2 
Picture Vocabulary 
7-7 
2.2 
7/90 
61 (51-70) 
Very Low 
0.5 
Oral Comprehension 
6-0 K.5 
2/90 44 (<40-55) 
Very Low 
<0.1 
Segmentation 
7-1 
1.6 30/90 
84 (77-91) 
Low Average 
14 
Rapid Picture Naming 
8-1 
2.7 19/90 
76 (66-86) 
Low 
6 
Sentence Repetition 
3-4 <K.0 0/90 <40 (<40-46) 
Very Low 
<0.1 
Understanding Directions 
6-6 
1.1 26/90 
67 (59-74) 
Very Low 
1 
Sound Blending 
13-10 8.4 90/90 100 (92-109) 
Average 
51 
Retrieval Fluency 
7-5 
2.0 44/90 
67 (54-80) 
Very Low 
1 
Sound Awareness 
7-3 
1.8 34/90 
73 (65-81) 
Low 
3 
  
Woodcock-Johnson IV Tests of Achievement Form A and Extended (Norms based on age 53-8) 
CLUSTER/Test 
AE GE RPI SS (95% Band) SS Classification PR 
WRITTEN LANGUAGE 
7-3 
1.9 
1/90 
55 (49-62) 
Very Low 
0.1 
Spelling 
7-11 2.5 
1/90 
62 (56-68) 
Very Low 
1 
Passage Comprehension 
7-2 
1.7 
1/90 
57 (50-64) 
Very Low 
0.2 
Calculation 
10-5 5.0 36/90 
83 (75-90) 
Low Average 
13 
Writing Samples 
6-10 1.4 
2/90 
57 (46-67) 
Very Low 
0.2 
Sentence Reading Fluency 
6-10 1.4 
0/90 47 (<40-56) 
Very Low 
<0.1 
  
  
 
STANDARD SCORES 
DISCREPANCY Interpretation at 
VARIATIONS 
Actual Predicted Difference 
PR 
SD 
+ or - 1.50 SD 
(SEE) 
Intra-Oral Language [Extended] Variations 
ORAL EXPRESSION 
<40 
70 
 
0.2 
-2.93 
Weakness 
LISTENING COMP 
49 
73 
-24 
1 
-2.45 
Weakness 
PHONETIC CODING 
90 
75 
15 
89 
+1.23 
-- 
SPEED of LEXICAL 
ACCESS 
69 
74 
-5 
35 
-0.40 
-- 
Picture Vocabulary 
61 
72 
-11 
15 
-1.03 
-- 
Oral Comprehension 
44 
76 
-32 
0.1 
-2.99 
Weakness 
Segmentation 
84 
78 
6 
68 
+0.46 
-- 
Case 1:22-cr-00330-JKB     Document 20-1     Filed 08/29/23     Page 14 of 15

 
15 
 
 
STANDARD SCORES 
DISCREPANCY Interpretation at 
VARIATIONS 
Actual Predicted Difference 
PR 
SD 
+ or - 1.50 SD 
(SEE) 
Intra-Oral Language [Extended] Variations 
Rapid Picture Naming 
76 
78 
-2 
46 
-0.10 
-- 
Sentence Repetition 
<40 
75 
 
<0.1 
-3.13 
Weakness 
Understanding Directions 
67 
78 
-11 
17 
-0.97 
-- 
Sound Blending 
100 
80 
20 
95 
+1.63 
Strength 
Retrieval Fluency 
67 
77 
-10 
22 
-0.76 
-- 
 
 
  
  
 
STANDARD SCORES 
DISCREPANCY
Significant at 
COMPARISONS 
Actual Predicted Difference 
PR 
SD 
+ or - 1.50 SD 
(SEE) 
Oral Language/Achievement Comparisons 
WRITTEN LANGUAGE 
55 
64 
-9 
24 
-0.69 
No 
PHONETIC CODING 
90 
70 
20 
96 
+1.70 
Yes (+) 
SPEED of LEXICAL 
ACCESS 
69 
72 
-3 
41 
-0.24 
No 
 
 
BRIEF-A Adult Informant Score Summary Table 
 
Index/scale 
T score 
Percentile 
Behavior Regulation Index 
71 
95 
Metacognition Index 
83 
99 
Inhibit 
78 
99 
Self-Monitor 
72 
96 
Shift 
73 
97 
Emotional Control 
58 
81 
Initiate 
78 
99 
Working Memory 
82 
>99 
Plan/Organize 
85 
99 
Task-Monitor 
77 
>99 
Organization of Materials 
76 
98 
 
Validity scale 
Raw score 
Percentile 
Protocol 
classification 
Negativity 
5 
 98 
Acceptable 
Inconsistency 
7 
 98 
Acceptable 
Infrequency 
0 
99 
Acceptable 
Note: Male, age-specific norms have been used to generate this profile. 
For additional normative information, refer to Appendixes A–C in the BRIEF-A Professional 
Manual. 
 
Case 1:22-cr-00330-JKB     Document 20-1     Filed 08/29/23     Page 15 of 15

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