Counselors in the Courtroom - Texas Counseling … · Counselors in the Courtroom: How to Survive and Thrive in a Legal Minefield ... 2005; Tsushima & Anderson, 1996) – Can offer

Counselors in the Courtroom:How to Survive and Thrive in a Legal Minefield

Christy Bradshaw Schmidt, MA, LPC

Social Study Evaluator/Expert Consultant

Michael Puhl, JD – Puhl, Berbarie & Hewett

Purpose of the Presentation

• To Provide General Professional Knowledge

• To Educate the Professional About the Many Legal Implications of

Their Professional Therapeutic Relationship (i.e., Confidentiality

Issues)

• To Assist With Your Understanding of Your Role as an Expert or

Non-Expert Witness at Trial

• To Prepare for a Particular Court Action or Adjudicative

Proceeding When You have been called to testify

• To Make the Counselor Aware of trial process in Order to Prepare

the Counselor for the Challenging and Stressful Situations this

might arise in the course of legal proceedings.

Attitudes, Opinions and Triggers

• Many counselors are somewhat unnerved at the thought of being in court as a witness.

• Attorneys are trained in the “art of adversarial exchange.”

• Counselors are trained in creating empathy, collaboration and understanding.

• Self-of-therapist issues: we need to identify our triggers (sources of frustration/anxiety) to be an effective witness.

Attitudes, Opinions and Triggers

• Various factors play into our reactions to court:

– Adversarial vs. Collaborative approaches

• Win-lose / right-wrong stance vs. working together to

resolve a problem or conflict

– Conflict between Fairness vs. Rules

• Both sides having a voice vs. rules of procedure

– Objective (what happened) vs. Subjective meaning

(meaning attributed to event)

• Court looks for linear causality to predict future behavior

vs. therapist addressing how client interprets events

Case Records

• Consent Forms/Engagement Letters

– Who consents for treatment (Example: HIPPA)

• Role should be spelled out

– Consent form should address

-- Include ethical guidelines

-- court caveats

-- fees/hourly rates

-- trial retainers

-- dual roles

-- terms for your withdrawal

Case Records

• Where to Begin in Family Court Cases

– Divorce Decree/Orders

– Temporary Orders

– File Stamped Rule 11 Agreement(s)

– Authorization to release information

– What records can be released or requested

Case Records (Divorce Decree)

• Title 22, Texas Administrative Code, Chapter, 681,

Subchapter C. Code of Ethics (LPC)

– §681.41. General Ethical Requirements

• (aa) Prior to the commencement of counseling services to a

minor client who is named in a custody agreement or court

order, a licensee shall obtain and review a current copy of

the custody agreement or court order, as well as any

applicable divorce decree. A licensee shall maintain these

documents in the client’s record.

Case Records (Rule 11 Agreement)

• What is a Rule 11 agreement?– A Rule 11 Agreement is an agreement which is made in compliance

with Rule 11 of the Texas Rules of Civil Procedure.

– It says that an agreement between the attorneys or parties involved in a law suit can be made enforceable and binding in one of two ways:

• (1) if it is in writing, the agreement must be signed by the attorneys or parties making the agreement and it must be filed with the papers of the Court; or

• (2) if it is not in writing, the agreement must be made (stated) in open court (while court is in session) and made part of the official record of the case.

The Rule 11 Agreement must be clear and complete. Written agreements can be typed or hand-written. If oral, the record must show that all parties consented to the agreement (Dick Price, Fort Worth, Texas)

Know Basic Laws & Presumptions

• TFC Sec. 153.001: The Court shall “encourage

parents to share” in the rights and duties of

raising children.

• Texas is a presumed joint custody state.

• Standard Possession Order is presumed.

• Consider child’s preferences.

• Domicile restrictions.

Roles

• Therapist

• Parent Facilitator/Coordinator

• Mental Health Evaluation

• Social Study

• Consultant

• Avoiding Dual Roles

Dual Roles

• A dual role occurs when the treating practitioner becomes a forensic witness (moves from therapist to evaluator).

• Rules and codes of ethics most often deal with avoiding professional vs. non-professional interactions.

• Dual roles do not seem to be as present when the therapist is acting as a fact witness but more when he/she is acting as an expert witness.

Laws Regulating Dual Roles

• LPC SUBCHAPTER C. CODE OF ETHICS

§681.41. General Ethical Requirements (l) –addresses non-therapeutic relationships.

• LMFT SUBCHAPTER C. GUIDELINES FOR PROFESSIONAL THERAPEUTIC SERVICES AND CODE OF ETHICS

§801.44. Relationships with Clients (i) and (p) addresses dual relationships and non-therapeutic relationships.


• ACA Code of Ethics: Section A.5.e. Role Changes in the Professional Relationship address when a counselor changes from the original role to a different role.

• AAMFT Code of Ethics: Principle III – Professional Competence and Integrity, Section 3.14 Separation of Custody Evaluation from Therapy prohibits therapists from performing forensic evaluations for custody if they are treating provider.


• You never know when a case may

become court-connected

• Do the right thing in the first place

• Know your role and your limitations

• Recognize client goals vs. court goals

Ten Differences Between Therapeutic

and Forensic Relationships

1. Whose client is the patient / litigant?

_________________________________

Care Provision Forensic Evaluation

Mental Health The Attorney

Provider



2. The Relational Privilege That Governs

Disclosure in Each Relationship.

_________________________________


Therapist/Patient Attorney/Client &

Privilege Attorney work-

product privilege



3. The Cognitive Set and Evaluative

Attitude of Each Expert

_________________________________


Supportive, Neutral, Objective,

Accepting, Detached

Empathic



4. The Differing Areas of Competency of Each Expert

________________________________

Care Provision Forensic EvaluationTherapy Forensic evaluationtechniques for techniques relevanttreatment of to legal claimthe impairment



5. The Nature of the Hypotheses Tested by Each Expert

________________________________

Care Provision Forensic EvaluationDiagnostic criteria Psycholegal criteriafor purpose of for purpose of legaltherapy adjudication(Have you ever asked a family to see their court orders first?)



6. The Scrutiny Applied to the Information Utilized in the Process and the Role of Historical Truth _______________________________________________


Based on info from Litigant informationperson being treated supplemented with w/ little scrutiny of collateral sourcesthat information by scrutinized by court therapist evaluator

1st Q when conducting a forensic evaluation should be “What is occurring”?



7. The Amount and Control of Structure in Each Relationship

_________________________________

Care Provision Forensic EvaluationPatient structured Evaluator structured& relatively less & relatively morestructured than structured than forensic evaluation therapy



8. The nature and degree of

“adversarialness” in each relationship

___________________________________

Care Provision Forensic EvaluationA helping An evaluative relationship;

relationship; frequently adversarial

Rarely adversarial (show me mentality)



9. The Goal of the Professional in Each Relationship

____________________________________

Care Provision Forensic EvaluationTherapist attempts Evaluator advocatesto benefit the patient for the results andby working w/in implications of thethe therapeutic evaluation for the relationship benefit of the court



10. The Impact on Each Relationship of Critical Judgment by the Expert

___________________________________

Care Provision Forensic EvaluationBasis of the Basis of relationshiprelationship is the is evaluative & therapeutic alliance critical judgment is& critical judgment is unlikely to cause likely to impair that serious emotional alliance harm

The Counselor-Witness Role

• Fact vs. Expert


• Fact Witness –

– Observes an event and testifies about his/her

observations / experiences through the senses and

what he/she knows, i.e., direct knowledge of facts

(Barsky & Gould, 2002; Bernstein & Hartsell, 2005)

– Cannot offer opinions or answer hypothetical

questions


• Expert Witness –

– Subject matter must be beyond the knowledge of the average layperson

– The witness must offer special knowledge / experience / training in a particular field so that the opinion will assist judge / jury (Bernstein & Hartsell, 2005; Tsushima & Anderson, 1996)

– Can offer opinions / interpretations (La Forge & Henderson, 1990)

– Can answer hypothetical questions


• Qualifying the mental health expert

– Daubert standard

• Means expert must demonstrate a “thorough and

comprehensive knowledge of the subject matter and the

reliability of the science or methodologies employed”

(Bernstein & Hartsell, 2005)


– Judge will determine expert’s competence

– Professional vitae• Your Professional title

• Books, research, or published articles

• Training and education

• Positive book reviews

• Degrees, professional licenses, and credentials

• Professional speaking experiences

• Years of experience ongoing supervision or case consultation

• Employment history

• Professional development and continuing education courses

• Supervisory experience

• Consultation work

• Codes(s) of ethics to which you prescribe

• Special awards or citations

• Courses you have taught

• Prior court experience

• Membership and offices held in professional organizations

• Work under recognized experts

• Recognized specializations

• Methods of practice to which you prescribe

• Profession-related volunteer work


• Example of qualifying the expert witness:

Example One

Example Two

http://www.dailymotion.com/video/x7jsxg_my-

cousin-vinny-expert-witness_fun

Pre-Trial Preparation

• Keep a precise log (case notes) of:

–All activity related to the case

–All activity performed (session activity, etc.)

–Amount of time spent with client in each session

–History provided by client

–Clinical Diagnosis

–Care provided to the patient (including the focus of care)


Log (case notes) continued

–Up-to-date treatment plan(s)

–Patient’s response to the treatment

–Patient’s prognosis / progress

–Mood, cognitions and/or behaviors of the

patient at particular times

–Statements that the patient made in treatment

–Use terms like: “Client reports” or “Client

states” in notes


• Checklist for Trial Preparation

1. Research the subject matter.

2. Research court orders

3. Limit Your testimony to your charge

4. Research the literature that both supports and contradicts your opinions and conclusions.

5. Research the opposing experts.

6. Conference with attorney(s).

7. Research the courthouse.

8. Review for direct examination and cross-examination.


• Preparing for Court Testimony1. Review the record of the client.

2. Organize the file.

3. Contact the client.

4. Bring a copy of your records to court.

5. Comply with and review production requests.

6. Review requests for admissions, interrogatories, and depositions.

7. Consider protective orders.

8. Don’t avoid either attorney.

9. Expect certain questions in cross-examination.

10. Engage a personal lawyer if needed.

Direct Exam of Expert

How is information ascertained?

• Interviews Conducted

• Independent Investigation

• Written Statements

• Reports

• Other Expert Reports

• Testimony

• Materials Reviewed in Preparation for Testimony Writings and by whom written, Records (& from where), Data (source of origin), Exams/evaluations/tests

Exams/Evaluations/Tests/Other Expert

Reports/Methodology

• Explain exam – procedure, what tested, how

performed

• Evaluations – normal protocols

• Tests – explain the test

• Other expert reports – proper formats

• Explain your methodologies

Basis for Opinion

• Explain factual basis

• Explain the theory on which your opinion is based

• Discuss/recognize differing schools of thought as it applies in case

• Be ready to explain why you believe your theory to be accurate & reliable

• Is there a margin for error; can you explain it

• Did you consult with other experts

• Has your methodology been peer-reviewed

Scope of Testimony

• Most important rule – when answering questions remain within your scope of expertise and avoid elaborating beyond the immediate scope of the specific question.

• It is sanctionable to recommend custody, visitation restrictions or court supervision (without conducting a forensic evaluation)

• Know what laws regulate your profession

• Know what professional codes of ethics and standards of professional conduct need to be followed

Scope of Testimony

• Know what professional guidelines you would like to aspire to.

• Know legal mandates, if any, of your agency and your position

with the agency. Know what contractual obligations your agency

has with the government or other funding sources. Know if there

are any agency policies that need to be considered.

• Don’t put the cart before the horse on causality issues.

• Make sure your recommendations and evaluations are well-

reasoned.

• Exercise scrutiny when evaluating a situation

• Avoid leaps of logic

Scope of Testimony

• MHC providing care can usually qualify to testify

as a treating expert and offer a clinical diagnosis

and prognosis.

• A conflict arises when the treating expert also

attempts to testify as a forensic expert

addressing the psycho-legal issues of the case

(e.g., testamentary capacity, parental fitness &

capacity, visitation schedules, custody, etc.)

Request for Records

• Ways you might receive a request for records:

– Attorney asking for voluntary assistance

– Police warrants (although this is rare)

– Subpoenas

• From your client’s attorney – plain or duces tecum

• From opposing counsel – plain or duces tecum

– Plain = requirement to appear at time/location specified in subpoena

– Duces tecum = appear and produce identified documents

– Discovery (Health & Safety Code, chapter 181)

– Direct orders from the court

Request for Records

• How should you respond to a subpoena?– Ignore – only if you like wearing orange

– Contact your client – inform & obtain consent to release

– File a motion to quash• Must demonstrate why protection of client’s confidential

information is crucial to maintaining integrity of therapeutic relationship (i.e., harm caused by disclosure is greater than any related benefit)

– File a protective order• Ex. = Going on vacation during time subpoena specifies

• Ex. = addresses specific information to be released / handled

– Request an “in camera” review

Don’t Forget About HIPAA & TMRPA

• Is the subpoena valid under HIPAA & TMRPA?

• A lawyer’s signature on the subpoena is not

sufficient.

• Most subpoenas are not signed by a judge. . . but

don’t ignore the subpoena altogether if it is not

signed by the judge.

What to do if the Subpoena to Court is

not signed by a Judge.

• You still have to go to court. Ordering you to

appear is not violating HIPAA.

• Try to get a HIPAA release signed.

• Express your concerns about release of patient

records to the judge before turning over records

• Follow the judge’s order to release the records

• Hire a lawyer

• File a motion to quash or for a protective order

The Judge must decide to order:

• Provider to release the records to opposing party

or not.

• Or that the records be released to the judge only

and only the judge will read them.

• Or that only a portion of them be released.

• Or that they will be released only to specific

people once a confidentiality order is in place.

TMRPA: New Notice Requirements

• Use the Atty. General form to meet all notice

requirements for release of records under the

Texas Medical Records Privacy Act. (Health &

Safety code, Chapter 181)

Deposition

• These are question-answer sessions that take place prior to trial in most cases

• Main function is to learn about witness evidence

• Key areas of questioning include source of information in client’s records and reports:

» What information was observed directly?

» What information was obtained from other professionals?

» What information has been inferred, guessed at, hypothesized, speculated on, or assumed?

» How has any information been verified?

Deposition

• If questioning the expert

witness, will explore how

is the expert qualified

and what is the extent of

his expertise

• Will investigate expert

witness’ processes,

theories and techniques

• Anything can be asked

during this process.

In-court Testimony

Role of Attorney

– Strategy

– Marshaling relevant facts

to construct an effective

case

– Asking the right

questions

– Making objections when

necessary

Role of Therapist

– Educating the judge, jury

and/or third parties about

the counseling profession

– Educating the judge, jury

and/or third parties on

the impact of the client’s

condition on present and

future functioning

abilities

Impartiality

• Resist the temptation to slant testimony

• State facts honestly and objectively

• Operate out of a factual, neutral scientific tradition

• Let attorneys direct the adversarial process based on client

advocacy

• Responses not based upon personal knowledge will place

witness on shaky ground

• You are only one piece of the puzzle; don’t try to control the

other pieces

• Converse with both attorneys if you treated the child

Question Response Procedure

• Maintaining objectivity

• If you mess up in the middle of the case and

recognize the mistake, fix it. “I forgot…” or “I need

to correct…” Don’t defend the mistakes;

acknowledge and embrace them.

• An expert must be willing to consider and

recommend a range of alternatives for the court to

consider.

• See handout for Do’s and Don’ts.


Direct Examination

&

Cross examination

Direct Examination

• Should play like a melody

• Methodical

• Answer questions asked

• Trust the process

• No leading questions

• Who, what, when, where & why

• Witness tells the story


• Direct Examination – Ten Rules– Rule 1. Tell the Truth, The Whole Truth and Nothing

but The Truth.

– Rule 2. Convey Professionalism and Genuineness.

– Rule 3. Respect the Formalities of the Tribunal.

– Rule 4. Speak Slowly, Loudly, and Without Hesitation.

– Rule 5. Provide Clear, Concise Answers.

– Rule 6. Let the Attorney Lead the Questions.

– Rule 7. Experts can Testify to Facts and Provide Opinions.

– Rule 8. Demonstrate Confidence and Maintain Composure.

– Rule 9. Maintain Eye Contact.

– Rule 10. Use Notes to Refresh your Memory.


Cross-Examination

• Usually limited to matters brought up during direct examination

• Can use leading questions which are of a closed format type carefully stated to elicit succinct answers, usually a yes or no

• Rules are different. More confrontational

• Attorney is telling the story

• Attorney checks thoroughness of investigation


• Cross-Examination (continued):

• Attorney will search for biases

• Attorney may challenge witness credibility

• Attorney seeks to expose skewed opinions

• Attorney seeks to establish doubt

• Attorney may use rapid fire question tactic

• See handout for witness’ role and Top Ten Tactics

used by Attorneys


• Cross Examination – Frequently Used Tactics– Tactic 1. Challenging Credibility.

– Tactic 2. Establishing Doubt.

– Tactic 3. Logic Funnel.

– Tactic 4. Leading Questions.

– Tactic 5. Feigned Ignorance or Pleasure.

– Tactic 6. Be wary of questions that require you to predict the future.

– Tactic 7. Rapid Fire.

– Tactic 8. Intentional Ambiguity.

– Tactic 9. Implying Impropriety.

– Tactic 10. Rattling the Witness.

Privileged Communication

• Client has right of privileged communication

• Counselor-witness has no grounds for withholding

information if client waives that right

• Counselor-witness has two options if he/she believes a

question infringes on client-held confidentiality:

– Inform the judge that the answer would violate client

confidentiality and request a ruling on whether the

question should be answered

– Request that the response be held in camera, that is in

the judge’s chambers or in the courtroom without

spectators

What Legal Professionals Want

• Information that is tangible.

• Recommendations supported by research or

literature.

• Collaborative working relationships.

• Knowledge of the court system.

• Willingness and competency to testify.

What Judges Want on The Stand

• Court Room DecorumRemain Neutral in Fact and Appearance

Body Language

Manage Anxiety

Be Confident

Speak up and Be Clear

Don’t Preempt Attorney

Be Dignified

Okay to “Not Know”

Don’t Take it Personally

Don’t Think Out Loud

Copy of Presentation

You may download a copy of this

presentation and sign up for periodic blogs at:

http://legal.myfamilylawyer.net/d

ownload-presentation-

counselors-courtroom.html

References

Association of Family and Conciliation Courts. (2010). Guidelines for court-involved therapy. Madison, WI: Court-involved Therapist Task Force.

Barsky, A. E., & Gould, J. W. (2002). Clinicians in court: A guide to subpoenas, depositions, testifying, and everything else you need to know. New York: Guilford Press.

Bernstein, B. E., & Hartsell, T. L. (2005). The portable guide to testifying in court for mental health professionals: An A-Z guide to being an effective witness. Hoboken, N.J.: John Wiley & Sons, Inc.

Coles, E. M. (2000). The emperor in the courtroom: psychology and pseudo-science. The Journal of Forensic Psychiatry, 11(1), 1-6.

References

Davis, G. G. (2006). The art of attorney interaction and courtroom testimony. Archives of Pathology & Laboratory Medicine, 130, 1305-1308.

Faust, D. (1993). Use and then prove, or prove and then use? Some thoughts on the ethics of mental health professionals’ courtroom involvement. Ethics and Behavior, 3, 359-380.

Fidnick, L. S., Koch, K. A., Greenberg, L. R., & Sullivan, M. (2011). Association of family and conciliation courts white paper guidelines for court-involved therapy: A best practice approach for mental health professional. Family Court Review, 49(3), 557-563.

Greenberg, S. A., & Shuman, D. W. (1997). Irreconcilable conflict between therapeutic and forensic roles. Professional Psychology: Research and Practice, 28 (1), 50-57.

La Forge, J. & Henderson, P. (1990). Counselor competency in the courtroom. Journal of Counseling & Development, 68, 456-459.

Tsushima, W. T., & Anderson Jr., R. M. (1996). Mastering expert testimony. Mahwah, N.J.: Lawrence Erlbaum Associates, Publishers.

RESUME CHRISTY BRADSHAW SCHMIDT, MA, LPC

P.O. Box 701328 Work: 214-502-7224 Dallas, Texas 75370 Facsimile: 972-745-4585 OBJECTIVE: A position as a LICENSED PROFESSIONAL COUNSELOR where my experience and expertise in the

field of child custody

evaluations, mediation, and adoption social studies can be best utilized to assist families in formulating two

healthy home

environments in an efficient and effective manner after a difficult separation and divorce. STRENGTHS:

• Strong work ethic; willing to go above and beyond • Extensive experience in the field of substance abuse and addiction-related counseling • Over ten years experience in the field of contested child custody matters having completed over five

hundred social studies • Excellent people skills – extensive experience in public speaking, lecturing, etc. • Efficient and effective in getting work done; able to prioritize • Energetic; a “go-getter”; dynamic

PROFESSIONAL EXPERIENCE: 11/03 – Present Private Social Study Evaluator/Expert Consultant --provide private social study evaluations for Collin, Dallas, and surrounding counties --provide consultation in the field of child custody as an expert witness

--available for mediation with training in family/divorce and CPS mediation

05/00 – 05/06 Family Court Counselor DALLAS COUNTY FAMILY COURT SERVICES – Dallas, Texas --completed social studies for custody evaluations and adoptions

--conducted mediations for families facing divorce and custody disputes

--provided services as ordered by the courts, i.e. testimony, counseling, etc.

12/99 – 05/00 Director of High School Activities EDUCATION AMERICA, INC. – DALLAS CAMPUS --developed relationships with 50 high schools’ counselors and teacher

--coordinated and conducted public service presentations for the senior classes of those high

schools

5/99 – 12/99 Clinical Coordinator of the Adolescent Intensive Outpatient Programming GREEN OAKS PSYCHIATRIC HOSPITAL AND PLANO CLINIC, Dallas and Plano, TX --expanded successful IOP programming to include two locations

--initiated marketing to expand both programs to: allied professionals, residential treatment

facilities, schools, churches, probation departments, judges, and attorneys 11/98 – 8/99 Clinical Coordinator of the Adolescent Chemical Dependency Services and IOP GREEN OAKS PSYCHIATRIC HOSPITAL, Dallas, TX --developed CD services on the adolescent inpatient and day hospital unit --coordinated and developed the program and materials to begin IOP --successfully managed an IOP program with a census up to 10 while balancing patient care and

CD group services in the hospital --individually managed all aspects of IOP programming without assistance, including: group therapy, individual therapy, multi-family groups, family therapy, utilization review,

paperwork, etc.

--maintained a caseload of 3 patients in the hospital along with 4 group therapy

opportunities, including: CD education, relapse prevention, process group, and experiential group

therapy

1/98 – 11/98 Clinical Coordinator of the Minirth Christian Program GREEN OAKS PSYCHIATRIC HOSPITAL, Dallas, TX --developed a Christian program and material in coordination with Dr. Frank Minirth and

implemented the program into the hospital with all populations --hired and supervised a staff of 2 therapists plus 4 practicum interns with a program census of up to 25 --coordinated weekly programming to include: group coverage, patient needs, treatment

team rounds, discharge planning, and utilization review --managed a caseload of 5-6 patients in correlation with supervision responsibilities

8/97 – 12/97 Counselor for Pre-natal and Post-partum Women and Children’s Services NEXUS RECOVERY CENTER, Dallas, TX --managed a caseload of 3-5 clients and families and all services pertaining to their needs and

discharge planning --primary facilitator of Parenting Education and Instruction --completed weekly treatment plans, treatment plan reviews, biopsychosocial assessments, and

discharge summaries for all clients --provided individual, group and family therapy to all clients within the program to

increase their level of functioning and ability to return to society

7/95 – 9/97 Lead Counselor for Dual Diagnosis Team SUNDOWN RANCH, INC., Canton, TX --managed a caseload of 10 clients, including families, and utilization review --lead weekly treatment team meetings --facilitated 10 hours of group therapy per week --provided 10-15 hours of family therapy per week --facilitated 2-4 hours of experiential group therapy per week --provided educational opportunities for families regarding: chemical dependency, dual disorders,

and healthy family coping skills --facilitated 8 hours of multi-family group therapy per month --facilitate 24 hours of intensive family programming 4 times per year --facilitated extensive crisis intervention on an individual and community level as necessary --completed treatment plans, treatment plan reviews, discharge summaries, and necessary

paperwork for all clients in a timely manner

CERTIFICATION: Licensed Professional Counselor (License number 14323) – October 1997 – Present Mediator for Family, Divorce, and CPS Cases – November 2000 – Present Certified Experiential Group Facilitator – January 1996 – April 1999 EDUCATION: SOUTHWESTERN BAPTIST THEOLOGICAL SEMINARY, Fort Worth, TX MA in Marriage and Family Counseling (May 1995): GPA = 3.942 MA in Religious Education (May 1995): GPA = 3.942 BAYLOR UNIVERSITY, Waco, TX BA in Religion (May 1992): GPA =3.5

Documents

Counselors in the Courtroom - Texas Counseling … · Counselors in the Courtroom: How to Survive and Thrive in a Legal Minefield ... 2005; Tsushima & Anderson, 1996) – Can offer