BEFORE THE MINNESOTA BOARD OF PSYCHOLOGY STIPULATION AND CONSENT ORDER May 7, 1999 In the Matter of Renee Fredrickson, Ph.D., L.P. License No. LP2653 IT IS HEREBY STIPULATED AND AGREED by Renee Fredrickson, Ph.D., L.P. (Licensee) and the Minnesota Board of Psychology (Board) as follows: 1. During all times herein, Licensee has been and now is subject to the jurisdiction of the Board from which she holds a license to practice psychology in the sate of Minnesota. FACTS 2. For the purpose of this stipulation the Board may consider the following facts as true: I. _Background_ 3. Since 1977, Licensee has provided individual, marital, and group therapy to several clients at Fredrickson & Associates. Licensee provided psychological services to clients for depression. Post- Traumatic Stress Disorder (PTSD), anxiety disorders, and alleged cult and ritualistic abuse. Licensee also has provided therapy to infants and pre-school aged clients who were allegedly abused. Since 1994, with regard to certain clients, Licensee has demonstrated a number of practice deficiencies including, but not limited to: failing to adequately inform clients of Licensee's use of innovative or newly emerging services and techniques and their related risks; providing psychological services to clients when Licensee's objectivity and effectiveness were impaired; failing to obtain written informed consent to share private information on clients; and engaging in unprofessional conduct. Licensee provided therapy to the following individual clients as well as clients in group therapy. 4. From June 16, 1994 to April 1995, Licensee provided individual therapy to client #1, whose therapeutic complaints included being the victim of sexual abuse and experiencing intrusive thoughts of knives when under stress. Licensee listed client #1's diagnosis as PTSD. 5. From 1986 to November 1996, client #2 received individual, couples, and group therapy at Fredrickson & Associates and was diagnosed with PTSD. Client #2 sought therapy for mental distress and complaints related to her parents, including her mother's chemical dependency, sexual abuse, and fear of her father. In addition to client #2's membership in a Tuesday therapy group, Licensee provided limited individual therapy to client #2 for approximately 6 to 10 sessions. 6. From 1988 to November 1996, client #3, the sister of client #2, received individual and group therapy at Fredrickson & Associates. Client #3 initially sought therapy as a result of memories of physical and sexual abuse by her father. During the course of therapy client #3 began to identify alleged memories of ritual satanic abuse. Client #3's diagnoses were Dysthymia; Major Depression, Recurrent, "superimposed on [Dysthymia]"; PTSD; and Polysubstance Dependence, in Remission. Client #3 had a few individual sessions with Licensee, but was primarily a member of a Thursday therapy group. 7. From 1980 to 1987, client #4 received group therapy at Fredrickson & Associates. Client #4 also received individual therapy from 1987 to 1990. Client #4 was diagnosed with PTSD and experienced depression, anxiety, relationship problems, and disturbing memories of physical and sexual abuse by her parents. Client #4 resumed individual therapy on September 3, 1995, because of suspected abuse of her son by a baby-sitter. 8. Client #5, the minor son of client #4, received therapy from Licensee in 1995 and 1996 for sexual abuse issues and family stress. 9. Licensee provide therapy to clients at Fredrickson & Associates in four different therapy groups which met on Monday, Tuesday, Wednesday, and Thursday. Licensee and a co-leader facilitated the groups. Clients in the Monday and Wednesday groups had a variety of therapeutic complaints. The Tuesday group, which Licensee led with a co-facilitating therapist (co-facilitator) for approximately 20 years, addressed sexual abuse issues as well as depression and family-of- origin issues. Client #2 was a member of Tuesday group. In January 1996, Licensee began co-leading the Thursday group with the co- facilitator. The group is now disbanded. The clients in the Thursday group were all women who had complaints related to sexual abuse. At one point, four clients in the Thursday group alleged they were victims of ritual satanic abuse. Clients #3, #6, and #7 were members of the Thursday group. II. _Failure to Inform Clients of Licensee's Use of Innovative or Newly Emerging Services and Techniques, Including Risks_ _____________________________ Client #1: Recovered Memories 10. Early in 1994, client #1 began to be more troubled by her long- standing memories of sexual abuse committed by a man who rented the basement of her family's home when client #1 was a young child. Prior to therapy, client#1 had read a local newspaper article which featured Licensee as a psychologist who specialized in sexual abuse issues. Client #1 also heard Licensee quoted on a radio program in connection with the topic of repressed memories. Prior to seeking treatment with Licensee in June 1994, client #1 purchased and read Licensee's book "Repressed Memories: A Guide to Recovery from Sexual Abuse" (1992). Licensee maintains that client #1 did not inform her that she had read the book. 11. In June 1994, client #1 made an appointment and had her first session with Licensee on June 16. During this session, client #1 told Licensee everything she remembered about being sexually abused as a child by a man. The client's journal entries reflect additional information about the sexual abuse by this man and Licensee read and discussed the client's journal with her. Client #1 also reported her recurring visual images of thousands of knives and the slicing off of a breast nipple. Client #1's husband was present at the intake session and for many of her subsequent sessions with Licensee. 12. In the therapy sessions with client #1, Licensee used several therapeutic techniques. These included using hypnosis upon client #1, having the client write with her left hand, and suggesting that she write to her "inner child". Client #1 also kept a journal of her thoughts and dreams which Licensee often read in preparation for a session. Licensee incorporated the journal entries in client #1's therapy notes. While at home and under the supervision of her treating psychiatrist, client #1 participated in hundreds of "holding sessions" with her husband and other family members. Client #1 recorded her feelings and "memories" from those holding sessions in her journal. 13. During the next several months of therapy, client #1 developed memories of ritual cult abuse, including torture, dismemberment, cannibalism, and murder, which she later believed were false. In some of these memories, client #1 developed the following images: (1) she cut off a penis; (2) a knife was inserted into her vagina: (3) she had sex with dogs in a "ritual abuse ceremony"; (4) she tortured her younger sister; (5) she had knives thrown at her "William Tell style"; (6) she was raped by here grandfather on the edge of a haymow; (7) she watched her uncle cut up people; and (8) she was programmed to commit suicide if she ever told anyone about the abuse. 14. In approximately August 1994, Licensee induced client #1 into a trance state and asked her to empty her mind of images, or "put up a blank screen." Client #1 complied and began to visualize hundreds of knives. Licensee asked client #1 who she saw holding the knives, but client #1 did not visualize anyone. Client #1 then viewed a young girl on the edge of the haymow in her grandfather's barn and Licensee asked client #1 to name the girl. Client #1 replied by naming the girl by her own first name. She then experienced graphic images of knives chopping up the girl and pieces of the girl falling off the haymow. Licensee asked client #1 to describe the pieces and client #1 replied that they were bloody. 15. Also around August 1994, client #1 wrote a journal entry describing a nightmare in which she saw severed arms and legs dripping with blood at the top of her shower stall. Client #1 came to believe the dream represented a repressed memory. 16. During the course of therapy, client #1 came to believe that a number of her family members had victimized her through sexual abuse. She believed her uncle and grandfather had forced her to have sex with the neighbor's dogs when she was child. Client #1 also wondered whether her mother had sexually abused her as a child. For example, during a therapy session on August 4, 1994, Licensee and client #1 discussed a purported memory. Session notes reflect the discussion: "Mommy did it, mommy made Chipper [dog] lick me. Image this a.m. -- little girl getting out of bathtub, mom is there, dog comes up & starts licking her -- 'You're getting it too?' recall fragment of mom waving a knife increasing pressure of knife memory Image of truck careening out of control -- careening, horn blowing [client #1's] mom has what sounds lake a fantasy rel. Hypnosis -- millions thousands of knives -- rescue fantasy." 17. During therapy with Licensee, client #1 began to wonder whether her grandfather also had sexually abused her. 18. Due to the shock and trauma of many of her memories, client #1 became suicidal for the first time in her life during the course of therapy. Client #1 experienced extreme fear, trembling, and sleeplessness, as well as a feeling that she was going insane. The memories as they related to family members impaired client #1's relationship with those family members.. Eventually, client #1 recorded the following in her journal: 9/10/94 "Everyone in [a U.S. state] is mad at me. I'm afraid I'll lose everyone in my family... I'm accepting I was sexually abused & terrorized with knives in [a U.S. state]. It's true. I'm not crazy. It happened to me & I bet to [redacted] too. That's why she doesn't want to talk to me..." 19. In the course of treatment, client #1 continued to report numerous memories of abuse which Licensee addressed through hypnosis and other means, as evidenced in part by the following entries in client #1's therapy notes and journal: 6/19/94 [written as 6/19/93 by client #1] Journal entry. "We saw [Licensee]. She says there is no way I'd have come us with the dog activity on my own." Portion of undated session note. "Hypnosis...Christina Oksana's book. Stop reading Reader's Digest[,] Good Housekeeping...You're safe[.] Family is safe[.] It is over[.] You will not hurt yourself[.] You can live[.] You will not go crazy[.] You are sane -- you are having normal trauma reaction ...You are free to remember..." "1/27/97...Told her this because these articles caused physiologic reactions[.]" "Suggested telling herself these messages might help." 9/27//94 Session note. "It's safe to remember[.] Somewhat dep. yesterday - but no more suicidal urges[.] Read journal... 1. Put knife in vagina[;] 2. Shock[;] 3. Cut off a penis -- dog? 4. Sex with dogs[;] 5. Had to kill herself if she told [;] 6. Made her hurt [sister]? (Her arm started to shake when I asked about this)[;] 7. Threw knives -- William Tell style[;] 8. Scissors on nipple and threatened to cut it off; 9. G. raped at edge of hay mow..." "Update 1/27/97: Here I asked her what she thought might have happened, except ? about [sister]." 12/15/94 Session note "hypnosis plan[.] Dead[.] you're alive[.] Liars[.] Believe yourself[.] Only remember what[.] Not info. You are ready." Margin note: "Begin & finish w/ safety program..." 12/20/94 Session note. "read her journal.., image of knife near [redacted] eyes - we spent some time getting a clearer picture of this image[.] manicure scissors to eyelids - image[.] has a sense of nipple being cut off nipple (sic) - then eye[.] scared of anything that could be used for cutting[.]" 20. In or shortly after August 1994, Licensee and client #1 discussed client #1's sensations of tingling fingers. On one occasion, during a break in a therapy session, Licensee told client #1's husband that she had heard reports of sadistic-type abusers building small electrical apparatuses to deliver electrical shocks during sexual abuse. Client #1 learned of this in a subsequent conversation with her husband. Client #1 subsequently developed memories and sensations of being tortured through the use of an electrical box, which client #1 later believed were false. 21. Licensee recommended that client #1 read "Safe Passage to Healing", by Chrystine Oksana, which is a book about surviving ritual and satanic abuse. Client #$1 read the book, which contains graphic stories of human sacrifice, torture, and cannibalism. The author wrote that suicidal thoughts were part of the healing process involved in surviving childhood abuse. Client #1 was frightened by the book, but continued the professional relationship with Licensee in the hope of undergoing a healing process. 22. Client #1 continued to engage in "holding" and "feeling" work with her husband. She began to believe her ritual abuse experience involved being raped by dogs and being forced to torture her younger sister. Although Licensee did not give client #1 assignments to engage in holdings and feeling work with her husband, she was aware that client #1 was doing so. 23. During the course of therapy, Licensee made a self-hypnosis tape for client #1 to use for her sense of personal safety. The tape included calming messages but also contained the following comments by Licensee: "They made you do things." "It's not your fault." "These crazy thoughts that come into your head...they're not craziness, they're just about what happened to you.,..[Your abusers] were crazy, sick, silly people." Client #1 claims that these comments further reinforced her belief that she had been ritualistically abused. Licensee claims she asked client #1 what she wanted said on the tape and in any hypnosis session, as was her usual and standard practice. 24. Although client #1 expressed skepticism in many of her purported recovered memories, Licensee responded to client #1's skepticism by encouraging her to believe in the images she was experiencing. After client #1 described to Licensee an image of torture in which client #1 saw herself cut someone's eyes, nipples, and penis, and a scenario in which her uncle forced her to cut someone's eyelid with scissors, client #1 subsequently had a "memory" of being forced to eat an eyeball. 25. Sometime between December 1994 and January 1995, during a therapy session, client #1 and her husband drew pictures using their opposite hands. Client #1 drew a picture of a small girl holing a knife and kneeling over a tied down naked man with blood protruding from his nipples and eyes. Client #1 wrote with her left hand under the picture, "I killed him all by myself. Dogs ate him up." 26. Licensee continually reinforced client #1's belief that her memories of involvement in a ritualistic cult were plausible. For example, Licensee told client #1 that in a city the size of Brainerd, Minnesota, hypothetically there could be 5-to-10 people involved in cult ritual abuse that would have a significant ripple effect on the community. Licensee told client #1 that the FBI was not properly investigating claims of ritual satanic abuse. _______________________ Client #2 and Client #3 27. While in therapy, client #2 came to believe her parents were involved in a cult. Part of client #2's therapy involved working on her memories of abuse. 28. During her course of therapy, client #3 wanted to talk about her memories and explore their impact on her current relationships. She began to identify alleged memories of ritual satanic abuse. 29. A February 23, 1995, note in client #3';s group file states: "Did hypnosis session. Discovered she and her sister 'remember' several things the same about the murder of family...Treatment actions. Continue to debrief memory/deal with feelings/reframe 'needs.'" 30. During therapy sessions on February 18 and 23, 1995, which are described more fully below, Licensee performed joint hypnosis on client #2 and client #3 regarding their memories and images of their parents killing a family in Oregon. When client #2 and client #3 told Licensee that they wanted to locate the relatives of the murdered family in Oregon, Licensee suggested they contact the producers of the show, Unsolved Mysteries, among other suggestions. 31. An August 22, 1995, group therapy note for client #2 states: "Was suicidal last Wednesday, decided to kill herself. Fears about the work situation. Talked about what happened when the cult was betrayed ... Did work on memory of being made to eat a live rat, also feces." Licensee stated to the Board's investigator that during the session client #2 said she wanted to throw up and a group member noticed client #2 picking at her teeth. Client #2 said she had a memory of fur or gristle in her teeth and that she had been forced to eat something but couldn't remember what it was. Licensee stated that because client #2 was crying and session time was running out she asked client #2. "Do you think it might be rat?" Client #2 responded. "That fits." Licensee told the Board's investigator that, "This is the one time in ten years, or however long I have been doing this, that I took a shortcut and asked direct questions rather than a 'blank slate question'." The client previously had discussed a memory of being locked in a shed with other children, and that a large starving rat was introduced. The client stated that she thought she had killed the rat with her bare hands and indicated the possibility of being forced to bite into the rat. ___________________ Client #1: Hypnosis 32. Licensee does not have a competency on file with the Board to perform hypnosis. Nevertheless, Licensee used hypnosis in her treatment of client #1 and billed client #1 for sessions in which hypnosis was used. Licensee's records for client #1 include entries regarding the use of hypnosis on the following dates: June 1994; August 4 1994; September 29, 1994; November 17, 1994; December 1, 1994; December 15, 1994; and February 8, 1995. 33. Although Licensee warned client #1 about some of the risks of using hypnosis, she failed to adequately inform client #1 that hypnosis can sometimes result in vary vivid memories which are false but which are still believed. _______________________ Client #2 and Client #3 34. On February 18, 1995, Licensee conducted a joint hypnosis session with client #2 and client #3 regarding their images of their parents killing a family in Oregon. Licensee states she is not sure how common it is to perform simultaneous hypnosis on two clients and has no specific training to perform joint hypnosis. Licensee did not obtain informed consent from either client #2 or client #3 for the use of hypnosis in this manner. III. _Providing Psychological Services to Clients When Licensee's Objectivity and Effectiveness were Impaired_ 35. During a telephone conversation with her therapist on January 15, 1997, Licensee told her therapist she was aware she was impaired. 36. In a letter to the Board's Complaint Resolution Committee, dated September 19, 1997, Licensee acknowledged that she departed from her current usual and customary practices of care in terms of impaired objectivity, breaching confidentiality and unprofessional conduct. Licensee stated, "I now realize that I was dealing with a great many stressors that impaired my ability to separate my underlying emotions from my professional life." ________________________________________________ Exhibiting Signs of a Possible Mental Dysfunction 37. Beginning in September 1996, and continuing through December 1996, Licensee repeatedly contacted the St. Paul Police Department to report incidents of alleged stalking. Licensee believed she was being stalked based on a certain number of these incidents. She exhibited symptoms of a possible mental dysfunction, her objectivity was impaired, and she failed to protect the privacy of clients. For example, Licensee reported the following incidents to the police: a. Licensee made numerous complaints to the police, including that persons had broken into her home; cultic ritual marks were left by these persons; her mail had been tampered with; clothing or personal items had been stolen, moved, or misplaced in her home; items had been mysteriously damaged and then repaired. She expressed concern that naturally occurring incidents, such as a large tree branch caught upside down in wires next to her home and the presence of a large eviscerated bug with a fresh carapace found on her step might be related to stalking. These complains were investigated by the police and were not confirmed. b. Licensee believed that members of a cult were largely responsible for the alleged stalking. 38. On September 9, 1996, Licensee reported that someone had recently entered her home through an unlocked window, and removed a part of a window lock. Licensee also reported unusual incidents that had happened in her home and office during the past six months as perhaps being related to a pattern of stalking, such as finding her bra hanging from a ceiling hook in her basement and an impression of a symbol associated with cult abuse pressed into her carpet. Licensee believed one of the perpetrators might be the father of clients #2 and #3. Licensee told the police that the perpetrator was responsible for several unsolved homicides, was a cross-dresser, and was involved with cult activity. 39. On September 16, 1996, Licensee reported that someone attempted to enter her home the day before by forcing open a locked window, damaging the lock, and tearing the screen. She suspected the perpetrator was the father of clients #2 and #3 or his ex-wife, or someone involved with them. 40. On October 8, 1996, Licensee reported that on or about October 2, 1996, someone stole a file form her office. The file was for her Wednesday group and contained six folders, one for each person in the group. Licensee was concerned because of pattern of unusual incidents that occurred whenever either client #2 or client #3 was being seen. Licensee noted that her secretary had pulled the file before 1:00 p.m. After working in her office for an hour an a half, Licensee noted the file was missing. It was never discovered. According to a police investigative report, Licensee stated that members of the group were regaining memories about the Jacob Wetterling abduction case and the 1981 Smith-Jones homicide. Licensee suspected that client #2 and client #3's father and his ex-wife were linked to those cases. 41. On the same date, Licensee also reported to the police that another file, that of client #8, had been discovered missing during the summer. She told the police that client #8 was an alleged cult survivor who lived near the Wetterling family when Jacob Wetterling was abducted, and the client, along with other family members, was suspicious that the mother was involved in the kidnapping. 42. On October 8, 1996, Licensee also reported that on an unspecified date, persons had entered her garage and were in her 11-year-old son's room. Licensee stated that it made her sick to think of anyone touching or fondling her son's belongings. She was fearful of her son being abducted. She also reported that persons had been knocking on the side of her house and night and that she had opened a window and shouted, "Get away form here, you parasites!" 43. On October 21, 1996, Licensee reported that three days earlier she noticed that the screen which had been cut on September 15, 1996, had been replaced. She did not know how this occured; she did not fix it or ask anyone to fix it. 44. On October 21, 1996, Licensee reported: a. that pants she had reported missing on October 8, 1996, "reappeared" in the same drawer where she had first left them; b. that the latch on her bathroom no longer made a noise upon closing and must have been fixed by some unknown person; c. that unknown persons could make her phones jingle in whichever room she was present, and could identify which room she was in even if all the lights in the house were on; and d. that she was concerned that her phones might be bugged. 45. On October 22, 1996, Licensee reported that on an unspecified date the perpetrator or those who helped him had left feces and vomit in the bathroom of her home and an empty shell of an insect on her front step. 46. On December 3, 1996, Licensee reported she heard pounding on the house and about 3:00 a.m. She shouted out the window, "Get out of here before God curses you!" Licensee had made numerous reports to the police about pounding on her outside wall and stated there was damage to the stucco on that outside wall. She also stated that one of the people she suspected of doing this had been hospitalized for this behavior in the past (clients #2 and #3' mother). 47. On December 6, 1996, according to police records, Licensee reported that person who had been harassing her had stopped doing so since she had stopped counseling people who she believed were victims of, or connected, with, the Summit Avenue Cult, the St. Cloud Cult, or the Wetterling case. Licensee told police officers that, initially, much of what she saw (80 percent by her estimation) was paranoia and that she did not notify the police about suspicious incidents unless she was certain it was more than paranoia. 48. On December 9, 1996, according to police records, Licensee reported that on November 26, 1996, she had found a hair brush missing, a hinge taken off the bathroom cabinet door, and a pair of dirty underpants in a cabinet in the bathroom. The underpants were folded so that fecal stains were facing out. According to police records, Licensee reported that she was sure that these underpants did not belong to a family member and that the cleaning couple who were there that day took cleaning supplies from that cabinet and that there were no underpants in there in that morning. 49. On December 9, 1996, according to police records, Licensee told the police that she had wanted to hire a marine sniper to sit on top of her house for protection and that she had changed the locks to her house. Licensee asserts she made this remark in ridiculing the policeman's suggestion that she should have a private detective to stay in her home when she was not there. 50. On December 19, 1996, according to police records, Licensee reported that four days earlier she found a faint trident mark on the side of her garage. She had noticed trident markings on the side of her garage during the summer; they were similar to marks left by a ball her son bounces against the garage. When she questioned her son, he said he had a ball which left some marks, but he did not leave so many marks. 51. On December 19, 1996, according to police records, Licensee reported that two days earlier, she observed "drips" on the glass wall of the elevator at work. The drips were similar to those at her home. She reported that she saw a marking which looked like a trident and which seemed to be of a color similar to fingerprint powder. 52. On December 20, 1996, according to police records, Licensee reported that on the previous day, she had found a child's soiled sock on the steps in front of her home. She gave it to the police. The police sergeant examined the sock and found a small piece of cellophane tape on the bottom. Attached to the tape was a small piece of paper inscribed with a very small letter "c," similar to the extremely small printing on the anonymous letter she received. Licensee believed this may have been a type of message to her, as if symbolic for "cult" or something of a similar nature. 53. On December 24, 1996, according to police records, at Licensee's request, the police sergeant, who had been taking most of her reports, met with her at her home. She showed him wax drippings and a stain on the stair landing carpet. She claimed that client #2 had reported a similar stain at her home. Licensee said the wax on the carpet, as well as two drops of wax on a window sill, had appeared over the previous weekend. Licensee also noted that the perpetrator had fixed the laminate on her medicine cabinet. ____________________________________________________ Investigating Officer's Observations and Conclusions 54. On October 8, 1996, the police sergeant interviewed clients #2 and #3. In a memorandum prepared after the interview, the sergeant noted that although Licensee had told him the clients were survivors of satanic/ritual abuse by their parents and a satanic cult form Oregon, their report to him of abuse was vague and lacked detail of occult-specific data. The sergeant concluded: "While it is evident these women believe the reported incidents themselves, there is neither physical evidence, nor reported evidence to substantiate a belief in the accuracy of the incidents recalled." 55. In his December 26, 1996, report, the sergeant noted the following: "Most of the reports of unusual occurrences have a logical explanation... These occurrences most often are normal actions or results of same.... While the complainant does not appear to accept any of these explanations, there is insufficient evidence to proceed further at this time." ________________________________ Additional Mental Health History 56. In 1995 and 1996, Licensee suffered significant stress, depression, and anxiety in part due to alleged stalking she believes was perpetrated by the father of client #2 and client #3, and associated cult members. 57. After clients #2 and #3 terminated their group therapy on November 12 and November 7, 1996, respectively, Licensee told her psychiatrist in a session on November 18, 1996, "I'm left [to deal] with their parents." ____________________________ Individual and Group Therapy 58. In August or September 1996, Licensee disclosed to client #2's Tuesday group members that things were occuring in Licensee's home which led her to believe she was being harassed by client #2's parents. Licensee reported examples of the alleged harassment during several sessions. Licensee added to the atmosphere of fear in the group, encouraging the group to discuss fears that anyone who was affiliated with client #2 was in danger, particularly those with children. 59. In August of September 1996, group therapy notes for client #2 states, "Doing OK, lots of memories regarding the cult [Licensee] told her about call to police department. Treatment Actions: Need to assess if harassment related." 60. On October 18, 1996, Licensee, the co-facilitator for the Tuesday and Thursday therapy groups, client #2, and client #3 met to discuss the alleged harassment of Licensee and to explore options. Client #2 said she was considering leaving Fredrickson & Associates and a referral was discussed. Clients #2 and #3 claim Licensee asked them to help stop the harassment; she denies this. 61. On November 1, 1996, Licensee, the co-facilitator, client #2, and client #3 met with consultant #1, a psychologist, for the purpose of assisting client #2 and client #3. The consultant was concerned about Licensee's objectivity. Licensee stated that she had another consultant available to discuss how the therapy relationship had been impaired by the alleged harassment. 62. The consultant observed, and Licensee agrees, that Licensee was frightened and stressed at the November 1, 1996 meeting. The consultant believed Licensee's objectivity was impaired by her anxiety. The consultant believed that after the alleged stalking began, Licensee's boundaries blurred. For example, Licensee became concerned about herself and her clients, which jeopardized the professional distance necessary in a therapeutic setting. The consultant believed Licensee should have referred the clients to another provider earlier. 63. Licensee admitted to the Board's investigator that she continued to treat client #2 and client #3 after she began to experience harassment which she suspected was being perpetrated by the clients' parents. 64. On November 7, 1996, which was client #3's final group session. Licensee cried and was angry with client #3. At one point, Licensee told client #3, "Oh great, you're dumping the whole thing in my lap." 65. During individual therapy sessions. Licensee told client #4 about the alleged incident of cult stalking occuring at her home and office. Licensee attributed the alleged stalking to client #2's parents. Licensee's discussions about stalking sometimes took up to 15 minutes of the therapy sessions. 66. In August or September 1996, Licensee told the Thursday group members that she was very possibly being stalked in connection with client #2 and client #3's family. Licensee continued to provide details of the alleged stalking at subsequent group sessions, including the following: (1) her house was broken into; (2) her TV had been moved; (3) clothing had been moved; and (4) an eviscerated bug was left on her porch. Licensee also told the group that files were stolen from the office. On one occasion, Licensee frightened group members by asking one client if she had a list of telephone numbers of group members in her home when she was stalked. On another occasion during group therapy, Licensee claimed that after each group session she and the co-facilitator received strange telephone calls or hang-ups after the Tuesday and Thursday groups, and that now the calls were coming during groups, possibly attributable to client #3's parent. When the telephone rang, Licensee told client #3, "If this is your parents, I'm handing the phone to you." The allegations of stalking alarmed group members, and prevented them from doing their own therapeutic work IV. _Failure to Obtain Informed Written Consent to Disclose Private Information_ 67. In February 1995, without the informed written consent of client #2, Licensee gave client #1 the name and telephone number of client #2 for the purpose of having the clients discuss their memories of ritualistic abuse. Client #1 later contracted client #2 and arranged a lunch at which the two discussed their common memories of abuse. 68. In September 1996, Licensee failed to protect the privacy of client #2 and client #3 in that she reveled their full names as well a certain therapy issues to police officers without permission from the clients. Licensee also discussed client #2 with client #4 without having obtained informed written consent from client #2 to do so. 69. See paragraph 40 above which involves a violation of confidentiality. 70. In December 1995, client #2 attended a therapy session with client #4 and client #4's then five-year-old son, client #5. Client #2 had met client #4 in the Tuesday group and the two of them had become close friends. Based on previous sessions with client #5, Licensee believed he may have been abused in a cult setting. At the joint session on December 19, 1995, client #2, who had come to the session for support, brought her own family album because she believed her parents may have been involved in abusing this child. While looking at client #2's album, client #5 identified client #2 and client #2's mother as people from whom he should be protected. Licensee then told him the pictures were of client #2 and her mother. Client #5 became afraid of client #2. 71. Later, on December 19, 1995, when client #2 raised the issue in group of client #5 having pointed her out in a group picture, Licensee discussed with client #2 various possibilities, including the presence of multiple personalities or unconscious connection with the cult. Client #2 had suicidal thoughts resulting from Licensee's statements and had to have someone drive her home after the session. 72. In August or September 1996, Licensee also began telling client #3's Thursday group about the alleged harassment she believed she was suffering at the hands of client #3's parents. 73. Licensee told the Board's investigator that she did not talk to client #2 and client #3 individually before she disclosed the alleged harassment by their parent to their respective therapy groups. Licensee stated that in hindsight it would have been appropriate to consult. 74. See paragraphs 55, 65, and 67 above, which describe Licensee disclosing confidential patient information to other patients during therapy. 75. Licensee did not have written informed consent from client #2 to disclose information to client #4. Licensee acknowledges that she needed a release of information to discuss client #2 with client #4 and stated that "[T]he boundaries were blurred for me, because of the mounting stress and the interconnectedness of client #2 and #4." V. _Unprofessional Conduct; Failure to Maintain Boundaries_ 76. Licensee disclosed information about herself to client #1; for instance , she told client #1 that she had been sexually abused and that a Catholic priest had exposed himself to her. 77. On or about August 1995, client #3 had an individual therapy session with Licensee. After the session, the two were walking to their cars and Licensee told client #3 that Licensee and her spouse were separated. 78. A September 12, 1995, therapy note indicates that client #2 was "feeling affected by [Licensee and her husband's] separation." 79. As discussed in paragraph 66 above, during August or September 1996, Licensee began telling client #3's Thursday group about the alleged harassment she believed she was suffering at the hands of client #3's parents. Licensee's repeated discussion of alleged harassment by client #3's parents caused client #3 to feel she was responsible for the alleged harassment and should intervene to preserve the safety of Licensee and group participants. Licensee told client #3 that in the past the parents of clients had harassed her. In such cases Licensee had the clients intervene to address the problem. 80. See paragraphs 64 and 65 above for further examples of unprofessional conduct. 81. Licensee disclosed excessive details to client #4 about her divorce. 82. Licensee admits she disclosed too much personal information to her group clients, including details about her divorce, that she had no money, how her life was "in the toilet", and that she wanted to start dating. Licensee told the group that as part of her divorce and custody case, she was being subjected to mental health tests and a chemical dependency test. Licensee states, "I do think I was in so much personal pain that I said too much to clients." Licensee also told the group that a priest had exposed himself to her. After Licensee made some of these disclosures, at least one client expressed concerns about Licensee's stability and mental health. Some clients felt they needed to take care of Licensee and worried about how their statements during therapy would affect Licensee. Licensee claims that she responded in an appropriate and reassuring manner when this issue was raised in the Tuesday group. Some clients believed Licensee's performance and objectivity in group sessions were impaired. 83. Licensee took telephone calls from her son during group sessions. Licensee's attorney called during some sessions. Client #7 confronted Licensee about the disruptive telephone calls during one of the client's final group sessions. Licensee was apologetic at first, but followed the apology with a defensive remark, telling the client, "I suppose you could have my license for that too." Licensee told client #7 she was angry with client's complaint about her son's daily call during group time. 84. Client #7 terminated from Licensee's group because she did not like that Licensee had shared personal information about her divorce. VI. _Failure to Refer_ 85. After the alleged harassment of Licensee began, Licensee told client #2 and client #3 on more than one occasion that she should refer them to another therapist. However, she did not do so. Clients #2 and #3 stated they did not want a referral and preferred to finish therapy at Fredrickson & Associates. Client #2's case notes reflect this. 86. As discussed above in paragraphs 61 and 62 above, Licensee met with client #2, client #3, and a consultant to discuss the alleged harassment of Licensee by the clients' parents and to explore options. During that meeting, client #2 said that she was considering leaving Fredrickson & Associates and a referral was discussed, but not made. 87. Licensee admitted that, according to the Board rules, if the clients' parents were perpetrating the alleged harassment, she had a "special relationship" with clients #2 and #3 "and should refer them." Licensee added, "In hindsight, I think I didn't want to push referral for fear that it would look like I was trying to meet my own needs, although I knew I was in a dual relationship if I thought it was [client #3's] parents; it was a complicated situation." Licensee defended her actions by saying that she was trying to create a referral process in which the clients would not feel abandoned by a sudden referral. 88. When Licensee informed her therapist of her impairment (see paragraph 35 above), she failed to refer her clients to another therapist, as required. VII. _Failure to Keep Adequate Records_ 89. There are no session notes for the following dates on which client #1 received therapy from Licensee: 7/21/94, 9/13/94, 9/21/94, 10/6/94, and 1/19/95. Additionally, there were numerous instances in which there is a one or more day difference between the date of therapy listed in the chart and the dates indicated on the account ledger and on client #1's checks. For example, the chart indicates a session date of 8/1/94, but the ledger card and client #1's check indicate the session was on 8/3/94. Licensee told the Board's investigator that during some sessions, she and client #1 discussed only journal entries and, therefore, no notes were written for those sessions. 90. Licensee's file for client #1 does not contain a treatment plan that documents treatment goals. 91. Licensee failed to complete a treatment plan for client #2. Licensee acknowledges that she failed to do so and stated it was a departure from her work that was likely the result of the stress she was experiencing. 92. Licensee's final session note with client #4 is dated October 28, 1996. There is no indication in the therapy records as to why client #4 discontinued therapy. VIII. _Licensee's Current Practice_ 93. Licensee is currently providing psychological services in a solo practice. Licensee states she currently has no clients who are cult or ritual abuse survivors and does not accept any referrals of such cases. REGULATIONS 94. Based on the above facts, the Board views Licensee's conduct to be in violation of statutes and rules enforced by the Board. Licensee agrees that the facts cited above constitute violations of Minn. Stat. 148.941, subd. 2(a)(3) and 2(a)(1) (violation of statue or rule Board is empowered to enforce); Minn. R. 7200.5700 (unprofessional conduct or any other conduct which has the potential for causing harm to the public, including any departure from or failure to conform to the minimum standards of acceptable and prevailing practice, without actual injury having to be established); Minn. Stat. 148.941, subd. 2(a)(9) (inability to practice with reasonable skill and safety to clients due to a mental illness or condition); Min R. 7200.4600. sup. 1 (failed to limit practice to areas of competence which had been stated in writing to the Board); Minn. R. 7200.4600. subp. 3 (failed to consult with other professional and failure to inform clients of innovative nature and known risks associated with a newly developing service, technique, or specialty); Minn. R. 7200.4700, subp. 1 (failed to safeguard private information on clients); Minn. R. 7200.4810. subps. 1, 2.A., 2.D., 2.E., and 3 (impaired objectivity and failure to terminate services and refer clients when objectivity or effectiveness impaired); Minn. R. 7200.4900. subp. 1a (recordkeeping); Minn. R. 7200.4900. sub;. 5 (failed to inform a client of a divergence of interests, values, attitudes, or biases between a client and the psychologist sufficient to impair the professional relationship); and Minn. R. 7200.4900, subp. 6 (failed to terminate a professional relationship even though the client was not likely to benefit from continued professional services), and constitutes a reasonable basis in law and fact to justify the disciplinary action provided for in the order. REMEDY 95. Upon this stipulation and without any further notice of proceeding, the Board places Licensee's license in a RESTRICTED AND CONDITIONAL status. 96. Licensee's license is RESTRICTED as follows: a. _Practice_. Licensee is permanently restricted from providing therapy to clients whose therapy issues involve cult, ritual, or satanic abuse. Licensee is also permanently restricted from providing supervision or consultation to other therapists with respect to cult, ritual or satanic abuse. Licensee shall immediately refer any existing or future clients who have or develop a diagnosis or symptoms related to cult, ritual, or satanic abuse. b. _Services_. Licensee is restricted from providing hypnosis or guided imagery services to clients, except under supervision or training, until she can demonstrate, to the satisfaction of the Complaint Resolution Committee, through the appropriate combination education, experience, training, and supervision, that she is competent to provide these psychological services. 97. Licensee's retention of her license is CONDITIONAL upon her complying with and/or submitting or causing to be submitted at least the following: a. _Psychological Evaluation_. Licensee shall complete a psychological evaluation and the Board shall receive the evaluator's report within 90 days of the date of this order. The evaluation shall be performed by a licensee of the Board who is not acquainted personally or professionally with Licensee and who has been approved in advance by the Board's Complaint Resolution Committee from a list of three names provided to the Committee by Licensee. Licensee shall cause each of the named evaluators to submit a current vitae to the Board for the Committee's review prior to approval of the evaluator. The Committee may, at its discretion, reject all names submitted by Licensee and select an evaluator from outside of the list submitted by Licensee. Licensee shall sign a release of information authorization which will allow the Committee to communicate with the evaluator both verbally and in writing. Licensee shall also sign release of information authorizations which will allow her current physician, psychiatrist and therapist to communicate with the evaluator and the Committee, both verbally and in writing. Licensee is responsible for the cost of the evaluation. The results of the evaluation shall be sent directly to the Board. b. _Evaluator's Report_. The evaluator's report shall include and/or address the following: 1) Verification that the evaluator has received and reviewed a copy of this stipulation and consent order and the information submitted by the Board; 2) A listing of all psychological and psychophysiological tests administered and related interpretive data; 3) Licensee's degree of cooperation, openness, and honesty while undergoing the evaluation; 4) A complete social and mental health history; 5) Identification of therapeutic issues underlying Licensee's past inability to maintain appropriate professional boundaries with individuals with whom Licensee interacts professionally; 6) Licensee's current mental status; 7) A summary of the results of the evaluation including a psychological assessment, applicable diagnoses, and specific recommendations for treatment, if necessary, including frequency and type of any recommended therapy sessions for any psychological or personality disorders; 8) Licensee's ability to practice psychology in a competent, ethical, safe and professional manner, and 9) Any other information which the evaluator believes would assist the Board in its ultimate review of this matter. c. _Current Therapist's Report_. Licensee's current therapist shall submit a report to the Board within 90 days of the date of this Order. It shall include and/or address the following: 1) Verification that the therapist has received and reviewed a copy of this stipulation and consent order and the information submitted by the Board; 2) A summary of Licensee's therapy, including a mental health history, psychological assessment, diagnoses, treatment plan, frequency of therapy sessions, and an estimate of the length of treatment; 3) Licensee's current mental status; 4) Any other information which the therapist believes would assist the Board in its ultimate review of this matter; and 5) In lie of items 2 through 4 in this section, Licensee's current therapist may provide a complete copy of licensee's treatment record to the Board within 30 days of the date of the Stipulation and Consent Order. d. _Additional Action_. Based on the evaluator's report and current therapist's report or treatment records, the Board reserves the right to impose additional appropriate disciplinary action on Licensee's license. e. _Treating Therapist_. If any treatment is recommended by the evaluator or Licensee's current therapist or as required in the judgment of the Committee based on Licensee's treatment records, Licensee shall comply with the treatment recommendations and shall be responsible for the cost of treatment. The therapist providing the treatment shall be a different individual than the evaluator and shall be approved in advance by the Compliant Resolution Committee from a list of at least three names submitted by Licensee. Licensee shall submit these names, and shall cause each of the named therapists to submit a current vitae to the Complaint Resolution Committee for review prior to its approval of the therapist. Licensee shall have 45 days to complete this requirement following notification from the Complaint Resolution Committee. f. _Treating Therapists Reports_. The therapist shall submit a report to the Board every 3 months and at the time Licensee petitions to have the conditions removed from her license. The first report is due three months after the date of the first session with the approved therapist. All subsequent reports shall be submitted the first day of the month in which they are due. Each report, except where indicated otherwise, shall provide and/or address the following: 1) In the first report, a statement that the the therapist has received and reviewed a copy of this stipulation and consent order and the evaluator's report; 2) In the first report, identification of a treatment plan devised specifically for Licensee. Any subsequent changes made in such treatment plan are to be identified in later reports; 3) A statement of the involvement between Licensee and the therapist, including dates, number and frequency of meetings; 4) Licensee's therapeutic progress and compliance with treatment plan; 5) The therapist's opinion as to Licensee's capacity to understand her professional role and the boundaries of that role and her ability to distinguish between her personal and professional needs, identity and behavior; 6) The therapist's opinion as to the need for continuing therapy or Licensee's discontinuance of therapy; 7) Any other information which the therapist believes would assist the Board in its ultimate review of this matter; and 8) At the time Licensee petitions for removal of the above referenced conditions, the therapist's report shall include an assessment of the Licensee's ability to conduct herself in a fit, competent and ethical manner in the practice of psychology. The Board further reserves the right to impose additional appropriate disciplinary action on Licensee's license based on reports of Licensee's treating therapist, if the Board determines that Licensee's mental health has deteriorated so as to pose a risk to the public health and welfare. g. _Boundaries Course_. Within nine months of the date of this stipulation and consent order, Licensee shall successfully compete the individualized professional boundaries training course taught by John Hung, Ph.D., L.P. All fees for the course shall be paid by Licensee. Successful completion shall be determined by the Complaint Resolution Committee. h. _Report on Boundaries Course_. Within 30 days of completing the professional boundaries course referenced above, Licensee shall submit a report to the Complaint Resolution Committee which provides and addresses: 1) the dates Licensee began and completed the boundaries training course; 2) a brief statement of the topics covered in the professional boundaries training course; 3) what Licensee has learned from the boundaries training course, including Licensee's comprehension and knowledge of boundary issues, as well as various ethical issues encountered in practice, and how this course will affect her practice in the future; 4) Licensee's reasons for believing that she is capable of conducting herself in a fit, competent, and ethical manner in the practice of psychology; and 5) any other information which Licensee believes would assist the Board in its ultimate review of this matter. i. _Report on Boundaries Course from Instructor_. Within 60 days of completing the professional boundaries course referenced above, Licensee shall cause to be submitted to the Board a report from the instructor of the professional boundaries course. This report shall address: 1) the extent of Licensee's participation in the course: and 2) the instructor's assessment of Licensee's knowledge obtained from the course and opinion as to Licensee's recognition of boundary issues and Licensee's ethical fitness to engage in the practice of psychology. j. _Professional Responsibility Examination_. Licensee shall take the examination described in Minn. R. 7200.3000, subp. 1.B., within six months of the date of this stipulation and consent order, and retake the examination, if necessary, until obtaining a passing score. k. _Continuing Education_. Licensee shall successfully complete six (6) units of continuing education in recordkeeping within one year of the date of service of this stipulation and consent order. The continuing education must be approved in advance by the Committee. Licensee shall provide verification of completion to the Committee. Licensee may apply these units to her continuing education retirement for licensure renewal. l. _Civil Penalty_. Licensee shall pay a civil penalty to the Board in the amount of fifteen thousand ($15,000) dollars for engaging in the 15 violations described the paragraph 105 above. Payment of $15,000 shall be remitted in full to the Minnesota Board of Psychology at Suite 320, 2829 University Avenue SE, Minneapolis, Minnesota 55414 within sixty (60) days of the date of this order. m. _Fine for Violation of Order_. If any due date required by this stipulation and consent order is not met, the Committee may fine Licensee $100 per violation. Licensee shall pay the fine and correct the violation within five days after service on Licensee of a demand for payment and correction. If Licensee fails to do so, the Committee may impose additional fines not to exceed $500 per violation. The total of all fines may not exceed $5,000. Licensee waives the right to seek review of the imposition of these fines under the Administrative Procedure Act, by writ of certiorari under Minn. Stat. 480A.06, by application to the Board, or otherwise. Neither the imposition of fines nor correction of the violation will deprive the Board of the right to impose additional discipline based on the violation. n. _Costs_. Licensee shall be responsible for all costs incurred as a result of compliance with this stipulation and consent order. 98. All reports shall cover the entire reporting period and provide the bases upon which conclusions were drawn. 99. The Board or its authorized representatives shall have the right to discuss Licensee's condition with and obtain records from any person with whom Licensee has contact as a result of her compliance with this stipulation and consent order or as a result of her being examined or her obtaining treatment, counseling, or other assistance on her own initiative or otherwise. Licensee shall execute and provide any health record or other waivers necessary for submission of the reports reference in the stipulation to enable the Board to obtain the information it desires and to authorize the testimony of those contacted by the Board in any proceeding related to this matter. 100. The Board may, at any regularly scheduled meeting at which Licensee has made a timely petition, take any of the following actions: a. Remove the restrictions or conditions attached to the license of Licensee; b. Amend the restrictions or conditions attached to the license of Licensee; c. Continue the restrictions or conditions attached to the license of Licensee upon her failure to meet her burden of proof; and d. Impose additional disciplinary actions on the license of Licensee. 101. If Licensee shall fail, neglect or refuse to fully comply with any of the terms, provisions, and conditions herein, the license of Licensee to practice psychology in the State of Minnesota shall be suspended immediately upon written notice by the Board to Licensee, such a suspension to remain in full force and effect until Licensee successfully petitions the Board to terminate the suspension after a hearing. Nothing contained herein shall prevent the Board from revoking or suspending Licensee's license to practice psychology in the State of Minnesota after any such hearing. 102. If Licensee's license has been suspended as discussed above. Licensee may petition to have the suspension lifted at any regularly- scheduled board meeting following Licensee's submission of a petition. provided that the petition is received by the Board at least 20 working days before the Board meeting. The Board shall grant the petition upon a clear showing by Licensee that she has corrected all violations of this stipulation and consent order which were the basis for the suspension. Based on the evidence presented, the Board may impose additional conditions or limitations upon reinstating Licensee's license. 103. This stipulation shall not in any way or manner limit or affect th authority of the Board to proceed against Licensee by initiating a contested case hearing or by other appropriate means on the basis of any act, conduct, or omission of Licensee justifying disciplinary action which occurred before or after the date of this stipulation and which is not directly related to the specific facts and circumstances set forth herein. 104. In the event the Board at its discretion does not approve this settlement or a lesser remedy than indicated in this settlement, then, and in that event, this stipulation is withdrawn and shall be of no evidentiary value and shall not be relied upon nor introduced by either party to this stipulation, except that Licensee agrees that should the Board reject this stipulation and this case proceeds to hearing, Licensee will assert no claim that the Board was prejudiced by its review and discussion of this stipulation or of any records relating to this matter. 105. Any appropriate court may, upon application of the Board, enter its decree enforcing the order of the Board. 106. Licensee has been advised by Board representatives that she may choose to be represented by legal counsel in this matter. Licensee has bee represented by Thomas Sanner. 107. Licensee waives all formal hearings on this matter and all other procedures before the Board to which Licensee may be entitled under the Minnesota or United States constitutions, statutes, or rules and agrees that the order to be entered pursuant to the stipulation shall be the final oder herein. 108. Licensee hereby acknowledges that she has read, understands, and agrees to this stipulation and has freely and voluntarily signed the stipulation without threat or promise by the Board or any of its members, employees, or agents. When signing the stipulation, Licensee acknowledges that she is fully aware that the stipulation shall be approved by the Board. The Board may either approve the stipulation and consent order as proposed, approve the stipulation and consent order subject to specified change, or reject it. If the changes are acceptable to Licensee, the stipulation will then take effect and the order as modified will be issued. If the changes are unacceptable to Licensee or the Board rejects the stipulation, it will be of no effect except as specified herein. 109. This stipulation and consent order constitutes a disciplinary action against the Licensee. 110. This stipulation and consent order is a public document and will be sent to all appropriate data banks. 111. This stipulation contains the entire agreement between the parties there being no other agreement of any kind, verbal or otherwise, which varies this stipulation. BOARD OF PSYCHOLOGY COMPLAINT RESOLUTION COMMITTEE ______________________________ ______________________________ RENEE FREDRICKSON, Ph.D., L.P. NORMAN L. JAMES, Ph.D., L.P. Licensee Dated: May 3, 1999 Dated: May 7, 1999 ______________________________ SAMUEL ALBERT, Ph.D., L.P. Dated: May 7, 1999 ______________________________ ______________________________ THOMAS SANNER ROSELLEN CONDON Hinshaw & Culbertson Assistant Attorney General 3200 Piper Jaffray Tower 500 Capitol Office Building 222 South Ninth Street 535 Park Street Minneapolis, MN 55402 St. Paul. MN 55103-2106 Telephone: (612) Telephone: (651) 297-1050 Attorney for Licensee Attorney for Committee Dated: 5/3, 1999 Dated: 5-7, 1999 ORDER Upon consideration of this stipulation and all the files, record, and proceedings herein, IT IS HEREBY ORDERED that the Licensee is placed in a RESTRICTED AND CONDITIONAL status and that all other terms of this stipulation are adopted and implemented by the Board this 7th day of May, 1999. MINNESOTA BOARD OF PSYCHOLOGY ______________________________ PAULINE WALKER-SINGLETON Executive Director