Outside the Rules:
Fiduciary Theory and Evidence of Multiple Victims
in Therapist Sexual Misconduct Cases

Therapists' sexual contact with patients is distressingly common. In nationwide surveys, up to 13.7% of therapists self- report engaging in sexual relations with patients.2 Since the early 1980s, all major mental health organizations have proscribed such practice as a breach of the patient's trust and a violation of the duty to "first, do no harm."3 Several states have adopted civil statutes to create specific causes of action for people harmed by such contact; fourteen states have criminalized therapist-patient sexual contact.4 Jury verdicts in therapist malpractice cases have topped $7 million.5

The issue in these cases is simple: a trained professional uses his or her power and influence to abuse and exploit a trusting patient. The emotional appeal of such cases increases when it becomes known that the professional has engaged in a predatory pattern of abusive behavior.6 Indeed, research shows that up to eighty percent of therapists who have had sexual contact with one patient, had sexual contact with other patients.7 Some commentators suggest that a therapist's past exploitative behavior toward a client is the best single predictor for exploitation of future clients.8

The Federal Rules of Evidence generally bar admission at trial of same act evidence to show the defendant acted in conformance with past acts on the theory that its prejudicial value far outweighs any probative value.9 The Federal Rules do not distinguish between use of the evidence in criminal or civil trials. Some scholars argue that "the marginal probative value of character evidence in proving individual actions generally is small. . . [and] 'however relevant character evidence is in the abstract, its incremental relevance in the context of a specific case is likely to be low.'"10 In the area of therapist-patient sexual contact, however, studies have demonstrated to the contrary.

The Federal Rules of Evidence contain exceptions allowing the admission of same-act evidence. Other options exist outside the formal Rules to gain admission of same-act evidence. This article will briefly discuss each of these options.

Going By The Rules

1. Rule 404(b) Exceptions

Rule 404 of the Federal Rules of Evidence states that a defendant's prior misconduct is not admissible to show that the defendant has a propensity to commit similar harmful acts. There are exceptions contained in other Rules11 and within Rule 404 itself there are exceptions. Rule 404(b) provides that evidence of other crimes, wrongs, or acts may "be admissible for other purposes," which are further detailed in the rule.

Examples of "other purposes" for same-act evidence under Rule 404(b) are to show knowledge, intent, motive, identity, plan, preparation, opportunity, or absence of mistake or accident.12 To this list, Rule 406 and some courts have added "habit."13 If the same-act evidence fits one or more of these categories, then the court must determine whether the evidence is relevant to an issue other than the person's character14 (including, did the act happen? is it substantially similar to the other act?), and second, whether the probative value of the evidence outweighs its potential for unfair prejudice.15

The application of exceptions such as those contained in Rule 404(b) varies from the federal courts to the individual state courts. The North Carolina court in MacClements v. LaFone held that under that state's version of Rule 404(b), testimony of three other victims was admissible in the plaintiff's case against her psychotherapist. The court found that "[t]he ultimate test for determining whether such evidence is admissible is whether the incidents are sufficiently similar and not so remote in time as to be more probative than prejudicial under the balancing test of N.C.G.S. § 8C-1, Rule 403."16 The facts the court considered in MacClements to find the prior evidence similar to the charged evidence were that all patients testifying had been treated by the defendant in his office; that the sex occurred both at the office and at the defendant's home; and that the defendant concluded each relationship before beginning the next. The court then admitted the evidence as "[i]t tends to demonstrate defendant's scheme or intent to take advantage of female patients being treated by him at [the mental health center]."17

Introducing evidence under the 404(b) exceptions is not without pitfalls. The "other purposes" under the Rule (with the possible exception of habit) run contrary to the cause of action propounded by most plaintiffs' attorneys in sexual misconduct cases. The predominant legal theory is "negligent mishandling of transference": that is, the therapist acted negligently with respect to the transference or love feelings that the patient developed as part of the ordinary course of psychotherapy.18 It is also likely that the defendant's malpractice insurance excludes coverage for anything other than negligent acts.19 If the plaintiff is able to show the defendant engaged in a common plan or scheme, the defendant's insurer may then successfully argue that the defendant's acts were intentional and thus not covered by the policy. Careful planning and strategizing are essential in these complicated cases.

2. Rule 703 Exception: Basis for Expert Testimony

Federal Rule of Evidence 703 allows a testifying expert to base his or her opinion on facts or data which, if they are the type reasonably relied upon by experts in the particular field in forming opinions or inferences upon the subject, need not be admissible in evidence. There is debate on whether this Rule creates a window for otherwise inadmissible evidence. Some courts have held, "The proper inquiry is not what the court deems reliable, but what experts in the relevant discipline deem it to be."20 Other courts have further elaborated that, "The way to combat such evidence is by cross-examination, not claiming foul."21

The plaintiff's expert may interview other victims of the therapist to provide corroboration of the therapist's propensity to cross boundaries with patients, or to provide evidence of the type of damage caused patients by the particular defendant.22 Arguably, the expert may then give testimony at trial regarding the nature, if not the content, of these interviews. Reasonable care suggests that in the event the court refuses to admit such testimony, the plaintiff's attorney have an alternate expert available.

Outside The Rules

1. Evidence of Prior Act Admitted to Establish Specific Element of Claim

Some causes of action require a showing of repeat conduct. If multiple victims are known, then a claim which incorporates this information may be appropriate, such as a cause of action against the therapist's supervisor or employer for negligent hiring, supervising, or retaining.23

In Copithorne v. Framingham Union Hospital, the doctor's employer, Framingham Union Hospital, had received actual notice of allegations that the doctor had sexually assaulted patients both on the hospital premises and off. The court found the hospital liable for the injuries caused a subsequent patient, concluding that it was not unforeseeable that the doctor would continue to act in a consistent, if not worse, manner.24

Claims under fraud-based statutes such as civil RICO (Racketeer Influenced and Corrupt Organizations Act) require the plaintiff to prove that the defendant engaged in a pattern of conduct.25 In Roe v. Doe, a former client of an attorney brought an action under RICO against her attorney. The attorney had engaged in a sexual relationship with his client and in other inappropriate behaviors. To show that the attorney engaged in "similar schemes of fraudulent activity," the plaintiff proffered testimony of three other victims.26 This case, however, was dismissed because the plaintiff failed to allege damage to property, as required by RICO.

Evidence of multiple victims is relevant in a negligence count alleging the therapist practiced beyond the scope of his or her competence. That the therapist was practicing while impaired can be supported by same-act evidence showing: (1) proof of the existence of the impairment (the defendant's predilection to becoming overly involved with patients), (2) proof of dangerousness of that condition, and (3) proof of notice of existence of the dangerous physical condition.27 Same-act evidence may also be admitted when punitive damages are sought to aid the jury in determining how much "punishment" to mete out against defendants for their conduct over the course of their practice.28

There may also be tactical reasons for pleading cases on behalf of several plaintiffs as it may in some contexts enhance individual plaintiff's recovery. The sexual abuse allegations against James Porter, who abused children while serving as a priest, and the Catholic Diocese of Fall River, Massachusetts exemplify the latter. Massachusetts has charitable immunity which insulates the Catholic Church and other similar non-profit institutions from recoveries in excess of $20,000.29 The effect, however, of 70 people together claiming Porter abused them arguably caused the Church properly to compensate them rather than hide behind statutory immunity.30

2. Relation of Evidence to Other Disputed Issues

In some situations, evidence of the defendant's abuse of other patients may relate to other issues in dispute, such as the applicable statute of limitations.31 For example, meetings between victims of the same therapist may be the "triggering" device that causes the plaintiff to recognize the therapist's actions as inappropriate. The plaintiff in Riley v. Presnell did not causally connect his psychiatrist's wrongful treatment with his injuries until he was introduced to another patient of the psychiatrist and compared notes with that patient.32 Thus, testimony concerning this meeting and the information exchanged became relevant to establish the plaintiff's knowledge of the harm for statute of limitations purposes.

Plaintiffs may suffer injuries directly related to the therapist's sexual activities with others. Evidence of the therapist's non-monogamy is relevant to the plaintiff's claim that he or she either contracted or fears contracting a sexually transmitted disease from the therapist.33 In addition, the betrayal that characterizes many victims' reactions when they discover that their therapist abused them may be compounded by the knowledge that the therapist abused others in the same fashion.

3. Evidence of Prior Act Admitted to Rebut Specific Defense

Defendants may make their physical condition an issue in the defense of the lawsuit. In such cases, the plaintiff may introduce specific-act evidence to rebut the defendant's claims.34 In Roy v. Hartogs, the defendant, Dr. Hartogs, claimed he could not have engaged in sexual contact with the plaintiff or with any patient during the period of treatment due to a hydrocele (an enlargement of the testicles caused by fluid) that affected his sexual capabilities. Because Dr. Hartogs made his physical condition relevant, rebuttal testimony by a former patient concerning his sexual capacity was admissible.35

Proof of the effects of the therapist's "treatment" on other victims may also be introduced to prove causation. The theory is like the "observational scientific method": the hypothesis is that the therapist's acts caused the plaintiff's injuries, and to experimentally verify this, the plaintiff shows that similar acts by the therapist caused similar harms.36

4. Fiduciary Theory and Admission of Evidence of Multiple Victims

Relevant evidence is admissible unless otherwise deemed inadmissible.37 The theory underlying the prohibition on same-act evidence focuses on the prejudicial effect on the defendant--the trier of fact would most likely conclude, "he did it once, he did it again."38 In the arena of therapist-patient sexual contact, however, therapists generally do do it again. We submit that the policy supporting increased fairness--fiduciary theory-- outweighs the policy of prohibiting same-act evidence.

As noted at the outset, therapist-patient sexual misconduct cases revolve around the issues of power, influence, trust, and exploitation. Indeed, therapists are fiduciaries to their patients.39 Fiduciaries are held to a higher standard of care with respect to their entrustors in recognition of the lack of a "level playing field."40 Because of this, they are under an affirmative duty to disclose all material facts which might affect the rights and interests of the vulnerable party.41 The statute of limitations tolling devices available in fiduciary misconduct cases, fraudulent concealment and equitable estoppel, reflect an attempt to correct the inherent unfairness regular rules would otherwise impose on the trusting party in fiduciary relationships.42 Fiduciaries occupy a unique position from which they may conceal, and indeed do conceal, their prior bad acts from their entrustors. Public policy dictates that the vulnerable party in such fundamentally unfair situations be afforded special rights, such as longer periods of time within which to bring suit.

Psychotherapists' sexual involvement with patients is common. The American Psychiatric Association specifically warns practitioners that "the necessary intensity of the therapeutic relationship may tend to activate sexual and other needs and fantasies on the part of both patient and therapist, while weakening the objectivity necessary for control."43 One court noted that therapists' mishandling of patients' transference actually constitutes an "occupational risk."44 Recidivism rates are high: up to 80% are repeat offenders.45

Psychotherapy patients who sue their therapists are compromised at the outset as witnesses because an element of their subsequent claim against the therapist is that they needed, sought, and received mental health care.46 While victims' reports of sexual abuse are generally credited by their therapists,47 defendants in sexual misconduct suits often portray the plaintiff as an emotionally unstable individual with a propensity to fabricate, exaggerate, or misunderstand interpersonal relationships.48 Corroborating evidence (letters, credit card receipts from out-of-office forays) may either not exist (the savvy therapist who is skilled in deception uses only cash) or may be destroyed by the therapist or patient at the therapist's instruction ("Destroy this note after you've read it"). In contrast, mental health professionals are enhanced as witnesses by virtue of their more exhaulted positions in society in general.49 Other matters aside, in the ensuing credibility contest between patient ("it happened") and therapist ("it didn't"), the therapist has the advantage.

Fiduciary theory provides the justification of fairness for allowing evidence of multiple victims to be introduced at trial. Admission of evidence of the therapist's abuse of other patients is clearly relevant. The rationale for excluding same-act evidence falls apart in the area of the therapist-patient sexual exploitation as its "incremental relevance in the context of each specific case" is high. The playing field is not level for the patient seeking compensation from an abusive therapist. Evidence of a therapist's exploitation of multiple victims should be introduced in civil trials.


ENDNOTES

  1. By Linda Mabus Jorgenson, Pamela K. Sutherland, Steven Bisbing. Copyright 1995. This article is adapted from a chapter in the authors' book, SEXUAL ABUSE BY PROFESSIONALS: A LEGAL GUIDE (Michie Company, 1995).
  2. See generally, Kenneth Pope, Therapist-Patient Sexual Contact: A Review of the Literature, 10 CLIN. PSYCHOL. REV. 477 (1990).
  3. See generally, Linda Jorgenson et al., The Furor Over Psychotherapist-Patient Sexual Contact: New Solutions to An Old Problem, 32 WM. & MARY L. REV. 645, 647 n.1 (1991).
  4. See generally id. at 664-683; Linda Mabus Jorgenson & Gary Richard Schoener, Regulation in the U.S.A., in PATIENTS AS VICTIMS: SEXUAL ABUSE IN PSYCHOTHERAPY & COUNSELLING 149 (Derek Jehu, 1994).
  5. David S. Rubsamen, What Are The Insurer's Obligations In Cases of Sexual Misconduct?, PHYSICIANS' FINANCIAL NEWS, Sept. 30, 1994, at 22 (describing May, 1994 verdict of $7.1 million against a psychiatrist for sexual misconduct with patient).
  6. GARY R. SCHOENER ET AL., PSYCHOTHERAPISTS' SEXUAL INVOLVEMENT WITH CLIENTS: INTERVENTION & PREVENTION 401-04 (1989).
  7. See J.C. Holroyd & Annette M. Brodsky, Psychologists' Attitudes and Practices Regarding Erotic and Nonerotic Physical Contact With Their Patients, 134 AM J. PSYCHIATRY 843, 849 (1977) (discussing research findings); Nanette K. Gartrell et al., Psychiatrist-Patient Sexual Contact: Results of a National Survey, 143 AM. J. PSYCHIATRY 1126, 1128 (1987).
  8. See Carolyn Bates & Annette Brodsky, Sex In The Therapy Hour: A Case of Professional Incest (1989).
  9. See FED. R. EVID. 404(b). See also, MCCORMICK ON EVIDENCE § 186 (1984) (citing M. SAKS & R. HASTIE, SOCIAL PSYCHOLOGY IN COURT 162-63 (1978)). Some states have not adopted the Federal Rules of Evidence. See, e.g., PAUL J. LIACOS, HANDBOOK OF MASSACHUSETTS EVIDENCE (1994).
  10. LEMPERT & SALTZBURG, A MODERN APPROACH TO EVIDENCE 237 (2d ed. 1983).
  11. See, e.g., FED. RULES OF EVID. 608, 609.
  12. See generally, 2 WEINSTEIN'S EVIDENCE § 404(13), at 72-77 (1994); Cotgreave v. Public Admin., 443 N.Y.S.2d 971, 973 (1981), appeal dismissed, 91 A.D.2d 600 (2d Dept. 1982) (in a medical malpractice case, court allowed evidence of "prior operations on persons other than the plaintiff, by [the doctor] for the purpose of proving a common plan or scheme to perform unnecessary and contraindicated surgery."); People v. Caprio, 364 N.Y.S.2d 588, 590 (3d Dept. 1975) (prior bad acts admissible to show the absence of mistake or accident in child abuse case). See also David Bryden & Roger Park, Other Crimes Evidence in Sex Offense Cases, 78 MINN. L. REV. 529 (1994).
  13. EDWARD J. IMWINKELRIED, UNCHARGED MISCONDUCT EVIDENCE § 7:14 (1994) (evidence is relevant to show defendant has a habit of acting a certain way: (1) defendant exhibits a specific behavioral pattern that is more probative of conduct than character; (2) defendant frequently repeats the behavioral pattern; (3) defendant regularly adheres to pattern; and (4) (in some jurisdictions) the behavioral pattern is semi-automatic. Arguably this is the only exception relevant to plaintiffs seeking recovery under negligence theories.).
  14. Compare, State v. Dee, 752 S.W.2d 942, 947-48 (Mo.App. 1988) (case worker's sexual abuse of multiple clients admissible to show his common scheme or plan to use his position of authority to obtain sexual gratification); State v. Sladek, 835 S.W.2d 308, 312-13 (Mo. 1992) (dentist's sexual abuse of multiple patients not admissible to show a common scheme or plan to exercise his authority over female patients in order to take advantage of them sexually because "there is no showing that Sladek had any authority or power over his patients as a person in the position of Dee would have. . . .").

    The plaintiff may not offer evidence of a defendant's uncharged torts to demonstrate a general character trait for negligent conduct. See, e.g., Donald v. Rast, 927 F.2d 379, 381 (8th Cir. 1991).

    A minority of jurisdictions have a relatively easy method for answering this query which is based upon a showing that a reasonable person could find that the act was in fact committed. See, e.g., United States v. Beechum, 582 F.2d 898 (5th Cir. 1978). The majority of jurisdictions, however, require clear and convincing evidence that the person committed the prior act. See, e.g., Unites States v. O'Brien, 618 F.2d 1234 (7th Cir. 1980); United States v. Fredrickson, 601 F.2d 1358 (8th Cir. 1979). But see, Huddleston v. United States, 485 U.S. 681 (1988) (evidence of similar acts should be admitted if there is sufficient evidence to support a finding by the jury that the defendant committed the similar act).
  15. FED. R. EVID. 403. See also, United States v. Beechum, 582 F.2d 898 (5th Cir. 1978); United States v. Jones, 913 F.2d 1552, 1566 (11th Cir. 1990) (probative value of evidence heightened by similarity).
  16. 408 S.E.2d 878, 882 (N.C. App. 1991).
  17. Id.
  18. See generally, Linda Jorgenson et al., Therapist-Patient Sexual Exploitation & Insurance Liability, 27 TORT & INS. L. J. 595 (1992).
  19. See, e.g., Linda M. Jorgenson & Pamela K. Sutherland, What's Sex Got To Do With It?, TRIAL, May 1992, at 22.
  20. In re Japanese Elec. Prods., 723 F.2d 238, 277 (3d Cir. 1983), cert. granted on other grounds, 471 U.S. 931 (1985), reversed and remanded sub nom., Matsushita Elec. Indu. Co. v. Zenith Radio Corp., 475 U.S. 574 (1986). See also, ARNOLD, FEDERAL RULE OF EVIDENCE 703: THE BACK DOOR IS WIDE OPEN 20 (1984); Dept. of Youth Services v. A Juvenile, 499 N.E.2d 812 (Mass. 1986) (court found that while expert could base opinion on facts not in evidence, the facts had to be admissible).
  21. Knightsbridge Mktg. Servs., Inc. v. Promociones Y Proyectos, 728 F.2d 572, 576 (1st Cir. 1984).
  22. See infra note 35 and accompanying text.
  23. See generally, Linda Jorgenson et al., Masters of Their Fate: Employer Liability in Sexual Misconduct Cases, ___ BROOKLYN L. REV. ___ (April, 1995). Evidence of the employer's knowledge of other victims may also show employer's ratification of the therapist's conduct.
  24. 520 N.E.2d 139, 142-43 (Mass. 1988). See also, Andrews v. United States, 732 F.2d 366 (4th Cir. 1984); Simmons v. United States, 805 F.2d 1363 (9th Cir. 1986); Evan F. v. Hughson United Methodist Church, 10 Cal. Rpt.2d 748 (1992).
  25. 18 U.S.C. § 1964 (1984). See generally, Stephen Rubino, Pedophilia: Organized Religion's Watergate, NAT'L TRIAL LAW, Apr. 1990, at 17.
  26. 756 F. Supp. 353, 357 (N.D. Ill. 1991).
  27. IMWINKELRIED, supra note 12, at §§ 7:15, 16, 17.
  28. See, e.g., Birchfield v. Texarkana Mem. Hosp., 747 S.W.2d 361 (Tex. 1987).
  29. MASS. GEN. L. ch. 231, § 85K (1987).
  30. Alison Bass, Law Limits Church Liability to $20,000, BOSTON GLOBE, May 13, 1992, at 8. See also, James L. Franklin, Diocese Offers Plan on Abuse, BOSTON GLOBE, October 3, 1992, at 13, 20.
  31. See generally, Linda Jorgenson & Rebecca M. Randles, Time Out: The Statute of Limitations & Fiduciary Theory in Psychotherapist Sexual Misconduct Cases, 44 OKLA. L. REV. 181 (1991).
  32. 565 N.E.2d 780 (Mass. 1991). See also, Geisz v. Greater Balt. Med. Ctr., 545 A.2d 659, 670-71 (Md. 1988).
  33. See, e.g., KENNETH S. POPE, SEXUAL INVOLVEMENT WITH THERAPISTS 108 (1994).
  34. See generally, 29 AM. JUR. 2D, EVIDENCE §§ 298, 361, 365 (1994). But see, Coopersmith v. Gold, Case No. 94-00616 (N.Y. Sup. Ct. - 2d Dept. 1994) (appeal of verdict for defendant in therapist sexual misconduct case in which defendant revealed ostomy scar to the jury which the plaintiff had been unable to identify; trial court excluded as "too prejudicial" the testimony of other victims as to defendant's idiosyncratic manner of having sexual intercourse while wearing clothes thus preventing the revelation of his scar to his patients).
  35. 85 Misc.2d 891, 381 N.Y.S.2d 587 (1976).
  36. IMWINKELRIED, supra note 12, at § 7:18. See also, LIACOS, supra note 8, at § 4.4.10 ("The general rule is that evidence of the experiment is admissible provided that the conditions are sufficiently similar to make the experiment of value in aiding the jury.").
  37. FED. R. EVID. 402.
  38. See generally, 1 MCCORMICK ON EVIDENCE 780 (John W. Strong ed., 4th ed. 1992).
  39. See, e.g., Greenberg v. McCabe, 453 F.Supp. 765 (E.D.Pa. 1978), aff'd, 595 F.2d 854 (3d Cir.), cert. denied, 444 U.S. 840 (1979); Horak v. Biris, 474 N.E.2d 13, 17 (Ill. App. 1985); Mazza v. Huffaker, 300 S.E. 2d 833, 837 (N.C.App. 1983).
  40. See generally, Tamar Frankel, Fiduciary Law, 71 CAL. L. REV. 795 (1983); A. SCOTT & W. FRATCHER, THE LAW OF TRUSTS §2.5 at 43 (once a plaintiff proves the existence of a fiduciary relationship, the burden shifts to the defendant/ fiduciary to show that he or she did not exercise undue influence over the plaintiff). See also, Barbara A. v. John G., 193 Cal.Rptr. 422, 432 (Cal.App. 1983); Ruebsman v. Maddocks, 340 A.2d 31, 36-37 (Maine 1975); McRae v. Watkins, 522 So.2d 731, 737 (Miss. 1988).
  41. See, e.g., Burns v. Mass. Inst. of Tech., 394 F.2d 416, 419 (1st Cir. 1968); Neel v. Magana, Olney, Levy, Cathcart & Gelfand, 491 P.2d 421, 429 (Cal. 1971); Plaquemines Parish Comm'n Council v. Delta Dev. Co., 502 So.2d 1034, 1039 (La. 1987); Willis v. Maverick, 760 S.W.2d 642, 645 (Tex. 1988).
  42. See generally, Jorgenson & Randles, supra note 30, at 219-22.
  43. AMERICAN PSYCHIATRIC ASS'N, THE PRINCIPLES OF MEDICAL ETHICS WITH ANNOTATIONS ESPECIALLY APPLICABLE TO PSYCHIATRY § 2.1 (1985).
  44. St. Paul Fire & Marine Ins. Co. v. Love, 459 N.W.2d 698, 701 (Minn. 1990).
  45. See supra notes 6 - 7 and accompanying text.
  46. See generally, J. SMITH, MEDICAL MALPRACTICE: PSYCHIATRIC CARE 5-8 (1986).
  47. See, e.g., Kenneth Pope & Valerie Vetter, Prior Therapist-Patient Sexual Involvement Among Patients Seen By Psychologists, 28 PSYCHOTHERAPY 429, 431 (1991) (leading survey of psychologists who had treated victims of sexual relations with prior therapists found only 4% of such allegations were, in the opinion of the subsequent therapist, untrue).
  48. "The most frequent defense asserted in [sexual misconduct cases brought by patients against therapists] is that the sexual contact never occurred." KENNETH S. POPE & JACQUELINE C. BOUHOUTSOS, SEXUAL INTIMACY BETWEEN THERAPISTS AND PATIENTS, 125 (1986). See also, JONAS ROBITSCHER, THE POWERS OF PSYCHIATRY, 427 (1980); (Dr. Hartogs, the defendant in a therapist-patient sexual misconduct suit, stated in his defense, "I never had sex with this person. Never! She does not know the difference between fantasy and reality. She will never know it." Roy v. Hartogs, 366 N.Y.S.2d 297 (1975), aff'd in part, 381 N.Y.S.2d 587 (1976)).
  49. See, e.g., BARBARA EHRENREICH & DIERDRE ENGLISH, FOR HER OWN GOOD (1978).


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