In recent years, several human rights legal centers, often working in conjunction with law school legal clinics, have pursued civil lawsuits against torturers and other abusers who can be found in the United States. Their clients are refugees, immigrants, and others with access to the U.S. court system. In addition, criminal prosecutions against individuals responsible for the commission of international crimes are increasingly proceeding in a network of international, hybrid, and national courts (including military commissons) around the world.
Lawyers and clinicians have discovered that plaintiffs and witnesses involved in such cases have a profound need for treatment support. Most crucially, victims and witnesses need medical and psychological services prior to filing suit and during the long process leading up to finally testifying and potentially facing responsible individuals in court. The experience of pursuing such litigation is greatly enhanced where victims and witnesses have access to these essential services.
In addition, lawyers, investigators, translators, and support staff working closely with victims of grave human rights abuses are also vulnerable to various forms of secondary, or vicarious, trauma that can impact their ability to be effective advocates for their clients in the legal process.
The Institute for Redress and Recovery at Santa Clara University (IRR or Institute) establishes a collaboration between the University and these lawyers and clinicians to provide support services both nationally and internationally.
About the Institute
In 1979, the New York based Center for Constitutional Rights filed the first civil lawsuit to recover damages on behalf of a Paraguayan family who had discovered that the police officer who had tortured their son to death in Paraguay was living openly in the U.S. Arguing that torture was an “international tort” within the purview of U.S. federal courts, these lawyers and plaintiffs brought and won a test case under the Alien Tort Statute (ATS)—a statute dating to the founding of our republic that allows civil suits by “aliens” for violations of certain established rules of international law. Since then, Congress entrenched a modern cause of action in the 1992 Torture Victim Protection Act (TVPA). The TVPA extends the right to sue to U.S. citizens tortured abroad and to the representatives of victims of summary execution. In Sosa v. Alvarez Machain, the U.S. Supreme Court confirmed the jurisprudential validity of these suits, echoing the conclusions of the majority of lower courts that had heard such cases.
In 1998, Gerald Gray—a clinician and social worker dedicated to working with survivors of human rights abuses—founded the Center for Justice & Accountability (CJA) in San Francisco to specialize in ATS and TVPA cases. To date, CJA has successfully sued perpetrators on behalf of plaintiffs from a number of countries, including El Salvador, Bosnia-Herzegovina, Haiti, Chile, Peru, Somalia, East Timor, and Honduras. In addition to CJA, several U.S. legal centers and law school clinics are devoted to this work with plaintiffs and witnesses in the U.S. and abroad. Canadian and European legal centers—such as the Canadian Center for International Justice, Redress Trust (the United Kingdom), the European Center for Constitutional and Human Rights (Germany), and the Fédération Internationale des Ligues des Droits de l’Homme (France)—do similar work under different statutory schemes. None of these centers, however, has had the expertise or resources to establish the treatment support systems that all have recognized are necessary for their clients and witnesses as they pursue litigation. Instead, such organizations provide such assistance on an ad hoc contract basis where possible.
CJA, for example, has over 30 plaintiff clients nationally, but no dedicated funding or staff for psychological support or social work. In its very first case, Bosnian plaintiffs and witnesses living in relative isolation in Utah were not initially assessed or provided service for the severe medical and psychological damage they had experienced. In the two-year pre-trial period, their symptoms were exacerbated by the stress and uncertainty of litigation. More than one client considered dropping out of the case, and one client lost his job. The Bosnian claimants ultimately won their case, but not without physical and psychological costs. Clinicians in the torture treatment centers working with clients in political asylum proceedings have confirmed that these reactions and problems can be mitigated with social work, psychotherapy, group therapy, psychiatric medication, and proper medical referrals.
The Institute’s Activities
The Institute brings together clinical treatment resources and legal resources in cases involving the commission of grave international crimes. These cases proceed in a number of fora, including international and hybrid tribunals, domestic courts, and U.S. military commissions. IRR works on behalf of civil plaintiffs and parties civiles (victims who have constituted themselves as civil parties in the context of penal proceedings), as well as on behalf of defendants (as before the U.S. military commissions).
To provide psychological services, the Institute works closely with the Palo Alto clinical non-profit, The Institute for Study of Psychosocial Trauma (ISPT), which has 25 years of experience in the field. ISPT principals have generated seminal clinical literature on trauma and legal processes. They have provided direct psychotherapy to torture victims in addition to providing expert testimony in court and participating in clinical training, supervision, consultation, and program management with others in this field. For the past five years, ISPT has subcontracted aspects of these services to The Center for Survivors of Torture in San Jose (where Gerald Gray served as program director).
The Institute has also formed a network of clinicians with experience working with torture survivors and established a number of agreements with the relevant legal centers in order to provide support for plaintiffs and witnesses. In particular, IRR is a part of the California Consortium of Torture Treatment Centers and works with other organizations that are members of the national counterpart—the National Consortium of Torture Treatment Programs. IRR also collaborates with treatment centers and universities worldwide to train other health professionals for the work.
Santa Clara As Host
Santa Clara University as a Jesuit institution has made programmatic commitments to examine social justice and globalization issues in all areas of the University curriculum. It is uniquely suited to host this organization. The Institute finds its home in the School of Law and the School of Education, Counseling Psychology, and Pastoral Ministries Program.
The School of Law has a close relationship with CJA. Professor Beth Van Schaack is on the organization’s Legal Advisory Board and many law students intern with CJA during the year and over the summer. Professor Van Schaack, who served as staff attorney and acting Executive Director of CJA, litigated Romagoza v. Garcia, a human rights suit involving Salvadoran refugees which resulted in a $54.6 million jury verdict. Santa Clara University School of Law features a certificate program in international and comparative law, social justice, and human rights through its Center for Global Law & Policy and Center for Social Justice & Public Service. In addition to regular coursework in human rights, clinical representation, immigration, and international law, Santa Clara has hosted a workshop on transitional justice featuring academics and activists working in Iraq, Sierra Leone, Cambodia, Chile, and Bosnia-Herzegovina. The workshop produced a series of faculty, guest, and student papers, some of which were published by the School of Law’s Journal of International and Comparative Law.
The Institute’s joint sponsor, the School of Education, Counseling Psychology, and Pastoral Ministries, is committed to fostering human compassion and social conscience.
Working through its host institutions, the Institute enables Santa Clara students and faculty to develop and apply their skills to communities in particular need of their services.
Santa Clara University School of Law
The School of Education, Counseling Psychology and Pastoral Ministries
Department of Psychology
Markkula Center for Applied Ethics/Global Leadership & Ethics
Nieves Molina Clemente (European Contact)
Kenneth Kitch (Communications Director)
United Nations and NGO Instruments and Documents
Basic Principles and Guidelines on the Right to a Remedy and Reparation for Victims of Gross Violations of International Human Rights Law and Serious Violations of International Humanitarian Law, C.H.R. res. 2005/35, U.N. Doc. E/CN.4/2005/ L.10/Add.11 (19 April 2005).
Declaration of Basic Principles of Justice for Victims of Crime and Abuse of Power, Adopted by General Assembly resolution 40/34 of 29 November 1985.
Academic Literature: Law
Greenwood, Arin, Ripple Effects: Education and Self-Care Can Help Lawyers Avoid Internalizing Client Trauma, ABA Journal 20 (January 2006).
Levin, Andrew P., Vicarious Trauma in Attorneys, 24 Pace L. Rev. 245 (Fall 2003).
Lutz, Ellen, & Kathryn Sikkink, The Justice Cascade: The Evolution and Impact of Foreign Human Rights Trials in Latin America, 2 Chi. J. Int’l L. 1 (2001).
Parker, Lynette, Increasing Law Students’ Effectiveness When Representing Traumatized Clients: A Case Study of the Katharine & George Alexander Community Law Center, 21 Georgetown Immigration Law Review 163 (2007).
Shelton, Dinah L. & Thoris Ingadottir, The International Criminal Court: Reparations to Victims of Crimes (Article 75 of the Rome Statute) and the Trust Fund (Article 79) (1999) (prepared for the Center on International Cooperation at New York University).
Van Schaack, Beth, With All Deliberate Speed: Civil Human Rights Litigation As a Tool for Social Change, 57 Vanderbilt Law Review 2305 (2005).
Van Schaack, Beth, In Defense of Civil Redress: The Enforcement of Human Rights Through Civil Litigation in the Context of the Proposed Hague Judgments Convention, 42 Harv. Int’l L. J. 143 (2001).
Academic Literature: Psychology
Herman, Judith, Trauma and Recovery (Basic Books, 1997).
Plante, Thomas et al., Coping With Stress Among Salvadoran Immigrants, 17 Hispanic Journal of Behavioral Sciences 471 (1995).
Plante, Thomas et al., Stress and Coping Among Displaced Bosnian Refugees: An Exploratory Study, 9 International Journal of Stress Management 31 (January 2002).
Academic Literature: Secondary Stress & Trauma
Fischman, Yael, Interacting With Trauma: Clinicians’ Responses to Treating Psychological Aftereffects of Political Repression, 61(2) American Journal of Orthopsychiatry (April 1991).
Greenwood, Arin, Ripple Effects: Education and Self-Care Can Help Lawyers Avoid Internalizing Client Trauma, 91 A.B.A. J. 20 (2006).
Holmgren, Helle, et al., Stress and Coping in Traumatized Interpreters: A Pilot Study of Refugee Interpreters Working for a Humanitarian Organization, 1(3) Intervention 22-27 (2003).
Hudnall Stamm, B., ed., Secondary Traumatic Stress, Self Care Issues for Clinicians, Researchers and Educators (Sidran Press, 1995).
Sagy, Tehila, Even Heroes Need To Talk: Psycho-Legal Soft Spots in the Field of Asylum Lawyering, London Law Review (2007).
Silver, Marjorie A. et al., Lawyering and Its Discontents: Reclaiming Meaning in the Practice of Law: Stress, Burnout, Vicarious Trauma, and Other Emotional Realities in the Lawyer Client Relationship, 19 Touro L. Rev. 847 (2004).
I. International Initiatives
In collaboration with the staff of the International Rehabilitation Council for Torture Victims in Denmark, IRR founder Jerry Gray is helping to develop a psychological treatment program for the war crimes tribunals based in The Hague, the Netherlands. The proposed programs will provide counseling support for the Tribunals’ victims and witnesses units. In particular, these programs will train counselors in the unique psychological and physical sequelae of victims of human rights violations and teach various coping strategies for victims testifying in war crimes trials. The program will rely in part upon local therapists and the municipal health system to provide these services alongside Tribunal staff. In this regard, the Institute is working with Centrum 45, a Dutch torture treatment center.
In addition to improving services to victims and witnesses involved in the Tribunals’ prosecutions, the program will also address the Tribunals’ “frontline” staff who are in direct contact with victims, such as interpreters, lawyers, clerks, social workers, etc. In several sessions, Institute trainers have taught tribunal staff trauma management skills to help them respond to the psychological impact of working with victims of grave human rights violations. The Institute is in discussions to extend this work into various sub-units of the Tribunals.
The Institute has also secured training grants for individuals from the Documentation Center of Cambodia (DC-Cam) to be in residence at the Torture Treatment Center of Oregon under the direction of Dr. David Kinzie. The training will enhance DC-Cam’s Victims of Torture Project, which is providing psychological support to victims of the Khmer Rouge in preparation for the commencement of trials before the Extraordinary Chambers in the Courts of Cambodia. In 2007, the Institute hosted two individuals from DC-Cam for a study tour and series of site visits in the United States with organizations dedicated to providing legal and psychosocial services to victims of trauma. In 2008 and early 2009, the Institute sent several U.S. psychologists and psychiatrists to Phnom Penh to help with the Victims of Torture project and explore the possibility of creating a national mental health system.
International Institution Building
IRR founder Jerry Gray worked with lawyers, activists, and psychologists to launch the Canadian Center for International Justice (CCIJ), which is affiliated with the Canadian Center for Victims of Torture. CCIJ recently received a major grant from the Law Foundation of Ontario to undertake legal education with (1) immigrant and refugee communities to explain basic legal remedies and available support services and (2) legal professionals about remedies in international, regional and Canadian tribunals. The grant also funds legal research into the extent to which Ontario civil law could provide remedies analogous to the ATS and TVPA in the United States. Prof. Van Schaack is on CCIJ’s Legal Advisory Board, and Gray is on the Board of Directors.
II. Domestic Initiatives
IRR worked with lawyers at the Center for Justice and Accountability and therapists with the Institute for the Study of Psychosocial Trauma (ISPT) to develop a pilot program for pro bono lawyers pursuing human rights cases under the Alien Tort Statute and the Torture Victim Protection Act. The program assists with the provisions of clinical and social work support for ongoing cases through such institutions as Survivors International, a San Francisco-based torture treatment center. In addition, this program trains lawyers in techniques to minimize the potential that their clients are re-traumatized by the litigation process. Once the litigation reaches the trial phase, the program ensures that victims and witnesses have adequate support persons with them as they deliver their testimony and undergo cross-examination.
IRR has also worked to link members of our network with the appropriate security clearances to lawyers representing individuals detained on Guantanamo and appearing before the U.S. military commissions to provide psychological consultations and expert testimony.
IRR regularly contributes to ongoing litigation efforts where the right of victims to seek redress for human rights abuses is at issue.
• IRR joined a brief filed in Matar v. Dichter on appeal to the Second Circuit Court of Appeals. A similar brief was filed in the Yousef v. Samantar case involving Somali torture victims. The briefs argue that the lower courts’ interpretation of the Foreign Sovereign Immunity Act essentially vitiated the TVPA by allowing individual state actors to invoke sovereign immunity as a defense to claims of torture under the TVPA. The appeals court recently reinstated the Samatar case, agreeing with the position taken in the brief.
• IRR co-director Beth Van Schaack drafted “friend of the court” (amicus) brief on the treatment to be accorded to detainees in the Al-Odah v. United States and Boumediene v. Bush cases pending before the U.S. Supreme Court. The brief outlines the obligations of signatories to the four Geneva Conventions of 1949 and their Protocols to refrain from subjecting individuals detained in armed conflict to all forms of torture, cruel or inhumane treatment, punitive detention conditions, or harsh interrogation tactics. The brief was filed on behalf of a number of experts in international humanitarian law.
• Professor Van Schaack also submitted an amicus brief to the Second Circuit Court of Appeals urging that court to review and reverse a ruling of the district court that had denied class certification to a class of Sudanese plaintiffs alleging that they were the victims of a campaign of crimes against humanity and war crimes committed by the Government of Sudan in conjunction with defendant Talisman Energy, Inc. The brief took the position that unless class certification was allowed, thousands of victims would be effectively denied redress because justice in the Sudan is impossible.
• Professor Van Schaack also contributed to another amicus brief on the question of mental torture in the case of Angel Enrique Villeda Aldana, et al., v. Fresh Del Monte Produce. Adopting the reasoning set forth in that brief, the 11th Circuit held that the intentional infliction of mental pain, even without physical suffering, may constitute torture under the international and domestic definitions of that offense.
Research and Teaching
IRR is developing an anti-impunity curriculum for the undergraduate and graduate level (see bibliography). It is also supporting ongoing research in this area.
Principals from ISPT with support from the IRR Advisory Board member Lynette Parker developed and implemented a course entitled “Trauma, Vicarious Trauma, and Legal Representation of Trauma Victims” for Santa Clara Law School. The course taught law students how to better understand, and thus more effectively advocate on behalf of, clients who have been victims of trauma and who need to testify at trial or prepare written declarations. The course identified the types of trauma suffered by victims of domestic violence, trafficking in persons, political persecution, and torture. It then provided ways for law students to recognize signs of trauma in their clients and various techniques for working with traumatized clients. The course also provided information on how the students can avoid secondary or vicarious trauma, along with the accompanying reduction in effective representation and/or professional burnout. This course was offered through the Katherine and George Alexander Community Law Clinic and complemented clinical skills training (civil and criminal), as well as courses in human rights, immigration, criminal law, and family law. The course is featured as a case study in a recent article by Prof. Parker: Parker, Lynette, Increasing Law Students’ Effectiveness When Representing Traumatized Clients: A Case Study of the Katharine & George Alexander Community Law Center, 21 Georgetown Immigration Law Review 163 (2007).
IRR principals regularly give guest lectures on these topics at local law schools, including Stanford Law School and Boalt Hall School of Law. Prof. Van Schaack regularly blogs (here) on issues of accountability for human rights abuses, international criminal law, and the rights of victims and witnesses.
Outreach & Community Involvement
The Institute has co-sponsored a number of events dealing with issues of transitional justice and accountability. For example, Santa Clara hosted an advanced workshop on transitional justice for educators convened by the
The Institute also co-sponsored an interdisciplinary conference organized by the American Friends Service Committee on the topic of Facing State Violence: Truth, Justice and Healing. The Conference was attended by educators, human rights advocates, journalists, legal advocates, therapists, trauma counselors, and concerned members of the public.
Jerry Gray and Beth Van Schaack facilitated sessions at both events. Professor Van Schaack also spoke about the importance of legal accountability at a public forum on justice, peace and reconciliation hosted by the Cambodian-American Community of Oregon in connection with the commencement of trials of surviving members of the Khmer Rouge in Phnom Penh, Cambodia.
Secondary Trauma and the Legal Process: A Primer & Literature Review
For many years, it was known that therapists and other mental health providers who work with victims of human rights abuses are affected in multiple ways by their clients’ stories of torture and persecution. Increasingly, it is becoming clear that all professionals who work with trauma victims—including lawyers, judges, court staff, and interpreters—can suffer from forms of secondary trauma and other psychological conditions that may negatively affect in their relationship to the injured person and their ability to perform the functions associated with their position.
Secondary Trauma & Related Conditions
The phenomenon of secondary trauma encapsulates several discrete conditions. Secondary traumatic stress is one form of secondary trauma experienced by professionals working with victims of trauma. Secondary traumatic stress can cause symptoms similar to the symptoms of Post Traumatic Stress Disorder (PTSD), which may include: feelings of fear, hopelessness, horror, anger, and rage; sleep disturbances; changes in memory; difficulty concentrating; and estrangement and detachment from others and from daily life. Thoughts about a client’s experiences may begin to intrude on a professional’s daily life. Professionals may also have nightmares about their clients’ experiences or avoid things that remind them of those experiences. People who work with victims of trauma may feel alternatively numb or experience hyper-arousal—a feeling of being in danger at any moment. Another form of secondary trauma is vicarious traumatization. People working with victims of trauma may internalize their client’s trauma, which can change their perception of the world and their ability to trust others.
Secondary trauma can interfere with professionals’ relationships with their clients, to the detriment of the client. For example, some attorneys working with victims of trauma respond to their clients’ stories by distancing themselves emotionally from their clients. This can damage the attorney-client relationship and the client’s ability to trust the attorney, who may appear insensitive to the client’s stories of torture or abuse. Secondary trauma can affect a professional’s ability to make decisions and can lead to inhibited listening.
Secondary trauma can also render it difficult to maintain appropriate boundaries. Attorneys working with victims of trauma often experience difficulty defining their role in relation to their clients. For example, when interviewed for a study on secondary trauma in the legal profession, attorneys working with victims of domestic violence stated that they often became overextended with their clients by helping them with problems other than domestic violence issues. Attorneys doing asylum work have reported that they have difficulty knowing how to respond to their clients’ stories of torture and persecution. A number of asylum attorneys have stated that they did not know how to strike a balance between being professional and offering basic sympathy.
In addition to secondary trauma, many people working with victims of trauma may begin to feel “burnout.” Burnout is often caused by stress and loss of idealism. Professionals experiencing burnout may suffer from headaches, depression, fatigue, and trouble sleeping. They may also have a negative perception of themselves and their work. Burnout may lead to aggression, irritability, substance abuse, and poor job performance.
Secondary Trauma in Lawyers & the Legal System
In Vicarious Trauma in Attorneys—the first study conducted on secondary trauma in the legal profession—Andrew P. Levin, MD, and Scott Greisberg, MA, surveyed attorneys working in family law, domestic violence, and legal aid criminal defense as well as mental health providers and social service providers working with the mentally ill. Levin and Greisberg found that attorneys had higher rates of secondary trauma than the other professionals surveyed. Levin and Greisberg attributed this discrepancy partially to the higher case loads taken on by the attorneys and partially to the lack of training given to the attorneys on how to work with traumatized clients. In Even Heroes Need to Talk: Psycho-Legal Soft Spots in the Field of Asylum Lawyering, Tehila Sagy identified the lack of emotional support given to attorneys working with traumatized clients as a major factor causing secondary trauma and burnout. Many attorneys are trained to separate their emotions from their work. Attorneys often work in environments in which becoming emotional about a case is equated with being unprofessional. This means that many attorneys are left to work through their responses to their client’s experiences without support from their colleagues.
In Stress and Coping in Traumatized Interpreters: A Pilot Study of Refugee Interpreters Working for a Humanitarian Organization Helle Holmgren et al. identified secondary trauma in Kosovo-Albanian interpreters working with victims of trauma through the Danish Red Cross. Most of the interpreters had fled Serbian persecution in Kosovo. The secondary trauma experienced by the interpreters was intensified, because their client’s stories often caused them to worry about family members still in Kosovo or reminded them of their own traumatic experiences. This situation was compounded by the fact that the interpreters were given very little recognition and respect for their work at the Danish Red Cross.
Individuals studying secondary trauma agree that it is important that professionals working with victims of trauma recognize and acknowledge the existence of symptoms associated with secondary trauma. In addition, they should be trained in methods for coping with traumatized clients and their own reactions thereto. For example, Holmgren et al. suggest that interpreters be given supervision by a psychologist experienced in psychotraumatology, so that they can better understand their clients and their own reactions to trauma. Sagy suggests that training attorneys in how to work with victims of trauma and establishing support systems in which attorneys can talk about their emotions in response to their work would help minimize secondary trauma and burnout. Sagy writes that organizations working with traumatized clients need to set up institutionalized support systems for their workers to help minimize secondary trauma and burnout. Organizations such as the United Nations, the International Criminal Court, and Human Rights Watch all provide their employees with support groups and self-help manuals to enable them to deal with their responses to their work. Sagy writes that this legitimization of secondary trauma helps ensure that individuals recognize the symptoms of secondary trauma and that they need not deal with their feelings alone.
The Institute for the Study of Psychosocial Trauma (ISPT) provides psychological services to survivors of war, torture, and repression. In addition ISPT provides training on secondary trauma to primary responders, clinicians, and members of the legal profession, including interpreters. In trainings for professionals and students working with victims of trauma, ISPT approaches the use of self care or treatment for secondary trauma as an issue of ethical responsibility.
ISPT’s educational model on secondary trauma is focused on the personal motivations that lead professionals to work with traumatized clients and the connection of those motivations to “purpose, meaning, world view, and the spiritual dimensions of trauma.” ISPT aims to encourage a “mentality of prevention” through lectures, group work, and small “process sessions” on the impact that secondary trauma can have on professionals. They also teach techniques for self care. Because a history of primary trauma can make professionals more vulnerable to secondary trauma, ISPT also provides an opportunity for professionals to discuss their own past traumatic experiences. In A Clinical Perspective: Secondary Trauma in the Legal Professions, an article to be published July/August 2008, ISPT discusses secondary trauma and gives a step-by-step description of the subjects discussed in their trainings.
Secondary Trauma Training at Santa Clara University School of Law
ISPT collaborated with Professor Lynnette Parker, a board member of the Institute for Redress and Recovery, to create a training program for law students representing victims of trauma at the Katherine and George Alexander Community Law Center (KGALC) at Santa Clara University. The class on trauma and the law offered by KGALC teaches law students techniques for effectively representing victims of trauma, and also gives law students information about secondary trauma and self care. KGALC teaches seven main skills to enable law students to effectively represent traumatized clients:
(1) techniques for interviewing clients and preparing cases with minimal retraumatization of clients,
(2) methods for working with emotional clients,
(3) ways to keep a client focused who is avoiding talking about a traumatic experience,
(4) techniques to help clients remember the details of traumatic events,
(5) strategies for working with clients who miss appointments or show up late,
(6) ways to build trust, and
(7) methods for defining the role of the legal advocate.
These skills help students deal with a number of the problems experienced by lawyers working with traumatized clients, from difficulty interacting with emotional clients, to difficulties defining their role in their client’s lives.
Secondary trauma is a problem prevalent among people working with victims of trauma, but it is a problem that receives very little recognition. Training in techniques for working with victims of trauma, coupled with information about secondary trauma and self care, can help professionals avoid and treat secondary trauma and burnout. When professionals receive training and support, they are more equipped to help the victims of trauma with whom they work.
 Institute for the Study of Psychosocial Trauma, A Clinical Perspective: Secondary Trauma in the Legal Professions (forthcoming July/August 2008) (hereinafter “ISPT”).
 Tehila Sagy, Even Heroes Need to Talk: Psycho-Legal Soft Spots in the Field of Asylum Lawyering 21, no. 71 (The Berkeley Electronic Press, Espresso Preparing Series Paper No. 1014, 2006) available at http://law.bepress.com/expresso/eps/1014/.
 Andrew P. Levin & Scott Greisberg, Vicarious Trauma in Attorneys, 24 Pace L. Rev. 245, 246 (2003)
 Sagy, supra, at 49.
 ISPT, supra.
 Levin & Greisberg, supra at 251.
 Sagy, supra, at43.
 Levin & Greisberg, supra at 250.
Id. at 251.
 Helle Holmgren et al., Stress and Coping in Traumatized Interpreters: A Pilot Study of Refugee Interpreters Working for a Humanitarian Organization, 1(3) Intervention 22-27 (2003).
 Sagy, supra,at 57-65.
 Id. at 61-65.
 ISPT, supra.
 Lynette Parker, Increasing Law Student’s Effectiveness When Representing Traumatized Clients: A Case Study of the Katherine and George Alexander Community Law Center, 21 Georgetown Immigration Law Review 163, 182 (2007).