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Dr. Charlotte Murrow Taylor NCC; LPC; LPC/S; MAC; 165 Kiefer Court Cameron, SC 29030 (843)-270-3883 March 3, 2020 6:19cv00029 Leitner v. Liberty University, Pride, Sosin, Deacon, Moitinho, Shield Minis David Truluck and Melodie Truluck Preliminary Expert Witness Report Prior to writing this report, I, Dr. Charlotte Murrow Taylor; Distinguished Professor Emeritus; NCC; LPC; LPC/S; MAC; M.ED; B.S, reviewed multiple sources of information related to this case, I utilized expertise developed in my career as a counselor-education and supervisor at two CACREP accredited institutions, as well as on CACREP site visits, in my volunteer work as a counselor within the South Carolina Department of Corrections, as well as in research, scholarship and the like. I have had expert witness accepted by courts in South Carolina, Arkansas, California and Arizona. Complete statement of all opinions that will be rendered ‘The following is a preliminary statement of all opinions I will express, as per the terms of the pre-trial order, as well as the basis and reasons for them. First, I believe that Sarah has experienced the following diagnoses, which occurred due to the lack of empathy, action and inaction of Liberty University and its employees. These diagnoses underscore the extreme conditions Sarah endured at the Naval Brig Charleston. The additional other conditions which may be a cause of clinical care (previously V-Code conditions) underscore the additional significant stressors Sarah endured. 1. F43.10 Post Traumatic Stress Disorder, due to exposure to two traumatic events in which Sarah felt her life was in danger while at the brig, in November 2015 and February 2016. ‘A verbal threat by Dr. Pride in mid-February 2016, forcing her to return to an unsafe environment, e.g., the brig, caused additional trauma. ‘These traumatic events resulted in symptoms of intrusive, involuntary and recurrent distressing memories; persistent avoidance of stimuli such as the Naval brig in Charleston; negative alterations in mood including inability to recall important aspects of the trauma; excessive self-blame and shame; detachment from others; an inability to feel positive emotions; and alterations in reactivity/arousal including problems with concentration and sleep disturbance. This caused clinically significant impairment in all spheres of life including as a professional counselor, as a wife and mother, and as a researcher. This condition appeers Charleston - Walterboro - Orangeburg to have begun in late 2015 and continued through 2019. 2. Major Depressive Disorder, with anxious distress, due to symptoms of feeling keyed ‘up/tense and restless; diminished interest or pleasure; hypersomnia and insomnia; fatigue or loss of energy; and loss of ability to concentrate. This caused clinically significant impairment in all spheres of life including as a professional counselor, as a wife and ‘mother, and as a researcher. This condition began in 2015 and continued through 2019. 3. F411 Generalized anxiety disorder, due to symptoms of restlessness/keyed up/on edge, easily fatigued, difficulty concentrating, muscle tension and sleep disorder. This caused clinically significant impairment in all spheres of life including as a professional counselor, as a wife and mother, and as a researcher, nThis condition began in 2015 and continued through 2019. 4, 269.81 Encounter for mental health services for victim of non-spousal or non-partner adult abuse, due to abuse that occurred at the Naval Brig Charleston between November 2015 and February 2016. 5. 260.50 Target of Adverse Discrimination or persecution, due to discrimination by Defendant Liberty University and its employees between December 2015 and the present. 6. 265.4 Victim of Crime, due to actions taken at the brig between November 2015 and February 2016, due to actions taken by Defendant Liberty University and its employees from 2015 onwards, and due to a burglary at Sarah’s home in January or February 2017. 7. 263.8 High level of expressed emotion within family, due to family difficulties including between December 2015 and 2019, particularly between December 2015 and February 2016 and from September 2016 through June 2017. 8. 263.5 Disruption of family by separation, due to Sarah’s child’s high level of expressed emotion within family, from mid-2014 to December 2015, second, due to a Department of Social Services (DSS) investigation of Sarah Leitner’s husband between late September and November 2016 for which no causes for concern were found by DSS. 9. This comprehensive compilation of series of events, in the opinion of this therapist and examiner, qualifed Ms. Leitner for services outlined in the Americans with Disabilities Act. ‘The consequences Sarah underwent due to Liberty University and its employees actions and. inactions included the following: 1. When Liberty University refused to remove Sarah from an abusive situation and later repeatedly denied and minimized the harm that had occurred this amplified the trauma Sarah underwent. 2. Asis the case with any type of impairment, this is extremely difficult to communicate to others. This difficulty is multiplied when the impairment is caused by those in power and particularly when the situation (e.g., abuse) is ongoing or has recently occurred. Many ‘wait years to report abuse. Charleston - Walterboro - Orangeburg 3. Nevertheless, Sarah attempted to bring this to Liberty University’s attention on many occasions. Many of these attempts seem to have been blamed on a perceived lack of emotional regulation within Sarah instead of on the trauma Sarah underwent while taking a University sanctioned course. 4, Liberty University did not adhere to the standards required by the American Counseling Association, or ACA, 2014 ethics code’, the CACREP 2016 standards’, as well as its own internal standards, such as in the course syllabus and manual. Many different standards were violated by Liberty University throughout Sarah’s internship experience. These violations occurred while Sarah was in the internship site and during Sarah’s attempts to notify Defendant Liberty and its employees of the situation, both while she was at the internship site and afterwards. As regards Shield Ministries, the following is clear: 1. Shield Ministries, as well as David and Melodie Truluck, also do not appear to have shown ordinary care for Sarah Leitner or even for Shield Ministries’ clients or volunteers. Shield Ministries does not appear to follow norms within the non-profit arena as shown by its lack of a volunteer application and its lack of screening potential volunteers for criminal records. 2. Asa volunteer therapist within the South Carolina Department of Corrections system, I have had dealings with David Truluck. Asa result, I would never place a supervise at Shield Ministries or at any other non profit that placed a supervisee at Shield Ministries. If I had known of this arrangement, which occurred while I was undergoing chemotherapy, I would have called the University. Facts and/or Data underlying the case In addition to the above, the following is clear: 1. Sarah attempted to withdraw around November 20, 2016 due to extreme stress from the unwarranted social services investigation, her child’s resumption of extreme emotionality, and her discovery that her child had been abused at summer camp previously. This of course was on top of dealing with an Inspector General Investigation, trauma from the previous internship, and her job. This attempt to withdraw was rejected immediately by Dr. Deacon. 2. Previously Sarah had asked for an investigation by the Inspector General since the previous site was a government site. Dr. Warren had agreed to wait for the grade appeal until the investigation was complete. Dr. Sosin knew of this investigation as she had been contacted by the government investigator in mid or late November 2016. 3. While experiencing these many stressors, Sarah first notified Dr. Pride around November 22, 2016 that she would be starting counseling for Win4I ife at Shield Shield Ministries as Win4L.ife and Shield Ministries had a partnership. 2 Charleston - Walterboro - Orangeburg 4. Around November 29 or 30, 2016, Sarah mentioned in an email to the Acting Dean of Behavioral Sciences, Dr. Warren, that an incident of abuse had occurred while her child was at summer camp. The University attempted to notify DSS. Sarah was only notified of the call when Officer Brown of the Liberty University Police Department spoke to her. This occurred around December 2nd. 5. Immediately, Sarah’s advisor should have spoken to her, offering support, suggesting Sarah withdraw from the course, as well as offering other resources from the University. 6. After Dr. Pride’s reply to Sarah’s email of around November 22, around ten days later, Sarzh notified Dr. Pride and Dr, Deacon Friday, December 2", 2016, 6:05 AM, that she was counseling for Win4Life at Shield Ministries under the agreement. 7. Rather than answering Sarah’s email, Liberty University chose to send her a letter, emailed around December 5, 2017, with many inaccuracies, including that all of her grade appeals had been completed. Sarah’s attempt to clarify the concerns raised in the letter, via email, was met by Dr. Sosin’s email telling her to complete the internship. ‘This letter of concem was signed only as coming “Dr. Sosin and the Department of Counselor Education and Family Studies leadership”. At this point the Inspector General Investigation had not been completed. 8, After Sarah’s attempt to clarify concerns from the letter was refused by Dr. Sosin, Sarah believed that Liberty University had made it clear it was looking for any reason to expel her. ‘Thus she had very litle chance of passing the intemship. Based on my review of documentation, it appears this fear was well-founded and not based on any lack of self regulation. 9. Inlate February 2017, Dr. Deacon claimed to have found out that Sarah was at an unauthorized internship site. The emails of December 2016 described above make it clear that Sarah was at an authorized internship site with Liberty’s full knowledge and consent. 10. In my experience as a doctoral student many years ago attending a CACREP accredited doctoral program at the University of Memphis, teaching in two CACREP accredited programs, and as a counselor and supervisor I do not remember such an egregious display of behavior by faculty at a University. This behavior goes against the foundations of the Counseling profession, as captured by the Mission statement of the ACA 2014 ethics code: “The mission of the American Counseling Association is to enhance the quality of life in society by promoting the development of professional counselors, advancing the counseling profession, and using the profession and practice of counseling to promote respect for human dignity and diversity.” Qual ications I retired from Clemson University as Distinguished Professor Emeritus in 2001. I received the Doctor of Education in 1992 after receiving the Master of Education in 1976 and a Bachelor’s degree in 1969. 1 am a Past Secretary for the Association for Counselor Education and Supervision (ACES), who also gave me the Distinguished Professional Service Award in 1994. I Charleston - Walterboro - Orangeburg ama Past President of the South Carolina Counseling Association. I am presently a member of ‘The Citadel’s Counselor Education Community Advisory Board. Thave also served on various CACREP site visit teams. Past research from the 1990’s included a 1.7 million dollar project funded by a National Center for Substance Abuse Prevention Demonstration Grant for which I was the Principal Investigator from 1992-1994, In addition to work in the educational and academic arenas, I have worked as a private therapist, as a volunteer therapist in the South Carolina Department of Corrections, and as a school counselor in K-12 environments. A full Curriculum Vitae is attached. List of previous cases Thave been accepted as an expert witness in South Carolina, Arkansas, California, and Arizona, At present, I am semi-retired due to several chronic health conditions, including periodic chemotherapy. I have come out of retirement for this case due to its extreme importance. Compensation This report was produced pro bono. Conclusions Sarah Leitner is an incredibly dedicated, gifted, and intelligent clinician who has worked through hortific situations that occurred as part of her PhD internship. Simultaneously she ran a neuroscience laboratory, dealt with incredible difficulties at home, including her now 19 year old's struggle with self harm, gender dysphoria, anxiety, and depression due to underlying post traumatic stress disorder, and dealt with internship situations that caused her great harm. As adjunct faculty at the Citadel for 13 years and full time faculty at Clemson University for eight years, both of which are CACREP accredited, I have seldom seen a student overcome such great adversity. I believe Sarah has been able to overcome these adversities in part due to her great inner strength, resilience, emotional regulation and integrity. Please let me know of any additional questions or comments at any time. I am available via telephone at (843)-270-3883. Respectfully submitted, Dr. Charlotte Murrow Taylor, Distinguished Professor Emeritus; NCC; LPC; LPC/S; MA\ M.ED; BS. 165 Keifer Court Charleston - Walterboro - Orangeburg Cameron, SC, 29030 Attachments: full curriculum vitae; copy of initial letter sent to Dean of the School of Behavioral Sciences in Fall 2017. Charleston - Walterboro - Orangeburg Dr. Charlotte Murrow Taylor NCC; LPC; LPC/S; DAC 165 Keifer Court Cameron, SC 29030 Dr. Steven Emil Warren 843-270-3883 11 University Boulevai 1971 Us Boulevard Lmchburg, VA 24515 have experienced along term professional relationship with Ms. Leitner and request that vou kindly take note of the following: © Sarah Leiter's family has been seen by me since early 2013, when Ashley Lele, Sarah’s now 17 year old daughter first began acting ‘out upon her expressed emotional difficulties. Therapy has been, at times, intermittent due to cancer treatments and other health problems of mine; * While a referral for altemate therapeutic support was recommended for the family it was refused due to my on-going knowledge of the family history and our success asa therapeutic team. We continued therapy as I was able; Provide support and recommended treatment for an adolescent laughter who has struggled with self-harm, gender dysphoria, and anxiety and depression related to underlying Post Traumatic Stress Disorder. ‘Complicating matters, Ashley also struggles with ‘coramunication due to early hearing difficulties; © As family members have | ‘mobilized to ameliorate these aforementioned issues, they have also been faced with other “ienificant challenges, ie. multiple surgeries experienced by Mr. Leitner and neck and shoulder injuries experienced by Ashley. Hannah, The youngest daughter, has also ‘struggled with feelings of “invisibility” because parental attention has, of necessity, been focused on her older sister, © In my vocation of serving as adjunct faculty atthe Citadel for thirteen years and as a professor at Clemson University for eight (both CACREP accredited programs), I have seldom. experienced a Charlton. Woerbro- Orangeburg Collegially, student attempt to overcome such great adversity. Sarah has displayed incredible resilience, emotional regulation, and integrity. This resilience and emotional regulation will only enhance her abilities as a clinician; As a doctoral level student (years ago), attending a CACREP accredited doctoral program atthe University of Memphis, my major advisor and other professors brought the human dynamic tothe table, «assisted each graduate student in the development of additional skills with which to cope, and proceeded from there to instruction in a developmental, timely and exceedingly professional manner; Twas unaware of the agreement between WinLife and Shield Ministries when it was negotiated due to weekly chemotherapy. Due {0 an ongoing role as a volunteer therapist within the South Carolina Department Corrections system, I have had numerous dealings with Mr Truluck. Iam a licensed Supervisor and would never place a supervisee at Shield Ministries; Finally, while I am fully aware thatthe issues have become convoluted, clearly Ms. Vanessia Stokes at Win4Life placed Ms. ‘Leitner at Shield Ministries without the approval of Dr. Mary Deacon. Had no personal issues been on the table, Ms. Leitner still ‘would have not realized she was participating in an unauthorized intemship. She trusted that Ms. Stokes was intimately conversant with the requirements of Liberty University’s internship program. Readmitting Ms. Leimer will not only assist her, it will speak volumes to the quality of the professors and programs at Liberty University. Takia ey m0 Dr. Charlotte Murrow Taylor CHARLOTTE MURROW TAYLOR VITA 165 Kiefer Court Cameron, South Carolina 29030 843-270-3883 EDUCATION Fa. D. 1992 University of Memphis Major: Counseling M.Ed. 1976 The Citade! B.S. 1969 Jacksonville University ‘Major: Psychology, Education CERTIFICATION/LICENSURE Licensed Professional Counselor in South Carolina #499 Licensed Professional Counselor/Supervisor-S. C. #1523 Nationally Certified Counselor #5329 Teaching graduate courses in counseling 1995-2001 CHARLOTTE M. TAYLOR Private Practice © Charleston, Orangeburg, Walterboro, SC Individual, family and group therapy University of Memphis, Memphis, TN ‘Teaching “Crisis Counseling” and “Counseling Theories” ‘The Citadel, Charleston, SC Teaching graduate courses in counseling University of South Carolina, Columbia, SC Teaching graduate courses in counseling Di fc ing Servi Berkeley County, SC Distr of al pte shots in Berkeley County Berkeley County, SC Hanahan Middle School, Berkeley County, SC Providing counseling services for the students Classroom Teacher Berkeley County, SC Teaching science, reading, and social studies Professional ofthe Year, Cambridge Institute, 2010 Distinguished Professor Emeritus, Clemson University, 2001 Distinguished Professional Service Award, 1994 The Association for Counselor Education and Supervision Elected to “Leadership Berkeley, Class of 1991" 1989-Present 1990-1992 1984-1995 1984-1986 1981-1995 1978-1981 1972-1978 1971-1972 CHARLOTTE M. TAYLOR VITA Elected to the National Distinguished Service Registry for Counseling and Human Development, 1990 Outstanding Counseling Supervisor Award, 1990 Southem Association for Counselor Education and Supervision Outstanding Administrator Award, 1987 South Carolina Association for Counseling and Development Tribute to Women and Industry Award (TWIN), 1986 The YMCA of Greater Charleston, South Carolina South Carolina House of Representatives Letter of Commendation for Services, 1985 Humanitarian Award, 1984 South Carolina Association for Counseling and Development Outstanding Guidance Administrator of the Year, 1984 Department of Counseling Psychology, University of South Carolina Charles L. Wells Cup for Outstanding Service, 1969 Jacksonville University, Jacksonville, Florida PUBLICATIONS INSTRUCTIONAL MATERIALS Taylor, C. M. (Editor and consultant), (1995). School E Pr Guide. Berkeley County School District. Moncks Comer, S.C. Taylor, C. M. (Contributing author). Inte Association Publication. Taylor, C. M. (Editor). (1994). Dis mergency Procedures R Berkeley County Schoo! District. Moncks Comer, §. C. Taylor, C. M. (Reviewer). (1990). Discover Skills for Life, (grades 7 & 8 editions), Educational Assessment Publishing Company. San Diego, CA. Tavlos, C. M. (Writing Team member). (1988-89). Professional Development Guidelines Manual for Elementary Counselors: A Self Audit, Alexandria, VA: ASCA Publicat FAN fon. CHARLOTTE M. TAYLOR VITA Taylor, C.M. Funded by The Children’s Celebrate Life: A Suicide Prevention Curriculum. ‘Trust Fund of South Carolina and sponsored by The Tri-County Mental Health Association 1986. ‘Taylor, C. M. (Reviewer). (1986, Fall). Special Middle School Edition, The School Counselor, RESEARCH ARTICLES IN REFERRED JOURNALS Taylor, C. M., & Graves, L. C. (1998, Fall). Trainees endorse crisis response, recovery training. School Safety. 20-22, 30. Taylor, C. M., Foltz, B., Ellis, M. R., & Culbertson, K. A Multicultural Career Fair for Elementary School Students. Professional School Counseling, Article revised, and scheduled to be published February, 1999, Shannon, M. P., Lonigan, C. J., Finch, A. J., & Taylor, C. (1994). Children Exposed to Disaster: 1. Epidemiology of Post-Traumatic Symptoms and Symptom Profiles. L_Am. Acad. Child Adolesc, Psychiatry, 33: (1). Lonigan, C. J., Shannon, M. P., Finch, A. J., Daugherty, T. K., & Taylor, C. (1991). Children’s Reactions to a Natural Disaster: Symptom Severity and Degree of Exposure. Advances in Behavioral Research and Therapy. Shannon, M., Finch, A., Taylor, C., Imm, P., & Sallee, F. (1991). Psychometric Properties of a Soi Raperted Post-Traumatic Stress Measure in Children and Adolescents. Taylor, C. M. (1998). Safety Skill Training for Children. Elementary School Guidance and Counseling. 22 , (4), 314-317. RESEARCH ARTICLE IN NON-REFERRED JOURNALS ‘Taylor, C. M. (1997). Original Writings Promote Growth Within ADHD Adolescents. The Clemson Kappan. 14, (1), 11-14. Taylor, & M0198, Sorin). Counselors i tie Riceeatery School ‘South Carolina CHARLOTTE M. TAYLOR: VITA RESEARCH ACTIVITIES Research question: “Will School Counselors provide significantly more group counseling if they have received training specific to counseling in groups within the school setting?” Research regarding Gender Equity and Career Development, a grant funded through the SC State Department of Education. Conducted a Post Hurricane Hugo Anxiety Assessment of 7000 Children and Adolescents in Berkeley County in conjunction with the Medical University of South Carolina Institute of Psychiatry. Resulted in four articles and two national presentations. Conducted an Eating Disorders Assessment of Middle School Students in Berkeley County in conjunction with the Medical University of South Carolina. Resulted in a presentation and a survey instrument. Conducted a School-Based Demonstration Grant Research project for the National Center for Substance Abuse Prevention. Resulted in three national presentations and an additional curriculum elective for high school students in the target county. Conducted a Community-Based Demonstration Grant Research project for the U.S. Dept. of Education Office of Substance Abuse Prevention. Resulted in one national presentation and replication in several rural counties. Conducted research with 1013 high school students utilizing Prevention Curriculum and crnparng etd poste levels of ee oi Tecan ponaed ty Tae Chive Tras Fund of South Carolina and the Tri-County Meatal Health Association as well as replication in high schools around the state. GRANTS Taylor, C. M. (1998-99, Funded $5,000:) Gender Equity and Career Development. S. C. State Department of Education. Taylor, C. M. (1998, Funded $1,000:) Portable Ropes Training Experience. The Electric Cooperative of South Carolina. ‘Taylor, C. M. (1990-91, Funded $2,000:) Eating Disorders Assessment of Middle School ‘Students in Berkeley County. Research project conducted in conjunction with the Medical University of South Carolina. CHARLOTTE M. TAYLOR VITA Taylor, C.M. (1989-90, Funded $10,000:) Post Hurricane Hugo Anxiety Assessment of:7000 Children and Adolescents in Berkeley County. Research project conducted in conjunction with the Medical University of South Carolina Institute of Psychiatry. Taylor, C. M. (1992-94, Funded $1.7 Million) Principal Investigator. National Center for ‘Substance Abuse Prevention Demonstration Grant.”United, We Stand.” Taylor, C. M. (1990, Funded $184, 000:) Facilitator of U. S. Dept. of Education Community Based Grant for Substance Abuse Prevention. Taylor, C. M. (1988, Funded $30, 000:) Facilitator for U. S. Federal Government “Desert Storm” funds awarded for Berkeley County, SC. Taylor, C. M. (1987-present, Funded $228,000:) Facilitator of U. S. Dept. of Education Drug-Free-Schools Grant. ADVISING RESPONSIBILITIES Univers Graduate Student Advisement “Elementary and Secondary Schoo! Counseling, 1995 - present 84 students on 1-6 1999 -Anderson School District #1 Cohort Advisement & Program Coordination 20 students on 1-11-1999 Master Level Committees, 1995 - Retirement Faculty Advisor, Chi Sigma Iota counseling honors society. Chi Upsilon charter, Clemson University, S. C. 1995-1999. CHARLOTTE M. TAYLOR VITA INSTRUCTIONAL EXPERIENCE Q Universit Graduate Education ED C 801- Foundations of Elementary School Counseling ED C 802- Foundations of Secondary ‘School Counseling ED C810- Theories & Techniques of Counseling EDC 814- Development of Counseling Skills ED C 820- The School Counselor as Consultant ED C 823- Advanced Counseling Skills ED C 830- Elementary School Counseling Practicum I ED C 831- Elementary School Counseling Practicum IV Internship ED C832; Secondary Schoo! Counseling Practicum I ED C 833- Secondary School Counseling Practicum [Internship Graduate Education “Into to the Counseling Profession” “Group Practice in Schoo! Counseling” “Vocational Counseling”