Parental Alienation is a term used to describe the behavior of a parent and often other family members who manipulate a child's mind with the motive of severing all ties between the child and the other parent. The agenda is packed with various tactics and actions are pre-meditated. When the pressure on the child to remain loyal to the alienating parent becomes too intense, the child gives up, and total rejection of the other parent becomes reality.

1. Honorable Judge Judges Name
Name of Court House
Address
City, State, Zip Code
To The Honorable Judge Judges Name:
Attached you will find an eleven (11) page notarized copy of my Amicus Brief
documenting that it is child abuse for a parent/guardian to alienate a child from a fit
parent and to engage in behaviors that interfere with and/or fail to encourage the
relationship between a fit parent and child. This situation requires court intervention----
just as it intervenes in a child protective case to impose remedy. Should the court wish to
contact me for clarification or confirmation, my office phone number is (631) 673-6665,
and I would be more than happy to articulate telephonically or through Skype, under
Oath, any and all points Your Honor would require of me.
I make an explicit point that I have not evaluated the parents/guardians or the
child in the case for the purpose of this Brief, nor do I favor one party over another. I
offer my professional opinions given my history of four decades of professional work
experience and examinations in the area of high conflict divorce, and I trust my
statements will carry weight in Your Honorable Court in consideration that a child is at
risk for emotional, behavioral, and cognitive disabilities when a fit parent is eradicated
from her/his life. Finally, I declare that I was neither compensated nor otherwise received
any financial compensation or other benefits for writing this Brief.
Respectfully signed on letterhead, notarized and submitted for the case of Plaintiff's
Name vs. Defendant's Name
____________________________
Linda J. Gottlieb, LMFT, LCSW-R
Licensed Marriage Family/Relationships Therapist, Speaker and Published Author
Member of American Association for Marriage and Family Therapy (AAMFT)
Linda Gottlieb, LMFT, LCSW, r 8 Folger Lane
www.Lindagottlieb.com Dix Hills, NY 11746
ljgottlieb@verizon.net (631) 673-6665 Office
(631) 967-1616 Fax

2. COVER PAGE
IN THE COURT OF COMMON PLEAS OF NAME OF COUNTY COUNTY, STATE
CIVIL ACTION LAW – FAMILY LAW
_________________________________________________________
:
NAME Last Name : Docket No. Docket No.
Plaintiff, : IN DIVORCE
Vs. :
:
NAME Last Name :
Defendant. : Docket No. Docket No.
: IN CUSTODY
AMICUS BRIEF DOCUMENTING THAT ALIENATION IS CHILD ABUSE
Honorable Judge Judges Name
Name of Court House County Court House
Address
City, State, Zip
Report of Linda Gottlieb, LMFT, LCSW-R
Total Number of Pages: 11
To The Honorable Judge Judges Name:
My name is Linda J. Gottlieb, LMFT, LCSW-R, and I am writing this Amicus
Brief letter in support of documenting for the court that to engage in behaviors that
interfere with and/or fail to support the relationship between a child and a fit parent is
emotional child abuse. (The words “interfering” and “alienating” will be used
interchangeably in this brief because the outcome of such behaviors is the destruction or
minimization of the child’s relationship with a parent.) My judgment herein that such
alienating/interfering behaviors is child abuse assumes that there is no child protective
supervision of the targeted/alienated parent or that such parent has not been assessed to
be socially deviant or mentally impaired to the degree that parenting or any childrearing
activity will be compromised.

3. I have taken the position that alienating behavior leads to child abuse based upon
my forty-three (43) years of professional experience working with families and children,
my initial twenty-four (24) years as a social worker and then as an administrator in New
York's foster care system, and subsequently for nineteen (19) years as a family therapist
currently in private practice, specifically focused on parents and children of high-conflict
divorce. In my professional career, I have worked with several thousands of children
who had been placed in foster care and, in my private practice as a family therapist, with
more than 500 children who have experienced their parents’ high-conflict separation or
divorce.
Based on my extensive experience and expertise with these populations, I have
arrived at the conclusion that the eradication of a fit parent from a child’s life is child
abuse because it minimizes the child’s likelihood of obtaining optimal development and
functioning and because the child is unlikely to escape serious mental health and
behavioral symptoms in the coming months and years. This conclusion has been
validated by extensive research which be listed shortly in this brief.
To begin with, I quote here the professional opinions of my mental health
colleagues, matrimonial attorneys, and attorneys for the child whom I had interviewed for
my book, published in April of 2012, The Parental Alienation Syndrome: A Family
Therapy and Collaborative Systems Approach to Amelioration.
Raymond Havlicek, Ph.D., is one of these esteemed experts. He is a forensic and
clinical psychologist who is a Diplomat of the American Board of Professional
Psychology and a Fellow at the American Academy of Clinical Psychology. He is a
founding member of the Parent Coordinator Association of New York. Dr. Havlicek has
completed hundreds of child custody evaluations for County and Supreme Family Courts.
He is currently developing an educational program for upstate New York judges
concerning issues of child custody and parental alienation. Dr. Havlicek asserted, “The
trust that children place in both parents is to their mental health what the foundation is to

4. a building. If you undermine that trust, there is no stability.” Dr. Havlicek declares,
"There is no question that alienating/interfering behaviors is a form of child abuse.
It is a horror show. The damage to children is enormous. When a child loses a
parent, they are killing off a part of themselves because there is an identity between
the child and both parents. The result is that they become self-injurious. I see all the
warning signs and all the red flags of this self-hatred: nightmares, anxiety,
oppositional behaviors in school, presence of gastrointestinal syndromes, falling
school grades, more susceptibility to peers with oppositional behaviors, juvenile
delinquency, substance abuse, depression.”
Amy Baker holds a Ph.D. in Developmental Psychology with a specialization in
Early Social and Emotional Development. She is the Director of Research at the Vincent
J. Fontana Center for Child Protection at the New York Foundling. In her well-researched
book, Adult Children of Parental Alienation Syndrome, Baker (2007) concluded that
alienation is a form of emotional child abuse due to the devastating effects to children
when a parent is eradicated or abridged from their lives. These devastating effects include
but are not limited to 1) Damage to the child's self-esteem resulting from the pain of
being "enlightened" that the targeted parent does not love and has rejected
her/him; 2) Feeling bad about herself/himself resulting from the introjected
negative view of a parent, with whom a child instinctively identifies; 3) Being
ignored by the alienating/interfering parent for association with the targeted
parent; 4) Terrorizing the child, who is criticized and/or punished by the
alienating/interfering for expressing normal feelings and opinions; 5) Corruption of
the child whereby the alienating/interfering parent tolerates extreme acting out

5. behaviors in exchange for the child's allegiance and also because the child's
maltreatment of the targeted parent is normalized; 6) Exploiting the child's
dependency as a captive audience of the alienating/interfering parent, who chooses
to expose the child to adult information that exceed the child's cognitive and
emotional capabilities to handle; 7) Formation of shame and guilt resulting from the
child's inability to fulfill the alienating/interfering parent's expectation as her/his
problem solver; 8) Subjecting the child to the fear of abandonment as a punishment
for the child's desire for contact with the targeted parent (pp. 84-99). Baker (2007)
summarized her findings as follows: 65% of the study's participants were afflicted
with low self-esteem; 70% suffered episodes of depression due to the belief of being
unloved by the targeted parent and from extended separation from that parent;
35% engaged in substance abuse as a means to mask their feelings of pain and loss;
40% lacked trust in themselves as well as in meaningful relationships because the
trust was broken with their parents; 50% suffered the heartbreaking repetition of
the alienation by becoming alienated from their own children; and 57.5% were
beset by divorce, higher than the national average of 52%. (pp. 180-191)
Barbara Burkhard, Ph.D., co-founded Child and Family Psychological Services,
P.C., in Smithtown, New York, with Jane Albertson-Kelly, Ph.D. This agency provides
research-informed therapy for children and families. It has a contract with Suffolk
County Department of Social Services to provide therapeutic child/parent visits and
evaluations of parents who have been accused of abuse and neglect. They also receive
referrals from Suffolk County Supreme and Family Courts for custody evaluations,
therapeutic visitation, reunification therapy, and forensic mental health evaluations and
risk assessments. Both Dr. Burkhard and Dr. Kelly affirmed, “Children generally benefit
from a relationship with each parent with respect to the attainment of healthy long-term

6. relationships and for their optimal social, psychological, and cognitive development.” Dr.
Burkhard addressed how children who were initially assessed by her to be “high
functioning” became “highly disturbed” as a result of the process of alienation or
parental interference. Dr. Burkhard compares alienated children to a group of
traumatized children who have been raped, burned, beaten, sexually abused, and/or
victims of crime, and she concluded that the latter group “don't hold a candle in
terms of symptoms and prognosis to alienated children, who have dropped out of
school, become addicted to drugs, born children out of wedlock addicted to drugs,
and engaged in other antisocial behaviors.” Dr. Burkhard maintains that childhood is
a time to develop a sense of responsibility. It is a time to develop a conscience.
Children who become alienated have this fundamental aspect of their
development derailed. They are not only not held accountable for their mistakes
and misdeeds, they may be encouraged to tell lies or exaggerate the truth and
otherwise act in ways that are disrespectful of others. The maladaptive behaviors of
these children are reinforced by a trusted parent, and this further undermines
normal moral development as well as the development of the child’s ability to
develop healthy relationships. According to Dr. Burkhard, to engage in
alienating/interfering behaviors, “is maltreatment of children in the most profound
way."
Dr. Kelly asserted that children who become victims of alienation or parental
interference suffer lifetime damage. She expressed, "They do not learn
interpersonal problem solving because they are often prevented from working out
realistic everyday conflicts with a parent. This is simply not healthy in the long run.
This affects them in a very negative way. Having permission from a parent to
maltreat the other parent is going to have a very deleterious effect on the child’s
ability to interact with others.” Dr. Kelly is also concerned about the serious damage
to children resulting from false sex abuse allegations, which are a frequently
employed alienating maneuver. She stated, "It confirms damage to the child as if the

7. abuse really happened." She further commented, “Alienation undermines healthy
family functioning, such as family hierarchy in that the boundaries between the
parental and child subsystems breakdown when the child is elevated by the
alienating parent to an adult level as a result of their coalition. This explains why
such children often do not respond appropriately to authority figures such a school
principals, teachers, and others.” According to Dr. Kelly, “Another lifelong penalty is
that alienated children often pay a dear price resulting from the guilt that they bear
for having abused their targeted parent. And should the targeted parent no longer
be available to them when they come to the realization of what has occurred in their
family, there is no possibility for atonement.”
Matrimonial attorney, Robert Hiltzik, stated that he believes that
alienating/interfering behavior is a form of child abuse, and he described what he
has witnessed in his 22 years of family law practice: “The alienating parent is not
enforcing discipline. The crucial dynamic is that the alienating parent strives to be
the child's best friend while the other parent is left with the responsibility of being
the disciplinarian. The children then run amok, and the alienating parent is
sanctioning this because they are saying to their child, 'I won't enforce the rules as
long as you do what I say and give your other parent a hard time.’ I think the
damage is pervasive. If you allow a child to conduct himself/herself in such a
conflicted way, the child carries that throughout life. If the child can be so
disrespectful to a parent without any justification whatsoever, then there is no
doubt the child will exhibit similar conduct before other authority figures.”

8. Matrimonial attorney, Mr. Robert Previto, graphically described what he has
encountered in his 17 years of practice as a marital attorney as to the damage done
to children resulting from alienating/interfering behaviors when he stated, "If a
child is walking the across the train tracks, gets an electrical shock from the third
rail but is not killed, the scars will be there for the rest of his life. The emotional
scars resulting from an alienation are not going away either." Mr. Previto described
some of these injuries to children as having to live with tremendous guilt for having
allowed themselves to be manipulated into being so abusive to a parent.
Matrimonial attorney and Attorney for the Child, Susan Saltz, stated that
alienation is a form of child abuse because "alienated children do not form healthy
relationships as adults. And very often as adults, they don't have healthy
relationships with their own children." Ms. Saltz added, "It's not healthy for these
children not to see the non-custodial parent. I think children need to know where
they come from, and if they are missing a parent, they are missing a part of
themselves. If they miss out on one of their parents, there is a hole inside of them.
And they don't fill that hole with good stuff. These children tend to hate themselves
as a result of hating a parent. And when you hate yourself, you are likely to act out."
Matrimonial attorney, Joshua Hecht, believes that the negative effects to
children of alienating or interfering behaviors are "impactful and severe."
Attorney for the Child, Evie Zarkadas, asserts that she has witnessed during
her 20 years of practice severe detrimental affects to children as a result of
alienating/interfering behaviors. She stated that these difficulties run the gamut
from problems in education, difficulties in peer relationships, illegal substance use,

9. engaging in criminal activities, development of mental health disturbances. Ms.
Zarkadas expressed, "These children are being asked to deal with adult situations
that even adults don't know how to handle. The child will walk away with the idea,
‘What did I do wrong?’ These kids walk away from these messes feeling that they
are to blame." Ms. Zarkadas insists that the alienating behavior “be criminalized”
because “the pain these children suffer because of the decision by one parent to
erase the other parent out of their life----is criminal!"
Matrimonial attorney, Dorothy Courten, stands with the others that
alienating/interfering behavior is a form of child abuse. She described what she
sees happening to these children: “In terms of showing disrespect for authority, it is
absolutely there. You get really mixed up little kids out of it. Because these kids lack
control over what is happening to them by finding themselves in an upside down
world----a world in which they are manipulated into believing that love is hate; that
disrespect, defiance and maltreatment are acceptable; that their feelings must be
denied----I do not see a good outcome for them. They become self-destructive. They
attempt to take back control by adopting behaviors over which they do have control,
such as bedwetting, drug use, eating disorders, drinking, and stealing. They become
violent people.”
In his article, “Father? What father? Parental Alienation and its Effect on
Children," appearing in the Law Guardian Reporter, Chaim Steinberger, Esq., (2006)
painstakingly summarizes the literature which addresses the detrimental effects on
children from the loss of a relationship with a parent. These effects include but are
not limited to anxiety, self-loathing, rigidity, hopelessness, powerlessness,
confusion, withdrawal, isolation, and hypocrisy.

10. All the recent research indicates that children who have a parent either eradicated
from their lives or only marginally involved develop very poor outcomes. And I suggest
referring to the book, Fatherneed, by child psychiatrist, Dr. Kyle Pruitt, in which he
summarizes the alarming research by Yale University when a father is only minimally
involved in his children's lives or was completely eradicated from his children's lives.
Dr. Pruitt conveys that when fathers are absent or are involved only on a limited basis,
children have a significantly high vulnerability to acting out behaviors, dropping out of
school, suicidal ideation and other serious mental disorders, engaging in sexually
inappropriate activities, and other serious issues. Other research indicates the following
alarming statistics to children resulting from father-deprivation: 72% of all teenage
murders, 60% of rapists, 70% of kids incarcerated, twice as likely to quit school, 11 times
more likely to be violent, 3 out of 4 suicides, 80% of adolescents in psychiatric hospitals,
90% of runaways. The conclusion is that “Father-deprivation is a more reliable predictor
of criminal activity than race, environment or poverty.” (National Fatherhood Initiative,
US Bureau of Census, FBI)
I am unequivocal that the same findings would apply to the eradication or
minimization of a mother from a child’s life. We are already beginning to develop this
research about mothers now that more fathers are receiving residential custody.
The child of a high-conflict divorce is like a rope in a tug-of-war between her/his
parents. And just like the rope, the child will also unravel. It is a double-bind situation in
which the child cannot have both parents because of the pressure to align with one parent
against the other. Usually, but not always, the residential parent has the greater influence
due to opportunity and due to the child’s utter dependence upon that parent. This
detrimental family dynamic in which the child must chose between her/his parents had
been first observed by the child psychiatrists who later founded the family therapy
movement; they documented it on the psychiatric ward when observing their psychotic
child patients during family visits. This dysfunctional family dynamic, labeled by child
psychiatrist, Murray Bowen as the “pathological triangle,” was adapted by Bowen’s
peers, and they include but are not limited to Don Jackson, Nathan Ackerman, and
Salvador Minuchin, my mentor.

11. I have witnessed in my practice the detrimental effects to children as a result of
the triangulation or alienating/interfering behavior. And due to the influences that
technology has now afforded the younger population, I am seeing socio-pathology in
addition to psychosis in this population. I deem this family dynamic to be severe child
abuse in that the targeted parent’s love and nurturing is labeled for the child as
maltreatment and rejection; deceit and cruelty are normalized; there is a fostering
of a dependency upon a manipulative parent; there is a suppression of the child’s
superego, or conscience; there is a self-alienation resulting from the repression
one’s true feelings; there is a chronic state of anxiety that a slip of behavior will
expose the true positive feelings and longing for the alienated parent; there is the
loss of self as a result of the rejection of the alienated parent; there is a malaise or
depression that overtakes the child due to the loss of one of only two of the most
significant figures in the child’s life; there is an undermining of the child’s cognitive,
moral, and emotional development.
I am enclosing with this Amicus Brief my Professional Resume/Curriculum Vitae
(CV). Please feel free to contact me with any questions.
Respectfully signed, notarized and submitted for the case of Plaintiff's Name vs.
Defendant's Name.
____________________________
Linda J. Gottlieb, LMFT, LCSW-R
Licensed Marriage Family/Relationships Therapist, Speaker and Published Author
Member of American Association for Marriage and Family Therapy (AAMFT)
website: www.LindaGottlieb.com e-mail: ljgottlieb@verizon.net
Office/Practice Location: 8 Folger Lane, Dix Hills, NY 11746
(631)673-6665 Phone (631)967-1616 Fax
Amicus Brief, Number of Pages: 11