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					MEMORANDUM

DATE:              July 19, 2004

TO:                Logan Hennessey

FROM:              Brian J. Schmidt

RE:                Social worker privilege in Florida, Arizona, and Texas



As we discussed, the following should be appended as new sections to the existing version of the Social
Worker Privilege Confidentiality Manual:



D.        Florida

Which classes of social workers are covered by the privilege?
         Florida also has a social worker privilege that is created by statute.1 In this case, it is not a
separate privilege, but is considered part of the psychotherapist-patient privilege. As a result, the focus
is on treatment of a mental health condition. Only a person ―licensed or certified as a clinical social
worker, marriage and family therapist, or mental health counselor under the laws‖ of Florida may claim
the privilege.2 All these titles require at the minimum a master’s degree. For a social worker, the
degree must emphasize ―direct clinical patient or client health care services.‖3 Furthermore, in order
for the privilege to apply, the social worker must be ―engaged primarily in the diagnosis or treatment of
a mental or emotional condition, including alcoholism and other drug addiction‖ 4 at the time the client
discloses confidential information. This focus on psychotherapy makes the privilege in F lorida much
narrower than in New York or New Jersey, both of which extend the privilege to social workers acting
outside of the clinical realm.

1
    Fla. Stat. Ann. § 90.503.
2
    Fla. Stat. Ann. § 90.503(1)(a)(3).
3
    Fla. Stat. Ann. § 491.005.
4
    Fla. Stat. Ann. § 90.503(1)(a)(3).
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DISCLAIM ER These materials are provided solely for informational purposes and are Not legal advice. Transmission of
these materials is not intended to create,and receipt does not constitute, an att orney client relationship. This
matter should not be pursued further without contacting an attorney or legal representative.
When is a communication between a social worker and a client privileged?
         The Florida statute protects both verbal communications between a patient and her
psychotherapist, as well as written records.5 Remember that the communications or records must be
made ―for the purpose of diagnosis or treatment of the patient’s mental or emotional condition‖ in order
for them to be protected by privilege. 6 This means that a casual conversation outside of the clinical
setting is not privileged.

        In order for a particular communication to be protected by the social worker privilege, the
client must intend for it to be confidential. This means that she must not intend for its contents to be
disclosed to third persons, except for:

              1. those persons present to further the interest of the patient in the consultation,
                 examination, or interview;
              2. those persons necessary for the transmission of the communication; or
              3. those persons who are participating in the diagnosis and treatment under the direction
                 of the social worker. 7

         While it is clear that a licensed clinical social worker must oversee the client’s treatment in
order for the privilege to apply, the third category suggests that under certain conditions, case managers
or other non-licensed social workers may also claim the privilege if they are working under the direct
supervision of a LCSW. However, this is only true if the services of these personnel are directly
related to the diagnosis and treatment of the client’s mental or emotional condition.

         Although there is no case law directly addressing the question of whether a lawyer could fall
under the first category above, such an argument is at least possible. Remember, though, that since the
Florida social worker privilege is actually part of the psychotherapist-patient privilege, its focus is on
communications made in the course of treating a mental condition. This essentially means that in order
for the client’s lawyer to be covered by it, she would have to be present during a psychotherapy
session—something the client may not be comfortable with. Furthermore, the privilege would only
apply if the purpose of the lawyer’s presence were to further her client’s legal interests. It may be hard
to imagine such a situation, and even harder to persuade a judge that this is the case. So in general, a
lawyer should only plan on attending a client’s psychotherapy session if she can legitimately claim that
she did so in order to advocate for her client in a legal capacity. Otherwise, a court may even interpret
her presence as an indication that the client did not intend for the communication to remain
confidential. This could have the entirely undesirable effect of destroying the privilege between the
client and the social worker! For these reasons, the attorney-client privilege will probably be better
suited to cover meetings where the client, her social worker, and her lawyer are all presen t.


What are the exceptions to the privilege?
      The same statute that creates the privilege declares that no privilege exists when the
communications in question are:

5
    Fla. Stat. Ann. §90.503(2).
6
    Id.
7
    Fla. Stat. Ann. § 90.503(1)(c). The third item in the statute actually concludes with ―under the
           direction of the psychotherapist.‖

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              1. relevant to an issue in proceedings to compel the patient’s hospitalization for mental
                 illness, if the psychotherapist believes the patient is in need of hospitalization;
              2. made in the course of a court-ordered examination of the mental or emotional
                 condition of the patient; or
              3. relevant to an issue of the patient’s mental condition, if the patient is relying on the
                 condition as part of her claim or defense.8

        In addition, a separate statute provides that a client may forfeit her right to the social worker
privilege under certain circumstances. This statute considers the privilege ―waived‖ when:

              1. the client brings a lawsuit against the psychotherapist;
              2. the client agrees in writing to waive her right to the privilege; or
              3. there is a ―clear and immediate probability of physical harm‖ to the client, other
                 individuals, or society, and the clinical social worker communicates the information
                 ―only to the potential victim, appropriate family member, or law enforcement or other
                 appropriate authorities.‖ 9


Can social workers be covered by the attorney-client privilege?

        As with the other states reviewed, Florida law is unclear as to whether the attorney-client
privilege is broken when a social worker attends a meeting between her client and the client’s attorney.
The Florida statute conferring the attorney-client privilege allows the client to prevent the disclosure of
the content of ―confidential communications,‖ which are defined as those which are ―not intended to be
disclosed to third persons,‖ except:

          1. those to whom disclosure furthers the provision of legal services; or
          2. those ―reasonably necessary‖ for transmitting the communication. 10

          It is already established that a ―spouse, parent, business associate or joint client‖ may fall under
the first exception. 11 It is not unreasonable to imagine that a social worker could fit the definition as
well. The key is that the social worker must be present in order to help the lawyer provide legal
services. Furthermore, the client must intend for all communications between the three to be kept
confidential.


The sexual assault counselor privilege
It should be noted that while the psychotherapist/patient privilege in Florida only extends to licensed
clinical social workers, marriage and family therapists, and mental health counselors, the state has a
separate privilege for sexual assault counselors. 12 In order to qualify, the sexual assault counselor must

8
    Fla Stat. Ann. § 90.503(4).
9
    Fla. Stat. Ann. § 490.0147.
10
     Fla. Stat. Ann. § 90.502
11
     Id., 1976 Law Revision Council note.
12
     Fla. Stat. Ann. § 90.5035

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work for a rape crisis center, which is defined as ―any public or private agency that offers assistance to
victims of sexual assault or sexual battery and their families.‖ Many organizations that assist
trafficking victims undoubtedly fit this definition. It is not necessary that the organization offer
assistance exclusively to sexual assault victims; the definition implies that the organization may provide
a broader range of services, as long as one of these is to assist sexual assault victims.

There are two classes of counselors who are covered by the privilege. The first, formally called a
―sexual assault counselor‖ by the statute creating the privilege, is defined as an ―employee of a rape
crisis center whose primary purpose is the rendering of advice, counseling, or assistance to victims of
sexual assault or sexual battery.‖ The second, added to the statute in 2002, is called a ―trained
volunteer.‖ This is defined as ―a person who volunteers at a rape crisis center, has completed 30 hours
of training in assisting victims of sexual violence and related topics provided by the rape crisis center,
is supervised by members of the staff of the rape crisis center, and is included on a list of volunteers
that is maintained by the rape crisis center.‖ These definitions greatly expand the number of social
workers who can claim a privilege in Florida, since no doubt many non-clinical social workers work
for an organization that could be described as a ―rape crisis center,‖ and offer assistance of the type
described above.

A victim of sexual assault has the right to prevent the disclosure of confidential communications, which
are defined in almost the same way as for the psychotherapist privilege. 13 Interestingly, the statute
covers any ―confidential communication made by the victim to a sexual assault counselor or trained
volunteer or any record made in the course of advising, counseling, or assisting the victim,‖ whereas
the psychotherapist privilege described above covers only ―conf idential communications or records
made for the purpose of diagnosis or treatment of the patient’s mental or emotional condition.‖ This
suggests that any statement the victim makes to the sexual assault counselor will be privileged, even if
it does not directly relate to treatment for sexual assault, as long as it is made in the course of the
victim’s professional relationship with the counselor.

The sexual assault counselor privilege will likely be affected by the presence of a lawyer in the same
way that the psychotherapist privilege is. Again, for a communication to be considered confidential,
the victim must not intend for it to be disclosed to third person except for the exceptions listed in the
rule. Just as with the psychotherapist privilege, these include ―those persons present to further the
interest of the victim in the consultation, examination, or interview.‖ While the same caveats discussed
above apply here as well, it is theoretically possible that a lawyer’s presence would not break the
privilege if the lawyer meets this description.

Similarly, the presence of a sexual assault counselor in a client’s meeting with her lawyer is also
affected the same way as when a clinical social worker is present. That is, the sexual assault counselor
must be present in order to help the lawyer provide legal services, and the client must intend that all
communications be kept confidential.




13
     The only difference is that the third part of the definition of ―confidential communications‖ (covering
          ―those persons who are participating in the diagnosis and treatment under the direction of the
          social worker‖) is replaced by the phrase, ―those persons to whom disclosure is reasonably
          necessary to accomplish the purposes for which the sexual assault counselor or the trained
          volunteer is consulted.‖

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E.        Texas

Which classes of social workers are covered by the privilege?
         Texas grants a privilege to mental health professionals by statute. 14 And like Florida, there is
no separate statute for social workers. Unlike Florida, however, the Texas Rule of Evidence that
creates the privilege does not actually specify that social workers are among the type of mental health
professionals covered. Instead, it simply states that the privilege applies to people ―licensed or certified
by the State of Texas in the diagnosis, evaluation or treatment of any mental or emotional disorder.‖

        Strangely, there is not a wide body of case law to help determine whether a Texas court will
apply the mental health professional privilege to social workers. In fact, there is apparently only one
case that does so. In it, the Court of Appeals for El Paso noted in passing that ―clinical social workers
have been specifically recognized as entitled to the same psychotherapist-patient privilege that is
afforded psychiatrists and psychologists . . . .‖ 15 This is a reference to the Jaffee case (decided by the
U.S. Supreme Court and discussed in the first section of this manual), not to a Texas rule. While the
court decision is certainly helpful, it is important to remember that it is not binding on other courts
outside of the El Paso jurisdiction, although a lawyer may certainly cite it in order to persuade a judge
to adopt the same position. Fortunately, although there may not be a definitive line of case law in
Texas affirming that a social worker may claim the mental health professional privilege, there appears
to be no case that decided a social worker cannot.

         In the absence of case law, further guidance may be found in the sections of Texas law that
regulate the social work profession. Notably, this law states that ―the practice of social work may
include the provision of individual, conjoint, family, and group psychotherapy using the Diagnostic and
Statistical Manual of Mental disorders, the International Classification of Diseases, and other
diagnostic classification systems in assessment, diagnosis, treatment, and other activities by a person
licensed under this chapter.‖16 This suggests that under certain circumstances, a social worker may
qualify for the privilege. But it does not mean that any social worker may claim the privilege in
connection with any of her functions.

         The social worker licensing law may provide an answer. It establishes three levels of licensed
social workers: A clinical social worker (LCSW), requiring a master’s degree and clinical
specialization; a master social worker (LMSW), which also requires a master’s degree; and a
baccalaureate social worker (LBSW), which requires a baccalaureate degree.17 According to the Texas
Administrative Code, only clinical social work involves ―the practice of providing evaluation,
diagnosis, and treatment to individuals, families, or groups with mental or emotional conditions or
disorders or who are adversely affected by social or psychosocial stress or health impairment.‖ 18 Given
how closely related the wording of this definition is to the language describing the scope of the mental
health professional privilege, it is a logical conclusion that only licensed clinical social workers may

14
     Tex. R. Evid. 510.
15
     Am. W. Airlines, Inc. v. Tope, 935 S.W.2d 908, 908 (Tex. App. El Paso 1996).
16
     Tex. Occupations Code Ann. § 505.0025.
17
     See Tex. Occupations Code Ann. § 505-353.
18
     22 Tex. Admin. Code § 781.102.
                                                     5
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claim the privilege. This makes the Texas law more similar to Florida’s than New York or New
Jersey’s in terms of the class of social workers covered.

         It is worth noting that the Texas privilege statute also applies to people who are ―involved in
the treatment or examination of drug users.‖ They do not have to be social workers to qualify.
Therefore, if a non-clinical social worker learns of certain information while treating a client for drug
use, any information learned during this process may be privileged.

         Finally, the privilege law also extends to people ―reasonably believed by the patient to be
included in any of the preceding categories.‖ This means that if it is reasonable for a patient to believe
that the person counseling her is licensed to diagnose, evaluate, and treat mental disorders, the privilege
may apply. Unfortunately, there is no published case law examining just what is meant by the phrase
―reasonable belief.‖ While it is assuredly better to make sure that only licensed clinical social workers
be involved in confidential communications, this provision of the statute should not be forgotten in the
event that a social worker not otherwise covered finds herself asked to disclosed information that the
client expected would be confidential.


When is a communication between a social worker and a client privileged?

         The Texas statute protects both verbal communication between a patient and a mental health
professional, and ―records of the identity, diagnosis, evaluation, or treatment of a patient which are
created or maintained by a professional.‖ 19 Remember that a verbal communication must be made in
the course of a consultation for the diagnosis, evaluation, or treatment of a mental or emotional
condition in order for it to be protected by privilege. 20 This means that a casual conversation outside of
the clinical setting is not privileged.

        In order for a particular communication to be protected by the social worker privilege, the
client must intend for it to be confidential. This means that she must not intend for its contents to be
disclosed to third persons, except for:

              1. those present to further the interest of the patient in the diagnosis, examination,
                 evaluation, or treatment;
              2. those reasonably necessary for the transmission of the communication; or
              3. those who are participating in the diagnosis, examination, evaluation, or treatment
                 under the direction of the professional, including members of the patient’s family.21

        While it is relatively clear that a licensed clinical social worker must oversee the client’s
treatment in order for the privilege to apply, the third category suggests that under certain conditions,
case managers or other non-licensed social workers may also claim the privilege if they are working
under the direct supervision of a LCSW. However, this is only true if the services of these personnel
are directly related to the diagnosis and treatment of the client’s mental or emotional condition.

        Although there is no case law directly addressing the question of whether a lawyer could fall
under the first category above, such an argument is at least possible. Remember, though, that since the

19
     Tex. R. Evid. 510(b)(2).
20
     See Gaynier v. Johnson, 673 S.W.2d 899, 903 (Tex. App. Dallas 1984).
21
     Tex. R. Evid. 510(a)(4).

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Texas social worker privilege is actually part of the ―mental health professional‖ privilege, its focus is
on communications made in the course of treating a mental condition. This essentially means that in
order for the client’s lawyer to be covered by it, she would have to be present during a psychotherapy
session—something the client may not be comfortable with. Furthermore, the privilege would only
apply if the purpose of the lawyer’s presence were to further her client’s legal interests. It may be hard
to imagine such a situation, and even harder to persuade a judge that this is the case. So in general, a
lawyer should only plan on attending a client’s psychotherapy session if she can legitimately claim that
she did so in order to advocate for her client in a legal capacity. Otherwise, a court may even interpret
her presence as an indication that the client did not intend for the communication to remain
confidential. This could have the entirely undesirable effect of destroying the privilege between the
client and the social worker! For these reasons, the attorney-client privilege will probably be better
suited to cover meetings where the client, her social worker, and her lawyer are all present.


What are the exceptions to the privilege?

          The Texas statute provides that a patient cannot claim the mental health professional privilege
when:

              1. the patient sues the mental health professional, such as for malpractice, and in license
                 revocation proceedings against the professional in which the patient is a complaining
                 witness;
              2. the patient or her representative waives her right to the privilege in writing;
              3. the proceeding is to collect from the patient unpaid fees for mental health services
                 rendered;
              4. the patient made the communications in the course of a court-ordered examination
                 relating to her mental health, and was informed prior to the examination that the
                 communications would not be privileged;
              5. the patient is relying on a mental condition as part of her claim or defense, and the
                 communication in question is relevant to that issue; or
              6. the proceeding regards the abuse of neglect of the resident of a state institution. 22


Can social workers be covered by the attorney-client privilege?
        As with the other states reviewed, Texas law is unclear as to whether the attorney-client
privilege is broken when a social worker attends a meeting between her client and the client’s attorney.
The Texas statute conferring the attorney-client privilege allows the client to prevent the disclosure of
the content of ―confidential communications.‖ Confidential communications are defined as those
which are ―not intended to be disclosed to third persons,‖ except:

              1. those to whom disclosure is made in furtherance of the rendition of professional legal
                 services to the client; or
              2. those ―reasonably necessary‖ for transmitting the communication. 23

       These communications are privileged when they are between the client and the lawyer, or
between the client’s representative and the lawyer. In this context, the client’s representative is defined

22
     Tex. R. Evid. 510(d).
23
     Tex. R. Evid. 503(a)(5).

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as someone who, ―while acting in the scope of employment for the client,‖ communicates with the
lawyer ―for the purpose of effectuating legal representation for the client.‖ Under certain
circumstances, a social worker could apparently fit this definition as well. However, it is crucial that
the social worker serve as the client’s representative, in the sense that her communication with the
lawyer—and her presence at a meeting between her client and the client’s lawyer—be for the express
purpose of helping the lawyer provide legal services.

        The key is that the social worker must be present in order to help the lawyer provide legal
services. Furthermore, the client must intend for all communications between the three to be kept
confidential.



F. Arizona

Which classes of social workers are covered by the privilege?

        Arizona grants a privilege to ―behavioral health professionals‖ by statute.24 And like Florida
and Texas, there is no separate statute for social workers. The Arizona statute grants the privilege to
―licensees,‖ a term which covers anyone licensed under the laws that regulate behavioral health
professionals.25 This means that the privilege extends not only to licensed social workers, but also to
licensed counselors, licensed marriage and family therapists, and licensed substance abuse
counselors.26

         Arizona has three classifications of licensed social workers, all of which seem to fall under the
protection of the behavioral health professional privilege: a licensed baccalaureate social worker, which
requires a baccalaureate degree in social work; a licensed master social worker, which requires at least
a master’s degree in social work; and a licensed clinical social worker, which requires at least a
master’s degree in social work and two years of post-degree supervised clinical experience. 27

         Interestingly, the only Arizona case that addresses the behavioral health professional privilege
suggests that even an unlicensed counselor would be bound by the privilege, as long as he makes
himself out to be a licensed counselor. 28 Therefore, in the event that a social worker working with a
trafficking victim learns that her client has inadvertently given confidential information to someone
who is not actually a licensed behavioral health professional, it may still be possible to claim the
privilege as long as the client reasonably believed that the person was a licensed counselor. Of course,


24
     Ariz. Rev. Stat. Ann. § 32-3283.
25
     See Ariz. Rev. Stat. Ann. § 32-3251(5) (defining ―licensee‖ as ―a person licensed pursuant to this
          chapter‖).
26
     All four of these classes of behavioral health professionals are regulated by Chapter 33 of Arizona’s
           Professions and Occupations Code.
27
     Ariz. Rev. Stat. Ann. §§ 32-3291–93.
28
     See Barnes v. Outlaw, 937 P.2d 323, 327-28 (Ariz. Ct. App. 1996), vacated in part on other grounds,
          964 P.2d 484 (Ariz. 1998).

                                                      8
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it is always better to play it safe and make sure that the client only divulges confidential information to
licensed social workers.


When is a communication between a social worker and a client privileged?
         Unfortunately, compared to the other states reviewed in this manual, the statute creating
Arizona’s behavioral health professional privilege is quite short and poorly written. Together with the
almost complete lack of case law on this privilege, there is very little guidance on exactly what
communications are protected. It may be that the rules of the behavioral health professional privilege
follow the same contours as those of the attorney-client privilege, but keep in mind that much of the
law in this area is undecided.

          The Arizona statute itself does provide some indication of what types of communications are
privileged. Specifically, it says that a behavioral health professional cannot be ―examined‖ in a legal
action about ―any communication made by the client to the [social worker] or as to any such
knowledge obtained with respect to personnel dealing with the client.‖ 29 This last part most likely
means that if a client reveals information to ―personnel‖ in the social worker’s office, and the recipient
of this information later tells the social worker, then the social worker cannot be forced to reveal the
information in court. The statute does not say anything about whether the personnel to whom the client
actually gives the information in the first place are protected by the privilege, but presumably they
would not be forced to reveal the information. At least, this would parallel the rule for the attorney-
client privilege,30 and would seem to be the only way to provide the client with any meaningful
protection. The statute also protects from disclosure ―information that the [social worker] received by
reason of the confidential nature of the [social worker’s] practice as a behavioral health professional.‖
This probably refers to information that the social worker obtains from sources other than her client.

         Although the statute does not explicitly say so, general principles of privilege law indicate that
the client must intend for a particular communication to be confidential in order for it to be protected. 31
This means that she must not intend for its contents to be disclosed to third persons. The presence of a
third person will generally indicate that a communication is not intended to be confidential, and
therefore is not privileged. Exceptions may be made for people who are present to help the behavioral
health professional perform her responsibilities to the patient.

        Under certain conditions a lawyer may wish to attend a client’s meeting with her social worker.
But the behavioral health professional privilege would probably only apply if the lawyer’s function
were similar to that of the other ―personnel‖ to whom the statute refers. That is to say, the lawyer
would have to be there to help the social worker care for the client’s behavioral health. It may be hard
to imagine such a situation, and even harder to persuade a judge that this is the case. So in general, a

29
     Ariz. Stat. Ann. § 32-3283(A).
30
     See Ariz. Stat. Ann. § 12-2234(A) (―An attorney’s paralegal, assistant, secretary, stenographer or
          clerk shall not, without the consent of his employer, be examined concerning any fact the
          knowledge of which was acquired in such capacity.‖).
31
     See, e.g., State v. Ortiz, 698 P.2d 1301, 1302-03 (Ariz. Ct. App. 1985) (―For information obtained by
           a psychologist to be privileged, it must have been acquired in an examination or consultation
           intended to be private and confidential.‖) (internal quotation marks and citation omitted). The
           psychologist privilege, Ariz. Stat. Ann. § 32-2085, is conferred by a different statute than that
           which confers the behavioral health professional privilege.

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lawyer should only plan on attending a client’s session with her social worker if she can legitimately
claim that she did so in order to assist the social worker in providing the client with behavioral health
services. Otherwise, a court may even interpret the lawyer’s presence as an indication that the client
did not intend for the communication to remain confidential. This could have the entirely undesirable
effect of destroying the privilege between the client and the social worker! For these reasons, the
attorney-client privilege will probably be better suited to cover meetings where the client, her social
worker, and her lawyer are all present.


What are the exceptions to the privilege?
       The Arizona behavioral health professional privilege does not extend to cases where the social
worker has:

              1. a duty to report nonaccidental injuries and physical neglect of minors;
              2. a duty to report unprofessional conduct by another behavioral health professional; or
              3. a duty to inform victims and appropriate authorities that a client’s condition indicates a
                 clear and imminent danger to the client or others. 32


Can social workers be covered by the attorney-client privilege?
        As with the other states reviewed, Arizona law is unclear as to whether the attorney-client
privilege is broken when a social worker attends a meeting between her client and the client’s attorney.
The Arizona statute conferring the attorney-client privilege allows the client to prevent the disclosure
of the content of confidential communications with her lawyer. It specifically extends the privilege to
―an attorney’s paralegal, assistant, secretary, stenographer or clerk.‖33 Some courts have further
extended the privilege to anyone assisting the lawyer in providing legal services.

         However, it is important to remember that the privilege only protects communications that the
client makes to her lawyer in order to obtain legal advice. The presence of someone unnecessary for
the purposes of the legal consultation will indicate that the client did not intend for the communication
to remain confidential, and the privilege will not protect the information that was exchanged. It is
crucial that a social worker who wishes to attend a meeting between her client and her client’s lawyer
be able to convincingly argue that her presence at the meeting is for the express purpose of helping the
lawyer provide legal services.

        The key is that the social worker must be present in order to help the lawyer provide legal
services. Furthermore, the client must intend for all communications between the three to be kept
confidential.




32
     Ariz. Stat. Ann. § 32-3283(A).
33
     Ariz. Stat. Ann. § 12-2234(A).

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