Spring

BACKGROUND

Administrative Hearing The evidence at the administrative hearing was as follows. Petitioner had provided marriage counseling to the family court parties (referred to herein as Mother and Father) for several years, for a total of 50 sessions.1 Mother and Father ultimately

1 Petitioner’s case notes from his sessions with Mother and Father were introduced as an exhibit at the administrative hearing. The parties dispute the admissibility of a transcribed version of these notes. We do not rely on this transcription and therefore need not decide its admissibility.

1 decided to divorce. After a mediator recommended that Father have 35 percent custody of the couple’s only child (Child), Father contacted petitioner. Petitioner wrote two declarations that Father’s counsel filed in the family court proceeding. The first declaration was filed June 3, 2011. It stated, in its entirety: “[Mother] and [Father] have been in couple’s therapy for a few years, and I have observed each of them many times as they interacted with their son [Child] in the waiting area of my office. [¶] Each of them has demonstrated great love and caring for [Child] and each of them has been very involved…