Unit 5: Overview of the Legal System in Domestic Violence Cases

Describe the criminal and civil legal systems as they pertain to domestic violence

Explain how various aspects of the legal system can be used to assist survivors of domestic violence

Explain the content and process of obtaining restraining orders in Massachusetts (209A)

Describe the special circumstances and resources for immigrant survivors of domestic violence

Describe the mandated reporting requirements for situations of domestic violence that involve a child, an adult with a disability, or an elderly individual

Describe confidentiality and privacy laws when working with domestic violence survivors

Relief available from restraining orders

The court can order any or all of the following, based on what the plaintiff requests:

• Stay away from you and your children

• Stay away from your residence, place of work, school, child's school or day care (you must specifically request these places)

• Stop threatening or hurting you

• Stop contacting you (directly or through third parties/electronic means)

• Move out of the house (if you lived together) and not return (and not interfere with your right to live there except by proper legal means)

• Pick up his/her personal belongings with a police escort

• Pay temporary support for you (if married) and your child

• Pay for any losses you suffered as a direct result of the abuse, such as:

  • Lost wages

    • Medical bills

  • Broken locks

  • Changing locks

  • Personal property

• Surrender any and all firearms and firearm identification cards to the police

• Return all house keys and family car keys to you

• Not spend money in a bank account, unless that money is necessary for him/her to survive

• Attend a batterer's intervention program (this is more likely to happen in a criminal case than in the restraining order hearing)

• Not abuse, threaten, take, interfere with, hide, harm or get rid of any animal owned or kept by you, the person using abusive behaviors, or a child living in your household

The abuse prevention order can also:

• Protect ("impound") your address if you moved to escape abuse so the person using abusive behaviors does not find out where you are

• Award you temporary custody of your children (but see "Note" below)

• Give you possession, care and control of any domesticated animal owned or kept by you, the abusive partner or a child living in your household

• Other reasonable requests that the judge believes are necessary in order for you to be free from the violence

Note: If there is already a custody or child support order established (or pending) from the probate/family court, the judge can still include an order for custody or support in your abuse prevention order as long as it is for a period of time that does not exceed 30 days. A judge in the probate/family court can always change the terms of custody or support later, however, and that judge will have the final say in the matter. If the parties have never been to family court, but later have a case in that court and receive custody/visitation/support orders, those will supersede the district court restraining order regarding the children, and the family court judge can modify the restraining order to make it consistent with those family court orders.

Harassment Prevention Orders

Massachusetts has an anti-harassment law, MGL 258E, which may be relevant to some people in situations of interpersonal violence. This law was specifically drafted to provide a criminally-enforceable protection order for sexual assault and stalking survivors who do not have the substantive relationships with the person using abusive behaviors required for 209A orders.

Harassment is defined to include:

“Three or more acts of willful and malicious conduct, aimed at a specific person, committed with the intent to cause fear, intimidation, abuse or damage to property and that does in fact cause fear, intimidation, abuse or damage to property; An act that by force, threat or duress causes another to involuntarily engage in sexual relations.”

Because of the complexity of 258E and the serious nature of the acts that are required for a survivor to be eligible, it is a good idea to contact a lawyer or legal advocate prior to going to court and filling out any paperwork. A useful Massachusetts resource is the Victim Rights Law Center, which provides civil legal services to survivors of sexual assault.

Additional resources:

• 258E Fact Sheet

• Differences between 209A and 258E

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Chapter 4: Refugee and Immigrant Survivors and the Legal System

Massachusetts Department of Public Health Refugee and Immigrant Safety and Empowerment program funds 19 community-based services for women victims of violence from varied cultures. Their web site is on the list at: http://www.mass.gov/dph/violence.

A short YouTube video, Domestic Violence Among Refugee and Immigrant Women, illustrates some of the issues.

Issues Specific to Immigrant Survivors

Survivors who are immigrants often have additional concerns. Language may be a major barrier to accessing help. It may be more difficult to find appropriate services. Survivors may be more isolated because they do not have family or friends here or because they live in a tight-knit community and do not feel they can ask for help.

If a survivor is undocumented, meaning she or he is not in this country legally, it is critical that the risk of deportation be considered. Some abusive partners will retaliate against their victims who are undocumented by reporting them to immigration. This is a common threat used by the abusive partner that is extremely powerful. A survivor may also be reluctant to take legal action against an undocumented partner, for fear that he or she may be deported. Connecting survivors with culturally and linguistically appropriate services is important. The Massachusetts Department of Health and Human Services Refugee and Immigration Safety and Empowerment program has a list of culturally-responsive resources for survivors on their website.

Relief available to immigrant survivors

Under the Violence Against Women Act, some undocumented immigrants are eligible to apply for legal status, independent of their abusive partner, or for other sorts of relief. This is a very complicated and constantly changing system, and there are many nuances as to whether or not a survivor may be eligible for this relief (e.g., based on their abuse partner's immigration status, how the survivor entered the U.S., whether the survivor has a criminal record, etc.). It is important that an undocumented survivor seek consultation with an attorney that specializes in immigration and domestic violence. Some legal service offices are able to provide such expertise free of charge to those survivors who qualify (Greater Boston Legal Services, Inc. Phone: 617-371-1270 x1667).

Regardless of immigration status, an immigrant survivor of domestic violence is eligible for police intervention and to apply for a restraining order in Massachusetts. In the past, the legal system typically would not report a survivor's immigration status to Immigration and Naturalization Services (INS). Reporting practices, however, can vary by location and circumstance. Furthermore, if the abusive partner is also undocumented, that person may be reported to INS as a consequence of criminal charges being filed against them, which could jeopardize the survivor's safety and wellbeing. Again it is recommended that you consult with your local DV program and/or legal counsel before encouraging the survivor to take any steps unless there is an imminent risk of harm.

An immigrant survivor is also eligible in Massachusetts for domestic violence programs, including the 24-hour emergency hotlines, shelter, and counseling services, regardless of their legal status. However, with recent changes in legislation, undocumented immigrants may not be eligible for the support services necessary to remain separated from their abusive partner, such as welfare and Section 8.

Some government agencies may be required to ask clients about their immigration status and report undocumented people to INS. You should caution the survivor never to answer questions about their immigration status, unless they are sure of the purpose for the question. You should consider calling agencies on behalf of the survivor and researching whether or not immigration status is relevant to accessing help before referring her or him to the agency.

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Chapter 5: Mandated Reporting in Massachusetts

This section provides an overview of mandated reporting as it relates to domestic violence situations that involve a child, an adult with a disability, or an elderly individual. Please keep in mind that this overview is specific to Massachusetts.

Filing a mandated report is often a very difficult decision. It always requires thought and care before action, and this is particularly true for domestic violence cases, as it can increase danger to survivors and their children. It is important not to make that decision alone, but to seek the consultation and support of your supervisor or other consultant.

• Social workers are required by law to report abuse of a child by a caretaking adult (Mass General Law Chapter 119A, Section 51A), abuse of an elder (Mass General Law Chapter 19A), and abuse of a person with a disability (Mass General Law Chapter 19C). Social workers who fail to report such incidents are subject to fines and possible loss of licensure.

• In Massachusetts, there is no requirement to report incidents of domestic violence toward non-elderly, non-disabled adults.

Reporting child abuse/neglect in domestic violence situations (known as "51A")

• Not every situation involving domestic violence merits intervention by the Department of Children and Families (DCF). There is no requirement to report incidents of a child witnessing domestic violence to DCF, and witnessing domestic violence is NOT considered, in itself, a reportable condition.

• Mandated reporters are encouraged to carefully review each family's situation and to identify any specific impact on the child/children when considering whether or not to file a 51A child abuse/neglect report with DCF.

• The Massachusetts Department of Children and Families has issued guidelines for responding to children in situations of domestic violence, which are summarized below. For additional information, the brochure explaining the guidelines and the DCF Mandated Reporters Guide are included in the resource and referrals section (Unit 6).

• The Department of Children and Families has a Domestic Violence Unit, which works in consultation with Area and Regional DCF offices on cases involving domestic violence and child welfare. Fore more information, the DCF Domestic Violence Unit can be contacted at 617-748-2000.

Factors to consider when assessing whether or not it is necessary to file a 51A:

• According to DCF, "A report is more likely necessary if the following higher risk circumstances are current concerns:

  • The alleged perpetrator intentionally or unintentionally abused or injured the child(ren)

  • The alleged perpetrator threatened to kill the caretaker/survivor, children, and/or self, and the caretaker fears for their safety

  • The alleged perpetrator used a weapon, made threats to use a weapon, and the caretaker believes that the perpetrator intended or has the ability to cause harm."

• In addition to the above high threshold circumstances, other circumstances to consider include if there has been a long history of domestic violence, the child's behavior has changed dramatically, or the child is having nightmares and sleeping difficulties. In these situations, consider calling DCF to get feedback on whether or not to file.

• The alleged perpetrator coerced the child to participate in or witness the abuse of the caretaker.

Legal requirements for filing a 51A

• If you are a mandated reporter, the report must be filed verbally within 24 hours of learning of the harm or neglect being done to the child to the DCF office that covers the town or city in which the family lives.

• In addition, a written report must be filed within 48 hours of learning of the abuse.

• If you see that the child is in imminent danger of being harmed without immediate intervention on a night, weekend, or holiday, there is a 24 hour DCF hotline number (1-800-792-5200).

• When filing, include as much of the following information as you can: names, dates of birth, addresses of the children present in the home at the time of the incident; names, dates of birth, phone numbers, addresses of the caretaker and perpetrator; phone numbers and names of the involved individuals (such as family, friends, therapists, nurses, doctors, probation/police officers) whom DCF can contact.

• If you are filing a 51A report as a mandated reporter, your name and other identifying information will be kept confidential by DCF.

How to file safely

• Discuss the need to file with the non-offending parent, if at all possible. In this discussion be sure to talk with the person about whether s/he has safety concerns in regards to filing a report (e.g., does the person think it will be safe to inform the perpetrator about the report? Will it be safe to inform the children about the report?). It is understandable for the non-offending parent to become upset during the conversation and present safety concerns; however, those are not reasons to avoid filing if you suspect the child is already in danger. It does mean that you should have a frank discussion about safety with the non-offending parent, engage in safety planning, and connect the person with relevant resources.

• Consider filing in conjunction with the non-offending parent.

• Be clear in the report that there are safety issues from the abusive parent, if that is the case. Include the safest way for the DCF to contact the non-offending parent privately. Safe contact is paramount for the effective and safe intervention with the family.

• Offer a safe place for the initial DCF visit with the non-offending parent (e.g., a reporter's office or other identified location).

• File on behalf of the children.

• Name the identified perpetrator of the domestic violence.

• Address safety planning with the non-offending parent.

Approaches for intervening safely when a report is not filed

• Encourage caretaker to express family's immediate needs

• Seek the support of a community domestic violence advocate

• Connect caretaker and family to services that meet their immediate needs

• Connect the family to longer term supportive services where needed

• Assist the adult victim in developing a safety plan

Adult with disability abuse reporting

• A social worker is required to file a report with the Disabled Persons Protection Commission (DPPC) if a person between the ages of 17 and 59 (inclusive) with a disability is being physically, sexually, emotionally, or financially abused by a caretaker. The 24-hour hotline number for the DPPC is 1-800-426-9009 V/TTY.

• You will be asked to provide the same kinds of information for this report as with the others.

• Similarly, include concerns about the individual's safety as a consequence of the report being filed and inform the survivor of the fact that you will be filing the report.

• If you have a relationship with the client normally covered by confidentiality, the client may invoke that privilege, in which case you need to rely on your judgment and consultation.

Elder abuse reporting

• Social workers are mandated to report situations where an elder, defined as anyone 60 years of age or older, is abused physically, emotionally or financially by a care-taker or through self-neglect.

• Reports are telephoned in to the nearest Aging Service Access Point or to the elder abuse hot-line at 800-922-2275.

• A protective service caseworker responds to reports. Elders may refuse protective service.

• Elders in nursing homes are covered by a different law. Such reports should go to the local Long-Term Care Ombudsman

• Telephone numbers for Access Points and Ombudsman offices can be found through the massresources.org page at: http://www.mass.gov/elders/homecare/.

• Once again it is critical to consider risks to the survivor's safety as a consequence of filing the report and to include ideas for the agency to contact the survivor.

• Inform the survivor that the report is being filed, and that they have the right to refuse services. Let him or her know that the agency might have useful resources.

Duty to warn or protect

In 1974, a civil case involving the murder of Tatiana Tarasoff by a classmate at UC Berkely reached the Supreme Court of California. In Tarasoff, a patient told his psychotherapist that he intended to kill an unnamed but readily identifiable woman. Subsequently, the patient killed the woman. Her parents then sued the psychotherapist for failing to warn their daughter about the danger. The California Supreme Court rejected the psychotherapist's claim that he owed no duty to the woman because she was not his patient, holding that if a therapist determines or reasonably should have determined "that a patient poses a serious danger of violence to others, he bears a duty to exercise reasonable care to protect the foreseeable victim of that danger.";

Originally categorized as “Duty to Warn” prospective victims of potential harm, it was later clarified as “Duty to Protect” foreseeable victims from harm. Although the exact legal definition of “Duty to Protect” varies from state to state and is subject to case law interpretation, it has been widely interpreted to mean that the duty may require the mental health professional to inform the intended victim of the danger, to notify the police, or to take “whatever steps are reasonably necessary under the circumstances.”

Massachusetts Duty to Warn

In Massachusetts, the laws mandate to warn a victim or the police if,

a) the patient has communicated to the licensed mental health professional an explicit threat to kill or inflict serious bodily injury upon a reasonably identified victim or victims and the patient has the apparent intent and ability to carry out the threat, or

b) the patient has a history of physical violence which is known to the licensed mental health professional and the licensed mental health professional has a reasonable basis to believe that there is a clear and present danger that the patient will attempt to kill or inflict serious bodily injury against a reasonably identified victim or victims.

For more information, see: https://malegislature.gov/Laws/GeneralLaws/PartI/TitleXVII/Chapter123/Section36b

This situation is more likely to arise if your client is the person using abusive behaviors than if your client is the survivor, but survivors may become desperate enough to threaten to kill or hurt.

• In assessing whether your "duty to warn" has been triggered it would be important to consult with your supervisor and an attorney.

• You will need to inform the police of the name of the person making the threat of harm, the name of the intended victim, the extent of the threat, reasons for believing the threat will be carried out, how you learned of the threat, and what steps, if any, have been taken to ensure the safety of the intended victim.

• It is also important to address any concerns of retaliation by the intended victim towards the person making the threat, as well as any concerns for your own safety.

• As with the other mandated reporting situations, it is important to let your client know of your action. If you believe that this will place you at risk of harm, you need to take prior steps for your own safety.

  • For information regarding duty to warn/protect by state, see: http://www.ncsl.org/research/health/mental-health-professionals-duty-to-warn.aspx.

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Chapter 6: Confidentiality, Privacy, and Privilege Issues

Issues of confidentiality, privacy, and privilege are complicated and vary according to your role and the legal statutes of your geographic area. Nevertheless, it is essential that you have a clear understanding of the extent to which your communication and interaction with survivors is protected by law. If not, you risk making promises you can’t keep and possibly putting the person in serious danger.

For people working in Massachusetts, Jane Doe Inc. (the Massachusetts Coalition Against Sexual Assault and Domestic Violence) has prepared an excellent resource on the laws pertaining to privilege and confidentiality when working with survivors. All of the material in this section of the training has been taken verbatim from that resource, and we are grateful to Jane Doe Inc. for giving us permission to replicate the content here. For people who are working in other states, we encourage you to contact the legal services in your area.

Privileges and Confidentiality Laws

The Massachusetts General Laws (MGL) include a number of privileges that may apply to domestic violence and sexual assault survivors who seek counseling. The intent of these laws is to encourage survivors to speak freely during counseling by protecting extremely private and sensitive information disclosed during counseling sessions. Privilege laws are intended to prevent this information from being used as evidence. Some of the privileges, however, contain exceptions allowing disclosure. The courts also have created exceptions. Note that these are privileges under state law, and that federal law may be different, providing more or less protection, depending on the nature of the proceeding.

Privileges under Massachusetts state law include:

Sexual Assault Crisis Counselor Privilege

(MGL Chapter 233, Section 20J) A sexual assault counselor is defined as a person who: is employed or is a volunteer in a rape crisis center; has undergone 35 hours of training; reports to and is under the direct control and supervision of a licensed social worker, nurse, psychiatrist, psychologist, or psychotherapist; and whose primary purpose is rendering advice, counseling, or assistance to victims of sexual assault. A rape crisis center is defined as any office, institution, or center offering assistance to victims of sexual assault and their families through crisis intervention, medical, and legal counseling. Chapter 25: Privacy Rights, Confidentiality, and Record-Keeping 25-2.

Domestic Violence Crisis Counselor Privilege

(MGL Chapter 233, Section 20K) A domestic violence victims' counselor is defined as a person who is employed or volunteers in a domestic violence victim's program; has undergone a minimum of 25 hours of training; who reports to and is under the direct control and supervision of a direct service supervisor of a domestic violence victims' program; and whose primary purpose is rendering advice, counseling, or assistance to victims of abuse through crisis intervention and medical, legal, or support counseling.

Doctor/Patient Privilege (Common Law)

Psychotherapist/Patient Privilege (MGL Chapter 233, Section 20B or 20C)

Psychologist/Patient Privilege (MGL Chapter 112, Section 129A)

Social Worker/Client Privilege (MGL Chapter 112, Section 135A)

Priest/Penitent Privilege (MGL Chapter 233, Section 20A)

Attorney/Client Privilege (Common Law)

This list is not intended to be all inclusive, but to include the laws that most often apply to sexual assault survivors. Two of these privileges are known as absolute because the laws that created them contain no exceptions: the sexual assault crisis counselor and priest/penitent privilege. Some of the privileges are termed qualified because the laws that created them include exceptions allowing for disclosure in certain circumstances: the domestic violence counselor and attorney/client privileges.

Other state and federal laws provide for confidentiality and may limit disclosure of certain records about the victim. For example, the following types of information are considered confidential, unless statutory or judicial exceptions allow disclosure:

• Medical records (MGL Chapter 111, Section 70; Chapter 4, Section 7)

• Previous sexual conduct/reputation (MGL Chapter 233, Section 21B)

• Sexually transmitted diseases (MGL Chapter 111, Section 119)

• HIV/AIDS testing status (MGL Chapter 111, Section 70F)

• Department of Mental Health and Mental Retardation records (MGL Chapter 123B, Section 17)

• Alcohol and drug treatment (42 CFR Section 2)

• Special education records (MGL Chapter 71B, Section 3)

• Mental Health records (MGL Chapter 176B, S20)

• Public School Records (603 C.M.R. 23.001(4))

The Counselor’s Role in Protecting Confidentiality

Confidentiality is a foundation of rape crisis and domestic violence work. If a center receives a request for records, it works with the survivor to ensure that privacy and confidentiality are maintained to the full extent of the law. Although survivors cannot count on absolute privilege and confidentiality for their counseling records, they should understand that the rape crisis center has a responsibility to see that records are protected until all legal options have been explored.

While the importance of communications privacy between counselor and survivor is critical to understand, so are the limits of the counseling confidentiality. It is the counselor’s responsibility at the very beginning to explain clearly what can and cannot be expected with regard to confidentiality.

You might say to a new client:

"The information you share with me in our counseling relationship is confidential, with some important exceptions: if I have reason to believe that a child or elder is at risk, or that you are a danger to yourself or someone else, I may be required to report that. Also, if your records are subpoenaed and I am ordered by the court to turn them over, I may have to do so. I would not turn your records over without first discussing this with you and making sure that all proper procedures are followed to protect your rights. Except for those circumstances, and when I am in supervision (which is also a confidential relationship), I will not tell anyone what you say here unless you sign a release of information and give me permission to do so."

To protect survivors’ confidentiality and minimize the possibility of being ordered to turn over counseling records, the counselor should:

• Advise survivors of the implications (which could include later defense attorney's requests for counseling records) of disclosing personal, confidential or privileged information to anyone, including whether they have ever had counseling of any kind. Survivors should realize that they do not need to disclose this information unless ordered by a judge after a proper hearing at which they have an opportunity to object. Make sure survivors understand they have this right to refuse to disclose this information to anyone including hospital personnel, the police, and the district attorney, as well as friends, counselors, etc.

• Inform clients that absolute privilege and confidentiality may be compromised if they share confidential information with persons the court may consider not necessary to their healing process, such as friends, relatives, coworkers, or others.

• Keep no notes of direct statements from the client in the file. Direct quotes increase the likelihood that, if records are turned over to the defense, the counselor will become a "prior inconsistent statement" witness against the victim.

• Give survivors a list of privileges and confidentiality laws and explain that they may need their own attorney to enforce these. Inform the survivor involved in a criminal case that the prosecutor is not her attorney but the attorney for the government, and may not be in a position to advocate for her interests.

Responding to a Subpoena

If your agency has a lawyer, you should contact that individual as soon as possible after receipt of a subpoena for advice regarding your response. If no agency lawyer is available, the Victim Advocacy and Research Group (VARG) has trained, pro-bono attorneys available to assist rape crisis centers and battered women’s programs to ensure that the victims' rights are upheld.

Faced with a subpoena or other request for records, the counselor should:

• Immediately advise your client and your supervisor of any request (letter, subpoena and/or court order) for records, and advise the survivor of his or her right to oppose such a request. Remember that the survivor will likely need emotional support at this time.

• Never comply with a) a subpoena for privileged records that is unaccompanied by a court order or signed release from the victim; or b) a subpoena without a signed release even if accompanied by a court order, if the victim was not afforded his or her right to be heard before the order was issued, unless compliance is otherwise required by law.

• Always respond to a subpoena or court order by at least sending a letter to the court and all attorneys of record outlining the inadequacy of the subpoena or other. This correspondence should identify all applicable privileges and confidentiality laws and should contain a constitutional due process-based request to be heard before a court order is issued. Other procedural defects may also be identified in the correspondence including, for example, that the request is made prematurely, not as the "last step" before that, as required by Bishop and Fuller.

• Be aware that at the hearing to decide whether the privileged records should be revealed, it is the responsibility of the holder of confidential material and/or the victim to ensure that disclosure is only allowed where the defense has established its burden of proving that a court order is warranted under applicable law because proper legal standards have been met.

• If a rape crisis center or domestic violence program received a signed release from a survivor, the counselor should ascertain whether the release was signed knowingly and voluntarily. If a court order issues in violation of proper legal standards, the center should seek legal guidance to determine whether an appeal is appropriate.

Record-keeping

Record-keeping is a complex issue for rape crisis centers and domestic violence programs. Questions arise about the most effective way to keep records to meet the needs of the survivor, the counselor, the agency, and funders. Indeed, some people question the need to keep any records at all.

Client records serve many purposes. They facilitate a continuity of services to survivors. They confirm that someone sought services. They may provide protection for a center and counselor in the unlikely event of a lawsuit.

In some cases, it is sufficient merely to record the fact that a victim had service with a counselor on a particular date; in other instances, other records may be needed to meet the standards of umbrella agencies and satisfy the requirements of funders. However, rape crisis or domestic violence records are not intended to be used as evidence because the function of rape crisis counselors as facilitators of the healing process is completely distinct from the function of the criminal justice system members as fact finders.

The challenge, then, is for rape crisis centers and domestic violence programs to develop record-keeping policies that best meet the needs of all parties. In July 1995, the Massachusetts Coalition Against Sexual Assault (name of former sexual assault coalition prior to its merger to form Jane Doe Inc.) approved recommendations on information that should be included in client records. Recognizing the differences among rape crisis centers, these recommendations provide guidelines for obtaining client information, allowing each center to develop policies and train counselors according to its particular requirements.

The suggestions for practice include:

• Counselors should be aware of the language they use in records. All statements should be factual and objective and should not contain anything related to the counselor's interpretation of the facts. Any statements should be kept to a minimum.

• Record-keeping should be minimal, containing only information necessary to the integrity of the counseling relationship and coordination of care, and/or dated record of services provided, as required by statute, license, funding agency, or auditors. (This may relate to items such as signed consent forms, record of consultations with other providers, and suicidality assessments, if provided.)

• No notes of quotes! Never include quotations by the survivor within the records. These could easily be misquoted and could lead to problems in court with corroborating evidence.

• Sensitive information should be identified by code in a separate part of the file, and identified as confidential, citing appropriate statutory provisions.

• Destruction policies should be developed to provide for the swiftest possible disposal of records at the conclusion of each counseling period.

At the printing of this chapter, efforts are underway to further develop and promote more specific guidelines for centers and counselors on the important issue of record keeping. Once these guidelines are developed, they will be distributed to all rape crisis centers and domestic violence programs for their use.

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Unit 5 Quiz

You have the option to move immediately to the next unit, or to take this quiz for Unit 5. Follow the directions to take

the quizbelow. This quiz is designed to help you review the material covered in Unit 5 in preparation for your CEU Quiz. You will see your results immediately after you submit this quiz. This review quiz is not worth any CEUs.