[PDF]  Summer 2010 – Newsletter of the NOW Family Law Ad Hoc Advisory ... www.nowfoundation.org/issues/.../family_law_newsletter_summer2010.pdf File Format: PDF/Adobe Acrobat - Quick View WHEREAS, the term Parental Alienation Syndrome (PAS) was created by the psychiatrist,. Richard Gardner. It is used as a tactic in courts by litigating attorneys