Chapter 8:
The Fiend Unmasked:
Developing the mental health dimensions of the defense
BY JAMES J. CLARK, LANE J. VELTKAMP
AND EDWARD C. MONAHAN

A defense attorney litigating a criminal case on behalf of a troubled client can benefit from using a mental health consultant to help develop and manage the mental health dimensions of the case. With the consultant’s assistance, the defense team can meet a range of critical goals:

Most important, the defense team must create empathy for the client and reduce misunderstanding of the client’s behavior through the careful use of mental health evidence. By presenting the client’s actions as an attempt to resolve a specific problem, it becomes possible to gain an understanding of the human being behind the act, no matter how monstrous the act may be.

When a client’s mental health plays a significant role in determining whether he or she is guilty, or what degree of punishment is appropriate, a defense attorney cannot provide competent representation without the assistance of a mental health consultant. This article provides a realistic view of what mental health experts can and cannot offer and how to make the best use of their services to defend your client.

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Your relationship with the expert

It is often imperative that an attorney include mental health testimony as a part of the defense, but mental health experts present attorneys with a dilemma. On the one hand, attorneys need such experts to offer evidence regarding a client’s behavior, incompetence, insanity, or mitigating factors. On the other hand, these experts can sometimes seem unpredictable, stubborn, superficial, and oblivious to the pressing needs of the case.

Deciding on a specialist. Before choosing a mental health specialist, it is important to develop an accurate mental health history of the client. On the basis of that history, the attorney can formulate a range of possible mental health theories to explain the client’s behavior and then decide what specialist might be appropriate for the case.

Evaluating the expert’s report. Consider the following example:

Feeling that your client has some very serious mental problems, but unable to formulate exactly what they are or to identify what relevance they have to the case, you hire Dr. Stanley Jones, a psychiatrist, to testify regarding your client’s apparent mental illness. Dr. Jones conducts a psychiatric interview of the client, which includes a mental status exam and a medical and psychiatric history. He reports his conclusions: The client’s lifelong antisocial behavior justifies a DSM-III-R diagnosis of Antisocial Personality Disorder (that is, a diagnosis based on the American Psychiatric Association’s Diagnostic and Statistical Manual of Mental Disorders (American Psychiatric Press, 3d ed. Rev. 1987)). You complain that Dr. Jones’s findings give you no better understanding of your client than you had before and that Jones, your own expert, is revealing information that will be viewed only as harmful by the fact finders. Many attorneys who find themselves in a similar situation feel they have no basis for further dialogue with the expert who has rendered an unhelpful or damaging diagnosis. Can it really be argued that Dr. Jones’s examination yielded invalid or incomplete results? What background knowledge can an attorney marshal to make clear to Dr. Jones what kind of examination would be useful to help others understand the meaning of the client’s behavior?

Some attorneys use guides to mental health evaluations, but such guides describe only the components of the evaluation and cannot speak to the validity of the opinion formed by the evaluator. (See, e.g., John Blume, Mental Health Issues in Criminal Cases: The Elements of a Competent and Reliable Mental Health Evaluation, The Advocate 42-46 (Aug 1990).) For example, it takes years to refine the technique of conducting a mental health interview, an extremely complex social interaction that is difficult for laypersons to evaluate.

Reducing unpredictability. An equally difficult problem arises when the expert provides the attorney with an analysis favorable to the defense, but this analysis does not hold up in court – or actually backfires.

In another case, you hire a neurologist, Dr. Hopkins, to testify that your client is brain damaged. Dr. Hopkins takes the stand and describes the client’s history of head injury. He carefully explains the results of the neurological examinations, including the electroencephalogram (EEG) and even a magnetic resonance imaging (MRI). It seems like science at its best. Under cross-examination by the prosecutor, Dr. Hopkins acknowledges that this type of serious organic damage is not reversible. Unfortunately, the jurors are so effectively persuaded that they form the view that such severe damage, so carefully documented, describes the defendant as a "Frankenstein’s monster," not amenable to treatment or restraint without danger to others. Deana Dorman Logan, in her excellent discussion of this problem (Is It Mitigation or Aggravation? CACJ/Forum 14-20 (Sept-Oct 1989) ["Mitigation or Aggravation?"]), suggests that the introduction of mental health evidence can cause jurors to either empathize with the defendant or see the evidence as further aggravation requiring aggravated penalties, including a death sentence, in order to ensure society’s protection. In the case just described, the client was indeed brain damaged. How could the powerful scientific evidence of the injury be marshaled to help the criminal defendant? Or should this evidence not have been introduced at all?

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Consulting experts and testifying experts

We classify mental health experts as either consulting experts or testifying experts. Consulting experts become part of the defense team and help the attorney develop the mental health theory that will be argued in the case. Testifying experts conduct evaluations specific to their field of expertise and testify to the results as a witness for a party.

You have hired Rita Johnson, a licensed clinical social worker, to assist you in handling the mental health problems in your criminal case. Ms. Johnson carefully studies various social and mental health records of the client and then conducts several interviews with your client. The records reveal an extremely dysfunctional family background, including strong indications of childhood sexual abuse. Working with you and your staff, Ms. Johnson helps construct a developmental time-line of the client’s life and a genogram (family tree). The time-line reveals serious inconsistencies and gaps, along with several early childhood head injuries and a long history of involvement with community mental health agencies.

While Ms. Johnson understands your desire to present the client as a paranoid schizophrenic, she has grave doubts that this is a valid diagnosis. She observes that the client has never received a thorough neurological examination and recommends that you hire a person with expertise in family theory and the evaluation of childhood traumas. She also recommends a neuropsychologist to test for brain injury and to provide a detailed report of the client’s brain functioning. After reviewing these experts’ reports, you decide to hire a neurologist to correlate the neuropsychological evidence. These experts testify at trial.

 Why should the defense spend more money and time on a mental health consultant when it seems less expensive and easier to limit oneself to mental health experts who will only evaluate and testify? Alternatively, why not hire a mental health professional who will both consult and testify? As discussed in some detail below, the consulting expert who does not testify is an important player with a unique role on the defense team.

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Correcting for the bias of the expert witness

Social psychology research demonstrates that experts tend to assess clients only from their particular professional vantage points. As a result, clients will be diagnosed as suffering from problems the expert has the ability to detect and the resources to label and treat. (Dennis C. Turk and Peter Salovey, eds., Reasoning, Inference and Judgment in Clinical Psychology (The Free Press, 1988) ["Reasoning, Inference"]; Jurgis Karuza, Michael A. Zevon, Vita C. Rabinowitz, and Phillip Brickman, Attribution of Responsibility by Helper and Recipients, in Thomas A. Wills, ed., Basic Processes in Helping Relationships 107-29 (Academic Press, 1982).) A psychiatrist may be extremely skilled at developing a Diagnostic and Statistical Manual (DSM-II-R) diagnosis but have little idea about how family dynamics or environmental deprivations have shaped the client. A clinical social worker may have expertise in psychosocial and family dynamics issues but erroneously neglect the complex biological issues involved in the case.

This "dominant orientation" phenomenon can lead to several problems at the level of assessment:

  1. The expert may uncover issues that pertain to his or her area of expertise but report no other finding. Thus, the report may describe accurately only a few dimensions of the client’s personality and behaviors.
  2. The expert, finding no sign of problems in his or her area of expertise, may report the absence of significant mental health issues and thereby mislead an attorney into believing that there are no helpful mental health explanations available.
  3. The expert may identify various mental health issues but, believing many of them to be insignificant, may choose not to report them or remain unwilling explore them further.
  4. The expert’s analysis, while helpful, may need a broader context or corroborating findings from other mental health perspectives to fully and persuasively communicate the meaning of the client’s behavior.
Let’s say that in the first case described above, Dr. Jones was asked about the client’s family background, but he was confident that family background, while worthy of notice, was not a sufficiently powerful explanation for the defendant’s psychopathology. Dr. Jones refused to conduct more thorough family interviews or testify in more detail about the family background, saying it was "a waste of time."

A consulting expert would be vigilant for these situations and alert the attorney to the strengths and weaknesses of different mental health evaluation. The consultant can suggest other mental health evaluations that will complement and strengthen weak or incomplete evaluations. The consultant can also advise the attorney on ways to approach experts who are resistant to continued dialogue and analysis.

It is too easy for even the sophisticated attorney to miss the consequences of the mental health expert’s particular professional orientation. A consultant can help the attorney by identifying the orientation of the testifying expert and discussing the use of other experts with differing expertise. The incisive testimony of the expert witness is irreplaceable, but it must be used with caution and only in the context of the entire mental health strategy of the case.

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Sorting out the roots of violence

Perhaps the most important reason to work with a consulting expert is to allow the defense to thoroughly consider competing and complementary mental health theories of the case. Do not see this as an opportunistic stance; rather, it is based on a theoretical understanding of violence. Psychiatrist Dorothy Lewis has developed a compelling argument that there are multiple influences on the development of violent individuals. (The Development of the Symptom of Violence, in Melvin Lewis, ed., Child and Adolescent Psychiatry: A Comprehensive Textbook (Williams and Wilkins, 1991).) These influences include:

The search for the etiology of violence has taken multiple pathways. Much of this research is still in its early stages, suggesting that our understanding of aggression and of violent crime in particular is limited. Unfortunately, this is not the stance many expert witnesses take when they testify – to the delight or chagrin of the attorneys trying the case. An individual clinician typically prefers one or two of these etiological explanations because of training, expertise, and core beliefs, but a thorough evaluation of the client requires that the attorney explore multiple explanatory pathways, especially when the defense’s mental health argument is initially being considered.

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Helping to prepare a multipathway defense

A consulting expert who is aware of the complexity of the situation can help the defense gain a more realistic view of the client. The exploration of many possible explanations for the client’s behavior may prove frustrating initially, but it is an approach that can have long-term benefits. Trying to make your case with a simple, quick explanation may be disastrous, as the argument can often be destroyed by an effective cross-examination or refuted by a better-informed prosecution witness.

A carefully constructed multipathway theory may still be vulnerable to attack, but it can retain its basic integrity even if one dimension of the argument is refuted. If the attorney decides to present only one explanation, the earlier exploration of many pathways can still help the defense prepare to argue against completing explanations that may be used by prosecution experts.

The client’s story. An argument against the multiple-pathways approach is that it is too difficult for the defense to integrate several explanations into a coherent, persuasive presentation. If we accept the current empirical findings of social psychologists, we understand that jurors process information most readily if it is in narrative form; that is, in the form of a story. (Nancy Pennington and Reid Hastie, Evidence Evaluation in Complex Decision Making, 51(2) J. Personality & Soc. Psychology (1986); Explanation-based Decision Making: Effects of Memory Structure on Judgment, 14(3) J. Experimental Psychology: Learning, Memory & Cognition (1988).)

Rather than developing simply a list of arguments, the attorney must develop a formulation, weaving the multiple mental health issues into the larger story of the client being told in the voir dire, opening statement, examination of witnesses, and closing argument. In the following, we offer some strategies for constructing an effective mental health story.

All behavior has meaning. The most frequent approach to evaluating persons is to employ a bio-medical model that emphasizes psychopathology. While it is not our intention to recommend routine exclusion of the biomedical model, we believe that relying on it alone is a serious mistake. Even if the diagnosis is not as prejudicial as "antisocial personality disorder," emphasis on psychopathology tends to emphasize the differences between the client and the fact finders and to decrease the likelihood of an empathic connection.

In our experience, a biopsychosocial assessment that elicits the client’s experience of the offense in the context of his or her life situation offers the key to the jurors gaining a more profound understanding of the defendant. This approach was recommended in the early twentieth century by Alfred Adler, who argued that "all behavior is purposeful." (Harold H. Mosak, Adlerian Psychotherapy, in Raymond J. Corsini and Danny Wessing, eds., Current Psychotherapies (Peacock Publishers, 4th ed. 1989).) Contemporary cognitive and phenomenological approaches emphasize that understanding even maladaptive coping behavior is possible when the clinician explores the "appraisals," or readings of the situation, made by the client, even when these appraisals may not be ordinary or prosocial. (Susan Folkman and Richard S. Lazarus, Stress, Appraisal and Coping (Springer, 1984).) We argue that no matter how bizarre or inexplicable behavior seems initially, by understanding the subjective experience of the client and how his/her actions were an attempt to solve a problem or deal with a stressful situation, the observer can begin to see the ultimate purpose of the behavior.

The prosecution presents evidence that your client murdered her husband with a gun, dismembered the body with an axe, and then buried the evidence. Careful evaluation of the client reveals a woman who had been beaten and terrorized by the victim for seven years and had witnessed him abusing their two young children. You lay out this history in some detail and present a thorough history of the client’s impoverished development in a dysfunctional family-of-origin in which she was sexually abused by her alcoholic father. Your expert testifies that after seeking help from various social service agencies and receiving inadequate responses, the client killed her husband to save herself and her children from further abuse. The testimony includes a videotape of the clinical interview of the client describing her childhood, the marriage, and the overwhelming conditions that drove her to this self-protective act. You integrate this story under the rubric "battered wife syndrome" in the voir dire, opening statement, examination of witnesses, and closing argument. Eliciting empathy for your client. Another way to conceptualize this approach is to think of an empathy / compassion "equation" that includes the issues discussed by Logan (Mitigation or Aggravation?, supra) and the multiple dimensions we described above. Such an equation might look like this:
Family dysfunction &
Childhood traumas

+

Other psychiatric &
Neurological evidence

+

Client’s subjective
purpose behind acts

+

Lack of support
network, help,
or treatment

=

Empathy & compassion
for the client

 The consultant must help the attorney and the expert witnesses present this entire equation to the jury in order for the evidence to explain persuasively the client’s behavior. Our experience has taught us that leaving out any one of these variables increases the risk that mental health evidence will be meaningless, fragmented, or even aggravating. Consider what happens in the following case when the equation is incomplete. Your client is found guilty of shooting, stabbing, and driving over three elderly victims. During the penalty phase, the mental health experts testify that your client came from an extremely deprived childhood that included being battered, sexually abused, and addicted to drugs. You also demonstrate that child-protection services never developed a plan for your client and that, as a child, she was in five foster homes in seven years. Despite viewing a videotape of this interview and hearing sympathetic testimony by a family friend, the jurors voted for the death penalty. When one member of the jury was later asked about her decision, she said that she felt badly about the defendant’s childhood but believed that so heinous a crime was beyond understanding and excuse. In this case, the client’s childhood traumas included attachment disruption, sexual victimizations (including being sold into prostitution), introduction to drugs as a child, and repeated exploitation by others. However, the defense never explained to the jury why the violent crime occurred. Without a convincing link between the violent acts and the client’s tragic life history, these offenses remained unfathomable and horrifying to the jurors – a lethal combination.

To ensure that jurors and judges understand the defendant compassionately rather than see him or her as a monster, the defense must take the following three steps when presenting mental health evidence in criminal cases:

  1. Vividly describe and fully explain the client’s family dysfunction and childhood traumas.
  2. Explain why this violent behavior was purposeful for the client, that is, why the behavior occurred.
  3. Explain what could have happened to prevent this tragic event from taking place.
In the example, step one was done well, but steps two and three were not done at all. The defense never emphasized that the defendant’s drug abuse mediated the psychological ramifications of her childhood experiences and that her adult rage – disinhibited by drug use – was directed toward persons who were very much like those who had victimized her as a child and adolescent. Furthermore, the jury never fully understood that through mismanagement and ignorance, the institutions of local law enforcement, child welfare, and mental health not only failed consistently to protect the defendant but in fact exposed her to new victimizations. The defense needed to highlight clearly these recurring themes as a link between the defendant’s life history and the violent acts the jury was being asked to examine.

Jurors can psychologically deal with a heinous crime if it is presented in the context of a compelling and coherent story. Even if this is not always a sufficient condition, it seems that it is a necessary condition for the jury to be able to empathize and connect with the humanity of the client.

Developing a mental health argument that integrates the defendant’s life story and its relationship to the crime, while simultaneously grounding the argument in valid mental health theory, is a daunting enterprise. It requires time, money, competent consultation, and expert testimony. However, such a presentation can be extremely persuasive if it is well prepared and delivered. While each expert witness can present a piece of the story, the consulting expert assists the attorney in developing the theory that drives all the testimony and the narrative that integrates and explains it to the jurors.

Consultants can help exclude unnecessary information that may derail the defense, encourage spurious correlations, or foster overinterpretation of information. These "cognitive errors" can lead to invalid inferences that derail the defense team and, later, the jury. (See Paul E. Meehl, Psychodiagnosis (Norton, 1972); Turk and Salovey, eds., Reasoning, Inference, supra.)

The skilled criminal defense investigator who is able to track the long paper trail of a client’s life provides the defense team with important clues to the mental health issues in the case. Due to the limited time and money involved, it is eventually necessary to direct the investigation and data analysis to specific areas. This is where the consulting expert comes in. The consulting expert can read this voluminous record and then recommend what further mental health investigation might prove most fruitful.

When the attorney, paralegal, and investigator brainstorm with the consulting expert, new ideas and a team consensus for future efforts often emerge. One forum for brainstorming is a team meeting to look at the client’s developmental time-line and vigorously discuss issues from the mental health and legal points of view.

Collaborative preparation can encourage development of a streamlined argument and prevent presentation of too many expert witnesses. Cognitive psychology teaches us that presenting too much information can befuddle persons who are asked to perform complex tasks of memory and judgment. How many mental health experts should jurors hear? As many as can help them remember the client’s story and integrate the variables in the empathy / compassion equation described above. No more, no less.

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Finding appropriate expert witnesses

The consultant can help the attorney hire witnesses whose expertise will be applicable to the case. Having worked with the consultant to develop several possible mental health approaches for the case, the defense team can then seek witnesses with particular expertise.

Just as we would not recommend choosing a psychotherapist by calling the first number in the Yellow Pages, we recommend against choosing an expert based only on reputation or credentials. The consultant can help identify persons who are competent mental health practitioners and who will be comfortable with the overall mental health theory of the case. For example, the consultant can help the defense team decide whether to hire a clinical psychologist, neuropsychologist, neurologist, psychiatrist, psychopharmacologist, clinical social worker, or some combination of these specialists.

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Consultant as liaison between attorney and experts

Because the consultant is familiar with the specialized language and "culture" of mental health experts, he or she can help the attorney and the experts to develop good working relationships. This liaison work can continue after the expert is hired, through the processes of evaluation, report writing, and testimony. The consultant can, for example, encourage busy, experienced forensic experts to be more invested in the case because they perceive the defense team as efficient, approachable, and committed.

The deliberate development of a relationship between the attorney and the testifying expert is a critical role for the consultant. By helping to resolve disagreements and misunderstandings between the expert and the attorney, the consultant not only enhances communication but improves the expert’s subsequent testimony. The more complex and difficult the case, the more likely difficulties will arise between the testifying experts and the attorney. A sturdy relationship is the only hope that the collaboration will survive these predictable conflicts.

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Legal and ethical aspects of using a consultant

A mental health consultant’s work is protected by the Sixth Amendment guarantee of counsel as well as the attorney-client and work-product privileges, because the consultant "has the same obligations and immunities as any member of the prosecution or defense team." (ABA Criminal Justice Mental Health Standards (1984) Standard 7-1.1©; Miller v District Court, 737 P.2d 834 (Colo. 1987).) Notably, the testifying expert's work is subject to some discovery (Standard 7-3.8), but the consultant'’ work is beyond the reach of the court or the opposing party. (See, e.g., Federal Rules of Criminal Procedure 16(b)(2).)

These protections are critical to the full functioning of the consultant / attorney relationship and markedly distinguish the role of the consultant. If a consultant’s work were subject to discovery, the possibility of frank dialogue between the attorney and the consultant would be nonexistent. The consultant thus is an invaluable resource, and can communicate, advise, and work out a strategy at length with the attorney.

When attorneys obtain expert assistance, they usually hire a testifying expert whom they may ask to double as a consultant because this seems more efficient or because economic constraints demand it. However,

[d]ifficulties arise when professionals attempt to serve in the dual capacities of evaluator and consultant. Ideally, these roles should be separated so that the objectivity of an evaluation is not contaminated by a long-standing consultative relationship between a professional and an attorney. (Commentary to Standard 7-1.1©.) It is also unwise to have a testifying expert involved with information or discussions that are consultative in nature, because consultative work is exposed to discovery. To maximize the value of the experts’ assistance, separate individuals must perform the two distinct roles. Asking one expert to perform both potentially contradictory roles will create conflicts, introduce needless limitations, and force the defense into unsolvable dilemmas.

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Resources to hire a consultant

Unfortunately, lawyers too often put little effort into trying to secure funds for experts and therefore seldom receive funding for an expert consultant or for a testifying expert. How can an attorney obtain the money to hire a consulting expert as well as a testifying expert?

A client rarely has sufficient resources (or a family with sufficient financial resources) to retain a consulting expert. More often, the client and his or her family and friends are indigent. Experts must be retained through outside resources.

One strategy is to recruit mental health consultants who work in academic settings, especially research and training universities. Some may be willing to assist because of a belief in the value of the work, the quest for valuable experiences for clinical teaching, or the need to develop research projects to meet the demands of "publish or perish."

The most frequent means used to obtain funds to hire an expert consultant is a request to a judge to order the funding authority – the county, state, or federal government – to supply the funds. Case law across the nation clearly instructs that a substantial threshold showing is necessary before a court is statutorily or constitutionally required to authorize the money and that the showing must demonstrate the following eight features:

  1. Kind of expert required.
  2. Type of assistance needed from that expert (investigating, testing, consulting, evaluating, testifying).
  3. Name, qualifications, fees, estimated total costs.
  4. Reasonableness of expected costs.
  5. Basis for the request, showing that expert help is "reasonably necessary":
  1. objective, e.g., prior mental health history;
  2. subjective, e.g., observation of bizarre behavior by attorney;
  3. legal, e.g., relevance of mental state to culpability;
  4. competence and national standards requirements for effective representation.

    5.  
    6. Case law and statutes affording right to expert.
    7. Unavailability or inadequacy of available state-employed and – funded experts.
    8. Supporting information, such as affidavit of proposed expert or mental health records of the client.

(Edward Monahan, Obtaining Funds for Experts in Indigent Cases, 13(7) The Champion 10-18 (1989).)

Funds for both consulting and testifying experts are provided with increasing regularity when the attorney makes a competent threshold showing. (Ake v. Oklahoma, 470 U.S. 68 (1985).) Ake explicitly recognizes the necessity of access to both testifying and consulting experts. As a guarantee of Fourteenth Amendment due process when the threshold showing has been made, the Ake court determined that an indigent defendant is entitled not only to an expert who would conduct a professional exam, help determine the viability of a defense, and testify but also to one who would "assist in preparing the cross-examination of a State’s psychiatric witnesses" (e.g., a consulting expert).

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Characteristics of a consultant

What type of person makes an effective mental health consultant for criminal cases? We recommend looking for seven main characteristics when you consider hiring a consultant for your case:

  1. Expertise in the area of family theory and a biopsychosocial systems orientation. (George L. Engel, The Clinical Application of the Biopsychosocial Approach, 137(5) Am. J. Psychiatry 535-43 (1980).)
  2. Expertise in detecting childhood trauma and a clinical understanding of how it affects persons later in life.
  3. In-depth background in human development research and theory, along with a practical knowledge of psychopathology and the ability to "translate" this specialized knowledge for laypersons.
  4. Understands human behavior as purposeful and sees even violent behavior as often an attempt to meet crises and to solve problems.
  5. An interdisciplinary orientation and an understanding of the expertise of mental health professionals from disciplines other than his / her own.
  6. Enjoys working with attorneys, investigators, and paralegals, and understands and appreciates legal ethics as well as the criminal justice system’s valuing of the adversarial process.
  7. Perhaps most critical: Sees the client as a human being who is ultimately comprehensible and deserving of the best mental health assistance and advocacy possible.
Conclusion

To successfully defend a client, an attorney needs to demonstrate how the defendant’s mental condition was the proximate cause of the criminal act that was committed, and then be able to show that that condition is subject to remediation. A consulting expert can help attorneys develop a persuasive mental health theory of the case, choose competent expert witnesses, and develop a narrative that integrates the variables of the empathy / compassion equation described above.
 
 
JAMES J. CLARK

Assistant Professor
CATS Project
University of Kentucky
3260 Blazer Pkwy, Suite 102
Lexington, KY 40509
Tel: (859) 543-0078 x 0

E-mail: jjclar00@pop.uky.edu

 LANE J. VELTKAMP

Assistant Professor
Department of Psychiatry
University of Kentucky
3470 Blazer Pkwy
Lexington, KY 40509
Tel: (859) 323-6021 x287

E-mail: ljvelt2@pop.uky.edu
 

 EDWARD C. MONAHAN

Deputy Public Advocate
Department of Public Advocacy
100 Fair Oaks Lane, Suite 302
Frankfort, Kentucky 40601
Tel: (502) 564-8006, ext. 236
Fax: (502) 564-7890

E-mail: emonahan@mail.pa.state.ky.us

© James J. Clark, Lane J. Veltkamp and Edward C. Monahan, 1993

 

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