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SPECIAL ISSUE: PARENT-CHILD CONTACT PROBLEMS: CONCEPTS, CONTROVERSIES, & CONUNDRUMS INNOVATIVE SYSTEMIC RESPONSES INNOVATIVE PROGRAMS IN ISRAEL FOR PREVENTION & RESPONDING TO PARENTAL ALIENATION: EDUCATION, EARLY IDENTIFICATION AND TIMELY, EFFECTIVE INTERVENTION Philip Marcus There is substantial research and documentation showing that behavior of a parent which alienates a child against the other parent (PA) and other family members may cause serious, and sometimes permanent, damage to the child. Building on the work that deﬁnes maladaptive parental gatekeeping (MG) and PA, and on identifying typologies of behavior, and their effects on the alienated child, the need for prevention of children in these cases is well established. This paper describes programs and responses in Israel, some already in place and others under development, almost all of which require multidisciplinary collaboration between professionals. The programs include: primary prevention; early identiﬁcation, so as to allow prompt secondary intervention by advice and treatment of parents and child; and immediate tertiary intervention when alienation has led to contact failure or is about to do so. Prevention and early intervention can reduce the need for the massive investment of resources needed for attempts to restore contact, and also for treatment of those affected by PA. Practitioner Key Points: Parental alienation is highly damaging to the child, and the damage lasts into adulthood. The general public and professionals who work with children are largely unaware of PA, and its damaging effects. Prevention of PA is a public health issue. Prevention of PA is possible, but depends on public awareness and training of professionals to take preventative steps. Prevention requires identiﬁcation of at-risk children and parents, and of situations in which PA is liable to develop. After identiﬁcation, immediate intervention – therapy for the child and parenting education – are required. If PA has already resulted in contact failure, courts must act speedily and resolutely to make orders for reconciliation therapy and treatment. Identiﬁcation, treatment, and judicial intervention require multidisciplinary coordination. The court must supervise progress of reconciliation and therapy, and impose sanctions for parental disobedience. Israel has programs which address all the above issues. Keywords: Maladaptive Gatekeeping; Multidisciplinary; Parental Alienation; Prevention; Public Awareness. In a previous paper, Parental Alienation, Contact Refusal and Maladaptive Gatekeeping: A Mul- tidisciplinary Approach to Prevention of Contact Failure,1 the author made use of a quasi-medical analogy to describe the need for multidisciplinary collaboration in preventing parental alienation (PA). PA is comparable to a disease or illness.2 To the extent that disease can be prevented, every effort must be invested; this is primary prevention. When the symptoms of sickness ﬁrst manifest, prompt diagnosis and treatment by the family physician can often provide a cure – secondary Correspondence: [email protected]; www.philip-marcus.com FAMILY COURT REVIEW, Vol. 58 No. 2, April 2020 544–559 © 2020 Association of Family and Conciliation Courts intervention. When the symptoms do not disappear, and become acute, there is no alternative to intervention by specialists, often in the emergency room – tertiary treatment; in many cases, time is of the essence because if such treatment is not given promptly, the situation may become incurable.3 Further developing the themes of that paper, this article discusses how many of the recommenda- tions are being implemented in Israel and sets out plans for further multidisciplinary work.4 I. PRIMARY PREVENTION – AWARENESS A. THE GENERAL PUBLIC A person who has no knowledge of their sickness will not ask for treatment. For example, high blood pressure or bad HDL/LDL ratio in the blood are described as the silent killers, because they can lead to disaster when the potential victim is unaware of the risk. Similarly, some types of cancer are symptomless until they reach the stage when treatment is highly expensive and the chances of success are relatively low. In recent years, public health authorities have realized that in many cases the costs of awareness campaigns and screening are minimal when compared with the costs of treat- ment, and in addition, ultimately lead to better quality of life and longer life expectancy. Attempts to encourage the general population to change to a healthier lifestyle and undergo screening for these diseases have been met with signiﬁcant success.5 In the same way, primary prevention of PA starts with raising public awareness of the existence of the phenomenon, its causes, and its devastating results. Campaigns need to utilize all media of commu- nication to ensure that to the extent possible, all sectors of the public are exposed to the message. Thus far, we can point to the following successful outreach efforts, aimed at the general public: A three-part documentary on television, shown at prime time, produced and narrated by Tzoﬁt Grant, a well-known investigative journalist, featuring alienated parents, alienated children, alienating parents, and experts, emphasizing that much still needs to be done to ensure that the social welfare authorities and the courts deal swiftly and effectively with PA. A large demonstration in a central square in Tel Aviv, featuring large boxes on which there were quotes from responses of alienated children to expressions of affection and longing by parents: “I never want to see you again,” “You are not my mother/father,” “Do not harass me by trying to make contact.” Articles by experts and others, in print and on-line media, describing PA and its consequences. Legislative proposals also bring public attention to the issues being tackled. In Israel, an ambitious Bill was presented to the Knesset, Israel’s parliament, by then-member of the Knesset, Ms. Revital Swed. The Bill proposed expanding the powers of the courts, includ- ing accelerated procedures for cases in which PA is alleged, and for setting up a cadre of professionals who specialize in PA to whom the courts must refer to in dealing with such cases, etc. Another Bill proposes criminal sanctions against alienating parents, and a stan- dard ﬁxed ﬁne for non-compliance with court orders regarding contact and treatment of children affected by PA. The present writer has criticized some of the proposals as dis- cussed below; some may be unnecessary or even counterproductive. However, the public- ity attracted by these Bills has drawn PA to the attention of legislators and members of the public who were not previously aware of the phenomenon and its effects. There has been coverage, largely positive, in the press of judicial decisions relating to PA, espe- cially those under the new schemes, described later in Part Three, for tertiary court interventions. However, with regard to publicity relating to individual cases, a word of caution is in order. In some cases, an alienated parent may use the press and social media to lash out at everyone who was involved in therapeutic or judicial activities in the case. Admittedly, it may be true that in many Marcus/ISRAELI RESPONSES TO PARENTAL ALIENATION 545 cases, if alienating behavior had been recognized early enough, and prompt and appropriate action had been taken, the total failure of contact might have been avoided; however, there is no justiﬁca- tion for saying that all judges are incompetent or corrupt, that all welfare ofﬁcers are ignorant, or that all expert consultants and witnesses are ill-informed or bribed. Such wild allegations, although they reﬂect the intolerable pain of a parent who has been separated from any contact with their child due to brainwashing by the other parent, do no good to the efforts being made by activists and others to bring the issue to the attention of the public and of policymakers. Such counterproductive actions put all alienated parents at risk of being labeled as being mentally disordered or fanatics, and that the refusal of the child to have contact with them is therefore justiﬁed. On the other hand, ﬁrst-hand accounts of the travails of alienated parents and even more so of adults who, in their childhood, were alienated from one of the parents, are exceptionally effective in drawing public attention. The impact of a riveting talk by a victim far exceeds that of a scientiﬁc article. B. RELATIONSHIP EDUCATION Programs are being initiated for outreach to speciﬁc populations who are in the process of enter- ing relationships: For high school students and youth movement members: Here, the accent will be upon for- ming lasting relationships based on good communication skills, adequate problem-solving techniques, and an understanding that parenting consists of responsibilities to the child,6 which include the need of the child for good and beneﬁcial relationships with both parents, even (especially…) when they separate. The materials need to be culturally appropriate, and youth are to be involved in producing materials for use in schools and on social media, etc. There is a need to prevent the breakdown of relationships between couples who have chil- dren; one of the ways to do so is through pre-marriage training for couples. The content of such training will vary according to the cultural and religious orientation of the couple, but should include those elements already described: communication skills and problem- solving methods in the event of misunderstandings and differing viewpoints which arise as a matter of course when two people join together. Ideally, these courses will advise the couple of agencies and professions they can turn to for help.7 For those who are in the process of separating, we are preparing a Red Flags8 document which will contain information about types of behavior that are likely to lead to problems with child–parent rela- tionships and may lead to PA. The need for such a document arises because in many cases, a parent is unaware that the actions, words, or omissions of the other parent are likely to lead to contact problems; in such cases, only when the child expresses reluctance to have contact with one of the parents, or con- tact fails completely, does the alienated parent become aware that this is the result of a campaign of alienation. The longer that the child is exposed to alienating behaviors without intervention, the greater the chance that intervention will not succeed in putting parent–child contact on the right track. It remains to be decided when, how and to whom to distribute such a document. Among the pos- sibilities for distribution are: in parenting supplements in the general press, and as a handout to be given to parents in kindergarten or school settings, etc. C. STUDENTS It is important for undergraduate and graduate courses in the departments of law, psychology, medicine, education, social work and other relevant disciplines to include material about MG and PA. The objective is to ensure that when these students enter their chosen professions, they will be able to recognize the signs of MG and understand its damages if left unchecked. Also important, is to start the process of training them to intervene should they come across the signs of incipient PA, which are set out below. 546 FAMILY COURT REVIEW For example, at the time of writing we have lectured at seminars for students of social work, at Ben Gurion University in Beersheba, and at the Tel Hai Academic College in northern Israel. It became clear that these students can become agents for social change. From comments and ques- tions at seminars and lectures thus far, material delivered excited both surprise that PA exists and anger at the damage it causes, and among some listeners a desire to learn more and “do something about it.” We have no illusions that all of those who are studying law, medicine, social work, psychology, education, and similar disciplines will want to specialize in the branches of their professions dealing speciﬁcally with the relations between children and their parents. However, people in these and allied professions may incidentally come across examples of distress in a child, or parental behav- ior, and recollect what they heard from us: that these parental behaviors are not trivial, and must be addressed immediately, so that they do not become pathological. For example, we believe that all law students should be informed about the phenomenon of PA. Even if they have no intention of practicing family law, frequently a family member will con- sult with a relative who is a lawyer, in another area of law altogether, for initial advice and a referral to an expert. The lawyer may very well remember a lecture on PA given at law school and know about the urgency and the need for a lawyer who is well versed in these issues. II. SECONDARY PREVENTION: IDENTIFICATION AND INTERVENTION A. RECOGNITION AND EARLY IDENTIFICATION Although child maltreatment always existed, it was only a few years ago that the need was recog- nized for educational programs and procedures to identify physical and sexual abuse of children; the time has come to apply the lessons learned from such efforts to the emotional maltreatment of children by PA. Effective intervention to prevent strife between parents from affecting the relationships of the child with both parents requires all professionals who come into regular contact with children and parents to receive training. As is the case with other forms of abuse and neglect, as well as info- rming students about the issues as stated in the previous section, such training will take many forms: articles in professional publications; in-service and continuing education training seminars; circulars issued by government ministries requiring the adoption of procedures and allocation of responsibilities in handling such cases; and the appointment of individuals in organizations whose responsibility it is to disseminate information and ensure procedures are followed. B. TRAINING PROFESSIONALS: METHODS AND CONTENT Content of the training will be adapted to the speciﬁc professions and specialties within those professions. Professionals working in schools and kindergartens may be the ﬁrst to notice signs of distress in their pupils and of maladaptive behavior by a parent. Although the general orientation of the education profession is to make the school a safe haven and not be involved in disputes between parents, these principles must in some cases give way to the need for intervention when parental strife is likely to, or is already, getting in the way of the primary role of the school – to educate. The balance is indeed delicate, and education of school staff, including the principal and teachers, administrative workers, and the person who supervises at the gate when children are brought to school and collected, will enable sound decision making about the pupils.9 Social workers and psychologists are both socialized to not only believe their clients, but to also to sympathize with them, particularly children. In a case where PA is already starting, the social worker needs to adopt a ﬁrm approach, which may run counter to the basic orientation of social work. The alienated child may speak convincingly about the evil deeds of the alienated parent, but Marcus/ISRAELI RESPONSES TO PARENTAL ALIENATION 547 this must be recognized as the product of the alienating process, including parental inﬂuence and other parental alienating behaviors, or fantasy. The alienating parent may be convincing and try to bring the social worker “onboard,” but the social worker must be trained to see through potential misguided behavior or manipulations on the part of the alienating parent, and proceed to adopt an uncompromising stance against the alienating behavior. 1. Handbooks Training will make use of materials, both digital and hard copy, in handbooks or guides, which are being prepared by the In-Between team. The intention in doing so is to ensure that these mate- rials are distributed and shown at every appropriate opportunity. The handbooks will consist of an introductory section on MG and PA as maltreatment, and their effects and include detailed sections on: the responsibilities of parents to their children, and on maladap- tive parental behaviors, which members of each profession are likely to see in their day to day work; the children particularly susceptible to alienating behaviors by one of the parents; and, the signs of dis- tress which a child may exhibit and may be associated with parental friction. For example, the rejection of the alienated parent may be overt, when a child tells a teacher that one of the parents is horrible or abusive, or that regular contact has stopped, but often the stresses of rejecting a previously loved parent can only be discovered from the child’s conduct – poor achievement, withdrawal, acting out, etc. The handbooks will also contain information and instructions, so that if alienation is suspected, the professionals will know how to go about bringing the problem to the attention of the parents, and how to persuade them to get help for the child in addition to advice on their parenting behavior, despite the problems they are experiencing in their relationship with one another. If the alienating behavior reaches the level of maltreatment such as to require immediate intervention, the relevant pro- fessionals will know the proper procedure to report to child protection or law enforcement agencies. To prepare these handbooks, we are conducting discussions with kindergarten teachers and their helpers, grade school teachers, high school teachers, principals, and school counselors and psychol- ogists to be able to develop instructional materials suitable for each age group of children and dif- ferent religious and social orientation of the pupils. Additionally, we are conducting discussions with family doctors and pediatricians, which will lead to instructional material for medical staff, including administrative and nursing staff, to assist them to identify patterns of parental behavior, and symptoms in children, that, if left unattended, might lead to PA. Child protection workers and police also need to have speciﬁc training. In cases where they are called to an incident where there is an allegation of violence or abuse by one parent, whether the alleged victim is a child or the other parent, they must be sensitized to the possibility that the allegation is part of a campaign of denigration and may lead to PA. Likewise, when PA is alleged, these workers must also be aware that there may have been violence or abuse, such as to make the actions of the par- ent trying to distance the child from the other parent, justiﬁable for the protection of the child. This requires great care, since it is reasonable to assume that the majority of complaints are genuine. How- ever, there should be an intensive effort to establish whether there have previously been unjustiﬁed complaints, and whether the family is known to be one where there is strife between the parents. Prosecutors and judges in the criminal courts who deal with cases where violence and abuse are alleged, need to be similarly warned of the possibility that a complaint is unfounded, against a background of the parents’disputes over the child. Juvenile court judges need to be aware that com- plaints of neglect and abuse may arise against a similar background. We are working on handbooks for these personnel as well. 2. Lectures, Workshops, Courses Members of the In-Between team are lecturing at seminars and courses for professionals in many ﬁelds. For example, at a seminar for nurses working in emergency rooms, as well as describing PA 548 FAMILY COURT REVIEW and its results, we were able to show the nurses examples of MG, including heated discussions, bor- dering on aggression, between the parents in the presence of the sick child. The Early Childhood Center in Kiryat Gat in southern Israel held a day seminar on PA for all of those working with pre-school and primary school children: parenting counselors, child develop- ment experts, kindergarten teachers and helpers, psychologists, welfare ofﬁcers and social workers, special needs experts, and community workers. At the seminar, members of the In-Between profes- sional guidance group presented material on the effects of divorce on children and on the prevention of PA. C. PROMPT INTERVENTION Early identiﬁcation is not enough to ensure prompt attention to the issues which arise; it is for this reason, that the handbooks and guides will include a protocol for inviting parents to discuss the needs of the child in a way which is appropriate to the speciﬁc child, the responsibilities of the par- ents to the child, and the legal and ethical aspects of such a discussion. There will also be guidance for referral of the parents and the child to appropriate agencies, for treatment of the child and psycho-didactic interventions for the parents. To this end, In-Between has set up support and guidance centers in two local authorities in Israel, in the city of Holon, and in the HaSharon Coast area authority, which serve children, as well as separating and divorced parents. In addition to providing parenting seminars, these centers are centrally placed and offer immediate thera- peutic advice and intervention, at subsidized rates, for children and adolescents, and their parents. One of the objectives of the In-Between support and guidance centers is to show how essential it is that existing social services agencies develop a fast-track intake and intervention service speciﬁcally for cases where the situation gives rise to the suspicion that the child is being subjected by one parent to indoctrination against the other parent. In such cases, time is of the essence; although indoctrination has built up gradually and reaches a critical level, without the other parent being aware that it is hap- pening, a child may turn against a parent and stop all contact without advance warning. Once children reject a parent, the situation may be irreversible. For this reason, as soon as parents are referred, there should be an immediate intake and decision as to whether, and what type of intervention, is necessary. Should it be deemed necessary, such intervention should be available within days of the referral. It may be objected that social services are already over-stretched because of low budgets and shortage of manpower. The answer is clear; a family whose issues are addressed early on will require far fewer resources than the family would, without prompt attention, need later on.10 For example, when the court asks social services to provide a report on the family during legal proceed- ings in the Family Court, a social worker will, on average, spend thirty hours interviewing family members and others, preparing the report, and then may additionally spend several more hours if summoned to court to be questioned as to the report. That same social worker, who would be assigned to intake and immediate intervention, would succeed in removing the threat of alienation in many cases, perhaps with only a few hours of work. In this way, the mental health professional would not need to spend thirty hours preparing a report. This would also prevent the need for court proceedings and prevent the huge economic costs to the state which would be incurred if PA were to become established. III. TERTIARY INVOLVEMENT: EFFECTIVE JUDICIAL AND MULTIDISCIPLINARY ACTION A. SWIFT AND EFFECTIVE JUDICIAL INTERVENTION While there is room for optimism that the primary and secondary measures described thus far will be effective in preventing many, even most cases of marital strife from deteriorating into PA, Marcus/ISRAELI RESPONSES TO PARENTAL ALIENATION 549 the effectiveness of such measures is bound to be uneven, at least in the early stages of implementa- tion. The alienating parent often manages to manipulate situations to their advantage; the other par- ent is often unaware of what is happening until it is very late; the child is more and more convinced of the rightness of the rejection as time goes on. Thus, some families will continue to reach the stage where effective and authoritative steps need to be taken to ensure: continued contact where it has not yet been completely severed; reestablishment where contact has completely broken down; and that children receive intensive help to enable them to put relationships back on a proper basis, by insisting that both parents take part in such treatment given these are family, not individual problems. Experience in a number of jurisdictions suggests intensive “reuniﬁcation programs” used after custody reversal for the rejected parent and child to restore a relationship, while effective in some cases, are very expensive, and may have side effects which may be undesirable.11 This is partially due to the fact that they are ordered by the court only after long drawn out adversarial proceedings. While these proceedings are going on, the alienating parent beneﬁts from the continuing absence of contact between the child and the other parent. By the time the outpatient or intensive family ther- apy intervention occurs, the alienation may be too severe to be responsive to intervention. In addi- tion, the most commonly used approach with severe cases of alienation requires a reversal of custody and an interim cessation of contact with the formerly alienating parent for several months, and may have other undesirable effects. The child loses the stability, albeit unhealthy, experienced before with the favored parent. The child’s relationship to the formerly rejected parent and other family members may be restored. However, the relationship with the alienating parent is often lost in those cases where, even though the intervention is designed for their participation so as to restore co-parenting after the child’s refusal of contact with the rejected parent has been overcome, the pre- viously favored parent chooses, unwisely, not to participate in the program. This leads to the conclusion that court proceedings, where alienation or abuse or violence is alleged, must be swift and effective. Adversarial proceedings between parents are always damaging to the children, as are the accompanying uncertainty, the parents’ preoccupation with the proceed- ings, and the expenses of time and money which take away from the parents’ ability to focus on the child’s developmental needs and economic welfare. All of these require judicial authorities to take account of the needs of the child and reduce to a minimum the time taken between the ﬁling of alle- gations and effective decisions.12 In addition, decisions must be resolutely enforced. Doing so requires that the judge receive fre- quent reports as to compliance or non-compliance with contact and treatment orders. Non- compliance must be met with sanctions for contempt of court, including ﬁnes and even imprison- ment. Even the most recalcitrant alienating parent is likely to comply if faced with the alternative of a period of imprisonment, during which the child will be with the other parent. B. THE ROLE OF LAWYERS Although all advocates are entitled to appear in the family court without the need for additional qualiﬁcations, in most jurisdictions there is a well-established cadre of lawyers who specialize in family law. Needless to say, not all of them have a therapeutic approach to the profession. As in all countries, in Israel there are those who foment strife rather than encourage their clients to try to reach an agreed resolution, by mediation, collaborative divorce, and other non-adversarial methods. This augurs ill for the children of those clients. However, the Israel Bar Association has taken the initiative. We have spoken at well-attended seminars for family lawyers, organized by the IBA, exposing them to the damaging effects of PA and the legal remedies available to the alienated parent if no other resolution is possible. Family lawyers need to be made aware of the possibility that their adult client may be the victim of, or the perpetrator of, MG or PA. The client may be unaware of the signs of PA: red ﬂag behav- iors by the other parent, or that their child is starting to speak or behave in a way that is not only 550 FAMILY COURT REVIEW attributable to the “normal” stresses of parental disharmony. The duty of the lawyer does not begin and end with being a megaphone for what the client wants. A competent lawyer has an ethical responsibility to the children of his client and to ensure they come to no harm as a result of the law- yer’s acts or omissions. The lawyer must bring these matters to the attention of the client. If the client is, or is about to be alienated, then the lawyer must act immediately to warn the alienating parent to stop any maladaptive behavior. If it does not cease immediately, the lawyer must then apply to the court for the relevant orders to be made, for injunctive relief, for instruc- tional interventions, and for treatment of the child and family members. For this reason, lawyers taking on cases involving children must be conversant with the professional literature on PA, so that they will appreciate the dangers if PA is not stopped, the urgency of initiating proceedings, and what relief to seek. They need to be able to place the relevant research material before the court. Also, where it appears that the client is exhibiting alienating behaviors, knowingly or unknow- ingly, the lawyer must warn the parent about the potential damage to the child; in other words, they must warn that the parent is guilty of maltreatment of the child, that in many cases an alien- ated child will realize that he/she has been manipulated, and will sooner or later reject the alienat- ing parent. If alienation is proven, this may lead to radical changes in residence and contact arrangements, including an order that the alienating parent’s contact with the child, who will now live with the other parent, may only take place under supervision. If a client continues to engage in alienating behavior that is harming a child, the lawyer must cease to represent that client,13 and, where mandated, should report to child protection authorities if they are not already involved. C. THE ROLE OF JUDGES There is an increasing appreciation of the central role that judges need to play in preventing PA, or at least in ameliorating its effects. Educational activities for judges are essential, so that they will not allow long drawn-out proceedings, as if cases involving children are ordinary civil cases. This requires: Drastically shortening the time for ﬁling pleadings and afﬁdavits; Zero tolerance for time-wasting by litigants and lawyers, including unjustiﬁed applications for deferral of due dates and of hearings; Sufﬁcient familiarity with the literature on failure of contact between a child and a parent, to avoid being drawn into unnecessary debates on the existence of PA, or whether or not it is a “syndrome,” and whether all the criteria are present.14 An appreciation that there are some situations, for example of egregious maltreatment of the child or the resident parent by the rejected parent,15 or of behavior of the non-resident parent towards an older adolescent close to adulthood,16 such that no beneﬁt to the child can be expected from restoration of contact and contact refusal is justiﬁed; Understanding that a rejected parent may often exhibit anger, frustration, and aggression in court, that an alienating parent may be calm and cooperative, at least on the surface, and that these emotional states may not be indicative of the personalities of the parents and their parenting abilities or styles. Understanding that the existence of PA does not rule out the possibility that there has been intimate partner violence or child maltreatment,17 together with familiarity with the situa- tions in which abuse is falsely alleged in order to justify cessation of contact18; and an appreciation that the existence of IPV or child abuse and neglect do not always justify complete cessation of contact. Sufﬁcient knowledge about the types of parents who deliberately or by negligence encourage a child to break off contact with the other parent,19 including those with mental or personality Marcus/ISRAELI RESPONSES TO PARENTAL ALIENATION 551 disorders, those with weak or non-existent understanding of the need for boundaries,20 and those who fail to override children’s unjustiﬁed decisions about contact,21 etc. The importance of framing decisions for contact in such a way as to prevent the manipula- tion by those ordered to comply: precision as to the dates and times for performance of each action, with stated sanctions for non-compliance, and requiring frequent reports by the parties and those overseeing contact or providing treatment; The importance of clarity and precision in framing decisions for treatment, which should include the following22: the identity of the person to provide therapy, the goals of treatment, including intermediate stages, the dates by which treatment shall start, which family members must participate, discretion of the therapist to decide on types of treatment, including the power to see the parents separately and the child with or without parents, extent of involvement of lawyers (including whether they may or shall or shall not receive information while the treatment is in progress), requiring the parents to allow therapists to obtain information from others (including therapists for either parent, school personnel, medical and mental health profes- sionals, etc.), limits of conﬁdentiality, who is responsible for payment of fees, sanctions for non-compliance with therapy, and non-payment of fees, requiring frequent reports to the court by those conducting therapy. As we have seen, orders of the court in such cases should be given the widest possible publicity (without, of course, giving any information that may identify the child or the parents), to play a part in the primary prevention efforts described in Part One. D. THE ROLE OF SOCIAL WORKERS, PSYCHOLOGISTS AND OTHER PROFESSIONALS Social workers and psychologists play an essential role in family litigation. Judges need input from well-qualiﬁed and experienced professionals who have specialized training that allows them to understand the dynamics of the family concerned as well as the social and psychological effects of the dispute, of the high conﬂict co-parenting, and of the court process on all participants involved, beyond the pleadings of the parties and the evidence in the case. This is especially the case where a child is involved and there is a possibility that there is MG and PA. The involvement of court social services in Israeli Family Courts is described in a recent article.23 E. THE TEL AVIV FAMILY COURT PILOT SCHEME AND THE CENTRAL DISTRICT FAMILY COURTS INITIATIVE – INTRODUCTION It is with the realization that the court has a crucial role in preventing or at least mitigating the effects of MG and PA that a pilot scheme is currently being carried out in the Tel-Aviv-Jaffa Fam- ily Court, and an initiative has been instituted in the Family Courts in the Central District. Before describing the schemes, a few words are necessary about the Family Court system in Israel. The Family Courts in Israel were set up under legislation in 1995.24 The principles on which they were founded include: A specialist court, with jurisdiction in all family matters25 (except dissolution of marriage (i.e. the divorce itself), which is in the exclusive jurisdiction of religious courts); 552 FAMILY COURT REVIEW Specialist judges who, in order to be appointed, are required to have knowledge and expe- rience in the family law ﬁeld26; Accessibility – the courts are located in most population centers27; An in-house social services unit, which assists the litigants and the court28; Broad discretion of the judge in matters of procedure and evidence, including the power to require the Legal Aid Ofﬁce to appoint a lawyer for the child29; The power to give any order which may be necessary to ensure the welfare of a child, even when such an order has not been requested, subject only to both parties being given an opportunity to make submissions about the order proposed30; Availability of legal aid for litigants with low income, as well as for children31; Expert witnesses appointed by the court, not by the parties, and are chosen from a list of experts with proven knowledge in the ﬁeld, and a cap imposed on the fees they may charge32; Arrangements for hearing the views of a child whose interests may be affected by the proceedings.33 Family court judges are required to attend topic-related residential seminars every year to ensure that they are up to date with academic and therapeutic issues. Judges of the religious courts, Jewish, Muslim, Druze and Christian, who also have jurisdiction in cases involving children, also hold in- service training seminars, and over the years there have been successful joint seminars for all judges who deal, in the various courts, with family matters. F. THE TEL AVIV PILOT SCHEME In the light of an increasing appreciation that PA cases take up an inordinate amount of court time, and that even when PA is established after a trial and judgment, the effectiveness of the judgment in changing the child’s rejection of a parent is minimal, the Judge in charge of the Tel-Aviv-Jaffa Fam- ily Court initiated a fast track process. The underlying principles are that parental alienation can cause severe harm to the child, that with every day that passes without contact between the child and the parent, the prospects of reconciliation become more remote, that a parent who prevents contact or fails to act to restore contact is acting unlawfully, and that in cases ﬁled in which one of the parents alleges PA by the other, the matter should be handled as an emergency. As in a case where violence is alleged in the family, the resources of the court, including the court social services unit, need to be harnessed for a swift determination of the question if there is a need for interim measures.34 Such cases are diverted to a designated judge, or dealt with by the judge to whom the family is assigned, who makes immediate orders for a response to the allegations of alienation, violence or abuse. Regardless of the main petition which may be for custody, visitation, or other matters relat- ing to a child, the judge ﬁxes a hearing, usually within 14 days of the ﬁling of the application for contact, which both parents must attend, and refers the case to the court social services unit for an initial assessment. If it appears necessary, the court may also appoint counsel for the child. 1. The Questions At the hearing, if there is no agreement about reestablishing contact and/or for treatment, the court makes an immediate decision after hearing the parents and their lawyers, based on the answers to the following two questions35: 1. Is the child in contact with both parents? 2. If the child is not in contact with one of the parents, why not? Marcus/ISRAELI RESPONSES TO PARENTAL ALIENATION 553 G. THE CENTRAL DISTRICT INITIATIVE The judges of the Family Courts in the Central District came to the same conclusions: that unjustiﬁed failure of contact between a child and a parent causes severe damage, and that where a court is presented with an allegation of PA, this must be dealt with swiftly, as an emergency. The method by which such applications are expedited, however, is somewhat different. In the Central District scheme, where the judge dealing with the case becomes aware of an allegation of PA, the parent making the allegation is required, within seven days of the order, to complete a ques- tionnaire including details of the relationships in the family and a description of the contact, past and present, and any problems with contact between the child and the applicant. The questionnaire is attested as an afﬁdavit. The applicant is additionally required to give a written undertaking to pay any legal costs which may be awarded to the respondent and/or the State treasury, in the event that the application is found to be baseless, as well as to have a third party give a guarantee for payment of the costs. If the applicant’s questionnaire-afﬁdavit and guarantees for costs are duly ﬁled, the judge ﬁxes a hearing within seven days, and orders the respondent to ﬁle a response, in the form of a question- naire afﬁdavit with the same information as that of the applicant, not later than three days before the hearing. If the applicant fails to ﬁle the required documents, the application is deemed to have been withdrawn and the case will be handled as a regular case; if the applicant ﬁles and the respon- dent fails to do so, the expedited hearing will take place and orders made on the basis of the appli- cation alone.36 H. THE ISRAELI INITIATIVES: HOW THEY WORK 1. The Burden of Proof The burden of proof that there is a plausible reason for lack of contact is on the parent who has primary care. This is a heavy burden, being that the parent must satisfy the court that the reason for lack of contact is egregious abuse by the rejected parent of the child or another close family mem- ber, or rejection of the child by the applicant who alleges PA. The shifting of the burden of proof is one of the central innovations of this system; the underlying assumption is that a child will beneﬁt from contact with both parents. It is often very difﬁcult for the rejected parent to prove that the other parent has alienated the child, or has failed to override the child’s reluctance to have contact. The child’s expressed reluctance or opposition is not, of itself, a convincing reason: if it were, the alienating parent would beneﬁt from their own wrongdoing, having persuaded the child that the other parent is evil/dangerous/mad, etc., and then relying on the reluctance to avoid contact or ther- apeutic intervention.37 2. Orders with Sanctions for Non-compliance In the absence of plausible reasons for lack of contact, the court will immediately make orders for contact, including the use of a contact center, or other forms of supervision where this is neces- sary, and for therapeutic interventions with the child, including the name of the therapist and orders for payment of fees,38 in order to enable them to enjoy normal contact with the previously rejected parent and their family. In the event of non-compliance, a court can impose sanctions on the parent who is in breach of the order of the court. Non-compliance may be failure to bring the child to the place designated for contact or to the therapist for treatment, at the time set out in the court decision, failure to pay the therapist, or the breach of any other part of the court’s order. These sanctions may include: Fines, under the Contempt of Court Ordinance, to be payable to the court treasury, for each time the order is breached.39 These ﬁnes can be on a rising scale, such that a 554 FAMILY COURT REVIEW relatively small ﬁne is imposed for the ﬁrst breach, but so that the amount is doubled or tripled for each subsequent breach. Payment of compensation to the other parent for wasted time in waiting for the child,40 and/or to the therapist for the time wasted.41 Reduction of child support.42 Imprisonment for contempt of court43; the length of imprisonment may be on a rising scale starting with two or three days and increasing with every breach. In a case where it is appropriate, the child may be placed with the previously rejected parent while the alien- ator is in prison; in any case, the child will not be under the inﬂuence of that parent. Moving the child to live with the alienated parent,44 with or without banning contact with the alienator. Referring the case for investigation by the child protection authorities and declaring that the child is in need of protection.45 Where the parent involves the child in proceedings, by bringing him to testify in court or make an afﬁdavit to be used in evidence: dismissal of the parent’s claims and ordering payment of court costs for abuse of the process of the court.46 Ordering non-compliant alienating parent to pay the other parent’s legal fees and court costs,47 and/or to pay the costs of wasted court time to the court treasury.48 Requesting that police open an investigation on the basis of the criminal offence of breaching a court order.49 Experience shows that in many cases the threat of sanctions is sufﬁcient to persuade the alienat- ing parent to comply with the orders of the court, even if he or she does not appreciate the gravity of the alienating behavior. I. THE EFFECTS The impact of the expedited management of cases in which PA is alleged has been signiﬁcant. The primary achievement is that children do not have to wait many months, or more, for a determi- nation if there has or has not been PA. The period in which parents are litigating is exceptionally hard on children, in the sense that the parents are ﬁghting over them instead of attending to their needs. Litigation is a drain on parental time, energy, and resources, precisely at a time when chil- dren need more attention because their home is in a state of instability. Where one parent is trying to inﬂuence a child directly or indirectly, consciously or unconsciously, to cut off all contact with the other parent, and even more so when the child has already cut ties, the length of time taken to resolve the issues between the parents contributes to the emotional damage suffered. As stated above, the length of the proceedings is, by the new procedures adopted (which have not necessitated any legislative changes – only changes in the way in which cases are managed within the existing framework of laws and rules of procedure), sharply reduced. This achievement is due to immediate consideration of the central issue – is there or is there not PA – and giving orders (and enforcing them) soon after the start of proceedings. The “traditional” way of handling such proceedings was no different from any other civil case: the ﬁling of a statement of claim, and then of a defense within 30 or 45 days of service of proceedings on the defendant (and all kinds of excuses are given for delaying ﬁling the defense, especially “negotiations between the parties towards a settlement” or “ongoing mediation”50). After that, the court will ﬁx a pre-trial hearing, where any procedural application will be heard; a report may be requested of the local authority social services, which may take many months to arrive; or there may be an application to appoint an expert to deliver an opinion – even though the court appoints the expert, there is ample room for disputes as to the identity of the expert and who pays their fees – which may be delivered after sev- eral months. It is only then that a trial is ﬁxed, which may be several more months in the future. At trial (more applications for deferrals may be ﬁled) there may be days of oral testimony; and then Marcus/ISRAELI RESPONSES TO PARENTAL ALIENATION 555 the judge will ask for summations in writing – more room for applications to extend time – and then judgment will be given, several months or over a year after the ﬁrst application is ﬁled. Even if applications are ﬁled for interim orders, in the ordinary course of events the defendant will submit that any interim order would prejudge the issues in the case. In the meantime – there has been no contact between the child and the alienated parent. The alienation strikes deeper roots, and may spread to siblings who have previously had contact with the alienated parent and/or with the alien- ated parent’s wider family. Children experience time differently from adults, and an alienating parent will often take advantage of this, telling the child that the alienated parent does not love the child. As we have shown, sometimes the allegation of alienation by a rejected parent is found to be unjustiﬁed, either because the person alleging it is responsible for the absence of contact (whether by egregious maltreatment of the child or a close family member by the alleging parent or failure to take advantage of contact arrangements without involvement of the other parent), or, because the allegation is made without justiﬁcation, as a tactical answer to allegations of child abuse or partner violence by the so-called alienating parent. Even in these types of cases, the advantage of the short- ened procedure is marked, not only because of the brief time lapse between allegation and determi- nation, but also because the court is able in short order to establish the true issues and the personalities of the parents involved. This is also the case when both parents bear some responsibil- ity for the absence of contact. An additional contribution of the pilot program has been extensive attention in the media, both because the procedure is new and swift, and because the penalties threatened and imposed on alien- ating parents are unusual in their severity. In this way, perhaps paradoxically, effective tertiary atten- tion to the phenomenon assists in primary prevention 1. Interdisciplinary Collaboration The pilot scheme, and indeed any program for effective action to limit the damage of PA, requires collaboration between professions. As we have seen, the court calls on the services of social workers, psychologists and other mental health professionals to examine, diagnose, and treat PA, or to determine that it does not exist. The court calls on the assistance of lawyers to represent the children involved. In this way, prompt and decisive judicial action, making full use of professionals in other ﬁelds, even at the late stage when legal proceedings have been issued (meaning that primary prevention and secondary identiﬁcation and interventions have not happened or have not been successful) will prevent further deterioration and ensure that the situation is dealt with immediately and effectively. The expedited procedure places cases where PA is alleged in a proper frame that is appropriate to the urgency of the case and the increasing severity of the damage if the matter is not dealt with swiftly. As needed, qualiﬁed and experienced professionals in many ﬁelds are at the disposal of the court. IV. CONCLUSION From widespread concern about the results of PA, and efforts to treat it when it has happened, the need for prevention becomes clearly apparent. Prevention of the phenomenon itself requires public awareness of what PA is (and how to distinguish it from other reasons for contact failure, such as abuse and neglect in the family, when separation of the child from an abusive parent may be necessary and justiﬁed) and what its effects are on the child. Professionals in ﬁelds working with children and their parents must be aware of their critical roles in identiﬁcation of the signs of incipi- ent and actual PA. The authority of the court to recognize PA, and so far as possible to nip it in the bud, requires lawyers familiar with the issues and judges who are specialists in the ﬁeld, with access to other professionals who will take part in framing and carrying out the orders of the court. 556 FAMILY COURT REVIEW This requires training in the respective professions, and familiarization of workers in each profes- sion with the abilities and methods of members of the other professions. This is true generally, but the way in which we deal with PA also requires local alliances, so that the individuals concerned know each other’s working procedures and expectations. In this spirit, In-Between has set up centers for multidisciplinary work with children of divorce and their parents. The working assumption is that early intervention will help parents and children to minimize the damage and suffering caused by the breakup of families, and thereby substantially save on budgets for social services, mental health interventions, etc. As pointed out above in the section on prompt intervention, the ﬁrst two centers are already operating, and, on the basis of their work and experience, it is hoped that more centers will be set up so as to provide nationwide coverage. Practical programs for prevention of PA are up and running in many ﬁelds, and under develop- ment in several others. Hopefully, programs of this kind can be developed in each country, adapted, of course, to the legal and judicial frameworks and the services available (or which need to be developed). The programs will include professional training of all those who are involved in dealing with children, so as to provide comprehensive services for prevention, early identiﬁcation, and timely and effective intervention where PA exists or is likely to develop. This article is dedicated to the memory of my beloved parents, the late Jack and Pearl Marcus. May their memory be a blessing. ENDNOTES 1. PHILIP MARCUS, FAMILY LAW AND FAMILY REALITIES, 16TH ISFL WORLD CONFERENCE BOOK 349–366 (Carol Rogerson et al. eds., 2019). 2. See QE52 Problem associated with interpersonal interactions in childhood, INT’L CLASSIFICATION OF DISEASES FOR MOR- TALITY AND MORBIDITY STAT., https://icd.who.int/browse11/lm/en#/http%3a%2f%2ﬁd.who.int%2ﬁcd%2fentity%2f901608346. 3. There are those who still contend that parental alienation does not exist, or that it has not been proven scientiﬁcally. This is the same as stating that a person complaining of a headache does not have a headache, or that it should not be treated, because the scientiﬁc basis for the headache has not been proven. 4. About In-Between, BALEV, http://balev.org/children-come-ﬁrst/. Work on many of the programs is being carried out by In-Between, an initiative of Topaz, an organization that leads social innovation. The goal of the initiative is “supporting chil- dren and families undergoing divorce and further on as they adjust to their new families.” The orientation of In-Between is multidisciplinary. Among its many other activities, In-Between has formed a PA prevention team, which at the time of this writing consists of: Ms. Michal Feffer, Director of In-Between, Dr. Inbal Kibenson Bar-On, Lecturer in Psychology at the University of Haifa, Family Therapist, Dr. Dorit Eldar, formerly director of Family Court Social Services; and the undersigned. 5. See, e.g., Gary M Ginsberg, Cost effectiveness of strategies to combat breast, cervical, and colorectal cancer in sub- Saharan Africa and South East Asia: mathematical modelling study, 344 BRIT. MED. J., (2012). 6. See Philip Marcus, Parental responsibilities: Reformulating the paradigm for parent–child relationships Part 1: What is wrong with the ways in which we deal with the children of separated parents and how to put them right, 14, J. OF CHILD CUSTODY, 83 (2017); See also Philip Marcus, Parental responsibilities: Reformulating the paradigm for parent–child relation- ships Part 2: Who has responsibilities to children and what are these responsibilities?, 14, J. OF CHILD CUSTODY, 106 (2017). 7. TOGETHER IN HAPPINESS, https://together-in-happiness.com (discussing a scheme to encourage young couples to attend pre-marital relationship seminars, by giving them incentives – in this case, a reduction in Income Tax). 8. See, generally JOAN T. KLOTH-ZENARD, WHERE DID I GO WRONG? HOW DID I MISS THE SIGNS? DEALING WITH HOSTILE PARENTING AND PARENTAL ALIENATION (LuLu Self-publishing, Kloth Consulting 2009) (2012). 9. Karen Woodall, Parental Alienation The Phenomenon Explained, YOUTUBE (March 16, 2019), https://www.youtube. com/watch?v=BdeFmHN23VQ (showing a presentation for the National Association of Alienated Parents (UK), aimed at school staffs, pointing to several issues which school staffers may experience, including, efforts by the alienating parent to draft in teachers and administrative staff to assist unwittingly in the program of alienation). 10. Philip Marcus, Economic implications of prevention and early intervention for parental alienation, in PARENTAL ALIENATION: SCIENCE AND LAW (Demosthenos Lorandos et al. eds. 2020), (discussing the economic costs of a situation when the child is alienated. These include: the costs of mental health services in view of the psychological and psychiatric damage to the child; the costs of lowered educational achievements of the child, including reduced earning capacity; the costs to gen- eral health services arising from epigenetic neurological damage to the child caused by excessive stress, and STDs, as a result of indiscriminate sexual activity, and drug and alcohol addictions as coping mechanisms; the costs of criminal processes, Marcus/ISRAELI RESPONSES TO PARENTAL ALIENATION 557 including police, probation services and prisons for children who act out; the costs of family court services, including judge time, secretariat, lawyers etc., where the cases are litigated in situations of high conﬂict; and costs of social services.). 11. Jean Mercer, Are intensive parental alienation treatments effective and safe for children and adolescents?, 16 J. CHILD CUSTODY 67 (2019). 12. Marcus, supra note 6, at 9–11. 13. Fam. (Nz) 10846–01-19 A.P. v S.S., (Nevo Legal Database, by subscrition, in Hebrew (hereinafter: Nevo) Nevo 5780 (2019) (Isr.) (holding that where a lawyer represents a parent, who insists on having the child who is the subject of proceed- ings testify in court or make an afﬁdavit to be used as evidence, then the lawyer must, in his role as ofﬁcer of the court, refuse to continue to act for the client.). 14. Most researchers and practitioners dispute the need to use the terminology of a syndrome, and prefer to identify the causes of the problem on a case-by-case basis. See B. J. FIDLER ET AL., CHILDREN WHO RESIST POST-SEPARATION PARENTAL CON- TACT (2013); STEVEN FRIEDLANDER & MARJORIE GANS WALTERS, When a Child Rejects a Parent: Tailoring the intervention to ﬁt the problem, 48 FAM. CT. REV. 98, 98–111 (2010). 15. Richard Warshak, Parental Alienation: Overview, Management, Intervention, and Practice Tips, 28 J. AM. ACAD. MATRIM. LAW. 181, 188 (2015) (“Some children have good reasons to reject parents who are grossly deﬁcient.”). 16. Fam. (TA) 45433–07-14, A.K. v. D.A.K., Nevo 5780 (2019) (Isr.) (explaining that the daughter was aged 17.5. Her refusal to meet her father, which had started a year earlier, was founded on his inability and lack of desire to understand her needs and sensitivity, as well as his self-centered attitude when meetings had taken place, without any of the blame attaching to the mother who had encouraged contact.). 17. Barbara Fidler & Peggie Ward, (2017). Clinical decision-making in parent–child contact problem cases: Tailoring the intervention to the family’s needs, in OVERCOMING BARRIERS AND OTHER CLINICAL APPROACHES: FAMILY-BASED INTERVENTIONS FOR CHILDREN’S RESITANCE, REJECTION, ALIENATION 13 (Abigail Judge et al eds., 2017). 18. File No. 792673 Rabbinical Court (Jer) Anon. v. Anon (Isr.); Fam. (CT) 58557/04–19, The Mother v The Father, Nevo 5780 (2019) (Isr.). 19. Fam. (TA) 49688–02-19, L.P. v G.P., Nevo 5780 (22 August 2019) (Isr.) 20. Fam. (Jer) 20386–05-16 P.G. v A.G., Nevo 5779 (2018) (Isr.) 21. Fam. (TA) 1503-02-18 N.T. v A.T., PS 5780 (2019) (Isr.). 22. See Fidler, supra note 17. 23. Philip Marcus, The Israeli Family Court –Therapeutic Jurisprudence and Jurisprudential Therapy from the Start, 63 INT’L J. L. & PSYCHIATRY 68, 68–75 (2019). The mission statement of Family Court Social Services includes the following objectives: to promote settlement of conﬂicts, to assist both the court and families in crisis, to act in the interest of all family members and of children in particular, to assist families in litigation to settle their conﬂicts outside the court, to help curtail the adversarial process, to address the emotional, personal and intra-personal needs of the litigant and his family, and to improve parenting skills. 24. Family Courts Law, 5755–1995 (Isr.) (hereinafter FCL). 25. See, e.g., Sec. 1 FCL. For example, in cases of defamation. Although this is a regular civil claim, where the parties are members of one family, and the claim arises from the family relationship, the Family Court has exclusive jurisdiction. See also Fam. (Nz) 30290/05–18 A.C. v A.C., Nevo 5780 (2019) (Isr.) (describing where the father sued the mother for false allegations of abuse of the child, drug use, etc., which she sent in letters to the welfare department and other organizations, in the context of a proven history of PA: the Family Court ordered the mother to pay compensation of 50,000 NIS with court costs of 7,500 NIS to the father.). 26. FCL §2(b) (Isr.). 27. FCL §2(a) (Isr.). 28. FCL §5 (Isr.). See also Marcus, supra note 23. 29. FCL §8(a) (Isr.). 30. Capacity and Guardianship Law 5722–1962, §68 (Isr.) (hereinafter CGL). 31. See Legal Aid Law, 5732–1972, §2 (Isr.); see also Legal Aid Regulations, 5733–1973, Reg. 5(1) (Isr.); Fam. (TA) 40394/02–19 M.P v. G.P. Nevo (5780) (2019) (Isr.) (explaining that the court requested appointment of a guardian ad litem for a 16 year old who was on the autism spectrum in the light of lack of contact with the father, for no convincing rea- son, for 3½ months.). 32. FCL §8(c) (Isr.); Rule 258 xxii, Civil Procedure Rules, 5744–1984 (Isr.) (hereinafter CPR). 33. Chapter 20 (2), CPR (Isr.). 34. As described in the cases referred to above and in what follows, many judges in other Israeli courts adopted speedy, effective approaches to PA cases. 35. “In order to justify a ﬁnding, from a legal point of view, … of parental alienation, … we need a ﬁnding that contact has ceased … and the absence of justiﬁcation…” Fam. (TA) 1503-02-18 Case TLHM N.T. v. E.T. Nevo (2019) (Isr.) 36. The Central District initiative is presented here as another example of expedited procedures, whose objective is expe- ditious handling by the court of cases in which PA is alleged. At the time of writing, the President of the Supreme Court, the Courts Administration and the Ministry of Justice, are composing regulations which will apply to all Family Courts and will incorporate provisions about swift and authoritative judicial action in cases where PA is alleged, on the basis of the Tel Aviv pilot and the Central District initiative. 37. Fam. (TA) 49688–02-19, L.P. v G.P., Nevo 5780 (2019) (Isr.) 558 FAMILY COURT REVIEW 38. The powers of the court under §68 of the CGL include the power to order a parent to cooperate in any matter needed in the child’s best interests, including consultations and treatment for the parent. 39. A ﬁne of 1000 NIS (about two or three days of average Israeli salary) was imposed on the mother in respect of each missed meeting of the children with the father: Case TMS Fam. (TA) 59564–12-18 H.C. v K.C. (Nevo) (2019) (Isr.) 40. Fam. (TA) Case TLHM 57367–12-18, M.C. v K.Y Nevo (2019) (Isr.) (the mother alleged that the father’s mental ill- ness made him dangerous to the child, and contravened contact orders. The court, on the basis of experts’ opinions, found no indications of danger, and ordered renewal of contact, with compensation to the father of 750 Shekels for each missed meet- ing with the child, and 15,000 shekels costs to be paid to the Legal Aid department which represented the father). 41. Fam. (Hi) Case TMS 2533-05-15 Re A.B. and others, D.B. v G.B. Nevo (2019) (Isr.) (Payment by the father of 3500 NIS to the expert for missed meetings, and similar amount to the state treasury). 42. Fam. (Jer) Case TLHM 65003–01-17 Anon. v Anon. Nevo (2019) (Isr.). 43. Fam. (Jer) Case RMS 55946–11-16 Anon. v Anon. Nevo (2019) (Isr.). 44. Fam. (TA) Case TMS 59564–12-18 H.C. v K.C. Nevo (2019) (Isr.). On 28 August 2019 the Supreme Court approved transfer of custody at the interim stage by the ﬁrst instance court, before trial of the custody action and before cross examina- tion of the expert witnesses, in light of the urgency and clear indications that the mother had not ceased her alienating behav- ior despite repeated orders and warnings: BAM 5451/19. Anon. v Anon. Nevo (2019) (Isr.). 45. Fam. (Nz) Case TNZ 27692–10-14, TMS 37506–06-13 Anon. v Anon. Nevo (2014) (Isr.). 46. Fam. (Nz) 10846–01-19 A.P. v S.S., PS 5780 Nevo (2019) (Isr.) 47. Fam. (CT) 58557/04–19, The Mother v The Father, Nevo 5780 (2019) (Isr.). 48. Id. 49. Sec. 278, Penal Law 5737–1977; Case PLA 187438/13, referred to in Fam. (TA) Case YS 21954–06-19, Z.H.D. v G. H. Nevo (2019) (Isr.) 50. A determined alienating parent, who is aware that the length of zero contact plays into his hands, will utilize these, as well as other excuses, whilst at the same time extending his manipulation of the child and of the court system. Philip Marcus was born and educated in England. He moved to Jerusalem in 1978 where he practiced family law. He was appointed as a Judge of the Jerusalem Magistrates Court in 1995 and served as a Judge of the Jerusalem Family Court from its opening in 1997 until his retirement in 2012. Since retiring he has written numerous articles on parent–child relationships, parental alienation, therapeutic jurisprudence, testamentary capacity and guardianship of persons with disabilities. He is an expert consultant on Family Law legislation to the committees of the Knesset, Israel’s parliament. He is a member of the professional advisory committee of In Between, an Israeli initiative to advance the interests of children whose parents have separated. He has spoken and presented workshops on Family Law, including Child Law and on Family Courts, on ﬁve continents. Marcus/ISRAELI RESPONSES TO PARENTAL ALIENATION 559