FST-FA-17-5016797-S :: SUPERIOR COURT

JENNIFER DULOS :: J.D. OF STAMFORD/NORWALK

V. :: AT STAMFORD

FOTIS DULOS :: SEPTEMBER 3, 2019

DEFENDANT’S REPLY TO INTERVENOR’S RESPONSE TO DEFENDANT’s

MOTION FOR PSYCHOLOGICAL EVALUATION OF GLORIA FARBER,
PENDENTE LITE

1. In the last 24 months, Mr. Dulos has been examined by a Ph.D. level, licensed
psychologist, Dr. Humphrey, and a court appointed, board-certified licensed psychiatrist, Dr.
Herman1.
2. The psychologist assessed and provided court-ordered therapy to Mr. Dulos and met
with him approximately twenty times.
3. The psychologist administered the Personality Assessment Inventory (PAI) to Mr.
Dulos in connection with his assessment.
4. According to its author, the PAI is an objective inventory of adult personality that assesses
psychopathological syndromes and provides information relevant for clinical diagnosis,
treatment planning, and screening for psychopathology.2

1
Dr. Herman in Board Certified in Pediatrics, Adult Psychiatry, Child & Adolescent Psychiatry and Forensic Psychiatry. His meetings with Mr.
Dulos are related to a court-ordered custodial evaluation that he performed. As such, the content of the sessions with Dr. Herman is not
privileged.

2 The clinical scales measure the respondent's psychopathology using diagnostic categories that were judged by the developers to be
relevant based on their historical and contemporary popularity among psychologists. Each clinical scale (except Alcohol Problems and
Drug Problems) represents a particular trait, and each scale has sub-scales that represent more specific aspects of that trait.
• Somatic concerns (SOM) measures a respondent's physical concerns and complaints.
• Anxiety (ANX) measures a respondent's general feelings of tension, worry, and nervousness.
• Anxiety Related Disorders (ARD) measures more specific anxiety symptoms that relate to different categories of anxiety disorders.
• Depression (DEP) measures a respondent's general feelings of worthlessness, sadness, and lethargy.
• Mania (MAN) measures a respondent's level of high energy and excitability.
• Paranoia (PAR) measures a respondent's suspiciousness and concern about others harming them.
• Schizophrenia (SCZ) measures a respondent's unusual sensory experiences, bizarre thoughts, and social detachment.
• Borderline features (BOR) measures a respondent's problems with identity, emotional instability, and problems with friendships.
• Antisocial features (ANT) measures a respondent's level of cruel/criminal behavior and selfishness.
• Alcohol Problems (ALC) measures a respondent's problems with excessive drinking.
• Drug Problems (DRG) measures a respondent's problems with excessive recreational drug use.

Treatment consideration scales

 5. The psychologist determined that Mr. Dulos’s responses to the PAI were valid patterns,
and, as such, would be considered reliable.
6. The scoring on the PAI did not find ANY elevations on any clinical scales or subscales.
7. Accordingly, no psychopathology was detected.
8. The testing also indicated that Mr. Dulos presents as a gregarious and confident person.
9. Additionally, Mr. Dulos met with Dr. Herman on fourteen occasions, the results of which
are summarized in a sealed report dated April 24, 2019.
10. If Ms. Farber is intent on proceeding with a psychological evaluation as indicated in her
response to Defendant’s Motion for a Psychological Evaluation, Mr. Dulos would, subject to
language agreed to by each parties’ counsel, propose the following:
a) Ms. Farber having access to Dr. Herman’s entire report, including his notes from sessions
with Mr. Dulos;
b) Ms. Farber and the Court having full access to Mr. Dulos’s psychologist’s file and the
testing performed by such psychologist (i.e., the PAI); and
c) Mr. Dulos and the Court having full access to Ms. Farber’s various treatment providers
and the associated records.

DEFENDANT:

By:/s/ 418682 Rich Rochlin___

Richard Rochlin
Rich Rochlin Law Group
10 North Main Street
Suite 304
West Hartford, CT 06107
V: 860-357-5003

The treatment consideration scales measure factors that may relate to treatment of clinical disorders or other risk factors but which are
not captured in psychiatric diagnoses.
• Aggression (AGG) measures the respondent's different kinds of aggressive behaviors toward others.
• Suicidal ideation (SUI) measures a respondent's frequency and severity of suicidal thoughts and plans.
• Nonsupport (NON) measures how socially isolated a respondent feels, and how little support the respondent reports having.
• Stress (STR) measures the controllable and uncontrollable hassles and stressors reported by the respondent.
• Treatment rejection (RXR) measures certain attributes of the respondent that are known to be related to psychological treatment
adherence, including motivation, willingness to accept responsibility, and openness to change and new ideas.
Interpersonal scales
The interpersonal scales measure two factors that affect interpersonal functioning for the respondent. They are based on the circumplex model of
emotion classification.
• Dominance (DOM) measures the degree to which a respondent acts dominant, assertive, and in control in social situations.
• Warmth (WRM) measures the degree to which a respondent acts kind, empathic, and engaging in social situations.
F: 860-218-9659
rich@richrochlinlaw.com
 CERTIFICATION

Pursuant to Connecticut Practice Book §§ 10-12 through 10-17, inclusive, the undersigned
certifies that a copy of the foregoing motion was mailed, postage pre-paid, via USPS First Class
Mail, and/or electronically delivered, via electronic mail or facsimile, on SEPTEMBER 3, 2019
to all counsel and self-represented parties of record, and that written consent for electronic
delivery was received from all counsel and self-represented parties of record who were
electronically served:

Rubin Midler, Esq.

Effron Wayne D. PC
P.O. Box 5237
Greenwich, CT 06831
FAX: 203-622-4004

Meehan Law
76 Lyon Terrace
Bridgeport, CT 06604
FAX: 203-331-0107

Pullman & Comley

90 State House Square
Hartford, CT 06103
FAX: 860-424-4370

Norm Pattis (via email)

_____/s/ 418682 Rich Rochlin______________________