Trapp v Vonne (2009) 41 Fam LR 471
A mother issued a subpoena to obtain documents from an agency that had provided family counselling for her husband and herself. The mother reported that a counsellor had described the husband as a sex and pornography addict and as emotionally dysfunctional, and the mother wanted access to files to provide evidence that the husband had made these admissions. The mother wanted to protect their children from being placed in a position of risk of emotional and psychological harm when in the care of their father.
The appeal judge ruled that the subpoena be struck out.