Wednesday, August 21, 2019

Can A Suspect Be Interviewed Without Legal Representation?

Can A Suspect Be Interviewed Without Legal Representation? A suspect is in custody for robbery and the OIC wants to interview him as soon as possible without legal representation. The custody officer declines this request and a solicitor is brought to the police station. During questioning, it became necessary, in order to clarify the interviewees account, to pose questions which had already been asked. The solicitor argued that this is not permitted. There is then a break in the interview and when it is re-commenced the solicitor reads out a pre-prepared statement. Consider the above paragraph and paying particular regard to legislation, case law and the PACE Codes of Practice comment and critically evaluate under what circumstances can a suspect be interviewed when legal representation has been withheld. Secondly whether the solicitor is correct in his assumption that questions which have already been posed cannot be repeated. Thirdly the dangers for the defence in submitting a pre-prepared statements. Word Limit 2500 Word Count 2415 Circumstances under which a suspect can be interviewed when access to legal advice is withheld: In order to look into circumstances in which a suspect can be interviewed in the midst of delayed legal advice access, the criteria which must be met to make this delay must first be explored. The relevant legislation which governs the delay of legal advice comes from s.58 of the Police and Criminal Evidence Act 1984(PACE), in particular part (6) of the section, which states; Delay in compliance with a request is only permitted (a) in the case of a person who is in police detention for a serious arrestable offence; and (b) if an officer of at least the rank of superintendent authorises it. The request, for the purposes of this section, is a request to have legal access delayed for the suspect. The legislation is succinct; however, the codes of practise which need to be followed in order to successfully prevent legal advice from attending the interview, presents an officer of rank equal to or higher than superintendant, with a number of criteria which must be fulfilled before the delay is granted. Failure to follow these codes could bring the relevant officers up for disciplinary proceedings. Such failure occurred in the case of R v McGovern  [1]  , where the defendant was of limited intelligence and was unable to understand the caution. She was denied legal advice, and as such the subsequent confession she made was not admissable in court. Following from this breach of s.58 PACE, the second interview in which she was granted legal advice resulted in a confession. However, the conduct in the first interview was deemed to have tainted the second, and so this confessi on was also denied. Delay can only be made for a time period of up to 36 hours, after which legal advice must be granted, regardless of circumstances.  [2]   Under Annex B(Para.1) of PACE, there are 4 criteria from which an officer must find good reason to request a delay; Failing to exercise the delay would: (i) lead to: à ¢Ã¢â€š ¬Ã‚ ¢ interference with, or harm to, evidence connected with an indictable offence; or à ¢Ã¢â€š ¬Ã‚ ¢ interference with, or physical harm to, other people; or (ii) lead to alerting other people suspected of having committed an indictable offence but not yet arrested for it; or (iii) hinder the recovery of property obtained in consequence of the commission of such an offence  [3]   Specific circumstances must be in place to delay access to a solicitor, and there must be clear evidence that the solicitors presence will result in one of the four criteria above occurring. This was the case in R v James Ors  [4]  , where confessions were obtained whilst in the absence of legal advice. The court heard that there was no specific evidence with regards to the unlawful conduct under part (ii) (above), of the individual solicitor, and that, with regards to the decision making process in passing this delay the number of times that a police officer could genuinely be in that state of belief will be rare. Furthermore, the suspect must not have been charged with the offence  [5]  , before the delay can be enforced. This was the case in R v Samuel  [6]  , where the original conviction was quashed on the basis that at the time of the interview of the defendant, at which the presence of a solicitor was denied, there had already been a charge of the offence. In addition to this, and in relation to the criteria above, it was deemed that access to a solicitor could not be denied simply by the belief that access might lead to other suspects in connection with the offence being alerted; the probability had to be high. A well-referenced quote was made in this case, from Hodgson LJ, which stated that entitlement to free legal representation was one of the most important and fundamental rights of a citizen. Equally, a breach of s.58 PACE does not always result in a quashed conviction. In R v Alliadice  [7]  , the grounds for refusal of legal advice for an interview included the worry that the solicitor may inadvertently warn other persons linked with the offence. The appeal against conviction was refused, as although there was a poor decision on the part of the officer for delaying advice, it was at the judges discretion to reverse the conviction. The judge decided against excluding the evidence under s.78 PACE, as the defendant was aware of his rights, exercised them (including the right to silence), and as such the presence of legal advice would not have changed the outcome of the interview. Finally, the offence with which the suspect is under question for must be a serious arrestable offence. S.116(1) of PACE lists the offences which fall under this category, and any factors which may cause a normal arrestable offence to become a serious one. Robbery is not normally an arrestable offence, and so for the delay in legal advice to be allowed, there must be exceptional circumstances as detailed in the section.  [8]   Providing that these criteria have been met, and that correct evidence is present, a suspect interview is permitted to be conducted under Code C (para 6.6) of PACE, a part of the code which otherwise would prevent such interviews from taking place. Is repeating questions previously posed, permissible? There is no mention of limits on repeating questions in the PACE codes of conduct; However, guidelines on the subject of investigative interview aims and techniques were published by the Home Office in 1992. Amongst these guidelines were the seven principles of investigative interviewing.  [9]  Following these guidelines, which were devised with existing Human Rights legislation in mind  [10]  , interviewing officers have a framework within which they can work without overstepping the line with regards to the treatment of suspects. In particular, there is one guideline which influences how repeat questioning can be posed. Principle number 4 states; Investigators are not bound to accept the first answer given. Questioning is not unfair merely because it is persistent. Therefore, persistent questioning, considering these guidelines, published under the title of The National Investigative Interviewing Strategy 2009  [11]  is permitted. But at what point does persistent questioning become oppressive? Oppressive behaviour can amount to inadmissibility of evidence; examples including confessions  [12]  . In R v Fulling  [13]  , Lord Lane CJ said that oppression occurred following behaviour which included excercise of authority or power in a burdensome, harsh or wrongful manner  [14]  . In R v Paris  [15]  , also known as the case of the Cardiff Three, over the course of 13 hours worth of interview time, a statement was put to the defendant forcefully, along with the question of whether he had committed the offence detailed, over 300 times. Despite no violence being used, this conduct was deemed to be oppressive. Another case which illustrates when questioning becomes beyond what is expected of the police officer, is that of R v Hero n  [16]  . In this case persistent badgering and questioning along the lines of getting a confession for the murder of a 7 year old girl resulted in the case being thrown out of court. This was despite the tone of the questioning not being aggressive or harsh; It was merely the style and purpose of the questioning with which the judge took issue. The result of a report into the actions taken during this enquiry found that the line between robust questioning and oppressive questioning was difficult to draw  [17]  . However, these are exceptional circumstances in which repeated questioning has been deemed to have gone too far; there are few reported cases. For the main part, the investigative guidelines are the key to allowing repeats of questioning. Code C (para.11.5) of PACE also guides the police officer to not use oppressive behaviour whilst conducting an interview. For the PEACE model of investigative interviewing, repeats of questions mentioned previously are a fundamental of the account clarification section of the model. The model is the standard start point from which all policing interviews are carried out in the United Kingdom, and as such, the guidelines must be clear. Without the freedom to ask questions repeatedly which may have either not been answered fully previously or without any conviction, then it becomes harder to ascertain the truth behind events; the main aim of investigative interviewing. Another of the principles of investigative interviewing confirms this; When conducting a suspect interview, police officers are free to ask questions in order to establish the truth The Dangers of Submitting Pre-Prepared Statements The purpose of handing in a pre-prepared statement is to provide a written copy of the details of the case, from the defences point of view, usually at the beginning of a suspect interview. If the statement contains adequate levels of detail, and covers any facts which are mentioned in court fully, then it has the power to negate the drawing of adverse inferences. An instance of when such inferences can be drawn can be found under s.34(1)(a) of the Criminal Justice and Public Order Act 1994(CJPOA), which reads; Where, in any proceedings against a person for an offence, evidence is given that the accused- at any time before he was charged with the offence, on being questioned under caution by a constable trying to discover whether or by whom the offence had been committed, failed to mention any fact relied on in his defence in those proceedings. As questioning under caution is mentioned, the statement should be handed in once the caution has been given. But what happens when the statement fails to give sufficient evidential value? Mentioning a fact in court which was not mentioned in the pre-prepared statement, but would have been reasonable to include in such a document, is one danger. In R v McGarry  [18]  , the defendant relied on facts which were not present on the statement which was handed in. There was merely flesh on the bones of that account, and an adverse inference can be drawn based on the reliance of such evidence in the proceedings, as in s.34(1)(a) CJPOA. Failure to mention basic facts which would have been reasonably expected in a vital piece of evidence is another danger in submitting a pre-prepared statement without thorough planning. Planning can be done prior to any interview in private between defendant and legal advisor, as the pre-prepared statement is a legally privileged document, and as such the police have no right to enforce access to it. In R v Bourgass  [19]  , the appellant had picked up a knife and stabbed 4 officers. He was convicted of murder, and then appealed based on admissibility of evidence. When analysed, the pre-prepared statement which was given at the beginning of the original interview provided no insight as to the reasoning behind why the appellant wished to escape, nor did it try to persuade that the use of the knife was in self-defence. In court the appellant relied solely upon this statement, and gave no other testimony in front of the jury; yet it contained such little in the way of a defence of his actions that the statement proved pointless, and the appellants conviction was held. It is not the failure to answer questions which can introduce the possibility of adverse inferences; but rather the failure to provide sufficient answers in the prepared statement, as in R v Knight  [20]  . In this case, despite failing to answer any questions in interview, the defences pre-prepared statement was enough to negate any wrong doing under s.34  [21]  , and so the appeal was allowed and the conviction was overruled.  [22]  However, this ruling came with a warning from the presiding judge; We wish to make it crystal clear that of itself the making of a pre-prepared statement gives no automatic immunity against adverse inferences under section 34  [23]   Adverse inferences can also be avoided providing what is said in the interview is in line with evidence found in the pre-prepared statement, as in R v Ali Ors  [24]  . The credibility of the suspect can be put under question if 2 statements which do not match in character and account are put to the court; A pre-prepared statement and an oral statement. Under s.119 of the Criminal Justice Act 2003, (1) If in criminal proceedings a person gives oral evidence and- (a) he admits making a previous inconsistent statement, or (b) a previous inconsistent statement made by him is proved by virtue of section 3, 4 or 5 of the Criminal Procedure Act 1865 (c. 18), the statement is admissible as evidence of any matter stated of which oral evidence by him would be admissible. This legislation means that both types of statement must be taken into account by the court, and both are admissible when the jury are making their decision. The decision must be made in light of the ruling in R v Argent  [25]  , where 6 guidelines were put in place to decide when an inference could be inferred; There must be proceedings against a person for an offence; The alleged failure to mention a fact at trial must have occurred before charge, or on charge; The alleged failure must have occurred during questioning under caution); The questioning must have been directed to trying to discover whether or by whom the alleged offence was committed; The alleged failure of the accused must have been to mention any fact relied on in his defence in those proceedings; The alleged failure must have been to mention a fact which in the circumstances existing at the time the accused could reasonably have been expected to mention when so questioned. Bibliography Cases: R v Argent [1997] 2 Cr.App.R. 27 R v Knight [2003] EWCA 1977 Paragraph 13 R v Ali Ors [2001] EWCA Crim 683. R v Knight [2003] EWCA 1977 R v McGarry[1998] EWCA Crim 2364 (16th July, 1998) R v Bourgass[2005] EWCA Crim 1943 (19 July 2005) R v Fulling[1987] 2 WLR 923 R v Paris (1993) 97 Cr. App. R. 99 R v George Heron, (November 1993) Unreported R v Samuel [1988] 1 QB 615 R. v Alladice[1988] Crim. L.R. 608 R v James Ors [2008] EWCA Crim 1869 (30 July 2008) R v McGovern(1991) 92 Cr. App. R. 228 Case Study: Depression and Dementia Care Case Study: Depression and Dementia Care Introduction Mr X is a 78 years old gentleman who has been admitted to a busy dementia unit six months ago. He was admitted from home following increasing lethargy, depression and reduced mobility. Prior to the admission he was diagnosed inter alia with Vascular Dementia. He communicates verbally with no difficulties, using very wide vocabulary however can mix up words and situations. He was assessed as lacking capacity to make informed decisions. Mr X has one daughter who is of the opinion that her father lacks insight into the difficulties he was having at home believing that he was managing fine. Mr X’s wife (Eva) died few months ago, in a hospital suffering from breast cancer. Mr X was very involved into her care throughout the illness and cannot accept the loss. Problem assessment Mr X, does appear to have an understanding of the sourroundings albeit he is very quiet most of the times almost like having no intrest of what is happening around him. He appears unable to generate any enthusiasm. Mr X remains independent in terms of personal care, use of facilities, eating and drinking and requires minimum assistance and maximum encouragement and prompting. He is able to mobilize with a zimmer frame, though seem to feel best sitting in a chair in his room, even at â€Å"meals or activities times†. In relation to the above three main problems that interlock have been identified 1. Depression and its effects Mr X cannot reconcile yourself to the loss of his wife, changes in life his physical and mental health resulting in depression and progress in dementia. He appears isolated, lost a lot of weight; apathy and withdrawal are present affecting seriously his ability to perform everyday tasks. According to him, to his daughter and to the information gained on assessment using Initial Dementia Assessment (IDA) he used to enjoy reading books, travelling and had an outgoing personality. The IDA indicated that the dramatic change and deterioration in his condition was noted when his wife passed away and he was told that he is having dementia. On the Mini-Mental State Examination (MMSE) Mr X scored 20/30 which could suggest that his dementia is not severe and that there may be other reasons for his withowal. His score could have been slightly inflated because well educated people like Mr X find thequestions â€Å"easy† to answer (Marshal at al 1983) but he could be described as â€Å" mildly confused†. One of the MMSE questions related to language skills was about writing a sentence about anything. Mr X wrote a short statement â€Å"Eva is not here and I have dementia†. Research show that coping and getting along with the diagnosis of dementia is a time-consuming process often related to a range of emotions such as: fear, shame, guilt, sadness, bitterness, isolation and helplessnes. (Alzheimer Europe, 2009) Mr. X appeared to feel overwhelmed by those emotions. Paying attention to non verbal signs of Mr X bevaiour helped staff to investigate his case further. He often avoided eye contact, showed no inattentiveness his appetite decreased and his posture expressed â€Å"tiredness of living†. Studies of nonverbal behaviour indicators in show that this type of signs are often related to post traumatic stess disorder ( PTDS) and that men are more likely to show depression in a form of isolation and withrowal (Stratou at al, n.d.). 2. Upset family relationships Assessment tools demonstrated that family was very important to Mr X. When communicating with the daughter lack of understanding dementia, depression and PTDS were identified as an important factor contributing to Mr X situation. Evidence show that above named health issues have an impact on family members; relationship difficulties are common and it it not easy to understand the â€Å"loved one†. ( Alzheimer’s Society, 2013). The main concern was no communication with the father and unwillingness to spend time with him to enable him to accept his chalanging situalion. She could not imagine that her normally happy and sociable father was so depressed, and in addition diagnosed with dementia which meant he became â€Å"a stranger† to her. 3. Challenging behaviour Whilst staff members were doing their best trying to motivate and encourage Mr X to get more involved into his care and the care home life, Mr. X refused everything or simply ignored them. The efforts had a negative impact on him and caused reactions such as pretending to be dependent and irritating staff. These types of reaction have been identified by Wallbridge as types of aggression called â€Å" active resistance† ( Wallbridge, n.d.). Staff then presented negative attidude and disaffection towards Mr X. Evidence suggests that behaviours, including uncooperativeness, staff find difficult to cope can lead psychological stess amongst staff and discourage them to deepen knowledge related to the health problem of the patient. ( Brodaty at al, 2003) Planning From the above assessment a list o goals have been created in order to improve the quality of life for mr X which is aimed to be archived through: creating an environment where Mr X could feel emotionally safe, supported and understood helping him understand, manage and accept his condition . Lowering the level of lethargy and depression and stimulate functional ability, social contact and activity by encouraging him to talk and listen to what he is saying Stimulating and motivating Mr X to create new habits related to maintain his physical independence, eating and help him use his potential involving Mr X’s daughter into care and help her understand the complexity of her father’s condition to make the psychosocial interventions better and improve Mr X behaviour and mood as well as increase his acceptability of the care home settings. Encourage her to let Mr X know that she cares about him and to stay in contact with him by visiting him, taking him out, calling etc to minimise the isolating experience training for staff in relation to challenging behaviour and dementia awareness, communication, behaviour and work related stress management The desired outcome is partially based on the outcomes from the research done amongst people with mild dementia and suffering on depression that have successfully managed to improve their lives, that was done was done by the social work department of University of Stirling for the Scottish Executive. (Scottish Executive Social Research 2005) Implementation In relation to problem 1 Assessment using IDA and MMSE indicated that Mr X condition is affected by depression. Further investigation has been done. GP and the Liason Psychiatric Nurse have been contacted and involved. Mr X scored 23/30 in the Geriatric Depression Scale (GDS) indicating severe depression. (Yesavage et al, 1982) It has been decided that his depression should be addressed first because it was the major factor preventing Mr X from enjoying life similarly to like he used to. It is known that the effects of depression go far beyond the mood ( Smith at el. 2014). In Mr X case this had an impact not only on his energy, appetite, and physical activity but also on his relations with family and staff. In relation to the weight loss Malnutrition Universal Screening Too (MUST) (BAPEN, n.d.) has been used. Initial MUST score was 0 with healthy BMI but due to his poor appetite the score rose to 1 within 3 months. Therefore his dietary intake was documented in a form of Food and Fluids Record Chat ( Care NHS UK, n.d) and his weight was monitored every two weeks. In relation to diet intake Mrs X was offered meals according to his likes suggested by his daughter and accepted by himself which significantly increased the likehood of an â€Å" consumed meal† . After 2 months his weight stabilised. He remains â€Å" poor eater† and therefore his meals contain more calories. His weight is currently monitored once a month and is not a concern anymore. Changes are documented in his care plan that is evaluated every month. Studies show an association between depression and increased mortality in older adults. Factors identified in Mr X case included poor adherence , lack of physical activity, cognitive impairment. ( Gallo et al 3013) From the point of his medication, a rviewd was requested by the GP and and it has been suggested to discontinue Paroxetine(Seroxat) and commence on Amitriptyline. Both belong to antidepressants but vary in side effects. ( NHS Choice, 2013). In addition it has been requested to commence Mr X on regular laxatives as episode of constipation have been noted. Currently Mr X bowels are monitored and documented on bowels chart on daily basis. No concerns have been noted. In relation to problem 2 Reduced sense of purpose was identified as the main co-existing factor To help Mr X overcome this problem (which he expressed clearly during the MMSE mentioning the loss of his spouse and dementia diagnosis) his daughter was asked to participate and although she was initially sceptical she brought meaningful memoralia and small pieces of furniture to help him feel like home. Staff gave her assistance and explanation in relation to dementia and depression. She was also offered help and given reassurance in a form of Family Support Meetings organised by the home. The initial scepticism disappeared with gaining awareness of the illness. She became Mr X advocate and currently holds medical and financial power of attorney for him. ( Office of the Public Guardian, Scotland, n.d.) Furthermore her two sons come regularly to visit Mr. X, they often take him out for a meal or call him to find out how he is. Staff has also managed to discuss one the most sensitive matters related to Mr. X’s End of Life such as DNACPR certificate that is present in Mr X file in the event of need. Mr. X’s relationship with his daughter and grandsons appears happy. The daughter stated that this helped also her to resolve personal problems she feels acknowledged by her father and therefore valued. There is a Family/Relatives Communication part in Mr X care plan and a book in Mr X room where any suggestions, complaints or comments can be made by staff members or by the family .(U.S National Library of Medicine, 2011) The relation with staff can be defined as very good. A person’s family is often the most important, long-standing connection in their life. Therefore, the ability of staff to work positively and inclusively with families and carers is a core staff skill. In relation to problem 3 Most of the staff required training to help them understand the nature of behaviour that challenges. The importance of the training this became so vital that it is now one of the mandatory trainings every member of staff has to attend. Skills that were aimed to be improved included addressing challenging behaviour, person centred approach and communication skills (Skills for Care, 2013) Many staff showed the need to be trained in related to stress management (Wallbridge, n.d.) The future aim is to create a team that focuses on people’s assets and life outcomes. A team that is confident of their roles and impact on Mr X and any other client, willing to contribute and encouraging new members of staff to learn. Evaluation Summarising, Mr. X case has been an example of mostly successful process of assessment and implementation of the planned actions. There was and so called â€Å"multi agency† approach to Mr X needs. Assessment tools helped in the identification and articulation of the needs and contributed to positive changes leading to holistic, personalised approach to them. Recent changes to the social care management and the need to comply with the Public Services Reform Scotland Act 2010 contributed to the awareness in relation to staff due to the accent on the importance of systematic and sensitive assessment. Mr X’s continuing care did not require up to now any specific nursing interventions. The difficulty consisted of identifying the roles and the division of work. Mr X’s case proved that there are different functions staffs have to complete that contribute to the optimum health and overall wellbeing of older people such as: psychosocial and emotional support enabling life review – where the family support was crucial but required time to function work aimed at maintaining his independence and functional ability that continues to be improved through the aspiration of a well functioning team work. educative teaching self-care activities by encouraging physical activity managerial- directions in terms of who and when undertakes the administrative and supervisory responsibilities could have been improved. All the above reduces to good knowledge, awareness, and experience, will power to change things for the better and to a well functioning team work. Many things would have been done sooner or could have been dealt with better if we were aware of the need and knew how. This is why it would be recommended to pay more attention to training needs in relation to new regulations, staff assessments, achieving and evidencing outcomes, person-centred care planning. References Office of the Public Guardian( Scotland)( n.d.) http://www.publicguardian-scotland.gov.uk/whatwedo/power_of_attorney.asp Care NHS UK ( n.d.) Food and Fluid Record Chart http://www.glos-care.nhs.uk/images/Food_and_Fluid_chart_-_attachment_31_copy_copy_copy.pdf (BAPEN, n.d.) Malnutrition Universal Screening Tool http://www.bapen.org.uk/pdfs/must/must_full.pdf Skills for Care (2013) Supporting staff working with people who challenge services Guidance for employers http://www.skillsforcare.org.uk/Document-library/Skills/People-whose-behaviour-challenges/Supporting-staff-working-with-challenging-behaviour-(Guide-for-employers)vfw-(June-2013).pdf U.S National Library of Medicine (2011) no author Communicating with families of dementia patients Can Fam Physician Joulrnal Vol 57(7): 801–802 http://www.ncbi.nlm.nih.gov/pmc/articles/PMC3135450/ NHS Choice ( 2013) Antidepressantshttp://www.nhs.uk/conditions/Antidepressant-drugs/Pages/Introduction.aspx Melinda Smith, M.A., Lawrence Robinson, and Jeanne Segal, Ph.D. Last updated: February 2014. Depression in Older Adults the Elderly http://www.helpguide.org/mental/depression_elderly.htm Gallo, J., Morales, K.H.,Bogner, H.R, Raue, J.P, Zee,J, Bruce M.L and Reynolds C.F(2013) BMJ Helping doctors making better decisions Long term effect of depression care management on mortality in older adults: follow-up of cluster randomized clinical trial in primary care http://www.bmj.com/content/346/bmj.f2570 Scottish Executive Social Research (2005) Effective Social Work with Older People http://www.scotland.gov.uk/Resource/Doc/47121/0020809.pdf Wallbridge, H. ( n.d.) When pushed to the limit:Moving beyond a difficult situation http://www.alzheimer.mb.ca/handouts/When%20Pushed%20to%20the%20LimitMoving%20Beyond%20a%20Difficult%20Situation.pdf Alzheimer Society (2013) Understanding and respecting the person with dementia file:///C:/Users/GEORGE/Downloads/Understanding_and_respecting_the_person_with_dementia_factsheet.pdf Stratou,G., Scherer,S., Gratch,J. and Morency, L.P. (n.d) University of Southern California, Institute for Creative Technologies, Los Angeles Automatic Nonverbal Behavior Indicators ofDepression and PTSD: Exploring Gender Differences http://ict.usc.edu/pubs/Automatic%20Nonverbal%20Behavior%20Indicators%20of%20Depression%20and%20PTSD-%20Exploring%20Gender%20Differences.pdf Alzheimer Europe (2009) no author Facing the diagnosis Diagnosis of dementia http://www.alzheimer-europe.org/Living-with-dementia/After-diagnosis-What-next/Diagnosis-of-dementia/Facing-the-diagnosis Marshal F. Folstein, MD; Lee N. Robins, PhD; John E. Helzer, MD (1983) The Mini-Mental State Examination JAMA Network Journal Archives of General Psychiatry Vol 40, No. 7 http://archpsyc.jamanetwork.com/article.aspx?articleid=493108 National Chronic Care Consortium and the Alzheimer’s Association (2003) Tools for Early Identification,Assessment, and Treatment for People with Alzheimer’s Disease and Dementia http://www.alz.org/national/documents/brochure_toolsforidassesstreat.pdf

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