Assuming the counselor failed to follow the treatment protocol for the patient by causing the patient to recall repressed memories, there may be a claim for negligent infliction of emotional distress -- if the patient has in fact been distressed by the memories. If recalling the repressed memories has interfered with the patient's progress in rehab, that too may be a source of damages. As to the memories triggering a DCFS investigation which may delay the time when the patient may by joined...