In R.L. v. L.T. (NYLJ 1202672096267 [Sup Ct, Westchester County, index No. 3406-12], the Court was similarly unpersuaded by the father's request in that case for access to the forensic evaluator's entire file. In addition to claiming that the entire file was needed to prepare for cross-examination at trial, the father contended that the forensic evaluator did not use accepted psychological testing methods and reached her conclusions without a proper basis. The court denied access, relying upon the specific finding in Ochs that such access could have a deleterious effect on the parties' relationship. The court also concurred with Ochs' assessment of the evaluator's underlying notes, finding little value in the "unfiltered, immediate impressions of the psychologist, jotted down in haste." (Id. at 4, quoting Ochs at 508.) The court held that the father did not identify "any particular bias on the part of the evaluator" and his contention about the testing methodology merely threatened to turn the trial into a long and costly critique of the methodology utilized by the evaluator. Accordingly, the court found no special circumstances to justify the father's access to the file.