A parent's pattern of abusive, threatening and inappropriate behaviour towards the other parent, their legal representatives, the independent children's lawyer, and the other parent's employer, combined with expert psychiatric evidence of personality disorder, can support a finding of real and identifiable risk of psychological abuse to children sufficient to justify supervised access only. The primary judge's assessment of such risk, based on the totality of the evidence including the parent's conduct during the proceedings, will not be disturbed on appeal absent material error.
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