“Canadian researcher Donald Dutton . . has written that marital work with a man who has a history of relationship violence may be a “conflict-generator” and that individual work . . should come first for both husband and wife. …Marital therapy does not provide the battered woman the kind of safety she needs for rebuilding her strength and finding her identity. The consequences may be severe if she is truthful in a couple’s session. She may be too afraid. Moreover, many upscale batterers can be charming and persuasive and may convey a far different image of themselves to the therapist than the one that reflects the woman’s reality at home.”