v. Jefferson, Jefferson & Vaida, 167 N.J.Super. 282, 400 A.2d 836 (App.Div.1979). We perceive no impenetrable barrier, on the limited record before us, to establishing a standard of care applicable to cleric-counselors in the context of an allegation that the counselor used his position to sexually exploit the counselee. Cf. Simmons v. United States, 805 F.2d 1363, 1365 (9th Cir.1986) (affirming judgment based on sexual exploitation of plaintiff by a social worker-counselor, discussing the “transference phenomenon” and noting that “[wjhen the therapist mishandles transference and becomes sexually involved with a patient, medical authorities are nearly unanimous in considering such conduct to be malpractice”); Corgan v. Muehling, 143 Ill.2d 296, 158 Ill.Dec. 489, 574 N.E.2d 602 (1991) (<HOLDING>); N.J.AC. 13:42-10.9 (prohibiting a
recognizing negligent procurement to be a negligence cause of action recognizing the cause of action holding that the allegations in the complaint stated a cause of action under section 376313 holding that complaint stated cause of action for negligence arising from psychologists engaging in relations with plaintiff during course of treatment recognizing cause of action