I, too, have exchanged "I love yous" with my last few therapists. The first time I did this was the last session with one (I was moving) and she gave me a card and this just came out--and she responded right back "I love you, too." We'd been writing "love" in our emails, but saying aloud to someone "I love you" is different. With my next therapist (we worked together for almost two years) we wrote "love" in our emails and then one day I said "I love you." She didn't say it back, which hurt some. I kept on saying it and then one day she surprised me by saying it back. After this, she said it once in a while, though I knew she felt this all the time. With my current therapist she knew pretty early on that my last one and I had exchanged "I love yous" and she said up front that this isn't something she felt comfortable with--she just said this to her mom and her husband. I wrote "love you" in my emails to her but she never did, except she wrote "love" on my birthday card and she also wrote a few times "sending you a loving hug." But then the first time I said aloud "I love you" to her, about a year after we started working together, she responded, "I know you do, and you do know that I love you, too." Even if she hadn't responded like this I would have been OK--I know from the way she treats me and from looking into her eyes that she does love me and I just have to respect her boundaries. We haven't said "I love you" since then (about 2 months ago), and this is OK, too. In short, each therapist has different boundaries, but this is something that they do encounter. For a long time with this current therapist I was thinking, I know you love me, so why can't we say this to each other? But knowing her boundaries (which did change one day) made it easier for me to understand why.
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