I have no idea. My T took some notes on my first session a year and a half ago, I think just to jot some key names down, etc, but she hasn't taken notes in session since. I also never have a client after me, and oftentimes she leaves after my session, sometimes we've walked out together, so I know she doesn't (always) take notes right after the session. Honestly, I think she just has a good memory and probably takes few, if any, notes at all.