My longtime T, D, had a pretty good memory. She never took notes that I remember. She never forgot anything important that I shared with her. I know she hates writing, so I doubt she documents much after session, so it's pretty impressive how much she remembers.

My new T (I recently relocated) also has a good memory. I think she sometimes takes notes, but I'm not sure. I have a hard time looking at her during session, so I can't say how much note-taking she does.