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The imperative to be “non-directive” was arguably the grounding principle of Carl Rogers’s psychotherapeutic method, which he would “objectify” and systematically test in order to bring psychotherapy “within the boundaries of scientific psychology,” to acclaim from the APA (1957). In attempts to bring (mechanical) objectivity and “absolute accuracy” to accounts of psychotherapy cases, Rogers recorded entire series of therapy sessions phonographically and had them transcribed for later study. Importantly, he also published hundreds of pages of such transcripts, annotated extensively with footnote commentary, as in the “Case of Herbert Bryan” in Counseling and Psychotherapy (1942). In doing so, Rogers inscribed his clinical work in a tradition of publishing extensive textual accounts of routine psychotherapy that dates to the late 19th-century origins of the term in Hippolyte Bernheim’s hundreds of published observations of suggestive “psychotherapy.” Yet for all the critical scholarship examining what it means to “think in cases” or collate them into series for diagnostic purposes, it is much less clear what published (psycho)therapeutic cases did for therapists, learners, and medico-psychological knowledge-making. This paper analyzes Rogers’s published phonographic sessions in order to open up our understanding of how epistemic and textual functions intersect in case-writing centered on psychotherapy. I examine dynamics of reproducibility, generalizability, and epistemic inclusion and exclusion, as they link to the textual and narrative features of the published sessions. What might it mean that Rogers’s annotated transcripts direct a reader/learner towards precise conclusions and impose particular forms of reading, when his therapy prioritizes just the opposite in interactions with a client? Does reproducing “every spoken word” from a therapy session leave no space for the therapist’s conceptual reasoning or reader’s active knowledge-making in a case narrative?