FMSF NEWSLETTER ARCHIVE - May 1, 1996 - Vol. 5, No. 5, HTML version

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    The FMSF Newsletter is published 10 times a year by the  False
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    ISSN #1069-0484
  Focus on Science
      Legal Corner
          From Our Readers

Dear Friends,

  "Does recovered memory therapy help patients get better?"

  Elizabeth Loftus, Ph.D. presented the first outcome-data addressing
this question when she spoke at the Southwestern Psychological
Association meeting in Houston on April 5, 1996. The data are from the
Washington State Crime Victims Compensation Program. The audience of
500 sat in stunned silence as data confirmed: RECOVERED MEMORY THERAPY
  There were 670 repressed memory claims to the Washington Victim's
Compensation program between 1991 and June of 1995. The state approved
325 (49%). A review of 183 of the approved claims was made from which
30 were randomly selected for closer examination.
  Of the 30 closely examined claimants, there were 29 women and 29
Caucasians. The median age was 39 (range from 15 to 67 years).
Masters-level therapists treated 26 of the 30 people. Two patients
saw a Ph.D.-level therapist and two saw an M.D.
  For 26 of the claimants, the first memory surfaced when they were in
therapy.  All of the 30 claimants were still in therapy three years
after their first memory. Eighteen of the claimants were still in
therapy five years after the first memory.
  Only 3 claimants thought about suicide or attempted suicide before
recovering their first memory but 20 did so after memories. Two people
had been hospitalized prior to their first memory while 11 were
hospitalized after memories started. One person engaged in self-
mutilation before memories but 8 did so after memories.
  Twenty-nine claimants reported memories of satanic ritual abuse (the
average age at which these memories were said to have begun was 7
months.) The number of murders reported by this group of patients was
150. Twenty-two patients claimed memories of birth and infant
cannibalism. Twenty patients recalled memories of being tortured with
spiders and 29 remembered physical torture and mutilation.  The
records of these patients showed no corroborating medical evidence of
torture or mutilation. Not one of the allegations resulted in a police
  Two thirds (21) of the patients had graduated from high school and
seven had post high school education. Half of the patients (15) had
been employed in the health industry and seventeen had been employed
in fields that involved art or writing. BEFORE THERAPY 25 HAD BEEN
  Before their first memory, 23 of the patients were married. Three
years after getting memories, 11 were divorced. Seven people lost
custody of their minor children. 100% of patients were estranged from
their extended family.
  The average cost of non-repressed memory claims was $2,672. The
average cost of repressed memory claims was $12,296 (median was
$9,296). The total cost to the Crime Victims Compensation Program for
this group of 30 repressed memory claims was $2,533,000.
   These data will probably not surprise readers of this newsletter.
FMSF Advisory Board members have expressed concern from the very
beginning about the efficacy of recovered memory therapy. The data
collected from parents and then supported by the accounts of
retractors dramatize the concern of the few professionals who have had
the courage to speak out. Sadly, the harm continues. New families
still call to say that they have recently been accused by their grown
daughter or son. Insurance companies, Medicare and Medicaid continue
to pay for these treatments. Scarce mental health dollars continue to
be wasted creating iatrogenic illnesses and then paying for the
therapy to deal with what was created. Allowing these practices to
continue further undermines the credibility of the mental health
professions. The inability of the professions to self-police
encourages those harmed by these practices to seek the only
alternative left to them -- courts and licensing boards.
  Also undermining credibility of the whole profession is the
resounding silence to the American Psychological Association's Final
Report of the Working Group on Investigation of Memories of Childhood
Abuse in which clinicians and scientists say they do not agree about
the conception and mechanisms of memory. The silence implies an
endorsement of the report conclusion that clinicians do not agree with
scientists about "the rules of evidence by which we can test
hypotheses about the consequences of trauma and the nature of
  The rules of evidence for science are clear: a theory must be
testable and falsifiable, capable of meeting peer review and if
involving a methodology or process, have a known rate of error. If
clinicians do not hold to these rules, it is not science. The public,
then, has a right and a duty to ask how clinicians differ from
astrologers and witch doctors.
  The False Memory Syndrome Foundation has asked people to think about
the lack of scientific evidence supporting the constellation of
practices known as recovered memory therapy. Research on memory does
not support any professional telling a patient that there is some way
to get to historic truth other than external corroboration. Research
does not support telling a patient that she or he has "all the signs
of abuse." Data do not support the belief that in order to get better
a person must recover a memory of a forgotten trauma. Data do not
support confronting and suing. Data do not support cutting off strong
social support systems..
  The data from the state of Washington are a stark reminder of the
harm that can be done when science is abandoned for a sociopolitical
movement. These data come from a government source, not proponents or
critics of recovered memory.  How long will the profession be silent?
/                                                                    \ 
| "Increases in self-injury and suicide attempts have been reported  |
| in some patients given recovered memory treatment."                |
|                   Canadian Psychiatric Association, March 15, 1996 |
|         Position paper: "Adult recovered memories of sexual abuse" |

                     A SOCIAL POLITICAL MOVEMENT

  A memory researcher told us that research academics"don't even know
what this memory debate is about. They see the evidence and to them
the science of memory is obvious." He is right. The "science" of the
"memory" is established. We are dealing with a sociopolitical
movement. Activities around the Southwestern Psychological Association
(SWPA) give an example of the difference. Before the meeting, some
therapists and survivors tried to stop the presentations of Dr.
Loftus and other invited speakers (Larry Weiscrantz, Henry L.
Roediger, III, and John F. Kihlstrom) just because they advised the
  The SWPA meeting was a serious scientific affair, but after
Dr. Loftus's talk, one recovered memory advocate stood up to say that
the program was not balanced and that the program should have listed
speakers' affiliation with the FMSF. He then stomped out of the room
before anyone could respond -- not good form in a scientific meeting.
This prompted one member of the audience to quip, "Are you now or have
you ever been a member of the Communist party?" a reference to the
parallel with the McCarthy era.
  How could a scientific program about memory be "balanced?" The
notion makes no more sense than trying to balance a program in
astronomy by including astrologers.

/                                                                    \ 
|             Psychology Today, May/June, 1996, responds             |
|           to the smear campaign against Elizabeth Loftus           |
|                                                                    |
| "Why Loftus? And why now? The tide has turned. Many recovered      |
| memory convictions have been overturned. Much of this is due to    |
| Loftus; it would help if she could be discredited as an expert     |
| witness. But far more powerful a reason is that Loftus is a woman, |
| a scientist, unshakable, and widely liked; she's broken too many   |
| taboos. Women are supposed to burn bras, weep, and yell, not       |
| marshall strong science in powerfully argued debates. And no woman |
| is supposed to turn traitor to the cause -- the misguided feminist |
| cause of other women as victims."                                  |


  The Canadian Psychiatric Association issued a position statement on
"Adult recovered memories of childhood sexual abuse," on March 25,
1996. It affirms the importance of external corroboration in knowing
the truth of memory. In addition, it states: "Confrontation with
alleged perpetrators solely for the supposed curative effect of
expressing anger should not be encouraged. THERE IS NO RELIABLE
  The statement notes that psychotherapy based upon the assumption
that "common symptoms such as depression, anxiety, anorexia or
overeating, poorly explained pain and other bodily complaints"
indicate "the likelihood of individuals having been abused" may "lead
to deleterious effects." They also note that,"increases in self-injury
and suicide attempts have been reported in some patients given
recovered memory treatment."

                           FOCUS ON SCIENCE

  From time to time, various scientific articles appear which discuss
issues of childhood sexual abuse, memory, and responses to trauma.
Since such studies are often widely cited in the scientific and
popular press, it is critical to recognize their methodological
limits. It is particularly important to understand what conclusions
can and cannot legitimately be drawn from these studies on the basis
of the data presented. As a result, we periodically present analyses
of recent well-known studies, prepared with help from members of our
Scientific Advisory Committee.

                      *       *       *       *

  In the ongoing debate about the scientific validity of "repressed"
and "recovered" memory, one commonly hears of various case reports --
anecdotal reports of specific individuals -- which appear to document
that "repression" has occurred. Do such case reports represent useful
scientific evidence?
  In answer to this question, it is fruitful to recall some of the
other case reports which have appeared in the scientific literature
from time to time. For example, a report in a prestigious peer-
reviewed journal, the American Journal of Psychiatry, described a
woman who appeared to have acquired the ability to speak another
language by supernatural means [1]. She was said to display a
secondary personality, capable of speaking a language that she had
never learned, that tended to appear on the eighth (ashtami) day of
the waxing or waning moon. The authors did not provide any explanation
based upon known scientific principles for this case of "paranormally
acquired speech."  Similarly, one can find compelling case reports of
individuals who have had experiences in past lives [2,3] and, of
course, individuals who have been abducted by space aliens [4]. Now,
can we conclude, on the basis of these case reports, that such
phenomena actually occur? And if we do not accept these phenomena as
proven, what is our reason for skepticism?
  The reason that we are skeptical, or at least should be, is because
of a principle known in science as "measurement error." This term
refers to the fact that when one makes a large number of observations,
a few errors are bound to occur. In other words, there is a certain
"background noise," due to occasional "false positive" observations,
which permeates even the most careful studies. A classic example of
such a "false positive" was obtained by a police department in
Florida, whose officers used a radar gun to clock a grove of trees
moving at 86 miles per hour, and a house moving at a more leisurely 20
miles per hour [5].  In other words, although radar is usually
accurate (as most of us unfortunately know), it is, like everything
else, vulnerable to false positive observations.
  How do scientists deal with the problem of "measurement error?"
There are various methods, depending upon the type of research being
conducted. For example, if we know that a test for the HIV virus is
wrong approximately 1% of the time, and this test yields a 10%
prevalence rate for HIV in a given population of individuals, we can
state with reasonable confidence (depending on the size of the
population) that this population has an elevated rate of HIV
infection, and that this finding cannot be explained merely by the
rate of false positives expected from the test. This is an example of
what the United States Supreme Court had in mind, in its pivotal
Daubert ruling, when it required that a scientific test have a "known
rate of error" in order to be admissible in expert scientific
testimony. When the rate of error is unknown and may be quite high, as
in such methods as handwriting analysis, lie detector tests, or
hypnotically refreshed memory, then the admissibility of the evidence
is thrown into question. It may be ruled to be "junk science" and
excluded from the courtroom.
  Returning now to the issues of "repression" and "recovered memory,"
we find an analogous situation. There are various anecdotal cases in
which individuals have provided dramatic stories of an allegedly
"repressed" memory that was subsequently "recovered" many years later,
and where corroborating evidence was allegedly found to prove that the
"recovered memory" was actually true. But, when we consider that
literally hundreds of thousands of therapists and counselors of every
description have seen many millions of patients over the years, one
would expect to see numerous case descriptions of "repressed memory,"
just from measurement error alone. Specifically, if the rate of "false
positives" were only one in one thousand, but we have a denominator of
millions of patients, then we would expect to see hundreds or
thousands of reported "cases" even of a phenomenon which did not
actually exist at all.
  Not only do we have a very large and unknown denominator, but we
also have very little idea of the rate of error to be expected. If we
studied 100 patients with severe depression, and found 2 individuals
with seemingly clear, corroborated cases of "repressed" memory, would
this be a satisfactory scientific demonstration of "repression?" Or
would a 2% rate be simply the level of "background noise" to be
expected from measurement error, in which case the study would offer
no evidence for "repression" at all? Since we do not know the rate of
"false positives" to be expected as a result of measurement error, we
would probably require a fairly robust prevalence of documented cases
of "repression" in our hypothetical study to be certain that we were
comfortably above the level that could be accounted for by measurement
  In summary, then, when we hear a dramatic and seemingly ironclad
case example of some individual who appears to have "repressed" and
"recovered" a traumatic memory, it is easy to be impressed. Indeed,
such cases may be valuable as "hypothesis generating" evidence. But
they are not legitimate "hypothesis testing" evidence. In the modern
scientific debate on the existence of "repression" and "recovered
memory," such case reports have no more place than the 20-mile-per
hour house or the 86-mile-per-hour trees.

  1. Stevenson I, Pasricha S. A case of secondary personality with
     xenoglossy. Am J Psychiatry 1979; 136: 1591-1592.
  2. Pasricha S, Stevenson I. The cases of the reincarnation type in
     India. Ind J Psychiatry 1977;19:36-42.
  3. Woolger T. Other lives, other selves. New York: Doubleday, 1987.
  4. Mack JE. Abduction: Known encounters with aliens. New York:
     Scribners, 1994.
  5. Smith D, Tomerlin J. Beating the radar rap. Chicago: Bonus Books,

                         LEGISLATIVE ACTIVITY 
                              FMSF Staff
               Informed Consent Bill Passed in Indiana   
  Senate Bill No 210 sponsored by Senator Patricia Miller was passed
in the Second Regular Session 109th General Assembly in 1996 (House
92-1 and Senate 48-0).
  The bill "Provides that a mental health provider must obtain the
consent of a patient (or other legal representative) before providing
mental health services; provides certain exceptions to the consent
requirements; provides that mental health services consent
requirements expire July 1, 1998; establishes the mental health
practice study committee to study informed consent for mental health
services, the definition of mental health services, mental health
scopes of practice, enforcement of mental health scopes of practice,
and any other related area as determined by the chairman of the
  The bill states that "Before providing mental health services, a
mental health provider must obtain written consent from each patient.
The consent required..must include a statement that the patient is
consenting only to those mental health services that the mental health
provider is qualified to provide within: (1) the scope of the
provider's license, certification, and training; or (2) the scope of
the license, certification, and training of those mental health
providers directly supervising the services received by the patient."
  Mental health providers are: registered or licensed practical nurse;
clinical social worker; marriage and family therapist; psychologist;
school psychologist; drug and alcohol abuse counselor; and individuals
who claim to be mental health providers. Physicians (and, therefore
psychiatrists) are not covered by this bill.
  This informed consent bill does not force providers to tell the
patient the general nature of his or her condition, the expected
outcome of the treatment, the material risks of the treatment, the
reasonable alternatives, or that the patient has the right to withdraw
consent for treatment at any time.  
                        Statutes of Limitation
  Four states have recently enacted or are considering legislation
regarding the statute of limitations for both criminal and civil
matters in cases involving childhood sexual abuse and sexual assault
  In NEW JERSEY, the governor recently signed Senate Bill 452 which
eliminates the statute of limitations in criminal sexual assault
cases. Prior to the passage of this new legislation, homicide and
manslaughter were the only crimes for which prosecutions could be
brought at any time.  Previously, sexual assault prosecutions could
only be brought within five years of the crime.  The new law also
states that in cases where claimants under the age of 18 are sexually
assaulted, prosecutors may bring charges before the victim's 23rd
birthday or "within two years of the discovery of the offense by the
victim, whichever is later." According to one newspaper report, this
clause is meant to help those who were assaulted as young children and
repressed the memory until they become adults (see, The Record,
Trenton Bureau, March 1, 1996, p. A-3).
  On February 23, 1996, MASSACHUSETTS Governor Weld signed into law
S.B. 1965, which extends the statute of limitations in rape cases from
10 to 15 years. As Taunton defense lawyer, Francis O'Boy noted, many
of the rape cases brought 10 or more years after the alleged incident
will come on the basis of repressed memory. Mr. O'Boy is quoted as
calling the new law, "an abomination" to justice "created by a small
coven of advocates that stampeded the public into thinking it was the
right thing to do." (The Providence Journal-Bulletin, March 4, 1996,
p. 1-C).
  TENNESSEE is currently debating the passage of H.B. 3002, which
would establish a three year statute of limitations "from discovery
and cause of injury for civil actions brought for sexual abuse
occurring when the injured party was a minor."
  RHODE ISLAND introduced S.B. 825 which would eliminate the necessity
of intentional conduct on the part of the perpetrator in its civil
childhood sexual abuse statute. This would effectively hold employers
or non-perpetrator defendants liable for alleged abuse by their

  It's important to understand the reasoning behind such legislation
in order to interpret the impact these laws may have on claims
involving repressed memory. The events leading up to the sudden
proliferation of legislation commencing from the 1980's to amend or
implement childhood sexual abuse statutes cannot be overlooked. As a
result of these circumstances, over 24 states have amended their
statutes of limitation or effected a delayed discovery rule
specifically to allow civil claims for childhood sexual abuse decades
after the alleged event.
  In the late 1980's, the first civil repressed memory suit to argue
for the delayed discovery rule was unsuccessful, Tyson v. Tyson, 727
P. 2d 226 (Wash. 1986). There, the Washington Supreme Court expressed
concern about the length of time which had elapsed since the alleged
abusive events, and about the lack of "objective, verifiable evidence"
(Id. at 227). The court also noted that a substantial risk of stale
claims would result from allowing repressed memories to toll the
statute of limitations.
  Three years later, in 1989, a woman claiming repressed memories of
childhood sexual abuse, found she was prevented from bringing suit
against her alleged perpetrator in a Washington State court following
the Tyson decision. Thereafter, she successfully lobbied the
Washington state legislature to enact the first statute of limitations
to apply the discovery doctrine to civil cases of childhood sexual
abuse. She and her husband then lobbied every state in the nation, and
it is largely through their efforts that many states followed
Washington's lead and adopted similar statutes. Many legislators were
sympathetic to testimony which argued that plaintiffs who were
traumatized into repressing memories of alleged incidents should be
allowed their day in court. At that time, it was generally assumed
the theory of repressed memory in these cases was valid.
  Since 1989, legislatures throughout the country have heard similar
testimony from many groups, including plaintiffs' attorneys, victims
rights organizations, NOW and other similarly disposed parties. In
Connecticut in 1991, for example, the head of the Sexual Assault
Crisis Services testified to the General Assembly's Judiciary
Committee that a lengthy statute of limitations was needed because
"the vast majority" of victims are completely unaware they have been
sexually abused until later in life... "[O]ur experience tends to show
a large increase in memory retrieval in the 30's and 40's." Other
testimony cited Ellen Bass as a "well-known therapist in the field of
incest," who "knows our thoughts and feelings." As many who read this
newsletter know, Ellen Bass is not a therapist but a creative writing
teacher and the well-known author of the controversial self-help book,
The Courage to Heal, which advocates suing as part of the healing
process and contains the infamous line, "If you think you were abused,
and your life shows the symptoms, then you were." Nevertheless, the
Connecticut legislature, relying on these misstatements and
inaccuracies, passed the bill to extend the childhood sexual abuse
statute of limitations from two to seventeen years.
  One must always keep in mind the principles underlying the statute
of limitations. These laws are in place to protect the courts from
fraudulent claims and the difficulty of discerning the truth in cases
where evidence has been lost due to the passage of time. And, further,
the statute of limitations seeks to protect defendants from defending
against stale claims where witnesses have died, records have been lost
or destroyed, memories faded, etc. The delayed discovery rule evolved
to allow plaintiffs equitable relief in cases where the cause of
action was "inherently unknowable" at the time of the injury, e.g., a
surgical sponge left in the body. Historically, courts have been
cautious when applying the delayed discovery doctrine to any set of
circumstances by requiring independent, objective and verifiable
evidence of the injury.
  Before the controversy surrounding the scientific validity of
repressed memory theory became well-known, many courts and
legislatures accepted the theory and gave special exception to this
class of claims. However, courts have matured in their understanding
of repressed memory theory over the past few years, as exemplified in
the Michigan case, Lemmerman v. Fealk. In 1993, the Michigan Appeals
Court in Lemmerman went so far as to state, "[W]e find it illogical to
require corroborative evidence under the delayed discovery rule." The
Michigan Appeals Court, accepting repressed memory theory as
scientifically valid, stated, "[C]onsidering the present broad
acknowledgment that child sexual abuse can be suppressed, we believe
that plaintiff's claims cannot be sacrificed in favor of a policy
discouraging stale claims." Fortunately, two years later, in 1995,
this decision was reversed by the Michigan Supreme Court, holding,
"[I]f we applied the discovery rule to such actions, the statute of
limitations would be effectively eliminated and its purpose ignored. A
person would have an unlimited time to bring an action, while the
facts became increasingly difficult to determine. The potential for
spurious claims would be great and the probability of the court's
determining the truth would be unreasonably low." The Michigan Supreme
Court's concerns are strikingly similar to those voiced nine years ago
in Tyson.
  Recently, the Texas Supreme Court, in a reasoned decision in a civil
repressed memory suit, reviewed the legislative history of childhood
sexual abuse statutes noting: "[T]he first generation simply adopted
the discovery rule or extended the statute of limitations for some
fixed, extended period after the minor reached majority...[T]he second
generation of statutes, including amendments to existing statutes, is
more complex and gives greater weight to avoiding the danger of
possibly fraudulent claims." The court goes on to cite examples of
California, Oklahoma, Colorado and New Mexico childhood sexual abuse
statutes which include language that, while not alleviating potential
problems entirely, attempt to protect innocent persons from defending
themselves against false allegations by requiring a higher standard of
  Today, as courts and legislatures carefully examine the reliability
of repressed memories, more decisions reflect a reluctance to allow
actions based on unsubstantiated theory, unsupported by objective,
verifiable and corroborative evidence. As doors to these claims are
closing, many of the same groups who lobbied the legislatures in the
1980's continue to vigorously lobby the legislatures of the 1990's.
They seek to circumvent the current trends in recent legislation and
court decisions without regard to evidentiary concerns or the pain and
suffering that many wrongfully accused individuals undergo in trying
to defend an action brought decades after the alleged event. Likewise,
advocates of repressed memory theory continue to give testimony and
publish in law reviews and professional journals claiming the
widespread occurrence of repression of childhood sexual abuse. They do
so despite the fact that comprehensive reviews of the literature have
concluded that there is no controlled experimental evidence to support
the authenticity of such memories or even the very existence of
repression. Such efforts will no doubt continue to influence courts
and legislatures as seen in the recent spate of legislation.  So,
while much progress has been made in educating lawmakers on the
scientific reliability of repressed memory theory, much work still
remains to be done.
/                                                                    \ 
| The Salem Witch Trials ended only after the Massachusetts          |
| legislature passed legislation that forbade the use of spectral    |
| evidence as proof alone of guilt.                                  |
|                                 Boyer, P. and S. Nissenbaum (1974) |
|                  Salem Possessed: The Social Origins of Witchcraft |
|                   Cambridge: Harvard University Press, pp. 181-185 |


#61 Collection F "Newspaper Articles from 1995"               $10.50
  FMS Foundation. 1995. 12 newspaper articles on various topics
  including FMS, retractor lawsuits against therapists, Wenatchee
  accusations, Satanic accusations and legal cases. 46 pp (unbound).

#513 Margolin, E. "A Lawyer's View of Invented Memory: The Ramona
Case"The Champion.  Jan./Feb. 1996                             $3.00
  Overview: how memory works, how it can be manipulated, what
  "repressed memory" is, and the importance of the 3rd party Ramona
  case in causing mental health workers to re-examine their support
  for the "repressed memory" hypotheses.

/                                                                    \
| FREE LIBRARY DISPLAYS are now available through SIRS Publishers.   |
| Call 1-800-232-7477. This is an attractive and positive way to     |
| inform people about the many new books that are now available      |
| about false memories and the devastating effects this is having on |
| families.                                                          |

                       NEW ARTICLES OF INTEREST

  ABRAMS, STAN "False Memory Syndrome vs. Total Repression." Journal
of Psychiatry & Law. Summer 1995.  A polygraph was used to test
alleged child abusers accused on the basis of recovered memories vs
those whose purported victims experienced no repression. The former
group was found to be deceptive in only 4% of the cases in contrast to
78% for the latter group.
  CREWS, FREDERICK "The Verdict on Freud." Psychological Science
Vol. 7, No.  2, March 1996. In this book review of Malcolm Macmillan's
"Freud Evaluated: The Completed Arc," Crews declares that the product
of Freud's efforts proved to be a pseudoscience.
  DUBOIS, STEPHANIE and PERSINGER, M.A. "Personality profiles of women
who report and who do not report physical assault or sexual
harassment: comparisons with traumatic brain injury". Social Behavior
and Personality, Vol. 24, No. 1, 1996. In this study, the groups
reporting a history of physical assault or who had sustained brain
trauma displayed significantly higher scores that infer egocentricity
and deviations from rule systems than the group reporting no history
of assault.
  FUTRELLE, DAVID "The Mouths of Babes". Chicago Reader 25(23). March
15, 1996. Gerald Hill was charged with hundreds of counts of sexual
assault, injecting his children with drugs and feeding them rats and
roaches. This article examines press coverage of this and hundreds of
other cases of fantastic stories including SRA and repressed memory.
  HALLER, KARON "Satan's Theater". Connecticut Magazine. April, 1996.
In addition to pointing out the inaccuracies of the information
provided to legislators by survivor groups that resulted in
Connecticut changing its statute of limitations, this is a fascinating
anatomy of the B v S lawsuit
  HIPP, DEB "Rare Everywhere but here, MPD is being called an
'American Disease'". PitchWeekly. (Kansas City) November 30, 1995.
Peppered with quotations from interviews with professionals having
opposing views, as well as with retractors, this article describes the
controversy around the MPD diagnosis.
  HIPP, DEB "When evil resides within the therapist". PitchWeekly,
(Kansas City) March 7, 1996.This well-researched article uses personal
stories to tell how families are devastated by accusations of satanic
ritual abuse as a result of "memories" of heinous acts uncovered in
  HUBNER, JOHN "Not my brother's keeper". San Jose Mercury News. March
17, 1996.The author poignantly describes how his brother, a minister,
renounces his family and claims satanic ritual abuse as a young child,
abuse the author knows did not occur.
  KIESLING, ANGELA "Digging up the Pain". Charisma. February 1996.
This Christian magazine tells how some Christian counselors promote
the practice of retrieving "buried memories" through prayer and
psychotherapy, and how this practice hurts more people than it helps.
  LUEDERS, BETH "Total Recall". Aspire. May 1996 .Written from a
Christian perspective, this article relates how the pursuit of
psychological treatment can lead to divergent memory lanes. The
differing experiences of two young women with repressed-memory therapy
are depicted, as well as interviews with several Christian therapists.
  NEIMARK, JILL "Dispatch from the Memory War". Psychology Today,
March/April 1996.Neimark addresses the details of the smear against
E. Loftus and asks why Loftus is the object of such a campaign. As a
scientist, unshakable, she has broken the taboo -- "the misguided
feminist cause of other women as victims."  
                                - - -
  The Fall 1995 issue of The Journal of Psychiatry and Law is a
collection of papers presented at the Hopkins/FMSF Baltimore
Conference: "Memory and Reality."  The following articles are
included: ELIZABETH LOFTUS and LAURA ROSENWALD - "Recovered Memories:
Unearthing the Past in Court"; HARRISON POPE and JAMES HUDSON - "Does
Childhood Sexual Abuse Cause Adult Psychiatric Disorders?  Essentials
of Methodology"; RALPH SLOVENKO - The Duty of Therapists to Third
Parties" ; HAROLD LIEF and JANET FETKIEWICZ - "Retractors of False
Memories: The Evolution of Pseudomemories" ; MICHAEL KENNY - "The
Recovered Memory Controversy: An Anthropologist's View"; STEPHEN
D. LINDSAY and DEBRA POOLE - "Remembering Childhood Sexual Abuse in
Therapy: Psychotherapists' Self-reported Beliefs, Practices, and
Experiences"; STEVE PAUL MOEN - "Consequences of the Therapist's Claim
"I'm Not a Detective'."
  To order this issue, at $14.00 per copy, contact: Federal Legal
Publications, Inc., 157 Chambers Street, New York, NY 10007; (212)
                                - - -
  PSYCHOANALYTIC DIALOGUES, 6(2), 1996 is devoted to a symposium on
the "False Memory" controversy, with the commentators providing a
range of considerations and points of view.  We expect to publish a
review of this special issue soon.  Articles include: ADRIENNE HARRIS
- "False Memory? False Memory Syndrome? The So-Called False Memory
Syndrome?"; JODY MESSLER DAVIES - "Dissociation, Repression, and
Reality Testing in the Countertransference: The Controversy Over
Memory and False Memory in the Psychoanalytic Treatment of Adult
Survivors of Childhood Sexual Abuse"; Commentary on Papers by Davies
and Harris: C. BROOKS BRENNEIS - "Cause for Skepticism About Recovered
Memory"; FREDERICK CREWS - "Forward to 1896?  Commentary on Papers by
Harris and Davies"; DONNEL STERN - "Dissociation and Constructivism";
and Replies to Commentaries:; ADRIENNE HARRIS - "The Anxiety in
Ambiguity"; JODY DAVIES -"Maintaining the Complexities".
  The single issue price is $17.50, and can be ordered from: The
Analytic Press, Inc.; 101 West Street. Ste. 15; Hillsdale, NJ 07642
                         CONTINUING EDUCATION

  Terence Campbell, Ph.D., a member of the Foundation's Professional
and Advisory Board, is the featured presenter at a continuing
education program, "Appropriate Standards of Care in Working with
Memories." Psychologists and Social Workers can earn seven continuing
education credits. The program will be held in Stiteler B 21 on the
UNIVERSITY OF PENNSYLVANIA CAMPUS. Members who register by May 10 pay
the reduced $60.00 fee (non-member's fee $80.00). For registrations
received after May 10, member's fee is $75.00 (non-members $95.00).
For a brochure, call the Foundation at 215-387-8663 (or 800-568-8882).
Please specify that you want a brochure and leave your full name and a
complete address including zip code.

/                                                                    \ 
|                  SAN DIEGO AUDIO TAPES AVAILABLE                   |
|                                                                    |
| Audio tapes from the highly successful FMSF/Johns Hopkins          |
| conference held in San Diego on March 30, 1996 can be purchased    |
| from Aaron Video.                                                  |
|                                                                    |
| The tapes are approximately 90 to 120 minutes long and cost $8.00  |
| (US) per tape [Ohio residents add 7% sales tax].                   |
| TAPE 1 features Elizabeth Loftus, Ph.D. and Pamela Freyd, Ph.D.    |
|   who discuss current experimental research and detail the scope   |
|   of the problem.                                                  |
| TAPE 2 focuses on clinical research with Jason Brandt, Ph.D. and a |
|   panel (Drs.  McHugh, Loftus, Brandt and Freyd's) conversation    |
|   with the audience.                                               |
| TAPE 3 is a presentation by Paul R. McHugh, MD on the standards of |
|   care.                                                            |
| TAPE 4 is devoted to family issues and reconciliation and is led   |
|   by John Hochman, MD. This tape is largely an interview conducted |
|   by Allen Feld, LCSW with a retractor, Diana Anderson and her     |
|   sister, Elizabeth Erickson.  Dr. McHugh's concluding remarks are |
|   also part of tape 4.                                             |
|                      Aaron Video's address is                      |
|               6822 Parma Park Blvd. Parma, OH 44130                |
|           The phone is (216) 886-0923 [fax 216 478-8949]           |

/                                                                    \
|                           Special Thanks                           |
|                                                                    |
| We extend a very special "Thank you" to all of the people who help |
| prepare the FMSF Newsletter.                                       |
|                                                                    |
|   Editorial Support: Toby Feld, Allen Feld, Peter Freyd            |
|   Research: Merci Federicia, Michele Gregg, Anita Lipton           |
|   Notices: Valerie Fling                                           |
|   Production: Frank Kane                                           |
|   Columnists: Katie Spanuello and                                  |
|       members of the FMSF Scientific Advisory Board                |
|   Letters and valuable information: Our Readers                    |

                       August Piper, Jr., M.D.

  The February edition of this column was entitled "A special delivery
of some food for thought." Apparently the article provided food energy
for writing as well as thinking, because it generated several letters.
Today, we sample readers' responses. We will continue next month.
                               * * * *
  A question in the February column asked why therapists treat
patients in ways that promote false memories. This question intrigued
a reader from Washington state, who wrote a dignified but provocative
reply. She says the field of psychotherapy in general has contributed
to the false memory syndrome phenomenon because of:
  1) the lack of objective, scientific research-based diagnostic and
     treatment guidelines and standards.  Because of this deficiency,
     the kind of therapy a patient receives depends less on the
     patient's diagnosis than it does on the psychotherapist's
     theoretical orientation;
  2) the lack of educational and training standards for practitioners
     and the lack of education in salient other fields such as social
  3) the lack of objective documentation of therapy sessions. This
     results in therapists being able to claim credit for any benefits
     of the treatment, with- out needing to be concerned about being
     required to produce concrete evidence (such as audiotapes) to
     provide proof of what really took place in the ses- sions;
  4) the apathy and tolerance of many professionals toward colleagues'
     incompetence and improprieties, combined with the lack of
     external social controls on the profession; and
  5) the attitude of many mental health proessionals toward patients
     that, because they are patients, everything they feel, say, or do
     is explainable by the patient's pathology.

  These statements answer the question of how a therapist _could_
treat patients in ways that are harmful. However, the real spirit of
the February question seemed to be why _would_ a therapist do so.
  The writer from Washington also described some goings-on at a
well-known mental health center in the Seattle area:

  at this center, we were specifically told (in addition to other
  nonsense) that there are several satanic cults and witches' covens
  in our area where infants are being murdered and children horribly

She enclosed 26 pages from a social psychology textbook. Among other
fascinating points, the book warned about "Barnum Descriptions" --
named for P.T. Barnum, who believed "there's a sucker born every
minute." Such descriptions are recipes for impressing patients:

  * give people a subjective test;
  * make them think that its interpretation is unique to them;
  * and, drawing upon things true of most people, tell them something
    that is ambiguous.

Here's an example:

  You have a strong need for other people to like you and for them to
  admire you. You tend to be critical of yourself, and have a great
  deal of unused energy that you have not turned to your advantage. At
  times you seriously doubt whether you have made the right decision
  or done the right thing. You have found it unwise to be too frank in
  revealing yourself to others.

  Research shows that if people are told that descriptions like the
above are designed, on the basis of psychological tests or
astrological data, specifically for them, they will say the
description is very accurate. (In fact, given a choice between a fake
"Barnum description" and a real personality description based on a
bona fide test, people tend to say that the phony description is more
  The textbook also warns that people can easily be induced to give
information that fulfills the expectations of the treating
clinician. This "confirmatory bias" is responsible for many self-
confirming beliefs in psychotherapy. For example, consider a therapist
who strongly believes that gay adult males had poor relationships with
their mothers. Studies show that such practitioners may meticulously
probe for recalled -- or fabricated -- signs of tension between gay
patients and their mothers, but neglect to perform a similarly-careful
review of their heterosexual patients' relationships with their
  This material has obvious relevance to concerns of the FMSF. Barnum
descriptions play a significant role in the current overdiagnosis of
multiple personality disorder cases. That is, proponents of MPD
actually say that having significant mood swings, speaking in a
childlike voice during therapy sessions, or sometimes dressing in
bright colors may signal MPD. Barnum descriptions also play a
significant role in the current overdiagnosis of sexual abuse based on
"repressed memories." That is, trauma-search therapists actually say
that being unable to remember what happened in the fifth grade,
experiencing discomfort when using public bathrooms, or not liking to
have water on your face when swimming or bathing may signal past
sexual mistreatment.
  Before closing, I thought it would be good to acknowledge the
compliments from a California reader. He thought this column was as
pleasurable to read as his favorite (but now defunct) comic strip,
"Calvin and Hobbes." Because I too used to wait every day to see what
Calvin and his funny stuffed tiger would do, I consider this quite a

  August Piper, M.D. is in private practice in Seattle, Washington.
  His book on multiple personality disorder will be published in the
  summer of 1996. He is a member of the FMSF Scientific and
  Professional Advisory Board.

/                                                                    \ 
|               NATIONAL PUBLIC RADIO, WEEKEND EDITION               |
|   A Delusion of Satan: The Full Story of the Salem Witch Trials    |
|                             Doubleday                              |
|       Discussion with author Frances Hill , October 29, 1995       |
|                                                                    |

|   LIANE HANSEN: This was a case of mass hysteria. We had political,|
| social, theological, historical reasons for it happening. One of   |
| the interesting points that you make in your book, and I think one |
| of the reasons you actually wrote it, is that it could happen      |
| again. Could it?                                                   |
|   FRANCES HILL: Indeed, yes, it certainly could. I mean -- and to  |
| some extent it is happening. There are all these cases now of      |
| recovered memory where people think they remember abuse, which was |
| so traumatic they'd repressed the memories of it when there is no  |
| evidence that the abuse took place and what is happening is that   |
| there are therapists, counselors, people in their church, social   |
| workers, whomever, suggesting to them that this abuse might have   |
| taken place.  Sometimes they go into hypnosis. Sometimes they go   |
| into trance-like states. They start to think they remember these   |
| things, and I'm sure the same thing happened in the prisons in     |
| Salem -- that the minister would go in, he would talk to the women,|
| he would say,"But didn't you see the devil?"  and "What did the    |
| devil look like?" and "Where did you go?" and their imaginations   |
| would start to work. And in those conditions, in prison conditions |
| where they were cold, hungry, probably deprived of sleep, it would |
| be so easy for that to happen, especially when they had the        |
| tremendously strong motive that if they confessed they wouldn't be |
| hanged.                                                            |

                             LEGAL CORNER
                              FMSF Staff
 Maine's Highest Court Prohibits "Repressed Memory" From Providing a
     Basis for the Application of Equitable Estoppel to Toll the 
                        Statute of Limitations!

  (Equitable estoppel is a principle of law which allows a plaintiff
  to extend the statute of limitations if the defendant acted in such
  a manner which actually induced the plaintiff not to take any legal
  action which could have been taken. To rely on this doctrine, the
  plaintiff must demonstrate that she intended to seek legal redress
  but failed to do so specifically because of the defendant's conduct.)

  The Supreme Judicial Court of Maine, that state's highest tribunal,
issued a unanimous opinion on April 8, 1996 in Nuccio v. Nuccio, 996
Me. LEXIS 82, holding that "repressed memories" could not serve as the
basis for the application of the legal doctrine of equitable estoppel
to toll the statute of limitations. The United States Court of
Appeals, First Circuit, a federal court, seeking guidance on Maine
law, had certified the following question to the Maine court: "Does a
showing that a plaintiff, who was the victim of childhood sexual
abuse, suffered repressed memory as a result of a defendant's threats
of violence and generally violent nature, her witnessing acts of
violence by the defendant and her fear of the defendant, provide a
basis for the application of equitable estoppel so as effectively to
toll the statute of limitations during the period that the plaintiff's
memories remain repressed?"
  To have a full understanding of the significance of this decision
and how this litigation landed in state court, a review of the case
history is in order.
  In 1992 Kathleen Nuccio, age 42 at the time, filed an action in
federal court against her father, Luke, seeking compensatory and
punitive damages as a result of his having allegedly sexually abused
her from the age of 3 to the age of 13 and threatening to cut her
throat if she told anyone. She claimed to have repressed all awareness
of her father's purported abuse until her memory was triggered by a
dream. Plaintiff claims that the repression was the result of her
father's threats and violence. The record reflects Ms. Nuccio's
independence and level of over-all functioning in the years prior to
her filing this claim.  She graduated in the top 15% of her high
school class, completed college in 1972, earned a masters degree in
social work in 1973 and a doctorate in 1987. She held a variety of
professional posts, including that of a college professor, a
caseworker, research assistant and consultant. Personally, she managed
her own financial affairs, purchased real estate on several occasions,
participated in political campaigns, and had intimate relationships.
Since 1970 she has been treated as both an inpatient and outpatient
for numerous psychological afflictions, including depression, multiple
personality disorder, and post traumatic stress disorder. She cited
stress or workplace pressure, depression and mental illness as reasons
for leaving various positions and discontinuing consulting assignments
in 1993. In 1994 she left her tenured position as an associate
professor at the University of Minnesota.
  The trial court granted the father's motion for summary judgment so
that the case never went to trial, ruling that her claim was barred by
the statute of limitations. It was not persuaded that Ms. Nuccio had a
mental illness which prevented her from filing or that equitable
estoppel prevented her father from raising the statute of limitations
as a defense. From this adverse ruling dismissing her case on motion,
Ms. Nuccio appealed.
  The federal appellate court in Nuccio v. Nuccio, 62 F.3d 14 (1st
Cir. 1995), certified the question set out above to the Supreme
Judicial Court of Maine since there was no clear, controlling
precedent in that state on the issue. The reason the federal court
sought guidance can be gleaned from its comment:
  "Cases involving repressed memory stemming from alleged childhood
sexual abuse have appeared in increasing numbers in recent years. We
are convinced that the question is of considerable prospective
importance. Thus, the Supreme Judicial Court of Maine should be given
the opportunity to resolve the issue."
  In its opinion, the Maine court pointed out that, unlike at trial
level, the daughter was not pressing her claim that she had a mental
illness. In addressing the certified question, the court wrote that
"equitable estoppel is a doctrine that should be carefully and
sparingly applied" and "requires clear and satisfactory proof." The
caution is justified in balancing the need to "provide potential
defendants with the assurance of eventual repose from claims made
stale by the passage of time." The court held that Plaintiff's claim
was insufficient to invoke the equitable estoppel doctrine. "There was
no evidence in this record that Luke continued to utter threats or
display violence toward Kathleen when, by reason of her majority, she
was no longer under his control.  Accordingly, the fact that she
suffered repressed memory as a result of the previously imposed
violent conduct does not at this time equitably estop Luke from
invoking the statute of limitations....The victims claims accrue at
the time of the alleged abuse or when the victim reaches the age of
          Issue of duty owed to a third party to be reviewed 
                    in two repressed memory cases
  Two recent cases brought by third parties argue that when a third
party is directly injured by the practice of scientifically unproven,
dangerous, experimental therapy or negligently administered
traditional therapy, the granting of third party standing is
justified. In cases where the misdiagnosis of childhood sexual abuse
is made, and where false memories are negligently implanted or
reinforced by a health care professional, the patient may be unwilling
to bring an action against the therapist on her own behalf or
incapable of perceiving the injury to herself and her family. If an
injured third party were not granted standing in these cases, the
falsely accused parent would be rendered powerless to redress the
profound injury suffered and powerless to bring a measure of
accountability to the health care provider who negligently propagates
false allegations.
  The question of whether defendant therapists owe a duty to third
party plaintiffs may be heard by the 7th Circuit Court in the case of
Lindgren v. Moore [Footnote: Lindgren, v. Moore,, 1996
U.S. Dist. LEXIS 3450, March 22, 1996.  See also 1995 U.S. Dist. LEXIS
15140. ] On April 1st, the defendant therapists filed a petition for
leave to appeal with that court.  However, at the time of this
writing, the 7th Circuit has not decided whether it will hear the
  In a September 1995 memorandum opinion, the U.S. District Court had
dismissed 2 of the 5 counts (malpractice and negligence) against the
therapists but had allowed 3 others to stand (Intentional Infliction
of Emotional Distress (IIED), Loss of Society, and Public Nuisance).
Then in March 1996, the court agreed to reconsider whether Illinois
law allowed a cause of action for the remaining counts of IIED and
loss of society in connection with mental health treatment provided to
an adult patient who is not a party to the claim. Though not generally
an immediately appealable order, the court granted an order certifying
an interlocutory appeal on those remaining counts.
  Originally the court had denied the motion to dismiss the IIED and
the loss of society claims because it believed the Illinois Supreme
Court would allow those claims based on the facts.  However, in the
1996 opinion, the Court allowed the appeal of its earlier order
because it agreed that the question of whether either defendant owed a
duty to the third party plaintiffs was a controlling question of law
which would require reversal if decided incorrectly and that there was
"substantial ground for difference of opinion and that an immediate
appeal may materially advance the ultimate determination of this
litigation." In other words, if the case were to go forward, any
decision in favor of the Plaintiffs could be reversed if, on appeal it
were found that Illinois law does not allow these claims. The court
agreed that the question of duty should be resolved prior to trial.
  The third-party suit was brought by the father and two siblings of
Amy Lindgren against her therapist and the therapist's supervisor "for
inducing what has been labeled as 'False Memory Syndrome.'" Plaintiffs
allege that although Amy originally sought treatment in 1990 for
depression and bulimia, unlicensed therapist Janet Moore used various
clinical psychological methods to treat the daughter, including
hypnosis. As a result of the treatments, the daughter began having
"flashbacks" of being sexually abused by her father, one of the
plaintiffs.  Plaintiffs deny that any such events ever occurred. Amy
is not a plaintiff in this action.
  Plaintiffs maintain that not only was Moore's treatment of Amy not
proper for the disorders she suffered, but that the therapist took
advantage of Amy's mental state in using "Recovered Memory" therapy.
In addition, they challenge the use of such methods in general as
being unreliable and improper under the circumstances.  These
allegations formed the basis of the negligence and malpractice claims.
On 9/29/96, the Court dismissed the malpractice and negligence counts
holding that under Illinois law [Footnote: citing Kirk v.  Michael
Reese Hospital, 117 Ill.2d 507, N.E.2d 387 (1987). The Kirk court
expressed its concern about extending a doctor's duty of care beyond
the patient to the general public because the duty would extend "to an
indeterminate class of potential plaintiffs." at 399.], absent a
"special relationship", the plaintiffs did not have standing to sue.
  Plaintiffs also allege that the defendants "falsely convinced Amy
that she was abused by [her father] in the course of 'therapy.'" The
therapist knew, or had reason to know that such a course of treatment
would ultimately lead to destruction of the family unit and permanent
estrangement of the daughter from the rest of her relations. Before
the treatment, all the plaintiffs had maintained close, enjoyable
relationships with Amy. These claims are the basis of charges of
intentional infliction of emotional distress (IIED) and loss of
society. The fifth cause of action, public nuisance, was based on the
allegation that while Moore practiced as a psychologist, she did
nothing to affirmatively indicate that she was not, in fact, a
clinical psychologist.
  The 1995 opinion noted that determination of whether the conduct on
which the IIED claim is based was "extreme or outrageous" is
objectively made on a case-by-case basis and that "the methodology of
'recovered memories' will undoubtedly play a role." The court also
referred to Dralle [Footnote: Dralle v Ruder, 124 Ill. 2d 61, 529
N.E. 2d 209 (1988). ].for support of the decision that an intentional
tort involving direct interference, such as IIED, would be allowed by
the Illinois Supreme Court. Furthermore the Court likened the facts of
this case to those of Sullivan v. Cheshire [Footnote: Sullivan
v. Cheshire, 846 F. Supp. 654 (U.S. Dist., N.D. Ill., 1994). ].in
which the patient is convinced that the sexual abuse had occurred and
was therefore not likely to bring a suit against the doctor so that
only the injured third party was able to take action. These
circumstances, the court felt, were unlikely to result in the
multiplicity of claims feared by the Dralle court.

  In a case of first impression in California [Footnote: Father
v. Social Worker, California Court of Appeal, Fourth Appellate
District, Div. 3, Case No. GO16875. See FMSF Brief Bank #41.] a
plaintiff father charged a defendant social worker with professional
negligence, alleging that "without the proper education, training or
licensure authority" she diagnosed his daughter as being a victim of
repressed memories of childhood sexual abuse. Defendant therapist
advised the daughter that her mental and psychological problems were
the direct result of the alleged abuse and that she suffered from
"body and cell memories" which were accurate and confirmed the
abuse. Plaintiff charges that defendant social worker encouraged the
daughter to take legal action against her father and that defendant
knew or should have known that charging plaintiff with a crime of
childhood sexual abuse foreseeably endangered plaintiff's reputation.
Because of the foreseeable nature of the injury and the close
connection between therapist's conduct and the father's injury, a duty
was owed to plaintiff.
  The Plaintiff father appealed an order of dismissal, dated 9/20/94,
after the trial court sustained defendant's demurrer to complaint
without leave to amend.  One of the issues presented for consideration
to the California Court of Appeal, 4th Appellate District is whether
the therapist owes a duty to Plaintiff not to falsely diagnose him as
a child sexual abuser, despite the absence of a professional
therapeutic relationship between therapist and father. The case has
been fully briefed but a date for oral arguments has not yet been
  The National Association of Social Workers (NASW) filed an amicus
curiae brief in the matter, arguing that "expanding the social
worker's duty of care to include third parties when the social
worker's diagnosis is that the patient is a victim of child abuse
would be unreasonable." The brief of the NASW further argued that
allowing a "duty of care" in this situation would eventually "widen
the scope of duty well beyond the current standard and open the social
worker to conflicts in complying with child abuse reporting statutes."
Plaintiff argues that under special circumstances when the patient
herself does not recognize the injury, only the injured third party is
able to hold the therapist liable for his or her actions. As the
Plaintiff's Opening Brief eloquently concludes, "Without granting the
injured father standing in these cases, the falsely accused parent is
powerless to redress the profoundly tragic injury suffered and
powerless to bring a measure of accountability to the health care
provider who negligently propagates false allegations. The ruling of
the Trial Court in this case effectively bars the father, as a direct
victim of the therapist's negligent and wrongful conduct, from any
source of redress for his damage. This is wrong."  
               Ex-teacher wins new trial on sex charges 
          The Vancouver Sun, by Larry Still, March 19, 1996
  The British Columbia Court of Appeal says a trial judge erred in
denying the accused adequate access to a complainant's therapeutic
records. The unanimous decision by the court (Regina v. Kliman, Case
No. CA 18381, 3/18/96) said that defendant Kliman had been deprived of
the right to a fair trial because the production of adequate records
is essential to a case in which the defense contends that therapy
sessions improperly influenced the retrieval of memory. A new trial
was ordered.
  Michael Kliman was convicted in 1994 of 5 sex-related offenses
involving 2 young female students. The offenses were alleged to have
occurred between 1974 and 1977 at the school where Kliman taught.
Defense attorney Ace Henderson tried to show that one of the
complainants, because of therapy aimed at reviving hidden memories,
had difficulty distinguishing fact from fiction. During the appeal,
Kliman's new lawyer, Michael Carroll, noted one of the complainants
had no recollection of the assaults until 1992, when she underwent
counseling by a clinical psychologist. One of the purposes of the
counseling was to bring back memories of childhood sexual abuse.
  The trial judge, following the principles applicable at the time of
trial, ordered a restricted set of therapy notes be made available,
which in this case, amounted to only one page of clinical
notes. Justice Hugh Legg, writing for the Court of Appeal, stated, "I
consider that the learned trial judge erred in denying the appellant
sufficient access to the records...when it was apparent that these
records may have cast doubt on [the complainant's] ability to testify
accurately. The rulings also limited the ability of the defense to
demonstrate that [the complainant] was either confused or fantasizing
with respect to specific allegations." The court noted a recent
Supreme Court of Canada case which set guidelines for the production
of records in sex-offense cases.
 California jury awards plaintiffs $1.1 million   after judge rejects
            motion to hold a pre-trial Kelly/Frye hearing
  An Orange County jury awarded two women $1.1 million in compensatory
damages but only $1 each in punitive damages. The suit (Wilson and
Nemeth v. Phillips, Superior Ct., Orange Co., CA, Case No. 636967) was
brought by two sisters, each of whom claimed to have recovered
repressed memories of childhood sexual abuse by their father. The
defendant father adamantly denied the allegations.
  Following an eight week-long trial, the jury took 3 days to reach a
verdict, voting 10-2 in favor of Wilson and 9-3 in favor of her
sister. According to the Los Angeles Times (4/11/96), juror Bob
Bloough said he found conflicting testimony on both sides of the case,
but that jurors felt bound to rule for the sisters if there was at
least a 51% chance they had been abused. "There was a chance he did
it, but it is not clear," he said. "Based on the chance that he did,
the [sisters] were given the ability to recover. That's all this
verdict means."
    The defense presented several pre-trial motions seeking to limit
the use of the repressed memory testimony.  A motion to hold a pre-
trial Kelly/Frye hearing on the reliability of repressed memory was
rejected by Judge Bryan McMillan. The judge also rejected a pre-trial
motion aimed at limiting the prejudicial impact caused by prematurely
labeling the plaintiffs' claims as "memories." The motion argued that
by referring to the claims as "memories" rather than, for example,
"mental images" prior to their being proven to be more than mere
"mental images" usurped the role of the jury. The role of the jury is
to decide whether the claims were, in fact, memories of actual events
or were simply confabulation or fantasy.
  At trial, the defense expert witness testimony was presented through
the cross-examination of the plaintiffs' experts. For example, a
psychopharmacologist who had treated plaintiff Wilson testified that
on the maternal side of her family, there was an extensive history of
bipolar and manic depressive disorders so it could not be determined
with certainty whether plaintiff Wilson's symptoms were the result of
the alleged abuse or were genetically influenced. Plaintiffs' experts
included psychologist Diana Elliott who testified regarding the
"classic symptoms" of abuse. Other family members testified that the
defendant had been seen in "compromising situations" with the girls.
  Defense attorney Gerald Blank of San Diego intends to file a motion
for a new trial based largely on the judge's denial of a request for a
special hearing to consider the admissibility of expert testimony
based on recovered memory therapy.  If that motion is unsuccessful, an
appeal may be filed.  
 Florida Court of Appeals upholds dismissal of repressed memory case 
                 as barred by statute of limitations.
  The Florida Court of Appeals (Boyce v. Cluett, 1996 Fla. App. LEXIS
3325, 4/3/96) held that a Florida Statute of Limitations enacted in
1992 (95.11(7)) could not be applied retrospectively to claims which
had been barred under an earlier statute (95.11(3)(O)). In this case,
a step-daughter, age 33, had sued her step-father for childhood sexual
abuse she claims to have uncovered in 1990 through psychological
counseling. In 1995, the trial court had dismissed the claim as time-
barred and awarded attorney fees to the defendants. The Court of
Appeals affirmed the dismissal. The court rejected Plaintiff's claim
that the financial support given to the daughter by her parents
amounted to continuing control over her which should estop the
defendants from asserting the statute of limitations defense. The
court noted that the weight of case law rejects Plaintiff's
position. [Footnote: See, e.g., Burpee v. Burpee, 578 N.Y.S.2d 359
(N.Y.App. Div. 1991); Schmidt v. Bishop, 779 F.Supp. 321
(S.D.N.Y. 1991); Bailey v. Lewis, 763 F.Supp. 802 (E.D.Pa. 1991);
Hewczuk v. Sambor, 803 F.Supp. 1063 (E.D.Pa. 1992).  The FMSF Summary
of Legal Resources, Chapter VIII contains a summary of case law
regarding the doctrine of equitable estoppel in repressed memory
       Ex-police captain's rape trial set to begin this summer
         Providence Journal  by C.J. Chivers, April 16, 1996
  A criminal case based on a 28-year-old woman's alleged "flashbacks"
of repeated rapes during the 1970's by her step-father is set for
trial in July.  The defendant, former police captain Anthony Rubino,
has maintained his innocence. On 4/15/96, Associate Justice Frank
J. Williams denied a motion to block evidence derived from the alleged
victim's "repressed" memories, saying that the credibility of the
evidence is a matter for a jury to decide. Judge Williams wrote, "The
burden is on the state to prove Rubino's guilt beyond a reasonable

         Therapist's certificate revoked in 'demon' diagnosis
         The Arizona Republic by Jodie Snyder, April 7, 1996
  A therapist accused of telling his client she was possessed by
demons has had his certificate to practice revoked by the Arizona
Board of Behavioral Health Examiners. The revocation, which is the
board's most severe punishment, followed an investigation into the
treatment of a patient of Alfred Ells, director of the House of Hope
(formerly Samaritan Counseling Services) in Scottsdale, AZ.  According
to the patient, instead of counseling her for post-traumatic stress,
Ells almost had her believe that her father sexually abused her, that
her church had satanic rituals, and that she was possessed by
demons. Board members said that after reviewing the details of this
case, they believed he was guilty of both unprofessional conduct and
gross negligence.
  Ells was already on one year's probation because of complaints by
relatives of five patients who said therapists working under Ells
wrongly convinced patients that they were abused as children. There
are two malpractice suits brought by former patients currently pending
against Ells. Ells has denied the allegations, saying that his actions
were misinterpreted and that he plans to continue his practice,
because the state doesn't require therapists to be certified.
               Psychologist loses bid to regain license
                             March, 1996
  A malpractice suit brought in 1993 against Sacramento clinical
psychologist Richard J. Boylan by three former patients has been
settled out of court and the terms are confidential. The former
patients also complained to the California Board of Psychology, which
last year revoked Boylan's license. In addition, Boylan's licenses as
a child counselor and clinical social worker were revoked by the Board
of Behavioral Science Examiners. In January, Boylan went to court
arguing that his licenses had been wrongly taken away. On Feb. 8, the
court turned him down.
  The three former patients alleged that Boylan had used his belief in
extraterrestrial life and UFOs to diagnose and treat their emotional
problems. The women claimed Boylan's counseling left them dependent
upon him as a "father-like figure," and that he asked them to join him
in nude exercises.  Boylan denied the sexual allegations and defended
his therapy as meeting acceptable standards.

       False bills, diagnoses cost doctor $1.5 million, prison
          The Boston Globe by Judy Rakowsky, March 23, 1996
  A Massachusetts psychiatrist who invented diagnoses, session notes
and bills for patients he never saw was sentenced March 22 to nearly
four years in a federal prison camp and ordered to pay $1.5 million in
fines and restitution. Dr. Richard P. Skodnek used the diminished
capacity defense, but a jury convicted him of 136 counts of
fraud. U.S. District Judge Nancy Gertner said that the false records
Skodnek created for his patients may haunt them for years, possibly
making it difficult to get medical insurance or a government security
clearance. "I am deeply troubled by the fact that Dr. Skodnek made up
records of family members he never saw and assessed teen-agers as drug
abusers, being sexually dysfunctional or having sexual identity
problems," she said. "It is an information age, and we cede so much to
            Psychotherapist surrenders counseling license 
              prior to hearing of California regulators
               San Diego Union-Tribune, March 21, 1996
                    John Wilkens and Jim Okerblom
  A La Mesa psychotherapist facing state disciplinary hearings has
surrendered her counseling license amid allegations that she coerced
an 8-year-old rape victim into falsely identifying her father as the
attacker. Kathleen King Goodfriend was accused by government
regulators of being "grossly negligent or incompetent" in her
treatment of the child, Alicia Wade. The California Board of
Behavioral Science Examiners said that "pressure" by Goodfriend over a
period of 13 months finally led the girl to falsely accuse her
father. As a result, her father, James Wade was arrested, charged and
faced 16 years in prison. Alicia was nearly placed for
adoption. Alicia's mother, Denise Wade attempted suicide.  Authorities
overlooked DNA evidence which proved the father had not assaulted his
daughter and disregarded a suspect already convicted of attacking
other girls in the neighborhood.
  Under the agreement that takes effect April 15, Goodfriend admits no
wrongdoing, but she will no longer be allowed to practice as a
marriage, family and child counselor in California. By law, Goodfriend
could apply for a new license in three years. But in doing so, she
would have to acknowledge that her treatment of the child was
"unprofessional" and "recklessly caused emotional or physical harm" to
Alicia, according to the agreement. "The burden would be on her to
show that she is rehabilitated," said Susan Fitzgerald, a deputy state
attorney general who prepared the case against the therapist. Although
regulators had looked forward to a full airing of the case against
Goodfriend, they felt the settlement was merited, Fitzgerald said.
  Two years ago, the Wade family settled a multimillion-dollar civil
suit filed against Goodfriend, social workers, detectives, prosecutors
and others involved in the case. The settlement was about $3.7
million. Of that, $1 million came from Goodfriend.

                            LEGAL UPDATES:
  Oral arguments were heard on Monday, April 5, 1996 in the cases DOE
v. MASKELL, ROE v. MASKELL before the Maryland Court of Appeals,
Maryland's highest court.  Among the questions the court will consider
are whether the lower court correctly held that the concept of
repressed memory does not meet the Frye-Reed standard and whether the
lower court correctly held that the theory of repressed memory does
not merit application of Maryland's discovery rule.  The 7 appellate
judges heard 90 minutes of legal arguments, but gave no indication of
when they would issue a ruling.  
                                - - - 
  The retrial of GEORGE FRANKLIN is scheduled to begin Sept. 16 in San
Mateo County Superior Court. George Franklin's daughter, Eileen
Franklin-Lipsker will testify regarding her "recovered memories" of
the murder of her childhood friend. According to the California
Lawyer, April 1996, page 19, defense attorneys hope to exclude
prosecution experts on repressed memories. Rex Bossert, the author of
the California Lawyer article writes, "Skepticism now runs so deep
[over repressed memory] that many wonder why prosecutors would even
bother to retry the case."
                                - - -
  An evidentiary hearing regarding the reliability of repressed memory
testimony has been completed before Judge Edward Harrington in the
U.S. District Court, Boston (SHAHZADE v. GREGORY). Testimony given by
Dr. Alexander Bodkin and Richard Ofshe, Ph.D. discounted the
scientific validity of repressed memories.  Dr. Bessel van der Kolk
testified that a victim's flashes of traumatic memory are reliable but
that victims do not necessarily piece the disconnected flashes
together into an accurate narrative. The plaintiff, age 68, claims she
had repressed memories of being raped by her cousin, now 75, until
after she entered therapy in 1990. At the time of this writing, no
decision has been rendered.
                                - - -
  Public record in Harris County, Texas reveals that a malpractice
suit brought by a former patient against her treating therapists and
hospital was settled as to all defendants early in March 1996. The
terms of the suit (Gornic v. Peterson, Seward, and Spring Shadows Glen
Psychiatric Hospital) are confidential.

/                                                                    \ 
| ...There is no videotape in the mind. We all have false memories,  |
| confusions of events, people, sequences, stories and even dreams.  |
| Most of the time it doesn't matter if these are true or false.     |
|   But when a parent is accused of a horrific crime it becomes      |
| critical...The gravity of the charges, usually sexual abuse,       |
| prevents the parents from reaching out for support....At this time |
| of tremendous need, the last thing they may consider is supportive |
| therapy. Increasingly they consider litigation, and they are       |
| winning against recovered memory therapists. Unfortunately, this   |
| doesn't mean they win back their children. Like a hotly contested  |
| divorce, nobody wins."                                             |
|           Michael Freeny, L.C.S.W., The Orlando Sentinel, 7./23/95 |

                             BOOK REVIEW
                       Convicting The Innocent:
              The Story of a Murder, A False Confession,
                and the Struggle To Free a "Wrong Man" 
                     Edited by Donald S. Connery
               Brookline Books, 1996, Paperback $16.95
                       Reviewer: Gary W. Schons

  Gary Schons is a Senior Assistant Attorney General and head of the
  Criminal Justice Division of the California Attorney General's
  Office in San Diego, which he joined in 1976. The views expressed in
  this review are his and do not reflect those of Attorney General
  Daniel Lungren or the California Department of Justice.

  Editors comment: Readers of this newsletter know how false memories,
  when conjured up in psychotherapy, can lead to wrongful accusations.
  The ABC movie "Forgotten Sins" that aired in March about Paul Ingram
  and Richard Ofshe gave insight into both false memories and false
  confessions. Confessions in the criminal justice system sometimes
  lead to erroneous convictions.

  In Convicting the Innocent, editor Donald S. Connery binds news and
magazine articles around a centerpiece report on the September 1995
public forum in Hartford, Connecticut convened to explore the issues
surrounding the conviction of Richard Lapointe for the 1987
rape/murder of his grandmother-in-law. Noted writer William Styron
chips in an introduction and the book finishes with the hopeful
telling of the recent pardon of Johnny Lee Wilson in Missouri and the
retrial acquittal of Rolando Cruz in Illinois, both mentally disabled
men convicted on the strength of false confessions obtained by police.
Connery is the author of Guilty Until Proven Innocent, which explored
the 1973-77 manipulated and forced confession and conviction of Peter
Reilly in Connecticut.
  On the evening of March 11, 1987, police and fire officers found
Bernice Martin's raped and strangled body in her smoldering apartment.
Lapointe, who had walked from his home nearby, discovered the fire and
called in the alarm.  Lapointe was interviewed by police and
cleared. For nearly two and a half years, police sought in vain for
Martin's killer. In June 1989, a new detective was assigned to review
the case and he soon focused on Lapointe, despite the absence of any
witnesses or physical evidence linking Lapointe to the crime. On the
Fourth of July, Lapointe voluntarily accompanied detectives to the
police department where he was read and waived his "Miranda rights"
and was accused of Martin's murder. For the next nine and a half hours
Lapointe was interrogated by three detectives without benefit of
counsel or a tape-recording. Despite repeated denials of any
involvement in the crime, Lapointe signed three separate confessions
penned by the detectives. True to their promise to release him if he
confessed, the detectives set Lapointe free and he returned home. The
next evening, after a day at his job as a dishwasher, police arrested
Lapointe and held him in lieu of $500,000 bail. Lapointe has been in
custody since.
  Lapointe languished in jail for nearly two and one-half years before
counsel was appointed to represent him. Although his defenders argued
that the confession was obtained in violation of the Miranda
safeguards and that he was so mentally damaged that he lacked the
capacity to challenge the allegations made by the police-authority
figures, Lapointe was convicted and sentenced to life in prison. His
appeal is pending in the Connecticut Supreme Court, which is expected
to rule this summer.
  At the heart of the controversy over Lapointe's confession and
conviction is the man, himself. Lapointe is a 50- year-old, 5'4" man
who wears glasses and a hearing aid which has earned him the sobriquet
of "Mr. Magoo." More critically, Lapointe suffers with Dandy-Walker
Syndrome and has an IQ just below average.  Lapointe underwent five
surgeries before age 15 to relieve symptoms of related hydrocephalus.
   (America's most well known hydrocephalus sufferer to be charged
with a major crime, Dale Akiki, who in 1991 was charged with multiple
counts of child molestation based on therapeutically retrieved
memories of 3- and 4-year-olds from a church daycare, was acquitted
after the longest and costliest trial in San Diego history. Perhaps
fortunately for Mr. Akiki, authorities were so convinced of his guilt
that despite waiving his Miranda rights and being willing to make a
statement, police and prosecutors never sought to interrogate him
about the charges.)
  Despite his mental, physical and social handicaps, Lapointe earned a
living as a dishwasher, was married to a woman who suffers from
cerebral palsy (she divorced him after the conviction), and was
raising a normal, bright son.  Lapointe had no prior criminal record
or suggestion of sexual pathology.  Fortunately, Lapointe has friends.
  Shortly after Lapointe's 1992 sentencing, citizens who had attended
his trial, including advocates for persons with mental impairments,
began meeting as The Friends of Richard Lapointe to assist in
overturning his conviction. The group's work resulted in widespread
media attention to the case. The forum attracted legal and financial
resources to battle the conviction and produced the book's centerpiece
six-hour public forum in Hartford which brought together writers,
including playwright Arthur Miller, attorneys, journalists, and
academic experts, most notably social psychologist and false
memory/confession expert Professor Richard Ofshe of Berkeley, mental
disability advocates, the falsely convicted, and ordinary, but
extraordinarily caring, citizens.
  In his preface, Connery warns that the reader will never think about
the criminal justice system in the same way again, as the reader will
be "appalled -- perhaps horrified -- by the dirtiest secret in the
darkest corner of law enforcement: 'coerced, involuntary false
confessions'," But it is hardly the horrifying secret Connery
suggests. Indeed, the book is salted with a number of cases involving
false convictions and confessions stretching over the past century. So
what does Convicting the Innocent, which acknowledges that it is an
attempt "to illuminate the whole by focusing intensely on a single
case," offer?
  Connery's work powerfully demonstrates the need for the citizenry,
enlighted, educated and empowered by its press, to keep watch over its
criminal justice system. Just as the post-War perfection of
"scientific management" divorced the man-on-the street from
understanding and controlling the institutions of business, education
and government, so too has our criminal justice system been hijacked
by a legion of attorneys who have lupine-like poured out of the
nation's law schools in the past fifty years, staffing huge law firms,
government law offices, courts, commissions, and legislative staffs.
Legal rules, arcane procedures and experts have sprouted like clover
as the "litigation explosion" has reverberated from shore to shore.
"Legal loopholes," through which the guilty escape justice, are
believed to abound, and in the only direct role in the criminal
justice system, the citizen-juror is treated like either a laboratory
animal or a mushroom. Ironically, the concept of jury service we
inherited from our English forebears was premised on the notion that
the jury, "drawn from the venire" (the local area where the crime
occurred) would be familiar both with the circumstances of the crime
and the reputation and character of the accused. While our large,
mobile society would make this goal difficult to achieve, the criminal
justice system actively roots out potential jurors with any such
knowledge. (Imagine that Lapointe had been judged by people who knew
  Active citizen involvement, beginning with the laborious talk of
"courtwatching" or"witnessing" justice is crucial. In this regard,
Connery's book proves that ordinary citizens can make a difference.
Connery might have offered the reader some insight into how the
Friends of Richard Lapointe organized and incited the writers and
experts to his cause. Such a blueprint for action in other such cases
would have been worthwhile and welcome.
  The most riveting aspect of Connery's book is his own speech before
the forum in which he declares: "This case is about abuse of power and
arrogance of power, and I take it personally."
  As a prosecutor of 20 years experience, this struck a nerve.
Ignorance is one thing, arrogance is quite another. But Connery has a
point. Why would law enforcement -- police and prosecutors -- have any
interest in convicting the "wrong man"? Aside from the moral
reprehensibility of this, convicting the wrong person means that the
right guy, a vicious murderer or sexual predator, is still out there.
And worse, why are police and prosecutors, in particular, so adamant
in defending convictions once obtained in the face of recantations,
impeachment and revelations of misconduct, to say nothing of proof of
  Lapointe's prosecutors appear unmoved by Connery and his brief. But
so is Massachusetts Attorney General Scott Harshbarger who continues
to defend the highly questionable Amirault convictions. They are not
alone in the prosecutorial community. Perhaps it says something about
today's state of affairs that in 1924 Homer Cummings, a Connecticut
State's Attorney, threw out a confession-backed case against Harold
Israel, a mentally retarded vagrant charged with murdering a priest,
and went on to become FDR's Attorney General.  More recently, the
current Attorney General conjured a confession from Ileana Fuster to
nail her husband Frank for satanic ritual child sexual abuse in the
Country Walk case while she was District Attorney of Dade County,
  In their defense, it may be offered that the arrogance of these
prosecutors is a product of the conceit of a system which in all but
the rare case in fact produces proper convictions within the
strictures of constitutional due process, including, but certainly not
limited to, the right against self-incrimination and to the assistance
of counsel. Indeed, it could be that the Miranda requirement and the
rights it protects contributes to the veneer of propriety which
infects these convictions and justifies their defenders.
  Will Lapointe and cases like it repeat themselves? Let us see: This
most recent New Year's Day, William Beason was stabbed to death in his
Rochester, N.Y. home in the course of an apparent robbery, a capital
murder. On January 6, ex-convict Douglas Warney was arrested and
subsequently signed a confession to the crime. Warney has an IQ of 68
and is delusional and suicidal as a result of AIDS-related
dementia. His confession does not square with many of the facts known
to investigators. A January 29 editorial by Bob Herbert for the New
York Times reports that Monroe County prosecutors have yet to charge
Warney, although he remains in a hospital under police guard. Perhaps
Mr. Connery should forward a copy of his book to Howard Relin,
District Attorney of Monroe County. Better yet, I will send him my
/                                                                    \ 
| "The Crucible is a play about the seductive nature of power and    |
| that seductiveness is perhaps not unconnected with a confused      |
| sexuality. The judges were people who chose not to inquire into    |
| their own motives. They submitted to the irrational with a kind of |
| perverse pleasure, a pleasure not entirely drained of sexual       |
| content. They dealt, after all, with exposure, with stripping      |
| souls bare, with provoking and hearing confessions of an erotic    |
| forthrightness that no other occasion or circumstances would       |
| permit. They saw young women cry out in a kind of orgasmic ecstasy.|
| They witnessed men and women of position, intelligence, and        |
| property rendered into their power by the confessions of those who |
| recalled abuses and assaults, revealed to them only in a           |
| religiously and therapeutically charged atmosphere. These were the |
| "recovered memories" of Puritan New England, and the irrational    |
| nature of the accusations, their sexual frisson, the lack of any   |
| proof beyond "spectral evidence" (the dreams and visions of the    |
| accusers) were a part of their lubricious attraction. When Mary    |
| Warren accused a woman, she says, "I never knew it before...and    |
| all at once I remembered everything she done to me!"  In our own   |
| time we are not so remote from this phenomenon as to render it     |
| wholly strange. Men and women with no previous memory of assaults, |
| which were apparently barbaric and even demonic, suddenly recall   |
| such abuse, more especially when assisted to do so by therapists,  |
| social workers, or religionists who offer themselves as experts in |
| the spectral world of suppressed memories. Such abuse, recalled in |
| later life, is impossible to verify, but the accusations alone     |
| have sufficed to destroy entire families. To deny reality to such  |
| abuse is itself seen as a dangerous perversion, just as to deny    |
| witchcraft was seen as diabolic in Puritan New England."           |
|                                                 Christopher Bigsby |
| Introduction to The Crucible by Arthur Miller, Penguin Books, 1995 |

                          MAKE A DIFFERENCE
  This is a column that will let you know what people are doing to
  counteract the harm done by FMS. Remember that three and a half
  years ago, FMSF didn't exist. A group of 50 or so people found each
  other and today more than 17,000 have reported similar experiences.
  Together we have made a difference. How did this happen?

  I was elated to receive a note from one of my home state senators in
response to my entreaty to amend that state's current childhood sexual
abuse statute to include evidentiary and procedural safeguards in the
language of the statute.
  My letter to the senator included a brief description of my personal
situation, i.e., that my sister was a victim of the cult-like
recovered memory movement which has wreaked havoc on thousands of
American families. I also gave a brief historical account, including
the fact that since the 1980's hundreds of civil lawsuits have been
brought based upon recovered repressed memories of childhood sexual
abuse. And, that, due to intense lobbying efforts by "victims"
organizations, more than 24 state legislatures have extended their
statute of limitations or implemented a statute of repose or delayed
discovery rule which permits repressed memory lawsuits to be brought
decades after the alleged injury.
  In my opinion, if the courts and legislatures in this country have
the facts and do their homework -- they will do the right thing (see,
e.g., Texas Supreme Court decision, S.V. v. R.V., FMSF Newsletter,
April 1, 1996, pp. 8-10). To that end, enclosed with my letter were
various articles (e.g., FMSF Publication #431), case law involving the
scientific status of repressed memories (see FMSF Newsletter, April,
1996, p. 13) and FMSF Rhode Island Amicus Curiae brief (FMSF
Publication #803) to help educate the senators on the breadth of the
problem and current scientific understanding of repressed memory
theory. Also included in the package was an article written in the
Connecticut Magazine, April 1996 Vol.  59, No.4, entitled, "Satan's
Theatre." This piece is particularly relevant because it describes a
typical repressed memory civil suit and also points out the
inaccuracies and misstatements made by "victims" organizations on
which the Connecticut legislature relied to amend their statute of
limitations for childhood sexual abuse from ages two to seventeen
years in 1992.
  As I told the senators, "[A]ssuming, for the sake of argument, that
an actual repressed memory case exists, the pain and suffering that
many wrongfully accused individuals undergo in trying to defend an
action brought decades after the alleged event outweighs, in public
policy terms, any relief which might be granted a legitimate
plaintiff. To allow claims of such serious consequences to be brought
without assurance of independent, objective, verifiable evidence,
vitiates common sense and the legal principles underlying the statute
of limitations and compromises the judicial integrity of our courts
and legislatures."
  The senator wrote that although it would not be possible to repeal
the law, to please send specific suggestions on procedural safeguards
to include in the statute. To that end, I forwarded copies of examples
of two states' childhood sexual abuse statutes, California and
Oklahoma, which contain language that, while not alleviating potential
problems entirely, attempt to protect innocent persons from defending
themselves against false allegations by requiring a higher standard of
proof and establishes procedural safeguards for bringing such suits.
For example, Oklahoma Statutes Annotated (1994), Title 12, Section
95(a) requires, "objective verifiable evidence that should include
both the proof that the victim had psychologically repressed the
memory of the facts upon which the claim was predicated and that there
was corroborating evidence that the [injury] actually occurred" and
California Code of Civil Procedure Section 340.1, was amended in 1994,
to include compliance requirements, e.g., filing certificates of
merit, for potential plaintiffs. Also, enclosed in my letter was a
recent law review article entitled, "Requiring clear and convincing
proof in tort claims involving recently recovered repressed memories,"
174 Southwestern University Law Review 25 (1995), which reviews the
legal history of cases involving repressed memories, examines the
reliability of repressed memories and argues that California should
require plaintiffs to prove the elements of tort claims involving
recovered repressed memories of childhood sexual abuse by clear and
convincing evidence (this law review article notes that most repressed
memory cases are brought in civil court because of the difficulty in
establishing guilt beyond a reasonable doubt in criminal cases).
  It's amazing that one letter could produce a dialogue between this
senator and me and, hopefully, bring about this most needed change in
the law. Like it or not, it's our duty to educate the courts and
legislatures of this country to understand what FMSF families know all
too well. This issue continues to threaten the integrity of our
judicial system and the country as a whole. I would especially like to
urge FMSF siblings, the sons and daughters of elderly, falsely accused
parents, to join me in writing your governor, senator, state senator,
representative, congressman and the President TODAY and help right
this terrible wrong. The FMSF bibliography has listings of the most
relevant and important scientific and legal research to enclose or you
may choose to simply tell your story.
                                       A Sibling and Concerned Citizen

  Send your ideas to Katie Spanuello c/o FMSF.

/                                                                    \
| When bad men combine, the good must associate; else they will fall |
| one by one, an unpitied sacrifice in a contemptible struggle.      |
|                                                       Edmund Burke |
|    Thoughts on the Cause of the Present Discontent Vol. i. p. 526. |

                           FROM OUR READERS
                  Time Wears Away "Imposter Parents"
  I watched my parents go through hell and it's difficult to even try
to make it up to my Dad. I pray everyday that if a person like me can
break away from that craziness so can others. The only thing I can
give you is hope. If anyone had told me when I was in therapy that I
was wrong and the therapist was wrong, I would have defended the
"truth" as I saw it as fiercely as I'd defend my own children. There's
no rationale when you're there, no sense of reality outside the
Therapist's belief and support, nothing to fill up the longings you
feel except to immerse yourself completely in the falsehoods you so
truly believe.  There feels like there is no escape once you're in it,
nowhere to go.
  My Dad, even knowing what I believed about him, never cut me off
even when I wasn't speaking to him and was so afraid of him. Somewhere
in my mind I knew he was still my Dad no matter how much I hated him
for what I believed he had done to me. He was there if I ever wanted
to talk to him and he never condemned me.  He was devastated, of
course, but he simply waited for 6 years for me to come back to him
and I finally did.
  I hope the parents out there going through this tragedy can get a
little glimmer of hope from people like me who were so certain of the
abuse that never existed. The question I had the most difficulty with
was: "Did I in all honesty ever stop loving my parents?" I finally
realized I never stopped loving the parents I knew, because in this
therapy you believe you've not only been horribly abused, you feel
such rage at being lied to about the parents you know were there
everyday of your life---they lied about the very basis of who they
were and are; not loving parents like you remember them being but
deceitful, selfish, liars who never loved you. The sad fact is that
parents you "remember" in therapy are the lies and the parents you
remember before therapy are, in fact, the loving parents you've loved
all your life.
  So, no, I never stopped loving my "real" parents. The ones I hated
were only fakes made up in therapy sessions by a therapist who used
all the wrong techniques. Time will wear away the "imposter parents"
and you find the real parents still there just like you truly remember
them -- and still loving them despite all the therapist's attempts to
destroy that love. I hope I'm notoverstepping here, but it's so hard
for me to see how much pain this therapy has and is causing. I will be
sending you any interesting articles I find.  Thanks again and God
                                                          A Retractor
                            Parental Crime
                                                      December, 1995
Dear Mr. & Mrs. "T"
  We are writing to demand that you cease and desist from making any
contact with out client, whether direct or indirect, through any means
whatsoever including written, oral, or in-person communication, or
communication through any other person. We also demand that you cease
and desist from contacting others in an effort to influence, interfere
with, or in any other way affect our client.
  As you know, our client has advised you on numerous occasions since
at least March, 1994 that she wishes to cease all contact with you
permanently.  Notwithstanding our client's position, you have
persistently engaged in repeated communications, both direct and
indirect, you have followed her from place to place, you have
attempted to interfere with her ability to obtain medical care and you
have generally engaged in repeated incidents of harassment against our
client. Your attempts to contact our client are offensive, abusive,
vexatious, and threatening to the point that they cause our client to
fear for her safety.
  Your conduct is unwelcome, to say the least. This should have been
abundantly clear to you given our client's communication with you
directly, and with other family members who you have caused to make
similar attempts to interfere with out client's well being.
  This letter puts you on notice that if you do not cease and desist
immediately all attempts to contact our client, either directly or
indirectly, we have instructions to take appropriate legal action.
Yours very truly, 
                                - - - 
                                                      January, 1996
Dear "Lawyer,"
  In April 1994, we received a letter in which our daughter expressed,
without any explanation, her wish to cease all contacts with us. We
respected her wish.  We did not talk to her and did not write her any
letters or cards. The only exception was her mother's attempt to see
her in December 1995. The allegations contained in your letter are
absolutely unfounded. Our daughter has not advised us on numerous
occasions that she wishes to cease all contacts with us permanently.
We were not in touch whatsoever. We have not persistently engaged in
repeated communications. We have not followed her from place to
place. We have not attempted to interfere with her ability to obtain
medical care and we have not engaged in repeated incidents of
harassment against your client. These allegations are false and
  As far as family members, friends or concerned professionals are
concerned, we have neither the power nor the right to stop them from
contacting our daughter if they wish to do so.
  In December 1995, we tried to meet with our daughter to give her a
Christmas gift. We hoped that when our daughter saw our faces, she
might be willing to sit down and talk. In December, we met your client
in the lobby of the YWCA. Once our daughter made it clear that she did
not want to talk, we respected her wish and left.
  We hope that sometime in the future, the lines of communication will
reopen because we love our daughter and we deeply care for her
                                                     Mr. & Mrs. "T"
                 What Efforts to Discredit FMSF Show
  I can think of no greater evidence to substantiate the contention of
a deliberate effort to defraud the public than the criticism your
organization has received from within therapeutic circles, and the
attempts to defame and discredit the members of your organization. If
the opponents of FMSF had any remotely genuine interest in the serious
treatment of psychological maladjustment, they would demonstrate a
will to openly discuss and debate the efficacy and propriety of the
practices which are presently being employed in treatment.  
                      Our Grandchildren Know Us
  "Our daughter made her accusations against us in the spring of 1989
and we had not seen or heard from her or her husband and our two
granddaughters in all that time. Our youngest granddaughter turned
three in 1989, and because I had already bought gifts for her and her
sister who was six, I decided to mail them. I didn't hear whether they
received them or not. Since they were not returned, I decided to send
them Christmas presents and then presents for the older child's
birthday. We did this three times a year for all these years, hearing
  Last Christmas we received a letter from each of our grandchildren!
What a surprise. They are now nine and twelve years old. The letters
were lovely and told us what they had been doing and thinking. They
thanked us for always sending the gifts. Nothing was mentioned about
their mother or father. We have since received two more letters after
the birthdays. We are so glad now that we continued sending the gifts.
I guess it doesn't work in all families, but it has in ours. My family
doctor told me when the accusations first happened that if we didn't
write to the granddaughters that they would forget us. They do know
who we are and I guess that is what is so encouraging.
                                                               A Mom
                        Forgive But Not Forget
  Our daughter appealed the decision in our favor to our state Supreme
Court. They passed it back to the Court of Appeals. This has been
dragging on since 1992. We are weary of the whole trying mess, and
needless to say, have spent thousands of dollars just to protect
ourselves from these false allegations. She injected more accusations
in the appeal. The allegations have grown worse with time and she
seems more intent on money than on the allegations.
  We have not tried to reconcile with her. We feel she initiated this
whole mess after 50 years of being close to the family. If this is
what she thinks of us, we really do not want her back. It could never
be the same. Yes, we could say that we could "forgive," which is
essential to reconciliation, but we could never forget.  
                                                     A Mom and Dad

/                                                                    \ 
|                           WRITER'S BLOCK                           |
|                                                                    |
| "I had horrible trouble with writer's block and procrastination.   |
| It had to do with being a survivor."                               |
|                Abuse suvivors break the silence U of CA Santa Cruz |
|                                 City on a Hill Press, Feb. 1, 1996 |

  If one feels inefficacious in the therapy session, that's the time
to use your numerology charts, tarot cards, astrology charts and Ouija
boards, or talk about past lives, alien abduction or satanic ritual
abuse. That will fill up the hour.

           /                                             \
           |                   An Ode                    |
           | On The Insanity Of Repressed Memory Therapy |
           |                                             |
           | If our daughter had died an untimely death, |
           | We would be granted the privilege of grief. |
           | There would be calls on the phone           |
           | And knocks on the door.                     |
           | There would be ceremony and cards,          |
           | And sympathy, and empathy, and caring.      |
           | Flowers would arrive,                       |
           | Which we might gently place upon her grave. |
           |                                             |
           | Our family would gather 'round              |
           | With staunch support upholding              |
           | To lift us when we fell                     |
           | And talk of the time which heals.           |
           | We would hear, "We are so sorry,"           |
           | "What can we do for you?"                   |
           | "Shall we bring some food,                  |
           | Some fruit, or bake a cake?                 |
           |                                             |
           | Friends would remind us                     |
           | Of the grace of her presence,               |
           | Of her laughter and her love,               |
           | Her giving inner spirit...                  |
           | Old photographs might help                  |
           | To see how she grew and prospered.          |
           | We'd say, "She had a wonderful life         |
           | Though it was cruelly taken."               |
           |                                             |
           | But to be gone and not gone,                |
           | To be stolen from us                        |
           | And her mind transformed                    |
           | Toward hatred and revenge                   |
           | For crimes never committed                  |
           | By us? Her Parents?                         |
           | Who anguished, dreamed, and loved,          |
           | Who gave her years of our lives.            |
           |                                             |
           | We cannot speak, we cannot tell             |
           | Family, friends, and others.                |
           | We fear that phone call,                    |
           | More accusations, the hatred,               |
           | The fingers which might point               |
           | And call us "horrid," "wretched."           |
           | That unwelcome knock...                     |
           | The police? Will they take us away?         |
           |                                             |
           | And so we live in terror and in fear,       |
           | Anguishing daily for her,                   |
           | for siblings, for us,                       |
           | For a family ripped apart                   |
           | By madness and conceit,                     |
           | by insanity of precept and of purpose.      |
           | Knowing she is gone -- unreachable.         |
           | Delusional and as dead to us but living.    |
           |                                             |
           |                         EGF, M.A. (c) 1994  |
                        MAY 1996 FMSF MEETINGS
  (MO) = monthly; (bi-MO) = bi-monthly; (*) = see State Meetings list


  Saturday, May 11 @1pm
    speaker:  Donald Tashjian, MD, PAPA 
  Maggie 505-662-7521 (after 6:30pm) 

PA, NJ & DE 
  Saturday, May 18- 
    Guest Quarters Hotel Chesterbrook Blvd. Wayne, PA
    Guest speakers/Panel discussion
  Jim & Jo (610) 783-0396  or Lee & Sally (609) 967-7812  

  Sunday, May 19 @ 1:15pm 
  Unitarian Church, Westport, CT 
    Speaker: Mark Pendergrast 
  Paul (203) 458-9173 

  Saturday, May 25 
    Speakers: Dr. E. Loftus & A. Gold, Esq. 
  call Ontario contacts for further info

  Saturday, June 8 @ 1-3:30 pm 
    Seminar: How We Helped Our Daughter Return
  Elly & Paul Ovrebo JoAnne (916) 933-3655


(bi-MO) Barbara (602) 924-0975; 854-0404(fax) 

LITTLE ROCK Al & Lela (501) 363-4368  

  Northern California 
      Joanne & Gerald (916) 933-3655 or
      Rudy (916)443-4041 
      (bi-MO) Gideon (415) 389-0254 or 
      Charles 984-6626(am);435-9618(pm) 
    EAST BAY AREA  (bi-MO) 
      Judy (510) 254-2605 
    SOUTH BAY AREA  Last Sat. (bi-MO) 
      Jack & Pat (408) 425-1430 
      Carole (805) 967-8058 
  Southern California 
    CENT. ORANGE CNTY. 1st Fri. (MO) @ 7pm 
      Chris & Alan (714) 733-2925
    ORANGE COUNTY -3rd Sun. (MO) @6pm 
      Jerry & Eileen (714) 494-9704 
    COVINA AREA -1st Mon. (MO) @7:30pm
      Floyd & Libby (818)  330-2321 
    SOUTH BAY AREA -3rd Sat.. (bi-MO) @10am 
      Cecilia (310) 545-6064  

  DENVER-4th Sat. (MO) @1pm
    Ruth (303) 757-3622 

    Earl 329-8365 or Paul 458-9173 

    Madeline (305) 966-4FMS
  BOCA/DELRAY 2nd&4th Thurs(MO) @1pm 
    Helen (407) 498-8684 
    Bob & Janet (813) 856-7091  

  3nd Sun. (MO) Eileen (708)980-7693  

   Nickie (317)471-0922(ph);334-9839(fax) Pat (219) 482-2847 (*) 

    Betty & Gayle (515) 270-6976 
    2nd Sat. (MO) @11:30am Lunch 

    Leslie (913) 235-0602 or Pat 738-4840 Jan (816) 931-1340  

    Dixie (606) 356-9309 
    Last Sun. (MO) @ 2pm Bob (502) 957-2378 

  Francine (318) 457-2022  

  Area Code 207 BANGOR 
    -Irvine & Arlene 942-8473 
  FREEPORT -4rd Sun. (MO) Wally 865-4044 

    Margie (410) 750-8694  

  CHELMSFORD- Ron (508) 250-9756  

    1st Mon. (MO) Catherine (616) 363-1354 

  Terry & Collette (507) 642-3630 
  Dan & Joan (612) 631-2247 

  KANSAS CITY 2nd Sun. (MO) 
    Leslie (913) 235-0602 or Pat 738-4840 Jan (816) 931-1340 
  ST. LOUIS AREA-3rd Sun. (MO)- AREA CODE    314
     Karen 432-8789 or Mae 837-1976 
  SPRINGFIELD - 4th Sat. (MO) @12:30pm 
    Dorothy & Pete (417) 882-1821 Howard (417) 865-6097  


  Maggie 662-7521(after 6:30pm) or  Martha 624-0225  

    Barbara (914) 761-3627 (bi-MO) 
    Elaine (518) 399-5749 
     George & Eileen (716) 586-7942  

    Len 364-4063        Dee 942-0531 HJ 755-3816        
    Rosemary 439-2459  

    Paul & Betty (717) 691-7660 
  PITTSBURGH -Rick & Renee (412) 563-5616 
    Jim & Jo (610) 783-0396  
  June 8 @ 1pm/July & Aug -no mtg 

  Kate (615 665-1160
  1st Wed. (MO) @1pm

    Nancy & Jim (512) 478-8395 
     Jo or Beverly (713) 464-8970 

  April 27-Keith (801) 467-0669  

  Judith (802) 229-5154  

   Sue (703) 273-2343  

  Pat (304) 269-5871(*)  

  Katie & Leo (414) 476-0285


    Ruth (604) 925-1539 Last Sat. (MO) @1-4pm 
    John (604) 721-3219 3rd Tues. (MO) @7:30pm  

  LONDON -2nd Sun (bi-MO) Adrian (519) 471-6338 
  OTTAWA -Eileen (613) 836-3294 
  TORONTO /N. YORK-Pat (416) 444-9078 
  WARKWORTH - Ethel (705) 924-3546 
  BURLINGTON - Ken & Marina (905) 637-6030 
  SUDBURY-Paula (705) 692-0600  

  MONTREAL Alain (514) 335-0863  

  Mrs Irene Curtis P.O. Box 630, 
  Sunbury, VCT 3419 phone (03) 9740 6930  

  fax-(972) 2-259282 or  E-mail-  

    Mrs. Anna deJong (31) 20-693-5692 

  Mrs. Colleen Waugh (09) 416-7443 

    Roger Scotford (44) 1225 868-682  

                   JUNE '96 Issue Deadline: May 24 
Mark Fax or envelope: "Attn: Meeting Notice" & send 2 months before
scheduled meeting.


/                                                                    \
|          Do you have access to e-mail?  Send a message to          |
|                                         |
| if  you wish to receive electronic versions of this newsletter and |
| notices of radio and television  broadcasts  about  FMS.  All  the |
| message need say is "add to the FMS-News". You'll also learn about |
| joining  the  FMS-Research list  (it distributes reseach materials |
| such as news stories, court decisions and research  articles).  It |
| would be useful, but not necessary, if you add your full name (all |
| addresses and names will remain strictly confidential).            |

  The False Memory Syndrome Foundation is a qualified 501(c)3 corpora-
tion  with  its  principal offices in Philadelphia and governed by its 
Board of Directors.  While it encourages participation by its  members
in  its  activities,  it must be understood that the Foundation has no 
affiliates and that no other organization or person is  authorized  to
speak for the Foundation without the prior written approval of the Ex-
ecutive Director. All membership dues and contributions to the Founda-
tion must be forwarded to the Foundation for its disposition.

3401 Market Street suite 130,  Philadelphia, PA 19104,  (215-387-1865)

This address and the phone numbers have changed as of July 15, 2000

Pamela Freyd, Ph.D.,  Executive Director

FMSF Scientific and Professional Advisory Board,          May 1, 1996:
AARON T. BECK, M.D., D.M.S., University of Pennsylvania, Philadelphia,
PA; TERENCE   W.  CAMPBELL, Ph.D.,   Clinical and Forensic Psychology,
Sterling  Heights, MI;  ROSALIND CARTWRIGHT, Ph.D.,  Rush Presbyterian
St. Lukes Medical Center, Chicago, IL; JEAN CHAPMAN, Ph.D., University
of Wisconsin, Madison,   WI;   LOREN CHAPMAN, Ph.D.,   University   of
Wisconsin,  Madison,  WI; FREDERICK C.    CREWS,  Ph.D., University of
California, Berkeley, CA; ROBYN    M.  DAWES, Ph.D.,  Carnegie  Mellon
University,  Pittsburgh, PA; DAVID  F.   DINGES, Ph.D., University  of
Pennsylvania, Philadelphia, PA;  HENRY C. ELLIS, Ph.D.,  University of
New Mexico, Albuquerque, NM; GEORGE K. GANAWAY, M.D., Emory University
of Medicine, Atlanta,  GA; MARTIN GARDNER, Author, Hendersonville, NC;
ROCHEL GELMAN, Ph.D., University of California, Los Angeles, CA; HENRY
GLEITMAN, Ph.D.,  University  of Pennsylvania, Philadelphia, PA;  LILA
GLEITMAN, Ph.D., University of Pennsylvania, Philadelphia, PA; RICHARD
GREEN, M.D., J.D., Charing Cross Hospital,  London; DAVID A. HALPERIN,
M.D., Mount Sinai School of  Medicine,  New York, NY; ERNEST  HILGARD,
Ph.D., Stanford University,  Palo  Alto, CA; JOHN HOCHMAN,  M.D., UCLA
Medical School, Los Angeles, CA; DAVID S. HOLMES, Ph.D., University of
Kansas, Lawrence, KS; PHILIP S.   HOLZMAN, Ph.D., Harvard  University,
Cambridge,  MA; ROBERT  A.  KARLIN, Ph.D.   , Rutgers University,  New
Brunswick,  NJ;  HAROLD  LIEF,   M.D., University  of    Pennsylvania,
Philadelphia, PA; ELIZABETH  LOFTUS, Ph.D., University of  Washington,
Seattle,  WA; PAUL McHUGH,  M.D., Johns Hopkins University, Baltimore,
MD;   HAROLD  MERSKEY, D.M., University   of  Western Ontario, London,
Ph.D., Emory University, Atlanta, GA; RICHARD OFSHE, Ph.D., University
of California, Berkeley, CA;  EMILY  CAROTA ORNE, B.A.,  University of
Pennsylvania, Philadelphia, PA;  MARTIN ORNE,  M.D., Ph.D., University
of  Pennsylvania,   Philadelphia, PA;   LOREN PANKRATZ,  Ph.D., Oregon
Health Sciences   University,  Portland, OR;   CAMPBELL PERRY,  Ph.D.,
Concordia University, Montreal,  Canada; MICHAEL A.  PERSINGER, Ph.D.,
Laurentian University, Ontario,  Canada; AUGUST T.  PIPER,  Jr., M.D.,
Seattle, WA;  HARRISON   POPE, Jr.,   M.D., Harvard  Medical   School,
Cambridge, MA; JAMES RANDI, Author and Magician, Plantation, FL; HENRY
L.  ROEDIGER, III, Ph.D. ,Rice University, Houston, TX; CAROLYN SAARI,
Ph.D.,  Loyola    University,  Chicago, IL;    THEODORE SARBIN, Ph.D.,
University of  California, Santa  Cruz, CA;  THOMAS  A. SEBEOK, Ph.D.,
Indiana University,  Bloomington, IN;  MICHAEL  A.  SIMPSON, M.R.C.S.,
L.R.C.P.,  M.R.C, D.O.M., Center for  Psychosocial & Traumatic Stress,
Pretoria,  South  Africa;   MARGARET   SINGER,  Ph.D.,  University  of
California, Berkeley, CA;  RALPH SLOVENKO,  J.D., Ph.D.,  Wayne  State
University Law School, Detroit, MI;  DONALD SPENCE, Ph.D., Robert Wood
Johnson   Medical   Center, Piscataway,  NJ;   JEFFREY  VICTOR, Ph.D.,
Jamestown Community  College, Jamestown, NY;  HOLLIDA WAKEFIELD, M.A.,
Institute  of  Psychological   Therapies,   Northfield,  MN;   CHARLES
A. WEAVER, III, Ph.D. Baylor University, Waco, TX.

                           MEMBERSHIP  FORM

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    Annual Dues for professionals ($125.00)              $________

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  U.S. dollar money order, or a check drawn on a U.S. dollar account.


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