FMSF NEWSLETTER ARCHIVE - Fall 2007 - Vol. 16, No. 4, HTML version

Return to FMSF Home Page

This text version assumes a constant-space font (such as Courier)
F M S   F O U N D A T I O N   N E W S L E T T E R     (e-mail edition)
Fall 2007  Vol. 16  No. 4
ISSN #1069-0484. Copyright (c) 2007 by the FMS Foundation
The FMSF Newsletter is published 4 times a year by  the  False  Memory
Syndrome Foundation and delivered electronically. It is also available
at on the  FMSF website:  Those without access to
the Internet should contact the Foundation.
           1955 Locust Street, Philadelphia, PA 19103-5766
                 Phone 215-940-1040, Fax 215-940-1042
       The next e-mail newsletter will be sent in late January.

Dear Friends, 

The really great news is the flood of outstanding books and papers
that enriches our understanding of false memories and the relationship
between memory and emotion. The really bad news is that many people
have not read these materials. The good news is that FMSF readers can
do something about one small area of ignorance.

Following is a sample of some of the new books and not-so-new books:

Mistakes Were Made (but not by me): Why We Justify Foolish Beliefs,
Bad Decisions, and Hurtful Acts by Carol Tavris and Elliot Aronson
(below) explains, in a most entertaining way, how the theory of
cognitive dissonance applies to the recovered memory phenomenon (and
other areas.)

Seduced by Madness: The True Story of the Susan Polk Murder Case by
Carol Pogash (below) is a page-turning story that describes a family
destroyed by their uncritical acceptance of beliefs in satanic ritual
abuse and recovered memories. It is an amazing case study.

Both The Fate of Early Memories by Mark Howe, Ph.D. and Myths of
Childhood by Joel Paris, M.D. conclude that there is no scientific
evidence to support the notion that early traumatic experiences will
necessarily have a powerful influence over adult lives. (below)
These books provide a comprehensive review of the research with

A few of the recent papers mentioned in this issue:

Simona Ghetti, Ph.D. and colleagues (below) explored the experience of
subjective forgetting to learn what it could reveal about memory for
child trauma. Among other things, they found that if child sexual
abuse "was forgotten in childhood, it was also likely to be recovered
in childhood, rather than later on in adulthood." They "found no
evidence of adult recovery of [child sexual abuse] memories."

The results of a paper by Depue and colleagues (below) and another by
Payne and Corrigan (below) seem to be contradictory. The Payne paper
found that strong emotion makes it very difficult to intentionally
forget a memory. The Depue paper, on the other hand, seems to say that
it is possible to intentionally forget an emotional memory. Who is
right? How does it affect our understanding of claims of repressed
memories? On page 2 is an excerpt from an article by Ost and Wade that
may help put the studies in perspective.

So much exciting research about memory in the past two decades! Yet,
sadly, some people in influential positions appear not to have read
anything about memory since 1988. We admit that we were shocked
(before a happy ending) when a reader recently called our attention to
the Counseling and Psychological Services section on the Carnegie
Mellon web site. 

  "If you remember being sexually violated as a child, trust your
  memories, even if what you're remembering seems too awful to be
  true. Children simply do not make these things up."

  "Whether or not you have specific memories, if you suspect that you
  were sexually abused, then you probably were."

The web page encouraged vulnerable students to consider the list of
symptoms from The Courage to Heal by Bass and Davis (1988).

  "There are many ways that people experience the harm that results
  from having been sexually abused. Consider the following questions
  (Bass and Davis, 1988)"

As long ago as 1994, the American Psychological Association and
American Psychiatric Association issued statements warning that a list
of symptoms was not a reliable way to tell if someone had been
abused. Most such lists are so vague that any normal person will have
experienced some of them at some time.

Carnegie Mellon is not the only university whose Counseling Service is
in a time warp. The University of Illinois offers similar advice

This is a dreadful state of events.

The good news is that officials at Carnegie Mellon are removing the
misinformation -- saying that the material was posted without the
appropriate vetting.

How many other university counseling service web sites have misleading
information? It's time to get to work. If each newsletter reader
checks the counseling service website of the university that he or she
attended and/or the university or universities close to where you now
reside, we should be able to get ample information. In the next
newsletter issue, we can print a list of those colleges or
universities that seem to be responsible and those that are
irresponsible. That should give us some idea as to whether this is a
selective or a widespread problem in university counseling services.
Once we have that information, we can make a systematic effort to
correct those counseling services that need to be brought into the
21st Century.

Please mail or email the information you get to: 

  Please put FMSF in the header so your message is not trapped in a
  spam filter.

  Please include the name of the university counseling service you
  check and also the web page address if you find misinformation.

One of the new tools that we will have at our disposal to help educate
those who need it is a newly published collection of family stories
from the British False Memory Society. (below) The slim book was
developed for just this purpose.

As always, we thank you for your wonderful enduring support. We thank
you for your very prompt response to our annual appeal. Only one
percent of the FMSF budget is used for raising the funds that are
needed to operate and that is because of your help.

We look forward to learning the results of your investigations into
the offerings of the counseling services of universities with which
you are familiar.
/                                                                    \
|                    Can We Forget Bad Memories?                     |
|                                                                    |
| Comments by Ost, J. & Wade, K.(2007) on Depue, B.E.,Curran, T.,|
| Banich, M.T. (2007). Prefrontal regions orchestrate suppression of |
| emotional memories via a two-phase process. Science 317, 215-219.  |
| Excerpt from British False Memory Society Newsletter, 15(2). 4-8.  |
| Full article can be found at:                                      |
|    |
|                                                                    |
| "So does this research tell us how to forget bad memories? The     |
| stark answer, despite newspaper claims to the contrary, is no.     |
| We've all had the experience of cringing, and trying to distant    |
| ourselves, when a memory for an embarrassing event suddenly comes  |
| to mind. Most of us try, often with limited degrees of success,    |
| not of success, not to think about events that upset us. This is   |
| called suppression -- and psychological research shows that we     |
| are not very good at it. This is mainly because the rule ("I must  |
| try not to think about X") contains the thing one is trying to     |
| forget. Thus, most of us cannot help but picture a white bear,     |
| when explicitly instructed not to...                               |
|                                                                    |
| "Likewise, survivors of trauma generally find it difficult not to  |
| think about the events they have witnessed. Nothing in the Depue   |
| et al. experiments suggests that people can be trained to do this  |
| more effectively... If it could be shown that people could learn   |
| to effectively 'suppress' traumatic memories -- would this offer   |
| hope for PTSD sufferers? Again -- contrary to the newspaper        |
| article -- the answer is no. Most treatments for PTSD do not       |
| involve helping survivors to 'forget' their experiences. Rather    |
| they aim to help sufferers change the way they react to, and cope  |
| with, their traumatic experiences (although PTSD itself is highly  |
| controversial; see Rosen, 2004, for excellent discussions).        |
|                                                                    |
| "More worrying, however, is the claim made in the opening lines of |
| the article by Depue et al. (2007). They state that whilst there   |
| is evidence that people actively try to suppress memories, 'others |
| claim that memory repression or suppression is a clinical myth in  |
| search of scientific support' (p. 215). This sleight of hand, in   |
| which suppression and repression are conflated, is problematic --  |
| the two terms are not interchangeable. Suppression... refers to    |
| cases where people actively try not to think about something,      |
| usually with very limited degrees of success (Anderson & Green,|
| 2001; Depue et al., 2007). Repression, on the other hand, is when  |
| an individual is allegedly unable to remember something because    |
| the mind has unconsciously blocked out any memory of the event.    |
| Years of psychological research have indicated that this is indeed |
| a 'clinical myth'                                                  |
|                                                                    |
| "Yet the work of Anderson and colleagues, and Depue and            |
| colleagues, has somehow been seized on as providing evidence that  |
| it exists. This is probably because important qualifications --    |
| such as the distinction between suppression and repression -- are  |
|  of little interest to non-psychologists and headline writers. The |
| accurate reporting of scientific findings is critical if we are to |
| prevent further confusion in an area already plagued with          |
| misunderstanding and therapeutic folklore. Unfortunately, media    |
| reports of the Anderson and Depue work have provided the "take     |
| home" message that the latest advances in technology are showing   |
| that people can, consciously or unconsciously, block out memories  |
| of traumatic events. In fact, the evidence actually supports the   |
| opposite conclusion -- survivors of trauma generally have          |
| difficulty forgetting the experiences they have been through."     |


The lawsuit against Elizabeth Loftus has been settled. The lawsuit had
been brought by Nicole Taus who was the subject of an article by
Loftus and Mel Guyer that was published in the Skeptical Inquirer
called "Who Abuse Jane Doe?" (Background of the case reprinted from
Spring 2007 FMSF Newsletter appears as at the end of this e-mail).

There are three important results of the case.

First, the California Supreme Court said that the plaintiff should pay
attorney fees.  Subsequently, a fee motion was prepared and submitted
for over $450,000.  The hearing on that motion will be held October 2,
Second, of the 21 counts that Taus filed against Loftus and her
co-defendants, Taus lost soundly on 20 of them. The right of Loftus
and others to speak about the Jane Doe case remains protected and

Third, based on a declaration that Loftus states did not correctly
state the facts, the California Supreme Court left a single claim
alive. Attorneys urged Loftus to settle because of the great burden
that would be placed on her to litigate the single claim and to prove
that it was false.

The $7,500 that Taus demanded to settle was a pittance compared to the
more than a million she had previously requested.

The settlement is not an admission of wrongdoing, Loftus categorically
denies the allegations Taus made against her in that count, but she
wanted to avoid further harassment by Taus and her supporters.

The case has now gone on for several years and Loftus and colleagues
prevailed on all the important legal and ethical issues. By settling
for a trivial sum, everyone will be spared a futile "she said/she
said" trial.

    Fractured Families: The Untold Anguish of the Falsely Accused
      Norman Brand (Editor). British False Memory Society. 2007

Fractured Families is the first book to be published by the British
False Memory Society. It is a collection of eighteen short stories
ranging from two to five pages. Some of the stories are written by
falsely accused families and some by people who have experienced
recovered memory therapy. In addition, there are several brief
comments by professionals.

The book is small, just eighty-nine pages. It was conceived both as a
way to help families and also as a document that could be presented to
legislators, academics, clinicians, child protection workers and
everyone in the criminal justice field as a way to help them
understand the catastrophe that befalls families when a false
accusation of abuse based only on claims of recovered memories
explodes. The stories express the heartache of the families and they
tell the story of the spread of FMS in Britain.

Madeline Greenhalgh has been the head of the British False Memory
Society for almost a decade. Her words best explain the book:

  "After 13 years of working with the BFMS the most moving and
  powerful aspect of the work has been to experience the level of
  anguish and suffering endured by families who, in so many ways, are
  just like yours and mine. Most parents have attempted to bring their
  children up to the best of their abilities and to willingly make
  sacrifices for them, in the way that we all do, because they are our
  children and we will do almost anything for them. Barring the
  untimely death of a child there can be little that equates with the
  pain of losing a child as a result of being falsely accused of the
  heinous crime of child sexual abuse. The level of indignation we
  feel at being falsely accused of even a petty matter strikes at our
  moral being. How can anyone who has not experienced being falsely
  accused of child sexual abuse ever understand the enormity of such
  an injustice? We cannot, but we can listen and learn from those who
  have been caught in the fallout. There is no better way to highlight
  the seriousness of this problem than to bring together a collection
  of these stories from families who reveal numerous common features
  in their heart-rendering accounts."  pp 18-19.

Fractured Families is available via It can
also be ordered directly from the British False Memory Society using
Visa or MasterCard credit cards. The price from the BFMS is #6.99 plus
#1.34 postage. Contact Madeline Greenhalgh at

/                                                                    \
| Childhood abuse is, of course, a dire problem not to be            |
| underestimated. But adult abuse by fervent accusers, often of a    |
| crusading vigilante nature, based on events that never occurred,   |
| is a life-shattering experience."                                  |
|                                       Professor Larry Weiskrantz   |
|                                      Fellow of the Royal Society   |
|                                         p 83. Fractured Families   |

/                                                                    \
| "Allegations are thrown and yet, in many of these cases, no legal  |
| investigation is instigated, leaving accused persons without any   |
| opportunity to put their side of the story. This is not a          |
| one-sided matter to be left smoldering without attention. Many     |
| families are trapped in the grief for the loss of their loved ones |
| and their life as it was before being accused. They have never     |
| been allowed to respond to the 'bombshell' that was dropped        |
| without warning. It is time to recognize that a plea of innocence, |
| or, as it is more frequently referred to, 'a denial of guilt',     |
| does not always equate to being 'in denial'. This caveat has       |
| fostered an environment where an individual who is falsely accused |
| is damned if they do and damned if they don't."                    |
|                                           p. 9. Fractured Families |

/                                                                    \
| The depth of society's condemnation of the sexual abuse of         |
| children, which we share completely, is also a measure of the      |
| agony of the falsely accused, as they face the effective loss of a |
| loved family member-- an experience frequently compared to that of |
| bereavement."                                                      |
|                                                p. 84  Norman Brand |
|                                                 Fractured Families |

                        A POSSIBLE EXPLANATION
                 Mistakes Were Made (but not by me):
   Why We Justify Foolish Beliefs, Bad Decisions, and Hurtful Acts
                   Carol Tavris and Elliot Aronson
                        Harcourt, Inc. (2007)

  "We are all capable of believing things which we know to be untrue,
  and then, when we are finally proved wrong, impudently twisting the
  facts so as to show that we were right." George Orwell (1946)
                                         Quoted in Mistakes Were Made.

If you have ever asked yourself why only two or three therapists have
spoken up and apologized for the recovered memory fiasco or why so
many of the returning accusers want to reunite with their families but
not talk about the consequences of their horrible accusations, then
you will certainly want to read Mistakes Were Made (but not by me).
Although this lively and engaging book spans a wide number of topics,
the authors devote a significant portion to an analysis of the
recovered memory movement. [1]

In the introduction, distinguished social psychologists Tavris and
Aronson explain that, "As fallible human beings, all of us share the
impulse to justify ourselves and avoid taking responsibility for any
actions that turn out to be harmful, immoral, or stupid." Indeed, they
note that, "most people, when directly confronted by evidence that
they are wrong, do not change their point of view or course of action
but justify it even more tenaciously." Self-justification "allows
people to convince themselves that what they did was the best thing
they could have done," but, they note, that it is not necessarily a
bad thing. The authors wrote this book in an effort to help us
understand self-justification so that we can move beyond it.

Tavris and Aronson argue that the concept of "cognitive dissonance" is
"the engine that drives self-justification." [2] Cognitive dissonance
is the uncomfortable state we experience when we have ideas that
conflict. The greater the internal conflict the more the need to
resolve it. If this begins to sound a bit dry, rest assured that the
authors give wings to the concepts they address. The fascinating
anecdotes and the witty prose make this book a delightful read from
cover to cover.

[1] An example from the book that will resonate with FMSF readers is
    from a deposition of Bessel van der Kolk, MD. (pages 106-107)

  Q: Are you aware of any research on the reliability or the validity
    of clinical judgment or clinical predictions based on interview
  A: No.
  Q: What's your understanding of the current term "disconfirming
  A: I guess that means evidence that disconfirms treasured notions
     that people have.
  Q: What's the most powerful piece of disconfirming evidence that
     you're aware of for the theory that people can repress memories
     or that they can block out of their awareness a series of
     traumatic events, store those in their memory, and recover those
     with some accuracy years later?
  A: What's the strongest thing against that?
  Q: Yes. What's the strongest piece of disconfirming evidence?
  A: I really can't think of any good evidence against that...
  Q: Have you read any literature on the concept of false memories
     using hypnosis?
  A: No.
  Q: Is there research on whether clinicians over a period of years
     develop more accurate clinical judgment?
  A: I don't know if there is, actually...
  Q: Is [there] a technique that you use to distinguish true and false
  A: We all, we all as human beings are continuously faced with
     whether we believe what somebody feeds us or not, and we all make
     judgments all the time. And there is such a thing as internal
     consistency, and if people tell you something with internal
     consistency and with appropriate affect, you tend to believe that
     the stories are true.

  Notice that Dr. van der Kolk avoids cognitive dissonance by avoiding
  learning about ideas that might contradict his beliefs. Notice, too,
  that van der Kolk appears to be confident that he knows if a client
  is telling the truth and whether a memory is true or false based on
  his experience and on his judgment of the story's "internal
  consistency." Research has shown repeatedly that neither therapist
  experience nor internal consistency are reliable determinants of the

[2] See FMSF Newsletters July/August 2004, Volume 13 No. 4 and
    July/August 2005, Volume 14 No. 4 for discussions of cognitive
    dissonance by Mark Pendergrast.

/                                                                    \
|                              Abstract                              |
|                  Rubin, D.C., Berntsen, D. (2007)                  |
|      People believe it is possible to have forgotten memories      |
|                     of childhood sexual abuse.                     |
|           Psychonomic Bulletin & Review, 14(4), 776-778.           |
|                                                                    |
| "Pezdek, Blandon-Gitlin, and Gabbay (2006) found that perceptions  |
| of the plausibility of events increase the likelihood that         |
| imagination may induce false memories of those events. Using a     |
| survey conducted by Gallup, we asked a large sample of the general |
| population how plausible it would be for a person with             |
| longstanding emotional problems and a need for psychotherapy to be |
| a victim of childhood sexual abuse, even though the person could   |
| not remember the abuse. Only 18% indicated that it was implausible |
| or very implausible, whereas 67% indicated that such an occurrence |
| was either plausible or very plausible. Combined with Pezdek et    |
| al.'s findings, and counter to their conclusions, our findings     |
| imply that there is a substantial danger of inducing false         |
| memories of childhood sexual abuse through imagination in          |
| psychotherapy."                                                    |

                     MEMORY STUDY OUT OF THE LAB
                           Everyday Memory
               Magnussen, S. and Helstrup, T. (Editors)
                 New York: Psychology Press  (2007).

Magnussen and Helstrup introduce the scholarly papers in Everyday
Memory with the results of a survey from three representative samples
of 1000 adult Norwegians. The survey questioned the beliefs of
ordinary people about memory. The questions covered such topics as
whether people thought that training could make memory stronger or
whether there was a limit to how much information could be remembered.
These beliefs are then compared with what science has shown and set
the stage for the scholarly discussions that follow.

The editors' intent was a book covering general aspects of memory in
everyday contexts that are not found in other texts. It is geared for
readers with some background in cognitive psychology who are
interested in how memory works in everyday situations but not
necessarily familiar with the technical details of the research. The
book is the cumulative work of an international group of cognitive
psychologists invited to Centre of Advanced Study at the Norwegian
Academy of Science and Letters in Oslo 2003-2004.

Although all of the work ultimately adds to our understanding of
memory and thus false memories, a few chapters address the concerns of
FMSF members directly. For example, one of the questions that people
were asked was if they thought that memories for dramatic events would
be worse, as good or better than memories for everyday events. Most
people's beliefs agreed with what science has shown -- that memory for
dramatic events is as good as, or better than, memory for ordinary
events. But they also asked if people who have had frightening and
dramatic experiences and who claim memory loss are being truthful.
Most people thought that they were truthful but this belief varied
with the respondent's educational level. The more education, the more
a person was apt to believe. They note:

  "Psychoanalytically inspired thinking has been absorbed by society,
  especially by intellectuals, but detached from its theoretical basis
  and diluted. In Norwegian daily language, the concept of repression
  has become almost synonymous with forgetting but with special
  reference to unpleasant memories, such as remembering an appointment
  with the dentist. So the idea that extremely unpleasant memories can
  be completely blocked is readily available. The finding that the
  proportion of participants accepting the idea of repression
  increased with years of formal education is an indication that the
  belief derives from intellectual theory rather than from folk
  psychology. However, the ideas of folk psychology are consistent
  with science. The concept of repression has been difficult to
  support it does not stand the test of relevant
  real-life studies of traumatized individuals... Indeed,
  trauma-induced psychogenic amnesia is extremely rare, if it exists
  at all... Rather, studies of war veterans, some of whom may
  themselves have committed gruesome acts, and of victims to such
  acts, point in the opposite direction: These memories persist all
  too well." [1]

Another chapter that FMSF readers will likely find of interest is
"Memory illusions and false memories in the real world," [2] written
by Gail Goodman and colleagues. The authors state in the first
paragraph that everyday memory is of importance to all society because
lack of knowledge can lead to miscarriage of justice. Using actual
cases from Norway and the United States, they show compelling examples
of false memories and what science has explained about their

The chapter concludes with a summary of what the authors believe is
known about false memories:

  1. "We believe there are several different routes to false-memory
     formation. Some routes may be self-generated. Other routes
     involve highly suggestive or coercive techniques. In any case,
     important contributors to false-memory formation include that the
     individual accepts that the event was plausible, that the
     individual develops a mental image of the event, and that the
     individual does not apply optimal source monitoring to the
  2. "[C]conversations between friends and group members, who have no
     explicit intentions to contaminate memories, adversely affect
     people's recollections... Social influence appears to be most
     potent for memories that are held with lower confidence..."
  3. "There are important individual differences in tendencies toward
     memory errors, including false-memory errors." Researchers are
     now identifying some of the factors such as age or dissociative
     tendencies or lack of confidence in one's memory.
  4. "There are mechanisms that guard against false memory."
     Understanding these mechanisms may lead to strategies that can be

Everyday Memory is an excellent addition to the arsenal of scholarly
books about memory.

[1] Page 21. Chapter 1. Magnussen, S., Endestad, T., Koriat, A.,
    Helstrup, T . What do people believe about memory and how do they
    talk about memory?
[2] Page 178. Chapter 7. Goodman, G.S., Magnussen, S., Andersson, J.,
    Endestad, T., Lokken, L., Moestur, A.C. Memory illusions and false
    memories in the real world.

| "What is memory? Not a storehouse, not a trunk in the attic, but   |
| an instrument that constantly refines the past into a narrative,   |
| accessible and acceptable to oneself."                             |
|                                                   Stanley Kaufmann |

   Seduced by Madness: The True Story of the Susan Polk Murder Case
                             Carol Pogash
                        William Morrow (2007)

In 2006, the media spawned a "feeding frenzy" over the Susan Polk
murder trial in Contra Costa County, California. Susan, who was
charged in 2002 with stabbing her husband 27 times, had insisted on
defending herself. Not surprisingly, the trial was colorful and
entertaining -- "infotainment." Jury selection began on February 26,
2006 and the trial ended on June 16, 2006 when the jury found Susan
Polk guilty of the second-degree murder of her 70-year-old husband,
psychologist Felix Polk.

Although this case was not reported in the FMSF Newsletter, it is one
that we followed closely through newspaper accounts. In fact, at one
point the defense called the Foundation to ask for information. Susan
Polk had recovered memories that her husband had abused her and wanted
to use those memories to justify the murder. (The Foundation position
on the unreliability of such memories, however, seemed not to be what
the caller sought!)

The Polk family saga that culminated in the murder trial began when a
14-year-old Susan Polk began psychotherapy with Felix Polk, Ph.D. A
number of years later, Felix Polk divorced his wife and married Susan.
He and Susan had three children. When their first child was a toddler,
not long after the McMartin trial, the Polks became convinced that
their child had been abused in a satanic cult. Felix Polk took to the
lecture circuit in California in the late 80s giving talks about the
dangers of satanic cults. Previously Dr. Polk had been an advocate of
the human potential movement, embracing the cult-like EST (Erhard
Seminars Training) program. In the 90s, Felix Polk drifted to the
recovered memory movement. He and Susan came to believe that her
father had abused her. Later, as Susan and the marriage disintegrated,
Susan believed that she had recovered memories that Felix had abused

Author Carol Pogash has done a service for us all in Seduced by
Madness. Her thorough investigation of the people involved in this sad
case provides a perspective that was missing in the ongoing reports of
the sensational trial. FMSF Newsletter readers will almost certainly
find the first part of this book fascinating as it traces the Polk
family's ready adoption of belief in practices lacking any scientific
foundation: EST, satanic cults and recovered memories. The book paints
a remarkable picture of a person and a family that is ultimately
undermined and destroyed by uncritical belief in bizarre fads.

Seduced by Madness is a page-turner. 
                         BOOKS BRIEFLY NOTED
		     The Fate of Early Memories:
   Developmental Science and the Retention of Childhood Experiences
                             Mark L. Howe
       American Psychological Association: Washington, DC, 2000
According to author Mark Howe, the focus of The Fate of Early Memories
is a consequence of the widespread beliefs that "early experiences, at
least traumatic ones, can exert their influence on later adult
behavior and do exist in memory regardless of whether they can be
recalled." The author's purpose is to examine these beliefs in the
light of scientific evidence. He notes that it is "a particularly
fortuitous time to write such a book" because there has been so much
new research in the field. The result is a scholarly, scientific and
comprehensive book about the" development of the survival of memories
in long-term storage and their subsequent recollection."

Howe carefully constructs his arguments by examining the scientific
research at each stage of development. For example, there is a chapter
on memory development from birth to 2 years and another looking at the
preschool years. Each chapter is introduced in a clear manner and
concludes with a summary of the main finding. This makes the book
accessible to a general audience.

The author concludes that scientific research does not support the
popular claims about the influence of early traumatic experience on
later development. He notes that these modern folk beliefs have had
serious consequences and that they need to be counteracted with
empirical facts. It is encouraging to know that this book is available
to students and researchers.

  "It is this belief that early experiences can exert such a powerful
  influence over people's lives, and that these so-called formative
  events can be remembered, that served as the impetus for writing
  this book...there is a need to counteract these beliefs about early
  memories of experiences with the empirical facts." (p. xii).

Mark L. Howe, Ph.D. is a professor of psychology and dean of Graduate
Studies and Research at Lakehead University in Thunder Bay, Ontario,
			  Myths of Childhood
                              Joel Paris
                  New York: Brunner-Routledge, 2000
In Myths of Childhood, psychiatrist Joel Paris challenges some deeply
held cultural beliefs. They are: 1) that personality is formed by
early childhood experiences; 2) that mental disorders are caused by
early childhood experiences; and 3) that effective psychotherapy
depends on the reconstruction of childhood experiences. The book
marshals the scientific evidence to counter these beliefs. For
example, he shows that genes and environment significantly affect
personality, that mental disorders are influenced by genetic
predispositions, and that the quality of the relationship between the
patient and therapist and the quality of their collaborative work are
related to curing effects of therapy.

Paris notes that although some people are indeed badly affected by
early experiences, "most people with an unhappy childhood do
reasonably well as adults. A predisposed and vulnerable minority is
most affected by adversity."

It is the myths of the importance of early childhood experiences that
underlie the beliefs leading to the recovered memory movement.
According to Paris:

  "The history of the recovered memory movement can also be seen as a
  warning. It will go down in the history of psychology as one of its
  greatest scandals, creating a cult that has sometimes threatened to
  bring the entire practice of psychotherapy into disrepute. The
  conviction that childhood is the main source of adult symptoms is
  the ultimate basis of the theories of repression and dissociation.
  This powerful belief system can lead to serious errors in clinical
  practice. The concept of recovered memory takes some of the most
  common but misleading premises underlying psychotherapy, and places
  them in a distorting mirror." Page 93

Joel Paris, M.D., is Professor of Psychiatry at McGill University in

/                                                                    \
| "Paris' book is an important and necessary step away from the      |
| culture of belief and tradition, toward a culture of knowledge and |
| science."                                                          |
|                                        Leif Edward Ottesen Kennair |
|                                                                    |
| Review of Myths of Childhood by Leif Edward Ottesen Kennair, Chief |
| Psychologist, Nordfjord Psychiatric Center, Norway can be found    |
| at: 03/paris.html               |

/                                                                    \
| "The concept of recovered memory takes some of the most common but |
| misleading premises underlying psychotherapy, and places them in a |
| distorting mirror."                                                |
|                                                Joel Paris, page 93 |

                         NEW RESEARCH PAPERS
     With Practice Some People Can Suppress Newly Formed Memories
            Depue, B.E., Curran, T., Banich, M.T. (2007).
       Prefrontal regions orchestrate suppression of emotional
                  memories via a two-phase process.
                        Science 317, 215-219.
Brendan Depue, a doctoral candidate at the University of Colorado, and
two of his professors have found that people are capable of
suppressing the memory of unpleasant pictures. This research received
much media attention as some reporters assumed it addressed the
recovered-memory controversy. According to the author, it does not.

Researchers asked 16 people to look at two pictures at the same time.
One picture was a disturbing image, for example a wounded soldier or a
bad car accident; the other picture was a neutral face. There were 40
different pairs of pictures that the subjects learned.

After they had memorized the pairs, the subjects were shown only the
pictures of faces and asked either to think about, or not to think
about the disturbing picture with which it was associated. As they did
this, their brains were observed using a functional magnetic resonance
imaging scanner f(MRI). The fMRI images showed that the subjects
seemed to shut down specific portions of the brain when asked not to

Later the participants were shown the faces and asked to write down
which image had been paired with them. About half the time the
participants forgot the disturbing image. Depue commented "At first,
you can't successfully suppress (the memory)," but "after repetition
of the items, you get control of them. In the end, there is actually
suppression." [1]

When interviewed about this research, Elizabeth Loftus commented that
she feared, "This will be used as a supposed piece of proof that
[memory] repression has been discovered in the brain. This is not
evidence for that but people will try to pretend that it is." [2]

Depue, however, has commented that there is considerable debate over
whether repressed memories and suppressed memories are even
interchangeable terms, or whether repressed memories exist at all.[3]

  "The debate over repressed memories probably won't be resolved in my
  lifetime. I think the important thing here is that we have
  identified neural mechanisms with potential for helping the clinical
  community develop new therapeutic and pharmaceutical approaches for
  people suffering from emotional disorders." [3]

  "My prediction is it won't be as easy to suppress something that's
  long-standing and personally emotional."[4]

  "We have shown in this study that individuals have the ability to
  suppress specific memories at a particular moment in time through
  repeated practice. We think we now have a grasp of the neural
  mechanisms at work, and hope the new findings and future research
  will lead to new therapeutic and pharmacological approaches to
  treating a variety of emotional disorders." [3]

[1] Mishra, K. (2007, July 13). Rather not remember? You can
    fuggedaboudit. Retrieved from
[2] Smith, M. (2007, July 12). Practice forgetting and memories fade.
    Medpage Today. Retrieved 7/14/07
[3] (2007, July 16). Suppression of emotional memories shows potential
    in treatment of emotional disorders. Medical News Today. Retrieved
    from on September 6,
[4] Ganguli, I. (2007, July 13). Creating psychopaths! You can forget
    the unhappy past sez study. Reuters
    the+unhappy+past+sez+study. Retrieved July 13, 2007.

/                                                                    \
|          Other comments about the Depue et al. research            |
|                                                                    |
| "We do know that very serious emotional memories are, in general,  |
| very remembered."                                                  |
|                                         Art Shimamura, UC Berkeley |
|                                         Mishra, K. (2007, July 13) |
|                         Rather not remember? You can fuggedaboudit |
| Retrieved from                                                     |
|                                                                    |
| "The stimuli may be unpleasant, but they are hardly traumatic."    |
|                                        John Kihlstrom, UC Berkeley |
|                                        Ganguli, I. (2007, July 13) |
|    Creating psychopaths! You can forget the unhappy past sez study |
|                                                            Reuters |
| Retrieved from                                                     |
|          |
| Psychopaths!+You+can+forget+the+unhappy+past+sez+study. 7/13/07    |
|                                                                    |
| "For a mother haunted by the memory of her son's suicide, it is    |
| hard to imagine that you'd ever get her to forget that the event   |
| occurred."                                                         |
|                                                       John Gabriel |
|                              Massachusetts Institute of Technology |
|                                        Ganguli, I. (2007, July 13) |
|    Creating psychopaths! You can forget the unhappy past sez study |
|                                                            Reuters |
| Retrieved from                                                     |
|          |
| Psychopaths!+You+can+forget+the+unhappy+past+sez+study. 7/13/07    |

	       Self-Reports of Amnesia for Child Abuse
                   No Substitute For Corroboration
Ghetti, S., Edelstein, R.S., Goodman, G.S., Gordon, I.M., Quas, J.A.,
        Alexander, K.W., Redlich, A.D., Jones, D.P.H. (2006).
                What can subjective forgetting tell us
                  about memory for childhood trauma?
                 Memory & Cognition 34 (5), 1011-1025
Most research examining whether people may have forgotten past abuse
has relied on self-reports. There are only a few studies that have
taken a prospective view, i.e. have examined adults with documented
childhood abuse. Simona Ghetti and colleagues wondered to what extent
retrospective reports may reflect actual forgetting. The researchers
believe that the comparison is important to determine if subjective
reports may be substituted for documented child abuse.

The authors questioned child sexual abuse victims whose cases had
resulted in criminal proceedings in the mid 1980s. The vast majority
remembered (81% to 88%) and the prevalence and predictors of their
disclosure was previously reported (Goodman et al., 2003). This paper
focuses on "self-reported experiences of forgetting and memory
accuracy among disclosers."

Subjects were asked about the details of their abuse after they had
disclosed. They were also asked if they had ever forgotten it and, if
so, they were "asked to describe the reasons why they had forgotten."
This paper looks specifically at how the subjects characterized their
forgetting experiences and what factors might predict such
experiences. The specific factors they examined were: 1. The severity
of abuse; 2. The relation between victim and perpetrator; 3. Whether
the victim had maternal support; and 4. The involvement in legal
system. They also examined individual differences such as age, gender,
or ethnicity.

Twenty-one of the 138 people reported that they had experienced a time
when they had no memory for the documented abuse. The authors found,
"Victim age, maternal support, relationship to the perpetrator, and
ethnicity were not significant predictors of subjective forgetting."
The most frequent reasons endorsed for the forgetting were: "I felt
afraid, and I did not want to think about it." "It was so horrible
that I pushed it out of my mind."

The researchers looked particularly at five individuals who reported a
period of time when they would have been unable to remember their
abuse even if someone had asked them about it. They found that if
child sexual abuse "was forgotten in childhood, it was also likely to
be recovered in childhood, rather than later on in adulthood." They
"found no evidence of adult recovery of [child sexual abuse]

Research with a population of people whose cases had gone to court may
not be typical of most abuse cases. Such people would almost certainly
have had greater occasion to talk about the abuse. Nevertheless, the
researchers conclude: "It may be problematic to use subjective
forgetting as a proxy for actual amnesia when drawing conclusions
about the fate of CSA memory." The "differences between subjective and
objective memory underscore the risks of using subjective measures to
assess lost memory of abuse."

            | "Nothing fixes a thing so intensely in |
            |  the memory as the wish to forget it." |
            |                    Michel de Montaigne |
		      Emotional Memories Persist
                   Payne, B.K., Corrigan, E. (2007)
           Emotional constraints on intentional forgetting
      Journal of Experimental Social Psychology 43(5). 780-786.
Keith Payne and Elizabeth Corrigan ask whether people continue to
remember emotional memories even when they would rather forget them.
They note: "a strong memory for a painful event will help avoid it in
the future, while a strong memory for a pleasant event will help seek
it out again." There seems good reason that emotional memories will be

Previous studies of intentional forgetting of emotional memories have
used emotion-laden words as stimuli. This study used pictures that had
been previously tested to affect participants' moods. Previous
studies, i.e. McNally et al. 2004, had focused on who might show
"enhanced or disrupted intentional forgetting." This study examined
whether "emotional events resist intentional forgetting." Is
intentional forgetting different for emotional memories compared to
neutral memories?

Two hundred-eighteen undergraduates studied two lists of picture
items. Half of the participants were told to forget the items in the
first list and half told to remember them. The pictures were both
pleasant and unpleasant or neutral. Then students were tested.

The results of the study showed that "when participants tried to
forget emotional or neutral memories, they were able to forget only
the neutral ones." Both the pleasant and unpleasant memories

  "Our findings add to accumulating evidence that emotion places
  limits on the ability to control the contents of the mind. Our
  results suggest that even a relatively mild emotional reaction can
  undermine intentional forgetting. But this doesn't necessarily mean
  that emotional memories can never be intentionally forgotten. If the
  motivation to forget is powerful enough, individuals might be able
  to overcome the effects of emotion by enlisting additional coping
  strategies. A different study would be needed to examine what
  treatment and coping strategies might be effective in helping people
  voluntarily forget an unwanted memory."

/                                                                    \
|            New Research Adds to the Evidence for Caution in        |
|              Use of Anatomical Dolls with Young Children           |
|                                                                    |
| "The victims of abuse are often very young children, who are quite |
| difficult to interview. Consequently, many professionals --        |
| including police officers, social workers and mental health        |
| professionals -- employ anatomically detailed dolls, assuming that |
| a young child will have an easier time describing what happened    |
| using a doll. Notice that this assumption entails the further      |
| assumption that a young child will be able to think of this object |
| as both a doll and a representation of himself or herself."        |
|                                                                    |
| "In several independent studies,... investigators have asked       |
| preschool children to report what they remember about a checkup    |
| with their pediatrician, which either had or had not included a    |
| genital check. Anatomically detailed dolls were sometimes used to  |
| question the children, sometimes not. In general, the children's   |
| reports were more accurate when they were questioned without a     |
| doll, and they were more likely to falsely report genital touching |
| when a doll was used."                                             |
|                                                                    |
| "Based on my research, I suspected that very young children might  |
| not be able to relate their own body to a doll. In a series of     |
| studies in my lab...[a researcher] placed a sticker somewhere on a |
| child -- on a shoulder or foot, for example -- and asked the child |
| to place a smaller version of the sticker in the same place on a   |
| doll. Children between three and three and a half usually placed   |
| the sticker correctly, but those younger than three were correct   |
| less than half the time. The fact that these very young children   |
| cannot relate their own body to the doll's in this extremely       |
| simple situation that does not have memory demands or emotional    |
| involvement supports the general case against the use of           |
| anatomically detailed dolls in forensic situations with young      |
| children. (Because of many demonstrations akin to this one, the    |
| use of dolls with children younger than five is viewed less        |
| favorably than in the past and has been outlawed in some states.)" |
| page 34,35                                                         |
|                                                                    |
|                                             DeLoache, J. S. (2006) |
|                                                 Mindful of symbols |
|                             Scientific American Mind, 17(1), 71-75 |

                       L E G A L   C O R N E R
     Canadian Supreme Court Hands Carte Blanche to Social Workers
                           Adriaan J.W. Mak
  Syl Apps Secure Treatment Centre and B [social worker] v. B.D and
     family, Supreme Court of Canada 38 Decision can be found at:

On July 27, 2007, Justice Rosalie Abella, appointed to the Supreme
Court of Canada in 2004, wrote her first and long awaited tort
decision, namely: that neither treatment centers nor social workers
caring for children apprehended by the Children's Aid Societies owe
any duty of care to the families of these children.

Twelve years earlier in 1995, R.D., an imaginative, shy, and gifted,
fourteen year old girl who was the oldest daughter in a closely knit
and nurturing immigrant family of four children and a grandmother, had
written a fictional story, describing how a female character had been
sexually and physically abused.

This story, referred to in court documents as an "essay," sparked a
series of tragic events, beginning with the apprehension of the young
author by the Children's Aid Society, which had received temporary
wardship. This was followed by the girl's placement in a foster home.

Away from the protection of her family, the girl became suicidal.
Subsequently the girl was transferred to several psychiatric
facilities, where her condition continued to worsen and she made other
suicide attempts. These events finally caused her to be placed in a
"secure" treatment centre under the special care of social worker B.

The local police apparently found that the girl's essay was indeed
fictional, since no charges were ever brought against the parents, nor
were any of the siblings of R.D. removed from the family to be placed
under the care of the Children's Aid Society.

What happened behind the doors in the facilities where R.D. had been
placed after being denied contact with her family, may never be
known. Certainly a very big transition had taken place because the
girl consented to be made a permanent ward of the Crown in October

When the girl reached the age of eighteen a judge confirmed that the
parents had been cleared of any wrongdoing, yet that he had no power
to cause her to rejoin her family.

Her family then sought $40,000,000 in damages, alleging that R.D. had
been treated negligently as if her parents had actually physically and
sexually abused her. This caused the daughter to choose not to return
to her family.

Although a lower court judge decided to dismiss this claim, the family
appealed. Justice Laskin of the Ontario Court of Appeal writing for
the majority reversed the lower court and allowed the family's appeal
to proceed. Laskin argued that a secure treatment facility and social
workers employed there, may indeed owe a legal duty of care to the
family of a child in their care.

The treatment facility appealed this decision and the case then went
to Canada's Supreme Court, where Justice Abella, a renowned human
rights and family lawyer, an advocate for the rights of the disabled,
and the rights of women, argued:

  "...child protection work is difficult, painful and complex because
  catering to a child's best interest . . . means catering to a
  vulnerable group at its most vulnerable. Those who do it, do so
  knowing that protecting the child's interests often means doing so
  at the expense of the family. They must be free to execute this
  mandate to the fullest extent possible. The result they seek is to
  restore the child, not the family."

It should be noted that the literature cited in the court decision
conspicuously omits the names of researchers who have been critical of
the way in which child care workers have often repeatedly and
suggestively questioned children.

At the time this took place (1995) books such as Jeopardy in the
Courtroom by Ceci and Bruck were available. Certainly the local police
had been made well aware of this research.

We are also not told that any members of the judiciary ever listened
to tapes of these all important first interviews of Children's Aid
Society social workers with R.D.
  Adriaan Mak is the Canadian contact for people falsely accused of
  child sexual abuse and victims of misguided therapy. In the next
  issue members of the D. family will tell of their 12 year long
  ordeal, as well their efforts and continuing hopes to be once more
  united with their truly restored daughter, granddaughter and sister.

                           Charges Dropped

A Rhode Island legal case provides an example of the importance legal
precedents may have in recovered memory cases.

On June 15, 2006, a Rhode Island woman accused a 48-year-old man of
raping her 32 years ago in 1975 when she was 16. The woman claimed
that she had repressed the memory. The charge was a single incident of
rape alleged to have occurred sometime within a seven-month time
frame. No date or place was provided and no evidence beyond the
woman's recovered memory has been given.

In Rhode Island, there is no statute of limitations for charges of
first-degree sexual assault and the case was presented to a grand jury
that returned an indictment against the man. The man, Harold Allen,
who grew up in the same neighborhood and who knew the girl as a teen,
maintained his innocence. Married, with two high-school age children,
he had never been previously charged or arrested for anything -- not
even a traffic offense.

A year later on July 13, 2007, the Rhode Island Attorney General
announced that the charge against the man had been dropped. The
dismissal noted that because of the case law in Rhode Island, "the
high burden for admissibility, at trial, of testimony based on
repressed memory" [would create] "a legal impediment that the state is
unlikely to overcome."

A spokesperson for the office stated that he did not think that that
the woman's recovered memory evidence would be allowed in court. He
said "Decisions from many state Supreme Courts from across the country
have made clear that repressed or recovered memory is a genuinely
contentious legal issue. We are acknowledging that her evidence would
not likely hold up. I suppose there is a very small chance, but it
would be very small."

The dismissal form mentioned the case of State v. Quattrocchi, a
recovered-memory case that went to the Rhode Island Supreme Court.
That court decided in 1996 that any case that relies on repressed
memory must have a pre-trial hearing on the evidence.

The defendant's attorney, Walter R. Stone, commented that "This man's
whole life has been ruined," and he wondered why the case went as far
as it did considering the lack of evidence. The Rhode Island Attorney
General Patrick Lynch said, "Perhaps a prosecutor's greatest power is
to dismiss a charge and end an unwarranted criminal prosecution."

John Quattrocchi, the attorney whose case resulted in Rhode Island
law, said that the good news about the Allen case is that once it
reached the higher levels of the prosecution team, it was dismissed.
He said that the legal community education work of the FMS Foundation
in the 90s had a significant effect in Rhode Island. Quattrocchi
added, however, that the bad news is:

  "local police and a low level prosecutor were blissfully ignorant
  about false memory and wanted to be politically correct. They had
  likely never read my case. They were able to charge Allen and
  present his case to a Grand Jury. Predictably, he was indicted and
  left to dig himself out of a deep hole. I shudder to think what
  would have happened if there had not been a local precedent looming
  over the case. I shudder to think of what may go on in states that
  do not have such clear precedents about the reliability of claims of
  recovered memories." [1]

[1] Quattrocchi, J. (2007, September 4). Personal email

Belluck, P. (2007, July 13). Rape case is dismissed in Rhode
Island. New York Times. Retrieved from
on 8/30/2007.

Kuffner, A. (2007, July 13). Lynch drops rape charge. Providence
Journal. Retrieved from
on 7/13/07.
          Nebraska Court Rules Star Witness May Not Testify
          State of Nebraska v. Donald J. Sykora, CR 05-148,
           District Court of Sarpy County. (January, 2007)

On May 29, 2007 Sarpy County Nebraska District Judge William Zastera
ruled that Lenora Kay Parker could not testify about her childhood
memories of her mother's murder in 1971. Parker, who was 4-years-old
at the time of the murder, is the chief witness in the case against
her father, Donald Sykora. Judge Zastera disallowed Parker's testimony
because her memory had been enhanced by a 30-hour cognitive interview,
a technique he said was not scientific and could produce false

According to media reports, two federal agents and a police officer
interviewed Lenora Parker for four days in a row. The interview was
conducted in a meeting room in a fire station that had been converted
to a more relaxing environment with items such as a recliner, a sofa
and soft lights. In a cognitive interview, subjects are first asked
open-ended questions and they respond in a narrative fashion.

The purpose of the interview was to help Lenora Parker remember the
details of her alleged vision of her father strangling her mother. The
interview was not tape recorded. Instead, one officer took notes as he
sat in another room and observed. At one point during the interview,
the group left to visit the grave of Parker's mother.

Ronald Fisher, a Florida International University professor of
experimental psychology, testified that cognitive interviews are as
reliable or more reliable than standard police interviews. He said
that people usually provide more information in a cognitive interview.

Daniel Wilson, chair of the Creighton University psychiatry
department, testified for the defense and said that there is no
scientific evidence that demonstrates that a cognitive interview is a
reliable way to extract a traumatic memory from an adult who had
witnessed an event 35-years-ago when she was 4. Wilson was also
concerned about the great duration of the interview and the impact of
the visit to the mother's grave.

In his decision, Judge Zastera noted that the Parker interview did not
follow recommendations for standard cognitive interviews and that the
questions of a federal agent were so suggestive that Parker's
testimony would not be reliable.

The prosecution is challenging the judge's ruling. A decision on the
motions is expected before the end of the year.

John Reisz is Deputy Sarpy County Attorney. Sykora is represented by
Don Fiedler of Omaha.

Midlands News Service (2007, January 14). Sykora case takes new
twist. Bellevue Leader (Omaha),1.

Midlands News Service. (2007, May 25). Key witness can't testify in
Sykora murder case. Belleview Leader (Omaha). Retrieved from

See Whitehouse, W.G., Orne, E.C., Dinges, D.F., Bates, B.L., Nadon,
R., Orne, M.T. (2005, Summer). The cognitive interview: Does it
successfully avoid the dangers of forensic hypnosis?  American Journal
of Psychology 118(2). 213-234.

/                                                                    \
|               Crimes Against Children Have Declined                |
|                   Finkelhor, D. Jones, L. (2006)                   |
|   Why have child maltreatment and child victimization declined?    |
|              Journal of social Issues, 62(4), 685-716              |
|                                                                    |
| Between 1993 and 2004, various forms of child maltreatment and     |
| child victimization declined as much as 40-70%. That included      |
| physical abuse, homicide, aggravated assault, robbery and sexual   |
| abuse. Substantiated cases of childhood sexual abuse have declined |
| by 49% according to the National Child Abuse and Neglect Data      |
| System.                                                            |
|                                                                    |
| When these data were first presented, some people questioned       |
| whether the results were real or statistical artifacts. The        |
| authors present their evidence for considering that the            |
| improvements are genuine. They think that it is important for      |
| policymakers to understand why this trend took place so that it    |
| can be extended or elaborated. They wonder why the data have       |
| received so little attention.                                      |
|                                                                    |
| "[I]t would seem to make sense to draw greater attention to the    |
| declines. We are actually quite baffled about why recent           |
| epidemiological reports on child maltreatment have given so little |
| attention to the issue.                                            |

                   F R O M   O U R   R E A D E R S
                             Wrong Event?
Although our family's experience begins as it did for many of you, it
ends with a different twist. In 1992, we experienced the same
bombshell many of you describe. In our case, the incomprehensible
charges focused on age 3 1/2, and they were the result of the
iatrogenic counseling of our married adult daughter.

Perhaps a bit different in our case was the detailed description of
the "rape" that was supposedly abetted by my wife. She was accused of
slapping our daughter when our daughter told her of the incident. We
never slapped any of our children.

It was not until three years later in 1995 that we pieced together
what must have happened. We read a local news article : "Suspect's
Past Becomes Issue: Man Charged with Molestation Fondled Others,
Prosecutors Say." That fondling was said to have taken place 25 years

The accused man and his wife had a young daughter who was my
daughter's teen-age schoolmate. They invited her to a weekend at the
Omaha Fair. My daughter was enthusiastic about going, but upon her
return she asked me a strange question: "Why did you let me go?"
Surprised, I responded: "Why? Didn't you have a good time?" "No," she
replied. "I don't want to talk about it." We didn't pursue it. We had
no suspicions even though hospital tests because of her subsequent
headaches found no physical pathology. Rape never occurred to us until
we read that 1995 article.

The charges against us which had seemed so incomprehensible then began
to make sense. Possibly the events of the Omaha weekend became skewed
to a belief in incest when she was 3. Perhaps the man's wife had
actually slapped our daughter as a scare tactic to prevent any
charges. We will never know for sure.

Unfortunately, our daughter's belief remains focused upon her false
memory of being raped when she was a toddler. Sadly, the alienation
remains even today
                                                          A loving dad
                            After 20 Years
FMSF families: Keep up your courage. After 20 years of being lost to
us, our estranged daughter is back from her nightmare of abuse and
satanic memories. Her exact words were: "I'm all the way back!"

Her return has been very slow, taking more than 2 years. Happily, we
are now once again as close as we were before her disastrous
therapy. Sadly, she is not in good health at this time and
unfortunately, she lives a thousand miles from us. But the good news
is that she is planning a trip home. We took a trip to see her last

Someday we may understand all the whys of this terrible period. I
suppose that each of us tries to make sense of the false memories in
our own way.

I believe that parents must forgive their children as God forgives
us. Our children have suffered as much or more than we have. I truly
believe that if you keep your faith, you will get your children back.
                                               Forever grateful mother
                              Our Story
One of our four children went to a female "Christian" therapist who
was still in training to get her MFCC. This not-yet-a-therapist worked
under the direction of Satan-chasing psychologist, Dr. F. What better
way for a student to impress Dr. F. than to find a patient who had
actually suffered satanic ritual abuse?

My daughter had sought help at a time when her basic problem was
overwork; she had a job, 3 children, and 3 stepchildren. This
not-yet-certified therapist, however, helped my daughter to believe
that her problems were caused by repressed memories of satanic ritual
abuse. The little bit of reality that grew into memories of satanic
rituals and horrible abuse was almost certainly a real memory of a
fluoroscope machine in a dark room that our pediatrician used when she
was little.

As a consequence of the therapy, our daughter was told to tell all her
siblings never to talk to us, write to us, or see us again. Another
daughter who was also overworked in her effort to be the perfect
professional, wife, and mother went to the same therapist. When her
sister told this second daughter about her new memories, it wasn't
long before she also believed she had endured satanic ritual abuse.

When I tried to see our daughters, they called the police -- as they
had been told to do. In the case of the first daughter, I would not
leave her driveway until she explained why she would not return our
phone calls. Up to this point, we had never been told what the problem
was, and we could not understand the shunning.

The police arrived and took me to the local prison. I sat there with 6
prostitutes and drug addicts, all the while reciting the Lord's Prayer
and the 23rd Psalm. Some of these women surprisingly joined me.

My husband got me released that same night. We didn't try again to see
those 2 daughters, and we did not see them or our grandchildren for
almost 10 years. Thankfully, our other 2 children thought their
sisters were imagining things and they supported us. My brother, a
Psychology Professor at San Diego State University, told me about the
False Memory Syndrome Foundation in Philadelphia. The Foundation saved
us from dying of remorse for something that never happened.

As a consequence of the existence of the Foundation, a show about FMS
appeared on Primetime TV. Our second daughter saw that program and
realized that she had been duped by bad therapy. She soon returned to
us. After another year, the first daughter also returned. Both are
once again the loving daughters they used to be.

Although we have put the lost years behind us, I vow to continue to do
all that I can to expose those charlatans who continue to practice bad
therapy that creates false memories and dupes both women and insurance
                                              Enjoying my family again
                         Afraid to Try Again
It is now 12 years since our daughter declared she was abused.

Just before she wrote us "the letter" we bought a three-flat apartment
building for her. She moved in with her then five-year-old son and
lived rent and hassle free for eleven years. During that time we had
little or no communication. In the last four years she did "manage"
the other two apartments, so she and I emailed about necessary
management issues. In fall of 2006 she moved out.

I am very happy to report she has reestablished contact with her
oldest brother and now seems to have a real life. Her son is a good
student and a gifted artist. She is living with a stable and nice
partner and she has a good job. She travels and has responsibility
and, as her brother says, "no issues." This is exactly what we hoped
for her.

She has not, however, contacted her sister, her younger brother or us
and we will leave the situation alone. Should she ever get to the
point where she can and wants to reach us, we shall respond. Her
brother has taken the attitude, what is over is just that-over. He,
however, did not suffer any harm from her -- she just stopped
communicating with him 12 years ago. He is not angry with her. Indeed,
he was always a mentor to her, so perhaps it is natural and wonderful
that they now have a good relationship.

We, on the other hand, have been abused and damned. I do not think we
will be able to let "it" go if not resolved in some fashion. It was
too devastating. Once bitten, twice shy. Actually, I'm really afraid
to try again. Her alienation may go on forever and she may never
return. If that is the case, we are prepared for that.

The one thing we have had for the past 12 years is peace. She did give
us that. For with her in our lives, we never had peace. From the time
she manifested her manic/depressive symptoms at age 11, she wore us
and the whole family down. If peace is the end result -- so be it.

Right now, I still love her and salute her triumph, but I can't accept
what she did and I don't like what she did and it will require some
heavy duty work with her to get over it. She's very bright and must
take some responsibility for what she did. That may not happen.

That being said, we were supported by FMS and will always, always
appreciate what you did and what you stand for. You helped us
tremendously and hope all of this someday comes to a withering end.
Until then -- stay strong and keep "heart."  
                                                  Forever in your debt
                      Is the Problem Ever Over?
I am sending my yearly contribution early because I believe we still
have a crisis in mental health care. I received my "letter" in 1996.
Three years later, we had a shaky reunion. In 2002, the charges
surfaced again after the birth of my son and daughter-in law's second
baby. Then, there were four "pretty good" years with lots of family
holidays and vacations.

Sadly, the ugly accusations have again surfaced after the birth of
their fourth child. My daughter-in-law says I can't see the
grandchildren unless I take responsibility for what I did! This time,
the split will be permanent. My daughter-in-law's mood swings were
totally overlooked by the therapist. I am 70-years-old and can no
longer tolerate the effect of this on my health.

The original accusations began when my son and his wife were seeing a
therapist for marriage counseling. The therapist said that the problem
in their marriage was that I, the mother, had abused my son. When I
offered to meet with her so that she could get the whole picture she
said, "I never see the guilty parent as they go nuts." This therapist
held her sessions in her living room and she insisted on being paid in
cash. There was no accountability.

I left FMSF for a few years thinking the problem was over. Is it ever?
The newsletters used to upset me when things were going well, but now,
once again, they are a comfort.
                                                   An anguished mother

*                           N O T I C E S                            *
*                                                                    *
*                      WEB  SITES  OF  INTEREST                      *
*                                                                    *
*                      *
*                       Against Satanic Panics                       *
*                                                                    *
*                         *
*            The Lampinen Lab False Memory Reading Group             *
*                       University of Arkansas                       *
*                                                                    *
*                              *
*                  The Exploratorium Memory Exhibit                  *
*                                                                    *
*                                       *
*                     The Memory Debate Archives                     *
*                                                                    *
*                                         *
*                      French language website                       *
*                                                                    *
*                  *
*             The Bobgans question Christian counseling              *
*                                                                    *
*                                       *
*                   Illinois-Wisconsin FMS Society                   *
*                                                                    *
*                                   *
*                             Ohio Group                             *
*                                                                    *
*                                           *
*                Australian False Memory Association.                *
*                                                                    *
*                                           *
*                    British False Memory Society                    *
*                                                                    *
*                               *
*            This site is run by Laura Pasley (retractor)            *
*                                                                    *
*                         *
*                            Upton Books                             *
*                                                                    *
*                   *
*                       Locate books about FMS                       *
*                     Recovered Memory Bookstore                     *
*                                                                    *
*                        *
*               Information about Satanic Ritual Abuse               *
*                                                                    *
*                                      *
*                   Parents Against Cruel Therapy                    *
*                                                                    *
*                               *
*                       New Zealand FMS Group                        *
*                                                                    *
*                                     *
*          Site run by Bruce Robinson contains information           *
*             about Christchurch Creche and other cases.             *
*                                                                    *
*                                       *
*                       Netherlands FMS Group                        *
*                                                                    *
*                                   *
*           National Child Abuse Defense & Resource Center       *
*                                                                    *
*                                  *
*                  Excerpts from Victims of Memory.                  *
*                                                                    *
*                          *
*                         Ross Institute                             *
*                                                                    *
*         *
*             Perspectives for Psychiatry by Paul McHugh             *
*                                                                    *
*                                *
*                 FMS in Scandinavia -- Janet Hagbom                 *
*                                                                    *
*                                              *
*                National Center for Reason & Justice            *
*                                                                    *
*                                      *
*          Skeptical Information on Theophostic Counseling           *
*                                                                    *
*                               *
*                Information about Attachment Therapy                *
*                                                                    *
*                                  *
*           English language web site of Dutch retractor.            *
*                                                                    *
*                                        *
*             This site is run by Stephen Barrett, M.D.              *
*                                                                    *
*                                    *
*            Contains information about filing complaints            *
*                                                                    *
*                                        *
*                  False Memory Syndrome Foundation                  *
*                                                                    *
*                     LEGAL WEBSITES OF INTEREST                     *
*                                        *
*                                           *
*                                       *
*                                           *
*                                                                    *
*                          ELIZABETH LOFTUS                          *
*                we                *
*                                                                    *
*            The Rutherford Family Speaks to FMS Families            *
*                                                                    *
* The video made by the Rutherford family is the most popular video  *
* of FMSF families. It covers the complete story from accusation, to *
* retraction and reconciliation. Family members describe the things  *
* they did to cope and to help reunite. Of particular interest are   *
* Beth Rutherford's comments about what her family did that helped   *
* her to retract and return.                                         *
*                   Available in DVD format only:                    *
*                      To order send request to                      *
*                    FMSF Video, 1955 Locust St.                     *
*                      Philadelphia, PA  19103                       *
*    $10.00 per DVD; Canada add $4.00; other countries add $10.00    *
*               Make checks payable to FMS Foundation                *
*                                                                    *
*                       RECOMMENDED  BOOKS                           *
*                                                                    *
*                       REMEMBERING TRAUMA                           *
*                       by Richard McNally                           *
*                    Harvard University Press                        *
*                                                                    *
*         S. O. Lilienfeld, S.J. Lynn and  J.M. Lohr (eds.)          *
*                  New York: Guilford Press (2003)                   *
*                                                                    *
*                         PSYCHOLOGY ASTRAY:                         *
*  Fallacies in Studies of "Repressed Memory" and Childhood Trauma   *
*                   by Harrison G. Pope, Jr., M.D.                   *
*                            Upton Books                             *
                F M S    B U L L E T I N    B O A R D

Contacts & Meetings:

  See Georgia
  Kathleen 907-333-5248
        Pat 480-396-9420
  Little Rock
        Al & Lela 870-363-4368
        Jocelyn 530-570-1862
  San Francisco & North Bay 
        Charles 415-435-9618 (pm)
  San Francisco & South Bay
        Eric 408-738-0469
  East Bay Area
        Judy 925-952-4853
  Central Coast
        Carole 805-967-8058
  Palm Desert
        Eileen and Jerry 909-659-9636
  Central Orange County -- 1st Fri. (MO) @ 7pm
        Chris & Alan 949-733-2925
  Covina Area 
        Floyd & Libby 626-357-2750
  San Diego Area 
        Dee 760-439-4630
  Colorado Springs
        Doris 719-488-9738
  S. New England
        Earl 203-329-8365 or
        Paul 203-458-9173
        Madeline 954-966-4FMS
  Central Florida -- Please call for mtg. time
        John & Nancy 352-750-5446
        Francis & Sally 941-342-8310
  Tampa Bay Area
        Bob & Janet 727-856-7091
        Wallie & Jill 770-971-8917
  Chicago & Suburbs -- 1st Sun. (MO)
        Eileen 847-985-7693 or
        Liz & Roger 847-827-1056
        Bryant & Lynn 309-674-2767
  Indiana Assn. for Responsible Mental Health Practices
        Pat 260-489-9987
        Helen 574-753-2779
  Wichita -- Meeting as called
        Pat 785-762-2825
  Louisville- Last Sun. (MO) @ 2pm
        Bob 502-367-1838
        Sarah 337-235-7656
        Carolyn 207-364-8891
        Wally & Boby 207-878-9812
   Andover -- 2nd Sun. (MO) @ 1pm
        Frank 978-263-9795
  Greater Detroit Area
        Nancy 248-642-8077
  Ann Arbor
        Martha 734-439-4055
        Terry & Collette 507-642-3630
        Dan & Joan 651-631-2247
  Kansas City  --  Meeting as called
        Pat 785-738-4840
  Springfield -- Quarterly, 4th Sat. of 
        Jan., Apr., Jul., Oct. @12:30pm
        Tom 417-753-4878
        Roxie 417-781-2058
  Lee & Avone 406-443-3189
  Jean 207-367-5819
  Mark 802-872-0847
        Sally 609-927-4147
        Nancy 973-729-1433 
  Albuquerque  -2nd Sat. (bi-MO) @1 pm
  Southwest Room -- Presbyterian Hospital
        Maggie 505-662-7521 (after 6:30 pm)
        Sy 505-758-0726
  Westchester, Rockland, etc.
        Barbara 914-922-1737
  Upstate/Albany Area
        Elaine 518-399-5749
  Susan 704-538-7202
        Bob & Carole 440-356-4544
  Oklahoma City
        Dee 405-942-0531
        Jim 918-582-7363
  Portland area
        Kathy 503-655-1587
        Paul & Betty 717-691-7660
        Rick & Renee 412-563-5509
        John 717-278-2040
  Wayne (includes S. NJ) -- 2nd Sat. (MO)
        Jim & Jo 610-783-0396
  Nashville -- Wed. (MO) @1pm
        Kate 615-665-1160
        Jo or Beverly 713-464-8970
   El Paso
        Mary Lou 915-595-2966
        Keith 801-467-0669
        Mark 802-872-0847
        Kathy 503-557-7118
        Katie & Leo 414-476-0285 or
        Susanne & John 608-427-3686
        Alan & Lorinda 307-322-4170

  Vancouver & Mainland 
        Lloyd 250-741-8941
  Victoria & Vancouver Island
        John 250-721-3219
        Roma 204-275-5723
        Adriaan 519-471-6338
        Eileen 613-836-3294
        Ken & Marina 905-637-6030
        Paula 705-543-0318
        Mavis 450-882-1480
  FMS ASSOCIATION fax 972-2-625-9282 
        Colleen 09-416-7443
        Ake Moller FAX 48-431-217-90
  The British False Memory Society
        Madeline 44-1225 868-682
         Deadline for the Winter 2007 issue is December 1
                  Meeting notices MUST be in writing
    And should be sent no later than TWO MONTHS PRIOR TO 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". 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.

PAMELA FREYD, Ph.D.,  Executive Director

FMSF Scientific and Professional Advisory Board,       October 1, 2007

AARON T. BECK, M.D., D.M.S., U of Pennsylvania, Philadelphia, PA;
TERENCE W. CAMPBELL, Ph.D., Clinical and Forensic Psychology, 
    Sterling Heights, MI;
ROSALIND CARTWRIGHT, Ph.D., Rush Presbyterian St. Luke's 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;
FRED H. FRANKEL, MBChB, DPM, Harvard University Medical School;
GEORGE K. GANAWAY, M.D., Emory University of Medicine, Atlanta, GA;
MARTIN GARDNER, Author, Hendersonville, NC;
ROCHEL GELMAN, Ph.D., Rutgers University, New Brunswick, NJ;
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., (deceased) Mount Sinai School of Medicine, 
    New York, NY;
ERNEST HILGARD, Ph.D., (deceased) 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., (deceased) Harvard University, 
    Cambridge, MA;
ROBERT A. KARLIN, Ph.D. , Rutgers University, New Brunswick, NJ;
HAROLD LIEF, M.D., (deceased) University of Pennsylvania, 
    Philadelphia, PA;
ELIZABETH LOFTUS, Ph.D., University of California, Irvine, CA;
SUSAN L. McELROY, M.D., University of Cincinnati, Cincinnati, OH;
PAUL McHUGH, M.D., Johns Hopkins University, Baltimore, MD;
HAROLD MERSKEY, D.M., University of Western Ontario, London, Canada;
ULRIC NEISSER, Ph.D., Cornell University, Ithaca, NY;
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., (deceased) U of Pennsylvania, Philadelphia
LOREN PANKRATZ, Ph.D., Oregon Health Sciences Univ., Portland, OR;
CAMPBELL PERRY, Ph.D., (deceased) 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, Boston, MA;
JAMES RANDI, Author and Magician, Plantation, FL;
HENRY L. ROEDIGER, III, Ph.D. ,Washington University, St. Louis, MO;
CAROLYN SAARI, Ph.D., Loyola University, Chicago, IL;
THEODORE SARBIN, Ph.D., (deceased) University of California, 
    Santa Cruz, CA;
THOMAS A. SEBEOK, Ph.D., (deceased) U of Indiana, 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., {deceased) 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 Ctr, 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

                     YOUR CONTRIBUTION WILL HELP
                   Please Fill Out All Information
                             Please Print

       __Visa: Card # & exp. date:_____________________________

       __Discover: Card # &  exp. date:________________________

       __Mastercard: # & exp. date:____________________________

       __Check or Money Order:_________________________________

      Signature: ______________________________________________

      Name: ___________________________________________________


      State, ZIP (+4) _________________________________________

      Country: ________________________________________________

      Phone: (________)________________________________________

      Fax:  (________)_________________________________________


	  Reprinted from Spring 2007 FMSF Newsletter, 16(2)

                    COURT TOSSES ALL BUT ONE CLAIM
      Taus v. Loftus, S133805. Cal Sup. Ct. Filed Feb. 26, 2007.
                       (Decision available at:

On February 26, 2007, the California Supreme Court ruled in the Taus
v. Loftus case that journalists and scholars can be held liable for
invasion of privacy if they misrepresent themselves in order to obtain
information. In a 5 to 2 decision written by Chief Justice George, the
court tossed out three of the four issues under examination. Justices
Moreno and Baxter dissented, arguing that all four items should have
been stricken. The court ordered that Taus pay the costs of the Loftus
appeal writing:

  "[I]t is apparent when the determinations of the Court of Appeal and
  this court are viewed as a whole that the overwhelming majority of
  plaintiff's claims properly should have been struck in the trial
  court under the anti-SLAPP statute. Under these circumstances, and
  consistent with the fundamental purpose of the anti-SLAPP statute to
  minimize the chilling of conduct undertaken in furtherance of the
  constitutional right of free speech, we conclude that it is
  appropriate to award defendants their costs on appeal." Majority
  opinion, page 78.

Readers may recall that Elizabeth Loftus, a courageous founding member
of the Scientific and Professional Advisory board of the Foundation,
and Mel Guyer conducted an investigation into the 1997 "Jane Doe" case
study published by Corwin and Olafson [1] after widespread claims were
circulated that the study proved that people could repress and then
recover accurate memories of abuse. Loftus and Guyer arrived at a very
different conclusion, but before they could publish their results,
Nicole Taus and Lynn Crook filed ethical complaints against Loftus at
the University of Washington in connection with the research. Although
Loftus was exonerated, her records were confiscated for almost two
years. In 2002, Loftus and Guyer published "Who Abused Jane Doe? The
Hazards of the Single Case History."[2]

Soon after the publication of the article, Nicole Taus filed a
complaint [3] against Loftus and Guyer. The complaint also named Carol
Tavris, who had written about the Loftus/Guyer article, the Skeptical
Inquirer, that had published the article, the University of
Washington, and Shapiro Investigations, a firm that had helped Loftus
and Guyer in their investigation. The complaint had four causes of
action: negligent infliction of emotional distress, invasion of
privacy, fraud, and defamation.

Some of the defendants filed a motion to have the complaint
stricken. They argued that the Taus lawsuit was a "Strategic Lawsuit
Against Public Participation" (SLAPP). SLAPP suits are retaliatory
lawsuits intended to silence, intimidate, or punish those who have
used public forums to speak, petition, or otherwise move for
government action on an issue of public interest. The trial court
denied most of the actions to strike and the defendants appealed. The
Court of Appeal concluded that the majority of the Taus claims should
have been dismissed, but it held that the legal case could proceed on
four counts of action against Loftus. Loftus then appealed to the
California Supreme Court. The case received wide attention and the
Court received a number of amicus briefs, especially because of its
importance to First Amendment issues.

The California Supreme Court then reviewed whether the Court of Appeal
properly concluded that the following actions against Loftus should
remain. The four actions were: 1) Loftus defamed Taus in a talk at an
October 2002 FMSF seminar in Chicago; 2) Loftus disclosed private
facts about Taus in a deposition; 3) Loftus improperly intruded into
private matters by collecting information from court records; 4)
Loftus improperly intruded into private matters by misrepresenting her
relationship to Corwin. The Court dismissed the first three actions
and ordered that Taus must pay Loftus' legal expenses.

Loftus has vigorously denied the accusation of the remaining action
that she misrepresented her relationship with Corwin when she
interviewed Taus's former foster mother, Margie Cantrell. Ms. Cantrell
has declared that she was contacted by Loftus in 1997 and that Loftus
said that she was the supervisor of David Corwin. Cantrell provided
some details about Taus's life. In the majority decision, Chief
Justice Ronald M. George wrote that "personal information about a
person that happens to be known by the person's relatives or close
friends is not information that has entered the public domain." In
their dissent, Justices Carolos R. Moreno and Marvin R. Baxter wrote
that Nicole Taus had no reasonable expectation that her former foster
mother would not talk about her. "The majority's desire to protect
society from the kind of misrepresentations alleged in the present
case is understandable...will likely chill vigorous journalistic
investigation because of the inherently problematic nature of the
relationship between journalists and their news sources." The
California Supreme Court ordered that the claim be settled at the
trial level.

An attorney who represented the news media expressed concern that the
decision will cause problems for other journalists and investigators
who may interview third parties. [4] He said that that it was not
unusual for embarrassed news sources to later claim that they had been

Supporters of recovered memories have claimed victory in this case. In
a letter to the Los Angeles Times, Joyanna Silberg wrote that the
California Supreme Court upheld the viewpoint of the Leadership
Council, on human-subjects-research.[5] In its decision, however, the
California Supreme Court on page 32, footnote 11, expressly noted

  "[T]he Court of Appeal rejected plaintiff's claim that the first
  amended complaint stated a cause of action based on defendants'
  alleged breach of professional ethics, and plaintiff did not seek
  review of that ruling. Accordingly, the human-subjects-research
  issue raised by amicus curiae is not properly before us and will not
  be addressed."

Loftus's attorney said that he was pleased that most of the lawsuit
was dismissed and that the Court decided that Taus must pay Loftus'
legal bills. Burke said that Loftus will be able to prove that she did
not misrepresent herself. "There was no trickery and no misrepres-
entation," he stated. "It was a four-hour interview and [the foster
mother] knew who she was speaking to."[6]

Elizabeth Loftus commented that she is gratified that the vast
majority of the claims were dismissed. She said that the one remaining
claim is completely untrue. She also noted that in all of this case
there is something missing: the voice of the falsely accused mother.

Thomas Burke of Davis Wright Tremaine in San Francisco represents
Elizabeth Loftus. Julian Hubbard of Hubbard & Ebert in Redwood City,
California represents Nicole Taus.

[1] Corwin, D.L. & Olafson, E. (1997). Videotaped discovery of a
    reportedly unrecallable memory of child sexual abuse: Comparison
    with a childhood interview videotaped 11 years before. Child
    Maltreatment 2, 91-112.
[2] Loftus, E.F. & Guyer, M.J.(2002, May/June, July/August). Who
    abused Jane Doe? The hazards of the single case history. Skeptical
    Inquirer, Part 1, 24-32. Part 2, 37-40. Article available at: Doe.htm.
[3] Taus v. Loftus. No FCS 021557, Sup. Ct. of Cal., Solano
    County. See FMSF Newsletter 12(3).
[4] Dolan, M. (2007, February 27). Ruling may constrain researchers.
    Los Angeles Times. Retrieved on February 27, 2007 from,1,4612801.story.
[5] Silberg, J. (2007, March 5). Ethical guides are already in place.
    Los Angeles Times.
[6] Ward, S.F. (2007, March ). Interview methods face trial. Retrieved from www.abanet/journal/redesign/
    m5reserch.html on March 14, 2007.