GORDON KEENE VELLA. - On Point News

[S]etting aside the question of whether these people’s reports were or were
not false, it is not possible to state with confidence that any of the people
“completely forgot the abuse.” In other words, the error rate for
diagnosing “dissociative amnesia” in the studies could effectively be as
much as 100%.
(Id.)
Indeed, Dr. Brown’s “passing off” his accuracy error rate as an error rate applicable to
the theory of repressed memory itself represents an overt misrepresentation, and Dr. Pope’s
characterization of it as being only “misleading” is generous to a fault.
The distinction between the theory itself and the accuracy of recovered memories is a
critical distinction and must not be overlooked, especially not in the present case. The question
of whether or not the “memories” are accurate, while relevant to the question of liability, does
not address the statute of limitations issue in this case. In fact, Dr. Brown’s representation of
error rate was in response to a question regarding the underlying hypothesis and not the
purported accuracy of allegedly recovered memories. The desire for an articulated error rate for
the hypothesis flowed naturally from the fact that Dr. Brown’s entire premise, and indeed the
ability to maintain Plaintiff’s case, was predicated upon the validity of Dr. Brown’s hypothesis
that an individual can “completely” forget or repress a memory and then fully recover that
memory years later. 6
(See Filing 225, Mem. & Order on Summ. J. at 15-17) (finding that Dr.
Brown’s testimony created genuine issue of material fact as to whether Plaintiff had, in fact,
been unable to access memories until long after limitations period ended.)
6
“Dissociative amnesia” refers to the hypothesis that an individual could develop
amnesia for a traumatic event, such that the person was unable to remember the event
afterwards. The term does not apply to individuals who simply tried not to think about
an event, or who had simply not recalled the event for a long period of time, but who
would have been perfectly capable of recalling the event if specifically asked about it.
(Pope Decl. 9.)
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