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Melchert and Parker study as one of the 87 studies in which the authors found “complete forgetting” when the study actually contradicts that theory. (Pope Decl. 16.) Another study cited by Dr. Brown as supportive of dissociative amnesia, the Epstein and Bottoms study, repeatedly questions the legitimacy of the theory, rather than offering support for it. As Dr. Pope explains, Epstein and Bottoms opined that “some victims who report temporary forgetting might have always remembered an event but thought about it differently during certain periods of their lives . . . .” (Pope Decl. 17) (emphasis added.) Additionally, Epstein and Bottoms noted that some respondents may have “forgotten” their abuse because they chose not to think about it and not because the memories were actually unavailable. (Pope Decl. 18.) The Epstein and Bottoms study is especially significant here because it confronted headon Dr. Brown’s theory that repressed memories are “inaccessible” so as to constitute a basis for tolling a limitations period. The authors of that study concluded that the temporary forgetting reported by their test subjects would “not meet the [legal] standard set by the more common delayed discovery doctrine adopted by many states to accommodate repressed memories of abuse, wherein victims seek redress after normal statutes of limitations have lapsed must prove that they had no memory (classic repression) of the sexual abuse until filing suit (Brown et al., 1998).” (Pope Decl. 19.) Significantly, the “Brown et al., 1998” cited by Epstein and Bottoms is the very same Daniel Brown who testified at trial in this matter. (Id. 20.) Thus, the Epstein and Bottoms study repeatedly questions whether true amnesia has occurred in any of the test subjects and explicitly concludes that the reports of forgetting would not meet Dr. Brown’s own definition of repressed memories sufficient to toll a statute of limitations, specifically calling out Dr. Brown by name, and contradicts Dr. Brown’s hypothesis - 16 -
of “complete forgetting.” Nonetheless, Dr. Brown explicably cites the Epstein and Bottoms study as supportive of his theory of dissociative amnesia. Dr. Brown also cites numerous studies known as prospective studies where a traumatic event is known to have occurred in the past. (See Pope Decl. 23-24.) However, these studies also fail to demonstrate “complete forgetting” and prompt Dr. Pope to opine that Dr. Brown’s misrepresentations have misled the Court and the jury by using that term. (Pope Decl. 23.) In these prospective studies, individuals known to have suffered from some traumatic event were interviewed at a later date to ascertain whether they recalled the experience. In many of these tests, the subjects are not actually asked if they remember the specific trauma event. Instead they were simply asked about traumatic events, in general. They were not asked whether they remembered the known trauma even if they failed to disclose it. As Dr. Pope explained, attributing “nondisclosure” to “complete forgetting” is misleading. (Pope Decl. 24.) In fact, one prospective study cited by Dr. Brown as support for “dissociative amnesia” reported finding no “special memory mechanisms unique to traumatic events.” (Pope Decl. 26.) A conclusion precisely opposite Dr. Brown’s hypothesis. In that study, Goodman and colleagues followed numerous known victims of childhood trauma. Some of the victims did not report their sexual abuse following interviews about trauma. At the conclusion of the study, Goodman and colleagues cautioned that “failure to report CSA [childhood sexual abuse] should not necessarily be interpreted as evidence that the abuse in inaccessible to memory.” (Id.) (emphasis added.) Yet, despite the fact that the Goodman study questions whether failure to report childhood sexual represents compete forgetting, Dr. Brown presents the study as supporting that very theory. (Pope Decl. 27.) - 17 -
Page 1 and 2: IN THE UNITED STATES DISTRICT COURT
Page 3 and 4: eviews, and 7 books on different ar
Page 5 and 6: new trial under Rule 60(b)(3) upon
Page 7 and 8: Significantly, the court so held ev
Page 9 and 10: is presumed to have been aware of t
Page 11 and 12: [S]etting aside the question of whe
Page 13 and 14: Dr. Barden, “As a national expert
Page 15: subjects are asked if they recall h
Page 19 and 20: And the list continues. Dr. Brown m
Page 21 and 22: accurately it is akin to a land war
Page 23 and 24: which is mentioned by Dr. Brown in
Page 25 and 26: when many of those publications eit

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