GORDON KEENE VELLA. - On Point News

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.)
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