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amnesia.” (Report at 2.) Similar reference to this study is made in his book to the effect that “amnesia for Nazi Holocaust experiences has also been reported.” However, that characterization of the study’s findings is misleading, at best. In that regard, the study noted a “remarkable degree of remembering” when comparing the survivors’ current recollections of their internment with depositions that they had provided shortly after their liberation. The study did not note “dissociative amnesia.” (McNally Decl. 8.) The study’s authors remarked that “There is no doubt that almost all witnesses remember Camp Erika in great detail, even after 40 years” (p. 84). (Id.) It is simply inexplicable that Dr. Brown would cite this study as supportive of the hypothesis of “dissociative amnesia” when the study apparently contradicts the theory. In summary, the instances documented above reveal an extensive pattern of misrepresentation with regard to the peer review publications that support his theory of traumatic amnesia and dissociative amnesia. There can be little question that the purpose of these erroneous citations was to bolster the “reliability” and “relevance” of his theory, when in fact these very studies either reach conclusions contrary to that theory or completely fail to address the point. What is most significant here is that he was under no obligation to cite these studies. But, having done so, he was assuredly under an obligation to truthfully represent the nature of the study and the conclusions reached therein. The misrepresentations constitute grounds for vacating the judgment under Rule 60(b). C. Dr. Brown Misrepresented That the Theory of Dissociative Amnesia Is Generally Accepted by the Relevant Scientific Community. Dr. Brown also testified that the dissociative amnesia hypothesis is “generally accepted” amongst the relevant scientific community; however, that assertion is patently false. At best, this issue represents a heated controversy within the relevant scientific community – perhaps more - 20 -
accurately it is akin to a land war. (See generally Barden Decl. 12-20 and authorities cited therein.) However, rather than simply admit the controversial nature of his theory, Dr. Brown persists in misrepresenting surveys and studies as supporting a conclusion of general acceptance when they do no such thing. For instance, Dr. Brown cites certain surveys and testifies that a combined figure of 89% of respondent members of the relevant scientific community either consider dissociative amnesia valid or possibly valid. (Tr. at 46:14 – 47:4.) There are two major errors with Dr. Brown’s conclusion. First, the surveys to which Dr. Brown cites involved mostly practicing clinicians including psychiatrists, psychologists, social workers, counselors, and other types of therapists. However, practicing clinicians are not the “relevant scientific community” in this case. (Pope Decl. 36.) This is so because “such clinicians may or may not have sufficient training to be able to evaluate the merits of a theory such as ‘dissociative amnesia.’ Indeed, many types of practicing clinicians have had little formal scientific training, and very little ability to evaluate the methodology and conclusions of peer-reviewed scientific studies.” (Id.) Furthermore, even if clinicians are members of the relevant scientific community, Dr. Brown has misled this Court as to the meaning of these surveys. In particular, the inclusion of individuals responding “possibly valid” as being among those in general acceptance of the theory is without support. As Dr. Pope notes: The truth is that a response of “possibly valid” does not mean that a hypothesis is scientifically accepted. For example, many scientists would agree that there is “possibly” some form of life on Mars, at least on a bacterial level. A search for evidence of such life is currently underway. But the fact that many scientists think there is “possibly” life on Mars does not mean that it is generally accepted in the relevant scientific community that there is life on Mars. - 21 -
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 and 16: subjects are asked if they recall h
Page 17 and 18: of “complete forgetting.” Nonet
Page 19: And the list continues. Dr. Brown m
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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