GORDON KEENE VELLA. - On Point News

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.
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