False Memory Syndrome: A False Construct

Juliette Cutler Page

In recent years, one of the most controversial concepts in psychology has been that of "recovered memory". Many therapists have become wary of treating clients who appear to have recovered memories of abuse after a long period of forgetting. Among the reasons for this concern are extremely vocal organizations that have come forward in support of accused abusers, claiming that there is no such thing as "recovered memory", and often stating that not only are therapists who treat such clients negligent, but that therapists are in fact themselves creating these memories in their clients. This article will discuss the origins and methods of the primary such organization (the False Memory Syndrome Foundation), and in so doing, address relevant issues of memory and the experience of abuse.

The concept of "recovered memory", that is, memory of a traumatic event that had been forgotten for some period of time, has been variously explained by such mechanisms as repression, amnesia, and dissociation. However, there are over 100 years of reports and descriptions of recovered memory in the literature, including instances from times of war, torture, bereavement, natural disasters, and concentration camp imprisonment. (HOROWITZ) Many corroborated cases have been documented in instances of recovered memory of sexual abuse, as well, which will be discussed later in this paper.

Responses to trauma now termed, for example, "repression", "Post-traumatic stress disorder", or "dissociation" have been recognized literally for thousands of years. Charcot (a neurologist) in the late 1800’s recognized that "hysteria" was precipitated by events that the patient experienced as stressful or traumatic. Several years later, Janet noted what we now term "dissociation" as primary symptoms of hysteria - forgetting and disconnection from emotions and/or experience. Janet also observed the re-living or re-enactment of trauma that remains one of the criteria of PTSD. As psychology and the DSM evolved, the trauma response "hysteria" did as well, becoming various hysterical neuroses, and eventually somatoform or dissociative disorders. (KIHLSTROM).

However, organizations formed in support of those accused of abuse have chosen to ignore this history. One such organization, the False Memory Syndrome Foundation, was born in November 1991 as a result of an article in the Philadelphia Inquirer. In this article, a couple claimed that their adult daughter had recovered memories of incest in therapy, and as a result refused contact with some friends and family. The couple denied any incest. In the week after the article appeared, a University of Pennsylvania professor (Harold Lief) who was quoted in the column received a number of telephone calls from people who felt that they, too, had been falsely accused.

During this time, a psychologist at Stanford University had cut off communication with her father after confronting him with her own memories of abuse. Her parents, Peter (a mathematician at the University of Pennsylvania) and Pamela Freyd, joined Dr. Lief in March of 1992 to form the False Memory Syndrome Foundation. All three are still FMSF board members.

The story of Dr. Freyd and her parents is an illustrative one. Dr. Freyd confronted her father privately with her memories, yet her parents chose to take their experiences public. The story contains several examples of questionable behavior by FMSF board members, which became a pattern, as will be discussed later in this paper. For example, the very same Dr. Harold Lief who formed the FMSF with Pamela and Peter Freyd was the therapist not only of Dr. Freyd, but also of her father. Lief, in fact, told Dr. Freyd that he did not believe her memories of abuse, stating that they could not have happend because in his experience, Peter Freyd’s fantasies were "entirely homoerotic". (FREYD) Pamela Freyd, on her part, took her daughter’s private life public in an article (published as a book chapter and a journal article) that disparaged Dr. Freyd’s personal life and compared Dr. Freyd’s successful professional career unfavorably to her own. She also, in an interesting foreshadowing of future FMSF members’ positions on child abuse, ridiculed those who were opposed to child sexual abuse as "politically correct" and therefore, perhaps, merely trendy.

Interestingly, Dr. Freyd’s memories were supported by other family members. Her uncle William, Peter’s brother, stated in a letter that "there’s no doubt in my mind that there was severe abuse.... The false memory syndrome foundaton is a fraud designed to deny a reality that Peter and Pam have spent most of their lives trying to escape. There’s no such thing as a false memory syndrome. It is not, by any normal standard, a foundation. Neither Peter nor Pam have any significant mental health expertise."(FREYD LETTER)

The False Memory Syndrome Foundation created the term "false memory syndrome" to explain how false accusations could occur. Further than that, however, the FMSF has taken the stance that delayed memories are often false, and that memories recovered in therapy are particularly suspicious. Their theory has been that vulnerable women are often coerced into believing they have been abused by therapists who are either more interested in having long-term clients than in assisting those clients, or who are unknowingly creating false memories in their clients through hypnosis or suggestion.

Increasingly throughout the country, grown children undergoing therapeutic programs have come to believe that they suffer from "repressed memories" and incest and sexual abuse. While some reports of incest and sexual abuse are surely true, the decade delayed memories are too often the result of False Memory Syndrome caused by a disastrous "therapeutic" program. False Memory Syndrome has a devastating effect on the victim and typically produces a continuing dependency on the very program that creates the syndrome. (FMSF Newsletter, May 1995)

Dr. John F. Kihlstrom, professor of psychology at Yale University and a member of the FMSF, has suggested the following definition of "false memory syndrome":

" a condition in which a person's identity and interpersonal relationships are centered around a memory of traumatic experience which is objectively false but in which the person strongly believes. Note that the syndrome is not characterized by false memories as such. We all have memories that are inaccurate. Rather, the syndrome may be diagnosed when the memory is so deeply ingrained that it orients the individual's entire personality and lifestyle, in turn disrupting all sorts of other adaptive behavior. The analogy to personality disorder is intentional. False memory syndrome is especially destructive because the person assiduously avoids confrontation with any evidence that might challenge the memory. Then it takes on a life of its own, encapsulated and resistant to correction. The person may become so focused on memory that he or she may be effectively distracted from coping with the real problems in his or her life."

Kihlstrom does not mention his basis for the creation of this definition (studies, case reports, etc.). The FMSF website (http://advicom.net/~fitz/fmsf/) notes, in its section "What Are The Symptoms Of FMS?":

John Kihlstrom's definition offers a general description of many who were making accusations. In virtually every situation of which the Foundation is aware, the accusing adult was facing emotional and psychological distress. Often there was a precipitating event such as a job loss or change, divorce, eating disorder, relationship problem, or birth or death in the family. These contemporary concerns were seldom addressed in therapy.

Other common observations of FMS are: radically changed behavior, claiming a new malady of repressed memory syndrome, redefining personal history, assuming a new identity and refusing to have contact with anyone who did not share the beliefs of abuse.

The symptoms indicated that FMS was probably of social origin such as in folie a deux. FMS is not listed in the Diagnostic and Statistical Manual-IV (1994). It quite properly takes many years for the official recognition of a medical diagnosis. The fact that the major professional organizations have issued statements about FMS is an indication of its seriousness.

"The AMA considers recovered memories of childhood sexual abuse to be of uncertain authenticity, which should be subject to external verification. The use of recovered memories is fraught with problems of potential misapplication."

Council on Scientific Affairs

American Medical Association, June 16, 1994

Again, no basis for these statements is given. In fact, the syndrome as described above can alternately be explained by disorders that are included in the DSM-IV, such as post-traumatic stress disorder, varioius amnesias, or dissociation.

Members of the FMSF are largely individuals who seek to defend themselves from accusations of sexual abuse of children. The FMSF does not attempt to determine whether these members are falsely accused or not. However, everyone who contacts their organization is included in their statistics of "falsely accused". There is little discrimination or skepticism, although members often criticize supporters of survivors of sexual abuse for believing the survivors.

The language used by the FMSF (particularly in its newsletter) regarding psychiatry, therapists, survivors, and women in general is frequently negative. For example, the previous quote attempting to define false memory syndrome implies that those who recall past abuse are suffering from a personality disorder, rather than retrieving recollections of actual events. How to determine the veracity of memories is not discussed; instead, such memories are simply assumed to be false. There is certainly no question that external verification for repressed memories should be sought, and that failing external verification, great care should be taken in whatever "application" of these memories (again, see above quote) might occur. However, the very use of the term "application" in this context implies that monetary gains are the reason behind accusations of abuse. In fact, most survivors do not sue or even confront their abusers, due to the tremendous emotional pain involved, and those who do very rarely gain significant financial reward.

The majority of sexually abused children are girls. The National Committee for the Prevention of Child Abuse has estimated that one in three girls is sexually abused before age 18 (one in four before 14), and one in six boys before age 16. In 85% of cases, the perpetrator is known to the victim, and 1 in 25 girls is sexually abused by her father. (NCPCA) The FMSF believes that women who report recovered memories of sexual abuse are led by therapists to accuse their own families of abuse from their own sincere belief of incidents which did not occur. However, the FMSF provides no research or statistics to support this claim. Much FMSF evidence appears to be anecdotal. The FMSF has even appeared to falsify its own membership statistics - for example, in the June 7, 1995 newsletter, Accuracy About Abuse, the following notice appeared:

The American False Memory Syndrome Foundation is widely quoted as having 16,000 families as members but recently Peter Freyd admitted they have only about 2500 dues paying members.

The British False Memory Society which maintains close links with the American FMSF, now admits to 230 paid members as of December 1994, not the 650 more usually reported.

Ralph Underwager (who coined the term "false memory syndrome") and Hollida Wakefield, a married couple on the original FMSF Board of Advisors, have gone so far as to claim that "the women who make false allegations based on recovered memories [are] very angry, hostile, and sometimes paranoid... All will have demonstrated some type of psychopathology in earlier parts of their lives." (1984) Again, no evidence to support this is given. Neither do they state how such accusations have been determined to be false. Nor do Wakefield and Underwager consider why such women might justifiably be angry or appear "paranoid".

The FMSF also does not discuss the possibility that accused parents are misremembering the abuse (or lack thereof.) In an article in the Psychological Bulletin, Brewin notes:

Memories of childhood are likely to be more mis-remembered by over positive parents than their adult children. Parents may play a significant role in distorting reality and determining the family mythology concerning earlier events. Parental reports are

especially suspect as a guide to the reality of family life. Memory biases are not found more often in anxious patients and the recall of psychiatric patients is as reliable as that of non patients. The central features of accounts of childhood are likely to be reasonably accurate. Because memory distortion occurs more often to inhibit recall or disclosure, it seems fair to conclude that reports confirming events should be given more weight than ones which deny them. (FOOTNOTE)

Jackson and Thomas note that " It is now generally recognized by those working with sex offenders that child abusers, rapists and perpetrators of incest have an extraordinary capacity for denial and minimisation." Anna Salter, in her book Treating Child Sex Offenders and Victims, remarks that "Offenders may continue to assert their innocence despite overwhelming evidence and despite good rapport with their therapists .... offenders can be quite convincing when asserting their innocence." However, the FMSF makes no mention of this possibility.

In fact, there has been very little scientific endeavor involved in the formation and advertisement of "false memory syndrome". In a 1994 interview with the publication Treating Abuse Today , FMSF Exective Director Pamela Freyd was unable to provide a definition for "false memory syndrome". It is difficult to see how FMSF members could make claims about a syndrome so ill-defined that even their own Executive Director could not explain it. FMSF members paradoxically claim to place great value on scientific inquiry, while permitting their syndrome to remain so vaguely defined that it is virtually impossible not only to study it, but to determine who suffers from it.

A literature review by Wendy E. Hovdestad and Connie M. Kristiansen in the Journal of Psychiatry and Law attempted to determine clusters of symptoms underlying false memory syndrome as described by the FMSF. They then examined women with recovered memory for congruence with these clusters, and discovered that only 3.9% to 13.6% percent of these women with recovered memory met the criteria used by the FMSF itself to define false memory syndrome. This indicates that even of those women in the highest "risk group" for false memory syndrome, only a small percentage comforms to the (problematic) description provided by the FMSF, which contrasts quite dramatically with the FMSF’s description of a "false memory syndrome epidemic" sweeping the country. (The FMSF have been making claims that there is a false memory syndrome epidemic since 1993.)

FMSF members call those who believe survivors' stories "true believers", comparing them to hysterical murderers of witches (in this case, the witches are the innocent accused). FMSF members have personally attacked those who disagree with them, yet also accuse those same people for " unprofessional" and "unscientific" behavior. Many of these personal attacks are irrelevant to the discussion, such as when Marjorie Orr of the newsletter Accuracy About Abuse was ridiculed for her belief in astrology. However, in a few notable cases, the attacks were public and unfounded. For example, Elizabeth Loftus accused Kenneth Pope, a respected memory and trauma researcher, in the APA journal Clinical Psychology of being "wildly reckless" in an area of ethics. Her claim was later investigated by the journal and found to be false. The Fall 1997 issue of the journal published a correction and apology for the "false statement disparaging Dr. Pope’s ethics". (POPE LETTER ETC) It is disheartening to observe the FMSF, which in its newsletters and publications continually emphasizes the importance of scientific discourse, actively promoting such accusations.

In further evidence of questionable activity by FMSF board members, Notes from the Controversy (Treating Abuse Today, Nov./ December 1995, Jan./ Feb. 1996), discusses ethics complaints filed with the American Psychological Association against Elizabeth Loftus regarding her article "Remembering Dangerously", which was published in a 1995 issue of Skeptical Inquirer, a publication of the Committee for the Investigation of Claims of the Paranormal (CSICOP). In this article, Loftus reviews the case study of "Jennifer H.", in which she cites the court case Hoult vs. Hoult (thus revealing the identity of the persons involved). In 1988, Jennifer Hoult sued her father alleging sexual abuse and rape. Hoult provided corroborative evidence and was awarded $500,000 by the jury for the suffering caused by her father's abuse. Higher courts later upheld this jury's decision, including the first circuit appellate court. At some point during the proceedings, which lasted more than five years, Hoult's father joined the FMSF.

In "Remembering Dangerously," Loftus (who is not a clinician and who has no training or clinical experience in child psychology, trauma, processes of traumatic memory, or child sexual abuse) claimed that Hoult recovered her memories in therapy, which was not the case. According to Hoult, Loftus added events to the case study which did not occur and made various misstatements regarding the abuse.

In the January/February 1995 issue of Psychology Today, Loftus reviewed the legal case of Lynn Crook, who successfully sued her parents for abuse. Crook had presented testimony in her case from two sisters who also remembered incest by their father. In the article, Loftus presented the case with (according to Crook) nine crucial misstatements.

As a result of the errors in these articles, Jennifer Hoult and Lynn Crook, filed separate complaints with the APA against Elizabeth Loftus. Crook and Hoult filed their complaints on December 18, 1995. According to the rules and procedures of the APA ethics office, the chairman of the APA Ethics Committee (an active expert witness for accused perpetrators of abuse, and against therapists accused of implanting false memories in their clients) was responsible for the initial screening of all such complaints. The chairman and Loftus were, in fact, working together on a different case when the complaints were filed. They later claimed they had been unaware of this coincidence. The chair took no action before Loftus resigned from the APA less than a month later. After Loftus' resignation, the APA declined to investigate the charges.

Loftus gave as her reason for resigning from the APA as her belief that the APA had "moved away from scientific and scholarly thinking." The APA publishes many of the most prominent scientific psychological journals.

As mentioned above, the FMSF is characteristically intolerant of those who do not agree with their beliefs. In the newsletter and in board member publications, people with recovered memories and their supporters (particularly therapists) are compared to accusers in the Salem "witch hunts". FMSF members consider themselves to be victims of a "modern witch hunt". In fact, a popular Internet mailing list of supporters of FMS (listed on the FMS home page, but officially "not affiliated with the FMSF") is called "WITCHUNT", and is described on the FMS website as "a discussion list about the recent ‘ritual child abuse’ trials‘". In Loftus' 1995 introduction to her article Remembering Dangerously, Loftus says "we live in a strange and precarious time that resembles at its heart of the hysteria and superstitious fervor of the witch trials of the 16th and 17th centuries. Men and women are being accused, tried, and convicted with no proof or evidence of guilt other than the word of the accuser. Even when the accusations involve numerous perpetrators, conflicting grievous wounds over many years, even decades, the accused's pointing finger of blame is enough to make believers of judges and juries. (P. 20)" Many judges of court cases would be quite surprised at hearing that they had convicted perpetrators solely at "the word of an accuser".

In negative language that has become emblematic of the FMSF, Loftus’ book , " the myth of repressed memory: false memories and allegations of sexual abuse" repeatedly uses the metaphor of "an earlier time when God-fearing citizens, gripped by fear, superstition, and religious fervor, cried witch, and a forest of stakes was pounded into the very heart of the community"(p. 228). Quotes from Arthur Miller's book the Crucible are prominently featured. However, the "hysteria" implied by Loftus is not that of female victims of abuse who have developed dissociative or other coping skills as a result of the abuse, but that of female therapists who implant false memories and the female patients who believe them.

In an unsuccessful lawsuit brought by Ralph Underwager and Hollida Wakefield against psychologist Anna Salter in 1994 for defamation stemming from a study which mentioned their research, the court found that Underwager and Wakefield’s books, written claiming that most accusations of childhood sexual abuse result from memories implanted and created by therapists,

"have not been well received in the medical and scientific press. A review of the first in the Journal of the American Medical Association concludes that the authors took a one-sided approach: "... When a given reference fails to support the viewpoint, they simply mis-state the conclusion. When they cannot use a quotation out of context from an article, they make unsupported statements, some of which are palpably untrue and others simply unprovable.""

The court further described Underwager's testimony that "children are incapable of correctly remembering or accurately describing sexual contacts," and indeed stated that "Underwager is a hired gun who makes a living deceiving judges about the state of medical knowledge and thus assisting child molesters to evade punishment." Underwager himself resigned from the FMSF in 1994 after being quoted in a Dutch journal as saying that "Paedophiles can boldly and courageously affirm what they choose... With boldness they can say "I believe this is in fact part of gods will"... Paedophiles need to become more positive and make the claim that paedophilia is an acceptable expression of gods will for love and unity among human beings."" In fact, both Underwager and Wakefield have described pedophilia as a "positive lifestyle choice" (Bull & Marten, 1994; Ryan 1993b).

One would think that those allied with a group of falsely accused perpetrators would distance themselves from pedophilia. However, several members other than Ralph Underwager and Hollida Wakefield have argued that childhood sexual experiences with adults may be harmless. However, asociations between childhood sexual abuse and mental disorders in adulthood have been repeatedly proven (Briere & Elliott, 1993; Elliott & Briere, 1992; Herman, Russell, & Trocki, 1986/1994).

Sexually abused children have more symptoms than non-abused children. Fears, posttraumatic stress disorder, behaviour problems, sexualized behaviours, and poor self esteem occur most frequently among a long list of symptoms noted in 45 different studies but no one symptom characterized a majority of sexually abused children. Some symptoms were specific to certain ages, and about one third had no symptoms. (TACKETT)

Another FMSF Advisory Board member, James Randi, was involved in a scandal in which (according to court records):

"The scientist's lawyers sought to discredit Mr. Randi by playing taped conversations of teen-age boys who called the magician's home allegedly for sex."

[ Byrd v Randi (Civil Action No. MJG-89-636 in the United States District for the Court for the District of Maryland.] Transcripts of the tape are also part of the court record in Geller v Randi, (Civil Action No 91-1014-SSH in the United States District Court for the District of Columbia. The transcripts are contained in Exhibit 40 to Exhibit U].

Dr. Bill Thompson, Advisory Board Member of the British FMS, lecturer in Forensic Psychology at Reading University

" has been extensively quoted in the media as a sceptic about the

existence of satanic abuse. He is the author of SADOMASOCHISM, in which he puts forward the theory that sadomasochism is neither violent nor dangerous. Written about the Spanner case in which fifteen defendants were charged with "inflicting actual bodily harm" on each other, Thompson's book asks whether "hitting a penis with a ruler, dripping 'hot wax' on to a penis, strapping someone with a cat-o'nine tails, caning the buttocks" really are harmful activities. One of the accused was under 21....Thompson claims that "various moral groups have attempted to justify restricting the public's access to sexually orientated material by promoting a child pornography panic.".... He took exception to Lord Templeman's restating in the Spanner case that it was important to " provide safeguards against exploitation and corruption of others, particularly those who are especially vulnerable because they are young, weak in body or mind, inexperienced, or in a state of special physical, official or economic dependence."


There is considerable evidence supporting the recovery of traumatic memories. Contrary to the statements of the FMSF, there is empirical evidence regarding corroboration of formerly repressed memories, including that from other family members, medical or other physical evidence, and confessions of perpetrators. Ross Cheit, for example, has compiled a list of 50 cases of corroborated recovered memory. (See Ross Cheit.) In fact, research evidence shows that it is not unusual for victims of childhood sexual abuse to forget the abuse either entirely or for a period of time after the abuse.

Nor is it uncommon for genuine survivors of abuse to recant accusations.

Withdrawing stories of abuse is a normal part of the disclosure process and in 90 per cent of cases is followed at a later date by redisclosure. One study found that 27 per cent of children recanted, and 5 per cent recanted twice. The study says that lawyers, judges, parents and therapists must be helped to understand that recantation does not represent an end in itself and should not be equated with false allegation. Another study noted the propensity for abuse survivors to re-repress their memories after their retrieval. It is a mechanism which protects them from the full emotional impact of the loss of protection in their childhood. "If I don't remember it, then it didn't happen". Recantation also occurs if abused children or adults are faced with the family's denial and blame for the dissolution of the family. (GONZALEZ)

FMSF supporters often claim that it’s impossible to forget abuse. As proof, such studies as the numerous ones by Loftus are often quoted. These studies all pertain to non-traumatic memories. It is not at all clear whether the results of research on non-traumatic memories are in any way generalizable to the complex mechanisms involved in experiencing, dealing with, and remembering abuse or other traumatic experiences.

The FMSF also frequently attacks "repression", stating that either it does not exist, or that it does not result in the forgetting and later remembering of experiences of extreme trauma. However, there are other, well-studied mechanisms which are involved in the processing and storing of trauma experiences. For recovered memories to exist, belief in repression is not necessary.

For example, women with known histories of abuse have been studied to determine if they had ever had periods in which the abuse had been forgotten. The abstract of Linda M. Williams’ 1995 study, Recovered memories of abuse in women with documented child sexual victimization histories. (Journal of Traumatic Stress, 8,649 — 673, 1995) states:

The study provides evidence that some adults who claimed to have recovered memories of sexual abuse recall actual events that occurred in childhood. 129 women with documented histories of sexual victimization in childhood were interviewed and asked about abuse history. 17 years following the initial report of the abuse, 80 of the women recalled the victimization. One in 10 women (16 percent of those who recalled the abuse) reported that at some time in the past they had forgotten about the abuse. Those with a prior period of forgetting -- the women with "recovered memories" -- were younger at the time of abuse and were less likely to have received support from their mothers than the women who reported that they had always remembered their victimization. The women who had recovered memories and those who had always remembered had the same number of discrepancies when their account of the abuse were compared to the reports from the early 1970s.

None of the women in this study who had forgotten the abuse were in therapy at the time they began to remember again, and women's memories, when they returned, were consistent with the actual abuse.

Charles L. Whitfield, M.D. performed a review of 36 studies on over 6,000 children and adults who were abused as children. His results showed that between 16 and 78% of subjects in these studies experienced partial to total amnesia for their abuse for some substantial amount of time. Most of the subjects had been sexually abused as children. Eight of these studies involved only subjects with fully corroborated abuse histories, four had to a corroboration rate of 60 to 80 percent, and four had corroboration among half of the subjects. All groups were similar in occurrence of traumatic amnesia.

Elizabeth Loftus herself has published studies showing evidence of recovered memory. The 4 January 1996 issue of Accuracy About Abuse notes:

Elizabeth Loftus, high profile FMSF advocate, published a paper with colleagues on Remembering and Repressing in 1994. In a study of 105 women outpatients in a substance abuse clinic 54 % reported a history of childhood sexual abuse. 81% remembered all or part of the abuse. 19% reported they forgot the abuse for a period of time and later the memory returned. Women who remembered the abuse their whole lives reported a clearer memory, with a more detailed picture. Women who remembered the abuse their whole lives did not differ from others in terms of the violence of the abuse or whether the violence was incestuous. [Psychology of Women Quarterly, 18 (1994) 67 -84.]

Loftus has also discussed "motivated forgetting", and has presented the documented study of a college professor who became unable to remember a series of traumas, but after some time was able to recover those memories. Loftus remarked "after such an enormously stressful experience, many individuals wish to forget... And often their wish is granted." (Loftus, 1980/1988, p. 73) In 1976, Loftus wrote:

Memories that may cause us great unhappiness if they were brought to mind often appear to be forgotten. However are they really lost from memory or are they simply temporarily repressed as originally suggested by Freud (1922)? Repression is the phenomenon that prevents someone from remembering an event that can cause him pain and suffering. One way that we know that these memories are repressed and not completely lost is that the methods of free association and hypnosis and other special techniques used by psychotherapist can be used to bring repressed material to mind and can help a person remember things that he has failed to remember earlier. (Loftus and Loftus, 1976, p. 82).


It is clear that, while some memories of abuse may in fact be false, there is no evidence to prove the existence of a "false memory syndrome" epidemic. Recognition of this is important, as groups such as the FMSF, through publicity and lawsuits, have made some therapists unwilling to treat both adult and child victims of sexual abuse. Caution is necessary, but caution based on good practice rather than misinformation.

Appendix and Bibliography

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