It has been determined by many researchers in the scientific community that during hypnosis, false memories are very likely to be generated, and distinguishing them from real memories is difficult, if not impossible without some means of confirmation. This is, for instance, the conclusion of a
report for the U.S. Department of Justice by Martin T. Orne et al. titled “Hypnotically Refreshed Testimony: Enhanced Memory or Tampering with Evidence?” published January 1985 in Issues and Practices in Criminal Justice. With the above in mind, it is helpful for researchers attempting to evaluate a case when a distinction can be made between elements of the report derived from conscious recall and elements derived through the use of hypnosis. A case where this can be easily done is that of Judy Kendell of Zamora, California, thanks to a newspaper article announcing her intention to undergo hypnosis to recover around four hours of missing time, and another article in a different paper after the procedure, which was, apparently, well attended.
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