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that these memories cannot be trusted,
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that these memories are created through the actions of the therapist.
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And so, there's actually considerable psychological and legal battles
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over the veracity of the therapists
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where women who have claimed to have sexual be sexually abused,
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for instance, have pressed criminal charges against their fathers
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on the basis of false memories.
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Similarly, people who have been accused of sexual abuse
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have pressed criminal charges against psychiatrists
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claiming that these psychiatrists have implanted the memories
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into their sons and daughters.
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It is controversial whether memories are ever repressed.