4) cite the example of Laura Pasley, who sued her therapist for incompetence, having recovered memories which Laura later retracted, believing them to be false. Unfortunately, is it not clear whether Laura had any corroborating evidence that the abuse did not occur, and so this cannot be regarded as evidence of false recall. In fact is it almost impossible to prove that abuse did not occur, with the retraction of earlier statements alone constituting insufficient evidence (Pezdek, 1994). Read and Lindsay (1994) conclude that even their critics now concede that false memories can be implanted by therapists, and maintain that the debate has shifted from the possibility of therapy-induced false beliefs to their prevalence. The specific attitudes and behavior of therapists has been cited by false memory proponents as a factor contributing to this (Farrants, 1998).Watkins (1995) states that certainly part of the controversy today is the fault of overeager therapists who have too suggestively championed the possibility of child abuse. Some have blamed poorly trained therapists for inadvertently implanting false memories of abuse in their clients, or therapists who practice without an understanding of psychological theories of normal memory. However, it is not only the inexperienced and incompetent who are accused of eliciting false memories during therapy. Scotford (1994), the director of the British False Memory Society (BFMS), claims that, while therapists `palm off blame' onto poorly trained hypnotherapists, in fact the BFMS also receives complaints about fully trained professionals such as psychiatrists and psychologists. Ceci and Loftus (1994) state that even eminent, experienced therapists use techniques likely to create false memories. Similarly, Rogers (1995) found a significant number of doctoral therapists to regularly apply methods involving leading suggestions which may have potential risk. An Andrews et al. (1995) survey of the ...