David Calof was presented as a "Repressed Memories" expert in a PBS series "Divided Memories". He also trained hundreds of therapists in his techniques to recover memories and authored several popular popular articles on "repressed memories" (none were peer reviewed academic). It is noted his formal education was completed in high school and he never took any graded college courses and never obtained a college degree.
Mr. Caloff was not aware of what Fisher, t-tests or Bayesian Analysis were or how they could be used to evaluate his own practice. Those who have any training in the social sciences would be expected to know of analytical methods and how they would be used to evaluate counseling and therapeutic practices. Mr. Calof was uniformed in the basic methods of evaluation and was uninformed about how to evaluate the impact of his own practices.
When asked about the questions in his standard structured interviews used to followup and examine the impact of his practice (expected of professionals in the field) Mr. Calof indicated that the he had the questions "in his mind" bit did not recall exactly what they were. Anyone exposed to the questions and response would begin to question the professional qualifications of a person who claimed to be an expert in "repressed memories" and "satanic ritual abuse".
In the deposition below, while under oath and subject to charges of perjury, he indicated that he allows his clients to characterize "repressed memories" as historical BUT he does "not ever characterize them that way" and such memories "doesn't necessarily refer to veridical truth" which is an expression designed to obscure the meaning of both "truth" and "memory".
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King County Superior Court, State of Washington
Robin Avis, et al
Cause Number:
V. 97-2-02818-3 KNT
John Laughlin, et al
DEPOSITION UPON ORAL EXAMINATION OF DAVID CALOF
February 2, 1998
Appearances:
Deponent: A. Stephen Anderson
Plaintiffs: R. Christopher Barden, Michael Bolasina
Defendant CPC Fairfax Hospital: Christy A. Karjeker
Defendant Dr. Frerichs: Pamela Lang
Defendant Mr. Laughlin: Philip J. VanDerhoef
Defendant Dr. Rice: Vickie Williams
Defendant Lake Chelan Community Hospital: A. Clarke Johnson
Court Reporter: Annamarie C. Spangrud
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MR. VanDERHOEF: I consulted with Mr. Calof on this case and had him
look at some records. You can confirm this with him, but when I
first contacted him, he had no knowledge of the particulars of Robin
Avis's care and treatment. Therefore, anything he knows about the
particulars of this case, he knows because he's a consulting expert
for the defendants.
He's here today to testify on matters which may be relevant, given
testimony in prior depositions, and his role in, or his
participation in, a group that Mr. Laughlin and Dr. Rice attended,
but anything he knows about this case is something he knows only in
his role as a consulting expert.
We do not anticipate using him at the time of trial, and under the
civil rules and case law in Washington, his knowledge of facts of
this case and any opinions he formed about this case are immune from
discovery as attorney work product.
MR. ANDERSON: Well, I'd like to add something, if I may. I'm Steve
Anderson. I'm here as Mr. Calof's personal attorney, and there have
been an exchange of correspondence between us and one of your co-
counsel about his availability today, and I just wanted to advise
that we've cleared up the conflict that I had written your co-
counsel about, and he's available all day. We would ask that you
conclude this today, because he's not going to be available for
another day.
DR. BARDEN: Okay. For the record, we'll move along as quickly as we
possibly can, and we'll certainly stay within areas that am relevant
to the case. I would hope that we would finish this afternoon, but
sometimes we never know with these things. Okay. Are we ready to
swear the witness?
DAVID CALOF, having been first duly sworn by the Notary Public,
appeared and testified as follows:
BY DR. BARDEN:
Q. Good morning. My name is Dr. Christopher Barden, and I'm here
working with the Stafford, Frey, Cooper law firm in representing the
plaintiffs in this matter. Have you ever been deposed before?
A. Yes, I have.
Q. How many times?
A. Approximately three, to the best of my knowledge.
Q. Okay. Then you know that it's critical that your answers be
fully audible so the court reporter can write them down, and that
also it's important that you understand the question I'm asking. So
if there's anything confusing about any of the question that I ask
or anything like that, simply ask me to clarify, and I will
try to do so.
A. I'll be happy to do so.
Q. Have you ever testified as an expert witness before?
A. No, I have not. Well, actually, I was a witness of fact in an --
I'm actually not sure what my status was in a particular case. This
was about fifteen years ago, and I believe I was testifying as a
witness of fact in an automobile accident case where I had
interviewed the defendant in a civil suit.
Q. Okay. What have you done to prepare for the deposition this
morning?
A. I spoke with Mr. VanDerhoef, I spoke with my attorney, and I was
given, through my attorney, a brief segment of Dr. Rice's
deposition, I believe, in this case, three or four pages in which my
name was mentioned.
Q. There are a few things I'm not going to ask you about this
morning, one is any conversations you've had with your personal
lawyer, okay?
A. All right.
Q. Secondly, I'm not going to ask you for the names of any of your
patients, other than the patients' names that have already been
disclosed as part of the lawsuit.
A. I'm not aware of any names of my patients being disclosed as
part of this lawsuit.
Q. Then we won't be talking about any names of any patients all day
long.
A. All right.
Q. I'm also not going to ask you about any conversations with any of
your family members or anything like that, okay?
A. Very well.
Q. So, other than reading a segment of Dr. Rice's deposition, have
you read any other documents?
MR. VanDERHOEF: In preparation for this deposition?
DR. BARDEN: Yes.
A. No.
Q. [By Dr. Barden] Have you seen any of Mr. Laughlin's deposition?
A. No, I have not.
Q. Okay. Have you spoken to anyone else?
A. No, I have not.
Q. Have you seen a deposition of Dr. Van der Kolk that was taken
within the last year?
A. No, I have not.
Q Have you heard about it?
A. I believe he's given many depositions. I'm not clear what you're
referencing.
Q. Have you spoken to Dr. Van der Kolk in the last year?
A. No, I have not.
Q. Have you spoken to Dr. Bennett Braun in the last year?
A. No, I have not.
Q. And you're not on any kind of medications today that would
preclude you from testifying?
A. There is nothing in my -- there is nothing that would preclude
me from testifying.
Q. Okay, Now, have you ever served as a consultant to Mr. John
Laughlin?
A. I don't know that I would characterize it as consultant. Mr.
Laughlin was in a study group that I ran, and I'm not clear of the
dates at this point.
Q. Did you ever serve as a supervisor to Mr. Laughlin?
A. No, I did not.
Q. Did Mr. Laughlin ever pay you for supervision or consultation
services?
MR. VanDERHOEF: Compound.
A. Mr. Laughlin paid me for his membership in the study group which
I ran.
Q. [By Dr. Barden] What was the name of the study group?
A. I'm not sure that it actually had a name.
Q. Was it marketed as a study group?
A. I don't believe this group was actually marketed, believe that
individuals in it actually contacted me on their own initiative.
Q. Was Mr. Laughlin ever advised that this was a study group rather
than a consultant or supervision group?
A. I don't remember that per se.
Q. Do you have any documentary evidence that would indicate that
the members of the group had been informed that this was a study
group rather than a consultant or supervision group?
A. The very nature of the group precluded it from being a
supervision or consultation group.
Q. Okay. I think my question was: Do you have any documents that
would indicate that the members of the group had been instructed
that it was a study group rather than a consultant or a supervision
group?
A. The only document -- no, I do not have any documentation.
Q. And how much did you charge Mr. Laughlin for his work with you?
A. I don't --
Mr. VanDERHOFF. Object to form.
A. I'm not sure what you mean by "his work."
Q. [By Dr. Barden] Well, work or study with you.
A. I'm not sure. I think the rate was something like $35 a session,
but I'm not sure. I don't remember exactly. It's changed over the
years.
Q. And do you have any memory of what years Mr. Laughlin was in
your group?
A. I really don't per se. I really don't remember exactly.
Q. Do you know a Dr. Rice?
A. Dr. Donald Rice?
Q. Yes.
A. Yes, I do.
Q. And has Dr. Donald Rice ever been a consultant or a supervisee
of yours?
MS. WILLhkMS: Object to form: Compound.
A. Has Dr. -- would you please repeat that?
Q. [By Dr. Barden] Okay. Let's take them one at a time. Have you
ever consulted for Dr. Rice?
MS. WILLIAMS: Object to form: Ambiguous.
A. Have I ever consulted to one of his cases?
Q. [By Dr. Barden] Yes, have you ever served as a consultant to Dr.
Rice?
A. Dr. Rice was in a study group of mine.
Q. Was it the same study group Mr. Laughlin was in?
A. No, it was not.
Q. Do you know what years Dr. Rice was in your study group?
A. I don't remember exactly, but he hasn't been in a group
of mine for a number of years.
Q. Same as with Mr. Laughlin. Do you have any document indicating
that the group that Dr. Rice was in was a study group as opposed to
a consultant or a supervision group?
MS. WILLIAMS: Object to the form.
A. The only -- I do not have any documentation as to those groups.
Q. [By Dr. Barden] Do you have any idea why Dr. Rice might have
considered the group to be a consultant or supervision group?
MS. WILLIAMS: object to form; lacks foundation.
A. I don't know if Dr. Rice thought of it that way, and I have no
evidence of him discussing it in that way.
Q. [By Dr. Barden] In the study group - let's take the one with Mr.
Laughlin first -- what was your understanding of why in a study
group people in the group would pay you money?
A. I believe they paid me money because I had developed a set of
expertise and because I was reasonably familiar with the extant
literature. I believe that's why.
Q. You believe you were familiar with the literature in which
field?
A. At that time, I was reasonably familiar with the literature in
the field of traumatology.
MR. VanDERHOEF: Traurna what?
THE WITNESS: Traumatology.
MR. VanDERHOEF: Thank you.
Q. [By Dr. Barden] Who are the experts in the field of traumatology
that you were reading at that time that led you to believe you were
familiar with the literature?
A. Well, there were a number of them. I had done some work with
Milton Erickson in that regard. I was very familiar with his work. I
had read extensively Clark Hull. I had read, and I'm always
forgetting this name and how to pronounce it, I believe it's Cadiman
[phonetic]. I can check that. I had read Emelia Mira, M-i-r-a, who
was an Army psychiatrist who had written for W. W. Norton. I had
read Meninger -- Carl Meninger. Then by then I had read Charles
Figley, Bessel Van der Kolk. I'm sure there are many others that I'm
not remembering at this point.
Q. In your study group with Mr. Laughlin, did you ever discuss
satanic cult ritual abuse with him?
A. What exactly do you mean by "satanic cult ritual abuse"?
Q. Well, have you ever published things on satanic cult ritual
abuse?
A. I've never -- have I personally written and published, do you
mean?
Q. Have you published or have you edited a journal or a newspaper
or pamphlet or any other source of in information in which such
articles were published?
A. They may have been. I don't remember per se right now, but it's
very possible they were.
Q. You don't remember if in your journal, for example, Treating
Abuse Today, were there any articles published in there about
satanic cult abuse?
A. My recollection is that we mainly spoke to the issue of ritual
abuse, with perhaps the issue of satanic ritual abuse being a subset
of that. My understanding of satanic ritual abuse when I think of it
is that it more speaks to a representation on the part of a patient
than it does necessarily to any kind of veridical truth.
Q. Did you ever tell Mr. Laughlin that you, in fact, believed that
there were satanic cults practicing in the Pacific Northwest?
A. I believe that I didn't, although I may have relayed to Mr.
Laughlin information that had been relayed to me by various police
jurisdictions to that effect.
Q. And who were the people who relayed that to you?
A. The one that I remember most at the moment was a representative
of the Washington State Patrol. I don't remember his rank at the
moment. I believe his name was John Farrow, F-a-r-r-o-w.
Q. Any other sources of information for you on the existence of
satanic cults practicing in the Pacific Northwest?
A. Well, let me be careful that I'm not implying that I have a
belief one way or another when I answer this question. What I'm
saying is that there was anecdotal information sent my way that I
may have passed on to the group. In that light, there was this
information from the Washington State Patrol. I've also participated
as a technical expert for various police jurisdictions where I've
interrogated witnesses who were not going to testify as to fact in
these cases, whose only function in the cases was to, in essence,
point the police in the direction of evidence, and, in some of those
cases, there was evidence revealed that eventually led to an arrest
and, I believe, subsequent conviction.
Q. What was the name of the case?
A. I'm not at liberty to say that for several reasons. In these
particular instances, my testimony -- I'm sorry, I spoke wrong --
my participation in these cases was pro bono, and I operated under
an assumed name because of potential danger to myself and my
family, so my name was never introduced into these cases. It was
never a matter of fact. The people that I worked with were never
witnesses in these matters, and so I'm really not at when I was
involved in some of those cases I mentioned earlier.
Q. Did you have your office swept for bugs?
A. The Washington State Patrol swept my office for bugs.
Q. And who was the member of the Washington State Patrol who swept
your office for bugs?
A. I don't believe I remember his name.
Q. Do you have any idea at all?
A. I'm not even sure I heard his name. I may have heard it once,
but I don't recall.
Q. Do you know which office he worked out of?
A. I don't recall that either.
Q. Can you describe what he looked at?
A. What he looked at?
Q. What he looked like.
A. I believe he was a heavy-set gentleman, rather tall. That's
all I remember.
Q. And have you ever stated that you carried a gun because of your
fear of the cults?
A. I wouldn't characterize it that way. There was a point where I
had actually confiscated a gun from a patient and had it in my
trunk, and within a very short period of time, I disposed of it.
MR. VanDERHOFF- I missed the last few words.
THE WITNESS: Within a very short period of time, I disposed of it.
MR. VanDERHOEF: Thank you.
Q. [By Dr. Barden] Have you ever given a different explanation for
why you carried a gun in your speeches, Mr. Calof?
A. I can remember that -- I'm not sure about that, actually, but it
is possible that I might have -- actually, I think the gun was in
some way frightening me, and I may have spoken to that. I really
don't recall.
Q. Have you ever stated in any of your speeches that you had your
office swept for bugs, rather than the Highway Patrol doing it?
A. I don't believe so. I'm incapable of doing that.
Q. Have you ever described yourself as having gone through a period
of hysteria when you began to believe in the cults?
A. It doesn't sound like something I would have said.
Q. Well, have you ever said anything like, quote, You know that I
wasn't exactly prone to hysteria about this, but that was before I
began to believe in it, and then I did go through a period of
hysteria with respect to this, end quote?
A. It's possible that I said that, but I'm not recognizing the
context.
Q. Now, when would you have gone through a period of hysteria when
you started to believe in the cults?
A. I'm not sure that I testified I did.
Q. Okay. Well, what years were you most interested in the, problem
of the so-called cults?
MR. VanDERHOEF: Object to form.
A. Yeah, I'm not sure that I was interested in the problem of the
cults as much as I was interested in the people who wanted to
consult me about patients who were representing these stories.
Q. [By Dr. Barden] Have you ever told professionals in any meetings
you spoke at that you and other people were discovering how the
cults created a ritual abuse multiple?
A. Not to my recollection.
Q. Have you ever instructed groups where you taught them look at
the kind of programming that you were discover that went into
creating a ritual abuse multiple?
A. Could you restate that, please?
Q. Did you ever tell professional groups in any of your speeches
that you wanted to look at the kind of programming that you were
discovering that went into creating a ritual abuse multiple?
A. I'm not sure I know what a "ritual abuse multiple" is.
Q. Have you ever used that phrase in your own speeches - that term?
A. If I did, I was misspoken. I'm not sure what that means.
Q. What's your understanding of the term "reactive multiple"?
A. My understanding of that term is that the splitting and
dissociation that occurs is naturalistically in response to some
sort of stressor or demand characteristic.
Q. And what's your understanding of the term "structured
multiple"?
A. That's not my term but as that term has been used by others in
the field, it generally means that there was more of a deliberate
attempt to create dissociation and splitting through the induction
of stress or demand characteristics.
Q. Okay. Have you ever in any of your speeches made the following
statement, quote, What we do know about ritual abuse contacts is
that they do know about splitting and they know about dissociation
and they know about MPD. In the orthodoxy of satanic cult abuse,
there's a different belief system about MPD that has to do more with
a demonological explanation than it does with a psychological
explanation. But they darned well know about splitting and MPD, and
their intent is to produce splits and what they have called
implants, which are basically alters that have been created with special functions for the cult. These alters may have functions in terms of criminal activity, they may have functions in terms of amnesia for the patient, certain kinds of self-destruction programs should they reveal or disclose, and that's what we mean by a structured multiple, end quote?
Q. Did you ever say that in any of your speeches, Mr. Calof?
A. I don't know per se, but it's possible that I might have said
that.
Q. How would you have known that, quote, their intent -meaning the
satanic cult abusers -- their intent was to produce splits? How
would you have known that?
A. This came to me -- if, in fact, I did say that -- this came to me
-- this notion would have come to me through my work with the police
department where I saw it demonstrated and testified to -- not
testified to, but spoken to by some of the people I worked with and
by anecdotal report primarily.
Q. Were you ever the editor of a journal called Treating Abuse
Today?
A. Yes, I was.
Q. Did you ever have an entire volume -- I'm sorry -- an entire
issue, I guess you would call it, devoted to ritual abuse?
A. We had an entire issue devoted to reports of ritual
abuse, to clinical representations of ritual abuse.
Q. Was there a picture of a devil with horns on his head on the
cover of that?
A. I notice that you're holding that. I'd be happy to look at it. I
actually don't remember. [Dr. Barden shows the witness a document.]
A. It looks that way to me.
Q. [By Dr. Barden] And you were the head editor for the journal at
that time?
A. That is correct.
Q. I'm sorry, what do you call this? Do you call it a journal or a
newsletter?
A. We've actually called it several different things. I think
probably the most accurate description is a journal.
Q. Okay. I note on the cover of this one it says that it's a news
journal, so should we just use that term?
A. That would be fine. I mean, I think different issues had
different terms on it. So that one says news journal. I'm happy to
use that.
Q. Have you ever served as an editor for any journal published by
the American Psychological Association?
A. No, I have not.
Q. Have you ever been on the editorial board of any journal
published by the American Psychological Association?
A. No, I have not.
Q. Have you ever been an editor for any journal published b the
American Medical Association?
A. No, I have not.
Q. Have you ever been on the editorial board for any journal
published by the American Medical Association?
A. I think you just asked me that, and, no, the answer is no.
Q. I'm sorry, I just want to make clear, did you ever serve as an
editor or as a member of the editorial board of the journal
published by the American Medical Association?
A. The answer is no to both questions.
Q. Have you ever served as an editor or a member of the editorial
board of any journal published by the American Psychiatric
Association?
A. No to both questions.
Q. Have you ever served as a faculty member at any college,
university, or medical school?
A. I've served as an adjunct faculty member and have -there's been
credit granted for numerous courses that I've presented at medical
schools and universities.
Q. Where have you served as an adjunct medical faculty member?
A. Let me be clear that we're using the same term here. I'm
not suggesting that I had a faculty appointment. What I'm suggesting
is that I was employed by various institutions to provide courses
for which credit was given.
Q. Were you listed on their roster as an adjunct professor of
medicine?
A. No, I was not. Not to my knowledge, at least.
Q. Okay. Where have you taught at a medical school where the
students got credit for your class?
A. Well, there's been several. I can mention the ones that come to
mind at first -- University of Connecticut, St. Joseph's -- is it
St. Joseph's? I believe it is -University and Medical Center in
London, England. There are several others that aren't coming to mind
right now. I would certainly be happy to mention them should they.
Q. Okay. Who was your supervisor or contact person at the University
of Connecticut?
A. Stuart Silverman, I believe is his name -- Sugarman. I beg your
pardon.
Q. And how much credit did the students receive for your class?
A. I'm not sure I ever knew that.
Q. Have you ever seen any documentation that they, in fact, received
any credit for your class?
A. I know that I had to -- I had to complete paperwork in
order that that be done.
Q. And who was the contact person -- I'm sorry, that was at St.
Joseph's?
A. I believe that's the name of it. That was -- I'm not remembering
his name right now.
Q. Male, female?
A. Male.
Q. Older person, younger person?
A. In his 40s. He wrote the book Transgenerational Family Therapy --
Stuart Lieberman, L-i-e-b-e-r-m-a-n.
Q. What's the highest level of formal education that you have, Mr.
Calof? And by that, I mean in terms of a diploma.
A. High school.
Q. Where did you go to high school?
A. Sammamish High School in Bellevue, Washington.
Q. And did you learn anything about repressed memory or
disassociated memory in your high school training?
A. I was doing some reading in psychoanalysis at the time, but it
wasn't actually part of my curriculum.
Q. Did you learn anything about satanic cult abuse in your high
school training?
A. I did not.
Q. Do you feel that you're qualified to give training speeches to
licensed psychiatrists and psychologists in the field of
psychotherapy?
A. I believe that I am.
Q. Have you ever told anyone that you did, in fact, personally
believe that there were satanic cults mistreating children in the
Pacific Northwest?
A. If I did, it was, again, relating information that had been given
to me by those police jurisdictions or anecdotal reports for which I
believe corroboration had been obtained.
Q. How many patients have you yourself treated who reported being
satanically ritually abused in their childhood? Again, I'm not
interested in any names of patients.
A. I appreciate that. When you say "reported," do you mean reported
as if they were true, it was a memory, and I agreed with them that
it was a memory?
Q. No, I mean reported to you that that had happened to them.
A. I have had patients who, on occasion, have reported images of
that kind of thing, but they didn't necessarily attribute that they
were memories. There were, I believe, only two patients who reported
to me that they had memories of being abused in multiperpetrator
groups that seemed to have some kind of satanic trappings, although
that wasn't the primary interest in those issues.
Q. Have you ever written an article explaining how the cult uses
things like sending postcards to patients in order to retrigger
them?
A. I have not written anything about that as a practice.
Q. Have you ever written an article in which you interpreted a
postcard sent by a cult member to a survivor patient?
A. I gave a talk once that has been -- where they have -where there
have been pirated versions of that talk transcribed against my
copyright in which apparently that was an issue, but the particular
speech that I gave regarded a patient that wasn't actually even
mine, so the interpretation wasn't mine.
Q. Did you say in that speech that that's one of the ways that the
cults do retrigger or maintain control over their victim?
A. I believe my intent there was not at all about whether the cult
was -- what kind of practices cults do, but it was more speaking to
the possibility that people who have been abused can have contact
with perpetrators that they don't report, and I think it also spoke
to how people who have been abused internalize injunctions that then
can govern their behavior and mentation. In that particular example,
there was no attempt to generalize this to a practice on the part of
any other case except that one, and, as I say, that one was not even
the interpretation that I made.
Q. Did you, in fact, in your speech about this card indicate that
patients could be triggered to commit suicide by receiving postcards
from supposed satanic cult members?
A. You're using the plural there when you say "patients" and, as I
say, the only issue in that particular case was the behavior of that
particular patient. I know that there has been pirated
transcriptions of that talk made. You may actually be referring to
one of those, and I highly doubt their accuracy.
Q. Have you ever made any audiotape presentations in which you
discussed ways in which satanic cults retrigger or regain control
over their victims?
A. The talk that I've just mention, that I'm referencing, which was
at the Meninger Clinic, was audiotaped, to my knowledge. I'm not
sure that audiotape was actually given to the public. But I've never
gone out and recorded an audiotape with the intent of making that
teaching, because, again, don't hold the belief that that is
necessarily a widespread practice or a standard practice, for that
matter.
Q. And by standard practice, you mean standard practice of the
satanic cults?
A. Of any perpetrator.
Q. Why did you think in that case that the cult had tried to
get this patient to commit suicide by sending her a postcard?
A. I think you're mischaracterizing my testimony.
Q. What did you say in that tape, Mr. Calof, about that?
A. I don't remember my exact words, but as I explained to you, this
seemed to be a case where an individual -- and again, not my case,
but one which had been reported to me -- where an individual seemed
to internalize perceived injunctions from her family and other
people as to her worth, as to her value as a human being, such that
when she was acting on these internalized injunctions, she was quite
self-destructive.
Whether or not there was criminal intent or whether or not she was -
- I really couldn't speak to the intent of the people who allegedly
sent the postcard because I was not a witness to it, and, as I say,
I was only second party in this case, but I was speaking to the way
that people internalize injunctions. I have no evidence that she, in
fact, even received a postcard other than, again, what was told to
me by the treating therapist.
Q. All right. I'm going to ask this again so I just want to make it
really clear.
A. Sure.
Q. Have you ever in your audiotaped presentations indicate to
therapists that, as part of their programming practices, satanic
cults will attempt to regain control over patients using means such
as sending a postcard?
A. As I testified, there was a particular case where apparently the
patient represented that a postcard had been sent to her, and she
attributed to that postcard that it was an attempt to control her.
If I did ever speak to the issue of perpetrating -- allegedly
perpetrating groups attempting to control alleged victims, it would
have come from evidence gained in my contacts with the police.
Q. Have you ever tried to explain why there have not been any bodies
found of the infants who are supposedly sacrificed by satanic cults,
Mr. Calof?
A. Not in any kind of professional or thoughtful manner. I once
quipped something about that in an angry way to a reporter from a
television station, and I believe that was unfortunate as it's been
taken out of context, but I've never actually attempted to answer
that question in any learned fashion.
Q. Are you aware of any similarity between your answer to that
question and Dr. Braun's answer to that question?
A. I don't know that Dr. Braun has answered that question.
Q. Are you aware of any similarity between your answer to that
question and Dr. Ross's answer to that question?
A. Well, I don't know what Dr. Ross has said about that, if in fact
he said anything.
Q. What's your definition of a "hypnotic as if identity"?
A. I'm not sure I understand the term.
Q. Well, have you ever used that term in any of your writings or
speeches yourself?
A. I may have, but not consistently, and right now the meaning of
that escapes me. If you could provide me a context, I might be able
to answer your question easier.
Q. Have you ever talked or written about your theory as to how
mistreatment of children is transmitted across generations by
hypnotic means?
A. I don't know that that was -- well, yeah, I think you're taking
something out of context. First of all, those kinds of comments did
not regard abuse of children per se, they regarded family patterns.
Abuse certainly can be a pattern of that, and the use of hypnosis
there is more a metaphor in the sense that it spoke to the child's
uncritical acceptance of the parents' suggestions.
Q. Have you ever written or said that, quote, both parent and child
float between hypnotic as if identities with a dream logic that then
inducts succeeding generations, end quote?
A. I don't remember those words per se, but that sounds like
something I might have said or written.
Q. Have you ever published anything, Mr. Calof, in a peer-reviewed
journal published by the American Psychological Association?
A. At this point, no. I have had peer-reviewed chapters in books
published, but not in a peer-reviewed APA publication.
Q. What's your understand of the difference between peer reviewing
in APA journals and peer reviewing in books, Mr. CaIof?
A. Well, that depends on the book. The particular books that I was -
- that I did have chapters in had a similar peer review process to
the APA in that it was a blind review process. Generally speaking,
my understanding in books is that there is not a peer review
process, nor is it blind.
Q. And how many articles have you published in your career? I'm not
interested in an exact number.
A. In any source, you mean?
Q. Yes.
A. Forty or more. I'm not -- please don't hold me to that. That's an
approximation. It may be more, it may be less.
Q. Is there a reason or a strategy as to why none of these have been
published in peer-reviewed journals published by the American
Psychological Association?
A. I've never submitted any.
Q. Have you ever published a single -
A. Well, actually, that's not true. I have one on 2 submission now.
Q. And where is that?
A. To the Journal of Ethics and Behavior.
Q. And who is the editor of the Journal of Ethics and Behavior?
A. I believe the current editor is Dr. Gerald Koocher, K-o-o-c-h-e-
r.
Q. Have you ever done any presentations with Dr. Koocher?
A. Dr. Koocher moderated a panel that I was a part of at the annual
American Psychological Association meeting last August in Chicago.
Q. What did you talk about there?
A. I'm not sure that that's germane to this case. Perhaps if you can
help me understand that, it would be easier for me to answer.
Q. Did you present any of your discussions on the theory of
repression or false memories, for example?
A. No, I did not.
Q. Well, what did you talk about? And then I guess we'll be able to
find out if it's relevant.
A. Well, I spoke to matters that do not regard this case. I spoke to
a campaign of harassment that had been directed toward me, my staff,
and family. There was nothing theoretical in my discussion.
Mr. Barden, with your permission, may I just get a bit of tea?
Q. I just want to make it clear that if you need a break at any
time, that's fine.
A. Oh, no, I'd be happy to continue. I'll just get some water over
here, but I can still hear your question.
Thank you, Mr. Barden. I'm ready.
Q. Have you ever published a single article in any peer-reviewed
journal published by the American Medical Association?
A. We can probably make this a lot easier. I don't believe that I've
submitted any articles other than the one that I've already
mentioned to a peer-reviewed journal.
Q. Is there a reason for that?
A. Not particularly -- busy.
Q. All right. You mentioned you'd worked with Milton Erickson.
When did you do that?
A. Approximately during the years 1976 or '75 -- 1975 or 1976
through 1980.
Q. And where did you work with Dr. Erickson?
A. Largely in Phoenix, Arizona, although we also had a fairly robust
correspondence and, on occasion, phone contact.
Q. And were you being personally trained by Dr. Erickson?
A. For part of that.
Q. For -
A. For part of my work with him.
Q. And that was in Phoenix?
A. Again, it would be in all the venues that I described.
Q. Well, how many face-to-face meetings did you have with Mr.
Erickson and where did they take place?
A. Oh, I had at least -- this is an estimate at this point -- but at
least one week per quarter for a period of about four or five years
I went to Phoenix and studied with him.
Q. So that would be a total of about twelve weeks?
A. Oh, let's see, no, probably more than that. Perhaps closer to
twenty weeks, because some of the visits were actually longer than a
week.
Q. And did you pay Dr. Erickson for these weeks?
A. Sometimes yes, sometimes no.
Q. Do you have any documentary evidence that you received any credit
for these meetings?
A. By credit, do you mean university or college credit?
Q. Yes.
A. No, I did not.
Q. Do you have any letters from Dr. Erickson indicating that these
meetings, in fact, took place?
A. I don't know that I still have those.
Q. Do you have any eyewitnesses who could testify that these
meetings actually took place?
A. There were -- oh, sure. There were a number of people that would
occasionally come to these meetings.
Q. Who?
A. I remember being there at least once with an individual named
Mike Flowers.
Q. And who is Mike Flowers?
A. He's a therapist here in Seattle.
Q. And how many hours did Mr. Mike Flowers observe you with Dr.
Erickson?
A. I can't remember if he was there for one or two, but certainly
one full week.
Q. Who else?
A. I should add that a fair number of these hours were actually
spent with just Dr. Erickson and myself in the room.
Q. Would there be any documentary evidence that those meetings ever
took place?
A. I do have available books in which he signed them to me with a
personalized inscription that took place during those meetings.
Q. Did he ever write in any of those books how many hours he worked
with you?
A. He did not. He wrote that he was proud to have had me as a
coworker.
Q. Who else, other than Mike Flowers, ever saw you being trained by
Milton Erickson?
A. There were a variety of people there. They may actually have at
the Erickson Foundation a list of those names. I'm sure if I thought
further, I could think of some others, but at the moment I'm not.
Q. In your work with Dr. Erickson, did he ever train you in how to
treat people suffering from ritual abuse?
A. The subject never came up.
Q. How about satanic cult abuse?
A. I don't believe the subject ever came up.
Q. How about multiple personality disorder?
A. Yes, we had extensive conversations about that.
Q. What was Dr. Erickson's theory about how you treat multiple
personality disorder?
A. Well, that certainly depends on the presentation, the previous
health of the person, the natural course of the illness. It's an
awfully difficult question to answer in abstraction.
Q. Do you have any idea at all what Dr. Erickson's views were on the
treatment of multiple personality disorder?
MR. VanDERHOEF: Object to form; argumentative.
A. Well, yes, I do. He spoke about a number of cases, but it was
very hard -- it's very hard to generalize his approach from one case
to the other because Dr. Erickson's approach was, to some extent, a
theoretical and depended upon the unique circumstances of each
patient.
Q. To the best of your knowledge, did Dr. Erickson ever have his
office swept for bugs?
A. To the best of my -- I have no idea.
Q. To the best of your knowledge, did Dr. Erickson ever, in his
writings or audiotaped presentations, ever discuss ways in which
satanic cults can retrigger their victims?
A. Not to my knowledge.
Q. How many multiple personality disorder patients have you treated?
A. Forty plus approximately -- certainly less than fifty, probably
low forties.
Q. And how many are you currently treating suffering from DID or
MPD?
A. I'm currently treating none that correspond to that diagnostic
criteria.
Q. When was the last time you treated a patient suffering from MPD
or DID?
A. I believe the last one that I worked with that successfully
integrated and moved beyond that diagnostic category was, I'm
guessing, about three or four years ago.
Q. That would have been, what, '95?
A. Well, probably earlier than that.
Q. '94?
A. Probably. It occurs to me that I need to revise my answer.
I do have a support group for individuals who were previously
diagnosed as having DID. I did not make the diagnosis, and I don't
treat them for that per se. It's not a therapeutic group, it is a
support group. But other than that, I stand by my answer. I am not
their primary therapist.
Q. When did you treat your first multiple personality disorder
patient?
A. 1976 or '77. 1 can't remember, '76 or '77.
Q. And did you feel you were qualified to treat an MPD patient in
'76 or '77?
A. Certainly not as qualified as I am today.
Q. Did you seek consultation or supervision for that first patient?
A. I did.
Q. Who did you seek that with?
A. Dr. Erickson -- Dr. Erickson and also a local psychologist.
Q. And who was that?
A. Doug Anderson.
Q. Okay. You had mentioned that your highest level of formal
education was a high school diploma. Have you had any college
courses in psychology or psychiatry?
A. I've had a number of courses that were accredited with college
credit in those topics.
Q. And where did you take those?
A. A variety of places. I was for a while a matriculated student in
the master's degree program at Antioch University; I was for a time
a matriculated student in the master's program at a college known as
Promethius College, which has since gone out of business. So those
are certainly two of the places.
I took the elective in hypnosis at the medical school at the
University of Washington, There's a number of other ones, but I'm
not remembering them at the moment.
Q. Do you have a transcript of your grades at Antioch University?
A. I'm not sure grades were given. I believe it's a kind of
portfolio situation. My evaluation was very high.
Q. Do you have any -- well, why didn't you finish the master's
program at Antioch?
A. It was actually interfering with my practice. My practice was so
full that it was difficult to both go to school and do my practice,
and I found some of what they wanted me to study -- the research
methodology was not germane to my particular practice, so I found it
less than relevant. And it was very costly, and I had concerns
whether obtaining that degree would actually qualify me in any
additional way, so I decided not to go on.
Q. At that time that you were in the master's program at Antioch
University, was that an APA-approved program?
A. My impression is yes, but I don't know for sure.
Q. Have you ever applied to any Ph.D. programs in psychology?
A. No, I have not.
Q. Now, you mentioned you were in the master's program at Promethius
College?
A. Yes. That was in Tacoma, Washington.
Q. From what year to what year?
A. Oh, I believe it was during the year of 1976, to the best of my
knowledge.
Q. So you were there for one year?
A. Yeah.
Q. And how many credits did you get there?
A. I'm not really sure. I'm not really sure. It would be a low
number, though, probably less than ten.
Q. Do you have a transcript of your grades from Promethius College?
A. I do not.
Q. When did the college go bankrupt or go out of business, or
whatever?
A. It was several years after that. I'm not sure exactly when.
Q. Now, you mentioned you took an elective in hypnosis at the
medical school?
A. Yes, I did.
Q. Who was your instructor for that?
A. Herbert Ripley and Thomas Wahl.
Q. Herbert -- pardon?
A. Ripley, R-i-p-l-e-y.
Q. And Thomas Wahl?
A. Yeah. Dr. Ripley was an M.D. and Dr. Wahl was a Ph.D.
Q. Did you pay for that class?
A. Oh, yes.
Q. And did you receive any credit for that class?
A. Yes, I did.
Q. What kinds of credits could you receive not being a student in
the medical school?
A. I'm not sure how that works exactly, to be frank with you, but I
believe I got an A for the course, and I think it was a five-credit
course, although I really don't remember.
Q. And what year was that that you took that hypnosis class?
A. That would be approximately -- it would be the late '70s,
but I'm not exactly sure of the year.
Q. Have you had any formal training in hypnosis or anything else
having to do with psychology since this class in the -- since your -
- well, let's back up.
When were you in the master's program at Antioch?
A. I believe that was 1983 to '84, that academic year.
Q. Okay. Have you had any formal education since 1984?
A. I've had considerable training.
Q. Well, I'm not interested in continuing professional education,
I'm interested in matriculated student classes.
A. I've not been matriculated except in those instances.
Q. Have you received any university, college, or medical school
credit for any classes since 1984?
A. Not as a matriculated student.
Q. Have you received any credit from any college, university, or
medical school since 1984 as a nonstudent?
A. I believe so. I'm not sure exactly how that works, but I know
that in a couple of instances I paid for continuing education
credit, and I'm not exactly sure how that
works, to be frank.
Q. And where was that? Which university?
A. I don't remember at the moment.
Q. Do you have any idea? I mean, was it in the Northwest, was it in
--
A. No, it would not have been in the Northwest, most likely the
Northeast.
Q. Are you licensed as a health care provider in the state of
Washington?
A. I'm registered as a mental health counselor.
Q. What are the requirements to be registered as a mental health
counselor in the state of Washington?
A. It's been a while since I've looked at them. You know, frankly,
I'm not sure what those requirements are at this moment. I know some
of them, but I don't think I know the full requirements.
Q. Do you see patients in psychotherapy?
A. I see clients.
Q. What are the requirements in the state of Washington for informed
consent for psychotherapy by a registered mental health counselor,
to the best of your knowledge?
A. They include disclosure of fee structure, policies with respect
to -- I think one has to disclose one's educational background,
one's theoretical orientation. I
know that it's evolved as a standard of practice that you would
disclose things re fee arrangements, how absences will be covered,
crisis management, and other areas. I'm not sure which of those are
required by the statute and which have evolved by virtue of
standards of practice, however. That's a fairly complete list.
Q. Is there anything else?
A. There may be. I'm not recalling it at the moment.
Q. Are you a member of the American Psychological Association?
A. No, I'm not.
Q. Why not?
A. I've never applied.
Q. Okay. Are you familiar with the ethics code of the American
Medical - I'm sorry, the American Psychological Association?
A. Reasonably familiar.
Q. What's the ethics code of the APA requirements with regard to
informed consent for psychotherapy, do you know?
A. I believe it is pretty much the areas that I've already
described. I'm not sure there would be major disagreement.
Q. What professional journals, if any, do you read to stay current
in your field?
A. I have off and on read several of them regularly. At this point
in time, I don't read any regularly, but I can give you a list of
the ones that I'm most interested in.
Q. Okay. Let's go through the time period in your career up through
1995. Which journals were you reading to stay current in your field?
This would, of course, cover the time you were in study groups or
whatever you were doing with Dr. Rice and Mr. Laughlin.
A. I was in study groups with them. What is the question again?
Q. Which journals were you reading to stay current in your field?
MS. WILLLIAMS: I object to the form. Is that from the beginning of
his career through those times?
DR. BARDEN: Right - yes.
A. Oh, lord, it's a long list. I'll just start with - I would read
JAMA on occasion -- Journal of the American Medical Association --
Counseling Psychologist, the National Psychologist, the Family
Process, the Journal of the American Association of Marriage and
Family Therapy, the Journal of the American Society for Clinical
Hypnosis, the Journal of the International Society for Clinical and
Experimental Hypnosis, the Journal of Psychotherapy, the Journal of
the Society - I believe this is the name of it, the Journal of the
Society for International -- no, it's the journal published by the
International Society for Traumatic Stress studies, the
Journal of Dissociation, the Journal of Counseling and Development,
the -- I can't remember the name of this one, but it's the journal
put out by the American Association of Mental Health Counselors,
Psychology Today, but I don't consider it very informed. There's
others, but they're not actually coming to mind at the moment. I can
think longer if you'd like me to.
Q. Okay. Do you recall reading anything in the Journal of the
American Medical Association with regard to the creation of pseudo
memories using hypnosis?
A. I believe there was a warning statement, if I'm not mistaken,
that advised that operators should be careful to -- in their use of
hypnosis not to create pseudo memories.
Q. And when was that published, do you know?
A. You know, I actually think there's been two statements b3 them.
If I'm not mistaken, one came out in 1985, but I must tell you I
don't recall the substance of it.
Q. In your study group work, as you have characterized it, with Mr.
Laughlin and Dr. Rice, did you ever discuss the use of hypnosis?
A. I believe that we did. I don't have specific recollection of
that, but it is certainly consistent with my practice that we would
have.
Q. As part of the study group, did you inform the people in the
study group about the 1985 warning in the Journal of the American
Medical Association?
MS. WILLLIAMS: I'm going to object to form. I'm hearing one group,
and I believe his testimony was that they were in different groups.
DR. BARDEN: Yes, okay, groups.
Q. [By Dr. Barden] Did you inform the people in those groups about
the 1985 warning in JAMA?
A. It's very possible that I did, but I know as well that I would
have informed them about the substance of the concerns, if not the
specific citation or attribution.
Q. What were the recommendations that were published in JAMA in 1985
with regard to the use of hypnosis, if you know?
A. It's been a long time since I read that article. I hesitate to
answer because I don't remember specifically.
Q. Do you have any idea?
A. I really don't, and I'm sure -- I'm sort of relating that, I
think, with their later statement as well.
Q. Well, to the best of your knowledge, has there ever been a
statement reversing or rescinding the recommendations made in 1985
in JAMA?
A. There has been scientific evidence that seems, to some extent, to
diminish the importance of that statement, but, no, there's not been
a statement to rescind it.
Q. Now, based on that, if those recommendations are still in force,
to the best of your knowledge, do you know of any of those
recommendations?
A. I'm sure that there's great agreement with the way that I
practice and teach in those recommendations, but I hesitate to
specifically cite what they are because I don't remember
specifically.
Q. Can you name any of them even generally?
A. My guess is that they probably spoke to the caution in terms of
using hypnosis for memory retrieval and the potential in that kind
of practice for the induction of pseudo memory -- not the induction
of pseudo memory, but the co-creation of pseudo memory.
Q. Anything else?
A. Not to my recollection.
Q. Any specific safeguards therapists were told to take in that 1985
warning?
A. I don't know about that, but I know there are several safeguards
that have generally been in the literature that even predate that
with respect to the use of hypnosis, and I'm sure they were probably
in agreement with that statement.
Q. And what are those safeguards?
A. They regard that operators should be careful not to suggest or
lead the clients in terms of specific content. They regard the --
basically, hypnotically derived memories are no more or less
reliable, according to the scientific literature, than any kind of
memory, and I believe they caution that operators should not regard
these memories as any more true or less true than others.
Q. Any specific recommendations or safeguards?
A. Well, I can remember safeguards and recommendations from various
sources, and I would be happy to speak to those. I will not
represent that I know specifically they're in the 1985 statement.
Q. Okay. What are the general ones that you could speak to?
A. There's two sets of recommendations in the use of hypnosis. Some
of those regard the use of hypnosis in therapeutic contexts and the
others regard the use of hypnosis in forensic contexts. I'm assuming
that we're talking about the use of hypnosis in the
psychotherapeutic context since this is a psychotherapeutic case
that I'm testifying in.
Q. Is it your understanding that the 1985 warning from JAMA did not
apply to the psychotherapy context?
A. I'm suggesting that it did apply to psychotherapy context, but
not to forensic context.
Q. Okay. What is your understanding of the safeguards and how
they're different for those particular context?
A. In a forensic hypnotic interrogation or interview, there's a
whole different code of ethics and a completely different object.
There the operator must take great care not to be leading or
suggestive, since what is being developed is, in fact, a record that
potentially will be used before a trier of fact.
In psychotherapy, where the emphasis is on the narrative truth as
opposed to the veridical truth, there is a lot more leeway for the
psychotherapist to make leading suggestions.
In the forensic context, there's a number of documentation
requirements; for example, the videotaping of interviews. There's
also an informed consent process that one goes through. This is not,
however, the requirement in the psychotherapeutic use of hypnosis.
Q. What is your citation, if you have one, for your opinion that
these things are not required in the psychotherapeutic use of
hypnosis?
A. Are we speaking about the years in question for this case?
Q. Yes. We're talking about psychotherapy cases in which patients
are reporting murders, for example.
A. Well, now, you've asked me two different questions.
Q. Yes. I'm interested in your opinion as to whether you would use
the psychotherapy safeguards or the forensic safeguards if you were
in therapy with a patient who is reporting murders?
A. If a client were being treated by me and in the process of being
treated by me reported that they had committed a murder?
Q. Either that they had comitted it or that they had witnessed it.
A. All right, that's the context. Now, what is the question?
Q. Would you thus use the forensic safeguards that you've just been
describing or the therapy safeguards for the use of hypnosis?
A. If my relationship to that client was a psychotherapeutic one, I
would use the psychotherapeutic safeguards.
MR. ANDERSON: I'd like to take a break for a few minutes.
DR. BARDEN: Sure.
[A short recess was taken.]
DR. BARDEN: We're back on the record.
Q. [By Dr. Barden] We were talking, Mr. Calof, about safeguards
recommended by JAMA and whether they applied to therapy or forensic
settings.
I guess my question is: Is it your understanding that the 1985 JAMA
warning applied to therapy settings, forensic settings, or both?
A. My understanding is that it applied to psychotherapy settings.
Q. Now, you also mentioned that recent scientific research weakened
the need for these safeguards. Could you explain your answer?
A. What I mean by that is that scientific evidence seems to indicate
that hypnosis is no more likely to create pseudo memories or
distortions of memories than any kind of memory.
Q. And can you cite for me any peer-reviewed scientific studies that
would support your theory?
A. Not at this time, but I believe the subject has been discussed
fairly thoroughly in the two national hypnosis journals that are
peer reviewed.
Q. Are you aware of recent public statements by the British Royal
College of Psychiatrists on this topic?
A. On the topic of -
Q. Whether recovered memories, those through hypnosis or not, can be
considered to be contaminated or reliable?
A. I'm vaguely aware of their statement.
Q. Do you know what it says?
A. Not per se. I've not read it.
Q. Do you have any idea?
A. No, because my only knowledge of it came from other than the
document itself, so I really don't.
Q. Have you ever read the national position statements by the
American Medical Association on the reliability of alleged recovered
memories?
A. I don't know that they made any statement about the reliability
of alleged recovered memories.
Q. Have they made any statement about recovered memories? We're
talking about the AMA now, the American Medical Association.
A. My understanding is that they made a statement that cautioned
operators to not regard those statements as wholly the veridical
truth, although I don't believe that they made a statement that they
were, by necessity, not veridical truth.
Q. Is there anything else about the AMA statement that you remember?
A. Not at this time.
Q. Have you seen any statements by the American Psychological
Association?
A. With respect to -
Q. -- the topic we're discussing here; that is, the accuracy of
alleged recovered memories.
A. I've not seen any statements from them about that.
Q. Have you seen anything about potential problems with recovered
memories in therapy from the APA -- that's the American
Psychological Association?
A. I read some articles in some of their publications that caution
that in this climate of increased litigation, that therapists should
be careful to practice neutrally.
Q. Have you seen any national public statements by the American
Psychiatric Association on the issue of recovered or repressed
memories?
A. I may have, but I don't recall at this time.
Q. Have you ever talked to Dr. Renee Frederickson?
A. Once, I believe.
Q. And when was that?
A. Oh, over a year ago approximately -- a yew or two ago. I'm not
quite sure.
Q. And how long did you talk to Dr. Frederickson?
A. Oh, maybe ten minutes.
Q. What was the nature of the conversation?
A. She had apparently had a Board complaint against her that was
quite troubling to her, and the nature of the conversation was how
she might care for herself during that period of heightened stress.
Q. Did you have any discussions with her about alleged conspiracies
to get her?
A. No.
Q. Have you read Dr. Frederickson's book on repressed memories?
A. No, I have not.
Q. Have you ever talked to someone named Kathleen Steele?
A. Is this the Kathy Steele in Atlanta?
Q. Yes.
A. Yes, I have.
Q. How many times have you talked to her?
A. Oh, approximately a dozen.
Q. Is that in person or over the phone?
A. There may have been a couple over the phone, but primarily in
person.
Q. And where did those contacts take place?
A. The in-person contacts took place in Washington, D.C., or close
to there -- Alexandria, Virginia -- but the Washington, D.C., area
and then once in Seattle.
Q. Did you ever go to any of Kathleen Steele's training seminars?
A. I went to one that she presented in Seattle, and then I presented
with her once, I believe, at a conference in Washington, D.C.
Q. What was the topic area for your presentation in Washington,
D.C., with Kathleen Steele?
A. It was basically a seminar -- all-day workshop or two-day
workshop for therapists on how to, in essence, take care of
themselves in terms of stress management.
Q. Was there anything in the seminar about satanic cult abuse?
A. No.
Q. Nothing at all?
A. Participants may have mentioned it, but it certainly was not in
the syllabus.
Q. What year did you do that seminar with Kathleen Steele in
Washington?
A. Sometime in the '90s. I'm not sure. Let me think if I can piece
that together. Approximately '93, maybe '94.
Q. How about the seminar you went to of Kathleen Steele's in
Seattle? When was that?
A. '92, '93 approximately.
Q. And what was the nature of the seminar presented by Kathleen
Steele?
A. It was on the treatment of what was then called multiple
personality, now called dissociative identity disorder.
Q. And did she discuss the role of ritualistic abuse or satanic
cults in creating multiple personality disorder?
A. She may have.
Q. Was that not a major focus of that seminar in 1992, '93?
A. I think it was a three-day seminar, and I believe that it was a
focus only on the last day.
Q. Do you have any of the handouts or the materials given out by
Kathleen Steele in that seminar?
A. No, I'm sure I don't.
Q. Why did you go to a seminar by Steele in Seattle in '92, '93?
A. My organization sponsored it.
Q. And what was your organization that sponsored it?
A. It was a component of the journal Treating Abuse Today. It was
actually also a part of my practice. I had been bringing continuing
education events to Seattle for about fifteen years.
Q. Why did you decide to sponsor Kathleen Steele?
A. There was a great interest expressed in the clinical community
for presenters on that topic.
Q. Did she present by herself, or did anyone else come with her?
A. She was alone.
Q. Did you find anything about Ms. Steele's presentation that was
false, deceptive, or misleading?
A. No.
Q. Did you find any of the advice that she gave that could be
hazardous to psychotherapy patients?
A. Not to my knowledge.
Q. Did you get from her, for example, a list of symptoms of patients
who had been satanically abused?
A. I don't remember, but I don't believe so.
Q. Have you ever seen a list of symptoms of persons who have been
satanically ritually abused?
A. Most likely.
Q. Have you ever published such a test in your Treating Abuse Today
news journal during the time you were the editor?
A. The only list of symptoms in that regard that we ever published
was a compilation of self-reports in two different studies.
Q. And in that self-report study, how many of these patients
reported participating in human sacrifices?
A. I don't recall the figures. I would be happy to look at the
article, though.
Q. How many of your patients that you've worked with have recalled
or reported to you they participated in human sacrifices?
MS. WILLIAMS: Object: Compound.
A. Can you please state it again?
Q. [By Dr. Barden] Yes. Of the patients you've treated -again, I'm
not interested in any patient names -
A. Right.
Q. -- of the patients you've treated, how many of them reported to
you that they have participated in human sacrifices?
A. By human sacrifices, are you including simple murder?
Q. Let's start with that.
A. I had one patient -- well, by "participated in," you mean other
than witnessed?
Q. Let's start with witnessed.
A. Okay. I had one patient -- two patients -- three patients --
three patients who claim to have witnessed murder.
Q. What steps, if any, did you take to report that to the
authorities?
A. I'm not obligated to do so. In fact, as I understand the
requirements of confidentiality, I'm obligated not to do so.
Q. How many of your patients have reported witnessing or
participating in human sacrifices?
A. Reported to me?
Q. Yes.
A. There's one that I might characterize that way, but we never in
the therapy characterized it as a memory.
Q. How many of your patients during your entire practice have
reported to you participating in injuring human beings as part of
ritual or cult activity?
A. Three.
Q. How many patients have reported to you witnessing or forced
participation in animal sacrifice?
A. Animal sacrifice as independent operators, do you mean? Or in
concert with others?
Q. I'm asking you about forms of abuse reported by ritual abuse
survivors in your practice. How many of them reported witnessing or
forced participation in animal
sacrifice?
A. By "ritual abuse survivors," you mean people who reported to have
been ritual abuse survivors? Because I have no corroboration in most
of those cases. So for people in my practice who reported being
ritually abused by satanic cults -- is that correct? -
Q. Yes.
A. -- how many participated or observed animal
Q. Sacrifice.
A. -- sacrifice?
Q. Yes.
A. None.
Q. Okay. Now, I think you added the word "satanic." How about ritual
abuse survivors?
A. Well, I'm aware of some patients who were abused by multiple
perpetrators in some kind of methodical abuse, who then later in
life engaged in harming animals.
Q. And in talking about the forms of abuse reported by ritual abuse
survivors in treatment with you, what percentage reported forced
participation in group sex with adults?
A. Three -- one hundred percent.
Q. And how many of those patients reported to you witnessing or
forced participation in cannibalism?
A. None.
Q. And how many of them reported being forced to be baby breeders
for children that were later sacrificed?
A. None.
Q. Have you ever spoken about that, this theory that these cults do
baby breeding? Have you ever spoken about that in your presentation?
A. Not to my knowledge, but if I did, it was not to assert it was
true. It would have been, if I had spoken about it, it would be to
simply report the reports that were being given to me by other
clinicians.
Q. In your publications; that is, the publications that you were
editor of, the Treating Abuse Today, when you describe satanic cult
survivors, did you describe them as "alleged" or "reported," or did
you just list them as satanic cult survivors or ritual abuse
survivors?
A. Probably a mixture of both, although I don't recall specifically.
Q. Of the times that you listed in your publication ritual abuse
survivors, what percentage of the time you used that term do you
think you ever used the word "reported"?
A. If we didn't use the word "reported," we made it clear from the
context that these were self-reports that had not been verified.
Q. I think the question was: What percentage of the time do you
think you used the word "reported"?
A. I don't know.
Q. What percentage of the time -- same question -- do you think you
used the word "alleged"?
A. I don't know.
Q. Did you ever put the word "memories" in quotes when you were
describing the reported memories of these patients?
A. Perhaps.
Q. Did you ever publish in Treating Abuse Today in the entire time
that you've ever discussed the questions of cult abuse or MPD, did
you ever publish a summary of the warning from the American Medical
Association published in JAMA in 1985?
A. We did not.
Q. Did you ever in the entire time that you ever published Treating
Abuse Today and were discussing issues regarding hypnosis, did you
ever discuss any legal restrictions on the ability of patients who
had been hypnotized to testify in criminal trials against the people
who abused them?
A. Please state the question again?
[The court reporter reads back.]
A. I don't recall, but my impression is that we may have at least
once.
Q. [By Dr. Barden] Do you have any idea what year that might have
been published in Treating Abuse Today?
A. No, I don't.
Q. In the entire time that you ever published Treating Abuse Today,
did you ever publish research following children known to have been
sexually mistreated to ascertain whether they had any symptoms or
not?
A. No, we did not.
Q. Are you aware of any research on children known to have been
sexually mistreated that followed them to see what, if any, symptoms
they displayed from being mistreated?
A. When you say "followed them," what do you mean?
Q. What's your understanding of the term "longitudinal study"?
A. In this regard, it would be a study that would follow -that would
take statements from them throughout their lifetime.
Q. Are you aware of any study like that?
A. I'm aware of some that you cited in some public talks, but I
looked for those studies and was unable to find them, and, frankly,
I think they would be ridden with methodological errors.
Q. What kind of methodological errors do you think they would be
ridden with?
A. Well, the first one would be that in order to ask those kinds of
questions, you would have to be asking leading questions, so you
would have the contaminated field to begin with.
Q. Any other methodological errors?
A. How you would find the children to ask them about abuse without
also potentially contaminating the field?
Q. Any other methodological errors?
A. None that occur at the moment, but on reflection there may be
others.
Q. Have you read any studies of children known to have been abused
where they were asked questions about what symptoms they had?
A. I'm aware of those. I can't cite them for you.
Q. Can you tell me any of them?
A. Not at the moment.
Q. Okay. Can you tell me any of the symptoms?
A. The symptoms of
Q. What's the standard symptom picture for children known to be
sexually mistreated?
A. Oh, I don't know that there's necessarily a standard symptom
picture. I think there's constellations perhaps.
Q. Okay. What's your understanding of the constellations?
A. That these children will tend to show symptomatic features in the
interpersonal realm, in the cognitive realm, the behavioral realm,
and developmental realms.
Q. Of the children known to have been sexually abused, what
percentage of them developed repression or amnesia for being abused,
to the best of your knowledge?
A. When you say "amnesia," you mean complete amnesia?
Q. Yes.
A. So that they have no memory at all and no behavioral or emotional
representation of memory?
Q. Well, I'm asking about narrative memory now because we're dealing
with interview studies, correct?
A. So their ability to tell the story, you mean?
Q. Yes.
A. I don't know, but I think it was a fairly low percentage.
Q. How low?
A. I don't know.
Q. Do you know what percentage of children showed no symptoms?
A. No symptoms of -
Q. No symptoms of psychological distress.
A. I don't know.
Q. Do you have any idea at all?
A. Well, it's a difficult question to answer because I'm not sure
what you mean when you say "abused."
Q. Okay. I mean sexually abused.
A. You mean one time? Do you mean several times?
Q. From one to many times.
A. Well, I think the answer would depend upon the severity and the
nature of the abuse.
Q. Well, my question, though, Mr. Calof, is: In the published
literature -- are you aware of the published literature on this or
not?
A. The published literature pertaining to -
Q. Children who are abused who were followed to ascertain what
symptoms, if any, they displayed.
A. I'm somewhat familiar with that literature.
Q. Can you name for me any authors of that literature?
A. Linda Meyer-Williams would be one. There's a gentleman who as a
three-letter last name, and I can't think of it right now.
Q. Now, again, in looking at the research by any of these
individuals who studied children known to have been abused, followed
the children to ascertain what symptoms they displayed, if any, can
you discuss for me how many, if any, of these children displayed
symptoms of amnesia, dissociation, or repression for being abused?
A. I think Linda Meyer-Williams found something like twenty-nine
percent.
Q Now, when you say twenty-nine percent, what was the nature of the
study that you're referring to?
A. As I remember it, it was a study in which she tracked -well, I
shouldn't say tracked actually, a study in which she identified
individuals who had been abused as children and who had been treated
in a hospital for that, and based on their hospital records, then
she got in contact with those individuals -- I'm not sure how she
did that -- and then asked them about their recollections.
Q. Are there any methodological errors in that study, Mr. Calof?
A. I understand that some people have raised some.
Q. What's your understanding of the methodological errors in that
study?
A. I don't know that I hold with this necessarily, but I understand
that there has been concern that she didn't specifically ask them if
they had been reluctant to share the information as opposed to
forgetting it -- having amnesia for it.
Q. Has a study been conducted that corrected that methodological
problem?
A. Not to my knowledge.
Q. Now, in that study by Linda Meyer-Williams that you are referring
to, what was the youngest age at which the people were known to have
been abused in that sample by Linda Meyer-Williams?
A. I don't think I know that.
Q. Do you have any idea at all?
A. No, I really don't.
Q. What's the youngest age at which children can form lasting
narrative memories, do you know?
MR. ANDERSON: Im sorry, I didn't hear the question.
Q. [By Dr. Barden] What's the youngest age at which children are
known to be able to form lasting narrative memories; that is,
memories that will last throughout their lifetime?
A. I think there's some disagreement about that in the field, but I
think generally you'll find estimates between two and three.
Q. Any of Linda Meyer-Williarns' subjects abused before age three,
for example?
A. I don't know.
Q. Were there any subjects in the Linda Meyer-Williams study who
remembered being abused very well, just not the particular instance
that Linda Meyer-Williams was looking for?
A. I'm not aware of that.
Q. Are you aware of any studies done by Linda Meyer-Williams in
which she looked for symptoms in children; that is, not waiting
until their adults? The study we've been discussing, Linda Meyer-
Williams is talking to adults about something that happened decades
ago, correct?
A. That's correct.
Q. Are you aware of any studies that Linda Meyer-Williams or anyone
else has done looking at children who have known to have been abused
and followed for a shorter period of time to ascertain whether they
had any symptoms?
A. There may be one. I believe Dr. Frank Putnam at NIMH May be
conducting that kind of research, but I'm not familiar with it nor
have I read it.
Q. Are you aware of any published reviews in leading professional
journals looking at dozens of such cases?
A. No, I'm not.
Q Are you aware of any peer-reviewed journals indicating that any
human being known to have been abused had been shown to repress
memories of being abused and later recovered those memories with any
degree of accuracy?
A. I wouldn't, except the characterization of repress. If you
rephrase that in terms of traumatic amnesia, then yes.
Q. Okay. And what are those studies?
A. There were numerous studies reported by Clark Hull at Yale in the
1930s and 1920s in various journals, Abnormal Psychology, Journal of
-- that's the one I remember the most. There were thirty-six papers
that he published from his study in two books.
Q. What was the nature of his methodology?
A. There were many different ones, actually. He took reports of
individuals -- clinical reports and then ruled out those for which
there was not corroboration. He then demonstrated in the laboratory
the ability for individuals to develop amnesia and then later on
recall information.
Q. So what kinds of things did the subjects repress or fail to
remember in the studies by Dr. Hall that you're discussing with us?
A. Well, he cited numerous traumatic kinds of incidents including
abuse, but also including accidents, I think automobile accidents I
can't remember the other categories right now and then there was
also information that was not of a traumatic nature.
Q. And according to the studies by Dr. Hall -
A. Hull, H-u-l-l.
Q. -- Dr. Hull -- as your discussing them, what percentage of these
people experiencing trauma repressed or forgot being mistreated?
A. I'm not sure he actually came to a conclusion about that.
Q. Do you have any idea at all?
A. I really don't.
Q. I mean, was it more than one percent, for example?
MS. LANG: Objection: Calls for speculation. MS. WILLIAMS: Asked and
answered.
A. I really don't know.
Q. [By Dr. Barden] Was it your understanding from reading the
studies from Dr. Hull that he thought that these people could
completely block out of their minds ever experiencing the trauma?
A. I don't know that -- he may have said that, but I know that the
issue there was more, how you put it earlier, the inability to give
narrative descriptions of it. I think that he, like Jench and other
people, believe that those memories still exerted influence on
behavior cognition and affect.
Q. Well, was he talking about the loss of partial memory or details
or tidbits of memory, or was he talking about blocking out the
entire incident?
A. He studied all of those.
Q. Did he offer any research as to how to help people recover
memories?
A. Not to my knowledge. His emphasis was more experimental than
clinical.
Q. And did he
A. Well, actually, he did make reference to the use of hypnosis to
help them do that. I should say that.
Q. To the best of your knowledge, how many states have rules or
statutes restricting the testimony of persons who have been
hypnotized?
A. I don't know that that's done by statute in any state. I believe
that's more done by precedent.
Q. Are you aware of how many states it's done by either statute or
by precedent?
A. I'm aware it's a fairly high number.
Q. Are you aware of the basis for why a high number of states
restrict testimony of persons known to have been hypnotized?
A. Well, I really can't get into the minds of the people that frame
those, so not per se. Maybe you can ask me in a different way.
Q. Do you know any research that was used to support the findings of
the -
A. No.
Q. Pardon?
A. No, I do not.
Q. Are you aware of the work of Dr. Martin Orne?
A. I'm aware of some of the work of Dr. Orne.
Q. And what are you aware of?
A. I'm aware that his name has -- that he's been an experimenter in
hypnosis for a good number of decades.
Q. Are you familiar with any of his work?
A. I think I answered that.
Q. Are you familiar with any of his particular research projects or
studies?
A. Not off the top of my head.
Q. Are you familiar with any of his conclusions about the use of
hypnosis to enhance memory?
A. I know that he's been cautionary about that.
Q. Are you aware of any warnings published in national textbooks in
psychology or psychiatry through the 1980s warning people against
the use of hypnosis to enhance memory?
A. Not per se.
Q. Well, are you aware in any general or specific way whatsoever of
any textbook warnings of that type?
A. Not textbook warnings, no.
Q. Are you aware of any warnings in any textbooks in psychology or
psychiatry through the 1980s having to do with multiple personality
disorder being iatrogenically created?
A. I'm aware that there's been opinion expressed on that subject,
but I'm not aware of any scientific evidence.
Q. In your study group or whatever with Dr. Rice and in your study
group with Mr. Laughlin, did you ever teach them that it was
necessary to inform patients of the controversy regarding the
etiology of multiple personality disorder?
MS. WILLLIAMS: I object to form "or whatever."
A. Could you ask again, please?
Q. [By Dr. Barden] Yes. You had groups with Mr. Laughlin and Dr.
Rice, correct?
A. Correct.
Q. You discussed the treatment of multiple personality disorder,
correct?
A. Correct.
Q. In both groups?
A. Correct.
Q. Did you ever teach them as part of the study group that because
there were differing theories for the etiology of MPD, that it was
necessary to tell patients those theories?
A. I taught them that it was necessary for them to consider them,
but whether or not it was necessary to tell patients was another
matter, and I don't believe that you can generalize.
Q. Are you aware of any other research, other, than the research by
Clark Hull that you've just listed, indicating that human beings are
capable of suffering streams of traumatic events, such as being
satanically ritually abused for years, somehow blocking out all
memory of that mistreatment, and later recovering it with any degree
of accuracy?
A. Dr. Hull listed numerous studies in his works, and, I'm sorry, I
can't remember them at the time. I know that Dr. Loftus reported on
a case of a college professor who lost her memory after a string of
traumatic incidents.
Q. Are you familiar with the work of Dr. Loftus?
A. Reasonably.
Q. Is it your conclusion from reading Dr. Loftus' work that she
considers the theory of repressed and recovered memory to be
reasonable?
A. Once again, I think you're misusing the term "repressed," but if
you're asking me about traumatic amnesia, I believe that Dr. Loftus
has been inconsistent in her positions.
Q. Are you familiar with the work of Dr. Richard Ofshe?
A. Yeah, somewhat.
Q. Okay. What's your understanding of the work of Dr. Ofshe?
A. I understand that he is a sociologist who has, well, worked in a
number of areas.
Q. Have you read any articles by Dr. Ofshe in the International
Journal of Experimental and Clinical Hypnosis, for example?
A. I believe I read the article in which he references the Paula
Ingraham case.
Q. Are you aware of any national or international awards given to
Dr. Ofshe for his work in the field of hypnosis?
A. No. The only award in contention there is one that I think he's
misrepresented.
Q. And which one is that?
A. The Pulitzer prize.
Q. And why do you say that you feel he's misrepresented it?
A. Because the Pulitzer Committee sent out a letter to that effect.
Q. Do you have a copy of this letter?
A. I don't believe I do any longer.
Q. Have you seen the letter?
A. I have.
Q. And what did the letter say?
A. That he could not claim that he had been a recipient, that he had
not been a recipient, and that if he were to claim that, that it
would be improper.
Q. And when did you see this letter?
A. Oh, sometime within the last couple of years.
Q. And where did you get a copy of that letter?
A. From the Pulitzer Committee.
Q. I think you mentioned that you do read the Journal of
International Experimental -
A. Not consistently.
Q. Oh, really? Okay.
A. I receive it. I don't always read it cover to cover.
Q. Are you a member of any hypnosis associations or professional
societies?
A. Yes.
Q. Which ones?
A. The American -- let's see, the Association for Ethical -for the
Advancement of Ethical Hypnosis, the American Hypnosis Association,
the American Hypnosis Examiners Council, the National Board for
Hypnotherapists Certification. I believe there are some others, but
those are the ones that come to mind.
Q. Now, looking at those various associations, do any of them have
any ethical codes?
A. I believe they all do.
Q. Do any of them have any ethical codes with regard to informed
consent for hypnosis?
A. I believe that they are in the process of developing them, some
of them. I'm not sure -- well, that's not completely true. Yes, they
do.
Q. And what do they say?
A. That you should explain the procedure to the client, that you
should obtain the client's consent to proceed, that you should
discuss the limitations of hypnosis, and that you should not
represent yourself as having expertise in an area which is outside
of your expertise; for example, medical knowledge.
Q. Is there anything else?
A. There may be, but none that comes to mind right now.
Q. In your work with clients, do you use hypnosis?
A. On occasion.
Q. What informed consent procedure do you use with your work with
clients?
A. There is a thorough discussion about hypnosis that I engage in
before I conduct any hypnosis.
Q. And what is that thorough discussion?
A. It involves an agreement; in essence, a contracting about the
intended purposes of the hypnosis, how it will be conducted, ways
that the -- sort of the client's rights and abilities while a
subject of hypnosis. It reaffirms the professional boundaries of the
operator and the subject, it answers any questions or concerns the
client may have with respect to the procedures, and it attempts to
demythologize the client's unreasonable expectations about the
process.
Q. Are you aware of any peer-reviewed treatment outcome research
indicating that hypnosis has been shown to be a safe and effective
treatment for emotional disorders?
A. If you mean safe and effective as defined by the American
Psychological Association, that's a process of approval that certain
-- that modalities of therapy are subjected to. I'm not sure it's
been subjected to that. I do know that in 1956 the British Medical
Association did find it a safe and effective means of treatment, and
in 1957 I believe the American Medical Association followed suit.
Q. Do you frequently rely upon 1956 and '57 research in your
therapy, Mr. Calof.?
A. Only when it's not been supplanted by further findings.
Q. When were lobotomies popular, Mr. Calof, do you know?
A. I think they've gone out of fashion a number of decades ago.
Q. About the same time that you're referring to in the '50s perhaps?
MS. WILLIAMS: I'm going to object as argumentative.
A. If you're attempting to draw any causal connection there, I don't
see it.
Q. [By Dr. Barden] No.
DR. BARDEN: And for the record, I'm just checking the witness's
knowledge of his field.
A. I don't practice lobotomies.
MS. WILLIAMS: Just for the record, yes, I haven't heard any
testimony that lobotomies is part of his field.
DR. BARDEN: The history of dangerous pseudo treatments is an
important part of the knowledge of one's field, just for the record.
Q. [By Dr. Barden] Have you ever put out a tape called, "Working
with Difficult Alters"?
A. A company put out a tape that I was featured in.
Q. Is it your voice on that tape?
A. Yes.
Q. And what did you teach people about how to work with difficult
alters?
A. I think the primary message in that type was how do you obtain
rapport.
Q. Did you encourage therapists to talk to alters by a name?
A. Not per se.
Q. Did you ever encourage therapists to find out who the alters
were?
A. I'm not sure I understand the meaning of the question.
Q. Find out how many alters the patient had?
A. Not the way you're asking it, no.
Q. Well, could you tell me more particularly what you taught
therapists on the tape "Working with Difficult Alters"?
A. The tape was primarily a demonstration of my clinical work. I
don't believe that I -- there was a lot of didactic discussion on
that tape.
Q. What did you present as examples of your clinical work in terms
of working with difficult alters on that tape?
A. It was a tape of a consultative interview that I did with someone
else's client.
Q. Was this in a consultative group?
A. No.
Q. And what did you advise the client in the consultative session
that was on the tape "Working with Difficult Alters"?
A. I'm not sure I advised the client of anything.
Q. Did you offer any advice to the client in the tape "Working with
Difficult Alters"?
A. I may well have, but I don't recall.
Q. Do you have any idea what you would have advised on the tape
"Working with Difficult Alters"?
MR. VanDERHOEF. Object to form; speculative.
A. Well, as I say, I don't remember exactly, but I can tell you that
the issues in the tape regarded self-harm, and I'm sure that my
position was that the client should stop doing that.
Q. [By Dr. Barden] Have you ever indicated in any of your writings
or speeches that clients will self-harm as a result of programming
from the cults?
A. I believe that I have indicated that they may self-harm as a
result of the perception that they have been programmed or as a
result of internalizing injunctions to that effect.
Q. Have you ever written or spoken about programming by the cults
without indicating that it was alleged or reported by the client?
A. I may have, and, if so, it was misleading.
Q. Have you ever done a tape called "Hypnosis in the Management Of
MPD'?
A. "Hypnosis in the Management Of MPD-?
Q. That's correct.
A. Done a tape about that? I don't believe so.
Q. Is your voice on a tape called "Hypnosis in the Management of
MPD'?
A. I've given talks on that subject matter. They may have been tape
recorded. I don't recall at the moment.
Q. What have you recommended to therapists in terms of using
hypnosis in the management of MPD?
A. I don't recall per se, but typically it involved the use of
hypnosis for containment, for mediation of self injurious behaviors.
Largely along those lines.
Q. Can you cite for me any peer-reviewed treatment outcome research
indicating that hypnosis has ever been shown to be useful in
containment with MPD?
A. I can't cite it for you.
Q. Have you seen any such research?
A. I believe that them has been some research published on that.
Q Do you know who might have published such research?
A. Perhaps the Journal of Dissociation, perhaps other psychiatric
journals, but I don't recall specifically.
Q. Do you consider the Journal of Dissociation to be a credible
source of information?
A. Yes, I do.
Q. Do you consider Dr. Van der Kolk to be a credible source of
information?
A. If you mean credible in that I accept every word he's ever spoken
or written, then I can't say that about anybody. But, in general,
yes, I do consider him to be a credible researcher and clinician.
Q. Have you ever read the works of Judith Herman?
A. I've not read her books. I may have read some things she's
written.
Q. Do you consider her to be a credible source of information?
A. With the same caveat that I've given, yes.
Q. Have you read works by Dr. Kluft?
A. Yes.
Q. Do you consider him to be a credible source of information?
A. Yes.
Q. Have you read works by Dr. Bennett Braun?
A. The only work by Dr. Braun I think I ever read was an early
article in a book published by the American Psychiatric Association
and possibly an article in -- it may have been a repeat, actually,
of the same article in Dissociation.
Q. Who serves as the editor and associate editors of the Journal of
Dissociation, do you know?
A. I believe Dr. Kluft has been the editor since its inception.
Q. Do you know who the associate or assistant editor was since its
inception?
A. I don't off the top of my head.
Q. Do you know who the members of the editorial board of the Journal
of Dissociation were since its inception?
A. I don't know. I believe that they've change a fair number. I
believe that-- well, Dr. Kluft was on there, I believe Dr. Loestein
was on there, Dr. Ganoway, I think Dr. Fine, perhaps Dr. Braun. I'm
sure there were others. I may not be accurate, but I believe those
were on there.
Q. How about Dr. Colin Ross? Was he on there?
A. He could have been. I don't know for a fact.
Q. Do you consider him to be a credible source of information?
A. With the same caveat that I gave above.
Q. How about Dr. George Grieves?
A. What about him?
Q. Was he on the editorial board of Dissociation?
A. My impression was that he was early on, but I'm not sure.
Q. Do you consider him to be a credible source of information?
A. With some exceptions.
Q. What are the exceptions?
A. Dr. Grieves got into a boundary violation with at least one
patient that I believe was proven, and so I would not accept his
views on issues of -- views on boundary violations for sure, and I
think his views would be tainted as to transference and
countertransference.
Q. Has Dr. Corey Hammond ever been on the editorial board of
Dissociation, to the best of your knowledge?
A. Not to my knowledge.
Q. Do you consider Dr. Hammond to be a credible source of
information?
A. I don't know much about Dr. Hammond except for his work in
hypnosis, and I believe that he is very credible there. I believe he
helped develop the informed consent procedures for the American
Society of Clinical Hypnosis.
Q. Have you ever read a speech by Dr. Hammond called the Dr.
Greenbaum speech?
A. No, I have not.
Q. Have you ever heard of a Dr. Greenbaum?
A. In passing. I couldn't tell you who he was, though.
Q. Do you have any memory of how you heard about Us in passing?
A. I was at a conference where I believe he gave that speech, and I
was presenting opposite him so I did not attend. Some people
mentioned it in the hallways.
Q. What did they say to you about that in the hallways?
A. My predominant impression was that they were disturbed by the
content.
Q. What was it about the content that they found disturbing?
A. I think it frightened them.
Q. What was it about that frightened them?
A. I really don't know.
Q. Have you ever read the work of Mr. Alan Scheflin?
A. I think I read a book he wrote in 1989 called Trance on Trial.
Q. Do you consider him to be a credible source of information?
A. With the same caveat expressed above.
Q. Now, you said that in your tape "Hypnosis in the Management of
MPD,' you discussed using hypnosis for containment. What did you
advise therapists to do in that regard?
A. There were a variety of suggestions that I've given in talks of
that topic. They would include the use of imagery.
MR. VanDERHOEF.. Are you asking what he advised on the tape?
DR. BARDEN: Yes.
A. Well, I don't know what tape you're making reference to.
Q. [By Dr. Barden] Okay. Well, let's just do it in general, then.
During, let's say, the time period 1990 to 1994, what were you
advising therapists in the use of hypnosis for the management of
MPD?
A. With respect to the containment, the recommendations were
generally to use -- would be -- in the use of hypnosis would be to
use it as a relaxation medium the behavioral notion of reciprocal
inhibition that a person can't be both relaxed and anxious at the
same time was a large part of it, the use of imagery in order to
contain feelings, and variations on those themes.
Q. How do you use imagery to contain feelings?
A. You might, for example, imagine putting the disturbing feelings
in some kind of imagery container.
Q. Did you ever create a tape called "Response to the False Memory
Controversy"?
A. Actually, I don't think I've created any tapes.
Q. Okay. Was your voice ever on a tape, to the best of your
knowledge, entitled "Response to the False Memory Controversy"?
A. It could have been. I don't remember that specific title, but it
surely could have been.
Q. And what were you saying about response to the false memory
controversy? What are your views on that?
MS. WILLIAMS: I object. I heard two questions, one of which had no
foundation whatsoever.
Ms. LANG,: And overbroad and vague.
Q. [By Dr. Barden) Let's ask you during the time period well, let's
just ask you in general. Have you ever given a speech about a
response to the false memory controversy?
A. Yes, I've given invited addresses of that form.
Q. What did you say?
A. I said a lot of things.
Q. Have you ever characterized the proponents of the idea that false
memories can be created as a conspiracy?
A. No, I don't believe I've said that.
Q. Have you ever stated anywhere that there is a conspiracy to
harass you?
A. I believe there has been a conspiracy to harass me, and I believe
that's been established.
Q. Have you ever told anyone that the false memory movement is
funded by satanic cults?
A. No, I have not.
Q. Pardon?
A. No, I have not.
Q. Have you ever had any training in psychological testing?
MR. ANDERSOM In -
THE WITNESS: Psychological testing.
MR. ANDERSON: Okay.
A. Not really, no.
Q. [By Dr. Barden] Do you give any psychological tests?
A. No, I do not.
Q. What percentage of your patients are injured by your treatment?
MR. VanDERHOEF: Object to form -
MS. LANG: Object to form.
MR. VanDERHOEF: -- argumentative. Now we're getting beyond the scope
of anything he could testify to that might be reasonably calculated
to lead to the discovery of admissible evidence in this case.
Q. [By Dr. Barden] Do you have any idea how many of your parties are
injured by your treatment?
MR. VanDERHOEF: Same objections.
MR. ANDERSON: I'm going to object to that question as well. Unless
you can demonstrate -first of all, there's absolutely no foundation
that any of them ever have been injured. Your question presumes that
there is such a population of patients. I see that that has no
possible bearing in this case at all so I'll instruct Mr. Calof he
doesn't have to answer that if he doesn't wish to.
DR. BARDEN: Arc you going to instruct the witness not to answer?
MR. ANDERSON: No, I'm telling him he doesn't have to answer that if
he doesn't want to.
Q. [By Dr. Barden] Do you have any way of ascertaining whether your
patients are injured by your treatment or not?
A. No one has ever complained about my treatment.
Q. Have you done any structured interviews pre- and posttherapy to
determine whether any of your patients are injured by your
treatment?
A. I've done some of those.
Q. What was the structured interview method that you used, Mr.
Calof?
A. I called some of them after five-year follow-ups to ask them if
their symptoms had returned and to garner their impressions of their
treatment.
Q. What percentage of your patients did you call and use that
procedure with?
A. I'm not sure I recall that number. It would have been perhaps ten
or fifteen percent.
Q. And do you have any summary data for those phone calls?
A. No, I don't.
Q. Did anyone else other than you ever obtain any data of that type?
MR. ANDERSON: About his patients
DR. BARDEN: Yes.
MR. ANDERSON: -- or his client population?
Q. [By Dr. Barden] Were there any research workers or office staff
who conducted any of the -
A. No.
Q. -- so-called interviews?
A. No.
Q. Pardon?
A. No.
MR. VanDERHOEF: Object to form.
Q. [By Dr. Barden] What's your understanding of the term "structured
interview" as it's used in the mental health field?
A. My understanding of the term is that it's an interview that's --
where the questions were predetermined so that there will be
consistency between administrations of it.
Q. And is it your testimony that you used a structured interview to
ascertain outcome data on your patients?
A. I generated a list of questions that I asked each and every
person I called.
Q. And where is that list of questions now?
A. In my mind.
Q. Pardon?
A. Somewhere in my mind. It doesn't exist.
Q. Do you have -
A. I considered the information confidential, and so I destroyed it.
Q. Are you aware of any structured interviews that are used in the
mental health field?
A. Aware by virtue of the fact of being trained in them or doing
them, do you mean?
Q. Are you aware of any?
Ms. LANG: Objection: Vague.
A. I'm aware they exist.
DR. BARDEN: Vague to lawyers, not at all to mental health
professionals.
MS. LANG: Objection: Vague.
A. I'm aware they exist.
Q. [By Dr. Barden] And can you name any of them for me?
A. The Beck Depression Inventory.
Q. Is it your testimony that's a structured interview?
A. No, it's not a structured interview. That's not my testimony.
Q. Can you name for me any of the widely-used structured interviews
in the field of mental health?
A. There's one called the -
MR. VanDERHOEF: Same objection.
A. -- SCIDD. That's the acronym. I can't remember what it stands for
at the moment -- structured clinical interview for dissociative
disorders.
Q. [By Dr. Barden] And have you ever used that with any of your
patients?
A. I have used it in two cases, I believe.
Q. And in your group sessions with Dr. Rice and Mr. Laughlin, did
you ever recommend that they use any structured interviews with
their patients?
A. I don't believe so. I don't believe that instrument actually
existed at the time.
Q. Were there any structured interviews that were in existence at
that time that might have been helpful to them?
A. There was one, I believe, called the Dissociative Experiences
Scale.
Q. Were there any structured interviews for any other diagnostic
categories other than dissociation that you know about?
A. The SCIDD makes the differential diagnosis between personality
disorders and dissociative identity disorders, so I'm not sure that
it's fair to characterize it as wholly relating to dissociative
identity disorder.
Q. Are there any other structured interviews for any other
diagnostic groups?
MR VanDERHOEF: Object as overly broad.
A. I'm sure there are, but I'm not aware of them at this point.
Q. [By Dr. Barden] Have you had any training in the philosophy of
science?
A. Not training per se.
Q What's your understanding, if any, of the theories of Carl Popper?
A. I'm not aware of that.
Q. Have you ever heard that name?
A. Perhaps.
Q. Have you ever had any training in how children react to stress?
A. I believe I've had some continuing education on that subject.
Q. Have you ever heard of the work of Norman Garmezy?
A. I believe he was the investigator -- one of the investigators
into the question of resiliency in children.
Q. What did he find, in general?
A. For children who had been abused?
Q. Just in general for children experiencing traumas of various
types.
A. Well, I don't recall specifically.
Q. Do you recall generally?
A. I believe that he said that they would fair better if there was
an emotionally-containing context around them if there was social
support around them. There was two other or several other major
factors that I'm not recalling at the moment.
Q. In the work by Norman Garmezy on children experiencing trauma,
did he ever indicate that any of these children would repress or
dissociate or suffer traumatic amnesia?
A. I don't know whether he addressed that or not.
Q. Are you familiar with the work of Richard Lazarus?
A. Not really. I understand he's also a worker in the issue of
resiliency.
Q. What's your understanding of the term "KAPPA coefficient as it's
used in the mental health field?
A. It's Cohen KAPPA?
Q. "KAPPA coefficient." Have you ever heard that term?
A. I believe it's called the Cohen KAPPA coefficient, if I'm not
mistaken.
Q. What is your understanding of that term?
A. In general -- and let me say, this is really out of the area of
my expertise -- but, in general, my understanding is that it rates
interrelator reliability in the administration of tests or research.
Q. What's your understanding of the interrelator reliability of the
diagnosis of multiple personality disorder during the years 1990
through 1995?
A. I don't remember exactly how the scale works, but I remember it
was a very high correlation.
Q. What's your understanding of the KAPPA coefficient for the
diagnosis Of DID?
A. Same answer.
Q. What's your understanding of the term "Bayesian" as it's used in
the social science and mental health fields?
A. I'm not sure,
Q. Have you ever heard that term?
A. I perhaps have.
Q. What's your understanding of the term "Fisher test"?
A. I don't know.
Q. Have you ever heard that term?
A. I don't remember that I did.
Q, What's your understanding of the term "T test"?
A. I don't have an understanding. I believe these areas are outside
my area of expertise.
Q. Have you ever heard of the term "one-tailed test"?
A. I've heard the term. I don't know the meaning.
Q. Have you ever beard the term "two-tailed test"?
A. Same answer.
Q. When you were doing your meetings with Mr. Laughlin, were you
employed by any agency or company or group?
MR. VanDFRHOEF. Object to characterization "meetings with Mr.
Laughlin."
Q. [By Dr. Barden] Well, you talked about group training or whatever
with Mr. Laughlin.
MR. VanDERHOEF: Objection.
Ms. LANG: Objection.
Q. [By Dr. Barden] During that time period, were you being employed
by any group, agency, or business?
MR. VanDERHOEF: Same objection.
A. Are you asking me during the period of time that John was
attending the study group if I was receiving compensation from any
other organization?
Q. (By Dr. Barden] Okay. Why don't we start with that.
A. The answer is yes.
Q. And who were you receiving compensation from?
A. There were a number of them. The one that was most primary in my
mind was Seattle Mental Health Institute.
Q. And were you an employee of the Seattle Mental Health Institute?
A. I was a contract worker.
Q. Okay. Was there any organization or institution where you were an
employee at that time?
A. In the practical sense of that, no. In the legal sense, when I
was paid by some of these people -- some of these organizations,
they filed W-2's on me. So I'm not sure what the legal
characterization would be, but I was not an employee.
MR. ANDERSON: W-2'S or 1099's?
A. 1099's. I beg your pardon, 1099's.
Q. [By Dr. Barden] Were there any W-2's that were filed for you?
A. No.
Q. Same question for when you were meeting with Dr. Rice.
Ms. WILLIAMS: Same objection as to "meeting."
A. I'll answer as I did for the question above -
Q. [By Dr. Barden] So there were no -
A. -- that during the period of time that Dr. Rice was attending my
study group, there were some places that provided me compensation,
but I was not an employee.
CERTIFIED QUESTION
Q. What kind of malpractice insurance, if any, did you have during
the time you were meeting with Mr. Laughlin and Dr. Rice?
MR. VanDERHOEF: Object to -
MS. WILLIAMS: Same objection.
MR. VanDERHOEF: -- form, and well beyond the scope of anything
pertinent to this case.
MR. ANDERSON: Let's take a break for a moment.
DR. BARDEN: Okay, let's take a break.
[A discussion was held off the record.)
[A lunch recess was taken at 12:00 p.m.]
AFTERNOON SESSION
[The deposition resumed at 12:50 p.m.]
DR. BARDEN: Let's go back on the record.
Mr. Calof's counsel wanted to make a statement, I think, for the
record.
MR. ANDERSON: I just said I think it's inappropriate to inquire into
Mr. Calof's -- whether or not he has insurance coverage, the nature
and extent of it, the firms, what his personal assets might be. He's
not a party to his litigation. This is not an area that can be
reasonably calculated to lead to the discovery of admissible
evidence, and I'm going to instruct Mr. Calof that he's not required
to answer any of those questions, and he's declined to do so unless
he's otherwise ordered by the court.
DR. BARDEN: Okay. We will then certify that question to the court.
For the record, there is already a factual dispute as to whether the
meetings Mr. Calof had with Mr. Laughlin and Dr. Rice were
supervision sessions, consultation sessions, study groups, or
something else, and whether Mr. Calof had insurance
for consulting and supervision might be relevant to solving that
factual question. There may be other reasons why it might be
relevant to this case, but, in any event, we'll certainly agree to
certify that for the court.
Q. [By Dr. Barden] Mr. Calof, you talked about the meeting you had
with Mr. Laughlin. Were there any records kept for any of these?
A. No.
Q. Did anybody take any notes?
A. Not that I remember.
Q. Were there any audiotaped or videotaped records of any of these
meetings?
A. No.
Q. Same questions with regard to Dr. Rice. Any records, audiotapes,
videotapes, notes, anything?
A. No.
MS. WILLIAMS: I want to object to the form of the question -- the
term "meeting" being used for whatever took place between the
witness and Dr. Rice.
DR. BARDEN: Okay.
Q. [By Dr. Barden] Well, I think you testified these were 4 study
groups?
A. These were study groups.
Q. Where did they take place?
A. In my office.
Q. And were you meeting in your office as a study group?
A. We were meeting in my office as a study group.
Q. Did people bring research projects or did they talk about cases
they were having, or how did that work?
MS. WILLIAMS: I object. Are we talking about -- which study groups
are we talking about, or are you just talking in general?
DR. BARDEN: I'm talking in general now, and then we'll get into each
one in particular.
A. In general, people brought readings; they brought questions that
I suppose arose out of cases, but they were more academic questions;
they brought -- yeah,
that's basically it.
Q. [By Dr. Barden] Okay. And was that the case for the meetings with
Mr. Laughlin and for Dr. Rice, or were they different?
A. To the best of my recollection, they were the same.
Q. Did you give any indication in the meetings with Mr. Laughlin or
with Dr. Rice that you personally believed that cults could program
their victims?
A. I don't really remember doing so.
Q. Are you denying that you did or you just don't recall?
A. I don't recall.
Q Now, you had mentioned that you had received some training from
Dr. Milton Erickson, correct?
A. Correct.
Q. Did you end up disagreeing with Dr. Erickson about the way that
multiple personality disorder patients should be treated?
A. In one particular case that he mentioned to me, I did.
Q. And what was the difference that you had with him?
A. In the particular case, I thought that his methods were too
authoritarian and too directive.
Q. Have you, in fact, written that you kind of grew out of your
training with Dr. Erickson and went off on your own direction?
A. Not with respect to multiple personality disorder. I've not
written that.
Q. With respect to what did you write that?
A. Dr. Erickson held a very strategic orientation to therapy, and I
thought that for some classes of clients that was inappropriate.
Q. Were there any other differences in the way that you recommend
treating patients and the way Dr. Erickson recommends treating
patients?
A. I'm sure there were many. I don't know that I fully explored
them.
Q. When was the last contact you had with Dr. Erickson?
A. Late in 1980.
MR. VanDERHOEF: Late -
THE WITNESS: Late in 1980.
MR. VanDERHOEF: Thank you.
Q. [By Dr. Barden] Did Dr. Erickson, to the best of your knowledge,
ever give a seminar on how to treat multiple personality disorder
patients?
A. I have no idea.
Q. Did he ever give a seminar on how to treat victims of satanic
cult abuse?
A. I have no idea.
Q. Have you read any research in which the investigators tried to
ascertain whether allegations of satanic cult abuse could be
corroborated?
A. No.
Q. Have you seen any reports from any national commissions or
associations on child abuse and neglect as to whether allegations of
satanic cult mistreatment appear to be accurate or not?
A. I've not read those if they exist.
Q. Pardon?
A. If they exist, I've not read them.
Q. Have you ever heard of Professor Gail Goodman?
A. Yes, but I can't place the context.
Q. Have you ever read any of her work with regard to
allegations of satanic cult abuse or any other kind of ritual abuse?
A. Not -- Goodman or Goodwin?
Q. Goodman, m-a-n.
A. Not to my knowledge.
Q. Have you ever heard of Professor Gail Goodman?
A. Not to my knowledge.
Q. You're thinking of Jean Goodwin?
A. No. I was just asking for clarification.
Q. Okay. Have you heard of Jean Goodwin?
A. I believe she's a professor in Texas.
Q. And she's written on multiple personality disorder, correct?
A. I believe so.
Q. Have you ever read her article on animal alters, for example?
A. No, I've not.
Q. Have you ever read any of the FBI reports on so-called satanic
cult ritual abuse?
A. If they exist, I have not read them.
Q. Have you read any reports by anybody who worked with the FBI with
regard to whether these cults exist or not?
A. If they exist, I have not read them.
Q. Have you ever recommended group treatment for patients who
believe they were sexually mistreated?
A. Have I recommended that to any of my clients?
Q. Yes.
A. I believe I have, but I want to be clear that this does not speak
to my role in this particular case.
Q. Are there any risks or hazards to group psychotherapy with people
who believe they have recovered memories of being mistreated in
their childhood?
A. I believe there's risks and hazards to every form of treatment.
Q. What would be the specific risks and hazards to group treatment
with patients who come to believe they have recovered memories of
being mistreated in childhood?
A. Role inappropriateness by the leader, the possibility of
stressing -- of underemphasizing the importance of function. Those
are the ones that come to mind.
Q. Have there been any risks of this kind of group treatment that
have been published in the professional literature, to the best of
your knowledge?
A. Most likely, but I'm not familiar with it as we sit here.
Q Have you ever recommended to therapists in your talks that they
read certain books?
A. Most likely, but I don't remember.
Q. Have you ever recommended in print or in any of your taped
speeches that they read the book The Courage to Heal, for example?
A. Not per se. I think people ask me about that book, and having not
read it, there wasn't much I could say about it except I was told by
clients who had read it that they found it useful, and I relayed
that information.
Q. So you have not read the book The Courage to Heal?
A. I read only one section in it where I was quoted just to be sure
the quotations were accurate.
Q. What was the quote?
A. I don't recall at the moment.
Q What did it have to do with, do you know?
A. I don't recall specifically.
Q. Was the quote accurate?
A. To the best of my knowledge.
Q. Have you ever recommended any books to any of your patients?
A. On occasion.
Q And which books?
A. For a number of years I recommended books on assertiveness, one
called Your Perfect Right and one called When I Say No, I Feel
Guilty. It's generally my practice not to recommend books. I don't
particularly find that a useful form of therapy.
Q. In your news journal that you edit, have you published
recommendations for certain books?
A. We may have published bibliographies, but I don't think we ever
endorsed them.
Q. Have you ever published recommendations by authors in your news
journal of certain books?
A. Not to my knowledge, although we may have.
Q. Have you ever written a book called Multiple Personality and
Dissociation: Understanding Incest Abuse in MPD?
A. What book was actually an edited interview that I gave in a
newsletter.
Q. On the title cover, does it say "David L. Calof," do you know?
A. Yes, it does.
Q. And with Mary Lee Lou?
A. Uh-huh.
Q. And who was Mary Lee Lou?
A. She was the person who interviewed me.
Q. And this was published through Parkside Publishing; is that
correct?
A. Yes.
Q. In 1993?
A. I believe so.
Q. And who owns the copyright to this?
A. Mary Lee Lou.
Q. Does it, in fact, say in here that you own the copyright with
Mary Lee Lou?
A. It may say that, but the contract is in her name.
Q. Okay. Did you receive any royalties from this book?
A. Mary Lee Lou received the royalties and then passed along some
money to me.
Q. Now, was the copyright held by Mary Lee Lou or by Parkside
Publishing?
A. I believe it was by Mary Lee Lou.
Q. And when you were being interviewed by Mary Lee Lou, were you
being truthful with her?
A. Yes.
Q. Do you recall indicating that, quote, In by far the majority of
cases in MPD, there is sadistic torture, usually with a sexual
component?
A. You asked me if I recall saying that?
Q. Yes.
A. Not specifically those words, but I believe that I said something
that was substantially the same.
Q. How would you know that?
A. In a number of cases, I was able to obtain corroboration, and
I've noticed corroboration in other cases.
Q. Have you ever published any corroboration for sadistic torture in
-- well, let me ask you this: Do you have any evidence that, quote,
In by far the majority of cases of MPD contain sadistic torture?
A. Let me be clear what I mean when I say that so that we're on the
same sheet of music. I'm not referring to ritual abuse in that
statement. I'm referring to the character of the perpetrator.
Q. Okay. I'll ask you again: What, if any, evidence do you have
that, quote, In by far the majority of cases of MPD, there is
sadistic torture, usually with a sexual component?
A. I extrapolated from the cases where I have known corroboration.
Q. How many cases do you have corroboration for?
A. About twenty.
Q. And how many MPDs have you treated?
A. Forty some.
Q. What kinds of corroborating evidence did you have?
A. Confessions by perpetrators, criminal convictions, testimony by
corroborative witnesses, diary entries.
Q. Have you published any of this corroborative evidence, Mr. Calof?
A. No. In deference to my clients, I have not.
Q. Can you tell me the names of any of the people who were
criminally convicted?
A. I'm sorry, I can't.
Q. Can you give me even one?
A. I'm sorry, I can't.
Q. Now, have you ever said that it is not rare for a polyfragmented
multiple to have a hundred or more alters?
A. That sounds like something I might have said.
Q. And how many polyfragmented multiples have you treated, Mr.
Calof?
A. I would guess less than ten.
Q. And in those ten cases, how did you determine that they had a
hundred or more alters?
A. By self-report.
Q. And how did you keep track of that? Did you map or count the
alters?
A. Not in that kind of case. In a case like that it really isn't
important to track that many. What you basically want to do is track
the more important ones, the ones that have more executive control
and more of a percentage of the ego function.
Q. Well, how long did it take you in therapy to ascertain that you
were dealing with a polyfragmented multiple with more than a hundred
alters?
A. Most of those people actually came through the door on referral
by other people, and that was already established by the time they
came through the door. In fact, I can't think of a single case where
that call was mine solely.
Q. Can you name any licensed health care providers, other than
yourself, in the state of Washington who have ever treated a
multiple personality disorder patient with more than a hundred
alters?
A. Where the privilege of confidentiality doesn't extend?
Q. Well, this has nothing to do with that because I'm not interested
in the name of the patient. I'm interested in the name of the
therapist.
A. Well, but I'm -- but there may be some that have a confidential
privilege with me that I'm not willing to specify.
Q. Well, as long as you don't say their name, it doesn't apply, Mr.
Calof. I'm interested in the numbers.
A. I don't know the numbers.
Q. Okay. Are you aware of any therapists throughout the United
States in your reading who have ever treated a polyfragmented
multiple who had more than a hundred alters?
A. Not by name.
Q. Well, other than Dr. Braun, for example, who has written quite a
bit about this, correct?
A. I don't know.
Q. Well, do you know of anyone who claims to have treated someone
with more than a hundred alter personalities in the United States of
America?
A. Many times to my professional audiences I've asked that question
by a show of hands, so I don't know names, but I've seen shows of
hands in my audiences that range anywhere from a quarter to a half.
Q. Can you give me the name of any licensed health care provider
practicing in the United States of America who has ever admitted in
public or on record -- any record -that they've treated an MPD
patient with more than a hundred alters?
A. I don't know.
Q. Now, you started treating MPDs in the mid-1970s, correct?
A. Correct.
Q. What kind of training did you have to do that?
A. At that point, my training was in hypnosis and dissociative
states.
Q. How many multiple personality disorders did you diagnose in the
1970s?
A. I'm guessing, but I would say probably around a handful.
Q. And how many multiple personality disorders had been diagnosed in
the world up until, let's say, 1980?
A. I have no idea.
Q. You have no idea at all?
A. I have no idea at all.
Q. Have you read anything about the history of the diagnosis of
multiple personality disorder?
A. Yes.
Q. Can you tell me anything about the theories of Dr. Morton Prince,
for example?
A. What would you like to know?
Q. What was his concept of an MPD?
A. His concept of an MPD?
Q. Yes.
A. I believe basically his point of view was that personality
fractures into coconsciousness.
Q. And what caused that fracture?
A. Some kind of demand.
Q. Did he think it was caused by abusive treatment in childhood?
A. I believe that was one of the factors.
Q. And how many alters did Morton Prince claim to have treated in
his lifetime?
A. I don't know.
Q. Have you seen any historical surveys of the numbers of MPDs
diagnosed in the U.S. or the world up until 1980?
A. I may have seen something like that, but I really don't recall
the substance.
Q. So do you have any idea of the numbers?
A. You're asking me if I know the numbers of alters that may have
been revealed in private therapy, and I have no way of knowing that.
Q. No, I'm asking you about the published literature.
A. In the published literature, I really don't know.
Q. Have you ever said that in your office alone you turn away one to
three cases Of MPD each day that you're unable to place for
appropriate treatment?
A. I believe I said that.
Q. Have you ever said that the therapy is very intense and labor
intensive, thus costly?
A. Yes, I believe I said that.
Q. Have you ever seen any studies indicating a relationship between
diagnosis of MPD and the richness of insurance policies?
A. I don't take insurance, and so I'm really not interested in that
area and haven't studied it.
Q. But you haven't seen anything like that in any of the -
A. No, it's not of interest to me.
Q. Have you ever said, quote, In the greater Seattle area, there are
probably fifteen to twenty people who are quite experienced in
treating MPD's?
A. Most likely.
Q. And who are those people?
A. I wrote that many years ago, so I'm going to think back to that
time frame.
Q. Okay.
A. I can name some of them. I don't think I can name them all. Some
of that was extrapolation based on the number of phone calls I had
received. I was thinking about Dr. Robert Olson, past president of
the Washington State Psychiatric Association; Dr. Lindsey -- I can't
remember his first name right now. I'm drawing a blank.
Q. Would John Laughlin be in that group?
A. I doubt I would have included him in -- well, I don't know when I
made that statement actually. I think he was certainly qualified to
treat it. I'm not sure if I was thinking about him at the time or
not, but it certainly wouldn't exclude him in terms of the criteria.
Q. Would Dr. Rice be in that group?
A. I don't know that I knew Dr. Rice when I made that statement.
Q. Well, this was published in '93. Did you know Dr. Rice in 1993?
A. Well, that was published in '93, but the interview had taken
place sometime before that.
Q. When did the interview take place?
A. I think it was a year and a half or two years prior to that.
Q. When you worked on this book with Mary Lee Lou, when she
completed the drafts of the book, did she show them to you?
A. Well, not completely. There was actually editing done by the
publishing house that unfortunately neither one of us had a chance
to review. I would just like to make a comment. Mr. Laughlin did not
live in the Seattle area.
Q. Okay.
A. So it would be hard to include him in that list.
Q. But you would consider him to be someone who was well trained to
treat -
A. I believe he was competent.
Q. -- MPDs? How about Dr. Rice? Based on your meetings with Dr.
Rice, do you think he was competent to treat MPD patients?
MS. WILLIAMS: I object. I don't think there's been testimony as to
when he met Dr. Rice in the context of when this interview took
place. What's the time frame of your question?
Q. [By Dr. Barden] During the time that you were meeting with Dr.
Rice, did you consider him competent to treat MPD patients?
MS. WILLIAMS: Object to the characterization of "meeting with Dr.
Rice."
A. During the time that Dr. Rice was attending the study group, I
had numerous reports about his competency from other clinicians, and
I took those at their face value.
Q. [By Dr. Barden] Are you aware of any peer-reviewed professional
journal treatment outcome research indicating that there's any
treatments shown to be
effective in treating multiple personality disorder?
A. I'm not aware of it because I don't think the question has
actually been posed by the groups who grant that designation.
Q. Have you ever stated this question and answer in your book:
Question: Do you believe people have to go back and remember and
experience their childhood abuse in its entirety to heal?
Answer: Most of it, yes. Some of the material will generalize.
Enough must be remembered so the denial lifts and the person accepts
what happened. Did they need to remember every day of their abuse,
three hundred sixty-five days a year over, say, twelve years?
Probably not, although I will tell you what I do. We do enough of
the work so that integration begins to happen and then people will
recover ever more memory over the years, even after integration.
Do you recall that question and answer?
A. I don't recall it specifically, but I believe I said that.
Q. How did you know these were memories the people were recovering?
A. In some cases, I had corroboration. I should also add that they
weren't necessarily characterized as memories in the therapy. My
position in therapy is to take neutrality with respect to that.
Q Do you feel that you took neutrality in your answer to this
question?
A. I don't think the concept of neutrality applies there. That's a
clinical concept.
Q. Is there any indication in here at all that you were the least
bit concerned about these alleged memories not being totally
accurate?
A. I don't believe the question of total accuracy has been raised.
Q. Do you have any peer-reviewed scientific evidence to support your
statement that "Enough must be remembered so the denial lifts and
the person accepts what happened"?
A. In terms of long-term psychotherapy, which is not necessarily
what I did in all of these cases, I believe that's the general
standard of care in the field.
Q. Yes, I'm looking for citations to peer-reviewed professional
journals.
A. I don't believe I can give you any.
Q. Now, when you said "the person accepts what happened," if you
don't know if their memories are real or not, Mr. Calof, then what
are they really accepting?
A. Their emotional reactions to their history, the cognitive effects
of it, their behavioral effects of it, their points of view.
Q. If that's true, if that was you're perspective, then why did you
say they have to accept "what happened" in your book?
A. I don't think that's inconsistent.
Q. Now, did you do trauma memory work in your therapy?
A. How would you define that?
Q. Well, have you ever used the term "trauma memory work" yourself?
A. I may have.
Q. How did you use that term? What does that term mean to you?
A. To me what it means is that the -- that what's called traumatic
memory -- and I must clarify that traumatic memory doesn't
necessarily refer to veridical truth, it refers to the way that the
client reacts to the memory -that that kind of memory intrudes into
therapy and into a person's life. Part of the goal of therapy is to
help them manage those intrusions.
Q. If you don't know if the memories are accurate or not, why do you
call them memories?
A. In some cases the clients characterized them that way.
Q. Yes, but my question is: Why do you in your book talk about
trauma memory?
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Grace will always be one phone call away from reconciliation or getting help.
We hope and pray for that day!
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*** WARNING ***
If you are seeking help for personal struggles and a therapist, counselor or friend says that "recovering childhood memories can help you get better" then IMMEDIATELY get up from your chair (or off the couch), run to the door, open it and flee. Hundreds of thousands have lost families, years of productive living and squandered immense wealth with tragedy inducing therapy that produces horrid false memories, splinters families, isolates the client and is documented to cause decline in mental health.
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This is an effort to Break the Cycle of Shame
and Save Others from Similar Tragedy!
RESEARCH ON MEMORY BASED THERAPY MEMORY EXPERTS COMMENTS BOOKS ON MEMORY BASED THERAPIES LEGAL CASES AND PRECEDENTS HARMFUL PRAYER MINISTRY PERSONAL "MEMORY HEALING" STORIES VIDEOS ON MEMORY BASED THERAPIES EXPERT LECTURES ON HARMFUL THERAPIES NEWS ON MEMORY BASED THERAPIES CLINICAL HEALING AND MEMORY
Grace and I while visiting family in New England OUR DAUGHTER BEFORE TREATMENT A SAD STORY OF HARMFUL THERAPY
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