Anytime you work with memory using hypnosis you can and do plant false memories whether it is going back five lifetimes ago or dealing with something that happened just before you put yourself under hypnosis. It is a common side effect even when professionals use it and Loftus (second article below) is an expert in dealing with it.
There is even a false Memory Foundation.
Here are some articles on it.
September 1997, vol 277 #3
Creating False Memories
In 1986 Nadean Cool, a nurse's aide in Wisconsin, sought therapy from a
psychiatrist to help her cope with her reaction to a traumatic event experienced
by her daughter. During therapy, the psychiatrist used hypnosis and other
suggestive techniques to dig out buried memories of abuse that Cool herself had
allegedly experienced. In the process, Cool became convinced that she had
repressed memories of having been in a satanic cult, of eating babies, of being
raped, of having sex with animals and of being forced to watch the murder of her
eight-year-old friend. She came to believe that she had more than 120
personalities-children, adults, angels and even a duck-all because, Cool was
told, she had experienced severe childhood sexua| and physical abuse. The
psychiatrist also performed exorcisms on her, one of which lasted for five hours
and included the sprinkling of holy water and screams for Satan to leave Cool's
When Cool finally realized that false memories had been planted, she sued the psychiatrist for malpractice. In March 1997, after five weeks of trial, her case was settled out of court for $2.4 million. Nadean Cool is not the only patient to develop false memories as a result of questionable therapy. In Missouri in 1992 a church counselor helped Beth Rutherford to remember during therapy that her father, a clergyman, had regularly raped her between the ages of seven and 14 and that her mother sometimes helped him by holding her down. Under her therapist's guidance, Rutherford developed memories of her father twice impregnating her and forcing her to abort the fetus herself with a coat hanger.The father had to resign from his post as a clergyman when the allegations were made public. Later medical examination of the daughter revealed, however, that she was still a virgin at age 22 and had never been pregnant. The daughter sued the therapist and received a $1-million settlement in 1996.
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