"For more than a century, scientific investigators and clinicians have noted the potential for memory distortions associated with hypnosis. Moll, a noted nineteenth-century authority, commented that "Retroactive hallucinations are of great importance in law. They can be used to falsify testimony. People can be made to believe that they have witnessed certain scenes, or even crimes." (Moll 1889/1958, pp. 345-346). The pioneer hypnosis practitioner, Bernheim, observed, "I have shown how a false memory can cause false testimony given in good faith, and how examining magistrates can unwittingly cause false testimony by suggestion" (Bernheim, 1891/1980, p. 92). Similar findings have been observed by later legal commentators, as will be noted in the following discussion."