a lack of evidence to support the accuracy of memories recovered in this way. In 2004, the government of the Health Council of the Netherlands issued a report in response to inquiries from professionals regarding RMT and memories of traumatic child sexual abuse. The Health Council stated that while traumatic childhood experiences were major risk factors for psychological problems in adulthood, the fact that most traumatic memories are well-remembered but can be forgotten or become inaccessible though the influence of specific circumstances precludes a simple description of the relationship between memory and trauma. The report also notes that memories can be confabulated, re-interpreted and even apparently vivid or dramatic memories can be false, a risk that is increased when therapists use suggestive techniques, attempt to link symptoms to past trauma, with certain patients and through the use of methods to stimulate memories. The Australian Hypnotherapists Association (AHA) issued a similar statement, for contexts where false memories of child sexual abuse may arise. The AHA acknowledges that child sexual abuse is serious, damaging and at least some memories are genuine, while cautioning that some questioning techniques and interventions may lead to illusory memories leading to false beliefs about abuse. The Canadian Psychological Association has issued guidelines for psychologists addressing recovered memories. Psychologists are urged to be aware of their limitations in knowledge and training regarding memory, trauma and development and "that there is no constellation of symptoms which is diagnostic of child sexual abuse". The guidelines also urge caution and awareness of the benefits and limitations of "relaxation, hypnosis, guided imagery, free associations, inner child exercises, age regression, body memory interpretation, body massage, dream interpretation, and the use of projective techniques" and special caution regarding any legal involvement of memories, abuse and therapy. Legal issues In Ramona v. Isabella, Gary Ramona sued his daughter's therapist for implanting false memories of his abuse of her. In the first case putting recovered memory therapy, itself, on trial, he eventually was awarded $500,000 in 1994. Discussing RMT in the New South Wales Parliament in 1995, the state Minister for Health, Andrew Refshauge – a medical practitioner – stated that the general issue of admissibility of evidence based on recovered memories was one for the Attorney General. In 2004 Australian Counselling Association issued a draft position statement regarding recovered memories in which it informed its membership of possible legal difficulties if they affirm accusations as