Monday 9 November 2009

Munchausen's again

Well, I am certainly glad to find myself acquitted of the charge of dreaming up some connection between Munchausen's Syndrome by proxy and home education; I find that people have evidently been talking about this idea for years. Asking around, I have found a few home educators who feel that they have been suspected of this. Even the woman who sat next to me at the select committee was herself suspected by some professionals of having this syndrome a few years ago. She didn't, I hasten to add, have it at all. Most frequently, it seems to be with reference to ME and Chronic Fatigue Syndrome, as I surmised, but I have also found it associated with autism. All very curious. Actually, this shows Graham Badman in a rather better light. Instead of simply plucking the idea out of thin air, it suggests that he had actually been doing a bit of research. Mind you, as Julie said a few days ago, without knowing how he said it and exactly what was said, it is hard to know how serious he was being. I have certainly said things myself in exasperation such as, "I think some of these home educators must be absolutely mental!". Of course this has been said to my wife in the privacy of my own home; I would have thought twice about saying anything of the sort in front of a witness.

I don't suppose for a moment that Graham Badman meant to suggest that all home educating mothers suffered from this syndrome or even that it was a major factor in the decision to home educate. He is not a fool. The second meeting with Paula Rothermel took place after he had visited a home education group at which practically every child to whom he was introduced apparently had some special need or other. One was too gifted for school, another had ME, a couple were dyslectic, there was OCD, dyspraxia, ADHD and various other syndromes. I heard about this from one of the few mothers present who had home educated through simple choice. I can see that after meeting so many children described like this, he might have felt tempted to wonder what on earth was going on!

The main objection that people seem currently to be raising to the idea that there might be cases of Munchausen's by proxy among home educating mothers seems to be that the majority of home educators do not crave attention, which is usually seen as a defining factor of the syndrome. I am not so sure that this is a good argument. Often, the very act of withdrawing a child from school does attract attention to a mother. Attention from the school, from her family and friends, from the local authority, health services, sometimes even social workers. So although it may not be the only reason why parents take their kids out of school, it could still be a factor in some cases. I am not a huge fan of Paula Rothermel's research, as I said yesterday, but she did find that over a fifth of home educating parents have children whom they claim to have special educational needs.

In short, it should be quite clear now that I did not myself invent this idea of a connection between Munchausen's Syndrome and home education. I felt I had to nip that in the bud, otherwise I would find it being accepted as fact that Simon Webb told Graham Badman that home educators had Munchausen's! Without wishing to be unkind, I can't help noticing that the person who started this particular hare is not only on medication for anxiety, but has also self-diagnosed herself as suffering from dyslexia, dyspraxia and ADHD. More worryingly, she has apparently retrospectively diagnosed some of her grownup children as having had similar learning difficulties. I would have thought that such a person could hardly keep too quiet on the subject of Munchausen's syndrome by proxy; never mind accusing complete strangers of starting a scare about it! It is however an interesting notion and I would be keen to find out more. I certainly would not dismiss it out of hand as a contributing factor in some parents decision to de-register their child, but I would have to see an awful lot of convincing evidence in order to persuade me that it was a major cause of home education.

39 comments:

  1. It hardly seems fair to be labelled as potentially having MBP because we did something that makes other people talk about us! I'd much rather they didn't. I took my daughter for an eye test recently, and it was a wonderful experience - not because I got attention from the optition for HE, but because he asked if dd was HE, simply to assatain whether she would have problems seeing a whiteboard (she needs glasses) and asked only to help his diagnoses, no silly questions of odd reactions. It was a really refreshing experience and I loved the experience of having HE treated like the regular choice it is rather than something odd.

    We do get extra attention from medical and/or official types about HE, so maybe this could be good for MBP sufferers - they can get this attention they crave without any need to harm anybody. They can invite LA employees into their house and get their attention by showing them the results of their HE so far etc...

    I think it's a shame that people apparently think some of us HE because we have this syndrome, I know about 40ish HEing families, and I don't suspect anyone of having MBP... I did once think of a mother as putting a unearned label onto her child (if that's the right way to put it) but it turned out she was right, she was a non HEing mother btw.

    I'm not surprised that a HE group could turn out to have a lot of children with special needs in it. I think some people like to label their difficulties/differences, and there's no shortage of labels these days are there? Also it's our nature to copy each other, so once a few people within a group have analysed and labeled their children's difficulties and differences, the others might do that too if they haven't already. I would expect there to be more children who don't fit the average model in a HE group, maybe school is less suitable or more difficult for them.

    It might be kinder not to write about someone with anxiety etc. on a blog like this, especially if they might read it and know it's about them.

    "More worryingly, she has apparently retrospectively diagnosed some of her grownup children as having had similar learning difficulties"

    I'm not sure what's worrying about this, what harm can it do? It sounds like someone reflecting back rather than projecting imagined things onto children. Are you thinking that the adult children might be harmed by their mother reflecting on their childhood and thinking that they've had/ still have an undiagnosed learning difficulty?

    I think I owe you a reply on an earlier thread, I wrote one, compy crashed and lost it, and then I went away for a few days, sorry about that.

    Bws,
    Fiona M

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  2. How come you are so ready to question the existence of such 'vague' conditions as ASD, ADHD etc, Simon, but do not appear to apply the same scepticism to the equally alphabetical MSBP, when the practitioner who first identified it, and a leading expert in it, have both had serious criticisms levelled at their professional conduct in relation to it?

    Let's imagine that a child with nystagmus, say, or malfunctioning stapedial acoustic reflex (neither of which is looked for in auditory or visual screening tests) is in school. Both abnormalities would be expected to impact on the child's ability to learn and cope adequately with the school environment. But because neither the mother, nor the GP nor the school is aware of the problems, and would have great difficulty finding someone to identify them if they were, one could easily draw the erroneous assumption that there was nothing 'wrong' with the child and the mother's anxiety was misplaced.

    There. You've found out more.

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  3. I was wondering about the validity of MBP too, but the only case I've read about is that of the Holt family, they were used in a study of SIDS (Sudden infant death syndrome, or cot death), to prove a genetic factor in SIDS. It later transpired that the mother had been harming her children, she was said to have had MBP, and the reserach was discredited.

    I'm not sure what to make of the case, because it's now transpired that SIDS may well have a genectic factor, and I only read the one account of it. I might look it up ...

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  4. There is indeed a huge question mark over the very existence of Munchausen't by proxy, suzyg. Who can forget Roy Meadowes and his famous court cases? It's just that I have been surprised to see that something of which I was quite unaware a week ago is apparently commoner than I thought.(That is the suspicion of Munchausen's, not the actual thing).

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  5. Fiona M, the reason that I was interested in the behaviour and thoughts of the person I mentioned was because she made these weird suggestions about me! Here is what she said;

    "And considering it was probably him who told Badman that Paula Rothermel's
    work was not sound I think he has an immense amount to answer for. Wouldn't
    be surprised if this wasn't the source of the Munchausens fiasco too."

    In those circumstances, I think it quite fair to ask myself why the person concerned seems keen to spread some sort of rumour about Minchausen's in connection with me in this way. That is why I found her own conduct interesting. I did not say anything that she has not herself posted on public sites, so I don't think I am betraying any confidences. As Suzyg has pointed out, this syndrome may not even exist. I am more interested in the fact that until a few days ago I had never heard of it being connected with home education and that now I am asking around and looking into it, I find that there has been a tenuous association for a while. I am just surprised that I have not heard about this before.

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  6. Simon, you really are incredibly touchy. Any statement beginning with "I would not be surprised if.." isn't really something most other people take seriously.

    Also, regarding Graham Badman's apparent experience of meeting lots of mothers with SEN children at a meeting, I would say it depends on how the subject is introduced. "Why did you withdraw your child from school?" quite often leads onto: "Well, he/she had this SEN and the school couldn't deal with it, so my child got very distressed and I had to withdraw him/her."

    This is an extremely common occurrence due to our rubbish state school system, not due to home educating mothers having MBP, although MBP is a typical male explanation for the kind of mother love that would just remove a child in distress from school and stay home with it, rather than persevering with school at the expense of the child's happiness.

    MBP is such a heavily loaded suggestion though, even to make in jest or exasperation. It's always going to have repercussions because of its history and the way it's acted on by professionals.

    Think about it: the mother is being accused of actually harming her child in order to get attention for herself. If it exists, it's a seriously damaging mental illness and therefore children must be removed from any mother found to be suffering from it. The diagnosis itself is an arbitrary process.

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  7. No, I don't think that I am incredibly touchy. I have just seen how stupid stories spread in the home education world unless steps are taken early to stamp on them. I am open minded about the existence of this form of Munchausen's. I can certainly see how an anxious mother might persuade herself that her child is not able to cope with school due to the nature of her difficulties. I can then see that a very neurotic parent might decide to withdraw her child from school on that account. This is of course a long way from Munchausen's which is, as you say, a serious illness, if indeed it exists at all. We really don't know what, if anything, was said on the subject by Graham Badman.

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  8. OK. It's just that, with respect, I'm struggling to see how anyone could take seriously the idea that you had any influence over Graham Badman's thinking in the conduct of his review.

    "I can certainly see how an anxious mother might persuade herself that her child is not able to cope with school due to the nature of her difficulties. I can then see that a very neurotic parent might decide to withdraw her child from school on that account."

    Can you also see how a loving mother might persuade herself that her child is not able to cope with school due to the nature of his/her inability to sleep or eat, constant crying, begging not to be sent, suicide attempts, or self-harming? All of these effects of school problems, usually in combination, have been reported. Or is it just the neurotic parent that you can see?

    Also, why should the removal of a child from school for any reason be circumspect or require investigation, any more than the decision to home educate from scratch because you think you can teach them better? Both dodgy decisions, from the point of view of certain mindsets. Where do you draw the line?

    Answer: you don't. Home education is a legal option and the reasons for it shouldn't be questioned.

    "This is of course a long way from Munchausen's which is, as you say, a serious illness, if indeed it exists at all."

    Indeed. And if even you can see that, Graham Badman should have said nothing on the matter.

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  9. The suspicion of MSBP provides hard-pressed staff in education, social services and healthcare with a convenient way of avoiding taking responsibilty for failing to address 'too hard to do' cases. They probably don't even do this knowingly.

    In my daughter's case, what was required was a systematic elimination of the most likely causes for her illness. Not rocket science. But not within the scope of the PCT, it seemed. FII (aka MSBP) was a much neater and cheaper diagnosis, and could be arrived at by an EWO without any medical training whatsoever. No need to bother a consultant to go through all those complicated and expensive blood tests.

    FII is alive and well and permeating many official publications relating to child maltreatment, just as, presumably, satanic abuse was a couple of decades ago.

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  10. You can be no more puzzled than I am at the idea that Graham Badman would be taking my advice about the direction his review was to go! That is why I was so staggered to see Maire Stafford making the suggestion. In fact she said that I was "probably" the one who trashed Paual Rothemel's research to him. Weird.

    I do not know whether Graham Badman did say anything at all about Munchausen's. There is very little evidence for this. As I have said before, if he did it is strange that we have only recently learnt of it. A mother pulling her kid from school becuase of real or imagined helath problems or psychological difficulties is worth looking at, if only to see whether or not with proper support she would not need to take such a serious step.

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  11. "That is why I was so staggered to see Maire Stafford making the suggestion. In fact she said that I was "probably" the one who trashed Paual Rothemel's research to him. Weird."

    Weird, but understandable from a community that feels itself to be under attack, and is exhibiting all of the likely stresses and strains of that position. I suggest you don't rise to it, because it makes you look quite neurotic when you do, if you don't mind me saying so.

    "I do not know whether Graham Badman did say anything at all about Munchausen's."

    But Paula says he did, so he must have.

    "There is very little evidence for this."

    On the contrary, there is Paula's written evidence to the Select Committee inquiry: all the evidence we could need.

    "As I have said before, if he did it is strange that we have only recently learnt of it."

    Perhaps she just hasn't been asked. One of her other points mentioned that she hadn't even been officially told about the inquiry.

    " A mother pulling her kid from school becuase of real or imagined helath problems or psychological difficulties is worth looking at, if only to see whether or not with proper support she would not need to take such a serious step."

    SEN aren't necessarily health problems. Also, isn't a father pulling his kid out of school worth looking at? Also, it's an equally serious step for a person to choose not to send their child to school in the first place, so by that token, we're all 'worth looking at'.

    No thank you. I do not wish to live in a zoo.

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  12. Yes, I know that, and I feel the same about it. Now I've seen the quote I feel a little bit sorry for the author, they haven't said it was you at all, only that they wouldn't be surprised if it were, e.g. that s/he thinks that's something you might say. I'm not sure I'd post that sort of thing on a public site though, I'd assumed it was posted as part of a conversation on a HE support list.

    I wonder if talk of people who self-diagnose; reflect about themselves/their children and research learning difficulties etc. having M/MBP has made those people feel attacked. If we research something and find it applies to us, it must be really shocking to then feel - or even actually be - under suspicion of having a mental disorder which is about harming oursleves or other people.

    As to why the whole MBP thinkg has been linked to you, I can't help there! I don't know the whole story of whatever is going on with you and the HE community, maybe people think that you support the goverment's campaign to put their own ideas of education onto the whole population - rather than just their own family like regular people! It seems that they worry tha government employees will quote things you say and say, look home educators like what we're doing...

    Bws,
    Fiona M

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  13. Paula Rothemel's written evidence is not really all that reliable. In it, she says that Graham Badman began doubting the worth of her research as a result of something a "lay" person had told him. A few months ago she was attributing his change of mind to other academics who were deingrating her work. This suggests to me that we should treat would she says in the submission with some caution. It is clear that she was tailoring what she said in it to suit the audience. As I have remarked elswhere, she is in regular contact with Mike Fortune-Wood. I would have expected her to mention this Munchausen's business back in the Spring if something really was said by Graham badman. It would after all have been a perfect weapon to use against him and an indication of his lack of impartiality. There is something fishy about this whole Munchausen's/Graham Badman thing. I talked about mothers pulling their kids out of school rather than fathers, because most home educating parents are mothers.

    As for my appearing neurotic, well there are worse things that one can seem to be!

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  14. So basically, you're calling Paula a liar, Simon? Not only that, but you're accusing her of having lied to a Commons Select Committee? If that's not true, it's a wee bit libelous, don't you think?

    "There is something fishy about this whole Munchausen's/Graham Badman thing."

    Yes there is, but I don't think the fishy smell is coming from Paula Rothermel.

    "As for my appearing neurotic, well there are worse things that one can seem to be!"

    Are there? If you're labeled 'neurotic' then all of your decisions, your parenting, everything is open to question. In fact, isn't being labeled 'neurotic' what this is all about?

    It disturbs me that you - and here I do see similarities with Graham Badman - seem to naturally fall on the side of criticism, negative judgment and mistrust in considering the position and decisions of many home educators.

    Why not work from the basis of benign, rather than malign intent in the first place? Parental instinct/input being a beneficial thing for children and all.

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  15. Who is telling the truth?

    Probably they both are, their truth.

    "The Truth" to a single person is only ever their perspective of events that is influenced over the passage of time and subsequent events.

    One might underplay the significance of a comment, the other overplay it, but neither of them are necessarily lying, just telling the truth as they see it.

    A human that is able to channel Dr. Spock (star trek version) and manage accurate, uninfluenced, total recall is a rare thing indeed.

    I think he probably over reacted to his meetings with p-off HEing parents and overstated things by pulling MBP out of the bag and I think initially she kept it to herself in the form of "making allowances/cutting slack/building bridges/trying to get him onside" but since then has felt let down or daft because that postion was not recipriocated so she over reacted to it in retropect.


    There is a quick way to find out if there is a solid basis for a concern when it comes to such a specific condition, who are the leading experts on MBP? HE is done by not inconsiderable numbers of parents, have they flagged up a disproportionate number of suspected cases in HEed kids compared to "In School" kids via hospital and doctor's records, social services data and family court outocmes ?

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  16. The 'leading experts' on MBP, Roy Meadows and David Southall, have both got into very hot water over it. Another reason to be cautious about bandying such terms about.

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  17. "The 'leading experts' on MBP, Roy Meadows and David Southall, have both got into very hot water over it."

    Yeah, I heard there was some more recent controversy, to do with the stats used against mums who lost babies to SIDS wasn't it ?

    Still, I used homeschool+MBP as a search string and I couldn't find a solid body of work that inferred there was some concern in the medical community that it might be more prevalent in the HE community. Which is what you would expect BEFORE it hit the lay community if there was anything to support the idea.

    Maybe what has happened is that since HEing parents seem to be making "odd" choices they must be "odd" and "odd" people have PDs and since for the layman (thanks to medical shows like Casualty, ER etc) MBP is a well known PD that involves the maternal/child dynamic lots of conclusions are leapt to as the 2+2 makes 7,000,893,987,222 process whips into action.

    I am now off to google PDs+homeschool and see if there is anything out there that suggests we are "odd" in a very specific medical way ...or not.

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  18. Well apart from the fact that Sarah Palin might have one based on the evidence that she planned to be VP and HS...based on a lack of evidence to the contrary, we are mainly just boring old "odd" rather than "here is your diagnosis, check into the locked ward on the left" sort of "odd".

    I leave others to goggle further, I have to go and disperse a posse of pilgrims who are making my dogs bark by peering hopefully through my gate, trust me by the time the exchange is over they will be the ones calling me mad despite the fact THEY are the ones wandering around aimlessly in the middle of nowhere after 1000 K drive looking for "miracle water".

    Mental health issues in others, it is all very relative.

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  19. Anonymous said;

    "So basically, you're calling Paula a liar, Simon?"

    No, I am not calling her a liar. I am saying that there are quite a few discrepancies between what she said in her submission to the select committee and what she said shortly after the meetings with Graham Badman. For example, a few weeks after the second meeting, she told me that there had been "bitching" about her by "other academics" denigrating her work. In the submission to the select committee, she says that he was influenced by a "lay person". She gives this as grounds for questioning his suitability to be in charge of the review; the fact that he would allow a lay person to give hima negative view of her work. Both statements cannot be true.

    There are however other explanations besides telling lies. People get muddled up, they make mistakes, they forget things. Why are you so keen to introduce the word "lie" into the matter? If I am libelling anybody, that is my own affair. Another curious point is that in the submission to the select committee, at the first meeting Graham Badman kicked off by asking about Munchausen's. Paula was obliged to tick him off and remind him that she had no medical qualification. All very prickly. Yet a few weeks after this meeting, she said they got on very well together. Are the notes of this meeting available anywhere? I am bound to say that I am puzzled as to why we have not heard about this Munchausen's thing from Graham Badman before this.

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  20. So, Paula told you that there had been "bitching" about her by "other academics" denigrating her work. In the submission to the select committee, she says that he was influenced by a "lay person".

    "She gives this as grounds for questioning his suitability to be in charge of the review; the fact that he would allow a lay person to give hima negative view of her work. Both statements cannot be true."

    Why not?

    "There are however other explanations besides telling lies. People get muddled up, they make mistakes, they forget things."

    So, she was muddled up, mistaken or forgetful about Graham Badman asking her whether she thought home educating mothers were suffering from MSP? I don't think so. It's not the kind of thing a person would be muddled up, mistaken or forgetful about, is it?

    "Why are you so keen to introduce the word "lie" into the matter?"

    Just calling a spade a spade.

    "If I am libelling anybody, that is my own affair."

    True. I just thought perhaps you hadn't realised.

    "Another curious point is that in the submission to the select committee, at the first meeting Graham Badman kicked off by asking about Munchausen's. Paula was obliged to tick him off and remind him that she had no medical qualification. All very prickly. Yet a few weeks after this meeting, she said they got on very well together."

    ........ Nope. I'm not following your train of logic here either. None of that makes Paula a liar, or puts her evidence into question. You seem to be clutching at straws a bit, in your attempts to discredit her.

    "Are the notes of this meeting available anywhere? I am bound to say that I am puzzled as to why we have not heard about this Munchausen's thing from Graham Badman before this."

    Well perhaps, having run his musings past a few academics like Paula and seen their incredulous reaction, he realised that it wouldn't go down very well with the rest of us?

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  21. Well now, I probably have not made myself clear. Let us look at the submission which Paula Rothermel made to the select committee;

    " At our first interview Mr Badman was interested in what I had to say. His opening question was to ask me if home educating mothers suffered from Munchhausen's by Proxy. I thought this to be a curious starting point - that of questioning whether home education is a symptom of mental illness. I am not medically qualified, but I was able to inform Mr Badman that there is no research evidence available that I am aware of, which makes this link.
    4. At our second interview Mr Badman was dismissive of my work. He insisted that my study covered just 30 children. He indicated that someone had told him this and insisted that my conclusions and findings, therefore, were of little significance. Nothing I could say would sway him from this view. He had clearly not informed himself about my work by reading it.
    5. I consider the review to be seriously flawed. It should be a matter of concern to the Select Committee that the person commissioned to carry out the review could so easily be influenced by a lay person hostile to my work. I question the rigour applied to the Review."

    This is obviously an attempt to put Graham Badman into a bad light. Graham Badman was "easily influenced" by "a lay person hostile to my work". Who is this mysterious "lay person"? How does Paula Rothermel know that it was a lay person and not one of those academics who are denigrating her work? We are not told. Did Graham Badman identify the person who had told him about the work? If he had and it was definitely a lay person, then I should have expected Paula Rothermel to be a little more specific. This in itself is odd. The reasons that I am curious about the notes from the meeting is that they would presumably have been taken at the time and make mention of Munchausen's Syndrome.

    During the review, people were grabbing at any opportunity to present Graham Badman in a bad light. Everything he said was examined carefully for any sign of bias. Now here is a gift from the Gods. The man is accusing home educating mothers of being mentally ill! And yet we have not heard a word about it until the submissions to the select committee are made public. As I say, I have had dealings with Paula Rothermel on this subject and I know a number of other people who have also discussed with her what was said when she saw Badman. She was a bit pissed off not to be invited on to the expert group, there was every opportunity to expose him for this odd idea about Munchausen's. Yet nothing at all. Has anybody heard anything about this before the select committee published these submissions? You are quite wrong about my clutching at straws to discredit Paual Rothermel. I just feel in my bones that there is something funny about this and I am really wondering what it is!

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  22. "Well now, I probably have not made myself clear."

    No no, I think you did. I understand quite well that you're trying to suggest that Paula was perhaps acting vindictively in mentioning the MSP quote, or doesn't know her own mind, though I observe that you are now stopping short of accusing her of lying, presumably because of the issue of libel.

    Personally, and notwithstanding anything you've said, the facts of which I don't dispute, I believe Paula Rothermel told the truth in her Select Committee evidence. Her reasons for doing so, or for waiting for so long, are neither here nor there.

    Graham Badman either asked her that question about MSP or he didn't. I think he did, because I don't believe Paula Rothermel would lie about it, and I notice Graham Badman himself has not denied it.

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  23. I am open minded about the possibility of lying, although the balance of probabilities is perhaps against it. How it was said and in what context is another matter entirely. I am hardly going to stop short of accusing somebody of lying, simply out of fear of libel! I don't know Paula Rothrmel well enough to accuse her of lying, although it would be surprising if, like most of us, she did not do so from time to time. As for acting vindictively, yes there is certainly evidence for that. The claim that Graham Badman was not suitable to head the review because he did not take her research seriously due to listening to some "lay person", is a vindictive attempt to bring him into disrepute. This is definitely so, because as I said Paula Rothermel really attributed his change of heart on the subject to other academics rather than a "lay person". The tone of the first meeting with him is presented in quite a different light from what she ws saying at the time. In the submission made in September, the feeling is that Badman started off by talking about Munchausen's and Paual Rothermel was taken aback. A few weeks after the meeting she was, as I said above, saying she got on very well with him. So yes, the submission has certainly been coloured to give particular emphasis to some things and leave others out entirely. This is probably because she was pissed off with him and decided to get her own back by slagging him off to the select committee.

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  24. I really think this is an utterly pointless discussion. It's all about what Simon says Paula said, and unless we hear from Paula herself about what she actually said we will never know. It looks as if Simon is trying to discredit Paula by implication, first by speculating that she might have been responsible for bringing Tasmania to Badman's attention, and now by accusing her of vindictively trying to bring him into disrepute. It's just another attempt on Simon's part to drive a wedge between us. Ridiculous.

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  25. Actually, both the posts I have put up on this subject accept that Graham Badman said something sbout Munchausen's. Reading through them, I can't see how they would be designed to discredit Paual Rothermel. People in these comments keep leaping in though and talking about lying and so on. My own feeling is that there is a bit more to this business than meets the eye. Re-red the posts and see if you really think that they are intended to smear Paual Rothermel. She is hardly mentioned.

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  26. Come on, Simon. Read these comments again, particularly yours. They're all about Paula.

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  27. Paula Rothermel is not mentioned at all in the original post. Other people kept bringing her name into the subject and so I responded. I have no idea at all what was and was not said to her about Munchausen's. I have said that it is in open question. I hardly think that this is an attempt to discredit her; more a statement of fact.

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