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Case 1:20-cr-00330-PAE Document 424-3 Filed 11/08/21 Page 4 of 29 98 J. Engle and W. O'Donohbue that lack clear corroborating evidence, an understanding of pathways to false allegations may be useful to help determine the accuracy of the claims. Binder and McNeil (2007) presented several civil cases in which the alleged perpetrator of sexual assault and/or boundary violations completely denied all wrongdoing, and there was no corroborating evidence to help verify the claims of either party. The authors contended that in cases such as these, carefully administered and interpreted psychological evaluations may provide a context for allegations by allowing the court to understand personality traits, personality disorders, cognitive disability, and psychotic symptoms that may affect the alleged victim’s allegations. Certain psycho- logical processes have in past cases explained the lack of corroborating accounts between a plaintiff and a defendant. Some relevant psychologi- cal processes that have been suggested are psychosis, hypersensitivity when interacting with others, tendency toward exaggeration, and serious cognitive problems (Binder & McNeil). The authors also suggested that there may be several additional psychological markers to consider when determining the credibility of a complaint. We believe that a more thorough identification of these pathways is important and can be partly achieved by understanding the role of psychological disorders, as currently specified by the Diagnostic and Statistical Manual (DSM-IV-TR; American Psychiatric Association, 2000), in explicating specific motivations and cognitive distortions that may be associated with false allegations and malingering behaviors. Some of these variables may interact in a complex manner. For instance, an individual with borderline personality may place herself in riskier situations and may, therefore, have an increased risk of actual sexual assault. Conversely, as we discuss below, the individual with borderline personality disorder may also suffer from certain key cognitive distortions that lead to false reports. We caution against a simplistic reading of this analysis in that it never is the case that because a person suffers from a certain diagnosis that her alle- gations are, therefore, false. In addition, it can be useful for the forensic mental health professional to understand these pathways in context with the alleged perpetrator’s mental health status. Again, no diagnosis would mean that the perpetrator is guilty of the accusations; however, mental health professionals can offer expertise in helping to understand the path- ways to false allegations and false denials. Part of the focus of the present paper, then, is to bring attention to the dearth of psychological literature investigating correlates and causal mechanisms of false allegations of sexual assault and to propose a model specifying the major causal pathways to false allegations. These pathways are intended as a model for further empirical investigation. Therefore, a legitimate concern about enumerating such pathways is the misuse of psychological diagnoses in determining the accuracy of specific accusations. It is important to recognize that a model that comprehensively and accurately identifies pathways provides information regarding necessary DOJ-OGR- 00006272