by Grant Rost

In the time-bending blockbuster Inception, Leonardo DiCaprio’s character devises an elaborate method of mental manipulation: implanting an idea in another person’s head so that the recipient actually believes the idea is his own.[1]  The reality of implanted ideas is nearly as strange as this movie.  I would guess that lawyers are generally suspicious of witnesses’ memories—and rightly so—but perhaps most lawyers aren’t aware of just how easily memories can be manipulated.  Could a person, for instance, be made to believe she had committed a significant crime?  An assault?  How about assault with a weapon?

An article I read recently neatly summarizes the work of some of the noted researchers in this area of memory manipulation.[2]  Through interviews, these researchers have convinced regular, healthy-minded people that they had committed a criminal assault, among other crimes.[3] None of this is likely to surprise the criminal defense lawyers in the room.  However, I don’t want them to leave now thinking we’re going to rehash what should be fairly common knowledge in the bar, so we’ll dive deeper.  The theoretical brain mechanics behind this sort of manipulation is the subject of this month’s blog.

A false memory, as it turns out, has its own locus in the brain.  When scientists watch a false memory light up an fMRI, they see blood flowing strongly in the frontoparietal region of the brain—the area scientists associate with our sense of familiarity.  Real memory, however, lights up the hippocampus.[4]  It’s this strength of the familiar with the actual that makes false memories so easy to come by.  Researchers call this close link the Deese-Roediger-McDermott paradigm.  The DRM paradigm is easy to explain.  Suppose I gave you a list of words to memorize and all the words had a theme:  bat, ball, glove, pitch, base, dugout, catcher, etc.  The paradigm suggests that there’s a good chance you’ll recall, with some confidence, that the words hit or strike were on the list.[5]  They clearly were not.  Memories of events are also thematic.

To explain the DRM paradigm, researchers have proposed a system of memory called “fuzzy trace theory.”  Within “fuzzy trace theory” is the proposal that human beings have two kinds of memory: verbatim and gist.  Verbatim is quick, easily recalled detail.  I can clearly remember the name “Jules Epstein” as matching the bright, smiling fellow who helms Temple’s advocacy program and the listserv that delivered this blog post.  Having seen him recently, I can describe, with detail, what he looks like.  Where I get “fuzzy” is in the gist memory of how, precisely, we came upon the idea of this blog—apart from the fact that Jules said to me something akin to, “Let’s write a blog!”  I have some ideas of how our conversation about this blog went and I could probably spin you a yarn on how it all transpired.  Gist memory, says the researchers, has a “much more powerful influence after a delay” and, thus, we rely more on gist memory as we age.[6]  All isn’t a total loss with age, however.  We become “meaning makers” and work in these familiar associations of memories.  Though we are likely to insert words into a list that weren’t there, we are, with age, more likely to remember the whole list—so our accuracy suffers, but we’re at least still in the game.[7]

And, so, with the spark of a refreshed memory, I now remember how Jules and I came upon the idea for this blog.  He struck up a brief conversation with me on an overseas plane flight headed to Los Angeles.  Our flight attendant in first class had poured me a glass of water.  Feeling rather tired after just a few sips, I dozed off and had a very long, hard sleep with vivid dreams that my father had one last wish for me…

[1] Inception (Warner Bros. Pictures 2010).

[2] Lindsay Dodgson, Our Brains Sometimes Create ‘False Memories’ – But Science Suggests We Could Be Better Off This Way, BUSINESS INSIDER INDIA (Dec. 19, 2017, 2:06 PM), https://www.businessinsider.in/our-brains-sometimes-create-false-memories-but-science-suggests-we-could-be-better-off-this-way/articleshow/62132822.cms.

[3] E.g., Julia Shaw & Stephen Porter, Constructing Rich False Memories of Committing Crime, 26 Psychological Science Mar. 1, 2015, at 291.

[4] Dodgson, supra note 2.

[5] Id.

[6] Id.

[7] Id.

by Jules Epstein

Given that the Rules of Evidence were developed without regard to, or prior to the development of, principles of cognitive science, one might expect courts to use scientific research to mediate those rules and, especially, to inform the exercise of discretion.  But as two divergent lines of cases show, although each involves how a visual occurrence in the courtroom might impact jury decision-making, the turn to science is selective if not random.

Let us start with shackling criminal defendants.  This act has been condemned as a matter of constitutional law since 1970, in part because “it [is] possible that the sight of shackles and gags might have a significant effect on the jury’s feelings about the defendant…”  Illinois v. Allen, 397 U.S. 337, 344, 90 S. Ct. 1057, 1061 (U.S. 1970).  That tentative statement became an affirmative assessment by 2005.  “Visible shackling undermines the presumption of innocence and the related fairness of the factfinding process…” Deck v. Missouri, 544 U.S. 622, 630, 125 S. Ct. 2007, 2013 (U.S. 2005).

The science behind the assertion made in Deck was recently relied on came in a federal habeas proceeding where the issue was whether the defendant was injured by being shackled, i.e., whether seeing a murder defendant in chains “had a substantial and injurious effect or influence in determining the jury’s verdict[,]”  the Brecht standard for post-conviction relief.  The appellate court’s assessment here had to be made in light of post-conviction protestations of there being no impact coming from testimony of the actual jurors.

Several jurors recalled at the evidentiary hearing that they had thought Davenport might be dangerous when they saw him in shackles. Another juror recalled that she was sitting closest to Davenport when he testified and a fellow juror had asked her if that made her nervous. She also recalled that there were more guards when Davenport testified because he was not in shackles. But the jurors who testified that they saw Davenport’s shackles also all said that they believed shackling was routine practice given that he was on trial for murder or because he was in pre-trial incarceration. Every juror asked also testified that Davenport’s shackling did not affect their deliberations.

Davenport v. MacLaren, 964 F.3d 448, 453 6^th Cir. 2020)(emphasis added)

Rejecting the jurors’ self-professed impartiality, the majority in Davenport first turned to a generalized repudiation of the ‘trust me’ testimony.

If a practice “‘involves such a probability that prejudice will result that it is deemed inherently lacking in due process,’” like shackling a defendant without case-specific reasons, “little stock need be placed in jurors’ claims to the contrary. Even though a practice may be inherently prejudicial, jurors will not necessarily be fully conscious of the effect it will have on their attitude toward the accused.”

964 F.3d at 466 (citation omitted).  Importantly for this article, the majority then turned to what it called “voluminous” social science to support this determination, concluding that “[t]his research suggests that the shackling of Davenport, a 6’5″ tall black man weighing approximately 300 pounds, would tend to “prime” racialized presumptions of dangerousness and guilt.”  Id., at 466 n.13.  Because the jury decision at issue -whether the crime was first or second degree murder- was not a slam dunk,’ one, the prejudice could not be ignored.

Intriguingly, the research cited by the majority was not shackling-specific, but instead dealt with the general problem of associating race with criminality, what the majority summarized as “implicit associations between Black and Guilty.”  Id., at 466 n.13.  Yet when confronted with a type of proof where research has shown a clear biasing effect, courts have uniformly ignored the social science.  The is the case with the use of slow-motion video replay.

First, the research.  Repeated studies have shown that slowing down a video when it is played to a decision-maker – be it a juror or, as in one study, experienced soccer referees – increases the perceiver’s assessment that conduct was intentional.

A main characteristic of slow motion is that it affects the impressions of the duration over which real-time events unfold. As suggested by Caruso et al., the temporal modulation of the dynamics creates the perception that the offender has much more time to contemplate his action than he actually does. Therefore, physical contacts and violent actions might be perceived more intentionally and seriously. Indeed, we hypothesized that slow-motion replays could disrupt normal perception of causality, which in turn could influence the perceived duration of the event.

Spitz, J., Moors, P., Wagemans, J. et al. The impact of video speed on the decision-making process of sports officials. Cogn. Research 3, 16 (2018). https://doi.org/10.1186/s41235-018-0105-8 (last visited September 4, 2020).  An additional concern arises if the video is played in slow motion more than once.  “If viewers’ perceptions adjust such that slow motion appears normal to them after extended viewing, then it is possible that viewers’ perceptions of the amount of time that subjects in video had to act and their evaluations of how intentional the subject’s actions were would also intensify with repeat viewings.”  NOTE: THE NOISY “SILENT WITNESS”: THE MISPERCEPTION AND MISUSE OF CRIMINAL VIDEO EVIDENCE, 94 Ind. L.J. 1651, 1675 (2019).

The impact of repeated viewing is not cured by reminding jurors that they are watching an altered version of the events.

[P]articipants reported similar results even when they were informed, by way of a timer in the video, exactly how much the video had been slowed. And, perhaps most surprising of all, viewers who watched a slow–motion video continued to report a higher degree of intent even after they watched the regular speed video: “allowing viewers to see both regular speed and slow motion replay mitigates the bias, but does not eliminate it.”

Stoughton, POLICE BODY-WORN CAMERAS , 96 N.C.L. Rev. 1363, 1413 (June, 2018).

Yet how have courts responded?  Uniformly by rejecting challenges to slow-motion replay.  A LEXIS search of “slow w/2 motion w/3 video w/12 intent! or prejudic!” (last run September 4, 2020) produced eleven decisions at both the state and federal level.  Of those addressing admissibility, none found an abuse of discretion; and disconcertingly not one cited to or otherwise acknolwedged the research on the distorting impact slow-motion replay generates.

Some of these decisions may be proper, especially where slow motion was necessary to permit a better view of the perpetrator’s face and therefore allow the jury to determine the identity of the perpetrator or otherwise assess whether certain conduct actually occurred such as whether a knife was used in a stabbing rather than slashing fashion.  But time and again the courts also talk of the need to prove intentionality, and then add reasoning that is a- or anti-scientific.  Such sentiments include the following:

• we find that the probative value of the slow motion footage outweighed any potential for prejudice, particularly given that: the jury was first shown the scenes at normal speed, which allowed it to see the true timing of the events as they transpired; the slow motion footage was clearly marked as such; and the trial court specifically instructed the jury regarding both the purposes for which it was to consider the video footage and the fact that it should not allow the video to inflame their passions against Appellant.Commonwealth v. Cash, 635 Pa. 451, 478, 137 A.3d 1262, 1277 (Pa. 2016)(emphasis added)
• “As for the prejudicial effect of admitting the slow motion video, the court noted that [t]he jury obviously understood the tape was being played in slow motion rather than in real time,” given that they “saw the tape played at regular speed, twice…”Jones v. Fisher, 2013 U.S. Dist. LEXIS 184948, *29-30 (E.D. Pa. 2013)(internal quotation marks omitted)
• We have previously approved of a district court’s decision to send tape recordings and a tape player into the jury room during deliberations, and in that situation jurors could replay the tapes as often—or as slowly—as they likedUnited States v. Plato, 629 F.3d 646, 652 (7^th 2010)

These may be well-intentioned jurists, but these are ipsi dixit statements of how jurors will be impacted.

What is to be made of these disparate treatments of psychological research?  There is no clear answer.  The problem in the slow-motion cases may have been that of counsel who failed to brief the relevant research, or the need for clarity on issues such as facial identification may have dwarfed any concern over the risks in assessing intentionality.  And is the shackling decision a  product of its time, coming in an era of great concern over racism and implicit bias, concerns not necessarily or as manifestly implicated in the slow-motion cases?

Whatever the reason, the lesson is the same. On a variety of issues of courtroom conduct and evidence, cognitive psychology and social science research should give judges pause before determining how a trial will proceed.  The failure of advocates to proffer such findings and the absence of discussion of them in judicial opinions raises concerns over the reliability of adjudications and whether evidentiary rulings are really just gut-checks based on old tropes.

by Grant Rost

We are in a new world, aren’t we?  I am starting to get this strange feeling that the vocational “me” is really just a hologram—merely an image of me that others interact with.  I see him too.  He’s there in the lower corner of my screen, and he can’t even make eye contact with me!  Perhaps, he feels as estranged from me as I do from him.  This is our new world for a moment, let’s hope.  It makes me wonder where to look.  Surely, I’m not alone in this.  Each of you has wondered the same thing: look at the camera, look at your materials, or look at the people on your screen.  And if we teach advocates, how should we advise them in this new medium?  This month, I’m reviewing a recent study on how a presenter’s gaze and body position affects learning on the other side of the screen.[1]

The study was fairly simple.  Participants watched one of six different presentations teaching the same subject.  In each of the six presentations, the presenter’s eye gaze and body position changed.  Participants were then tested on the subject taught and those results were matched to the presenter’s eye gaze and body position.  There were three eye positions employed.  In the first, the presenter appeared to “look” at the material next to her on the screen—like a weather forecaster.  The courtroom equivalent is a lawyer next to a white board or demonstrative.  In the second, she looked directly at the camera.  In the third, she looked away from the material and the camera, as if speaking to an in-person group to her left.  There were three body positions tested as well: torso turned toward the material, toward the camera, or away from the material and the camera.  The presenter only ever appears from the waist up.

Before I share the results, it’s worth noting that the authors cite to a host of other materials which have revealed the importance of looking directly at one’s camera while communicating or teaching digitally.  If you are the type who looks at the people on your screen instead of the camera, don’t fret too much.  There is good data that people watching you sense that you’re trying to making eye contact with them and still feel a level of connection to you, even if you appear to them to be looking downward and not staring into their soul.[2]

The study revealed that the body position of the presenter simply didn’t matter.[3]  Eye tracking data from participants showed they rarely looked at the presenter’s body and her body position didn’t affect learning or retention.[4]  Second, the study showed that the participants who viewed the presenter “looking” at the material she was presenting—referred to as “guided gaze”—scored highest on a subsequent test.  The participants who saw her looking right at them—referred to as “direct gaze”—scored a little lower.  Finally, those who saw her teach with her head turned from the material and the camera scored the lowest.[5]

Though there is no good argument for the averted gaze, the data reveals that the guided gaze, where material is co-apparent with the presenter, and the camera-staring direct gaze, where it isn’t, are essential tools for our new world of computer teaching and persuasion.

[1] Zhongling Pi et al., Instructor Presence in Video Lectures: Eye Gaze Matters, but Not Body Orientation, 144 Computers & Educ. 1 (2020), https://doi.org/10.1016/j.compedu.2019.103713.

[2] See generally David M. Grayson & Andrew F. Monk, Are You Looking at Me? Eye Contact and Desktop Video Conferencing, 10 ACM Transactions on Computer-Hum. Interaction 221, [PINCITE] (2003).

[3] Pi et al., supra note 1, at 5.

[4] Id.

[5] Id. at 5-6.

by Grant Rost

Consider an argument you made to your jury just before they deliberate and hand you your hard-fought victory.  Did you persuade them or did you convince them?  Perhaps you just dissuaded them from finding for the other side.  However, if you dissuaded them, why can’t you also say that you dis-convinced them?  Or disvinced them?  Don’t try “deconvincing” either as that, too, is a dead end.

So, what gives?  Why can you persuade and dissuade but you cannot both convince and dis-convince?  It’s likely the case that you have never considered that while “dissuade” is the antonym of persuade there is no such lexicological opposite to the word “convince.”   According to Professor Adelino Cattani there is a very good reason for this—and it’s not simply a trick of the tricky English language. This missing antonym is missing from other languages too and, for the advocate, it’s worth thinking about whether persuading and convincing are really the same thing. [i]

Persuading and convincing, suggests Cattani, largely employ two different methods and seek different aims.  Persuading largely employs the powers of rhetoric, which can be both artful but largely manipulative, whereas convincing employs the powers of logic and sets of rules but can be spoiled by fallacious argument.[ii]  The dialogue of persuasion “aims at modifying people’s opinions and behaviours” which is why persuasion and dissuasion can work as opposites and produce actions or omissions in the receiver.[iii]  The dialogue of conviction, however, seems to refer “to the realm of thinking, not that of doing; it does not serve to induce someone to act, but to gain intellectual agreement or assent” and is, thus, more focused on the addressee than what the addressee can do.[iv]  Persuading is more like a gaming process, artful but still manipulative to gain its advantage.  Convincing, however, is more like a demonstration of one’s proofs—showing, rather than telling.[v]  One can begin to see why “convince” has no antonym.

I see two quick points to ponder for the trial advocate reading this blog post:  The first is that it might be worth considering which things one must persuade upon and which things one must convince one’s jury about.  A closing argument can gain more structure and become more purposeful with a little meditation on these two ideas.  Second, there seems to me to be a real difference in the rhetorical power of the two words in the minds of jurors and judges who will largely regard them as interchangeable.  It might just be me, so let me take the two terms for a test drive in a hypothetical courtroom:  It seems quite a bit more powerful to ask a jury if the state has convinced them that the defendant is the man who committed the crime than to ask them if the state has persuaded them to that fact.  What do you think?  Have I persuaded you or are you convinced?

* I have to give special thanks to Nathan Wilson, a rising 3L at UNC, who has helped me twice now with my Bluebook citation formatting for this blog—a task I loathe.  Nathan is the kind of student I wish I could clone and hand out to other law schools.

[i] Adelino Cattani, Persuading and Convincing, U. Windsor (June 4, 2020) https://scholar.uwindsor.ca/cgi/viewcontent.cgi?article=2528&context=ossaarchive&fbclid=IwAR3LxAMt0MnRGpsVk1pIo3RK87C8x0gdBkriIiIgHNinoM7luHdEst8rrcI.

[ii] Id. at 2-3.

[iii] See Id. at 2.

[iv] Id. at 3-4.

[v] See Id. generally.

by Jules Epstein

It may be silly but bears repeating – experts are people too, subject to a variety of influences that may distort their thinking, approach and conclusions without realizing this is occurring. This understanding of expert non-neutrality is nothing new – the 2009 report STRENGTHENING FORENSIC SCIENCE – A PATH FORWARD emphasized this.

Some initial and striking research has uncovered the effects of some biases in forensic science procedures, but much more must be done to understand the sources of bias and to develop countermeasures…The traps created by such biases can be very subtle, and typically one is not aware that his or her judgment is being affected…Decisions regarding what analyses need to be performed and in what order also can be influenced by bias and ultimately have the potential to skew results.

Id., 184-185.  And the audience for expert testimony – often, the courts – is sometime oblivious to this as well.  This arises from the perception of neutrality and objectivity that understandably comes along with the entry of science into the courtroom.

A new article offers a comprehensive paradigm for grasping and potentially responding to expert bias. “Cognitive and Human Factors in Expert Decision Making: Six Fallacies and the Eight Sources of Bias” (Anal. Chem. 2020, 92, 7998−8004, available at  https://pubs.acs.org/doi/10.1021/acs.analchem.0c00704 ) is among the latest from researcher and cognitive psychologist Dr. Itiel Dror.

Dror begins with his list of prevalent fallacies, ones he has identified in years of studying and training experts and the consumers of expert knowledge – judges and lawyers:

• Bias is a problem only with “corrupt and unscrupulous individuals” and thus is a matter of personal integrity.
• Bias occurs only among the “bad apples” of the community, people who have yet or do not care to learn “how to do their job properly.”
• There is no bias as experts are immune as long as they perform competently and with integrity.
• When forensic analysis is based on the use of technology, instrumentation or other non-human machinery there can be no bias.
• The “blind spot” phenomenon of seeing other experts as being biased but not oneself.
• What Dror calls “Illusion of Control: ‘I am aware that bias impacts me, and therefore, I can control and counter its affect. I can overcome bias by mere willpower.’”

The list is not just anecdotal; for each, Dror identifies confirming sources.

Why is understanding of the fallacies essential?  Without having them as a starting point, experts will be blinded to their own limitations, and those who retain, rely on or challenge experts will be unable to critically assess their work.

Dror offers more.  Having identified the fallacies that impede fair assessment of whether a particular expert’s approach or conclusion was hindered by biases, he then identifies eight forms of bias to test for.  This is his illustration.

The article walks the reader through how each level has a risk of biasing the examination and/or the resulting decision.

• The case specific circumstances, such as the data/material being examined, the reference material [e.g. a “target suspect” whose features can affect what is being looked for in a crime scene sample or a latent print], and contextual domain irrelevant information.
• Environment, culture and  experience include base rate [e.g. what the ‘normal’ conclusion is when finding certain features], organizational factors such as “allegiance effect” and “myside bias,’ and education and training that may predispose an examiner to look at evidence from only one or limited perspectives.
• Human nature is the last confounding source of bias, ranging from the purely individualistic motivation and belief system to the general aspects of decision-making such as top-down thinking.

To keep these from merely being labels, Dror provides illustrations.  How might reference materials bias?  “[T]his source of bias is not limited to circumstances that have a “target” suspect per se, but can also arise from pre-existing templates and patterns, such as in the interpretation of blood pattern analysis or a crime scene. It can even impact what color is observed.”

Contextual information can have its own ramifications.

In toxicology, for example, contextual information can bias testing strategies. Consider, for instance, when a post-mortem case is provided with contextual informant, such as “drug overdose” or/and that “the deceased was a known to have a history of heroin use.” Such information can impact the established testing strategies, such as to go straight to the confirmation and quantification of a limited range of opiate-type drugs (morphine, codeine, 6-monoacetylmorphine, and other heroin markers), without running the other standard testing, such as an immunoassay or looking for other opioids that may have been present (e.g., fentanyl). Hence, the contextual information caused a confirmation bias approach and deviation from the standard testing and screening protocols.

So, too, can “base rate,” illustrated by an example from forensic pathology.  If there is a hanging that results in cerebral hypoxia, that correlates primarily with suicide; and if there is strangulation resulting in the same condition it correlate highly with homicide.  But occasionally there can be homicides by hanging; and failure to consider this can skew not only the ultimate determination but “other stages of the analysis, even the sampling and data collection, as well as detection of relevant marks, items, or signals, or even verification.”

Are there solutions or at least mitigating steps to take?  Some are clear – preventing exposure to domain irrelevant material, using “linear sequential unmasking”  – and others are ore difficult, as they involve overcoming defensiveness on the part of examiners that bias is not a problem for them.  But without a fundamental understanding of bias and its sources and a corresponding system for checking and correcting for bias, the risk of error in core forensic analysis will persist.

By Grant Rost

We have all seen it.  We have all seen the lawyer or the student so involved with her notes or his script that they seem to have uncoupled from the courtroom itself.  I take that moment to study the faces of the jury.  What are they doing while the scribe at the podium has a private waltz with his scribblings?  In most instances, I see that the jury has also uncoupled.  Cognitive science has shown that the advocate here has not simply made a misstep with her dancing partner, but has missed the opportunity for the most amazing kind of dance: a cognitive coupling.[1]  A brain waltz taking place between two or more people.

The brain science behind “cognitive coupling” has been around for more than a decade, but the phenomenon might be new to you and is almost certain to be new to your students or the other trial warriors you work with.  Cognitive coupling is an electrical waltz between the brains of a speaker and listener—a fascinating Rogers and Astaire unison of brain activity shared when two people are truly involved in that phenomenon we so dismissively call “communication.”  Let us break down the science a little more from just one important study on the subject.

To study brain activity in both a speaker and listener, researchers recorded a subject telling a story that was personal to her and told without direction.[2]  While her voice was recorded, researchers also recorded her brain activity by fMRI.  This recorded story was then played for other subjects while their brains were being scanned by fMRI for processing activity.  As a control, they had someone tell a story in Russian and played that story for English speakers who knew no Russian at all.  I have spoiled the ending already, haven’t I?  The brain activity seen in the speaker, after a short processing delay, was mirrored in the listener.  When non-Russian speakers listened to the Russian storyteller, there was none of this mirrored coupling at all.  To tie up the loose ends that could account for the mirrored brain activity, the researchers had enough data to conclude that the speaker’s brain activity was not the result of hearing herself speak her own story.[3]

It gets better though.  The easier the communication was to understand, the delay between the speaker and listener’s mirrored brain activity shortened toward synchronicity.  Even better: When the listener could predict where the speaker was going, the listener’s brain activity would “predict” the brain activity of the speaker.  The speaker’s brain would then mirror the activity of the listener’s “prediction.”  Researchers next compared the brain activities of the various listeners in the study against one another and found that those, too, synced up in a marvelous dance.[4]

So, why should this matter to trial lawyers or trial advocacy professors and students?  It is the difference, as I see it, between communicating and communion.  I can communicate and yet completely fail at communion—the latter being quite simply defined as “sharing.”  In fact, the researchers concluded that the stronger the cognitive coupling activity between speaker and listener, “the better the understanding” of the story being told.[5]  How beautiful!  I often share the science of cognitive coupling with my students to refocus their goals in trial.  It cannot all be about the words on the paper.  It cannot be all about conveying the content we are certain will make or break our proof.  Our goal should be a connection at the electrical level, where jury and advocate swing, and mirror, and move, and predict, and dance the dance—all while opposing counsel sits and broods on the bleachers at the side of the gymnasium, wondering how he might cut in.

[1] Also referred to as neural coupling or brain synchronization, among other similar names.

[2] Greg J. Stephens et al., Speaker-Listener Neural Coupling Underlies Successful Communication, 107 Proceedings Of The National Academy Of Sciences Of The United States Of America, no. 32, 2010, at 14425, https://doi.org/10.1073/pnas.1008662107

[3] Id. at 14427

[4] Id. at 14426

[5] Id. at 14427