Shaken Baby Syndrome Fraud

Shaken Baby Syndrome Fraud

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In May of 2009 the AAP published their bizarre policy statement that endorsed “shaking” as a biomechanical injury-causation mechanism for traumatic brain injury (TBI). Biomechanical experiments that had tested and eliminated ‘shaking’ as a TBI mechanism are audaciously cited by the authors as somehow supporting ‘shaking’ as a TBI mechanism, while the leading biomechanical research on the subject of shaken baby syndrome (SBS), shaken impact syndrome (SIS), and lethal minor falls (LMF) are not cited by the authors in their “Abusive Head Trauma in Infants and Children” position paper, as the biomechanical research consistently contradicted their position. In this critique the authors are requested to rescind their paper and its flagrant misrepresentation of the biomechanical sciences that have consistently and repeatedly proven that ‘shaking’ is not a valid TBI mechanism or medical diagnosis.

Key words: Shaken baby syndrome (SBS), shaken impact syndrome (SIS), lethal minor falls (LMF), traumatic brain injury (TBI).

AMERICAN ACADEMY OF PEDIATRICS
SHAKEN BABY SYNDROME FRAUD

by

Kent R. Holcomb

Introduction

Biomechanicians, who are the only professionals with the training and expertise to examine biomechanical injury causation mechanisms, such as the shaken baby syndrome (SBS), shaken impact syndrome (SIS), and lethal minor fall (LMF) theory, have repeatedly tested all three of these injury mechanisms and found SBS to be a human impossibility, while validating both the SIS and accidental LMF mechanism. Legal investigators who examined this research have independently concluded that SBS does not exist and had been founded upon a biomechanical misunderstanding by medical doctors who had no training and were unqualified in this scientific field. [1-2]
By contrast, in 2006 the National Association of Medical Examiners (N.A.M.E.) officially rescinded their endorsing position paper on SBS and did not renew it. Forensic pathologists have a legal obligation to determine the cause of death in these types of cases and, after numerous pathologists studied the biomechanical literature, they determined that SBS did not exist. For this reason their position paper was not
renewed. [3]
Moreover, in recent years numerous state trial judges have been faced with the question of whether or not to permit convictions founded upon this medical hypothesis or to uphold old SBS convictions and have concluded that SBS cannot sustain a criminal conviction. These state judges instead banned SBS from their court rooms and reversed years-old convictions. [4-11] In Ontario, Canada the medical examiner felt ethically compelled to Sua Sponte notify the court that SBS did not exist and was granted permission to review their 220 former SBS convictions to free the innocent. [12]
However, in May, 2009 the American Academy of Pediatrics (AAP) published their official policy statement that endorsed the SBS biomechanical hypothesis, [13] which placed the AAP in direct conflict with the entire branch of biomemchanical science, most forensic pathologists, most state court judges and federal judges who were correctly briefed on the hypothesis, and the legal commentators who published on the topic. [1-12]
To arrive at their conclusion that endorsed “shaking” as a traumatic brain injury (TBI) mechanism, Dr. Christian, Dr. Block, and the committee on child abuse and neglect fraudulently mischaracterized the body of biomechanical scientific knowledge as follows:

“in 1987 Duhaime et al reported that victims of fatal shaken baby syndrome, and many of those who survived their trauma, showed evidence of blunt impact to the head at the time of the diagnosis. The importance of impact in acceleration/deceleration injury was supported by their basic biomechanical models, and they concluded that most serious abusive head injuries required an impact to the head. The relative importance of impact as a contributor to the head injury sustained by abused children became a source of controversy. Biomechanical modeling has since been used to both support and refute the contributions of shaking or impact to abused head trauma. In reality, all models and theories have known limitations, and many clinicians and researchers acknowledge that precise mechanisms for all abusive injuries remain incompletely understood.” [13]

To support this statement the authors cite Duhaime [14] for historic purposes, Ommaya [15] to refute, Cory [16] to support, and Wolfson [17] for SBS ambiguity purposes.
The above-quoted statement grossly and fraudulently mischaracterizes the biomechanical studies while deceiving pediatricians as to the findings from the biomechanical branch of science.
This critique will clarify the true results from the quoted experiments and studies, discuss the lead biomechanical research that the AAP authors saw fit to suppress, urge the AAP to rescind, and discuss the apparent motivation behind the authors’ misrepresentation of the biomechanical sciences.

Background

Before discussing the biomechanical literature, a few points should be made about the role of pediatricians and biomechanicians. If a pediatrician were to diagnose a child with diabetes and prescribe treatment based on extensive medical literature that the pediatrician had reviewed, then he would be in his legitimate domain, an area in which a biomechanician would be unqualified to dispute the pediatrician. By the same token, if a biomechanician renders his opinion on the validity of a mechanical injury hypothesis, after conducting experimental tests on the hypothesis and reviewing all the biomechanical literature (for examples on SBS/SIS/LMF), his opinion would carry legitimate authority and could not be contradicted by a pediatrician who is not qualified in the biomechanical sciences.
In either instance the complaining party is not qualified to dispute the diagnosis/findings of the other party. Regarding the field of biomechanics and its applications to the SBS/SIS/LMF mechanisms, biomechanicians Bandak and Goldsmith
best describe their roles:

“Biomechanics is the subset of the scientific discipline of mechanics that deals with the forces, motions, deformation, ruptures, fractures, breaks, etc of living tissue. The science of biomechanics applies at the microscopic … and the macroscopic (tissue, organ, full body, etc) scales. ‘Injury biomechanics’ is the application of biomechanics to the understanding of the causation and mechanism of injury.” [18]

“Biomechanicians and physicians evaluate trauma in fundamentally different ways. The biomechanician constructs or accepts a particular system, obtains its physical and geometric characteristics, applies a specific and quantifiable input (load) and then determines the output using experimental, analytical, and numerical techniques. A physician, in contrast, sees the end product of signs and symptoms and relies primarily if not exclusively on experience and observational case material to diagnose and treat. A biomechanician traces a continuous path from cause to effect using the laws of nature, tries to determine the specific mechanism of any injury, and attempts to either establish or eliminate an ultimate mechanical cause.” [19]

Accordingly, it is the role of the biomechanician to “establish or eliminate” SBS/SIS/LMF as injury mechanisms for TBI, yet the AAP authors do not suggest that their pediatricians consult with biomechanics experts when evaluating TBI cases. (Although they suggest consulting with other specialists, biomechanician are not cited.)

AAP Authors Misrepresent Biomechanical Findings

When discussing Duhaime, Cory, Wolfson, and Ommaya, the AAP authors report falls somewhere between disingenuous and fraudulent, depending upon their foreknowledge.
In their report of Duhaime, they fail to disclose the results of the 69 “repetitive violent shaking” tests, in which peak accelerations came in at 9.29 G., which is about 1/10th of the forces needed for subdural hematoma or diffuse axonal injury, and 1/50th of the 428 G. forces reached from shaking-impacts. Since the shaking force levels were only 7-10 percent of that needed for lethal cerebral injury, these tests eliminated or falsified the SBS hypothesis. Yet the authors make no mention of these results in their paper. [13] Why?
Their most egregious error, however, comes from their nonsensical citation to Cory [16] as somehow supporting SBS. Either the authors never reviewed this study, or they intentionally misrepresented its results, as Cory conducted two experiments. The first experiment falsified SBS, and the second experiment falsified the infant-whip hypothesis as lethal cerebral injury-causation-mechanisms.
Cory correctly noted that Duhaime’s description of her infant model allowed for variations in its design. He postulated that slight variations in design parameters could lead to higher acceleration force levels. To test for these model design variations he replicated Duhaime’s infant model with an adjustable version and then tested each variation of the model that had a modified parameter change, such as higher center of gravity, or modified heads or hinged necks. In conducting this experiment, each variation of the Duhaime infant model was tested by volunteer shakers who violently and repetitively shook the Duhaime replica model in the anteroposterior (A-P) sagittal plane.
This replication of the Duhaime experiment confirmed that classical shaking alone did not nearly approach the force level needed for lethal cerebral injury. Cory’s highest force levels came in at only about 4,000 radians/second squared, which is about 18 percent of the force needed for lethal TBI under the Thibault-Margulies 22,000 radians/second squared scale.
Accordingly, while Cory’s experiments were understandably able to generate slightly higher force levels than those obtained by Duhaime with her more basic model, these levels were only 11-18 percent of the levels needed for SDH (brain) injuries.
Cory also discovered a secondary problem with the SBS hypothesis. Most of the SBS literature postulated a 1-2 minute violent shaking event, yet his volunteer shakers became overly fatigued after only 10 seconds of shaking.
Cory then set out to test what he postulated as his “worst case scenario” model and mechanism. Using the data from his first series of experiments, he created an infant model that combined all the parameters that had generated higher acceleration numbers; (i.e. higher center of gravity, hinge-neck, etc.) into a single model for his tests. He then created what was called in the study his gravity-assisted shaking pattern. This new pattern does not resemble any reasonable definition of “shaking,” but instead it better conforms with an “infant-whip” mechanism, not a shaking mechanism, as described by Cory:

“In the ‘gravity-assisted’ shake pattern the arms are extended such that the model is elevated about one shoulder and accelerated downwards to below waist level (using gravity to assist). This results in the back of the head (occiput) impacting with the back of the model. The volunteer’s arms are then pulled upwards, returning to the original position above the shoulders (with the volunteer’s head tilted to avoid collision with the model) and inwards to induce chin-chest impact at the opposite end-point of the shake cycle.” [16]

During this series of infant-whip tests, Cory again fell far short of the SDH (brain hemorrhage) force levels. This time he achieved 10,000 radians/second squared or 29 percent of the Duhaime SDH scale and 46 percent of the Thibault-Margulies SDH scale,
far short of the forces needed for lethal traumatic brain injury.
While this experiment did not test the SBS mechanism, it does serve as an interesting experiment, as not even this severe and unreported infant-whip mechanism could generate lethal TBI forces. In this indirect manner it serves to “eliminate” (Goldsmith) human shaking or whip-lashing as a TBI mechanism. Put another way, it proved that no form of human shaking or whip-lashing of an infant could generate the mechanical-sized forces needed for TBI, even in a worst-case scenario.
To cite this SBS-falsification experiment as supporting the SBS hypothesis is disingenuous or fraudulent, and again, it begs the question of why were these findings not reported.
Additionally, the AAP authors cite Wolfson [17] as evidence that the mechanisms behind SBS are “incompletely understood.” Yet Wolfson, like Cory and Duhaime before, once again tested and falsified the SBS hypothesis.
In these experiments, anthropometric infant dummies, designed to replicate six-month-old infants with rigid necks were used to gather data. Ten volunteers were told to violently shake the dummies in the A-P sagittal plane for as long as they could while Wolfson recorded the data.
Test results showed yet again that a human shaker (as opposed to the Ommaya 30 m.p.h. mechanical sled mechanism used in the original monkey experiments) could only generate about 10 g’s of force or about 7-10 percent of the force needed for SDH, comparable to the Duhaime 9 g results. Maximum duration of any shaker was 22 seconds with an average duration of 11 seconds (comparable to Cory’s 10 second finding).
Wolfson then recorded all this data into his MADYMO CRAB computational model that allowed him to test the full range of neck stiffness characteristics, ranging from no resistance, that allowed the head to impact with the chest/back, all the way up to the “end-stop” resistance level, which halted the head before making contact with the torso.
Since these experiments mimicked the SBS motions and not the Cory infant-whip experiment, Wolfson noted that “none of these results lie near those of Cory” for chest/back head impact results. (While unclear, Wolfson seemed unaware that Cory’s “infant-whip test” did not take place in the A-P sagittal plane.)
Still, no matter how stiff or flexible Wolfson adjusted the neck, he could not reach any recognized level of force for SDH/DAI injuries, and therefore validated yet again the Duhaime/Cory results by concluding that:

“Although this particular investigation has produced further results exceeding criteria for concussion, current literature does not report clinical findings consistent with this mechanism. If violent impact of the head against the torso were the mechanism of intracranial injury in SBS, it is likely that findings such as bruising of the chin, chest, back, and occiput would be reported. As with previous research, the results from these simulations have been unable to show that shaking alone can cause the head accelerations necessary to cause the brain injuries associated with SBS.” [17]

In discussing his results, (p. 65) Wolfson observed that 46 of his 50 simulations generated data below any of the recognized injury levels. That is, these simulations could not cause concussion. Simulations that did reach concussion levels came from the end-stop-type stiffness characteristic, which Wolfson states “mimics the behavior of an end-stop OR IMPACT.” (id) (Capitalization not in original)
Accordingly, like the earlier experiments, this one falsified and eliminated shaking as a lethal SDH injury mechanism, yet the AAP authors made the conscious decision not to report on these results. Why?
Ommaya’s study [15] is correctly represented by the authors as refuting SBS. However, the profound significance of this study should be placed in historic context.
Historically, it was Ommaya’s 1968 rhesus monkey whiplash experimental data that gave birth inadvertently to SBS. This experiment rapidly accelerated the monkeys to 30 m.p.h. and then brought them to a sudden stop. Radiologist Dr. Caffey saw the published report, telephoned Ommaya, and asked if the test results would support an SBS hypothesis. Ommaya explained that it would not. Ommaya explained to Caffey that a human shaker could not mimic the force levels of a mechanical sled that was accelerated to 30 m.p.h. and then suddenly decelerated. Ignoring or misunderstanding this advice, Caffey published his SBS hypothesis anyway with the Ommaya experiment appearing as the sole experimental source for subsequent SBS papers. [20]
In Ommaya’s 2002 paper, he performed a biomechanical analysis of his 1968 data, Duhaime’s experimental data, and all other subsequent biomechanical data to see if it supported or eliminated shaking as a cause of traumatic brain injury and concluded that shaking alone produces maximum accelerations:

“well below thresholds for cerebral concussion, subdural hematoma, subarachnoid haemorrhage, deep brain haemorrhages, and cortical contusions.” [15]

Accordingly, Ommaya has come forth to notify the medical community that his 1968 data was misunderstood by the medical community and should not be used to support the SBS hypothesis. The AAP authors by glossing over the Ommaya history and his 2002 findings, mislead pediatricians everywhere and do them a tremendous disservice. But why?
Since the AAP authors have grossly misrepresented the biomechanical literature that they cite, they should rescind their paper before they incur liability, especially when considered in light of the following four leading biomechanical studies that the AAP authors fail to mention in their report.

Selection Bias Fraud of AAP Authors Neglecting Biomedical Studies

An AAP policy statement on SBS/SIS should contain a concise distillation of the best scientific knowledge available to pediatricians, described in a fairly balanced manner that is free from personal bias or speculation. Disputes and controversies within the medical community or between it and the biomechanicians should also be discussed.
No such paper should be issued without discussing the results of the 2003 Prange, [21] 2004 Goldsmith, [19] 2005 Bandak, [18] and 2007 Prange [22] studies. While much more biomechanical literature exists, the findings from these studies are central to the SBS/SIS/LMF subject material.
In 2003 the leading experimental study of falls, shaking, and impact surfaces was published by Prange, Coats, Duhaime, and Marguiles. [21] This experiment tested shaking alone, shaking-impacts, and minor falls (1 ft, 3 ft, 5 ft heights) against concrete; carpet padding covered concrete; and concrete covered by a 4” foam piece from a crib mattress.
Cognizant of some valid criticism that was leveled against Duhaime’s 1987 experiment, these tests utilized a far more sophisticated 1.5 month old infant model and employed concise methodology that was beyond criticism.
Prange’s shaking only and shaking-impact against concrete and carpet-padded-concrete test results were similar to the 1987 results in that they eliminated SBS and validated SIS. His impact tests of 4” foam were similar to the shaking-only tests and could not generate sufficient forces to cause any form of TBI. Results from the one/three feet fall levels onto concrete pad were similar to those of shaking, while five foot falls onto these surfaces reached potentially lethal forces.
Therefore, although Prange’s experiments eliminated both SBS and the soft-cushion version of SIS as injury mechanisms, while validating the LMF theory, the AAP authors fail to notify their pediatricians of the experiments. But why?
In 2004 Goldsmith/Plunkett published their in-depth biomechanical study of all the data and laws of biomechanics that govern loading characteristics, injury parameters and criteria, scaling, failure characteristics, differences between infants and adults, and impacts due to falls in the context of TBI/SBS/SIS/LMF. Goldsmith determined that Dr. Caffey had incorrectly interpreted the results of Ommaya’s 1968 test when publishing Caffey’s original paper, as the results from a 30 m.p.h. vehicular impact are not comparable to a 9.3 g “shake.” It was also concluded that it was impossible to “differentiate a deliberate impact from an accidental fall under the same mechanical circumstances (speeds, surfaces, configurations) by biomechanical analysis, since the mechanism and injury patterns will be identical,” and since accidental falls from 5-6 ft heights could generate lethal forces comparable to an intentional impact. [19]
Observing that biomechanical studies had established that shaking could not cause concussion, subdural hemorrhage (SDH), or diffuse axonal injury (DAI), they noted that even if a super-human event generated forces sufficient to cause these injuries, there would necessarily be “significant structural neck damage.” [19] Yet once again the
A.A.P. azuthors made the nefarious decision to leave their pediatricians in the dark. Once again, this begs the question of why.
In 2005 Bandak published on this precise point, in a ground-breaking study that performed an “injury biomechanics analysis of the reported SBS levels of rotational velocity and acceleration of the head for their injury effects on the infant neck. Resulting forces were compared with experimental data on the structural failure limits of the cervical spine in several animal models as well as human neonate cadaver models. [18]
As the former director for the Accident Reconstruction Division of the U.S. National Highway Traffic Safety Administration and a Professor of Engineering and Applied Sciences for George Washington University, Bandak is arguably among the nation’s foremost biomechanicians and a voice that cannot be ignored.
Bandak’s findings demonstrated that the infant’s neck/cervical spinal cord would suffer lethal structural failure at force levels well below any of the recognized levels for SDH/DAI. Thus, if SBS was valid, which Bandak found that it was not, any victim of SBS would also have suffered structural damage to the neck-spinal cord. Yet, there were no such cases reported in the literature. [18] This profound study was, yet again, not reported on by the A.A.P. and again begs the question of why.
Medical doctors, grasping at straws, soon speculated that Cory’s chest/back/occiput impacts protected the neck from structural injury. However, this hypothesis was eliminated by Prange’s 2007 experiment: Testing with a pneumonic sled used to mimic 20, 30, and 40 m.p.h. frontal crashes with a 3-yr-old dummy restrained at the torso by a five-point belt in a forward facing child care seat, upper neck tension levels were measured at 250-350 lbs for the 20 m.p.h. crash, 450-500 lbs for the 30 m.p.h. crash, and 500-700 lbs for the 40 m.p.h. crash. [22] These were levels of force well above the 254 lb injury tolerance level accepted by the U.S. federal government. Dr. Prange’s video and raw data showed that these “peak upper neck tension levels” were reached during the forward arcing motion of the head BEFORE the chin made contact with the chest. Accordingly, this data showed that structural neck/spinal cord failure (Bandak) would take place before chin/back impacts of the head took place, thus falsifying the hypothesis that these impacts protect the neck. [23]
Yet, despite the profound significance of the Prange, Goldsmith, and Bandak studies, to any pediatrician who is trying in good faith to distinguish accidental from abusive TBI, the AAP authors fail to discuss these findings. This again begs the question of why?

Conclusion

As demonstrated by the foregoing discussion, the AAP has issued a policy statement that misrepresents the biomechanical sciences and glosses over the profound findings from this discipline.
Biomechanical experiments and studies from Duhaime, [14] Ommaya, [15] Prange, [21-22] Goldsmith, [19] Cory, [16] Bandak, [18] and Wolfson, [17] have yielded consistent data that repeatedly eliminated ‘shaking’ and impact against 4” foam as mechanisms of TBI. This body of research also validated SIS and LMF theories and found there was no biomechanical method of distinguishing between these two mechanisms in a typical case.
Accordingly, while a pediatrician may speculate as to a SBS cause of TBI, he could not issue a formal SBS diagnosis as no experimental data or science exists to support such a diagnosis, as the best scientific data available shows that SBS does not exist.
Most of the research that eliminated shaking as an injury causation mechanism was published in the medical literature and would show up under a medical database search for SBS; i.e., Duhaime, Ommaya, Cory, Bandak, 2005 Prange, and Uscinski.
Exceptions are Wolfson and 2007 Prange, that were published in the bioengineering journals. Since the AAP authors have cited both medical and bioengineering journals when discussing SBS, they appear cognizant of the foregoing research. Yet, no effort was made to accurately report these findings. Furthermore, the limited biomechanical reports that were mentioned were grossly misrepresented to the extent that the AAP may incur liability.
However, the AAP authors did liaison with Janet Saul, Ph.D. from the Centers for Disease Control and Prevention (CDC), [13] before publishing their policy statement. This is somewhat of a mystery standing alone, as the paper did not directly deal with disease. But when viewed in the context of an observation made by Wolfson in his study, we perhaps begin to grasp the AAP authors’ true motivation:

“…impact does not provide a plausible explanation for those cases of SBS where no evidence of impact can be observed in the presence of severe intracranial and neurological injury.” [17]

Thus, by advocating the nonexistent SBS hypothesis to their members, the AAP provides a default diagnosis for the large number of TBI cases that have no history of deliberate SIS or accidental LMF, and no soft tissue head injuries to support these diagnoses.
Put another way, as long as the pediatrician can fall back on the mythical SBS diagnosis, he need not look elsewhere for his TBI answer. Yet, this is precisely what pediatricians should be doing when confronted with a TBI case that has no head soft tissue injury and no history of abuse or minor falls. One logical area of research would be adverse vaccine reactions, and this may be the area of research that the AAP policy attempts to block, although speculative on my part.
Whatever the AAP authors true reasons are for grossly misrepresenting their cited studies and omitting key biomechanical studies from their paper, it should be rescinded, since it has the effect of instructing all pediatricians to commit medical malpractice and incurring liability upon the AAP and its authors.
Moreover, the medical community should avoid unwarranted conflicts between pediatricians and forensic pathologists, and the AAP should not advocate disingenuous policies that will infect the integrity of an organization that should have the public’s trust.
Relabeling SBS/SIS as abusive head trauma in an effort to be overly vague as to the mechanism of injury, while glossing over biomechanical research that conclusively eliminated ‘shaking’ as a TBI mechanism, could have a chilling affect upon the research into non-impact TBI cases. One wonders if this was not the authors’ intent and the reason for the CDC liason.
Before publishing this critique, the .A.A.P. authors were provided a copy of this manuscript and given the opportunity to deny the allegations herein or otherwise defend their position paper. Rather than defending their paper, the A.A.P. authors chose to remain silent and to let the criticism stand. In a court of law this silence would equate to a tacit admission of wrongdoing. This author welcomes all questions and comments.

About the Author:
Kent R. Holcomb is an expert in “shaken baby syndrome” (SBS) and founder of Medical Legal Advocate, A.S.P.C. Tucson, Unit Manzanita 3A22L; P. O. Box 24401, Tucson, AZ 85734

References:

1.Holcomb, K.R., Shaken Baby Syndrome actual innocence petition, Medical Veritas, 2008; 5(2): 1828-1835.
2.Kelly, R.H. and Bravos, Z. M. A critical look at the shaken baby syndrome, Illinois Bar Journal, April, 2009; 97:200-203.
3.Email from Gregory G. Davis, Chairman, N.A.M.E. Position Paper Committee, to Dr. J. Plunkett on 10-17-06 and other correspondence with N.A.M.E. and A.J.F.M.P.
4.Stern v. Schriro WL 201235 (2007 D. Ariz.)(pending Frye innocence claim)
5.State v. Edmonds, 308 Wisc. 2d 374, 746 NW2d 590(2008) (Old SBS case reversal).
6.Missouri v. Hyatt, 06 M7-CR00016-02 (Cir. Ct. Shelby City, MO)(11-6-07))(Frye)
7.Smith v. Mitchell, 437 F3d. 884(9th Cir. 2006).
8.Florida v. Sanidad, 00-524 CFFA(Cir. Ct. Flager City)(2008)(Frye).
9.Oklahoma v. Watts, CF-2001-43 (D.Ct. Woods City, Oklahoma)(2002) (Daubert).
10.Ex Parte Henderson, 246 S.W. 3rd 690 (Tex App. 2007) (Execution halted due exculpatory affidavits from biomechanician and pathologist.)
11.Ohio v. Mills, 2006, C.P. 1002315 (Ct. Com. Pleas, Tuscatawas City, Ohio)(2006)(Frye).
12.Ontario, Canada, Oct. 1, 2008, Report from Hon. Stephen Goudge granting M.E. Sua Sponte request, SEE: .
13.“Policy Statement: Abusive Head Trauma in Infants and Children”, Pediatrics, May, 2009; 123(5):1409-1411.
14.www.sbsreferences.com, Exhibit #1, Duhaime, A.C., Gennarelli, T.A., Thibault, L.E., et al, The shaken baby syndrome: A clinical, pathological, and biomechanical study, Journal of Neurosurgery, 1987; 66:409-415.
15.Ommaya, A.K., Goldsmith, W., Thibault, K.L. Biomechanics and neuropathology of adult and pediatric head injury, British Journal of Neurosurgery, 2002; 16:220-242.
16.Cory, C.Z. and M.D. Jones. Can shaking alone cause fatal brain injury? Medicine, Science, and the Law. 2003; 43(4):317-333.
17.Wolfson, D.R., McNally, D.S., Clifford, M.J., and M. Vloeberghs, Rigid-body modeling of shaken baby syndrome, Proc. Inst. Mech. Engineering, 219(1):63-70.
18.www.sbsreferences.com, Exhibit #10, Bandak, F.A., Shaken baby syndrome: A biomechanics analysis of injury mechanisms, Forensic Science International, 2005; 151:71-79.
19.www.sbsreferences.com, Exhibit #7, Goldsmith, W., Plunkett, J. A biomechanical analysis of the causes of traumatic brain injury in infants and children. American Journal of Forensic Medicine and Pathology, 2004; 25:89-100.
20.www.sbsreferences.com, Exhibit #4, Uscinski, R. Shaken baby syndrome: Fundamental questions. British J of Neurosurgery, 2002; 16(3): 217-219.
21.www.sbsreferences.com, Exhibit # 6A, Prange, M.T., Coats, B., Duhaime, A.C., and S.S. Margulies, Anthropomorphic simulations of falls, shakes, and inflicted impacts in infants. Journal of Neurosurgery, 2003; 99:143-150.
22.www.sbsreferences.com, Exhibit # 12, Prange, M., Newberry, W., Moore, T., Peterson, D., Smyth, B., and Catherine Corrigan, Inertial neck injuries in children involved in frontal collisions, World Congress, Society of Automotive Engineers, SAE 2007 International, paper #2007011170, and Email from Dr. Prange,
23.Galaznik’s 6-28-07 Email summarizing meeting with Dr. Prange and their review of video/raw data from Reference #22.

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