Although the preservationist can allow that memory generates justification when it also generates a new belief (recall the example of my using my event memory of the ice on my driveway to form the new belief that the ice on my driveway was of uniform thickness), she'll insist that when memory acts only to preserve belief, it is not an epistemically generative process. However, the claim that memory is not generative has recently come under attack. Jennifer Lackey has presented cases in which, at t1, S has a prima facie justified but defeated belief that P but over time comes to lose the defeater and hence at t2 has an ultima facie justified belief that P. That is to say, at t1 the belief is unjustified but at t2 the belief is justified even though S has acquired no new evidence regarding P. So, it is argued, memory can generate epistemic justification. (For discussion of these cases see Lackey 2005, Senor 2007, and Lackey 2007.)