 Another problem is that, since knowledge requires truth, justification, and belief, the epistemic theorist must claim that memory requires truth, justification, and belief, and each of these claims has been persuasively challenged. As we will see in section 6, there appear to be cases of memory without truth. There are likewise arguably cases of belief without justification (Audi 1995; Bernecker 2011). Lackey (2005), for example, describes a case in which, after initially forming a belief, the subject acquires defeaters which undermine his justification for it. And there are arguably cases of memory without belief. Martin and Deutscher (1966) illustrate one kind of nonbelieved memory by means of the hypothetical case of a painter who paints a scene that he takes to be imaginary but that turns out to correspond exactly to a scene that he witnessed as a child; intuitively, this is an instance of remembering without believing. Since the subject lacks the phenomenology characteristic of remembering, the epistemic theorist might in principle deny that this particular case is an instance of remembering. But, in the kind of nonbelieved memory studied by psychologists (Otgaar, Scoboria, &amp; Mazzoni 2014), the subject fails to form a belief corresponding to his memory despite having the phenomenology characteristic of remembering; the existence of nonbelieved memories of this kind is well-established.