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Fenwick is of the view that their brains were so dead that they should not have been able even to hallucinate (assuming that NDEs are hallucinations) and even if they were able to hallucinate, they should not subsequently have been able to recollect any part of their hallucinations (because the memory functions of their physical brain should have been 100% impaired).
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The can hallucinate afterwards that they had certain experiences.
It's quite easy to create false memory's in people (easy to get into a trance and full of narcotics) like this.
At the moment I don't think that we have proof in either way.