“Memories can’t be completely unavailable and then suddenly recovered. The person just chose not to think about it.”
“The memory problems that are mentioned actually refer to everyday forgetfulness -- not an inability to remember the trauma… Ordinary memory processes, not repression, explain the subjective experience of recovering a memory.” - FMS Foundation Staff, in the FMSF Newsletter. 
“Not thinking about a trauma for a long time is not the same as being unable to remember it.” - Richard McNally, in the FMSF Newsletter. 
How do we know a memory is actually unavailable to consciousness before being recovered – rather than actively avoided and ignored, simply not thought about, or subject to non-traumatic ordinary forgetfulness mentioned in the previous claim [link]. Brown et al. describe such claims as shifting “focus away from doubting the existence of repressed memories and toward debating about its explanation.” 
Jim Hopper suggests that the difference between available and unavailable is a false dichotomy: “There’s no simple thing called ordinary human forgetfulness. There are a whole bunch of mechanisms and processes by which people can forget things and retrieve them . . . . It’s a matter of degrees; it’s a matter of context.”  Whether something is truly unavailable as compared to simply forgotten matters less than the impact recollection has on one’s life.
However, this claim – what it says about the dichotomy of memory availability and whether memories can be truly ‘unavailable’ – is still refuted in a number of ways:
In a process called directed forgetting, repeatedly avoiding, ignoring, or rejecting a memory can eventually make it unavailable to consciousness. Constance Dalenberg notes that when one “tries to forget an event,” they can “speed the decay of the memory trace” through “executive control” over forgetting. 
In a review of over 30 years of literature, Colin MacLeod writes that “Unlike many memory phenomena, I believe that we now understand directed forgetting quite well… forgetting is important, perhaps just as important as remembering… intentional forgetting is a key element we use broadly in orchestrating our memories.” 
This shows another false dichotomy of this claim: active avoidance of a memory is not distinct from memories that are unavailable – in fact, avoiding a memory can cause it to become unavailable.
It is important to note that choice and agency in forgetting does not affect truthfulness of the memory or place the blame on the victim.
Continuously Unavailable Memories
If someone was simply ignoring or avoiding their memories, they would be able to recollect their experience of abuse when reminded. The following cases involve people whose memories remain unavailable – when reminded or given clear evidence of forgotten abuse, they still cannot remember their own experiences.
1. Bostick vs. Huott: After hearing a news story about a swim coach sexually abusing a girl, Bostick said “I felt unsettled, but wasn’t sure why.” At the time, she did not identify herself as a victim of abuse. Within a year of hearing about the Curl case, Bostick approached the police with what she described as “little more than memory fragments and a gut feeling that I had been abused” by her own swimming coach, Christopher Huott. The police arranged for a monitored telephone call to Houtt. As she described it, “for nearly two hours, [Houtt] confessed to abuse more horrifying than I had imagined or feared.” Houtt pleaded guilty and was convicted of child abuse. Even when presented with a confession, many of Bostick’s memories remained unavailable. 
2. Bidrose & Goodman: A case study analyzing a detailed record of the repeated sexual assault of four girls, which was corroborated by extensive photographic and auditory documents. Though 318 different acts of sexual abuse were documented, only 194 were included in the girl’s allegations. Furthermore, “There were three instances where a girl said an event did not occur but the evidence shows that it did.” In these cases, memories continued to remain unavailable even when presented with photographic evidence. 
3. Luke Benson: Philippe Vincent Trutmann, who was sentenced to 6 1/2 years in prison in 2005, “admitted to sexually abusing [Luke Benson] 30 to 40 times over a two-year period.” But Mr. Benson, who remembers Trutmann as a “father figure,” has no recollection of the abuse. He stated that “It is confusing to have no recollection of the abuse… I have no memory of this happening and I inquired whether it was a mistake.” 
Episodic / Intermittent unavailability
Schooler et al. describe two cases of recovered memories of abuse where memories of abuse were intermittently unavailable. Both participants husband’s reported being told about the abuse during a period of time where the participants indicated they had no recollection of their memories. Subsequently, both the abuse and the communication of their memories were forgotten.
Excerpt: “In recounting her reaction to learning that she had told her ex-husband about it, [participant] DN said she "felt like falling over. Absolutely shocked and floored that it [telling her husband] happened. And I still am ... I can't remember telling him, I can't think of anything about the memory before [the discovery], and it's very disturbing, actually." 
They study concludes that “While the memory might be perceived to have been recalled for the first time in years, in reality it may have been recalled previously but without as much emotional punch, perhaps with a less negative interpretation. Indeed, both WB and TW's husbands reported that their wives earlier discussions of their experiences had been "emotionally flat” … abuse was found to have been remembered at a time in which it was believed to have been forgotten.” 
 FMS Foundation Staff. (2009, Spring). Understanding The Subjective Experience of Recovered Memories. FMS Foundation Newsletter. 18(2), 3.
 McNally, Richard. (2005). Debunking myths about trauma and memory. Canadian Journal of Psychiatry, 50(13). 817-822.
Cited in New Articles of Interest. (2006, March/April 2006). FMS Foundation Newsletter. 5(2), 4.
 Brown, D., Scheflin, A. W., & Whitfield, C. L. (1999). Recovered Memories: The Current Weight of the Evidence in Science and in the Courts. The Journal of Psychiatry & Law, 27(1), 5–156. doi:10.1177/009318539902700102
 Clark v. Edison, Memorandum and Order on Cross-Motions to Limit or Exclude Expert Testimony. Civil Action No.09-40040-FDS Document 156 (District Court of Massachusetts, 2012, July 25). https://www.govinfo.gov/content/pkg/USCOURTS-mad-4_09-cv-40040/pdf/USCOURTS-mad-4_09-cv-40040-2.pdf
 Dalenberg, C. (2006). Recovered Memory and the Daubert Criteria. Trauma, Violence, & Abuse, 7(4), 274–310. doi:10.1177/1524838006294572
 MacLeod, C. M. (1998). Directed forgetting. In J. M. Golding & C. M. MacLeod (Eds.), Intentional forgetting: Interdisciplinary approaches (pp. 1–57). Lawrence Erlbaum Associates Publishers.
 Lewis, Kevin. (2014, September 11). Maryland swim coach Chris Huott sentenced to 10 years in prison for child sex abuse. WJLA
 Bidrose, S., & Goodman, G. S. (2000). Testimony and evidence: a scientific case study of memory for child sexual abuse. Applied Cognitive Psychology, 14(3), 197–213.
 Jacks, Timna. (2015, September 2). Sex abuse royal commission: Geelong Grammar student has “no memory” of repeated abuse at school. The Sydney Morning Herald.
 Schooler, J. W., Bendiksen, M., & Ambadar, A. (1997). Taking the middle line: Can we accomodate both fabricated and recovered memories of sexual abuse? In M. A. Conway (Ed.), Recovered memories and false memories. Oxford: Oxford University Press.