 |
| Read the Bio for Barbara Johnson at Amazon.com |
 |
| Available on Amazon |
As a result of the original appointment, Murphy testified, she conducted an investigation and wrote a report, which Bea had never seen. In the course of it, Murphy spoke to Chloe for about ninety minutes on the day she was appointed. She also reviewed the social workers’ files but she had never spoken with Bill.
Aguilar wanted the report admitted into evidence and Bea objected, calling it biased and prejudicial. Worse, it was filled with hearsay from the Center, Carol Tracy, and Heather Bruce. If Murphy were acting on the court’s behalf, the guardian ad litem statute would allow Murphy’s report into evidence.
Bea would be able to cross-examine her, but would she want to?
Attached to Murphy’s report were letters by Tracy, Heather, and Leavitt, all written in July 1990. Bea had seen none of them. When they surfaced at trial, Bea fumed. The judge who heard her motion to compel Tracy to deposition might have allowed that motion had he been aware a letter from Tracy had been filed in the case.
The DA’s communication was something else Bea had not heard: “The District Attorney’s office only advised us the child would make an excellent witness in Court, due to her repeatedly telling them the same story, never changing it.”
Tracy’s letter, of course, presented problems for Bea. Aguilar hadn’t called Tracy as a witness, and Bea couldn’t cross-examine a piece of paper. Nevertheless, Tracy’s letter to Murphy was admitted into evidence as an attachment to her report. Tracy did not mince any words.
Essentially Tracy wrote she could “only imagine the fear and confusion Chloe must experience with each visit,” given that Bill’s father supervised the visits where the alleged abuse occurred. Tracy also wrote about Chloe saying Bill’s “pee pee doesn’t taste good. I think he has a virus in his penis.” That statement was one of many things which led her to file a 51A report.
She continued, “Knowing the fear, betrayal and confusion that a child often experiences when faced by the perpetrator (particularly when the perpetrator is the child’s father), I strongly urge that visitation rights be revoked in this case.” These were the reasons she gave for altering both the supervisor and the place of the visitations.
By imputing “fear, betrayal and confusion” to Chloe, Tracy was impermissibly giving her opinion and vouching. Of course, Tracy was certainly not an expert on visitation. The admission of her report into evidence came through what Bea believed was an unconstitutional back door. She hoped Goldblatt wouldn’t consider the letter when making his decision.
Leavitt’s letter to Murphy summarized her process notes up until that date. She added another dimension to the short-shorts incident that Bea hadn’t heard before: Chloe had told her mother that seeing the short shorts reminded her “of when he was sticking his penis in my mouth and my vagina. It made me feel like I did when he was doing that. It made me feel stupid again.”
The Horse’s Ass Talks
Murphy’s figure was even more abundant than Bea’s. Bea was sympathetic to the morbidly obese who regularly suffered unjustified discrimination because of their size, but there was something about Murphy she didn’t like.
Murphy was a young woman with a well-paying civil service job. The job provided her better health benefits than most Americans have, a pension, job security, and rights to due process far beyond those employed in the private sector. Why did she look and act so morose? There was no reason for her to act and look like her glass was half-empty.
Bea thought Murphy was a sneak, an unethical sneak. Murphy should have called Bea for her input—no, for Bill’s input—to the biased report. Bea hoped her dislike didn’t show.
She began cross-examining Murphy. “Ms. Murphy, to your knowledge were you ever notified by one of the clerks or by Judge Quimper that you were removed from this case?”
Her answer was a half and half: “No, once we file a report, we’re out of the case.”
Goldblatt was curious: “In other words, that’s your final action?”
“That’s our final act. We file the report and then that’s it.”
“So filing of a report discharges you?” Goldblatt rephrased his question.
“Yes.”
“Do you have a time-stamp or date-stamp copy of this report?” Bea asked, to expand on Goldblatt’s line of questioning.
“It’s stated on the memorandum to the judge.”
“But that’s what you typed on it?”
“I don’t type, Ma’am. We have secretaries that do that.”
Puh-lease. Give me a break.
A few more questions by Goldblatt and Murphy was put to rest. “I will say there was nothing in the file when I got it,” Goldblatt declared.
Overwhelmed and surprised with delight, Bea said, “Thank you.” Then she thought something she never would do. She dared conclude that Goldblatt was going to ignore Murphy’s report and the letters.
Aguilar said, “Judge, as an officer of the court, I’d also point out that the motion for the appointment of a guardian ad litem is missing from that file. I believe there may be a second file in Judge Quimper’s lobby.”
You betcha. Bet it has the September removal of Murphy and the appointment of Dr. Frechette in it too. And that’s several weeks before she supposedly submitted her report to Quimper.
“She has testified and the report is admitted,” Goldblatt said.
What? Am I missing something?
Goldblatt continued. “Now you may cross-examine her as to the report. You may cross-examine her as to whether she brought it up to Judge Quimper’s secretary.”
“Do you have any personal knowledge that Judge Quimper’s secretary ever saw this report?”
Murphy evaded the question as to whether she personally knew whether the report got to the secretary’s office.
A few minutes were then spent on trying to get her to respond Yes or No to the question of whether she’d been notified she was removed as the GAL on this case. Bea stated for the record, “Please let it be noted the witness is looking to Mr. Aguilar for a response.” That bought Bea nothing, but she believed Goldblatt got the message, and Aguilar had no further questions of Murphy. He had a surprise for them instead.
Ploy
“I’d like to call Chloe Abernathy as a witness,” Aguilar said. “However, my client and her therapist would like that to be taken by you in chambers without the parties present and without counsel present—if Attorney Archibald would stipulate to that—and written questions.”
“Unless you stipulate, I don’t think I can do that without a court order. If you want to go ahead.”
Aguilar said, “If need be, we’ll call her with Mother and Father not present.”
Goldblatt said, “Unless you want to stipulate, I can go before a judge tomorrow to ask for instruction on this motion.”
“Are you willing to stipulate?” Aguilar asked Archibald.
Before Bea could respond, Goldblatt said, “Me to hear Chloe in camera with just the stenographer. I would have the stenographer present because I think that would be the record.”
Bea responded, “That’s good. It’s one problem I had.”
Goldblatt added quickly, “I suppose as a suggestion, I might say if she does testify, both counsel and
I would have the stenographer mark that portion confidential, and either counsel can see it or I can report to counsel before the stenographer, just to summarize her testimony. If you want to stipulate to that?”
Bea thought, Confrontation. She wanted to cross-examine. She took it slow, wanting to get a feel for Goldblatt’s position. Equally important, she wanted Toffett to testify before Chloe did, in order to educate the judge on the suggestibility of a child’s memory. “Your Honor,” she said. “I have another problem. I’ve had Dr. Toffett—”
“If you want to take your witness out of turn,” the court suggested.
Bea said, “That might be a way of approaching it. It is Dr. Toffett, who is an expert and certified guardian ad litem—”
“Your Honor,” Aguilar said, “my question to counsel simply is, is she willing to stipulate that Chloe will speak with the master?”
The judge came to Bea’s rescue. “We got two different issues.”
Bea suggested, “If we take the doctor out of turn, it might be possible....” Bea stopped herself lest she sound too anxious. “Also, he’s been here for two days. I’d like to let him be on his way back to New Hampshire by midday tomorrow and not have to come back still one more day.”
“Yes, I’d like to finish by then, too,” Toffett said.
“Mr. Aguilar, are you in agreement?” Goldblatt asked.
“Yes, that’s fine.”
“To be sure, then, that we have an agreement—” Bea began saying.
“Bea, why don’t you and I just write up the agreement before we leave?”
“Fine.”
Goldblatt suspended the proceedings for the day, after which he, the experts, and the stenographer left. The Abernathys, though, stayed while Aguilar and Bea worked out a written stipulation for the next day regarding the order of witnesses.
Chill Out
Outside the courthouse, as Bill walked Bea to her car, she said, “I’m overjoyed about getting Toffett on before Chloe goes into the judge’s lobby. In the morning, I’ll be sure to save your rights to confrontation, to cross-examine, et cetera, again. I already mentioned it today, but I want to say it loud and clear in the morning.”
“I’m keeping my fingers crossed for Chloe,” he said. “I’m so angry at Denise for putting her through this.”
“Well, I’m grateful Denise won’t be in the same room with her when she testifies. That’s the big reason I agreed to the lobby idea. In the little room, the child might have felt trapped. Denise’s presence pervades it. I think it’s her eyes. I really do.”
“Yeah, I was afraid of that too. Chloe looks to her for approval,” Bill said. “Every Saturday she intimidates her, particularly when Chloe doesn’t want me to leave. And when I do leave, I just know she wants to kiss me goodbye.” Bill shook his head. “She has to kiss the window pane instead.” He turned his head, so Bea couldn’t see the pain in his eyes.
Bea took a deep breath. She may not have seen Bill’s pain, but she felt it. She changed the subject.
“I’ll call Dr. Toffett to confirm our meeting early, before court, tomorrow morning. He wants to review his testimony with me. In the meantime, I want you to go out and have a nice dinner tonight and relax. We’re getting there. Slowly but surely, we’re getting there. Go ahead, get out of here. Rehashing the day is not going to win us anything. You’re better off chilling out.”
Bill laughed.
“Isn’t that what the kids say, chill out?” Bea asked.
He nodded as he walked away alone.
They’ll Do It Every Time
“Can you imagine stipulating to a guardian ad litem like Murphy?” Bea asked Hugh rhetorically.
“Bill’s previous attorney, Phinney, I heard has been working in Salem County for years. And Murphy’s been in that court for fourteen years. He had to know she was incompetent,” she said as she stirred the curried rice, one of Hugh’s favorite dishes. “That the court would even appoint her to be a GAL is mind-blowing.”
As Hugh finished tossing the salad, she pulled the teak bowls from the cupboard and put them on the table.
“Well, you get what you pay for, don’t you?”
“True, but if we can agree on that, certainly the legislature knew it too before it passed the statute requiring courts to accept GAL reports, regardless of the otherwise inadmissible evidence they had in them.” She decided to set out her favorite candlesticks, the Japanese divers, one coming to the surface, one aiming for the deep. “They all should be thrown the hell out.”
“Your solutions are always so radical, my dear.”
Unsurprised by his reaction, she said, “Only because I come up with them when I’m tired and frustrated. But think of it, Hugh—every court appointee has one form of immunity or another.
There’s no accountability.”
Hugh peeked in at the lamb. “Looks scrumptious.”
As she set out an assortment of condiments, she said, “If someone brings the issue to your court, you and your pals could circumvent the statute if you want to.”
“How do you propose we do it?”
“Impute to the statute a meaning the legislature never intended.”
“But we have to give meaning to every word of a statute.”
“Exactly my point. You guys all the time give explicit meaning to allegedly implicit intentions. Like finding that only a judge and not a jury can determine a 93A claim. C’mon, like finding each time the words ‘by the court’ appear in a statute, it means no jury is allowed. Why not let the collective imagination do some good occasionally for us ordinary folks? They overlooked those words in the Dalis case after I brought it up in my amicus brief. The governor didn’t want to lose the women’s votes, so the court relented.”
Like Denise’s raving went in and out of Bill’s ears, Bea’s raving went in one of Hugh’s ears and out the other. As Bea was falling asleep, she couldn’t shake the report from her mind. Because Goldblatt let Murphy testify as the GAL, her report had to be let into evidence, even though it was objectionable on numerous grounds, not only for the hearsay in it. If the report hadn’t come in,
Aguilar would have had a reason to appeal.
In front of a jury, those documents would’ve been devastating. In front of Goldblatt, maybe not so. Maybe he wouldn’t give the report much credence. The letters alone screamed that Murphy didn’t investigate: she only rubber-stamped.
Count sheep. Toffett will tear it to shreds! She was concerned, though, that even if Goldblatt ultimately ignored Murphy’s report and the letters attached to it, Bill and his father would suffer while awaiting Goldblatt’s decision.
Dr. Wilburt Toffett
Aguilar handed the judge the agreement he and Bea had reached the previous night. Toffett would testify here, in the same cramped conference room being used as a courtroom. Chloe would then testify in a judge’s chamber with only Goldblatt and a stenographer, who’d record the judge’s questions of the child. Afterwards, the judge would read to Bea and Aguilar exactly what Chloe said, and then ask if they had any questions for him to ask her.
“Your Honor, for the record,” Bea said, “I agreed to this procedure with the proviso that you preserve Mr. Abernathy’s rights on the constitutionality of the procedure.” She breathed deeply and then said,
“His right to confront the child.”
“His rights are certainly preserved,” Goldblatt said.
Bea handed Dr. Wilburt Toffett’s curriculum vitae to the judge. “Your Honor, I offer the doctor’s CV as evidence.”
He accepted it.
She then began questioning the doctor. “Dr. Toffett, what is your occupation?”
“I’m a clinical and forensic psychologist with a subspecialty in neuropsychology.”
The doctor’s experience was extensive in a variety of environments. He’d been a staff member, an assistant director, and a director at multiple treatment centers, psychology units, and child and adolescent units in hospitals.
The last twenty years, Toffett’s private practice had been in the area of child, adolescent, and adult clinical psychology, neuropsychology, and forensic psychology. In whatever capacity he’d served, he’d been at the top.
To get an expert’s opinion into evidence, the court must declare the witness an expert in his or her field. So Bea identified the four fields in which she wanted Toffett declared an expert.
His memberships in professional associations, like the American Psychological Association, were as impressive as his practice had been.
For the court, the doctor explained, “A clinical psychologist practices in that branch of psychology which deals with the diagnosis and treatment of mental, emotional, and behavior disorders. A forensic psychologist provides psychological services to the courts, to the criminal and civil justice system.
“Neuropsychology deals with brain behavior relationships. So neuropsychologists diagnose brain injury and brain disease in terms of the dysfunction of the brain, and that includes cognitive processes such as memory, learning, attention, concentration, language, and the so-to-speak higher mental processes.
“And a diplomate is the highest level of qualification in the field. It’s comparable to when people talk of a Board Certified Surgeon.”
Bea swelled with internal joy, knowing how rarely true experts testified in family courts. She hoped Goldblatt recognized this rarity.
She then took Toffett through a series of questions required to qualify him as an expert by the court. Goldblatt, too, asked him a few questions for the same purpose. Once Toffett was deemed eminently qualified, Bea moved on to substantive questions.
“Are there any special factors that must be considered when allegations of child sexual abuse are made in the context of divorce and custody litigation?”
“Yes.”
“What are those special factors?”
“Children are growing, developing organisms, so one has to take into account the developmental stage where the child is both at the time the alleged offense occurred and the time frame when the child is interviewed and evaluated for the abuse. That makes the development of the child’s memory one of the more important factors.”
“And do you have any special education or experience in dealing with memory?”
“Yes. As a neuropsychologist, I probably do more testing for memory disorders than almost any other thing I do, because it is such a frequent accompaniment head injuries. So I have devoted a great deal of my time to the matter of memory.”
“Would you describe to the court what you consider important regarding children’s memory as it’s related to this case?”
“Well, children’s memory— This is an extremely complex subject so I have to try hard to simplify it,” the doctor said. “We talk of memory, but there are really many kinds of memory: for example, visual, auditory, and olfactory memory. We also have different kinds of functions of memories: for example, procedural, semantic, and episodic.
“One of the earliest memories we begin to acquire is called procedural memory, by which a child learns to hold a spoon; how to take a piece of zweibach and manipulate it into its mouth; later, how to put on its shoes, button its clothes; and still later, how to ride a bike.
“By semantic memory, we remember things such as who was the first President of the United States.
“Episodic, the last type of memory to develop, becomes the critical issue when talking of sex abuse. Episodic memories are unique to the individual about his personal life experience, like ‘the day I graduated from high school’ or ‘the day I was married.’
“In other words, our memory system is building one step on top of each other. So, obviously, the very young child who does not have any backlog of experience is building a very rudimentary kind of memory system. As we get older, we move on from there.
“For example, the constancy of visual memory—a child’s ability to remember a particular face as a familiar face—really doesn’t begin until about six months. So if a parent is absent for over a week while the infant is a few months old, the child will forget that parent. When the parent reappears, the child has to relearn it until somewhere after six months, when the parent becomes learned and the visual memory is constant.”
Bingo! Bea thought. The example backs up what she and Bill had been saying: Chloe could not have remembered being hit by a baseball bat in the head and on her bum while she was only a year old, which Rachel Gidseg wrote in the report of her investigation for DSS. Lordy, the infant would have been brought to a hospital, if she wasn’t dead.
Bea’s thoughts didn’t stop Toffett.
“Obviously, the young child has a very fragile memory system, and as the child gets older, the memory system becomes more developed. A significant problem arises when we’re trying to explore the young child’s memory. For instance, when you ask a child, What did you do today? the child might say Nothing. You say, Well, what do you mean nothing? Didn’t you go to school today? Yes. Well, what did you do at school? Nothing. Well, wait a minute, didn’t you have recess today?
“That is to say, it’s in the child’s memory system, but they don’t spontaneously bring it out. We do know the child’s memory is perfectly good, but the problem is getting it out, and because it’s so difficult, people turn to leading questions. And of course, once you begin to ask leading questions, you’re contaminating the memory.”
“Hold on just a moment,” Judge Goldblatt said. He scribbled some notes quickly, and then said,
“Okay. Go ahead. I’m sorry.”
Toffett resumed his lengthy explanation. “One of the things about the distortion of memory is that additional information about a subject, including false information, can distort the memory—of adults as well as children.
“I’m going to object,” Aguilar interrupted. “I think we’ve gone far beyond the response to the question as to the experience.”
To Bea, Aguilar seemed antsy. With no windows and a door kept shut, the crowded conference room was insulated from the air of the outside world and even the sounds and smells of the courthouse, which shared the same ceiling.
Accustomed to being focused on what goes on around him at a trial, the judge fixed on Aguilar’s objection and disagreed. “No, he’s talking about the factors. I think he’s come within the factors considered in the allegations concerning memory, and he’s given the developing memory of children. He’s given several different factors—I have five factors—the last one was episodic memory, and now he’s indicating, I guess, the subfactors in episodic memory. I think he may have this. He’s testifying as an expert. Go ahead, Doctor.”
He did. “The research shows that when additional information is given, the original memory can be changed or modified without the person, including adults, realizing the memory has changed.
“We all believe that what our memory is is our memory. Adults, of course, have one additional factor going that children don’t, and that is reality testing. We tend to check our beliefs against our means to tell us whether this is valid information or not. The young child has not yet developed the ability to test reality. This doesn’t occur in their developmental stage until about seven or eight.
“For example, the five year old doesn’t even raise the question of whether reindeer can fly through the sky; he simply accepts these things. The world of the young child, of course, is very much a world of fantasy. The books we read them are not factual books—they’re fairy tales, TV cartoons, TV stories, The Little Mermaid—so the young child is very much living in a world of fantasy and we encourage it.
“Again, it’s not until they’re at a later developmental stage, seven or eight, that we begin to require them to check the reality and that they develop the mental ability to do so. So when we’re talking to the very young child, we do have to consider those factors that can distort their memory. When they’re questioned, it’s very difficult and it takes a highly skilled interviewer to avoid leading questions. I think those would be my main points.”
When the judge stopped writing, Bea asked, “Would you describe now to the court the issues involved in evaluating allegations of sexual abuse?”
“When we’re investigating allegations of child sex abuse, we’re involved in something certainly very critical. On one hand, we must not let a child continue to be subjected to sexual abuse; on the other hand, we must not deprive a child of a loved parent and the relationship with that parent. So either way, we’re going down a very narrow dividing line and extreme care must be taken when we’re doing these kinds of evaluations.”
Yes, this Abernathy case is a tricky one. Bea wondered what the others were thinking of Toffett’s presentation.
“The American Academy of Child and Adolescent Psychiatry,” the suave doctor said, “has prepared a standard set of guidelines dealing with the elements that in ACAP’s view must be part of an evaluation in order to ensure maximum reliability. Certain of those guidelines are particularly relevant to the Abernathy case.” Toffett stopped to pick up a printout and began reading the guidelines.
Aguilar objected, but the judge said, “Go ahead.”
Persisting, Aguilar said, “This is an unresponsive answer. The question again is what are the important aspects of the guidelines. He’s not given us the important aspect of the guidelines, but is just reading some information out of this report.”
“I’m going to take it as the important aspects of the policy statement,” the judge responded. “In these child abuse cases, in custody cases, we have a lot of flexibility and we have to have it in the interests of the child. So I’m going to allow him to testify.”
Toffett continued reading the section that said evaluations ideally should be performed under the direction of an experienced child and adolescent psychiatrist or psychologist, and the people conducting the evals should be trained in how to conduct diagnostic evaluation of both children and adults.
The closed room was so small, and the judge so intensely taking notes, no one dared stir in their seats.
The doctor continued reading aloud how a child should be interviewed by the fewest number of people necessary, and the importance of gathering a history on the child from each parent or caregiver alone and what the history should include.
“For instance, there should be a psychiatric assessment of each parent, especially if there is concern that the allegations may be false or that a parent was abused as a child. “The possibility of false allegations needs to be considered, particularly if allegations are coming from the parent rather than the child, if parents are engaged in a dispute over custody or visitation, and/or if the child is a preschooler.
“‘False allegations may arise in other situations as well, such as the misinterpretation of a child’s statement or behavior by relatives or caretakers.’”
Aguilar interrupted. “Judge, I’m going to object and ask the witness instead of reading, to testify from his memory if he can do so.”
Bea thought, Interesting how Aguilar objected soon after the doctor uttered the words “false allegations.”
Goldblatt again disagreed and allowed Toffett to continue, but the doctor, sensitive to his presentation, stopped reading and began using his own words.
“Then comes the issue of the anatomically correct dolls. These guidelines do allow the anatomically correct dolls to be used. However, the American Psychological Association does not consider the use of anatomically correct dolls as appropriate.
“Within our scientific community, there’s a matter of great dispute going on about using the anatomically correct dolls in evaluation. The dolls were first used in therapy, and there’s no objection to them being used in child therapy. But as soon as you begin to use that doll as part of a diagnostic evaluation, that’s where you get into trouble.”
Goldblatt said, “Let me interrupt here, Dr. Toffett. Anatomically correct dolls—two questions: First, are you saying the psychological association doesn’t have faith in the use of anatomically correct dolls for the determination of whether sex abuse actually occurred?”
“Yes.”
“Second, do you or does the association take any position on whether the anatomically correct dolls demonstrate the child’s perception of whether sex abuse occurred, irrespective of whether the abuse really occurred?
“Yes. It would not be valid. The APA doesn’t condone the use of the anatomical dolls as an evaluation tool. In either case, it would not be valid. The dolls should not be used to evaluate whether abuse really occurred or whether the child just perceives that the abuse occurred.”
“Okay,” Goldblatt said.
“Among other things, there simply hasn’t been the research with the control groups of abused and non-abused children to see how they react.”
“Okay. Go ahead,” said the judge.
And Toffett did, giving first a bit of history of what the APA did. The group compared the reactions of essentially abused children with non-abused children, trying to answer whether the dolls really make a difference.
Aguilar again objected to the guidelines. An ambiguous objection, thought Bea. Aguilar wants to get rid of Toffett’s testimony about the standards set out in the guidelines.
“It’s still in for Identification,” Goldblatt said.
Toffett then went on to discuss how children’s drawings are helpful in assessing child sex abuse. “It depends again upon how one uses children’s drawings. There’s no evidence I’m aware of which says any clinician can look at a child’s drawing and say that it’s a clear indication of whatever.
“One may use the drawing in the sense of an aid to the interviewer, but not to look at any particular drawing and say it is indicative of a particular problem.
“The only validated research on that is in terms of the child’s developmental level. For example, we have data showing what a five year old will draw and what a six year old will draw in terms of whether they’ll put eyes or toes or belts or hair on the drawing of the human figure. Now, if I see a drawing of a ten year old of what is characteristic of what a five year old can draw, then I can say this is probably a retarded child.
“We can make those kinds of diagnostic things. We have the data on that but not in terms of looking at a drawing and saying this is diagnostic of sexual abuse; you can’t do that.
“The guidelines say videotaping when possible can serve several useful purposes. From my own point of view, I think there absolutely should be videotaping and I now do it in everyday—”
“Judge, I’m going to, once again, object,” Aguilar again interrupted. “His prior testimony is not what he believes or what his opinion is. He’s testifying on what he believes these people believe. I don’t think it’s admissible.”
“I’ll take it. I’m going to rule on it all later.”
Toffett continued. “On the issue of psychological testing, the guidelines say testing alone does not diagnose sexual abuse either in the victim or the offender. In cases of possible false allegations, if testing is done to one parent, it should probably, in all fairness, be done on the other as well. Testing of the victim may be indicated if there are questions about intelligence or thought processes.
“And every child who may have been sexually abused should have a physical examination. A carefully written report should document the basis for any determinations. Finally, in some cases, there are a number of reasons why an evaluator may not be able to determine whether sexual abuse occurred, one being contamination by too many evaluations and using particularly biased or leading questions. In addition, the child may be too young to verbalize what occurred.”
Dr. Toffett stopped, and Goldblatt looked at me. “Okay. Ms. Archibald.”
Look for part 18 of this serial to post on Monday, September 8th
