At the beginning of the third session of her deposition, Samek asked Ileana
"What other things do you remember that Frank did to you?" Ileana described how
Frank brought a snake into the house, which he used to scare the children. She
said he beat her with the snake and placed it inside her vagina, and that
afterwards he "punched" the snake with a screwdriver in front of the
A. Well, I remember a snake.
Q. What about the snake?
A. Having bad dreams about it.
Q. Tell us about the snake.
A. He had a snake. He brought a snake one day to the
house, and he used to scare me with it and he used to
scare the children with it too, especially Justin and
Q. What kind of snake was it?
A. I don't know about snakes. I just know it was a
Q. What did he tell you about it?
A. I was very afraid if it was poison. He would say it wasn't poisonous.
Q. Was not. Did he tell you where he got it?
A. From the street he say.
Q. How big was it?
A. About this big.
Q. Three feet?
MR. HOGAN: Looks like that.
A. Um-hum. He used to keep it there.
Q. Do you know when it was that he found it?
A. No, I don't remember.
Q. Do you know when it was that you first saw it?
A. That day he brought it.
Q. I was just trying to distinguish whether or not he showed it to you the day
he got it or if he had it for a while?
A. Yeah, he and--
Q. Excuse me. Was it before or after you started babysitting?
Q. Was it in the winter time, November, December, January or was it the summer
A. I can't tell you. I don't remember when it was but it was after December.
Q. How do you know it was after December?
A. Because it was after Christmas. I remember Christmas was--
Q. What did he do with the snake to scare people?
A. Well, he wanted to put it in the children's body.
Q. In the children's body?
A. On the children. He wanted the children to carry it but theywere kind of
afraid because maybe they never saw something like that.
Q. What did he say to them?
A. Excuse me?
Q. What did he say to them about the snake?
A. He wanted them to carry it.
Q. What did he say?
A. I don't remember exactly the words. I just
Remember that he wanted them to carry it then.
Q. Which kids did he ask to carry the snake?
A. I remember Justin, Noel, and I don't remember at this time what the others
but at that night he kept it in the house for a couple of days.
Q. Just walking, slithering around in the house or walking, slithering around
in the house or did he keep it in the cage?
A. No, he used to keep it in a bucket.
Q. A bucket?
A. Yeah, in the porch.
Q. What kind of bucket?
A. A regular bucket and in the back of the porch. And that's that same night
he, I remember when I got in my covers the snake was there and that's when he
used to scare me with the snake too when he used to make the children--
Q. The snake was in the bed?
A. Yes, yeah, in the bed.
Q. How many times did that happen?
A. Just that night.
Q. How long did he keep the snake?
A. Just a couple of days. I don't-- I'm not sure. I
cannot tell you how long it was. But he kept it more than
two days.Also he used to put the snake, he wasn't
afraid of it. He used to at night. He would like spank me
with it and I didn't have clothes on.
Q. Is that the night that you found it in the bed?
Q. That was the first night he had the snake?
A. Yeah, but it earlier but he also--
Q. He smacked you with the head or the tail?
A. I don't know. It was just part of the snake.
Q. Where did he hit you with it, on what part of your body?
A. In my back, just in my body. All I remember.
Q. You're not that big. Your body has a lot of parts too. Do you remember what
parts of your body?
A. The sides.
Q. For the record, showing the back of the left arm. Is that where he hit you,
the back of your left arm?
A. I'm not sure. It's just the body. He used to hit me a lot. That night he, I
remember he put it around my neck and he said that the snake could kill me.
Q. He said the snake could or could not?
A. Could. But--
Q. Was that before or after he beat you with it?
A. After. And he put it around my neck and he, if he would let it the snake
could have shock me, he said.
Q. Could shock you?
A. That's what he say. I was just scared.
Q. What else did he do with the snake?
A. He would put it on around my legs.
Q. Both at the same time?
A. Yeah. I was-- I wouldn't move because I was afraid. I was afraid. I didn't
want the snake to bit me cause no matter what he say I still was afraid no
matter if he say it wasn't poison I was afraid that snake could bit me and I
remember I was just still on the bed and he put it, he put it in my vagina
Q. Did he put it on your pubic hair or did he actually put it in your
A. No, just remember it was around in the area, in the area.
Q. Did he put the snake on so that it was touching any part of your vagina?
A. Yeah, it was.
Q. What part of the snake was touching your vagina?
A. I don't know it. I wasn't looking, could just feel
Q. You weren't looking?
A. No, just feel it.
Q. How do you know it wasn't his hands?
A. Excuse me?
Q. If you weren't looking, how do you know it wasn't his
A. Because the way it would move.
Q. Well, what is it that you felt?
A. Like when he used to hit me with it when he put it on my legs, the same
feeling. I wouldn't, just I wouldn't move. I remember I wouldn't move. I was
Q. What else did he do with the snake that night?
A. That's all I remember from now.
Q. Did he put the snake on his body?
A. Around him.
Q. Around his neck?
A. No, with his hand, hold it like that and also he--all I remember after that
is a couple of days after and I don't know if it was the next day or next after
that I would--I came in the kitchen and he had it on the counter. And the snake
was like, like not cut. It was like if he had punch it with something.
Q. Like he had punched the snake?
A. Yeah, with something. He had a screw driver. Be had punch it and the kids
were there around the counter and they were watching.
Q. Why do you say it was as if he had punched it with a screw driver? What did
you see about the snake that made you think that?
A. It was the way it was. The holes, it wasn't with a knife or anything like
Q. How many holes did the snake have?
A. I think two.
Q. Was the snake moving?
A. A little bit.
After arguing over who should clean the carpet after a child had defecated
on it, Ileana stated that Frank tied her to a bed and beat her. In this
section, Dr. Rappaport breaks in every so often to clarify Ileana's
Q. What else did Frank do to you?
A. It-- how scratch my back.
A. I had to scratch my back. I remember he-- it was before July on or in the
month of July before the 4th of July. And that was, it was because in the play
room he made me clean the carpet with sponge and my hands, some feces.
Q. Your hands what?
DR. RAPPAPORT: She had to clean feces.
A. With my hand and the sponge. I don't want to do it but he said that one of
the children had bowel movements and that's why but the children did not have
Pampers. If he would have done it, why he didn't have his Pampers on. So I did
not believe him and so I told him no, I wasn't going to clean it. And he was in
the play room area. And there was, there was Justin again and one of the
babies. And I remember the baby was laying on the carpet so he took me to the
bathroom and he tied me against the post of the bed.
Q.He took you in the bathroom?
DR. RAPPAPORT: Bedroom.
A. Bedroom. He tied me on one the of the posts of the bed with a blanket, so a
blanket from the bed. And he start punching me in my back. And it was punching
me in my back and he told me I had to do what he say because he wasn't going to
clean. I told him I did not want to be part of nothing, just leave me alone. He
went, he pulled me off the post. That's how I scratch my back because in the
edge of the bed I went against it, and the next day I was very sore from it.
Q. How many times did he hit you?
A. Like five times maybe real fast. And then he just pull me up but I was with
the blanket around me and I don't know how he was expecting me to come up.
That's why the next day I was very sore, sore and he hurt me.
Q. Did he have sex with you that night?
Q. What did he do to you that night?
A. I can't remember now, just remember he did afterwards, but I was hurt. Is
DR. RAPPAPORT: You can't remember or you don't want to?
A. I don't want to remember.
DR. RAPPAPORT: If you can remember you have to tell them.
A. I don't want to. It's not there.
DR. RAPPAPORT: You don't remember?
Ileana described how Frank tied her up in the garage, beat her, and rubbed
feces on her body. She said that the children may have seen the incident
because the kitchen door was left open.
Q.(BY MR. SAMEK) What else did Frank do to you?
A. He just so hard but it was one of the worst days. I remember him-- he, what
he used to happen, his punching bag. He hang me from both my hands and I
remember he was wearing the green pants like military pants.
Q. Military pants?
A. And he had a chain around him, and a real thick chain, and he hang me from
both of my hands. He put a tape on my face. He put the chain around my-- this
part of my body and what you call it--
DR. RAPPAPORT: The waist?
A. The waist. He wanted to hit me with the chain.
Q. Tie you with the chain?
A.No, he wanted to-- he put it around me and do this like.
DR. RAPPAPORT: Tighten?
A. Tight. That's a word. And he was hurting me. Then I just remember that he
was under a table.
Q. He what? Sorry?
A. He was under a table. Nearby. He would look from there. He would look at me.
But I was-- I couldn't see well. I couldn't. And then he came. He had a piece
of cloth in his-- had some feces on it. He started put it on my body.
Q. Where on your body did he put the feces?
A. On my legs.
Q. Where else?
A. On my legs and but the garage door was closed but the kitchen door was open.
And there were children in the other side. They could see it.
A. They could. I was so awful. I didn't-- I was just-- I didn't realize it. I
just remembered door open of the kitchen. But it's so-- all I can remember.
Q. Did you say the children did see or they didn't see?
A. They could, yes.
Q. They could?
A. Yeah, because they were in the kitchen.
Q. Do you know if they did?
A. I heard their voices.
Q. What did you hear them say?
A. I don't remember very well.
Q. Do you?
A. How could I have in mind at the time to remember what they were saying?
Q. You remember what Frank said, you remember what Frank did, only reasonable
to ask the question how do you know that children saw if they didn't say
anything about it??
A. Because they were in the kitchen and the kitchen door was open, from there
from what it happened, it was just a couple of steps, they could have just come
to the door and see it.
Q. Do you know if any of them did?
A. I am not sure. But I'm sure, I mean I didn't see them but I'm sure they did
see it because their voices, I remember there were voices very clear near
Q. You remember the voices but you don't remember what they were saying?
A. No, they were like yelling, like kind of yelling thing, something like that.
After that he took me down and I know I stood there like at least a half
Q. Hanging from the--
A. At least half, 25 minutes, half an hour.
In this section, Ileana alleged that Frank drugged her so she fell asleep.
When she woke up, she said that she caught Frank forcing Noel to fellate
Q. If you keep thinking maybe you'll be able think of some more. What other
things did you see him do to the children or have you told me everything you
ever saw him do with the children?
A. In the last deposition I mentioned to you when I saw him putting his penis
in Noel's mouth and he was vomitting.
Q. I don't remember if you did or not. Make believe you didn't and can you tell
A. There was one of the nights he used to give me those little pills like so
often, 4 times a week, and then he used to give me marijuana too. I was
exhausted. And there was the Saturday we have a real bad fight. And he hit me
real bad. And that one of my eyes was swollen and--
Q. Your eye was what?
DR. RAPPAPORT: Swollen.
A. Swollen. And I remember after that happened somebody called. It was one of
the parents, and but I didn't answer. Frank answered, and Frank say okay. I
tell him who he had called. He just told me to get ready because I was going to
take care of two children that night, that they were going to sleep over, and
so I refused. I told him no because of the way I was. And I didn't want them to
see me that way. There was no way that he could cover it. And he said no, just
put your green robe up to here and it was up to the neck and put some make up
on me and like but we still kept on refusing so I refused. I stood in my room,
and the children came. And I stood in my room all the time. I did not see him.
So he say that if I didn't want to take care of them he would do it.
Q. Go ahead.
A. So I never saw the children, so after he came back in to the room and asked
me again remind to get out of the room because the children were asking for me.
I tell him no, I was going to stay in because I didn't want them to see me, see
my face. So he say to put glasses on, and I didn't do that.
I just stood there and he gave me these pills, made me-- I was sleepy.
Q. How many pills?
Q. Took them both?
A. Yeah. He said there was going to calm me because of my pain. And like all I
remember that I opened my eyes and again it was real late, everybody was
sleeping except that I heard, I heard something in my bathroom. I got up, but I
went out of my room first, to check the children, the other two and they were
sleeping in the living room. They were okay. They were sleeping. Then I went
back to my room and check in to the bathroom where the noise was coming from. I
was still feeling very dizzy. And I came to the door and I saw Frank and Noel.
Frank had his penis in his mouth. And I didn't want to believe it. And then
Noel, he just start vomiting real bad. So he saw me. Frank saw me, told me to
not stand there acting stupid, to help me.
Q. Help who?
A. Help Noel because he was vomiting.
Q. When Frank turned to talk to you did he keep his penis in Noel's mouth or
did he take it out?
A. No, he kept it there but then he took it out. Everything was so fast. And I
say, no. So I run out of the bathroom. He came after me. And there in the
bathroom, Noel stood in the bathroom. He was vomiting. Then he told me to stop
being stupid and just to help Noel because he got sick and but I didn't want to
be part of nothing. I told him no. He start slapping me, slapping me real hard
again, over, over, over and over until he throw me out of the room so I, when I
went into the, went into the play room area.
Q. Where did he hit you?
A. In the face.
Q. Slapping or punching?
A. Slapped me and punched. I don't want to remember that.
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