At the start of the deposition, Cohen establishes that Ileana is testifying
of her own free will:
Q. Okay. Now, has anyone forced you to be here today?
Q. Has anyone threatened you in any way or promised you anything in regards to
meeting with me here today?
A. No. Nobody has.
Q. Okay. And are you here on your own free will?
A. Yes, I am.
Ileana alleges that state investigators removed her from the prison and took
her out to dinner in order to remind her what she was missing while in
A. Back to my cell. And some days, you know, I also remember they would take me
out of my cell.
Q. Who's they?
A. Investigators would take me out of the cell at night and we'd go to
restaurants. I recall twice.
Q. Where were the investigators from, do you know?
A. From the state.
Q. How do you know that?
A. Because I saw them in court a couple of times, and because they told me they
worked with Mr. Hogan.
Q. Can you -- I know it's ten years later but can you recall what one or either
of them may have looked like?
A. No. I don't remember their names. I -- maybe if I look at a picture, yeah, I
would remember their faces, who they were.
Q. Do you recall -- well, how many times that you can remember did they take
out of your jail cell into a restaurant?
A. I remember at least twice.
Q. Do you recall the restaurant you went to?
A. No, no, because it was at night. I just remember being taken out and going
to nice restaurants and eat Spanish food. I remember that.
Q. It was just you and the investigators?
A. Right. And they would just tell me, you know, isn't the restaurant nice, I
mean don't you miss being out here in a restaurant, stuff like that.
And -- but I be quiet all the time. I was very quiet.
Q. So that's about all they talked to you about?
A. Yeah. They never talked about anything else.
Q. Then what would happen after dinner?
A. They would take me back to the cell.
Q. And you recall that --
Q. -- about two times?
A. Right. And so I thought they were being nice to me.
Cohen asks Ileana to talk about her original deposition in Frank's
trial and who helped prepare her to give that testimony. At this point she
discusses Janet Reno's involvement and alleges that her testimony regarding
Janet Reno's visits to the prison had been altered.
Q. Who prepared you?
A. My lawyer.
Q. Anyone else or just your lawyer?
A. My lawyer, and I think I talked to the -- someone from the state --
Q. Do you recall who?
A. -- about it.
I don't remember if it was Mr. Hogan. And I remember Janet Reno coming in a
couple of times, too, to see me.
Q. Let's talk about that for a little bit. When you say Janet Reno came to
visit you a couple times, where did she visit you?
A. At the jail.
Q. And do you recall when in point of time that would have been?
Q. Closer to trial? Further away from trial?
A. Close to the trial
A. Close to the trial she visit me.
Q. And you said she came to visit you twice. Is that what you recall?
A. No. It was more than two times. I don't exactly know how many times but --
you know, but it was more. She'd come in, and all I remember is that -- even
now I have the feeling that she's a very intelligent lady. And she was very
nice to me and she told me she wanted to help me, and that something real bad
had happened to me and it was her duty to make sure that justice was done and
Q. Is this what her conversation would consist of --
Q. -- when she came to see you?
A. Yeah. And she told me that those things had happened, that that's what the
psychologists said, and that I had to accept it.
Q. And you recall that conversation?
Q. Okay. As far as -- do you recall when you gave your deposition a question
was asked of you regarding how many times Janet Reno came to visit you?
Q. Do you recall being asked that question?
Q. And do you recall what your response was?
A. I said that she came to see me. And then I talked to the state again and my
lawyer, and they told me I should have not said that she came to see me, but
now I have to say it because I had said it before.
Q. When did they tell you this?
A. I don't remember, but it was in between the -- in the deposition.
Q. So you took a break, is that -- or something happened like that, or you
A. I don't remember the procedures or -- sometimes I did not know if I was in
record or not because -- you know, it's not like right now I know exactly
what's going on. And back then everybody told me what to do or when to talk,
when not to talk. And I was afraid.
Q. So someone from -- during your deposition, what you just stated is that
A. Yeah, they stopped.
Q. -- someone -- they stopped, and then someone told you, you know, to go back
in there and say something else?
A. Yeah. I had to fix that.
Q. You had to fix it. Okay. So that would be --
A. So they told me --
Q. Because I've read your deposition, and in your deposition it reflects that
you came back in and said that you wanted to correct a statement that you had
made regarding how many times Janet Reno visited you.
Q. So is that what you're talking about?
Cohen asks Ileana to talk about her sessions with Dr. Michael Rappaport and
Dr. Merry Sue Haber, the psychologists who ran a company called "Behavior
Changers," and were hired by the prosecution (with the consent of Ileana's
attorney) to treat her in prison. Ileana alleges that the two told her she was
remembering the abuse through her dreams.
Q. All right. Now I want to get back again to these -- the sessions that you
had, because the next names on my list here are Dr. Rappaport and Dr. Haber.
Do you recall if -- when they would start these sessions what would they say to
you? Do you recall what they would say?
A. No. I can hardly remember. This has been so long. You know, I remember just
that I will calm down, and I just wanted to get it over with because, you know,
they told me this happened, this happened, this happened.
And I will break down and say no, no, no, it didn't happen.
And then they would tell me that yes, I have to accept it, I have to confront
it. So they were long sessions and tiring. I just remember that that was the
And I would go to bed, and I don't know why, but I would dream about the same
things the kids were saying and the same things they were telling me.
So I came back, and the first question was so what did you dream about last
night, did you have any bad dreams or did you not. If I had bad dreams had to
tell them about my bad dreams in detail. And they did tell me, you see, you
And then I say no, it cannot be because have -- I still have no memory, I just
have bad dreams.
And they say that that was the way of me remembering. So it was shocking, you
know, and -- up to today, you know, I've been confused, you know, did that
really happen or not, because I have no memories of it.
Q. Did they -- do you recall them teaching you in any way how to remember
things? Did they give you any instructions on what to do?
A. No. Just that during the sessions they would repeat the -- they said that --
they would tell me that -- I think the state or Von Zamft, I don't know who,
would give them the information about what the kids were saying, and they would
tell me what the kids were saying and they would ask me about it.
And I'd go back to bed. And then I remember having bad dreams about it. They
told me that that was a technique of remembering bad things.
Q. Did they ever tell you to relax?
A. Yeah. When I -- when I went to the sessions and I had -- they told me I had
to feel clear, I had to clear my mind about anything else that was happening. I
had to forget that I was in jail, and I had to think that I was back in the
house. And then I --
Q. Were you able to see those thoughts once they start to --
A. Yeah. I can actually be in the house. I mean I could go to any room. I can
-- they would tell me just, you know, close your eyes and think you are walking
into the room.
And I had to give them details of the room first, where the bed was, where the
lamps were, whatever I could remember. And then I have to visualize the events,
what the kids were saying, and visualize my dreams.
And I had to tell them, you know, if it was something in the kitchen, I had to
think about the kitchen, how the kitchen was. And I have to picture myself in
there. And then I have to tell them about my nightmare that I had in the
And then I had nightmares about the living room, I had nightmares about the
main room, and I had to do the same thing.
Q. Now when that would happen and you like woke up from these nightmares, if
you can recall them, did you believe it was true?
A. Yes, because I was in there. You know, the same things I was dreaming, I was
in there. I could actually feel I was in there. I remember the walls, and then
I'd remember Frank, too.
Q. Do you recall if during these sessions that anyone took any notes?
A. Yeah, they took notes.
Q. Drs. Haber and Rappaport took notes?
A. Yeah, they took notes. And they said that I was remembering, and then after
remembering I was going to feel better. And that I needed to help the children,
and the only way to help them is remembering and backing their word up. I have
to back up their word.
Q. Do you want to take a break, Ileana?
Q. Do you want a tissue?
A. That's all right.
Q. Okay. Now, do you recall how -- I know you indicated before that there were
a lot of sessions. Can you recall how long a session would last
A. No. I just remember they were long, or until I remember.
And when I came back with nightmares that I have had the night before, we had
to go through the nightmare again. I had to tell it and I had to transport
myself into the house again. And once that was over, then we'd take a break
into the next day.
And then the next day I had nothing to say. And then they'd tell me something
else that the kids said, and I have no memories, and I tell them I don't
remember, I don't remember. So they said that then it was time for me to go and
rest. And I had to think at night -- before going to bed, I had to think and
try to remember real hard. And I just had to clear my head again and then rest,
and that everything was going to come up, because it was a defense that
I had. My own mind was defending me from the memories. So that's what I used to
do for that whole period.
Q. Did there -- did there come a time during these sessions that you believed
or came to believe that you, you know, and/or Frank had sexually abused any of
A. I -- after -- how can I explain you? After talking to the psychologists and
after having the bad dreams, I came to a point that those things really had
happened because they convinced me that I was remembering everything through my
dreams, and I came to realize that maybe those things happened.
But one thing that I always argued with them is how come I didn't have memory
of it. I mean -- and they told me that with time I will know it.
But, you know, it's like when you know you did something, you broke something,
but you know you did it, you know, even if you -- if you tell your mom, no, I
didn't do it, but you know you did it.
And I didn't have that feeling. You know, it was just -- it was just something
that had happened that it was true, but- I didn't know about it because of this
blackout that they said I had.
At the end of their session, Cohen asks Ileana if she has anything else she
wants to add for the record. At this point Ileana insists that sexual abuse
did not happen at Country Walk.
Q. I think I've just about covered everything that I wanted to cover here with
you today, Ileana.
Anything else that you can think of that, you know, we've spoken about here
today that you've told me that you might want to add to, or anything else that
you can think of that I may not have inquired about that you would like to make
part of your statement here today?
A. No, just that -- that I'm still trying to clear up what happened, you know,
after knowing that there could be a possibility that these things never
happened. You know, I just -- I want to know the truth. But the truth of it is
that none of these things happened because there's no way that I cannot
remember. How come I remember what I was six years old and how come I remember
my school? I even remember the bad times I had with Frank. And I don't
remember anything with the kids. And I always had the -- you know, after
getting out of the prison, you know, I told myself that maybe the kids would
grow up and they will remember, too, that nothing happened to them. And that
maybe if that happened then I'll know what really happened to me.
And the only things I remember is what I briefly told you, you know, is the
times in jail. That's what's been traumatic to me. The times in jail were
awful. I mean I had -- I have no peace at all. I remembered that -- the lights,
the coldness, the people banging on the doors, you know.
And then the doctors, they were there day and night. They were there on the
weekend. And I didn't rest until I said whatever I had to say, you know,
whatever would help the kids in court, because otherwise he was going to get
out and he was going to get me.
|+||Read the full transcript of the deposition as published in the journal
Issues in Child Abuse Accusations.|
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