Names of all children and their families have been changed.
The following are excerpts from Dr. Laurie Braga's testimony during the Harold
Grant Snowden trial in which she explains the techniques she used in
interviewing Leslie (not her real name), the primary child witness. (These
excerpts include both direct examination by prosecution and cross examination
Can you give me some examples of some of the reassurances that you gave
Leslie in the interview and explain why it is you found that it necessary to
employ that procedure?
Sure. In interviewing a child like Leslie, who, there was a possibility she may
have been molested, it's important to give a child who may have been molested
reassurance that they didn't do anything wrong. If somebody told them not to
tell, that it was okay to tell, that they are brave to tell and that their mom
and dad would not be mad at them because, from all the experience that I had
with children who have been molested, they are generally told outright or if
they are not told outright, they are given the definite message that this is a
Children who have been molested are either told not to tell this or you are
going to get in trouble, or your mommy and daddy are not going to love you
anymore, that they are going to be mad at you, or if they are not told that
outright, they get the definite feeling because this is something that other
grownups don't do to them, that this is something they are not supposed to
tell, and that it is bad. It is very hard for them to talk about it. It's
really important to counteract the fears they have about telling, to give them
reassurance that it is okay to tell, that mommy and daddy won't be mad, and
that they are not going to get in trouble no matter what they are told.
When you interviewed Leslie, did you explain to her what the purpose of the
interview room was, and if so, can you explain why you employed that
Yes, I did. The reason why is because, again, kids who have been molested feel
that they are the only ones, and they feel very frightened and very alone, and
it is important to give them reassurance that other people have gone through
something like this, that they are not alone, and to make them feel
comfortable. It can be said in such a way that if the child, the particular
child that you are interviewing, has not been molested, then it is not going to
upset them, but if they have been, then it would give them the information that
they are not alone, and that it's okay.
What is "the yucky secrets doctor?"
That's my way of explaining to the child that I am not the kind of doctor that
gives shots, I am the kind of doctor that kids come to to tell me something
that is a yucky secret, something that is a secret, and something that is hard
to talk about.
When Leslie revealed the details about the sexual abuse, what if anything
did you do?
I didn't praise her, per se, but I gave her reassurance, again, that it was
brave of her to talk about it, and nothing bad would happen to her.
Does this reassurance, in your opinion, affect the reliability of the
child's information and the statement?
It affects the reliability in a positive way, in the sense that the child would
feel comfortable and feels reassured that nothing bad was going to happen, that
they are able to be comfortable enough to continue to tell details of what
happened to them, including the things that they are holding most deep inside
What is the term in psychology--diversionary behavior--and can you apply
that term to any other observations that you made in the tape of Leslie?
As a general term it means behavior which is a distraction from something else.
In terms of observing the tape of Leslie and her behavior, like a lot of kids,
it's very, very hard to talk about what happened, so there is a tendency to try
to talk around it before getting to the point of really being able to say,
"Here is what happened to me."
Like beating around the bush?
Yes, like beating around the bush.
You used anatomically correct dolls in your interview with Leslie, is that
Why did you find it necessary to put a name to the doll? Why didn't you just
let her play with the dolls without naming them?
That depends on the particular focus of the interview, whether or not you name
the dolls or not name the dolls. If a child is brought in, who had a rendered
hymen, and that child was -- that child came home that way, and somebody
noticed this child definitely had been abused, but who did it? Then, of course,
you would never name the dolls, because that is the question, whereas, in a
case like this, the information was that the child had been to a babysitter's,
that the names were Grant and Janice, and the question was not who were the
people, but did anything happen.
At a certain point on the tape Leslie denied any abuse occurred to her, and
you asked her whether she was threatened or whether she was afraid to tell, and
why did you employ that procedure?
I don't think I used the word "threatened," but I did ask her something to the
effect of whether she was afraid to talk about it.
Why did you do that?
Because, again, in my experience in working with kids who have been molested,
they are generally very much afraid to tell, and by asking, "Are you afraid to
tell?" and telling them, "It's okay to tell," that again helps them, makes it
more comfortable for them, if there is something for them to talk about.
Did you use leading questions in your interview with Leslie?
Can you explain why and how you used them?
Okay. There are different degrees of leading questions, from something as
leading as, "Did so and so put his penis in your mouth?" to "Did so and so do
something to hurt you?" to "Hi, how are you?" And the degree of leading that
you give a child depends on a number of things--the child's age. The younger
the child is, the more you have to ask leading questions, just because of the
level of their understanding and vocabulary. Also, their comfort. In the
interview with Leslie, I started out very open ended: "Do you know why you are
here?" et cetera. " Did something happen to you?" and then I would proceed, as
I observed her behavior and observed her trying to tell me something, that I
needed to help her a little bit so that she would feel more comfortable.
Do you feel that you were feeding Leslie information or answers by employing
Not at all, no.
At certain points in the tape you used some "either/or" questions. Could you
explain why you would use those type of questions?
For the same reason in talking about questions, given the age level and the
ability to understand language of the child, sometimes it's necessary to give
them a choice of two or three things. Also, I remember specifically, specific
examples with Leslie where she had the dolls, and she put her finger inside
what looked to me, she was putting her finger inside the vaginal area of the
girl doll and said something. In order for me to check what it was she was
telling me, which particular area to make sure that what she was showing me was
in fact that she was showing me that he put his finger in her vagina, I asked
if he did put it in her vagina or in her bottom, and I believe she answered in
the vagina, and that's an example of why I would give a choice like that.
Do you think it would be possible for a young child to be coached about
being sexually abused?
It's possible, but it's extremely rare and difficult to do.
Why is it extremely rare and difficult to do?
For one thing, very young kids have very limited memory for things that did not
actually occur to them. If you say to a child, for example, "Go upstairs and
get your coat and close the door, come down and we are going for a ride," by the
time the child goes upstairs, they are going to forget to get the coat, close
the door, and they might go back downstairs and forget to do half the things.
Children don't have the capacity in terms of their memory to absorb and give
back very much, and for a young child, four, five, six years old, it's very
limited. There is not a limit in terms of what they actually experience, but in
terms of what somebody can teach them and have them remember, and give back in
the same way, it's just very limited in young child.
Can an adult remember events that happened to them better than a four- or
Well, the research on memory has shown that although there is a significant
difference in the ability of adults to take in information and give back
information that an adult can do, as opposed to a child, there is really very
little, if any difference, and sometimes children are actually better in terms
of details of what happened actually to them as compared to adults.
In the course of your interview of thousands of kids, three or four hundred
alleged victims of sexual abuse and one hundred confirmed victims of sexual
abuse, have you noticed a common pattern of disclosure of the sexual abuse
event by children?
Yes. I have seen a common thread, a common pattern of how children disclose.
They typically will start off by saying -- either by saying nothing happened or
they will say something happened, but they will either say the least of what
happened, or they will say something happened, but it was just some other kid,
or something happened and that they saw it. Then they will gradually, as they
become more comfortable, they will begin to open up more and say what happened,
actually what happened to them, "This is what actually what happened to me," and
gradually, as they become more comfortable, they will build up to the worst of
what happened to them, especially anything that they feel personally
responsible for, as if they themselves were a partner in the crime and did
something real bad. Then after having disclosed, if they [are] then met with
openness and comfortableness, from someone else, say their parents, then they
will continue to open up and continue to tell what happened. If they are met
with, "I don't want to hear this stuff," or they are with a person who is in an
adverse position to them who is sort of saying to them, "Well, this didn't
really happen, did it?" they will then retract what they said, take it back and
say, "No, it didn't really happen," or of they don't completely take it back,
they will say the things that are the easiest and not the hardest to talk
Was your interview with Leslie, was her disclosure to you consistent with
the pattern that you have just described?
What was your fee in this case, Doctor?
You told us that sometimes children are afraid to tell about incidents of
sexual abuse because they have been warned not to tell by the abuser. Isn't it
a fact that, during the video tape session that you had with Leslie, you
specifically asked her if Harold Snowden told her not to tell anybody, and she
specifically told you no?
I believe at the time that I did ask her, that she did say "no" with her words,
but did say something else with her behavior.
And the tape will reflect that?
You testified before about initial disclosure by a child. You said that,
according to the syndrome that you are familiar with, if a child initially
denies an incident of abuse, that is consistent with the syndrome of abused
children; is that correct?
No. What I actually said was that it's common for children who have been abused
to initially deny, but that doesn't mean that every child who initially denies
has been abused nor does it mean that every child that has been abused
initially denies. That just means that amongst the population of children who
are confirmed to have been abused, a large majority of them do initially deny
having been abused.
So then, what you are saying is that if a child initially denies it, then
that is a factor that can indicate that the child has in fact been abused? Is
that what you are saying?
What I am saying is exactly what I said, which is, the fact that a child
initially denies doesn't preclude the possibility that the child has been
abused, and in fact, many children who have been abused do initially deny.
And many children who have been abused initially disclose?
No. Actually, it is unusual for children who have been abused to initially
disclose. It does happen, but because of the children's discomfort in talking
about this, it is more common for children to initially deny, and then later
feel comfortable enough to disclose.
Does the nature of a sexual abuse event affect a young child's ability to
remember the event at a later date?
Yes, it does, because a sexually abused child -- it is traumatic to the child,
whether it is done violently or gently, it's nevertheless traumatic to the
child, very upsetting to them. We all remember experiences, whatever our age.
If there is some emotion attached to it, if the emotion is negative emotion,
then it is something really scary, and it is going to be imprinted heavily.
Can a young child fabricate an event of sexual abuse if there is no basis
for it in his life experience?
Because children, as I explained before, children are very much tied to the
here and now. That's how they learn. They learn from their experiences. Even in
their play, they play out what they have experienced in their life, so they
cannot draw from out of the sky something they have never experienced.
Can you get kids to say something that is not true?
No, I cannot.
You have testified. I believe, on cross examination that your whole role in
working with the State Attorney's office is to enable the child to make a
statement, whatever the statement may be. Is that what you testified to?
So when you spoke to Leslie during the tape and she told you that she
watched TV and then Grant turned off the TV and then you said, "You cried?" and
she said "Yes," and he turned off the TV, you said, "Why did you cry?" and she
said "He turned off the TV, " and then you asked her, "Did he do anything
else?" and she shook her head. You then asked her if he did anything else to
make you sad, and she shook her head. Then you asked her, you said, "Can you
tell me what he did?" and that's when she said he picked her up and dropped her
on the floor. You said, "He dropped you on the floor?" and she said, "It was a
hard floor in the kitchen." "Did you fall and hurt yourself?" and she shook her
head. "Did anything else happen that upset you?" "No." That was the statement,
When you still, later on in the video, asked her to tell what happened that
second day, to tell another story, and she told you another story, and she told
you another story of watching TV with Grant and Janice came home and Leslie
spontaneously said Grant did not do anything, Grant didn't make her sad, she
wanted to stay at Grant's house forever, then she pretended to pack a suitcase
so she could stay at Grant's house forever, was Leslie making a statement to
The child at that point in the interview, in the initial things that she was
saying, was telling some things through words, and also telling some things
through her behavioral reaction, through things she was doing with the dolls
that she told me was something which upset me, and she was using a story to try
to build truth, and a lot of this was -- a lot of this was about diversionary
behavior, to build up to the point where she can talk about what happened, and
in the process of that, she talked about various things. She was basically
making up a story about some of the things that would happen when she would go
Dr. Braga, are you aware of studies of children, especially younger
children, that can be influenced or vulnerable to leading type
Am I aware of studies that suggest that? I am also aware that those studies are
a problem in a number of ways. One, most of the studies that exist are either
directly or indirectly related to studies that were done at the turn of the
century, which did not compare children to adults, but simply looked at kids in
a very basic, prejudiced way against children, and even the kinds of studies
that are done now, there are some studies that are showing that children are
not any more susceptible than adults, or suggestible than adults. And in some
studies, children are actually able to remember things, not be as suggestible
as adults. The problem though in interpreting and applying those studies to
child sexual abuse is that the nature of those kinds of studies do show studies
on adults in cases in cases where I do compare them with adults, to show them a
slide of something, and then ask them a question, adding in something that was
not in the slide, and then asking them questions later to see if they include
that in their answer. That's a very abstract kind of thing, and has no real
relationship to something as profound and physical as child abuse.
Was it leading to tell Leslie that a lot of children come in here and talk
about things that happened that made themselves sad, and they take their
clothes off, on the dolls that is, to show you before they make any mention of
sexual abuse? Is that leading, in other words?
It's leading to some extent, yes, but you have to look at it from the point of
view of the child.
When I said something about the reason the clothes are torn, is because a lot
of kids come in here and they take off the clothes and tell me about something
that happened. I didn't say anything about sex, from the point of view of the
kids. I could have been talking about daddy pulling down her pants and spanking
her with a belt. I have interviewed kids, not only in terms of child sexual
abuse, but physical abuse, to show there is something implied in that question
at that point about sexual abuse, and I was simply telling her if something had
happened to you, you are not the only one, and if something bad happened, it's
okay to talk about it, that you are not alone.
What you did in this case was a criminal investigative interview; isn't that
And the first time you ever did an interview like that was in August 1984,
and this occurred in September 1984?
I don't know the exact dates.