DIRECT EXAMINATION BY MS. LAMB:
Q Okay. Well, let's talk first about your hiney then; did [Mr. Bob]
ever touch that part of your body?
A Yes, ma'am.
Q With what part of his body did he touch with your hiney?
A He did it with his finger.
Q Where did he put his finger?
A In my hiney.
Q How did that feel?
A It didn't feel very good.
Q And were you at Little Rascals when this happened?
A Yes, ma'am.
Q Do you remember where at Little Rascals, one time?
A Um, I think it was at the old house.
Q At the old place. And it happened at the new
place, too, didn't
it?
A Yes, ma'am.
Q Okay. Now, let's talk about, um,
anything else that Mr. Bob put
in your hiney. Did Mr. Bob put another part of his body in your hiney?
A Sometimes.
Q Okay.
A He would -
-
Q Can you tell me what part of his
body, what other part he touched you with besides his finger?
A He would sometimes do it with his foot.
Q Okay. How did he do that?
A He would sit down and do it with the chair.
Q What do you mean?
A I know you know what a chair is, so he pulled the chair up and sat down.
Q Okay. And where were you?
A I was in the -- using the bathroom.
Q And what would happen?
A Um, he would stick his foot out and do it.
Q Do what?
A Stick his foot in my hiney.
Q Now, let's talk about, um, anything else that Mr. Bob
touched your hiney with; was there another part of his body that he touched
your hiney with that was private to him?
A (Shakes head).
Q All right. Do you remember
telling your mom about Mr. Bob
putting his penis in your hiney?
A Yes, ma'am.
MR. MILLER: Objection.
THE COURT: Overruled.
BY MS. LAMB:
Q You do remember telling your momma about that?
A Yes, ma'am.
Q And did Mr. Bob put his penis in your hiney?
A Yes, ma'am.
Q How did that feel when he did that?
A Um, it didn't feel very good.
Q Now, did he ever put anything in your hiney besides his penis and
his finger?
A One time he put an ink pen.
Q An ink pen?
A Yes, ma'am.
Q And anything else that you remember?
A No, ma'am.
Q Do you remember telling Doctor Betty
about Mr. Bob putting a knife
in your hiney?
A Yes.
Q What part?
A Since -
-
Q Go ahead, I'm sorry.
A -
-
since you mention it now I remember it.
Q Okay.
A It was the round part that you hold.
Q So the round part that you hold is not the sharpened end of it?
A (Shakes head).
Q Okay. Do you remember -
-
A Like that (indicating).
Q And did that happen? Did Mr. Bob do that to you?
A Yes, ma'am.
Q And you told Doctor Betty about that, didn't you?
A Yes, ma'am.
Q Now, did something happen to your penis that Mr. Bob made you do
that you didn't like?
A Yes, ma'am.
Q What did Mr. Bob make you do that you -
-
A He made me -- he made me stick it up against his hiney.
Q Made you stick what up against his hiney?
A My penis.
Q And did he ever make you put it somewhere else besides against his hiney?
A No, ma'am.
Q Do you remember telling your momma about having to put your penis
in Mr. Bob's mouth?
MR. MILLER: Objection.
A No, ma'am.
THE COURT: Overruled.
BY MS. LAMB:
Q Did that happen to you, did you ever -- did Mr. Bob ever make you put your penis in his mouth?
A Yes, ma'am.
Q And you told Doctor Betty about this?
A Yes, ma'am.
Q And you told your momma about it, too, didn't you?
A Yes, ma'am.
Q And do you remember Mr. Bob ever --whether Mr. Bob ever put his penis in your mouth?
A No, ma'am.
Q You don't remember that?
A No, ma'am.
Q Did Mr. Bob ever put his penis in your mouth and you didn't want
that to happen?
MR. MILLER: Objection.
THE COURT: Overruled.
BY MS. LAMB:
Q You said what now?
A Yes, ma'am.
Q And did he do something when he put his penis in your mouth?
A No, ma'am.
Q Did you tell your mother about that happening to you?
A Yes, ma'am.
Q And do you remember a time where you ever had to do anything to
Mr. Bob's hiney with your mouth?
A No, ma'am.
Q Do you remember telling Doctor Betty that one time you had to lick
Mr. Bob's hiney?
MR. MILLER: Objection.
THE COURT: Overruled.
BY MS. LAMB:
Q Did that happen? Did you ever have to do that that you didn't
want to do it?
A Um, yes, ma'am.
Q Now, when sometimes these things would happen to you, um, would
you be afraid to go home and tell your mom and dad about it?
A No, ma'am.
Q But you didn't go home right then and tell them about it that day,
would you?
A No, ma'am.
Q Did Mr. Bob tell you what might happen to you if you were to go
home and tell them about what he had done?
A Huh?
Q Did he ever tell you what might happen to you if you went home and
told your mom and dad what he had done to you?
A Uh-
huh.
Q What did he say would happen?
A He said he would kill my dog.
Q Did he ever tell you that he would kill your mommy and daddy?
MR. MILLER: Objection.
THE COURT: Overruled.
A Yes, ma'am.....
CROSS-EXAMINATION
BY MR. SPIVEY (FOR THE DEFENSE):
...
Q Okay. On the times when you were taking your nap tell me what happened when Mr. Bob came in the room?
A I don't know, because I was --I think I was asleep usually.
Q Okay. Well, how did you wake up?
A I would wake up, Ms. Shelly would come and push --go like that so I would wake up, and then she would take my mat and put it
up.
Q What about the times that you were in there taking a nap and you
said that Mr. Bob came in and took you to the bathroom?
A Uh-
huh.
Q Okay. Who woke you up then?
A He did.
Q And tell me what happened after he woke you up?
A He picked me up and he pushed me in the bathroom.
Q Did the other children stay asleep when Mr. Bob picked you up and pushed you in the bathroom?
A Yes, sir.
Q What happened after Mr. Bob pushed you in the bathroom?
A He closed the door.
Q Okay. What happened then?
A He touched me where he wasn't supposed to.
Q What did you do when Mr. Bob did that?
A I could --I couldn't do anything cause he was too big and I was too small to --to hurt him or anything.
Q Okay. Did you say anything to Mr. Bob?
A Um, no, sir.
Q Did Mr. Bob say anything to you?
A Yes, sir.
Q What did Mr. Bob say to you?
A Um, he would --he would say," turn around," and
that's mostly all he would say.
Q Okay. When you left the bathroom, Andy,
what did you do then?
A I got back on my nap --my mat.
Q Okay. When Ms. Shelly came back to the room,
did you tell Ms.
Shelly?
A Um, no, sir.
Q Why not?
A Cause she was a part of it, too.
Q Okay. Now, why do you think Ms. Shelly
was a part of it?
A Because, every time at nap time she would just leave us in the
room and she would go somewhere and usually she would be in the nursery.
Q Okay. Well, why didn't you tell Ms.
Dawn or Ms. Cindy?
A Well, I couldn't get up from my nap cause Ms. Cindy was in the
nursery and Ms. Dawn was gone somewhere, she was gone to get snacks.
....
Q Did someone put a --do you know what a tree saw is?
A No, sir.
Q Okay.
A Is it one of those things it's electric and --and you have to pull
a string and it goes like Rrr-
Rrr-
Rrr-
Rrr-
Rrr
and it cuts a tree down.
Q
Andy, did anybody ever put one of those in your hiney?
A No, sir.
Q Did you ever tell your mom or Doctor Betty that someone at the day care put a tree saw in your hiney?
A Um, no, sir.
Q All right. If you said that that would not be
the truth, would
it, Andy?
A Well, I don't know because it was so long back I can't remember
all these things because it was -
-
I was a little kid back then.
...
Q Andy, did you tell your mother one time
that, ah, ah, Bob didn't
stick his finger in your hiney, that that was something that David had told
you?
A Excuse me. What did you say?
Q Did you tell your mother that David
told you the things about Mr. Bob touching your bottom?
A Yes, sir.
Q And is that something that David had told you?
A Yes, sir.
...
Q Okay. Now, was it at nap time that
David told you this?
A Yes, sir.
Q What did David tell you?
A He said the wrong -
-
the things that Mr. Bob
shouldn't have done, like -
-
like, you know, yeah, taking a knife and sticking it in my hiney or
something.
Q Now, did you tell your mom that those
were things that didn't
really happen to you, that they are things that David said happened?
A Well, they did stick a knife in me, a knife thing in me.
Q But did you tell your mom -
-
Andy, did you tell your mother that those are things David told you and
they didn't really happen to you?
A Um, well, the knife did happen to me and I told my mom about it.
Q Did you ever tell your mother that
David told that to you and it didn't really happen at all?
A Uh-uh.
(Shakes head).
...
Q Now, tell me what happened when Mr. Bob peed in your mouth.
A He, um, unzipped his pants and unsnapped them and he peed in my
mouth.
Q Okay. Did he get your clothes wet?
A No, sir.
Q Did he get the carpet wet?
A A little bit.
Q What happened then?
A Then he zipped them back up because the kids were coming in from recess -
-
I mean, they were coming in from recess.
Q Did you tell anybody or any of the
children that happened?
A Um, no, sir.
Q Okay. Do you remember telling
Doctor Betty when that happened
that his pee was purple?
A No, sir.
Q Was it?
A I don't know. I think it was.
Q You think it was purple?
A It looked yellowish- white.
Q It looked yellowish- white?
A Uh- huh.
Q Why did you think it was purple?
A Because -
-
because I was little enough that I couldn't understand colors back then.
....
Q Andy, did any bad things ever
happen to you when you were in
the old day care, at the old building, the house?
A Um, sometimes.
Q What kind of bad things happened there?
A Sometimes he would push you around and sometimes, Bob would push
you and get mean and usually he was real, real bossy -
-
Q Okay.
A -
-
and stuff.
Q Did he ever do anything besides
push you around and be bossy?
A Sometimes he would take you in the bathroom and do stuff he wasn't
supposed to.
Q What kind of things would he do
that he wasn't supposed to?
A Um, stuff that he wasn't supposed to do.
Q Did you see any of those things happen?
A No, sir.
Q Then why do you think they happened?
A Because, everybody -
-
everybody -
-
I was -
-
I was near the last, so everybody I saw that it happened -
-
everybody I saw -
-
everybody got a chance, to, um, get pushed in the bathroom, and something
happened to them. Something had to happen to them if they got pushed in the
bathroom and Mr. Bob went with them.
Q Why do you think that something had to
happen to them if they got
pushed in the bathroom?
A Well, Mr. Bob pushed them in the bathroom and then he went in
there and closed the door; what are you expecting -
-
....
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