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 by defense.)

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 secret.

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 technique?

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 of them.

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 correct?

Yes.

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?

Yes.

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 that procedure?

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 five-year-old?

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 about.

Was your interview with Leslie, was her disclosure to you consistent with the pattern that you have just described?

Yes.

What was your fee in this case, Doctor?

Nothing.

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?

Yes.

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?

No.

Why not?

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?

Right.

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, wasn't it?

Yes.

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 you?

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 there.

Dr. Braga, are you aware of studies of children, especially younger children, that can be influenced or vulnerable to leading type questions?

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 correct?

Yes.

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.