Defense Considerations in The Child as Witness in Allegations of Sexual Abuse.
Part III: Defense Strategies for the
Falsely Accused Individual
ABSTRACT: Although the false allegation of child
sexual abuse does not always start with a child, the child becomes the
key to unlocking the mystery of how the allegations came to be
made. The following article is the third of three parts and deals
with the anatomically correct dolls, strategic planning and the child as
a witness at trial. Part III is directed towards recommended
strategies for an individual who has been falsely accused of sexual
Anatomically Correct Dolls
"Anatomically correct" dolls are used in
almost all cases involving young children. It should be noted that
if, as it is claimed, the child is competent to testify, having the
ability to receive correct impressions by his senses and to recollect
and narrate intelligently, the dolls are unnecessary.
The dolls are generally about 20 inches in length,
the mature females protrude breasts, the man and boy child have
penises. The female dolls have oral, anal and vaginal
openings. The man and women dolls have public hair either of dark
embroidery or fur. The dolls have fingers. Police officers,
social workers and even psychologists believe that by carefully
observing how a child plays with the dolls, they can determine whether,
when, where, how and by whom a child has been molested. Take for
example, the following report by a therapist describing how the child
clearly named with the use of the dolls her father as the perpetrator of
... I introduced the anatomically
correct dolls and then asked her to pretend the girl doll was
herself. When I asked who the male doll was, she unhesitatingly
said: 'Daddy.' When asked to demonstrate with the dolls what daddy
had done, she inserted the male doll's finger into the vagina of the
girl doll. She then showed the dolls kissing. After much
hesitation and seemingly embarrassed, she took the female doll and
straddled the lap of the male doll in such a way as to show that the
male doll and female genitalia were touching. She then turned the
female doll around and sat her in the opposite direction. She then
said she didn't want to talk about it anymore.
"The fact is that normal
children know a doll is a plaything, not a person, and their behavior
when playing with a doll has nothing to do with their own real-life
experiences. Little Sally might throw her doll on the floor and
step on it, although she never acts like this with her baby
sister. Little Sidney might twist the doll's head around to see if
it comes off, although nobody has ever twisted his head in his
life. Yet, untrained state personnel hand a preverbal or barely
verbal child one of these dolls with its huge, bulging genitals
("anatomically correct" dolls are anatomically complete, but
not anatomically correct), and believe that if the child even notices
the genitals that he or she is "acting out sexual abuse."(1)
It should be noted that these dolls are made by toy
manufacturers. They are not made by the people who make scientific
instruments but by people who make toys. They are sold, not by
established organizations who sell such things as the MMPI, the
Stanford-Binet IQ test, or the Rorschach test, but by people who are in
business to manufacture this type of toy.
As Mclver, Wakefield and
Underwager have stated: "Our results suggest that the information
obtained by the use of these dolls in interviews is misleading.
The dolls are likely to increase the error and decrease the reliability
of the information gathered. Any information obtained from such
interviews should be discarded. There is nothing to support their
use as diagnostic or assessment tools. ... The dolls are not generally
accepted in the scientific community and nothing obtained from their use
should ever be admitted into evidence. ..."(2)
The scant instructions on how to use the dolls are so
suggestive, not only to the child but to the interviewer, that both
embark on a journey of self deception. For example, one so-called expert
suggests that the collection of dolls should have four — mother, father,
boy, and girl doll. Even if there were some validity to the
interpretation of doll use, limiting the use to one "daddy"
doll selectively steers the doll to Daddy rather than to a choice of
other significant and likely candidates, such as the live-in boyfriend
or teen-age neighbor.
In playing with the dolls, it is not uncommon that
the young child creates a nuclear family even though the real father has
not spent ten seconds with the ex-wife in the last three years. Fantasy
Dr. Susan White suggests a protocol (3) for the use
of dolls where the interviewer is "blind." Information as to
who the child first named and other information is withheld from the
interviewer so that suggestions and prompting can be avoided. This is
aimed at preventing the interviewer from influencing the child. This
protocol is seldom used because, in those cases of false allegations,
the use of the dolls would not have any value. A child with nothing to
report will report nothing. This, of course, spells failure on the part
of the interviewer who wants to save the child. Therefore the protocol,
because of its reliability, will not be used.
The Mclver, et al. study (4) reported several
important findings concerning the basic assumptions underlying the use
of these dolls. Among them were the following:
(a) There is no empirical evidence for the assumption
that "Children will identify gender (or the 'sex' of the dolls) on
the basis of primary sexual characteristics rather than on the basis of
Although I presume the study did not involve a group
of children of nudists, it makes sense that children as well as adults
do not examine genitalia of strangers to determine sex. Adults make the
determination without removing the clothing of strangers, and yet, the
interviewer using the dolls will often suggest, "Let's take the
pants off to see if the doll is a boy or a girl."
b) There is no empirical evidence supporting the
assumption that: "Children will not demonstrate, either
spontaneously or in response to the interviewer's verbal and/or
nonverbal cues, sexual acts that did not occur."
Indeed the evidence is that the dolls in and of
themselves are suggestive. This is known as the "doll effect,"
that is, the use of the dolls in and of themselves, creates behavior
which is then interpreted as being evidence of abuse.
c) There is no empirical evidence for the assumption
that "The things nonabused children do with these dolls will be
different from the things abused children do with them."
The defense of a false allegation of sexual abuse is
unlike anything either you or your attorney has ever seen. It is not a
battle, it is a war, and as a war it needs money, soldiers, a will to
fight, and strategic and tactical planning. The following list of
considerations is set forth neither in importance nor in a chronological
order, as many of the actions should be implemented at the same time.
The outline is limited, and does not involve such things as choosing an
attorney, preparing an alibi defense, or many of the other elements
which go into a successful defense strategy.
1. Do not act guilty.
Fleeing from the scene of a crime has traditionally
been considered as evidence of guilt. If you "agree" to make
certain concessions, such as no contact "until this matter can be
looked into," your guilt, rather than your willingness to
cooperate, will be presumed. If someone were to publicly call you a
crook, if a newspaper were to run an article saying false malicious
things about you, what would your response be? Unless there was some
basis in fact, you most likely would be at an attorney's office
demanding a retraction, and threatening a suit for slander and/or libel.
If a physician committed malpractice by wrongfully making a diagnosis,
even of child abuse, based on an inadequate physical examination, again
you would be seeking legal advice about a possible malpractice action.
Under the laws of slander, if one repeats a statement
made by another, even if made by a child, and the statement relates to
accusing one of a crime (such a child molestation) or defames one in his
business or professions, the tort of defamation has been committed.
repeating of a lie is no less harmful than the original statement.
should go on the offensive and demand accountability. Those well
intentioned people who are accusing you of the most dastardly crime
known to man must realize that there is a downside to the spreading of
false and malicious statements about you. You must remind those who would do you harm that
they also must be accountable for their actions and their opinions.(5)
2. Do not waive any rights especially to a hearing.
You may find yourself undergoing several litigation
events at the same time. If you are a teacher accused of abusing a
student, you probably will be defending a criminal action as well as
seeking to retain your job. If you quit without a hearing, the
presumption will be that you are guilty. If you are a divorced parent,
you may be fighting the criminal charges, as well as a change of custody
or termination of visitation proceeding. If you are a parent of a
teen-age child, you may be fighting both an abuse and neglect proceeding
and the criminal charges as well. In any of the above you may be sued
for assault and battery of the child.
It is tempting to waive the rights to a hearing in
one action in order to focus your energies and monies in the other
action. However, every time you give up a right to a hearing, you give
up the enormous rights to (a) an official version of what happened and
(b) general discovery of the case against you. There are different rules
of discovery in the criminal arena and the civil arena. Basically you
can obtain more information in the civil or family court than you can in
the criminal court. Thus if you waive any rights to proceed in the civil
court, you are giving up significant opportunities to learn who the
witnesses will be, and what they will say. You will lose the opportunity
to discover the details of the abuse including when, where, who, why,
and who was present.
3. Keep contact with the alleged victim.
There are many reasons to keep in contact with the
alleged victim. If the child is your own, no matter how you feel, the
child needs you. No matter what the child says, the child will continue
to need you. Stay involved for your sake and your child's sake.
needs for you are certain, critical and constant. Do not let the
short-term whims of a child control her long-term needs. Without contact
the child can be brainwashed against you. If you stay in contact, it is
difficult for the child to believe what others are saying because it
conflicts with the real first-hand experience of your child. If the
child is a teenager, and if the false allegation is the result of
custody/visitation problems, it is easy to concede and let the child
live with the other parent. To do so, however, without a hearing,
removes you from the sphere of influence and destroys any chance of having the child come
to grips with what was said and
why it was said.
If the situation is a divorce custody problem do not,
under any circumstances, agree to have the matter continued unless
visitation (supervised, if necessary) can be arranged. If the mother
wants more time, or wants time to have a psychologist do a study, it is
because she needs the time to better prepare the child to testify
against you. A continuance gives her the opportunity to obtain
additional "expert" witnesses and rehearse the child. Their
case gets better while your case gets worse. There is a natural
inclination on your attorney's part to want more time to study and
prepare. But unless you maintain contact with the child, there is no
guarantee that the court will reassign the case within a reasonable
time. In one recent case it took two years to obtain a full hearing.
experts then came to the unanimous conclusion that whether the three and
one-half year old child was sexually abused by the father didn't matter.
Since she now believed that she was sexually abused, the father should
have no contact with his daughter.
The second reason to keep contact is that your child
may suffer separation anxiety if your child is deprived of contact with
you. (6) The "behavioral manifestations of child abuse" with
one or two exceptions track the behavioral manifestations of parental
separation anxiety. Thus, your absence may induce behavioral indicators
which will then be used as evidence that the child has been abused.
The third reason you should maintain contact is that
the nonverbal reaction of the child to the pleasure to your company may
be more telling of the relationship than what the child testifies to on
the witness stand. In one case, while the litigation dragged on for
years, the father had illicit visitation with his daughter. During many
of these visits pictures were taken of his daughter and her father
having fun. At the trial the daughter testified how she
"hated" her father for the things he had done to her. When
asked what good things about her father she could describe, she could
not offer one. When shown a picture of herself having fun with her
father after the abuse is supposed to have occurred, and asked to
explain the picture her response was simple: "That's not me."
With that her credibility fell to zero.
A fourth reason to maintain contact is that you may
have an opportunity to have your own psychological evaluation of the
child done. Without contact you may have to rely on the psychologist
chosen by the state or someone else. If there are criminal matters
pending, you may never get an independent psychological evaluation.
If your child is the victim and she has
been sexually molested, you may be able to discover independent evidence
as to who is doing it. After all, everybody else may have closed the case
knowing that you are guilty. Only if you keep contact will you be able
to find out who the real perpetrator is.
The final reason to maintain contact is to avoid the
dilemma occasioned by the lack of contact. Thus, if because of court
imposed delays several years go by without you having seen your child,
any chance of obtaining custody or meaningful visitation will be
lessened because of the "shock" the child would have after not
seeing you for many years.
4. Obtain expert psychiatric review
In addition to having a good lawyer, a competent,
experienced, honest, psychologist or psychiatrist is essential. One
cannot rest on a defense that "it" (whatever "it"
is) never happened and therefore I have nothing to worry about. The mere
fact that a child has allegedly said certain things that led to the
conclusion of child abuse is enough for the court system to presume
guilt. It is therefore important to hire for evaluation and/or testimony
an expert who can explain the origin of allegation. It may be as simple
as explaining when the child said "candle in my vagina" she
was in fact describing "candies in my jamies."
One psychiatrist recently testified that the
four-year-old child did say that her father was "bad" but it
was in a rehearsed manner. By observing her play (with regular dolls) he
noted that the child consistently thought of the father as a protective
and fun-loving individual. He concluded that there had been no sexual
Sometimes, if visitation continues, (even chaperoned)
it is possible to have the child examined privately. if that can't work,
one may have to ask the court to appoint someone. This may have risks if
the court traditionally appoints a psychologist who is known to find sex
abuse with every child. Also you can be sure that the court-appointed
psychologist's report, good or bad, is going to be available to everyone.
If it is against you, you will have an impossible burden.
Have a clear understanding with the psychologist in
advance of the evaluation as to the protocol to be used. Will father be
able to be examined in the presence of his daughter? Will the
psychologist be able to see the child alone? Will the mother be
interviewed? Where will be interviews take place and when is the target
date for the report?
5. Obtain inadmissible evidence in support of your
Many of the issues (such as interim visitation) are
resolved without a trial. Therefore it is important to secure
nonadmissible evidence which can have tremendous impact on settlement
discussions. Thus, a lie detector test should be obtained at the first
opportunity. It should be done out of state by a competent lie detector
examiner. If the test is done locally, and if the test is failed, you
run the risk of word getting out that the test was failed. This may hurt
you in the eyes of your attorney as well as everyone else connected with
the case. Pay the examiner by cash. At some point, if the opposition is
going through your checkbook and finds that you paid for a lie detector
test and you did not reveal that you had passed it, you can be sure the
opposition will discover that you had failed it.
Affidavits from friends, children, character
references and the like may have value although they would not be
permitted as evidence in a trial. Hire a psychologist or psychiatrist
to evaluate you to determine if you would be likely to be a child
abuser. By using standardized tests it may be possible for the
professional offer an opinion as to whether you fit the classic profile
of a child sexual abuser. While there is no litmus test for such an
abuser, the tests may reveal whether you have a deviant personality or
poor impulse control or some of the other traits commonly associated
with child abusers. If you do not, and the person is reputable, the
opinion may satisfy the attorney of the child or guardian ad litem that
there should be contact pending the final hearing. The report from your
psychologist or psychiatrist may be very important on the issue of
contact with the child pending a full hearing.
6. File a responsive pleading
Very often, especially if viewed in the context of a
divorce proceeding, the allegations have been made in an affidavit in
support of an application for an ex parte custody/visitation order.
affidavit and application contains all sorts of hearsay, nonexpert
opinion, statements which the child is supposed to have said, and claims
made by physicians and others. That document sits in the file and every
judge who picks up the file reads the document and decides that you are
guilty and then makes all decisions about how the case will be handled,
including when and whether it should be set down for trial.
Although the rules of practice do not require a
responsive pleading, they do not prohibit it either. Consequently you may file your own affidavits in
support of your position, as well as a memorandum and any other
evidence. Once you and your attorney have a theory of the case, it is
important to balance the file with your own version. Only then will you
gave a chance of obtaining a meaningful hearing at a meaningful time.
However, you must be sure of the theme of your
defense before you file a responsive pleading. Otherwise, if you act too
quickly, and have one theory only to find that there exists a better
theory, the judge will presume you will take any convenient theory.
example, the theory of the defense may be that the child was abused but
you didn't do it. Upon further investigation you decide that the child
wasn't abused. If your initial responsive pleading admits the child was
abused, the judge is going to be hard pressed to now find that the child
was never abused. If the theory is that the child's sexually transmitted
disease was acquired nonsexually, for you later to decide that (a) the
test was invalid or (b) she was abused by someone else with the disease
will leave you without a solid position. It is better to save your
options and not file a responsive pleading than to file one based on a
theory which you later abandon. Nevertheless, one can not underestimate
the impact that the initial pleading has against you nor overestimate
the impact that your responsive pleading may have for you.
7. Gather intelligence
Knowledge is power. It is absolute essential that you learn as many facts as is possible and keep them in a manageable form.
The gathering of intelligence can provide two things. It can show that
the story as told by the child could not have happened as described
because of the impossibility of the event. For example, it can affect
the credibility of the child who testifies that the door was locked,
when the door never had locks. Also, through careful investigation, you
may be able to determine the origin of the thought which went into the
Photographs, engineering diagrams
One parent was accused of sexually fondling a
neighbor's child in a tool shed. It sounded plausible, as the place was
private, and it was near the home of the child. One photograph of the
floor to ceiling junk without room for one person to stand was
sufficient to show that the child could not have been telling the truth.
Teenagers often report having been raped in the bathroom. I presume it is possible to be raped in
a bathroom, although there are many bathrooms which are simply too small.
The best evidence of the size and shape of the bathroom is a photograph,
or a floor diagram. Asking the child to demonstrate, with scale figures
where each person was during the act may make the whole thing
In another case the children were able describe
sexual acts with graphic detail. How else could the children know such
things if it had not happened to them? The mother denied that the child
had ever seen any adult sexual behavior. Explaining the origin of the
knowledge was difficult until it was discovered that the children's
bedroom was over the mother's bedroom and that there was a hot air grate
in the middle of the floor. After the mother vacated the apartment, the
father was able to obtain access and hired an engineer to do a drawing
(and photographs) of the room showing the optical zone from the upstairs
bedroom. That was sufficient to explain how the children had acquired
the specialized knowledge.
Medical records, medical experts, psychological reports
It is also important to obtain the medical reports
and psychological reports. If there is medical evidence, you may have to
contact an expert in the medical field to be able to understand the
significance of the medical reports. In one recent case the child was
diagnosed as having chlamydia. That was enough for the doctor to
conclude abuse. However, after the defense lawyer spent some time in a
medical library, it was apparent that the doctor used a test to discover
chlamydia which had not been approved by the manufacturer for use on
children, had not been approved by the FDA, was contrary to Surgeon
General's Protocol on clinical investigation of abuse and was generally
considered an unreliable test.
In another case, the child had contracted gonorrhea. Both the mother and father were positive for the disease.
produced a lab slip showing he was negative. The defense lawyer hired a
pediatric physician and reviewed the conflicting literature about
whether gonorrhea can be contacted nonsexually. As the attorney was
leaving the office, the expert added: "By the way, if the boyfriend had intercourse
twice with the mother, he also had gonorrhea, and I don't care what the
lab report says." The attorney then continued his search for
medical records and sure enough the boyfriend was diagnosed and treated
for gonorrhea on the same day as the child.
An examination of the psychological reports often contain inaccuracies or misstatements.
claimed to have a tape recording of the child which clearly identified
the father as the abuser. After listening to the tape, it provided no
information whatsoever. In another case, the records were so fraught
with suggestions that one could not seriously believe the child. In that
case the child was seen 72 times for therapy. During each session the
child and her therapist talked about good touch and bad touch, played
sex abuse prevention games, played with the anatomically correct dolls.
Needless to say, after 72 sessions the child knew everything about sex
abuse. However, in her effort to encourage the child to talk about abuse
the child, the therapist had plastered so many layers of learning over
her original memory that the child had no independent recollections.
A deposition is the product of having a witness sworn
and asked questions which are taken down by a certified court reporter.
It is usually done in your lawyer's office and in noncriminal cases, can
be done as of right. Sometimes the court will prohibit the child from
being deposed. Nevertheless, by taking the deposition of the
professional, you may be able to establish (a) the qualifications of the
therapist, (b) the protocol and techniques used, (c) what the child is
saying or not saying, (d) the basis upon which the professional come to
the conclusion of abuse. It is absolutely essential to depose everyone
in sight to freeze the story in order to have an official story as soon
Stop the Counseling
Attempt to prohibit any further interviewing or
treatment, except under conditions and by people who will avoid teaching
the child that he or she has been abused. Attempt to require all further
interviews to be videotaped. If the court procedure is an exercise to
obtain the truth, there should be no problem with this requirement.
Note taking, record keeping
Start keeping notes from the first time there is a
hint that you may be a suspect in child abuse cases. It is absolutely
essential that you keep the following records: (a) A calendar, (b) A
diary, (c) An expense book, (d) Photographs and video recordings.
Also, if it is legal in your state, you should buy a
teletaper (Radio Shack sells them) and record every telephone
conversation with you wife, ex-wife, social worker, and anyone who may turn out not to be your
friend. The calendar is necessary to keep track of events, past, present
and future. You try to reconstruct you entire life as it involved
contact with the alleged child victim. For example, if you had weekend
visitation and were denied visitation for the last six months (not an
uncommon occurrence in this type of case) try to establish where you
were and why you didn't have visitation. If the child claims she saw you
Christmas and she didn't, her credibility is suspect but only if you can
prove where you were and why you didn't see her. The calendar may be
useful if you attempt to use, by way of explanation, the S.A.I.D.
syndrome, developed by Dr. Gordon Blush and Karol Ross.(7)
The diary is also important for you may be accused of
molesting the child even after the alleged first incident. To this
extent the more detail about where you were and what you did the better.
An expense book is important to record every dime you
spend defending yourself. You may be asking your spouse for attorney
fees; you may sue the therapist for malpractice; you may sue the
neighbor for slander. If you do the expenses will be important.
Consequently not only keep an expense book; keep receipts.
Finally, a lawyer needs tools to work with. He needs
affirmative evidence. It is very rare that he will be able to destroy
all the testimony by all the witnesses. It may be a question of who is a
better witness and you may lose. You must have something anything to
provide the judge or jury with.
The Child Witness At Trial
If a child testifies, your attorney must be kind and
gentle to the child. Otherwise, you will be considered to be an abuser.
If, in response to questioning by your attorney, the child cries, the
jury will believe that the child is frail because of the abuse.
While the attitudes of judges will vary, most will
permit leading questions by both parties, will discourage objections by
both parties, and will permit all attorneys to discuss anything. Relevancy will not be grounds for objection.
Use the threshold question
of competency to elicit the nature of the rehearsals and the amount of
programming. The child will not usually have been prompted on the issue
of previous interrogation and the responses on this issue may, in and of
themselves, let the judge make a determination as to competency.
When the child testifies, ask questions to determine
the suggestibility of the child.(8)
Q: Lots of children who have been in situations like this tell me that their thumbs hurt?
Does your thumb
Ask questions aimed at discovering what children can
say without it being a lie. In one case the child was absolutely certain
that she never had lied, never did lie and never would lie. On cross
examination she admitted to fibbing, not seeing this as a problem.
Thus a child may distinguish between the wrong behavior of lying, and
permitted behavior, such as fibbing, telling of white lies, or telling
Ask questions to suggest the possibility of
Q: Sometimes kids make up stories in their minds. Sort of like a daydream.
Do you know what a daydream is? After a while
they think the stories are true when they were really only daydreams.
Maybe that's what you did. Maybe what happened is sort of like in your
mind and not like it really happened. Is it like a daydream?
Sometimes listening to the child's tape recordings
will give you an idea of how they distinguish fact from fantasy. For
example, in one tape, the five-year-old child said that she called her
dad, "Eliot." When the mother corrected her and said she never
did, the little girl replied: "I do in my heart." Thus, she
has developed in her own mind a way of having "fabricated
events" in her heart which she swears are real.
Ask questions as to the origin of the thought.(10)
Q: Maybe somebody told you to say those things about
your dad. Maybe somebody put those ideas in your head. Is that what
Use toys and the unexpected to interrupt the script
which the child is following. Sometimes an attractive toy in the lap of
your client will evoke behavior which overrides the fact that the child
has learned to say she dislikes her father. Sometimes asking the child
what she likes about her father and her mother and her paternal
grandparents will totally catch the child off guard which can lead to
other questions. Such questions will permit the jury to compare the
uncertainty of the responses, the verbal and thought maturity, and
affect to determine whether the previous well rehearsed story was just
that a well rehearsed story.
Do not suggest that the child is lying, only that the
testimony is the product of other influences. After all, many people,
judges included, do not believe that children would lie about something
like this. Ask the child to make up a story. If the child has testified
about lions, ask for a story about lions. For all you know, the child
may simply repeat his testimony because after all, it was a story which
was made up. On the other hand, the child may tell the story about
Little Red Riding Hood and how her grandmother was eaten by a wolf.
course, how would a child be able to describe with such specific sexual
detail if ...
(1) Pride, M. (1968). The Child Abuse
Westchester, Illinois: Crossway
(2) Mclver, W., Wakefield, H., & Underwager, R.
(1989). Behavior of Abused and Non-abused Children in Interviews with Anatomically
Correct Dolls. Issues in Child Abuse Accusations, 1(1),
p. 47. [Back]
(3) White, S., Strom, G., & Santilli, G. (1985,
October). Clinical protocol for interviewing preschoolers with sexually
anatomically correct dolls. Paper presented at the 32nd Annual Meeting
of the American Academy of Child
Psychiatry, San Antonio, Texas. [Back]
(4) Id., pp. 39-48. [Back]
(5) It should be noted that the State, and its agents
have governmental immunity. A suit against them would most likely be
(6) See generally, J. Wallerstein & J. Kelly
(1980). Surviving the Breakup: How Children and Parents Cope with
(). New York:
(7) The S.A.I.D. Syndrome stands for "Sexual
Allegations in Divorce." Dr. Blush and Ms. Ross may be contacted at
Professional Counseling Associates, 36040 Dequindre, Sterling Heights,
MI. 48310 (313) 939-5110. [Back]
(8) Nurcombe, B. (1986). The child as witness:
Competency and credibility, Journal of the Academy of Child Psychiatry,
25(4), 473-480, pp. 473, 447. [Back]
(9) Ibid. [Back]
(10) Ibid. [Back]
* Louis Kiefer is an Attorney at Law and can be
contacted at 60 Washington Street, Suite 1403, Hartford
Connecticut, 06106. [Back]