When “Hearsay” Became the “Law of the Land”

Oprah Winfrey 635519860555079608-AP-IB0-OPRAH-WINFREY-24-LLINE

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Hillary Clinton and Bill Cosby

This article is in reference to what went on in Bill Cosby’s trial on July 7th, 2016. DA Steele argued and Judge O’Neill agreed that it was okay to use hearsay at a preliminary hearing against Dr. Cosby because it was “the law of the land.” This was an assault (sexual assault?) on the Sixth Amendment right of all Americans to confront their accusers at trial. This has been a right since 1791, at least until now.

Bill Cosby Returns to Court Seeking Dismissal of Sex Assault Charges

Bill Cosby Loses Bid to Get Criminal Case Dismissed

This is from the first “Daily Times News”article above: “While the state Supreme Court is currently reviewing the Superior Court’s decision in Ricker, Steele said “it is still binding precedent” and argued unless the rule is overturned, “this is the law of the land.”

Is the allowing of “Hearsay” testimony at preliminary hearings instead of readily available witnesses, really the “law of the land?” Have Sixth amendment  rights to cross examine witnesses really been eliminated from preliminary trial hearings?

This is what Steven F. Fairlie, the chair of the Montgomery County Criminal Defense Committee writes about the ruling Steele and Judge O’Neill cited. PA Superior Court: Hearsay Enough for Prima Facie Case?

Hearsay is an out-of-court statement used to prove the matter asserted. Generally, hearsay is excluded from legal proceedings because it is deemed unreliable, subject only to explicit and carefully defined exceptions (i.e. a “dying declaration” is admissible to prove the identity of the assailant and a “present sense impression” is admissible because statements made simultaneously as the information conveyed is perceived by the declarant is more likely to be accurate).   Hearsay not otherwise considered reliable is excluded because a fact-finder cannot assess the credibility of the declarant through her own perception. In other words, the prohibition of hearsay prevents “he said; she said” situations from being given too much undue credence.

However, hearsay is admissible at preliminary hearings in Pennsylvania. The preliminary hearing is an initial stage of the criminal adversarial process whereby the prosecution must prove that it has the specific evidence necessary, if later proved true beyond a reasonable doubt at trial before a jury, for the defendant to be convicted of the crime charged.   Preliminary hearings are held in front of a magisterial district judge, an elected position that does not require a law degree.

The admissibility or inadmissibility of hearsay in a criminal case is an especially important decision for the reliability of certain statements to be considered. As anyone who has ever sat for jury duty will note, one of the first questions a defense attorney or a prosecutor may ask is whether or not the potential juror will be especially swayed (for better or worse) by the testimony of a police officer. Preliminary hearings are generally considered to be prosecution-friendly, where the Commonwealth has a low burden. Nevertheless, the hearing serves an important role in holding the prosecution accountable.

This reality is what makes the intermediate appellate court’s decision in Ricker all the more alarming, and, perhaps, suspect. As the decision in Ricker stands, a prosecutor can in essence “phone it in” by having some different officer read the notes of the investigating officer, or worse yet, an officer provide his version of what the complaining witness said. There are absolutely no safeguards to such a system.

Certainly, we should be “alarmed” at a system where “there are absolutely no safeguards.

This is from the 2010 University of Illinois Law Review article entitled “THE CONFRONTATION CLAUSE AND PRETRIAL HEARINGS: A DUE PROCESS SOLUTION” by Christine Holst (pg 1614). She is talking about a 1987 Supreme Court Decision in “Pennsylvania V. Ritchie,” the last Supreme Court Decision in a case such as this.

“Predictably, in navigating the muddled Supreme Court precedent laid out above, courts came to different conclusions about the applicability of the Confrontation Clause prior to trial. The analysis of these courts roughly falls into two categories: those that applied the Confrontation Clause to a pretrial hearing because it was a “critical stage” of the criminal prosecution process, and those that held the Confrontation Clause is only a trial right and does not apply to pretrial hearings.”

“Pennsylvania vs. Ritchie” seems to be the important Supreme Court Decision here: Hoist notes this about it:

“Some would say that Ritchie settled the issue: the Confrontation Clause applies only to trial. Once again, however, this seems to be reading the Court’s opinion too broadly. The first flaw in this reading of the Court’s opinion is that the key passage about the Confrontation Clause (Part III-A of the opinion) was signed by only four justices, making this section a plurality opinion and not part of the majority opinion.65 Justice Harry Blackmun, who joined the Court on the rest of the opinion, wrote a concurring opinion where he stated that he refused to join Part III-A because he disagreed with the plurality’s conclusion “that the Confrontation Clause protects only a defendant’s trial rights and has no relevance to pretrial discovery.”66 Instead, Justice Blackmun argued that “there might well be a confrontation violation if, as here, a defendant is denied pretrial access to information that would make possible effective cross examination of a crucial prosecution witness.” Because Justice Blackmun disagreed with this portion of the Court’s opinion, the conclusion that the right to confrontation is a trial right and only a trial right is not one endorsed by the Court.”

The last sentence is important here — “Because Justice Blackmun disagreed with this portion of the Court’s opinion, the conclusion that the right to confrontation is a trial right and only a trial right is not one endorsed.”

DA Steele is arguing that the right to confront a witness is a trial right and only a trial right and not applicable at a preliminary trial hearing as this one was. However Supreme Court Justice Blackmun and the majority of the Supreme Court said in 1987 it was a right in a pretrial hearing. He was therefore incorrect when he said that Commonwealth vs. Ricker was “the Law of the Land” The law of the land was expressed in Blackmun’s statement that “there might well be a confrontation violation if, as here, a defendant is denied pretrial access to information that would make possible effective cross examination of a crucial prosecution witness.”

Certainly, DA Steele, introducing a hearsay statement by accuser Andrea Constand, instead of introducing her was a violation of Dr. Cosby’s Sixth Amendment right to confront his accusers. Sadly, Judge McHugh and Judge O’Neil ignored the law of the land and went along with Steele’s false and mistaken interpretation of the law of the land. If Andrea Constand had taken the stand and given testimony and the defense given a chance to cross-examine her, she may have repudiated the hearsay evidence Steele presented.

DA Steele claimed that she would have been attacked under cross-examination. He says: “Defendant wants to cross-examine the victim that he is charged with sexually assaulting in 2004 and attack her credibility.” Steele makes a false and malicious statement regarding Dr. Cosby here. Perhaps, Constand now sees differently than she did nearly 12 years ago. Perhaps, she now remembers events that she had forgotten at the time. Perhaps, she was under the influence of drugs or other people and she now knows the things she said aren’t true any more. If this was the case, and she admitted her mistake, the defense would not have attacked her credibility at all. By not putting her on the stand, Steele denied her an opportunity to correct her old testimony, either to add or subtract things.

In the second article, Cosby’s lawyers noted that hearsay cannot be a substitute for a live witness:

“We’re talking about an allegation of assault that happened over 11 years ago,” said one of Cosby’s defense lawyers, Christopher Tayback, arguing to the court that the statement read during the preliminary hearing was taken so long ago that the officer who recorded it has no recollection of it. It should not stand in for the witness herself, Tayback argued.

“You know what a witness can do?” he asked the court. “A witness can recant.” He reiterated the point, saying that a witness can do and say all kinds of things that a piece of paper can’t.

Part 2 – The Re-traumatization Excuse

According to the second article above, DA Steele also said, “It’s our position that we’re not going to re-traumatize victims,”

It is amazing that he can bring up the idea that Andrea Constand could be re-traumatized talking about this event:

  1. Andrea Constand did worry about being re-traumatized when she again met with Cosby at four different times after the alleged incident and never talked with him about it.
  2. Ms. Constand did not seem re-traumatized when she gave an expensive sweater to Dr. Cosby as a gift after the incident.
  3. She did not seem re-traumatized when she asked him for free tickets to a concert Cosby gave in Toronto and took her parents to see him eight months after the alleged drugging and assault.
  4. She did not seem re-traumatized when her mother repeatedly called Cosby over a five month period after the concert in order to establish a friendship with him.
  5. In 2005, Ex-professional basketball player 31 year old Andrea Constand was not re-traumatized when she told her parents about the event.
  6. Andrea Constand was not re-traumatized when she told a set of lawyers about the event.Ms. Constand was not re-traumatized when she told a second set of lawyers, Troiani and Kivitz, about the event.
  7. Ms. Constand was not re-traumatized when she told the Toronto Police about the event.
  8. Ms. Constand was not re-traumatized when her parents went to the Toronto Star and did an interview revealing her name just one week after she reported to the Police. Apparently her parents did not worry about her being re-traumatized by this.
  9. Ms. Constand was not re-traumatized when she told detectives from the Montgomery Country DA’s office about the event.
  10. Ms. Constand was not re-traumatized when she talked with detectives a second time from the Montgomery County’s DA’s office.
  11. 8. Ms. Constand was not re-traumatized when she gave or sold an interview to the National Enquirer about the event, just a week after talking to the detectives.
  12. Ms. Constand did not worry about being re-traumatized when she filed a lawsuit against Bill Cosby in March 2005.
  13. Ms. Constand’s lawyers Troiani and Kivitz did not worry about 12 women they found to testify against Cosby that they would be re-traumatized by telling their stories.
  14. Ms. Constand did not worry about being re-traumatized when she sued Cosby’s lawyer Martin Singer for negotiating a newspaper interview for Bill Cosby.
  15. Ms. Constand was not re-traumatized when she was deposed at the time of the lawsuit.
  16. Ms. Constand was not re-traumatized when Judge Robreno released bits and pieces of her sealed testimony and Cosby’s sealed testimony to the public in the Summer of 2015.
  17. Ms. Constand was not re-traumatized when the Washington Post and CNN and the N.Y. Times and hundreds of other sites released out of context bits and pieces of Cosby’s sealed testimony.
  18. Ms. Constand was not re-traumatized when DA Steele ran campaign ads reminding people that his opponent DA Castor did not prosecute Cosby in her case.
  19. Ms. Constand was not re-traumatized when she communicated with a number of other Cosby accusers on the internet in 2015, if not earlier.
  20. Ms. Constand was not re-traumatized when she decided to countersue Cosby in the Summer of 2015 for breaking his legal settlement with her.
  21. Ms. Constand did not worry about being re-traumatized when she agreed to help Montgomery County D.A. Steele reopen the case against Cosby that had been closed 11 and a half years before.
  22. Andrea Constand was not re-traumatized when she talked again about the case with Montgomery Country detectives in 2015.
  23. Ms. Constand was not re-traumatized when she talked a second time with Montgomery County detectives in 2015. That would be a total of four times, at least talking to the police.
  24. Ms. Constand did not worry about being re-traumatized when she sued DA Attorney Castor for not believing her in 2005.
  25. Ms. Constand was not re-traumatized when DA Steele released bits and pieces of her testimony about the event repeatedly over the last seven months.
  26. Ms. Constand was not re-traumatized when DA Steele released written statement by her from 2005 at the Preliminary trial hearing.

Only when taking away Dr. Cosby’s Sixth Amendment Rights does Steele express fears about her re-traumatization

Besides the amazing hypocrisy of this statement, one has to consider that a person has to be traumatized before they can be re-traumatized and no proof has been presented except her own claims that she ever was traumatized by the original incident involving a few minutes of mutual masturbation between a 30 year old college graduate and a 65 year old man who had been friends for over two years at that point.

Psychiatrists are divided about the nature of traumatization and if talking about something re-traumatizes a person. Rather, the whole basis of modern Freudian psychiatry seems to be that talking about traumas helps to cure them. That is why Freud’s technique was known as “the Talking Cure” and was not known as “the Talking Re-traumatization”.

Should we also close down all 1300 so-called Rape clinics in the United States, as they urge women to talk about rape and therefore could cause re-traumatization? Should we shut down all Woman’s Gender Studies courses as they talk often about rape and could cause re-traumatization.

Hopefully, the Supreme Court of Pennsylvania will agree with the Supreme Court of the United States and not take away Sixth Amendment rights to its citizens. The life and liberty of not just Bill Cosby, but every citizen of Pennsylvania, and possibly the United States, is at stake.

 

 

 

Mathematical Proof of Conspiracy Against Bill Cosby


Time Magazine Cover

This is the outline for a deeper scientific study that needs to be done.

Saturday Evening Post

Bill Cosby is one of the most important civil rights leaders, educators, and entertainers in the history of the United States. In 2005, when he was 65 years old, five women publicly accused him of drugging and sexually assaulting them. One claimed it happened one year in the past [1], two claimed it happened about 20 years in the past[2] and two claimed it happened 30-35 years in the past [3]. Nobody accused him for the next nine years. In 2014-2015, when he was 77 years old, some 35 more women accused him on television and in the mass media of drugging and assaults, from 7-50 years in the past,  All of the public accusers in 2005 were part of a lawsuit against Cosby filed by attorneys Deloris Troiani and Bebe Kivitz.  Apparently six of the 2014-15 accusers were non-public accusers from the 2005 lawsuit.

Most of the new accusers in 2014-15 were clients of attorney Gloria Allred or her associates. Besides the 40 women accusing him of drugging and sexual assault, an additional 20 women went to the mass media and made other much less sensational accusations against him (ranging from “rough kissing” to “spreading rumors” to “touching a woman’s breast in a public restaurant”).

All of the accusers, with the exception of the first, admitted to seeing or hearing reports of Cosby drugging and assaulting women in the mass media before going public with their claims. This suggests that the mass media coverage was an important factor in their making these claims.

The one thing that all the drug and sexual assault accusers have in common is that at the time of the incident/incidents, none went to the police to file a report, or to a doctor, clinic or hospital to be tested after being drugged, none got a lawyer to file a lawsuit, and none went to a reporter to offer their stories. None wrote a letter or made a diary entry. None told a relative or a friend who wrote a letter or publicized it in any way.

What are the odds that all these woman are telling the truth about the drugging and sexual assault and none of them going to the police, or a doctor, or a clinic, or a lawyer, or talking to a reporter or writing a letter, (either signed or anonymous), or telling relatives or friends who did any of these things?  This article attempts to quantify those odds. While no scientific evidence exists for calculating the odds of an accuser not doing all of the these things, there is scientific evidence available to calculate the odds of an accuser not going to the police. Logically, not going to police does not preclude women from going to a doctor, clinic, lawyer, reporter, or writing a signed or anonymous letter about it, or telling relatives or friends who did any of these things. Thus we would expect women to be able to present more physical evidence than just going to the police and generating police reports.

The idea that one of the most well known, beloved, celebrated, and honored men in American history should also be a secret serial criminal suggests a fantastic breakdown in the American justice system for 50 years or a mass conspiracy against Dr. Cosby. For the purposes of this article, we shall define a conspiracy according to 18 U.S.C. 371: which makes it

a separate Federal crime or offense for anyone to conspire or agree with someone else to do something which, if actually carried out, would amount to another Federal crime or offense. So, under this law, a ‘conspiracy’ is an agreement or a kind of ‘partnership’ in criminal purposes in which each member becomes the agent or partner of every other member. as any untrue accusation made public with the help of lawyers and the mass media[4].

Reasons for Not Going to Police that are Not Scientifically Backed

Accusers and others have given numerous reasons for not reporting the crimes in a timely fashion. For example, that the perpetrator was a wealthy, black man. There is no scientific evidence that victims of rape are less reluctant to go to the police when their attackers are wealthy or black than when their attackers are poor or white.

Frequently, the accusers say that they feared retaliation in their careers. There is evidence that sexual assault victims are more reluctant to go to the police when they fear physical or other retaliation. However, Dr. Cosby was a comedian and had never shown any significant indication of violent behavior, there is no reason to believe that any of the accusers felt physically threatened by Cosby. Because of his extreme gentleness and warmth, demonstrated in thousands of live concerts, hundreds of television shows, hundreds of well publicized charitable activities, and testimonies from hundreds of people who worked with Cosby, none of the accusers would have had any reason to expect any physical retaliation for going to the police. As far as retaliation to their careers, since Cosby was only one of hundreds of Hollywood producers, there was also no reasonable expectation that he could hurt their careers if they went to the police. One can question if there is any evidence of Hollywood or New York actors or actresses being blacklisted or seriously hindered from work over the last 50 years due to criminal reports or lawsuits. Other explanations, such as Cosby being too powerful to report to the police, lack any scientific evidence to back them up.

In fact, models and actresses, the vast majority of the accusers, are taught to act brash and bold, and often welcome publicity.  One can logically conclude that they are far more likely to go to the police than the average person

Reported and Unreported Rape Statistics
While not all rapes and attempted rapes are reported to the police, a great number are. Since 1973, the Department of Justice has been using annual surveys to scientifically determine how many rapes/attempted rapes are reported and go unreported. Based on these reports we can determine mathematically the odds that all these women were actually assaulted and did not go to the police.

By adding up the percentage of reported rapes each year from 1973-1992, and dividing by 20, we find that the average annual number of reported rapes was 52%. This means 48% went unreported annually on average.  (Note: all data can be found at http://www.bjs.gov/index.cfm?ty=dcdetail&iid=2450 It is in “Criminal Victimization 1992”).

Criminal Victimizations 1992 Table 5 Reporting Victimizations to the Police
Total = 1044% / 20 years = 52.2% reported per year on average

Rape was defined this way in the surveys from 1973 to 1992. (Note: from “Crime Victimization in the United States, 1991.”)

Rape — Carnal Knowledge through the use of force or the threat of force, including attempts. Statutory rape (without force) is excluded. Both heterosexual and homosexual rape are included.

The Important Change in the Definition of Rape in 1993 in the Annual Crime Surveys
In the 1993 survey published in 1996, the definition of rape was drastically broadened. (Note: from “Crime Victimization in the United States, 1993”)

Rape — Forced sexual intercourse including both psychological coercion as well as physical force. Forced sexual intercourse means vaginal, anal or oral penetration by the offender(s). This category also includes incidents where the penetration is from a foreign object such as a bottle. Includes attempted rapes, male as well as female victims, and both heterosexual and homosexual rape. Attempted rape includes verbal threats of rape.

The main and essential difference is that “psychological coercion” has been added. The term “psychological coercion” is extremely broad and can be interpreted in any number of ways. It is often impossible to distinguish between “coercion” and “offers.” For example, if a man offers a woman cocaine, or a mink coat, in exchange for sex, that can be considered coercion and therefore rape. If a woman offers a man sex in exchange for cocaine, or a mink coat, that is considered an offer and not considered rape. Yet the actions will be exactly the same in both situations.
The effect of broadening the definition of rape to include non-violent “psychological coercion” was to cause a jump in the unreported rape rate. In 1993, unreported rapes jumped from an average of 48% that it had been for the previous 20 years, to 71%. This was 12% higher than the highest previous one year number of unreported rapes (59% in 1980) in the 20 year period from 1973-1992. Over the next 18 years, from 1993 to 2010, the average number of unreported rapes was 66%.
Victimizations not reported to the Police 2006 to 2010
There is no evidence and no reason to believe that the police reports of violent rape/rape attempts went down from 1993 to 2010. Rather it is probable that the expansion of the definition to “psychological coercion” caused the increase in unreported rapes from 48% average per year to 66% on average.

None of the drug and sexual assault accusations against Dr. Cosby would have been reports for non-violent psychological coercion. Because they involved drugging, they would have been reports for actual violent rape/rape attempts. Therefore it makes sense to use the 52% reported violent rape/rape attempts that was established from the data from 1973 to 1992.Also, the majority of the incidents are alleged to have happened during this time.

This means that if a drugging and sexual assault did take place, there was a 52% chance of that person going to the police. Cosby would have had a 48% chance of the woman not going to the police. This means that the chances are 52% that any specific one of the accusers would have gone to the police. If  the first two accusers are telling the truth, Cosby would have had a .48 x .48 chance or a .23 chance of not being reported by one of these two women. There is thus a less than a one in four chance that any two of the 40 accusers selected at random are telling the truth.  If the first three women are telling the truth, Cosby would have had a .48 x .48 x .48 chance or an .11 or 11% chance of not getting investigated by the police. Another way of looking at it, is that the odds are 89% that at least one of the first three women are not telling the truth.
Assuming these women were normal assault victims and had a normal chance of reporting to the police, here are the odds of the chances that 1-40 of the women are telling the truth about assault  and no one going to the police:
One accuser accusations true – 48%, accusations false – 52%
Two accusers accusations true – 23%, accusations false – 77%
Three accusers accusations true – 11%, accusations false – 89%
Four accusers accusations true – 5%, accusations false – 95%
Five accusers accusations true – 3%, accusations false – 97
10 accusers accusations true – .065%, accusations false – 99.94%
20 accusers accusations true – .00000042% (42 in 100 million), accusations false – 99.999958%

30 accusers accusations true – .00000000027 (27 in 100 billion), accusations false – 99.999999973%

40 accusers accusations true – .00000000000018 (18 in 100 trillion), accusations false – 99.99999999999982%.

Thus the odds of all of the accusers telling the truth are 18 in 100 trillion or less than 2 in 10 trillion.

Calculation of Confidence Level

Let us assume for our null hypothesis that The women accusing Dr. Cosby are not a random and independent sample from the population in the study of women rape victims from 1973-1992 as portrayed in the U.S. Department of statistics when it comes to reporting to the police.

Since the number of alleged drug and assaults was established at 52%, we can round that off to 50% or the same odds as a coin flip which makes the probabilities a binomial distribution. We can calculate a confidence level for the 40 allegations that we are dealing with.

For a binominal, Standard deviation = SQR{(N*p*(1-p)}.

Thus, Standard deviation = SQR{(40*.5*(1-5)} = SQR{(40*.5*.5)} = SQR 10 = 3.16227766017 = ~ 3.162

Confidence level for one standard deviation or Z is 68.8%, thus sample average plus or minus sample standard deviation equals  x̅ (±)s. Since the average of people going to the police in a binomial sample of 40 is 40/2 or 20, we can say that 20 (±) 3.162 or between 16.838 – 23.162 would go to the police with a 68.8% confidence level.
A Z score of 2.59 would give us a 99% confidence level. Thus 2.58(Z) = 2.58(3.162) = 8.15796 or ~8.16. The 20 average reports would allow us to expect 20 (±) 8.16 or between 11.84 to 28.16 police reports with a 99% confidence level.

Since 12 to 28 of the alleged victims did not report to the police, we can say with a 99% confidence level that the null hypothesis is wrong. The women accusing Dr. Cosby are not a random and independent sample from the population of women rape victims from 1973-1992 as portrayed in the U.S. Department of statistics when it comes to reporting to the police.

Does this mean that the odds are equally great that some of the accusers are telling the truth?

The odds that an accuser is not telling the truth increases exponentially with each additional accuser. With 40 accusers, we should have expected 20 or 21 to have gone to the police. The fact that none did, can only be reasonably explained by this not being a random sample of sexual assault victims, which points in the direction of a conspiracy. This should not be taken to mean that it is likely that 19 or 20 are telling the truth. If half are implicated in a conspiracy, there is reason to believe that the other half are also part of that conspiracy (or conspiracies). If we find that 40 people claim to see Big Foot or a wizard flying through the air, and we find that 19 of them are lying, it does not mean that the rest are telling the truth, but it suggests strongly that all are lying or mistaken and have entered into a conspiracy with each other.

It should be recognized that going to the police was only one of a number of ways that the accusers could have provided evidence for their claims. They could have had drug tests done, hired lawyers, called reporters, written letters to friends or relatives, written anonymous letters to the mass media, written to companies employing Dr. Cosby, or told friends and relatives, who, in turn, could have notified authorities or written letters.

Summary
Based on their not reporting their alleged crimes to the police, and Department of Justice crime statistics, there is at least a 52% chance of any accuser falsely accusing Dr. Cosby.  The lack of any written evidence generated at the time that the incidents were alleged to have occurred would and admissions by all the accusers that they did not seek medical or legal or write any complaints or include direct references to the event increase those odds enormously. The chances that these accusers are telling the truth and are not part of a conspiracy become less and less as more accusers come forward. The chances of this being a conspiracy against Dr. Cosby increase exponentially with each accuser. The chances of conspiracy against Dr. Cosby are at least a trillion to one in favor, unless some other reasonable explanation for the lack of evidence to confirm any of the accounts is found.

Basically, a 52% chance of going to the police is very close to 50%, which is the odds of a coin flipping heads or tails. If all the women are telling the truth, each time that there was a drugging and assault, Cosby was flipping a coin. According to them it came up the same  40 times in a row. This gives us a result of .0000000000009 or 9.094947e-13.The odds against this happening are .5 to the 40th power or 9,999,999,999,999 to 1 (~ten trillion to one). Assuming that the women are a randomly and independently selected group of women, the odds that there is a conspiracy against Dr. Cosby are greater than 10 trillion to one.

We also found with a 99% confidence level that 12-28 of the 40 accusers should have gone to the police if all 40 of these people had been assaulted. The fact that none did suggests that this was not a random and independent sample of actual rape victims.

 

Footnotes

[1] Andrea Constand

[2] Barbara Bowman, Beth Ferrier

[3] Shawn Berkes, Tamara Green

[4] http://www.lectlaw.com/def/c103.htm