The Complete Testimony of Virginia Stone

1/28/85

VIRGINIA STONE, Witness

(Child enters courtroom with her mother)

MR. FORD: Virginia, we’ve got a special chair for you. Marsha, do you want to sit right here?

VIRGINIA STONE: Where’s Bernie?

THE CLERK: Can you raise your right hand, please? Put your right hand up in the air. That’s your left hand. Raise your right hand.

(Child raises right hand)

THE CLERK: Do you promise to tell what happened?

(Child nods head up and down)

MR. FORD: May the record reflect –

THE COURT: Yes.

*****

DIRECT EXAMINATION BY MR. FORD

MR. FORD: Tell these people your name.

VIRGINIA STONE: Virginia.

MR. FORD: What’s your last name?

VIRGINIA STONE: Stone.

MR. FORD: How old are you?

VIRGINIA STONE: Five.

MR. FORD: Five years old? You’re a big girl for five. Who is the lady right next to you?

VIRGINIA STONE: My mommy.

MR. FORD: Is she really? What’s my name?

VIRGINIA STONE: (No response).

MR. FORD: Did you forget my name?

VIRGINIA STONE: Dan Ford.

MR. FORD: Now that’s right. Who’s that right up there? Do you know who he is?

VIRGINIA STONE: He’s the judge.

MR. FORD: The judge, that’s right. Virginia, did you ever go to school at E.C.D.C.?

VIRGINIA STONE: Yes.

MR. FORD: Did you really>

VIRGINIA STONE: (Nods head up and down)

MR. FORD: Who were your teachers at E.C.D.C.?

VIRGINIA STONE: Kathleen, Laurie and Julie.

MR. FORD: What about Bernie?

VIRGINIA STONE: (Nods head up and down)

MR. FORD: Do you know what Bernie did down there?

VIRGINIA STONE: He was helping my teachers.

MR. FORD: He was helping your teachers?

VIRGINIA STONE: (Nods head up and down)

MR. FORD: Did anybody else down at E.C.D.C. touch you?

VIRGINIA STONE: (Shakes head from side to side)

MR. FORD: How about tickling? Did anybody ever tickle you?

VIRGINIA STONE: (Shakes head from side to side)

MR. FORD: Did Bernie tickle you?

VIRGINIA STONE: (Shakes head from side to side)

MR. FORD: Did he tell you stories?

VIRGINIA STONE: (Shakes head from side to side)

MR. FORD: How about the other teachers? Did they tell you stories?

VIRGINIA STONE: (Shakes head from side to side)

MR. FORD: Do you know Mrs. Hanes?

VIRGINIA STONE: (Shakes head from side to side)

MR. FORD: Did you tell your mommy about what happened?

VIRGINIA STONE: (Nods head up and down)

MR. FORD: When did you do that, Honey?

VIRGINIA STONE: (No response).

MR. FORD: Did you tell the teachers what happened?

VIRGINIA STONE: (Shakes head from side to side)

MR. FORD: When Bernie was — was Bernie — was he a good boy or a bad boy?

VIRGINIA STONE: Bad boy.

MR. FORD: Did you go on trips with him?

VIRGINIA STONE: (Nods head up and down)

MR. FORD: Virginia, when you were at E.C.D.C., did Bernie ever touch you somewhere?

VIRGINIA STONE: (No response).

MR. FORD: It’s okay. Show us where Bernie touched you?

THE MOTHER: It’s okay.

MR. FORD: Virginia, just point and show us where Bernie touched you?

THE MOTHER: It’s okay.

MR. FORD: Can you point on this dolly and show us where Bernie touched you, Virginia?

VIRGINIA STONE: (Child points to the doll)

MR. FORD: Right down there? May the record show that the witness pointed to the doll’s genital area?

THE COURT: Yes, it may.

MR. FORD: Virginia, did Bernie ever do anything else to you?

VIRGINIA STONE: (No response).

MR. FORD: Did he put his peniey somewhere, his dinky?

VIRGINIA STONE: (Nods head up and down)

MR. FORD: Where did he put it?

VIRGINIA STONE: (No response).

MR. FORD: It’s okay, sweetheart. Tell us where Bernie put his dinky.

VIRGINIA STONE: In my mouth.

MR. FORD: What room were you in when this happened?

VIRGINIA STONE: In the bathroom.

MR. FORD: How did it make you feel when Bernie did these things to you, Virginia?

VIRGINIA STONE: (No response).

MR. FORD: Did it make you feel kind of scared?

VIRGINIA STONE: (Nods head up and down)

MR. FORD: May the record show that the witness nodded in the affirmative, your Honor?

THE COURT: Yes.

MR. FORD: Virginia, did anything come out of Bernie’s dinky when he touched you?

VIRGINIA STONE: (Shakes head from side to side)

MR. FORD: Excuse me, just one minute.

(Pause in proceedings)

MR. FORD: Virginia, that’s all I’m going to ask you. I’ve got no more questions. See this man over here.

VIRGINIA STONE: (Nods head up and down)

MR. FORD: His name is Mr. Conway and he’s a very, very nice man and he’s going to ask you some questions too. I want you to answer his questions just the way you answered mine. You’re a good girl, Virginia. Your witness, counsel.

*****

CROSS-EXAMINATION BY MR. CONWAY

MR. CONWAY: Hi Virginia, you look tired. Are you tired? Are you tired this morning?

VIRGINIA STONE: (Nods head up and down)

MR. CONWAY: Didn’t get a good nap — or do you take a nap later? You take a nap in the afternoon?

VIRGINIA STONE: (Nods head up and down)

MR. CONWAY: You went to school at E.C.D.C.; is that right?

VIRGINIA STONE: (Nods head up and down)

MR. CONWAY: Who was your teacher?

VIRGINIA STONE: Kathy, Laurie and Julie.

MR. CONWAY: And Bernie was a helper?

VIRGINIA STONE: (Nods head up and down)

MR. CONWAY: Did Kathy sometimes take you to the bathroom, Honey?

VIRGINIA STONE: (Shakes head from side to side)

MR. CONWAY: How about Laura> Did she take you to the bathroom?

VIRGINIA STONE: Yes.

MR. CONWAY: Did Bernie take you to the bathroom too, sometimes?

VIRGINIA STONE: (Nods head up and down)

MR. CONWAY: Did you sing songs?

VIRGINIA STONE: (Shakes head from side to side)

MR. CONWAY: What did you do when you were in school? Did you play with finger paints?

VIRGINIA STONE: Yes.

MR. CONWAY: When you went in the bathroom with Bernie where were the other kids?

VIRGINIA STONE: They were in the school.

MR. CONWAY: You were in the school too, right?

VIRGINIA STONE: (Nods head up and down)

MR. CONWAY: And other kids were at school?

VIRGINIA STONE: (Nods head up and down)

MR. CONWAY: Were there other teachers at the school?

VIRGINIA STONE: (Nods head up and down)

MR. CONWAY: Lots of teachers? Three teachers?

VIRGINIA STONE: Three teachers in the class.

MR. CONWAY: And a lot of kids. How many kids?

VIRGINIA STONE: Nine — I mean ten.

MR. CONWAY: When you were in the classroom #1, #1 classroom upstairs — what was your classroom number?

VIRGINIA STONE: (Child shrugs)

MR. CONWAY: You don’t know, okay. Did you go to school in the morning or the afternoon?

VIRGINIA STONE: The morning.

MR. CONWAY: In the morning. Did you have lunch there?

VIRGINIA STONE: Yes.

MR. CONWAY: Sometimes?

VIRGINIA STONE: Yes, I did.

MR. CONWAY: When did this thing happen? Is it in the morning or the afternoon, Honey? Before lunch?

VIRGINIA STONE: (Nods head up and down)

MR. CONWAY: You told mommy about it?

VIRGINIA STONE: (Nods head up and down)

MR. CONWAY: Did you talk to mommy about it a lot of times?

VIRGINIA STONE: (Nods head up and down)

MR. CONWAY: Can you show me on your fingers how many times you talked to mommy about it?

VIRGINIA STONE: (Child holds up five fingers)

MR. CONWAY: Did you talk to Dan Ford about it a lot?

VIRGINIA STONE: (Nods head up and down)

MR. CONWAY: Can you show me on your fingers, how many times you talked to Dan?

VIRGINIA STONE: (Child holds up seven fingers)

MR. CONWAY: Seven times. That’s a lot of times.

VIRGINIA STONE: Eight times.

MR. CONWAY: Eight times. Did you talk to the policemen about it a lot?

VIRGINIA STONE: (Shakes head from side to side)

MR. CONWAY: Just mommy and Mr. Ford?

VIRGINIA STONE: (Nods head up and down)

MR. CONWAY: Okay. I have no further questions, your Honor.

*****

REDIRECT EXAMINATION BY MR. FORD:

MR. FORD: Virginia, did Bernie ever tell you that something bad would happen if you told anybody what he did to you?

VIRGINIA STONE: (No response).

MR. FORD: Do you remember that? Did he tell you something bad would happen to your mommy?

VIRGINIA STONE: (Nods head up and down)

MR. FORD: What did he say?

CHILD’S MOTHER: It’s okay.

VIRGINIA STONE: Kill her.

MR. FORD: Did he — that he would kill your mommy?

VIRGINIA STONE: (Nods head up and down)

MR. FORD: No further questions.

MR. CONWAY: I have no further questions.

THE COURT: You’re excused, Madam.

MR. FORD: You’re all done, Virginia. You can leave now.

(Witness excused)

[Note: A few months later, Virginia would tell her therapist that nothing had really happened but that her mother had coaxed her to say so, so that they could get a lot of money.]