Contents
PART ONE

Statement of the Proceeding Below and Introduction
Statement of Facts

The Facilities

Taekwondo Unifroms

The Accusations

The Trial

The Genesis of the Accusations

The Church and School Further Disseminated Accusations

The School Was Also a Mouthpiece for the Accusations

Complainants Mixed and Mingled

Influential Methods of Questioning

Parents' Use of Influence

Parents and Other Adults Told the Complainants What to Say
The State Interviews

The Accusations Elicited by Parents, Investigators, and at Trial

Stories That Changed

The Complainants
The Parents
Videotapes of Interviews

The State Experts

The Scientific Research

Mr. Fiek's Testimony

PART TWO
Enumeration of Errors

Statement of Jurisdiction

Standards of Review

Preservation of Record

Part Three: Argument

Error #1: Hearsay

A. Introduction

Hearsay Admitted in Error

Admissible Hearsay Must be Reliable

The Hearsay Was Unreliable

Out of Court Statements Not Trustworthy

Out-of-Court Videotapes

The Hearsay was Unnecessary

Error #2: Exclusion of Non-Accusers Videos

Content of Non-Accuser Interviews

Non-Accuser Interviews Were Crucial

The Right to a Defense and to Cross-Examine

Exclusion was Unconstitutional

Error #3: Experts Bolstered the Accusations

The State Experts' Testimony

Testimony Violated Prohibition on Bolstering

Error #4: Insufficient Evidence

Conclusion