[1] Sonya Hill was also charged. The charges against Ms. Hill were later dropped then reinstated. She eventually pled guilty, without admitting guilt, to taking indecent liberties with a child. The trial court found as a non-statutory mitigation circumstance that she was innocent. See Appendix.

[2] After hearing others testify, Ms. Holmes was recalled to testify to what Zachary had told her on the way home from a session with Nancy Berson. Ms. Holmes testified that Zachary said that defendant tore his jogging pants and hurt his "hiney" with a screwdriver. (Tp. 1171)

[3] Michael slept with his father and Michelle slept with Ms. Blackmon. (Tp. 320)

[4] The notion that pedophilia and satanism are linked is a common theme in the testimony of some North Carolina psychologists. See, e.g, State v. Kelly (Pitt County, 91 CrS 4250 et seq.) (testimony of Dr. Mark Everson).

[5] It is another common theme in child sexual abuse prosecutions that child molesters may not themselves be interested in children as sexual objects, but take pictures of their victims to sell to others. In this way the state can counter the defense that the defendant himself has no pedophilic tendencies. See State v. Kelly, (Pitt County, 91 CrS 4250 et seq).

[6] Prof. Richard Rosen testified in a pre-trial hearing that the District Attorney said that he believed her to be innocent. (Dunne Tp. 33)

[7] Some states have held that statements by children to sex abuse counselors are presumptively unreliable because of methods typically used by such counselors to extract statements. See, e.g., State v. Harris, 247 Mont. 495, 808 P.2d 453 (1991); Felix v. State, 849 P.2d 220 (Nev. 1993).

[8] The state may argue that the verdict having to do with Zachary was not implicated. Given the relationship among the children and the charges, a belief that any one child had been abused would translate to a guilty verdict as to all three.

[9] Many courts have recognized the suggestiveness of repeated interviewing by sex abuse counselors. See, e.g., State v. Harris, 247 Mont. 495, 808 P.2d 453 (1991); Felix v. State, 849 P.2d 220 (Nev. 1993).