Affidavit of Ted Gunderson in the Linda Weigand matter

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I, Ted L. Gunderson, being duly sworn, state:

1. I have personal knowledge of the facts and matters contained herein and if called upon as a witness to testify to the same, I can and will testify hereto:

2. I am over the age of twenty one years and believe in the obligations of an oath, and I am not a party nor do I have an interest in this matter.

3. I served in the FBI from December, 1951 to March, 1979. For the first nine and one half years, I was assigned as a Special Agent investigator. Thereafter, I advanced through various administrative levels until I retired in March, 1979. At the time of my retirement, I was one of the top executives, specifically the Senior Special Agent in Charge of the Los Angeles Division. I had three Special Agents in Charge as well as more than 700 personnel under my command. As the Senior Special Agent in Charge it was my responsibility to oversee all phases of the FBI's investigative jurisdiction throughout most of Southern California which encompassed a population of more than 14 million people. I was also responsible for the handling of all administrative manners as well as liaison with other government agencies and the media.

4. After retiring I was asked by US Attorney General Griffin Bell to coordinate security for the Pan American games, San Juan, Puerto Rico (Summer, 1979) There were six anti-American terrorist groups active on the island, yet no terrorist acts were committed during the games. In 1981-1982, I served on the California Narcotic Authority as a consultant for Governor Jerry Brown. I served as a consultant in 1984 to the Los Angeles Olympic Committee.

5. After retirement, I established Ted L. Gunderson and Associates, Santa Monica, California, an international security consulting and investigation firm. Since 1979, I have worked with many of America's most prominent attorneys and I have been involved as an investigator in numerous high profile cases, including the Doctor Jeffrey R. MacDonald, triple murder case, Fort Bragg, North Carolina, February 17, 1970 and the McMartin pre-school alleged sexual molestation case, Manhattan Beach, CA. My resume is attached.

6. I have examined and reviewed the following documents. From this review, and based on my 46 years as an investigator, it is my professional opinion, that Jon and Ben's lives and personal safety and security have been, and continue to be, in grave danger. It is also my professional opinion, that certain public officials have been derelict in their duties by not removing the children from Thomas Wilkinson before now. These children must be removed immediately to ensure that they are not harmed sexually, emotionally, psychologically and/or physically any more.

a. I have provided herewith a true and exact copy of the Affidavit of Bruce Merriam, Detective, Stowe (Vermont) Police Department, January 22, 1993. In this affidavit, Officer Merriam and Social Worker James Adams interviewed Benjamin Wiegand and Ben "said he has worries, holding up three fingers. When asked, B.W. said those worries are dad (Thomas Wilkinson), his penis on my penis, tongue in my butt and penis and his penis in my mouth. B.W. said that his dad, Tom, pees in his mouth. When asked what color the pee was, B.W. said white. when asked if his dad's penis was hard or soft at the time, B.W. said hard.

b. I have provided herewith a true and exact copy of the letter dated January 25,1993, signed by a Vermont State's Attorney and a District Judge, from the State of Vermont, Lamoille County, charging Wilkinson, between 10/13/92 to 1/20/93 with sex acts of contact between penis and anus with Ben Wiegand, a person under 16 years of age.

c. I have provided herewith a true and exact copy of the Letter dated July 15, 1993 from Department of Social and Rehabilitation, Social Services Division, State of Vermont, Caroline S. Russel, District Director of Social Services to Paul Shanley, Department of Children and Families, New Britain, CT. "I am greatly concerned that the court in Connecticut has ordered custody of Ben to be with Karen Wilkinson, Tom's sister. She has been an avid supporter of her brother, does not believe that he committed these acts with the boys, and has traveled to VT, numerous times with her brother for the various proceedings here. If either of the boys were to be ordered into her custody, this could place them at great risk of harm and further abuse by Mr. Wilkinson".

"Linda Wiegand has acted appropriately to protect her sons from further harm and to see that they are receiving proper counseling to deal with their abuse. Mr. Wilkinson's argument has been that the boys were coached by Ms. Wiegand to say the things that they did in order to gain custody of them in the divorce. Dr. Balsam was questioned about this and feels confident that the boys were not coached."

d. I have provided herewith a true and exact copy of Letter from Dr. Gordon Ahlers, Lakewood Health Care, to Attorney Judith Benedict (who represents Jon and Ben), dated August 25, 1993. Dr. Ahlers relates to Ms. Benedict bizarre behavior of Ben during a visit wherein Ben stated "I'm going to hump you Mom. I'm going to hump you Jon. I'm going to suck your vagina, Mom. I'm going to suck my penis. Jon, I'm going to suck your penis. Jon, why don't you suck my penis. I'm going to fuck you Jon." Dr. Ahlers was attempting to dress Jonathan's burns. While doing this, Ben "attempted to suck his own penis." Dr. Ahlers further states that Jon and Ben needed ongoing psychotherapy to get them through this stage of child sexual abuse.

e. I have provided herewith a true and exact copy of the Discharge, Outright Summary, McLean Hospital, Belmont, MA for Benjamin Wiegand Wilkinson, date of discharge September 2, 1993. Benjamin described as a four and a half year old boy. Page six of this report states that on August 28th and 29th, Ben showed an increase in concerns about sexual issues. Ben spoke about his concerns about Aunt Karen... "problems... pee pee and poo poo problems." He stated "My dad has 116 problems. He has pee pee and poo poo problems." While playing Nintendo, Ben lost his turn, and said about Mario, the Nintendo character, that his "doo doo was sticking out" and made a reference to Mario having a vagina. His brother said he did not have a vagina.

On August 29, 1993, Ben stated "Super Mario got an ax on his penis" after losing in Nintendo, Mrs. Wiegand, the mother, reported to the staff about her son's disclosure of sexual abuse with his father, his aunt and others. In the presence of his mother and a friend. Ben stated that he had "pee pee and doo doo problems" with his father outside one day. He stated that his "Aunt Karen has a vagina, a pee pee hole, and butt hole and tried to kill him". The report further states that after the mother left, that he had "gina" problems with Aunt Karen, who he said "Pushed my head down to her "gina" and stood up and tried to pee in my mouth."

This report further states Ben advised "Well, I have these problems. My dad has these problems. He wakes me up in the middle of the night and takes me outside. I saw animals and I got killed." When asked what Ben meant by "got killed", he answered, "Well, when you get that close to animals, you get killed." The report further states, that afternoon, Ben asked to show one of the staff the picture he was drawing. While drawing he said "She pee pee'd into my mouth.. Auntie Karen pee'd into my mouth. That's what these drops are here...pee. In that hole there is a vagina." When asked what one of the figures in a drawing represented, Ben answered "That's me.. my mouth." Ben gave the writer the drawing and when the writer asked if he wanted her to keep it, Ben said "Yes, I want you to have it so you won't forget what I told you."

Page 8 of same report states "sexualized material and comments about possible abuse by Ben increased over the weekend of 8/27-8/29. This included comments specifically implicating his father and Karen as well as drawings."

f. I have provided herewith a true and exact copy of the Discharge, Outright Summary, McLean Hospital, Belmont, MA for Jonathan Wiegand, date of discharge September 2, 1993. Jonathan is a seven and a half year old boy. Upon first meeting Jon and Ben, the report states Jon spontaneously advised "I know why we're here." He stated "It's because my dad put his penis in our butts, and the last time he put it in Ben's mouth." Dr. Stromherg asked when, and Jon did not respond, coloring quietly, and abruptly stated that he wished to leave.

Page 5 of the report sets forth information of Jon's behavior on August 29, 1993. He playfully kicked his brother in the groin area, once, and while his brother was in the bathroom, stated "I know what he is doing in there." That afternoon, Jon gave a staff member a picture with two human figures, one labeled "Jon" and the other labeled "Tom". The Tom figure has a penis and the Jon figure appears to have buttocks facing towards the penis.

g. I have provided herewith a true and exact copy of the Affidavit taken for the United States District Court, for the District of Vermont, of James Adams, Social Worker, Department of Social and Rehabilitative Services, Morrisville, Vermont, dated June 16, 1994. James Adams is the departments Child Abuse Investigator. In this affidavit, Adams stated that he was provided with sexually explicit drawings made by Benjamin and Jonathan, prior to formal interviews. He states that during the interview, Jonathan states that he had seen his half brother, Benjamin, sexually abused by Tom Wilkinson. Adams stated "based on information relayed by the boys' mother, a licensed psychiatrist, who had seen the boys, the boys themselves, and from the Stowe police, as well as other collateral information, he substantiated that sexual abuse had occurred." He also investigated allegations that Ms. Wiegand had been sexually inappropriate, and found no substantive evidence to these allegations. He stated Ms. Wiegand appeared to he making correct and responsible decisions concerning the boys safety and welfare and the case was closed February 8,1993.

h. I have provided herewith a true and exact copy of the Affidavit taken for the United States District Court, for the District of Vermont, of Stephen J. Balsam, MD, civil action file number 2:94-cv-175, dated August 16, 1994. Dr. Balsam is a licensed psychiatrist practicing in Burlington, Vermont. In this affidavit Dr. Balsam advised after observing and speaking with Jonathan and Benjamin Wiegand, he suspected that they had been sexually abused. This suspicion was based on the following facts: "Both children engaged in violent and overly sexualized behavior, which is common in children who have been sexually abused".." Both recounted specific instances of Thomas Wilkinson abusing them" which included, but were to limited to "Thomas Wilkinson putting his penis in Benjamin's butt, Thomas Wilkinson striking Jonathan, and Thomas Wilkinson licking Benjamin's butt. The children recounted other instances of sexual and physical abuse as well."

Continuing, Dr. Balsam stated that the allegation was made that Linda Wiegand was coaching the children. He advised "I conducted a stress interview with the children while Ms. Wiegand was absent from the room. During that interview I explained to the children that they bad to be careful, to tel1 the truth, because the allegations they were making could result in their dad going to jail. Benjamin then became very angry. After he calmed down, he said that he did not want his dad to go to jail, but just wanted him to stop doing these bad things to him. Benjamin's reaction to this interview was immediate and straightforward." Continuing, Dr. Balsam stated in his report "Jonathan's reaction was to remain quiet for many weeks. He eventually told me that he wished Tom would go to jail." Dr. Balsam stated "because of the fact that I stressed and surprised the boys with my statement about possible jail, without Linda being present, and because their reactions were harmonious with their individual personality styles, I felt that no coaching had occurred,"..."Interestingly, both continued to assert that their father had sexually abused them. It was their reactions to this interview that led me to believe that the children's allegations of sexual abuse were credible."..."My belief that the children had been sexually abused by Thomas Wilkinson was arrived at after lengthy consideration."

i. I have provided herewith a true and exact copy of the separate depositions of Jonathan Wiegand and Benjamin Wiegand taken for the United States District Court, for the District of Vermont, at Department of Children and Families Headquarters, Hartford, CT. On page 27, line 21, "Q: All right. Now, where were you when he (Thomas Wilkinson) stuck his penis in your butt? A: Where were we? Q: Where were you? What house? A: The one in Connecticut, when we were all living together, and the one in Vermont, when he visited." On page 28, line 9, "Q: Would you be standing or laying down? A: Laying down, faking like I was asleep when he did it. Q: And would you be laying on your back or on your tummy? A: Sometimes on my back, sometimes on my tummy." Page 28, line 18, "Q: So you pretended you were sleeping? A: Yes. Q: And would Tom say anything to you? A: Yes, he would kill me if I told. Q: But you pretended to sleep anyway? A: When he walked in the door and was doing it to Ben, I peeked, and I was watching it, too, happen to Ben. Q: All right. So when he walked in the door, you were peeking in then, and you saw him doing it to Ben? A:I was laying on my bed and he was in with Ben and I was peeking and he did it to me.

i. Page 29, line 8, "Q: And what would Ben do or say about all this? A: He got threatened too. A: Uh-uh. Q: How did he get threatened? A: That he would kill us if we said anything to anyone. Q: Did he ever kill you? A: No, because we never told anyone until we were living in Vermont, away from him." Page 30, line 2, "Q: Now..and then, and when you were in your house in Connecticut, what did you wear to bed? What did you sleep in? A: Pajamas. Q: So, when Tom came in, you were pretending to sleep? Did he take your PJ's off or did he leave them on? A: Took them off. Q: And did that wake..did you still pretend to be asleep? A: Not when he started doing it, because it hurt. Q: All right. So did you say it hurt? Did you ever complain about it? A: Once, I think. Q: What did you say? A: Stop. Q: And what did he say? A: He said really nothing. Q: Did you like it, or did you dislike it, him having his penis in your butt? A;I never liked it Q: Did he put anything on his penis when he had it in your butt? A: Yes Q: What did he put on his penis? A: A condom."

Page 31, line 21, "Q: When he put his penis in your butt, was it hard or was it soft? A: Well, it hurt, but it was soft sometimes. Q: Did he ever try to bribe you like with candy or anything? A: Yes. Q: OK. How did be do that? A: Well, before he would bring us to the batting cage and miniature golf and take us to ice cream, and he told us if we said anything, he would kill us right after we got ice cream. Q: And so that was in Connecticut. So you are saying some nights, he would stick his penis, not only in Ben's butt, but he would stick it in your butt? A: What? Q: In Connecticut, he would stick his penis in Ben's butt, and then go over and stick his penis in your butt? A: Yes. He did it to both of us. Q: Same night? A:(nodding head in the affirmative) Q: How soon after he put his penis in Ben's butt would he would put it in your butt? A:I don't know. An hour."

Page 32, line 24, "Q: Now, in Vermont, did he ever stick his penis in your butt or do anything that you didn't like? A: Yes, he did. "Q: OK, when was that? A: At night." Page 33, line 10, "Q: The night that Tom did something that you didn't like. A: He did that more than one time. Q: Okay. Was it always at night. A: Yes. Sometimes he did it in the day. Q: Okay. But most times at night? A: Yes. Q: And usually, your mom was sleeping? A: Yes. Q: Do you recall times when he did it...Did he ever do it in the Stowe house, next to the school? A: Yes. Q: Okay. And whereabouts were you when he did it.. or when he did it to Ben? A: He did it to both us."

Affidavit of Ted L. Gunderson Part II

The testimony of this child continues throughout the remainder of the deposition, which is 65 pages in length. Benjamin's deposition was also taken on this date and is 31 pages in length, very informative and indicates similar behavior as Jonathan's which is indicative of a child who has been sexually abused. It should he noted, with extreme interest, that these children were forced to sit next to the man, Wilkinson, during these depositions, who they accuse of sexually abusing them, with no child advocate in the room, and with Wilkinson's attorney as the "children's" attorney. A videotape of this deposition is available through the Vermont Federal Court Judge.

j. I have provided herewith a true and exact copy of the Physician's Affidavit of Children's Condition of Imminent Danger, by Dr. Gordon Ahlers, Burlington, Vermont, August 19,1996 to the Commissioners of Social Services, States of New York and Connecticut. In this affidavit, Dr. Ahlers informed the Commissioners of Social Services, that he had grave concerns about Jon and Ben's safety and well-being and asked them to immediately investigate this report and to remove these children from abuse and harm. He stated "I believe that every minute counts and these children are in danger of being further sexually abused" and according to the children's statements to him, "they were threatened with their lives for disclosing the abuse and the abusers."..."These children are in serious and imminent danger."..."The boys were at risk from Tom and from his sister, Karen, and should have no contact with them." ..."In addition, the boys' hospital reports (McLean Hospital, Belmont, MA) from September, 1993 indicate that Benjamin describes and implicates Tom and Karen having oral and anal sex with him."..."As a mandated reporter and as the children’s' physician, having first hand knowledge of the children's statements and allegations, I ask that you immediately withdraw these children from an environment which presents the risk of further physical, psychological, and sexual abuse as each second goes by. I feel that we have a moral and legal obligation to remove these children, secure their safety, and interview them about their past and present trauma. I believe that unless you act immediately, these children will be further victimized and perhaps deceased. How can the person the children accuse of raping them, be in charge of their care and well-being?"

k. I have provided herewith a true and exact copy of: 1. Protective order from the State of New York, Family Court, Duchess County, Judge James D. Pagones, Family Court Judge, August 21, 1996. This order was issued as a direct result of Dr. Ahler's Statement as set forth above (j). Because of this order, the New York State Police were dispatched to Karen Wilkinson Nutter's house to take Jon and Ben away >from her and to return them to their mother. The children and Nutter were no longer there when the police arrived. They were later found in Suffield, CT and the Suffield police refused to serve this order.

This order awarded custody of Jon and Ben to petitioner, Linda Wiegand. It denied respondent, Thomas Wilkinson, all access to, all visitation and contact with the children, and it ordered that the court make and enter an order of protection in favor of the children by appointing a law guardian to advance the best interests of the children. It ordered that Thomas Wilkinson shall not harass, menace, recklessly endanger, engage in disorderly conduct towards, assault or threaten the children. It ordered that Wilkinson shall stay completely away from the children and the petitioner, her residence and place of employment.

2. Multi~purpose Petition, Family Court, Duchess County, to the Honorable James D. Pagones, in the matter of Benjamin and Jonathan Wiegand, August 21, 1996, from Robert B. Allers, Acting Commissioner. This is an order that Jon and Ben be removed from the custody of their aunt, Karen Nutter.

3. Sworn statement by Louise Tetor, Case Manager II, State of New York, Duchess County, signed August 21, 1996. Ms. Tetor advises that on August 20, 1996, a report of suspected child abuse was received concerning Benjamin and Jonathan Wiegand and involving the Aunt, and current custodian, Karen Nutter. The report alleges that the children are in imminent danger with Ms. Nutter because of allegations of sexual abuse.

l. I have provided herewith a true and exact copy of the Letter dated August 23, 1996 from the Duchess County Social Services Department, Poughkeepsie, New York, Louise W. Teter, Case Manager II and Dorothy Sucato, Supervisor, to Mr. Thomas Wilkinson, 1360 South Street, Suffield, CT 06078. This letter informs Mr. Wilkinson that he is listed as an alleged perpetrator on a suspected child abuse maltreatment report sent to Duchess County by the State Central Registry, Albany, New York The letter asks Mr. Wilkinson to contact the Social Services Department for an interview. It is not known if Wilkinson was interviewed.

m. I have provided herewith a true and exact copy of the CPS (Child Protective Services) Report No.11340, State of Connecticut, Department of Children and Families (DCF), CPS Report Protocol, October 31, 1996. Status of report: Protective service accepted. Case open date: August 20, 1996. Reporter James Thomas, State's Attorney, 101 Lafayette Street, Hartford, CT 06106. Home phone (860)566-3190. This inside report which was furnished anonymously to Linda Wiegand states that Jon and Ben Wiegand are "at risk" and the alleged perpetrator is Thomas Wilkinson, 1360 South Street, Suffield, CT 06078. This report confirms that DCF is aware that Jon and Ben are with the "father" as of the date of this report. Intake worker Margaret Russell and Intake Supervisor, Linda Harris, according to this report, are also aware of the sexual abuse allegations made by Ben and Jon against Thomas Wilkinson, and according to DCF form 2073-A. it was the intention of the writer, who appears to be Margaret Russel, to refer this mailer to the appropriate law enforcement agency for a criminal investigation.

n. I have provided herewith a true and exact copy of the Letter from James E. Thomas, Connecticut State's Attorney, Criminal Division, to Linda Rossi, Commissioner, DCF, Hartford, CT, dated October 30, 1996. In this letter, Mr. Thomas states "It has been reported to me that Thomas Wilkinson has removed these children (Jon and Ben) from the State of Connecticut. Pursuant to CGS 17A- 103, I have reasonable cause to suspect that these children are in danger of being abused and or have been abused and I am referring said matter to you for the action you deem appropriate."

o. I have provided herewith a true and exact copy of the Defendant's Reply to Plaintiffs Opposition to Motion to Compel and Request for a Protective Order, signed by Harrison Liebowitz, Assistant Attorney General, Waterbury, Vermont, dated November 19, 1996. AAG Liebowitz attended Jon and Ben's deposition on August 1, 1996 at Connecticut DCF headquarters and comments as follows:

"Thomas Wilkinson was physically present in the room, during the deposition, without the children having a support person to accompany them."..."Jon Wiegand maintained at his videotaped deposition that he was sexually abused by Thomas Wilkinson, a position that he has continued to maintain since the allegations first arose."... "The written transcript of this deposition completely fails to show the detail of emotion suffered by this child in the process of this attempted impeachment, including his attorney forcing him to tears."

p. I have provided herewith a true and exact copy of the Affidavit of Gordon K. Ahlers, MD of Children's Condition of Immediate Danger, dated November 19, 1996, submitted November 20, 1996 to the Hartford Superior Court, Judge George Levine presiding with Judith Benedict as the children's "attorney", and was ignored. Transcript of this court hearing is available. This letter states that Dr. Ahlers learned on August 16, 1996 that Ben and Jon Wiegand were in the care and custody of Tom Wilkinson and his sister, Karen. Dr. Ahlers reiterates information as set forth in his letter dated August 19, 1996 ( above) and further states "How can the persons the children accuse of raping them, be unsupervised in caring for them...in addition the children are at risk for the AIDS virus...which increases exponentially as each day goes by which includes further sexual abuse." He continues "Untreated and unsupervised pedophiles caring for two defenseless, innocent children is a travesty. I recommend that the children be removed from Tom and Karen Wilkinson immediately, that they be given to their mother Linda Wiegand, and that she be ordered to take them to an appropriate medical facility which specializes in the diagnosis and treatment of severely sexually and emotionally abused children..."

Dr. Ahlers concluded that "the medical/legal maneuvering in both Vermont and Connecticut has done nothing to serve the truth or interests of these two boys." ..."I believe that the children are at grave psychological and physical danger."

q. I have provided herewith a true and exact copy of the Motion to Amend, March 31, 1997, Linda Pierce Prestley, Assistant Attorney General, representing Attorney General Richard Blumenthal. This petition is in an abuse and neglect case that DCF filed against Thomas Wilkinson, January, 1997. It states that the petitioner, Linda D'Amato Rossi, Commissioner of DCF moves this Juvenile court in Rockville, CT to amend their petition to add the allegations of neglect, specifically 1: The children have been living under conditions detrimental to their well being; 2: The children have been denied proper care and attention emotionally.

r. I have provided herewith a true and exact copy of a Motion to Quash Defendant's Subpoena Duces Tecum, filed by the law firm of Carmody and Torrence, on behalf of Dr. Kenneth Robson, Institute of Living Medical Group, dated April 18, 1997. In response to Linda Wiegand's subpoena to produce any and all copies of audio taped interviews of Jon and Ben, conducted by Dr. Robson, in 1993 and 1994, his motion to quash these tapes was granted. The motion asked that the tapes not be released because "Sessions with the minor children involved discussions of very sensitive issues, including, grave allegations of sexual abuse by their father, Thomas Wilkinson."

s. I have provided herewith a true and exact copy of a Motion to Amend, May 14, 1997, Linda Pierce Prestley, Assistant Attorney General, representing Attorney General Richard Blumenthal. This petition is in an abuse and neglect case that DCF filed against Thomas Wilkinson, January, 1997. It is amended to "reflect the following facts"..."The children were abused as defined by CT state statutes. This allegation is based primarily on the statements of the children to Dr. Kenneth Robson in 1993; their statements to various professionals in the State of Vermont in 1994; statements that the respondent, the mother, claims were made to her by the children and statements made by Jonathan during a deposition on August 1, 1996, that the respondent, father of Ben and legal guardian of Jon, Thomas Wilkinson, sexually molested them. After the children were handed over to the alleged perpetrator, during the depositions taken on August 1, 1996, the children were afforded no protection, with no legal counsel to ensure their best interests, yet Jonathan, although traumatized by the questions posed, continued to assert that he and his brother had been sexually abused by Mr. Wilkinson." This further claims that DCF has been denied access by Mr. Wilkinson to the children's purported therapist, access to the children, and access to school officials, completely thwarting DCF statutory mandates to investigate referrals of abuse. This Motion to Amend states that access to the children has been prevented, although consent is not required to interview the children, when the alleged perpetrator is a member of the household.

t. I have provided herewith a true and an exact copy of the Petition: Neglected, Uncared-for, Dependent Child/Youth, filed by DCF on. June 4, 1997 in Rockville Juvenile Court which states that Jon and Ben "are being denied proper care and attention, physically, educationally, emotionally, or morally; are being permitted to live under conditions, circumstances or associations injurious to well-being; have been abused, a condition which is the result of maltreatment such as but not limited to, malnutrition, sexual molestation, deprivation of necessities, emotional maltreatment or cruel punishment; that they are uncared for, in that, their home cannot provide the specialized care which the physical, emotional or mental condition of the children requires."

I have seen many drawings by both children, a true and exact copy contained herewith. They are sexually explicit showing the genitals in some instances. A survey, by I believe, UCLA, was conducted in the late 1980's that established that children who were never sexually molested did not include genitals in their drawings whereas a high percentage of those who were sexually molested did include the genitals in their drawings. Another survey in the late 1980's, by I believe, University of New York at Buffalo, revealed that children tell the truth in traumatic situations 98% of the time (exact percentage not known at this time.) I do not have the surveys available at this writing, but will provide them at a later date.

I have personally inspected Ms. Linda Wiegand's home and note, when the children are removed and placed into her custody, each has his own bedroom and facilities, including toys and bicycles; the facilities are clean and safe. They provide pleasant surroundings for the children. I have met with officials of the Hamden police department, including Chief of Police, John Amhrosio, and Inspector Bob Nolan, and they have assured me that they will provide safety in the event of a problem or emergency.

I have read the foregoing affidavit, it is true and accurate under the penalty of perjury to the best of my knowledge, and belief.

Signed:

Ted L. Gunderson, retired FBI Senior Special Agent in Charge

Subscribed and sworn to before me this 29th day of October, 1997, in and for New Haven county, State of Connecticut. ss: Hamden

Notary: Linda M. Melillo Seal My Commission Expires

December 31, 2000