IN THE CIRCUIT COURT OF WASHINGTON COUNTY, ARKANSAS
STATE OF ARKANSAS PLAINTIFF VS. NO. CR.-75403 THOMAS ALFRED TAYLOR DEFENDANT
AFFIDAVIT
Comes Hillary Rodham of Fayetteville, Arkansas, and being duly sworn states upon oath the following:
I am the attorney for Thomas Alfred Taylor and am fully familiar with the facts and circumstances of this case.
The defendant is charged with the crime of first degree rape of [redacted], age 12, of 724 E. Johnson, Springdale, Arkansas.
I have made an investigation of the facts and circumstances in this case and verily believe that a psychiatric examination of the complainant, [redacted] is necessary and vital in this case.
I have been informed that the complainant is emotionally unstable with a tendency to seek out older men and to engage in fantasizing. I have also been informed that she has in the past made false accusations about persons, claiming they had attacked her body. Also that she exhibits an unusual stubbornness and temper when she does not get her way.
I have also been told by an expert in child psychology that children in early adolescence tend to exaggerate or romanticize sexual experiences and that adolescents with disorganized families, such as the complainant, are even more prone to such behavior.
For these reasons and others that may be presented to the Court at the hearing on this motion, I believe a psychiatric examination would be in the best interests of justice.
WHEREFORE, I respectfully request that the relief sought in the motion be in all respects granted.
Hillary Rodham Attorney or Defendant
Sworn and subscribed to before me this 28th day of July, 1975. Pamela V. Bone Notary Public
My Commission expires: 11-15-77