The Complainant's Testimony at Trial Cannot Be Relied Upon to Establish Proof Beyond A Reasonable Doubt

In the course of numerous interviews, the complainant has given irreconcilable accounts of what happened immediately after her encounter with the defendant, leaving us unable to ascertain what actually occurred or to count on truthful testimony from the complainant in this regard. She has also made numerous false statements, both to prosecutors and in the past. Some of these statements were made under oath or penalty of perjury; some constituted fraudulent acts.

1. The Continued Conflicting Accounts from the Complainant Regarding the Charged Incident
2. The Complainant's Persistent Pattern of False Statements, Including False Accounts of a Prior Rape