Johannesburg - A trauma specialist testifying in the Jacob Zuma rape trial, has rejected defence suggestions that the woman should have developed ways of resisting such attacks.
The woman has admitted to having been raped before.
Zuma's counsel, Kemp J Kemp, suggested that the woman, with her history of being a rape victim, should have developed ways of resisting such attacks.
Merle Friedman, the trauma specialist, replied: "I haven't met people who have made an active effort to get used to being raped."
Last week, the woman told the court that when she turned around and saw Zuma naked she just "froze", did not fight back or scream, and was in a daze that lasted for some time.
Friedman, reading her assessment of the woman to the court, said: "Based on recent literature, freeze, flight, fight, fright, faint provides a more-complete description of the human acute stress response sequence than current descriptions."
It was "entirely consistent" with the literature and her professional experience, that there were variations of response.
"However, when the attack is completely unexpected, and the victim is woken from sleep and perceives herself to be trapped, it is probable that her response would be to freeze and submit, rather than to fight.
"In addition, the history of the relationship, as that of father/daughter, and the respect in which she held him, would further reduce the chance of her fighting.
'Others stay in the freeze'
"She did say 'no' twice to him and turned her face away and closed her eyes, which was some attempt at not being there or fleeing.
"The first response to a traumatic event is to freeze and some people come out of it and other people stay in the freeze," she said.
The woman has known Zuma since she was five and repeatedly referred to him throughout her testimony as "umalume" (uncle).
Friedman said most women "froze" while being raped and studies showed that even soldiers were known to freeze in traumatic situations.
Kemp disagreed, saying this often depended on circumstances, such as if the attacker was bigger than the woman, or if he was armed.
Spoke about her sexual needs
At the time of the alleged rape in Zuma's Johannesburg home last year, he was 5kg heavier than the woman.
Kemp also said it was not usual for a woman and her father to speak about her sexual needs - as Zuma and the complainant had before the alleged rape - and questioned Friedman on her knowledge of the Zulu culture.
She said she was not qualified to say if this was an appropriate conversation, according to Zulu tradition and culture.
The complainant testified last week that she had been raped three times while a child and believed that a pregnancy was due to a rape she did not remember.
'She was completely overwhelmed'
Friedman said she interviewed the woman, called "Khwezi" (star) by a group of supporters who refer to themselves as the "One in Nine" group, twice - once for an hour, and once for an hour and a quarter.
She also studied her statements, was briefed by the police and found that the woman was completely overwhelmed and shocked by the alleged rape.
She said it was normal for rape victims to take a long time to report rapes and difficult for them to begin to use the word "rape" to describe what had happened to them.
"The time it took her to be able to use the word was very consistent with rape survivors."
Showed signs of dissociation
This and the "trance-like" state she spoke of could have explained confusing information she sent afterwards in an SMS.
This said that Zuma was beginning to look at her sexually, there was "something in my drawers" and the "mothers must not know".
Friedman testified that the woman also showed signs of dissociation and startled easily.
Dissociation was when the human mind was so overwhelmed it could not actually deal with it. A person could dissociate by freezing or becoming unaware of what was going on."
"Dissociation is usually indicative of early childhood sexual abuse," she said.
The dissociative amnesia associated with this could explain why she could not remember how she fell pregnant.
Questioned about 'selective memory'
The woman believes she fell pregnant after being raped at a seminary during what she describes as an "attack" which included fainting.
But Kemp put it to her that this could just have been a way of securing permission for an abortion at that time.
He questioned Friedman extensively on what he believed was "selective memory" and on why the woman could remember certain details, but not others.
He also wanted to know why she had not conducted tests to determine the levels of trauma claimed and whether the woman was malingering.
Friedman said most of these tests were based on norms not applicable to South Africa and it would have been irresponsible to do so.
Tense exchanges in court
She based her assessment on two tests accepted in South Africa, her professional experience and by consulting international specialists.
She believed that the woman showed signs of post-traumatic stress disorder.
She only started speaking about the rape when she was in her own office and when she felt safe.
The exchange between Kemp and Friedman was tense at times and with Kemp at one stage questioning an expert's description of trauma she presented by saying: "Can I ask you, did she leave out shouting for help, because it doesn't start with an 'f'?"
To which Friedman replied: "I don't think that requires an answer."
The doctor who examined the woman told the court in the afternoon the only injury the woman had was a posterior fourchette tear between 2mm and 5mm long.
This could have been from force or from passion, from not having intercourse for a long time, a lack of preparation (such as not being lubricated), or from an instrument or a nail.
She had appeared calm, said Dr Mupata Likibi.
He described in intimate detail the physical attributes and the state of her vagina.
Likibi will continue his testimony on Tuesday.
Trip to Dar es Salaam
Towards the end of Friedman's testimony Kemp asked her to confirm that the woman told her she went shopping often "which was not like her".
Friedman replied this was one of the few things she was allowed to do while in the witness-protection programme.
Kemp then asked if she knew about a trip made to Dar es Salaam in Tanzania, and just before asking Judge Van der Merwe for a lunch break, posed the question: "Didn't you ask where she got the money?"
He did not pursue that line of questioning after lunch.
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