I have no idea if it happened or not, but one does not have reliable memories before 5. It's just a human thing. Sometimes people have a vague image but they can't place it in time, and it's usually a reconstructed memory based on a story or a photo.
Basing an accusation like this on a 3-yo's memory is dicey. It actually weakens the accusation imo. That it continued and she clearly remembers it later is very different and he should be investigated thoroughly.
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