John Ramsey Deposition - Wolf Case - December 12, 2001

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    5 NO. 00-CIV-1187(JEC)
    7 ~~~~~~~~~~~~~~~~~~~~~~~~~~~
    10 December 12, 2001
    9:49 a.m.
    500 The Candler Building
    12 127 Peachtree Street, N.E.
    Atlanta, Georgia
    14 Alexander J. Gallo, CCR-B-1332, CRR
    2 On behalf of the Plaintiff:
    4 Law Offices of Darnay Hoffman
    5 Suite 209
    6 210 West 70th Street
    7 New York, New York 10023
    8 (212) 712-2766
    9 .EVAN M. ALTMAN, Esq.
    10 Law Offices of Evan M. Altman
    11 Suite 495
    12 5901-C Peachtree Dunwoody Road
    13 Atlanta, Georgia 30328
    14 (770) 394-6466
    15 .
    16 On behalf of the Defendants:
    17 JAMES C. RAWLS, Esq.
    18 ERIC P. SCHROEDER, Esq.
    19 S. DEREK BAUER, Esq.
    20 Powell, Goldstein, Frazer & Murphy, L.L.P.
    21 Sixteenth Floor
    22 191 Peachtree Street, N.E.
    23 Atlanta, Georgia 30303
    24 (404) 572-6600
    25 -and-
    1 L. LIN WOOD, Esq.
    2 MAHALEY C. PAULK, Esq.
    3 L. Lin Wood, P.C.
    4 2140 The Equitable Building
    5 100 Peachtree Street
    6 Atlanta, Georgia 30303
    7 (404) 522-1713
    8 .
    9 Also Present:
    10 Patricia Paugh Ramsey
    11 Michael McElroy, Videographer
    12 .
    13 .
    14 .
    15 .
    16 .
    17 .
    18 .
    19 .
    20 .
    21 .
    22 .
    23 .
    24 .
    25 .
    1 Deposition of John Bennett Ramsey
    2 December 12, 2001
    3 THE VIDEOGRAPHER: We are on the
    4 video record at 9:49.
    5 MR. HOFFMAN: Good morning. This is
    6 the deposition of John Ramsey in the case of
    7 Robert Christian Wolf versus John Bennett Ramsey
    8 and Patricia Paugh Ramsey.
    9 I am the lead counsel for the
    10 plaintiff Chris Wolf.
    11 Would the gentlemen here identify
    12 themselves?
    13 MR. WOOD: My name is Lin Wood. I
    14 represent the defendants John and Patsy Ramsey.
    15 MR. RAWLS: My name is Jim Rawls. I
    16 am co-counsel for the defendants, John and Patsy
    17 Ramsey.
    18 MS. RAMSEY: I am Patsy Ramsey.
    19 MR. PAULK: Mahaley Paulk.
    20 MR. SCHROEDER: Eric Schroeder.
    21 MR. ALTMAN: Evan Altman, co-counsel
    22 with Darnay Hoffman, representing the plaintiff.
    23 MR. WOOD: The deposition is taken
    24 pursuant to the Federal Rules of Civil Procedure.
    25 The deposition is taken pursuant to agreement of
    1 counsel.
    2 The deposition is taken pursuant to a
    3 stipulation and protective order agreed to by all
    4 parties, which protective order specifically
    5 states, as we went over yesterday, the right of
    6 counsel to make sure that this deposition is not
    7 abused and that only areas that are relevant to
    8 the claims and defenses in this lawsuit are
    9 inquired of today in this deposition.
    10 Anything you want to add to that,
    11 Mr. Hoffman?
    12 MR. HOFFMAN: No. Sounds like pretty
    13 much what we agreed yesterday was the case. And
    14 I believe yesterday you also explained what you
    15 believe the claims were, in fact, that would be
    16 relevant with respect to the deposition.
    17 So based on yesterday's statement, we
    18 will just continue the deposition.
    19 MR. WOOD: Do you want to swear the
    20 witness, please.
    21 JOHN RAMSEY, having been first duly
    22 sworn, was examined and testified as follows:
    25 Q. Your full name, please, sir?
    1 A. John Bennett Ramsey.
    2 Q. Have you ever attended a deposition
    3 before?
    4 A. Yes.
    5 Q. Are you familiar with the deposition
    6 procedure?
    7 A. I wouldn't say I am familiar with it.
    8 I have been at one deposition.
    9 Q. All right. If at any time you don't
    10 understand --
    11 MR. WOOD: He will answer questions,
    12 and he understands how to proceed with answering
    13 your questions. You do not need to counsel or
    14 advise him in that regard. Your job is to ask
    15 questions. If you would, go ahead and pose a
    16 question to the witness, please, sir.
    17 MR. HOFFMAN: This is my deposition,
    18 Mr. Wood.
    19 MR. WOOD: It is your deposition, but
    20 you are not here to lecture or counsel or advise
    21 my witness on what he is or is not to do.
    22 Trust me, he will answer your questions, and if
    23 he doesn't understand them, he will so indicate.
    24 Ask your first question, please.
    25 Q. (By Mr. Hoffman) Mr. Ramsey, who is
    1 Chris Wolf?
    2 A. Chris Wolf is your client, and he is
    3 a person who came to our attention as someone who
    4 should be looked at as a possible suspect in the
    5 murder of our daughter.
    6 Q. Do you remember how Mr. Wolf came to
    7 your attention as a possible suspect?
    8 A. I believe he contacted my wife's
    9 parents -- no, I am sorry. His girlfriend
    10 contacted my wife's parents and said she firmly
    11 believed that he was the killer of my daughter,
    12 that he had been out all night and returned home
    13 early that morning, and that we needed to look at
    14 him.
    15 Q. Do you know what was done with that
    16 information when your parents were -- or
    17 Mrs. Ramsey's parents were given that?
    18 A. I am sure we referred it to our
    19 attorneys through -- or through our attorneys to
    20 our investigators.
    21 Q. All right. Do you know which
    22 investigators were responsible for investigating
    23 that claim on your behalf?
    24 A. Not for certain. I think probably
    25 they were involved, each involved at different
    1 stages.
    2 Q. Do you know the names of the
    3 investigators that were involved?
    4 A. I do.
    5 Q. Could you give me their names?
    6 A. Well, there was a group called Ellis
    7 Armistead & Associates. David Williams. John --
    8 and I can't think of his last name. Those were
    9 the principal investigators that our attorneys
    10 retained.
    11 Q. Without revealing the substance of
    12 what you were given with respect to any reports
    13 that your investigators may have given you, do
    14 you remember if you ever saw any investigative
    15 reports concerning Chris Wolf?
    16 A. I don't remember seeing any
    17 investigative reports regarding Chris Wolf.
    18 Q. Do you remember whether or not you
    19 were shown investigative reports with respect to
    20 any of the other potential suspects that you may
    21 or may not have been looking at?
    22 A. I don't recall ever seeing a report
    23 on any suspect that they might have looked at.
    24 MR. HOFFMAN: All right. For the
    25 purpose of my next question, I would like the
    1 court reporter to please mark this as Plaintiff's
    2 Exhibit 14 for identification. And, actually, I
    3 am going to turn to the portion to which I am
    4 going to direct Mr. Ramsey to look at this.
    5 (Plaintiff's Exhibit-14 was marked for
    6 identification.)
    7 THE WITNESS: You want me to read
    8 this part that is highlighted?
    9 Q. (By Mr. Hoffman) Yes. After you
    10 had an opportunity to read it to yourself, please
    11 read it out loud.
    12 A. You want me to read it out loud? I
    13 am sorry; I wasn't listening. I was reading.
    14 Q. Yes, Mr. Ramsey.
    15 A. "Katie Couric: You also mentioned
    16 Chris Wolf, a total stranger whose girlfriend
    17 reported that he had disappeared on Christmas
    18 night and was very agitated rather when he
    19 watched the news of the murder on TV.
    20 "John Ramsey: Uh-huh.
    21 "Katie Couric: Why do you mention
    22 him?
    23 "John Ramsey: Because he had been
    24 widely mentioned in the news, and we wanted to
    25 clarify the facts that we knew.
    1 "John Ramsey: I can tell you when,
    2 when we first startled looking at it, one
    3 particular lead early on, my reaction was, 'This
    4 is it. This is the killer.' And our
    5 investigators said, 'Whoa, whoa, whoa,' he'd say,
    6 'Don't do a Boulder police on me. Don't rush to
    7 conclusions.'"
    8 Q. Do you remember making this statement?
    9 A. I don't remember making the statement,
    10 but that was a number of years ago, I guess,
    11 so....
    12 MR. HOFFMAN: In fact, just simply
    13 for the record, I believe this is the Katie
    14 Couric Today Show. It was aired on, I believe,
    15 March 24th. And I believe it was in the year
    16 2000.
    17 MR. WOOD: Are you talking about his
    18 statement to Katie or the statement to the
    19 investigator?
    20 MR. HOFFMAN: The statement to Katie
    21 that --
    22 MR. WOOD: Did you understand he was
    23 asking you if you remember making a statement to
    24 Katie as opposed to the investigator?
    25 THE WITNESS: Yeah.
    1 Q. (By Mr. Hoffman) Okay. Now, do you
    2 remember who it was that you were -- that you
    3 made the statement, This is it, this is the
    4 killer? Do you remember who that person was, the
    5 investigator that had shown you material on it?
    6 A. Yes.
    7 Q. Can you name that person?
    8 A. I don't recall his first name.
    9 Helgoth was his last name, a fellow that
    10 committed suicide on Valentine's Day, the day that
    11 Alex Hunter told the world that they were going
    12 to get the killer.
    13 Q. Right. So you were not referring to
    14 Chris Wolf in that statement; is that correct?
    15 A. No. That is correct.
    16 Q. Now, I want to ask you, in the
    17 statement, there is a reference to an early lead.
    18 What kind of lead was it? Was it -- you know,
    19 specifically. Since you weren't shown any files.
    20 MR. WOOD: Do you mean how was he
    21 imparted, the information imparted to him by
    22 Helgoth?
    23 MR. HOFFMAN: Yes. I had asked him
    24 earlier if he ever had an opportunity to review
    25 any of the investigative files on any of the
    1 murder suspects.
    2 MR. WOOD: No, you didn't. You
    3 asked him if he had ever reviewed any
    4 investigative reports.
    5 MR. HOFFMAN: All right. Reports.
    6 MR. WOOD: And now you are asking
    7 him how he obtained the information about Helgoth?
    8 MR. HOFFMAN: Uh-huh, yes. If he
    9 hadn't seen any investigative reports.
    10 THE WITNESS: I think -- I don't
    11 recall specifically whether my attorney told me
    12 about him or one of the investigators, but
    13 typically I communicated with my attorney.
    14 Q. (By Mr. Hoffman) Were you actually
    15 shown evidence or were you just simply given a
    16 summary?
    17 A. I have not seen any evidence that the
    18 police have.
    19 Q. Any evidence that your investigators
    20 have?
    21 A. I have seen a few things relating to
    22 your client. I don't know that I have seen
    23 anything relating to Helgoth.
    24 Q. All right. Were you involved in
    25 directing the activities of these investigators
    1 that were working on your behalf?
    2 A. I was not.
    3 Q. Then what was, basically, your
    4 association with the private investigation of the
    5 potential suspects in the murder of JonBenet
    6 Ramsey?
    7 A. The investigators were retained by our
    8 attorneys, and they stated to me that the
    9 principal purpose of those investigators was to
    10 prepare a defense in the case that the police
    11 might bring a charge against me.
    12 I hoped that they would also follow
    13 up on leads that came to us, but I was
    14 frequently reminded by our attorneys that their
    15 principal role was to prepare a defense should
    16 that be necessary.
    17 Q. For a moment, I just want to direct
    18 you to the morning of December 26th. And to the
    19 degree that you can remember things today, I
    20 would like to ask you if you could just briefly
    21 summarize what happened when you got up that
    22 morning.
    23 A. Well, I got up, was showering, getting
    24 prepared for a trip that we would be leaving on
    25 early that morning. I heard Patsy scream. I
    1 ran downstairs. She told me that JonBenet was
    2 missing, that there was a ransom note.
    3 She asked me, What should we do?
    4 I said, Call the police.
    5 Sometime during that frantic period,
    6 we checked on Burke. He appeared to be asleep
    7 to us. A uniformed officer arrives reasonably
    8 quickly, and I focussed all the energy I could
    9 focus on getting my daughter back from that point
    10 on.
    11 Q. When the police officer arrived, do
    12 you remember the name of the police officer?
    13 A. I think it was French was the first
    14 one there, Officer French.
    15 Q. Did you have an opportunity to observe
    16 what Officer French did at that point when he
    17 arrived? Did he speak to you?
    18 A. He spoke to me. I told him my
    19 daughter had been kidnapped. He said, Do you
    20 think she might have just run away?
    21 And I said, For heaven's sake, she is
    22 only six years old; no, I don't.
    23 He asked us all to, Patsy and I, to
    24 stay in the sunroom, which is a small room off
    25 our living room. So I didn't see all that he
    1 did beyond that.
    2 Q. You say that he asked you to stay in
    3 the sunroom. Did you remain in the sunroom the
    4 whole morning?
    5 A. We did not. Other people arrived.
    6 The police arrived. They asked to use our cell
    7 phones because theirs were dead. They asked us
    8 to do a number of things that required us to
    9 leave that room.
    10 Q. Did Officer French give you any
    11 explanation as to why he wanted you just to
    12 remain in the sunroom?
    13 A. No.
    14 Q. Did anybody ask you to go back to
    15 the sunroom and remain there?
    16 A. No.
    17 Q. Did any other law enforcement official
    18 ask you to remain in any other part of the
    19 house?
    20 A. No.
    21 Q. Do you remember, in a general way,
    22 where you were in the morning from the time the
    23 police arrived and you left the sunroom? Could
    24 you just sort of walk me through what was going
    25 on?
    1 A. I was in the house. That is
    2 probably the best I could tell you.
    3 Q. Did you ever have occasion prior to,
    4 say, 1:00 in the afternoon to go down to the
    5 basement?
    6 A. Yes.
    7 Q. How many times?
    8 A. Twice.
    9 Q. Prior to 1:00?
    10 A. I don't know what time it was. I
    11 wasn't paying attention.
    12 Q. Prior to the time that I believe it
    13 was Linda Arndt had asked people to begin looking
    14 around the house?
    15 A. Linda Arndt asked me to look around
    16 the house, yes.
    17 Q. Did she ask anybody else to do it?
    18 A. I don't remember her specific
    19 instruction, no.
    20 Q. Prior to Linda Arndt asking you to
    21 look around the house, how many times did you go
    22 to the basement?
    23 A. Once.
    24 Q. Do you remember at what time in the
    25 morning you went to the basement?
    1 A. I do not.
    2 Q. Do you remember what you saw in the
    3 basement when you went down there?
    4 A. I saw a partially opened window with
    5 broken glass and a suitcase beneath the window.
    6 Q. When you would -- did you see
    7 anything else there?
    8 A. Not that looked out of the ordinary.
    9 Q. May I ask why you went to the
    10 basement at that time?
    11 A. I was trying to determine how someone
    12 could have gotten into our house.
    13 Q. Did anyone ask you to go to the
    14 basement at that time?
    15 A. No.
    16 Q. Do you know if anybody saw you go to
    17 the basement at that time?
    18 A. I have no idea.
    19 Q. When you saw that the basement was in
    20 the condition that it was in, as you have just
    21 described it, and you came back upstairs, did you
    22 inform anybody of what you found in the basement?
    23 A. I don't recall specifically if I did
    24 or not. I have a vague recollection of telling
    25 Linda Arndt that I found an open window with
    1 broken glass, but that I perhaps had broken that
    2 glass myself months earlier.
    3 Q. Do you think you might have mentioned
    4 that to any other law enforcement officer beside
    5 Linda Arndt?
    6 A. Not that I recall.
    7 Q. When Linda Arndt asked you to go down
    8 to the basement, I think that was sometime in the
    9 early afternoon --
    10 A. I don't remember the time. I really
    11 don't.
    12 Q. When she asked you to go down to the
    13 basement, could you explain why you chose going
    14 to the basement since you had already been there
    15 earlier?
    16 A. She told me to go through the house
    17 and look for anything -- go through the house
    18 thoroughly, as I recall, and look for anything
    19 that seems out of place. And so my intent was
    20 to do it thoroughly.
    21 Q. Did you ask Fleet White to join you?
    22 A. I think I did, as I recall.
    23 Q. Do you remember exactly the sequence
    24 of events when you went down to the basement the
    25 second time?
    1 A. Uh-huh (affirmative).
    2 Q. Can you tell me where you looked?
    3 A. I went back into the train room,
    4 showed Fleet the broken window, explained to him
    5 that I might have broken it myself months ago.
    6 I showed him the suitcase that I saw under the
    7 window, which I felt was very out of place.
    8 We looked for any large pieces of
    9 broken glass. And then I got up and went to
    10 the cellar room, opened the door, and found
    11 JonBenet.
    12 Q. Do you remember why you decided to go
    13 to the cellar door at that particular time?
    14 A. It was the next door outside of the
    15 train room. Other than that, no, it was a
    16 methodical search, in my mind.
    17 Q. Was there a reason that you hadn't
    18 looked at that door the first time you went down
    19 to the basement?
    20 A. There is no external exit from that
    21 room, so I was -- the first time I went to the
    22 basement, I was trying to figure out how someone
    23 could possibly have gotten into our home.
    24 Q. Do you remember whether or not Fleet
    25 White said anything to you while you were down in
    1 the basement showing him the broken window and
    2 the suitcase?
    3 A. I don't remember that he said
    4 anything.
    5 Q. Okay. Were you the first one to go
    6 to the cellar door?
    7 A. I don't know.
    8 Q. When you opened the cellar door, can
    9 you describe, to the best of your recollection
    10 today, what it was that you saw?
    11 A. I saw a white blanket, and I knew
    12 immediately I found JonBenet.
    13 Q. Had you turned the light on or --
    14 A. I don't remember turning the light on.
    15 Q. When you found the white blanket, what
    16 did you do?
    17 A. I took the tape off of her mouth, I
    18 tried to untie the cord that was wrapped around
    19 her arms, and I kissed her and talked to her.
    20 Q. Did you do anything then after that?
    21 A. I realized that she wasn't just
    22 asleep, that this was not good. And I carried
    23 her upstairs.
    24 Q. Do you know what, if anything, Fleet
    25 White was doing at that time?
    1 A. I have no idea what he was doing. I
    2 wasn't aware that he was around me.
    3 Q. So you wouldn't have known whether or
    4 not he had stepped into the cellar area where her
    5 body was?
    6 A. No. I don't -- I -- well, I don't
    7 remember him stepping into the cellar area, no.
    8 Q. Do you remember asking him to go
    9 upstairs and get assistance or help?
    10 A. I did not. I did not ask him that.
    11 Q. During the time -- I am going to
    12 direct your attention to the time that is earlier
    13 than the time you found JonBenet's body, and that
    14 is the time when the police were in the house,
    15 between the time Officer French first arrived and
    16 the time Linda Arndt asked you to make a more
    17 thorough search of the house.
    18 Were you questioned by the police?
    19 A. Yes, I think I was.
    20 Q. All right. Do you remember making
    21 statements to the police?
    22 A. I remember responding to a number of
    23 questions they had.
    24 Q. Do you remember if you were asked
    25 whether or not the house was secured when you
    1 went to bed the night before?
    2 A. No, I don't remember that they asked
    3 me that question.
    4 Q. Do you remember ever telling any law
    5 enforcement officer that the house had been
    6 secured before you went to bed that night?
    7 A. I remember telling, I believe it was
    8 Linda Arndt, that I thought all the doors were
    9 locked, and I didn't understand how someone could
    10 have gotten in. Of course, I learned later that
    11 one of the doors was found wide open.
    12 Q. Did you know whether or not the
    13 security alarm was on that night?
    14 A. It was not on.
    15 Q. Did you tell Linda Arndt or any other
    16 police officer that the security alarm was off --
    17 A. I don't --
    18 Q. -- the night before?
    19 A. No. I don't believe I did.
    20 Q. When you were -- when you spoke to
    21 the police, did you offer them any theories as to
    22 why you thought JonBenet was missing?
    23 A. I responded to a number of questions
    24 they had.
    25 Q. Do you remember some of those
    1 questions?
    2 A. Oh, they asked: Was anyone angry
    3 with you at work? Was anyone around you acting
    4 peculiar recently in the last few days? Anyone
    5 you could think of that would do such a thing?
    6 Q. And do you remember what you answered?
    7 A. Oh, not completely. I know that in
    8 terms of people that were angry with me at work,
    9 I mentioned Jeff Merrick, who we had terminated
    10 due to performance. And he was extremely angry,
    11 to the point of making threats in the past six
    12 months prior to that.
    13 Patsy made me aware of Linda
    14 Hoffman-Pugh's strange behavior just prior to, but
    15 you need to ask Patsy about that because that is
    16 not firsthand information.
    17 Q. Anyone else?
    18 A. I don't believe so.
    19 Q. Do you remember what, if any, other
    20 questions you were asked by any of the law
    21 enforcement people that were present?
    22 A. Well, they asked if we had any recent
    23 pictures of JonBenet. Gosh, that is the only one
    24 I can remember.
    25 Q. Were you asked at any time by law
    1 enforcement during this period what had transpired
    2 the night before in your home?
    3 A. During that period?
    4 Q. Uh-huh (affirmative).
    5 A. I don't recall that they asked that.
    6 Q. Can you remember what occurred on
    7 December 25th, say, from the morning on?
    8 A. Generally, I can.
    9 Q. Could you give me just a general
    10 summary, to the best of your knowledge?
    11 A. I remember the kids bounding into our
    12 room that morning excited to open their presents.
    13 Our normal tradition is that I go downstairs,
    14 turn on the Christmas tree lights. I brought a
    15 bicycle out of the garage that I had as a
    16 surprise for Patsy.
    17 The kids came down. We opened
    18 presents. JonBenet wanted me to take movies, but
    19 my battery was dead. We had breakfast, Christmas
    20 breakfast.
    21 Q. Do you remember what was served at
    22 that breakfast?
    23 A. Not -- no, I don't. Probably
    24 pancakes.
    25 Q. Was that one a family favorite?
    1 A. Yes.
    2 Q. Who --
    3 MR. WOOD: Wait. You asked him a
    4 question, and he was trying to answer. Why don't
    5 you let him finish his answer.
    6 MR. HOFFMAN: All right. Sorry.
    7 THE WITNESS: I enjoyed making
    8 pancakes with kids, and JonBenet enjoyed
    9 decorating them. So, yes, it was kind of a
    10 special treat.
    11 Q. (By Mr. Hoffman) And after you
    12 finished breakfast, do you remember what you were
    13 doing?
    14 A. At some point, I went out to the
    15 airport to pre-pack some gifts in the airplane,
    16 check it out, get it ready for an early morning
    17 departure. I remember kids being in and out of
    18 the house when I was there, neighborhood kids.
    19 We were going to go to the Whites'
    20 that evening for a dinner. I remember JonBenet
    21 asking me to help her ride her bike around the
    22 corn- -- around the block, her new bike that she
    23 had gotten for Christmas.
    24 That is generally what I remember that
    25 day.
    1 Q. Do you remember what happened in the
    2 evening, what you were doing in the evening?
    3 A. Well, we went to the Whites' house
    4 where they had family and relatives, friends, I
    5 guess. We were perhaps the only friends there
    6 for Christmas dinner.
    7 Q. Do you remember anything else about
    8 that Christmas dinner at Fleet White's?
    9 A. Nothing notable. It was a family
    10 dinner.
    11 Q. What, if anything, did you do after
    12 Fleet White's dinner?
    13 A. We left. Patsy wanted to drop two
    14 gifts off at the Walkers' and the Stines', which
    15 we did on the way home.
    16 We pulled in the driveway into the
    17 garage. And JonBenet was asleep in the back of
    18 the car. I carried her upstairs and put her to
    19 bed.
    20 Q. Is that the last time you saw
    21 JonBenet alive?
    22 A. Yes, it was.
    23 Q. All right. Do you know if Patsy
    24 joined you in the bedroom when you put her to --
    25 put JonBenet to bed?
    1 A. I don't recall that she was in the
    2 bedroom when I was in the bedroom.
    3 Q. Do you remember what JonBenet was
    4 doing that evening when you were over at Fleet
    5 White's?
    6 A. She was playing with Daphne upstairs.
    7 She and Daphne had both received a little
    8 bead-making machine. She and I and Fleet and
    9 Daphne sat on the floor and made necklace beads.
    10 Q. Do you remember anything else?
    11 A. That is the highlight of my memory.
    12 Q. Do you have any memory of what she
    13 was doing after you left Fleet White's?
    14 A. She was asleep.
    15 Q. How soon after you left Fleet White
    16 did she go to sleep?
    17 A. I don't know. Sometime between the
    18 time she got in the car and when we arrived
    19 home.
    20 Q. Do you remember whether she woke up
    21 at any time between the time you saw her asleep
    22 in the car and the time you put her to bed?
    23 A. She did not.
    24 Q. At that point, after you put her to
    25 bed, what, if anything, did you do?
    1 A. I went downstairs to get Burke in
    2 bed. He was putting together a little plastic toy
    3 that he had gotten for Christmas. I helped him
    4 finish it so he could get off to bed. And we
    5 did that, and then I went to bed myself.
    6 Q. When you say you went to bed
    7 yourself, do you remember exactly the sequence by
    8 which you prepared for going to bed that night?
    9 A. I think I took my clothes off,
    10 brushed my teeth, put my pajamas on, and crawled
    11 into bed. That's --
    12 Q. Did you do anything else?
    13 A. Not that I remember.
    14 Q. Did you use anything to help yourself
    15 go to sleep?
    16 A. I took a melatonin tablet.
    17 Q. Do you know the amount of melatonin
    18 you took?
    19 A. No. It was an over-the-counter
    20 tablet.
    21 Q. Was it a single tablet or half a
    22 tablet or two tablets?
    23 A. I think it was a single tablet, as I
    24 recall.
    25 Q. Do you remember the brand?
    1 A. No.
    2 Q. Do you know or remember whether or
    3 not you read anything before going to sleep?
    4 A. I read for a few minutes, as I
    5 recall, before I turned the light out.
    6 Q. Do you remember at any point Patsy
    7 joining you in bed that night?
    8 A. Patsy was in bed before I went to
    9 bed.
    10 Q. Do you remember what Patsy was wearing
    11 when she got into bed or was in bed?
    12 A. I don't remember specifically, no.
    13 Q. All right. Did you wake up at all
    14 during the night?
    15 A. I did not.
    16 Q. Was this routine pretty much the
    17 normal routine when you went to bed at night when
    18 you were at home?
    19 MR. WOOD: To take off his clothes,
    20 brush his teeth --
    21 Q. (By Mr. Hoffman) Was anything
    22 different than that?
    23 MR. WOOD -- put on his pajamas and
    24 go to bed?
    25 MR. HOFFMAN: Yes.
    1 Q. (By Mr. Hoffman) Anything different
    2 than that?
    3 A. Pretty standard routine.
    4 Q. Pretty standard routine? And --
    5 A. Except I usually didn't take a
    6 melatonin tablet every night.
    7 Q. Why were you taking the melatonin that
    8 night?
    9 A. I wanted to be sure I slept well
    10 because we were going to get up early, and I was
    11 going to fly to Minneapolis and then on to
    12 Michigan, and I wanted to be fresh.
    13 Q. Do you know if Mrs. Ramsey was taking
    14 any medication to help her sleep?
    15 A. Not to my knowledge.
    16 Q. Any melatonin?
    17 A. No, I don't believe so.
    18 Q. You mentioned that you were going to
    19 fly to -- where was it?
    20 A. Minneapolis and then on to Charlevoix,
    21 Michigan.
    22 Q. You have a pilot's license, I presume?
    23 A. Yes, I do.
    24 Q. Would you tell me what sort of
    25 pilot's license you have?
    1 A. I have a commercial license, I have a
    2 flight instructor license for airplanes, for
    3 instrument flying. I have a multi-engine rating,
    4 and I have an instrument rating.
    5 Q. What sort of planes does that allow
    6 you to fly?
    7 A. Anything below 12,500 pounds gross
    8 weight.
    9 Q. Does that include twin engines?
    10 A. Yes.
    11 Q. Does it include any kind of a jet?
    12 A. Most jets are over 12,500 pounds that
    13 I know of.
    14 Q. May I ask you where you learned to
    15 fly?
    16 A. My dad taught me.
    17 Q. Did you ever have occasion to fly
    18 when you were in the military?
    19 A. No, I did not, other than in flying
    20 clubs.
    21 Q. Was that the normal means by which
    22 you would travel; you would fly yourself, or did
    23 you take commercial airlines?
    24 MR. WOOD: Travel in?
    25 Q. (By Mr. Hoffman) Travel around the
    1 country whenever you would travel.
    2 A. If I was flying for business, I
    3 normally would take commercial airlines. If I
    4 was flying personally with my family, we normally
    5 flew ourselves.
    6 Q. You say that -- and I understand that
    7 you were in the Navy; is that correct?
    8 A. Yes.
    9 Q. All right. When you were in the
    10 Navy, would you describe, if you remember, pretty
    11 much what area you were responsible for as a
    12 serviceman?
    13 A. Well, I was a Civil Engineer Corps
    14 officer. I was stationed in the Philippines for
    15 two years. I was the civil engineer for the
    16 Naval supply depot in the Philippines. I was
    17 transferred to Atlanta where I was the base
    18 engineer for the Naval Air Station in Atlanta.
    19 Q. Would you describe what you were doing
    20 as an engineer?
    21 A. Contract management. We ran all the
    22 base utilities, maintenance and repair, road
    23 construction, long-term planning, site planning.
    24 Q. Were you actually involved in any
    25 hands-on engineering projects?
    1 A. I had a staff that did that. I was
    2 in charge of the staff.
    3 Q. So were you ever involved in any of
    4 the actual construction?
    5 A. Did I help pound nails? No.
    6 Q. Or do anything like that, any sort of
    7 manual labor work.
    8 A. In the military?
    9 Q. Yes, in the military.
    10 A. I did not.
    11 Q. When you were not in the military,
    12 did you do that?
    13 A. I enjoy remodeling and doing work with
    14 my hands, yes.
    15 Q. Did you do any remodeling in your
    16 home in Boulder?
    17 A. We did quite a bit of remodeling. I
    18 did not do any of the work there, as I recall.
    19 Q. Did you have occasion to do remodeling
    20 in any of your other homes?
    21 A. We have remodeled every home we have
    22 owned.
    23 Q. Have you personally done any
    24 remodeling in any of these homes?
    25 A. Yes.
    1 Q. When you were in the Navy, you went
    2 through basic training, naturally?
    3 A. I went through officer candidate
    4 school in Newport, Rhode Island.
    5 Q. And would you just describe briefly
    6 what your basic training was like?
    7 A. It was physical training, it was
    8 navigation, celestial navigation, seamanship, rules
    9 of the road relative to ship movement, and,
    10 generally, familiarization with military procedures
    11 and the military system.
    12 Q. All right. You say that one of the
    13 areas that you were instructed in was seamanship?
    14 A. Navigation and piloting. You were
    15 being prepared to captain a ship.
    16 Q. Did any of your basic training involve
    17 -- and I don't know if they still do this --
    18 learning various nautical knots?
    19 A. No.
    20 Q. Do you sail at all?
    21 A. I used to.
    22 Q. Did you pilot your own sailboat or
    23 did you --
    24 A. Yes.
    25 Q. -- have someone --
    1 A. Yes.
    2 Q. -- do it for you?
    3 A. No.
    4 Q. Did you receive any training in
    5 sailing?
    6 A. No.
    7 Q. Are you familiar with the various
    8 knots involved in sailing?
    9 A. I am really not. I should be, but I
    10 am not.
    11 Q. All right. So how would you
    12 generally moor your craft?
    13 A. I would tie it up on a cleat.
    14 Q. Was there any sort of knot that you
    15 used that you could identify that has a technical
    16 term?
    17 A. I don't know the technical term for
    18 it.
    19 Q. Have you had occasion to be able to
    20 look at the knot that was tied around the
    21 so-called paintbrush garotte?
    22 A. I have not.
    23 Q. Is there any reason why you haven't?
    24 A. It is very painful for me,
    25 Mr. Hoffman.
    1 Q. I understand that. But with your
    2 nautical training, do you think that you could in
    3 any way be able to identify the sort of knot?
    4 A. No.
    5 Q. Okay. Do you know whether or not
    6 any -- if your private investigators hired anyone
    7 to look at the way in which that knot was made
    8 and to give a report on it?
    9 A. Not to my knowledge.
    10 Q. Do you know if any of your
    11 investigators have been involved in trying to look
    12 at forensic evidence?
    13 A. What is "forensic evidence"?
    14 Q. Any of the physical evidence that
    15 might have been at the scene that you might have
    16 had occasion to have.
    17 A. Well, I think any evidence that was
    18 at the scene was in the possession of the police.
    19 I don't know that we had any physical evidence
    20 that --
    21 Q. Would the ransom note be considered
    22 physical evidence, in your mind?
    23 A. Absolutely.
    24 Q. Do you know whether or not your
    25 investigators had occasion to have anyone who was
    1 professional in this area examine the ransom note?
    2 A. I believe they did.
    3 Q. Do you know -- well, first of all,
    4 were you ever given a copy of the ransom note?
    5 A. Patsy handed it to me that morning,
    6 yes.
    7 Q. Do you know what happened to the
    8 ransom note after Patsy handed it to you?
    9 A. I gave it to Officer French when he
    10 arrived.
    11 Q. Did you give the ransom note to any
    12 of the friends that you had invited to come over?
    13 A. I did not.
    14 Q. Do you know if the ransom note was
    15 passed around to other police officers? Did you
    16 have occasion to observe that?
    17 A. I don't -- I don't know.
    18 Q. Do you know what happened to the
    19 ransom note after you gave it to Officer French?
    20 A. Not for certain. I think they took
    21 it and made copies of it.
    22 Q. Do you remember the next time you saw
    23 a ransom note?
    24 A. I think Linda Arndt or someone gave
    25 me a Xerox copy of it that morning as we were
    1 waiting.
    2 Q. Do you know why she gave you a Xerox
    3 copy of it?
    4 A. No.
    5 Q. Did you ask for a Xerox copy of it?
    6 A. No.
    7 Q. You say you had an opportunity to
    8 read the ransom note when it was initially
    9 discovered by Patsy --
    10 A. Yes.
    11 Q. -- is that correct?
    12 Would you tell me how much time you
    13 spent reading it?
    14 A. Not specifically. It was -- I spread
    15 it out on the floor and tried to read it as
    16 quickly as possible.
    17 Q. Do you remember when that -- was it
    18 in the morning that Linda Arndt gave you a copy
    19 of the ransom note?
    20 A. It was prior to finding JonBenet. I
    21 don't remember specifically what time.
    22 Q. Do you know how she was able to make
    23 a copy for you?
    24 A. I do not.
    25 Q. Once she gave you a copy of the
    1 ransom note, did you at any point in the morning
    2 read it again?
    3 A. Yes.
    4 Q. Did you read it more than once?
    5 A. Yes.
    6 Q. Do you remember how many times you
    7 may have read it?
    8 A. No.
    9 Q. Would you say a dozen times?
    10 A. I don't remember. I mean, I was
    11 trying to figure out, to the best of my ability,
    12 who in the world had my daughter.
    13 Q. And were you looking at the ransom
    14 note for that purpose?
    15 A. Yes.
    16 Q. When you were looking at the ransom
    17 note, was there anything in the language of the
    18 ransom note that struck you as peculiar?
    19 A. The whole thing was peculiar. We
    20 were addressed as "Mr. and Mrs. Ramsey," and then
    21 they switched to "John" personally.
    22 They asked for twenty dollar bills and
    23 hundred dollar bills, as I recall. The amount
    24 was a very odd amount.
    25 The way the note was signed was very
    1 odd.
    2 The cruelty that they threatened was
    3 bizarre. It was a very sick mind that wrote
    4 that note.
    5 Q. Were there any phrases in that ransom
    6 note that you thought were peculiar?
    7 A. I don't remember at that time that I
    8 thought that, but certainly later, we focused in
    9 on some phrases that seemed very peculiar.
    10 Q. When you say "we focused in on some
    11 phrases" that were peculiar, would you identify
    12 the "we"?
    13 A. Talking corporately in terms of
    14 everyone that was looking at the note.
    15 Q. Would you tell me what phrases you
    16 were focusing on as peculiar?
    17 A. Oh, I think the "grow a brain" phrase
    18 was one that looked odd. "You are not the only
    19 fat cat in this town, John." Those are the two
    20 that I recall now.
    21 Q. "Use your good common sense, John"; do
    22 you remember that phrase?
    23 A. Your good southern common sense, or
    24 something like that.
    25 Q. Did those phrases seem peculiar to
    1 you?
    2 A. On reflection they did. I don't
    3 remember how they struck me that morning.
    4 Q. Had you ever heard any of those
    5 phrases used in relation to you before?
    6 A. In relation to me?
    7 Q. Uh-huh (affirmative).
    8 A. No.
    9 Q. Had you heard anybody that you knew
    10 ever use those as common phrases in their speech?
    11 A. Yes.
    12 Q. Would you identify them?
    13 A. Priscilla White used the term "fat
    14 cat" in my presence.
    15 Q. Any other phrases that you can
    16 remember somebody using?
    17 A. No.
    18 Q. Did anybody in your family ever use
    19 any of those phrases?
    20 A. No.
    21 Q. The phrase "common sense" or "good
    22 southern common sense," have you ever heard
    23 anybody use that before?
    24 MR. WOOD: Are you asking has he
    25 ever heard anybody use the term "common sense"?
    1 MR. HOFFMAN: No.
    2 MR. WOOD: Why don't you give him
    3 the precise phrase from the ransom note so that
    4 we don't have any misunderstandings about what you
    5 are asking, Mr. Hoffman.
    6 MR. HOFFMAN: I will go back and ask
    7 him that. I will get the ransom note in a bit.
    8 I just want to see what he remembers.
    9 MR. WOOD: Darnay, he is telling you
    10 what he remembers in response to your question,
    11 but when you ask him, Have you ever heard anybody
    12 use the phrase "common sense" or "good common" --
    13 I want to make -- I want to know precisely what
    14 you are asking him.
    15 MR. HOFFMAN: All right. Fine.
    16 MR. WOOD: He is entitled to do
    17 that, and that is your obligation in terms of
    18 asking a proper question.
    19 MR. HOFFMAN: Are you finished?
    20 MR. WOOD: He will be glad to look
    21 at the note if you want him to.
    22 MR. HOFFMAN: Thank you. May I
    23 continue, Mr. Wood?
    24 MR. WOOD: Absolutely.
    25 MR. HOFFMAN: Thank you.
    1 Q. (By Mr. Hoffman) Mr. Ramsey, so you
    2 are certain that you don't remember anybody in
    3 your family using any of the phrases in the
    4 ransom note?
    5 A. I am certain I don't remember ever
    6 hearing anyone in my family using any of those
    7 phrases.
    8 Q. Now, just briefly, do you know how
    9 your children were disciplined if they did
    10 something that was against a family rule or any
    11 wishes of their parents in your family?
    12 A. Yes.
    13 Q. Would you tell me how they were
    14 disciplined.
    15 A. I disciplined my children by raising
    16 my voice.
    17 Q. Do you know how your wife disciplined
    18 them?
    19 A. I think in a similar manner.
    20 Q. Did you personally ever have occasion
    21 to spank any of your children?
    22 A. I did not.
    23 Q. Do you have a philosophy with respect
    24 to corporal punishment in child-raising?
    25 A. Yes.
    1 Q. Can you tell me what that is?
    2 A. I don't believe it is appropriate to
    3 strike a child.
    4 Q. Do you know whether or not your wife
    5 ever had an occasion to strike any of the
    6 children?
    7 A. I have never seen her spank any of
    8 our children.
    9 Q. With respect to corporal punishment,
    10 do you know if she has any philosophy that she
    11 has expressed to you?
    12 A. I have only seen it demonstrated. We
    13 have never talked about philosophy of corporal
    14 punishment.
    15 Q. Have you ever discussed how the
    16 children should be disciplined?
    17 A. No.
    18 Q. No time during the marriage?
    19 A. Well, at no time have we ever
    20 discussed how the children should be disciplined?
    21 I am sure we have.
    22 Q. Do you remember any time?
    23 MR. WOOD: All of his children to
    24 the present date?
    25 Q. (By Mr. Hoffman) The two children
    1 that you had with Patricia Ramsey.
    2 A. You know, I don't. They were good
    3 kids. I don't remember ever talking about
    4 discipline. It didn't seem to be necessary.
    5 MR. HOFFMAN: Could I take a break
    6 for just about five minutes at this point? I
    7 want to start going into different areas.
    8 THE VIDEOGRAPHER: We are off the
    9 video record at 10:35.
    10 (A recess was taken.)
    11 THE VIDEOGRAPHER: We are on the
    12 video record at 10:53.
    13 MR. HOFFMAN: Thank you.
    14 Q. (By Mr. Hoffman) Mr. Ramsey, I
    15 forgot to ask you a couple questions before I
    16 asked for a break, and they regard any personal
    17 observations with respect to your daughter
    18 JonBenet.
    19 Do you know if she liked to draw on
    20 her hand? Did you ever personally see that?
    21 A. Not that I recall.
    22 Q. Do you remember whether or not she
    23 had drawn anything on her hand that night?
    24 A. I don't remember seeing anything on
    25 her hand.
    1 Q. Were you away a great deal in the
    2 year prior to her death on business and whatever?
    3 MR. WOOD: "Away a great deal...on
    4 business or whatever?"
    5 MR. HOFFMAN: Yes.
    6 MR. WOOD: Why don't you clear that
    7 question up. It is sloppy.
    8 Q. (By Mr. Hoffman) Did you ever --
    9 MR. HOFFMAN: Mr. Wood --
    10 MR. WOOD: I object to the form of
    11 the question. The question is vague and
    12 ambiguous and sloppy.
    13 MR. HOFFMAN: I object to the
    14 characterization. No, that is not a proper
    15 objection. "Sloppy" is not an objection to
    16 evidence.
    17 MR. WOOD: It strikes me as a sloppy
    18 question. I have asked you to rephrase it. And
    19 so if you want to, please do. If you don't,
    20 leave it on the table.
    21 MR. HOFFMAN: All right.
    22 MR. WOOD: Let's go.
    23 Q. (By Mr. Hoffman) All right.
    24 Mr. Ramsey, how much time would you say you were
    25 at home in the year prior to her death, JonBenet
    1 Ramsey's death?
    2 A. Well, I was normally gone Monday
    3 through Friday from 8:00 in the morning until
    4 5:00 or 6:00 at night every day. I traveled
    5 occasionally. I don't remember specifically that
    6 year. I tried to make my trips either one-day
    7 trips or one or two nights out. Typically, they
    8 were to California, Boston. Twice a year I
    9 probably went to Europe to visit our offices
    10 there.
    11 Q. So would it be fair to say you
    12 didn't do that much travelling away from home?
    13 Is that correct?
    14 A. I don't remember. I really don't.
    15 Certainly, more than I would have liked, I am
    16 sure, but I ran the company. I had to be there
    17 more often than not.
    18 Q. When Mrs. Ramsey was diagnosed with
    19 cancer, do you know what her treatment consisted
    20 of?
    21 A. Her treatment -- yes, I do.
    22 Q. Could you tell me what you do know
    23 about her treatment?
    24 (Whereupon, a discussion ensued and a
    25 recess was taken.)
    1 THE VIDEOGRAPHER: We are on the
    2 video record at 1:27.
    3 MR. HOFFMAN: Would the reporter
    4 please read back the last question that I asked
    5 Mr. Ramsey?
    6 (The record was read by the reporter,
    7 as follows:
    8 "Question: Could you tell me what
    9 you do know about her treatment?")
    10 MR. HOFFMAN: Mr. Ramsey, before you
    11 answer that question, I am withdrawing that
    12 question. Thank you very much.
    13 Q. (By Mr. Hoffman) Mr. Ramsey, I am
    14 going to ask you to look at page 145 of "the
    15 Death of Innocence." And I am going to just
    16 simply ask you to look at the highlighted area at
    17 the very top. And after you have read it, I
    18 would like you to have an opportunity to just
    19 read it out loud.
    20 A. Just the highlighted part?
    21 Q. Yes, please, Mr. Ramsey.
    22 A. "Douglas described the killer as
    23 someone with extreme anger towards John Ramsey,
    24 trying to hurt him in the most devastating manner
    25 possible."
    1 Q. Thank you very much.
    2 Now, Mr. Ramsey, I am also going
    3 to --
    4 MR. HOFFMAN: First of all, I am
    5 going to ask the reporter to please mark this
    6 document Plaintiff's Exhibit 15 for identification.
    7 Mr. Wood, I am going to show this to
    8 you.
    9 I am interested in Mr. Ramsey reading
    10 -- looking at the highlighted parts of that first
    11 on the second page.
    12 (Discussion ensued off the record.)
    13 (Plaintiff's Exhibit-15 was marked for
    14 identification.)
    15 Q. (By Mr. Hoffman) All right. Have
    16 you had a chance to read it, Mr. Ramsey?
    17 A. Yeah.
    18 Q. First I am going to ask you if you
    19 recognize this as a press release dated July
    20 23rd, 1997. Do you recognize this?
    21 A. Do I recognize this as --
    22 Q. As the language, not the article, but
    23 the actual language in this, do you recognize it
    24 at all?
    25 A. You know, I really don't.
    1 Q. Okay.
    2 A. I mean, it quite possibly came from
    3 us, but I don't remember it or recognize it.
    4 Q. I am going to ask you just to look
    5 at the second page and the highlighted area.
    6 Just simply look at the different
    7 elements here of this profile.
    8 Is this profile familiar to you?
    9 A. Generally. I mean, I think these
    10 were post-behavior characteristics that one might
    11 expect in the killer.
    12 Q. Were these characteristics that came
    13 from Mr. Douglas in this profile?
    14 A. I don't remember. It is possible,
    15 but I don't remember.
    16 Q. Okay. Because I just want you to
    17 examine it in conjunction with the statement that
    18 you had in your book that -- I believe the
    19 statement is that, "Douglas described the killer
    20 as someone with extreme anger towards John Ramsey,
    21 trying to hurt him in the most devastating manner
    22 possible."
    23 And I am assuming that, correct --
    24 Mr. Ramsey, do you --
    25 Did you put this statement in the
    1 book because you subscribe to that as true?
    2 A. I can't imagine anybody, anyone that I
    3 have made angry enough to murder a child. I
    4 took that at -- the opinion of someone who
    5 understands the criminal mind better than I do,
    6 but I am not convinced that is correct.
    7 Q. All right. What I would like you to
    8 do is just simply look at the elements on the
    9 second page there. And I would like to ask you
    10 if, for instance, in the first element, I believe
    11 it is, "JonBenet's killer may have been suffering
    12 from some stress in the weeks and months
    13 preceding the crime."
    14 Do you see that element --
    15 A. Uh-huh (affirmative).
    16 Q. -- in that profile?
    17 I am going to ask you, with respect
    18 to Patsy, do you feel that Patsy was under any
    19 kind of unusual stress during the Christmas
    20 holidays, your wife Mrs. Ramsey?
    21 A. No.
    22 Q. Did, at any point during the holidays,
    23 you observe her as working too hard?
    24 A. No.
    25 Q. Do you feel that Mrs. Ramsey took too
    1 much responsibility on herself, helping herself
    2 and other people?
    3 A. Well, she is a very giving person,
    4 but that is her nature. So I don't feel she
    5 took too much on, no.
    6 Q. All right. So you don't believe that
    7 she was under any unusual stress during that
    8 period?
    9 A. Absolutely not.
    10 Q. Okay. The second element here is "A
    11 triggering event, such as a job crisis or crisis
    12 in a personal relationship, may have caused this
    13 individual to vent anger, perhaps at a female
    14 close to him"--
    15 Or to her, though it doesn't say
    16 "her" here.
    17 -- "and perhaps at me personally."
    18 The question I have -- and I am very
    19 sorry to ask you this, and I don't mean any
    20 disrespect -- was there any stress in your
    21 personal relationship with Mrs. Ramsey that you
    22 would have observed at this time?
    23 A. No.
    24 Q. Were you having any marital problems?
    25 A. Absolutely not.
    1 Q. None. Okay. Now, with respect to
    2 two elements down, "He possibly has increased his
    3 consumption of alcohol or drugs," do you -- did
    4 you have occasion to observe Mrs. Ramsey drink at
    5 any point during this period?
    6 A. During what period?
    7 Q. The Christmas holidays.
    8 A. Well, we had a church party at our
    9 house at one point. We were at the Whites' at
    10 one point.
    11 Patsy is not a heavy drinker. I
    12 don't recall an image of her having a drink.
    13 She might have had a glass of wine, but I
    14 don't --
    15 Q. Did you ever have occasion to see
    16 Patsy, what you would call, inebriated at any
    17 point in your marriage?
    18 A. Not that I recall.
    19 Q. Okay. Do you know if Mrs. Ramsey
    20 was taking medication at that time during the
    21 Christmas holidays?
    22 A. Do I know if she was?
    23 Q. Yes.
    24 A. Not to my knowledge.
    25 Q. Now, the next element is "He may have
    1 even turned to religion." Was it your
    2 observation that Patsy was a particularly
    3 religious person?
    4 A. We both were.
    5 Q. Did there come a time during Mrs.
    6 Ramsey's cancer that she expressed to you that
    7 she had experienced an extremely intense spiritual
    8 or religious event in that --
    9 A. We had a healing service that was
    10 conducted by our priest from St. John's. He
    11 prayed an Episcopal prayer that asked God to heal
    12 her body. Patsy returned to NIH within a week
    13 and took a CAT scan, and the cancer was gone.
    14 And we believe that, that our prayers were
    15 answered, yes.
    16 Q. Do you or Patsy believe in the Holy
    17 Spirit?
    18 A. Yes, I do.
    19 Q. Do you believe that the Holy Spirit
    20 is an agent for healing by God?
    21 A. I believe the Holy Spirit is part of
    22 the Trinity of God. And I don't know that I
    23 understand the Holy Spirit's role in healing, no.
    24 I don't know that one way or other.
    25 Q. Are you familiar with Pentecostal
    1 religious beliefs that the true purpose of
    2 Christianity and Jesus' purpose was a healing
    3 ministry, and that the Holy Spirit was involved
    4 in that healing ministry?
    5 A. I am not familiar with that.
    6 Q. Also, are you familiar with the
    7 religious concept of what is known as "being in
    8 right relation to God"?
    9 A. I don't know of that as a concept.
    10 I have heard that phrase.
    11 Q. I was just wondering if you understood
    12 what that phrase meant to you.
    13 A. Do I understand the phrase "being in
    14 a right relationship with God"?
    15 Q. Yes. "One being in right relation to
    16 God."
    17 A. Well, I would -- that would not be
    18 how I would describe my relationship with God.
    19 Q. All right. I just wanted to know
    20 that.
    21 A. Uh-huh (affirmative).
    22 Q. The next statement: "He may be
    23 rigid, nervous and preoccupied in casual
    24 conversation."
    25 How would you describe your
    1 observations of Patsy -- of Mrs. Ramsey's --
    2 excuse me -- Mrs. Ramsey's conversational, you
    3 know, attitude? Do you find her to be rigid or
    4 nervous or preoccupied in conversation?
    5 A. You mean in general?
    6 Q. In general.
    7 A. No.
    8 Q. During the Christmas holidays, leading
    9 up to the death of your daughter, did you find
    10 her to be in any way rigid, nervous, or
    11 preoccupied --
    12 A. No.
    13 Q. -- in conversations?
    14 A. No.
    15 Q. Well, the next one I think speaks for
    16 itself. "He may have tried to appear very
    17 cooperative with the authorities."
    18 Have you tried, to the best of your
    19 knowledge, to cooperate with the authorities?
    20 A. Well, I think we detailed that pretty
    21 accurately. We were very willing to cooperate
    22 with them, given that their intentions were to be
    23 trusted.
    24 Q. "He may have quickly constructed an
    25 alibi for his whereabouts the night JonBenet was
    1 killed."
    2 That brings me to the issue of the
    3 next area I want to go into, which is the area
    4 of the ransom note, which I am going to show you
    5 at page 407, which I showed Mrs. Ramsey
    6 yesterday, in your book with respect to the
    7 ransom note.
    8 Would you read that aloud? I had
    9 Mrs. Ramsey do it yesterday too.
    10 A. Number 4. "The ransom note.
    11 Considered earlier and throughout the book, the
    12 note was written by the killer and remains an
    13 extremely important clue. An adequate amount of
    14 handwriting samples from the killer should
    15 conclusively tie him to the long and rambling
    16 note."
    17 Q. Do you still believe that statement to
    18 be true?
    19 A. That is my opinion, yes.
    20 Q. Yes. In your opinion?
    21 A. Yes.
    22 Q. May I ask you if any of your
    23 investigators made any attempt to examine or
    24 prepare -- did any of your investigators prepare
    25 handwriting reports with respect to your
    1 handwriting and Mrs. Ramsey's handwriting?
    2 A. I never saw any reports. I don't
    3 know what they prepared.
    4 Q. Do you know if reports have been
    5 prepared?
    6 A. I don't know that for a fact.
    7 MR. WOOD: For the record, I do
    8 think we indicated in response to requests for
    9 production that there are written reports that
    10 were in the possession of Hal Haddon under a
    11 belief on his part that they are grand jury
    12 materials that he is not allowed to release even
    13 to me, present counsel for the Ramseys.
    14 So I don't know that John knows that,
    15 but I do want to make the record clear that you
    16 know that.
    17 MR. HOFFMAN: Also, just to make the
    18 record clear, I don't know what effect, if any,
    19 the July 5th ruling by Judge -- the Denver
    20 federal judge, Wiley Daniel, with respect to
    21 third-party testimony and the fact that the grand
    22 jury secrecy rule with respect to that which was
    23 declared unconstitutional. To the extent that
    24 that would be the statement of the party --
    25 meaning whoever the expert was, his report is, in
    1 effect, statements, whether or not that that now
    2 would be covered under the grand jury secrecy
    3 act.
    4 And so for the purposes of this
    5 record, I would indicate that that might not be
    6 available to counsel.
    7 MR. WOOD: I have asked Hal Haddon
    8 since that ruling to produce those for me, and he
    9 declined.
    10 MR. HOFFMAN: Okay. Thank you.
    11 Q. (By Mr. Hoffman) Mr. Ramsey, what I
    12 am going to do now is I am going to first have
    13 the reporter mark this Plaintiff's Exhibit 16 for
    14 identification. We'll do that.
    15 MR. HOFFMAN: Mr. Wood, I will show
    16 you this, and please show it to your client.
    17 (Plaintiff's Exhibit-16 was marked for
    18 identification.)
    19 Q. (By Mr. Hoffman) Mr. Ramsey, I am
    20 going to ask you to look at the document that
    21 has been marked Plaintiff's Exhibit 16 for
    22 identification, and I am going to ask you if you
    23 recognize this document.
    24 A. Yes, I believe I do.
    25 Q. Could you identify it, please?
    1 A. Well, it appears to be a copy of the
    2 ransom note that we found in our home.
    3 Q. Does it look substantially like the
    4 ransom note that you saw that morning?
    5 A. Yes, I think so.
    6 Q. Okay. Now, Mr. Ramsey, I am going
    7 to ask you to, once again, look at it. And I
    8 am going to ask you, in looking at it, whether
    9 or not you see any similarity between your wife's
    10 handwriting and the handwriting in the ransom
    11 note; you personally.
    12 A. Absolutely not.
    13 Q. None at all?
    14 A. No.
    15 Q. Not even a little bit?
    16 A. Not even a little bit.
    17 Q. Now, Mr. Ramsey --
    18 A. Patsy writes very neatly. She is a
    19 feminine writer.
    20 Q. Right.
    21 A. There are misspellings in the note.
    22 She graduated at the top of her class. She
    23 doesn't misspell words like "business" and
    24 "possession."
    25 Q. Do you think the ransom note writer
    1 was trying to disguise their identity?
    2 A. I have been told that that was the
    3 intent, but there are parts of it that -- where
    4 that is broken down. I don't know which parts,
    5 but --
    6 Q. Do you think that maybe some of the
    7 misspelling may have been an attempt by whoever
    8 was writing this note to disguise their identity?
    9 A. I don't think so, because I think
    10 they tried to be very articulate, to the best of
    11 their ability, and misspellings were because they
    12 didn't know how to spell those words.
    13 Q. With respect to the sloppiness of the
    14 handwriting, do you think it is possible that the
    15 handwriting -- that the person who wrote this
    16 handwriting was trying to make their handwriting
    17 look sloppier than normal?
    18 A. I don't know. It is very sloppy
    19 handwriting. I would agree with that.
    20 Q. Now, Mr. Ramsey, do you know whether
    21 or -- were you ever told that Mrs. Ramsey could
    22 not be eliminated from any of the handwriting
    23 investigation being done by the Colorado Bureau of
    24 Investigation? Did anybody ever tell you that?
    25 A. I was told that it was virtually
    1 certain that she did not write the note, but that
    2 there were some similarities which exist in all
    3 of our handwriting because we have all been
    4 taught the same, and that is how we communicate
    5 is with the written language in English. But
    6 that because of these few similarities, she could
    7 not be absolutely eliminated, but it was highly
    8 improbable that she wrote the note. And that, in
    9 fact, there were more dissimilarities in her
    10 writing than a number of other people that had
    11 been looked at.
    12 Q. Right. Do you know if your
    13 handwriting was examined by the law enforcement?
    14 A. As far as I know, it was.
    15 Q. Do you know whether or not you were
    16 eliminated as the author of the note?
    17 A. I was told that, on a scale of 1 to
    18 5, Patsy was placed at a 4.5 in terms of
    19 probability. In other words, a very low
    20 probability. Mine was a 5.
    21 Q. Just to go back to the one point
    22 that you made, it was your understanding that the
    23 reason Mrs. Ramsey could not be eliminated was
    24 because of what is, I think called, style book
    25 similarities. We all go to school, as you say; we
    1 are taught to make our letters look the same way.
    2 Is that the reason?
    3 MR. WOOD: Let me object to the form
    4 of the question only because you have used what I
    5 think is meant to be some form of a technical
    6 term, "style book similarities."
    7 MR. HOFFMAN: Yes.
    8 MR. WOOD: I don't think that was a
    9 term Mr. Ramsey used. So to the extent you
    10 misstated his testimony, I object to the form.
    11 If you would understand it, John, feel
    12 free to answer it.
    13 THE WITNESS: Well, I don't know what
    14 that means. I told you what I was told. And I
    15 was told that by our attorneys. I was told that
    16 by -- I heard the police make that statement. I
    17 heard the district attorney make that statement,
    18 that it is highly improbable that Patsy wrote
    19 this note based on their testing and our testing.
    20 Q. (By Mr. Hoffman) Do you know if she
    21 was the only one that law enforcement could not
    22 completely eliminate as the author of --
    23 A. No. In fact, I was told that your
    24 client had fewer dissimilarities than Patsy had
    25 with the note.
    1 Q. Without revealing an attorney/client
    2 privilege, do you know who told you that? Was
    3 it a law enforcement source, or was it your
    4 private investigators?
    5 A. I don't recall. I don't recall.
    6 MR. WOOD: I do know --
    7 THE WITNESS: I was told that there
    8 were other people that were tested that were much
    9 more interesting than Patsy in terms of a
    10 comparison.
    11 Q. (By Mr. Hoffman) Now, how do you
    12 know that?
    13 A. I was told that. I don't recall by
    14 whom. It is general knowledge that I have in my
    15 head.
    16 MR. WOOD: Plus I want to point out,
    17 and I have not shared with Mr. Ramsey Alex
    18 Hunter's testimony on that very point, which I
    19 think you were aware of --
    20 MR. HOFFMAN: Yes.
    21 MR. WOOD: -- who has stated there
    22 were a number of people who had not been
    23 eliminated that were under suspicion.
    24 MR. HOFFMAN: I just want to know
    25 how Mr. Ramsey, if he remembers how he knows
    1 that, with respect to that.
    2 Q. (By Mr. Hoffman) Now, Mr. Ramsey, I
    3 am going to ask you to do something that I did
    4 yesterday, at least on a few pages here, and that
    5 is I am going to ask you to look at Plaintiff's
    6 Exhibit No. 1 that was marked for identification
    7 yesterday, and I would like you to look at that
    8 document.
    9 A. Okay.
    10 Q. I am going to ask you if you
    11 recognize, without naming anybody, any of the
    12 figures in that particular document?
    13 A. I think I recognize two.
    14 Q. Okay. Now I am going to ask you to
    15 look at the handwriting beneath the document, and
    16 I am going to ask you if you recognize that
    17 handwriting.
    18 A. I do not.
    19 Q. Could it be your wife's handwriting?
    20 A. I don't recognize it. It doesn't
    21 look like Patsy's writing. It is sloppy. It is
    22 irregular. I would not look at that and say
    23 that is Patsy's handwriting.
    24 Q. Thank you. Now I am going to hand
    25 to you Plaintiff's Exhibit No. 2 that was marked
    1 for identification yesterday, and I am going to
    2 ask you to please look at that.
    3 Now I am going to ask you if you can
    4 identify, without naming the individuals in those
    5 photographs, any of them.
    6 A. Yes.
    7 Q. Now I am going to ask you to look at
    8 the handwriting, and tell me if you can recognize
    9 the handwriting.
    10 A. I do not.
    11 Q. Could that be your wife's handwriting?
    12 A. I doubt it very seriously.
    13 Q. Tell me why you don't think it is
    14 your wife's handwriting.
    15 A. It doesn't look like her handwriting.
    16 It is sloppy. It is -- it just doesn't look
    17 like her handwriting.
    18 Q. Now I am going to ask you to look at
    19 Plaintiff's Exhibit 11, marked for identification,
    20 and all I am going to ask you to do is look at
    21 this document and tell me if you have ever seen
    22 it before.
    23 A. Not that I recall.
    24 Q. So would it be fair to say that
    25 today is the first time you ever have seen that
    1 document?
    2 A. I think so. I don't remember seeing
    3 it. I don't remember seeing it. Let me put it
    4 that way.
    5 Q. Okay. Thank you very much.
    6 Now, Mr. Ramsey, do you know -- have
    7 you ever heard the name Cina Wong?
    8 A. I have heard that name in association
    9 with you, yes.
    10 Q. Do you know who Cina Wong is?
    11 A. I have no idea.
    12 Q. Have you heard the name David Liebman?
    13 A. It was on that form right there.
    14 Q. Had you ever heard the name or seen
    15 the name before this?
    16 A. Not that I recall.
    17 Q. Are you aware those names appear in
    18 your book?
    19 A. It is very possible.
    20 Q. So you weren't the person that
    21 provided the names in the book, in the
    22 manuscript; is that correct?
    23 A. I don't remember. It is possible.
    24 I found that my brain cells have depleted a lot
    25 during the last five years.
    1 Q. Have you ever heard the name Howard
    2 Rile?
    3 A. Yes.
    4 Q. Would you tell me who Howard Rile is?
    5 A. He is either a handwriting expert or
    6 an expert linguistic examiner. I don't recall
    7 which.
    8 Q. Do you recall the context in which
    9 you heard his name?
    10 A. I think he was someone that our
    11 attorneys consulted to examine a number of
    12 documents that we have received.
    13 Q. Do you know if he examined Mrs.
    14 Ramsey's handwriting?
    15 A. I believe that he did, yes.
    16 Q. Do you know if he prepared a written
    17 report?
    18 A. I don't know.
    19 MR. WOOD: Again --
    20 THE WITNESS: Isn't he the one that
    21 started the book?
    22 MR. WOOD: No, that is someone else.
    23 THE WITNESS: Okay.
    24 MR. WOOD: Again, we go back, and we
    25 have provided you as his counsel information that
    1 Mr. Rile and Mr. Cunningham, we are told, did
    2 prepare written reports, but they were submitted
    3 to the grand jury and they are, again, in the
    4 possession of Hal Haddon, and the question of
    5 releasing them from Mr. Haddon, at least, is
    6 something that he has not done voluntarily yet.
    7 Whether he did that in response to a request from
    8 you, I don't know. But there are written reports
    9 from Mr. Rile and Mr. Cunningham about Mrs.
    10 Ramsey.
    11 Q. (By Mr. Hoffman) Had you ever heard
    12 of the name Floyd Cunningham, Mr. Ramsey?
    13 A. Yes.
    14 MR. WOOD: Lloyd.
    15 MR. HOFFMAN: I am sorry. Is it
    16 Floyd?
    17 MR. WOOD: Lloyd.
    18 MR. HOFFMAN: Oh, Lloyd. All right.
    19 I am sorry. I don't know why I thought Floyd.
    20 Q. (By Mr. Hoffman) Lloyd Cunningham,
    21 have you ever heard that name?
    22 A. Yes.
    23 Q. Would you tell me in what context you
    24 heard that name?
    25 A. I think he was someone that was used
    1 by our attorneys and investigators to look at
    2 handwriting exemplars.
    3 Q. Do you know anything else?
    4 A. That he is at the top of his field.
    5 That is what I remember.
    6 Q. Do you know if Mr. Cunningham prepared
    7 a written handwriting report?
    8 A. I don't know that for a fact.
    9 MR. WOOD: Again, same observation --
    10 MR. HOFFMAN: Absolutely.
    11 MR. WOOD: -- for the benefit of you
    12 and the benefit of the record.
    13 MR. HOFFMAN: Yes.
    14 Q. (By Mr. Hoffman) I want to make
    15 sure that what I am about to say is accurate, so
    16 I have to do it in summation, and Mr. Wood will
    17 absolutely correct me if I am wrong in
    18 characterizing anything that I have said.
    19 MR. WOOD: It sounds like an
    20 invitation.
    21 MR. HOFFMAN: It is, Mr. Wood, in
    22 this particular instance.
    23 Q. (By Mr. Hoffman) I want to make
    24 sure I am correct.
    25 You have not personally seen the
    1 handwriting report, if there was one, by
    2 Mr. Rile; is that correct?
    3 MR. WOOD: Hang on a second. Let me
    4 confer. I want to make sure we are not touching
    5 into an area that might go to attorney-client
    6 privilege --
    7 MR. HOFFMAN: Okay.
    8 MR. WOOD: -- because that report was
    9 prepared by former counsel for Mr. Ramsey, or at
    10 their request for Ramsey purposes.
    11 MR. HOFFMAN: Well, I can remove the
    12 offending language as to prepared it -- prepared
    13 for him. I don't know who prepared it for him.
    14 Q. (By Mr. Hoffman) I am not asking
    15 that. That this handwriting report by Mr. Rile
    16 was prepared for the Ramseys, irrespective of who
    17 prepared it. I am not trying to identify who
    18 prepared it, but that it was prepared by some
    19 person for you.
    20 A. I know of no report that was prepared
    21 for us that I saw.
    22 Q. And when you say report, I am more
    23 interested in if you had an opportunity to see
    24 any report involving handwriting of either Mrs.
    25 Ramsey or yourself by any expert that you or your
    1 agents and people that worked for you hired. Did
    2 you have an opportunity to see any report?
    3 A. I don't recall seeing any report.
    4 Q. Do you remember whether or not you
    5 had an opportunity to see any other handwriting
    6 reports by, say, law enforcement?
    7 A. I don't recall seeing any reports from
    8 law enforcement, no.
    9 Q. Then are you saying that you are
    10 relying upon the opinion or statements of people
    11 that have seen those reports as the basis for
    12 your belief that Mrs. Ramsey is not the ransom
    13 note writer?
    14 MR. WOOD: Hold on one second.
    15 I don't know how he is going to
    16 differentiate counsel's discussions. Do you want
    17 to omit counsel?
    18 MR. HOFFMAN: You mean our
    19 discussions?
    20 MR. WOOD: Well, you say that you
    21 are relying -- are you saying that you are
    22 relying upon the opinion or statements of people
    23 that have seen those reports as the basis for
    24 your belief that Mrs. Ramsey is not the ransom
    25 note writer?
    1 Do you understand what he is asking
    2 you, John?
    3 THE WITNESS: Yes.
    4 MR. HOFFMAN: Well, to put it
    5 more --
    6 MR. WOOD: I am going to let him
    7 answer.
    8 MR. HOFFMAN: Oh, okay.
    9 MR. WOOD: Let's go ahead and just
    10 let him answer.
    11 THE WITNESS: No, I do not base my
    12 opinion on the reports that I have heard from
    13 others. I base my opinion on that I know my
    14 wife. I would stake my life on the fact that she
    15 did not murder her child, she did not fake all
    16 of this nonsense, and she did not write this
    17 bizarre note. That is what I stake my belief on,
    18 Mr. Hoffman.
    19 Q. (By Mr. Hoffman) So it is not based
    20 on anything empirical, such as --
    21 A. The empirical information supports that
    22 belief totally.
    23 Q. I am just wanting to determine whether
    24 you are familiar with the empirical information
    25 that supports it.
    1 A. Yes.
    2 Q. I am trying to distinguish between
    3 your belief in your wife, which is understandable,
    4 and a belief that comes from actually having
    5 looked at forensic evidence that you personally
    6 have had an opportunity to view.
    7 MR. WOOD: Let me just -- again, I
    8 am going to object to the form of that question
    9 because I think -- at one point you are talking
    10 about determining whether he is familiar with the
    11 information, and then you turn it around and make
    12 it limited to reports that he has personally had
    13 an opportunity to view.
    14 I mean, you are omitting the fact
    15 that his counsel, and present company included,
    16 may have fully apprised him of the nature of the
    17 variety of expert reports in summary fashion
    18 verbally.
    19 MR. HOFFMAN: Yes.
    20 MR. WOOD: That would go into
    21 attorney-client privilege.
    22 MR. HOFFMAN: Right. Which I am not
    23 trying to go into.
    24 MR. WOOD: But you can't omit the
    25 fact they may have received that information. I
    1 don't think it would be fair for the record
    2 to --
    3 MR. HOFFMAN: No.
    4 MR. WOOD: I don't want the record
    5 to appear that Mr. Ramsey is unaware of what
    6 Mr. Rile, Cunningham, and, obviously, the
    7 information from the Boulder authorities that we
    8 know from Mr. Smit and others in terms of -- and
    9 Mr. Hunter now, and Chief Beckner, what that --
    10 those conclusions, even though he hasn't seen the
    11 formal report.
    12 Am I making sense here?
    13 MR. HOFFMAN: Absolutely.
    14 MR. WOOD: I just want to make sure
    15 the record is not -- doesn't mislead one to think
    16 that Mr. Ramsey, because he may have heard it
    17 through counsel, is unaware of it. That is my
    18 point.
    19 THE WITNESS: And I have answered the
    20 questions that I understood were, have I
    21 physically seen and read a report.
    22 Q. (By Mr. Hoffman) Right. So I am
    23 now going to ask you one additional question,
    24 which may be a bit of a repetition, but I hope
    25 it will clarify it. And you may have already
    1 answered it.
    2 In light of the fact that you have
    3 admitted that you have not physically seen the
    4 handwriting reports themselves, but may be relying
    5 on summaries from the people around you, why are
    6 you so certain that Mrs. Ramsey is not the ransom
    7 note writer?
    8 A. Because I know my wife. I know how
    9 much she loved JonBenet. I know how much she
    10 valued life. She valued every day that she
    11 lived, and lived every day to its fullest as if
    12 it were a gift from God.
    13 Q. Are you aware that there are
    14 handwriting experts which are experts on behalf of
    15 Chris Wolf that have rendered opinions --
    16 MR. HOFFMAN: Do you want to stop
    17 there?
    18 MR. WOOD: I just want to make sure
    19 he knows that I want to make an objection.
    20 MR. HOFFMAN: Okay. Okay.
    21 MR. WOOD: Why don't you start again.
    22 MR. HOFFMAN: All right. Just
    23 simply, I just want to know what he knows or
    24 doesn't know. I am not asking him to do
    25 anything other than yes or no to this.
    1 Q. (By Mr. Hoffman) Are you aware that
    2 there are handwriting experts that are working on
    3 behalf of Chris Wolf who have concluded that
    4 Patsy Ramsey is, as one of them said, without
    5 doubt the ransom note writer?
    6 MR. WOOD: I am going to object to
    7 that question and -- on several bases.
    8 Number one, there has been no finding
    9 of qualification of any individual submitted to
    10 date by the plaintiff as a handwriting,
    11 quote/unquote, expert, number one.
    12 To the contrary, at least three or
    13 four of the individuals that are presently being
    14 relied upon, at least we believe, by the
    15 plaintiff, have been specifically rejected as
    16 legitimate handwriting experts by the Boulder
    17 District Attorney's office and the Boulder Police
    18 Department.
    19 Third, you are representing,
    20 Mr. Hoffman, that one of these individuals is
    21 making a statement without doubt Patsy Ramsey
    22 wrote the ransom note, and I think that that is
    23 an unfair statement on your part because we have,
    24 as counsel for the defendants, been seeking for
    25 several months, at least the last two months, to
    1 obtain Rule 26 reports from these individuals that
    2 you represent to be experts, so that we,
    3 according to law, could then depose them, test
    4 their qualifications, test their opinions, against
    5 cross-examination, including cross-examination of
    6 standard and fundamental handwriting practices and
    7 procedures.
    8 So far, for whatever reason, we have
    9 not been afforded those reports, we have not been
    10 afforded the opportunity to examine those experts
    11 to determine what, if any, opinion they may hold
    12 and what, if any, credibility that opinion is
    13 worth receiving.
    14 And I think it is fundamentally unfair
    15 to ask Mr. Ramsey a question that presupposes at
    16 least one of those expert's opinions and ask him
    17 if he is aware of it.
    18 MR. HOFFMAN: Just all I want to
    19 know is if he is aware.
    20 MR. WOOD: The point is, I think it
    21 is fundamentally unfair to ask him to do that.
    22 Beyond that point, I think it is
    23 clearly a question that does not raise a
    24 reasonable chance of discovering admissible
    25 evidence because Mr. Ramsey's knowledge of that
    1 does not go to any issue of admissibility;
    2 whether he knows about something that one of your
    3 alleged experts says, I don't see how that is
    4 relevant in terms of reasonably calculated to lead
    5 to the discovery of admissible evidence.
    6 But as long as you will stipulate for
    7 me that we have not received the Rule 26 reports
    8 and have not yet had the opportunity to
    9 cross-examine those experts, and then, obviously,
    10 we have not reached the questions about Dalbert
    11 and other cases --
    12 MR. HOFFMAN: Absolutely.
    13 MR. WOOD: -- about whether the court
    14 would allow those individuals to testify.
    15 MR. HOFFMAN: Absolutely.
    16 MR. WOOD: If you will stipulate that
    17 I am accurate in those representations, then I am
    18 going to let him answer the question. Is that
    19 fair?
    20 MR. HOFFMAN: There is only one
    21 representation that I won't stipulate to, and that
    22 is two of the handwriting experts, Larry Ziegler
    23 and Gideon Epstein, for which you have, at least,
    24 there preliminary reports, one of which has that
    25 statement, "without doubt Patsy Ramsey is the
    1 ransom note writer." That you have those
    2 statements, that they were given to you, and that
    3 those two experts are not only highly qualified,
    4 but have been admitted, one of which was admitted
    5 by Judge Carnes in a case that she sat on
    6 several years ago.
    7 So to the degree that your
    8 representation is that the handwriting experts
    9 are, in fact, not experts, I would take -- I
    10 would disagree with at least that characterization
    11 with respect to Mr. Gideon Epstein and Larry
    12 Ziegler.
    13 And that is the only thing I want to
    14 correct within it, but I will stipulate to
    15 everything else that you have said with respect
    16 -- that you haven't received the federal Rule 26
    17 reports, or anything else. That is absolutely
    18 correct.
    19 MR. WOOD: Well, I have not and I
    20 will not, and I don't believe that I am allowed
    21 to characterize an individual as an expert. I
    22 think that is a decision that would ultimately be
    23 determined by Judge Carnes in this case. And
    24 whatever may have happened to Mr. Ziegler in
    25 another case has no bearing whatsoever on what
    1 his position will be in this case.
    2 MR. HOFFMAN: All right.
    3 MR. WOOD: But I don't want this
    4 record to be kind of one-sided, Darnay, on this
    5 issue of Gideon Epstein and Larry Ziegler because
    6 you have asked me about what is in their
    7 affidavits. I don't have those in front of me.
    8 MR. HOFFMAN: They are not affidavits.
    9 They are letters.
    10 MR. WOOD: Well, that is what I --
    11 it is my recollection there was a letter to you
    12 from each of these individuals.
    13 MR. HOFFMAN: Right.
    14 MR. WOOD: I can't recall sitting
    15 here today, because my brain cells are failing me
    16 as I age also, exactly what those letters said.
    17 But I do know this -- and I want
    18 this to be clear on the record. I know that
    19 you submitted affidavits from these two
    20 individuals, Epstein and Ziegler.
    21 MR. HOFFMAN: I never --
    22 MR. WOOD: I am sorry. Submitted
    23 letters --
    24 MR. HOFFMAN: Yes.
    25 MR. WOOD: -- as part of a
    1 supplemental response to mandatory disclosures.
    2 MR. HOFFMAN: Right.
    3 MR. WOOD: And I know for a fact
    4 that those letters to you, submitted by you,
    5 indicated that there were some similarities
    6 between Patsy's handwriting and the note, copy of
    7 the note they looked at. And they stated
    8 unequivocally that they believed that they could
    9 reach a conclusion if they were allowed to see
    10 other handwriting examples from Mrs. Ramsey from
    11 that time period.
    12 Am I right so far?
    13 MR. HOFFMAN: Yes.
    14 MR. WOOD: And I do know that I have
    15 a number of public statements made by you, both
    16 on the internet and on television, wherein you
    17 made almost the identical representations that
    18 Mr. Ziegler and Mr. Epstein would, in fact,
    19 testify conclusively that Patsy Ramsey wrote the
    20 note.
    21 And I know as a matter of undisputed
    22 fact that you made those representations about the
    23 conclusions of Ziegler and Epstein at a time when
    24 Ziegler and Epstein had not been given any
    25 additional handwriting exemplars which they had
    1 earlier stated they had to have in order to reach
    2 the conclusions that you attributed do them.
    3 Those, I believe, are clearly
    4 undisputed facts that can be shown. And those
    5 facts alone, before I even get to an expert's
    6 report or the ability to cross-examine that
    7 expert, say to me that Mr. Ziegler and
    8 Mr. Epstein, if you have accurately stated their
    9 conclusions publicly at the time you did state
    10 them, have some very, very serious credibility
    11 problems.
    12 That is my response to Ziegler and
    13 Epstein for the record.
    14 MR. HOFFMAN: I, just for the record,
    15 I think that that was sort of an unnecessarily
    16 long response; but irrespective of that, I would
    17 just simply like to state that the more recent
    18 statements by Mr. Ziegler and Mr. Gideon Epstein
    19 reflect the fact that they were able to actually
    20 look at the police exemplars that were given by
    21 Mr. Ramsey and Mrs. Ramsey and which were
    22 provided by you subject to a discovery request,
    23 and that those most recent observations are based
    24 on that.
    25 And to that degree, those observations
    1 are more complete.
    2 MR. WOOD: Well, let's leave it here.
    3 MR. HOFFMAN: I will withdraw this
    4 question if it is a problem.
    5 MR. WOOD: No, I am going to let him
    6 answer whether he is aware of that.
    7 MR. HOFFMAN: I just want to --
    8 MR. WOOD: He probably is now after
    9 listening to us.
    10 The point is, simply this: We look
    11 forward to receiving the reports, and we look
    12 extremely forward to the opportunity to
    13 cross-examine Mr. Ziegler, Mr. Epstein, and any
    14 other individual who is identified by you as a
    15 potential expert.
    16 MR. HOFFMAN: All right.
    17 Q. (By Mr. Hoffman) So, Mr. Ramsey,
    18 could you answer?
    19 MR. HOFFMAN: But maybe I am going
    20 to need a read-back from the question.
    21 Q. (By Mr. Hoffman) And, Mr. Ramsey, if
    22 you can answer it, please do, to the best of
    23 your ability.
    24 (The record was read by the reporter,
    25 as follows:
    1 "Question: Are you aware that there
    2 are handwriting experts that are working on behalf
    3 of Chris Wolf who have concluded that Patsy
    4 Ramsey is, as one of them said, without doubt the
    5 ransom note writer?")
    6 Q. (By Mr. Hoffman) That is a yes or
    7 no.
    8 MR. WOOD: Or answer any way you
    9 feel appropriate.
    10 THE WITNESS: I wouldn't be qualified
    11 to say that they are handwriting experts,
    12 particularly if they reach that conclusion.
    13 Q. (By Mr. Hoffman) All right.
    14 A. They are wrong. And they made
    15 probably a serious career limiting decision if
    16 that, in fact, is their statement, because that
    17 is something that neither the CBI, the FBI, the
    18 Secret Service, nor the top experts in this
    19 country have ever said. In fact, quite the
    20 contrary.
    21 Q. How do you know that, Mr. Ramsey,
    22 that they --
    23 A. I have heard statements from the
    24 police, I have heard statements from the district
    25 attorney, I have heard the results of what we
    1 consider and most people would consider the top
    2 handwriting experts and linguistic experts in the
    3 country, all of which have said, highly improbable
    4 that Patsy wrote the note.
    5 Q. Yet you have never actually seen any
    6 of these reports?
    7 A. I have never read any of the reports.
    8 They have never physically been given to me.
    9 Q. That is all I want to know.
    10 In light of that, I think, then, we
    11 are just going to move on, and I am going to
    12 ask you to look at a document that I am going
    13 to have marked as Plaintiff's Exhibit 17.
    14 MR. HOFFMAN: Okay. Would you please
    15 do that?
    16 THE WITNESS: And might I ask a
    17 question?
    18 Q. (By Mr. Hoffman) Would you like
    19 to --
    20 A. No. I would like to ask you a
    21 question. Was this used by your experts?
    22 Q. That was one of the exhibits that was
    23 attached to an early handwriting report, and one
    24 of the reasons that we are, in fact, here asking,
    25 we have made an initial request in what is known
    1 as a notice to -- a request for admission, and
    2 there seemed to be some question as to whether or
    3 not what I had attached as an exhibit was
    4 sufficiently clear for there to be, you know, an
    5 accurate representation of yes or no.
    6 So I thought it would be easier if I
    7 just brought in clearer copies and just asked you
    8 and Mrs. Ramsey to determine whether or not these
    9 are, in fact, samples of her handwriting.
    10 Clearly, nobody wants to be drawing conclusions
    11 based on handwriting samples which are, in fact,
    12 not hers.
    13 It seems that Mrs. Ramsey doesn't
    14 remember this as being hers.
    15 A. She said she doesn't recognize it, nor
    16 do I.
    17 Q. (By Mr. Hoffman) Nor do you. Okay.
    18 That's all --
    19 MR. WOOD: And fairly, Darnay, let's
    20 be clear that we are talking about Plaintiff's
    21 Exhibit No. 2 and Plaintiff's Exhibit No. 1. And
    22 to the extent that it is also letters from those
    23 might be in Plaintiff's Exhibits 11, and I think
    24 also 10, as well as Plaintiff's Exhibit No. 9,
    25 the record should accurately reflect that each and
    1 every one of your experts, including Epstein and
    2 Ziegler, have, in fact, stated conclusions to some
    3 extent relying in part on each and every one of
    4 those exhibits except for Exhibits 10 and 11,
    5 which are Cina Wong, David Liebman's exhibit.
    6 So all of your experts have relied on
    7 that to form their statements made in their
    8 reports to date, including just the recent letters
    9 we received --
    10 MR. HOFFMAN: Right.
    11 MR. WOOD: -- that you sent us a few
    12 months ago from Epstein and Ziegler; they did
    13 rely on those documents, and they didn't even
    14 know that it wasn't Patsy's handwriting.
    15 MR. HOFFMAN: Well, that hasn't been
    16 established because the argument can always be
    17 that there is always a reason why Mr. and
    18 Mrs. Ramsey might have a motive to lie. I am
    19 not saying that they are, but the fact is, there
    20 might be a reason why it is convenient for them
    21 not to be able to recognize it.
    22 THE WITNESS: I think Patsy was very
    23 clear that she did identify handwriting that she
    24 recognized as hers.
    25 MR. HOFFMAN: And, quite frankly, she
    1 may very well have been telling the truth.
    2 THE WITNESS: Quite frankly, she was
    3 telling the truth, Mr. Hoffman.
    4 MR. WOOD: And what might be
    5 interesting is to know what efforts were made by
    6 any of your so-called experts to actually
    7 authenticate those documents as Patsy Ramsey's
    8 handwriting before they were willing to go out
    9 and publicly stake their reputations that she is
    10 the author of the note based on handwriting
    11 exemplars that they didn't even have the slightest
    12 clue were written by her.
    13 So those are --
    14 MR. HOFFMAN: Not necessarily they
    15 didn't have the slightest crew. Don't
    16 mischaracterize.
    17 MR. WOOD: Well, when you raise
    18 questions about whether my clients might have a
    19 motive to lie, I am going to respond by saying
    20 that I think these people that you claim to be
    21 experts might have a motive to lie, and that
    22 motive is to get publicity and other things. We
    23 won't clutter the record up today.
    24 But let me tell you something, my
    25 clients have clearly identified the documents that
    1 you attached as exhibits. When the writing was
    2 Patsy Ramseys, nobody ran from it. The problem
    3 is, your people are relying on documents that
    4 either are not Patsy's or documents that they
    5 never bothered clearly to find out whether they
    6 were Patsy's before they went out publicly and
    7 accused Patsy Ramsey of writing a note to support
    8 the accusation that Patsy Ramsey killed her
    9 daughter. That is pretty flimsy, in my opinion,
    10 and I think that your experts will have a lot to
    11 answer for when we are finally given their report
    12 and allowed to cross-examine them, Darnay.
    13 MR. HOFFMAN: Absolutely. I will say
    14 one thing in my defense and in their defense.
    15 MR. WOOD: What?
    16 MR. HOFFMAN: If, in fact, we were
    17 concerned that there was something bogus about
    18 their examination, I think the last thing we
    19 would want to do is establish at a deposition
    20 record by the testimony of both Mr. and
    21 Mrs. Ramsey that this is, in fact, not their
    22 handwriting. I think we can let that go by the
    23 board.
    24 MR. WOOD: Well, with all due
    25 respect, with all due respect, you should have
    1 had reasonable notice to be concerned about
    2 whether there was something bogus about the
    3 alleged reports of Cina Wong and David Liebman
    4 and Mr. Stacey -- or Lacey, I am sorry, and I
    5 think Tom Miller, when you were informed by
    6 Michael Kane of the Boulder District Attorney's
    7 office that those experts were not following
    8 recognized handwriting methodology, that they were
    9 not even attempting to discuss dissimilarities,
    10 but were only hinging their alleged conclusions on
    11 a few similarities which are common to almost all
    12 handwritings, and that there were serious
    13 questions in the Boulder District Attorney's minds
    14 also on their credibility because of their efforts
    15 to gain publicity for themselves regarding those
    16 reports.
    17 That information was provided to you,
    18 Mr. Hoffman, in writing from Michael Kane. And I
    19 don't think you are going to state that Michael
    20 Kane was necessarily trying to do John or Patsy
    21 Ramsey any favors in his role as a grand jury
    22 specialist for the Boulder D.A.
    23 But once he told you that and put
    24 that in writing, I believe that you should have
    25 been on clear notice that there were legitimate
    1 and serious concerns about the bogusness of these
    2 people's reports and conclusions, and those are
    3 the individuals, Mr. Hoffman, not Mr. Epstein and
    4 Mr. Ziegler, who are now Johnny-come-latelys to
    5 this lawsuit, those were the individuals who you
    6 relied upon when you filed this complaint for
    7 Chris Wolf and submitted your mandatory
    8 disclosures.
    9 So I think there are very serious
    10 questions about their legitimacy, not just those
    11 raised by me. I haven't had the time yet and
    12 opportunity to cross-examine them, which I say I
    13 look forward to. But they were carefully studied
    14 by the Boulder District Attorney's offices, and
    15 they were soundly and wholeheartedly rejected as
    16 credible experts on the issue of handwriting.
    17 You knew that before you used them to
    18 file this lawsuit, yet you filed it anyway, I
    19 would say without further inquiry into their
    20 legitimacy. That is a problem and an issue, and I
    21 think the record ought to reflect it, and I think
    22 I stated it accurately.
    23 MR. HOFFMAN: I have to -- now,
    24 naturally, since you made a record, I am going to
    25 have to respond to what may be either
    1 mischaracterizations or just simply things that
    2 you are not aware of.
    3 To begin with, the letter by Michael
    4 Kane did not indicate what about the methodology
    5 with the exception of dissimilarity was suspect.
    6 MR. WOOD: I can get the record, and
    7 we can put it into the record here. Why don't
    8 we do that.
    9 Let the letter speak for itself. I
    10 have got a copy of the letter.
    11 MR. HOFFMAN: Well, if you would like
    12 to take a break and do that, we can --
    13 MR. WOOD: We don't have to take a
    14 break, but I can have someone find that letter.
    15 MR. HOFFMAN: That letter, fine. We
    16 will put that into the record. That is the
    17 first thing, from what I remember, since you are
    18 speaking from memory, also.
    19 MR. WOOD: I have a pretty good
    20 memory on that one. It doesn't always fail me.
    21 MR. HOFFMAN: Second point is that,
    22 with respect to the similarities, we do not know
    23 who Mr. Kane had actually submitted those reports
    24 to and who he was relying upon for the questions
    25 about the legitimacy of the reports. He did not
    1 indicate in his letter who it was that he had
    2 consulted.
    3 But, more importantly, I will say one
    4 thing, that, with respect to disguised
    5 handwriting, finding dissimilarities is less useful
    6 since the person clearly is trying to create
    7 consciously dissimilarities in the handwriting.
    8 And to the degree that the handwriting is
    9 disguised, there is, to some degree, dissimilarity
    10 to be expected and to continually belabor the
    11 point that disguised handwriting has
    12 dissimilarities is really not useful in a
    13 discussion of dissimilarities with respect to
    14 being able to put, add, or eliminate people from
    15 handwriting.
    16 So I never thought that Mr. Kane's
    17 one methodological discussion was a particularly
    18 valid one.
    19 Now, with respect to the district
    20 attorney's office that experts would be seeking
    21 publicity, I know that at one time they certainly
    22 did consult with a Donald Foster, who I believe
    23 was thought to be seeking publicity at one point,
    24 but that did not prevent them from at least
    25 consulting with him at least at some time.
    1 I know that Barry Scheck, who is a
    2 former professor of mine and was brought in as a
    3 DNA expert, I won't say he is a publicity hound,
    4 but he certainly is not media-averse. They
    5 brought him in, and they relied upon him.
    6 Also, I know that periodically the
    7 district attorney's office would trot out an
    8 expert. I believe there was somebody from Canada
    9 who was not an expert, or whatever, so I don't
    10 think the district attorney was averse to using
    11 media-seeking experts. And I think Michael Kane's
    12 characterization of Cina Wong and David Liebman as
    13 media experts disqualifying them inherently because
    14 of that was, in fact, anything other than just
    15 simply hypocritical on his part.
    16 Now, as far as Mr. Kane is concerned,
    17 I don't think that, from the statements that I
    18 have heard from the Ramseys, that they
    19 particularly trust, A, his judgment, B, his
    20 motivation. I may be incorrect with respect to
    21 that. I, in turn, do not trust either his
    22 motivation or his competence.
    23 But I will point out that these
    24 handwriting reports were given to Alex Hunter's
    25 office. In the four years that they have had
    1 the reports or anything else, they not once made
    2 an attempt to contact either myself or any of my
    3 experts to talk even in a collect telephone call.
    4 There was never any acknowledgment of receiving
    5 it, and that is despite the fact that the
    6 district attorney's office, and I believe the
    7 police department, made public appeals to
    8 individuals to please come forward, that they
    9 would listen to any sort of reasonable clue, if
    10 it came over the internet, if it came from
    11 telephone calls, or whatever, and here were
    12 handwriting reports that I had solicited, some of
    13 which I actually had to use my own money to
    14 prepare, and they were completely ignored. They
    15 weren't even acknowledged by anybody in the
    16 district attorney's office, and yet they spent an
    17 inordinate amount of money trying to track down
    18 something that was known in the press as a Santa
    19 Bear, for instance. That sort of thing --
    20 Yes, Mr. Ramsey?
    21 THE WITNESS: Well, I have got a
    22 band concert to go to tonight. Could I get my
    23 questions asked, and then you guys could put
    24 stuff on the record?
    25 MR. HOFFMAN: The only reason I am
    1 responding, and I am very sorry, is that I have
    2 to respond to your counsel's colloquy here, and I
    3 have to make a record. I am very sorry for
    4 that.
    5 Mr. Wood, and I am sure will take
    6 this -- this is my first hearing that you have a
    7 band concert. I am very sorry. And I will try
    8 to make this -- I will try to make it --
    9 MR. WOOD: I think he is trying to
    10 say, maybe, let's don't go back and forth until
    11 7:00 or 8:00 tonight.
    12 THE WITNESS: Yeah.
    13 MR. HOFFMAN: You made a record with
    14 respect to and representation for a record with
    15 respect to my experts, and I am not going to
    16 allow my silence to act as some sort of admission
    17 that you, in fact, were correct.
    18 I categorically deny that my experts
    19 are unqualified, any of them, that any of them
    20 acted out of any malice. In fact, it was my
    21 experience that when Cina Wong, when I contacted
    22 her initially -- each expert was contacted to
    23 look at the report of another expert to see
    24 whether or not there was a problem in their
    25 methodology.
    1 And as a result of looking at the
    2 methodology, they reached the same conclusions. I
    3 did not ask them to reach a conclusion. I
    4 basically wanted to make sure that if, in fact,
    5 there was going to be a case made in civil court
    6 against Mr. and Mrs. Ramsey, that there was, in
    7 fact, a sufficient basis for it. I was doing my
    8 best to investigate the facts of the case before
    9 making the allegations.
    10 The only allegation that I ever really
    11 made is that, based on the handwriting reports by
    12 people that I trust to be experts, that their
    13 conclusion that Mrs. Ramsey is the ransom note
    14 writer was the basis not only for any allegations
    15 that I may have made personally in public with
    16 respect to Mrs. Ramsey, but also forms the basis
    17 by which I filed the -- not only the action
    18 against Alex Hunter in 1997, but also the action
    19 on behalf of Chris Wolf and Linda Hoffman-Pugh.
    20 So I have tried to do a due
    21 diligence and certainly avoid any problems with
    22 Rule 11. I am under a duty as an officer of
    23 the court to investigate the case and the facts.
    24 And the only reason, basically, we are here today
    25 is because I have yet to see handwriting reports
    1 from any source other than my own that, in fact,
    2 clear Mrs. Ramsey.
    3 I would love to see those reports.
    4 I don't know why I have never been offered a
    5 report. The question I have for Mr. Wood is, at
    6 the time that Mr. Wood was releasing your
    7 polygraph reports and had a very attentive
    8 national media, why did he not come forward with
    9 written handwriting reports that could clear Mrs.
    10 Ramsey? I think that that would have been a
    11 spectacular and an extremely important opportunity
    12 in order to clear your wife from any suspicion of
    13 being the ransom note writer.
    14 And, yet, there has never been,
    15 despite all the money that Mr. and Mrs. Ramsey
    16 have spent, any attempt to release a written
    17 report at any time to the media similar to the
    18 written report that was released in the polygraph,
    19 and I never have been able to understand it. It
    20 is like the dog that should have barked in the
    21 night that hasn't barked in the night. My
    22 question has always been, why haven't the Ramseys
    23 released a handwriting report to shut me up, to
    24 just simply stop all the noise about the fact
    25 that there are handwriting experts that believe
    1 that Mrs. Ramsey wrote the ransom note? Why
    2 haven't, Mr. Wood, your clients been willing to
    3 produce for public consumption a handwriting
    4 report that simply, adequately, and for all time
    5 clears Mrs. Ramsey?
    6 MR. WOOD: Darnay, out of respect for
    7 John, who does have a band concert, I am not
    8 going to engage in trying to go back through and
    9 respond to all of that colloquy.
    10 MR. HOFFMAN: Okay.
    11 MR. WOOD: Suffice it to say, because
    12 you have referenced two individuals, clearly,
    13 Barry Scheck has never sought publicity about the
    14 Ramsey case. He has never discussed it publicly.
    15 He has refused to do so. Don Foster was not
    16 rejected by the Boulder District Attorney's office
    17 because he sought publicity. Don Foster was
    18 rejected because he concluded, after being hired
    19 by Steve Thomas, that Patsy Ramsey was the author
    20 of the note, and they thereafter found out that
    21 he had, prior to being hired by the Boulder
    22 District Attorney's office, written a three-page
    23 letter to Patsy Ramsey stating unequivocally that
    24 he would stake his reputation on her innocence
    25 that she was not the author of the note.
    1 So they discovered that Don Foster
    2 was, as we say in the business, a liar for hire.
    3 There are a lot of liars for hire in our
    4 business. You and I can debate, after I have
    5 been presented with your experts' reports and the
    6 opportunity to depose them, whether they have any
    7 legitimacy or whether they too are liars for hire
    8 or for publicity. We will resolve that another
    9 day.
    10 Suffice it to say here that we are
    11 not going to react to your comments about
    12 handwriting experts until we get your experts,
    13 which we are entitled to get, and then I want
    14 you to know this: You will receive handwriting
    15 expert reports from the Ramseys. Okay? So the
    16 time for that will come. It hasn't been time
    17 yet, but that will happen at the appropriate
    18 time.
    19 But, first, we are entitled to get
    20 your reports and cross-examine your experts. Once
    21 we have done that, you will get your reports that
    22 you so desperately want. And then I am going to
    23 hold you to that; that once you get those
    24 reports, since you don't believe the four people
    25 that Alex Hunter described as top of the line
    1 that said out there in Boulder she didn't write
    2 it, since you don't believe them, I will hold you
    3 to your word.
    4 Once we give the reports to you, I
    5 am going to ask you to, quote/unquote, as you
    6 say, "shut up," your words, not mine, then
    7 dismiss your lawsuit. Okay? So let's go on and
    8 let Mr. Ramsey answer questions.
    9 Q. (By Mr. Hoffman) All right.
    10 Mr. Ramsey, what time do you need to be out of
    11 here. I am not going to hold it against you.
    12 Seriously, I would like to -- because I will do
    13 this according to that.
    14 THE WITNESS: What time is the band
    15 concert?
    16 MS. RAMSEY: 7:00.
    17 THE WITNESS: 7:00, okay.
    18 MS. RAMSEY: He is not in a band
    19 concert.
    20 THE WITNESS: No, my son is.
    21 MR. ALTMAN: I understand that.
    22 Q. (By Mr. Hoffman) Okay. What time
    23 would you like to be able to leave here to be
    24 able to conveniently get there?
    25 A. If we left at 5:00, we will be in
    1 good shape.
    2 Q. What time do we have now?
    3 MR. WOOD: It is 2:30. We have got
    4 plenty of time.
    5 MR. HOFFMAN: We are not going more
    6 than an hour, Mr. Ramsey, at all, and maybe even
    7 less than that.
    8 THE WITNESS: Okay.
    9 MR. HOFFMAN: Okay.
    10 MR. WOOD: But that's not an
    11 invitation for him and I to go for another two
    12 and a half hours and talking.
    13 MR. ALTMAN: Once again, if I could
    14 say something, if we can stick to what we have
    15 been here for, ask questions, answer questions, I
    16 think we will be fine.
    17 MR. WOOD: I think that is
    18 appropriate, but I think Darnay knows as well,
    19 that this deposition, as the Ramseys have done
    20 before, they don't claim confidentiality, they
    21 have nothing to hide, and I want the record to
    22 be clear that this idea that Mr. Hoffman is
    23 asking questions that seem to contain damaging
    24 statements of experts about Mrs. Ramsey, I think
    25 that invites the record to be very clear that
    1 there are serious questions about whether these
    2 individuals are, as I say in the industry, we
    3 call them liars for hire. And so I think that
    4 both sides of that issue have to be explored on
    5 the record when he makes their conclusions part
    6 of his question. That is all.
    7 MR. ALTMAN: I think the question
    8 was, is it, in fact -- do you have knowledge of
    9 it, not so much do you agree with it.
    10 MR. WOOD: That is the way of
    11 putting out what we believe to be potentially a
    12 very bogus conclusion accusing Patsy Ramsey of
    13 writing the note because he wants that to then be
    14 part of a public record that is either watched on
    15 television or read by someone.
    16 And when you put that kind of
    17 information out there, the record, in order to be
    18 accurate and complete, has got to contain
    19 information that I think clearly demonstrates that
    20 there are, at a minimum, serious credibility
    21 issues with these experts, if there is not
    22 already sufficient evidence in the record to show
    23 that they are, quote/unquote, liars for hire or
    24 bogus excerpts.
    25 I have offered to resolve at least
    1 part of this, and I will do so. If I have my
    2 office locate Mr. Kane's letter to Mr. Hoffman,
    3 we will attach it to the record. It will speak
    4 for itself. That is all.
    5 MR. HOFFMAN: Mr. Wood, I just want
    6 to say one other thing with respect to that.
    7 You may have noticed that I have not asked
    8 Mr. Ramsey for personal information or
    9 Mrs. Ramsey. I haven't asked for their address.
    10 I haven't asked for social security numbers. I
    11 haven't asked for anything that would in any way
    12 hinder your ability to have to hold this back to
    13 at least redact those elements of it, because I
    14 am not interested in creating a record that will
    15 keep you from being able to make this public if
    16 you choose to do so at any time that you choose
    17 to do so.
    18 I just simply want to go -- I have
    19 had an opportunity to see a lot of the tapes and
    20 transcripts of Mr. Ramsey and Mrs. Ramsey with
    21 the police interviews and whatever, and I am not
    22 interested in taking them over the same ground.
    23 I could have easily -- Mrs. Ramsey, I believe,
    24 made a statement to the media yesterday that she
    25 was surprised at how short the deposition was,
    1 that there didn't seem to be any "Where is the
    2 meat to the Whopper," but a lot of that was
    3 already provided to me by material from discovery.
    4 So consequently, I am not trying to
    5 create any kind of record. I am just trying to
    6 get answers to questions that I still have. I
    7 am required to do that.
    8 MR. WOOD: Let's move forward. You
    9 ask questions. They have answered every one that
    10 you have asked so far, and they will continue to
    11 do so.
    12 MR. HOFFMAN: Okay. All right.
    13 Q. (By Mr. Hoffman) Mr. Ramsey, I am
    14 going to show you a document that I would like
    15 to have the court reporter mark as Plaintiff's
    16 Exhibit 17, marked for identification.
    17 (Plaintiff's Exhibit-17 was marked for
    18 identification.)
    19 MR. WOOD: Is there a part of this
    20 you want him to look at?
    21 MR. HOFFMAN: I want him to look at
    22 the headline, because, basically, I know this is
    23 a news story. I am going to ask him if he can
    24 -- if he has ever seen this news story before.
    25 THE WITNESS: No, I have not.
    1 Q. (By Mr. Hoffman) Are you familiar
    2 with Charlie Brennan --
    3 A. Yes.
    4 Q. -- as a news reporter?
    5 Do you have any opinion with respect
    6 to his ability as a journalist to accurately
    7 report the news? Any personal knowledge.
    8 A. I know of one instance in the
    9 beginning where he reported incorrect information.
    10 Q. I am going to ask you whether or not
    11 the headline in this story is substantially
    12 correct, knowing that these are not your words.
    13 Did you, in fact, have investigators
    14 tail possible suspects?
    15 A. I did not have investigators tail
    16 possible suspects.
    17 Q. Do you know if anyone working on your
    18 behalf had suspects tailed by investigators?
    19 A. I believe that our investigators
    20 observed the behavior of certain people the day
    21 that that ad appeared. I don't know for how
    22 long. I don't know what they did. But I am
    23 aware of that.
    24 Q. I would like to ask you, then, very
    25 simply, is this headline substantially correct or
    1 false as a statement of fact, in your opinion?
    2 A. Is it substantially --
    3 Q. -- correct as a statement of fact in
    4 your opinion, the headline?
    5 A. Well, the word I have difficulty with
    6 is "tail." I don't know that they tailed anyone.
    7 I think they observed outside their homes. So it
    8 is generally correct, to my knowledge.
    9 Q. Okay. I am going to now ask you to
    10 look at something I am going to have the court
    11 reporter mark as Plaintiff's Exhibit 18 for
    12 identification.
    13 (Plaintiff's Exhibit-18 was marked for
    14 identification.)
    15 Q. (By Mr. Hoffman) There are a series
    16 of documents here. I just would like you to
    17 look at them all at one time briefly, and I will
    18 ask you about each one.
    19 All right. With respect to the first
    20 document, I would like you to review the
    21 headline, and I am going to ask you whether or
    22 not that headline is substantially correct when it
    23 states that "Parents' book will name suspects,
    24 publisher says."
    25 A. I think it is substantially incorrect.
    1 Q. In what respect?
    2 A. Our book did not name suspects. It
    3 addressed people that were already being discussed
    4 in books, in the media, who had been on
    5 television and whom, had we not addressed, would
    6 have looked foolish.
    7 There are a number of people that we
    8 are interested in that we did not name in our
    9 book because they were not out in the public and
    10 known to the public.
    11 Q. Do you know if at this time -- the
    12 story is dated February 22. I believe it is --
    13 the year your book came out was 2000. It is
    14 copywritten 2000. Around this time, you were
    15 doing a media tour, what is commonly known as a
    16 media tour for the book?
    17 A. We agreed to do a few interviews,
    18 yes.
    19 Q. Interviews, right.
    20 Were you aware that your publisher was
    21 reported as having made these statements, that the
    22 Ramseys' book will name suspects? At the time.
    23 MR. WOOD: You may answer that.
    24 Reported, yes. But in fairness to
    25 Mr. Zettersten, I don't believe that that is what
    1 he said. If you look at the quote, that may be
    2 the headline that somebody decided to give it,
    3 but if you will look at the quotes, I don't
    4 think Ralph Zettersten said that before.
    5 In fact, he said very precisely, "It
    6 is people who have been mentioned before,
    7 Zettersten said. There will be a couple of
    8 others, but not by name."
    9 THE WITNESS: And that is correct.
    10 MR. WOOD: That is his quote. So, I
    11 mean, we are not responsible for what some writer
    12 decided to put in a headline for whatever reason.
    13 But you would answer the question, if
    14 you were familiar with this article or other
    15 articles that have claimed that that is what
    16 Mr. Zettersten was doing.
    17 MR. HOFFMAN: Actually, I am going to
    18 withdraw my question, and I am going to ask a
    19 different question.
    20 Q. (By Mr. Hoffman) Were you aware at
    21 the time this article was published that there
    22 were stories with this sort of headline
    23 circulating, that the Ramseys were naming
    24 suspects?
    25 A. Was I aware -- I was aware post that
    1 being out there. I wasn't aware that that was
    2 going to be said or that --
    3 Q. But afterward.
    4 A. But that was interpreted as the
    5 matter.
    6 Q. Did you make any attempt to object to
    7 any of the media with respect to this
    8 characterization? Did you make any attempt to
    9 correct that impression?
    10 A. What we found in dealing with the
    11 media is that it is a massive brute. I don't
    12 know how I would begin to correct that kind of
    13 thing. The book was an attempt to correct as
    14 many of the myths that we knew about.
    15 Q. Mr. Ramsey, I quite agree with the
    16 characterization as the media as a massive brute.
    17 However, did you at any time ever say
    18 in public that one of your intentions in your
    19 litigation was to change the way in which the
    20 press reported the news in a case like yours.
    21 MR. WOOD: You can answer that. If
    22 you want to see the statement. Darnay, I think
    23 you are obligated --
    24 MR. HOFFMAN: No, I am just saying
    25 in terms of that effect --
    1 THE WITNESS: I will tell you what
    2 my feeling is, and I have said this a number of
    3 times, that we need a law in this country that
    4 prevents the police from talking to the media
    5 about evidence in an ongoing case.
    6 We have bypassed the constitutional
    7 provisions that have been put in place to protect
    8 people's rights when the police could disclose
    9 evidence to the media for entertainment.
    10 It is a law in England. If some of
    11 the things that the media had done in this
    12 country and that the police had done in Boulder
    13 had been done in England, they would be in jail.
    14 It is a simple law. I think we need that in
    15 our society.
    16 So, yes, I would love to see that
    17 kind of a change because I think our system is
    18 too quick to convict based on hearsay that is
    19 broadcast on the media. And that is unfair to
    20 any citizen.
    21 Q. (By Mr. Hoffman) I don't know if
    22 you are familiar with J. Edgar Hoover, who was
    23 the former head of the FBI, or whether or not
    24 you are aware that J. Edgar Hoover used to tell
    25 his agents that if you cannot solve a case, if
    1 you are having a hard time solving the case, give
    2 it to the press because people are more likely to
    3 come forward and talk to a reporter than they are
    4 to a law enforcement agent, and that that might
    5 be the reason why some law enforcement agents, in
    6 fact, have this policy of giving information to
    7 the media. I just wanted to know if you were
    8 aware of that.
    9 A. Well, I am talking --
    10 MR. WOOD: Do you have any source
    11 for that statement from J. Edgar Hoover? I mean,
    12 you know, Darnay --
    13 MR. HOFFMAN: I don't have it, but I
    14 can produce it. I am just looking for a
    15 response here.
    16 MR. WOOD: We could say J. Edgar
    17 Hoover could speak for himself, but, you know,
    18 you are putting in --
    19 MR. HOFFMAN: Or herself, whatever the
    20 case may be.
    21 MR. WOOD: Himself or herself.
    22 MR. HOFFMAN: He is not somebody that
    23 I would, like, quote as a libertarian or a
    24 humanitarian, or an ACLU, whatever.
    25 MR. WOOD: I will let Mr. Ramsey
    1 answer, but we are getting far afield, I am
    2 afraid. But go ahead.
    3 THE WITNESS: I can tell you from my
    4 opinion some of the best investigative work has
    5 been done by journalists in this case. But that
    6 is different than disclosing evidence or opinions
    7 on evidence to the media prior to a trial.
    8 Q. (By Mr. Hoffman) Now, you said --
    9 A. That is what I am talking about,
    10 evidence. I am not talking about the fact that
    11 someone was murdered or accosted or raped and it
    12 was in this location and this is the description
    13 of the person we are looking for.
    14 I am talking about -- you know, we
    15 know for a fact that there was a deliberate and
    16 thought-out effort on the behalf of the police at
    17 the direction of the FBI to publicly assassinate
    18 our character and discredit us and bring massive
    19 pressure on Patsy and I in hopes that one of us
    20 would confess or break and turn the other one in.
    21 That is bypassing all of the rights
    22 that have been established in our constitution to
    23 protect every citizen, and that is wrong.
    24 Q. Okay. That brings me to my next
    25 question, which is, would you just express briefly
    1 your opinions of tabloid magazines, such as Globe,
    2 The Enquirer, The Examiner, the Star?
    3 A. I have said before, and I still
    4 believe, they are a cancer in our society.
    5 Q. Which brings me to the next question
    6 which I asked Mrs. Ramsey yesterday, and I am
    7 going to ask you. Did you at any time agree to
    8 give an interview with The Enquirer, this cancer
    9 on society?
    10 A. Yes.
    11 Q. May I ask you why you agreed to do
    12 that?
    13 A. It was part of a settlement agreement
    14 on behalf of some suits that we had filed against
    15 these people. And I cannot disclose per the
    16 agreement any more than that. And we were
    17 willing to confront our most ridiculous accusers.
    18 Q. I just want to ask you to --
    19 MR. HOFFMAN: I am going to ask the
    20 court reporter to mark this as Plaintiff's Exhibit
    21 19. And I will show that to Mr. Ramsey.
    22 (Plaintiff's Exhibit-19 was marked for
    23 identification.)
    24 Q. (By Mr. Hoffman) Mr. Ramsey, I am
    25 going to ask you if the document I just have
    1 shown you, which is marked Plaintiff's Exhibit 19
    2 for identification, is substantially correct in
    3 its reporting with respect to its headline?
    4 A. No, it is not.
    5 Q. In what respects is it incorrect?
    6 A. We did not turn to the work of a
    7 psychic. A picture was forwarded to us that was
    8 done by a Dorothy Allison, who I believe is a
    9 psychic, by someone. I think she had done it on
    10 a television program. We forwarded it to our
    11 investigators as a matter of procedure. We did
    12 that with everything we got in the mail. And we
    13 got a lot of stuff.
    14 And I believe they chose to put it
    15 on their website to stir up activity. And they
    16 did receive a number of leads and calls based on
    17 that.
    18 Q. Were those leads and calls useful to
    19 your investigation?
    20 A. I don't know.
    21 Q. Now, I am going to show you --
    22 unfortunately, for some reason, I ran out without
    23 making a second copy, so I am going to ask the
    24 reporter to mark this as Plaintiff's Exhibit 20
    25 for identification, and then I will just show it
    1 to you after he has marked it.
    2 (Plaintiff's Exhibit-20 was marked for
    3 identification.)
    4 THE WITNESS: Okay.
    5 Q. (By Mr. Hoffman) Mr. Ramsey, I am
    6 going to ask you if you can identify what appears
    7 in that document.
    8 A. I can identify most of the pictures
    9 of JonBenet. Some of them -- or one of them is
    10 very fuzzy. I just assume that is the picture
    11 that was on the website.
    12 Q. Do you know if that is, in fact, a
    13 picture of your website that you are looking at?
    14 A. I don't know that for a fact, no. I
    15 have not seen this image.
    16 Q. Do you know if the image of the man
    17 at the lower part of it --
    18 A. Uh-huh (affirmative).
    19 Q. -- do you know if that image ever
    20 appeared on your website?
    21 A. This is the first I have seen it. I
    22 don't usually look at that website.
    23 Q. Do you know if the man in question
    24 in that photo was, in fact, a suspect, to your
    25 personal knowledge?
    1 A. I don't know.
    2 Q. Was that man meant to be Chris Wolf?
    3 A. Not to my knowledge.
    4 MR. WOOD: Just so the record is
    5 clear, that is the drawing of the psychic that
    6 you were earlier referring to.
    7 MR. HOFFMAN: Is it? I don't know.
    8 THE WITNESS: Oh, yeah.
    9 MR. HOFFMAN: I was asking Mr. Ramsey
    10 what he did or didn't know.
    11 MR. WOOD: Just so the record is not
    12 confused here, Mr. Ramsey indicated to you that
    13 the psychic's drawing was sent to the Ramseys,
    14 that it was reviewed by the Ramsey investigators,
    15 and that the investigators put it up on the
    16 website. And I think he said their website.
    17 This website was utilized by the Ramsey
    18 investigators.
    19 MR. HOFFMAN: I just asked Mr. Ramsey
    20 if he could identify it, if he had he ever seen
    21 those pictures, and whatever else. That is all I
    22 want to know.
    23 THE WITNESS: That is a different
    24 question than I was asked.
    25 Had I ever seen this drawing? Yes,
    1 I have.
    2 Q. (By Mr. Hoffman) You have. Oh, I
    3 see. Okay. Do you know in what context it was?
    4 A. It appears to be, from the best I
    5 can tell from the copy, the drawing that was sent
    6 to us that was made by Dorothy Allison.
    7 Q. Had you ever seen a picture of Chris
    8 Wolf?
    9 A. Yes.
    10 Q. In your opinion, does Chris Wolf look
    11 anything like the picture there?
    12 A. I wouldn't draw that conclusion, no.
    13 Q. Okay. Now, I have one last question.
    14 Just simply, it is a point that involves
    15 something I just wanted to be clear about. And
    16 I am going to let you read this. It is -- and
    17 the reason I am not reading it out loud is that
    18 it is part of the Boulder police interview, which
    19 has been marked confidential. I don't want to
    20 have something read into the record that would in
    21 any way mean we would suddenly have to mark this
    22 confidential, if for some reason we don't want to
    23 have today's deposition marked confidential.
    24 So for the purposes of this question,
    25 I am just going to ask you to read to yourself
    1 the highlighted portions.
    2 And in fact, I am not going to even
    3 attach this as an exhibit. I am just going to
    4 simply -- just as a recollection, to reflect,
    5 refreshed. If you would look at that, I am just
    6 going to ask you one question with respect to it.
    7 MR. HOFFMAN: And, Mr. Lin, it is at
    8 the very end; it regards the, I think, the butler
    9 door, whatever it is.
    10 MR. WOOD: Let me say this to you.
    11 MR. HOFFMAN: Yes.
    12 MR. WOOD: This is a couple of pages
    13 from, it looks like, Patsy Ramsey's April '97
    14 interview --
    15 MR. HOFFMAN: Yes, on the front, I
    16 put that on the cover.
    17 MR. WOOD: -- six-hour interview.
    18 I don't have any problems; you can
    19 read it, you can put it into the record.
    20 MR. HOFFMAN: I would just prefer --
    21 MR. WOOD: We don't have any -- I
    22 don't have any problems with that being made part
    23 of the record officially. Put it out there. We
    24 would like to see the whole police investigative
    25 file be made public so people would know the
    1 truth about this case.
    2 MR. HOFFMAN: I would prefer, since
    3 this has been stamped "confidential" --
    4 MR. WOOD: I am the one that stamped
    5 it confidential in other litigation several months
    6 ago, if not last year, for reasons different than
    7 the issue of confidentiality in this case. I am
    8 waiving any claim for confidentiality. Put that
    9 into the record. I have no problems with you
    10 doing so.
    11 MR. HOFFMAN: Well, I am not --
    12 MR. WOOD: You could put the whole
    13 April 1997 transcript of both of their interviews
    14 into the record. I have no problems with you
    15 doing so.
    16 MR. HOFFMAN: I am not going to do
    17 that.
    18 MR. WOOD: I have no problems with
    19 it.
    20 MR. HOFFMAN: All right. Thank you
    21 very much.
    22 MR. WOOD: Let the truth come out.
    23 MR. HOFFMAN: I agree with you.
    24 Q. (By Mr. Hoffman) This question
    25 involves the -- do you know where the butler
    1 kitchen was in your house?
    2 A. Well, yes. I know what we called
    3 the butler kitchen.
    4 Q. Butler kitchen. Do you remember
    5 opening the door to the butler kitchen at any
    6 time in the morning while you were looking
    7 through the house for JonBenet?
    8 A. No.
    9 Q. And so is it that you have no memory
    10 of it or that you just didn't do it?
    11 A. I did not open it.
    12 Q. So it wasn't opened by you?
    13 A. No.
    14 MR. HOFFMAN: Thank you very much.
    15 This is going to conclude my
    16 deposition testimony of Mr. Ramsey. And I want
    17 to thank Mr. Ramsey for being here. I want to
    18 thank Mrs. Ramsey, once again, for her deposition
    19 yesterday and for being here today, and thank
    20 counsel.
    21 MR. WOOD: All right. Just so the
    22 record is clear, we have a number of hours under
    23 the Federal Rules of Civil Procedure remaining in
    24 which you have the right to examine Mr. Ramsey
    25 and to ask him any question factually otherwise
    1 that is proper and relevant to the claims and
    2 defenses in the lawsuit. And do you acknowledge
    3 that there are a number of hours remaining?
    4 MR. HOFFMAN: Yes. Absolutely.
    5 MR. WOOD: He answered every question
    6 today?
    7 MR. HOFFMAN: Yes, he has.
    8 MR. ALTMAN: I think with the
    9 exception of what we had spoken about regarding
    10 the financial issues which we may take up later.
    11 MR. WOOD: We are not going to take
    12 that up on the record, as that is something that
    13 would require a court ruling.
    14 MR. HOFFMAN: Every question that was
    15 put to Mr. Ramsey that was a matter of record
    16 today, that we agreed on was a matter of record,
    17 was, in fact, answered by Mr. Ramsey.
    18 MR. WOOD: And as you indicated, you
    19 have reviewed his April '97, June 1998, and April
    20 2000 police interviews --
    21 MR. HOFFMAN: That is correct.
    22 MR. WOOD: -- and I think you will
    23 say, with respect to Mr. Ramsey, Mr. Hoffman, the
    24 same as you said with respect to Mrs. Ramsey
    25 yesterday, he answered every question for the
    1 police; didn't he?
    2 MR. HOFFMAN: That I can't make a
    3 subjective statement about simply because I don't
    4 know what it was the police were trying to elicit
    5 in the way of answers, so I can't say that.
    6 MR. WOOD: You can't say that he
    7 gave him the answers they wanted?
    8 MR. HOFFMAN: No, I just don't know.
    9 It's really probably improper for me to
    10 characterize their testimony. I mean -- and I
    11 don't think anybody will want a testimonial from
    12 me, from the Ramsey family anyway.
    13 MR. WOOD: Yeah, but the point is --
    14 MR. HOFFMAN: But I did receive
    15 those.
    16 MR. WOOD: -- you have that massive
    17 what amounts to about 70 hours of their
    18 interviews with police; they voluntarily gave
    19 them. My question is, all of that material
    20 having been forwarded to you earlier by the
    21 Ramseys, along with a number of other documents,
    22 are you sure you have no other questions of
    23 Mr. Ramsey, because if you do, I want you to ask
    24 them today.
    25 MR. HOFFMAN: No. I understand. In
    1 fact, one of the reasons why -- and I want to
    2 characterize this properly.
    3 One of the reasons why these
    4 depositions are shorter than they might have been
    5 is because I am not asking either Mr. or
    6 Mrs. Ramsey to go over testimony that they have
    7 already given by the police.
    8 The police certainly have spent a
    9 great deal of time with the Ramseys, and, quite
    10 frankly, even though there may be areas that I
    11 might have personal curiosity about, I feel it
    12 would be inappropriate for me to ask them, and so
    13 that is why these depositions aren't going the
    14 full day.
    15 It is not because I feel that the
    16 Ramseys don't have anything to offer. It is just
    17 simply that I think that they offered a great
    18 deal of information when they were, in fact,
    19 interviewed, and I just chose not to cover most
    20 of it. And that is all.
    21 MR. WOOD: But you acknowledge that
    22 any question you have, curiosity or otherwise,
    23 that you believe to be relevant and properly
    24 framed in this case, you have the opportunity to
    25 ask them now.
    1 MR. HOFFMAN: There -- I have had
    2 the opportunity to ask Mr. Ramsey questions today.
    3 And with the stipulated exception that we have,
    4 which does not affect my answer here, I felt that
    5 Mr. Ramsey made the best effort that he could to
    6 answer those questions fully.
    7 MR. WOOD: Let me briefly cover a
    8 couple of matters with you, Mr. Ramsey, by way of
    9 direct or reflect discovery.
    11 BY-MR.WOOD:
    12 Q. Let me hand you what has been marked
    13 for purposes of identification as Plaintiff's
    14 Exhibit 16 to this deposition, and I think it has
    15 been represented to you and acknowledged by you,
    16 it appears to be -- we don't know how much
    17 generations away from the original, but a copy of
    18 the ransom note found in your home on December
    19 26, 1996. You have looked at that earlier today?
    20 A. Uh-huh (affirmative).
    21 Q. At the time earlier in your testimony
    22 with Mr. Hoffman, I think you made reference to
    23 one of the peculiarities of the ransom note being
    24 that you were first discussed or addressed
    25 formally and then later in the note informally.
    1 Do you remember --
    2 A. Yes.
    3 Q. -- telling Mr. Hoffman about that?
    4 And I think you made the reference
    5 that you were addressed "Mr. and Mrs. Ramsey."
    6 Do you recall telling him that?
    7 A. Yes.
    8 Q. Did you have the ransom note in front
    9 of you at the time you were giving that
    10 information to Mr. Hoffman?
    11 A. No. I had forgotten that it was
    12 only addressed to me. But what it was what --
    13 what I noticed was that it was a formal address,
    14 and yet they fell into a familiar form later on.
    15 MR. WOOD: That is all I wanted to
    16 clarify.
    17 MR. HOFFMAN: Yes.
    18 MR. WOOD: And now let me mark this
    19 as Defendant's Exhibit No. 1.
    20 (Defendant's Exhibit-1 was marked for
    21 identification.)
    22 MR. WOOD: Do you want to take a
    23 look at this real quick?
    24 MR. HOFFMAN: Yes, please. Thank you
    25 very much.
    1 May I make one observation about this
    2 before you read it into the record?
    3 MR. WOOD: Sure.
    4 MR. HOFFMAN: I would like the record
    5 to reflect that I made this document available on
    6 the internet at the time that Cina Wong, and
    7 there is a document which seems to be almost
    8 identical, that David Liebman received this. I
    9 would just like the record to reflect I made no
    10 attempt to keep this hidden from the public.
    11 MR. WOOD: And there has been no
    12 representation that you did make any such attempt.
    13 MR. HOFFMAN: I am sorry? No. I
    14 want the record to reflect that --
    15 MR. WOOD: But I appreciate the
    16 stipulation.
    17 MR. HOFFMAN: -- that I made that
    18 available through the internet.
    19 MR. WOOD: The stipulation was that
    20 you recognize the document, and it is actually
    21 the very material that you placed on the
    22 internet.
    23 MR. HOFFMAN: That is correct.
    24 MR. WOOD: And it was, in fact, and
    25 is, in fact, a true and correct statement of the
    1 letter that was sent to Cina Wong by Michael Kane
    2 on behalf of Alex Hunter, the --
    3 MR. HOFFMAN: Correct.
    4 MR. WOOD: -- the Boulder district
    5 attorney.
    6 MR. HOFFMAN: Uh-huh (affirmative).
    7 MR. WOOD: January 20, 1999.
    8 MR. HOFFMAN: Yes.
    9 MR. WOOD: And also a true and
    10 correct verbatim statement of the letter sent by
    11 Mr. Kane on that date, January 20, 1999, to
    12 Mr. David Liebman; am I right?
    13 MR. HOFFMAN: That is correct.
    14 MR. WOOD: All right. So that the
    15 record is clear, in those letters which predate
    16 the filing of this lawsuit, Mr. Kane stated to
    17 Ms. Wong and Mr. Liebman in identical language
    18 that he was informing them that their request to
    19 testify before the Boulder County grand jury in
    20 the JonBenet Ramsey murder investigation was
    21 denied, and the statement was, "We have determined
    22 that your proposed testimony would not serve the
    23 interest of justice, which is the controlling
    24 standard by which to judge your request."
    25 And I continue to quote: "The
    1 primary reason that we have reached this decision
    2 is that we believe that the methodology which you
    3 have used in reaching your conclusions does not
    4 meet the standards employed by the vast majority
    5 of forensic questioned document examiners in this
    6 country."
    7 I continue to quote: "Most
    8 significant is your complete failure to account
    9 for or even reference any unexplained
    10 dissimilarities between the questioned and known
    11 samples. You are willing to conclude with 100
    12 percent certainty that a writing was authored by
    13 a particular person based on some threshold level
    14 of similarities without any mention that there may
    15 be 10, 100, or 10,000 unexplainable
    16 dissimilarities between the known and unknown
    17 writings. I know of no reputable forensic
    18 document examiner who will not agree that
    19 unexplainable dissimilarities between a person's
    20 natural writing and questioned handwriting will
    21 preclude a positive identification.
    22 "In fact, where the degree of
    23 unexplained dissimilarity is high, it may result
    24 in an elimination, in spite of the existence of a
    25 number of points of similarity."
    1 And then I go down to state: "In
    2 addition to your technical deficiencies," I quote,
    3 "there are other reasons for our decision. I
    4 would note that you have engaged in a campaign of
    5 promoting your opinion in a manner that would
    6 surely open your credibility to doubt on
    7 cross-examination in a judicial proceeding.
    8 "As an experienced trial attorney, I
    9 believe that an expert witness who has attempted
    10 to insinuate herself," or himself, "into a
    11 particular criminal investigation through a public
    12 media campaign would appear less than objective
    13 and professional to a jury."
    14 Now, I make that statement because I
    15 misspoke earlier when I made a statement about a
    16 letter sent by Michael Kane to you. In fact,
    17 the letters were sent by Michael Kane directly to
    18 Cina Wong and to David Liebman in January of
    19 1999.
    20 You received copies of those letters
    21 before this lawsuit was filed. You published
    22 those letters on the internet, and I simply make
    23 this record because I now note there can be no
    24 dispute about what Michael Kane said about your
    25 alleged experts, and your knowledge.
    1 MR. HOFFMAN: About how they became
    2 available to the public.
    3 MR. WOOD: There is no -- I don't
    4 think there is any dispute about what Michael
    5 Kane has said about their methodology and their
    6 credibility. That is why this is important to be
    7 put into the record, since you have referred to
    8 them earlier today.
    9 And I do that not only to clarify
    10 the record but also to point out that this is
    11 another one of the reasons that we filed what is
    12 now correctly identified by me as the 15th
    13 defense, going on. I earlier said the 13th
    14 defense. That instead of bringing this legal
    15 action out of a concern for some real injury to
    16 reputation, Plaintiff Wolf and his counsel bring
    17 this lawsuit as a publicity stunt. They have
    18 thus joined legions of persons who have tried to
    19 make personal profit from the brutal murder of
    20 defendants' child. Neither plaintiff Wolf nor his
    21 counsel possesses any admissible evidence that any
    22 defendant murdered JonBenet Ramsey.
    23 That is verbatim the 15th defense.
    24 There was some question in the litigation raised
    25 earlier in the deposition about whether that had
    1 been made in the pleadings. It is a defense to
    2 this case asserted in the 15th defense in our
    3 answer.
    4 With those clarifications to the
    5 record, I have nothing further.
    6 MR. HOFFMAN: I would just only like
    7 to point out one thing with respect to Mr. Kane's
    8 objection. The operative word there is
    9 "unexplained dissimilarities." And the fact is
    10 that Mr. Liebman and Ms. Wong felt that these
    11 dissimilarities were explained by the fact that
    12 the person in question, in their opinion, was
    13 trying to disguise their handwriting.
    14 And in disguising your handwriting,
    15 occasionally, you are going to create
    16 dissimilarities which are not unexplained. They
    17 are dissimilarities, but they are not unexplained
    18 dissimilarities. And that is the point I would
    19 like to make with that. And thank you.
    20 MR. WOOD: I appreciate your
    21 statements about what they say. We look forward
    22 to that and the opportunity, as I am sure you
    23 would tell us to ourselves, cross-examine
    24 Mr. Wong, Mr. Liebman, Mr. Lacey, Mr. Miller, if
    25 he is going to be involved, as well as
    1 Mr. Epstein and Mr. Ziegler. We look forward to
    2 that day --
    3 MR. HOFFMAN: Thank you very much.
    4 MR. WOOD: -- when we can present
    5 them the questions and get the answers from them.
    6 Thank you.
    7 MR. HOFFMAN: All right. Thank you.
    8 Again, Mr. and Mrs. Ramsey, thank you
    9 for being here today.
    10 THE WITNESS: We have had our
    11 differences, but we are all children of God, and
    12 I respect you for that.
    13 MR. HOFFMAN: Thank you very much.
    14 THE VIDEOGRAPHER: We are off the
    15 video record at 3:03.
    16 (A recess ensued.)
    17 MR. WOOD: Just before we complete
    18 the record, I wanted to state that, on behalf of
    19 the Ramseys, and in this instance particularly
    20 John Ramsey, that we do not claim any
    21 confidentiality as to this deposition.
    22 The Ramseys agree that this deposition
    23 of John Ramsey, just like the deposition of Patsy
    24 Ramsey, can be presented publicly with no claim
    25 of confidentiality, unlike every other witness and
    1 party in the case to date.
    2 Every other witness, including Steve
    3 Thomas, including, in part, Mr. Wolf, and the
    4 other witnesses so far, Alex Hunter, Mark Beckner,
    5 Carey Weinheimer, have all claimed a measure of,
    6 if not entire, confidentiality.
    7 The Ramseys want the whole truth in
    8 this case out, and they are willing for the
    9 public to see their depositions in its entirety.
    10 So we make no claim to confidentiality.
    11 MR. HOFFMAN: And with respect to any
    12 claim of confidentiality that has been made in
    13 Chris Wolf's case, it has been a limited level of
    14 confidentiality; and we, of course, invite the
    15 Ramseys, to whatever extent they feel appropriate,
    16 to release any or all part of the unredacted
    17 portion of Mr. Wolf's deposition.
    18 MR. WOOD: I appreciate that.
    19 On behalf of the Ramseys, we would
    20 ask you to do the same thing they are doing,
    21 that is, let the entire truth come out about
    22 Chris Wolf and not prevent the public from
    23 knowing all aspects of his life, including those
    24 that you have chosen selectively to deem
    25 confidential.
    1 I would like for Mr. Wolf's deposition
    2 in its entirety to be made public, not just the
    3 selected portions. I think the truth -- that is
    4 why I haven't let it out, because I don't want
    5 -- I want the whole truth out, not just parts of
    6 it. Let it all come out.
    7 (Whereupon, the deposition was
    8 concluded.)
    9 .
    10 .
    11 .
    12 .
    13 .
    14 .
    15 .
    16 .
    17 .
    18 .
    19 .
    20 .
    21 .
    22 .
    23 .
    24 .
    25 .
    2 Plaintiff's
    3 Exhibit Description
    4 14 Printout from NBC website
    5 15 Article from Boulder News Ramsey Archive,
    6 "John Ramsey's Statement"
    7 16 Photocopy of ransom note
    8 17 Printout from Rocky Mountain News, "Ramsey
    9 investigators to tail possible suspects"
    10 18 Printout from Denver Post,"Parents' book
    11 will name suspects, publisher says"
    12 19 Printout from The Daily Camera, "Ramseys
    13 turn to work of deceased psychic"
    14 20 Printout from Ramsey Family website
    15 .
    16 Defendant's
    17 Exhibit Description
    18 1 Photocopy of letters from Mr. Hunter to
    19 Ms. Wong and Mr. Liebman
    20 .
    21 .
    22 .
    23 .
    24 .
    25 .
    3 I hereby certify that the foregoing
    4 transcript was reported, as stated in the
    5 caption, and the questions and answers
    6 thereto were reduced to typewriting under my
    7 direction; that the foregoing pages represent
    8 a true, complete, and correct transcript of
    9 the evidence given upon said hearing, and I
    10 further certify that I am not of kin or
    11 counsel to the parties in the case; am not
    12 in the employ of counsel for any of said
    13 parties; nor am I in anywise interested in
    14 the result of said case.
    15 .
    16 .
    17 .
    18 .
    19 .
    20 .
    21 .
    22 .
    23 .
    24 .
    25 .
    1 Disclosure Pursuant to Article
    2 8(B) of the Rules and Regulations of the
    3 Board of Court Reporting of the Judicial
    4 Council of Georgia, I make the following
    5 disclosure:
    6 I am a Georgia Certified Court
    7 Reporter, here as a representative of
    8 Alexander Gallo & Associates, Inc., to report
    9 the foregoing matter. Alexander Gallo &
    10 Associates, Inc., is not taking this
    11 deposition under any contract that is
    12 prohibited by O.C.G.A. 5-14-37 (a) and (b).
    13 Alexander Gallo & Associates,
    14 Inc., will be charging its usual and
    15 customary rates for this transcript.
    16 .
    17 .
    20 .
    21 .
    22 .
    23 .
    24 .
    25 .
    2 The Deposition of John Bennett
    3 Ramsey, taken in the matter, on the date,
    4 and at the time and place set out on the
    5 title page hereof.
    6 It was requested that the deposition
    7 be taken by the reporter and that same be
    8 reduced to typewritten form.
    9 It was agreed by and between counsel
    10 and the parties that the Deponent will read
    11 and sign the transcript of said deposition.
    12 .
    13 .
    14 .
    15 .
    16 .
    17 .
    18 .
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    2 STATE OF :
    4 Before me, this day, personally
    5 appeared, John Bennett Ramsey, who, being duly
    6 sworn, states that the foregoing transcript
    7 of his/her Deposition, taken in the matter,
    8 on the date, and at the time and place set
    9 out on the title page hereof, constitutes a
    10 true and accurate transcript of said
    11 deposition.
    13 John Bennett Ramsey
    14 .
    15 SUBSCRIBED and SWORN to before me this
    16 day of , 2001 in the
    17 jurisdiction aforesaid.
    19 My Commission Expires Notary Public
    20 .
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    25 .
    2 .
    3 RE: Alexander Gallo & Associates
    4 File No. 1637
    5 Case Caption: Robert Christian Wolf vs.
    6 John Bennett Ramsey, et al
    7 Deponent: John Bennett Ramsey
    8 Deposition Date: December 12, 2001
    9 .
    10 To the Reporter:
    11 I have read the entire transcript of my
    12 Deposition taken in the captioned matter or
    13 the same has been read to me. I request
    14 that the following changes be entered upon
    15 the record for the reasons indicated. I
    16 have signed my name to the Errata Sheet and
    17 the appropriate Certificate and authorize you
    18 to attach both to the original transcript.
    19 .
    20 Page No. Line No. Change to:
    22 Reason for change:
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    11 .
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    5 .
    6 .
    7 SIGNATURE:_______________________DATE:___________
    8 John Bennett Ramsey
    9 .
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