Patsy Ramsey & John Ramsey - BPD Interviews (Atlanta) - August 28, 2000

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  1. Tricia

    Tricia Administrator Staff Member


    Volume I
    August 28, 2000
    9 2140 The Equitable Building
    100 Peachtree Street
    10 Atlanta, Georgia
    14 Alexander J. Gallo, CCR-B-1332
    2 .
    3 On behalf of John and Patsy Ramsey:
    4 L. LIN WOOD, Esq.
    5 Law Offices of L. Lin Wood
    6 2140 The Equitable Building
    7 100 Peachtree Street
    8 Atlanta, Georgia 30303
    9 .
    10 On behalf of The United States:
    11 MICHAEL KANE, Esq.
    12 BRUCE LEVIN, Esq.
    18 .
    19 Also present:
    20 Ollie Gray
    21 John San Agustin
    22 .
    23 .
    24 .
    25 .
    2 August 28, 2000
    3 CHIEF BECKNER: Let me say we
    4 appreciate the opportunity to talk to you and
    5 ask you questions, and we appreciate your
    6 willingness to do this. Mr. Wood, I
    7 appreciate your cooperation as well.
    8 MR. WOOD: Thank you, Chief. I
    9 appreciate that.
    10 THE WITNESS: We appreciate you
    11 being here too.
    12 CHIEF BECKNER: I will just
    13 extend again, one of the reasons I made this
    14 trip is based on your request that I come.
    15 I normally don't do this. Normally I leave
    16 it up to my investigators and to the D.A.
    17 prosecutors, but I made this trip partially
    18 because of your request. So if, after this,
    19 after today or tomorrow, whenever we get
    20 done, you want to meet just to talk in
    21 general, I am willing to do that.
    22 MR. WOOD: Thank you.
    23 CHIEF BECKNER: I believe we had
    24 introductions. Do you need everybody to
    25 introduce themselves again to refresh
    1 yourself?
    2 MR. WOOD: I got it.
    3 CHIEF BECKNER: Primarily today,
    4 at least to start off, Bruce Levin and Mike
    5 Kane are going to be asking the questions.
    6 We may chime in at times if we have a
    7 follow up question or something, but
    8 primarily they will be asking most of the
    9 questions.
    10 MR. LEVIN: Mrs. Ramsey, we have
    11 a lot of questions today. A lot of the
    12 questions we will ask are simple
    13 informational questions. Some of the
    14 questions you may take as tough questions, if
    15 I can use that term, quote/unquote.
    16 Two years ago when you came out
    17 to Boulder and we interviewed you in
    18 Broomfield, I told Mr. Ramsey that if we
    19 ever were to charge an intruder, Mr. Wood
    20 will tell you this, every prosecutor in the
    21 room will tell you, that the best defense is
    22 if you can find an alternative suspect. And
    23 if an intruder were ever charged in this
    24 case, there is no doubt that their defense
    25 would be I didn't do it, that Mr. and Mrs.
    1 Ramsey did it.
    2 And in order to raise the
    3 reasonable doubt about their own guilt, they
    4 would harp on that through the entire trial.
    5 And, as a result, those types of questions
    6 that would be asked by defense attorney
    7 representing an intruder need to be answered,
    8 and we need to ask you those questions. We
    9 need to know what is the answer to those
    10 questions.
    11 Do you understand that? Do you
    12 appreciate that we ask the question, we need
    13 to have an absolutely honest answer, because
    14 if we don't, if we don't get a -- if we
    15 get a defensive answer, if we get an evasive
    16 answer, all we are doing is playing into a
    17 defense sometime down the road, some defense
    18 attorney is going to use that to say my guy
    19 didn't do it, John and Patsy Ramsey did it.
    20 Do you understand that?
    21 MR. WOOD: Let me say this for
    22 your benefit, Michael. I don't know that
    23 Patsy understands the intricate nature of a
    24 defense in a criminal case, but I can tell
    25 you this. We are here to answer any
    1 questions as represented by the chief and
    2 you. She is going answer those questions as
    3 honestly as she can. That is all she is
    4 here to do today. So why don't we go ahead
    5 and get going.
    6 MR. KANE: Well, I just want to
    7 make it clear, though, because it is not
    8 going to do anybody any good to give a
    9 defensive answer. Don't take --
    10 MR. WOOD: She is not going to
    11 be offended by any questions.
    12 MR. KANE: Okay. Fair enough.
    13 MR. WOOD: If she is, we will
    14 tell you. But I think we're going to do
    15 fine and she's going to give you answers.
    16 MR. KANE: But I would like Mrs.
    17 Ramsey to assure me that. Not --
    18 MR. WOOD: She is going to answer
    19 your questions honestly, Michael.
    20 MR. KANE: Mrs. Ramsey, do you
    21 understand everything I just said?
    22 THE WITNESS: I believe I do,
    23 yes.
    24 MR. KANE: Do you have any
    25 questions about that?
    1 THE WITNESS: Not at this time.
    2 MR. KANE: Okay. And if you do,
    3 just simply bring it up. Okay?
    4 THE WITNESS: Okay.
    5 MR. KANE: Mr. Levin is going to
    6 start off.
    7 Q. (By Mr. Levin) Mrs. Ramsey, what
    8 I would like to do, your attorney said
    9 uh-huh, uh-uh. Yes, no works. The other
    10 thing -- Do you understand that?
    11 A. Uh-huh (affirmative).
    12 Q. Let's do a practice.
    13 A. Yes.
    14 Q. We are going to play sort of like
    15 we are in court because we have a court
    16 reporter. I don't know if you have given
    17 interviews where they are transcribed. So
    18 that we don't drive this man insane, it is
    19 important that you wait until the question is
    20 finished, then you give your answer so that
    21 we don't talk over each other.
    22 We are all going to ask you
    23 questions, but we are going to try to do
    24 that so that he knows - it is very
    25 difficult to take somebody, two people at
    1 once. Do you understand that?
    2 A. Yes.
    3 Q. I have just some background stuff
    4 I would like to ask you, and I don't have
    5 any intention of embarrassing you, but I know
    6 from reading other interviews that in the
    7 past you have taken some medication. I just
    8 want to make a record on it. Are you
    9 taking any medication now?
    10 A. Yes, I am.
    11 Q. What do you take?
    12 A. Zoloft.
    13 Q. And what's Zoloft?
    14 A. Zoloft is for treatment of
    15 posttraumatic stress disorder.
    16 Q. Antidepressant type thing?
    17 A. Yes.
    18 Q. I am assuming, you look very
    19 bright eyed and very alert, that it doesn't
    20 affect your ability to comprehend what is
    21 going on around you?
    22 A. That's correct.
    23 Q. Okay. The other thing is, too, if
    24 we ask you a question, whether it is from me
    25 or Mr. Kane or Mr. Morrissey, and you are
    1 not clear what we are asking you, instead of
    2 trying to guess, just be very honest and
    3 say, I don't have a clue what you are
    4 saying, Mr. Levin, can you ask that in
    5 English, because lawyers have a tendency to
    6 talk like lawyers instead of people, and we
    7 will try to talk like people here.
    8 A. All right. Thank you.
    9 Q. Where I would like to start is we
    10 have heard that you and your husband have,
    11 in effect, funded or conducted kind of a
    12 parallel personal investigation into the death
    13 of your daughter. Is that correct?
    14 A. Yes, it is.
    15 Q. What I would like you to do is
    16 just kind of lay out, let's start with who
    17 you have been in touch with, who has been
    18 assisting you. Just list those people.
    19 A. Mr. Ollie Gray, who is here in
    20 the room, is working for us in the
    21 investigation.
    22 Q. Is there anyone else?
    23 A. John, his assistant, who I think
    24 you met earlier.
    25 Q. Okay. And how long have you been
    1 associated with Mr. Gray, or has he been
    2 employed by you?
    3 A. I don't remember exactly. Quite
    4 some time.
    5 Q. Can you give us an approximation?
    6 Are we talking months?
    7 A. Several months.
    8 Q. Months?
    9 A. Uh-huh (affirmative).
    10 Q. And before you started your
    11 association with Mr. Gray, were there other
    12 investigators that performed services for you?
    13 A. Yes.
    14 Q. And who were they?
    15 A. Ellis Armistead & Associates.
    16 Q. And your association with Mr.
    17 Armistead goes back to '97; is that correct?
    18 A. Yes.
    19 Q. And how long was he in your
    20 employ?
    21 A. Up until fairly recently.
    22 Q. By fairly recently, we are
    23 talking --
    24 A. Probably --
    25 Q. -- a couple of months when
    1 Mr. Gray became in your employment?
    2 A. Yes. Somewhere around that time.
    3 Q. Does that correspond to when you
    4 terminated your professional relationship with
    5 Hal Haddon's firm and Pat Burke and Pat
    6 Furman, or did Mr. Armistead work for you
    7 after you terminated your professional
    8 relationship with Mr. Haddon's law firm?
    9 A. I am really fuzzy on all that.
    10 I just -- John would probably know that
    11 answer more clearly. He kind of --
    12 Q. Why don't you give us your best
    13 recollection.
    14 A. What was the question again?
    15 Q. When did you terminate your
    16 relationship with the law firm of Hal Haddon,
    17 and then we'll do Pat Burke and Pat Furman?
    18 A. Well, it was after the grand jury
    19 was concluded.
    20 Q. Did Mr. Armistead still perform
    21 services for you after you terminated your
    22 professional relationship with those attorneys?
    23 A. I don't know exactly.
    24 Q. Okay.
    25 A. I don't know, you know, exactly
    1 which dates, when it happened.
    2 Q. Oh, I understand that. Let me
    3 give you something that is really pertinent,
    4 probably, to all the questions I am going to
    5 ask you. I understand that we are talking
    6 now about questions dealing with a period of
    7 time three and a half years, going on four
    8 shortly. I understand that you are not in
    9 every situation going to be able to tell me
    10 a day and sometimes not a month. And that
    11 is okay. Do you understand that? Remember,
    12 it is yes or no.
    13 A. Yes.
    14 Q. Okay. But what I would like you
    15 to do is, to the best of your recollection,
    16 when I am asking you questions like this, if
    17 you can give me spring of '99, fall of '96,
    18 that type of thing, and that is fine.
    19 MR. WOOD: If you know.
    20 Q. (By Mr. Levin) If you know.
    21 Obviously I don't want to put words in your
    22 mouth.
    23 A. I will try. I will try my best.
    24 MR. WOOD: Let me help a little
    25 bit because if you are looking for this
    1 information, I think I am correct in stating
    2 this, that Ellis Armistead was employed by
    3 Hal Haddon and Bryan Morgan, not technically
    4 employed by John and Patsy, but obviously
    5 employed by their lawyers.
    6 Mr. Gray's involvement predates
    7 the time when those lawyers withdrew, no
    8 longer representing John and Patsy. And Mr.
    9 Armistead's resignation from the case, I
    10 think, coincides in time with Mr. Morgan's
    11 and Mr. Haddon's termination.
    12 Q. (By Mr. Levin) So essentially
    13 contemporaneous with the end of the grand
    14 jury?
    15 MR. WOOD: Yeah -- well, no.
    16 Actually, the end, first part, somewhere
    17 between mid to end of May actually they
    18 continued to be involved.
    19 Q. (By Mr. Levin) Mrs. Ramsey, are
    20 there other professionals that you have
    21 contacted or that were contacted at your
    22 request? For example, forensic pathologists.
    23 A. I believe so. I believe that we
    24 had a group of experts who had put together
    25 some information which we were hopeful could
    1 be presented to the police department and
    2 investigators last January.
    3 Q. Who was in that group of experts?
    4 Who do you remember?
    5 A. I don't know all the names. I
    6 just know they were, you know, they were
    7 forensic type people.
    8 Q. Why don't you tell me the names
    9 you do recall? Do you remember a Dr. Sperry
    10 from Georgia, Kris Sperry? He is a forensic
    11 pathologist.
    12 A. I believe that was one of the
    13 names.
    14 Q. Did you ever personally meet with
    15 him?
    16 A. No.
    17 Q. Was there anyone else that you
    18 recall? And if you don't recall their
    19 names, can you tell us what area of
    20 expertise?
    21 A. There again, that is kind of John
    22 was sort of involved with that more than I.
    23 I really don't. That is about all I know.
    24 I just know that the meeting was declined.
    25 Q. The meeting?
    1 A. We had requested to meet and
    2 present this information.
    3 Q. And were you involved in that?
    4 Did you directly contact the Boulder Police
    5 Department or contact a member of the
    6 prosecution team?
    7 A. No, I did not personally. I
    8 believe one of our lawyers sent a letter to
    9 that effect saying we would like to meet and
    10 present some findings, and it was not
    11 accepted.
    12 Q. One of the things that we are
    13 very interested in is that, since you do
    14 have and have had investigators working for
    15 you on this case, and, as you refer to them
    16 as forensic experts or group of experts I
    17 believe is what you are calling them, what
    18 have they presented to you that you think is
    19 significant that would assist us in getting a
    20 prosecuteable case against the killers of
    21 your daughter?
    22 A. They haven't presented anything to
    23 me.
    24 Q. Have they presented things to
    25 John?
    1 A. I don't know.
    2 Q. If I understand you correctly, you
    3 are saying that these people have been, and
    4 I am assuming at a fairly large expense,
    5 been retained by your family and that, that
    6 you -- and obviously you have a great
    7 interest in having -- in helping solve the
    8 murder of your daughter; correct?
    9 A. Correct.
    10 Q. But if I understood your response,
    11 you are saying that you've never sat down to
    12 talk to these people to discuss their
    13 findings?
    14 MR. WOOD: She said they haven't
    15 presented anything to her in way of a
    16 presentation. I don't think she said she
    17 wasn't aware, generally, of their finding.
    18 MR. LEVIN: You are on realtime,
    19 I assume; is that correct?
    20 MR. WOOD: Yes, I am.
    21 MR. LEVIN: Do you know what we
    22 are talking about? Realtime is the term of
    23 art for, he is reading off the court
    24 reporter's transcript, rough draft, which we
    25 don't have.
    1 MR. WOOD: But which we will be
    2 glad to hook you up to if you would like
    3 it.
    4 (Discussion ensued off the
    5 record.)
    6 Q. (By Mr. Levin) What your
    7 attorney told me is that there hasn't been a
    8 formal presentation. Let's talk about
    9 informal. Have you sat down personally and
    10 talked to any of these people that were
    11 retained in order to find out what they have
    12 uncovered in this case?
    13 A. I have not, no.
    14 Q. Have you received secondhand
    15 information concerning what information they
    16 have concerning possible alternative suspects?
    17 And that is an alternative to you and John,
    18 obviously.
    19 A. I don't remember them saying
    20 anything about specific suspects.
    21 Q. You have in the past suggested,
    22 during interviews, possible suspects, people
    23 that you in your mind think may have been
    24 involved in the murder of your daughter;
    25 correct?
    1 A. Correct.
    2 Q. Why don't you list those for us.
    3 Who have you stated you believe at some
    4 point in time was involved with the murder
    5 of your daughter?
    6 MR. WOOD: Now, that -- you have
    7 those prior statements.
    8 MR. LEVIN: Yes, I do.
    9 MR. WOOD: Then I - excuse me.
    10 MR. LEVIN: Pardon me, sir.
    11 MR. WOOD: Then in all fairness,
    12 you are asking her to simply repeat what
    13 she's already told you, which is exactly what
    14 we said we weren't going to do here today.
    15 MR. LEVIN: That is correct. And
    16 the follow-up questions will make it clear
    17 why this is not repetitive.
    18 MR. WOOD: But the problem is,
    19 how in the world can she sit here and play
    20 a memorization game with you about who she
    21 may have discussed, when she discussed it.
    22 I mean, if you have got her
    23 statements, you know who she has named. And
    24 she can't sit here and be expected to
    25 remember each and every person because
    1 sometimes you would ask, you know, if anybody
    2 had a key and they would give you names.
    3 Is that a possible suspect? I don't know
    4 what the term necessarily means. But she
    5 has given you those names, Bruce. You
    6 have --
    7 MR. LEVIN: I understand that.
    8 MR. WOOD: Excuse me. If you
    9 are here to get additional information, that
    10 question is not necessary. You already have
    11 that information.
    12 MR. KANE: Let me follow up on
    13 that.
    14 MR. WOOD: Sure.
    15 MR. KANE: Obviously the last
    16 statements that we have are two years ago.
    17 So maybe if we ask.
    18 MR. WOOD: Ask if there is
    19 anybody that she knows by name since when
    20 she last talked with you all. That is
    21 absolutely fair. I would, you know, let her
    22 answer that, but to ask her who she's told
    23 you about in the past would almost require
    24 her to be familiar with every statement she
    25 has given you all over four days or so.
    1 And she hasn't prepared to do that today
    2 because we weren't going to go into those
    3 areas.
    4 MR. KANE: Well, but also, I
    5 think it is also relevant to ask what, what
    6 information has subsequently been developed
    7 about people that were named before. I
    8 mean, two years is a long time.
    9 MR. WOOD: Well, I mean, I would
    10 think then you all ought to go straight -- I
    11 am not telling you how to ask your
    12 questions, but I would think if you have a
    13 name and you want to know if she is aware
    14 of any information developed since June of
    15 1998, throw the name out there and ask her
    16 have you learned anything that you know about
    17 this person since June of '98. She will
    18 answer that.
    19 MR. LEVIN: That is fine.
    20 MR. WOOD: I am not trying to be
    21 difficult. I just don't want --
    22 MR. LEVIN: I understand. What
    23 I'll do --
    24 MR. WOOD: - to put her in the
    25 awkward position of trying to somehow
    1 remembering what she said over four days two,
    2 three years ago because I don't think she
    3 could do that. She certainly didn't prepare
    4 to do that today, and I wouldn't ask her to.
    5 MR. LEVIN: No, and I, I
    6 certainly, Mr. Wood, do not expect her to do
    7 that. That's not where I was going. But
    8 if it makes you more comfortable, I'll ask
    9 the question another way.
    10 MR. WOOD: Thank you very much.
    11 Q. (By Mr. Levin) You've named
    12 Priscilla White in the past as a possible
    13 suspect. During the course of the last two
    14 years, have you rejected that as a possible
    15 suspect in the murder of your daughter, have
    16 you rejected Priscilla White?
    17 A. No.
    18 Q. You've named Fleet White, I
    19 believe, as a suspect. Same question, have
    20 you rejected him as a possible suspect?
    21 A. No.
    22 Q. Bill McReynolds?
    23 A. No.
    24 Q. No, you have not rejected him?
    25 A. No, I have not rejected him.
    1 Q. And I believe Chris Wolf you
    2 also --
    3 A. No, he has not been rejected.
    4 Q. I assume then that that is a
    5 function of the fact that you have not
    6 received any significant information concerning
    7 the murder of your child in the last two
    8 years that differs from the information that
    9 you received prior to your interviews with
    10 representatives of the Boulder district
    11 attorney's office?
    12 MR. WOOD: Hold on before you
    13 answer.
    14 Do you understand that?
    15 THE WITNESS: Not really.
    16 Q. (By Mr. Levin) Okay. I'll
    17 rephrase it for you. In June of 1998, the
    18 individuals that I've named were, in your
    19 mind, potential suspects in the murder of
    20 your child; correct?
    21 A. Uh-huh (affirmative). Correct.
    22 Q. You tell us that today, in August
    23 of the year 2000, those individuals remain
    24 suspects. Correct?
    25 A. Correct.
    1 Q. I am assuming, based on that,
    2 that you have not received, through your
    3 investigators or through your experts, any
    4 significant new information about the killing
    5 which caused you to abandon those opinions or
    6 suspicions?
    7 MR. WOOD: Let me just caution
    8 you. Because he tells you it is something
    9 that he assumes, Patsy, I think what he
    10 really wants to know is, why have you not
    11 necessarily rejected these people in my own
    12 mind. Do you follow me? I think that is
    13 an easier question.
    14 Isn't that what you are driving
    15 at, Bruce?
    16 MR. LEVIN: Well, not, no, it is
    17 not.
    18 MR. WOOD: For example, Chris
    19 Wolf, why do you still think he is not in
    20 your mind rejected as a suspect, isn't that
    21 what you are trying to get her to answer?
    22 Q. (By Mr. Levin) What I want to
    23 know is, it would seem to me that if you
    24 had people who are working on this case for
    25 you to develop information concerning the
    1 killing, that if they had developed anything
    2 significant, that it might impact your belief
    3 that Priscilla or Fleet or McReynolds or Wolf
    4 was involved. Do you understand that so
    5 far?
    6 A. Yes.
    7 Q. Is it a fair statement that you
    8 have not received any significant information
    9 concerning the murder of JonBenet in two
    10 years?
    11 MR. WOOD: About?
    12 THE WITNESS: We have significant
    13 information about the murder.
    14 Q. (By Mr. Levin) Okay. Why don't
    15 you tell us what is the significant
    16 information that you have been provided in
    17 the past two years. And again, I am not
    18 going, you know, I'm not going to ask you
    19 months and days, when did you find this out,
    20 but I would like --
    21 MR. WOOD: Specific information as
    22 to specific people?
    23 Q. (By Mr. Levin) Specific
    24 information concerning the killing generally.
    25 And you can block it out any way you want.
    1 A. Well, I don't know a whole lot of
    2 detail. John will, perhaps, be much better
    3 to answer that.
    4 What I know is that we know --
    5 how do I want to say it, forensically,
    6 pathologically, or whatever, how JonBenet
    7 died.
    8 Q. Why don't you explain what your
    9 belief is concerning her death.
    10 MR. WOOD: See, hold on a second.
    11 You got one question she is trying to
    12 answer, and now you -- are you withdrawing
    13 that question?
    14 MR. LEVIN: No, I am following it
    15 up.
    16 MR. WOOD: Well, but you haven't
    17 let her finish the first answer, in fairness,
    18 and you are throwing another question out.
    19 THE WITNESS: I was going to tell
    20 you the rest of what I know.
    21 MR. WOOD: And if I go back and
    22 look at this record, it looks like she's
    23 completed her answer and then you've asked
    24 her a new question and you've stopped her in
    25 the middle. Do you want her to go back and
    1 tell you generally what she's learned --
    2 MR. LEVIN: Sure, you can list
    3 them.
    4 MR. WOOD: - for the last two
    5 years and then you can move to the second
    6 question?
    7 Q. (By Mr. Levin) Go ahead.
    8 A. Well, I believe that from this
    9 group of experts we know the sequence of the
    10 way in which she died. I am not sure -- I
    11 don't think I know. There may be other
    12 things that that group had to present, but
    13 that is the one thing that I can remember.
    14 Otherwise, I think Mr. Gray has
    15 turned over everything, any piece of anything
    16 that he thinks is significant to the police
    17 department, including just recently a pair of
    18 Hi-Tec boots that were obtained from one of
    19 the suspects. We don't know what has
    20 happened with that since, and we would like
    21 to know that.
    22 Q. Anything else?
    23 A. No.
    24 Q. Why don't you explain to us your
    25 understanding concerning the sequence of
    1 events which led to your -- and I am talking
    2 from a medical perspective, the sequence of
    3 events that led to your daughter's death as
    4 it was explained to you by your forensic
    5 experts.
    6 A. That she died of asphyxiation, and
    7 the blow to her head was subsequent to that
    8 act. And the reason that they know that is
    9 because something to do with the very minute
    10 presence or negligible presence of blood at
    11 the fracture.
    12 Q. Now, this belief that you have,
    13 Mrs. Ramsey, was that a product of a
    14 conversation that you had directly with Dr.
    15 Sperry?
    16 A. No.
    17 Q. What is the source of your
    18 information then?
    19 A. I believe my attorney Pat Burke
    20 explained that to me.
    21 Q. Dr. Sperry is the source of that
    22 information, though, through your lawyer; is
    23 that your understanding?
    24 MR. WOOD: If you know that.
    25 THE WITNESS: I don't know that
    1 for sure.
    2 Q. (By Mr. Levin) What is your
    3 belief?
    4 MR. WOOD: If you have a belief,
    5 Patsy.
    6 THE WITNESS: Well, he was among
    7 a group of experts. I mean, it was he and
    8 several others is my understanding who, you
    9 know, thoroughly looked at all of this. And
    10 that was the gist of, in my layman's terms,
    11 I am sure it is much more technical than
    12 that, but --
    13 MR. WOOD: And I think that,
    14 Bruce, that Sperry was one of the people
    15 that was offered to you all back in January
    16 of 2000. I was not involved in that offer,
    17 but I understood that they were willing to
    18 have --
    19 THE WITNESS: They had a complete
    20 presentation ready for all of you all.
    21 MR. WOOD: I think that offer
    22 still stands.
    23 Q. (By Mr. Levin) Are you aware of
    24 what information he was in possession of,
    25 that is, Dr. Sperry?
    1 A. No, I am not.
    2 MR. LEVIN: Are you, Mr. Wood?
    3 Do you know what he had?
    4 MR. WOOD: Well, I think I have
    5 a general idea. I haven't sat here and
    6 tried to come up with it in my mind's eye,
    7 but again, my understanding is, I will check
    8 this for you, but you all are welcome to
    9 sit down and listen to him and talk with
    10 him. He would be better able to tell you
    11 that than me.
    12 Q. (By Mr. Levin) Other than --
    13 well, let's talk about the Hi-Tec boots.
    14 You said you believe that a suspect had a
    15 pair of Hi-Tec boots that were sent to us.
    16 A. (Witness nodded head
    17 affirmatively).
    18 Q. Who was that?
    19 A. His name is Helgother or Gogather.
    20 Q. This is the man who committed
    21 suicide?
    22 A. Yes.
    23 Q. How is it that your team, for
    24 lack of a better word, how is it that your
    25 team came into possession of those? Do you
    1 know?
    2 A. No, I do not.
    3 Q. Have you been told or offered an
    4 explanation?
    5 A. Of how?
    6 Q. Of how you got into possession of
    7 a pair of boots that belonged to someone who
    8 committed suicide several years ago.
    9 A. I believe Mr. Gray obtained them.
    10 Q. I don't believe that I have ever
    11 heard you discuss him as a potential suspect
    12 in this case. Can you tell us what
    13 information you are in possession of that
    14 causes you to hold that belief?
    15 A. I understand that he committed
    16 suicide on the 14th day of February '97. He
    17 was in the possession of a stun gun, and we
    18 believe, as best we can tell, that it was an
    19 AirTaser stun gun, and that apparently
    20 matches the markings that were found on
    21 JonBenet's body. And he owned a pair of
    22 Hi-Tec boots that appeared to be the same
    23 size as the footprint found at the crime
    24 scene.
    25 Q. That information, I am assuming,
    1 comes from the work that was done by Mr.
    2 Gray? Is that the source of that? If I
    3 am incorrect, tell me what the source is.
    4 A. Yes, I think.
    5 MR. LEVIN: Mitch or Mike, do you
    6 want to do some more on their investigation?
    7 MR. KANE: Sure.
    8 Q. (By Mr. Kane) Let me just follow
    9 up the last question. What was the name of
    10 the suspect?
    11 A. It is an unusual name. It is
    12 Helgoth or Golgath.
    13 MR. WOOD: I think you all asked
    14 her about him in June of 1998 by name.
    15 Michael Helgoth.
    16 MR. LEVIN: For the Reporter, I
    17 believe it's H-e-l-g-o-t-h.
    18 THE WITNESS: Lin just said it is
    19 Michael Helgoth.
    20 Q. (By Mr. Kane) What else do you
    21 know about Mr. Helgoth?
    22 A. That is all, that is all I know.
    23 Q. Did you ever hear that name
    24 before?
    25 A. No.
    1 Q. It was not somebody who was known
    2 to your family?
    3 A. No.
    4 Q. Besides Mr. Gray, do you have any
    5 information, has anyone else given you any
    6 information about him?
    7 A. Not that I can think of, no.
    8 Q. Besides the fact -- where did
    9 you --
    10 Did Mr. Gray tell you that he had
    11 an AirTaser stun gun on him when he
    12 committed suicide?
    13 A. Yes. I believe there is a
    14 photograph that he had.
    15 Q. And was it Mr. Gray who told you
    16 that he had Hi-Tec boots? Was he wearing
    17 those? I am sorry, that is a double
    18 question. Was it Mr. Gray who told you that
    19 he had Hi-Tec boots?
    20 A. Yes.
    21 Q. And was he wearing them at the
    22 time? Is that your understanding?
    23 A. I don't know that.
    24 Q. Outside of the fact that he
    25 committed suicide, he had a pair of Hi-Tec
    1 boots, and an AirTaser, is there any other
    2 information you have that connects him to
    3 this crime?
    4 A. Not that I have, no.
    5 Q. (By Mr. Morrissey) Have you seen
    6 this photograph where Mr. Helgoth has the
    7 stun gun? Have you actually seen that
    8 photograph?
    9 A. No, I don't believe so.
    10 Q. (By Mr. Kane) Do you know how
    11 Mr. Gray came into possession of these boots?
    12 A. I don't know exactly, no.
    13 MR. WOOD: I think that was
    14 explained in a memo to Chief Beckner by Mr.
    15 Gray that he sent to him in the last couple
    16 of weeks.
    17 THE WITNESS: You all have the
    18 boots now.
    19 MR. KANE: That wasn't my
    20 question. I want to know what you know
    21 about those.
    22 Q. (By Mr. Kane) So you don't know
    23 how he came into possession of those boots?
    24 A. I think he said he might have
    25 gotten them from a family member, or --
    1 Q. When did you learn this?
    2 A. Some time ago. A couple of
    3 months ago.
    4 Q. And was that the first time you
    5 heard about Mr. Helgoth having Hi-Tec boots?
    6 A. Yes.
    7 Q. All right. And did you learn
    8 about that in a personal conversation with
    9 Mr. Gray or did you learn it indirectly
    10 through somebody else?
    11 A. I think I probably heard it from
    12 John.
    13 Q. Have you ever talked to Mr. Gray
    14 about those Hi-Tec boots?
    15 A. Yes.
    16 Q. You mentioned this group of
    17 forensic experts, and I think that -- maybe
    18 you have answered this question, but did you
    19 ever meet Mr. Sperry, or Dr. Sperry, the
    20 GBI, Dr. Kris Sperry?
    21 A. I think Mr. Levin asked me that a
    22 couple of times. No, I have not.
    23 Q. Okay. Have you met with any of
    24 the other forensic experts?
    25 A. No.
    1 Q. Have you ever asked any of these
    2 to give you a briefing of what they
    3 concluded?
    4 A. No.
    5 Q. Why not?
    6 A. Well, I was hoping to be in this
    7 meeting that we were going to have with you
    8 folks in January, but that never took place.
    9 Q. Now, I got a letter from an
    10 attorney in Oregon about that. I can't
    11 remember his name. Do you remember what his
    12 name was?
    13 MR. WOOD: Why don't you show us
    14 the letter. If we can see it --
    15 MR. KANE: No, I am asking if
    16 she remembers the letter.
    17 MR. WOOD: How would she know the
    18 name of somebody who wrote you a letter from
    19 Oregon?
    20 MR. KANE: Because it was an
    21 attorney hired by her and her husband.
    22 MR. WOOD: Who was the attorney?
    23 MR. KANE: Well, that's what I'm
    24 asking --
    25 MR. WOOD: I am not aware of an
    1 attorney hired in Oregon. I could be wrong.
    2 Q. (By Mr. Kane) Do you remember an
    3 attorney hired who lived in Oregon who was
    4 involved in setting up that meeting?
    5 A. Oh, yes. John -- John something.
    6 He is a colleague of Pat Burke's.
    7 Q. Okay. Have you ever talked to
    8 him yourself?
    9 A. Yes.
    10 Q. That attorney?
    11 A. Yes.
    12 Q. Okay. And it was your
    13 understanding that you were going to be part
    14 of that meeting between Dr. Sperry and the
    15 Boulder law enforcement authorities?
    16 A. I just presumed I would be. I
    17 was hoping to. I don't know that it
    18 actually came to the point where, you know,
    19 you are in, you are not, you know.
    20 Q. Dr. Sperry, is it your
    21 recollection that Dr. Sperry was the one who
    22 gave the opinion that, because of the lack
    23 of blood, that would indicate that the
    24 strangulation occurred before the blow to the
    25 head?
    1 A. I don't know who exactly gave
    2 what information. My understanding was there
    3 were several on this team of experts.
    4 Q. You don't know who any of the
    5 other people were?
    6 A. No. I am sorry.
    7 Q. You never spoke with any of the
    8 other people?
    9 A. No.
    10 Q. Did you have a curiosity to speak
    11 with them firsthand?
    12 A. I felt that that time would come,
    13 but they had work to do.
    14 Q. I guess I don't understand why
    15 you didn't speak with them before this
    16 planned or suggested meeting with the Boulder
    17 law enforcement authorities?
    18 MR. WOOD: That is not a
    19 question. That's just your problem with
    20 understanding something. I have expert
    21 witnesses in cases every day, Michael, that
    22 never talk to my client. I give them the
    23 information. I have clients that have lost
    24 their daughter, please, sir. I have had
    25 clients that have had children seriously
    1 injured. I don't sit there and give them
    2 the benefit of sitting down and talking with
    3 the experts that I retain. No lawyer does
    4 that, necessarily.
    5 MR. KANE: Well, I am not asking
    6 whether your lawyer did.
    7 MR. WOOD: You are expressing a
    8 problem understanding it. You are not asking
    9 her.
    10 MR. KANE: I will ask her.
    11 MR. WOOD: She is not going to
    12 be able to help you whether you're able to
    13 understand something or not. You have to
    14 work that out. All I am saying is that
    15 from my perspective as a lawyer, it happens
    16 every day.
    17 MR. KANE: That is fine. And I
    18 am not asking you, Mr. Wood. I am asking
    19 Mrs. Ramsey.
    20 MR. WOOD: I know that. In
    21 fairness, it is nothing sinister to it.
    22 Q. (By Mr. Kane) Mrs. Ramsey, why
    23 didn't you ask to sit down and talk with
    24 these experts?
    25 MR. WOOD: I think she's already
    1 told you that two or three different times,
    2 Michael.
    3 MR. KANE: No. She said that
    4 she anticipated going --
    5 Q. (By Mr. Kane) Why didn't you ask
    6 to speak with them before this meeting that
    7 was trying to be set up in January?
    8 A. I didn't feel like there was a
    9 need for me to speak with them before until
    10 they were finished with what their objective
    11 was, and then we would all be presented the
    12 material together.
    13 Q. Okay. Now, and that meeting
    14 never took place in January?
    15 A. That's right.
    16 Q. Have you met with them since?
    17 A. No, I have not.
    18 Q. Why not?
    19 A. Because everything fell through.
    20 Q. The meeting fell through, but what
    21 about your own becoming aware of what these
    22 experts had to say about the death of your
    23 daughter, did you ever request to meet with
    24 them for a briefing yourself?
    25 A. I did not request a meeting, no.
    1 Q. You identified Priscilla White as
    2 a suspect back in June of '98. Is there
    3 anything since that time that -- is there
    4 any additional information that keeps her on
    5 your suspect list?
    6 MR. WOOD: And, you know, you got
    7 a lawsuit from Chris Wolf. I am not sure
    8 of the terminology, Michael, that was used
    9 precisely as I sit here, but I know you all
    10 asked a lot of questions in the course of
    11 your investigation, and information that is
    12 provided to you may be in your minds
    13 indicating someone is a, quote/unquote,
    14 suspect. I am never sure what a suspect is
    15 other than somebody that might be someone
    16 that should be investigated.
    17 I don't really think there is a,
    18 quote/unquote, suspect list. I think that
    19 carries with it a connotation that there is
    20 reason to have evidence to say somebody did
    21 this, and I think it is more of a list of
    22 people that are leads or possibilities that
    23 should be investigated. And I just don't
    24 want somehow somebody to start, besides Chris
    25 Wolf, filing lawsuits claiming that we've
    1 identified them as a, quote/unquote, suspect.
    2 That is my concern. I think you would
    3 appreciate it.
    4 Q. (By Mr. Kane) Well, obviously
    5 this is not -- I mean, we don't intend to
    6 make this information public, but in the
    7 course of the investigation, we need to know
    8 if there is additional evidence other than
    9 what we -- what you offered back in June of
    10 1998 that would suggest that Priscilla White
    11 was a viable suspect in this case, or
    12 someone that cannot be excluded?
    13 A. Well, it is kind of like Lin
    14 said. We early on provided a list of people
    15 who were, A, in our home, B, worked for us.
    16 You know, we wracked our brains about, you
    17 know, who this might have been because we
    18 were told early on that it, you know,
    19 possibly was someone that was close to us.
    20 And, you know, those were -- they were close
    21 friends of ours.
    22 Q. Was Susan Stein ever a suspect?
    23 MR. WOOD: By who, the police?
    24 Q. (By Mr. Kane) No, by you.
    25 A. No. I mean, the reason the
    1 Whites, I think, kind of came up on the
    2 radar screen was subsequent to JonBenet's
    3 death they just seemed to act, to us, in a
    4 very unusual manner in terms of being very
    5 confrontational, and, you know, jumping in on
    6 meetings with our priest, and writing
    7 voluminous letters to the governor. To me
    8 that just seemed unusual, and I wondered to
    9 myself why someone would act that way.
    10 Q. And it was this, the way they
    11 were acting, is what, in your mind, made
    12 them suspects, potential suspects?
    13 A. Well, potentially, yes. But, I
    14 mean, if I knew from you or from whomever
    15 about a lot of people, whether, you know,
    16 handwriting has thoroughly been checked, DNA
    17 has been checked, et cetera, et cetera, you
    18 know, that would help it cross off in my
    19 mind.
    20 Q. Other than the thing that you
    21 talked about the amount of blood indicating
    22 that the asphyxiation occurred before the
    23 blow to the head, are there any other
    24 details that you have that would suggest the
    25 sequence that you know of?
    1 MR. WOOD: From the forensic
    2 people?
    3 MR. KANE: From any source.
    4 THE WITNESS: That a stun gun was
    5 used to silence her.
    6 Q. (By Mr. Kane) Where was that
    7 information? Where did you get that
    8 information?
    9 A. I believe that came from Lou
    10 Smith.
    11 Q. Have you talked to anybody other
    12 than Lou Smith -- well, let me ask you that.
    13 Have you talked to Lou Smith directly
    14 yourself?
    15 A. Yes.
    16 Q. About that?
    17 A. Yes.
    18 Q. Have you talked to anybody else
    19 other than Lou Smith about a stun gun having
    20 been used?
    21 A. Yes.
    22 Q. And who was that?
    23 A. Ollie Gray.
    24 Q. Was Mr. Gray, did he offer up
    25 conclusions about that, that a stun gun was
    1 used?
    2 A. Yes.
    3 Q. And have you talked to any
    4 medical people about whether a stun gun was
    5 used?
    6 A. I have not myself.
    7 Q. Have you heard indirectly from any
    8 medical people about a stun gun having been
    9 used?
    10 A. I believe so.
    11 Q. Who was that that you heard it
    12 from?
    13 A. I don't know the names.
    14 Q. What have you heard from these
    15 people?
    16 A. I have heard that it has been
    17 substantiated that a stun gun was used.
    18 Q. What was it that substantiated the
    19 use of a stun gun?
    20 A. Whatever they do to test markings
    21 against known markings of a particular stun
    22 gun.
    23 Q. And so that is what it is, the
    24 markings?
    25 A. (Witness nodded head
    1 affirmatively).
    2 Q. Have you ever, to your knowledge,
    3 you or Mr. Ramsey, ever hired a forensic
    4 expert to look at that issue, to look at the
    5 autopsy report or look at any other evidence
    6 that might be available that would have a
    7 bearing on whether a stun gun was used?
    8 A. I can't say for sure. John may
    9 know that.
    10 Q. But to your knowledge, you
    11 haven't?
    12 MR. WOOD: I think she told you
    13 she hasn't.
    14 MR. KANE: She said she can't say
    15 for sure.
    16 THE WITNESS: I don't know.
    17 MR. WOOD: I think when you say
    18 you can't say for sure, is there anything to
    19 add to that, Patsy?
    20 THE WITNESS: No. I don't know.
    21 Q. (By Mr. Levin) Mrs. Ramsey, in
    22 the course of your conversation with Mr.
    23 Schmidt concerning the stun gun, do you
    24 recall whether or not he sat down and showed
    25 you photographs of the injuries he believed
    1 to be stun gun injuries?
    2 A. I believe he did.
    3 Q. Did you or, at your request, were
    4 copies of those provided to any other medical
    5 people, copies of the photographs to assist
    6 them?
    7 A. I don't know.
    8 MR. LEVIN: Are you done, Mike?
    9 MR. KANE: Yes. I have other
    10 questions, but take a minute.
    11 Q. (By Mr. Morrissey) We know what
    12 you said about Priscilla White. I am just
    13 -- my question is, since we talked to you
    14 last, have you developed any evidence that
    15 would confirm your suspicion as far as
    16 Priscilla White is concerned, anything that
    17 you know of in the course of the
    18 investigation that you have conducted that
    19 would keep her on this list, independent of
    20 what you might think we know, that kind of
    21 thing?
    22 A. No.
    23 Q. How about Fleet White, anything
    24 that you have developed since the last time
    25 we spoke to you that would keep him on this
    1 suspect -- or that would keep him on this
    2 list?
    3 MR. WOOD: Are you talking about
    4 whether their investigators have developed
    5 information as opposed to like an event
    6 occurring such as filing a criminal civil
    7 case, which is a little odd?
    8 Q. (By Mr. Morrissey) Anything new
    9 that we don't know about Fleet White that
    10 you have developed or your investigators have
    11 developed?
    12 A. I can't remember any. The only
    13 -- I just heard recently that we have come
    14 across a copy of his statement to you folks
    15 or to the police department on or the day
    16 after JonBenet's death and that he was asked
    17 about the ransom note and could very closely
    18 recite the content, which seemed unusual.
    19 Q. The same, I guess, the same
    20 question in regard to Mr. McReynolds, and I
    21 am sorry I don't remember Mr. McReynolds'
    22 first name.
    23 MR. WOOD: Is it Bill?
    24 MR. LEVIN: Yes.
    25 MR. MORRISSEY: William, yes.
    1 Q. (By Mr. Morrissey) Anything, I
    2 know his name came up, and I was wondering
    3 if anything since the last time you spoke
    4 to, I believe it was the Boulder district
    5 attorneys, I think after the formal
    6 discussion you had on tape and everything,
    7 then you went -- and I heard an audiotape --
    8 where you were focusing on Mr. McReynolds
    9 himself with Mr. DeMouth and a couple of
    10 other people. I was wondering if anything,
    11 any follow-up had been done as far as your
    12 investigation is concerned, any new
    13 information on Mr. McReynolds' possible
    14 involvement.
    15 A. I don't know.
    16 Q. And Mr. Wolf? I mean these,
    17 Bruce asked you these kind of in a group of
    18 four. I was interested specifically, since
    19 we last spoke to you, what have you
    20 developed, if anything, about Mr. Wolf?
    21 A. Well, I think subsequent to that,
    22 I know we have a tape from his one-time
    23 girlfriend.
    24 Q. Ms. Dilson?
    25 A. Dilson. She videotaped herself
    1 imploring John and me to help her. She is
    2 very frightened of him. She believes that
    3 he did this. She is in hiding.
    4 Q. Have you ever spoken to Ms.
    5 Dilson in person or --
    6 A. I can't, I can't remember.
    7 Q. Okay. But you viewed this tape
    8 of her asking for your help?
    9 A. Yes, uh-huh, uh-huh.
    10 Q. Anything other than the tape that
    11 would indicate to you or keep Mr. Wolf in
    12 that position that he was in last time we
    13 spoke?
    14 A. I just can't think of anything
    15 right now.
    16 MR. KANE: Can I ask a question?
    17 MR. LEVIN: I was going to just
    18 follow-up on that, Michael.
    19 Q. (By Mr. Levin) Have you sent
    20 your investigators out to interview Ms.
    21 Dilson or try to locate her to follow up on
    22 this tape?
    23 MR. WOOD: Well, let me help you
    24 a little bit. Chris Wolf has filed a
    25 lawsuit against John and Patsy Ramsey, so you
    1 can rest assured that Chris Wolf and Ms.
    2 Dilson, in terms of information, are being
    3 developed about that in terms of the defense
    4 to that case, among other things. So if we
    5 come across anything in the course of that
    6 civil litigation, we will get it as quickly
    7 as we can copy it and get it to you.
    8 Obviously we have begun to study a lot of
    9 his appearances in some other things.
    10 Q. (By Mr. Levin) So, Mrs. Ramsey,
    11 I take it then that the answer to my
    12 question as far as to date is no, that no
    13 one has gone out and attempted to interview
    14 Ms. Dilson on your behalf?
    15 MR. WOOD: If you know.
    16 MR. LEVIN: If you know.
    17 THE WITNESS: I don't know.
    18 Q. (By Mr. Levin) Have you received
    19 any reports or any summaries from any
    20 investigator that would cause you to believe
    21 that she was contacted directly by your
    22 representatives?
    23 A. I just don't know. That would be
    24 -- John, perhaps, would know.
    25 Q. You have no recollection, as you
    1 sit here, of seeing any follow-up information
    2 in any form?
    3 A. That is correct.
    4 Q. This tape, was that unsolicited on
    5 the part of your family?
    6 A. Oh, yes.
    7 Q. When did you receive that?
    8 A. Probably sometime last spring.
    9 Q. The spring of '99?
    10 A. No. Spring of -- I think spring
    11 of 2000 or maybe fall of 2000.
    12 Q. Well, it wouldn't be fall. So
    13 maybe spring of this year?
    14 A. I mean spring, yes.
    15 Q. Or fall of '99?
    16 A. I'm just thinking of, I know we
    17 saw it in our apartment. I am trying to
    18 think when, how long we have been in that
    19 apartment.
    20 MR. LEVIN: Michael.
    21 Q. (By Mr. Kane) Have you had any
    22 forensic people look into the issue of the
    23 pineapple that was found in JonBenet's
    24 digestive tract?
    25 MR. WOOD: Let me ask you this,
    1 Michael. Are you stating as a matter of
    2 fact that it was pineapple without any
    3 question?
    4 MR. KANE: That was stated two
    5 years ago in the interview. Yes. There is
    6 no doubt about it.
    7 MR. WOOD: Are you stating it as
    8 fact?
    9 MR. KANE: Lou Smith told Mr.
    10 Ramsey that too.
    11 MR. WOOD: I just want to make
    12 sure it's clear that you're stating it as a
    13 matter of fact and not opinion that it is
    14 pineapple.
    15 MR. KANE: It is pineapple.
    16 Q. (By Mr. Kane) Why did you state,
    17 let me ask you, why did you state in your
    18 book that it was pineapple?
    19 MR. WOOD: Are you going to
    20 withdraw the last question?
    21 MR. KANE: Lin, look, this is not
    22 -- we are not in court.
    23 MR. WOOD: But we are making a
    24 record, and it is important, because I looked
    25 at some of the stuff in the past, and it is
    1 jumping back and forth. I want to make sure
    2 that, if there is a question pending, the
    3 record accurately reflects that she either
    4 has answered it or at this point in time
    5 you're not insisting upon an answer and you
    6 will come back to it later.
    7 I think from what you are telling
    8 me is you are going to hold off on the last
    9 question about forensics and go to the book.
    10 MR. KANE: I'll ask it, but I
    11 was going to preface it with the book, but I
    12 will do it in the reverse order.
    13 MR. WOOD: Okay.
    14 Q. (By Mr. Kane) Have you talked to
    15 anybody about findings of pineapple in her
    16 digestive system?
    17 A. No.
    18 Q. In your book you said that this
    19 was -- that that became an urban legend.
    20 MR. LEVIN: Hang on a second.
    21 MR. WOOD: Hang on one second,
    22 Michael.
    23 MR. LEVIN: Do you want to have
    24 him change the tape?
    25 MR. WOOD: He's got about nine
    1 minutes, I guess.
    2 MR. MORRISSEY: Can I ask a
    3 question or are we just on break or
    4 something?
    5 MR. WOOD: While he goes to get
    6 a book, yes, of course.
    7 Q. (By Mr. Morrissey) Mrs. Ramsey,
    8 will you have any trouble, problems with us
    9 seeing this Dilson tape, at some point
    10 getting us a copy of that?
    11 A. Sure. That would be fine.
    12 MR. MORRISSEY: I mean, I don't
    13 know if --
    14 THE WITNESS: I am not sure where
    15 it is right now, but I am sure we can run
    16 it down.
    17 MR. WOOD: Rest assured that, if
    18 you have any kind of request like that, if
    19 you'll make it to me, you know, I'll
    20 carefully consider it. And if in any way
    21 possible, I will try to get that stuff to
    22 you. That is the kind of thing that's gonna
    23 be clearly coming out in the civil case,
    24 so --
    25 MR. MORRISSEY: Right. That is
    1 why I wasn't sure. I just wanted to ask
    2 her, but I wasn't sure what your position
    3 was going to be --
    4 MR. WOOD: Well, you know --
    5 MR. MORRISSEY: --because I know
    6 that is kind of a shadow case, but I would
    7 sure like to see that tape.
    8 THE WITNESS: She was very upset.
    9 MR. WOOD: All right. We're back
    10 to Mr. Kane's question now. Did you have a
    11 page, Michael?
    12 MR. KANE: Yeah, on Page 273 in
    13 the middle.
    14 Q. (By Mr. Kane) You say
    15 apparently, during the autopsy, an issue was
    16 raised about the possibility of JonBenet
    17 having eaten pineapple. Do you recall -- do
    18 you recall, during the interviews in June of
    19 1998, being told that there was, in fact,
    20 pineapple in her system?
    21 A. I don't remember the specific
    22 discussion. I believe someone said there may
    23 have been something that looked like
    24 pineapple.
    25 Q. Okay.
    1 A. I'm not - no one ever has told
    2 me that it was definitively pineapple.
    3 Q. All right. Did John -- so John
    4 never told you that Lou Smith told him that
    5 it was definitely pineapple?
    6 A. No.
    7 Q. Have you, whether it was pineapple
    8 or any other type of fruit, it is your
    9 understanding that you haven't asked any
    10 forensic experts to, gastroenterologist or
    11 someone of that nature, someone with a
    12 medical background, what their opinion of
    13 that being in her system is?
    14 A. I don't know. That may have been
    15 part of the presentation that was being
    16 prepared.
    17 Q. Well, the presentation was Dr.
    18 Sperry. Let me just clarify this. Was
    19 anybody else besides Dr. Sperry going to take
    20 part in that presentation, to your knowledge?
    21 A. To my knowledge, there were
    22 several people involved.
    23 Q. But you don't know who these
    24 people are?
    25 A. No.
    1 Q. Do you know what their fields of
    2 expertise were?
    3 A. I am sorry, I don't.
    4 Q. And you didn't learn subsequent to
    5 January who these people are and what their
    6 fields of expertise are?
    7 MR. WOOD: Specific names, I
    8 think she's told you.
    9 THE WITNESS: I mean, I think, I
    10 think I was told, probably, you know, this
    11 name, this name, and this is who he is and
    12 that is and that is. They are all like
    13 names with degrees this long. I just knew I
    14 was very impressed by the caliber of the
    15 individuals consulting on this.
    16 Q. (By Mr. Kane) Okay. All right.
    17 And you don't have any problem with giving
    18 us those names, do you, afterwards if you
    19 and Mr. Ramsey --
    20 MR. WOOD: Whatever names were
    21 offered to you and Pat Burke, I will tell
    22 you, whatever names were offered in January
    23 of 2000 by Pat Burke when that offer was
    24 rejected, we will certainly provide you with
    25 those names if you don't already have them.
    1 MR. KANE: Well, I'll tell you
  2. Tricia

    Tricia Administrator Staff Member

    1 MR. KANE: Well, I'll tell you
    2 right now there was only one name that was
    3 offered to me, and that was Dr. Sperry from
    4 GBI.
    5 MR. WOOD: That may be true, but
    6 my understanding is there were other
    7 individuals either contemplated in that
    8 presentation, that it was more than one, but
    9 you've got his name and if there were
    10 others --
    11 THE WITNESS: And if we want to
    12 do the presentation, we can do it.
    13 MR. WOOD: - we will get those
    14 names to you, no question. In fact, what we
    15 can do at some point, if we can figure out
    16 an appropriate time, but like this Dilson
    17 tape, or these names, et cetera, if you can
    18 get a list and you all can get it to me,
    19 and then we will try to go through it and
    20 see what we can get to you if you don't
    21 have it.
    22 MR. LEVIN: Mr. Wood, I am taking
    23 maybe incorrectly, I am taking your statement
    24 that if we wanted to personally just directly
    25 contact Dr. Sperry that we can do that?
    1 MR. WOOD: I would have to make
    2 that decision. I haven't thought about it.
    3 MR. LEVIN: I don't want to --
    4 MR. WOOD: I wouldn't make a seat
    5 of the pants decision on something like that.
    6 MR. LEVIN: Sure.
    7 MR. WOOD: Obviously he is a
    8 retained expert.
    9 MR. KANE: Can I clarify that?
    10 Q. (By Mr. Kane) Has he been
    11 retained by you? That was the whole issue
    12 that was presented to us when Pat Burke was
    13 suggesting this meeting. I asked whether he
    14 had been retained by you. Was he retained
    15 by you?
    16 MR. WOOD: If you --
    17 MR. KANE: If you know.
    18 THE WITNESS: I don't know.
    19 MR. WOOD: That is probably
    20 something she wouldn't know the legal
    21 niceties of.
    22 THE WITNESS: I mean, I don't
    23 know who.
    24 MR. WOOD: Listen, we'll sort out
    25 the question of Sperry's status.
    1 MR. KANE: Okay.
    2 MR. WOOD: And you know,
    3 unfortunately I don't have the direct
    4 knowledge that Pat Burke has, but we will
    5 sort out that in terms of what he
    6 contemplated offering you all and what their
    7 status is and how available they will be. I
    8 will get those answers to you one way or the
    9 other.
    10 MR. KANE: I just have one thing
    11 to follow up on, Bruce.
    12 Q. (By Mr. Kane) Bruce said that
    13 Ellis Armistead had been hired in 1997. Do
    14 you recall that Mr. Armistead, in fact, was
    15 hired in December of 1996?
    16 A. I can't say for sure. I don't
    17 know.
    18 MR. WOOD: I think that he was,
    19 just if that helps you.
    20 MR. KANE: Yeah, I just wanted to
    21 clarify, Mr. Levin said '97.
    22 MR. WOOD: He said as far back
    23 as '97, as I recall.
    24 MR. KANE: But it was as far
    25 back as 1996.
    1 THE WITNESS: I just remember he
    2 was there very -- you know, my days are
    3 really foggy then. I just remember we were
    4 intensely afraid for our safety, and he -- I
    5 just remember, you know, in my trauma,
    6 looking up at this big guy and thinking,
    7 boy, am I glad he is here. So I don't
    8 know what day that was, or --
    9 Q. (By Mr. Kane) Did he ever
    10 interview you?
    11 A. Quite possibly. I can't remember.
    12 Q. You don't have any recollection of
    13 ever being interviewed by Mr. Armistead or
    14 anybody else working for him?
    15 A. I mean, we talked, certainly. I
    16 don't know if you would say it was an
    17 interview.
    18 Q. Did Mr. Armistead or any other --
    19 I guess it was Jennifer Getty worked for
    20 him. Do you recall her?
    21 A. Uh-huh, uh-huh (affirmative).
    22 Q. John Foster, do you recall him?
    23 A. Yes.
    24 Q. David Williams, do you recall him?
    25 A. Yes.
    1 Q. Did any of these people ever take
    2 statements from you about what happened?
    3 MR. WOOD: Subsequent to June of
    4 1998?
    5 MR. KANE: No.
    6 Q. (By Mr. Kane) Of the events of
    7 December 25th, 26th, of 1996.
    8 A. I can't remember.
    9 Q. You don't have any recollection of
    10 being interviewed?
    11 MR. WOOD: She told you she can't
    12 remember.
    13 MR. KANE: Lin, if you are going
    14 to object to every question --I asked you --
    15 THE WITNESS: I can go back and
    16 look.
    17 MR. KANE: Because I am asking a
    18 clarifying question.
    19 MR. WOOD: No, no. I am not
    20 objecting. I am just making sure that we
    21 are fair here. You know, when she says I
    22 can't remember and you look over and go, you
    23 mean you can't remember, I mean, the tone of
    24 that implies that there is something wrong
    25 with a truthful answer being I can't
    1 remember. That is all -- she tells you
    2 something, you know, you don't have to beat
    3 her over the head with her answer. Once
    4 ought to be enough.
    5 MR. KANE: Well, is that your
    6 objection, that I am beating her over the
    7 head?
    8 MR. WOOD: It is not an
    9 objection. No, no.
    10 MR. KANE: I think, you know, we
    11 came down here with the understanding that we
    12 could ask questions. And what you are
    13 trying to do is channel those questions into
    14 a certain tone. And I --
    15 MR. WOOD: No, I am not. I
    16 really am not. I mean, you came down here
    17 under the request of Chief Beckner to ask
    18 new questions about information that has been
    19 obtained by you since June of 1998 or
    20 developments that have arisen since June of
    21 1998. That was the request. We agreed to
    22 that.
    23 MR. KANE: Okay.
    24 MR. WOOD: And all I am saying
    25 is that, in the process of giving
    1 information, there may be an answer that to
    2 you strikes you, as you can't remember that.
    3 If she can't remember, Mitch, that is the
    4 truth, and, you know.
    5 MR. MORRISSEY: I am Mitch.
    6 MR. WOOD: I don't mean the
    7 phrase, I am sorry, Michael. I don't mean
    8 to use the phrase -- I don't think you beat
    9 her over the head. I am just using the
    10 phrase that sometimes lawyers do tend to beat
    11 witnesses over the head when they don't
    12 either like or necessarily react favorably to
    13 an answer. You haven't beat her over the
    14 head here today. I wouldn't let you do
    15 that. And I don't mean to suggest otherwise
    16 on the record.
    17 MR. KANE: Okay.
    18 MR. LEVIN: Lin, if I, if I can
    19 just follow up your statement a little bit,
    20 we are, the four of us, extremely experienced
    21 trial lawyers, and I can't imagine that, in
    22 the course of your practice, you have not
    23 either, during the course of a deposition or
    24 in formal interview with a witness or in a
    25 courtroom, gotten a witness who says I can't
    1 remember and then not follow it up to see if
    2 you can kind of spark their memory. I think
    3 that is all we are trying to do.
    4 MR. WOOD: I am not going to
    5 prevent that type of follow-up, and I know
    6 you guys are experienced. And I have
    7 managed to do a little bit of that myself
    8 over the last 23 years. So I fancy myself
    9 as quite experienced in trial law also.
    10 And I understand the difference,
    11 though, between an interview and a
    12 cross-examination. In a cross-examination,
    13 you might follow up and, as we lawyers say,
    14 beat on the witness a little bit. This is
    15 not a cross-examination of my client. And
    16 there is a difference.
    17 This is an interview where you
    18 are here to get information about the new
    19 questions, as I have earlier stated. But I
    20 am not sitting here saying, Patsy Ramsey has
    21 been offered up for you skilled trial lawyers
    22 to cross-examine her.
    23 MR. LEVIN: We have no intention.
    24 MR. WOOD: That is the
    25 difference.
    1 MR. LEVIN: I'm sure it is
    2 apparent to you that we are not
    3 cross-examining your client.
    4 MR. WOOD: Listen, I think we are
    5 doing very well so far. I am pleased.
    6 MR. LEVIN: I'm just saying that
    7 we try to prod her memory a little bit, if
    8 we get a --
    9 MR. WOOD: I have no problems
    10 with you trying to jog someone's recollection
    11 at all.
    12 MR. LEVIN: Great. I appreciate
    13 that.
    14 THE VIDEOGRAPHER: We need to
    15 make a tape change. One moment.
    16 (A recess was taken.)
    17 THE VIDEOGRAPHER: We are rolling.
    18 MR. LEVIN: Mrs. Ramsey, I
    19 believe that Chief Beckner has a couple of
    20 questions for you concerning your
    21 investigation, and then we're gonna move onto
    22 another area.
    23 Q. (By Chief Beckner) Now, I am
    24 just a little bit confused because it
    25 certainly had been our impression through
    1 public statements and communications that you
    2 and John have had very publicly about having
    3 a secondary investigation conducted by your
    4 people, hiring a team of experts to do
    5 follow-up investigation, and had really
    6 expressed a desire to share this information
    7 with us.
    8 I get the sense that you are not
    9 controlling that investigation, sitting here
    10 today, which is a different sense. So I
    11 wanted to ask you if you are in charge of
    12 that investigation.
    13 A. Am I personally in charge of the
    14 investigation?
    15 Q. Are you and John heading up that
    16 investigation into JonBenet's death?
    17 A. Well, we are having the
    18 investigation done.
    19 Q. Who is directing it? Who is
    20 directing that investigation? In other
    21 words, who is making the day-to-day
    22 decisions, we need to do this, we need to
    23 hire this person, those sorts of things?
    24 A. Ollie Gray.
    25 Q. So you have hired Ollie Gray with
    1 instructions to conduct an investigation, and
    2 he is given a free hand to do whatever that
    3 takes?
    4 A. Yes.
    5 MR. WOOD: He is employed
    6 full-time on that at the present time.
    7 Q. (By Chief Beckner) Has that
    8 always been the case or has that been a
    9 recent development? Because we talked about
    10 a lot of other people that have been
    11 involved from '96 on.
    12 A. Right.
    13 Q. Is that a recent development?
    14 A. Well, within the past year.
    15 MR. WOOD: You are talking about
    16 with Ollie?
    17 CHIEF BECKNER: Yes, with Ollie.
    18 Q. (By Chief Beckner) Is John more
    19 involved than you are --
    20 A. Yes.
    21 Q. - in terms of getting
    22 information?
    23 A. Yes.
    24 Q. And knowing where the
    25 investigation is going?
    1 A. Yes.
    2 Q. But John does not share that with
    3 you?
    4 A. He shares some of it with me.
    5 Q. But not all of it?
    6 A. That is right.
    7 MR. KANE: Can I ask a follow-up
    8 to that then?
    9 Q. (By Mr. Kane) What is your
    10 understanding of the reason that Ellis
    11 Armistead is no longer working on the case?
    12 A. Well, I think -- I don't know
    13 exactly why he is not and why Ollie is, but
    14 Ollie is full-time. They were I don't
    15 believe capable of continuing it on on a
    16 full-time basis.
    17 Q. Is that your understanding?
    18 A. That is my understanding.
    19 Q. They couldn't do it full-time, so
    20 you got somebody else?
    21 A. Correct.
    22 MR. WOOD: Let me just correct,
    23 when you say -- Ollie has been involved
    24 before Ellis left. And I think Ellis's
    25 leaving was tied to the fact that Bryan and
    1 Hal would no longer be in the case and the
    2 question of how much could really be done
    3 effectively and whether it could be done by
    4 one full-time person and whether there was
    5 really anything else for Ellis to do.
    6 CHIEF BECKNER: Let me follow-up.
    7 Q. (By Chief Beckner) Who was in
    8 charge of the investigation prior to Ollie?
    9 A. Ellis Armistead, John Foster, and
    10 Williams, David Williams.
    11 Q. So when Mr. Gray came on the
    12 investigation, Ellis Armistead was still on
    13 at that time?
    14 A. Yes. There was a transition in
    15 time.
    16 Q. So Ellis was still in charge at
    17 that time?
    18 A. I don't know who was in charge.
    19 I think it was kind of a change in command.
    20 Q. And what was John's involvement at
    21 that time?
    22 A. I don't know exactly, but he
    23 basically has been the point man.
    24 MR. WOOD: And don't leave out
    25 Pat Burke and Bryan Morgan, Chief. I think
    1 they were taking on a more active role in
    2 making decisions about things that could or
    3 should be done as opposed to what now is
    4 more Ollie's area.
    5 CHIEF BECKNER: Yeah, I was just,
    6 because the impression was that, based on
    7 some of the statements that you've made
    8 publicly and John specifically about spending
    9 all of his time trying to find the killer of
    10 JonBenet, I am trying to get at, you know,
    11 what are you doing and how involved are you.
    12 Because I was getting the sense here that
    13 you aren't particularly involved in that.
    14 THE WITNESS: Well, I am not
    15 day-to-day involved with it. John speaks
    16 with Ollie, I would say, on a daily basis.
    17 You know, where we are, what's been --
    18 CHIEF BECKNER: On a daily basis?
    19 MR. WOOD: You sure about that?
    20 THE WITNESS: I don't know if it
    21 is daily, but it is frequently.
    22 MR. MORRISSEY: Okay.
    23 MR. KANE: Can I ask, is
    24 Mr. Gray employed by you or employed by
    25 Mr. Wood?
    1 MR. WOOD: Employed by me, which
    2 would be standard handling, as I understand
    3 it.
    4 Q. (By Chief Beckner) So the
    5 decisions to hire the forensic people, those
    6 were not made by you or John?
    7 A. I, you know, I don't know who
    8 actually says, you know, let's hire him and
    9 him and him. I am sure that it was, this
    10 is what we want to do. We want to have
    11 people look at this and that and the other,
    12 you know, competent experts, and we said
    13 great.
    14 I mean, we entrusted them to make
    15 the decisions. I mean, we don't know how to
    16 investigate.
    17 Q. No, I understand that. Experts
    18 can be quite expensive.
    19 A. Yes, they are.
    20 Q. Quite costly. So I am just, I'm
    21 trying to figure out whether whoever is in
    22 charge of the investigation at whatever
    23 particular time has a free hand to hire
    24 those experts. I mean, is it kind of like
    25 an open checkbook kind of thing or do they
    1 have to come back?
    2 THE WITNESS: No, not --
    3 MR. WOOD: I don't think it is
    4 an open checkbook.
    5 THE WITNESS: No.
    6 MR. WOOD: Certainly not now. I
    7 don't think it ever has been, Chief. I
    8 think that there was a -- Pat Burke and
    9 Bryan Morgan were out there and dealing more
    10 directly with that issue. I am quite
    11 confident John, you all can ask him, he can
    12 tell you, but I am quite sure that, as any
    13 lawyer would do with any major expenditure
    14 first, it has to be approved by the client.
    15 So that is my understanding.
    16 CHIEF BECKNER: That is what I am
    17 getting at.
    18 THE WITNESS: Yes.
    19 Q. (By Chief Beckner) It was
    20 somebody, whether it was you or John,
    21 somebody had to be aware of who was being
    22 hired to do work for the investigation?
    23 A. Yes.
    24 Q. And you think it was John who was
    25 well aware of those decisions?
    1 A. Yes.
    2 CHIEF BECKNER: Okay.
    3 Q. (By Mr. Morrissey) Mrs. Ramsey,
    4 what does Mr. San Agustin do?
    5 A. He assists Ollie.
    6 Q. So he works for Ollie?
    7 A. Now, there again, I don't know
    8 who signs whose paychecks or whatever.
    9 Q. Right. I am not asking you that.
    10 A. But Ollie brought him in.
    11 Q. What does he do? Do you know?
    12 A. He is, in lay terms, a computer
    13 whiz.
    14 MR. WOOD: Business partner.
    15 THE WITNESS: Business partner,
    16 yeah, but he --
    17 Q. (By Mr. Morrissey) He is a
    18 computer guy?
    19 A. He is a computer guy.
    20 Q. Okay.
    21 MR. WOOD: I don't know if he
    22 would necessarily agree with computer guy --
    23 THE WITNESS: I mean, I know
    24 that's probably not fancy enough.
    25 MR. GRAY: He is basically, as
    1 you know, Mitch, an evidence specialist as
    2 far as courtroom evidence goes.
    3 MR. MORRISSEY: Demonstrative
    4 evidence type stuff, yeah, that has been my
    5 experience with him. I just thought he was
    6 in the employ of the El Paso County
    7 Sheriff's Office.
    8 Q. (By Mr. Levin) Ms. Ramsey, we
    9 are going to move on to another area. And
    10 what I want to discuss with you is the
    11 underpants that JonBenet was wearing at the
    12 time that she was discovered on the 26th.
    13 We are going to try to get some background
    14 information on those from you. Hopefully you
    15 can help us out a little bit. Okay?
    16 I don't, I'll be perfectly honest
    17 with you, I don't follow all of the media
    18 developments in this case, so I am not quite
    19 sure what is out in the public sector. But
    20 what I would like to get a feel for is just
    21 what your belief is with regard to the
    22 significance of the underpants that your
    23 daughter was wearing at the time that she
    24 was found murdered.
    25 MR. WOOD: With all due fairness,
    1 didn't you cover that in June of 1998?
    2 MR. LEVIN: I don't believe so,
    3 and I think that will become apparent.
    4 MR. WOOD: Okay. Well, maybe if
    5 you help me, just so I understand, when you
    6 say what is the significance of it, are you
    7 really just trying to find out what she
    8 might know about why she was wearing them?
    9 I am not sure what significance, with regard
    10 to significance --
    11 MR. LEVIN: What I would like to
    12 know is what Mrs. Ramsey's belief, as she
    13 sits here, is significant about the
    14 underpants. In a normal homicide case, what
    15 kind of underpants someone is wearing is
    16 typically not national news. Fair enough?
    17 THE WITNESS: Yes.
    18 MR. LEVIN: But apparently it has
    19 become national news, and I just want to get
    20 a sense, before I start asking some specific
    21 questions, which I hope she can help us
    22 with, why you think, what is your
    23 understanding of what the significance is.
    24 MR. WOOD: Bruce, I don't know,
    25 just so it is clear, I don't know that her
    1 underwear has become national news.
    2 Now, I don't know, sitting here
    3 today, I may want to go back and look at
    4 them, but it may be something that the
    5 tabloids have written about, but I don't know
    6 of any national news from reputable news
    7 agencies that have made that a major issue.
    8 But I am not arguing with that.
    9 I just want to make sure I don't agree with
    10 you by acquiescence, but --
    11 MR. LEVIN: I understand.
    12 MR. WOOD: - the question is, I
    13 think he wants to know, and maybe I am still
    14 not clear, you assume she attaches some
    15 significance to it, but I am not sure. If
    16 you asked her a factual question, maybe she
    17 will understand.
    18 Q. (By Mr. Levin) Well, let's start
    19 with what - I will make it very simple for
    20 you, Mrs. Ramsey. What information are you
    21 in possession of or what do you know about
    22 the underwear that your daughter was wearing
    23 at the time she was found murdered?
    24 A. I have heard that she had on a
    25 pair of Bloomi's that said Wednesday on them.
    1 Q. The underwear that she was
    2 wearing, that is Bloomi's panties, do you
    3 know where they come from as far as what
    4 store?
    5 A. Bloomingdales in New York.
    6 Q. Who purchased those?
    7 A. I did.
    8 Q. Do you recall when you purchased
    9 them?
    10 A. It was, I think, November of '96.
    11 Q. In the fall of 1996, how many
    12 trips did you make to New York?
    13 A. Two, I believe.
    14 Q. Do you recall, and again, the
    15 same, same qualification I gave you when we
    16 started, which is, I understand that you are
    17 not going to give me exact dates, but the
    18 two trips you made, did you make those with
    19 different groups of people?
    20 A. Yes.
    21 Q. The first trip, who was that trip
    22 with?
    23 A. The first trip was a
    24 mother-daughter trip with my mother Nedra
    25 Paugh, my sister Pam Paugh, friends Susan
    1 Flanders from Charlevoix, Michigan, and her
    2 daughter and a friend of Susan's, Ms.
    3 Kirkpatrick I believe was her name, and her
    4 daughter, and JonBenet and myself.
    5 Q. And the second trip you made was?
    6 A. The second trip we made was with
    7 Glen and Susan Stein.
    8 Q. Is that the trip -- which trip
    9 was the November trip?
    10 A. With the children.
    11 Q. Was that -- that is the first
    12 trip?
    13 A. Yes.
    14 Q. And the second trip that you and
    15 your husband and the Steins took, was that
    16 also November, but later in the month, or
    17 was that a December trip?
    18 A. I think it was December.
    19 Q. And maybe this will help jog your
    20 memory as to time. I believe that was the
    21 time of the Christmas parade in Boulder.
    22 A. Yes.
    23 Q. Is that correct?
    24 A. Yes.
    25 Q. Were you out of town?
    1 A. I remember that.
    2 Q. Which of those two trips did you
    3 purchase the Bloomi's?
    4 A. The first trip.
    5 Q. Was it something that was selected
    6 by JonBenet?
    7 A. I believe so.
    8 Q. Was it your intention, when you
    9 purchased those, for those to be for her,
    10 not for some third party as a gift?
    11 A. I bought some things that were
    12 gifts and some things for her. So I
    13 don't --
    14 Q. Just so I am clear, though, it is
    15 your best recollection that the purchase of
    16 the underpants, the Bloomi's days of the
    17 week, was something that you bought for her,
    18 whether it was just I am buying underwear
    19 for my kids or these are special, here's a
    20 present, that doesn't matter, but it was your
    21 intention that she would wear those?
    22 A. Well, I think that I bought a
    23 package of the -- they came in a package of
    24 Monday, Tuesday, Wednesday, Thursday, Friday.
    25 I think I bought a package to give to my
    1 niece.
    2 Q. Which niece was that?
    3 A. Jenny Davis.
    4 Q. They came in, if you recall, do
    5 you remember that they come in kind of a
    6 plastic see-through plastic container.
    7 A. Right.
    8 Q. They are rolled up?
    9 A. Yes.
    10 Q. So if I understand you correctly,
    11 you bought one package for Jenny Davis, your
    12 niece, and one for JonBenet?
    13 A. I am not sure if I bought one or
    14 two.
    15 Q. Do you remember what size they
    16 were?
    17 A. Not exactly.
    18 Q. JonBenet was found wearing the
    19 Wednesday Bloomi's underpants, and your
    20 understanding is correct, that is a fact, you
    21 can accept that as a fact, when she was
    22 found murdered. Those underpants do not fit
    23 her. Were you aware of that?
    24 MR. WOOD: Are you stating that
    25 as a matter of fact --
    1 MR. LEVIN: I'm stating that as a
    2 matter --
    3 MR. WOOD: - for a six-year-old
    4 child?
    5 MR. LEVIN: I am stating that as
    6 a matter of fact.
    7 MR. WOOD: Don't fit her
    8 according to whose standard?
    9 MR. LEVIN: By --
    10 MR. WOOD: I mean, I have got an
    11 11-year-old boy, and he wears underwear that
    12 potentially hangs down to his knees, Bruce.
    13 I mean, I don't know how you can come up
    14 with that as a fact. That sounds to me
    15 like more of an opinion. Who states that as
    16 fact?
    17 Q. (By Mr. Levin) Ms. Ramsey, your
    18 daughter weighed, I believe, 45 pounds;
    19 correct?
    20 A. Uh-huh (affirmative).
    21 Q. She was six years old?
    22 A. Uh-huh (affirmative).
    23 Q. What size underpants would you
    24 normally buy for her?
    25 A. 8 to 10.
    1 Q. Ms. Ramsey, would you say that it
    2 would, it is safe to assume that, if she is
    3 wearing underpants designed for someone who
    4 weighs 85 pounds, who is 10 to 12 years old,
    5 that those would not fit her?
    6 A. Those -- I mean, I am sure she
    7 could wear them, yes, but they wouldn't fit
    8 as well as a smaller pair.
    9 Q. And as a mother, you would know
    10 that someone who is 85 pounds is
    11 significantly larger than your little
    12 six-year-old?
    13 MR. WOOD: Can't we assume that
    14 as a matter of 85 is more than 45 without
    15 her having to document a mathematical fact,
    16 Bruce?
    17 Q. (By Mr. Levin) 40 pounds is the
    18 wrong size pair of underpants, would you
    19 agree?
    20 A. Yes.
    21 Q. Okay. What we are trying to
    22 understand is whether -- we are trying to
    23 understand why she is wearing such a large
    24 pair of underpants. We are hoping you can
    25 help us if you have a recollection of it.
    1 A. I am sure that I put the package
    2 of underwear in her bathroom, and she opened
    3 them and put them on.
    4 Q. Do you know if -- you bought
    5 these sometime in mid to early December, is
    6 that correct, as far as -- no, I am sorry,
    7 you bought them in November?
    8 A. Right.
    9 Q. Do you recall, was she wearing
    10 these? And I don't mean this specific day
    11 of the week, but was she wearing, were you
    12 aware of the fact that she, you know, was in
    13 this package of underpants and had been
    14 wearing them since the trip to New York in
    15 November?
    16 A. I don't remember.
    17 Q. Ms. Hoffman Pugh generally did the
    18 laundry for the family, that is part of her
    19 duties; is that correct?
    20 A. Correct.
    21 Q. Exclusively, or did you wash
    22 clothes on occasion?
    23 A. I washed a lot of clothes.
    24 Q. Do you have any recollection of
    25 ever washing any of the Bloomi panties?
    1 A. Not specifically.
    2 Q. Was it something that, the fact
    3 that she is wearing these underpants designed
    4 for an 85-pound person, did you ever -- and
    5 I will give you a minute to think about it
    6 because I know it is tough to try to pin
    7 down a couple of months of casual
    8 conversation -- do you recall ever having any
    9 conversations with her concerning the fact
    10 that she is wearing underwear that is just
    11 too large for her?
    12 A. No.
    13 Q. Knowing yourself as you do, if it
    14 was, if it had caught your attention or came
    15 to your attention, do you think you might
    16 have said, JonBenet, you should, those don't
    17 fit, put something on that fits, that is
    18 inappropriate? Do you think, if it came,
    19 had come to your attention --
    20 A. Well, obviously we, you know, the
    21 package had been opened, we made the
    22 decision, you know, oh, just go ahead and
    23 use them because, you know, we weren't going
    24 to give them to Jenny after all, I guess,
    25 so.
    1 I mean, if you have ever seen
    2 these little panties, there is not too much
    3 difference in the size. So, you know, I'm
    4 sure even if they were a little bit big,
    5 they were special because we got them up
    6 there, she wanted to wear them, and they
    7 didn't fall down around her ankles, that was
    8 fine with me.
    9 MR. MORRISSEY: Did you ever see
    10 if they fell down around her ankles or not?
    11 THE WITNESS: No.
    12 MS. HARMER: But you specifically
    13 remember her putting on the bigger pair?
    14 And I am not saying --
    15 THE WITNESS: They were just in
    16 her panty drawer, so I don't, you know, I
    17 don't pay attention. I mean, I just put all
    18 of her clean panties in a drawer and she can
    19 help herself to whatever is in there.
    20 MS. HARMER: I guess I am not
    21 clear on, you bought the panties to give to
    22 Jenny.
    23 THE WITNESS: Right.
    24 MS. HARMER: And they ended up in
    25 JonBenet's bathroom?
    1 A. Right.
    2 Q. (By Ms. Harmer) Was there - I'm
    3 sorry. Do you recall making a decision then
    4 not to give them to Jenny or did JonBenet
    5 express an interest in them; therefore, you
    6 didn't give them to Jenny? How did that --
    7 A. I can't say for sure. I mean, I
    8 think I bought them with the intention of
    9 sending them in a package of Christmas things
    10 to Atlanta. Obviously I didn't get that
    11 together, so I just put them in her, her
    12 panty drawer. So they were free game.
    13 Q. (By Mr. Morrissey) At the time,
    14 how old was Jenny?
    15 A. I don't know. Probably -- I
    16 don't know. She is older than JonBenet, but
    17 I don't know exactly how old she was.
    18 Q. Would these panties, size wise, be
    19 more appropriate for -- is she an older
    20 girl?
    21 A. Yes.
    22 Q. And I assume a larger girl?
    23 A. Well, at that time, no, not -- I
    24 mean, she is not -- I mean, today she is a
    25 young woman, but then she was a little girl.
    1 Q. How old is she now?
    2 A. She is now 15, I believe.
    3 Q. So she would have been about 12
    4 or somewhere --
    5 A. 11.
    6 Q. -- 11, 12?
    7 A. Yeah.
    8 Q. And based on the, I guess,
    9 dimensions that Mr. Levin has talked about,
    10 these would have been a size appropriate for
    11 her?
    12 A. Uh-huh (affirmative).
    13 MR. WOOD: Do you know that?
    14 Q. (By Mr. Morrissey) Based on your
    15 knowledge of her? I mean, I never have seen
    16 this girl, so --
    17 MR. WOOD: Guys, I think -- if
    18 you all have kids, I mean, I just think you
    19 are making assumptions based on poundage,
    20 apparently, that isn't necessarily, you know,
    21 in touch with the realities with kids and
    22 their clothes. But you know, if you know
    23 that, Patsy, please tell them.
    24 Why don't you go ahead and
    25 restate your question.
    1 Q. (By Mr. Morrissey) You purchased
    2 these specifically for a person?
    3 A. Okay.
    4 MR. WOOD: Is that your
    5 recollection?
    6 THE WITNESS: Yes.
    7 MR. WOOD: Okay.
    8 Q. (By Mr. Morrissey) And I assume
    9 you wanted them to fit her and she be able
    10 to wear them or there would be no sense in
    11 purchasing them; right?
    12 A. Right.
    13 Q. Okay. Would the size that has
    14 been described here be appropriate for the
    15 size of the girl you purchased them for?
    16 A. I was guessing at her size, so I
    17 had hoped that they would be.
    18 Q. Now, we have talked -- you know,
    19 the fact that a boy may wear boxer shorts
    20 that go down to his ankles --
    21 A. Uh-huh (affirmative).
    22 Q. --has nothing to do with girls,
    23 when you purchase girl's panties; right?
    24 MR. WOOD: Come on, Mitch.
    25 Mitch --
    1 THE WITNESS: I mean, if --
    2 MR. WOOD: Don't answer that.
    3 That's not a --
    4 MR. MORRISSEY: It is different.
    5 MR. WOOD: I made the statement
    6 because of my kids, but let me just tell
    7 you, my nine-year-old daughter likes to wear
    8 my XL T-shirts. I mean, you are asking now
    9 about the realm of kids, and I don't think
    10 that is a factual question that she is
    11 really here to give you information about.
    12 MR. MORRISSEY: Mrs. Ramsey, I
    13 never purchased a pair of girl's panties.
    14 Okay.
    15 Q. (By Mr. Morrissey) What do you
    16 do, I mean, when you do that, what do you
    17 think about as far as the person you're
    18 purchasing them for?
    19 A. Well, you just look, small,
    20 medium, large, you know, and you pick the
    21 one you think would most likely fit.
    22 Q. And do they have age groups or
    23 are they suggested for like a 10-year-old
    24 through a 12-year-old or a 13-year-old
    25 through a 15-year-old? Do they do it that
    1 way too?
    2 A. I never paid any attention if
    3 they do.
    4 MR. MORRISSEY: Okay.
    5 Q. (By Mr. Kane) Let me ask it
    6 this way. Did you say you bought more than
    7 one set of Bloomi's?
    8 A. I can't remember.
    9 Q. You bought some for JonBenet?
    10 A. I can't remember.
    11 Q. Why is it that you remember
    12 buying Bloomingdale's panties in November of
    13 1996?
    14 A. Because --
    15 MR. WOOD: Because she remembers
    16 it. I mean --
    17 MR. KANE: Wait a second, Lin.
    18 Would you please let her answer the question?
    19 It is a simple question.
    20 MR. WOOD: Why is it that you
    21 remember something?
    22 MR. KANE: Yes, why do you
    23 remember --
    24 MR. WOOD: Because she remembered.
    25 Q. (By Mr. Kane) - that, that
    1 detail?
    2 A. Well, for starters, it has been
    3 made such a big detail.
    4 Q. Okay, well, that is my question.
    5 A. I remember that I -- and I, you
    6 know, we were kind of shopping around, and
    7 it was close to Christmas season, so we
    8 might pick up a little souvenir. I
    9 bought -- I think I picked up a little
    10 something for a baby-sitter, you know.
    11 Q. Where was it that you became
    12 aware that this was -- where was it that it
    13 was made a big deal? What was the source
    14 of your information that Bloomingdale's
    15 panties somehow were significant that made
    16 you then say, wait a second, did I ever buy
    17 those?
    18 MR. WOOD: Do you have a precise
    19 recollection of that event occurring where
    20 all of a sudden something happened and you
    21 decided it was some big deal?
    22 THE WITNESS: I don't know. I
    23 mean, my first thought is something in the
    24 tabloids, but, you know, they get everything
    25 wrong, so --
    1 Q. (By Mr. Kane) Okay. Were you
    2 aware that these were the size of panties
    3 that she was wearing, and this has been
    4 publicized, it is out in the open, that they
    5 were size 12 to 14? Were you aware of
    6 that?
    7 A. I have become aware of that, yes.
    8 Q. And how did you become aware of
    9 that?
    10 A. Something I read, I am sure.
    11 Q. And I will just state a fact
    12 here. I mean, there were 15 pair of panties
    13 taken out of, by the police, out of
    14 JonBenet's panty drawer in her bathroom. Is
    15 that where she kept -
    16 A. Uh-huh (affirmative).
    17 Q. -- where you were describing that
    18 they were just put in that drawer?
    19 A. Yes.
    20 Q. Okay. And every one of those was
    21 either a size four or a size six. Okay?
    22 Would that have been about the size pair of
    23 panties that she wore when she was six years
    24 old?
    25 A. I would say more like six to
    1 eight. There were probably some in there
    2 that were too small.
    3 Q. Okay. But not size 12 to 14?
    4 A. Not typically, no.
    5 MR. KANE: Okay.
    6 Q. (By Mr. Morrissey) And you
    7 understand the reason we are asking this, we
    8 want to make sure that this intruder did not
    9 bring these panties with him, this was
    10 something --
    11 A. Right.
    12 Q. - that was in the house.
    13 A. Yes.
    14 Q. And we are clear that, as far as
    15 you know, that is something that was in this
    16 house?
    17 A. Yes.
    18 Q. -- that belonged to your daughter,
    19 these panties?
    20 A. Correct.
    21 Q. (By Ms. Harmer) Mrs. Ramsey,
    22 have you ever seen a crime scene photo of
    23 the underwear that your daughter was found
    24 in?
    25 A. No.
    1 Q. Did Lou Schmidt ever show you a
    2 photo?
    3 A. No.
    4 Q. (By Mr. Kane) I want to follow
    5 up with something you said earlier. You
    6 said she would have just gone in and gotten
    7 a pair herself?
    8 A. Uh-huh (affirmative).
    9 Q. Okay. Was she -- did she usually
    10 dress herself?
    11 A. She was pretty much able to dress
    12 herself.
    13 Q. And I can't recall if you've
    14 ever, and forgive me if you have answered
    15 this before, but did she have a bath that
    16 day, Christmas Day?
    17 MR. WOOD: You have asked that
    18 before, several times.
    19 Q. (By Mr. Kane) What was the
    20 answer? Can you refresh my memory?
    21 MR. WOOD: You know that I'm sure
    22 better than I do.
    23 MR. KANE: Oh, come on, Lin, I
    24 was just asking a question so that I can
    25 follow up on the thing. If you are going
    1 to start getting into you asked that one
    2 time, I just don't have a recollection of
    3 it.
    4 MR. WOOD: Sure I am. Calm
    5 down.
    6 Q. (By Mr. Kane) Did she have a
    7 bath that day?
    8 MR. WOOD: Excuse me one second,
    9 Patsy. Calm down, Michael. I am not trying
    10 to create a problem for you.
    11 MR. KANE: You certainly are.
    12 MR. WOOD: No, I am not.
    13 MR. KANE: You certainly are.
    14 MR. WOOD: Let me finish. I am
    15 not going to interrupt you. Please don't
    16 interrupt me.
    17 The fact that you know it has
    18 been asked --
    19 MR. KANE: I don't know that it
    20 has been asked.
    21 MR. WOOD: Are you going to let
    22 me finish?
    23 MR. KANE: No, because I did not
    24 say that --
    25 MR. WOOD: Then let's take a
    1 break, and when you can let me speak without
    2 being interrupted, we'll start again.
    3 MR. KANE: You mischaracterized
    4 what I said. I said I don't remember if it
    5 has been asked. Forgive me if it was.
    6 MR. WOOD: Let me go back and
    7 let's look at it.
    8 It is not clear. Why don't we
    9 take a break and look and see if it has
    10 been asked.
    11 MR. KANE: We don't need to take
    12 a break. It is just a simple question.
    13 MR. WOOD: Listen. All of the
    14 questions should be simple.
    15 MR. KANE: It is a very simple
    16 question. Did she have a bath that day?
    17 MR. WOOD: Right. But please
    18 remember that I have to make sure that we
    19 abide by what you requested.
    20 MR. KANE: Well.
    21 MR. WOOD: I really am going to
    22 take a break.
    23 MR. KANE: Go ahead. Make your
    24 speech.
    25 MR. WOOD: I am not making a
    1 speech.
    2 MR. KANE: That is exactly what
    3 you are doing, Lin.
    4 MR. WOOD: I am not making a
    5 speech. Chief Beckner asked us to come down
    6 here, you all to come out here to ask new
    7 questions about developments that have
    8 occurred since June of 1998 and information
    9 that has been obtained since June of 1998.
    10 And I am confident that the
    11 question about JonBenet taking a bath or a
    12 shower has been asked before, and I would
    13 simply say let's don't start, even when it
    14 seems like it is not important at the
    15 moment, let's don't start going down the road
    16 of asking questions that have been asked
    17 before because that is specifically what you
    18 and Chief Beckner told me you weren't going
    19 to do.
    20 And so I will be glad at a break
    21 to look that up and see if we can find the
    22 answer for you. And then we can come back,
    23 give her a chance to look and see what she
    24 said before, put that in the context of your
    25 question and she will answer the question if
    1 it is a new one.
    2 MR. KANE: Okay, so in other
    3 words what you are doing is, and just to
    4 make this clear, you're directing your client
    5 not to answer that until she's had a chance
    6 to go back and look to see whether she's
    7 asked and answered that before.
    8 MR. WOOD: No. It's really more
    9 of a chance for you and I to look and see
    10 if she's answered it.
    11 MR. KANE: You are directing her
    12 not to answer the question?
    13 MR. WOOD: I am asking you to --
    14 MR. KANE: No. Are you directing
    15 her not to answer the question?
    16 MR. WOOD: I am asking you to,
    17 in the spirit of why you all wanted to come
    18 here and we agreed for you to come here
    19 about new questions on information developed
    20 or obtained since June of 1998, I am asking
    21 you, on what appears even to you to be a
    22 situation where it probably was asked in June
    23 or, if not, April of '97, to let's take a
    24 time at a break. You're well prepared here.
    25 You've looked at this.
    1 MR. KANE: All right.
    2 MR. WOOD: If she has been asked
    3 that, then you will have your answer. And
    4 if she hasn't been asked that, then she will
    5 give you that answer today; although, I don't
    6 know why you wouldn't have asked her that
    7 before.
    8 MR. KANE: So you are directing
    9 her not to answer that question?
    10 MR. WOOD: I am asking you to
    11 defer it.
    12 MR. KANE: Yes or no, are you
    13 directing her not to answer the question?
    14 MR. WOOD: I am asking you to
    15 defer it, Michael. That's all.
    16 MR. KANE: Let me, let me just
    17 say something. We are down here to solve a
    18 murder. Are you telling me that you are
    19 going to tell her not to answer that
    20 question, whether it has anything to do with
    21 this murder, you are directing her not to
    22 answer that question?
    23 MR. WOOD: I have not direct --
    24 MR. KANE: Because of some,
    25 because of some rule that has been
    1 established for this?
    2 MR. WOOD: Are you through?
    3 MR. KANE: Yeah.
    4 MR. WOOD: I understand that you
    5 are investigating a murder. Do you
    6 understand that I understand that?
    7 MR. KANE: I hope you do.
    8 MR. WOOD: I understand it, Mr.
    9 Kane. Now listen to me.
    10 I was asked, and my clients
    11 agreed to answer new questions about
    12 information that has been obtained since June
    13 of 1998 after three full days of interviews
    14 which had been followed by April of 1997 in
    15 almost a full day of an interview by Patsy
    16 Ramsey, new questions about new information
    17 since June of 1998 or developments that have
    18 come up since June of 1998.
    19 That was the request made by
    20 Chief Beckner. That was what we agreed to
    21 do because that is what we were asked to do.
    22 Now, if you want to change the
    23 format, then let's consider that after we
    24 finish this format. But I didn't ask Patsy
    25 Ramsey or John Ramsey to go back and study
    1 what they had said before to try to memorize
    2 it or refresh their recollections, period,
    3 because it was represented to me that you
    4 weren't going to do that.
    5 So if you do it, I am not really
    6 directing her not to answer it. I am
    7 directing you that you are outside of the
    8 scope of your request and, therefore, your
    9 question is not fair and appropriate. It is
    10 as simple as that. I am not trying to be
    11 difficult.
    12 MR. KANE: If that is your
    13 definition of what is fair, then that is
    14 fine. All right. You've made your record.
    15 I withdraw that question.
    16 MR. WOOD: I think it is very
    17 fair. I made my statement. It is not
    18 meant to be a record, necessarily.
    19 Q. (By Mr. Kane) Here's a question
    20 that was not asked, Mrs. Ramsey. Did you
    21 dress JonBenet Christmas Day?
    22 A. I can't remember.
    23 Q. (By Mr. Levin) Mrs. Ramsey, do
    24 you know whether or not she changed her
    25 underwear Christmas Day?
    1 A. I don't know.
    2 Q. We are going to assume the fact
    3 that she did not take a bath because you
    4 previously stated that. Would she change her
    5 underwear if she didn't take a bath on
    6 Christmas Day?
    7 MR. WOOD: Excuse me. You
    8 remember that she has been asked that now.
    9 MR. LEVIN: I have known that.
    10 MR. WOOD: Why didn't he know
    11 that?
    12 MR. LEVIN: I can't speak for Mr.
    13 Kane.
    14 MR. KANE: I don't have a big
    15 catalog of every single question and answer.
    16 MR. LEVIN: I don't either. I
    17 can assure you Mr. Kane knows many facts I
    18 don't know.
    19 MR. WOOD: Well, you all planned
    20 the interview. You have got him over here
    21 claiming he doesn't know if a question's been
    22 asked. Why didn't you pop up and look over
    23 and say she had answered that.
    24 MR. LEVIN: I didn't want to
    25 interrupt you, Mr. Wood. You were very
    1 upset.
    2 MR. WOOD: I am not upset.
    3 MR. LEVIN: You were upset that
    4 you were interrupted by Mr. Kane.
    5 MR. WOOD: I'm upset that when I
    6 tried to speak I was interrupted, but why
    7 didn't you look over and say, Mitch, I mean,
    8 Michael, she has answered that.
    9 MR. LEVIN: I was just going to
    10 let each of you speak and then ask my
    11 question.
    12 Q. (By Mr. Levin) Do you know if
    13 she changed her underwear?
    14 A. I do not know.
    15 Q. Would it be her routine habit or
    16 practice, if she is going out for dinner at
    17 friends, for her to change from head to toe,
    18 including her underwear, getting dressed to
    19 go out for the evening, even if she didn't
    20 take a bath?
    21 A. I don't know that there is any
    22 particular routine. She may have. I don't
    23 know.
    24 Q. If she listened to mom, would she
    25 have done that? I mean, we are going out,
    1 you change from head to toe, wash up?
    2 MR. WOOD: You are saying if she
    3 had said that?
    4 MR. LEVIN: No. I am saying,
    5 this child was raised by Mrs. Ramsey, and I
    6 am assuming that, in the course of your
    7 raising your child, that it was JonBenet, we
    8 are going out, even if she hadn't taken a
    9 bath, you wash up, you change your clothes,
    10 and that would include if she hasn't bathed,
    11 change your underwear because she is running
    12 around and playing all day.
    13 MR. WOOD: Are you stating that
    14 is what you do with your children?
    15 MR. LEVIN: No. I am asking
    16 her.
    17 THE WITNESS: I don't, I don't
    18 remember the course of events --
    19 MR. LEVIN: Okay.
    20 THE WITNESS: - really.
    21 Q. (By Mr. Levin) So you just don't
    22 know whether or not she changed her
    23 underpants?
    24 A. I don't know.
    25 Q. During the course of one of the
    1 prior interviews, I think it was '98, but I
    2 am not certain, you were asked and stated
    3 that, on occasion, she would leave her
    4 underclothes at a friend's house if they had
    5 gone swimming or gotten wet. Do you
    6 remember that?
    7 MR. WOOD: Hold on. Do you have
    8 a copy of that?
    9 MR. LEVIN: I don't have it right
    10 here.
    11 MR. WOOD: I mean, I asked you
    12 all to be able to produce those prior
    13 statements so we can look at it in context.
    14 MR. LEVIN: We've got it in the
    15 computer. Mr. Wood, I will represent to you
    16 that that is a statement that your client
    17 made. I have a clear recollection. I am
    18 not -- this is not an attempt to make her
    19 -- I am developing a question that assumes
    20 that to be true. I will represent to you
    21 that, to a near certainty, as certain as
    22 someone can be, in reviewing statements and
    23 working on this case for two years, I
    24 believe that statement to be made. And I am
    25 not trying to trick you or your client. I'm
    1 trying - as Mr. Kane said, I am here to
    2 try to solve the murder of a young child.
    3 And I'm not --
    4 MR. WOOD: We are here to help
    5 you.
    6 MR. LEVIN: And I understand that
    7 and I appreciate that.
    8 MR. WOOD: Within the request as
    9 made and the request as agreed to.
    10 MR. LEVIN: I understand that.
    11 And if you were a judge, I would look you
    12 in the eye and say as an officer of the
    13 court, Your Honor, I have no -- I believe in
    14 my heart that statement was made. Okay?
    15 MR. WOOD: And the judge would
    16 look at you, Bruce, and say, Mr. Levin, it
    17 is your responsibility, when asking about a
    18 prior statement, to produce the statement for
    19 the witness to look at to put it into
    20 context. Am I right, Mr. Levin? That is
    21 all I asked you to do.
    22 MR. LEVIN: My judge would take
    23 my word because my word is my bond, sir.
    24 MR. WOOD: Well, my judge would
    25 say the proper examination would give the
    1 witness an opportunity, not only to take your
    2 statement as you set it forth, which you
    3 admit may or may not be exactly accurate,
    4 but to take that statement and look at it in
    5 context because I don't know what question
    6 you will necessarily follow up with, Bruce.
    7 That is all. We are not judges. We are
    8 lawyers. But I did ask Chief Beckner, if
    9 there were going to be prior statements for
    10 you all to bring them so that we could look
    11 at them and put her, put them into context.
    12 That is all.
    13 MR. LEVIN: And we have them. If
    14 you want to take time --
    15 Q. (By Mr. Levin) I mean, there is
    16 a simple way. You recall saying that, don't
    17 you? Isn't that the easy way to do it?
    18 MR. WOOD: That may be fine, but
    19 I think she is entitled to see it anyway.
    20 That is all I am saying so she can look at
    21 it.
    22 MR. LEVIN: If I was in a
    23 courtroom and she was under oath. It is not
    24 a deposition. This is an interview. That
    25 is all.
    1 MR. WOOD: She is not. It's an
    2 interview. And all I asked going into the
    3 interview is, if this came up, because there
    4 has been so many hours and days of
    5 interviews and statements that, fairly, now
    6 two years plus since June of 1998, three
    7 years plus since April of 1997, that if
    8 there is statements, media or otherwise, put
    9 them out there, she will look at it, she
    10 will answer your question.
    11 MR. LEVIN: Why don't we just ask
    12 her if she recalls it, and then we can save
    13 some time.
    14 MR. WOOD: Well, we can ask her
    15 that, and I will let her answer that, Bruce,
    16 but I want to set the procedure correctly
    17 that, when we get into these things about
    18 prior statements, that I really did expect
    19 and think it fair that you all have them for
    20 her to look at it and put it into context.
    21 It may not be of consequence here, but it
    22 certainly may be later when there are more
    23 difficult questions. Okay?
    24 MR. LEVIN: I understand.
    25 Q. (By Mr. Levin) Do you remember
    1 saying that during one of your interviews?
    2 A. Tell me what --
    3 Q. That on occasion JonBenet may go
    4 over to a friend's house, I think you talked
    5 about the White's daughter Daphne, and they
    6 could go swimming or do something and she
    7 might leave her underwear there, get a clean
    8 pair from a friend and then be laundered,
    9 returned, you would do the same for her
    10 girlfriends who may have been -- got wet
    11 from swimming or doing, got dirty playing
    12 outside. Do you recall saying that?
    13 A. Not specifically.
    14 Q. Do you recall that occurring then?
    15 A. Probably did. I can't say for
    16 sure, but --
    17 Q. Okay. What I am interested in is
    18 whether or not you have a recollection as to
    19 whether or not any of the Bloomi panties,
    20 and I certainly wouldn't want to pin you
    21 down to the day or the week, all right, but
    22 do you ever recall any of the Bloomi panties
    23 from November to the time of JonBenet's
    24 murder being left at a friend's house and
    25 then returned to you?
    1 A. No.
    2 Q. Do you recall any occasions where
    3 JonBenet had an accident at school and -- I
    4 know that they kept at her school like I
    5 think they do at most grammar schools, they
    6 have a box of like clean underpants if a kid
    7 has an accident at school, do you ever
    8 remember her getting to that situation and
    9 borrowing panties from the school and having
    10 to return them?
    11 A. No.
    12 Q. Okay. I am slightly confused,
    13 and I would like this clarified. When I
    14 first started to ask you about the purchase
    15 of the panties in November, I got the
    16 impression that you were somewhat unclear as
    17 to whether you bought two sets or one.
    18 In follow-up questions, I got the
    19 impression that you felt confident that you
    20 only bought one. Do you know?
    21 A. I really can't remember.
    22 Q. Do you recall that you did -- you
    23 never mailed this pair out to --
    24 A. Jenny, yes.
    25 Q. Okay. So if there was an
    1 unopened package, it would have been left in
    2 the house?
    3 A. Yes.
    4 Q. (By Mr. Morrissey) Mrs. Ramsey,
    5 prior to going to the Whites, did you see
    6 JonBenet in panties? In other words, were
    7 you at any point, prior to going to the
    8 Whites, in the process of her getting
    9 dressed, did you ever see if she was wearing
    10 panties?
    11 A. I mean, I just probably didn't
    12 notice. I would, she must have had them on
    13 or I would have certainly noticed if she
    14 didn't have any on.
    15 Q. When you came home and you got
    16 her ready for bed, did you notice if she was
    17 wearing panties? When you changed her out
    18 of the black velvet --
    19 A. Uh-huh (affirmative).
    20 Q. - type pants --
    21 A. Right.
    22 Q. -- and into the long underwear
    23 pants --
    24 A. Uh-huh, right.
    25 Q. -- the White ones, did you notice
    1 if she had a pair of panties on?
    2 A. Yes, she did. I believe she did.
    3 Q. Why do you remember that? I
    4 mean, what do you remember? I just want to
    5 know what you remember about that.
    6 A. Well, I took the jeans off and
    7 put the long leggies on.
    8 Q. And you noticed that she had
    9 panties on in that process?
    10 A. Uh-huh (affirmative).
    11 Q. You have to answer yes or no.
    12 A. Well, I noticed -- I mean,
    13 nothing was unusual. I mean, if she hadn't
    14 had panties on, it would have been unusual.
    15 So --
    16 Q. So there was nothing unusual
    17 there?
    18 A. Correct.
    19 Q. When you actually removed those --
    20 you have -- they are black velvet pants?
    21 A. Yes.
    22 Q. And did the panties come down
    23 with them when you removed those pants, if
    24 you remember?
    25 A. I don't remember.
    1 Q. If they had, would you remember,
    2 or is that too long ago?
    3 A. It has been a long time.
    4 Q. But did you change -- did you put
    5 a fresh pair of panties on her at that point
    6 when you were getting her ready for bed?
    7 A. No.
    8 Q. (By Mr. Wickman) Mrs. Ramsey, I
    9 have a daughter myself, and kids do strange
    10 things, but was it her habit, when she
    11 changed clothes, did she have a routine to
    12 put them in a basket if they were dirty?
    13 How did that work?
    14 A. She usually probably dropped them
    15 wherever they came off.
    16 MR. WICKMAN: Okay. Thank you.
    17 Q. (By Mr. Levin) Was that pretty
    18 much her practice with most of her clothes?
    19 A. Uh-huh (affirmative).
    20 Q. I mean, not just her underwear,
    21 just they are off, new pair?
    22 A. (Witness nodded head
    23 affirmatively).
    24 MR. WOOD: Wait until he
    25 finishes and then answer.
    1 Q. (By Mr. Levin) For the record,
    2 you were nodding your head, and I take that
    3 as a yes.
    4 A. Yes.
    5 MR. LEVIN: Anything else on that
    6 topic?
    7 MR. KANE: No. Go ahead.
    8 Q. (By Mr. Levin) Mrs. Ramsey, I
    9 would like to ask you some questions on an
    10 area that actually you started to talk about
    11 when we were talking about the investigation
    12 being conducted at your behest, and that is
    13 the Hi-Tec shoes.
    14 You are, I would assume, aware of
    15 the fact that there is a Hi-Tec shoe
    16 impression in the wine cellar?
    17 A. Yes, I am.
    18 Q. How did you become aware of that,
    19 if you can recall?
    20 A. I don't remember if I read it in
    21 the paper or one of our lawyers told us.
    22 Q. Was it something you have been
    23 aware of for a substantial period of time,
    24 though?
    25 A. Yes.
    1 Q. And do you recall, I know you had
    2 several conversations with Lou Schmidt or
    3 other investigators working for you, is it
    4 something, prior to your interviews in 1998,
    5 that you had discussed either with your
    6 lawyers or with your investigators? And I
    7 don't want to know about the conversations
    8 between you and your attorneys, obviously,
    9 but something that you talked about?
    10 A. I can't remember if I knew about
    11 it before then or not.
    12 Q. When you were interviewed in 1998
    13 by the Boulder D.A.'s office and some of
    14 their helpers, were you at that time aware
    15 of the fact that the Hi-Tec existence or non
    16 existence of an identifiable source for the
    17 Hi-Tec shoes was something that seemed to be
    18 important to the investigation?
    19 A. Are you asking me if they were
    20 wanting to know if I knew anyone with Hi-Tec
    21 boots?
    22 Q. No. What I'm ask --see, I am
    23 talking like a lawyer. Let's see if we can,
    24 I'll talk like a person, if I can. You
    25 were interviewed --
    1 MR. WOOD: That assumes that
    2 lawyers are people. Some would disagree that
    3 they are sharks or whatever.
    4 Q. (By Mr. Levin) In June of 1998,
    5 you were interviewed by the Boulder D.A.'s
    6 office; right?
    7 A. That was Hannay, Mr. Hannay.
    8 Q. Yes. Mr. DeMouth?
    9 A. Yes.
    10 Q. Prior to commencing that
    11 interview, did you know that identifying the
    12 source of the Hi-Tec shoes was a priority
    13 for the investigation? That would be more
    14 than two years after, a year and a half
    15 after your daughter's murder.
    16 MR. WOOD: Are you asking her if
    17 she knew what was a priority in your all,
    18 the investigator's minds?
    19 MR. LEVIN: No, no, no. In her
    20 mind. Did she believe --
    21 Q. (By Mr. Levin) Did you believe,
    22 and if I didn't throw that in, I thought it
    23 was clear, did you believe that, in the
    24 course of the investigation, that identifying
    25 the source of the Hi-Tec shoes was important?
    1 A. Well, I would think it is
    2 important, yes. I mean, I can't remember at
    3 that time if I knew about the Hi-Tec shoes
    4 or not. I don't remember when all that
    5 surfaced.
    6 Q. You have since then, since 1998,
    7 become aware that the source of the Hi-Tec
    8 shoes is important?
    9 A. Yes.
    10 Q. You know that today?
    11 A. Yes.
    12 Q. And you thought that one of the
    13 things that made Helgoth viable was the fact
    14 that you believe he had Hi-Tec shoes?
    15 A. Correct.
    16 Q. Have you, whether it was before
    17 the interview in 1998 or subsequent to the
    18 interview in 1998, have you personally made
    19 attempts to find possible sources for the
    20 Hi-Tec shoe impression?
    21 A. You mean like ask around if
    22 anybody had --
    23 Q. Pick up the phone and call some
    24 friends, for example.
    25 A. I didn't, no.
    1 Q. Had you at any time, for example,
    2 some of the kids, like the Colby kids ever
    3 come over, did you ever go and just pick up
    4 the phone or walk across the alley and say,
    5 do you guys have Hi-Tec shoes? Did you ever
    6 do anything like that?
    7 MR. WOOD: You are assuming she
    8 may have learned about it at the time she
    9 still lived there. She told you she wasn't
    10 sure when she first learned that.
    11 THE WITNESS: No, I did not call
    12 the Colbys to ask if their children had --
    13 Q. (By Mr. Levin) Whether it was
    14 from Boulder or Atlanta?
    15 A. Right.
    16 Q. Okay. Did you sit down and
    17 discuss with Burke at any length whether or
    18 not he ever had Hi-Tec shoes?
    19 A. No.
    20 Q. Did it cross your mind that he
    21 might be the source of that, for the Hi-Tec
    22 shoes?
    23 A. No. Because my understanding was
    24 that it was an adult footprint. He was nine
    25 years old at the time.
    1 Q. Do you know the source of your
    2 belief that it was an adult's foot,
    3 footprint?
    4 A. Whoever told me about it or
    5 wherever I learned it in the first place.
    6 Q. Did you get any details concerning
    7 how much of a shoe impression was present?
    8 A. No. It was just a footprint.
    9 Q. Did you take that to, to be a
    10 full footprint, and by that I mean like a
    11 shoe, a complete shoe impression?
    12 A. That is what I imagined, yes.
    13 Q. And that, whether you were told
    14 that directly or you just assumed that, you
    15 believe is the source of your belief that it
    16 was an adult's shoe?
    17 A. Yes.
    18 Q. You have been asked about whether
    19 or not anyone in your family owns Hi-Tec
    20 shoes or ever owned Hi-Tec shoes?
    21 A. Yes.
    22 Q. And I am not restating a
    23 question, Mr. Wood. And do you recall you
    24 said no one ever did?
    25 A. Yes.
    1 Q. You have had -- and that was in
    2 '98, more than two years ago. You have had
    3 an opportunity to, now that you are in
    4 possession of knowledge causing you to
    5 believe this is a significant fact in the
    6 investigation, you have had almost, we will
    7 assume, at least a year to rethink that.
    8 Have you given it some thought as to maybe
    9 someone in the family had Hi-Tec shoes?
    10 MR. WOOD: Are you asking her
    11 whether she thought about whether somebody in
    12 the family -- I mean, all of the prefatory
    13 comments leading up to that.
    14 Is the question, since June of
    15 1998, Ms. Ramsey, have you given any thought
    16 as to whether someone in your family had
    17 Hi-Tec shoes?
    18 MR. LEVIN: That is correct.
    19 That is the question.
    20 MR. WOOD: All right. You can
    21 answer that question.
    22 THE WITNESS: No.
    23 Q. (By Mr. Levin) Did you try, in
    24 your mind, and perhaps to assist your
    25 investigator, identify sources close to your
    1 family that might be the origin of the
    2 Hi-Tec shoe impression?
    3 A. I think, you know, I may have
    4 asked Susan if she had ever seen any. I
    5 mean, I didn't, I don't know what a Hi-Tec
    6 boot looks like, per se. I have tried to
    7 kind of, as I am in shoe stores, look around
    8 trying to see what, what's the significance
    9 and special about a Hi-Tec boot, and I
    10 haven't, haven't even seen any yet. But I
    11 may have asked Susan, did you know anybody
    12 that looked like they wore Hi-Tec shoe,
    13 boots, or whatever.
    14 Q. Do you recall a period of time,
    15 prior to 1996, when your son Burke purchased
    16 a pair of hiking boots that had compasses on
    17 the shoelaces? And if it helps to
    18 remember --
    19 A. I can't remember.
    20 Q. Maybe this will help your
    21 recollection. They were shoes that were
    22 purchased while he was shopping with you in
    23 Atlanta.
    24 MR. WOOD: Are you stating that
    25 as a fact?
    1 MR. LEVIN: I am stating that as
    2 a fact.
    3 Q. (By Mr. Levin) Does that help
    4 refresh your recollection as to whether he
    5 owned a pair of shoes that had compasses on
    6 them?
    7 A. I just can't remember. Bought so
    8 many shoes for him.
    9 Q. And again, I will provide, I'll
    10 say, I'll say this as a fact to you, that,
    11 and maybe this will help refresh your
    12 recollection, he thought that -- the shoes
    13 were special because they had a compass on
    14 them, his only exposure for the most part to
    15 compasses had been in the plane and he kind
    16 of liked the idea of being able to point
    17 them different directions. Do you remember
    18 him doing that with the shoes?
    19 A. I can't remember the shoes. I
    20 remember he had a compass thing like a
    21 watch, but I can't remember about the shoes.
    22 Q. You don't remember him having
    23 shoes that you purchased with compasses on
    24 them?
    25 MR. WOOD: She will tell you that
    1 one more time. Go ahead and tell him, and
    2 this will be the third time.
    3 THE WITNESS: I can't remember.
    4 Q. (By Mr. Levin) Okay. Does it
    5 jog your memory to know that the shoes with
    6 compasses were made by Hi-Tec?
    7 MR. WOOD: Are you stating that
    8 as a fact?
    9 MR. LEVIN: Yes. I am stating
    10 that as a fact.
    11 THE WITNESS: No, I didn't know
    12 that.
    13 Q. (By Mr. Levin) I will state this
    14 as a fact. There are two people who have
    15 provided us with information, including your
    16 son, that he owned Hi-Tec shoes prior to the
    17 murder of your daughter.
    18 MR. WOOD: You are stating that
    19 Burke Ramsey has told you he owned Hi-Tec
    20 shoes?
    21 MR. LEVIN: Yes.
    22 MR. WOOD: He used the phrase
    23 Hi-Tec?
    24 MR. LEVIN: Yes.
    25 MR. WOOD: When?
    1 MR. LEVIN: I can't, I can't give
    2 you the source. I can tell you that I have
    3 that information.
    4 MR. WOOD: You said Burke told
    5 you.
    6 MR. LEVIN: I can't quote it to
    7 you for reasons I am sure, as an attorney,
    8 you are aware.
    9 MR. WOOD: Just so it is clear,
    10 there is a difference between you saying that
    11 somebody said Burke told them and Burke
    12 telling you because Burke has been
    13 interviewed by you all December of 1996,
    14 January of 1997, June of 1998.
    15 Are you saying that it is within
    16 those interviews?
    17 MR. LEVIN: No.
    18 MR. WOOD: So he didn't tell you,
    19 he told somebody else you are stating as a
    20 fact because I don't think you all have
    21 talked to him other than those occasions,
    22 have you?
    23 MR. KANE: Mr. Wood, we don't
    24 want to get into grand jury information.
    25 Okay?
    1 MR. WOOD: Okay.
    2 MR. KANE: Fair enough?
    3 MR. LEVIN: I am sorry, I should
    4 have been more direct. I thought you would
    5 understand --
    6 Q. (By Mr. Levin) Fleet Junior also
    7 says that he had Hi-Tec shoes.
    8 A. Okay. Now --
    9 Q. Does that jog your memory?
    10 A. Is, are you talking like Hi-Tec
    11 like --
    12 Q. The brand name.
    13 A. These are really high tech or the
    14 brand name? Did the children understand the
    15 difference, or are they --
    16 Q. I was talking brand name.
    17 A. They knew like a brand name like
    18 Nike, whatever?
    19 Q. Yes, yes, ma'am.
    20 A. Okay.
    21 Q. That doesn't jog your recollection
    22 at all?
    23 A. No.
    24 MR. WOOD: You are answering no
    25 for the reporter?
    1 THE WITNESS: No, it does not.
    2 MR. WOOD: You gave it a nod of
    3 the head.
    4 Q. (By Mr. Morrissey) Just so we
    5 are clear, these boys may have referred to
    6 them as boots. Does that make any
    7 difference to you as far as distinguishing
    8 between shoes and boots?
    9 MR. WOOD: She would have to see
    10 what those boys said in context, in all
    11 fairness, Mitch, before she can comment on
    12 what they might have meant and how it
    13 affects her.
    14 THE WITNESS: I mean, I just, I
    15 can't remember shoes with compasses, and I
    16 don't know all of the brand names of all the
    17 shoes that I buy for my children. So --
    18 Q. (By Mr. Morrissey) And I am just
    19 asking do you remember a pair of boots with
    20 compasses?
    21 MR. WOOD: For the fourth time
    22 now.
    23 THE WITNESS: I don't remember
    24 compasses on any shoes.
    25 MR. WOOD: Fair enough. Shoes,
    1 boots, compasses.
    2 THE WITNESS: I have a picture in
    3 my mind of a compass on a watch, but --
    4 Q. (By Mr. Morrissey) Shoes, boots,
    5 you don't remember a compass on footwear?
    6 A. No, I can't.
    7 CHIEF BECKNER: I have a
    8 follow-up question.
    9 Q. (By Chief Beckner) You said you
    10 had never seen the photograph of a footprint?
    11 A. Right.
    12 Q. Have you seen some of the crime
    13 scene photos?
    14 A. I have seen photographs of her
    15 bedroom, and I think I have seen photographs
    16 of the downstairs bathroom, basement bathroom.
    17 A few.
    18 Q. (By Mr. Levin) Just to follow-up
    19 on Chief Beckner's --
    20 MR. WOOD: You all asked her, you
    21 all gave her a ton of photographs in June.
    22 MR. LEVIN: Right, and that's
    23 what I was going to ask her, if you've seen
    24 photos.
    25 Q. (By Mr. Levin) I mean, they
    1 spent days, day and a half going through
    2 photographs with you. Other than in that
    3 setting in June of '98, have you ever been,
    4 have you ever had a sit down with someone
    5 and gone through some of the crime scene
    6 photographs other than that, that particular
    7 experience, which we don't need to rehash?
    8 A. I don't think so. No.
    9 Q. (By Chief Beckner) Lou Smith has
    10 never shown you any photographs that he has?
    11 A. I can't remember if he has. I
    12 am sure I would have remembered if they
    13 were.
    14 Q. How about Ellis Armistead?
    15 A. I just can't remember.
    16 Q. Ollie Gray?
    17 A. No.
    18 Q. Any of your attorneys?
    19 MR. WOOD: Well, you are going
    20 into what attorneys may have shown her, I
    21 think that may be infringing into the
    22 attorney-client privilege. I don't want to
    23 go there.
    24 THE WITNESS: I can't, I mean, if
    25 you would show me something and say have you
    1 seen this before, maybe I can remember if I
    2 have seen it before.
    3 Q. (By Chief Beckner) You just
    4 don't recall sitting down and having any of
    5 your investigators show you any photos?
    6 MR. WOOD: Well, you were asking
    7 about crime scene photos, Chief, I thought.
    9 THE WITNESS: They have shown me
    10 photos of people and said do you recognize
    11 this person.
    12 Q. (By Chief Beckner) Okay. I am
    13 specifically referring to photos taken inside
    14 the house or outside the house.
    15 A. Yeah. Right. Well, certainly
    16 when we did that interview.
    17 Q. Yeah, I am not talking about the
    18 photos we showed you.
    19 A. Yeah.
    20 Q. I am just asking -
    21 A. Other ones.
    22 Q. - other photos that your
    23 investigators may have shown you.
    24 A. No.
    25 Q. (By Mr. Kane) You said at one
    1 point you might have asked Susan. Are you
    2 talking about Susan Stein?
    3 A. Uh-huh (affirmative).
    4 Q. You said you might have asked
    5 her. Do you have any recollection of asking
    6 her about Hi-Tec? Is there anything that
    7 makes you think that you might have asked
    8 that? What made you --
    9 A. Well, we just spent quite a lot
    10 of time together, and she is very interested
    11 in the case. And we kind of hung around
    12 the same people.
    13 Q. Uh-huh (affirmative).
    14 A. And I could have asked her, you
    15 know, do you know anybody with Hi-Tec boots
    16 or something.
    17 Q. But you don't have any specific
    18 recollection of that?
    19 A. I don't specifically remember
    20 saying that.
    21 Q. Okay. Is this the first time
    22 that you've heard that Burke says that he
    23 had Hi-Tec?
    24 A. Yes, it is.
    25 Q. This is the very first time?
    1 A. Yes.
    2 Q. When you said in your book and
    3 then you said at other times too that you
    4 didn't own either brand --
    5 MR. WOOD: Hold on. If you have
    6 got a reference of the book.
    7 MR. KANE: I'm sorry. Page 232.
    8 MR. WOOD: And then you said at
    9 other times, too. Be more specific to it.
    10 MR. KANE: Okay. Well, I will
    11 stick to the book.
    12 Q. (By Mr. Kane) But I don't think
    13 it is any big
    14 secret that you've said that a bunch of
    15 times.
    16 A. I don't remember --
    17 MR. WOOD: Okay. What is the
    18 question?
    19 Q. (By Mr. Kane) When you made that
    20 statement in your book -- I mean, maybe I
    21 ought to authenticate. You wrote this book,
    22 is that -
    23 A. Sure.
    24 MR. WOOD: We are not asking you
    25 to authenticate it. We are just asking you
    1 to refer us to the page.
    2 Q. (By Mr. Kane) Okay. Well, I
    3 just want to make it clear that this wasn't
    4 written by somebody else or a ghost writer
    5 or something like that.
    6 MR. WOOD: I think they had some
    7 help, but I don't think it was like Mr.
    8 Davis who wrote Mr. Thomas's book.
    9 THE WITNESS: I think we were
    10 referring that John or I didn't, did not
    11 ever have -- were not in possession of --
    12 Q. (By Mr. Kane) So when you said
    13 we, you were referring to John or you?
    14 A. Yes. It never occurred to me
    15 about Burke's shoes.
    16 MR. WOOD: You are assuming,
    17 number one, Burke said it. You said, and I
    18 accept your representation in terms of what
    19 is clear in terms of when, but the question
    20 obviously still remains whether Burke is
    21 accurate or not. But be that as it may,
    22 next question.
    23 Q. (By Mr. Kane) But I mean, but
    24 my question was, when you said we, you were
    25 talking about you or John?
    1 A. Well, what is the, what size
    2 print is the Hi-Tec? Is it a child's or is
    3 it an adult's?
    4 Q. I don't think there is any
    5 difference between the two. And I think
    6 that has been pretty well publicized too.
    7 MR. WOOD: Well, you all can
    8 debate that another day, if necessary.
    9 MR. KANE: Yeah, I mean. That
    10 is obvious, yes.
    11 MR. WOOD: The point is, it would
    12 probably be of some consequence to know the
    13 context of what Burke said, at age, at age,
    14 at age what?
    15 THE WITNESS: Nine.
    16 MR. KANE: Nine.
    17 MR. WOOD: No, he didn't say it
    18 at age nine.
    19 THE WITNESS: Eight.
    20 MR. WOOD: You are telling me he
    21 said it sometime late fall of 1999, and I
    22 think his age would have been closer in the
    23 neighborhood of 12.
    24 MR. LEVIN: I think 11 going on
    25 12.
    1 MR. WOOD: No, I think he turned
    2 13 January of 2000. So he was 12, and it
    3 was some three years after the murder of his
    4 sister, if that is when he first said it.
    5 THE VIDEOGRAPHER: Pardon me. We
    6 need to make a tape change.
    7 (A recess was taken.)
    8 THE VIDEOGRAPHER: All right.
    9 Q. (By Mr. Kane) I just want to
    10 follow up, Mrs. Ramsey. How many times have
    11 you spoken with Lou Schmidt personally?
    12 Let's put it this way, since the grand jury
    13 ended to narrow it down.
    14 A. Oh, half a dozen.
    15 Q. Was that here in Atlanta or back
    16 in Colorado or both?
    17 A. Both.
    18 Q. During any of those discussions,
    19 did you ever talk about the Hi-Tec shoeprint
    20 that was found?
    21 A. Probably. Not -- I can't
    22 remember specifically what we talked about
    23 each time.
    24 Q. Okay. I mean, what was your,
    25 were your -- the times that you did talk to
    1 him, was it about the investigation or about
    2 evidence and that kind of thing or was it
    3 more social? Maybe that is an unfair
    4 question.
    5 MR. WOOD: That is a bunch of
    6 things. I think he wants to know what you
    7 talked to him about, generally.
    8 Q. (By Mr. Kane) Did you talk about
    9 the investigation?
    10 A. Yes.
    11 Q. Okay. But you don't have any
    12 recollection of the shoeprint being part of
    13 those discussions; is that what you are
    14 saying?
    15 A. Well, not specifically. I am
    16 sure we talked about it. I mean, you know,
    17 I've just heard many references made to the
    18 Hi-Tec shoeprint.
    19 Q. Okay. I think you said that you
    20 don't recall whether Lou showed you any
    21 photographs. Did he ever show you, on a
    22 computer image, of any of the photographs?
    23 A. I think so.
    24 Q. Have you seen a photograph of the
    25 Hi-Tec shoeprint yourself?
    1 A. I can't remember. I have this
    2 vague image, but I don't know whether I am
    3 imagining it in my mind or if I saw the
    4 picture.
    5 Q. (By Mr. Levin) Mrs. Ramsey, on,
    6 I believe it was Saturday the 28th of
    7 December, your sister Pam went and was
    8 permitted to take personal property out of
    9 the house. Do you recall that?
    10 A. Yes.
    11 Q. Can you give us -- and again I
    12 don't want to be unfair to you. I am not
    13 certainly expecting you to itemize what came
    14 out, but can you just give us kind of an
    15 overview of what you recall what types of
    16 things were brought out?
    17 MR. WOOD: Let me just ask, in
    18 fairness to the request, isn't that long
    19 since knowledge? We are talking about
    20 developments and information since June of
    21 1998. I mean, that seems to me you all
    22 were aware of that long ago, discussed in
    23 Thomas's book.
    24 MR. LEVIN: Well, I haven't read
    25 Thomas's book, and to be perfectly honest
    1 with you, Mr. Wood, we are not exactly
    2 certain what was taken out of the house.
    3 And there are some things, some specific
    4 things I am going to get into, but I am
    5 trying to get a sense beyond what is
    6 documented in the police reports of what came
    7 out of the house.
    8 And I think it is helpful for the
    9 investigation. I think it will move things
    10 forward.
    11 MR. WOOD: Well, I am going to
    12 let her answer. I just wanted to make sure
    13 that it was clear that, in my mind, that
    14 would not, would not be -- I am going to
    15 let her go, I am going to let her answer
    16 the question, but it does go back to areas
    17 that clearly were available for examination
    18 for three days.
    19 MR. KANE: Let's clarify that. I
    20 am under the understanding that you said the
    21 purpose of this was to ask new questions
    22 which means we are not going to plow old
    23 ground again, but there are certainly a lot
    24 of questions that have developed that involve
    25 evidence that may have been known day one.
    1 MR. WOOD: I understand that. I
    2 am trying, I'm going to be, I'm going to be
    3 extremely liberal in the definition of events
    4 that have occurred since or developed since
    5 or information developed since with the
    6 emphasis in my mind on what was asked in
    7 terms of new questions. So I am going to
    8 let her answer that. But I did want to
    9 just make it clear that that was something
    10 that you all I thought had known about from
    11 long ago.
    12 MR. LEVIN: I am unaware of it.
    13 MR. WOOD: Do you want to restate
    14 it or, Patsy, I will read it back to you.
    15 He said, can you give us, and again, I don't
    16 want to be unfair to you, I'm certainly not
    17 expecting you to itemize what came out, but
    18 can you just give us kind of an overview of
    19 what you recall what kinds of things were
    20 brought out. Do you understand the question?
    21 If you know the answer, go ahead and answer
    22 it for him.
    23 THE WITNESS: I think the kinds
    24 of things that were brought out were --
    25 well, Pam asked me, what did I need from the
    1 house. And I told her the only thing I
    2 cared about in that house were my things in
    3 the little baby curio cabinet where I kept
    4 the children's baby shoes and christening
    5 gown and locks of hair and little special
    6 little things. And aside from that, I don't
    7 know what came out.
    8 I know that there is a list
    9 because she didn't take anything that wasn't,
    10 you know --
    11 MR. WOOD: Inventoried.
    12 THE WITNESS: -- inventoried as
    13 she --
    14 Q. (By Mr. Levin) Did you provide
    15 her, you personally or John at your request
    16 or some third party at either your or John's
    17 request, did you provide a list of clothing
    18 that you needed, that you had an immediate
    19 need for that you asked for?
    20 A. No.
    21 Q. She brought, she did bring
    22 articles of clothing out though?
    23 A. I don't know that she did. I
    24 don't know.
    25 Q. Just so that I am clear, what you
    1 are saying is you just don't have a present
    2 recollection of whether or not she brought
    3 clothes out, not that she did not; is that
    4 right?
    5 A. I don't know whether she did or
    6 not. I know Susan Stein had to go out to
    7 -- she said that she went to Foley's to buy
    8 me some clothes and some shoes because I
    9 didn't have any, so -- except what I had on
    10 leaving the house, so --
    11 Q. After the funeral, you move back
    12 to Atlanta, that house is packed -- and the
    13 police released the house back to the family
    14 after they finished their search, the
    15 contents is packed up and shipped to Atlanta;
    16 is that what happened?
    17 A. Yes.
    18 Q. So anything not taken out by your
    19 sister Pam or seized by the Boulder Police
    20 Department during their search was returned
    21 to you?
    22 A. I think so. I don't know if our
    23 -- I think our investigators spent time in
    24 the house after the police investigators were
    25 finished. I don't know. They may have
    1 taken some things.
    2 Q. Were there things that your
    3 investigators took that was done at your
    4 direction or John's direction that you are
    5 aware of?
    6 MR. WOOD: Are you talking about
    7 a specific request for an investigator to get
    8 something?
    9 MR. LEVIN: Yes.
    10 Q. (By Mr. Levin) For example, take
    11 this particular coat, it might be important,
    12 or take this jacket, it might be important,
    13 any of those types of conversations?
    14 A. No. The only things I cared
    15 about in that house were my baby things. It
    16 could have burned to the ground.
    17 Q. So I take that as saying, no, I
    18 never had a conversation with the
    19 investigators to assist them in seizing
    20 things that might be of evidentiary value?
    21 A. Correct.
    22 Q. To your knowledge, did John have
    23 a conversation of that nature with the
    24 investigators suggesting items that might be
    25 important to your investigation?
    1 A. Not to my knowledge.
    2 Q. In December of 1998, there was a
    3 fairly well publicized request from the
    4 Boulder Police Department for assistance in
    5 identifying and perhaps retrieving a Santa
    6 Bear. Do you recall that?
    7 A. Yes.
    8 Q. Was it your understanding that the
    9 bear that was sought was the same bear that
    10 you were shown photographs of in 1998 June?
    11 A. Yes.
    12 Q. The same bear that you were
    13 unable to identify?
    14 A. Yes.
    15 Q. We collectively, the prosecution
    16 team, received from either Mr. Morgan or Mr.
    17 Haddon the bear, the bear. Is that your
    18 understanding?
    19 A. Yes.
    20 Q. How did we get it? I mean, what
    21 was your participation in the chain of events
    22 that led to the recovery of that bear?
    23 A. The -- well, I think our lawyers
    24 asked Gene Matthews, who was a local retired
    25 police officer who had helped us with some
    1 security at our home --
    2 Q. Your home in Atlanta?
    3 A. In Atlanta.
    4 -- to go through boxes and look
    5 for the bear.
    6 Q. Did you assist him or is it her?
    7 A. It is a him.
    8 Q. Okay. Did you assist Mr.
    9 Matthews, you personally?
    10 A. You mean in digging through boxes?
    11 Q. No. In offering suggestions to
    12 where to look.
    13 A. Well, I believe at that time we
    14 were in the throes of a remodeling session,
    15 and JonBenet's things that had come out of
    16 her room in Colorado were packed and were in
    17 the basement at my mother and father's house
    18 in Roswell, Georgia.
    19 So I told him that is where he
    20 should start looking.
    21 Q. Mrs. Ramsey, you emphatically
    22 denied, in June of 1998, knowledge of that
    23 bear. Did you have a change of
    24 recollection, following the interviews in
    25 1998, as to whether or not you had prior
    1 knowledge of that bear?
    2 MR. WOOD: Do you know what he
    3 is asking you?
    4 THE WITNESS: Do I recognize the
    5 bear?
    6 MR. WOOD: The emphatic part is
    7 the only thing that concerns me. I am not
    8 denying that it was emphatic, but I think
    9 the point is you denied it in June of 1998,
    10 and the question I think he is asking you is
    11 when you found it, did that jog your
    12 recollection that you might remember the
    13 bear. Is that what you are asking?
    14 MR. LEVIN: That is not quite the
    15 question, but it is pretty close.
    16 Q. (By Mr. Levin) What I am asking
    17 you is, in June of 1998, you stated I do
    18 not recognize this bear?
    19 A. Correct.
    20 Q. You recall that. The cry went
    21 out for help in locating the origin of the
    22 bear. Did you, at some point between our
    23 request for assistance and in June of 1998,
    24 have an opportunity to rethink the origin of
    25 the bear and realize that that was, in fact,
    1 JonBenet's Santa Bear?
    2 MR. WOOD: I think you meant
    3 between your request and December of 1998.
    4 Q. (By Mr. Levin) Between June of
    5 1998 and our request for help in December of
    6 1998 --
    7 MR. WOOD: That's right.
    8 Q. (By Mr. Levin) -- did your
    9 recollection get jogged and you realized that
    10 you did, in fact, own the bear?
    11 A. No. I mean, it was still a bear
    12 that I did not recognize.
    13 Q. Have you since that time had
    14 anything that has refreshed your recollection
    15 in that regard so that you now presently
    16 know the source of that bear?
    17 A. No.
    18 Q. I am going to provide you with
    19 some information to see if we can jog your
    20 memory. I have seen a videotape taken at a
    21 pageant in December, in fact, December 14,
    22 1996. I think that was -- was that the
    23 last -- I believe that was the last pageant
    24 that JonBenet participated in.
    25 MR. WOOD: Is that right?
    1 Q. (By Mr. Levin) I am asking you
    2 if that is your recollection as well.
    3 THE WITNESS: Is that the
    4 Christmas, one of the Christmas ones down by
    5 the --
    6 Q. Yes.
    7 A. All right.
    8 Q. Was that the last formal pageant
    9 she participated in?
    10 A. Uh-huh (affirmative).
    11 Q. I have seen a videotape of that.
    12 A. Uh-huh (affirmative).
    13 Q. And in the videotape it shows the
    14 prizes.
    15 A. Uh-huh (affirmative).
    16 Q. And that bear is in the videotape
    17 with you in the videotape?
    18 A. Oh, really?
    19 Q. And JonBenet won that bear at
    20 that pageant. Assuming that that is a
    21 fact --
    22 MR. WOOD: And you represent it
    23 as fact.
    24 MR. LEVIN: I'm representing that
    25 it is my belief that that is true, and I
    1 have seen videotape that shows what appears
    2 to be that bear.
    3 MR. WOOD: The question, though,
    4 is are you representing it is that bear
    5 because there is a difference, and I think
    6 you understand it. I haven't seen the
    7 videotape that you are referring to, but I
    8 mean, you are saying it appears to be.
    9 THE WITNESS: Yeah, I would like
    10 to see that too because it was my
    11 recollection that she won a bear, but it had
    12 a little banner on it, and it was like a
    13 little angel bear or something. It was all
    14 white.
    15 Q. (By Mr. Levin) Assuming that
    16 that is correct, that, and, of course,
    17 perhaps my observations are incorrect, just
    18 assuming that, does that refresh your
    19 recollection as to the origin of the Santa
    20 Bear that we saw?
    21 A. Well, this bear that I think she
    22 was presented at that pageant did not have
    23 Santa, Santa attire. It was a little angel
    24 bear, which I have someplace.
    25 Q. And just, I don't want to mislead
    1 you because I am trying to jog your memory
    2 to see if you can help us out here.
    3 A. I appreciate that.
    4 Q. And Detective Harmer is the one
    5 that came up with the videotape.
    6 MR. WOOD: I don't suppose we
    7 have it.
    8 MS. HARMER: No, I don't have it.
    9 THE WITNESS: But it is the one
    10 in the Santa outfit?
    11 MS. HARMER: Can I --
    12 MR. LEVIN: Yeah, because we are
    13 trying to get Ms. Ramsey to see if we can
    14 jog her memory.
    15 MS. HARMER: The person who
    16 provided the gifts is LaDonna Graygo.
    17 THE WITNESS: All right.
    18 MS. HARMER: Is she with All
    19 Stars or America? I can't remember which.
    20 THE WITNESS: I don't remember
    21 either.
    22 MS. HARMER: Whatever pageant she
    23 was in on the 14th of December, and LaDonna
    24 was involved in it, that is where the bear
    25 came from.
    1 THE WITNESS: Oh, okay.
    2 MR. WOOD: According to?
    3 THE WITNESS: LaDonna?
    4 MS. HARMER: Yes.
    5 MR. WOOD: Just so we are clear,
    6 we are now talking about two things.
    7 MS. HARMER: And the video.
    8 MR. WOOD: The video shows a
    9 Santa Bear.
    10 MS. HARMER: Yes. The video is
    11 taken at the same pageant where LaDonna
    12 passed out these prizes, one of which was
    13 the bear.
    14 MR. WOOD: Again, I am just
    15 trying to make sure, do you have a video of
    16 JonBenet holding or receiving a Santa Bear or
    17 are you saying that Santa bears were given
    18 out to some of the people there?
    19 MS. HARMER: The video shows the
    20 Santa Bear on the table.
    21 MR. WOOD: Well, the table, who
    22 all is in the picture?
    23 MR. KANE: Maybe I can clarify
    24 it. LaDonna Graygo purchased the bear,
    25 purchased the Santa Bear. It was the prize
    1 to JonBenet, and she told us the prize that
    2 JonBenet was awarded for winning little Ms.
    3 Christmas. That was the prize and it was
    4 the only bears that she had, and she got it
    5 from someplace in Nebraska, a mail order
    6 company. I can't remember the name.
    7 THE WITNESS: Okay.
    8 Q. (By Mr. Kane) Did you look at
    9 the bear when it was found by -- what is
    10 her name?
    11 A. Gene.
    12 Q. Gene, or his?
    13 MR. LEVIN: Mr. Matthews.
    14 THE WITNESS: Uh-huh
    15 (affirmative).
    16 Q. (By Mr. Kane) You looked at it
    17 before it was shipped off to Colorado?
    18 A. Yes.
    19 Q. And that didn't ring any bell
    20 with you?
    21 A. Uh-uh (negative).
    22 Q. But you remember getting -- she
    23 won a bear at that pageant?
    24 A. I thought it was the little white
    25 angel bear, but maybe it was, maybe she got
    1 that some other time.
    2 Q. (By Mr. Levin) If I understand
    3 you correctly, Mrs. Ramsey, you do recall, my
    4 sense is, and if I am wrong, tell me, you
    5 do recall with some degree of certainty she
    6 won a bear at that pageant, her last
    7 pageant?
    8 A. Yes.
    9 Q. And then what I am understanding
    10 you to say is, what you are not certain of
    11 is the type of bear?
    12 MR. WOOD: No, she is not saying
    13 she is not certain. She is saying I thought
    14 it was the little white angel bear, but
    15 maybe she got that some other time.
    16 Q. (By Mr. Levin) And I took that
    17 to mean that you are not certain that it was
    18 the angel bear --
    19 A. Or the Santa Bear.
    20 Q. -- or the Santa Bear?
    21 A. Right.
    22 Q. So if I understand you correctly,
    23 you are saying that you don't have an
    24 independent memory today to state emphatically
    25 she didn't win the Santa Bear?
    1 A. Right.
    2 Q. Did you, when you directed Mr.
    3 Matthews where to look for the bear, that
    4 is, in the box of things from JonBenet, did
    5 you know that that bear had been taken out
    6 of the house with your other property? I
    7 suppose what I am getting at is, had you
    8 been able to go through all of the things
    9 that were removed from the Boulder house --
    10 A. No.
    11 Q. -- prior to December of '98?
    12 A. No.
    13 Q. Did you go through any of the
    14 property at all, if you recall?
    15 A. No.
    16 Q. You were shown, I believe,
    17 photographs that were taken -- and this is
    18 during your '98 interview -- photographs that
    19 were taken at the White's house Christmas
    20 night at dinner. In that you are wearing a
    21 red coat, kind of a wool, wool jacket. Do
    22 you recall seeing that?
    23 A. It is kind of a black and red
    24 and gray fleece.
    25 Q. Cut more like a blazer than --
    1 A. Like a peacoat.
    2 MR. WOOD: Well, the picture is
    3 the picture, isn't it?
    4 Q. (By Mr. Levin) Right, like a
    5 peacoat. I just want to make sure we are
    6 talking about the same thing. Do you
    7 remember that jacket?
    8 A. Uh-huh (affirmative).
    9 Q. I would like you to give us a
    10 little background on that coat, and again I
    11 am not going to hold you to days of the
    12 week, but do you recall, first of all, where
    13 you purchased it?
    14 A. Well, Priscilla had had one like
    15 it that I admired. And she told me, I
    16 believe she told me she got hers at EMS.
    17 So I went there to look. And they didn't
    18 have one or I didn't want to get one exactly
    19 like hers. So I think I got that one at
    20 Marshals in Boulder.
    21 Q. Do you recall what year you
    22 purchased it?
    23 A. No.
    24 Q. Let's -- I can understand that.
    25 Now I am going to -- we will take a time
    1 frame. Was it a fairly, by your
    2 recollection, was it a fairly recent purchase
    3 that you had or was this a coat you'd had
    4 for some period of time prior -- and, of
    5 course, I am using it as the date of
    6 JonBenet's murder.
    7 A. Well, I can't remember. I am
    8 sure I bought it in -- as it was getting
    9 colder. So it was either probably fall of
    10 '96 or '95.
    11 Q. That, the coat that you wore the
    12 night to the Whites, was it something that
    13 was -- I mean, the primary color is red.
    14 MR. WOOD: Well, don't fight over
    15 -- excuse me, Patsy. Don't you have a
    16 picture?
    17 MR. LEVIN: I don't have a
    18 picture with me.
    19 MR. WOOD: Why characterize it.
    20 It is what it is.
    21 THE WITNESS: There is a picture.
    22 MR. WOOD: It is in the picture.
    23 Let's look at that.
    24 MR. LEVIN: Just to expedite
    25 things, because I am not fighting over the
    1 color, what I want to know is --
    2 MR. WOOD: I think she said it
    3 was red and black and gray.
    4 THE WITNESS: A red and black and
    5 gray check.
    6 Q. (By Mr. Levin) What I am, what
    7 I am interested in is, I am certainly not
    8 going to debate concentration of colors. It
    9 is irrelevant. What I am interested in, is
    10 it something that you wore exclusively during
    11 the Christmas season or is this a coat that
    12 you wore anytime it was appropriate for the
    13 weather?
    14 A. Anytime it was appropriate.
    15 Q. So it is not like a special
    16 Christmassy type, type of Christmas sweater,
    17 I know you talked about Christmas?
    18 A. (Witness shook head negatively).
    19 MR. WOOD: Your answer is not,
    20 because you are nodding your head.
    21 THE WITNESS: No, it is not.
    22 MR. WOOD: So the record is
    23 clear.
    24 Q. (By Mr. Morrissey) We were
    25 provided that coat by, I believe, Ellis
    1 Armistead.
    2 MR. TRUJILLO: Correct.
    3 Q. (By Mr. Levin) What I would like
    4 you to help us with is to understand how the
    5 coat got from you to Ellis, if you know.
    6 A. The -- I think you all requested
    7 it.
    8 Q. That is correct.
    9 A. So I went to my closet, dug it
    10 out, put it in a box, and sent it to Ellis.
    11 Q. Was that coat something that was
    12 taken -- you didn't wear that coat out of
    13 the house when the police took you out of
    14 the house the afternoon of the 26th. Do you
    15 recall?
    16 A. No, I don't think I did.
    17 Q. Do you know how you came into
    18 possession? Was that something that came
    19 through Pam when she picked up some clothes
    20 for you or was that something that was boxed
    21 up and shipped when the house was packed?
    22 MR. WOOD: Just so I am clear,
    23 when was the request made?
    24 MR. TRUJILLO: It was received
    25 January of '98. So it was --
    1 MR. WOOD: Are we talking about
    2 sometime between December of '96, and then
    3 you all asked for it when, a year later?
    4 MR. TRUJILLO: I don't have the
    5 exact date.
    6 THE WITNESS: It was a long time
    7 later. We were in the house in Atlanta when
    8 the request was made.
    9 CHIEF BECKNER: December of '97.
    10 MR. WOOD: So a year later you
    11 all asked for the clothes, and they produced
    12 it in January of '98?
    13 MR. TRUJILLO: Yes.
    14 MR. WOOD: Okay. Does that help
    15 just put it in the time context of when it
    16 might have been?
    17 MR. LEVIN: And because everyone
    18 needs a computer whiz, we have Mr. Kane.
    19 We're talking about that coat.
    20 THE WITNESS: Yes.
    21 CHIEF BECKNER: Is that a, just
    22 for clarification, is that a coat or a
    23 sweater?
    24 THE WITNESS: It is kind of a
    25 little jacket, coat.
    1 CHIEF BECKNER: We called it a
    2 sweater in the past.
    3 THE WITNESS: It is a jacket.
    4 CHIEF BECKNER: Ellis Armistead
    5 called it a sweater in his letter to us.
    6 So I just want to clarify we are talking
    7 about the right piece of clothing.
    8 THE WITNESS: Well, we are
    9 talking about that. You can call it
    10 whatever you want. It is kind of a jacket
    11 more.
    12 MR. WOOD: I'd go with jacket.
    13 THE WITNESS: I mean, I, you
    14 know, it is something you put on to go
    15 outside in the cold.
    16 MR. WOOD: All right. Now, I
    17 had to interrupted you to try to figure out
    18 if we can put it into context of time.
    19 Your question was?
    20 THE WITNESS: You want to know
    21 did it come to --
    22 MR. WOOD: Let's let him figure
    23 out what it was. Hold on a second. He
    24 asked, was that something that came through
    25 Pam when she picked up some clothes, which I
    1 am taking to be back early right after
    2 the --
    3 MR. LEVIN: I'm talking about,
    4 yes.
    5 MR. WOOD: Pam picked up some
    6 clothes right after.
    7 MR. LEVIN: Saturday the 28th of
    8 December, 199 -
    9 MR. WOOD: Right. Was that
    10 something that was boxed up and shipped when
    11 the house was packed? Does that help you?
    12 Do you know the answer?
    13 THE WITNESS: No.
    14 MR. WOOD: If so, tell him.
    15 Q. (By Mr. Levin) When the request
    16 came to you, though, from, either I suppose
    17 your lawyers, about turning that jacket over,
    18 it was, if I understand you correctly,
    19 hanging in your closet?
    20 A. Uh-huh (affirmative), in Atlanta,
    21 yes.
    22 Q. And that would be, the request is
    23 made approximately a year after your daughter
    24 is murdered. Is it something that was just
    25 hanging in your closet or something that you
    1 continued to wear if you recall during the
    2 one-year period or any portion thereof?
    3 A. I don't remember.
    4 Q. I will take -- tell me if this
    5 is correct. I am taking that as saying you
    6 may have worn it, but some point in time
    7 between the murder of JonBenet and when you
    8 turned it over, you may not have; you have
    9 no independent recollection?
    10 A. Correct.
    11 Q. Did you, if you recall, did you
    12 clean it at any time -- I believe it is
    13 wool, primarily wool -- dry-clean it from
    14 when you -- which may sound like a silly
    15 question, but I will put it in a larger
    16 context. The clothing that came boxed, did
    17 you -- those items that you kept, continued
    18 to use or at least have available, did you
    19 clean them all before you put them away,
    20 take them all to the cleaners?
    21 MR. WOOD: I am going to ask you
    22 to go back and redo that one because that
    23 one kind of went in about three different
    24 directions, Bruce.
    25 MR. LEVIN: Okay.
    1 MR. WOOD: You started off asking
    2 about whether she had this jacket cleaned and
    3 then you started talking about clothes that
    4 were boxed up. And I don't know if she
    5 knows whether this one was boxed up or not.
    6 MR. LEVIN: Right. And I
    7 understand that.
    8 Q. (By Mr. Levin) So what I am
    9 trying to do is just to, because I
    10 understand you can't identify a particular,
    11 whether it was this particular item.
    12 A. Uh-huh (affirmative).
    13 Q. Let's start with the clothes that
    14 were boxed up. The clothes that were boxed
    15 up that you then reintegrated into your
    16 wardrobe, did you clean all of those before
    17 you did that?
    18 A. No.
    19 Q. Do you have any recollection as
    20 to this particular coat, whether or not you
    21 ever cleaned it before giving it to Mr.
    22 Armistead?
    23 A. No.
    24 Q. It is a coat that you would
    25 dry-clean, though?
    1 A. I am not so sure about that. I
    2 think, I think it is able to be thrown in
    3 the washing machine.
    4 MR. KANE: I believe it was made
    5 of acrylic, if that helps.
    6 THE WITNESS: Yeah.
    7 MR. WOOD: You all gotta decide,
    8 he says wool, you say acrylic.
    9 MR. LEVIN: It was acrylic.
    10 MR. WOOD: It ought to say
    11 dry-cleaning only on it, if it is, or if it
    12 doesn't, sometimes it'll get washed. Do you
    13 know for a fact, that is the key, do you
    14 know whether you dry cleaned it or washed it
    15 as you sit here today, Patsy?
    16 THE WITNESS: No, I don't.
    17 MR. MORRISSEY: Do you know if
    18 Mr. Armistead did before he sent it to us?
    19 THE WITNESS: No, I don't.
    20 Q. (By Mr. Levin) I will take that
    21 as a statement that, once you turned the
    22 coat over or may have boxed it up and
    23 shipped it to Mr. Armistead, that your
    24 personal knowledge of what happens to it is
    25 none?
    1 A. Correct.
    2 Q. It is not something that you and
    3 he ever discussed during the course of maybe
    4 a briefing or something like that?
    5 A. No.
    6 Q. Was it a jacket that you wore
    7 around the house? I know this is an indoor
    8 picture. Did you do that commonly?
    9 A. Sometimes, if it was particularly
    10 chilly.
    11 Q. Do you recall whether or not you
    12 wore that on either the 23rd of December
    13 1996, the 24th, or the 20-- well, we know
    14 you wore it on the 25th. The 23rd or the
    15 24th?
    16 A. I don't remember.
    17 Q. Was it something that you would
    18 frequently wear inside the house?
    19 A. Sometimes I would, but what is
    20 frequently? You know, I don't --
    21 Q. Frequently would be three or four
    22 times -- I mean, was it, if you are chilly,
    23 was this the item that you always threw on?
    24 That is what I am getting at.
    25 A. Not necessarily, no.
    1 Q. You talked about, in your '98
    2 interview, that you, on the 24th, that you
    3 were in the basement and you were wrapping
    4 presents. Do you know, when you were doing
    5 that, whether or not you had on that coat?
    6 A. I don't know.
    7 Q. You have told us that you painted
    8 as a hobby. Would you wear this coat to
    9 paint?
    10 A. No.
    11 MR. LEVIN: Mitch?
    12 MR. MORRISSEY: Nothing about the
    13 coat.
    14 Q. (By Mr. Levin) Mrs. Ramsey, we
    15 were sent, and Detective Trujillo probably
    16 can give me dates on this to orient
    17 everyone, two black shirts.
    18 CHIEF BECKNER: Same time. It
    19 was January 28, 1998.
    20 MR. TRUJILLO: Same date.
    21 MR. LEVIN: Received the same
    22 date as the red coat?
    23 CHIEF BECKNER: Yes.
    24 Q. (By Mr. Levin) We have asked for
    25 -- we had also requested, through your
    1 attorneys, that we be sent a black shirt, a
    2 black shirt that John was wearing at the
    3 Whites on Christmas of 1996. Were you aware
    4 of that request in addition to the request
    5 for your red coat?
    6 A. I am sure I was.
    7 Q. Did you participate in collecting
    8 that? What I mean by that is you said,
    9 well, I went in my closet and grabbed my
    10 jacket. Did you go and grab what you
    11 thought was John's shirt? How did that come
    12 about? Why don't you just tell us in your
    13 own words?
    14 A. I don't remember. More likely he
    15 found his shirt, I found my jacket.
    16 Q. He sent us two black shirts. I
    17 am going to show you a photograph here. It
    18 shows you wearing your red coat and then
    19 John wearing a black shirt. He sent us two,
    20 two different black shirts. This one, does
    21 this have a collar, this shirt?
    22 A. I can't tell.
    23 Q. While Mr. Kane tries to get a
    24 little closer, I have some more questions.
    25 John sent us two black shirts. One had a
    1 collar and one did not. Was there any
    2 discussion that he had with you in which he
    3 tried to obtain your assistance in refreshing
    4 his memory as to which of those two shirts
    5 he wore Christmas of 1996?
    6 A. I don't remember.
    7 Q. If it took place, you just don't
    8 recall it?
    9 A. I don't remember, no.
    10 Q. I think this is a little better
    11 shot.
    12 MR. WOOD: I don't believe
    13 there's contrast.
    14 THE WITNESS: I can't tell, you
    15 know, which one that was. He has got
    16 several.
    17 MR. WOOD: You are talking about
    18 the question of the collar, though, on that
    19 one. I don't think you can tell, even from
    20 the zoom I can't tell.
    21 THE WITNESS: You can't tell if
    22 there's a collar.
    23 Q. (By Mr. Levin) And the sheriff,
    24 this is just, the two he sent us, the one
    25 that this appears to be, it is a wool shirt
    1 that is made in Israel, which is kind of
    2 unusual. It wasn't a gift that maybe you
    3 bought for him, something like that, that
    4 would make it stand out?
    5 MR. WOOD: Let me stop. You are
    6 saying this one appears to be. You are
    7 talking about the picture that Mr. Kane has
    8 just shown us?
    9 MR. LEVIN: Yes. And then we
    10 are --
    11 MR. WOOD: You say it is a wool
    12 shirt that is made in Israel.
    13 MR. LEVIN: The shirt that your
    14 husband sent us.
    15 MR. WOOD: Which is kind of
    16 unusual. I don't know if that is true or
    17 not. But the point is, are you asking if
    18 this shirt was one that was made -- are you
    19 asking her if she knows whether this is a
    20 wool shirt that was made in Israel?
    21 MR. LEVIN: Yes.
    22 MR. WOOD: The one that you see
    23 in this photograph, are you able to know
    24 that?
    25 THE WITNESS: No, I don't know.
    1 Q. (By Mr. Levin) The wool shirt
    2 that he sent us was made in Israel. Is it
    3 a shirt that maybe you bought him as a gift?
    4 A. I don't remember.
    5 Q. I am not going through, from the
    6 minute you walked in the door Christmas
    7 coming back from dropping presents off, but
    8 what I would like to do, and I don't believe
    9 you have been asked this, if you can recall
    10 when you got upstairs, had John hung up his
    11 clothes that he had worn on the 25th, if you
    12 remember?
    13 MR. WOOD: Had he hung them up?
    14 MR. LEVIN: Yes.
    15 THE WITNESS: You mean when I
    16 came up to get ready for bed?
    17 Q. (By Mr. Levin) Yes. Do you
    18 remember if he had just left them laying
    19 around or if he had hung them up?
    20 A. I don't remember. I mean, my
    21 dressing room, bathroom, was this direction
    22 and his was that direction. So I didn't, I
    23 didn't see it.
    24 Q. Your husband's routine practice
    25 and habit, as far as when he would get
    1 undressed, if things needed to be hung up,
    2 did he generally hang things up or if they
    3 needed to go into the hamper or the laundry
    4 chute, would he put them right in the
    5 laundry chute?
    6 THE WITNESS: Usually.
    7 MR. WOOD: Hold on a second.
    8 You were going to say something else.
    9 MR. LEVIN: We can, we can take
    10 it one at a time.
    11 MR. WOOD: Well, I mean, her
    12 answer doesn't give you any information as I
    13 see it because you asked her, did he
    14 generally hang it up or if they needed to go
    15 into the -- why don't you ask a specific
    16 question. I'm not sure --
    17 MR. LEVIN: I was going to split
    18 it.
    19 MR. WOOD: I think she jumped on
    20 top of you actually. Let him finish the
    21 question, Patsy, and then go ahead and do
    22 it.
    23 MR. LEVIN: Let's do it, we will
    24 do it one step at a time.
    25 Q. (By Mr. Levin) Your husband's
    1 routine practice and habit, if he had
    2 clothing that he was changing out of that
    3 could be worn again, would he normally hang
    4 them up?
    5 A. I don't know if he has a routine.
    6 Sometimes he does. Sometimes he doesn't.
    7 Q. When he had clothes that were not
    8 going to -- that he'd just worn that he was
    9 changing out of that he was not going to
    10 wear again, was it his habit, routine habit
    11 and practice, to just leave them laying
    12 around or would he normally throw them in
    13 the laundry chute?
    14 A. Both. Sometimes he puts some in
    15 the laundry chute and sometimes he left some
    16 in the bathroom.
    17 Q. Do you have any recollection with
    18 regard to the clothing that he wore on
    19 January -- excuse me, December 25th if they
    20 went in the laundry chute, hung up, any
    21 recollection whatsoever?
    22 A. No.
    23 Q. (By Mr. Morrissey) What was your
    24 practice in your house when things that were
    25 dry cleaned would go out? How did you
    1 handle that, not laundry items, but
    2 dry-cleaning items?
    3 A. Yeah.
    4 MR. WOOD: You mean like did she
    5 put it in a special place to make the run
    6 to the dry cleaner?
    7 Q. (By Mr. Morrissey) Was there
    8 like a bag or how did that work?
    9 MR. WOOD: Do you understand what
    10 he is asking you, Patsy?
    11 THE WITNESS: Yeah. I don't know
    12 that we had a particular routine. I mean,
    13 if -- I think if I was going to the dry
    14 cleaners, I would kind of check around and
    15 see if anything was left, and I would pick
    16 it up and take it.
    17 Q. (By Mr. Morrissey) Did you have
    18 like a dry-cleaning bag? I know some people
    19 have --
    20 A. No.
    21 Q. - like a bag that is
    22 specifically for that or a place that is
    23 specifically for those kinds of items.
    24 A. I wasn't that organized.
    25 Q. Well, and some people have dry
    1 cleaners that come to their house, pick the
    2 stuff up, and then bring it back in a couple
    3 of days and hang it on their door. Did you
    4 have any of that kind of service in Boulder
    5 there?
    6 A. I think I tried that a couple of
    7 times, but it just never -- I could never
    8 promise when I was going to be there to pay
    9 them and all of that.
    10 MR. MORRISSEY: Thank you.
    11 Q. (By Mr. Levin) You told us
    12 that -- I believe you said you didn't help
    13 JonBenet get dressed for the Whites'
    14 Christmas Day '96?
    15 MR. WOOD: When did she tell you
    16 that?
    17 MR. LEVIN: I thought she told
    18 that to Mr. Kane.
    19 MR. WOOD: Earlier today?
    20 MR. LEVIN: I thought so. I
    21 could be mistaken. We don't need to go
    22 through it. I can just ask her the
    23 question.
    24 MR. WOOD: Let's just make sure
    25 of what she said.
    1 MR. LEVIN: Okay.
    2 MR. WOOD: How do you search,
    3 Mr. Gallo?
    4 MR. GALLO: F1.
    5 MR. WOOD: F9?
    6 MR. GALLO: F1.
    7 MR. WOOD: F1, search down? I
    8 am not finding it under dress. Why don't
    9 you just ask the question again, if you
    10 don't mind, Bruce.
    11 MR. LEVIN: No problem.
    12 Q. (By Mr. Levin) Did you help
    13 JonBenet get dressed for the Whites'
    14 Christmas Day '96?
    15 A. Yes.
    16 Q. Did you do this by yourself or
    17 did John help you too?
    18 A. No, John did not help me.
    19 Q. You told us that you changed
    20 JonBenet's clothing when she came home to put
    21 her in clothes to sleep?
    22 A. Correct.
    23 Q. Did John assist in that process?
    24 A. He, I believe, took her coat off,
    25 maybe her shoes.
    1 Q. Okay. As far as putting the
    2 long johns on her for sleeping purposes, did
    3 you do that alone?
    4 A. Yes.
    5 Q. While you were at the Whites'
    6 house, if JonBenet went to the bathroom, did
    7 either you or he ever go in to help her for
    8 some reason that you can recall?
    9 A. I did not.
    10 Q. Do you have a recollection of
    11 John having to go in and help her for any
    12 reason?
    13 A. No.
    14 Q. And under normal -- barring a
    15 problem, under normal circumstances, she would
    16 just go on her own?
    17 A. Yes.
    18 Q. Mrs. Ramsey, you told us that the
    19 red coat that we showed you in the
    20 photograph, that you didn't paint with it, to
    21 the best of your recollection?
    22 A. To the best of my recollection.
    23 Q. And you have told investigators
    24 before that, as the holiday season began,
    25 that the painting equipment which is normally
    1 kept in the butler's pantry was transferred
    2 to the basement by Ms. Hoffman Pugh. Do you
    3 remember that?
    4 MR. WOOD: Why don't you give her
    5 the statement so she can look at that. You
    6 now are directly asking her to reaffirm
    7 something she's already apparently said.
    8 MR. LEVIN: I didn't think it was
    9 a matter of discussion. Let me ask a second
    10 question.
    11 MR. WOOD: I don't know whether
    12 it is or not, Bruce, but I mean, it is not,
    13 apparently by the nature of your question,
    14 something new. You already have gotten the
    15 information from a question, so --
    16 Q. (By Mr. Levin) Let me just, let
    17 me just ask another question. We will just
    18 drop that one.
    19 At the time of JonBenet's death,
    20 your painting supplies were found in the
    21 basement. Did you ever paint in the
    22 basement?
    23 A. No.
    24 Q. When you were helping JonBenet get
    25 ready for bed, were you still wearing the
    1 red coat -- excuse me, the red, black, and
    2 gray coat?
    3 MR. WOOD: Well, from what I saw,
    4 it looked like the red and black jacket.
    5 THE WITNESS: I don't remember.
    6 MR. WOOD: The one we have been
    7 discussing that Mr. Kane had a picture of.
    8 THE WITNESS: I don't remember.
    9 MR. WOOD: Did you get your
    10 answer?
    11 MR. LEVIN: Yes, I did.
    12 Q. (By Mr. Levin) I believe you
    13 said you don't remember.
    14 Was that the outer coat that you
    15 were wearing Christmas, or did you have a
    16 heavier coat that you wore on top of that?
    17 MR. WOOD: For outdoors?
    18 MR. LEVIN: For outdoors.
    19 THE WITNESS: I don't remember.
    20 I think, I think that was the only one I
    21 wore. Because we were in the car and out,
    22 but I don't remember exactly.
    23 MR. MORRISSEY: Mrs. Ramsey, I am
    24 sorry to interrupt you. Before you get
    25 going too far, when was the last time you
    1 remember using the paint set?
    2 THE WITNESS: Oh, god. Oh, you
    3 know, probably that fall sometime, I --
    4 MR. WOOD: Do you remember that,
    5 Patsy? Be sure of your answer.
    6 THE WITNESS: No, I don't
    7 remember the last time I used it.
    8 Q. (By Mr. Morrissey) Right. I am
    9 not asking for a date.
    10 A. Yeah.
    11 Q. A season.
    12 A. Yeah.
    13 Q. And you indicate the fall? I
    14 don't want to put words in your mouth.
    15 A. Well, the last time I used it was
    16 in conjunction with this art class that I
    17 signed up to, and I can't remember when that
    18 was exactly from CU. And all of my stuff
    19 was there in the butler's pantry. But then
    20 the holidays came, we needed that space, and
    21 we moved all of the junk to the basement.
    22 Q. Once it was moved to the
    23 basement, you never hauled it up and painted
    24 or anything? You never used it again?
    25 A. No.
    1 Q. (By Mr. Levin) Mrs. Ramsey, you,
    2 you had cut evergreens, I believe, in a
    3 bucket of water in your house during the
    4 holidays. Do you recall that during
    5 Christmas of '96, like boughs or --
    6 A. Greenery, yeah, I decorate with
    7 greenery.
    8 Q. Greenery. Did you have garden
    9 gloves that you wore when you were, when you
    10 were -- I assume, you tell me if I am
    11 wrong, I assume that you cut them off some
    12 of your Evergreen trees outside?
    13 A. Yeah.
    14 Q. Do you wear gloves when you do
    15 that?
    16 A. No.
    17 Q. And I know that you -- there were
    18 some flower beds I believe that you
    19 occasionally worked with, that you worked on
    20 that were on, is it, the south side of the
    21 house?
    22 A. The rose, I think the roses.
    23 Q. Did you wear gardening gloves when
    24 you worked out in the yard?
    25 A. Not usually.
    1 Q. Did you own gardening gloves?
    2 A. I don't think so, no.
    3 Q. Do you recall ever seeing in your
    4 house brown kind of work gloves, cotton?
    5 A. Brown cotton? John had -- I
    6 don't remember brown work gloves.
    7 Q. Can you picture what I am talking
    8 about?
    9 MR. WOOD: Do you have a photo
    10 maybe or something?
    11 MR. LEVIN: No, I, we, we don't.
    12 Q. (By Mr. Levin) Have you ever
    13 seen, they are kind of a --
    14 MR. WOOD: No, I don't think so.
    15 You got to do better than that. You can
    16 conjure up a zillion different brown work
    17 gloves.
    18 Q. (By Mr. Levin) Cotton brown work
    19 gloves.
    20 A. Cotton brown work gloves?
    21 Q. Costs you about three bucks in
    22 the grocery store. I am not creating any
    23 images for you?
    24 A. No.
    25 Q. Okay.
    1 MR. WOOD: Me either.
    2 MR. LEVIN: We will just leave
    3 that.
    4 CHIEF BECKNER: Before we go too
    5 far, for clarification for me, when you were
    6 asked about wearing garden gloves, you said
    7 not usually, I believe. Does that mean
    8 sometimes you would?
    9 THE WITNESS: I don't remember
    10 doing that. I mean, I do wear them now
    11 because now I am wearing these funny
    12 fingernails, I don't want to get them messed
    13 up, but I don't think I was doing it then.
    14 So I don't, I don't ever remember -- I am
    15 not a big gardener, so I didn't have all of
    16 the trappings, you know, all of that stuff.
    17 So I do not remember having any gardening
    18 gloves.
    19 Q. (By Mr. Kane) You started to say
    20 that John had. John had what?
    21 MR. WOOD: Let's see exactly what
    22 she said.
    23 MR. KANE: Lin, she said John had
    24 30 seconds ago. What did John have?
    25 MR. WOOD: Excuse me. The
    1 question was, do you recall ever seeing in
    2 your house brown kind of work gloves, cotton,
    3 and you went brown cotton, and you said John
    4 had, and you said I don't remember brown.
    5 All I want to do is put it in the context
    6 of what she said. Do you remember saying
    7 that?
    8 THE WITNESS: Yes.
    9 MR. WOOD: Now, Mr. Kane, go
    10 right ahead.
    11 Q. (By Mr. Kane) Now that you've
    12 had time to think about it for a minute,
    13 what did John have?
    14 A. What kind of gloves did he have?
    15 Q. What were you about to say? You
    16 said John had.
    17 A. John had ski gloves.
    18 Q. (By Mr. Levin) In addition to
    19 his ski gloves, Mrs. Ramsey, do you recall
    20 John having any kind of work gloves that he
    21 might have kept in the car if he had to
    22 change a tire or anything like that?
    23 A. No.
    24 Q. Just for clarification, for the
    25 record, when you say no, does that mean no,
    1 you don't recall whether he did or didn't or
    2 no, he did not own any work gloves?
    3 A. I don't recall that he did. You
    4 will have to ask him if he did.
    5 Q. Fair enough. Thank you.
    6 Mr. Morrissey?
    7 Q. (By Mr. Morrissey) What color
    8 were the ski gloves that you were thinking
    9 about?
    10 A. It seems to me like they were
    11 black. I can't be sure, but I think they
    12 were black. They were the puffy kind.
    13 Q. (By Mr. Levin) Now, Mrs. Ramsey,
    14 you -- are you aware, I should say, that
    15 your paint kit was found very close to the
    16 wine cellar door?
    17 A. I have heard that.
    18 Q. Did you recall at any time that
    19 you were shown photographs in that regard?
    20 A. No.
    21 Q. We have found, and I want you to
    22 help us, maybe you can offer an explanation
    23 for this. We have found fibers in the paint
    24 tray that appear to come off of the coat in
    25 the photograph we showed you.
    1 A. In the paint tray?
    2 Q. Yes.
    3 A. What's a paint --
    4 MR. WOOD: Hold on. Let him ask
    5 you his question and then answer his
    6 question. What is your question?
    7 MR. LEVIN: I did.
    8 MR. WOOD: You got your answer?
    9 MR. LEVIN: Well, I got, she said
    10 what's a paint tray.
    11 MR. WOOD: No, she didn't. She
    12 was following your question, in the paint
    13 tray because you said we have found, and I
    14 want you to help us, maybe you can offer an
    15 explanation for this. We have found fibers
    16 in the paint tray that appear to come off of
    17 the coat in the photograph we showed you.
    18 What is the question?
    19 Q. (By Mr. Levin) Can you explain
    20 for us how the fibers from the coat got in
    21 the paint tray?
    22 MR. WOOD: Are you stipulating as
    23 a fact that the fibers that you say are in
    24 the paint tray, in fact, came from that coat
    25 that we earlier discussed, or is it simply a
    1 matter that you say they may have? Because
    2 I am not going to let her answer
    3 argumentative, hypothetical opinions. I will
    4 let her answer if you are going to state it
    5 as a matter of fact that that fiber came
    6 from that jacket.
    7 MR. LEVIN: I can state to you,
    8 Mr. Wood, that, given the current state of
    9 the scientific examination of fibers, that,
    10 based on the state of the art technology,
    11 that I believe, based on testing, that fibers
    12 from your client's coat are in the paint
    13 tray.
    14 MR. WOOD: Are you stating as a
    15 fact that they are from the coat or is it
    16 consistent with? What is the test result
    17 terminology? Is it conclusive? I mean, I
    18 think she is entitled to know that when you
    19 ask her to explain something.
    20 MR. KANE: It is identical in all
    21 scientific respects.
    22 MR. WOOD: What does that mean?
    23 Are you telling me it is conclusive?
    24 MR. KANE: It is identical.
    25 MR. WOOD: Are you saying it is
    1 a conclusive match?
    2 MR. KANE: You can draw your own
    3 conclusions.
    4 MR. WOOD: I am not going to
    5 draw my own conclusions.
    6 MR. KANE: I am saying it is
    7 identical.
    8 MR. WOOD: Well, what you are
    9 saying in terms of how you interpret a lab
    10 result may or may not be the lab result.
    11 If you have it, let's see it. I would be
    12 glad to let her answer a question about it,
    13 but I don't want to go into the area of
    14 where we are dealing with someone's
    15 interpretation of something that may not be a
    16 fact and have her explain something because
    17 she can't explain something that might be
    18 someone's opinion or someone's interpretation.
    19 She can try to answer something
    20 if you are stating it as a matter of fact.
    21 MR. LEVIN: Well, I believe that
    22 Mr. Kane's statement is accurate as to what
    23 the examiner would testify to.
    24 MR. WOOD: Will he testify that
    25 it is a conclusive match?
    1 MR. KANE: Yes.
    2 MR. WOOD: Everybody is -- you
    3 all want to take a minute and confer on
    4 that?
    5 MR. KANE: No.
    6 MR. WOOD: Because I want to make
    7 sure, if I am going to let her answer this,
    8 that you are representing and stipulating
    9 that it is a conclusive match.
    10 MR. KANE: Well, come on, Lin, we
    11 have been around a long time. You know, you
    12 know exactly what I am saying.
    13 MR. WOOD: No, I don't. I
    14 honestly do not.
    15 MR. KANE: Well, I am telling
    16 you, it is -- is it conclusive in the sense
    17 that, that there is something unique about it
    18 that could only come from a particular item,
    19 then the answer is no.
    20 Is it that it is identical in all
    21 respects to the fibers off of the jacket,
    22 then the answer is yes.
    23 Now, does that mean it is
    24 conclusive?
    25 MR. WOOD: It doesn't sound like
    1 it to me.
    2 MR. KANE: Then you have got your
    3 answer.
    4 MR. WOOD: It sounds like to
    5 me --
    6 MR. KANE: Then you have your
    7 answer.
    8 MR. WOOD: Then it is a matter
    9 of opinion. It is not a matter of fact.
    10 MR. KANE: Then you have your
    11 answer.
    12 MR. WOOD: I want to make sure,
    13 because this is an area that you are asking
    14 her to explain something that may or may not
    15 be a fact because you are representing to
    16 her, Ms. Ramsey, a fiber from your red and
    17 black and gray jacket was found in the paint
    18 tray, how do you explain it.
    19 I mean, if it is a matter of
    20 fact, I will let her answer that.
    21 MR. LEVIN: Well, Mr. Wood, let
    22 me -- I thought I made it as clear as
    23 possible. I will try to clarify for you.
    24 I assume that, in your practice,
    25 that you have dealt with --
    1 MR. WOOD: Don't assume anything
    2 about my practice. I am asking you a
    3 question. You used the term in your
    4 question, Mr. Levin, you used the term in
    5 your question, and I am sure that you have
    6 precisely framed your questions. You said
    7 appears.
    8 Now, "appears to be" and "is," in
    9 my practice, are two different things. I
    10 want to make very clear what the question is
    11 before I let her answer. That is all I am
    12 asking.
    13 MR. LEVIN: Given -- and I want
    14 to answer your question. I am going to try
    15 to answer your question before I phrase it
    16 to your client.
    17 Given the status of fiber
    18 analysis, the state of the art, that fiber
    19 is identical in all respects to fibers from
    20 your client's coat; however, as is the case
    21 with any type of scientific evidence, even
    22 DNA evidence, where you get numbers that say,
    23 for example, the likelihood of a random match
    24 would be 1 in, say, 14 trillion. An expert
    25 is not going to get up, they'll talk about
    1 numbers, but they are not going to get up
    2 and say that that is the DNA from that man.
    3 MR. WOOD: Maybe you should give
    4 us the numbers on this fiber.
    5 MR. LEVIN: There are no numbers
    6 on the fiber.
    7 MR. WOOD: Give us that, whatever
    8 you got, and we will look at it.
    9 MR. LEVIN: Do you understand
    10 what I'm saying? I don't want to, I don't
    11 want to mislead you because scientific
    12 evidence is always subject to --
    13 MR. WOOD: That's why I don't
    14 think she should be put into the position of
    15 explaining something that scientists may
    16 differ on.
    17 MR. LEVIN: Well, scientists will
    18 differ on many, many things.
    19 MR. WOOD: Well, then -- that is
    20 my point. She shouldn't be explaining
    21 something that one person may say this
    22 appears to be the case and the other person
    23 may say no, it doesn't appear to be the
    24 case. You are putting her in an incredibly
    25 awkward situation.
    1 CHIEF BECKNER: Let me try to
    2 offer a compromise.
    3 MR. WOOD: We are ready to hear
    4 it.
    5 CHIEF BECKNER: Instead of wording
    6 the question in terms of fibers from the
    7 jacket or appear to be from the jacket,
    8 maybe if you word it fibers that by
    9 scientific analysis are identical to fibers
    10 from the jacket and not say, not identify
    11 those fibers from the jacket but say
    12 identical to fibers --
    13 MR. WOOD: What if we left out
    14 the fiber problem altogether and just simply
    15 ask her whether or not she ever had the
    16 jacket, the red and black, gray jacket in
    17 the proximity of the paint tray. We don't
    18 have to fight the question of what the fiber
    19 is or isn't. Isn't that what you really
    20 want to find out?
    21 CHIEF BECKNER: Well, I think
    22 that is probably what Bruce and Mike were
    23 trying to get to is is there an explanation.
    24 MR. WOOD: Well, but again, I am
    25 not trying to prevent there from being an
    1 explanation as to the question of the jacket
    2 in proximity to the paint tray, but I am
    3 very much concerned about her trying to
    4 explain something that may or may not be the
    5 case scientifically based on opinion.
    6 MR. LEVIN: I will rephrase the
    7 question and maybe this will satisfy you.
    8 MR. WOOD: Okay.
    9 Q. (By Mr. Levin) Mrs. Ramsey, I
    10 have scientific evidence from forensic
    11 scientists that say that there's fibers in
    12 the paint tray that match your red jacket.
    13 I have no evidence from any scientist to
    14 suggest that those fibers are from any source
    15 other than your red jacket.
    16 MR. WOOD: Well, you can't ask
    17 her -- Come on. What other sources did they
    18 test? How many other red jackets and red
    19 and black jackets did they test? That is an
    20 unfair question on the face of it, Bruce.
    21 Did they test anything other than that red
    22 and black jacket?
    23 I mean, they can't have
    24 information that it could come from another
    25 source if they didn't test another source,
    1 for gosh sakes. So, I mean, that doesn't
    2 help solve the dilemma.
    3 I think what you want to know is,
    4 you suspect, apparently, for whatever reason,
    5 that there may be a match or there may be a
    6 fiber from her red and black jacket that was
    7 on the paint -- in the paint tray, but we
    8 are not at all clear whether that is a fact
    9 or whether that's just something that you
    10 believe may or may not be the case.
    11 MR. LEVIN: Well, I told you in
    12 the question and I told you face-to-face
    13 that, given the most sophisticated testing
    14 available at this time, there is fiber
    15 evidence in that paint tray that matches.
    16 MR. WOOD: Then fairly we would
    17 like to see that evidence so we can then let
    18 her answer it so she can fairly know what
    19 the actual results are.
    20 I think that is a fair request.
    21 MR. LEVIN: Whether it is her
    22 fiber or not, I mean, if she can say I
    23 can't explain it, I can't explain it, it
    24 doesn't matter what the test says.
    25 MR. WOOD: No, no, I think it
    1 would be fair for her to be able to
    2 recognize the question of whether this is
    3 something that she even has to explain.
    4 MR. MORRISSEY: Lin.
    5 MR. WOOD: You know, a red fiber
    6 can be in a paint tray from any number of
    7 sources. I mean, we don't, you are asking,
    8 specifically you are trying to attach
    9 apparently a red fiber, I take it from her
    10 jacket to the paint tray.
    11 MR. MORRISSEY: Lin, if we charge
    12 an intruder in this case, this is a question
    13 that is going to get asked her.
    14 MR. WOOD: Well, I mean, but
    15 you're going to be able, that intruder's
    16 defense lawyer is going to have the benefit
    17 of knowing what result, the test result that
    18 you are looking at; true? So why shouldn't
    19 Pat --
    20 MR. MORRISSEY: And he is going
    21 to be asking her this very same question.
    22 MR. WOOD: Wouldn't that person
    23 have the benefit of knowing your test result?
    24 MR. MORRISSEY: Exactly.
    25 MR. WOOD: And I think Patsy
    1 ought to have the benefit too because I am
    2 not going to let her speculate, and I don't
    3 think you want her to speculate, that is all
    4 I am saying. We will let her answer the
    5 question, but I would like for her to fairly
    6 know exactly what the factual underpinning is
    7 or even if it is a factual underpinning or
    8 whether it is a disputed issue in the case.
    9 And then if you all -- why don't
    10 we tag that and come back to it maybe after
    11 lunch and let me think about it a little bit
    12 and then you all think about it. And then
    13 maybe after, we will resolve it, I think, in
    14 a way that gets you the information that you
    15 want.
    16 MR. MORRISSEY: The problem is,
    17 even if it is somewhat in dispute, it is
    18 going to get asked. I mean, a judge is,
    19 would, would allow that. And, and these are
    20 questions, these kinds of questions are the
    21 things we need to know the answer to if we
    22 are confronted with a scenario where we have
    23 to put Mrs. Ramsey on the witness stand and
    24 subject her to, explain to us how is it that
    25 fibers that are identified back to your,
    1 quote, coat as the source. Now, you know --
    2 MR. WOOD: But her answer may be,
    3 you know, did you check anything else?
    4 MR. MORRISSEY: Well --
    5 MR. WOOD: I mean, you know, the
    6 intruder, what was, if you find the intruder
    7 and you find clothing there, did you check
    8 the intruder's clothing to see if it matches
    9 the same, better, or whatever. I mean,
    10 there are so many hypotheticals there that we
    11 just have to know what we are talking about,
    12 in all fairness, Mitch.
    13 MR. MORRISSEY: But you understand
    14 the position we are in as far as that is
    15 going to get asked.
    16 MR. WOOD: Yeah, but I also
    17 understand that the body or universe of
    18 evidence that may be in existence when that
    19 is asked is totally different than what
    20 exists here today. We don't even know what
    21 other items were tested. We don't even know
    22 what the test results are. And I am just
    23 very hesitant to have Patsy speculate over
    24 something that we don't know whether it is
    25 true or not, we don't know what other things
    1 were tested, et cetera.
    2 That is my dilemma. Let me think
    3 about it. We won't take a hard position on
    4 it yet, but you all think about it in terms
    5 of whether you might be able to can get some
    6 additional information on it and we can come
    7 back at a later date and answer it or we
    8 can do it in a different fashion.
    9 THE VIDEOGRAPHER: We need to
    10 make a tape change.
    11 MR. LEVIN: I think it is a good
    12 lunch break and you can think about it
    13 because there are other similar questions, so
    14 the answer, your decision on this will
    15 dictate what happens with a series of coming
    16 questions, just so you know what is coming.
    17 MR. WOOD: Well, and fairly, I
    18 anticipated there might be something because,
    19 I mean, the forensics issue is one that I
    20 think everyone is aware of, tests that have
    21 been done subsequent to June of 1998, and I
    22 just wanted to make sure that we were not
    23 asking her to answer questions that are based
    24 on what could be differing opinions on
    25 forensics --
    1 THE VIDEOGRAPHER: Audio cassette
    2 has ended.
    3 MR. WOOD: -- versus fact.
    4 MR. LEVIN: I understand, I
    5 understand your position.
    6 MR. WOOD: Okay, thank you.
    7 (A recess was taken.)
    8 MR. KANE: Are you ready to roll?
    10 MR. LEVIN: Yes. Mr. Wood, we
    11 left off with, I had posed the question to
    12 Mrs. Ramsey concerning her offering an
    13 explanation for fiber or fibers found in her
    14 paint tray. You did not want her to answer
    15 prior to the break. You wanted some time to
    16 think about it. I assume that you've had
    17 that opportunity. So the question now is
    18 will she answer the question?
    19 MR. WOOD: Not as phrased. And
    20 let me explain just quickly why.
    21 I do not want, nor do I think
    22 you should expect for Mrs. Ramsey, for Patsy,
    23 to speculate. Pure speculation is always
    24 fraught with peril in anybody's part. And
    25 your question not only calls for, I think,
    1 gross speculation, but it is at best a
    2 hypothetical that reasonably may not even be
    3 based on fact. Here is what I would offer
    4 in terms of a compromise, and that is, you
    5 have indicated, at least by your questions,
    6 that you are comfortable in giving us, at
    7 least, your verbal statement of the results
    8 of these tests.
    9 I think, if you would give us,
    10 subsequent to this or if you want to do it
    11 today, this afternoon, or tomorrow, you can
    12 get those, if you can give us the actual
    13 result, not looking for the details of the
    14 testing, but just the results, the
    15 terminology used, we will then consider,
    16 reconsider, and maybe we can get you some
    17 additional information.
    18 But right now as it stands, I am
    19 just not willing to let Patsy sit here and
    20 speculate about scenarios that may not, in
    21 fact, be based in fact. I just don't think
    22 that is fair.
    23 MR. LEVIN: Just so you know,
    24 what I would like to ask her is the
    25 following, and you will have this in case
    1 you have a change of heart in the future.
    2 MR. WOOD: Okay.
    3 MR. LEVIN: I think that is
    4 probably fair. Based on the state of the
    5 art scientific testing, we believe the fibers
    6 from her jacket were found in the paint
    7 tray, were found tied into the ligature found
    8 on JonBenet's neck, were found on the blanket
    9 that she is wrapped in, were found on the
    10 duct tape that is found on the mouth, and
    11 the question is, can she explain to us how
    12 those fibers appeared in those places that
    13 are associated with her daughter's death.
    14 And I understand you are not going to answer
    15 those.
    16 MR. WOOD: Right. Not, not
    17 without -- I mean, with all due respect,
    18 Bruce, even the discussion we had, as I can
    19 best recall it, we didn't get a consistent
    20 description of the fiber results on the
    21 question of the paint tray. You are sitting
    22 here making a record saying that it is a
    23 fact, and I don't know that.
    24 MR. LEVIN: I understand that,
    25 and I'm just --
    1 MR. WOOD: And I think what we
    2 will probably find, more likely than not, is
    3 when we look at your test results, we will
    4 find that there was -- there were fibers
    5 that were consistent with or similar to
    6 fibers that you believe were found on Patsy's
    7 sweater or jacket.
    8 I think we will also find, if you
    9 put all of the information out there, that
    10 there were an extraordinary number of fibers
    11 that are not, in fact, in any way similar to
    12 any item associated with Patsy Ramsey on
    13 these very items.
    14 And to single out now in this
    15 record and say a fiber was found on the
    16 ligature that was consistent with Patsy
    17 Ramsey's jacket, fairly, I think if asked,
    18 you would say, Mr. Wood, there were an
    19 extraordinary number of other fibers that we
    20 do not relate in any way to Mrs. Ramsey and
    21 probably you would tell me you don't have an
    22 explanation for.
    23 So I don't want this record to be
    24 accusatory based on your statements about the
    25 fibers. Fiber evidence, as you know, is
    1 pretty, pretty -- I won't say weak, but
    2 let's just say that it is subject to a great
    3 amount of debate in the profession. And
    4 that is why I am just not comfortable
    5 leaving your statements there without, I
    6 think, putting a more accurate picture,
    7 Bruce, on the whole record.
    8 MR. LEVIN: I understand your
    9 position.
    10 In addition to those questions,
    11 there are some others that I would like you
    12 to think about whether or not we can have
    13 Mrs. Ramsey perhaps in the future answer. I
    14 understand you are advising her not to today,
    15 and those are there are black fibers that,
    16 according to our testing that was conducted,
    17 that match one of the two shirts that was
    18 provided to us by the Ramseys, black shirt.
    19 Those are located in the
    20 underpants of JonBenet Ramsey, were found in
    21 her crotch area, and I believe those are two
    22 other areas that we have intended to ask
    23 Mrs. Ramsey about if she could help us in
    24 explaining their presence in those locations.
    25 MR. WOOD: And again, you state
    1 that on this record as fact, and I really
    2 think that is unfair. I think if you would
    3 produce the full truth of the fibers that
    4 you have collected that it would probably be
    5 at best similar to, which is not uncommon.
    6 And I think you would also probably have to
    7 admit that there are any number of other
    8 fibers found in these areas that you have no
    9 explanation for, and I don't want this record
    10 to be distorted down the road as being a
    11 situation where somehow there is greater
    12 weight given to these similar fibers you
    13 represent in terms of their location and
    14 their alleged origin than really is fair
    15 under the truth of fiber evidence and the
    16 total fiber evidence in this case.
    17 So I mean, I understand your
    18 position, and we may very well be able to
    19 get over it. You all are willing verbally
    20 to tell us the result. I think you clearly,
    21 in fairness, should be perfectly willing to
    22 show us the result. And when you do that,
    23 that would give us an opportunity to perhaps
    24 reconsider and answer the question.
    25 Would you all be willing to do
    1 that, Bruce?
    2 MR. LEVIN: I think that is
    3 something we'd have -- I would have to
    4 discuss with Chief Beckner. And I think you
    5 can appreciate why, when we are talking about
    6 physical evidence in an ongoing investigation,
    7 which is not a filed case, that we are
    8 reluctant to release reports.
    9 MR. WOOD: Well, in fairness to
    10 John and Patsy, though, you are willing to
    11 state that these fibers, you believe, match,
    12 and it seems to me then you are not giving
    13 away anything by simply giving us the actual
    14 result. What did the forensic expert say?
    15 What is the actual result?
    16 If you are willing to say it
    17 verbally and characterize it, it seems to me
    18 you don't jeopardize anything in an ongoing
    19 investigation not filed by giving us the
    20 result and letting us see if, in fact, what
    21 the result says is consistent with the way
    22 you represent it today. It seems to me that
    23 would be fair and wouldn't hurt you in the
    24 slightest.
    25 MR. LEVIN: I understand your
    1 position.
    2 MR. WOOD: Okay.
    3 Q. (By Mr. Levin) Mrs. Ramsey, your
    4 son Burke, when he was attending grammar
    5 school in Boulder, there was a weekly sort
    6 of report that was sent by the teacher to
    7 the parents. Do you recall that?
    8 A. Vaguely.
    9 Q. And you were, as a parent, given
    10 the opportunity or asked to provide some
    11 input or response to teacher's little report
    12 that was sent out once a week. Do you
    13 remember doing that? The Friday folder I
    14 think is what --
    15 A. Oh, Friday folder, yeah, I
    16 remember the Friday folder.
    17 Q. Okay. Up until the murder of
    18 your daughter, your, as a parent, your
    19 response in the Friday folder was always
    20 handwritten. Following the death of your
    21 daughter, your responses were always typed.
    22 Can you explain why you changed that?
    23 A. I didn't -- I wasn't aware that
    24 they were typed.
    25 MR. WOOD: Do you have any that
    1 you can let her look at?
    2 THE WITNESS: Do you have any of
    3 those?
    4 MR. LEVIN: I don't think we have
    5 any in the computer.
    6 MR. KANE: Not in the computer.
    7 MR. LEVIN: No, no, we don't have
    8 those.
    9 MR. WOOD: Are you representing
    10 that every one afterwards was in fact typed?
    11 MR. KANE: That is what Burke's
    12 teacher has told us.
    13 MR. WOOD: Do you have them, the
    14 actual reports?
    15 MR. KANE: We certainly don't
    16 have them here. I am not sure if we have
    17 them.
    18 MR. WOOD: Well, I --
    19 THE WITNESS: I don't ever
    20 remember -- I mean, I don't have any
    21 recollection of ever typing anything in the
    22 Friday folder, but --
    23 MR. WOOD: I mean, if we can see
    24 them somewhere down the road, that might help
    25 refresh and give us some indication of an
    1 explanation if they, in fact, are as you say
    2 or as his teacher says.
    3 Q. (By Mr. Levin) So I am assuming,
    4 Mrs. Ramsey, then the answer to my question,
    5 which was, can you explain why the change,
    6 you can't offer one because you don't recall
    7 the change occurring --
    8 A. Correct.
    9 Q. -- as you sit here today?
    10 A. Right.
    11 MR. LEVIN: Mike, do you have
    12 some more questions.
    13 MR. KANE: Yes.
    14 Q. (By Mr. Kane) Mrs. Ramsey, in
    15 your book, and it is in here numerous times
    16 on television programs after you wrote your
    17 -- first of all, why did you write the book?
    18 What was your primary purpose in writing this
    19 book?
    20 A. Primary purpose was to get
    21 information out about who we think the
    22 intruder was so that more people would be
    23 aware of that profile and could help us.
    24 Q. Okay. And that was your number
    25 one goal?
    1 A. Yes.
    2 Q. All right. In that book you talk
    3 about a chronology, I think you call it, of
    4 cooperation, something along that line, a
    5 chronicle of cooperation. Actually the
    6 second line, this is on page 393, Mr. Wood,
    7 it says police interviewed and questioned,
    8 police interviewed and questioned John and
    9 Patsy on December 27 and John again on
    10 December 28. Did you give any interviews to
    11 the police on the 27th? It was the day
    12 after you found her body.
    13 MR. WOOD: Are you talking about,
    14 what do you mean by, a sit down interview?
    15 MR. KANE: Well, it says here,
    16 police interviewed and questioned John and
    17 Patsy.
    18 THE WITNESS: Police were there
    19 in the home where we were staying, and we
    20 were talking with them all the time.
    21 Q. (By Mr. Kane) Were you
    22 interviewed and questioned on the 27th, to
    23 your recollection?
    24 A. To my best recollection, yes.
    25 Q. Do you remember having a meeting
    1 with, I am not sure if it was at Barbara
    2 Furner's house, but you met with Linda Arndt
    3 one time and I believe your mother was
    4 there? Do you remember that?
    5 A. My mother?
    6 Q. There was a meeting that was set
    7 up between sort of within the first couple
    8 of months of the homicide.
    9 MR. KANE: I don't know the date.
    10 MR. WOOD: January, February of
    11 '97?
    12 MR. KANE: Yeah. You met with
    13 Linda Arndt. And it was you and your mother
    14 and I believe Barbara Furner was there.
    15 THE WITNESS: Okay.
    16 MR. KANE: Remember that?
    17 THE WITNESS: I don't remember my
    18 mother being there, but I don't remember a
    19 lot from those days.
    20 Q. (By Mr. Kane) Okay. Why was it
    21 at that meeting that one of the ground rules
    22 was that you couldn't talk about the case?
    23 A. I don't know.
    24 Q. Well, that was your ground rule.
    25 MR. WOOD: Wait a minute. Help
    1 us know that. Whose ground rule was it?
    2 Linda Arndt? How was it conveyed? Who was
    3 it conveyed to?
    4 MR. KANE: Well, Linda Arndt was
    5 told.
    6 MR. WOOD: By whom?
    7 MR. KANE: By your lawyer.
    8 MR. WOOD: That is different.
    9 Come on.
    10 MR. KANE: During that meeting,
    11 do you recall at one point telling her that,
    12 when the subject matter of the case came up,
    13 that you couldn't talk about that?
    14 MR. WOOD: Do you have a
    15 statement? Do you have a recorded statement?
    16 Q. (By Mr. Kane) I am asking if
    17 you have a recollection of it.
    18 THE WITNESS: I have a
    19 recollection --
    20 MR. WOOD: Excuse me a second,
    21 Patsy. Do you have a statement that she
    22 made?
    23 MR. KANE: Yes, I do.
    24 MR. WOOD: Well, let her see it.
    25 MR. KANE: No, I don't, I don't
    1 have, there is no statement made just because
    2 there was no statement made. That was the
    3 point, there was no discussion --
    4 MR. WOOD: Was the discussion
    5 that you are talking about recorded?
    6 MR. KANE: No.
    7 MR. WOOD: No report was entered
    8 by Linda Arndt?
    9 MR. KANE: There was a report.
    10 MR. WOOD: Can we see that?
    11 MR. KANE: I don't have it here.
    12 It is Linda Arndt's report. It's not your
    13 client's report.
    14 MR. WOOD: But it's a statement
    15 you are trying --
    16 MR. KANE: I am asking if it is
    17 true or false.
    18 MR. WOOD: Let me finish. If
    19 you have a report, we can look at it in
    20 context. I think that would be fair.
    21 MR. KANE: No. Well, I am
    22 asking if she recalls it.
    23 MR. WOOD: I mean, if you are
    24 telling her that her lawyer told Linda Arndt
    25 that she didn't want her to discuss a
    1 certain area of questioning, are you asking
    2 her basically did you follow your lawyer's
    3 advice?
    4 MR. KANE: I am asking if she
    5 recalls having a meeting and recalls that
    6 that was one of the ground rules?
    7 MR. WOOD: Mr. Kane, when did
    8 this develop after June of 1998?
    9 MR. KANE: Once again, we are
    10 back to the question that I asked you
    11 earlier.
    12 MR. WOOD: It is a new question.
    13 Excuse me. It is a new question, based,
    14 though, on developments that have occurred or
    15 information that has been obtained since June
    16 of 1998.
    17 MR. KANE: So in other words, if
    18 it was something that was available at the
    19 time, you are saying you won't answer any
    20 question to anything that was available to us
    21 since June of 1998?
    22 MR. WOOD: Here is the question.
    23 Chief Beckner's letter to me of May the
    24 10th, since the last interviews you gave to
    25 law enforcement in June, a lot of information
    1 has been developed in the continuing
    2 investigation in JonBenet's death. This has
    3 resulted in many new questions.
    4 MR. KANE: Okay.
    5 MR. WOOD: Now, this information
    6 had to be known to Linda Arndt and to all
    7 of you back in 1997.
    8 MR. KANE: Well, I wasn't on the
    9 case until June of 1998, so it was news to
    10 me.
    11 MR. WOOD: Whether you were on
    12 the case or not does not dictate whether
    13 someone else on the case would know this.
    14 MR. KANE: Let's stop arguing.
    15 Are you telling her she can't answer any
    16 questions about this?
    17 MR. WOOD: No.
    18 MR. KANE: I don't want to debate
    19 it. It's either yes or no.
    20 MR. WOOD: It is not always black
    21 and white, Michael. Sometimes there is an
    22 in between.
    23 MR. KANE: That's what I'm
    24 saying, I'm asking the question and are you
    25 telling her not to answer or are you telling
    1 her to answer?
    2 MR. WOOD: Why don't you give me
    3 a minute.
    4 THE WITNESS: Why is it
    5 important --
    6 MR. KANE: There is nothing to
    7 debate, there is nothing to debate.
    8 MR. WOOD: I am not debating. I
    9 am looking through my notes here.
    10 This is Chief Beckner's letter of
    11 July the 13th. I believe we have made it
    12 clear in our telephone conversation on
    13 Friday, July the 7th, that our intent was to
    14 not rehash old questions but that we still
    15 had new questions on the prior evidence based
    16 on new information and additional forensic
    17 testing.
    18 Now, I don't think it can be any
    19 clearer. That is not a statement that we
    20 have new questions based on information we
    21 had prior to June of 1998 but we either
    22 forgot to ask or Mr. Kane was not involved
    23 in the case and would now like to ask.
    24 I didn't come in here with my
    25 client prepared to go into areas that I was
    1 never told we would go into. This is very
    2 clear that we are talking about subsequent to
    3 June of 1998.
    4 MR. KANE: So in other words --
    5 MR. WOOD: Don't you agree it is
    6 as clear as a bell, Mike?
    7 MR. KANE: We have been talking
    8 about December 26, 1996 all morning.
    9 MR. WOOD: Well, now, wait a
    10 minute, that's what I don't want to get into
    11 where you're going to start claiming that
    12 you're talking about a date certain now
    13 you've got the right to do it. I made it
    14 very clear when we talked about those dates
    15 today that you were asking about forensic
    16 tests that you got --
    17 MR. KANE: Lin, you made it
    18 clear.
    19 MR. MORRISSEY: The new
    20 information is in the book.
    21 MR. KANE: And that's where I am
    22 getting that.
    23 MR. WOOD: Well, tell us where in
    24 the book. That is not the question you
    25 asked. You are talking about Linda Arndt.
    1 MR. KANE: Okay. I am not going
    2 to ask that question, Lin, because it's clear
    3 you are not going to let her answer it.
    4 MR. WOOD: It is not clear.
    5 MR. KANE: So let the record
    6 reflect you will not let her answer the
    7 question.
    8 MR. WOOD: No, no, no. We will
    9 take a break. Let's take a break and make
    10 sure we don't get off track.
    11 MR. KANE: I said I'm withdrawing
    12 the question.
    13 MR. WOOD: We have been doing
    14 pretty well today. Let's take a moment and
    15 let everybody make sure we gather ourselves
    16 and then let's take a five-minute break. I
    17 don't want a problem that would disrupt this.
    18 MR. KANE: You don't want a
    19 problem, then let's get down to the
    20 bottom --
    21 MR. WOOD: Don't point your
    22 finger or we will have a problem with this.
    23 MR. KANE: Let's get down to the
    24 bottom line of this. We're down here
    25 purportedly because Mr. and Mrs. Ramsey want
    1 to solve the murder of their daughter. To
    2 get to that point, there is one prosecuting
    3 authority that's got any -- that's got any
    4 say in who gets prosecuted and when they get
    5 prosecuted, and that's the Boulder Police and
    6 the Boulder D.A.
    7 Now, unless we get beyond Mr. and
    8 Mrs. Ramsey, we are never going to get to
    9 the end of this case. And if the purpose,
    10 if your purpose in objecting is because you
    11 don't want to answer any questions that might
    12 reflect badly on them, well, then just simply
    13 state it. But if the purpose --
    14 MR. WOOD: That is so, pardon my
    15 language, asinine, Michael.
    16 MR. KANE: Then why are you not
    17 letting, why are you throwing up these
    18 artificial barriers?
    19 MR. WOOD: No, sir.
    20 MR. KANE: That is what you are
    21 doing.
    22 MR. WOOD: When you are finished,
    23 then I'll respond. You let me know when you
    24 are finished.
    25 MR. KANE: You are throwing up an
    1 artificial barrier to a simple question.
    2 MR. WOOD: You are misrepresenting
    3 what is happening here. Now, when you are
    4 finished, I don't want to interrupt.
    5 MR. KANE: The record will
    6 reflect it.
    7 MR. WOOD: The record will
    8 reflect what Chief Beckner asked my clients
    9 to do. I just read it verbatim from his
    10 July the 13th letter. That's what he made
    11 clear to us, that's what we agreed to do,
    12 that's what I brought them in here prepared
    13 to do.
    14 MR. KANE: Okay.
    15 MR. WOOD: I didn't, excuse me.
    16 I did not bring them in here prepared to go
    17 back and answer questions about things that
    18 occurred prior to June of 1998 that you all
    19 have known about all along and questioned
    20 them about in June of 1998 for three days,
    21 in April of 1997 for a day, and, fairly, if
    22 that's what you wanted to do, then you
    23 should have asked me that. I could have
    24 discussed it with them. They could have
    25 made a decision, which may very well have
    1 been to come in and do that with you. I
    2 don't know. But you didn't ask that.
    3 Now, you can't sit in here today
    4 and change the scope of what you asked for
    5 and turn around, because we say you didn't
    6 ask for it and we didn't agree, and then
    7 make this accusatory statement that is
    8 totally unsupported, and again, pardon my
    9 language, it's an asinine statement, that I'm
    10 objecting to questions the answers of which
    11 might reflect adversely on my client.
    12 I am going to try, and I've been
    13 doing, to give you all of the leeway I can
    14 within the framework of your request, but you
    15 don't have the right, Mr. Kane, to come in
    16 here and ask unfair questions, and you don't
    17 have the right to come in here and ask
    18 questions in subject matters that the Chief
    19 didn't ask for when he asked for the
    20 request. That's unfair, and I am not going
    21 to let it happen today, and it doesn't mean
    22 one thing in terms of it reflecting adversely
    23 or otherwise on my clients. It's simply not
    24 what you asked to do. Okay?
    25 MR. KANE: I said I withdrew the
    1 question.
    2 MR. WOOD: No, but then you made
    3 a speech. And then, well, usually as
    4 lawyers go, one good speech deserves another.
    5 Let's take two minutes now just so we can
    6 try and catch some water and take a break.
    7 All right? Because I usually, when we get
    8 into a little back and forth, it's better to
    9 get calmed down, stay focused and get the
    10 information that you came here to do. Let's
    11 take five minutes. All right?
    12 MR. KANE: It is your office.
    13 You do what you want.
    14 MR. WOOD: Well, I'm not being
    15 unfair about that. Anytime you say the same
    16 thing, just look over to me and say let's
    17 take five, okay?
    18 MR. KANE: That is fine.
    19 (WHEREUPON, a brief recess was
    20 taken.)
    21 THE VIDEOGRAPHER: All right.
    22 Q. (By Mr. Kane) Mrs. Ramsey, after
    23 the homicide, I mean, you mentioned several
    24 times in the book on several occasions where
    25 you wondered if the killer was watching you
    1 or following you. You know, I think you
    2 described one time when you had some cable
    3 that was cut at your house by some workmen
    4 and the lights were out or something like
    5 that, and Mr. Ramsey wondered if the killer
    6 might be in there.
    7 I mean, you had a concern about
    8 this person being out there and coming after
    9 you and your family after the homicide?
    10 A. Yes.
    11 Q. All right. And I take it your
    12 biggest concern was for Burke; is that
    13 correct?
    14 A. Yes.
    15 Q. All right. And you got -- there
    16 were some security arrangements for Burke
    17 when he went back to school, I believe, at
    18 the end of January. Were you involved in
    19 those discussions --
    20 A. Absolutely.
    21 Q. -- of the security arrangements?
    22 Do you remember who those took place with or
    23 where they took place?
    24 A. At the High Peak School, we made
    25 arrangements for Tracy Temple to be in there.
    1 She is with a security company in Colorado.
    2 There were also parent volunteers who sat
    3 outside the classroom and basically watched
    4 him at all times.
    5 Q. All right. And so you wanted to
    6 have security in the school in case somebody
    7 were to come in and try to do harm to
    8 Burke?
    9 A. And we set up a 911 system. The
    10 teacher, I believe the teacher and one of
    11 the parents would always have a little
    12 medallion that they could press in an
    13 emergency.
    14 Q. Why was Tracy Temple only hired
    15 for one week?
    16 MR. WOOD: Why was she what?
    17 Q. (By Mr. Kane) Why was Tracy
    18 Temple only employed for one week to be at
    19 the school?
    20 A. Well, we wanted her to stay
    21 longer, but the school felt like it was a
    22 disruption to the children.
    23 Q. So it was the school's decision,
    24 not yours?
    25 A. Yes. So we compromised and had
    1 the Burke watch set up.
    2 Q. Why did you insist that Ms.
    3 Temple be inside the classroom rather than
    4 out in the hall?
    5 A. She wasn't in the classroom.
    6 Q. No, no, no. Why did you -- but
    7 there was discussion that you had with the
    8 school authorities that Tracy be allowed to
    9 be inside the classroom, and the school
    10 authorities objected to that. Do you recall
    11 that?
    12 MR. WOOD: Do you represent that
    13 as fact?
    14 MR. KANE: Yeah, that's a fact.
    15 THE WITNESS: I don't, I --
    16 Q. (By Mr. Kane) Do you remember
    17 that?
    18 A. I don't remember that.
    19 Q. Okay. What was your concern? I
    20 mean, what was in your mind when you were
    21 trying to construct these security
    22 arrangements with the 911 thing, with
    23 Ms. Temple, with the moms and all? What was
    24 the scenario you had in mind that you were
    25 trying to protect against?
    1 A. One of my children had just been
    2 brutally murdered in the sanctity of our
    3 home. I have one remaining child, and I
    4 didn't want him let out of my sight. I
    5 didn't want him to return to school. I
    6 didn't want to return to Boulder. I was
    7 frightened for all of our safety.
    8 Then it became apparent that it
    9 would be in Burke's best interest to be back
    10 in a routine in his normal environment with
    11 his friends, and I saw the benefit of that.
    12 And I said the only way I will let him go
    13 is that if there is a great deal of security
    14 put in place.
    15 Q. And that's why you hired
    16 professionals such as Tracy Temple?
    17 A. Yes.
    18 Q. I think Ellis Armistead also had
    19 some involvement in that; correct?
    20 A. Well, together or somehow they
    21 installed that wiring system and all that
    22 kind of stuff.
    23 Q. Why did you allow Burke to go to
    24 school without a guard and have Susan Stein
    25 transport him?
    1 A. Well, Susan had the medallion.
    2 The medallion was in Burke's proximity at any
    3 given time.
    4 Q. That medallion worked in the
    5 school, it was tied into something in the
    6 principal's office; is that correct?
    7 A. Right, right.
    8 Q. So on the way to school it
    9 wouldn't work. Why did you allow her to go
    10 without any security and against Tracy
    11 Temple's advice, as a matter of fact, to be
    12 transported to and from school when he was
    13 most vulnerable?
    14 A. Well, he left the garage in a
    15 locked car and drove straight to school and
    16 then was escorted into the school.
    17 Q. You didn't have any concerns about
    18 somebody at a stop sign?
    19 MR. WOOD: Mr. Kane, Michael --
    20 MR. KANE: What is the objection
    21 now?
    22 MR. WOOD: I just wonder what
    23 does this have to do with the investigation
    24 into finding who killed JonBenet Ramsey?
    25 MR. KANE: The very fact that I'm
    1 asking it means it has something to do with
    2 it.
    3 MR. WOOD: What?
    4 MR. KANE: I don't have to, I
    5 don't have to, if you're now going to make
    6 me justify every question that I ask, now
    7 we're so, you know, in the very beginning,
    8 Lin, you sent a letter --
    9 MR. WOOD: Don't point.
    10 MR. KANE: I am not. I am just
    11 emphasizing. You sent a letter --
    12 MR. WOOD: I point sometimes.
    13 MR. KANE: You know, this is
    14 nothing personal. You are doing your job
    15 and I am doing mine.
    16 In the very beginning you sent a
    17 letter to us, and you laid down this fair
    18 and objective, as long as these questions are
    19 fair and objective you'll answer, and I wrote
    20 back to you, I wrote a letter back, and
    21 within five minutes of you getting that
    22 letter off your fax machine, you were on the
    23 phone with me. And then the next thing you
    24 said --
    25 MR. WOOD: You know, I wrote a
    1 letter to Chief Beckner, which I would be
    2 glad to make part of this record, and then I
    3 got a letter from you, and I called you.
    4 MR. KANE: That's right. And we
    5 spoke about that the next day.
    6 MR. WOOD: We talked for over an
    7 hour and a half.
    8 MR. KANE: And the next day you
    9 wrote another letter saying that there would
    10 be no conditions on this interview.
    11 MR. WOOD: Now, wait a minute.
    12 MR. KANE: Oh, yes, you did.
    13 MR. WOOD: I didn't impose any
    14 conditions.
    15 MR. KANE: You are now. Now
    16 you're asking me what's the purpose of me
    17 asking a question. That's a condition.
    18 MR. WOOD: No, it's not.
    19 MR. KANE: What do you call it?
    20 MR. WOOD: Just what it was.
    21 I asked you a question.
    22 MR. KANE: And I'm saying I don't
    23 have to explain my purpose. I am asking the
    24 question.
    25 MR. WOOD: Mr. Kane --
    1 MR. KANE: If you don't want to
    2 answer the question, don't answer it, but I
    3 don't have to justify the question.
    4 MR. WOOD: Mr. Kane, you
    5 misrepresent my letter to you. You
    6 misrepresent our conversation. You
    7 misrepresent your statements that I have
    8 imposed conditions. Let me finish.
    9 MR. KANE: You know, Mr. Wood,
    10 this is a sham.
    11 MR. WOOD: No, it's not.
    12 MR. KANE: This is a big
    13 publicity stunt on your part.
    14 MR. WOOD: No, it's not.
    15 MR. KANE: You want to go out
    16 there and say my clients answered every
    17 question. Well, don't say that because you
    18 are not letting your client answer this
    19 question.
    20 MR. WOOD: Mr. Kane, why don't
    21 you sit down and let's try --
    22 MR. KANE: You are obstructing.
    23 You are obstructing, Lin. You are asking me
    24 now to justify why I am asking the
    25 questions.
    1 MR. WOOD: Mr. Kane, sit down.
    2 Sit down.
    3 MR. KANE: Yes or no, can she
    4 answer that question?
    5 MR. WOOD: Mr. Kane, life does
    6 not always turn on what Michael Kane thinks
    7 is fair. Just give me a second. I don't
    8 think I am being unreasonable.
    9 MR. KANE: I think you are.
    10 You're asking me to justify.
    11 MR. WOOD: Give me a chance to
    12 talk without jumping up and making your
    13 preplanned speeches.
    14 MR. KANE: You stated your
    15 objection.
    16 MR. WOOD: Now wait a minute.
    17 You all made the request and you all set the
    18 conditions, and I agreed to them at the
    19 direction of John and Patsy. I got the
    20 letters that demonstrate and document that.
    21 The only thing I asked for was the courtesy
    22 of whether you would consider this being done
    23 in Atlanta, and you quickly said yes. I
    24 asked for a stenographic reporter because of
    25 the concern over an accurate transcript
    1 because there never had been one in the
    2 prior interviews in April of '97 and in June
    3 of 1998.
    4 And that's it. I didn't impose
    5 any conditions, and I don't want to be
    6 misrepresented in that connection.
    7 All I've done today, because I
    8 thought we were here to be productive, in
    9 looking for the killer of this child, the
    10 parents want to come in here and help you,
    11 but when you start asking questions about why
    12 did you let Burke go to school with Susan
    13 Stein, I mean, with all due respect, I mean,
    14 I haven't instructed that she can't answer
    15 it, but I don't think it's unfair and
    16 unreasonable for me to say, what in the
    17 world does that have to do with the question
    18 of moving this investigation forward on who
    19 killed this child.
    20 MR. KANE: Let's go back to what
    21 I said.
    22 MR. WOOD: I didn't mean to get
    23 you all upset and hot and bothered. I just
    24 thought it was a fair question. To my mind,
    25 Susan Stein drove Burke Ramsey to school in
    1 a locked automobile and dropped him off, I
    2 am having a lot of trouble finding something
    3 sinister about that or inconsistent with a
    4 parent's love and protection of their son.
    5 MR. KANE: Well, I think it is
    6 inconsistent, number one. Number two, it
    7 doesn't matter what I think.
    8 MR. WOOD: It does. You are the
    9 special prosecutor.
    10 MR. KANE: What matters is, if
    11 you ever think an intruder is going to be,
    12 and I'm going to go back to the speech I
    13 made in the very beginning that I made two
    14 years ago to John Ramsey, if you ever expect
    15 for us to be able to put a case against an
    16 intruder together, the intruder is going to
    17 ask that question. The intruder is going to
    18 say, why is it that the parents of a month
    19 after their child is murdered allow their son
    20 to be transported at a time when he is most
    21 vulnerable, at a time when their own security
    22 people said this is crazy to be transported
    23 with no protection. And that is a
    24 legitimate question.
    25 Now, are you going to let her
    1 answer or not?
    2 MR. WOOD: Let me say this to
    3 you. That, again, Mr. Kane -- and I don't
    4 mean, Mr. Kane -- Michael, you know, you
    5 have a perspective. I just think that what
    6 you are trying to represent about the lack
    7 of security --
    8 MR. KANE: Mr. Wood, you are an
    9 obstructionist.
    10 MR. WOOD: Let me finish, Mike.
    11 I'm not an obstructionist.
    12 MR. KANE: You go out there and
    13 you tell these press people that they
    14 cooperated, and I will go out and tell them
    15 what really happened in here.
    16 MR. WOOD: Mr. Kane, what's
    17 happened here is you are looking to storm
    18 out for no reason.
    19 MR. KANE: I'm looking to go
    20 storm out because I can't ask a question --
    21 MR. WOOD: Take five, take five
    22 minutes and be reasonable enough to listen.
    23 MR. KANE: Look, I don't need
    24 this. It is a game. You're playing a
    25 game.
    1 MR. LEVIN: Take five minute.
    2 MR. WOOD: Take five minutes.
    3 MR. KANE: Are we going to take
    4 every five minutes every time I ask a
    5 question because you want to, you want to
    6 know what it is that's in my mind. I just
    7 told you what's in my mind.
    8 MR. WOOD: Mr. Kane, we are both
    9 trying to do our jobs under very unusual and
    10 difficult circumstances.
    11 MR. KANE: Right. And my job is
    12 not to stand in the way of the truth.
    13 CHIEF BECKNER: Let us take a
    14 time out.
    15 MR. LEVIN: Let's take five
    16 minutes.
    17 MR. WOOD: If you are implying my
    18 job is to obstruct the truth, I take that as
    19 a professional insult. And you will not be
    20 staying in my office. I pay the rent here.
    21 I will not be insulted by you.
    22 MR. KANE: That's fine.
    23 CHIEF BECKNER: Time out. Time
    24 out.
    25 (A recess was taken.)
    1 (Mr. Morrissey is no longer
    2 present).
    3 MR. WOOD: It is my
    4 understanding, and, Chief Beckner, correct me
    5 if I am wrong, I will try to state it and
    6 see if we can get at least an accurate
    7 record of the ending of Patsy's interview.
    8 It is my understanding that the
    9 only area that you did not cover with Patsy
    10 Ramsey that you wanted to discuss with her
    11 today was the area of Burke's security.
    12 Other than the issue of the fiber results
    13 that we discussed right after lunch and just
    14 before lunch that we talked about we can
    15 address and perhaps come back and be able to
    16 deal with another day.
    17 CHIEF BECKNER: Correct.
    18 MR. WOOD: And you decided,
    19 because of my questions that resulted in the
    20 colloquy of counsel, that you do not wish to
    21 complete your questioning of Patsy on the
    22 issue of Burke's security, but it is my
    23 understanding that that was it in terms of
    24 what you wanted to talk to her about today
    25 is what you told me in the hallway, isn't
    1 it? Didn't you tell me that in the hall?
    2 CHIEF BECKNER: I told you that
    3 there was no reason to go further with
    4 Patsy. That was the consensus of the group.
    5 MR. WOOD: Well, I thought you
    6 told me -- but, Chief, you told me the only
    7 areas you had to wrap up with her anyway was
    8 the security and the fibers. The fibers we
    9 already agreed to disagree for the moment
    10 with the chance of resolution. Didn't you
    11 tell me that?
    12 CHIEF BECKNER: I don't know that
    13 I was that clear, and if I was, then I
    14 apologize.
    15 MR. WOOD: What other areas are
    16 there that you have to talk to Patsy Ramsey
    17 about? And if so, I want to make sure you
    18 understand, she is here, she is available,
    19 she is ready. The only question we had that
    20 has come up that has been an area to defer
    21 has been the area of the fibers.
    22 MR. LEVIN: Mr. Wood, let me
    23 address that issue, if I might, with you.
    24 We did have an opportunity, because it was
    25 left up in the air as to whether or not we
    1 would provide you with reports from our
    2 forensic experts, and we have discussed that,
    3 and we are not going to do that. And I
    4 understand that you will not permit her
    5 without seeing those reports, to answer those
    6 question, which we understand.
    7 CHIEF BECKNER: I will also say
    8 that was not a condition prior to this
    9 interview, that you had to see police reports
    10 or lab reports in order to answer questions
    11 based on evidence.
    12 MR. WOOD: No, no, no. The idea
    13 never was discussed. I mean, it's not a
    14 condition now.
    15 CHIEF BECKNER: So it was not a
    16 condition.
    17 MR. WOOD: And it's not a
    18 condition now. I simply said that it would
    19 be unfair to have a witness speculate about
    20 a scenario's explanation based on a
    21 representation of the significance of a
    22 forensic test on the fibers when it seems to
    23 me very simple, if you're going to sit here
    24 and say that it appears to be her jacket, a
    25 fiber from her jacket, and we are trying to
    1 figure out what "appears to be" means because
    2 it was one of the weak areas of evidence in
    3 the law, fiber evidence when you are talking
    4 about appears to be and similarities, that,
    5 you know, with all due respect, I wanted to
    6 see not the full report, just the conclusion
    7 of the person that did the test to find out
    8 if that is really an accurate
    9 characterization.
    10 And based on knowing that, in
    11 terms of it being in the examiner's words
    12 versus the prosecutor's words, we might very
    13 well be able to answer the question. That's
    14 not a condition. That's a fair request.
    15 You all don't want to be unfair, I wouldn't
    16 think.
    17 CHIEF BECKNER: Well, it is a
    18 condition, whether you think it is fair or
    19 unfair.
    20 MR. WOOD: You all throw around
    21 the word condition. If I ask a question, it
    22 becomes a condition. If I ask a question,
    23 in this man's mind, Mr. Kane's, it becomes
    24 an objection or instruction not to answer,
    25 which this record will not bear out.
    1 I mean, if you're telling me you
    2 have other areas for Patsy Ramsey and it's
    3 not what you just represented to me in the
    4 hallway, and I don't know if you were there
    5 or not, Ollie, but, Chief, you told me that
    6 was all you wanted to ask about anyway was
    7 the security and then the fibers and you
    8 were done.
    9 And you know, then I said, if
    10 that's the case, let's make that record and
    11 we will move on to John, but now Mr. Kane
    12 is saying there are other areas.
    13 MR. KANE: Well, I think given
    14 the fact that you put on three types of
    15 objections during the questioning, and let me
    16 just answer, the three objections that you
    17 raised are no question that has been covered
    18 before, and we have no problem with that
    19 from the very beginning, we don't want to
    20 plow old ground.
    21 MR. WOOD: Don't fault me for
    22 that one.
    23 MR. KANE: No, I am not. But
    24 there were two others that became clear
    25 today. And one was that you wouldn't
    1 entertain any question that involved
    2 information that was available to us before
    3 June of 1998 but not asked, and you made
    4 that specific --
    5 MR. WOOD: Don't fault me for
    6 that one because I read the Chief's
    7 letter --
    8 MR. KANE: Let me finish.
    9 MR. WOOD: You are making it
    10 sound like I did something wrong. All I'm
    11 doing is stating what we agreed to.
    12 MR. KANE: No. Well, see that's
    13 where we had the disagreement.
    14 MR. WOOD: Have I misread this
    15 letter?
    16 MR. KANE: That's where we have a
    17 disagreement.
    18 MR. WOOD: I am reading the
    19 letter that says, of July 13th, I think it's
    20 mis-dated June 13th --
    21 MR. KANE: Lin, Lin, you've
    22 already made a record of this. We don't
    23 need to, we don't need to hash this out.
    24 MR. WOOD: You are accusing me of
    25 doing something improper in my objection and
    1 yet you won't --
    2 MR. KANE: I am just stating, no,
    3 I am saying that's what you're interpreting
    4 your letter to mean that no question that
    5 could have been asked before June of 1998
    6 that wasn't asked.
    7 MR. WOOD: That is what it says.
    8 MR. KANE: Okay. That's all I
    9 am saying.
    10 MR. WOOD: It says our intent was
    11 not to rehash old questions but that we
    12 still had new questions over prior evidence
    13 based on new information and additional
    14 forensic testing. Asking old questions would
    15 be a waste of our time.
    16 That's what the Chief told me he
    17 wanted to do. Now you're making a record
    18 that says I'm somehow improper in objecting.
    19 MR. KANE: I am saying that's
    20 your -- no, I'm saying that's your
    21 interpretation of it.
    22 MR. WOOD: It is plain language.
    23 MR. KANE: We are debating an
    24 abstract of that.
    25 CHIEF BECKNER: In interpreting
    1 that, you are interpreting it differently.
    2 Over prior evidence, prior evidence can be at
    3 any time.
    4 MR. WOOD: But prior evidence
    5 based on new information and additional
    6 forensic information.
    7 CHIEF BECKNER: Sure.
    8 MR. WOOD: You can't leave that
    9 out.
    10 CHIEF BECKNER: No, I know. But
    11 you develop new information on old evidence
    12 oftentimes as we continue the investigation.
    13 MR. WOOD: And we got into the
    14 question about Linda Arndt on a meeting with
    15 her in February of '97, and I asked about
    16 whether that was based on new information or
    17 additional forensic testing, which wouldn't
    18 apply, and it seemed to me that Mitch
    19 Morrissey was getting ready to show us
    20 something in the book and then you all
    21 didn't want to go there.
    22 CHIEF BECKNER: Without debating
    23 that particular issue, I just want to make
    24 clear that --
    25 MR. WOOD: Let me tell you
    1 something, I know exactly what we came here
    2 to do, there's no doubt in my mind, it was
    3 documented by our letters. My clients are
    4 willing to do it. Patsy Ramsey is willing
    5 to complete any areas within what you ask
    6 and we agreed to do.
    7 MR. KANE: Okay. No. All I am
    8 saying --
    9 MR. WOOD: And if you're really
    10 telling me now that you've got a number of
    11 other areas for Patsy, different as I
    12 understood what you told me in the hall,
    13 Chief, and maybe I misunderstood, I thought I
    14 did understood. But I'll --
    15 CHIEF BECKNER: I said they
    16 didn't have any additional questions, and
    17 without the explanation it goes beyond that.
    18 MR. WOOD: Well, do you have any
    19 areas for Patsy Ramsey other than the
    20 security of Burke when he returned to school
    21 or what we've already made I think a clear
    22 record on about the fibers?
    23 MR. KANE: Yes, absolutely.
    24 MR. WOOD: Well, why don't we get
    25 her back in here and finish.
    1 MR. KANE: Fine, as long as
    2 you're not going to object, but if are you
    3 going to object and say, if the question
    4 could have been asked in June of '98 but it
    5 wasn't and the information that would have
    6 prompted that question was available in June
    7 of '98, but the question wasn't asked, if
    8 that's going to be your objection, then, no,
    9 I don't, but if that's the way you are
    10 interpreting what is agreed to --
    11 MR. WOOD: Why don't you, Mr.
    12 Kane, why don't you just state in plain
    13 English what you want to do. I thought it
    14 was clear as a bell from Chief Beckner's
    15 letters that you wanted to ask these new
    16 questions based on new information or
    17 information developed since June of 1998.
    18 MR. LEVIN: Mr. Wood, let me,
    19 I'll make this --
    20 MR. WOOD: That is what the
    21 letter says.
    22 MR. LEVIN: -- I will make this
    23 as clear as possible.
    24 MR. WOOD: That would help.
    25 MR. LEVIN: What we want to do
    1 is we would like to ask some questions of
    2 John Ramsey. The reason why we choose to
    3 ask additional or not additional questions of
    4 Patsy is not going to be productive to go
    5 back and forth.
    6 MR. WOOD: It is going to
    7 determine whether we can legitimately move
    8 forward with John. If you are going to walk
    9 out, in effect, of Patsy's interview, what's
    10 the difference? I am going to take the same
    11 position with John.
    12 MR. LEVIN: For whatever
    13 reason --
    14 MR. WOOD: I am going to make
    15 you live up to what you said you came here
    16 to do.
    17 MR. KANE: We keep debating.
    18 Okay. You're not even interpreting --
    19 MR. WOOD: Why don't you leave
    20 for a minute and let the lawyers work this
    21 out, John.
    22 (Mr. Ramsey leaves the deposition
    23 room).
    24 MR. WOOD: It's just not fair for
    25 John and Patsy to sit here and listen to us
    1 haggle back and forth.
    2 Let me say this, Michael, it
    3 makes no sense to me at all that you don't
    4 want to finish with Patsy.
    5 MR. KANE: It makes no sense at
    6 all --
    7 MR. WOOD: Make your record.
    8 MR. KANE: It makes no sense to
    9 me at all that you were going to object when
    10 we ask the question that could have been
    11 ask -- is this not what your objection is?
    12 Please. Tell me.
    13 I think you have raised three
    14 objections. We already went over the first
    15 one, nothing that was covered before. But
    16 the other two objections that you've raised
    17 are nothing that involved information that
    18 was available in June of '98 but that we
    19 didn't ask a question about.
    20 In other words, we are not going
    21 to get a second bite of the apple, something
    22 that could have been asked in June of 1998.
    23 Is that your objection? Is that how you are
    24 interpreting that?
    25 MR. WOOD: I really, with --
    1 MR. KANE: Is it or isn't it?
    2 Because if it's not the way you are
    3 interpreting it, let me ask the question.
    4 MR. WOOD: I told you I accepted
    5 on the face of what Chief Beckner asked us
    6 to do, and I think he put it in writing and
    7 I answered him back and said it, and this
    8 whole idea was to deal with new questions
    9 based on information developed since June of
    10 1998.
    11 MR. KANE: Right. And that's --
    12 MR. WOOD: Now, that's what you
    13 asked us to come here to do. John and
    14 Patsy directed me to agree to that. That's
    15 what they came in here prepared to do. It
    16 seems like what's happened is you would like
    17 to do more than that, and now you are upset
    18 with me because I won't say okay, let's go
    19 beyond what you asked for and they were
    20 prepared to do.
    21 MR. KANE: That's all I am saying
    22 is we have a disagreement. We have a
    23 disagreement.
    24 MR. WOOD: Why are you stopping
    25 it is what makes no sense. Maybe I will
    1 object to 10 questions out of the next 100.
    2 You will get 90 answers, Michael. Don't you
    3 want those 90?
    4 MR. KANE: Lin, that's not what
    5 you're --
    6 MR. WOOD: You came out here, we
    7 are ready to do it. Don't you want the
    8 information?
    9 MR. KANE: Absolutely. So why
    10 are you raising objections?
    11 MR. WOOD: Why are you abandoning
    12 the ability to --
    13 MR. KANE: All I'm saying is that
    14 I don't even know why we are having this
    15 discussion.
    16 MR. WOOD: Because you stormed --
    17 you threatened to storm out of the room and
    18 leave. You were packing your bag.
    19 MR. KANE: We are having this
    20 discussion because you said just a minute ago
    21 that it's your understanding that we only had
    22 one more area to cover, and I am telling
    23 you, and I'm telling you --
    24 MR. WOOD: I misunderstood what
    25 Chief -- I think Chief Beckner will come
    1 slightly to my defense in what I thought he
    2 told me was not unreasonable.
    3 CHIEF BECKNER: No, it is not.
    4 MR. WOOD: It is not.
    5 MR. KANE: Okay. That's fine.
    6 That's fine. But all I am saying to you is
    7 that that is not the case with me. Is that
    8 I have a lot of other questions, but if you
    9 are not going to, if you are going -- let
    10 me finish.
    11 If you are going to interpret
    12 that, because it's not clear, if you are
    13 going to interpret that to mean that no
    14 question that could have been asked but
    15 wasn't, then I have no further questions in
    16 that area, particularly when the third
    17 objection that you have raised is that we
    18 now have to explain what the relevance of a
    19 question is to further the investigation,
    20 which was the last objection that you raised.
    21 So given that, given that, those
    22 conditions, no, there is nothing further that
    23 we have of her.
    24 Okay? I mean, now we've made our
    25 record.
    1 MR. WOOD: Well, I didn't come
    2 here to make a record.
    3 MR. KANE: That's exactly what
    4 you said, that you want to make a record.
    5 MR. WOOD: Well, I didn't come
    6 here to make a record.
    7 MR. KANE: Neither did I. I
    8 came here to ask questions.
    9 MR. WOOD: I may be forced to
    10 make a record, which apparently I have been
    11 forced to do so, but I didn't came here to
    12 do it. I came here to present John and
    13 Patsy Ramsey to you and the other six
    14 interrogators to ask your questions and get
    15 answers to move this investigation forward.
    16 Okay?
    17 Now, I thought it was very clear
    18 what the request was. We spent some time
    19 clarifying it. It's documented. It seems
    20 to me that there shouldn't be any fighting
    21 over it. Maybe it's not what you thought
    22 coming in, Michael. Maybe you wanted more,
    23 but that's not what I was asked to give, and
    24 that's not what my clients came prepared to
    25 give. And what your request was, Chief, I
    1 thought and my clients thought, even though I
    2 had my lawyer concerns, that they thought it
    3 was reasonable and they would come here to
    4 help.
    5 I didn't make an objection about
    6 Burke's security. I asked a question. And
    7 I think it's a fair question. You could
    8 have said, Mr. Wood, I am not going to
    9 answer your question, and you could have
    10 forged on --
    11 MR. KANE: Which I did, and you
    12 still didn't let her answer it.
    13 MR. WOOD: I really think, I
    14 really -- I don't think you're going to
    15 find --
    16 MR. LEVIN: Just hang on a
    17 minute.
    18 MR. WOOD: -- where I instructed
    19 Patsy not to answer that question. I think
    20 what happened is you took off after me
    21 because you didn't like me asking you the
    22 question.
    23 MR. KANE: Whatever.
    24 MR. WOOD: I just, I hear
    25 everything you are saying, Michael, and with
    1 all due respect, it makes no sense to me,
    2 when we're here and Patsy is here, you
    3 brought six people out from Colorado -- well,
    4 six from Colorado, one from Pennsylvania, and
    5 you say you got other subject matters.
    6 Let's ask her the questions.
    7 If you -- look, so what if
    8 something comes up that as a lawyer I feel I
    9 have to give her instruction to protect my
    10 client's interests or to do what I think is
    11 fair in terms of the parameters of the
    12 agreement. You can't deny me that right.
    13 It doesn't mean that you're still not going
    14 to get information about things to do with
    15 this investigation that I think you would
    16 want to have.
    17 But you are saying, Mr. Wood,
    18 unless you agree to let her answer every
    19 question, even if you think it's unfair or
    20 outside the scope of the agreement, we are
    21 not going to ask her any questions. That,
    22 Michael, makes no sense to me, and I don't
    23 think it makes sense to any reasonable
    24 person.
    25 MR. KANE: Do you remember the
    1 letter I sent to you?
    2 MR. WOOD: I do. Painfully
    3 remember.
    4 MR. KANE: And where I said, you
    5 will remember, we object, Chief Beckner and I
    6 object to your placing a condition that as
    7 long as the questions are fair and objective,
    8 and I said that definition can be used to
    9 exclude anything.
    10 MR. WOOD: You haven't been
    11 excluded on hardly anything here today.
    12 MR. KANE: And you wrote -- and
    13 then you called me, and then you wrote the
    14 next day. You called me and said you're
    15 misinterpreting what I am saying.
    16 MR. WOOD: You were. You are
    17 misinterpreting what is happening here today.
    18 MR. KANE: You assured us, you
    19 assured us that was not designed and it was
    20 not going to be used to exclude questions.
    21 Look, you made your record. I made my
    22 record. There really is no record here.
    23 This isn't a deposition.
    24 MR. WOOD: I'm not, but I'm
    25 not --
    1 MR. KANE: We don't have a judge
    2 that we can go to with a motion to compel.
    3 Okay? We are used to civil cases, I think,
    4 you and I. We are not in front of a --
    5 this is simply questioning of individuals,
    6 and there is no reason to --
    7 MR. WOOD: I still haven't heard
    8 a reason why you don't want to ask Patsy
    9 other questions.
    10 MR. KANE: I stated my position,
    11 you stated your position, so I have no
    12 further questions based on what I stated.
    13 MR. WOOD: I am not sure what
    14 you stated.
    15 MR. KANE: It doesn't matter.
    16 MR. WOOD: It does matter. It
    17 does matter. It does matter.
    18 MR. KANE: Oh, Jesus, Lin. Let's
    19 go, guys.
    20 MR. WOOD: I sat here for a day,
    21 Michael --
    22 MR. KANE: Let's go.
    23 CHIEF BECKNER: Take five.
    24 MR. KANE: We're going to take
    25 five.
    1 CHIEF BECKNER: Let's take five.
    2 MR. KANE: We are going to take
    3 five.
    4 MR. WOOD: Stay on the record.
    5 I will say what I was going to say and we
    6 will come back and get going one way or the
    7 other.
    8 MR. KANE: Could we have a
    9 conference here?
    10 MR. WOOD: I mean --
    11 MR. KANE: You just said you --
    12 come on, Lin, five minutes ago you said I
    13 will extend the courtesy to you.
    14 MR. WOOD: I think you came here
    15 to leave. I don't think you came here to
    16 question.
    17 MR. KANE: I came here to ask
    18 questions, and I thought they had been
    19 answered --
    20 MR. WOOD: You have got them, you
    21 got them all, you got them, you got them,
    22 and now I am offering you more and you don't
    23 want them.
    24 MR. KANE: Lin, I'm not going to
    25 debate the point. I'm not going to debate
    1 the point. You have your interpretation.
    2 You have your spin.
    3 MR. WOOD: I don't have spin.
    4 MR. KANE: That is what it is.
    5 MR. WOOD: Listen to me, I don't
    6 have spin.
    7 MR. KANE: Don't point.
    8 MR. WOOD: I told you a minute
    9 ago, I do point occasionally. I don't have
    10 spin.
    11 MR. KANE: Okay. It doesn't
    12 matter.
    13 MR. WOOD: You people put a spin
    14 in this thing for three and a half years
    15 before I ever get involved with this thing.
    16 MR. KANE: I have never ever,
    17 ever -- the only time I have gone on the
    18 public record in this case, Lin, was to
    19 clear your client, Burke Ramsey, and to tell
    20 the world that it was outrageous what they
    21 did to Burke Ramsey, and you settled for
    22 probably millions a week later. So don't
    23 ever say that we spun anything. You're on
    24 every nightly television show for the past
    25 two weeks telling the public --
    1 MR. WOOD: That is a total
    2 exaggeration of the truth. I was on one
    3 series of days.
    4 MR. KANE: -- telling the public
    5 that you're here to say -- you are here,
    6 that your clients, against your advice, are
    7 going to answer any question, and we are
    8 finding out that is not the case.
    9 MR. LEVIN: Mr. Kane, let me
    10 interrupt for a second. Mr. Wood, let's --
    11 MR. WOOD: By the way, I didn't
    12 settle the case in December when your
    13 interview was published. It settled several
    14 months after.
    15 MR. KANE: Right. After I made
    16 the statement. Yeah.
    17 MR. WOOD: And I appreciated your
    18 candor with respect to that interview, and I
    19 so stated to you.
    20 MR. KANE: But it's the only time
    21 I've ever said anything publicly.
    22 MR. WOOD: I painted too broad of
    23 a brush when I said you all. You all
    24 probably meant the Boulder Police Department,
    25 at times the Boulder district attorney,
    1 former members of the police department.
    2 MR. KANE: Nobody present here.
    3 MR. WOOD: It's hard for me
    4 to -- well, I am not going to agree with
    5 that. It's hard for me to sit here and be
    6 accused of spin when all I do is turn on
    7 Good Morning America and get spin --
    8 MR. LEVIN: Mr. Wood, I've
    9 been --
    10 MR. WOOD: -- from the other
    11 side.
    12 MR. LEVIN: I am sorry, I did
    13 not mean to interrupt you. Are you
    14 finished?
    15 MR. WOOD: Yes, for the moment.
    16 MR. LEVIN: This is the bottom
    17 line. The bottom line is, for whatever
    18 reason, we have made a decision that we no
    19 longer wish to ask questions of your client,
    20 Mrs. Ramsey. We are asking you if we may
    21 begin to ask questions of John Ramsey,
    22 regardless of whatever is going on in your
    23 mind -- and no one is accusing you of any
    24 misconduct or ill purpose in any way, shape,
    25 or form -- all we are saying is we would
    1 like to begin questioning John. And we can
    2 do --
    3 MR. WOOD: And I would like you
    4 to finish with Patsy.
    5 MR. LEVIN: I understand that.
    6 We are finished with Patsy for whatever
    7 reason, and we stated what we believe is our
    8 reasons. We will not state any more. We
    9 would like to start questioning John --
    10 MR. WOOD: It is 4:15.
    11 MR. LEVIN: -- if we can do
    12 that, we will do that.
    13 MR. WOOD: It is 4:15. I am
    14 tired. I spent more time talking today than
    15 I thought I would have to. Why don't we
    16 come back at 9:00 and get John in the
    17 morning if that works. I mean, that seems
    18 to me reasonable.
    19 MR. KANE: It is a quarter to,
    20 we've taken a break every hour. We have
    21 taken an hour and a half.
    22 MR. WOOD: I am going to talk to
    23 John and Patsy and make a decision whether
    24 or not, when you come in here and you create
    25 what I think is an artificial record to
    1 somehow justify --
    2 MR. KANE: Okay. Go ahead. Go
    3 ahead, Lin.
    4 MR. LEVIN: Would you give us a
    5 couple of minutes to collectively discuss
    6 your timing proposal, please, sir?
    7 MR. WOOD: Okay. Let me have a
    8 couple of minutes while you are doing that
    9 to make sure because I have spoken without
    10 talking to John and Patsy.
    11 MR. LEVIN: We understand.
    12 MR. WOOD: Let me finish this by
    13 saying something to you, Michael. I don't
    14 know your background, but we are all trying
    15 to do our jobs, and I am not going to laugh
    16 at you. If you want to laugh when I say
    17 something, that is your prerogative. I just
    18 don't think that's productive because I
    19 think, of all the people, of all the
    20 people --
    21 MR. KANE: You are doing your
    22 job.
    23 MR. WOOD: -- who get involved,
    24 well I -- doing my job is not to laugh at
    25 another professional.
    1 But I think that, of all of the
    2 people who have been involved with this, that
    3 I have tried more, whether you think I have
    4 done everything that you wanted me to do, I
    5 think I have been on the phone and I have
    6 made a greater effort to try to get your
    7 side and my side together than anybody else.
    8 That doesn't fault anyone else
    9 involved. They made very good decisions in
    10 my judgment for their reasons. I don't
    11 criticize any other lawyer in this case. I
    12 only speak for myself. And I think that I
    13 have tried to be extremely reasonable. And
    14 I didn't physically block the door for John
    15 and Patsy to come in here. I didn't feel
    16 good about it. You know that one of the
    17 reasons that I didn't feel good about it was
    18 because you were going to be involved.
    19 I went to the Chief after your
    20 letters and our discussions and I said I
    21 have some real concerns about Michael Kane's
    22 objectivity, and I think it might be better
    23 if he were not involved, and I was told that
    24 your involvement would be a deal breaker.
    25 Either you got to be involved or nobody
    1 wanted to talk to John and Patsy.
    2 And I've got to tell you, with
    3 all due respect again -- I hate to use that
    4 phrase because usually you figure something
    5 bad is coming, and it usually does -- I
    6 think you came here on a self-fulfilling
    7 prophecy. I think you came in here ready to
    8 jump on me the minute I opened my mouth.
    9 If I made a request, it was going to be
    10 called a condition. If I asked a question,
    11 it would be deemed an objection. You kept
    12 trying to get me to say that I was
    13 instructing Patsy not to answer, and I don't
    14 think that is what I have done.
    15 I'll tell you this, if I did it,
    16 boy, I am going to be unhappy with myself
    17 because I sure didn't mean to do it. I
    18 wanted to facilitate your getting these
    19 questions answered. I still would like to
    20 do that. You haven't gotten on the plane to
    21 go back yet. I think it is still serves a
    22 purpose to try to sit here and answer some
    23 questions.
    24 So you all talk about timing, let
    25 me talk to John and Patsy, and let's see if
    1 there is any place to go. I hope there is.
    2 I hope we can still go forward and be
    3 productive. Okay?
    4 (WHEREUPON, a brief recess was
    5 taken.)
    6 MR. WOOD: Everybody ready? I
    7 don't know what you all decided, but I have
    8 spoken with John and Patsy. It was your
    9 condition, Chief and Mr. Kane, that Patsy
    10 Ramsey be finished first before John Ramsey
    11 was interviewed. It is my understanding that
    12 you've got a number of areas to inquire of
    13 Patsy Ramsey. She is here, and we are
    14 prepared to go forward and complete her,
    15 understanding that the fiber issue is one
    16 that we would, although you say you have
    17 made your decision, I would urge to you
    18 reflect upon it, perhaps reconsider it.
    19 But we are here for any and all
    20 other areas, but in all fairness to my
    21 clients, after you imposed this condition, I
    22 think it is proper that you finish with
    23 Patsy Ramsey before you do John Ramsey. And
    24 if you are unwilling to do that, then
    25 unfortunately your decision will end this
    1 day. So I will ask John to step out. I
    2 will let Patsy finish. It's your call.
    3 CHIEF BECKNER: If you have no
    4 other questions, then you have no other
    5 questions.
    6 MR. WOOD: If you are willing to
    7 stipulate that you had no further questions
    8 beyond the security and the fibers that we've
    9 already talked about ad nauseam, pardon my
    10 language, I think that is probably accurate,
    11 then John can go forward, but if you are
    12 telling me you have other questions, but for
    13 the reasons you've stated you are not going
    14 to ask them today, then we are done because
    15 I am going to insist that you live up to
    16 your demand that Patsy go first and be
    17 finished. I am not going to change my
    18 position about my right to defend my clients
    19 in what I think is a very clear
    20 understanding of what we agreed to do at
    21 your request.
    22 MR. KANE: Given what I --
    23 MR. WOOD: It is your call.
    24 MR. KANE: -- said about the
    25 parameters that you placed on it, I don't
    1 have any further questions.
    2 MR. LEVIN: And I am in the same
    3 position.
    4 MR. WOOD: But you acknowledge,
    5 absent my parameters, you have other areas
    6 for Patsy.
    7 MR. KANE: Yes.
    8 MR. WOOD: Well, she's here.
    9 We'll sit here for you to ask questions.
    10 MR. KANE: Okay. Well, then let
    11 me ask you this, are you going to raise
    12 those objections?
    13 MR. WOOD: I am going to continue
    14 to make sure that we play by the rules you
    15 all established, yes, sir.
    16 MR. KANE: I mean, we are back
    17 into the debate.
    18 CHIEF BECKNER: Now that is not
    19 fair if you say, based on those parameters
    20 they don't have any further questions. I
    21 don't know how it can be fair then to say,
    22 well, go ahead and ask those questions
    23 because you have parameters of what you are
    24 going to let her answer.
    25 MR. WOOD: I have not. That is
    1 not true. The only thing that I have told
    2 you that we will not answer today are the
    3 issues of the fiber based on what I think
    4 are potentially mischaracterizations of
    5 laboratory results that I would like to have
    6 verified just by the result itself so that
    7 we could then know exactly what facts we are
    8 testifying to as opposed to speculation on
    9 issues that may be hypothetical and not based
    10 in fact. And that's it. You won't find
    11 where I've instructed her not to answer
    12 another question.
    13 So she is here. We are prepared
    14 to go forward. You all insisted that there
    15 was some mystical, magical reason that she
    16 had to be finished before John could done,
    17 and if you didn't finish her you didn't want
    18 John. You either are going to do what you
    19 said you're going to do, gentlemen, or we
    20 are done.
    21 CHIEF BECKNER: I don't know
    22 where we ever said that.
    23 MR. WOOD: Let me just say
    24 this --
    25 MR. WOOD: You said it was a
    1 deal breaker, Patsy would go first or you
    2 wouldn't take John --
    3 MR. KANE: This is a just a
    4 tennis game.
    5 MR. WOOD: We assumed you
    6 wanted --
    7 CHIEF BECKNER: You assumed, but
    8 you are stating as though there were some
    9 statement somebody said that --
    10 MR. WOOD: Were you telling me
    11 you just wanted to start with her but not
    12 finish before you started John?
    13 CHIEF BECKNER: I didn't say
    14 that.
    15 MR. WOOD: Don't you think it is
    16 a reasonable assumption, when you insist on
    17 her going first, that I would have assumed
    18 you were going to finish her before you did
    19 John?
    20 CHIEF BECKNER: Not necessarily.
    21 MR. WOOD: Well, you changed --
    22 CHIEF BECKNER: -- ask her some
    23 additional questions.
    24 MR. WOOD: You can have John and
    25 Patsy back in an ongoing dialogue if we
    1 weren't involved in this kind of stuff. But
    2 this stuff is not going to be productive.
    3 It is unfortunate, but as they say, it --
    4 look, I do not believe that I ever agreed or
    5 you requested that Patsy start, not finish,
    6 John come back, Patsy come back. I don't
    7 think it ever was going to be a ping pong
    8 match with these people coming back and
    9 forth.
    10 I thought it was clear you wanted
    11 her first or you wouldn't talk to either
    12 one. I think it was a reasonable assumption
    13 on my part that meant you would finish her
    14 back to back as you called it, and then we
    15 would move on with John.
    16 Now you're telling me that's not
    17 necessarily the case, then I really am
    18 concerned about whether we can agree on
    19 anything in terms of what you mean when you
    20 talk plain and simple English. That is not
    21 meant to be defensive.
    22 CHIEF BECKNER: You said it was a
    23 condition. That was never a condition.
    24 MR. WOOD: It wasn't. It was an
    25 assumption on my part, when you said you
    1 wanted Patsy first, that we would finish her
    2 and go back to back with John. I don't
    3 think it was an unreasonable assumption on my
    4 part.
    5 But the point is, she is here,
    6 you have got, as you say, Mr. Kane, a murder
    7 you want to try to solve. You've all
    8 represented that you need to ask her
    9 questions. She may not be able to answer
    10 all of them because I may feel like that
    11 there are areas where I am not comfortable,
    12 for legitimate reasons in my mind, we may
    13 not reach agreement on the legitimacy of
    14 those. I am comfortable with what I have
    15 done so far. If you don't want the other
    16 part, then just say so.
    17 MR. KANE: I am not going to say
    18 a word, Mr. Wood, because every time I say a
    19 word, I hear a ten-minute speech.
    20 MR. WOOD: Well, then I think
    21 your characterization shows your lack of
    22 objectivity. Do you want to ask questions
    23 or not? Let's go. If you want to ask
    24 them, ask the next question.
    25 MR. KANE: Is Mr. Ramsey going to
    1 step out?
    2 MR. WOOD: All right.
    3 (Mr. Ramsey leaves the room. )
    4 MR. WOOD: Ready to go?
    5 MR. KANE: I am ready.
    6 Q. (By Mr. Kane) Mrs. Ramsey, the
    7 last question I asked you was, you had this
    8 concern about Burke and this killer and the
    9 potential that he could be harmed, and in
    10 spite of concerns by your security people,
    11 you had him transported to and from the
    12 school by Susan Stein. Did Ms. Stein have
    13 any kind of training in self-defense, to your
    14 knowledge?
    15 A. I don't know.
    16 Q. Does she have any kind of
    17 training in taking evasive maneuvers if
    18 someone were to try to get into her car at
    19 a stop sign or anything like that?
    20 A. I don't know if she had any
    21 formal training in that.
    22 Q. Was there a discussion, when you
    23 talked about security issues with either
    24 Tracy Temple or with Ellis Armistead, were
    25 you privy to discussions about the potential
    1 for harm to come to Burke while being
    2 transported to or from school?
    3 A. No.
    4 Q. And in your recollection, that
    5 never came up as an issue? Is that what
    6 you are saying?
    7 A. No.
    8 Q. No, it didn't come up or --
    9 A. I was unaware if it ever came up.
    10 Q. Okay. When I asked you about
    11 what it was that you had in mind in setting
    12 up a security system, I take it that you
    13 thought somebody could come into the school
    14 and do harm to Burke inside the school; is
    15 that correct?
    16 A. Correct.
    17 Q. Okay. The --
    18 A. That's inconclusive of media as
    19 well.
    20 Q. Oh, okay. But was it more media
    21 than the killer?
    22 A. Well, it was all of those. You
    23 know, the media would alert -- their presence
    24 there would alert everyone that Burke was at
    25 the school, so I wasn't crazy about them
    1 hanging around the school. Of course, the
    2 killer was still out there; although, we had
    3 been advised that he probably would not, you
    4 know, come out because now everybody is
    5 alerted and looking for him.
    6 You know, and then there is what
    7 they call copy cat people, you know, who
    8 want to get a piece of the publicity, and
    9 they would be lurking around.
    10 Q. And who was it who gave you this
    11 advice that the killer would probably not
    12 want to come back?
    13 A. John Douglas.
    14 Q. Okay. And did Mr. Douglas tell
    15 you that -- or what did he tell you?
    16 A. Well, he said we had to be aware
    17 of three situations. One, obviously the
    18 killer was at large; two, what you call a
    19 copy cat killer, somebody that says, oh, that
    20 looks like an interesting idea, I think I
    21 will try to do the same thing; and, three,
    22 what he termed vigilante perpetrators or
    23 whatever term you want to use for them. You
    24 know, somebody that says, oh, you know, the
    25 police aren't taking care of this, I will
    1 take care of it.
    2 In other words, just alerting us
    3 that there are a lot of crazy people out
    4 there.
    5 Q. And the first, so the first
    6 concern he said was that it was probably
    7 unlikely that the killer would come back, the
    8 person that perpetrated the crime; is that
    9 what he said?
    10 A. He said it was very unlikely.
    11 Q. Okay. But how about the copy cat
    12 killer, what kind of opinion did he offer
    13 about the potential for that?
    14 A. He said it was very great.
    15 Q. And this would be somebody who
    16 would try to pattern what had already
    17 happened to JonBenet, to do the same thing
    18 to Burke?
    19 A. Uh-huh (affirmative). Right.
    20 MR. LEVIN: Can I interrupt you
    21 just a second, Mike? I am sorry.
    22 MR. KANE: Yes.
    23 Q. (By Mr. Levin) Mrs. Ramsey, as I
    24 understand it, at this point in time, which
    25 would be early 1997, your belief was that
    1 the murder of your daughter was an act of
    2 retaliation for some unknown reason towards
    3 either you or your husband?
    4 A. Right.
    5 Q. You no longer hold that belief;
    6 correct?
    7 A. Not necessarily.
    8 Q. I was under the impression that,
    9 in your book, you stated you thought it was
    10 a pedophile.
    11 A. Well, it could be one in the
    12 same.
    13 Q. I see.
    14 MR. LEVIN: Thank you, ma'am.
    15 Q. (By Mr. Kane) In the third, the
    16 vigilante, what was Mr. Douglas' opinion
    17 about the probability or possibility about
    18 somebody feeling that the authorities weren't
    19 getting to the bottom of this so that they
    20 would do harm?
    21 A. Uh-huh (indicating affirmatively).
    22 Q. What was his opinion about how
    23 strong of a threat that was?
    24 A. He just thought it was very
    25 strong because, in his years of experience,
    1 there are lots of those kinds of strange
    2 people out there.
    3 Q. Did he talk to you about where
    4 your copy cat killer or vigilante might
    5 strike and where you should be careful?
    6 A. No.
    7 Q. But you thought that school was
    8 certainly one of the places that a person
    9 could come in?
    10 A. Well, since that's where Burke
    11 spent the greatest part of his day.
    12 Q. Okay.
    13 A. You know, I'm the mother of a
    14 murdered child. I was fearful, just fearful
    15 of everything. Most particularly about my
    16 child, my husband, and myself.
    17 Q. Okay. And, I mean, did you have
    18 discussions either with Mr. Douglas or with
    19 Ellis Armistead or any of the other security
    20 people that you had, had you had discussions
    21 with them about how somebody might pose a
    22 threat to Burke while he was in school?
    23 A. Not specifically.
    24 Q. Did you have any kind of security
    25 on Burke outside of school?
    1 A. Well, he was with us all the
    2 time. You know, he was pretty much in a
    3 protected environment other than the time he
    4 was in school.
    5 Q. When you say a protected
    6 environment, other than the fact that his
    7 parents were there, was there any protection
    8 afforded to him outside of school? You
    9 hired Tracy Temple, obviously, who was a
    10 trained martial arts person, I believe.
    11 A. Yeah. Well, we had, you know,
    12 for many days, we had security people, you
    13 know, with us at the homes where we were
    14 staying for quite some time.
    15 Q. Where, which homes?
    16 A. Jay Olowski's. I know we had
    17 somebody there then. And I believe there
    18 might have been someone when we were at Mike
    19 Bienam's house.
    20 Q. Who were these people? Who were
    21 the security people?
    22 A. Somebody Ellis's group sent.
    23 Q. So Ellis Armistead hired somebody
    24 to be at Jay Olowski's house?
    25 A. Yes.
    1 Q. Did they stay in the house or
    2 outside the house?
    3 A. Inside.
    4 Q. Inside the house?
    5 A. Mostly at night.
    6 Q. And you moved into Mike Bienam's
    7 house at some point?
    8 A. Uh-huh (affirmative).
    9 Q. Was that after Jay Olowski?
    10 A. No. That was before.
    11 Q. Okay. And then how about the
    12 Stein's, did you have anybody there?
    13 A. I can't remember. I don't think
    14 we did as much. We may have for a few
    15 days when we first got there.
    16 Q. The people, the security people
    17 that were hired while you were at Mike
    18 Bienam's, let me -- how long did you stay at
    19 Bienam's after?
    20 A. My memory is real fuzzy with
    21 those days, but -- I can't remember that. A
    22 few days. Maybe a week or something.
    23 Q. And then you went to Jay
    24 Olowski's?
    25 A. Right.
    1 Q. And you were there for a month or
    2 so?
    3 A. A couple of months, right.
    4 Q. And then you went to the Stein's?
    5 A. Right.
    6 Q. And this person or these people,
    7 how many -- was it one person that you had
    8 as security at Jay Olowski's or was it a
    9 series of people?
    10 A. It might be different people.
    11 Q. Was this 24 hour a day coverage?
    12 A. No. It was mostly at night.
    13 Q. And you say they were inside?
    14 They were hired to be inside the house?
    15 A. Yes.
    16 Q. For the whole time that you
    17 stayed at Jay Olowski's house?
    18 A. I don't remember. I don't know
    19 if it was the whole time.
    20 Q. Did these people -- this security,
    21 you don't remember who it was?
    22 A. No.
    23 Q. Did they have any -- did you
    24 discuss with them transporting Burke to
    25 school?
    1 A. No.
    2 Q. Did you discuss with anybody
    3 having a professional security person
    4 transport Burke to school?
    5 A. I don't know. John may have. I
    6 don't know.
    7 Q. How about you, though? You were
    8 involved in discussions with the school and
    9 with the school district and with the
    10 principal, I believe, is that correct, about
    11 security arrangements while Burke was in
    12 school?
    13 A. I think so, yes. I mean, part
    14 of the concern was I wanted him protected,
    15 but at the same time I didn't want him made
    16 paranoid, you know. And he didn't want -- I
    17 didn't want him -- he didn't like Tracy
    18 Temple being there. He said, mom, why is
    19 this woman watching me all the time, and he
    20 knew the kids knew that she was watching.
    21 And so I am trying to walk a
    22 fine line to keep me happy and peace of mind
    23 about the security of my child, at the same
    24 time not making him overly paranoid. So
    25 the, you know, the best situation that we
    1 could come up with that was satisfactory to
    2 both John and me was that he would be, you
    3 know, picked up by Susan Stein. She began
    4 taking him to school when we were at the
    5 Olowski's. She would take him, and I
    6 believe at that time nobody really knew where
    7 we were. And he would duck down, you know,
    8 and she would get him to the school and that
    9 kind of thing.
    10 Q. So you made a conscious decision
    11 then not to have security --
    12 A. In the transport.
    13 Q. -- because Burke didn't feel
    14 comfortable having security; is that what you
    15 --
    16 A. Right. He was, you know, he
    17 was --
    18 MR. WOOD: You are talking about
    19 the lady Temple?
    20 Q. (By Mr. Kane) No. You said
    21 that --
    22 A. Well, Susan, you know -- see, we
    23 were -- the objective was to try to give him
    24 as much normalcy as possible, but at the
    25 same time putting, you know, security,
    1 security measures in place that would, you
    2 know, ensure his security.
    3 Q. Why was the decision made to have
    4 the security inside the classroom versus to
    5 and from school?
    6 A. Well, because -- and she -- I
    7 don't believe Tracy was inside the classroom.
    8 I think she was standing in the hall like
    9 near close to the front doors so she could
    10 kind of be watching doors.
    11 Q. Well, inside the school proper.
    12 A. Yeah.
    13 Q. Why was the decision made, as you
    14 said --
    15 A. Well, it was much more of an
    16 uncontrolled environment. I mean, when you
    17 go from a locked garage to locked car to,
    18 you know, adult escort into the classroom,
    19 you know, that's pretty safe.
    20 Q. Is that what was represented to
    21 you, was that it was more secure -- it was
    22 more unsecure inside the school than it was
    23 going to and from school?
    24 A. Yes.
    25 Q. And who represented that to you?
    1 Who told you that? I mean, when you say
    2 that, let me ask it this way.
    3 When you say that was represented
    4 to you, was this represented to you by a
    5 security consultant or Tracy Temple or Ellis
    6 Armistead?
    7 A. I don't remember. You know, I
    8 just remember saying that I wanted somebody
    9 at the school watching, you know. And at
    10 first, you know, we put Tracy Temple there,
    11 and then, you know, Burke was bothered by
    12 her being there, the children didn't know who
    13 she was, and the school said, you know, this
    14 is kind of becoming disruptive.
    15 And I said, well, you know, if
    16 there is nobody there, he's coming out. And
    17 then is when Susan and Roxy Walker got
    18 together with the principal, I believe, and
    19 said, you know, could we set up what they
    20 call a Burke watch.
    21 And they had a team of volunteer
    22 parents, all of whom I knew, who volunteered
    23 around the clock to be right at the door,
    24 right outside the door of his fourth grade
    25 classroom.
    1 And if he went to the bathroom or
    2 somewhere, somebody would (indicating), you
    3 know, without being right on his back, but
    4 they were watching.
    5 Q. And what were they expected to do
    6 if somebody came into the school and tried
    7 to harm Burke?
    8 A. The first thing was to punch that
    9 Lavalier, and call 911 and start screaming.
    10 Q. And then what were they expected
    11 to do after doing this, while the 911
    12 response came in?
    13 A. I don't know --
    14 MR. WOOD: I don't want to stir
    15 this up, but, you know, you guys got all the
    16 meat off this chicken you are going to get.
    17 Come on, move on to something else. I am
    18 sitting here listening. You know, this is
    19 just absurd. This doesn't have anything to
    20 do with JonBenet's murder.
    21 MR. KANE: Are you asking her not
    22 to answer the question?
    23 MR. WOOD: I am asking you to
    24 move on to something productive. You just
    25 beat this one to death, man. Let's go.
    1 THE WITNESS: I don't know what
    2 they were supposed to do. They were
    3 supposed to be there as a pair of eyes on
    4 him and at a, you know, at an arm's length
    5 without disrupting him, necessarily, but
    6 keeping him as safe as possible.
    7 Q. (By Mr. Kane) Well, Mr. Douglas
    8 was brought into the case early, back in
    9 January of 1997, and why was he brought into
    10 the case?
    11 A. I --
    12 MR. WOOD: Mr. Kane, you don't
    13 really want to ask questions on stuff
    14 subsequent to June of 1998, do you?
    15 MR. KANE: I made the record. I
    16 said if the objection is going to be that I
    17 can't, then I have no further questions.
    18 And you said go ahead and ask your
    19 questions.
    20 MR. WOOD: No. I told you that
    21 I was not going to change my position. You
    22 were either going to do what Chief Beckner
    23 asked to be done and we agreed to --
    24 CHIEF BECKNER: Before we go on,
    25 time out, time out.
    1 MR. WOOD: Mr. Kane just wants a
    2 free-for-all. We didn't come here prepared
    3 to do that. Maybe we would have done it if
    4 you asked for it. I don't know. But this
    5 is not in good faith what you asked me to
    6 do, Chief.
    7 CHIEF BECKNER: Hang on here. I
    8 believe the questions you are leading up to
    9 are based on, while it goes back to an event
    10 prior to June of 1998, it is based on
    11 information from interviews that you got
    12 subsequent to June of 1998; isn't that
    13 correct.
    14 MR. KANE: Correct.
    15 MR. WOOD: Well, you all can work
    16 that out amongst themselves, but asking why
    17 they hired John Douglas, I mean, you know,
    18 that's just not going to get it, so I am
    19 going to ask you to move on to something
    20 that is new, a new question based on
    21 information developed or evidence since June
    22 of 1998.
    23 I'm going to draw the line now
    24 with you, and I am going to draw it very
    25 firm. Okay?
    1 If you want to make a record with
    2 me making that statement, I will be glad to
    3 make it each and every time, and maybe you
    4 will catch a question I will let her answer
    5 and maybe you won't.
    6 Q. (By Mr. Kane) Did John Douglas
    7 interview you?
    8 A. Yes.
    9 Q. Did he interview you individually?
    10 A. Individually? You mean like
    11 without anybody else in the room?
    12 Q. Well, when I say individually,
    13 without Mr. Ramsey being present.
    14 A. I believe so.
    15 Q. That's your recollection?
    16 A. Yes. I can't remember exactly.
    17 I mean, we have been with him, you know,
    18 more than once. So --
    19 Q. I am talking about back in
    20 January of 1997.
    21 MR. WOOD: Did you know that
    22 Mr. Douglas had been involved in January of
    23 1997?
    24 MR. KANE: I knew he was, but I
    25 was never given access to him until probably
    1 January of 1999.
    2 MR. WOOD: Is that --
    3 MR. KANE: I never got access to
    4 him until January of 1999. I asked.
    5 CHIEF BECKNER: So that's new
    6 information.
    7 MR. WOOD: What is new
    8 information, that he got access to him in
    9 January of 1999?
    10 MR. KANE: I got to ask him
    11 questions in January of 1999.
    12 MR. WOOD: What does that have to
    13 do with asking her questions?
    14 MR. KANE: Here we go again.
    15 Okay. Let's move on. I don't want to sit
    16 and debate this all day. I'll move on and
    17 note your objection.
    18 MR. WOOD: Thank you.
    19 Q. (By Mr. Kane) Okay. The
    20 JonBenet Ramsey Foundation, is that still in
    21 existence?
    22 A. Yes.
    23 Q. Does it have any money in it?
    24 A. A little.
    25 Q. What is the most it has had in
    1 it since it was started? Do you know?
    2 A. I don't know.
    3 Q. Do you have any idea?
    4 A. Not really. I don't keep the
    5 books.
    6 Q. Have you ever looked at the books
    7 of the Foundation or looked at any kind of a
    8 financial statement about it?
    9 A. I don't know that I have. I
    10 don't think so.
    11 Q. Have you ever conducted any kind
    12 of efforts to raise money for the Foundation?
    13 A. No.
    14 Q. Has the Foundation, to your
    15 knowledge, ever spent any money on any of
    16 the things that the purpose of it, you know,
    17 is stated --
    18 MR. WOOD: Other than what she
    19 told you about back in June of 1998?
    20 MR. KANE: I never asked anything
    21 in June of 1998.
    22 MR. WOOD: Are you representing
    23 to me that the Foundation was never discussed
    24 in June of 1998?
    25 MR. KANE: I don't know if it
    1 was or not. I don't think it was.
    2 MR. WOOD: Why don't you find
    3 that out, and then we will decide whether to
    4 answer it.
    5 THE WITNESS: I think I --
    6 MR. WOOD: Wait. He's going to
    7 find out whether he discussed it or not.
    8 MR. KANE: Okay. Here's
    9 another --
    10 MR. WOOD: I personally am
    11 getting disgusted that we are talking about
    12 the finances of the JonBenet Ramsey
    13 Foundation when we are supposed to be talking
    14 about information about the death of the
    15 child. I just am getting to the point where
    16 maybe I had enough.
    17 Do you want to ask something to
    18 move this investigation forward or do you
    19 want --
    20 MR. KANE: I feel this is moving
    21 it forward.
    22 MR. WOOD: I am sure you do,
    23 sir.
    24 MR. KANE: You know what, we are
    25 the only law enforcement agency that has the
    1 authority to --
    2 MR. WOOD: You are still a law
    3 enforcement agent?
    4 MR. KANE: I am under contract
    5 with the Boulder D.A.'s office.
    6 MR. WOOD: Do you have a copy of
    7 that contract?
    8 Are you being paid by the hour
    9 for your time here or are you doing it pro
    10 bono?
    11 MR. KANE: No. I'm being paid.
    12 I am being paid to be here.
    13 Q. (By Mr. Kane) What, to your
    14 knowledge, if any, money was spent for any
    15 purposes that the Foundation was being set up
    16 to advance?
    17 MR. WOOD: This is your last
    18 question on the Foundation unless you can
    19 relate it to who murdered the child. I am
    20 going to draw the line.
    21 THE WITNESS: There have been
    22 gifts donated if that's what you are asking.
    23 Q. (By Mr. Kane) No, I'm not asking
    24 about donations. I am asking about money
    25 going out.
    1 A. That is what I am saying. There
    2 have been gifts given to non-profits.
    3 Q. Do you know what those are?
    4 MR. WOOD: Didn't I just say that
    5 we need to move on to another subject? I
    6 think that --
    7 THE WITNESS: I do know some of
    8 them.
    9 MR. WOOD: Can you go on to
    10 something that will help us figure out who
    11 killed the child?
    12 MR. KANE: Lin, how do you, let
    13 me ask you then, will you please define --
    14 MR. WOOD: I mean, I'm so
    15 disgusted at what you are doing, I am not
    16 going to define anything for you, Mr. Kane.
    17 MR. KANE: Well, then I have no
    18 idea of whether any questions --
    19 MR. WOOD: I don't think you have
    20 any idea what is a relevant question in a
    21 murder investigation.
    22 MR. KANE: Now you're --
    23 MR. WOOD: I just think I'm
    24 just tired.
    25 MR. KANE: I think you are right.
    1 MR. WOOD: It's been a long day
    2 and I've had to listen to a lot of back and
    3 forth. It's five minutes to 5:00. Maybe
    4 I'm just wearing down. But, you know, why
    5 don't we just close it up --
    6 CHIEF BECKNER: Just keep going.
    7 MR. WOOD: Why don't we close it
    8 down for the day. 5:00 was my kind of cut
    9 off time anyway. I don't know about you
    10 all, but I am pretty tired.
    11 MR. KANE: I can go on all
    12 night.
    13 MR. WOOD: Mr. Kane, that
    14 doesn't -- I don't want to -- you may be
    15 Superman, but I'm not.
    16 MR. KANE: So are you saying you
    17 want to stop it? Obviously --
    18 MR. WOOD: No, I mean, I'm
    19 just --
    20 MR. KANE: Well, then tell me, do
    21 you want to stop it or keep going?
    22 MR. WOOD: My goal coming in was
    23 to go to 5:00, and it's five minutes to
    24 5:00.
    25 MR. KANE: Okay. Five more
    1 minutes.
    2 Q. (By Mr. Kane) All right. Since
    3 I can't ask my questions about the
    4 Foundation, I'll move on to something else.
    5 When you said in your book and
    6 you said recently in interviews that the
    7 reason, I don't know the specific page, but
    8 let me ask you.
    9 MR. WOOD: Let's try to find one.
    10 Q. (By Mr. Kane) The reason that
    11 you went on CNN in January of 1997 was
    12 because Fleet White insisted --
    13 MR. WOOD: Let's find that now.
    14 MR. KANE: I mean, is it --
    15 MR. WOOD: No, no, Patsy, please
    16 wait. You've got something in the book or
    17 some interview, please let us see it, put it
    18 in context.
    19 Q. (By Mr. Kane) Let me ask you
    20 this way, did you say that in your book?
    21 MR. WOOD: No. You already
    22 represented it's in the book and you're
    23 coming from there. So let's just find it in
    24 the book and let her look at it in context.
    25 MR. KANE: Okay. I will find
    1 it. I will find it.
    2 MS. HARMER: It is around 45, 44.
    3 Around 45, 44.
    4 MR. KANE: Thank you.
    5 Q. (By Mr. Kane) All right. Mr.
    6 Ramsey's statement on page 43.
    7 MR. WOOD: Hold on. We found
    8 it. Let me just take a look at it.
    9 Okay. We are with you.
    10 Q. (By Mr. Kane) This was obviously
    11 Mr. Ramsey stating this in the book, the
    12 last paragraph on page 43, but was that your
    13 understanding too? Is that why you went to
    14 see him, partially because Fleet had
    15 insisted?
    16 A. That was a large part of it.
    17 Q. Okay. Now, that was January the
    18 1st of 1997; is that correct? It was the
    19 day after the funeral.
    20 A. Was it? Okay. I don't remember
    21 what day it was.
    22 Q. All right. And this, you
    23 described, in that same chapter, that same
    24 page, about confrontations you had with
    25 Fleet.
    1 MR. WOOD: What page are you
    2 talking about now?
    3 MR. KANE: This whole, that's the
    4 whole chapter.
    5 MR. WOOD: The chapter Facing the
    6 Cameras?
    7 MR. KANE: Yes. I mean, the two
    8 paragraphs before that, after Fleet arrived
    9 in Atlanta, he kept arguing that we didn't
    10 need lawyers to defend us. The solution was
    11 to go on national television and tell our
    12 story.
    13 MR. WOOD: Okay.
    14 MR. KANE: There is a point in
    15 here, and if you are going to make me tell
    16 you the exact spot, I will find it for
    17 you where you say.
    18 MR. WOOD: We want to be fair.
    19 MR. KANE: -- Fleet got into --
    20 or you got a phone call from Mr. Ramsey's
    21 brother Jeff.
    22 MR. WOOD: What page are you on?
    23 MR. KANE: I don't have the page.
    24 MR. WOOD: Well, you have to --
    25 MR. KANE: All right. All right.
    1 I am not going to ask the question.
    2 MR. WOOD: I don't mind her
    3 answering if you just help us.
    4 THE WITNESS: Well, I mean, I
    5 remember --
    6 Q. (By Mr. Kane) You remember the
    7 whole thing? Okay, outside of the book --
    8 MR. WOOD: I want to put it
    9 in --
    10 MR. KANE: All right. I'll close
    11 the book. I won't --
    12 MR. WOOD: I do want to see what
    13 you're talking about in the book.
    14 THE WITNESS: There is someplace
    15 where John talks about with you know
    16 Fleet --
    17 MR. WOOD: Jane, do you know?
    18 MS. HARMER: I believe she made a
    19 statement today in this interview prior about
    20 this situation.
    21 MR. KANE: There have been a
    22 bunch of statements. I am not going to
    23 quote the book.
    24 MR. WOOD: But you started the
    25 book and you leave it dangling about the
    1 book, and I want you to help me find in the
    2 book what you're talking about.
    3 MR. KANE: It is my question
    4 though. It is my question.
    5 MR. WOOD: And it's not my
    6 witness.
    7 MR. KANE: I am withdrawing that
    8 part of the --
    9 Q. (By Mr. Kane) Isn't it not true,
    10 Mrs. Ramsey, that Fleet White, according to
    11 John's brother, that Fleet and he got into
    12 some kind of argument and you got a phone
    13 call at your mother's house that Fleet was
    14 on his way over?
    15 MR. WOOD: Hold on. The reason
    16 I am asking for the book here is you all
    17 asked about that, haven't you? And I
    18 thought we were going to have some new
    19 information in the book that would go back
    20 over that.
    21 MR. KANE: It is repeated in the
    22 book.
    23 MR. WOOD: Then what is the new
    24 information? I mean, what's the point of
    25 having her restate it?
    1 MR. KANE: Are you saying we are
    2 quitting at 5:00?
    3 MR. WOOD: I know I am pretty
    4 tired. I know you are not. Guys, what
    5 time is it, what's Colorado time right now?
    6 CHIEF BECKNER: 3:00.
    7 MR. WOOD: Well, no wonder I am
    8 the only one tired. I am in Georgia time.
    9 MR. KANE: I live in the east.
    10 MR. WOOD: You already told me
    11 you can go all night. I already told you I
    12 can't keep up with that.
    13 CHIEF BECKNER: How much more do
    14 we have?
    15 MR. KANE: Lots and lots of
    16 stuff.
    17 MR. WOOD: Well, we might as well
    18 come back.
    19 CHIEF BECKNER: Do you have an
    20 accurate --
    21 MR. WOOD: Let's kick it off
    22 tomorrow at 9:00.
    23 MR. LEVIN: Your clients will
    24 both be available tomorrow?
    25 MR. WOOD: That was our
    1 agreement. We will live up to our
    2 agreement.
    3 MR. KANE: Okay.
    4 (Whereupon, the videotaped
    5 interview of PATSY RAMSEY was continued to
    6 August 29, 2000.)
    7 .
    8 .
    9 .
    10 .
    11 .
    12 .
    13 .
    14 .
    15 .
    16 .
    17 .
    18 .
    19 .
    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 .
    19 My commission expires on the
    20 17th day of March, 2001.
    21 .
    22 .
    23 .
    24 .
    25 .
  3. Tricia

    Tricia Administrator Staff Member


    5 August 29, 2000
    8 2140 The Equitable Building
    100 Peachtree Street
    9 Atlanta, Georgia
    12 Alexander J. Gallo, CCR-B-1332
    2 On behalf of John and Patsy Ramsey:
    3 L. LIN WOOD, Esq.
    4 Law Offices of L. Lin Wood
    5 2140 The Equitable Building
    6 100 Peachtree Street
    7 Atlanta, Georgia 30303
    8 .
    9 On behalf of The United States:
    10 MICHAEL KANE, Esq.
    11 BRUCE LEVIN, Esq.
    16 .
    17 Also present:
    18 Ollie Gray
    19 John San Agustin
    20 .
    21 .
    22 .
    23 .
    24 .
    25 .
    2 Volume II
    3 August 29, 2000
    4 CHIEF BECKNER: Okay. Mrs.
    5 Ramsey, we only have a few more things we
    6 want to ask you to finish up today. One of
    7 the things, I just want to give you the
    8 opportunity, if there is anything that you
    9 want to tell us, information that you have
    10 that you didn't tell us yesterday during the
    11 questioning, any other theories you may have,
    12 anything like that.
    13 I just want to kind of ask you
    14 an open-ended -- do you have any other
    15 information you expect to be able to tell us
    16 today that we didn't ask you about?
    17 MR. WOOD: I just can't let -- I
    18 will submit that to you in writing. That is
    19 such an open-ended question for her to sit
    20 here and try to be sure she could actually
    21 give that all to you, Chief.
    22 CHIEF BECKNER: Okay.
    23 MR. WOOD: That would be almost
    24 like her trying to sit here inventing in her
    25 own mind a whole range of questions that you
    1 could have asked her but didn't. I will
    2 tell you, to the extent we have any
    3 information that relates to the question of
    4 JonBenet's death from our investigation or
    5 otherwise, we will give it to you. I would
    6 rather do it that way than for Patsy to try
    7 to sit here today and try to give it to you
    8 off the top of her head. Okay?
    9 CHIEF BECKNER: Okay.
    10 MR. WOOD: Is that okay with you,
    11 Patsy?
    12 THE WITNESS: Well, I believe we
    13 have been giving, all along the way, what
    14 Ollie has come up with and Ellis and John
    15 Foster. I mean, as soon as we get
    16 something, we send it over.
    17 CHIEF BECKNER: I was trying to
    18 ask you what your thoughts were specifically,
    19 having that information, had you developed
    20 any thoughts? I mean, obviously, you being
    21 part of the family, as an example, any of
    22 the names that your investigators have
    23 provided to you, any of those ring a bell in
    24 terms of known to the family, you had
    25 interactions with that person, business
    1 relations with that person?
    2 MR. WOOD: If we get a specific
    3 name, if you want us to go pull names now
    4 and let her go through them, if you want to
    5 all go through them or if you have them.
    6 CHIEF BECKNER: I guess I am
    7 assuming that, over the last three and a
    8 half years, you have been privy to names of
    9 people that your investigators have
    10 investigated. If that is not the case
    11 A. Yes.
    12 MR. WOOD: But I am not sure she
    13 memorized them. We have them. I can go
    14 get them.
    15 THE WITNESS: Yes.
    16 MR. WOOD: The problem is, for
    17 you to, just to be fair, we've got names,
    18 and if you want to go through each one of
    19 them with her to see if --
    20 THE WITNESS: That would be
    21 great.
    22 MR. WOOD: John can do that too.
    23 CHIEF BECKNER: My thought is, if
    24 you are looking at 20 names that your
    25 investigators have looked at, if a name
    1 stands out as we had business dealings with
    2 that person, I would think you would remember
    3 it.
    4 THE WITNESS: Well, there's a lot
    5 of them.
    6 MR. WOOD: That you remember?
    7 THE WITNESS: Well, I can't
    8 remember names because some of them I hadn't
    9 known before, but a lot of information has
    10 come up that has been very interesting. I
    11 mean --
    12 CHIEF BECKNER: Let me ask you
    13 this. Do you recall seeing any of the
    14 names, you don't have to tell me the name,
    15 that said, ah, we know that person?
    16 THE WITNESS: Well, of course
    17 they looked at Bill McReynolds. We know
    18 that person. They looked at Linda Hoffman
    19 Pugh, the housekeeper, and some family
    20 members of hers. They looked at Chris Wolf,
    21 of course. You know, and then there are
    22 some people that have a record, you know,
    23 that are kind of not so nice people like
    24 this Helgoth and -- I mean, there are lots
    25 of other names like that.
    1 MR. WOOD: How many names, Ollie,
    2 are we talking about? How many names would
    3 you state right now?
    4 MR. GRAY: That I would recommend
    5 them look at or something?
    6 MR. WOOD: Yes.
    7 MR. GRAY: There are probably
    8 six.
    9 MR. WOOD: Other than the ones
    10 that Patsy just went through?
    11 MR. GRAY: Yes.
    12 MR. WOOD: I am familiar with
    13 names, and I don't remember them, Chief.
    14 That is why I say, if you want us to get
    15 the names. Have they been provided to the
    16 Chief?
    17 MR. GRAY: Probably all except
    18 the last couple, the Westminster that I told
    19 you about and that kind of stuff.
    20 MR. LEVIN: I would suggest that,
    21 if we are talking six or eight people, that,
    22 when we finish with Mrs. Ramsey and get
    23 Mr. Ramsey, perhaps you or your investigator
    24 could get that list and we could talk about
    25 it then.
    1 MR. WOOD: Okay.
    2 MR. LEVIN: Just for purposes of
    3 keeping things going.
    4 MR. WOOD: Is that all right?
    5 CHIEF BECKNER: That's fine, but
    6 nothing sticks out in your mind in terms
    7 of --
    8 THE WITNESS: Well, the most
    9 recent thing that sticks out in my mind is
    10 that Ollie obtained the Hi-Tec boots that
    11 belonged to Helgoth, and that was very, you
    12 know, surprising to me that he came up with
    13 those. And I just am real curious as to
    14 whether that -- you know, I don't know how
    15 much of a footprint you all have, but does
    16 it match and what have you done with that.
    17 CHIEF BECKNER: That is something
    18 we are still looking into.
    19 Was Helgoth known, when that name
    20 came up, was Helgoth somebody you knew prior
    21 to this investigation?
    22 THE WITNESS: I don't know. I
    23 don't know what his business was or -- I
    24 don't know any more about him than that.
    25 CHIEF BECKNER: The reason I am
    1 asking, one of the theories, obviously, is,
    2 if this is an intruder, they had to know the
    3 family pretty well, they had to know the
    4 house, the layout of the house, they had to
    5 know some things about the family based on
    6 what was in the note, those kind of things.
    7 MR. WOOD: And they could have
    8 otherwise learned all of that when they were
    9 there like they were in September of '97 for
    10 several hours when the family was away?
    11 There is a chance that everything in that
    12 note in terms of the family could have been
    13 gleaned from different things in the house if
    14 somebody had been in there, so it is not
    15 exclusive the idea that somebody had to know
    16 the family, while I understand where you are
    17 coming from.
    18 THE WITNESS: Oh, no, I'm --
    19 MR. WOOD: You've got another
    20 incident in Boulder nine months later, in all
    21 fairness, where someone did camp out in the
    22 house.
    23 CHIEF BECKNER: That hasn't been
    24 proven.
    25 MR. WOOD: That is what the
    1 parents say.
    2 CHIEF BECKNER: That's what they
    3 believe, yes, but that doesn't --
    4 MR. WOOD: And they believe it to
    5 this day, from what I'm told, concluding that
    6 their daughter was a petite, small
    7 14-year-old, didn't necessarily look her age.
    8 THE WITNESS: And the girl who
    9 was molested, this same incident, and
    10 JonBenet attended the same dancing school.
    11 CHIEF BECKNER: Right. We know
    12 that.
    13 THE WITNESS: So there could
    14 be --
    15 MR. WOOD: I think that is
    16 probably something that we want -- one of
    17 the people that you may or may not have,
    18 what we understand, have not talked to, the
    19 person who works there.
    20 CHIEF BECKNER: At the dance
    21 school?
    22 MR. WOOD: Right.
    23 CHIEF BECKNER: I don't know. I
    24 can't answer that.
    25 THE WITNESS: I mean, that could
    1 be --
    2 MR. WOOD: If you can't answer
    3 it, it is kind of hard for her to be able
    4 to, in all fairness.
    5 CHIEF BECKNER: In terms of
    6 whether we talked to that particular person
    7 you talked about. We talked to over 600
    8 people.
    9 THE WITNESS: But there could be
    10 a situation there that I didn't know that
    11 this particular person, but he, you know, saw
    12 JonBenet and found out where we lived or
    13 whatever.
    14 MR. LEVIN: Mrs. Ramsey, I think
    15 the question, and let me see if I can make
    16 it very simple, that the chief was getting
    17 at was Mr. Helgoth's name, was that a name
    18 that was prior to the murder of your
    19 daughter? I know since then you've became
    20 familiar with it, but prior to the murder of
    21 your daughter, was that a name you were
    22 familiar with?
    23 THE WITNESS: No.
    24 CHIEF BECKNER: I don't think you
    25 talked about Jeff Merit or Jeff Merit's wife
    1 yesterday. Am I remembering that correctly?
    2 MR. WOOD: I don't know Jeff
    3 Merit. I don't think you asked about him or
    4 his wife
    5 THE WITNESS: No, we didn't speak
    6 of him --
    7 MR. WOOD: -- or Jeff Merit by
    8 name.
    9 CHIEF BECKNER: When Bruce was
    10 asking you yesterday about people who were
    11 mentioned as possible suspects, Jeff Merrick
    12 or his wife was mentioned at one time.
    13 THE WITNESS: Right.
    14 CHIEF BECKNER: Do you not
    15 consider either Jeff or his wife no longer
    16 possible suspects?
    17 THE WITNESS: Well, early on we
    18 provided a list, Boulder police or whomever,
    19 said who could -- is there anybody that
    20 could be angry with you all or you know had
    21 a reason or who had access to the -- I mean
    22 because we made lengthy lists of those. And
    23 I believe John, you know, mentioned Mr.
    24 Merrick among that list because he had been
    25 let go from Access.
    1 And I remember very vividly that
    2 the day he was going to be asked to let go,
    3 I was afraid. Not unlike the postal
    4 incidents that happen. I was just afraid
    5 for my father and John and -- because you
    6 never know what people are going to do when
    7 they are asked to leave a company.
    8 And subsequent to that, when he
    9 was asked to leave, he made some threats to
    10 John and I think maybe even to my father.
    11 That -- I mean, I am paraphrasing. I don't
    12 know exactly. You can ask John, but
    13 something like you are going to be sorry. I
    14 am going to bring this company to your
    15 knees. Just really, you know, ugly.
    16 Q. (By Mr. Levin) Mrs. Ramsey,
    17 since June of 19
    18 MR. WOOD: Let me ask you, I
    19 think what you were asking her is anything,
    20 have you learned anything that has caused you
    21 to have less concern about potentially
    22 Merrick.
    23 THE WITNESS: No.
    24 MR. WOOD: Right now I can tell
    25 you, Chief, until you all can tell us
    1 somebody has been cleared, I don't think
    2 anybody that has been mentioned has ever, in
    3 our mind, been taken off of possibilities.
    4 I mean, you all haven't, as I
    5 understand, you all haven't officially
    6 cleared, I am not even sure beyond Burke,
    7 John Andrew and Melinda.
    8 I hear rumblings back from the
    9 White camp that April of '97 allegedly he
    10 was cleared, but as I remember what I
    11 learned about it, it looked pretty qualified.
    12 THE WITNESS: All right. Because
    13 I don't know --
    14 MR. WOOD: We are not here to
    15 clear anybody. The question for her was
    16 about --
    17 CHIEF BECKNER: I am asking her
    18 what she believes.
    19 MR. WOOD: If she's heard anything
    20 that's changed her -- any other additional
    21 information about Merrick other than what you
    22 already had given them earlier.
    23 THE WITNESS: No.
    24 Q. (By Mr. Kane) Let me follow up
    25 on that, Mrs. Ramsey. How were you advised
    1 before he was fired that he was going to be
    2 fired? How did you know he was going to be
    3 fired?
    4 A. I don't remember. I think
    5 probably John.
    6 Q. John told you?
    7 A. Probably. I can't think of where
    8 else I would have heard it, but I am not
    9 sure.
    10 Q. Before he was let go, what was it
    11 about him, you said you were fearful that
    12 day he was going to be let go, what was it
    13 about him that made you fearful that day
    14 before he was let go?
    15 A. I don't know. I don't know if I
    16 can -- I am not sure I understand your
    17 question.
    18 Q. You said before he was let go,
    19 you were fearful that he was going to be let
    20 go.
    21 THE WITNESS: No, I wasn't
    22 fearful he was going to be let go. When I
    23 understood that he was going to be fired
    24 that day, I was frightened for my husband's
    25 safety.
    1 Q. (By Mr. Kane) Because he was
    2 going to be fired that day?
    3 A. Yes.
    4 Q. Was there anything about Jeff
    5 Merrick you knew, violent propensities or
    6 anything of that nature, before he was told
    7 that he was no longer employed by Access
    8 Graphics?
    9 A. No.
    10 Q. What was it that made you
    11 fearful?
    12 A. Well, just because of, like, I
    13 gave an example of the postal workers. When
    14 an employee is fired, you never know how
    15 they are going to react to that.
    16 Q. Okay. Were there other people
    17 that had been fired by Access Graphics that
    18 you had the same fear?
    19 A. I didn't know. I guess I didn't
    20 know many more people. I knew Jeff Merrick.
    21 Q. (By Mr. Levin) Mrs. Ramsey, is
    22 there anything since June of 1998, any
    23 contact at all you had with Mr. and Mrs.
    24 Merrick which has increased or solidified
    25 your belief that they are viable suspects in
    1 the murder of your daughter?
    2 A. I have not had any contact with
    3 them.
    4 MS. HARMER: Mrs. Ramsey and Mr.
    5 Wood, I am going to cite a page in the
    6 book, 153.
    7 THE WITNESS: Okay.
    8 Q. (By Ms. Harmer) You mention a
    9 kid by the name of Nathan that was living
    10 with the Steins. Was he living with them
    11 prior to December of '96?
    12 A. Yes, he was.
    13 Q. And at any time did he look after
    14 Burke or JonBenet?
    15 A. He would, on occasion, take them
    16 to school in the morning.
    17 Q. Do you know anything more about
    18 him, his last name?
    19 A. Inouwe, Nathan Inouwe.
    20 Q. Do you know how to spell that?
    21 A. I-n-o-u -- maybe y-e or -e.
    22 Q. Is he a white male?
    23 A. He is American, but of Japanese
    24 descent, I believe.
    25 Q. How old is he?
    1 A. He has graduated now and is doing
    2 missionary work, I think. Susan would know
    3 exactly where he is, but at that time he was
    4 a college junior or senior?
    5 MR. LEVIN: Mr. Wood, can you
    6 facilitate getting the information to us so
    7 we can contact him?
    8 MR. WOOD: I think we said
    9 yesterday, if you all make a hit list for
    10 me, so to speak, point by point what you
    11 want me to do, and we will do it.
    12 MS. HARMER: That is it.
    13 MR. WICKMAN: Mrs. Ramsey, does
    14 the name David Charles Brantley mean anything
    15 to you?
    16 THE WITNESS: Brantley?
    17 MR. WICKMAN: Yes, B-r-a-n-t-l-e-y.
    18 THE WITNESS: I don't think so,
    19 no.
    20 MR. WICKMAN: Ollie, can you
    21 write that name down?
    22 MR. GRAY: Just did.
    23 MR. WICKMAN: Thanks.
    24 Q. (By Mr. Wickman) I wanted to ask
    25 you, since your relocation to Atlanta, have
    1 you, John, or Burke had any credible threats
    2 since your relocation here?
    3 A. We have had, I don't know if they
    4 have been threats, we have had a lot of
    5 weirdos come calling.
    6 Q. Physically to the house?
    7 A. Yes.
    8 MR. WOOD: While you are all here,
    9 you all might want to check out one this
    10 morning that called me. Somebody called my
    11 office, a female. I don't make light of it.
    12 It was a pretty serious phone conversation.
    13 I am not expecting you all to deal with it,
    14 but you might want me to save the tape
    15 because she has called here before.
    16 MR. LEVIN: Have the Atlanta
    17 police followed that up in the past?
    18 MR. WOOD: It never has been a
    19 threat made to the level that I would call
    20 the police, but the last two days it has
    21 gotten to the point where I may because I
    22 think it may be directed toward me.
    23 Q. (By Chief Beckner) Would you be
    24 willing to sign releases to allow us to
    25 interview Ellis Armistead and David Williams?
    1 MR. WOOD: I think we talked
    2 about that, and I think that is something I
    3 would address.
    4 MR. LEVIN: I have proposed
    5 written releases for both Patsy and John, and
    6 when we leave this afternoon, I will leave
    7 them with you and give you an opportunity to
    8 look. It refers to the Colorado statute, so
    9 you can have some time to look them over.
    10 You can call me directly if you want to talk
    11 about it.
    12 MR. WOOD: Okay. Did you all
    13 make a decision about whether you wanted to
    14 talk with Ed Gelb, Cleve Baxter? I offered
    15 them up for interviews with you, no holds
    16 barred, waive the privilege.
    17 CHIEF BECKNER: We may at some
    18 time.
    19 MR. WOOD: They talked to John
    20 and Patsy. They interviewed them. So if
    21 you will give me those, I will certainly --
    22 MR. LEVIN: I will leave them
    23 with you.
    24 MR. WOOD: My concern, Bruce, and
    25 obviously there are no secrets there, your
    1 intentions, your being the prosecution's
    2 intentions, are not clear to us. Obviously,
    3 as an attorney, we have to always be
    4 prepared for the worst case scenario. We
    5 don't think it is likely or something that
    6 should happen. So there is that balancing
    7 of trying to get you information from Ellis
    8 and David Williams that can help with the
    9 investigation but yet still maintain certain
    10 information that might be important in any
    11 potential defense of the case.
    12 MR. LEVIN: I understand.
    13 CHIEF BECKNER: Anybody have
    14 anything else?
    15 MR. LEVIN: I do not.
    16 MR. WOOD: Although if you all
    17 stay tuned to the civil cases where the
    18 discovery rules are fairly liberal, that is a
    19 source of tremendous information somewhere
    20 down the road both ways.
    21 THE WITNESS: Could I ask who is
    22 David Brantley?
    23 MR. WICKMAN: Not at this time,
    24 but I will talk to Mr. Wood.
    25 MR. WOOD: Okay. Are you all
    1 done with Patsy?
    2 MR. LEVIN: We are. Thank you,
    3 ma'am.
    4 THE WITNESS: Thank you so much.
    5 CHIEF BECKNER: Thank you for
    6 your time.
    7 (Whereupon, the videotaped
    8 interview of PATSY RAMSEY was concluded.)
    9 .
    10 .
    11 .
    12 .
    13 .
    14 .
    15 .
    16 .
    17 .
    18 .
    19 .
    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 .
    19 My commission expires on the
    20 17th day of March, 2001.
    21 .
    22 .
    23 .
    24 .
    25 .
  4. Tricia

    Tricia Administrator Staff Member

    August 29, 2000

    2140 The Equitable Building
    7 100 Peachtree Street
    Atlanta, Georgia

    Alexander J. Gallo, CCR-B-1332
    2 .
    3 On behalf of John and Patsy Ramsey:
    4 L. LIN WOOD, Esq.
    5 Law Offices of L. Lin Wood
    6 2140 The Equitable Building
    7 100 Peachtree Street
    8 Atlanta, Georgia 30303
    9 .
    10 On behalf of The United States:
    11 MICHAEL KANE, Esq.
    12 BRUCE LEVIN, Esq.
    18 .
    19 Also present:
    20 Ollie Gray
    21 John San Agustin

    2 August 29, 2000
    3 MR. KANE: Okay. Mr. Ramsey,
    4 good morning.
    5 MR. BECKNER: Just before we get
    6 in, I want to say we appreciate your
    7 willingness to sit down with us and answer
    8 questions. We appreciate the opportunity.
    9 THE WITNESS: Likewise.
    10 MR. BECKNER: I want to make
    11 sure, do you know who everybody is here?
    12 THE WITNESS: Yes. We met. We
    13 met everybody yesterday.
    14 THE VIDEOGRAPHER: All right.
    16 Q. (By Mr. Kane) Okay, Mr. Ramsey,
    17 we've spoken before for quite a period of
    18 time. When I first spoke with you earlier,
    19 I explained to you that, if ever there were
    20 going to be an intruder on trial, the
    21 defense is going to be that you did it. Do
    22 you remember that?
    23 A. I remember that, but I am not
    24 here to prove my innocence. I am here to
    25 find the killer of my daughter.
    1 MR. WOOD: Without getting into a
    2 back and forth, I don't want to, but I think
    3 you raised it and it was raised yesterday.
    4 I just think you all can sell that somewhere
    5 else about the idea that if an intruder is
    6 put on trial you will need to have answers
    7 from the Ramseys because, if you find the
    8 person that killed their daughter, the
    9 intruder, and you put that person on trial,
    10 before that trial date occurs, you will have
    11 every opportunity to talk with John and Patsy
    12 to make sure that they can assist you in the
    13 prosecution of the criminal, including
    14 assisting you in rebutting any defense.
    15 MR. KANE: I thought that is what
    16 we are here for today.
    17 MR. WOOD: Well, you haven't
    18 gotten the intruder yet. All I am saying
    19 is, if you will get the guy, we will always
    20 be available to help you with that.
    21 MR. KANE: Okay.
    22 Q. (By Mr. Kane) How active have
    23 you been involved in the investigation in the
    24 last two years since we last met? How
    25 actively have you taken part in it?
    1 A. Well, that's a relative term. I
    2 don't know how to answer that question. I
    3 am aware somewhat of what is going on.
    4 Bryan Morgan shepherded the effort for a good
    5 while after the grand jury and specifically
    6 told me he didn't want to tell me a lot
    7 because we were talking to the media and I
    8 had a tendency to perhaps say things I
    9 shouldn't.
    10 Q. What kinds of things were you
    11 concerned of saying?
    12 A. He was concerned about keeping the
    13 efforts of the investigation as confidential
    14 as possible.
    15 Q. Why is that?
    16 A. I don't know. You have to ask
    17 him.
    18 Q. In your mind --
    19 A. In my mind, it compromises the
    20 effort.
    21 Q. In your mind it compromises the
    22 effort or in his mind?
    23 A. Yes, in my mind.
    24 Q. It compromises the effort to
    25 disclose things?
    1 A. To find the killer, which is what
    2 we were trying to do.
    3 Q. That wasn't my question, how does
    4 it compromise the effort to not disclose
    5 things you are uncovering?
    6 MR. WOOD: Disclose them publicly?
    7 MR. KANE: Yes, yes.
    8 THE WITNESS: We've always felt
    9 that way.
    10 MR. WOOD: Don't you all feel
    11 that way, with all due respect?
    12 Q. (By Mr. Kane) But you said that
    13 Bryan had to tell you that he wasn't going
    14 to disclose information to you because you
    15 would take it public?
    16 A. He thought that that risk was
    17 there because we were in conversation with
    18 the media. We were in the process of
    19 writing a book.
    20 Q. The first time that you had,
    21 between June of 1998 and the time you wrote
    22 your book, had you given any media
    23 interviews?
    24 A. I think we gave one in Nashville.
    25 That's all I can remember, but I don't
    1 recall the timing.
    2 Q. So you got a limited briefing on
    3 what the progress of the investigation was?
    4 A. Uh-huh (affirmative).
    5 Q. What were the things that were
    6 disclosed you?
    7 A. I think anything substantive has
    8 been turned over to you, first of all, or to
    9 the Boulder Police Department.
    10 Q. No, I understand that, but what
    11 was disclosed to you?
    12 MR. WOOD: Wait. Give him --
    13 MR. KANE: That wasn't my
    14 question.
    15 MR. WOOD: Doesn't matter. Let
    16 him finish saying what he was going to say.
    17 He has the right to answer. If you don't
    18 think it's responsive, then just deal with
    19 it, but I -- John, go ahead and finish.
    20 Don't interrupt.
    21 THE WITNESS: I forgot your
    22 question now.
    23 Q. (By Mr. Kane) The question was,
    24 what was disclosed to you?
    25 MR. WOOD: And you started to
    1 say, John --
    2 THE WITNESS: That I, first of
    3 all, I believe that whatever has been
    4 disclosed to me I am highly confident has
    5 been given to the Boulder Police Department
    6 as information.
    7 We have, I know, pursued a good
    8 number of leads. I don't know that any of
    9 them are the killer. I don't know that one
    10 of them is not the killer. They are
    11 interesting leads, the ones I am aware of.
    12 They need to be pursued. We are pursuing
    13 them to the best of our ability as a private
    14 citizen.
    15 One of the reasons we are here
    16 today is because we realize that there are
    17 powers that the state has that we cannot, as
    18 private citizens, exercise, and that's going
    19 to be necessary to ultimately find the
    20 killer.
    21 Q. (By Mr. Levin) If I can
    22 interrupt. Mr. Ramsey, what I would like
    23 you to do, I mean, as an individual, I am
    24 sure, who has thought about this all day,
    25 every day, is just lay out for us what you
    1 see as the significant lead so that we can
    2 make sure that we have followed these things
    3 up.
    4 A. Well, the -- and this is the file
    5 I've kept of leads that come in on the
    6 internet. And we have a tip line, we get
    7 lots of letters, most of which are not of
    8 any interest or value, but these are ones
    9 that I kept. I sent these on to Ollie, and
    10 I think probably he has sent them on to you.
    11 These aren't necessarily inclusive.
    12 This is just from a psychologist,
    13 who had, I think, a good perspective on the
    14 killer.
    15 This is the Dorothy Allison stuff
    16 which I believe you guys are familiar with.
    17 Chris Wolf is still very much of
    18 interest to me. I don't know that he is
    19 involved. I don't know he's not. But --
    20 Q. (By Mr. Levin) Hang on. I
    21 suppose what I'm -- I don't mean to cut you
    22 off, Mr. Ramsey, obviously. But what I am
    23 interested in, I mean, we had a list of
    24 names that you provided early on, and I was
    25 interested if there are recent people. I
    1 mean, obviously we've looked at Chris Wolf
    2 and we looked at Fleet and we've looked at
    3 Priscilla and we've looked at Merrick, and
    4 those people, and I'm looking for --
    5 MR. WOOD: Have they been
    6 cleared, Bruce? Have they been cleared?
    7 MR. LEVIN: I can't comment on the
    8 status of the investigation.
    9 MR. WOOD: Has he been cleared
    10 from your list. Are we wasting our time?
    11 Tell us so we won't waste Ollie's resources.
    12 They can go elsewhere.
    13 Well, let me go get the 50-page
    14 document which the Ramseys gave to you all
    15 and you ask him what is significant.
    16 MR. LEVIN: Let me get post-98.
    17 MR. WOOD: But you interrupted
    18 him. Post '98, you gave us 51 pages almost
    19 50 pages. Let's go through that because you
    20 certainly thought that was significant.
    21 Let's get that. Let me get that.
    22 MR. LEVIN: Maybe my question
    23 wasn't clear and maybe this will save you
    24 the trouble.
    25 MR. WOOD: Okay.
    1 MR. LEVIN: What I'm interested
    2 in is --
    3 MR. WOOD: You will not tell us
    4 if the other people are cleared?
    5 MR. LEVIN: No.
    6 MR. WOOD: Thank you for the
    7 cooperation.
    8 MR. LEVIN: I am interested in
    9 what, I'm interested in what Mr. Ramsey felt
    10 was significant, if there were people post
    11 '98 that jumped out.
    12 MR. WOOD: That 50 page document
    13 was felt to be significant.
    14 MR. LEVIN: To a man that it's
    15 at the heart of who murdered his child.
    16 THE WITNESS: Well, I can tell
    17 you that I think you know there was this
    18 whole issue of some strange activity in the
    19 Cherry Knolls, and I've often thought, you
    20 know, we lived there, it was a small town,
    21 we were higher profile, you know, perhaps we
    22 went to the wrong place.
    23 I spent a little time this summer
    24 talking to some of the people that I know
    25 our investigators talked to. Some of the
    1 information that I heard secondhand wasn't as
    2 strong as I thought it was in terms of being
    3 interesting.
    4 We had the incident of someone
    5 sleeping in JonBenet's bed while we were
    6 gone. We had the incident of somebody
    7 running down the hill saying they were going
    8 to get even with me and harm my daughter.
    9 I don't know if there is anything there or
    10 not, but I think it's foolish not to look at
    11 that.
    12 MR. KANE: Can I ask --
    13 MR. WOOD: Wait, let him finish
    14 answering the question.
    15 MR. KANE: He did.
    16 THE WITNESS: I am not finished.
    17 MR. WOOD: I have a 50 page
    18 document we're going to go through,
    19 gentlemen. You are not going to cut him off
    20 and say he doesn't have information that he
    21 thought was significant.
    22 MR. KANE: I just want to ask
    23 one follow-up --
    24 MR. WOOD: Follow up after his
    25 answer. We are going to talk about the
    1 September of '97 incident. We're going to
    2 talk about all of this. You want him to
    3 give you this information. And I hope you
    4 do want it. That's why I would like him to
    5 have that 50 page document in front of him
    6 when he talks about this. Would you like to
    7 have it, John?
    8 THE WITNESS: I have not seen it,
    9 so I would. Here's a lead on a guy named
    10 Pete Flynn who was part of a motorcycle gang
    11 in Casper, Wyoming called the Saints Bike and
    12 Trail Club, SBTC, possible connections to
    13 Linda Hawk, worked at the Tomahawk Lounge in
    14 Casper, in the '70s. It was where the
    15 Saints hung out. I don't know. You know,
    16 I have, I have stretched my imagination to
    17 the limit trying to figure out what SBTC is.
    18 This lady continues to claim that
    19 Larry Petrie is the killer. She goes on and
    20 on. I don't think that is terribly
    21 significant, but what I look for in these
    22 things is, is there something that they know
    23 that really ties it together or is there
    24 something they know that really isn't public,
    25 which is kind of difficult because so much
    1 has been public.
    2 This is a -- these Patricia
    3 letters are incredibly bizarre. When I read
    4 those things, this wasn't just an internet
    5 quack, in my opinion. This was somebody who
    6 was watching us, who knew a lot about us,
    7 who would talk about the killer being
    8 actually a pretty nice guy.
    9 You know, we tried desperately to
    10 track this back. He's a very clever fellow.
    11 He used several servers in his Internet
    12 transmissions. We couldn't, couldn't track
    13 it back. But I still am very interested in
    14 that.
    15 I have an original letter that I
    16 am convinced the same guy sent me that was
    17 written in a different -- supposedly it is a
    18 different author, but it's the same. So I
    19 mean, it could be the killer. I don't know.
    20 But it's a lead.
    21 Here is a, this is a family
    22 that -- oh, this is just some Dorothy
    23 Allison information. This is about a killer
    24 of a six-year-old child.
    25 One of my theories is, frankly,
    1 that the murder of a child is such a
    2 horrible thing and so subhuman that there are
    3 not many people around that do it. Here is
    4 a fellow that murdered a six-year-old child,
    5 or the name of a fellow. My contention is
    6 that --
    7 MR. KANE: Dorothy Allison, can I
    8 ask, is that a psychic?
    9 THE WITNESS: No, no, this was
    10 from --
    11 MR. WOOD: He is talking about
    12 someone else now.
    13 MR. KANE: No, but before you
    14 said --
    15 MR. WOOD: You are going to let
    16 him finish what he's saying.
    17 MR. KANE: Oh, come on. Lin,
    18 I'm just asking who is Dorothy Allison for
    19 the record.
    20 MR. WOOD: Let him finish. Make
    21 a note and --
    22 THE WITNESS: Dorothy Allison was
    23 on a television program. I believe she is a
    24 psychic. I did not see it. I've never
    25 have seen her. These are letters from
    1 people who have sent information based on
    2 what they heard on the television program.
    3 MR. KANE: I just wanted to --
    4 MR. WOOD: It is going to be a
    5 better procedure to let my client finish.
    6 You are going to let my client answer his
    7 question or you're going to leave. You're
    8 not here to interrupt. Show some courtesy
    9 and I will show it to you.
    10 THE WITNESS: Dennis Kelly. This
    11 is actually very interesting.
    12 MR. KANE: If you want to play
    13 that game, I will win.
    14 MR. WOOD: Well, did you
    15 answer -- hold on, John.
    16 What did you say, sir?
    17 MR. KANE: I said, if you want
    18 to play that game, let's take a break.
    19 MR. WOOD: Let's take a break.
    20 I don't know what that means. We'll
    21 consider what that means. I'm going to play
    22 that game, you're going to win? I don't
    23 know.
    24 MR. KANE: You are playing games.
    25 MR. WOOD: I am not playing a
    1 game, Mr. Kane.
    2 MR. KANE: He mentioned Dorothy
    3 Allison, and I said who is Dorothy Allison.
    4 MR. WOOD: Mr. Kane, I am not
    5 going to waste my breath talking to you like
    6 I did yesterday. I am going to take a
    7 break now, but when you make comments about
    8 me playing a game and you are going to win
    9 when I asked you not to interrupt my client,
    10 number one, sir, that was rude. I asked you
    11 not to do it. I told you if you were
    12 going to be discourteous to my client, you
    13 would have to leave.
    14 MR. KANE: I was not
    15 discourteous.
    16 MR. WOOD: If it is a game to
    17 you, as you practice law, it is not a game
    18 for me.
    19 MR. KANE: Are we going to take
    20 a break here?
    21 MR. WOOD: We will get through
    22 this, Chief, no matter what he tries to do,
    23 we will get through it. I promise you.
    24 MR. KANE: This is a stall.
    25 MR. WOOD: And I will get that
    1 50 page document too.
    2 (WHEREUPON, a brief recess was
    3 taken.)
    4 THE VIDEOGRAPHER: All right.
    5 THE WITNESS: Well, I started to
    6 talk about Dennis Kelly, which interested me
    7 because this is a note from a guy in Boulder
    8 who lived near Kelly who apparently painted
    9 our basement in either '95 or 1996. He's a
    10 fairly dysfunctional fellow. I don't know if
    11 you know his name or not.
    12 Q. (By Chief Beckner) When you say
    13 dysfunctional, what do you mean?
    14 A. Well, I can give you copies of
    15 these things, but he was wearing an ankle
    16 monitor when he was painting our basement,
    17 apparently. I don't know how this was
    18 known, but obviously he was supposed to be
    19 on a restricted duty.
    20 MR. TRUJILLO: Mr. Ramsey, are
    21 you speaking of Mr. Kelly as the person who
    22 painted your basement?
    23 THE WITNESS: Yes, Dennis Kelly.
    24 Do you know that name or --
    25 MR. TRUJILLO: I would have to go
    1 back and look.
    2 THE WITNESS: But anyway, this is
    3 one of those that had a connection, in our
    4 house.
    5 MR. BECKNER: And that is the
    6 type of thing that is particularly of
    7 interest to us are people who have had
    8 connections, because obviously there are a
    9 lot of people that are going to write on the
    10 internet and send letters and things.
    11 THE WITNESS: Right. Yeah. I
    12 mentioned a wealthy friend I visited, da-dah,
    13 da-dah, da-dah, and then Kelly said, yeah, I
    14 know some rich people. Who? The Ramseys.
    15 He seemed to have some sort of grudge
    16 against you which he wouldn't explain.
    17 But -- and this was March 2000. So I can
    18 give you a copy of that.
    19 In terms of the stuff that I have
    20 been keeping track of, that's probably the
    21 most interesting.
    22 This is Randy Simons. I don't
    23 know if there is anything there.
    24 This is a woman who believes that
    25 her brother might have done it. And I
    1 think -- I can give you this too, but I
    2 think you guys know about it.
    3 MR. KANE: Who is that?
    4 THE WITNESS: Well, I don't know.
    5 She didn't give me a name.
    6 Q. (By Mr. Kane) Her, the name of
    7 the brother?
    8 A. She doesn't, but she has an
    9 e-mail address. Well, this actually came from
    10 Jamison, who I am sure you guys are
    11 painfully aware of. But I think she had
    12 been communicating with this woman, or this
    13 person who is a woman.
    14 We had another lady write us that
    15 her ex-husband did it, but in talking to
    16 her, we decided she was really a woman
    17 scorned.
    18 MR. WOOD: We had everybody back
    19 from John Kennedy calling.
    20 THE WITNESS: Yeah, it got really
    21 bizarre in the end. That's the kind of
    22 thing I've been looking for, and that's what
    23 I've learned, yet one of those for every
    24 hundred that really are not particularly
    25 interesting.
    1 Michael Helgoth, I know we gave
    2 you some boots, Hi-Tec boots, that from my
    3 perspective looked like a perfect match to
    4 the footprint.
    5 We also know he has a stun gun
    6 that was an AirTaser. We know he committed
    7 suicide the day after Alex Hunter's speech
    8 about we know who you are, we are going to
    9 get you.
    10 There is the another fellow, I
    11 don't know his name, but I know Ollie has
    12 been working on it that had a shrine of
    13 JonBenet prior to '96.
    14 MR. TRUJILLO: Mr. Ramsey, let me
    15 jump back to Mr. Helgoth for a moment. You
    16 said he had boots that you have seen. Have
    17 you seen the boots?
    18 THE WITNESS: I haven't seen the
    19 boots. I saw a picture that Ollie had taken
    20 earlier of the footprint compared to the
    21 image of the bootprint.
    22 Q. (By Mr. Trujillo) That is my
    23 question, have you seen the actual crime
    24 scene photograph of the boot print there?
    25 A. No, no.
    1 Q. What image have you seen?
    2 MR. WOOD: That is a copy of it.
    3 THE WITNESS: I don't know what
    4 image I have seen, but it was on the
    5 internet.
    6 MR. TRUJILLO: Okay. I don't
    7 know if this is the boot image of -- oh,
    8 here it is, yes.
    9 MR. WOOD: This is a copy.
    10 MR. TRUJILLO: This is an image
    11 off of the internet?
    12 THE WITNESS: And yes, I don't
    13 know --
    14 MS. HARMER: And the internet,
    15 the person who put it on the internet is
    16 purporting it to be the actual footprint that
    17 was found in the cellar?
    18 THE WITNESS: Not necessarily.
    19 His parents, Helgoth's parents finally turned
    20 over his boots, which we turned over to you.
    21 I don't know Helgoth. I don't know that
    22 name. Whether or not there is any
    23 significance there, I don't know.
    24 MS. HARMER: I guess I am not
    25 clear about where you got this image.
    1 THE WITNESS: The --
    2 MR. WOOD: Ollie would be able to
    3 tell us that.
    4 THE WITNESS: Yeah, I don't know.
    5 MR. WOOD: The image of the print
    6 in the wine cellar.
    7 MR. GRAY: I did that comparison
    8 with glue.
    9 THE WITNESS: But here is a guy
    10 that ought to be looked at. I don't know
    11 anything else about it, but he certainly
    12 meets some of the factors that we find
    13 interesting.
    14 I still believe the September '97
    15 incident is significant. I don't know what
    16 you found on that, but that sent chills down
    17 my spine when I read about that, heard about
    18 that a month or two ago.
    19 This person that has a shrine, I
    20 think, had a cane, one of those candycanes
    21 from my front yard in his home. I don't
    22 know how he could have come by that after
    23 the fact. It was secured December 25th.
    24 Those are probably, in my mind,
    25 the most interesting, substantial leads that
    1 I had seen.
    2 Q. (By Mr. Levin) Mr. Ramsey, you
    3 mention --
    4 MR. WOOD: Before we go there,
    5 Bruce, let me say to you, I turned over to
    6 Ollie two expandables of stuff that I have
    7 gotten for him to look at, including, you
    8 may know this, Chief, but I got some really
    9 long and detailed analysis of Fleet White's
    10 letters compared to the ransom notes from a
    11 lawyer in New York. Are you familiar with
    12 it? You may not have gotten it yet.
    13 MR. BECKNER: I don't believe so.
    14 MR. WOOD: He will go through it
    15 and get it all to you. I am trying to
    16 keep up with it to go to Ollie. It is two
    17 expandables of different tips on leads.
    18 MR. BECKNER: What type of
    19 analysis is it?
    20 MR. WOOD: It's a linguistic
    21 analysis of the public letters that Fleet
    22 White and Priscilla White have written about
    23 the case, and they have taken that and done
    24 an analysis of the ransom note. So I am
    25 not making any suggestions except to describe
    1 it.
    2 Q. (By Ms. Harmer) Mr. Ramsey, this
    3 Dennis Kelly that you brought up, the
    4 painter, have your investigators contacted him
    5 or done any follow-up that you are aware of?
    6 A. I don't know of.
    7 MR. GRAY: I beg your pardon?
    8 MR. WOOD: Dennis Kelly, any
    9 follow-up on Kelly yet?
    10 MR. GRAY: I don't know a Kelly.
    11 MR. WOOD: The painter.
    12 MR. GRAY: Uh-uh (negative).
    13 MR. WOOD: Give that to Ollie.
    14 MR. GRAY: There are a couple of
    15 others we followed up on, but not him.
    16 MR. LEVIN: Mr. Ramsey, you
    17 mentioned Dorothy Allison provided you with a
    18 name? I missed it.
    19 THE WITNESS: A woman who had
    20 seen her on television provided us with a
    21 name of a -- I said I can give you what
    22 she sent, but I don't --
    23 Q. (By Mr. Levin) Was that on the
    24 list that you gave us, the name?
    25 A. No, no.
    1 Q. If I can change gears for just a
    2 second, one of the things that you found
    3 significant, and, obviously since you found
    4 it significant, it was of great interest to
    5 us, was the baseball bat, the second baseball
    6 bat, aluminum bat.
    7 And we have, through confidential
    8 grand jury investigations, found that that
    9 bat, that second bat was Burke's. Was there
    10 anything else that you thought about,
    11 assuming that is true?
    12 A. Well, I never have seen the bat,
    13 so -- and I think the best person to say
    14 whether it was Burke's or not is to ask
    15 Burke.
    16 Q. Okay.
    17 A. I don't know.
    18 Q. That's it from your
    19 perspective --
    20 A. No, there was nothing else I know
    21 about the bat.
    22 Q. Okay. Thank you. We received
    23 from your lawyers in January of '97 two
    24 black shirts which we received really
    25 without --
    1 MR. BECKNER: January of '98.
    2 MR. LEVIN: January of '98. I
    3 am sorry.
    4 Q. (By Mr. Levin) January of 1998.
    5 It was in response to Boulder Police
    6 Department's request for the shirt that you
    7 are wearing in the photographs from Christmas
    8 at the White's house. And they were given
    9 to us without explanation of how they got
    10 into their possession. I thought you could
    11 explain that for us.
    12 A. Well, I assume they were the
    13 shirts that, when we were asked to provide
    14 the clothing we had on that night before, we
    15 couldn't remember. We asked for a picture
    16 that was taken that night so we could
    17 remember. As far as I know, those are the
    18 only shirts that we sent.
    19 Q. And that was in response to our
    20 request --
    21 A. Uh-huh (affirmative).
    22 Q. -- for the clothing that you were
    23 wearing?
    24 A. I suspect it was, yes.
    25 Q. What I would like you, if you
    1 recall, did you personally retrieve it, send
    2 it off to your lawyers, and, if so, where
    3 did you retrieve it from?
    4 A. Gosh, I don't know. It would be
    5 in December of '98, we were living in
    6 Atlanta.
    7 MR. TRUJILLO: Actually December
    8 of '97.
    9 MR. WOOD: I think the request
    10 for the clothing was made in December of
    11 '97, a year after the murder.
    12 THE WITNESS: Oh, yes, December
    13 of '97, yeah, yeah.
    14 MR. WOOD: And you turned it over
    15 in January of '98.
    16 MR. LEVIN: I believe that is
    17 correct, sir.
    18 THE WITNESS: We still lived in
    19 Atlanta. So it was either in a box or in
    20 my closet, I suppose.
    21 Q. (By Mr. Levin) Do you recall,
    22 when, on September the 28th, when your
    23 sister-in-law Pam went over to retrieve some
    24 items for the family, was that among the
    25 items that she took out of the house?
    1 A. December?
    2 Q. 28th, 1996. That Saturday
    3 before -- that Saturday after the murder.
    4 A. I don't know.
    5 Q. So just so I am clear, your best
    6 recollection is that that was an item that
    7 was in the house that was packed up by the
    8 movers that was sent off?
    9 A. Uh-huh (affirmative).
    10 Q. You provided us with two shirts.
    11 One of them had a collar, it's a wool shirt
    12 made in Israel. The other one did not have
    13 a collar. Do you have a belief as to which
    14 one was the actual shirt that you were
    15 wearing on Christmas '96?
    16 A. I don't remember, I guess. And
    17 if I -- well, I think the issue, if I
    18 recall was I couldn't remember which one, so
    19 I think we sent you both. But I mean, I'd
    20 have to look at pictures, I guess, to
    21 compare. I don't remember that far back.
    22 Q. Mr. Ramsey, I take it, and
    23 correct me if I am wrong, please, that the
    24 fact that you sent two shirts as opposed to
    25 one indicated you were not certain which of
    1 the two you were wearing?
    2 A. Well, I think that's what we did,
    3 but I don't, I mean, I don't remember
    4 exactly the logic. I know that we were
    5 asked about shoes, and the picture didn't
    6 even show shoes, so I couldn't remember what
    7 shoes we had on. So was it to send all my
    8 shoes or one hundred percent sure.
    9 Q. Those items of evidence, did you
    10 continue, after the clothing was moved down
    11 to Atlanta, after you moved to Atlanta, did
    12 you continue to wear them? Were they
    13 laundered? Were they -- one of them was
    14 wool. I assume that would be dry cleaned.
    15 Do you have any recollection in that regard?
    16 A. No, I don't.
    17 Q. We have been provided, and again,
    18 one of the sources of this information is
    19 confidential grand jury material I can tell
    20 you in the question, but we have been
    21 provided information from two sources that
    22 your son Burke, prior to the murder of your
    23 daughter, owned and wore Hi-Tec boots that
    24 had a compass on them, which makes them
    25 distinctive.
    1 Do you recall -- if you don't
    2 recall that they actually were Hi-Tec, do you
    3 remember Burke having boots that had a
    4 compass on the laces?
    5 A. Vaguely. I don't know if they
    6 were boots or tennis shoes. My memory is
    7 they were tennis shoes, but that is very
    8 vague. He had boots that had lights on them
    9 and all sorts of different things.
    10 Q. But you do have some recollection
    11 that he had some type of footwear that had
    12 compasses attached to them?
    13 A. I don't, I don't specifically
    14 remember them, but my impression is that he
    15 did, in my mind, yeah. But my impression
    16 was that they were tennis shoes.
    17 Q. Sneakers?
    18 A. Sneakers. Yeah. Ask Burke if he
    19 remembers it.
    20 I said, ask Burke, perhaps he --
    21 well, we could certainly ask Burke.
    22 Q. (By Mr. Kane) Mr. Ramsey, page
    23 266 and 267 of your book, you quote a letter
    24 you sent to Alex Hunter.
    25 A. Okay.
    1 Q. The last full paragraph of that,
    2 finally I am willing, it's on 267, I am
    3 willing and able to put up a substantial
    4 reward, $1 million, through the help of
    5 friends if this would help drive the
    6 investigation.
    7 Now, did you ever put up $1
    8 million reward?
    9 A. No. I was advised that it
    10 wouldn't make any difference.
    11 Q. Who was it that advised you of
    12 that?
    13 A. My attorneys. That $100,000 was
    14 a significant amount of money. And I didn't
    15 have a million dollars at that point. I
    16 would have had to gone to friends for help.
    17 And if it wasn't significant, I wasn't going
    18 to approach my friends for that kind of
    19 help.
    20 Q. Did you talk to anybody else
    21 about whether the amount of money offered
    22 would have any bearing?
    23 A. Well, I never got a response from
    24 Alex on that, but I don't remember that I
    25 did, no.
    1 Q. Was there something about, in your
    2 attorney's experience, that they cited --
    3 MR. WOOD: I don't want to go
    4 into anything further on that, about
    5 attorneys. The things they cited to him,
    6 would go into the privilege.
    7 MR. KANE: Fine. No problem.
    8 Q. (By Mr. Kane) What did you
    9 think? What did your instinct tell you
    10 about a million versus 100,000?
    11 A. Well, in the beginning, I thought
    12 that that would drive information. At the
    13 beginning we couldn't get the police to even
    14 acknowledge or participate in announcing a
    15 reward. It was very frustrating.
    16 And so we, you know --
    17 Q. Do you have a reward outstanding
    18 right now?
    19 A. Yes. As far as I am concerned,
    20 we do.
    21 Q. I am sorry?
    22 A. As far as I'm concerned, we do,
    23 yeah.
    24 Q. Is it publicized anywhere?
    25 A. It is publicized on our internet
    1 site, I believe.
    2 Q. Who maintains that?
    3 A. Ollie and I guess -- you can do
    4 that yourself and have an internet service.
    5 Q. You understand there is a reward
    6 that is listed on your internet site?
    7 A. (Witness nodded head
    8 affirmatively).
    9 Q. Is that that
    10 A. It was originally. We changed
    11 the number. I guess that is still how you
    12 access it. I think you access it both ways,
    13 don't you?, and we also set
    14 up a
    15 Q. JonBenetinfo --
    16 A. -- That's not a
    17 website.
    18 Q. That is an e-mail?
    19 A. Right.
    20 Q. (By Mr. Levin) Mr. Ramsey, I know
    21 that the -- it is my belief, I should say,
    22 that the fact that certain people have
    23 represented to you that there are stun gun
    24 injuries to your daughter is a significant
    25 fact.
    1 A. Uh-huh (affirmative).
    2 Q. And I am curious, if you don't
    3 mind, could you just tell us who has
    4 provided you information in that regard that
    5 has caused you to hold the belief that she
    6 has suffered a stun gun injury?
    7 MR. WOOD: That would be
    8 information provided to him subsequent to
    9 June of 1998?
    10 MR. LEVIN: Yes.
    11 MR. WOOD: Do you understand the
    12 question, John? I know what you said in
    13 June of 1998, but he is talking about since
    14 the time of your last interviews. If you've
    15 got anything else.
    16 Let me ask him a question.
    17 (Mr. Ramsey and his counsel
    18 confer.)
    19 THE WITNESS: We had, under
    20 the -- kind of the direction of Pat Burke a
    21 group of experts assembled to look at the
    22 medical, from the scientific and medical
    23 aspects of this, and that was one of the
    24 things, I believe, that they looked at.
    25 Q. (By Mr. Levin) That would be
    1 Dr. Sperry?
    2 A. Well, that would be one of the
    3 names. There were two to three. I don't
    4 remember the other names because I never met
    5 them, but these are the people we offered to
    6 have meet with you in January.
    7 Q. Right, right. Were you provided
    8 information from those folks that told you
    9 that one of the things that they examined
    10 were photographs of the reported stun gun
    11 injuries, ask Mr. Sperry and his colleagues
    12 if he had --
    13 A. I don't, I don't remember what
    14 they said, I guess. I never talked to him
    15 directly. You know --
    16 MR. WOOD: Bruce, as indicated
    17 by your question, you all have now an
    18 interest in the information from those
    19 individuals and would like to reconsider the
    20 request to meet with them which you earlier
    21 rejected, again, I think I am pretty sure
    22 that I can speak with Pat Burke and that
    23 that can be done. As indicated by your
    24 question, you are obviously interested in
    25 what those people have to say, and we will
    1 give them to you.
    2 THE WITNESS: My position on stun
    3 guns is that the people that have told me
    4 that this was likely the case seemed pretty
    5 qualified.
    6 MR. LEVIN: But that, I am sorry,
    7 Michael.
    8 Q. (By Mr. Levin) But that, just a
    9 follow up so I am clear, that information is
    10 not from this group that was put together
    11 after '98. That is some other individuals
    12 that precede your June '98 interviews?
    13 A. Well, the first time the stun gun
    14 came up was in a meeting with Lou Schmidt
    15 and Tom was there. I don't remember.
    16 MR. WICKMAN: Pete Hoster?
    17 MR. LEVIN: Ainesworth?
    18 THE WITNESS: And he asked me to
    19 keep it very confidential but did we have,
    20 did we know anybody that owned a stun gun.
    21 That is the first I heard about it. But
    22 that was probably in '97.
    23 MR. WICKMAN: Yeah.
    24 Q. (By Mr. Levin) And since your
    25 interviews in '98, there has been a passage
    1 of a significant period of time, have you
    2 come up with names of people you know that
    3 have, that you were associated with, which
    4 you know owned stun guns that were unfamiliar
    5 with --
    6 A. Not the -- I mean, my answer to
    7 that back then was I don't know of anybody
    8 that I know that owns a stun gun, and I
    9 still don't. I mean, we have come up with
    10 guys like Helgoth who we know owned the
    11 brand that was a suspect, but --
    12 MR. KANE: Let me follow up on
    13 that.
    14 Q. (By Mr. Kane) have you talked to
    15 Lou Schmidt about the stun gun after he
    16 resigned from the case?
    17 MR. WOOD: After he resigned from
    18 the case would have been?
    19 MR. KANE: Would have been
    20 September of 1998.
    21 MR. LEVIN: '99?
    22 MR. WOOD: '98.
    23 MR. KANE: '98.
    24 MR. LEVIN: '98.
    25 THE WITNESS: Only, I think, that
    1 he still believes it's very significant.
    2 Q. (By Mr. Kane) Now, you said that
    3 you hadn't talked to any of the experts that
    4 had looked at it. What information did you
    5 get, if any, from these people?
    6 A. I think the most significant piece
    7 of information, that they felt that the blow
    8 to the head was after she had died or near
    9 death.
    10 Q. I am now talking about the stun
    11 gun.
    12 A. Oh, about the stun gun?
    13 Q. Yes.
    14 A. I don't remember that they told
    15 me anything about the stun gun that I didn't
    16 already know, I mean, that I was aware of.
    17 Q. What are you aware of, I guess,
    18 is the question, about the stun gun?
    19 A. Well, I was aware that it was
    20 highly likely that one was used, which is a
    21 very distressing fact. I learned, and I
    22 think I heard this in the media, it might
    23 have been Carol McCane, I don't remember,
    24 said something about there were burn marks on
    25 the tape. I don't know if that is true or
    1 not.
    2 Q. But you don't know of any experts
    3 that say that?
    4 THE WITNESS: No, I don't.
    5 MR. WOOD: Because of what's
    6 obviously of interest on your all's part, I
    7 take it you would all be receptive with
    8 meeting with them now? Are you interested
    9 in hearing what they want to say? I assume
    10 you would want us to arrange that, Bruce?
    11 MR. LEVIN: I think that is
    12 something we can talk about. There are
    13 issues are surrounding those people that
    14 isn't germane to our talking to Mr. Ramsey
    15 at this time that maybe you and I can talk
    16 about in the future.
    17 Q. (By Mr. Kane) You started to say
    18 about the most significant thing was the blow
    19 to the head preceded the strangulation. Was
    20 that, have you talked to any particular
    21 expert about that?
    22 A. I haven't talked directly to any
    23 particular expert about that. That was the
    24 analysis I got back through Pat Burke, I
    25 believe.
    1 A. And do you know who --
    2 MR. WOOD: Just so it is clear,
    3 I think you said preceded strangulation. I
    4 think you misspoke.
    5 MR. KANE: If the blow, no I
    6 think that's what you said. You said, I am
    7 sorry.
    8 MR. WOOD: Hold on. Let's make
    9 sure. He said precisely, the most
    10 significant piece of information was that
    11 they felt was the blow to the death was
    12 after the death, and your question, I think
    13 inadvertently you said preceded the
    14 strangulation, which is not what he said.
    15 MR. KANE: You are right. That's
    16 not what I meant. Okay.
    17 Q. (By Mr. Kane) But you got this
    18 information through Pat Burke. Have you ever
    19 sought to talk to the people that he got the
    20 information from?
    21 A. No, because I wanted to stay
    22 independent of them. The objective was, when
    23 we presented these people up in January, was
    24 to present highly qualified experts that
    25 would help provide information to find the
    1 killer.
    2 Q. But there are people in addition
    3 to Kris Sperry?
    4 A. Yes. I don't remember their
    5 names, but it seems to me there were
    6 several.
    7 Q. But you could get access to who
    8 they were and provide us with those?
    9 A. As far as I know, yes.
    10 Q. (By Mr. Levin) Mr. Ramsey, I know
    11 that you were asked questions about a black
    12 metal flashlight that was found in the house.
    13 We have developed, since '98, some
    14 information about that flashlight I would
    15 like to ask you just a little bit about.
    16 Is that the flashlight that you
    17 habitually used, say for example, if your
    18 power went out and you had candles lit in
    19 your house? Do you know?
    20 A. Not necessarily. And I don't
    21 know that that was my flashlight. The
    22 picture I saw, and I think I commented at
    23 the time, was that that one was very dirty.
    24 My flashlight, while it looked to be the
    25 same size, mine was clean. And my son gave
    1 it to me for a present. So that was the
    2 issue that I saw. It kind of looks like
    3 mine, but it's certainly filthy.
    4 Q. May not be?
    5 A. Yeah.
    6 Q. Let's talk about, I want to ask
    7 this so it is clear for you. The flashlight
    8 your son gave you, whether the light in the
    9 picture is that or not, but that flashlight,
    10 the one you received as a gift from your
    11 son, was that the light that, if you had
    12 power failures, routinely, that is the first
    13 thing you would grab?
    14 A. No, not necessarily.
    15 Q. Not necessarily?
    16 A. Because we kept it -- it was a
    17 big flashlight. We kept it, I believe,
    18 normally in the drawer down that little sink
    19 area in the back hall. I don't even
    20 remember if I had a flashlight by my bedside
    21 or not.
    22 Q. (By Mr. Kane) The documentary that
    23 was done by Michael Tracy in 1998 sometime,
    24 did you have any say in any aspect of that
    25 documentary?
    1 A. No.
    2 Q. I think previously you said the
    3 one thing you did was you insisted that it
    4 wouldn't be shown before --
    5 A. Well, there was an issue about,
    6 if it was, if the grand jury was in session
    7 or convened or something that we had the
    8 right to tell them not to put it on. That
    9 was the only thing, I believe, that we --
    10 Q. Did you have any discussions with
    11 anybody about when it was aired just a
    12 couple of weeks before the grand jury
    13 started?
    14 A. Did I have discussions? No, not
    15 that I remember.
    16 Q. (By Mr. Levin) Mr. Ramsey, one of
    17 the things that you were asked about during
    18 your interview in 1998 I would like to
    19 follow up on is some new information, are
    20 some questions about a Santa Bear that was
    21 found on your daughter's bed. Do you
    22 remember that?
    23 A. Uh-huh (affirmative).
    24 Q. Do you remember the bear?
    25 A. (Witness nodded head
    1 affirmatively).
    2 Q. At the time you were interviewed,
    3 you stated to the effect that you did not
    4 recognize it?
    5 A. Correct.
    6 Q. And I am wondering, we have
    7 identified the source, we know how it got to
    8 JonBenet through a pageant on December 14.
    9 MR. WOOD: Well, you say that,
    10 but we're not -- we haven't seen the
    11 photographs or video.
    12 MR. LEVIN: I understand that.
    13 Q. (By Mr. Levin) It is our belief.
    14 Are you comfortable with that
    15 phrasing?
    16 MR. WOOD: I would be more
    17 comfortable if you are going to question him
    18 about something that you give him the right
    19 to look at it yourself, but, you know, since
    20 you, for whatever reason, choose not to do
    21 so, I accept you state that is your belief.
    22 Q. (By Mr. Levin) It is my belief,
    23 Mr. Ramsey, that she received that as a
    24 prize in a pageant on December 14, 1996.
    25 And I am wondering if, do you recall being,
    1 first of all, were you at her last pageant
    2 in December? Do you remember?
    3 A. I got there late. I usually
    4 would try to go for the talent portion. And
    5 they were running early. I was late. I
    6 got there after it was over. So I was
    7 there, but not for very long.
    8 Q. And the follow-up question to that
    9 would be, if my belief is correct that you
    10 received that bear at that pageant, does that
    11 maybe jog your memory as to the origin of
    12 it?
    13 A. No.
    14 MR. WOOD: I don't think you
    15 meant to say that he received it.
    16 THE WITNESS: We have no idea
    17 whether that was significant or not, that
    18 bear. I mean, you know, it was, when I was
    19 shown those photos, we were looking for
    20 anything that looked out of the ordinary.
    21 I mean, we had fully expected
    22 that, if someone had given it to her, that
    23 they would come forward and say, oh, yes, I
    24 gave that to JonBenet. That explains that.
    25 Q. (By Mr. Levin) And you understand
    1 of course, that anything you found
    2 significant or out of the ordinary became
    3 significant to us, obviously?
    4 A. That's right. Yeah.
    5 MR. WOOD: You did misspeak, just
    6 for the record. You meant to say JonBenet
    7 received it, not that John received it.
    8 MR. LEVIN: That's correct. I
    9 don't think John won a Little Miss Christmas
    10 pageant.
    11 THE WITNESS: I don't remember
    12 that.
    13 MR. WOOD: No, and it's
    14 unfortunate what you asked him in the
    15 question says that he did.
    16 MR. LEVIN: Michael?
    17 Q. (By Mr. Kane) Mr. Ramsey, at the
    18 present time, how much money is in the
    19 JonBenet Ramsey Foundation?
    20 A. I believe that is public record,
    21 but I think there is about $7,000 in there.
    22 Q. What is the highest balance that
    23 you know of that it has been?
    24 A. I don't know.
    25 Q. Have you done any fundraisers to
    1 fund it?
    2 A. No. It wasn't our intention to
    3 raise public money. I set up a foundation
    4 for my other daughter, which still exists, by
    5 the way. We were desperate to honor our
    6 daughter in some way, and that was our
    7 attempt to do it, and why we have been
    8 criticized for that, I don't know.
    9 Q. You put out a press release that
    10 gave an address for contributions to be made
    11 to the foundation.
    12 A. I don't remember ever asking for
    13 contributions.
    14 MR. WOOD: Do you have a copy of
    15 the press release?
    16 MR. KANE: Yes. As a matter of
    17 fact, I do.
    18 MR. WOOD: Why don't you let him
    19 see it.
    20 THE WITNESS: I would like to see
    21 it.
    22 MR. KANE: I have what the Denver
    23 Post has published as coming from your press
    24 release.
    25 MR. LEVIN: While he gets booted
    1 up on that just so that we don't waste time,
    2 how about if I ask him questions on another
    3 matter? Does that work for you procedurally?
    4 MR. WOOD: Sure.
    5 THE WITNESS: Can I respond to
    6 that though?
    7 MR. WOOD: Go ahead, John.
    8 THE WITNESS: I am offended, and
    9 I have been offended. I have been offended
    10 that you investigated that foundation during
    11 the grand jury. I have a mind to disband
    12 it and treat it just as a private -- we
    13 want to honor our daughter, and we have
    14 received nothing but grief from you folks,
    15 from the media over that attempt, and I am
    16 baffled by that.
    17 Q. (By Mr. Kane) I'll get it, but
    18 I want to follow up on that, you made an
    19 application for it to be a 503(C) charitable
    20 foundation, haven't you?
    21 A. Yes.
    22 MR. WOOD: I think it actually
    23 has been so designated.
    24 MR. KANE: Has it been? That
    25 was what I was going to ask you.
    1 THE WITNESS: Yes.
    2 MR. WOOD: There was a mistake in
    3 the book jacket cover that indicated an
    4 application had been made. An application
    5 for tax exempt status has been submitted, and
    6 I remember someone called it to the attention
    7 of the publisher that, in fact, it had been
    8 granted. I don't sit here and represent
    9 that I have seen it, but I do know that
    10 information.
    11 Q. (By Mr. Kane) Has any, to your
    12 knowledge, any of the money that ever has
    13 been in that foundation ever been given to
    14 any charitable --
    15 A. Yeah.
    16 Q. -- or social --
    17 A. Not to the level we would have
    18 hoped. I mean, our original plan was that we
    19 were going to sue the hell out of the
    20 tabloids and donate it all to the foundation
    21 and do some very significant things. That
    22 has been a tough process.
    23 So we have not been able to do
    24 with it what we hoped, but I hope some day
    25 we can.
    1 Q. You did get money from the
    2 public, though, that came in?
    3 A. Very, very little. I got -- the
    4 most significant donations I got were from
    5 two friends. One was the president of
    6 Lockheed-Martin, sent $1,000, and my boss
    7 sent $1,000. We probably received a few
    8 very small checks.
    9 Q. (By Mr. Levin) While Mr. Kane is
    10 looking for that on his computer, Mr. Ramsey,
    11 I am interested, and this is concerning
    12 events, obviously, that precede 1998, but it
    13 is based on information developed after the
    14 grand jury was convened. I am interested,
    15 if you would, please tell us what types, if
    16 any, work gloves you own, whether you kept
    17 them in the house, on the plane, in the car,
    18 it doesn't matter, but just identify them by
    19 their location.
    20 A. I don't remember that I owned any
    21 work gloves. I don't normally wear work
    22 gloves.
    23 Q. So just to clarify, you are
    24 saying that your recollection is that you did
    25 not or you are just unsure because of the
    1 passage of time?
    2 A. I don't remember. I mean, I
    3 don't normally wear work gloves. I've had
    4 work gloves from time to time, but I
    5 don't -- I can't specifically remember that I
    6 had any then or if I did what they were
    7 like.
    8 I had a pair here that were gray,
    9 and I bought those at Home Depot, and God
    10 knows where they are now. So they kind of
    11 come and go.
    12 Q. So it wasn't your routine habit
    13 or practice to keep a pair of work gloves in
    14 your cars if you needed to change a tire
    15 or --
    16 A. (Witness shook head negatively).
    17 Q. -- or on your plane if you needed
    18 to do something where you would kind of get
    19 dirtied up?
    20 A. No. I am not qualified to work
    21 on my airplane, my former airplane.
    22 MR. WOOD: Do you have the PR
    23 statement, Mr. Kane?
    24 MR. KANE: No. It's still
    25 booting up.
    1 MR. WOOD: Okay.
    2 Q. (By Mr. Levin) Mr. Ramsey, during
    3 the evening of December 25th, was there a
    4 time when either, after JonBenet got dressed
    5 to leave for the White's house or while she
    6 was at the White's house or after you came
    7 home from the White's house, she had any
    8 problems going to the bathroom or problems
    9 with her clothes that you may have helped
    10 her with?
    11 A. I don't remember. I really do
    12 not.
    13 Q. If I may follow --
    14 A. It is possible. I don't know.
    15 Q. If I can follow it up just to
    16 clarify, when you say you don't remember,
    17 does that mean, as you sit here today, your
    18 best recollection is no or you don't know
    19 yes or no?
    20 A. I don't remember. It was three
    21 and a half years ago.
    22 Q. I understand that. I was just
    23 trying to clarify your answer.
    24 A. I don't know. I just don't
    25 remember.
    1 Q. One way or the other?
    2 A. One way or the other.
    3 MR. LEVIN: Mike, do you have
    4 other questions while your computer is
    5 humming?
    6 MR. KANE: No.
    7 Q. (By Mr. Levin) I've got some
    8 questions, Mr. Ramsey, that deal with fiber
    9 evidence, and this is probably going to be
    10 questions that your lawyer is going to advise
    11 you not to answer, but I would like to pose
    12 them to you.
    13 MR. WOOD: Is this what we
    14 discussed yesterday with Patsy?
    15 MR. LEVIN: Different fibers
    16 associated directly with --
    17 MR. WOOD: I think the position
    18 is, to save some time, if you want to
    19 question Mr. Ramsey about test results, that
    20 it is absolutely fair that we be allowed to
    21 see the result ourselves before we answer
    22 questions so that we are not dealing with
    23 speculation and hypotheticals that are not
    24 supported by the facts as you might represent
    25 them.
    1 We couldn't get yesterday what I
    2 discerned to be a consistent response from
    3 any of you all about the test results that
    4 you discussed on the red fiber. That just
    5 tells me that, to try to go into this area
    6 without being privy to the actual result, is
    7 not something I am comfortable with in terms
    8 of fundamental fairness. If you are willing
    9 to disclose to us what you claim the result
    10 to be, it makes absolutely no sense to me
    11 that you would not share the actual result
    12 with us. I do not see how that can in any
    13 justified way impede your investigation or
    14 prevent you from going forward with your
    15 investigation.
    16 So we are not comfortable with
    17 your characterization of any test results
    18 forensically. We will reconsider at the
    19 appropriate time if we get there whether we
    20 will answer those questions if you will
    21 provide us with the actual result itself.
    22 So that's our position yesterday. That's our
    23 position today. That will be our position
    24 tomorrow.
    25 But if you will give us the
    1 results, we will look at them and we will
    2 consider whether or not we can answer
    3 questions based on those results.
    4 Fair enough?
    5 MR. LEVIN: I understand. And,
    6 of course, and I believe you feel I am
    7 entitled to at least pose the questions,
    8 understanding your position, so they are part
    9 of the record so this is an accurate --
    10 MR. WOOD: Well, you can pose
    11 them if you want to make a record, and I
    12 think I understand pretty clearly why you
    13 want to make that record based on what you
    14 said yesterday.
    15 I said yesterday I thought it was
    16 an injustice for you to make those kinds of
    17 representations through your questions or
    18 statements.
    19 If you are going to make
    20 statements that contain some form of innuendo
    21 that an article of clothing might possibly be
    22 connected to some portion of the crime scene
    23 or this man's daughter's body, I think you
    24 have an obligation, not only to him but to
    25 whoever reads that report and this
    1 transcript, to be candid and give full
    2 disclosure, show the people what the results
    3 are, show the people what you also had in
    4 terms of fiber evidence.
    5 We are told there are hundreds of
    6 fibers, for example, on the duct tape. And
    7 I think you have a fundamental right,
    8 fundamental fairness requires that you
    9 disclose that information and not single out
    10 some hypothetical innuendo that unfairly casts
    11 perhaps in someone's mind that reads this
    12 some finger of blame at John or Patsy
    13 Ramsey. I think it is totally inappropriate
    14 for you to do so, but if you want to go
    15 ahead and make a record for whatever reason,
    16 I certainly am not here to stop you. You
    17 have the right.
    18 MR. LEVIN: Thank you, Mr. Wood.
    19 I appreciate the opportunity.
    20 MR. WOOD: Thank you.
    21 Q. (By Mr. Levin) Mr. Ramsey, it is
    22 our belief based on forensic evidence that
    23 there are hairs that are associated, that the
    24 source is the collared black shirt that you
    25 sent us that are found in your daughter's
    1 underpants, and I wondered if you --
    2 A. ********. I don't believe that.
    3 I don't buy it. If you are trying to
    4 disgrace my relationship with my daughter --
    5 Q. Mr. Ramsey, I am not trying to
    6 disgrace --
    7 A. Well, I don't believe it. I
    8 think you are. That's disgusting.
    9 MR. WOOD: I think you --
    10 MR. LEVIN: I am not.
    11 MR. WOOD: Yes, you are.
    12 MR. LEVIN: And the follow-up
    13 question would be --
    14 MR. WOOD: Posing the question in
    15 light of what I said to you yesterday is
    16 nothing more than an attempt to make a
    17 record that unfairly, unjustly, and in a
    18 disgusting fashion points what you might
    19 consider to be some finger of blame at this
    20 man regarding his daughter, and you ought to
    21 be ashamed of yourself for doing it, Bruce.
    22 You knew we weren't going to
    23 answer the question. Why don't you just
    24 give us the report, and we'll put it out
    25 there for someone to look at and tell us
    1 what it says and see how fair and accurate
    2 you have been.
    3 I know why you said what you said
    4 yesterday about Patsy and the fibers and John
    5 and the fibers. And you know why you did
    6 it, Bruce. Because you want this somehow to
    7 get out and then people will read that and
    8 be prejudiced even further against this
    9 family.
    10 I just don't know why you want to
    11 do it, but I can't stop you.
    12 MR. LEVIN: Mr. Wood, if you
    13 would like to, I would challenge you to find
    14 any article anywhere that I have been quoted
    15 as giving an opinion or any statement to the
    16 press concerning this case.
    17 MR. WOOD: You don't have to be
    18 quoted. You don't have to be quoted.
    19 MR. LEVIN: Or any piece of
    20 evidence that I have released.
    21 MR. WOOD: You don't have to be
    22 quoted. You do not have to be quoted.
    23 MR. LEVIN: This is a murder
    24 investigation, and I am trying to get an
    25 explanation, which can be an innocent
    1 explanation.
    2 MR. WOOD: It could be, but you
    3 pose your question as if it's not not.
    4 That's what's unfair. Why don't you let us
    5 see the report so we can know exactly what's
    6 going on, exactly what other fibers were
    7 found in that area so that you don't
    8 unfairly cast an aspersion through innuendo
    9 or suggestion toward this man and his
    10 daughter.
    11 It seems to me that you should
    12 look over and go look, Mr. Wood, we want
    13 your client's help, we will give you the
    14 test results if it will help get this
    15 answered, if it is so important, we'll tell
    16 you whether there was another fiber or fibers
    17 found that we doen't know where they came
    18 from and maybe he can help you with that
    19 information, but that is not what you are
    20 doing. You are focusing on what you believe
    21 is one specific area. And you are doing it
    22 in a way that I think is just unfair.
    23 Let me just answer your question
    24 about you being quoted. Look, John and
    25 Patsy Ramsey sat around for three years and
    1 did not go public with this case, even
    2 though your people were talking to tabloids
    3 and writing books and appearing on
    4 television. Linda Arndt, Steve Thomas, Alex
    5 Hunter.
    6 You want to go through the litany
    7 of how your people have publicly prosecuted
    8 and persecuted this family, and now they
    9 decided enough is enough and they tried to
    10 go out with me, yes, sir, and them and try
    11 to refute some of the absolute lies that
    12 have been told about them. Do you have a
    13 problem with that?
    14 MR. LEVIN: Mr. Wood.
    15 MR. WOOD: Because your people
    16 have been saying it. I am not calling your
    17 name. I don't know who it is linked to.
    18 I don't know who gave the ransom note to
    19 Vanity Fair. I'm not suggesting it is you.
    20 But don't sit here and tell me that because
    21 Bruce Levin hasn't been quoted that this
    22 investigation from the Boulder Police
    23 Department and the district attorney's office
    24 is a lily white when it comes to talking
    25 about this case in the media because that is
    1 false, and you know it.
    2 MR. LEVIN: Now, Mr. Wood, if I
    3 can just respond very briefly, and I want
    4 Mr. Ramsey to listen to this because it's
    5 important, the suggestion is that I am
    6 suggesting that the only explanation for that
    7 question is sinister. I am a part of a
    8 team conducting an investigation into your
    9 daughter's death, and an innocent explanation
    10 that would help us further that investigation
    11 is very welcome. I am not looking for a
    12 sinister answer or innocent answer.
    13 MR. WOOD: If you are looking for
    14 that, then give us the test result and let
    15 us know what it says.
    16 MR. LEVIN: Mr. Wood, the fact
    17 of --
    18 MR. WOOD: No, Bruce. If you
    19 wanted the answer so badly, you would give
    20 us the test result instead of representing
    21 what the test result is. I, for the life
    22 of me, do not understand the logic.
    23 You say we can tell you what the
    24 test result is, but we can't show you the
    25 test result. So trust us, Mr. Ramsey, and
    1 answer this hypothetical question.
    2 If that information means that
    3 much to this investigation, Bruce, you would
    4 not hesitate to give us that report, period.
    5 So let's move to something else.
    6 MR. LEVIN: Let's move on to
    7 another topic.
    8 THE WITNESS: If the question is
    9 how did fibers of your shirt get into your
    10 daughter's underwear, I say that is not
    11 possible. I don't believe it. That is
    12 ridiculous.
    13 THE VIDEOGRAPHER: I need to
    14 change the audio cassette. It will take
    15 just one moment.
    16 MR. WOOD: Did we ever find it?
    17 MR. KANE: No. I can't put my
    18 finger on it. I will send it to you.
    19 THE WITNESS: Well, we have
    20 never, knowingly to me, ever solicited any
    21 funds from the public.
    22 It was not the intent and is not
    23 the intent. In fact, we may even not accept
    24 funds from the public because of the
    25 innuendoes that seem to be cast upon that.
    1 MR. WOOD: So that we are clear,
    2 too, and Mr. Kane, you do not have this
    3 alleged --
    4 MR. KANE: I have --
    5 MR. WOOD: Excuse me, let me
    6 finish.
    7 MR. KANE: Okay.
    8 MR. WOOD: You do not have as
    9 you represented or at least thought, you do
    10 not have here today this public relations ad
    11 or whatever you called it claiming that John
    12 and Patsy were soliciting public funds? You
    13 said you would look for it, and send it to
    14 me.
    15 MR. KANE: Yes. It is on my
    16 computer somewhere, and I can't find it.
    17 Q. (By Mr. Levin) Mr. Ramsey, when
    18 you came home on the 25th, do you recall if
    19 you threw your clothes down the chute to the
    20 second floor where someone who might have
    21 been in the house would have access to them?
    22 Can you tell us who might have done that?
    23 A. Who knows. I don't know.
    24 Q. I understand it is tough.
    25 A. I really don't. Yeah, I don't
    1 know.
    2 MR. WOOD: I mean, you asked for
    3 his clothes in December of '97, you got them
    4 in January of '98. Why, for the love of
    5 common sense and logic, wouldn't you have
    6 asked him about that in June of 1998 when
    7 his memory was a lot more fresh, at least
    8 fresher than it is now two plus years later?
    9 But, you know, that's just a part of the
    10 ongoing mystery of some of the aspects of
    11 the case, I guess, in terms of the
    12 investigation.
    13 Q. (By Mr. Levin) Wool shirts, would
    14 those normally go out to the cleaners or
    15 would it depend? Even now, what is your
    16 family practice?
    17 A. Well, if it is a dry-cleaning
    18 item, we'd normally send it directly to the
    19 dry cleaners. Once in a while they get
    20 thrown in by mistake, but particularly if it
    21 is a shirt.
    22 Q. Your dry-cleaning items, would you
    23 just throw them down the chute and let Linda
    24 sort them out, this is dry-cleaning, this
    25 gets washed or would you separate them up
    1 front and keep them in a separate place, if
    2 you recall?
    3 A. I don't -- I am trying to
    4 remember where the laundry chute went to. I
    5 mean, it probably -- I wasn't that organized
    6 to separate things out like that as a normal
    7 course of business.
    8 MR. BECKNER: Did you ask what he
    9 did on that particular night with the shirt?
    10 I missed that.
    11 THE WITNESS: Frankly, I don't
    12 remember.
    13 MR. LEVIN: I thought I had asked
    14 you. I wasn't sure if that was clear.
    15 THE WITNESS: I mean, typically
    16 if it is a wool shirt, something that does
    17 require dry-cleaning, I try to get several
    18 cycles out of it, but I don't remember.
    19 MR. BECKNER: What was your
    20 normal routine?
    21 THE WITNESS: Well, normally, I
    22 would --
    23 MR. WOOD: About dry-cleaning?
    24 MR. BECKNER: No.
    25 THE WITNESS: -- I would hang
    1 onto it. If it was something I wanted to
    2 wear again, I'd hang it, I'd try to, I'd
    3 usually hang it up. Sometimes I would put
    4 it on a chair. But I wasn't religious about
    5 that. I would normally try to hang it up.
    6 Q. (By Chief Beckner) Let me be
    7 more specific. Would you throw your clothes
    8 on the floor typically in a pile?
    9 A. Well, no, not, not if I was, if
    10 I was going to wear it again. If it was
    11 headed for the laundry, you know, it could
    12 end up on the floor before it ended up in
    13 the laundry chute, but if I intend to wear
    14 it again, if it was a suit or sweater, or
    15 something like that, I normally wouldn't
    16 throw it on the floor.
    17 MR. WOOD: Have we finished that
    18 area of questioning because it seemed like
    19 maybe it is a good time to take a short
    20 break.
    21 MR. LEVIN: I am finished with
    22 that area.
    23 MR. WOOD: Is that okay for
    24 everybody to take a short break?
    25 MR. LEVIN: That is good.
    1 MR. WOOD: Any guesstimate on
    2 time?
    3 MR. LEVIN: How about if we
    4 discuss it during the break.
    5 MR. WOOD: I am not looking to
    6 force you to answer, but curious for lunch
    7 plans.
    8 MR. LEVIN: Certainly as a courtesy
    9 we will tell you. Let us talk about it and
    10 we will let you know.
    11 (WHEREUPON, a brief recess was
    12 taken.)
    13 THE VIDEOGRAPHER: All ready.
    14 MR. KANE: Shall I go? Okay.
    15 Q. (By Mr. Kane) Mr. Ramsey, after
    16 December 26, 1996, did you ever go back in
    17 the house?
    18 A. No.
    19 Q. You never were in it after that?
    20 A. No.
    21 Q. Did you ever go back to the
    22 house?
    23 A. I think I drove by it, but I
    24 never went back to the house.
    25 Q. You mentioned Dorothy Allison
    1 earlier. Is this Dorothy Allison the
    2 psychic, she is now dead?
    3 A. As far as I know. I heard she
    4 is dead.
    5 Q. Well, I said that. That wasn't a
    6 question. Dorothy Allison is the Dorothy
    7 Allison who was a psychic that's made
    8 comments about this?
    9 A. As far as I know. I never laid
    10 eyes on Dorothy Allison, nor heard her. She
    11 was on a television program about this case,
    12 and we received information as a result of
    13 some things she said in terms of leads.
    14 Q. Okay. And that was part of that
    15 packet you handed in there?
    16 A. Uh-huh (affirmative).
    17 Q. There was a sketch that was made
    18 based on a description that she --
    19 A. Right.
    20 Q. -- created. Are you aware of
    21 that, that sketch?
    22 A. Yes.
    23 Q. Have you gotten any leads as a
    24 result of that sketch?
    25 A. We have gotten -- I know the lead
    1 level went up dramatically when we put that
    2 out there, and I think the reason for
    3 putting it out there was to keep things
    4 stirred up. One of our objectives certainly
    5 has been to keep this active in the public's
    6 mind.
    7 Q. So after that --
    8 A. Yeah, we got a lot of leads after
    9 that.
    10 Q. When you say you put it out
    11 there, what do you mean?
    12 A. It was put on our website by the
    13 investigators.
    14 Q. Okay. And you say after that, it
    15 got put on your website, you got a lot
    16 of --
    17 A. Yeah.
    18 Q. And is that still on your
    19 website?
    20 A. I haven't looked, but I don't
    21 believe so.
    22 Q. Why is that?
    23 A. We are trying to keep the website
    24 active so people come back. The whole
    25 objective here is to keep it stirred up,
    1 keep it active.
    2 Q. Is the ransom note on the
    3 website?
    4 A. It was -- well, the ransom note?
    5 No, I don't think so. No, not that I know
    6 of. I mean, I haven't seen it there.
    7 Q. Was that a conscious decision not
    8 to put it on?
    9 A. I wasn't directly involved with
    10 what went on that website from the beginning.
    11 I don't know if it was a conscious decision
    12 or not.
    13 MR. WOOD: I think Ollie would
    14 probably know.
    15 THE WITNESS: I think it's on the
    16 web in other places, I've been told.
    17 Q. (By Mr. Kane) Have you been
    18 involved in any efforts to publicize the
    19 ransom note?
    20 A. No. Not -- we wanted it released
    21 early on based on strong recommendations that
    22 that be done, but --
    23 Q. But you haven't, yourself,
    24 promoted that or anything?
    25 A. Uh-uh (indicating negatively).
    1 Q. Have you gotten anybody in the
    2 last two years who has contacted you saying
    3 they recognize the handwriting?
    4 A. We have gotten, we have gotten
    5 handwriting samples from people that say this
    6 looks familiar. The woman that turned her
    7 ex-husband in sent us a volume of his
    8 handwriting samples.
    9 Q. Well, she was dismissed on other
    10 grounds, from what I understand?
    11 A. Well, yes.
    12 Q. Was there anybody else besides her
    13 who submitted handwriting?
    14 MR. WOOD: I told you about the
    15 Fleet White package that I received.
    16 MR. KANE: Yes. That is right.
    17 Fleet White.
    18 MR. LEVIN: If I can interrupt
    19 for just a second, that's based on
    20 linguistics, though, if I understood you?
    21 MR. WOOD: To tell you the truth,
    22 I haven't, other than to recognize what it
    23 was, I did not try to study it. So I
    24 wouldn't -- my impression was initially it
    25 was linguistics, but it might be, it might
    1 reference handwriting.
    2 MR. KANE: Was that a handwritten
    3 note or something of Fleet or --
    4 MR. WOOD: No. It's about an
    5 inch and a half thick report.
    6 MR. KANE: Okay. But it's not
    7 handwritten, I was talking about handwriting
    8 here, was that in here?
    9 MR. WOOD: That is what I was
    10 telling Bruce. I didn't study it other than
    11 to recognize that it was someone sending me
    12 an analysis of Fleet White's writings. And
    13 whether it is limited to linguistics or
    14 whether it goes into the handwriting issue, I
    15 wouldn't state on the record without being
    16 certain, but I will get that to you all and
    17 you will know exactly what it is.
    18 Q. (By Mr. Kane) So, I'm sorry, YOU
    19 were saying, you said the Allison woman.
    20 Anybody else whose handwriting has been
    21 submitted based on -- well, by anybody?
    22 A. Well, we received a package that
    23 was delivered anonymously, which I believe we
    24 turned over to police a couple of years ago.
    25 I don't know. It's been --
    1 Q. I mean, to your recollection, has
    2 there been any handwriting you received as a
    3 result of the massive publicity about the
    4 handwriting, or about the ransom note?
    5 A. Is there any? Yeah, yeah.
    6 Q. You received that or your
    7 investigators have?
    8 A. Yeah, as far as I know.
    9 Q. Have you had any of that analyzed
    10 by any experts?
    11 A. I know early on we had Chris
    12 Wolf's handwriting looked at. I know we had
    13 them look at several.
    14 Q. There have been others that have
    15 been looked at by your experts?
    16 A. As far as I know.
    17 Q. Which experts are these now? I
    18 am aware of Mr. Ryle and Mr. Cunningham.
    19 A. As far as I know, that is who
    20 looked at it.
    21 Q. And when you say as far as you
    22 know, I mean, have you talked to them about
    23 their --
    24 A. I've never talked to Ryle and
    25 Cunningham directly.
    1 Q. Have you received information
    2 about them, because I am not aware that they
    3 looked at any others when I asked them
    4 besides Chris Wolf? Have you received
    5 information that they have, in fact, looked
    6 at those?
    7 A. I have not received information.
    8 It is my impression that they have, yes.
    9 Q. What was that impression based
    10 upon?
    11 A. The thousands and thousands of
    12 information bits that hit me every day from
    13 everywhere.
    14 I don't know. Ask them.
    15 Q. (By Mr. Beckner) You mentioned
    16 Chris Wolf. Did you know Chris Wolf prior
    17 to the death of your daughter?
    18 A. No.
    19 Q. (By Chief Beckner) Had you ever
    20 heard of Chris Wolf?
    21 A. No.
    22 MR. WOOD: There is some
    23 connection between Wolf and the Colorado
    24 University. Somebody has indicated that
    25 there may have been.
    1 MR. WICKMAN: I thought that he
    2 had been to a class.
    3 MR. KANE: I lost my place here.
    4 Q. (By Mr. Kane) You are aware of
    5 Jackie Dilson?
    6 A. Uh-huh (affirmative).
    7 Q. Have you ever spoken with Jackie
    8 Dilson yourself?
    9 A. Not directly, I don't believe.
    10 We got a videotaped message from her months
    11 ago, and that's the first time I had ever
    12 seen her.
    13 Q. So you never had an one-on-one
    14 conversation with her?
    15 A. No. Our investigators had, I
    16 know, at some length.
    17 Q. Do you recall, when you left
    18 Jalleo, is that how you pronounce it?
    19 A. Jalleo.
    20 Q. Jalleo. Jim Marino was quoted in
    21 the Denver papers about your leaving. Do
    22 you remember that at all?
    23 A. No, I don't remember the
    24 quote.
    25 MR. WOOD: Do you have a quote
    1 you can put in front of him to look at to
    2 refresh him?
    3 MR. KANE: I just asked him if
    4 he would remember it.
    5 MR. WOOD: Why don't you tell him
    6 what the quote was. Maybe he will remember.
    7 (By Mr. Kane) Well, he said that
    8 you had left Jalleo to concentrate on the
    9 investigation, that he had spoken to you the
    10 week before?
    11 A. I left Jalleo because of the
    12 tarnished reputation that had been laid upon
    13 me was detrimental to the business.
    14 Q. Okay. So it didn't have anything
    15 to do with spending more time on the
    16 investigation?
    17 A. No.
    18 Q. You also said that you had gotten
    19 a lot of, maybe not a lot, but you got
    20 experts to volunteer their time on the case.
    21 Who are those people? I never heard a name,
    22 but that statement.
    23 A. Well, it was part of the group
    24 that we asked to present to you in January.
    25 John Douglas spent time on it. We have a
    1 number of psychologists that have offered
    2 their help.
    3 Q. Do you know who they are?
    4 A. Well, one of the letters I have
    5 is in the file. We can certainly provide
    6 that to you.
    7 Q. I will be honest with you, when I
    8 got the letter in January, the only person
    9 who was mentioned in there was Kris Sperry.
    10 A. My impression was that it was a
    11 group of people who had looked at it. It
    12 was being led by John -- wasn't Wardman. He
    13 used to be a -- whether it is a prosecutor
    14 in Denver or not, but I met with him a
    15 couple of times.
    16 Q. Was he the one from Oregon?
    17 A. Yes. I cannot remember the name.
    18 But he had a medical associate that was
    19 involved with it, I know, out of New Mexico,
    20 I think.
    21 Q. What was that person's
    22 involvement?
    23 A. He was a, I believe -- I believe
    24 he was a --
    25 MR. LEVIN: Forensic pathologist?
    1 That is Sperry. Out of New Mexico?
    2 THE WITNESS: There is another
    3 guy.
    4 MR. RAMSEY: There are several --
    5 MR. LEVIN: Sperry worked in New
    6 Mexico on an Indian reservation to pay off
    7 his student loans many years ago.
    8 THE WITNESS: No. This is a guy
    9 who I believe currently lives in New Mexico.
    10 It's not Sperry. I can get you their names.
    11 I just don't remember off the top of my
    12 head. This was a year ago.
    13 Q. (By Mr. Kane) Why did you write
    14 the book?
    15 A. Needed the money. First of all,
    16 we wanted to tell our story. We had been
    17 lied about in the press for three years. We
    18 wanted to address every one of the media
    19 myths that were out there. We wanted one
    20 place that the truth was encapsulated. And
    21 we wanted to find the killer of our
    22 daughter.
    23 Q. So by publicizing information, you
    24 thought it would generate --
    25 A. Yeah.
    1 Q. Okay. Why did you decline to put
    2 in anything about your own investigation?
    3 A. One of the problems we had with
    4 the book is it got way too big. I know
    5 that. And we had to cut a lot.
    6 Q. Why did you decide to cut that?
    7 A. I don't know that we cut that at
    8 all. I don't remember if it was in there
    9 to start with.
    10 Q. Well, you made a statement about
    11 it.
    12 MR. WOOD: What page?
    13 THE WITNESS: What's the point?
    14 MR. KANE: On page, it's 373.
    15 Q. (By Mr. Kane) You say to avoid an
    16 accusation of grand standing from the media,
    17 not much will be said outside of a close
    18 circle about our own efforts to find the
    19 killer.
    20 A. And not much has been said about
    21 it.
    22 MR. WOOD: Doesn't that answer
    23 your question then?
    24 Q. (By Mr. Kane) Well, was that, I
    25 mean, was that the reason --
    1 A. Yes.
    2 Q. -- because you didn't want to be
    3 accused of grand standing?
    4 A. We have been in a position, and
    5 we have been for the past three and a half
    6 years, where we are damned if we do, damned
    7 if we don't. And that was our position.
    8 Q. Do you still consider Priscilla
    9 White to be a suspect?
    10 A. I never considered either of the
    11 Whites to be a suspect. Their behavior
    12 post-December '96 was very, very strange.
    13 And that -- we were frightened of it, pure
    14 and simple.
    15 MR. WOOD: Did they ever --
    16 THE WITNESS: But I -- you know,
    17 we were at their home that evening, they
    18 were in good spirits, they had relatives
    19 there, I had no reason to consider them
    20 suspects.
    21 MR. WOOD: All of their letters,
    22 you made mention of this, and it now has
    23 struck that cord with me on handwriting, it
    24 seems that all of Fleet's and Priscilla's
    25 joint letters have been typed. Do you all
    1 have handwriting on Fleet White?
    2 MR. KANE: I am sure we do. I
    3 know we do.
    4 (By Mr. Kane) Maybe the word
    5 suspect then needs to be defined. Do you
    6 today think there is a possibility that
    7 Priscilla White killed your daughter?
    8 A. We have not eliminated anyone in
    9 our minds. We have become suspicious of
    10 everyone. And that's how I feel.
    11 Q. Is there anything, other than what
    12 you described on several occasions about what
    13 happened down in Atlanta around the time of
    14 the funeral, is there anything other than
    15 that that would suggest --
    16 A. Yeah. God, he is in the paper
    17 every few months with some 20 page letter.
    18 I just think that -- I don't understand it.
    19 I can't explain it. I don't know if he --
    20 I mean, it was a traumatic event. They were
    21 there. I don't know. But our feeling was
    22 that their behavior was frightening.
    23 MR. WOOD: You all are aware that
    24 there is a problem exists between the libel
    25 charges and all of the background behind
    1 that?
    2 MR. KANE: Yes.
    3 MR. WOOD: So all of that, for
    4 whatever reason, is bizarre.
    5 THE WITNESS: But it makes no
    6 sense.
    7 MR. WOOD: Or for whatever
    8 reason. I am not suggesting bizarre to any
    9 individual, but the whole thing is bizarre.
    10 Q. (By Mr. Levin) Mr. Ramsey, I
    11 don't know for a fact it has been answered,
    12 so if the question sounds kind of naive,
    13 bear with me. Neither Priscilla nor Fleet,
    14 since '98, have made any attempts to contact
    15 you, reconcile, restore your friendship, have
    16 they?
    17 A. Well, they -- we were staying at
    18 the Stein's, and they apparently, I learned
    19 later, approached Susan, asked to meet with
    20 us. And she refused. I wasn't aware of
    21 that at the time. There would have been no
    22 reason to do that. But maybe that added
    23 fuel to the fire. I don't know. From
    24 their perspective.
    25 But I had written Fleet. I had
    1 a sail off of a sailboard that belonged to
    2 him that got packed inadvertently. And I
    3 sent it back to him with a note, don't
    4 believe what you've read in the media.
    5 He burst in on me one day when I
    6 was meeting with our minister, and I talked
    7 to him then. But other than that --
    8 Q. But nothing in '99 or since June
    9 of '98 --
    10 A. No.
    11 Q. -- no attempts or no letters from
    12 them to renew --
    13 A. No.
    14 Q. -- your friendship?
    15 A. No.
    16 Q. (By Mr. Kane) Have you been
    17 critical of the Boulder police for not
    18 interviewing everyone who was around the
    19 neighborhood?
    20 A. I have been told that that wasn't
    21 done at the beginning, and I had been
    22 critical of that, yes.
    23 Q. The people who were not
    24 interviewed, have your investigators
    25 interviewed them?
    1 MR. WOOD: Hold on one second.
    2 I think you are comparing apples and oranges,
    3 slightly. If I understood your question, you
    4 are asking, was he critical of the fact they
    5 weren't interviewed.
    6 MR. KANE: Yeah.
    7 MR. WOOD: And I think his answer
    8 was, yes, that they weren't interviewed early
    9 on. And obviously the opportunity for his
    10 investigators to interview them early on, you
    11 know, is lost.
    12 THE WITNESS: My understanding is
    13 the information we sent to Chief Beckner was
    14 a list of people that we were aware of that
    15 hadn't been talked to, and I believe the
    16 Chief said he had, that that had been done.
    17 So --
    18 Q. (By Mr. Kane) Have any of your
    19 investigators interviewed any of those people
    20 themselves?
    21 A. I know they have interviewed a
    22 number of people. I don't know if they have
    23 interviewed all of them. I mean, ask our
    24 investigator.
    25 Q. Mr. Ramsey, to follow up on the
    1 neighborhood, it was brought to my
    2 attention --
    3 THE WITNESS: Do we want an
    4 answer to that question or not?
    5 MR. WOOD: If you all make your
    6 list, add that to the list when all is said
    7 and done, and I will consider it and get you
    8 an answer if it is appropriate. It probably
    9 will be.
    10 Q. (By Mr. Levin) It was brought to
    11 my attention fairly recently that a woman I
    12 believe named Jean Fortier, F-o-r-t-i-e-r, for
    13 the reporter, who are the parents of some
    14 children who were over your house on
    15 Christmas, and they, they, she, excuse me,
    16 said that her children reported to her at
    17 Christmas day when they went over to play,
    18 they played with Burke but that JonBenet did
    19 not play because she was sick. I hadn't
    20 heard that before. Is that nonsense?
    21 A. Absolutely. I don't know who
    22 that is, but we had a whole parcel of kids
    23 there all day.
    24 MR. KANE: I have to bolt.
    25 MR. LEVIN: Do you have anything
    1 left?
    2 MR. KANE: No.
    3 MR. LEVIN: Mike's got to catch a
    4 plane.
    5 (WHEREUPON, Mr. Kane left the
    6 interview.)
    7 Q. (By Chief Beckner) What about
    8 your relationship with John and Barbara
    9 Furnham --
    10 A. It was -- they were good friends.
    11 We spent a fair amount of time together.
    12 They were good family friends.
    13 Q. Are they still good friends?
    14 A. Well, we certainly consider them
    15 friends. Barbara had some emotional problems
    16 before this all happened, and John wrote us,
    17 I don't know, I guess months later and said
    18 that Barbara is having difficulty dealing
    19 with this and please ask Patsy not to write
    20 her or respond to her.
    21 I have talked to John a few
    22 times, but not, not recently.
    23 Q. Since June of '98, have you
    24 talked to John?
    25 A. Possibly. I don't remember
    1 specifically, but I have talked to him
    2 probably twice, I guess.
    3 Q. By telephone?
    4 A. By telephone.
    5 Q. (By Mr. Wickman) John, I asked
    6 this of Patsy earlier this morning. Since
    7 you relocated to Atlanta, have there been any
    8 threats to you, to her, or to Burke?
    9 A. There have been. In fact, I just
    10 got one last night on the internet. The guy
    11 was in New York and said if I ever came to
    12 New York, I was done for.
    13 We've had people come to our
    14 door -- I mean to our home. We put a gate
    15 up. But what has been uplifting for us is
    16 that, in the last three and a half years,
    17 virtually everyone who has approached us has
    18 been kind and sympathetic.
    19 But we would get occasional hate
    20 letters. We haven't gotten many, haven't
    21 gotten too many recently other than the one
    22 last night.
    23 Q. I was in discussion with an
    24 Atlanta detective probably a year and a half
    25 ago about some guy beating on your door in
    1 order to meet somebody -- I don't know if it
    2 was you or Patsy -- at the club or
    3 something. Do you remember that?
    4 A. Yeah. Yeah. I remember that.
    5 That was one of the, he rang our doorbell
    6 basically at 2:00 in the morning and said, I
    7 saw the lights were on so I figured we were
    8 up. We had an intercom system. He said I
    9 have got critical information. Well, it's
    10 2:00, we will meet you. I think he said
    11 yes to that and we called the Atlanta police
    12 and I guess they contacted you.
    13 Q. Yeah, and I don't remember, but I
    14 don't think it panned out.
    15 A. No. The Atlanta police came back
    16 that afternoon and said the guy was
    17 certifiable, and we never heard from him
    18 again.
    19 Q. (By Mr. Levin) Mr. Ramsey, your
    20 wife told us that there was a college
    21 student that was staying with the Steins, I
    22 believe, named Nathan Inouwe?
    23 MR. WOOD: It was a reference in
    24 the book.
    25 Q. (By Mr. Levin) Okay. Had you,
    1 prior to the murder of your daughter, had
    2 you had any contact with him?
    3 A. Yeah. We would see him at their
    4 house. He would drive the kids to school
    5 occasionally in a carpool, Patsy would take
    6 them, sometimes, Susan would sometimes or
    7 Nathan would take them.
    8 Q. Was there anything unusual about
    9 his conduct -- and I am asking for your
    10 contemporaneous impression, and then I'm going
    11 to ask you about the post-murder impression.
    12 Your contemporaneous impression of Mr. Inouwe
    13 I assume was favorable if you let him drive
    14 your kids to school?
    15 A. Yes. He was a very, very kind,
    16 nice person.
    17 Q. Keeping in mind that you told us
    18 that you are suspicious of everyone, is there
    19 anything in particular about Mr. Inouwe,
    20 using the power of hindsight, that causes you
    21 today to be particularly suspicious of him?
    22 A. Nothing specifically in terms of
    23 his actions or what he said. Have I
    24 eliminated him? No, I haven't. I thought
    25 about that from time to time, but I don't
    1 consider him of strong, strong interest.
    2 Q. We asked Mrs. Ramsey about the
    3 Bloomi's underpants that JonBenet was wearing
    4 when she was found murdered, and we are
    5 trying to kind of track those from purchase
    6 to her. And again, I suspect you probably
    7 don't have detailed information --
    8 A. No.
    9 Q. -- about your child's underwear,
    10 but you can see why I need to ask the
    11 questions; right?
    12 A. Right.
    13 Q. We believe that they were
    14 purchased in November of 1996. Were you
    15 aware of their existence before JonBenet's
    16 death?
    17 A. No, but I wouldn't have been.
    18 But I mean, I -- what I know is what was
    19 asked of Patsy when she said, you know, we
    20 were on a trip to New York. She bought
    21 them and I think had planned to give them to
    22 her niece, who is older than JonBenet, and
    23 then they, for some reason, decided that
    24 JonBenet would have them. I don't know if
    25 she wanted them or if Patsy gave them to
    1 her, but --
    2 Q. The niece that they were purchased
    3 for, I think, was Jenny Davis?
    4 A. Uh-huh (affirmative).
    5 Q. Do you recall approximately how
    6 big she was in 1996? I know it is a tough
    7 question.
    8 A. She's either a junior or a senior
    9 in high school now. And she's fairly
    10 stocky.
    11 Q. Was there anything about the
    12 Bloomi's underwear that was particularly,
    13 other than the fact that they come from
    14 Bloomingdale's, fascinating that caused them
    15 to be, you know, JonBenet would talk about
    16 them or something, like I have these cool
    17 panties that have the days of the week,
    18 anything that would direct your attention to
    19 them?
    20 A. No, no.
    21 Q. As far as the size, they were for
    22 an 85-pound girl. Were you aware she was
    23 wearing these real big panties?
    24 A. Only after the fact.
    25 Q. After the fact?
    1 A. Yeah.
    2 Q. Our information that we developed
    3 from the grand, well -- after the grand
    4 jury, actually, were you unaware of any
    5 incident where JonBenet had any accidents at
    6 school where she would have to go into the
    7 extra panty box that most grammar schools
    8 keep for young kids? Do you have a memory
    9 of an incident that is contrary to that?
    10 A. At school?
    11 Q. Yes.
    12 A. No.
    13 Q. (By Chief Beckner) Did you, the
    14 night of the 25th, did you help undress
    15 JonBenet?
    16 A. I did. I think I was asked that
    17 before, but I don't -- I mean, I at least
    18 took her shoes off, I believe, later on. I
    19 carried her upstairs, laid her in bed, took
    20 her shoes off. I don't know if I took her
    21 coat off.
    22 Usually what I would do is try to
    23 get her semi-ready for bed because it wasn't
    24 infrequent she would fall to sleep when we
    25 came home like that, before we got home.
    1 Patsy would come in, get her in bed totally.
    2 Q. I guess what I mean is, did you
    3 notice at that time whether she was or was
    4 not wearing underwear?
    5 A. I mean, I think I would have
    6 noticed if she wasn't. But I don't
    7 remember. I really don't.
    8 Q. Do you recall if you took her
    9 underwear off?
    10 A. No, I'm sure I did not.
    11 MR. LEVIN: Mr. Wickman?
    12 Questions?
    13 MS. HARMER: Nothing.
    14 MR. LEVIN: I think we are done.
    15 MR. WOOD: All right.
    16 MR. LEVIN: Thank you for talking
    17 to us.
    18 MR. BECKNER: Thank you for your
    19 time.
    20 THE WITNESS: You are welcome.
    21 Thanks for coming out.
    22 (Whereupon, the interview of JOHN
    23 RAMSEY was concluded.)
    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.
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