Patsy Depo: Part 1

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Patsy Depo: Part 1

Post by Mama2JML on Sun Jan 06, 2013 10:53 pm

VIDEOTAPED DEPOSITION OF PATRICIA PAUGH RAMSEY
December 11, 2001 9:14 a.m.

Page 1
1 IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF GEORGIA
2 ATLANTA DIVISION
3
ROBERT CHRISTIAN WOLF,
4
Plaintiff, CIVIL ACTION FILE
5 vs. NO. 00-CIV-1187(JEC)
6 JOHN BENNETT RAMSEY and
PATRICIA PAUGH RAMSEY,
7
Defendants.
8 ~~~~~~~~~~~~~~~~~~~~~~~~~
9
10 VIDEOTAPED DEPOSITION OF
11 PATRICIA PAUGH RAMSEY
12
December 11, 2001
13 9:14 a.m.
14 Alexander Gallo & Associates, Inc.
500 The Candler Building
15 127 Peachtree Street, N.E.
Atlanta, Georgia
16
17
Alexander J. Gallo, CCR-B-1332, CRR
18
19
20
21
22
23
24
25

Page 2
1 APPEARANCES OF COUNSEL
2 .
3 On behalf of the Plaintiff:
4 DARNAY HOFFMAN, Esq.
5 Law Offices of Darnay Hoffman
6 Suite 209
7 210 West 70th Street
8 New York, New York 10023
9 (212) 712-2766
10 -and-
11 EVAN M. ALTMAN, Esq.
12 Law Offices of Evan M. Altman
13 Suite 495
14 5901-C Peachtree Dunwoody Road
15 Atlanta, Georgia 30328
16 (770) 394-6466
17 .
18 .
19 .
20 .
21 .
22 .
23 .
24 .
25 .

Page 3
1 On behalf of the Defendants:
2 JAMES C. RAWLS, Esq.
3 ERIC P. SCHROEDER, Esq.
4 S. DEREK BAUER, Esq.
5 Powell, Goldstein, Frazer & Murphy, L.L.P.
6 Sixteenth Floor
7 191 Peachtree Street, N.E.
8 Atlanta, Georgia 30303
9 (404) 572-6600
10 -and-
11 L. LIN WOOD, Esq.
12 BRANDON HORNSBY, Esq.
13 MAHALEY C. PAULK, Esq.
14 L. Lin Wood, P.C.
15 2140 The Equitable Building
16 100 Peachtree Street
17 Atlanta, Georgia 30303
18 (404) 522-1713
19 .
20 Also Present:
21 John Bennett Ramsey
22 Michael McElroy, Videographer
23 .
24 .
25 .

Page 4
1 Videotaped Deposition of Patricia P. Ramsey
2 December 11, 2001
3 THE VIDEOGRAPHER: We are on the
4 video record at 9:14.
5 MR. HOFFMAN: Good morning, Mrs.
6 Ramsey, Lin Wood.
7 This is the deposition of Patricia
8 Ramsey in the case of Robert Christian Wolf
9 versus John Bennett Ramsey and Patricia Paugh
10 Ramsey.
11 Do you need the index number for that
12 for the tape?
13 Mrs. Ramsey, have you ever attended a
14 deposition before.
15 MR. WOOD: Maybe we ought to have --
16 MR. HOFFMAN: So we have a record of
17 everybody that is here.
18 MR. WOOD: -- so we have an
19 understanding, we might want to make sure we have
20 a record of who is here and then a couple of
21 other stipulations.
22 I am Lin Wood. I represent John and
23 Patsy Ramsey.
24 MR. RAWLS: I am Jim Rawls,
25 co-counsel with Mr. Wood for John and

Page 5
1 Patsy Ramsey.
2 MR. RAMSEY: I am John Ramsey.
3 MS. PAULK: Mahaley Paulk.
4 MR. BAUER: Derek Bauer.
5 MR. SCHROEDER: Eric Schroeder.
6 MR. ALTMAN: Evan Altman, co-counsel
7 with Darnay Hoffman on behalf of Mr. Wolf.
8 MR. HOFFMAN: Yes. And, of course,
9 Darnay Hoffman, lead counsel on the Chris Wolf
10 case.
11 MR. WOOD: And I think we have
12 agreed that this deposition is taken pursuant to
13 the Federal Rules of Civil Procedure and that the
14 deposition is taken pursuant to agreement of
15 counsel.
16 Mrs. Ramsey will read and sign, and I
17 am sure that can be undertaken before any notary
18 public.
19 MR. HOFFMAN: Certainly.
20 Also, this is a deposition that is
21 being taken subject to a so-ordered, stipulated
22 protective order also and confidentiality agreement
23 between counsel.
24 MR. WOOD: It is. And in that
25 regard, I want to make just one statement, if I

Page 6
1 may, on the record.
2 MR. HOFFMAN: Sure.
3 MR. WOOD: Federal Rule of Civil
4 Procedure 26(b)(1) states that the scope of
5 discovery is as follows, and I quote:
6 "Parties may obtain discovery regarding
7 any matter not privileged that is relevant to the
8 claim or defense of any party."
9 And it goes on to state:
10 "For good cause, the Court may order
11 discovery of any matter relevant to the subject
12 matter involved in the action."
13 As you know, Darnay, that represents
14 the change that was effectuated in the scope of
15 discovery with the December 2000 amendments to the
16 Federal Rules of Civil Procedure. And in the
17 stipulation and protective order in paragraph 2,
18 the parties, including the plaintiff, and you, on
19 behalf of the plaintiff, have agreed that, and I
20 quote from the protective order, "Consistent with
21 the amendments to the Federal Rules of Civil
22 Procedure, which became effective December 1,
23 2000, the parties recognize the right of parties'
24 counsel to issue appropriate instructions to
25 parties during their depositions in order to

Page 7
1 maintain the appropriate scope of discovery as
2 defined in the rules."
3 I make that observation solely because
4 I do not want there to be any subsequent
5 misunderstanding or misrepresentation as to why it
6 may be necessary, during the course of this
7 deposition, for me, as counsel for the Ramseys,
8 to instruct Mrs. Ramsey that a subject that you
9 are inquiring about is beyond the scope of the
10 Federal Rules of Civil Procedure.
11 That is to say, you may inquire into
12 something that is relevant to the subject matter,
13 but since there has not been good cause shown and
14 a court order entered, as we have noted in our
15 protective order, the parties have agreed that we
16 would instruct the witness not to answer because
17 it would go beyond the claim or the defense in
18 this action and it would not be in any way a
19 matter of Mrs. Ramsey being unwilling to answer a
20 question. It would simply be a matter of, as you
21 and I know, we don't make the rules. We are
22 simply obligated to play by the rules, and so,
23 therefore, we will obviously play by the rules
24 today. And if we do get outside the relevant
25 scope of discovery, I will exercise my obligation

Page 8
1 as recognized by you to make an instruction to
2 her not to answer the question.
3 Agreed?
4 MR. HOFFMAN: Absolutely.
5 MR. WOOD: Okay.
6 MR. HOFFMAN: And, in fact, what I
7 thought we would do is that, if we run into a
8 roadblock with respect to what is, in fact,
9 relevant or not relevant, what we could do is
10 just simply make a notation for the record, and
11 then I thought that the most prudent thing for
12 everybody to do is, as we are coming to the
13 close of discovery, that almost in like an
14 omnibus motion, both parties could present Judge
15 Carnes with anything that they wanted in the way
16 of an instruction to compel an answer, if
17 appropriate.
18 So if we need to get a judge's
19 ruling on issues or whatever, we will just simply
20 reserve it -- preserve it in the deposition
21 record; and then what we would do is at some
22 future date, just simply go before Judge Carnes
23 and just have her make a one-time ruling on all
24 of our issues and claims and whatever else with
25 respect to discovery, which I think is probably

Page 9
1 the most economical way to do it, and maybe I
2 think Judge Carnes would probably appreciate it if
3 we handled it that way.
4 MR. WOOD: Well, I just don't want
5 the record to be misconstrued that, obviously, we
6 understand that there may be, obviously, a need
7 to, in this deposition, to make the instruction.
8 And it is not to be used against the witness.
9 It is simply a matter of trying to properly
10 follow the rules.
11 And then, if necessary, if someone
12 believes that the witness should have answered,
13 then obviously that party has a right, as that
14 party deems appropriate, to file a motion with
15 Judge Carnes and get a ruling.
16 I think we agree on what we
17 stipulated to, and I think we agree on the scope
18 of the deposition. I don't really think we are
19 going to have a problem. I think you will stay
20 to the issue of the claims made by Mr. Wolf and
21 the defenses made by the Ramseys. And if we
22 don't go beyond that, we are not going to have a
23 problem, I don't believe, on that particular
24 issue.
25 MR. HOFFMAN: Just for the record, so

Page 10
1 there is no misunderstanding later on in the
2 deposition, what precisely do you see the claims
3 as Mr. Wolf is representing them in the complaint
4 for the purposes of establishing relevance here?
5 MR. WOOD: Mr. Wolf has made a
6 claim, as I understand it, that the Ramseys
7 published certain statements in their book that
8 were false pertaining to him, that they published
9 certain statements in their book that were also
10 defamatory with regard to Mr. Wolf. That makes
11 up the first part of his libel claim.
12 And then he contends that they
13 published those statements, false and defamatory,
14 with actual malice. And as I understand the
15 claim, that actual malice is based on the
16 allegation that Patsy Ramsey killed JonBenet and
17 that Mr. Ramsey has been part of a cover-up.
18 The second part of the case, as I
19 understand it, is that, subject to the statute of
20 limitations problems, Mr. Wolf is asserting that
21 the Ramseys hired investigators to give the
22 Boulder police information about Mr. Wolf which
23 inflicted emotional distress upon him.
24 Those are your claims, as I think I
25 clearly understand them. Have I got them right?

Page 11
1 MR. HOFFMAN: Absolutely. The only
2 reason I am asking you to articulate them for the
3 record is so that, if I go into any of these
4 claim areas, you will at least deem them relevant
5 for the purposes of the deposition.
6 MR. WOOD: I will have to deal with
7 that on a question-by-question basis.
8 MR. HOFFMAN: I understand that, but
9 you do understand that if, in fact, one of the
10 claims is that Mrs. Ramsey was somehow involved
11 in either the authorship of the ransom note or in
12 the death of her daughter, that questions
13 involving that are, in fact, relevant for the
14 purposes of the rules?
15 MR. WOOD: I don't have any problem
16 with acknowledging that issues regarding ransom
17 note authorship by Mrs. Ramsey, and the issue of
18 whether she, as contended by you and Mr. Wolf,
19 killed her daughter, are clearly part of Mr.
20 Wolf's lawsuit. And that is part of the burden
21 that Mr. Wolf has to carry to prove that beyond
22 clear and convincing evidence.
23 The point being, though, that there
24 are a host of matters that would go to the
25 subject matter but are not specifically confined

Page 12
1 to those claims and the defenses, the basic
2 defense being truth, that published statements
3 were true, and that, in fact, Mrs. Ramsey was not
4 involved in the criminal death of her daughter.
5 I think the only other defense we
6 have is not something you would be questioning
7 Mrs. Ramsey about, and that might go to the issue
8 of I think the 13th defense and the issue of
9 publicity of the plaintiff.
10 I don't think we are going to have a
11 problem; but, for example, personal private
12 information about the Ramseys' life at present
13 certainly would not be relevant to the claims
14 made.
15 MR. HOFFMAN: No. I agree.
16 MR. WOOD: That is just one example.
17 I want to make sure we protect that on the
18 record. I think we understand where we are
19 headed, so let's get going and get there.
20 PATRICIA RAMSEY, having been first
21 duly sworn, was examined and testified as follows:
22 EXAMINATION
23 BY-MR.HOFFMAN:
24 Q. Good afternoon -- actually, good
25 morning, Mrs. Ramsey. Thank you for being here.

Page 13
1 A. Good morning.
2 Q. You just heard your attorney explain,
3 basically, the claims in this action. Is there
4 anything that you need clarified with respect to
5 what he said before we go forward?
6 MR. WOOD: I don't think she can
7 answer that question.
8 MR. HOFFMAN: Okay. I just want to
9 give her the opportunity to --
10 MR. WOOD: We would have to send her
11 to law school and let her go 24 years of
12 practice before we would ask her if she could
13 understand anything I might say.
14 Q. (By Mr. Hoffman) Mrs. Ramsey, I
15 believe that you were the coauthor on a book
16 called "the Death of Innocence"; is that
17 correct?
18 A. Yes, sir.
19 Q. And I would just like to ask you, in
20 your own words, though I know there is discussion
21 in the book, why it is that you wrote the book
22 "Death of Innocence"?
23 A. My husband and I wrote the book so
24 that we could make sure that the truth was
25 presented accurately from our own hearts and lips.

Page 14
1 Q. Were there any other reasons?
2 A. No, sir.
3 Q. I am going to -- there is a
4 reference on page 408 of your book. I am going
5 to show that to Mr. Lin first.
6 MR. WOOD: Do you want to mark this?
7 MR. HOFFMAN: No. I just simply
8 want to refresh her memory with respect to that.
9 MR. WOOD: This is page 408 of the
10 paperback?
11 MR. HOFFMAN: Yes, with respect to
12 the paperback.
13 Q. (By Mr. Hoffman) Where there is --
14 MR. WOOD: Are you asking her to
15 look at the highlighted portion?
16 MR. HOFFMAN: The highlighted portion
17 there, just to refresh her memory with respect to
18 maybe another reason why the book was written.
19 MR. WOOD: You are not representing
20 that this paragraph talks about why the book was
21 written?
22 MR. HOFFMAN: Well, it is one of the
23 express reasons for going into the material that
24 was gone into there with the hope that the killer
25 will be caught; the truth being that the Ramseys,

Page 15
1 contrary to media reports, were not responsible
2 for their daughter's death, and that this book,
3 in fact, not only shows that, but also the book
4 contains a chapter on the murderer, meaning that
5 there is a profile of the potential murderer.
6 And I wanted to know from Mrs. Ramsey
7 whether the purpose of the book was something
8 more than just a general, you wanted the truth
9 out.
10 Q. (By Mr. Hoffman) Was the purpose of
11 the book also to present information to the
12 public who might then be able to come forward as
13 to who the murderer was in this particular case?
14 MR. WOOD: That doesn't have anything
15 to do with page 408.
16 MR. HOFFMAN: Well, it is mentioned
17 there. That is one of the stated goals.
18 MR. WOOD: We may just be parsing
19 words. This talks about their goals, bringing the
20 killer to justice.
21 MR. HOFFMAN: Right.
22 Q. (By Mr. Hoffman) Was this part of
23 your goal?
24 MR. WOOD: Was the book consistent
25 with part of your goals? I think that is a

Page 16
1 fair question.
2 THE WITNESS: So could you repeat the
3 question?
4 Q. (By Mr. Hoffman) You will be asking
5 me to do a lot of that today. Believe me.
6 Was one of the goals of writing the
7 book to help in the solution of this crime,
8 identifying the possible murderer; meaning that if
9 you put this information before the public, that
10 maybe someone would have information that could
11 then come forward --
12 MR. WOOD: Objection.
13 MR. HOFFMAN: You object?
14 MR. WOOD: I object to the form of
15 the question, but go ahead and finish. I thought
16 you were through.
17 MR. HOFFMAN: I would like Mrs.
18 Ramsey to explain whether or not that was part of
19 the goal of the book was basically to assist in
20 finding the killer of JonBenet Ramsey.
21 THE WITNESS: Well, I believe there
22 was a section of the book that talks about the
23 profile of the killer, as we have been told about
24 him. So that information, yes, was included in
25 the book to be brought forth to the public in

Page 17
1 the event that that would assist in someone
2 remembering things that would lead us to leads
3 that would lead us to the killer.
4 Q. (By Mr. Hoffman) So would it be
5 fair to say that the purpose of the book was to
6 do something other than just simply tell the
7 truth about the case, that there was -- that you
8 were trying to assist the investigation in some
9 way by including certain information in the book,
10 such as the profile of the murderer?
11 A. The reason that I wrote the book is
12 so that there is in one place, in black and
13 white, an accurate account of what happened.
14 I mean, when I was writing it, I was
15 thinking of my children and my grandchildren.
16 There are so many stories out there that are
17 false and misleading and untrue, I wanted -- you
18 know, I was thinking of this as a historical
19 document to give to my children.
20 Q. Could you explain, to the best that
21 you remember, the process by which you wrote the
22 book? I mean, did you sit down with a pen and
23 pad or did you use a Dictaphone? How was the
24 book written, given that both you and John are
25 listed as authors, the actual writing process?

Page 18
1 MR. WOOD: I object to the form of
2 the question.
3 You may answer the question, if you
4 understand it.
5 The problem is you kind of sometimes
6 ask two or three questions within one.
7 MR. HOFFMAN: I understand.
8 MR. WOOD: I want her to be clear on
9 exactly what the question is. I think, correct
10 me if I am wrong, I think he is trying to find
11 out whether you actually physically typed on a
12 computer, dictated into a tape, made handwritten
13 notes.
14 Is that what you are asking?
15 MR. HOFFMAN: Exactly.
16 MR. WOOD: Do you understand that?
17 THE WITNESS: I think we did some of
18 all of that.
19 Q. (By Mr. Hoffman) Did you and Mr.
20 Ramsey sit physically together and write the book,
21 or did you write it in separate, you know,
22 environments, meaning you are in one part of the
23 house and he is in another part? Did you
24 compose it that way?
25 A. Some of all of that. We were living

Page 19
1 in an apartment at the time, so it was a small
2 living space. So we were --
3 Q. At some point, I believe there was --
4 well, I will withdraw that question.
5 Did anyone else assist you in writing
6 the book?
7 A. We had an editor that was provided by
8 the publisher and a ghost writer, if you want to
9 call it that, who helped us with some of the
10 structure and organization.
11 Q. Who is the ghost writer?
12 A. I think his name is in the book
13 there somewhere. Let's see. Oh, Robert Wise,
14 Reverend Robert Wise.
15 Q. When you looked at the final
16 manuscript of the book, was it very different
17 from what you had originally prepared and given
18 to Mr. Wise, or Reverend Wise?
19 MR. WOOD: Are you assuming they
20 prepared a manuscript and gave to it Wise and
21 then got back a manuscript?
22 MR. HOFFMAN: At some point, I am
23 assuming that their work product was turned into
24 a manuscript of some sort and that Mr. Wise
25 worked with it in some way.

Page 20
1 MR. WOOD: Well, I am not sure that
2 is right. It may have been given to him
3 piecemeal, Darnay. I think you need to figure
4 that out first.
5 Q. (By Mr. Hoffman) I will withdraw
6 that question and ask you very simply, explain
7 exactly how you worked with Reverend Wise on
8 writing the book.
9 A. Well, he would sit, and we would
10 talk. I had some things that I had written, and
11 sometimes he would ask questions about things.
12 It was kind of a back and forth. Sometimes he
13 would take something I had written and edit, and
14 then would -- I mean, it was kind of an evolving
15 process.
16 Q. Did he use a tape recorder to tape
17 any of the things you were saying?
18 A. I believe so, yes.
19 Q. Did you give him written notes to
20 look at?
21 A. I can't remember exactly. I don't --
22 Q. Did you prepare notes for the book,
23 written notes?
24 A. Yes. Sometimes -- I mean, I had
25 some things I had written and some things we

Page 21
1 just talked about.
2 Q. Did you keep copies of your notes?
3 A. No, I did not.
4 Q. Do you know what happened to your
5 notes?
6 A. They were thrown away as I finished
7 with that part of the writing.
8 Q. You threw them away?
9 A. Yes.
10 Q. Were you shown a copy of what we
11 would call the rough draft of the book before it
12 was sent to the publisher?
13 A. There were many drafts, yes, that we
14 would keep reviewing.
15 Q. Who would prepare the drafts?
16 A. A typist, I think, or the editor,
17 perhaps. She kept a main manuscript going.
18 Q. A main file?
19 A. I am not sure how she did it, but
20 she would keep it.
21 Q. Were you given an opportunity to
22 review the final manuscript before it was sent to
23 the publisher?
24 A. I believe so. I believe so.
25 Q. Do you remember reviewing?

Page 22
1 A. Not specifically. I mean, there were
2 so many iterations, I can't remember exactly
3 which.
4 Q. When was the first time you had an
5 opportunity to read the book from beginning to
6 end as it was published?
7 MR. WOOD: After it was published?
8 MR. HOFFMAN: In the form in which
9 it was published.
10 MR. WOOD: Like the galleys?
11 MR. HOFFMAN: It could have been a
12 galley. I don't know at what point --
13 THE WITNESS: You mean the hardback
14 book?
15 Q. (By Mr. Hoffman) The hardback book,
16 yes.
17 A. Probably when it was completely
18 published in March of 2000.
19 Q. Did you see anything that looked like
20 what they call galleys?
21 A. I don't think I saw galleys.
22 Q. So the first time you actually were
23 able to read the book, then, is when it appeared
24 in hard cover in the actual bound, hard-covered
25 issue?

Page 23
1 A. Well, I read the manuscript. I don't
2 know if you call that the book.
3 Q. So there was a manuscript, a completed
4 manuscript that you were able to read before it
5 was sent to the printer; is that correct?
6 A. I believe so.
7 Q. Did you review it?
8 A. I believe I did.
9 Q. And did you look at portions of it
10 in terms of statements that were accurate or not
11 accurate?
12 A. Well, I primarily -- the way the book
13 is written, I speak, John speaks, I speak, John
14 speaks. And I was mainly concentrating on what I
15 had put in the book.
16 Q. Do you remember, in the book, whether
17 or not there is a theory of the crime that was
18 -- as you believed it may have been committed
19 talked about in the book, written about?
20 A. I am not sure what you mean.
21 Q. The book contains a theory of the
22 crime. Do you remember what the theory of the
23 crime was in the book?
24 MR. WOOD: Why don't you show her
25 what you are talking about in the book.

Page 24
1 THE WITNESS: I mean, the whole book
2 is --
3 MR. WOOD: There may be a number of
4 different theories that are discussed in whole or
5 in part.
6 MR. HOFFMAN: I just want to see
7 what she remembers.
8 MR. WOOD: We are not here to engage
9 in a memory contest about what is or is not in
10 the book. If you have a question about something
11 that is in the book, I think, fairly, you are
12 required to put it in front of her, give her the
13 opportunity to look at it, put it into context,
14 and then respond to your question.
15 So if there is something in the book,
16 be it theory or whatever, show her what you want
17 her to look at, and she will be glad to answer
18 your question.
19 MR. HOFFMAN: I am going to test her
20 memory right now.
21 MR. WOOD: We are not going to
22 engage in a memory contest of what is in the
23 book.
24 MR. HOFFMAN: It is not a memory
25 contest. I have a right to see what, if

Page 25
1 anything, Mrs. Ramsey currently remembers about
2 the theory of the crime.
3 MR. WOOD: That is a different
4 question. You are asking her about what is in the
5 book, and she is entitled, and you know she is
6 entitled, to see what you are referencing in the
7 book, put it into context, and then answer your
8 question.
9 MR. HOFFMAN: Mrs. Ramsey, I am going
10 to withdraw the question.
11 Q. (By Mr. Hoffman) I would like you
12 to tell me what, if anything, you can remember
13 about the theory of the crime that you may have
14 developed over time.
15 A. Someone was in our home the night of
16 December 25th and murdered our daughter while we
17 slept.
18 Q. Is there anything more about that
19 theory that you remember or have developed?
20 A. Well, that is basically it. There
21 was someone who is not a member of our family in
22 our home that night, took JonBenet from her bed,
23 and murdered her.
24 Q. With respect to that theory of the
25 crime, is there anything else that you can

Page 26
1 remember about it?
2 MR. WOOD: What do you mean is there
3 anything else she can remember about it?
4 MR. HOFFMAN: Remember about that
5 night as far as it leading to developing that
6 theory.
7 MR. WOOD: I am going to have to --
8 that is a question that is either so vague or so
9 broad -- you are asking her now to say, is there
10 anything she can remember about that night that
11 would lead to her developing that theory?
12 Why don't you ask her a specific
13 question, Darnay. That is too broad and too
14 vague.
15 MR. HOFFMAN: All right.
16 Q. (By Mr. Hoffman) What is it about
17 the events of that evening and the next day that
18 has led you to this theory of the crime?
19 A. I found a ransom note. I found my
20 daughter missing from her bedroom. And several
21 hours later, our daughter was found dead in our
22 home. That is pretty clear to make one draw the
23 conclusion that someone came into our home and
24 murdered her.
25 Q. And you don't feel it was a member

Page 27
1 of your own family; is that correct?
2 A. No, sir.
3 MR. WOOD: I think your answer is
4 really "yes, sir." "Is that correct" would
5 require a "yes" response, so that the record is
6 clear.
7 Don't we agree, Darnay?
8 MR. HOFFMAN: Yes, that is fine.
9 THE WITNESS: It was not a member of
10 my family.
11 Q. (By Mr. Hoffman) I am going to take
12 just a short break because I am going to go into
13 another area. I just wanted to sort of generally
14 establish it. So let's take a one- or two-minute
15 break. I know people can't hop up or whatever.
16 MR. WOOD: We don't mind moving.
17 MR. HOFFMAN: No need to. Just a
18 natural break.
19 MR. WOOD: Off the video, too?
20 MR. HOFFMAN: Yes.
21 THE VIDEOGRAPHER: We are off the
22 video record at 9:39.
23 (A recess was taken.)
24 THE VIDEOGRAPHER: We are on the
25 video record at 9:49.

Page 28
1 MR. HOFFMAN: Mrs. Ramsey, Lin, I
2 want to proceed when you are ready.
3 MR. WOOD: Absolutely. Go right
4 ahead.
5 Q. (By Mr. Hoffman) Okay. Mrs. Ramsey,
6 I would like you to look at page 407 of the
7 paperback edition of your book, "the Death of
8 Innocence." I have highlighted a section I would
9 like you to read, which begins number 4 and then,
10 "The ransom note."
11 Could you read that, please, for the
12 record.
13 A. "4. The ransom note. Considered
14 earlier and throughout the book, the note was
15 written by the killer and remains an extremely
16 important clue. An adequate amount of handwriting
17 samples from the killer should conclusively tie
18 him to the long and rambling note."
19 Q. Mrs. Ramsey, do you still agree with
20 that statement?
21 A. I am not sure which statement.
22 Q. The statement you just read in your
23 book, do you still agree with it?
24 A. Well, it is my belief that whoever
25 wrote the ransom note probably had something to

Page 29
1 do with her murder. Is that what you are asking
2 me?
3 Q. Yes, I am. I just want to know --
4 I know this book was written a couple of years
5 ago, and I just want to determine whether it is
6 still your belief, that this statement is still
7 your belief, that you believe this statement to
8 be true today?
9 A. Yes, I believe that. Yes, I believe
10 that.
11 Q. Now I would like you to turn to page
12 145 of "the Death of Innocence," the paperback
13 edition of it, and I would like you to please
14 read out loud starting where it is highlighted "A
15 week and a half after the first of February."
16 If you could, read that, please.
17 A. "A week and a half after the first
18 of February, the Denver Post ran an interesting
19 observation on the handwritten ransom note that
20 Douglas had spoken about on Dateline. The paper
21 said: 'Leaving a handwritten document at the
22 scene of the crime, in most cases, is tantamount
23 to leaving one's calling card. Bradley and other
24 forensic document examiners say that it is nearly
25 impossible for a person to disguise handwriting so

Page 30
1 that an expert can't link a suspect to a
2 document, such as the note found in the Ramsey
3 home. The older a person is, the more automatic
4 and difficult it becomes to conceal the clues.
5 And the longer a document is, the harder it
6 becomes to disguise one's writing.'"
7 Q. Thank you. Do you agree with that
8 statement?
9 MR. WOOD: For clarification, does she
10 agree that that is what the Denver Post said, or
11 are you asking her --
12 MR. HOFFMAN: I am not asking her if
13 that is what the Denver Post said because they
14 are indicating in the book.
15 MR. WOOD: Right.
16 MR. HOFFMAN: I just want to know if
17 she agrees -- just because the statement is in
18 here doesn't necessarily mean she agrees with it.
19 Q. (By Mr. Hoffman) I would just like,
20 for clarification, do you agree with that
21 statement?
22 MR. WOOD: Or has any understanding
23 of who Bradley is, for example.
24 MR. HOFFMAN: I am not really
25 concerned whether she knows who Bradley is. I

Page 31
1 just want to know if she agrees with the
2 statement that "leaving a handwritten document at
3 the scene of the crime in most cases is
4 tantamount to leaving one's calling card." And
5 also, the --
6 MR. WOOD: Do them one at a time.
7 Q. (By Mr. Hoffman) Start with that.
8 Do you agree with that statement?
9 A. Well, I have been told that this is
10 the ransom note of ransom notes, the longest that
11 people have ever seen, and that it is a lot of
12 information for discovering someone's handwriting,
13 so I don't know if it "is tantamount to leaving
14 a calling card."
15 Q. I was wondering why you had put this
16 statement in this book, if you don't agree with
17 it?
18 A. I didn't say I didn't agree with it.
19 MR. WOOD: I am not sure that is her
20 statement. Again, going back, looking in context
21 to who writes this.
22 THE WITNESS: This was something that
23 was in the newspaper.
24 Q. (By Mr. Hoffman) I know, but it was
25 included in the book for some purpose, and I am

Page 32
1 assuming, reading it -- and I don't want to make
2 an assumption, but I can only assume reading it
3 that it is put here because you agree with the
4 basic premise of the article, or at least the
5 basic premise of the section that is excerpted
6 for this.
7 MR. WOOD: What is the question?
8 MR. HOFFMAN: I just want to know if
9 she agrees with the first sentence, "Leaving a
10 handwriting document at the scene of the crime in
11 most cases is tantamount to leaving one's calling
12 card."
13 Q. (By Mr. Hoffman) Do you agree with
14 that statement?
15 MR. WOOD: With all due respect, I
16 think she has given you an answer to that exact
17 question.
18 MR. HOFFMAN: I wasn't certain that
19 she had.
20 MR. WOOD: Let me make sure. I
21 don't want you to not get an answer.
22 MR. HOFFMAN: I mean, it would be
23 consistent with the earlier statement on page 407
24 about "an extremely important clue."
25 MR. WOOD: I thought she did answer

Page 33
1 that. She said: "I had been told that this is
2 the ransom note of ransom notes, the longest that
3 people have seen, that it is a lot of information
4 for discovering someone's handwriting, so I don't
5 know if it is tantamount to leaving a calling
6 card." I mean, that is what she said.
7 MR. HOFFMAN: Well, if she could say
8 yes or no, it would be very helpful.
9 MR. WOOD: That would be, but it
10 would only be if it were the only answer she
11 could give. I think she is entitled to give you
12 her full answer, including an explanation.
13 I think she told you she doesn't
14 disagree with it, but the use of the phrase
15 "leaving a calling card" she is not in the
16 position to comment on.
17 THE WITNESS: A calling card would
18 have been better because it would have had the
19 person's name, address, and phone number.
20 Q. (By Mr. Hoffman) I was curious as
21 to why this had been put in the book, if you
22 remember. Do you know why this statement was
23 included in the book, the one you just read,
24 "Leaving a handwritten document at the scene of a
25 crime"?

Page 34
1 A. Well, I don't remember exactly. It
2 has been a couple of years.
3 Q. If you remember.
4 A. Well, I don't remember exactly why we
5 put it in here. I believe this is a section
6 that John wrote, so you might want to ask him
7 that.
8 Q. Were you ever asked to give
9 handwriting exemplars at any time by anyone after
10 your daughter's death?
11 A. Yes, I was.
12 Q. Can you tell me who asked you to do
13 that, not violating any attorney-client privilege?
14 A. The Boulder Police Department.
15 Q. Did anyone else ask you to give
16 handwriting exemplars besides the Boulder Police
17 Department?
18 A. I gave several of them. I believe
19 it all had to do with the Boulder Police
20 Department. Whether it was the CBI or --
21 Q. But nobody other than law enforcement
22 asked you to give them handwriting exemplars; is
23 that true?
24 A. I don't remember anyone else asking
25 me.

Page 35
1 Q. I just want to clarify. Do you
2 remember how many times you were asked to give
3 handwriting exemplars by the law enforcement
4 people, authorities? And I am assuming it is in
5 Colorado.
6 A. Yes. I -- five or six, I think.
7 Something like that.
8 Q. In the back of the book, Appendix A,
9 page 428 -- actually, you can identify it as 429.
10 It doesn't have 428 in the upper left-hand
11 corner. It is called "A Chronicle of Cooperation."
12 The paragraph that is second from the bottom,
13 there is an indication when handwriting samples
14 were given by John, and there are dates, and then
15 Patsy, and there are dates, and then Burke, and
16 there are dates.
17 Would you just review that and see if
18 that refreshes your recollection with respect to
19 the dates? Are those dates accurate or
20 substantially accurate, if you can remember?
21 A. I am sure they probably are.
22 Q. And I am counting them. There is a
23 date "December 28, January 4, February 28, April
24 12, and May 20." That is one, two, three, four
25 -- it looks like five.
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