Patsy Depo: Part 3

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Patsy Depo: Part 3

Post by Mama2JML on Sun Jan 06, 2013 11:03 pm

Page 74
1 bottom portion looks more angular.
2 MR. WOOD: We have the same stip on
3 this?
4 MR. HOFFMAN: Same stipulations.
5 Q. (By Mr. Hoffman) Any other
6 observations of either similarities or
7 dissimilarities before I move on, Mrs. Ramsey?
8 A. No.
9 Q. I will ask you to look at the top
10 and final one, what I would identify as a D, but
11 that doesn't mean it is a D. I would like you
12 to look at that and tell me what similarities or
13 dissimilarities that you see there.
14 MR. HOFFMAN: And, Lin, of course, we
15 have the same stip.
16 MR. WOOD: Thank you.
17 THE WITNESS: The left one looks like
18 an A to me, and the right one looks like a D.
19 It looks like maybe a shaky or older person might
20 have written it. Kind of squiggly.
21 This one has a higher -- the one on
22 the right has a higher stick on the side than
23 the one on the left.
24 Q. (By Mr. Hoffman) Right.
25 A. And the open space, the doughnut hole

Page 75
1 is bigger on the one on the right than the left.
2 I don't think they look alike.
3 Q. Okay. Fair enough.
4 A. They look like two different letters
5 to me.
6 Q. Thank you for putting up with that
7 exercise.
8 MR. HOFFMAN: And, Mr. Wood, thank
9 you also.
10 Q. (By Mr. Hoffman) You remember earlier
11 I had you read about the handwriting from your
12 book. And I would say that maybe we both concede
13 that the handwriting is an important part of the
14 evidence in this crime.
15 MR. WOOD: She can speak for herself,
16 but we are not going to have her speaking for
17 you. Concessions are one thing. She has answered
18 your questions about that with respect to her
19 belief.
20 MR. HOFFMAN: I am just using that
21 foundationally to move on --
22 MR. LIN: That's okay. I wanted to
23 make sure.
24 MR. HOFFMAN: -- to move on so that
25 there is no question why I am moving into a

Page 76
1 particular area.
2 Q. (By Mr. Hoffman) It goes to the
3 issue of why Mr. Wolf is here in this lawsuit
4 with respect to some elements of it, why in the
5 complaint there is what may appear to you to be
6 an extremely unfair accusation or representation
7 of you as author of the ransom note, as the
8 person who killed her daughter, or whatever.
9 And a lot of this is to try and
10 determine the degree to which the handwriting
11 experts that Mr. Wolf is using in this case can
12 accurately determine whether you are, in fact, the
13 author of the ransom note or not, which is part
14 of why we have been doing this.
15 I just want to show you something
16 that is -- I just want you to look at it. It,
17 again, is why, so to speak, why --
18 I would like you to mark this as
19 Plaintiff's Exhibit 11. I am going to show this.
20 Now, I am not making any
21 representations in this document as to whether, in
22 fact, its submission means anything other than
23 this was prepared by two handwriting experts.
24 This document is not being submitted to prove the
25 truth of anything in the document.

Page 77
1 So if you could, mark that.
2 Lin, we will stipulate to that effect.
3 Would you mark this document, please,
4 as Plaintiff's Exhibit 11.
5 (Plaintiff's Exhibit-11 was marked for
6 identification.)
7 Q. (By Mr. Hoffman) Now, Mrs. Ramsey, I
8 am going to tell you that that document, along
9 with reports, handwriting reports, were prepared
10 by document examiners Cina Wong and David Leadman.
11 And other handwriting was prepared -- other
12 handwriting was used in the form of the police
13 exemplars that were given to my office by Mr.
14 Wood pursuant to discovery requests.
15 And those documents are, without a
16 doubt, your handwriting because they were
17 identified by Mr. Wood as being the handwriting
18 exemplars that you personally gave to law
19 enforcement in Colorado at their request during
20 that five-day period.
21 Now, the problem for Mr. Wolf in this
22 case is the fact that not one of the experts --
23 Cina Wong, David Leadman, an expert known as
24 Gideon Epstein, Larry F. Siegler, and an expert
25 known as Don Lacey have all identified you as the

Page 78
1 ransom note writer. It is not a close call, as
2 far as they are concerned. They have identified
3 you. One of them, in fact, said, without doubt
4 you are the author of the ransom note.
5 So in order to be certain that they
6 are, in fact, correct in what they are looking at
7 as examples of your handwriting, I wanted you to
8 look at some of the documents that I gave you.
9 Now I want you to look at the document there and
10 see why, in fact, this, the issue of your
11 authorship, is such a problem.
12 MR. WOOD: Do you have a question?
13 MR. HOFFMAN: Yes.
14 MR. WOOD: Let's ask the question.
15 Q. (By Mr. Hoffman) Okay. Mrs. Ramsey,
16 did you write the ransom note?
17 MR. WOOD: Before you answer that, I
18 want to object to the form of the question. And
19 I want to specifically object to each and every
20 one of the prefatory comments with respect to
21 that question which started off a long time ago,
22 where you said: "-- to move on, so there was no
23 question why I am moving into a particular area."
24 "By Mr. Hoffman: It goes to the
25 issue of why Mr. Wolf is here in this lawsuit"

Page 79
1 -- beginning at that point down through and
2 including everything except for your stipulation,
3 which we will accept.
4 I want to move to strike all of the
5 prefatory comments from that beginning down
6 through where you said and ended, "Now I want you
7 to look at the document there and see why, in
8 fact, this, the question of your authorship, I
9 believe, is a problem."
10 All of those are improper as to form.
11 I move to strike each and every one of them with
12 the exception of your stipulation. I also want
13 to tell you that I was very courteous in letting
14 you sit here and, in effect, lecture my client.
15 That is your one and only lecture, Mr. Hoffman.
16 You are here to ask questions.
17 Now, your question, as I understand
18 it, if you would like to restate it, is, Did
19 Patsy Ramsey write the ransom note. Is that the
20 question?
21 MR. HOFFMAN: Yes, it is.
22 MR. WOOD: Why don't you restate that
23 because I don't think the other question isn't
24 worth the paper it is written on or the time you
25 have taken up to ask it because it is totally

Page 80
1 improper as to its form.
2 Now, ask her a question.
3 MR. HOFFMAN: First of all, I am
4 going to respond to your ad hominem attack.
5 MR. WOOD: It is not an ad hominem
6 attack.
7 MR. HOFFMAN: It is an ad hominem
8 attack, and it is done for the purposes
9 grandstanding, which, you know, seems to be the
10 way you are operating, sir.
11 MR. LIN: Take that up with Judge
12 Carnes. Why don't you just ask your question.
13 MR. HOFFMAN: No. I am going to
14 respond to your ad hominem colloquy, which was,
15 in effect, an attack on me.
16 I was not lecturing Mrs. Ramsey.
17 And, Mrs. Ramsey, I apologize if I --
18 MR. WOOD: You don't have to respond
19 to that.
20 Do you have a question?
21 MR. HOFFMAN: No, Mr. Wood. I am
22 going to respond to your ad hominem attack, which
23 is what I consider it to be.
24 The fact is, I was not lecturing Mrs.
25 Ramsey. I was explaining to Mrs. Ramsey,

Page 81
1 prefatory to asking her a question which could be
2 regarded as very insensitive, which is simply, Did
3 you write the ransom note?, as to why I was
4 asking that question.
5 And, quite frankly, I don't think it
6 was improper of me to show a certain sensitivity
7 to a mother whose daughter has died rather
8 brutally.
9 MR. WOOD: Darnay, Darnay, you have
10 not shown this family any sensitivity since March
11 of 1997.
12 MR. HOFFMAN: That's not --
13 MR. WOOD: Let me stop you here.
14 MR. HOFFMAN: That's not before --
15 MR. WOOD: Let me stop you here.
16 No, sir. Let me stop you here.
17 I am not going to sit here and have
18 you go back and forth and talk with my client or
19 lecture my client. You are here under the
20 Federal Rules of Civil Procedure to ask questions.
21 I have the right to make an objection. If you
22 deem my objection to be an ad hominem attack,
23 take it up with Judge Carnes.
24 MR. HOFFMAN: Same here.
25 MR. WOOD: I believe my objection is

Page 82
1 100 percent good.
2 Now, ask your question, let's get
3 answers, and let's move on. We don't need the
4 back-and-forth every time I make an objection.
5 Okay. Please, let's get going.
6 MR. HOFFMAN: You are responsible, to
7 some degree, for the back-and-forth.
8 Quite frankly, under the Federal
9 Rules, I don't think you have the right to
10 interfere and try to control my deposition.
11 MR. WOOD: I have the right to make
12 an objection, I did make an objection, and I
13 asked you to state your question.
14 MR. HOFFMAN: But not an attack on
15 counsel, which is, in fact, what this was. This
16 was an ad hominem attack. You characterized what
17 I was doing with your client as lecturing her.
18 MR. WOOD: I think the record will
19 speak for itself.
20 MR. HOFFMAN: And also, I think you
21 spoke outside of anything that was going on here,
22 which was to conduct that you considered to be
23 improper on my part outside of this deposition.
24 MR. WOOD: I don't know what you are
25 talking about now.

Page 83
1 MR. HOFFMAN: You just made a
2 reference -- you can read it back -- to my lack
3 of sensitivity to the Ramsey family in general.
4 MR. WOOD: You are the one making
5 representations on the record about being
6 concerned.
7 MR. HOFFMAN: No. I am not making
8 representations. I am explaining.
9 MR. WOOD: You are wasting all of
10 our time now.
11 MR. HOFFMAN: No. This is my time.
12 MR. WOOD: Okay. If you want to
13 waste it.
14 MR. HOFFMAN: This is my deposition
15 time, and I am going to make a record responding
16 to your ad hominem attack on counsel.
17 MR. WOOD: Why don't you go ahead
18 and make that record.
19 MR. HOFFMAN: I just have been making
20 it. I have been making it.
21 MR. WOOD: When you are through, she
22 will come back and she will answer questions.
23 You don't have to sit here and listen
24 to this, Mrs. Ramsey.
25 MR. HOFFMAN: If she doesn't want to,

Page 84
1 that is fine.
2 MR. WOOD: You don't have to. You
3 can take a break, and you can go ahead and make
4 your response. And when you have a question, we
5 will bring her back in here, and we will answer
6 all your questions that are properly formed.
7 MR. HOFFMAN: All right. What we
8 will do is this, I am going to ask Mrs. Ramsey
9 a very simple question.
10 MR. WOOD: Thank you.
11 Q. (By Mr. Hoffman) Mrs. Ramsey, did
12 you write the ransom note that was discovered by
13 yourself on December 26, 1996, at your home?
14 A. No, sir, I did not.
15 MR. HOFFMAN: Okay. Thank you.
16 Now, at this point, I think we will
17 take a break. I think this would be an
18 appropriate time to take a break. Thank you.
19 THE VIDEOGRAPHER: We are off the
20 video record at 10:55.
21 (A recess was taken.)
22 MR. HOFFMAN: Just for the purposes
23 of taking up briefly before we left off, I
24 believe Mr. Wood made a motion to strike or will
25 do so with respect to that, and I just want to

Page 85
1 formally say that I would object and I do object
2 to any motion to strike any of the material he
3 referred to earlier. That is all. I simply want
4 to be on record as objecting to that. And that
5 is all.
6 THE VIDEOGRAPHER: Ready to go on the
7 video record?
8 MR. HOFFMAN: Oh, I want to put that
9 on the video record. Sorry.
10 THE VIDEOGRAPHER: We are on the
11 video record at 11:07.
12 MR. HOFFMAN: At this point, I would
13 like to move on to another topic area, but just
14 for the purposes of making a record, Mr. Wood
15 earlier in the deposition said that he was going
16 to object to or asked to strike statements that I
17 had made prefatory to a question that I asked
18 Mrs. Ramsey concerning the authorship of the
19 ransom note. And just for the record, I object
20 to any attempt to have that stricken from the
21 record. That is all I want to say with respect
22 to that.
23 Mr. Wood, if you want to add anything
24 to that.
25 MR. WOOD: Next question.

Page 86
1 Q. (By Mr. Hoffman) Now I am just
2 going to go into -- I am going to ask for some
3 clarification of things that are in the book,
4 things that I didn't understand.
5 I am going to turn your attention to
6 page 378. It is chapter -- in fact, I can let
7 you look at that. There are two statements
8 there. In fact, Mrs. Ramsey, if you will just
9 give me your book, I will just quickly highlight
10 it. I am sorry about not having done this
11 beforehand.
12 All right. I would like you to read
13 the highlighted portions on page 378 in your book
14 "the Death of Innocence." That is the paperback
15 edition.
16 A. "The Boulder grand jury said no to an
17 indictment."
18 Q. And then the next statement that I
19 highlighted.
20 A. "The grand jury's secret decision."
21 Q. Do you have any personal knowledge as
22 to whether or not the grand jury did, in fact,
23 make a decision based on that statement?
24 A. Well, the district attorney, I
25 believe, made a public statement that said there

Page 87
1 would not be an indictment.
2 Q. There is a reference here to the
3 grand jury's secret decision. Do you have any
4 knowledge of a secret decision by the grand jury,
5 any personal knowledge? Are you referring to
6 that?
7 A. Well, I think all of the grand jury
8 information is under wraps or under seal or
9 something.
10 Q. But do you know whether or not the
11 grand jury, in fact, made a decision in your
12 case?
13 A. Just going from what the district
14 attorney said, that there was no indictment.
15 Q. Okay. But this doesn't indicate --
16 the reason I am asking you this question is --
17 withdraw.
18 Is Patrick -- is it Patrick Furman,
19 was he an attorney of yours at one point?
20 A. Yes, he was.
21 Q. Were you aware that Mr. Furman made a
22 statement that was published in the Boulder papers
23 to the effect that there was a rumor that the
24 grand jury had taken a straw poll and had decided
25 not to indict?

Page 88
1 MR. WOOD: Object to the form of the
2 question in that I think you have inadvertently,
3 perhaps, made reference to the wrong lawyer; but
4 if you have a statement to show her, that might
5 be helpful.
6 MR. HOFFMAN: I don't have that
7 statement. I am just asking her if she has
8 heard that.
9 THE WITNESS: I am not aware of a
10 statement by Mr. Furman in the paper.
11 Q. (By Mr. Hoffman) Then I will ask
12 you, by any of your attorneys --
13 A. No, I am not.
14 Q. -- to the effect that the grand jury
15 -- that there was a rumor that the grand jury
16 had taken a secret straw poll and had decided or
17 voted not to indict?
18 MR. WOOD: You are talking about
19 public statements, not anything attorneys may have
20 said to her?
21 Q. (By Mr. Hoffman) No. No attorney.
22 I don't want you to reveal anything that is an
23 attorney/client.
24 A. No, I am not aware of any such
25 statement.

Page 89
1 Q. So the statement "The grand jury's
2 secret decision" is not referring to any personal
3 knowledge that you have about what went on in the
4 grand jury room with respect to any decision to
5 indict or not indict; is that correct?
6 A. I think that adjective was used just
7 referring to grand jury as a whole does
8 everything behind closed doors.
9 Q. So it is just a figure of speech; is
10 that correct?
11 A. Actually, I did not write this
12 section. John wrote this. So you might want to
13 ask him that question.
14 Q. Okay. Thank you.
15 Now, there is an incident in the book
16 on page 191 which you might remember. It is
17 fairly lengthy. I just want you to review it.
18 I am not asking you to read it. It involves
19 the alarm system that apparently failed when you
20 came home. I think you were in your home in
21 Charlevoix. Is that it?
22 It is the next-to-last paragraph on
23 191. If you could, just look at that to refresh
24 your memory generally.
25 A. Where it says, "John put in an alarm

Page 90
1 system"?
2 Q. System, yes.
3 MR. WOOD: And you can read anything
4 you need to to put that into context.
5 MR. HOFFMAN: Yeah.
6 THE WITNESS: Okay.
7 Q. (By Mr. Hoffman) Do you remember
8 that incident?
9 A. About putting the alarm system in?
10 Q. No. That incident where -- no.
11 Your feelings with respect to security and
12 whatever. It is not an incident.
13 I am going to refer to another part
14 of the book in a minute. Just simply your state
15 of mind in security systems.
16 A. I guess I am unclear about what you
17 are asking me.
18 Q. What I am going to ask you is this:
19 Do you know whether or not -- first of all, when
20 you were living in Boulder at the time of the
21 death of your daughter, did you have a security
22 system in your home?
23 A. Yes, we did.
24 Q. Was that a security system that you
25 used at the time you went out that night,

Page 91
1 December 25th, as you would explain it in your
2 book? When you went out visiting people, did you
3 have the security alarm on that night?
4 A. No, we did not.
5 Q. When you moved to Atlanta, did you
6 install a security system in your homes, any of
7 them?
8 A. Yes, we did.
9 Q. Did you have a security system in the
10 home that has been identified as the Atlanta --
11 not mansion, but that -- I don't have the
12 address. The house where John was assaulted in
13 May of, I think it was, 2001. Do you know if
14 there was a security alarm in that facility, that
15 home, in Atlanta?
16 A. There was. When we moved in, we
17 installed a very elaborate security system. And
18 subsequent to that, we had some extensive
19 remodeling done, and the security system was
20 dismantled and was subsequently reinstalled.
21 Q. Who was in charge of, in Boulder,
22 with turning the security system on or off? Was
23 that you or was that John, normally?
24 A. We normally did not use the security
25 system in Boulder.

Page 92
1 Q. Why was that?
2 A. Because we felt safe in Boulder.
3 Q. In Atlanta, I believe the security
4 system was not on when John was assaulted. Do
5 you know if that was true or not?
6 A. I don't believe that it was on.
7 Q. Do you know why it wasn't on?
8 A. I don't know why it wasn't on.
9 Q. Were you concerned that it hadn't been
10 left on?
11 MR. WOOD: You are assuming it was
12 not dismantled at that time?
13 MR. HOFFMAN: I actually ought to go
14 back to that, because you did mention
15 "dismantling."
16 MR. WOOD: I am trying to be lenient
17 with you. We have had a few back-and-forths,
18 Darnay, but I have a lot of trouble understanding
19 what this has to do with Chris Wolf and the
20 allegations in his claim or the defenses to this
21 case.
22 MR. HOFFMAN: Do you want me to
23 explain?
24 MR. WOOD: If you feel like you need
25 to, it might be helpful.

Page 93
1 MR. HOFFMAN: Fine. Oftentimes, a
2 jury or a trier of fact, as the case may be, is
3 allowed to consider something other than forensic
4 evidence in determining whether somebody is
5 involved in a crime or not, or just in any
6 event. And sometimes it is the demeanor of the
7 witness on the stand, whether a witness is, in
8 fact, telling the truth or not telling the truth,
9 or whether there are inconsistencies in the story
10 which are such that a jury would have a right to
11 draw what we call an inference; and from that
12 inference, what we call consciousness of guilt.
13 So the theory is that, if a person
14 is thought to be not telling the truth or just
15 simply the story is so implausible or inconsistent
16 that it indicates that there is a consciousness
17 of guilt, which a jury can use, at least in a
18 criminal case, to determine guilt or innocence, it
19 can be an element in it.
20 MR. WOOD: Talk to me.
21 MR. HOFFMAN: I hope I am stating
22 the law correctly. And that is one of the areas
23 I am going into in the deposition for the purpose
24 -- depositions, from what I understand, Lin, from
25 the federal rules, allow you to go into areas

Page 94
1 where you might be able to impeach a witness
2 later on. And so sometimes the questions don't
3 appear to be relevant except for the impeachment
4 purposes.
5 So that is one of the reasons why I
6 am going into this area.
7 MR. WOOD: Well, I am not going to
8 make a statement about whether I agree or
9 disagree with your statement of the law. It is
10 your right to make that statement. I understand
11 impeachment. I understand that it has to go to
12 a relevant and material issue.
13 I have grave doubts about whether an
14 incident in 2001 that occurred in the Ramseys'
15 home here where Mr. Ramsey was assaulted when he
16 got in and found someone that had broken in and
17 stolen a number of items from his home has
18 anything whatsoever to do, from a relevancy
19 standpoint or from an impeachment standpoint, with
20 the issues raised in Chris Wolf's libel lawsuit.
21 But I am going to let her answer the
22 question because I don't think it is -- you know,
23 it is one of those things we don't need to come
24 back and do later.
25 You can get the answer, but I just

Page 95
1 think that -- you know, just keep in mind that I
2 think you are pushing the envelope here, if not
3 going beyond it.
4 MR. HOFFMAN: For the purposes in
5 case you raise an objection, I will just simply
6 explain --
7 MR. WOOD: I will let her answer.
8 You do what you got to do.
9 MR. HOFFMAN: -- briefly why I am
10 doing this, and what it is about the security
11 system that I find intriguing in this case. And
12 it is the fact that there were concerns expressed
13 in the book about the security of the Ramsey
14 family and the fact that the Ramsey family felt
15 insecure.
16 And, naturally, one of the areas that
17 you would think would concern a family is the
18 fact that a night when their daughter had been
19 murdered, the security system had not been
20 working. And if there was any --
21 THE WITNESS: I believe in the
22 book --
23 MR. WOOD: No. Hold on.
24 This is where we don't need to go.
25 The security system was not turned on. And I

Page 96
1 think if you are familiar with the book, they
2 made it very clear why they didn't use it in
3 Boulder.
4 MR. HOFFMAN: Right.
5 MR. WOOD: The point is, you are
6 asking about an incident that occurred, you say,
7 in 2001 where Mr. Ramsey came home while his
8 house was under renovation with construction
9 workers there and found someone in his home
10 stealing items, and there was a physical
11 altercation. And you are asking about the
12 security system here in 2001.
13 And I am just simply letting you
14 know, Darnay, I am going to let her answer
15 questions about that, but I think you are over
16 the line on relevancy to the claims and defenses
17 in this case. But I am trying to be lenient
18 because I want you to have the opportunity to
19 push the envelope out, but I would just ask you
20 to keep in mind that we are stretching this, in
21 my view, and I would ask you to --
22 MR. HOFFMAN: I am trying to --
23 MR. WOOD: No explanations are needed.
24 Your theory of the case is not needed. Just ask
25 the question, and I am going to let her answer.

Page 97
1 MR. HOFFMAN: I am just trying to
2 enlarge the envelope so you see the envelope
3 isn't being stretched.
4 MR. WOOD: The envelope, to be
5 enlarged, is supposed to be under the rules by
6 you making a showing of good cause and getting a
7 court order.
8 MR. HOFFMAN: I am trying to do
9 that. I am trying to prevent you from having to
10 go in front of --
11 MR. WOOD: I am letting you ask it.
12 Just ask the question.
13 MR. HOFFMAN: Okay.
14 Q. (By Mr. Hoffman) Mrs. Ramsey, were
15 you at all concerned with the fact that your
16 husband was attacked in your Atlanta home -- I
17 don't know if you have one or two -- Atlanta
18 home, and the security system had not been turned
19 on?
20 MR. WOOD: I object to the form of
21 the question.
22 You may answer the question.
23 THE WITNESS: I was concerned when I
24 learned that my husband had been physically
25 attacked, yes.

Page 98
1 Q. (By Mr. Hoffman) Were you concerned
2 that the alarm system had not been turned on?
3 A. I did not know -- I was not at the
4 home when all this happened, so I didn't know
5 whether the alarm system was on or not.
6 Q. Do you know, were you told by anyone
7 if the alarm system was or wasn't on at the time
8 of Mr. Ramsey's assault?
9 A. I don't believe that it was on. You
10 would have to ask him that.
11 Q. But that is your belief; is that
12 correct?
13 A. Yes. It was midday.
14 Q. There was -- also I believe in your
15 book you described an incident where you came
16 back to your home in Charlevoix, and everyone was
17 waiting in front of the house. I think Mr.
18 Ramsey, in fact, describes this incident.
19 MR. WOOD: What page?
20 MR. HOFFMAN: I don't know if I
21 marked that. What I may have to do is go back
22 to this question after lunch, because I think
23 that this may be one page that I didn't mark,
24 and I will go back to it. I was just going to
25 ask her if she recalled that particular event

Page 99
1 without having to reference it to the book. If
2 she needs to --
3 THE WITNESS: Which event is that?
4 Q. (By Mr. Hoffman) In Charlevoix,
5 there, I believe, is an incident where you
6 recount where something happened to the alarm
7 system, and I believe you and your mother and
8 maybe other members of your family were waiting
9 nervously outside for the alarm system people to
10 arrive, and they didn't. And I believe John went
11 looking through the -- I believe it was the
12 Charlevoix home to see if there was an intruder.
13 And I was just curious as to how that alarm
14 system had failed, that security system.
15 A. I don't recall that part in the book.
16 Q. Well, after the lunch break, I just
17 may bring you back very briefly to ask you if
18 you have any memory of that by referring to it
19 in your book there.
20 A. Okay. Thank you.
21 Q. Did you ever at any time make a
22 statement to anyone, other than your attorneys,
23 that you had written the phrase "Mr. and Mrs.
24 Ramsey," which had appeared on one of the pads
25 that the police found in your home, and has been

Page 100
1 referred to as the so-called "practice ransom
2 note"?
3 MR. WOOD: Let me just, for the
4 record -- are you stipulating that you have
5 evidence that the phrase "Mr. and Mrs. Ramsey"
6 was written on what has been called a "practice
7 note"?
8 MR. HOFFMAN: No, I am not going to
9 stipulate to that.
10 MR. WOOD: I think, if you are going
11 to ask her about something, we ought to know
12 exactly what you are referring to, because I am
13 not sure that is correct at all.
14 MR. HOFFMAN: Fair enough. I didn't
15 want to have to bring it in in a long-winded
16 way.
17 In order to properly ask this
18 question, I am going to have to ask her a couple
19 of foundational questions.
20 MR. WOOD: Sure.
21 Q. (By Mr. Hoffman) Mrs. Ramsey, did it
22 ever come to your attention, through whatever
23 source that is not privileged, like
24 attorney-client privilege, that there may have
25 been what the police have identified as "a

Page 101
1 practice ransom note" being written?
2 A. Yes, I have heard of "a practice
3 ransom note."
4 Q. Now, can you tell me what it is that
5 you heard was on that practice ransom note?
6 A. I don't know that I ever heard
7 exactly what was on the practice ransom note.
8 Q. Did you at any time ever say to
9 anyone, say, Pam Griffin, or someone like that,
10 somebody you knew, that you, in fact, had written
11 whatever was on the practice ransom note?
12 A. No, sir.
13 Q. Now I am going to ask you to look at
14 your book here. And at page 210, it is right
15 by the photographs. Right down here, you will
16 see: "By now, anyone who knows John and me" --
17 just read the two sentences out loud.
18 A. "By now, anyone who knows John and me
19 will agree that, if there is anything we avoid,
20 it is the tabloids. When I pass the magazine
21 rack in the grocery store, I literally try to
22 look the other way."
23 Q. Is that an accurate statement of how
24 you feel?
25 A. Yes, it is.

Page 102
1 Q. Now I am going to ask the -- in
2 fact, let me make sure. That was from page 210
3 of "the Death of Innocence," the paperback
4 edition, that Mrs. Ramsey just read.
5 MR. HOFFMAN: I am going to have the
6 reporter please mark this as Plaintiff's Exhibit
7 12 for identification. And I am going to show
8 you this.
9 (Plaintiff's Exhibit-12 was marked for
10 identification.)
11 Q. (By Mr. Hoffman) Mrs. Ramsey, can
12 you identify Plaintiff's Exhibit 12?
13 A. It looks like a Xerox copy of Editor
14 & Publisher magazine.
15 Q. Can you tell me if you recognize the
16 people in the photograph?
17 A. I certainly do. Lin Wood, my husband
18 John, and myself.
19 Q. Do you remember sitting for that
20 photograph?
21 A. Yes, I do.
22 Q. Do you know why that photograph was
23 taken?
24 A. Yes, I do.
25 Q. Can you tell me why?

Page 103
1 A. For this publication.
2 Q. For the purposes of being on the
3 cover of the publication; is that correct?
4 A. I didn't know at the time it was
5 going to be on the cover, necessarily, but yes.
6 Q. Did you have any idea of what the
7 substance of the article in the publication would
8 be about?
9 A. I believed it to be an article about
10 Lin Wood.
11 Q. And did you have an opportunity to
12 read the article when it came out?
13 A. When it came out, yes, I did.
14 Q. Do you remember what the article was
15 about?
16 A. It was just about Mr. Wood's law
17 practice.
18 Q. And would you say that this article
19 is consistent with an attorney who challenges the
20 media for misrepresentation?
21 MR. WOOD: I have got to ask you,
22 Darnay, what does this have to do with anything
23 in turn --
24 MR. HOFFMAN: Oh, it does. A lot --
25 I will --

Page 104
1 MR. WOOD: Why don't you tell us
2 succinctly what this article has to do with Chris
3 Wolf's claims or the defenses to his claims in
4 this libel action.
5 MR. HOFFMAN: Okay. It has to do
6 with statements made in "the Death of Innocence,"
7 which I just had Mrs. Ramsey read.
8 MR. WOOD: We will answer questions
9 about that.
10 Q. (By Mr. Hoffman) Because the next
11 question is, given the fact that clearly you gave
12 your support to your attorney for the purposes of
13 this photo to appear on the cover of Editor &
14 Publisher --
15 MR. WOOD: Don't. I asked them if
16 they would have the photograph made because the
17 request was made to me.
18 Darnay, this is ridiculous. We don't
19 need to go into this. Ask her about "the Death
20 of Innocence." Is there a claim, Chris Wolf
21 claim that he was libeled by this article or
22 anything said in it?
23 MR. HOFFMAN: No.
24 MR. WOOD: Let's go to something else
25 that has relevance.

Page 105
1 MR. HOFFMAN: It goes to the issue
2 of one of the stated purposes in the book. You
3 have to understand, I have a right to know what
4 purposes were involved in this book.
5 MR. WOOD: Why Editor & Publisher
6 chose to write an article about my law practice
7 and my cases has nothing to do with the purposes
8 of John and Patsy Ramsey in writing the book "the
9 Death of Innocence."
10 MR. HOFFMAN: Okay.
11 MR. WOOD: So let's move on to
12 something that is relevant.
13 MR. HOFFMAN: I will try to connect
14 it up.
15 Please mark that Plaintiff's Exhibit
16 13 for identification.
17 (Plaintiff's Exhibit-13 was marked for
18 identification.)
19 Q. (By Mr. Hoffman) Now, Mrs. Ramsey, I
20 am going to ask you to look at what I have
21 marked as Plaintiff's Exhibit 13 for
22 identification and ask you if you recognize it.
23 A. No, I don't.
24 Q. I am going to ask you if at any time
25 you ever gave an interview with The National

Page 106
1 Enquirer.
2 A. We spoke with a representative from
3 The National Enquirer as part of some litigation
4 we were involved with for Burke.
5 Q. Did you ever agree to be interviewed
6 by The National Enquirer for publication?
7 MR. WOOD: Hold on. Tell me how
8 this is relevant to the libel claims of Chris
9 Wolf, whether John and Patsy Ramsey were
10 interviewed by The National Enquirer.
11 MR. HOFFMAN: Because I am going to
12 ask her about statements that were made in The
13 National Enquirer which relate to the murder and
14 the case. That is why I am asking her.
15 MR. WOOD: Ask her about the
16 statements.
17 MR. HOFFMAN: I am going to first
18 lay the foundation that, in fact, she --
19 MR. WOOD: I let you say she gave
20 the interview. Why she gave the interview is not
21 relevant.
22 MR. HOFFMAN: I want to ask her why.
23 MR. WOOD: I told you that is not
24 relevant to any claim.
25 MR. HOFFMAN: You can't make that
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