Patsy Depo: Part 3

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Patsy Depo: Part 3

Post by Mama2JML on Sun Jan 06, 2013 11:14 pm

Page 107
1 objection.
2 MR. WOOD: In the stipulation --
3 MR. HOFFMAN: You can direct her not
4 to answer. I want you to direct her not to
5 answer.
6 MR. WOOD: If you let me finish.
7 Why do you want me to do that? You mean you
8 came here with a plan to ask irrelevant
9 questions?
10 MR. HOFFMAN: No, not at all. Quite
11 simply because it is the proper form. I am
12 going to ask the question to Mrs. Ramsey and ask
13 her if she will answer it despite counsel's
14 objection.
15 MR. WOOD: Let's set the ground rules
16 right now. Mrs. Ramsey is going to follow the
17 instructions of her counsel, and you are not
18 going to ask her whether she will or will not.
19 MR. HOFFMAN: Oh, no, I will, and I
20 will tell you why, Mr. Wood.
21 MR. WOOD: You may --
22 MR. HOFFMAN: I will tell you why,
23 Mr. Wood.
24 MR. WOOD: You know, Darnay, you --
25 MR. HOFFMAN: I don't think you

Page 108
1 understand procedure.
2 MR. WOOD: I don't think you
3 understand courtesy. Down here in the south, we
4 don't interrupt people. You have interrupted me
5 repeatedly.
6 MR. HOFFMAN: You are using manners
7 as a ploy to avoid things.
8 MR. WOOD: Interruptions are
9 interruptions.
10 MR. HOFFMAN: You have interrupted me
11 many times.
12 MR. WOOD: Not repeatedly or
13 intentionally.
14 MR. HOFFMAN: If you want to go back
15 and count my interruptions of you, or Mr. Rawls
16 in Mr. Wolf's deposition --
17 MR. WOOD: You weren't even there
18 except by telephone.
19 MR. HOFFMAN: Yes. But the fact is
20 that no counsel interrupted you --
21 MR. WOOD: This man asked proper
22 questions. There was no need to have to go
23 through all this kind of back-and-forth.
24 MR. HOFFMAN: You are wrong. You
25 are out of order here, sir. You are out

Page 109
1 of order.
2 MR. WOOD: Darnay, Darnay, I am being
3 patient with you.
4 MR. HOFFMAN: No, no, no. I am
5 being patient with you.
6 This is my deposition. This is not
7 a forum for you to grandstand to look like a big
8 shot in front of your clients. That is not what
9 this is.
10 MR. WOOD: Darnay, Darnay, Darnay, I
11 am not going to sit here and listen to that.
12 You are not going to characterize what my efforts
13 are for my clients in a deposition as
14 grandstanding or otherwise. That is totally
15 inappropriate.
16 Look, I am trying to make an
17 objection, and, if necessary, an instruction which
18 at the beginning of this deposition we all agreed
19 was appropriate if you went outside of areas
20 relevant to the claims and defenses in the
21 lawsuit.
22 I happen to believe that, if the
23 question you are trying to get to is why did
24 John and Patsy Ramsey agree in the year 2000 or
25 2001 to an interview with The National Enquirer,

Page 110
1 that that is not relevant to the claims or
2 defenses in this libel lawsuit. That was the
3 question. I am going to instruct them not to
4 answer.
5 So why don't you just ask the
6 question and leave off all this back-and-forth,
7 and what I do think might be better to describe
8 now as somewhat of an ad hominem attack, which is
9 okay if you want to do it, but it is just a
10 waste of all of our time.
11 MR. HOFFMAN: Mr. Wood, just to
12 clarify one thing. I believe that, in the event
13 that the judge were to issue an order for Mrs.
14 Ramsey to compel her to answer certain questions,
15 that the record must reflect the fact that she
16 has refused to answer it, not that her counsel,
17 because the judge will not be ordering you to
18 answer it. They will be ordering Mrs. Ramsey.
19 And unless the court is clear that it is Mrs.
20 Ramsey who is refusing to answer the question and
21 not yourself, I have to make that as a record.
22 And that is the law, sir.
23 MR. WOOD: Darnay, please ask your
24 question, and then I am going to instruct my
25 client appropriately; and, if necessary, Judge

Page 111
1 Carnes will determine the law. Just ask the
2 question, for gosh sakes. Let's get going.
3 Q. (By Mr. Hoffman) Mrs. Ramsey, do you
4 know why you agreed to a National Enquirer
5 interview?
6 MR. WOOD: I instruct you not to
7 answer on the grounds that that issue is not
8 relevant to any claim or defense in this lawsuit.
9 Q. (By Mr. Hoffman) Mrs. Ramsey, will
10 you still answer the question?
11 MR. WOOD: I instruct you not to
12 respond to that question.
13 She will, in fact, follow her lawyer's
14 instructions just as any client should
15 appropriately follow her lawyer's instruction so
16 that she does not waive any right she has to
17 have Judge Carnes review this issue and rule
18 appropriately.
19 MR. HOFFMAN: Can I take that as a
20 no from your witness, that she will not --
21 MR. WOOD: You can take that exactly
22 for what it is, my statement on this record.
23 Next question, please.
24 Q. (By Mr. Hoffman) All right. Mrs.
25 Ramsey, I am looking at this interview; and,

Page 112
1 actually, since we have two interviews, what I
2 would like to do is give you an opportunity to
3 review this interview because I am going to ask
4 you questions about statements that you allegedly
5 made in the interview. And since we have only a
6 minute to go before we change, I think this would
7 be an appropriate time to break and give you an
8 opportunity to read the interview.
9 MR. WOOD: Whatever you would like to
10 do.
11 MR. HOFFMAN: Okay.
12 THE VIDEOGRAPHER: We are off the
13 video record at 11:35.
14 (A recess was taken.)
15 THE VIDEOGRAPHER: We are on the
16 video record at 11:43.
17 Q. (By Mr. Hoffman) Mrs. Ramsey, I have
18 shown you what has been marked Plaintiff's
19 Exhibit, I believe, No. 13. Has it been marked?
20 Yes. Plaintiff's Exhibit 13 for identification.
21 Have you had an opportunity to review the
22 document that I have handed you?
23 A. Yes, I have.
24 Q. I am now going to ask you again, do
25 you remember giving an interview for The National

Page 113
1 Enquirer?
2 A. I remember talking with them as part
3 of litigation we had with them concerning Burke.
4 Q. Now, I just want to ask you --
5 MR. HOFFMAN: Do we need to do that
6 again?
8 MR. HOFFMAN: Did you pick up the
9 answer?
10 THE VIDEOGRAPHER: I picked it up.
11 I picked it up.
12 Q. (By Mr. Hoffman) Just simply, I am
13 going to hand you another copy, and I've
14 highlighted just statements that The National
15 Enquirer claimed you made just simply for the
16 purposes of asking you whether or not you made
17 that statement. I am not going to go beyond
18 that. I just want to see if the Enquirer
19 quotes are, in fact, accurate where you are
20 quoted.
21 If you will, look at the bottom of
22 the first page. You will see they, quote, have
23 you say, "He has never -- we have never talked
24 about anything."
25 Is that an accurate quote?

Page 114
1 A. Who is the "he" they are talking
2 about?
3 Q. Burke. I will read the paragraph
4 before.
5 The Ramseys were asked whether Burke,
6 now 14, ever asked for details of JonBenet's
7 death. Quote, He has never -- we have never
8 talked about anything, said Patsy, who wore a
9 purple suit and a white blouse.
10 MR. WOOD: What is the question?
11 Q. (By Mr. Hoffman) The question is,
12 did you, in fact, say that, "He has never -- we
13 have never talked about anything"?
14 MR. LIN: In that context?
15 Q. (By Mr. Hoffman) Is this quote
16 accurate?
17 MR. WOOD: They may have spoken to
18 her in an interview and taken bits and pieces out
19 of context. I don't know --
20 Q. (By Mr. Hoffman) Is --
21 A. I don't remember whether I said that
22 in conjunction with having talked to Burke or
23 not.
24 Q. Substantively, is that accurate? Have
25 you ever talked to Burke about anything regarding

Page 115
1 the JonBenet murder as they have stated here? I
2 want to determine if that is accurate.
3 A. Yes, we talked about some things.
4 Q. So is the substance of that quote
5 accurate or inaccurate?
6 A. Well, I may have said that, but it
7 may not have been about talking to Burke or not.
8 I don't -- I would have to see -- they take
9 things out of context a lot.
10 Q. I just want to know what it is that
11 they are taking out of context here. So again,
12 I don't mean to belabor this. Did you or did
13 you not, in substance, say that you never talked
14 to Burke about anything to The National Enquirer?
15 A. I don't remember saying that.
16 Q. Now, turn to the next page, and you
17 will see highlighted on the right, "When children
18 are really tired and they don't go potty before
19 they go to bed, sometimes they have accidents."
20 One, do you remember making that
21 statement to the Enquirer?
22 A. That sounds like something I may have
23 said.
24 Q. Is it substantively correct then?
25 A. Yes, I believe so.

Page 116
1 Q. Thank you.
2 I draw your attention down a little
3 but further where, quote -- I am going to read
4 the paragraph just prior to your quote to put it
5 in context.
6 "Patsy, who is naturally right-handed,
7 was asked if she can write with her left hand."
8 "Can I write with my left hand," she
9 said, pondering the question. A smile crossed
10 her face, and she replied, "I can, but not very
11 well."
12 Did you make that statement to the
13 Enquirer?
14 A. It sounds like something I might have
15 said, yes.
16 Q. Is it substantively correct that you
17 can write with your left hand, though not very
18 well?
19 A. Well, I am not left-handed. If push
20 came to shove, I could probably write something
21 if I had broken my right arm, but I am not in
22 the manner of writing with my left hand all the
23 time, no.
24 Q. Have you ever told anybody at any
25 time that you were ambidextrous?

Page 117
1 A. No.
2 Q. That is all with respect to that.
3 Thank you.
4 Now, with respect to your book, I am
5 going to ask you to turn to page 283. In fact,
6 what I am going to do is I am going to exchange
7 this and just show you the highlighted portion
8 there. If you wouldn't mind, I would like you
9 to read it to yourself and then read it out
10 loud.
11 A. Okay.
12 Q. If you don't mind reading it out
13 loud.
14 A. "For the first time I learned that
15 someone had drawn a heart on JonBenet's hand.
16 Who had drawn that heart? The killer? JonBenet?
17 I doubted that my daughter had done so.
18 Certainly, as a younger child, she might have
19 drawn things on her hand, but at almost seven
20 years old, she was beyond that stage, in my
21 opinion. She cared about her appearance and was
22 not likely to have done so. And if she had,
23 she would have had to have drawn it with her
24 right hand. Which hand was the heart on? I
25 don't know the answer to that."

Page 118
1 Q. I am going to ask you whether that
2 was John or yourself making that statement in the
3 book. Is that information from John or from you?
4 Sometimes it becomes confusing as to one voice is
5 and another is leaving off. It is for the
6 purposes of asking --
7 MR. WOOD: Let me see if I can help
8 cut to the chase. This is talking about the
9 June 1998 interrogation or interview. Lou Smit
10 interviewed John. Did he ever interview you?
11 THE WITNESS: No. It looks like
12 maybe this was John's.
13 MR. WOOD: Looking at the next
14 paragraph, it talks about, Darnay, the other
15 people's picture was crossed out, but mine was
16 circled. I think that is John's picture, so I
17 think that probably answers it.
18 THE WITNESS: I think that is John.
19 Q. (By Mr. Hoffman) I am going to ask
20 you whether or not you know personally whether or
21 not JonBenet ever drew hearts on her hand or
22 hands at any time when she was a small child.
23 A. When she was much younger, she did,
24 but not in recent years, no.
25 Q. So would it be fair to say that you

Page 119
1 would be surprised if JonBenet had drawn a heart
2 in her hand the day before?
3 A. Yes.
4 Q. Do you know whether or not JonBenet
5 had either washed her hands or had either bathed
6 or showered prior to going to bed that night at
7 any time on December 25th?
8 A. I can't recall.
9 Q. If she had drawn a heart in her
10 hand, do you think you might have seen it
11 sometime during the day?
12 A. I may have. I don't remember seeing
13 a heart.
14 Q. Are you surprised that the autopsy
15 apparently indicates that there might have been a
16 heart drawn in her hands?
17 A. Yes.
18 Q. Did you ever at any time tell anybody
19 that you were in the habit or practice of drawing
20 hearts in JonBenet Ramsey's hand --
21 A. No.
22 Q. -- just as a sign of affection?
23 A. No.
24 Q. I am going to give this back to you,
25 and I will take that back.
Page 120
1 I would like to ask you, with respect
2 to the beauty pageants regarding JonBenet Ramsey,
3 were those pageants frequent or infrequent?
4 MR. WOOD: I am going to ask you to
5 tell me what beauty pageants that JonBenet
6 participated in have to do with this lawsuit. We
7 have responded to your request for production of
8 documents where you asked for, in number 21, "all
9 documents concerning JonBenet Ramsey's involvement
10 and participation in child beauty pageants," and
11 we have stated in our response that we object
12 because it was limitless in time and scope,
13 unreasonable, and seeks documents with no
14 relevance to the claims or defenses made in this
15 lawsuit as JonBenet Ramsey's participation in
16 beauty pageants is not at issue.
17 You have not made any attempt to
18 compel or respond to that or taken any issue with
19 our position. I don't believe that JonBenet
20 Ramsey's involvement in beauty pageants has
21 anything to do with Chris Wolf or any of the
22 claims that you make in your lawsuit.
23 MR. HOFFMAN: Are you objecting to
24 the question, then?
25 MR. WOOD: If you want to do one of

Page 121
1 your explanations of how JonBenet Ramsey's
2 participation in beauty pageants has anything to
3 do relevancy-wise, if you could point me to the
4 claim in your lawsuit or the defense that it is
5 relevant to, that would help. Just give me a
6 simple --
7 MR. HOFFMAN: It goes to the issue,
8 again, of consciousness of guilt, impeachment for
9 the purposes of witness testimony at trial. It
10 would basically give us an opportunity if there
11 is, in fact, contradictions in the answer. Basic
12 things that all trial lawyers are trying to do
13 when they are having depositions.
14 MR. WOOD: Hold on one second.
15 I am going to give you some leeway
16 on this issue in terms of questioning. Your
17 question as I understand it is now asking her
18 whether the pageants were frequent or infrequent.
19 We will do it on a question-by-question basis,
20 understanding that I think the relevancy here is
21 tenuous at best. But I am going to give you
22 the opportunity to go through it a little bit,
23 please.
24 Q. (By Mr. Hoffman) I simply want to
25 know whether or not, as her mother, you felt that

Page 122
1 the level of activity in beauty pageants was high
2 or low, in your mind?
3 A. Low.
4 Q. Did you keep a room in the house
5 known as the pageant room in your home in
6 Boulder?
7 A. No.
8 Q. Did you keep a room where you kept
9 all your trophies and all of JonBenet's pageant
10 trophies in your home in Boulder?
11 A. She had some in her room, some in
12 the play room and different places.
13 Q. I just have one other question. Did
14 you at any time tell anyone that JonBenet was
15 going to be the next Ms. America, or that she
16 was being groomed to be the next Ms. America?
17 A. Well, she could hardly be the next
18 Ms. America since she was only six years old.
19 Q. I understand. But at the time you
20 were taking her to the beauty pageants, did you
21 at any time say to anybody that you were grooming
22 JonBenet to be the next Ms. America?
23 A. I don't know. I may have said
24 something like that.
25 Q. If you don't know, fine.

Page 123
1 MR. HOFFMAN: How are we doing with
2 the time, gentleman?
3 MR. WOOD: A little before 12:00.
4 We can push on if you want.
5 MR. HOFFMAN: How much before 12:00
6 are we?
7 MR. WOOD: Just a few minutes.
8 MR. HOFFMAN: Why don't we break.
9 MR. WOOD: If that is what you want
10 to do.
11 MR. HOFFMAN: Is an hour adequate?
12 We are not going to run more than, tops, two
13 hours past the lunchtime, and it may not even be
14 that much.
15 MR. WOOD: So 3:00. Whatever. We
16 are here as long as you want us here.
17 MR. HOFFMAN: I understand. I am
18 just giving you a rough idea so that everybody
19 can be mentally out the door around that hour.
20 MR. WOOD: Is there any chance you
21 would like to go ahead and take John to see if
22 there is a chance you can finish him later today.
23 MR. HOFFMAN: I haven't finished my
24 preparation. I would like to start fresh in the
25 morning and just review the answers.

Page 124
1 MR. WOOD: I just want to make that
2 offer to you. Okay.
3 MR. HOFFMAN: Thank you very much.
4 It will be just a little bit longer than just a
5 couple of hours before the end of today.
6 MR. WOOD: Okay.
7 MR. HOFFMAN: And thank you very
8 much.
9 MR. WOOD: All right.
10 THE VIDEOGRAPHER: Off the video
11 record at 11:55.
12 (A recess was taken.)
13 THE VIDEOGRAPHER: We are on the
14 video record at 1:03.
15 Q. (By Mr. Hoffman) Mrs. Ramsey, I am
16 going to ask you if you can tell me who Chris
17 Wolf is. Do you know who Chris Wolf is?
18 A. Yes. He -- yes, I can tell you who
19 he is. He is a suspect in the murder of our
20 daughter.
21 Q. When you say "a suspect," how do you
22 know he is a suspect in the murder of your
23 daughter?
24 A. Well, I understand that the police had
25 him as a suspect early in 1997, and his

Page 125
1 girlfriend is, I believe, the way we came by his
2 name.
3 Q. Do you know why his girlfriend came
4 to your attention?
5 A. Yes. She called and said that she
6 believed that he was the murderer.
7 Q. Do you know who she called?
8 A. She called my parent's home.
9 Q. And do you --
10 A. I believe she had tried to call the
11 Boulder Police Department, but they had not
12 returned her calls.
13 Q. And do you know who it was that she
14 spoke to in your family with respect to --
15 A. I think initially she spoke with my
16 mother and then I believe my sister.
17 Q. Do you know the substance of what she
18 said to your mother?
19 A. Generally, she said that she was his
20 girlfriend. She -- he came home to her
21 residence. Apparently, they were living together.
22 He came home late in the middle of the night,
23 changed his clothes, and acted very strangely the
24 next morning when he saw the things were being
25 reported.

Page 126
1 Q. Now, did you just say earlier in your
2 answer that she had been attempting to contact
3 the Boulder police but had been unsuccessful, and,
4 therefore, was contacting your parents for that
5 reason?
6 MR. WOOD: I object to the form of
7 the question. It misstates the witness'
8 testimony.
9 MR. HOFFMAN: Can I have a read back
10 with respect to the answer?
11 MR. WOOD: I can tell you. "I
12 believe she had tried to call the Boulder Police
13 Department, but they had not returned her calls."
14 I don't think that means she had not ever spoken
15 with them or been unsuccessful.
16 MR. HOFFMAN: I see. I was about to
17 ask her if she could clarify whether she knew the
18 calls were being returned because they had never
19 spoken to her.
20 THE WITNESS: I don't know. I just
21 know that she apparently had made an attempt to
22 reach them.
23 Q. (By Mr. Hoffman) Do you know what
24 your parents did with the information that -- or
25 the person that spoke to her on the phone, your

Page 127
1 parents' phone, what they did with that
2 information? Did they call anybody?
3 A. Well, I think they told us about it.
4 Q. Do you know who they told? Not
5 revealing any attorney-client privilege.
6 A. Well, I don't -- somehow in the chain
7 of events, we found out about it, alerted our
8 investigators about it, and then I don't know
9 what happened after that.
10 Q. Do you remember when you first heard
11 about Chris Wolf as a potential murder suspect;
12 you personally?
13 A. I can't remember exactly, no.
14 Q. Was there any discussion when you
15 wrote your book, "the Death of Innocence," over
16 Chris Wolf being included in the book? Do you
17 know if you had any discussions about that, you,
18 yourself, with any of the people that were
19 writing the book with you?
20 A. Yes.
21 Q. Can you give me the substance of what
22 those discussions were?
23 A. I remember Janet Toma, the editor,
24 saying that she thought we should speak to a lot
25 of the untruths that had been imparted in other

Page 128
1 books or -- like, specifically, Steve Thomas'
2 book, and "The Perfect Murder, Perfect Town," or
3 something like that. That book.
4 And she said Chris Wolf had been
5 mentioned a lot in the media, and she felt like
6 we needed to speak to that as well as other
7 myths.
8 Q. Did you agree with that suggestion,
9 you personally?
10 A. Well, I remember -- I remember John
11 and I both saying that, you know, that -- we
12 kind of said, Well, are you sure we should really
13 go into all that detail? And she said,
14 Absolutely. She felt the readers wanted to know
15 any untruths that we knew of and could refute.
16 Q. What was the untruth in the issues
17 involving -- or the Chris Wolf's involvement in
18 the case that you were trying to clarify? What
19 was the untruth in reporting that Chris Wolf was
20 a suspect? What was your editor and what were you
21 trying to clarify by reporting that in your book?
22 A. Well, I don't know that that was an
23 untruth. I think she was just saying that he,
24 his name, had been brought up quite a number of
25 times, as had Bill McReynolds and Linda

Page 129
1 Hoffman-Pugh. Those were kind of the names being
2 bantered about in the media and other
3 publications, and she felt like we needed to
4 speak to those, talk about Fleet White, talk
5 about just names and incidents that were sort of
6 the no footprints in the snow, all those little
7 urban legends we called them.
8 Q. What was the urban legend about Chris
9 Wolf that you were trying to clarify?
10 MR. WOOD: I am going to object to
11 the form. I think you all may be missing each
12 other. I think she is talking about dealing with
13 myths and urban legends and addressing individuals
14 that had been talked about, and you are saying
15 that it is one in the same. That may be what
16 she is saying, but I don't think she means that.
17 If you are misunderstanding, maybe you
18 all can clarify what you are talking about,
19 Patsy.
20 MR. HOFFMAN: Okay.
21 THE WITNESS: Well, the editor said
22 that she felt like we should -- that anything
23 that had been already out there in the public,
24 that we should talk about anything that we knew
25 about that so that there wasn't -- I mean, Chris

Page 130
1 Wolf's name was not an urban legend. That was a
2 true statement, that he had been a suspect, you
3 know.
4 Q. (By Mr. Hoffman) Do you feel like
5 he was fairly a suspect?
6 A. Was he "fairly a suspect"?
7 Q. Yes. Do you feel it was fair that
8 he was a murder suspect or had been discussed as
9 one?
10 A. From what I know about his background,
11 yes, I do.
12 Q. Do you feel that, in the other media
13 that your editor was referring to, like "Perfect
14 Murder, Perfect Town," whatever, that there was
15 anything you needed to correct in the way of
16 misinformation?
17 A. I had never read that book, so I
18 don't know. I can't say that specifically. She
19 just said that his name had been mentioned, so we
20 just -- you know, she wanted us to address that.
21 Q. Were you ever given an opportunity to
22 look at any evidence that would implicate Chris
23 Wolf in this crime; you, personally, given any
24 evidence or an opportunity to look at any
25 evidence, without telling me what it was, did

Page 131
1 your investigators come to you and say, We have
2 evidence concerning Chris Wolf?
3 MR. WOOD: You are asking her now to
4 go into what would constitute attorney-client
5 privilege or work product privilege, I think.
6 Anything other than what you may have
7 learned from your attorneys' investigators or your
8 attorneys, he is entitled to know; otherwise, I
9 think he would agree it is privileged.
10 Q. (By Mr. Hoffman) I want to know if
11 you were ever shown any evidence, without
12 identifying who showed it. Just from the group
13 of people you are associated with in helping you
14 solve the crime, did anyone within your own group
15 show you evidence of Chris Wolf's involvement,
16 without identifying who the people were that
17 showed it to you? Just in a general way, did
18 you ever see a file involving -- about Chris
19 Wolf's involvement in the crime that may have
20 been prepared for you by somebody working for
21 you?
22 MR. WOOD: Or that might have been
23 prepared by someone working for her regardless of
24 who it was prepared for.
25 MR. HOFFMAN: Yes.

Page 132
1 MR. WOOD: Do you understand what he
2 is asking you?
3 THE WITNESS: Not quite.
4 Q. (By Mr. Hoffman) I have to tread a
5 fine line here.
6 A. You are saying the evidence --
7 Q. Did you ever see anything, any
8 writing --
9 A. I had seen some of his effects; is
10 that what you are saying? Yes, I have.
11 Q. Or anything that was purported to be
12 evidence pointing to Chris Wolf as a potential
13 murder suspect, have you ever actually physically
14 seen any of that yourself?
15 A. I have seen some of his personal
16 effects, yes.
17 Q. Were these personal effects meant to
18 show that he might, in fact, be a murder suspect
19 or be someone who could have killed your
20 daughter?
21 A. I believe so.
22 Q. I have one sort of quick question
23 here. Did your sister Pam ever tell you that she
24 knew who the killer of JonBenet Ramsey was?
25 A. No, she didn't.

Page 133
1 Q. Never made a statement like that to
2 you?
3 A. Not emphatically like that. She has
4 given me her opinion of who she thought might be
5 this or that.
6 Q. Did she tell you who, in her opinion,
7 she thought was the killer?
8 A. Yes.
9 Q. Can you name the person in question
10 or persons that she thought were the killer, was
11 or were the killers?
12 A. Could I?
13 Q. Yes.
14 A. Yes, I could.
15 Q. Would you?
16 A. Well, she has named several people.
17 Q. Could you just give me their names?
18 THE WITNESS: Is that appropriate?
19 MR. WOOD: Let me ask you, Darnay,
20 what possible relevance could it have? I don't
21 know if Chris Wolf is one of them or not. You
22 could ask that, I think, but what possible
23 relevance could it have to your claims to go into
24 the issue of who her sister says she believes
25 might be the killer?

Page 134
1 MR. HOFFMAN: Well, because her sister
2 actually made statements that got reported in the
3 media to the effect that she knew who the killer
4 was, in fact, had seen that person only recently,
5 and I was wondering whether or not she had ever
6 made that statement around Patsy, a statement like
7 that, and then identify --
8 MR. WOOD: Why don't you take her
9 deposition to find out what she was talking 10 about. I think that would be more appropriate.
11 MR. HOFFMAN: I will take that under
12 advisement. Thank you.
13 Q. (By Mr. Hoffman) Okay. Back to the
14 issue of Chris Wolf.
15 Do you know whose decision it was,
16 when your book "the Death of Innocence" was bound
17 in hard cover and ready to sort of be given to
18 the media, who decided to issue press releases to
19 the effect that the book would name murder
20 suspects, your group of murder suspects?
21 MR. WOOD: When you use the phrase
22 "would name murder suspects," are you equating
23 that with the book stating the identities of
24 individuals who had previously been identified as
25 murder suspects? Because I don't know of anyone

Page 135
1 who was, quote/unquote, named a murder suspect as
2 if that was the first mention of that person in
3 that book.
4 Do you understand the difference I am
5 asking?
6 MR. HOFFMAN: I understand.
7 MR. WOOD: Because I think it is a
8 fair question to clarify.
9 MR. HOFFMAN: Absolutely.
10 MR. WOOD: Thank you.
11 MR. HOFFMAN: I am going to try and
12 ask it. I may have to ask it in multiple parts
13 with a yes or no.
14 Q. (By Mr. Hoffman) When you were
15 preparing your book, did you think there might
16 come a time when the book was released that the
17 names of the people that were discussed as
18 possible murder suspects, either by yourself or by
19 law enforcement authorities, might actually become
20 public knowledge in the publication of this book?
21 A. Well, if their names are in the book,
22 it was going to be public knowledge.
23 Q. Do you know who made the decision to
24 advertise this book as naming -- well, actually,
25 I think the colloquial is, The Ramseys name their

Page 136
1 murder suspects.
2 MR. WOOD: Where is this?
3 MR. HOFFMAN: Not in here. It was
4 in media that was circulating around the time.
5 MR. WOOD: I don't think we can
6 speak to whatever media was circulating. The
7 bottom line is, Darnay, they identified people
8 that had already been identified as suspects, and
9 they discussed them.
10 Let me finish.
11 And you are trying to ask her about
12 some, perhaps, misinterpretation or some
13 interpretation circulating in the media that they
14 were for the first time going to identify
15 suspects. And I don't think it is fair to do
16 that unless you show her what you are talking
17 about, and then she can answer the question, and
18 then she will answer the question.
19 Q. (By Mr. Hoffman) Actually, really all
20 I want to know is who was responsible for
21 deciding how to promote this book in the media
22 when it came out. Do you know who the individual
23 was that made that decision?
24 A. I would say the people at Thomas
25 Nelson publishers.

Page 137
1 Q. Was there any specific person that you
2 know of personally that was going to be making
3 those decisions or did make those decisions on
4 how to promote the book?
5 A. It is a large company. They have a
6 marketing department. I don't know.
7 Q. So you were never introduced to
8 anybody in the marketing or promotional part of
9 Thomas Nelson who discussed the promotion of this
10 book with you, you, personally, that said, This
11 is what we are going to do or not going to do?
12 A. I don't remember having those specific
13 discussions, no.
14 Q. So you weren't actually asked for your
15 advice with respect to any of the marketing of
16 the book; there was no discussion between author
17 and the marketing or promotion part of it?
18 A. Not that I remember, no.
19 Q. Thank you.
20 Now, with respect to Steve Thomas --
21 MR. WOOD: Hold on.
22 (Deponent and her counsel confer.)
23 MR. WOOD: Let me ask you, Darnay,
24 because I don't think Patsy understood. When you
25 used the term "marketing and promotion," I

Page 138
1 interpret that as meaning you are including,
2 perhaps, discussing with them the interviews that
3 they were either considering or actually being --
4 or actually giving.
5 MR. HOFFMAN: Just an overall.
6 MR. WOOD: I don't think she got
7 that part because --
8 THE WITNESS: I was thinking like
9 advertising.
10 MR. WOOD: Like advertising in the
11 newspaper and things.
12 You may want to rephrase that again
13 including press interviews.
14 THE WITNESS: We had discussions about
15 where we were doing press interviews, but not
16 about print advertising or something like that.
17 Q. (By Mr. Hoffman) Then did there
18 really ever come a time when you were preparing
19 your book for publication that you had occasion
20 to talk at Thomas Nelson, or with anyone Thomas
21 Nelson might have hired to help in this area
22 involving media interviews such as print
23 interviews, radio interviews, television interviews,
24 anything like that? Were you brought into any
25 discussions involving that?

Page 139
1 A. Yes.
2 Q. Were you given approval, the right to
3 approve or disapprove of any of those interview
4 vehicles?
5 A. I think the final decision fell with
6 Thomas Nelson, probably.
7 Q. In your media interviews or whatever,
8 were you ever told that there were areas that you
9 could go into or not go into by anybody at
10 Thomas Nelson when you talked in your interviews?
11 A. No.
12 Q. So that if you chose in an interview
13 to name an individual or not name an individual
14 who appeared in this book and who may or may not
15 have been named as a source in other books, that
16 the discussion of that individual, you weren't
17 told not to talk about anybody that was named in
18 the book, meaning that no one said, Don't talk
19 about Chris Wolf in your interviews, or, Don't
20 talk about anybody that is a potential murder
21 suspect?
22 MR. WOOD: Object to the form of the
23 question as being multiple in nature.
24 MR. HOFFMAN: Okay.
25 THE WITNESS: Did they tell me?

Page 140
1 What are you asking me? Did they tell me what
2 to say or not to say?
3 Q. (By Mr. Hoffman) Did they say there
4 were areas you really shouldn't discuss --
5 A. No.
6 Q. -- in your media interviews?
7 So any decision to, say, discuss Chris
8 Wolf or Linda Hoffman-Pugh, or mention in your
9 interviews, that was a decision you made for
10 yourself in doing the interview?
11 A. During the interview?
12 Q. Yes, during the interview.
13 A. Yes.
14 Q. So no one coached you or encouraged
15 you to make statements like that; they were made
16 voluntarily by yourself?
17 A. In answer to an interviewer's
18 question, yes.
19 Q. That is all I wanted to establish.
20 Thank you.
21 Now, this may be one of the last
22 topic areas I go into today with respect to your
23 deposition. I am going to ask you if you are
24 familiar with Steve Thomas' book, "JonBenet"?
25 A. I know he wrote the book. I have

Page 141
1 not read it.
2 Q. And this may be a subject of
3 discussion for Lin and I. He may or may not
4 object to it. We will see.
5 Since you haven't read it, what I
6 wanted you to do was to have an opportunity to
7 read -- you can review it. You can take
8 whatever time you want to just simply read three
9 or four pages of his book where he, in effect,
10 outlines his theory of what happened that night.
11 Because then I would like to be able to ask you,
12 for the record, whether or not any of these
13 statements are true or false.
14 A. You can go ask me the questions. I
15 generally know his theories.
16 MR. WOOD: Let me say this to you,
17 Darnay. Are you referring to --
18 MR. HOFFMAN: In the paperback, it
19 is 318.

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