Patsy Depo: Part 4

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Patsy Depo: Part 4

Post by Mama2JML on Sun Jan 06, 2013 11:15 pm

20 MR. WOOD: Excuse me. In your
21 client's request for admission number 108, you set
22 forth, I thought, in verbatim quotations, Steve
23 Thomas' description or theory of the case and
24 asked my clients to admit or deny whether that
25 was an accurate statement of the passages from

Page 142
1 the book, which they admitted.
2 What I would say is we know they
3 have been forced to look at that by virtue of
4 responding to your request for admissions, even
5 though they didn't look at it in the book proper.
6 Why don't you just go ahead and ask
7 her specific questions, and let's leave Steve
8 Thomas' book to Steve Thomas' lawsuit because he
9 has enough to answer for that himself without her
10 answering for him.
11 MR. HOFFMAN: No. I understand.
12 All I wanted to do is just simply, because it is
13 one thing to simply say yes, you admit for the
14 purposes of request to admit that these statements
15 were made in the book.
16 MR. WOOD: Sure. She read it. She
17 has a general familiarity with it because you
18 included it in your request to admit. So I
19 would ask you to go ahead and ask her specific
20 questions. And, like I said, let's leave Steve
21 Thomas' book to his lawyers to worry about. As
22 I say, they have their hands full on that one.
23 We don't need to get into that today.
24 Why don't you ask her specific
25 questions about the murder of her daughter, the

Page 143
1 death of her daughter, factual questions about
2 what may or may not have been done, et cetera.
3 She will answer any question you have in that
4 regard.
5 MR. HOFFMAN: I had just basically
6 wanted her to review it before I asked her --
7 MR. WOOD: I don't believe it is
8 necessary because we are not going to test to the
9 truth or falsity of Mr. Thomas' book. We will
10 test her knowledge about factual issues related to
11 the death of her daughter. That is why I don't
12 want to put it in the context of Mr. Thomas'
13 book, which we, as you know, clearly contend to
14 be libelous.
15 MR. HOFFMAN: Okay. I am just going
16 to need a minute to make sure I go into relevant
17 areas rather than irrelevant areas.
18 MR. HOFFMAN: All right. What I am
19 going to do, rather than -- because I think most
20 of what he talks about is not factual. It is
21 more his subjective interpretation of evidence,
22 and I can't ask her whether his subjective
23 interpretation is true or false.
24 I am going to ask her if she read
25 the complete statement. And then ask her whether

Page 144
1 or not she, in fact, was involved in any way in
2 the murder of her daughter, as Steve Thomas --
3 because I think these statements speak for
4 themselves as far as his hypothesis.
5 She doesn't know how to test a
6 hypothesis. I am not really asking her to do
7 that.
8 MR. WOOD: The question of whether
9 Steve Thomas' statements or hypothesis are
10 factual, capable of being proven true or false,
11 is not an issue for us to debate today, and I
12 think you understand that.
13 MR. HOFFMAN: That's right. Yes.
14 MR. WOOD: She is not here to
15 test Steve Thomas' hypothesis or factual
16 representations --
17 MR. HOFFMAN: I agree with that.
18 MR. WOOD: -- whatever the case may
19 be. She is here to answer any question. And I
20 want to say this to you without any doubt in
21 your mind of what I am telling you, Darnay. She
22 is here to answer any question, any question that
23 you have that asks her about factual information
24 relevant to the death of her daughter.
25 So you have the opportunity today for

Page 145
1 however many hours you have left under the
2 federal rules to ask her anything about that.
3 She is prepared, ready, and willing and able to
4 answer any of those questions.
5 So that is what I would like you to
6 do. Let's go at it that way. You fire away,
7 and she will answer them.
8 Q. (By Mr. Hoffman) One of the most
9 controversial pieces of evidence is a red Boy
10 Scout knife or a whittling knife. I don't know
11 if it is a Swiss Army knife. Do you know
12 whether or not Burke owned a red knife at any
13 time?
14 A. He had a couple of them.
15 Q. He had more than one?
16 A. I believe so.
17 Q. Do you know if he had more than one
18 at one time?
19 A. Yes.
20 Q. So it wasn't like he owned one and
21 then lost it and then owned another one?
22 A. Oh, well, I don't know that exactly.
23 I guess he has had a couple of them in his
24 life. I don't know that.
25 Q. Do you know the whereabouts of that

Page 146
1 knife on Christmas day?
2 MR. WOOD: Which one?
3 MR. HOFFMAN: The red knife that I
4 was just referring to.
5 MR. WOOD: She said he had a couple.
6 Q. (By Mr. Hoffman) Do you know the
7 whereabouts of either one of those knifes?
8 A. No.
9 Q. There is apparently a kitchen knife
10 found.
11 MR. WOOD: Kitchen knife found where?
12 MR. HOFFMAN: Found at the scene of
13 the crime somewhere in the kitchen, or whatever.
14 MR. WOOD: That would be news to me.
15 MR. HOFFMAN: Okay. All right.
16 MR. WOOD: I don't know what you are
17 talking about. If you can, help me. If the
18 question is, Did you have kitchen knives --
19 MR. HOFFMAN: I know she has kitchen
20 knives.
21 MR. WOOD: But when you represent,
22 please, when you represent something as being
23 evidence, I just have to make sure that that is
24 just not --
25 MR. HOFFMAN: I am not saying any of

Page 147
1 this is evidence.
2 MR. WOOD: -- made up out of whole
3 cloth because the tabloids said it was evidence.
4 Most of that doesn't exist.
5 MR. HOFFMAN: I want to know what
6 she knows is and isn't.
7 Q. (By Mr. Hoffman) Let me ask you
8 this question. Are you a coffee or a tea
9 drinker, generally?
10 A. I drink both.
11 Q. In the mornings, when you prepare
12 yourself for the day, generally what do you have,
13 coffee or tea?
14 A. Usually coffee.
15 Q. Could you just describe what would be
16 a typical weekday for you when you get up in the
17 morning?
18 MR. WOOD: Now or back in 1996?
19 MR. HOFFMAN: I am sorry. In 1996.
20 Q. (By Mr. Hoffman) Just a typical
21 weekday morning. Who would normally get up first
22 in the morning?
23 Was John generally an early riser?
24 Did you get up beforehand, that sort of thing, go
25 down and make coffee?

Page 148
1 MR. WOOD: Are we talking about a
2 typical Monday through Friday where the kids are
3 in school?
4 MR. HOFFMAN: Right, nobody on
5 vacation.
6 MR. WOOD: John was going to work?
7 MR. HOFFMAN: Uh-huh (affirmative).
8 MR. WOOD: Can you do that, Patsy?
9 Do you understand what he is asking you?
10 Q. (By Mr. Hoffman) Can you describe
11 it?
12 A. Just in general, get up, get the kids
13 ready for school. He would go to work. I
14 would do things around the house or shopping or
15 school volunteer work and pick up the kids. And
16 that was about it.
17 Q. When you would get up in the morning,
18 would you just generally dress first and go down
19 and start preparing meals for the family, or
20 would you go down, prepare the meals first, and
21 then go get dressed?
22 A. It was probably no set pattern, but
23 usually I would dress first.
24 Q. I am sorry, you would dress?
25 A. I would usually get dressed.

Page 149
1 Q. Before you would go down to the
2 kitchen to prepare meals?
3 A. Yes. Usually. I can't say for
4 sure, but --
5 Q. But --
6 A. Usually.
7 Q. Your best recollection.
8 And then after you had dressed and
9 gone downstairs, normally what was the meal
10 preparation like for your family?
11 A. The kids would usually have cereal, I
12 think, before school. Oatmeal sometimes, fruit,
13 Pop Tarts, whatever was around.
14 Q. And you were generally dressed for the
15 day by that time; and when that was done, then I
16 just take it that you would just go about your
17 business for the rest of the day, whatever that
18 was?
19 A. Yes.
20 Q. Did you ever prepare meals in a more
21 informal way in the morning, like go down in
22 like, say, a black housecoat with something that
23 might have like rose color flowers on it, that
24 sort of thing? Ever prepare meals in the morning
25 informally?

Page 150
1 A. Oh, I probably -- I don't know about
2 the rose color robe you are talking about, but --
3 Q. The black robe with rose colors, or
4 anything like that.
5 MR. WOOD: Or anything like that?
6 MR. HOFFMAN: Or any type of clothing
7 like that.
8 MR. WOOD: What do you mean when you
9 say any clothing like --.
10 Like a black robe with red roses,
11 pink roses?
12 MR. HOFFMAN: Linda Hoffman-Pugh once
13 identified her as --
14 MR. WOOD: Why don't you just be
15 direct and ask her the question did she own such
16 a robe and had she ever worn it. Go right
17 ahead.
18 Q. (By Mr. Hoffman) Did you ever own a
19 black housecoat with pink roses on it, or a black
20 robe? I don't know if it was a housecoat or
21 how you would describe it. I don't know how
22 women identify these types of informal garments.
23 A. I can't remember. I know I have a
24 white one with pink roses.
25 I may have. I can't remember. I

Page 151
1 had a lot of robes.
2 Q. With respect to JonBenet, was
3 pineapple a favorite meal of hers?
4 A. She liked fruit, in general.
5 Q. No particular fruit?
6 A. Just most any fruit.
7 Q. And was that a preference for Burke
8 also, fruit, like his sister?
9 A. He liked it -- he likes fruit, but
10 not as much as she did.
11 Q. Do you know if JonBenet would play in
12 the basement area?
13 A. She did not play much in the
14 basement.
15 Q. Did she ever express an aversion to
16 playing in the basement area?
17 A. An aversion?
18 Q. Yes.
19 A. No.
20 Q. What was the basement area generally
21 used for in the house?
22 A. Burke had a train set up in one area
23 of the basement. There was -- and generally the
24 rest of it was for storage of seasonal
25 decorations, art supplies, school project supplies,

Page 152
1 that kind of thing.
2 Q. So if you didn't know what to do
3 with something in the house, you would just take
4 it down, have it sent down to the basement. Was
5 that the general storage area for things?
6 A. Largely, yes.
7 Q. Because Linda Hoffman-Pugh told me
8 that if you didn't know what to do with something
9 in the house, you would always say, Take it to
10 the basement; that was a favorite phrase of
11 yours?
12 MR. WOOD: Are you asking her whether
13 Linda Hoffman-Pugh told you that or --
14 MR. HOFFMAN: No. Whether that is,
15 in fact, a favorite phrase of hers.
16 MR. WOOD: Let me ask you so that
17 the record is clear, would you rephrase it so she
18 will know exactly what you are asking her.
19 Q. (By Mr. Hoffman) Was the phrase
20 "Take it to the basement" a favorite phrase of
21 yours if there was something in the house that
22 you didn't know what to do with?
23 A. I can't say what is a favorite phrase
24 or not. I am sure I don't know what that is.
25 Q. Frequently, the solution to any

Page 153
1 problem about where to take or store anything in
2 the house.
3 A. Probably so.
4 Q. With respect to the day in question,
5 whose decision was it to call the police when you
6 found the ransom note? Do you remember?
7 A. John and I, we just said, "What do
8 we do? Call the police." I don't know if it
9 was specifically one's decision or the other.
10 Q. Whose idea was it to call all the
11 people that eventually arrived, your friends, your
12 whatever, that came afterwards?
13 A. Oh, I did that.
14 Q. Can you tell me why you did that?
15 A. It just seemed instinctive. It was
16 just kind of a very stressful time, and I just
17 called on friends.
18 Q. Had you read the ransom note by
19 that time?
20 A. I don't think I had read all of
21 it, no.
22 Q. Were you aware that there was a part
23 in the ransom note where you were told not to
24 contact authorities?
25 A. I think I read that later.

Page 154
1 Q. Did you think that there might be
2 a chance that, if you called a group of people
3 over to the house and it was being observed,
4 that the kidnappers might, in fact, see that
5 you had disobeyed the condition of their ransom
6 note?
7 A. Well, that just didn't go through my
8 mind at that time.
9 Q. Were there any -- I am going to
10 withdraw that. I don't know if it is going to
11 be relevant.
12 What I am going to do, because I
13 don't think there is very much more about that
14 particular day that I really want to go into that
15 you haven't already given in the way of
16 statements that I have received. I just want to
17 clarify a few things.
18 Lin has been very forthcoming in
19 giving me discovery and whatever, so rather than
20 rehash all that, I just wanted to address a few
21 questions.
22 I am going to close the deposition by
23 asking you one question. It is just I feel I
24 am obligated to do it, and then we are going to
25 end the deposition unless there is something Lin

Page 155
1 wants to add. I am just going to ask you a
2 question.
3 Mrs. Ramsey, did you write the ransom
4 note that was found on December 26 at your
5 Boulder home?
6 A. I believe you have already asked me
7 that, and I said I did not write the ransom
8 note, no.
9 Q. I am just asking. Did you have
10 anything to do with the death of your daughter?
11 A. No, sir, I did not.
12 MR. HOFFMAN: Thank you. I am
13 finished.
14 MR. WOOD: For the record, I
15 mentioned to you, Darnay, during the break that I
16 think there has been, correct me if I am wrong,
17 one instruction on my part to Mrs. Ramsey not to
18 answer a question.
19 Am I right?
20 MR. HOFFMAN: Yes.
21 MR. WOOD: That question went to
22 making inquiry of her as to why she and her
23 husband granted an interview to The National
24 Enquirer.
25 Since the last thing I want to do is

Page 156
1 to fight a motion battle over that, and because I
2 have been consistent throughout in my
3 representation of the Ramseys, as I think they
4 have been even before I was involved in terms of
5 trying to answer every question, if you will
6 agree that we are not waiving any right to the
7 question of relevancy in allowing her to answer
8 that question, I am going to let her answer it,
9 and effectively withdraw with that understanding
10 my objection and instruction. Is that okay?
11 MR. HOFFMAN: That is fine.
12 MR. WOOD: So with that agreement, if
13 you would like to ask her; and if, Patsy, you
14 would answer the question for him, please.
15 MR. HOFFMAN: I am going to formally
16 ask it.
17 Q. (By Mr. Hoffman) Mrs. Ramsey, I
18 showed you a document that was identified as
19 Plaintiff's Exhibit 13. I am going to show that
20 document to you again. Could you identify what
21 it is that that document purports to be?
22 A. They are copies from a tabloid
23 article, National Enquirer tabloid article.
24 Q. Would you characterize the statements
25 that you made in this article as being statements

Page 157
1 that were made in the course of an interview,
2 formal interview with The National Enquirer?
3 A. It was an interview in conjunction
4 with some litigation for Burke that we were
5 involved with.
6 Q. If it was --
7 MR. HOFFMAN: See, this is why it is
8 a tricky area because for litigation, I don't
9 want to go into what the litigation was about,
10 and, naturally, if she gave it for the purposes
11 of the litigation, then she is required to by
12 law.
13 MR. WOOD: No, it was not given as a
14 requirement of the litigation as a matter of law.
15 MR. HOFFMAN: Oh, okay.
16 MR. WOOD: But I think what she is
17 saying is that the issue about the interview came
18 up in connection with actually the resolution of
19 some of Burke's claims.
20 MR. HOFFMAN: Because I don't want to
21 get into it if this is part of the settlement.
22 If that is really what she is going to say, that
23 she agreed to this interview because it was part
24 of a settlement agreement --
25 MR. WOOD: I don't think that is

Page 158
1 what she said.
2 THE WITNESS: I agreed to the
3 interview because, I mean, we are not afraid to
4 face even our most vile opponent, of which I
5 consider The National Enquirer to be one of the
6 most vile.
7 And, you know, we have faced Steve
8 Thomas. We have faced The National Enquirer. We
9 have nothing to hide. And I am facing you
10 today, Mr. Hoffman.
11 I did not kill my daughter, I did
12 not write the ransom note, and I don't know who
13 did either of those things. And I am not afraid
14 to answer any questions from either you or from
15 them or from the police department or from anyone
16 else, for that matter. And that is why the
17 interview was taken.
18 MR. HOFFMAN: Okay.
19 Q. (By Mr. Hoffman) The only reason I
20 had asked it was in relation to a statement that
21 was made in the book about how disapproving you
22 were of the tabloids, and --
23 A. And to this day I disapprove of the
24 tabloids.
25 Q. And also, I believe Mr. Ramsey once

Page 159
1 stated that it was his intention to see that, if
2 anything came out of this case, it would be a
3 change in the way in which the media reported
4 certain news.
5 And I was just wondering why, after
6 these strong statements of principle, that you
7 basically were willing to give a tabloid an
8 interview. That is all, my only reason for
9 asking that.
10 A. Because we wanted to prove that we
11 have nothing to hide and that we can sufficiently
12 face our most vile opponent.
13 MR. HOFFMAN: Okay. Thank you very
14 much.
15 Lin, I have no further questions.
16 MR. WOOD: One second.
17 So that we are clear, because you
18 have obviously done a good job of economically
19 handling the time, despite some of the colloquy
20 earlier in the day, it is clear on this record
21 that you are completing well within the maximum
22 seven hours allowed by --
23 MR. HOFFMAN: Yes.
24 MR. WOOD: -- the Federal Rules of
25 Civil Procedure. You understand we are willing

Page 160
1 to sit here for the remainder of the afternoon --
2 MR. HOFFMAN: I understand.
3 MR. WOOD: -- for however many hours
4 and answer any questions?
5 MR. HOFFMAN: Absolutely.
6 MR. WOOD: Now that we made our one
7 change of heart, you understand, Mr. Hoffman, that
8 we have answered every question, Patsy Ramsey has
9 answered any question you have put to her and
10 expressed a willingness to stay for several more
11 hours and answer any other questions; right?
12 MR. HOFFMAN: Well, I do know that I
13 would have to review the transcript. You made
14 certain objections over and above the objection
15 with respect to that, and there was an ongoing
16 colloquy between the two of us.
17 MR. WOOD: We have that transcript
18 available on this computer, and I want to make
19 sure, because you have come a long way from New
20 York, and there are a lot of lawyers that are
21 here today to make sure that Chris Wolf and his
22 attorneys have had every opportunity to ask any
23 question relevant to the claims or defenses in
24 this case.
25 And if you are representing that you

Page 161
1 have now done so to your satisfaction, then the
2 deposition is, in fact, complete.
3 MR. HOFFMAN: Again, it is subject
4 to --
5 MR. WOOD: If there is any --
6 MR. HOFFMAN: -- any review.
7 MR. WOOD: -- issue you want to look
8 at now, we don't mind taking a break, turn my
9 computer around, you can scroll through the entire
10 deposition, and if there is a question, she is
11 here. We can come back after the break, and you
12 can clarify it.
13 THE WITNESS: Let's do that to make
14 sure.
15 MR. WOOD: I would rather take the
16 time today to make sure that you are done and
17 not take any chance that we would have to come
18 back and put together this type of a force of
19 people.
20 MR. HOFFMAN: I really don't foresee
21 that there is any area.
22 MR. WOOD: That is all I wanted to
23 know.
24 MR. HOFFMAN: And, Mr. Wood, I wanted
25 to tell you that at lunchtime, in light of our

Page 162
1 earlier discussion, I felt that, given -- I had a
2 chance to review all of the, which was quite
3 substantial, the discovery documentation, and in
4 doing that, I realized that a lot of what I
5 would be asking had been an asked-and-answered
6 situation, and there was simply no reason to
7 subject Mrs. Ramsey to answer questions and
8 answers that she has already given on other
9 occasions.
10 MR. WOOD: In fact, you have been
11 provided with complete transcripts of the April
12 1997 police interviews, of the June 1998 police
13 and district attorney interviews, and of the
14 August 2000 police interviews; we have given those
15 to you.
16 MR. HOFFMAN: Yes, absolutely.
17 MR. WOOD: And I think you would
18 acknowledge, as she did today for you, she did in
19 every one of those, she answered every question;
20 didn't she?
21 MR. HOFFMAN: I believe she did, to
22 the best of her ability.
23 MR. WOOD: All right. Deposition
24 concluded. Thank you very much.
25 MR. HOFFMAN: Thank you, Mrs. Ramsey,

Page 163
1 for coming.
2 MR. WOOD: Let's go back on. Are we
3 back on?
4 One thing I do want to make clear,
5 because this has come up in other depositions, in
6 whole or in part, and I want to state it now so
7 that there is no doubt about it being something
8 that even has to take a moment's reflection.
9 Subject to the court reporter's need
10 to coordinate the videotape with the stenographic
11 transcript, the written transcript, which I
12 understand takes some time in order to ensure
13 complete accuracy, I want to state that, on
14 behalf of the Ramseys, this deposition shall not
15 be deemed confidential. No part of this
16 deposition will be deemed confidential.
17 My clients are perfectly willing for
18 this entire deposition, either in the written
19 stenographic form or in the videotape form, in
20 its entirety, to be made public. And we make
21 that statement unlike any other witness in this
22 case. Every other witness has claimed
23 confidentiality in whole or in part. We claim no
24 such confidentiality.
25 We are willing to let anyone that

Page 164
1 wants to see it in its entirety see it.
2 So with that statement, then we are
3 completed.
4 MR. HOFFMAN: With that statement,
5 that means that when the videotapes are -- do you
6 need to review the videotapes before?
7 MR. WOOD: No. I have made my
8 statement without the necessity of reflection or
9 review. The Ramseys are willing to allow this
10 deposition to be made public in its entirety.
11 The only delay, as I understand it,
12 in being able to do that is for the videographer
13 and the stenographer to review the transcript in
14 writing and the videotape to make sure that there
15 is a coordinated and accurate transcript.
16 Once that process is done, whoever
17 would like to see this deposition in video or to
18 read it in writing, the Ramseys make no claim to
19 confidentiality.
20 MR. HOFFMAN: Fine. Thank you. And
21 thank you once again, Mrs. Ramsey.
22 THE VIDEOGRAPHER: We are off the
23 video record at 1:45.
24 (Whereupon, the deposition was
25 concluded at 1:45 p.m.)

Page 165
1 INDEX OF EXHIBITS
2 EXHIBIT DESCRIPTION
3 1 Photograph
4 2 Photographs
5 3 Lights of December Parade Entry Form
6 4 Hawaiian Tropic International Official
7 Entry Form
8 5 Photocopy of inside of greeting card
9 6 Handwritten note on letterhead of Patricia
10 Paugh Ramsey
11 7 Document
12 8 Laser color copy of photograph
13 9 Laser color copy of photographs
14 10 Handwritten document containing letters
15 and various markings
16 11 Handwritten document containing letters
17 and various markings
18 12 Photocopy of Editor & Publisher magazine
19 cover of November 27, 2000
20 13 Photocopy of The National Enquirer article
21 (Original exhibits attached to the
22 original deposition.)
23.
24.
25.

Page 166
1 STATE OF GEORGIA:
2 COUNTY OF FULTON:
3 I hereby certify that the foregoing
4 transcript was reported, as stated in the
5 caption, and the questions and answers
6 thereto were reduced to typewriting under my
7 direction; that the foregoing pages represent
8 a true, complete, and correct transcript of
9 the evidence given upon said hearing, and I
10 further certify that I am not of kin or
11 counsel to the parties in the case; am not
12 in the employ of counsel for any of said
13 parties; nor am I in anywise interested in
14 the result of said case.
15 .
16 .
17 .
18 .
19 .
20 .
21 .
22 .
23 .
24 .
25 .

Page 167
1 Disclosure Pursuant to Article
2 8(B) of the Rules and Regulations of the
3 Board of Court Reporting of the Judicial
4 Council of Georgia, I make the following
5 disclosure:
6 I am a Georgia Certified Court
7 Reporter, here as a representative of
8 Alexander Gallo & Associates, Inc., to report
9 the foregoing matter. Alexander Gallo &
10 Associates, Inc., is not taking this
11 deposition under any contract that is
12 prohibited by O.C.G.A. 5-14-37 (a) and (b).
13 Alexander Gallo & Associates,
14 Inc., will be charging its usual and
15 customary rates for this transcript.
16 .
17 .
18 .
19 ALEXANDER J. GALLO, CCR-B-1332
20 .
21 .
22 .
23 .
24 .
25 .

Page 168
1 CAPTION
2 The Deposition of Patricia P. Ramsey,
3 taken in the matter, on the date, and at the
4 time and place set out on the title page
5 hereof.
6 It was requested that the deposition
7 be taken by the reporter and that same be
8 reduced to typewritten form.
9 It was agreed by and between counsel
10 and the parties that the Deponent will read
11 and sign the transcript of said deposition.
12 .
13 .
14 .
15 .
16 .
17 .
18 .
19 .
20 .
21 .
22 .
23 .
24 .
25 .

Page 169
1 .
2 CERTIFICATE
3 STATE OF :
4 COUNTY/CITY OF :
5 Before me, this day, personally
6 appeared, Patricia P. Ramsey, who, being duly
7 sworn, states that the foregoing transcript
8 of his/her Deposition, taken in the matter,
9 on the date, and at the time and place set
10 out on the title page hereof, constitutes a
11 true and accurate transcript of said
12 deposition.
13
14 Patricia P. Ramsey
15 .
16 SUBSCRIBED and SWORN to before me this
17 day of , 2001 in the
18 jurisdiction aforesaid.
19
20 My Commission Expires Notary Public
21 .
22 .
23 .
24 .
25 .

Page 170
1 DEPOSITION ERRATA SHEET
2 .
3 RE: Alexander Gallo & Associates
4 File No. 1637
5 Case Caption: Robert Christian Wolf vs.
6 John & Patricia Ramsey
7
8 Deponent: Patricia P. Ramsey
9 Deposition Date: December 11, 2001
10 .
11 To the Reporter:
12 I have read the entire transcript of my
13 Deposition taken in the captioned matter or
14 the same has been read to me. I request
15 that the following changes be entered upon
16 the record for the reasons indicated. I
17 have signed my name to the Errata Sheet and
18 the appropriate Certificate and authorize you
19 to attach both to the original transcript.
20 .
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11 DEPOSITION OF Patricia P. Ramsey
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8 SIGNATURE:_______________________DATE:___________
9 Patricia P. Ramsey
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