Chris Wolf

IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF GEORGIA
ATLANTA DIVISION
ROBERT CHRISTIAN WOLF,
Plaintiff,
CIVIL ACTION FILE
vs.
NO. 00-CIV-1187(JEC)
JOHN BENNETT RAMSEY and PATRICIA PAUGH RAMSEY,
Defendants.
~~~~~~~~~~~~~~~~~~~~~~~~
VIDEOTAPED DEPOSITION OF ROBERT CHRISTIAN WOLF


May 17, 2001
9:11 a.m.

Sixteenth Floor
191 Peachtree Street, N.E.
Atlanta, Georgia

Alexander J. Gallo, CCR-B-1332, CRR


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APPEARANCES OF COUNSEL
On behalf of the Plaintiff:
DARNAY HOFFMAN, Esq.
Law Offices of Darnay Hoffman
Suite 209
210 West 70th Street
New York, New York 10023
(212) 712-2766

EVAN M. ALTMAN, Esq.
Law Offices of Evan M. Altman
Suite 495
5901-C Peachtree Dunwoody Road
Atlanta, Georgia 30328
(770) 394-6466

On behalf of the Defendants:
JAMES C. RAWLS, Esq.
ERIC P. SCHROEDER, Esq.
S. DEREK BAUER, Esq.
Powell, Goldstein, Frazer & Murphy, L.L.P.
Sixteenth Floor
191 Peachtree Street, N.E.
Atlanta, Georgia 30303
(404) 572-6600

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APPEARANCES, Continued
L. LIN WOOD, Esq.
BRANDON HORNSBY, Esq.
MAHALEY C. PAULK, Esq.
L. Lin Wood, P.C.
2140 The Equitable Building
100 Peachtree Street
Atlanta, Georgia 30303
(404) 522-1713

Also Present:
Michael McElroy, Videographer


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Videotaped Deposition of Robert Christian Wolf
May 17, 2001

MR. RAWLS: This will be the deposition of the plaintiff Robert Christian Wolf in this lawsuit. It's taken by counsel for the defendants John and Patricia Ramsey. It is taken for all proper purposes in accordance with the Federal Rules of Civil Procedure and the Federal Rules of Evidence, including, without limitation, purposes of potential cross-examination, potential use in evidence, discovery, potential perpetuation of testimony, and all other appropriate purposes. All objections except as to the form of the answer or the responsiveness of -- excuse me -- form of the question or the responsiveness of the answer will be reserved until trial, hearing, or other use of the testimony. Is that suitable?

MR. ALTMAN: That is acceptable.

MR. RAWLS: Good. For the record, let me simply also establish that the deposition has been set up

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at a time and a place agreeable after which a notice of this deposition was submitted.

MR. ALTMAN: Correct.

MR. RAWLS: Good. And would you please administer the oath. THE VIDEOGRAPHER: Do you want this on the video record?

MR. RAWLS: Yes. THE VIDEOGRAPHER: We are on the video record at 9:11. ROBERT CHRISTIAN WOLF, having been first duly sworn, was examined and testified as follows: EXAMINATION BY-MR.RAWLS:

Q. Would you state your full name, please, sir.

A. Robert Christian Wolf.

Q. Mr. Wolf, are you here with Mr. Altman, one of your attorneys today?

A. Yes, sir.

Q. And is Mr. Darnay Hoffman, one of your other counsel, with us from New York by telephone today?

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A. Yes, sir.

MR. RAWLS: And, Mr. Hoffman, I assume you can still hear us?

MR. HOFFMAN: Yes, I can.

MR. RAWLS: Good.

Q. (By Mr. Rawls) Mr. Wolf, you are aware, are you not, that you have brought this lawsuit against John Ramsey, who is present, and his wife, Patricia Ramsey?

A. Yes, sir.

Q. And you are aware that the Ramseys are here represented by counsel as well today; are you not, sir?

A. Yes, sir.

Q. One of those attorneys is me. I'm Jim Rawls, and we met earlier today; did we not?

A. Yes, we did.

Q. One of those attorneys is Lin Wood, seated right beside me as well.

A. Yes, sir.

Q. Before today, have you ever met John Ramsey, who is seated immediately to Mr. Wood's right?

A. No, sir.

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Q. Do you recognize him from photographs that you have seen of him?

A. Yes, sir.

Q. And also in the room today are several other attorneys, some of whom work with me and some of them work with Mr. Wood, and may, from time to time, be in and out. It is not intended -- if they should be coming and going, it is not intended to be a distraction. Mr. Wolf, have you ever been a plaintiff in a lawsuit other than this one?

A. No, sir.

Q. Have you ever given testimony under oath before today?

A. Yes, sir.

Q. When was that, please?

A. I assume I have, having been in court for traffic tickets or -- I was in court when I was about 19, I think, for a traffic accident that I was a passenger in a car in, and I had to testify, and --

Q. Any other times?

A. As far as giving testimony, I know I raised my right hand and sworn to tell the

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truth other times. I'm trying to think of when.

Q. Take your time. I'm interested in knowing what you can recall.

A. I was in a civil case as a defendant about three years ago or so.

Q. Did you give testimony in that case?

A. Yes, I did.

Q. In court or in a deposition?

A. In court.

Q. Who sued you on that time?

A. Matthew Franzen.

Q. What was that case about?

A. About back rent.

Q. What was the outcome?

A. I was liable for money to him.

Q. Where was that case?

A. In Boulder, Colorado.

Q. How much was involved?

A. Well, it depends on what you mean by "involved."

Q. How much did you wind up having to pay?

A. I -- I think it was $500.

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Q. Apart from those two occasions, have you ever given testimony before under oath that you recall?

A. Not that I recall.

Q. In connection with the investigation into the death of JonBenét Ramsey, have you ever given testimony on any occasion?

A. Well, I've talked to a number of people on it. I don't think I've given testimony, per se. I've talked to prosecutors a number of times, but I don't think I was under oath.

Q. Do you recall giving a signed statement to any detective, police officer, prosecutor, district attorney, or anyone else in connection with the investigation into the murder of JonBenét Ramsey?

A. I gave non-testimonial evidence, including handwriting. I don't know that I signed anything.

Q. Do you remember today signing anything at the request of the police or district attorney or prosecutor or any other investigator?
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A. I don't remember signing anything; although, if I had signed something, I think I probably would have thought it incidental, and I might not remember it now.

Q. Mr. Wolf, where do you reside at this time?

A. In Kentucky.

Q. What's your address?

A. I'm living with relatives. I wonder if that's really necessary to -- relatives who aren't aware of this, my involvement in this situation.

Q. I would like for you to answer the question, please.

MR. ALTMAN: Answer the question.

THE WITNESS: Ah, Rural Route #, Box ***, Ewing, Kentucky, E-w-i-n-g.

Q. (By Mr. Rawls) And the zip code?

A. 41039, I believe.

Q. And with whom are you living at this time?

A. With my paternal grandparents.

Q. Their names?

A. ##########.

Q. How is that spelled?

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A. *************

Q. What is your date of birth, sir?

A. 10/28/59.

Q. Place of birth?

A. Cincinnati, Ohio.

Q. Your social security number?

A. **************.

Q. Your driver's license number?

A. I don't know.

Q. Do you have a driver's license?

A. Yes.

Q. Is it on your person?

A. Yes.

Q. Please check it.

A. Colorado, 922550063.

Q. What is its expiration date?

A. 10/28, this year.

Q. 2001?

A. Yes, sir.

Q. By whom are you currently employed?

A. DeWitt Photography.

Q. The address of that, please?

A. I don't know.

Q. What is your position with DeWitt

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Photography?

A. Photographer.

Q. To whom do you report?

A. David Brown.

Q. Where is the location or the town in which --

A. Lexington, Kentucky.

Q. Okay. How long have you been employed there?

A. Two months.

Q. Mr. Wolf, I want to discuss with you for a few moments who the plaintiff in this case, in fact, is. You go by Chris; am I correct?

A. Yes, sir.

Q. That was a yes?

A. Yes.

Q. And have you been known at any time by any other name than Chris Wolf or Robert Christian Wolf?

A. No.

Q. Have you ever used any other name?

A. I -- yes.

Q. What other name or names have you used?

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A. I don't have any particular aliases that I've used as an alias. I may have told somebody I had another name than my real name. So I don't recall.

Q. You answered "yes" to my question, Have you ever used another name. What names do you recall having used for yourself?

A. I don't recall.

Q. Tell me the names that you do recall that you have previously used for yourself.

A. I'm trying to explain to you that if I did, and I remember on occasions when I have told people that I had -- that my name was other than what it is, it was just on a moment's -- just for the sake of a particular situation or whatever, and I do not recall what those names may have been or what any other name I may have said was mine.

Q. So you recall none of the other names that from time to time you may have used to identify yourself?

A. That's right.

Q. Mr. Wolf, you are the only plaintiff in this case; are you not, sir?

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A. Yes, sir, I am.

Q. You're here today voluntarily?

A. Yes, sir.

Q. Is anyone other than you today providing any financial support to the pursuit of this case?

A. Yes, sir.

Q. Who were those people?

A. That would be Darnay.

Q. Okay. And apart from you and Darnay Hoffman, is any person providing any financial support to your pursuit of this case?

A. Not that I'm aware of.

Q. Is there any person other than you and one or both of your attorneys who has any financial interest in the outcome of this case?

A. No.

Q. Not to your knowledge?

A. Not to my knowledge.

Q. Have you furnished anyone with any understanding that anyone can have any benefit other than financial from this case such as through disclosure of information or testimony

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or videotapes or audiotapes or transcripts or documents?

A. I am sorry. Could you repeat that?

MR. RAWLS: Would you please read that back? (The record was read by the reporter.) THE WITNESS: Not to my knowledge or that I can recall. And if -- if something I said to someone may have been construed as such, it was -- I'm positive that I've never said anything specifically to anyone that would indicate that I was planning to, for whatever reason, give them money if I would win this case, or anything like that, if that makes sense.

Q. (By Mr. Rawls) Let me try to do better with my question because I'm not sure you have understood it. Have you told anyone you are going to give them information that comes out of this lawsuit?

A. I am trying to think in terms of this -- the murder investigation; and,

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certainly, I have not suggested or told anyone that I was going to give them information that comes out of this lawsuit.

Q. To the best of your knowledge, have any of your attorneys reached an understanding with anyone that anyone would be furnished any evidence, any testimony, or any information that comes out of this case?

A. To the best of my knowledge, no.

Q. Do you have any understanding that you're going to have some form of a book deal as a result of this case?

A. No.

Q. Or as a result of the investigation into the murder of JonBenét Ramsey?

A. I have no such understanding as that.

Q. Do you have any knowledge as to whether any of your attorneys has a book deal arising out of this case or arising out of the investigation into the murder of JonBenét Ramsey?

A. To the best of my knowledge, they do not.

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Q. Do you or, to your knowledge, either of your attorneys have any understanding about any docu-drama that is going to come out of this case or about the investigation into the murder of JonBenét Ramsey?

A. I'm sorry. Can you repeat the question?

MR. RAWLS: Please read that back. (The record was read by the reporter.) THE WITNESS: I don't know if that makes sense. Do we have any understanding as to any docu-drama? Any agreement or --

Q. (By Mr. Rawls) Any agreement or understanding reached with anybody outside yourself and your attorneys.

A. No. I do not.

Q. Do you have any plan to disclose your deposition testimony to any person after today?

A. No, sir, I do not.

Q. Does your attorney or either of your attorneys, to your knowledge?

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A. Not to my knowledge.

Q. Does any person have any understanding that he or she will be given a copy of the videotaped deposition of John Ramsey or Patsy Ramsey after those depositions are taken?

A. I am not aware of any such agreement as that.

Q. You're not aware that you have made such an agreement?

A. I certainly have not made any such agreement.

Q. And you're not aware if one of your attorneys has made such an agreement?

A. I'm not aware if one of my attorneys has. To my knowledge, they have not.

Q. Mr. Wolf, when did you first meet your New York attorney, Mr. Darnay Hoffman?

A. I guess it was just about a year ago, a little more than a year ago now.

MR. HOFFMAN: Jim?

MR. RAWLS: Yes.

MR. HOFFMAN: Jim, can I interject right now?

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MR. RAWLS: I'd prefer to keep the deposition involving questions and answers with the witness.

MR. HOFFMAN: No, I understand, Jim. But now that we are getting into attorney-client communications or interactions, we are moving into a potential privilege area. So, I mean, you know, I've let all those other questions go by the board as to what he understands, which is just another word for "Did your attorney tell you?" And this "understands" as sort of a surrogate for "tell you" is getting into an attorney/client privilege area.

MR. RAWLS: If I ask a question that's objectionable, I'm sure the attorney for the plaintiff who is handling this deposition will make the suitable objection, and he certainly has not yet. There is a rule that one attorney only is a spokesperson at each proceeding. Which attorney will that be for this witness?

MR. ALTMAN: Well, I will designate Mr. Hoffman, then, to be the case. That's fine.

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MR. RAWLS: All right. That makes a total of two. Is there an objection to the pending question?

MR. HOFFMAN: Yes, to any questions involving Mr. Wolf's relationship with his attorneys.

Q. (By Mr. Rawls) Mr. Wolf, did you complete your answer?

A. Yes.

Q. About a year ago, where was that meeting?

A. Aren't we back on that subject? I'm sorry.

Q. Mr. Wolf, unless the question is objected to --

A. Okay.

Q. -- it's your duty to answer. All right. Please do that.

A. I talked to Darnay on the telephone when I was in Boulder, and he was in New York.

Q. I'm sorry. My question was, when did you meet Mr. Hoffman?

A. Well, I was taking the term "meet" in a broad sense, meaning that's when I met

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him, when we talked on the telephone.

Q. When did you meet Mr. Hoffman in person? Let me clarify it, please.

A. I have not met him in person.

Q. Did I understand correctly that you have not ever met Mr. Darnay Hoffman in person, Mr. Wolf?

A. Yes, sir. You understood correctly. That's what I said.

Q. Mr. Hoffman's efforts to investigate your claims did not take place in person at any time before today? Am I correct?

A. That's correct.

Q. When did you first meet your Atlanta counsel, Evan Altman, who is here with you today?

A. This morning.

Q. Before the filing of your complaint in this action in May of the year 2000, and before your amendment of that complaint in this case in June of the year 2000, you had not personally met either of your attorneys; am I correct?

A. That's correct.

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Q. And today, as we sit here in your deposition in this case, after the filing of substantive motions in the case, today you have met for the first time one of your attorneys, Mr. Altman, here in Atlanta this morning. Am I correct?

A. That's correct.

Q. That was the first time?

A. That's correct.

Q. And Mr. Hoffman has joined us for this proceeding by telephone, much as he has conducted all of his business with you in the past; is that correct?

A. He has joined us by telephone.

Q. Mr. Wolf, how did it come about that a Colorado resident hired a New York attorney to handle an Atlanta lawsuit? If you could, just bring me up to date on that, please.

MR. HOFFMAN: Jim, I'm going to object. I don't see where this questioning is going. This is a privileged area. I'm going to object on privilege.

Q. (By Mr. Rawls) Please answer until you are instructed not to do so, Mr. Wolf.

MR. HOFFMAN: I'm going to instruct Mr. Wolf not to answer on the grounds of privilege. I'm going to claim the privilege for Mr. Wolf on his behalf.

Jameson wrote:I deleted the personal info about his grandparents to protect them from BORG harrassment. Chris Wolf's social security number has also been deleted from transcript.

Q. (By Mr. Rawls) Mr. Wolf, how did it happen that you saw the need for an attorney to represent you?
A. Well, I felt that I was deliberately and wantonly libeled by the publication of Mr. and Mrs. Ramsey's book. And I had sought legal counsel.

Q. Tell me about the process of your seeking legal counsel, please.

A. I called a couple of attorneys I knew in Boulder and asked them if they thought that I had a case.

Q. I don't want to know what you said to them and what they said to you, but I do want to know who those attorneys were.

MR. HOFFMAN: Jim, I'm going to object and direct my client not to answer that question on the grounds that it will violate the attorney-client privilege.

MR. RAWLS: There is something confidential about who he spoke to?

MR. HOFFMAN: No, what he said.

MR. RAWLS: I've asked a question, Mr. Hoffman, that obviously you did not hear. Let me restate it.

Q. (By Mr. Rawls) Mr. Wolf, I do not want to know what you said to those attorneys and what they said to you, but I do want to know who they are.

A. I think there is really only one that I discussed this particular aspect of this case.

Q. Who?

A. Linda Sue Smollen.

Q. Please spell that.

A. Linda Sue is --

Q. I can understand and spell Linda Sue. What's the last name, please?

A. S-m-o-l-l-e-n.

Q. What city is she located in?

A. In Boulder.

Q. When did you speak with her?

A. I think within a week or possibly, at the outside, two weeks after the publication of Mr. and Mrs. Ramsey's book.

Q. Did you read the book?

A. No. I skimmed it and looked for my name.

Q. Have you by today read the book?

A. No, sir. I have read all the parts that contain my name.

Q. At least you think you have, but having not read the entire book, you can't be sure of that; can you, sir?

A. I am trained as a reporter, and I've got a graduate degree in journalism, and I think I can skim a book proficiently enough to catch my name when it comes -- when it appears in print.

Q. You believe your accuracy was 100 percent?

A. I believe it was close.

Q. Mr. Wolf, who are your parents, please, sir?

A. ######### and ####### Wolf.

Q. Where do they reside?

A. In Savannah, Georgia.

Q. Can you give us their address, please?

A. ##########, Savannah,

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Georgia. And I do not recall the zip code.

Q. How long, approximately, have they resided there?

A. Maybe close to ten years. Maybe eight.

Q. Does ####### Wolf have a career or occupation?

A. He's retired.

Q. And did he -- well, from what did he retire?

A. He was a manager of a folding carton factories.

Q. For what employer?

A. A number of different ones.

Q. And does #########Wolf have an occupation or a career?

A. She's had a few different jobs, but generally has been a housewife.

Q. Are they your natural parents?

A. They're my adoptive parents.

Q. And do you know when you were adopted and at what age?

A. November 11th, 1959, at less than two weeks old.

Q. Do you know your natural parents?

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A. I know my biological mother.

Q. Who is that?

A. That's ##########.

Q. Where is she?

A. In #########, Kentucky.

Q. Do you have a relationship with her? Do you speak with her or see her?

A. Yes, sir.

Q. And you had told us earlier that the grandparents with whom you reside now are your paternal grandparents?

A. Yes, sir.

Q. Is that paternal grandparents biologically or adoptive?

A. Biologically.

Q. So they are the parents of your biological father?

A. Yes, sir.

Q. Whom you do not know?

A. That's right.

Q. And what was his name?

A. ######### V.

Q. Is ########### V living?

A. No, sir. He's dead.

Q. And when did he die, if you know?

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A. He died in January 1960.

Q. At a time when, in your life, you were too young to know him?

A. Well, I was already given away for adoption at the time that he died.

Q. Are your adoptive parents related to either of your natural parents?

A. No, sir.

Q. Okay. Where did ############### Wolf raise you?

A. First few years of my life in Cincinnati, and then we moved to Baltimore. And then -- you want the whole chronologic order of where I lived?

Q. Yes, please.

A. Then we moved to Iowa when I was in fifth grade. Then we moved back to Baltimore. When I was in -- starting seventh grade. Then we moved to Chicago when I was starting my junior year in high school. Then we moved back to Baltimore when I was 20? No. 19. 19.

Q. Where did you graduate from high school?

A. ############, Illinois.

Q. In what year?

A. In 1977.

Q. And you went on to college, did you not, sir?

A. Yes, sir.

Q. Where?

A. #######State University, #########, Maryland.

Q. Did you receive any degree from ######## State?

A. Yes, sir.

Q. What degree?

A. A Bachelor's degree.

Q. What year?

A. '83.

Q. In what course of study?

A. Political science.

Q. And did you take any journalism courses at ######### State?

A. No, sir.

Q. Did you go on to graduate school thereafter?

A. Not immediately. I started graduate school in, I guess, 1990.

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Q. Where?

A. At the University of Colorado.

Q. In what field of study?

A. In journalism.

Q. And did you receive a degree?

A. Yes, sir. A Master's degree in journalism.

Q. Your high school graduation was six years before your Bachelor's degree at ######### State. Did you go to college four years or longer than four years at ######## State?

A. I think I had a semester more than the 16, I guess it would be, that would be required. Is that right? Or eight. It would be eight that would be required. I had an extra semester and time off.

Q. So when did you take time off out of school?

A. I guess -- I think I had two semesters in a row off.

Q. When?

A. 1981.

Q. What did you do during those two semesters that you took off in about 1981?

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A. Worked and traveled.

Q. What kind of work?

A. I was a bellman at a Marriott Hotel.

Q. Where?

A. In ##########, Maryland.

Q. Any other work during those two semesters?

A. No, sir.

Q. Where did you travel?

A. To Colorado and Wyoming.

Q. Anywhere else?

A. Just in the -- en route.

Q. As a result of which you decided to go back to ########### State?

A. Yeah.

Q. Mr. Wolf, do you have any natural brothers or sisters?

A. A half brother and a half sister. I always planned to go back to school. I didn't decide on travel.

Q. And who is your half brother?

A. ########### C.

Q. Where is he?

A. Louisville.

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Q. And who is your half sister?

A. ########## C.

Q. And are they your brother and sister by virtue of your natural mother?

A. Yes.

Q. Are you close to them?

A. No, I wouldn't say that. I've only met my brother once, and -- maybe twice over Christmas. And ########, probably a couple of other times more than that, but I just met them for the first time in my life in January.

Q. January of this year, 2001?

A. Yes, sir.

Q. Where is ####### C?

A. In Lexington.

Q. Do you have any adoptive brothers or sisters?

A. Yes, I do.

Q. Who are they, please?

A. #### Wolf is my brother, and ###### Wolf is my sister.

Q. Are you close to them?

A. Not my brother. And my sister, more so.

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Q. You say "more so." Do you feel close to your sister ######## Wolf or not?

A. Yes, I do.

Q. Where does ###### Wolf reside now?

A. In #######, Maryland.

Q. What is his job or occupation, if he has one?

A. I couldn't explain to you. I'm not sure. He does some sort of, kind of middleman processing of financial electronic fund transfers, or something like that.

Q. Do you know his address?

A. No.

Q. Where does ######## Wolf reside now?

A. ########, Virginia.

Q. When did you last see ####### Wolf?

A. Well, I guess it has been a couple of years.

Q. When did you last talk to her?

A. A month ago.

Q. Do you speak to her regularly?

A. Periodically.

Q. Other than ######## Wolf and ####### Wolf, do you have any other adoptive brother or sister?

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A. No, sir.

Q. Are you close to your adoptive parents?

A. Yes, sir.

Q. When did you last see them?

A. In either February or March.

Q. Of this year, 2001?

A. Yes.

Q. Did you see them here in Georgia?

A. Yes.

Q. Mr. Wolf, who is your best friend?
A. I think it is kind of hard to say, lately. I wouldn't want to single any particular person out for that designation.

Q. Well, why don't you tell us about your two, three, or four closest friends.

A. I have a number of good friends in Boulder who I worked with at one of the newspapers I worked at. And a few other friends who I have lived with at different times. And that's probably about it. That sums it up.

Q. And who are the good friends in Boulder with whom you have worked at a newspaper?

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A. Michael Sanderock, Jay Gluckstern, Chrissie Smiley, Kiki Bomer, K-i-k-i, B-o-m-e-r, I believe. Alex Stein.

Q. Any other good friends in Boulder with whom you had worked at a particular newspaper?

A. I would say many other acquaintances, but probably those would be the ones that I would call good friends.

Q. Which newspaper did you work with with the people you have just named?

A. The Colorado Daily.

Q. How long did you work there?

A. Four years.

Q. And what years were they?

A. '90 to '94.

Q. When is the last time that you saw Michael Sanderock?

A. Just before I moved out here in December.

Q. December of 2000?

A. 2000.

Q. Jay Gluckstern?

A. Same.

Q. Chrissie Smiley?

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A. Same.

Q. Kiki Bomer?

A. Same.

Q. Alex Stein?

A. Same.

Q. Was this at a party or something in December?

A. No. I saw -- I saw most of them pretty frequently.

Q. Have you corresponded with them since leaving Boulder?

A. I've talked to a couple of them on the phone.

Q. Have you exchanged e-mails with them?

A. No.

Q. Which ones have you spoken to by telephone?

A. Jay Gluckstern and Alex Stein.

Q. Do the five people that you have named know about your lawsuit?

A. Yes, sir.

Q. You told me earlier that there were a few other friends of yours with whom you have lived at different times.
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A. Uh-huh (affirmative).

Q. Who were they, please?

A. Matthew F########. I guess that's mainly that list of those people I generally -- let's see. That is probably all.

Q. So when you said earlier a few others with whom you have lived at different times, really only one other, Mr. F#########, that you consider a relatively close friend?

A. Well, there are a couple others, but -- there were a couple others.

Q. Are you choosing not to tell me the couple of others, or will you tell me their names, please, sir?

A. Well, let's see. P W. I can't remember the -- I can't -- the other guy we called by a nickname, and he had a first name that I knew and a last name that I didn't.

Q. What was the nickname?

A. Shakespeare.

Q. What was the first name?

A. J.

Q. Who knows him well?

A. P.

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Q. Where is P located?

A. He moved, and I wasn't sure if he was going to Beaumont Texas; Austin, Texas; or New York City.

Q. When's the last time you were in touch with P?

A. The time he moved, which was September or October of 2000.

Q. Mr. Wolf, have you ever been married?

A. No, sir.

Q. Have you ever resided in Georgia?

A. No, sir.

Q. Except, perhaps, spending a few nights here to visit your adoptive parents in Savannah?

A. Yes.

Q. Of the people that you have named just now -- Michael Sanderock, Jay Gluckstern, Chrissie Smiley, Kiki Bomer, Alex Stein, Matthew F, P W, and Shakespeare, J, with an unknown last name -- which of those people is familiar with your own personal arrest record, sir, if anyone?

Page 39

A. Well, I couldn't say for sure, seeing as how it was made public on the Today Show recently. So whoever may have been watching. Other than that, I would say none.

Q. So with that particular list of people, you had never disclosed any of your personal arrests?

A. Arrests?

Q. Yes, sir.

A. I had, if we're talking about the time I was arrested, yes, I had disclosed details of one of the times I was arrested, or maybe two.

Q. Which arrest details did you disclose to one or all of the people we've named in the last few moments here?

A. I'm sorry. Could you repeat the question?

Q. Sure.

MR. RAWLS: Read that back, please. (The record was read by the reporter.) THE WITNESS: I think I told -- I may have told some of those people about

Page 40

being arrested for nothing at one time by the Boulder Police Department because I set off an alarm at the University of Colorado library with a book that I had just checked out. And I think I may have told some of those people about being arrested for drunken something or another, disorderly, or whatever they may have called that, which I really never even -- I don't even know that I was arrested, to tell you the truth, because I never went to court. It was about -- I think they just wanted to put me in the tank for the night, which is what they did. And then I left the next day without any paper or anything. And that was -- that was, I think, about 1983 or something.

Q. (By Mr. Rawls) Any other --

A. So I don't think that that was -- I don't think I was arrested, no.

Q. Are there any other arrests of yourself that you disclosed to any of those eight different people?

A. No.

Q. Your arrest for public indecency

Page 41

you did not disclose to any of those people?

A. Not to any of those people.

Q. To whom did you disclose that arrest?

A. I believe I told Jackie Dilson about that.

Q. Who else?

A. I don't think I told anybody else about that.

Q. Certainly you told your parents?

A. Certainly not.

Q. Your brother and sister?

A. No.

Q. Your adoptive brother and sister, I mean?

A. Of course not.

Q. You did not tell them. Did you have a lawyer in connection with that matter?

A. No, sir.

Q. Mr. Wolf, we're going to talk a little more about your arrests a little later on today. I want to find out a little more about your education right now, and then about -- learn more about your career. After you got your Master's degree

Page 42

in journalism, did you have any additional graduate school education?

A. No, sir.

Q. Who was your faculty advisor during your graduate school in journalism at the University of Colorado in Boulder?

A. Well, I think I had a number of them.

Q. Okay. Who were they?

A. Well, I guess -- I guess Willard Roland, who was the dean of the school. Ray Chavez. Polly McClean. I guess that's probably --

Q. Is that all?

A. I think I got advisement from a number of people on, you know, an impromptu basis.

Q. Were you close to any of the faculty members you've just named?

A. Well, yeah, I liked a lot of them. Those three and others.

Q. And who else did you like and did you feel you were close to?

A. Bob Terrell.

Q. Who else?

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A. I'm trying to think; although, that may be about the list for that category.

Q. Did you know Mr. McClendon? I'm sorry. Bill McReynolds. I'm sorry. I misspoke earlier.

A. I had met him -- or I wouldn't even say met, I guess. Well, okay, I would say I had met him once when I was going to enter one of his classes, but I was told at that time that I should go to a different class, which I did. And I really never talked to him again.

Q. Do you have any relationship at all with Bill McReynolds?

A. No, sir.

Q. Did you ever spend any time with him outside the school?

A. I have talked to him once in my life, and that was the day I tried to get into his class.

Q. Never been at his cabin?

A. No, sir.

Q. Never been at his home?

A. No, sir.

Q. And he has never been a faculty

Page 44

advisor of yours ever?

A. No, sir. Unless I was -- unless I was assigned to him for some reason by -- at some sort of, kind of initial -- and I don't recall if that ever happened, but like I said to you, I have -- I have talked to him once in my life. So I'm certain he was not my advisor.

Q. And when you talked to him on that occasion, he was not furnishing you advice?

A. No, sir. He was standing at the front of a crowded classroom, and I was standing at the door at the rear, and he said, You should go get into a different class, and so I left.

Q. After you got your Master's degree, did you seek employment as a journalist?

A. Yes, sir. Well, prior to when I got my Master's degree, I was hired as a reporter at the Colorado Daily.

Q. When did that begin?

A. September of 1990.

Q. And you told us earlier, I

Page 45

believe, that ended in 1994; am I correct?

A. Yes, sir.

Q. How did it end?

A. I asked them to fire me, and they did.

Q. Explain that to me, please, why you asked them to fire you.

A. I was tired of writing the same stories every year, and I felt that I had done everything that I needed to do and was supposed to do at that job, and I was not happy on the job anymore. And I wanted to be able to be eligible to get unemployment compensation in order to give me time to find another job, and so I had asked them if they would fire me, and they did after a short interval.

Q. So instead of quitting, you wanted to be fired so that you could get unemployment compensation; is that right?

A. Yes, sir. That's right.

Q. And when you told them you wanted them to fire you, did you tell them why?

A. I told them I was frustrated and wasn't happy at the job anymore and felt like

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I wasn't contributing what I expected myself -- of myself, and that I wanted to be fired.

Q. Did they have any other reason to fire you that you are aware of?

A. No, sir.

Q. Did you tell them that you planned to go out and seek unemployment compensation if they indeed were to fire you?

A. I did not tell them that.

MR. RAWLS: Let's go off the record for a moment.

THE VIDEOGRAPHER: One moment. We are off the video record at 10:11. (A recess was taken.)

MR. RAWLS: All right, let's go back on the record.

THE VIDEOGRAPHER: We are on the video record at 10:22.
Q. (By Mr. Rawls) Mr. Wolf, I want to backtrack for just a moment before talking more about your career as a journalist. Have you ever had a job or an employment for a longer period of time than your job with the Colorado Daily?

A. I worked for a -- well, no, I

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don't think so. Not longer than that.

Q. And back to the subject of your friends or people who know you well, does anyone know you better than Jackie Dilson?

A. I guess at this point in my life, probably -- probably not.

Q. Is it fair to say that you and Jackie Dilson had a romantic involvement or relationship for a time?

A. Yes, sir.

Q. And for approximately how long?

A. Ah, approximately a couple of years, I guess.

Q. Have you had longer romantic relationships with anyone else than you had with Jackie Dilson?

A. I think that's probably about the -- I've had, well, romantic relationships of equal length, but not probably longer.

Q. And tell me the names, please, of those individuals with whom you have had romantic relationships of equal length.

A. In chronological order, TP, GC. And that's probably the other two

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that I was involved with for the similar length of time.

Q. And you, if I'm not mistaken, you lived with Jackie Dilson for approximately two years; is that right?

A. Yeah. Probably longer. I guess -- I think we probably were so-called romantically involved for probably longer than two years. And I think that also there was a period, I'm sure, that also there was a period of time during that period of time that we were not living together.

Q. Okay. And where does TP now live, if you know?

A. As far as I know, Baltimore, Maryland.

Q. When did your romantic relationship with TP begin and end, approximately?

A. Approximately -- began, approximately, I guess, 1980 to '82.

Q. And was it in Baltimore when you and she were involved?

A. Yes.

Q. Where is GC now?

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A. In Boulder.

Q. Was it in Boulder that you and she --

A. Yes.

Q. -- were romantically involved?

A. Yes.

Q. And when was that, approximately?

A. I guess -- I guess maybe '85 to '87. Yeah. And I guess there was another girl that I was involved with for about probably not quite two years.

Q. Who is that?

A. That was CR. CR. I don't know why I had that, but -- yeah. So that was a -- yeah. That was between TP and GC.

Q. Where is she?

A. I thought she had moved, and I am not sure where, but I was involved with her in Baltimore, Maryland.

Q. Are you still in touch with CR?

A. No. I've seen -- I have seen her once or twice since we were involved, but I haven't seen her for some time now, and --

Page 50 no.

Q. Are you still in touch with GC?

A. No. I haven't talked to her for quite a while.

Q. With TP?

A. No, I'm not, but in each of these cases, I have talked to them since we -- talked to them or seen them sort of, maybe, periodically in the broadest sense, I guess, just, you know, occasionally now and then since the time we broke up, I guess. And I think that, you know, I have a friendly relationship with all of them, if that's what you're interested in.

Q. Do you stay in touch with Jackie Dilson?

A. Well, I had, but I haven't for quite a while now. I guess -- I guess I just had the -- I guess I just thought that I probably shouldn't, given the circumstances of this lawsuit and the case in general. Although, I had -- we had been in pretty much communication for -- for a long time.

Q. Do you still know her address, her

Page 51

telephone number, how to reach her?

A. Well, I probably do know her address unless she's moved in the last year.

Q. Do you have an address and a telephone number for TP?

A. I had a telephone number for her, and I called her about, I guess it's probably been, four years ago, five years ago, maybe. And we chatted for a little bit.

Q. Do you have a phone number and an address for GC?

A. No, I don't. But she was born and raised in Boulder, and I know I can find her, get in touch with her if I wanted to.

Q. Mr. Wolf, before you worked with the Colorado Daily, did you have any other jobs in journalism?

A. No, sir.

Q. No jobs of any sort in journalism? You never tried to cover any stories as a reporter?

A. No.

Q. Did you ever do any freelance work?

A. Oh, yeah. I worked for the

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Longmont -- did I work for the Daily Times-Call as an intern. I guess that was prior to -- that may have been prior to or maybe simultaneous with the -- with the Daily.

Q. Is that one job you just spoken of because you used a lot of words, Longmont and Daily Times and intern. Is that one publication?

A. Yeah, the Longmont Daily Times-Call is the name of the newspaper.

Q. So were you an intern at that paper perhaps simultaneously with your work for the Colorado Daily?

A. Yes.

Q. What did you do as an intern?

A. Covered the Lyons City Council and wrote stories for them.

Q. Was that a part-time job with the Longmont publication?

A. That really wasn't a job at all. It was an internship. I don't think that they paid me.

Q. And after --

A. It was a semester. It was a

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semester long, once a week, or something like that.

Q. During the years you were with the Colorado Daily, did you do any other journalistic work other than the internship for this Longmont publication?
A. Yeah. I wrote for the Boulder County Business Report on a freelance basis.

Q. Were you paid per article?

A. Yes.

Q. Was business a particular interest of yours in Boulder?

A. No.

Q. Nonetheless, you sought out an opportunity to be published in the Boulder County Business Report on a freelance basis?

A. Yes. A friend of mine told me he was working there and that they paid, you know, a reasonable amount per story. And so I asked if I could write for them.

Q. Who was the friend who told you that?

A. Jim Burres.

Q. While you were at the Colorado Daily, to whom did you report?

Page 54

A. Clint Talbott.

Q. Is that true for each of the years you worked there?

A. Yes.

Q. Who was the person you asked to fire you?

A. Debbie Melani.

Q. Who is the person who actually fired you?

A. Clint Talbott.

Q. Can you spell Debbie Melani's name, please?

A. Debra, D-e-b-r-a, M-e-l-a-n-i.

Q. What was her title?

A. She was a managing editor.

Q. What was Clint Talbott's title?

A. Editor.

Q. What was your beat at the Colorado Daily?

A. I had a number of them. I covered Rocky Flats' nuclear weapons plant. Something called Culture, which meant student protests and student activities and speakers on campus. NASA, and science research at the University of Colorado. And I cannot

Page 55

remember the other one. I think I wrote -- know I wrote education stories and -- whether that be the University of Colorado administration or K through 12, which we wrote something on occasionally. And I can never remember what the other beat may have been, but there was one other main one there. I remember I had four. And education was really not one of them. I guess general assignment may have been the other one.

Q. Did you inform your employer of your indecency arrest?

A. No, sir.

Q. To the best of your knowledge, did anyone with your employer ever learn about it?

A. To the best of my knowledge, no one ever said anything to me about it.

Q. Did you ever cover anything that Bill McReynolds had done while you worked with the Boulder Daily?

A. Not to my knowledge or recollection.

Q. Did you express an interest in

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covering student protests while you worked with the Boulder Daily, or were you simply assigned that?

A. I was simply assigned that. And -- yeah, I was simply assigned that.

Q. Did you express an interest in covering the Rocky Flats nuclear facility, or were you simply assigned that?

A. Well, I think they asked me to, and I said I would be interested in doing that. Which was probably, probably the same circumstances of all of those.

Q. Covering NASA at the University of Colorado, did you express an interest in that or was that an assignment you were given?

A. That was an assignment I was given.

Q. Covering science research at the University of Colorado, was that an assignment or did you seek that out?

A. No, that was assignment I was given. I think that all of those fall under the category of they wanted me to cover those things because they were sort of

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serious and complicated subjects that they thought I could do a good job with, and that I was willing and interested to try to do the best job I could with all of those.

Q. Mr. Wolf, what was the next job you had by way of regular employment in journalism after the Colorado Daily fired you?

A. That was at the Lyons Recorder.

Q. When did that start?

A. Maybe -- maybe spring or summer of -- of '96.

Q. How long did you receive unemployment compensation?

A. I think about maybe four months.

Q. And once that ran out and before you began working with the Lyons Recorder, what did you do for gainful activity in journalism, if anything?

A. I was writing part-time or freelance for the Business Report and taking pictures for them. And that's all in the meantime.

Q. What was your job with the Lyons Recorder?

A. I was a reporter, photographer.

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Q. How long did you hold that job?

A. I think maybe four months.

Q. So that ended sometime in 1996, did it, or shortly thereafter?

A. Yeah. It ended in the late summer or fall of '96.

Q. To whom did you report at the Lyons Recorder?

A. Walt Kinderman.

Q. Title of Mr. Kinderman?

A. Editor and publisher, I believe. No, he was just the publisher.

Q. What was your beat at that paper?

A. Everything. City council and features and police.

Q. What was the reason or the cause for your employment ending at the Lyons Recorder?

A. He fired me.

Q. Did he tell you why?

A. I think he did, and I can't remember why.

Q. Is there any document that he gave you that would have that information?

A. No.

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Q. He didn't send you a termination notice or letter?

A. No.

Q. Can you tell me what you do recall about the reason and circumstances for your having been fired from the Lyons Recorder?

A. I think it was basically over money, over the amount he was paying me.

Q. That's your best recollection?

A. Uh-huh (affirmative).

Q. What was your next job in journalism after that?

A. I got a job with a paper in the British Virgin Islands, and I went there and sort of worked for a week or two, and I could not get a work permit.

Q. What was the paper?

A. The Beacon something, maybe, something Beacon. Or Beacon something.

Q. What city?

A. Tortola. I don't know what the city, what's the city called? I forget. It's on the islands there.

Q. There are a couple of cities on

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it, and I don't recall their names right now.

A. Is there? The big one.

Q. The big one. Okay. That helps. Thank you.

A. Well, there is only really one, I think.

Q. I think that's right. After you could not get a work permit, you returned to the mainland U.S.?

A. (Witness nodded head affirmatively.)

Q. And did you take a job in journalism thereafter?

A. Yes. I came back to Boulder and I got a job with the Louisville Times, which is Louisville, Colorado, just outside of Boulder in Boulder County.

Q. And what was your job?

A. They called me the editor. I was basically a reporter and a photographer, and I did the layout.

Q. That's a small publication then?

A. Uh-huh (affirmative). Twice weekly.

Q. How much employees were there?

A. Oh, maybe 12 or 15. Something

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like that.

Q. How many other reporters?

A. Oh, maybe three or four. Maybe three or four.

Q. And how -- well, at what date, approximately, did you get that job?

A. Maybe May of '97.

Q. And when did that job end, if it did?

A. May of '98.

Q. And what was the reason that that job was not continued?

A. They fired me.

Q. To whom did you report at that publication?

A. Doug Conarroe, C-o-n-a-r-r-o-e.

Q. Thank you for spelling that. Who is the person that fired you?

A. Doug Conarroe.

Q. Did he tell you why?

A. He said -- he fired me for missing time, which I hadn't really missed any time in the entire year that I was there to speak of more than -- I don't think I missed, missed a deadline in the year I was

Page 62

there until like the week before he fired me, at which time I was very sick and very stressed out, and I missed, basically, an entire week.

Q. Why were you stressed out?

A. It was a heavy, heavy workload. I had -- I worked basically about eight hours on Monday, and about 12 to 15 on Tuesday, and then eight hours on Wednesday, and 12 to 15 on Thursday. And I wasn't making much money, and I was very tired.

Q. The schedule you just described, was that your schedule in every week or a typical week?

A. That was a typical week. It was a twice weekly publication, and I had to write all the stories I wrote, eight stories a week, eight to ten. And I had to cover city council, planning commission, cops and courts, features, and I had to do all those interviews and write all those stories and take all the photographs and make all the appointments, and make all the appointments for all those to fit together, and then lay the entire paper out -- well, not the entire

Page 63 paper, the entire four-page news section on the night, deadline night, which was a Tuesday and a Thursday. And I always, every week and with every story, try to do the very best job that I could on every single story, as well as the photographs and the layout.

Q. What was the next job you had in journalism after you were fired at that publication?

A. Well, I worked at the -- I worked at the Slidell Century News in Slidell, Louisiana, as a photographer.

Q. When was that?

A. That was -- I guess I started in September of -- I guess September of '98. And I think I worked for approximately not quite a year.

Q. What was the reason you were terminated or you terminated that job?

A. No. Yeah. I just couldn't afford to work there anymore, and I had to -- I had to quit, even though I sort of liked it.

Q. What was your photography beat for

Page 64 that publication?

A. I shot most of the photos for the paper, front page photos, maybe, probably between one and three photo assignments for the front page for the -- well, I think -- well, I'd say between -- well, let's see. I would say one to three per day, whether they be the front or the inside. There is always, always at least one for the front.

Q. And so you quit your job at that paper?

A. Yes, sir.

Q. To whom did you report at that location?

A. Kevin Chiri, C-h-i-r-i.

Q. What's his title?

A. Editor.

Q. After that, what was your next job in journalism?

A. I guess I basically have been just -- I came back to Boulder, and I was doing freelance for the Business Report again.

Q. For how long?

A. Oh, until I moved back -- moved out here. So I guess maybe, maybe August

Page 65

'99 through last, last December.

Q. In that period of time, did you have any regular employment other than the freelance work?

A. Yes. I worked at Mike's Camera in the repair department.

Q. And who was the person you reported to there? Mike?

A. No. That was Vahe Christianian; V-a-h-e, Christianian, Christian with an i-a-n.

Q. Did you resign from that job or were you fired?

A. I was fired.

Q. By the person you just named?

A. No. By a manager.

Q. Who was that?

A. Jeff Brewer.

Q. What was the reason?

A. I said something unkind to a customer.

Q. Do you recall what you said?

A. I called him an asshole.

Q. Did the customer complain?

A. Yes.

Page 66

Q. What is the name of the customer?

A. I have no idea. It was a 20-year-old male.

Q. Did you resign in any formal manner as a freelance writer for the Business Report, or were you told that your reports would no longer be welcomed?

A. No, I wasn't told that at all. I never have been told that, and I've worked there since 19 -- well, for ten years. I just told them that I was moving, and that I appreciated them giving me the work that they had, and that I wouldn't be able to write for them anymore, at least for the time being.

Q. Have you told us about all of your journalism work in your entire journalistic career today or have we left out anything?

A. I wrote a -- let's see. I had an internship at the Ft. Collins Coloradoan. And that was way back at the time I was in school. And I guess I wrote a couple of things for a space magazine based in

Page 67

Washington. The editor was in Colorado frequently and I guess had seen me -- my stories on the subject in the Daily, and asked me to write some stories for him.

Q. Who was that?

A. I can't remember his name.

Q. Were you paid for those?

A. Yes.

Q. And is there any journalistic job that you have held or freelance journalistic work that you have done that you have not told us about here this morning?

A. Not that I can think of. I wrote a couple of -- I wrote some stories for a little 'zine, kind of self-published little thing that a friend of mine, Jay Gluckstern was doing. That was quite a while ago.

Q. Okay. Anything else?

A. No. That's probably all.

Q. And from 1990 up to today, what other employment have you had that is outside the journalistic field?

A. I was a baker, and I was a stripper in New Orleans.

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Q. Any other employment?

A. That's all. That's all that I think. From 1990 you asked?

Q. Yes, sir.

A. That is all that I can think of.

Q. When were you a baker?

A. Oh, some of those periods of time when I was between jobs in the -- the middle of the 1990s after the Daily. I think I was a baker -- I know I was a baker for two different times for a few months each.

Q. And who was your employer when you were a baker?

A. Billy's Bagels and Moe's Bagels.

Q. Are both in Boulder?

A. Yes.

Q. Were you fired from either position?

A. Yeah. I was fired from -- no. I quit both of them. I'm sorry. I wasn't fired from either of them.

Q. When were you a stripper in New Orleans?

A. During a period of time that I lived there. Sort of the --

Page 69

Q. Is that the period of time you held the job with the Slidell paper?

A. Yes. Although, the -- I -- I lived in New Orleans from September '98 through August '99, and really, I guess, I worked at the Slidell paper. I got that job at the Slidell paper pretty much when I arrived there a few weeks after I got there. And I guess I quit that. Yeah, I didn't work there a year. I had another job taking -- portrait photography for a company in Kansas City from which I was able to travel from New Orleans and travel around frequently every week. And that was -- I did that job during the, pretty much, the second part of the time that I lived in New Orleans.

Q. What was the name of the Kansas City portrait photography company?

A. That was Creative Expressions.

Q. To whom did you report there?

A. Bryan Rothrock, R-o-t-h-r-o-c-k.

Q. How did that relationship cease?

A. They fired me.

Q. Who did that?

Page 70

A. Bryan and his sister, who owned the company.

Q. Did they tell you why?

A. No.

Q. And for what employer or employers were you a stripper New Orleans?

A. A company called Prestige Entertainment or something like that. Prestige something.

Q. Did you strip at any one location or would you go to --

A. Parties, yes. You go to different locations.

Q. You go to private parties, in essence?

A. Uh-huh (affirmative).

Q. About how many assignments did you have per week?

A. Oh, probably about -- probably, maybe, one a week at the most.

Q. Were you given a particular amount of money per each occasion?

A. Yeah.

Q. And would you also get paid tips?

A. Occasionally.

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Q. Did that relationship come to an end?

A. Yeah. I just --

Q. Was that your doing or --

A. Yeah, it was. I was -- when I moved, I couldn't work there anymore.

Q. All right, sir. So since 1990, have we now covered all of your gainful employment activities, both inside and outside the field of journalism?

A. Well, I guess so. And I guess it jogs my memory, I worked as a stripper in Colorado in the early '90s, also.

Q. And for what firm or entity or employer did you work in Colorado as a stripper?

A. I'm not sure if I can remember their name. Oh, Triple-A Party Dancers.

Q. Was there any other entity that you ever worked with or for as a stripper?

A. Yes. Prior to moving to Colorado.

Q. Okay. Where was that?

A. In Baltimore.

Q. And what entity in Baltimore did you work with as a stripper?

Page 72

A. I'm sure I can't remember the name of that company.

Q. Was it just one company?

A. Yes.

Q. Were all of these three different employers which you worked with as a stripper employers which sent you out to private parties?

A. Yes.

Q. There was never a regular club or bar or location where you were a stripper?

A. No. Not on a regular basis.

Q. Did you, in fact, meet Jackie Dilson because of an engagement that you took as a stripper?

A. Yes, sir.

Q. When was that?

A. August of '95.

Q. Do your parents know that you, from time to time, have been a stripper?

A. Yes.

Q. Your paternal grandparents with whom you're now living?

A. No.

Q. Your brother and sister?

Page 73

A. Not that I know of.

Q. So you have shared that fact with a few people to whom you are close, but not many?

A. Right.

Q. The friends that you told us about from Boulder, there were eight names we discussed earlier in the day that were people you felt particularly close to in Boulder, five of them from the Boulder Daily, three others from other walks of life, did they know you were a stripper?

A. Not at the time. I think they probably do now.

Q. They probably do now for what reason?

A. Because it's been publicized as a result of this case.

Q. As a result of your lawsuit filed just last year?

A. As an indirect result of that, I guess.

Q. How did your parents come to know you were a stripper?

A. I told them.

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Q. Had you ever been terminated as a stripper from any of these agencies?

A. No.

Q. Did you have any engagements with any of those agencies to do anything other than strip?

A. No.

Q. Did you ever have any engagement to pose as a model for photographs?

A. Yes.

Q. For Prestige Enterprises?

A. No. That would -- those would have been either for me to get a portfolio done for work as a stripper or for me to model for a couple of friends of mine who were photographers.

Q. So the only modeling you have done for photographs has either been for a portfolio for the agency for which you were a stripper or it's been for friends of yours who are photographers?

A. Yes.

Q. And who are the friends of yours who are photographers for whom you have posed?

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A. Oh, gosh, I'm trying to remember her name. The one, the first time that I did that was for a girl who I met in an art class in Baltimore a long time ago, and I do not remember her name. And then, more recently, it was for a lady who I met in an art class who I should remember her name, and I'm trying to. It really slips my mind. I haven't really talked to her for about, probably, close to, maybe -- nearly -- well, at least four years, probably five. And I really am surprised I can't remember her name. I will be able to eventually, I'm sure.

Jameson wrote:This is where I may start deleting large chunks - I found myself quite disturbed by what he said and don't feel comfortable posting it "as is" - - but you will all get an honest feel for the content.

Q. What kind of photographs did you pose for for those ladies?

A. Just nice artful photographs.

Q. What kind of "nice artful photographs," just so we will understand.

A. Well, nude is what we are talking about, right?

Q. We are talking about nude artistic photographs?

A. I thought that's what we are talking about.

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Q. I had not used the word "nude."

A. Oh. Yeah, nude.

Q. Have you posed for photographs for pay when you have worn clothing?

A. I was -- no, I haven't. I was trying to -- considering doing that, but I never ended up doing that. I got later assigned -- I got assigned to go to a job, and I just didn't want to do that. I never went.

Q. What job was that?

A. Oh, it was one of those, it was just an ad, you know, you see in the paper, and, you know, be a model. And they were going to -- you know, you had to put down $250, and they were going to -- she said she was going to send me to do a fashion for a newspaper for Foley's, or whatever, department store or something. And I decided not to go.

Q. Were you paid by either of those two ladies that you described here who took nude photographs of you at two different times in your life?

A. No.

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Q. You did not receive pay?

A. No.

Q. Did you sign a model waiver or release so that they could use those photographs?

A. No. Those were -- the two occasions I'm referring to, they were people who I was friendly with. We were just friends. And we just did it on a -- it wasn't a professional job or assignment, no.

Q. Did you keep copies of the photographs?

A. I have copies of one of those photographs.

Q. Which one?

A. The more recent ones.

Q. Where are those photographs?

A. I have them in my personal things in Kentucky.

Q. So your posing in those situations was a personal matter?

A. Yes.

Q. As opposed to a business matter?

A. Yes.

Q. And did you have a romantic

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relationship with those women?

A. I didn't with either of them. And the second one I know now wanted to with me, and I did not pursue that, and I feel like she was hurt by that, by my failure to pursue that. And I feel bad about that to this day, because she was a nice lady and a friend of mine.

Q. Have you yet remembered her name?

A. No. Surprising. I have it written down in my book somewhere.

Q. In what might you have it written down?

A. In my Daytimer.

Q. Where is that?

A. Oh, I have a -- oh, in Kentucky.

Q. At your place of residence now?

A. Yes. In an old Daytimer, you know, from one of the years around the time that she took those photographs.

Q. Have you ever posed for photographs that you consider pornographic?
A. Not that I would consider pornographic.

Q. Have you ever posed for

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photographs that have appeared in advertising, to your knowledge?

A. Yeah. I think that the one group in Denver used one of my photos for an ad.

Q. What group was that?

A. Some strip company or --

Q. Was that the same company that you worked with?

A. I didn't work with them.

Q. How did they get your photograph?

A. Through a third party, I think.

Q. Did you consent to that?

A. No.

Q. Did you get paid for it?

A. No.

Q. Did you complain about it?

A. No.

Q. How long did they use your photo?

A. I don't know.

Q. Were you proud of it?

A. I thought it was a good photo, and it wasn't -- I thought it was a good photo.

Q. Do you still have a copy?

A. No.

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Q. Were you happy they were using it?

A. I wasn't happy or unhappy.

Q. Mr. Wolf, tell me, as best you recall, please, sir, all of your residence addresses from 1990 up to now.

A. 1990. I guess it something like 1500 block of Pine Street in Boulder. Maybe 1519. After that I lived with a woman for a short period of time who was a friend of mine, before and since; although, she's dead.

Q. Do you recall the address?

A. Well, 1519 was with the roommate situation. After that, I moved in with this woman, who was a friend of mine, and her address was something like 700 block of Spruce Street in Boulder.

Q. What was the name of that woman?

A. I am drawing a blank on names. It's embarrassing. I can't recall where I have tucked her away. I'm sure I will remember.

Q. Is there anything that is blocking your memory today or interfering with it in

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any way?

A. I think I'm trying to think about a lot of different things that I haven't thought of for a long time.

Q. My interest is that you focus on the particular question, and I'm sure you know that.

A. Uh-huh (affirmative).

Q. Are you under any medication today?

A. No, sir.

Q. Are you under any particular stress today?

A. I think it's somewhat stressful being here.

Q. You are here because you filed a lawsuit.

A. Yes, sir. And I didn't complain about being here. I'm here completely voluntarily.

Q. You filed your lawsuit voluntarily.

A. Yes, sir.

Q. Is there anything that we can do to make you more comfortable today and to make it easier for you to recall who --

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A. I could use the restroom.

Q. All right. Let's take a break.

THE VIDEOGRAPHER: We are off the video record at 11:15. (A recess was taken.)

THE VIDEOGRAPHER: We are on the video record at 11:28.

Q. (By Mr. Rawls) Mr. Wolf, if at any time you need to take a break for purposes of using the restroom, please do let us know.

A. Okay. Thank you.

Q. And before we go to some different subjects, I want to get just a small number of additional details about some of the things we discussed in the last hour. Did the people, the customers who would book your act as a stripper, did they have a list of options to choose from, options as to different strippers and options as to different kinds of acts?

A. I -- in some -- I guess they probably did through the agency.

Q. Was there more than one show that you would put on?

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A. No, I don't think so.

Q. You would essentially do the same show each time?

A. Well, yeah. Just --

Q. Was this true in all of the three different agencies that you worked with as a stripper?

A. Uh-huh (affirmative). Yep.

Q. And tell us what that show was.

A. Just show up, say hi to everybody, turn the music on, and dance around, and take most or all of my clothes off.

Q. You say "most or all"?

A. Most or all.

Q. Which was it?

A. Either that they wanted.

Q. So you would be booked by, on occasion, by people who would say that they did not want you to take all your clothes off?

A. Yeah, I assume so. Yeah.

Q. You assume so, but you don't know that?

A. I think that they used to say sometimes just go to a G string.

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Q. And other times what would they say?

A. Go nude.

Q. And mostly which was it?

A. Mostly it was not specified. Either of those, I would say.

Q. And how would you learn which was preferred?

A. I guess by the time you got to the G string, it was pretty obvious which was preferred.

Q. And which was usually preferred?

A. Nude.

Q. And were your parties that you would attend mostly parties involving women?

A. Yeah.

Q. Almost always?

A. Almost always.

Q. But not always?

A. But not always.

Q. So sometimes you would be at parties where the customers were mostly male?

A. Yes.

Q. Or entirely male?

A. Yes.

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Q. And sometimes you would be at parties where the customers were mostly or entirely women?

A. Primarily, yes.

Q. That was the usual case?

A. Uh-huh (affirmative).

Q. And almost never was there somebody there who was a male if this was a party involving mostly women customers; is that right? Other than you, as a male.

A. Right. Yes.

Q. Did your show or your act include any contact with any of the customers?

A. Yes. It could.

Q. What kind of contact?

A. Them touching me or -- and me touching them, you know, in less than -- in nonsexual kinds of ways.

Q. Explain to us how you would touch them or they would touch you.

A. I would put my hands on their shoulders and then put my legs against their legs probably, mostly.

Q. And did they kiss you? Did you kiss them?

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A. Sometimes, yes.

Q. Were there any limits on what you would do in these shows?

A. Oh, yes. You know -- well, yeah, there were -- there was no intercourse or anything like that involved.

Q. What limits did you put on what you would do?

A. Oh, probably just generally would let them touch me as much as they wanted to, but -- they could kiss me if they wanted to. And that was about it.

Q. Was there any limit on where they could touch you?

A. No.

Q. Or what they could touch?

A. No.

Q. And where did they touch you?

A. In the shoulders, waist, head, hair, genitals and bottom and legs pretty much everywhere.

Q. So you drew no limits on where they could touch you, and often the customers also did not have any limits?

A. Well, no, I'm not saying that. I

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really drew no limits on where they could touch me, but I didn't really generally touch the customers in those same places. I touched their shoulders, their arms, their hair, maybe squeeze their bottom or something if they want, you know, if they really, if they are dancing with me, or something like that. But I wouldn't touch genitals.

Q. Of the customers.

A. Of the customers.

Q. Even if they were touching your genitals.

A. Even if they were touching my genitals.

Q. Did you ever work as a male prostitute?

A. No. I would say I was, just a stripper.

Q. You hesitated, though. And why was that?

A. Well, because of all of the touching that was involved.

Q. How far did the touching go?

A. I guess in some cases, oral sex.

Q. Simulated or actual?

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A. Actual.

Q. And in "actual," to the point of ejaculation.

A. No, no, I didn't do that.

Q. Ever?

A. No.

Q. Ever through touching?

A. No.

Q. Did you, as part of your act or show, do any kind of simulated sex acts?

A. I think, you know, dancing and such like that. Kind of dancing. You know, you see people in clubs these days dancing in what you would call simulated sex acts, so I think I did similar kinds of things.

Q. With someone from your agency that would join you at these shows or with one of your customers or both?

A. Customers. I never really -- I can't recall ever dancing with -- I can't recall being at a -- I don't think I was ever -- I'm sure I was never at a party where there was another person from one of those agencies, another stripper.

Q. You were the only person from the

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agency who would ever go to your own show as a stripper?

A. Uh-huh (affirmative).

Q. Did some of the customers take their clothes off during your show?

A. Uh-huh (affirmative).

Q. And engage in simulated sex with you?

A. Or oral sex or actual sex.

Q. Did people take photographs when this was going on?

A. Occasionally. I tried to discourage it, but sometimes I couldn't. And, you know, it wasn't often that people wanted to, but sometimes they would. And I didn't really feel it was my place to say that they couldn't at that point.

Q. So you did not refuse?

A. No, I didn't.

Q. Did you sign autographs on any of these photographs --

A. No, no.

Q. -- ever? Did you ever see a photograph taken during one of your acts as a stripper?

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A. Yes, I have see them.

Q. Do you possess it?

A. Yes. One or two. I think probably one. I don't have -- no, I don't possess a copy of it.

Q. And did you engage in actual sex acts other than oral sex on any of these occasions?

A. I never gave anyone oral sex. They did to me. And I didn't --

Q. And apart from oral sex and simulated sex, as you've described, was there any other actual sex act at any of your shows as a stripper?

A. No.

Q. Did you have a stage name as a stripper?

A. I did when I was in New Orleans.

Q. What was that name?

A. I can't recall.

Q. Was there more than one name?

A. Not that I remember. Just I thought there was just one with the one company.

Q. Do you possess any of the

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portfolios that were used to merchandise your service as a stripper?

A. No, I don't.

Q. Do you possess any of the ads that was used to sell or market your services as a stripper?

A. No, I don't. Sir, I should -- I'm sorry. I should amend something. I think I do recall having sex with a couple of girls in a couple of different times during shows.

Q. And this was not oral sex?

A. No. Intercourse. But really it was a couple of different times when I was living in New Orleans, when I was working for them I had intercourse with a couple of the girls, I think. I'm sure.

Q. Anywhere else?

A. No. Prior to that it was all what I told you about, just what I have told you before. That having intercourse was a brand new thing for me to be doing at that time when I was in New Orleans.

Q. Did you do it for money?

A. Well, I was a stripper for money,

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and so I got paid for stripping.

Q. Did you receive anything, any additional payment for intercourse?

A. No.

Q. Were people watching you have intercourse on those occasions?

A. Yes.

Q. Were people taking photographs of you having intercourse on those occasions?

A. No.

Q. Did you have a stage name when you were a stripper in Baltimore?

A. No. Not that I can recall. That was quite a long time ago.

Q. Did you have a stage name when you were a stripper in Boulder or the Boulder vicinity?

A. No.

Q. Was it Boulder or was it Denver?

A. Both. Mostly Denver.

Q. Was there a different agency in Denver from the one in Boulder?

A. No. It was the same one. And, really, I didn't hardly -- I don't know that I -- I think I may have done one show in

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Boulder, but it was all pretty much in Denver.

Q. What kind of costume would you wear to begin with when you would arrive as a stripper?

A. I would just wear jeans and a shirt.

Q. Always?

A. Uh-huh (affirmative).

Q. That was true in Boulder?

A. Uh-huh (affirmative).

Q. That was true in Baltimore?

A. Uh-huh (affirmative).

Q. That was also true in New Orleans?

A. Uh-huh (affirmative).

Q. What kind of role play would you engage in as a stripper?

A. It wasn't really like that. I don't think that it was role play except for the fact of me being there to take my clothes off in front of everyone that was there.

Q. Did you sing? Did you dance?

A. No. Danced, yes. I didn't sing.

Q. What kind of a dance?

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A. Well, just whatever you do in a club.

Q. Would you bring music with you?

A. Yes, usually.

Q. What music would you bring?

A. Music I liked.

Q. What was that?

A. Oh, I don't remember. Whatever was popular.

Q. You have been a male stripper as recently as 1999, you took music that you liked, and you don't recall any of that music?

A. I guess The Cure, mainly.

Q. What particular songs?

A. That I don't know. I don't know the names of any of those songs, really.

Q. Did you encourage your customers to scream and shout during your stripping?

A. I think, generally, I didn't have to encourage them in any way except what we've discussed.

Q. Did you ever, when the customers were men, did you ever engage in simulated sex?

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A. No.

Q. In actual sex?

A. No. Well, receiving oral sex.

Q. I'm sorry?

A. Receiving oral sex or being touched, that holds true. Those -- yes.

Q. That holds true in the male parties --

A. For men, uh-huh (affirmative).

Q. -- that you attended as well?

A. Uh-huh (affirmative).

Q. You drew no limits on those parties either?

A. Well, I didn't say that. I drew limits as far as penetration.

Q. As far as male parties were concerned?

A. Yes.

Q. Did you do parties in which the customers were males in Baltimore?

A. No.

Q. In Boulder?

A. No.

Q. In Denver?

A. No. Not until I moved to New

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Orleans.

Q. Only in New Orleans?

A. Yes.

Q. Did you take any different music to a gathering of men?

A. No.

Q. Did you wear different clothing to a gathering of men?

A. No.

Q. Did you have stage names for gathering of men?

A. I don't recall having a -- I think I did, and I don't know what it was. I think I said that.

Q. Did you do nude dancing with other men when you were stripping in a group of men?

A. Yes.

Q. Were photographs taken?

A. Could have been. I don't recall. Like I said, I didn't really tend to try and stop people from doing that because I thought that that was their prerogative as a customer.

Q. In a gathering of men, did you

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have simulated anal sex?

A. No.

Q. Actual anal sex?

A. No.

Q. Either giving or receiving?

A. Neither.

Q. No intercourse?

A. No.

Q. In a gathering of women, did you have simulated or actual anal sex?

A. No.

Q. You're sure?

A. Yes, I'm sure.

Q. In a gathering of men, did you permit yourself to be touched anally?

A. No. That's sort of what I was referring to as far as penetration. I didn't -- that's where I drew the line.

Q. You would be touched, but not penetrated --

A. Yes.

Q. -- anally?

A. On my rear end. They could touch me on my rear end. Not on my anus.

Q. In any of these shows that you

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performed ever in Baltimore, in Boulder, in Denver, in New Orleans, did you ever engage in actual or simulated bondage?

A. No.

Q. Did you allow yourself to be put in a situation of actual or simulated bondage?

A. Never.

Q. Did you ever allow any of the customers to be placed in actual or simulated bondage?

A. Never. I've never done anything resembling bondage or S&M in any way, in being a stripper or in my own sexual activities or interests, or whatever. I have never, never participated in that.

Jameson wrote:OK - you have an idea of what this is all about - - I am going to skip the rest of this stuff as it truly sickens me. Call me a prude if you like, this is disgusting.

Q. You told us earlier that you have masturbated in front of people; did you not, sir?
A. Yes, I did.

................

Q. And, Mr. Wolf, you've also done that outdoors in plain sight; have you not, sir?

A. Oh, I don't think in plain sight. I have done it outdoors.

Q. You've been arrested for doing that outdoors; have you not, sir?

A. I don't think I was arrested for masturbating. I wasn't masturbating at the time I was arrested.

Q. That was 1992; am I correct?

A. As I recall.

Q. Tell us what you were doing and what you think you were arrested for on that occasion.

A. I was -- I stopped at a -- on a side of a commercial kind of road and pulled in the back of a commercial, what appeared to me to be sort of a strip mall of some kind at, I think, nearly midnight or after midnight. And there were no cars in the front of that building and there were no cars anywhere nearby, and the building was all dark, and it was obviously a commercial building. And I pulled in behind because I had to go to the bathroom, and I had been drinking. I had been drinking, and I had to go to the bathroom. And I had to urinate. And I pulled in behind that shopping center strip mall, or whatever it was, and parked my car in a place where I saw no other cars parked and no lights on in any windows in the back of the building and no sign that there was anybody anywhere nearby. And I proceeded to urinate. And someone, a woman, turned on -- a light went on on the second floor near where I was urinating, and a woman stepped out on a porch kind of a situation or deal, and was watching me. And I finished urinating, and she was sort of smiling at me, I thought, or in some way acting kind of encouraging, I guess. And I finished urinating, and I started to walk toward her. I guess I said
something, was being friendly, I'm sure. And I thought that she had said something sort of friendly. Laughed or something, laughed in a friendly way. And then, as I started approaching her, as I started approaching the stairs that led to where she was standing, she sort of went back in. And as she did, I just, as soon as she did, I turned around and got back in my car and left.

Q. When you were speaking with the woman, was your penis still exposed?

A. It was for part of the time while I was still urinating. As soon as I finished urinating, I zipped my pants up.

Q. Did you continue to talk with her before you had zipped your pants up?

A. Yes. And it was a matter of not a conversation. I wouldn't even consider it a conversation. Like I said, I had been drinking, and I was -- I had been drinking, I would say, quite a lot. So I don't recall -- you know, it wasn't what I would call a conversation. It was a matter of like, you know, she said, What are you doing there? Or -- and laughed or something. I mean, I have no idea if that's what she said, but something just sort of in the way of a greeting of some sort. Or -- and I may have said something. I have no idea what I may have said, but it was, you know, that kind of an exchange, meeting, you know, to and fro, one cycle, and not an extended conversation in any way.

Q. Are you remembering what actually happened or are you remembering today what you would like to think actually happened on that occasion?

A. I am remembering what happened.

Q. Did you read the police report?

A. Yes, I have read the police report.

Q. Have you read what the woman said?

A. I haven't read what she said.

Q. Have you read her statement?

A. No, I haven't. I haven't seen that.

Q. She said that, with your penis exposed, you walked up the steps, came to her door, knocked on the door, asked to come inside. Did that happen?

A. No, sir.

Q. You're positive that did not happen?

A. I'm positive that did not happen.

Q. So if the woman said that and called the police, she was lying?

A. I think her -- I thought her husband or boyfriend or someone like that called the police.

Q. What was the outcome of that arrest?

A. I pled guilty. I didn't want it to be a trial. I was working as a reporter at the time, and I didn't want it to be in the paper. I went to the newspaper stand the next day to see if that story was in the paper. I was very nervous about that being in the paper, and I didn't want to prolong any jury -- any procedure. And I don't think that that statement that you just imparted was in the police report that I signed at the time of my pleading guilty.

.............

MR. RAWLS: This is a copy of Exhibit 1, Evan, except I believe there is one more copy in what I've given you than is in Exhibit 1. THE WITNESS: I did not see this at the time that I --

MR. ALTMAN: Let him ask the question. THE WITNESS: -- pled guilty.

Q. (By Mr. Rawls) Do you see that the victim and complaining person is said to be a woman in the police report?

A. Yes, I do. Yes, I do.

Q. Does that refresh your recollection as to who complained?

A. I guess so.

Q. Does the statement by the woman that you have just read refresh your recollection of the actual events that took place on that occasion?

A. No, sir, it doesn't. And like I said, if I had read this at the time of pleading guilty, I would not have pled guilty.

Q. And the statement by the woman as related by the police officer in Defendant's Exhibit 1 it's your testimony is false?

A. I'm sorry? Could you repeat the question?

Q. Have you read what the woman said to the police officer as captured by the police officer on Defendant's Exhibit 1?

A. That's this?

Q. Yes, sir.

A. Yeah, I've read that.

Q. And that it's your testimony today that is false?

A. To my recollection, that is not what happened.

Q. So you pleaded guilty to an offense of public indecency without knowing what you were supposed to have done?

A. I wouldn't say that. I guess I pled guilty to an offense of public indecency because I was -- because I had my penis exposed when a woman came out and looked at it and apparently was -- called the police.

Q. A woman whom you approached.

A. Well, from a story away and for a matter of a few steps until she went back in the house, and then I left. I certainly didn't try to grab her or reach her in time to grab her or anything like that.

Q. And that's as much as you'll admit today about something that happened in 1992 when you were very drunk and to which you pleaded guilty?

A. Well, I certainly -- yes. I want to be very clear in stating that I in no way threatened her or would ever threaten anyone with even the idea of touching them if they didn't want me to.

Q. Mr. Wolf, now let's look at what the police officer says you said to him. Do you see that in Defendant's Exhibit 1?

A. Uh-huh (affirmative).

Q. You said you were heading for a smut shop; correct?

A. I don't think I would ever use that term. I think I probably would have said a bookstore, maybe an adult bookstore, which is what I was doing, and that's what I told them.

Q. Was there not a restroom in that bookstore?

A. I assume that there may have been.

Q. How far away from where you stopped was that bookstore?

A. To me, at that time, it was an unknown distance away. And I really had to go to the bathroom.

Q. What was the bookstore?

A. Adult Palace is what it says here.

Q. I'm sorry?

A. Does it say "Adult Palace"? Did I read that?

Q. I don't know what you've read. I am asking you if you recall what the bookstore was.

A. I just knew where it was, meaning on South Santa Fe.

Q. You also told the officer you were having lots of problems; did you not, sir?

A. I told them that hoping that they would let me go.

Q. You admit you told them that?

A. (Witness nodded head affirmatively.)

Q. And, in fact, was it true that you were having lots of problems?

A. I don't think I was probably having lots of problems. I think I was probably exaggerating the ones that I was having.

Q. Why?

A. My nature.

Q. It's your nature to exaggerate?

A. To exaggerate my own plight.

Q. To exaggerate your difficulties?

A. Maybe, to myself or to -- yeah.

Q. So, in fact, you lied to the officer. You didn't have a lot of problems. You just wanted to get out of trouble, and you wanted him to take pity on you?

A. I wanted him to take pity on me, yes, yes.

Q. And you lied to him?

A. Well, I don't know. I think -- I guess having them surrounding me and asking me questions about a public indecency charge that they were threatening me with, I figured, I guess, saying I was having problems wasn't probably a lie at that point.

Q. The problem you were having that you told the officer about was that you were being arrested?

A. I think it's both of those things. And I'm not going to be able to be any more specific than that.

Q. After that episode, did you ever go back to the house or apartment of that woman complaining party?

A. No, sir. Absolutely not.

Q. Did you ever call her?

A. No, sir. Absolutely not. I wouldn't have any way of being able to if I had wanted to.

Q. Did you ever correspond with her?

A. No, sir, absolutely not.

Q. Did you ever try to?

A. No, sir.

Q. Before today, had you ever read what that woman said to the police?

A. No. My attorney, Darnay Hoffman, sent me some of this, but I don't think I ever saw this before.

Q. And you're referring to which page of Defendant's Exhibit 1?

A. "Continuation." I don't know.

Q. All right, sir. It's the page with the woman's statement?

A. Yes.

Q. All right. When did you first see some parts of that police report?

A. I got this from my attorney, Darnay Hoffman, in the mail a few months ago. A couple of months ago. I am not sure.

Q. It was this year, 2001?

A. Yeah.

Q. You never --

A. I'm sorry.

Q. Go ahead.

A. Whatever it was that I signed is not here the day I pled guilty. Whatever it was that I signed is not here.

Q. All right. What was the sentence?

A. It was a $125 fine and 13 hours of community service.

Q. Did you pay the fine?

A. Yes, sir.

Q. Did you do the service?

A. Yes, sir.

Q. What was the service?

A. Cutting the lawn for an old lady.

Q. One particular lady?

A. Yes.

Q. Who was that?

A. I don't have any idea.

Q. What was the address?

A. It was -- I think it was in Littleton. Other than that, I have no way of knowing.

Q. Before your attorney sent you parts of that arrest record, had you ever gone to the police or to the court to look for it?

A. No. No.

Q. Was anything ever published, to your knowledge, about that arrest?
A. Not to my knowledge.

Q. Did John and Patsy Ramsey write in their book The Death of Innocence about that arrest?

A. Yes.

Q. They did?

A. Well, that I had been arrested for public indecency.

Q. All right. Is that all they said about it?

A. I believe so.

Q. And that's not something you have claimed as false in their book; is it?

A. No, that's not something that I have claimed as false.

Q. Indeed, they did not even say you were convicted; did they?

A. No. Not that that makes a big difference.

Q. Mr. Wolf, when you answer my question, if it's a yes or no question, a "no" is really enough.

A. Sure.

Q. All right?

A. Uh-huh (affirmative).

Q. And what makes a big difference is going to be for someone other than you and me to figure out. Do you understand that?

A. Yes.

Q. So your editorials are not necessary. Do you understand that?

A. Yes, sir.

Q. All right. And they are also inappropriate. Do you understand that?

A. Yes, sir.

Q. Thank you. Mr. Wolf, how many of your own personal calendars or Daytimers do you keep?

A. I have a few of them from some time ago, and then I have a long period of not having any. And then I have a few of the recent ones.

Q. The ones you have, where are they?

A. In Kentucky.

Q. How many are there specifically, if you can tell us?

A. I think there are maybe two from quite some time ago, and maybe I have two or three including this year's.

Q. The ones from quite some time ago, what times are they from?

A. The middle of the '90s, I think.

Q. Middle '90s being when?

A. I don't remember the year exactly. Maybe '90. For all I know, in '92, maybe '93, maybe '94. I don't know if these three or four of them. Maybe '95, '96. I really haven't looked at those recently. If I can still find them because I moved so many times. That's why I lost the interim ones, and the other ones I have not seen recently.

Q. Those that you have in your possession in Kentucky or that you can obtain, we do want to see. We will make a formal request, if that's necessary.

A. Uh-huh (affirmative).

Q. So will you agree with me that you will not destroy and you will not intentionally lose any of those documents that are still in your possession or your ability to obtain?

A. Yes, sir.

....................moving on to a later bit

Q. (By Mr. Rawls) Mr. Wolf, in the photography job that you had in New Orleans with the Kansas City based photographer, were you taking pictures of school children?

A. No. I was taking pictures of women and couples and families. Mostly women. It was a glamour portrait company, and we -- it is kind of a fun thing for ladies to do, to do their hair and the makeup and the outfits. And just shot portraits.

Q. No school children at all?

A. Well, in that job, you know, occasionally there will be a family there.

Q. But this was not school photography?

A. No, it wasn't. But now that you mention that, I do recall now that I did have a job just prior to that job taking school pictures. And, you know, I did do -- I worked at that job for just a couple of weeks. And then I got the new job.

Q. Where was that?

A. That was in New Orleans.

Q. Who was the employer?

A. I can't remember his name, the guy's name. It was Life Touch Photography.

Q. Life Touch?

A. Yes.

Q. And were you salaried with that company?

A. Uh-huh (affirmative).

Q. How did it happen that you parted company with that?

A. He fired me.

Q. Why?

A. Because I was late.

Q. For jobs?

A. Because I was late for one job, and then a day or two later I loaded the film in backwards. It was -- really, that was my first job as a photographer except for -- that was my first job as a portrait
photographer or a photographer using a medium format or something other than 35 millimeter.

Q. Your current job is with a photography firm?

A. Yes.

Q. And what kinds of photographs do you do in that job?

A. Kids' sports teams.

Q. More kids?

A. Some, not entirely.

Q. Any kids, boys or girls?

A. Boys and girls.

Q. What ages of children?

A. Maybe 4 through, probably, 14, 15.

Q. You've held that job how long now?

A. I don't -- I think I said two months. I don't think it's been really quite two months. It's probably really been about, maybe, five or six weeks, I guess.

Q. And geographically speaking, how big is the territory that you cover in photographing these kids' sports teams?

A. Oh, I guess most of Kentucky. I've only really been on, I guess, maybe four shoots so far. I am working the lab, also.
And we just shoot on weekends.

Q. And have you yet listed with an agency in Kentucky to dance?

A. No.

Q. Or strip?

A. No.

Q. You're laughing at that. Why do you laugh at that?

A. Too old for that. Not, you know -- too old for that.

Q. That's the only reason?

A. Well, no. I probably wouldn't have wanted to do that living with my grandparents. I'm sure I wouldn't have been doing that if I had been living there, which I am. If I was -- if I was as -- if I was unemployed like I have been for -- since I moved from Colorado, and I had been living somewhere else, and I could still do it, I may well have done it, just because I need to pay the rent and eat, if that's the question you're asking me.

Q. I will certainly accept your answer, and I think it probably was
responsive. Mr. Wolf, in this lawsuit that you filed here in Atlanta, you have accused my client, Patsy Ramsey, of murder; have you not, sir?

A. I think that that is in the legal verbiage of the complaint, and I don't think I particularly did it, that.

Q. Mr. Wolf, do you or do you not claim, you, Chris Wolf, that Patsy Ramsey murdered her daughter?

A. I do not claim that, per se, but I am aware of all the evidence -- not all the evidence, even, but I'm aware of a lot of evidence that points in that direction, and I'm aware of the people on the inside of the case who believe exactly that. And I'm aware of some of the specifics of the evidence, including the handwriting matches and fiber matches and behavior after the -- after the fact, and many, many other things.

Q. Are you finished with your answer?

A. Yes, sir.

Q. So you yourself do not make any claim that Patsy Ramsey murdered her daughter; you're simply familiar with evidence?

THE WITNESS: Darnay, what should -- what do we want to do here?

Q. (By Mr. Rawls) Mr. Wolf, if you need assistance to answer, you are going to have to get that assistance after the question has been asked and after the answer has been given. Are you unable to answer that question now?

A. What's the question?

Q. It is exactly this. So you, yourself, do not make any claim that Patsy Ramsey murdered her daughter. You are simply familiar with the evidence. Is that true or is that false?

A. I make -- in this lawsuit, I am making a claim -- I am making a claim that Mr. and/or Mrs. Ramsey knew enough about the perpetration of that crime to know that I was not responsible for it prior to their writing and insinuating as such in their book about me.

Q. Are you finished with your answer?

A. Yes, sir.

Q. Mr. Wolf, do you, Chris Wolf, totally apart from something your lawyer might want to claim, intend to tell this court that you claim that Patsy Ramsey murdered her daughter? Are you willing to make that claim or are you not?

A. I don't feel like I can answer that question.

Q. The fact is, you don't know who killed JonBenét Ramsey; do you, sir?

A. I have a very good idea.

Q. And you don't know; do you?

A. As near as anyone who wasn't present at the scene can know, I, like many and many and many other people, including investigators, most investigators, have a very good idea.

Q. But you don't know; do you, sir? That was the question that I asked. Can you answer that for me?

A. Most murder trials are based on evidence that is accumulated and set out without anybody really, quote, knowing.

Q. Yes or no, please, sir. Do you know who killed JonBenét Ramsey?

A. I know who the police investigators think.

Q. Will you please answer the question, Mr. Wolf? You've danced around this long enough.

A. I can't answer it anymore than -- I can't answer your question as you're asking me.

Q. Do you know who killed JonBenét Ramsey? I want you to name that person right now.

THE WITNESS: Can I get some assistance from my attorney on this?

Q. (By Mr. Rawls) Your attorney will object if he has an objection to make, Mr. Wolf, and we have -- I've asked you that question so many times, I would like for to you answer it. If then you need to take some time and talk with your attorney, feel free.

A. I think I do.

Q. After you answer it, that's fine. It's a yes or no question.

MR. HOFFMAN: Jim, I think he's answered it.

MR. RAWLS: Thank you.

MR. HOFFMAN: I don't know how many more times you want him to answer it.

MR. RAWLS: Did he answer it yes or no, Mr. Hoffman?

MR. HOFFMAN: He said he is not capable of answering it yes or no. I think that is an answer.

Q. (By Mr. Rawls) Mr. Wolf, are you capable of answering yes or no to the question? Do you know who killed JonBenét Ramsey?

A. I don't think I'm capable of answering that question.

MR. RAWLS: All right. Let's go off the record if you need to speak with your attorney. Tell us know when you are ready to proceed. THE VIDEOGRAPHER: Off the record at 1:35. (A recess was taken.) THE VIDEOGRAPHER: On the video record at 1:47.

Q. (By Mr. Rawls) Mr. Wolf, did you have an opportunity to speak with your attorneys --

A. Yes, I did.

Q. -- during the break? Was that a sufficient opportunity for you to do so?

A. Yes. He answered the specific question that I had to ask him.

Q. Good. I am glad. Is there any change you would like to make in your previous testimony as a result of that conversation.

MR. ALTMAN: Could you repeat the question, the last question that was asked?

MR. RAWLS: The last question before the break? I believe so. Actually, I should read off of yours, Lin.

Q. (By Mr. Rawls) The question was, "Mr. Wolf, are you capable of answering yes or no to the question, Do you know who killed JonBenét?"

A. Yes, sir. I am capable of answering yes to that question because I have a number of different handwriting experts who will testify that Patsy Ramsey is the author of that ransom note, that bogus ransom note that was found in the house that day of the murder. And Mr. and Mrs. Ramsey have both said on national television that they would agree that the author of the ransom note is the murderer.

Q. And so you do know who killed JonBenét Ramsey?

A. Yes, sir.

Q. And that is?

A. Patsy Ramsey.

Q. And you have made your views known to the authorities; haven't you, sir?

A. Yes, sir.

Q. And you do --

A. Well, incidentally, when they were investigating and interrogating me about -- as a straw suspect.

Q. Who thought you were a straw suspect, you or they?

A. Both.

Q. And, Mr. Wolf, do you, as a result now of having conferred with your counsel, claim in this lawsuit that Patsy Ramsey killed her daughter JonBenét Ramsey?

A. Yes, sir, I do. And I needed to confer with my attorney as to whether I was libel for -- libel in making such a statement.

Q. Well, Mr. Wolf, it's never necessary for you to tell me what you spoke with your attorneys about. All right?

A. Okay.

Q. And I do not wish to know, okay? Because that is privileged.

A. Okay.

Q. All right? And you are entitled to hold that back.

A. Uh-huh (affirmative).

Q. (By Mr. Rawls) Mr. Wolf, I'm handing you two pages that are marked

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Defendant's Exhibit 2. Do you recognize the first page?

A. I'm sure I know who wrote it and who I wrote it to.

Q. Did you write it?

A. Oh, yeah.

Q. Is that your handwriting?

A. Yes, sir.

Q. Is that your signature, "Chris Wolf"?

A. Yes, sir, it is.

Q. And "Hi, Carol" is what you wrote; is that correct?

A. Yes.

Q. Wasn't this something that you wrote to Carol McKinley?

A. Yes.

Q. And did you enclose to Carol McKinley the next page of Defendant's Exhibit 2?

A. Yes.

Q. Did you author that page of Defendant's Exhibit 2?

A. Yes.

Q. You said at that time that you

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did not know what happened the night the little girl was killed. Is that true at that time?

A. That was true, and that's -- yes, that was true.

Q. When did you send this to Carol McKinley?

A. I wish I knew that. I have been trying to think. This must have been -- this was -- I was still in Colorado. This was, ah, sometime in -- sometime in 1998.

Q. And in this --

A. I think.

Q. Are you finished?

A. I'm trying to remember. I wish I had put a date on it. Yeah, ah -- yeah this was sometime in 1998 and probably not very late in 1998.

Q. You were accusing Burke Ramsey of the murder in this document; were you not, sir?

A. I don't think I was accusing Burke Ramsey of the murder in this document.

Q. You said that Burke Ramsey "is no normal 11-year-old," did you not?

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A. Yes, I did.

Q. You said, "he is a bizarre and alienated version of the same who has seen far too much in the way of video atrocities and real life opulence at far too young an age to know what respect for human life means." Is that what you said?

A. Yes. That's what I wrote.

Q. You said it was a tragedy for the Ramseys to lose their daughter, did you not, no matter who killed her?

A. Yes, I absolutely wrote that. And, of course, I believed that then and I believe that now. There's an important part of this previous sentence that you were quoting that you didn't -- the end of the sentence, the same sentence says, "regarding Burke" this, that, and the other, and not that he's the only one.

Q. Yes, sir. You wrote this entire page?

A. Yes, I did.

Q. You wrote the things I read, and you wrote the things I haven't yet read?

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A. Yes, if you are going to read from this.

Q. As a matter of fact, you also wrote that, if Burke did the murder, that didn't necessarily mean that the Ramseys were innocent?

A. That's right.

Q. You wrote that John Ramsey is one of those who had been called the merchants of death; did you not?

A. Yes, I wrote that.

Q. And you spoke of Dwight Eisenhower's warning. Were you talking about warning of the military industrial complex?

A. Yes.

Q. And you felt that John Ramsey was part of the military industrial complex --

A. Yes.

Q. -- is that right? When did you come up with that point of view?

A. When I heard that Mr. Ramsey's company was owned by Lockheed.

Q. When did you hear that?

A. Was it Lockheed? I think it was

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Lockheed. Somewhere along the line sometime prior to this when I wrote this. Sometime in or before 1998.

Q. You accused John Ramsey of having sex with JonBenét Ramsey in this document; did you not, sir?

A. Well, I don't know. I haven't read that, and I haven't read this for a long time. And --

Q. Well, take a look and take your time, please.

A. And, sir, I want to be clear that this was a personal correspondence, not a letter for publication.

Q. Personal correspondence to a reporter for whom?

A. FOX TV, but -- FOX News Channel.

Q. A local news television station in what city?

A. In -- well, it's a national network, and she is a reporter in Denver, but this is -- they don't -- FOX, obviously -- well, you know as well as I do that FOX doesn't have a TV -- no TV news has a forum for reading a letter like this, or -- and

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that this is not -- this doesn't say, Dear Editor and -- well, it's clear that this is a personal correspondence as opposed to a letter to the editor.

Q. And did you, in this letter, accuse John Ramsey of having had sex with his daughter, JonBenét Ramsey?

A. I don't know. Where is that part?

Q. I think you should go to the third paragraph from the bottom to refresh your recollection.

A. Well, you might read that into that commentary, but I don't think there is any direct accusation.

Q. Well, did you or did you not intend to accuse John Ramsey of having had sex with his daughter, JonBenét Ramsey?

A. I did not intend to accuse Mr. Ramsey of having sex with his daughter.

Q. And you made no such claim in this case?

A. I don't make any such claim, but I think that there's a coroner's report that suggests vaginal trauma.

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Q. Do you claim in this case that Patsy Ramsey took actions that caused the vaginal trauma to her daughter, JonBenét Ramsey? Do you claim in this case that John Ramsey did so?

A. I don't think our complaint suggests any of that, or I don't think that's part of our complaint or our case.

Q. If it is, you would disclaim it at this time; would you not, sir?

A. Well, if it's part of our complaint, I would not disclaim it.

Q. Do you care whether it's in there or not, Mr. Wolf?

A. My primary concern is what they said about me.

Q. Do you care whether it's in there or not, Mr. Wolf?

A. If it's important to our case, I -- there's no care about whether it's in there or not. There is nothing -- I don't care one way or another if it's in there or not.

Q. It doesn't matter to you whether Patsy Ramsey or John Ramsey or somebody else

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took action that caused vaginal trauma to JonBenét unless it helps your case; is that what you're telling us?

A. I don't think that that is necessary for our case. The vaginal trauma is not part of our case.

Q. Mr. Wolf, when did you change your mind and decide that Burke Ramsey did not kill JonBenét Ramsey, but Patsy Ramsey did?

A. I don't think I ever thought that Burke Ramsey killed JonBenét Ramsey. I thought that it was a possibility at one time. I thought it was a possible scenario.

Q. When did you decide that Patsy Ramsey murdered her daughter?

A. I think that was a -- kind of an evolutionary process of hearing bits and pieces of evidence in the media and, not in the least, the evidence offered by many respected handwriting experts.

Q. Which ones?

A. Cina Wong and -- oh, others that we have in our complaint. Former FBI handwriting experts. Not to mention lots and lots of commentary and -- by respected

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coroners, and the police investigators who spent a lot of time on the case, and the police who were first on the scene and --

Q. And to get back to the question I asked, when did you decide that Patsy Ramsey murdered her daughter?

A. I guess sometime in -- sometime in 1998.

Q. Mr. Wolf, you claim that you did not murder JonBenét Ramsey; is that correct?

A. Yes, sir.

Q. You claim that you should never even have been considered a suspect in connection with the death of JonBenét Ramsey; is that correct?

A. Yes, sir.

Q. You claim you're not a violent man.

A. Yes, sir.

Q. In fact, physical violence is not something you have ever done. Did I understand you to say that earlier today?

A. Did I say that earlier today? I've said that many times in discussions about this case. I have -- I think that's a

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-- I have been in fights with boys when I was in -- one that I recall in 6th grade. One I recall in -- when I was a senior in high school. And I think one when I was in college. And ever since then, I have never hit anyone. I have never struck anyone. I have -- and aside from those three cases, I, all my life growing up, I have never struck anyone. I have never harmed anyone in any way physically.

Q. And, in fact, I believe you make the claim you are not capable of murder; is that correct?

A. Yes, I make that claim.

Q. Have you ever threatened anyone's life?

A. Absolutely not.

Q. Have you ever threatened anyone with physical violence?

A. Well, I said I've engaged in physical violence on rare occasions when I was very -- when I was very younger. Since I was maybe 20, maybe 22, I cannot recall engaging in physical violence against anyone.

Q. When you got fired from the

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Louisville Times -- What's the gentleman's name who fired you?

A. Doug Conarroe.

Q. Sorry?

A. Doug Conarroe.

Q. -- you did not threaten his life?

A. Absolutely not.

Q. You did not threaten the life of anybody there.

A. Absolutely not.

Q. In fact, no employer who has fired you has heard you threaten his or her life?

A. Absolutely not.

Q. You've never threatened Jackie Dilson?

A. Absolutely not.

Q. Ricky Elsey never had to chase you away with a baseball bat to end an angry confrontation involving your threats to Jackie Dilson; did he?

A. Ricky Elsey picked up a baseball bat and attempted to threaten me with it, but I had no weapon. We were arguing verbally, Jackie and I. I was in no way threatening

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her.

Q. And he picked up the bat and forced you to leave; did he not?

A. I told him to put the bat down, and I would leave, you know, when I -- when I was ready to, and I did, eventually, after we had discussed further things that we needed to discuss.

Q. Did he put the bat down?

A. Yeah. He --

Q. Did your anger subside after he picked up the baseball bat?

A. Yes.

Q. Mr. Wolf, you have sued the Ramseys in this case in part because of their having hired private investigators to investigate you; have you not, sir?

A. Yes, sir.

Q. And I want you to tell us about what actions were taken by the private investigators that you felt are inappropriate, as far as you are concerned, in their efforts to learn information about you.

A. I think we're waiting on you all to provide us with most of that information.

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They are the spooks and private investigators, and I am not accomplished or proficient at identifying them and keeping track of what they are up to in tailing me or whatever else they did as far as investigating me.

Q. Obviously, all you can tell us, Mr. Wolf, is what you know. And I want to know what you know about conduct by private investigators hired by the Ramseys that you felt was not appropriate that caused you to bring a lawsuit about it. If you don't know of anything, you can tell me that, and that will be that.

A. Well, they came to my place of residence, and I thought that that was inappropriate.

Q. What else?

A. I suspect that they broke into my car. Someone did, without leaving much of a trace, but enough that I could notice. To whatever the degree they were investigating me, they were supplying information about me, personal information, that was basically being used to try and frame me for murder in the absence of an

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aggressive prosecution. The vacuum left by the failure of the district attorney's office and the district attorney's office going way overboard to continue to consider me a suspect was a de facto -- resulted in a de facto attempt to frame me for that murder. Now, they also -- when I was still at Jackie's house in 1997, we got prank phone calls. We got a -- she had break-ins and -- with a -- and we got a -- she got a phone call saying that I was making pornographic movies at her house, and how did she feel about that, which is untrue. And -- but it certainly didn't -- it certainly did serve to divide the two of us and make her more willing to, I guess, or interested in being suspicious of me or being angry at me, being willing to work against me.

Q. Are you finished?

A. And her house was broken into on a couple of occasions, I guess, with the intent of making her think that it was me. Someone came through the house, you know. Jackie and her daughter told me that people had broken in and come walking

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through the house and run away when they -- something. I don't know. I didn't really quite get the whole story.

Q. Are you finished with your answer?

A. Yes, sir.

Q. When did one of the Ramseys' private investigators come to your place of residence?

A. I think that was -- oh, gee. I think that was in 1997.

Q. Who came?

A. Ellis Armistead. Not him, but someone working for him, or I think it was two people. I wasn't there. I was given business cards from my roommate. He was there.

Q. So the people who came left business cards?

A. Yes.

Q. Were they rude?

A. I didn't hear that they were rude, and I assume that they weren't.

Q. Did they make any threats?

A. I assume not.

Q. Well, what was wrong with those

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two people coming to your place of residence in 1997 that caused you to file a lawsuit?

A. I don't think that that's the main reason I'm filing a lawsuit.

Q. Well, was anything wrong with anybody coming to your house in a courteous manner asking if you were present and leaving business cards?

A. I think it is wrong. I think it was wrong. I think that Ellis Armistead should have left the investigation to the police department.

Q. All right. Did --

A. Not to work for the primary suspects in the murder.

Q. All right. If you were running Ellis Armistead's business, you would have suggested that he not take that particular assignment. Is that what you are telling us?

A. Yes, I would have suggested that.

Q. How upset did you get, or what trauma did you suffer, if anything, when these two individuals came to your place of residence?

A. I was quite upset.

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Q. You were angry?

A. I was upset. I was nervous. I was scared.

Q. Well, did you pick up the business card and call them back and ask them what they wanted?

A. No, sir.

Q. With your answer just now, Mr. Wolf, were you exaggerating so that anyone watching this deposition might feel pity for you, or was that a true bit of testimony on your part?

A. That's a true bit of testimony on my part.

Q. Who broke into your car without much of a trace?

A. I don't know, but I only know who would have had a reason to want to.

Q. What was taken from your car?

A. Nothing.

Q. How do you know that your car was broken into?

A. Because there was kind of a mark that may have been -- it looks like it may have been left by kind of a rubber pad of

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some sort used to brace against the door handle while jimmying the lock or sliding a -- sliding a, one of those things that opens a car door down the window.

Q. What was missing from your car?

A. Nothing.

Q. What was disturbed inside the car?

A. I thought I noticed -- when I saw the mark on the outside of the car, you know, I mean, I immediately noticed it. It was about three or four inches long and, obviously, had been put there by something being pressed against it pretty -- with a significant amount of pressure. And, you know, it wasn't there the day before. I noticed it the first thing when I went out there that morning, and that was sometime in late -- in the fall of 1997, I think. And I think it was around fall or late 1997. But -- and I noticed it immediately, and then I got in the car and looked around, and it looked like things had been sort of kind of moved or something to me.

Q. Did you call the police about

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that?

A. No, sir. I didn't really -- I considered it, and at that point I was really -- the police were the last people I wanted to talk to at that point because of what they had already done to me.

Q. And you're accusing a private investigator for the Ramseys of breaking into your car based on what you've just told us?

A. I'm not accusing them. I am saying that I suspect them of that. I don't know who else would have done -- would have had a reason to do that or why else something would have transpired in the way that it appeared that my car had been entered and nothing was taken.

Q. Now, are you accusing any private investigator for the Ramseys of making any prank phone call to Jackie Dilson's house?

A. Again, I don't know who else would have reason to do that, and that had never happened to her or me prior to the period of time right after the murder of the child.

Q. Mr. Wolf, what reason would a private investigator for the Ramseys have to
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make a prank call to Jackie Dilson's house?

A. To divide her and I so she would be more willing to be a witness against me or a -- or assist them in investigating me, or, as I said, in a de facto way framing me, attempting to frame me.

Q. When did those prank phone calls take place?

A. Sometime in -- I think that was sometime in 1997.

Q. You have not, in fact, cohabited with Jackie Dilson since 1997; have you, sir?

A. That's not true. I have. And moved out for a period of time, and then I moved back in.

Q. But when you moved back in, you didn't get prank phone calls from any private investigators for the Ramseys; did you, sir?

A. Not that she told me about.

Q. And when was Jackie Dilson's home broken into twice?

A. It may have been three or four times. I was only -- I was only told about those incidents by Jackie and her daughter. And that was in -- when was that? That may

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have been -- that may have been by 1998. I think that was. I remember hearing about that. I think that was in 1998 and maybe even into -- yeah, that was -- maybe even into -- maybe even into the following year, 1999.

Q. And are you accusing one or more private investigators employed by the Ramseys of breaking into Jackie Dilson's house?

A. I'm not accusing them of that. I'm just suggesting that. I don't know why anyone else would have done such a thing as that. And I think that it makes sense as an MO.

Q. It makes sense to whom?

A. To me.

Q. And what was that MO? Explain it to me so it will make sense to me, please.

A. The MO being to divide Jackie and I from each other and make her suspicious of me. Make her more willing to or interested in considering me as a violent or dangerous person. Make her more willing to reveal unflattering or defamatory or useful information about me for people who were

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trying to, at least in the minimum, deflect suspicion away from themselves towards me, if not to try and frame me.

Q. And the other thing I believe you testified about that you consider steps by the Ramseys private investigators to which you object was supplying personal information about you. And I want you to tell me what personal information about you was supplied by the Ramseys' investigators to whom that you're complaining about.

A. Well, I think that we are hoping to find that out in our discovery process.

Q. So the answer is you do not now know of any such information; is that true?

A. I do not know of any, but I find it beyond comprehension -- I'm quite -- I'm quite sure that Ellis Armistead supplied the Ramseys with something in the way of information about me.

Q. You don't know whether that information was true, whether it was false, or even what it was in any part; is that correct?

A. No, I don't. That's true. I

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don't. I'm hoping to find out in this discovery process.

Q. Your complaint complains about severe emotional distress, Mr. Wolf. And what's the worst emotional distress that you have suffered as a result of something done by one of the Ramseys' private investigators or by several of the Ramseys' private investigators, sir?

A. Well, I think the main point of the severe emotional distress, which I certainly felt like I suffered, and continue to as a result of all this, was the -- resulting from the Ramseys publishing their book about the murder of a six-year-old girl, their own child, suggesting to an international audience that I could -- that I am a person who could conceivably have been responsible for such a crime as that. That's been the most severe emotional distress that I've experienced.

Q. And to go back to my question, what is the most severe of any emotional distress that you can tell us about today that you suffered as a result of something a

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private investigator hired by the Ramseys did, sir?

A. I guess just putting me on notice that I was being watched.

Q. Were you ever interviewed by one of the private investigators for the Ramseys?

A. No.

Q. Were you ever followed?

A. I have to assume that I was.

Q. You don't know?

A. No.

Q. Did they come into your place of employment and ask questions about you?

A. Not that I know of.

Q. Did they go through your trash?

A. Not that I know of.

Q. Did they talk to your parents?

A. Not that I know of.

Q. Did they talk to your sister?

A. Not that I know of.

Q. To your brother?

A. Not that I know of.

Q. Is there anything you know of that any Ramsey private investigator did that took place after 1998 and involved you?

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A. Not that I know of, but I'm hoping that we'll have a successful and credible discovery process and find out to what degree, because if the Ramseys published their book in 1999 saying that they still thought and went on national television saying that there were unanswered questions about me, well, I assume that they were still interested in finding out what they could about me.

Q. Mr. Wolf, do you expect to learn in the discovery process about any additional emotional distress you have suffered as a result of something the private investigators might have done?

A. No. I have already experienced all of that.

Q. Okay. That's probably behind you at this time.

A. I don't think so.

Q. You are still suffering from these things that the Ramseys' private investigators did that you told us about; is that your testimony?

A. I think in a residual way, yes.

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It is quite a terrible, terrible thing to have people saying that you are someone who they suspect could be responsible for such a horrible crime as that.

Q. And one of the persons who says that about you is Jackie Dilson; is that right?

A. Apparently.

Q. And that's a pretty difficult thing for you to know; is it not?

A. Well, I -- I have a -- you have to know her to -- it was hard for me to come to grips with the fact that she could have done that, but once I did realize once and for all that she had been saying such things as that, really, it kind of made sense to me. She's got severe -- I don't want to say severe, but she's got pretty significant psychological problems. Not to say that she is not a nice person and was a good friend of mine and someone that I liked quite a lot, but she's -- she is not really -- she is kind of in another world sometimes.

Q. As a matter of fact, you have told many people that she had significant

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problems because you wanted them to disbelieve Jackie Dilson; haven't you, sir?

A. I have tried to say that as few times as I possibly could. In fact, I've never, to my knowledge, said that to any media persons. I have said that to only the most critical people involved in investigating me, meaning --

Q. The police?

A. -- the police. Yeah, the police. And the police knew that; they didn't need me to tell them that.

Q. But you were glad to help?

A. Well, I was trying to explain why, just like many of the other people that were interviewed as suspects in this, or that were interviewed by the police, just like many of the other -- some of the other people who were interviewed by the police regarding this crime were required, felt compelled to explain their domestic situation and why their domestic partner or someone in their life might be inclined to want to cast suspicion on them for their own vindictive reasons.

Q. Mr. Wolf, as a matter of fact,

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you took actions repeatedly after the murder of JonBenét Ramsey to try to rattle Jackie Dilson, to try to shake her, to try to make her nervous so that she might believed to be crazy; didn't you, sir?

A. No.

Q. Repeatedly you did that?

A. No, sir.

Q. You broke into her house, didn't you, sir --

A. No, sir.

Q. -- to try to do that?

A. No, sir.

Q. And the reason that you said earlier today that there were break-ins and the persons who broke in tried to make it look like it was you is it was you; wasn't it, sir?

A. Absolutely not.

Q. Because the more you could rattle her, the less somebody might believe her. Wasn't that your thinking?

A. Absolutely not.

Q. Let's talk about --

A. I never have broken into anyone's

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house, never in my life.

Q. That's something else you're not capable of?

A. I've never broken into anyone's house.

Q. As a matter of fact, you asked Ricky Elsey to tell you how to break into houses; didn't you, sir --

A. No, sir.

Q. -- without leaving a trace?

A. No, sir.

Q. And he told you how to break into houses, didn't he, sir --

A. No, sir.

Q. -- without leaving a trace?

A. I never asked him that, and he never told me that.

Q. And you knew he knew that because he had done that as a military officer?

A. I did not know that.

Q. When did you first learn, Mr. Wolf, that the police were interested in you in connection with the murder of JonBenét Ramsey?

A. I guess that was maybe three to

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five weeks after the murder, as best that I can recall.

Q. What happened?

A. That is quite a kind of a long story, and I sort of wondered why they didn't go through the whole circuitous trail of events and setups in order to get the Ramseys to come in to talk to them about the murder.

Q. Mr. Wolf, I have not asked you what you wondered about. All right, sir?

A. Yes, sir.

Q. My question is very simple. It is, what happened?

A. It's a long story.

Q. Would you answer that?

A. Okay. Sometime within, like a couple of, few weeks after the murder, I was driving north on 28th Street when I was pulled over by a state trooper. He asked me for my license, et cetera, went back into his Bronco and sat there for a long period of time, probably at least 20 minutes; and then came back to my car and told me, You need to come sit in the car with me. So I went and sat in the passenger seat.

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And I was just -- I was very cooperative. He was late, and he was really -- you know, I had been there for probably a half an hour by then, but I was just cooperating with him. I just didn't know what in the heck was going on. And he said -- he finally said, You've got an outstanding ticket, a speeding ticket from the State of Illinois from nineteen-eighty -- from 1987 or '89 or -- I don't know when. A long time ago. And he said, you're going to surrender your driver's license to the Department of Motor Vehicles tomorrow because of that. And so I said -- I said I was surprised; but nonetheless, the next day, I think it was the next day, and it seems like, or I am trying to think, maybe it was the following day, because I had something I had to do all day the next day, and I told him as such. But whatever the case, within 48 hours I went into the Department of Motor Vehicles and surrendered my driver's license. And -- well, I mean, I lived what, ten miles outside of town, and I had a job in town.

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And I certainly needed to drive to work. So I continued driving to work. And, so, within a few days after that, I was driving into town, and I came down Foothills Highway, turned onto Broadway, and passed an officer. I was going under the speed limit the entire way. The speed limit changes from 55 to 45 at one point, and I was going -- I was going about 45 by the time I hit the sign. And then a couple hundred yards further on up the road, I passed the police officer sitting there taking radar, and as soon as I went past her, she pulled out and tailed me, and her lights went on almost immediately. I pulled over. At that point, I was not very happy because this is the second time in about four days I had been pulled over. And this -- for nothing, once again, because I wasn't speeding.

Q. You were merely driving without a license?

A. Yes, I was driving without a license.

Q. All right. Keep talking, please.

A. And she asked me, you know, she

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said, You know, you're speeding, which, of course, I said, Well, I don't think I was speeding. And she said, Can I see your driver's license? And I said, No, I don't have a driver's license because I just had to surrender my driver's license. And she said, Well, we're going to have to take you to jail. And she said, Park the car over there, get out of the car, we'll put the handcuffs on you. And she put the handcuffs on me, threw me in back of the squad. She took me downtown, pulled me into an interrogation room where I found Thomas and Gosage. And they said, Do you want to help us with this murder investigation -- help us with this investigation. And they pushed a piece of paper at me saying, you know, saying words that were included in the ransom note. They said, do you want to copy these words down for us. And I said, No, I don't really want to. So they took me to jail, put me in jail for about 45 minutes. They said they were going to charge me with obstructing

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a police investigation. And I said, Well, okay; we'll see how far that goes. So then, you know, within 45 minutes, they let me out and I walked out of there, and that was the end of that. About, within, about a week later, I went back to the police department, and I said, I would like to talk to Thomas and see my -- see that police report. And so I went in and sat with Thomas and John Eller, at which time John Eller said to me, We have no interest in you as a suspect in this case. So that was five weeks -- that was within two months after the murder. And ever since then, as far as I know, that's all I've heard is I am not a suspect. And Tom Whitman has told me that and Michael Kane has told me that and John Eller has told me that and Steve Thomas has told me that and Carey Weinheimer has told me that.

Q. Mr. Wolf, did the police have to get physical with you?

A. They felt like they had to get physical with me.

Q. What did you do that caused them

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to do that?

A. I told them that they are way out of line, and I turned my back when they tried to take a Polaroid photograph of me.

Q. That's all you did?

A. That's all I did.

Q. In fact, you shouted you --

A. After they started twisting my hands around in the handcuffs, I shouted.

Q. You got angry with them.

A. After they were banging me up against the wall, I got angry with them.

Q. You got physical with them?

A. No, sir.

Q. And they hobbled you; didn't they?

A. I never got physical with them. I never threatened to strike or kick any police officer.

Q. Because you are not a violent person?

A. Exactly.

Q. But they hobbled you; didn't they?

A. Yes, they did.

Q. All right, sir. Tell us about that. What did they do to hobble you?

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A. That's when they put your hands in handcuffs and put your feet in handcuffs and wrap the handcuffs around each other.

Q. You couldn't move?

A. Exactly.

Q. All right, sir. And that's because you were obstructive?

A. Is that because I declined to fill out a piece of paper with handwriting analysis on it?

Q. Not only did you refuse to give a handwriting sample to the police, you refused to answer their questions; did you not, sir?

A. That's right, I refused to answer their questions.

Q. You did obstruct a police investigation into the death of JonBenét Ramsey.

A. I don't think I obstructed a police investigation.

Q. You simply refused to comply with the police investigation?

A. At that time, yes.

Q. All right, sir. You since learned that the people who spoke to the police about

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you were not the Ramseys and were not private investigators for the Ramseys, but it was no one other than Jackie Dilson. Haven't you learned that, sir?

A. I have learned that that's where it started.

Q. All right, sir. Now, you have not told us the whole story of your involvement with the police, have you, because you haven't told us about going back to the police and providing other samples; have you, sir?

A. No. You haven't asked me about that.

Q. The fact is that, at the urging of a reporter named Jeff Shapiro, you went back to the police about a year later?

A. No. Jeff Shapiro had nothing to do with that.

Q. All right. Why did you go?

A. Because they came to my place of employment and left their card. I wasn't there. And I called them. This is in April, I believe, of '98. And they left cards, and I hadn't talked to them since the time that

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I came back, a week after I had originally been taken in. And they left their cards, and I called them back, and they said, We'd like you to provide us with this non-testimonial evidence. And I said, I'll call you back and tell you whether I want to do that or not. And I called them back in five minutes and told them I would do it today, that afternoon, which I did.

Q. What did you do in that five minutes?

A. Thought about it.

Q. Did you talk to Jeff Shapiro?

A. No.

Q. Who left cards in April 1998?

A. I can't remember, but I guess it was Carey Weinheimer, because he is the one that I talked to when I went in there.

Q. Don't guess if you don't know. Just tell me what you do know.

A. I don't know. I don't know whose cards they were.

Q. How many cards were left?

A. No, I'm sorry. They didn't leave cards. The -- Ellis Armistead left cards.

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Excuse me. I'm wrong. The police did not leave cards. They just -- the guy I shared the office with told me that there were a couple of guys in suits there who looked like they might be cops. And, of course, he was right, and, of course, at that point I knew exactly who they were and I knew that he was right and I called the police.

Q. Well, how did you know who they were if all that he told you was guys in suits?

A. He told me they were -- well, because -- I guessed correctly.

Q. Mr. Wolf, you just testified that a year earlier you were told that the police had no interest in you, but a year later guys in suits show up and you know they're police? Were you feeling a little guiltier about this than what you told us?

A. No, it's not because of that at all. It's because of the nature of the investigation. The investigation was really being obstructed from your client's end, and that's well-documented also.

Q. And that's why you thought guys in

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suits who showed up in April of 1999 were police?

A. Yes. And I had been listening to the talk show and I'd been reading the paper, and I knew that the investigation was still ongoing and searching far and wide for anybody other than the prime suspects to interrogate and, hopefully, I guess, apparently frame.

Q. Well, at this time, was your prime suspect Burke or Patsy or John?

A. At that time, it was a matter of me being quite convinced that it was somebody who lived in the house.

Q. And when you talked to the police after calling, you called the police without a phone number. All you knew was guys in suits had come by.

A. I looked her phone number up.

Q. And you spoke with who exactly?

A. I think I may have asked for Thomas and got Thomas, and then Thomas said, Why don't you talk to Weinheimer.

Q. Did you ask Thomas if he had changed his mind about having any interest in

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you?

A. I didn't get into a long conversation with him. I didn't ask him for anything that I knew he wasn't going to tell me.

Q. You then talked to Officer Weinheimer?

A. Yes.

Q. And what did you say?

A. I can't remember what I said. I guess I just said, I'm here to provide the evidence that you are requesting of me, and let's go ahead with it.

MR. RAWLS: All right. Let's take a short recess. THE VIDEOGRAPHER: We are off the video record at 2:41. (A recess was taken.) THE VIDEOGRAPHER: We are on the video record at 2:58.

MR. RAWLS: Mr. Wood would like to make a statement. THE WITNESS: Darnay, are you back with us?

MR. HOFFMAN: Yes, I am.

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MR. WOOD: Yes. I want to just simply state on the record, because I think it is important for purposes of preserving this record and the accuracy of the record from a contemporaneous standpoint, I just got off the phone returning a message from a Carol McKinley at FOX News, and I have learned from Carol McKinley that you have literally, during the course of this deposition, already telephoned her, contacted her, and discussed with her testimony that has been given here today by Mr. Wolf, and I think the record ought to note your involvement in discussing this deposition with the media literally while the deposition is ongoing. So I have just had that conversation with Carol McKinley in the last five minutes, and I think the record ought to reflect your conduct in that regard. Particularly --

MR. HOFFMAN: However, I --

MR. WOOD: I'm not through yet, please.

MR. HOFFMAN: -- on the record.

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MR. WOOD: Excuse me. Excuse me. Darnay. Darnay? Darnay, I am not through, yet, please. Don't interrupt me.

MR. HOFFMAN: All right.

MR. WOOD: And then you can talk ad nauseam if you choose to do so without interruption. I think that it is important for the record to be clear at this point in time, because of the fact that concerns about this very type of activity are presently pending before Judge Carnes, and this may, obviously, have some bearing on the decision she has to make in the future. So I've made my statement. You may now speak, as I said, ad nauseam, should you choose to do so.

MR. HOFFMAN: I am not going to comment on that particular statement. Because I don't even know what you talked about with Carol McKinley or with anyone else.

MR. WOOD: Do you deny calling her?

MR. HOFFMAN: I would like to say --

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MR. WOOD: Do you deny calling her?

MR. HOFFMAN: I'd like to say, for the record, that I do know that I got a call from Carol McKinley, I think, either yesterday or the day before to the effect that she had been approached by attorneys for the Ramseys with respect to getting her correspondence, and that she referred the matters to the lawyer. And the other thing that she had contacted me about with respect to that also was if you, in fact, did have correspondence, that the only place she felt you could have gotten the correspondence was from the grand jury; that that's the only place that correspondence of hers could have gone, which was to the grand jury, so that you are in possession, theoretically, of the grand jury material.

MR. WOOD: Do you deny calling her today and discussing with her substantive --

MR. HOFFMAN: I spoke to her earlier today.

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MR. WOOD: Excuse me. Did you discuss with her today substantive discussions of Mr. Wolf?

MR. HOFFMAN: I spoke to her earlier today, but I did not talk to her about any testimony going on in this deposition.

MR. WOOD: You did not discuss with her today any testimony by Mr. Wolf about the letter that he presented to her. Is that what you are stating on the record here in your place, Darnay?

MR. HOFFMAN: Yes, that is what I am saying.

MR. WOOD: All right. Then we will have to let you and Carol decide who is telling the truth on that issue because that's not what she just talked to me about.

MR. HOFFMAN: Well, I'm sorry if that's what she told you, but that's not what I told her.

MR. WOOD: Did you talk to her today?

MR. HOFFMAN: I talked to her earlier today.

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MR. WOOD: During the deposition?

MR. HOFFMAN: At one of our breaks.

MR. WOOD: After Mr. Rawls had questioned your client about the letter that he sent to Carol McKinley?

MR. HOFFMAN: I'm not really sure exactly what time. It was after the lunch break, but I don't know exactly at what point.

MR. WOOD: Did you discuss with her the letter?

MR. HOFFMAN: This particular letter, this particular deposition? No. But she had raised the issue of correspondence a day or two earlier, so there was a discussion with her about correspondence between Chris Wolf and Carol McKinley.

MR. WOOD: I made my --

MR. HOFFMAN: And I do know that was something that was on her mind and that was something that she was discussing with me, but it wasn't today.

MR. WOOD: Well, I've made my statement for the record. And to the extent

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the court has to inquire upon it further, the record speaks for itself at this point. Let's move on.

MR. HOFFMAN: The record will reflect that.

MR. WOOD: Yes.

Q. (By Mr. Rawls) Mr. Wolf, when you went back to the police in April 1998 at the request of the police, what took place, sir? Were you read your rights?

A. Not that I recall.

Q. Do you recall being read your rights in 1997 by the police?

A. Not that I recall.

Q. What non-testimonial evidence did you provide in April 1998?

A. Handwriting, saliva, hair, and palm prints.

Q. Did you take a polygraph test?

A. No, sir.

Q. Have you at any time taken a polygraph test in connection with the death of JonBenét Ramsey?

A. Not regarding this case or any time in my life have I taken a polygraph

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test.

Q. Have the police ever suggested or requested that you do so?

A. No, sir.

Q. How much of a handwriting sample did you give the police?

A. Lengthy, single spaced, I think. I think it must have been at least five pages, and they were legal pages.

Q. Did you write it on that occasion in April 1998?

A. I wrote it as I sat there in front of Detective Weinheimer.

Q. Did you bring them any other handwriting samples of your writing?

A. No. But they already had lots of that.

Q. How do you know that?

A. From reading and discussing this, discussing the investigation with people. I know that they -- I know that Jackie gave them -- not only that, but, you know, my jacket and my computer. I've read that -- I think that that's in Steve Thomas' book. Maybe it's in Larry Schiller's book. I don't

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know. I've read that somewhere.

Q. Where is your computer now?
A. In Kentucky.

Q. You have it among your personal effects?

A. Yes.

Q. We will be requesting that, so could you please not destroy anything that's on it now?

A. I won't. And I had erased a number of -- lots of business articles, and Jackie was all, I guess, suggesting to people that that was part of the reason she thought that I was involved in this crime, because I was busily erasing old business stories. But I do believe that they are backed up there, and anybody that knows much about a computer will be able to see everything that's ever been on that computer. There is no internet access on that computer, never has been, for the record.

Q. Did you provide the police in April of 1998 any fiber samples?

A. No, not -- no.

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Q. At any time?

A. Fiber sample? I don't know. No.

Q. Did you ever, in 1997 or 1998, or any other time, give any of your clothing to the police?

A. No. I never did, but, again, I understand that Jackie did.

Q. Mr. Wolf, it's only necessary for you to answer the question that I asked you. All right? And I asked you about your conduct, not what you suspect about others. Do you understand that?

A. Uh-huh (affirmative).

Q. Do you understand that?

A. Yes, I do.

Q. And did the police ever request that you provide any clothing to them at all at any time?

A. No.

Q. Not your blue sweater?

A. They didn't ask me for any clothing. I think I've read that they have -- that they have a sweater of mine.

Q. Mr. Wolf, I'm not asking what you have read about. I'm asking what the police

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requested from you. Did they request you to bring them your blue sweater?

A. No, they never asked me for that, that I can recall.

Q. Did they request that you bring them any black jeans?

A. They did not request that I bring them any black jeans or any other articles of clothing that I can recall.

Q. At any time?

A. At any time.

Q. You certainly never refused to bring them clothing?

A. No, I never refused to bring them clothing.

Q. Did any representative of the police ever deliver a search warrant to you to search anything?

A. No, sir.

Q. Not your car?

A. (Witness shook head negatively.)

Q. Not where you lived?

A. (Witness shook head negatively.)

Q. Not where you worked?

A. No, sir.

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Q. No search warrant from the police to you at any time?

A. No, sir.

Q. Did you ever provide the police an alibi?

A. Yeah.

Q. Tell us about that.

A. I was home that night. I went out for a drive in the early evening or probably around, sometime around 6:00 and not later than 7:30 or 8:00. And I was home early because we had stayed up sort of late the night before. Not even really that late, but we had a meal and drank a little bit, and I am not in the habit of drinking two nights in a row. And I just had a few drinks on Christmas Eve, and on Christmas night I was in bed early.

Q. Did you stay in bed?

A. Yes, sir.

Q. And what witnesses can confirm you stayed in bed?

A. Only Jackie. She is the only other one who lived in the house.

Q. Were you in bed with Jackie?

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A. At that time we had -- she had a queen size bed and I had a queen size bed that were sort of just pushed against each other, mattress and box spring on the floor and just pushed next to each other.

Q. So she could not be sure that you were there all night; could she, sir?

A. Apparently, that's what she told everyone.

Q. And it's true what she's told the police; isn't it, sir?

A. What would that be?

Q. That she cannot know that you were there all night or not.

A. I guess because she was asleep; that would be true.

Q. And what were you wearing that night?

A. I have no idea.

Q. What were you wearing to bed?

A. I'm sure -- I'm sure I was probably wearing -- well, okay, I can answer that. I mean, I was wearing jeans because I always wear jeans, and probably a T-shirt or sweater or a flannel shirt, or some sort of

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a hunting shirt or work shirt, or -- probably most likely a sweater and tennis shoes. And then as far as to bed, just shorts.

Q. What time did you get up the next morning?

A. I have no recollection of that; although, I've heard that she says I was up very early, which would be consistent with my sort of behavior or how I would -- how I would -- my schedule on that kind of a situation, when I would be up late one night and then to bed early the following night, I would probably likely get up early the next day. I tend to like to get up early, generally; although, if I -- I don't always. But if I'm in bed early and can go to sleep early, like I would have been able to do had I been drinking the previous night, then I would be up early the next day.

Q. Mr. Wolf, apart from what you have read about what Jackie Dilson has said, do you have any recollection what time you got up the next morning?

A. I have a -- I have the idea that

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I probably got up about 6:30 or 7:00, which would be sort of what I'm referring to as sort of early, maybe even earlier, maybe 6:00.

Q. You have an idea about that, but you don't know?

A. The first time I was -- no, I really don't know. The first time I was ever asked that question was more than a year after. It was close to a year and a half after that, and I don't know why anybody would expect me to remember that. I didn't.

Q. You did not give the police a chance to ask you that question, however, in January of 1997; did you, sir?

A. I think I gave them a chance to ask me a few questions, and I told them that -- and I gave them answers, too.

Q. And wouldn't it have been useful for you to start thinking about an alibi in January of 1997 when the police asked you for handwriting samples and you refused to provide them?

A. Well, I had told them -- they did ask me a few questions, and I gave them a

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few answers, and answers in the negative as to did I have anything to do with that crime or --

Q. Did you give them an alibi in January of 1997?

A. I told them what I just told you; I was home that night. I went out for a drive early in the evening, possibly even something like what would be considered late afternoon, and was home very early and asleep relatively early, 8:30, 8:00, 8:30, something like that. Maybe 9:00 was probably about the time I went to sleep. And I'm sure that that's what I've said in the past, and --

Q. In January 1997 --

A. -- and that is what happened.

Q. -- then, did the police ask you what time you got up the next morning?

A. I don't recall them asking me that.

Q. You don't know when was the first time you were asked that question, then; is that correct, Mr. Wolf?

A. Well, I -- no. I -- yeah, I don't know exactly. I don't know if the

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first time was in April of 1998 or if it was in January of 1997. I don't know when the first time was. I think I was asked by reporters or somebody other than the police sometime in the meantime.

Q. Was your sweater dirty the morning of December 26, 1996, when you got up?

A. It may well have been dirty in the sense of having been worn for a few days. I am sure it wasn't dirty with dirt or grease or mud or something like that. I mean, you know, I guess it could have been. I may have laid down to look underneath the car or I don't know what, but, I mean, I have no way of answering that question really.

Q. Were your jeans dirty on the morning of December 26, 1996, when you got up?

A. The same thing. I mean, they were, you know -- could likely have been dirty from wear or, you know, I don't know. I wear them a number of days in a row, and they could have been dirty in that sense, or they could have been -- you know, Jackie's

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house was kind of a gravel driveway and large parking lot. And if I sat down on that to look under the car or if I got down on my knees in the parking lot or in the house somewhere or out on the ground somewhere to fix something or look at something, they could well have been dirty in that, in that sense of dirty.

Q. If Jackie Dilson says you were showering between 5:00 a.m. and 5:30, is that true or false, or do you know?

A. I don't know. I think -- I take a shower first thing every morning, that's what I do, take a shower. And if I got up that early, that's entirely conceivable, also, 5:30. I mean, it's conceivable that I could have gotten up at 5:30 after having gone to bed very early the night before, and the first thing I do when I wake up is take a shower.

Q. She says that you told her, after you took the shower, you were going to a coffee shop. Do you remember that?

A. I don't remember that, but that's the second thing I do every morning.

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Q. Which coffee shop did you go to December 26th, 1996, in the morning?

A. December 26th? Most likely, the Trident, although it may have been Penny Lane, but it was probably the Trident.

Q. But you're not sure?

A. I would say chances are very good that it was the Trident.

Q. Did the police ask you about any alias that you might have ever used?

A. Not that I recall.

Q. When did you use the name Chris Damian?

A. I don't recall using that name.

Q. The first you ever heard of that is when I just mentioned that?

A. Yes. I don't think I ever used that name.

Q. In April of 1998, after you provided the non-testimonial evidence that you have described, did you give a statement to the police?

A. Yeah.

Q. In writing?

A. I don't think so.

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Q. On tape?

A. I don't think so.

Q. You just simply were asked some questions and you gave some answers?

A. I think that is probably something like that.

Q. Well, what do you remember? Don't tell me what probably happened, Mr. Wolf. I only want to know what you recall happening, please.

A. I don't recall what he asked me. He asked me a couple of questions, and I just -- you know, regarding the crime. And I just would have responded truthfully in the negative. I don't, didn't -- I never heard of the Ramseys, never heard of their daughter, never hurt anyone in my life, never said so much as a harsh word to any child, never broke in anyone's house, certainly not the Ramseys, never had any reason to do anything like that.

Q. To the best of your recollection, that is all the statement consisted of?

A. I'm really speculating as to what it consisted of. I'm just saying whatever he

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would have asked me, I would have responded in the negative as to any involvement I would have, may have supposedly had in that crime.

Q. Did the police ever talk to you about Susanna Chase?

A. I think I was asked questions about her.

Q. By the police?

A. Yeah.

Q. When?

A. I think -- I don't really remember. It may have been the very first time I was there, they may have started with that, or it may have been the time I went back there in April of '98. It was probably -- it was -- I'm pretty sure it was either one of those occasions. I've talked to them since then, but I think that it was one of those two occasions.

Q. What were you asked about Susanna Chase?

A. I think if I knew her.

Q. What else?

A. If I ever dated her.

Q. What else?

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A. I don't know of anything else.

Q. What did you answer?

A. I answered yes, that I knew her, and, no, I never dated her.

Q. Did you tell them you asked her out?

A. I may have told them that I said something like that.

Q. And she turned you down?

A. No, she didn't. She gave me her phone number.

Q. Did you use her phone number and call her?

A. I called once a week or so later and I talked to her roommate. And her roommate said she wasn't there, and I said -- I don't know if I left a message with my name or I said I'd call back or what, but I never did call her back.

Q. You just told us, I have talked with them since, in reference to the police, meaning you talked with them after April of 1998. Tell us about that, please.

A. In, maybe, July of 1999, when I was in New Orleans, I got back from a job, a

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photo shoot job, and I went to -- I talked to a friend of mine, and he told me that the police were looking for me. And I said -- I guess I wasn't too surprised, and I went to his house. He gave me -- he said, They left a card. I said, Well, I'll be right over. And I went to his house pretty quickly, within an hour or so, and got the card, and it was a card of a New Orleans homicide detective. And he suggested to me that I should call them right away. And I said that that's what I'm going to do, and that's what I did. No, in fact, I didn't call them. I went to the French Quarter police station and presented the card, and they started making phone calls. The guy was from a different precinct. And they got this and that, and the guy comes back to me after a few minutes and says, Were you involved in this JonBenét business, and I said, Well, apparently unwittingly, or something. And I said, you know, it was cleared or very sure to be clear in saying, I am in no way

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involved other than to have been sucked into the vortex of the whole mess. But, regardless. So he called the Boulder Police Department, and he got -- I don't know who he got, but I guess he got Tom Wickman cause that's who he put me on the phone with, and that's the very first time I ever talked to Tom Wickman. And Tom Wickman at that time told me, Listen to me, you are not a suspect. Okay? He said, Listen to me, you are not a suspect. So that was the third time I had heard that from the police. And, of course, that, you know, was nice to hear, but nonetheless I knew it wasn't the end of my problems with this. He said, If you're coming back to Boulder, we would like to talk to you. And I said, If I come back to Boulder, I'll call you. And that was pretty much that conversation. I mean, there was more to it. Nothing -- the woman detective, Jane Harmer, had looked for me in New Orleans and had gotten to New Orleans homicide detective who was looking for me for her.

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Q. How do you spell Jane Harmer?

A. I guess it is just like it sounds. So as it turns out, it was sort of a little bit, ah, a little bit, kind of -- well, I didn't expect to be back in Boulder soon, but as it turned out, I was.

Q. And did you, in fact, get in touch with the police again?

A. I called them the day I got there.

Q. What day was that?

A. Sometime in August of 1999. No. Maybe it was September.

Q. Who did you call?

A. I called Tom Wickman.

Q. What did you talk about then?

A. He said, Michael Kane would like to talk to you. Do you want -- can you meet us? And I said, Sure. And I said, When? And he said, you know, I guess it was a day or so before we scheduled an appointment. And I was there, and-- at the downtown police station -- not the downtown. It's the main station, 30th Street.

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And we sat in the interrogation room for, I don't know, about maybe ten minutes or something. Well, no, maybe a little longer. And they just asked me, Is there anybody out there who's going to say that you're a pedophile, that you -- that they were talking to you, and you were getting turned -- little children, or that you are in any way involved in this, or that-- you know, all this. Just, Is there anybody out there who's going to say anything about this, anything that we don't know about this, about you? And I just said no, no, no. There's nothing that you don't know that, about any of that.

Q. Are you a pedophile?

A. No, sir.

Q. Have you ever been a pedophile?

A. Absolutely not.

Q. Did you tell the police about your career as a stripper?

A. I don't know that I did. I don't remember that I did.

Q. Did you tell them that you were a sexual deviant?

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A. No, sir.

Q. Did you tell them that you would perform in front of complete strangers in the nude and allow people to touch you anywhere?

A. I didn't tell them that.

Q. Did you tell them that you would excite yourself or allow others to excite you to arousal and erection?

A. I didn't tell them that.

Q. Did you tell them that you engaged in sex acts and simulated sex acts for pay?

A. No, I didn't tell them that.

Q. So there is a lot they don't know, even today, about your sexual behavior?

A. I don't think that's true. They talked to Jackie plenty.

Q. Does Jackie know that you had sex when you appeared as a stripper?

A. I think she -- I think that she thought I did that prior to the time that I ever did. In fact, I basically sort of had sex with her at the time I was out there at her party, I mean, in the sense that she was touching me.

Q. So that did not start in New

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Orleans?

A. No, I didn't say that. I said that they have always been able to touch me. I said that having intercourse with people as a result of -- having intercourse with women as a result of being there to be a stripper happened for the first and last times in New Orleans.

Q. So in response to the police asking you about whether you were -- whether there were going to be any surprises to come forth about your sex life, you decided that it was enough for them to hear about your sex life from Jackie Dilson?

A. I didn't think any of those things -- I don't think then and I don't think now that any of those things that you're recounting are germane or relevant to a violent murder of a child at all.

Q. But you didn't let the police decide that. You decided that for them, and you kept that information from them, assuming Jackie Dilson would tell them that?

A. No, not assuming Jackie would. I just -- I just knew that those were

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absolutely irrelevant to the investigation of that kind of a crime. I told them that I've never been -- I'm not a violent person, that I've never harmed any child, that I've never had sex with any child, that I've never broken into anyone's house, that I've never -- I'm not -- I've never done anything resembling sadomasochism or bondage and discipline. I've never harmed -- I told them all those things, on all those things being true. I told them that I've never heard of the Ramseys. I told them that I've never heard of JonBenét Ramsey. I told them I've never seen a child beauty pageant. I told them I've never wanted to see a child beauty pageant. I told them at that time I had never been on the internet.

Q. Are you finished?

A. Yep, sure.

Q. How had you learned, as you had told Carol McKinley, according to Defendant's Exhibit 2, that it was very possible for a grown man to have sex with a six-year-old girl?

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A. I learned that because Jackie Dilson told me that that was her experience as a child, ritual sexual abuse from an early, early age.

Q. As a matter of fact, Jackie Dilson had written a story about that?

A. Tried to write a book.

Q. And you read that story?

A. Uh-huh (affirmative).

Q. You read that story repeatedly?

A. No, no. I read it -- I really -- I wouldn't even say read it. It wasn't very good writing. It was -- I looked it over as a writer because she wanted me to write a book about it. I thought it was an interesting and compelling subject, and an important subject in the sense of peace and justice in the world. And I considered, and I still would like to, you know, include her story, which I think is a tragic one, in something that I would like to write in the future.

Q. How many times did you read Jackie Dilson's story about sexual abuse of children?

A. Like I said, I think -- I think

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that was probably maybe, maybe 25 or 30 pages at the most, double-spaced. Probably more like closer to 20 pages double-spaced. And I really didn't ever read it. I sort of looked it over, skimmed it once, and I may have -- I may have looked it over. I'm sure I looked it over one other time at some time thereafter. I never looked at that more-- another time. I never looked at it more than twice.

Q. If Jackie Dilson said that you read that story repeatedly, she would be mistaken or lying?

A. Yes.

Q. If she said you had a profound fixation with that story, she would be wrong?

A. Well, I told you I thought it was a compelling story, her story, her story -- the story that she tells of her life I think is a compelling story. But as far as reading that particular piece of middling prose, I was not fixated with it at all.

Q. In April of 1998, when you gave some non-testimonial evidence to the police and you gave a statement, as you have

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testified about today, did anybody tell you you had been cleared?

A. At that time Carey Weinheimer did not say that; he just said, What are you so worried about? Don't -- you don't have anything to worry about. That's what he said.

Q. After that, were you ever told that the police had made any tests of your non-testimonial evidence?

A. I was never told that they did or didn't.

Q. You don't know whether any use was made of that today?

A. Well, I can only assume that something was.

Q. Mr. Wolf, I want to talk to you a little bit about your experience with reporters. The murder of JonBenét Ramsey received a tremendous amount of media attention; did it not?

A. Yes, it absolutely did.

Q. That began almost immediately?

A. Uh-huh (affirmative).

Q. Did it not?

A. It did.

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Q. A number of reporters called you; didn't they?

A. Not like I would have thought they would have, but they did, over the whole period of time between now and the murder, the time of the murder, I have talked to, I guess, quite a few reporters.

Q. Name some of the reporters that you've talked to, please.

A. Charlie Brennan, Carol McKinley, Raj Chopan.

Q. How do you spell his name?

A. R-a-j, I believe it's C-h-o-p-a-n, maybe. He's channel 4 in Denver. Bill O'Reilly. Let's see. Alli Krupski. Wayne Laugasen, Santino Lucci, Don Gentile. That may be -- that may be all. Peter Boyles, he's not a reporter, but -- let's see. It seems like I'm missing one.

Q. Did you speak with Jeff Shapiro?

A. Jeff Shapiro, yes.

Q. Did you speak with Frank Kaufman?

A. Yeah. He's not a reporter.

Q. Did you speak with Lawrence Schiller or his assistant?

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A. That's Charlie Brennan.

Q. Okay.

A. And I've talked to Larry Schiller since the book was published, but not prior to that. Just kind of housekeeping basis.

Q. Since Mr. Schiller's book was published?

A. Uh-huh (affirmative).

Q. What was that housekeeping matter?

A. I called him to ask if, if -- I called him to ask about the docu-drama, or something, whatever, the video or broadcast presentation or version of his book was going to be out, when it was going to be.

Q. Did you read Mr. Schiller's book?

A. Yeah. I --

Q. Perfect Murder, Perfect Town?

A. Yeah. I didn't read it word for word, but I skimmed it pretty thoroughly.

Q. Did you read it for references to you?

A. Yes.

Q. Did you watch the docu-drama based on Mr. Schiller's book?

A. I think I watched either the first

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part or the second part. I'm not sure whichever part of that ridiculous portrayal of me was included in it.

Q. You didn't sue Mr. Schiller; did you?

A. No, I didn't sue Mr. Schiller.

Q. Not for the book and not for the docu-drama?

A. No, I didn't.

Q. Anything that hurt your reputation in that book?

A. Well, to a lesser degree than this situation, certainly. I was willing to go along with a lot of this for a long period of time.

Q. Anything in the docu-drama that hurt your representation? And I'm speaking of the docu-drama based on Mr. Schiller's book.

A. Oh, I thought it was unflattering, but I thought it was -- I didn't think it was deliberately libelous.

Q. Did you speak with Charlie Brennan knowing that Lawrence Schiller was planning to write a book?

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A. Yes.

Q. And did you get paid to do so?

A. No.

Q. Did you sign a release or a waiver that they could use what you said?

A. I don't recall that, but I made no -- I didn't -- I didn't suggest one, and I was fully aware that I was talking to Charlie on the record.

Q. And was your conversation with Charlie Brennan recorded by videotape or audiotape, to your knowledge?

A. Audiotape.

Q. Audiotape?

A. Uh-huh (affirmative).

Q. With your knowledge and consent?

A. Yes.

Q. Have you seen a transcript of that?

A. No.

Q. Is the book accurate? Is Mr. Schiller's book, is it accurate with respect to quoting you where it does so?

A. As far as I recall; although, I haven't looked at that book for quite a

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while. (Discussion off the record.)

MR. RAWLS: Please mark this Defendant's Exhibit 3, Mr. Gallo. Evan, here's a copy for you, and, yes, please deliver this. (Defendant's Exhibit-3 was marked for identification.)

Q. (By Mr. Rawls) Mr. Wolf, you've just been handed by Mr. Gallo a copy of Defendant's Exhibit 3. I'll tell you this is a copy of several pages from Mr. Schiller's book, Perfect Murder, Perfect Town. Please review that and tell me if that is accurate insofar as it quotes you.

A. You want me to read this right now?

Q. Yes, sir, but not aloud, please. (Deponent reviews document.)

A. Well, here's a paraphrase of mine, and I wouldn't cop to that. I don't -- I wouldn't have said something like that. I wouldn't have said, "I hope the fucker dies." I didn't say that.

Q. And on what page is that?

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A. That's on page 195, right there on the second paragraph.

Q. You deny saying that?

A. I deny saying. I don't -- I deny saying, "I hope the F'er dies." I don't talk like that. And, you know, I mean, I don't do this business that they had me in the docu-drama with the pucker lips at the detective. I don't -- that's not -- neither of these things is anything that I would do or say.

Q. All right. And what about the excerpt from, just a little below halfway down the page, on page 195, through about a quarter of the page on 197, that purports to be a verbatim statement from Chris Wolf? Is it accurate that you made that statement to Charlie Brennan?

A. Yeah, well, I can see that -- let me see. (Deponent reviews document.) THE WITNESS: Well, that's -- I don't --

MR. ALTMAN: Hold on a second. Jim, are you ready for the answer?

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MR. RAWLS: Oh, did you stop him because I was distracted?

MR. ALTMAN: Yeah. You looked busy.

Q. (By Mr. Rawls) Please go ahead with your answer, Mr. Wolf. I thought I was waiting on you.

A. I don't see anything in there that I think was deliberately or -- or seriously inaccurate or certainly libelous. I don't see anything in there that would strike me as something that I would not or did not, or, say --

Q. So --

A. -- except this paraphrase from Jackie Dilson regarding "the F'er." I don't say, "I hope the F'er dies." I don't say things like that.

Q. So, in fact, you did tell Charlie Brennan that you don't -- you did not remember being out Christmas night. That's a true quote, the very first thing you are quoted as saying on page 195?

A. Well, yeah, I think that's probably right. And I think what I meant

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was what I told you earlier, I was out in the late afternoon or very early evening for a very short period of time, and I was in on Christmas night.

Q. You told us you were in on Christmas night, but some years ago you told Charlie Brennan on an audiotape made with your consent that you did not recall going out on Christmas night; is that true?
A. I figured they probably transcribed the tape accurately and wrote it in this book accurately. I figured that's probably -- that's probably what I said, which is not inconsistent with anything I've just told you. We are talking about the difference between afternoon or night, early evening maybe or night. I was not out on Christmas night.

Q. Mr. Wolf, on page 197, immediately after the remarks that are quoted from you, the book goes on to say, as follows, "Chris Wolf would remain a police suspect." Is that true?

A. I think I remained a suspect in the mind of some of the less serious, less competent people in the district attorney's

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office. And I think that I was not a suspect of the police.

Q. Anybody serious or competent would not have made you a suspect; is that your testimony?

A. The incompetent people in the district attorney's office thought I remained a suspect.

Q. Who were they?

A. Trip DeMuth and Peter Hofstrum, and probably as a result of letting them go on with their obstruction, the district attorney himself, Alex Hunter was probably one of the incompetent people in the district attorney's office.

Q. As a matter of fact, you use the "F" word about Alex Hunter; don't you, sir?

A. I -- are you referring to the Boulder Weekly story?

Q. I'm just asking you a question right now. Do you have any trouble answering that?

A. I may well have used the "F" word about Alex Hunter.

Q. You did tell the Boulder Weekly,

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did you not, sir --

A. That's an inaccurate quote.

Q. -- as follows --

A. I don't use the term "scum bag" either.

Q. The quote you're referring to as inaccurate is an article attached in your complaint in this case; is it not, sir? Do you not know what was attached to your complaint in this case, sir?

A. No, I do.

Q. You do?

A. Yes, I do.

Q. And there's a quote there. "'Alex Hunter is the lowest F'ing scum bag on earth,' Wolf says." You're saying the word "scum bag" is not --

A. -- something I would say.

Q. Right. But the rest of that is something that you would say?

A. I don't tend to refer to people as "the lowest" this or that either, and I may have said the "F" word him. But that whole quote just sounded to me, just rang

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false to me. I don't think I really ever said just exactly that. I -- and I haven't said this probably because I know the reporter, and I think he did a good job on that story, generally. And I think that was his own feelings coming out in that quote. I think he hates Alex Hunter. I think he hates Alex Hunter.

Q. Who is that reporter?

A. Wayne Laugasen. I would like to amend that comment. I don't know whether -- I don't have any way of knowing whether Wayne Laugasen hates Alex Hunter. I think Wayne Laugasen is quite sure in his own mind that Alex Hunter failed in his duty and his public trust in the JonBenét Ramsey murder investigation. I think that Wayne Laugasen thinks that just like I do and many other people do.

Q. Mr. Wolf, the same article you just have referred to that is attached to your complaint from the Boulder Weekly, on page 2 of that article, the following remarks appear, quote, Hoffman is the first lawyer

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Wolf has spoken with regarding the Ramsey case. Did you tell the reporter that?

A. I think that is shorthand for the first lawyer that I have been represented by.

Q. I see. So this is just a misquote or an error by the reporter?

A. I don't think it is a quote at all.

Q. You are right. It is not put in quotation marks. The article goes on to say, Never, while being interrogated by the police as a suspect in the Ramsey case did he call a lawyer, with reference to you. And, frankly, that is false; isn't it?

A. Well, I guess I did call one lawyer, and he would not talk to me. And I did not call any other lawyers. And then the next lawyer that I talked to was at the time of the publication of the Ramseys book, and that was Ms. Smollen. But I did call one defense attorney that I knew in Boulder who did not take my call, and I did not try to call him back, and I never did talk to him. That was within a couple of days after

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they pulled me in. So to that degree, maybe that is inaccurate.

Q. You told us earlier, Mr. Wolf, that your work permit in the British Virgin Islands was denied. The fact is, you told this same reporter for the Colorado Weekly that the work permit was denied in the British Virgin Islands because "The government there found out I was a suspect in this case." Is that true?

A. I was speculating.

Q. That is what you said; was it not, sir?

A. That I -- I imagine, that is what Wayne quoted me as saying. I am sure I thought that at the time, and I think I was just speculating that that is what happened. I don't know why else I would have been denied a work permit.

Q. You told that same reporter about Jackie Dilson. "Jackie is not a stable person"; didn't you, sir?

A. I think I probably -- is that a quote in the story?

Q. Yes, sir.

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A. Well, like I said, I told some people that. And I think that is pretty well true. She spent years and years in therapy, and she admits all of that. It is not news. It is not slander. And like I said, I guess I thought that I asked him not to include that in the story, and I have asked other reporters, if I even suggested other things to reporters -- like I said earlier, I have not made a campaign of slandering Jackie at all. I told most people that I have sympathy -- that I have great sympathy for her and that I don't harbor malice against her. And that is how I do feel. I am not trying to slander or cause her stress or anything at all like that.

Q. As a matter of fact, on the very next page, after the phrase I just quoted --

MR. ALTMAN: Jim, what page is that?

MR. RAWLS: The numbering on my copy at the top is missing.

MR. ALTMAN: How about the words?

Page 219

MR. RAWLS: Let me go to the back. There are 12 pages. So there is 11. I am talking now about page 11. The quote I just used, quote, Jackie is not a stable person, end quote, Wolf says. That comes from page, I believe, 10.

MR. ALTMAN: Page 10.

MR. WOOD: 9 of 12.

MR. RAWLS: That was 9 of 12. I'm sorry. So I am now on page 10 of 12.

Q. (By Mr. Rawls) It reads as follows -- this is after the phrase about Alex Hunter and the "F" word and "scum bag" word. The next paragraph says, Mr. Wolf says Ms. Dilson turned police on to him because she is unstable and was legitimately paranoid at a time when their relationship was on shaky ground. Anyone close to the case knows that, Wolf says. Is that something else you told this reporter but asked him not to publish because of your concern about slandering Jackie Dilson?

A. I think this is exactly what happened. She was a jilted lover and a

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vindictive -- pursued a vindictive cause of action against me. I didn't enjoy hurting her, breaking her heart, to whatever degree, and I think that is maybe a little -- she probably wouldn't assent to that, but I didn't enjoy -- I didn't enjoy leaving her and hurting her feelings in any way. And as far as what I may have -- this probably is just what you suggested, it is something that I told him so that he would understand more about the reason I was involved in this case, because that is the reason I am involved in it. And that's what I -- I really have no choice but to explain to some people, at least.

Q. Mr. Wolf, the simple fact of the matter is, you are involved in the JonBenét Ramsey case because Jackie Dilson called the police; are you not, sir?

A. As far as I know, that's exactly why, yes.

Q. That is exactly where it started.

A. That is what the -- the only thing I've ever been told.

Q. It did not start with John

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Ramsey --

A. No, the --

Q. -- am I correct?

A. That's correct, but that is not the point of our case.

Q. It did not start with Patsy Ramsey; did it, sir?

A. No, it didn't.

Q. It did not start with Alex Hunter; did it, sir?

A. No, I think it did start with Patsy Ramsey. I think it did start with Patsy Ramsey. I think -- I think it started with both of them. I think that if they had not exploited that child and been in some way complicitous in her death, that this would not have happened to me.

Q. Had Patsy Ramsey ever heard of you before Jackie Dilson called the police about you in January of 1997?

A. I have no idea. I was a reporter.

Q. All right, sir.

MR. RAWLS: Let's take a break.

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THE VIDEOGRAPHER: We are off the video record at 4:01. (A recess was taken.)

THE VIDEOGRAPHER: We are on the video record at 4:16.

Q. (By Mr. Rawls) Mr. Wolf, have you ever used the "F" word about Lou Smit, sir?

A. I imagine I have.

Q. And, in fact, you did it long before the publication of the Ramseys' book; did you not, sir?

A. I had a really clear idea of what he was up to pretty quickly after he got involved, and I may well have.

Q. And as a matter of fact, you were very concerned about Alex Hunter long before the Ramseys published their book; were you not, sir?

A. Very concerned?

Q. Yes.

A. In what sense?

Q. Angry with him, felt that he was incompetent, felt that he was protecting the Ramseys.

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A. I tried to stick with him for as long as I could, and I think -- I don't know if I completely -- well, I -- apparently, by the sound of that quote in the Weekly, I wasn't happy with him at that point. Although, I think I went back and forth with him for quite a long period of time trying to have faith in his method and his intent. And at this point, I can certainly, without qualification, say that I'm very disappointed in him as a prosecutor and a public official.

Q. In fact, you were very disappointed in him before the publication of the Ramseys' book; were you not?

A. At times, yes, before the publication.

Q. In fact, before the publication of the Ramseys' book, you told Jeff Shapiro you were convinced the Boulder Police Department was a, quote, rich man's imperialist police force trying to protect the Ramseys and frame him, Wolf, for the murder as just another measure of the, quote, fascist police state, end quote. Did you tell him that?

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A. That is Jeff Shapiro's quote. That's Jeff Shapiro talking, and I certainly didn't say, I don't think, any of those things.

Q. You said none of that?

A. No.

Q. Did you believe that was the case?

A. I think I probably said to him that I thought they were trying to frame me in the sense of how they explained it to you, in the vacuum of pursuing the primary suspects, and all of the unwarranted energy and initiative that they spent in trying to investigate me after time and time again being -- coming up with nothing about me that would indicate that I would ever or could ever do anything like that. So in the sense -- in that sense, I do feel like and did feel like and do feel like that they, in effect, tried to frame me, yes. And I think that that is the one accurate part of that commentary from Mr. Shapiro, who I don't consider a friend, I never did, and anything he has said about me as far as I can tell that I've read or heard

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on the media is not true. He did not offer to give his DNA, if I would give my DNA, or anything like that. He seems to be somewhat of a pathological liar.

Q. Mr. Wolf, perhaps you thought I had asked you about Jeff Shapiro's credibility, but I had not. So please do listen to the question and try to answer, and we'll be all finished more quickly if you do.

A. Uh-huh (affirmative).

Q. Did you tell the same reporter for the Colorado Weekly, did you not, that, after you refused to cooperate with the police in January 1997, "The years since then have been a nightmare." "It has just been unbelievably stressful to be connected with this in any way." Is that a true quote from you to that reporter?

A. Yes.

Q. In fact, it's true that the year 1997 was "unbelievably stressful" for you; was it not, sir?

A. Yes, it was very stressful.

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Q. The same is true of 1998; is it not, sir?

A. Yes, it's true.

Q. The same is true for 1999; is it not, sir?

A. At some point in 1998 and into 1999, I was feeling like -- well, at some point, and probably in 1999, I was feeling a lot better about things.

Q. All right, sir. As a matter of fact, in 1997, 1998, and 1999, there was no book published by John and Patsy Ramsey; was there, sir?

A. No, there was not. And that's why their willingness to publish that book fully, more than two years after I had given the evidence that the police had asked me for, was -- made it all that more hurtful and devastating to me personally and emotionally.

Q. Mr. Wolf, you've got an awful lot of enemies out there; don't you, sir?

A. I think I have a few.

Q. You've got Alex Hunter out there, but you haven't sued him. You've got Lou

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Smit out there, but you haven't sued him. Those are folks who are attacking you and have attacked you and have made your life unbelievably stressful; aren't they?

A. Yes.

Q. Same is true of Trip DeMuth; isn't it?

A. Well, you know, I think that it's important for me to express to you, sir, that, at least in the case of Hunter and DeMuth, like I expressed to you, I have tried to have faith with them as public officials and as well-meaning people. And I understand that their job is a difficult one, and I understand, as Alex Hunter expressed, that his investigation into the Ramsey murder, his investigation of the parents of JonBenét Ramsey, was a political matter, and I understand that it was a difficult political matter for him. So I have tried to bear with them, I guess. And I think the difference being, the point you are getting to, the difference being that I feel like it's very clear to me and my attorneys that Mr. and

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Mrs. Ramsey knew who was responsible for the child's death and, nonetheless, were willing to implicate me.

Q. Mr. Wolf, you're making a speech again.

A. Yes, sir.

Q. And I want to tell you, again, I want you to answer my question and stop. And I move to strike what you've just said about John and Patsy Ramsey, which has nothing to do with the question I just asked you, sir. Now, all of this nightmare started with Jackie Dilson; did it not, sir?

A. I think it started with the death of a little girl.

Q. And your involvement was brought about by Jackie Dilson; was it not, sir?

A. I don't see it that way, as I told you before.

Q. Well, who brought you to the attention of the police, as you told me before?

A. As far as I know, Jackie, but she is not the one who killed the little girl,

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and neither am I.

Q. Mr. Wolf, if it turns out that you're mistaken in your accusation that Patsy Ramsey or Burke Ramsey or John Ramsey killed JonBenét Ramsey, then they're simply in the same boat you find yourself in; aren't they? They have had some even more stressful years, have they not, sir, since the death of their daughter, even more stressful than poor Chris Wolf; have they not, sir?

A. Well, if that scenario that you described were true, yes, the answer would be yes, but, sir, I'm --

Q. Thank you.

A. I'm a --

Q. Thank you.

A. I'm an educated person, and I understand about law and politics and crime, and I have -- I have entertained that -- that idea that you're describing. And I have entertained it numerous times. And there is just too much evidence that cannot be ignored, and there's too much of a lack of contradictory evidence, a giant vacuum of

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contradictory evidence, even in the -- even after all the millions of dollars and man hours and the extremely over -- unwarranted amount of time that the investigators have spent investigating hundreds of other, quote -- or dozens and dozens and dozens, more than a hundred or 150 or so, other, quote, suspects.

Q. Mr. Wolf, are you finished?

A. Yes, sir.

Q. All right. Have you ever been paid to talk to anyone about the JonBenét Ramsey murder investigation?
A. Yes, sir.

Q. Who?

A. Santino Lucci paid me, the Hard Copy. And the Enquirer paid me a couple hundred dollars, $250.

Q. All right. How much were you paid by Hard Copy?

A. 5,000.

Q. How was that set up?

A. She called me at work and left a message, and I called her back, and she said she was happy to get in touch with me, and

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would I be interested in talking about my experience. And I said -- I said, I understand that you pay people to do that; and she said, Yeah. And she said, How much do you want? And I said, It would have to make it worth to me, and we agreed on a figure of $5,000. And she came out and we did the interview.

Q. Do you have a transcript of that interview?

A. No, I don't.

Q. Do you have a tape of it?

A. No, I don't.

Q. What did you say on Hard Copy?

A. Oh, I'm not sure. It's been a long time.

Q. You said the Ramseys were liars; didn't you, sir?

A. I don't know if I said that.

Q. How did it happen that you took money from the Enquirer to talk about the JonBenét Ramsey murder investigation?

A. I just told you.

Q. Who called you about that, sir?

A. Santino Lucci.

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Q. The Enquirer.

A. Oh, the Enquirer, I'm sorry. Yeah, John Gentile, the reporter for the Enquirer called me.

Q. Has anybody else, other than the Hard Copy and Enquirer, ever paid you to talk about the murder investigation into the death of JonBenét Ramsey?

A. Not to my recollection. I'm quite -- almost sure that no one else has.

Q. How did it happen that you appeared on the Bill O'Reilly show?

A. That was just after we filed the lawsuit. And I guess he got in touch with Darnay, and Darnay said, Do you want to do this? And I said, Sure, and did it.

Q. Did you get paid for that?

A. No, sir.

Q. On the Today Show, a few weeks after -- or within a few weeks after the judge ruled in this case denying the defendant's motion to dismiss your case, why weren't you part of that broadcast?

A. I guess they offered me to go to Cincinnati and sit and stare at a camera and

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be sort of a -- I don't know what that's called, in a -- I forget, an off location or whatever. And I just didn't want to do it that way. They said, you know, I'd have to get up like 3:00, 4:00 in the morning and drive all the way to Cincinnati, and I just didn't want to do it.

Q. Mr. Wolf, now I want you to tell me, please, about reporters that you refused to talk with about the investigation into the murder of JonBenét Ramsey. Who are they, please?

A. I'm trying to think. It's a much shorter list. I tried to -- I tried to have a policy of talking to anybody, and then, more recently, I realized that that's not something that I want to do anymore. I don't want people to say, He's in it for the publicity. I'm not. But the reporters that I haven't talked to -- I'm trying to remember. I know they are -- golly. I'd like to just say that the reason I am doing this, I guess, is that I don't want anybody -- I don't want anybody to

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think that I could or would ever do anything like that, just that --

Q. Mr. Wolf --

A. I know.

Q. -- I have not asked you the reason you did this.

A. Yes, sir.

Q. There's a question pending, and it's very simple. Tell me the names of the reporters that you refused to talk with about the murder investigation into the death of JonBenét Ramsey.

A. I'm trying to remember. I can't -- I know there's been -- I told Carol McKinley I wouldn't talk to her the first time she asked me. And then -- and then I subsequently did a couple of times. I don't know. That's the only thing that rings a bell, although it seems like there's been somebody called me on, and I said I didn't want to talk to them. I don't know. That may be the only time I said no to a reporter. The Today Show, they, you know, just recently, they said -- at one point they

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said, They want you to fly to New York and sit in the studio and talk to Katie. And I said, You know, that sounds great. I'd be happy to do that. And then it changed from that to, you know, They want you to go get up at 3:00 in the morning and go to Cincinnati and stare at a TV camera. And I said that I didn't want to do it under those circumstances, after them changing their mind on me like that. And I just didn't want to get up this early. I don't know if that's the only time. Those are the only things.

Q. Mr. Wolf, all of the reporters that you have spoken with about the murder investigation into the death of JonBenét Ramsey are people to whom you freely told that you had been a suspect in that investigation; correct?

A. Yes, sir. I -- and, you know, I don't know if I want to just say it in a blanket statement like that. Obviously, that's why they were in touch with me, and that was the premise of our whole conversation and the whole story. And as I

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told you, I know I remained a suspect in the minds of people in the district attorney's office for a long, long time.

Q. And you told Hard Copy on national television in return for $5,000 that you had been a suspect, and, indeed, you were a suspect in the death of JonBenét Ramsey; didn't you, sir?

A. Not a police suspect.

Q. You told Hard Copy you had been a police suspect; had you not, sir?

A. I think, if I said that, I was confused at the time as to whether I was or not, and I have subsequently found out that I was not a police suspect. I was only a suspect in the minds of some of the incompetent people in the district attorney's office.

Q. But you told Hard Copy that you were a suspect in the minds of some public officials; did you not, sir?

A. I assume that you have the transcript of that, and I wouldn't want to just say one thing or another. Whatever it says in the transcript is probably what I

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said.

Q. I'm asking you what you recall. Do you recall telling Hard Copy you were a suspect?

A. I don't recall telling Hard Copy that I was a suspect. She called me with the -- saying, I understand you are a suspect in this investigation, and I would like to talk to you, and I probably just said, Okay.

Q. Mr. Wolf, I want to show you what you told the nation when you spoke with Bill O'Reilly about the plan you had with Mr. Hoffman to file this lawsuit. And if we can take a moment and we'll run the videotape, and we'll see if we can focus the camera on the TV.

MR. HOFFMAN: Do you want to go off the record for --

MR. RAWLS: Well, let's go off the record until we've got it set up. THE VIDEOGRAPHER: We are off the video record at 4:34. (A recess was taken.) THE VIDEOGRAPHER: We are on the video record at 4:39.

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Q. (By Mr. Rawls) All right. Mr. Wolf, please take a look at the Bill O'Reilly show.

MR. RAWLS: And, Eric, I'll tell you when we are finished with the segment that I want to discuss with the witness. (Whereupon, a videotape was played and transcribed as follows: "Speaker: JonBenét Ramsey. The cops can't solve the mystery, so now the case is being played out in books and in unproven accusations. In the Ramseys' book, The Death of Innocence, the couple writes about freelance Denver journalist, Chris Wolf, quote, Whatever the police's intention, Wolf went on our suspect list. He represented too many unanswered questions, unquote. "During Today Show interview, Katie Couric asked Mr. Ramseys about Mr. Wolf. Here is what John Ramsey said: He had been widely mentioned in the news, and we wanted to clarify the facts that we knew. I can tell you, when we first started looking at one particular lead early on, my reaction was, This is it. This is the killer. And

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our investigator said, Whoa, whoa, whoa. He said, Don't do a Boulder police on me. Don't rush the conclusions, end quote. "With us right now from Denver is Chris Wolf. And here in the studio is his attorney Darnay Hoffman, who has been a critic of the Ramseys all along. We must say that Mr. Wolf is filing a major lawsuit against the Ramseys. "Now, you have been cleared by the Boulder police, Mr. Wolf. You are not a suspect in the case any longer. But you were a suspect in the beginning due to your girlfriend, and how did that happen? What did she say? "Mr. Wolf: I'm not sure exactly what she said, but it must have been something that -- about me and regarding the murder of the little girl, which, of course, I had nothing to do with. I could never and would never do anything like that. But I think that she was angry with me, and for personal reasons, I guess, as far as regarding our relationship, and I think that she wanted to make my life miserable, and I

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think that she succeeded. "Speaker: Why didn't you sue her, first of all? "Mr. Wolf: Well, we have a long history, and we were at one time very close friends. And at this point I still have a great deal of sympathy for her, and I don't have, you know, malice towards her. "Speaker: All right. So you never met the Ramseys, never come into contact with the family at all? "Mr. Wolf: Never. Never heard of either of them or their daughter prior to the murder of the little girl. "Speaker: How -- were you anywhere near the house? Was there any -- "Mr. Wolf: No. "Speaker: So when the police came to your door to ask you questions, what was your reaction? "Mr. Wolf: Well, I was shocked, and I was angry, and I refused to answer questions initially. They first tried to interrogate me and asked me to give handwriting samples and such, maybe like a

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month after the murder. And I refused. "It wasn't until more than a year later that I heard from them again, and they asked me -- they called me at work and asked me to come into the police station and give handwriting and DNA and hair and palm prints. And, of course, a lot had happened in that period of time, and I was more inclined to cooperate with them at that point, which I did that afternoon. I went directly to the police station after work and provided them with a lengthy handwriting sample, a hair and DNA samples as well as palm prints. "Speaker: All right. So the first time, you would chalk up the first refusal as being nervous or being -- "Mr. Wolf: No, not nervous at all, but just outrage, just shock -- "Speaker: Okay. "Mr. Wolf: -- that they would be interested in me. I have no criminal record and no history of any of these things, breaking and entering, sex with children, or violent act against any person. I've never committed any of those crimes or been accused

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of them. "Speaker: All right. And we will tell the audience again that the Boulder police cleared you so that you don't have to worry about any recriminations from this broadcast.")

MR. RAWLS: Okay. That's enough.

Q. (By Mr. Rawls) Mr. Wolf, did you pay attention to the videotape as it was running just now?

A. Yes, as close as I could.

Q. Was that you, in fact, on that videotape that we just saw and heard?

A. As far as I could tell, yes, it was me.

Q. Was that your voice that we heard?

A. Yes, I guess so, for better or worse.

Q. Was that you saying that Jackie Dilson "wanted to make my life miserable"?

A. Yeah, that was me saying that.

Q. Was it you saying that she succeeded?

A. Yes.

Q. To a national television audience?

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A. In answer to a reporter's specific question about her.

Q. Yes, sir. And was that you saying that you had no criminal record?

A. That's true. That was me saying that, and that's what I believe to be true.

Q. Did you simply forget while you were on the O'Reilly show with the camera on yourself, forget your plea of guilty to indecency?

A. I was told by an attorney that I consulted regarding that plea sometime after that -- maybe more than probably two years after that, I asked an attorney who I really didn't know, I called him out of the Yellow Pages, and I just asked him if there was any way to kind of rescind it or something, and he said, No. And he described that charge as quasi-criminal. So I say, I am comfortable in saying that I have no criminal record.

Q. Well, so you didn't think you were lying to the television viewing audience on the O'Reilly show when you said you had no

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criminal record?

A. No, I didn't think I was lying, sir.

Q. The fact is, you have an extensive criminal record in addition to the indecency charge; isn't it?

A. No, sir, that's not true.

Q. You have been repeatedly arrested for traffic and driving and license offenses; have you not, sir?

A. No, I wouldn't say that at all.

Q. Well, how many times?

A. I have no idea.

Q. How many times have you been arrested for speeding?

A. I don't think you get arrested for speeding.

Q. Well, did you?

A. I don't think I got arrested for speeding.

Q. Did you get ticketed for speeding?

A. I have been ticketed for speeding, yes.

Q. How many times?

A. I don't know. A few.

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Q. Do you not think that was criminal?

A. I absolutely don't think that's criminal.

Q. And did you drive without a license and get ticketed for that time after time?

A. Not time after time. The one time. There's only been one time that I have been ticketed for driving without a license, and that was when the D.A.'s office was setting me up. They told me to -- can you imagine a state trooper saying, You have to go to the D.M.V. to surrender your license tomorrow because of a 15-year-old ticket from out of state, for no reason? I was obviously being set up. I don't count that as my responsibility, sir.

Q. Mr. Wolf, did you ever live on East Euclid in Boulder?

A. Yes.

Q. Did you run a red light and get stopped by an officer who learned that you were driving without insurance in 1986?

A. That could be. I do recall that

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that happened, yes. I have been in court for not -- for without insurance.

Q. Did you ever live at 4524 Starboard Court in Boulder?

A. Yes, sir.

Q. Did you get accused in March 1988 of driving with expired plates?

A. I don't remember that.

Q. Were you charged in September of 1988 in Jefferson County with speeding and with driving without insurance?

A. I only remember one driving without insurance, and in that case, I don't -- didn't run a red light. I've never really run a red light. I probably rolled a red light making a right-hand turn.

Q. Did you get accused when you lived on 1037 Pine Street, number 9, in Boulder of driving without insurance?

A. I don't remember that. I remember one occasion of driving without insurance.

Q. Did you ever live at 1037 Pine Street, number 9, in Boulder?

A. Yes.

Q. Did you ever get accused in 1990,

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when you still lived in the Pine Street address or gave it, of driving without insurance?

A. I don't remember that. I remember one incident of being -- of receiving a ticket for driving without insurance.

Q. The time you got arrested that you told us about for driving without a driver's license was in 1997; was it not?

A. Yes. It was a direct result of being set up for this investigation. That's why I said I wish that they had tried to do some of the same tactics with the Ramseys in order to get them to come talk to the police.

Q. Mr. Wolf, isn't it true that, in June of 1996, you were charged with driving without a driver's license? This is before anybody could have been setting you up.

A. I always had a driver's license. I've never had a suspended, never a DUI, never on points. I've never had more than a few points at any time in my entire life.

Q. Well, Mr. Wolf, you never had a criminal record according to what you told

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the police.

A. I don't have a criminal record.

Q. But sometimes you exaggerate a little bit; don't you, sir?

A. I don't think so.

Q. You deny that you were charged in June 1996 with driving without a driver's license?

A. Like I told you, I have never had a suspended license, so I don't know. I mean, if I didn't have it on my person at the time, maybe that's what you are referring to, but I've never had a suspended license in my entire life.

Q. Now, there was a time, Mr. Wolf, when you were ordered to report to the authorities before you changed an address; wasn't there, sir?

A. No, sir.

Q. You deny that as well?

A. What was that regarding?

Q. I'm going to ask you that question.

A. I have never, no. I have never had those orders.

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Q. It never happened?

A. Never.

Q. So if there is a court record of your being accused of failing to report before changing address, that is the wrong Robert Christian Wolf. You deny that that ever happened to you; am I correct?

A. I do not recall that.

Q. You don't deny it, then?

A. I guess I'm waiting to hear a fuller explanation of it. I don't recall it.

Q. Did you ever talk with Inside Edition?

A. No.

Q. You deny that you did or you don't remember?

A. I don't recall talking to Inside Edition. I thought Hard Copy was the only one of those TV tabloids that I talked to.

Q. Is there any reporter that you ever refused to speak with unless you got paid?

A. No.

Q. Have you ever tried to date Carol McKinley?

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A. No.

Q. What is your relationship with Jeff Shapiro?

A. I don't imagine that I have a relationship with him.

Q. Frank Kaufman?

A. I used to know him. He is sort of a gadfly in Boulder. He used to hang around the Colorado Daily and write letters to the editor. And I've talked to him around town a number of times. I don't really -- I used to sort of like him. And then when he got on this "maybe-the-Ramseys-didn't-do-it-bandwagon recently," I just had it with him, and I don't want to talk to him anymore.

Q. Have you ever spoken to Dan Glick?

A. No, sir. Don't want to.

Q. Why is that?

A. Because he wrote my name as a -- in the Newsweek article, and he's just been just lapping up the propaganda from the D.A.'s office, and he is a total sham.

Q. Is he somebody who's made your life miserable, Mr. Wolf?

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A. No. Well, that Newsweek article was a little rough, but, oh, I can ignore him.

Q. Mr. Wolf, did you read the complaint that was filed on your behalf in this case?

A. Yes, sir.

Q. It's customary in a defamation case for a plaintiff to plead that he had a good reputation before the remarks that are claimed to be libelous were made about him. And you did not do that. Why is that?

A. My attorney didn't ask me to do anything on that.

Q. What was your reputation like before the publication of the Ramseys book, sir?
A. I had a good reputation around town because I was a reporter for a respected newspaper, the Colorado Daily. I knew many people on the university campus, both student leaders who were, of course, by that time not there anymore, but -- as well as administrators and professors. I knew lots of professors from being a student there. I

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knew people associated with the whole Rocky Flats controversy and had been, I thought, and have been told that I distinguish myself as a reporter covering Rocky Flats. I went out there numerous times for interviews with top managers. I -- as well as the union, as well as the environmentalists. And I had lived in Boulder for 15 years. I had worked at the YMCA. I knew a lot of people from there. I was involved in -- I knew some people from climbing, although I didn't do most of the climbing that I had done in Colorado. I did most of it in California and Washington and Oregon, but I knew some people from that. Although I don't think that that was a big sort of social circle of mine. You know, I worked at the Louisville Times and knew the whole counsel, city counsel out there, the planning commission, the mayor. I thought that they all respected me a lot. I'm sure they did because they told me so. And I knew, I met lots of the citizens for this and that, and

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I wrote a feature story, or a couple of feature stories every week, and, you know, it was always a matter of interviewing one of the residents, one of the people that lived there. And I met a lot of them over, about a year that I worked there. And I worked in Lyons as a reporter. I knew the mayor and the city counsel and lived near Lyons. And I thought a lot of the people out there liked me and knew me as somewhat of a nice person and a reporter, which to me is a good thing. I don't know. That sounds like it adds up after a few years.

Q. Mr. Wolf, everything you have just said in that answer was true to December 25, 1996; was it not, sir?

A. Yes, sir, it was.

Q. And that started downhill in 1997; didn't it, sir?

A. It did, but I thought that it was a very -- I think that at that time, most everybody who was paying whatever degree of attention that they were to the murder investigation was taking almost everything

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that they read with a grain of salt and understanding that fully that many, many, many innocent people whom the cops had no reason, no significant, no worthwhile reason to suspect of committing a crime like that, were being interviewed as part of the investigation.

Q. Mr. Wolf, who shunned you, sir, after the publication of the Ramseys' book who had not shunned you before then, during 1997 and 1998 and 1999, if anybody?

A. I think my relationship, my sort of standing in the eyes of some of the people I worked with at Mike's Camera sort of suffered. I think that it put me under a great deal more stress at work when everybody found out about that as a result of the publication of the Ramseys' book. I think that I got sort of harassed a little bit around where I lived up on the hill in Boulder, which is sort of the university ghetto, the student ghetto kind of place. And, well, it's obviously got a couple different parts of the hill, but the part I lived in was down near the urban

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area. And I think I got -- I know I got harassed a little bit by some of the kids and skateboarders and runaways and spit on at just about that time that the book was being published and publicized. I think that, prior to the publication of their book, the Ramseys' book, I was kind of being able to rebound a little bit from a difficult couple of few years, and I was making some headway. And that sort of just -- you know, I mean, it's one thing when the cops or the D.A. or investigating, all these dozens and dozens of people, and, you know, you happen to be one of them, and people really aren't paying that much attention, trying their best -- not to pay a whole lot of attention to it anyway. And it's another when the parents of the child who was murdered come out with their own book naming you as one of four people who they thought -- who they said they thought could have or would have done something like that. That's an entirely different thing. And it really was a, really, a burden.

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Q. Mr. Wolf, somewhere in the distant past you've lost the question. All right. The question was, who shunned you after the publication of the Ramseys' book. And --

A. People at work.

Q. I want you to give me some names.

A. You know, I don't really remember people's names at that Mike's Camera so well. I think that -- I think my employers really lost a lot of confidence in me. Vahe. Although I'm not saying that they -- I'm not saying that they dismissed or abandoned me, but it was something that they weren't really happy to want to deal with. They have a family-owned business, and it's kind of an institution. And they all have a really very high reputation in Boulder, and I'm sure that they just were probably just waiting for an opportunity to end our relationship.

Q. Can you give me any other names apart from the employers who you did, in fact, name earlier today of people who shunned you based on the Ramseys' book?

A. I don't really remember the people's names. I think the people in my

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department whose names I do remember were, were -- well, let's see. The people in my department who I do -- whose names I do remember were supportive, I think, tried to be; although, I know it was a burden for them, also.

MR. RAWLS: Let's go off the record. Let me apologize to everyone. I've got to take a short break to cancel some evening plans, and I'll be back as quickly as I can; hopefully no more than five minutes. THE VIDEOGRAPHER: We are off the video record at 5:01. (A recess was taken.) THE VIDEOGRAPHER: We are on the video record at 5:14.

Q. (By Mr. Rawls) Mr. Wolf, how many of the handwriting experts that you and your attorney have engaged in this case have analyzed your handwriting, sir?

A. None that I am aware of.

Q. Excuse me. Did you say none that you are aware of?

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A. I said "none that I am aware of."

Q. So you have not asked them whether they can eliminate you as a suspect or whether they can brand you as the author of the ransom note that was found in the home of John and Patsy Ramsey; am I correct?

A. I haven't asked them. I am sure they can't identify me as the author of that note.

Q. And you have not asked them to try to help you eliminate suspicion; is that correct?

A. No. I don't think -- I have no reason to. The police have already done that. They had numerous, very qualified handwriting experts look at my handwriting, and they -- you know, they don't have to go through chapter and verse to eliminate mine because they have already done that and they have so many who want to identify it as another of the suspects --

Q. Mr. Wolf --

A. -- that being Mrs. Ramsey.

Q. -- are you finished now?

A. Yes, sir.

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Q. Mr. Wolf, which of the police handwriting experts have analyzed your handwriting?

A. I assume it's the CBI.

Q. I'm sorry?

A. Colorado Bureau --

Q. You assume?

A. Yes, sir, I assume.

Q. But you don't know that any police handwriting expert has analyzed your handwriting either?

A. No, sir, I don't.

Q. You don't know whether anything was done with the handwriting samples that you gave to the Boulder police?

A. No, sir, I don't know that they put them on the shelf and let them sit there.

Q. Have you ever, Mr. Wolf, in your life sought the assistance of a psychiatrist or a psychologist?

A. I went and saw a psyche -- I don't know which one she was, a therapist, for one, on one occasion, at some point within a few months after I was arrested for

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this public indecency charge.

Q. So many years before, or at least several years before the murder of JonBenét Ramsey?

A. Yes.

Q. And given the severity, Mr. Wolf, of the mental distress that your complaint claims you have had after the murder of JonBenét Ramsey, it's your testimony you have sought no professional help from any health care provider, therapist, psychologist, or psychiatrist about that; is that correct?

A. I have sought no professional help. I have borne that burden alone.

Q. The professional help you sought has not been in the medical community; it's been in the legal community. Is that correct?

A. To the degree that I have sought that, yes.

Q. And in the community of handwriting analysis?

A. My attorney sought that.

Q. Have your friends or family members ever urged you to seek help?

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A. Yes, people have. They've seen me struggling in my life, and they've suggested that I see one of those therapists, or something along those lines.

Q. Who has made that suggestion to you?

A. My adoptive father.

Q. Mr. --

A. Wolf.

Q. -- Wolf of Savannah?

A. Mr. Wolf of Savannah.

Q. He goes by #######; does he not?

A. Yes, he does.

Q. When did he make that suggestion to you?

A. Oh, a number of -- a couple -- a few different times over the last few years, I guess.

Q. Including before the murder of JonBenét Ramsey?

A. I don't recall before that.

Q. Has your adoptive sister suggested that you seek help?

A. Not that I recall.

Q. Does anyone in your family refer

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to you as a bad seed?

A. No, sir. Not to me.

Q. Have your friends asked you to seek help?

A. Not anyone that I can think of. I think most people tend to and have generally seen me as a very stable person. I am sure there are exceptions, in exceptional cases and exceptions in the sense of, you know, this or that individual, but I think that, generally, people have seen me as, I guess, able to deal with my stress or problems. I don't know that they always thought that if they had similar problems or stress that they could deal with them, but I think that they've seen me as willing and able to deal with them.

Q. On December 26 of 1996, did you ask Jackie Dilson's son to help you delete information from your computer?

A. I don't recall that it was that date; although, at some point around that -- around that Christmas, he did help me delete a number of Business Report files that I told

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you about earlier. And I'm sure if you're going to look at my computer and you're going to have somebody who knows anything about computers, you'll be able to identify their backup files and see their ghost images or whatever it is that are on there, and I don't have any problem showing those to you. It was strictly a word processor for me. It didn't have a modem; I didn't have internet access. I had never been on the internet in my life prior to working at the Slidell Century News, at which time I had to send photographs over the internet, and that's the only thing I used that for then. But that computer was a word processor with which I downloaded stories onto a three-inch floppy disk and turned the disk into the newspaper.

Q. Mr. Wolf, who is Barbara ########?

A. Oh, she's Jackie's friend.

Q. Who is Ellen ##########?

A. Jackie's friend.

Q. You have testified and you have told reporters and you have told the national television viewing audience time and time

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again that you never heard of the Ramseys and you never heard of their company Access Graphics before the murder of JonBenét Ramsey; haven't you, sir?

A. Yes, sir.

Q. You even testified to that today; didn't you?

A. Yes, sir.

Q. But the fact is that, in March of 1996, Barbara ####### was reading an article that was in the March 3, 1996, Boulder Daily Camera about John Ramsey and Access Graphics in your presence, and you went ballistic when she talked about it. Isn't that true, sir?

A. I don't recall that, and I don't know what "went ballistic" means. What was the date?

Q. March 1996.

A. I don't recall that. I don't know -- I can't imagine Barbara ########### reading a story about Access Graphics from the Daily Camera. And, I mean, what, aloud?

Q. Mentioning it to you.

A. It sounds ridiculous.

Q. And, in fact, were you from time

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to time in the presence of both Barbara ####### and Ellen ####### and Jackie Dilson in 1996?

A. I -- sure, yeah.

Q. The fact is that you already had an opinion about Access Graphics --

A. No, sir.

Q. -- and John Ramsey --

A. Absolutely not.

Q. -- before the murder of JonBenét Ramsey; didn't you?

A. Absolutely not.

Q. The fact is that even you had written about Access Graphics; had you not?

A. I have been told that, and my answer to that is the same that it's been to everybody who's mentioned that to me, and that's that I wrote, you know, a couple of stories a month for Gerry, and, you know, long, thousand-word stories, and I would forget about those stories as soon as I sent them to him or gave them to him. And I had no interest in the businesses or the people running the businesses other than just to write a story and get it sent in.

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I certainly had no ill will or motive against any person for the kind of business that they were involved in. And it is my understanding that that story that you are referring to was a story that mentioned a number of different contractors for the airport, is what I have been told. And I have not seen that story, but I have been told that, that it mentioned contractors at the airport, and I may or may not be right about this. But, you know, if that's the case, then I'd have even less cause to remember any given person or company.

Q. Mr. Wolf, you might not have seen the story lately, but you wrote it; did you not, sir?

A. That's entirely possible.

Q. You've not even gone back to look at what you wrote in connection with this lawsuit?

A. No. I have no way of accessing that story. The Business Report is not on file or microfilm, and I am not inclined to go around asking the people who have told me that they have a copy of that story, namely

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being Carol McKinley, if can have a copy of it. I have not asked anyone for a copy of that story. I'm -- it doesn't matter to me whether I read the story or not. What I told you is essential, the absolute truth about the story and about my knowledge, foreknowledge, my awareness of the company, of how Mr. Ramsey, his family, his daughter, or his company. I have no conscious awareness of those people, that company ever in my life that I'm aware of that I can recall.

Q. And the fact is, Mr. Wolf, you decided that if the police are not going to investigate your claims that you never heard of John Ramsey and you never heard of Access Graphics, then you're not going to help them and you're not going to investigate it yourself. Isn't that the truth of the matter?

A. Well, how would I be able to investigate that claim?

Q. By refreshing your recollection based on the article that you wrote. And you have not even tried to do that; have

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you?

A. I told you what I know about that article. I told you about what I know about all those articles that I wrote, you know, hundreds of articles that I wrote about business in which I -- the information went in one ear and out the other as soon as I could commit it to a piece of, you know, the computer file.

Q. In --

A. I don't feel that I need any more defense that I can get from seeing that article than that.

Q. Who is Cheryl ########?

A. I have no idea who she is.

Q. All right. She was quoted in your article, and she worked for Access Graphics. Does that refresh your recollection, sir?

A. No. I have no recollection of that name or talking to her.

Q. Who is Chris #######?

A. He is a friend of mine.

Q. You haven't named him yet today; have you, sir?

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A. No, sir, I haven't.

Q. Wasn't he a close friend of yours at one time?

A. He was at one time.

Q. Is he not now?

A. I hope so. I haven't talked to him for quite a while.

Q. In 1996, before the murder of JonBenét Ramsey, he was a very close friend of yours; was he not?

A. I had been living here for -- living in Colorado for quite a long time, and we hadn't seen each other. We had been very close friends for a couple of few years just prior to me moving to Colorado. And I would always hope and want him to be my friend.

Q. Are you in touch with him now?

A. I haven't been for quite a long time now.

Q. By whom was he employed when you last knew him?

A. Sun Microsystems.

Q. And, in fact, he shared with you, did he not, that one of his accounts was Access Graphics in Boulder, Colorado; didn't

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he, sir?

A. He may have, but I -- he talked about Access Graphics. I do not recall that he told me it was one of his accounts. But we talked about the company, but that was -- when he and I talked about that company, it was after the murder of the little girl. I don't know how long after. It was sometime after.

Q. Are you positive about that?

A. Yes, I'm positive about that.

Q. Where can we find Chris ########## now, sir?

A. I don't -- I don't really know. I'm sure he's in Baltimore. He has got two kids, and he's told me a number of times that he's never going to move because he's divorced and his mother lives there, and he can't see them if he leaves town.

Q. Mr. Wolf, you sought help, professional help from a therapist in 1992 because you felt you were unstable; did you not, sir?

A. No, I didn't feel I was unstable. I felt like I -- I've always felt like I was

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very stable, very, very stable; very willing and able to deal with a lot of confusion and stress resulting from being adopted and a lack of a firm identity that I struggled through my whole life to find, and at this point have really come as close as I've ever known. But I didn't seek that -- I sought that counseling or therapy, or whatever it was. Really, it turned out to be, what, an initial visit consultation. And I sought that because I thought it was my responsibility to do that at that point.

Q. Who was that therapist?

A. I don't know.

Q. Where was he or she located?

A. In Boulder.

Q. Male or a female?

A. A woman.

Q. Do you have any document that would help you give --

A. No.

Q. -- us her name?

A. No, sir. I'm sorry, I don't.

Q. In 1996, you were increasingly

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unstable, were you not, as that year progressed?

A. I would not say "unstable."

Q. In fact, you threatened to kill your boss ######## ######## at the Lyons Recorder; did you not?

A. No, sir. I've never threatened to kill anyone.

Q. I've heard you say that, Mr. Wolf, repeatedly.

A. Yes, and you will again, I imagine.

Q. That was -- you were fired by ######## ########--

A. Yes.

Q. -- only a few weeks before the murder of JonBenét Ramsey; were you not, sir?

A. I think it was much longer a period of time before that murder than that. I think it was a couple, a few months before that.

Q. Before the murder of JonBenét Ramsey, had you ever expressed the view that Lockheed Martin exported weapons?

A. I imagine I -- I don't know about

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specifically Lockheed. I don't think I had any particular pet defense contractor that I was, you know, on a bandwagon against. I think that, you know, Lockheed is one of a well-known handful of big defense contractors that make us the number one arms exporter in the country by far. And I was aware of that fact, and I have expressed that view.

Q. In the world.

A. In the world.

Q. And had you expressed the view before the murder of JonBenét Ramsey that Lockheed Martin was responsible for killing children all over the world?

A. I think my previous answer is sufficient. I think that the weapons that this country exports all over the world have killed many children, and I think that that's, you know, somewhat outrageous. I think that, obviously, we -- there are political struggles and disputes, and, you know, that thing does and will continue to happen. But I just hate to see people so willing to fan the flames of those problems.

Q. You had that view before the

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murder of JonBenét Ramsey; did you not, sir?

A. Yes, I certainly did.

Q. Mr. Wolf, your adoptive mother, #######, is blonde; is she not?

A. No, she's not blonde. She is brunette, and now she's sort of got frosted hair.

Q. She was a beauty pageant winner; was she not, sir?

A. She was a Home Coming Queen.

Q. When was that?

A. When she was in high school. She never was in a beauty pageant.

Q. And did you have a strong dislike, or do you have a strong dislike for your adoptive mother?

A. No, I don't have a strong dislike for her at all. I have a -- I have a somewhat of a difficult relationship with her that I've always tried to deal with as positively and constructively as I could.

Q. Have you ever owned a weapon?
A. No, sir.

Q. A gun?

A. No, sir.

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Q. A knife?

A. Well, a BB gun. And a Swiss Army knife.

Q. A stun gun?

A. No, sir.

Q. Have you ever used a firearm?

A. It's not my thing. I don't --

Q. Just tell me yes or no, please.

A. When the guns come out in the movies, I leave. I don't -- I'm not interested. I've never seen Speed. I don't see those kind of movies. I'm not interested in violence.

Q. Have you used a gun, sir?

A. No -- well, a BB gun. And, you know, I guess I -- I guess I shot a handgun once back when I was 20 at a friend of mine's farm. He had a-- he had an old, kind of a -- sort of a vintage firearm, and we fired it a couple -- once or twice. And I think that may have been the last time I fired a gun.

Q. Have you ever used a stun gun?

A. No, sir.

Q. Have you ever had one in your

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hands?

A. No, sir.

Q. Mr. Wolf, have you ever been a cross-dresser?

A. No, I wouldn't say that.

Q. Have you ever dressed in woman's underwear?

A. On Halloween I wore a dress.

Q. Have you ever dressed in woman's underwear?

A. No.

Q. Which Halloween did you wear a dress?

A. Last Halloween.

Q. Do you, from time to time, shave your legs?

A. Yes, sir.

Q. How long have you been doing that?

A. Since I was racing bicycles. And I don't do it on any regular basis at all. I've done it probably six times in my life. Mostly when I was bike racing, which I did that for three years.

Q. Do you dial what I will refer to as pornographic telephone lines?

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A. I have.

Q. While you were living with Jackie Dilson, did you do that?

A. Yes, sir. I regret to say that I did. I realize that that was not the right thing to do when you live with a woman.

Q. Do you frequent what I refer to as porn shops?

A. Yes, sir. I have been to them on a number of occasions over many years.

Q. This is true throughout the '90s and before?

A. Uh-huh (affirmative).

Q. Did you tell Ricky Elsey that you enjoy staring at school girls?

A. No, sir.

Q. Did you own a pair of Hi-Tec boots? And I want to get the spelling correct, H-i, dash, capital T-e-c.

A. No, sir. I never owned a pair of Hi-Tec boots. I own a pair of Danner boots that Jackie bought me.

Q. If Jackie Dilson or Ricky Elsey or anyone else said that you had owned a pair of Hi-Tec boots, they were simply mistaken or

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lying; is that correct?

A. They were lying because -- yeah, simply mistaken or lying, yes.

Q. Well, I said mistaken or lying, but in fact, your answer began with they were lying; didn't it, sir?

A. Well, Jackie knew what kind of boots that I wore. So if Jackie said they were Hi-Tec boots -- Jackie bought those boots for me, so I -- I don't know. I guess she wouldn't know one brand for another, so she could be mistaken. But I've got those boots in Kentucky, and I can produce them for you at any time you want.

Q. Did you borrow a long, black metal flashlight from Jackie Dilson's home?

A. No, sir.

Q. Ever?

A. I didn't know that -- I didn't know her to have one, and I have not borrowed one for any purpose.

Q. Did the police ever even show you one?

A. I don't think so.

Q. You were a rock climber at one

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time; were you not, sir?

A. Yes, sir.

Q. You became very familiar with knots during your rock climbing; did you not?

A. Climbing knots.

Q. Yes, sir.

A. Well, and it was definitely my weak point as a climber. Knots and the mechanics.

Q. In your bathroom at Jackie Dilson's home, could Ricky Elsey have found five pairs of little girls underwear?

A. I didn't have a bathroom that was my bathroom. Jackie and I shared the bathrooms. And I guess he could have found -- I mean, Jackie had lots of people over, and, you know, the place was a bed and breakfast, and a conference center, and there were children there. And for all I know -- I mean, everything else that he has apparently said to you has been a lie, so I assume that that may be, too, although he may have found five pairs of children's underwear in the bathroom.

Q. Let me put the question to you

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this way. Did you bring little girls' underwear into the Dilson home, sir?

A. No, sir.

Q. Have you ever --

A. No, sir.

Q. -- collected little girl's underwear --

A. No, sir.

Q. -- of the size that might be worn by a four, five, or six-year-old girl?

A. No, sir.

Q. And if, after your truck stopped to open a gate, in the plain view of Ricky Elsey and Jackie Dilson, and very soon thereafter, a little pair of little girl's underwear was found right where it might have fallen out of your automobile or truck, it didn't get there from your vehicle?

A. Well, I didn't own a truck. Jackie owned a truck. And if Jackie had little girls' underwear in the car and it fell out when I opened the door, that may have happened, but I don't have anything to do with any little girl's underwear.

Q. With Jackie Dilson, did you ever

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engage in a fantasy that she was a six-year-old girl?

A. No, sir.

Q. Did you ever put your hands around her neck and squeeze her neck?

A. I have put my hands around her neck. I have never squeezed her neck.

Q. When did you put your hands around her neck?

A. I did that as sort of a joke because she had told me that she has fantasies of being killed during having sex, which I thought was strange, and I didn't want to participate in any play, in any playing around like that with her, but I -- at one point, as I recall, as I have been reminded by people who reminded me about that incident in regards to this case, I think I do recall one time trying to -- going in to wake her up and in so doing, putting my hands gently, without any pressure that would cause even the slightest bit of injury, around her neck sort of as a joke, which sort of came to me just as the spur of the moment. And I-- you know, relating to her

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having told me that she has a fantasy of being murdered during sex. So I, you know, I don't know anything about S&M or violence or anything like that, and I never played any of that, anything like that with her or anyone else, but I did do that sort of kind of stupid thing at one point, as I recall.

Q. Did you tell Jackie Dilson soon after JonBenét Ramsey was murdered that you would never strangle anyone with your hands; you would always use a rope?

A. No, sir. No. I never said anything like that.

Q. That seems funny to you; didn't it?

A. It's so, so ridiculously out of character for me to even discuss things like that. I'm not interested in violence. I'm certainly not interested in harming a child.

Q. Your personal possessions, Mr. Wolf, when you lived with Jackie Dilson included clippings of news stories about JonBenét Ramsey; didn't they, sir?

A. No, sir, absolutely not.

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Q. It also included clippings of news accounts about the murder of Susanna Chase; didn't they?

A. I kept one story about Susanna Chase. It was the story in the Boulder Planet because it was such a nice picture of her. And -- and I did know her, and I knew her because she was a clerk at a grocery store that I went to often. And she was a wonderful, beautiful, young woman who I found, you know, charming and delightful to, you know, chat with in the process of going through the line. And would certainly never, ever want any harm to come to a person like that or really anyone. That's not even considering the idea that I -- well, you haven't suggested that I harmed her, and that's fine.

Q. Yes, it's unnecessary for you to deny that, Mr. Wolf. You once lived in an apartment near 19th Street and Pearl, did you not, in Boulder?

A. Uh-huh (affirmative).

Q. How far was that from the site of

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her --

A. It wasn't -- it was 20th and -- 20th and Pine.

Q. Okay. How far was that, approximately, from the site where her body, Susanna Chase's body was found?

A. I think it was just a few blocks. It was diagonal about -- it was south about a block and a half, and then west about two blocks or so. I don't know where, exactly where her body was found, but I know the general area, and it was a -- it was terrible shock to me to have heard about that.

MR. RAWLS: Mr. Gallo, would you please mark this as the next Defendant's exhibit, please. Is that 4? (Defendant's Exhibit-4 was marked for identification.)

MR. RAWLS: This is a blank sheet of paper that I marked as Defendant's Exhibit 4, and because it's blank, Evan, you probably have no interest in seeing it, and I have no real need to show it to Darnay.

MR. ALTMAN: No objection.

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Q. (By Mr. Rawls) Mr. Wolf, may I hand you Exhibit 4, and may I also ask you to please take a pen or pencil of your choice from the table here. Would you write several words for me, please, in your own hand? "John." (Witness complies with request of counsel.)

Q. "Ramsey." (Witness complies with request of counsel.)

Q. "Police." (Witness complies with request of counsel.)

Q. The phrase "grow a brain." (Witness complies with request of counsel.)

Q. The word "connotation." (Witness complies with request of counsel.)

Q. The word "possessed." (Witness complies with request of counsel.)

Q. Thank you. I appreciate you

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complying with that request. May I see that, please?

A. Still trying to frame me.

Q. Mr. Wolf, you may accuse anyone that you care to accuse. And I have no doubt, given your testimony today, that you will do that.

MR. RAWLS: Will you please keep this with the original exhibits, Mr. Gallo?

Q. (By Mr. Rawls) What does "SBTC" mean to you, sir?

A. Nothing.

Q. Did you ever have a sweat shirt or a T-shirt with those letters on it?

A. No.

Q. Do you have some familiarity with Santa Barbara?

A. I've never been there.

Q. Have you ever had a T-shirt or sweat shirt with the name Santa Barbara on it?

A. Jackie's son gave me a T-shirt with the name Santa Barbara on it.

Q. Was there any other language on that T-shirt?

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A. Not that I recall.

Q. Do you still own that T-shirt?

A. No, sir.

Q. Do you still own a blue sweater that, according to Jackie Dilson, you were wearing on December 26, 1996?

A. I remember that sweater, and I don't have that sweater anymore. I haven't for some time. It was a rag when, at that time, I think.

Q. Where is that sweater?

A. I have no idea. It's been garbaged a long time ago.

Q. Have you regularly taken any medication during the 1990s --

A. No, sir.

Q. -- up through today?

A. No, sir.

MR. RAWLS: Let me suggest we take five or six minutes. And I want to confer with my colleagues, look at my notes, and gather a few exhibits, and then we'll come back and see if we can conclude after a few more minutes. Thank you.

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THE VIDEOGRAPHER: We are off the video record at 5:49. (A recess was taken.)

THE VIDEOGRAPHER: We are on the video record at 6:04.

Q. (By Mr. Rawls) Mr. Wolf, who trained you in your use of knots?

A. Oh, friends that taught me climbing and -- yeah, mostly friends who taught me climbing.

Q. Who?

A. I don't know. People I don't remember their names now, a long, long time ago.

Q. What knots were you taught?

A. Figure 8, overhand knot, a bowline.

Q. A slipknot?

A. I don't call a bowline a slipknot.

Q. No. Were you taught a slipknot?

A. No. That's not a climbing knot.

Q. What other knots were you taught?

A. Those are the main ones. The only other one that I'm thinking of, and I don't recall what it's called is a -- is a

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knot that links two strands of rope together end to end, and it is just a figure 8 that you follow through from -- with the other end. Those are the only knots I know besides a bow and a square knot.

Q. Is that a sheepshank?

A. That could be. I don't really want to say that for sure. I don't know that that's what that's called.

Q. When in your life did you do rock climbing?

A. Age 20. Maybe 20 -- probably 20 through -- I don't know. Let's see. I guess, yeah, I guess, 21 or 22 through 30. Not continuously, but --

Q. Did you do any rock climbing after age 30?

A. No. Nope. I pretty much quit.

Q. Tell me, sir, your e-mail addresses for the last five years.

A. I only have ever had one, and that is ############

Q. Is that still --

A. Yes.

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Q. -- your e-mail address?

A. Uh-huh (affirmative).

Q. Have you taken part in internet forums?

A. No.

Q. Chat groups?

A. No.

Q. Any internet exchanges concerning JonBenét Ramsey?

A. No.

Q. Or the murder investigation of JonBenét Ramsey?

A. Well, I corresponded by e-mail to Mr. Wood last week just to correct him on a false -- an inaccurate quote that he said about me in the Westword.

Q. Any other use of the internet concerning JonBenét Ramsey by you?

A. I check the Boulder Camera for stories occasionally. And this has only been -- I guess it's been, maybe -- maybe a year that I've been doing this at all. And over the past year it's been very sporadically that I've done it at all. But over the past year, I have

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looked at Mrs. Brady occasionally, and Boulder Daily Camera, and, oh, some of those others that are listed under Ramsey, but no chat rooms, or I've never sent any responses or anything like that to any questions or polls or comments, or anything like that. I've just tried to keep up on -- I've just looked at it to keep up on anything resembling news that has happened just in the last year, and not prior to that.

Q. Mr. Wolf, when you worked as a stripper with a variety of agencies, as you told us about earlier in this deposition, did you ever, from time to time, dance at a strip club?
A. I have danced at a couple of strip clubs, just sort of like applying for a job or trying to get a job working at these clubs in New Orleans. And I didn't really want to continue working at any of those places.

Q. Did you get turned down at any of those places?

A. Oh, I guess you'd say that, yeah, but it was -- the feeling was mutual, and

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that was probably why. Although --

Q. So on occasion, you got turned down as a dancer at strip clubs and decided after you were turned down that you didn't really like the club anyway. Is that what you are --

A. You could say that if you want.

Q. Well, is it true, Mr. Wolf?

A. It's true in the reverse order, too. I didn't like them, so why would they like me?

Q. Well, who spoke first about the liking or disliking, Mr. Wolf? Were you told first that you were not going to be hired, or did you say, first, that you did not care to apply?

A. Oh, I can't recall.

Q. Mr. Wolf, did you ever see the movie Dirty Harry?

A. Yeah, I saw that movie. Yeah. I think I may have probably fell asleep. I don't remember anything about it.

Q. Did you see the movie Ransom?

A. No, sir.

Q. Did you ever see the movie Speed?

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A. No, sir. Never heard of it -- never heard of Ransom or Speed except for in regards to this case.

Q. When did you see the movie Dirty Harry?

A. I guess when it was -- came out or soon thereafter in the '70s. I don't like those kind of movies. And, I mean, when you're that -- when you're a kid, you know, you end up going to things that you don't know whether you want to be there or not sometimes. And I didn't like it then, and I haven't made a point of seeing those kinds of movies as I have gotten older.

Q. How many of the sequels to Dirty Harry did you see?

A. None.

Q. Can you tell me their names?

A. No, sir. I never heard of them. I didn't know there were any.

Q. Have you in the last ten years used illegal drugs?

A. Yes, sir.

Q. What drugs?

A. Marijuana.

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Q. Any other drugs?

A. Ecstacy.

Q. Any other drugs?

A. No.

Q. How regularly did you use marijuana?

A. Regularly, until a few -- a couple of years ago. I'd say, oh, often, a few times a week.

Q. You were a regular marijuana user in 1995, 1996, and 1997?

A. Yes, sir.

Q. How frequently did you use Ecstacy?

A. I have only done that three times in my life.

Q. When?

A. This past fall.

Q. All three times this past fall?

A. Yes, three out of four weekends.

Q. Never before the murder of JonBenét Ramsey?

A. Never before the murder of JonBenét Ramsey.

Q. Have you ever been arrested for

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drug use?

A. No, sir.

Q. For drug possession?

A. No, sir.

Q. For drug dealing?

A. No, sir.

Q. Have you ever sold illegal drugs?

A. No, sir.

Q. Have you ever been arrested for drunkenness?

A. No, sir -- well, yeah. I was in Dallas, I think I told you about. I -- but like I said, I mean, I was taken in handcuffs and put in the drunk tank, but I did not receive paper or court date. I never did anything more on it. So I figured I was not arrested. I mean, if you want to -- if you call that arrest, I don't know. I mean, it worked fine for me. I was probably a danger to myself being that intoxicated. I was about 22. And I was drunk as I've ever been, and I ended up in the drunk tank for the night. It was basically like a -- it wasn't a police station. It was a Salvation Army drunk tank

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or something. I don't know what. But they just let me out the next day, and I went home and never did anything more about it.

Q. How many times have you been, in the last ten years, have you been so drunk as to be a danger to yourself?

A. Well, oh, I don't know. A few, I guess. I mean, I never hurt myself. I never had a car accident when I was drunk, so I shouldn't say I was probably a danger to myself. I've never injured myself drinking, and I've never injured anyone else drinking, as a result of drinking. So -- so I don't think I was a danger to myself that night. I was just very, very drunk, and I guess they didn't appreciate it, the police.

Q. Mr. --

A. And as far as in the last ten years, I was very drunk over Mardi Gras in 1999, when I lived in New Orleans; but other than that, I haven't gotten that drunk for, like, I don't know, 15 years since I consumed that much alcohol. I had a few beers to watch a baseball game is all, except for Mardi Gras, in the last 15 years.

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Q. Why did you not consult an attorney given your concern that you have outlined for us today about the Lawrence Schiller book?

A. Given my concern about the Lawrence Schiller book? What concern?

Q. Why didn't you consult an attorney about a possible action involving Mr. Schiller's book on your behalf?

A. Because I thought that that was basically accurate, and I thought that he said that I had been cleared as a suspect.

Q. Mr. Wolf, you told us very early today that your paternal grandparents with whom you are living currently do not know about this case, and you do not want them to know about this case.

A. That's right.

Q. Why do you not want them to know about this case?

A. I think for obvious reasons.

Q. This is a case in which you are trying to uphold your reputation; is it not, sir?

A. You could say that.

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Q. Aren't you proud of this case?

A. I would say I'm more likely trying to -- oh, well, okay, yes. I'm trying to uphold my reputation. I'm trying to right a wrong that was done to me. And so in that sense, yes, I'm, I guess -- I wouldn't say proud. It's not a kind of situation that anybody probably particularly would like to be associated with, but I guess I'm committed to trying to get justice for myself regarding this case.

Q. Are you or are you not proud of your lawsuit?

A. I don't think I'm proud or not proud. I don't think that that is an applicable word. I'm just doing what I feel like has to be done.

Q. Have you visited internet pornography sites?

A. No, sir.

Q. Ever?

A. I have seen them over someone's shoulder once.

Q. Where? Whose shoulder was that?

A. Some person in New Orleans.

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Q. Was this at one of your performances?

A. No.

Q. Who was the person in New Orleans, please?

A. It was a person that I knew who was a gay man who was attracted to me and who I went to his house to ask him if I could borrow money.

Q. Do you recall his name?

A. No, I don't.

Q. Where do you access the internet from at present?

A. From the Lexington Public Library.

Q. And in the past, where have you gotten access to the internet?

A. Boulder County Public Library.

Q. Where else?

A. That's all.

Q. In connection with your first conversation with Darnay Hoffman, who initiated the contact, you or Mr. Hoffman?

A. I don't recall.

Q. At that time, were you aware that Darnay Hoffman had filed a lawsuit in his own

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name against the Ramseys arising out of the publication of the book The Death of Innocence?

A. I was aware that he was a vocal critic of the Ramseys and the investigation and the Boulder authorities, but I don't think that I was specifically aware that he had filed a lawsuit.

Q. Are you aware of that now?

A. I've read that.

Q. Before today?

A. Before today.

Q. Mr. Wolf, earlier today -- and this was on page 245 -- excuse me, 244 and 245 of your deposition. I'd like to read you a couple of questions and answers to remind you what you testified. I asked, "Did you ever put your hands around her neck and squeeze her neck?" We were referring to Jackie Dilson. Your answer was, "I have put my hands around her neck. I have never squeezed her neck." That was your answer. I then asked you, "When did you put your hands around her neck?" You spoke

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of you did that as sort of a joke. You spoke about her having fantasies of being killed during sex --

A. I told you she had told me that she had those. I did not know that she had those.

Q. Absolutely. And I don't mean to be, by paraphrasing, I don't mean to be changing this record at all, and I'm not -- I don't have the power to do that. And believe me, I do not wish to do that. But I did want to get to the part of your answer I wanted to ask you about. And that was the following: Quote: At one point, as I recall, as I have been reminded by people who reminded me about that incident with regard to, say, this case, I think I do recall one time trying to, going in to wake her up. Do you recall that testimony that I just quoted?

A. Yes, I do.

Q. All right. Who were the people who reminded you about that incident?

A. I can't really remember. I was

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trying to think of the answer to that question at that time I was talking about it, and I guess I just -- I guess it was somebody in Boulder who was sort of a kind of a little -- sort of -- I don't know. Either a reporter or a, sort of just some sort of, a kind of a Ramsey -- Ramsey investigation groupee or something. But I guess it must have been a reporter; although, I don't know. It could have been some -- just some other sort of little groupee kind of person.

Q. No name comes to mind right now?

A. I don't recall who may have been telling me about that.

Q. What, Mr. Wolf, have you done to prepare for this deposition?

A. I've thought about my reasons for filing this lawsuit, and I read the number -- some of the books, looked at some of the -- looked at mostly Steve Thomas' book. And I have just tried to prepare myself for you all to slander and intimidate me like you have been doing.

Q. Mr. Wolf, thank you for that.

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A. Sure.

Q. I appreciate that.

A. Well, sir, when you ask me to write six words that you are going to, apparently, get some bogus handwriting analysis to say that they look like that ransom note, what do you expect me to say?

Q. Thank you again, Mr. Wolf. And please don't volunteer testimony that is not an answer to my question. All right? It's getting late in the day. I know you're exhausted.

A. I'm fine.

Q. I am tired.

A. What good is six words?

MR. ALTMAN: Just answer the question. THE WITNESS: All right.

Q. (By Mr. Rawls) Mr. Wolf, what else did you do in preparation for this deposition?

A. I thought through a lot of what I have been doing at different points along the line, at different points in this case, and what I have been thinking or doing, or where

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I had been. I thought about dates and itinerary as far as moving here, there, which jobs I had when, who I talked to when, which reporters I talked to in sequence at what time. And I thought of all -- I thought of all the reasons why I'm here to tell you how wrong this whole thing has been regarding me. And for no fault of my own. For only the -- for only the fault of the wealth and power of the Ramseys who have bought the district attorney's office.

Q. Did the Ramseys ever buy Jackie Dilson?

A. I imagine they probably did.

Q. Mr. Wolf --

A. And if they didn't, they certainly did appropriate her.

Q. Apart from the argument and speeches you wish to make, have you otherwise answered my question?

A. Yes, sir.

Q. And finished?

A. Yes, sir.

Q. Now, Mr. Wolf, what other

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documents did you read that you have not told me about yet in preparation for this deposition?

A. I don't think -- I didn't even read -- I read the -- I read a few chapters of the Steve Thomas' book, and -- because I started that book back maybe a year or more ago. I read about maybe a -- not quite a third of it. I really don't like reading those kind of books. It's very literal writing. I'm just bored by it, and I couldn't really keep up and hang with it. So I stopped about maybe close to a third of the way through. And then I, in the last few days, prior to this deposition, I picked it up and read another 50 to 60 pages over two days. And as far as anything else I have read, Darnay asked me to read the complaint, and I could not find my copy of the complaint because I have moved. And I just have -- that's all. I don't think I've read anything else.

Q. How long did you spend talking with your attorneys in preparation for this

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deposition?

A. Oh, Darnay and I have talked frequently, sometimes more than others, and certainly in the last week or so or couple weeks leading up to this, we've talked pretty frequently. I don't know. Is this attorney-client privilege at all?

Q. The question is, How long? I don't care what you said.

A. How many hours all together?

Q. Yes, sir.

A. Over what, two weeks, over the last two weeks?

Q. In preparation for this deposition.

A. In preparation -- in preparation for this deposition, well, I don't know. Maybe an hour. And, basically, all he's told me is I just need to be honest. And I don't -- he has not told me anything particular or specific to say or not say. He's just -- he's basically, as he's done a lot of the time over the year or more than year that he's been handling this case for me, he's tried to calm me down and make me feel somewhat, you know, kind of

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less --

Q. Mr. Wolf. I'm am sure Mr. Hoffman --

A. -- less worried about it.

Q. -- is a true humanitarian and is very interested in the search for the truth here, but I do not want to know what he told you. Just how long, sir, and you've answered that. You said about an hour.

A. Okay.

Q. All right? And I will stipulate that you made no attempt to waive the attorney-client privilege in the self-serving argument that you just made to me about in the conversations that you and Mr. Hoffman have had. All right?

A. Sure.

Q. Mr. Wolf, which investigators in the Boulder Police Department have given you evidence?

A. None.

Q. Have given you information about the investigation into the death of JonBenét Ramsey?

A. I wouldn't call anything that I

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have been told information.

Q. Earlier today, and this was at page 70, line 8, of your deposition, you referred to a person with whom you lived for a short period of time who was a friend of yours before and since. And then you said, "although she is dead." Who is that person?

A. Yeah. I remember both of those people. R#######

Q. How did she die?

A. She died in a bicycling accident.

Q. When?

A. Ah, must be -- must be a couple of years ago now. Maybe it is two years this summer. It might be three years this summer. I bet it's three years this summer.

Q. Was it a collision with an automobile?

A. No. As I understand it, what I have been told is that she hit a rock going down a steep hill, flew off her bike, hit her head, and died pretty much on the scene.

Q. Mr. Wolf, at page 172 of your deposition today, you testified -- and this

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I'm going to read, beginning at line 8, actually line 7: "He said, Listen to me, you are not a suspect." And this was Tom Whitman.

A. Uh-huh (affirmative).

Q. Quoting you again, "So that was the third time I had heard that from the police, and, of course, that was nice to hear, but, nonetheless, I knew it wasn't the end of my problems with this." The first question I want to ask you is, what were the other two times?

A. The first time was with -- was a week after I had initially been pulled in when John Eller told me, We have no interest in you in this case. The second time was when Carey Weinheimer told me, What are you worried about? You don't have anything to worry about.

Q. Did she tell you why?

A. That's a he.

Q. Did he tell you why?

A. No, she wasn't more specific. So you might construe that as not being told I

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was cleared, but I did at that time.

Q. Those were the two times?

A. Those were the two times prior to Tom Wickman telling me, You are not a suspect. And then Michael Kane saying, You don't have anything to worry about. Being a material witness in a grand jury investigation is different than being a target.

Q. And, Mr. Wolf, the other question I have for you about that previous testimony which I just read to you is, why did you know that was not going to be the end of your problems?

A. Well, because I knew that they were just taking all the evidence in, and, for all I knew, I was still being set up to be framed. For all I know, I still am. I mean, at that point -- the first time I refused to cooperate with the police, a few weeks after the murder, I was naive enough to think that it would be resolved. And since I didn't have anything to do with it, and that I would be -- I wouldn't have -- I really half-expected or maybe probably three-quarters expected not to

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hear from them anymore at that time. And so by the time Carey Weinheimer asked me to come in, I was aware that it wasn't going to end at that point for me.

Q. What was not going to end, sir?

A. The problems. The stress, the worry, the burden.

Q. Did you bring more of those problems on yourself by filing this lawsuit, sir?

A. The way I see it, sir, is that when the parents of the murdered child published a book specifying me as someone who they thought could be or was possibly responsible for such a crime as that, and then went on national television and, for whatever reason, were able to get my picture posted on national TV on the Today Show, and say things like, We're still investigating him, we have a lot of unanswered questions, he represents a lot of unanswered questions still; at that point, I felt like it was certainly a case of lesser of -- a worse of two choices, whether to file a lawsuit or not

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file a lawsuit. But I decided that I did not want the Ramseys or anyone else to think for a minute that I could or would ever do such a thing as that. Because that's really important to me, as you might understand, as you might think it might be important to you if someone were trying to suggest to the rest of the world that you were the kind of person that could do something like that.

Q. Mr. Wolf, if you're finished with your speech --

A. I'm answering your question.

Q. -- let me ask you to answer my question yes or no. Did you bring any of those problems on yourself by filing this lawsuit?

A. I'm trying to solve those problems by filing this lawsuit.

MR. RAWLS: Would you, please, Mr. Gallo, mark this as Defendant's Exhibit 5. Evan, here's a copy. (Defendant's Exhibit-5 was marked for identification.)

Q. (By Mr. Rawls) Mr. Wolf, the

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document you've just been handed by Mr. Gallo is Defendant's Exhibit 5. It purports to be a copy of a letter to you from November 7, 1989. Would you take a moment and see if you recognize that letter, please.

A. Yes, I guess I do recognize this. This is -- this is -- this never came to pass at all.

Q. The letter did come to you; did it?

A. I do recall this. And this is really, I think -- I think I was -- I wonder how in the hell you got a copy of this letter.

Q. Well, I don't doubt that, Mr. Wolf, given your testimony.

A. You guys must have your ways. Well, I never saw Bill McReynolds as academic advisor. This never happened.

Q. You were advised in writing that your academic advisor would be Bill McReynolds; were you not, sir?

A. And now I'm trying to wonder what you might be trying to prove as a result of suggesting that I -- that Bill McReynolds was

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my academic advisor. What would that mean to you?

Q. Mr. Wolf, would you please do your wondering --

MR. ALTMAN: Just answer the question.

Q. (By Mr. Rawls) -- when you're not required to answer my question because you'll have a lot of time to wonder about that, but could you just answer the question?

A. What question?

Q. You received this letter; did you not, sir?

A. Yes, I did. I think I recall receiving this letter.

Q. And it told you that your academic advisor would be Bill McReynolds; did it not, sir?

A. Yes.

Q. So you can understand a certain amount of surprise on our part when we heard your testimony earlier today, could you not, sir?

A. Well --

Q. But that doesn't matter, and I'll

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withdraw the question.

A. -- it doesn't matter because he was never my academic advisor for any, any significant period of time or for any portion of my time in school. I, in fact, I -- my academic advisor at that point, for whatever reason, and I can't recall why it was changed, but my academic advisor was Frank Kaplan. And he was my first academic advisor. And then that did change later, but Bill McReynolds never did serve as my academic advisor. I mean, so I guess you can't imply that me and Bill McReynolds sat in his office in the university in the journalism school and discussed whatever you might imagine.

Q. Mr. Wolf, there's no question pending, but are you finished --

A. Yes, sir.

Q. -- with your remarks --

A. Yes, sir.

Q. -- about Mr. McReynolds? Thank you. You know you have filed a lawsuit

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for libel; do you not, sir?

A. Yes, sir.

Q. And you know you filed a lawsuit in which you claim that Patsy Ramsey murdered her daughter; do you not, sir?

A. Yes, sir.

Q. Do you understand that, when a plaintiff files a libel lawsuit, that plaintiff puts his character in issue?

A. Yes, sir.

Q. Do you understand that?

A. Yes, sir, I understand that.

Q. And that plaintiff puts his reputation in issue. Do you understand that?

A. Yes, sir, I understand that.

Q. Do you understand that you have put your reputation in issue by filing this lawsuit?

A. I understand that now, and I understood that at the time that I decided to file this lawsuit.

Q. And you understood that you have placed your character in issue; did you not, sir?

A. Yes, sir.

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Q. And you understood that it was my duty to ask you questions about matters about your private life that I wish I never knew about. Did you understand that?

A. Sure.

Q. Do you know, Mr. Wolf, that I've never in my life in a legal profession or in my private life asked someone about their masturbation practices, and I wish I didn't have to do that today; do you recognize that?

A. Yeah, and I imagine that some of the attorneys involved in this case never asked people about how a six-year-old child was murdered, brutally tortured and murdered either, and had vaginal trauma either. And nobody has asked me about any of those things.

Q. Mr. Wolf, you're going to get your day in court, Mr. Wolf, in this case. Today it was our job to try to learn some information about Chris Wolf, his character, his reputation, and his conduct, and I compliment you for having sat through that today, and I appreciate your having done that.

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MR. RAWLS: I have no further questions. Mr. Hoffman and Mr. Altman have a right to ask you questions at this time.