John Depo: Part 1
Page 1 of 1
John Depo: Part 1
by Mama2JML Sun Jan 06, 2013 11:25 pm
John Ramsey Deposition
Wolf v Ramsey Lawsuit
Date of Deposition = December 12, 2001
Source: Daily Camera Newspaper
THE VIDEOGRAPHER: We are on the video record at 9:49.
MR. HOFFMAN: Good morning. This is the deposition of John Ramsey in the case of Robert Christian Wolf versus John Bennett Ramsey and Patricia Paugh Ramsey. I am the lead counsel for the plaintiff Chris Wolf. Would the gentlemen here identify themselves?
MR. WOOD: My name is Lin Wood. I represent the defendants John and Patsy Ramsey.
MR. RAWLS: My name is Jim Rawls. I am co-counsel for the defendants, John and Patsy Ramsey.
MS. RAMSEY: I am Patsy Ramsey.
MR. PAULK: Mahaley Paulk.
MR. SCHROEDER: Eric Schroeder.
MR. ALTMAN: Evan Altman, co-counsel with Darnay Hoffman, representing the plaintiff.
MR. WOOD: The deposition is taken pursuant to the Federal Rules of Civil Procedure. The deposition is taken pursuant to agreement of counsel. The deposition is taken pursuant to astipulation and protective order agreed to by all parties, which protective order specifically states, as we went over yesterday, the right of counsel to make sure that this deposition is not abused and that only areas that are relevant to the claims and defenses in this lawsuit are inquired of today in this deposition. Anything you want to add to that, Mr. Hoffman?
MR. HOFFMAN: No. Sounds like pretty much what we agreed yesterday was the case. And I believe yesterday you also explained what you believe the claims were, in fact, that would be relevant with respect to the deposition. So based on yesterday's statement, we will just continue the deposition.
MR. WOOD: Do you want to swear the witness, please.
JOHN RAMSEY, having been first duly sworn, was examined and testified as follows:
EXAMINATION BY-MR.HOFFMAN:
Q. Your full name, please, sir?
A. John Bennett Ramsey.
Q. Have you ever attended a deposition before?
A. Yes.
Q. Are you familiar with the deposition procedure?
A. I wouldn't say I am familiar with it. I have been at one deposition.
Q. All right. If at any time you don't understand -
MR. WOOD: He will answer questions, and he understands how to proceed with answering your questions. You do not need to counsel or advise him in that regard. Your job is to ask questions. If you would, go ahead and pose a question to the witness, please, sir.
MR. HOFFMAN: This is my deposition, Mr. Wood.
MR. WOOD: It is your deposition, but you are not here to lecture or counsel or advise my witness on what he is or is not to do. Trust me, he will answer your questions, and if he doesn't understand them, he will so indicate. Ask your first question, please.
Q. (By Mr. Hoffman) Mr. Ramsey, who is Chris Wolf?
A. Chris Wolf is your client, and he isa person who came to our attention as someone who should be looked at as a possible suspect in the murder of our daughter.
Q. Do you remember how Mr. Wolf came to your attention as a possible suspect?
A. I believe he contacted my wife's parents - no, I am sorry. His girlfriend contacted my wife's parents and said she firmly believed that he was the killer of my daughter, that he had been out all night and returned home early that morning, and that we needed to look at him.
Q. Do you know what was done with that information when your parents were - or Mrs. Ramsey's parents were given that?
A. I am sure we referred it to our attorneys through - or through our attorneys to our investigators.
Q. All right. Do you know which investigators were responsible for investigating that claim on your behalf?
A. Not for certain. I think probably they were involved, each involved at different stages.
Q. Do you know the names of theinvestigators that were involved?
A. I do.
Q. Could you give me their names?
A. Well, there was a group called Ellis Armistead & Associates. David Williams. John - and I can't think of his last name. Those were the principal investigators that our attorneys retained.
Q. Without revealing the substance of what you were given with respect to any reports that your investigators may have given you, do you remember if you ever saw any investigative reports concerning Chris Wolf?
A. I don't remember seeing any investigative reports regarding Chris Wolf.
Q. Do you remember whether or not you were shown investigative reports with respect to any of the other potential suspects that you may or may not have been looking at?
A. I don't recall ever seeing a report on any suspect that they might have looked at.
MR. HOFFMAN: All right. For the purpose of my next question, I would like the court reporter to please mark this as Plaintiff's Exhibit 14 for identification. And, actually, Iam going to turn to the portion to which I am going to direct Mr. Ramsey to look at this.
(Plaintiff's Exhibit-14 was marked for identification.)
THE WITNESS: You want me to read this part that is highlighted?
Q. (By Mr. Hoffman) Yes. After you had an opportunity to read it to yourself, please read it out loud.
A. You want me to read it out loud? I am sorry; I wasn't listening. I was reading.
Q. Yes, Mr. Ramsey.
A. "Katie Couric: You also mentioned Chris Wolf, a total stranger whose girlfriend reported that he had disappeared on Christmas night and was very agitated rather when he watched the news of the murder on TV. "John Ramsey: Uh-huh. "Katie Couric: Why do you mention him? "John Ramsey: Because he had been widely mentioned in the news, and we wanted to clarify the facts that we knew. "John Ramsey: I can tell you when, when we first startled looking at it, oneparticular lead early on, my reaction was, 'This is it. This is the killer.' And our investigators said, 'Whoa, whoa, whoa,' he'd say, 'Don't do a Boulder police on me. Don't rush to conclusions.'"
Q. Do you remember making this statement?
A. I don't remember making the statement, but that was a number of years ago, I guess, so....
MR. HOFFMAN: In fact, just simply for the record, I believe this is the Katie Couric Today Show. It was aired on, I believe, March 24th. And I believe it was in the year 2000.
MR. WOOD: Are you talking about his statement to Katie or the statement to the investigator?
MR. HOFFMAN: The statement to Katie that -
MR. WOOD: Did you understand he was asking you if you remember making a statement to Katie as opposed to the investigator?
THE WITNESS: Yeah.
Q. (By Mr. Hoffman) Okay. Now, do you remember who it was that you were - that you made the statement, This is it, this is the killer? Do you remember who that person was, the investigator that had shown you material on it?
A. Yes.
Q. Can you name that person?
A. I don't recall his first name. Helgoth was his last name, a fellow that committed suicide on Valentine's Day, the day that Alex Hunter told the world that they were going to get the killer.
Q. Right. So you were not referring to Chris Wolf in that statement; is that correct?
A. No. That is correct.
Q. Now, I want to ask you, in the statement, there is a reference to an early lead. What kind of lead was it? Was it - you know, specifically. Since you weren't shown any files.
MR. WOOD: Do you mean how was he imparted, the information imparted to him by Helgoth?
MR. HOFFMAN: Yes. I had asked him earlier if he ever had an opportunity to review any of the investigative files on any of the murder suspects.
MR. WOOD: No, you didn't. Youasked him if he had ever reviewed any investigative reports.
MR. HOFFMAN: All right. Reports.
MR. WOOD: And now you are asking him how he obtained the information about Helgoth?
MR. HOFFMAN: Uh-huh, yes. If he hadn't seen any investigative reports.
THE WITNESS: I think - I don't recall specifically whether my attorney told me about him or one of the investigators, but typically I communicated with my attorney.
Q. (By Mr. Hoffman) Were you actually shown evidence or were you just simply given a summary?
A. I have not seen any evidence that the police have.
Q. Any evidence that your investigators have?
A. I have seen a few things relating to your client. I don't know that I have seen anything relating to Helgoth.
Q. All right. Were you involved in directing the activities of these investigators that were working on your behalf?
A. I was not.
Q. Then what was, basically, your association with the private investigation of the potential suspects in the murder of JonBenet Ramsey?
A. The investigators were retained by our attorneys, and they stated to me that the principal purpose of those investigators was to prepare a defense in the case that the police might bring a charge against me. I hoped that they would also follow up on leads that came to us, but I was frequently reminded by our attorneys that their principal role was to prepare a defense should that be necessary.
Q. For a moment, I just want to direct you to the morning of December 26th. And to the degree that you can remember things today, I would like to ask you if you could just briefly summarize what happened when you got up that morning.
A. Well, I got up, was showering, getting prepared for a trip that we would be leaving on early that morning. I heard Patsy scream. I ran downstairs. She told me that JonBenet was missing, that there was a ransom note. She asked me, What should we do? I said, Call the police. Sometime during that frantic period, we checked on Burke. He appeared to be asleep to us. A uniformed officer arrives reasonably quickly, and I focussed all the energy I could focus on getting my daughter back from that point on.
Q. When the police officer arrived, do you remember the name of the police officer?
A. I think it was French was the first one there, Officer French.
Q. Did you have an opportunity to observe what Officer French did at that point when he arrived? Did he speak to you?
A. He spoke to me. I told him my daughter had been kidnapped. He said, Do you think she might have just run away? And I said, For heaven's sake, she is only six years old; no, I don't. He asked us all to, Patsy and I, to stay in the sunroom, which is a small room off our living room. So I didn't see all that he did beyond that.
Q. You say that he asked you to stay inthe sunroom. Did you remain in the sunroom the whole morning?
A. We did not. Other people arrived. The police arrived. They asked to use our cell phones because theirs were dead. They asked us to do a number of things that required us to leave that room.
Q. Did Officer French give you any explanation as to why he wanted you just to remain in the sunroom?
A. No.
Q. Did anybody ask you to go back to the sunroom and remain there?
A. No.
Q. Did any other law enforcement official ask you to remain in any other part of the house?
A. No.
Q. Do you remember, in a general way, where you were in the morning from the time the police arrived and you left the sunroom? Could you just sort of walk me through what was going on?
A. I was in the house. That isprobably the best I could tell you.
Q. Did you ever have occasion prior to, say, 1:00 in the afternoon to go down to the basement?
A. Yes.
Q. How many times?
A. Twice.
Q. Prior to 1:00?
A. I don't know what time it was. I wasn't paying attention.
Q. Prior to the time that I believe it was Linda Arndt had asked people to begin looking around the house?
A. Linda Arndt asked me to look around the house, yes.
Q. Did she ask anybody else to do it?
A. I don't remember her specific instruction, no.
Q. Prior to Linda Arndt asking you to look around the house, how many times did you go to the basement?
A. Once.
Q. Do you remember at what time in the morning you went to the basement?
A. I do not.
Q. Do you remember what you saw in thebasement when you went down there?
A. I saw a partially opened window with broken glass and a suitcase beneath the window.
Q. When you would - did you see anything else there?
A. Not that looked out of the ordinary.
Q. May I ask why you went to the basement at that time?
A. I was trying to determine how someone could have gotten into our house.
Q. Did anyone ask you to go to the basement at that time?
A. No.
Q. Do you know if anybody saw you go to the basement at that time?
A. I have no idea.
Q. When you saw that the basement was in the condition that it was in, as you have just described it, and you came back upstairs, did you inform anybody of what you found in the basement?
A. I don't recall specifically if I did or not. I have a vague recollection of telling Linda Arndt that I found an open window with broken glass, but that I perhaps had broken that glass myself months earlier.
Q. Do you think you might have mentioned that to any other law enforcement officer beside Linda Arndt?
A. Not that I recall
Q. When Linda Arndt asked you to go down to the basement, I think that was sometime in the early afternoon -
A. I don't remember the time. I really don't.
Q. When she asked you to go down to the basement, could you explain why you chose going to the basement since you had already been there earlier?
A. She told me to go through the house and look for anything - go through the house thoroughly, as I recall, and look for anything that seems out of place. And so my intent was to do it thoroughly.
Q. Did you ask Fleet White to join you?
A. I think I did, as I recall.
Q. Do you remember exactly the sequence of events when you went down to the basement the second time?
A. Uh-huh (affirmative).
Q. Can you tell me where you looked?
A. I went back into the train room, showed Fleet the broken window, explained to him that I might have broken it myself months ago. I showed him the suitcase that I saw under the window, which I felt was very out of place. We looked for any large pieces of broken glass. And then I got up and went to the cellar room, opened the door, and found JonBenet.
Q. Do you remember why you decided to go to the cellar door at that particular time?
A. It was the next door outside of the train room. Other than that, no, it was a methodical search, in my mind.
Q. Was there a reason that you hadn't looked at that door the first time you went down to the basement?
A. There is no external exit from that room, so I was - the first time I went to the basement, I was trying to figure out how someone could possibly have gotten into our home.
Q. Do you remember whether or not Fleet White said anything to you while you were down in the basement showing him the broken window and the suitcase?
A. I don't remember that he said anything.
Q. Okay. Were you the first one to go to the cellar door?
A. I don't know.
Q. When you opened the cellar door, can you describe, to the best of your recollection today, what it was that you saw?
A. I saw a white blanket, and I knew immediately I found JonBenet.
Q. Had you turned the light on or -
A. I don't remember turning the light on.
Q. When you found the white blanket, what did you do?
A. I took the tape off of her mouth, I tried to untie the cord that was wrapped around her arms, and I kissed her and talked to her.
Q. Did you do anything then after that?
A. I realized that she wasn't just asleep, that this was not good. And I carried her upstairs.
Q. Do you know what, if anything, Fleet White was doing at that time?
A. I have no idea what he was doing. Iwasn't aware that he was around me.
Q. So you wouldn't have known whether or not he had stepped into the cellar area where her body was?
A. No. I don't - I - well, I don't remember him stepping into the cellar area, no.
Q. Do you remember asking him to go upstairs and get assistance or help?
A. I did not. I did not ask him that.
Q. During the time - I am going to direct your attention to the time that is earlier than the time you found JonBenet's body, and that is the time when the police were in the house, between the time Officer French first arrived and the time Linda Arndt asked you to make a more thorough search of the house. Were you questioned by the police?
A. Yes, I think I was.
Q. All right. Do you remember making statements to the police?
A. I remember responding to a number of questions they had.
Q. Do you remember if you were asked whether or not the house was secured when you went to bed the night before?
A. No, I don't remember that they askedme that question.
Q. Do you remember ever telling any law enforcement officer that the house had been secured before you went to bed that night?
A. I remember telling, I believe it was Linda Arndt, that I thought all the doors were locked, and I didn't understand how someone could have gotten in. Of course, I learned later that one of the doors was found wide open.
Q. Did you know whether or not the security alarm was on that night?
A. It was not on.
Q. Did you tell Linda Arndt or any other police officer that the security alarm was off -
A. I don't -
Q. - the night before?
A. No. I don't believe I did.
Q. When you were - when you spoke to the police, did you offer them any theories as to why you thought JonBenet was missing?
A. I responded to a number of questions they had.
Q. Do you remember some of those questions?
A. Oh, they asked: Was anyone angry with you at work? Was anyone around you acting peculiar recently in the last few days? Anyone you could think of that would do such a thing?
Q. And do you remember what you answered?
A. Oh, not completely. I know that in terms of people that were angry with me at work, I mentioned Jeff Merrick, who we had terminated due to performance. And he was extremely angry, to the point of making threats in the past six months prior to that. Patsy made me aware of Linda Hoffman-Pugh's strange behavior just prior to, but you need to ask Patsy about that because that is not firsthand information.
Q. Anyone else?
A. I don't believe so.
Q. Do you remember what, if any, other questions you were asked by any of the law enforcement people that were present?
A. Well, they asked if we had any recent pictures of JonBenet. Gosh, that is the only one I can remember.
Q. Were you asked at any time by law enforcement during this period what had transpired the night before in your home?
A. During that period?
Q. Uh-huh (affirmative).
A. I don't recall that they asked that.
Q. Can you remember what occurred on December 25th, say, from the morning on?
A. Generally, I can.
Q. Could you give me just a general summary, to the best of your knowledge?
A. I remember the kids bounding into our room that morning excited to open their presents. Our normal tradition is that I go downstairs, turn on the Christmas tree lights. I brought a bicycle out of the garage that I had as a surprise for Patsy. The kids came down. We opened presents. JonBenet wanted me to take movies, but my battery was dead. We had breakfast, Christmas breakfast.
Q. Do you remember what was served at that breakfast?
A. Not - no, I don't. Probably pancakes.
Q. Was that one a family favorite?
A. Yes.
Q. Who -
MR. WOOD: Wait. You asked him a question, and he was trying to answer. Why don't you let him finish his answer.
MR. HOFFMAN: All right. Sorry.
THE WITNESS: I enjoyed making pancakes with kids, and JonBenet enjoyed decorating them. So, yes, it was kind of a special treat.
Q. (By Mr. Hoffman) And after you finished breakfast, do you remember what you were doing?
A. At some point, I went out to the airport to pre-pack some gifts in the airplane, check it out, get it ready for an early morning departure. I remember kids being in and out of the house when I was there, neighborhood kids. We were going to go to the Whites' that evening for a dinner. I remember JonBenet asking me to help her ride her bike around the corn- - around the block, her new bike that she had gotten for Christmas. That is generally what I remember that day.
Q. Do you remember what happened in theevening, what you were doing in the evening?
A. Well, we went to the Whites' house where they had family and relatives, friends, I guess. We were perhaps the only friends there for Christmas dinner.
Q. Do you remember anything else about that Christmas dinner at Fleet White's?
A. Nothing notable. It was a family dinner.
Q. What, if anything, did you do after Fleet White's dinner?
A. We left. Patsy wanted to drop two gifts off at the Walkers' and the Stines', which we did on the way home. We pulled in the driveway into the garage. And JonBenet was asleep in the back of the car. I carried her upstairs and put her to bed.
Q. Is that the last time you saw JonBenet alive?
A. Yes, it was.
Q. All right. Do you know if Patsy joined you in the bedroom when you put her to - put JonBenet to bed?
A. I don't recall that she was in the bedroom when I was in the bedroom.
Q. Do you remember what JonBenet was doing that evening when you were over at Fleet White's?
A. She was playing with Daphne upstairs. She and Daphne had both received a little bead-making machine. She and I and Fleet and Daphne sat on the floor and made necklace beads.
Q. Do you remember anything else?
A. That is the highlight of my memory.
Q. Do you have any memory of what she was doing after you left Fleet White's?
A. She was asleep.
Q. How soon after you left Fleet White did she go to sleep?
A. I don't know. Sometime between the time she got in the car and when we arrived home.
Q. Do you remember whether she woke up at any time between the time you saw her asleep in the car and the time you put her to bed?
A. She did not.
Q. At that point, after you put her to bed, what, if anything, did you do?
A. I went downstairs to get Burke inbed. He was putting together a little plastic toy that he had gotten for Christmas. I helped him finish it so he could get off to bed. And we did that, and then I went to bed myself.
Q. When you say you went to bed yourself, do you remember exactly the sequence by which you prepared for going to bed that night?
A. I think I took my clothes off, brushed my teeth, put my pajamas on, and crawled into bed. That's -
Q. Did you do anything else?
A. Not that I remember.
Q. Did you use anything to help yourself go to sleep?
A. I took a melatonin tablet.
Q. Do you know the amount of melatonin you took?
A. No. It was an over-the-counter tablet.
Q. Was it a single tablet or half a tablet or two tablets?
A. I think it was a single tablet, as I recall.
Q. Do you remember the brand?
A. No.
Q. Do you know or remember whether ornot you read anything before going to sleep?
A. I read for a few minutes, as I recall, before I turned the light out.
Q. Do you remember at any point Patsy joining you in bed that night?
A. Patsy was in bed before I went to bed.
Q. Do you remember what Patsy was wearing when she got into bed or was in bed?
A. I don't remember specifically, no.
Q. All right. Did you wake up at all during the night?
A. I did not.
Q. Was this routine pretty much the normal routine when you went to bed at night when you were at home?
MR. WOOD: To take off his clothes, brush his teeth -
Q. (By Mr. Hoffman) Was anything different than that?
MR. WOOD - put on his pajamas and go to bed?
MR. HOFFMAN: Yes.
Q. (By Mr. Hoffman) Anything differentthan that?
A. Pretty standard routine.
Q. Pretty standard routine? And -
A. Except I usually didn't take a melatonin tablet every night.
Q. Why were you taking the melatonin that night?
A. I wanted to be sure I slept well because we were going to get up early, and I was going to fly to Minneapolis and then on to Michigan, and I wanted to be fresh.
Q. Do you know if Mrs. Ramsey was taking any medication to help her sleep?
A. Not to my knowledge.
Q. Any melatonin?
A. No, I don't believe so.
Q. You mentioned that you were going to fly to - where was it?
A. Minneapolis and then on to Charlevoix, Michigan.
Q. You have a pilot's license, I presume?
A. Yes, I do.
Q. Would you tell me what sort of pilot's license you have?
A. I have a commercial license, I have a flight instructor license for airplanes, for instrument flying. I have a multi-engine rating, and I have an instrument rating.
Q. What sort of planes does that allow you to fly?
A. Anything below 12,500 pounds gross weight.
Q. Does that include twin engines?
A. Yes.
Q. Does it include any kind of a jet?
A. Most jets are over 12,500 pounds that I know of.
Q. May I ask you where you learned to fly?
A. My dad taught me.
Q. Did you ever have occasion to fly when you were in the military?
A. No, I did not, other than in flying clubs.
Q. Was that the normal means by which you would travel; you would fly yourself, or did you take commercial airlines?
MR. WOOD: Travel in?
Q. (By Mr. Hoffman) Travel around the country whenever you would travel.
A. If I was flying for business, Inormally would take commercial airlines. If I was flying personally with my family, we normally flew ourselves.
Q. You say that - and I understand that you were in the Navy; is that correct?
A. Yes.
Q. All right. When you were in the Navy, would you describe, if you remember, pretty much what area you were responsible for as a serviceman?
A. Well, I was a Civil Engineer Corps officer. I was stationed in the Philippines for two years. I was the civil engineer for the Naval supply depot in the Philippines. I was transferred to Atlanta where I was the base engineer for the Naval Air Station in AtlantA.
Q. Would you describe what you were doing as an engineer?
A. Contract management. We ran all the base utilities, maintenance and repair, road construction, long-term planning, site planning.
Q. Were you actually involved in any hands-on engineering projects?
A. I had a staff that did that. I wasin charge of the staff.
Q. So were you ever involved in any of the actual construction?
A. Did I help pound nails? No.
Q. Or do anything like that, any sort of manual labor work.
A. In the military?
Q. Yes, in the military.
A. I did not.
Q. When you were not in the military, did you do that?
A. I enjoy remodeling and doing work with my hands, yes.
Q. Did you do any remodeling in your home in Boulder?
A. We did quite a bit of remodeling. I did not do any of the work there, as I recall.
Q. Did you have occasion to do remodeling in any of your other homes?
A. We have remodeled every home we have owned.
Q. Have you personally done any remodeling in any of these homes?
A. Yes.
Q. When you were in the Navy, you wentthrough basic training, naturally?
A. I went through officer candidate school in Newport, Rhode Island.
Q. And would you just describe briefly what your basic training was like?
A. It was physical training, it was navigation, celestial navigation, seamanship, rules of the road relative to ship movement, and, generally, familiarization with military procedures and the military system.
Q. All right. You say that one of the areas that you were instructed in was seamanship?
A. Navigation and piloting. You were being prepared to captain a ship.
Q. Did any of your basic training involve - and I don't know if they still do this - learning various nautical knots?
A. No.
Q. Do you sail at all?
A. I used to.
Q. Did you pilot your own sailboat or did you -
A. Yes.
Q. - have someone -
A. Yes.
Q. - do it for you?
A. No.
Q. Did you receive any training in sailing?
A. No.
Q. Are you familiar with the various knots involved in sailing?
A. I am really not. I should be, but I am not.
Q. All right. So how would you generally moor your craft?
A. I would tie it up on a cleat.
Q. Was there any sort of knot that you used that you could identify that has a technical term?
A. I don't know the technical term for it.
Q. Have you had occasion to be able to look at the knot that was tied around the so-called paintbrush garotte?
A. I have not.
Q. Is there any reason why you haven't?
A. It is very painful for me, Mr. Hoffman.
Q. I understand that. But with yournautical training, do you think that you could in any way be able to identify the sort of knot?
A. No.
Q. Okay. Do you know whether or not any - if your private investigators hired anyone to look at the way in which that knot was made and to give a report on it?
A. Not to my knowledge.
Q. Do you know if any of your investigators have been involved in trying to look at forensic evidence?
A. What is "forensic evidence"?
Q. Any of the physical evidence that might have been at the scene that you might have had occasion to have.
A. Well, I think any evidence that was at the scene was in the possession of the police. I don't know that we had any physical evidence that -
Q. Would the ransom note be considered physical evidence, in your mind?
A. Absolutely.
Wolf v Ramsey Lawsuit
Date of Deposition = December 12, 2001
Source: Daily Camera Newspaper
THE VIDEOGRAPHER: We are on the video record at 9:49.
MR. HOFFMAN: Good morning. This is the deposition of John Ramsey in the case of Robert Christian Wolf versus John Bennett Ramsey and Patricia Paugh Ramsey. I am the lead counsel for the plaintiff Chris Wolf. Would the gentlemen here identify themselves?
MR. WOOD: My name is Lin Wood. I represent the defendants John and Patsy Ramsey.
MR. RAWLS: My name is Jim Rawls. I am co-counsel for the defendants, John and Patsy Ramsey.
MS. RAMSEY: I am Patsy Ramsey.
MR. PAULK: Mahaley Paulk.
MR. SCHROEDER: Eric Schroeder.
MR. ALTMAN: Evan Altman, co-counsel with Darnay Hoffman, representing the plaintiff.
MR. WOOD: The deposition is taken pursuant to the Federal Rules of Civil Procedure. The deposition is taken pursuant to agreement of counsel. The deposition is taken pursuant to astipulation and protective order agreed to by all parties, which protective order specifically states, as we went over yesterday, the right of counsel to make sure that this deposition is not abused and that only areas that are relevant to the claims and defenses in this lawsuit are inquired of today in this deposition. Anything you want to add to that, Mr. Hoffman?
MR. HOFFMAN: No. Sounds like pretty much what we agreed yesterday was the case. And I believe yesterday you also explained what you believe the claims were, in fact, that would be relevant with respect to the deposition. So based on yesterday's statement, we will just continue the deposition.
MR. WOOD: Do you want to swear the witness, please.
JOHN RAMSEY, having been first duly sworn, was examined and testified as follows:
EXAMINATION BY-MR.HOFFMAN:
Q. Your full name, please, sir?
A. John Bennett Ramsey.
Q. Have you ever attended a deposition before?
A. Yes.
Q. Are you familiar with the deposition procedure?
A. I wouldn't say I am familiar with it. I have been at one deposition.
Q. All right. If at any time you don't understand -
MR. WOOD: He will answer questions, and he understands how to proceed with answering your questions. You do not need to counsel or advise him in that regard. Your job is to ask questions. If you would, go ahead and pose a question to the witness, please, sir.
MR. HOFFMAN: This is my deposition, Mr. Wood.
MR. WOOD: It is your deposition, but you are not here to lecture or counsel or advise my witness on what he is or is not to do. Trust me, he will answer your questions, and if he doesn't understand them, he will so indicate. Ask your first question, please.
Q. (By Mr. Hoffman) Mr. Ramsey, who is Chris Wolf?
A. Chris Wolf is your client, and he isa person who came to our attention as someone who should be looked at as a possible suspect in the murder of our daughter.
Q. Do you remember how Mr. Wolf came to your attention as a possible suspect?
A. I believe he contacted my wife's parents - no, I am sorry. His girlfriend contacted my wife's parents and said she firmly believed that he was the killer of my daughter, that he had been out all night and returned home early that morning, and that we needed to look at him.
Q. Do you know what was done with that information when your parents were - or Mrs. Ramsey's parents were given that?
A. I am sure we referred it to our attorneys through - or through our attorneys to our investigators.
Q. All right. Do you know which investigators were responsible for investigating that claim on your behalf?
A. Not for certain. I think probably they were involved, each involved at different stages.
Q. Do you know the names of theinvestigators that were involved?
A. I do.
Q. Could you give me their names?
A. Well, there was a group called Ellis Armistead & Associates. David Williams. John - and I can't think of his last name. Those were the principal investigators that our attorneys retained.
Q. Without revealing the substance of what you were given with respect to any reports that your investigators may have given you, do you remember if you ever saw any investigative reports concerning Chris Wolf?
A. I don't remember seeing any investigative reports regarding Chris Wolf.
Q. Do you remember whether or not you were shown investigative reports with respect to any of the other potential suspects that you may or may not have been looking at?
A. I don't recall ever seeing a report on any suspect that they might have looked at.
MR. HOFFMAN: All right. For the purpose of my next question, I would like the court reporter to please mark this as Plaintiff's Exhibit 14 for identification. And, actually, Iam going to turn to the portion to which I am going to direct Mr. Ramsey to look at this.
(Plaintiff's Exhibit-14 was marked for identification.)
THE WITNESS: You want me to read this part that is highlighted?
Q. (By Mr. Hoffman) Yes. After you had an opportunity to read it to yourself, please read it out loud.
A. You want me to read it out loud? I am sorry; I wasn't listening. I was reading.
Q. Yes, Mr. Ramsey.
A. "Katie Couric: You also mentioned Chris Wolf, a total stranger whose girlfriend reported that he had disappeared on Christmas night and was very agitated rather when he watched the news of the murder on TV. "John Ramsey: Uh-huh. "Katie Couric: Why do you mention him? "John Ramsey: Because he had been widely mentioned in the news, and we wanted to clarify the facts that we knew. "John Ramsey: I can tell you when, when we first startled looking at it, oneparticular lead early on, my reaction was, 'This is it. This is the killer.' And our investigators said, 'Whoa, whoa, whoa,' he'd say, 'Don't do a Boulder police on me. Don't rush to conclusions.'"
Q. Do you remember making this statement?
A. I don't remember making the statement, but that was a number of years ago, I guess, so....
MR. HOFFMAN: In fact, just simply for the record, I believe this is the Katie Couric Today Show. It was aired on, I believe, March 24th. And I believe it was in the year 2000.
MR. WOOD: Are you talking about his statement to Katie or the statement to the investigator?
MR. HOFFMAN: The statement to Katie that -
MR. WOOD: Did you understand he was asking you if you remember making a statement to Katie as opposed to the investigator?
THE WITNESS: Yeah.
Q. (By Mr. Hoffman) Okay. Now, do you remember who it was that you were - that you made the statement, This is it, this is the killer? Do you remember who that person was, the investigator that had shown you material on it?
A. Yes.
Q. Can you name that person?
A. I don't recall his first name. Helgoth was his last name, a fellow that committed suicide on Valentine's Day, the day that Alex Hunter told the world that they were going to get the killer.
Q. Right. So you were not referring to Chris Wolf in that statement; is that correct?
A. No. That is correct.
Q. Now, I want to ask you, in the statement, there is a reference to an early lead. What kind of lead was it? Was it - you know, specifically. Since you weren't shown any files.
MR. WOOD: Do you mean how was he imparted, the information imparted to him by Helgoth?
MR. HOFFMAN: Yes. I had asked him earlier if he ever had an opportunity to review any of the investigative files on any of the murder suspects.
MR. WOOD: No, you didn't. Youasked him if he had ever reviewed any investigative reports.
MR. HOFFMAN: All right. Reports.
MR. WOOD: And now you are asking him how he obtained the information about Helgoth?
MR. HOFFMAN: Uh-huh, yes. If he hadn't seen any investigative reports.
THE WITNESS: I think - I don't recall specifically whether my attorney told me about him or one of the investigators, but typically I communicated with my attorney.
Q. (By Mr. Hoffman) Were you actually shown evidence or were you just simply given a summary?
A. I have not seen any evidence that the police have.
Q. Any evidence that your investigators have?
A. I have seen a few things relating to your client. I don't know that I have seen anything relating to Helgoth.
Q. All right. Were you involved in directing the activities of these investigators that were working on your behalf?
A. I was not.
Q. Then what was, basically, your association with the private investigation of the potential suspects in the murder of JonBenet Ramsey?
A. The investigators were retained by our attorneys, and they stated to me that the principal purpose of those investigators was to prepare a defense in the case that the police might bring a charge against me. I hoped that they would also follow up on leads that came to us, but I was frequently reminded by our attorneys that their principal role was to prepare a defense should that be necessary.
Q. For a moment, I just want to direct you to the morning of December 26th. And to the degree that you can remember things today, I would like to ask you if you could just briefly summarize what happened when you got up that morning.
A. Well, I got up, was showering, getting prepared for a trip that we would be leaving on early that morning. I heard Patsy scream. I ran downstairs. She told me that JonBenet was missing, that there was a ransom note. She asked me, What should we do? I said, Call the police. Sometime during that frantic period, we checked on Burke. He appeared to be asleep to us. A uniformed officer arrives reasonably quickly, and I focussed all the energy I could focus on getting my daughter back from that point on.
Q. When the police officer arrived, do you remember the name of the police officer?
A. I think it was French was the first one there, Officer French.
Q. Did you have an opportunity to observe what Officer French did at that point when he arrived? Did he speak to you?
A. He spoke to me. I told him my daughter had been kidnapped. He said, Do you think she might have just run away? And I said, For heaven's sake, she is only six years old; no, I don't. He asked us all to, Patsy and I, to stay in the sunroom, which is a small room off our living room. So I didn't see all that he did beyond that.
Q. You say that he asked you to stay inthe sunroom. Did you remain in the sunroom the whole morning?
A. We did not. Other people arrived. The police arrived. They asked to use our cell phones because theirs were dead. They asked us to do a number of things that required us to leave that room.
Q. Did Officer French give you any explanation as to why he wanted you just to remain in the sunroom?
A. No.
Q. Did anybody ask you to go back to the sunroom and remain there?
A. No.
Q. Did any other law enforcement official ask you to remain in any other part of the house?
A. No.
Q. Do you remember, in a general way, where you were in the morning from the time the police arrived and you left the sunroom? Could you just sort of walk me through what was going on?
A. I was in the house. That isprobably the best I could tell you.
Q. Did you ever have occasion prior to, say, 1:00 in the afternoon to go down to the basement?
A. Yes.
Q. How many times?
A. Twice.
Q. Prior to 1:00?
A. I don't know what time it was. I wasn't paying attention.
Q. Prior to the time that I believe it was Linda Arndt had asked people to begin looking around the house?
A. Linda Arndt asked me to look around the house, yes.
Q. Did she ask anybody else to do it?
A. I don't remember her specific instruction, no.
Q. Prior to Linda Arndt asking you to look around the house, how many times did you go to the basement?
A. Once.
Q. Do you remember at what time in the morning you went to the basement?
A. I do not.
Q. Do you remember what you saw in thebasement when you went down there?
A. I saw a partially opened window with broken glass and a suitcase beneath the window.
Q. When you would - did you see anything else there?
A. Not that looked out of the ordinary.
Q. May I ask why you went to the basement at that time?
A. I was trying to determine how someone could have gotten into our house.
Q. Did anyone ask you to go to the basement at that time?
A. No.
Q. Do you know if anybody saw you go to the basement at that time?
A. I have no idea.
Q. When you saw that the basement was in the condition that it was in, as you have just described it, and you came back upstairs, did you inform anybody of what you found in the basement?
A. I don't recall specifically if I did or not. I have a vague recollection of telling Linda Arndt that I found an open window with broken glass, but that I perhaps had broken that glass myself months earlier.
Q. Do you think you might have mentioned that to any other law enforcement officer beside Linda Arndt?
A. Not that I recall
Q. When Linda Arndt asked you to go down to the basement, I think that was sometime in the early afternoon -
A. I don't remember the time. I really don't.
Q. When she asked you to go down to the basement, could you explain why you chose going to the basement since you had already been there earlier?
A. She told me to go through the house and look for anything - go through the house thoroughly, as I recall, and look for anything that seems out of place. And so my intent was to do it thoroughly.
Q. Did you ask Fleet White to join you?
A. I think I did, as I recall.
Q. Do you remember exactly the sequence of events when you went down to the basement the second time?
A. Uh-huh (affirmative).
Q. Can you tell me where you looked?
A. I went back into the train room, showed Fleet the broken window, explained to him that I might have broken it myself months ago. I showed him the suitcase that I saw under the window, which I felt was very out of place. We looked for any large pieces of broken glass. And then I got up and went to the cellar room, opened the door, and found JonBenet.
Q. Do you remember why you decided to go to the cellar door at that particular time?
A. It was the next door outside of the train room. Other than that, no, it was a methodical search, in my mind.
Q. Was there a reason that you hadn't looked at that door the first time you went down to the basement?
A. There is no external exit from that room, so I was - the first time I went to the basement, I was trying to figure out how someone could possibly have gotten into our home.
Q. Do you remember whether or not Fleet White said anything to you while you were down in the basement showing him the broken window and the suitcase?
A. I don't remember that he said anything.
Q. Okay. Were you the first one to go to the cellar door?
A. I don't know.
Q. When you opened the cellar door, can you describe, to the best of your recollection today, what it was that you saw?
A. I saw a white blanket, and I knew immediately I found JonBenet.
Q. Had you turned the light on or -
A. I don't remember turning the light on.
Q. When you found the white blanket, what did you do?
A. I took the tape off of her mouth, I tried to untie the cord that was wrapped around her arms, and I kissed her and talked to her.
Q. Did you do anything then after that?
A. I realized that she wasn't just asleep, that this was not good. And I carried her upstairs.
Q. Do you know what, if anything, Fleet White was doing at that time?
A. I have no idea what he was doing. Iwasn't aware that he was around me.
Q. So you wouldn't have known whether or not he had stepped into the cellar area where her body was?
A. No. I don't - I - well, I don't remember him stepping into the cellar area, no.
Q. Do you remember asking him to go upstairs and get assistance or help?
A. I did not. I did not ask him that.
Q. During the time - I am going to direct your attention to the time that is earlier than the time you found JonBenet's body, and that is the time when the police were in the house, between the time Officer French first arrived and the time Linda Arndt asked you to make a more thorough search of the house. Were you questioned by the police?
A. Yes, I think I was.
Q. All right. Do you remember making statements to the police?
A. I remember responding to a number of questions they had.
Q. Do you remember if you were asked whether or not the house was secured when you went to bed the night before?
A. No, I don't remember that they askedme that question.
Q. Do you remember ever telling any law enforcement officer that the house had been secured before you went to bed that night?
A. I remember telling, I believe it was Linda Arndt, that I thought all the doors were locked, and I didn't understand how someone could have gotten in. Of course, I learned later that one of the doors was found wide open.
Q. Did you know whether or not the security alarm was on that night?
A. It was not on.
Q. Did you tell Linda Arndt or any other police officer that the security alarm was off -
A. I don't -
Q. - the night before?
A. No. I don't believe I did.
Q. When you were - when you spoke to the police, did you offer them any theories as to why you thought JonBenet was missing?
A. I responded to a number of questions they had.
Q. Do you remember some of those questions?
A. Oh, they asked: Was anyone angry with you at work? Was anyone around you acting peculiar recently in the last few days? Anyone you could think of that would do such a thing?
Q. And do you remember what you answered?
A. Oh, not completely. I know that in terms of people that were angry with me at work, I mentioned Jeff Merrick, who we had terminated due to performance. And he was extremely angry, to the point of making threats in the past six months prior to that. Patsy made me aware of Linda Hoffman-Pugh's strange behavior just prior to, but you need to ask Patsy about that because that is not firsthand information.
Q. Anyone else?
A. I don't believe so.
Q. Do you remember what, if any, other questions you were asked by any of the law enforcement people that were present?
A. Well, they asked if we had any recent pictures of JonBenet. Gosh, that is the only one I can remember.
Q. Were you asked at any time by law enforcement during this period what had transpired the night before in your home?
A. During that period?
Q. Uh-huh (affirmative).
A. I don't recall that they asked that.
Q. Can you remember what occurred on December 25th, say, from the morning on?
A. Generally, I can.
Q. Could you give me just a general summary, to the best of your knowledge?
A. I remember the kids bounding into our room that morning excited to open their presents. Our normal tradition is that I go downstairs, turn on the Christmas tree lights. I brought a bicycle out of the garage that I had as a surprise for Patsy. The kids came down. We opened presents. JonBenet wanted me to take movies, but my battery was dead. We had breakfast, Christmas breakfast.
Q. Do you remember what was served at that breakfast?
A. Not - no, I don't. Probably pancakes.
Q. Was that one a family favorite?
A. Yes.
Q. Who -
MR. WOOD: Wait. You asked him a question, and he was trying to answer. Why don't you let him finish his answer.
MR. HOFFMAN: All right. Sorry.
THE WITNESS: I enjoyed making pancakes with kids, and JonBenet enjoyed decorating them. So, yes, it was kind of a special treat.
Q. (By Mr. Hoffman) And after you finished breakfast, do you remember what you were doing?
A. At some point, I went out to the airport to pre-pack some gifts in the airplane, check it out, get it ready for an early morning departure. I remember kids being in and out of the house when I was there, neighborhood kids. We were going to go to the Whites' that evening for a dinner. I remember JonBenet asking me to help her ride her bike around the corn- - around the block, her new bike that she had gotten for Christmas. That is generally what I remember that day.
Q. Do you remember what happened in theevening, what you were doing in the evening?
A. Well, we went to the Whites' house where they had family and relatives, friends, I guess. We were perhaps the only friends there for Christmas dinner.
Q. Do you remember anything else about that Christmas dinner at Fleet White's?
A. Nothing notable. It was a family dinner.
Q. What, if anything, did you do after Fleet White's dinner?
A. We left. Patsy wanted to drop two gifts off at the Walkers' and the Stines', which we did on the way home. We pulled in the driveway into the garage. And JonBenet was asleep in the back of the car. I carried her upstairs and put her to bed.
Q. Is that the last time you saw JonBenet alive?
A. Yes, it was.
Q. All right. Do you know if Patsy joined you in the bedroom when you put her to - put JonBenet to bed?
A. I don't recall that she was in the bedroom when I was in the bedroom.
Q. Do you remember what JonBenet was doing that evening when you were over at Fleet White's?
A. She was playing with Daphne upstairs. She and Daphne had both received a little bead-making machine. She and I and Fleet and Daphne sat on the floor and made necklace beads.
Q. Do you remember anything else?
A. That is the highlight of my memory.
Q. Do you have any memory of what she was doing after you left Fleet White's?
A. She was asleep.
Q. How soon after you left Fleet White did she go to sleep?
A. I don't know. Sometime between the time she got in the car and when we arrived home.
Q. Do you remember whether she woke up at any time between the time you saw her asleep in the car and the time you put her to bed?
A. She did not.
Q. At that point, after you put her to bed, what, if anything, did you do?
A. I went downstairs to get Burke inbed. He was putting together a little plastic toy that he had gotten for Christmas. I helped him finish it so he could get off to bed. And we did that, and then I went to bed myself.
Q. When you say you went to bed yourself, do you remember exactly the sequence by which you prepared for going to bed that night?
A. I think I took my clothes off, brushed my teeth, put my pajamas on, and crawled into bed. That's -
Q. Did you do anything else?
A. Not that I remember.
Q. Did you use anything to help yourself go to sleep?
A. I took a melatonin tablet.
Q. Do you know the amount of melatonin you took?
A. No. It was an over-the-counter tablet.
Q. Was it a single tablet or half a tablet or two tablets?
A. I think it was a single tablet, as I recall.
Q. Do you remember the brand?
A. No.
Q. Do you know or remember whether ornot you read anything before going to sleep?
A. I read for a few minutes, as I recall, before I turned the light out.
Q. Do you remember at any point Patsy joining you in bed that night?
A. Patsy was in bed before I went to bed.
Q. Do you remember what Patsy was wearing when she got into bed or was in bed?
A. I don't remember specifically, no.
Q. All right. Did you wake up at all during the night?
A. I did not.
Q. Was this routine pretty much the normal routine when you went to bed at night when you were at home?
MR. WOOD: To take off his clothes, brush his teeth -
Q. (By Mr. Hoffman) Was anything different than that?
MR. WOOD - put on his pajamas and go to bed?
MR. HOFFMAN: Yes.
Q. (By Mr. Hoffman) Anything differentthan that?
A. Pretty standard routine.
Q. Pretty standard routine? And -
A. Except I usually didn't take a melatonin tablet every night.
Q. Why were you taking the melatonin that night?
A. I wanted to be sure I slept well because we were going to get up early, and I was going to fly to Minneapolis and then on to Michigan, and I wanted to be fresh.
Q. Do you know if Mrs. Ramsey was taking any medication to help her sleep?
A. Not to my knowledge.
Q. Any melatonin?
A. No, I don't believe so.
Q. You mentioned that you were going to fly to - where was it?
A. Minneapolis and then on to Charlevoix, Michigan.
Q. You have a pilot's license, I presume?
A. Yes, I do.
Q. Would you tell me what sort of pilot's license you have?
A. I have a commercial license, I have a flight instructor license for airplanes, for instrument flying. I have a multi-engine rating, and I have an instrument rating.
Q. What sort of planes does that allow you to fly?
A. Anything below 12,500 pounds gross weight.
Q. Does that include twin engines?
A. Yes.
Q. Does it include any kind of a jet?
A. Most jets are over 12,500 pounds that I know of.
Q. May I ask you where you learned to fly?
A. My dad taught me.
Q. Did you ever have occasion to fly when you were in the military?
A. No, I did not, other than in flying clubs.
Q. Was that the normal means by which you would travel; you would fly yourself, or did you take commercial airlines?
MR. WOOD: Travel in?
Q. (By Mr. Hoffman) Travel around the country whenever you would travel.
A. If I was flying for business, Inormally would take commercial airlines. If I was flying personally with my family, we normally flew ourselves.
Q. You say that - and I understand that you were in the Navy; is that correct?
A. Yes.
Q. All right. When you were in the Navy, would you describe, if you remember, pretty much what area you were responsible for as a serviceman?
A. Well, I was a Civil Engineer Corps officer. I was stationed in the Philippines for two years. I was the civil engineer for the Naval supply depot in the Philippines. I was transferred to Atlanta where I was the base engineer for the Naval Air Station in AtlantA.
Q. Would you describe what you were doing as an engineer?
A. Contract management. We ran all the base utilities, maintenance and repair, road construction, long-term planning, site planning.
Q. Were you actually involved in any hands-on engineering projects?
A. I had a staff that did that. I wasin charge of the staff.
Q. So were you ever involved in any of the actual construction?
A. Did I help pound nails? No.
Q. Or do anything like that, any sort of manual labor work.
A. In the military?
Q. Yes, in the military.
A. I did not.
Q. When you were not in the military, did you do that?
A. I enjoy remodeling and doing work with my hands, yes.
Q. Did you do any remodeling in your home in Boulder?
A. We did quite a bit of remodeling. I did not do any of the work there, as I recall.
Q. Did you have occasion to do remodeling in any of your other homes?
A. We have remodeled every home we have owned.
Q. Have you personally done any remodeling in any of these homes?
A. Yes.
Q. When you were in the Navy, you wentthrough basic training, naturally?
A. I went through officer candidate school in Newport, Rhode Island.
Q. And would you just describe briefly what your basic training was like?
A. It was physical training, it was navigation, celestial navigation, seamanship, rules of the road relative to ship movement, and, generally, familiarization with military procedures and the military system.
Q. All right. You say that one of the areas that you were instructed in was seamanship?
A. Navigation and piloting. You were being prepared to captain a ship.
Q. Did any of your basic training involve - and I don't know if they still do this - learning various nautical knots?
A. No.
Q. Do you sail at all?
A. I used to.
Q. Did you pilot your own sailboat or did you -
A. Yes.
Q. - have someone -
A. Yes.
Q. - do it for you?
A. No.
Q. Did you receive any training in sailing?
A. No.
Q. Are you familiar with the various knots involved in sailing?
A. I am really not. I should be, but I am not.
Q. All right. So how would you generally moor your craft?
A. I would tie it up on a cleat.
Q. Was there any sort of knot that you used that you could identify that has a technical term?
A. I don't know the technical term for it.
Q. Have you had occasion to be able to look at the knot that was tied around the so-called paintbrush garotte?
A. I have not.
Q. Is there any reason why you haven't?
A. It is very painful for me, Mr. Hoffman.
Q. I understand that. But with yournautical training, do you think that you could in any way be able to identify the sort of knot?
A. No.
Q. Okay. Do you know whether or not any - if your private investigators hired anyone to look at the way in which that knot was made and to give a report on it?
A. Not to my knowledge.
Q. Do you know if any of your investigators have been involved in trying to look at forensic evidence?
A. What is "forensic evidence"?
Q. Any of the physical evidence that might have been at the scene that you might have had occasion to have.
A. Well, I think any evidence that was at the scene was in the possession of the police. I don't know that we had any physical evidence that -
Q. Would the ransom note be considered physical evidence, in your mind?
A. Absolutely.
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