John Depo: Part 4

Q. (By Mr. Hoffman) All right.

A. They are wrong. And they made probably a serious career limiting decision if that, in fact, is their statement, because that is something that neither the CBI, the FBI, the Secret Service, nor the top experts in this country have ever said. In fact, quite the contrary.

Q. How do you know that, Mr. Ramsey, that they -

A. I have heard statements from the police, I have heard statements from the district attorney, I have heard the results of what we consider and most people would consider the tophandwriting experts and linguistic experts in thecountry, all of which have said, highly improbable that Patsy wrote the note.

Q. Yet you have never actually seen any of these reports?

A. I have never read any of the reports. They have never physically been given to me.

Q. That is all I want to know. In light of that, I think, then, we are just going to move on, and I am going to ask you to look at a document that I am going to have marked as Plaintiff's Exhibit 17.

MR. HOFFMAN: Okay. Would you please do that?

THE WITNESS: And might I ask a question?

Q. (By Mr. Hoffman) Would you like to -

A. No. I would like to ask you a question. Was this used by your experts?

Q. That was one of the exhibits that was attached to an early handwriting report, and one of the reasons that we are, in fact, here asking, we have made an initial request in what is known as a notice to - a request for admission, andthere seemed to be some question as to whether ornot what I had attached as an exhibit was sufficiently clear for there to be, you know, an accurate representation of yes or no. So I thought it would be easier if I just brought in clearer copies and just asked you and Mrs. Ramsey to determine whether or not these are, in fact, samples of her handwriting. Clearly, nobody wants to be drawing conclusions based on handwriting samples which are, in fact, not hers. It seems that Mrs. Ramsey doesn't remember this as being hers.

A. She said she doesn't recognize it, nor do I.

Q. (By Mr. Hoffman) Nor do you. Okay. That's all -

MR. WOOD: And fairly, Darnay, let's be clear that we are talking about Plaintiff's Exhibit No. 2 and Plaintiff's Exhibit No. 1. And to the extent that it is also letters from those might be in Plaintiff's Exhibits 11, and I think also 10, as well as Plaintiff's Exhibit No. 9, the record should accurately reflect that each and every one of your experts, including Epstein and Ziegler, have, in fact, stated conclusions to someextent relying in part on each and every one of those exhibits except for Exhibits 10 and 11, which are Cina Wong, David Liebman's exhibit. So all of your experts have relied on that to form their statements made in their reports to date, including just the recent letters we received -

MR. HOFFMAN: Right.

MR. WOOD: - that you sent us a few months ago from Epstein and Ziegler; they did rely on those documents, and they didn't even know that it wasn't Patsy's handwriting.

MR. HOFFMAN: Well, that hasn't been established because the argument can always be that there is always a reason why Mr. and Mrs. Ramsey might have a motive to lie. I am not saying that they are, but the fact is, there might be a reason why it is convenient for them not to be able to recognize it.

THE WITNESS: I think Patsy was very clear that she did identify handwriting that she recognized as hers.

MR. HOFFMAN: And, quite frankly, she may very well have been telling the truth.

THE WITNESS: Quite frankly, she wastelling the truth, Mr. Hoffman.

MR. WOOD: And what might be interesting is to know what efforts were made by any of your so-called experts to actually authenticate those documents as Patsy Ramsey's handwriting before they were willing to go out and publicly stake their reputations that she is the author of the note based on handwriting exemplars that they didn't even have the slightest clue were written by her. So those are -

MR. HOFFMAN: Not necessarily they didn't have the slightest crew. Don't mischaracterize.

MR. WOOD: Well, when you raise questions about whether my clients might have a motive to lie, I am going to respond by saying that I think these people that you claim to be experts might have a motive to lie, and that motive is to get publicity and other things. We won't clutter the record up today. But let me tell you something, my clients have clearly identified the documents that you attached as exhibits. When the writing was Patsy Ramseys, nobody ran from it. The problemis, your people are relying on documents that either are not Patsy's or documents that they never bothered clearly to find out whether they were Patsy's before they went out publicly and accused Patsy Ramsey of writing a note to support the accusation that Patsy Ramsey killed her daughter. That is pretty flimsy, in my opinion, and I think that your experts will have a lot to answer for when we are finally given their report and allowed to cross-examine them, Darnay.

MR. HOFFMAN: Absolutely. I will say one thing in my defense and in their defense.

MR. WOOD: What?

MR. HOFFMAN: If, in fact, we were concerned that there was something bogus about their examination, I think the last thing we would want to do is establish at a deposition record by the testimony of both Mr. and Mrs. Ramsey that this is, in fact, not their handwriting. I think we can let that go by the board.

MR. WOOD: Well, with all due respect, with all due respect, you should have had reasonable notice to be concerned aboutwhether there was something bogus about thealleged reports of Cina Wong and David Liebman and Mr. Stacey - or Lacey, I am sorry, and I think Tom Miller, when you were informed by Michael Kane of the Boulder District Attorney's office that those experts were not following recognized handwriting methodology, that they were not even attempting to discuss dissimilarities, but were only hinging their alleged conclusions on a few similarities which are common to almost all handwritings, and that there were serious questions in the Boulder District Attorney's minds also on their credibility because of their efforts to gain publicity for themselves regarding those reports. That information was provided to you, Mr. Hoffman, in writing from Michael Kane. And I don't think you are going to state that Michael Kane was necessarily trying to do John or Patsy Ramsey any favors in his role as a grand jury specialist for the Boulder D.A. But once he told you that and put that in writing, I believe that you should have been on clear notice that there were legitimate and serious concerns about the bogusness of thesepeople's reports and conclusions, and those arethe individuals, Mr. Hoffman, not Mr. Epstein and Mr. Ziegler, who are now Johnny-come-latelys to this lawsuit, those were the individuals who you relied upon when you filed this complaint for Chris Wolf and submitted your mandatory disclosures. So I think there are very serious questions about their legitimacy, not just those raised by me. I haven't had the time yet and opportunity to cross-examine them, which I say I look forward to. But they were carefully studied by the Boulder District Attorney's offices, and they were soundly and wholeheartedly rejected as credible experts on the issue of handwriting. You knew that before you used them to file this lawsuit, yet you filed it anyway, I would say without further inquiry into their legitimacy. That is a problem and an issue, and I think the record ought to reflect it, and I think I stated it accurately.

MR. HOFFMAN: I have to - now, naturally, since you made a record, I am going to have to respond to what may be either mischaracterizations or just simply things that you are not aware of. To begin with, the letter by Michael Kane did not indicate what about the methodology with the exception of dissimilarity was suspect.

MR. WOOD: I can get the record, and we can put it into the record here. Why don't we do that. Let the letter speak for itself. I have got a copy of the letter.

MR. HOFFMAN: Well, if you would like to take a break and do that, we can -

MR. WOOD: We don't have to take a break, but I can have someone find that letter.

MR. HOFFMAN: That letter, fine. We will put that into the record. That is the first thing, from what I remember, since you are speaking from memory, also.

MR. WOOD: I have a pretty good memory on that one. It doesn't always fail me.

MR. HOFFMAN: Second point is that, with respect to the similarities, we do not know who Mr. Kane had actually submitted those reports to and who he was relying upon for the questions about the legitimacy of the reports. He did not indicate in his letter who it was that he had consulted. But, more importantly, I will say one thing, that, with respect to disguised handwriting, finding dissimilarities is less useful since the person clearly is trying to create consciously dissimilarities in the handwriting. And to the degree that the handwriting is disguised, there is, to some degree, dissimilarity to be expected and to continually belabor the point that disguised handwriting has dissimilarities is really not useful in a discussion of dissimilarities with respect to being able to put, add, or eliminate people from handwriting. So I never thought that Mr. Kane's one methodological discussion was a particularly valid one. Now, with respect to the district attorney's office that experts would be seeking publicity, I know that at one time they certainly did consult with a Donald Foster, who I believe was thought to be seeking publicity at one point, but that did not prevent them from at least consulting with him at least at some time. I know that Barry Scheck, who is aformer professor of mine and was brought in as a DNA expert, I won't say he is a publicity hound, but he certainly is not media-averse. They brought him in, and they relied upon him. Also, I know that periodically the district attorney's office would trot out an expert. I believe there was somebody from Canada who was not an expert, or whatever, so I don't think the district attorney was averse to using media-seeking experts. And I think Michael Kane's characterization of Cina Wong and David Liebman as media experts disqualifying them inherently because of that was, in fact, anything other than just simply hypocritical on his part. Now, as far as Mr. Kane is concerned, I don't think that, from the statements that I have heard from the Ramseys, that they particularly trust, A, his judgment, B, his motivation. I may be incorrect with respect to that. I, in turn, do not trust either his motivation or his competence. But I will point out that these handwriting reports were given to Alex Hunter's office. In the four years that they have had the reports or anything else, they not once made an attempt to contact either myself or any of my experts to talk even in a collect telephone call. There was never any acknowledgment of receiving it, and that is despite the fact that the district attorney's office, and I believe the police department, made public appeals to individuals to please come forward, that they would listen to any sort of reasonable clue, if it came over the internet, if it came from telephone calls, or whatever, and here were handwriting reports that I had solicited, some of which I actually had to use my own money to prepare, and they were completely ignored. They weren't even acknowledged by anybody in the district attorney's office, and yet they spent an inordinate amount of money trying to track down something that was known in the press as a Santa Bear, for instance. That sort of thing - Yes, Mr. Ramsey?

THE WITNESS: Well, I have got a band concert to go to tonight. Could I get my questions asked, and then you guys could put stuff on the record?

MR. HOFFMAN: The only reason I am responding, and I am very sorry, is that I haveto respond to your counsel's colloquy here, and Ihave to make a record. I am very sorry for that. Mr. Wood, and I am sure will take this - this is my first hearing that you have a band concert. I am very sorry. And I will try to make this - I will try to make it -

MR. WOOD: I think he is trying to say, maybe, let's don't go back and forth until 7:00 or 8:00 tonight.

THE WITNESS: Yeah.

MR. HOFFMAN: You made a record with respect to and representation for a record with respect to my experts, and I am not going to allow my silence to act as some sort of admission that you, in fact, were correct. I categorically deny that my experts are unqualified, any of them, that any of them acted out of any malice. In fact, it was my experience that when Cina Wong, when I contacted her initially - each expert was contacted to look at the report of another expert to see whether or not there was a problem in their methodology. And as a result of looking at themethodology, they reached the same conclusions. Idid not ask them to reach a conclusion. I basically wanted to make sure that if, in fact, there was going to be a case made in civil court against Mr. and Mrs. Ramsey, that there was, in fact, a sufficient basis for it. I was doing my best to investigate the facts of the case before making the allegations. The only allegation that I ever really made is that, based on the handwriting reports by people that I trust to be experts, that their conclusion that Mrs. Ramsey is the ransom note writer was the basis not only for any allegations that I may have made personally in public with respect to Mrs. Ramsey, but also forms the basis by which I filed the - not only the action against Alex Hunter in 1997, but also the action on behalf of Chris Wolf and Linda Hoffman-Pugh. So I have tried to do a due diligence and certainly avoid any problems with Rule 11. I am under a duty as an officer of the court to investigate the case and the facts. And the only reason, basically, we are here today is because I have yet to see handwriting reports from any source other than my own that, in fact, clear Mrs. Ramsey. I would love to see those reports. I don't know why I have never been offered a report. The question I have for Mr. Wood is, at the time that Mr. Wood was releasing your polygraph reports and had a very attentive national media, why did he not come forward with written handwriting reports that could clear Mrs. Ramsey? I think that that would have been a spectacular and an extremely important opportunity in order to clear your wife from any suspicion of being the ransom note writer. And, yet, there has never been, despite all the money that Mr. and Mrs. Ramsey have spent, any attempt to release a written report at any time to the media similar to the written report that was released in the polygraph, and I never have been able to understand it. It is like the dog that should have barked in the night that hasn't barked in the night. My question has always been, why haven't the Ramseys released a handwriting report to shut me up, to just simply stop all the noise about the fact that there are handwriting experts that believe that Mrs. Ramsey wrote the ransom note? Whyhaven't, Mr. Wood, your clients been willing toproduce for public consumption a handwriting report that simply, adequately, and for all time clears Mrs. Ramsey?

MR. WOOD: Darnay, out of respect for John, who does have a band concert, I am not going to engage in trying to go back through and respond to all of that colloquy.

MR. HOFFMAN: Okay.

MR. WOOD: Suffice it to say, because you have referenced two individuals, clearly, Barry Scheck has never sought publicity about the Ramsey case. He has never discussed it publicly. He has refused to do so. Don Foster was not rejected by the Boulder District Attorney's office because he sought publicity. Don Foster was rejected because he concluded, after being hired by Steve Thomas, that Patsy Ramsey was the author of the note, and they thereafter found out that he had, prior to being hired by the Boulder District Attorney's office, written a three-page letter to Patsy Ramsey stating unequivocally that he would stake his reputation on her innocence that she was not the author of the note. So they discovered that Don Fosterwas, as we say in the business, a liar for hire. There are a lot of liars for hire in our business. You and I can debate, after I have been presented with your experts' reports and the opportunity to depose them, whether they have any legitimacy or whether they too are liars for hire or for publicity. We will resolve that another day. Suffice it to say here that we are not going to react to your comments about handwriting experts until we get your experts, which we are entitled to get, and then I want you to know this: You will receive handwriting expert reports from the Ramseys. Okay? So the time for that will come. It hasn't been time yet, but that will happen at the appropriate time. But, first, we are entitled to get your reports and cross-examine your experts. Once we have done that, you will get your reports that you so desperately want. And then I am going to hold you to that; that once you get those reports, since you don't believe the four people that Alex Hunter described as top of the line that said out there in Boulder she didn't write it, since you don't believe them, I will hold youto your word. Once we give the reports to you, I am going to ask you to, quote/unquote, as you say, "shut up," your words, not mine, then dismiss your lawsuit. Okay? So let's go on and let Mr. Ramsey answer questions.

Q. (By Mr. Hoffman) All right. Mr. Ramsey, what time do you need to be out of here. I am not going to hold it against you. Seriously, I would like to - because I will do this according to that.

THE WITNESS: What time is the band concert?

MS. RAMSEY: 7:00.

THE WITNESS: 7:00, okay.

MS. RAMSEY: He is not in a band concert.

THE WITNESS: No, my son is.

MR. ALTMAN: I understand that.

Q. (By Mr. Hoffman) Okay. What time would you like to be able to leave here to be able to conveniently get there?

A. If we left at 5:00, we will be in good shape.

Q. What time do we have now?

MR. WOOD: It is 2:30. We have got plenty of time.

MR. HOFFMAN: We are not going more than an hour, Mr. Ramsey, at all, and maybe even less than that.

THE WITNESS: Okay.

MR. HOFFMAN: Okay.

MR. WOOD: But that's not an invitation for him and I to go for another two and a half hours and talking.

MR. ALTMAN: Once again, if I could say something, if we can stick to what we have been here for, ask questions, answer questions, I think we will be fine.

MR. WOOD: I think that is appropriate, but I think Darnay knows as well, that this deposition, as the Ramseys have done before, they don't claim confidentiality, they have nothing to hide, and I want the record to be clear that this idea that Mr. Hoffman is asking questions that seem to contain damaging statements of experts about Mrs. Ramsey, I think that invites the record to be very clear that there are serious questions about whether theseindividuals are, as I say in the industry, wecall them liars for hire. And so I think that both sides of that issue have to be explored on the record when he makes their conclusions part of his question. That is all.

MR. ALTMAN: I think the question was, is it, in fact - do you have knowledge of it, not so much do you agree with it.

MR. WOOD: That is the way of putting out what we believe to be potentially a very bogus conclusion accusing Patsy Ramsey of writing the note because he wants that to then be part of a public record that is either watched on television or read by someone. And when you put that kind of information out there, the record, in order to be accurate and complete, has got to contain information that I think clearly demonstrates that there are, at a minimum, serious credibility issues with these experts, if there is not already sufficient evidence in the record to show that they are, quote/unquote, liars for hire or bogus excerpts. I have offered to resolve at least part of this, and I will do so. If I have myoffice locate Mr. Kane's letter to Mr. Hoffman,we will attach it to the record. It will speak for itself. That is all.

MR. HOFFMAN: Mr. Wood, I just want to say one other thing with respect to that. You may have noticed that I have not asked Mr. Ramsey for personal information or Mrs. Ramsey. I haven't asked for their address. I haven't asked for social security numbers. I haven't asked for anything that would in any way hinder your ability to have to hold this back to at least redact those elements of it, because I am not interested in creating a record that will keep you from being able to make this public if you choose to do so at any time that you choose to do so. I just simply want to go - I have had an opportunity to see a lot of the tapes and transcripts of Mr. Ramsey and Mrs. Ramsey with the police interviews and whatever, and I am not interested in taking them over the same ground. I could have easily - Mrs. Ramsey, I believe, made a statement to the media yesterday that she was surprised at how short the deposition was, that there didn't seem to be any "Where is themeat to the Whopper," but a lot of that wasalready provided to me by material from discovery. So consequently, I am not trying to create any kind of record. I am just trying to get answers to questions that I still have. I am required to do that.

MR. WOOD: Let's move forward. You ask questions. They have answered every one that you have asked so far, and they will continue to do so.

MR. HOFFMAN: Okay. All right.

Q. (By Mr. Hoffman) Mr. Ramsey, I am going to show you a document that I would like to have the court reporter mark as Plaintiff's Exhibit 17, marked for identification. (Plaintiff's Exhibit-17 was marked for identification.)

MR. WOOD: Is there a part of this you want him to look at?

MR. HOFFMAN: I want him to look at the headline, because, basically, I know this is a news story. I am going to ask him if he can - if he has ever seen this news story before.

THE WITNESS: No, I have not.

Q. (By Mr. Hoffman) Are you familiar with Charlie Brennan -

A. Yes.

Q. - as a news reporter? Do you have any opinion with respect to his ability as a journalist to accurately report the news? Any personal knowledge.

A. I know of one instance in the beginning where he reported incorrect information.

Q. I am going to ask you whether or not the headline in this story is substantially correct, knowing that these are not your words. Did you, in fact, have investigators tail possible suspects?

A. I did not have investigators tail possible suspects.

Q. Do you know if anyone working on your behalf had suspects tailed by investigators?

A. I believe that our investigators observed the behavior of certain people the day that that ad appeared. I don't know for how long. I don't know what they did. But I am aware of that.

Q. I would like to ask you, then, very simply, is this headline substantially correct or false as a statement of fact, in your opinion?

A. Is it substantially -

Q. - correct as a statement of fact in your opinion, the headline?

A. Well, the word I have difficulty with is "tail." I don't know that they tailed anyone. I think they observed outside their homes. So it is generally correct, to my knowledge.

Q. Okay. I am going to now ask you to look at something I am going to have the court reporter mark as Plaintiff's Exhibit 18 for identification.

(Plaintiff's Exhibit-18 was marked for identification.)

Q. (By Mr. Hoffman) There are a series of documents here. I just would like you to look at them all at one time briefly, and I will ask you about each one. All right. With respect to the first document, I would like you to review the headline, and I am going to ask you whether or not that headline is substantially correct when it states that "Parents' book will name suspects, publisher says."

A. I think it is substantially incorrect.

Q. In what respect?

A. Our book did not name suspects. It addressed people that were already being discussed in books, in the media, who had been on television and whom, had we not addressed, would have looked foolish. There are a number of people that we are interested in that we did not name in our book because they were not out in the public and known to the public.

Q. Do you know if at this time - the story is dated February 22. I believe it is - the year your book came out was 2000. It is copywritten 2000. Around this time, you were doing a media tour, what is commonly known as a media tour for the book?

A. We agreed to do a few interviews, yes.

Q. Interviews, right. Were you aware that your publisher was reported as having made these statements, that the Ramseys' book will name suspects? At the time.

MR. WOOD: You may answer that. Reported, yes. But in fairness to Mr. Zettersten, I don't believe that that is what he said. If you look at the quote, that may be the headline that somebody decided to give it, but if you will look at the quotes, I don't think Ralph Zettersten said that before. In fact, he said very precisely, "It is people who have been mentioned before, Zettersten said. There will be a couple of others, but not by name."

THE WITNESS: And that is correct.

MR. WOOD: That is his quote. So, I mean, we are not responsible for what some writer decided to put in a headline for whatever reason. But you would answer the question, if you were familiar with this article or other articles that have claimed that that is what Mr. Zettersten was doing.

MR. HOFFMAN: Actually, I am going to withdraw my question, and I am going to ask a different question.

Q. (By Mr. Hoffman) Were you aware at the time this article was published that there were stories with this sort of headline circulating, that the Ramseys were naming suspects?

A. Was I aware - I was aware post that being out there. I wasn't aware that that wasgoing to be said or that -

Q. But afterward.

A. But that was interpreted as the matter.

Q. Did you make any attempt to object to any of the media with respect to this characterization? Did you make any attempt to correct that impression?

A. What we found in dealing with the media is that it is a massive brute. I don't know how I would begin to correct that kind of thing. The book was an attempt to correct as many of the myths that we knew about.

Q. Mr. Ramsey, I quite agree with the characterization as the media as a massive brute. However, did you at any time ever say in public that one of your intentions in your litigation was to change the way in which the press reported the news in a case like yours.

MR. WOOD: You can answer that. If you want to see the statement. Darnay, I think you are obligated -

MR. HOFFMAN: No, I am just saying in terms of that effect -

THE WITNESS: I will tell you whatmy feeling is, and I have said this a number oftimes, that we need a law in this country that prevents the police from talking to the media about evidence in an ongoing case. We have bypassed the constitutional provisions that have been put in place to protect people's rights when the police could disclose evidence to the media for entertainment. It is a law in England. If some of the things that the media had done in this country and that the police had done in Boulder had been done in England, they would be in jail. It is a simple law. I think we need that in our society. So, yes, I would love to see that kind of a change because I think our system is too quick to convict based on hearsay that is broadcast on the media. And that is unfair to any citizen.

Q. (By Mr. Hoffman) I don't know if you are familiar with J. Edgar Hoover, who was the former head of the FBI, or whether or not you are aware that J. Edgar Hoover used to tell his agents that if you cannot solve a case, if you are having a hard time solving the case, giveit to the press because people are more likely tocome forward and talk to a reporter than they are to a law enforcement agent, and that that might be the reason why some law enforcement agents, in fact, have this policy of giving information to the media. I just wanted to know if you were aware of that.

A. Well, I am talking -

MR. WOOD: Do you have any source for that statement from J. Edgar Hoover? I mean, you know, Darnay -

MR. HOFFMAN: I don't have it, but I can produce it. I am just looking for a response here.

MR. WOOD: We could say J. Edgar Hoover could speak for himself, but, you know, you are putting in -

MR. HOFFMAN: Or herself, whatever the case may be.

MR. WOOD: Himself or herself.

MR. HOFFMAN: He is not somebody that I would, like, quote as a libertarian or a humanitarian, or an ACLU, whatever.

MR. WOOD: I will let Mr. Ramsey answer, but we are getting far afield, I am afraid. But go ahead.

THE WITNESS: I can tell you from my opinion some of the best investigative work has been done by journalists in this case. But that is different than disclosing evidence or opinions on evidence to the media prior to a trial.

Q. (By Mr. Hoffman) Now, you said -

A. That is what I am talking about, evidence. I am not talking about the fact that someone was murdered or accosted or raped and it was in this location and this is the description of the person we are looking for. I am talking about - you know, we know for a fact that there was a deliberate and thought-out effort on the behalf of the police at the direction of the FBI to publicly assassinate our character and discredit us and bring massive pressure on Patsy and I in hopes that one of us would confess or break and turn the other one in. That is bypassing all of the rights that have been established in our constitution to protect every citizen, and that is wrong.

Q. Okay. That brings me to my next question, which is, would you just express briefly your opinions of tabloid magazines, such as Globe,The Enquirer, The Examiner, the Star?

A. I have said before, and I still believe, they are a cancer in our society.

Q. Which brings me to the next question which I asked Mrs. Ramsey yesterday, and I am going to ask you. Did you at any time agree to give an interview with The Enquirer, this cancer on society?

A. Yes.

Q. May I ask you why you agreed to do that?

A. It was part of a settlement agreement on behalf of some suits that we had filed against these people. And I cannot disclose per the agreement any more than that. And we were willing to confront our most ridiculous accusers.

Q. I just want to ask you to -

MR. HOFFMAN: I am going to ask the court reporter to mark this as Plaintiff's Exhibit 19. And I will show that to Mr. Ramsey.

(Plaintiff's Exhibit-19 was marked for identification.)

Q. (By Mr. Hoffman) Mr. Ramsey, I am going to ask you if the document I just have shown you, which is marked Plaintiff's Exhibit 19for identification, is substantially correct inits reporting with respect to its headline?

A. No, it is not.

Q. In what respects is it incorrect?

A. We did not turn to the work of a psychic. A picture was forwarded to us that was done by a Dorothy Allison, who I believe is a psychic, by someone. I think she had done it on a television program. We forwarded it to our investigators as a matter of procedure. We did that with everything we got in the mail. And we got a lot of stuff. And I believe they chose to put it on their website to stir up activity. And they did receive a number of leads and calls based on that.

Q. Were those leads and calls useful to your investigation?

A. I don't know.

Q. Now, I am going to show you - unfortunately, for some reason, I ran out without making a second copy, so I am going to ask the reporter to mark this as Plaintiff's Exhibit 20 for identification, and then I will just show it to you after he has marked it.

(Plaintiff's Exhibit-20 was marked for identification.)

THE WITNESS: Okay.

Q. (By Mr. Hoffman) Mr. Ramsey, I am going to ask you if you can identify what appears in that document.

A. I can identify most of the pictures of JonBenet. Some of them - or one of them is very fuzzy. I just assume that is the picture that was on the website.

Q. Do you know if that is, in fact, a picture of your website that you are looking at?

A. I don't know that for a fact, no. I have not seen this image.

Q. Do you know if the image of the man at the lower part of it -

A. Uh-huh (affirmative).

Q. - do you know if that image ever appeared on your website?

A. This is the first I have seen it. I don't usually look at that website.

Q. Do you know if the man in question in that photo was, in fact, a suspect, to your personal knowledge?

A. I don't know.

Q. Was that man meant to be Chris Wolf?

A. Not to my knowledge.

MR. WOOD: Just so the record is clear, that is the drawing of the psychic that you were earlier referring to.

MR. HOFFMAN: Is it? I don't know.

THE WITNESS: Oh, yeah.

MR. HOFFMAN: I was asking Mr. Ramsey what he did or didn't know.

MR. WOOD: Just so the record is not confused here, Mr. Ramsey indicated to you that the psychic's drawing was sent to the Ramseys, that it was reviewed by the Ramsey investigators, and that the investigators put it up on the website. And I think he said their website. This website was utilized by the Ramsey investigators.

MR. HOFFMAN: I just asked Mr. Ramsey if he could identify it, if he had he ever seen those pictures, and whatever else. That is all I want to know.

THE WITNESS: That is a different question than I was asked. Had I ever seen this drawing? Yes, I have.

Q. (By Mr. Hoffman) You have. Oh, I see. Okay. Do you know in what context it was?

A. It appears to be, from the best I can tell from the copy, the drawing that was sent to us that was made by Dorothy Allison.

Q. Had you ever seen a picture of Chris Wolf?

A. Yes.

Q. In your opinion, does Chris Wolf look anything like the picture there?

A. I wouldn't draw that conclusion, no.

Q. Okay. Now, I have one last question. Just simply, it is a point that involves something I just wanted to be clear about. And I am going to let you read this. It is - and the reason I am not reading it out loud is that it is part of the Boulder police interview, which has been marked confidential. I don't want to have something read into the record that would in any way mean we would suddenly have to mark this confidential, if for some reason we don't want to have today's deposition marked confidential. So for the purposes of this question, I am just going to ask you to read to yourself the highlighted portions. And in fact, I am not going to even attach this as an exhibit. I am just going to simply - just as a recollection, to reflect, refreshed. If you would look at that, I am just going to ask you one question with respect to it.

MR. HOFFMAN: And, Mr. Lin, it is at the very end; it regards the, I think, the butler door, whatever it is.

MR. WOOD: Let me say this to you.

MR. HOFFMAN: Yes.

MR. WOOD: This is a couple of pages from, it looks like, Patsy Ramsey's April '97 interview -

MR. HOFFMAN: Yes, on the front, I put that on the cover.

MR. WOOD: - six-hour interview. I don't have any problems; you can read it, you can put it into the record.

MR. HOFFMAN: I would just prefer -

MR. WOOD: We don't have any - I don't have any problems with that being made part of the record officially. Put it out there. We would like to see the whole police investigative file be made public so people would know the truth about this case.

MR. HOFFMAN: I would prefer, sincethis has been stamped "confidential" -

MR. WOOD: I am the one that stamped it confidential in other litigation several months ago, if not last year, for reasons different than the issue of confidentiality in this case. I am waiving any claim for confidentiality. Put that into the record. I have no problems with you doing so.

MR. HOFFMAN: Well, I am not -

MR. WOOD: You could put the whole April 1997 transcript of both of their interviews into the record. I have no problems with you doing so.

MR. HOFFMAN: I am not going to do that.

MR. WOOD: I have no problems with it.

MR. HOFFMAN: All right. Thank you very much.

MR. WOOD: Let the truth come out.

MR. HOFFMAN: I agree with you.

Q. (By Mr. Hoffman) This question involves the - do you know where the butler kitchen was in your house?

A. Well, yes. I know what we called the butler kitchen.

Q. Butler kitchen. Do you remember opening the door to the butler kitchen at any time in the morning while you were looking through the house for JonBenet?

A. No.

Q. And so is it that you have no memory of it or that you just didn't do it?

A. I did not open it.

Q. So it wasn't opened by you?

A. No.

MR. HOFFMAN: Thank you very much. This is going to conclude my deposition testimony of Mr. Ramsey. And I want to thank Mr. Ramsey for being here. I want to thank Mrs. Ramsey, once again, for her deposition yesterday and for being here today, and thank counsel.

MR. WOOD: All right. Just so the record is clear, we have a number of hours under the Federal Rules of Civil Procedure remaining in which you have the right to examine Mr. Ramsey and to ask him any question factually otherwise that is proper and relevant to the claims anddefenses in the lawsuit. And do you acknowledgethat there are a number of hours remaining?

MR. HOFFMAN: Yes. Absolutely.

MR. WOOD: He answered every question today?

MR. HOFFMAN: Yes, he has.

MR. ALTMAN: I think with the exception of what we had spoken about regarding the financial issues which we may take up later.

MR. WOOD: We are not going to take that up on the record, as that is something that would require a court ruling.

MR. HOFFMAN: Every question that was put to Mr. Ramsey that was a matter of record today, that we agreed on was a matter of record, was, in fact, answered by Mr. Ramsey.

MR. WOOD: And as you indicated, you have reviewed his April '97, June 1998, and April 2000 police interviews -

MR. HOFFMAN: That is correct.

MR. WOOD: - and I think you will say, with respect to Mr. Ramsey, Mr. Hoffman, the same as you said with respect to Mrs. Ramsey yesterday, he answered every question for the police; didn't he?

MR. HOFFMAN: That I can't make asubjective statement about simply because I don't know what it was the police were trying to elicit in the way of answers, so I can't say that.

MR. WOOD: You can't say that he gave him the answers they wanted?

MR. HOFFMAN: No, I just don't know. It's really probably improper for me to characterize their testimony. I mean - and I don't think anybody will want a testimonial from me, from the Ramsey family anyway.

MR. WOOD: Yeah, but the point is -

MR. HOFFMAN: But I did receive those.

MR. WOOD: - you have that massive what amounts to about 70 hours of their interviews with police; they voluntarily gave them. My question is, all of that material having been forwarded to you earlier by the Ramseys, along with a number of other documents, are you sure you have no other questions of Mr. Ramsey, because if you do, I want you to ask them today.

MR. HOFFMAN: No. I understand. In fact, one of the reasons why - and I want to characterize this properly.One of the reasons why these depositions are shorter than they might have been is because I am not asking either Mr. or Mrs. Ramsey to go over testimony that they have already given by the police. The police certainly have spent a great deal of time with the Ramseys, and, quite frankly, even though there may be areas that I might have personal curiosity about, I feel it would be inappropriate for me to ask them, and so that is why these depositions aren't going the full day. It is not because I feel that the Ramseys don't have anything to offer. It is just simply that I think that they offered a great deal of information when they were, in fact, interviewed, and I just chose not to cover most of it. And that is all.

MR. WOOD: But you acknowledge that any question you have, curiosity or otherwise, that you believe to be relevant and properly framed in this case, you have the opportunity to ask them now.

MR. HOFFMAN: There - I have hadthe opportunity to ask Mr. Ramsey questions today. And with the stipulated exception that we have, which does not affect my answer here, I felt that Mr. Ramsey made the best effort that he could to answer those questions fully.

MR. WOOD: Let me briefly cover a couple of matters with you, Mr. Ramsey, by way of direct or reflect discovery.

EXAMINATION BY-MR.WOOD:

Q. Let me hand you what has been marked for purposes of identification as Plaintiff's Exhibit 16 to this deposition, and I think it has been represented to you and acknowledged by you, it appears to be - we don't know how much generations away from the original, but a copy of the ransom note found in your home on December 26, 1996. You have looked at that earlier today?

A. Uh-huh (affirmative).

Q. At the time earlier in your testimony with Mr. Hoffman, I think you made reference to one of the peculiarities of the ransom note being that you were first discussed or addressed formally and then later in the note informally. Do you remember -

A. Yes.

Q. - telling Mr. Hoffman about that? And I think you made the reference that you were addressed "Mr. and Mrs. Ramsey." Do you recall telling him that?

A. Yes.

Q. Did you have the ransom note in front of you at the time you were giving that information to Mr. Hoffman?

A. No. I had forgotten that it was only addressed to me. But what it was what - what I noticed was that it was a formal address, and yet they fell into a familiar form later on.

MR. WOOD: That is all I wanted to clarify.

MR. HOFFMAN: Yes.

MR. WOOD: And now let me mark this as Defendant's Exhibit No. 1. (Defendant's Exhibit-1 was marked for identification.)

MR. WOOD: Do you want to take a look at this real quick?

MR. HOFFMAN: Yes, please. Thank you very much. May I make one observation about thisbefore you read it into the record?

MR. WOOD: Sure.

MR. HOFFMAN: I would like the record to reflect that I made this document available on the internet at the time that Cina Wong, and there is a document which seems to be almost identical, that David Liebman received this. I would just like the record to reflect I made no attempt to keep this hidden from the public.

MR. WOOD: And there has been no representation that you did make any such attempt.

MR. HOFFMAN: I am sorry? No. I want the record to reflect that -

MR. WOOD: But I appreciate the stipulation.

MR. HOFFMAN: - that I made that available through the internet.

MR. WOOD: The stipulation was that you recognize the document, and it is actually the very material that you placed on the internet.

MR. HOFFMAN: That is correct.

MR. WOOD: And it was, in fact, and is, in fact, a true and correct statement of the letter that was sent to Cina Wong by Michael Kaneon behalf of Alex Hunter, the -

MR. HOFFMAN: Correct.

MR. WOOD: - the Boulder district attorney.

MR. HOFFMAN: Uh-huh (affirmative).

MR. WOOD: January 20, 1999.

MR. HOFFMAN: Yes.

MR. WOOD: And also a true and correct verbatim statement of the letter sent by Mr. Kane on that date, January 20, 1999, to Mr. David Liebman; am I right?

MR. HOFFMAN: That is correct.

MR. WOOD: All right. So that the record is clear, in those letters which predate the filing of this lawsuit, Mr. Kane stated to Ms. Wong and Mr. Liebman in identical language that he was informing them that their request to testify before the Boulder County grand jury in the JonBenet Ramsey murder investigation was denied, and the statement was, "We have determined that your proposed testimony would not serve the interest of justice, which is the controlling standard by which to judge your request." And I continue to quote: "The primary reason that we have reached this decisionis that we believe that the methodology which youhave used in reaching your conclusions does not meet the standards employed by the vast majority of forensic questioned document examiners in this country." I continue to quote: "Most significant is your complete failure to account for or even reference any unexplained dissimilarities between the questioned and known samples. You are willing to conclude with 100 percent certainty that a writing was authored by a particular person based on some threshold level of similarities without any mention that there may be 10, 100, or 10,000 unexplainable dissimilarities between the known and unknown writings. I know of no reputable forensic document examiner who will not agree that unexplainable dissimilarities between a person's natural writing and questioned handwriting will preclude a positive identification. "In fact, where the degree of unexplained dissimilarity is high, it may result in an elimination, in spite of the existence of a number of points of similarity." And then I go down to state: "Inaddition to your technical deficiencies," I quote, "there are other reasons for our decision. I would note that you have engaged in a campaign of promoting your opinion in a manner that would surely open your credibility to doubt on cross-examination in a judicial proceeding. "As an experienced trial attorney, I believe that an expert witness who has attempted to insinuate herself," or himself, "into a particular criminal investigation through a public media campaign would appear less than objective and professional to a jury." Now, I make that statement because I misspoke earlier when I made a statement about a letter sent by Michael Kane to you. In fact, the letters were sent by Michael Kane directly to Cina Wong and to David Liebman in January of 1999. You received copies of those letters before this lawsuit was filed. You published those letters on the internet, and I simply make this record because I now note there can be no dispute about what Michael Kane said about your alleged experts, and your knowledge.

MR. HOFFMAN: About how they becameavailable to the public.

MR. WOOD: There is no - I don't think there is any dispute about what Michael Kane has said about their methodology and their credibility. That is why this is important to be put into the record, since you have referred to them earlier today. And I do that not only to clarify the record but also to point out that this is another one of the reasons that we filed what is now correctly identified by me as the 15th defense, going on. I earlier said the 13th defense. That instead of bringing this legal action out of a concern for some real injury to reputation, Plaintiff Wolf and his counsel bring this lawsuit as a publicity stunt. They have thus joined legions of persons who have tried to make personal profit from the brutal murder of defendants' child. Neither plaintiff Wolf nor his counsel possesses any admissible evidence that any defendant murdered JonBenet Ramsey. That is verbatim the 15th defense. There was some question in the litigation raised earlier in the deposition about whether that had been made in the pleadings. It is a defense tothis case asserted in the 15th defense in our answer. With those clarifications to the record, I have nothing further.

MR. HOFFMAN: I would just only like to point out one thing with respect to Mr. Kane's objection. The operative word there is "unexplained dissimilarities." And the fact is that Mr. Liebman and Ms. Wong felt that these dissimilarities were explained by the fact that the person in question, in their opinion, was trying to disguise their handwriting. And in disguising your handwriting, occasionally, you are going to create dissimilarities which are not unexplained. They are dissimilarities, but they are not unexplained dissimilarities. And that is the point I would like to make with that. And thank you.

MR. WOOD: I appreciate your statements about what they say. We look forward to that and the opportunity, as I am sure you would tell us to ourselves, cross-examine Mr. Wong, Mr. Liebman, Mr. Lacey, Mr. Miller, if he is going to be involved, as well as Mr. Epstein and Mr. Ziegler. We look forward to that day -

MR. HOFFMAN: Thank you very much.

MR. WOOD: - when we can present them the questions and get the answers from them. Thank you.

MR. HOFFMAN: All right. Thank you. Again, Mr. and Mrs. Ramsey, thank you for being here today.

THE WITNESS: We have had our differences, but we are all children of God, and I respect you for that.

MR. HOFFMAN: Thank you very much.

THE VIDEOGRAPHER: We are off the video record at 3:03.

(A recess ensued.)

MR. WOOD: Just before we complete the record, I wanted to state that, on behalf of the Ramseys, and in this instance particularly John Ramsey, that we do not claim any confidentiality as to this deposition. The Ramseys agree that this deposition of John Ramsey, just like the deposition of Patsy Ramsey, can be presented publicly with no claim of confidentiality, unlike every other witness and party in the case to date. Every other witness, including SteveThomas, including, in part, Mr. Wolf, and the other witnesses so far, Alex Hunter, Mark Beckner, Carey Weinheimer, have all claimed a measure of, if not entire, confidentiality. The Ramseys want the whole truth in this case out, and they are willing for the public to see their depositions in its entirety. So we make no claim to confidentiality.

MR. HOFFMAN: And with respect to any claim of confidentiality that has been made in Chris Wolf's case, it has been a limited level of confidentiality; and we, of course, invite the Ramseys, to whatever extent they feel appropriate, to release any or all part of the unredacted portion of Mr. Wolf's deposition.

MR. WOOD: I appreciate that. On behalf of the Ramseys, we would ask you to do the same thing they are doing, that is, let the entire truth come out about Chris Wolf and not prevent the public from knowing all aspects of his life, including those that you have chosen selectively to deem confidential. I would like for Mr. Wolf's deposition in its entirety to be made public, not just theselected portions. I think the truth - that is why I haven't let it out, because I don't want - I want the whole truth out, not just parts of it. Let it all come out.

(Whereupon, the deposition was concluded.).