In this section we see .... well, if the Ramseys had pulled this crap in their interviews or depositions, Thomas would have been all OVER them - - just read it and feel your blood pressure rise - - I don't know, I can't remember, you didn't word that quite right...

VIDEO TECHNICIAN: The time is 9:45. We're back on the record.

Q. (BY MR. WOOD) I'm going to try to make sure I can avoid any problems that Mr. Diamond
might have with my question. Let me go back and withdraw the last question and restate it. What I
would like to know, Mr. Thomas, is do you have notes pertaining to your involvement in or the
investigation of the murder of JonBenet Ramsey?

A. The Boulder Police Department has those notes. I don't know that I have any notes.

Q. You left the Department by resignation of August the 6th, right?

A. Yes.

Q. 1998?

A. Yes.

Q. When did you turn over all of your notes to the Boulder Police Department?

A. Shortly thereafter.

Q. Who did you turn them over to?

A. I returned my briefcases and those contents, along with all my police equipment, which was
inventoried, to Commander Dave Hayes and Sergeant Michael Ready.

Q. Did you turn over your case notebooks?

A. Everything.

Q. How many case notebooks did you turn over?

A. What do you mean by case notebooks?

Q. Don't you know what the case notebook was used in this case, sir, filled out by all of the
detectives on a daily basis?

MR. DIAMOND: He may ask you for an explanation, what you're referring to. You're not going to
help him out?

Q. (BY MR. WOOD) Do you know, sir, 6 what the case notebooks were in this case in terms of
the notebooks prepared by the detectives, I believe on a daily basis?

A. A case notebook that was prepared --

Q. Did you have --

A. -- on a daily basis?

Q. Yes. Did you have a notebook that you kept, maintained with respect to your investigation?

A. I had folders and my working papers which I maintained with respect to my parts of the
investigation.

MR. DIAMOND: He's asking about a notebook.

THE DEPONENT: Yeah, I know.

Q. (BY MR. WOOD) You didn't have them in any notebook form?

A. No.

Q. Now, those working papers, all of that was turned back into the Boulder Police Department
shortly after you resigned in August of 1998?

A. Yes.

Q. You maintained no notebooks; is that right?

A. I maintained copies of those.

Q. So you have copies of your reports?

A. No, I didn't say that. I don't know that I have those copies anymore.

Q. Well, you said you maintainedcopies. Copies of what?

A. I maintained copies of what was in my working file briefcase which I returned to the Boulder
Police Department.

Q. How many pages of documents are we talking about?

A. A couple hundred maybe.

Q. Do you have those presently in your possession, custody or control?

A. No.

Q. What did you do with them?

A. I don't know.

Q. They just mysteriously disappeared?

A. No, I have moved twice in the interim. We have some things in storage. We, my wife moved
overseas. If I still had a cardboard box full of those documents or materials. I'm unaware of their
present location.

Q. When do you last recall looking at them or reviewing them?

(Discussion off the record between the deponent and Mr. Diamond.)

A. I last looked at those in --

MR. DIAMOND: He has mentioned the first full report that he --

MR. WOOD: Yeah, well, let him answer that.

MR. DIAMOND: Are you excluding that?

MR. WOOD: No, I'm not excluding anything. I want to learn everything.

A. Early 2000.

Q. (BY MR. WOOD) How early 2000?

A. Probably February or March.

Q. That was the last time you saw them?

A. Right.

Q. And when did you move?

A. I moved -- I sold my house this summer, summer of 2001.

Q. And did you pack up your possessions?

A. Yes.

Q. So you don't have any explanation to offer as to what happened to your JonBenet Ramsey
working papers since you last claimed to have seen them sometime in February or March of 19' -- of
2000?

A. Yeah, after I last looked at them, this was a cardboard box full of these documents. And to your
question, yeah, I don't know where they are currently.

Q. You did not destroy them intentionally, did you?

A. No.

Q. You didn't intentionally lose them, did you?

A. No.

Q. You didn't think they were valuable to keep?

A. No, not necessarily.

Q. When did you -- in terms of that, you did know at some point that the Ramseys indicated they
were going to file a lawsuit against you if you published a book, didn't you?

A. Repeat the question, please.

Q. You knew early on when your book was published that the Ramseys had stated that they were
going to file a lawsuit against you?

A. I had heard through the media that they had made those threats.

Q. You didn't think it might be wise to keep up with your notes to have those in the event there was
a lawsuit?

A. Those are all available in the Boulder Police Department.

Q. So everything that you had, the 200 pages is available from the Boulder Police Department; is
that right?

A. Yes, as I said, I turned everything back to the Boulder Police Department.

Q. In fact, there's quotes in your book, for example, of interview testimony from different
individuals. For example, there are quotes alleged to have been made by Burke Ramsey in June of
1998, by John Ramsey in June of 1998, by Patsy Ramsey in June of 1998, by John Ramsey in April of
1997, by Patsy Ramsey in April of 1997 during police or district attorney interviews.

MR. DIAMOND: You'll represent that is the case?

Q. (BY MR. WOOD) Yeah, well, that is the case, isn't it; you know that to be true, don't you?

A. That the book contained --

Q. Quotes from the interviews of April 1997 and June of 1998 of John and Patsy Ramsey and from
Burke of June of 1998?

A. Yeah, I would agree with that.

Q. I'm just trying to find out, for example, your notes, would they -- would the notes have those
quotes in them?

A. What notes are you referring to?

Q. The notes that you can't find now. How would you have quotes --

MR. DIAMOND: I'm going to object.

MR. WOOD: Let me.

MR. DIAMOND: He didn't say he couldn't find them. He said he doesn't know where they are. You
haven't asked him whether he's been looking for them recently, have you?

MR. WOOD: Well, I mean, I will ask him that in a minute. Again, Chuck, we'll move quicker if you
limit yourself to instructions on privilege.

MR. DIAMOND: Mischaracterizes his testimony in your --

MR. WOOD: That's not an objection on privilege, nonetheless.