Q. (BY MR. WOOD) Mr. Thomas, I'm trying to figure out whether you had notes that would have
had these precise quotes in them and that's how you were able to use them to come up with the quotes
in your book. Or did you come up with those quotes from their various interviews from your mind's
eye, your own recollection only? Do you follow me? A. Yes.
Q. Which was the case?
A. They were either in notes which I had or in documents I subsequently received.
Q. And what documents did you subsequently receive about the investigation?
A. After I left the police department, over a period of time I received through the mail various
documents concerning the investigation.
Q. From whom?
A. Anonymously through the mail.
Q. Postmarked from where?
A. Boulder or Denver.
Q. And were these documents police files or reports on the JonBenet Ramsey investigation?
A. Yes.
Q. Were they documents from the district attorney's office on the JonBenet Ramsey investigation?
A. What do you mean from the district attorney's office?
Q. Well, for example, a report prepared by Michael Kane, as opposed to a report prepared by Mark
Beckner. One works for the Boulder PD and one works for the district attorney or did. You know the
difference.
A. No, these were Boulder Police Department documents.
Q. And how many pages of documents did you receive subsequent to the time that you left the
Boulder Police Department that concerned the JonBenet Ramsey murder investigation?
A. Several hundred.
Q. Where are those documents?
A. Unknown. They would be in the same box if I still have it.
Q. So how many -- let me see if I've got all the sources of written materials that you had after you
left the Boulder Police Department on August the 6th, 1998. You had some couple hundred pages of
your work papers that you had copied, correct?
A. Correct.
Q. You didn't make copies of police reports?
A. In what context are you talking about?
Q. In this 200 some odd pages of your working papers, were there also copies of police files, police
reports on the JonBenet Ramsey investigation?
A. Yes, these were my working papers, yes.
Q. Well, for example, would it only be reports prepared by you or did you have copies of reports
prepared by other officers?
A. As I was the affiant on the master affidavit in this case I certainly was in possession of reports
from others to include in any search or arrest warrant in this case.
So the answer is yes?
A. To what question?
Q. The one I asked you. Did you have copies of other officers' reports on the JonBenet Ramsey
case in your working papers?
A. Yes.
Q. You make reference to being the affiant on the master affidavit. Did your working papers then
include copies of all of the documents that you had and had in any way relied on in preparing the master
affidavit in the JonBenet Ramsey case?
A. If I understand you correctly, no.
Q. Were you authorized to keep those copies by the Boulder Police Department?
A. When I resigned abruptly, I returned all those papers to the Boulder Police Department and there
was no further communication between us.
Q. But did you tell them you had kept copies of the papers?
A. No.
Q. Am I correct that everything you had in your physical possession in terms of case files, case
reports, notes, at the time that you resigned, whatever you turned over to the Boulder Police
Department at the time of your resignation, you made copies of and kept yourself; is that right?
A. I believe so.
Q. And that was only a couple hundred pages?
A. I believe so, yes.
Q. And did you keep, for example, a transcript of the April 30, 1997 interview that you conducted
with Patsy Ramsey?
A. I don't know.
Q. So subsequent to leaving, from what period of time until what period of time were you receiving
anonymous police file information on the JonBenet Ramsey case that you say totaled several hundred
pages? When did it start and when did you last get something?
A. Initially after I had made my intentions known that I was going to tell my story through a book.
And that was probably early, maybe January of 1999 and throughout that calendar year of 1999.
Q. Any materials in the year 2000?
A. Not that I recall.
Q. Did you make any efforts to solicit information from any member of the Boulder Police
Department about the investigation after you left?
MR. DIAMOND: May I ask a clarifying question? Solicit written materials or just talking to
somebody?
MR. WOOD: Information, case information about the case.
A. Can you repeat the question please?
Q. (BY MR. WOOD) Sure, did you make any efforts to solicit information about the JonBenet
murder investigation from any member of the Boulder Police Department after you left the department
in August of 1998?
A. No.
Q. Do you have any idea who sent you any of these alleged anonymous documents?
A. These are smart people. No.
Q. How do you know they were accurate if you don't know who sent them to you?
A. Because I had previously seen all of them.
Q. So this was information that was contained in the case file that you didn't copy when you left the
force, but it predated your leaving the force; is that true?
A. Yes.
Q. Did you ever receive any information about grand jury testimony or evidence in the case?
A. Never.
Q. Did you ever receive any information about the investigation in terms of efforts and information
subsequent to the investigation August 1998? Let me withdraw that and make it a little bit cleaner. I
want to know, you tell me the information you got predated your resignation date. Did you ever get any
new information, that is to say information that was generated about the case after August of 1998?
A. Without reviewing this box, I would have to say as we sit here now that it was all pre-August
'98. I don't recall sitting here that any of it was post-August '98.
Q. So that the documents that you have and the information that you had about the case, your best
recollection is that would have been limited to information generated prior to August of 1998, true?
A. Yes.
MR. DIAMOND: Counsel, I see no relevance to this line other than to find out what he knew at the
time he wrote the book. I instruct him not to answer. If you want to take this up with the judge, I am
happy to do so. If you want to make a record as to why this is relevant to the Wolf case, I'm happy to
listen to you. Otherwise, he's instructed not to answer. Move on.
MR. WOOD: Is there a privilege being asserted?
MR. DIAMOND: You heard me, move on.
MR. WOOD: Sir, if you will be polite, we will be polite, also.
MR. DIAMOND: Go ahead. I am happy to be polite.
MR. WOOD: Yes, sir, please do.
Q. (BY MR. WOOD) My question is, I'm trying to find out about your knowledge concerning the
JonBenet Ramsey investigation. And it seems from what I am hearing that your knowledge is limited
to information about the case from the date of the murder in 1996 through August of 1998. Is that
right?
MR. DIAMOND: From police sources is what you have asked him about?
MR. WOOD: My question is on the table, now, sir. We can call Judge Carnes and correct the
problem that we're experiencing with you if we need to. I hope we don't need to.
MR. DIAMOND: We may well have to.
MR. WOOD: We certainly may have to if you keep interrupting inappropriately under the Federal
Rules of Civil Procedure, procedure for depositions.
Q. (BY MR. WOOD) Could you answer my question, please, Mr. Thomas?
A. Could you repeat it for me, please?
Q. Sure. I'm going to read it right back to you. I'm trying to find out about your knowledge
concerning the JonBenet Ramsey investigation. And it seems from what I'm hearing that your
knowledge is limited to information about the case from the date of the murder in 1996 through August
of 1998; is that right?
A. No, after August of 1998, I certainly followed media accounts and what was released publicly
and followed the case with some interest.
Q. Fair enough. Let me add that in. Can I then say in terms of drawing a circle around your
knowledge of the JonBenet Ramsey murder investigation, that your knowledge consists of knowledge
about the police information and to some extent district attorney information from the date of the
murder until the time you left in August of 1998 and subsequent to 1998 has been supplemented by
what you have learned either through media accounts or through official statements from the Boulder
Police Department or the district attorney's office; is that right?
A. Very confusing question. Can you break that up for me? I don't understand what you --
Q. I just want to find out what you've got. You've got your personal knowledge. You've got the
police file information that you described for me, the copies of the documents you copied, the
documents that have been sent to you subsequent. And that all dealt, you believe, pre-August 1998,
right?
A. I'm not following you, Mr. Wood.
Q. Well, stick with me. I'll try and make it simple for you.
A. Please.
Q. More simple. You've told me about the documents. I've covered all the documents, haven't I?
You've got the documents you copied and you've got the documents that were anonymously sent to
you, right?
A. Yes, that's correct.
Q. Do you have any other documents about this investigation, other than those documents? Do you?
A. Oh, I'm sorry. If I understand the question correctly, no, as I said, not that I recall because
post-August '98 began the grand jury. And certainly I don't have any information from the grand jury
room.
Q. So we've got your personal knowledge about your involvement in the case, right?
A. Yes.
Q. We've got your knowledge from the written documents that you've just described for me?
A. Yes.
Q. And then subsequent to August of 1998, your knowledge about the case and its status would be
limited to what you have either seen or heard in the media or what may have been officially stated by
law enforcement authorities, right?
A. As far as I recall, I don't recall anything, as I have said, post August of 1998 coming my way, but
I'm not limiting myself to that, if that answers your question.
Q. As we sit here today, can you think of anything other than that? Is that your best recollection as
you sit here today, sir?
A. Yes, as I sit here right now, if I understand this correctly, that's my answer.
Q. And I'm sure that you came to this deposition in an effort to prepare for it and to refresh yourself
about the investigation, you knew you were going to be asked about it, didn't you?
A. The question being I know I was going to be asked about the investigation?
Q. Sure.
A. Yes.