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Forum Name: old depo and interview threads
Topic ID: 3
Message ID: 2
#2, RE: Thomas depo 43 - evidence
Posted by jameson on May-18-03 at 08:57 PM
In response to message #1
Q. At page 232 of your book -- I apologize, I apparently have gotten the wrong cite in my record.
Oh, 236, I'm sorry, 236 where you say first paragraph under the line right here "With our Dream Team,
we tallied the points supporting probable cause and found more than 50 items."

A. Yes, I'm with you.

Q. When was that tally made? Date that for me.

A. Mr. Wood, I can't date it specifically but they assisted us in our preparation for the VIP
presentation and just a quick reading of this was maybe spring or late spring of '98. But no, it was
before that because later in the paragraph it talks about the Title-3, which was way back before
Christmas '97. So this was, I would guess, late '97, early to spring of '98.

Q. Can I -- I don't have the time today, at least, to ask you to go through and list those 50 items. But
can I be reasonably confident that if I set about myself in your book that I could find reference to those
50 items in this book, that you have included those somewhere in here?

A. No, I can't commit to that because of what was, I remember there was an easel that was used in
which everybody in the room put out evidence, information, that sort of thing that went on to this
50-plus point probable cause board.

Q. So it may have been all of your points, you may have --

A. It certainly wasn't.

Q. You may not agree with all of them?

A. Right.