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Forum Name: old depo and interview threads
Topic ID: 31
Message ID: 0
#0, Thomas depo 7 - boxes of stuff
Posted by jameson on May-16-03 at 06:14 PM
Q. Right. Now, your materials, just so that I have got this down, how many boxes were these police
records and file copies of reports and things, both the ones you copied and the ones anonymously sent
to you from, you believe, from someone in the Boulder Police Department, right?

A. Logic would conclude that.

Q. Yeah, and that was your conclusion?

A. Yes.

Q. And, you know, how many boxes did you store those materials in?

A. One cardboard box.

Q. Size?

A. A file-size cardboard box, a banker's box.

Q. How was it marked?

A. Unmarked.

Q. What color was it?

A. White.

Q. Did you have a concern? I mean, you've been in law enforcement for a number of years.
You've got an ongoing investigation. Did you take any particular precautions to maintain the integrity of
those documents?

A. No.

Q. Did you give them to Don Davis?

A. Don Davis doesn't have -- no, he doesn't have that box or any of those records.

Q. Did he look at them?

A. Are you talking about the preparation of the book?

Q. I'm talking about the reports. Did Don Davis ever see the reports --

A. He may have.

Q. -- and the copies of the file that you made?

A. He may have.

Q. Have you ever made any effort to find them?

A. No.

Q. When did you learn that they were lost?

MR. DIAMOND: He didn't say ever they were lost.

MR. WOOD: I'm sorry?

MR. DIAMOND: He never testified that they were lost.

MR. WOOD: Misplaced or lost. Can we agree one of the two things occurred? I always kind of
figured lost means misplaced, too. When you've lost something, you've lost it. It doesn't imply
intentionally. Although, one might draw their own conclusion.

Q. (BY MR. WOOD) The point is when did you -- if you -- you've made no effort to look for
them. When did you first learn that the file box was either lost or misplaced and couldn't be found?

A. The last time I recall looking in that box was at some point in the weeks prior to the book coming
out.

Q. I'm not asking you the last time you looked at it. I'm asking you when you first learned that you
couldn't find it. You came here today under oath and told me --

A. I haven't been looking for it, Mr. Wood.

Q. Because you've told me under oath, sir, that you can't find it, haven't you?

MR. DIAMOND: I don't think he has. I don't think he's ever testified to that. Why don't you ask him
that.

Q. (BY MR. WOOD) Didn't you tell me where -- do you know where it is?

A. No.

Q. Have you made any effort to look for it in recent months?

A. No.

Q. You didn't think that, you know, Lin Wood is going to examine me on the Ramsey investigation, I
ought to try to read over some of my reports and remember some things so I'm up to speed; you didn't
ever have that thought as you came into this deposition?

A. No, I'm here to answer your questions today.

Q. But why would you not want to refresh your recollection about the investigation when you know
I'm going to be asking you about it and you knew that?

A. I did. As I told you earlier, I reread my book.

Q. But your -- all these reports and all these copies of police reports, there is a lot more information
there than what is in your book, isn't there, sir?

A. There may be, yeah. The book is not a police report, it's a narrative.

Q. No, then it's not complete. It certainly is not as complete as the hundreds of pages of police files,
reports and copies of reports that you have had at least at some point in time in your possession, is it?

A. It's not a reproduction of the 30,000 plus page case file, no. That's ridiculous. No.

Q. It's not a reproduction of the hundreds of pages that you had in your possession, is my question, is
it, sir?

A. No.

Q. I mean, if we want to find out what information you know about this investigation from the police
reports, we can't get an answer to that from reading the book. We would have to look at all the files
and the reports that you had, wouldn't we?

A. I'm here to answer your questions today.

Q. Answer that one for me. If I want to try to find out what information you had known or what
you knew about this investigation from all these hundreds of police reports that you copied or that were
sent to you, I can't get that answer from your book. I can only get that answer if I can look at those
files and reports, true?

A. Okay.

Q. Is that true?

A. Sure.