Q. At what point in time did you say I think Patsy Ramsey killed her daughter?

A. I think the evidence led me to those conclusions and further strengthened my belief in the early
months of 1997.

Q. When in 1997, the early months, what does that mean? Tell me what that means with some
specificity, please, sir.

A. There was not a defining moment in which the bell rang and I noted the date and time. Early in
1997 it became more and more apparent to me that that's where the abundance of evidence was
leading.

Q. And you were heavily influenced in that determination by the conclusion of John Foster, weren't
you, sir?

A. Don Foster?

Q. Don Foster, yeah.

A. No, he did not come on board for I think almost another year.

Q. Right. So you had decided in your mind's eye that Patsy Ramsey killed her daughter many
months before Don Foster made the appearance as a consultant in the case, right?

A. Again, Mr. Wood, as I said, I felt there was an abundance of evidence pointing in that direction.
And that became -- and others viewed it the same way, incidentally. And, yes, in those early months of
'97, she looked pretty good for that.

Q. Yes, sir. Thank you. But that doesn't answer my question. You had decided in your mind's eye
that Patsy Ramsey killed her daughter many months before Don Foster made his appearance as a
consultant in the case, true?

A. I felt that she was the best suspect, yes, many months prior to Don's... Foster's involvement.

Q. Plaintiff's Exhibit Number 2 is Mr. Foster's letter to my client, Patsy Ramsey. Have you seen
that letter before?

A. I haven't looked at it yet.

Q. Do you think there was more than one?

MR. DIAMOND: Can you hold on a second?

MR. WOOD: Did I call that Plaintiff's Exhibit 2, it's Defendants' Exhibit 2, excuse me.

MR. SMITH: I don't have any --

MR. WOOD: I can't hear you. I can assume the general gist of what you're saying.

(Pause.)

MR. WOOD: Do you want to go off the record to save tape?

MR. DIAMOND: No, I will be done in a second. How are you doing?

THE DEPONENT: Yeah, I'm keeping up with you on it.

MR. DIAMOND: Do you want to give him a moment to look at it?

Q. (BY MR. WOOD) If you want to look at it, we can take a break instead of wasting tape
because I don't want it to count against my time?

MR. DIAMOND: If you show him a document he has a right to read it. If you only come with one
we've got to read it one at a time. This is your time use it the way you want.

MR. WOOD: Every road goes in two directions, Mr. --

MR. DIAMOND: Diamond.

MR. WOOD: Diamond, is that your name? I'm sorry, I forgot it just momentarily. Why don't we take
a five-minute break and let him read that. I need to go to the restroom anyway.

VIDEO TECHNICIAN: The time is 3:48. We're going off the record.

(Recess taken from 3:48 p.m. to 3:53 p.m.)

VIDEO TECHNICIAN: The time is 3:53. We're back on the record.

Q. (BY MR. WOOD) Defendants' Exhibit Number 2, you've had an opportunity to review it during
the break?

A. Yes.

Q. That is what you recall being as being a true and correct copy of a letter that was subsequently
brought to your attention at some point in the investigation that Mr. Foster, Don Foster, had written to
Patsy Ramsey in June of 1997?

A. I had only seen the first page of that.

Q. Does the first page appear to be a true and correct copy of that page that you saw?

A. Yes.

MR. DIAMOND: Did you get an audible response?

MR. WOOD: I thought he said yes. Did you get a yes?

THE REPORTER: Yes.