24 Q (BY MR. WOOD) Did the Boulder Police
25 Department ever issue a search warrant in connection
1 with Chris Wolf, either his premises or in connection
2 with obtaining, for example, his computer, laptop
4 A I can't recall.
5 Q Who would you point me to to say,
6 Mr. Wood, here is the person that I think is the best
7 person to talk to about those kind of specifics or
8 would you say --
9 A Possibly --
10 Q -- better to get the records and look?
11 A Possibly Tom Wickman or Tom Trujillo.
12 Q On a lot of these questions could we be
13 dealing with a situation where we might run around in
14 a circle trying to figure out who knows the answer to
15 a question like that. Would it be better to simply
16 try to get the documents to look at them as they
17 pertain to Chris Wolf, no questions about that?
18 A It might be better to say here is -- we
19 have a question about whether there was a search
20 warrant and then we can go research that and find
21 that out for you. To try to remember everything that
22 has occurred over a four- or five-year period --
23 Q Were there search warrants issued against
24 or pertaining to individuals other than Ramsey family
1 A I'm not sure. Because in a lot of cases
2 we just got cooperation so I'm not sure.
3 Q I mean as you sit here today, can you
4 recall any search warrant being issued that was not
5 issued against the Ramseys or a Ramsey family member?
6 MR. MILLER: I take it you're not
7 including 41-1 as being -- even though it's under the
8 search and seizure rules in Colorado.
9 MR. WOOD: 41-1, you have to tell me what
10 41-1 is.
11 MR. MILLER: That's non testimonial.
12 MR. WOOD: Oh, are you talking about --
13 no, we know that there was a -- we know that any
14 number of individuals provided non-testimonial
16 MR. MILLER: It's under the same rule in
17 Colorado. So --
18 MR. WOOD: I'm asking now about the
19 issuance of a search warrant for the ability to
20 search or seize property of an individual.
21 A I'm just not sure, sure enough to answer
22 that under oath.
23 Q (BY MR. WOOD) Okay. That's something you
24 could research and find out?
25 A (Deponent nods head.)
1 Q True?
2 A Yes.
3 Q You indicated that there was some
4 telephone conversations between Jackie Dilson and
5 Chris Wolf that were tape recorded and monitored or
6 reviewed by the Boulder Police Department.
7 A Yes.
8 Q Tell me about those.
9 A I don't know a lot about them, I did not
10 review them.
11 Q How were they obtained?
12 A Through Jackie Dilson.
13 Q Who taped them?
14 A Again, that's something I would have to
15 research; I don't know off the top of my head.
16 Q Is it possible the Boulder Police
17 Department performed the taping?
18 A I believe we did in conjunction with
20 Q Would that have been through some
21 mechanism, again, Bob knows all about this, not more
22 about this, in Georgia you can record a conversation
23 if you're party to it?
24 A Right, yes, you can.
25 Q But if you're not a party to it you can
1 not record it. I don't know whether Jackie Dilson --
2 if that's the Colorado law or not. Was there any
3 search warrant or any judicial authority granted for
4 the Boulder Police Department to tape record those
5 conversations or do you believe it was permissible
6 for the department, if it did so, to do so under an
7 agreement with Jackie Dilson who was a party to the
9 A No, it would have been legal in Colorado
10 to do that because she was a party to the
12 Q And consented to the Boulder Police
13 Department taping?
14 A Yes.
15 Q Do you know how many conversations,
16 ballpark, that you believe were tape recorded?
17 A No, I don't.
18 Q Was Jackie Dilson provided with any type
19 of questioning or scenarios to discuss with Chris
20 Wolf designed to evoke potential incriminating
21 statements from him?
22 A I don't know.
23 Q What would you have expected?
24 A My expectation would be that there would
25 be some conversation around those issues.
1 Q You would have a guy like Steven Pitt who
2 could give you input into things she might be able to
3 say that might trigger a particular answer that might
4 show some or provide information one way or the other
5 to the department?
6 A Sure.
7 Q Do you know whether Steven Pitt --
8 A No, I don't.
9 Q Would you have expected him to do so?
10 A No, I'm not sure what time frame we're
11 talking about. So I don't know whether he was even
12 involved at that time.
13 Q Is he actively involved now?
14 A No.
15 Q How long has he been off the case?
16 A A couple years.
17 Q He was off prior to the grand jury being
18 adjourned in 1999, wasn't he?
19 A Prior to it being adjourned?
20 Q Well, sent home, discharged?
21 A You know, I'm not sure whether he was
22 still consulting at that time with the DA
23 investigators or not.
24 Q Okay. Let me just ask this specifically,
25 I threw it in with the search warrant question, did
1 the Boulder Police Department ever make any attempt,
2 to your knowledge, to obtain and perform a search on
3 any computer used by or owned by Chris Wolf?
4 A I don't know.
5 Q Jackie Dilson in her statement to
6 authorities, I would ask you to assume, indicated
7 that -- is there a part of that you want me to pull
8 out of that assumption?
9 A Well, just when you say assume, okay.
10 Q Well, I mean, I think it's fairly reliable
11 that Jackie Dilson informed the Boulder Police
12 Department that on the 26th of December that one of
13 the things that she thought was suspicious about
14 Chris Wolf was that he wanted one of her relatives, I
15 believe, to delete certain files from his, I believe,
16 laptop computer. Does that ring any bells to you in
17 terms of refreshing you on information that might
18 have been obtained by the Boulder Police Department
19 on that issue?
20 A Vaguely.
21 Q Since it's vague and not clear, let me put
22 it in the form of a hypothetical. To assume that she
23 provided substantively that type of information,
24 would you have expected the Boulder Police Department
25 to undertake efforts to obtain the computer to see
1 then if they could ascertain the contents of the
2 files that allegedly had been deleted?
3 A Without knowing the full context, it's
4 hard to answer that. And without knowing all the
5 information that was available and what information
6 was available, it's hard to answer that.
7 Q Were any -- did the Boulder Police
8 Department engage in any investigative efforts to
9 review contents of individuals' computers who were
10 under suspicion?
11 A Boy, I don't know. I can't recall at this
12 time if we did that or not.
13 Q Jackie Dilson also has indicated, and I
14 believe Chris Wolf has confirmed, that she presented
15 the Boulder Police Department with the blue cotton
16 sweater worn by Chris Wolf. Do you recall that
17 being --
18 A I don't recall that. I recall vaguely
19 that there was some clothing that she offered.
20 Q Were any fiber tests, forensic tests
21 conducted on those articles of clothing by the
22 Boulder Police Department?
23 A I don't know.
24 Q Would you have expected there to be?
25 A Again, without knowing the context and all
1 the information, it's difficult to answer.
2 Q The context of Chris Wolf being
3 investigated as an individual under the umbrella of
5 A Without knowing what the clothing is and
6 whether there was something that potentially could
7 match --
8 Q Blue cotton sweater?
9 A -- those things, I would expect that.
10 Q Because there were blue fibers found on
11 the crime scene?
12 A Yes.
13 Q So do we know whether the fiber test was
14 conducted on the blue cotton sweater and, if so, the
15 results of whether there was any type of consistency
16 in the fibers with the fibers found at the crime
18 A That I don't know.
19 Q Fiber evidence in and of itself would not
20 eliminate any individual as being under suspicion,
21 would it?
22 A In what way?
23 Q In any way.
24 A Well, fiber evidence -- it's not evidence
25 if it's not a match. So what do you mean by
2 Q When you say it's not a match, that's
3 loose. I mean matches are rare in fiber analysis,
4 aren't they? What you generally come up with --
5 A I don't know how rare they --
6 Q -- is consistent with, isn't that what you
7 generally get?
8 A Yes.
9 Q Okay. Because it would take a very unique
10 fiber to say that we can absolutely tell you that
11 this is a match?
12 A Yes.
13 Q That's a very rare, if ever, occurrence,
15 A Yes.
16 Q So if I have got Chris Wolf and he's got a
17 blue cotton sweater and he submits that to the
18 authorities and you check and you say, okay, we've
19 got a fiber from this sweater of Mr. Wolf's and it's
20 consistent with the blue cotton fiber that we found
21 at the crime scene, that doesn't tell you that Chris
22 Wolf was involved in the murder, does it?
23 A No.
24 Q And if it comes back that it's not
25 consistent with, that doesn't tell you that he was
1 not involved in the murder, does it?
2 A Correct.
3 Q But you would want to know, it would seem,
4 if he's under suspicion and he submits material to
5 you, in this case hypothetically blue cotton, you
6 would expect it to be analyzed because there were
7 blue cotton fibers found on the crime scene, true?
8 MR. MILLER: Objection. Asked and
10 Q (BY MR. WOOD) Am I right?
11 MR. MILLER: You can answer it again.
12 A Yes.
13 Q (BY MR. WOOD) Okay. To your knowledge,
14 have those blue fibers at the crime scene ever been
16 MR. MILLER: Wait a minute. What is the
18 MR. WOOD: To his knowledge, have the blue
19 fibers found at the crime scene ever been sourced.
20 A There are a lot of reports around on fiber
21 evidence. To the best of my recollection, no.
22 Q (BY MR. WOOD) Were there any other color
23 fibers found at the crime scene that had not been
25 A That have not been sourced?
1 Q Yes.
2 A Yes.
3 Q What colors?
4 A Brown.
5 Q So blue, brown, anything else?
6 A Not off the top of my head, no.
7 Q That's something that could be ascertained
8 with research?
9 A Yes.
10 Q Do you know whether Jackie -- do you
11 recall Jackie Dilson turning in any sheets to the
12 Boulder Police Department that she said were sheets
13 that had been slept on or in contact with Chris Wolf?
14 A I don't recall it, no.
15 Q Again, that would be something that
16 someone might -- would be expecting to find in the
17 records if researched?
18 A Yes.
19 Q Because you would log it in and you would
20 obviously keep up with wherever it was sent for
21 testing and the test results?
22 A Yes.
23 Q Do you know -- I believe Chris Wolf has
24 told us that he gave blood samples. Is that a form
25 of non-testimonial evidence that the Boulder Police
1 Department was obtaining from people under suspicion?
2 A It was a form, yes.
3 Q What type of testing was done on blood
4 samples that were obtained from individuals under
6 A Well, I know there were some DNA tests
7 done on blood samples.
8 Q Any other test, other than DNA?
9 A Not that I'm aware of.
10 Q Do you know whether DNA -- I believe you
11 told me DNA tests were done or were performed with
12 respect to Chris Wolf?
13 A Yes; to the best of my recollection, yes.
14 Q Do you know the results?
15 A Yes.
16 Q What were the results?
17 A He did not match the DNA from the scene.
18 Q Has anyone matched the DNA from the scene?
19 A No.
20 Q Can you give me a ballpark figure of how
21 many individuals have submitted DNA?
22 A Well, back up a minute. There is more
23 than one sample of DNA. So specifically what are you
24 referring to?
25 Q Well, as I understand it, there is DNA and
1 I don't want to get technical here, but I understand
2 there was DNA found, foreign DNA, found under the
3 fingernails on JonBent's left and right hands; am I
5 A Okay. Yes.
6 Q As I understand it, there was foreign DNA
7 found either on -- I'll just say on her underwear?
8 A Yes.
9 Q Now, I'm not aware as I sit here of any
10 other DNA. Was there any other?
11 A Yes.
12 Q Where was it?
13 A Well --
14 MR. MILLER: Just a minute.
15 THE DEPONENT: Yeah. We're getting into
16 evidence here.
17 MR. MILLER: I don't think you should
18 answer that question.
19 Q (BY MR. WOOD) I have to be able to know.
20 You raised the issue yourself about the different
21 areas of DNA. So I assume it has some relevance to
22 the subject matter that I'm asking you about in terms
23 of the tests done with Chris Wolf.
24 A You can certainly ask me if Chris Wolf
25 matched any DNA at the scene. I can answer that.
1 Q But I'm asking you about -- but I asked
2 you whether anyone else's did and you indicated
3 initially no. I said Do you know whether DNA -- I
4 believe you told me DNA tests were done or performed
5 with respect to Chris Wolf?
6 Yes; to the best of my recollection, yes.
7 Do you know the results?
9 What were the results?
10 "Answer: He did not match the DNA from
11 the scene.
12 "Question: Has anyone matched the DNA
13 from the scene?
14 "Answer: No.
15 "Question: Can you give me a ballpark
16 figure of how many individuals have submitted DNA"
17 and you didn't answer that.
18 You said "Well, back up a minute. There
19 is more than one sample of DNA. So specifically what
20 are you referring to" was the question you posed to
22 So that has relevance of your own inquiry
23 and so I need to find out what other DNA you're
24 referring to.
25 A When you asked the question, I'm thinking
1 the unknown DNA.
2 Q Well, I mean --
3 A I answered the question in that context.
4 Q Known DNA -- I'm talking about DNA foreign
5 to JonBent.
6 A Okay.
7 Q That's what I'm asking you about and
8 whether any of that has been matched, DNA found on
9 her, foreign to her, whether that was matched to
10 Chris Wolf?
11 A DNA found on her?
12 Q Or on her clothing.
13 A And the question is did that match to
14 Chris Wolf? The answer is no.
15 Q Has it matched, been matched to anyone?
16 A The DNA on JonBent?
17 Q And/or on her clothing?
18 A No.
19 Q Obviously you're telling me there was DNA
20 that was not on JonBen t or on her clothing; is that
22 A Correct.
23 Q Where was that?
24 A We're getting into areas where I feel like
25 we can't go.