24 Q (BY MR. WOOD) Did the Boulder Police

25 Department ever issue a search warrant in connection

109

1 with Chris Wolf, either his premises or in connection

2 with obtaining, for example, his computer, laptop

3 computer?

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

25 members?

110

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

15 evidence.

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.)

111

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

19 Jackie.

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

112

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

8 conversation?

9 A No, it would have been legal in Colorado

10 to do that because she was a party to the

11 conversation.

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.

113

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

114

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

115

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

116

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

4 suspicion?

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

17 scene?

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

117

1 evidence?

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,

14 true?

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

118

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

9 answered.

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

15 sourced?

16 MR. MILLER: Wait a minute. What is the

17 question?

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

24 sourced?

25 A That have not been sourced?

119

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

120

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

5 suspicion?

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

121

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

4 right?

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.

122

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?

8 Yes.

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

21 me.

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

123

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

21 correct?

22 A Correct.

23 Q Where was that?

24 A We're getting into areas where I feel like

25 we can't go.