19 A Well, you could have suicide, natural

20 death, accidental death, homicide.

21 Q What else?

22 A Homicide, accidental, natural, suicide. I

23 think that probably covers it.

24 Q So you're not sure if the other case was a

25 homicide case or not? You said you assisted in a

15

1 couple of homicides, you may have been referring to a

2 couple of death investigations, one being the Stoner

3 homicide, the other you don't recall?

4 A It seems like there was another homicide

5 during that two-year period but I can't recall now.

6 Q Then when we moved into the frame of 1983

7 to 1986 when you were a patrol sergeant and I think

8 you indicated you did some crime -- served as a crime

9 scene investigator?

10 A Um-hum.

11 Q Did you have any experience at that time

12 in homicide investigations?

13 A No.

14 Q And then with respect to the tactical

15 patrol unit --

16 A And again, specifically homicides versus

17 death investigations?

18 Q Right. Yeah, I'm asking you about

19 homicide investigations.

20 A Okay.

21 Q Then you started '86, '87 for a year or

22 two with the tactical unit. Any occasion there to be

23 involved in homicide investigations?

24 A No.

25 Q No. '88, '89, back to patrol followed by

16

1 nine months as traffic supervisor. During that time

2 period, any homicide investigations?

3 A No.

4 Q Three years starting in '91 as the

5 professional internal affairs investigator?

6 A (Deponent nods head.)

7 Q Any homicide investigations during that

8 time period that you were involved in?

9 A No.

10 Q 1994, commander to patrol for I believe

11 you said the second watch?

12 A Yeah.

13 Q What is a second watch, is that a time?

14 A Swing shift, it would be 3 in the

15 afternoon until 1 in the morning primarily.

16 Q During that time period which looks like

17 about three years up until October of '97, did you

18 have any involvement in any homicide investigations?

19 A Some peripheral involvement in one.

20 Q And what do you mean by some peripheral

21 involvement?

22 A As the commander, I was actually acting

23 chief at one time when we had a homicide and I

24 responded to that and kind of generally oversaw the

25 investigation for a couple of days until the chief

17

1 got back in town.

2 Q What type of case was that, do you recall?

3 A That was a person who opened his door,

4 there was a knock at the door, opened his door and he

5 was shot in the chest and killed.

6 Q Was that case ultimately solved?

7 A Not yet.

8 Q And then in 1997 specifically in October

9 of 1997, you were placed in charge of the Ramsey,

10 JonBent Ramsey, murder investigation?

11 A October of '97, yes.

12 Q Correct. And that was your, at the time,

13 sole assignment?

14 A Yes.

15 Q Let me go back and make sure I've got -- I

16 believe I have this correctly. Prior to October of

17 1997 when you were placed in charge of the JonBen t

18 Ramsey investigation, your experience in homicide

19 investigations would have consisted of assisting in a

20 couple of homicide investigations back in 1981 to

21 1983 where you did in one some interviews, the other

22 you're not really familiar with in terms of

23 recollection and then in one case sometime in the

24 1994 to '97 time frame where you were the acting

25 chief and therefore oversaw for a two-day time period

18

1 the investigation into the homicide where the

2 individual was shot in the chest when he opened the

3 door?

4 A Correct.

5 Q Have I now covered all of your homicide

6 experience as a police officer prior to October of

7 1997?

8 A To the best of my recollection.

9 Q Thank you. Do you know why you came to be

10 the individual selected to be in charge of the Ramsey

11 investigation in October of '97?

12 A I mean, I have a pretty good idea why.

13 Q Tell me what that pretty good idea is.

14 A I don't want to answer for Chief Koby

15 obviously.

16 Q What is your understanding and belief is

17 what I'm asking, I'm not asking for Chief Koby?

18 A Some of what I am good at is coordinating

19 and organizing, I mean managing large-scale events

20 and I think that was part of the reason that Chief

21 Koby tabbed me at that time. There was some concerns

22 about the coordination and organization of the

23 investigation. And I think he saw those abilities in

24 me and thought that I could bring some better

25 organization to the investigation itself.

19

1 There was also some conflict between the

2 DA's office and the police department at that time

3 and he felt like I could ease some of those

4 relationships and improve those relationships.

5 Q And I don't mean this disrespectfully but

6 I guess you would agree with me that you weren't

7 brought in to be in charge of the Ramsey

8 investigation in October of '97 because of your

9 experience in dealing with homicides?

10 A No.

11 Q You would agree with me, wouldn't you?

12 A I would agree with you.

13 Q When you were commander during this time

14 period of the second watch, give me some idea of what

15 your job responsibilities were.

16 A Responsible for everything that happened

17 in patrol on watch two. I was the commander. Above

18 me was the chief. So everything that happened in

19 patrol on watch two I was responsible for and managed

20 basically.

21 Q Give me some feel for what could happen in

22 terms of the patrol on the second watch that you

23 would be in charge of. I guess we're talking about

24 anything that happens with your patrol officers --

25 A Sure, sure.

20

1 Q -- that work under you?

2 A Anything that happened with patrol

3 officers, any major crimes that occurred. And what I

4 didn't mention, I left out, is I was -- during that

5 time I was also the SWAT commander for the

6 department. And we had some major events that

7 occurred during those years that I was responsible

8 for as far as the department response in managing

9 those events. And so those were things that were

10 part of my duties as well.

11 Q That might have been part of your

12 background in coordinating and managing large events,

13 some of the work with the SWAT?

14 A I'm sure that was part of my role.

15 Q The SWAT commander didn't get you involved

16 in any homicide investigations, did it?

17 A I'm trying to think if we had any deaths

18 during that time. I don't believe we did.

19 Q Am I correct that you replaced John Eller?

20 A Yes.

21 Q John Eller was in charge of the Ramsey

22 investigation prior to October of 1997?

23 A Yes.

24 Q Now, you said that in March of 1998, your

25 job responsibilities changed and you were placed in

21

1 charge of the entire investigative unit?

2 A Correct.

3 Q Tell me -- I think I understand, but tell

4 me what that meant to you in terms of your job

5 responsibilities. And obviously you went beyond the

6 Ramsey case, but how much further?

7 A Yes, I became -- managing all the

8 detectives that we had in the bureau at that time as

9 their commander, again then ultimately responsible

10 for anything that happened in investigations.

11 Q Is the investigative unit, in effect, the

12 detective unit?

13 A Yes.

14 Q Okay.

15 A Interchangeable.

16 Q How many detectives worked under you when

17 you took that job on in March of 1998? And again I

18 know this -- give me your best estimate?

19 A I believe we had 16 or 17.

20 Q And how many were working under you when

21 you took charge of the Ramsey case in October of '97?

22 A We had eight.

23 Q Did anyone take on any sole responsibility

24 for the Ramsey case under your supervision when you

25 took on in March of '98 the responsibility for the

22

1 entire detective unit?

2 A Yes, Sergeant Tom Wickman was actually in

3 charge of the investigation. Detective Tom Trujillo

4 was the lead investigator assigned to that case. So

5 when we say that I was in charge of the

6 investigation, what really that means is that I

7 managed the personnel that were investigating that

8 case.

9 Q Would that be true in October of '97?

10 A Yes.

11 Q In October of '97, you took on

12 responsibility for managing the personnel who were

13 handling the case, Tom Wickman being in charge of the

14 detectives handling the Ramsey case and Tom Trujillo

15 being the lead detective?

16 A And coordinating the investigation.

17 Q And your job to coordinate the

18 investigation?

19 A Yes.

20 Q Right. And so when you took on the more

21 expanded role in March of 1998, that hierarchy as

22 such did not change, Wickman still was in charge

23 responding to you?

24 A (Deponent nods head.)

25 Q You were managing the detectives?

23

1 A Correct.

2 Q And coordinating the investigation?

3 A Correct.

4 Q Trujillo remained the lead detective?

5 A Correct.

6 Q Did Steve Thomas ever have the role of

7 lead detective in the Ramsey investigation?

8 A Not under my command, no.

9 Q Do you know whether prior to your taking

10 on the case in October of '97 Mr. Thomas ever had

11 been given the role of lead detective?

12 A I have been told no.

13 Q You understand that the primary reason for

14 your deposition today, at least this portion of it,

15 is to talk about Chris Wolf?

16 A That's my understanding.

17 Q And you understand that Chris Wolf has

18 filed a lawsuit against John and Patsy Ramsey in

19 Atlanta, Georgia, making allegations of libel in

20 connection with the publication of their book "The

21 Death of Innocence" and also allegations about an

22 intentional infliction of emotional distress. You

23 may not know the details of the case but I take it

24 you're aware of the fact that he's filed a lawsuit

25 and that's why we're here, in part, today?

24

1 A Correct.