10 Q If, as you recall, Mr. Ubowski said I
11 don't believe Chris Wolf wrote the note?
12 A Um-hum.
13 Q But you don't know whether --
14 MR. MILLER: You've got to say yes, Mark.
15 A Yes.
16 Q (BY MR. WOOD) But you don't recall
17 whether it was a situation where he found any
18 similarities but nonetheless did not feel that he
19 wrote it. You don't know whether he found
20 similarities or not?
21 A Again you're asking me detailed
22 questions --
23 Q Yeah, I want to make sure that --
24 A -- I didn't have conversations with
25 Mr. Ubowski.
1 Q Who did?
2 A I'm telling you secondhand information
3 that --
4 Q Okay. Who would have had those
6 A I don't know for sure, probably Tom
8 Q Okay. Any reason why Trujillo as opposed
9 to, say, Wickman?
10 A Tom Trujillo being the primary
11 investigator was responsible for getting samples sent
12 to CBI and getting those reports back.
13 Q Okay. I'm still, and I don't want to get
14 beyond where Mr. Miller doesn't want me to go, but
15 I'm trying to figure out, I mean, I know from
16 information that there were varying opinions on Patsy
17 Ramsey's handwriting. And I'm trying to find out
18 what the police department's policy was because it
19 seems that it would apply to all individuals perhaps
20 why you wouldn't have a second person look at Chris
21 Wolf since you had four people on board and you know
22 that in other instances you had conflicting opinions.
23 Does that make sense? I may not be asking
24 the question.
25 A No, it doesn't make sense.
1 Q In other words, Chet Ubowski may have said
2 one thing but Richard Dusak may have disagreed,
3 right? I mean, that happened I take it?
4 A I'm not aware of that happening.
5 Q Do you think they were always in
7 A In relation to who? Who are you talking
8 about now?
9 Q Anyone. I don't want to try to get into
10 specific names; I want to know if they were always in
11 agreement. Because if they're not and I understand,
12 at least my understanding is on one particular person
13 they were not in agreement. Why you would decide to
14 stop at Ubowski and not have one of the other
15 examiners look at Chris Wolf.
16 MR. MILLER: I'm going to object because I
17 think it's been asked and answered. I think he
18 already answered your question.
19 Q (BY MR. WOOD) Was Ubowski the end-all of
20 the situation in terms of handwriting? Once you got
21 Ubowski's opinion, that was good?
22 A In some cases.
23 Q What would make the difference between the
24 cases where it was good and the cases where you would
25 take it to someone else?
1 A Well, I think you have to look at it in --
2 you're looking at it in a vacuum. When you're
3 looking at handwriting, we're looking at the whole
4 case and all the evidence combined.
5 And we're looking for things that
6 corroborate other evidence. And if you have
7 somebody, for instance, whether it's this case or
8 another case, that you have got some evidence that
9 you can put them at the scene and now you have a
10 handwriting expert that says, yeah, there's some
11 similarities there, that's corroborating evidence.
12 That's building that person up as a stronger suspect
13 in the case.
14 If you have -- if you run down these leads
15 and you have no evidence that pans out in any of
16 these other areas, fingerprints, hair, DNA, whatever.
17 Q Witnesses, alibi?
18 A Witnesses, alibis, and the handwriting
19 comes back negative, well, that's corroborating why
20 nothing else is lining up as well. So it's you can't
21 look at it in a vacuum.
22 Q The handwriting is not -- would not be
23 looked at in a vacuum to determine the ultimate issue
24 of whether someone was believed to be involved or not
25 involved in the case. You have to look at, as you
1 say, all of the evidence; is that right?
2 A That's correct.
3 Q So the fact that Ubowski reached the
4 opinion that Wolf, he did not believe, wrote the
5 note, that in and of itself would not eliminate or
6 exclude Chris Wolf from being involved in the crime,
7 would it?
8 A Correct.
9 Q And again, I'm not trying to get you to
10 pin this down, but I want to make sure that you're
11 not pinning yourself down. When you said Ubowski
12 said, I don't believe he wrote it, you're not saying
13 that from the standpoint of whether he said no
14 indications or elimination or whatever, you just
15 remember that you were informed that Ubowski didn't
16 believe Wolf wrote the note; is that right?
17 A Correct.
18 Q The formal findings as such would be
19 contained in the written materials submitted by
20 Ubowski back to your department?
21 A Correct.
22 Q Okay. Were there -- you're confident
23 there were materials, written materials, submitted
24 back to the Boulder Police Department on Wolf?
25 A Yes.
1 Q By CBI?
2 A Yes.
3 Q That would have been the case in any
4 handwriting analysis done by CBI or any of the other
5 individuals who were hired by the Boulder PD?
6 A Yes.
7 Q Okay. Why did the Boulder Police
8 Department analyze Chris Wolf's handwriting?
9 A Well, again, there were a number of
10 factors, one of which being his girlfriend came
11 forward and gave some incriminating statements
12 indicating she thought he might be involved. And so
13 that is what initially brought him to the police
14 department's attention. Again this is prior to me
15 being on the case.
16 Q Right.
17 A So I'm giving you --
18 Q Your understanding --
19 A -- hearsay of the, you know, testimony
21 Q But your understanding is when you took on
22 the role of being in charge of the investigation in
23 October of '97 I'm sure you went back, to the best of
24 your ability, to familiarize yourself with what had
25 been done in the investigation from the time of her
1 death up until the time you took on the role?
2 A Yes.
3 Q Okay. So while it's not I wasn't there at
4 the time, it's still we get an educated --
5 A I just want to make it clear I'm not
6 giving you -- I'm not giving you firsthand
7 information --
8 Q I understand.
9 A -- I just want to make it clear.
10 Q Right. But your understanding from your
11 review of the investigation was that Chris Wolf had
12 been brought to the attention of the Boulder Police
13 Department by his then girlfriend, an individual who
14 I believe you would agree is Jackie or Jacqueline
16 A Yes.
17 Q Okay. If I tell you I believe that
18 occurred in January of 1997, does that sound about
19 right to you in terms of when Ms. Dilson first
20 approached the Boulder police?
21 A Yes, that's my understanding.
22 Q Was it -- as a result of Ms. Dilson's
23 information, did Chris Wolf become a suspect in the
24 JonBent Ramsey murder investigation?
25 A I wouldn't call him a suspect.